Joseph J. Tabacco, Jr . (75484) Julie Bai (227047) 2 BERMAN DeVALERIO PEASE TABACCO BURT & PUCILLO 425 California Street, Suite 2025 San Francisco, California 94104-2205 4 Telephone: (415) 433-3200 Facsimile: (415) 433-6382 Email: jtabacco@bermanesq .com 6 Stanley M. Grossman Marc I. Gross 7 POMERANTZ HAUDEK BLOCK GROSSMAN & GROSS LLP 8 100 Park Avenue, 26' Floor New York, New York 10017-5516 9 Telephone: (212) 661 -1100 Facsimile: (212) 661-8665 10 Email : smgrossman@pomlaw .com Email: migross@pomlaw .com 11 [Names of additional counsel appear on signature page ] 12 Attorneys for Plaintiffs Louisiana School Employees' 13 Retirement System and Louisiana District Attorneys' Retirement System 14 UNITED STATES DISTRICT COURT NORTHER DISTRICT OF CALIFORNIA 15 ------ ------------------------------------------------ x 16 JAMES M. BAKER, On Behalf of Himself Civil Action No . 05-cv-00295-PJH and All Others Similarly Situated, Honorable Phyllis J. Hamilton 17 Plaintiff, DECLARATION OF JOSEPH J. 18 TABACCO IN SUPPORT OF -vs- LOUISIANA SCHOOL 19 EMPLOYEES' RETIREMENT SILICON STORAGE TECHNOLOGY, SYSTEM AND LOUISIANA 20 INC., JACK LAI, BING YEH, YASUSHI DISTRICT ATTORNEYS' CHIKAGAMI, and ISAO NOJIMA, RETIREMENT SYSTEM'S 21 MOTION T 0 CONSOLIDATE Defendants . RELATED ACTIONS, BE 22 APPOINTED LEAD PLAINTIFFS AND APPROVAL OF LEAD 23 COUNSEL AND LIAISON COUNSEL 24 Location: Courtroom 3 25 Hearing Date : April 27, 2005 Hearing Time : 9:00 a.m 26 x 27 28 [ OS-cv-00295-PJH ] TABACCO DELL ISO LO UISIANA SCHOOL EMPLOY EES' RETIREMENT SYSTEM AND LOUISIANA DISTRICT ATTORNEYS' RETIREMENT SYSTEM'S MTN TO CONSOLIDATE RELATED ACTIONS, BE APPOINTED LEAD PLNTFS & APPROVAL OF LEAD COUNSEL & LI AISON COUNSEL 1 -------------------------------------------------------x SOPHIA GROBLER, on behalf of hersel f 2 and all others similarly situated, 3 Plaintiff, 4 -vs- Civil Action Na. 05-cv-00376-PJH Honorable Phyllis J . Hamilton 5 SILICON STORAGE TECHNOLOGY, INC., JACK LAI, BING YEH, YASHUSHI 6 CHIKAGAMI, and ISAO NOJIMA , 7 Defendants . ------------------------------------------------------- x 8 ROY TALMO, Individually and on Behal f of All Others Similarly Situated, 9 Plaintiff, 10 -vs- Civil Action No . 05-cv-00390-PJH 11 Honorable Phyllis J. Hamilton SILICON STORAGE TECHNOLOGY, 12 INC ., BING YEH, JACK K. LAI, ISAO NOJIlVIA, and YASUSHI CHIKAGAMI , 13 Defendants . 14 -------------------------------------------------------x GARY HUNT, Individually and On Behal f 15 of All Others Similarly Situated, 16 Plaintiff, 17 -vs- Civil Action Na. 05-cv-00408-PJH Honorable Phyllis J. Hamilton 18 SILICON STORAGE TECHNOLOGY, INC., BING YEH, JACK K. LAI, and 19 YAW-WEN HU, 20 Defendants . ---------------- --------------------------------------- x 21 PAT A. DICINTIO, Individually and on behalf of all others similarly situated, 22 Plaintiff, 23 -vs- Civil Action No. 05-cv-00708-PJH 24 Honorable Phyllis J. Hamilton SILICON STORAGE TECHNOLOGY, 25 INC ., BING YEH, YAW-WEN HU, and JACK K. LAI, 26 Defendants . 27 ----x 28 [ OS-cv-OQ295-PJH ] TABACCO DECL ISO LOUISIANA SCHOOL EMPLOYEES' RETIR EMENT SYSTEM AND LOUISIANA DI STRICT ATTORNEYS' RETIREMENT SYSTEM'S MTN TO CONSOLIDATE RELATED ACTIONS, BE APPOINTED LEAD PLNTFS & APPROVAL OF LEAD COUNSEL & LIAISON COUNSEL -2- 1 I, Joseph J. Tabacco, Jr . declare as follows : 2 1 . I am a partner in Berman DeValerio Pease Tabacco Burt & Pucillo, proposed 3 liaison counsel for the Louisiana School Employees' Retirement System and Louisiana District 4 Attorneys' Retirement System (the "Louisiana Funds") . I make this declaration in support of the 5 Louisiana School Employees' Retirement System and Louisiana District Attorneys' Retirement 6 System's Motion to Consolidate the Related Actions, Be Appointed Lead Plaintiffs and 7 Approval of Lead Counsel and Liaison Counsel under § 21D(a)(3)(B) of the Securities 8 Exchange Act of 1934. 9 2. Attached hereto as Exhibit A is a true and correct copy of the first Notice of 10 Pendency of this action published on Business Wire pursuant to the PSLRA . 11 3 . Attached hereto as Exhibit B is a true and correct copy of the Louisiana School 1 2 Employees Retirement System's Certification pursuant to 15 U .S .C. § 78u-4(a){2}(A)(I) . 13 4. Attached hereto as Exhibit C is a true and correct copy of the Louisiana District 14 Attorneys' Retirement System's Certification pursuant to 15 U .Q.C. § 78u-4(a)(2)(A)(I) . 15 5 . Attached hereto as Exhibit D is the resume of Pomerantz Haudek Bloc k 16 Grossman & Gross LLP. 17 6. Attached hereto as Exhibit E is the resume of Berman DeValerio Pease Tabacc o 18 Burt& Pucillo . 19 I declare under penalty of perjury that the foregoing is true and correct . Executed this 20 22nd day of March, 2005, in San Francisco, California . 21 22 Is/ Joseph J. Tobacco, Jr. 23 Joseph J. Tobacco, Jr. (75484) 24 25 26 27 28 [ 45-cv-00295-P7H ] TABACCO DECL ISO LOUISIANA SC HOOL EMPLOYEES' RETIREMENT SYSTEM AND LOUISIANA DISTRICT ATTORNEYS' RETIREMENT SYSTEM'S MTN TO CONSOLIDATE RELATED ACTIONS, BE APPOINT ED LEAD PLNTFS & APPROVAL OF LEAD COUNSEL & LIAISON COUNSEL -3- EXHIBIT A } 1 of 2 BUS Lerach Coughlin Stoia Geller Rudman & Robbins LLP Files Class Jan 21 2005 8 :55 Action Suit Against Silicon Storage Technology, Inc . SAN DIEGO--(BUSINESS WIRE)--Jan . 21, 200 5 Lerach Coughlin Stoia Geller Rudman & Robbins LLP ("Lerach Coughlin") (http ://www .lerachlaw .com/cases/siliconstorage/) today announced that a class action has been commenced in the United States District Court for the Northern District of California on behalf of purchasers of Silicon Storage Technology, Inc . ("Silicon Storage") (NASDAQ :SSTI) common stock during the period between March 30, 2004 and December 20, 2004 (the "Class Period"} . If you wish to serve as lead plaintiff, you must move the Court no later than 60 days from today . If you wish to discuss this action or have any questions concerning this notice or your rights or interests, please contact plaintiff's counsel, William Lerach or Darren Robbins of Lerach Coughlin at 800/449-4900 or 619/231- 1 058, or via e-mail at wsl@lerachlaw .com . If you are a member of this class, you can view a copy of the complaint as filed or join this class action online at http ://www .lerachlaw .com/cases/siliconstorage/ . Any member of the purported class may move the Court to serve as lead plaintiff through counsel of their choice, or may choose to do nothing and remain an absent class member . The complaint charges Silicon Storage and certain of its officers and directors with violations of the Securities Exchange Act of 1934 . Silicon Storage is a supplier of flash memory semiconductor devices for the digital consumer, networking, wireless communications and Internet computing markets . The complaint alleges that during the Class Period, defendants issued false and misleading statements regarding the Company's business and prospects . The true facts, which were known by each of the defendants but concealed from the investing public during the Class Period, were as follows : (a) the Company's sales and margins were being materially impacted by Macronix and Intel actively lowering average selling prices ; (b) the Company was not on track to achieve Q4 profitability, but rather losses ; {c} the Company's gross margin projections were overstated by at least 1,000% ; (d) the Company's accounting during the Class Period was false and misleading ; and (e) as a result, the Company's Q4 estimates of revenue of $120-$130 million and income of $0 .10 to $0 .14 per share were grossly inflated and the Company's reported assets were materially overstated . As a result of the defendants' false statements, Silicon Storage's stock traded at inflated prices during the C1ass,Period, increasing to as high as $ 1 7 .32 on April 19, 2004, whereby the Company's top officers and directors sold more than $2 .9 million worth of their own shares . On December 20, 2004, the Company issued a press release announcing that "its revenue in the fourth quarter is expected to be between $102 and $108 million versus previous guidance of $120 to $130 Copyright (c) 2005 2 of 2 BUS Lerach Coughlin Stoia Geller Rudman & Robbins LLP Files Class Jan 21 2005 8 :55 million . Due to current market conditions, the company expects to record an inventory charge of between $20 and $25 million for excess inventory and to write certain products down to their current estimated market values ." On this news, the Company's shares plummeted from $7 .00 to $5 .43 per share . Plaintiff seeks to recover damages on behalf of all purchasers of Silicon Storage common stock during the Class Period (the "Class") . The plaintiff is represented by Lerach Coughlin, which has expertise in prosecuting investor class actions and extensive experience in actions involving financial fraud . Lerach Coughlin, a 140-lawyer firm with offices in San Diego, San Francisco, Los Angeles, New York, Boca Raton, Washington, D .C ., Houston, Philadelphia and Seattle, is active in major litigations pending in federal and state courts throughout the United States and has taken a leading role in many important actions on behalf of defrauded investors, consumers, and companies, as well as victims of human rights violations . Lerach Coughlin lawyers have been responsible for more than $20 billion in aggregate recoveries . The Lerach Coughlin Web site (http ://www .lerachlaw .com) has more information about the firm . CONTACT : Lerach Coughlin S t oa. a Geller Rudman & Robbins LLP William Lerach, 800-449-49 0 0 wsl@ lerachlaw .com -0- Jan/21/2005 16 :55 GMT Copyright (c) 2005 EXHIBIT B MAR 22 '05 17 :33 FR PNBGn TO 1 41 54336382 P .e8i14 GERTIFICATZON OF PLAIIJTiF'k' PURSUANT TO FEDERAL SECLLR=S LAWS i, Warren D. Ponder, make this declaration pursuant to Section 21D(a)(2) of the Securities Exchange Act of 1934 . 1 . 1 have reviewed the Complaint against Silicon Storage Technologies, Inc .