Response and Supplemental Response Letter

0001193125-13-467221.txt : 20140225 0001193125-13-467221.hdr.sgml : 20140225 20131209202507 ACCESSION NUMBER: 0001193125-13-467221 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20131209 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CORRECTIONAL SERVICES CORPORATION, LLC CENTRAL INDEX KEY: 0000914670 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-FACILITIES SUPPORT MANAGEMENT SERVICES [8744] IRS NUMBER: 113182580 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1819 MAIN STREET SUITE 1000 CITY: SARASOTA STATE: FL ZIP: 34236 BUSINESS PHONE: 9419539199 MAIL ADDRESS: STREET 1: 1819 MAIN STREET SUITE 1000 STREET 2: CORRECTIONAL SERVICES CORP CITY: SARASOTA STATE: FL ZIP: 34236 FORMER COMPANY: FORMER CONFORMED NAME: CORRECTIONAL SERVICES CORP DATE OF NAME CHANGE: 19960814 FORMER COMPANY: FORMER CONFORMED NAME: ESMOR CORRECTIONAL SERVICES INC DATE OF NAME CHANGE: 19931110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CORRECTIONAL SYSTEMS LLC CENTRAL INDEX KEY: 0001010032 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MANAGEMENT CONSULTING SERVICES [8742] IRS NUMBER: 330607766 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6910-A MIRAMAR ROAD STREET 2: SUITE 200 CITY: SAN DIEGO STATE: CA ZIP: 92121 BUSINESS PHONE: 858-566-9816 MAIL ADDRESS: STREET 1: 6910-A MIRAMAR ROAD STREET 2: SUITE 200 CITY: SAN DIEGO STATE: CA ZIP: 92121 FORMER COMPANY: FORMER CONFORMED NAME: CORRECTIONAL SYSTEMS INC DATE OF NAME CHANGE: 19991118 FORMER COMPANY: FORMER CONFORMED NAME: CORRECTIONS SERVICES INC/TX DATE OF NAME CHANGE: 19960426 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Corrections of California, Inc. CENTRAL INDEX KEY: 0001298210 IRS NUMBER: 942411045 STATE OF INCORPORATION: CA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Interventions, Inc. CENTRAL INDEX KEY: 0001298211 IRS NUMBER: 742918981 STATE OF INCORPORATION: IL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Corrections of Rhode Island, Inc. CENTRAL INDEX KEY: 0001298217 IRS NUMBER: 742650654 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO RE Holdings LLC CENTRAL INDEX KEY: 0001517745 IRS NUMBER: 650682878 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Correctional Properties Prison Finance LLC CENTRAL INDEX KEY: 0001517749 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Transport, Inc. CENTRAL INDEX KEY: 0001517753 IRS NUMBER: 562677868 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Companies of Texas OS, LLC CENTRAL INDEX KEY: 0001578135 IRS NUMBER: 461664300 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Corrections Holdings, Inc. CENTRAL INDEX KEY: 0001578145 IRS NUMBER: 461972528 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Operations, LLC CENTRAL INDEX KEY: 0001578146 IRS NUMBER: 461288456 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Group REIT, Inc. CENTRAL INDEX KEY: 0001591188 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 000000000 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE, SUITE 700 STREET 2: 621 NORTHWEST 53RD STREET CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE, SUITE 700 STREET 2: 621 NORTHWEST 53RD STREET CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO GROUP INC CENTRAL INDEX KEY: 0000923796 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 650043078 STATE OF INCORPORATION: FL FISCAL YEAR END: 0101 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NW 53RD STREET STREET 2: SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: 621 NW 53RD STREET STREET 2: SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FORMER COMPANY: FORMER CONFORMED NAME: WACKENHUT CORRECTIONS CORP DATE OF NAME CHANGE: 19940525 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Corrections of Alaska, Inc. CENTRAL INDEX KEY: 0001298209 IRS NUMBER: 760578707 STATE OF INCORPORATION: AK FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Corrections of Texas, Inc. CENTRAL INDEX KEY: 0001298212 IRS NUMBER: 742650651 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WBP Leasing LLC CENTRAL INDEX KEY: 0001426035 IRS NUMBER: 261849095 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH STREET 2: SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: (713) 623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH STREET 2: SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Acquisition II, Inc. CENTRAL INDEX KEY: 0001517752 IRS NUMBER: 010882442 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BII Holding I Corp CENTRAL INDEX KEY: 0001517755 IRS NUMBER: 263334669 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Municipal Corrections Finance, LP CENTRAL INDEX KEY: 0001578148 IRS NUMBER: 721509519 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: B.I. Inc CENTRAL INDEX KEY: 0001517758 IRS NUMBER: 840769926 STATE OF INCORPORATION: CO FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CPT Ltd Partner, LLC CENTRAL INDEX KEY: 0001517747 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Abraxas Group, Inc. CENTRAL INDEX KEY: 0001298192 IRS NUMBER: 760545741 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Corrections Management, LLC CENTRAL INDEX KEY: 0001298208 IRS NUMBER: 742650655 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 713-623-0790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FORMER COMPANY: FORMER CONFORMED NAME: Cornell Corrections Management, Inc. DATE OF NAME CHANGE: 20040723 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BII Holding Corp CENTRAL INDEX KEY: 0001517754 IRS NUMBER: 263064495 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CPT Operating Partnership L.P. CENTRAL INDEX KEY: 0001517748 IRS NUMBER: 650873924 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Interventions OS, LLC CENTRAL INDEX KEY: 0001578158 IRS NUMBER: 461679031 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CORNELL COMPANIES LLC CENTRAL INDEX KEY: 0001016152 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-FACILITIES SUPPORT MANAGEMENT SERVICES [8744] IRS NUMBER: 760433642 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH STREET 2: STE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 7136230790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH STREET 2: STE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FORMER COMPANY: FORMER CONFORMED NAME: CORNELL COMPANIES INC DATE OF NAME CHANGE: 20000623 FORMER COMPANY: FORMER CONFORMED NAME: CORNELL CORRECTIONS INC DATE OF NAME CHANGE: 19960604 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Public Properties Development & Leasing LLC CENTRAL INDEX KEY: 0001517750 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Behavioral Acquisition Corp. CENTRAL INDEX KEY: 0001517757 IRS NUMBER: 223746193 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CCG I LLC CENTRAL INDEX KEY: 0001298188 IRS NUMBER: 760544498 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 7136230790 MAIL ADDRESS: STREET 1: 1700 WEST LOOP SOUTH, SUITE 1500 CITY: HOUSTON STATE: TX ZIP: 77027 FORMER COMPANY: FORMER CONFORMED NAME: CCG I CORP DATE OF NAME CHANGE: 20040723 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Re-entry Services, LLC CENTRAL INDEX KEY: 0001578157 IRS NUMBER: 461260559 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Holdings I, Inc. CENTRAL INDEX KEY: 0001517751 IRS NUMBER: 562635779 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MCF GP, LLC CENTRAL INDEX KEY: 0001578184 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Abraxas Group OS, LLC CENTRAL INDEX KEY: 0001578137 IRS NUMBER: 461270920 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO Corrections & Detention, LLC CENTRAL INDEX KEY: 0001578167 IRS NUMBER: 461258100 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEO MCF LP, LLC CENTRAL INDEX KEY: 0001578176 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cornell Companies of California OS, LLC CENTRAL INDEX KEY: 0001578136 IRS NUMBER: 461658344 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 561-893-0101 MAIL ADDRESS: STREET 1: ONE PARK PLACE STREET 2: 621 NW 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Behavioral Holding Corp. CENTRAL INDEX KEY: 0001517756 IRS NUMBER: 204244005 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: (561) 893-0101 MAIL ADDRESS: STREET 1: 621 NORTHWEST 53RD STREET, SUITE 700 CITY: BOCA RATON STATE: FL ZIP: 33487 CORRESP 1 filename1.htm Response and Supplemental Response Letter

December 9, 2013

VIA EDGAR

Mr. Duc Dang

Special Counsel

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

RE:

The GEO Group, Inc.

Registration Statement on Form S-4

Filed November 7, 2013

File No. 333-192170

Dear Mr. Dang:

On behalf of The GEO Group, Inc. (the “Company” or “GEO”), we hereby respond to the Staff’s comment letter, dated November 21, 2013, regarding the above referenced Form S-4 filed on November 7, 2013 (the “Form S-4”). Please note that we are simultaneously filing Amendment No. 1 to the Form S-4 (“Amendment No. 1”). We are providing Ms. Sandra B. Hunter with a courtesy copy of Amendment No. 1 marked to show changes from the Form S-4. Please note that, for the Staff’s convenience, we have recited the Staff’s comment in boldface type and provided our response to the comment immediately thereafter.

General

We note your disclosure that you are registering 5 ⁷⁄₈% Senior Notes due in 2022 in reliance on our position enunciated in no action letters issued to third parties, specifically Exxon Capital Holdings Corp., SEC No-Action Letter (April 13, 1988), Morgan Stanley & Co. Inc., SEC –No-Action Letter (June 5, 1991) and Sherman & Sterling, SEC No-Action Letter (July 2, 1993). Accordingly, with the next amendment, please provide us with a supplemental letter stating that you are registering the exchange offer in reliance on our position contained in these letters and include the representations contained in the Morgan Stanley and Sherman & Sterling no-action letters.

Response:

Contemporaneously with the submission of this response letter and the filing of Amendment No. 1, GEO is filing a supplemental letter stating that GEO is registering the exchange offer in reliance on the Commission’s position enunciated in the above mentioned no-action letters. The supplemental letter includes the representations contained in the Morgan Stanley and Shearman & Sterling no-action letters.

Mr. Duc Dang, Special Counsel

December 9, 2013

Page 2

In connection with responding to the Staff’s comments, GEO has acknowledged in Exhibit A to this letter the following:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve GEO from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

GEO may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We believe the response provided above fully addresses the Staff’s comment. If you have any questions, please call the undersigned at 305-982-5519.

Sincerely,

AKERMAN LLP

/s/ Esther L. Moreno

Esther L. Moreno

For the Firm

cc:	Securities and Exchange Commission

Sandra B. Hunter, Staff Attorney

The GEO Group, Inc.

John J. Bulfin, Esq., Senior Vice President and General Counsel

Brian R. Evans, Senior Vice President and Chief Financial Officer

Akerman LLP

Jose Gordo, Esq.

Stephen K. Roddenberry, Esq.

EXHIBIT A

THE GEO GROUP, INC.

One Park Place, Suite 700

621 NW 53^rd Street

Boca Raton, FL 33487

December 9, 2013

In connection with its response to the United States Securities and Exchange Commission’s comment letter, dated November 21, 2013, The GEO Group, Inc. (“GEO”) acknowledges the following:

•

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve GEO from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

GEO may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.


The GEO Group, Inc.

By:		/s/ Brian R. Evans
		Brian R. Evans Senior Vice President and Chief Financial Officer

[GEO Letterhead]

December 9, 2013

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:

The GEO Group, Inc.

Registration Statement on Form S-4

Filed November 7, 2013

File No. 333-192170

Ladies and Gentlemen:

The GEO Group, Inc. (“GEO”) has filed with the U.S. Securities and Exchange Commission (the “Commission”) on November 7, 2013 the above-referenced registration statement on Form S-4 (File No. 333-192170) (the “Registration Statement”), as amended by Amendment No. 1 to the Registration Statement (“Amendment No. 1”) being filed simultaneously herewith, relating to the contemplated offer to exchange (the “Exchange Offer”) up to $250,000,000 aggregate principal amount of GEO’s 5 ⁷⁄₈% senior notes due 2022 (the “Exchange Notes”) for a like amount of GEO’s privately placed 5 ⁷⁄₈% senior notes due 2022 (the “Original Notes”). The Original Notes are, and the Exchange Notes will be guaranteed, jointly and severally, on a senior unsecured basis by GEO RE Holdings LLC, Correctional Services Corporation, LLC, CPT Limited Partner, LLC, CPT Operating Partnership L.P., Correctional Properties Prison Finance LLC, Public Properties Development and Leasing LLC, GEO Holdings I, Inc., GEO Acquisition II, Inc., GEO Transport, Inc., Cornell Companies, LLC, Cornell Corrections Management, LLC, CCG I, LLC, Cornell Corrections of Alaska, Inc., Cornell Corrections of California, Inc., Cornell Corrections of Texas, Inc., Cornell Corrections of Rhode Island, Inc., Cornell Interventions, Inc., Correctional Systems, LLC, Cornell Abraxas Group, Inc., WBP Leasing, LLC, BII Holding Corporation, BII Holding I Corporation, Behavioral Holding Corp., Behavioral Acquisition Corp., B.I. Incorporated, MCF GP, LLC, GEO MCF LP, LLC, Municipal Corrections Finance, LP, GEO Operations, LLC, GEO Corrections Holdings, Inc., GEO Corrections and Detention, LLC, GEO Re-entry Services, LLC, Cornell Abraxas Group OS, LLC, Cornell Companies of California OS, LLC, Cornell Companies of Texas OS, LLC and Cornell Interventions OS, LLC (collectively, the “Guarantors”). GEO and the Guarantors are making the Exchange Offer in reliance on the position enunciated by the Division of Corporation Finance in Exxon Capital Holdings Corporation, SEC No-Action Letter (available May 13, 1988), Morgan Stanley & Co, Inc., SEC No-Action Letter (available June 5, 1991), and Shearman & Sterling, SEC No-Action Letter (available July 2, 1993). GEO is submitting this supplemental letter to the Commission in order to make the representations set forth below in response to the Commission’s comment letter, dated November 21, 2013.

GEO and the Guarantors (a) have not entered into any arrangement or understanding with any person to participate in a distribution (within the meaning of the Securities Act of 1933, as amended (the “Securities Act”)) of the Exchange Notes received in the Exchange Offer and (b) have not entered into any arrangement or understanding with any broker-dealer to participate in a distribution of the Exchange Notes, and, to the best of GEO’s and the Guarantors’ information and belief, based upon the representations and agreements to be set forth in the Letter of Transmittal, each person participating in the Exchange Offer is acquiring the Exchange Notes in the ordinary course of its business and has no arrangement or understanding with any person to participate in a distribution of the Exchange Notes to be received in the Exchange Offer.

In this regard, GEO and the Guarantors will make each person participating in the Exchange Offer aware (through the Exchange Offer prospectus and the related letter of transmittal) that if such person is an affiliate or has an arrangement or understanding with respect to the distribution of the Exchange Notes, such person (i) cannot rely on the position of the Staff enunciated in the Exxon Capital Holdings Corporation SEC No-Action Letter and other interpretive letters with similar effect and (ii) must comply with registration and prospectus delivery requirements of the Securities Act of 1933, as amended (the “Securities Act”), in connection with any secondary resale transaction unless such resale is made pursuant to an exemption from such requirements.

GEO and the Guarantors acknowledge that such a secondary resale transaction by such person participating in the Exchange Offer for the purpose of distributing the applicable Exchange Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 of Regulation S-K under the Securities Act.

GEO and the Guarantors will make each person participating in the Exchange Offer aware (through the Exchange Offer prospectus) that any broker-dealer who holds Original Notes acquired for its own account as a result of market-making activities or other trading activities, and who receives applicable Exchange Notes in exchange for such Original Notes pursuant to the applicable Exchange Offer, may be a statutory underwriter and must deliver a prospectus meeting the requirements of the Securities Act (as described in the Shearman & Sterling SEC No-Action Letter in connection with any resale of such Exchange Notes.

GEO and the Guarantors further represent that, with respect to any broker-dealer that participates in the Exchange Offer with respect to the Original Notes acquired for its own account as a result of market-making or other trading activities, each such broker-dealer must confirm that it has not entered into any arrangement or understanding with GEO or an affiliate of GEO to distribute the Exchange Notes.

GEO and the Guarantors will include in the transmittal letter to be executed by an exchange offeree in order to participate in the Exchange Offer the following additional provisions:

If the exchange offeree is not a broker-dealer, an acknowledgment that the exchange offeree is not engaged in, and does not intend to engage in, a distribution of the applicable Exchange Notes.

ii.

If the exchange offeree is a broker-dealer holding Original Notes acquired for its own account as a result of market-making activities or other trading activities, an acknowledgment that it acquired the Original Notes for its own account as the result of market-making or other trading activities and it will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of Exchange Notes received in respect of such Original Notes pursuant to the applicable Exchange Offer; and a statement to the effect that by so acknowledging and by delivering a prospectus, such broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

Should you have any questions or require any further information, please contact our outside counsel, Esther L. Moreno, Esq. at (305) 982-5519.


Very truly yours, The GEO Group, Inc.

By:		/s/ Brian R. Evans
		Brian R. Evans
		Senior Vice President and Chief Financial Officer
GEO RE Holdings LLC Correctional Services Corporation, LLC CPT Limited Partner, LLC CPT Operating Partnership L.P. Correctional Properties Prison Finance LLC Public Properties Development and Leasing LLC GEO Holdings I, Inc. GEO Acquisition II, Inc. GEO Transport, Inc. Cornell Companies, LLC Cornell Corrections Management, LLC CCG I, LLC Cornell Corrections of Alaska, Inc. Cornell Corrections of California, Inc. Cornell Corrections of Texas, Inc. Cornell Corrections of Rhode Island, Inc. Cornell Interventions, Inc. Correctional Systems, LLC Cornell Abraxas Group, Inc. WBP Leasing, LLC BII Holding Corporation BII Holding I Corporation Behavioral Holding Corp. Behavioral Acquisition Corp. B.I. Incorporated MCF GP, LLC GEO MCF LP, LLC Municipal Corrections Finance, LP GEO Operations, LLC GEO Corrections Holdings, Inc. GEO Corrections and Detention, LLC GEO Re-entry Services, LLC Cornell Abraxas Group OS, LLC Cornell Companies of California OS, LLC Cornell Companies of Texas OS, LLC Cornell Interventions OS, LLC The GEO Group REIT, Inc.

By:		/s/ Brian R. Evans
		Brian R. Evans
		Principal Financial Officer