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
File and source
- File
- gov.uscourts.vaed.477405.150.12.pdf
- Size
- 1,372,708 bytes
- SHA-256
- 237dc38ae91a5d63160bc4c08aac72aa370027fac6e357140a3364fc4a878979
- Original
- PACER (login required)