Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-00593-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE In re INACOM CORP., et al., Debtors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

INACOM CORP., on behalf of all affiliated Debtors, Plaintiffs, v. INGRAM ENTERTAINMENT INC., as successor in interest to NASHVILLE COMPUTER LIQUIDATORS, L.P., Defendant.

Civil Action No. 04-593 (GMS)

DEFENDANT INGRAM ENTERTAINMENT INC.'S PROPOSED JURY VOIR DIRE QUESTIONS Defendant Ingram Entertainment Inc. ("Ingram"), pursuant to D. Del. LR 47.1(a) and the Court's Scheduling Order, files the attached proposed jury voir dire questions in triplicate and on diskette.

DATED: August 15, 2005 By: /s/ Thomas G. Macauley_____ Thomas G. Macauley (ID No. 3411) ZUCKERMAN SPAEDER LLP 919 Market Street, Suite 990 P.O. Box 1028 Wilmington, Delaware 19899-1028 Tel.: (302) 427-0400 Fax: (302) 427-8242 -and-1-

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Jonathan P. Hersey (CA Bar No. 189240) Scott B. Lieberman (CA Bar No. 208764) SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 650 Town Center Drive, 4th Floor Costa Mesa, CA 92626 Telephone: (714) 513-5100 Facsimile: (714) 513-5130 Attorneys for Defendant INGRAM ENTERTAINMENT INC., as successor in interest to NASHVILLE COMPUTER LIQUIDATORS, L.P.

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE In re INACOM CORP., et al., Debtors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

INACOM CORP., on behalf of all affiliated Debtors, Plaintiffs, v. INGRAM ENTERTAINMENT INC., as successor in interest to NASHVILLE COMPUTER LIQUIDATORS, LP, Defendant.

Civil Action No. 04-593 (GMS)

JURY VOIR DIRE QUESTIONS 1. [Separately as to each individual panel member]: Please tell us your name and the

occupation of yourself and your spouse? 2. To the panel as a group: Do you have any personal knowledge regarding the parties

or the facts of this case? If so, please explain. 3. Have you read, seen or heard anything from anyone else about this case or in any

way relating to this case? If so, please explain. 4. 5. describe. 6. Have you had any training in accounting? If so, please describe. -3Have you had any legal training or experience? If so, please describe it. Have you had any experience with any bankruptcy proceeding? If so, please

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7.

Have you, or have members of your family, had any relationship such as: (1)

present or former employee; (2) consultant; (3) friend; or (4) other, with any of the following: a. b. c. d. e. f. g. h. Inacom Corporation; Vanstar Corporation; Nashville Computer Liquidators, L.P. Dell, Inc.; Tech Data Corp.; Lexmark International, Inc.; Ingram Entertainment, Inc.; Bridge Associates, L.L.C., (formerly known as Restoration Management Company, L.L.C.); i. j. k. l. m. n. Wiser LLP; Houlihan, Lokey, Howard & Zukin; Deutsche Bank; Duff & Phelps; Sasco Hill Advisors; or Alix Partners?

If so, please explain. 8. During the course of this case, various witnesses may be called to testify on behalf

of the parties. The parties are not required to call all of these witnesses and might decide not to call some of the witnesses and may instead call other witnesses. Are you, or is any member of your family or any friend of yours related to or acquainted with, or do you have any association whatsoever with any of the following people, who may be witnesses in this case: -4-

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a. b. c. d. e. f. g. h. i. j. k. l. m. If so, please explain. 9.

Elaine G. Agee; Thomas J. Fitzpatrick; Lazarus Krikorian; Richard C. Oshlo; Gerry A. Gagaliardi; Dean Vomero; Francis X. Devine; Michael L. Newsom; Stuart A. Gollin; Neil Gilmour; Steven Gadsey; Jason Fensterstock; or Richard Whalen?

Do you know any of the following attorneys who represent the parties in this case: a. Andrew Caine of the firm Pachulski, Stang, Ziehl, Young, Jones &

Weintraub PC; b. c. or d. 10. Thomas Macauley of the firm Zuckerman Spaeder LLP. Jeffrey Nolan of the same Pachulski firm; Jonathan Hersey of the firm Sheppard, Mullin, Richter & Hampton LLP;

Have you or any member of your immediate family ever been employed or

represented by any of these attorneys or their firms? -5-

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11.

Do you have any medical condition which would not allow you to properly carry

out your duties as a juror? 12. It is anticipated that this civil trial will take approximately five days. Would there

be any great undue hardship on you to serve as a juror in this case? 13. Do you know any fact or circumstance that you believe might make you an

unsuitable juror for this particular case? 14. Do you know of any reason you could not serve as a juror in this case?

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