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Videotaped Deposition of Michael Wong — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 132-18)

Summary

Case 1:20-cv-00658, Document 132-18, is Exhibit 18, an excerpt of the remote videotaped deposition of Michael Wong, taken by Zoom on Tuesday, January 19, 2021, in Blue Flame Medical LLC v. Chain Bridge Bank, N.A. Mr. Madden asks the witness about a purchase order marked as Exhibit 43, including a required delivery date of April 3rd in the shipping instructions. The witness answers that at least the initial shipment of the masks should have been received by April 3rd, which the witness believes is eight days from the issuance of the purchase order. The witness also states that FOB destination means freight on board destination and that the legal meaning is not known to the witness.

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Cite this document

“Videotaped Deposition of Michael Wong — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 132-18).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cv-00658-dkt-132-18-e-d-va-d4cdc92db1/, SHA-256 5eaf7c6e14640fc30f896336d599f7f05fe8ee9d499f477f43e6969ddb7cdfeb.

Full text

Case 1:20-cv-00658-LMB-IDD   Document 132-18   Filed 05/07/21   Page 1 of 4 PageID#
                                     2671




       EXHIBIT 18
Michael Wong                      CONFIDENTIAL                               1/19/2021
Case 1:20-cv-00658-LMB-IDD   Document 132-18 Filed 05/07/21   Page 2 of 4 PageID#
                                                                                Page 1
                                     2672

  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., JOHN                :    1:20-cv-00658

  9     J. BROUGH and DAVID M.                       :

 10     EVINGER,                                     :     CONFIDENTIAL

 11          Defendants.                             :

 12     _____________________________                :

 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                                     Tuesday, January 19, 2021

 21                  Videotaped Deposition via Zoom of MICHAEL

 22   WONG, a witness herein, called for examination by

                                www.trustpoint.one                     800.FOR.DEPO
                              www.aldersonreporting.com                 (800.367.3376)
Michael Wong                      CONFIDENTIAL                               1/19/2021
Case 1:20-cv-00658-LMB-IDD   Document 132-18 Filed 05/07/21   Page 3 of 4 PageID#
                                                                              Page 108
                                     2673

  1   Flame Medical's shipping costs, right?

  2          A.      Yes, sir.

  3          Q.      Do you see there's a line for shipping

  4   instructions in the middle of the document?

  5          A.      Which section are you looking at, sir?

  6          Q.      Yeah.     It's roughly in the middle of

  7   Exhibit 43, there's a line labeled shipping

  8   instructions, just above the terms and conditions.

  9          A.      Yes, sir.

 10          Q.      You see that now?

 11          A.      Yes, sir.

 12          Q.      It has a required delivery date of April

 13   3rd, 2020.       Do you see that?

 14          A.      Yes, sir.

 15          Q.      Did that convey that some or all of the

 16   masks being ordered were required to be delivered by

 17   April 3rd?

 18          A.      Yes, sir.

 19          Q.      And what was your understanding of that

 20   requirement as related to this purchase order?

 21          A.      At least the initial shipment of the masks

 22   should have been received by April 3rd.                   I believe

                                www.trustpoint.one                     800.FOR.DEPO
                              www.aldersonreporting.com                 (800.367.3376)
Michael Wong                      CONFIDENTIAL                               1/19/2021
Case 1:20-cv-00658-LMB-IDD   Document 132-18 Filed 05/07/21   Page 4 of 4 PageID#
                                                                              Page 109
                                     2674

  1   that's the eight days from the issuance of the

  2   purchase order.

  3          Q.      And was it your understanding that if an

  4   initial shipment of masks was not delivered by April

  5   3rd, that would have been a breach of your agreement

  6   with Blue Flame Medical?

  7          A.      Yes, sir.

  8                  MS. PORTER:        Objection.        Calls for a legal

  9   conclusion.

 10   BY MR. MADDEN:

 11          Q.      And then next to the required delivery

 12   date, there's a checkmark for FOB destination.

 13                  Do you see that?

 14          A.      Yes, sir.

 15          Q.      And what does that signify?

 16          A.      Freight on board destination.

 17          Q.      And what does that -- what does that mean?

 18          A.      The legal meaning of it I don't know

 19   myself.

 20          Q.      And then a little further down the page,

 21   do you see there's a section for procurement methods?

 22          A.      Yes, sir.

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

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