JPMorgan Chase Bank, N.A.'s Consent Motion for Extension of Time — Blue Flame Medical LLC v. Chain Bridge Bank (Document 54)

Date: 2021-01-15

Summary

A consent motion for extension of time to complete discovery, filed October 28, 2020 as Document 54 by third-party defendant JPMorgan Chase Bank in Blue Flame Medical LLC v. Chain Bridge Bank, 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 recites the Rule 16(b) Scheduling Order of September 24, 2020 and the Third-Party Complaint that Chain Bridge filed against JPMC on October 13, 2020. It asks the court to move the opening expert report deadline from November 23, 2020 to January 22, 2021, the rebuttal expert report deadline from December 23, 2020 to February 23, 2021, and the close of discovery from January 15, 2021 to March 19, 2021. It states that Chain Bridge and Blue Flame consented and that a proposed order is attached as Exhibit A.

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Cite this document

“JPMorgan Chase Bank, N.A.'s Consent Motion for Extension of Time — Blue Flame Medical LLC v. Chain Bridge Bank (Document 54).” Original at ecf.vaed.uscourts.gov, dated 2021-01-15. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-01-15-plaintiff-v-chain-bridge-bank-n-a/, SHA-256 5bc3589a841abe68444beb3629e887f9a6e0898b9865173399602b532e6c2d76.

Full text

Case 1:20-cv-00658-LMB-IDD Document 54 Filed 10/28/20 Page 1 of 3 PageID# 391

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,

JPMORGAN CHASE BANK, N.A.,

Third-Party Defendant.

JPMORGAN CHASE BANK, N.A.’S CONSENT MOTION FOR EXTENSION OF TIME
TO COMPLETE DISCOVERY

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”) submits this consent motion for an extension

of time (the “Consent Motion”) to complete discovery, and states as follows:

1. On September 24, 2020, this Court issued a Rule 16(b) Scheduling Order (ECF

No. 37), setting forth a January 15, 2021, deadline for all discovery. At the time, this case was a

bilateral dispute between Plaintiff Blue Flame Medical LLC and Defendants Chain Bridge Bank,

N.A., John J. Brough, and David M. Evinger.

1
Case 1:20-cv-00658-LMB-IDD Document 54 Filed 10/28/20 Page 2 of 3 PageID# 392

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

Complaint against JPMC.

3. JPMC has filed this same day a consent motion (ECF No. 52) seeking an

extension of its time to answer or otherwise respond to the Third-Party Complaint until

November 16, 2020.

4. After the filing of its answer or otherwise responding to the Third-Party

Complaint, and based on this Court’s Rule 16(b) Scheduling Order, JPMC and Chain Bridge will

have less than two months to complete fact and expert discovery with respect to Chain Bridge’s

Third-Party Complaint, which JPMC and Chain Bridge believe is insufficient given the issues in

this case, particularly in light of demands of other cases, anticipated scheduling conflicts, and the

upcoming holidays. JPMC therefore requests that this Court extend the following: (1) deadline

to serve opening expert reports from November 23, 2020, to January 22, 2021; (2 ) deadline to

serve rebuttal expert reports from December 23, 2020, to February 23, 2021; and (3) deadline to

conclude all discovery from January 15, 2021, to March 19, 2021.

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

for Plaintiff Blue Flame Medical regarding the requested extension. On October 27, Chain

Bridge Bank, through counsel, consented to the requested relief. On October 28, Blue Flame,

through counsel, consented to the requested relief.

6. JPMC has not previously requested any extension of discovery. Chain Bridge

Bank and Blue Flame have agreed to this extension and would not suffer any prejudice by the

Court granting JPMC’s requested extension of time. A hearing is waived on this Consent

Motion.

7. A proposed order is attached as Exhibit A.

2
Case 1:20-cv-00658-LMB-IDD Document 54 Filed 10/28/20 Page 3 of 3 PageID# 393

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

discovery deadlines as set forth in paragraph 4 of this Consent Motion.

Dated: October 28, 2020 Respectfully submitted,

WILMER CUTLER PICKERING HALE AND
DORR LLP

/s/ Meredith K. Loretta
Meredith K. Loretta (92369)
1875 Pennsylvania Avenue N.W.
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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