---
title: "WWE Parent Company TKO Issues Statement Addressing Vince McMahon Sex Trafficking & Abuse Allegations"
canonical: "https://wrestletalk.com/news/vince-mcmahon-sex-trafficking-abuse-wwe-parent-tko-statement/"
type: "post"
language: "en-US"
author: "Liam"
section: "News"
published: "2024-01-25T21:40:55Z"
modified: "2024-01-26T14:17:54Z"
---

# WWE Parent Company TKO Issues Statement Addressing Vince McMahon Sex Trafficking & Abuse Allegations

TKO, the parent company of WWE, has issued a statement addressing the allegations made against Vince McMahon in a lawsuit today.

**UPDATE: A statement has been made on behalf of Vince McMahon in response to the lawsuit – [read the latest at this link](https://wrestletalk.com/news/vince-mcmahon-responds-sex-trafficking-abuse-allegations/).**

The allegations included sexual trafficking, abuse and more. The full lawsuit can be read below.

McMahon currently serves as Executive Chairman of the Board for TKO.

In a statement to [Variety](https://variety.com/2024/biz/news/wwe-vince-mcmahon-sued-sexual-abuse-trafficking-1235887844/), a spokesperson for TKO said:

*“Mr McMahon does not control TKO nor does he oversee the day-to-day operations of WWE. While this matter predates our TKO executive team’s tenure at the company, we take Ms. Grant’s horrific allegations very seriously and are addressing this matter internally.”*

You can read the full lawsuit below. Please be advised its content is grossly disturbing.

**COMPLAINT**

*Plaintiff JANEL GRANT, by and through her undersigned counsel, hereby files this* *Complaint against Defendants WORLD WRESTLING ENTERTAINMENT, INC. n/k/a WORLD* *WRESTLING ENTERTAINMENT, LLC (“WWE” or the “Company”), VINCENT K.* *MCMAHON (“McMahon”), and JOHN LAURINAITIS (“Laurinaitis”), alleging as follows:*

***INTRODUCTION***

*1. Plaintiff Janel Grant is a former employee of WWE who was the victim of physical* *and emotional abuse, sexual assault and trafficking at WWE. Ms. Grant is filing this lawsuit not* *just to address her own suffering, but also to act for those who are afraid to speak out.*

*2. WWE’s billionaire Founder & Executive Chairman, Defendant Vincent K.* *McMahon, lived in a penthouse duplex in Ms. Grant’s apartment building.*

*3. The two met in March 2019, when Ms. Grant was dealing with profound grief and* *struggling financially – after devoting years to around-the-clock caregiving, her parents passed* *away. On top of that, she was unemployed and her family home was lost in her parents’* *bankruptcy.*

*4. After her family passed away, Ms. Grant dedicated herself to finding gainful* *employment. Neighbors in her building provided career advice and sought her assistance with* *personal events. Ms. Grant used these non-paying roles and volunteer work in community* *initiatives to build her resume.*

*5. The building’s Resident Manager wanted to help. She messaged McMahon to ask* *whether he would talk to her, sharing that Ms. Grant had been through hardship and would do* *great things if given a fresh start. McMahon enthusiastically responded, “Hell Yes!!”*

*6. McMahon befriended Ms. Grant, giving her hopes of a new life with promises of a* *yet-to-be-determined role at WWE, and showering her with attention and assurances, along with* *gifts like a VIP experience at WrestleMania. But what seemed like a dream in the Spring of 2019* *quickly became a nightmare.*

*7. As McMahon dangled career-making and life-changing promises in front of Ms.* *Grant, he demonstrated an increasing lack of boundaries. During several meetings that were* *ostensibly about a potential job at WWE, he greeted her in his underwear, touched her, repeatedly* *asked for hugs, and spent hours sharing intimate details about his personal life.*

*8. McMahon warned Ms. Grant to keep their “closeness” secret, lest rumors lead to* *public trouble – and added that, while he protects loyal people, he had world-class legal resources* *on speed-dial to deal with people who became a problem.*

*9. As such, when McMahon pushed Ms. Grant for a physical relationship in return for* *long-promised employment at WWE, she felt trapped in an impossible situation: submitting to* *McMahon’s sexual demands or facing ruin. Ms. Grant feared she had everything to lose and faced* *negative consequences no matter what happened.*

*10. After succumbing to the pressure for a physical relationship, Ms. Grant was slotted* *into an entry-level position as an “administrator-coordinator”—a position McMahon created for* *her in WWE’s legal department. Ms. Grant began work in that role on June 17, 2019.*

*11. Ms. Grant remained in that role, with the exception of a temporary relocation to* *XFL (Extreme Football League), until McMahon verbally directed her to transfer to the Talent* *Relations department, reporting to Defendant John Laurinaitis, on March 9, 2021. During a* *conversation the same day, McMahon explained that her presence in the legal department was* *effectively delaying efforts to hire a new General Counsel for the company.*

*12. McMahon and Laurinaitis informed Ms. Grant that she would be promoted to Vice* *President of Operations in the Talent Relations department, providing her with an organizational* *chart reflecting this decision.*

*13. Shortly thereafter, they informed her that they needed her to begin at a lower level* *as a director, but promised her promotion to Vice President after a 12-month period.*

*14. Despite Ms. Grant’s expressions of unhappiness and attempts to end the sexual* *relationship—and while she came to understand that McMahon expected the physical relationship* *to continue as part of her employment—she had no idea how sordid it would become, nor how the* *psychological torture and physical violence would leave her feeling helpless, isolated and trapped.*

*15. In March 2020, McMahon began sharing sexually explicit photographs and videos* *of Ms. Grant (including pornographic content he recorded) with other men both inside and outside* *the company, including with members of the television production “tech” team, executive(s),* *producer(s), and a world-famous athlete and former UFC Heavyweight Champion with whom* *WWE was actively trying to sign to a new contract (and ultimately did sign that contract).*

*16. Given McMahon’s omnipotent position at WWE, coercion was inherent in his* *increasingly depraved sexual demands. Specifically, while McMahon was CEO of WWE and Ms.* *Grant was employed as an entry level coordinator in the legal department, McMahon recruited* *individuals to have sexual relations with Ms. Grant and/or with the two of them, directed Ms. Grant* *to visit Defendant Laurinaitis prior to the start of workdays for sexual encounters, and expected* *and directed Ms. Grant to engage in sexual activity at the WWE headquarters, even during working* *hours.*

*17. All this time, McMahon ordered Ms. Grant to keep their relationship secret (unless* *otherwise instructed), including lying to maintain whatever cover stories he fabricated.*

*18. McMahon’s assurances that Ms. Grant was safe and independent rang hollow in* *light of his efforts to isolate her from friends and attempts to chip away at her identity until it was* *replaced with his desired role for her as his “bitch,” his “fantasy,” and/or his “porn star” (while* *occasionally intermixing softer descriptors like “girlfriend” and “baby,” even “love” when* *convenient). He exercised complete ownership and control over both her personal and* *professional lives.*

*19. McMahon also subjected Ms. Grant to acts of extreme cruelty and degradation that* *caused Ms. Grant to disassociate and/or become numb to reality in order to survive the horrific* *encounters.*

*20. As one example of McMahon’s extreme depravity, on May 9, 2020, he defecated* *on Ms. Grant during a threesome, and then commanded her to continue pleasuring his “friend”—* *with feces in her hair and running down her back—while McMahon went to the bathroom to* *shower off. Upon his return from the bathroom, McMahon and his “friend” actively resumed the* *threesome, which lasted over an hour and a half, while Ms. Grant remained covered in McMahon’s* *filth. When McMahon’s “friend” left, McMahon ordered her to stay and to continue to sexually* *gratify him.*

*21. In June 2021, McMahon and Defendant Laurinaitis sexually assaulted Ms. Grant* *inside Laurinaitis’ office in WWE headquarters while colleagues were busy at their desks. Behind* *a locked door, the two men cornered her and pulled her in between them, forcibly touched her,* *before ultimately putting her on top of a table in between them. She begged them to stop, but they* *forced themselves on her, each taking turns restraining her for the other, while saying “No means* *yes” and “Take it, bitch.”*

*22. Unsurprisingly, others at WWE knew what was going on. But instead of* *intervening to protect Ms. Grant, WWE actively sought to conceal the wrongdoing.*

*23. In January 2022, McMahon told Ms. Grant that his wife had found out about their* *relationship. Purportedly to avoid divorce, negative publicity, and other repercussions, McMahon* *said that Ms. Grant’s time at WWE was at an end, but that he wanted her to sign an NDA to ensure* *her silence on, among other things, his personal misconduct.*

*24. In the days ahead, McMahon put Ms. Grant under immense pressure to sign, saying* *that refusing would not only jeopardize McMahon, his family, and the company, but that she’d* *surely become a public headline, suffer reputational ruin (including from the pornographic content* *McMahon had captured), and face McMahon’s legal resources. Conversely, McMahon reassured* *her that her signature would ensure his continued support and protection and safeguard her* *reputation. Ultimately, Ms. Grant succumbed to the pressure and signed the NDA in exchange for* *payments – which McMahon later stopped making.*

*25. Even after pushing Ms. Grant out of the Company and muzzling her with an NDA,* *McMahon continued efforts to exploit her, including attempting to traffic her to a WWE star who* *would be in New York City for a live event and TV taping in March 2022.*

*26. Understandably, Defendants’ predatory conduct has left Ms. Grant crippled, both* *physically and mentally, including from debilitating symptoms of post-traumatic stress disorder* *and suicidal ideation. These symptoms led to her termination from her subsequent job running her* *building’s operations due to her inability to leave her home for weeks at a time.*

*27. Despite McMahon’s promise of reputational protection, WWE appears to have* *leaked information that led to the public disclosure of her name by a media blogger who cited “a* *source in #WWE with direct knowledge of the situation,” which, upon information and belief, was* *an overt intimidation tactic aimed at Ms. Grant.*

*28. WWE has also attempted to sweep the matter under the rug. Following media* *reports that McMahon was involved in a “hush money” payment scandal, WWE released a* *statement in June 2022 to announce that a special committee of its board of directors was* *investigating the alleged misconduct and appointing Stephanie McMahon as Interim CEO and* *Interim Chairwoman.*

*29. In this capacity, Ms. McMahon publicly affirmed her commitment to “doing* *everything in \[her\] power to help the Special Committee complete its work…and to implement its* *findings.” She also declared the “importance of a safe and collaborative workplace.”* *Notwithstanding this public statement, the investigation was a sham.*

*30. In November 2022, WWE touted the conclusion of the Special Committee* *investigation into the misconduct – yet the Special Committee never even bothered to interview* *Ms. Grant or request any documents despite Ms. Grant stating that she would cooperate.*

*31. In SEC filings, the Company tried to divert attention away from McMahon’s abuse* *of women by focusing on the technical issue of how hush money was accounted for—in the words* *of the Company, the issue was “immaterial accounting errors related to certain payments that Mr.* *McMahon . . . agreed to make during the period from 2006 through 2022” (emphasis added).*

*32. Through all this trauma, Ms. Grant has endured profound suffering in silence,* *feeling of exploitation, loss of security, and the fear of facing the wrath of WWE and McMahon’s* *army of attorneys if she were to come forward and bring to light the egregious acts detailed herein.* *That time has passed, and Ms. Grant seeks to hold Defendants accountable for their reprehensible* *and unlawful acts, for her own sake and for others.*

*33. Ms. Grant seeks a declaratory judgment that her NDA is invalid under Federal and* *State laws and asserts claims other laws, including the Trafficking Victims Protection Act.*

***PARTIES***

*34. Plaintiff JANEL GRANT, a Connecticut citizen, is a former employee of WWE,* *having worked there from June 2019 through March 2022.*

*35. Defendant VINCENT K. MCMAHON, a Connecticut citizen, co-founded WWE* *in 1980 and served on the board of directors of WWE from 1980 to September 2023. He is* *currently the Executive Chairman of the Board for TKO Group Holdings LLC.*

*36. Defendant WORLD WRESTLING ENTERTAINMENT, INC. n/k/a WORLD* *WRESTLING ENTERTAINMENT, LLC (“WWE”) is a Delaware limited liability company,* *whose sole managing member is TKO Group Holdings, Inc. (“TKO”), a Delaware corporation.* *Until on or about September 12, 2023, WWE was a Delaware corporation with headquarters in* *Connecticut.* *On September 12, 2023, a transaction completed between Endeavor Group Holdings* *and World Wrestling Entertainment, Inc., resulted in a merger between the WWE and Ultimate* *Fighting Championship (“UFC”) promotions and the formation of their new parent company,* *TKO.*

*37. Defendant JOHN LAURINAITIS, an Arizona citizen, is the former Head of Talent* *Relations and General Manager at WWE, who on information and belief was officially dismissed* *by WWE in August 2022 (amid allegations of misconduct by women in WWE).*

***NON-PARTY OFFICERS/EMPLOYEES OF WWE***

*38. At all times relevant, “WWE Corporate Officer No. 2” was a high-ranking* *employee at WWE who made hiring decisions, conducted prospective employee interviews, and* *maintained significant control over personnel decisions. WWE Corporate Officer No. 2 worked* *in these capacities during Ms. Grant’s employment with WWE. This individual is referred to* *herein as “WWE Corporate Officer No. 2.”*

*39. At all times relevant, “WWE Corporate Officer No. 1” was a high-ranking* *employee and Board member at WWE during Ms. Grant’s employment with WWE. WWE* *Corporate Officer No. 1 continued to work in high-ranking positions in connection with the* *September 12, 2023, merger. This individual is referred to herein as “WWE Corporate Officer* *No. 1.”*

*40. At all times relevant, “WWE Corporate Officer No. 3” was a high-ranking* *employee and/or Board member during Ms. Grant’s employment with WWE. This individual is* *referred to herein as “WWE Corporate Officer No. 3.”*

*41. At all times relevant, “WWE Corporate Officer No. 4” was a high-ranking* *employee at WWE who worked with legal affairs at the company. WWE Corporate Officer No.* *4 held that position from the time of Ms. Grant’s initial employment with WWE until sometime* *in 2020. This individual is referred to herein as “WWE Corporate Officer No. 4.”*

*42. “WWE Superstar” is a professional wrestling superstar who performs at WWE branded wrestling events. During the time of Ms. Grant’s employment, McMahon signed WWE* *Superstar to a new Booking Contract with WWE. This individual is referred to herein as “WWE* *Superstar.”*

***JURISDICTION AND VENUE***

*43. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 because* *Ms. Grant’s claims under the Trafficking Victims Protection Act, 18 U.S.C. §§ 1591, 1595* *(“TVPA”), and her cause of action for declaratory relief under the Speak Out Act, 42 U.S.C.* *§ 19401 et seq., all raise a federal question.*

*44. This Court also has supplemental jurisdiction over Ms. Grant’s state-law claims* *pursuant to 28 U.S.C. § 1367 because the claims are so related to the TVPA claims as to form part* *of the same case or controversy.*

*45. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b)(2), as a substantial* *part of the events or omissions giving rise to the claims occurred in the District of Connecticut.*

***FACTUAL ALLEGATIONS***

***I. Ms. Grant’s History with McMahon, Laurinaitis and WWE***

***A. Ms. Grant’s Introduction to McMahon Turns into a Two-Hour Meeting* *Between a Potential Entry-Level Employee and a Billionaire CEO.***

*46. Prior to having any involvement with WWE, Ms. Grant was dealing with profound* *grief following the loss of her parents, whom she cared for full time as their sole caretaker.*

*47. After her family passed away, Ms. Grant dedicated herself to finding gainful* *employment. During this time, Ms. Grant often ran into McMahon’s two personal assistants in* *her building (one of whom was a former grade school classmate of Ms. Grant).*

*48. Ms. Grant’s closest friend in the building was the resident manager. That individual* *is referred to herein as “Resident Manager.” Similar in personality, Ms. Grant and Resident* *Manager bonded over stories of adversity as they coordinated community initiatives in the building* *together. Resident Manager was aware of Ms. Grant’s efforts to obtain employment.*

*49. In March 2019, Ms. Grant remained unsuccessful in securing long-term* *employment. Resident Manager offered to help Ms. Grant, suggesting she could reach out to* *Defendant McMahon in case he could assist, and texted him to see if he would be willing to speak* *with Ms. Grant to provide advice about employment.*

*50. McMahon responded enthusiastically and proposed times to meet with Ms. Grant* *to discuss employment. Resident Manager passed along Ms. Grant’s resume to McMahon ahead* *of the prospective meeting.*

*51. Ahead of the meeting, Resident Manager advised Ms. Grant to be energetic as* *McMahon is “big on energy” and talk to McMahon no differently than she talks to Resident* *Manager.*

*52. On or about March 23, 2019, Ms. Grant arrived for the meeting in McMahon’s* *condo with additional printed copies of her resume, a black notepad, and “thank you” cookies.*

*53. Sitting at his dining table, McMahon looked at Ms. Grant’s resume and* *complimented both her communication skills and “common sense,” before discussing little but* *their personal lives. For example, Ms. Grant told McMahon about the hardship that led to Resident* *Manager’s offer to help and described losing her parents, her family’s bankruptcy, and other* *trauma that led her to seek financial independence to ensure she would never experience losing* *her home again.*

*54. McMahon shared stories about his upbringing, his traumatic childhood, growing up* *in poverty, and current family dynamics, including his separation from Linda McMahon—* *described as “his ex” and “long gone.” He added his marital status is an arrangement on paper for* *business purposes and that he lives a quiet, isolated existence outside of the WWE.*

*55. At the end of the meeting, McMahon told Ms. Grant that he didn’t just want to give* *her a job, but “give \[her\] a life,” and that he would find a place for her at WWE.*

*56. Stunned, Ms. Grant said that she didn’t know how to thank him for “possibly just* *changing my life.” McMahon responded that one simple “thank you” is enough and that he’d* *accept a hug; they stood and embraced.*

*57. McMahon then told Ms. Grant that he’d “get the ball rolling” on next steps but it* *was a busy time of year as WWE prepared for WrestleMania, explaining that it was WWE’s* *“Superbowl.” He then invited Ms. Grant to attend as his guest along with Resident Manager, and* *added that he would personally select their seats to have the best possible experience.*

*58. McMahon advised her that his office would reach out to her to set up a meeting* *with a trusted official, WWE Corporate Officer No. 2, at WWE headquarters. After asking if her* *cell was the best number to reach her, McMahon shared his personal phone number with Ms.* *Grant, walked her to his door, and again hugged her while whispering, “So good.”*

***B. McMahon Arranges for Ms. Grant to Be Hired by WWE—While Beginning* *to Groom Her for Sexual Exploitation.***

*59. On March 31, 2019, the day before Ms. Grant was scheduled to meet with WWE* *Corporate Officer No. 2, McMahon unexpectedly invited Ms. Grant to come back to his condo for* *pointers for her meeting with WWE Corporate Officer No. 2. When she arrived, McMahon gave* *a huge embrace and suggested they sit on the couch. It quickly became clear that McMahon had* *no intention of giving her pointers for an interview except for a single direction: if the topic comes* *up during her meeting, Ms. Grant could state they “met through a mutual friend.”*

*60. During this meeting, McMahon described a surgery he had on his knee by touching* *Ms. Grant’s leg and drawing a line where the surgery had taken place with his finger. He stated* *that similar to rehabbing an injury, Ms. Grant cannot let scar tissue build up inside her from trauma* *as her vulnerability is “a gift.”*

*61. McMahon explained that people are intimidated around him and are afraid to touch* *him. McMahon added that he is an affectionate person who likes to hug and “starves” for physical* *affection. McMahon then led Ms. Grant on a tour of his condo before hugging her goodbye, again* *whispering “Feels so good.”*

*62. On April 1, 2019, Ms. Grant met with WWE Corporate Officer No. 2 at WWE* *Headquarters for a short time. WWE Corporate Officer No. 2 hardly asked any questions, saying* *that WWE Corporate Officer No. 2 was figuring out where Ms. Grant would be placed and then* *promised to be in touch again after WrestleMania.*

*63. Later that day, Ms. Grant texted McMahon and enthusiastically described her* *meeting with WWE Corporate Officer No. 2. She also commented on a dinosaur skull that she* *saw on McMahon’s office wall, prompting his response, “btw if Ur a BAD girl the T-rex will eat* *U” followed by “Seriously Janel wherever U land in WWE U will be a credit to the organization.”*

*64. On April 7, 2019, Ms. Grant and Resident Manager were provided a “VIP”* *experience at WrestleMania, including private transportation in a black SUV arranged by* *McMahon. Per McMahon’s instructions, Ms. Grant diligently took notes about her impressions* *from WrestleMania—her first time attending such an event. Ms. Grant left overwhelmed with* *emotion and feeling hopeful that everything McMahon promised was becoming a reality.*

*65. Over the next several weeks, McMahon invited Ms. Grant to his condo on several* *occasions, each time assuring her that he would find the right position for her at WWE.*

*66. For each meeting with McMahon, Ms. Grant brought sample job descriptions she* *found online to review with him and demonstrate the types of roles she might fit in. McMahon* *listened to Ms. Grant, asked her questions, and pointed out qualities that he described as rare gifts,* *including her “goodness,” “vivaciousness,” “childlike-innocence,” and ability to be* *“vulnerable”—all things that made her an easy target. McMahon also initiated long physical* *embraces with Ms. Grant, repeatedly telling her that he trusted her, that he could be himself around* *her, and how he’d opened his home to her.*

*67. During one visit to the condo in late April 2019, McMahon did not greet Ms. Grant* *when she entered, but instead called her to his master walk-in closet. As soon as she turned the* *corner, McMahon emerged from his bathroom wearing only briefs. Shocked, Ms. Grant turned* *around and apologized, as McMahon laughed and asked her to turn around. He then handed her a* *shirt and asked for help with the buttons. McMahon reminded her that he was working hard on* *her role and said he felt good about her taking care of him.*

*68. Around that time, McMahon also told Ms. Grant that he would never forget how* *helpless she looked when they first met, that he wanted to wrap his arms around her, and assured* *her “that everything is going to be okay” and that Ms. Grant’s problems were in the past. McMahon* *also told Ms. Grant that he viewed her as a true friend.*

*69. However, McMahon advised Ms. Grant that people at WWE could never know* *about their closeness or else rumors would spawn and threaten them – particularly due to Ms.* *Grant’s physical beauty. McMahon also emphasized that the circumstances could jeopardize the* *Company. Around this time, he mentioned that he had an attorney on speed dial whom he* *described as the “best of the best” at making problems—including people who become problems—* *go away.*

*70. On April 21, 2019, McMahon unexpectedly invited Ms. Grant to his condo to* *provide her with an update. Upon her arrival, McMahon assured her Ms. Grant that he was a man* *of his word that his office would be in touch with her soon with the right role. As she turned to* *leave, McMahon grabbed a large black electric massager and told Ms. Grant to turn around for a* *demonstration. He quickly moved to rubbing his hands on Ms. Grant’s upper back before* *reminding her that she would hear from his office about next steps in a day or two.*

*71. Two days later, Ms. Grant was contacted about further meetings at WWE; a week* *later, she met with two high ranking human resources employees (referred to herein as “Human* *Resources Employee No. 1” and “Human Resources Employee No. 2,” respectively). Both Human* *Resources Employee No. 1 and Human Resources Employee No. 2 provided Ms. Grant with their* *impressions about company culture at WWE and confirmed that “the ball \[was\] in \[their\] court”* *to figure out where she would best fit in at WWE.*

*72. On May 5, 2019, Ms. Grant visited McMahon’s condo again and the topic of* *“bucket lists” came up, during which Ms. Grant expressed that she always dreamed of attending* *the Belmont Stakes. McMahon responded that he would personally acquire two tickets for her,* *which Ms. Grant said she could not accept.*

*73. McMahon then stood up from his chair and knelt in front of the chair where* *Ms. Grant was seated, blocking her from standing. He leaned close to Ms. Grant and told her to* *kiss him. Ms. Grant paused and gave McMahon a kiss on the cheek, to which McMahon sighed,* *“That’s not what I meant.”*

*74. After McMahon walked off to his bedroom and said that he wanted Ms. Grant, she* *swiftly rejected his advances and tried to reason with him that he was putting her in a bad position.* *Ms. Grant pled with McMahon to stop and think about what he was doing.*

*75. McMahon then begged repeatedly simply to hold Ms. Grant.*

*76. Out of fear for her employment and his earlier implied threats about his legal team* *dealing with problems, Ms. Grant lay down in bed next to McMahon and kept her hands clasped* *and ankles crossed, as she acquiesced in saying that he could only hold her, but nothing more.*

*77. When Ms. Grant tried to make small talk about WWE’s TV storylines, McMahon* *suggested she watch the next episode of Monday Night Raw and text him before the broadcast.* *After she agreed, he forcibly kissed her and began pulling down a strap on her sweater. Ms. Grant* *then sat up, said she needed to leave and had a lot to process, and left.*

*78. The next day, Ms. Grant watched the show as promised, and texted McMahon to* *wish him well. She was shocked when he appeared on the show and texted back in the middle of* *the live broadcast, “That was a very nice message :). Made me smile :):)”.*

*79. On May 9, 2019, McMahon texted Ms. Grant that she will have a job at WWE by* *that Friday.*

*80. The next day, Human Resources Employee No. 2 called Ms. Grant to inform her* *that the WWE Corporate Officer No. 4, would contact her at 4:00pm to discuss a legal role.*

*81. After her call with WWE Corporate Officer No. 4, Ms. Grant sent McMahon a* *“thumbs up” text message to indicate the call went well. Around 7:00pm, WWE Corporate Officer* *No. 4 unexpectedly called her a second time and formally offered her a job, saying “Welcome to* *WWE.”*

*82. On May 11, 2019, McMahon invited Ms. Grant to his condo again and asked her* *to lay in bed with him before informing her that he had ordered WWE Corporate Officer No. 4 to* *offer her the job, even though a job description had not been firmed up beyond a high-level* *summary.*

*83. While incredibly excited to finally receive long-awaited employment and financial* *security, Ms. Grant expressed to McMahon that there seemed to be a conflict between his doing* *this and his warning to Ms. Grant that no one could know about their closeness. He appeared* *amused with this, replying “It’s my company.” McMahon then undressed down to his briefs, while* *Ms. Grant remained clothed, and he began kissing Ms. Grant and inserting his hands into her pants* *without consent.*

*84. On May 16, 2019, McMahon informed Ms. Grant that he had obtained two tickets* *to the Belmont Stakes scheduled for June 8, 2019.*

*85. On May 17, 2019, Ms. Grant received an offer letter from WWE for an entry level* *job as “legal administrator-coordinator” with a salary of $75,000.*

*86. On May 18, 2019, McMahon summoned Ms. Grant to his condo and she brought a* *printed copy of the offer letter to review with him. McMahon informed Ms. Grant that her new* *boss, a WWE employee who worked in risk and government relations (referred to herein as “WWE* *Employee No. 1”), was a decades-long family friend and confidante, similar in age to McMahon* *and one of a small, original group (what McMahon called the “titan family”) who helped the WWE* *expand from a regional promotion to a global juggernaut.*

*87. McMahon stated that outside of his attorney, WWE Employee No. 1 was the most* *feared figure in the company because WWE Employee No. 1 usually fired employees. Beyond* *that, he offered little detail about WWE Employee No. 1’s role at WWE. Instead, he focused on* *WWE Employee No. 1’s personal traumas, explaining that similar to Ms. Grant, WWE Employee* *No. 1 has no family left after WWE Employee No. 1’s spouse passed away and that the McMahons* *and WWE were WWE Employee No. 1’s surrogate family. McMahon touted WWE Employee* *No. 1’s loyalty, saying that WWE Employee No. 1 would be able protect Ms. Grant, and then led* *her to his bedroom while giving her the command of, “Please don’t stop this.”*

*88. During the May 18, 2019, encounter, Ms. Grant felt coerced into engaging in sexual* *activity and that McMahon had trapped her an impossible situation, as she feared adverse career* *and personal consequences and legal retaliation if she declined his advances. McMahon stated,* *“This is what I have been waiting for” as he performed oral sex on Ms. Grant. Ms. Grant asked* *that protection be used, and McMahon responded that there was no need to worry because he was* *“clean.”*

*89. Feeling that she was being used for his gratification, Ms. Grant went numb and was* *unable to make eye contact. McMahon then flipped on his back and said, “Okay, jack ’em off.”*

*90. Disturbed by the nonconsensual sexual encounter, she hoped that McMahon would* *cease his advances. But his advances continued and left her to fulfill his demands or lose her job.* *91. On June 16, 2019, the day before starting with WWE, Ms. Grant attempted to shut* *down any further physical contact or sexual encounters by admitting to McMahon her unhappiness* *and concern starting her first-ever job – in his legal department no less – while in a physical* *relationship with the Chairman and CEO. She requested that they end any physical relationship* *while remaining friends to avoid any risks to either of them.*

*92. McMahon refused, saying that it was not ending, it did not need to, and that he did* *not “ever envision” it ending. He reminded her that he trusted her, reiterated that rumors would* *lead to trouble, probed whether her silence would be an issue, and brushed off her concerns that* *she was struggling with the feeling that her job felt unearned. McMahon told Ms. Grant that all* *she needed to do was not tell anyone and that, “it just has to look legit.”*

*93. McMahon then spun the conversation and told Ms. Grant to focus on the positives* *and embrace that her life was about to change, saying “Isn’t that what you’ve always wanted?”* *McMahon manipulatively emphasized that she’s about to start an adventure and gain a new family* *with the WWE, as a surrogate for the family that she had lost.*

*94. Ultimately, Ms. Grant’s unsuccessful attempt to end further unwanted physical* *contact quickly taught her that her view on the matter was not relevant.*

***C. Ms. Grant’s WWE Career Commences: Minimal Work and an Absent Boss.***

*95. On June 17, 2019, Ms. Grant reported to WWE headquarters for her first day of* *work. With attorneys in glass offices and support staff in cubicles with low walls and tall monitors* *it was easy to see how much other colleagues worked; as a quiet and small department, it was even* *easier to overhear their conversations.*

*96. Ms. Grant was immediately surprised that there was not much work assigned to* *her, struggling even to appear busy in her new role. In stark contrast to colleagues who complained* *about overflowing inboxes, Ms. Grant’s phone only overflowed with controlling and sexually* *charged text messages from the Chairman and CEO, reminding her both of McMahon’s power and* *ever-present surveillance.*

*97. Colleagues shared onboarding stories with Ms. Grant and talked about receiving* *pre-made binders of information or the opportunity to shadow departing employees – none of* *which happened for Ms. Grant. Nor did anyone know what her unusual title of “administratorcoordinator” meant.*

*98. Ms. Grant did not even meet WWE Employee No. 1 until her second week of* *employment. WWE Employee No. 1 was a lively individual who frequently regaled the legal* *department with stories of others at WWE. If McMahon’s name was mentioned, WWE Employee* *No. 1 would turn to Ms. Grant with a smile, a finger point, and/or a comment that drew attention* *to her connection to McMahon – such as, “She knows what I’m talking about.”*

*99. WWE Employee No. 1 and Ms. Grant bonded as quickly as McMahon had* *predicted. Ms. Grant, referred to as “partner” was taught words to live by in WWE, including “We* *do what’s in the best interests of the company,” “Protect the business,” and, if McMahon wants* *something, “The answer isn’t ‘no’ but rather how do we make it happen.” WWE Employee No.* *1 also impressed on Ms. Grant that job titles “don’t mean anything” for members of McMahon’s* *inner circle, which she was clearly considered to be a part of.*

*100. As WWE Employee No. 1 was seldom in the office and required little* *administrative support, Ms. Grant reported indirectly to another WWE employee within the legal* *department (referred to herein as “WWE Employee No. 2”), who provided her with occasional* *projects related to Talent appearances and XFL that helped fill Ms. Grant’s time.*

*101. Based on her hiring alone, WWE Corporate Officer No. 4 was on notice that there* *was something different about Ms. Grant; namely, her connection to McMahon. As Ms. Grant* *feared (and had expressed to McMahon), she was unhappy that a spotlight was unnecessarily put* *on her before she ever set foot in the office. Ms. Grant immediately noticed that WWE Corporate* *Officer No. 4 was warm with other colleagues but cold towards her.*

*102. Beginning in July 2019, after Ms. Grant raised an issue related to XFL’s* *Performance Enhancing Drug Policy with McMahon, WWE Corporate Officer No. 4’s behavior* *shifted from cold to actively hostile. If Ms. Grant walked into a room while WWE Corporate* *Officer No. 4 was laughing with colleagues, WWE Corporate Officer No. 4’s expression* *immediately became blank and WWE Corporate Officer No. 4 would walk away. If WWE* *Corporate Officer No. 4 and Ms. Grant walked towards each other in a hallway, WWE Corporate* *Officer No. 4 stopped and changed directions.*

*103. Colleagues noticed this shift in behavior; while some commented on it to Ms. Grant,* *others emulated it.*

*104. Notwithstanding the issues detailed above, Ms. Grant took her employment* *seriously. In contrast, McMahon continued a pattern of sending sexually charged messages* *throughout the work week. Certain her employment depended on her continued appeasement of* *and obedience to McMahon—and believing she needed McMahon’s protection from the* *suspicious WWE Corporate Officer No. 4 and others—Ms. Grant felt no choice but to respond in* *kind.*

*105. From all this, Ms. Grant began to experience debilitating panic attacks in the office* *on a near-daily basis that left her physically drained. She could not hide the physical symptoms* *of these attacks and texted Resident Manager, “u should see the way people look at me when I’m* *having an attack.” But while her co-workers noticed, no one dare get involved.*

***D. McMahon’s Coercive Control Tactics to Sexualize and Dehumanize Ms.* *Grant.***

*106. In the summer of 2019, McMahon’s presence was all-consuming in Ms. Grant’s* *life. In the office, she felt monitored as she was surrounded by allies of McMahon, which led to* *continued daily panic attacks. Outside the office, McMahon sexualized her entirely. He no longer* *referred to her as a friend, and largely stopped talking to Ms. Grant outside of sexting and fantasy* *talk. Any non-sexual texts related to life and/or work were either ignored or given token responses* *like “ok” or “yup.”*

*107. As detailed herein, McMahon was adamant about having Ms. Grant send him* *explicit photographs, impressing upon her that it was part of her sexuality. Given the control that* *McMahon had over Ms. Grant’s employment, she felt compelled to comply and sent the explicit* *photographs to McMahon’s mobile device. Ms. Grant was routinely assured that the photographs* *she was providing to McMahon were to remain private and were part of their “secret world.”*

*108. McMahon began to degrade Ms. Grant, calling her “his bitch,” while hinting at a* *fascination with having other people watch them engage in sexual activity.*

*109. Additionally, this Complaint details encounters during which McMahon caused* *Ms. Grant to sustain physical injuries, including bleeding and pain, from forceful use of sex toys.* *Despite Ms. Grant’s plea to cease any further sexual activity, the number of sexual encounters* *increased, as did McMahon’s physical aggression during them.*

*110. Notably, McMahon was most aggressive when using the certain sex toys named* *after male WWE wrestlers and performers. McMahon named the sex toys so that the color of the* *toy matched the race of the wrestler—for example, a black “dildo” would be named after an* *African American wrestler and a white “dildo” would be named after a Caucasian wrestler. In* *addition to McMahon’s infatuation with pretending that other men (and, namely, certain WWE* *talent) were in the room with them, this was yet another incremental step in desensitizing Ms.* *Grant to his fantasy, and eventual demands that she perform sexual acts for and/or have sexual* *contact with others within WWE.*

*111. During a David-versus-Goliath-type wrestling match in 2019, Ms. Grant shared* *with McMahon her thoughts on the event, the draw of rooting for the underdog, and ideas for* *future events. McMahon complimented her creative input. She believed she was being taken* *seriously—that is, until McMahon named a dildo after the smaller wrestler and attempted to* *sexualize the situation, diminishing her input.*

*112. By fall of 2019, McMahon frequently pressed for pornographic videos and more* *explicit content. When Ms. Grant expressed apprehension with his requests, McMahon responded* *with assurances that she could trust him—or questioned why she didn’t trust him.*

*113. McMahon also took care to remind Ms. Grant of his power and influence, such as* *by flaunting a meeting with the Saudi Crown Prince in October 2019.*

***E. McMahon Tightens His Grip on Ms. Grant and Discredits Her Doctor,* *Replacing Him with One of McMahon’s Choosing.***

*114. In addition to her panic attacks, Ms. Grant began experiencing increasingly severe* *physical, mental and emotional symptoms, including sleep disruption, dizziness, exhaustion,* *rashes, weight loss, hair loss and migraines.*

*115. In November 2019, Ms. Grant informed McMahon that her doctor suggested that* *her symptoms stemmed from trauma and ongoing stress. McMahon mocked her: “emotional* *trauma my ass!!”*

*116. However, on November 20, 2019, McMahon insisted that Ms. Grant see a physician* *of his choosing. This physician is referred to herein as “Celebrity Doctor” and the facility that* *Celebrity Doctor operated from is referred to herein as “Alternative Clinic.”*

*117. McMahon and Celebrity Doctor assured Grant that her bills at Alternative Clinic* *would be taken care of under McMahon’s account. After the initial visit, it became apparent to* *Ms. Grant that McMahon and Celebrity Doctor wanted Ms. Grant to remain in the care of Celebrity* *Doctor’s practice and Ms. Grant felt pressured to do so. Celebrity Doctor made comments about* *how Celebrity Doctor/they (“they” referring to McMahon and Alternative Clinic) had “saved her* *life” and Celebrity Doctor often remarked how Ms. Grant was unable to even make eye contact* *with Celebrity Doctor during their initial sessions—an obvious sign of trauma.*

*118. Ms. Grant acknowledged having a relationship with McMahon during visits with* *Celebrity Doctor, who gave little reaction, save telling her there were “many different paths to God* *and love.”*

*119. Celebrity Doctor lavished attention, treatments and products on Ms. Grant, all of* *which were paid for under McMahon’s account. Ms. Grant was never provided with any receipts.* *When Ms. Grant inquired about certain treatments provided, Celebrity Doctor challenged her on* *whether she trusted Celebrity Doctor and postured that if she didn’t trust Celebrity Doctor, then* *“we should part ways right now.”*

*120. At the outset of her care with Celebrity Doctor, each session lasted up to one hour.* *Ms. Grant would leave feeling exhausted from Celebrity Doctor’s deep dives into her personal and* *work life as “a coach” focused on behavioral science.*

***F. In 2020, McMahon Voices Concern about Rumors, Then Publicly Exploits* *Her, and Ms. Grant’s Desperate Attempt to Leave WWE.***

*121. On January 30, 2020, WWE issued a press release announcing that the company’s* *co-presidents, George Barrios and Michelle Wilson, were departing the company and would no* *longer serve on its Board of Directors; a significant drop in WWE’s stock price followed.*

*122. The company announced that Frank Riddick III, a member of Board of Directors* *for more than 11 years, would be interim Chief Financial Officer and report directly to McMahon.*

*123. On February 3, 2020, McMahon sent a message to Ms. Grant advising he had been* *informed by WWE Corporate Officer No. 2 that there were a lot of rumors circulating about* *McMahon and Ms. Grant.*

*124. McMahon warned Ms. Grant that rumors “were not good for either of them.” Then,* *on February 10, 2020, without any advance warning, Ms. Grant was temporarily relocated to the* *XFL workforce.*

*125. Ms. Grant, having been desperate to escape the feeling of being trapped in her* *existence at WWE, applied to remain with the XFL on March 6, 2020. She openly vocalized her* *desire to remain with XFL to colleagues, even referring to her state of work at WWE as* *“nothingness,” and she sought permission to make the change official from WWE Employee No.* *1 and Corporate Officer No. 4 before informing McMahon. Days after this—during which time* *she had finally told McMahon about her application to remain with the XFL—her request was* *denied.*

*126. In the weeks that followed, despite McMahon’s warning about rumors and direction* *to Ms. Grant to “play dumb,” he began showing explicit photos of Ms. Grant to people both inside* *and outside the company.*

*127. On March 26, 2020, McMahon sent a lengthy message to Ms. Grant describing in* *detail the circumstances surrounding sharing explicit photographs of Ms. Grant to a former WWE* *referee (referred to herein as “WWE Referee”). McMahon described how WWE Referee left to* *masturbate and told Ms. Grant she had made a perfect stranger very happy.*

*128. Ms. Grant initially dismissed this as mere fantasy talk, believing that McMahon* *would not actually do such a reckless thing. But when she voiced apprehension about McMahon* *sharing naked photos of her with someone she did not know, McMahon’s response was not to* *comfort her, but to assure of WWE Referee’s loyalty to him. This sharing of explicit photos* *terrified Ms. Grant as it illustrated McMahon’s sheer lack of self-control, and it further panicked* *her that these private and intimate photos, which included her face, were being shared with* *complete strangers.*

*129. On March 30, 2020, McMahon enthusiastically messaged Ms. Grant that WWE* *Referee had showed a friend a naked photo of Ms. Grant – which marked the beginning of* *McMahon sharing Ms. Grant’s naked pictures with others (who he encouraged to share with their* *friends).*

*130. On March 31, 2020, Ms. Grant expressed concern to McMahon that she had no* *intention of having sex with these strangers and requested McMahon make that message clear, as* *she felt threatened and distressed by the responses her pictures were getting. She made clear that* *she did not want any perception of her moving beyond the point of mere fantasy.*

*131. Shortly after, McMahon surprised Ms. Grant with news that he had protected her* *job from a furlough that WWE would imminently announce. The furlough affected a large number* *of employees and McMahon emphasized that he personally made sure that she would not be one* *of them – reinforcing her dependency on him, particularly after a majority of the support staff in* *the legal department (all hired prior to Ms. Grant) were furloughed.*

*132. McMahon became the most important figure in Ms. Grant’s life as he meticulously* *asserted power and control over almost every aspect of it. Ms. Grant’s fears intensified over the* *consequences that could result from McMahon’s actions, particularly by sharing her naked* *pictures. She became paranoid, completely dependent on and worshipfully devoted to McMahon.* *He, in turn, pressed forward in exerting his power over Ms. Grant as he saw fit.*

***G. McMahon Recruits Other Men and Forces Ms. Grant Into Sex Trafficking.***

*133. In May 2020, McMahon had recruited an individual whom he manipulatively* *referred to as his “friend” to engage in a “threesome” with McMahon and Ms. Grant. The “friend”* *turned out to be McMahon’s physical therapist at Alternative Clinic and is referred to herein as* *“Physical Therapist.”*

*134. To induce Ms. Grant’s participation in the threesome, McMahon began referring to* *Ms. Grant as his “girlfriend” and sent her a large bouquet of flowers. Nevertheless, on May 8,* *2020, Ms. Grant expressed apprehension about participating in the threesome. In response,* *McMahon insisted that the plans were already made and suggested he would lose a friendship if* *she did not go through with it.*

*135. On the day of the threesome on May 9, 2020, Ms. Grant showed up to the condo* *but reiterated that she did not want to go through with the act. She expressed fear of being thrown* *around like a “rag doll” by McMahon and Physical Therapist. After Ms. Grant clearly stated she* *wanted to back out, McMahon responded by telling Ms. Grant for the first time that he loved her,* *stunning her into silence.*

*136. McMahon’s manipulative tactic resulted in the outcome he wanted, and he led her* *down the stairs to the bedroom where Physical Therapist was already waiting to begin the* *threesome.*

*137. Early in the encounter, McMahon immediately directed Ms. Grant to lay down on* *her back in a supplicating position. While straddling over her, McMahon defecated on Ms. Grant’s* *head. McMahon left to shower off, but he instructed Ms. Grant to remain in place, with excrement* *in her hair, and to continue performing for his friend. While Ms. Grant requested protection, none* *was offered. McMahon and Physical Therapist actively continued with the threesome and directed* *Ms. Grant’s sexual performance for around an hour and a half while she was left covered in feces.*

*138. Following the threesome, on May 11, 2020, McMahon sent an explicit message to* *Ms. Grant that further detailed his fantasies of seeing her engaged in sexual relations: \[screenshot of message\]*

*139. McMahon then pressured Ms. Grant into several additional threesomes, in large* *part because she felt she had no other choice – particularly after McMahon’s comments that he* *had personally ensured that she had not lost her job.*

*140. Her subsequent run-ins with Physical Therapist at Alternative Clinic also served as* *a reminder of how much was at stake if she did not obey; McMahon controlled Ms. Grant’s* *employment, income, paid for her medical care, circulated naked pictures of her, and ignored her* *lack of consent for the first threesome.*

*141. Indeed, when text conversations would begin to cross over from McMahon’s* *fantasies into reality, Ms. Grant often attempted to avoid physical encounters with Physical* *Therapist—as on September 23, 2020, when she told McMahon there was “no room for a 3rd* *body.”*

*142. After the threesomes began, McMahon became more sadistic and his fantasies* *focused on control, such as choking, sensory deprivation, pain, humiliation, and group scenarios* *in which Ms. Grant was to be physically overwhelmed and subservient:*

*143. On one occasion, he instructed Ms. Grant: “Do NOT knock on the door cause if I* *see U ::: I will rape U in the hallway.”*

*144. To leave no doubt regarding the dynamic of their relationship: on May 12, 2020,* *McMahon texted Ms. Grant, “i’m the only one who owns U and controls who I want to f\*\*k U,”* *a theme that was often reiterated throughout their involvement.*

*145. On June 17, 2020, Ms. Grant sent texts to McMahon noting her one-year* *anniversary in joining WWE; McMahon ignored her.*

*146. A month later, McMahon reminded Ms. Grant about the far-reaching results of his* *texting out explicit content of her: “By now thousands of men see U everyday all over the world.* *They all want to f\*\*k you.”*

*147. Around this time, McMahon openly shared explicit photographs and salacious* *stories about Ms. Grant with WWE crew at TV tapings, a group McMahon also referred to as her* *“fan club.” Indeed, McMahon exuberantly messaged her a “truthful story” of having just shared* *explicit content of her with a group of twelve men on the WWE tech crew and recounted the* *obscene details he shared with them: \[screenshot of message\]*

*148. On the occasions when Ms. Grant informed McMahon that she was physically* *injured during their sexual encounter, McMahon’s responses varied from apologies to nonaccountable pushback and blaming impulse control. When encounters were particularly brutal,* *Ms. Grant learned to bookend the truth of her injuries with compliments to create the least amount* *of pushback from McMahon. However, Ms. Grant sustained brutal and painful injuries, including* *bleeding, swelling, bruising, and spans of incontinence resulting from McMahon’s forceful use of* *his fists, adult toys, and objects unsafe for vaginal insertion or penetration.*

*149. For instance, on August 28, 2020, Ms. Grant texted McMahon that she was injured* *during their latest sexual encounter, as a result of McMahon’s insistence on penetrating Ms. Grant* *with “extra-large” sex toys, including a vibrating wand that caused her to panic. McMahon ignored* *Ms. Grant’s warning that the device was not meant for insertion and forcefully shoved the wand* *inside of her so deeply that it became stuck for a period. She texted she was in pain and “bleeding* *a lot between last night and today” and “I’m on the floor right now bcuz I can’t get comfortable”* *and on August 29, 2020, she texted him an update that she was “still really uncomfortable” and “I* *got hurt in some way that I’m having trouble describing.” McMahon did apologize, saying that* *“Sometimes I just get carried away.”*

***H. McMahon Recruits Laurinaitis Into his Exploitation of Ms. Grant and* *Transfers Her Into Laurinaitis’s Department at WWE; Trafficking and Sex* *Acts at WWE Headquarters.***

*150. During this time, Ms. Grant became so sick from the stress of the situations that* *McMahon had subjected her to that her weight plummeted to just over 100lbs – which McMahon* *ignored.*

*151. One distressing event occurred on November 21, 2020, when McMahon drove Ms.* *Grant to WWE Headquarters to fulfill his fantasy of having a sexual encounter with her in his* *office, causing Ms. Grant to suffer a panic attack in the passenger seat while pleading with* *McMahon to change his mind and drive her back home. McMahon scoffed and then gave her an* *ultimatum: either have a sexual encounter in his office or inside the parked car. Terrified, Ms.* *Grant obeyed McMahon’s directions and they entered WWE headquarters for the encounter.*

*1**52. Further, despite Ms. Grant’s repeated statements that she did not consent to* *threesomes with McMahon and Physical Therapist, McMahon advertised her to others and told* *her that he had found another person to join them: Defendant John Laurinaitis.*

*153. In November 2020, McMahon pressed Ms. Grant to make explicit photos and* *videos to send to Laurinaitis. McMahon orchestrated exchanges by instructing Ms. Grant when to* *create explicit content for Laurinaitis, including what to say, and provided her with notes to adjust* *her performance. McMahon then facilitated the exchange of explicit content back and forth* *between Ms. Grant and Laurinaitis. Notably, even once phone numbers were exchanged between* *Ms. Grant and Laurinaitis, McMahon insisted that he be privy to any messages that Ms. Grant sent* *to Laurinaitis, and demanded that she report back about all interactions, further illustrating the* *level of control he held over Ms. Grant.*

*154. On or about December 29, 2020, a threesome was arranged between McMahon,* *Laurinaitis, and Ms. Grant at McMahon’s condo – McMahon instructed her to tell Laurinaitis that* *she was a neighbor and girlfriend working in the legal field (but not at WWE).*

*155. Shortly after meeting Laurinaitis, Ms. Grant asked him if she was the first woman* *whom McMahon had introduced him to in such a setting. Laurinaitis failed to respond and shot a* *look directly at McMahon, who quickly intervened by kissing Ms. Grant and initiating the sexual* *encounter amongst the three of them. Once again, Ms. Grant asked for protection; once again, her* *request was denied after an assurance that Laurinaitis was “clean.”*

*156. In the days that followed, McMahon texted her that Laurinaitis “hugged me like a* *bear and said thank you to me about 12 times already.” In contrast, Laurinaitis messaged Ms.* *Grant, “Thanks for the fun afternoon.”*

*157. On or around January 25, 2021, Ms. Grant was reassigned to directly support* *WWE’s new hire, a high-ranking employee in the legal department.*

*158. On February 5, 2021, McMahon sent Ms. Grant to establish a schedule for when* *other men (including Physical Therapist and Laurinaitis) could have sex with Ms. Grant, which* *Ms. Grant attempted to rebuff: \[screenshot of messages\]*

*159. Texts like this – a shift schedule – caused Ms. Grant to suffer breakdowns over how* *her original hope for a new life had been reduced to an objectified and dehumanized existence,* *with no way out.*

*160. On or about March 6, 2021, a second threesome between McMahon, Laurinaitis* *and Ms. Grant occurred.*

*161. In March 2021, WWE had still not hired a replacement after WWE Corporate* *Officer No. 4’s termination in November 2020. On March 9, 2021, McMahon informed Ms. Grant,* *still an entry-level coordinator, that top executives in the Company knew about their relationship* *and that her presence in the legal department was effectively delaying the Company’s efforts to* *hire a new replacement for this high ranking official, reinforcing the fact that many within the* *Company were well aware of the circumstances detailed herein.*

*162. As a result, McMahon stated the plan was for her to change departments and he* *verbally directed Ms. Grant to transfer to the Talent Relations Department, reporting to Laurinaitis.*

*163. On March 10, 2021, Ms. Grant sent McMahon a text message recapping their* *conversation and expressing shock and a range of concerns, including about Laurinaitis.* *Essentially, Ms. Grant expressed a desire to be treated humanely and taken seriously, which she* *acknowledged could be an “uphill battle.”*

*164. Unfortunately, Ms. Grant’s transfer to the Talent Relations department came with* *the expectation, from both McMahon and Laurinaitis, that she engage with Laurinaitis sexually,* *both physically and with explicit content.*

*165. On March 10, 2021, WWE Corporate Officer No. 2 informed Grant that day that* *she would officially be moved to Talent Relations and would quickly begin reporting to* *Laurinaitis, although details about her role, including a title and salary, were still being firmed up.* *In essence, Ms. Grant again found herself in a completely undefined role, except for the* *understanding that she remain a sexual slave to be used and trafficked by McMahon within the* *WWE.*

*166. On March 12, 2021, McMahon reminded her of the connection between her job and* *her role as a sexual object: “Let’s work hard and PLAY hard too !!!”*

*167. On March 16, 2021, Ms. Grant was directed to pick up a key to Laurinaitis’ hotel* *room and serve herself to him as “breakfast” before the start of work.*

*168. McMahon constantly reinforced the expectation that Ms. Grant sexually perform* *for him and her new boss Laurinaitis, both in and out of the office. McMahon wrote on March 22,* *2021, “Do U promise to make me proud Baby? Will U show him what a Porno Star U can B. Will* *U Show Off for me like never before ????” and “On days when he’s in town, I want him to f\*\*k* *U every morning and later In the office too.”*

*169. McMahon also indicated on April 2, 2021 that Ms. Grant should obey if Laurinaitis* *wanted to bring in yet more men: \[screenshot of message\]*

*170. In April 2021, WWE’s Senior Vice President of Human Resources was fired.*

*171. The same month, McMahon informed Ms. Grant that that she would be given the* *title of Vice President, Operations, within the Talent Relations department. However, days later,* *McMahon backtracked and said she would be a director of operations instead, to avoid suspicion* *of a sudden promotion to vice president.*

*172. During this conversation, McMahon told Ms. Grant that he had expressed to other* *WWE management that he wanted her to reach the level of Vice President and spend a year or two* *in the position, as she would be able to “take the experience anywhere.”*

*173. Ms. Grant left this conversation with McMahon hoping that she could escape this* *situation with her finances and reputation intact. She just needed to survive until that point.*

*174. In an April 2021 meeting between Ms. Grant and WWE Corporate Officer No. 2,* *WWE Corporate Officer No. 2 acknowledged that the jump initially proposed to Vice President* *was too big and could put a target on Ms. Grant’s back. Nevertheless, WWE Corporate Officer* *No. 2 presented Ms. Grant with paperwork detailing a base salary increase to $200,000 as Director* *of Operations.*

*175. As soon as Ms. Grant began working directly for Laurinaitis, forcible touching and* *overtly sexual behaviors became part of daily life when he was in the office. On numerous* *occasions, Ms. Grant was directed to visit Laurinaitis at his hotel room before work to serve herself* *to him as his “breakfast.” These devastating experiences made Ms. Grant feel as though she were* *being pimped out as an object for sexual gratification for her new boss. Upon information and* *belief, corporate funds from the WWE were used to finance Laurinaitis’s hotel stays when these* *coerced sexual encounters occurred.*

*176. Per McMahon’s instructions, Ms. Grant reported interactions with Laurinaitis back* *to McMahon, for whom the stories served as a source of arousal.*

*177. The arrangement with Laurinaitis left Ms. Grant miserable and enraged. However,* *in her years of experience with McMahon, she knew her requests to stop would be ignored at best* *or used to destroy her career and reputation at worst. Ms. Grant was further left feeling isolated* *by colleagues and surveilled by the top-level employees within WWE.*

*178. Professionally and personally, Ms. Grant’s fate was entirely in the hands of* *McMahon, Laurinaitis, and the other WWE executives who enabled her abuse.*

*179. On May 24, 2021, McMahon messaged Ms. Grant to remind her that a mistake* *could destroy her career and that she should pursue verbal communication rather than written* *where possible: \[screenshot of messages\]*

*180. Panic that someone else’s mistake could cost Ms. Grant her livelihood left her* *feeling helpless and afraid of what would happen if McMahon’s mood shifted, leading her to* *message him expressions of loyalty, love, and submission as a coping mechanism and with the* *hope that he would protect her.*

*181. On June 14, 2021, Ms. Grant again told McMahon that she did not want to engage* *in sexual encounters with Laurinaitis, adding “I’ve left that hotel feeling bad about myself every* *time.” McMahon responded that the one-on-one encounters could cease, but that he expected* *threesomes with Laurinaitis to continue.*

***I. McMahon and Laurinaitis Confined Ms. Grant in an Office for an Abusive* *Sexual Assault at WWE Headquarters.***

*182. The following morning, on June 15, 2021, at approximately 7:51am, Ms. Grant* *messaged McMahon that, due to her work on an important project, she did not want a threesome* *that week as a “3some won’t set me up for success. It’ll knock me out.” To avoid pushback from* *McMahon, Ms. Grant offered the following week instead.*

*183. McMahon and Laurinaitis ignored her plea and brought her into Laurinaitis’ office,* *forcibly touching and undressing her before forcing her to engage in a threesome on a conference* *table. Ms. Grant pleaded, “No, no, no” and “Please stop”; McMahon responded with “No means* *yes.” Ms. Grant again told them to stop. Instead, McMahon licked his fingers and penetrated Ms.* *Grant and said, “Take it, bitch.” With each taking turns restraining her for the other, Laurinaitis* *then joined by forcibly shoving his tongue, then penis, into Ms. Grant’s mouth.*

*184. On June 23, 2021, around 11:42am, McMahon directed Ms. Grant – in the middle* *of a workday – to meet him on a lower floor. When Ms. Grant arrived, McMahon led her inside* *his private locker room, locked the door, and forced himself on her over a massage table. Later* *that day, $15,000 in gift cards to Bloomingdales were purchased at McMahon’s direction and* *delivered by McMahon’s personal assistant to Ms. Grant in her office.*

*185. On multiple other occasions while Ms. Grant worked under Laurinaitis, including* *after McMahon’s promise that one-on-one encounters would end – and even after his wife moved* *across the country to join Laurinaitis – he would call Ms. Grant to his office, lock the door, unzip* *his pants, and instruct Ms. Grant to perform oral sex.*

*186. Through all this, Ms. Grant noticed that the less she sexually engaged with* *Laurinaitis, the less work she had as Laurinaitis began to belittle Ms. Grant in front of colleagues.* *Fearing for herself and her future, Ms. Grant asked Laurinaitis whether he still supported her* *promotion to vice president. He deflected with an answer about considering all options and* *changed the topic. The extreme uncertainty and fear for her future exacerbated Ms. Grant’s* *physical symptoms of illness, including gastrointestinal issues and vomiting, which continued to* *worsen over the remainder of her time with WWE.*

***J. McMahon Uses Ms. Grant as a Sexual Pawn to Entice World-Famous* *Wrestling Talent and to Keep WWE Superstar Under Contract with WWE.***

*187. WWE Superstar is famous world-wide as a top talent with WWE with a large* *collective fan base that helps generate viewership and drives in-person attendance, all of which* *enrich WWE and McMahon.*

*188. Upon information and belief, McMahon began to recruit WWE Superstar for a* *sexual encounter with Ms. Grant while she was still a coordinator in the legal department. By July* *of 2021, McMahon informed Ms. Grant that WWE Superstar would be their next “playmate.”*

*189. As in other instances, McMahon described his fantasy of seeing Ms. Grant engaged* *in unmerciful sexual acts with WWE Superstar during which he would “rip” her open.*

*190. McMahon also confided to Ms. Grant that he wanted to have WWE Superstar under* *a new contract, while WWE Superstar indicated an interest in a return to other professional* *endeavors.*

*191. On or about July 12, 2021, McMahon directed Ms. Grant to create personalized* *sexual content for WWE Superstar. McMahon shared the photos with WWE Superstar and then* *informed Ms. Grant that “he likes what he sees.”*

*192. On July 21, 2021, McMahon flew and/or caused WWE Superstar to fly on a jet into* *a local airport and travel into Connecticut (across state lines) for what McMahon described to* *Ms. Grant as a “business dinner,” as well as a sexual encounter with Ms. Grant in McMahon’s* *condo. Upon information and belief, the dinner was to discuss WWE Superstar’s continued* *involvement with WWE. Prior to the “business dinner” with McMahon, WWE Superstar made a* *brief visit to Ms. Grant’s building. However, WWE Superstar did not return to the building for a* *sexual encounter because he was too intoxicated and taken back to the plane.*

*193. Later that evening, after McMahon recounted the story about his dinner with WWE* *Superstar to Ms. Grant, he sought to salvage the night with a request that they “role play” a sexual* *encounter, in which McMahon acted as if he were WWE Superstar. McMahon was so physically* *rough with Ms. Grant during this encounter, that Ms. Grant begged McMahon to stop numerous* *times, including loud cries of “Help!” “I’m serious!” and “I’m scared!” as he – among other things* *– penetrated her, fisted her, pulled her hair, pinned her, shoved her, and open-palm slapped her.* *McMahon’s assault caused Ms. Grant to break down weeping and curl into the fetal position with* *her arms pulled up to protect her face. McMahon alternated between slaps and shoves before* *admitting that “I’m really f\*\*king up with you right and left tonight, huh?”*

*194. McMahon forbade Ms. Grant from leaving his condo that night unless she could* *verbally assure him that there wasn’t a problem and everything between them was okay. Notably,* *however, he made no effort to check on her well-being after she left his condo.*

*195. On August 26, 2021, WWE held its second biggest annual event, SummerSlam, in* *Las Vegas’ Allegiant Stadium. Around this time, McMahon and WWE Superstar privately* *reached an informal agreement about his return.*

*196. That night, McMahon texted Ms. Grant a reminder that she was an enslaved object* *to him: “I want to drive U lower and lower. So low that U might beg me to sell U” (emphasis* *added).*

*197. McMahon continued to advertise a sexual encounter with Ms. Grant to WWE* *Superstar during the formal negotiation of a new Booking Contract with WWE: \[screenshot of message\]*

*198. In December 2021, McMahon gave Ms. Grant’s personal cell phone number to* *WWE Superstar and promised “she’ll do anything” requested of her.*

*199. In the days that followed, WWE Superstar revealed a fetish to Ms. Grant and tested* *McMahon’s promise that Ms. Grant would “do anything” with a request that she send a video of* *herself urinating.*

*200. Unable to recognize herself, Ms. Grant went numb and obeyed. WWE Superstar* *informed Ms. Grant if she had not complied with the request, WWE Superstar would have lost any* *interest in her and then called her a “bitch.”*

*201. That same month, WWE Superstar expressed to Ms. Grant his desire to “set a play* *date” and have a sexual encounter. However, a snowstorm changed WWE Superstar’s travel plans* *and Ms. Grant ultimately used the weather and COVID-19 as an excuse to back out.*

***K. McMahon Tells Ms. Grant That his Wife Has Learned About Her and* *Pressures Ms. Grant for an NDA.***

*202. In early January 2022, McMahon abruptly distanced himself from Ms. Grant,* *saying that he could not speak to or be in the same room as her.*

*203. On January 9, 2022, McMahon agreed to speak with Ms. Grant at his condo.* *During this meeting, McMahon told Ms. Grant that his wife, Linda McMahon, had learned about* *his relationship with Ms. Grant, that he was losing his condo, and that she would divorce him. He* *added, too, that a public divorce would make Ms. Grant a headline.*

*204. Purportedly to salvage his marriage and avoid both the negative publicity and other* *repercussions of a divorce, McMahon wanted to ensure that Ms. Grant would remain silent about* *his personal misconduct in order to preserve his controlling interest in WWE. McMahon told Ms.* *Grant that if she left WWE and signed an NDA, he was confident Linda McMahon would not* *divorce him, he could remain in the condo, and Ms. Grant would avoid reputational harm.*

*205. McMahon instructed Ms. Grant that she should not go back to the office and* *immediately lessen her involvement on open work items. Ms. Grant expressed concerns about both* *her name being mentioned in the media and the loss of control over her image, especially as* *McMahon had shared content of her for close to two years, and the ramifications for her career.* *McMahon suggested that he would attempt to help keep Ms. Grant’s reputation intact, and that he* *or WWE Corporate Officer No. 1 would personally help Ms. Grant to find another job.*

*206. McMahon also instructed Ms. Grant not to share this news with anyone, and* *suggested she offer health-related excuses if asked about leaving WWE.*

*207. Regarding the NDA, Ms. Grant asked McMahon, “Is this when Jerry sends the* *papers?” McMahon nodded and assured Ms. Grant that they would be “in the driver’s seat” to i**ron out terms together but she would need an attorney to make things official and approved of* *Ms. Grant asking Celebrity Doctor for an attorney referral.*

*208. Following this discussion, McMahon led Ms. Grant to his bedroom for another* *sexual encounter.*

*209. On January 14, 2022, McMahon sent Ms. Grant a to-do list for purposes of* *effectuating the NDA, such as retaining counsel, and also included an offer for one-on-one career* *coaching. McMahon suggested the list had been drafted by WWE Corporate Officer No. 2.*

*210. Before Ms. Grant retained counsel, McMahon discussed the amount of money that* *would be exchanged for the NDA and settled on a lump sum of $3,000,000 after Ms. Grant told* *McMahon his initial offer of $1,000,000 was not enough to compensate for the lost earning* *potential and the fact that she would be unable to continue the promised career trajectory of Vice* *President, as well as failing to last as a Director for a full year.*

*211. Before Ms. Grant retained counsel, McMahon called Ms. Grant with an update and* *informed her that McMahon’s attorney and counsel for WWE insisted on installment payments* *due to “cash flow purposes.” When Ms. Grant responded that this reasoning did not make sense* *for a billionaire, McMahon insisted that it was not his idea.*

*212. On or about January 19, 2022, Ms. Grant advised McMahon that she had contacted* *Celebrity Doctor about an attorney referral, and on that physician’s recommendation, and upon* *McMahon’s approval, she signed a retainer agreement with a lawyer later that day.*

*213. On January 24, 2022, McMahon continued to engage in sexual text message* *exchanges with Ms. Grant, including encouraging her to send an explicit photo to WWE Superstar.* *McMahon also requested Ms. Grant send him content she had sent to WWE Superstar.*

*214. The “negotiations” of the NDA were brief – lasting only eight days. Ms. Grant* *reminded McMahon that the NDA ought to address people who knew about their relationship,* *including, but not limited to: WWE Corporate Officer No. 1, WWE Corporate Officer No. 2, John* *Laurinaitis, and McMahon’s personal assistants. Ms. Grant and her attorney sought to incorporate* *the list of individuals who had knowledge of the relationship into a Schedule A in the NDA. Ms.* *Grant’s requested revisions were flatly rejected by McMahon and WWE, who reverted to their* *original draft rather than incorporate any of her proposed changes – with the exception that, as of* *the date of execution, Ms. Grant would not speak of the relationship.*

*215. On or around January 26, 2022, McMahon articulated an even more pressing need* *to get the NDA signed immediately, informing Ms. Grant that he was under a tight deadline to* *report pending or threatened legal actions to the WWE Board of Directors – specifically the Audit* *Committee – and that McMahon and his attorney could not do so unless Ms. Grant signed the* *NDA. He informed Ms. Grant that Board members were concerned about the delay.*

*216. Furthermore, McMahon repeatedly pressed Ms. Grant to stop her attorney from any* *further “wordsmithing” and blamed Ms. Grant’s attorney for not understanding the urgency of the* *situation. Also, despite any previous approval, McMahon now expressed that both he and his* *attorney had concerns about Ms. Grant’s attorney and warned her that her counsel could not be* *trusted, which in turn caused Ms. Grant to question her trust in her personal attorney.*

*217. On or around January 26, 2022, Ms. Grant became so overwhelmed that she asked* *to simply give notice without the need for a payment, even offering to sign a napkin or Post-It as* *a sign of goodwill. McMahon flatly rejected her desire to back out.*

*218. On January 27, 2022, just eight days after Ms. Grant had hired an attorney,* *McMahon left Ms. Grant a lengthy audio message explaining why they needed to go through with* *the NDA, pushing her to hurry up and sign the NDA and advising that he would be “double f\*\*ked”* *if she did not (presumably referring to both his divorce and report to the Board of Directors).*

*219. Between on January 27, 2022 and January 28, 2022, there were unresolved edits* *that led to panicked phone calls, including an attorney confidentiality clause and signatory line* *that Ms. Grant’s counsel said he would never sign. Also, the deadline to sign the NDA was pushed* *up from January 31 to January 28, 2022.*

*220. McMahon continued pressuring Ms. Grant with calls, during which he pleaded,* *demanded, threatened, and begged her sign the NDA and reminded her that by not signing, she* *would jeopardize him, the company, and his family, and that she would surely become the subject* *of national headlines and ruin her reputation if she did not sign the NDA by the start of WWE’s* *live programming schedule on January 28. He reassured her that nothing would change between* *them, and she would emerge with her reputation intact if she would simply sign the NDA.*

*221. In a state of mental defeat and fear from McMahon’s threats, Ms. Grant succumbed* *to his unrelenting pressure and signed the NDA just before the deadline on January 28, 2022.*

*222. On February 4, 2022, Ms. Grant was wired $1,000,000 as the first installment of* *the NDA. On February 28, 2022, Ms. Grant was wired $10,000 to cover her attorneys’ fees* *incurred in connection with the NDA. Both wires were sent with originator described as “Vincent* *K. McMahon C/O WWF…”, and originator address “1241 EAST MAIN STREET, STAMFORD,* *CONNECTICUT, 06902 UNITED STATES.”*

*223. On February 9 and 10, 2022, Ms. Grant gave notice to Laurinaitis and put human* *resources at WWE on official notice that she was leaving WWE.*

*224. After signing the NDA, Ms. Grant continued to ask about who had told Linda* *McMahon, as she was concerned about her ability to obtain employment in the future. McMahon* *responded that it did not matter and that he was tired of her questions.*

*225. After the NDA was signed, McMahon, wearing only a white robe, met Ms. Grant* *in his condo to review outstanding business items. As Ms. Grant was proceeding to the door to* *leave, McMahon grabbed her arm before she exited and commanded her to do “one last thing” and* *get “on your knees.”*

*226. As Ms. Grant knelt on the hard floor, barely a few feet away from the front door,* *McMahon opened his robe and ordered her to “Eat him!” McMahon grabbed the back of Ms.* *Grant’s head and slammed her face into his crotch a couple times until she gagged and pushed him* *away, telling him to stop and that she couldn’t breathe. McMahon responded that she wouldn’t* *get away that easily and held her head as he forced himself back in her mouth until she had no air.* *Ms. Grant tried to push him away but he held her head firmly in place and loudly commanded her* *to “Look up!” followed by “Take it, bitch.” They momentarily made eye contact before* *McMahon’s force caused Ms. Grant’s body to convulse and retch with tears streaming down her* *face. McMahon then released his hold and closed his robe as she stood up. After leaving, Ms.* *Grant never saw McMahon again.*

*227. On March 2, 2022, while Ms. Grant was away on a trip to Florida, McMahon called* *Ms. Grant to advised that it would probably be the last time she would hear from him and, if she* *needed anything, to contact WWE Corporate Officer No. 1 or WWE Corporate Officer No. 2.* *Over the course of an approximately half hour call, McMahon lamented both his inability to focus* *on the upcoming WrestleMania and how his personal life had blown up over the past few weeks.* *Towards the end of their conversation, McMahon and Ms. Grant agreed to resume contact after* *WrestleMania. He also instructed Ms. Grant to continue having sexual relations with other men,* *including WWE Superstar, in the meantime*

*228. On or around March 4, 2022, WWE Superstar messaged Ms. Grant that he was in* *New York. In line with McMahon’s orders, Ms. Grant texted WWE Superstar explicit pictures.*

*229. On March 27, 2022, WWE Superstar reached out to Ms. Grant again. Ms. Grant* *interpreted these back-to-back advances as an indication of McMahon’s continued control.*

*230. On March 30, 2022, Ms. Grant’s counsel received a call from McMahon’s attorney* *advising that there had been an anonymous email about the relationship between Ms. Grant and* *McMahon and Laurinaitis. Later, in June and July 2022, stories were published regarding the* *matter of McMahon’s multiple NDAs with various women associated with WWE and others. Ms.* *Grant did not receive another payment under her NDA in February of 2023.*

*231. Further, despite assurances from McMahon that he would cover her medical care* *and the costs associated with her tax liability for the $1,000,000 payment, McMahon has refused* *to cover those costs. McMahon continued to pay for Ms. Grant’s medical care until April 15, 2022,* *when it abruptly ceased.*

***II. Gifts Given to Plaintiff during Time with WWE and Association with McMahon.***

*232. From 2019 until early 2022, McMahon provided Ms. Grant with “gifts” to keep her* *under McMahon’s control. Upon information and belief, the gifts provided to Ms. Grant included* *ones purchased by McMahon and expensed them to WWE.*

*233. Examples of the items received by Ms. Grant from McMahon in 2019 included the* *following:*\
*a. Alternative Clinic medical care and medical & cosmetic services and products;*\
*b. Clubhouse Access tickets to the Belmont Stakes;*\
*c. WrestleMania private full day transportation & premium tickets;*\
*d. A $2,000 Nordstrom gift card; and*\
*e. A massive box of Godiva.*

*234. Examples of the items received by Ms. Grant from McMahon in 2020 included the* *following:*\
*a. $20,000 towards surgery (paid directly to a surgeon’s office);*\
*b. Pearl/diamond pave lariat necklace from Betteridge in Greenwich, CT;*\
*c. Blue cashmere knee length cardigan (Nordstrom);*\
*d. Blue Burberry check cashmere scarf (Nordstrom);*\
*e. Blue cashmere & fur hat (Nordstrom);*\
*f. Grey cashmere shawl (Nordstrom);*\
*g. Celine sunglasses (Nordstrom);*\
*f. Cable knit throw blanket; and*\
*g. Large bouquets of flowers delivered approximately every other week.*

*235. Examples of the items received by Ms. Grant from McMahon in 2021 included the* *following:*\
*a. 2022 BMW 430XI;*\
*b. $5,000 gift certificate at Landphier Spa;*\
*c. Two private chef-catered dinners in McMahon’s condo;*\
*d. Gold & diamond pave paperclip necklace from Betteridge in Greenwich, CT;*\
*e. $15,000 Bloomingdales gift cards;*\
*f. Food assortment display & antique tea ceremony set from Saudi Arabia; and*\
*g. Large bouquets of flowers delivered approximately every other week.*

***III. Ms. Grant was a Subordinate and Vulnerable Victim to Predators, Not a Consenting* *and Willing Participant.***

*236. Ms. Grant was groomed and coerced by McMahon and Laurinaitis, and the WWE* *stood by and facilitated efforts to keep Ms. Grant employed by WWE to ensure McMahon’s* *continued sexual exploitation. In addition to what Ms. Grant (and her medical providers who*\
*examined her following the abuse) will testify to, there is ample other evidence of Ms. Grant’s* *mental state and her attempts to avoid the unfortunate circumstances she found herself in.*

*237. In January of 2021, Ms. Grant sent a message to Resident Manager stating that she* *was miserable at WWE: “I don’t say it to Vince but (as grateful as I am for my job & my salary, I* *actually am miserable… mismanaged all the time, they admit they don’t know what to do with me,* *nobody gave a f\*\*k when I was harassed & retaliated against to the point my reputation was* *questioned & my work was taken away).”*

*238. As further alleged throughout this Complaint, Ms. Grant was frequently referred to* *as McMahon’s “bitch.” On multiple occasions, Ms. Grant objected to this treatment.*

*239. As alleged herein, before Ms. Grant was being routinely directed by McMahon to* *engage in sexual contact with other men, Ms. Grant had expressed her apprehension about* *McMahon’s “fantasy” texts manifesting and graduating into reality.*

*240. Further, at nearly all relevant times, Ms. Grant was an employee of the WWE and* *could reasonably expect, at a minimum, to lose her position if she did not comply with the wishes* *of McMahon.*

***IV. McMahon Controlled WWE During Ms. Grant’s Employment, and the Company* *Knew, But Did Nothing About, McMahon’s Exploitation of Ms. Grant.***

*241. As detailed herein, WWE knew of McMahon’s illegal conduct and did nothing to* *stop it. This is self-evident from the numerous executive level and board members who were privy* *to McMahon’s involvement with Ms. Grant, as well as his prior incidents involving sexual* *misconduct.*

*242. For instance, in or around March 2021, Ms. Grant introduced herself to WWE* *Corporate Officer No. 1 when they passed one another in the hallway. WWE Corporate Officer* *No. 1 responded by telling Ms. Grant that WWE Corporate Officer No. 1 knew exactly who she* *was.*

*243. WWE Corporate Officer No. 1 maintained an office suite on the executive 4th floor* *of WWE’s company headquarters at 1241 East Main Street. Meanwhile, Ms. Grant’s cubicle in* *the company’s legal department was in a different building (1266 East Main) and across the street* *from WWE Corporate Officer No. 1’s office. Ms. Grant had no physical presence at 1241 East* *Main Street until the beginning of February 2021, when she began to report to an attorney who* *kept an office in both buildings.*

*244. Given that WWE Corporate Officer No. 1 a very high-ranking WWE officer and* *Ms. Grant was an entry-level coordinator in the legal department, it is unusual that WWE* *Corporate Officer No. 1 would know who Ms. Grant was at all at that point, except WWE* *Corporate Officer No. 1 knew of Ms. Grant at least in part by hearing about the ongoing* *exploitation of Ms. Grant by McMahon.*

*245. Following Ms. Grant’s messages to McMahon on March 9, 2021, McMahon* *summoned Ms. Grant to his condo that evening for a conversation during which McMahon* *confirmed that WWE Corporate Officer No. 1, indeed, knew exactly who she was, as McMahon* *had met privately with WWE Corporate Officer No. 1 and WWE Corporate Officer No. 2 and* *advised these individuals of McMahon’s connection to Ms. Grant.*

*246. McMahon continued this conversation by detailing to Ms. Grant that they had* *expressed concern but were ultimately supportive. McMahon also advised Ms. Grant that one or* *both of WWE Corporate Officer No. 1 and/or WWE Corporate Officer No. 2 inquired whether* *Ms. Grant could be trusted, and that McMahon offered assurances that Ms. Grant would not do* *something to hurt the WWE.*

*247. Knowledge on the part of WWE is further illustrated by the multiple meetings Ms.* *Grant had about initial hiring and subsequent position changes, including a number of such* *meetings with WWE Corporate Officer No. 2 and a voice memo McMahon sent Ms. Grant the* *following morning, on March 10, mentioning the names of both WWE Corporate Officer No. 1* *and WWE Corporate Officer No. 2 in connection with the new role. It’s unusual for the Executive* *Chairman and CEO to name-drop two of the company’s highest-ranking officers in connection* *with a coordinator’s first job promotion—especially as there are Human Resources partners* *assigned to each department.*

*248. WWE Corporate Officer No. 4 was a high-ranking legal department employee at* *WWE until around November 2020. Upon information and belief, WWE Corporate Officer No.* *4 was terminated or asked to resign from WWE Corporate Officer No. 4’s post at WWE. McMahon* *expressed to Ms. Grant that WWE Corporate Officer No. 4, while still employed at WWE, knew* *or highly suspected that a sexual relationship existed between McMahon and Ms. Grant. Upon* *information and belief, WWE Corporate Officer No. 4 articulated WWE Corporate Officer No.* *4’s knowledge and/or suspicion to at least one other executive.*

*249. Knowledge on the part of WWE is further illustrated by the fact that Ms. Grant’s* *presence became more visible over time, including during Executive Committee meetings, which* *were attended by individuals who had either direct knowledge of McMahon’s sexual exploitation* *of Ms. Grant or were otherwise suspicious. Given Ms. Grant’s length of employment and job title,* *it was an abnormal sign of different and special treatment for her to attend such meetings,* *especially when the executive head of the department, Laurinaitis, was in attendance as well.*

*250. Notably, Ms. Grant inquired with both WWE Corporate Officer No. 1 and WWE* *Corporate Officer No. 2 about whether it was appropriate for her to attend these meetings.*

*251. Additionally, WWE Corporate Officer No. 3, another high-ranking WWE official* *and member of the WWE Board of Directors at the time of Ms. Grant’s employment with WWE,* *motioned for Ms. Grant to sit in a chair near WWE Corporate Officer No. 3 at the Boardroom* *Table during one of the meetings. Upon information and belief, WWE Corporate Officer No. 3* *knew of other instances of McMahon engaging in inappropriate sexual conduct.*

*252. Upon information and belief, numerous other independent contractors, employees,* *as well as executives and/or Board Members within WWE, knew of or suspected McMahon’s* *misconduct involving Ms. Grant, including by being shown explicit photos of Ms. Grant by* *McMahon.*

*253. McMahon directed a single attorney to negotiate the NDA on behalf of WWE and* *McMahon – both parties to the agreement.*

*254. McMahon’s abuse of Ms. Grant did not come as a surprise to anyone at WWE* *because he had faced numerous prior accusations of sexual misconduct, including:*\
*a. In 1994, former WWE referee Rita Chatterton alleged that McMahon had* *raped her after luring her into a limousine to discuss her career. She* *recounted it for New York Magazine: “I was forced into oral sex with Vince* *McMahon. When I couldn’t complete his desires, he got really angry,* *started ripping off my jeans, pulled me on top of him, and told me again* *that, if I wanted a half-a-million-dollar-a-year contract, that I had to satisfy* *him. He could make me or break me, and if I didn’t satisfy him, I was blackballed, that was it, I was done.”*\
*b. In February 2006, the Palm Beach Post reported that McMahon had shown* *nude pictures of himself to a tanning booth attendant at Tanzabar in Boca* *Raton, Florida, and subsequently “made unwelcome advances and finally* *cornered her in a tanning booth and groped her.”2*\
*c. A former spa manager at a California resort accused McMahon of assault at* *the resort in 2011.*

*255. To further illustrate knowledge of the culture of sexual misconduct at WWE, top* *level executives not only failed to properly investigate abuse, but also compounded Ms. Grant’s* *suffering by making public statements that trivialized the harm perpetrated upon her.*

*256. These are just a few examples as to how the WWE, and its most senior officials,* *knew about and fostered a culture where the venture of harassment and sexual exploitation of* *women was tolerated to further the business and financial interests of WWE.*

*257. Given, among other things, the history of misconduct involving other women, the* *notice provided by McMahon to senior leadership at WWE, rumors about the relationship within* *WWE Headquarters, the widespread sharing of Ms. Grant’s pictures – including her face – to those* *inside the company by McMahon, the atypical hiring of Ms. Grant and the atypical advancement* *of Ms. Grant within WWE, WWE clearly knew of McMahon’s misconduct involving Ms. Grant* *and/or recklessly disregarded facts available to them.*

***V. Circumstances Surrounding the NDA, Its Invalidity, and McMahon and WWE’s* *Disregard for the NDA.***

*258. As detailed herein, the NDA signed by Ms. Grant, McMahon, and WWE was* *entered into through coercive tactics, and it is legally unenforceable pursuant to federal statute and* *common law. Exhibit A, attached hereto, is a true and accurate copy of the NDA.*

*259. The NDA violates the Speaks Out Act and is thus unenforceable.*

*260. The NDA is also void and unenforceable because the confidentiality term—a core* *term—is overly broad on its face. As written, it would prevent Ms. Grant from saying anything to* *anyone about WWE or her employment there (which, of course, she would need to do to apply for* *a job, for example), let alone exposing McMahon and others’ sexual assaults and abuse of Ms.* *Grant. The NDAs that McMahon has used to silence other women may be equally unenforceable* *if the same language was used.*

*261. Ms. Grant was, moreover, coerced into signing the NDA merely eight days after* *she first spoke to an attorney – an attorney whom McMahon initially approved of and then* *cautioned Ms. Grant against trusting – before she was railroaded into rejecting all of her own* *attorneys’ comments. This occurred because of relentless pressure, including implicit and explicit* *threats, by McMahon.*

*262. The NDA did not even include basic terms she was promised by McMahon –* *including that he would pay for her lawyers, medical care, and taxes.*

*263. Regardless, even if it were enforceable, McMahon has breached a core term of the* *NDA. He paid $1,000,000, but failed to make any further payments, including the installment of* *$500,000 that was to be paid within 10 days of February 1, 2023, under Section V.B of the* *agreement.*

*264. Furthermore, circumstances have changed in that Ms. Grant’s name has now been* *publicly released, through no fault of her own, which impacts employment prospects and has led* *to further trauma and humiliation.*

***VI. Ms. Grant’s Life After This Abuse and Resulting Damages.***

*265. As detailed herein, Ms. Grant was exploited during her time of employment with* *WWE and was subjected to countless depraved and humiliating acts, which has led to severe and* *permanent trauma. She has been further traumatized by having to relive those experiences when* *giving evidence to the government in connection with their investigations of WWE.*

*266. Indeed, Ms. Grant’s trauma (and ongoing fears of additional retaliation) was so* *severe that she required extended inpatient treatment. Today, she lives with so much anxiety and* *depression that she is unable to leave her residence for weeks at a time out of fear and PTSD.*

*267. Due to this trauma and inability to leave her home, Ms. Grant was terminated from* *employment on January 27, 2023 where she lost not only her dream job of managing her building* *but the only job she could procure without the need for any references. Ms. Grant’s lost income* *is $80,000 per year.*

*268. The severe restrictions of the NDA have created a wedge in all of Ms. Grant’s* *relationships and left her in a perpetual state of isolation, as her family has passed away and she* *cannot (and does not) lean on the support of the community due to the NDA’s restrictions.*

*269. Further, Ms. Grant has experienced weight loss, insomnia, rashes, flashbacks to her* *exploitation, nightmares, panic attacks, and depression. Ms. Grant will go days without brushing* *her teeth, taking a shower, or washing her clothes. On many days, she doesn’t leave her bed.*

*270. Ms. Grant will prove at trial that she will need lifelong treatment because of the* *pain and suffering inflicted upon her by Defendants.*

***CAUSES OF ACTION***

***Count I***

***Declaratory Relief – NDA Voided Under Speak Out Act, 42 U.S.C. § 19401 et seq.* *Against McMahon and WWE***

*271. Plaintiff incorporates paragraphs 1 through 270 as if fully stated herein.*

*272. The NDA attached as Exhibit A was entered into on January 28, 2022.*

*273. The Speak Out Act, 42 U.S.C. § 19401 et seq., was enacted on December 7, 2022,* *and “appl\[ies\] with respect to a claim that is filed under Federal, State, or Tribal law on or after* *December 7, 2022.” 42 U.S.C. § 19404.*

*274. The Speak Out Act defines a “sexual assault dispute” as “a dispute involving a* *nonconsensual sexual act or sexual contact, as such terms are defined in section 2246 of title 18 or* *similar applicable Tribal or State law, including when the victim lacks capacity to consent” and a* *“sexual harassment dispute” as “a dispute relating to conduct that is alleged to constitute sexual* *harassment under applicable Federal, Tribal, or State law.” 42 U.S.C. § 19402.*

*275. The Speak Out Act provides that, “\[w\]ith respect to a sexual assault dispute or* *sexual harassment dispute, no nondisclosure clause or nondisparagement clause agreed to before* *the dispute arises shall be judicially unenforceable in instances in which conduct is alleged to have* *violated Federal, Tribal, or State law.” 42 U.S.C. § 19403.*

*276. The allegations herein include sexual harassment and assault disputes as defined by* *the Speak Out Act, and the NDA seeks to bar the claims brought herein.*

*277. Because the claims themselves constitute the dispute as of the date of this* *Complaint filing then, pursuant to the Speak Out Act, the core term of the NDA, and thus the NDA* *itself, is judicially unenforceable and Plaintiff is entitled to declaratory judgment.*

***Count II***

***Declaratory Relief – NDA Voided Under Common Law* *Against McMahon and WWE***

*278. Plaintiff incorporates paragraphs 1 through 277 as if fully stated herein.*

*279. The NDA appearing at Exhibit A is void and unenforceable pursuant to Connecticut* *common law for at least five reasons.*

*280. First, the scope of the NDA, including the confidentiality provision, is* *impermissibly broad. It provides Ms. Grant will not “disclose, discuss or reveal any claims against,* *or information about, McMahon, her relationship with McMahon, WWE, or any employees or* *independent contractors of WWE, to third parties, on social media, in any public forum, or to any* *member of the media” (emphasis added). Read literally, this would prevent her from disclosing* *the mere fact she worked for WWE in an interview or on her resume. Further, “confidential* *information” was not defined, and thus is overbroad, particularly in light of information that has* *since become public knowledge. There cannot have been a meeting of the minds on the overly* *broad confidentiality provision.*

*281. Second, the NDA is invalid in that Ms. Grant entered into the contract under duress* *and undue influence, as detailed herein. There was a drastic power difference and economic* *disparity: Ms. Grant, who had never held a paying office job in her life due to caretaking for her* *parents, was up against McMahon and WWE – titans of the wrestling and entertainment worlds.* *The emotional and mental abuse and trauma endured by Ms. Grant further compounded this* *disparity such that Ms. Grant felt like she did not have a real say or choice in the matter. McMahon* *also exerted relentless pressure on Ms. Grant. As but one example, McMahon left her an extensive* *voice memo shortly before the NDA was signed, wherein he emphasized the public nature of the* *WWE and the consequences that could result if the NDA was not signed before an audit committee* *convened.*

*282. Third, the NDA is a contract of adhesion; there was no meaningful choice for Ms.* *Grant. Proposed revisions by Ms. Grant’s attorney were consistently and ultimately rejected by* *McMahon’s attorney, and during that time McMahon was pressuring Ms. Grant to sign the* *agreement.*

*283. Fourth, the NDA is substantively unconscionable in that it is clearly one-sided. For* *example, the non-disparagement provision only applies to Ms. Grant and not McMahon or the* *WWE. Further, although she was slated to receive $1,000,000 (and $2,000,000 in installments of* *$500,000 over the years), Ms. Grant also gave up her job at WWE as a result of this agreement.* *Plaintiff’s compensation is also out of line with what similarly situated individuals have received.* *The agreement is even more one-sided with respect to the WWE because only McMahon is* *responsible for payments. The WWE’s only obligations are to not sue Ms. Grant and to write a* *favorable letter of recommendation to a future employer upon request; notably, however, per the* *terms of the NDA, that letter would come from now-fired/disgraced former employee Defendant* *Laurinaitis who raped and sexually assaulted Ms. Grant.*

*284. Fifth, the NDA is void as against public policy. The NDA purports to silence a* *victim of unlawful sexual abuse and prevent her from taking steps to protect other women at WWE.* *The policies at issue include those that were the impetus for the Speaks Out Act.*

*285. Under Connecticut law, courts will not “blue pencil” contracts where the* *unreasonable provision forms the heart of an agreement, such as here where the non-disclosure* *provision forms the heart of the contract. Thus, the entirety of the NDA must be deemed void and* *unenforceable, even if the confidentiality term were the only invalid term (it is not).*

*286. The NDA has, in any event, been breached by McMahon and the WWE in that Ms.* *Grant did not receive a second payment of $500,000 within 10 days of February 1, 2023.*

***Count III***

***Violation of TVPA, 18 U.S.C. §§ 1591, 1595* *Against McMahon and Laurinaitis***

*287. Plaintiff incorporates paragraphs 1 through 286 as if fully stated herein.*

*288. At all times relevant, McMahon was engaged in travel throughout the United States* *for purposes of conducting business in his position with the WWE. McMahon communicated with* *Plaintiff while traveling across the country (and internationally) to recruit, entice, obtain, provide,* *maintain and/or solicit Plaintiff for purposes of engaging in sexual acts. He also flew others and/or* *caused others to travel to Connecticut, including Laurinaitis and WWE Superstar, from out of state* *for the purpose of sexually exploiting Ms. Grant.*

*289. At all times relevant, McMahon and Laurinaitis recruited, enticed, obtained,* *provided, maintained, supervised, or otherwise solicited Ms. Grant to engage in sexual conduct* *with the assurance that Plaintiff would be given a position at WWE, job security within the WWE,* *and advancement within the WWE.*

*290. At all times relevant, McMahon and Laurinaitis knew that they would use fraud or* *coercion (as they had done to other women in the past) on Plaintiff for sexual encounters.* *McMahon and Laurinaitis offered job placement and security, as well as numerous gifts and* *special treatment, and assurances of personal protections (i.e., McMahon’s financial protection,* *reputational protection, and medical care) and promised these would continue if Plaintiff remained* *loyal and obedient by engaging in the sex acts described herein.*

*291. McMahon and Laurinaitis were well aware that a job at WWE and advancement* *and protections outlined above were of significant value to Plaintiff and used that against her.*

*292. As a result, McMahon and Laurinaitis were able to force, defraud, or coerce Ms.* *Grant into continued sexual activity because of promises of job placement, job security, and* *advancement with the WWE and personal protections outlined above.*

*293. McMahon knew that Plaintiff’s position would ultimately be temporary, as* *numerous other women had been employed by WWE, only to be dismissed with NDAs and* *releases.*

*294. At all times relevant, Plaintiff was subjected to coercion in that a scheme, plan or* *pattern was in place that was designed to cause Plaintiff to believe that failure to perform sexual* *acts as alleged herein would result in serious harm, including but not limited to financial harm,* *reputational harm, invasion of privacy, loss of control over her image, losing her job with WWE,* *termination from subsequent employment, and/or loss of career trajectory.*

*295. At all times relevant, McMahon sought to exploit Plaintiff’s vulnerabilities in that* *he knew she had been through past trauma, grief, and had been unable to find employment prior* *to joining WWE.*

*296. At all times relevant, McMahon and Laurinaitis held positions of power over Ms.* *Grant, controlled her continued employment with WWE, and pressured her to engage in sex acts.*

***Count IV***

***Participating in Venture in Violation of TVPA, 18 U.S.C. §§ 1591, 1595* *Against WWE***

*297. Plaintiff incorporates paragraphs 1 through 296 as if fully stated herein.*

*298. WWE knowingly participated in the trafficking described above in violation of* *18 U.S.C. §1595 by benefiting from and knowingly facilitating the venture in which McMahon* *traveled for WWE affairs across the United States and recruited or enticed females such as Plaintiff* *into coerced sexual encounters on the promise of employment with WWE, job security and* *advancement.*

*299. WWE knew, or recklessly disregarded, that it was the practice of McMahon to* *entice, recruit, force, and/or coerce women into sexual acts based on the promise of a new life, a* *job, an income, job security, and advancement within the WWE, including with respect to Plaintiff.* *Alternatively, WWE reasonably should have known of these facts under the circumstances and is* *subject to liability pursuant to the civil remedy provision of the TVPA, 18 U.S.C. § 1595(a).*

*300. As detailed herein, WWE employees, executives, and Board Members were aware* *of McMahon’s exploits involving Plaintiff. Some were told, some were shown exploitative* *pictures, some witnessed unusual and/or overtly sexual behaviors by McMahon and/or Laurinaitis,* *and others could not help but hear what was going on through the walls at WWE’s headquarters.*

*301. As detailed herein, WWE had been privy to multiple allegations against McMahon* *involving those similar in nature as alleged herein, prior to Plaintiff’s employment with WWE.*

*302. Despite this knowledge, WWE continued to facilitate and/or supervise McMahon’s* *wishes of hiring and/or advancing Plaintiff within the company.*

*303. As detailed herein, McMahon showed numerous WWE employees sexually explicit* *photographs and/or video of Ms. Grant, which demonstrates the knowledge of those specific* *employees and constructive evidence that other employees would have learned of this.*

*304. Upon information and belief, other WWE employees benefited financially in* *helping to assist, support and facilitate the commercial sex acts of McMahon in that WWE’s* *culture revolved around trust relationships, increased status with McMahon and prioritizing the* *protection of the company. For instance, both WWE Corporate Officer No. 1 and WWE Corporate* *Officer No. 2 continued to assist in maintaining a position at WWE, as well as advancement* *opportunities, for Ms. Grant after being told of McMahon’s relations with her. Upon further* *information and belief, other employees were forced to resign or were let go if they knew of* *McMahon’s exploits and failed to assist, support and/or facilitate them, such as former WWE* *employee, WWE Corporate Officer No. 4.*

*305. WWE benefited financially from the commercial sex act venture orchestrated by* *McMahon, including by having wrestling talent, such as WWE Superstar, sign new contracts with* *WWE after McMahon presented Plaintiff as a sexual commodity for their use.*

***Count V***

***Negligence* *Against WWE***

*306. Plaintiff incorporates paragraphs 1 through 305 as if fully stated herein.*

*307. WWE has a responsibility and duty as an employer to ensure the safety, protection,* *and well-being of its employees.*

*308. Notwithstanding its responsibility and duties, WWE knew, or reckless disregarded,* *that it was the practice of McMahon and Laurinaitis to entice, recruit, force, and/or coerce women* *into sexual acts based on the promise of hire, job security and advancement within the WWE,* *including with respect to Plaintiff. Alternatively, WWE reasonably should have known of these* *facts under the circumstances.*

*309. WWE did nothing to prevent McMahon’s and Laurinaitis’s conduct or protect* *employees like Ms. Grant from it and took no appropriate actions against the risk of harm.*

*310. As a result of WWE’s negligence, Ms. Grant has suffered damages in the form of* *the harmful or offensive contact herein described, and the same caused pain and injury to Plaintiff,* *as well as mental and emotional trauma that is permanent in nature as described herein.*

*311. Ms. Grant’s injuries and damages were caused by the negligence of WWE, its* *employees and agents, for whose negligence WWE is liable in the following ways:*\
*a. WWE, by commission and omission, allowed and tolerated sexual assault* *and humiliation and fostered a culture in which such acts would be* *tolerated;*\
*b. WWE, by commission and omission, retained McMahon and Laurinaitis* *despite actual and/or constructive knowledge of their propensity to entice,* *recruit, force, and/or coerce women into sexual acts based on the promise* *of hire, job security and advancement within the WWE; and*\
*c. WWE failed to warn Ms. Grant of the risk of harm to which she was* *subjected while employed by WWE.*

*312. WWE owed Ms. Grant a duty of care, it breached that duty, and its breach caused* *Ms. Grant to suffer the acts, injuries, and damages described in this Complaint.*

***Count VI***

***Civil Battery* *Against McMahon and WWE***

*313. Plaintiff incorporates paragraphs 1 through 312 as if fully stated herein.*

*314. As alleged herein, Plaintiff was subjected to numerous instances of civil battery* *after meeting McMahon and even after the NDA was signed, including by way of the following* *examples:*\
*a. On July 21, 2021, McMahon demanded that Plaintiff “eat him” and perform* *oral sex. Ms. Grant pleaded that she couldn’t breathe and needed air and* *asked that the encounter stop. However, McMahon persisted and verbalized* *his role play fantasy while pretending to be WWE Superstar. As Ms. Grant* *begged for the encounter to stop multiple times, including “Help!” “I’m* *serious!” and “I’m scared!” as McMahon – among other things – penetrated* *her, fisted her, pulled her hair, pinned her, shoved her, and open-palm* *slapped her. McMahon’s assault caused Ms. Grant to break down into* *visible weeping and curl up into the fetal position with her arms pulled up* *to protect her face. McMahon alternated between slaps and shoves while* *Ms. Grant remained motionless in the fetal position and wept “Vince, I* *don’t recognize you” two times. Only at that point, McMahon stopped.*\
*b. After the NDA was executed, McMahon grabbed Plaintiff’s arm to turn her* *around when she was leaving, forced her to kneel, grabbed her head and* *slammed it into his groin while saying, “Take it, bitch.”*

*315. In all such instances, McMahon intended to engage in the harmful and offensive* *contact herein described and complained of.*

*316. As a direct and proximate result, Ms. Grant experienced damages in the form of the* *harmful or offensive contact herein described, and the same caused  pain and injury to Plaintiff, as* *well as mental and emotional trauma that is permanent in nature as described herein.* *317. In all such instances, McMahon’s conduct was malicious in nature in that he sought* *to degrade, humiliate, and objectify Plaintiff for his own gratification.*

*318. WWE is vicariously liable for the conduct of McMahon described above.*

***Count VII***

***Civil Battery* *Against Laurinaitis and WWE***

*319. Plaintiff incorporates paragraphs 1 through 318 as if fully stated herein.*

*320. As alleged herein, Plaintiff was subjected to numerous instances of civil battery* *after meeting Laurinaitis. On numerous occasions, he pressed her to perform oral sex for him on* *demand, including in his office within company headquarters, and even in the middle of a workday* *while colleagues were busy at their desks.*

*321. During a June 15, 2021, encounter with McMahon and Laurinaitis in the latter’s* *office, Laurinaitis shoved his tongue in Ms. Grant’s mouth after she had pleaded to stop the whole* *encounter, then unzipped his pants and shoved his penis into Plaintiff’s mouth.*

*322. In all such instances of battery perpetrated by Laurinaitis, he intended to engage in* *the harmful and offensive contact herein described and complained of by Plaintiff.*

*323. As a direct and proximate result of the forgoing, Ms. Grant experienced damages* *in the form of the harmful or offensive contact herein described, and the same caused pain and* *injury to Plaintiff, as well as permanent psychological and emotional trauma.*

*324. In all such instances, Laurinaitis’ conduct was malicious in that he sought to* *degrade, humiliate, and objectify Plaintiff for his own gratification.*

*325. WWE is vicariously liable for the acts of Laurinaitis described above.*

***Count VIII***

***Intentional or Negligent Infliction of Emotional Distress* *Against McMahon and WWE***

*326. Plaintiff incorporates paragraphs 1 through 325 as if fully stated herein.*

*327. As detailed herein, McMahon intended to inflict emotional distress—or knew or* *should have known that emotional distress was the likely result of his conduct.*

*328. McMahon’s conduct was extreme and outrageous. Examples include:*\
*a. McMahon sexually assaulted Ms. Grant on numerous occasions. He was* *aggressive during sexual encounters with Ms. Grant to the point of causing* *her pain, including during encounters she tried to stop.*\
*b. McMahon objectified and trafficked Ms. Grant. He demanded that Ms.* *Grant engage in threesomes with other men and that she send explicit* *photographs for him to share with other men, despite Ms. Grant on multiple* *occasions explaining that she was hesitant to obeying, and all while* *McMahon controlled Ms. Grant’s job security.*\
*c. McMahon regularly humiliated and degraded Ms. Grant. As one example,* *McMahon defecated on Ms. Grant and directed her to continue sexually* *performing while covered in his fecal matter.*\
*d. McMahon created an environment of fear and secrecy by warning Ms.* *Grant of the grave consequences of not being discreet about their sexual*\
*encounters while at the same time sharing explicit photographs of her with* *others inside and outside of the Company and directing her to sexually* *service other WWE-affiliated individuals.*\
*e. McMahon sent perverted messages to Ms. Grant that involved the latter* *being subjected to sexual scenarios involving extreme pain and humiliation,* *including during instances when Ms. Grant clearly attempted to avoid a text* *message exchange that was sexually charged. McMahon would push back,* *question the Plaintiff and/or become cold or distant if Ms. Grant pushed* *back or ignored his sexually charged messages.*\
*f. McMahon promised other men that the Plaintiff would “do anything” they* *desired and provided the Plaintiff’s personal cell number (without her* *permission) for the purpose of her performing and/or providing humiliating* *sexual acts, such as exploitative pictures and videos, including of her* *urinating. McMahon ordered Ms. Grant to report all such exchanges to him.*

*329. As described herein, McMahon’s conduct caused Plaintiff’s emotional distress,* *including in that her distress would result from manipulative and coercive controlling conduct* *engaged in by McMahon. Further, Plaintiff’s resulting emotional distress includes flashbacks and* *bouts of PTSD brought on by the conduct engaged in by McMahon.*

*330. As described herein, Plaintiff’s emotional distress is severe, long lasting, and* *permanent, in that, for example, she has needed inpatient and outpatient care following her* *separation from WWE and that she continues to be impacted with distress and resulting adverse* *consequences and diminished quality of life in her day-to-day life.*

*331. McMahon’s conduct was malicious in nature in that he sought to degrade,* *humiliate, and objectify Plaintiff for his own gratification throughout her employment with WWE.*

*332. WWE is vicariously liable for the conduct of McMahon described above.*

***Count IX***

***Intentional or Negligent Infliction of Emotional Distress* *Against Laurinaitis and WWE***

*333. Plaintiff incorporates paragraphs 1 through 332 as if fully stated herein.*

*334. As detailed herein, Laurinaitis intended to inflict emotional distress—or knew or* *should have known that emotional distress was the likely result of his conduct. Laurinaitis’ conduct* *was extreme and outrageous, and examples of this include the following:*\
*a. Treated Ms. Grant as a sexual object over which he had been given complete* *control by McMahon and forced Ms. Grant to sexually service him on* *demand, including in his office at WWE headquarters.*\
*b. Forced Ms. Grant to walk to his hotel on certain mornings to serve herself* *to him as “breakfast,” a euphemism for sexual service.*\
*c. Engaged in aggressive sexual encounters with Ms. Grant and McMahon,* *including a sexual assault in a WWE conference room where he inserted his* *penis into Ms. Grant’s mouth despite her protest.*\
*d. Despite being Plaintiff’s direct supervisor at WWE, Laurinaitis would* *almost always conduct himself in a way that was overtly sexual and* *objectified Plaintiff, including by asking for explicit photographs and sexual* *encounters at WWE Headquarters.*

*335. As described herein, Laurinaitis’ conduct was the cause of Plaintiff’s emotional* *distress, including in that her distress would result from unwanted conduct engaged in by* *Laurinaitis, who was also her boss. Further, Plaintiff’s resulting emotional distress includes* *flashbacks and bouts of PTSD brought on by the conduct engaged in by Laurinaitis.*

*336. As described herein, Plaintiff’s emotional distress is severe, long lasting, and* *permanent, in that, for example, she has needed inpatient and outpatient care following her* *separation from WWE and that she continues to be impacted with distress and resulting adverse* *consequences and diminished quality of life in her day-to-day life.*

*337. WWE is vicariously liable for the acts of Laurinaitis described above.* *WHEREFORE, Plaintiff respectfully requests:*\
*a. Declaratory judgment that the NDA is void and unenforceable, and does not* *bar any of Plaintiff’s claims against Defendants McMahon and WWE;*\
*b. Judgment for compensatory damages, reasonable attorneys’ fees, costs and* *punitive damages against Defendants pursuant to 18 U.S.C. § 1595 and*\
*other applicable laws; and*\
*c. Such other and further relief as the Court deems just and proper.*

*Respectfully, submitted, this 25th day of January, 2024.*\
*By: \[signature\]*\
*ROBINSON & COLE LLP*\
*Benjamin M. Daniels (ct29713)*\
*280 Trumbull Street*\
*Hartford, CT 06103*\
*(860) 275-8200 Telephone*\
*(860) 275-8299 Facsimile*\
*bdaniels@rc.com*\
*HOLLAND LAW FIRM, LLC*\
*Eric D. Holland (to be admitted pro hac vice)*\
*Gregory R. Jones (to be admitted pro hac vice)*\
*211 North Broadway, Suite 2625*\
*St. Louis, MO 63102*\
*(314) 241-8111 Telephone*\
*(314) 241-5554 Facsimile*\
*eholland@hollandtriallawyers.com*\
*gjones@hollandtriallawyers.com*\
*Ann E. Callis (to be admitted pro hac vice)*\
*6181 Bennett Drive, Suite 210*\
*Edwardsville, Illinois 62025*\
*(618) 452-1323 Telephone*\
*(618) 452-8024 Facsimile*\
*acallis@hollandtriallawyers.com*\
*Attorneys for Plaintiff Janel Grant*

If you have been affected by any of the subjects mentioned above, information on where you can find support can be found [at this link](https://wrestletalk.com/features/support-wrestletalk-support-each-other/).

([Source](https://storage.courtlistener.com/recap/gov.uscourts.ctd.157647/gov.uscourts.ctd.157647.1.0.pdf))