Declaration of Donald Burke in Support of Third-Party Plaintiff

Summary

Donald Burke, an attorney at Robbins, Russell, Englert, Orseck & Untereiner and counsel for Third-Party Plaintiff Chain Bridge Bank in Blue Flame Medical LLC v. Chain Bridge Bank, submits a declaration supporting Chain Bridge's motion to establish the amount of indemnified fees and expenses to be awarded from Third-Party Defendant JPMorgan Chase Bank. The declaration attaches billing records to Chain Bridge from Robbins Russell, Weisbrod Matteis & Copley, Analysis Group and CRI Compliance as Exhibits 1-4. Burke states that the firm has confirmed, based on a reasonably diligent investigation, that Chain Bridge has paid all of the bills found in Exhibits 1-4. The declaration is executed on October 28, 2021 under /s/ Donald Burke.

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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.

DECLARATION OF DONALD BURKE IN SUPPORT OF THIRD-PARTY PLAINTIFF
CHAIN BRIDGE BANK, N.A.’S MOTION TO ESTABLISH THE AMOUNT OF
INDEMNIFIED FEES AND EXPENSES TO BE AWARDED FROM
THIRD-PARTY DEFENDANT JPMORGAN CHASE BANK, N.A.
I, Donald Burke, state as follows:
1.
I am over twenty-one years of age, and I am competent to give this declaration. I
have personal knowledge of the facts set forth in this declaration.
2.
I am an attorney at Robbins, Russell, Englert, Orseck & Untereiner LLP (Robbins
Russell), and counsel for Third-Party Plaintiff Chain Bridge Bank, N.A. (Chain Bridge) in the
above-captioned case.
3.
I submit this declaration in support of Third-Party Plaintiff Chain Bridge Bank,
N.A.’s Motion To Establish The Amount Of Indemnified Fees And Expenses To Be Awarded
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2
From Third-Party Defendant JPMorgan Chase Bank, N.A. in order to place before the Court true
and correct copies of certain documents that are relevant to this matter.
4.
Attached hereto as Exhibit 1 are billing records from Robbins Russell to Chain
Bridge in connection with this matter.
5.
Attached hereto as Exhibit 2 are billing records from Weisbrod Matteis & Copley
to Chain Bridge in connection with this matter.
6.
Attached hereto as Exhibit 3 are billing records from Analysis Group to Chain
Bridge in connection with this matter.
7.
Attached hereto as Exhibit 4 are billing records from CRI Compliance to Chain
Bridge in connection with this matter.
8.
My firm has confirmed, based on a reasonably diligent investigation, that Chain
Bridge has paid all of the bills found in Exhibits 1-4.

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

Executed on: October 28, 2021

/s/ Donald Burke

Washington, DC

Donald Burke
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CERTIFICATE OF SERVICE
I hereby certify that on October 28, 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:

Meredith K. Loretta (VA Bar No. 92369)
WILMER CUTLER PICKERING HALE & DORR LLP
1875 Pennsylvania Ave NW
Washington, D.C. 20006
Phone: (202) 663-6981
Email: meredith.loretta@wilmerhale.com
Counsel for Third-Party Defendant JPMorgan Chase Bank, N.A.

Peter H. White, Esq. (VA Bar No. 32310)
SCHULTE ROTH & ZABEL LLP
901 Fifteenth Street, NW, Suite 800
Washington, D.C. 20005
Phone: (202) 729-7476
peter.white@srz.com
Counsel for Plaintiff Blue Flame Medical LLC

/s/ Donald Burke
Donald Burke (VA Bar No. 76550)
ROBBINS, RUSSELL, ENGLERT,
    ORSECK & UNTEREINER LLP
2000 K Street, N.W., 4th Floor
Washington, D.C. 20006
Tel: (202) 775-4500
Fax: (202) 775-4510
dburke@robbinsrussell.com

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