Case 3:14-cv-01689-ST Document 1 Filed 10/23/14 Page 1 of 42 Steve D. Larson, OSB No. 863540 Email:
[email protected] Joshua L. Ross, OSB No. 034387 Email:
[email protected] STOLL STOLL BERNE LOKTING & SHLACHTER P.C. 209 S.W. Oak Street, Suite 500 Portland, Oregon 97204 Telephone: (503) 227-1600 Facsimile: (503) 227-6840 Attorneys for Plaintiff William Albert Haynes III IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON WILLIAM ALBERT HAYNES III, individually and on behalf of all others Case No. ________________ similarly situated, Plaintiffs, CLASS ACTION ALLEGATION COMPLAINT v. WORLD WRESTLING JURY TRIAL DEMANDED ENTERTAINMENT, INC., Defendant. Plaintiff William Albert Haynes III (“Plaintiff”), alleges the following upon personal knowledge as to his own transactions and upon information and belief as to all other matters. Page 1 - CLASS ACTION ALLEGATION COMPLAINT Case 3:14-cv-01689-ST Document 1 Filed 10/23/14 Page 2 of 42 INTRODUCTION 1. This class action concerns World Wrestling Entertainment, Inc.’s (“WWE”) egregious mistreatment of its wrestlers for its own benefit, as well as its concealment and denial of medical research and evidence concerning traumatic brain injuries suffered by WWE wrestlers.1 Under the guise of providing “entertainment,” WWE has, for decades, subjected its wrestlers to extreme physical brutality that it knew, or should have known, caused long-term irreversible bodily damage, including brain damage. For most of its history, WWE has engaged in a campaign of misinformation and deception to prevent its wrestlers from understanding the true nature and consequences of the injuries they have sustained.