3 Individually, and as Trustee of the Vincent K. McMahon Irrevocable Trust U/T/A dtd. June 24, 2004, as Trustee of the Vincent K. McMahon 2008 Irrevocable Trust U/T/A dtd. December 23, 2008, and as Special Trustee of the Vincent K. McMahon 2013 Irrev. Trust U/A dtd. December 5, 2013, and as Trustee of Certain Other Unnamed McMahon Family Trusts, and as Controlling Shareholders of WWE , and allege, upon facts and information and belief, except for the allegations concerning Plaintiffs’ own actions, as follows. Please note that although the Complaint is divided into Counts as suggested by the Federal Rules, each and every paragraph alleged in each and ever y Count is intended to be taken as alleged in, and incorporated by reference, in every Count.

INTRODUCTION

1.

This case involves retired professional wrestlers and performers who sustained long term neurological injuries during their tenure with WWE. 2.

These injuries involve a neurological disease and ongoing disease process called Chronic Traumatic Encephalopathy (CTE) as well as the effects of Traumatic Brain Injuries (TBI) that occur as a consequence of repetitive head trauma sustained by the Plaintiffs as professional wrestlers in matches sponsored, controlled and creat ed by WWE. 3.

The wrestling moves that involve the occupational head trauma that causes CTE and associated diseases from the accumulated effects of TBIs are the result o f wrestli ng moves and maneuvers that were performed “correct ly” by the Plaintiffs. In other words, the head t rauma that has resulted in injury is the accumulated effect of many impacts to the Plaintiffs’ heads that occurred on a reg ular, routine basis during their WWE career. 4.

The occupational head trauma sustained by the Plaintiffs is also a consequence of more serious concussions, as well as frequent sub-concussive head injuries, which occurred in the ordinary course of each o f the Named Plaintiffs’ WWE tenure.