1 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

STEVE HARTEL, Individually and On 

Behalf of All Others Similarly Situated, 

Plaintiff, 

v. 

THE GEO GROUP, INC., GEORGE C. 

ZOLEY, and BRIAN R. EVANS, 

Defendants. 

Case No. 

CLASS ACTION COMPLAINT 

JURY TRIAL DEMANDED

Plaintiff Steve Hartel (“Plaintiff”), individually and on behalf of all other persons similarly 

situated, by Plaintiff’s undersigned attorneys, for Plaintiff’s complaint against Defendants, alleges 

the following based upon personal knowledge as to Plaintiff and Plaintiff’s own acts, and 

information and belief as to all other matters, based upon, inter alia, the investigation conducted 

by and through Plaintiff’s attorneys, which included, among other things, a review of the 

Defendants’ public documents, conference calls and announcements made by Defendants, United 

States (“U.S.”) Securities and Exchange Commission (“SEC”) filings, wire and press releases 

published by and regarding The GEO Group, Inc. (“GEO Group” or the “Company”), analysts’ 

reports and advisories about the Company, and information readily obtainable on the Internet. 

Plaintiff believes that substantial additional evidentiary support will exist for the allegations set 

forth herein after a reasonable opportunity for discovery. 

NATURE OF THE ACTION 

1. This is a federal securities class action on behalf of a class consisting of all persons 

other than Defendants who purchased or otherwise acquired GEO Group securities between 

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February 27, 2020 and June 16, 2020, both dates inclusive (the “Class Period”), seeking to recover 

damages caused by Defendants’ violations of the federal securities laws and to pursue remedies 

under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) and 

Rule 10b-5 promulgated thereunder, against the Company and certain of its top officials. 

2. GEO Group is purportedly the first fully integrated equity real estate investment 

trust specializing in the design, financing, development, and operation of secure facilities, 

processing centers, and community reentry centers in the U.S., Australia, South Africa, and the 

United Kingdom. GEO Group is also purportedly a leading provider of enhanced in-custody 

rehabilitation, post-release support, electronic monitoring, and community-based programs. The 

Company’s worldwide operations include the ownership and/or management of, among other 

facilities, halfway houses in the U.S. 

3. Between late 2019 and early 2020, a novel strain of the coronavirus disease, 

commonly referred to as COVID-19, became an ongoing global pandemic, with the outbreak first 

identified in Wuhan, China, in December 2019. The virus quickly spread to other countries, 

including the U.S., prompting state, federal, and private parties to enact various health and safety 

measures to halt the spread of the disease, which has since claimed hundreds of thousands of lives, 

with over one hundred thousand deaths in the U.S. alone. To date, the State of Kansas (“Kansas”) 

has experienced at least 12,970 cases and 261 deaths related to COVID-19. 

4. Throughout the Class Period, Defendants made materially false and misleading 

statements regarding the Company’s business, operational and compliance policies. Specifically, 

Defendants made false and/or misleading statements and/or failed to disclose that: (i) GEO Group 

maintained woefully ineffective COVID-19 response procedures; (ii) those inadequate procedures 

subjected residents of the Company’s halfway houses to significant health risks; (iii) accordingly, 

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the Company was vulnerable to significant financial and/or reputational harm; and (iv) as a result, 

the Company’s public statements were materially false and misleading at all relevant times. 

5. On June 17, 2020, during pre-market hours, The Intercept published an article 

entitled “GEO Group’s Blundering Response to the Pandemic Helped Spread Coronavirus in 

Halfway Houses.” The article reported details of a significant COVID-19 outbreak at the 

Grossman Center, a halfway house in Leavenworth, Kansas, operated by GEO Group—which 

“was for weeks the hardest hit federal halfway house in the country” in terms of confirmed cases 

of COVID-19. Citing interviews with residents of the Grossman Center, The Intercept

characterized GEO Group’s response as “blundering” and reported “that the virus spread not in 

spite of the facility’s efforts to contain it, but because of it.” According to the article, the Grossman 

Center continued to keep its residents in overcrowded conditions without enforcing personal 

protective measures even as COVID-19 diagnoses at the facility increased. 

6. On this news, GEO Group’s stock price fell $1.03 per share, or 7.8%, to close at 

$12.17 per share on June 17, 2020. 

7. As a result of Defendants’ wrongful acts and omissions, and the precipitous decline 

in the market value of the Company’s securities, Plaintiff and other Class members have suffered 

significant losses and damages. 

JURISDICTION AND VENUE 

8. The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a) of 

the Exchange Act (15 U.S.C. §§ 78j(b) and 78t(a)) and Rule 10b-5 promulgated thereunder by the 

SEC (17 C.F.R. § 240.10b-5). 

9. This Court has jurisdiction over the subject matter of this action pursuant to 28 

U.S.C. § 1331 and Section 27 of the Exchange Act. 

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10. Venue is proper in this Judicial District pursuant to Section 27 of the Exchange Act 

(15 U.S.C. § 78aa) and 28 U.S.C. § 1391(b). GEO Group is headquartered in this Judicial District, 

Defendants conduct business in this Judicial District, and a significant portion of Defendants’ 

actions took place within this Judicial District. 

11. In connection with the acts alleged in this complaint, Defendants, directly or 

indirectly, used the means and instrumentalities of interstate commerce, including, but not limited 

to, the mails, interstate telephone communications, and the facilities of the national securities 

markets. 

PARTIES 

12. Plaintiff, a resident of Lakewood, Colorado, acquired GEO Group securities at 

artificially inflated prices during the Class Period, as set forth in the attached Certification, and 

was damaged upon the revelation of the alleged corrective disclosures. 

13. Defendant GEO Group is incorporated in Florida, with principal executive offices 

located at 4955 Technology Way, Boca Raton, Florida 33431. The Company’s common stock 

trades in an efficient market on the New York Stock Exchange (“NYSE”) under the ticker symbol 

“GEO.” 

14. Defendant George C. Zoley (“Zoley”) has served as GEO Group’s Chief Executive 

Officer at all relevant times. 

15. Defendant Brian R. Evans (“Evans”) has served as GEO Group’s Chief Financial 

Officer at all relevant times. 

16. Defendants Zoley and Evans are sometimes referred to herein as the “Individual 

Defendants.” 

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17. The Individual Defendants possessed the power and authority to control the 

contents of GEO Group’s SEC filings, press releases, and other market communications. The 

Individual Defendants were provided with copies of GEO Group’s SEC filings and press releases 

alleged herein to be misleading prior to or shortly after their issuance and had the ability and 

opportunity to prevent their issuance or to cause them to be corrected. Because of their positions 

with GEO Group, and their access to material information available to them but not to the public, 

the Individual Defendants knew that the adverse facts specified herein had not been disclosed to 

and were being concealed from the public, and that the positive representations being made were 

then materially false and misleading. The Individual Defendants are liable for the false statements 

and omissions pleaded herein. 

18. GEO Group and the Individual Defendants are collectively referred to herein as 

“Defendants.” 

SUBSTANTIVE ALLEGATIONS 

Background 

19. GEO Group is purportedly the first fully integrated equity real estate investment 

trust specializing in the design, financing, development, and operation of secure facilities, 

processing centers, and community reentry centers in the U.S., Australia, South Africa, and the 

United Kingdom. GEO Group is also purportedly a leading provider of enhanced in-custody 

rehabilitation, post-release support, electronic monitoring, and community-based programs. The 

Company’s worldwide operations include the ownership and/or management of, among other 

facilities, halfway houses in the U.S. 

20. Between late 2019 and early 2020, a novel strain of the coronavirus disease, 

commonly referred to as COVID-19, became an ongoing global pandemic, with the outbreak first 

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identified in Wuhan, China, in December 2019. The virus quickly spread to other countries, 

including the U.S., prompting state, federal, and private parties to enact various health and safety 

measures to halt the spread of the disease, which has since claimed hundreds of thousands of lives, 

with over one hundred thousand deaths in the U.S. alone. To date, Kansas has experienced at least 

12,970 cases and 261 deaths related to COVID-19. 

Materially False and Misleading Statements Issued During the Class Period 

21. The Class Period begins on February 27, 2020, the day after GEO Group filed an 

Annual Report on Form 10-K with the SEC, reporting the Company’s financial and operating 

results for the quarter ended December 31, 2019 (the “2019 10-K”). With respect to “Quality of 

Operations,” the 2019 10-K stated, in relevant part: 

We operate each facility in accordance with our company-wide policies and 

procedures and with the standards and guidelines required under the relevant 

management contract. For many facilities, the standards and guidelines include 

those established by the American Correctional Association, or ("ACA"). The ACA 

is an independent organization of corrections professionals, which establishes 

correctional facility standards and guidelines that are generally acknowledged as a 

benchmark by governmental agencies responsible for correctional facilities. Many 

of our contracts in the United States require us to seek and maintain ACA 

accreditation for our facilities. We have sought and received ACA accreditation and 

re-accreditation for all such facilities. We achieved a median re-accreditation score 

of 100% as of December 31, 2019. Approximately 90% of our 2019 U.S. Secure 

Services revenue was derived from ACA accredited facilities for the year ended 

December 31, 2019. We have also achieved and maintained accreditation by The 

Joint Commission at five of our secure service facilities and at nine of our youth 

services locations. We have been successful in achieving and maintaining 

accreditation under the National Commission on Correctional Health Care 

("NCCHC") in a majority of the facilities that we currently operate. The NCCHC 

accreditation is a voluntary process which we have used to establish comprehensive 

health care policies and procedures to meet and adhere to the ACA standards. The 

NCCHC standards, in most cases, exceed ACA Health Care Standards and we have 

achieved this accreditation at 14 of our U.S. Secure Services facilities and at one 

youth services location. Additionally, B.I. Incorporated ("BI") has achieved a 

certification for ISO 9001:2008 for the design, production, installation and 

servicing of products and services produced by the electronic monitoring business 

units, including electronic home arrest and electronic monitoring technology 

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products and monitoring services, installation services, and automated caseload 

management services. 

22. Further, with respect to “Corporate Social Responsibility,” the 2019 10-K stated, 

in relevant part: 

We have referenced the GRI Standards and the UN Guiding Principles on Business 

and Human Rights as we have recognized the need for a transparent and disciplined 

enterprise-wide approach. In our pursuit of this approach, we have begun with the 

following set of ongoing objectives: 

 Provide greater transparency for our stakeholders and the general public 

with respect to our various efforts in all our facilities aimed at respecting 

human rights. 

 Enhance our ability to flag potential issues in all areas of our operations and 

compress the time it takes to respond with corrective measures. 

 Use widely accepted methodologies for evaluating performance and setting 

objectives for improvements in corporate governance, corporate social 

policy, environmental impact and energy conservation. 

23. In addition, the 2019 10-K touted numerous of the Company’s “Competitive 

Strengths,” including: 

Leading Secure Services Provider Uniquely Positioned to Offer a Continuum of Care 

We are the second largest provider of public-private partnership secure 

services and processing center facilities worldwide and the largest provider of 

community-based reentry services, youth services and electronic monitoring 

services in the U.S. secure services sector. We believe these leading market 

positions and our diverse and complementary service offerings enable us to meet 

the growing demand from our clients for comprehensive services throughout the 

entire corrections lifecycle. Our continuum of care platform enables us to provide 

consistency and continuity in case management, which we believe results in a 

higher quality of care for individuals in our care, reduces recidivism, lowers overall 

costs for our clients, improves public safety and facilitates successful reintegration 

of individuals back into society. 

 *** 

Large Scale Operator with National Presence

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We operate the seventh largest correctional system in the U.S. by number 

of beds, including the federal government and all 50 states. We currently have 

secure services operations in approximately 33 states and offer electronic 

monitoring services in every state. In addition, we have extensive experience in 

overall facility operations, including staff recruitment, administration, facility 

maintenance, food service, security, and in the supervision, treatment and education 

of individuals within our care. We believe our size and breadth of service offerings 

enable us to generate economies of scale which maximize our efficiencies and 

allows us to pass along cost savings to our clients. Our national presence also 

positions us to bid on and develop new facilities across the U.S. 

(Emphasis in original.) 

24. Finally, with respect to “Business Strategies,” the 2019 10-K stated, in relevant 

part: 

Provide High Quality, Comprehensive Services and Cost Savings Throughout the 

Corrections Lifecycle 

Our objective is to provide federal, state and local governmental agencies 

with a comprehensive offering of high quality, essential services at a lower cost 

than they themselves could achieve. We believe government agencies facing 

budgetary constraints will increasingly seek to outsource a greater proportion of 

their correctional needs to reliable providers that can enhance quality of service at 

a reduced cost. We believe our expanded and diversified service offerings uniquely 

position us to bundle our high quality services and provide a comprehensive 

continuum of care for our clients, which we believe will lead to lower cost outcomes 

for our clients and larger scale business opportunities for us. 

(Emphasis in original.) 

25. Appended to the 2019 10-K as exhibits were signed certifications pursuant to the 

Sarbanes-Oxley Act of 2002 (“SOX”) by the Individual Defendants, attesting that “the information 

contained in the [2019 10-K] fairly presents, in all material respects, the financial condition and 

results of operations of the Company.” 

26. On April 30, 2020, GEO Group hosted an earnings call with investors and analysts 

to discuss the Company’s financial and operating results for the first quarter of 2020. Throughout 

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the call, Defendant Zoley touted the Company’s COVID-19 response procedures, stating, in 

relevant part: 

Some of our employees live in communities that have endured significant hardship 

and a few of our facilities have experienced cases of COVID-19 in both on our staff 

and individuals entrusted to our care. From the outset of this global pandemic our 

corporate, regional and field staff have implemented comprehensive steps to 

address and mitigate the risks of COVID-19 to all of those in our care and our 

employees. 

Ensuring the health and safety of all those in our facilities and our employees has 

always been our number one priority. As a longstanding provider of the central 

government services we have the experience for the implementation of best 

practices for the prevention, assessment and the management of infectious diseases. 

All of our facilities operate safely and without overcrowded conditions. All of our 

facilities have access to regular handwashing with clean water and soap, as well as 

ample hygiene and sanitation products. All of our GEO Group Secure facilities 

provide 24/7 access to healthcare. 

*** 

As you've heard today, we have taken comprehensive steps to address and mitigate 

the risk of COVID-19 across all of our facilities and programs. Ensuring the health 

and safety of all of those in our care and our employees has always been our number 

one priority. 

We are committed to working closely with our government agency partners and 

local health officials across the country as well as continue to fight the spread of 

COVID-19. Despite the significant challenges associated with this global 

pandemic, our business, earnings and cash flows remain resilient. 

27. Further, other GEO Group executives touted the Company’s COVID-19 response 

procedures on the earnings call, stating, in relevant part: 

We immediately updated our policies and procedures to include best practices for 

the prevention, assessment and management of COVID-19, again relying on the 

guidance issued by the CDC. These best practices include the implementation of 

quarantine and cohorting procedures to isolate confirmed and presumptive cases of 

COVID-19, including medical isolation and the use of airborne infection isolation 

rooms at our facilities. 

We also provided educational guidance to our employees and individuals in our 

care on the best preventive measures to avoid the spread of COVID-19, such as 

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frequent and careful handwashing, avoiding touching areas of the face including 

facial hair, avoiding individuals exhibiting flu-like symptoms, proper cough and 

sneeze etiquette, social distancing requirements and adjustments to laundry and 

meal schedules. 

We have increased the distribution of personal hygiene products including soap, 

shampoo and bodywash and tissue paper to at least twice per week at all of our 

facilities and more frequently if needed. Additionally, bars of soap or soap 

dispensers are placed at each sink daily for hand washing. 

We have also deployed specialized sanitation teams to sterilize high-contact areas 

of our facilities and have developed intensive schedules and procedures for the 

cleaning and disinfecting of facility spaces above and beyond normal cleaning 

activities. We have procured additional cleaning equipment and sanitation products 

that are proven health care-grade disinfectants. 

We advised our employees to remain home if they exhibit flu-like symptoms. And 

we've exercised flexible paid leave and paid-time-off policies to allow for 

employees to remain home if they exhibit flu-like symptoms or to care for a family 

member. We engaged with our government partners to promptly suspend 

nonessential visitation at all of our facilities and we have employed additional 

measures during the intake process in all of our facilities to include screening 

specific to COVID-19. 

These additional screening procedures include temperature checks for all staff and 

any legally required visits before entering our facilities as well. Verbal medical 

screening questionnaires are also available. We ordered and received swab kits for 

COVID-19 from a national supplier and we enacted quarantine and testing policies 

for any employees who may have come into contact with any individual who has 

tested positive for COVID-19. 

At every one of our facilities we have worked closely with our government agency 

partners and local health officials to develop COVID-19 emergency plans and 

testing policies for the individuals in our care. 

In March of this year, we started procuring additional personal protective 

equipment and began issuing if clinically needed at facilities impacted by COVID19. And over the course of April, we coordinated with our government partners to 

distribute personal protective equipment including face masks to all staff, inmates 

and detainees as a precautionary measure at all of our GEO Secure Services 

facilities. 

 *** 

Consistent with the efforts undertaken by our GEO Secure Services facilities, all of 

our residential facilities and GEO Reentry and GEO Youth Services had issued 

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COVID-19 guidance consistent with the guidance issued by the Centers for Disease 

Control and Prevention. 

We have updated our policies and procedures to include best practices for the 

prevention, assessment and management of COVID-19 including the 

implementation of quarantine and cohorting procedures to isolate confirmed and 

presumptive cases of COVID-19. 

We have provided educational guidance to our employees and all individuals in our 

care on the best preventative measures to avoid the spread of COVID-19 and we 

have increased the distribution of personal hygiene products. 

Similar to our GEO Secure Services facilities, we have deployed specialized 

sanitation teams to sterilize high-contact areas of our facilities and have developed 

special schedules and procedures for the cleaning and disinfecting of facility spaces 

using sanitation products that are proven health care-grade disinfectants. 

We have also advised our employees to remain home if they exhibit flu-like 

symptoms and have exercised flexible paid leave and paid-time-off policies to 

allow for employees to remain home as needed. 

We have implemented additional screening measures for entry into our facilities 

and we are providing face masks to all staff and residents. At all of our facilities, 

we have worked closely with our government agency partners and local health 

officials to develop COVID-19 emergency plans and testing policies consistent 

with CDC guidance. 

We have also established rapid response teams to be deployed to assist facilities 

that have been impacted by COVID-19. The COVID-19 pandemic has affected 

many communities where our employees live especially in the Northeast. 

28. On May 6, 2020, GEO Group filed a Quarterly Report on Form 10-Q with the SEC, 

reporting the Company’s financial and operating results for the quarter ended March 31, 2020 (the 

“Q1 2020 10-Q”). With respect to “Health and Safety,” the Q1 2020 10-Q stated, in relevant part: 

As the COVID-19 pandemic has impacted communities across the United States 

and around the world, our employees and facilities have also been impacted by the 

spread of COVID-19. Ensuring the health and safety of our employees and all those 

in our care has always been our number one priority. As a longstanding provider of 

essential government services, we have experience with the implementation of best 

practices for the prevention, assessment, and management of infectious diseases. 

 All of our facilities provide 24/7 access to healthcare; 

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 All of our ICE Processing Centers typically have approximately double the 

number of healthcare staff, compared to state correctional facilities; 

 Many of our facilities are equipped with Airborne Infection Isolation 

Rooms; 

 All of our facilities operate safely and without any overcrowded conditions; 

and 

 All of our facilities have access to regular handwashing with clean water 

and soap. 

29. Further, the Q1 2020 10-Q touted a list of steps that the Company purportedly 

implemented at the outset of the global pandemic, including: 

 We issued guidance to all of our facilities, consistent with the guidance 

issued for correctional and detention facilities by the Centers for Disease 

Control and Prevention Interim Guidance on Management of Coronavirus 

Disease 2019 (Covid-19) in Correctional and Detention Facilities; 

 We updated our policies and procedures to include best practices for the 

prevention, assessment, and management of COVID-19, including the 

implementation of quarantine and cohorting procedures to isolate confirmed 

and presumptive cases of COVID-19, including medical isolation and the 

use of Airborne Infection Isolation Rooms; 

 We ordered and received swab kits for COVID-19 from a national supplier, 

and we enacted quarantine and testing procedures for any employees who 

may have come into contact with any individual who has tested positive for 

COVID-19; 

 In March 2020, we started procuring additional Personal Protective 

Equipment and began issuing it as clinically needed at facilities impacted 

by COVID-19; 

 Over the course of April 2020, we coordinated with our government 

partners to distribute Personal Protective Equipment, including face masks 

to all staff, inmates, detainees and residents as a precautionary measure at 

all of our Federal Bureau of Prisons facilities, ICE Processing Centers, U.S. 

Marshals facilities, state correctional facilities, local correctional facilities 

and jails, residential reentry centers, and youth services residential facilities; 

 We provided educational guidance to our employees and individuals in our 

care on the best preventative measures to avoid the spread of COVID-19 

such as frequent and careful handwashing, avoiding touching areas of the 

face, including facial hair, avoiding individuals exhibiting flu-like 

symptoms, proper cough and sneeze etiquette, social distancing 

requirements and adjustments to laundry and meal schedules; 

 We increased the frequency of distribution of personal hygiene products, 

including soap, shampoo and body wash and tissue paper, and we are 

ensuring the daily availability of bars of soap or soap dispensers at each sink 

for hand washing in all of our facilities; 

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 We advised our employees to remain home if they exhibit flu-like 

symptoms, and we have exercised flexible paid leave and paid time off 

policies to allow for employees to remain home if they exhibit flu-like 

symptoms or to care for a family member; 

 We procured additional cleaning equipment and sanitation products that are 

proven healthcare grade disinfectants; 

 We deployed specialized sanitation teams to sterilize high-contact areas at 

our facilities and have developed intensive schedules and procedures for the 

cleaning and disinfecting of facility spaces above and beyond normal 

cleaning activities; 

 At every one of our facilities, we have worked closely with our government 

agency partners and local health officials to develop COVID-19 emergency 

plans and testing policies for the individuals in our care; and 

 We engaged with our government agency partners to promptly suspend 

non-essential visitation at all of our facilities, and we have employed 

additional measures during the intake and entry process at all of our 

facilities to include screening specific to COVID-19, including temperature 

checks for all staff and any legally required visitors before entering our 

facilities, as well as, verbal medical screening questionnaires. 

30. Appended to the Q1 2020 10-Q as exhibits were signed certifications pursuant to 

SOX by the Individual Defendants, attesting that “the information contained in the [Q1 2020 10-

Q] fairly presents, in all material respects, the financial condition and results of operations of the 

Company.” 

31. On June 1, 2020, GEO Group released a statement entitled “GEO Group Has Taken 

Comprehensive Steps to Address and Mitigate the Risks of COVID-19 to Those in Our Care and 

Our Employees.” The statement touted the Company’s response procedures to COVID-19, stating, 

in relevant part: 

As the COVID-19 pandemic has impacted communities across the United States 

and around the world, our employees and facilities have also been impacted by the 

spread of COVID-19. Ensuring the health and safety of our employees and all those 

in our care has always been our number one priority. As a longstanding provider of 

essential government services, we have experience with the implementation of best 

practices for the prevention, assessment, and management of infectious diseases. 

 All of our facilities operate safely and without overcrowded conditions. 

 All of our facilities have access to regular handwashing with clean water 

and soap. 

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 All of our secure services facilities provide 24/7 access to healthcare. 

 All of our U.S. Immigration and Customs Enforcement (“ICE”) Processing 

Centers typically have approximately double the number of healthcare staff, 

compared to state correctional facilities. 

 Most of our facilities are equipped with Airborne Infection Isolation Rooms 

32. Further, the statement touted a list of steps that the Company purportedly 

implemented at the outset of the global pandemic, including: 

 We issued guidance to all our facilities, consistent with the guidance issued 

for correctional and detention facilities by the Centers for Disease Control 

and Prevention. 

 We updated our policies and procedures to include best practices for the 

prevention, assessment, and management of COVID-19, including the 

implementation of quarantine and cohorting procedures to isolate confirmed 

and presumptive cases of COVID-19, including medical isolation and the 

use of Airborne Infection Isolation Rooms. 

 We provided educational guidance to our employees and individuals in our 

care on the best preventative measures to avoid the spread of COVID-19 

such as frequent and careful handwashing; avoiding touching areas of the 

face, including facial hair; avoiding individuals exhibiting flu-like 

symptoms; proper cough and sneeze etiquette; social distancing 

requirements; and adjustments to laundry and meal schedules. 

 We increased the frequency of distribution of personal hygiene products, 

including soap, shampoo and body wash, and tissue paper, and we are 

ensuring the daily availability of bars of soap or soap dispensers at each sink 

for hand washing in all of our facilities. 

 We deployed specialized sanitation teams to sterilize high-contact areas of 

our facilities and have developed intensive schedules and procedures for the 

cleaning and disinfecting of facility spaces above and beyond normal 

cleaning activities. 

 We procured additional cleaning equipment and sanitation products that are 

proven healthcare grade disinfectants. 

 We advised our employees to remain home if they exhibit flu-like 

symptoms, and we have exercised flexible paid leave and Paid Time Off 

policies to allow for employees to remain home if they exhibit flu-like 

symptoms or to care for a family member. 

 We engaged with our government agency partners to promptly suspend 

non-essential visitation at all of our facilities, and we have employed 

additional measures during the intake and entry process at all of our 

facilities to include screening specific to COVID-19, including temperature 

checks for all staff and any legally required visitors before entering our 

facilities, as well as, verbal medical screening questionnaires. 

 We ordered and received swab kits for COVID-19 from a national supplier, 

and we enacted quarantine and testing policies for any employees who may 

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have come into contact with any individual who has tested positive for 

COVID-19. 

 At every one of our facilities, we have worked closely with our government 

agency partners and local health officials to develop COVID-19 emergency 

plans and testing policies for the individuals in our care. 

 In March of 2020, we started procuring additional Personal Protective 

Equipment and began issuing it as clinically needed at facilities impacted 

by COVID-19. 

 Over the course of April of 2020, we coordinated with our government 

agency partners to distribute Personal Protective Equipment, including 

facemasks to all staff, inmates, detainees, and residents as a precautionary 

measure at all of our Federal Bureau of Prisons facilities, ICE Processing 

Centers, U.S. Marshals facilities, state correctional facilities, local 

correctional facilities and jails, residential reentry centers, and youth 

services residential facilities. 

 As a service provider, GEO has fully disclosed all information related to 

COVID-19 testing, cases, and fatalities to our federal, state, and local 

government partners, as well as state and local health officials, throughout 

the course of the pandemic. 

33. The statements referenced in ¶¶ 19-32 were materially false and misleading because 

Defendants made false and/or misleading statements, as well as failed to disclose material adverse 

facts about the Company’s business, operational and compliance policies. Specifically, 

Defendants made false and/or misleading statements and/or failed to disclose that: (i) GEO Group 

maintained woefully ineffective COVID-19 response procedures; (ii) those inadequate procedures 

subjected residents of the Company’s halfway houses to significant health risks; (iii) accordingly, 

the Company was vulnerable to significant financial and/or reputational harm; and (iv) as a result, 

the Company’s public statements were materially false and misleading at all relevant times. 

The Truth Begins to Emerge 

34. On June 17, 2020, during pre-market hours, The Intercept published an article 

entitled “GEO Group’s Blundering Response to the Pandemic Helped Spread Coronavirus in 

Halfway Houses.” The article reported details of a significant COVID-19 outbreak at the 

Grossman Center, a halfway house in Leavenworth, Kansas, operated by GEO Group—which 

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“was for weeks the hardest hit federal halfway house in the country” in terms of confirmed cases 

of COVID-19. Citing interviews with residents of the Grossman Center, The Intercept

characterized GEO Group’s response as “blundering” and reported “that the virus spread not in 

spite of the facility’s efforts to contain it, but because of it.” According to the article, the Grossman 

Center continued to keep its residents in overcrowded conditions without enforcing personal 

protective measures even as COVID-19 diagnoses at the facility increased. 

35. For example, the article referenced photos of men in a crowded bunk in which 

“some wore masks but most did not,” and suggested that: 

Contrary to the claim that GEO Group was prepared from the outset to respond to 

the pandemic, one resident who arrived at the Grossman Center in March said the 

facility had done “absolutely nothing” to mitigate the virus, apart from suspending 

the 42-hour passes that allow residents to go see family, as ordered by the BOP. At 

one point, he said, “they taped up these benches and said that we had to sit, like, a 

certain distance apart from one another. ... But you have to understand, they have 

us in these units that are super small,” with a limited number of bathroom stalls, 

sinks, and showers. “So basically regardless of the protocols they try to do outside 

the unit, inside the unit, they literally have us shoved in on top of each other. So 

there’s really no way for us to have any type of distancing. It’s impossible.” 

Further, the article cited reports that residents were kept in the same areas as residents who tested 

positive for the virus, and that residents had to clean their areas themselves upon being moved 

from dorm to dorm. In addition, the article indicated that members of the staff continued to work 

despite feeling ill, and that residents were being placed in the halfway house even after receiving 

instructions to self-quarantine. Finally, the article stated, in relevant part, that: 

All of the residents told The Intercept that they were disturbed by the lack of 

urgency in providing medical care. “It’s pretty tough dealing with being so sick 

with Covid-19 in this facility because the people that run it have no concern for the 

fact that we’re actually sick,” one man said. “It’s just like statistical number 

processing.” Another resident called it worse than prison. “Mentally I’m going 

crazy,” they said. Despite the outdoor recreation area, they were not being allowed 

out for fresh air. “We’re in this room with only one window, and they have film 

over the window, so we can’t see outside.” 

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Today most of the people who spoke to The Intercept are no longer in the halfway 

house. The director has returned to work, and people are going back to work on the 

outside — although not at the Triumph plant. Otherwise, “it doesn’t seem like much 

has changed as far as their safety measures go,” one resident said. 

36. On this news, GEO Group’s stock price fell $1.03 per share, or 7.8%, to close at 

$12.17 per share on June 17, 2020. 

37. As a result of Defendants’ wrongful acts and omissions, and the precipitous decline 

in the market value of the Company’s securities, Plaintiff and other Class members have suffered 

significant losses and damages. 

PLAINTIFF’S CLASS ACTION ALLEGATIONS 

38. Plaintiff brings this action as a class action pursuant to Federal Rule of Civil 

Procedure 23(a) and (b)(3) on behalf of a Class, consisting of all those who purchased or otherwise 

acquired GEO Group securities during the Class Period (the “Class”); and were damaged upon the 

revelation of the alleged corrective disclosures. Excluded from the Class are Defendants herein, 

the officers and directors of the Company, at all relevant times, members of their immediate 

families and their legal representatives, heirs, successors or assigns and any entity in which 

Defendants have or had a controlling interest. 

39. The members of the Class are so numerous that joinder of all members is 

impracticable. Throughout the Class Period, GEO Group securities were actively traded on the 

NYSE. While the exact number of Class members is unknown to Plaintiff at this time and can be 

ascertained only through appropriate discovery, Plaintiff believes that there are hundreds or 

thousands of members in the proposed Class. Record owners and other members of the Class may 

be identified from records maintained by GEO Group or its transfer agent and may be notified of 

the pendency of this action by mail, using the form of notice similar to that customarily used in 

securities class actions. 

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40. Plaintiff’s claims are typical of the claims of the members of the Class as all 

members of the Class are similarly affected by Defendants’ wrongful conduct in violation of 

federal law that is complained of herein. 

41. Plaintiff will fairly and adequately protect the interests of the members of the Class 

and has retained counsel competent and experienced in class and securities litigation. Plaintiff has 

no interests antagonistic to or in conflict with those of the Class. 

42. Common questions of law and fact exist as to all members of the Class and 

predominate over any questions solely affecting individual members of the Class. Among the 

questions of law and fact common to the Class are: 

 whether the federal securities laws were violated by Defendants’ acts as alleged 

herein; 

 whether statements made by Defendants to the investing public during the Class 

Period misrepresented material facts about the business, operations and 

management of GEO Group; 

 whether the Individual Defendants caused GEO Group to issue false and 

misleading financial statements during the Class Period; 

 whether Defendants acted knowingly or recklessly in issuing false and misleading 

financial statements; 

 whether the prices of GEO Group securities during the Class Period were 

artificially inflated because of the Defendants’ conduct complained of herein; and 

 whether the members of the Class have sustained damages and, if so, what is the 

proper measure of damages. 

43. A class action is superior to all other available methods for the fair and efficient 

adjudication of this controversy since joinder of all members is impracticable. Furthermore, as the 

damages suffered by individual Class members may be relatively small, the expense and burden 

of individual litigation make it impossible for members of the Class to individually redress the 

wrongs done to them. There will be no difficulty in the management of this action as a class action. 

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44. Plaintiff will rely, in part, upon the presumption of reliance established by the fraudon-the-market doctrine in that: 

 Defendants made public misrepresentations or failed to disclose material facts 

during the Class Period; 

 the omissions and misrepresentations were material; 

 GEO Group securities are traded in an efficient market; 

 the Company’s shares were liquid and traded with moderate to heavy volume 

during the Class Period; 

 the Company traded on the NYSE and was covered by multiple analysts; 

 the misrepresentations and omissions alleged would tend to induce a reasonable 

investor to misjudge the value of the Company’s securities; and 

 Plaintiff and members of the Class purchased, acquired and/or sold GEO Group 

securities between the time the Defendants failed to disclose or misrepresented 

material facts and the time the true facts were disclosed, without knowledge of 

the omitted or misrepresented facts. 

45. Based upon the foregoing, Plaintiff and the members of the Class are entitled to a 

presumption of reliance upon the integrity of the market. 

46. Alternatively, Plaintiff and the members of the Class are entitled to the presumption 

of reliance established by the Supreme Court in Affiliated Ute Citizens of the State of Utah v. 

United States, 406 U.S. 128, 92 S. Ct. 2430 (1972), as Defendants omitted material information in 

their Class Period statements in violation of a duty to disclose such information, as detailed above. 

COUNT I 

 (Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Promulgated 

Thereunder Against All Defendants) 

47. Plaintiff repeats and re-alleges each and every allegation contained above as if fully 

set forth herein. 

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48. This Count is asserted against Defendants and is based upon Section 10(b) of the 

Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 promulgated thereunder by the SEC. 

49. During the Class Period, Defendants engaged in a plan, scheme, conspiracy and 

course of conduct, pursuant to which they knowingly or recklessly engaged in acts, transactions, 

practices and courses of business which operated as a fraud and deceit upon Plaintiff and the other 

members of the Class; made various untrue statements of material facts and omitted to state 

material facts necessary in order to make the statements made, in light of the circumstances under 

which they were made, not misleading; and employed devices, schemes and artifices to defraud in 

connection with the purchase and sale of securities. Such scheme was intended to, and, throughout 

the Class Period, did: (i) deceive the investing public, including Plaintiff and other Class members, 

as alleged herein; (ii) artificially inflate and maintain the market price of GEO Group securities; 

and (iii) cause Plaintiff and other members of the Class to purchase or otherwise acquire GEO 

Group securities and options at artificially inflated prices. In furtherance of this unlawful scheme, 

plan and course of conduct, Defendants, and each of them, took the actions set forth herein. 

50. Pursuant to the above plan, scheme, conspiracy and course of conduct, each of the 

Defendants participated directly or indirectly in the preparation and/or issuance of the quarterly 

and annual reports, SEC filings, press releases and other statements and documents described 

above, including statements made to securities analysts and the media that were designed to 

influence the market for GEO Group securities. Such reports, filings, releases and statements were 

materially false and misleading in that they failed to disclose material adverse information and 

misrepresented the truth about GEO Group’s finances and business prospects. 

51. By virtue of their positions at GEO Group, Defendants had actual knowledge of 

the materially false and misleading statements and material omissions alleged herein and intended 

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thereby to deceive Plaintiff and the other members of the Class, or, in the alternative, Defendants 

acted with reckless disregard for the truth in that they failed or refused to ascertain and disclose 

such facts as would reveal the materially false and misleading nature of the statements made, 

although such facts were readily available to Defendants. Said acts and omissions of Defendants 

were committed willfully or with reckless disregard for the truth. In addition, each Defendant 

knew or recklessly disregarded that material facts were being misrepresented or omitted as 

described above. 

52. Information showing that Defendants acted knowingly or with reckless disregard 

for the truth is peculiarly within Defendants’ knowledge and control. As the senior managers 

and/or directors of GEO Group, the Individual Defendants had knowledge of the details of GEO 

Group’s internal affairs. 

53. The Individual Defendants are liable both directly and indirectly for the wrongs 

complained of herein. Because of their positions of control and authority, the Individual 

Defendants were able to and did, directly or indirectly, control the content of the statements of 

GEO Group. As officers and/or directors of a publicly-held company, the Individual Defendants 

had a duty to disseminate timely, accurate, and truthful information with respect to GEO Group’s 

businesses, operations, future financial condition and future prospects. As a result of the 

dissemination of the aforementioned false and misleading reports, releases and public statements, 

the market price of GEO Group securities was artificially inflated throughout the Class Period. In 

ignorance of the adverse facts concerning GEO Group’s business and financial condition which 

were concealed by Defendants, Plaintiff and the other members of the Class purchased or 

otherwise acquired GEO Group securities at artificially inflated prices and relied upon the price of 

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the securities, the integrity of the market for the securities and/or upon statements disseminated by 

Defendants, and were damaged thereby. 

54. During the Class Period, GEO Group securities were traded on an active and 

efficient market. Plaintiff and the other members of the Class, relying on the materially false and 

misleading statements described herein, which the Defendants made, issued or caused to be 

disseminated, or relying upon the integrity of the market, purchased or otherwise acquired shares 

of GEO Group securities at prices artificially inflated by Defendants’ wrongful conduct. Had 

Plaintiff and the other members of the Class known the truth, they would not have purchased or 

otherwise acquired said securities, or would not have purchased or otherwise acquired them at the 

inflated prices that were paid. At the time of the purchases and/or acquisitions by Plaintiff and the 

Class, the true value of GEO Group securities was substantially lower than the prices paid by 

Plaintiff and the other members of the Class. The market price of GEO Group securities declined 

sharply upon public disclosure of the facts alleged herein to the injury of Plaintiff and Class 

members. 

55. By reason of the conduct alleged herein, Defendants knowingly or recklessly, 

directly or indirectly, have violated Section 10(b) of the Exchange Act and Rule 10b-5 

promulgated thereunder. 

56. As a direct and proximate result of Defendants’ wrongful conduct, Plaintiff and the 

other members of the Class suffered damages in connection with their respective purchases, 

acquisitions and sales of the Company’s securities during the Class Period, upon the disclosure 

that the Company had been disseminating misrepresented financial statements to the investing 

public. 

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COUNT II 

 (Violations of Section 20(a) of the Exchange Act Against The Individual Defendants) 

57. Plaintiff repeats and re-alleges each and every allegation contained in the foregoing 

paragraphs as if fully set forth herein. 

58. During the Class Period, the Individual Defendants participated in the operation 

and management of GEO Group, and conducted and participated, directly and indirectly, in the 

conduct of GEO Group’s business affairs. Because of their senior positions, they knew the adverse 

non-public information about GEO Group’s misstatement of income and expenses and false 

financial statements. 

59. As officers and/or directors of a publicly owned company, the Individual 

Defendants had a duty to disseminate accurate and truthful information with respect to GEO 

Group’s financial condition and results of operations, and to correct promptly any public 

statements issued by GEO Group which had become materially false or misleading. 

60. Because of their positions of control and authority as senior officers, the Individual 

Defendants were able to, and did, control the contents of the various reports, press releases and 

public filings which GEO Group disseminated in the marketplace during the Class Period 

concerning GEO Group’s results of operations. Throughout the Class Period, the Individual 

Defendants exercised their power and authority to cause GEO Group to engage in the wrongful 

acts complained of herein. The Individual Defendants therefore, were “controlling persons” of 

GEO Group within the meaning of Section 20(a) of the Exchange Act. In this capacity, they 

participated in the unlawful conduct alleged which artificially inflated the market price of GEO 

Group securities. 

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61. Each of the Individual Defendants, therefore, acted as a controlling person of GEO 

Group. By reason of their senior management positions and/or being directors of GEO Group, 

each of the Individual Defendants had the power to direct the actions of, and exercised the same 

to cause, GEO Group to engage in the unlawful acts and conduct complained of herein. Each of 

the Individual Defendants exercised control over the general operations of GEO Group and 

possessed the power to control the specific activities which comprise the primary violations about 

which Plaintiff and the other members of the Class complain. 

62. By reason of the above conduct, the Individual Defendants are liable pursuant to 

Section 20(a) of the Exchange Act for the violations committed by GEO Group. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff demands judgment against Defendants as follows: 

A. Determining that the instant action may be maintained as a class action under Rule 

23 of the Federal Rules of Civil Procedure, and certifying Plaintiff as the Class representative; 

B. Requiring Defendants to pay damages sustained by Plaintiff and the Class by reason 

of the acts and transactions alleged herein; 

C. Awarding Plaintiff and the other members of the Class prejudgment and postjudgment interest, as well as their reasonable attorneys’ fees, expert fees and other costs; and 

D. Awarding such other and further relief as this Court may deem just and proper. 

DEMAND FOR TRIAL BY JURY 

Plaintiff hereby demands a trial by jury. 

Dated: July 7, 2020 

Respectfully submitted, 

/s/ Jayne A. Goldstein 

Jayne A. Goldstein 

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Florida Bar Identification Number: 144088 

SHEPHERD, FINKELMAN, MILLER & 

SHAH, LLP 

1625 North Commerce Parkway, 

Suite 320 

Fort Lauderdale, FL 33326 

Telephone: 954-515-0123 

Facsimile: 866-300-7367 

Email: jgoldstein@sfmslaw.com

POMERANTZ LLP 

James M. LoPiano 

(pro hac vice application forthcoming) 

600 Third Avenue, 20th Floor 

New York, New York 10016 

Telephone: (212) 661-1100 

Facsimile: (212) 661-8665 

Email: jlopiano@pomlaw.com 

BRONSTEIN, GEWIRTZ & 

GROSSMAN, LLC 

Peretz Bronstein 

(pro hac vice application forthcoming) 

60 East 42nd Street, Suite 4600 

New York, NY 10165 

Telephone: (212) 697-6484 

Facsimile: (212) 697-7296 

Email: peretz@bgandg.com 

Attorneys for Plaintiff

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