Memorandum in Support of Third-Party Plaintiff Chain Bridge
Summary
A memorandum filed May 20, 2021 as Document 147 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, in the Eastern District of Virginia, Alexandria Division. Third-Party Plaintiff Chain Bridge Bank, N.A. moves to file a redacted version of Exhibit 104 to the Declaration of Donald Burke, the Expert Report of Teresa A. Pesce served by JPMorgan Chase Bank, N.A. on February 12, 2021. The memorandum states that JPMC designated the report Confidential and portions of it Highly Confidential, and requires two portions to be redacted in any public filing with the unredacted report filed under seal. It is signed /s/ Donald Burke.
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- Date
- 2021-05-20
Cite this document
“Memorandum in Support of Third-Party Plaintiff Chain Bridge.”
Original at ecf.vaed.uscourts.gov, dated 2021-05-20. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-05-20-plaintiff-v-chain-bridge-bank-n-a-john-j-42b698a7-1/
, SHA-256 42b698a76211ac6cbde2dd14d491eaefdebb556baf377aa54ae27eb0b3789341.Full text
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 DAVID M. EVINGER, Defendants. Civil Action No. 1:20-cv-00658 CHAIN BRIDGE BANK, N.A, Third-Party Plaintiff, v. JPMORGAN CHASE BANK, N.A., Third-Party Defendant. MEMORANDUM IN SUPPORT OF THIRD-PARTY PLAINTIFF CHAIN BRIDGE BANK, N.A.’S MOTION TO FILE UNDER PROVISIONAL SEAL Pursuant to Local Civil Rule 5 and the Amended Stipulated Confidentiality Agreement and Protective Order (ECF No. 68) (“Protective Order”), Third-Party Plaintiff Chain Bridge Bank, N.A. (“Chain Bridge”) respectfully moves to file a redacted version of Exhibit 104 to the Declaration of Donald Burke in Support of Defendants’/Third-Party Plaintiff’s Memoranda in Opposition to Blue Flame Medical LLC and JPMorgan Chase Bank, N.A.’s Motions for Summary Judgment. The Protective Order requires that “any document or thing containing or embodying Confidential or Highly Confidential Discovery Material” filed with the Court to be “filed under seal in accordance with Local Civil Rule 5.” (Dkt. 68 ¶ 7). Exhibit 104 is the Expert Report of Case 1:20-cv-00658-LMB-IDD Document 147 Filed 05/20/21 Page 1 of 4 PageID# 3575 2 Teresa A. Pesce, served by Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) on February 12, 2021. JPMC has designated this document as “Confidential,” and portions of it as “Highly Confidential,” under the terms of the Protective Order. On May 20, 2021, Third-Party Plaintiff Chain Bridge will file its memorandum in opposition to Third-Party Defendant JPMorgan Chase Bank, N.A.’s (“JPMC”) motion for summary judgment, which includes Ms. Pesce’s expert report as an exhibit. The parties have conferred in advance of this filing, and JPMC has informed Chain Bridge that JPMC requires two portions of the report to be redacted in any public filing, and the unredacted report to be filed under seal. Chain Bridge accordingly seeks leave to file a redacted version of this exhibit, and a sealed, unredacted version of it, pursuant to the Protective Order. Chain Bridge takes no position on JPMC’s confidentiality designation concerning the redacted text. Pursuant to the Scheduling Order in this case, “[w]here a party moves to file material under seal because the opposing party has designated that material as confidential, the opposing party must file a response to the motion and a proposed order that meet the requirements of Local Civil Rule 5.” ECF No. 37 ¶ 10(a). Chain Bridge has provided public notice of its request to seal by filing the accompanying Notice of Motion to File Under Provisional Seal. For the foregoing reasons, Third-Party Plaintiff respectfully submits that the Motion to File Under Provisional Seal should be granted. Case 1:20-cv-00658-LMB-IDD Document 147 Filed 05/20/21 Page 2 of 4 PageID# 3576 3 Date: May 20, 2021 Respectfully submitted, /s/ Donald Burke Donald Burke (VA Bar No. 76550) ROBBINS, RUSSELL, ENGLERT, ORSECK & UNTEREINER LLP 2000 K Street, NW, 4th Floor Washington, D.C. 20006 Tel: (202) 775-4500 Fax: (202) 775-4510 dburke@robbinsrussell.com Counsel for Third-Party Plaintiff Chain Bridge Bank, N.A. Case 1:20-cv-00658-LMB-IDD Document 147 Filed 05/20/21 Page 3 of 4 PageID# 3577 CERTIFICATE OF SERVICE I hereby certify that on May 20, 2021, I will electronically file the foregoing with the Clerk of Court using the CM/ECF system, which will then send a notification of such filing to the following: Peter H. White, Esq. (VA Bar No. 32310) SCHULTE ROTH & ZABEL LLP 901 Fifteenth Street, NW, Suite 800 Washington, DC 20005 Phone: (202) 729-7476 Fax: (202) 730-4520 Email: peter.white@srz.com Counsel for Plaintiff Meredith K. Loretta, Esq. (VA Bar No. 92369) WILMER CUTLER PICKERING HALE & DORR LLP 1875 Pennsylvania Avenue NW Washington, DC 20006 Phone: (212) 663-6981 Email: meredith.loretta@wilmerhale.com Counsel for Third-Party Defendant /s/ Donald Burke Donald Burke (VA Bar No. 76550) ROBBINS, RUSSELL, ENGLERT, ORSECK & UNTEREINER LLP 2000 K Street, NW, 4th Floor Washington, D.C. 20006 Tel: (202) 775-4500 Fax: (202) 775-4510 dburke@robbinsrussell.com Counsel for Defendants and Third-Party Plaintiff Case 1:20-cv-00658-LMB-IDD Document 147 Filed 05/20/21 Page 4 of 4 PageID# 3578
File and source
- File
- gov.uscourts.vaed.477405.147.0.pdf
- Size
- 147,480 bytes
- SHA-256
- 42b698a76211ac6cbde2dd14d491eaefdebb556baf377aa54ae27eb0b3789341
- Original
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