Declaration of Meredith K. Loretta in Support of JPMorgan Chase Bank's Reply — Blue Flame v. Chain Bridge Bank

Summary

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, Eastern District of Virginia, Alexandria Division), Meredith K. Loretta declares in support of JPMorgan Chase Bank, N.A.'s (JPMC) Reply in Support of Motion for Summary Judgment. The declaration identifies Loretta as an attorney at Wilmer Cutler Pickering Hale and Dorr LLP and counsel for Third-Party Defendant JPMC. It attaches excerpts of the expert reports of Thomas C. Baxter, Jr. and Charles H. Grice, deposition transcript excerpts, a March 25, 2020 email titled "RE: NEW business account needed" from Mike Gula to Maria Cole, and a publication titled "FedLine Training for Account Holders" dated January 2002. It is executed May 27, 2021, with /s/ Meredith K. Loretta.

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Full text

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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
(Alexandria Division)
BLUE FLAME MEDICAL LLC,

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

Defendants.

Civil Action No. 1:20-cv-00658 (LMB/IDD)

CHAIN BRIDGE BANK, N.A.,

Third-Party Plaintiff,
v.
JPMORGAN CHASE BANK, N.A.,

Third-Party Defendant.

DECLARATION OF MEREDITH K. LORETTA IN SUPPORT OF
JPMORGAN CHASE BANK, N.A.’S REPLY IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT

Meredith K. Loretta, an attorney duly admitted to practice law in the Commonwealth of
Virginia, declares as follows:
1.
I am an attorney at Wilmer Cutler Pickering Hale and Dorr LLP, and counsel for
Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) in the above-captioned case.  I
make this declaration based upon my personal knowledge and documents provided to me, in
support of JPMC’s Reply in Support of Motion for Summary Judgment.
2.
Attached hereto as Exhibit 1 is a true and accurate copy of excerpts from the
Expert Report of Thomas C. Baxter, Jr. dated March 12, 2021.
Case 1:20-cv-00658-LMB-IDD     Document 158-1     Filed 05/27/21     Page 1 of 2 PageID#
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3.
Attached hereto as Exhibit 2 is a true and accurate copy of excerpts from the
Expert Report of Charles H. Grice, dated February 12, 2021.
4.
Attached hereto as Exhibit 3 is a true and accurate copy of excerpts from the
transcript of the deposition of John J. Brough, taken on February 2, 2021.
5.
Attached hereto as Exhibit 4 is a true and accurate copy of excerpts from the
transcript of the deposition of Charles H. Grice, taken on April 9-10, 2021.
6.
Attached hereto as Exhibit 5 is a true and accurate copy of an email titled “RE:
NEW business account needed” from Mike Gula to Maria Cole dated March 25, 2020 at
12:25:54 p.m., produced by Chain Bridge, bearing Bates numbers CBB00001514-
CBB00001517.
7.
Attached hereto as Exhibit 6 is a true and accurate copy of excerpts from a
publication titled “FedLine Training for Account Holders” dated January 2002 and previously
archived on the Federal Reserve Bank of Minneapolis’s website, available at
https://tinyurl.com/2ehk6kpr.

Executed on:  May 27, 2021

/s/ Meredith K. Loretta

Washington, DC

Meredith K. Loretta

Case 1:20-cv-00658-LMB-IDD     Document 158-1     Filed 05/27/21     Page 2 of 2 PageID#
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