Comstock Mining, Inc. (LODE)

REPRINTED FROM APRIL 15, 2013

CORRADO DE GASPERIS is President, CEO and Director of Comstock Mining, Inc., a gold and silver producing mining company that is revitalizing the historic Comstock Lode District in Nevada. He brings 25 years of manufacturing, metals and mining operational and financial management, project management and capital markets experience. Previously, he served as the Chief Executive Officer of Barzel Industries Inc., formerly Novamerican Steel Inc., from April 2006 through September 2009. Barzel operated a network of 15 manufacturing, processing and distribution facilities in the United States and Canada that offered a wide range of metal solutions to a variety of industries, including construction, infrastructure development and mining. From 2001 to 2005, he served as Chief Financial Officer of GrafTech International Ltd., a global manufacturer of industrial graphite and carbon-based materials, in addition to his duties as Vice President and Chief Information Officer, which he assumed in 2000. He served as Controller of GrafTech from 1998 to 2000. From 1987 to 1998, Mr. De Gasperis was a Certified Public Accountant with KPMG LLP. As a Senior Assurance Manager in the Manufacturing, Retail and Distribution Practice, he served major clients like GE and Union Carbide Corporation. KPMG announced his admittance, as a Partner, effective July 1, 1998. He holds a BBA from the Ancell School of Business at Western Connecticut State University, with honors. Mr. De Gasperis was appointed as a Director to Comstock Mining Inc.’s board in June 2011. He also served as a Director of GBS Gold International Inc., where he was Chairman of the Audit, and Governance Committee and the Compensation Committee and a member of the Nominations and Advisory Committees. Mr. De Gasperis is a Member of the NYSE Markets Advisory Committee, the Northern Nevada Development Authority and the Prospectors and Developers Association of Canada.

SECTOR — METALS & MINING Mr. De Gasperis: It was very, very important, a breakthrough TWST: Let’s begin with a brief overview of Comstock actually. The BLM had decided that one of our land claims was not Mining. private, as we believed, and that it was in fact public and so it was Mr. De Gasperis: Comstock Mining was established 10 years basically a title dispute. The alternative haul route was onerous and ago. It spent the first seven years consolidating the land and data of an expensive. By them accepting our Color-of-Title claim, they basically entire historic gold mining district, the Comstock Lode in Nevada, and acknowledged that the land could be private and that decision also about three years ago commenced the process for exploration, development allowed us to use the haul road immediately. So not only was our cost and permitting and moving back into production just recently. We’ve reduced by over $3 million per year, but our throughput — our validated over 3 million gold-equivalent ounces; that is, about 2.7 million productivity — increased by almost 50%; in other words, we are able to ounces of gold and almost 27 million ounces of silver. We started mining haul more, crush more, mine more, and all at a lower cost. on private, patented claims, relatively small-scale production, but the plan TWST: Let’s talk about the chute zone. Give us a little ramps up multiple mines with the possibility of 150,000-plus ounces per insight into the economics of the chute in terms of anticipated year, just from our first two mines. recovery costs, cost of production. TWST: As I understand it, you recently received a favorable Mr. De Gasperis: First I would say that, since we started drilling action from the Bureau of Land Management allowing the company in 2009, outside of the current mine area, we’ve literally hit on every hole to move forward with a Class I Color-of-Title Act claim. How will except one. We’ve drilled almost 140 exploration holes, and we’ve hit on that contribute to your overall business plan? literally every hole but one. The grade and the expansion of the district is

COMPANY INTERVIEW COMPANY INTERVIEW —— COMSTOCK MINING, INC. (LODE) astounding, and has enabled us to validate over 3 million gold-equivalent TWST: What is the financial snapshot for Comstock’s ounces on just two of our seven targets areas — and we have only drilled on Balance sheet and P&L? What are the strengths, and do you have a fraction of these two areas. It’s important to highlight that in the late 1800s the balance sheet in place to accomplish all of your goals? there were over 33 bonanzas discovered on the Comstock, some of massive Mr. De Gasperis: We do. We have an incredibly strong proportion representing billions of dollars of contained gold and silver in capital structure in the sense that we have a list of some of the most today’s values. The chute zone was a high-grade concentrated area, with drill outstanding United States based investors from U.S. Global Investors intercepts of 50 to 270 feet, and has currently mapped dimensions of up to to Century Asset Management to Gabelli Gold to Sun Valley Gold. We 150 feet by up to 450 feet — that was comparable, actually slightly bigger have a permanent equity-based capital structure. We have just a small than the historic Woodville bonanza, one of those 33 bonanzas previously amount of revolver debt, which we believe will be paid off by this July. discovered on the Comstock. The chute zone represents in and of itself By the end of this year, we will have a strong cash position, though we almost $100 million of metal value. So in the context of the metals that we have a strong cash position now — just recently raising $10 million validated already, it’s relatively small. In the context of the structure and and ramping up to cash positive production. But we will have a what it means, because we are very early on in the definition of it, it’s stronger cash position going forward because we are planning to be potentially huge and it extends right off of our existing mine operation. So cash-positive after this month.

“We are in one of the most prolific historic geologies in the country, if not in all of North America. The Comstock Lode produced almost 200 million ounces of silver and over 8 million ounces of gold in the late 1800s. We have really consolidated this historically rich district.” even though we don’t have an engineered mine plan for the chute zone, it’s TWST: Do you see partnerships as part of your forward not irrational to extrapolate the economics of our existing operation because looking growth? the chute zone is almost adjacent to our existing mine. So we see it as just a Mr. De Gasperis: We have a huge land position; we control logical expansion to the east from where we’re already mining. And the 100% of our land and claims. We are open-minded in any idea that would economics for where we’re mining today are extremely compelling because accelerate and increase value, but to date we haven’t entertained we have a very, very low strip ratio, good grades and very good metallurgy, seriously any partnership or joint venture for mining. so the yields in our heap leaching process are very good. Plus, the chute zone TWST: Introduce us to your top level management team, is, overall, much better in grade. two or three of your key individuals including the top geologist and TWST: What makes your company sort of different from your key technical person. other mining companies out there? Mr. De Gasperis: Our top operating man who directs all of Mr. De Gasperis: I think there are a couple of things. First and our mining and processing is Dave Thomas. He has over 30 years of foremost, we are in one of the most prolific historic geologies in the mine and mine construction and mine operation experience. He’s country, if not in all of North America. The Comstock Lode produced built many of the major mines in Alaska. He was most recently one almost 200 million ounces of silver and over 8 million ounces of gold in of the top executives at Newmont, and we have an outstanding the late 1800s. We have really consolidated this historically rich district. operations management, from mining to crushing to metal extraction, So when other companies talk about their deposits, they love to compare on site. Dave also has an exceptional record in terms of environmental themselves to different trends or companies that are close to them. We stewardship. A prerequisiite for working on the Comstock is that you control substantially all of this district, and in that regard we were able have a very different covenant with the territory. We represent a to take a holistic view of the geology. national historic landmark, our responsibility with the territory is In the late 1800s, there were over 400 companies on the very, very different; it’s very, very strong. So David absolutely is a Comstock. They were only looking at a sliver of the geology whereas we key member of our team. took a much more holistic view with the added advantage of 150 years We also have Larry Martin who is our Chief Geologist in of historical data. The resulting productivity has been almost unbelievable. every regard, and Larry has also spent 30 years as a finder of gold in For example, many in the industry are projecting exploration costs to be many places, even internationally, but substantially so in Nevada. So $100 an ounce or more just to discover and validate an ounce. In our first in terms of the cornerstone geological mine development and full year of exploration in 2011, it was just $6 an ounce because we have operation, those are our two most senior, technically competent such strong geological control and a data-driven model on the whole professionals, but we have an incredibly experienced team of district. In essence, we are following one of the most robust, reliable metallurgical engineers, senior geologists, environmental scientists, geological models built, and we are hitting on almost every hole. So I permitting, financial, etc., and we are also very strong in an area that think that’s the biggest difference when you consider that we’ve only I think the mining industry has demonstrated some deficiency or drilled on a tiny fraction of our property position. We have almost 6,000 weakness, in project management. So we have dedicated resources acres representing 10 square miles, and we’ve only drilled on a tiny for project management. I believe real project management is a key fraction, less than 10% of our property. So we have high exploration to the success of any capital or construction based industry, but productivity, and we also have a very, very long runway for upside. especially junior miners, where scheduling for construction, COMPANY INTERVIEW —— COMSTOCK MINING, INC. (LODE) permitting lead times, competent resources and the timely deployment specifically we are targeting operations producing at a rate of 400 ounces of money is something that’s seems to be lacking. It’s not luck when per week or 20,000 gold equivalent ounces per year. a new mine goes into production. The second objective is to start the permitting processes that TWST: In your discussions with the investment community, allow us to go from one mine producing 20,000 gold equivalent ounces what, if any, are the recurring questions or misperceptions? Is per year to two mines totaling 150,000 gold equivalent ounces plus per Comstock understood? year. So we are focused on the progress that we are making on the Mr. De Gasperis: I think so, I think it’s incredibly difficult to engineering to permit and expand the existing operation and a second maintain alignment internally and externally, and I think in today’s operation. Lastly, we will step out and develop and validate more world, especially in a public company environment, the CEO has to minable ounces and develop the ore to a much, much, much bigger spend the majority of his time or her time on communications. And so, resource for the future. we take pride in that it is very time-consuming, but we have been — I TWST: In conclusion, what is it that compels an investor to would say we’ve been selective, to the extent we can be, in the types of not only consider, but include Comstock as a part of their investment investors that have invested into the company. This has resulted in an strategy? A-list of top investors, and we spend a meaningful amount of time, Mr. De Gasperis: I think three things. First, just from a macro obviously always within the disclosure rules, but a meaningful amount perspective, a tremendous upside on the metal value based on the state of time keeping them abreast and understanding not just the business of the world’s fiscal and monetary policies and the growing demand for plan, not just the goal, but the method that we use to get there. To me the metal relative to a more and more scarce resource. Second, and more that’s very important. importantly for us from a micro perspective, we are a company at the There are some investors who don’t want to understand how inflection point of tremendous cash flow growth, and I don’t know any you do it, they just want to see the result, and while they should, it’s a other value driver better than cash flow growth. It’s worth repeating, cash warning, a risk, if you will, if they don’t have a deeper understanding of flow and cash flow growth. And then third, there is such a long, long how you plan on accomplishing your objectives. Otherwise, you quickly runway in terms of the potential amount of gold and silver that is still get misalignment. And so making sure they understand our methods of undiscovered in this district, despite us already having a huge base, it’s doing it are, to me, as important as them understanding the objective that difficult not to get excited. we are going to deliver. TWST: Is there anything you’d like to add? TWST: What do you see as the biggest risk to Comstock Mr. De Gasperis: Nevada is called the Silver State solely other than gold, silver prices going lower? because of the prominence of Comstock Lode and its Silver Rush legacy. Mr. De Gasperis: I think at this point, it’s just our execution. The fact that it has 150 years of tremendous history, we get an incredible If you asked me the question a few years ago, I would have said amount of positive attention for what we are doing and an incredible permitting; if you asked me the question four years ago, I would have amount of political support for what we are doing because we are doing said community support, regulation and politics, but we have worked for it right and it’s important for so many reasons. The economic development and gained community, regulatory and political support. We have our is important, the job creation is important, but in our case, our importance permits, and we have our substantial resource in the ground, so really, for is even greater than that in terms of the cultural importance to Nevada us, it’s execution. Even though we are very, very excited about the that the Comstock Lode is being re-established, and frankly, the history potential future of growing ounces, doubling, tripling, quadrupling, etc., is being preserved and restored. our ounces, right now we’re not doing that, we are focused on stabilizing TWST: Thank you. (KL) production, stabilizing cash flow and production growth, and staying focused on the execution that’s right in front of us. TWST: What are the key metrics or milestones that CORRADO DE GASPERIS investors should focus on, what should matter to the investor, what President, CEO & Director matters to you? Comstock Mining, Inc. Mr. De Gasperis: The most important thing is the speed at P.O. Box 1118 which we generate cash. We call that “throughput,” and we monitor it Virginia City, NV 89440 every day. We are only in the sixth month of ramping up production, so (775) 847-0545 that hasn’t stabilized yet, and that’s in line with our plan, but we’re on (800) 750-5740 — FAX the brink of it stabilizing, and we expect to have stable and transparent www.comstockmining.com understanding of our throughput, which again, is the speed that we generate cash from our system. So that’s number one, and we have said