UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 9:20-cv-81063-RS

STEVE HARTEL, Individually and on 

Behalf of All Others Similarly Situated, 

Plaintiff, 

v. 

THE GEO GROUP, INC. and GEORGE C.

ZOLEY,

Defendants.

_____________________________________/ 

DEFENDANT THE GEO GROUP, INC’S 

ANSWER AND AFFIRMATIVE DEFENSES TO LEAD PLAINTIFFS’ 

CONSOLIDATED CLASS ACTION SECOND AMENDED COMPLAINT

The GEO Group, Inc. (“GEO” or the “Company”), by and through its undersigned counsel, 

hereby responds to the correspondingly numbered paragraphs of Lead Plaintiffs’ Consolidated 

Class Action Second Amended Complaint filed on October 4, 2021 [ECF No. 46] (“Second 

Amended Complaint”), denies each and every allegation not expressly admitted, and asserts its 

Affirmative Defenses as follows:

ANSWER

GEO responds to the non-numbered introductory statement in the Second Amended 

Complaint as follows: GEO admits that Lead Plaintiffs purport to bring a putative federal securities 

class action against GEO and co-defendant George C. Zoley (“Mr. Zoley;” and together with GEO, 

“Defendants”). GEO lacks knowledge or information sufficient to form a belief as to the basis for 

Lead Plaintiffs’ allegations and therefore denies same. GEO denies the remaining allegations in 

the Second Amended Complaint’s non-numbered introductory statement. 

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1. GEO admits that Lead Plaintiffs purport to bring a federal securities class action on 

behalf of a putative class of persons who purchased or otherwise acquired GEO common stock 

from November 9, 2018 to August 5, 2020, both dates inclusive, pursuing remedies against 

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

Act”) and SEC Rule 10b-5. GEO further responds that Lead Plaintiffs’ proposed purported class 

period has been modified by this Court in its Order Granting Defendants’ Motion to Dismiss, dated 

June 21, 2022 [ECF No. 63] (“June 21 Order on Motion to Dismiss”). GEO denies that any of 

Lead Plaintiffs’ claims have any merit, and denies that any putative class should be certified 

pursuant to Federal Rule of Civil Procedure 23. 

2. GEO admits only that it was founded in 1984; that it operates internationally; that 

it provides complementary, turnkey solutions for numerous government partners worldwide across 

a spectrum of diversified correctional and community reentry services; and that it aspires to be the 

world’s leading provider of evidence-based rehabilitation across its diversified spectrum of 

correctional and community reentry services. GEO denies that it is currently a REIT, and denies 

the remaining allegations in Paragraph 2. 

3. GEO admits only that it restructured itself as a REIT as of January 1, 2013, but 

denies that it is currently a REIT. GEO denies the remaining allegations in Paragraph 3. 

4. In response to the allegations contained in Paragraph 4, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 4, because the Court has previously 

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dismissed these allegations. To the extent a response is required, the allegations in Paragraph 4 

are denied. 

5. In response to the allegations contained in Paragraph 5, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 5, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 5 

are denied.

6. In response to the allegations contained in Paragraph 6, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 6, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 6 

are denied. 

7. In response to the allegations contained in the first three sentences of Paragraph 7, 

GEO responds that, in the June 21 Order on Motion to Dismiss, the Court specifically noted that 

although it had previously “dismissed all of [Lead] Plaintiffs’ claims except those based on 

statements about pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains 

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most of the allegations contained in the Amended Complaint. However, only the statements about 

pending lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. 

As such, no responsive pleading is required to the allegations contained in the first three sentences 

of Paragraph 7, because the Court has previously dismissed these allegations. To the extent a 

response is required, the allegations in the first three sentences of Paragraph 7 are denied. 

Responding to the allegations in the fourth sentence of Paragraph 7, GEO states that statements it 

has made in court filings speak for themselves, and denies any inconsistent allegations in 

Paragraph 7. Responding to the allegations in the fifth sentence of Paragraph 7, GEO states that 

Mr. Zoley’s May 30, 2018 letter to ICE speaks for itself, and denies any inconsistent allegations 

in Paragraph 7. GEO further states that its reported net income speaks for itself and denies any 

inconsistent allegations in Paragraph 7. GEO denies the remaining allegations in Paragraph 7. 

8. GEO denies the allegations contained in the first sentence of Paragraph 8. In 

response to the allegations contained in the second to fourth sentences of Paragraph 8, GEO 

responds that, in the June 21 Order on Motion to Dismiss, the Court specifically noted that although 

it had previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in the second to fourth sentences of 

Paragraph 8, because the Court has previously dismissed these allegations. To the extent a 

response is required, the allegations in the second to fourth sentences of Paragraph 8 are denied. 

9. In response to the allegations contained in Paragraph 9, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

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lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 9, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 9 

are denied. 

10. In response to the allegations contained in Paragraph 10, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 10, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 10 

are denied. 

11. In response to the allegations contained in Paragraph 11, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 11, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 11 

are denied. 

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12. In response to the allegations contained in Paragraph 12, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 12, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 12 

are denied. 

13. In response to the allegations contained in Paragraph 13, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 13, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 13 

are denied. 

14. In response to the allegations contained in Paragraph 14, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

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pleading is required to the allegations contained in Paragraph 14, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 14 

are denied. 

15. In response to the allegations contained in Paragraph 15, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 15, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 15 

are denied. 

16. In response to the allegations contained in Paragraph 16, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 16, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 16 

are denied. 

17. In response to the allegations contained in Paragraph 17, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

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lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 17, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 17 

are denied. 

18. In response to the allegations contained in Paragraph 18, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 18, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 18 

are denied. 

19. In response to the allegations contained in Paragraph 19, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 19, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 19 

are denied. 

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20. In response to the allegations contained in Paragraph 20, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 20, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 20 

are denied. 

21. In response to the allegations contained in Paragraph 21, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 21, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 21 

are denied. 

22. In response to the allegations contained in Paragraph 22, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

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pleading is required to the allegations contained in Paragraph 22, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 22 

are denied. 

23. In response to the allegations contained in Paragraph 23, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 23, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 23 

are denied. 

24. In response to the allegations contained in Paragraph 24, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 24, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 24 

are denied. 

25. GEO denies the allegations in Paragraph 25. 

26. There is no numbered Paragraph 26 in the Second Amended Complaint. 

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27. GEO admits that Lead Plaintiffs purport to assert claims against Defendants 

pursuant to Sections 10(b) and 20(a) of the Exchange Act, 15 U.S.C. §§ 78(j(b) and 78t(a), and 

Rule 10b-5 promulgated thereunder, 17 C.F.R. § 240.10b-5. GEO denies that the claims have any 

merit.

28. Paragraph 28 contains conclusions of law as to which no response is required. To 

the extent a response is required, the allegations in Paragraph 28 are admitted for jurisdictional 

purposes only. 

29. Paragraph 29 contains conclusions of law as to which no response is required. To 

the extent a response is required, GEO admits only that its corporate headquarters is located in 

Boca Raton, Florida. GEO specifically denies any allegations of fraud, and specifically denies 

allegations relating to the purported dissemination of materially false and/or misleading 

information in Paragraph 29. 

30. GEO denies the allegations in Paragraph 30. 

31. GEO denies that any purported certification of Lead Plaintiff DeLoach is attached 

to the Second Amended Complaint. GEO lacks knowledge or information sufficient to form a 

belief as to Lead Plaintiff DeLoach’s alleged purchases of GEO common stock during the 

purported class period, and therefore denies the allegations in Paragraph 31. GEO denies the 

remaining allegations in Paragraph 31. 

32. GEO denies that any purported certification of Lead Plaintiff Oketola is attached to 

the Second Amended Complaint. GEO lacks knowledge or information sufficient to form a belief 

as to Lead Plaintiff Oketola’s alleged purchases of GEO common stock during the purported class 

period, and therefore denies the allegations in Paragraph 32. GEO denies the remaining allegations 

in Paragraph 32. 

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33. GEO denies that it is incorporated in Maryland. GEO admits that its corporate 

headquarters is in Boca Raton, Florida, and that its common stock trades on the NYSE under the 

symbol “GEO.” 

34. GEO admits that Mr. Zoley is the Executive Chairman of GEO’s Board of 

Directors; that Mr. Zoley served as CEO beginning when the Company went public in 1994; that 

Mr. Zoley served as GEO’s Vice Chairman of the Board of Directors from January 1997 to May 

of 2002; that Mr. Zoley founded GEO in 1984; that Mr. Zoley served as President and Director 

from GEO’s incorporation in 1988 until it went public in 1994; that Mr. Zoley also serves as a 

director of several business subsidiaries through which GEO conducts its operations worldwide; 

and that Mr. Zoley has bachelor’s and master’s degrees in Public Administration from Florida 

Atlantic University and a Doctorate Degree in Public Administration from Nova Southeastern 

University. GEO denies that Mr. Zoley currently serves as its CEO, and further denies that Mr. 

Zoley has served as CEO since the Company went public in 1994. 

35. GEO admits only that Mr. Zoley was an officer and director of the Company during 

the putative class period and had knowledge of certain details of GEO’s internal affairs. GEO 

denies the remaining allegations in Paragraph 35. 

36. GEO admits that Mr. Zoley was an officer and director of the Company during the 

putative class period. GEO denies the remaining allegations in Paragraph 36. 

37. GEO admits that Mr. Zoley was an officer and director of the Company during the 

putative class period. GEO responds that the statements in Paragraph 37 regarding Mr. Zoley’s 

duties as an officer and director of the Company state legal conclusions and questions of law to 

which no response is required. To the extent that a response is required, GEO denies the remaining 

allegations in Paragraph 37. 

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38. GEO admits that Mr. Zoley was an officer and director of the Company. GEO 

denies the remaining allegations in Paragraph 38. 

39. GEO denies the allegations in Paragraph 39. 

40. There is no numbered Paragraph 40 in the Second Amended Complaint. 

41. There is no numbered Paragraph 41 in the Second Amended Complaint. 

42. There is no numbered Paragraph 42 in the Second Amended Complaint. 

43. There is no numbered Paragraph 43 in the Second Amended Complaint. 

44. GEO admits only that it was founded in 1984; that it operates internationally; that 

it provides complementary, turnkey solutions for numerous government partners worldwide across 

a spectrum of diversified correctional and community reentry services; and that it aspires to be the 

world’s leading provider of evidence-based rehabilitation across its diversified spectrum of 

correctional and community reentry services. GEO denies that it is currently a REIT, and denies 

the remaining allegations in Paragraph 44. 

45. GEO admits only that it restructured as a REIT as of January 1, 2013, but denies 

that it is currently a REIT. GEO denies the remaining allegations in Paragraph 45. 

46. GEO admits only that each agreement it has entered into speaks for itself and denies 

any inconsistent allegations in Paragraph 46. 

47. GEO denies the allegations in Paragraph 47. 

48. GEO denies the allegations in Paragraph 48. 

49. In response to the allegations contained in Paragraph 49, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

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the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 49, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 49 

are denied. 

50. In response to the allegations contained in Paragraph 50, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 50, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 50 

are denied. 

51. In response to the allegations contained in Paragraph 51, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 51, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 51 

are denied. 

52. In response to the allegations contained in Paragraph 52, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously

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“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 52, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 52 

are denied. 

53. In response to the allegations contained in Paragraph 53, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 53, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 53 

are denied. 

54. In response to the allegations contained in Paragraph 54, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 54, because the Court has previously 

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dismissed these allegations. To the extent a response is required, the allegations in Paragraph 54 

are denied. 

55. In response to the allegations contained in Paragraph 55, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 55, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 55 

are denied. 

56. In response to the allegations contained in Paragraph 56, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 56, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 56 

are denied. 

57. GEO admits only that certain lawsuits have been filed against it, as disclosed in its 

SEC filings when and to the extent required by the federal securities laws. Each lawsuit speaks 

for itself, and GEO denies any inconsistent allegations relating to such lawsuits in Paragraph 57. 

GEO denies the remaining allegations in Paragraph 57. 

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58. In response to the allegations contained in Paragraph 58, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 58, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 58 

are denied. 

59. GEO admits only that a putative class action lawsuit, Menocal v. GEO Group, Inc., 

Civil Action No. 14-cv-02887, was filed regarding the Aurora Facility in Aurora, Colorado, and 

that the procedural history of that lawsuit, including pleadings and orders, speaks for itself. GEO 

denies any inconsistent allegations in Paragraph 59. 

60. GEO admits only that more than one lawsuit was filed regarding ICE’s Voluntary 

Work Program at certain of GEO’s facilities. GEO states that Mr. Zoley’s May 30, 2018 letter to 

ICE speaks for itself, and denies any inconsistent allegations in Paragraph 60. GEO also states 

that Senator Warren’s July 24, 2019 letter to the SEC Chairman speaks for itself, and denies any 

inconsistent allegations in Paragraph 60. GEO specifically denies that it made any misleading 

public statements and omissions of material facts, and denies the allegations in the last sentence 

of Paragraph 60. The remaining allegations in Paragraph 60 are denied.

61. In response to the allegations contained in Paragraph 61, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 17 of 57
18 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 61, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 61 

are denied. 

62. In response to the allegations contained in Paragraph 62, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 62, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 62 

are denied. 

63. In response to the allegations contained in Paragraph 63, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 63, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 63 

are denied. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 18 of 57
19 

64. In response to the allegations contained in Paragraph 64, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 64, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 64 

are denied. 

65. In response to the allegations contained in Paragraph 65, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 65, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 65 

are denied. 

66. In response to the allegations contained in Paragraph 66, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 19 of 57
20 

pleading is required to the allegations contained in Paragraph 66, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 66 

are denied. 

67. In response to the allegations contained in Paragraph 67, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 67, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 67 

are denied. 

68. In response to the allegations contained in Paragraph 68, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 68, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 68 

are denied. 

69. In response to the allegations contained in Paragraph 69, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 20 of 57
21 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 69, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 69 

are denied. 

70. In response to the allegations contained in Paragraph 70, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 70, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 70 

are denied. 

71. In response to the allegations contained in Paragraph 71, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 71, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 71 

are denied. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 21 of 57
22 

72. In response to the allegations contained in Paragraph 72, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 72, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 72 

are denied. 

73. In response to the allegations contained in Paragraph 73, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 73, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 73 

are denied. 

74. In response to the allegations contained in Paragraph 74, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 22 of 57
23 

pleading is required to the allegations contained in Paragraph 74, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 74 

are denied. 

75. In response to the allegations contained in Paragraph 75, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 75, because the Court has previously

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 75 

are denied. 

76. In response to the allegations contained in Paragraph 76, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 76, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 76 

are denied. 

77. In response to the allegations contained in Paragraph 77, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 23 of 57
24 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 77, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 77 

are denied. 

78. In response to the allegations contained in Paragraph 78, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 78, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 78 

are denied. 

79. In response to the allegations contained in Paragraph 79, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 79, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 79 

are denied. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 24 of 57
25 

80. In response to the allegations contained in Paragraph 80, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 80, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 80 

are denied. 

81. In response to the allegations contained in Paragraph 81, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 81, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 81 

are denied. 

82. In response to the allegations contained in Paragraph 82, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 25 of 57
26 

pleading is required to the allegations contained in Paragraph 82, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 82 

are denied. 

83. In response to the allegations contained in Paragraph 83, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 83, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 83 

are denied. 

84. In response to the allegations contained in Paragraph 84, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 84, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 84 

are denied. 

85. In response to the allegations contained in Paragraph 85, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 26 of 57
27 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 85, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 85 

are denied. 

86. In response to the allegations contained in Paragraph 86, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 86, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 86 

are denied. 

87. In response to the allegations contained in Paragraph 87, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 87, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 87 

are denied. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 27 of 57
28 

88. In response to the allegations contained in Paragraph 88, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 88, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 88 

are denied. 

89. In response to the allegations contained in Paragraph 89, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 89, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 89 

are denied. 

90. In response to the allegations contained in Paragraph 90, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 28 of 57
29 

pleading is required to the allegations contained in Paragraph 90, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 90 

are denied. 

91. In response to the allegations contained in Paragraph 91, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 91, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 91 

are denied. 

92. In response to the allegations contained in Paragraph 92, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 92, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 92 

are denied. 

93. In response to the allegations contained in Paragraph 93, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 29 of 57
30 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 93, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 93 

are denied. 

94. In response to the allegations contained in Paragraph 94, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 94, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 94 

are denied. 

95. In response to the allegations contained in Paragraph 95, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 95, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 95 

are denied. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 30 of 57
31 

96. In response to the allegations contained in Paragraph 96, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 96, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 96 

are denied. 

97. In response to the allegations contained in Paragraph 97, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 97, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 97 

are denied. 

98. In response to the allegations contained in Paragraph 98, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 31 of 57
32 

pleading is required to the allegations contained in Paragraph 98, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 98 

are denied. 

99. In response to the allegations contained in Paragraph 99, GEO responds that, in the 

June 21 Order on Motion to Dismiss, the Court specifically noted that although it had previously 

“dismissed all of [Lead] Plaintiffs’ claims except those based on statements about pending 

lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the allegations 

contained in the Amended Complaint. However, only the statements about pending lawsuits form 

the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive 

pleading is required to the allegations contained in Paragraph 99, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 99 

are denied. 

100. In response to the allegations contained in Paragraph 100, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 100, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 100 are denied. 

101. In response to the allegations contained in Paragraph 101, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 32 of 57
33 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 101, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 101 are denied. 

102. In response to the allegations contained in Paragraph 102, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 102, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 102 are denied. 

103. In response to the allegations contained in Paragraph 103, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 103, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 103 are denied. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 33 of 57
34 

104. In response to the allegations contained in Paragraph 104, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 104, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 104 are denied. 

105. In response to the allegations contained in Paragraph 105, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 105, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 105 are denied. 

106. In response to the allegations contained in Paragraph 106, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

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35 

no responsive pleading is required to the allegations contained in Paragraph 106, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 106 are denied. 

107. GEO admits that it filed a Form 10-Q with the SEC on November 8, 2018. GEO 

states that the November 8, 2018 Form 10-Q speaks for itself, and denies any inconsistent 

allegations in Paragraph 107. 

108. GEO denies the allegations in Paragraph 108. 

109. GEO states that any statement made by Mr. Evans during the February 14, 2019 

Fourth Quarter 2018 Earnings Conference Call speaks for itself, and denies any inconsistent 

allegations in Paragraph 109. 

110. GEO denies the allegations in Paragraph 110. 

111. GEO admits that it filed a Form 10-K with the SEC on February 25, 2019. GEO 

states that the February 25, 2019 Form 10-K speaks for itself, and denies any inconsistent 

allegations in Paragraph 111. 

112. GEO denies the allegations in Paragraph 112. 

113. GEO admits that it filed a Form 10-Q with the SEC on May 6, 2019. GEO states 

that the May 6, 2019 Form 10-Q speaks for itself, and denies any inconsistent allegations in 

Paragraph 113. 

114. GEO denies the allegations in Paragraph 114. 

115. In response to the allegations contained in Paragraph 115, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 115, because the Court has previously 

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36 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 115 

are denied. 

116. In response to the allegations contained in Paragraph 116, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 116, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 116 

are denied. 

117. In response to the allegations contained in Paragraph 117, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 117, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 117 

are denied. 

118. In response to the allegations contained in Paragraph 118, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 118, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 118 

are denied. 

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37 

119. In response to the allegations contained in Paragraph 119, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 119, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 119 

are denied. 

120. In response to the allegations contained in Paragraph 120, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 120, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 120 

are denied. 

121. In response to the allegations contained in Paragraph 121, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 121, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 121 

are denied. 

122. In response to the allegations contained in Paragraph 122, GEO states that, in the 

June 21 Order on Motion to Dismiss, the Court specifically held that “Defendants’ Motion to 

Dismiss is GRANTED as to all statements made after July 17, 2019. [Lead] Plaintiffs’ claim shall 

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38 

proceed only on those statements made before July 17, 2019 . . .” As such, no responsive pleading 

is required to the allegations contained in Paragraph 122, because the Court has previously 

dismissed these allegations. To the extent a response is required, the allegations in Paragraph 122 

are denied. 

123. In response to the allegations contained in Paragraph 123, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 123, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 123 are denied. 

124. In response to the allegations contained in Paragraph 124, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 124, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 124 are denied. 

125. In response to the allegations contained in Paragraph 125, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

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39 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 125, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 125 are denied. 

126. In response to the allegations contained in Paragraph 126, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 126, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 126 are denied. 

127. In response to the allegations contained in Paragraph 127, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 127, because the Court 

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40 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 127 are denied. 

128. Responding to the allegations in Paragraph 128, GEO states that Mr. Zoley’s May 

30, 2018 letter to ICE speaks for itself, and denies any inconsistent allegations in Paragraph 128. 

GEO states that the historical price of GEO’s common stock speaks for itself, and denies any 

inconsistent allegations in Paragraph 128. GEO denies the remaining allegations in Paragraph 

128. 

129. In response to the allegations contained in Paragraph 129, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 129, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 129 are denied. 

130. In response to the allegations contained in Paragraph 130, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 130, because the Court 

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41 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 130 are denied. 

131. In response to the allegations contained in Paragraph 131, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 131, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 131 are denied. 

132. In response to the allegations contained in Paragraph 132, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 132, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 132 are denied. 

133. In response to the allegations contained in Paragraph 133, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

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42 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 133, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 133 are denied. 

134. In response to the allegations contained in Paragraph 134, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 134, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 134 are denied. 

135. In response to the allegations contained in Paragraph 135, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 135, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 135 are denied. 

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43 

136. In response to the allegations contained in Paragraph 136, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 136, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 136 are denied. 

137. In response to the allegations contained in Paragraph 137, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 137, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 137 are denied. 

138. In response to the allegations contained in Paragraph 138, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

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44 

no responsive pleading is required to the allegations contained in Paragraph 138, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 138 are denied. 

139. GEO denies the allegations in Paragraph 139. 

140. GEO denies the allegations in Paragraph 140. 

141. In response to the allegations contained in the second sentence of Paragraph 141, 

GEO responds that, in the June 21 Order on Motion to Dismiss, the Court specifically noted that 

although it had previously “dismissed all of [Lead] Plaintiffs’ claims except those based on 

statements about pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains 

most of the allegations contained in the Amended Complaint. However, only the statements about 

pending lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. 

As such, no responsive pleading is required to the allegations contained in the second sentence of 

Paragraph 141, because the Court has previously dismissed these allegations. To the extent a 

response is required, the allegations in the second sentence of Paragraph 141 are denied. GEO 

denies the remaining allegations in Paragraph 141. 

142. In response to the allegations contained in Paragraph 142, GEO responds that 

Senator Warren’s July 24, 2019 letter to the SEC Chairman speaks for itself, and denies any 

inconsistent allegations in Paragraph 142. GEO further responds that, in the June 21 Order on 

Motion to Dismiss, the Court specifically noted that although it had previously “dismissed all of 

[Lead] Plaintiffs’ claims except those based on statements about pending lawsuits . . . ,” Lead 

“Plaintiffs’ [Second Amended Complaint] contains most of the allegations contained in the 

Amended Complaint. However, only the statements about pending lawsuits form the basis of

[Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive pleading is 

required to the remaining allegations contained in Paragraph 142, because the Court has previously 

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45 

dismissed these allegations. To the extent a response is required, the remaining allegations in 

Paragraph 142 are denied. 

143. GEO denies the allegations in Paragraph 143. 

144. GEO denies the allegations in the first sentence of Paragraph 144. Responding to 

the remaining allegations in Paragraph 144, GEO further responds that, in the June 21 Order on 

Motion to Dismiss, the Court specifically noted that although it had previously “dismissed all of 

[Lead] Plaintiffs’ claims except those based on statements about pending lawsuits . . . ,” Lead 

“Plaintiffs’ [Second Amended Complaint] contains most of the allegations contained in the 

Amended Complaint. However, only the statements about pending lawsuits form the basis of 

[Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, no responsive pleading is 

required to the allegations contained in the second through ninth sentences of Paragraph 144, 

because the Court has previously dismissed these allegations. To the extent a response is required, 

the allegations in the second through ninth sentences of Paragraph 144 are denied. 

145. In response to the allegations contained in Paragraph 145, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 145, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 145 are denied. 

146. In response to the allegations contained in Paragraph 146, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

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46 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 146, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 146 are denied. 

147. In response to the allegations contained in Paragraph 147, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 147, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 147 are denied. 

148. In response to the allegations contained in Paragraph 148, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 148, because the Court 

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47 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 148 are denied. 

149. In response to the allegations contained in Paragraph 149, GEO responds that, in 

the June 21 Order on Motion to Dismiss, the Court specifically noted that although it had 

previously “dismissed all of [Lead] Plaintiffs’ claims except those based on statements about 

pending lawsuits . . . ,” Lead “Plaintiffs’ [Second Amended Complaint] contains most of the 

allegations contained in the Amended Complaint. However, only the statements about pending 

lawsuits form the basis of [Lead] Plaintiffs’ claims” in the Second Amended Complaint. As such, 

no responsive pleading is required to the allegations contained in Paragraph 149, because the Court 

has previously dismissed these allegations. To the extent a response is required, the allegations in 

Paragraph 149 are denied. 

150. GEO denies the allegations in Paragraph 150. 

151. GEO denies the allegations in Paragraph 151. 

152. GEO denies the allegations in Paragraph 152. 

153. GEO denies the allegations in Paragraph 153. 

154. GEO denies the allegations in Paragraph 154. 

155. GEO denies the allegations in Paragraph 155. 

156. GEO admits that Lead Plaintiffs purport to bring a federal securities class action on 

behalf of a putative class of persons who purchased or otherwise acquired GEO common stock 

during a proposed purported class period. However, Lead Plaintiffs’ proposed purported class 

period has been modified by this Court in its June 21 Order on Motion to Dismiss. GEO denies 

that any of Lead Plaintiffs’ claims have any merit, and denies that any putative class should be 

certified pursuant to Federal Rule of Civil Procedure 23. 

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157. GEO admits that GEO’s common stock was traded on the NYSE during the 

purported class period as modified by the Court in its June 21 Order on Motion to Dismiss. GEO 

denies the remaining allegations in Paragraph 157. 

158. GEO denies the allegations in Paragraph 158. 

159. GEO denies the allegations in Paragraph 159. 

160. GEO denies the allegations in Paragraph 160. 

161. GEO denies the allegations in Paragraph 161. 

162. GEO lacks knowledge or information sufficient to form a belief as to what Lead 

Plaintiffs’ will rely upon, and therefore denies the allegations in Paragraph 162. 

163. GEO denies the allegations in Paragraph 163. 

164. GEO denies the allegations in Paragraph 164. 

COUNT I

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

Against All Defendants

165. GEO repeats and realleges its responses to Paragraphs 1 to 164 above as if fully set 

forth herein. 

166. GEO admits that Count I is based upon Section 10(b) of the Exchange Act, 15 

U.S.C. § 78j(b), and Rule 10b-5 promulgated thereunder and is purportedly asserted against 

Defendants. GEO denies that Count I has any merit. 

167. GEO denies the allegations in Paragraph 167. 

168. GEO denies the allegations in Paragraph 168. 

169. GEO denies the allegations in Paragraph 169. 

170. GEO denies the allegations in Paragraph 170. 

171. GEO denies the allegations in Paragraph 171. 

172. GEO denies the allegations in Paragraph 172. 

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173. GEO denies the allegations in Paragraph 173. 

174. GEO denies the allegations in Paragraph 174. 

COUNT II

Violations of § 20(a) of the Exchange Act 

Against Defendant Zoley 

175. GEO repeats and realleges its responses to Paragraphs 1 to 164 above as if fully set 

forth herein. 

176. Count II is not directed towards GEO and therefore no response by it is required or 

provided.

177. Count II is not directed towards GEO and therefore no response by it is required or 

provided. 

178. Count II is not directed towards GEO and therefore no response by it is required or 

provided. 

179. Count II is not directed towards GEO and therefore no response by it is required or 

provided. 

180. Count II is not directed towards GEO and therefore no response by it is required or 

provided. 

PRAYER FOR RELIEF

181. GEO denies Lead Plaintiffs’ Prayer for Relief in all respects.

GENERAL DENIAL

182. GEO states that the disclosures referenced in Appendix A to the Second Amended 

Complaint speak for themselves and denies any inconsistent allegations. 

183. GEO denies each and every allegation of the Second Amended Complaint to which 

it has not otherwise made a specific response in this Answer. 

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50 

AFFIRMATIVE DEFENSES

GEO will rely on all defenses available to it at the time of trial of this matter and reserves 

the right to amend its Answer and Affirmative Defenses. For its Affirmative Defenses, GEO 

pleads as follows, without assuming the burden of proof where it otherwise rests with Lead 

Plaintiffs:

First Defense

 The Second Amended Complaint fails to state a claim upon which relief may be granted. 

Second Defense

Lead Plaintiffs and other alleged members of the putative class lack standing to bring this 

action and pursue their claims.

Third Defense

Lead Plaintiffs’ claims are barred, in whole or in part, by the doctrines of assumption of 

risk, waiver, ratification, estoppel and/or laches. 

Fourth Defense

The Second Amended Complaint fails to allege fraud with particularity as required by Fed. 

R. Civ. P. 9(b). 

Fifth Defense

The Second Amended Complaint fails to comply with the pleading standards and 

requirements of the Private Securities Litigation Reform Act of 1995.

Sixth Defense

GEO did not act with the requisite scienter to give rise to any claims against it under Section 

10(b) or Rule 10b-5. 

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Seventh Defense

The purported false statements or omissions alleged in the Second Amended Complaint 

were not material.

Eighth Defense

The Second Amended Complaint is barred on the grounds and to the extent that the 

statements alleged were true and accurate when made.

Ninth Defense

Lead Plaintiffs’ claims are barred because they are based upon forward-looking statements, 

which are protected by the safe harbor provided under the Private Securities Litigation Reform 

Act of 1995. 

Tenth Defense

Lead Plaintiffs’ claims are barred by the bespeaks caution doctrine.

Eleventh Defense

GEO acted in good faith and had no knowledge or belief, and was not reckless in not 

knowing, that any statement or omission alleged in the Second Amended Complaint was false or 

misleading at the time it was made. 

Twelfth Defense

GEO did not know, and in the exercise of reasonable care could not have known, of any 

untruth or material omission that may be proved by Lead Plaintiffs. 

Thirteenth Defense

Lead Plaintiffs’ purported claims are barred because GEO’s actions or inactions are not the 

cause in fact, nor the legal cause, nor the proximate cause of Lead Plaintiffs’ alleged losses or 

damages. 

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Fourteenth Defense

Any injury or damage which may have been suffered by Lead Plaintiffs resulted wholly or 

in substantial part from the misconduct of parties other than GEO, for which GEO is in no way 

liable.

Fifteenth Defense

To the extent Lead Plaintiffs knew the truth of the alleged misrepresented or omitted facts, 

the Second Amended Complaint must be dismissed. 

Sixteenth Defense

To the extent that the truth of the alleged misrepresented or omitted facts were available to 

or within the market for the Company’s stock, the Second Amended Complaint must be dismissed. 

Seventeenth Defense 

Lead Plaintiffs assumed and accepted the risks associated with their investment in GEO’s 

common stock, and any drop in the market price of GEO’s common stock was due to superseding 

causes. 

Eighteenth Defense

Any damages suffered by Lead Plaintiffs are barred by Lead Plaintiffs’ failure to mitigate 

their injuries or damages, if any. 

Nineteenth Defense

Any injury or damage which may have been suffered by Lead Plaintiffs resulted wholly or 

in substantial part from Lead Plaintiffs’ failure to exercise due care and to reasonably protect 

themselves.

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Twentieth Defense

In the event that Lead Plaintiffs prevail in this action, GEO is entitled to a set-off and/or 

reduction of any damages awarded equal to any payment to, or recovery by, Lead Plaintiffs from 

other sources. 

Twenty-First Defense

This action may not properly be maintained as a class action. 

Twenty-Second Defense

Lead Plaintiffs are not proper or adequate class representatives. 

Twenty-Third Defense

Lead Plaintiffs’ claims are not typical of the claims of the putative class of persons whom 

Lead Plaintiffs seek to represent; there are not questions of law or fact common to the members of 

the putative class, if any; and alternatively, to the extent that there may be questions of law or fact 

common to the members of the putative class, if any, those questions do not predominate over 

questions affecting only individual members, and a class action is not superior to other available 

methods for the fair and efficient adjudication of this controversy. Lead Plaintiffs’ claims do not 

otherwise satisfy the requirements of Fed. R. Civ. P. 23 for class treatment. 

Twenty-Fourth Defense

Lead Plaintiffs are not entitled to rely on the fraud-on-the-market presumption, and are 

therefore required to prove individual reliance on any alleged misstatements or omissions.

Twenty-Fifth Defense

 To the extent GEO is found liable, any liability must be apportioned pursuant to the terms 

of the Private Securities Litigation Reform Act of 1995 and other applicable law. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 53 of 57
54 

Twenty-Sixth Defense

Lead Plaintiffs’ claims are barred because factors other than the alleged misconduct, 

including but not limited to the condition and volatility of the stock market and economy, and 

business and industry conditions, were the actual and/or legal cause of any alleged damages or 

injury. 

Twenty-Seventh Defense

Lead Plaintiffs’ claims are barred because any damage or injury suffered by Lead Plaintiffs 

and others alleged to be members of the putative class is speculative and not recoverable.

Twenty-Eighth Defense

Lead Plaintiffs’ claims are barred because Lead Plaintiffs and others alleged to be members 

of the putative class did not reasonably rely on any alleged misstatements or omissions. 

Twenty-Ninth Defense

Lead Plaintiffs’ claims are barred because Lead Plaintiffs and others alleged to be members 

of the putative class did not suffer any damages or injury. 

Thirtieth Defense

Lead Plaintiffs’ claims are barred because GEO acted in accordance with the rules and 

regulations set forth by the SEC and other administrative, regulatory and government agencies. 

Thirty-First Defense

Lead Plaintiffs’ claims are barred because the statements at issue were vague and 

immaterial and thus not actionable.

Thirty-Second Defense

 GEO did not directly or indirectly induce or foster any violation of the securities laws. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 54 of 57
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Thirty-Third Defense

GEO’s purported false statements were not the cause of any drop in the market price of 

GEO’s stock during the putative class period, as modified by the Court in its June 21 Order on 

Motion to Dismiss.

Thirty-Fourth Defense

The Second Amended Complaint does not establish loss causation. 

Thirty-Fifth Defense

Lead Plaintiffs’ claims are barred by the “truth on the market” doctrine because the truth 

concerning any alleged misrepresentation or omission was at all relevant times already publicly 

available and/or known to the market and could therefore not defraud the market. 

Thirty-Sixth Defense

Lead Plaintiffs’ claims are barred because the substance of the information alleged to have 

been omitted or misrepresented was in fact publicly disclosed by GEO, and was otherwise publicly 

available and known by the public. 

Thirty-Seventh Defense

Lead Plaintiffs’ claims are barred, in whole or in part, because Lead Plaintiffs had 

knowledge of the alleged untruths or omissions at the time they acquired the securities in question. 

Thirty-Eighth Defense

Lead Plaintiffs’ claims fail to the extent they rely on unproven allegations made in other 

litigation and/or articles relating thereto.

Thirty-Ninth Defense

Lead Plaintiffs’ claims fail because any alleged misstatements contained sufficient 

cautionary language and risk disclosure. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 55 of 57
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Fortieth Defense

Lead Plaintiffs and other alleged members of the putative class would have acquired GEO 

stock even if, when acquired, they had known of the alleged misrepresentations or omissions. 

Forty-First Defense

Lead Plaintiffs’ damages, if any, resulted from ongoing economic events, over which GEO 

had no control. 

Forty-Second Defense

Any recovery for damages allegedly incurred by Lead Plaintiffs and members of the 

putative class, if any, is subject to offset in an amount including, but not limited to, any tax benefits 

actually received by Lead Plaintiffs or each member of the putative class through its/his/her 

investments.

Forty-Third Defense

GEO hereby reserves its right to assert, at a later date, third-party complaints or crossclaims against other parties for contribution or indemnity. 

WHEREFORE, GEO, having fully answered Plaintiffs’ Second Amended Complaint, 

prays: 

(1) that the Second Amended Complaint be dismissed with prejudice; 

(2) that judgment be entered in Defendants’ favor; 

(3) that all costs of this action be taxed against Lead Plaintiffs;

(4) that Defendants’ attorneys’ fees be taxed against Lead Plaintiffs pursuant to the 

Private Securities Litigation Reform Act of 1995; and

(5) for such other and further relief as the Court deems just and proper. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 56 of 57
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Dated: July 1, 2022 Respectfully submitted,

 KING & SPALDING, LLP

Southeast Financial Center

 200 S. Biscayne Boulevard 

 Suite 4700 

 Miami, Florida 33131 

 Telephone: (305) 462-6000 

 By: /s/ Brian P. Miller

Brian P. Miller, Esq. 

Florida Bar No. 0980633 

bmiller@kslaw.com 

Samantha J. Kavanaugh, Esq. 

Florida Bar No. 0194662 

skavanaugh@kslaw.com

Ross E. Linzer, Esq. 

Florida Bar No. 0073094 

rlinzer@kslaw.com

 Counsel for Defendant The GEO Group, Inc. 

Case 9:20-cv-81063-RS Document 64 Entered on FLSD Docket 07/01/2022 Page 57 of 57