UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

PANAMA CITY DIVISION 

JUAN BA YOLO, M.D., 

Plaintiff, 

v. Case No. 5:19-cv-00403-TKW-MJF 

MHM HEALTH PROFESSIONALS, 

LLC f/k/a MHM HEAL TH 

PROFESSIONALS, INC., 

Defendant. _______________ ./ 

DECLARATION OF VICTORIA LOVE 

1. I, Victoria Love, am of majority age, am competent to testify, and 

provide this Declaration based on my personal knowledge and my review of 

business records maintained by MHM Health Professionals, LLC ("MHMHP"), 1 

in the ordinary course of business. 

2. I am employed by MHMHP. I have been employed with MHMHP 

for fourteen years. Since February of 2016, my title has been Regional Vice 

President for the State of Florida. Prior to February of 2016, I was the Vice 

President of Operational Development and worked in several states. 

1 MHMHP was converted from a corporation to a limited liability company effective December 31 , 2018. 

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3. I am responsible for ensuring that MHMHP is meeting its contractual 

obligations with the Florida Department of Corrections. In that capacity, I oversee 

the delivery of healthcare at some seventy-plus locations throughout the State of 

Florida. 

4. I also am operationally responsible for the provision of healthcare 

services for MHMHP. I work closely with the Vice President of Operations, 

Regional Directors and the Human Resources Department who directly engage 

with employees at facilities throughout Florida. For the period from April 2016 

through October 2019, I also participated in, review, and approve employee 

disciplinary action when termination is suggested. 

5. For the period from April 2016 through October 2019, the termination 

process typically began at the facility level for facility employees. The facility 

then submitted the termination paperwork, and all relevant and supp011ing 

documentation, to the Regional Director. If the Regional Director approved the 

termination, it was then submitted to Human Resources for review. If Human 

Resources approved, the te1mination was then submitted to me for final approval. 

6. In ce11ain limited instances, regional management or facility 

management could have suspended an employee while an investigation was 

pending. This was usually in instances where, because of the severity of the 

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alleged employee misconduct, MHJ'v1HP or its client did not believe that the 

employee should be at the facility, but management had not completed an 

investigation into the misconduct or had not yet obtained all of the necessary 

termination approvals required by MHMHP. 

7. With respect to Dr. Juan Bayolo's termination, I was the final

decisionmaker. I approved his termination on October 19, 2017. Based on my 

review of documents, the termination notice was ultimately delivered to Dr. 

Bayolo on October 20, 2017. 

8. My decision to terminate Dr. Bayolo was based on his violation of

the Workplace Violence Prevention Policy following earlier similar incidents. 

ongm. 

9. My decision to terminate Dr. Bayolo was not based on his gender.

10. My decision to terminate Dr. Bayolo was not based on his national

11. My decision to terminate Dr. Bayolo was not in retaliation for, nor

based on, any complaints that Dr. Bayolo made to Management or to Human 

Resources. 

12. My decision to terminate Dr. Bayolo was not in retaliation for, nor

based on, any alleged "whistleblowing" as Dr. Bayolo claims. 

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13. My decision to terminate Dr. Bayolo was not based on his alleged 

disability. In fact, I was not aware that he had any disability. 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the 

foregoing is true and correct. 

Executed on 13th day of October, 2020. 

Victoria Love 

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