Exhibit 01 — Blue Flame Medical LLC v. Chain Bridge Bank, N.A., et al.

What This Document Is

Further excerpts (transcript pages ~68-125) of the February 11, 2021 deposition of Timothy Coffey, filed here by JPMorgan as Exhibit 1 to its own opposition memorandum — a different transcript range than the Coffey excerpts already reviewed in this docket at Exhibit 63 (132.63). A cover-page banner shows a font-substitution encoding artifact (cosmetic only); the substantive testimony pages extracted cleanly. No render was needed.

Factual Summary

Coffey testifies that when he called Evinger, he was "merely carrying out the request of Rakesh to get the funds held" and had no independent information to heighten his own concerns beyond relaying JPMorgan's suspicions. Asked whether Evinger told him the funds had been credited to Blue Flame, Coffey testifies: "I believe he had said to us, we are holding the funds, which would be terminology that would mean it never hit the beneficiary's account. They're holding it." The excerpt also covers Coffey's account of Korpal directing him, based on Korpal's own conversations with Evinger and others internally (to which Coffey was not privy), to engage Chain Bridge to recall the funds.

Key Facts

Coffey's account that Evinger represented the funds as merely "held," not credited, is a further data point on this docket's credited/not-credited dispute — consistent with Williamson's own "never actually credited" reading of the GL entries (Exhibit 101/142-2), though attributed here to what Evinger reportedly told JPMorgan rather than Chain Bridge's own internal record (which shows "received and credited" language, Exhibit 55).
Coffey again confirms he acted on Korpal's instruction to recall the funds without independent knowledge of what drove Korpal's own decision internally.

Source Caveats

Marked Highly Confidential; excerpted testimony only, spanning noncontiguous transcript pages.
Coffey's "never hit the beneficiary's account" characterization is his own understanding of Evinger's reported words, not a document he personally authored; it is reproduced as attributed testimony.

Date: 2021-05-20

Full text

EXHIBIT 1
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Case 1:20-cv-00658-LMB-IDD     Document 145-2     Filed 05/20/21     Page 2 of 13 PageID#
3519

Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 1
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
 1
         IN THE UNITED STATES DISTRICT COURT
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         FOR THE EASTERN DISTRICT OF VIRGINIA
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                (Alexandria Division)
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 - - - - - - - - - - - - - - -  X
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 BLUE FLAME MEDICAL LLC,        :
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     Plaintiff,                 :
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           v.                   :  Civil Action No.
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 CHAIN BRIDGE BANK, N.A.,       :  1:20-cv-00658
 9
 JOHN J. BROUGH and DAVID M.    :
10
 EVINGER,                       :
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     Defendants.                :    HIGHLY
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 _____________________________  :  CONFIDENTIAL
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 CHAIN BRIDGE BANK, N.A.,       :
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     Third-Party Plaintiff,     :
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           v.                   :
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 JPMORGAN CHASE BANK, N.A.,     :
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     Third-Party Defendant.     :
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 - - - - - - - - - - - - - - -  X
19
                        Remote Deposition
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                        Thursday, February 11, 2021
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           Deposition via Zoom of TIMOTHY P. COFFEY,
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a witness herein, called for examination by counsel
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3520

Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 2
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
 1
for Defendant/Third-Party Plaintiff in the
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above-entitled matter, pursuant to notice, the
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witness being duly sworn by MARY GRACE CASTLEBERRY, a
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Notary Public in and for the District of Columbia,
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taken at 9:31 a.m. EST, Thursday, February 11, 2021,
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and the proceedings being taken down by Stenotype by
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MARY GRACE CASTLEBERRY, RPR, and transcribed under
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her direction.
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10
11
12
13
14
15
16
17
18
19
20
21
22
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 3
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
 1
APPEARANCES:
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 3
     On behalf of the Plaintiff Blue Flame Medical
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     LLC:
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           BILL GUSSMAN, ESQ.
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           GREG KETCHAM-COLWILL, ESQ.
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           JASON MITCHELL, ESQ.
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           KENI UKABIALA, ESQ.
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           Schulte Roth & Zabel
10
           901 15th Street, N.W., Suite 800
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           Washington, D.C.  20005
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           (202) 729-7476
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           bill.gussman@srz.com
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           gregory.ketcham-colwill@srz.com
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           jason.mitchell@srz.com
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           ekenedilichukwu@ukabiala@srz.com
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               and
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           ETHAN BEARMAN, ESQ.
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           The Bearman Firm
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           10250 Constellation Boulevard, Suite 100
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           Los Angeles, California  90067
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           (747) 344-1004
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 4
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800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
 1
APPEARANCES (Continued):
 2
 3
     On behalf of the Defendant/Third-Party Plaintiff
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     Chain Bridge Bank, N.A.:
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           DONALD BURKE, ESQ.
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           GARY A. ORSECK, ESQ.
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           ZACHARY N. FERGUSON, ESQ.
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           Robbins Russell Englert, Orseck,
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            Untereiner & Sauber
10
           2000 K Street, N.W., 4th Floor
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           Washington, D.C.  20006
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           (202) 775-4500
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           dburke@robbinsrussell.com
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           gorseck@robbinsrussell.com
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           znferguson@robbinsrussell.com
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17
18
19
20
21
22
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 5
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
 1
APPEARANCES (Continued):
 2
 3
     On behalf of the Third-Party Defendant JPMorgan
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     Chase Bank:
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           ALAN SCHOENFELD, ESQ.
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           ALBINAS PRIZGINTAS, ESQ.
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           TODD CLAYTON, ESQ.
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           Wilmer Cutler Pickering Hale & Dorr LLP
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           1875 Pennsylvania Avenue, N.W.
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           Washington, D.C.  20006
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           (212) 663-6981
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           alan.schoenfeld@silmerhale.com
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           albinas.prizgintas@wilmerhale.com
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           todd.clayton@wilmerhale.com
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     ALSO PRESENT:
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           JASON AQUI, Videographer
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19
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21
22
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 68
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
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the intent of my phone call, and I needed to report
 2
that to Rakesh to let him know that I've -- that
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they're holding the funds, too.
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     Q.    I see.  And did -- did the fact that Chain
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Bridge Bank had expressed concerns regarding the
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transaction heighten any concerns you had with
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respect to the transaction?
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     A.    At that time, I didn't have the
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information to have any heightened concerns.  I was
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merely carrying out the request of Rakesh to get the
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funds held.
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     Q.    I see.  And did you then discuss that
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conversation with Mr. Evinger with anybody else at
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JPMorgan?
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     A.    I discussed it with Rakesh.
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     Q.    Do you recall how that discussion took
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place?
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     A.    I believe it was via a communicated
19
message or Skype message advising him that I spoke to
20
such and such, David Evinger, and he confirms they
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are withholding the funds, with similar suspicions.
22
     Q.    And do you recall whether Mr. Evinger told
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
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you whether the funds had been credited to the
 2
beneficiary in the transaction?
 3
     A.    I believe he had said to us, we are
 4
holding the funds, which would be terminology that
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would mean it never hit the beneficiary's account.
 6
They're holding it.
 7
     Q.    I see.
 8
           MR. BURKE:  Zach, could you share what was
 9
Plaintiff's Exhibit 98?
10
BY MR. BURKE:
11
     Q.    For the record, it is a document with the
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Bates label JPMC-00000243.
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     A.    Is that PX-98, guys?
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     Q.    Yes.
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     A.    Okay.  I just opened it in front of me.
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     Q.    Do you have that available to you,
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Mr. Coffey?
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     A.    I do.
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           MR. SCHOENFELD:  Sorry.  We do not.  Give
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us just one second.  Okay.  We got it.  Go ahead.
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Sorry.
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           MR. BURKE:  Great.
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 125
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800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
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to me to engage Chain Bridge Bank to recall the funds
 2
based upon whatever interaction he had had with
 3
people internally and with David Evinger, and I was
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not privy to those conversations.
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BY MR. BURKE:
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     Q.    So I want to -- I want to make sure I
 7
understand, to the best of your recollection, exactly
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what it is Mr. Korpal told you versus what you may
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have understood from the context or otherwise.
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           So at some point Mr. Korpal contacted you
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and directed you to recall the funds from Chain
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Bridge Bank; is that right?
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     A.    Yes.
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     Q.    And at that point, did he explain to you
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why JPMorgan would be recalling the funds from Chain
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Bridge Bank?
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     A.    No.
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     Q.    So the only information you had was a
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direction to go ahead and recall the funds; is that
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right?
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     A.    Yes.
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     Q.    And then outside of what Mr. Korpal told
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 126
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
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you in that conversation, did you have an
 2
understanding of why JPMorgan was issuing the recall
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to Chain Bridge Bank?
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     A.    I would assume whatever factfinding he did
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individually and in conjunction with David Evinger
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drove that decision.
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     Q.    But that's your -- that's your assumption
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based on -- strike that.
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           Is that assumption based on standard
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procedure in these sorts of investigations or is it
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based on some other source?
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     A.    I was not privy to any of the
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conversations that drove the decision for the funds
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to be returned.  I was just directed to engage Chain
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Bridge Bank and agree we need to return the funds,
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both sides being concerned.
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     Q.    At that point when Mr. Korpal directed you
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to recall the funds from Chain Bridge Bank, did you
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understand whether JPMorgan had been in contact with
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California officials about the transaction?
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     A.    I did not know as I was not part of that
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conversation.
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 141
www.trustpoint.one
800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
 1
creating an historical audit trail.
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     Q.    And so in connection with the Blue Flame
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wire transfer, you did approve the service message
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that was then sent to Chain Bridge; is that correct?
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     A.    I did.
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     Q.    And do you remember the content of that
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service message?
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     A.    These are standard templates that are
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built within the application and you really go in and
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pick the generic template for the recall and it
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populates the dates, dollar amounts and parties into
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it.
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           So it's an automated way of utilizing
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templates to get a recall of funds.  So she picked
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the recall of funds, it populates the message and
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spits out that Fed service message.
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     Q.    I see.  So do you -- in the system, do you
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select the original wire transfer and then it
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populates that information into a recall request?  Is
20
that how it works?
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     A.    So we save the original transaction to the
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case.  That way, if anybody else looked up that wire
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Timothy P.  Coffey
HIGHLY CONFIDENTIAL
2/11/2021
Page 142
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800.FOR.DEPO
www.aldersonreporting.com
(800.367.3376)
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at a future time, it would know that it already has a
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case opened up on it.
 3
     Q.    And then when you get to the step of
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initiating the recall service message, does the
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information about the transaction automatically
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populates from the information on the prior transfer?
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Is that how it works?
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     A.    Correct, the automation.
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     Q.    And then is there a component of the
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service message that is typed into the system, like a
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message to the other bank?
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     A.    Yeah, there can be.  If you don't choose a
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template, you can use a freeform message.  But in
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general, we try to cover things by utilizing the
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basic templates that we have in the system.
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     Q.    Do you know whether in this case the
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service message that was generated and then sent to
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Chain Bridge came from a template?
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     A.    I would -- I didn't create it.  It didn't
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look like a freeform message.  It looked like it was
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one of the templates that we used.
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     Q.    At this point in time, when you were
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