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Videotaped Deposition of Michael Wong — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 160-14)

Summary

This is Exhibit 132 in Document 160-14 of Case 1:20-cv-00658, excerpts of the remote videotaped deposition via Zoom of Michael Wong, taken Tuesday, January 19, 2021. On page 202 the witness is asked about model numbers approved by the Department of Public Health and answers "I believe that's true". Asked whether the state would have accepted 100 million N95 NIOSH certified masks delivered as agreed, the witness says "If we received the masks that were agreed upon, we would have accepted them". The questioning then turns to the terms on the invoice marked Defendant's Exhibit 20.

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Cite this document

“Videotaped Deposition of Michael Wong — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (Dkt. 160-14).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cv-00658-dkt-160-14-e-d-va-7583e475d1/, SHA-256 d1cf680a95e152633975a47051634000e3ad55dee658402b56eb718424c6eb0b.

Full text

Case 1:20-cv-00658-LMB-IDD   Document 160-14   Filed 05/27/21   Page 1 of 3 PageID#
                                     4261




     EXHIBIT 132
Michael Wong                      CONFIDENTIAL                               1/19/2021
Case 1:20-cv-00658-LMB-IDD   Document 160-14 Filed 05/27/21   Page 2 of 3 PageID#
                                                                                Page 1
                                     4262

  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

                                www.trustpoint.one                     800.FOR.DEPO
                              www.aldersonreporting.com                 (800.367.3376)
Michael Wong                      CONFIDENTIAL                               1/19/2021
Case 1:20-cv-00658-LMB-IDD   Document 160-14 Filed 05/27/21   Page 3 of 3 PageID#
                                                                              Page 202
                                     4263

  1   BY MR. MITCHELL:

  2          Q.      And do you recall that those model numbers

  3   had been approved by the Department of Public Health?

  4                  MS. PORTER:        Objection.        Asked and

  5   answered.

  6                  THE WITNESS:         I believe that's true.

  7   BY MR. MITCHELL:

  8          Q.      Mr. Wong, if Blue Flame had delivered 100

  9   million N95 NIOSH certified masks that had been

 10   approved by the Department of Public Health to the

 11   state of California as agreed, would you have

 12   accepted those masks?

 13                  MS. PORTER:        Objection.        Calls for

 14   speculation.

 15                  THE WITNESS:         If we received the masks

 16   that were agreed upon, we would have accepted them.

 17   BY MR. MITCHELL:

 18          Q.      All right.        Mr. Wong, I'd like to turn

 19   your attention back to the invoice which is

 20   Defendant's Exhibit 20.             And I want to ask you about

 21   the invoice itself, in particular, the terms and it's

 22   at the top right portion of the document.                    It says

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

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d1cf680a95e152633975a47051634000e3ad55dee658402b56eb718424c6eb0b
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