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Blue Flame Medical v. Chain Bridge Bank — Notice of Motion to File Reply Under Seal

Date
2021-11-29

Summary

A notice of motion to file under seal filed November 29, 2021 as Document 207 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. Third-Party Plaintiff Chain Bridge Bank, N.A. gives notice that it will move to file a redacted version of its reply in support of its motion to establish the amount of indemnified fees and expenses to be awarded from Third-Party Defendant JPMorgan Chase Bank, N.A., keeping the unredacted reply under permanent seal. The notice states that the reply quotes billing records submitted at Dkt. No. 196, which the Court kept under seal at Dkt. No. 197. Citing Local Civil Rule 5(C), it states a seven-day period for memoranda or objections, and it includes a certificate of service.

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Cite this document

“Blue Flame Medical v. Chain Bridge Bank — Notice of Motion to File Reply Under Seal.” Original at ecf.vaed.uscourts.gov, dated 2021-11-29. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-11-29-plaintiff-v-chain-bridge-bank-n-a-john-j-b03fff61-1/, SHA-256 b03fff610b43a205015ceb0d690e8b5fbf0e0e11df8090fa737b02f6fd5a8c3b.

Full text

Case 1:20-cv-00658-LMB-IDD            Document 207      Filed 11/29/21      Page 1 of 3 PageID#
                                            5242



                      IN THE UNITED STATES DISTRICT COURT
                      FOR THE EASTERN DISTRICT OF VIRGINIA
                                (Alexandria Division)

  BLUE FLAME MEDICAL LLC,

                         Plaintiff,
                                                       Civil Action No. 1:20-cv-00658
  v.

  CHAIN BRIDGE BANK, N.A., 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.


               THIRD-PARTY PLAINTIFF CHAIN BRIDGE BANK, N.A.’S
                    NOTICE OF MOTION TO FILE UNDER SEAL

       Notice is hereby given that Third-Party Plaintiff Chain Bridge Bank, N.A. (Chain Bridge)

will file a Motion to File Under Seal seeking to file a redacted version of its Reply in Support of

Chain Bridge’s Motion To Establish The Amount Of Indemnified Fees And Expenses To Be

Awarded From Third-Party Defendant JPMorgan Chase Bank, N.A., and maintaining the

unredacted version of Chain Bridge’s Reply under permanent seal. The Reply discusses and quotes

from certain billing records that were submitted by Chain Bridge in support of its motion to

establish the amount of indemnified fees (see Dkt. No. 196), and which this Court has already

determined should remain under permanent seal (see Dkt. No. 197).
Case 1:20-cv-00658-LMB-IDD           Document 207         Filed 11/29/21      Page 2 of 3 PageID#
                                           5243



       In accordance with Local Civil Rule 5(C), Third-Party Plaintiff states the following: All

parties and non-parties may submit memoranda in support of or in opposition to the Motion To

File Under Seal within seven (7) days after the filing of the Motion, and they may designate all or

part of such memoranda as confidential. Any information designated as confidential in a

supporting or opposing memorandum will be treated as sealed pending a determination by the

Court on the Motion. Any person objecting to the Motion must file an objection with the Clerk

within seven (7) days after the filing of the Motion, and if no objection is filed in a timely manner,

the Court may treat the Motion as uncontested.



Dated: November 29, 2021                          Respectfully submitted,

                                                  /s/ Donald Burke
                                                  Gary A. Orseck (pro hac vice)
                                                  Matthew M. Madden (pro hac vice)
                                                  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
                                                  Counsel for Third-Party Plaintiff




                                                  2
Case 1:20-cv-00658-LMB-IDD          Document 207         Filed 11/29/21     Page 3 of 3 PageID#
                                          5244



                                CERTIFICATE OF SERVICE
       I hereby certify that on November 29, 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
       WILMER CUTLER PICKERING HALE & DORR LLP
       1875 Pennsylvania Ave NW
       Washington, DC 20006
       Phone: (202) 663-6981
       Email: meredith.loretta@wilmerhale.com
       Counsel for Third-Party Defendant JPMorgan Chase Bank, N.A.

       Peter H. White, Esq.
       SCHULTE ROTH & ZABEL LLP
       901 Fifteenth Street, NW, Suite 800
       Washington, DC 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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