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working with him to fill extremely large orders for PPE. I think he also talked about other
Date
2021-05-06
Full text
EXHIBIT 42
Case 1:20-cv-00658-LMB-IDD Document 130-42 Filed 05/06/21 Page 1 of 3 PageID#
1791
From:
Michael Gula
Sent:
Saturday, May 9, 2020 5:57 PM PDT
Brielle Appelbaum
To:
Subject:
Fwd: My memory of the call with Chain Bridge Bank
Begin forwarded message:
From: MICHAEL CASE <bcase@mbcase.net>
Date: May 9, 2020 at 8:22:27 PM EDT
To: Mike Gula <mike@blueflame.agency>
Subject: My memory of the call with Chain Bridge Bank
Mike: In case you want to pass along to your counsel, here's my memory of the call with Chain Bridge
Bank:
•
One afternoon in late March 2020, Mike and I were on the phone talking about his new business.
A call came in for Mike; he said it was his bank and that he wanted to give them a heads up about
a large incoming wire transfer from California. He asked me to listen in. I agreed. Mike merged the
calls.
•
Two officials from Chain Bridge Bank (the "Bank") introduced themselves. One was the CEO,
while the other seemed like a high-level executive. From the conversation I could tell that Mike
had already told them I was on the line.
•
Mike started out the call by indicating that he wanted to give them a heads up about a ~$450M
wire that would be coming in soon from the State of California.
•
Mike explained that he had a new business concerning medical supplies that had been
remarkably successful in its very early days. One of the Bank officials interrupted him almost
immediately, assuring him that he could speak freely because the conversation was protected by
the Bank Secrecy Act.
•
Mike went on to speak quite frankly with them, e.g., "I know this is hard to believe, to go from
deposits of hundreds of thousands a year to doing transactions in the hundreds of millions. But
this is what is happening." Mike said that his partner was in California. He said the partner had a
very good friend with access to lots of manufacturing facilities in China, and they would be
working with him to fill extremely large orders for PPE. I think he also talked about other
manufacturers they had lined up. Mike said that some of the funds that were being wired would
be transferred to the manufacturers to purchase the supplies, while tens of millions of dollars
would remain in his company's account with the Bank.
CONFIDENTIAL
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•
The Bank officials then talked for a few minutes. They started out with some positive comments
about Mike and his late partner Jon, acknowledging that the Bank had worked with them for
years and it had been great to watch their business grow.
•
The Bank officials said the first issue for them would be that such a large transfer of funds into
the Bank would somehow throw their holdings out of whack. The implication was that it was
something for them to figure out on their end.
•
The Bank officials then noted that the funds would obviously be well in excess of FDIC coverage
limits, and said that they had a program that could spread the account proceeds across accounts
at other institutions so they would be covered by FDIC insurance. I think they were referring to a
sweep-account program. There was a little discussion about the particular program the Bank
used, including the program's namesake.
•
One of the Bank officials said that further documentation about Mike's business would be useful.
Mike said that his company would be happy to provide whatever information the Bank needed
and that he would put them in touch with his company's attorney.
•
The Bank officials never: discouraged the transaction, indicated they were unable to handle it, or
suggested it was fraudulent. They gave no indication that they may reject it or that they could not
accept it unless certain prerequisites were met.
•
At the tail end of the call, they asked about me. I said a few words about myself: that I was a
labor attorney in Denver; that Mike and I had known each other for almost 30 years; and that
Mike and I were the best men in each other's weddings. I said that I was not representing anyone
here, and particularly not Mike's company, which has its own lawyer. I said things were moving a
lightning speed for Mike with this new business, that I cared about him, and I had agreed to just
be an extra set of ears for the call.
•
The entire call lasted about 20 minutes. If at least one of the Bank officials was using the Bank's
landlines, I suspect it was recorded.
CONFIDENTIAL
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