19.  Plaintiff brings this action as a class action on behalf of himself and the other  public stockholders of Mines Management (the “Class”).  Excluded from the Class are  Defendants herein and any person, firm, trust, corporation, or other entity related to or affiliated  with any Defendant.   20.  This action is properly maintainable as a class action.   21.  The Class is so numerous that joinder of all members is impracticable.  As of May  13, 2016, there were approximately 31,643,704 shares of Mines Management common stock  outstanding, held by hundreds, if not thousands, of individuals and entities scattered throughout  the country.   22.  Questions of law and fact are common to the Class, including, among others: (i)  whether Defendants violated the 1934 Act; and (ii) whether Defendants will irreparably harm  Plaintiff and the other members of the Class if Defendants’ conduct complained of herein  continues.   23.  Plaintiff is committed to prosecuting this action and has retained competent  counsel experienced in litigation of this nature.  Plaintiff’s claims are typical of the claims of the  other members of the Class and Plaintiff has the same interests as the other members of the  Class.  Accordingly, Plaintiff is an adequate representative of the Class and will fairly and  adequately protect the interests of the Class.   24.  The prosecution of separate actions by individual members of the Class would  create the risk of inconsistent or varying adjudications that would establish incompatible  standards of conduct for Defendants, or adjudications that would, as a practical matter, be  dispositive of the interests of individual members of the Class who are not parties to the  Case 2:16-cv-00256-SMJ    Document 1    Filed 07/12/16 26.  Mines Management was founded in 1947 and is a U.S.-based mineral exploration  and development company engaged in the acquisition, exploration, and development of silver- dominant mineral projects.    27.  The Company’s current focus is advancement and development of the Montanore  Silver-Copper Deposit, one of the largest silver-copper deposits in the world.    28.  The deposit is located in northwestern Montana, approximately forty miles north  of the famed Silver Valley of Idaho, within one of the world’s most prolific silver districts.    29.  Mines Management acquired the Montanore deposit in 2002 when its partner and  operator, Noranda Minerals of Canada, withdrew.    30.  On February 12, 2016, Mines Management issued a press release wherein it  reported that Records of Decision (“ROD”) approving development of the Montanore Mine  Project were issued by the U.S. Forest Service (“USFS”) and the Montana Department of  Environmental Quality (“MDEQ”).     31.  The agencies’ decisions approved the project defined in the preferred alternative  as outlined in the Joint Final Environmental Impact Statement (“EIS”) previously announced on  December 21, 2015, and provided a path forward for development of the project.   32.  MDEQ’s conditioned approval amended the previously-existing state Hard Rock  Operating Permit #00150 to conform with provisions of the RODs, and issued the Certificate of  Case 2:16-cv-00256-SMJ    Document 1    Filed 07/12/16 72.  Plaintiff repeats and realleges the preceding allegations as if fully set forth herein.   73.  The Individual Defendants disseminated the false and misleading Registration  Statement, which contained statements that, in violation of Section 14(a) of the 1934 Act and  Rule 14a-9, in light of the circumstances under which they were made, omitted to state material  facts necessary to make the statements therein not materially false or misleading.  Mines  Management is liable as the issuer of these statements.     74.  The Registration Statement was prepared, reviewed, and/or disseminated by the  Individual Defendants.  By virtue of their positions within the Company, the Individual  Case 2:16-cv-00256-SMJ    Document 1    Filed 07/12/16 80.  Plaintiff repeats and realleges the preceding allegations as if fully set forth herein.   81.  The Individual Defendants and Hecla acted as controlling persons of Mines  Management within the meaning of Section 20(a) of the 1934 Act as alleged herein.  By virtue of  their positions as officers and/or directors of Mines Management and participation in and/or  awareness of the Company’s operations and/or intimate knowledge of the false statements  contained in the Registration Statement, they had the power to influence and control and did  influence and control, directly or indirectly, the decision making of the Company, including the  content and dissemination of the various statements that Plaintiff contends are false and  misleading.  Case 2:16-cv-00256-SMJ    Document 1    Filed 07/12/16 A. Background of the Company    Claim for Violation of Section 20(a) of the 1934 Act   Against the Individual Defendants and Hecla   Claim for Violation of Section 14(a) of the 1934 Act and Rule 14a-9 Promulgated  Thereunder Against the Individual Defendants and Mines Management  