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The Dream Defenders
6161 NW 9th Avenue Every man must decide whether he will walk in the light of creative altruism or
Miami, FL 33127 the darkness of destructive selfishness.
info@dreamdefenders.org - Dr. Martin Luther King, Jr.

August 6, 2018

The GEO Group, Inc.


℅ Attorney Carolyn P. Short
Holland & Knight, LLP
carolyn.short@hklaw.com
Cira Centre, 2929 Arch. St., St. 800
Philadelphia, PA 19104

RE: Cease and Desist Demand Letter - August 3, 2018

The GEO Group, Inc.:

We received your cease and desist letter on Friday. On behalf of the members of the Dream Defenders,
we vehemently deny your claims; which are laughable, at best. Unsurprisingly, after checking with our
lawyers, it turns out your accusations of “defamation” fall woefully short by every measure.

We will not back down in the face of your baseless threats and attempts at intimidation. You will not
silence us. You will not quell our fire. You will not win in this fight of right and wrong because, well, you’re
wrong.

Until you cease and desist from profiting off of the incarceration of our communities, and the politicians
you bankroll are no longer in power, we will continue speaking the truth about your practices, as loudly
as we like.

GEO Group has maintained and generated profits from the caging of children, immigrants and
members of our communities for longer than most of us have been alive. Last year, GEO reportedly
made 2.26 billion dollars in revenue. Your business niche is locking people up. No amount of legal
rhetoric will make that a lie. The opinions we’ve expressed about your corporation are supported by the
lived experiences of people locked behind your bars, news coverage, academic research, local and
federal reporting systems and your own website. Hell, just ask the dozens of plaintiffs behind all the
lawsuits against you from all across the country. It’s your word and the word of your fancy lawyers vs. the
rest of us? Nah.

Since you called us liars, and threatened to sue us, this letter serves as our response to your
allegations.

CAGING CHILDREN
You claim that we made “blatantly false allegations that GEO ‘cages’ children.”
Merriam-Webster defines the verb “cage” as to confine or keep in or as if in a cage. The top two examples
of the use of the word are news articles describing immigration detention conditions of children and
families.

You hold children behind bars, fences, and/or in locked facilities. GEO’s own website details facilities
across the country used to detain children for federal and state governments. Your own promotional
materials refer to “standard GTI security equipment such as steel cages” in your transportation fleet. Just
this week, conditions in your Karnes County, TX facility have forced hundreds of children and fathers into
a strike to protest what they describe as “being treated like animals.” Furthermore, GEO maintains
specially outfitted busses for field trips, brief respites from confinement, for children as young as four
years old.

It isn’t only immigrant children and their families who are at risk. You’ve profited off of the incarceration
of Black, Latino, and poor white youth in the criminal justice system for years. A federal court found that
your operation of a youth prison in Mississippi “allowed a cesspool of unconstitutional and inhuman acts
and conditions to germinate” and placed youth at “substantial ongoing risk.”

We guess you would prefer us to call your operations “academies,” “treatment centers,” “leadership
development programs,” “residential facilities”, “family detention” centers or one of the many other
euphemisms you list on your website? We’ll stick with the truth. You are caging children.

SEPARATION OF FAMILIES
You claim that we made “blatantly false allegations that GEO ‘separates’ families.”
GEO facilitates, maintains and profits off the separation of families under mass incarceration and anti-
immigrant policies. News reports have stated that “no single company is making more money off the
federal deportation machine than GEO.” And GEO’s CEO has highlighted the business opportunities
that come with the Trump administration’s immigration policies in calls with analysts. GEO not only
maintains the physical walls separating inmates and detained immigrants from their families, but has
even profited off of the few moments of connection detainees have over the phone.

JAILING BLACK, LATINO AND POOR WHITE PEOPLE


You claim that we made “blatantly false allegations that GEO ‘puts Black, Latino and poor White
People into jail.’”
The over-policing and incarceration of Black people in the United States is well documented. Black,
Latino and poor white people fill the court systems you feed off of. GEO then jails these people in your
various prison and detention centers. It is the core of the private prison model. We assume you have
many hours of training for your employees on exactly how to handcuff, transport, and turn the key on
the thousands of cells you maintain. Just because GEO is not directly responsible for sentencing or
deciding which families to incarcerate, detain or deport does not absolve the company of participating
in a racist system of mass incarceration that has its roots in slavery and Jim Crow laws. GEO’s cries that
befehl ist befehl (an order is an order) will not do.

IMPROPER INFLUENCE OVER THE UNITED STATES POLITICAL SYSTEM


You claim that we made “blatantly false allegations that GEO asserts improper influence over the
United States political system.”
In Florida alone, hundreds of candidates and elected policymakers have received donations from GEO
Group and its lobbying affiliates from as early as 2004. Please note that “lawfully” influencing our
politicians with donations is not the same as exercising it morally or properly.

Recent news reports have cited contributions of “more than $8.7 million to politicians during the last two
decades” and reported on what may be an “illegal donation [of $125,000] to a super PAC backing
Florida Republican Gov. Rick Scott’s campaign for Senate.” An election integrity organization recently
sued to make the federal government act on allegations your subsidiary was “violating FECA’s
prohibition on contributions by government contractors by illegally contributing $225,000 to a Trump
‘super PAC.’”

The Washington Post reported that after “an intense effort by GEO Group to align itself with the
president and his administration,” you moved your annual meeting to a “golf resort owned by President
Trump.” That doesn’t seem proper to us.

Also, we’d like our list of individuals to whom GEO and your lobbying affiliates makes political
contributions to be accurate. Please send us an updated list. We’d love to know who we’ve missed.

---

So now that we’ve laid it all out, is it the truth that threatens you? Is it the video of Yaya, an 8 year old,
plainly exposing your business model and her vision for a future free of private prisons? Or is it the
dozens of lawsuits filed against you from people inside your facilities across the country? Or maybe it's
the people who are rising up to protest against big corporations like you and the NRA, who are making
millions of dollars in profit off of human suffering?

You had the audacity to allege that the Dream Defenders, a group of young people of color who are
advocating for our basic human rights, are exhibiting “threatening and violent behavior toward GEO.”
We are advocating the end to your harmful and violent carceral behavior, which countless news reports,
lawsuits, and government investigations have already established.

Threatening us with lawsuits won’t stop us from exposing the truth about what the GEO Group and other
Dream Killers are doing to our communities. Groups around the country are gearing up to stand against
you this week. You’ll need more than flimsy legal maneuvers to stop us.

Sincerely,
The Dream Defenders

P.S. We’re sure paying a big law firm to send us that threatening letter cost you $$$. Why not take
whatever money you’re scrambling to put towards a reply to this email and donate it to the National Bail
Out and Immigration Defense funds instead?

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