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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 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

          DICKINSON WRIGHT PLLC JOHN P. DESMOND JUSTIN J. BUSTOS

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

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

          CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER

          William G. Cobb United States Magistrate Judg.

         Pursuant to Fed.R.Civ.P. 26(c) and subject to the Court's approval, this Confidentiality Agreement and Stipulated Protective Order (“Stipulation and Order”) is entered into by and among: (a) Plaintiff Andrey Slomnitsky (“Plaintiff”); and (b) Defendants Scott A. Caldwell, Robert M. Buchan, Randy E. Buffington and Stephen M. Jones (collectively, the “Defendants”), to facilitate the production of confidential, proprietary and/or private information during the course of discovery and pretrial proceedings in this action (the “Action”).

         I. DEFINITIONS

         1. Challenging Party. A Party or Non-Party that challenges the designation of Discovery Material as “Confidential” under this Stipulation and Order.

         2. Confidential Discovery Material. Any Discovery Material (regardless of how it is generated, stored or maintained) designated as “Confidential” pursuant to the terms of this Stipulation and Order.

         3. Designating Party. Any Party or Non-Party who designates information or items for protection pursuant to the terms of this Stipulation and Order.

         4. Discovery Material. Any information provided in the course of discovery in this Action, including, but not limited to, information contained in documents, testimony taken at depositions and transcripts thereof, deposition exhibits, and tangible things.

         5. Inadvertently Disclosed Information. Information subject to a claim of attorney-client privilege, attorney work product protection, or other applicable privilege, that a Producing Party inadvertently discloses to a Receiving Party in this Action.

         6. Non-Party. Any person or entity that is not a Party to the Action.

         7. Party. Any Party to the Action, including all of his employees, consultants, retained experts, and counsel (including their support staff) and any entity controlled by a named plaintiff or defendant in the Action, including all officers and directors thereof.

         8. Producing Party. A Party or Non-Party that produces Discovery Material in the Action.

         9. Receiving Party. A Party that receives Discovery Material from a Producing Party in the Action.

         10. Undertaking. The Non-Disclosure Agreement annexed as Exhibit A hereto.

         II. SCOPE

         1. The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. However, the protections conferred by this Stipulation and Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial or otherwise; and (b) any information known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the information lawfully and under no obligation of confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.

         III. DESIGNATING DISCOVERY MATERIAL

         1. Any Producing Party may designate as “Confidential” Discovery Material that Party believes in good faith consists of:

(a) any personal information of a sensitive nature regarding any individual;
(b) proprietary information;
(c) personnel-related ...

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