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Attorneys representing Vince McMahon filed the following before The United States District Court of Connecticut today in regard to the lawsuit Janel Grant brought against him, WWE and John Laurinaitis:
DEFENDANT VINCENT K. McMAHON’S LOCAL RULE 56(a)(1) STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF HIS MOTION TO COMPEL ARBITRATION
Pursuant to the Court’s May 8, 2024 Order Approving Stipulation re: Scheduling (Dkt. No. 49) and Rule 56 of the Local Rules of the United States District Court for the District of Connecticut, Defendant Vincent K. McMahon (“McMahon” or the “Defendant”), respectfully submits this Statement of Undisputed Material Facts in Support of His Motion to Compel Arbitration filed on April 23, 2024 (Dkt. No. 30). Defendant believes the material facts stated below are undisputed and conclusively resolve the forum dispute before the Court. 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.
1. Plaintiff Janel Grant (“Plaintiff”) and McMahon (collectively, the “Parties”) had a three-year relationship which ended in or about January 2022. (Defendant Vincent K. McMahon’s Declaration in Support of His Motion to Compel Arbitration Executed on April 18, 2024 (Dkt. No. 30-2 (“McMahon Decl.”)) ¶ 2.)
2. During their entire relationship, Plaintiff lived in the same luxury apartment building as Defendant. (Plaintiff’s Complaint (Dkt. No. 1 (“Compl.”)1 ¶ 2.)
3. When Plaintiff and Defendant’s relationship ended, they entered into a contract entitled Confidential Settlement Agreement, General Release and Covenant Not to Sue (the “Agreement” or “Agmt.”). (McMahon Decl. ¶ 2 & Ex. 1.)
4. Before the Parties involved their respective attorneys in the negotiation of the Agreement, Plaintiff herself negotiated the monetary compensation that Defendant would pay her under the Agreement from $1,000,000 (the amount initially offered by Defendant) to $3,000,000. (McMahon Decl. ¶ 3; Compl. ¶ 210.)
5. The Parties were represented by counsel in connection with the drafting and negotiation of the Agreement: Jonathan M. Shapiro of Aeton Law Partners LLP for Plaintiff, and Jerry S. McDevitt of K&L Gates for Defendant. (McMahon Decl. ¶ 4.)
6. On or about January 20, 2022, Defendant’s attorney sent a draft of the Agreement to Plaintiff’s attorney. (McMahon Decl. ¶ 4.)
7. On or about January 27, 2022, Plaintiff’s attorney sent a revised version of the draft Agreement to Defendant’s attorney proposing that the following language be inserted into the Agreement’s arbitration provision: “In the event of a claim of breach under this Agreement by any party that results in arbitration or any legal proceeding, the prevailing party, as determined by the tribunal or Court, shall recover from the non-party(ies) all of its resulting costs and attorneys fees.” (McMahon Decl. ¶ 5.)
8. Section X of the Agreement, in its entirety, states:
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. (McMahon Decl. Ex. 1 (Agmt.) § X.)
9. The Agreement further contains a provision pursuant to which Plaintiff agreed to keep the Agreement, and information about Defendant, confidential. (McMahon Decl. Ex. 1 (Agmt.) § I(A)-(D).)
10. The Agreement also contains a 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 Decl. Ex. 1 (Agmt.) § IX.)
11. In the Agreement, Plaintiff acknowledged that “among the rights she is knowingly and voluntarily waiving by executing this Agreement is the right to bring or pursue any claims or causes of action against McMahon and/or WWE.” (McMahon Decl. Ex. 1 (Agmt.) § VII(B) (emphasis added).) 12. The Agreement provided that Plaintiff was to be paid $1,000,000 within ten (10) days of the execution of the Agreement and the remaining $2,000,000 in four equal installments of $500,000:
V. MONETARY CONSIDERATIONS TO GRANT
A. Upon execution of this Agreement by the parties, McMahon will pay the sum of One Million Dollars ($1,000,000.00) to Grant within ten (10) days of execution of this Agreement.
B. Provided all confidentiality obligations of Grant under this Agreement are complied with in ensuing years, McMahon will pay the following sums to Grant within ten (10) days of the dates listed below:
February 1, 2023 - $500,000.00
February 1, 2024 - $500,000.00
February 1, 2025 - $500,000.00
February 1, 2026 - $500,000.00
In the event of any disclosure by Grant of the matters required to be kept confidential under this Agreement, McMahon shall have no obligation to make any payments set forth above which would otherwise become due on the dates indicated, and all monies previously paid to Grant pursuant to this Agreement shall be returned to McMahon in accordance with the terms of this Agreement.
(McMahon Decl. Ex. 1 (Agmt.) § V(A)-(B).)
13. Finally, the Agreement states that by signing her name, Plaintiff “represents that she is able to read the language and to understand the meaning and effect “she has read and understands this Agreement and the effect of it,” and that “her attorney . . . has explained it to her.” (McMahon Decl. Ex. 1 (Agmt.) § VII(A).)
14. The Parties signed and dated the Agreement on January 28, 2022. (McMahon Decl. ¶ 6 & Ex. 1 (Agmt.) p. 6.)
15. Within ten (10) days of the Agreement’s execution, Defendant paid Plaintiff the first payment specified in Section V(A) of the Agreement in the amount of $1,000,000. (Compl. ¶¶ 222, 263.)
The Motion also noted, "Defendant expressly denies the allegation in paragraph 263 of the Complaint that Defendant “breached a core term of the NDA” and that he “failed” to make further payments: indeed, as stated in Defendant’s Memorandum of Law in Support of His Motion to Compel Arbitration, Defendant did not pay Plaintiff the payments specified in Section V(B) because Plaintiff failed to comply with her confidentiality obligations under the Agreement by disclosing her relationship with Defendant."
McMahon's previous statement had including statements about Grant, her former fiance and responses to Grant's statements about the passing of her parents as well as her emotional state during the period she and McMahon first met. Grant's attorneys have filed motions seeking to have that material officially stricken from the record, which McMahon's side has pushed back against.
As noted, the situation will continue to get uglier publicly unless the Court rules that it should be moved to private arbitration as McMahon, WWE and John Laurinaitis have now all requested.
PREVIOUS JANEL GRANT LAWSUIT COVERAGE
VINCE MCMAHON, WWE SUED BY FORMER EMPLOYEE ALLEGING SEX TRAFFICKING AND ABUSE AT HANDS OF MCMAHON, JOHN LAUIRINAITIS
by Mike Johnson
1/25/2024 12:57 PM
STATEMENT FROM ATTORNEY REPRESENTING JANEL GRANT, WHO IS SUING WWE AND VINCE MCMAHON
by Mike Johnson
1/25/2024 1:04 PM
NBC AFFILIATE IN RI PUBLISHES COMPLETE MCMAHON LAWSUIT, MORE ON WHY JANEL GRANT FILED SUIT
by Mike Johnson
1/25/2024 2:43 PM
HORRIFIC' - TKO GROUP HOLDING ISSUES STATEMENT ON VINCE MCMAHON ALLEGATIONS IN LAWSUIT
by Mike Johnson
1/25/2024 4:46 PM
ANSWERING SOME OF YOUR VINCE MCMAHON LAWSUIT QUESTIONS
by Mike Johnson
1/26/2024 9:13 AM
FIRST SIGN WWE MAY BE DISTANCING FROM VINCE MCMAHON
by Mike Johnson
1/26/2024 10:33 AM
WWE PULLS VINCE MCMAHON SHIRT FROM ONLINE SALES
by Mike Johnson
1/26/2024 2:06 PM
FORMER WWE BOARD OF DIRECTORS MEMBER STATES INVESTIGATION INTO VINCE MCMAHON INCLUDED 'OUTREACH' TO JANEL GRANT, HER ATTORNEY
by Mike Johnson
1/26/2024 4:56 PM
JANEL GRANT STATEMENT REGARDING MCMAHON, WWE LAWSUIT TO BE RELEASED THIS EVENING VIA CRIME PODCAST
by Mike Johnson
1/26/2024 5:30 PM
INTERNAL WWE REACTION TO VINCE MCMAHON RESIGNATION
by Mike Johnson
1/26/2024 8:49 PM
JANEL GRANT'S ATTORNEY MAKING ROUNDS DISCUSSING VINCE MCMAHON LAWSUIT
by Steven Fernandes
1/27/2024 12:09 PM
INTERNAL REACTION TO VINCE MCMAHON'S TKO & WWE RESIGNATION, WHERE THINGS STAND WITH THE JANEL GRANT LAWSUIT AND LOTS MORE
by Mike Johnson
1/29/2024 9:10 AM
WWE HALL OF FAMERS THE BELLAS COMMENT ON WWE ALLEGATIONS IN GRANT LAWSUIT
by Mike Johnson
1/29/2024 5:26 PM
NEWSWEEK COVERS CALLS FOR BOYCOTT AGAINST WWE ON SOCIAL MEDIA
by Mike Johnson
1/29/2024 7:07 PM
DAVE SCHERER DISCUSSES THE VINCE MCMAHON LAWSUIT, HIS RESIGNATION AND MORE ON SLATE.COM'S WHAT NEXT PODCAST
by Mike Johnson
2/1/2024 9:09 AM
JOHN LAURINAITIS' ATTORNEY COMMENTS ON JANEL GRANT LAWSUIT, SAYS HE WAS A VICTIM OF VINCE MCMAHON AS WELL
by Mike Johnson
2/1/2024 4:09 PM
BROCK LESNAR PULLED FROM WWE 2K SUPERCARD GAME
by Mike Johnson
2/1/2024 8:33 PM
VINCE MCMAHON UNDER FEDERAL CRIMINAL INVESTIGATION, MCMAHON COMMENTS
by Mike Johnson
2/2/2024 8:38 AM
REPORT: VINCE MCMAHON NDAS WERE CREATED WITHOUT WWE KNOWLEDGE
by Mike Johnson
2/2/2024 5:01 PM
WHO TOLD VINCE MCMAHON TO RESIGN FROM TKO AND WWE
by Mike Johnson
2/7/2024 10:00 AM
BRET HART RIPS APART VINCE MCMAHON
by Mike Johnson
2/9/2024 11:24 AM
BROCK LESNAR-WWE 2K UPDATE
by Mike Johnson
2/22/2024 12:44 PM
VINCE MCMAHON LOOKING TO SELL MORE TKO STOCK
by Mike Johnson
3/4/2024 7:10 PM
NICK KHAN, BRAD BLUM AND MORE IDENTIFIED AS WWE CORPORATE OFFICERS IN JANEL GRANT LAWSUIT, WWE COMMENTS
by Mike Johnson
3/11/2024 5:54 PM
JOHN LAURINAITIS ACKNOWLEDGES JANEL GRANT LAWSUIT BEFORE COURT IN CT, WILL RESPOND WITHIN 60 DAYS
by Mike Johnson
3/21/2024 12:29 PM
NEW YORK POST OBTAINS LOVE LETTER FROM JANEL GRANT TO VINCE MCMAHON, GRANT CLAIMS SHE WAS 'COERCED' TO WRITE IT
by Mike Johnson
4/1/2024 12:50 PM
NBC COVERS VINCE MCMAHON'S LIFE AFTER WWE
by Mike Johnson
4/17/2024 2:54 PM
JANEL GRANT FIRES BACK AT VINCE MCMAHON, FILES MOTION ASKING COURT TO STRIKE 'INFLAMMATORY LIES' AGAINST HER
by Mike Johnson
4/24/2024 9:03 PM
JOHN LAURINAITIS ALIGNS WITH VINCE MCMAHON IN JANEL GRANT LAWSUIT
by Mike Johnson
5/2/2024 3:26 PM
HUGE RESIGNATION FROM WWE HAS EYEBROWS RAISED
by Mike Johnson
5/3/2024 10:02 AM
WWE FILES MOTION IN JANEL GRANT CASE, THEY 'ANTICIPATE' THEY TOO WILL SEEK PRIVATE ARBITRATION
by Mike Johnson
5/8/2024 10:33 AM
VINCE MCMAHON RESPONDS TO JANEL GRANT'S ATTEMPTS TO STRIKE MCMAHON'S STATEMENTS FROM THE RECORD
by Mike Johnson
5/13/2024 5:54 PM
WWE OFFICIALLY FILES MOTION REQUESTING JANEL GRANT LAWSUIT BE MOVED TO ARBITRATION, REQUEST COURT HEARING TO ARGUE MATTER
by Mike Johnson
5/14/2024 7:39 PM
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