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Home Source documents Exhibit 96: Deposition Transcript Pages — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va.)

Exhibit 96: Deposition Transcript Pages — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va.)

What This Document Is

A short excerpt (pages 212-213 of the transcript) from the February 10, 2021 remote videotaped deposition of DGS Deputy Director Andrew Sturmfels, taken via Zoom from West Sacramento, California, and reported by Dawn Matera of Veritext Legal Solutions. Per the White affirmation (Docket Entry 150, paragraph 14), this is Exhibit 96. This Veritext-format transcript's text extraction shows pervasive ligature-substitution artifacts (e.g., "l-" for "l", "entitl-ed" for "entitled") rather than a true encoding cipher; the text remains legible and was read directly.

Factual Summary

Sturmfels is questioned about what he knew at the time he signed "the wire transfer memorandum." Asked whether additional information about the counterparty organization would have been helpful given "the size of the transaction, the complexity and risk," he agrees it would have aided the state's decision-making. Asked directly whether he knew, at the time he signed, that "Blue Flame Medical owned no inventory of N95 masks," Sturmfels answers that his understanding was that Blue Flame "was a broker that had direct lines to inventory" and that the inventory "was not in their control at the point in time," which he says "was the purpose of needing the funds up front." Asked whether he knew, at the time he signed, that Blue Flame "had never delivered N95 masks to any customer," Sturmfels answers, "I did not have that information at the time." The excerpt ends mid-question, turning to a discussion Sturmfels had with "Andre Rivera" about a call between Chain Bridge Bank and the State Treasurer's Office.

Key Facts

  • Sturmfels's admission that he did not know, at the time he signed the wire authorization, that Blue Flame had never previously delivered N95 masks to any customer is a direct data point on the state side's due-diligence gaps — corroborating and adding specificity to the broader vetting-process picture already developed through Daniel Kim's and Richard Chivaro's testimony (Exhibits 92-93/150.8-150.9, reviewed alongside this file).
  • Sturmfels's characterization of Blue Flame as "a broker that had direct lines to inventory" not "in their control" — offered as his understanding of why upfront payment was required — is his own after-the-fact explanation of the state's prepayment rationale, not independently verified within this excerpt.
  • This is the same Andrew Sturmfels whose urgent March 25, 2020 "Can you call me — 376-5044 stat please" message to Michael Wong closes the email chain already reviewed at Exhibit 90/150.6, and whose "email chain restored" internal messages are separately documented at 132.76-132.77 as California's own account of independently deciding to "null the wire transfer request."

Source Caveats

  • This is a 2-page excerpt of a much longer deposition; the full transcript, including the "Andre Rivera" call discussion referenced at the excerpt's end, is not part of this exhibit.
  • Objections by counsel (form, speculation) are reproduced as part of the record but do not affect the substance of Sturmfels's answers.
  • This page's web address (built from the court-reporter caption) does not describe this document's content. The address is kept unchanged.
Date
2021-05-20

Cite this document

“Exhibit 96: Deposition Transcript Pages — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va.).” Original at ecf.vaed.uscourts.gov, dated 2021-05-20. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-05-20-matera-a-shorthand-reporter-and-notary/, SHA-256 237dc38ae91a5d63160bc4c08aac72aa370027fac6e357140a3364fc4a878979.

Full text

Case 1:20-cv-00658-LMB-IDD   Document 150-12   Filed 05/20/21   Page 1 of 4 PageID#
                                     3750




         EXHIBIT 96
Case 1:20-cv-00658-LMB-IDD    Document 150-12         Filed 05/20/21     Page 2 of 4 PageID#
                                      3751



                                                                             Page 1

   1       IN THE UNITED STATES DISTRICT COURT
           FOR THE EASTERN DISTRICT OF VIRGINIA
   2
           i:l:::::::: ::::::::l                            ---x
   3       BLUE FLAME MEDICAL LLC/
                               Plaintiff,
   4

                              - a€tain s t-                        Civil    Action
   5                                                               No.
           CHAIN BRIDGE BANK, N. A. , JOHN J. L:20 -cv-00 658
    6      BROUGH, and DAVID M. EVINGER,
                                  Defendants .
   7                                        ----x
           CHAIN BRIDGE BANK, N. A. ,
   I               Third-Party    PLaintiff ,
    9                    - agains t-
  10       JPMORGAN CHASE BANK, N. A. ,

  11                   ::t::_:::::        ::fendan'L ---x
  L2                                       February 10, 202L
                                           10:07 a.m.
  13
  L4
  15                 Remote Videotaped Deposition of
  t6       ANDREW STURMFELS, held in the above-
  t7       entitl-ed action, located in West Sacramento
  18       California,   taken via Zoom before Dawn
  19       Matera, a Shorthand Reporter and Notary
  20       Publ-ic.
  2!
  22

                                     Veritext Legal Solutions
        2t2-267-6868                   www.veritext.com                         s16-608-2400
Case 1:20-cv-00658-LMB-IDD            Document 150-12      Filed 05/20/21    Page 3 of 4 PageID#
                                              3752



                                                                                 Page 212

    1      additionaL            information            that         would have
    2     been heJ-pful                to know at the time you
    3      signed        the wire         transfer          memorandum?
    4                           MS .    PORTER: Objection.                    Ca11s
    5              for    specuLation.
    6              A.           Again,      repeating           my previous
    7      response r any additional-                       inf ormation          on
    8      the organj-zation                that      we were doing
    9     business         with,         based on the size                  of the
  10       transaction,                the complexity                and risk,
  11      would have been hel-pful                        in our decision-
  L2      making process.
  13               A.       Okay. Just                a few more of these
  t4       style        of questions.
  15                            At the time you signed                      the wire
  t6       transfer        memorandum, did you know that
  t7       BIue Flame Medical                   owned no inventory                 of
  18       N95 masks?
  19                            MR.     WHITE :       Obj ection           to form.
  20               A.           My     understanding            is they were a
  2L      broker         that        had direct         lines         to
  22       inventory.                So I think         we did have some



                                          Veritext Legal Solutions
        212-267-6868                        www.veritext.com                           5 I 6-608-2400
Case 1:20-cv-00658-LMB-IDD        Document 150-12       Filed 05/20/21    Page 4 of 4 PageID#
                                          3753



                                                                            Page 213

    1      understanding            that
                                    the inventory was not
    2      in their       control at the point in time.
    3                      That was the purpose of needing
    4      the funds up front.
    5          A.          Okay.         At the time you                 s igned

    6      the wire             did you know that BLue
                          transfer,
    7      Fl-ame Medica]- had never del-i-vered N95
    I      masks to any cus tomer?
    9                      MR      WHITE:         Objection.
  10             Misstates          evidence.
  11                       MS .     PORTER: Objection.                     Assumes
  t2              facts    not      in evidence.
  13             A.        I did not have that                     information
  t4       at   the time .
  15            A.         You testif         ied ear1ier            about     a
  L6       discussion        that     you had with                Andre Rivera
  t7       about a call           between Chain Bridge                    Bank on
  18       the one hand and officials               at the State
  19       Treasurerrs          Office      on the other; do you
  20       recal-l- that?
  2L             A.        I do.
  22              A.       Do you know whether Mr. Rivera



                                      Veritext Le gal Solutions
        212-267-6868                    www.veritext.com                           sI6-608-2400


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