Remote Videotaped Deposition of Ethan Bearman — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 150-1)
Summary
This is Exhibit 85 in Document 150-1 of Case 1:20-cv-00658, containing the cover page and excerpts of the remote videotaped deposition of Ethan Bearman, taken Thursday, January 21, 2021, in Blue Flame Medical LLC v. Chain Bridge Bank. The testimony covers what the witness understood about Blue Flame Strategies: consulting and political strategy for clients, with names such as Velox Medical, NeVap and Glymate, plus hospitals. The witness says its functions were helping manage grant money and connecting medical supply companies with buyers.
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“Remote Videotaped Deposition of Ethan Bearman — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 150-1).”
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Case 1:20-cv-00658-LMB-IDD Document 150-1 Filed 05/20/21 Page 1 of 5 PageID#
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EXHIBIT 85
Ethan Bearman CONFIDENTIAL 1/21/2021
Case 1:20-cv-00658-LMB-IDD Document 150-1 Filed 05/20/21 Page 2 of 5 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 150-1 Filed 05/20/21 Page 3 of 5 PageID#
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1 Q And that was in early February of 2020?
2 A I don't recall if it was early
3 February, but it was February 2020.
4 Q Okay. And at that time, what did you
5 understand to be Blue Flame Strategies' business?
6 A I understood it to be consulting and
7 political strategy helping clients.
8 Q And helping what kinds of clients?
9 A I don't -- I don't know that I knew in
10 February 2020.
11 Q Was there a time when you came to learn
12 what kinds of clients Blue Flame Strategies
13 intended to help?
14 A Yes.
15 Q And about how long after filing
16 paperwork in the State of Delaware did you come to
17 that understanding?
18 A I don't recall specifically. It could
19 have been days. It could have been weeks.
20 Q Okay.
21 A But in that time -- days or weeks
22 afterwards.
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 150-1 Filed 05/20/21 Page 4 of 5 PageID#
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1 Q Whenever it was that you came to
2 understand the kinds of clients that Blue Flame
3 Strategies intended to help, what did you -- what
4 understanding did you come to?
5 A It was a broad range of clients. I --
6 I -- I'm not sure I know how to tell you exactly
7 what I learned at that point in time. It -- it
8 was -- I know names of some companies, but I don't
9 know how to categorize it the way you're asking
10 me. I'm just not sure.
11 Q Well, what were the names of some of
12 the companies?
13 A So apologies. I'm not sure if I'm
14 going to mix up clients versus other -- I'm going
15 to use clients in a very generic sense, so it
16 would be Velox Medical, NeVap or NeVap, Glymate.
17 There were a number of hospitals. There were -- I
18 want to say that there was discussion of
19 government entities even -- but in that -- that
20 time frame that we're generally speaking, like I
21 said, it's this broad range that's hard to
22 categorize.
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 150-1 Filed 05/20/21 Page 5 of 5 PageID#
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1 That is about the best I can do right
2 now.
3 Q Okay. And, generally speaking, what
4 was Blue Flame Strategies going to help these
5 clients with?
6 A There were kind of two primary
7 functions, to the best of my recollection, which
8 were, one, should an entity receive grant money,
9 they were going to help them manage the grants and
10 kind of keep track of it for distribution
11 purposes.
12 And the other was connecting
13 suppliers -- excuse me, not -- not limited to PPE
14 but medical supply companies with buyers.
15 Q And the companies you listed, were
16 those suppliers, buyers or some of both?
17 MR. GUSSMAN: Objection to form.
18 THE WITNESS: I mean, all three that
19 you said and additional categories.
20 BY MR. MADDEN:
21 Q Okay. You mentioned Velox Medical?
22 A Yes.
www.trustpoint.one 800.FOR.DEPO
www.aldersonreporting.com (800.367.3376)
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- 150-att1.pdf
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