Plaintiffs in LAURINAITIS et la

·                  JOSEPH M. LAURINAITIS, a.k.a. Road Warrior Animal

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

·                  JIMMY “SUPERFLY” SNUKA, by and through his guardian, Carole Snuka

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

·                  PAUL ORDNDORFF, a.k.a. Mr. Wonderful

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

·                  SALAVADOR GUERRERO IV, a.k.a. Chavo Guerrero, Jr.

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

·                  CHAVO GUERRERO, SR., a.k.a. Chavo Classic

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

·                  BRYAN EMMETT CLARK, JR., a.k.a. Adam Bomb

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

                      

·                  ANTHONY NORRIS, a.k.a. Ahmed Johnson

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

·                  JAMES HARRIS, a.k.a. Kamala

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

·                  DAVE HEBNER

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.

·                  EARL HEBNER

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.

·                  CHRIS PALLIES, a.k.a. King Kong Bundy

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

·                  KEN PATERA

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

·                  BARRY DARSOW, a.k.a. Smash

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

·                  BILL EADIE a.k.a. Ax

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

·                  JOHN NORD, a.k.a. The Bezerker

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

·                  JONATHAN HUGGER a.k.a. Johnny The Bull

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

·                  JAMES BRUNZELL, a.k.a. Jumpin’ Jim

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

·                  SUSAN GREEN, a.k.a. Sue Green

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.

·                  ANGELO MOSCA, a.k.a. King Kong Mosca

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

·                  JAMES MANLEY, a.k.a. Jim Powers

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

·                  MICHAEL “MIKE” ENOS

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

·                  BRUCE “BUTCH” REED, a.k.a. The Natural

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

·                   CARLENE B. MOORE-BEGNAUD, a.k.a. Jazz

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

·                  SYLVAIN GRENIER

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

·                  OMAR MIJARES a.k.a. Omar Atlas

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.

·                  DON LEO HEATON, a.k.a. Don Leo Jonathan

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.

·                  TROY MARTIN, a.k.a. Shane Douglas

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

·                  MARC COPANI, a.k.a. Muhammad Hassan

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

·                  MARK CANTERBURY, a.k.a. Henry Godwin

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

·                  VICTORIA OTIS, a.k.a. Princess Victoria

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.

·                  JUDY HARDEE a.k.a. Judy Martin

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

·                  MARK JINDRAK

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

·                  BERNARD KNIGHTON as Personal Representative of the Brian Knighton, a.k.a. Axl Rotten, Estate

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.

·                  MARTY JANNETTY

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

·                  JON HEIDENREICH

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

·                  TERRY SZOPINSKI, a.k.a. The Warlord

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

·                  LARRY OLIVER, a.k.a. The Crippler

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

·                  BOBBI BILLIARD

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

·                  TIMOTHY SMITH, a.k.a. Rex King

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

·                  TRACY SMOTHERS, a.k.a. Freddie Joe Floyd

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.

·                  MICHAEL R HALAC, a.k.a. Mantaur

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

·                  RICK JONES, a.k.a. Black Bart

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.

·                  KEN JOHNSON, a.k.a. Slick

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.

·                  GEORGE GRAY, a.k.a. One Man Gang

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

·                  FERRIN JESSE BARR, a.k.a. JJ Funk

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

·                  LOU MARCONI

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.

·                  ROD PRICE

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

·                  DONALD DRIGGERS

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.

·                  RODNEY BEGNAUD, a.k.a. Rodney Mack

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

·                  RONALD SCOTT HEARD, a.k.a. Outlaw Ron Bass

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

·                  BORIS ZHUKOV

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