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.