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