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Mike and I talked about preparing ICS agreements just in case it comes in and he and Maria are taking care of that in

Date
2021-05-07

Summary

Document 132-39, filed May 7, 2021 in Case 1:20-cv-00658-LMB-IDD, is Exhibit 39: an email chain among Chain Bridge Bank, N.A. staff dated March 25, 2020 under the subject line Blue Flame Medical incoming wire. A branch manager reports that Blue Flame Medical, which opened an account that day, expects a wire from the State of California for 450 million, and a commercial banking manager replies that a sum of that size is half the bank's asset size and could affect its capital ratios. Chief Executive Officer John J. Brough writes that he and David M. Evinger are skeptical and asks staff to prepare ICS documents so any funds can be moved off the balance sheet. The chain ends with a reply that ICS agreements are being prepared. The pages carry confidential document numbers and a plaintiff's trial exhibit stamp.

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Full text

Case 1:20-cv-00658-LMB-IDD   Document 132-39   Filed 05/07/21   Page 1 of 4 PageID#
                                     2856




       EXHIBIT 39
To:      Case  1:20-cv-00658-LMB-IDD
          John J.                               Document 132-39 Filed 05/07/21 Page 2 of 4 PageID#
                  Brough[JBrough@chainbridgebank.com]
Cc:       Mike Richardson[mrichardson@chainbridgebank.com];2857
                                                            Joanna Williamson[jwilliamson@chainbridgebank.com]; David M.
Evinger[DEvinger@chainbridgebank.com]
From:     Heather Schoeppe
Sent:     Wed 3/25/2020 9:03:13 PM
Subject:  Re: Blue Flame Medical incoming wire 450 million

John,
Mike and I talked about preparing ICS agreements just in case it comes in and he and Maria are taking care of that in
the morning.

Heather

Sent from my iPhone


       On Mar 25 , 2020, at 6:24 PM, John J. Brough <JBrough@chainbridgebank.com> wrote:



       Heather,

       David and I spoke to Mike Gula. He is very confident about the transactions, but David and I are very skeptical.
       We called Peter to bring him up to speed. Peter also thinks it is a scam.

       In the event we do receive the cash, there is no way we can hold it on our balance sheet. So, would you please
       prepare ICS documents? Zero interest rate. I told Mike we would need to move the money off balance sheet
       into the ICS program .

       John


       John J. Brough
       Chief Executive Officer
       Chain Bridge Bank, N.A.
       (703) 748-7384 Direct
       (703) 748-2005 Main
       (703) 216-5477 Cell
       (703) 748-2007 Fax

       1445-A Laughlin Avenue
       McLean, VA 22101

       www.cha in bridge bank.com

        From: Heather Schoeppe <HSchoeppe@chainbridgebank.com>
Sent: Wednesday, March 25, 2020 4:22 PM
To: Mike Richardson <mrichardson@chainbridgebank.com>; John J. Brough <JBrough@chainbridgebank.com>; Joanna
        Williamson <jwilliamson@chainbridgebank.com>
Subject: FW: Blue Flame Medical incoming wire 450 million
Importance: High

       John and Joanna,
       We opened and account today for Blue Flame Medical/Mike Gula and he is expecting a wire in today for 450
       Million from the State of California . Mike Gula said the Governor of California just announced that California is
       buying 100 Million N95 masks from China and will be deploying them. Mike' s company Blue Flame Medical
       received the contract . He said the money should be in today and will be spent out fairly rapidly as China
       produces the masks and they pay them . He said he understands that the timing is important to us and can give


                                                                       Plaintiff's
                                                                      Trial Exhibit
CONFIDENTIAL                                                               531                                     CBB00000761
        Case
       us more1:20-cv-00658-LMB-IDD         Document
              information tomorrow on the timing        132-39
                                                 of payments         Filed
                                                             out of the    05/07/21
                                                                        account.                 Page 3 of 4 PageID#
                                                              2858
       I will ca ll you right away, but wanted you to see this in case I can't reach you immediately.

       Thanks,
       Heather


       Heather Schoeppe
       Senior Vice President and Branch Manager
       Chain Bridge Bank, N.A.
       (703) 748-2005 Office
       (703) 748-7383 Direct
       (703) 748-2007 Fax

       1445-A Laughlin Avenue
       McLean, VA 22101

       www .chainbridgebank.com

        From: Mike Richardson <mrichardson@chainbridgebank.com >
Sent: Wednesday, March 25, 2020 4:00 PM
To: Heather Schoeppe <HSchoeppe@chainbridgebank.com>
Cc: Wires <Wires@chainbridgebank.com >; Commercial Banking <commercialbanking@chainbridgebank.com >
Subject: Re : Blue Flame Medical incoming wire

       Anything of that size would need to be known on the front end because that's half our asset size and could be
       problems on our capital ratios .

       Please reach out to confirm and let's talk with John and Joanna if it turns out to be something that massive.
       MR

       Mike Richardson
       Sr. Vice President &
       Commercial Banking Manager
       Chain Bridge Bank
       703-748-2074

       Sent from my Verizon Wireless mobile device



             On Mar 25, 2020, at 3:54 PM , Heather Schoeppe <HSchoeppe@chainbridgebank.com > wrote :



             He actually said 450 million. I was hoping Maria knew about it already b/c it is pretty crazy and
             would explain why he is going crazy today. If not, then maybe someone should reach out to
             discuss further to see what it's all about and the timeline of how long it will be here. I'm happy to
             do it if you want.


              Heather Schoeppe
             Senior Vice President and Branch Manager
             Chain Bridge Bank, N.A.
             (703) 748-2005 Office
             (703) 748-7383 Direct
             (703) 748-2007 Fax

              1445-A Laughlin Avenue




CONFIDENTIAL                                                                                                         CBB00000762
        CaseMcLean,
             1:20-cv-00658-LMB-IDD
                    VA 22101                   Document 132-39          Filed 05/07/21       Page 4 of 4 PageID#
                                                       2859
             www .chainbridgebank.com

               From: Mike Richardson <mrichardson@chainbridgebank.com >
Sent: Wednesday, March 25, 2020 3:53 PM
To: Heather Schoeppe <HSchoeppe@chainbridgebank.com >; Wires <Wires@chainbridgebank.com >
Cc: Commercial Banking <comm ercialbanking@chainbridgebank.co m>
Subject: RE: Blue Flame Medical incoming wire

             Heather - I hope you' re using " M " as roman numeral for thousands and not "M" for millions. ©
             MR


             Mike Richardson
             Senior Vice President &
             Commercial Banking Manager
             Chain Bridge Bank, N.A.
             Direct 703-7 48-207 4
             Cell    571-329-7456
             Main    703-7 48-2005

               From: Heather Schoeppe
Sent: Wednesday, March 25, 2020 3:31 PM
To: Wires <Wires@chainbridgebank.com >
Cc: Commercial Banking <commercialbanking@chainbridgebank.com >
Subject: Blue Flame Medical incoming wire

             Mike Gula with Blue Flame Medical is expecting a wire from the state of California for 450M . and
             he would like to be contacted at 202-255-9745 as soon as we receive the funds.

             Thank You,
             Heather


             Heather Schoeppe
             Senior Vice President and Branch Manager
             Chain Bridge Bank, N.A.
             (703) 748-2005 Office
             (703) 748-7383 Direct
             (703) 748-2007 Fax

             1445-A Laughlin Avenue
             McLean, VA 22101

             www.chainbridgebank.com




CONFIDENTIAL                                                                                                     CBB00000763


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