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EXHIBIT A

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 9:20-81063-CIV-SMITH

STEVE HARTEL, Individually and on Behalf 

of All Others Similarly Situated,

Plaintiff,

v. 

THE GEO GROUP, INC., et al., 

Defendants.

 

[PROPOSED] ORDER PRELIMINARILY APPROVING SETTLEMENT 

AND FOR PROVIDING NOTICE TO THE CLASS

WHEREAS, an action is pending before this Court entitled Hartel v. The GEO Group, Inc., 

et al., Case No. 9:20-cv-81063-RS (S.D. Fla.) (the “Action”);1

WHEREAS, the Parties to the Action entered into the Stipulation, which together with the 

Exhibits annexed thereto, sets forth the terms and conditions for proposed Settlement of the Action; 

WHEREAS, pursuant to Federal Rule of Civil Procedure (“Rule”) 23(e), Plaintiffs seek

preliminary approval of Settlement of the Action, and for approval of the form and manner of 

providing notice of Settlement to members of the Settlement Class, in accordance with the 

Stipulation; and

WHEREAS, pursuant to Rule 23(a) and 23(b), Plaintiffs seek certification of the 

Settlement Class for purposes of Settlement. 

AND NOW THIS ___ day of _______________ 2023, the Court having considered 

Plaintiffs’ unopposed Motion for Preliminary Approval of Settlement and good cause appearing 

1 Unless otherwise noted, capitalized terms used herein have the same meaning ascribed to them 

as in the Stipulation and Agreement of Settlement dated May 1, 2023 (the “Stipulation”). 

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therefore, IT IS HEREBY ORDERED THAT: 

1. Pursuant to Rule 23(e), the Court preliminarily approves the Settlement, in 

accordance with the Stipulation and the Exhibits annexed thereto, subject to further consideration 

at the Settlement Hearing described below. 

2. Pursuant to Rule 23(a) and 23(b), the Court approves certification of the Settlement 

Class, as defined in the Stipulation, for purposes of Settlement. 

3. Pursuant to the requirements of Rule 23(e), the Private Securities Litigation Reform 

Act of 1995, 15 U.S.C. § 78u-4(a)(7), and due process, the Court approves, as to form and content,

the Notice of Pendency and Proposed Settlement of Class Action (the “Notice”), the Summary of 

Proposed Settlement of Class Action (the “Summary Notice”), the Proof of Claim and Release 

form (“Proof of Claim”), and Postcard Notice, annexed to the Stipulation as Exhibits A-1, A-2, A3, and A-4, respectively.

4. Lead Counsel are responsible for the dissemination of notice of Settlement to the 

Settlement Class, and the Court approves its selection of the firm of Epiq Class Action and Claims 

Solutions, Inc. (the “Claims Administrator”) to serve as the claims administrator for the Settlement 

Class. 

5. All fees, costs, and expenses incurred in identifying and notifying Settlement Class 

Members shall be paid for by the Settlement Fund, as set forth in the Stipulation, and in no event 

shall any of the Released Persons bear any responsibility for such fees, costs, or expenses. 

6. Notwithstanding the foregoing, Defendants shall be responsible for the costs and 

expenses of providing to Lead Counsel or the Claims Administrator reasonably available transfer 

records for purposes of disseminating notice of Settlement to the Class, as set forth in the 

Stipulation. 

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7. GEO shall use its best efforts to provide, or cause to be provided, to Lead Counsel 

or the Claims Administrator reasonably available transfer records reflecting ownership or 

acquisition of GEO common stock during the Class Period, in electronic searchable form, such as 

Excel, containing relevant information including, without limitation, names, mailing addresses and 

email addresses, if available, no later than ten (10) calendar days after the entry of this Order. 

8. No later than twenty-one (21) calendar days after the entry of this Order (the 

“Notice Date”), Lead Counsel and/or the Claims Administrator shall commence mailing the 

Postcard Notice by First-Class Mail to all potential Settlement Class Members who can be 

identified with reasonable efforts and post the Stipulation, and Exhibits annexed thereto, on the 

Settlement website, www.HartelSecuritiesSettlement.com.

9. No later than fourteen (14) calendar days after the Notice Date, Lead Counsel 

and/or the Claims Administrator shall cause the Summary Notice to be published once in a national 

business newswire. 

10. No later than seven (7) calendar days prior to the Settlement Hearing, Lead Counsel 

shall provide the Court, and all parties to the Action, proof of the mailing the Postcard Notice and 

publication of the Summary Notice, by way of an affidavit or declaration.

11. All opening briefs in support of final approval of the Settlement, the Plan of 

Allocation, and Lead Counsel’s application for an award of attorneys’ fees and expenses shall be 

filed no later than forty-two (42) calendar days prior to the Settlement Hearing, providing all 

documents in support thereof. 

12. Settlement Class Members shall be bound by all determinations and judgments in 

the Action concerning the Settlement, including, but not limited to, any release provided for 

therein, whether favorable or unfavorable to the Settlement Class, whether or not such Settlement 

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Class Members submit a Proof of Claim or otherwise seek or obtain by any means any distribution 

from the Settlement Fund.

13. Settlement Class Members who wish to participate in the Settlement shall complete 

and submit a Proof of Claim no later than one hundred and twenty (120) calendar days after the 

Notice Date. Any Settlement Class Member who does not timely submit a Proof of Claim within 

the time provided for, shall be barred from sharing in the distribution of the proceeds of the Net 

Settlement Fund, unless otherwise ordered by the Court, but will in all other respects be subject to 

and bound by the provisions of the Stipulation and the final Judgment, if entered. Notwithstanding 

the foregoing, Lead Counsel may, in its discretion, accept late-submitted claims for processing by 

the Claims Administrator so long as distribution of the Net Settlement Fund to Authorized 

Claimants is not materially delayed thereby.

14. Any Settlement Class Member may enter an appearance in the Action, at his, her, 

or its own expense, individually or through counsel of their own choice. Any Settlement Class 

Member who does not enter an appearance will be represented by Lead Counsel.

15. Any Settlement Class Member may, upon request, be excluded from or “opt out” 

of the Settlement Class. To “opt out”, the Settlement Class Member must submit to the Claims 

Administrator a signed request for exclusion (“Request for Exclusion”) no later than twenty-eight

(28) calendar days prior to the Settlement Hearing. A Request for Exclusion must state: (i) the 

name, address, and telephone number of the Person or Entity requesting exclusion; (ii) a list 

identifying the number of shares of GEO common stock owned during the Class Period, the date 

of each purchase or acquisition during the Class Period, the price paid for each share of GEO stock, 

the number of shares of GEO common stock sold during the Class Period, if any, the date of each 

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sale, and the price at which the shares were sold; and (iii) that the identified Person or Entity wishes 

to be excluded from the Settlement Class. 

16. Any Settlement Class Member who submits a valid and timely Request for 

Exclusion in the manner set forth in the Notice and herein shall have no rights under the Settlement, 

shall not share in the distribution of the Net Settlement Fund, and shall not be bound by the 

Settlement or final Judgment, if entered. Unless otherwise ordered by the Court, any person or 

entity who purchased or otherwise acquired GEO common stock during the Class Period who fails 

to timely opt out of the Settlement Class shall be deemed to have waived his, her, or its right to 

exclusion, and shall be barred from requesting exclusion from the Settlement Class in this or any 

other proceeding.

17. Lead Counsel and/or the Claims Administrator shall provide copies of all Requests 

for Exclusion to Defendants no later than five (5) business days after their receipt by the Claims 

Administrator. Notwithstanding the foregoing, all Requests for Exclusion shall be provided to 

Defendants no later than twenty-one (21) calendar days before the Settlement Hearing. Any laterreceived Requests for Exclusion shall be provided to Defendants within one (1) business day of 

receipt. Lead Counsel shall also provide Defendants any written revocation of Requests for 

Exclusion promptly upon receipt and as expeditiously as possible.

18. Any Settlement Class Member may file a written objection to the preliminarily 

approved Settlement and show cause why the Settlement of the Action should or should not be 

approved as fair, reasonable, and adequate, why final Judgment should or should not be entered 

thereon, why the Plan of Allocation should or should not be approved, why Lead Counsel’s 

application for attorneys’ fees and expenses should or should not be approved, or why expenses 

or Plaintiffs’ PSLRA Award should or should not be awarded to Plaintiffs. Any Settlement Class 

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Member or other Person who wishes to contest the Settlement must deliver by hand or send via

First-Class Mail, to all Parties to the Action, written objections and copies of any papers and briefs, 

such that they are received, not simply post-marked, and be filed with the Clerk of the United 

States District Court for the Southern District of Florida, no later than twenty-eight (28) calendar 

days prior to the Settlement Hearing.

19. Any written objections, filings, and/or other submissions must include: (i) the 

name, address, and telephone number of the Person or Entity objecting and must be signed by the 

objector; (ii) a statement of the objection or objections, and the specific reasons for each objection, 

including any legal and evidentiary support the objector wishes to bring to the Court’s attention 

and whether the objection applies only to the objector, a specific subset of the Settlement Class, 

or to the entire Settlement Class; and (iii) documents sufficient to prove membership in the 

Settlement Class, including the objector’s purchases or acquisitions, and sales, if any, of GEO 

common stock during the Class Period, the dates of each transaction, the number of shares 

purchased, acquired, or sold, and the price paid or received for each share purchased, acquired, or 

sold.

20. Any Settlement Class Member or other Person who timely and validly objects may 

attend the Settlement Hearing but is not required to do so. Persons who wish to be heard orally in 

opposition to approval of the Settlement, the Plan of Allocation, and/or the award of attorneys’ 

fees and expenses to Lead Counsel or expenses or awards to Plaintiffs are required to indicate their 

intention to appear at the Settlement Hearing in their written objection. Persons who intend to 

appear and present evidence at the Settlement Hearing must include in their written objections the 

identity of any witness they may call to testify and exhibits they intend to introduce into evidence. 

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21. Any Settlement Class Member who does not make his, her, or its objection in the 

manner provided in the Notice and herein shall be deemed to have waived such objection and shall 

forever be foreclosed from making any objection to the fairness or adequacy of the proposed 

Settlement, to the Plan of Allocation, or to the award of attorneys’ fees and expenses to Lead 

Counsel or expenses or awards to Plaintiffs, unless otherwise ordered by the Court. 

22. The deadline to file any replies to any objections shall be fourteen (14) calendar 

days prior to the Settlement Hearing. 

23. None of the Defendants, their counsel, or any Released Persons shall have any 

responsibility for: (i) the Plan of Allocation; (ii) any application for attorneys’ fees or expenses 

submitted by Lead Counsel; or (iii) expenses or awards to Plaintiffs. Such matters will be 

considered separately from the fairness, reasonableness, and adequacy of the Settlement. Any 

order or proceeding relating to the Plan of Allocation or any application for attorneys’ fees or 

expenses, or any appeal from any order relating thereto or reversal or modification thereof, shall 

not operate to terminate or cancel the Settlement, or affect or delay the finality of the Judgment 

and the Settlement of the Action.

24. All funds held by the Escrow Agent shall be deemed and considered to be in 

custodia legis of the Court and shall remain subject to the jurisdiction of the Court until such time 

as such funds shall be distributed pursuant to the Stipulation and/or further order(s) of the Court.

25. The Court shall hold a Settlement Hearing on _____________, 2023, at ____ __.m., 

a date that is at least one hundred (100) calendar days from the entry of this Order, to determine: 

(a) whether the Settlement of the Action, in accordance with the Stipulation, is fair, reasonable, 

and adequate and warrants final approval; (b) whether a Judgment should be entered; (c) whether 

the Plan of Allocation is fair, reasonable, and adequate and should be approved; (d) the amount of 

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fees and expenses to be awarded to Lead Counsel and Plaintiffs; and (e) any such other matters as 

the Court may deem appropriate. 

26. The Court reserves the right to adjourn the date of the Settlement Hearing, or hold 

the Settlement Hearing by video or telephonically, without further notice to Settlement Class 

Members, and retains jurisdiction to consider all further applications arising out of or connected 

with the proposed Settlement. The Court may approve the Settlement, with such modifications as 

may be agreed to by the Settling Parties, if appropriate, without further notice to the Settlement 

Class.

27. If the Settlement is not approved or consummated for any reason whatsoever, this 

Order shall be rendered null and void, and be of no further force and effect, except as otherwise 

provided by the Stipulation. In such event, this Order, the Stipulation, and the Settlement and all 

proceedings had in connection therewith shall be without prejudice to the rights of the Settling 

Parties status quo ante as of December 16, 2022.

28. Unless otherwise ordered by the Court, all proceedings in the Action are stayed, 

except as may be necessary to implement the Settlement or comply with the terms of the 

Stipulation or other agreement of the Settling Parties. Pending final approval of the proposed 

Settlement, neither Plaintiffs nor any Settlement Class Member, directly or indirectly, 

representatively, or in any other capacity, shall commence or prosecute against any of the 

Defendants, any action or proceeding in any court or tribunal asserting any of the Released Claims.

IT IS SO ORDERED.

DATED: _______________, 2023 _____________________________

RODNEY SMITH

UNITED STATES DISTRICT JUDGE

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EXHIBIT A-1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 9:20-81063-CIV-SMITH

STEVE HARTEL, Individually and on Behalf 

of All Others Similarly Situated,

Plaintiff,

v. 

THE GEO GROUP, INC., et al., 

Defendants.

NOTICE OF PENDENCY AND PROPOSED 

SETTLEMENT OF CLASS ACTION

A United States Court authorized this Notice. This is not a solicitation from a lawyer.

TO: ALL PERSONS OR ENTITIES WHO PURCHASED OR OTHERWISE 

ACQUIRED THE GEO GROUP, INC. COMMON STOCK FROM NOVEMBER 

9, 2018 TO AUGUST 5, 2020, BOTH DATES INCLUSIVE (THE “SETTLEMENT 

CLASS”).

1

PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. YOUR RIGHTS 

MAY BE AFFECTED BY LEGAL PROCEEDINGS IN THIS ACTION. IF YOU ARE A 

SETTLEMENT CLASS MEMBER, AS DESCRIBED HEREIN, YOU MAY BE ENTITLED 

TO A PORTION OF THE PROCEEDS OF THE PROPOSED SETTLEMENT DESCRIBED 

IN THIS NOTICE. PLEASE NOTE THAT TO RECEIVE YOUR PORTION OF THE 

PROPOSED SETTLEMENT PROCEEDS, YOU MUST SUBMIT A VALID PROOF OF 

CLAIM AND RELEASE FORM (“PROOF OF CLAIM”) POSTMARKED OR SUBMITTED 

ONLINE ON OR BEFORE __________. 

Excluded from the Settlement Class are (i) Defendants; (ii) the Officers and directors of GEO 

currently and during the Class Period; (iii) Immediate Family Members of any such excluded 

persons; (iv) the legal representatives, heirs, successors, or assigns of any such excluded 

persons or entities; and (v) any entity in which any such excluded party has, or had during the 

Class Period, a controlling interest. 

1

 All capitalized terms used in this Notice that are not otherwise defined herein shall have 

the meanings ascribed to them in the Stipulation and Agreement of Settlement dated May 1, 2023 

(the “Stipulation”). The Stipulation is available at www.HartelSecuritiesSettlement.com. 

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Shares and Time Period: The GEO Group, Inc. (GEO) (“GEO”) common stock purchased or 

otherwise acquired from November 9, 2018 to August 5, 2020, both dates inclusive (the “Class 

Period”). 

Settlement Fund: $3,000,000.00 in cash. Your recovery will depend on the number of shares 

purchased or acquired, the timing of your purchases or acquisitions, and any sales of the included 

shares. Depending on the number of eligible shares that participate in the settlement and when 

those shares were purchased and sold, Lead Plaintiffs estimate the average cash recovery per share 

of common stock will be approximately $0.055 per share (assuming claims representing all 

damaged shares are filed) before deduction of court-approved fees, expenses, and awards.

Reasons for Settlement: Lead Plaintiffs believe that the proposed settlement is fair, reasonable, 

adequate to, and in the best interest of the Settlement Class. Lead Plaintiffs, and their counsel, 

reached this conclusion after investigating and considering, among other things, the strengths and 

weakness of Lead Plaintiffs’ claims against Defendants, including Defendants’ contentions that 

the claims are entirely without merit, the uncertainties of complex litigation, the legal and factual 

defenses available to Defendants, and the concrete benefits provided by the settlement to the 

Settlement Class Members. The proposed settlement agreement was entered into after extended 

mediation proceedings. Defendants expressly deny that Lead Plaintiffs have asserted any valid 

claims as to any of them, and expressly deny any and all allegations of fault, liability, wrongdoing, 

or damages whatsoever. Defendants are nevertheless willing to settle to avoid the continuing 

burden, expense, inconvenience, and distraction of this Action, and to avoid the ongoing risk of

litigation. Likewise, Lead Plaintiffs and the Settlement Class also avoid the costs and risks 

associated with continued litigation, including the danger of no recovery for Settlement Class 

Members. 

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Potential Outcome of the Case if not Settled: The parties vigorously disagree on both liability 

and damages. Continuing with the case could have resulted in dismissal or loss at trial. Further, 

the two sides do not agree on the amount of money that could have been won if Lead Plaintiffs 

prevailed at trial. The issues on which the parties disagree include, but are not limited to: (1) the 

method for determining whether the price of GEO common stock was artificially inflated during 

the relevant period; (2) the amount of any such inflation; (3) the extent that various statements 

and/or omissions alleged by Lead Plaintiffs were materially false or misleading; (4) the extent that 

various statements and/or omissions alleged by Lead Plaintiffs influenced the trading price of GEO 

common stock during the Class Period; and (5) whether the statements and/or omissions alleged 

were material, false, misleading, or otherwise actionable under the securities laws. 

Attorneys’ Fees and Expenses: Lead Plaintiffs are represented by Lead Counsel. Lead Counsel 

has not received any payment for their work investigating the facts, conducting this litigation, or 

negotiating the proposed settlement on behalf of Lead Plaintiffs and the Settlement Class, nor have 

they been reimbursed for its out-of-pocket expenditures. If the settlement is approved by the Court, 

Lead Counsel will ask the Court for an award of attorneys’ fees not to exceed 33% of the 

Settlement Fund, and reimbursement of out-of-pocket litigation expenses not to exceed $40,000

to be paid from the Settlement Fund. If the above amounts are requested and approved by the 

Court, the average cost per share of common stock will be $0.018. In addition, a Plaintiffs’ PSLRA 

Award for the time and expenses incurred by the Lead Plaintiffs will be requested, not to exceed 

$5,000.

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Your Legal Rights and Options in this Proposed Class Action Settlement: 

SUBMIT A CLAIM FORM The only way to get a payment.

EXCLUDE YOURSELF Get no payment. This is the only option that 

allows you to participate in another lawsuit 

against the Defendants relating to the legal 

claims in this case. 

OBJECT You may write to the Court if you do not like 

this Settlement. 

GO TO A HEARING You may ask to speak in Court about the 

fairness of the settlement. 

DO NOTHING Get no payment.

Deadlines to Exercise Your Legal Rights and Options: 

Submit Claim: ______________, 2023 

Request Exclusion: ______________, 2023 

File Objection: ______________, 2023 

Court Hearing on Fairness of Settlement: __________, 2023 

Distribution of Settlement Funds: The Court overseeing this Action must decide whether to 

approve the settlement. Payments will be made if the Court approves the settlement and, if there 

are any appeals, after appeals are resolved. Please be patient. 

For More Information: For more information regarding the Action or this Notice, please visit

www HartelSecuritiesSettlement.com, or direct requests for information may be sent to: 

Claims Administrator: 

Hartel Securities Settlement

c/o Epiq

P.O. Box 3729

Portland, OR 97208-3729 

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Lead Counsel:

LEVI & KORSINSKY, LLP

Nicholas I. Porritt, Esq. 

Adam M. Apton, Esq.

55 Broadway, 4th Floor 

New York, New York 10006 

nporritt@zlk.com 

aapton@zlk.com 

FREEDMAN NORMAND FRIEDLAND LLP

Velvel (Devin) Freedman, Esq. 

Ivy T. Ngo, Esq. 

Constantine P. Economides, Esq. 

1 SE 3rd Avenue, Suite 1240 

Miami, FL 33131 

vel@fnf.law 

ingo@fnf.law 

ceconomides@fnf.law

The sending of this Notice should not be construed as any indication of the Court’s view as to 

the merits of any claims or defenses asserted by any party to this Action. 

BASIC INFORMATION

1. Why Did I Get This Notice Package?

You or someone in your family may have purchased or acquired the publicly traded shares 

of GEO common stock listed above between November 9, 2018 and August 5, 2020. 

Pursuant to an order issued by the Court overseeing this Action, you received this Notice 

because you have a right to know about the proposed settlement and about your rights and options 

as a potential member of the Settlement Class before the Court decides whether to approve the 

settlement. If the Court approves the proposed settlement and after any objections or appeals are 

resolved, the Claims Administrator appointed by the Court will distribute all payments allowed 

under the settlement. 

This package explains the lawsuit, the proposed settlement, including, what benefits are 

available, who is eligible for them, and how to get them, and your legal rights and options. 

2. What is this Lawsuit About? 

The Court in charge of the case is the United States District Court for the Southern District 

of Florida, and the case is known as Hartel v. The GEO Group, Inc. et al., Case No. 9:20-cvCase 9:20-cv-81063-RS Document 86 Entered on FLSD Docket 05/08/2023 Page 55 of 92
6

81063-RS. The person who files a lawsuit is called the plaintiff or plaintiffs, and the company 

and/or individuals sued are called Defendants. 

Lead Plaintiffs brought this lawsuit, which the Court subsequently narrowed. The only 

remaining allegations are that Defendants acted with scienter when making false and materially 

misleading statements and/or omissions about GEO’s pending lawsuits, including but not limited 

to: (1) the Company did not expect any pending claims or lawsuits to have a material adverse effect 

on its financial condition, results of operations, or cash flows; (2) at all relevant times, the

Company had not recorded an accrual relating to these matters; and (3) the Company did not expect 

the outcome of any pending claims or legal proceedings to have a material adverse effect on its 

financial condition, results of operations or cash flows. Plaintiffs allege that the alleged false and 

materially misleading statements and/or omissions induced Plaintiff and other similarly situated 

shareholders to purchase shares of GEO common stock at artificially inflated prices. Lead 

Plaintiffs further allege that when the truth concerning GEO’s pending lawsuits was revealed, the 

value of GEO common stock declined and, as a result, Lead Plaintiffs and other members of the 

Settlement Class suffered damages. 

Defendants deny each of the claims and all allegations of wrongdoing made by Plaintiffs 

in this lawsuit. Defendants further deny that Lead Plaintiffs and the Settlement Class were entitled 

to recover anything in this lawsuit. The Court has not decided who is right. 

3. Why Is This a Class Action? 

In a class action, one or more people or entities called class representatives sue on behalf 

of people who have similar claims. This collective group of people is referred to as the class and 

each individual person with similar claims is considered a class member. One court is designated 

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to resolve the claims for all class members, except for those who exclude themselves from the 

class. The Honorable Judge Rodney Smith is overseeing this lawsuit. 

4. Why Is There a Settlement?

Lead Counsel and counsel for Defendants participated in an out of court process known as 

mediation. Mediation is alternative method to resolving legal disputes rather than waiting for the 

court to decide. The Court has yet to decide whether Lead Plaintiffs or Defendants are right in this 

case. 

During mediation, the parties discussed, among other things, the claims and potential 

defenses, the parties’ positions on damages, the evidence to be presented at trial, the risks of 

continuing litigation, and other important factual and legal issues. Following these negotiations, 

the parties agreed to settle all claims of the Settlement Class against the Defendants. By entering 

into the agreement to settle, Defendants do not concede the truth of any of the claims against them. 

Lead Plaintiffs believe that the claims asserted in this Action have merit and that the 

evidence presented to date supports their allegations. However, Lead Plaintiffs recognize and 

acknowledge the expense and length of continued proceedings, trial, and possible appeals, and 

have considered the uncertain outcome and the risk of any litigation, especially complex actions 

such as this lawsuit. They are also mindful of the inherent problems of proof under the federal 

securities laws asserted in this case, and the potential defenses available to Defendants. 

The proposed settlement allows the Settlement Class to avoid the costs and risks associated 

with continued litigation, and eligible Settlement Class Members who make valid claims will 

receive meaningful compensation from the Settlement Fund. Lead Plaintiffs and Lead Counsel 

believe the proposed settlement is in the best interest of the Settlement Class. 

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CLASS MEMBERS TO RECEIVE SETTLEMENT PROCEEDS 

 5. How Do I Know if I Am A Class Member?

Settlement Class Members are eligible to receive a portion of the settlement proceeds. The 

Settlement Class includes all Persons and entities who purchased or otherwise acquired GEO

common stock between November 9, 2018 and August 5, 2020, both dates inclusive, except those 

that are excluded, as described below.

6. What Are the Exceptions to Being Included In The Class? 

You are not a Settlement Class Member if you are: (i) one of the Defendants named in the 

lawsuit; (ii) the Officers and directors of GEO currently and during the Class Period; (iii) 

Immediate Family Members of any such excluded persons; (iv) the legal representatives, heirs, 

successors, or assigns of any such excluded persons or entities; and (v) any entity in which any 

such excluded party has, or had during the Class Period, a controlling interest. 

Further, if you only sold GEO common stock between November 9, 2018 and August 5, 

2020, that alone does not make you a Settlement Class Member. In other words, in addition to any 

sales made during the Class Period, you needed to have made at least one purchase or acquisition 

of GEO common stock during the Class Period to be a Settlement Class Member. 

7. What Do I Do If I Am Still Not Sure If I Am A Class Member?

If you are still not sure whether you are included in the Settlement Class, you can ask for 

free help. You can contact the Claims Administrator toll-free at 877-589-2242, or you can fill out 

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and return the Proof of Claim and Release Form enclosed with this Notice package, to see if you 

qualify. 

BENEFITS PROVIDED BY THE SETTLEMENT 

8. What Does the Settlement Provide?

Defendants have agreed to a settlement total of $3,000,000.00 in cash. The Settlement 

Fund, less taxes, approved costs, fees, and expenses (the “Net Settlement Fund”), will be divided 

amongst all eligible Settlement Class Members who submit a valid Proof of Claim and Release 

Form, known as Authorized Claimants. 

9. How Much Will My Payment Be? 

Your portion of the Net Settlement Fund will depend on several things, including, how 

many Settlement Class Members submit timely and valid Proof of Claim and Release Forms, the 

total recognized losses represented by the valid Proof of Claim and Release Forms submitted, the 

total number of shares of GEO common stock you purchased or acquired during the Class Period, 

how much you paid for your shares, when you purchased or acquired your shares, and if you sold 

your shares and for how much. 

By following the instructions in the Plan of Allocation, you can calculate what is called 

your Recognized Loss. An Authorized Claimant’s Recognized Loss depends upon the number of

shares of GEO common stock held at certain points in time during the Class Period. The Plan of 

Allocation also takes into consideration the limitation on damages set by governing federal law, 

the advice of experts, and the principles of economic loss articulated by the U.S. Supreme Court. 

For this settlement, the following table provides an average per-share amount of potential damages 

for purposes of calculating an Authorized Claimant’s Recognized Loss: 

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CALCULATION OF RECOGNIZED LOSS

Date Shares Sold

Date Shares

Purchased

11/09/2018-

07/16/2019

07/17/2019-

08/05/2020

08/06/2020-

Present

11/09/2018-

07/16/2019 $0 $1.48 $2.25 

07/17/2019-

08/05/2020 N/A $0 $0.77 

Please note that it is unlikely that you will receive all your Recognized Loss. After all 

Settlement Class Members have submitted their Proof of Claim and Release Forms, the payment 

you receive will be a portion of the Net Settlement Fund equal to your Recognized Loss divided 

by the total of all Authorized Claimant’s Recognized Losses. Likewise, this formula is not intended 

to be an estimate of a Settlement Class Member’s actual losses or what might have been 

recoverable after a trial. 

The Plan of Allocation also includes the following provisions: 

1) An Authorized Claimant will only have a Recognized Loss in connection with 

damaged shares;

2) There shall be no Recognized Loss attributed to any GEO securities other than 

common stock or to any shares of common stock purchased on a foreign exchange;

3) The date of a purchase or sale is the “trade” date and not the “settlement” date;

4) The last-in, first-out basis (“LIFO”) will be applied to both purchases and sales

when applicable; 

5) Shares purchased as a result of covering a short position will not result in a 

Recognized Loss; 

6) Exercise of option contracts or the conversion of preferred stock into common stock 

will be considered to be purchases or sales of common stock as of the date of the 

exercise or conversion. Your purchase or sale price will be the exercise price for 

the option, unless otherwise stated herein; 

7) No cash payment will be made on a claim where the potential distribution amount 

is less than $10. Please be advised that if you did not incur a Recognized Loss as 

defined in the Plan of Allocation, you will not receive a cash distribution from the 

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11

Net Settlement Fund, but you will be bound by all determinations and judgments 

of the Court in connection with the Settlement, including being barred from 

asserting any of the Released Claims against the Releasees; 

8) No person shall have any claim against Lead Counsel, or the Claims 

Administrator or other agent designated by Lead Counsel, based on the distribution 

made substantially in accordance with the Stipulation and this Plan of Allocation, 

or further orders of the Court. In addition, Defendants and Defendants’ Counsel 

have no responsibility or liability whatsoever for the Plan of Allocation, the 

administration of the settlement, or the distribution to Settlement Class Members, 

and no person shall have any claim against Defendants or Defendants’ Counsel 

based on the Plan of Allocation, the administration of the settlement, or the 

distribution to the Settlement Class Members; and

9) Settlement Class Members who do not submit a valid Proof of Claim will not share 

in the settlement proceeds. Settlement Class Members who do not either submit a 

request for exclusion or submit a valid Proof of Claim will nevertheless be bound 

by the settlement and the Order and Final Judgment of the Court dismissing the 

Action. 

SUBMITTING A PROOF OF CLAIM FORM

 10. How Do I Receive A Portion Of The Settlement Proceeds? 

To qualify for payment, you must be an eligible Settlement Class Member and you must 

submit a valid Proof of Claim and Release Form before the deadline. A Proof of Claim and Release 

Form is enclosed with this Notice. Read the instructions carefully, fill out the form, include all 

required documents identified in the form, sign it, and mail it in the enclosed envelope postmarked 

no later than __________. You can also submit a claim online at 

www.HartelSecuritiesSettlement.com. 

11. When Will I Get My Payment? 

The Court will hold a hearing on __________, 2023, to decide whether to approve the 

settlement. If Judge Smith approves the proposed settlement, there is the possibility of appeals

and/or objections. It is always uncertain whether these appeals and/or objections can be resolved, 

and resolving them can take time, perhaps several years. Everyone who sends in a Proof of Claim

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and Release Form will be informed of the determination with respect to their claim. Please be 

patient. 

12. What Am I Giving Up To Collect A Settlement Payment?

In return for payment pursuant to the settlement, the Court’s approval order will apply to 

you and legally bind you and will release, discharge, and dismiss with prejudice all claims asserted 

in the lawsuit against each and all Defendants, without costs to any party except as explained in 

this Notice. This means that you cannot sue, continue to sue, or be part of any other lawsuit against 

the Defendants alleging the same legal issues in this case. The terms of the release are included in 

the enclosed Proof of Claim and Release Form. 

EXCLUDING YOURSELF FROM THE SETTLEMENT

13. How Do I Exclude Myself from the Class?

If you are an eligible Settlement Class Member and do not want to receive payment from 

this settlement, but you want to keep the right to sue or continue to sue any of the Defendants on 

your own, regarding the same legal issues in this case, then you must take steps to exclude yourself 

from the Settlement Class, also referred to as opting out of the Settlement Class. 

To exclude yourself from the Settlement Class, you must send a written letter by first class 

mail stating that you want to be excluded from the Settlement Class as defined in Hartel v. GEO 

Group, Inc., et al., Case No. 9:20-cv-81063-RS. Your written request for exclusion must include 

your name, address, telephone number, signature, and the number of shares of GEO common stock 

you purchased or acquired between November 9, 2018 and August 5, 2020, the number of shares 

of GEO common stock you sold during this time period, if any, and the dates, quantities, and prices 

of such purchases and/or sales. You must mail your exclusion request postmarked no later than 

__________ to: 

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Hartel Securities Settlement

c/o Epiq

P.O. Box 3729

Portland, OR 97208-3729

_

You cannot exclude yourself by telephone, email or fax. 

If you submit a written request for exclusion, you are not eligible to receive any settlement 

payment, and you cannot object to the proposed settlement. You will not be legally bound by any 

orders or judgments entered with respect to this proposed settlement. 

14. If I Do Not Exclude Myself, Can I Sue Defendants for the Same Thing Later? 

No. Settlement Class Members who do not exclude themselves from the Settlement Class 

and who fail to submit a valid and timely Proof of Claim and Release Form will nevertheless be 

bound by the settlement if approved, and all orders and judgments entered by the Court in 

connection therewith. Therefore, if you do not submit a written request for exclusion, you give up 

any right to sue Defendants for the claims resolved by the settlement. If you have a pending lawsuit 

against any of the Defendants, speak to your lawyer in that case immediately. Remember the 

exclusion deadline is __________. 

15. If I Exclude Myself, Can I Still Receive A Settlement Payment? 

No. If you submit a written and timely request for exclusion, you are not entitled to receive 

any benefits provided by the settlement in the event it is approved by the Court. If you submit a 

request for exclusion, please do not submit a Proof of Claim and Release Form. But you may sue, 

continue to sue, or be part of a different lawsuit against any of the Defendants as you will no longer 

be bound by any orders or judgments entered in respect to this settlement. 

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THE LAWYERS REPRESENTING YOU

16. Do I Have a Lawyer in This Case? 

The Court certified the law firms of Levi & Korsinsky, LLP and Freedman, Normand, 

Friedland LLP to represent you and the other Settlement Class Members. These lawyers are called 

Lead Counsel. You will not be charged for the services performed by these lawyers. If you want 

to be represented by your own lawyer, you may hire one at your own expense. 

17. How Will the Lawyers Be Paid?

Plaintiffs’ Counsel will ask the Court for attorneys’ fees of one-third of the Settlement 

Fund ($3,000,000) and for reimbursement of their out-of-pocket litigation expenses up to $40,000 

that were advanced in connection with the Action. Such sums as may be approved by the Court 

will be paid from the Settlement Fund. Settlement Class Members are not personally liable for any 

such fees or expenses. 

The attorneys’ fees and expenses requested will be the only payment to Plaintiffs’ Counsel 

for their efforts in achieving this settlement and for the risk in undertaking this representation on 

a wholly contingent basis. To date, Plaintiffs’ Counsel has not been paid for their services for 

conducting this litigation on behalf of the Lead Plaintiff and the Settlement Class, nor has 

Plaintiffs’ Counsel received reimbursement for their out-of-pocket expenses. The fees requested 

will compensate Plaintiffs’ Counsel for their work in achieving this settlement and is within the 

range of fees awarded to class counsel under similar circumstances in other cases of this type. 

However, it is within the Court’s discretion to award less than the requested amount. 

Lead Counsel will also request an award in an amount not to exceed $5,000 for the Lead 

Plaintiffs pursuant to the Private Securities Litigation Reform Act of 1995 for their reasonable 

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15

costs and expenses, including lost wages, serving as the class representatives in this Action. All 

amounts, including expenses incurred by the Claims Administrator for disseminating notice of this 

settlement, will be requested before distribution of the Net Settlement Fund to Settlement Class 

Members. Again, such sums, as may be approved by the Court, will be paid from the Settlement 

Fund. 

OBJECTING TO THE SETTLEMENT

18. How Do I Tell The Court That I Do Not Like The Settlement?

If you are a Settlement Class Member and you do not agree with the proposed settlement 

or some part of it, you can file an objection with the Court. When objecting, you can give reasons 

why you think the Court should not approve it. The Court will consider your views. To object, you 

must send a letter to the Court saying that you object to the proposed settlement in Hartel v. GEO

Group, Inc., et al., Case No. 9:20-cv-81063-RS. Be sure to include your name, address, telephone 

number, signature, the GEO common stock purchased and sold between November 9, 2018 and 

August 5, 2020, along with the dates, quantities, and prices, and the reasons you object to the 

proposed settlement. All objections must be filed with the Court no later than __________. 

 19. What Is The Difference Between Objecting And Opting Out?

 

 Objecting to the proposed settlement is simply telling the Court that you do not like 

something about the terms of the settlement. You can object only if you stay in the Settlement 

Class. Excluding yourself, or opting out, is telling the Court that you do not want to be part of the 

Settlement Class, and do not want to receive any benefits under the proposed settlement. If you 

exclude yourself, you have no basis to object because the case no longer affects you. 

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THE COURT’S FINAL APPROVAL HEARING 

20. When and Where Will the Court Decide Whether to Approve the 

Settlement? 

The Court will hold a fairness hearing at ____ a.m., on ______, 2023, in Courtroom 202B 

at the U.S. Federal Building and Courthouse, 299 East Broward Boulevard, Fort Lauderdale, 

Florida 33301. At this hearing the Court will consider whether the proposed settlement is fair, 

reasonable, and adequate. If there are objections, the Court will consider them at this time. Judge 

Smith will listen to people who have asked to speak at the hearing. The Court will also consider 

how much to pay to Plaintiffs’ Counsel and whether an award to the Lead Plaintiffs is appropriate. 

The Court may decide these issues at the hearing or take them under consideration. We do not 

know how long these decisions will take. 

21. Do I Have to Come to the Final Approval Hearing? 

No. Lead Counsel will answer any questions Judge Smith may have, but you are welcome 

to come at your own expense. If you choose to attend, you may speak, but you do not have to. If 

you send an objection, you do not have to come to Court to talk about it. If you timely mailed your 

written objection, the Court will consider it. You may also pay your own lawyer to attend, but it is 

not necessary. 

22. May I Speak at the Final Approval Hearing? 

You may ask the Court for permission to speak at the Final Approval Hearing. To do so, 

you must send a letter saying that it is your intention to appear in Hartel v. GEO Group, Inc., et 

al., Case No. 9:20-cv-81063-RS. Be sure to include your name, address, telephone number, 

signature, and the number of shares of GEO common stock purchased or acquired between 

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November 9, 2018 and August 5, 2020, along with the dates, quantities, and prices. However, you 

cannot speak at the Final Approval Hearing if you exclude yourself from the Settlement Class. 

IF YOU DO NOTHING IN RESPONSE TO THIS NOTICE

23. What Happens if I Do Nothing In Response To This Notice? 

If you do not submit a valid and timely Proof of Claim and Release Form, you will not 

receive any money from the settlement, once approved by the Court. And unless you exclude 

yourself from the settlement, you will not be able to start a lawsuit, continue with a lawsuit, or be 

part of any other lawsuit against the Defendants relating to the same legal issues in this case. 

MORE INFORMATION ABOUT THE SETTLEMENT

24. Where Can I Find More Details About The Settlement?

This Notice summarizes the proposed settlement. More details are in the Stipulation and 

Agreement of Settlement dated May 1, 2023. You can get a copy of the Stipulation or more 

information about the Settlement by visiting www.HartelSecuritiesSettlement.com. 

You can also contact the Claims Administrator or Lead Counsel: 

Claims Administrator: 

Hartel Securities Settlement

c/o Epiq 

P.O. Box 3729 

Portland, OR 97208-3729 

Lead Counsel:

LEVI & KORSINSKY, LLP

Nicholas I. Porritt, Esq. 

Adam M. Apton, Esq. 

55 Broadway, 4th Floor 

New York, New York 10006 

nporritt@zlk.com 

aapton@zlk.com 

FREEDMAN NORMAND FRIEDLAND LLP

Velvel (Devin) Freedman, Esq. 

Ivy T. Ngo, Esq. 

Constantine P. Economides, Esq. 

1 SE 3rd Avenue, Suite 1240 

Miami, FL 33131 

vel@fnf.law 

ingo@fnf.law 

ceconomides@fnf.law 

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A copy of the Stipulation and other pleadings in the Action may also be obtained from the 

Clerk’s Office during regular business hours: 

 Clerk of Court 

United States District Court for the Southern District of Florida 

U.S. Federal Building and Courthouse 

299 East Broward Boulevard, #108 

Fort Lauderdale, Florida 33301

DO NOT CONTACT THE COURT, THE CLERK’S OFFICE, DEFENDANTS OR 

DEFENDANTS’ COUNSEL REGARDING THIS NOTICE

SPECIAL NOTICE TO BROKERS AND OTHER NOMINEES

Brokerage firms, banks, financial institutions and other nominees (“Nominees”) who, 

during the Class Period, purchased, acquired, or sold GEO common stock in the name of the 

Nominees on behalf of beneficial owners who may be Settlement Class Members, must within ten 

(10) days after receipt of this Notice, either: (1) send a copy of this Notice by first class mail to all 

such Persons; or (2) provide a list of names and addresses of such Persons to the Claims 

Administrator: 

Hartel Securities Settlement

c/o Epiq 

P.O. Box 3729 

Portland, OR 97208-3729 

If you choose to mail the Notice yourself, you may obtain from the Claims Administrator 

(without cost to you) as many additional copies of these documents as you will need to complete 

the mailing. 

Regardless of whether you choose to complete the mailing yourself or elect to have the 

mailing performed for you, you may seek reimbursement for or advancement of reasonable 

administrative expenses actually incurred or expected to be incurred in connection with forwarding 

the Notice and which would not have been incurred but for the obligation to forward the Notice, 

Case 9:20-cv-81063-RS Document 86 Entered on FLSD Docket 05/08/2023 Page 68 of 92
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not exceeding $0.15 per name and address, upon submission of appropriate documentation to the 

Claims Administrator. 

DATED: ______________, 2023 

 

__________________________________ 

RODNEY SMITH

UNITED STATES DISTRICT JUDGE

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1 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 9:20-81063-CIV-SMITH

STEVE HARTEL, Individually and on Behalf 

of All Others Similarly Situated,

Plaintiff,

v. 

THE GEO GROUP, INC., et al., 

Defendants.

PROOF OF CLAIM AND RELEASE FORM

I. GENERAL INSTRUCTIONS

1. To recover as a member of the Settlement Class based on the claims asserted in the 

action entitled Hartel v. The GEO Group, Inc., et al., Case No. 9:20-cv-81063-RS (the “Action”), 

you must complete and, on pages _____ hereof, sign this Proof of Claim and Release. If you fail 

to submit a properly addressed (as set forth in paragraph 3 below) Proof of Claim and Release

Form, your claim may be rejected and you may be precluded from any recovery from the 

Settlement Fund created in connection with the proposed Settlement of the Action.

1

 

2. Submission of this Proof of Claim and Release Form, however, does not assure that 

you will share in the proceeds of the Settlement of the Action. 

3. YOU MUST MAIL YOUR COMPLETED AND SIGNED PROOF OF CLAIM 

AND RELEASE FORM POSTMARKED ON OR BEFORE ________________, 2023, 

ADDRESSED AS FOLLOWS:

 

1 Unless otherwise stated, all capitalized terms used, but not defined, shall have the meanings 

ascribed to them in the Stipulation of Settlement filed with the Court. 

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2

Hartel Securities Settlement

c/o Epiq

P.O. Box 3729

Portland, OR 97208-3729

4. If you are a Settlement Class Member, you are bound by the terms of any judgment 

or order entered in the Action, WHETHER OR NOT YOU SUBMIT A PROOF OF CLAIM AND 

RELEASE FORM, unless you timely submit a valid request for exclusion from the Settlement 

Class pursuant to the Notice. 

II. CLAIMANT IDENTIFICATION

1. If you purchased or acquired GEO common stock during the period between 

November 9, 2018 and August 5, 2020, both dates inclusive, and held the certificate(s) in your 

name, you are the beneficial purchaser or acquirer as well as the record purchaser or acquirer. If, 

however, the certificate(s) were registered in the name of a third party, such as a brokerage firm

or other nominees (“Nominees”), you are the beneficial purchaser, and the third party is considered 

a record purchaser. 

2. Use Part I of this form entitled “Claimant Identification” to identify each purchaser 

of record (Nominee), if different from the beneficial purchaser of GEO common stock which form 

the basis of this claim. THIS CLAIM MUST BE FILED BY THE ACTUAL BENEFICIAL 

PURCHASER OR PURCHASERS, OR THE LEGAL REPRESENTATIVE OF SUCH 

PURCHASER OR PURCHASERS OF THE GEO COMMON STOCK UPON WHICH THIS 

CLAIM IS BASED. 

3. All joint purchasers must sign this claim. Executors, administrators, guardians, 

conservators, and trustees must complete and sign this claim on behalf of Persons represented by 

them; their authority must accompany this claim and their titles or capacities must be stated. The 

Social Security (or taxpayer identification) number and telephone number of the beneficial owner 

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3

may be used in verifying the claim. Failure to provide the foregoing information could delay 

verification of your claim or result in rejection of the claim. 

III. CLAIM FORM

1. Use Part II of this form entitled “Schedule of Transactions in GEO common stock” 

to supply all required details of your transaction(s). If you need more space or additional 

schedules, attach separate sheets providing all of the required information in substantially the same 

form. Sign and print or type your name on each additional sheet. 

2. On the Schedule of Transactions in GEO common stock, provide all of the 

requested information with respect to all of your purchases or acquisitions and all of your sales of 

GEO common stock which took place at any time beginning November 9, 2018 through August 

5, 2020, regardless of whether such transactions resulted in a profit or a loss. You must also 

provide all requested information with respect to all of the shares of GEO common stock you held 

at the close of trading on November 8, 2018, July 17, 2019, and August 5, 2020. Failure to report 

all such transactions may result in the rejection of your claim. 

3. List each transaction in the Class Period separately and in chronological order by 

trade date, beginning with the earliest. You must accurately provide the month, day, and year of 

each transaction you list. 

4. Broker confirmations or other documentation of your transactions in GEO common 

stock should be attached to your claim. Failure to provide this documentation could delay 

verification of your claim or result in rejection of your claim. 

5. The above requests are designed to provide the minimum amount of information 

necessary to process the simplest claims. 

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4

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Hartel v. The GEO Group, Inc., et al.

Case No. 9:20-cv-81063-RS

PROOF OF CLAIM AND RELEASE

Must be Postmarked No Later Than 

_____________, 2023

Please Type or Print

PART I: CLAIMANT IDENTIFICATION

_______________________________________________________________

Beneficial Owner’s Name (First, Middle, Last)

________________________________________________________________

Street Address

________________________________ ____________________________

City State or Province

________________________________ ____________________________

Zip Code or Postal Code Country

________________________________ ______________ Individual

Social Security Number or 

Taxpayer Identification Number ______________ Corporation/Other

____________________ ______________________

Area Code Telephone Number (Work)

____________________ _______________________

Area Code Telephone Number (Home)

_______________________________________________________________

Record Owner’s Name (if different from beneficial owner listed above)

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5

PART II: SCHEDULE OF TRANSACTIONS IN GEO COMMON STOCK

A. Number of shares of GEO common stock held at the close of trading on 

November 8, 2018: _______

B. Purchases or acquisitions of GEO common stock between November 9, 2018 and 

August 5, 2020: 

Trade Date

Mo. Day Year

Number of Shares

Purchased or Acquired

Total Purchase or 

Acquisition Price

1.

2.

3.

C. Sales of GEO common stock between November 9, 2018 and August 5, 2020: 

Trade Date

Mo. Day Year

Number of Shares

Sold

Total Sales Price

1.

2.

3.

D. Number of shares of GEO common stock held at the close of trading on July 17, 

2019: ____________

E. Number of shares of GEO common stock held at the close of trading on August 5, 

2020: ____________

If you require additional space, attach extra schedules in the same format as 

above. Sign and print your name on each additional page. 

YOU MUST READ AND SIGN THE RELEASE ON PAGE ____. FAILURE TO SIGN 

THE RELEASE MAY RESULT IN A DELAY IN PROCESSING OR THE 

REJECTION OF YOUR CLAIM. 

IV. SUBMISSION TO JURISDICTION OF COURT AND ACKNOWLEDGMENTS

I (We) submit this Proof of Claim and Release Form under the terms of the Stipulation and 

Agreement of Settlement, dated as of May 1, 2023 (“Stipulation”) described in the Notice. I (We) 

also submit to the jurisdiction of the United States District Court for the Southern District of 

Florida, with respect to my (our claim) as a Settlement Class Member (as defined in the Notice) 

Case 9:20-cv-81063-RS Document 86 Entered on FLSD Docket 05/08/2023 Page 74 of 92
6

and for purposes of enforcing the release set forth herein. I (We) further acknowledge that I am 

(we are) bound by and subject to the terms of any judgment that may be entered in the Action. I 

(We) agree to furnish additional information to Lead Counsel to support this claim if required to 

do so. I (We) have not submitted any other claim covering the same purchases or sales of GEO

common stock during the Class Period and know of no other Person(s) having done so on my (our) 

behalf. 

V. RELEASE

1. I (We) hereby acknowledge full and complete satisfaction of, and do hereby fully, 

finally, and forever settle, release, relinquish, and discharge all the Released Plaintiffs’ Claims. 

2. “Released Plaintiffs’ Claims” means any and all claims and causes of action of 

every nature and description whatsoever, including both known claims and Unknown Claims, 

whether arising under federal, state, local, statutory, common, or foreign law, or any other law, 

rule or regulation, including without limitation, claims for negligence, gross negligence, breach of 

contract, breach of duty of care, breach of duty of loyalty, breach of duty of candor, fraud, negligent 

misrepresentation, or breach of fiduciary duty, that relate to the purchase or otherwise acquisition 

of GEO common stock during the Class Period, and that the Plaintiffs or the Settlement Class 

Members, or any of them, or the successors or assigns of any of them, whether directly, indirectly, 

representatively or in any other capacity, against any of the Released Persons (i) asserted in the 

Complaint or (ii) could have asserted in any forum that arise out of, are based upon, or relate in 

any way, directly or indirectly, to (a) the allegations, transactions, facts, events, matters, 

occurrences, acts, representations, or omissions involved, set forth, or referred to in the Complaint; 

(b) Defendants’ statements, including public filings, and (c) the purchase, sale, holding, or 

acquisition of GEO stock by any Settlement Class Member during the Class Period. “Released 

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7

Plaintiffs’ Claims” does not include: (i) claims to enforce the Settlement; (ii) claims asserted 

derivatively on behalf of GEO in the Derivative Actions; or (iii) the claims of any person or entity 

that submits a request for exclusion from the Settlement Class that is accepted by the Court. 

3. “Unknown Claims” means any Released Claims which Releasing Plaintiffs or 

Released Persons do not know or suspect to exist in his, her, or its favor at the time of the release 

of such claims, which, if known by him, her, or it, might have affected his, her, or its release of 

the Released Persons, or Releasing Plaintiffs, or might have affected his, her, or its decision(s)

with respect to this Settlement. Unknown Claims include those Released Claims in which some 

or all of the facts comprising the claim may be suspected, or even undisclosed or hidden. With 

respect to any and all Released Claims, the Parties stipulate and agree that, upon the Effective 

Date, Plaintiffs and Defendants shall expressly waive and relinquish, and each of the other 

Settlement Class Members shall be deemed to have waived and relinquished by operation of the 

Judgment, any and all provisions, rights, and benefits conferred by any law of any state or territory 

of the United States, or principle of common law or foreign law, which is similar, comparable, or 

equivalent to California Civil Code §1542, which provides:

A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE 

CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT 

TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE 

RELEASE AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE 

MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE 

DEBTOR OR RELEASED PARTY.

Lead Plaintiffs and Defendants acknowledge, and each of the other Settlement Class Members 

shall be deemed by operation of law to have acknowledged, that the foregoing waiver was 

separately bargained for and is a key element of the Settlement.

4. This release shall be of no force or effect unless and until the Court approves the 

Settlement set forth in the Stipulation and it becomes effective on the Effective Date. 

Case 9:20-cv-81063-RS Document 86 Entered on FLSD Docket 05/08/2023 Page 76 of 92
8

5. I (We) hereby warrant and represent that I (we) have not assigned or transferred or 

purported to assign or transfer, voluntarily or involuntarily, any matter released pursuant to this 

release or any other part or portion thereof. 

6. I (We) hereby warrant and represent that I (we) have included information about 

all of my (our) transactions in GEO common stock that occurred during the Class Period as well 

as the number and type of GEO shares held by me (us) on November 8, 2018, July 17, 2019, and 

August 5, 2020. 

7. I (We) certify that I am (we are) not subject to backup withholding under the 

provisions of Section 3406(a)(1)(C) of the Internal Revenue Code. 

Note: If you have been notified by the Internal Revenue Service that you are subject to 

backup withholding, please strike out the language that you are not subject to backup withholding 

in the certification above. 

I (We) declare under penalty of perjury under the laws of the United States of America that 

the foregoing information supplied is true and correct. 

Executed this day of in

(Month/Year) (City/State/Country)

(Sign your name here) (Sign your name here)

(Type or print your name here) (Type or print your name here)

(Capacity of signatory, e.g., Beneficial 

Purchaser, Executor or Administrator)

Capacity of signatory, e.g., Beneficial 

Purchaser, Executor or Administrator)

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9

ACCURATE CLAIMS PROCESSING TAKES A SIGNIFICANT AMOUNT OF TIME. 

THANK YOU FOR YOUR PATIENCE.

Reminder Checklist:

1. Please sign the above release and 

declaration.

2. If this Claim is being made on behalf of 

Joint Claimants, then both must sign. 

3. Remember to attach copies of supporting 

documentation, if available. 

4. Do not send originals of certificates. 

5. Keep a copy of your claim form and all 

supporting documentation for your records. 

6. If you desire an acknowledgement of receipt of 

your claim form, please send it Certified Mail, 

Return Receipt Requested. 

7. If you move, please send your new address to 

the address below. 

8. Do not use red pen or highlighter on the Proof 

of Claim and Release form or supporting 

documentation. 

THIS PROOF OF CLAIM FORM MUST BE MAILED NO LATER THAN _____ , 2023

ADDRESSED AS FOLLOWS:

Hartel Securities Settlement

c/o Epiq

P.O. Box 3729

Portland, OR 97208-3729

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EXHIBIT A-3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 9:20-81063-CIV-SMITH

STEVE HARTEL, Individually and on Behalf 

of All Others Similarly Situated,

Plaintiff,

v.

THE GEO GROUP, INC., et al., 

Defendants.

SUMMARY OF NOTICE

TO: ALL PERSONS OR ENTITIES WHO PURCHASED OR OTHERWISE 

ACQUIRED THE GEO GROUP, INC. COMMON STOCK BETWEEN 

NOVEMBER 9, 2018 AND AUGUST 5, 2020.

1

YOU ARE HEREBY NOTIFIED, pursuant to Rule 23 of the Federal Rules of Civil Procedure 

that a hearing will be held on _____________, 2023, at ___:00 _.m., before the Honorable 

Rodney Smith, United States District Judge, in Courtroom 202B at the U.S. Federal Building and 

Courthouse, 299 East Broward Boulevard, Fort Lauderdale, Florida 33301, for the purpose of 

determining, among other things, whether the following matters should be approved: (1) the 

proposed settlement of the Action for the sum of $3,000,000.00 in cash as fair, reasonable and 

adequate to the Settlement Class Members; (2) thereafter, dismissal with prejudice of the Action

as set forth in the Stipulation; (3) the Plan of Allocation as fair, reasonable and adequate; and (4) 

the application of Lead Counsel for the payment of attorneys’ fees and reimbursement of 

expenses incurred in connection with the Action and an award to the Lead Plaintiffs. 

If you purchased or otherwise acquired GEO common stock between November 9, 2018 and 

August 5, 2020, both dates inclusive, your rights may be affected by the settlement of this Action. 

If you have not received the detailed Notice of Pendency and Proposed Settlement of Class 

Action (the “Notice”) and a copy of the Proof of Claim and Release Form, you may obtain them 

free of charge by contacting the Claims Administrator, by mail at: Hartel Securities Settlement, 

c/o Epiq, P.O. Box 3729, Portland, OR 97208-3729, or at the following website: www.

HartelSecuritiesSettlement.com.

1 Unless otherwise noted, capitalized terms used herein have the same meaning ascribed to them 

as in the Stipulation and Agreement of Settlement dated May 1, 2023 (the “Stipulation”).

Case 9:20-cv-81063-RS Document 86 Entered on FLSD Docket 05/08/2023 Page 79 of 92
2

If you are a Settlement Class Member and wish to share in the distribution of the Net Settlement 

Fund, you must submit a Proof of Claim and Release Form no later than ________, 2023

establishing that you are entitled to recovery. As further described in the Notice, you will be 

bound by any Judgment entered in the Action, regardless of whether you submit a Proof of Claim

and Release Form, unless you exclude yourself from the Settlement Class, in accordance with 

the procedures set forth in the Notice, no later than _________, 2023. Any objections to the 

Settlement, Plan of Allocation, attorneys’ fees and expenses, or award to Lead Plaintiffs must be 

filed and served, in accordance with the procedures set forth in the Notice, no later than 

_________, 2023.

Inquiries, other than requests for the Notice, may be made to Lead Counsel for the Settlement 

Class:

LEVI & KORSINSKY, LLP

Nicholas I. Porritt, Esq.

Adam M. Apton, Esq.

55 Broadway, 4th Floor

New York, New York 10006

nporritt@zlk.com

aapton@zlk.com

FREEDMAN NORMAND FRIEDLAND LLP

Velvel (Devin) Freedman, Esq.

Ivy T. Ngo, Esq.

Constantine P. Economides, Esq.

1 SE 3rd Avenue, Suite 1240

Miami, FL 33131

vel@fnf.law

ingo@fnf.law

ceconomides@fnf.law 

INQUIRIES SHOULD NOT BE DIRECTED TO THE COURT, THE

CLERK’S OFFICE, DEFENDANTS, OR DEFENDANTS’ COUNSEL.

If you have any questions about the settlement, you may contact Lead Counsel at the addresses

listed above. 

DATED: ______________, 2023 ____________________________________

RODNEY SMITH

UNITED STATES DISTRICT JUDGE

Case 9:20-cv-81063-RS Document 86 Entered on FLSD Docket 05/08/2023 Page 80 of 92
EXHIBIT A-4

Court d 

Hartel v. The GEO Group, Inc., et al. 

c/o _____________

[Insert]

[Insert]

[Insert]

COURT-ORDERED LEGAL NOTICE

Important Notice about a Securities Class 

Action Settlement.

You may be entitled to a CASH payment. 

This Notice may affect your legal rights. 

Please read it carefully.

Hartel v. The GEO Group, Inc., et al., 

Case No. 9:20-cv-81063-RS

 [Postage Prepaid]

Name

Address

City, State 

Zip

THIS CARD PROVIDES ONLY LIMITED INFORMATION ABOUT THE SETTLEMENT. 

PLEASE VISIT WWW.HARTELSECURITIESSETTLEMENT.COM FOR MORE INFORMATION.

There has been a proposed settlement of claims against the GEO Group, Inc. (“GEO”), and George C. Zoley 

(collectively, the “Defendants”). The settlement would resolve a lawsuit in which Lead Plaintiffs allege Defendants 

disseminated materially false and misleading information to the investing public about GEO between November 9, 

2018 and August 5, 2020 (the “Class Period”) in violation of the federal securities laws. Defendants deny that Lead 

Plaintiffs have asserted any valid claims as to any of them, and expressly deny any and all allegations of fault, liability, 

wrongdoing, or damages whatsoever. You received this Postcard Notice because you or someone in your family may 

have purchased or otherwise acquired GEO common stock during the Class Period.

Defendants have agreed to a settlement that includes payment in the amount of $3,000,000. The settlement provides 

that the Settlement Fund, after deduction of any Court-approved attorneys’ fees and expenses, award to Lead 

Plaintiffs, notice and administration costs, and taxes, is to be divided among all Settlement Class Members who submit 

a valid Proof of Claim and Release Form, in exchange for the settlement of this case and the release of claims by 

Settlement Class Members. For all details of the settlement, read the Stipulation and full Notice, available at 

www.HartelSecuritiesSettlement.com. 

Your share of the settlement proceeds will depend on the number of valid Proof of Claim and Release Forms

submitted, and the number, size and timing of your transactions in GEO common stock. If every eligible Settlement 

Class Member submits a valid Proof of Claim form, the average recovery will be $0.055 per eligible share before 

expenses and other Court-ordered deductions. Your award will be determined pro rata based on the number of claims 

submitted. This is further explained in the detailed Notice found on the settlement website.

To qualify for payment, you must submit a valid and timely Proof of Claim and Release Form. The Proof of 

Claim and Release Form can be found at www.HartelSecuritiesSettlement.com or will be mailed to you upon request 

to the Claims Administrator (877-589-2242). Proof of Claim and Release Forms must be submitted online or 

postmarked by . If you do not want to be legally bound by the settlement, you must exclude yourself by 

_______, or you will not be able to sue Defendants for claims that are released in this settlement. If you exclude 

yourself, you cannot share in the settlement proceeds. If you want to object to the settlement, you may file an objection 

by __________. The detailed Notice explains how to submit a Proof of Claim and Release Form, request exclusion

from the Settlement Class, or file an objection.

The Court will hold a hearing in this Action on ______________, to consider whether to approve the proposed 

settlement and the requests made by the lawyers representing Lead Plaintiffs and the Settlement Class for attorneys’ 

fees up to 33% of the Settlement Fund, plus actual expenses up to $_____ associated with conducting this litigation

and negotiating the settlement, and an award to Lead Plaintiffs. You may attend the hearing and ask to be heard by 

the Court, but you do not have to. For more information, call toll-free (877-589-2242) or visit the website

www.HartelSecuritiesSettlement.com and read the detailed Notice.

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EXHIBIT B 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case File No. 9:20-cv-81063-RS

STEVE HARTEL, individually and on behalf 

of all others similarly situated, 

Plaintiff, 

vs.

THE GEO GROUP, INC., et al., 

Defendants. 

 

 

/

[PROPOSED] FINAL JUDGMENT AND 

ORDER OF DISMISSAL WITH PREJUDICE 

WHEREAS, an action is pending before this Court entitled Hartel v. The GEO Group, Inc. 

et al., Case No. 9:20-cv-81063-RS (S.D. Fla.) (the “Action”);1 

WHEREAS, pursuant to the Court’s Order Preliminarily Approving Settlement and 

Providing for Notice (the “Notice Order”), dated ____________, 2023, Lead Counsel 

disseminated due and adequate notice to the Settlement Class; and 

WHEREAS, pursuant to the Notice Order and Federal Rule of Civil Procedure (“Rule”) 

23(e), the Parties seek final approval of the Settlement, in accordance with the Stipulation, and for 

dismissal with prejudice upon the terms and conditions set forth therein. 

AND NOW THIS ____ day of _________________ 2023, the Court having considered 

the pleadings and other filings herein, and such other written and oral arguments requested or 

permitted by the Court, and otherwise being fully informed on the premises and good cause 

1 Unless otherwise noted, capitalized terms used herein have the same meaning ascribed to them 

as in the Stipulation and Agreement of Settlement dated May 1, 2023 (the “Stipulation”). 

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2

appearing therefore, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT:

1. This Court has jurisdiction over the subject matter of the Action, including the 

terms and conditions of the Stipulation and all exhibits thereto and the Plan of Allocation, and over 

all parties to the Action, including all Settlement Class Members.

2. Pursuant to Rule 23, the Court certifies, solely for purposes of effectuating the 

Settlement, a Settlement Class consisting of all Persons or entities who purchased or otherwise 

acquired GEO common stock during the Class Period (i.e., the period commencing on November 

9, 2018 and ending on August 5, 2020, both dates inclusive), and who were damaged thereby. 

Excluded from the Settlement Class are (i) Defendants; (ii) the Officers and directors of GEO 

currently and during the Class Period; (iii) Immediate Family Members of any such excluded 

persons; (iv) the legal representatives, heirs, successors, or assigns of any such excluded persons 

or entities; and (v) any entity in which any such excluded party has, or had during the Class Period, 

a controlling interest. Also excluded from the Settlement Class are any Persons or entities who or 

which validly and timely requested exclusion in accordance with the requirements set by the Court

in its Notice Order.

3. Solely for the purposes of the Settlement of this Action, the Court finds that each 

element required for certification of the Settlement Class pursuant to Rule 23 has been met: (a) the 

Settlement Class is so numerous that joinder of all members is impracticable; (b) there are 

questions of law or fact common to the members of the Settlement Class; (c) the claims of Plaintiffs 

are typical of the claims of the other members of the Settlement Class; (d) Plaintiffs and Lead 

Counsel have and will fairly and adequately protect the interests of the Settlement Class Members 

in connection with the Settlement; (e) common questions of law and fact predominate over 

questions affecting only individual Settlement Class Members; (f) resolution of the claims in this 

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3

Action by way of the Settlement is superior to other available methods for the fair and efficient 

resolution of the claims of the Settlement Class Members.

4. Pursuant to Rule 23(e)(2), the Court approves the Settlement and finds that: (i) the 

Settlement is the result of arm’s length negotiations between experienced counsel representing the 

interests of the Parties; (ii) the Settlement is fair, reasonable, adequate; and (iii) the Settlement 

treats Settlement Class Members equitably relative to each other and is in the best interest of the 

Settlement Class. 

5. Accordingly, the Court authorizes and directs implementation and performance of 

all the terms and provisions of the Stipulation, in addition to the terms and provisions herein, except 

as to any individual claim of those Persons or entities who have validly and timely requested 

exclusion from the Settlement Class. 

6. The Action is DISMISSED WITH PREJUDICE in its entirety.

7. In accordance with the Stipulation, the term “Defendants” means The GEO Group, 

Inc. and George C. Zoley.

8. In accordance with the Stipulation, the term “Released Persons” means Defendants 

and Brian R. Evans, J. David Donahue, and Ann M. Schlarb, and, whether or not identified in any 

complaint filed in the Action, each past and current defendants’ respective past and current parents, 

associates, affiliates, subsidiaries, officers, directors, agents, representatives, successors, 

predecessors, assigns, assignees, partnerships, partners, principals, employees, trustees, trusts, 

heirs, executors, administrators, Immediate Family Members, insurers, reinsurers, underwriters, 

professional advisors, law firms and attorneys affiliated with such law firms, in their capacities as 

such.

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9. In accordance with the Stipulation, the term “Releasing Plaintiffs” means each and 

every past and current plaintiff, all other Settlement Class Members, Plaintiffs’ Counsel, and each 

of their respective current and former trustees, executors, administrators, officers, directors, 

partners, members, employees, contractors, auditors, principals, agents, attorneys, predecessors, 

successors, assigns, representatives, affiliates, joint ventures, shareholders, underwriters, insurers, 

personal or legal representatives, estates, financial advisors or consultants, banks or investment 

bankers, parents, subsidiaries, general or limited partners or partnerships, and limited liability 

companies; and the Immediate Family Members, representatives and heirs of any Releasing 

Plaintiffs (who is an individual), as well as any trust of which any Releasing Plaintiffs is the settlor 

or which is for the benefit of any of their Immediate Family Members. Releasing Plaintiffs do not 

include any Person who would otherwise be a Settlement Class Member but who validly and 

timely requested exclusion from the Settlement Class.

10. In accordance with the Stipulation, “Released Plaintiffs’ Claims” means any and 

all claims and causes of action of every nature and description whatsoever, including both known 

claims and Unknown Claims, whether arising under federal, state, local, statutory, common, or 

foreign law, or any other law, rule or regulation, including without limitation, claims for 

negligence, gross negligence, breach of contract, breach of duty of care, breach of duty of loyalty, 

breach of duty of candor, fraud, negligent misrepresentation, or breach of fiduciary duty, that relate 

to the purchase or otherwise acquisition of GEO common stock during the Class Period, and that 

the Plaintiffs or the Settlement Class Members, or any of them, or the successors or assigns of any 

of them, whether directly, indirectly, representatively or in any other capacity, against any of the 

Released Persons (i) asserted in the Complaint or (ii) could have asserted in any forum that arise 

out of, are based upon, or relate in any way, directly or indirectly, to (a) the allegations, 

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5

transactions, facts, events, matters, occurrences, acts, representations, or omissions involved, set 

forth, or referred to in the Complaint; (b) Defendants’ statements, including public filings, and (c) 

the purchase, sale, holding, or acquisition of GEO stock by any Settlement Class Member during 

the Class Period. “Released Plaintiffs’ Claims” does not include: (i) claims to enforce the 

Settlement; (ii) claims asserted derivatively on behalf of GEO in the Derivative Actions; or (iii) 

the claims of any person or entity that submits a request for exclusion from the Settlement Class 

that is accepted by the Court.

11. In accordance with the Stipulation, “Released Defendants’ Claims” means any and 

all claims and causes of action of every nature and description whatsoever, including both known 

claims and Unknown Claims, whether arising under federal, state, common or foreign law, against 

Plaintiffs, Plaintiffs’ Counsel or any Settlement Class Member that arise out of or relate in any 

way to the institution, prosecution, or settlement of the claims asserted in the Action against 

Defendants. Released Defendants’ Claims do not include: (i) any claims relating to the 

enforcement of the Settlement; (ii) any claims against any person or entity who or which submits 

a request for exclusion from the Settlement Class that is accepted by the Court; or (iii) any claims 

by Defendants against their insurers.

12. Upon the Effective Date, and as provided in the Stipulation, Plaintiffs shall, and 

each and every Releasing Plaintiffs (including each and all of the Settlement Class Members) shall 

be deemed to have, and by operation of law and of this final Judgment shall have, fully, finally, 

and forever compromised, settled, released, resolved, relinquished, waived, dismissed, and 

discharged each and every Released Plaintiffs’ Claims (including Unknown Claims) against each

and every one of the Released Persons, regardless of whether or not such Settlement Class 

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Members execute and deliver a Proof of Claim and Release, and whether or not such Settlement 

Class Members share in the Settlement Fund.

13. Upon the Effective Date, and as provided in the Stipulation, Plaintiffs, all Releasing 

Plaintiff Parties (including each and all of the Settlement Class Members) and anyone claiming

through or on behalf of any of them, shall forever be barred and enjoined from commencing, 

instituting, intervening in or participating in, prosecuting or continuing to prosecute any action or 

other proceeding in any court of law or equity, arbitration tribunal, or administrative forum, or 

other forum of any kind or character (whether brought directly, in a representative capacity, 

derivatively, or in any other capacity), that asserts any or all of the Released Plaintiffs’ Claims 

against any of the Released Persons, regardless of whether or not such Settlement Class Members 

execute and deliver a Proof of Claim and Release, and whether or not such Settlement Class 

Members share in the Settlement Fund. To the fullest extent provided by Section 21D(f)(7) of the 

Exchange Act, 15 U.S.C. § 78u-4(f)(7), and the common law of the U.S. Court of Appeals for the 

Eleventh Circuit, all claims, including, but not limited to, claims for contribution, indemnification 

or equitable indemnification against any party or third person, including, but not limited to, any 

trustee appointed in a Chapter 7 or 11 bankruptcy proceeding, a receiver, an assignee for the benefit 

of creditors, or any similar successor related, directly or indirectly, to the facts of this Action shall 

be barred. For the avoidance of doubt, this bar order does not bar or impair (i) any claims asserted 

derivatively on behalf of GEO in the Derivative Actions; (ii) any claims relating to the enforcement 

of the Settlement; or (iii) any claims by Defendants against their insurers.

14. Upon the Effective Date, and as provided in the Stipulation, each of the Defendants 

shall be deemed to have, and by operation of law and of the Final Judgment and Order shall have, 

fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, 

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dismissed, and discharged each and every Released Defendants’ Claims against Plaintiffs, each 

and all of the Settlement Class Members and Plaintiffs’ Counsel, and shall forever be barred and 

enjoined from commencing, instituting, intervening in or participating in, prosecuting or 

continuing to prosecute any action or other proceeding in any court of law or equity, arbitration 

tribunal, or administrative forum, or other forum of any kind or character (whether brought 

directly, in a representative capacity, derivatively, or in any other capacity), that asserts any or all 

of the Released Defendants’ Claims against Plaintiffs, any of the Settlement Class Members or 

Plaintiffs’ Counsel. This release shall not apply to any Person or entity who or which submits a 

request for exclusion from the Settlement Class that is accepted by the Court. 

15. Pursuant to the requirements of Rule 23(e), the Private Securities Litigation Reform 

Act of 1995, 15 U.S.C. § 78u-4(a)(7), and due process, the Notice of Pendency and Proposed 

Settlement of Class Action (the “Notice) was reasonably calculated, under all the circumstances, 

to apprise Settlement Class Members of the pendency of the Action and the definition of the 

Settlement Class, provided an explanation of the proposed Settlement, as set forth in the 

Stipulation, afforded them an opportunity to present their objections, if any, and advised them of 

their right to opt out of the Settlement Class or be bound by this Judgment. Indeed, the nature and 

method of the Notice provided direct notice to all the Settlement Class Members who could be 

identified through reasonable effort. Thus, no Settlement Class Member is relieved from the terms 

of the Settlement, including the releases provided for therein, based upon the contention or proof 

that such Settlement Class Member failed to receive actual or adequate notice. Settlement Class 

Members were provided full opportunity to object to the proposed Settlement and to participate in 

the hearing thereon. The Court further finds that the notice provisions of the Class Action Fairness 

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8

Act, 28 U.S.C. §1715, were fully discharged and that the statutory waiting period has elapsed. 

Thus, the Court hereby determines that all Settlement Class Members are bound by this Judgment.

16. Any Plan of Allocation submitted by Lead Counsel or Order entered by this Court 

regarding Lead Counsel’s application for attorneys’ fees and expenses shall in no way disturb or 

affect this Judgment and shall be considered separate from this Judgment.

17. Neither this Judgment, the Settlement, the Stipulation, including the exhibits hereto 

and the Plan of Allocation contained therein (or any other plan of allocation that may be approved 

by the Court), the negotiations leading to the execution of the Stipulation and Settlement, nor any 

proceedings, communications, drafts, documents, or agreements taken pursuant to or in connection 

with the Stipulation, and/or approval of the Settlement (including any arguments proffered in 

connection therewith):

a. shall be offered or received against any Released Persons as evidence of, or 

construed as, or deemed to be evidence of any presumption, concession, or admission by any of 

Released Persons with respect to the truth of any fact alleged by Plaintiffs or the validity of any 

claim that has been or could have been asserted in the Action, or the deficiency of any defense that 

has been or could have been asserted in this Action or in any other litigation, or of any liability, 

negligence, fault, or other wrongdoing of any kind of any of the Released Persons or in any way 

referred to for any other reason as against any of the Released Persons, in any arbitration 

proceeding or other civil, criminal, or administrative action or proceeding, other than such 

proceedings as may be necessary to effectuate the provisions of the Stipulation;

b. shall be offered or received against or to the prejudice of any Released 

Persons as evidence of, or construed as, or deemed to be evidence of any presumption, concession, 

or admission of any fault, misrepresentation, or omission with respect to any statement or written 

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9

document approved or made by any Defendant, or against Plaintiffs or any Member of the 

Settlement Class, in any arbitration proceeding or other civil, criminal, or administrative action or 

proceeding, other than such proceedings as may be necessary to effectuate the provisions of the 

Stipulation;

c. shall be offered or received against or to the prejudice of any Released 

Persons as evidence of, or construed as, or deemed to be evidence of any presumption, concession, 

or admission of any liability, negligence, fault, or wrongdoing, or in any way referred to for any 

other reason as against any of Parties to the Stipulation, in any other civil, criminal, or 

administrative action or proceeding; provided, however, the Released Persons may refer to the 

Stipulation to effectuate the protections from liability granted thereunder or otherwise to enforce 

the terms of the Settlement; or 

d. shall be construed against the Released Persons, Plaintiffs or the Settlement 

Class as evidence of a presumption, concession, or admission that the consideration to be given 

hereunder represents the amount which could be or would have been recovered after trial or in any 

proceeding other than this Settlement. 

18. Without affecting the finality of this Judgment in any way, this Court hereby retains 

continuing jurisdiction over: (a) implementation of this Settlement and any award or distribution 

of the Settlement Fund, including interest earned thereon; (b) disposition of the Settlement Fund; 

(c) hearing and determining applications for attorneys’ fees, expenses, and interest in the Action; 

and (d) all Parties herein for the purpose of construing, enforcing, and administering the 

Settlement.

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19. Any orders regarding the Plan of Allocation, attorneys’ fees and expenses, or any 

award to Plaintiffs, or any appeal, modification or change of any of the foregoing, shall in no way 

disturb or affect the finality of this Judgment and shall be considered separate from this Judgment.

20. No Settlement Class Member shall have any claim against any Defendant, 

Defendants’ Counsel, or any of the Released Persons with respect to: (a) any act, omission, or 

determination of Plaintiffs’ Counsel, the Claims Administrator, or any of their respective designees 

or agents, in connection with the administration of the Settlement or otherwise; (b) the 

management, investment, or distribution of the Settlement Fund and/or the Net Settlement Fund; 

(c) the Plan of Allocation; (d) the determination, administration, calculation, or payment of claims 

asserted against the Settlement Fund and/or the Net Settlement Fund; (e) the administration of the 

escrow account; (f) any application for, or award of, attorneys’ fees and expenses to Plaintiffs’ 

counsel or the allocation or distribution thereof as between them; (g) any losses suffered by, or 

fluctuations in value of, the Settlement Fund and/or the Net Settlement Fund; or (h) the payment 

or withholding of any Taxes or Tax Expenses incurred in connection with the taxation of the 

Settlement Fund and/or the Net Settlement Fund or the filing of any tax returns.

21. The Court finds that during the course of the Action, the Parties and their respective 

counsel at all times complied with the requirements of Rule 11.

22. In the event that the Settlement does not become effective in accordance with the 

terms of the Stipulation, or the Effective Date does not occur, or in the event that the Settlement 

Fund, or any portion thereof, is returned to the Defendants or their insurers, then this Judgment 

(including its certification of the Settlement Class) shall be rendered null and void to the extent 

provided by and in accordance with the Stipulation and shall be vacated and, in such event, all 

orders entered and releases delivered in connection herewith shall be null and void to the extent 

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provided by and in accordance with the Stipulation, and the Parties shall revert to their respective 

positions in the Action as of December 16, 2022, as provided in the Stipulation.

23. The Parties are hereby authorized, without further order of the Court, to agree to 

and adopt in writing such amendments, modifications, and expansions of the Stipulation and all 

exhibits attached thereto, provided that such amendments, modifications, and expansions of the 

Stipulation are done in accordance with the terms of the Stipulation, are not materially inconsistent 

with this final Judgment and do not materially limit the rights of Settlement Class Members or the 

Releasees under the Stipulation.

24. There is no just reason to delay the entry of this Judgment in the Action. 

Accordingly, the Court directs immediate entry of this Final Judgment by the Clerk of the Court 

dismissing this Action against all Defendants with prejudice, without cost to any party, except as 

provided for in the Stipulation and herein.

IT IS SO ORDERED.

DATED: _______________, 2023 _____________________________

RODNEY SMITH

UNITED STATES DISTRICT JUDGE

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