Free Motion in Limine - District Court of Delaware - Delaware

Case 1 :04—cv—00593-Gl\/IS Document 58-4 Filed 08/15/2005 Page 1 of 2
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 No. 04-593 GMS 4
Debtors, _
Plaintiff, Adversary Case No. 02-3960 (PJW)
v. Bankruptcy Case No. 00-2426 (PJW) _-
INGRAM ENTERTAINMENT, INC., as [MOTION IN LIMINE NO. 3 OF 4]
successor in interest to NASHVILLE
COMPUTER LIQUIDATORS,
Defendant. _-
DECLARATION OF JEFFREY P. NOLAN -
IN SUPPORT OF PLAlNTIFF’S MOTION IN LIMINE TO EXCLUDE THE EXPERT ‘
TESTIMONY OF STEPHEN GADSEY AT TIME OF TRIAL
TO THE CLERK OF THE ABOVE-ENTITLED COURT:
I, Jeffrey P. Nolan, declare: j
l. The matters stated herein are based on my own personal knowledge, and if
called, I could and would competently testify thereto.
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
District of Delaware I am of counsel to Pachulski, Stang, Ziehl, Young, Jones & Weintraub
P.C., attorneys for plaintiff Inacom Corporation. I make this declaration in support of Plaintiffs ii,
Motion In Limine To Exclude The Expert Testimony Of Stephen Gadsey At Time Of Trial.
3. Attached as Exhibit A is a true and correct copy of Ingram’s Expert
Disclosure which was served on this law firm during the course ofthe litigation.
42l25-003\DOCS_LA:l432S6.l

Case 1:04—cv—00593-Gl\/IS Document 58-4 Filed 08/15/2005 Page 2 of 2 l_
4. Attached hereto as Exhibit B is a true and correct copy of excerpts from
the Deposition of Stephen Gadsey taken in the instant case by the undersigned on August 3,
2005. Mr. Gadsey testified that he was prepared to give his final opinions and conclusions.
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 12, 2005, at Los Angel ali mia.
Jef olan ,
42:25-00axoocs_LA;142zss.1 2

Case 1:04-cv-00593-GMS

Document 58-4

Filed 08/15/2005

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Case 1:04-cv-00593-GMS

Document 58-4

Filed 08/15/2005

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