I have uploaded an extremely crude copy of Tom Cole’s May 6, 1993, complaint in New York Supreme Court in Oneida County against World Wrestling Federation, Titan Sports, Inc. d/b/a Titan Sports Enterprises, Terry Garvin, Mel Phillips, and Pat Patterson.
The poor copy of the file, viewable at http://muchnick.net/colecomplaint.pdf, is caused by various conversions of second- or third-generation hard copies into an uploadable electronic format. I’ll try to get a better copy online if that becomes important.
Remember that Cole was on the verge of suing Linda McMahon’s company in early 1992 after alleging sexual harassment and abuse by three supervisors. Cole and WWF settled and he got his old job back. This filing documents a new complaint the following year after his relationship with McMahon and company soured again – a sequence of events chronicled in last Friday’s article at Politico.com, with commentary and further background at this blog.
Highlights of this 1993 complaint:
* “WWF employed plaintiff as a ring-boy and set-up person from 1985 until February 1990. Promises which defendants Garvin and Phillips made to plaintiff that he would have career opportunities … induced plaintiff to forego academic education beyond the ninth grade.”
* Cole alleged sexual harassment from Garvin, Phillips, and Patterson. Cole further alleged that he lost his job after rebuffing a sexual solicitation from Garvin.
* On March 13, 1992, Cole’s lawyer of the time, Jacob D. Fuchsberg, presented Titan Sports with a summons and complaint listing these same claims. On April 8, 1992, Cole and WWF signed a settlement paying Cole $55,000 (“primarily representing back salary”), re-employing him, and providing him with “the opportunity to do ring announcing and, if qualified, be given regular ring announcing jobs.” In a companion agreement, Titan also paid Fuchsberg’s law firm $82,535.