Remote Videotaped Deposition of Ethan Bearman — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 132-3)

Summary

Case 1:20-cv-00658, Document 132-3, is Exhibit 3, an excerpt of the remote videotaped deposition of Ethan Bearman, taken on Thursday, January 21, 2021, in Blue Flame Medical LLC v. Chain Bridge Bank, N.A. Asked why Blue Flame Medical was formed, the witness says that Mike and John, the co-members of Blue Flame Strategies and the co-members and founders of Blue Flame Medical, wanted to start selling PPE as a major distributor and wanted a separate entity from the consulting and referral business. The witness answers "No" when asked whether Blue Flame Strategies could not have sold or purchased PPE, and says it continues to exist. Mr. Madden then turns to Exhibit 73.

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Case 1:20-cv-00658-LMB-IDD   Document 132-3   Filed 05/07/21   Page 1 of 4 PageID#
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          EXHIBIT 3
Ethan Bearman                     CONFIDENTIAL                               1/21/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-3 Filed 05/07/21   Page 2 of 4 PageID#Page 1
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  1             IN THE UNITED STATES DISTRICT COURT
  2            FOR THE EASTERN DISTRICT OF VIRGINIA
  3                       (Alexandria Division)
  4   - - - - - - - - - - - - - - - X
  5   BLUE FLAME MEDICAL LLC,                       : Civil Action No.
  6               Plaintiff,                        : 1:20-CV-00658
  7   vs.                                           :
  8   CHAIN BRIDGE BANK, N.A.,                      :
      JOHN J. BROUGH, and                           :
  9   DAVID M. EVINGER,                             :
 10               Defendants.                       :
 11   - - - - - - - - - - - - - - - X
 12   CHAIN BRIDGE BANK, N.A.,                      :
 13         Third-Party Plaintiff,                  :
 14   vs.                                           :
 15   JPMORGAN CHASE BANK, N.A.,                    :
 16         Third-Party Defendant.                  :
 17   - - - - - - - - - - - - - - - X
 18                              CONFIDENTIAL
 19      Remote Videotaped Deposition Of ETHAN BEARMAN
 20                   Thursday, January 21, 2021
 21                            9:34 a.m. (EST)
 22   Reported by:        Dana C. Ryan, RPR, CRR

                                www.trustpoint.one                      800.FOR.DEPO
                              www.aldersonreporting.com                  (800.367.3376)
Ethan Bearman                     CONFIDENTIAL                                1/21/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-3 Filed 05/07/21    Page 3 of 4 PageID#
                                                                               Page 121
                                     2477

  1           A       I recall that to be true, yes.
  2           Q       Do you have an understanding as to why
  3   Blue Flame Medical was formed?
  4                   MR. GUSSMAN:         Objection to form.
  5                   THE WITNESS:         I -- I'm aware of the
  6   request, and, yes.
  7           BY MR. MADDEN:
  8           Q       And what was the reason for forming
  9   Blue Flame Medical?
 10           A       To begin to become -- excuse me.                    I'm
 11   trying to think of how to phrase that correctly.
 12                   They --
 13                   MR. GUSSMAN:         Just note my objection to
 14   the form.
 15                   I'm sorry.        Go ahead.
 16                   THE WITNESS:         Okay.          Mike and John, the
 17   co-members of Blue Flame Strategies and the
 18   co-members and founders of Blue Flame Medical,
 19   wanted to start selling PPE, really moving
 20   product, becoming a major distributor.                      And they
 21   wanted a separate entity for that, separate from
 22   the consulting and, kind of, referral business

                                www.trustpoint.one                       800.FOR.DEPO
                              www.aldersonreporting.com                   (800.367.3376)
Ethan Bearman                     CONFIDENTIAL                               1/21/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-3 Filed 05/07/21   Page 4 of 4 PageID#
                                                                              Page 122
                                     2478

  1   that was Blue Flame Strategies; therefore, it
  2   required a new entity to do that, a new company.
  3           BY MR. MADDEN:
  4           Q       Was there any reason that Blue Flame
  5   Strategies could not have sold PPE to customers?
  6                   MR. GUSSMAN:         Objection to form.
  7                   THE WITNESS:         No.
  8           BY MR. MADDEN:
  9           Q       And is there any reason that Blue Flame
 10   Strategies could not have purchased PPE from
 11   suppliers?
 12                   MR. GUSSMAN:         Objection to form.
 13                   THE WITNESS:         No.
 14           BY MR. MADDEN:
 15           Q       And at the time of forming Blue Flame
 16   Medical, am I right that Blue Flame Strategies
 17   didn't close down; correct?
 18                   It continued in operation?
 19           A       Continues to exist.
 20           Q       Okay.      Okay.
 21                   MR. MADDEN:         Now, I'm going to turn to
 22   what we're marking as Exhibit 73, which is a

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

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