On January 16, 1973 a
Party Statement
was filed
involving a dispute between
Chris Gatling,
and
Geo Group Inc,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 122525934 E-Filed 03/04/2021 03:50:07 PM
8511/jlb IN THE CIRCUIT COURT OF THE 15%
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No. 50 2020 CA 012582 XXXX MB AF
CHRIS GATLING
Plaintiff,
vs.
THE GEO GROUP, INC.,
Defendant.
#5
AFFIDAVIT OF
TRAVIS HALLMAN
In support of Defendant’s Motion to Dismiss Based
Upon Forum Non Conveniens set for hearing
on March 10, 2021
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/04/2021 03:50:07 PM ***8511 /jlb IN THE CIRCUIT COURT OF THE 15
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No. 50 2020 CA 012582 XXXX MB AF
CHRIS GATLING
Plaintiff,
vs.
THE GEO GROUP, INC.,
Defendant.
/
AFFIDAVIT OF TRAVIS HALLMAN
STATE OF ARIZONA )
COUNTY OF dane 2 )
BEFORE ME, the undersigned authority personally authorized to administer oaths
and take acknowledgments, personally appeared TRAVIS HALLMAN who, after being
duly sworn, deposes and says as follows:
1. I am over the age of eighteen (18) years of age, of sound mind, and
otherwise competent to make this affidavit.
2. I have personal knowledge of the facts attested to herein.
3. Iam employed by The GEO Group, Inc. (“GEO”) as the Fire and Safety
Manager for Kingman Prison, which is located at 4626 W. English Drive, Golden Valley,
Arizona 86413.
4. On April 3, 2019, ] arrived on scene to investigate the subject incident
-1-of this lawsuit that involved the Plaintiff, Chris Gatling.
5. Based upon my investigation, I learned that Mr. Gatling, who is part of the
maintenance team fell off the back of a flat-bed truck that was being operated by Robert
Powers.
6. At the time of the incident, three other inmates assigned to the maintenance
team were with Mr. Gatling on the flat-bed truck. The three inmates included Adam
Fisher, James McNulty, and Patrick Carillo.
7. 1 am also aware of the applicable safety protocols when transporting
inmates on the maintenance team.
8. Lastly, if called as a witness in the above referenced lawsuit, it would be
substantially inconvenient for me to travel outside of Arizona as my residence and
employment are here. It would be most convenient for me to provide such testimony
before an Arizona state court.
(THIS SPACE IS INTENTIONALLY LEFT BLANK)FURTHER AFFIANT SAYETH NAUGHT.
/
TRAVIS HALLMAN
STATE OF ARIZONA )
COUNTY OF dul )
BEFORE ME, the undersigned authority, appeared TRAVIS HALLMAN, who is
Ww personally known or [ ] has produced to me deposes and says
that he has read the foregoing and it is true and correct to the best of his knowledge.
SWORN and SUBSCRIBED to before me this dud, day of March 2021.
‘Mohave County
‘Commission # 556621 am
S52” My Comm. Eapires Dec 5, 2022 # My Commission ExpireQQyegupey S oe
a SHANNON LEIGH HILTON ine
S Suey Public asizone Notary Public - State of Arizona
-3-
Document Filed Date
January 15, 2033
Case Filing Date
January 16, 1973
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Filing # 122525934 E-Filed 03/04/2021 03:50:07 PM 8511/jlb IN THE CIRCUIT COURT OF THE 15% JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2020 CA 012582 XXXX MB AF CHRIS GATLING Plaintiff, vs. THE GEO GROUP, INC., Defendant. #5 AFFIDAVIT OF TRAVIS HALLMAN In support of Defendant’s Motion to Dismiss Based Upon Forum Non Conveniens set for hearing on March 10, 2021 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/04/2021 03:50:07 PM ***8511 /jlb IN THE CIRCUIT COURT OF THE 15 JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2020 CA 012582 XXXX MB AF CHRIS GATLING Plaintiff, vs. THE GEO GROUP, INC., Defendant. / AFFIDAVIT OF TRAVIS HALLMAN STATE OF ARIZONA ) COUNTY OF dane 2 ) BEFORE ME, the undersigned authority personally authorized to administer oaths and take acknowledgments, personally appeared TRAVIS HALLMAN who, after being duly sworn, deposes and says as follows: 1. I am over the age of eighteen (18) years of age, of sound mind, and otherwise competent to make this affidavit. 2. I have personal knowledge of the facts attested to herein. 3. Iam employed by The GEO Group, Inc. (“GEO”) as the Fire and Safety Manager for Kingman Prison, which is located at 4626 W. English Drive, Golden Valley, Arizona 86413. 4. On April 3, 2019, ] arrived on scene to investigate the subject incident -1-of this lawsuit that involved the Plaintiff, Chris Gatling. 5. Based upon my investigation, I learned that Mr. Gatling, who is part of the maintenance team fell off the back of a flat-bed truck that was being operated by Robert Powers. 6. At the time of the incident, three other inmates assigned to the maintenance team were with Mr. Gatling on the flat-bed truck. The three inmates included Adam Fisher, James McNulty, and Patrick Carillo. 7. 1 am also aware of the applicable safety protocols when transporting inmates on the maintenance team. 8. Lastly, if called as a witness in the above referenced lawsuit, it would be substantially inconvenient for me to travel outside of Arizona as my residence and employment are here. It would be most convenient for me to provide such testimony before an Arizona state court. (THIS SPACE IS INTENTIONALLY LEFT BLANK)FURTHER AFFIANT SAYETH NAUGHT. / TRAVIS HALLMAN STATE OF ARIZONA ) COUNTY OF dul ) BEFORE ME, the undersigned authority, appeared TRAVIS HALLMAN, who is Ww personally known or [ ] has produced to me deposes and says that he has read the foregoing and it is true and correct to the best of his knowledge. SWORN and SUBSCRIBED to before me this dud, day of March 2021. ‘Mohave County ‘Commission # 556621 am S52” My Comm. Eapires Dec 5, 2022 # My Commission ExpireQQyegupey S oe a SHANNON LEIGH HILTON ine S Suey Public asizone Notary Public - State of Arizona -3-