Remote Videotaped Deposition of Joanna Williamson — Blue Flame Medical LLC v. Chain Bridge Bank (Dkt. 132-31)

Summary

Case 1:20-cv-00658, Document 132-31, is an excerpt of the remote videotaped deposition of Joanna Williamson, taken on Sunday, April 11, 2021, in Blue Flame Medical LLC v. Chain Bridge Bank, N.A. In the pages shown, the witness testifies that the OCC sets capital ratios, that the bank has a leverage ratio and a few risk-based capital requirements, and that capital ratios are normally computed and reported for quarter end. On March 26th, the witness says, a hold was placed on the Blue Flame Medical account, and the witness was copied on an e-mail showing David Evinger asking that the hold be placed. The witness states no involvement in the decision and does not believe holds are reflected in balance sheets.

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Full text

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Case 1:20-cv-00658-LMB-IDD Document 132-31 Filed 05/07/21 Page 2 of 6 PagelD#

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CONFIDENTIAL
Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
(Alexandria Division)
BLUE FLAME MEDICAL LLC, )
Plaintiff, )
)
vs. )Civil Action
)No.
CHAIN BRIDGE BANK, )1:20-cv-00658

N.A., JOHN BROUGH, and
DAVID M. EVINGER,
Defendants.

CHAIN BRIDGE BANK,
N.A.,
Third-Party
Plaintiff,

JPMORGAN CHASE BANK,
N.A.,
Third-Party
Defendant.

***CONFIDENTIAL***
REMOTE VIDEOTAPED DEPOSITION OF
JOANNA WILLIAMSON
located in McLean, Virginia
Sunday, April 11, 2021

Reported By:
CATHI IRISH, RPR, CRR, CLVS

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CONFIDENTIAL
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WILLIAMSON - CONFIDENTIAL
OCC typically have for you, the CFO?
A. They are typically pretty general

and usually would have to do with the
bank's liquidity position, asset liability
management, interest rate risks, generally
those types of topics. They may also ask
me questions about the bank's audit
process.

Q. Does the OCC set capital

requirements for the bank?

A. Yes.

Q. What form do those requirements
take?

A. I don't understand.

Q. Are -- does the OCC set capital

ratios that the bank must comply with?

A. The OCC does set capital ratios,
yes.

Q. And are you familiar with how
those ratios are calculated?

A. Yes, I am.

Q. Were you familiar with how they
were calculated as of March 25, 2020?

MR. MADDEN: Objection to the

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CONFIDENTIAL

Page 21

WILLIAMSON - CONFIDENTIAL
form.

THE WITNESS: Normally our
capital ratios are computed and
reported for quarter end so I'm not
sure that I had a calculation prepared

for March 25th.

BY MR. KETCHAM-COLWILL:
9 Q. The quarter end for 2020 would

10 have been the end of March 2020?

11 MR. MADDEN: Objection to the
12 form.
13 THE WITNESS: Yes.

14 BY MR. KETCHAM-COLWILL:

15 Q. And excuse my ignorance here, but
16 what capital ratios does the bank maintain
17 as -- in complying with OCC requirements?
18 A. The bank has a leverage ratio.

19 We also have a few risk-based capital

20 requirements. Excuse me?

21 Q. I didn't mean to interrupt you.
22 Are you done?

23 A. Yes, I am.

24 Q. How is the leverage ratio

25 calculated?

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Page 175

WILLIAMSON - CONFIDENTIAL
BY MR. KETCHAM-COLWILL:

Q. I'll move on.

At some point on March 26th did
you become aware that there was a hold
placed on Blue Flame Medical's account?

A. I don't have a recollection of
that though I believe that there was a
hold placed.

Q. Do you know who directed that a
hold be placed?

A. I have been copied on an e-mail
that showed David Evinger asking that hold
be placed.

Q. Were you involved in the decision
to place that hold?

A. No.

Q. Do you know how a hold works from
a bank operational perspective?

A. I am not involved with decisions
to place holds or the actual placement of
holds.

Q. When funds are held beyond --
sorry.

When funds are deposited into a

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WILLIAMSON - CONFIDENTIAL
customer's account and then a hold is
placed and that hold lasts through the
next day, how is that hold or is that hold
reflected somewhere in the bank's balance
sheet?

MR. MADDEN: Objection to form.

THE WITNESS: No, I don't believe

holds are reflected in balance sheets.
BY MR. KETCHAM-COLWILL:

Q. So the funds come in credited to
a customer's account and a hold is placed,

how does the bank account for those funds?

MR. MADDEN: Objection to form.
THE WITNESS: The same as any
other account. Regardless of whether

it has a hold, it's going to be

accounted for in the balance sheet the

same.

MR. KETCHAM-COLWILL: Okay.
Angie, can we go back to -- actually
let's go with our tab 7. Tab 7 is

Bates stamped CBBO0004468.
MS. GARCIA: And it hasn't been

introduced yet; correct?

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