The Latest: Janel Grant files petition for medical records related to WWE, Vince McMahon lawsuit

Welcome to another episode of The Latest with Denise Salcedo breaking down the biggest wrestling news headlines of the week so far.

Topics:

–Janel Grant files petition for medical records related to WWE, Vince McMahon lawsuit

— Liv Morgan accepts Rhea Ripley’s Women’s World title challenge for WWE SummerSlam

— Ric Flair would have ‘no problem’ with John Cena breaking World title record

Janel Grant files petition for medical records related to WWE, Vince McMahon lawsuit

Lawyers representing Janel Grant have filed a petition in Connecticut court.

Grant’s attorneys submitted a pre-action discovery petition against Peak Wellness Inc. and the company’s owner and CEO, Dr. Carlon Colker. The petition is seeking medical records related to Grant’s treatment at the clinic as it concerns her sex trafficking lawsuit against WWE, Vince McMahon, and John Laurinitis.

Grant alleges that McMahon arranged for her to be seen at the clinic and that she received pills and IV treatments from Colker but was never informed about the substances she was given.

A spokesperson for Vince McMahon issued the following statement to WON/F4W, stating that the filing by Grant’s attorneys is in violation of the court-ordered stay:

“Ms. Grant’s petition for pre-action discovery against Dr. Colker is a direct violation of the court-ordered stay, and nothing more than an attempt to generate publicity on her false allegations and to harass people connected to Mr. McMahon, who is being sued by Ms. Grant in a separate matter. The facts are that Ms. Grant told Mr. McMahon she was fatigued and asked him to recommend a doctor.  Ms. Grant called Dr. Colker and became a patient of his.  Her statement in the filing is inconsistent with her prior remarks.  Ms. Grant never had anything but good things to say about the doctor when speaking to Mr. McMahon and others about him.”

Grant’s attorneys are seeking to receive records of the following from Dr. Colker and Peak Wellness Inc:

  1. Plaintiff’s electronic medical records, including all associated metadata;
  2. Defendants’ recordkeeping and billing procedures;
  3. Payment records relating to Ms. Grant;
  4. Defendants’ payment arrangements with McMahon and/or the WWE;
  5. The purpose of Ms. Grant’s prescribed treatments;
  6. The substance of Ms. Grant’s prescribed treatments;
  7. Any communications between Dr. Colker and McMahon relating to Ms. Grant; and
  8. Dr. Colker’s involvement in recommending Ms. Grant’s attorney for negotiation of the purported non-disclosure agreement.

Other key parts of the petition read:

“Peak Wellness operates a medical center that markets itself as providing traditional medical care along with advanced diagnostics, functional medicine, naturopathy, physical medicine, anti-aging, and aesthetics.”

“Dr. Colker is Chief Executive Officer and Medical Director of the medical center. Upon information and belief, Dr. Colker routinely treats employees and talent of World Wrestling Entertainment.”

“In or about November 2019, McMahon arranged that Ms. Grant see Dr. Colker to treat her fatigue and insomnia. At McMahon’s direction, Ms. Grant began seeing Dr. Colker regularly. From November 22, 2019 through April 15, 2022, Ms. Grant saw Dr. Colker or another practitioner at Peak Wellness on at least 60 occasions.”

“On multiple visits, Dr. Colker prescribed Ms. Grant with ‘adrenal trays’ or ‘adrenal supplement trays,’ provided by his office and instructed her to take the unmarked pills daily. Dr. Colker did not explain the substances, dosages, or purpose of the pills to Ms. Grant beyond purportedly addressing her symptoms of fatigue. When Ms. Grant asked Dr. Colker about the substance of the supplement trays, and specifically which substance(s) caused her to experience nausea, he responded with pushback about trust, including, ‘If you don’t trust me, we have bigger problems.'”

“Dr. Colker also prescribed weekly I.V. infusions, and similarly did not disclose the substance of the infusions to Ms. Grant, other than a generalized description in a “drip lounge” menu. These treatments caused Ms. Grant to feel unwell during the I.V. sessions, which Dr. Colker attributed to individual ‘tolerance.'”

“Additionally, an employee of Peak Wellness also was involved in several instances of sexual abuse against Ms. Grant by McMahon as further described in Ms. Grant’s federal complaint.”

“On Ms. Grant’s last visit to Peak Wellness in April 2022, Dr. Colker demanded that she sign a statement that required her to provide a credit card to pay for her visits to the clinic. When Ms. Grant refused, Dr. Colker berated her and asked, ‘What’s the matter, Janel – is there a problem with money? Is this about the NDA?'”

“By letters dated February 5, 2024 and March 20, 2024, Ms. Grant, through counsel, requested her medical records from Peak Wellness in electronic format pursuant to the Health Information Technology for Economic and Clinical Health Act (“HITECH Act”).”

“In response to each letter, Dr. Colker and Peak Wellness provided records to Ms. Grant’s counsel in paper copies only. Peak Wellness used electronic recordkeeping for Ms. Grant’s medical records, as she was instructed to utilize an iPad for administrative purposes, such as patient intake, in the Peak Wellness office. To date, despite repeated requests, Dr. Colker and Peak Wellness has failed or refused to provide Ms. Grant’s electronic medical records, including any associated metadata.”

“Upon review, Ms. Grant and her counsel noticed that the provided paper records are incomplete and inaccurate. For example, there are billing records that do not have a corresponding medical record, medical records that do not have a corresponding billing record, inconsistent billing rates, and double charges.”

“The medical records provided by Peak Wellness also do not contain a copy of Peak Wellness’ Privacy Policy, despite the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) requirement that covered entities distribute a plain-language Notice of Privacy Practices to all patients describing their policies for using and distributing protected health information.”

“Additionally, each of the “Patient Receipts” Defendants provided itemize the charges for each service provided and indicate that “Patient Paid” the full amount. However, Ms. Grant never received or paid a single medical bill from either Peak Wellness or Dr. Colker.”

“Upon information and belief, McMahon and/or WWE paid each of Ms. Grant’s medical bills from Peak Wellness and Dr. Colker, totaling over $51,000.”

“Further, Dr. Colker had personal knowledge of the circumstances surrounding a purported non-disclosure agreement at issue in the Federal Action. Specifically, during the negotiation of the purported non-disclosure agreement, McMahon approved of Ms. Grant asking Dr. Colker for an attorney referral. Dr. Colker recommended Defendants’ attorney to Ms. Grant and, upon McMahon’s approval, Ms. Grant engaged that attorney to represent her in the negotiation of the purported non-disclosure agreement.”

“The information that Ms. Grant has requested is material and necessary to determine whether Defendants were civil conspirators in her pending claims against McMahon and the WWE.”

“The information is also material and necessary to determine whether Defendants have engaged in falsifying medical records, Racketeer Influenced and Corrupt Organizations Act (“RICO”) violations, RICO conspiracy, assault, battery, and/or breaches of fiduciary against Ms. Grant.”

“Plaintiff has potential causes of action sounding in civil conspiracy, aiding and abetting, fraud, assault, battery, RICO, RICO conspiracy, and/or breach of fiduciary duty that will be supported by the materials sought.”

Grant’s lawsuit against WWE, McMahon, and Laurinitis is currently paused per a request from the Department of Justice as they continue a federal investigation into McMahon.

Judge officially pauses Vince McMahon/Janel Grant lawsuit

The judge in the Janel Grant/Vince McMahon/WWE lawsuit has officially put the lawsuit on pause.

Judge Jeffery A. Meyer on Tuesday officially put Grant’s lawsuit against Vince McMahon, John Laurinaitis, and WWE on pause after both sides agreed to pause the suit per a request from the Department of Justice as they continue a federal investigation regarding McMahon. The case will be put on pause for the next six months, meaning the lawsuit at the earliest won’t resume until December 11.

In a statement to Wrestlenomics, a spokesperson for McMahon said they did not object to pause the suit.

Mr. McMahon is eager to prove Ms. Grant’s claims are false and expose her lies, but did not object to the government’s request to pause the matter in connection with the investigation regarding disclosures at WWE. Following the six-month stay, when his legal team is able to get discovery and depose Ms. Grant and others, the evidence will show the relationship was consensual and Ms. Grant’s allegations are malicious fabrications of a jilted lover.

With the pause, the defendant’s motion to compel arbitration has been denied, along with Grant’s motion to strike comments from McMahon’s filings. However, they were denied “without prejudice,” meaning the motions can be renewed two weeks after the case resumes.

On May 30, Grant agreed to delay the lawsuit at the Justice Department’s request. She filed the lawsuit in January accusing McMahon and Laurinaitis of sexual assault and trafficking, something both have denied.

John Laurinaitis files statement regarding Janel Grant, Vince McMahon lawsuit

John Laurinaitis has filed a “statement of material facts” regarding Janel Grant’s lawsuit against him, WWE, and Vince McMahon.

Two weeks ago, Grant agreed to pause her litigation in response to a request by the US Attorney’s office pending a non-public investigation into the matter. However, on June 8, Laurinaitis’ legal team filed a document with three stated facts in support of the motion to send Grant’s lawsuit to private arbitration. They also state that Laurinaitis believed he was a “released party” of any lawsuits brought on by Grant due to her NDA with WWE and McMahon.

Laurinaitis’ filing reads:

“I, John Laurinaitis, declare under penalty of perjury as
follows:

  • At all times material to the allegations set forth in the Complaint, I was an employee of World Wrestling Entertainment, Inc.
  • As a full-time employee of WWE, it is my understanding that I was listed as a released party from any and all lawsuits or causes of action by Plaintiff Grant.
  • Pursuant to the terms of the Confidential Settlement Agreement, General Release, and Covenant Not to Sue (Dkt. 30-2) it is my understanding that the sole and exclusive legal method to resolve any disputes related to the Confidential Settlement Agreement would be in binding arbitration under the Federal Arbitration Act.”

Laurinaitis filed a motion in support of sending the lawsuit to arbitration in a filing early last month. He had previously claimed, through lawyers, that he was also a victim of McMahon in regards to the allegations made by Grant. 

“Like the Plaintiff, Mr. Laurinaitis is a victim in this case, not a predator. The truth will come out,” Laurinaitis’ lawyer said in a statement on February 1.  

Wrestling Observer Radio: Steve Keirn interview, AEW business notes

Dave Meltzer and I are back with Wrestling Observer Radio going over the big stories in the latest issue of the Wrestling Observer Newsletter.

But first, Steve Keirn joined us to discuss his brand new book, which is part two of his career in wrestling. We talked about his run in WWF at the time, a little bit about his WCW run, and then a lot about his job as a producer/agent for Vince McMahon as well as his trainer role at FCW which predated NXT.

Links for both of his books:

Then, Dave and I wrapped things up talking about the following:

  • The latest on the Janel Grant lawsuit
  • WWE contracts coming up
  • Dave’s story on AEW’s TV rights
  • AEW Dynamite and NXT ratings
  • AEW Double or Nothing early buys
  • Tyson/Paul postponement

We put this show up on the free YouTube page, which you can watch below. If you want to see Dave and I do this show live on video every week, you can subscribe at https://video.f4wonline.com/.

Click here to Listen (sub needed)

Wrestling Observer Live: Dynamite, Forbidden Door, Owen Hart Cup, tons of AEW news

Wrestling Observer Live with Bryan Alvarez and Mike Sempervive is back with tons to talk about including many, many thoughts on AEW Dynamite, the awesome main event, the reaction to Mercedes and how she is being positioned, the main event of Forbidden Door and trying to figure out the Ospreay booking, and tons more. A fun show as always so check it out~!

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Janel Grant delays Vince McMahon, WWE lawsuit at Justice Department’s request

Janel Grant has agreed to pause her lawsuit against Vince McMahon, WWE, and John Laurinaitis.

According to comments from Ann Callis, the attorney representing Grant, her client has agreed to a request by the US Attorney’s office to stay her litigation pending a non-public investigation into the matter.

“Ms. Grant has consented to a request by the US Attorney for the Southern District of New York to stay her case against Mr. McMahon, WWE and Mr. Laurinaitis, pursuant to a pending non-public investigation,” Ann Callis, an attorney for Grant, said in an emailed statement to Bloomberg on Thursday. “We will cooperate with all appropriate next steps.”

In February, The Wall Street Journal and ABC News reported that the US Attorney for the Southern District of New York had launched a criminal investigation into allegations of sexual misconduct and sex trafficking against McMahon.

“Basically the Grant lawsuit is pausing at the request of the Justice Department as the goverment is conducting its own investigation,” wrote our own Dave Meltzer.

McMahon’s lawyer Jessica Rosenberg, a partner of Kasowitz, Benson Torres, issued the following statement to WON/F4W and other media:

“We remain confident the evidence will prove Ms. Grant’s allegations are false and her complaint is nothing more than a fabricated, vindictive narrative from a disgruntled former girlfriend.”

The stay is expected to last six months, a source close to the case stated to Bloomberg.

Wrestling Observer Radio: Vince McMahon vs. Janel Grant latest, AEW Dynamite live report

Wrestling Observer Radio with Bryan Alvarez and Dave Meltzer is back with tons to talk about including the latest on Vince McMahon and Janel Grant, WrestleMania claims regarding Las Vegas tourism, ratings, the Dominion lineup, AEW Dynamite and NXT TV reviews, and tons more. A fun show as always so check it out~!

Timestamps:
Start: WWE sides with Vince McMahon in Janel Grant lawsuit
22:41: WWE’s wild numbers for WrestleMania 41
25:50: Ratings
30:58: NJPW Dominion lineup, Willow Nightingale vs. Tam Nakano Stardom match, Paul Walter Hauser in MLW’s Battle Riot IV
36:00: AEW Dynamite recap
1:12:30: NXT notes
1:17:41: NXT spoilers for next week

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The Latest: WWE supports Vince McMahon motion in Janel Grant lawsuit

Welcome to another episode of The Latest with Denise Salcedo breaking down the biggest wrestling news headlines of the week so far.

On today’s episode, we have another update in regards to the Vince McMahon/Janel Grant lawsuit. McMahon has filed a ‘Statement of Undisputed Material Facts,’ plus WWE supports McMahon’s motion.

In other news, the Las Vegas tourism group approved $5 million to host WWE WrestleMania, and Drew McIntyre discussed why he chose to stay with WWE.

WWE supports Vince McMahon motion in Janel Grant lawsuit

WWE is siding with Vince McMahon in the lawsuit against Janel Grant.

The company filed a memorandum on Wednesday in support of Vince McMahon’s motion to compel arbitration, disputing Grant’s allegations in the lawsuit.

“WWE disputes Grant’s allegations. But, as a threshold matter, this dispute cannot be heard in court because Grant agreed to arbitrate her claims. WWE therefore moves to compel this action to arbitration,” WWE said in the filing.

If the case moves to arbitration, that would mean that the case would move to private mediation and out of public court. All three defendants in the lawsuit (WWE, McMahon, and John Laurinitis) support taking the suit in this direction.

“Simply put, Grant has no claims actionable in this Court because the separation and non-disclosure agreement she signed with McMahon and WWE (the “Agreement”)—the monetary benefits of which she concededly accepted and retained—contains an arbitration provision that unambiguously precludes this Court from adjudicating her claims,” WWE further said.

WWE also said that which parts of the dispute should be handled in arbitration should ultimately be decided by an arbitrator.

“This action should be compelled to arbitration. The Agreement—which Grant concededly negotiated, signed, and accepted the benefits of—contains a clear and unambiguous arbitration provision. That provision requires not only that all claims Grant asserts here be decided in arbitration, but also that the threshold question of the arbitrability of those claims be decided by an arbitrator. The Court should grant WWE’s motion to compel arbitration and order that the claims proceed to arbitration, as the parties intended and as the Agreement requires.”

In her initial lawsuit, Grant said that the NDA was unenforceable, listing the Speak Out Act and the Victims of Trafficking and Violence Protecting Act of 2000. WWE said in their filing that neither applies to arbitration.

Earlier on Wednesday, Vince McMahon filed a new document presenting a “Statement of Undisputed Material Facts” in the lawsuit.

Vince McMahon files new ‘Statement of Undisputed Material Facts’ in Janel Grant lawsuit

Vince McMahon’s attorneys have filed a new “Statement of Material Facts” in support of his motion to compel arbitration.

The court filing released on Wednesday argued that the facts McMahon submitted are ‘undisputed’ in nature and he reserves the right to introduce additional evidence.

“Defendant believes the material facts stated below are undisputed and conclusively resolve the forum dispute before the Court,” the new filing reads. “Should the Court find it necessary to conduct a hearing on any issue, Defendant respectfully reserves his right to introduce additional evidence that bears on witness credibility, sophistication, state of mind, and similar issues.”

According to the filing, McMahon and Grant entered a three-year relationship that ended in January 2022. When the relationship ended, a “confidential settlement agreement” was agreed to, and Grant herself “negotiated the monetary compensation” that McMahon offered from one million dollars to three million dollars before involving their attorneys in the case.

On January 27, 2022, Grant’s attorney sent a revised version of the draft agreement which included the following language:

In the event of any dispute arising under or out of this Agreement, its construction, interpretation, application, performance or breach, the parties agree to first attempt to resolve such disputes informally and prior to taking any formal legal action to resolve such disputes. In the event any such dispute cannot be resolved informally, all parties hereto agree that the sole and exclusive legal method to resolve any and all disputes and/or controversies is to commence binding arbitration under the Federal Arbitration Act pursuant to the procedures of the American Arbitration Association and to do so by sealed proceedings which preserve the confidential and private nature of this Agreement. The parties agree to discuss the venue for any such arbitration proceeding if and when such a dispute arises which cannot be informally resolved; but in the event the parties cannot agree on a venue then the exclusive venue for any arbitration proceeding shall be in Stamford, Connecticut. The prevailing party, as determined by the arbitration tribunal, shall be entitled to recover from the non-prevailing party all of its attorney’s fees and costs.

The agreement also included the following severability provision:

In the event that any provision of this Agreement is held to be void or unenforceable by an arbitration panel or court reviewing an arbitration decision, the remaining provisions shall nevertheless be binding provided, however, if any of the confidentiality obligations of this Agreement are ever contended to be unenforceable by Grant, or are found to be unenforceable by any tribunal, Grant agrees that she shall return all monies paid pursuant to this Agreement to McMahon.

McMahon agreed to pay Grant three million dollars over four years through February 1, 2026. Both McMahon and Grant signed and dated the agreement on January 28, 2022, and ten days later McMahon issued the first payment of one million dollars.

On Monday, McMahon’s lawyers filed a new memo opposing Grant’s motion to strike McMahon’s preliminary statement.

Wrestling Observer Live: Vince McMahon/Janel Grant, King of the Ring, RAW report

Wrestling Observer Live with Bryan Alvarez and Mike Sempervive is back with tons to talk about including the latest on the Vince McMahon/Janel Grant lawsuit, more questions on the case, a look at all the latest news, the RAW report, King of the Ring and tons more. A fun show as always so check it out~!

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Wrestling Observer Radio: Death of Bob Bruggers, McMahon’s latest legal filing, RAW report, more

Wrestling Observer Radio with Bryan Alvarez and Dave Meltzer is back with tons to talk about including the death of Bob Bruggers, the latest filing from Vince McMahon’s lawyers in the Janel Grant lawsuit, Cash Wheeler is free and clear, InDemand is dead, ratings, the RAW report and tons more. A fun show as always so check it out~!

Timestamps:
Start: Bob Bruggers passes away
12:16: Vince McMahon responds to Janel Grant’s motion to strike comments
30:05: Cash Wheeler’s aggravated assault case dropped, InDemand pay-per-view service is shutting down
36:27: Ratings
39:04: David Taylor new head coach at Oklahoma State, UFC 303 ticket sales breaks records, Dana White says WWE may move PLEs to Sunday
46:30: WWE Raw report, AEW Dynamite lineup

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Vince McMahon responds to Janel Grant’s motion to strike comments

Vince McMahon’s legal team filed a new memorandum today.

Lawyers representing the former WWE Chairman have responded to Janel Grant’s legal team filing a motion to strike comments included in McMahon’s motion to compel arbitration submitted on April 23.

Grant’s team contends that McMahon used the motion to spread “inflammatory lies” and that it was used “as a platform to launch vicious falsehoods attacking Janel’s moral character in an attempt to harass and intimidate her into submission.”

Today, McMahon’s team referred to Grant’s motion as the “height of hypocrisy.”

The full memorandum submitted today can be read here.

Plaintiff’s Motion to Strike is meritless and the height of hypocrisy. Having falsely accused Defendant in a public forum, despite an obligation to arbitrate, in an inflammatory 67- page Complaint that completely disregards the mandate of Rule 8(a)(2) of the Federal Rules of Civil Procedure, Plaintiff now seeks to strike the Preliminary Statement of the Memorandum of Law in Support of Defendant’s Motion to Compel Arbitration (Dkt. No. 30-1) on the purported basis that it is too “inflammatory.”

The memorandum continues to state that Grant’s lawsuit includes several text messages between her and McMahon but does not include Grant’s responses. They contend her responses to McMahon’s texts “are equally and often more aggressive and provocative.” However, it also notes that McMahon is no longer in possession of those text messages, as he has since deleted them.

Ignoring her obligations to keep the nature of their relationship or the dispute private, the Complaint unnecessarily includes private sexual text messages from Defendant without including any of Plaintiff’s responses to those texts—responses which are equally and often more aggressive and provocative than Defendant’s communications and show not only that the relationship was consensual, but also that in many instances the Plaintiff was the initiator.

Defendant’s communications and show not only that the relationship was consensual, but also that in many instances the Plaintiff was the initiator. Indeed, while Defendant no longer is in possession of the text messages between the Parties as he deleted them when he broke off the relationship, the discovery in this case will show that Plaintiff sent him sexually explicit images of herself and texted him to say, among other things:

  • That she was in love with him and he was the love of her life;
  • That he was her best friend;
  • That she wanted to have sex with him and providing graphic detail;
  • That she fantasized about being held down, enjoyed being in pain, and wanted rough sex;
  • That she wanted Defendant to watch her have sex with other people and know about her sex with others;
  • That she wanted Defendant to give her thousands of dollars for clothes, plastic surgery, and other gifts;
  • That she wanted to have a future with Defendant even after signing the Agreement; and
  • That she wanted Defendant to keep living in the same building, so she could continue to see him, even after signing the Agreement.

“For the foregoing reasons, Defendant respectfully requests that Plaintiff’s Motion to Strike be denied,” the memorandum concludes.

John Laurinaitis supports Vince McMahon motion in Janel Grant lawsuit

John Laurinaitis’ legal team has released a statement in support of Vince McMahon’s motion to compel arbitration in Janel Grant’s lawsuit. 

McMahon’s legal team filed a motion on April 23 requesting that the court recognize an arbitration clause in an NDA Grant signed and send the matter to an independent arbitrator rather than it going to litigation. This would mean the proceedings would take place behind closed doors.

Laurinaitis’ lawyer, Edward M. Brennan, released the following statement on behalf of his client on Thursday:

John Laurinaitis has filed a Motion today fully joining in and adopting Vince McMahon’s motion to compel arbitration. Mr. Laurinaitis corroborates Mr. McMahon in publicly declaring that Ms. Grant’s allegations of sexual abuse and coercion in her Complaint are completely unfounded. My client will fight these false allegations together with Mr. McMahon in the proper forum, arbitration.

McMahon’s lawyer, Jessica Taub Rosenberg, Partner at Kasowitz Benson Torres LLP, released the following statement on Thursday in reaction to the motion filed by Laurinaitis’ legal team:

In January 2024, Ms. Grant, a 43-year-old with a law degree, who was in love with Mr. McMahon and devastated by their break-up, filed an outrageous and false lawsuit to ruin Mr. McMahon’s career and reputation. Now, her false allegations are slowly unraveling. Today, Mr. Laurinaitis’ attorney confirmed his client will corroborate Mr. McMahon’s account and expose the lies within the Complaint. Despite their intense efforts, Ms. Grant’s attorneys won’t be able to suppress the truth from coming out.

Representatives of Laurinaitis had previously stated that their client was a victim of McMahon in this case. 

“Like the Plaintiff, Mr. Laurinaitis is a victim in this case, not a predator. The truth will come out,” Brennan said in a statement on February 1.  

However, Brennan’s statement today suggests his client and McMahon’s legal team will work together in their defense. 

“John Laurinaitis filed a motion basically flipping and joining with Vince McMahon in stating Janel Grant’s stories weren’t true,” our own Dave Meltzer commented on the situation. 

A copy of today’s motion to compel arbitration from Laurinaitis’ legal team is below:

Defendant John Laurinaitis, by and through his undersigned attorneys, respectfully moves this Court for an order compelling arbitration of this matter pursuant to the Federal Arbitration Act, 9 U.S.C. §§ 3, 4, for the reasons set forth more fully in Defendant Vincent K. McMahon’s Motion to Compel Arbitration (Doc. 30) and Defendant McMahon’s Memorandum of Law in Support of Motion to Compel Arbitration (Doc. 30-1) which legal arguments advanced therein are adopted in full and joined by Defendant Laurinaitis as though set forth herein. Defendant Laurinaitis further moves the Court for such other and further relief as the Court may deem just and proper and seeks leave to advance additional and or other responses, defenses, counter-claims and or affirmative defenses to Plaintiff’s Complaint in the event the Motion to Compel Arbitration is denied.