MILBERG WEISS BERSHAD

HYNES & LERACH LLP

KEITH F. PARK (54275)

ALAN SCHULMAN (128661)

MARK SOLOMON (151949)

JOY ANN BULL (138009)

600 West Broadway, Suite 1800

San Diego, CA 92101

Telephone: 619/231-1058

- and -

KIMBERLY C. EPSTEIN (169012)

222 Kearny Street, 10th Floor

San Francisco, CA 94108

Telephone: 415/288-4545

WEISS & YOURMAN

JOSEPH H. WEISS

JACK I. ZWICK

551 Fifth Avenue

Suite 1600

New York, NY 10176

Telephone: 212/682-3025

- and -

KEVIN J. YOURMAN (147159)

10940 Wilshire Blvd.

24th Floor

Los Angeles, CA 90024

Telephone: 310/208-2800

BERNSTEIN LIEBHARD & LIFSHITZ

MEL E. LIFSHITZ

274 Madison Avenue

New York, NY 10016

Telephone: 212/779-1414

Attorneys for Plaintiffs

BROOKE GRAUBART, et al., On Behalf of

Themselves and All Others Similarly Situated,

Plaintiffs,

vs.

INSIGNIA SOLUTIONS PLC, et al.,

Defendants.

___________________________________

No. C-97-20265-JW(EAI)

CLASS ACTION

DATE: April 20, 1998

TIME: 9:00 a.m.

COURTROOM: The Honorable

James Ware

I, KEITH F. PARK, declare as follows:

1. I am a member of the firm of Milberg Weiss Bershad Hynes & Lerach LLP. I am submitting this declaration in support of my firm's application for an award of attorneys' fees in connection with services rendered in the above-entitled action and the reimbursement of expenses incurred by my firm in the course of this litigation.

2. This firm is counsel of record for plaintiffs.

3. The identification and background of my firm and its partners is attached hereto as Exhibit A.

4. My firm expended a total of $250,648.75 in unreimbursed expenses in connection with the prosecution of this litigation. These expenses are broken down as follows:

EXPENSES 

From Inception through March 31, 1998 

Dow Jones, Lexis, Westlaw, Online Library Research              $ 11,845.86

Experts/Consultants/Investigators                                150,204.90

Filing and Legal Fees (including attorney

 services and witness fees)                                        3,337.15

Meals, Hotel and Transportation                                   18,307.76

Mediation Fees                                                     4,990.00

Messenger, Courier, Federal Express                                1,304.98

Paralegal                                                         43,020.00

Photocopying                                                      12,605.18

Postage                                                              435.15

Telephone, Facsimile                                               4,597.77

TOTAL:                                                          $250,648.75

5. The expenses incurred pertaining to this case are reflected in the books and records of this firm. These books and records are prepared from expense vouchers and check records and are an accurate record of the expenses incurred.

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

Exhibit B: Berley, et al. v. Sculley, et al., Civ. No. C-91-20270-JW (PVT) (N.D. Cal. April 20, 1992);

Exhibit C: In re Altera Corp. Sec. Litig., Master File No. C-92-20399-JW(EAI) (N.D. Cal. July 29, 1994);

Exhibit D: Strassman, et al. v. Fresh Choice, Inc., et al., Civil No. 95-20017 SW (N.D. Cal. October 10, 1997);

Exhibit E: Stack, et al. v. Lobo, et al., No. C-95-20049-SW (EAI) (N.D. Cal. April 4, 1997);

Exhibit F: Slomovics v. Gallogly, et al., No. C-94-2262-CAL (N.D. Cal. June 13, 1996);

Exhibit G: In re AT&E Corporation Sec. Litig., Master File No. C-90-3265-CAL (N.D. Cal. July 13, 1992);

Exhibit H: In re Genentech, Inc. Sec. Litig., Master File No. C-88-4038 DLJ (N.D. Cal. February 21, 1991);

Exhibit I: In re Ross Systems Sec. Litig., Master File No. C-94-0017-DLJ (WDB) (N.D. Cal. December 13, 1995);

Exhibit J: Leonard v. NetFrame Systems, Inc., et al., C-95-0238-DLJ (N.D. Cal. March 20, 1996);

Exhibit K: In re Seagate Technology Sec. Litig., Master File No. C-84-20756(A)-WAI (N.D. Cal. August 14, 1991);

Exhibit L: In re ASK Computer Systems Sec. Litig., Master File No. C-85-20207(A)-WAI(EAI) (N.D. Cal. November 16, 1992);

Exhibit M: In re Advanced Micro Devices Sec. Litig., Master File No. C-93-20662-EAI (N.D. Cal. December 12, 1994);

Exhibit N: Fisher, et al. v. Acuson Corp., et al., No. C-93-20477-EAI (N.D. Cal. October 7, 1996);

Exhibit O: Cooper, et al. v. Hwang, et al., No. C-86-20146-WAI (N.D. Cal. March 5, 1991);

Exhibit P: Perkins, et al. v. Preletz, et al., Civ. No. 90-20026-WAI (N.D. Cal. October 1, 1991);

Exhibit Q: Shields v. Smith, et al., Civ. No. C-90-0349-FMS (N.D. Cal. Dec. 21, 1993);

Exhibit R: Levy, et al. v. Eletr, et al., No. C-88-3457-FMS (N.D. Cal. June 20, 1994);

Exhibit S: Roe, et al. v. Hospital Staffing Services, Inc., et al., No. C-92-4101-CW (N.D. Cal. June 30, 1995);

Exhibit T: In re Sam & Libby Inc. Sec. Litig., Master File No. 92-1564-WHO (N.D. Cal. August 1, 1994);

Exhibit U: Empirical Study of Class Actions in Four Federal District Courts, Final Report to the Advisory Committee on Civil Rules, (Federal Judicial Center 1996); and

Exhibit V: Recent Trends III: What Explains Settlements in Shareholder Class Actions? (National Economic Research Associates June 1995).

I declare under penalty of perjury that the foregoing is true and correct. Executed this 8th day of April, 1998, at San Diego, California.

___________________________________

KEITH F. PARK

INSIGN-2\DLM13121.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 Diego, over the age of 18 years, and not a party to or interested in the within action; that declarant's business address is 600 West Broadway, Suite 1800, San Diego, California 92101.

2. That on April 10, 1998, declarant served the DECLARATION OF KEITH F. PARK IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS' FEES AND REIMBURSEMENT OF EXPENSES by depositing a true copy thereof in a United States mailbox at San Diego, 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:

http://securities.milberg.com

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 10th day of April, 1998, at San Diego, California.

______________________________

DANELLE L. McNERTNEY