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SCOTT C. CLARKSON, ESQ. SBN 143271 EVE A. MARSELLA, ESQ. SBN 165797 CLARKSON, GORE & MARSELLA A PROFESSIONAL LAW CORPORATION 3424 Carson Street, Suite 350 Torrance, California 90503 (310) 542-0111 Telephone (310) 214-7254 Facsimile Attorneys for MTI Technology Corporation

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA, SANTA ANA DIVISION In re MTI TECHNOLOGY CORPORATION, a Delaware corporation, Debtor and Debtor in Possession. Case No. 8:07-bk-13347 ES In A Chapter 11 Case DEBTORS SECOND SUPPLEMENT TO BIDDING PROCEDURES REQUESTED IN CONNECTION WITH MOTION TO SELL ASSETS TO THE COLLECTIVE GROUP Date: April 11, 2008 Time: 2:00 p.m. Ctrm: 5A 411 West 4th Street, Santa Ana, CA 92701

TO THE HONORABLE ERITHE A. SMITH, UNITED STATES BANKRUPTCY JUDGE, THE OFFICE OF THE UNITED STATES TRUSTEE, THE CREDITORS COMMITTEE AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD: NOTICE IS HEREBY GIVEN that at the date, time and location, as set forth above,

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Debtors Second Supplement to Bidding Procedures Request in Connection with Motion to Sell Certain of Debtors Assets to The Collective Group

MTI Technology Corporation, debtor in possession in the above-captioned chapter 11 case (Debtor and Case respectively), in conjunction with the Debtors motion for an order pursuant to sections 105, 363(b), 363 (f) and 365 of title 11 of the United States Code, 11 U.S.C. 101, et seq. (the Bankruptcy Code) approving Debtors agreement with The Collective Group, LLC (Collective and Motion, respectively), has requested approval of a procedure for accepting and processing competing bids, if any, which included the request to establish a

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minimum overbid requirement of at least $485,000. The Debtor subsequently requested, by a Supplement filed on or about March 25, 2008, that the minimum overbid requirement be modified to $392,820, which amount is derived as follows: $125,000 purchase price, plus 20% new business component, a $10,000 overbid increment, and $257,810 attributable to the then current outstanding receivables. The Debtor believes the overbid procedure will protect the Estate regarding the collectability of the outstanding receivables. As fully stated in the Motion, the Debtor believes that Collective is in a unique position to aid the Debtor in its continued collections efforts. Indeed, Collective has advised the Debtor that it has spent a significant amount of time helping the Debtor collect the Debtors receivables. To date, over the last six months, Collective asserts that it has utilized ten of its personnel, who have collectively expended approximately 597 hours, valued at $97,350.00, on matters related to

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Debtors Second Supplement to Bidding Procedures Request in Connection with Motion to Sell Certain of Debtors Assets to The Collective Group

aiding the Debtor in collecting the Debtors receivables, post-petition. As part of this transaction, Collective has agreed to guarantee collections of up to $160,000.00 of the outstanding accounts receivables by 90 days from entry of the order approving the Motion. Further, Collective has agreed to fully release the Estate of liability for up to $100,000 of any potential administrative claim. As stated in the Motion, the Debtor believes that this overbid procedure protects the Estate regarding the collectability of its remaining MTI Collective Division receivables. Dated: March 28, 2008 CLARKSON, GORE & MARSELLA, A Professional Law Corporation

By: /s/ Scott C. Clarkson, Esq. Eve A. Marsella Attorneys for MTI Technology Corporation

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