Full text
E,XHIBIT I29
Case 1:20-cv-00658-LMB-IDD Document 160-11 Filed 05/27/21 Page 1 of 7 PageID#
4244
CONFIDENTIAL
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Page 1
IN
FOR
THE
THE
UNITED STATES DISTRICT
COURT
EASTERN DISTRICT OF VIRGINIA
(ALexandria
Division)
BLUE FLAME MED ICAL LLC ,
Plaintiff,
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vs.
Civil
Action
No.
L:20-cv-00658
CHAIN
N.4.,
DAVID
BRTDGE BANK,
JOHN BROUGH, and
M. EVINGER,
Defendants.
CHAIN BRIDGE BANK,
N.4.,
Third-Party
PLaintj-f
f ,
vs.
JPMORGAN CHASE BANK,
N.A.,
Th i rd- Par ty
Defendant.
***coNFIDENTIAL***
REMOTE VIDEOTAPED DEPOS I T ION OF
JOANNA WILLIAMSON
l-ocated in McLean, Virginia
Sunday, April
tt,
2O2t
Reported By:
cATHr rRrsH , RPR, CRR, CLVS
212-267-6868
5 16-608-2400
Case 1:20-cv-00658-LMB-IDD Document 160-11 Filed 05/27/21 Page 2 of 7 PageID#
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Page 190
WI LL I AMS ON
CONF I DENT IAL
going for
about another
hour.
WouLd
you like
a break?
THE VIDEOGRAPHER: This wi].l
end
media unit
4.
Going off
the record
at
2:47,
April
tL,
2O2L.
(Recess taken from 2247 p.m. to
3:05 p.m.)
THE VIDEOGRAPHER: We are back on
the record.
The time is 3:05,
April
tL,
2O2t.
This wiII
begin media unit
5.
BY MR. KETCHAM-COLWILL:
A.
Ms. WilIiamson,
can I ask you to
open up once again Plaintiff's
Exhibit
48
which was the general
account history
document , the g:reen and whi te ledger
document?
A.
I have it
open.
Which page?
a.
2534.
A.
Irm there.
A.
I bel-ieve
okay, so I'm looking
at rows 2 and 4 again,
the incoming wire
transfer
entries,
and we discussed
how
there
are equal. debit
and credit
entries
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Case 1:20-cv-00658-LMB-IDD Document 160-11 Filed 05/27/21 Page 3 of 7 PageID#
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Page LgL
refl-ected
tran s fer
.
WILLIAMSON
CONFIDENTIAL
here
for
that
incoming
wire
Do you recal- l- that?
A.
Yes.
A.
And I believe
you testified
that
the fact
that
there
are those equal debit
and credit
entries
with respect
to the
incoming wire transfer
is because the
funds were, you said,
guote,
the funds
were never actuaJ-J-y credited
to the
c]-ient'.
Do you recal- L that?
A.
Yes.
A.
Did that
statement
refer
to a
hard post?
A.
Yes, it
did.
A.
As opposed to a memo post?
A.
Right.
A.
And that' s because the funds were
memo posted to Bl-ue Flame's account?
MR. MADDEN: Object
to the form,
foundation.
THE WITNESS:
The funds were not
was trying
to
hard. posted is what I
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Page t92
WILLIAMSON
CONFIDENTIAL
convey.
BY MR. KETCHAM-COLWILL:
a.
I understand
that
your testimony
is they were not hard posted.
Do you
agree that
they were memo posted?
MR. MADDEN: Obj ection
to the
form , foundation.
THE WITNESS: I have seen the
screenshot
that
we looked at earlier
that
said
I believe
memo credit
was
the term used in that
screenshot
so it
does appear that
there
was a memo.
BY MR. KETCHAM.COLI{ILL :
a .
A memo credi t?
A.
Yes.
A.
And itts
your understanding
that
if
you
itrs
your understanding
that
the
entr j-es on thi s document are automatical
Iy
generated?
A.
Yes, it
is.
A.
And so if
you went into
this
system on March 26Eh before
batch
processing
occurred,
you would see the
debit
but it
would also indicate
that
it
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Page 193
WILLIAMSON
CONFIDENTIAL
was a memo credit?
MR. MADDEN: Obj ection
to the
form,
sisstates
the testimony.
THE WITNESS: I think
that
we
covered this
a little
bit
before
and
Irm not sure in the
with
these
automatic
journal
entries
whether or
not I would see the memo post in the
generaJ- ledger
accounts.
Irm not sure
because I dontt
often
track
them.
BY MR. KETCHAM-COLWTLL:
A.
So is it
a matter
of access,
you're
not sure you would be able to
access that
information
same day?
MR. MADDEN: Obj ection
to the
form,
misstates
the testimony.
BY MR. KETCHAM-COLWILL:
A.
I'm asking.
A.
I don't
recalL
J-ooking for
it
before
so that's
why I don't
know.
A.
But your understanding
is they
are automatically
generated
during
the
day ?
MR. MADDEN: Obj ection
to the
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Page
WILLIAMSON
CONFIDENTIAL
form r vdgue.
BY MR. KETCHAM.COLWILL:
A.
I'11
restate.
Your understanding
is that
entries
such as these debit
entries
for
wire transfers
in Chain Bridge
Bank's
Federal
Reserve Bank accounts
are
automatically
generated
as the funds hit
Chain Bridge
Bank's Federal
Reserve Bank
account?
A.
Only in a pending status.
I
donrt
believe
that
these records
are
actualJ.y
produced until
we have that
overnight
batch process
that
we talked
about.
A.
The entries
are in a pending
status
but they exist
in some form or
fashion?
MR. MADDEN: Obj ect to
vague.
Answer if
you can.
THE WITNESS: I don't
answer that.
Irrn sorry,
I
BY MR. KETCHAM-COLWILL:
A.
Isnrt
it
reasonabJ.e to
the form,
L94
know how to
donr t know.
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