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Declaration of Meredith K. Loretta — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Document 145-1)

Date
2021-05-20

Summary

A declaration of Meredith K. Loretta, counsel for third-party defendant JPMorgan Chase Bank, N.A., filed May 20, 2021 as Document 145-1 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., John J. Brough, and David M. Evinger, Civil Action No. 1:20-cv-00658 (LMB/IDD), in the U.S. District Court for the Eastern District of Virginia. It supports JPMorgan Chase's memorandum in opposition to Chain Bridge Bank's motion for summary judgment. The declaration identifies six attached exhibits: deposition transcript excerpts (Exhibits 1, 2 and 5, including the deposition of John J. Brough), a CalMatters news article dated May 11, 2020 (Exhibit 3), excerpts from an expert report dated March 12, 2021 (Exhibit 4), and an email produced by Chain Bridge bearing Bates number CBB00001385 (Exhibit 6).

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Cite this document

“Declaration of Meredith K. Loretta — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Document 145-1).” Original at ecf.vaed.uscourts.gov, dated 2021-05-20. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-05-20-p-l-a-i-n-t-i-f-f-v-chain-bridge-bank-n-a-6810f257-1/, SHA-256 6810f257dd0906e4d0aff2c1ab31c725dd0b5e6881e8b3cefe7148e7306144af.

Full text

Case 1:20-cv-00658-LMB-IDD            Document 145-1        Filed 05/20/21   Page 1 of 2 PageID#
                                             3516



                        IN THE UNITED STATES DISTRICT COURT
                       FOR THE EASTERN DISTRICT OF VIRGINIA
                                  (Alexandria Division)


  BLUE FLAME MEDICAL LLC,

                                  Plaintiff,

  v.

  CHAIN BRIDGE BANK, N.A.,
  JOHN J. BROUGH, and                                 Civil Action No. 1:20-cv-00658 (LMB/IDD)
  DAVID M. EVINGER,

                                  Defendants.


  CHAIN BRIDGE BANK, N.A.,

                         Third-Party Plaintiff,

  v.

  JPMORGAN CHASE BANK, N.A.,

                         Third-Party Defendant.


          DECLARATION OF MEREDITH K. LORETTA IN SUPPORT OF
       JPMORGAN CHASE BANK, N.A.’S MEMORANDUM IN OPPOSITION TO
        CHAIN BRIDGE BANK, N.A.’S MOTION FOR SUMMARY JUDGMENT

        Meredith K. Loretta, an attorney duly admitted to practice law in the Commonwealth of

 Virginia, declares as follows:

        1.      I am an attorney at Wilmer Cutler Pickering Hale and Dorr LLP, and counsel for

 Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) in the above-captioned case. I

 make this declaration based upon my personal knowledge and documents provided to me, in

 support of JPMC’s Memorandum in Opposition to Chain Bridge’s Motion for Summary

 Judgment.



                                                  1
Case 1:20-cv-00658-LMB-IDD          Document 145-1         Filed 05/20/21       Page 2 of 2 PageID#
                                           3517



        2.      Attached hereto as Exhibit 1 is a true and accurate copy of excerpts from the

 transcript of the deposition of Timothy Coffey, taken on February 11, 2021.

        3.      Attached hereto as Exhibit 2 is a true and accurate copy of excerpts from the

 transcript of the deposition of Rakesh Korpal, taken on February 9, 2021.

        4.      Attached hereto as Exhibit 3 is a true and accurate copy of a news article titled

 “CA lawmakers told half-billion dollar Blue Flame mask deal thwarted by suspicious bankers”

 dated May 11, 2020 (updated September 17, 2020), published by CalMatters online.

        5.      Attached hereto as Exhibit 4 is a true and accurate copy of excerpts from the

 Expert Report of Thomas C. Baxter, Jr. dated March 12, 2021.

        6.      Attached hereto as Exhibit 5 is a true and accurate copy of excerpts from the

 transcript of the deposition of John J. Brough, taken on February 2, 2021.

        7.      Attached hereto as Exhibit 6 is a true and accurate copy of an email titled “Blue

 Flame Medical LLC - Wire Transfer” from Ethan Bearman to mcole@chainbridgebank.com

 dated March 26, 2020 at 12:14:28 p.m., produced by Chain Bridge, bearing Bates number

 CBB00001385.

        I declare under penalty of perjury that the foregoing is true and correct.



 Executed on: May 20, 2021                            /s/ Meredith K. Loretta
              Washington, DC                          Meredith K. Loretta




                                                  2

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