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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA

 The parties have filed an unopposed Joint Motion to Enter Consent Decree (Doc. 

80), along with the proposed Consent Decree (Doc. 80-1). The Court has reviewed the 

filings and concludes that the Consent Decree is fair, reasonable, and not contrary to law. 

Accordingly, 

IT IS ORDERED that Joint Motion for Entry of Consent Decree (Doc. 80) is 

granted. The parties’ lodged Consent Decree, as attached hereto, is adopted and entered 

as the final judgment in this case pursuant to Rule 54 of the Federal Rules of Civil 

Procedure. 

 Dated this 24th day of August, 2017.

Honorable Steven P. Logan

United States District Judge

 

Equal Employment Opportunity 

Commission, 

 

Plaintiff, 

vs. 

The Geo Group, Inc., 

Defendant. 

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No. CV-15-01909-PHX-SPL

ORDER 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA

TABLE OF CONTENTS 

I. RECITALS ............................................................................................... 4 

II. JURISDICTION ....................................................................................... 4 

III. TERMS AND SCOPE ............................................................................. 4 

IV. ISSUES RESOLVED ............................................................................... 5 

V. MONETARY RELIEF ............................................................................ 5 

VI. OTHER INDIVIDUAL RELIEF ............................................................ 6 

VII. EQUITABLE RELIEF ............................................................................ 7 

VIII. REPORTING PROVISIONS ............................................................... 17 

 IX. RETENTION OF JURISDICTION AND ENFORCEMENT OF 

 DECREE ................................................................................................. 19 

X. EEOC AUTHORITY ............................................................................. 20 

XI. COSTS AND ATTORNEY'S FEES ..................................................... 20 

Equal Employment Opportunity 

Commission, 

 

Plaintiff, 

vs. 

The Geo Group, Inc., 

Defendant. 

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No. CV-15-01909-PHX-SPL 

CONSENT DECREE 

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 XII. SIGNATURES ....................................................................................... 20

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I. RECITALS 

1. This matter was instituted by Plaintiff, Equal Employment Opportunity 

Commission (“Commission” or “Plaintiff” or “EEOC”), an agency of the United States 

government, alleging that Defendant, the GEO Group, Inc., subjected Roberta Jones to 

sexual harassment and retaliation. 

2. Defendant denies all of the allegations. Nothing in this Consent Decree 

(“Decree”) shall constitute an admission of liability by the Defendant related to this 

matter. 

3. The Parties to this Decree are the Plaintiff EEOC and Defendant The GEO 

Group, Inc. 

4. The Parties, desiring to settle this action by an appropriate Decree, agree to 

the jurisdiction of this Court over the Parties and the subject matter of this action, and 

agree to the power of this Court to enter a Consent Decree enforceable against 

Defendant. 

5. As to the issues resolved, this Decree is final and binding upon the Parties 

and their successors and assigns. 

6. The Parties agree that this Consent Decree is fair, reasonable, and not 

contrary to law. 

7. For the purpose of resolving disputed claims, the Parties jointly request 

this Court to adjudge as follows: 

IT IS ORDERED, ADJUDGED, AND DECREED AS FOLLOWS: 

II. JURISDICTION 

8. The Parties stipulate to the jurisdiction of the Court over the Parties and 

subject matter of this action and have waived the entry of findings of fact and 

conclusions of law. 

III. TERM AND SCOPE 

9. Term: The duration of this Decree shall be two years from the date of 

signing by the Court.

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10. Scope: The terms of this Decree shall apply to The GEO Group Inc.’s 

Central Arizona Correctional Facility (“CACF”), located in the state of Arizona. 

IV. ISSUES RESOLVED

11. This Decree resolves the claims alleged in the above-captioned lawsuit, 

and constitutes a resolution of the Commission’s claims arising from unlawful 

employment practices suffered by the aggrieved individual, Roberta Jones, under Title 

VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-5(f)(1) and (3) 

(“Title VII”), that arise from Charge of Discrimination Numbers 35A-2013-00068 and 

35A-2013-00254, filed by Roberta Jones with the Arizona Civil Rights Division 

(“ACRD”).

12. Defendant and its officers, agents, employees, successors, and all other 

persons in active concert or participation with any of them will not interfere with the 

relief herein ordered, but shall cooperate in the implementation of this Decree.

V. MONETARY RELIEF 

13. Defendant shall pay the amount of sixty thousand dollars ($60,000) to 

Roberta Jones. This amount represents back pay in the amount of fifty thousand dollars 

($50,000) and ten thousand dollars ($10,000) in interest for Roberta Jones.

14. Defendant will not condition the receipt of individual relief upon Roberta 

Jones’s agreement to: (a) maintain as confidential the facts and/or allegations underlying 

her charges and complaint and the terms of this Decree; (b) waive her statutory right to 

file a charge with any governmental agency; (c) refrain from reapplying for a job with 

Defendant; or (d) agree to a non-disparagement and/or confidentiality agreement. 

Defendant shall pay the settlement amount to Roberta Jones by check, cashier’s check, 

or money order in accordance with Paragraph 13 of this Decree. By January 31, 2018, 

Defendant shall issue United States Internal Revenue Service Form 1099 for all 

payments designated as interest and United States Internal Revenue Service Form W-2 

for all payments designated as back pay.

15. The payment provided for in Paragraph 13 of this Decree shall be made by 

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check, cashier’s check, or money order and mailed directly by Defendant to Roberta 

Jones at addresses separately supplied by the Commission within fifteen (15) days after 

the Court’s entry of this Decree. Within three (3) business days of issuance of the 

checks, Defendant shall furnish a copy of each check and related correspondence to the 

Regional Attorney, Equal Employment Opportunity Commission, 3300 N. Central 

Avenue, Suite 690, Phoenix, Arizona, 85012. The payment of the settlement amount to 

Jones under paragraphs 13-15 of this Decree also satisfies GEO’s payment obligation to 

Jones in connection with National Labor Relations Board Case No. 28-CA-094752.

VI. OTHER INDIVIDUAL RELIEF 

16. Within thirty (30) days after entry of this Decree, Defendant shall expunge 

from Roberta Jones’s personnel files (a) any and all references to the allegations of 

discrimination filed against Defendant that formed the basis of this action; and (b) any 

and all references to this action. 

17. Within thirty (30) days after entry of this Decree, Defendant will also 

provide a neutral letter of reference in the form attached as Exhibit A for Roberta Jones 

and will change her personnel record to reflect that she is eligible for rehire. 

18. Within ten (10) days after entry of this Consent Decree, when contacted 

for employment references for Roberta Jones, Defendant shall direct any requests for 

employment references to its 1-800-WORK NUMBER which will provide the following 

information: 

18.1. Dates of employment; and 

18.2. Last position held. 

No other information will be provided to prospective employers that inquire 

about Roberta Jones’s employment history, other than to say that it is Defendant’s policy 

only to provide dates of employment and last position held. 

19. Within ten (10) days after entry of this Consent Decree, Defendant will 

inform all of its lieutenants, captains, assistant wardens, wardens, and Human Resources 

personnel at CACF in writing that any and all reference inquiries regarding Roberta 

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Jones per GEO policy must be directed to GEO’s 1-800-WORK NUMBER. 

20. Within fifteen (15) days after entry of this Decree, Defendant shall provide 

a letter to Roberta Jones on company letterhead in the form attached as Exhibit B. 

VII. EQUITABLE RELIEF 

A. Injunctive Relief 

21. Defendant, its officers, agents, successors, and other persons in active 

concert or participation with it, or any of them, are enjoined from engaging in any 

employment practice which discriminates on the basis of gender.

22. Defendant, its officers, agents, successors, and other persons in active 

concert or participation with them, or any of them, are enjoined from engaging in 

reprisal or retaliation of any kind against any person because of such person’s opposition 

to any practice made unlawful under Title VII of the Civil Rights Act of 1964, as 

amended. Defendant shall not retaliate against a person because such person brings an 

internal complaint of discrimination with the Defendant; because such person files or 

causes to be filed a charge of discrimination with the Commission, the ACRD, or any 

other agency charged with the investigation of employment discrimination complaints, 

or whose statements serve as the basis of a charge; or because such person testifies or 

participates in the investigation or prosecution of an alleged violation of these statutes. 

Defendant shall not retaliate in any manner against individuals identified as witnesses in 

this action or who assisted in the investigation giving rise to this action. Nor shall 

Defendant retaliate against any such persons identified as a witness or possible witnesses 

of discrimination in future investigations or proceedings.

B. GEO’s Office of Professional Responsibility 

23. For the duration of this Decree, Defendant shall ensure that all complaints 

of sexual harassment and/or retaliation at CACF will be investigated by GEO’s Office of 

Professional Responsibility (“OPR”), its designee within the Region, or the Human 

Resources Representative at the CACF. No individual who has been disciplined for 

sexual harassment and/or retaliation is eligible to investigate sexual harassment and/or 

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retaliation complaints. 

C. EEO Policy Review 

24. Within thirty (30) days of the entry of this Decree, the Defendant shall 

review its existing EEO policies to conform to the law and revise, if necessary. Such 

policy must be in conformity with the requirements provided in Paragraph 25 within 

ninety (90) days of the Court’s entry of this Consent Decree. 

25. The written EEO policies must include at a minimum: 

25.1. A strong and clear commitment to preventing unlawful gender 

discrimination and retaliation; 

25.2. A clear and complete definition of disparate treatment based on 

gender and retaliation; 

25.3. A clear and complete definition of sexual harassment based on 

gender to include vivid examples of the types of behavior, including 

but not limited to horseplay, banter, and sexual innuendos, which 

would not be tolerated under the existing or new EEO policy; 

25.4. An unequivocal statement that no sexually oriented materials or 

objects shall be brought onto or accessed from Defendant’s 

premises; 

25.5. A clear statement that employees are not to discuss sexual conduct 

and/or sexual jokes while at work; 

25.6. A statement that discrimination, of any type, based on gender or 

retaliation is prohibited and will not be tolerated; 

25.7. A clear and strong encouragement of persons who believe they have 

been discriminated or retaliated against to report such concerns; 

25.8. The identification of specific individuals and outside agencies such 

as the ACRD and EEOC, with telephone numbers, to whom 

employees can report their concerns about discrimination, 

harassment, or retaliation and the deadline for reporting to outside 

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agencies, including: 

25.8.1. The EEOC and ACRD; and 

25.8.2. OPR. 

25.9. Identification of a twenty-four (24) hour Hotline, which Defendant 

agrees to maintain, where employees will be able to call in to report 

what they reasonably believe to be discrimination. The hotline 

moderators will not disclose the name of any reporting employee to 

GEO management, unless necessary to fully and fairly investigate 

the allegations being made; 

25.10. A clear explanation of the steps an employee must take to report 

discrimination or retaliation, which must include the options of 

either an oral or written complaint; 

25.11. An assurance that Defendant will investigate allegations of any 

activity that might be construed as unlawful discrimination and that 

such investigation will be prompt, fair, and reasonable, and 

conducted by a neutral investigator specifically trained in receiving, 

processing, and investigating allegations of discrimination; 

25.12. A description of the role of the OPR under this Decree in 

responding to calls to the Hotline described in Paragraph 25.9, 

above; 

25.13. An assurance that appropriate corrective action (including but not 

limited to disciplining employees found to have violated these 

policies) will be taken by Defendant to make victims whole and to 

eradicate the unlawful conduct within its workforce; 

25.14. A description of the consequences, up to and including termination, 

that will be imposed upon violators of Defendant’s antidiscrimination policies; 

25.15. A promise of maximum feasible confidentiality for persons who 

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report unlawful discrimination, harassment, and/or retaliation, or 

who participate in an investigation into allegations of 

discrimination, harassment, and/or retaliation consistent with the 

NLRA; 

25.16. An assurance of non-retaliation for persons who report unlawful 

discrimination, harassment, and/or retaliation, and for witnesses 

who provide testimony or assistance in the investigation(s) of such 

unlawful discrimination, harassment, and/or retaliation; and 

25.17. An assurance that Defendant shall not retain documents related to 

the investigation in any complainant’s personnel files. These 

documents, instead, must be retained in a separate secure location. 

All disciplinary actions taken against employees for violation of 

Defendant's Anti-Discrimination Policy will be retained in the 

violator’s personnel file. 

26. Within thirty (30) days after completion of the policy review required 

under Paragraphs 24 and 25 above, the written EEO policies shall be posted in a 

prominent location frequented by employees at Defendant’s CACF facility in Arizona 

and distributed to each current employee by email or in hard copy. The written EEO 

policies shall be distributed to all new employees when hired. Defendant shall make the 

written EEO policies available in alternative formats as necessary for persons with 

cognitive and print disabilities that may prevent them from reading the policies. 

Alternative formats will include but not be limited to an audiotape format. 

D. Investigations 

27. For the duration of this Decree, complaints of sexual harassment and 

retaliation will be accepted in writing, orally, or anonymously, and all complaints will be 

taken seriously and investigated appropriately. Defendant shall put in writing all 

complaints of sexual harassment and/or retaliation that are made orally or anonymously 

to any of Defendant’s supervisors, managers, or Human Resource personnel. The 

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written summary of any sexual harassment and/or retaliation complaint shall be sent to 

OPR. 

28. All parties contacted in the course of an investigation will be advised that 

any retaliation or reprisal against an individual who is an alleged target of harassment or 

retaliation, including complainants and witnesses, will not be tolerated and will result in 

disciplinary action, up to and including termination. 

29. During the course of an investigation, Defendant will take adequate 

protective measures to protect the complainant and witnesses from sexual harassment, 

including placing employees who are under investigation for physical sexual harassment 

or other serious allegation on administrative leave. 

30. Only those who have an immediate need to know may be informed of the 

identity of the complainant and the specifics of the complaint. All other information 

regarding complaints will be maintained confidential to the maximum feasible extent 

consistent with the NLRA. 

30.1. When witnesses and/or complainants are called in for interviews 

pursuant to investigations of complaints of sexual harassment or 

retaliation, Defendant will ensure that no staff members are 

informed of the purpose of the interview. 

30.2. Such interviews will be conducted in private locations. 

31. During an investigation of a sexual harassment complaint of an employee 

or other individual, OPR, its designee (“OPR representative”), or the Human Resources 

Representative at the CACF will have the responsibility for expeditiously and 

appropriately investigating all complaints in compliance with Defendant’s policies and 

this Decree. 

31.1. Upon receiving a complaint, the Investigative Officers shall 

endeavor to immediately interview in person all affected individuals 

and potential witnesses to the alleged harassment discreetly and 

without the presence of other management officials. 

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31.2. Prior to beginning any interview conducted during an investigation 

of a complaint of sexual harassment and/or retaliation, the 

investigator shall: 

31.2.1. Inform the witness of the purpose of the questioning; 

31.2.2. If the witness is not the alleged harasser, assure the witness 

that no reprisal will take place based on his / her 

participation in the investigation; and 

31.2.3. If the witness is not the alleged harasser, ensure that no 

threat of disciplinary action for participation in the 

investigation has occurred. 

31.2.4. During an interview conducted during an investigation of a 

complaint of sexual harassment and/or retaliation, the 

investigator will conduct the interview in a manner that a 

reasonable person would not view as coercive. 

31.3. The investigator will conduct a thorough investigation of each and 

every allegation or complaint of sexual harassment and/or 

retaliation. At a minimum, investigations of complaints of sexual 

harassment shall include the following: 

31.3.1. Documentation of all oral and/or written complaints; 

31.3.2. Interviews of all potential victims and witnesses identified, 

including any and all individual(s) alleged to have 

participated in or condoned the unlawful conduct; 

31.3.3. Review of all documents which might shed light on the 

allegations of the complaint; 

31.3.4. Credibility assessment, where appropriate; 

31.3.5. Detailed contemporaneous notes of the investigation and 

conclusions, as well as all corrective and remedial measures 

(where discrimination is found to have occurred); and 

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31.3.6. Finding of whether a violation of the company’s EEO policy 

or anti-retaliation policy occurred. 

31.4. GEO’s Human Resources Department may recommend to CACF 

remedial measures, if appropriate, based upon the results of the 

investigation, and Defendant will promptly consider that 

recommendation in determining any disciplinary action. 

31.5. OPR will maintain a file on the original complaint(s) and any 

follow-up investigation. OPR will also forward one complete copy 

to the Human Resources Department and Warden at CACF, unless 

the Warden is the subject of the investigation in which case it will 

forward a copy to the Region.

32. Defendant shall inform the complainant and the alleged harassing official 

of the outcome of the investigation.

33. Defendant will take steps to scrutinize the employment decisions affecting 

the complainant and witnesses during and after the investigation to ensure that such 

decisions are not based on retaliatory motives.

E. Training 

34. At least annually, Defendant shall provide EEO training for all its 

employees. Under this provision, employees will be trained at a minimum in the 

following areas: (a) the Defendant’s policy and procedures for reporting alleged sex and 

gender discrimination; (b) understanding the kind of conduct which may constitute 

unlawful sex and gender discrimination or harassment; (c) the penalties of engaging in 

discriminatory behavior; and (d) Defendant’s non-retaliation policy and sex/gender 

harassment policies. Defendant shall record all live trainings under this Paragraph and, if 

requested to do so in writing, will send copies to the EEOC. The training will be 

conducted as follows:

34.1. Non-managerial Employees: Defendant will provide its nonmanagerial employees at CACF with training regarding gender 

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discrimination, including sexual harassment and retaliation. These 

trainings should last at least one (1) hour and may be live, videorecorded, or computer-based training sessions. 

34.2. Managerial and Supervisory Employees: Defendant will require 

all individuals who work in a managerial or supervisory capacity at 

CACF, including all sergeants, lieutenants, assistant wardens, and 

wardens who have hiring authority (as well as any employee who is 

temporarily acting in the capacity of any of these positions), to 

receive at least two (2) hours of live, video-recorded, or computerbased training annually regarding Title VII. One (1) of the two (2) 

hours must directly address gender-related discrimination, to 

include harassment and sexual harassment, and one (1) of the two 

(2) hours must be instruction in the proper methods of receiving, 

communicating, investigating (where applicable), and ameliorating 

discrimination. Defendant shall emphasize with managerial and 

supervisorial employees that due to their position of power, such 

employees must (a) be particularly vigilant not to discriminate, 

whether consciously or due to their reliance upon subconscious 

stereotypes; (b) be sensitive of how their actions or words might be 

perceived by subordinate employees; and (c) avoid the temptation 

to retaliate against an employee because a complaint is made, or 

might be made, against them. Additionally, Defendant will require 

employees who are newly hired or recently promoted into a 

managerial or supervisory position to complete the requisite one (1) 

hour of complaint-handling training within sixty (60) days of being 

hired or promoted. This training can be conducted in live, videorecorded, or computer-based training sessions.

34.3. Human Resource Employees: Defendant will require all 

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individuals at CACF who work in a human resource capacity who 

have not previously received this training within the last year to 

receive at least eight (8) hours of training regarding Title VII and 

other federal anti-discrimination laws. Six (6) of the eight (8) hours 

must directly address gender-related discrimination, to include 

harassment and sexual harassment, and at least two (2) hours of the 

eight (8) hours must be instruction in the proper methods of 

receiving, communicating, investigating (where applicable), and 

ameliorating discrimination, including the proper procedures for 

documenting and preserving evidence of discrimination, archiving 

the corporation’s investigation of complaints, as well as ensuring 

uniform and appropriate disciplinary consequences where 

discrimination is found. Defendant will require employees who are 

newly hired or promoted into a human resource position to 

complete this training within sixty (60) days of being hired or 

promoted into a human resource position. The training under this 

Paragraph must be provided by an appropriate third party approved 

by the EEOC. Human resources employees who have received this 

training within the last year will receive annual training that mirrors 

the Managerial and Supervisory Training set forth in Paragraph 

34.2, which could be online or video-recorded training and need not 

be live training. 

35. Training on Investigative Techniques Regarding Sexual Harassment 

and/or Retaliation: All employees with responsibility for responding to or investigating 

complaints of discrimination at CACF shall be provided two (2) additional hours of 

annual training instructing on accepted professional standards for receiving and 

investigating complaints of sexual harassment and/or retaliation at CACF, including 

such matters as witness interview techniques, conducting discreet and non-coercive 

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interviews, other evidence-gathering techniques, maintaining investigative notes and 

records, legal analysis of the evidence, and the procedures described under this Decree. 

The training under this Paragraph must be provided by an appropriate third party 

approved by the EEOC. Defendant agrees that the first such training session for each 

employee group identified in Paragraph 34 above, will take place within one hundred 

twenty (120) days after the Defendant’s EEO Policy is in conformity with the 

requirements provided in this Decree. Defendant agrees that all of its personnel shall 

both register and attend the training sessions. Defendant further agrees that it will 

monitor training attendance to ensure that any make-up sessions. 

F. Notice Posting 

36. Within five (5) business days after the Court’s entry of this Decree, 

Defendant shall post at its CACF facility, in a conspicuous place frequented by 

employees, the Notice attached as Exhibit C to this Decree. The Notice shall be the same 

type, style, and size as set forth in Exhibit C. The Notice shall remain posted for the 

duration of this Decree. If the Notice becomes defaced or illegible, Defendant will 

replace it with a clean copy. Defendant shall certify to the Commission, in writing, and 

include photographs of each notice as posted in the conspicuous location(s) in 

Defendant’s CACF facility, within twenty (20) days of entry of this Decree that the 

Notice has been properly posted and shall provide recertification in each of the semiannual reports required under the Reporting provisions of this Consent Decree. 

G. Individuals Ineligible for Hire, Rehire, Retention, or Transfer 

37. Defendant agrees that it shall never rehire Luis Beltran, Michael Connor, 

Rueben Molina, Jeffrey Perry, Matthew Rice, Matthew Scott, Jesse Sanchez, Gregory 

Souza, Robert Velasquez, or Jarrett Yoyokie at any time at any of Defendant's facilities 

in the United States. To assure that these individuals are never rehired by Defendant, 

Defendant will place a document on the top of the employee's personnel file that reads in 

bold, “Not Eligible for Rehire at any facility in the United States.” If Defendant 

maintains any computerized personnel file for the individual, such computerized file 

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must also be annotated to reflect ineligible for rehire. 

H. EEO Compliance as a Component of Management Evaluation 

38. Defendant shall, within sixty (60) days of the entry of this Consent Decree, 

and at least continuously for the duration of this Decree, develop and implement a 

management evaluation system at CACF which includes EEO compliance, compliance 

with policies and laws prohibiting retaliation, and compliance with this Decree. 

VIII. REPORTING PROVISIONS

39. Defendant shall report in writing and in affidavit form on a quarterly basis 

for each six (6) month period following the Court’s entry of this Decree to the following 

entities: 

39.1. Regional Attorney, Equal Employment Opportunity Commission, 

Phoenix District Office, 3300 North Central Avenue, Phoenix, 

Arizona 85012. 

This report shall be due thirty (30) days following the respective six-month 

period, except the final report, which shall be submitted to the Commission two (2) 

weeks prior to the date on which the Consent Decree is to expire. 

40. Reporting Requirements: Each report shall provide the following information: 

40.1. Reports of Discrimination at CACF

40.1.1. For purposes of this Paragraph, the term “report of 

discrimination” will include any written or verbal complaint 

which alleges sexual harassment and/or retaliation. For 

example, if a female employee reports that a male employee 

has made an offensive sexual comment, this should be 

recognized as a complaint of sexual harassment and/or 

gender discrimination even though the employee does not 

use the terms “harassment” or “discrimination,” and 

regardless of whether the complaint is made orally or in 

writing. 

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40.1.2. The report will include: 

a. The name of each person making a complaint of sexual 

harassment and/or retaliation to Defendant or to any 

federal, state, or local government agency; 

b. The name, address, email address, and telephone number 

of each person making a complaint shall be provided to 

the EEOC upon request; and 

c. A brief summary of each complaint, including the date of 

the complaint, the name of the individual(s) who 

allegedly engaged in the discriminatory conduct, the 

Defendant’s investigation and response to the complaint, 

the name of the person who investigated or responded to 

the complaint, and what, if any resolution was reached. 

40.2. Training 

40.2.1. For each training program required under Paragraph 34 and 

conducted during the reporting period, Defendant shall 

submit a registry of attendance and a certificate of 

completion. 

40.2.2. For each training program conducted by Defendant’s staff 

under this Decree, Defendant will provide the following 

information: (a) a detailed agenda; (b) copies of all training 

material provided to or utilized by the trainers; (c) the name 

of each trainer; and (d) a summary of trainer’s qualifications 

and/or the trainings the staff member attended. 

40.2.3. For each training program conducted, Defendant will 

provide a copy of the program agenda and a videotape of the 

trainings. 

40.3. Posting of Notice at CACF: Defendant shall recertify to the 

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Commission that the Notices required to be posted under this 

Decree have remained posted during the reporting period, or, if 

removed, were promptly replaced. 

40.4. Policy Review: Defendant shall report on the status of the EEO 

policy review process required under this Decree. 

40.5. Ineligible for Rehire: Defendant shall report that it has complied 

with the Decree and designated Luis Beltran, Michael Connor, 

Rueben Molina, Jeffrey Perry, Matthew Rice, Matthew Scott, Jesse 

Sanchez, Gregory Souza, Robert Velasquez, and Jarrett Yoyokie as 

ineligible for rehire under this Decree. 

40.6. Component of Management Evaluation: Defendant shall report 

its compliance with the management evaluation system required 

under this Decree. 

IX. RETENTION OF JURISDICTION AND ENFORCEMENT OF DECREE

41. This Court shall retain jurisdiction of this cause for purposes of 

compliance with this Decree and entry of such further orders or modifications as may be 

necessary or appropriate to effectuate equal employment opportunities for employees. 

42. There is no private right of action to enforce Defendant’s obligations under 

the Decree and only the Commission or its successors or assigns, may enforce 

compliance herewith. 

43. The Commission may petition this Court for compliance with this Decree 

at any time during which this Court maintains jurisdiction over this action. Should the 

Court determine that Defendant has not complied with this Decree, appropriate relief, 

including extension of this Decree for such period as may be necessary to remedy its 

non-compliance, may be ordered. 

44. Absent extension, this Decree shall expire by its own terms at the end of 

the second year from the date of the Court’s entry of this Consent Decree without further 

action by the Parties. 

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X. EEOC AUTHORITY

45. With respect to matters or charges outside the scope of this Decree, this 

Decree shall in no way limit the powers of the Commission to seek to eliminate 

employment practices or acts made unlawful by any of the statutes over which the 

EEOC has enforcement authority, and do not arise out of the claims asserted in this 

lawsuit. 

XI. COSTS AND ATTORNEY'S FEES

46. Each party shall be responsible for and shall pay its own costs and 

attorney’s fees. 

XIII. SIGNATURES 

47. The parties agree to the entry of this Decree subject to final approval by 

the Court. 

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EXHIBIT A 

[The GEO Group, Inc. Letterhead] 

To Whom It May Concern: 

 This letter will serve to confirm Ms. Roberta Jones’s employment with The GEO 

Group, Inc., from 2007 to 2013. During this time, Ms. Jones held the positions of food 

service worker and corrections officer. Ms. Jones is eligible for rehire. 

 

 Sincerely, 

 __________________________ 

 Warden Bennie Rollins 

Central Arizona Corrections Facility, 

The GEO Group 

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EXHIBIT B 

[Letterhead] 

Dear Ms. Jones: 

 While this letter is in no way an admission of any legal violation under Title VII 

or state law, we regret, on behalf of The GEO Group, Inc., and our management staff, 

any offensive or objectionable language or conduct you believe you experienced during 

your employment with us. Please accept our commitment that the Company will 

continue to take whatever steps are necessary to ensure that current and future 

employees work in an environment free of gender and sexual harassment. 

 Sincerely, 

___________________________ 

 Warden Bennie Rollins 

 Central Arizona Corrections Facility, 

The GEO Group 

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EXHIBIT C 

NOTICE 

The following notice is being posted pursuant to the terms of a Consent Decree 

reached between the Parties in EEOC v. The GEO Group Inc. filed in the United States 

District Court for the District of Arizona, Civil Action No. CV15-1909-PHX-SPL. 

 Management of the GEO Group Inc. will provide equal employment opportunity 

in all of its operations and in all areas of employment practices. The GEO Group Inc. 

will not discriminate against any employee or applicant for employment on the grounds 

of race, color, religion, sex, pregnancy, national origin, age or disability. This policy 

extends to insurance benefits and all other terms, conditions and privileges of 

employment. 

 Pursuant to Title VII, it is unlawful for an employer to discriminate based upon 

the gender of an applicant or employee. Further, it is unlawful for any employer to 

retaliate against an employee because he or she has requested reasonable 

accommodation for disability or religion, opposed discriminatory employment practices, 

or because he or she has filed a charge of discrimination with any municipal, state or 

federal equal employment opportunity agency, or because he or she has participated in 

an investigation of a charge of discrimination. 

 Any employee who believes that he/she has suffered discrimination on the basis 

of age, race, color, religion, sex, pregnancy, national origin, or disability, has the right to 

contact the EEOC directly at 1-800-669-4000. Employees in Arizona may also call the 

Arizona Civil Rights Division (“ACRD”) at 602-542-5263. In compliance with federal 

and Arizona state law, no official at the GEO Group Inc. will retaliate against an 

employee who makes an internal complaint of discrimination or who contacts the EEOC 

or the ACRD. 

 It is against the law for any action to be taken against you by any officer, 

supervisory or management official of The GEO Group, Inc., for : (1) opposing sexual 

or gender harassment or other discriminatory practices made unlawful by federal or state 

law; (2) filing a charge or assisting or participating in the filing of a charge of 

discrimination; or (3) assisting or participating in an investigation or proceeding brought 

under Title VII or the Arizona Civil Rights Act, including internal investigations into 

sexual or gender harassment and/or retaliation. Should any such retaliatory actions be 

taken against you, you should immediately contact the EEOC or ACRD at the address 

and/or telephone numbers listed below. 

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Equal Employment Opportunity 

Commission 

3300 North Central Avenue

Suite 690 

Phoenix, Arizona 85012 

Telephone: (602) 640-5000 

TTY: (602) 640-5072 

Website (national): www.eeoc.gov

Arizona Civil Rights Division 

Arizona Attorney General’s Office 

1275 West Washington Street 

Phoenix, Arizona 85007 

Telephone: (602) 542-5263 

TDD: (602) 542-5002 

 This Notice shall remain posted for the term of two (2) years. 

The GEO Group, Inc. 

By:__________________________________ _________________________ 

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