JPMorgan Chase Bank, N.A.'s Consent Motion for Extension of Time — Blue Flame Medical LLC v. Chain Bridge Bank (Document 52)

Summary

JPMorgan Chase Bank, N.A.'s consent motion for extension of time to file a response to a third-party complaint, filed October 28, 2020 as Document 52 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. The motion states that Chain Bridge Bank, N.A. filed its Third-Party Complaint (ECF No. 43) against JPMorgan Chase on October 13, 2020 and served it on October 19, 2020, making the response due November 9, 2020. It reports that Chain Bridge Bank consented on October 27, 2020 to a seven-day extension and asks the Court to extend the deadline to November 16, 2020, citing Federal Rule of Civil Procedure 6(b)(1) and Local Civil Rule 7.1. The three-page motion is signed by Wilmer Cutler Pickering Hale and Dorr LLP.

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Case 1:20-cv-00658-LMB-IDD             Document 52       Filed 10/28/20    Page 1 of 3 PageID# 386




                         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,                                   CONSENT MOTION

                                    Defendants.


   CHAIN BRIDGE BANK, N.A.,

                          Third-Party Plaintiff,

   v.

   JPMORGAN CHASE BANK, N.A.,

                          Third-Party Defendant.


  JPMORGAN CHASE BANK, N.A.’S CONSENT MOTION FOR EXTENSION OF TIME
           TO FILE A RESPONSE TO THIRD-PARTY COMPLAINT

         Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Local Civil Rule 7.1, Third-Party

  Defendant JPMorgan Chase Bank, N.A. (“JPMC”) respectfully submits this consent motion for

  an extension of time (the “Consent Motion”) to file an answer or otherwise respond to Third -

  Party Plaintiff Chain Bridge Bank, N.A.’s (“Chain Bridge Bank”) Third-Party Complaint (ECF

  No. 43), and states as follows:

         1.       On October 13, 2020, Chain Bridge Bank, N.A. filed its Third-Party Complaint

  against JPMC.




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Case 1:20-cv-00658-LMB-IDD          Document 52       Filed 10/28/20     Page 2 of 3 PageID# 387




         2.     On October 19, 2020, Chain Bridge Bank served JPMC with the Third-Party

  Complaint.

         3.     Thus, in accordance with Federal Rule of Civil Procedure 12, the deadline for

  JPMC to answer or otherwise respond to the Third-Party Complaint is November 9, 2020.

         4.     JPMC, through its counsel, consulted with counsel for Chain Bridge Bank

  regarding an extension of time for JPMC to answer or otherwise respond to the Third-Party

  Complaint. On October 27, 2020, Chain Bridge Bank, through counsel, consented to the

  requested relief, and the parties agreed to extend the deadline for JPMC to answer or otherwise

  respond to the Third-Party Complaint by seven days, until November 16, 2020.

         5.     JPMC believes this short extension will permit it to meaningfully consider how to

  respond to the Third-Party Complaint.

         6.     JPMC has not previously requested any extension of time to answer or otherwise

  respond to the Third-Party Complaint. Chain Bridge Bank has agreed to this extension and

  would not suffer any prejudice by the Court permitting JPMC the requested extension of time. A

  hearing is waived on this Consent Motion.

         7.     A proposed order is attached as Exhibit A.

         In consideration of the foregoing, JPMC respectfully moves this Court to extend the time

  for JPMC to file its responsive pleading until November 16, 2020.




   Dated: October 28, 2020                       Respectfully submitted,

                                                 WILMER CUTLER PICKERING HALE
                                                 AND DORR LLP

                                                 /s/ Meredith K. Loretta
                                                 Meredith K. Loretta (92369)

                                                 2
Case 1:20-cv-00658-LMB-IDD   Document 52   Filed 10/28/20    Page 3 of 3 PageID# 388




                                       1875 Pennsylvania Ave NW
                                       Washington, DC 20006
                                       Tel.: (202) 663-6981
                                       meredith.loretta@wilmerhale.com

                                       Alan E. Schoenfeld (pro hac vice pending)
                                       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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