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As noted earlier on PWInsider.com, WWE filed a motion seeking to halt the discovery requested by Major League Wrestling as part of their antitrust lawsuit against the company on 1/5.
PWInsider.com has acquired the discovery requests made by MLW in October 2022, which included:
"All documents related to MLW, including, but not limited to, the following: (a) communications that refer to, discuss or constitute your efforts to recruit performers who are under cont act with MLW; (b) communications between you and Tubi, Vice and/or FITE that reference MLW or its programs; (c) internal communications that reference MLW or its programs; (d)
communications that refer to, discuss or constitute your efforts to discourage businesses or performers from working with MLW; (e) documents that refer to or discuss MLW contracts, or
proposed or prospective contracts, with cable, broadcast, streaming or other media outlets, including Tubi, Vice and FITE; and (f) documents related to Court Bauer. "
"All documents related to AEW, including, but not limited to, the following: (a) communications that refer to, discuss or constitute your efforts to recruit performers who are under contract with AEW; (b) communications between you and third parties that reference AEW or its programs; (c) internal communications that reference AEW or its programs; (d) communications that refer to, discuss or constitute your efforts to discourage businesses or performers from working with AEW; (e) documents that refer to or discuss AEW contracts, or proposed or prospective contracts, with cable, broadcast, streaming or other media outlets; (f) documents concerning AEW’s, booking of, or attempt to book, Heritage Bank Center (formerly known as U.S. Bank Arena) for events, including communications with Heritage Bank Center concerning third-party bookings of Heritage Bank Center."
"From January 1, 2018 until December 31, 2018, all documents related to New Japan ProWrestling, including, but not limited to, documents relating to New Japan Pro-Wrestling’s booking of, or attempt to book, Madison Square Garden for events, including communications with MSG concerning third-party bookings of MSG venues."
"From January 1, 2018 until December 31, 2018, all documents related to Ring of Honor, including, but not limited to, documents relating to Ring of Honor’s booking of, or attempt to book, Madison Square Garden for events, including communications with MSG concerning thirdparty bookings of MSG venues."
"All documents related to Impact, including, but not limited to, the following: (a) communications that refer to, discuss or constitute your efforts to recruit performers who are under contract with Impact; (b) communications between you and third parties that reference Impact or its programs; (c) internal communications that reference Impact or its programs; (d) communications that refer to, discuss or constitute your efforts to discourage businesses or performers from working with Impact; (e) documents that refer to or discuss Impact contracts, or proposed or prospective contracts, with cable, broadcast, streaming or other media outlets."
"All documents related to MLW’s negotiations or relationship with VICE, including, but not limited to, communications between you and VICE that reference MLW or its programs."
"All documents related to WWE’s involvement with VICE’s “Dark Side of the Ring Program,” including documents related to Jerry McDevitt’s appearance on the show."
"All documents related to Tubi, including, but not limited to, communications between you and VICE that reference MLW or its programs."
"All documents related to FITE, including, but not limited to, communications between you and FITE that reference MLW or its programs."
"All documents and communications with Fox regarding (a) Tubi and/or (b) MLW"
"Documents sufficient to identify each person who has knowledge of communications between WWE and VICE that occurred during the time period January 1, 2021 through December 31, 2021 concerning MLW or MLW’s negotiations with VICE."
"Documents sufficient to identify each person who has knowledge of communications between WWE and Tubi that occurred during the time period May 1, 2021 through December 31, 2021 concerning MLW or MLW’s negotiations or agreement with Tubi."
"Documents sufficient to identify each person who has knowledge of communications between WWE and FITE that occurred during the time period January 1, 2021 through December 31, 2021 concerning MLW or MLW’s negotiations with FITE."
"All documents concerning WWE’s contracts with A&E, as well as documents concerning WWE partnerships or programs that A&E participates in or airs."
"All documents related to WWE’s efforts to source, locate or hire professional wrestlers, including, but not limited to, WWE’s efforts to source, locate or hire professional wrestlers from competitors."
"All documents related to WWE’s outreach, solicitation or hiring of former MLW professional wrestler Stephon Strickland (“Strickland”), who performs under the ring names Swerve Strickland or Isaiah Swerve Scott, including internal communications concerning WWE’s decision to hire Strickland; Strickland’s potential role in the dispute between the parties or litigation between MLW and WWE; and communications with Strickland"
"All documents related to WWE’s outreach, solicitation or hiring of former MLW professional wrestler Luis Alberto Medina (“Medina”), who performs under the ring name Gino Medina, including internal communications concerning WWE’s solicitation of Medina, any WWE events, programs or promotions that Medina appeared in, and any communications with Medina."
"All documents related to WWE’s outreach, solicitation or hiring of former MLW professional wrestler Harry Smith (“Smith”), who performs under the ring name Davey Boy Smith Jr., including internal communications concerning WWE’s solicitation of Smith, any WWE events, programs or promotions that Smith appeared in, and any communications with Smith."
"All documents related to WWE’s outreach, solicitation or hiring of former MLW professional wrestler Jacob Fuavaifatu (“Fuavaifatu”), who performs under the ring name Jacob Fatu, including internal communications concerning WWE’s solicitation of Fuavaifatu, any WWE events, programs or promotions that Fuavaifatu appeared in, and any communications with Fuavaifatu."
"All documents related to WWE’s outreach, solicitation or hiring of former MLW professional wrestler Lance Anoa’i (“Anoa’i”), including internal communications concerning WWE’s solicitation of Anoa’i, any WWE events, programs or promotions that Anoa’i appeared in, and any communications with Anoa’i."
"The contracts or employment agreements of all WWE professional wrestlers whose contracts contain non-compete clauses or other clauses that limit or restrict the performer’s alternative employment options."
"All documents related to the performance of WWE or any of its employees or contractors in connection with professional wrestling events, including documents containing analyses, reviews, evaluations, appraisals or other internal assessments related to the quality, value or completeness of, or defects in, each such person’s work; their knowledge, skills and qualifications; and warnings, criticisms, reprimands, demotions, reassignments, terminations or other disciplinary actions related to those individuals, as well as documents sufficient to show which WWE professional wrestlers participated in WWE’s events."
"All documents concerning the termination of the employment, or the resignation, of any professional wrestler during the time period January 1, 2020 through present."
"All documents, including organizational and staffing charts, related to the organization, areas of responsibility and reporting relationships of WWE, including, but not limited to, organizational charts reflecting the name, position and hierarchy of employees with any responsibilities relating to the production of professional wrestling content."
"From January 1, 2012 through the present, all lawsuits, claims, or complaints, threatened or actual, made by any third party relating to allegations that WWE wrongfully poached or solicited employees or contractors, or tortiously or unfairly interfered with a competitor’s business, including a copy of any transcript of testimony given in connection with such lawsuits, claims, or complaints."
"All lawsuits, claims, or complaints, threatened or actual, made by WWE’s employees in connection with WWE’s employment or contractor agreements, including claims or complaints related to the hiring or retention of WWE’s employees, contractors or agents, including a copy of any transcript of testimony given in connection with such lawsuits, claims, or complaints."
"All documents relating to WWE’s efforts to prevent competitors from booking arenas or venues for the production of professional wrestling content, including, but not limited to, WWE’s efforts to book arenas or venues during times when competitors sought to book such arenas or venues and communications with event venues, stadiums or arenas concerning third parties’ booking of, or attempt to book, such event venues, stadiums or arenas for events."
"All documents concerning the internal decision making related to when WWE programming is broadcast or streamed, which networks or platforms stream such programming, and whether to air programming in timeslots that compete with competitors, including, but not limited to, internal analyses, forecasts or projections."
"All documents concerning the internal decision making related to WWE’s decision to air Clash at The Castle on Saturday, September 3, 2022 and NXT Worlds Collide on September 4, 2022." [Note from Mike: These events would have run the same day as AEW PPV events]
"All documents related to WWE’s agreements for the distribution, licensing fees, rights fees, advertising revenue, or subscription revenue of WWE professional wrestling content, including, but not limited to agreements for the licensing or distribution of Smackdown, RAW or NXT programming, including documents and communications concerning negotiations with counter-parties."
"All documents relating to the pricing of WWE events, including but not limited to: (a) analyses concerning the initial pricing for the sale or licensing of WWE events to cable, broadcast or streaming platforms; (b) actual or potential price increases or decreases, including any such changes in response to competition from another product; (c) rebates, discounts, or markdowns, including the negotiation thereof; or (d) negotiations with cable, broadcast or streaming platform."
"All documents relating to: (a) competition to WWE, including but not limited to competition from MLW, AEW or Impact; or (b) analyses, forecasts or other projections reflecting sales of WWE programming, MLW programming, AEW programming or Impact programming, or any other competition to WWE programming."
"All documents concerning WWE’s decision to shut down or discontinue its streaming service, WWE Network."
"All documents, including market studies or analyses, concerning WWE’s target audience or viewership for professional wrestling content."
"On a monthly basis, all viewership or ratings data for professional wrestling content."
"All minutes or notes relating to meetings of Your Board of Directors, or any committee or subcommittee of the Board of Directors, from January 1, 2018 to the present."
"All insurance policies, insuring agreements, declarations, binders, endorsements, and certificates of insurance concerning insurance coverage maintained by you concerning the damages sought in this Action."
"All claims made or forms submitted by you to insurance carriers in connection with any claims made the basis of this Action."
"All documents related to any notification, claim or reservation of rights, made under any insurance policy, in connection with the Complaint."
"All documents concerning any settlement agreement, indemnity agreement, hold-harmless agreement, guaranty agreement, judgment sharing agreement, non-disclosure agreement, covenant not to sue, joint defense agreement, cooperation agreement, cost sharing agreement and common interest agreement between WWE and any other person in connection with this litigation."
"One copy of each of WWE’s quarterly and annual financial statements and reports."
"One copy of each U.S. tax return (federal and state) filed by WWE."
"All documents evidencing your ability to satisfy a judgment in this Action, including all documents concerning any financial reserve or amount to cover estimated or potential liabilities, settlements or other expenses which may result from this Action."
"All documents concerning this Action, including press releases."
"All documents concerning written statements between you and third parties or your parent, subsidiary or affiliate corporations, partners, stockholders and/or shareholders concerning this Action."
"All documents, regardless of date, concerning any policies and/or procedures concerning compliance with federal and state antitrust laws."
"All documents concerning each of the allegations in the Complaint and/or any denial or other contention or response you have with respect to each such allegation."
In a response to MLW, WWE argued that many of the requests were "vague, ambiguous, overly broad and unduly burdensome" while other requests could not be completed due to the nature of the case and the lack of protective orders in place at that juncture in time. That back and forth led to WWE filing their motion to halt the discovery on 1/5. It now rests on the court to decide how the two sides will move forward.
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