MILBERG WEISS BERSHAD
  HYNES & LERACH LLP
WILLIAM S. LERACH (68581)
ALAN SCHULMAN (128661)
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: 619/231-1058
     - and -
JEFFREY W. LAWRENCE (166806)
DAVID R. STICKNEY (188574)
222 Kearny Street, 10th Floor
San Francisco, CA 94108
Telephone: 415/288-4545

LAW OFFICES OF JAMES V.
  BASHIAN, P.C.
JAMES V. BASHIAN
500 Fifth Avenue
Suite 2700
New York, NY 10110
Telephone: 212/921-4110

WOLF POPPER LLP
STEPHEN D. OESTREICH
PATRICIA I. AVERY
ANDREW E. LENCYK
845 Third Avenue
New York, NY 10022
Telephone: 212/759-4600

Co-Lead Counsel for Plaintiffs and the Class

I, David R. Stickney, declare:

1. I am an associate with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, counsel for plaintiffs in this action. I am duly admitted to practice in the State of California and before this Court. I make this Second Declaration in Further Support of Motion for Order Staying This Action and Opposition to Defendant Harvey Wagner's Counter-Motion for Involuntary Dismissal, and I have personal knowledge of the facts asserted herein.

2. Attached hereto are true and correct copies of the following documents:

Exhibit A: Stipulation and Order, dated February 5, 1999;

Exhibit B: Letter to Jeffrey W. Lawrence from Gidon M. Caine, enclosing Stipulation and [Proposed] Order, dated February 1, 1999;

Exhibit C: In re Informix Corp. Sec. Litig., No. C 97-1289 CRB, Order (N.D. Cal. Nov. 6, 1998);

Exhibit D: David T. O'Neal Trust, Dated 4/1/77, et al. v. Vanstar Corp., et al., No. C-98-0216-MJJ, Order Denying Defendants' Motion to Preserve and Enforce the Mandatory Discovery Stay (N.D. Cal. Feb. 5, 1999);

Exhibit E: Richard A. Bader, et al. v. Electronics for Imaging, et al., No. C-97-4739 CAL, Hearing Transcript (N.D. Cal. Mar. 5, 1999);

Exhibit F: Albert. J. Copperstone, et al. v. TCSI Corporation, et al., CASE NO. 775199-2, Stipulation and [Proposed] Order Concerning the Treatment of Confidential Information (Alameda Super. Ct. Apr. 22, 1998); and

Exhibit G: Copperstone, et al. v. TCSI Corp., et al., CASE NO. 775199-2, Report and Recommendation Re Motion to Stay Discovery and Motion to Compel the Production of Documents From Third Party Ernst & Young LLP and Order Thereon (Alameda Super. Ct. Jan. 22, 1998).

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. If called as a witness, I could and would competently testify thereto. Executed this 13th day of April, 1999, at San Francisco, California.

TCSI\DRD02280.DEC

I, the undersigned, declare:

1. That declarant is and was, at all times herein mentioned, a citizen of the United States and a resident of the County of San Francisco, over the age of 18 years, and not a party to or interested in the within action; that declarant's business address is 222 Kearny Street, 10th Floor, San Francisco, California 94108.

2. That on April 13, 1999, declarant served the SECOND DECLARATION OF DAVID R. STICKNEY IN FURTHER SUPPORT OF MOTION FOR ORDER STAYING THIS ACTION AND OPPOSITION TO DEFENDANT HARVEY WAGNER'S COUNTER-MOTION FOR INVOLUNTARY DISMISSAL by depositing a true copy thereof in a United States mailbox at San Francisco, California in a sealed envelope with postage thereon fully prepaid and addressed to the parties listed on the attached Service List and that this document was forwarded to the following designated Internet site at:

3. That there is a regular communication by mail between the place of mailing and the places so addressed.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 13th day of April, 1999, at San Francisco, California.

Source: http://securities.milberg.com