Free Motion in Limine - District Court of Delaware - Delaware

Case 1 :04—cv—00593-Gl\/IS Document 59-4 Filed 08/15/2005 Page 1 of 2 :0
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re INACOM CORP., et al., .
INACOM CORP., on behalf of all affiliated Civil Action N0. 04-593 GMS ·
Debtors,
Plaintiff, Adversary Case No. 02-3960 (PIW)
v. Bankruptcy Case No. 00-2426 (PJW) _
IN GRAM ENTERTAINMENT, INC., as [MOTION IN LIMINE NO. 4 OF 4]
successor in interest to NASHVILLE
COMPUTER LIQUIDATORS,
Defendant.
DECLARATION OF JEFFREY P. NOLAN IN SUPPORT
OF PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE TESTIMONY
FROM PERSONS OTHER THAN THE PERSON DESIGNATED BY
DEFENDANT AS MOST KNOWLEDGEABLE ON THE TOPIC ‘
TO THE CLERK OF THE ABOVE-ENTITLED COURT:
I, Jeffrey P. Nolan, declare:
1. The matters stated herein are based on my own personal knowledge, and if A
called, I could and would competently testify thereto. t
2. I am an attorney licensed to practice before all of the courts of the State of _
California and am admitted to practice pro hac vice in the United States Bankruptcy Court for the I
District of Delaware I am of counsel to Pachulski, Stang, Ziehl, Young, Jones & Weintraub
P.C., attomeys for plaintiff Inacom Corporation. I make this declaration in support of Plaintiff’s
Motion In Limine To Exclude Testimony From Persons Other Than The Person Designated By l
Defendant As Most Knowledgeable On The Topic.
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A -. ' Case 1 :04—cv—0O593;GiIl/iS Document 59-4 Pilecl 08/15/2005 Page I2 off n L. A A F
3. Attached hereto as Exhibit A is a true and correct copy of the Notice of
Deposition of the Person Most Knowledgeable dated January 7, 2005 and the Continuance of
Notice of Deposition of Person Most Knowledgeable.
4. Attached hereto as Exhibit B are true and correct copies of portions of the l
Deposition of Steven Gadsey taken on August 3, 2005. Plaintiff attaches a draft copy of the
Deposition of Mr. Gadsey as the final version has not been received from the court reporter as of
this date. The deposition was taken on August 3, 2005. 5
5. In this adversary, Ingram designated Steven Gadsey as the Person Most A
Knowledgeable. There were no other substantive discussions raised by Ingram as to any other
individual who could testify on the categories outlined in the Notice of Deposition of Person T
Most Knowledgeable.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed on August _|f{;, 2005, at Los A ; 5 •’ H omia.
{Wl
er · Nolan
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Case 1:04-cv-00593-GMS

Document 59-4

Filed 08/15/2005

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Case 1:04-cv-00593-GMS

Document 59-4

Filed 08/15/2005

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