Blue Flame Medical Llc’S Motion For Partial Summary Judgment
- Date
- 2021-05-27
Summary
The Affirmation of Peter H. White in Further Support of Plaintiff Blue Flame Medical LLC's Motion for Partial Summary Judgment, filed May 27, 2021 as Document 160 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., Civil Action No. 1:20-cv-00658, in the U.S. District Court for the Eastern District of Virginia. White, of Schulte Roth & Zabel LLP, counsel for the plaintiff, submits it in support of the motion at ECF No. 127. The affirmation annexes fourteen exhibits, including emails, portions of deposition transcripts, a Certification of Beneficial Owners of Legal Entities for Chain Bridge Bank, N.A., and the bank's Funds Availability Disclosure. It states that two exhibits were redacted under Fed. R. Civ. P. 5.2. The four-page filing ends with a certificate of service.
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Case 1:20-cv-00658-LMB-IDD Document 160 Filed 05/27/21 Page 1 of 4 PageID#
4193
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
)
BLUE FLAME MEDICAL LLC )
)
Plaintiff, )
)
v. ) Civil Action No. 1:20-cv-00658
)
CHAIN BRIDGE BANK, N.A., ) The Honorable Leonie Brinkema
JOHN J. BROUGH, and )
DAVID M. EVINGER )
)
Defendants. )
)
)
CHAIN BRIDGE BANK, N.A. )
)
Third-Party Plaintiff, )
)
v. )
)
JPMORGAN CHASE BANK, N.A. )
)
Third-Party Defendant. )
)
AFFIRMATION OF PETER H. WHITE IN FURTHER SUPPORT OF PLAINTIFF
BLUE FLAME MEDICAL LLC’S MOTION FOR PARTIAL SUMMARY JUDGMENT
Peter H. White, an attorney duly admitted to practice law before the Eastern District of
Virginia, affirms the following to be true under penalty of perjury:
1. I am a member of the law firm of Schulte Roth & Zabel LLP, attorneys for Plaintiff
Blue Flame Medical (“Plaintiff”). As such, I am fully familiar with the facts and circumstances
surrounding this action.
2. I respectfully submit this affirmation in support of Plaintiff Blue Flame Medical
LLC’s Motion for Partial Summary Judgment (ECF No. 127).
Case 1:20-cv-00658-LMB-IDD Document 160 Filed 05/27/21 Page 2 of 4 PageID#
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3. Annexed hereto as Exhibit 119 is a true and correct copy of an October 26, 2020
email re Notes (DGS6516-18).
4. Annexed hereto as Exhibit 120 is a true and correct copy of excerpts of the
transcript of the March 29, 2021 deposition of Daniel Kim.
5. Annexed hereto as Exhibit 121 is a true and correct copy of a May 4, 2020 email
from Brian Stephenson to Rakesh Korpal et al. RE: Blue Flame Medical (JPMC-00000274).
6. Annexed hereto as Exhibit 122 is a true and correct copy of excerpts of the
transcript of the February 9, 2021 deposition of Rakesh Korpal, corporate representative of Third-
Party Defendant JPMorgan Chase Bank, N.A.
7. Annexed hereto as Exhibit 123 is a true and correct copy of a March 27, 2020 email
from Heather Schoeppe to David Evinger re Blueflame Strategies Wire Form for John Thomas
(CBB00000557-58). This exhibit has been redacted pursuant to Fed. R. Civ. P. 5.2.
8. Annexed hereto as Exhibit 124 is a true and correct copy of a Certification of
Beneficial Owners of Legal Entities for Chain Bridge Bank, N.A. (CBB00000566-69). This
exhibit has been redacted pursuant to Fed. R. Civ. P. 5.2.
9. Annexed hereto as Exhibit 125 is a true and correct copy of excerpts of the
transcript of the April 9, 2021 deposition of Charles H. Grice.
10. Annexed hereto as Exhibit 126 is a true and correct copy of a March 27, 2020 email
from David Evinger to Mariano Castagnello et al. RE: Blue Flame Medical LLC documentation
(CBB00000785).
11. Annexed hereto as Exhibit 127 is a true and correct copy of excerpts of the
transcript of the April 6, 2021 deposition of Sean O’Malley.
2
Case 1:20-cv-00658-LMB-IDD Document 160 Filed 05/27/21 Page 3 of 4 PageID#
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12. Annexed hereto as Exhibit 128 is a true and correct copy of excerpts of the
transcript of the February 2, 2021 deposition of John Brough.
13. Annexed hereto as Exhibit 129 is a true and correct copy of excerpts of the
transcript of the April 11, 2021 deposition of Joanna Williamson.
14. Annexed hereto as Exhibit 130 is a true and correct copy of an April 15, 2021 email
from Donald Burke to Jason Mitchell et al. RE: Blue Flame v. Chain Bridge: Defendants’
Responses and Objections to Plaintiff’s Second Set of RFPs.
15. Annexed hereto as Exhibit 131 is a true and correct copy of the Chain Bridge Bank
N.A. Funds Availability Disclosure (CBB00004310-11).
16. Annexed hereto as Exhibit 132 is a true and correct copy of excerpts of the
transcript of the January 19, 2021 deposition of Michael Wong.
Dated : Washington, D.C. Respectfully submitted,
May 27, 2021
/s/ Peter H. White
Peter H. White (VA Bar No. 32310)
SCHULTE ROTH & ZABEL LLP
901 Fifteenth Street, NW, Suite 800
Washington, DC 20005
Tel.: (202) 729-7476
Fax: (202) 730-4520
pete.white@srz.com
Counsel for Plaintiff Blue Flame Medical LLC
3
Case 1:20-cv-00658-LMB-IDD Document 160 Filed 05/27/21 Page 4 of 4 PageID#
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CERTIFICATE OF SERVICE
I hereby certify that on this 27th day of May, 2021, I caused the foregoing document
to be filed and served electronically using the Court’s CM/ECF system, which automatically sent
a notice of electronic filing to all counsel of record.
Dated: May 27, 2021 /s/ Peter H. White
Peter H. White, Esq. (VSB# 32310)
SCHULTE ROTH & ZABEL LLP
901 Fifteenth Street, NW, Suite 800
Washington, DC 20005
Tel: 202-729-7476
Fax: 202-730-4520
peter.white@srz.com
Counsel for Blue Flame Medical LLC
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