Videotaped Deposition of Ethan Bearman — Blue Flame Medical LLC v. Chain Bridge Bank (E.D. Va., Dkt. 130-21)
Summary
Exhibit 21, Case 1:20-cv-00658, Document 130-21, filed 05/06/21 (E.D. Va.): excerpts from the remote videotaped deposition of Ethan Bearman, taken Thursday, January 21, 2021, marked CONFIDENTIAL, in Blue Flame Medical LLC v. Chain Bridge Bank, N.A. Matthew M. Madden questions the witness for the Defendant/Third-Party Plaintiff, and counsel from Schulte Roth & Zabel appear for the Plaintiff and the witness. Bearman testifies that he believes factories in Suuchi's network manufacture some PPE products, and that he created an Excel spreadsheet named "California N95 order" at the request of Mr. Thomas as a first draft delivery schedule for California officials at DGS. Bearman says the numbers in that draft were placeholders that he plugged in to get the spreadsheet started.
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
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“Videotaped Deposition of Ethan Bearman — Blue Flame Medical LLC v. Chain Bridge Bank (E.D. Va., Dkt. 130-21).”
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Case 1:20-cv-00658-LMB-IDD Document 130-21 Filed 05/06/21 Page 1 of 9 PageID#
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EXHIBIT 21
Ethan Bearman CONFIDENTIAL 1/21/2021
Case 1:20-cv-00658-LMB-IDD Document 130-21 Filed 05/06/21 Page 2 of 9 PageID#
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1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE EASTERN DISTRICT OF VIRGINIA
3 (Alexandria Division)
4 - - - - - - - - - - - - - - - X
5 BLUE FLAME MEDICAL LLC, : Civil Action No.
6 Plaintiff, : 1:20-CV-00658
7 vs. :
8 CHAIN BRIDGE BANK, N.A., :
JOHN J. BROUGH, and :
9 DAVID M. EVINGER, :
10 Defendants. :
11 - - - - - - - - - - - - - - - X
12 CHAIN BRIDGE BANK, N.A., :
13 Third-Party Plaintiff, :
14 vs. :
15 JPMORGAN CHASE BANK, N.A., :
16 Third-Party Defendant. :
17 - - - - - - - - - - - - - - - X
18 CONFIDENTIAL
19 Remote Videotaped Deposition Of ETHAN BEARMAN
20 Thursday, January 21, 2021
21 9:34 a.m. (EST)
22 Reported by: Dana C. Ryan, RPR, CRR
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1 1 APPEARANCES CONTINUED
2 2
3 3 ON BEHALF OF THE DEFENDANT/THIRD-PARTY
January 21, 2021
4 4 PLAINTIFF CHAIN BRIDGE BANK, N.A.:
9:34 a.m. (EST)
5 5 MATTHEW M. MADDEN, Esquire
6 6 LESLIE ESBROOK, Esquire
7 7 GARY A. ORSECK, Esquire
8 8 Robbins, Russell, Englert, Orseck,
Remote Videotaped Deposition of ETHAN
9
BEARMAN, held via Zoom video teleconference, 9 Untereiner & Sauber
10 10 2000 K Street, Northwest
before Dana C. Ryan, Registered Professional
11
Reporter, Certified Realtime Reporter and Notary 11 4th Floor
12 12 Washington, D.C. 20006
Public in and for the State of Alabama.
13 13 Telephone: (202) 775-4500
14 14 Email: mmadden@robbinsrussell.com
15 15 Email: LEsbrook@robbinsrussell.com
16 16 Email: gorseck@robbinsrussell.com
17 17
18 18
Job No. 98495
19 19
Pages: 1 - 326
20 20
Reported by: Dana C. Ryan, RPR, CRR
21 21
22 22
Page 3 Page 5
1 APPEARANCES 1 APPEARANCES CONTINUED
2 2
3 ON BEHALF OF THE PLAINTIFF 3 ON BEHALF OF THE THIRD-PARTY DEFENDANT
4 BLUE FLAME MEDICAL LLC AND THE WITNESS: 4 JPMORGAN CHASE BANK, N.A.
5 WILLIAM GUSSMAN, Esquire 5 ALBINAS PRIZGINTAS, Esquire
6 JASON M. MITCHELL, Esquire 6 MARGARITA BOTERO, Esquire
7 PETER H. WHITE, Esquire 7 Wilmer Cutler Pickering Hale & Door LLP
8 GREG KETCHAM-COLWILL, Esquire 8 1875 Pennsylvania Avenue, Northwest
9 KENI UKABIALA, Esquire 9 Washington, D.C. 20006
10 Schulte Roth & Zabel LLP 10 Telephone: (202) 663-6900
11 901 Fifteenth Street, Northwest 11 Email: albinas.prizgintas@wilmerhale.com
12 Suite 800 12 Email: margarita.botero@wilmerhale.com
13 Washington, D.C. 20005 13
14 Telephone: (202) 729-7470 14
15 Email: bill.gussman@srz.com 15 Also present:
16 Email: jason.mitchell@srz.com 16 Jason Aqui, Videographer
17 Email: pete.white@srz.com 17
18 Email: gregory.ketcham-colwill@srz.com 18
19 Email: ekenedilichukwu.ukabiala@srz.com 19
20 20
21 21
22 22
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1 number 805. I guess that's the only page of it. 1
are still short, but I have other sources.
2 A I see it. 2
Do you see that?
3 Q Okay. You see at the top of this 3
A I do.
4 attachment it says, GHC products catalog? 4
Q Did you disagree with Mr. Thomas as of
5 A I do. 5
the time you received this email that Blue Flame
6 Q Okay. And GHC, you understand to mean 6
Medical was still short in terms of fulfilling
7 Great Health Companion? 7
California's mask order with available supplies?
8 A I do. 8
MR. GUSSMAN: Objection to form.
9 Q And at least, in form, if not 9
THE WITNESS: (Reviews document.)
10 necessarily every number on every row, you'll 10
It's possible. I -- I don't recall
11 agree with me this matches the attachment we just 11
specifically.
12 saw to Exhibit 15? 12
BY MR. MADDEN:
13 MR. GUSSMAN: Objection. 13
Q Okay. Well, do you recall telling
14 THE WITNESS: I mean, it looks like it. 14
Mr. Thomas, in words or substance, that you
15 BY MR. MADDEN: 15
disagreed with that statement?
16 Q Okay. And do you recall reviewing this 16
A I do not recall that.
17 attachment? 17
Q Okay. Okay.
18 A I don't recall specifically reviewing 18
MR. MADDEN: Let's look at Exhibit 22,
19 this attachment. 19
please, Leslie.
20 Q Okay. And -- but it's your testimony 20
THE WITNESS: I have it, Counsel.
21 that by Wednesday, March 25th, at 4:43 in the 21
MR. GUSSMAN: I don't have it.
22 morning Pacific time, you had come not to rely on 22
BY MR. MADDEN:
Page 187 Page 189
1 the information in the allocatable inventory 1
Q Okay. Exhibit 22, which has been
2 column of a GHC products catalog; is that correct? 2
previously marked as an email, Bates numbered
3 A Yeah, I -- correct. 3
BFM13558 and its attachment 559.
4 Q Okay. And the same question for the 4
MR. GUSSMAN: I have it now. Thank
5 monthly capacity column. By this time, you had 5
you.
6 come not to rely on that information in GHC 6
MR. MADDEN: Okay.
7 products catalogs; correct? 7
BY MR. MADDEN:
8 A That's -- 8
Q Mr. Bearman, you see Exhibit 22 is an
9 MR. GUSSMAN: Objection. 9
email from you to Mr. Thomas, Mr. Gula and
10 THE WITNESS: -- correct. 10
Ms. Brown, 9:15 p.m. Pacific on Wednesday,
11 BY MR. MADDEN: 11
March 25th.
12 Q Okay. On the first page of Exhibit 17 12
Do you see that?
13 under the See Attached email at the top, 13
A I do.
14 Mr. Thomas writes to you and others at 1:55 in the 14
Q Okay. And then there's an attachment
15 morning on Wednesday, March 25th. 15
to your email that's an Excel spreadsheet; is that
16 Do you see that email? 16
right?
17 A I do. 17
A That looks right.
18 Q Starting with the second sentence, 18
Q Okay. And the -- if you see on the
19 Mr. Thomas writes, Need to source inventory 19
email, it lists the name of the attachment -- the
20 amounts to tell California what we'll be sending 20
file name is California N95 order.
21 them. Gula has Henry's latest numbers broken down 21
Do you see that?
22 by model for what California needs. I think we 22
A Yes.
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1 1
Q Okay. Did you create this document? first line was the purchase order I had negotiated
2 2
A Yes, I did. with Suuchi, Inc. The third line was, I believe,
3 3
Q And for what purpose did you create it? a purchase order we were going to issue to Henry
4 4
A At the request of Mr. Thomas to help for an initial order that he, if I recall
5 5
lay out a schedule for California, and this was correctly, had ready to ship, and that was
6 6
the first draft. communicated to California officials.
7 7
Q Okay. And did Mr. Thomas explain to And then the remainder lines that are
8 8
you why a schedule was needed? all identical were placeholders.
9 9
A Yes. BY MR. MADDEN:
10 10
Q What did he say? Q And just to be clear, those lines, the
11 11
A I believe he said that he wanted to lay placeholders, are the ones that start with the
12 12
out a schedule -- delivery schedule to give to 3 million masks with an arrival date of April 8;
13 13
California officials at DGS. correct?
14 14
Q Okay. On the spreadsheet, you see A Correct.
15 15
there's a column labeled Arrival Date? Q Okay. And those you filled in without
16 16
A Yes. any basis, as just placeholders. Do I have that
17 17
Q And is the information in that column right?
18 18
intended to reflect the arrival date of various A To the best of my recollection, yes --
19 19
tranches of mask shipments to California in -- at Q Okay.
20 20
its delivery point? A -- so we could work on the spreadsheet
21 21
MR. GUSSMAN: Objection to form. as Mr. Thomas had more detail than I had at that
22 22
THE WITNESS: I believe so. I -- I moment.
Page 191 Page 193
1 1 Q Okay. On the first line that says the
can't recall if it was for coming through the port
2 2 supplier is Suuchi, there's no arrival date filled
or actual arrival at their facility because of
3 3 in.
variability between the port and their facility.
4 4 Do you see that?
I don't recall which.
5 5 A Correct.
BY MR. MADDEN:
6 6 Q Why was that?
Q Okay. And you called this a first
7 7 A Because I didn't enter a date.
draft; right?
8 8 Q Did you have a date -- an arrival date
A Yes.
9 9 corresponding to masks coming from Suuchi for the
Q And you prepared the, sort of,
10 10 State of California?
quantities of masks associated with various
11 11 A I don't believe so. I don't believe I
arrival dates in this first draft; correct?
12 12 had an arrival date yet.
A Yeah, I -- I literally just plugged in
13 13 Q Okay. You see at the bottom of the
numbers to get the spreadsheet started for us to
14 14 spreadsheet the total number of masks reflected is
fill out.
15 15 58 million; is that right?
Q Okay. And what was the basis on which
16 16 A Yep. Yes, that is what is there.
you came up with these numbers?
17 17 Q Okay. And then remaining, there's a
A I don't believe there was a basis. I
18 18 number in red, 42 million, below it.
believe I was just starting to plug in numbers for
19 19 Do you see that?
our discussion to fill it out.
20 20 A Yes.
Q You just made this up?
21 21 Q And the remaining masks, am I right,
MR. GUSSMAN: Objection to form.
22 22 are the 42 million masks for which no arrival date
THE WITNESS: And let me clarify. The
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1 1 MS. ESBROOK: Sure. Here it is.
or supplier is provided in this version of the
2 2 THE WITNESS: My turn to get the
spreadsheet; correct?
3 3 network errors. Okay. I have it, Counsel.
MR. GUSSMAN: Objection to form.
4 4 MR. MADDEN: All right. I'm not sure I
THE WITNESS: Can you ask that again,
5 5 do. Sorry. Just give me a minute to make sure
please?
6 6 I'm looking at the right thing.
BY MR. MADDEN:
7 7 MR. GUSSMAN: I have it.
Q Sure.
8 8 Matt, after this exhibit, could we take
The 42 million remaining masks listed
9 9 a break -- a short break?
at the bottom of this spreadsheet in Exhibit 17,
10 10 MR. MADDEN: Yeah. Of course.
that reflects 42 million masks for which no
11 11 BY MR. MADDEN:
supplier and no arrival date is reflected in this
12 12 Q Okay. Just to make sure we're looking
version of the spreadsheet; correct?
13 13 at the same thing, Exhibit -- sorry. I need to
A I dispute that categorization, no.
14 14 open up the chat version. Now, I have the network
It's a mathematical formula that just simply said,
15 15 error.
okay, we're delivering 100 million masks. I
16 16 MR. MADDEN: Why don't we take a break
plugged in numbers as previously testified to that
17 17 now while I figure this out. Is that all right?
were placeholders, and it just says you're
18 18 MR. GUSSMAN: That's fine.
42 million short.
19 19 MR. MADDEN: All right. Let's go off
Q Okay.
20 20 the record.
A So it -- I don't -- it has no meaning
21 21 THE VIDEOGRAPHER: Off the record at
beyond that.
22 22 2:30.
Q Okay. And if you take the 58 million
Page 195 Page 197
1 masks in the total line and subtract the 6 million 1 (Recess -- 2:30 p.m.)
2 masks for which Suuchi is listed as the supplier, 2 (After recess -- 2:40 p.m.)
3 you'll agree with me that the rest of the 3 THE VIDEOGRAPHER: We are now back on
4 52 million masks, at least according to this 4 the record. The time is 2:40 p.m.
5 spreadsheet, are coming from Great Health 5 BY MR. MADDEN:
6 Companion? 6 Q Okay. Mr. Bearman, we were just -- we
7 MR. GUSSMAN: Objection to form; 7 were just looking at Exhibit 22, which is a
8 misleading. 8 9:15 p.m. Pacific email you sent on March 25th.
9 THE WITNESS: Again, just 9 Are you with me?
10 arithmetically, just math, the 58 million minus 10 A Yes.
11 6 million equals 52 million, based on placeholders 11 Q Okay. And we've put in the chat what's
12 for a draft, sure. 12 been previously marked Exhibit 23, which is an
13 BY MR. MADDEN: 13 email and its attachment.
14 Q Okay. And what you call the 14 Do you have that?
15 placeholders in here are 3 million masks being 15 A Yes.
16 supplied by Great Health Companion every day from 16 Q Okay. And Exhibit 23 is an email,
17 April 8th through April 30th. 17 Mr. Bearman, that you sent to Mike Gula, John
18 Is that -- do I have that right? 18 Thomas and Jennilee Brown at 5:25 p.m. on
19 A That -- yes, that's what it says. 19 March 25th; correct?
20 MR. GUSSMAN: Objection to form. 20 A Yes.
21 MR. MADDEN: Okay. Let's look at 21 Q So this is ten minutes after you had
22 Exhibit 23, please. 22 sent the email that's Exhibit 22; right?
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1 buyers and what we were seeing when other people 1
Do you see that?
2 were trying to sell Blue Flame masks. 2
A Yes.
3 Q Other than what you were hearing from 3
Q Did you determine that shipping cost
4 buyers and seeing when other people were trying to 4
for the California invoice?
5 sell Blue Flame masks, do you recall any other 5
A I believe I may have calculated that,
6 information that Blue Flame considered in terms of 6
yes, I think so.
7 what the market was bearing? 7
Q And how did you go about calculating
8 A I don't recall other factors. 8
that?
9 Q Okay. And I believe you said one of 9
A If I recall correctly, it was based on
10 the factors considered was what was fair and 10
what suppliers had said the going rate of air
11 reasonable; is that correct? 11
freight for N95 masks from China to California
12 A Is that what the transcript says? 12
would be.
13 MR. GUSSMAN: Maybe rephrase your 13
Q Which suppliers do you have in mind who
14 question. 14
had provided Blue Flame that information?
15 MR. MADDEN: Sure. 15
A It's most likely the -- Great Health
16 BY MR. MADDEN: 16
Companion as the primary source of that
17 Q Was one of the factors Blue Flame 17
information.
18 considered in setting the price on the California 18
Q And was that information on the going
19 order whether it was fair and reasonable? 19
rate of air freight a per-shipment figure, a
20 A I don't recall that specific phrase. 20
per-mask figure?
21 Q Do you recall a substance of a factor 21
How was that information presented, if
22 along the lines of fairness and reasonableness? 22
you recall?
Page 243 Page 245
1 1 A I don't recall if it was per mask or
A Yes. Again, that's -- I recall that
2 2 per pallet, but that's a typical way of measuring
is, again, within the range of what other people
3 3 it.
are charging, and potentially -- although it's
4 4 Q Which is a typical way of measuring
never achieved that, not even near it -- what
5 5 that?
price laws may guide.
6 6 A Any. Per unit, per pallet, per carton.
Q Okay. Did you discuss the $4.76 per
7 7 Q It could be any of those?
mask price with Mr. Thomas?
8 8 A Yes.
A I'm sure we did.
9 9 Q Okay. Do you recall specifically
Q How about with Mr. Gula?
10 10 receiving information from Great Health Companion
A I don't specifically recall discussing
11 11 on what its shipping cost would be for the
that price with Mr. Gula.
12 12 California order?
Q Okay. Did Mr. Thomas instruct you, in
13 13 A I don't remember that specifically, but
words or substance, to set the per-mask price for
14 14 I -- I don't remember that specifically.
the California order just below the upper end of a
15 15 Q Okay. The last line -- well, I'll take
price range he had previously provided the state?
16 16 a step back.
MR. GUSSMAN: Objection to form.
17 17 The second-to-last line of the -- I'll
THE WITNESS: I don't remember him
18 18 call it chart in your email that reads,
communicating that to me.
19 19 $609,184,800, do you see that?
BY MR. MADDEN:
20 20 A I do.
Q Okay. The next line down in your email
21 21 Q And that was the total order amount for
that's Exhibit 74 says, Shipping, and then the
22 22 the California order?
figure next to that is $95.2 million.
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1 A That looks correct. 1 potentially for Mr. Thomas' ease of use.
2 Q Okay. And then the next line in your 2 Q Okay. And was it your understanding at
3 email reads, Deposit (75 percent), and then the 3 the time you sent this email that Blue Flame
4 figure $456,888,600. 4 Medical was requiring California to prepay a
5 Do you see that? 5 75 percent deposit on the total order amount?
6 A I do. 6 A I -- if I recall correctly, I was under
7 Q What did that line, Deposit 7 the understanding that there was a 75 percent
8 (75 percent), reflect? 8 deposit.
9 A 75 percent of that number above it. 9 Q And that that was a deposit that Blue
10 Q And why was that part of the California 10 Flame Medical was requiring of California in
11 invoice? 11 connection with this transaction; correct?
12 Let me -- let me rephrase. 12 A Yes.
13 Why -- 13 Q Okay. Shifting gears a little bit, who
14 MR. GUSSMAN: Objection -- 14 is Suuchi Ramesh?
15 BY MR. MADDEN: 15 A She's the, I believe, founder and chief
16 Q -- were you -- 16 executive officer of Suuchi, Inc.
17 MR. GUSSMAN: -- to form. Yeah, this 17 Q And how did you come -- did you --
18 is not an invoice. 18 sorry. Strike that.
19 MR. MADDEN: Yeah. Let me -- let me -- 19 You communicated with Ms. Ramesh about
20 MR. GUSSMAN: Are you talking about why 20 the potential supply of N95 masks in March 2020;
21 it's a part of this email -- 21 is that right?
22 MR. MADDEN: I said -- 22 A Yes, I did.
Page 247 Page 249
1 MR. GUSSMAN: -- or something else? 1 Q And how did you come to be
2 MR. MADDEN: Bill, I said I'd rephrase. 2 communicating with Ms. Ramesh about that topic?
3 MR. GUSSMAN: Okay. I didn't hear you. 3 Who reached out to whom? How did you
4 MR. MADDEN: Okay. 4 link up?
5 BY MR. MADDEN: 5 A Which question do you want me to
6 Q Why were you providing that "deposit 6 answer?
7 (75 percent)" information to Mr. Thomas in this 7 Q Fine.
8 email in connection with the California invoice? 8 How did you come to be communicating
9 A Communicating information as the 9 with Ms. Ramesh about that topic?
10 calculation. 10 A I have a cousin who at the time was
11 Q Yeah. My question is why. 11 vice president or senior vice president working at
12 A I -- I don't know specifically why. I 12 Suuchi, Inc., and I believe I had seen a post on
13 don't recall that specifically. 13 LinkedIn that they were trying to provide PPE, and
14 Q Do you recall generally why you were 14 so I reached out to my cousin and said, oh, my
15 providing information on what a 75 percent deposit 15 gosh, get me more information.
16 would be in connection with the California 16 Q And what's that --
17 invoice? 17 A So that's how I linked up with Suuchi.
18 A Generally speaking, that would be 18 Q Okay. And what's that cousin's name?
19 logical because there was discussion of a 19 A His name is Jason Bunin, B-U-N-I-N.
20 75 percent deposit, and if the numbers are being 20 Q Do you have an understanding as to
21 calculated, it looks -- above and that number is 21 whether Suuchi, Incorporated was, itself, a mask
22 $609,184,800, then I would calculate that for -- 22 manufacturer?
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1 1 Q But that Suuchi, Incorporated, itself,
Let me rephrase. Strike that question.
2 2 does not manufacture PPE; correct?
Did you have an understanding in
3 3 A I'm not sure.
March 2020 as to whether Suuchi, Incorporated,
4 4 Q Okay. Sorry. Just a second.
itself, made N95 masks?
5 5 Were you the principal person at Blue
A I do not recall that I believed that
6 6 Flame Medical communicating with Suuchi about its
they actually manufactured N95 masks, but I don't
7 7 PPE supply?
recall specifically. I might have thought it at
8 8 A Yes.
the time.
9 9 Q Okay. On or about March 24 -- Tuesday,
Q Okay. In late March 2020, what
10 10 March 24, 2020, did you have an understanding one
understanding did you have, if any, as to what
11 11 way or the other as to whether Suuchi had
Suuchi, Incorporated's principal business was?
12 12 6 million N95 masks that were ready to ship
A At the time -- if I recall correctly, I
13 13 immediately?
felt -- apologies.
14 14 A I don't recall if it was March 24th,
When I first -- the time frame that
15 15 specifically, but, yes, somewhere around that date
you're asking for is -- is broad.
16 16 we were -- we fully believe that she had 6 million
Q Okay.
17 17 N95 masks ready.
A Can you narrow that for me?
18 18 Q And by "ready," you mean you believe
Q Sure.
19 19 she had 6 million N95 masks already manufactured
By March 25th, 2020, what did you
20 20 and ready to ship; is that right?
understand Suuchi, Incorporated's principal
21 21 A That she had access to the inventory,
business to be, if you had an understanding?
22 22 yes.
A If I recall -- the best way I know how
Page 251 Page 253
1 to explain what my understanding was is they were 1 Q Okay. And what was the basis of that
2 a supply chain -- let me rephrase that. 2 belief?
3 They were a clothing and PPE 3 A Based on the company, Suuchi, Inc.'s,
4 manufacturer with an extensive network of 4 representations to Blue Flame Medical and myself.
5 factories and software to manage all of that along 5 Q That was going to be my question. Were
6 with people on the ground around the world to 6 those representations made to you or to others at
7 ensure high quality. 7 Blue Flame?
8 Q And as of March 25th, 2020, did you 8 A I believe both.
9 believe that Suuchi, Incorporated was, itself, a 9 Q Okay. In terms of the representations
10 PPE manufacturer? 10 made to you, who at Suuchi made those
11 A Yes, at that time I believe I believed 11 representations to you?
12 that they were making some PPE products. 12 A I don't actually recall all of the
13 Q Okay. Did you later come to believe 13 people I spoke with, but Suuchi Ramesh is the name
14 that -- or understand that Suuchi, Incorporated 14 I recall off the top of my head as the CEO who I
15 does not, itself, manufacture PPE products? 15 believe I had most contact with, and I believe she
16 A I -- I'm not sure. I'm not -- I'm just 16 had a -- like a head of procurement, and I seem to
17 not sure how to answer that. I -- I'm not clear. 17 recall that he also shared that kind of
18 Q Okay. Well, as you sit here today, do 18 information --
19 you have an understanding as to whether Suuchi, 19 Q Okay.
20 Incorporated, itself, makes PPE? 20 A -- of masks.
21 A I believe that factories in Suuchi's 21 Q And was it your understanding that
22 network manufactures some PPE products. 22 Suuchi's inventory of 6 million N95 masks was
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- Our copy
- 130-att21.pdf
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