Expert Report Of William T. Baskett
- Date
- 2021-05-07
Source document: Expert Report Of William T. Baskett; document type: Expert report (damages/economics), plaintiff's side.
Full text
EXHIBIT 84 Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 1 of 20 PageID# 2129 CONFIDENTIAL IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ) BLUE FLAME MEDICAL LLC ) ) Plaintiff, ) ) v. ) Civil Action No. 1:20-cv-00658 ) CHAIN BRIDGE BANK, N.A., ) JOHN J. BROUGH, and ) DAVID M. EVINGER, ) ) Defendants. ) ) ) CHAIN BRIDGE BANK, N.A. ) ) Third-Party Plaintiff, ) ) v. ) ) JPMORGAN CHASE BANK, N.A. ) ) Third-Party Defendant. ) ) EXPERT REPORT OF WILLIAM T. BASKETT ON BEHALF OF PLAINTIFF BLUE FLAME MEDICAL, LLC Revised March 8, 2021 Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 2 of 20 PageID# 2130 CONFIDENTIAL TABLE OF CONTENTS I. BACKGROUND, SUMMARY OF ISSUES, AND OPINIONS ........................................ 1 A. Scope of Assignment ........................................................................................................... 1 B. Compensation ...................................................................................................................... 1 C. Background .......................................................................................................................... 1 D. Summary of Opinions .......................................................................................................... 2 II. SUMMARY OF PROCESS .................................................................................................. 3 III. DETERMINATION OF ECONOMIC DAMAGES .......................................................... 3 A. Lost Revenue and Unincurred Incremental Costs ............................................................... 3 B. Determination of Total Lost Revenue .................................................................................. 4 C. Determination of Unincurred Incremental Costs ................................................................. 5 D. Additional Items to Include ................................................................................................. 6 E. Referral Fees, Base Salary Increase, and Performance Bonus ............................................ 7 F. Lost Profits ........................................................................................................................... 8 G. Viability of Claim for Lost Profits ....................................................................................... 8 IV. Conditions .............................................................................................................................. 8 Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 3 of 20 PageID# 2131 CONFIDENTIAL I. BACKGROUND, SUMMARY OF ISSUES, AND OPINIONS A. Scope of Assignment 1. BCG Financial Forensics, LLC was engaged by Schulte Roth & Zabel LLP (“Counsel”) on behalf of its client, Blue Flame Medical LLC (“Blue Flame”). Counsel requested that I calculate the profits Blue Flame would have realized from sales of personal protective equipment (“PPE”) that were aborted in the event Blue Flame establishes that those sales would not have been aborted but for actions taken by Chain Bridge Bank, N.A., John J. Brough, and David M. Evinger (together, “Defendants”) and that Defendants are liable for damages in connection with those sales. 2. I have also been asked to review the reports and deposition testimony of any experts designated by Defendants and provide rebuttal opinions, if necessary. B. Compensation 3. I have been retained by Counsel through an expert search firm, which is compensated for my time spent in this matter at a rate of $600 per hour excluding testimony at deposition and trial, and $700 per hour for deposition and trial testimony. The fees paid are not contingent on the outcome of this matter. All opinions set forth in this report are my own. C. Background 4. It is my understanding that on March 25, 2020, Blue Flame notified Defendants that it had entered an agreement to sell 100 million N95 masks placed by the State of California. Blue Flame informed Defendants that the State of California soon would be sending a wire transfer in the amount of approximately $457 million dollars to Blue Flame’s account at Chain Bridge Bank as a 75 percent deposit for the order, which Blue Flame planned to use to pay the suppliers of the masks purchased by the State of California. Blue Flame also informed Defendants that it would use is profits from the State of California’s order to finance additional PPE orders placed by other customers. However, after receiving the approximately $457 million from the State of California via wire transfer on March 26, 2020, Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 4 of 20 PageID# 2132 CONFIDENTIAL 2 Chain Bridge Bank returned the funds to the State of California without Blue Flame’s consent. 5. As a result, Blue Flame has asserted that Defendants violated Federal Reserve Board Regulation J. Blue Flame also has asserted that Defendants tortuously interfered with the contract Blue Flame entered into with the State of California in connection with the order for 100 million N95 masks. In addition, Blue Flame has asserted that Defendants defamed Blue Flame by wrongfully casting aspersions on the business and character of Blue Flame in conversations with third parties. 6. In addition to the profit it would have realized from the State of California’s order, Blue Flame claims it suffered consequential damages related to other sales of PPE that Blue Flame had executed, negotiated, or was in the process of negotiating and which would have generated profits for the company but for Defendants’ actions. Specifically, I have been asked to assume for purposes of this opinion that Defendants’ actions caused those other sales to be aborted, including through depriving Blue Flame of capital that it intended to use to finance PPE purchases for customers by returning the wire transfer sent by the State of California to Blue Flame’s account on March 26, 2020, damage caused to Blue Flame’s supplier relationships, and reputational harm associated with Defendants’ statements to third parties and news reports regarding those statements and the California transaction. D. Summary of Opinions 7. Based upon my review of the facts presented in this case, financial records obtained from Counsel, and my knowledge, skill, training, education, and experience as a CPA and Forensic Accountant performing economic damages analyses and calculations, consulting, business valuations, auditing, tax preparation, and tax research since 1977, it is my opinion that for the period of March 25, 2020 through April 27, 2020, Blue Flame Medical, LLC has incurred Lost Profits of $168,574,049. 8. In making this determination, I have assumed that Blue Flame had the capacity to and would have delivered on the Lost Sales. These amounts will be updated as of the date of trial. Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 5 of 20 PageID# 2133 CONFIDENTIAL 3 II. SUMMARY OF PROCESS 9. My findings and opinions are presented with a reasonable degree of certainty based upon: (1) reviewing financial records provided by Counsel; (2) discussing the issues of the case with Counsel; (3) my knowledge, skill, training, education, and experience, including more than 35 years as a CPA and more than 20 years of practice in the specialty field of forensic accounting and damages calculations. A true and current copy of my curriculum vitae is attached hereto as Appendix A. 10. I obtained an understanding of the operations of Blue Flame through numerous discussions with Counsel and my own review and analysis of documents and information provided to me by Counsel. I requested additional documents where I thought necessary, including the transcripts of depositions of various witnesses. 11. Appendix B contains a listing of the documents and other information I have considered in forming the opinions set forth in this report. I was not asked to audit the accuracy or test the authenticity of the records provided to me, but rather relied on them as presented to me. Should additional information become available between now and trial, I will consider that information and update my opinions as necessary. 12. I prepared analysis schedules to calculate the various economic damages incurred by Blue Flame. III. DETERMINATION OF ECONOMIC DAMAGES A. Lost Revenue and Unincurred Incremental Costs 13. Lost Profits are defined as Lost Revenue less unincurred expenses, which I will refer to as Unincurred Incremental Costs. 14. Blue Flame has asserted that Chain Bridge Bank wrongfully returned a wire transfer of approximately $457 million sent by the State of California for the benefit of Blue Flame and thereby deprived Blue Flame of the seed capital it planned to use to expand its operations. As a result of Defendants’ actions, Blue Flame was unable to fulfill commitments to its suppliers, straining those relationships and negatively impacting Blue Flame’s supply chain. Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 6 of 20 PageID# 2134 CONFIDENTIAL 4 It also received a great deal of negative publicity, leading to the cancellation of a number of PPE orders and further reducing Blue Flame’s ability to make PPE sales. Those cancellations and lost sales resulted in Lost Revenue that Blue Flame otherwise would have earned. 15. To determine the total amount of Lost Revenue, I obtained from Blue Flame the following documentation concerning its aborted PPE sales: a. Purchase Orders; b. Sales Orders; c. Invoices; d. Wire Transfer Memos; e. Banking information 16. When an order is canceled by the customer, the expected cost to purchase the product is not incurred, nor are costs such as commissions payable to employees or affiliates involved in the sale of the product. Costs related to shipping, taxes, insurance, or foreign tariffs are not incurred, either, but since these costs are passed on to the customer, they have no impact on Blue Flame’s net profits. Therefore, the sum of the unincurred product purchase cost and unincurred sales commissions equals Blue Flame’s unincurred expenses, defined here as Unincurred Incremental Costs. 17. To determine the total amount of Unincurred Incremental Costs, I utilized the following information: a. Purchase Orders; b. Sales Orders; c. Invoices; d. Suppliers Pricing Sheets; e. Blue Flame Cost and Sales Pricing Sheets; f. Referral Fee Agreements 18. Lost Revenue less the Unincurred Incremental Costs equals Lost Profits. B. Determination of Total Lost Revenue 19. Revenue is determined by multiplying the quantity of product sold by the sales price. The quantity and sales price are obtained from purchase orders, sales orders, or invoices. I received a list of PPE orders from Blue Flame and its Counsel that either were canceled or Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 7 of 20 PageID# 2135 CONFIDENTIAL 5 never executed due Blue Flame’s financial and reputational troubles following the aborted order by the State of California for 100 million N95 masks. 20. I prepared an analysis schedule of these orders and requested and received various types of correspondence explaining why the customer did not move forward with its order or why Blue Flame could not deliver the order. Multiplying the quantity of product by the sales price on the canceled or unexecuted purchase order, sales order, or invoice provides the Lost Revenue from each customer. Summing the Lost Revenue from each canceled or unexecuted order results in Total Lost Revenue. C. Determination of Unincurred Incremental Costs 21. To determine Unincurred Incremental Costs related to Blue Flame’s Lost Revenue, I obtained Purchase Orders between Blue Flame and its suppliers, the Supplier Product Pricing Sheets, and Blue Flame’s Item Cost and Bulk Sales Pricing Sheets based on its suppliers’ product pricing data. Those documents reflect the actual price paid by Blue Flame (or that would have been paid by Blue Flame) for the product. Blue Flame’s Bulk Sales Pricing Sheets listed the recommended sales prices that Blue Flame intended to charge customers. Those prices had a built-in mark-up of 30%. Therefore, when using Blue Flame’s Bulk Sales Pricing Sheets, I divided the listed price by 1.3 to arrive at the price paid by Blue Flame for the product. 22. Applying the prices from these pricing sheets, I was able to determine the purchase cost for each non-delivered order by multiplying the quantity of product by its product cost. 23. It is my understanding that there was unprecedented demand for PPE products in March through May of 2020 and that prices were constantly changing. As a result, Blue Flame made frequent updates to the various pricing sheets. To account for these frequent price changes in determining the purchase cost Blue Flame would have incurred had the order been delivered, I referred to the pricing sheet for the date the order was placed as reflected in the purchase order, sales order, or invoice. By this method, I was able to accurately determine the price of the product that Blue Flame would have paid had Blue Flame’s sale not been aborted, in order to calculate an accurate lost profit for each aborted sale. Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 8 of 20 PageID# 2136 CONFIDENTIAL 6 24. I used the product purchase prices on the various pricing sheets to determine Blue Flame’s purchase costs for the non-delivered orders, defined here as Unincurred Product Purchase Cost. 25. In addition to product purchase cost, Blue Flame would have incurred sales commissions payable to Ethan Bearman, which Mr. Bearman’s Employment Agreement terms a “Performance Bonus.” The compensation portion of the Employment Agreement entitled Mr. Bearman to 1.5% of all Net Collected Sales, as defined in the Employment Agreement. In addition, this Performance Bonus was to be prorated for any partial Company Fiscal Year during the Employment Period or Initial Employment Period. Mr. Bearman’s employment period started on July 5, 2020. The Company Fiscal Year was from March 1, 2020 to February 28, 2021. Therefore, Mr. Bearman was employed by Blue Flame for 238 days, or approximately 65.2% of the Company Fiscal Year. Any Performance Bonus that Mr. Bearman would have received in Blue Flame’s first Fiscal Year would have been adjusted down to 65.2% of the calculated amount. Since these sales did not incur revenue, Mr. Bearman did not receive that commission. Therefore, Mr. Bearman’s performance bonus also is considered an Unincurred Expense and is included within Unincurred Incremental Costs. D. Additional Items to Include 26. As previously defined, Lost Profits is the Lost Revenue less the Unincurred Incremental Costs. In determining Blue Flame’s Lost Profits, I started by subtracting the direct unincurred cost for each line item of revenue from the revenue lost from each non-delivered order. However, there are additional items necessary to take into consideration in determining Lost Profits. 27. Blue Flame’s credit card processing vendor, Anedot Inc., charged Blue Flame’s customer a fee for processing its payment, which Blue Flame either agreed to cover up front or which Blue Flame refunded at the time the customer’s order was cancelled in certain instances. Those fees represent a cost that would not have been incurred had Blue Flame been able to finance customer purchases with the proceeds from the State of California’s order and had Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 9 of 20 PageID# 2137 CONFIDENTIAL 7 not been required to issue refunds. Therefore, I have included the Anedot's fees in the calculation of Blue Flame’s Lost Profit. 28. An additional cost Blue Flame would have incurred relates to a Referral Fee Agreement the company entered into with Brielle Appelbaum. That agreement entitled Ms. Appelbaum to a referral fee based on a percentage of Blue Flame’s Net Revenue on orders placed by customers referred by Ms. Appelbaum. In addition, Ethan Bearman was entitled to a base salary increase and a one-time bonus based on company performance. E. Referral Fees, Base Salary Increase, and Performance Bonus 29. Brielle Appelbaum was to receive through Inspire Capital and Development, LLC a referral fee of 5% of the first $50 million of Net Revenue she generated through customer referrals, 6% of the next $200 million, and 7% of Net Revenue in excess of $250 million. Net Revenue is defined as the sales price Blue Flame receives from the referred engagements subtracted by (i) any shipping, handling, credits, rebates, and adjustments of the products sold, (ii) the price of the products purchased, and (iii) any price reductions, refunds, and direct expenses. A calculation of Ms. Appelbaum’s Referral Fee is provided on Supporting Schedule 2. 30. Ethan Bearman was entitled to a base salary increase of $97,000 and a one-time annual performance bonus of $239,000 after monthly gross revenue exceeded $10 million. This $239,000 performance bonus was also subject to the previously mentioned adjustment for days worked in the First Fiscal year and would also be adjusted down to approximately 65.2% of $239,000, or $155,841, as reflected in Schedule 1. 31. Had the above mentioned performance events occurred, Blue Flame would have incurred additional cost in satisfying those obligations. Therefore, the costs related to the performance incentives of Mr. Bearman and Ms. Appelbaum must be subtracted from Blue Flame’s Lost Profits as Additional Unincurred Incremental Costs. Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 10 of 20 PageID# 2138 CONFIDENTIAL 8 F. Lost Profits 32. As previously defined, Lost Profits is Lost Revenue less Unincurred Incremental Costs.1 In determining Blue Flame’s Lost Profits, I have subtracted the direct unincurred cost for each line item of revenue from the revenue lost from each non-delivered order. G. Viability of Claim for Lost Profits 33. Lost Profits can only be claimed if the entity claiming the Lost Profits had the capacity to fulfill the sales or services requested of it. My analysis of Blue Flame’s operations, particularly in light of the large lost sale to the State of California and all of the subsequent lost sale activity in April and May 2020, indicates that the company could have achieved the profitability it envisioned but for Defendants’ actions and the resulting loss of capital and negative press coverage. IV. CONDITIONS 34. This report is not to be used for any reason other than its original purpose of determining Lost Profits for the above captioned lawsuit. In addition, this report is subject to change upon receipt of additional information. ~~~~~~~~~~~~~~~~~~~ 1 I have not calculated or included pre-judgment interest in determining Blue Flame’s Lost Profits for purposes of this report. However, I understand that pre-judgment interest is available as to Blue Flame’s claims under Virginia law, Va. Code Ann. §§ 8.01-382, 6.2-302, and federal law, 12 C.F.R. § Pt. 210, Subpt. B, App. B, at Section 4A-204. Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 11 of 20 PageID# 2139 CONFIDENTIAL 9 This report is not to be used for any reason other than its original purpose of determining Lost Profits for the captioned lawsuit I reserve the right to supplement or revise my opinions expressed in this report based on review of additional documents, depositions, testimony, or other information that becomes available prior to my trial testimony, without any obligation to revise and reissue this written report. For purposes of providing testimony at trial, I may illustrate my testimony with demonstrative aids such as graphs, charts, and/or slides. I also expressly reserve the right to rely on the opinions expressed by any other expert retained in this case. This report should be read in its entirety. __________________ William T. Baskett, CPA/CFF, CVA, CFE Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 12 of 20 PageID# 2140 Schedule 1 Page 1 of 3 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinger Lost Profits from Sale of PPE Customer Order Date Product Name and Description Quantity Unit Price Lost Net Revenue Unit Price Unincurred Purchase Cost Ethan Bearman Performance Bonus @ 1.5% [4A] Total Incremental Cost Lost Profits State of California 03/25/20 N95 Protective Mask 100,000,000 4.76 $ 476,000,000.00 $ [1] [2] 3.33 $ [3] 332,880,000.00 $ [3] 1,399,831.23 $ 334,279,834.56 $ 141,720,165.44 $ Idaho State Police 03/30/20 N95 Protective Mask - Cup Full Respirator 400 6.23 $ 2,492.00 [5] 2.81 $ [26] 1,122.00 13.40 1,138.20 1,353.80 Idaho State Police 03/30/20 N95 Protective Mask - (foldable ) 400 6.69 $ 2,676.00 [5] 2.70 $ [26] 1,080.00 15.61 1,098.31 1,577.69 Idaho State Police 03/30/20 Surgical Masks - Sterile 10 pcs/pack 200 1.03 $ 206.00 [5] 0.59 $ [26] 118.00 0.86 119.45 86.55 Maryland Dept of State Police 03/30/20 N95 Protective Mask - (foldable ) - Dasheng 400 6.69 $ 2,676.00 [40] 2.90 $ [26] 1,160.00 14.83 1,177.73 1,498.27 Maryland Dept of State Police 03/30/20 16.9 oz bottles of hand sanitizer 24 5.24 $ 125.76 [40] 2.76 $ [26] 66.24 0.58 69.58 56.18 Maryland Dept of State Police 03/30/20 Surgical mask- Sterile 10 pcs/pack 40 1.03 $ 41.20 [40] 0.59 $ [26] 23.60 0.17 24.36 16.84 Maryland Dept of State Police 03/30/20 Disposable Nonwoven Safety Coverall 100 12.00 $ 1,200.00 [40] 5.80 $ [26] 580.00 6.06 591.86 608.14 Maryland Dept of State Police 03/30/20 Digital thermometers 30 77.96 $ 2,338.80 [6] 40.00 $ [26] 1,200.00 11.14 1,251.14 1,087.66 Melbourne Airport Police 03/30/20 N95 Protective Mask - Foldable - Dasheng 400 6.69 $ 2,676.00 [7] 2.90 $ [26] 1,160.00 14.83 1,177.73 1,498.27 Melbourne Airport Police 03/30/20 16.9 oz bottles of hand sanitizer 36 5.24 $ 188.64 [7] 2.76 $ [26] 99.36 0.87 102.99 85.65 Florida Dept of Law Enforcement 03/31/20 N95 Protective Mask - Cup Full Respirator - Makrite 400 6.87 $ 2,748.00 [36] 3.30 $ [27] 1,320.00 13.97 1,337.27 1,410.73 Florida Dept of Law Enforcement 03/31/20 Face Shields - Antifog 600 4.50 $ 2,700.00 [36] 1.70 $ [27] 1,020.00 16.43 1,038.13 1,661.87 Florida Dept of Law Enforcement 03/31/20 16.9 oz bottles of hand sanitizer 504 9.54 $ 4,808.16 [36] 2.76 $ [27] 1,391.04 33.42 1,427.22 3,380.94 Florida Dept of Law Enforcement 03/31/20 Disposable caps 1,000 0.35 $ 350.00 [36] 0.18 $ [26] 180.00 1.66 181.84 168.16 Florida Dept of Law Enforcement 03/31/20 Disposable shoe covers 1,000 0.74 $ 740.00 [36] 0.38 $ [26] 380.00 3.52 383.90 356.10 Melbourne Police Dept 03/31/20 16.9 oz bottles of hand sanitizer 48 5.24 $ 251.52 [37] 2.76 $ [27] 132.48 1.16 136.40 115.12 Melbourne Police Dept 03/31/20 Surgical mask- Sterile 10 pcs/pack 100 1.03 $ 103.00 [37] 0.66 $ [27] 66.00 0.36 67.02 35.98 Arizona Dept of Public Safety 04/01/20 1 oz bottles of hand sanitizer 96 0.90 $ 86.40 [38] 0.47 $ [28] 45.12 0.40 45.99 40.41 Arizona Dept of Public Safety 04/01/20 2 oz bottles of hand sanitizer 96 1.20 $ 115.20 [38] 0.63 $ [28] 60.48 0.54 61.65 53.55 Iowa DCI Crime Laboratory 04/01/20 Surgical Masks - Sterile 10 pcs/pack - Xin Lun 2,000 1.33 $ 2,660.00 [8] 0.66 $ [28] 1,320.00 13.11 1,333.77 1,326.23 Santa Rosa County Sheriffs Office 04/01/20 N95 Protective Mask - Cup Full Respirator - Makrite 400 6.87 $ 2,748.00 [9] 3.10 $ [28] 1,240.00 14.75 1,257.85 1,490.15 Santa Rosa County Sheriffs Office 04/01/20 Disposable shoe covers 1,000 0.74 $ 740.00 [9] 0.38 $ [26] 380.00 3.52 383.90 356.10 Santa Rosa County Sheriffs Office 04/01/20 Coveralls 1,000 1.28 $ 1,280.00 [9] 5.80 $ [26] 5,800.00 (44.21) 5,761.59 (4,481.59) North Carolina State Bureau of Investigation 04/02/20 2 oz bottles of hand sanitizer 384 1.86 $ 714.24 [10] 0.63 $ [28] 241.92 4.62 247.17 467.07 North Carolina State Bureau of Investigation 04/02/20 16.9 oz bottles of hand sanitizer 108 9.54 $ 1,030.32 [10] 2.76 $ [28] 298.08 7.16 308.00 722.32 North Carolina State Bureau of Investigation 04/02/20 Disposable shoe covers 400 0.74 $ 296.00 [10] 0.38 $ [26] 152.00 1.41 153.79 142.21 North Carolina State Bureau of Investigation 04/02/20 Surgical Masks - Sterile 10 pcs/pack 500 1.33 $ 665.00 [10] 0.66 $ [28] 330.00 3.28 333.94 331.06 Oklahoma State Bureau of Investigation 04/02/20 N95 Protective Mask - Cup Full - Makrite 400 6.87 $ 2,748.00 [11] 3.10 $ [28] 1,240.00 14.75 1,257.85 1,490.15 Oklahoma State Bureau of Investigation 04/02/20 Surgical Masks - Sterile 10 pcs/pack 1,000 1.33 $ 1,330.00 [11] 0.66 $ [28] 660.00 6.55 667.21 662.79 St. John's Child Wellness Center 04/02/20 16.9 oz bottles of hand sanitizer 2,004 9.04 $ 18,116.16 [12] 2.76 $ [28] 5,531.04 123.09 5,656.89 12,459.27 St. John's Child Wellness Center 04/02/20 2 oz bottles of hand sanitizer 20,064 1.07 $ 21,468.48 [12] 0.63 $ [28] 12,640.32 86.35 12,727.30 8,741.18 St. John's Child Wellness Center 04/02/20 Disposable caps 30,000 0.35 $ 10,500.00 [12] 0.18 $ [26] 5,400.00 49.88 5,450.06 5,049.94 St. John's Child Wellness Center 04/02/20 Disposable surgical gowns - non sterile 30,000 1.82 $ 54,600.00 [12] 0.96 $ [28] 28,800.00 252.35 29,053.31 25,546.69 St. John's Child Wellness Center 04/02/20 Surgical Masks, ASTM level 2 ear loop 200,000 0.117 $ 23,400.00 [12] 0.66 $ [28] 132,000.00 (1,062.20) 130,938.46 (107,538.46) Takoma Park Police 04/02/20 2 oz bottles of hand sanitizer 192 1.86 $ 357.12 [13] 0.63 $ [28] 120.96 2.31 123.90 233.22 Takoma Park Police 04/02/20 27 oz bottles of hand sanitizer 12 13.67 $ 164.04 [13] 4.04 $ [28] 48.48 1.13 53.65 110.39 Dixie County Sheriff's Office 04/02/20 16.9 oz bottles of hand sanitizer 36 9.54 $ 343.44 [14] 2.76 $ [28] 99.36 2.39 104.51 238.93 Dixie County Sheriff's Office 04/02/20 27 oz bottles of hand sanitizer 12 13.67 $ 164.04 [14] 4.04 $ [28] 48.48 1.13 53.65 110.39 Dixie County Sheriff's Office 04/02/20 Digital Forehead Infrared Thermometers 2 77.96 $ 155.92 [14] 40.00 $ [28] 80.00 0.74 120.74 35.18 Douglas County Sheriff's Office 04/02/20 Digital Forehead Infrared Thermometers 10 77.96 $ 779.60 [15] 40.00 $ [28] 400.00 3.71 443.71 335.89 Marion County Sheriff's Office 04/02/20 N95 Protective Mask - Cup Full Respirator - Makrite 400 6.87 $ 2,748.00 [16] 3.10 $ [28] 1,240.00 14.75 1,257.85 1,490.15 Northern Arizona University 04/02/20 N95 Protective Mask - (foldable ) - Dasheng 800 6.89 $ 5,512.00 [17] 3.11 $ [28] 2,488.00 29.58 2,520.69 2,991.31 Northern Arizona University 04/03/20 2 oz bottles of hand sanitizer 288 1.86 $ 535.68 [17] 0.63 $ [28] 181.44 3.46 185.53 350.15 Northern Arizona University 04/03/20 Surgical Masks - Sterile 10 pcs/pack 1,000 1.33 $ 1,330.00 [17] 0.66 $ [28] 660.00 6.55 667.21 662.79 Riverside University Health System 04/03/20 N95 Protective Mask - Cup Full Respirator - Makrite 64,000 4.76 $ 304,640.00 [18] 3.10 $ [28] 198,400.00 1,039.11 199,442.21 105,197.79 Riverside University Health System 04/03/20 Disposable caps 100,000 0.34 $ 34,000.00 [18] 0.18 $ [26] 18,000.00 156.49 18,156.67 15,843.33 Riverside University Health System 04/03/20 Disposable shoe covers 100,000 0.63 $ 62,900.00 [18] 0.38 $ [26] 38,000.00 243.54 38,243.92 24,656.08 State of Alabama 04/06/20 N95 Protective Mask , Sekura (Makrite) 350,000 3.96 $ 1,386,000.00 [19] 3.10 $ [28] 1,085,000.00 2,944.03 1,087,947.13 298,052.87 State of Tennessee 04/06/20 N95 Protective Mask - (foldable ) 20 pcs/box 500,000 3.96 $ 1,980,000.00 [20] 3.12 $ [28] 1,560,000.00 4,107.95 1,564,111.07 415,888.93 State of Tennessee 04/06/20 Gowns (non-sterile) isolation 500,100 1.22 $ 610,122.00 [20] 0.96 $ [28] 480,096.00 1,271.76 481,368.72 128,753.28 Lone Star College 04/07/20 Disposable Nitrile Gloves 55 13.98 $ 768.90 [21] 8.67 $ [42] 476.81 2.86 488.33 280.57 North Carolina State Dept of Safety 04/07/20 N95 Protective Mask - Cup Full Respirator - Makrite 800 6.98 $ 5,584.00 [22] 3.10 $ [28] 2,480.00 30.36 2,513.46 3,070.54 North Carolina State Dept of Safety 04/07/20 2 oz bottles of hand sanitizer 192 1.86 $ 357.12 [23] 0.63 $ [28] 120.96 2.31 123.90 233.22 State of Alabama 04/08/20 N95 Protective Mask , Sekura (Makrite) 350,000 3.96 $ 1,386,000.00 [24] 3.10 $ [28] 1,085,000.00 2,944.03 1,087,947.13 298,052.87 Purchase Net Revenue Unincurred Incremental Costs CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 13 of 20 PageID# 2141 Schedule 1 Page 2 of 3 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinger Lost Profits from Sale of PPE Customer Order Date Product Name and Description Quantity Unit Price Lost Net Revenue Unit Price Unincurred Purchase Cost Ethan Bearman Performance Bonus @ 1.5% [4A] Total Incremental Cost Lost Profits Purchase Net Revenue Unincurred Incremental Costs State of Alabama 04/08/20 Disposable Isolation Gowns, non-sterile 200,000 1.22 $ 244,000.00 [24] 2.02 $ [46] 404,615.38 (1,570.95) 403,046.46 (159,046.46) State of Alabama 04/08/20 Disposable Nitrile Gloves, box of 100 50,000 8.68 $ 434,000.00 [24] 8.35 $ [46] 417,692.31 159.50 417,860.16 16,139.84 State of Washington 04/09/20 Disposable surgical gowns - sterile 2,600,000 10.43 $ 27,118,000.00 [31] 4.40 $ [28] 11,440,000.00 153,343.73 11,593,348.13 15,524,651.87 State of Washington 04/09/20 Disposable isolation gowns - non sterile 2,600,000 3.42 $ 8,892,000.00 [31] 2.63 $ [43] 6,840,000.00 20,070.25 6,860,072.88 2,031,927.12 South Carolina Law Enforcement Division 04/10/20 Anti Fog Safety Face Shields 900 4.62 $ 4,158.00 [39] 1.70 $ [43] 1,530.00 25.70 1,557.40 2,600.60 South Carolina Law Enforcement Division 04/10/20 16.9 oz bottles of hand sanitizer 120 9.54 $ 1,144.80 [39] 2.76 $ [28] 331.20 7.96 341.92 802.88 South Carolina Law Enforcement Division 04/10/20 Surgical mask- Sterile 10 pcs/pack - ear loop 4,000 1.35 $ 5,400.00 [39] 0.56 $ [43] 2,246.15 30.85 2,277.56 3,122.44 South Carolina Law Enforcement Division 04/10/20 Disposable Nonwoven Safety GOWN 7,500 5.36 $ 40,200.00 [39] 18.35 $ [43] 137,647.06 (953.11) 136,712.30 (96,512.30) State of Rhode Island (Quonset Development) 04/10/20 Disposable surgical isolatation gowns - sterile 400,000 10.02 $ 4,008,000.00 [35] 4.40 $ [28] 1,760,000.00 21,987.29 1,781,991.69 2,226,008.31 State of Rhode Island (Quonset Development) 04/10/20 Reg. Medical Face Mask 501,000 0.75 $ 377,754.00 [35] 0.56 $ [43] 281,330.77 943.10 282,274.43 95,479.57 State of Rhode Island (Quonset Development) 04/10/20 Digital Forehead Infrared Thermometers 1,000 48.33 $ 48,330.00 [35] 40.00 $ [43] 40,000.00 81.47 40,121.47 8,208.53 Medical University of South Carolina 04/11/20 Antifog Safety Face Shield 1,000,000 2.14 $ 2,140,000.00 [33] 1.70 $ [43] 1,700,000.00 4,303.56 1,704,305.26 435,694.74 Medical University of South Carolina 04/11/20 Box of 100 Nitrile Gloves - Medium 10,000 10.43 $ 104,300.00 [33] 8.35 $ [43] 83,538.46 203.06 83,749.88 20,550.12 Medical University of South Carolina 04/11/20 Box of 100 Nitrile Gloves - Large 10,000 10.43 $ 104,300.00 [33] 8.35 $ [43] 83,538.46 203.06 83,749.88 20,550.12 Medical University of South Carolina 04/11/20 Box of 100 Nitrile Gloves - XLarge 10,000 10.43 $ 104,300.00 [33] 8.35 $ [43] 83,538.46 203.06 83,749.88 20,550.12 Florida State Emergency Operations Center 04/14/20 N95 Protective Mask - Full Cup 1,000,080 5.01 $ 5,010,400.80 [32] 3.85 $ [45] 3,854,154.46 11,309.04 3,865,467.35 1,144,933.45 Florida State Emergency Operations Center 04/14/20 Disposable isolation gowns - non sterile 499,950 3.42 $ 1,709,829.00 [32] 2.63 $ [45] 1,315,253.08 3,859.28 1,319,114.98 390,714.02 University Hospital 04/15/20 Disposable isolation gowns - non sterile 100,000 3.42 $ 342,000.00 [34] 2.63 $ [45] 263,076.92 771.93 263,851.49 78,148.51 University Hospital 04/15/20 Medical Surgical Mask -non sterile 200,000 0.81 $ 162,000.00 [34] 0.58 $ [45] 115,384.62 455.94 115,841.13 46,158.87 San Mateo County, California 04/15/20 N95 Protective Mask - Full Cup 300,000 5.05 $ 1,515,000.00 [30] 3.85 $ [45] 1,156,153.85 3,509.81 1,159,667.51 355,332.49 San Mateo County, California 04/15/20 Disposable Nitrile Gloves size large - box of 100 2,000 10.86 $ 21,720.00 [30] 8.35 $ [45] 16,707.69 49.02 16,765.07 4,954.93 San Mateo County, California 04/15/20 Anti Fog Safety Goggle 200,000 3.38 $ 676,000.00 [30] 2.60 $ [28] 520,000.00 1,525.81 521,528.41 154,471.59 San Mateo County, California 04/15/20 Anti Fog Safety Face Shield 200,000 2.21 $ 442,000.00 [30] 1.70 $ [45] 340,000.00 997.64 340,999.34 101,000.66 San Mateo County, California 04/15/20 Disposable isolation gowns - non sterile 200,000 3.42 $ 684,000.00 [30] 2.63 $ [45] 526,153.85 1,543.87 527,700.34 156,299.66 State of Colorado 04/27/20 N95 Protective Mask - Cup Full Respirator 1,000,000 5.38 $ 5,380,000.00 [25] 4.35 $ [44] 4,353,846.15 10,036.63 4,363,887.14 1,016,112.86 State of Colorado 04/27/20 KN95 Protective Mask - Zhejiang Baiyi 1,000,000 2.52 $ 2,520,000.00 [25] 2.20 $ [44] 2,200,000.00 3,129.86 2,203,132.06 316,867.94 State of Colorado 04/27/20 Surgical Masks - Sterile 4,000,000 0.75 $ 3,000,000.00 [25] 0.62 $ [44] 2,480,000.00 5,086.03 2,485,086.65 514,913.35 State of Colorado 04/27/20 Nitrile Gloves - 100 pcs per box 30,000 17.98 $ 539,400.00 [25] 12.50 $ [44] 375,000.00 1,607.97 376,620.47 162,779.53 State of Colorado 04/27/20 Disposable Isolation Gowns, sterile 1,000,000 9.28 $ 9,280,000.00 [25] 8.02 $ [44] 8,020,000.00 12,323.84 8,032,331.86 1,247,668.14 Sub-total 556,859,517.34 $ 386,371,917.04 $ 1,667,508.86 $ 388,039,823.53 $ 168,819,693.81 $ Plus: Fees paid to Anedot by Blue Flame Medical on behalf of customers 17,540.27 [47] Refunds of transaction fees paid by customers to Anedot for cancelled transactions 37,655.29 [47] Less: Inspire Capital Referral Fee (47,998.85) [41] Increase in Base Salary of Ethan Bearman for monthly gross revenue exceeding $10 million (97,000.00) [4C] One time annual performance bonus for Ethan Bearman after monthly gross revenue exceeds $10 million (155,841.10) [4B] Total 556,859,517.34 $ 386,371,917.04 $ 1,667,508.86 $ 388,039,823.53 $ 168,574,049.43 $ CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 14 of 20 PageID# 2142 Schedule 1 Page 3 of 3 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinger Lost Profits from Sale of PPE Customer Order Date Product Name and Description Quantity Unit Price Lost Net Revenue Unit Price Unincurred Purchase Cost Ethan Bearman Performance Bonus @ 1.5% [4A] Total Incremental Cost Lost Profits Purchase Net Revenue Unincurred Incremental Costs [1] Per State of California - General Procurement Division - Purchasing Authority Purchase Order dated 3/25/20 - Bates # BFM00009550 [2] Per Invoice # 20032501 dated 3/25/20 from Blue Flame Medical LLC to State of California - Procurement Division, Michael Wong, Contract Administrator - Bates # BFM00011112 [3] Average of Great Health Companion - Order Confirmation dated 3/26/20 @ $3.30 per unit - Bates # BFM000013611 for 94,000,000 units @ $3.30 per unit and Blue Flame PO # BMM-20-0325-003 dated 3/25/20 to Suuchi Inc. for 6,000,000 units at $3.78 per unit - Bates # BFM00164 [4A] Per Executive Employment Agreement with Ethan Bearman, Esq. dated 7/5/20. [1.5% of Net Collected Sales (Income less Cost of Goods) X 65.205% (representing % of days employed during 1st fiscal year)] - Bates # BFM000206166 - 16 [4B] Per Executive Employment Agreement with Ethan Bearman, Esq. dated 7/5/20. [$249,000 X 65.205% (representing % of days employed during 1st fiscal year)] - Bates # BFM000206167 - 16 [4C] Per Executive Employment Agreement with Ethan Bearman, Esq. dated 7/5/20. Base Salary increase upon Blue Flame receiving $10 million in Gross Revenue - Bates # BFM000206167 [5] Per Purchase Order dated 3/30/20 from Blue Flame Medical , LLC to Idaho State Police - Bates # BFM000117675 & 76 [6] Per Purchase Order dated 3/31/20 from Blue Flame Medical , LLC to Maryland Dept of State Police - Bates # BFM000068602 & BFM000070516 [7] Per Purchase Order dated 3/30/20 from Blue Flame Medical , LLC to Melbourne Airport Police Department - Bates # BFM000068670 [8] Per Purchase Order dated 4/01/20 from Blue Flame Medical , LLC to Iowa DCI Crime Laboratory - Bates # BFM000112958 [9] Per Purchase Order dated 4/01/20 from Blue Flame Medical , LLC to Santa Rosa County Sheriff's Office- Bates # BFM000069248 & 49 [10] Per Purchase Order dated 4/02/20 from Blue Flame Medical , LLC to North Carolina State Bureau of Investigation - Bates # BFM000083715 & 16 [11] Per Purchase Order dated 4/01/20 from Blue Flame Medical , LLC to Oklahoma State Bureau of Investigations - Bates # BFM000118575 & 76 [12] Per Purchase Order dated 4/02/20 from Blue Flame Medical , LLC to St. John's Child Wellness Center - Bates # BFM000072936 [13] Per Purchase Order dated 4/02/20 from Blue Flame Medical , LLC to Takoma Park - Bates # BFM000072150 & 51 [14] Per Purchase Order dated 3/31/20 from Blue Flame Medical , LLC to Dixie County Sheriff's Office - Bates # BFM000070304 & 05 [15] Per Purchase Order dated 4/02/20 from Blue Flame Medical , LLC to Douglas County Sheriff's Office - Bates # BFM000083765 & 66 [16] Per Purchase Order dated 4/02/20 from Blue Flame Medical , LLC to Marion County Sheriff's Office - Bates # BFM000070518 [17] Per Purchase Order dated 4/03/20 from Blue Flame Medical , LLC to Northern Arizona University - Bates # BFM000070710 & 1 [18] Per Invoice # 1004 dated 4/2/20 & Purchase Order dated 4/03/20 from Blue Flame Medical , LLC to Suzanna Hinkley, Directir of Supply Chain Operations - Bates # BFM000029674 all refunded per Bates # BFM00002967 [19] Per Invoice # 1006 & Purchase Order dated 4/06/20 from Blue Flame Medical , LLC to ADPH - CEP Warehouse in Montgomery, Alabama - Bates # BFM000120286 & BFM00003212 [20] Per Invoice # 1005 dated 4/06/20 from Blue Flame Medical , LLC to Tennessee Emergency Management Agency - Bates # BFM000071193 [21] Per SO # 20200507-001 dated 5/06/20 from Blue Flame Medical , LLC to Lone Star College - Bates # BFM000086303 [22] Per Purchase Order dated 4/07/20 & 4/08/20 from Blue Flame Medical , LLC to North Carolina Dept of Safety - Bates # BFM000074067 & BFM00012099 [23] Per Purchase Order dated 4/07/20 from Blue Flame Medical , LLC to NC Dept of Pub Safety - Bates # BFM000074068 [24] Per SO # 20200408-001 & Purchase Order dated 4/08/20 from Blue Flame Medical , LLC to ADPH - CEP Warehouse in Montgomery, Alabama - Bates # BFM000046684 & BFM00015910 [25] Per PR-20200427-001 from Blue Flame Medical , LLC to State of Colorado - Bates # BFM000134376 [26] Price per GHC Products Catalogue on 3-24-20- BFM000012250 [27] Price per GHC Products Catalogue on 3-31-20- BFM000016576 [28] Price per GHC Products Catalogue on 4-01-20- BFM000069053 [29] Per Purchase Order dated 4/07/20 from Blue Flame Medical , LLC to Florida Department of Law Enforcement - Bates # BFM000117912 - 13 [30] Per SO # 20200415-002 from Blue Flame Medical, LLC to San Mateo County Procurement dated 4-15-20 Bates # BFM000047313 [31] Per SO # 20200409-001 dated 4/09/20 from Blue Flame Medical , LLC to Washington Warehouse - Bates # BFM000126777 [32] Per SO # 20200414-001 dated 4/14/20 from Blue Flame Medical , LLC to Florida State Emergency Operations Center - Bates # BFM000045779 [33] Per PO # 20200411-001 dated 4/11/20 from Blue Flame Medical , LLC to Medical University of South Carolina - Bates # BFM000122093 [34] Per Email exchange and product listing dated 4/7/20 - 4/14/20 between various people at Blue Flame Medical , LLC and Robert Sharbaugh of University Hospital - Bates # BFM000046411 - 46420 & per PR-20200416-001 from Great Health Companion Bates # BFM00012350 [35] Per PO-20200410-002 dated 4/10/20 from Blue Flame Medical , LLC to Quonset Development Corporation - Bates # BFM000121643 [36] Per Purchase Order dated 3/31/20 from Blue Flame Medical , LLC to Florida Department of Law Enforcement - Bates # BFM000117912 & 13 [37] Per Spreadsheet dated 4/3/20 reflecting PO dated 3/30/20 from Blue Flame Medical , LLC to Melbourne Police Department - Bates # BFM0000119296 [38] Per Purchase Order dated 4/01/20 from Blue Flame Medical , LLC to Arizona Department of Public Safety - Bates # BFM000069332 [39] Per Purchase Order dated 4/10/20 from Blue Flame Medical , LLC to South Carolina Law Enforcement Division - Bates # BFM000078540 [40] Per Purchase Order dated 3/30/20 from Blue Flame Medical , LLC to Maryland Police - Bates # BFM000070533 [41] See Schedule 2 [42] Price per Blue Flame Medical Bulk Price Sheet on 4-07-20 divided by 1.3 to allow for a 30% markup- BFM000020446 [43] Price per Blue Flame Medical Bulk Price Sheet on 4-09-20 divided by 1.3 to allow for a 30% mark-up- BFM000072442 [44] Price per Blue Flame Medical Cost Price Sheet on 4-27-20- BFM000058901 [45] Price per Blue Flame Medical Bulk Price Sheet on 4-13-20 divided by 1.3 to allow for a 30% mark-up- BFM00005890 [46] Price per Blue Flame Medical Bulk Price Sheet on 4-08-20 divided by 1.3 to allow for a 30% mark-up- BFM000002469 [47] See Schedule 3 CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 15 of 20 PageID# 2143 Schedule 2 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinger Calculation of Referral Fee for Inspire Capital Customer Order Date Lost Net Revenue Unincurred Purchase Cost Ethan Bearman, Esq. Bonus @ 1.5% [4] Total Incremental Cost Total Lost Profits Ethan Bearman, Esq. Bonus @ 1.5% [4] Total Lost Profits plus Ethan Bearman, Esq. Bonus A B C D = B + C E = A - D F G = E + F State of Alabama 04/06/20 1,386,000.00 $ 1,085,000.00 $ 2,944.03 $ 1,087,944.03 $ 298,055.97 $ 2,944.03 $ 301,000.00 $ State of Alabama 04/08/20 1,386,000.00 1,085,000.00 2,944.03 1,087,944.03 298,055.97 2,944.03 301,000.00 State of Alabama 04/08/20 244,000.00 404,615.38 (1,570.95) 403,044.43 (159,044.43) (1,570.95) (160,615.38) State of Alabama 04/08/20 434,000.00 417,692.31 159.50 417,851.81 16,148.19 159.50 16,307.69 Medical University of South Carolina 04/11/20 2,140,000.00 1,700,000.00 4,303.56 1,704,303.56 435,696.44 4,303.56 440,000.00 Medical University of South Carolina 04/11/20 104,300.00 83,538.46 203.06 83,741.53 20,558.47 203.06 20,761.54 Medical University of South Carolina 04/11/20 104,300.00 83,538.46 203.06 83,741.53 20,558.47 203.06 20,761.54 Medical University of South Carolina 04/11/20 104,300.00 83,538.46 203.06 83,741.53 20,558.47 203.06 20,761.54 Total 5,902,900.00 $ 4,942,923.08 $ 9,389.36 $ 4,952,312.44 $ 950,587.56 $ 9,389.36 $ 959,976.92 $ Calculaton of Referral Fee: 5.0% of first $50 million of Net Reveune 47,998 85 $ 6.0% of next $200 million in Net Revenue - 7.0% of Net Revenue over $250 million - [1] Total Referral Fee 47,998.85 $ [1] Per Referral Fee Agreement with Inspire Capital Development dated 4/6/20 - Bates # BFM000032048 - 32055. (Assumes that Inspire referrals were for the State of Alabama and Medical University of South Carolina) CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 16 of 20 PageID# 2144 Schedule 3 Page 1 of 4 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinger Anedot Fees charged to Blue Flame Medical, LLC Date Card Holder Agency email Telephone Gross Fee Charged to Blue Flame 4/10/2020 Steve Sligh South Carolina Law Enforcement Divsion ssligh@sled.sc.gov 410-379-9412 55,006.84 $ (0.30) $ 4/9/2020 Angela Hayes North Carolina Department of Safety angela.hayes@ncdps.gov 919-901-5167 (cell) 2,959.52 (0.30) 4/7/2020 Julianne Lacsina Lone Star College braxton.fonner@lonestar.edu 832-813-6620 4,970.23 (174.26) 4/7/2020 Angela Hayes North Carolina Department of Safety angela.hayes@ncdps.gov 919-901-5167 (cell) 378.55 (0.30) 4/7/2020 Angela Hayes North Carolina Department of Safety angela.hayes@ncdps.gov 919-901-5167 (cell) 2,959.52 (0.30) 4/4/2020 Yelena Crowley Tennessee Emergency Management Agency 1,000,000.00 (0.30) 4/3/2020 Danny Forehand Dixie County Sheriff's Office scottyosteen@dixiecountysheriff.com 352-498-1231 Ext 245 696.57 (0.30) 4/3/2020 Theresa Wigley Northern Arizona University Theresa.Wigley@nau.edu 928-523-8391 8,423.84 (0.30) 4/3/2020 Matthew Martin Douglas County Sheriff's Office michael.smith@douglascounty-ne.gov 402-444-3603 919.93 (0.30) 4/3/2020 Barbara Lawrence Marion County Sheriff's Office Michael.Turner@Indy.Gov 727-515-7711 2,885.40 (0.30) 4/3/2020 Susanna Hinckley Riverside University Health System 495,974.46 (17,359.41) 4/2/2020 Karen Smith Melbourne Police Department Karen.smith@mlbfl.org 321-795-7355 275.98 (0.30) 4/2/2020 Ron Hardy Takoma Park Police Department ronh@takomaparkmd.gov 202-360-7304 614.97 (0.30) 4/2/2020 Brent Culbertson North Carolina State Bureau of Investigation bculbertson@ncsbi.gov (828)782-0324 (Mobile) 2,840.84 (0.30) 4/2/2020 Lindsay Green Oklahoma State Bureau of Investigations Lindsay.Green@osbi.ok.gov (405) 879-2649 4,812.04 (0.30) 4/1/2020 Bruce Reeve Iowa DCI Crime Laboratory hermsen@dps.state.ia.us 515-559-7057 2,793.00 (0.30) 4/1/2020 Patricia Blute Arizona Department of Public Safety pblute@azdps.gov 520-746-4520 1,638.37 (0.30) 4/1/2020 Kristin Gavin Santa Rosa County Sheriff’s Office kgavin@srso.net 850 983-1113 5,006.40 (0.30) 3/31/2020 Wendy Franz Maryland Department of State Police wendy.franz@maryland.gov 410-379-9412 2,900.11 (0.30) 3/31/2020 Jennifer Miller Florida Department of Law Enforcement JenniferCanfield@fdle.state.fl.us (850) 410-7306 11,913.47 (0.30) 3/31/2020 Karen Smith Melbourne Police Department Karen.smith@mlbfl.org C 321-795-7355 1,561.75 (0.30) 3/30/2020 Stephen Srodawa Idaho State Police stephen.srodawa@isp.idaho.gov 208-884-7037 5,642.70 (0.30) 3/30/2020 Sharon Skarda Maryland Police Department wendy.franz@maryland.gov 410-379-9412 4,254.11 (0.30) 3/30/2020 Sean Riordan Melbourne Airport Police Department sriordan@mlbair.com 321 723 6227 3,007.87 (0.30) 1,622,436.47 $ (17,540.27) $ CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 17 of 20 PageID# 2145 Schedule 3 Page 2 of 4 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinge Anedot Fees charged to Blue Flame Medical, LLC Date Card Holder Agency 4/10/2020 Steve Sligh South Carolina Law Enforcement Divsion 4/9/2020 Angela Hayes North Carolina Department of Safety 4/7/2020 Julianne Lacsina Lone Star College 4/7/2020 Angela Hayes North Carolina Department of Safety 4/7/2020 Angela Hayes North Carolina Department of Safety 4/4/2020 Yelena Crowley Tennessee Emergency Management Agency 4/3/2020 Danny Forehand Dixie County Sheriff's Office 4/3/2020 Theresa Wigley Northern Arizona University 4/3/2020 Matthew Martin Douglas County Sheriff's Office 4/3/2020 Barbara Lawrence Marion County Sheriff's Office 4/3/2020 Susanna Hinckley Riverside University Health System 4/2/2020 Karen Smith Melbourne Police Department 4/2/2020 Ron Hardy Takoma Park Police Department 4/2/2020 Brent Culbertson North Carolina State Bureau of Investigation 4/2/2020 Lindsay Green Oklahoma State Bureau of Investigations 4/1/2020 Bruce Reeve Iowa DCI Crime Laboratory 4/1/2020 Patricia Blute Arizona Department of Public Safety 4/1/2020 Kristin Gavin Santa Rosa County Sheriff’s Office 3/31/2020 Wendy Franz Maryland Department of State Police 3/31/2020 Jennifer Miller Florida Department of Law Enforcement 3/31/2020 Karen Smith Melbourne Police Department 3/30/2020 Stephen Srodawa Idaho State Police 3/30/2020 Sharon Skarda Maryland Police Department 3/30/2020 Sean Riordan Melbourne Airport Police Department Net to Blue Flame Gross Credit Card Charge by Anedot Invoiced by Blue Flame Fee Paid by Agency Anedot Fee Percentage Fee Refunded by Blue Flame 55,006.54 $ 57,001.90 $ 55,006.84 $ 1,995.06 3.63% - $ 2,959.22 3,066.86 2,959.52 107.34 3.63% - 4,795.97 4,970.23 4,970.23 - 3.63% - 378.25 392.28 378.55 13.73 3.63% - 2,959.22 3,066.86 2,959.52 107.34 3.63% - 999,999.70 1,036,269.43 1,000,000.00 36,269.43 3.63% 36,269.43 696.27 721.52 696.57 25.25 3.63% 25.25 8,423.54 8,729.37 8,423.84 305.53 3.63% 305.53 919.63 952.98 919.93 33.35 3.63% 33.35 2,885.10 2,885.40 478,615.05 495,974.46 495,974.46 - 3.63% - 275.68 285.68 245.57 10.00 3.63% 10.00 614.67 637.27 614.97 22.30 3.63% 22.30 2,840.54 2,943.56 2,840.84 103.02 3.63% 103.02 4,811.74 4,986.57 4,812.04 174.53 3.63% 174.53 2,792.70 2,793.00 1,638.07 1,697.48 1,638.37 59.41 3.63% 59.41 5,006.10 5,006.40 2,899.81 2,759.78 - 11,913.17 12,345.25 11,913.47 432.08 3.63% 432.08 1,561.45 1,618.08 1,561.75 56.63 3.63% 15.71 5,642.40 5,847.36 5,642.70 204.66 3.63% 204.66 4,253.81 4,245.11 3,007.57 3,007.87 1,604,896.20 $ 1,622,256.73 $ 39,919.69 $ 37,655.29 $ CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 18 of 20 PageID# 2146 Schedule 3 Page 3 of 4 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinge Anedot Fees charged to Blue Flame Medical, LLC Date Card Holder Agency 4/10/2020 Steve Sligh South Carolina Law Enforcement Divsion 4/9/2020 Angela Hayes North Carolina Department of Safety 4/7/2020 Julianne Lacsina Lone Star College 4/7/2020 Angela Hayes North Carolina Department of Safety 4/7/2020 Angela Hayes North Carolina Department of Safety 4/4/2020 Yelena Crowley Tennessee Emergency Management Agency 4/3/2020 Danny Forehand Dixie County Sheriff's Office 4/3/2020 Theresa Wigley Northern Arizona University 4/3/2020 Matthew Martin Douglas County Sheriff's Office 4/3/2020 Barbara Lawrence Marion County Sheriff's Office 4/3/2020 Susanna Hinckley Riverside University Health System 4/2/2020 Karen Smith Melbourne Police Department 4/2/2020 Ron Hardy Takoma Park Police Department 4/2/2020 Brent Culbertson North Carolina State Bureau of Investigation 4/2/2020 Lindsay Green Oklahoma State Bureau of Investigations 4/1/2020 Bruce Reeve Iowa DCI Crime Laboratory 4/1/2020 Patricia Blute Arizona Department of Public Safety 4/1/2020 Kristin Gavin Santa Rosa County Sheriff’s Office 3/31/2020 Wendy Franz Maryland Department of State Police 3/31/2020 Jennifer Miller Florida Department of Law Enforcement 3/31/2020 Karen Smith Melbourne Police Department 3/30/2020 Stephen Srodawa Idaho State Police 3/30/2020 Sharon Skarda Maryland Police Department 3/30/2020 Sean Riordan Melbourne Airport Police Department Refund Date Other Refund Refund Date Total Refund Refund Method - - - - - 4/22/2020 1,000,000.00 4/22/2020 1,036,269.43 Anedot Credit 4/23/2020 696.27 4/22/2020 721.52 Anedot Credit 4/21/2020 305.53 Anedot Credit 4/28/2020 919.93 4/28/2020 953.28 Anedot Credit - 4/30/2020 495,974.46 4/30/2020 495,974.46 Anedot Credit 4/23/2020 275.98 4/23/2020 285.98 Anedot Credit 4/24/2020 614.97 4/24/2020 637.27 Anedot Credit 4/23/2020 2,840.84 4/23/2020 2,943.86 Anedot Credit 4/19/2020 174.53 Anedot Credit - 4/8/2020 1,296.72 4/28/2020 1,356.13 Anedot Credit - 4/19/2020 140.33 140.33 Anedot Credit 4/23/2020 11,913.47 4/23/2020 12,345.55 Anedot Credit 4/23/2020 433.22 4/23/2020 448.93 Anedot Credit 4/19/2020 5,642.40 4/23/2020 5,847.06 Anedot Credit - - 1,520,748.59 $ 1,558,403.88 $ CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 19 of 20 PageID# 2147 Schedule 3 Page 4 of 4 Blue Flame Medical, LLC v Chain Bridge Bank, N.A., John J. Brough and David M. Evinge Anedot Fees charged to Blue Flame Medical, LLC Date Card Holder Agency 4/10/2020 Steve Sligh South Carolina Law Enforcement Divsion 4/9/2020 Angela Hayes North Carolina Department of Safety 4/7/2020 Julianne Lacsina Lone Star College 4/7/2020 Angela Hayes North Carolina Department of Safety 4/7/2020 Angela Hayes North Carolina Department of Safety 4/4/2020 Yelena Crowley Tennessee Emergency Management Agency 4/3/2020 Danny Forehand Dixie County Sheriff's Office 4/3/2020 Theresa Wigley Northern Arizona University 4/3/2020 Matthew Martin Douglas County Sheriff's Office 4/3/2020 Barbara Lawrence Marion County Sheriff's Office 4/3/2020 Susanna Hinckley Riverside University Health System 4/2/2020 Karen Smith Melbourne Police Department 4/2/2020 Ron Hardy Takoma Park Police Department 4/2/2020 Brent Culbertson North Carolina State Bureau of Investigation 4/2/2020 Lindsay Green Oklahoma State Bureau of Investigations 4/1/2020 Bruce Reeve Iowa DCI Crime Laboratory 4/1/2020 Patricia Blute Arizona Department of Public Safety 4/1/2020 Kristin Gavin Santa Rosa County Sheriff’s Office 3/31/2020 Wendy Franz Maryland Department of State Police 3/31/2020 Jennifer Miller Florida Department of Law Enforcement 3/31/2020 Karen Smith Melbourne Police Department 3/30/2020 Stephen Srodawa Idaho State Police 3/30/2020 Sharon Skarda Maryland Police Department 3/30/2020 Sean Riordan Melbourne Airport Police Department Comment Credit card fee accepted by customer Credit card fee accepted by customer Included in total Invoice and paid by Blue Flame when charged Credit card fee accepted by customer Credit card fee accepted by customer Processing Fee Refund taken from Anedot's Blue Flame Account Refund of items not available. Refund of items not available. Processed into Anedot website Refund of items not available. Refund of items not available. Refund of items not available. Refund of items not available. Refund Sales tax Refund of items not available. Refund of items not available. Refund of items not available. CONFIDENTIAL Case 1:20-cv-00658-LMB-IDD Document 131-19 Filed 05/07/21 Page 20 of 20 PageID# 2148
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