STIPULATION CONSOLIDATING ACTIONS AND RELATED MATTERS AND [PROPOSED] ORDER THEREON

RICHARD SEEBORG, District Judge.

WHEREAS, there are presently three related shareholder derivative actions against certain of the officers and directors of OCZ Technology Group, Inc. ("OCZ") on file in this Court;

WHEREAS, in an effort to assure consistent rulings and decisions and the avoidance of unnecessary duplication of effort, counsel for plaintiffs as well as counsel for defendants in the related OCZ shareholder derivative actions currently on file in this Court enter into this stipulation. The counsel are: (1) Robbins Arroyo LLP on behalf of plaintiffs Ian Cassiman and Clair Vanderschaaf; (2) Robbins Geller Rudman & Dowd LLP on behalf of plaintiff Robert L. Morton; (3) and Wilson Sonsini Goodrich & Rosati on behalf of defendants Arthur F. Knapp, Jr., Ralph H. Schmitt, Adam J. Epstein, Richard L. Hunter, Russell J. Knittel, and nominal defendant OCZ;

WHEREAS, the parties have met and conferred and agree that the actions should be consolidated under Rule 42(a) of the Federal Rules of Civil Procedure and that consolidation of the actions will promote judicial economy and preserve both public and private resources; and

WHEREAS, plaintiffs and defendants agree that it would be duplicative and wasteful of the Court's resources for defendants named in plaintiffs' shareholder derivative actions to have to respond to the individual complaints prior to the agreed upon consolidation;

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED by plaintiffs and defendants, through their respective counsel of record, as follows:

1. The following actions are hereby related and consolidated for all purposes, including pre-trial proceedings and trial:

2. Every pleading filed in the consolidated action, or in any separate action included herein, shall bear the following caption:

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

3. The files of the consolidated action shall be maintained in one file under Master File No. C-12-05556-RS.

4. Defendants are not required to respond to the complaint in any action consolidated into this action, other than a consolidated complaint or a complaint designated as the operative complaint.

5. Plaintiffs shall file a Consolidated Complaint ("Consolidated Complaint") by January 25, 2013, unless otherwise agreed upon by the parties or ordered by the Court. The Consolidated Complaint shall be the operative complaint and shall supersede all complaints filed in any of the actions consolidated herein. Defendants shall respond to the Consolidated Complaint within sixty days after service, unless otherwise agreed by the parties or ordered by the Court. In the event that defendants file any motions directed at the Consolidated Complaint, the opposition and reply briefs shall be filed within sixty and thirty days, respectively, of the motions, unless otherwise agreed upon by the parties or ordered by the Court. confer to select a hearing date.

6. The Co-Lead Counsel for plaintiffs for the conduct of these consolidated actions are:

7. Plaintiffs' Co-Lead Counsel shall have sole authority to speak for plaintiffs in matters regarding pre-trial procedure, trial, and settlement and shall make all work assignments in such manner as to facilitate the orderly and efficient prosecution of this litigation and to avoid duplicative or unproductive effort.

8. Plaintiffs' Co-Lead Counsel shall be responsible for coordinating all activities and appearances on behalf of plaintiffs. No motion, request for discovery, or other pre-trial or trial proceedings shall be initiated or filed by any plaintiff except through plaintiffs' Co-Lead Counsel.

9. Plaintiffs' Co-Lead Counsel shall be available and responsible for communications to and from this Court, including distributing orders and other directions from the Court to counsel. Plaintiffs' Co-Lead Counsel shall be responsible for creating and maintaining a master service list of all parties and their respective counsel.

10. Defendants' counsel may rely upon all agreements made with plaintiffs' Co-Lead Counsel, or other duly authorized representative of plaintiffs' Co-Lead Counsel, and such agreements shall be binding on all plaintiffs.

11. Defendants' counsel signing this stipulation shall appear for and accept service on behalf of all their clients who have not already been served.

12. Defendants take no position as to the appointment of Co-Lead Counsel.

13. This Order shall apply to each case, arising out of the same or substantially the same transactions or events as these cases, which is subsequently filed in, remanded to or transferred to this Court.

14. When a case which properly belongs as part of the In re OCZ Technology Group, Inc. Shareholder Derivative Litigation, Lead Case No. C-12-05556-RS, is hereafter filed in the Court or transferred here from another court, this Court requests the assistance of counsel in calling to the attention of the clerk of the Court the filing or transfer of any case which might properly be consolidated as part of the In re OCZ Technology Group, Inc. Shareholder Derivative Litigation, Lead Case No. C-12-05556-RS, and Co-Lead Counsel are to assist in assuring that counsel in subsequent actions receive notice of this Order. All such related derivative actions that are subsequently filed in, or transferred to, this District shall be consolidated into this action.

15. Pursuant to Fed. R. Civ. P. 5(b)(2)(E)-(F), service by e-mail transmission shall be permitted in addition to service via ECF notification. For non-CM/ECF participants, service shall be deemed effective upon transmission of the service e-mail.

I, George C. Aguilar, am the ECF User whose ID and password are being used to file this Stipulation Consolidating Related Actions, Appointing Co-Lead Counsel and Related Matters and [Proposed] Order Thereon. In compliance with General Order No. 45, X.B., I hereby attest that Diane Walters and Travis E. Downs, III have concurred in this filing.

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ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.