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Home Source documents Deposition of Daniel Kim — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va., Dkt. 132-6)

Deposition of Daniel Kim — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va., Dkt. 132-6)

Summary

Case 1:20-cv-00658, Document 132-6, is Exhibit 6, an excerpt of the remote deposition of Daniel Kim, taken by Zoom on Monday, March 29, 2021, in Blue Flame Medical LLC v. Chain Bridge Bank, N.A. The witness testifies that the Department of General Services was purchasing PPE on behalf of the state, that vetting was more expedited than normal, and that the chief procurement officer in March 2020 was Angela Shell. The witness says a state procurement typically takes six months to 12 months, while the state had days rather than months. Ms. Forstein asks about a delivery schedule from Mr. Thomas covering all 100 million masks, and the witness says there is no recollection of the two suppliers.

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Cite this document

“Deposition of Daniel Kim — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va., Dkt. 132-6).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cv-00658-dkt-132-6-e-d-va-fb32ef6d53/, SHA-256 b103f3d48aac73ca587152955c6a3a43bed4118fd86779cad9863a727824935f.

Full text

Case 1:20-cv-00658-LMB-IDD   Document 132-6   Filed 05/07/21   Page 1 of 7 PageID#
                                    2506




          EXHIBIT 6
Daniel Kim                                                                       3/29/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-6     Filed 05/07/21   Page 2 of 7 PageID#Page 1
                                     2507

  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.                              :

 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                                      Monday, March 29, 2021

 21                   Deposition via Zoom of DANIEL KIM, a

 22   witness herein, called for examination by counsel for

                                 www.trustpoint.one                         800.FOR.DEPO
                               www.aldersonreporting.com                     (800.367.3376)
Daniel Kim                                                                      3/29/2021
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                                                                                  Page 15
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  1   I'm trying to figure out the direct reports.                         Chuck

  2   Tobia, who's the deputy director for strategic

  3   planning.       Monica Hassan, the deputy director for

  4   public affairs.         Anita Kung, who is my special

  5   assistant.       Ida Clair was the acting state architect

  6   over the Division of State Architect.                      Juan Vasquez,

  7   who's the deputy director for special projects.

  8                   How many is that?

  9          Q.       I likewise haven't been counting, but if

 10   those are the ones you recall, that's all we're

 11   asking for.

 12          A.       Yeah.

 13          Q.       And why did you leave the Department of

 14   General Services?

 15          A.       I left because I found a position in Yolo

 16   County that fit my skill sets that was a great

 17   opportunity to be working under a really reputable

 18   leader for more pay than I was making at the state.

 19          Q.       And turning back to March of 2020, what

 20   was the Department of General Services' role in

 21   procuring personal protective equipment for the state

 22   of California?

                                www.trustpoint.one                         800.FOR.DEPO
                              www.aldersonreporting.com                     (800.367.3376)
Daniel Kim                                                                      3/29/2021
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  1          A.       Our role was to be one of a number of

  2   departments that were part of the statewide task

  3   force for logistics and commodity movement.                        We had a

  4   number of different roles in that capacity.                        In terms

  5   of PPE, we were purchasing PPE on behalf of the

  6   state.

  7          Q.       Did the Department of General Services

  8   play a role in vetting potential PPE vendors?

  9          A.       Yes.

 10          Q.       What was that role?

 11          A.       Our staff, who were doing procurement

 12   along with other staff who were part of the logistics

 13   commodity movement team, were doing some vetting to

 14   determine whether the vendors met the qualifications

 15   necessary to purchase from.

 16          Q.       And what were the qualifications that were

 17   necessary to purchase from in March 2020?

 18          A.       I don't know the specifics, but I do know

 19   that our process for vetting was much more expedited

 20   than it would normally have been, outside of an

 21   emergency.

 22          Q.       And who in your office was primarily

                                www.trustpoint.one                         800.FOR.DEPO
                              www.aldersonreporting.com                     (800.367.3376)
Daniel Kim                                                                      3/29/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-6    Filed 05/07/21   Page 5 of 7 PageID#
                                                                                  Page 17
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  1   responsible for that work?

  2          A.       Our chief procurement officer was largely

  3   responsible for that.

  4          Q.       And who was that in March 2020?

  5          A.       Angela Shell.

  6          Q.       And you mentioned that the department's

  7   rollout of the vetting process was abbreviated from

  8   what the usual vetting procedure would be.                        What is

  9   DG -- outside of the context of the pandemic, how do

 10   vetting procedures typically work for procurement at

 11   DGS?

 12          A.       And I don't know the specifics of the

 13   vetting procedure.          I just know that the process is

 14   much more time-intensive and rigorous.

 15          Q.       Was vetting vendors difficult at the start

 16   of the COVID-19 pandemic in March 2020?

 17          A.       Yes.

 18          Q.       And why was that?

 19          A.       We were asked to purchase PPE in a very

 20   expedited time frame.            Typically a procurement that

 21   the state conducts takes anywhere from six months to

 22   12 months.       So we had days rather than months or a

                                www.trustpoint.one                         800.FOR.DEPO
                              www.aldersonreporting.com                     (800.367.3376)
Daniel Kim                                                                      3/29/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-6    Filed 05/07/21   Page 6 of 7 PageID#
                                                                                  Page 98
                                     2511

  1          A.       I'll take your word for it, yes.

  2          Q.       Was getting a delivery schedule from

  3   Mr. Thomas in which California would have all 100

  4   million masks within a month important to you?

  5                   MR. KETCHAM-COLWILL:                Objection.     Vague.

  6                   MS. PORTER:       Objection.           Asked and

  7   answered.

  8                   THE WITNESS:        As I mentioned earlier, it

  9   was very important for the state of California to get

 10   N95 masks as soon as possible to save as many lives

 11   as possible.

 12   BY MS. FORSTEIN:

 13          Q.       And you said earlier that that meant a

 14   matter of days as opposed -- or weeks possibly as

 15   opposed to a matter of months; is that right?

 16          A.       Yes.

 17                   MS. PORTER:       Objection.           Asked and

 18   answered.

 19   BY MS. FORSTEIN:

 20          Q.       And looking back at the grid, the grid

 21   that Mr. Thomas sent you indicated that two suppliers

 22   would be supplying all of these 100 million masks; is

                                www.trustpoint.one                         800.FOR.DEPO
                              www.aldersonreporting.com                     (800.367.3376)
Daniel Kim                                                                       3/29/2021
 Case 1:20-cv-00658-LMB-IDD   Document 132-6     Filed 05/07/21   Page 7 of 7 PageID#
                                                                                   Page 99
                                     2512

  1   that right?

  2                   MS. PORTER:        Objection.         The document

  3   speaks for itself.

  4                   THE WITNESS:         To that point, I'm just

  5   verifying what is on the text because, frankly, I

  6   don't recall what happened a year ago.                       But based on

  7   the text, it appears that.                But I have no

  8   recollection of the two suppliers.

  9   BY MS. FORSTEIN:

 10          Q.       And -- understood and appreciate that

 11   clarification.          When you received this schedule on

 12   the evening of March 25th, had you previously

 13   received a delivery schedule of any kind from Blue

 14   Flame Medical?

 15          A.       I personally had not.

 16          Q.       And did Mr. Thomas tell you that he asked

 17   Blue Flame Medical's lawyer to create this delivery

 18   schedule only after he spoke with you on the evening

 19   of March 25th?

 20          A.       I don't recall, but I understood that he

 21   was putting together a schedule at my request.

 22          Q.       And did Mr. Thomas tell you that Blue

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

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