>3. The two met in March 2019, when Ms. Grant was dealing with profound grief and
struggling financially – after devoting years to around-the-clock caregiving, her parents passed
3:24-cv-90
Case 3:24-cv-00090 Document 1 Filed 01/25/24 Page 1 of 67
2
away. On top of that, she was unemployed and her family home was lost in her parents’
bankruptcy.
4. After her family passed away, Ms. Grant dedicated herself to finding gainful
employment. Neighbors in her building provided career advice and sought her assistance with
personal events. Ms. Grant used these non-paying roles and volunteer work in community
initiatives to build her resume.
5. The building’s Resident Manager wanted to help. She messaged McMahon to ask
whether he would talk to her, sharing that Ms. Grant had been through hardship and would do
great things if given a fresh start. McMahon enthusiastically responded, “Hell Yes!!”
6. McMahon befriended Ms. Grant, giving her hopes of a new life with promises of a
yet-to-be-determined role at WWE, and showering her with attention and assurances, along with
gifts like a VIP experience at WrestleMania. But what seemed like a dream in the Spring of 2019
quickly became a nightmare.
7. As McMahon dangled career-making and life-changing promises in front of Ms.
Grant, he demonstrated an increasing lack of boundaries. During several meetings that were
ostensibly about a potential job at WWE, he greeted her in his underwear, touched her, repeatedly
asked for hugs, and spent hours sharing intimate details about his personal life.
8. McMahon warned Ms. Grant to keep their “closeness” secret, lest rumors lead to
public trouble – and added that, while he protects loyal people, he had world-class legal resources
on speed-dial to deal with people who became a problem