Videotaped Deposition of Michael Wong — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 150-7)
Summary
This is Exhibit 91 in Document 150-7 of Case 1:20-cv-00658, excerpts of the remote videotaped deposition via Zoom of Michael Wong, taken Tuesday, January 19, 2021. The witness agrees that Blue Flame required prepayment on receipt of its invoice so it could secure product from suppliers, and that the invoice matched negotiations with Mr. Thomas. Questioning about an April 3rd email from Mr. Littman leads the witness to agree that none of the listed N95 models are 3M brand. The witness says he never discussed Blue Flame with anyone from the State of Maryland.
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“Videotaped Deposition of Michael Wong — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 150-7).”
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Case 1:20-cv-00658-LMB-IDD Document 150-7 Filed 05/20/21 Page 1 of 5 PageID#
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EXHIBIT 91
Michael Wong CONFIDENTIAL 1/19/2021
Case 1:20-cv-00658-LMB-IDD Document 150-7 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, :
6 Plaintiff, :
7 v. : Civil Action No.
8 CHAIN BRIDGE BANK, N.A., JOHN : 1:20-cv-00658
9 J. BROUGH and DAVID M. :
10 EVINGER, : CONFIDENTIAL
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 Tuesday, January 19, 2021
21 Videotaped Deposition via Zoom of MICHAEL
22 WONG, a witness herein, called for examination by
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Michael Wong CONFIDENTIAL 1/19/2021
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1 terms due on receipt. Do you see that?
2 A. Yes, sir.
3 Q. And you understood that Blue Flame was
4 requiring prepayment upon receipt of this invoice,
5 correct?
6 A. Yes, sir.
7 Q. Excuse me, upon your receipt of its
8 invoice, correct?
9 A. Yes, sir.
10 Q. And did you understand that Blue Flame
11 needed to receive that prepayment so that it could
12 secure the product from its suppliers?
13 MS. PORTER: Objection. Asked and
14 answered.
15 THE WITNESS: Yes.
16 BY MR. MITCHELL:
17 Q. This invoice attached to Defendant's
18 Exhibit 20 was consistent with your negotiations with
19 Mr. Thomas, correct?
20 MS. PORTER: Objection. Asked and
21 answered.
22 THE WITNESS: Yes.
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Michael Wong CONFIDENTIAL 1/19/2021
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1 Exhibit 67.
2 MR. MITCHELL: Greg, you may need to
3 republish that one in the chat.
4 BY MR. MITCHELL:
5 Q. Mr. Wong, please let me know when you have
6 that one in front of you. Apologies.
7 MR. MITCHELL: Greg, could you please
8 republish Defendant's Exhibit 27.
9 THE WITNESS: Are we looking at Exhibit 67
10 or Exhibit 27?
11 BY MR. MITCHELL:
12 Q. Well, if you have Exhibit 67 in front of
13 you, very quickly -- do you have it in front of you?
14 A. Yes, sir.
15 Q. And on the first page of Exhibit 67, which
16 is the email from Mr. Littman to you on April 3rd,
17 2020, you see those same four models of N95 masks
18 listed that were previously listed in the invoice and
19 in your purchase order, correct?
20 A. Yes, sir.
21 Q. And none of those masks were 3M brand
22 masks, correct?
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Michael Wong CONFIDENTIAL 1/19/2021
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1 MS. PORTER: Objection. Asked and
2 answered.
3 THE WITNESS: I don't remember at the time
4 what model numbers were associated with what brands.
5 BY MR. MITCHELL:
6 Q. Okay. Sitting here today, you understand
7 that none of those models of masks are 3M brand
8 masks, correct?
9 A. Yes, sir.
10 Q. And on the second page of that email from
11 Mr. Littman, do you see, Mr. Wong, that Mr. Littman
12 writes, "Also here is the information for the State
13 of Maryland. Maryland has placed a significant order
14 with Blue Flame."
15 And then he lists Danny Mays, director,
16 Office of State Procurement, Maryland Department of
17 General Services.
18 Do you see that?
19 A. Yes, sir.
20 Q. Did you ever discuss Blue Flame with any
21 representative of the State of Maryland?
22 A. No, I did not.
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