right to supplement these objections , including through motions in limine and in light of any

Date: 2021-04-29

Summary

JPMorgan Chase Bank, N.A.'s objections to Chain Bridge Bank, N.A.'s designation of witnesses whose testimony is to be presented by deposition, filed April 29, 2021 as Document 106 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., Civil Action No. 1:20-cv-00658, in the U.S. District Court for the Eastern District of Virginia. JPMC, the third-party defendant, responds under Federal Rule of Civil Procedure 32(a) to the designation at Dkt. 94. It objects to the extent any designated witness is not unavailable and reserves the right to supplement its objections, including through motions in limine. A table lists each designated deponent with an objection under Fed. R. Evid. 106 to incomplete portions of testimony, plus scope objections for two corporate designee depositions. The five-page filing ends with a certificate of service.

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Case 1:20-cv-00658-LMB-IDD Document 106 Filed 04/29/21 Page 1 of 5 PageID# 837

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

BLUE FLAME MEDICAL LLC,

Plaintiff,

CHAIN BRIDGE BANK, N.A.,
JOHN J. BROUGH, and Civil Action No. 1:20-cv-00658
DAVID M. EVINGER,

Defendants.

CHAIN BRIDGE BANK, N.A.,

Third-Party Plaintiff,

JPMORGAN CHASE BANK, N.A.,

Third-Party Defendant.

JPMORGAN CHASE BANK, N.A.’S OBJECTIONS TO
CHAIN BRIDGE BANK, N.A.’s RULE 26(a)(3)(A)(ii) DESIGNATION OF WITNESSES
WHOSE TESTIMONY IS TO BE PRESENTED BY DEPOSITION

Under Federal Rule of Civil Procedure 26(a)(3)(B) and Federal Rule of Civil Procedure

32(a), Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) submits the following

objections to Defendant/Third-Party Plaintiff Chain Bridge Bank, N.A.’s Rule 26(a)(A)(ii)

designation of witness testimony to be presented by deposition (Dkt. 94). JPMC reserves the

right to supplement these objections, including through motions in limine and in light of any

rulings thereupon. The parties have not yet designated the specific portions of depositions to be

presented at trial; JPMC reserves the right to object on any grounds to any such portions
Case 1:20-cv-00658-LMB-IDD Document 106 Filed 04/29/21 Page 2 of 5 PageID# 838

designated by Chain Bridge. Under Federal Rule of Civil Procedure 32(a), JPMC objects to

Chain Bridge’s designations to the extent that any designated witness is not unavailable.

Witness Whose Testimony Is to Be Objection
Presented by Deposition
Ethan Bearman (January 21, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Bearman’s
deposition that may confuse the issues or
mislead the jury as to his testimony.
California State Controller’s Office 30(b)(6) JPMC objects under Fed. R. Evid. 106 to any
(Richard Chivaro) (March 4, 2021) incomplete portions of Mr. Chivaro’s Rule
30(b)(6) deposition that may confuse the
issues or mislead the jury as to his testimony.
JPMC further objects to testimony that
exceeds the scope of the Rule 30(b)(6) topics
designated for this deposition.
Timothy Coffey (February 11, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Coffey’s
deposition that may confuse the issues or
mislead the jury as to his testimony.
Natalie Gonzales (January 28, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Ms. Gonzales’s
deposition that may confuse the issues or
mislead the jury as to her testimony.
Michael Gula (January 12, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Gula’s deposition
that may confuse the issues or mislead the
jury as to his testimony.
Daniel Kim (March 29, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Kim’s deposition
that may confuse the issues or mislead the
jury as to his testimony.
Rakesh Korpal/JPMC 30(b)(6) (February 9, JPMC objects under Fed. R. Evid. 106 to any
2021) incomplete portions of Mr. Korpal’s
individual and/or Rule 30(b)(6) deposition
that may confuse the issues or mislead the
jury as to his testimony. JPMC further
objects to testimony that exceeds the scope of
the Rule 30(b)(6) topics designated for this
deposition.
Mathew Littman (April 12, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Littman’s
deposition that may confuse the issues or
mislead the jury as to his testimony.

2
Case 1:20-cv-00658-LMB-IDD Document 106 Filed 04/29/21 Page 3 of 5 PageID# 839

Stephanie Smith (April 12, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Ms. Smith’s
deposition that may confuse the issues or
mislead the jury as to her testimony.
Andrew Sturmfels (February 10, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Sturmfels’s
deposition that may confuse the issues or
mislead the jury as to his testimony.
John Thomas (January 11, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Thomas’s
deposition that may confuse the issues or
mislead the jury as to his testimony.
Michael Wong (January 19, 2021) JPMC objects under Fed. R. Evid. 106 to any
incomplete portions of Mr. Wong’s
deposition that may confuse the issues or
mislead the jury as to his testimony.

Dated: April 29, 2021

Respectfully submitted,

WILMER CUTLER PICKERING HALE
AND DORR LLP

/s/ Meredith K. Loretta
Meredith K. Loretta (92369)
Whitney Russell (pro hac vice)
Albinas J. Prizgintas (pro hac vice)
1875 Pennsylvania Avenue N.W.
Washington, DC 20006
Tel.: (202) 663-6981
meredith.loretta@wilmerhale.com

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

Felicia Ellsworth (pro hac vice)
60 State Street
Boston, MA 02109
Tel.: (617) 526-6000
felicia.ellsworth@wilmerhale.com

3
Case 1:20-cv-00658-LMB-IDD Document 106 Filed 04/29/21 Page 4 of 5 PageID# 840

Margarita M. Botero (pro hac vice)
1225 17th Street, Suite 2600
Denver, CO 80202
Tel.: (720) 274-3135
margarita.botero@wilmerhale.com

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

4
Case 1:20-cv-00658-LMB-IDD Document 106 Filed 04/29/21 Page 5 of 5 PageID# 841

CERTIFICATE OF SERVICE

I certify that on this 29th day of April, 2021, I electronically filed the foregoing using the

Court’s CM/ECF system, which will then send a notification of such filing to all counsel of

record.

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

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