Pandemic Darlings The pandemic economy, in original documents
Home Source documents Deposition of Timothy P. Coffey — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va., Dkt. 130-58)

Deposition of Timothy P. Coffey — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va., Dkt. 130-58)

Summary

Exhibit 58, Case 1:20-cv-00658, Document 130-58, filed 05/06/21 (E.D. Va.): excerpts from the remote deposition via Zoom of Timothy P. Coffey, taken Thursday, February 11, 2021, marked HIGHLY CONFIDENTIAL, in Blue Flame Medical LLC v. Chain Bridge Bank, N.A. Donald Burke questions the witness for the Defendant/Third-Party Plaintiff. Coffey testifies that he was a vice president in the payment controls department of JPMorgan Chase, that his employment ended on December 11th, 2020, and that his role was eliminated due to downsizing, budget cuts and so forth. Coffey also states his belief that Chain Bridge was suspicious of the transaction and that JPMorgan's request to send a Fed service message is what drove the return of funds.

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

Cite this document

“Deposition of Timothy P. Coffey — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va., Dkt. 130-58).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cv-00658-dkt-130-58-e-d-va-d5ff88d6dd/, SHA-256 98db243b5a782a2f3072a43c98c3a2f120b735dc8e37cc2135f9146955f25c39.

Full text

Case 1:20-cv-00658-LMB-IDD   Document 130-58   Filed 05/06/21   Page 1 of 23
                              PageID# 1933




                     EXHIBIT 58
Timothy P. Coffey             HIGHLY CONFIDENTIAL                           2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21   Page 2 of 23Page 1 (1)
                                 PageID# 1934

  1               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.,                    :    1:20-cv-00658

  9     JOHN J. BROUGH and DAVID M.                 :

 10     EVINGER,                                    :

 11          Defendants.                            :      HIGHLY

 12     _____________________________               :    CONFIDENTIAL

 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                                    Thursday, February 11, 2021

 21                  Deposition via Zoom of TIMOTHY P. COFFEY,

 22   a witness herein, called for examination by counsel

                               www.trustpoint.one                     800.FOR.DEPO
                             www.aldersonreporting.com                 (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                             2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                     Page 3 ofPage
                                                                                                            23 2 (2 - 5)
                                 PageID# 1935
                                                           Page 2                                                   Page 4
 1 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 Defendant/Third-Party Plaintiff
 4 Notary Public in and for the District of Columbia,                4   Chain Bridge Bank, N.A.:
 5 taken at 9:31 a.m. EST, Thursday, February 11, 2021,              5      DONALD BURKE, ESQ.
 6 and the proceedings being taken down by Stenotype by              6      GARY A. ORSECK, ESQ.
 7 MARY GRACE CASTLEBERRY, RPR, and transcribed under                7      ZACHARY N. FERGUSON, ESQ.
 8 her direction.                                                    8      Robbins Russell Englert, Orseck,
 9                                                                   9       Untereiner & Sauber
10                                                                  10      2000 K Street, N.W., 4th Floor
11                                                                  11      Washington, D.C. 20006
12                                                                  12      (202) 775-4500
13                                                                  13      dburke@robbinsrussell.com
14                                                                  14      gorseck@robbinsrussell.com
15                                                                  15      znferguson@robbinsrussell.com
16                                                                  16

17                                                                  17

18                                                                  18

19                                                                  19

20                                                                  20

21                                                                  21

22                                                                  22
                                                           Page 3                                                   Page 5
 1                                                                   1 APPEARANCES (Continued):
     APPEARANCES:
 2                                                                   2

 3                                                                   3   On behalf of the Third-Party Defendant JPMorgan
       On behalf of the Plaintiff Blue Flame Medical
 4                                                                   4   Chase Bank:
       LLC:
 5                                                                   5      ALAN SCHOENFELD, ESQ.
          BILL GUSSMAN, ESQ.
 6                                                                   6      ALBINAS PRIZGINTAS, ESQ.
          GREG KETCHAM-COLWILL, ESQ.
 7                                                                   7      TODD CLAYTON, ESQ.
          JASON MITCHELL, ESQ.
 8                                                                   8      Wilmer Cutler Pickering Hale & Dorr LLP
          KENI UKABIALA, ESQ.
 9                                                                   9      1875 Pennsylvania Avenue, N.W.
          Schulte Roth & Zabel
10                                                                  10      Washington, D.C. 20006
          901 15th Street, N.W., Suite 800
11                                                                  11      (212) 663-6981
          Washington, D.C. 20005
12                                                                  12      alan.schoenfeld@silmerhale.com
          (202) 729-7476
13                                                                  13      albinas.prizgintas@wilmerhale.com
          bill.gussman@srz.com
14                                                                  14      todd.clayton@wilmerhale.com
          gregory.ketcham-colwill@srz.com
15                                                                  15
          jason.mitchell@srz.com
16                                                                  16   ALSO PRESENT:
          ekenedilichukwu@ukabiala@srz.com
17                                                                  17     JASON AQUI, Videographer
             and
18                                                                  18
          ETHAN BEARMAN, ESQ.
19                                                                  19
          The Bearman Firm
20                                                                  20
          10250 Constellation Boulevard, Suite 100
21                                                                  21
          Los Angeles, California 90067
22                                                                  22
          (747) 344-1004
                                                      www.trustpoint.one                                 800.FOR.DEPO
                                                    www.aldersonreporting.com                             (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                      2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                               Page 4Page
                                                                                                   of 23
                                                                                                       4 (10 - 13)
                                 PageID# 1936
                                                  Page 10                                                    Page 12
 1     A. It's -- sorry, 10410 Highland,                    1      A. Generally, they were cases regarding
 2 H-i-g-h-l-a-n-d, Manor, M-a-n-o-r, Drive. And that        2 either fraudulent wire transfers or path of funds or

 3 was in Tampa, Florida 33610.                              3 something of that nature, something where I was

 4     Q. Thank you. And just sort of by way of              4 called about to be a subject matter expert.

 5 ground rules, I want to let you know it's important       5     Q. I see. And have you testified in court
 6 that we speak one at a time and don't talk over each      6 proceedings, in a courtroom rather than by

 7 other. That allows the court reporter to get an           7 deposition?

 8 accurate transcription of the testimony. It's also        8     A. Yes, I have.
 9 important that you provide a verbal answer, not just      9     Q. And how many times have you done that?
10 a head nod, so that we can get an accurate record.       10     A. Probably 20 to 25 times.
11        Do you understand that?                           11     Q. And are all of those matters that arose in
12     A. Yes.                                              12 connection with your employment at JPMorgan?

13     Q. And over the course of the day, I'll try          13     A. That is correct.
14 to take a break about every hour or so just so           14     Q. Were you testifying as an expert witness
15 everybody gets a short rest. If you need a break off     15 in any of those court proceedings?

16 that schedule, just let me know and we should be able    16     A. I was testifying as a subject matter
17 to accommodate you. The only exception is if a           17 expert on behalf of Chase.

18 question is pending, we'll ask you to finish             18     Q. I see. And again, you may not remember
19 answering the question before we go off the record.      19 all of those 20 to 25 court proceedings, but can you

20        Do you understand that?                           20 describe generally what sort of matters they

21     A. Yes. Thank you.                                   21 involved?

22     Q. Is there any reason today that you won't          22     A. Largely has to do with the path of funds,
                                                  Page 11                                                    Page 13
 1 be able to give truthful and accurate testimony?         1 how a wire moves from system to system.    Largely
 2    A. No.                                             2 trying to find out if things are considered to be
 3    Q. Mr. Coffey, have you ever been deposed          3 interstate or intrastate.
 4 before?                                               4     Q. I'm sorry, I just didn't hear the last
 5    A. Yes, I have.                                    5 portion of your answer. Could you repeat that?
 6    Q. How many times?                                 6     A. Sure. The majority of my testimony was as
 7    A. Approximately six to eight times.               7 a subject matter expert. And generally, we're trying
 8    Q. Do you recall the most recent time?             8 to find out what we will call path of funds, how the
 9    A. Yes. I believe it was via a Zoom -- a           9 wire moves through the systems. Does it go through
10 Zoom call also.                                      10 New York City, where does the actual wire move to,

11        THE REPORTER: This is the court reporter. 11 those types of things.
12 Could you repeat that answer?                        12     Q. I see. I believe you testified a moment
13        THE WITNESS: I said yes, I believe it was     13 ago that you're no longer employed by JPMorgan; is
14 via a Zoom call also. Zoom.                          14 that correct?

15 BY MR. BURKE:                                        15     A. That's correct.
16    Q. And are these all -- are all of those          16     Q. When did your employment with JPMorgan
17 other depositions matters that arose in connection   17 cease?

18 with your employment at JPMorgan?                    18     A. December 11th, 2020.
19    A. Yes, sir.                                      19     Q. Are you currently employed by another
20    Q. You may not recall each and every one of       20 employer?
21 those, but to the extent you do recall them, can you 21     A. I am not.
22 describe the nature of the cases that they involved? 22     Q. Can you tell me the reason for your
                                            www.trustpoint.one                                     800.FOR.DEPO
                                          www.aldersonreporting.com                                 (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                         2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                  Page 5Page
                                                                                                      of 23
                                                                                                          5 (14 - 17)
                                 PageID# 1937
                                                  Page 14                                                     Page 16
 1 employment with JPMorgan ceasing?                         1 in the global command center in your prior position?

 2    A. Yes. My understanding is my exact role              2    A.    Sure. I managed a global team. We had
 3 that I had was being eliminated due to downsizing,        3 three different locations, one in Bournemouth, one in

 4 budget cuts and so forth.                                 4 India, one in Tampa.    We -- it was a 24 by 17 that
 5    Q. I see. And when did you learn that your             5 monitored and maintained the health of the operations

 6 position would be eliminated for that reason?             6 platforms that are out there, making sure all the

 7    A. The last week of October.                           7 servers, all the applications are up and running,

 8    Q. I see. What was your position with                  8 that mics are up and running, the links have dropped

 9 JPMorgan prior to leaving their employment in             9 and so forth.   It was a health center for technology
10 December of 2020?                                        10 and for the operations.

11    A. My position, I was a vice president with           11    Q.    I see. And is that an information
12 JPMorgan Chase. I was in the -- what we call the         12 technology role or would you describe it in a

13 payment controls department.                             13 different way?

14    Q. And is that the same role you had with             14    A.    I would probably describe it as more of a
15 JPMorgan in March of 2020?                               15 help with the operations role with some technical

16    A. Yes.                                               16 parts infused in it.

17    Q. And how long had you been employed by              17    Q.    I see. And prior to your position there
18 JPMorgan as of March of 2020?                            18 in the global command center, what was your position

19    A. Since 1988.                                        19 at JPMorgan?

20    Q. How long had you been in that role that            20    A.    I moved down to Tampa in 2002, and I was
21 you occupied as of March of 2020?                        21 managing the multicurrency investigations team.

22    A. Approximately five to six years.                   22    Q.    And what did you do in that role?
                                                  Page 15                                                          Page 17
 1     Q. And can you tell me what your position was         1     A. I would manage a staff of about 50 people
 2 prior to taking that position?                            2 that would do investigations for currencies not just

 3     A. Yes. Prior to coming into the payment              3 involving U.S. dollar.

 4 controls department, I managed what we call the           4     Q. What sort of investigations did that
 5 global command center.                                    5 entail?

 6     Q. And so that would have been in                     6     A. They were wire investigations.
 7 approximately 2015 when you changed positions?            7     Q. And how long had you been in that role
 8     A. That sounds about right, yes.                      8 before you moved on to the global command center?

 9     Q. And how long were you in that position             9     A. Approximately four years, three to four
10 managing the global command center?                      10 years.

11     A. For about 10 to 11 years.                         11     Q. And can you describe your position before
12     Q. Can you describe your position -- or              12 your role in the multicurrency investigations team?

13 strike that.                                             13     A. So I started in the bank in '88. I had
14         Can you describe your tasks in your              14 left the bank roughly in '98 for approximately three

15 position as of March of 2020 in the payment controls     15 and a half to four years, then came back to Chase.

16 department?                                              16         My coming back to Chase was in 2002, which
17     A. Yes. My primary responsibility was to try         17 was the role I just mentioned to you of the

18 to recover suspicious wire activity that was released    18 multicurrency investigations manager.

19 from the bank already, wires that had already gone       19     Q. I see. And where were you employed during
20 out into the street. My job was to attempt to            20 that break in your tenure at JPMorgan?

21 recover those funds.                                     21     A. I had two different jobs. I was a
22     Q. I see. Can you tell me what your role was         22 salesperson for Lucent Technologies and then I went


                                             www.trustpoint.one                                        800.FOR.DEPO
                                           www.aldersonreporting.com                                    (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                          2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                   Page 6Page
                                                                                                       of 23
                                                                                                           6 (18 - 21)
                                 PageID# 1938
                                              Page 18                                                             Page 20
 1 on to become a production manager for a company               1 years ago.
                                                                       That might have been the lead-in job.
 2 called TalentWorks who did television production.     2 Sorry, that was back in 1988.

 3     Q. And prior to 1998, can you describe your       3     Q. Yeah, it's a while ago. Can you tell me
 4 positions at JPMorgan?                                4 your educational background?

 5     A. Yeah. From '88 to roughly '98 -- I             5     A. Sure. I went to Hofstra University on
 6 started out in '88 as a wire investigator, okay? So   6 Long Island for approximately four semesters and left

 7 if a wire was initiated and any claim nonreceipt or   7 after the four semesters and went on to take the job

 8 they were looking to recover the funds or return the  8 at JPMorgan Chase.

 9 funds, I would get involved in that investigation.    9     Q. I see. And do you have any further
10         From there I went on to do what we called    10 degrees or certifications after leaving Hofstra
11 a CSO or customer service officer where you were a 11 University?

12 single point of contact for a portfolio of clients,  12     A. No.
13 high-profile clients in the bank. And then I left    13     Q. I want to now come back to March of 2020.
14 the bank.                                            14 And can you just please remind me the title of your

15     Q. And did your role as a customer service       15 position at that point?

16 officer also involve wire transfers?                 16     A. Yes. I was a vice president in the
17     A. That was one of many things it involved.      17 payment controls department.
18 You were pretty much the single point of contact for 18     Q. And to whom did you report in that role?
19 a portfolio of clients.                              19     A. I reported in to Jenifer Robinson.
20     Q. I see. In your role as a wire                 20     Q. And do you know who Ms. Robinson reported
21 investigator, do I understand correctly that you     21 to?

22 would have been involved in investigating outgoing 22       A. Jenifer reported in to Rakesh Korpal.
                                                       Page 19                                                    Page 21
 1 wire transfers from JPMorgan to other banks?                  1     Q. I see. And did you have a staff of --
 2    A.    That would be both incoming and outgoing              2 excuse me. Did you have a staff of others at

 3 wire transfers.                                                3 JPMorgan who reported up to you?

 4    Q.    I see. And you may have just mentioned                4    A. I did not have people in my org chart.
 5 this, but can you describe more specifically the               5    Q. So did you -- did you work with other
 6 source of investigations that you would conduct in             6 lower ranking employees at JPMorgan at the time?

 7 that role?                                                     7    A. Yes. I was engaged with the payment
 8    A.    Sure. The common investigations were                  8 controls staff on a daily basis. Me not having staff

 9 funds might go out of the bank and be sent to another          9 underneath myself was a matter of standard control,

10 bank and that ultimate beneficiary may come in and            10 so they were all listed under Jenifer Robinson. But

11 say they don't know what it is, can you please tell           11 I would interact with them on a daily basis.

12 me what this wire is.   I don't know what it is. That         12    Q. I see. So they also reported up to
13 was a primary type of investigation.                          13 Jenifer Robinson; is that correct?

14         In addition to beneficiaries claiming                 14    A. Yes, sir.
15 nonreceipt, a remitter may come in and say, hey, we           15    Q. But you had a higher ranking position in
16 sent this wire out, but that ultimate beneficiary             16 the company, is that right?

17 says he never got it.   So we would engage the other          17    A. That's correct. You can almost think of
18 financial institutions to confirm the date that the           18 them reporting in to me on a dotted-line type of

19 funds were credited to the account and so forth.              19 thing, but they were in Jenifer's org chart.

20    Q.    I see. Where -- were you employed                    20    Q. That's helpful. Thank you.
21 elsewhere prior to joining JPMorgan in 1988?                  21        Can you describe for me again the nature
22    A.    I worked for an auto interiors place many            22 of your responsibilities in that position in the


                                               www.trustpoint.one                                       800.FOR.DEPO
                                             www.aldersonreporting.com                                   (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                                   2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                            Page Page
                                                                                                              7 of 23
                                                                                                                   11 (38 - 41)
                                 PageID# 1939
                                                         Page 38                                                       Page 40
 1    A. Common themes of fraud are newly opened                    1 communicating back and forth. We would tell them the

 2 accounts receiving in large dollar amounts or a                  2 wire is fraudulent. They -- we would attempt to get

 3 velocity of payments over a very short period of                 3 them to restrict the account. Most of the times they

 4 time. That's a very common theme of fraudulent                   4 would restrict the account and the majority of the

 5 activity. A fraudulent party opening up an account,              5 time they would request JPMorgan Chase send them what

 6 getting a flow of funds in really quickly, and                   6 we call an indemnity.

 7 eventually getting caught and getting it shut down.              7    Q.     I see. And would you -- strike that.
 8 But that would be a common thing -- that would be a              8          Would the other banks in that situation
 9 common thing of newly opened account receiving in                9 sometimes ask you to explain the basis on which you

10 large dollar amounts.                                           10 had concluded that the transaction was fraudulent?

11    Q. And when you mentioned velocity, does that                11    A.     There could be times where they come in
12 refer to the number of incoming transactions that               12 and explain why do you consider this fraudulent.

13 occur over a period of time?                                    13    Q.     So you might explain to them the
14    A. Yes.                                                      14 indications of fraud that you had identified as part

15    Q. And when you were conducting these                        15 of your investigation?

16 investigations, how would you go about determining              16    A.     Yes.
17 whether an account had been newly opened or had a               17    Q.     And when you were doing that, when you
18 high velocity of payments into it?                              18 were communicating with other banks in connection

19    A. If it was on JPMorgan Chase's account --                  19 with these investigations, would you try to be clear

20 on JPMorgan Chase's books, we would see when the                20 and honest in your communications with the other

21 account was opened and the type of activity that's              21 bank?

22 going in and out of that account. If it was not on              22    A.     We would -- we would give them -- a lot of
                                                         Page 39                                                             Page 41
 1 JPMorgan Chase's books, if we were paying it out to              1 times we would not know the exact details of the

 2 Citibank, okay, we would really have to rely on them             2 fraud.   Citibank would come in to us and say this
 3 to tell us if they feel the transaction is                       3 wire was fraudulent, but they wouldn't give us any

 4 fraudulent, not fraudulent and whether they're                   4 more details.

 5 willing to restrict the account or not restrict the              5          We would go out to the beneficiary party
 6 account.                                                         6 and tell them that Citibank is claiming this to be

 7    Q. And when you were requesting that another                  7 fraudulent.      Many times we would not have any more
 8 financial institution restrict an account, would you             8 details than the remitting bank actually saying it's

 9 need to provide certain information to them in                   9 fraud.   They didn't give us the details.
10 support of that request?                                        10    Q.     What about in a situation where you were
11    A. If it was a phone -- can you repeat the                   11 seeking to have a beneficiary's bank restrict the

12 question? Sorry, because I think I was going                    12 funds.   Would you sometimes provide them information
13 somewhere else with that.                                       13 to support your belief that there had been fraud in

14    Q. Yeah. When you -- when you would be                       14 connection with the transaction?

15 requesting another financial institution to restrict            15    A.     Largely only if they asked for it. Those
16 funds that they had received in a transaction, would            16 messages would go out and say remitter advises us

17 you need to provide certain information to them to              17 this transaction to be fraud and we'd leave it at

18 support your request?                                           18 that.   If they came back to us and asked, we don't
19    A. Yeah. The majority of the time, when we                   19 always have that information.

20 engaged another financial institution to restrict an            20    Q.     You mentioned that these communications
21 account, that was done via SWIFT or what we would               21 would often occur by SWIFT message; is that correct?

22 call a Fed service message. Just a way of                       22    A.     Yes, that's correct.

                                                  www.trustpoint.one                                               800.FOR.DEPO
                                                www.aldersonreporting.com                                           (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                              2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                       Page Page
                                                                                                         8 of 23
                                                                                                              12 (42 - 45)
                                 PageID# 1940
                                                       Page 42                                                      Page 44
 1    Q.     And can you explain to me what a SWIFT               1 calls, it would be driven by many times the dollar

 2 message is?                                                    2 amount or how recent the activity happened and if

 3    A.     Sure. So SWIFT stands for Society For                3 something can be done quicker.

 4 Worldwide Interbank Financial Telecommunications.       It     4    Q.   I see. So if the transaction that you
 5 is a way for banks to initiate payments back and               5 were investigating was a more recent one, that might

 6 forth to each other in addition to communicate new             6 be a reason that you would have realtime telephone

 7 authenticated messages back and forth to each other.           7 communications with the other financial institution

 8         So many of these investigations, as you                8 rather than using service messages?

 9 are asking how they originate, are originated via              9    A.
                                                                    We would use the service message in
10 SWIFT.    You can send a SWIFT message advising the           10 addition to the phone call.
                                                                                         But the phone call
11 bank to claim nonreceipt of the funds. You can send  11 carries a lot of power based upon the transaction

12 a SWIFT message giving debit authorization to return 12 being same day or somewhat recent. It's in addition

13 the funds back to the remitter, those types of       13 to.

14 things. But SWIFT is a way for financial             14     Q. I see. I'm going to transition to the
15 institutions to talk back and forth to each other    15 subject matter of this particular case. Are you --

16 through -- through authenticated messages.           16 are you familiar with a wire transfer that California

17    Q. And is that something different than           17 caused JPMorgan to send to Chain Bridge Bank for the

18 messages communicated over the Fedwire system?       18 benefit of Blue Flame Medical on March 26 of 2020 in

19    A. Yes. That's different. The large               19 the amount of approximately $457 million?

20 financial institutions out there are members of      20     A. Yes.
21 SWIFT, okay? But the smaller mom and top type credit 21     Q. And just by way of terminology, I hope you
22 union places do not belong to SWIFT, so we would     22 can agree that if I refer to the Blue Flame wire or
                                               Page 43                                                                Page 45
 1 engage them via the Fedwire services communication             1 the Blue Flame transaction, that's the wire transfer

 2 system.                                                        2 I'm referring to.   Do you understand that?
 3    Q.     I see. Would you also have telephone                 3
                                                                A. Yes, sir.
 4 communications in connection with these                        4
                                                                Q. Can you tell me how you personally became
 5 investigations with other financial institutions?      5 aware of the Blue Flame wire transfer?

 6     A. At times, always depending on the               6     A. Yes. I was engaged by Rakesh Korpal to
 7 particular situation.                                  7 engage Chain Bridge Bank to restrict -- to hold on to

 8     Q. Do you have a sense of how often, just on       8 those funds, to restrict those funds as there was

 9 a rough basis, the investigation would involve         9 concerns about the validity of the transaction.

10 telephone communications with the other banks?        10     Q. And had you learned about the Blue Flame
11     A. Obviously it would be done on a daily          11 wire transfer before Mr. Korpal had engaged you to
12 basis depending on the situation. The best way I can  12 reach out to Chain Bridge Bank?

13 describe to you, suspicious activity is driven by a   13     A. No, that's my first recollection of having
14 timeline, okay? And if suspicious activity happened   14 any understanding of that wire.

15 today, there's a lot more I can do on a phone call    15     Q. Do you recall any discussions with anybody
16 than if a suspicious activity happened last month.    16 at JPMorgan before March 26th about the possibility

17 That phone call is not going to do a lot of good      17 of a large wire transfer being initiated by

18 because that suspicious activity happened 30 days ago 18 California?

19 and it's going to limit the ability to recover the    19     A. That was the first time I was engaged with
20 funds. Because 30 days in like a -- in a fraud        20 any thoughts of suspicion.

21 environment is a lifetime.                            21     Q. I see. I think my question was slightly
22         So if I think you're asking about phone       22 different, though. I meant to ask just about the
                                               www.trustpoint.one                                          800.FOR.DEPO
                                             www.aldersonreporting.com                                      (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                              2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                       Page Page
                                                                                                         9 of 23
                                                                                                              13 (46 - 49)
                                 PageID# 1941
                                                  Page 46                                                            Page 48
 1 possibility of a large wire transfer coming from the           1 that they've confirmed the instructions with a valid

 2 state of California.                                           2 source, okay?

 3         Do you have any recollection of any            3         So my job is to make sure that they've
 4 conversations about a large wire transfer that was     4 done their job and that's the approval, not to redo

 5 going to be sent by the state of California prior to   5 the investigations so much, but to really make sure

 6 March 26th?                                            6 that they've done the necessary steps to release the

 7     A. No.                                             7 transaction.

 8     Q. Did you have any role in approving the          8     Q. And did you complete that review process
 9 Blue Flame wire transfer before it was released by     9 in connection with the Blue Flame wire transfer?

10 JPMorgan?                                             10     A. I did.
11     A. I did.                                         11     Q. And then did you communicate that you had
12     Q. And can you describe your role in that         12 approved the release of the Blue Flame wire transfer?
13 process of approving the release of the Blue Flame    13     A. I approved the release of the Blue Flame
14 wire transfer?                                        14 wire transfer through their payment control

15     A. Sure. Any payment that's over $50 million 15 department, yes.
16 that stops in the payment control process needs to    16     Q. And do you recall the basis on which you
17 have an email approval sent to myself, Jenifer        17 made that decision to approve the release of the Blue

18 Robinson or Rakesh Korpal to approve that they've     18 Flame wire transfer through the payments control

19 taken the necessary actions to validate the wire with 19 office?

20 the remitter.                                         20     A. Generally, what we would look for is what
21     Q. And did you receive such an email message      21 operator reached out to what client and spoke to what
22 in connection with the Blue Flame wire transfer?      22 person to validate the transaction. We're making
                                                       Page 47                                                       Page 49
 1    A.   I did.                                                 1 sure they've done their due diligence and calling,

 2    Q.   Do you recall the content of that message              2 reaching out to the client to validate the

 3 seeking approval of the wire transfer?                         3 transaction.   So we're just really approving that
 4    A.   I don't know the exact details, but it                 4 they've taken the necessary steps.

 5 would mention dollar amount, clients involved and who          5    Q.   And sitting here today, do you have a
 6 they spoke to to validate the transaction.                     6 recollection of having completed that review process

 7    Q.   Do you have a recollection of when you                 7 in connection with this wire transfer or are you

 8 received that email message in connection with the             8 testifying about what you generally would have done

 9 approval of the Blue Flame wire transfer?                      9 in that situation?

10    A.   Sorry, could you repeat that?                         10    A.   I'm testifying what we -- how we generally
11    Q.   Do you have a recollection of when you                11 go about these approvals.

12 received that email message in connection with the            12    Q.   So you don't specifically recall the
13 approval of the Blue Flame wire transfer?                     13 thought process you had in providing approval for the

14    A.   I believe it was roughly around noon or               14 Blue Flame wire transfer?

15 12:30 or somewhere in that nature if I remember.              15     A. No.
16    Q.   And can you tell me what, if anything, you            16     Q. Do you have an understanding about what
17 did in response to the message you'd received                 17 occurred with respect to the Blue Flame wire transfer

18 regarding the approval of the wire transfer?                  18 after you had given that approval step?

19    A.   Yeah. My job in that -- in that chain,                19     A. From there, as we spoke about the life
20 that email approval, is to make sure that the payment         20 cycle of a transaction, that would get released out

21 control operator has done their job, their necessary          21 of the payment control department and moved on to

22 due diligence by engaging the client and making sure          22 funds control to eventually be released out to the


                                                  www.trustpoint.one                                        800.FOR.DEPO
                                                www.aldersonreporting.com                                    (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                            2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                    Page 10 of 16
                                                                                                      Page  23(58 - 61)
                                 PageID# 1942
                                                  Page 58                                                           Page 60
 1        THE WITNESS: I just got it.                        1 March?

 2 BY MR. BURKE:                                             2    A.     Yes.
 3    Q. Mr. Coffey, are you able to access                  3    Q.     So as you've testified previously, this
 4 Defendant's Exhibit 91?                                   4 was -- your approval was communicated pretty quickly

 5    A. Yes.                                                5 after the request for approval arrived; is that

 6    Q. And do you recognize this email message?            6 right?

 7    A. I do.                                               7    A.     Correct.
 8    Q. Can you tell me what it is?                         8    Q.     And do you recall speaking with anybody at
 9    A. This is my approval of the below                    9 JPMorgan about this wire transfer before you

10 transaction to be moved through the payment control      10 communicated your approval in this email message?

11 process based --                                         11    A.     No.
12    Q. And that's -- sorry. Go ahead.                     12    Q.     Thank you. I think you can close out of
13    A. Based upon the due diligence that was done         13 that exhibit at least for now.

14 by the payment control operator, which I reviewed        14          I think earlier today you testified that
15 below.                                                   15 after the wire transfer was released from JPMorgan,

16    Q. And the transaction at issue in these              16 Mr. Korpal initiated an investigation of the

17 email exchanges, that's the Blue Flame Medical wire      17 transaction; is that right?

18 transfer that we have been discussing; is that right?    18    A.     He had inquired me to send him a copy of
19    A. Yes.                                               19 the transaction.

20    Q. And can you tell me what the -- what               20    Q.     And how did he ask you to do that?
21 information in these emails you would have looked at     21    A.     I believe it was via what we call a
22 to determine that the due diligence had been             22 communicated message, which is a Skype message type
                                                  Page 59                                                           Page 61
 1 completed to your satisfaction?                           1 of thing, internal.

 2    A. Yes. I'm going to make note of the dollar           2    Q.     I see. And did he explain to you why he
 3 amount, the client name, the beneficiary name. But        3 was requesting the details of the transaction?

 4 largely, we're looking to see that section below that     4    A. He did not.
 5 says, "Natalie Gonzales confirmed payment is valid.       5    Q. Did you have any other basis for
 6 Call-back performed on a known telephone number."         6 understanding of why he was requesting the details of

 7         That's -- on the -- my approval is to             7 the transaction?

 8 assure that they've done their due diligence and          8    A. Not at that time.
 9 engaged the client properly.                              9    Q. What was the next communication you had in
10    Q. And can you describe what a call-back is?          10 connection with the Blue Flame wire transfer?

11    A. The client is going to reach out -- sorry.         11    A. Rakesh engaged me to call Chain Bridge
12 The payment control operator is going to reach out to    12 Bank to have the funds held at Chain Bridge Bank as

13 the client to try to find out how they received the      13 there was concerns about the validity of this

14 instructions. Did they do a call-back to a known         14 transaction.

15 number to make sure that this isn't some sort of         15    Q. And how did he engage you with that task?
16 fraudulent instructions and so forth.                    16    A. I believe he called me.
17         Again, it's not something that I                 17    Q. And do you recall what he told you about
18 specialize in as a payment control operator. I'm         18 the transaction?

19 making sure that they've done the due diligence of       19    A. He was asking me to engage Chain Bridge to
20 reaching out to the client.                              20 hold on to the funds as there was concerns about the

21    Q. I see. And do you see that this email was          21 transaction. That was the limit of the details.

22 sent at -- sent by you at 11:33 a.m. on the 26th of      22    Q. He told you that there were concerns about
                                            www.trustpoint.one                                             800.FOR.DEPO
                                          www.aldersonreporting.com                                         (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                           2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                   Page 11 of 17
                                                                                                     Page  23(62 - 65)
                                 PageID# 1943
                                                  Page 62                                                      Page 64
 1 the transaction?                                          1 was that you spoke with who picked up the phone at

 2    A. Yes.                                                2 Chain Bridge Bank that there were concerns of fraud

 3    Q. Do you recall whether he told you what the          3 with respect to the transaction?

 4 nature of those concerns was?                             4    A.   Do I recall saying that; is that the
 5    A. At that time he did not.                            5 question?

 6    Q. Did you have any understanding of what the          6    Q.   Yes.
 7 nature of the concerns with respect to the Blue Flame     7    A.   Yes.
 8 transaction were at that time?                            8    Q.   And then was your call transferred to
 9    A. I did not.                                          9 somebody else at Chain Bridge Bank?

10    Q. And did you talk with anybody else at              10    A.   Very quickly, I was transferred to -- I
11 JPMorgan about the Blue Flame wire transfer before       11 believe the name was David Everton.      My understanding
12 contacting Chain Bridge Bank as Mr. Korpal had           12 was he was the president of the bank.    But very
13 requested?                                               13 quickly I was transferred to him.

14    A. I do not recall engaging anybody else.             14    Q.   I see. And would the name David Evinger
15    Q. Did you know -- strike that.                       15 refresh your recollection at all?

16        Did you have an understanding of whether          16    A.   Yes.
17 Mr. Korpal had also contacted other personnel at         17    Q.   Does that sound right?
18 JPMorgan in connection with this transaction?            18    A.   Yes. Sorry.
19    A. I would not know what actions he would             19    Q.   What did you discuss with -- excuse me.
20 have taken.                                              20 What did you discuss with Mr. Evinger on that phone

21    Q. He didn't tell you if he had reached out           21 call?

22 to others at JPMorgan about the transaction?             22    A.   When I got to David Evinger, he was
                                                  Page 63                                                          Page 65
 1    A.   No.                                               1 already well aware of this wire transfer.
                                                                                                       I had
 2    Q. And so what did you do in response to            2 advised him that I was calling from JPMorgan Chase,

 3 Mr. Korpal's request, if anything?                     3 there was some suspicion about the wire and, if I

 4    A. I -- excuse me. I engaged Chain Bridge           4 recall, he very quickly said, oh, we -- we're holding

 5 Bank via phone and had asked to speak to somebody who 5 this wire right now. We have similar suspicions,

 6 could assist me with that wire transfer.               6 too. So he had already been engaged in holding on to

 7    Q. And do you recall who you called at Chain        7 the funds at that time.

 8 Bridge Bank, or did you just call the main number for  8    Q. Did you -- you shared with him that
 9 the bank?                                              9 JPMorgan viewed the transaction as suspicious?

10    A. I called the main number that I obtained        10    A. Yes, I'm sure I did.
11 off the Internet and spoke to whoever would -- manned 11    Q. Did you discuss with him any of the
12 that main number.                                     12 reasons that led JPMorgan to be suspicious regarding

13    Q. I see. And do you recall what you told to       13 this wire transfer?

14 whoever it was that picked up the phone?              14    A. I did not.
15    A. Not exactly. The intent was to get me           15    Q. Do you recall what else you learned from
16 somebody that could assist me with the suspicious     16 Mr. Evinger on the call?

17 wire.                                                 17    A. What I recall was him clearly stating that
18    Q. So at the time, you viewed the Blue Flame       18 they had suspicion about the wire, they're holding
19 wire transfer as a suspicious wire?                   19 the wire. And that was really the intent of my phone

20    A. At the time, I was told, yes, by Rakesh         20 call is to get them to hold the funds.

21 that the -- that the wire was suspicious.             21    Q. So your goal in calling Chain Bridge Bank
22    Q. Do you recall whether you told whoever it       22 was to get them to hold the funds?
                                            www.trustpoint.one                                           800.FOR.DEPO
                                          www.aldersonreporting.com                                       (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                                  2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                          Page 12 of 18
                                                                                                            Page  23(66 - 69)
                                 PageID# 1944
                                                        Page 66                                                            Page 68
 1     A. Yes.                                                     1 the intent of my phone call, and I needed to report

 2     Q. Did you -- did you ask Mr. Evinger to hold               2 that to Rakesh to let him know that I've -- that

 3 the funds?                                                      3 they're holding the funds, too.

 4     A. I'm sure I asked him to -- if they could                 4    Q.    I see. And did -- did the fact that Chain
 5 either restrict or hold the funds. And at that point            5 Bridge Bank had expressed concerns regarding the

 6 I remember -- I recall him saying to me, we've                  6 transaction heighten any concerns you had with

 7 already held the funds. We had the same suspicions.             7 respect to the transaction?

 8     Q. Did you -- did you discuss with him                      8    A.    At that time, I didn't have the
 9 whether JPMorgan was conducting an investigation                9 information to have any heightened concerns.       I was
10 regarding the Blue Flame transaction?                          10 merely carrying out the request of Rakesh to get the

11     A. No. The intent of that first original                   11 funds held.

12 phone call was to get them to hold the funds.                  12    Q.    I see. And did you then discuss that
13     Q. Did you discuss with him whether JPMorgan               13 conversation with Mr. Evinger with anybody else at

14 would be reaching out to Chain Bridge Bank again               14 JPMorgan?

15 later in the day?                                              15    A.    I discussed it with Rakesh.
16     A. Yes.                                                    16    Q.    Do you recall how that discussion took
17     Q. Do you recall what you told Mr. Evinger                 17 place?

18 about that?                                                    18    A.    I believe it was via a communicated
19     A. I don't recall the exact words.                         19 message or Skype message advising him that I spoke to

20     Q. Do you recall more generally what you                   20 such and such, David Evinger, and he confirms they

21 communicated to Mr. Evinger?                                   21 are withholding the funds, with similar suspicions.

22     A. The intent of the phone call was get the                22    Q.    And do you recall whether Mr. Evinger told
                                                        Page 67                                                            Page 69
 1 funds to be held at Chain Bridge Bank, which he                 1 you whether the funds had been credited to the

 2 advised they already were doing that, they had                  2 beneficiary in the transaction?

 3 similar suspicions and more or less told him, okay, I           3    A.    I believe he had said to us, we are
 4 appreciate that, we'll get back to you.   I didn't              4 holding the funds, which would be terminology that

 5 have details of the fraud at the particular time or             5 would mean it never hit the beneficiary's account.

 6 the suspicion or whatever as it was not privy to me             6 They're holding it.

 7 at that particular moment.                                      7    Q.    I see.
 8    Q.   I see. And did you -- did you learn from                8         MR. BURKE: Zach, could you share what was
 9 Mr. Evinger anything about the nature of the                    9 Plaintiff's Exhibit 98?

10 underlying transaction between California and Blue             10 BY MR. BURKE:

11 Flame Medical?                                                 11    Q. For the record, it is a document with the
12     A. No, not that I recall.                                  12 Bates label JPMC-00000243.

13     Q. Do you recall learning whether Chain                    13    A. Is that PX-98, guys?
14 Bridge Bank had been in contact with anybody at the            14    Q. Yes.
15 state of California at that time?                              15    A. Okay. I just opened it in front of me.
16     A. I don't believe it was that phone call,                 16    Q. Do you have that available to you,
17 but on one of the phone calls, they had advised us             17 Mr. Coffey?

18 they engaged our client.                                       18    A. I do.
19     Q. Do you recall your reactions to what you                19         MR. SCHOENFELD: Sorry. We do not. Give
20 learned from Mr. Evinger on the call?                          20 us just one second. Okay. We got it. Go ahead.

21     A. I was -- I was appreciative of the fact                 21 Sorry.

22 that they were already holding the funds as that was           22         MR. BURKE: Great.
                                                www.trustpoint.one                                              800.FOR.DEPO
                                              www.aldersonreporting.com                                          (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                            2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                    Page 13 of 19
                                                                                                      Page  23(70 - 73)
                                 PageID# 1945
                                                        Page 70                                                    Page 72
 1 BY MR. BURKE:                                                   1 wire transaction?

 2    Q. So Mr. Coffey, do you recognize this                      2     A. Yes.
 3 communication?                                                  3     Q. And so do you see you respond to his
 4    A. Yes.                                                      4 message by saying, "Yes. Sent"?

 5    Q. Can you describe for me what it is?                       5     A. Yes.
 6    A. This is a conversation via the internal                   6     Q. So would that be around the time that you
 7 Chase chat application.                                         7 shared the details of the wire transaction with

 8    Q. And do you see at the top that there's                    8 Mr. Korpal?

 9 what looks like some email header information saying            9     A. Yes.
10 that the document -- or the email was sent on March            10     Q. And is it your recollection that you sent
11 27th at 1:49 p.m.?                                             11 those details to him by email?

12    A. Yes.                                                     12     A. Yes, that's correct.
13    Q. So do you understand this to be chat                     13     Q. So looking down from there, there's two
14 information that was pasted into an email and then             14 lines, one marked 12:28 p.m. connected to Korpal

15 sent to you by Mr. Korpal?                                     15 Rakesh and then a phone number, and in the next line,

16    A. I'm not sure how this was obtained. This                 16 it says "12:29 p.m. call with Korpal Rakesh," phone

17 conversation was never sent to me, so I would say              17 number, "has ended."

18 this does not appear to be an email sent from Rakesh           18         Do you understand what those lines in this
19 to me. I'm not sure how this was -- it was pulled.             19 document represent?

20    Q. Do you see in the header information that                20     A. Yes.
21 you're listed on the "To" line? It says Timothy                21     Q. Can you tell me what they represent?
22 Coffey?                                                        22     A. The duration of a phone call from Rakesh
                                                        Page 71                                                    Page 73
 1    A.   I do.                                                   1 to myself.

 2    Q.   But you don't recall receiving this email               2    Q.   So does the Skype application that you
 3 from Mr. Korpal?                                                3 were using keep a record of phone conversations as

 4    A.   No, I don't think I -- I don't think this               4 well as these instant message type communications?

 5 is an email actually.                                           5    A.   I assume that to be correct by looking at
 6    Q.   Okay. Do you recognize the content of the               6 this.

 7 message as a set of Skype communications between                7    Q.   And that phone call that is represented by
 8 yourself and Mr. Korpal?                                        8 those entries, do you believe that would have been

 9    A.   Yes.                                                    9 around the time that Mr. Korpal requested that you

10    Q.   And just from looking through those                    10 reach out to Chain Bridge Bank?

11 communications, do they look like Skype                        11    A. Yes.
12 communications in connection with the Blue Flame wire          12    Q. Do you think that was the phone
13 transfer on March 26th?                                        13 conversation where he related that request to you?

14    A.   Yes.                                                   14    A. Yes.
15    Q.   And do you see right at the very top, that             15    Q. And then you -- looking down from there,
16 communication from Mr. Korpal, it says, "Can you give          16 there's a message from you at 12:36 p.m.

17 me a copy of this transaction?   Value today," and the         17         Do you see that one?
18 "456 million Blue Flame Medical"?                              18    A. Yes.
19    A.   Yes.                                                   19    Q. And you write, "I got the president of the
20    Q.   So do you recognize that as the                        20 bank... David Evinger," phone number. "They are

21 communication we had discussed earlier where                   21 holding the funds with similar concerns."

22 Mr. Korpal asked you to send him the details of this           22         Do you see those lines?
                                                  www.trustpoint.one                                     800.FOR.DEPO
                                                www.aldersonreporting.com                                 (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                                     2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                             Page 14 31
                                                                                                             Page of 23
                                                                                                                     (118 - 121)
                                 PageID# 1946
                                                        Page 118                                                           Page 120
 1 from the bank?                                                   1 of the investigation?

 2         MR. SCHOENFELD: Objection. Just to                       2         MR. SCHOENFELD: Objection.
 3 clarify, is this specifically with respect to                    3         THE WITNESS: Yes, it would be common for
 4 transactions other than this transaction.                        4 us to request a recall of funds, yes.

 5 BY MR. BURKE:                                                    5 BY MR. BURKE:

 6    Q. I mean as a general matter when,                           6     Q. And is that what occurred in the three or
 7 Mr. Coffey, you were involved in investigating wire              7 four other personal protective equipment related

 8 transfers from JPMorgan, was part of your role to                8 transactions that you referred to earlier in your

 9 help determine whether JPMorgan would decide to                  9 testimony?

10 request a recall of the wire transfer?                          10     A. Did that occur? Was that the question?
11    A. Yes. Oftentimes that would be the case.                   11     Q. Yes. Did JPMorgan make a request for the
12 Sometimes, as I mentioned earlier in my testimony,              12 financial institution on the other side of the

13 fraud has already been determined, but oftentimes we            13 transaction to return the funds?

14 would be involved in the decision-making.                       14     A. Once fraud was confirmed by the JPMorgan
15    Q. And with respect to this particular                       15 client, yes, we did.

16 transaction, the Blue Flame wire transfer, did you              16     Q. Mr. Coffey, if you could -- if you have
17 understand that the investigation you were involved             17 available to you a document we looked at earlier

18 in was at least in part meant to help determine                 18 today. It was Plaintiff's Exhibit 98, PX-98. It was

19 whether JPMorgan should request a recall of the wire            19 the chat record.

20 transfer that had been sent to Chain Bridge Bank?               20     A. I see it -- I see it here.
21         MR. SCHOENFELD: Objection. You can go                   21     Q. I wanted to refer you to the line about
22 ahead and answer.                                               22 maybe two-thirds of the way down the page at 12:43
                                                        Page 119                                                      Page 121
 1         THE WITNESS: The stepping away and doing                 1 p.m. that says, "Connected to Korpal Rakesh," and

 2 factfinding was to gather information on both sides              2 then a phone number.

 3 so that Chain Bridge could make a choice on what they            3          Do you see that line?
 4 wanted to do.                                                    4    A.     12:43, is that the one?
 5         I think it's important to note here that                 5    Q.     12:43 p.m.
 6 at this point of the transaction, Chain Bridge Bank              6    A.     Yes, I see it.
 7 was in possession of the funds.    So they really were           7    Q.     And then there is another intermediate
 8 the ultimate party who was going to make the decision            8 message that appears to be an instant message written

 9 on whether to return them or not.    We could only give          9 by you to Mr. Korpal.      Do you see that one that's at
10 them information to assist them.                                10 12:51?

11 BY MR. BURKE:                                                   11    A.     Yes, I see it. Sorry.
12    Q.    You could give them information to assist              12    Q.     And then right after that, there's the
13 them, but couldn't you also make a request to them to           13 entry at 12:53 p.m. that says a call with Mr. Korpal

14 return the funds?                                               14 has ended.    Do you see that one?
15    A.    We could -- in theory, we could make a                 15    A.     Yes.
16 request to return the funds.   They don't have to               16    Q.     And it says a duration of nine minutes and
17 honor that.                                                     17 57 seconds?

18    Q.    Again, stepping back from this particular              18    A.     Yes.
19 transaction and thinking more broadly about your role           19    Q.     Do you know whether that phone call that's
20 in investigating wire transactions, would it be                 20 recorded on this document is the phone conversation

21 common for JPMorgan to request a return of funds from           21 we listened to a little bit ago where it was you and

22 the other financial institution after the completion            22 Mr. Korpal and then Mr. Brough and Mr. Evinger from


                                                  www.trustpoint.one                                              800.FOR.DEPO
                                                www.aldersonreporting.com                                          (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                                    2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                            Page 15 32
                                                                                                            Page of 23
                                                                                                                    (122 - 125)
                                 PageID# 1947
                                                        Page 122                                                             Page 124
 1 Chain Bridge Bank?                                               1    A.      I do not recall. As I said before, Rakesh
 2    A. I believe that would be the phone call.                    2 was driving this -- this inquiry.

 3 The duration sounds about the amount of time we                  3    Q.      Do you recall Mr. Korpal contacting you
 4 spoke.                                                           4 with any further information about the status of the

 5    Q. And so does this help to refresh your                      5 investigation?

 6 recollection at all about whether that phone call                6    A.      I do not. I believe at some point there
 7 occurred with you in the office with Mr. Korpal or               7 was a conversation about Blue Flame and we had -- the

 8 whether you had joined him on the phone for the call?            8 agreement was they would send a recall.        That's the
 9    A. I'm sure I was in his office listening on                  9 last kind of interaction I remember with Rakesh on

10 speakerphone.                                                   10 this.

11    Q. I see. Do you have any recollection of                    11    Q.      I'm sorry, I want to make sure I
12 why -- or of what this phone call of approximately 10           12 understand your answer.       So that you recall that at
13 minutes with Mr. Korpal entailed?                               13 some point later you had another conversation with

14    A. Is -- is this referencing the second phone                14 Mr. Korpal and there was an agreement to send the

15 call between Rakesh and David Evinger?                          15 recall?

16    Q. Well, what I'm trying to figure out is                    16    A.      Yes, that's correct.
17 whether you had connected on the phone with                     17    Q.      And was that an agreement between you and
18 Mr. Korpal and then conferenced in the people from              18 Mr. Korpal or were you referring to some other

19 Chain Bridge Bank or whether you were sitting in                19 agreement?

20 Mr. Korpal's office and had the call on speakerphone.           20           MR. SCHOENFELD: Objection.
21    A. What I -- what I believe is -- what I                     21           THE WITNESS: It was an agreement between
22 recall is I had David Evinger's number and brought it           22 myself -- it was a -- it was a directive from Rakesh
                                                        Page 123                                                      Page 125
 1 into Rakesh's office to -- for him to initiate the               1 to me to engage Chain Bridge Bank to recall the funds

 2 phone call.                                                      2 based upon whatever interaction he had had with

 3    Q.   I see. And then do you see another entry                 3 people internally and with David Evinger, and I was

 4 at 12:53 p.m. that says connected to Mr. Korpal.     And         4 not privy to those conversations.

 5 then right after that, there's an entry at 12:54                 5 BY MR. BURKE:

 6 reflecting a call with Mr. Korpal ending with a                  6    Q.      So I want to -- I want to make sure I
 7 duration of one minute and two seconds?                          7 understand, to the best of your recollection, exactly

 8    A.   Yes, I see that.                                         8 what it is Mr. Korpal told you versus what you may

 9    Q.   And does that refresh your recollection at               9 have understood from the context or otherwise.

10 all about whether you had a short phone call of about           10           So at some point Mr. Korpal contacted you
11 a minute duration with Mr. Korpal after you had                 11 and directed you to recall the funds from Chain

12 spoken with personnel from Chain Bridge Bank?                   12 Bridge Bank; is that right?

13    A.   Yes, clearly -- clearly we did.                         13    A.      Yes.
14    Q.   Do you have any recollection of what you                14    Q.      And at that point, did he explain to you
15 discussed with Mr. Korpal on that phone call of                 15 why JPMorgan would be recalling the funds from Chain

16 approximately -- or a minute and two seconds?                   16 Bridge Bank?

17    A.   I do not. I'm sure it involved just him                 17    A.      No.
18 reiterating that he has concerns.                               18    Q.      So the only information you had was a
19    Q.   After that discussion that we just covered              19 direction to go ahead and recall the funds; is that

20 with Mr. Korpal, do you know the next time that you             20 right?

21 communicated with anyone else at JPMorgan about the             21    A.      Yes.
22 Blue Flame wire transaction?                                    22    Q.      And then outside of what Mr. Korpal told

                                                  www.trustpoint.one                                                800.FOR.DEPO
                                                www.aldersonreporting.com                                            (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                                    2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                            Page 16 33
                                                                                                            Page of 23
                                                                                                                    (126 - 129)
                                 PageID# 1948
                                                         Page 126                                                       Page 128
 1 you in that conversation, did you have an                         1 they needed some sort of recall message or if they

 2 understanding of why JPMorgan was issuing the recall              2 were just going to return the funds to Chase.

 3 to Chain Bridge Bank?                                             3    Q.   And do you recall what the Chain Bridge
 4    A.    I would assume whatever factfinding he did               4 personnel said to you in response?

 5 individually and in conjunction with David Evinger                5    A.   Yeah, I believe he asked us to send them
 6 drove that decision.                                              6 the standard Fed service recall message.

 7    Q.    But that's your -- that's your assumption                7    Q.   You just referred to it as a standard Fed
 8 based on -- strike that.                                          8 service recall message.   Did you use the word
 9         Is that assumption based on standard                      9 "standard" because you had seen that happen in other

10 procedure in these sorts of investigations or is it              10 transactions that you had investigated that resulted

11 based on some other source?                                      11 in the return of funds?

12    A.    I was not privy to any of the                           12    A.   That -- the need for that type of message
13 conversations that drove the decision for the funds              13 is -- can be -- is very common.

14 to be returned.   I was just directed to engage Chain            14    Q.   It's common for a bank to want to have a
15 Bridge Bank and agree we need to return the funds,               15 written official record of a request for the return

16 both sides being concerned.                                      16 of funds?

17    Q.    At that point when Mr. Korpal directed you              17    A.   Correct.
18 to recall the funds from Chain Bridge Bank, did you              18         MR. SCHOENFELD: I apologize. Donald, can
19 understand whether JPMorgan had been in contact with             19 you hold on one second?    My objection to the question
20 California officials about the transaction?                      20 about you just referred to it as a standard Fed

21    A.    I did not know as I was not part of that                21 service recall message wasn't noted on the record.     I
22 conversation.                                                    22 just wanted to make sure that's there.
                                                         Page 127                                                            Page 129
 1     Q. And so as we discussed earlier, you were                   1        MR. BURKE: I didn't -- actually didn't
 2 aware at some point that Mr. Korpal had initiated                 2 hear anything, which is probably why it didn't end up

 3 those contacts with the state of California, but as               3 on the record, but you're --

 4 to the timing of those discussions, you don't know?               4        MR. SCHOENFELD: Sorry about that.
 5     A. Correct.                                                   5        MR. BURKE: -- you're representing -- just
 6     Q. Do you recall any other discussions with                   6 to be clear, what was the objection in response to?

 7 other JPMorgan personnel before that point in time                7        MR. SCHOENFELD: The objection was in
 8 when Mr. Korpal contacted you to direct you to recall             8 response to the question, "You just referred to it as

 9 the funds from Chain Bridge Bank, but subsequent to               9 a standard Fed recall message." So I objected after

10 that second phone conversation we discussed earlier?             10 that question. I apologize for interrupting. So you

11     A. I do not recall any additional                            11 can go back to your question.

12 conversations.                                                   12        MR. BURKE: Yeah, no problem.
13     Q. And what did you do, if anything, in                      13 BY MR. BURKE:

14 response to Mr. Korpal's direction that you recall               14     Q. Did you at this point express any
15 the funds from Chain Bridge Bank?                                15 appreciation to the Chain Bridge personnel you spoke

16     A. I engaged Chain Bridge Bank to advise them                16 with for their willingness to return the funds?

17 that we have the same concerns that they have about              17     A. I'm sure I did.
18 this particular transaction, and Rakesh's suggestion             18     Q. And did you thank them for cooperating
19 is potentially we should return the funds back based             19 with JPMorgan on this -- on this transaction?

20 upon Chain Bridge holding onto the funds and being               20     A. I believe I did.
21 suspicious and we had some concerns, too.                        21     Q. And do you recall whether you asked the
22         At that point, I believe I asked him if                  22 Chain Bridge personnel you spoke with to return the


                                                   www.trustpoint.one                                            800.FOR.DEPO
                                                 www.aldersonreporting.com                                        (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                             2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                     Page 17 34
                                                                                                     Page of 23
                                                                                                             (130 - 133)
                                 PageID# 1949
                                                       Page 130                                                      Page 132
 1 funds as quickly as possible?                                  1 introduced as Plaintiff's Exhibit Number 69, which is

 2     A. I don't know that I put any sort of             2 an audio recording with the Bates label CBB-00002545.

 3 emphasis on that, but I may have said -- I may have    3 And I think we can just go ahead and just play the

 4 said that, possibly. Don't know. It would -- it        4 whole clip.

 5 would make sense that I might have.                    5        (Audio recording was played.)
 6     Q. And why would it make sense to you that         6 BY MR. BURKE:

 7 you might have said -- or might have asked for them 7       Q. Mr. Coffey, did you recognize the audio
 8 to return the funds as quickly as possible?            8 recording we just played?

 9     A. This transaction investigation, due to the      9    A. I did.
10 suspicion, had been lingering for a couple of hours   10    Q. And is that an audio recording of the
11 now. I don't have the exact times, obviously, but it  11 phone conversation we were just discussing where you

12 had been lingering. And the need to get word out to 12 called Chain Bridge Bank to -- at Mr. Korpal's

13 senior management that the situation has been taken 13 direction to recall the funds from Chain Bridge Bank?

14 control of is obviously important.                    14    A. Yes, it was.
15         This was getting some senior attention and    15    Q. And so you recognize your own voice on
16 people wanted to know what the resolution decision 16 that call, right?

17 was, and that was the emphasis to -- if there was an 17     A. Yes.
18 emphasis to send it back, that was the emphasis is to 18    Q. Do you recall whether there was any
19 put the situation to rest.                            19 discussion on that phone call before the portion that

20     Q. And did -- strike that.                        20 appears in the recording we just played?

21         Stepping back from this transaction and       21    A. I believe that was the full recording, I
22 thinking about your role in connection with other     22 believe.
                                                       Page 131                                                     Page 133
 1 investigations of wire transfers, when those                   1
                                                               Q. Did you hear the portion of the audio
 2 investigations have resulted in a request for the      2 recording where you say, "We're going to be recalling

 3 return of funds, would you say that frequently the     3 those funds, okay?"

 4 request is made over the Fedwire system?               4    A. Yes.
 5         MR. SCHOENFELD: Objection.                     5    Q. And did you mean that as a request to
 6         THE WITNESS: It's driven by who the            6 Chain Bridge Bank that they return the funds that had

 7 recipient bank is largely. If the recipient bank is    7 been wired earlier in the day?

 8 a SWIFT member, they would probably receive the SWIFT  8         MR. SCHOENFELD: Objection.
 9 message.                                               9         THE WITNESS: Yes, based upon whatever
10         As I mentioned before, some of the smaller    10 factfinding was done between my boss, Rakesh, and

11 mom and pop banks, federal credit unions and so       11 David, I was directed to tell them to return it.

12 forth, they're not part of SWIFT, so they would get a 12 BY MR. BURKE:

13 message via the Fed system -- Fed service wire        13    Q. And did you hear the portion of the
14 system.                                               14 recording where you said, "We have enough concerns

15 BY MR. BURKE:                                         15 that we feel like we need to claw those funds back"?

16    Q. So is it common that there would be some        16    A. Yes, I heard that.
17 form of a written message to communicate the recall   17    Q. And was that an accurate statement?
18 request either by the SWIFT system or by the Fedwire  18    A. That statement was based upon Rakesh's
19 system depending on the recipient?                    19 directive to please go ahead and recall the funds.

20    A. Yes.                                            20    Q. At the time, did you believe that JPMorgan
21         MR. BURKE: Zach, can you -- can you go        21 had enough concerns that JPMorgan felt the need to
22 ahead and play for us what had already been           22 recall the funds -- excuse me, to claw back the


                                                    www.trustpoint.one                                     800.FOR.DEPO
                                                  www.aldersonreporting.com                                 (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                          2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                  Page 18 35
                                                                                                  Page of 23
                                                                                                          (134 - 137)
                                 PageID# 1950
                                                   Page 134                                                        Page 136
 1 funds?                                                      1 BY MR. BURKE:

 2    A.   That --                                             2    Q.   And sitting here today, do you believe
 3        MR. SCHOENFELD: Objection.                           3 that the statement you made to the Chain Bridge Bank

 4        THE WITNESS: The decision-making at that             4 personnel that was recorded on that -- recorded

 5 point was being driven by Rakesh. So my level of            5 during that phone call was a truthful statement?

 6 concerns or nonconcern was not factored into the            6    A.   Can you repeat that, the exact same
 7 equation as Rakesh was in charge of working with            7 question?

 8 Chain Bridge to decision the funds.                         8    Q.   Sitting here today, do you believe that
 9 BY MR. BURKE:                                               9 the statement you made to Chain Bridge personnel that

10     Q. When you referred to concerns, what is it           10 JPMorgan needed to claw those funds back, was that a

11 you were referring to at the time?                         11 truthful statement?

12     A. Any sort of suspicion that hasn't been              12         MR. GUSSMAN: Objection.
13 cleared or any red flags that are engaged in the           13         THE WITNESS: It was truthful based upon
14 transaction.                                               14 the fact that that was the direction I was getting by

15     Q. And did you believe that JPMorgan needed            15 my boss. I might be missing what you're really

16 to claw the funds back?                                    16 asking.

17        MR. SCHOENFELD: Objection.                          17 BY MR. BURKE:

18        THE WITNESS: I was not involved in the              18     Q. You wouldn't make an untruthful statement
19 phone calls between Rakesh and the state of                19 in this context where you're communicating with

20 California and I don't know if he had separate phone       20 another financial institution in cooperation to

21 calls with Rakesh and David directly. I was not            21 investigate a transaction, would you?

22 involved in those phone calls, so my opinion -- my         22         MR. SCHOENFELD: Objection. Asked and
                                                   Page 135                                                        Page 137
 1 opinion didn't matter at that point.                        1 answered.

 2 BY MR. BURKE:                                               2         THE WITNESS: No, I would not.
 3    Q.    Well, I understand that perspective, but           3 BY MR. BURKE:

 4 I'm asking about what you believed at the time you          4    Q.   Did you hear the portion of the audio
 5 made that statement.   Did you believe that JPMorgan        5 recording where you thanked the Chain Bridge

 6 needed to recall the funds?                                 6 personnel for their cooperation in this and said that

 7     A. I'm trying not to repeat the same answer,            7 you guys did a great job?

 8 but the directive from my boss was to go out and            8    A. Yes.
 9 recall the funds. Whether I believed it or not              9    Q. From your perspective, did it seem like
10 wasn't part of the equation. He was directing me to        10 the investigation that was conducted in connection

11 engage them to recall the funds.                           11 with the Blue Flame wire transfer was a cooperative

12         So whether I believed it or not, if you're         12 investigation that involved both JPMorgan and Chain

13 asking for my professional opinion, there was enough       13 Bridge Bank?

14 suspicion and red flags that would be concerning.          14    A. Yes, I thought Chain Bridge was very
15     Q. When you were -- when you were interacting          15 cooperative.

16 with another financial institution in connection with      16    Q. And did you hear the portion of the audio
17 investigating a suspicious or potentially suspicious       17 recording where you said, "As quickly as you can

18 transaction, would you strive to communicate               18 return it, that'd be great"?

19 truthfully to the other personnel at the other             19    A. Yes.
20 financial institution?                                     20    Q. And that was -- that was a reference to
21     A. Yes.                                                21 returning the funds that had been transferred as

22         MR. SCHOENFELD: Objection.                         22 quickly as possible; is that right?


                                              www.trustpoint.one                                        800.FOR.DEPO
                                            www.aldersonreporting.com                                    (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                          2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                  Page 19 36
                                                                                                  Page of 23
                                                                                                          (138 - 141)
                                 PageID# 1951
                                                    Page 138                                                  Page 140
 1    A. Yes.                                                  1      A. Pega, P-e-g-a, Rules, R-u-l-e-s, Process
 2    Q. And did you understand that you were                   2 Commander. Pega Rules Process Commander.

 3 calling Chain Bridge Bank on behalf of JPMorgan?             3     Q. And is that a piece of software that
 4    A. Yes.                                                   4 JPMorgan uses in connection with wire transfers or

 5    Q. And you had authorization to make the                  5 does it have some broader application?

 6 request that was communicated to the Chain Bridge            6     A. It's largely involved in wire transfers.
 7 personnel on the phone recording, right?                     7 It's our investigation tool. But it also does ACH at

 8    A. Yes.                                                   8 the same time.

 9    Q. So after that phone conversation with the              9     Q. And you referred to, I think, opening up a
10 Chain Bridge personnel that we just listened to, what       10 case in that system; is that right?

11 did you do next in connection with the Blue Flame           11     A. That's correct.
12 wire transfer?                                              12     Q. And is that a step that's necessary before
13    A. Based upon Chain Bridge requesting a Fed              13 the recall notice can be initiated?

14 service message to recall the wire, I engaged a             14     A. That's correct.
15 counterpart of mine, Debra Naughton, to open up a           15     Q. Do you understand the purpose of that step
16 case and send out that Fed service recall message as        16 of opening up the case?

17 requested by Chain Bridge.                                  17     A. We cannot generate the Fed service message
18    Q. And can you explain a little bit more                 18 without having a case opened on that particular

19 about that process? How precisely does that work?           19 transaction. The reason for that is, if any other

20 Who was it that initiates the message?                      20 future correspondence comes in pertaining to that

21    A. So my counterpart, Deb Naughton, who I                21 transaction, it would automatically link to the case

22 mentioned, she would open up the case in our wire           22 that's already been opened. So it's a way of
                                                    Page 139                                                  Page 141
 1 investigation system, attach the transaction to the         1 creating an historical audit trail.

 2 investigation and, within that -- within that case,         2    Q.   And so in connection with the Blue Flame
 3 she can generate that Fed service message.                  3 wire transfer, you did approve the service message

 4    Q. And after she's generated the Fed service        4 that was then sent to Chain Bridge; is that correct?

 5 message, is there something that you would need to do 5      A. I did.
 6 before the message is sent out?                        6     Q. And do you remember the content of that
 7    A. I would need to approve the message that         7 service message?
 8 she sent.                                              8     A. These are standard templates that are
 9    Q. And so you would review the message and          9 built within the application and you really go in and
10 then provide approval so that it could be sent?       10 pick the generic template for the recall and it

11    A. I would.                                        11 populates the dates, dollar amounts and parties into

12    Q. How do you review it? Is it something           12 it.

13 that arrives by email or is there some other way that 13         So it's an automated way of utilizing
14 you would access the system to review the message?    14 templates to get a recall of funds. So she picked

15    A. The approval of the message is done within      15 the recall of funds, it populates the message and

16 the PRPC application itself. So it would go into the  16 spits out that Fed service message.

17 application.                                          17     Q. I see. So do you -- in the system, do you
18    Q. What was the acronym that you just              18 select the original wire transfer and then it
19 mentioned? The connection broke up a little bit.      19 populates that information into a recall request? Is

20    A. No problem. P as in Peter, R as in              20 that how it works?

21 Robert, P as in Peter, C as in Charlie. PRPC.         21     A. So we save the original transaction to the
22    Q. And what does that stand for?                   22 case. That way, if anybody else looked up that wire
                                               www.trustpoint.one                                      800.FOR.DEPO
                                             www.aldersonreporting.com                                  (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                         2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                 Page 20 37
                                                                                                 Page of 23
                                                                                                         (142 - 145)
                                 PageID# 1952
                                                    Page 142                                                   Page 144
 1 at a future time, it would know that it already has a       1 with the email that begins at the top of page 3 of

 2 case opened up on it.                                       2 this PDF.   That's an email from you, Mr. Coffey, to
 3    Q.   And then when you get to the step of                3 Debra Naughton at 1:42 p.m. on March 26th.

 4 initiating the recall service message, does the             4          Do you see that one?
 5 information about the transaction automatically             5     A. I think we need to -- scroll down. Sorry
 6 populates from the information on the prior transfer?        6 about that. I do see that. Sorry. Yeah.

 7 Is that how it works?                                        7    Q. And is -- do you recognize this email?
 8    A. Correct, the automation.                               8    A. I do.
 9    Q. And then is there a component of the                   9    Q. And is this the communication we were just
10 service message that is typed into the system, like a       10 discussing where you related the request to

11 message to the other bank?                                  11 Ms. Naughton that she open up the case and then

12    A. Yeah, there can be. If you don't choose a             12 create the service message for the wire transfer?

13 template, you can use a freeform message. But in            13    A. That's correct.
14 general, we try to cover things by utilizing the            14    Q. And then if you scroll up one email from
15 basic templates that we have in the system.                 15 there, so the second page of the PDF document,

16    Q. Do you know whether in this case the                  16 there's a response from Ms. Naughton to you at 1:50

17 service message that was generated and then sent to         17 p.m.?

18 Chain Bridge came from a template?                          18    A. Yes.
19    A. I would -- I didn't create it. It didn't              19    Q. And do you see she says, "PRPC case," and
20 look like a freeform message. It looked like it was         20 then there's a set of letters and numbers and says,

21 one of the templates that we used.                          21 "Kindly verify message"?

22    Q. At this point in time, when you were                  22    A. Yes, I do.
                                                Page 143                                                      Page 145
 1 working on approving the service message to go to           1 Q. And so did you understand that to mean
 2 Chain Bridge Bank, did you have any understanding      2 that she had opened up a case in the system to

 3 about whether California had requested that the wire   3 address the request that you had made to her?

 4 transfer be recalled?                                  4      A. She had opened up the case in the system
 5     A. I didn't have any understanding of what         5 and generated the necessary message to send to Chain
 6 was driving the recall. Again, the decision-making     6 Bridge.

 7 was being driven by Rakesh and David.                  7      Q. I see. So the second sentence there,
 8         MR. BURKE: Zach, can you add what we have      8 "Kindly verify message," that was letting you know
 9 as tab 44 as a new exhibit? I think this is going to   9 that the message was available for you to review?

10 be Defendant's Exhibit 91, if I'm counting correctly. 10      A. Correct.
11         MR. FERGUSON: I think it's actually 92        11      Q. And then at that point you would go into
12 and I'll add it.                                      12 the system, and is there a button in the interface

13         MR. BURKE: Thanks. Yeah, you're right.        13 that you can click to put your approval in?

14            (Defendant's Exhibit No. 92 was            14      A. There's a verify button, yes.
15            marked for identification.)                15      Q. So if you look up one email from there,
16 BY MR. BURKE:                                         16 it's an email from you back to Ms. Naughton at 2:06

17     Q. Mr. Coffey, were you able to access that       17 p.m., and the first line of that email is -- says,

18 new exhibit?                                          18 "Recall sent."

19     A. I am.                                          19         Do you see that?
20     Q. So for the record, this is a document          20      A. Yes.
21 produced by JPMorgan with a Bates label               21      Q. And what did you mean by that sentence?
22 JPMC-00000170. I think it would make sense to start 22        A. I was letting Rakesh know that the recall
                                              www.trustpoint.one                                      800.FOR.DEPO
                                            www.aldersonreporting.com                                  (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                         2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                 Page 21 38
                                                                                                 Page of 23
                                                                                                         (146 - 149)
                                 PageID# 1953
                                                  Page 146                                                        Page 148
 1 message -- the Fed service recall message has been         1A. It populates -- again, like I said to you,
 2 delivered to Chain Bridge.                             2 this is a template that pulls the information in. So

 3     Q. And then right below that, there's a block      3 nobody's keyed in the IMAD, nobody's keyed in the

 4 of text that begins on the first line with "McLean,"   4 date, nobody's keyed in the amount. It pulls in that

 5 and then there's a date and "message text."            5 information into this template, which is a template

 6         Do you see all of that?                        6 we used for recall of funds.

 7     A. I do.                                           7    Q. And so this was a message to Chain Bridge
 8     Q. Do you understand that to be the -- at          8 Bank requesting that they return the funds that had
 9 least part of the content of the service message that  9 been wired to them for Blue Flame's benefit?

10 was sent to Chain Bridge Bank in connection with this 10    A. Yes.
11 transaction?                                          11    Q. Mr. Coffey, in your career, have you seen
12     A. Yes.                                           12 service messages that were meant to recall funds that
13     Q. Was that something you were able to copy       13 included the phrase "no indemnity"?
14 and paste out of the PRPC system and put into the     14    A. I have seen that attached within some
15 email?                                                15 messages, yes.

16     A. Yes.                                           16    Q. Would you agree with me that there's no
17     Q. And so that's the message that -- or at        17 mention of the words "no indemnity," or any variation
18 least a component of the message that went out from   18 on those words, as part of this service message we're

19 JPMorgan to Chain Bridge?                             19 looking at here on Exhibit 92?

20     A. Yes.                                           20    A. It's not mentioned in this Fed service
21     Q. Would there have been other information as     21 message, no.
22 part of the message that went out?                    22    Q. And on the phone call you had with Chain
                                                 Page 147                                                     Page 149
 1     A. No. This would be the context of the                1 Bridge personnel that we were talking about a few

 2 message.                                                   2 minutes ago, did you mention anything about no

 3     Q. And there's a portion of this message that          3 indemnity as part of that conversation?

 4 sort of reads like it's in code with a set of              4    A.    The word "indemnity" was never mentioned
 5 abbreviations. Can you summarize for us the contents       5 by either party, be it Chase or Chain Bridge.

 6 of the message that's repeated here?                       6    Q.    So after you approved the recall message
 7     A. Are we referencing the attention line?              7 and it was sent to Chain Bridge Bank, did you do

 8     Q. Yes.                                                8 anything else in connection with the Blue Flame wire

 9     A. Yeah. So it's to shorten up the message.            9 transfer?

10 Because there's a limitation of characters in a Fed       10    A.    No. I just continued to monitor within
11 service message, there's a lot of abbreviations used      11 the JPMorgan Chase application for the return of

12 that are understood between the financial                 12 funds.

13 institutions.                                             13    Q.    And so would you get an alert when the
14         So that line reads as, "Attention                 14 funds were returned, or did you have to check

15 investigations, refer to our fed IMAD," dot, dot,         15 periodically to see whether they had arrived?

16 dot.                                                      16    A.    It could happen either way. I was
17     Q. And is the IMAD, is that a reference               17 checking periodically.

18 number for a wire transfer?                               18    Q.    Did you have any other phone conversations
19     A. It's a reference number for a Fedwire              19 with any of the personnel at Chain Bridge Bank that

20 transfer.                                                 20 day after the recall notice was sent?

21     Q. And then can you tell us your                      21    A.    No.
22 understanding of the remainder of that message?           22    Q.    You don't recall any calls with Chain
                                            www.trustpoint.one                                          800.FOR.DEPO
                                          www.aldersonreporting.com                                      (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                           2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                   Page 22 39
                                                                                                   Page of 23
                                                                                                           (150 - 153)
                                 PageID# 1954
                                                     Page 150                                                      Page 152
 1 Bridge personnel to check on the status of the recall        1     A. I do see that.
 2 notice or the status of Chain Bridge returning the            2    Q. Can you explain to me what Ms. Naughton
 3 funds?                                                        3 was communicating to you in this message?

 4    A.    I don't recall. We sent the recall                   4    A. Sure. She was confirming that the funds
 5 message.    We were monitoring for the return of funds.       5 had been returned. She's quoting the transaction

 6 Once the funds came back, there really is no more             6 number of the -- that is going to be the transaction

 7 need for interaction.                                         7 number between us and state of California. She's

 8    Q.    Do you have a recollection of how long it            8 advising, "Tim, please release."

 9 was between JPMorgan sending the recall message and           9        Again, just like the Fed service message,
10 the funds being returned from Chain Bridge back to           10 they needed to make a checker. The release of this

11 JPMorgan?                                                    11 transaction needs to make a checker, and I was to

12    A.    I don't recall the exact time frame. I do           12 perform the release of this transaction out to state

13 believe it took a little bit of time based upon the          13 of California.

14 fact that Rakesh had continued to ask me had the             14    Q. And at that point, did you go into the
15 funds been returned.                                         15 system and approve the release of the funds back to

16    Q.    I see. And how did he -- how did he ask             16 California?

17 you that question?                                           17    A. Yes.
18    A.    I believe he was coming by my cubicle and           18    Q. And is that the step that's documented in
19 asking me had they come back yet.                            19 the top email that you sent, if my math is right, at

20    Q.    Did he seem anxious to have the funds               20 4:03 p.m. on the 26th?

21 returned?                                                    21    A. Yes.
22    A.    I think, based upon the escalation that             22    Q. And if you flip down to the fifth page of
                                                 Page 151                                                        Page 153
 1 was going through Chase, okay, people making bosses          1 the PDF -- you might have to zoom in, too -- there's

 2 aware of what's going on.      Chain Bridge obviously was    2 a block of text in black here, you know, black

 3 uncomfortable holding these funds and not comfortable        3 background with white text.

 4 with applying them.      I think everybody was looking to    4     A. Yes.
 5 put this situation to rest.                                  5     Q. Is that -- is that an output from the
 6    Q.    Did you have any understanding at this               6 bank's system that you then copied and pasted into

 7 time of whether California officials were waiting for         7 the email?

 8 the funds to be returned?                                     8    A. This is an output from the PRPC system
 9    A.    I was not involved in any of that                    9 showing that the transaction has completed back to

10 conversation.                                                10 California state -- state of California.

11    Q.    I think I understand your answer, but I             11    Q. And Mr. Coffey, do you have any
12 just want to make clear.      I don't necessarily mean       12 understanding of the reaction of any California

13 information that you received directly from                  13 officials after the funds were returned?

14 California officials.   I'm wondering whether you were       14    A. I do not, based upon my nonengagement with
15 aware, because somebody told you about discussions           15 them.

16 with California officials, that somebody in                  16    Q. Did you ever talk to anyone at JPMorgan
17 California was waiting for the funds to be returned?         17 who shared something they had heard about California

18    A.    I was not aware of that.                            18 officials' reaction?

19    Q.    If you return back to Exhibit 92, on the            19    A. No.
20 first page, there's an email from Ms. Naughton back          20    Q. Did you understand that JPMorgan was
21 to you at 3:35 p.m.     Do you see that one? It's sort       21 seeking to protect California's money when it issued

22 of the bottom half of the first page?                        22 the recall notice to Chain Bridge Bank?


                                                   www.trustpoint.one                                   800.FOR.DEPO
                                                 www.aldersonreporting.com                               (800.367.3376)
Timothy P. Coffey             HIGHLY CONFIDENTIAL                                                              2/11/2021
    Case 1:20-cv-00658-LMB-IDD Document 130-58 Filed 05/06/21                                      Page 23 40
                                                                                                      Page of 23
                                                                                                              (154 - 157)
                                 PageID# 1955
                                                         Page 154                                                   Page 156
 1         MR. SCHOENFELD: Objection.                               1 had become suspicious of the transaction on the

 2         THE WITNESS: I would assume that that was                2 second phone conversation that we discussed that you

 3 the reason for people being concerned and the red                3 had with the Chain Bridge personnel?

 4 flags involved, yes, that we were protecting all                 4     A.    He did.
 5 parties involved.                                                5          MR. SCHOENFELD: Objection. Just give me
 6 BY MR. BURKE:                                                     6 a second. Objection.

 7     Q. Stepping back from the Blue Flame                          7 BY MR. BURKE:

 8 transaction, but thinking more broadly about other                8    Q. But Chain Bridge didn't return the funds
 9 investigations of wire transactions you've been                   9 immediately after that conversation with you and

10 involved in, is that generally JPMorgan's goal, when             10 Mr. Korpal, did they?

11 it -- when you would be involved in an investigation             11    A. No.
12 of a wire transaction that had been initiated by one             12    Q. Chain Bridge didn't return the funds until
13 of your customers, would you be seeking to protect               13 after you had called them and informed them that

14 the customer?                                                    14 JPMorgan would be recalling the funds, right?

15         MR. SCHOENFELD: Objection.                               15         MR. SCHOENFELD: Objection.
16         THE WITNESS: Yes.                                        16         THE WITNESS: My -- my directive was to
17 BY MR. BURKE:                                                    17 call them and ask for a recall of funds, which is

18     Q. Mr. Coffey, do you hold a belief that                     18 what I did. What drove that decision in the

19 Chain Bridge would have returned the funds to                    19 background, I'm not privy to that.

20 JPMorgan even if JPMorgan hadn't issued a recall                 20         Again, could have been conversations
21 request for the funds?                                           21 Rakesh had with state of California or conversations

22     A. Yes.                                                      22 he had with David directly, but I can't speak on
                                                         Page 155                                                   Page 157
 1    Q.    And can you tell me every fact you're                   1 behalf of that.

 2 aware of that supports your belief that Chain Bridge             2 BY MR. BURKE:

 3 would have returned the funds even if JPMorgan hadn't            3     Q.    I understand that perspective, but I don't
 4 made the recall request?                                         4 think that was really my question.     I think my
 5         MR. SCHOENFELD: Object to the form. You                   5 question was simpler than that.

 6 can answer.                                                       6         Just in terms of timing, Chain Bridge
 7         THE WITNESS: Based upon the word -- you                   7 didn't return the funds back to JPMorgan until after

 8 said -- belief is when I engaged Chain Bridge, they               8 you called them and told them that you would be

 9 were already holding the funds before I even got in               9 recalling the funds; is that correct?

10 touch with them.   So they had already started some              10    A. Correct. Their request to send a Fed
11 sort of internal investigation of some of the red                11 service message is what drove the return of funds,

12 flags that they had saw.                                         12 correct.

13         My belief, again, is that Chain Bridge was               13    Q. Well, on that conversation we were
14 suspicious of the transaction, wanted to return it,              14 speaking about a little bit ago when you called the

15 and when JPMorgan Chase, which is one of the bigger              15 Chain Bridge personnel and informed them that

16 banks that is out there, came in and said, hey, we're            16 JPMorgan would be recalling the funds, it was after

17 a little suspicious, too, that was the icing on the              17 you informed them that JPMorgan would be recalling

18 cake they needed to send the funds back.                         18 the funds that you then discussed whether Chain

19 BY MR. BURKE:                                                    19 Bridge would want a service message, right?

20    Q.    But thinking back to the phone                          20    A. That is correct.
21 conversations we discussed earlier today, didn't                 21    Q. And Chain Bridge didn't return the funds
22 Mr. Korpal share some of the reasons that JPMorgan               22 until after they had received the service message


                                                  www.trustpoint.one                                         800.FOR.DEPO
                                                www.aldersonreporting.com                                     (800.367.3376)


File and source

File
130-att58.pdf
Size
156,387 bytes
SHA-256
98db243b5a782a2f3072a43c98c3a2f120b735dc8e37cc2135f9146955f25c39
Our copy
130-att58.pdf
Original
No public link identified.
Back to top