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In re Allied Nevada Gold Corp., Securities Litigation

United States District Court, D. Nevada

July 19, 2019

In re ALLIED NEVADA GOLD CORP. SECURITIES LITIGATION

          MUCKLEROY LUNT, LLC MARTIN A. MUCKLEROY LIAISON COUNSEL FOR LEAD PLAINTIFF

          BROWER PIVEN A PROFESSIONAL CORPORATION CHARLES J. PIVEN (ADMITTED PRO HAC VICE) COUNSEL FOR LEAD PLAINTIFF ANDREY SLOMNITSKY AND LEAD COUNSEL FOR THE PROPOSED CLASS

          ROBBINS GELLER RUDMAN & DOWD LLP SAMUEL H. RUDMAN (ADMITTED PRO HAC VICE) JOSEPH RUSSELLO (ADMITTED PRO HAC VICE) WILLIAM J. GEDDISH (ADMITTED PRO HAC VICE) ADDITIONAL COUNSEL FOR LEAD PLAINTIFF

          DICKINSON WRIGHT PLLC JOHN P. DESMOND JUSTIN J. BUSTOS

          SULLIVAN & CROMWELL LLP ROBERT A. SACKS (ADMITTED PRO HAC VICE) AND LAURA KABLER OSWELL (ADMITTED PRO HAC VICE) DUNCAN C. SIMPSON LAGOY (ADMITTED PRO HAC VICE) COUNSEL FOR DEFENDANTS SCOTT A. CALDWELL, ROBERT M. BUCHAN, RANDY E. BUFFINGTON, AND STEPHEN M. JONES

          STIPULATED FORM OF PRODUCTION AGREEMENT AND ORDER

          THE HONORABLE WILLIAM G. COBB UNITED STATES MAGISTRATE JUDGE.

         This Form of Production Agreement will govern the format in which the parties produce documents in the above-captioned case.

         I. PRODUCTION OF HARD COPY DOCUMENTS- FORMAT

         1. Hard Copy Documents: Hard copy documents should be scanned as single-page, Group IV, 300 DPI TIFF images with an .opt image cross-reference file and a delimited database load file (i.e., .dat). The database load file should contain the following fields: “BEGNO, ” “ENDNO, ” “PAGES, ” “VOLUME” and “CUSTODIAN.” The documents should be logically unitized (i.e., distinct documents shall not be merged into a single record, and single documents shall not be split into multiple records) and be produced in the order in which they are kept in the usual course of business. If an original document contains color, the document shall be produced as single-page, 300 DPI JPG images with JPG compression and a high quality setting as to not degrade the original image. Multi-page OCR text for each document should also be provided. The OCR software shall maximize text quality. Settings such as “auto-skewing” and “auto-rotation” should be turned on during the OCR process.

         II. PRODUCTION OF ESI

         1. Format:

         Electronically stored information (“ESI”) should be produced in single-page, black and white, TIFF Group IV, 300 DPI TIFF images with the exception of spreadsheet type files, source code, audio and video files, which should be produced in native format. If an original document contains color, the document shall be produced as single-page, 300 DPI JPG images with JPG compression and a high quality setting as to not degrade the original image. Parties are under no obligation to enhance an image beyond how it was kept in the usual course of business. TIFFs/JPGs should show any and all text and images which would be visible to the reader using the native software that created the document, with the exception of redacted portions. For example, TIFFs/JPGs of e-mail messages should include the BCC line. Power Point documents shall be processed with hidden slides and all speaker notes unhidden, and shall be processed to show both the slide and the speaker's notes on the TIFF /JPG image.

         2. Format - Native Files:

         If a document is produced in native, a single-page, Bates stamped image slip sheet stating the document has been produced in native format should also be provided. Each native file should be named according to the Bates No. it has been assigned, and should be linked directly to its corresponding record in the load file using the NATIVELINK field. To the extent that either party believes that specific documents or classes of documents, not ...


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