UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION MARGARET B. ADAM, On Behalf of Herself ) No. C-93-20399-RMW(EAI) and All Others Similarly Situated, ) ) CLASS ACTION Plaintiff, ) ) vs. ) ) SILICON VALLEY BANCSHARES, et al., ) ) Defendants. ) NOTICE OF SETTLEMENT OF CLASS ACTION WITH DELOITTE & TOUCHE LLP TO: ALL PERSONS WHO PURCHASED THE COMMON STOCK OF SILICON VALLEY BANCSHARES ("SVB") DURING THE PERIOD BEGINNING JANUARY 9, 1991 THROUGH AND INCLUDING OCTOBER 12, 1992 PLEASE READ THIS NOTICE CAREFULLY. THIS NOTICE RELATES TO A PROPOSED SETTLEMENT OF THIS CLASS LITIGATION WITH DELOITTE & TOUCHE LLP AND IF YOU ARE A CLASS MEMBER IT CONTAINS IMPORTANT INFORMATION AS TO YOUR RIGHTS TO OBTAIN A SHARE OF THE SETTLEMENT FUND FURTHER DESCRIBED BELOW. IF YOU HAVE ALREADY SUBMITTED A PROOF OF CLAIM AND RELEASE FORM, DO NOT SUBMIT ANOTHER ONE. YOU ARE HEREBY NOTIFIED, pursuant to Rule 23 of the Federal Rules of Civil Procedure, and an Order of the United States District Court for the Northern District of California, San Jose Division (the "Court") that a Settlement (the "Settlement") in the amount of Nine Hundred Thousand Dollars ($900,000) of the captioned litigation (the "Litigation") with Deloitte & Touche LLP ("Deloitte") has been reached by the parties, which Settlement is subject to approval by the Court, and which, if approved, will result (a) in the creation of the Settlement Fund which shall be disbursed as set forth below; and, (b) in the dismissal of the Litigation with prejudice as against Deloitte and the release of the Released Claims (as defined below). This Notice is not intended to be, should not be construed as, and is not an expression of any opinion by the Court with respect to the truth of the allegations in the Litigation or the merits of the claims or defenses asserted. This Notice is merely to advise you of the pendency of this Litigation, the proposed Settlement of the Litigation with Deloitte and of your rights thereunder. I. DEFINITIONS 1. "Deloitte" means Deloitte & Touche and Deloitte & Touche LLP and all of its present and former parent companies, subsidiaries, affiliates, predecessors and successors, their respective directors, officers, partners, principals, employees, agents, servants and attorneys, and their respective representatives, heirs, executors, spouses, personal representatives, administrators and assigns, and any and all persons natural or corporate in privy with them or acting in concert with them or any of them. On August 15, 1994, Deloitte & Touche became a registered limited partnership, and is now known as Deloitte & Touche LLP. 2. "Former Defendants" means SVB, Silicon Valley Bank, Gary K. Barr, Clarence Ferrari, Jr., Henry M. Gay, Daniel J. Kelleher, J. Kerins, Allan C. Kramer, Benjamin E. Millerbis, Roger V. Smith, Thomas J. O'Connor, Barry A. Turkus, Miles McCormick and Ann R. Wells. 3. "Settlement Class" means all persons who purchased the common stock of SVB during the period beginning January 9, 1991 through and including October 12, 1992. Excluded from the Class are Deloitte, Former Defendants, members of the immediate family of any Former Individual Defendant, any entity in which any Former Defendant or Deloitte has or had a controlling interest, and the legal representatives, heirs, successors, or assigns of any such excluded person or entity. Also excluded from the Settlement Class are those persons who timely and validly requested exclusion from the settlement class pursuant to the "Notice of Pendency and Partial Settlement of Class Action" sent to the class in connection with the previous partial settlement as well as those persons who timely and validly request exclusion from the Settlement Class pursuant to the "Notice of Settlement of Class Action with Deloitte & Touche LLP" to be sent to the Class in connection with this settlement.

4. "SVB" means Silicon Valley Bancshares, and all of its predecessors, successors, parents, subsidiaries, divisions and related or affiliated entities. II. COMMENCEMENT OF THE LITIGATION AND NATURE OF THE ACTION On June 1, 1993, this action was filed in the United States District Court for the Northern District of California, San Jose Division, as a class action on behalf of all persons who purchased common stock of Silicon Valley Bancshares during the period January 9, 1991 through October 12, 1992. The complaint named as defendants Silicon Valley Bancshares, Silicon Valley Bank, certain of its officers and directors, the law firm of Ferrari, Alvarez, Olsen & Ottoboni (the "law firm") and SVB's auditors, Deloitte & Touche LLP ("Deloitte"). In addition to violations of 10(b) and 20 of the federal securities laws and Rule 10b-5 promulgated thereunder, the complaint alleged violations of certain state statutes. Subsequently, on August 27, 1993, plaintiff, by stipulation, voluntarily dismissed her state law claims. Similarly, on September 2, 1993, after further investigation and discovery, plaintiff, by stipulation, voluntarily dismissed her claims against the law firm. On July 7, 1994, plaintiff filed a First Amended Class Action Complaint (the "Complaint") for violations of the federal securities laws. This action is referred to herein as the "Litigation". In the Complaint, plaintiff alleges that during the Class Period, Former Defendants and Deloitte caused or permitted SVB to issue financial statements and a series of favorable public statements in annual and quarterly reports to shareholders, press releases and press interviews regarding SVB, its business, operations, management, results from operations, earnings, nonperforming loans and loan loss reserves and its future business prospects, which were materially false and misleading when made and which had the purpose and effect of artificially inflating the market price of SVB's common stock throughout the Class Period. A Stipulation of Partial Settlement dated as of September 5, 1994, was entered into by and among the Representative Plaintiff and SVB, Silicon Valley Bank, Gary K. Barr, Clarence Ferrari, Jr., Henry M. Gay, Daniel J. Kelleher, J. Kerins, Allan C. Kramer, Benjamin E. Millerbis, Roger V. Smith, Thomas J. O'Connor, Barry A. Turkus, Miles McCormick and Ann R. Wells. A Final Judgment and Order of Dismissal approving this partial settlement was filed on November 28, 1994. III. PRETRIAL PROCEEDINGS AND DISCOVERY IN THE LITIGATION A. Discovery, Investigation And Research Counsel for the Representative Plaintiff and the Class have conducted extensive hard-fought discovery and investigation in this case. This discovery has included, inter alia, (i) inspection and analysis of approximately 70,000 pages of documents produced by defendants; (ii) inspection and analysis of documents produced by third party analysts; (iii) review, analyses and investigation of defendants' interrogatory responses; (iv) review, analyses and investigation of documents produced by regulatory agencies; (v) consultation with experts in economics, accounting and banking; (vi) review of SVB's public filings, annual reports and other public statements; and (vii) research of the applicable law with respect to the claims asserted in the Complaint and the potential defense to those claims. B. Pretrial Motions On September 3, 1993, the Former Defendants answered the original complaint. However, on August 12, 1993, Deloitte filed a motion to dismiss the Complaint and a motion to strike certain allegations pursuant to Rule 12(b)(6). Deloitte's motion also requested that discovery be stayed pending the Court's resolution of the motion to dismiss. Plaintiff opposed all of Deloitte's motions, and, in addition, filed a motion to compel Deloitte to produce documents. That motion was granted. Deloitte's motion to dismiss was granted with leave to amend on February 7, 1994. Plaintiff subsequently filed a First Amended Class Action Complaint on July 7, 1994. Deloitte filed a motion to dismiss the Complaint on September 16, 1994, which motion was denied by order dated January 6, 1995. On February 1, 1995, Deloitte answered the Complaint. During the course of discovery, plaintiff served a subpoena duces tecum on the Federal Reserve Board requesting certain documents relating to the SVB. After exhausting her administrative remedies, plaintiff filed a motion to compel SVB to produce the subpoenaed records in the United States District Court for the District of Columbia. The Federal Reserve Board opposed the motion, and SVB moved the court to intervene in the action in opposition to plaintiff's motion. Plaintiff opposed SVB's intervention. Plaintiff's motion was granted by Order of the United States District Court for the District of Columbia, dated February 1, 1995. Deloitte moved to compel answers to its interrogatories to plaintiff on July 17, 1995. Plaintiff opposed the motion, and at a hearing held on September 1, 1995, the Court granted Deloitte's motion. IV. DELOITTE'S STATEMENT AND DENIAL OF WRONGDOING AND LIABILITY 2

Deloitte has denied and continues to deny each and all of the claims and contentions alleged against it by the Representative Plaintiff and the Class in the Litigation. Deloitte expressly has denied and continues to deny all charges of wrongdoing or liability against it arising out of any of the conduct, statements, acts or omissions alleged, or that could have been alleged, in the Litigation. Deloitte also has denied and continues to deny, inter alia, the allegations that the Representative Plaintiff or the Class has suffered damage, that the price of SVB common stock was artificially inflated by reasons of alleged misrepresentations, non-disclosures or otherwise by Deloitte, or that the Representative Plaintiff or the Class was harmed by the conduct alleged in the Complaint. Nonetheless, Deloitte has concluded that the further conduct of the Litigation would be protracted and expensive, and that it is desirable that the Litigation be fully and finally settled in the manner and upon the terms and conditions set forth in the Stipulation in order to limit further expense, inconvenience and distraction and to dispose of burdensome and protracted litigation. Deloitte also has taken into account the uncertainty and risks inherent in any litigation, especially in complex cases like this Litigation. Deloitte has, therefore, determined that it is desirable and beneficial to it that the Litigation be settled in the manner and upon the terms and conditions set forth in the Stipulation. V. CLAIMS OF THE REPRESENTATIVE PLAINTIFF AND BENEFITS OF SETTLEMENT The Representative Plaintiff believes that the claims asserted in the Litigation have merit and that the evidence developed to date supports the claims asserted. However, Plaintiff's Counsel recognize and acknowledge the expense and length of continued proceedings necessary to prosecute the Litigation against Deloitte through trial and through appeals. Plaintiff's Counsel also have taken into account the uncertain outcome and the risk of any litigation, especially in complex actions such as this Litigation, as well as the difficulties and delays inherent in such litigation. Plaintiff's Counsel also are mindful of the inherent problems of proof under and possible defenses to the federal securities law violations asserted in the Complaint. Plaintiff's Counsel believe that the settlement set forth in the Stipulation confers substantial benefits upon the Settlement Class and each of the Settlement Class Members. Based on their evaluation, Plaintiff's Counsel have determined that the settlement set forth in the Stipulation is in the best interests of the Representative Plaintiff and the Settlement Class and each of the Settlement Class Members. VI. THE RIGHTS OF SETTLEMENT CLASS MEMBERS If you are a member of the Settlement Class, you may receive the benefit of and you will be bound by the terms of the proposed Settlement described in Part VII of this Notice, upon approval of the Court. If you are a member of the Settlement Class, you have the following options: 1. You may file a Proof of Claim and Release ("Proof of Claim") as described below, if you have not already done so in connection with the previous partial settlement in this case. If you choose this option, you will remain a member of the Settlement Class, you will share in the proceeds of the proposed Settlement if your claim is timely and valid and if the proposed Settlement is finally approved by the Court, and you will be bound by the Judgment and Release described below. 2. If you do not wish to be included in the Class and you do not wish to participate in the proposed Settlement described in this Notice, you may request to be excluded. If you have previously requested exclusion from the Class, you need not do so again. To request exclusion, you must so state in writing no later than August 12, 1996. You must set forth the name of this Litigation (Adam v. Silicon Valley Bancshares, et al., No. C-93-20399-RMW (EAI)), your name, address and telephone number, and the name and address of the record owner if different from your own. You must also set forth the number of shares of SVB common stock purchased and sold during the Settlement Class Period and the dates and prices of such purchase(s) and sale(s). The exclusion request should be addressed as follows: SVB Securities Litigation c/o Gilardi & Co. P.O. Box 8040 San Rafael, California 94912-8040 NO REQUEST FOR EXCLUSION WILL BE CONSIDERED VALID UNLESS ALL OF THE INFORMATION DESCRIBED ABOVE IS INCLUDED IN ANY SUCH REQUEST. If you validly request exclusion from the Settlement Class, (a) you will be excluded from the Settlement Class, (b) you will not share in the proceeds of the settlement described herein, (c) you will not be bound by the judgment entered in the Litigation against Deloitte, (d) you will not be precluded, by reason of your decision to request exclusion from the Settlement Class, from otherwise prosecuting an individual claim, if timely, against Deloitte based on the matters complained of in the Litigation. 3. If you do not request to be excluded from the Settlement Class, whether or not you submit a Proof of Claim and Release you will be bound by any and all judgments or settlements entered or approved by the Court, whether favorable or unfavorable to the Settlement Class; including, without limitation, the Judgment described in Section VII, 4, below. 3

4. If you do not request to be excluded from the Settlement Class, you may object to the Settlement and/or the application of Plaintiff's Counsel for an award of attorneys' fees and reimbursement of expenses in the manner set forth below. The filing of a Proof of Claim by a Settlement Class Member does not preclude a Settlement Class Member from objecting to the Settlement. However, if your objection is rejected you will be bound by the Settlement and any judgment just as if you had not objected. 5. You may do nothing at all. If you choose this option, and you have not previously submitted a Proof of Claim in this matter, you will not share in the proceeds of the Settlement, but you will be bound by any judgment entered by the Court. If you are a member of the Settlement Class, you may, but are not required to, enter an appearance through counsel of your own choosing at your own expense. If you do not do so, you will be represented by Plaintiff's Counsel: Milberg Weiss Bershad Hynes & Lerach LLP, William S. Lerach, Jan M. Adler, Joy Ann Bull, 600 W. Broadway, Suite 1800, San Diego, California 92101-5050. VII. THE PROPOSED SETTLEMENT A proposed Settlement has been reached in the Litigation between the Plaintiff and Deloitte, which is embodied in a Stipulation of Settlement with Deloitte & Touche LLP (the "Stipulation") dated as of May 8, 1996, on file with the Court. The following description of the proposed Settlement of the Litigation is only a summary and reference is made to the text of the Stipulation, on file with the Court, for a full statement of its provisions: 1. A settlement fund (the "Settlement Fund") consisting of Nine Hundred Thousand Dollars ($900,000) will be deposited into an escrow account by Deloitte. 2. Upon approval of the Settlement by the Court and entry of a judgment that becomes a final judgment and upon satisfaction of the other conditions to the settlement, described below, the Settlement Fund will be distributed under the Court's direction, supervision and order(s), as follows: (a) To pay all costs and expenses reasonably and actually incurred in connection with the preparation and filing of tax returns and the payment of taxes on the interest earned on the Settlement Fund, including all Taxes and Tax Expenses as defined in the Stipulation; (b) To pay all costs and expenses reasonably and actually incurred in connection with providing notice to the Class, locating Class members, soliciting and processing Settlement Class Claims, assisting with the filing of claims, administering and distributing the Settlement Fund to the Settlement Class, processing Proof of Claim and Release forms and paying escrow costs and fees, if any; and (c) To pay Plaintiff's Counsel's attorneys' fees, expenses and costs plus accrued interest on the attorneys' fees, expenses and costs, if and to the extent allowed by the Court. 3. Pursuant to the Court's previously approved Plan of Allocation described below, the balance of the Settlement Fund (the "Net Settlement Fund"), shall be distributed to Settlement Class Members who submit valid, timely Proofs of Claim ("Authorized Claimants") in accordance with the following Plan of Allocation: (a) IF YOU HAVE ALREADY COMPLETED AND RETURNED A VALID PROOF OF CLAIM FORM IN THIS CASE, YOU NEED DO NOTHING AT ALL TO PARTICIPATE IN THIS SETTLEMENT. IF YOU HAVE ALREADY FILED A VALID PROOF OF CLAIM FORM, DO NOT SUBMIT ANOTHER ONE. (b) Each person claiming to be an Authorized Claimant and who has not already done so shall be required to submit a separate Proof of Claim and Release signed under penalty of perjury and supported by such documents as specified in the Proof of Claim form. (c) If you have not already submitted a Proof of Claim form, to share in the Net Settlement Fund you must submit a valid Proof of Claim and Release on the form enclosed with this notice no later than October 9, 1996, to the address set forth in the attached Proof of Claim form. Unless otherwise ordered by the Court, any Settlement Class member who fails to timely submit a valid Proof of Claim form within such period, or such other period as may be ordered by the Court, or otherwise allowed, shall be forever barred from receiving any payments pursuant to the Stipulation and the settlement, but will in all other respects be subject to and bound by the provisions of the Stipulation, the settlement and releases contained therein, and the final judgment entered by the Court. (d) To the extent there are sufficient funds in the Net Settlement Fund, each Authorized Claimant will receive an amount equal to the Authorized Claimant's Claim, as defined below, less any payments already received from the previous settlement. If, however, the amount in the Net Settlement Fund is not sufficient to permit payment of the total Claim of each Authorized Claimant, then each Authorized Claimant shall be paid the percentage that each Authorized Claimant's Claim is of the total of the Claims of all Authorized Claimants. A "Claim" will be computed as follows: (i) For shares of SVB common stock purchased by Settlement Class Members during the period from January 9, 1991 to July 8, 1992 and sold between January 9, 1991 and July 8, 1992, a claim shall be equal to twenty-five percent of the amount paid for (including commissions and transfer taxes) any such shares of SVB common stock less the amount realized (net of commissions and transfer taxes) from the sale of any such shares. (ii) For shares of SVB common stock purchased by Settlement Class Members during the period from January 9, 1991 to October 9, 1992 and sold between July 9, 1992 and October 9, 1992, a claim shall be equal to the amount paid for (including 4

commissions and transfer taxes) any such shares of SVB common stock less the amount realized (net of commissions and transfer taxes) from the sale of any such shares. (iii) For shares of SVB common stock purchased by Settlement Class Members during the Settlement Class Period and held on October 12, 1992, a claim shall be equal to the amount paid for (including commissions and transfer taxes) any such shares of SVB common stock less $6.25 per share. (iv) The date of purchase or sale is the "contract" or "trade" date as distinguished from the "settlement" date. (v) For Settlement Class Members who made multiple purchases or multiple sales during the Class Period, the earliest subsequent sale shall be matched with the earliest purchase and chronologically thereafter for purposes of the Claim calculation. (vi) All profits shall be subtracted from all losses to determine the net Claim of each Settlement Class Member. (vii)the Court has reserved jurisdiction to allow, disallow or adjust the claim of any Settlement Class Member on equitable grounds. (e) Payment pursuant to the Plan of Allocation set forth above was approved by the Court in connection with the earlier partial settlement in this matter and shall be deemed conclusive against all Authorized Claimants. No Person shall have any claim against Plaintiff's Counsel or any claims administrator or other agent designated by Plaintiff's Counsel based on the distributions made substantially in accordance with the Stipulation and the Settlement contained therein, the Plan of Allocation, or further orders of the Court. All Settlement Class Members who fail to complete and timely submit a valid Proof of Claim and Release shall be barred from participating in distributions from the Net Settlement Fund (unless otherwise ordered by the Court), but otherwise shall be subject to and bound by all of the terms of the Stipulation, including the terms of any judgment entered and the releases given. 4. If the proposed Settlement is approved by the Court, the Court will enter a judgment (the "Judgment") which will, among other things: (a) approve the settlement and the Stipulation as fair, reasonable and adequate, for purposes of Rule 23 of the Federal Rules of Civil Procedure, and direct the Settling Parties to consummate the settlement in accordance with the terms and conditions of the Stipulation; (b) dismiss the Complaint with prejudice as to Deloitte, including and against the Representative Plaintiff and all Settlement Class Members (except those who file valid and timely requests for exclusion in accordance with the procedures set forth in the Notice and are excluded from the Class pursuant to the Judgment); (c) irrevocably and unconditionally release, settle and extinguish all the Released Claims and bar and permanently enjoin all Settlement Class Members (except those who file valid and timely requests for exclusion in accordance with the procedures set forth in the Notice and are excluded from the Class pursuant to the Judgment) from asserting any of the Released Claims; (d) include a bar order provision which shall provide that any and all claims for contribution and indemnity by any person or entity, including, without limitation, the Former Defendants in the Litigation, which have been, could have been or could be asserted against the Released Persons, related to or arising directly or indirectly out of the Released Claims or the facts, transactions, events, acts or omissions underlying the subject matter of the Litigation, are hereby dismissed with prejudice, barred and the future filing of such claims is permanently enjoined; (e) direct that Deloitte cause the Settlement Fund to be paid into the Escrow Account in accordance with the terms of the Stipulation; (f) find that there is no just reason for delay of entry of a final order as to the Settling Parties; (g) expressly direct that the Clerk of the Court enter the Judgment in accordance with Rule 54(b) of the Federal Rules of Civil Procedure; (h) provide that the Court shall retain jurisdiction with respect to implementation and enforcement of the terms of the Stipulation, and all parties hereto submit to the jurisdiction of the Court for purposes of implementing and enforcing the settlement embodied in the Stipulation; (i) provide such other and further provisions consistent with the terms and provisions of the Stipulation to which the Settling Parties agree; and (j) provide that neither the Stipulation nor the settlement, nor any act performed or document executed pursuant to or in furtherance of the Stipulation or the settlement: (i) is or may be deemed to be or may be used as an admission of, or evidence of, the validity of any Released Claim, or of any wrongdoing or liability of the Released Claim, or of any wrongdoing or liability of the Released Persons; or (ii) is or may be deemed to be or may be used as an admission of, or evidence of, any fault or omission of any of the Released Persons in any civil, criminal or administrative proceeding in any court, administrative agency or other tribunal, other than in such proceedings as may be necessary to consummate or enforce the Stipulation, the settlement or the Judgment, except that the Released Persons may file the Stipulation and/or the Judgment in any action that may be brought against them in order to support a defense or counterclaim based on principles of res judicata, collateral estoppel, release, good faith settlement, judgment bar or reduction or any other theory of claim preclusion or issue preclusion or similar defense or counterclaim. As used above, "Released Claims" shall collectively mean and include any and all claims or causes of action, including "Unknown Claims" as defined below, demands, rights, liabilities, damages, losses, fees, costs and causes of action of every nature and description whatsoever, known or unknown, asserted or that might have been asserted, including, without limitation, claims for negligence, gross negligence, breach of duty of care and/or breach of duty of loyalty, fraud, breach of fiduciary duty, or violations of any state or federal statutes, rules or regulations, that now exist or heretofore existed that have been or could have been asserted in the Litigation by the Representative Plaintiff or the Settlement Class Members, or any of them, against the Released Persons which arises out of, is based upon or related to both the purchase of SVB common stock by the Representative Plaintiff or a Settlement Class 5

Member during the Settlement Class Period and the facts, transactions, events, occurrences, acts, disclosures, statements, omissions or failures to act which were or could have been alleged in the Litigation. "Unknown Claims," as used in the definition of Released Claims above, means any Released Claims which the Representative Plaintiff or any Settlement Class Member does not know or suspect to exist in his, her or its favor at the time of the release of the Released Persons which, if known by him, her or it, might have affected his, her or its decision to settle with and release the Released Persons, or might have affected his, her or its decision not to object to the Settlement. With respect to any and all Released Claims, the Settling Parties stipulate and agree that, upon the Effective Date, the Representative Plaintiff and each of the Settlement Class Members shall be deemed to have, and by operation of the Judgment shall have, expressly waived and relinquished, to the fullest extent permitted by law, the provisions, rights, and benefits of 1542 of the California Civil Code, which provides: A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor. The Representative Plaintiff and each of the Settlement Class Members, upon the Effective Date, shall be deemed to have, and by operation of the Judgment shall have, expressly waived and relinquished any and all provisions, rights and benefits conferred by any law of any state or territory of the United States, or principle of common law, which is similar, comparable or equivalent to 1542 of the California Civil Code. The Representative Plaintiff and each of the Settlement Class Members acknowledge that they may hereafter discover facts in addition to or different from those which he, she or it now knows or believes to be true with respect to the subject matter of the Released Claims, but the Representative Plaintiff and each Settlement Class Member, upon the Effective Date, intends to and shall be deemed to have, and by operation of the Judgment shall have, fully, finally, and forever settled and released any and all Released Claims, known or unknown, suspected or unsuspected, contingent or non-contingent, whether or not concealed or hidden, which now exist, or heretofore have existed upon any theory of law or equity now existing or coming into existence in the future, including, but not limited to, conduct which is negligent, intentional, with or without malice, or a breach of any duty, law or rule, without regard to the subsequent discovery or existence of such different or additional facts. The Settling Parties acknowledge that the foregoing waiver was separately bargained for and a key element of the Settlement of which this Release is a part. VIII. NOTICE TO BANKS, BROKERS, AND OTHER NOMINEES Banks, brokerage firms, institutions, and other persons who are nominees who purchased the common stock of SVB for the beneficial interest of other persons on any day beginning January 9, 1991 through and including October 12, 1992, inclusive are requested within ten (10) days of receipt of the Notice, (1) to provide Plaintiff's Counsel with the names and addresses of such beneficial owners, or (2) to forward copies of this Notice and the Proof of Claim and Release to each such beneficial purchaser and provide Plaintiff's Counsel with written confirmation that the notice has been so forwarded. Plaintiff's Counsel offer to prepay your reasonable expenses of complying with this request upon submission of appropriate documentation. Additional postage prepaid copies of the Notice may be obtained from Plaintiff's Counsel for forwarding to such beneficial owners. All such correspondence to Plaintiff's Counsel should be addressed as follows: SVB Securities Litigation c/o Gilardi & Co. P.O. Box 8040 San Rafael, California 94912-8040 IX. REQUEST FOR ATTORNEYS' FEES AND COSTS AND EXPENSES Plaintiff's Counsel will apply to the Court, at the conclusion of the hearing described below, for an award of counsel fees of up to one-third (33-1/3%) of the Settlement Fund plus litigation expenses and disbursements actually incurred and not reimbursed from the previous settlement, together with interest earned on said sums at the same rate and for the same periods as earned by the Settlement Fund. Such sums as may be granted by the Court will be paid from the Settlement Fund, and Plaintiff's Counsel have reserved the right to make additional applications for fees and expenses incurred. X. THE FINAL APPROVAL HEARING A Settlement Hearing will be held before the Honorable Edward A. Infante, United States Magistrate Judge, United States District Court, Northern District of California, San Jose Division, 280 South First Street, San Jose, California at 9:30 a.m. on August 26, 1996 for the purpose of determining whether the proposed Settlement with Deloitte is fair, reasonable and adequate and whether it should be approved by the Court and the Litigation dismissed with prejudice as against Deloitte, and the Judgment entered, as provided above; and to consider Plaintiff's Counsel's application for attorneys' fees, costs and expenses. The hearing on approval of the Settlement and on the application for an award of attorneys' fees, costs and expenses may be adjourned from time to time by the Court at the hearing or any adjourned session thereof without further notice. 6

Any member of the Settlement Class who has not requested exclusion may appear at the hearing to show cause why the proposed Settlement should not be approved and the Litigation should not be dismissed with prejudice as against Deloitte, and/or to present any opposition to the application of Plaintiff's Counsel for attorneys' fees, costs and expenses; provided, however, that no such person shall be heard, unless his, her or its objection or opposition is made in writing and is filed, together with copies of all other papers and briefs to be submitted by him, her or it to the Court at the hearing, with the Court no later than August 12, 1996, and showing due proof of service on: MILBERG WEISS BERSHAD HYNES & LERACH LLP WILLIAM S. LERACH JAN M. ADLER JOY ANN BULL 600 West Broadway, Suite 1800 San Diego, CA 92101 Attorneys for Plaintiff McCUTCHEN, DOYLE, BROWN & ENERSEN, LLP STEPHEN D. HIBBARD Three Embarcadero Center San Francisco, CA 94111-4066 Attorneys for Deloitte Any member of the Settlement Class who does not make his, her or its objection or opposition in the manner provided shall be deemed to have waived all objections and opposition to the fairness, reasonableness and adequacy of the proposed Settlement, and to the request of Plaintiff's Counsel for attorneys' fees, costs and expenses. 7

XI. EXAMINATION OF PAPERS AND INQUIRIES For a more detailed statement of the matters involved in this Litigation, reference is made to the pleadings, to the Stipulation of Settlement and to other papers filed in this action, which may be inspected at the Office of the Clerk of the United States District Court, Northern District of California, San Jose Division, United States Courthouse, 280 South First Street, San Jose, California, during business hours of each business day. Inquiries regarding the Litigation should be addressed as follows: SVB Securities Litigation c/o Gilardi & Co. P.O. Box 8040 San Rafael, California 94912-8040 PLEASE DO NOT TELEPHONE THE COURT REGARDING THIS NOTICE DATED: July 10, 1996 BY ORDER OF THE COURT UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 8