Blue Flame v. Chain Bridge — Deposition of Michael Wong (Exhibit 120)
- Date
- 2021-05-27
Summary
Document 157-8, filed May 27, 2021 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 U.S. District Court for the Eastern District of Virginia, is Exhibit 120: selected pages of the confidential remote videotaped deposition of Michael Wong taken January 19, 2021. The 9-page exhibit includes the caption, appearances of counsel for Blue Flame Medical, Chain Bridge Bank, JPMorgan Chase Bank and the deponent, and the index of examinations and exhibits. The transcript pages record questioning by Mr. Madden about text messages and emails with a Blue Flame Medical representative in March 2020, including prepayment, holding of funds and the company's manufacturers. The final page covers questions on the state controller's office and Blue Flame Medical's place of business.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 1 of 9 PageID#
4074
EXHIBIT 120
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 2 of 9 PageID#
Page 1 (1)
4075
IN THE UNITED STATES DISTRICT COURT
2 FOR THE EASTERN DISTRICT OF VIRGINIA
3 (Alexandria Division)
4 X
5 BLUE FLAME MEDICAL LLC,
6 Plaintiff,
7 V. Civil Action No.
8 CHAIN BRIDGE BANK, N.A., JOHN 1:20-cv-00658
9 J. BROUGH and DAVID M.
10 EVINGER, CONFIDENTIAL
11 Defendants.
12
13 CHAIN BRIDGE BANK, N.A.,
14 Third-Party Plaintiff,
15 V.
16 JPMORGAN CHASE BANK, N.A.,
17 Third-Party Defendant.
18 X
19 Remote Deposition
20 Tuesday, January 19, 2021
21 Videotaped Deposition via Zoom of MICHAEL
22 WONG, a witness herein, called for examination by
�7 Trustpoint. One Alderson.
Michael W ong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 3 of 9 PageID#
Page 2 (2 - 5)
4076
Page 2 Page 4
1 counsel for Defendant/Third-Party Plaintiff in the 1
APPEARANCES (Continued):
2 above-entitled matter, pursuant to notice, the 2
3 witness being duly sworn by MARY GRACE CASTLEBERRY, a 3 On behalf of the Plaintiff Blue Flame Medical
4 Notary Public in and for the District of Columbia, 4
LLC:
5 taken at 1:01 p m. EST, Tuesday, January 19, 2021, 5
ETHAN BEARMAN, ESQ.
6 and the proceedings being taken down by Stenotype by 6
The Bearman Firm
7 MARY GRACE CASTLEBERRY, RPR, and transcribed under 7
I 0250 Constellation Boulevard, Suite I 00
8 her direction. 8
Los Angeles, California 90067
9 9
(747) 344-1004
10 10
11 11
On behalf of the Defendant/Third-Party Plaintiff
12 12
Chain Bridge Bank, N.A.:
13 13
MATTHEW M. MADDEN, ESQ.
14 14
ZACHARY N. FERGUSON, ESQ.
15 15
Robbins Russell Englert Orseck
16 16
Untereiner & Sauber
17 17
2000 K Street, N.W., 4th Floor
18 18
Washington, D.C. 20006
19 19
(202) 775-4500
20 20
mmadden@robbinsrussell.com
21 21
znferguson@robbinsrussell.com
22 22
Page 3 Page 5
1
APPEARANCES: 1 APPEARANCES (Continued):
2 2
3 On behalf of the Plaintiff Blue Flame Medical 3 On behalf of the Third-Party Defendant JPMorgan
4
LLC: 4 Chase Bank:
5
PETER H. WHITE, ESQ. 5 ALAN SCHOENFELD, ESQ.
6
GREG KETCHAM-COLWILL, ESQ. 6 ALBINAS PRIZGINTAS, ESQ.
7
BILL GUSSMAN, ESQ. 7 MARGARITA BOTERO, ESQ.
8
JASON MITCHELL, ESQ. 8 Wilmer Cutler Pickering Hale & Dorr LLP
9
KENI UKABIALA, ESQ. 9 1875 Pennsylvania Avenue, N.W.
10
Schulte Roth & Zabel 10 Washington, D.C. 20006
11
901 15th Street, N.W., Suite 800 11
(212) 663-6981
12
Washington, D.C. 20005 12 alan.schoenfeld@silmerhale.com
13
(202) 729-7476 13 albinas .prizgintas@wilmerhale.com
14
pete.white@srz.com 14 margarita.botero@wilmerhale.com
15
gregory.ketcham-colwill@srz.com 15
16
bill.gussman@srz.com 16
17
j ason.mitchell@srz.com 17
18
ekenedilichukwu@ukabiala@srz.com 18
19 19
20 20
21 21
22 22
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800.367.3376)
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 4 of 9 PageID#
Page 3 (6 - 9)
4077
Page 6 Page 8
1
APPEARANCES (Continued): 1 E X H I B I TS
2 2 DEFENDANT'S EXHIBIT NO. PAGE
3
On behalf of the Deponent: 3 66 - March 25, 2020 email from John Thomas
4
CARA PORTER, ESQ. 4
to Michael Wong 113
5
SARAH FABIAN, ESQ. 5 67 -April 3, 2020 email from Mathew Littman
6
Office of the Attorney General 6
to Michael Wong 126
7
California Department of Justice 7 68 -April 15, 2020 email from John Thomas
8
455 Golden Gate Avenue, Suite 11000 8
to Michael Wong 139
9
San Francisco, California 94102-7020 9
10
(415) 254-3934 10 PLAINTIFF'S EXHIBIT NO. PAGE
11
cara.porter@doj.ca.gov 11 1 -March 24, 2020 email from John Thomas
12
Sarah.fabian@doj.ca.gov 12 to Michael Wong 163
13 1 3 2 -March 25, 2020 email from Andrew Sturmfels
14
ALSO PRESENT: 14 to Michael Wong 185
15
JASON AQUI, Videographer 15 3 -March 25, 2020 email from Angela Shell
16 16
to Andrew Sturmfels 188
17 17 4 -March 25, 2020 email from Michael Wong
18 18 to John Catching 208
19 19 5 -March 25, 2020 email from Andrew Sturmfels
20 20 to Kim Daniel 217
21 21 6 -March 26, 2020 email from Natalie Gonzales
22 22 to Andrew Sturmfels 221
Page 7 Page 9
1 C O N T E N TS 1 E X H I B I TS (Continued):
2
WITNESS EXAMINATION 2
PLAINTIFF'S EXHIBIT NO. PAGE
3 MICHAEL WONG 3
7 -March 26, 2020 email from Kim Daniel
4 BY MR MADDEN 12 4
to Andrew Sturmfels 224
5 BY MR MITCHELL 153 5
8 -March 25, 2020 email from Fee Chang
6 BY MR PORTER 254 6
to Andrew Sturmfels 227
7 BY MR MITCHELL 263 7
9 -Text message between Mr. Wong, Mr. Thomas
8 BY MS. PORTER 269 8
and Daniel Kim 233
9 9
10 -March 26, 2020 email from Andrew Sturmfels
10 Afternoon Session -Page 116 1
° CC Michael Wong 237
11 11
12 E X H I B I TS 12
1 3 DEFENDANT'S EXHIBIT NO. PAGE 1 3
14 61 -Screenshots of text messages 22 14
15 62 -March 22, 2020 -April 9, 2020 text 15
16
messages 22 16
17 63 -March 24, 2020 email from John Thomas 17
18 to Michael Wong 51 18
19 64 -March 24, 2020 email from Ethan Bearman 19
20 to Michael Wong and John Thomas 92 20
21 65 -March 25, 2020 email from John Thomas 21
22 to Michael Wong 111 22
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800.367.3376)
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 5 of Page 15 (54 - 57)
9 PageID#
4078
Page 54 Page 56
1 manufacturer had ever delivered any masks to Blue 1 A. Yes.
2 Flame Medical before? 2 Q. All right. Could we return to -- I
3 A. Not that I remember. 3 apologize for the flipping around -- but if we could
4 Q. Did Mr. Thomas tell you whether this 4 return to Exhibit 62, please. So the text messages.
5 products catalog attached to the -- excuse me. 5 A. Okay. I have Exhibit 62 up.
6
Strike that. 6
Q. Okay. And we're now back to page that
7
Did Mr. Thomas tell you whether the 7
ends in 138. It's the fourth page of the PDF.
8
inventory list attached to this email came from the 8 A. Okay.
9 manufacturer from which Blue Flame Medical intended 9 Q. Okay. And if you look at the fourth entry
10 to source the bulk of any masks California ordered? 10 down, it's from March 24th at 3:01 p.m. Do you see
11 A. He did not -- to the best of my memory, he 11 that one?
12 did not identify a link between specific 12 A. Yes, sir.
13 manufacturers and the bulk of the order. 13 Q. And you asked Mr. Thomas, "Quick question.
14 Q. Okay. If you flip to the inventory list 14 Is prepayment made to your company or overseas?"
15 itself which ends in Bates number 134. just tell me 15 Do you see that?
16
when you're there. 16 MR. MITCHELL: Objection. Misstates the
17 A. Yes. I see it. 17
document.
18 Q. And at the very top of the page, it says, 18 BY MR. MADDEN:
19 "XXXX," five Xs, "Products Catalog." 19 Q. Okay. I'll try again. At 3:01 p.m. on
20 Do you see that? 20 March 24th, you write to Mr. Thomas, "Quick question.
21 A. Yes, sir. 21 Is payment made to your company or overseas?"
22 Q. Did Mr. Thomas ever explain to you why 22 Do you see that?
Page 55 Page 57
1
this products catalog had a series of Xs instead of a 1
A. Yes, sir.
2
manufacturer name on it? 2
Q. And what prompted you to ask that
3 A. No, he did not. 3 question?
4
Q. And if you flip back to the email, please. 4
A. Typically, if it was payment made to a
5
MS. PORTER: Mr. Madden, which email are 5
foreign bank or a foreign company, we would not do a
6
you referencing? 6
prepayment.
7
MR. MADDEN: Oh, I'm sorry, the cover 7
Q. And why is that?
8
email that's Exhibit 63. 8
A. The exact reason of that, I do not know.
9
MS. PORTER: Very good. Thank you. 9
That was the guidance that I was given.
1o MR. MADDEN: Thank you. 10
Q. Is there a concern in the department --
11
BY MR. MADDEN: 11
strike that.
12
Q. Are you there? 12
Is there a concern that you're aware of at
13
A. Yes, sir. 13
the Department of General Services with prepaying
14
Q. Okay. Great. And at the very end of the 14
money that would end up overseas before the products
15
first paragraph, Mr. Thomas writes, "Of course you 15
had arrived?
16
can inspect/reject and we'll refund payment." 16
MS. PORTER: Objection. Calls for
17
Do you see that? 17
deliberative process. You can't answer that one,
18
A. Yes, sir. 18
Michael.
19
Q. And once again, you understood that to be 19
THE WITNESS: Do you want me to answer
20
conveying to you that the state of California would 20
that?
21
have the ability to reject any masks it received that 21
MS. PORTER: No, please do not answer the
22 q
22
it wasn't happy with; is that correct? uestion.
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800.367.3376)
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 6 of Page 16 (58 - 61)
9 PageID#
4079
Page 58 Page 6 0
1
BY MR. MADDEN: 1 that Blue Flame Medical had caged money before? That
2 Q. Okay. Mr. Thomas replies to you, "My 2 that's something they had done?
3 company cages the dollar sign." And you understood 3 A Yes, I would assume that they held money.
4
that to mean money? 4 Q. And did Mr. Thomas tell you on or about
5
A. Yes, sir. 5 March 24th that in fact Blue Flame Medical had never
6
Q. What did you understand Mr. Thomas to mean 6
held money for a customer as of this time?
7
by "cages the money"? 7
A No, they never told me that.
8
A. My understanding is that they were holding 8 Q. Okay. Further down the text chain, still
9
the money and then that was to be used to pay to the 9 on March 24th, now at 3:03 p.m., Mr. Thomas writes,
10
manufacturers. 10 "Also if it helps, my preferred manufacturer for this
11
Q. Did Mr. Thomas tell you now or at any time 11 state is a Chinese American citizen. He lives in
12
before this message that Blue Flame Medical didn't 12 Pasadena, too, and I've known him for years."
13
have a bank account? 13 Do you see that?
14
A. No, that was never brought up to me. 14 A Yes, sir.
15
Q. Would that have been important to you in 15 Q. And Mr. Thomas then continues in the next
16
considering whether Blue Flame Medical could handle 16 message, "Henry is stuck in China because they have
17
payment made to a company and to be sent to 17
everyone locked down, but he really wants to bring
18
manufacturers? 18 his supplies here."
19
MS. PORTER: Objection. Calls for 19 Do you see that?
20
speculation. You can answer the question. 20 A Yes, sir.
21
THE WITNESS: Would that be important? 21 Q. As of this time, had Mr. Thomas told you
22
Yes. 22 who Henry was?
Page 59 Page 6 1
1 BY MR. MADDEN: 1 A. No, I do not know who Herny was.
2 Q. Did Mr. Thomas tell you at this time or 2 Q. Did you come to understand that Blue Flame
3 any other time that as of March 24th, Blue Flame 3 Medical was working with someone named Herny Huang,
4 Medical had never caged any money for anyone? 4 H-u-a-n-g?
5 A I'm sorry, can you repeat the question? 5 A. To the best of my knowledge of that, that
6 Q. Sure. Did Mr. Thomas tell you on March 6 name doesn't ring a bell.
7
24th or any other time that Blue Flame Medical had 7 Q. How about the name Great Health Companion.
8
never caged any money for anyone? 8 Did Mr. Thomas tell you at this time or any other
9 MS. PORTER: Objection. Ambiguous. 9 time you recall that Blue Flame Medical was working
10 There's a double negative in there that's a little 10 with a company called Great Health Companion?
11
confusing. 11 A. At that time, he, to the best of my
12 BY MR. MADDEN: 12 knowledge, did not identify who his partners or
13 Q. Okay. I'll try again, at least one more 13 manufacturers or other suppliers were.
14 time. Mr. Wong, you see that Mr. Thomas writes, "My 14 Q. Did you have an understanding as to where
15 company cages the money." 15 Blue Flame Medical's manufacturers were located?
16 Do you see that? 16 A. I believe he told me that most of the
17
A Yes, sir. 17 manufacturers were overseas.
18 Q. Do you understand that to mean that's 18 Q. Was Mr. Thomas any more specific than
19
something Blue Flame Medical had done before? 19 that?
20 A I'm a little confused by that question. 20 A. To the best of my knowledge, I believe he
21 Q. Sure. When Mr. Thomas wrote, "My company 21 said most of them were in Asia.
22 cages the money," did you understand that to mean 22 Q. Mr. Thomas' text message here refers to a
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800.367.3376)
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 7 of Page 17 (62 - 65)
9 PageID#
4080
Page 6 2 Page 6 4
1
preferred manufacturer. Do you see that? I'm sorry, 1
Do I have that right?
2
at 3:03 p.m. 2
A. Yes, sir.
3 A. Yes, sir. 3
Q. You ask --you list the four model numbers
4
Q. Did Mr. Thomas ever tell you --strike 4
and ask what volume Blue Flame Medical can ship
5
that. 5
immediately; is that right?
6
Did Mr. Thomas or anyone else affiliated 6
A. Yes, sir.
7
with Blue Flame Medical ever tell you that Blue Flame 7
Q. Why are you asking about immediate
8 Medical's preferred manufacturer was owned by a 8 shipment?
9
state-owned enterprise of the Chinese government? 9 A. We wanted to know how many of those masks
10
A. No. 10
we could purchase and how soon we would get them.
11
Q. Would that information have been important 11
Q. And why was it important to you as a
12
to you as a procurement officer? 12
procurement officer how soon the state of California
13
A. We would have taken that into 13
could get the N95 masks?
14
consideration. 14
A. Particularly because if delivery was
15
MS. PORTER: I'm sorry. Objection. Calls 15
months and months out, that wouldn't be a viable
16
for speculation. 16
procurement for us.
17
BY MR. MADDEN: 17
Q. And that's because you were dealing with
18
Q. Down at the bottom of page 138, you send a 18
the pandemic, right?
19
message at 3:05 p.m. Do you see that one? 19
A. That's correct.
20
A. Yes, sir. 20
Q. Is it fair to say time was of the essence
21
Q. And you ask, "What volume of' --and then 21
on these sorts of procurements?
22 you list four model numbers --"masks can you ship 22
A. Yes, sir.
Page 6 3 Page 6 5
1 immediately?" 1
Q. Were you, in the emergency procurements of
2 Do you see that? 2 PPE during the pandemic, counting on suppliers to
3 A. Yes, sir. 3 meet their delivery schedules?
4 Q. And where did those four model numbers 4 A. Yes, absolutely.
5 come from? 5 Q. And why is that?
6 A. I believe those model numbers were taken 6
A. Well, we have an agreement with a supplier
7 directly from one of the inventory sheets or sales 7
to supply the goods in an agreed upon time frame.
8 sheets that was sent to me by Mr. Thomas. 8
Q. And if a supplier could only get you masks
9 Q. And why were you asking specifically about 9 months and months later, that would be much less
10 those four model numbers? 10
helpful to the state of California; isn't that
11 A. From what I recall, those model numbers 11
correct?
12
were already approved by the Department of Public 12
A. Yes, that's correct.
13 Health and so that would have made the vetting 13
Q. In the next text message, now on to the
14 process a little bit quicker. 14
next page, at 3:08 p.m., Mr. Thomas writes to you in
15 Q. And why is that? Why would it have made 15
part, "Henry can get you 2 million out the door and
16 the vetting process quicker? 16
to you within 8 days."
17 A. If they're a known model number of a 17
Do you see that?
18 specific type of N95 respirator, they would just need 18
A. Yes, sir.
19
to verify the spec sheets that are with the product. 19
Q. Did you understand here who Henry was?
20 Q. And again, for masks to be ordered and 20
A. I assumed that was manufacturer based on
21 received by the state of California, it had to be an 21
the previous text that I received from Mr. Thomas.
22 approved model from the Department of Public Health. 22
Q. And what did you understand Mr. Thomas to
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800.367.3376)
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 8 of Page
9 PageID#
22 (82 - 85)
4081
Page 82 Page 84
1
California had to prepay 75 percent of the shipping 1
Counsel, am I speaking over you? I'm sorry.
2
costs? 2
MS. PORTER: No. I'm sorry. No,
3 A. No, that was never explained. 3 Mr. Madden, you were not.
4
Q. Okay. We're going to flip back again to 4
BY MR. MADDEN:
5
Exhibit 62, which are the text messages, if you 5
Q. Okay. The message at 10:35 a.m., do you
6
would. 6
see that one?
7
A. Sure. 7
A. Yes, sir.
8
Q. Just give me a minute to find my own 8
Q. He writes, "Michael, sorry to be annoying,
9
place. Okay. We're at page Bates number ending 139 9
but I've got everything ready on my side and the
10
and specifically I was going to start with the text 10
inventory set aside."
11
message from Mr. Thomas at 7:59 a.m. 11
What did you understand Mr. Thomas to mean
12
A. Okay. 12
by he had the inventory set aside?
13
Q. Are you there? 13
A. I believe that meant all of the masks that
14
A. Yes, sir. 14
we had previously discussed.
15
Q. You're faster than I am. Okay. 15
Q. The masks you had previously discussed
16
Mr. Thomas writes to you, "Morning, 16
meaning --meaning what?
17
Michael, looking forward to closing this first 17
A. The total 100 million quantity that we
18
transaction this morning." 18
were looking at.
19
Do you see that? 19
Q. And then Mr. Thomas had those 100 million
20
A. Yes, sir. 20
masks set aside for the state of California as of
21
Q. He asks you about next steps and thanks 21
10:35 a.m. on March 25th.
22 you for your help. Did you --do you recall speaking 22
Was that your understanding?
Page 83 Page 85
1 to Mr. Thomas around this time, the morning of March 1
A. Yes.
2 25th? 2
Q. Did you understand, based on this and your
3 A. I don't remember. 3 other discussions with Mr. Thomas, that Blue Flame
4 Q. I've asked you about a number of specific 4
Medical had purchase orders in place from suppliers
5 phone calls, but I think you've said you recalled 5
for those 100 million masks?
6
generally speaking with Mr. Thomas by phone more than 6
MS. PORTER: Objection. Ambiguous.
7
once, correct? 7
Purchase orders as to who?
8
A. I believe so. 8
MR. MADDEN: Yeah, I'll try it again.
9 Q. What, if anything, do you remember about 9
BY MR. MADDEN:
10 those telephone conversations? 10
Q. When Mr. Thomas told you that Blue Flame
11 A. To the best of my knowledge, it was just 11
Medical had inventory set aside for California's
12
reiterating what was conveyed either in the text 12
purchase, did you understand that to mean that Blue
13 messages or in the emails. 13
Flame Medical had purchased 100 million masks from
14 Q. Am I right that you don't recall 14
manufacturers for California?
15 Mr. Thomas conveying to you any additional 15
A. I assume that meant that he had 100
16 information other than what's also conveyed in 16
million available to deliver to California.
17
writing? 17
Q. You --just a second. Okay. And he
18
A. That's correct. 18
writes at the end of that message, "Anything I can do
19
Q. Oh, there it is. The next message down at 19
to help speed things up on your side?"
20 10:30 -- 20
Do you see that?
21 MS. PORTER: Excuse me. 21
A. Yes, sir.
22 MR. MADDEN: I'm sorry. I'm sorry, 22
Q. And that you understood to convey a
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800.367.3376)
Michael W ong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 157-8 Filed 05/27/21 Page 9 of Page
9 PageID#
23 (86 - 89)
4082
Page 86 Page 88
1
message that it was still important to move very 1
least electronically, Mr. Thomas sends you a text
2
quickly on this transaction? 2
message at 11 :22 p.m. Do you see that one?
3 A. Yes, sir. 3 A. 11:22 p.m.? Which page?
4
Q. You write back, "Working with finance." 4
Q. I'm sorry, I might have misspoke. 11: 22
5
Do you see that? 5
a.m., excuse me. It's the second one on the page, on
6
A. Yes, sir. 6
page 140.
7
Q. And who or what is finance in that 7 A. Which date?
8
message? 8
Q. Yeah. I'll try --I'll start over.
9 A. That would mean the, I think, controller's 9
On the page that ends in Bates number 140,
10
office. 10
there's a message from Mr. Thomas on March 25th at
11
Q. And with whom specifically were you 11
11:22 a.m. Do you see that one?
12
working on this transaction in the state controller's 12
A. Yes, sir.
13
office? 13
Q. And Mr. Thomas in the first sentence
14
A. I personally did not have anybody directly 14
writes, "Also my principal place of business is in
15
at the controller's office. 15
Glendale, California."
16
Q. Was someone else in your office working 16
Do you see that?
17
with the state controller's office? 17
A. Yes, sir.
18
MS. PORTER: Objection to form. 18
Q. And did you understand Mr. Thomas to mean
19
Speculation. 19
that Blue Flame Medical's principal place of business
20
BY MR. MADDEN: 20
was in Glendale, California?
21
Q. Sorry. Let me just try again. Maybe I 21
A. That's what I assumed, yes.
22
misunderstood. You wrote to Mr. Thomas, "Working 22
Q. Was it reassuring to you to know the state
Page 87 Page 89
1
with finance." Do you see that? 1
of California was working with a California company?
2
A Yes, sir. 2 A. Yes, sir.
3
Q. And then you identified finance to be the 3
Q. Did Mr. Thomas or anyone else affiliated
4 with Blue Flame Medical ever tell you that in fact
4
state controller's office. Were you personally
5
working with the state controller's office? 5
Blue Flame's principal place of business was in
6
A No. 6
Washington, D. C.?
7
Q. Did you have an understanding as to 7
A. No, that was never told to me.
8
whether someone else in the Department of General 8
Q. Did Mr. Thomas or anyone else affiliated
9
Services was working with the state controller's 9
with Blue Flame Medical ever tell you that Blue Flame
10
office? 10
Medical's principal executive office was at his
11
A Yes, sir. 11
business partner's political consulting firm on
12
Q. And who was the person, to your 12
Capitol Hill in Washington, D.C.?
13
understanding, in your office that was working with 13 A. No.
14
the state controller's office? 14
Q. Did Mr. Thomas or anyone else affiliated
15
A I was relaying the information to Angela 15
with Blue Flame Medical ever tell you that at this
16
Shell, my boss, who was then -- how it got 16
time, Blue Flame Medical was not registered to do
17
coordinated, I don't know. 17
business in the state of California?
18
Q. And am I right that you don't know who 18
A. No.
19
Ms. Shell was working with in the state controller's 19
Q. And did Mr. Thomas or anyone else
20
office? 20
associated with Blue Flame Medical ever tell you that
21
A I do not know. 21
at this time, Blue Flame Medical had no fixed office
22
o. Okav. If vou flip to the next page, at 22
within the state of California?
�7 Trustpoint. One Alderson. 800.FOR.DEPO
(800. 367.3376)
File and source
- File
- gov.uscourts.vaed.477405.157.8.pdf
- Size
- 461,001 bytes
- SHA-256
- d520f21efb34d2a012865a2a405faebf96bc33b38e442466bca5535f3e029a47
- Original
- PACER (login required)