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Consent Motion to Amend Stipulated Confidentiality Agreement and Protective Order — Blue Flame Medical LLC v. Chain Bridge Bank

Date
2020-10-07

Summary

A Consent Motion to Amend Stipulated Confidentiality Agreement and Protective Order, filed November 17, 2020 as Document 65 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., John J. Brough, and David M. Evinger, Civil Action No. 1:20-cv-00658, in the U.S. District Court for the Eastern District of Virginia. Third-Party Defendant JPMorgan Chase Bank, N.A. states that the protective order entered October 7, 2020 (ECF No. 42) predates the Third-Party Complaint that Chain Bridge filed against it on October 13, 2020. JPMC asks the court to amend the order to add it as a party and make other changes, and states that Chain Bridge and Blue Flame consented on November 16, 2020. A proposed amended order is attached as Exhibit A, and the three-page motion is signed by Meredith K. Loretta of Wilmer Cutler Pickering Hale and Dorr LLP.

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Cite this document

“Consent Motion to Amend Stipulated Confidentiality Agreement and Protective Order — Blue Flame Medical LLC v. Chain Bridge Bank.” Original at ecf.vaed.uscourts.gov, dated 2020-10-07. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2020-10-07-p-l-a-i-n-t-i-f-f-v-chain-bridge-bank-n-a/, SHA-256 5807eea36ce03f108ca9db1ebd1757030e3cacfc59154c0505059e4025529e67.

Full text

Case 1:20-cv-00658-LMB-IDD          Document 65         Filed 11/17/20    Page 1 of 3 PageID# 456




                         IN THE UNITED STATES DISTRICT COURT
                        FOR THE EASTERN DISTRICT OF VIRGINIA
                                   (Alexandria Division)


   BLUE FLAME MEDICAL LLC,

                                 Plaintiff,
                                                      Civil Action No. 1:20-cv-00658
   v.

   CHAIN BRIDGE BANK, N.A.,
   JOHN J. BROUGH, and
   DAVID M. EVINGER,

                                 Defendants.


   CHAIN BRIDGE BANK, N.A.,

                         Third-Party Plaintiff,

   v.

   JPMORGAN CHASE BANK, N.A.,

                         Third-Party Defendant.


                         CONSENT MOTION TO AMEND
        STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”), submits this consent

  motion to amend the Stipulated Confidentiality Agreement and Protective Order in this case.

          1.    On October 7, 2020, this Court entered a Stipulated Confidentiality Agreement

  and Protective Order (ECF No. 42), governing the confidentiality of discovery material in this

  case. At that time, this case was a bilateral dispute between Plaintiff Blue Flame Medical LLC

  (“Blue Flame”) and Defendants Chain Bridge Bank, N.A. (“Chain Bridge”), John J. Brough, and

  David M. Evinger.




                                                  1
Case 1:20-cv-00658-LMB-IDD           Document 65        Filed 11/17/20      Page 2 of 3 PageID# 457




         2.      On October 13, 2020, Third-Party Plaintiff Chain Bridge filed a Third-Party

  Complaint against JPMC.

         3.      JPMC is not currently a party to the Stipulated Confidentiality Agreement and

  Protective Order, and it is therefore not protected or bound by its terms. JPMC therefore

  requests that this Court amend the Stipulated Confidentiality Agreement and Protective Order to

  add JPMC as a party thereto and make several other changes.

         4.      All parties to this action are in agreement that maintaining the confidentiality of

  certain discovery is necessary in this case, and as such, good cause exists for entry of an

  amended Protective Order.

         5.      JPMC, through counsel, consulted with counsel for Chain Bridge and counsel for

  Blue Flame regarding the requested amendment. On November 16, 2020, both Chain Bridge and

  Blue Flame, through their respective counsel, consented to the requested relief.

         6.      JPMC has not previously requested that this Court enter a protective order or

  amendment thereto. Chain Bridge and Blue Flame have agreed to the requested relief and would

  not suffer any prejudice by the Court granting JPMC’s requested amendment. A hearing is

  waived on this Consent Motion.

         7.      A proposed Amended Stipulated Confidentiality Agreement and Protective Order

  is attached as Exhibit A.




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Case 1:20-cv-00658-LMB-IDD   Document 65   Filed 11/17/20        Page 3 of 3 PageID# 458




  Dated: November 17, 2020             Respectfully submitted,

                                       WILMER CUTLER PICKERING HALE
                                       AND DORR LLP

                                       /s/ Meredith K. Loretta
                                       Meredith K. Loretta (92369)
                                       1875 Pennsylvania Ave NW
                                       Washington, DC 20006
                                       Tel.: (202) 663-6981
                                       meredith.loretta@wilmerhale.com

                                       Alan E. Schoenfeld (pro hac vice)
                                       7 World Trade Center
                                       250 Greenwich Street
                                       New York, NY 10007
                                       Tel.: (212) 230-8800
                                       alan.schoenfeld@wilmerhale.com

                                       Attorneys for Third-Party Defendant
                                       JPMorgan Chase Bank, N.A.




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