page 14: Named Plaintiff Joe Laurinaitis, states
“WWE is a big dance, if you don’t do it, someone else will, and 99% of the time
you perform under duress. Injured you suck it up and perform, keep your mouth
shut”.
Page 21: Plaintiff Joseph Michael “Joe”
Laurinaitis, a.k.a. Road Warrior Animal
(“Laurinaitis”)
is 55 years old and resides in Defiance, Missouri. Laurinaitis is arguably a
member of the most well-known tag team in WWE history, while his brother, John
Laurinaitis was a long time senior executive of WWE’s talent relations
department and a close associate of Vince McMahon in all aspects of the
business. Laurinaitis asserts he was given a boilerplate contract in which
“nothing was up for negotiation.” Laurinaitis wrestled hundreds of nights per
year in the WWE and performed at their ironfisted direction. He was even
threatened with fines for wearing jeans on an airplane and changing a 7 am
flight to a later one. Laurinaitis alleges there was little to no treatment by
WWE ringside doctors. Laurinaitis sustained numerous head injuries in WWE
matches. He specifically recalls at least four major concussions he suffered
while performing in WWE. In one instance, he was double suplexed in 1992 while
performing with the Beverly Brothers and suffered an impact which herniated two
discs in his neck. He was “powerbombed” by Shawn Michaels in 1997 immediately
after returning from neck surgery. Laurinaitis has had at least 11 surgeries
from the cumulative effects of his wrestling career. Laurinaitis’ tag team
partner, Michael Hegstrand died in 2003 of a heart attack at the age of 46.
Laurinaitis continues to receive royalties from his WWE performances, along
with letters offering drug and alcohol rehabilitation. Laurinaitis suffers from
cognitive difficulties, including, but not limited to, headaches, dizziness,
loss of memory, and fatigue.
Page 183: Laurinaitis, was doubled
suplexed in 1992, landed badly herniated discs in his neck. None of this nor
thousands of similar occurrences were ever reported to OSHA by the WWE as
required by law. Injuries were suppressed, not reported.
Notes: Last WWE Run ended in May 2006; had
one-off match vs. Heath Slater in July 2012
Page 22-23: Plaintiff Jimmy Snuka, a.k.a. Superfly
(“Snuka”) and his guardian, Carole Marie Snuka, is 72 years old and resides
with his wife Carole Snuka in Atco, New Jersey. Snuka was born in Fiji and
received minimal education. Snuka is illiterate and although he cannot read or
write, his wife alleges that the WWE “had him sign stuff all the time.” Snuka
performed for WWE between 1982 to 1985 and 1989 to 1992, returning in 1993.
Snuka was the WWE headliner for much of his tenure, participating in
Wrestlemania V, VI and VII and is one of the most famous wrestlers in the
world. Snuka’s high flying style which served to popularize wrestling around
the world is one of the most successful WWE performers of all time. Snuka’s
signature move the “superfly splash” was to dive off of the top rope and land
on his opponents. Snuka also was involved in one of the most famous stunts in
WWE history on October 17, 1983 when he leapt 15 feet off the top of a metal
cage in Madison Square Garden. Snuka sustained numerous blows to the head and
reports multiple events that are consistent concussions. During a WWE interview
Snuka was famously struck in the head with a coconut which smashed open as his
“opponent” (another deceased WWE wrestler named Roddy Piper) mocked his
Melanesian heritage whipped him with a belt and stuffed bananas in his mouth.
Snuka recalls that at the time he sustained neurological problems as a result
of being struck in the head, and he suffered dizziness and chronic headaches.
Snuka now experiences cognitive difficulties including, but not limited to,
depression, anger, mood swings, headaches, dizziness, severe loss of memory,
confusion. Snuka suffers from significant cognitive and neuropsychological
impairment, post-concussion syndrome due to thetraumatic brain injuries that he
sustained repeatedly as a result of successive blows to the head during his
wrestling career.
Notes: Last match: April 2009 at WrestleMania
25 (vs. Jericho w/ Steamboat/Piper); Sporadic matches in Jan 2008, June 2007,
November 2005, November 1996 and September 1993; Last WWE run: ended Feb 1992
Page 23-24: Plaintiff Paul Orndorff, a.k.a. Mr.
Wonderful (“Orndorff”) is 66 years old and resides with his wife in
Fayetteville, Georgia. Orndorff headlined Wrestlemania I and wrestled with Hulk
Hogan and Mr. T. He was a major figure during the “Golden Era” of 1983 to 1988
and was Hulk Hogan’s primary opponent into the 1990s. Inducted into the WWE
Hall of Fame in 2005, Orndorff was a famous wrestling instructor, both
well-known and well regarded. He alleges that he was “pressured to work
injured” and that despite his loyalty to WWE, the company has “treated him like
nothing.” He has three herniated discs in his back, neck injuries, requires
knee surgeries, shoulder and hip replacements. After a long and fabled career
with WWE, Orndorff suffers from severe cognitive difficulties, including, but
not limited to, difficulty sleeping, confusion, headaches, dizziness, severe
loss of memory, and fatigue resulting from the routine head trauma sustained
during his WWE career. Orndorff also gets easily confused, is clinically
depressed, paranoid, repeats himself constantly and has severe mood swings.
Orndorff at the height of his career was one of the most successful performers
in wrestling and was one of a fortunate few wrestlers that could afford and
purchased long term disability insurance, the policy however expired at age 65.
He is now on disability and Medicare.
Page 75 footnote: See also World Wrestling
Entertainment: Bloodbath Wrestling’s Most Incredible Steel Cage Matches”, WWE
Home Video, DVD (“The steel cage: It’s used as a barrier and as a weapon. It
keeps the competitors inside and the interference outside. The steel cage match
is the most brutal form of sports entertainment…” The box case features matches
by named Plaintiff Paul Orndorff who are thrown against steel bars often
resulting in injury).
Notes: Last run with WWE: Nov 1983-Jan 1988;
Last match: Sept 2000 in WCW
Page 24: Plaintiff Salvador Guerrero IV, a.k.a.
Chavo Guerrero, JR (“Guerrero Jr.”) is 45 years old and resides in Rancho Santa
Margarita, California. Guerrero Jr. is from well-known wrestling family, and
wrestled as a headliner for WWF during from 2000 to 2011. He was a featured WWE
performer including wrestling in Wrestlemania and No Disqualification matches.
Guerrero Jr. was a four time WWE cruiserweight champion two time tag team
champion as well as the ECW champion. Guerrero Jr. suffered head injuries in
WWE. He describes the WWE culture as brutal, with near total disregard for his
health and safety. By way of example on August 24, 2004 he was hit in the head
with a knee in a Shooting Star Splash by another wrestler. Guerrero, Jr. was knocked
completely unconscious for many minutes, with Stephanie McMahon at ringside
before being hospitalized with a concussion and subarachnoid hemorrhage. In
2005 he was kicked in the eye which fractured his orbital bone, yet shortly
thereafter he was still required to “drop his belt” (lose to another wrestler)
in the ring at the direction of the WWE. Guerrero Jr. suffers from cognitive
difficulties, including, but not limited to frequent headaches, anxiety,
involuntary muscle movements, insomnia, dizziness, memory loss, and fatigue
Page 155: Salvador Guerrero, contract dated July
23, 2001, a true and accurate copy of which is attached as Exhibit A, hereto.
Salvador Guerrero, IV, contract dated June 3, 2004, a true and accurate copy of
which is attached as Exhibit B, hereto. Salvador Guerrero, IV, contract dated
April 5, 2010, a true and accurate copy of which is attached as Exhibit D,
hereto.
Notes: Last WWE run: July 2001 - June 2011
Page
24-25: Plaintiff Chavo Guerrero, Sr., a.k.a. Chavo Classic (“Guerrero”) is 67
years old and resides in Dewey Arizona. Part of a dynastic wrestling family, he
wrestled for WWF during 2004 as part of storyline involving his brother and
son. Guerrero’s brother, famed WWF star Eddie Guerrero, died of a drug related
heart attack in 2005. His son is also a Plaintiff in this action. Plaintiff
Guerrero suffered head injuries during his stint in WWE, hitting a ring post
and falling out of the ring. He never heard the word “concussion.” “You got
your bell rung sometimes” but there was rarely treatment, inquiry or
intervention by WWE staff or ringside doctors unless it was an obvious medical
emergency. Guerrero suffers from cognitive difficulties, including, but not
limited to, headaches, dizziness, loss of memory, and fatigue.
Notes: Last WWE run: January 2004 – June 2004
Page 25: Plaintiff Bryan Emmett Clark, Jr., a.k.a. Adam Bomb (“Clark”) stands at 6’ 7” 290 pounds, is 51 years old and resides in Mesa, Arizona. Clark wrestled for WWE from 1993 to 1995 and again in 2001. Clark wrestled 280-290 days per year with WWF. He was given the gimmick of a man exposed to radioactive elements. Clark asserts WWE’s culture was to not ask any questions because if he did he alleges he would lose his bookings and his income. Clark says it was common in WWE and wrestling to be knocked in the head and lose consciousness. On September 23, 2001, he had a bad neck injury in Pittsburg, Pennsylvania when he was choke slammed by the Mark William Calaway a.k.a. The Undertaker (a famous wrestler) and discs in his neck were injured. Clark eventually had these discs replaced in 2014 and had spinal surgery. Clark is scheduled for another knee replacement in 2016. Clark has peripheral neuropathy, sleep problems and involuntary movements during sleep. He suffers from headaches, progressively worsening severe memory loss such that he has difficulty driving to his local grocery store, depression, anxiety and cognitive impairment. He is currently applying for disability.
Page 182: For example, Bryan Emmett Clark had his head driven full force into a ring post by Savio Vega in a WWE match and suffered a memory loss. Clark states it was common to get hit in the head and knocked out briefly.
Page 196-197: An example is Brian Clark who was recruited to WWE by a former well known WWE Wrestler turned WWE Agent “Sgt. Slaughter”. Mr. Clark passed his “try out” in Charleston, SC and then was mailed a boilerplate Booking Contract by WWE to his home in Atlanta, Ga. Mr. Clark read the contract, and fully understood that there was no “negotiating” allowed. Mr. Clark had no idea that he was not being classified as an employee, or that there were any financial and physical consequences he would suffer as a result of the misclassification. Clark was never told that he was an “independent contractor” and has no idea what the difference between an “independent contractor” and an employee is. Clark alleges that there was no “independence” for wrestlers who worked for the WWE – you did as you were told, the matches came out as you were told, props used (such as chairs) were utilized when you were told, wrestling moves were included or removed –all as dictated by WWE. Clark alleges that WWE provided the schedule, told you when and where to arrive and what you were to do, day after day. Mr. Clark observed that if anyone complained at WWE they were not around long. He was a “mid-level” wrestler. The men constantly complained to each other about injuries, the long schedule, constant traveling and poor pay, but they dared not complain to management knowing what the result would be swift and certain. 623. On September 23, 2001, Mr. Clark was wrestling in a match in Pittsburg, PA televised on “pay per view” when he was “choke slammed” by the “Undertaker” which seriously injured two disks in his neck which later required surgery. Clark alleges that he suffered numerous concussions such as but not limited to having his head driven into a ring post by Savio Vega such that he lost track of his surroundings. Clark also alleges further that on 12/28/93 while wrestling Tatanka in Canton, Ohio he was suffered a very serious head blow when Tatanka landed on his skull after jumping on Clark from a top rope. Clark alleges that Vince McMahon attended most televised or taped for television programs, and was readily available to personally witness the injuries experienced by the wrestlers. Having occasionally wrestled himself, McMahon would surely know how it felt to be smashed into the “mat” or the dangers of a “pulled punch” connecting instead of missing. Further Clark suffered serious shoulder injuries from the grinding schedule. He informed Vince McMahon of these injuries who tried to talk him out of the need for surgery claiming that WWF needed Clark right then. However, the pain was too severe and Clark had shoulder surgery, which he had to personally pay for. This payment was a direct result of the WWE misclassifying the Wrestlers as independent contractors so as to save on Worker’s Compensation premiums, well knowing that the Wrestlers would not comprehend what had been done to them.
Notes: Last runs with WWE: September 2001; March 1993-August 1995
Page
25: Plaintiff Anthony “Tony” Norris, a.k.a. Ahmed Johnson (“Norris”) is 52
years old and resides in Houston Texas. Norris wrestled for WWF from 1995 to
1998. He was recruited to WWE by Michael Hayes, and was sent to Connecticut to
Meet Vince McMahon. Norris brought his lawyer, but upon arrival Mr. McMahon
stated that he “hated lawyers” and instructed Norris’ lawyer to leave the
office as there was nothing to negotiate. Norris became the first African
American WWF champion in 1996. Norris selected the name Ahmed Johnson over the
WWE suggestion of the ring name “Buck,” and oddly he was billed from “Pearl
River Mississippi.” Norris sustained numerous injuries in WWE career he was
known for performing “suicide dives” which required him to go through the ropes
onto the floor, sometimes landing on his head. Norris was struck with a wooden
two by four injuring his arm which required hospitalization due to infection.
He injured his knee when another wrestler tackled him too low, his back was
struck with a steel rail by Goldust and he required back surgery from injuries
sustained in WWE. On January 21, 1996, Norris was knocked out completely after
a guitar was smashed over his head by Jeff Jarrett in Madison Square Garden
leading to a hospital visit and long term neurological injuries. Norris
suffered repeated and chronic head impacts throughout his career resulting in
cognitive difficulties, including, but not limited to, headaches, difficulty
sleeping severe loss of memory. He is under the care of a neurologist, on
numerous medications and currently on SSDI.
Page
194-195: The boilerplate Booking Contract was presented to the Wrestlers by the
WWE on an “its my way or the highway” basis. For example, Wrestler Anthony
Norris (a.k.a. Ahmed Johnson) attempted to bring an attorney to the Connecticut
office of WWE to discuss the Booking contract. Vincent McMahon told Mr. Norris
that “he hates lawyers” and had Norris’ attorney escorted off of the property
according to Norris. VKM apparently only hates other people’s attorneys as he surrounds
himself with not only many “in house” attorneys but high-profile outside
national firms, and places his attorney confidants as trustees of his family
trusts to do his bidding. See SEC Filings, Exhibit F hereto.
Notes:
Last WWE run: July 1995-Feb 1998
Page 26-27: Plaintiff
James Harris, a.k.a. Kamala (“Harris”) is 65 years old and resides in
Senatobia, Mississippi. Harris has a 9th grade education. Harris wrestled for
WWE from 1984 to 1992 and returned in 2001, and then again in 2004 to 2006.
Harris, an African-American, was portrayed the gimmick of a savage Ugandan
Giant, who wore a mask, did not speak, entered to the beat of tribal drums,
face paint, was barefoot, ate live chickens and had masked handlers. Harris
stated, “I thought the gimmick was a stereotype, I was just trying to make me
some money, I didn’t care, I didn’t want to hurt anything. I never got
embarrassed – I was alright with it.” A commentator wrote of such characters,
“inaugurating a new era of racial insensitivity that relegitimized antiblack racism
in seriocomically guise… Kamala the Ugandan Giant, who came in to the ring with
an animal print loincloth, tribal painting on his face and chest, and
sometimes, a tribal mask and spear. He was so ‘wild’ that he needed a handler,
so he was often accompanied by a masked fellow in a pith helmet…” [Shoemaker,
David, The Squared Circle: Life, Death and Professional Wrestling, 136 (NY
Gotham Books 2014).] (This “handler” in the pith helmet was another
wrestler/WWE agent named Steve Lombardi who when contacted by Plaintiffs’
investigators after being released from WWE in May 2016 after 33 years there,
stated his belief that the WWE was a “careful company,” and that he would
testify for the WWE and that those involved in the cases against the company were
“con men.”) At 410 pounds Harris was required to fly coach class, was required
to be barefoot at all times, and wrestled hundreds of nights per year for the
WWE. Harris wrestled Andre the Giant in cage matches and opponents such as Hulk
Hogan. Harris was hit with punches in the ring, hit his head on the concrete
floor, smashed his head on the mat and would be “dazed” many times in correctly
performed moves in WWE matches. Harris had no medical insurance after he
retired and could not afford to pay doctors which delayed treatment of his
declining health. In 2011, he was finally able to obtain state assistance with
the help of a social worker. Harris was only then diagnosed with late stage
diabetes with poor circulation in his legs. In December of 2011, his left foot
was amputated, then after his leg failed to heal, his left leg was amputated.
In April 2012, his right foot was amputated and later his right leg was
removed. Harris is currently on twice-weekly dialysis. He is on SSDI and
Medicare/Medicaid and is in debt for unpaid medical bills. Having suffered
countless and repeated blows to the head throughout his notable WWE career,
Harris is suffering from cognitive difficulties, including, but not limited to,
headaches, dizziness, loss of memory, and fatigue, is on medication for
depression as well as generally poor health. The WWE sends him “Wellness
Letters” offering drug rehab and suicide hotline as well as paying him
royalties. Harris’ last check paid to him in March 2016 was for $98.01 for his
annual quarterly royalties for his performances.
Page 157: James
Harris, a.k.a. Kamala received $98.01 by a mailing on or about March 24, 2016.
Additionally, attached as Exhibit H hereto is a document consisting of four
pages of mailings for Kamala regarding the corresponding royalty check. The
Exhibit details the specific earnings for direct, multi-media, other licensing,
and video WWE received, and the corresponding royalties WWE paid to Mr. Harris.
Page 159: As an
additional example on Page 3 of the royalty sheet dated 3/24/2016 for Plaintiff
James Harris there is shown as a royalty from HV Direct WWE No. 94879 for
quarter four of 2015 earnings by WWE of $5,095.73 with a royalty paid to
Plaintiff, James Harris of $1.46.
Notes:
Last
WWE match: 6/06 (vs. Umaga), 8/05 (vs. Randy Orton), Gimmick Battle WM X-7
Page 28: Plaintiff Dave Hebner (“Dave
Hebner”) is 66 years old and resides with his wife in Mechanicsville, Virginia.
Dave Hebner was a WWF employee without a Booking Contract for 27 years and was
a referee with his identical twin brother, Earl Hebner. As a referee in WWE
Dave Hebner was part of the performance and took bumps, falls and performed in
matches often being subjected to maneuvers of the highly trained wrestlers.
Dave Hebner suffered numerous blows to the head throughout his career and has
experienced cognitive difficulties, including, but not limited to, headaches,
dizziness, loss of memory, and fatigue. Dave Hebner was diagnosed with dementia
in the past two years and has recently been diagnosed with Parkinson’s disease.
Page 13: Named Plaintiff and famous WWE referee,
Earl Hebner, who performed from 1988 to 2005, observed that wrestlers relied on
the referees to maintain safety and end matches when injuries occurred. However,
the referees were limited by WWE’s own protocols and scripting, often watching
helplessly as wrestlers were repeatedly beaten in the head while WWE took no
action to prevent further injury. See, e.g., Royal Rumble on January 24, 1999
where Mick Foley received at least 11 unprotected blows to the head with a
metal chair by The Rock, while Earl Hebner stands by.
Page 27: Plaintiff Earl Hebner (“Earl Hebner”) is
66 and resides in King William, Virginia. Identical twin brother to Plaintiff
Dave Hebner, Earl Hebner is considered the most famous referee in WWE history
and was the Senior WWE Referee from 1988 to 2005, officiating most WWF events
during those years. During his 17-year career he officiated more high profile
matches than nearly every referee in WWE history. Earl Hebner sustained major
and numerous injuries in his role as referee which was part of many famous
storylines. One fan writer observes: “I have many pleasant memories of Earl the
official; mostly stemming from his incredible bumping ability. A referee who
can take an awesome bump is an underrated commodity. … Earl would take such a
severe bump that it was believable that he’d be lying around injured for
minutes afterwards. He’d draw gasps from the crowd.”[ Dixon, James, et al.,
“The Complete WWF Video Guide, Volume I”, 202 (2012).] As a result of the
numerous and repeated head trauma Earl Hebner sustained while employed by WWE,
he now suffers from neurological injuries and cognitive difficulties,
including, but not limited to, headaches, dizziness, loss of memory, and
fatigue.
Page 28: Plaintiff Chris Pallies, a.k.a. King
Kong Bundy (“Pallies”) is 60 years old and at 6’4” and 450 pounds is a famous
heavy weight wrestler who resides in Glassboro, New Jersey. Pallies was
recruited into the WWE and asked Vince McMahon what the booking contract
covered. Vince McMahon replied “that the contract includes everything up to and
including your first born.” It was not subject to negotiation. Pallies says he
was referred to as a “WWF product” by WWE staff. He characterized the schedule
as “brutal,” working hundreds of nights per year and sometimes seven nights a
week, with “double shots” on weekends - two shows on Saturday and two shows on
Sunday. He was fined for missing a show and threatened with fines for wearing
shorts on a plane to the shows. Pallies was the headliner for Wrestlemania II’s
steel cage match with Hulk Hogan. Pallies wrestled for WWF from 1985 to 1988
and from 1994 to 1995, performing in Wrestlemania II and XI. Pallies states
“you wrestled injured” or you didn't earn money. He sustained head trauma from
various moves and chair shots and was prevented by WWE from receiving adequate
time to recover which resulted in neurological injuries culminating in
cognitive difficulties, including, but not limited to, headaches, dizziness,
loss of memory, and burning pain all over his body. He is now on Medicare and
has been on SSDI for the past eight years.
Notes: Last
WWE run: August 1994-October 1995
Page 14: Named Plaintiff, Ken Patera, states,
“If you spoke up about injuries, you would be labeled ‘injury prone’ and lose
your spot”.
Page 29-30: Plaintiff Ken Patera (“Patera”) is 72
years old and resides in Woodbury, Minnesota. Patera is a highly decorated
Olympic weightlifter, winning gold at the pan-American games and winning four
consecutive weightlifting championships. In the 1970s, Patera was one of the
world’s strongest men. He is the only American to clean and press 500 lb (507)
and is the last American to excel at weightlifting on an international level.
Patera wrestled for WWWF starting in 1977 when he wrestled Bruno Sammartino in
Madison Square Garden. He returned for a year in 1980 and returned at the
behest of Vince McMahon in 1984. Patera was regularly asked to demean himself
“to put over” (to make an opponent look good) lessor talents to promote WWE
chosen stars or wrestlers, “they had me job all over the place” using wrestling
terminology for being required to lose. Patera describes a total and complete
lack of concern for wrestler health and safety, providing for example a 1987
match in Madison, Wisconsin where his injuries required 450 stitches and
eventual surgery, despite no ambulance, doctor, or even ice on site at the performance.
He sustained numerous injuries while wrestling for WWE, and states, “In WWF you
are a piece of meat, and once you can no longer perform they show you the
door.” Patera suffered numerous concussions, one from being clotheslined in
Fort Meyers, after which he was confused and unaware of his surroundings for
three hours. Patera was on the road almost every day and had at least seven
major surgeries resulting from his injuries with WWE. Patera estimates he
sustained numerous concussions in WWE. He also sustained many back and neck
injuries in WWE events. Patera alleges that the repeated blows to his head
resulted in neurological injuries and cognitive difficulties, including, but
not limited to, headaches, dizziness, loss of memory, and fatigue. He has been
on SSDI and Medicare/Medicare for more than a decade. He receives royalty
checks for his violent performances in WWE of about $264 per annual quarter.
Page 62: WWE’s culture of silence requiring
wrestlers to “suck it up and keep going” pressured the Named Plaintiffs to not
report their injuries or risk not being paid or even terminated. Specifically,
Named Plaintiff Ken Patera states in response to his injuries that he was
called “injury prone”, and was ridiculed as a result. Nearly all of the Named Plaintiffs
will attest to numerous specific examples of the culture of silence and
coercion that pervaded WWE during their careers.
Notes: Last WWE run ended in November 1988
·
TERRY
MICHAEL BRUNK, a.k.a. Sabu
Page 30: Plaintiff Terry Michael Brunk, a.k.a.
Sabu (“Brunk”) is 51 and resides in Allendale, Michigan. Described by the WWE
Encyclopedia as the “Homicidal, Suicidal, Genocidal, Death Defying Maniac,”
“Sabu is best remembered for the abundance of injuries he suffered.” In his
long career Brunk wrestled with WWE from 2006 to 2007. The WWE wanted to
exploit the extreme style of wrestling recruiting Brunk to smash through
tables, and engaging in Extreme rules matches that pushed the limits of
violence in wrestling, for example January 28, 2007, Brunk received a choke
slam over the top rope and through a table. Brunk’s repeated, chronic, and
countless head trauma has resulted in severe neurological injuries including
cognitive difficulties, including, but not limited to headaches, mood swings,
difficulty sleeping and loss of memory.
Notes: Last WWE run: 6/06-5/07
Page 30: Plaintiff Barry Darsow, a.k.a. Smash
(“Darsow”) is 56 years old and resides in Maple Grove, Minnesota. Darsow
wrestled for WWF from 1987 to 1993 and wrestled as part of a tag team called
Demolition with Plaintiff Bill Eadie. They had an extensive “run” with the WWE
winning the “belts” at Wrestlemania IV and remained the WWE Tag Team Champions
for a record 478 days. Demolition also had the longest cumulative run of Tag
Team Champions in WWE of 678 days. The schedule was rigorous, with Darsow
working hundreds of nights per year for the WWE. Darsow suffered extensive
injuries throughout his career, was knocked out numerous times including being
hit over the head with a chair that knocked out seven teeth. Darsow has severe
neurological injuries from the repeated, chronic, and routine head trauma
resulting in cognitive difficulties, including, but not limited to, constant
headaches, difficulty sleeping, severe loss of memory.
Notes: Last WWE match: Raw 15th Anniversary
(12/07) + Gimmick Battle Royal at WM X-7 (4/01); last run ended March 1993
Page 32: Plaintiff Bill Eadie, a.k.a. Ax
(“Eadie”) is 68 years old and resides in Roswell, Georgia. Eadie wrestled for
WWF from 1987 to 1991 and was the Three Time World Tag Team Champion with
Plaintiff Barry Darsow in Demolition. Eadie wrestled more than 200 nights per
year and explained that “there was no concern for [his] well-being;” that at
WWE, he was “not allowed to get hurt;” and that he was considered “a piece of
meat.” There were few doctors provided ringside nor any medical follow-up for
head injuries. Eadie suffered extensive injuries throughout his career, was
knocked out numerous times, and has severe neurological injuries from the
repeated, chronic, and routine head trauma resulting in cognitive difficulties,
including, but not limited to, headaches, dizziness, loss of memory, and
fatigue.
Notes: Last WWE run: ended November 1990; Last
Lawsuit vs WWE: lasted 1992-2001
Page 31: Plaintiff John Nord, a.k.a. The
Berserker, a.k.a. The Viking (“Nord”) is 56 years old and resides in Crystal,
Minnesota. Nord wrestled for WWF from 1991 to 1993 and has been on disability
for six years, having had seven neck fusions. Nord suffered major head injuries
during his career resulting from sustained and repeated head trauma. Nord endures
neurological injury manifesting as cognitive difficulties, including, but not
limited to, headaches, dizziness, loss of memory, and fatigue.
Notes: Last WWE run: Jan 1991-Feb
1993; Last WCW run: September 1997-April 1998
Page 32: Plaintiff
Jonathan Hugger, a.k.a. Johnny the Bull, a.k.a. Johnny Stamboli (“Hugger”) is
38 years old and resides in Phoenix, Arizona. Wrestling for WWE from 2001 to
2004. Hugger states that the WWE exercised near total control over him while at
WWE and that he was fined for lateness and wearing clothing that did not
conform to dress code. For example, he was fined $500 for wearing a baseball
cap on a bus at 3:00 a.m. because the dress code was “business casual.” Hugger
states he was fined $500 for wearing certain casual clothing on an airplane
arriving at a hotel at 7:00 a.m. on a redeye flight from Los Angeles to
Toronto. Hugger states; “You kept your mouth shut about injuries, compensation
or anything else or you would get heat from the office” and the WWE would “hurt
your character” meaning you would be told to lose. Hugger was knocked out
numerous times in WWE events, including by being slammed onto concrete. Noting
that every bump was like being in a car accident to his body, he endured grueling
hours, pain pills, and he believes several concussions. Hugger engaged in
hardcore matches for WWE where he was clotheslined, struck with steel chairs,
and knocked unconscious. Notably, he was knocked unconscious in developmental
by Accie Julius Connor a.k.a. D Lo Brown in 2001. On July 15, 2002, he hit the
back of his skull on concrete in East Rutherford, New Jersey when John Bradshaw
Layfield stormed into the locker room to get his title belt. At the time he did
not know it was a concussion, but merely shrugged it off as another injury
where there was no protocol or treatment of any kind. Hugger alleges he
sustained routine, continuous, and chronic head trauma even from correctly
performed moves in WWE matches that have resulting in neurological injuries
manifesting as cognitive difficulties, including, but not limited to,
headaches, dizziness, loss of memory, and fatigue.
Page 12: Named
Plaintiff Jonathan Hugger states he was knocked out by hitting his head on
concrete on a televised broadcast on 7/15/2002 whereupon he was examined by a
WWE Doctor and told to “shake it off.”
Page 14: For example,
Named Plaintiff, Jonathon Hugger, states that if a wrestler reported an injury
“the WWE would hurt your character” “you kept your mouth shut or you would get
‘heat from the office’ if you got too opinionated or spoke up about injuries or
anything you would be [messed] with”.
Page 130: Jonathan
Hugger (a.k.a. Johnny Stamboli) alleges that he was handed a contract to sign
by Jim Ross of WWE, which he executed with no negotiation on a “take it or
leave it” proposition. He was told he had to move to Cincinnati and to break
his lease. Mr. Hugger alleges that if he did not accept the WWE contract, you
did not wrestle. Once he questioned a story line and was sent to Louisville, KY
for two weeks as punishment
Notes: Last WWE
run: dark match vs Chavo on 7/31/07; June 2002-October 2004
Page 32-33: Plaintiff James Brunzell, a.k.a.
Jumpin’ Jim (“Brunzell”) is 66 years old and resides in St. Paul, Minnesota.
Wrestling for WWE from 1985 to 1993, Brunzell would wrestle 300 nights per year
often as many as 25-26 days each month. He even once wrestled 43 days in a row.
Brunzell suffered countless head injuries and was not permitted the necessary
and adequate time to heal, resulting in compounded and worsening neurological
injuries. Brunzell stated he was approached by Rene Goulet after he started
wrestling for WWE in 1985 and was told he needed to sign the agreement he was
proffered or “else he would be fired.” No negotiation was permitted. Brunzell
likened the working conditions at WWE to being an “indentured slave.” He states
that any discussions of being overworked would be met by a “pink slip,” and
that any protests were muted by the economic realities: “if you didn't wrestle
through injuries you would not be paid.” Brunzell believes he sustained several
major concussions in his WWE career and numerous times in WWE had his “bell
rung.” He recalls being in Salt Lake City Utah in 1988 when he was hit by
another wrestler who weighed 315 lbs. who threw a high kick that connected with
his jaw. Brunzell states: “My horizontal speed came to a halt and I slammed the
mat with the back of my head I saw a flash of light and stars. I was dizzy,
nauseous, and unstable on my feet for three days.” He finally saw a WWE
affiliated doctor in Los Angeles who stated he had a “3rd degree concussion.”
WWE agent Chief Jay Strongbow agreed that his very next match with Hercules
should be “light” and instructed his opponent to avoid slamming or hitting
Brunzell’s head. He continued to perform and didn’t miss a day. Brunzell has
had a shoulder replacement, knee replacement, partial hip replacement along
with back and neck problems. He works for a janitorial supply company and has
insurance though that job, though Brunzell attributes most of his injuries to
his wrestling career. As a result of the numerous and repeated head injuries
during his WWE career, Brunzell has cognitive difficulties, including, but not
limited to, short term memory loss, anxiety for which he takes medication and
difficulty sleeping.
Page 60: In the 1990s Named Plaintiff Jim
Brunzell reports wrestling 26 nights per month, in one instance 43 days in a
row.
Notes: Last WWE run: ended March 1993
Page
34: Plaintiff
Susan Green, a.k.a. Sue Green (“Green”) is 62 years old and resides in West
Columbia, South Carolina. Green wrestled with WWWF from 1971 to 1979 without a
Booking Contract and pioneered WWE’s women’s wrestling in the 1970s. She was
the second female wrestler ever to perform in Madison Square Garden and took
the title from Mary Lillian Ellison a.k.a. Fabulous Moolah in 1976. Green
wrestled with WWF until 1984. Green states that as a female wrestler she and others
were tightly controlled by Ellison who handled and controlled the booking for
virtually all the woman wrestlers for WWF during the period she wrestled. In
her wrestling career including in the WWF Green suffered numerous injuries to
her head, neck, and spine, and currently has nerve damage in her lower back
that affects both legs. As a result of the repeated and chronic head trauma
Green suffered during her career, she currently endures cognitive difficulties,
including, but not limited to headaches, memory loss, depression, anxiety,
difficulty sleeping for which she is prescribed medication (Paxil, Xanax and
Ambien). She is currently disabled on Medicaid and receives SSDI.
Page 34: Plaintiff Angelo Mosca, a.k.a. King
Kong Mosca (“Mosca”) is 78 years old and resides in St. Catherines, Ontario.
Mosca was fabled football player for 14 years before his wrestling career
(1959-1972) and was a five-time Grey Cup Champion and is in the Canadian
Football Hall of Fame. Building on his notoriety in Football, Mosca began
working in WWE as early as 1970. Mosca states he wrestled for WWF without a
Booking Contract into the 1980s and is known for being the WWE’s most hated
“bad guy” in 1981 when battling for the world championship and is featured in
the WWE Encyclopedia. Mosca was diagnosed with Alzheimer’s disease in 2015
after suffering repeated blows to his head throughout his long career. Mosca
believes that his wrestling career including his WWE matches significantly
contributed to his long term head injuries.
Notes: Last WWE runs: Oct-Dec 1984;
through Dec 1981
Page 35: Plaintiff James Manley, a.k.a. Jim
Powers (“Manley”) is 57 years old and resides in Merritt Island, Florida.
Manley wrestled for WWF from 1984 to 1994 and was member of the popular tag
team the Young Stallions. Manley sustained numerous head injuries while in WWE
including being knocked unconscious in a WWE Match in Italy with the Tag Team
Demolition (Bill Eadie and Barry Darsow who are also named Plaintiffs in this
action), additionally Manley states he has had his “bell rung” numerous times
at WWE events. Manley suffers from cognitive difficulties, including, but not
limited to, headaches, loss of balance, dizziness (bumps into walls and
sometimes falls down) and he has difficulty even going down stairs in his home,
severe memory loss, (constantly forgets who people are) and has trouble
sleeping, he has mood swings and anxiety. Manley is prescribed medications for
his conditions. He has had three hip surgeries, rotator cuff surgeries and is
currently on Medicaid and has been disabled on SSDI for approximately ten
years.
Notes:
Last WWE run: October 1984-October 1994; Last WCW run: June 1996-August
1998
Page 35: Plaintiff Mike Enos, a.k.a. Tag Team
Beverly Brothers (“Enos”) is 62 years old and resides in Tampa, Florida. Enos
wrestled for WWF from 1991 to 1993 and was injured numerous times, including
when the top rope broke, knocking Enos unconscious. Enos was not taken to the
hospital, but “walked off” the injury. He suffers from ruptured discs in his
back. As a result of the repeated and chronic head trauma during WWE matches,
Enos suffers from neurological injuries including cognitive difficulties, including,
but not limited to, depression for which is his prescribed medication,
headaches, dizziness, loss of memory, depression, and fatigue.
Notes: Last WWE run: May 1991-March 1993;
Last WCW run: May 1996-August 1999
Page 35-36: Plaintiff Butch Reed, a.k.a. The
Natural (“Reed”) is 61 years old and resides in Kansas City, Missouri. Reed
wrestled for WWE from 1986 to 1988 and appeared in Wrestlemania III. An African
American wrestler, he was given the gimmick by WWF to dye his hair blonde, and
so be known as “naturally blonde.” He didn't want to do it but “rolled with
it.” He says Vince McMahon liked to force wrestlers to change to gimmicks that
McMahon created. Reed alleges this was so that the WWE could control ownership
of the gimmick, and ring name he and other wrestlers were assigned and used by
the WWE. Reed wrestled close to 300 nights per year, twice on weekends and
often wrestled seven days a week. Reed states there were few WWE doctors or
medical examinations or safety rules generally. Reed was hurt when “a chair hit
me across the head and fell out of the ring and I couldn't get up for awhile.”
He says such incidents were relatively commonplace, “seeing stars” or getting
hit with a thrown punch that landed called a “potato,” sometimes “kicked so
hard you were paralyzed for a few seconds.” The preferred WWE medical treatment
was “Take yourself up, spit on it, put a band aid on it.”, “If you could put
your boots on you needed to be in the ring, otherwise there was no payday.”
Reed believes he suffered numerous, repeated and chronic head injuries,
resulting in long-term neurological injuries and cognitive difficulties from
his WWE matches, including, but not limited to, headaches, dizziness, loss of
memory, problems falling asleep and fatigue. He is on SSDI and Medicaid and
receives royalty checks from the WWE. His last check was for $69.
Page 157: As further example, Butch Reed received
$69.98 by a mailing on or about September 24, 2015 and a corresponding 1099 in
2016. Additionally, attached as Exhibit G hereto is a document consisting of
three pages of mailings for Butch Reed with the corresponding “royalty” checks.
A detail of the royalty checks mailed for the years 2013, 2014, 2015 consisting
of dozens of such checks and dozens of corresponding mailings is disclosed on
said Exhibit.
Page 159: In addition to the fraud and
swindles above alleged which violate 18 USC 1341 the Defendant Vincent McMahon,
individually and as trustee also engineered the WWE to cause violations of the
wire fraud statute 18 USC 1343 including but not limited to the following: The
WWE has established a video shop referenced on the Exhibits showing events for
“Bruce Reed” which Exhibit is dated 9/24/2015. Set forth on pages 1, 2 and 3 of
that Exhibit are shown numerous uses of the wires of the United States to sell
videos and thus generate further income for the enterprise WWE and furtherance
of the scheme of the Defendant, Vincent McMahon, individually and as trustee to
defraud the Plaintiffs. For example, on Page 2 there is noted for-KOC-DV-9056
$4,844.44 earned by WWE during the third quarter of 2013, resulting in a
payment to Bruce Reed of 0.23.
Notes: Last WWE run ended March
1988
Page 36: Plaintiff Carlene Denise Moore-Begnaud,
a.k.a. Jazz is 42 years old and resides in Lafayette, Louisiana. She wrestled
for WWE from 2001 to 2004 and was one of the most successful and skilled female
wrestlers of her era. She was a two time WWE Woman’s Champion. Moore-Begnaud
wrestled as the company’s top female heel and participated in Wrestlemania X8
and XIX. Her character was that of a tough female whose WWE tag line was “the
bitch is black and the bitch is back.” She was injured while wrestling in WWE events,
including being kicked in the temple where she was completely knocked out. She
went through a table on Monday Night Raw. Moore-Begnaud injured her knee so
badly it required surgery and she was forced to drop her title during her
recovery. She suffers from long-term neurological injuries and cognitive
difficulties, including, but not limited to, headaches, dizziness, and loss of
memory.
Notes: Last WWE matches: June 2006 (ECW),
November 2001-November 2004
Page 37: Plaintiff Sylvain Greiner (“Greiner”)
is 38 years old and resides in Terrebonne, Quebec. He wrestled for WWE from
2003 to 2007 along with his tag team partner Rene Gougen to form the tag team
La Resistance. He wrestled approximately 200 nights per year while at WWE and is
a four time WWE World Tag Team Champion. Many of his matches required that he
be thrown on a table that broke under him, he performed this finish night after
night. In some cases he would land on his head and neck. At some point he broke
his neck while wrestling in WWE and continued to perform nightly. The rule was
“you don't get hurt” and medical attention was not sought or administered
unless absolutely essential. Seeing doctors was in fact discouraged and the WWE
had very little supporting medical staff if any at the matches. Grenier states
his broken neck was not diagnosed until he secretly asked a state athletic
commission doctor in Madison Square Garden, New York who examined him for five
minutes, who told Grenier that it appeared to be broken based on the bulge he
felt. Grenier later had an MRI that confirmed it was broken in two places. He
was knocked out many times and sometimes would forget his “spot” due to
disorientation after a blow to the head and would be criticized for his
performances- his explanation of his head injuries was unpersuasive to WWE
staff. Grenier likens his career at the WWE to an “animal circus” in which the
wrestlers where not treated humanely. He suffers from long-term neurological
injuries and cognitive difficulties, including, but not limited to, severe
migraines, loss of sensation in his right arm, hearing loss, neck pain,
dizziness, and loss of memory.
Notes: last
WWE run: May 2002 through Aug 2007
Page 36-37: Plaintiff Omar Mijares,
a.k.a. Omar Atlas (“Mijares”) is 78 years old and resides in San Antonio,
Texas. Mijares, a Latin American wrestler with a 6th grade education, was a
well-known wrestler throughout most of his career. Mijares began working with WWE
on and off starting in 1970s. Mijares says “he trusted the WWE people,” but
found little health or safety rules in place during his time in the ring. As
the WWE expanded he started working for WWE more regularly 1984 with his fast
acrobatic style. Although Mijares was well known, he was eventually transformed
by the WWE into a “jobber to the stars” and by 1993 he was directed for $200 a
night to “put the WWE stars over,” meaning he was asked to repeatedly lose in
order to make the WWE headliners look better. At the time Mijares says he
needed to work, but says his last years in WWE stained his lifetime of work,
after a life dedicated to wrestling he was forced to lose and perform beneath
his skill level. Mijares received numerous injuries in WWE matches in his long
career and he was routinely punched, kicked and sustained head injuries often
in routine correctly performed moves. His wrestling career both in and out of
the WWE left him with two knee replacements, a left hip replacement, and nerve
damage to his elbow that required surgery. After wrestling he worked for the
San Antonio probation department and is now on Medicare and his own insurance.
Mijares receives Wellness Letters from the WWE, but no royalties. He suffers
from long-term neurological injuries and cognitive difficulties, including, but
not limited to depression, trouble sleeping, headaches, severe hearing loss,
mood swings, confusion, extreme and loss of memory.
Page 38: Plaintiff Don Leo Heaton, a.k.a. Don Leo
Jonathan (“Heaton”) 6’6” and 300 pounds is 84 years old and resides in Langley
British Columbia. A storied wrestler with a long career, Heaton is featured in
the WWE encyclopedia [“WWE Encyclopedia: The Definitive Guide to the WWE”,
“Brian Shields” and “Kevin Sutherland”, 100 (DK Publishing, London, 2012).] as
being “The Mormon Giant” who competed with Andre the Giant. He wrestled Pedro
Morales for the WWWF World Championship in 1973. Heaton is disabled, cannot
walk, and is on Medpay by the Canadian Government. He suffers from long-term
neurological injuries and cognitive difficulties, including, but not limited to
headaches, dizziness, and loss of memory.
Page 39: Plaintiff Troy Martin,
a.k.a. Shane Douglas (“Martin”) is 51 years old and resides in New Brighton,
Pennsylvania. He wrestled for WWE in 1990-1991 and became a headliner and
champion for another wrestling promotion called ECW that was later acquired by
WWE. Because of his success in ECW the WWE hired him in 1995 and recast him as
a college dean called “Dean Douglas.” The recast of his gimmick was significant
as it altered his image as a serious wrestler. As one wrestling writer
explains: “It was little surprise to most that Martin became the latest talented
performer to be saddled with a no-hype gimmick that seemed almost designed to
mock the performer…. Just a year earlier he was considered one of the cutting
edge talents in the business, but the Shane Douglas character had been
swallowed up by the WWF machine and remolded to their liking.” [ Dixon, James,
“Titan Sinking: The Decline of the WWF in 1995”, 126 (Dixon/History of
Wrestling Publishing 2014).] Martin has suffered routine, repeated, and chronic
head trauma resulting in long-term neurological injuries and cognitive
difficulties from the WWE, including, but not limited to, headaches, dizziness,
loss of memory, and fatigue.
Notes: WWE Runs: Aug 1995-Nov
1995; June 1990-August 1991; jobs in 1986
Page 39-40: Plaintiff
Marc Copani, a.k.a. Muhammad Hassan (“Copani”) is 34 years old and resides in
Liverpool, New York. He wrestled for WWE from 2004 to 2005, wrestling at least
four days a week for most of that time. Copani, an Italian, became one of the
most hated “heels” in the WWE being cast as an Arab-American Muslim who had
hooded henchman attend to him. His career ended with the July, 2005 London
Terrorist bombings when it became politically unpopular for the WWE to continue
this gimmick. He was told he would be “taking time off” before he was finally
released. He sustained numerous injuries while at WWE, including hitting the
back of his neck when he went through the stage as part of a storyline. Copani
was knocked in the head with closed fist punches and was knocked out at least
twice with little to no intervention by WWE medical staff who were in
attendance. Copani states that you “wrestled through injuries” at WWE otherwise
you would “lose your spot” and be “subjected to ridicule.” Copani has suffered
routine, repeated, and chronic head trauma resulting in long-term neurological
injuries and cognitive difficulties from his tenure at WWE, including, but not
limited to, depression, headaches, dizziness, loss of memory, and fatigue.
Page 137: A case in
point is Plaintiff Mark Copani (scripted as Muhammad Hassan). He was given a
“push” as a Muslim American (he is Italian) and scripted for a match with the
“Undertaker” then WWE’s biggest star on 6/28/05. His character was introduced
with the Muslim “call to prayer” and he wore a Middle Eastern costume
appropriate to his character, including a prayer rug. Mr. Copani was
accompanied by several “henchmen” supplied by WWE in black hoods who attacked
other wrestlers as a part of the show. The WWE established Hassan as a hated
figure in order to sell tickets. However, in July of 2005 after the terrorist
bombing in London which killed 52 people, Mr. Copani’s character became
politically incorrect and he was told by WWE that he was being put on leave. He
was terminated several months later, and his career ended – all at the control
of the WWE.
Notes: OVW:
2002-2004; WWE: 2004-2005
Page
40: Plaintiff Mark Canterbury, a.k.a. Henry Godwin (“Canterbury”) is 51 years
old and resides in Lindside, West Virginia. He wrestled for WWE from 1994-1999.
Canterbury was given the gimmick of Arkansan pig farmer who carried a bucket of
slop that he would throw at his opponents including in an “Arkansas Hog Pen
Match.” The cartoonish nature of this did not diminish the dangers faced in
WWE. In fact, Canterbury fractured his neck in 1998 on Monday Night Raw after
he was instructed by WWE staff against his objections to perform a dangerous
flip called a Doomsday Device which resulted in a mouthful of broken teeth and
a fractured C7 vertebrae. He made a brief return after his surgery. He alleges
he sustained at least three major concussions in WWE. Canterbury has suffered
routine, repeated, and chronic head trauma resulting in long-term neurological
injuries and cognitive difficulties from the WWE, including, but not limited
to, headaches, dizziness, loss of memory, and fatigue. He is currently on SSDI
from his broken neck, back issues and inability to work.
Notes: Last WWE Run: with Ray Gordy in March
2007; Nov 1994-Sept 1998
Page 40-41: Plaintiff Victoria Vickie Otis, a.k.a.
Princess Victoria (“Otis”) is 53 years old and resides in Pasco, Washington.
She has an eighth grade education and began wrestling at age 18. There was a
“code of silence” in wrestling “you keep your mouth shut be it injuries or what
income you earned.” Otis wrestled for WWE in 1983 and 1984. She was knocked out
several times and would throw up after the incidents. She was seriously injured
in the WWE ring, including when she landed on the top of her head in September,
1984 in Philadelphia, where she felt an “ungodly pain and tingling from head to
her toes” after the match. She went to the hospital and it was discovered she
had cracked two vertebrae in her neck. She was advised to have surgery but
could not afford it. She was told by the WWE booking agent to “take a break”
and “see how things went.” She never returned. She suffers from neck injuries,
reduced range of motion, long-term neurological injuries and cognitive
difficulties, including, but not limited to headaches, memory loss, insomnia
and trouble sleeping. She is applying for disability, has no insurance and
receives no royalties from WWE.
Plaintiff Judy Hardee, a.k.a. Judy
Martin (“Hardee”) is 60 years old and resides in Gaston, South Carolina. Hardee
wrestled for WWE from 1979-1989 and was one of the most successful female
wrestlers of her era. Like other wrestlers at the time, her career at WWE was
tightly controlled by Fabulous Moolah (Mary Lillian Ellison). Hardee was paid
in cash and paid her own taxes during her tenure at WWE. Hardee states: “If you
were hurt you had go in the ring, the show must go on.” In a WWE show in
Hartford, Connecticut she was hit in the head with a metal chair by Moolah.
Hardee was bleeding and was told by Moolah “you’ll be alright,” however Pat
Patterson a WWE agent who had recruited her into WWE insisted she go to the
local emergency room where she received 13 stitches. Hardee was often injured
while wrestling, including taking bumps and falls on hard rings, hitting
turnbuckles to which she attributes her back injuries which required surgery in
1998. Hardee suffers from long-term neurological injuries and cognitive difficulties,
including, but not limited to, headaches, loss of memory and difficulty
sleeping. Hardee has her own insurance from her job working in a hospital, and
attributes most of her injuries to her wrestling career. Hardee was paid a WWE
royalty check of $40 in the past few years and receives letters from WWE
offering drug and alcohol treatment.
Notes: Last WWE run: ended June 1989
Page 41-42: Plaintiff Mark Jindrak is 38 years old
and a resident of Rochester, New York (currently living in Mexico City). He
wrestled for WWE from 2001 to 2005. At one point he was cast with a
narcissistic gimmick that depicted himself as obsessed with his own physique
and was told to call himself "The Reflection of Perfection." He
sustained numerous head injuries in the WWE. For example, in 2004 he was
involved in a botched move with Scot Renald Garland a.k.a. Scotty 2 Hotty,
which resulted in a concussion, after which there was no head check or medical
evaluation of any kind. In 2004, he was kicked in the head where he sustained
head trauma with little to no intervention or evaluation by WWE staff. Jindrak
states “After the match the guys were joking about ‘having your bell rung like
that’ including jokes from WWE officials.” Jindrak states that “at WWE there
was no test, no evaluation, no doctor, not smelling salts, there was no follow-up
on concussions or anything else.” A few weeks before he was released from WWE his
head was slammed into an unpadded barrier made of metal- “it was a hard blow
and I was bleeding pretty good.” After the match a WWE trainer closed the wound
with glue but never checked for a concussion or had a doctor or medical
evaluation. He explains: "I was not vocal in follows ups because it was
not the WWE mentality, if you got injured you were a ‘pussy’ if you requested
any help you would lose work dates in the WWE.” Jindrak alleges he has suffered
routine, repeated, and chronic head trauma resulting in long term neurological
injuries and cognitive difficulties from the WWE, including, but not limited
to, difficulty sleeping, headaches, dizziness, loss of memory, and fatigue. He
continued his career in wrestling in Mexico where he indicates the working
conditions and health and safety practices for professional wrestlers are far
more advanced than in the WWE.
Notes: Last WWE Run: July 2001 - June 2005;
current CMLL
Page 42-43: Plaintiff Bernard Knighton (father of
deceased), Estate of Brian Knighton, a.k.a. Axl Rotten (“Knighton”) represents
a 44-year-old retired wrestler who resided in Berlin, Maryland. Knighton
wrestled for WWE in 2005 when the WWE acquired another wrestling organization
called Extreme Championship Wrestling (“ECW”). The ECW promoted an extreme
style of wrestling which featured “hardcore” matches. Hardcore wrestling
involves more lax rules (or no rules) and often features unusual environments
such as ladders, tables and chairs as well as the use of objects to strike the
participants. Shortly before his death Knighton been in assisted living and
confined to a wheelchair while recovering from back surgery. Knighton has gone
through WWE’s Rehab Wellness Program in 2009 for a thirty-day detox, and upon
information and belief was told by WWE staff that administers the drug and
alcohol program that he could not return to the program again because of his
limited WWE career. Knighton was thus shut out of future WWE rehab by the
unilaterally administered WWE drug and alcohol program. After retaining counsel
to investigate his claims, Knighton died of a drug overdose on February 4, 2016
in a McDonalds in Maryland. Knighton suffered numerous and repeated head
injuries during his WWE career and suffered from neurological injuries and
cognitive difficulties, including, but not limited to, headaches, dizziness,
loss of memory. Knighton’s brain tissues are being analyzed by Dr. Bennett
Omalu for evidence of CTE.
Page 169-170: COUNT
VI: WRONGFUL DEATH AND SURVIVAL ACTIONS
(Bernard Knighton, as Personal
Representative of Brian Knighton’s Estate, Against the WWE)
Plaintiffs
incorporate by reference all preceding paragraphs above as if fully set forth
herein, including all exhibits referenced. Plaintiffs incorporate by reference
all preceding paragraphs above as if fully set forth herein, including all
exhibits referenced. Plaintiffs and their respective Executors or equivalent
legal representatives under applicable state law (hereinafter “Executors”)
incorporate by reference the preceding paragraphs set forth above as if fully
set forth herein.
The Plaintiffs’ legal representatives
bring this action in their representative capacity of the decedent’s Estate and
next of kin and on behalf of the respective survivors of those Plaintiffs. As a
direct and proximate cause of the conduct alleged herein, the WWE caused the
Plaintiffs to develop the debilitating brain diseases and conditions set forth
above, which diseases and conditions caused extreme pain, suffering, and
anguish and, ultimately, the deaths of some Plaintiffs. The legal
representatives of the deceased Plaintiffs claim damages recoverable under
applicable law for all pecuniary and non-pecuniary losses suffered by the
deceased Plaintiffs by reason of their deaths. As a direct and proximate result
of the untimely deaths of the Plaintiffs, their respective survivors and/or
surviving distributees have been deprived of the earnings, maintenance,
guidance, support and comfort that they would have received from for the rest
of the respective Plaintiffs’ natural lives, and have suffered commensurate
pecuniary and nonpecuniary losses because of the Plaintiffs’ wrongful deaths.
The Plaintiffs’ legal representatives claim the full measure of damages allowed
under applicable law.
Page 43-44: Plaintiff Marty Jannetty
(“Jannetty”) is 55 years old and resides in Columbus, Georgia. He wrestled for
WWF from 1988 to 1993 though he continued to wrestle part-time for WWF for twenty
years. He wrestled more than 300 shows per year for WWF and twice on weekends.
He suffered numerous high-profile injuries during his performances. He asserts
WWE sometimes had doctors who mostly distributed drugs. “Generally we had to
take care of ourselves, I would help other guys pop shoulders back into place.”
Jannetty described WWE as a place where ‘You lick your own wounds.” That the
medical treatment provided was mostly ‘tape and go.’ According to Jannetty the
WWE trainers, agents and writers were well aware of each wrestler’s injuries
and wrestlers often conferred amongst themselves and WWE staff about the
injuries so they “could work around them.” This “working around” was the
preferred and commonplace method of dealing with injuries rather than seeking
medical treatment. Jannetty says he was never treated for concussions or head
injuries, and that it was commonplace to experience a momentary loss of
consciousness in the ring from a move. Closed fist punches occur regularly,
many guys threw them “stiff” because they were unskilled and could not properly
pull them. Jannetty alleges he was knocked out by Kevin Nash in February 1994,
when the WWF referee - Joe Maranalla - woke him up and told him he had been
knocked out. There was no medical intervention by WWE doctors or staff.
Jannetty was forced of his own accord to leave the tour because he was so dizzy
he could not walk very well. As a direct result of leaving the wrestling tour
due to the undiagnosed signs and symptoms of severe head trauma, Jannetty lost
his job and suffered economic harm. He was later rehired. Jannetty was treated
in WWE sponsored alcohol rehab in October of 2014 and was told that he was
self-medicating because of all of his serious injuries. Jannetty cannot walk
very well because of injuries to his ankles. In March, 2015 he spoke to Anne
Russo who he identifies as a WWE employee in the Wellness department and asked
about getting help for medical treatment. He asserts he was told by WWE, “if we
did it for you we would have to do it for everybody.” Jannetty suffers obvious
impairments from being knocked unconscious numerous times. Jannetty has black
outs throughout the day where he suffers confusion and is unaware of his
surroundings. Jannetty has suffered routine, repeated, and chronic head trauma
resulting in long-term neurological injuries and cognitive difficulties,
including, but not limited to, headaches, dizziness, loss of memory, and
fatigue. He has no health insurance and is attempting to acquire disability
coverage.
Notes: last WWE run: ended Dec
1996; several one-offs matches in 2005/2007/2009
Page 44-45: Plaintiff Jon Heidenreich
(“Heidenreich”) 6’7” 300 pounds, is 44 years old and resides in Picayune,
Mississippi. Heidenreich wrestled for WWE from 2003 to 2006 as a Tag Team
Champion and wrestled in Pay-Per-Views and main events with wrestlers such as
the Undertaker. Heidenreich has been injured countless times and knocked out
frequently in WWE events. He was treated by a WWE employee Dr. Rios who was one
of the few doctors he has seen in his life. He characterizes the travel
schedule as “insane, wrestling hundreds of night per year”, “you work nonstop
so there is no time to heal.” Heidenreich bears the marks of his career and has
a large permanent knot/cyst the size of baseball on his forehead. Heidenreich
sustained numerous repeated and chronic head trauma resulting in severe
neurological injuries and cognitive difficulties, including, but not limited
to, headaches, dizziness, loss of memory, severe depression, loss of ability to
work, and fatigue. Heidenreich has been suicidal and has received treatment for
his condition. Heidenreich also has congestive heart failure. Heidenreich says
that cannot work and will stay in bed sometimes four to five days at a time,
and has seen psychiatrists for severe depression. He has no health insurance
and is currently applying for disability. He received his last royalty check
from the WWE in 2015 for $130.
Notes: Last WWE Run: May 2003-Jan
2006
Page 45: Plaintiff Terry Scott Szopinski, a.k.a.
The Warlord (“Szopinski”) is 53 years old and resides in Pompano Beach,
Florida. Szopinski wrestled for WWE from 1988 to 1992 with The Barbarian (named
Plaintiff Sione Havea Vailahi) as part of the popular Tag Team “Powers of
Pain.” He described the WWE performance schedule as “full time and rigorous”
and performed over 300 shows per year. Szopinski was routinely injured in WWE
events and had his bell rung on many occasions. Szopinski suffered numerous and
repeated head injuries resulting in neurological injuries and cognitive
difficulties, including, but not limited to, headaches, dizziness, loss of
memory, and fatigue. Szopinski has no health insurance, and works as a bouncer
in a nightclub.
Notes: Last WWE Run: June 1988 - April 1992
·
SIONE
HAVEA VAILAHI, a.k.a. The Barbarian
Plaintiff Sione Havea Vailahi, a.k.a.
The Barbarian (“Vailahi”) is 57 years old and resides in Charlotte, North
Carolina. He wrestled for WWE from 1988 to 1992 and from 1994 to 1995 as a
high-profile performer with named Plaintiff Terry Scott Szopinski in a tag team
called “Powers of Pain.” He wrestled as his partner more than 300 nights per
year and “worked like a horse.” Vailahi’s finishing move was a dive that he hit
his opponents with night after night, that he alleges resulted in nerve damage
and occupational injuries. Vailahi has neck and back injuries and was hit in
the head with steel chairs resulting in ‘blackouts’ while at WWE. Vailahi
suffered numerous and repeated head injuries in WWE resulting in neurological
injury and cognitive difficulties, including, but not limited to, headaches,
dizziness with loss of consciousness, loss of memory, and fatigue.
Notes: Last WWE Run: June
1994-June 1995; June 1988-Feb 1992
Page
98: Plaintiff Larry Oliver, a.k.a. Rip “The Crippler” Oliver (“Oliver”) is 63
years old and resides in Homosassa, Florida. He wrestled for WWF from 1987 to
1988 and has had both knees replaced along with neck surgery, having suffered
spinal injuries while wrestling. Oliver states he was flown by WWE to
Sacramento California to wrestle the Ultimate Warrior in 1988, and that “I gave
them my body to put him over and he tried to take my head off with a real
clothesline.” Oliver sustained serious neck injuries in consequence of his WWE
appearances. Oliver has been deemed federally disabled since 2000 and is on
Medicare/Medicaid and SSDI. Oliver has been referred to a psychiatrist for
depression, memory loss, and inability to sleep. As a result of the routine,
repeated, and sustained head trauma, Oliver suffers from neurological injury
and cognitive difficulties, including, but not limited to, headaches,
dizziness, loss of memory, insomnia, and fatigue. Additionally, Oliver was
diagnosed with Alzheimer’s disease and is prescribed Donepezil.
Notes: Last WWE Run: November 1988
Plaintiff
Bobbi Billard (“Billard”) is 40 years old and lives in Las Vegas, Nevada. She
injured her neck in WWE’s women’s wrestling developmental program in 2003-2004.
Billard wrestled eight hours a day and had her neck fused in 2004. Billard
states that the WWE treated her injury with disdain, criticizing her as “afraid
of breaking a fingernail.” As a result of the repeated and chronic head trauma
she sustained while wrestling for WWE, Billard suffers from neurological injury
and cognitive difficulties, including, but not limited to, headaches,
dizziness, and loss of memory, depression and fatigue.
Notes: Trained in OVW in 2003-2004
Plaintiff
Timothy Smith, a.k.a. Rex King (“Smith”) is 54 years old and resides in
Mulberry, Florida. He wrestled for WWF starting 1993 as part of the Tag Team
“Well Dunn.” Smith says that the WWE culture was “Keep your mouth shut and ears
open.” As soon as he was recruited into WWE on Friday, October 13, 1993, he was
injured by a 500-pound wrestler, Nelson Frazier, Jr. in a power slam: “He
crushed me - I was black and blue above my knees to shoulders, I could barely
move or walk. There was no ambulance - two guys carried me into the locker
room.” The WWE road agent present, Chief Jay Strongbow, called him an
ambulance. Smith later learned that his pelvis had been crushed and no surgery
could aid because the cartilage had been separated. He was out of work for nine
months. He was told by WWE employee, JJ. Dillon, that he would be paid $500 per
week. Smith says received exactly one check, when he called to locate his
additional checks he was told by Mr. Dillon “the emperor says he cannot afford
to pay you for doing nothing.” Smith's understanding was that the term “The
Emperor” was a reference to VKM. Smith says there was little attention paid to
him by WWE medical staff or treatment rendered and that he was “hit over the
head all the time,” hit with chairs, pushed through tables, and sometimes he
would wake up in the ring and not know where he was or why he was there. Smith
walks with a cane, having had his hip replaced and three discs herniated in his
neck from his wrestling career. Smith’s tag team partner, Steve Doll, died in
2009. Smith has suffered countless, repeated, and chronic head trauma resulting
in long-term neurological injuries and cognitive difficulties, including, but
not limited to headaches, dizziness, loss of memory, severe suicidal
depression, and fatigue. He has been on SSDI for past five years. The WWE pays
him meager royalties, with his last check totaling $55.
Page 129: Timothy Smith (a.k.a. Ref
King) alleges that this WWF culture was “keep your mouth shut”. He was informed
by older wrestlers when he stated with WWF that if he spoke up and didn’t
follow orders he would be considered a “trouble maker”, “squashed” (i.e.
physically hurt) in the ring, then fired.
Notes: Last WWE Run: June 1993-April
1995; jobs in Dec 1987-March 1988
Page 48: Plaintiff Tracy Smothers (“Smothers”),
a.k.a. Freddie Joe Floyd is 53 years old and resides in Fort Branch, Indiana. A
storied performer who spent most of his career outside of the WWE, Smothers was
recruited in 1996 to provide needed experience to a struggling roster. Smothers
was given the gimmick Freddie Joe Floyd, the name was a inside joke on rival
promoters whose organization was absorbed into the WWE, the gimmick itself was
“to depict a dim-witted southern yokel.” Smothers described WWE as a very political
place in which the staff played “mind games” and fostered a coercive culture in
which you had to watch what you said and could not report injuries for fear of
retribution: losing your job. Smothers, described a basic flat back bump,
correctly performed by an experienced wrestler as being in his experience the
equivalent of being rear ended in a low impact automobile accident. Smothers
returned to WWE in 2000 and worked for over a year as a wrestler/trainer in
Memphis. In one instance, Smothers states that a wrestler named Joey Abs (Jason
Arhndt) was instructed by WWE agents to hit him over the head with a steel
chair as the finish to a match. The blow “nailed me” and “I was knocked out” he
reportedly was throwing up for days and experienced dizziness for up to 6 weeks
after the incident until he was fired in the aftermath of his symptoms.
Smothers described the WWE training staff as abusive, ignorant of any medical
protocols, in wrestling “you became your own doctor.” During his WWE experience
he suffered countless repeated head trauma and sustained neurological injuries
and cognitive difficulties, including, but not limited to, headaches,
dizziness/loss of balance, and acute short term loss of memory. Smothers has no
health insurance, receives no royalties but does receive annual letters from
the WWE offering drug and alcohol rehabilitation.
Page
137-138: Plaintiff Tracy Smothers (Screen name Freddie Joe Floyd) was a
well-regarded wrestler who worked very hard at conditioning and developing his
in the ring athletic abilities. He was branded by Vince McMahon, WWE’s “boss”
as a cartoon type character, a preposterous persona McMahon wanted to explore.
Tracy Smothers’ career was injured and he was terminated because the “buffoon”
gimmick didn’t catch on with the fans.
Page 49: Plaintiff Michael Robert
Halac, a.k.a. Mantaur (“Halac”) at 6” 1’ 400 pounds is 47 years old and resides
in Omaha, Nebraska. He wrestled for WWE from 1995 to 1997. His assigned gimmick
was to be a half man, half bull and to act like an animal. It was not a popular
character with one writer observing the idea was “consigned to the annals of
history as another failed career-killing experiment born from the mind of Vince
McMahon.”[Dixon, James, “Titan Sinking: The Decline of the WWF in 1995”, 57
(Dixon/History of Wrestling Pub., 2014).] Halac explains he did as he was told,
“shut your mouth and keep your ears open that's how it was.” Halac alleges he
had many events consistent with a concussion in WWF. He sustained serious
injuries in WWE such as landing on his head on metal stairs when his whole body
went numb with little to no intervention or treatment by WWE staff, in that
incident Halac injured his neck, spine and back. Today discs two through six are
fused. Noting that if he wanted to be paid, he had to fight through the pain
and wrestle despite his severe injuries. Halac suffered repeated and chronic
head trauma resulting in neurological injury and cognitive difficulties,
including, but not limited to, headaches, dizziness, loss of memory, and
fatigue. He takes pain medication every day, has half range motion in his neck,
cannot feel his arms or fingers and is having surgery to restore sensation.
Halac cannot work, has insurance through Medicaid, and recently received his
first SSDI disability check. Halac received a WWE royalty check of $105 in
November 2015.
Notes: last WWE appearances: 6/97
(as Tank in Truth Commission); Aug 1994-June 1995
Page 49-50: Plaintiff Rick Jones, a.k.a. Black Bart
(“Jones”) is 67 and resides in Weatherford, Texas. He wrestled for WWF in 1989
for a little over a year, including performing in WrestleMania IV. Although
Jones spent most of his career outside of WWE, he says wrestling in the WWE was
more intense, with more pressure to aggressively perform than at other
promotions. Jones was given the gimmick of being a “bad cowboy” with a black
hat and long beard by Dusty Rhodes and was given the name “Black Bart” by WWE
as Vince McMahon wanted to “own your name.” Jones explains that “you kept your
mouth shut, put guys over and don’t complain about injuries or anything else”
or you would be fired. Jones explained: “If you were sick or hurt, you vanished
form the booking sheet, if you were not on the sheet you didn't get paid.” In a
WWE appearance at Madison Square Garden (he believes in 1991) while wrestling
Koko B. Ware in a strong finish “I felt my back go out in the arena, “to which
Jones attributes a permanent back injury. He sustained numerous head injuries
which were simply called “bell ringing.” While in WWE Jones was knocked
unconscious at least three times by another wrestler named Tugboat (Fred
Ottman). Tugboat was large wrestler who worked “stiff” and “knocked me out
colder than a witch” after taking a clothesline, Jones woke up in the locker
room. On another occasion Jones hit his head on pavement outside the ring.
Jones observed that there were WWE trainers that performed basic tasks but
mostly looked out for bigger stars while he and most of the wresters were “on
our own.” Having sustained repeated and chronic head trauma wrestling for WWE,
Jones endures cognitive difficulties, including, but not limited to,
depression, headaches, severe dizziness, severe loss of memory. Jones states he
has involuntary muscle movements that are likely due to nerve damage and loss
of hearing for which he needs but cannot afford hearing aids. Jones has
received WWE letters offering drug and alcohol rehabilitation, Jones contacted
WWE staff sometime in 2015 to ask for help to pay for heart surgery that he
could not afford under his wife’s insurance plan, although WWE staff told him
that they would investigate options no one returned his call, he took medical
loans which he is struggling to pay. Jones is disabled and receives SSDI from
his past work as a construction foreman.
Page 60: Some report multiple performances per
night and in one instance, Named Plaintiff Rick Jones states he wrestled in 10
shows in a single night. The performance schedule is designed to maximize the
profits made by WWE, in reckless disregard of the welfare of the wrestlers.
Page 50-51: Plaintiff Ken Johnson, Sr.,
a.k.a. (“Johnson”) is 59 years old and resides in Louisville, Kentucky. Johnson
is currently a pastor at Shiloh Baptist church in Louisville with a
congregation of about 400 people. Johnson worked for WWE from 1986 to 1993, in which
he signed a contract without counsel that was offered on a “take it or leave
it” basis by Vince McMahon. Johnson did his own taxes and his income was
reported by WWE on 1099s. Johnson worked as a “manager.” A manager in the WWE
was part of the “storyline” in which he purported to represent certain wresters
as part of the act. Johnson was depicted as a stereotypical African American
and given the name “Slick” a “jive soul bro.” Johnson says the McMahon
instructed producers to focus on his lips when he appeared on television to do
his promos. During most of his tenure at WWE he worked over 300 nights per year
sometimes 30-40 nights straight with no breaks. Johnson as a “manager” never
received formal training how to properly perform wrestling moves in WWE but
“learned as he went.” Most often he was instructed after he took a bump or fell
improperly injuring himself, after the event someone would approach and tell
him “do it this way next time.” In 1987 in a match in Houston with Hulk Hogan
he fell through the ropes and was spitting up blood from internal injuries. On
another occasion in 1987 during a skit when a dog was chasing him, he fell and
broke his wrist. In 1989, he believes he had his “bell rung” after being body
slammed by George the Animal Steele, and that after the incident, Vince McMahon
sent someone to the ring to ask if he was ok. In another match Johnson was hit
in the head by Davy Boy Smith and was thrown over ropes onto the concrete below
in which he hit his head. Johnson sustained head trauma in WWE resulting in
cognitive difficulties, including, but not limited to, anxiety and mood swings,
headaches, dizziness, loss of memory, and difficulty sleeping. Johnson has no
health insurance and is forced to pay out-of-pocket for the medications he
needs for his diabetes and other health problems. WWE sends him letters
offering drug and alcohol rehabilitation, pays him about $200 in royalties each
year (in the past more) and as recently as April 2016 WWE paid Johnson $2,500
to induct a wrestler who died at age 41 “Big Bossman” in to the WWE Hall of
Fame.
Page 52: Plaintiff George Gray, a.k.a. One Man
Gang, a.k.a. Akeem (“Gray”), 6’7” and 400 pounds, is 55 and resides in Baton
Rouge, Louisiana. He wrestled for WWF full-time from 1988 to 1991. He performed
in three Wrestlemania events. He says “keep your mouth shut is the first rule
of the business, you keep quiet, keep your mouth shut and do what you are
supposed to do, if you talked you got pushed down in the card and made less
money.” His gimmick, “One Man Gang”, was akin to a motorcycle gang character
with a Mohawk, denim jacket, and skull jewelry. Vince McMahon called Gray and
told him his character was being remade as a black African, despite Gary being
white. He was rebranded “Akeem the African Dream.” In Gray’s words “a racially
stereotypical black guy.” Gray performed in shows with a burning trash barrel
that exploded and African tribal dancers jumping around him chanting “Akeem.”
Gary says that little to no medical attention was given to him. “If anything
happened to you, you were responsible for it. I traveled injured, at least 300
nights a year for WWE on the road.” He did not know what a concussion was, but
was punched, kicked, dropped on his head every night, “You got banged up every
day.” Gray alleges that he suffered many concussions in WWE events from being
knocked around in metal cages, punched in the head, hit with metal chairs, and
thrown head first into concrete. Gray never contemplated that his brain would
suffer long-term injury from the head trauma, and he continued to work injured
throughout his career. Gray suffers from the routine and repeated head trauma
endured during his WWE career with neurological injuries and cognitive
difficulties, including, but not limited to, headaches, dizziness, loss of
memory, and fatigue. He cannot stand for any period due to neck and back
injuries and has never had a brain test because he cannot afford it. He is
currently uninsured and disabled on Medicare with herniated discs in his neck
and back.
Page 129-130: George Gray (a.k.a. “One Man
Gang”) alleges that “keep your mouth shut is [the] first rule of the business”.
If you wanted to wrestle, you didn’t ask questions or you would be pushed down
in the card and make less money. Chairman McMahon personally remade his
character to “Akeem the African Dream” and required he dress in a yellow
Dashiki as a racially stereotypical black, complete with tribal dancers
supplied by WWE. Mr. Gray is Caucasian;
Notes: Last WWE Run: May 1987-Jan 1990;
one-off in 1998 & WM X-7
Page 53: Plaintiff Ferrin Jesse Barr,
a.k.a. JJ Funk (“Barr”) is 55 and resides in Vancouver, Washington. He wrestled
for WWE from 1986 to 1987. Barr says if you asked questions about pay or travel
you would get “bad bookings” and lose money. He was fined for being late even
though he was on time to perform, after he was delayed due to an accident on
the highway he was traveling on that delayed traffic. Barr was knocked
unconscious numerous times, it would be common to be hit seeing stars, as well
as kicked and punched in the head because WWE’s choreographing required the
action to seem as real as possible. According to Barr, sometimes punches called
potatoes landed because they were accidental or some people were not skilled.
Barr had to work through the injuries: “you had no choice but to work through
injuries if you wanted to get paid.” Barr tore his ACL and was told to perform
by taping it up from his foot to hip with four rolls of tape each night rather
than have time off to properly heal. Barr was injured by another WWE wrestler
intervening in a fight outside the ring, being kicked in the head causing his
eye to fall out due to orbital bone fractures. Barr suffered repeated and
chronic head trauma from WWE events including being hit in the head with metal
chairs resulting in cognitive difficulties, including, but not limited to,
headaches, dizziness, loss of memory, mood swings, and fatigue. Barr has a neck
fusion (discs four and five) from his career.
Notes: last WWE Run: April
1986-June 1987
Page 53-54: Plaintiff Lou Marconi (“Marconi”) is 42
years old and resides in Willow Spring, North Carolina. Marconi wrestled 10 to
15 times per year for the WWE between 1994 and 2000. During his matches, he was
used as “enhancement talent” to make the other full time WWE wrestlers look
good at his expense and the expense of his body. Marconi alleges that wrestlers
such as himself that were not on the WWE full time roster were subjected to
more harsh, less careful treatment than regular WWE performers. He states he sustained
what he alleges were at many concussions in WWE (although in his early 20s at
the time, he did not know what a concussion was), he recalls seeing ‘white
flashes’ after hitting his head or was knocked out. For example, in October,
1996, he was clotheslined by Stone Cold Steve Austin in Ohio resulting in head
injury for which he received no medical attention. Marconi sustained routine,
repeated, and chronic head trauma resulting in long-term neurological injuries
and cognitive difficulties, including, but not limited to, headaches, memory
loss, hearing loss in right ear due to nerve damage.
Page 54: Plaintiff Rod Price (“Price”) is 54
years old and resides in Ponchatoula, Louisiana. He wrestled for WWE in 1992,
1994, 1996 as enhancement talent. According to Price the wrestlers that
performed “jobs” such as himself were routinely subjected to physical abuse at
the hands of more experienced and regular WWE performers, as his health and
safety was given even less of a priority than full time WWE wrestlers. He
states he had numerous head injuries in WWE events and sustained routine,
repeated, and chronic head trauma resulting in long-term neurological injuries
and cognitive difficulties, including, but not limited to, headaches,
depression, insomnia, hearing loss in left ear, memory loss. Price is currently
on Medicaid and social security disability
Page 54: Plaintiff Donald Driggers (“Driggers”)
is 54 years old and lives in Columbia, South Carolina. He wrestled as
“enhancement talent” for WWF between 1985 and 1987 performing in dozens of
matches. He wrestled Hercules, Rick Rude, Bret Hart and many top performers in
WWF. As enhancement talent his job was to make other wrestlers “look good” and
he sustained many head injuries in the process. Driggers has suffered routine,
repeated, and chronic head trauma resulting in long-term neurological injuries
and cognitive difficulties, including, but not limited to depression,
headaches, dizziness, loss of memory, and fatigue. Driggers is currently
applying for SSDI.
Page 55: Plaintiff Rodney Begnaud, a.k.a. Rodney
Mack (“Begnaud”) is 45 and resides in Lafayette, Louisiana. Begnaud wrestled
for WWE from 2002 to 2005. His WWE assigned gimmick was to portray himself as
an “anti-white” black militant. Begnaud explains it “was a ‘no no’ to discuss
injuries or your job would be in jeopardy.” His dialogue consisted of lines
such as “Damn Right!” and “Yeah!” with his manager uttering lines such as “Kill
Whitey” and “Free James Brown.” He says he was not treated for injuries or
tested for signs of head injuries after sustaining blows to his head them in
the ring. Begnaud has suffered numerous concussions as a result of the repeated
and chronic head trauma sustained while wrestling for WWE. His injuries have
resulted in long-term neurological injuries and cognitive difficulties,
including, but not limited to, headaches, dizziness, loss of memory, and
fatigue.
Notes: Last WWE Run: Sept 2006-November 2006
(ECW), Oct 2002-November 2004
Page 55: Plaintiff Ronald Heard, a.k.a.
Outlaw Ron Bass (“Heard”) is 67 years old and resides in Thonotosassa, Florida.
Heard wrestled for WWE in 1987 to 1989. Heard states that he was hit in the
head with tables and chairs, and had bumps performed on him on concrete. Heard
suffered routine, repeated and sustained head trauma in WWE matches resulting
in long-term neurological injuries and cognitive difficulties, including, but
not limited to, headaches and migraines, dizziness, loss of memory, and
sleeping problems. Heard has received royalties from the WWE in past few years
of between and $50 and $100. Heard is currently on Medicare.
Notes: Last WWE Run: January
1987-March 1989
Page 55-56: Plaintiff Boris Zhukov (“Zhukov”) is 57
and resides in Wirtz, Virginia. He started wrestling for WWF in September of
1987 until December 1990 and performed in the WWE headline event Wrestlemania
IV and VI. Zhukov estimates he wrestled 275-300 nights per year while at WWE.
Zhukov’s gimmick was that of a Russian Communist from the Soviet Union and
teamed with another wrestler to form a tag team called the Bolsheviks. Zhukov’s
birth name was James Harrell and he is of English/Irish descent. Upon entry
into the WWE he legally changed his name to Boris Zhukov, he did so because the
WWE and Vince McMahon he learned would “own you” if you didn't do this. When
Vince McMahon learned that he was legally Boris Zhukov he says it caused much
friction and accounts for his failure to get a “Push” in WWE. He signed the
boiler plate booking contract which “you had to sign if you wanted to work,”
and his income was reported on 1099s by WWE. Zhukov says that “you had to watch
what you say” about injuries and compensation or you would be “going out the
door,” and “blackballed.” Zhukov says that shortly after the cold war ended and
the Berlin wall was torn down his career effectively ended as he was informed
by WWE that there was no need for a Russian gimmick any longer. Zhukov states
he sustained head injuries many times performing in the WWE and sustained other
injuries while with the organization. Zhukov says that regularly and correctly
performed moves in WWE required him to hit his head “very hard on the ring
floor.” He was treated by WWE and hospitalized for an infection he acquired in
the ring. He has cognitive difficulties, including, but not limited to,
migraine headaches, hearing loss, difficulty sleeping, depression/mood swings,
loss of balance and dizziness, as well as loss of memory. Zhukov was told by
his sports medicine doctor that these symptoms and conditions relate to head
trauma he sustained as a wrestler. He currently works as truck driver.
Notes: Last WWE Run: Nov 1990 / some shows in
Feb 1991
Last
in-ring match in WWE
2010s:
·
JOSEPH
M. LAURINAITIS, a.k.a. Road Warrior Animal
·
SALAVADOR
GUERRERO IV, a.k.a. Chavo Guerrero, Jr.
2000s:
·
JIMMY
"SUPERFLY" SNUKA, by and through his guardian, Carole Snuka
·
CHAVO
GUERRERO, SR., a.k.a. Chavo Classic
·
BRYAN
EMMETT CLARK, JR., a.k.a. Adam Bomb
·
JAMES
HARRIS, a.k.a. Kamala
·
DAVE
HEBNER
·
EARL
HEBNER
·
TERRY
MICHAEL BRUNK, a.k.a. Sabu
·
BARRY
DARSOW, a.k.a. Smash
·
JONATHAN
HUGGER a.k.a. Johnny The Bull
·
CARLENE
B. MOORE-BEGNAUD, a.k.a. Jazz
·
SYLVAIN
GRENIER
·
MARC
COPANI, a.k.a. Muhammad Hassan
·
MARK
CANTERBURY, a.k.a. Henry Godwin
·
MARK
JINDRAK
·
BERNARD
KNIGHTON as Personal Representative of the Brian Knighton, a.k.a. Axl Rotten,
Estate
·
MARTY
JANNETTY
·
JON
HEIDENREICH
·
BOBBI
BILLARD (OVW)
·
TRACY
SMOTHERS, a.k.a. Freddie Joe Floyd
·
GEORGE
GRAY, a.k.a. One Man Gang
·
LOU
MARCONI
·
RODNEY
BEGNAUD, a.k.a. Rodney Mack
1990s:
·
ANTHONY
NORRIS, a.k.a. Ahmed Johnson
·
CHRIS
PALLIES, a.k.a. King Kong Bundy
·
BILL
EADIE a.k.a. Ax
·
JOHN
NORD, a.k.a. The Bezerker
·
JAMES
BRUNZELL, a.k.a. Jumpin' Jim
·
JAMES
MANLEY, a.k.a. Jim Powers
·
MICHAEL
"MIKE" ENOS
·
OMAR
MIJARES a.k.a. Omar Atlas
·
TROY
MARTIN, a.k.a. Shane Douglas
·
TERRY
SZOPINSKI, a.k.a. The Warlord
·
SIONE
HAVEA VAILAHI, a.k.a. The Barbarian
·
TIMOTHY
SMITH, a.k.a. Rex King
·
MICHAEL
R HALAC, a.k.a. Mantaur
·
RICK
JONES, a.k.a. Black Bart
·
KEN
JOHNSON, a.k.a. Slick
·
ROD
PRICE
·
BORIS
ZHUKOV
1980s:
·
PAUL
ORDNDORFF, a.k.a. Mr. Wonderful
·
KEN
PATERA
·
SUSAN
GREEN, a.k.a. Sue Green
·
ANGELO
MOSCA, a.k.a. King Kong Mosca
·
BRUCE
"BUTCH" REED, a.k.a. The Natural
·
VICTORIA
OTIS, a.k.a. Princess Victoria
·
JUDY
HARDEE a.k.a. Judy Martin
·
LARRY
OLIVER, a.k.a. The Crippler
·
FERRIN
JESSE BARR, a.k.a. JJ Funk
·
DONALD
DRIGGERS
·
RONALD
SCOTT HEARD, a.k.a. Outlaw Ron Bass
1970s
·
DON
LEO HEATON, a.k.a. Don Leo Jonathan
