WEBVTT 1 00:00:00.040 --> 00:00:02.359 This is disc number four at the time is two fifty four. We're back 2 00:00:02.399 --> 00:00:06.919 on the record. Continued examination. Read the last question back for me if 3 00:00:06.919 --> 00:00:10.199 you can. At what point in time did you come to the realization or 4 00:00:10.199 --> 00:00:13.359 the thought process? You know what, I don't think these docs were doing 5 00:00:13.400 --> 00:00:15.720 for me what they said they were doing. I don't think they were really 6 00:00:15.720 --> 00:00:18.600 in it to help me. When is it that you first felt that way? 7 00:00:19.239 --> 00:00:24.679 Okay? Continued direct examination by mister Traine. I think your answer was, 8 00:00:24.760 --> 00:00:28.559 mister Balaia, that kind of after the fifth surgery, the second Breski 9 00:00:28.600 --> 00:00:31.879 surgery, and before the last surgery, you started thinking that what they were 10 00:00:31.879 --> 00:00:34.719 doing wasn't helping. Was that accurate or did I mistake that? No, 11 00:00:34.920 --> 00:00:37.640 that's wrong, Okay, tell me what tell me when it was? Yeah, 12 00:00:37.640 --> 00:00:40.359 the reason I hung in there for so many surgeries was I didn't know 13 00:00:40.719 --> 00:00:43.799 this was not supposed to be this way. I thought the first one would 14 00:00:43.840 --> 00:00:46.439 fix it, then the second one, Saint Louis said I should have went 15 00:00:46.479 --> 00:00:49.640 up another level and then more aggressive. So I just kind of felt, 16 00:00:49.920 --> 00:00:52.719 you know, I kind of like fell into the surgery after surgery, but 17 00:00:52.759 --> 00:00:55.200 I always had hope that the next one was going to be was going to 18 00:00:55.280 --> 00:01:00.640 be the one. So after the two with Bresca, I figured final one, 19 00:01:00.640 --> 00:01:03.399 you know, which I didn't know which I didn't know was the final 20 00:01:03.439 --> 00:01:06.439 one. You know, I wasn't even aware that six were too many. 21 00:01:06.680 --> 00:01:07.760 I didn't know if we needed twenty. You know, at this point I 22 00:01:07.799 --> 00:01:11.000 was in the game with them. You know that after the sixth point, 23 00:01:11.040 --> 00:01:14.480 I walked out of there hoping I'd be fixed. And then time went on 24 00:01:14.719 --> 00:01:17.840 and it was like all the surgeries. It was great for a couple of 25 00:01:17.920 --> 00:01:19.640 days, and I started to get these little tweaks, you know, and 26 00:01:19.680 --> 00:01:23.959 then it just went into an overdraw situation where that pain was unbearable. And 27 00:01:25.040 --> 00:01:27.239 somewhere after that, you know, down the road, David Houston called me 28 00:01:27.239 --> 00:01:32.439 and said that they were advertising you on their website. Okay, now using 29 00:01:32.760 --> 00:01:34.480 your image and likeness, And it was like at that point I went, 30 00:01:34.519 --> 00:01:38.480 wait and wait a minute. You know, I mean, they know I'm 31 00:01:38.519 --> 00:01:42.120 not any better. You know that I'm just in horrible shape, and they're 32 00:01:42.159 --> 00:01:45.280 advertising on this website. Man, you know, you know that I'm doing 33 00:01:45.359 --> 00:01:47.640 great. So at that point I started thinking, man, you know, 34 00:01:47.719 --> 00:01:51.120 this is really screwed up. My understanding is mister Houston. Did he write 35 00:01:51.120 --> 00:01:53.959 a letter communicate with LSI to say take your likeness off the website or something. 36 00:01:55.319 --> 00:01:57.760 I'm sure he did. Okay, do you know when approximately that was? 37 00:01:57.879 --> 00:02:00.840 What point in time? No? I don't. Did you ever report 38 00:02:00.840 --> 00:02:05.159 to any physician in twenty twelve that you were sort of having a new pain 39 00:02:05.239 --> 00:02:08.120 pattern in your low back, something different than what you had prior to the 40 00:02:08.120 --> 00:02:12.599 fusion. I don't recall that, do you? Okay? And again when 41 00:02:12.639 --> 00:02:15.000 you say you don't recall, I don't know if it's saying it could have 42 00:02:15.039 --> 00:02:16.879 happened, I don't have any memory of it, or if you're just saying, 43 00:02:16.919 --> 00:02:20.520 boy, I sure don't recall that ever happening. There's two different ways 44 00:02:20.560 --> 00:02:23.599 to interpret it. Well, I don't recall it ever happening. Okay. 45 00:02:23.039 --> 00:02:25.960 If I recalled it, I would tell you. Okay. So if there's 46 00:02:25.960 --> 00:02:30.199 a strike that you don't remember suffering any injury while wrestling or doing anywhere else 47 00:02:30.719 --> 00:02:34.919 where, you suffered a new pain pattern in your low back after the fusion, 48 00:02:35.280 --> 00:02:38.280 I don't recall if I've wrestled aufter the fusion. Okay, do you 49 00:02:38.319 --> 00:02:42.599 think you've wrestled after the fusion? I mean I don't. Don't Anything I 50 00:02:42.639 --> 00:02:46.319 did physically was not something i'd remember. Yeah, I'll mean walking to the 51 00:02:46.360 --> 00:02:50.080 ring. You're stepping in the ring, you know, blocking a punch or 52 00:02:50.120 --> 00:02:53.080 hitting somebody. You know. I haven't had a match book where okay, 53 00:02:53.120 --> 00:02:55.280 here's you know, I'm gonna go out and wrestle. I haven't had that. 54 00:02:55.639 --> 00:02:59.560 So anything that you know is minimal physicality, which is you know, 55 00:02:59.599 --> 00:03:02.240 picking the chair up is the same as blocking a punch or throwing a fake 56 00:03:02.280 --> 00:03:06.680 air punch, or I didn't make contact that you know. I mean, 57 00:03:06.759 --> 00:03:10.919 so I don't remember having a wrestling match after the fusion. Oh really, 58 00:03:12.000 --> 00:03:14.919 Okay, we keep you know, we keep talking about this term wrestling. 59 00:03:15.039 --> 00:03:16.080 Do you think you've had a match even if it was a match where you 60 00:03:16.080 --> 00:03:19.120 know, the majority of it was you know, punch is thrown, you 61 00:03:19.159 --> 00:03:21.759 know, some armbar and some you know, slinging against the ropes. Have 62 00:03:21.840 --> 00:03:24.680 you had anything like that versus Flare or you know, Sina or Sting or 63 00:03:24.719 --> 00:03:28.240 any of those guys. I don't recalling you that. And is that because 64 00:03:28.240 --> 00:03:30.599 you're physically not able to do that after the fusion? No, I feel 65 00:03:30.599 --> 00:03:34.879 really good after the fusion. I just don't have that opportunity right now. 66 00:03:35.080 --> 00:03:38.719 I mean the place I'm working at now has changed their I don't know, 67 00:03:38.719 --> 00:03:40.199 how do you say it? You know, everything from their rating to their 68 00:03:40.240 --> 00:03:44.719 perspective on their business agenda of that. You know it's PG. You know 69 00:03:44.719 --> 00:03:46.800 there are no steel chairs, there's no more blood row wrestle. You know, 70 00:03:46.879 --> 00:03:51.280 they want all young wrestlers. You're even at the performance center in Orlando. 71 00:03:51.599 --> 00:03:53.960 You know, if you're over forty years old, and they won't even 72 00:03:53.960 --> 00:03:58.439 look at you. You know, whereas before a few years ago and there 73 00:03:58.439 --> 00:04:00.680 were a guys my age that we're still may have venting in wrestling, you 74 00:04:00.719 --> 00:04:04.400 know now that it's not that way anymore at all. They changed their whole 75 00:04:04.439 --> 00:04:09.280 mind saying business wise? Is this WWE? Yes? WWE? Well did 76 00:04:09.360 --> 00:04:13.039 again? You say the claim in the lawsuit? This lawsuit is you had 77 00:04:13.039 --> 00:04:15.600 a window of opportunity to sign a twenty year contract with Vince in two thousand 78 00:04:15.639 --> 00:04:19.319 and nine. Yes, okay, And because of the lside treatment you were 79 00:04:19.360 --> 00:04:23.279 unable to sign that contract. Is that your contention? No, I didn't 80 00:04:23.279 --> 00:04:26.560 say that. Okay, How did you How did the LSID doctors prevent you 81 00:04:26.600 --> 00:04:29.600 from signing that contract? How did they close that window? Of opportunity. 82 00:04:29.800 --> 00:04:32.560 Well, you misspoke when it was because of the treatment. It was because 83 00:04:32.639 --> 00:04:35.600 that same day I had agreed on the fusion, and I could have moved 84 00:04:35.639 --> 00:04:40.920 forward with my w negotiations because there was a time frame of when I would 85 00:04:40.959 --> 00:04:44.800 be fixed, like I'm fixed now after the fusion, and I could have 86 00:04:44.839 --> 00:04:46.439 done a deal with Vince McMahon at the time. You know, they would 87 00:04:46.480 --> 00:04:49.120 have let me wrestle at my age, and I could have done the twenty 88 00:04:49.160 --> 00:04:53.600 twenty five year deal. You know, got back on the train. You 89 00:04:53.639 --> 00:04:56.879 know, once you once you are wrestle and you're on TV, it changes 90 00:04:56.920 --> 00:05:00.319 the numbers with your merchandise and licensing on top of your wrestling performances. And 91 00:05:00.360 --> 00:05:04.279 because I didn't get the fusion, that didn't happen. And when I went 92 00:05:04.319 --> 00:05:06.399 to Laser Spine, I said, you know, you don't need a fusion, 93 00:05:06.480 --> 00:05:10.000 we can fix you. Which made me think that I could, you 94 00:05:10.000 --> 00:05:13.360 know, just have this one surgery from Saint Louis and I would be good 95 00:05:13.360 --> 00:05:15.560 to go in a couple of weeks because they said that you didn't need a 96 00:05:15.639 --> 00:05:19.639 fusion, all you need is minimum invasive surgery. But after the year and 97 00:05:19.639 --> 00:05:24.120 a half I spent screwing around with laser spine. I was in worst shape 98 00:05:24.120 --> 00:05:27.560 pain wise, So I don't know if my back was worse, but I 99 00:05:27.600 --> 00:05:30.160 was in worst shape pain wise. After all the surgery, I couldn't even 100 00:05:30.240 --> 00:05:34.319 function or think straight. And by the time that I have the fusion eventually, 101 00:05:34.759 --> 00:05:38.279 you know, I wish I needed in the first place. The window 102 00:05:38.279 --> 00:05:41.480 of opportunity was gone. If you would have had the fusion in two thousand 103 00:05:41.519 --> 00:05:45.120 and nine, what was going to happen? Differently, mister Balaya, what 104 00:05:45.160 --> 00:05:47.480 were you going to do in two thousand and nine with WWE that you couldn't 105 00:05:47.480 --> 00:05:50.399 do because you were at laser spine. Well, with laser spine, I 106 00:05:50.399 --> 00:05:54.519 couldn't wrestle after they got done with me after this fusion. If I had 107 00:05:54.560 --> 00:05:57.839 to go wrestler, now I could well, all right. So hypothetically, 108 00:05:57.879 --> 00:06:00.079 if you had the fusion February twenty fifth or twenty in two thousand and nine, 109 00:06:00.120 --> 00:06:02.519 when you could have wrestled as the main event off the top, rope, 110 00:06:02.600 --> 00:06:05.759 leg drop arm, whip leg, take down, scorpion, deathlock, 111 00:06:05.839 --> 00:06:09.680 whatever you want to talk about, when would you have been able to do 112 00:06:10.279 --> 00:06:13.920 Why would you have been able to do that? Based on what based on 113 00:06:14.000 --> 00:06:17.319 what you know from conversations with your doctors about the fusion. Well, conversations 114 00:06:17.319 --> 00:06:21.079 of my doctors usually aren't accurate with how my body healed, because you know, 115 00:06:21.439 --> 00:06:26.560 Arriba and Vale said a four to six month window, which would have 116 00:06:26.600 --> 00:06:30.240 been perfect for Vince McMahon to promote it, get my brand up and running. 117 00:06:30.240 --> 00:06:32.199 You'll create new licenses and get me really where I needed to be. 118 00:06:32.560 --> 00:06:35.199 You know, that would have actually been better if I had a four to 119 00:06:35.279 --> 00:06:39.680 six month window. But knowing that how my body heals, you know, 120 00:06:39.680 --> 00:06:42.839 when I had my knee replacement, the first knee replacement with repeache, you 121 00:06:42.839 --> 00:06:45.560 know they said with the Rakishi, they said, you know it's gonna be 122 00:06:45.639 --> 00:06:47.120 you know, four to six months before you can wrestle. And I was 123 00:06:47.160 --> 00:06:50.800 wrestling Kurt Henry at the twelve week mark with a knee replacement. So I 124 00:06:50.800 --> 00:06:56.279 just couldn't exactly go by what the doctor said because sometimes my body surprised me 125 00:06:56.319 --> 00:07:00.120 and it heals quicker. So that's what I could have done quicker, And 126 00:07:00.160 --> 00:07:02.560 that's what I would have happened if I would have had the fusion the first 127 00:07:02.600 --> 00:07:06.199 time and not got derailed and missed this window of opportunity you know, with 128 00:07:06.319 --> 00:07:11.480 the year and a half or however long it was of the LSI surgeries and 129 00:07:11.560 --> 00:07:14.519 not being able to perform or not being able to do anything on a main 130 00:07:14.560 --> 00:07:17.560 event themed wrestling match, as compared to having the fusion later. You know, 131 00:07:17.600 --> 00:07:20.399 after a year and a half, after having the fusion later, then 132 00:07:20.439 --> 00:07:24.319 it took more time, and by the time I got done, you know, 133 00:07:24.319 --> 00:07:28.000 the window of opportunities gone. Who called doctor Valley or doctor a Reba 134 00:07:28.040 --> 00:07:30.279 in for every twenty fifth and said, you know what, mister Balai has 135 00:07:30.360 --> 00:07:31.600 changed his mind. He's not going to have the fusion. Who made that 136 00:07:31.680 --> 00:07:34.480 call? And the best of my recollection, it was me. Okay, 137 00:07:34.480 --> 00:07:38.000 it wasn't doctor Saint Louis, was it. I don't think so. I 138 00:07:38.040 --> 00:07:42.240 think it was me right because Veil said And it wasn't a rebo because him, 139 00:07:42.680 --> 00:07:45.279 him and I weren't right. You know, I was close with Veil 140 00:07:45.319 --> 00:07:46.639 at the time, and it was Veil that said, you know, you'll 141 00:07:46.680 --> 00:07:49.079 be back. I think we can agree that you made the decision not to 142 00:07:49.120 --> 00:07:53.160 have the fusion surgery. Is that correct? Yeah? Because they told me 143 00:07:53.319 --> 00:07:57.800 and needed they said, explore every option. Every doctor I talked to you 144 00:07:57.839 --> 00:08:01.839 said, explore every option before you have the fusion, and Saint Louis and 145 00:08:01.959 --> 00:08:05.360 he said, you don't need it, which means there's another option. Sure, 146 00:08:05.560 --> 00:08:07.560 but you are I mean, you are an intelligent, mature business person. 147 00:08:07.600 --> 00:08:09.800 You could have made the decision, no, I'm not going to undergo 148 00:08:09.800 --> 00:08:13.439 the laser spine. I'm going to do the fusion because I want to get 149 00:08:13.480 --> 00:08:16.360 whatever benefits it gives me. You could have made that decision in Febry two 150 00:08:16.360 --> 00:08:18.000 thousand and nine, isn't that correct? Well? I could have, but 151 00:08:18.079 --> 00:08:22.000 I trusted the professional doctors that you were talking about that were a lot more 152 00:08:22.079 --> 00:08:26.480 knowledgeable than me as far as back surgery. I trusted those guys. When 153 00:08:26.480 --> 00:08:28.680 you started feeling pain after the February twenty eighth procedure, the first procedure at 154 00:08:28.720 --> 00:08:31.600 LSI, when you started feeling pained again, you could have said, ah, 155 00:08:31.600 --> 00:08:35.000 this laser didn't really fix me. I'm going to do the fusion now. 156 00:08:35.039 --> 00:08:37.360 You could have done that right. Well, when I asked about the 157 00:08:37.360 --> 00:08:41.080 pain, Saint Louis said, you know, you should have he said, 158 00:08:41.720 --> 00:08:46.200 he said, he you should have been more aggressive and done another level. 159 00:08:46.440 --> 00:08:48.960 And so I just figured, you know, he was trying to be conservative 160 00:08:48.159 --> 00:08:50.159 and the way he talked to me that, you know, if we did 161 00:08:50.240 --> 00:08:54.919 one more level, he could, you know, fix and we should have 162 00:08:54.960 --> 00:08:58.360 done at the first time a thought process. I was in the game not 163 00:08:58.399 --> 00:09:01.799 to have a fusion because these guys said we can fix it with that. 164 00:09:01.960 --> 00:09:05.879 You without fusion, you know, and going through this long process it's minimum 165 00:09:05.919 --> 00:09:09.679 invasive surgery, you'll be up and running a lot quicker. And then after 166 00:09:09.679 --> 00:09:13.759 the second procedure you said you had amazing results for a little while and then 167 00:09:13.759 --> 00:09:16.200 the pain came back. You could have at that point said, you know, 168 00:09:16.279 --> 00:09:18.799 I've had two procedures here and I'm still in pain. I'm going to 169 00:09:18.879 --> 00:09:20.840 go back and have the fusion. Nobody at LSI prevented you from doing that, 170 00:09:20.879 --> 00:09:24.559 did they. No. In the meantime, while all this was going 171 00:09:24.600 --> 00:09:26.840 on, these procedures and steroid injections at LSI, in two thousand and nine, 172 00:09:28.159 --> 00:09:31.559 you were negotiating a new contract with TNA, Right, I don't recall 173 00:09:31.600 --> 00:09:33.440 if I was, if I was or not about time, and you were 174 00:09:33.480 --> 00:09:37.960 planning on wrestling a tour in Australia, right, Yes, I mean you 175 00:09:37.960 --> 00:09:39.399 mentioned a little bit ago in one of your answers that four to six month 176 00:09:39.480 --> 00:09:43.360 time frame would have been great because it would have allowed you to get your 177 00:09:43.360 --> 00:09:45.879 brand up and running with Vince. I mean, why couldn't you get your 178 00:09:45.919 --> 00:09:48.120 brand up and running with Vince when you were going to see the folks at 179 00:09:48.200 --> 00:09:50.200 LSI. Well, you know, I just I just never got back on 180 00:09:50.240 --> 00:09:54.000 my feet after the surgeries. You know, this is a couple of days, 181 00:09:54.000 --> 00:09:56.720 and then there were there would be another little tweak, you know why. 182 00:09:56.720 --> 00:09:58.639 I'd go, well, well just wait a minute, you know, 183 00:09:58.679 --> 00:10:01.519 and then there's another you know, there's something, a little something going on. 184 00:10:01.679 --> 00:10:05.840 And it was even to the point where after the second surgery or the 185 00:10:05.879 --> 00:10:09.159 third surgery, I planned the Australia trip and went ahead and gave him the 186 00:10:09.159 --> 00:10:11.279 green light to start the publicity, and all of a sudden, a couple 187 00:10:11.240 --> 00:10:15.399 of weeks before I went, my back completely went out again. So it 188 00:10:15.519 --> 00:10:18.799 was touch and go with is this the surgery or you know that's going to 189 00:10:18.879 --> 00:10:20.559 fix my back? You know. So, you know, when he first 190 00:10:20.639 --> 00:10:24.480 came out of surgery, you felt great for a couple of days. Something 191 00:10:24.600 --> 00:10:28.360 was even longer. But I hadn't been through enough surgeries to know that this 192 00:10:28.440 --> 00:10:31.279 was going to happen. Every single time they cut on me. I was 193 00:10:31.320 --> 00:10:33.679 hoping after the first or second one they might get it right. Who is 194 00:10:33.720 --> 00:10:39.159 Paul Henry, mister Balaia, Paul Henry? Do you know mister Henry? 195 00:10:39.240 --> 00:10:43.200 Or did you know mister Henry? You know I don't call Paul Henry. 196 00:10:43.240 --> 00:10:45.519 That name sounds really familiar. I'm going to read something to you, but 197 00:10:45.559 --> 00:10:48.000 I'm going to ask you a question. Could you show him a copy of 198 00:10:48.039 --> 00:10:50.799 what you're reading. No, I'm not going to show him, but I'll 199 00:10:50.840 --> 00:10:52.639 tell him. I mean, it's his statement from one of the reality shows, 200 00:10:52.759 --> 00:10:56.679 so I assume you have it. You're asking him to assume he made 201 00:10:56.679 --> 00:11:00.279 that statement when it was from a reality show. Yeah, it's you on 202 00:11:00.360 --> 00:11:05.600 camera, okay, I mean you can listen to it. I'm going to 203 00:11:05.679 --> 00:11:07.039 give you a shout out. It's good to see your brother. You look 204 00:11:07.080 --> 00:11:09.759 healthy, man. He wrestled with us for years. Yeah. Yeah, 205 00:11:09.799 --> 00:11:13.240 they told me about that. I couldn't wait to see it. But thank 206 00:11:13.240 --> 00:11:15.759 you, bro. I'm going to give you a shout out. It's me 207 00:11:15.960 --> 00:11:18.960 Knobs, Bischoff, Jimmy Hart, you know, the crew, brutus, 208 00:11:18.279 --> 00:11:22.960 all the fucking idiots. We are getting ready. Vince's freaking man, because 209 00:11:22.960 --> 00:11:26.879 he wanted me to be the main event against Sina. I told him I 210 00:11:26.919 --> 00:11:28.519 would, and then two weeks ago I said I can't. So I'm getting 211 00:11:28.519 --> 00:11:33.480 ready to do my own thing. Isn't it true that you didn't sign up 212 00:11:33.480 --> 00:11:35.200 with Vince in two thousand and nine because you wanted to do your own thing 213 00:11:35.919 --> 00:11:39.200 and you didn't want to be part of WWE. Isn't that true? No, 214 00:11:41.000 --> 00:11:43.519 So if you're on tape talking about setting up this new business recorded you, 215 00:11:45.080 --> 00:11:48.360 that's just an outright falsehood. It's not true. What's the you're reading 216 00:11:48.399 --> 00:11:52.360 from your own notes is what you're doing for the record. You need to 217 00:11:52.360 --> 00:11:54.840 show him the document if you're going to question him about it. You don't 218 00:11:54.919 --> 00:11:58.360 sit through many depositions. To you, mister Floren, this is my first 219 00:11:58.399 --> 00:12:01.480 one. It's cross examination. I can ask him whenever I want to. 220 00:12:01.559 --> 00:12:05.279 You can either deny it. You've got to show the witness. No, 221 00:12:05.639 --> 00:12:09.120 you've got to. Why don't you all give the court reporter or at least 222 00:12:09.120 --> 00:12:13.399 a little bit of deference and talk one at a time. All right, 223 00:12:13.519 --> 00:12:16.480 I'll talk. If you show him what you're reading from as you're required to, 224 00:12:16.639 --> 00:12:20.080 then he can answer the questions. You're just reading your own notes. 225 00:12:20.200 --> 00:12:22.960 Is all you're doing. Show me a rule that says I've got to show 226 00:12:22.000 --> 00:12:26.159 him anything. Show me that rule. Well you know that rule. No, 227 00:12:26.480 --> 00:12:31.120 there is no rule. My question to you is, didn't you want 228 00:12:31.159 --> 00:12:33.039 to start your own deal in two thousand and nine and not sign up with 229 00:12:33.039 --> 00:12:37.759 the WWE because of the fallout you had with your relationship with Vince McMahon. 230 00:12:37.799 --> 00:12:41.480 Isn't that really the truth? I object to form. It's not true at 231 00:12:41.519 --> 00:12:45.120 all. Isn't it true that your refusal to sign with ww in two thousand 232 00:12:45.240 --> 00:12:46.840 nine had nothing to do with your back problems? Did it? It's not 233 00:12:46.960 --> 00:12:50.960 true at all. Okay. Do you remember in twenty thirteen, two twelve, 234 00:12:50.960 --> 00:12:52.879 two thirteen time frame that you applied for some life insurance. You had 235 00:12:52.879 --> 00:12:56.639 stated that you needed to pay off some debts, you needed some life insurance. 236 00:12:56.639 --> 00:12:58.720 Do you recall that? No, I don't recall that. Do you 237 00:12:58.759 --> 00:13:01.279 recall when you applied for life rance that you have to fill out a medical 238 00:13:01.320 --> 00:13:03.320 questionnaire? Don't recall that? Okay. Even though if we have a medical 239 00:13:03.399 --> 00:13:07.799 questionnaire or an application for life insurance where you were asked medical questions, would 240 00:13:07.799 --> 00:13:09.840 you have been honest in answering the questions from the life insurance company or the 241 00:13:09.840 --> 00:13:13.720 group that you were applying for benefits from what you're saying, if you have 242 00:13:13.120 --> 00:13:16.080 will beat the question. I don't understand sure. I mean you say you 243 00:13:16.080 --> 00:13:20.759 don't remember filling out any life insurance applications, and I'm asking you to assume 244 00:13:20.000 --> 00:13:24.679 that you failed out a life insurance application. My question to you is in 245 00:13:24.720 --> 00:13:26.279 the medical part of the application, would you be honest? Would you tell 246 00:13:26.320 --> 00:13:30.759 them honestly what's going on with your medical condition? Well, I would assume, 247 00:13:30.879 --> 00:13:33.080 like you said, if I filled something out, I'll assume I would 248 00:13:33.080 --> 00:13:35.279 be honest. Okay, Well, do you know a group called the Smith 249 00:13:35.320 --> 00:13:37.840 Company? No, I don't. I mean, as you say here today, 250 00:13:37.840 --> 00:13:41.320 do you believe that you'd lie on a life insurance application. I have 251 00:13:41.360 --> 00:13:45.360 no reason to believe on lie. Do you want to show him that document? 252 00:13:45.879 --> 00:13:48.360 No? I will at trial, though. Well, if you're going 253 00:13:48.399 --> 00:13:50.399 to ask questions about a document that, I'm going to go in front of 254 00:13:50.399 --> 00:13:52.600 the judge and we'll talk to him about whether or not in depositions, you 255 00:13:52.600 --> 00:13:54.960 need to show him the documents is supposed to reading from your notes, so 256 00:13:54.000 --> 00:13:58.039 we can do that too. Wow, Please tell me what here? Well, 257 00:13:58.080 --> 00:14:00.919 when that hearing is so I can watch you make new law. I 258 00:14:00.960 --> 00:14:03.639 would want to be there if I get to hear. If we get the 259 00:14:03.679 --> 00:14:05.679 hearing, I'm sure you'll be noticed because you're on like certificate of service, 260 00:14:05.720 --> 00:14:09.759 so you'll be there. Thank you. This is all just for the court, 261 00:14:09.799 --> 00:14:13.720 mister Blais. Do you do you recall telling a group called the Smith 262 00:14:13.759 --> 00:14:18.879 Company that in two thousand and twelve and twenty and thirteen that your annual income 263 00:14:18.039 --> 00:14:22.639 was one million dollars and you had a total net worth of four million dollars. 264 00:14:22.679 --> 00:14:24.879 Does that sound like your financial situation in two thousand and twelve thirteen? 265 00:14:24.960 --> 00:14:28.519 Our recall what it was then? If your income is approximately one million dollars 266 00:14:28.559 --> 00:14:31.120 in two thousand and twelve, how would that compare with your annual income and 267 00:14:31.120 --> 00:14:33.320 save the years? I don't know two thousand and five to two thousand and 268 00:14:33.360 --> 00:14:35.840 nine was it more or less about the same? It was probably a lot 269 00:14:35.919 --> 00:14:41.919 less. You have had You have not had any additional back surgery, have 270 00:14:41.039 --> 00:14:43.480 you since the fusion in two thousand and ten? Is that correct? No, 271 00:14:43.600 --> 00:14:48.039 it's not correct. It's not correct you've had additional back surgery. Yes, 272 00:14:48.960 --> 00:14:50.799 tell me about that. Well. On my sixtieth birthday, I have 273 00:14:50.879 --> 00:14:54.840 the spinal court stimulator taken out? Who removed it? Doctor Riba? Did 274 00:14:54.840 --> 00:15:00.200 you ever again use that stimulator after the fusion procedure? No, I didn't 275 00:15:00.039 --> 00:15:03.720 eat it. So you were just carrying around this piece of hardware in your 276 00:15:03.720 --> 00:15:07.519 back for some period of time. Yeah, because was it uncomfortable? I'm 277 00:15:07.519 --> 00:15:09.519 sorry I cut you up. No, No, it wasn't uncomfortable. Okay. 278 00:15:09.559 --> 00:15:13.000 How long was it in your back before doctor you Rebay took it out? 279 00:15:13.360 --> 00:15:15.879 Well, whenever the surgery was, you know, the twenty fourth of 280 00:15:16.440 --> 00:15:18.399 I guess it was twenty ten, twenty eleven, you know, whenever the 281 00:15:18.720 --> 00:15:22.240 fusion was. I thought they took it out. After the fusion, they 282 00:15:22.240 --> 00:15:24.159 took out the stimulator. Well, you asked me how long it was in 283 00:15:24.200 --> 00:15:28.519 there? Yes, okay, I'm trying to tell you right. It was 284 00:15:28.559 --> 00:15:31.919 in there from whenever the fusion was. I think it was twenty ten until 285 00:15:31.960 --> 00:15:35.120 my sixtieth birthday. And that's how long it was in there. You know, 286 00:15:35.159 --> 00:15:37.039 I didn't use it. And finally that's what I wanted. That's what 287 00:15:37.080 --> 00:15:41.519 I wanted from my birthday was to get the battery out and all the wires 288 00:15:41.879 --> 00:15:43.960 because before it started leaking or there was a problem or something, okay, 289 00:15:45.000 --> 00:15:48.399 And when it was your sixtieth birthday August eleventh, last year, okay, 290 00:15:48.399 --> 00:15:52.000 So you had that stimulator in your body for three years almost after the shrugs 291 00:15:52.240 --> 00:15:56.919 okay, and you didn't have any problems with it. I didn't use it, 292 00:15:58.000 --> 00:16:00.240 you know, I didn't. I didn't charge it or anything. So 293 00:16:00.320 --> 00:16:02.559 I just I just wanted to get it out. Have you had any other 294 00:16:02.559 --> 00:16:04.240 conversations with any other physicians. I know, I've asked about a number of 295 00:16:04.240 --> 00:16:08.279 physicians, but any other physicians regarding your treatment and LSI where they expressed any 296 00:16:08.279 --> 00:16:11.559 opinion about the treatment you've had or the surgeries that were performed or anything like 297 00:16:11.600 --> 00:16:15.399 that. I thought, I recall, I think, have you had any 298 00:16:15.399 --> 00:16:17.799 injections at all in any part of your back, your upper back, your 299 00:16:17.799 --> 00:16:21.080 mid back, or your low back since the fusion surgery? No, have 300 00:16:21.200 --> 00:16:25.000 any physicians told you in the last five years say that you risk more serious 301 00:16:25.000 --> 00:16:26.480 injury to your back if you were to get in there and wrestle like the 302 00:16:26.519 --> 00:16:30.960 main event type, jumping off the top ring rope, doing the body slams, 303 00:16:30.000 --> 00:16:33.799 getting body slammed, cage matches, ladder matches. You know, any 304 00:16:33.799 --> 00:16:37.200 physicians said, you risk more serious injury. I'll talk to you Ariba and 305 00:16:37.279 --> 00:16:41.399 Veil about it, and I'll talk to him about the Hulk Cogan theme matches, 306 00:16:41.639 --> 00:16:44.679 which Hulk Cogan does the drop kick, you know Hulk Cogan does. 307 00:16:44.759 --> 00:16:48.200 Jump off the topic of the cages and it's pretty much the characters pretty much 308 00:16:48.240 --> 00:16:51.919 well established. I do need to get more physical than I would have had 309 00:16:52.159 --> 00:16:53.960 to get in TNA to have a main event match like I had with a 310 00:16:55.039 --> 00:16:59.080 Rock at WrestleMania X eight. You know that that's all within the safe zone 311 00:16:59.120 --> 00:17:00.879 of a Hull Cogan theme match. So I had to talk to Vail in 312 00:17:00.919 --> 00:17:06.160 Ariba about potentially doing that. When they say what they sayd is you know 313 00:17:06.160 --> 00:17:07.920 the way mat back is now, They didn't see any problem with it. 314 00:17:08.319 --> 00:17:11.920 Okay, So if I went back, the only thing is I'm sorry. 315 00:17:11.079 --> 00:17:15.319 The only thing I wouldn't do is do the leg drop because we talked about 316 00:17:15.319 --> 00:17:18.599 that and they said there's no reason to do that that could compromise the integrity 317 00:17:18.599 --> 00:17:22.200 of the fusion. I guess, well, it doesn't make sense to jump 318 00:17:22.279 --> 00:17:23.559 up and lound your tail boom. Okay, But if I were to go 319 00:17:23.599 --> 00:17:26.000 back and look at that match, Wrestleman the eighteen with the rock you could 320 00:17:26.039 --> 00:17:30.160 do everything else now that you did not accept for the leg drop. Yes, 321 00:17:30.519 --> 00:17:33.799 okay, And is it your testimony that the reason you're doing that now, 322 00:17:33.880 --> 00:17:37.359 mister Balaia is because what ww has changed its focus? They don't, 323 00:17:37.799 --> 00:17:41.519 they're not. That the reason you're not doing that now, mister Balaia is 324 00:17:41.559 --> 00:17:45.519 because what WWE has just changed its focus? They don't, they're not they 325 00:17:45.559 --> 00:17:48.119 want younger wrestlers, or they've changed their business model. What's the reason why 326 00:17:48.160 --> 00:17:52.480 you can't engage in that type of match? Well, it's actually, yeah, 327 00:17:52.480 --> 00:17:53.680 what you said, I read I guess in the last day or so 328 00:17:53.759 --> 00:17:59.119 that the TEENA contract with Spike TV has been canceled as of yesterday or something 329 00:17:59.160 --> 00:18:00.799 like that. Is that you're under standing or do you even know? Well, 330 00:18:00.799 --> 00:18:03.880 I've had people call me and say that, but I don't know. 331 00:18:03.960 --> 00:18:07.559 You know, it could be a wrestling angle. They've always got new owners 332 00:18:07.599 --> 00:18:11.000 come in and taking over, which are not really owners, they're wrestlers, 333 00:18:11.240 --> 00:18:15.440 you know. I know Kevin kay as Spike is involved in the storyline. 334 00:18:15.880 --> 00:18:18.599 He's one of the creative directors and he's the head of Spike. So it 335 00:18:18.680 --> 00:18:21.519 could just be a wrestling angle. I mean, is there any reason you 336 00:18:21.519 --> 00:18:25.680 couldn't in the last few years since the Fusion, go back to TNA and 337 00:18:25.720 --> 00:18:26.759 be the main event, the main guy, do everything you did in that 338 00:18:26.759 --> 00:18:30.240 match with the Rock except for doing the leg drop. But there's no reason 339 00:18:30.319 --> 00:18:34.039 other than there's no reason too. They wouldn't. They wouldn't pay me anymore 340 00:18:34.039 --> 00:18:37.240 for doing it. The reason you wrestle is you make more money, and 341 00:18:37.279 --> 00:18:41.559 they wouldn't pay me any more to wrestle. They just didn't have the financial 342 00:18:41.119 --> 00:18:45.039 No, No, they were just yeah, I think it was pretty much. 343 00:18:45.119 --> 00:18:45.960 You know, I know what it was. It was. It was 344 00:18:47.000 --> 00:18:49.559 a small independent wrestling company. It wasn't a large company like the w W 345 00:18:49.880 --> 00:18:52.359 or Ted Turner's company. Are there any of the wrestling companies out there that 346 00:18:52.359 --> 00:18:56.079 you would consider, you know, second tier behind the ww right now or 347 00:18:56.119 --> 00:18:59.079 for the last couple of years, other than TNA. TENA is not a 348 00:18:59.079 --> 00:19:06.839 wrestling company. Okay, Well, if you're comparing the two, you know, 349 00:19:06.880 --> 00:19:10.240 one is a multibillion dollar company and TNA can't afford to make payroll. 350 00:19:11.799 --> 00:19:14.559 It's a big drop off, I realized. But is there any other wrestling 351 00:19:14.559 --> 00:19:17.880 company that you would put in the same plane as TNA. As TNA, 352 00:19:18.880 --> 00:19:22.359 Oh god, there's hundreds of them, dude, Okay, they're probably forty 353 00:19:22.400 --> 00:19:25.799 them in Japan. Is that the I mean, when you signed on with 354 00:19:25.839 --> 00:19:29.079 TNA, you were excited about that possibility, weren't you. Well, yes, 355 00:19:29.160 --> 00:19:32.039 I was excited about that. The investors, you know, Dixie Carter's 356 00:19:32.079 --> 00:19:36.240 parents wanted to compete. I had no idea that it was just the opposite. 357 00:19:36.720 --> 00:19:38.720 I mean, you thought it was going You thought you were going to 358 00:19:38.759 --> 00:19:41.559 take on Vince Monday nights and take on the big monster, and that was 359 00:19:41.599 --> 00:19:44.880 the future of wrestling. Didn't you think that in two thousand and nine. 360 00:19:45.319 --> 00:19:47.559 Well, on two thousand and nine, we had a huge town pool of 361 00:19:47.599 --> 00:19:51.039 young guys that were established, and we had already done it before you Eric 362 00:19:51.039 --> 00:19:55.000 Bischoff and I had already done before with Ted Turner, and we were under 363 00:19:55.000 --> 00:19:59.039 the assumption that Dixie's parents, who are very wealthy billionaires and own an energy 364 00:19:59.079 --> 00:20:02.200 company, rain to compete. And they thought, you know, they may 365 00:20:02.400 --> 00:20:04.920 think we had a budget when they decided to go on Monday nights and it 366 00:20:06.000 --> 00:20:08.599 wasn't the case. Well, one was it that you realized that TNA was 367 00:20:08.680 --> 00:20:12.359 not going to be the presence in the industry that you thought it was going 368 00:20:12.400 --> 00:20:15.119 to be. Well, they wouldn't spend the money to go on the road 369 00:20:15.119 --> 00:20:18.880 and do things correctly. You're just everything from the pyro of the presentation to 370 00:20:19.000 --> 00:20:23.839 you know, they wouldn't spend any money on advertising, pronadvertising or any type 371 00:20:23.839 --> 00:20:27.079 of social media stuff. There wasn't a presence. Well, when I say 372 00:20:27.119 --> 00:20:30.559 timeframe, I'm trying to get you know, maybe just a month or a 373 00:20:30.640 --> 00:20:33.240 year. Do you have any idea when that sort of realization came to you 374 00:20:33.279 --> 00:20:36.000 that hey, this may not be the future of wrestling. Well, it's 375 00:20:36.000 --> 00:20:37.680 probably a second year I was there, Okay, Yeah, they made us 376 00:20:37.720 --> 00:20:41.400 think they were going to ramp up and be competitive. Do you still have 377 00:20:41.400 --> 00:20:45.039 any kind of assistive device that you use on a regular or periodic basis, 378 00:20:45.039 --> 00:20:48.000 A cane, a walk or anything like that. No, And I take 379 00:20:48.000 --> 00:20:52.319 it from the fusion procedure that was performed by doctors Uribe and Valet. You 380 00:20:52.359 --> 00:20:55.319 didn't have any complications at all after that, No infection, no problem with 381 00:20:55.359 --> 00:20:57.400 wound healing, anything like that. No. None. Did you ever tell 382 00:20:57.440 --> 00:21:02.000 anyone or did you ever make the state that after the fusion surgery something quote 383 00:21:02.079 --> 00:21:04.400 something is not there. I can't get the strength back, can't get my 384 00:21:04.480 --> 00:21:08.039 legs underneath me. Did you ever make that statement to your recollection? Could 385 00:21:08.079 --> 00:21:11.599 you show him what you're reading from? Again, I know you're from Atlanta, 386 00:21:11.640 --> 00:21:15.599 but Florida Rule ninety point six one four requires you to show the statement 387 00:21:15.599 --> 00:21:18.559 to a witness of any past statement that he's made. It's a statement he 388 00:21:18.559 --> 00:21:22.680 made on a reality show. Could you show it to him? No, 389 00:21:22.400 --> 00:21:26.440 he can answer, or you can instruct him not to answer. I'm not 390 00:21:26.440 --> 00:21:27.680 going to instruct him not to answer, but if it keeps up, I 391 00:21:27.799 --> 00:21:33.359 might and take it to the court. Okay, I said it just a 392 00:21:33.359 --> 00:21:36.559 little bit ago. You're required to show a witness what you're reading from on 393 00:21:36.640 --> 00:21:41.240 any past statement. Those are our rules. What was the all right? 394 00:21:41.559 --> 00:21:42.839 Well, are you going to answer the question, mister Balaah? Do you 395 00:21:42.880 --> 00:21:48.119 ever recall do you recall ever saying after the fusion surgery something is not there, 396 00:21:48.240 --> 00:21:51.880 that you couldn't get your strength and your legs back, can't get my 397 00:21:51.920 --> 00:21:55.240 legs underneath me. Do you recall saying anything like that? Well, if 398 00:21:55.240 --> 00:21:57.000 it was said, I will, I don't recall if it was. Okay, 399 00:21:59.039 --> 00:22:02.720 you're after the fusion during the LS surgeries. I don't know, you 400 00:22:02.759 --> 00:22:06.519 know, but I just haven't gotten my legs back underneath me completely. And 401 00:22:06.519 --> 00:22:08.079 your testimony would be that you do not have your strength back today after the 402 00:22:08.079 --> 00:22:11.000 fusion. You're not in any pain, haven't been in any pain? Well, 403 00:22:11.119 --> 00:22:14.720 no, I'm not in any pain. My back feels fine. Yeah. 404 00:22:14.720 --> 00:22:17.720 I don't have my legs back hundred percent like I wish they would. 405 00:22:17.839 --> 00:22:19.400 Is that because of the back problem or is that more because of the hips 406 00:22:19.400 --> 00:22:22.599 in the knees or do you know? I don't know, Okay, I 407 00:22:22.640 --> 00:22:25.880 don't. I have no idea, you know. I just remember my dad 408 00:22:25.880 --> 00:22:30.200 always tell me that those don't lose your dogs, don't let's your legs go 409 00:22:30.240 --> 00:22:32.200 off from under you. And I just, you know, that's in my 410 00:22:32.240 --> 00:22:34.920 head because he was he trained a lot of people. So I just costly 411 00:22:34.960 --> 00:22:40.319 focus on getting my legs back underneath me. Do you I think you referenced 412 00:22:40.400 --> 00:22:44.519 this earlier. You were filming a show out at Universal Studios in Orlando. 413 00:22:44.599 --> 00:22:47.440 You've talked about that a little bit. Was that for TNA? Yes? 414 00:22:47.640 --> 00:22:49.759 Okay, if you did wrestle a match after the fusion surgery, or even 415 00:22:49.799 --> 00:22:53.160 if you wrestled in a match before the fusion surgery. Was that match scripted 416 00:22:53.200 --> 00:22:57.799 to the point where there was actually a written script that talked about the kind 417 00:22:57.799 --> 00:23:02.079 of generally what the part subments we're going to do. No, okay, 418 00:23:02.079 --> 00:23:08.920 that never happened. I mean it was oh more just oh, you know, 419 00:23:08.920 --> 00:23:11.920 well, I'm gonna say it never happened. I wrestled for a long 420 00:23:12.000 --> 00:23:15.440 time, and part of the art form is not talking about what you're gonna 421 00:23:15.480 --> 00:23:19.240 do out there. You know, the best wrestlers never talk. They just 422 00:23:19.359 --> 00:23:22.759 know what the predetermined finish is going to be. Because if you try to 423 00:23:22.799 --> 00:23:26.039 if you go to try to plan something and doesn't work in front of the 424 00:23:26.079 --> 00:23:30.799 crowd, you would be pretty stupid to keep doing something you plan it didn't 425 00:23:30.799 --> 00:23:33.400 work. It was pretty much you listen to the crowd and what they want. 426 00:23:33.480 --> 00:23:37.839 You know, it's an art form. So after the fusion, be 427 00:23:37.880 --> 00:23:40.880 like that. You know, because before the fusion, if I did wrestle 428 00:23:40.960 --> 00:23:42.799 one of those matches you're talking about, I would sit down, which I 429 00:23:42.880 --> 00:23:45.440 never did. I would sit down and plan out, Okay, you know 430 00:23:45.480 --> 00:23:48.480 we're gonna do this, this, this, and this, the whole match. 431 00:23:48.880 --> 00:23:52.480 The stuff that I did in the ring was calculated and it's okay, 432 00:23:52.519 --> 00:23:56.680 I'm walking down. You know, I'm gonna block a punch, hits you 433 00:23:56.759 --> 00:23:59.720 twice and you scoot out from one of the ropes, or I'm gonna pick 434 00:23:59.799 --> 00:24:03.119 up a chair up and hit you. It wasn't a match. Everything that 435 00:24:03.160 --> 00:24:07.039 we talked about before the fusion wasn't written down, but it was calculating. 436 00:24:07.200 --> 00:24:11.119 All right, Well, let's go back to say two thousand and five or 437 00:24:11.160 --> 00:24:15.640 two thousand. You're at the height of your career. Your back problems haven't 438 00:24:15.680 --> 00:24:18.480 sort of gotten to you so bad. Yeah, you're going to go on 439 00:24:18.480 --> 00:24:22.240 a Monday night raw show. You're going to russell whomever, the Rock, 440 00:24:22.359 --> 00:24:25.759 somebody. Would you know going into the ring, would you have something written 441 00:24:25.799 --> 00:24:29.720 down, just like an outline? You know you're going to start out the 442 00:24:29.799 --> 00:24:32.000 Rock is going to kick your butt for you know, the first few minutes 443 00:24:32.000 --> 00:24:33.200 and then you're going to give it him in a headlock. Or was it 444 00:24:33.200 --> 00:24:36.759 just something like you've described, You talk about it with the Rock and then 445 00:24:36.799 --> 00:24:38.599 you get out there and it just sort of flows. Well, Rock was 446 00:24:38.680 --> 00:24:42.680 different. Okay, that's another example, bad example. Okay, two thousand 447 00:24:42.720 --> 00:24:47.400 and five, two thousand, it would not have been talked about. I've 448 00:24:47.400 --> 00:24:55.440 been talked before. Okay, would it have been written down? No, 449 00:24:55.920 --> 00:25:00.519 okay, you're the rock warming to talk about things. And it was the 450 00:25:00.519 --> 00:25:03.200 first time in my career I'd ever done this, you know. Actually flew 451 00:25:03.240 --> 00:25:04.359 down to Miami a month, a week, you know, ten days, 452 00:25:04.359 --> 00:25:07.319 I don't know when it was before the match in Toronto, and he had 453 00:25:07.319 --> 00:25:11.960 a ring set up and he wanted to go through the whole match, and 454 00:25:11.000 --> 00:25:15.000 he had someone there called an Asian I got I named Pat Patterson, you 455 00:25:15.039 --> 00:25:18.200 know, his father, and he wanted to go through this match, you 456 00:25:18.200 --> 00:25:19.880 know, and do all the all, do all the falls and everything. 457 00:25:21.119 --> 00:25:22.119 And I said, you know, there's no way I can let I can 458 00:25:22.160 --> 00:25:26.799 do that here, you know, because you're probably we're probably gonna get hurt. 459 00:25:26.880 --> 00:25:29.519 You know, it's an old ring and there's nobody here to give you 460 00:25:29.559 --> 00:25:33.000 any adrenaline. But we did walk through the match and everything he wanted to 461 00:25:33.039 --> 00:25:34.799 do. And then when we got to Toronto, he started punching me like 462 00:25:34.839 --> 00:25:37.640 he wanted to do, and the place was booing him out of the building 463 00:25:37.880 --> 00:25:41.119 and he looked at me with a deer in the headlights and goes, what 464 00:25:41.119 --> 00:25:42.400 do we do? And I said, take it easy, brother, I'll 465 00:25:42.400 --> 00:25:45.480 get us back on track. Just listen to the crowd and listen to me. 466 00:25:45.839 --> 00:25:48.559 So the rock was different. That was the only time I let somebody 467 00:25:48.559 --> 00:25:52.119 walk me through a match, and we didn't do any of this stuff we 468 00:25:52.160 --> 00:25:55.200 talked about because it didn't work. So if I wanted to send a request 469 00:25:55.240 --> 00:25:57.599 to TNA and say send me scripts of matches, you don't think there would 470 00:25:57.640 --> 00:26:02.640 be any well there being with me involving you. Yeah, No, not 471 00:26:02.759 --> 00:26:06.000 with me, dude. Okay. I did have a guy one time named 472 00:26:06.039 --> 00:26:08.400 Diamond Dallas Page in the only nineties I was wrestling. He was from Atlanta. 473 00:26:08.480 --> 00:26:11.920 He's still up there. Yeah, he actually facts a twenty page thing 474 00:26:17.319 --> 00:26:19.640 and he actually facts a twenty page thing of take a step, take a 475 00:26:19.680 --> 00:26:23.240 half step, block a punch, moved six more inches. Duck this when 476 00:26:23.279 --> 00:26:26.519 I was like, I said, you're out of your mind. I said, 477 00:26:26.720 --> 00:26:27.839 you know, I could never remember all this. You know, you 478 00:26:27.880 --> 00:26:32.000 know, you know once again, none of that happened. That's the only 479 00:26:32.039 --> 00:26:36.720 time anybody's ever written a match out for me was Domin Dallas Page. He 480 00:26:36.759 --> 00:26:37.960 said it to me, and he had only been in the business a couple 481 00:26:38.000 --> 00:26:41.799 of years. I'm like, this is insane. Okay, But your practice 482 00:26:41.880 --> 00:26:45.599 most or all the time was really to sort of see what the outcome was, 483 00:26:45.640 --> 00:26:49.559 and then you would determine artistically how to get there exactly. Okay. 484 00:26:49.599 --> 00:26:52.759 So all right, So this window of opportunity you've described in two thousand and 485 00:26:52.799 --> 00:26:56.400 nine, is it your testimony to a jury that had you had the fusion 486 00:26:56.440 --> 00:27:00.519 in late February early March of two thousand and nine, that you would have 487 00:27:00.519 --> 00:27:03.839 been participating without restriction in the WrestleMania event which was in Houston, I think 488 00:27:03.880 --> 00:27:07.599 Reliant Stadium. Is that your testimony? No? Okay? And that is 489 00:27:07.640 --> 00:27:10.640 it your testimony that had you had the fusion surgery in late February or early 490 00:27:10.720 --> 00:27:12.279 March whenever it was scheduled four in two thousand and nine, that you would 491 00:27:12.279 --> 00:27:15.079 have been able to participate in the Summer Slam at the Staples Center in August 492 00:27:15.119 --> 00:27:18.680 without restriction. Well, it's a very lively possibility. You the way my 493 00:27:18.720 --> 00:27:22.160 back healed a couple of years later with a fusion, with not being as 494 00:27:22.240 --> 00:27:26.880 good as shape as before, it's a very good possibility I could have made 495 00:27:26.920 --> 00:27:29.279 a ventd of Summer Slam or been on the card. Who was it who 496 00:27:29.279 --> 00:27:32.359 made the decision? That you were not going to participate in the w W 497 00:27:32.559 --> 00:27:34.079 events in the calendar year of two thousand and nine. Was that you or 498 00:27:34.160 --> 00:27:37.240 was that vins or someone else? Which events are you talking about When you 499 00:27:37.240 --> 00:27:40.799 say events, Well, I mean any event. I mean. I don't 500 00:27:40.799 --> 00:27:42.359 want to restrict him to SummerSlam in WrestleMania. I mean there might have been 501 00:27:42.759 --> 00:27:45.400 the Monday night raw tapings. There could have been, there was a Thursday 502 00:27:45.480 --> 00:27:48.160 night show I think. I mean, I'm not trying to restrict you. 503 00:27:48.160 --> 00:27:51.920 I'm asking you. You know this window of opportunity that you say you missed. 504 00:27:52.000 --> 00:27:53.920 Who decided that you would not take advantage of that? You were Vince 505 00:27:55.119 --> 00:27:56.720 or Well? I called Vince and I told him that my back didn't get 506 00:27:56.759 --> 00:28:00.480 fixed like I thought I would with a minimal ASA surgery, which would have 507 00:28:00.480 --> 00:28:04.960 put me at the wrestle at WrestleMania with Sena. I just had to call 508 00:28:06.039 --> 00:28:08.279 him and tell him that in my back just keeps get going out on me. 509 00:28:08.319 --> 00:28:11.920 Mister Beala, you were never going to wrestle at WrestleMania against John Cena 510 00:28:11.960 --> 00:28:15.519 in a traditional wrestling match without restriction if you had had that fusion. Isn't 511 00:28:15.559 --> 00:28:18.559 that right? Also? I'm right at all. If I'd had the fusion, 512 00:28:18.920 --> 00:28:22.240 I would have never wrestled Russell Money at all. There would have been 513 00:28:22.279 --> 00:28:25.680 no match. If I'd had the fusion in February of oh nine, I 514 00:28:25.720 --> 00:28:29.240 would I would have healed and gutten ready for SummerSlam or whenever Vince wanted me, 515 00:28:29.400 --> 00:28:32.000 and I would have had to deal with Vince where we were talking about 516 00:28:32.000 --> 00:28:34.160 and move forward from that point. The only way I would have wrestled Russell 517 00:28:34.200 --> 00:28:38.440 Maney against John would have been John Cena would have been as I talked with 518 00:28:38.559 --> 00:28:41.119 Vince and we planned on it and we were going to do it. The 519 00:28:41.160 --> 00:28:45.480 only way I could have done that is is if what doctor Saint Louis told 520 00:28:45.519 --> 00:28:48.640 me would have been true, that he could fix me, and I only 521 00:28:48.680 --> 00:28:52.880 thought it was going to be one surgery and it would be minimal invasive. 522 00:28:52.599 --> 00:28:55.480 He said, you know, you'd be good to go in a couple of 523 00:28:55.480 --> 00:28:56.960 weeks. If that would have been true, I could have rustled Sena at 524 00:28:56.960 --> 00:29:00.799 WrestleMania. Doctor Saint Louis never ever told you that he was going to get 525 00:29:00.799 --> 00:29:04.359 you back into the wrestling ring to wrestle John Cena at WrestleMania in a traditional 526 00:29:04.400 --> 00:29:07.880 wrestling match, without restriction. He did not tell you that, did he. 527 00:29:08.200 --> 00:29:11.319 He did not mention John Cena. But he said he could fix me 528 00:29:11.319 --> 00:29:14.480 and I would be good to go in a couple of weeks. What he 529 00:29:14.519 --> 00:29:17.039 told you, mister Balai, is that he hoped to provide you some pain 530 00:29:17.079 --> 00:29:21.119 relief to allow you to participate in the activity of daily living activities of daily 531 00:29:21.160 --> 00:29:23.559 living without being in debilitating pain. Isn't that what he told you. I 532 00:29:23.720 --> 00:29:26.480 was there, you know, I know what he told me. That's not 533 00:29:26.599 --> 00:29:30.400 true. What you're saying your testimony to the jury is that he told you 534 00:29:30.480 --> 00:29:33.039 he was going to cure your back problems to the point where you were not 535 00:29:33.119 --> 00:29:37.480 going to have any back pain or any structural back problems. Is that your 536 00:29:37.519 --> 00:29:41.720 testimony? My testimony is he told me I did not need a fusion and 537 00:29:41.799 --> 00:29:45.880 with his minimal invasive surgery, and he never said six surgeries. He said, 538 00:29:45.880 --> 00:29:49.240 with his minimal invasive surgery, which I thought would be one time, 539 00:29:49.480 --> 00:29:52.359 that I would be good to wrestle in a couple of weeks. You know, 540 00:29:52.440 --> 00:29:56.119 I'm going to hit the wrestrom real I'm gonna hit the rushroom real quick. 541 00:29:56.119 --> 00:29:59.440 You're all be back at the time is three thirty seven, we're off 542 00:29:59.440 --> 00:30:03.200 the record, recess the Times three forty seven. We're back on the record, 543 00:30:03.279 --> 00:30:07.200 continued examination by mister Train. Mister Balaya, let me hand you what 544 00:30:07.240 --> 00:30:11.119 I'm going to market his exhibit. I think we're up to six. Exhibit 545 00:30:11.119 --> 00:30:15.519 six marked for identification for the record. This is a document entitled informed Consent 546 00:30:15.640 --> 00:30:19.559 of Terry Jean Balia. We've marked as exhibit six. Have you had an 547 00:30:19.559 --> 00:30:22.880 opportunity to review that Exhibit six, mister Balea, Yes, it's at your 548 00:30:22.920 --> 00:30:26.119 signature on the back page second page. Devil was like a copy of it. 549 00:30:26.200 --> 00:30:32.559 Okay. Do you recall being provided with this informed Do you remember being 550 00:30:32.599 --> 00:30:37.359 provided with this informed consent prior to your first procedure at Laser Spine Institute, 551 00:30:37.799 --> 00:30:40.640 No, I don't recall, okay. And do you recall discussing the contents 552 00:30:40.640 --> 00:30:42.680 of this with Doctor Saint Louis before your procedure? No, I don't. 553 00:30:42.759 --> 00:30:47.079 It's it true, mister Balaiah, that you had consulted with doctor Juan Uribey 554 00:30:47.359 --> 00:30:51.839 at the Health Services Center Medical Clinic, and that doctor Euribe explained that your 555 00:30:51.880 --> 00:30:56.559 first option was considerable conservative management, but that given your years of such treatment 556 00:30:56.559 --> 00:30:57.640 and lack of success with it. He did not see it as a viable 557 00:30:57.680 --> 00:31:02.079 option. Did you have that conversation with doctor Euribey, Yeah, you know, 558 00:31:02.119 --> 00:31:04.240 when I met with him and decided on having the fusion, we talked 559 00:31:04.240 --> 00:31:07.559 about all the other options that I had tried at that point, and he 560 00:31:07.599 --> 00:31:11.279 agreed that they weren't giving me relief and they didn't work. And then did 561 00:31:11.319 --> 00:31:17.039 you discuss with Doctor Saint Louis prior to your surgery at LSI, that doctor 562 00:31:17.119 --> 00:31:19.480 uribe had said you could have a surgery that involved a multiple level fusion, 563 00:31:19.799 --> 00:31:23.359 and that you were concerned about some of the potential consequences of such surgery, 564 00:31:23.400 --> 00:31:26.960 including, but not limited to time for recovery, likely pain relief, and 565 00:31:27.000 --> 00:31:30.119 possible lesser mobility. With those some of the concerns you had about a fusion 566 00:31:30.160 --> 00:31:33.920 procedure. And my concerns about a fusion procedure, which I talked to all 567 00:31:33.960 --> 00:31:37.960 the doctors about, was it was uncertain whether it would work or not or 568 00:31:38.039 --> 00:31:42.119 make things worse. That's why every doctor I talked I talked to you said, 569 00:31:42.119 --> 00:31:47.559 try any other option first before you decide on the fusion, which is 570 00:31:47.559 --> 00:31:49.799 the final straw. And then when nothing else works and would you agree that 571 00:31:49.839 --> 00:31:53.759 paragraph seven to this document reflects exactly that, yes? And then would you 572 00:31:53.799 --> 00:31:57.680 agree wouldn't you that paragraph eight reflects that it was you who wanted to explore 573 00:31:57.680 --> 00:32:01.880 possible surgical alternatives instead of a fusion. Correct, Yes, And in fact, 574 00:32:01.880 --> 00:32:06.160 doctor Saint Louis didn't tell you that he could fix you and that he 575 00:32:06.160 --> 00:32:07.960 could make you pain free and allow you to get back in the wrestling ring 576 00:32:07.960 --> 00:32:12.400 without restriction. Doctor Saint Louis advised that he could perform a procedure that might 577 00:32:12.400 --> 00:32:15.480 reduce the amount of back pain you had, as reflected in paragraph nine. 578 00:32:15.519 --> 00:32:17.960 Isn't that true? Not completely? What is not completely true about that statement? 579 00:32:19.240 --> 00:32:21.640 Well, he told me that I did not need a fusion and that 580 00:32:21.720 --> 00:32:23.559 he could relieve me of the pain to where I could get back and wrestle. 581 00:32:23.839 --> 00:32:28.400 And although paragraph nine says that there's a surgical procedure that he could perform 582 00:32:28.440 --> 00:32:30.160 that might reduce the amount of pain, it doesn't say eliminate. It says 583 00:32:30.240 --> 00:32:34.319 might reduce the amount of pain. You sign this document? Did you not 584 00:32:35.799 --> 00:32:37.160 repeat the question again? Sure, I'll phrase it. It was a poorly 585 00:32:37.200 --> 00:32:40.519 worded question. Your testimony is doctor Saint Louis told you that he could make 586 00:32:40.519 --> 00:32:43.559 you pain free, fix your pain, and you could get back in the 587 00:32:43.559 --> 00:32:46.279 wrestling ring. Paragraph nine says that he talked to you about performing a procedure 588 00:32:46.319 --> 00:32:50.920 that might reduce the amount of back pain, and you signed that document, 589 00:32:50.960 --> 00:32:54.640 didn't you. It's a compound question. You could answer it if you understand 590 00:32:54.680 --> 00:32:59.680 it. Yeah, you know he told me that the surgery and that he 591 00:32:59.720 --> 00:33:02.400 would perform could fix me, yeah, and reduce back pain. But he 592 00:33:02.480 --> 00:33:07.039 also said that I might need to do an additional surgery to you, which 593 00:33:07.039 --> 00:33:08.640 I understood. All right, So you knew it that very first visit that 594 00:33:08.680 --> 00:33:12.759 you may have more than one surgery. You knew there was a possibility. 595 00:33:13.240 --> 00:33:15.319 Yeah, because he was being conservative and you wanted I'm sorry, I didn't 596 00:33:15.319 --> 00:33:17.480 mean to interrupt you. Go ahead, no, no, go ahead, 597 00:33:17.519 --> 00:33:21.039 Brunn, to be conservative, right. You wanted him to do the least 598 00:33:21.039 --> 00:33:22.519 amount to your back that hopefully would reduce the pain. Isn't that right, 599 00:33:23.039 --> 00:33:27.640 The least amount of my back that would fix me where I could get back 600 00:33:27.680 --> 00:33:30.359 to work. Okay. Now, I was in the middle of talking with 601 00:33:30.480 --> 00:33:34.160 Vince about wrestling Scena WrestleMania, and Saint Louis told me, you know, 602 00:33:34.279 --> 00:33:37.160 he could fix me where I could work, you know, and Matt, 603 00:33:37.200 --> 00:33:39.480 I don't need a fusion, And that's the whole basis for this whole thing. 604 00:33:39.680 --> 00:33:43.400 But he never told you that you could get back to wrestle Sena in 605 00:33:43.400 --> 00:33:45.880 two months in a wrestling match and be the main event with all the physical 606 00:33:45.880 --> 00:33:49.640 activity that you did in two thousand and two thousand and five and WrestleMania x 607 00:33:49.759 --> 00:33:52.519 nine with the Rock. I mean, he didn't tell you that, well, 608 00:33:52.559 --> 00:33:54.119 all of a dialogue that you added, but he told me that he 609 00:33:54.160 --> 00:33:58.119 could fix me and I'd be able to wrestle in two weeks. That's what 610 00:33:58.160 --> 00:34:00.799 I was counting on. That's why I was in to go with Vince. 611 00:34:00.839 --> 00:34:02.119 And if you will strike that maybe I misheard you. If you had the 612 00:34:02.160 --> 00:34:06.039 fusion procedure, do you believe you would have been back in the wrestling ring 613 00:34:06.079 --> 00:34:08.079 with John Cena on April fifteen, two thousand and nine, at the Reliant 614 00:34:08.119 --> 00:34:12.239 Stadium in a match without restrictions if you had had the fusion? No? 615 00:34:12.239 --> 00:34:15.559 No, never, Okay, I just I've stated that I believe that I 616 00:34:15.599 --> 00:34:21.039 would have known exactly what was going to happen and could have continued to negotiate, 617 00:34:21.079 --> 00:34:24.320 and I missed that window of the long term deal and being figured back 618 00:34:24.320 --> 00:34:28.079 in as a main event wrestler. So you knew when you were a meeting 619 00:34:28.119 --> 00:34:30.280 with Doctor Saint Louis, before they ever operated on you, that you might 620 00:34:30.360 --> 00:34:36.599 need additional minimally invasive spine surgery laser spine surgery. Right, he said it 621 00:34:36.639 --> 00:34:38.440 was a possibility, okay, And you also knew that it was a possibility 622 00:34:38.480 --> 00:34:43.599 that you may have to have the fusion surgery. From what he told me, 623 00:34:43.639 --> 00:34:45.280 he made me feel like I did not need a fusion, that he 624 00:34:45.320 --> 00:34:49.360 could fix me. I didn't care if my bones were straight or not. 625 00:34:49.679 --> 00:34:52.440 I just wanted to wrestle and not be in pain. You know. I 626 00:34:52.800 --> 00:34:54.920 couldn't see the bones if they were crooked or out of line, and he 627 00:34:55.000 --> 00:34:59.159 never looked at them before these issues came up. So I don't know if 628 00:34:59.239 --> 00:35:01.159 I had scull you this is or anything I saw. All I cared about 629 00:35:01.119 --> 00:35:05.000 I was being able to go back to work, and that's what he assured 630 00:35:05.039 --> 00:35:07.639 me I could do with this minimal invasive surgery. All right, Setting aside 631 00:35:08.239 --> 00:35:12.119 what you say he told you, what about what you read in this document, 632 00:35:12.119 --> 00:35:15.760 And I'm referring you to paragraph eleven I understand that any relief that I 633 00:35:15.800 --> 00:35:20.960 obtain may not be permanent. Did you read that back before you had the 634 00:35:21.000 --> 00:35:23.840 minimally invasive procedure with doctor St. Louis. I don't recall reading this, 635 00:35:24.960 --> 00:35:30.159 And the next sentence says, I understand that I may eventually have to undergo 636 00:35:30.239 --> 00:35:34.679 further surgery as described by doctor Uribay, that would be the fusion. Do 637 00:35:34.679 --> 00:35:37.519 you recall reading that before you agreed to have the surgery? No, I 638 00:35:37.519 --> 00:35:40.119 don't recall reading that, okay, but you're not telling the jury that you 639 00:35:40.199 --> 00:35:45.159 weren't given an opportunity to read this. I mean you may have read it 640 00:35:45.199 --> 00:35:46.480 that day. You may not have read it that day, but you certainly 641 00:35:46.559 --> 00:35:51.480 signed it. Let me just object to something because you misread the document. 642 00:35:51.519 --> 00:35:52.960 You said that quote, you added the words that would be the fusion. 643 00:35:53.519 --> 00:35:58.559 Those words don't appear in there. Those are your words. Okay, you're 644 00:35:58.599 --> 00:36:01.480 misrepresenting the document that he doesn't recall reading. That's cute, that's cute. 645 00:36:02.119 --> 00:36:12.559 Is it kind of cute that you inserted that tribala? What other surgery to 646 00:36:12.639 --> 00:36:15.559 doctor your rebate recommend to you other than the spinal fusion surgery? That was 647 00:36:15.599 --> 00:36:20.400 it? That's what I thought, all right, So back to my original 648 00:36:20.480 --> 00:36:22.559 question. Are you telling the jury that you know you didn't have a chance 649 00:36:22.599 --> 00:36:25.559 to read this, or that you were tricked into signing it or something like 650 00:36:25.599 --> 00:36:29.199 that, or do you just not remember it because it was I mean it 651 00:36:29.280 --> 00:36:31.360 was over four years ago. Well I don't remember it because it was over 652 00:36:31.400 --> 00:36:35.880 four years ago and I was signing. If it was ten pages, it 653 00:36:35.960 --> 00:36:38.000 was one hundred and ten pages. You know, multiple documents, and you 654 00:36:38.039 --> 00:36:40.559 know, from what I remember, sign him most of them on you know, 655 00:36:40.559 --> 00:36:44.800 like a credit card electronic thing, you know, so I signed a 656 00:36:44.800 --> 00:36:47.000 lot of stuff. You know, the lady would hit the computer, sign 657 00:36:47.039 --> 00:36:50.280 your name, hit the computer, sign your name. So I mean, 658 00:36:50.280 --> 00:36:52.840 I don't remember reading this, and if I did read it, I didn't 659 00:36:52.880 --> 00:36:55.599 remember. So there were just so many pages of things that I was dealing 660 00:36:55.639 --> 00:36:59.199 with. Well, okay, but I mean, you're the patient and this 661 00:36:59.239 --> 00:37:01.440 is a legal document you're being asked to sign. And actually paragraph fifteen says 662 00:37:01.480 --> 00:37:05.639 I have read this entire document consisting of two pages, at least twice before 663 00:37:05.679 --> 00:37:07.679 signing it. I mean, are you telling me the jury that you didn't 664 00:37:07.679 --> 00:37:09.519 read this at all? I'm telling the jury I don't recall, okay, 665 00:37:09.679 --> 00:37:13.679 do you agree with me that had you read this document on Fabry twenty seventh, 666 00:37:13.760 --> 00:37:15.960 the day before your surgery, that you would have understood that LSI was 667 00:37:16.000 --> 00:37:20.559 performing a procedure which might reduce your pain, but that it might not be 668 00:37:20.679 --> 00:37:23.639 permanent, and that you might need to undergo further surgery as described by doctor 669 00:37:23.639 --> 00:37:27.840 your rebate, you agree with me that if you read this on February twenty 670 00:37:27.840 --> 00:37:30.119 seventh, you would have known those things. I'd agree with that. You 671 00:37:30.119 --> 00:37:34.840 know, if I'd have read that on February twenty seventh, the might things 672 00:37:34.880 --> 00:37:37.960 that could have happened, and might have happened, but they're not as important 673 00:37:37.000 --> 00:37:39.679 as what happened to me. I mean, do you recall that your surgery 674 00:37:39.760 --> 00:37:44.119 was performed on a Saturday? No, I don't. Paragraph the next to 675 00:37:44.159 --> 00:37:47.519 last paragraph says that I understand that surgery will be performed on a Saturday because 676 00:37:47.559 --> 00:37:51.679 I have a film crew that would like to film portions of my visit to 677 00:37:51.880 --> 00:37:54.360 LSI, that otherwise I would be provided the same treatment as any other patient 678 00:37:54.639 --> 00:37:58.400 of LSI. Do you remember that they accommodated you in the film crew. 679 00:37:58.440 --> 00:38:00.280 They came in on a Saturday. The film crew could film this. Do 680 00:38:00.280 --> 00:38:04.039 you remember any of that taking place? No, I don't, okay, 681 00:38:04.079 --> 00:38:06.679 I mean, is it your testimony we'll strike that. Is it your recollection 682 00:38:07.119 --> 00:38:10.840 that these doctors weren't discussing all this with you and telling you what you know, 683 00:38:10.880 --> 00:38:14.760 the possibilities were, and they weren't answering your questions. Is that your 684 00:38:14.760 --> 00:38:17.280 recollection? The best of my recollection is, you know, Saint Louis said, 685 00:38:17.360 --> 00:38:22.239 we're going to do this minimal invasive surgery. And when I was and 686 00:38:22.280 --> 00:38:23.840 when I was out of pain, I mean, you know, when I 687 00:38:23.880 --> 00:38:25.960 was back in the pain in pain, he said, you know, you 688 00:38:27.000 --> 00:38:29.519 know, we got to do another surgery because I didn't get it or I 689 00:38:29.559 --> 00:38:32.440 didn't get as aggressive as I should. And my recollection goes back to him 690 00:38:32.440 --> 00:38:36.679 telling me that I didn't need a fusion, and with him being the doctor 691 00:38:36.760 --> 00:38:38.880 and knowing what was going on, I trusted him when he said, you 692 00:38:38.920 --> 00:38:43.960 didn't need fusion. And my whole mindset was based on, let's get this 693 00:38:44.000 --> 00:38:45.719 minimal invasive surgery because I don't need a fusion. We can fix it. 694 00:38:46.119 --> 00:38:50.320 So whether it was two surgeries or six or sixty, I was in the 695 00:38:50.360 --> 00:38:52.199 game with him and I trusted him. That he could fix it, because 696 00:38:52.440 --> 00:38:54.840 that's what he told me the first day that I walked in there, that 697 00:38:54.880 --> 00:38:58.960 I don't need a fusion. And if his testimony, Sir, was that, 698 00:38:59.360 --> 00:39:01.679 you know, maybe fix it is wrong, you maybe get out of 699 00:39:01.719 --> 00:39:06.440 pain, because I never dreamed that he could fix the bones. I just 700 00:39:06.599 --> 00:39:08.559 I knew we were we weren't doing that. I knew he was going to 701 00:39:08.760 --> 00:39:12.599 fix my back, so I wasn't in pain and I could continue working on 702 00:39:12.639 --> 00:39:15.679 with my career. If his testimony was that he told you that they thought 703 00:39:15.679 --> 00:39:17.519 they could perform a procedure on you that would reduce your pain to a level 704 00:39:17.559 --> 00:39:21.199 that allowed you to work, not get in the wrestling ring, but be 705 00:39:21.239 --> 00:39:22.719 a celebrity wrestler and be up there and be the face of the company and 706 00:39:22.760 --> 00:39:25.039 do those kinds of things, but not get in the ring and wrestle and 707 00:39:25.079 --> 00:39:28.960 get your pain reduced to where you could work out, walk, travel without 708 00:39:29.000 --> 00:39:32.400 being in debilitating pain. Is that not the conversation you recall having with doctor 709 00:39:32.400 --> 00:39:37.719 Saint Louis's definitely not the conversation. So if he testified to something like that, 710 00:39:37.760 --> 00:39:39.519 he doesn't. He's either telling a lie or he doesn't remember accurately. 711 00:39:39.920 --> 00:39:43.280 Right right at the time, you believe that, as you said, they 712 00:39:43.280 --> 00:39:45.719 were on Team Hogan, that they had your best interests at heart and we're 713 00:39:45.760 --> 00:39:49.519 trying to do the best for you at the time you first started seeing them. 714 00:39:49.800 --> 00:39:52.039 Yes, okay, I'm going to kind of jump back to that meeting. 715 00:39:52.159 --> 00:39:55.119 You and I originally were originally before our break talking about your ongoing what 716 00:39:55.159 --> 00:40:00.519 you say are ongoing conversations I guess with Vince and were you personally having these 717 00:40:00.559 --> 00:40:04.280 conversations about getting your brand up and running or were your representatives talking with Vince 718 00:40:04.400 --> 00:40:07.639 or both. Well, I was mainly focusing on Sena and the wrestling, 719 00:40:07.079 --> 00:40:10.079 you know, when I knew my back would be fixed from LSI, I 720 00:40:10.159 --> 00:40:15.000 was mainly focused on getting on that main stage with Sena right away because the 721 00:40:15.039 --> 00:40:16.880 time frame worked perfectly for me, even though it was pushing it. For 722 00:40:16.920 --> 00:40:21.519 a normal WrestleMania, usually you need twelve weeks to promote it. But the 723 00:40:21.559 --> 00:40:23.400 last WrestleMania with the Rock was such a you know, with me coming back 724 00:40:23.440 --> 00:40:29.119 after being gone for ten years, it was such a loyal following. We 725 00:40:29.360 --> 00:40:32.760 knew that we could have a shorter promotion time and would work with Sena, 726 00:40:32.840 --> 00:40:36.880 So my focus was making sure that the TV's going, you know, going 727 00:40:36.880 --> 00:40:39.920 into the Cena match, were set up the right way. Um when when 728 00:40:40.320 --> 00:40:43.920 you know where it was going to be the good the good guy, good 729 00:40:43.960 --> 00:40:46.840 guy respect for you or you know, whether it was gonna uh, whether 730 00:40:46.880 --> 00:40:50.519 it was going to cheap shot him, or what storyline we were going to 731 00:40:50.679 --> 00:40:52.920 go down to create the most interest, you know, that was my main 732 00:40:53.000 --> 00:40:57.559 focus. At the same time, my attorney, Henry Holmes, my entertainment 733 00:40:57.559 --> 00:41:00.360 attorney, had worked out all the deals with Vince in the past, asked 734 00:41:00.159 --> 00:41:04.159 and he knew what our objective was, and to get the money to a 735 00:41:04.199 --> 00:41:07.760 point where it was reasonable and to have a jump off point where I could 736 00:41:07.760 --> 00:41:10.599 get back on track, you know, and performed to where I could generate 737 00:41:10.960 --> 00:41:15.440 enough revenue for it to be advantageous for all of us. I wasn't working 738 00:41:15.440 --> 00:41:19.800 on that mainly. That was that mainly, that was mainly Henry working on 739 00:41:19.800 --> 00:41:21.920 that. You know, when I was where I was focusing more on the 740 00:41:21.920 --> 00:41:24.800 matter in hand with Sina and making sure that in ring went right. Who 741 00:41:24.840 --> 00:41:30.360 will strike that? Where would I want to go if I wanted to find 742 00:41:30.360 --> 00:41:32.440 out all these efforts that you were making to get the Scena thing going. 743 00:41:32.480 --> 00:41:36.280 I mean, who were you talking to at the w W about the lighting? 744 00:41:36.599 --> 00:41:38.920 And who are you talking to or writing back and forth corresponding with about 745 00:41:39.000 --> 00:41:42.320 you know, am I going to cheap shot him? Or are we going 746 00:41:42.320 --> 00:41:45.599 to have the mutual respect deal? Other than your word? Where would I 747 00:41:45.639 --> 00:41:47.679 go to find out about all those efforts? Well, the only person I 748 00:41:47.679 --> 00:41:52.239 had conversations with, and I didn't talk to anybody about the lighting. Yeah, 749 00:41:52.239 --> 00:41:54.679 I didn't talk to anybody about about cheap shotting Sina or being the good 750 00:41:54.679 --> 00:41:59.320 guy. It was something that the theme was that Vince and I were getting 751 00:41:59.320 --> 00:42:02.000 ready to address because we were blocking dates out for the TV's going up for 752 00:42:02.000 --> 00:42:06.159 the WrestleMania and so Vince was the only guy I talked to. Okay, 753 00:42:06.760 --> 00:42:10.719 so Vince McMahon would understand those conversations because he was as the final say so 754 00:42:10.840 --> 00:42:15.599 on all the wrestling as far as Henry and his negotiations. I don't know 755 00:42:15.679 --> 00:42:17.679 who the attorney was at the time. It could have been Jeremy McDivitt, 756 00:42:17.719 --> 00:42:22.199 who was still an in house attorney. I don't know who else was in 757 00:42:22.239 --> 00:42:23.440 there, But I mean, you know, there were so many there were 758 00:42:23.519 --> 00:42:27.599 so many changes, and there's so many attorneys there. I don't. Jeremy 759 00:42:27.639 --> 00:42:30.800 mcdivot is a criminal attorney, but he's also Vince's personal attorney, so I 760 00:42:30.800 --> 00:42:35.239 don't know if they had a business attorney Henry was talking to. But Henry 761 00:42:35.239 --> 00:42:38.320 would know who the person was with regard to the negotiations going on between you 762 00:42:38.360 --> 00:42:42.400 and Vince and WW around this time that you say would taking place, do 763 00:42:42.440 --> 00:42:45.480 you have in your possession any letters, offers, proposals, things like that, 764 00:42:45.519 --> 00:42:49.519 written documents, something that you have that maybe you haven't given over to 765 00:42:49.519 --> 00:42:52.039 your lawyers that would give us some information about that. No, I don't, 766 00:42:52.559 --> 00:42:55.079 No, I don't. Henry had communications back and forth with them as 767 00:42:55.079 --> 00:42:59.639 far as the deal went. Do you remember this contract that you have testified 768 00:42:59.639 --> 00:43:02.159 to it you were going to possibly enter into with Vince. Does that contract 769 00:43:02.199 --> 00:43:06.039 exists? I mean in a draft forum. I know you never signed it, 770 00:43:06.039 --> 00:43:07.679 but in a draft form to your knowledge, Well, I know there's 771 00:43:07.679 --> 00:43:12.880 a draft form from two thousand and five when we originally started to address this 772 00:43:12.920 --> 00:43:15.159 thing, you know, but money. But the money wasn't right, It 773 00:43:15.199 --> 00:43:17.920 wasn't It wasn't even close to enough to sign because Vince, I think even 774 00:43:17.920 --> 00:43:21.239 on camera, he asked me when I was going to sign it, you 775 00:43:21.320 --> 00:43:23.599 know, when we were filming something and I seemed to call him saying, 776 00:43:23.639 --> 00:43:25.840 you know, yeah, you know, when are you going to sign this? 777 00:43:25.920 --> 00:43:29.920 You know, I apparently thought I was worth more than what, you 778 00:43:29.920 --> 00:43:31.440 know, what they wanted to pay me. So I never signed it, 779 00:43:31.840 --> 00:43:36.480 but it was readdressed when we when we decided to go back in business in 780 00:43:36.679 --> 00:43:40.000 oh nine with Sina and getting me on the team because i own my name, 781 00:43:40.079 --> 00:43:44.559 brand and likeness, and I'm one of the only wrestlers that do you 782 00:43:44.599 --> 00:43:47.039 know, the whole Coogan, whole Camania Hoults your name, and he has 783 00:43:47.199 --> 00:43:52.480 he only has or he only had the rights to the intellectual properties to repackage 784 00:43:52.480 --> 00:43:55.360 old matches and old images. So the thing was, since I was coming 785 00:43:55.400 --> 00:44:00.920 back to work to relaunch that brand so he could make more make money even 786 00:44:00.960 --> 00:44:04.679 if I died ten years from now, so he could make so he could 787 00:44:04.679 --> 00:44:07.880 make money like Elvis, even after Elvis was dead, you know, with 788 00:44:07.000 --> 00:44:10.000 the brand, the name and the likeness. He wanted the rights to my 789 00:44:10.159 --> 00:44:15.320 name and likeness for twenty twenty five years, and that was on the tamphlet 790 00:44:15.320 --> 00:44:17.800 along with Sina. But I don't know if there's a draft you know, 791 00:44:17.840 --> 00:44:22.000 I know that there was a two thousand and five one and we were we 792 00:44:22.039 --> 00:44:23.599 were going to that same path in two thousand and nine. What was the 793 00:44:23.639 --> 00:44:27.800 money if it wasn't enough in two thousand and five? What was the money 794 00:44:27.800 --> 00:44:31.000 that was being discussed between WWE and yourself for this path that you were going 795 00:44:31.039 --> 00:44:35.239 down this new contract? What were the financial terms? Well, it was 796 00:44:35.280 --> 00:44:38.079 around a two million dollars minimum, you know, for licensing, merchandising, 797 00:44:38.079 --> 00:44:42.159 and then for the wrestling, you know, because of Wrestlemanian pay per views, 798 00:44:42.199 --> 00:44:45.199 depending on how much I wrestled, if I was on the main event 799 00:44:45.280 --> 00:44:47.199 status of that card, you know, wh would have generated more than that. 800 00:44:47.360 --> 00:44:51.159 So there was a basic minimum that we could have agreed on. Okay, 801 00:44:51.159 --> 00:44:52.920 and you think it was around two million dollars? Yes, I do. 802 00:44:53.079 --> 00:44:57.119 Okay? Was there anything and I'm outside of ww now, was there 803 00:44:57.119 --> 00:44:59.880 any type of deals that you either were negotiating or that you were supposed to 804 00:45:00.000 --> 00:45:02.079 signed off on that you couldn't do because of the treatment at LSI like a 805 00:45:02.079 --> 00:45:06.679 book deal or a movie or TV appearing or something like that, not that 806 00:45:06.760 --> 00:45:08.000 I can recall. Oh, you know what, I take that back. 807 00:45:08.239 --> 00:45:12.840 I take that back. I'm miss spoke. There were two different cameo parts 808 00:45:12.840 --> 00:45:15.199 than my agent, Peter Young, who's an entertainment agent, called me for 809 00:45:15.639 --> 00:45:20.119 and Adam Sandler movies during that lside time that I just I couldn't do because 810 00:45:20.280 --> 00:45:22.039 I was in too much back pain. Said cameo parts. Was that in 811 00:45:22.119 --> 00:45:25.199 one Adam Sandler movie or two Adam Sandler movies? It was two? You 812 00:45:25.199 --> 00:45:28.800 know, he had two different movies who he called for. Do you know 813 00:45:28.840 --> 00:45:31.480 which ones they were? Yeah? What was a hairdresser movie? I don't 814 00:45:31.480 --> 00:45:35.400 I don't know the name of it, the like Zoltron or something, Zohan 815 00:45:36.000 --> 00:45:39.760 Zion, Zohan, Zoohan. You don't mess with the Zoohan. Yeah. 816 00:45:39.800 --> 00:45:43.719 I was supposed to be the landlord, this evil landlord that was Adam you 817 00:45:43.760 --> 00:45:47.119 know whatever his name, Sandler's landlord. Okay, and then I couldn't do 818 00:45:47.599 --> 00:45:51.840 you know that He called about another one, and then I just thought about 819 00:45:52.039 --> 00:45:54.320 a third one. There was an American Pie movie which was redone at the 820 00:45:54.360 --> 00:45:58.639 New American Pie Movie. Okay, they called for that, and I couldn't 821 00:45:58.639 --> 00:46:00.920 do. I'm not familiar with you know, which was first or which was 822 00:46:00.960 --> 00:46:05.199 second in that time frame. But now that they were sitting here talking about 823 00:46:05.239 --> 00:46:07.199 other opportunities. I do remember those, and do you think that you were 824 00:46:07.239 --> 00:46:09.639 not able to strike that? Do you believe that had you had the fusion 825 00:46:09.679 --> 00:46:13.199 in February two thousand and nine, that you would have been able to take 826 00:46:13.199 --> 00:46:15.920 part in these cameo appearances in these three movies? Oh, I have no 827 00:46:16.039 --> 00:46:20.440 idea. I mean, if I would have been down with a fusion for 828 00:46:20.440 --> 00:46:23.039 four or six months, I wouldn't have been able to too if they came 829 00:46:23.159 --> 00:46:27.719 during that time frame. Okay, but I was just telling you what you 830 00:46:27.719 --> 00:46:30.079 asked me about, LSI. Yeah, well, I'm talking about that time 831 00:46:30.119 --> 00:46:31.519 period. What I want to know is, if this case goes to trial, 832 00:46:31.559 --> 00:46:35.360 are you go and ask the jury to award you some money because you 833 00:46:35.519 --> 00:46:38.360 couldn't have a cameo and don't mess with the Zohan because of what happened that 834 00:46:38.559 --> 00:46:43.719 LSI? Well, I mind neither. You remind me aout opportunities, right, 835 00:46:44.239 --> 00:46:45.880 I mean out to think about it. So I'm here for thank you. 836 00:46:45.800 --> 00:46:47.719 You don't keep coming. I like it. Yeah, I am to 837 00:46:47.800 --> 00:46:52.840 please thank you. So Peter Young would have been the one to negotiate those 838 00:46:52.880 --> 00:46:54.400 deals for you, Yes, sir? All right? And do you have 839 00:46:54.440 --> 00:46:59.559 any documents in your possession that would reflect those negotiations, any correspondence from Sandler's 840 00:46:59.559 --> 00:47:00.760 representation, tips with the producer, the director, you know, hey, 841 00:47:00.760 --> 00:47:04.639 we need help to come to out to LA on such and such a data 842 00:47:04.679 --> 00:47:07.880 shoot. Is he able to do that? Anything like that. Peter would 843 00:47:07.880 --> 00:47:10.360 have done those, whether it by be email. I know that there there 844 00:47:10.360 --> 00:47:15.239 were no formal contracts drafted because I was I just basically couldn't do it, 845 00:47:15.519 --> 00:47:17.800 but there was communication. You know, Peter usually does the email thing. 846 00:47:19.280 --> 00:47:22.559 Do you think these negotiations came up after the first LSI visit? In other 847 00:47:22.559 --> 00:47:24.360 words, is this something that came across Peter's desk and he asked you and 848 00:47:24.360 --> 00:47:28.000 you said, no, I can't do it because I'm having these back surgeries. 849 00:47:28.119 --> 00:47:30.599 Or was it something that was in place before the visit to LSI and 850 00:47:30.639 --> 00:47:35.239 you were planning to do it and then had to call it off. I 851 00:47:35.320 --> 00:47:38.719 didn't. I wasn't planning. I wasn't planned before the surgeries. Okay, 852 00:47:38.719 --> 00:47:44.679 And do you know whether these offers or proposals, requests, inquiries, whatever 853 00:47:44.719 --> 00:47:45.960 we call them. Do you know if they came during the two thousand nine, 854 00:47:46.000 --> 00:47:49.960 two and ten or in two thousand and ten or did they come in 855 00:47:50.079 --> 00:47:52.920 after the fusion procedure in December two thousand and ten. And to the best 856 00:47:52.920 --> 00:47:57.960 of my recollection, I know that the Adam Sandler ones came in before the 857 00:47:58.000 --> 00:48:00.800 fusion, you know for sure. I'm not I'm not exactly positive about the 858 00:48:00.840 --> 00:48:05.719 American Pie offer that could have been then also, I'm not but I'm not 859 00:48:05.800 --> 00:48:07.599 sure any other You know, this is my opportunity, mister Balay, And 860 00:48:07.599 --> 00:48:10.320 I know I'm beating a dead horse, but it's my opportunity to find out 861 00:48:10.360 --> 00:48:14.360 what kind of financial claims you're going to make a trial. So are there 862 00:48:14.360 --> 00:48:16.800 any other financial opportunities that you were not able to realize because of the treatment 863 00:48:16.840 --> 00:48:20.760 at LSI? And we're going to dig a little deeper into the ww contract. 864 00:48:20.840 --> 00:48:22.320 But we've talked about that a little bit. And now we've talked about 865 00:48:22.320 --> 00:48:27.519 these potential movie roles. Anything else that you can think of that I can 866 00:48:27.559 --> 00:48:30.159 think of now? And do you remember the name of that Adam Standley movie 867 00:48:30.199 --> 00:48:32.239 or what it was about? The second one? No, Peter would know, 868 00:48:32.360 --> 00:48:35.159 you know, he would know the movies. Okay, you don't even 869 00:48:35.199 --> 00:48:37.199 remember what the plot was. I remember one of them, you know, 870 00:48:37.280 --> 00:48:42.119 sheer a freshman memory with the name hairdresser, right, Yeah, one's a 871 00:48:42.119 --> 00:48:45.360 hairdresser movie. Yeah, Zolan or something like that was the name. But 872 00:48:45.440 --> 00:48:49.599 you don't know anything about or remember anything about the plot of the second one. 873 00:48:50.880 --> 00:48:52.719 No, I didn't see them. I don't know what they were. 874 00:48:52.800 --> 00:48:53.679 Okay, I think you told me this, but let me make sure I 875 00:48:53.679 --> 00:48:58.599 have it. You never specifically spoke with any physician about participating at the Summer 876 00:48:58.599 --> 00:49:00.159 Slam event. It's that, right, like a specific discussion of Hey, 877 00:49:00.239 --> 00:49:02.840 there's this big of it in August in whatever it was, Staple Center or 878 00:49:02.840 --> 00:49:06.079 a Lion Stadium. I want to attend. Can I attend it? Can 879 00:49:06.079 --> 00:49:09.679 I wrestle without restrictions? Did you have that conversation with any physician about SummerSlam? 880 00:49:09.840 --> 00:49:14.559 Yes, sir. Now I'll focus on the immediate WrestleMania because the you 881 00:49:14.599 --> 00:49:16.599 know, positive words from Saint Louis that you know I would be good in 882 00:49:16.639 --> 00:49:20.480 a couple of weeks after the surgery. It was a fellow named Jared Barty 883 00:49:20.639 --> 00:49:24.760 Bartie. Do you know Jared Barton Barty b A rtie. The first name 884 00:49:24.840 --> 00:49:29.320 is Jared j R. D doesn't bring a bell. And Scott Hervey is 885 00:49:29.360 --> 00:49:31.039 one of your lawyers. Used to be. He's no longer one of your 886 00:49:31.159 --> 00:49:34.519 lawyers. When did that strike that? I asked you two questions. Is 887 00:49:34.559 --> 00:49:37.519 he no longer one of your lawyers? No, I don't work with him 888 00:49:37.519 --> 00:49:39.360 anymore. Okay, let me show you what I've marked as exhibit seven to 889 00:49:39.440 --> 00:49:44.719 your deposition. Exhibit seven, mark fredentification. Just for the record. That's 890 00:49:44.719 --> 00:49:47.400 an email from mister Hervey to mister Barty, dated February second, two thousand 891 00:49:47.400 --> 00:49:52.199 and nine, with the bates number of WWB slash LSI zero zero zero one 892 00:49:52.360 --> 00:49:55.280 five four. Is that seven? Yes, mister Bala, I'm going to 893 00:49:55.320 --> 00:49:59.559 read into the record paragraph three of mister Hervey's email. And he was your 894 00:49:59.679 --> 00:50:00.880 lawyer, one of your lawyers at the time, two thousand and nine, 895 00:50:01.840 --> 00:50:06.000 apparently so by this, I've never seen this before, and now I definitely 896 00:50:06.079 --> 00:50:09.679 know I'm not working with them. Okay. Paragraph three says Terry has concerns 897 00:50:12.280 --> 00:50:15.000 at once he performs at WrestleMania twenty five, we will have problems getting the 898 00:50:15.119 --> 00:50:22.400 content from WWE. Accordingly, we now want the entire library of video and 899 00:50:22.480 --> 00:50:27.079 photos, both at WWE and WCW delivered by March first. If the content 900 00:50:27.280 --> 00:50:31.400 is not delivered by such date the appearance agreement automatically terminates. The content should 901 00:50:31.400 --> 00:50:36.280 be delivered in a digital format on hard drives, properly indexed, with any 902 00:50:36.320 --> 00:50:42.079 clearance issues noted. All content should comply with the order. Mister Blay, 903 00:50:42.119 --> 00:50:45.360 isn't it true that you didn't wrestle in Wrestlomnia twenty five because your lawyers could 904 00:50:45.360 --> 00:50:49.159 never reach an agreement with the wwe Isn't that true? It's not true? 905 00:50:49.719 --> 00:50:52.679 Okay? Is there something about that paragraph three that I'm not understanding? Well, 906 00:50:52.719 --> 00:50:55.800 it has to do with the website that Scott Hervey was slow dragging his 907 00:50:55.920 --> 00:51:00.519 feet on, that it took almost a year d up and running. I 908 00:51:00.559 --> 00:51:02.480 guess he refers to that be a but that is something he must have done 909 00:51:02.519 --> 00:51:06.519 on his own. Because I would never demand a letter for all content to 910 00:51:06.559 --> 00:51:09.119 be used at random. I definitely something that I would not condone under any 911 00:51:09.159 --> 00:51:13.559 circumstances. I would be very specific with what I needed for a website, 912 00:51:15.320 --> 00:51:17.599 because this is very valuable material which he's demanding, which had nothing to do 913 00:51:17.719 --> 00:51:22.679 with me doing a deal with Vincent Russellmanian a long term deal. The appearance 914 00:51:22.719 --> 00:51:25.199 agreement referred to in paragraph three, that's an appearance agreement for you to appear 915 00:51:25.239 --> 00:51:30.280 at WrestleMania. Isn't that right? And that's what it's talking about. I 916 00:51:30.360 --> 00:51:32.559 could be definitely taken that way, but I would have never seen but I've 917 00:51:32.599 --> 00:51:36.039 never seen it, heard of it, or didn't know what was happening. 918 00:51:36.239 --> 00:51:39.400 When you say you didn't you didn't know there was an appearance agreement before no. 919 00:51:39.599 --> 00:51:43.280 I knew that there was an appearance agreement. I knew I was supposed 920 00:51:43.280 --> 00:51:45.719 to make an appearance to Russell's Sena. You know what. I was fixed 921 00:51:46.079 --> 00:51:50.079 from Saint Louis. I was supposed to wrestle there. But never have I 922 00:51:50.199 --> 00:51:53.559 seen a demand for the letter for content for via libraries for all photos exclusive 923 00:51:53.599 --> 00:51:58.239 to w W ANDWCW. And never have I seen a letter that says I 924 00:51:58.320 --> 00:52:01.599 would not make an appearance or automatically teraminate. I would never do that. 925 00:52:01.880 --> 00:52:06.519 That's not how I do business. That is Scott Hervey well, but he's 926 00:52:06.559 --> 00:52:08.920 representing you at the time. I mean the subject of this email is WWE 927 00:52:08.960 --> 00:52:14.199 and Terry Balaya. The first sentences Terry and I discussed various issues regarding the 928 00:52:14.239 --> 00:52:16.719 agreements. Our additional notes are as follows. Are you denying that those conversations 929 00:52:16.800 --> 00:52:21.079 took place. Well, I've never had that much conversation with Scott Hervey. 930 00:52:21.599 --> 00:52:23.400 This might be the reason he hasn't worked for me, But I don't remember 931 00:52:23.480 --> 00:52:27.639 why. You know, I just had to terminate him because of several inconsistencies, 932 00:52:27.920 --> 00:52:30.840 and this looks like one of the big ones. When did you terminate 933 00:52:30.920 --> 00:52:34.360 mister Hervey? I don't recall. Was it within the last year, the 934 00:52:34.440 --> 00:52:37.559 last four years? That was a few years back. I talked my old 935 00:52:37.559 --> 00:52:40.480 attorney, Henry Holmes, and he coming out of retirement because also desperate, 936 00:52:42.000 --> 00:52:45.079 Scott Hervey was screwing so many different things up that I was desperate to get 937 00:52:45.280 --> 00:52:49.000 somebody that was consistent. Did so. You don't know, sitting here today, 938 00:52:49.440 --> 00:52:52.440 whether the WWE assumed that you terminated or there was a termination of the 939 00:52:52.480 --> 00:52:57.480 appearance agreement due to its failure to provide this content. You don't know whether 940 00:52:57.519 --> 00:53:05.760 that's the case or not. Why, yeah, I do. How do 941 00:53:05.840 --> 00:53:08.960 you know? Well, because I told Vince and myself I couldn't wrestle. 942 00:53:09.039 --> 00:53:12.360 I can't do it. My back is too screwed up. Okay, and 943 00:53:12.400 --> 00:53:15.719 your back was screwed up before you went to LSI right, Well, I 944 00:53:15.800 --> 00:53:17.480 wasn't good. So do you have any knowledge of what the outcome was with 945 00:53:17.559 --> 00:53:21.079 regard to this email to Jared Bardi? In other words, do you know 946 00:53:21.639 --> 00:53:25.000 whether the content requested in this email was delivered by March first? Noah was 947 00:53:25.079 --> 00:53:28.960 never delivered and the website didn't you know? I could, I couldn't have 948 00:53:29.079 --> 00:53:31.440 hired. I could have hired somebody locally, very cheaply to have the website 949 00:53:31.480 --> 00:53:36.000 up and running in thirty to sixty days. But Scott Hervey convinced me that 950 00:53:36.119 --> 00:53:37.960 he needed to protect me, and it took him over a year and a 951 00:53:38.039 --> 00:53:42.760 lot of money to deliver, and he never delivered the website. So I 952 00:53:42.840 --> 00:53:46.159 don't know whatever happened with this demand other than it probably just was an acknowledge. 953 00:53:46.159 --> 00:53:51.440 It's so ridiculous. You guys can keep going up right back. The 954 00:53:51.519 --> 00:53:53.800 extent I want to show you is Exhibit eight, mister Blay. I now 955 00:53:53.880 --> 00:53:58.159 represent that it's a document produced to us in discovery, which is a letterhead 956 00:53:58.199 --> 00:54:02.679 of TNA Entertainment exhibitate mark for identification. I am good, all right, 957 00:54:02.920 --> 00:54:06.360 mister Blair. I don't think I have that many questions about this document. 958 00:54:06.440 --> 00:54:09.000 This is you would agree your signature is on this contract, yes, sir, 959 00:54:09.519 --> 00:54:13.280 and I guess this is supposed to be treated as confidential for purposes of 960 00:54:13.320 --> 00:54:17.199 this deposition, the document itself, according to the confidential order we have, 961 00:54:17.639 --> 00:54:21.840 right right. Yeah, I don't know if I need to say that or 962 00:54:21.880 --> 00:54:24.039 not. You probably already knew it. Tell me the data and this is 963 00:54:24.079 --> 00:54:28.480 October. It says October twelfth of two thousand and nine. There's a signature 964 00:54:28.519 --> 00:54:30.239 pace that has your signature. It's got Dixie Carter's signature on it. It's 965 00:54:30.239 --> 00:54:34.639 got a signature I think for Eric Eric Bischoff's signature. Is that correct? 966 00:54:34.679 --> 00:54:37.440 Do you see that? Well, let me get back to it and find 967 00:54:37.440 --> 00:54:42.320 out what's on there. Yeah, okay, And you know when mister Blair 968 00:54:42.400 --> 00:54:45.440 did negotiate, When mister Blair did negotiations with TNA, first start, if 969 00:54:45.480 --> 00:54:52.480 you recall when, yes, sir, probably three or four years before, 970 00:54:52.599 --> 00:54:55.800 okay, whenever there was a match in Japan. Yeah, it could have 971 00:54:55.880 --> 00:54:59.280 been two or three years before. And then there was a match in Japan 972 00:54:59.320 --> 00:55:01.679 with a GNA Jo and I was wrestling. I was there wrestling him, 973 00:55:01.920 --> 00:55:05.400 and at the time one of the owners of the company, Jeff Jarrett, 974 00:55:05.440 --> 00:55:07.320 came over there and shot a wrestling angle where he attacked me over there in 975 00:55:07.440 --> 00:55:10.840 Japan. And it was during that time frame when I first started talking to 976 00:55:10.920 --> 00:55:15.159 TNA. Okay, So I mean, did those negotiations kind of continue through 977 00:55:15.159 --> 00:55:17.960 the years and ultimately culminated this agreement right here? No, Okay, tell 978 00:55:19.000 --> 00:55:21.760 me what happened. Well, they went on back and forth for about a 979 00:55:21.880 --> 00:55:24.280 year, okay, And I was talking to Jeff Jarrett off and on and 980 00:55:24.440 --> 00:55:28.599 just decided the time it wasn't right for me or Hogan knows best, or 981 00:55:28.639 --> 00:55:30.800 whatever I was doing was more important for whatever the reason, I chose not 982 00:55:30.920 --> 00:55:35.800 to pursue it any further after talking with him, okay. And then at 983 00:55:35.840 --> 00:55:39.440 some point did it pick back up again? Yeah? And when would that 984 00:55:39.480 --> 00:55:44.559 have been I don't recall, Okay. Jeff was always reaching out to me. 985 00:55:44.960 --> 00:55:46.559 He wrestled me before, and he was an owner of the company, 986 00:55:46.679 --> 00:55:51.079 part only with the owner of the company, so he would always call out 987 00:55:51.119 --> 00:55:52.639 on a friendly basis and reach out, you know, see if I was 988 00:55:52.679 --> 00:55:57.320 interested. But it was pretty consistent of calls from him. Was he involved 989 00:55:57.360 --> 00:56:00.039 with the TNA at the time you signed this agreement in October nine? Yeah? 990 00:56:00.079 --> 00:56:04.440 I actually started the company, okay. Yeah, way before Dixie Carter 991 00:56:04.559 --> 00:56:07.239 got involved. He's the one that actually originally put the money in and started 992 00:56:07.280 --> 00:56:12.280 this company. So when do you think, if you can guess, himate, 993 00:56:12.920 --> 00:56:15.039 I don't want you to guess, but if you can estimate, when 994 00:56:15.199 --> 00:56:17.639 somebody came to you from TNA or somebody from your side approach TNA in two 995 00:56:17.639 --> 00:56:21.440 thousand and nine to get the ball rolling that eventually resulted in this Exhibit eight. 996 00:56:22.119 --> 00:56:23.119 I couldn't yes, could have been. I mean, do you think 997 00:56:23.159 --> 00:56:27.639 it was a week before the document was signed? No, I wouldn't say 998 00:56:27.679 --> 00:56:30.440 a week. Okay. You know, we we could have been talking on 999 00:56:30.599 --> 00:56:32.400 off and on, you know, and anytime I had anything to go on, 1000 00:56:32.559 --> 00:56:37.360 my wife Jeff would call or say hello or ask how I was doing, 1001 00:56:37.719 --> 00:56:39.719 you know, so we could have talked. He could have been brought 1002 00:56:39.800 --> 00:56:44.280 it you know, we could have been brought it up. I don't know 1003 00:56:44.360 --> 00:56:46.800 when we got into hard negotiations, okay, but I mean he could have 1004 00:56:46.840 --> 00:56:50.440 been a month or two. I don't even know. But they were always 1005 00:56:50.440 --> 00:56:52.880 approaching you. Is that right? You didn't seek them out at some point? 1006 00:56:52.000 --> 00:56:53.639 And no, no, no, no, no, They've been asked 1007 00:56:53.679 --> 00:56:58.320 me for years. Okay, who handled the negotiations on your behalf with TNA 1008 00:56:58.440 --> 00:57:00.800 that you know, talked about all the terms. I'm not going to go 1009 00:57:00.840 --> 00:57:05.119 through any of these terms. But was that Eric Bishop and Bishop Hervey Entertainment? 1010 00:57:06.159 --> 00:57:08.000 I wouldn't think so. You would not think so, I would not 1011 00:57:08.119 --> 00:57:10.920 think so. Okay, do you know who it would have been? No, 1012 00:57:12.039 --> 00:57:14.119 there's only two people it could have been. It would either have been 1013 00:57:14.159 --> 00:57:16.320 Scott Hervey or Henry Holmes. I don't know. I don't know. I 1014 00:57:16.360 --> 00:57:20.719 don't remember when I terminated Hervey and Henry started back. But it had to 1015 00:57:20.800 --> 00:57:23.000 be one of those two people, Hervey and the Bishop Hervey Entertainment Television. 1016 00:57:23.039 --> 00:57:29.119 That's Jason Hervey. Is that right? Scott's brother? And Eric? Did 1017 00:57:29.159 --> 00:57:30.639 you get to know him through your time at w W? Yes? And 1018 00:57:30.719 --> 00:57:35.320 are you still well strike that during the period of time that you and Eric 1019 00:57:35.400 --> 00:57:37.400 were in business, signing these contracts and negotiating to go to Australia and things 1020 00:57:37.440 --> 00:57:39.960 like that, were you social friends with him too? Did you consider him 1021 00:57:39.960 --> 00:57:43.599 a friend? Yes? Or was he just a business partner? Oh, 1022 00:57:43.679 --> 00:57:45.519 he's a good friend about today? Are you still friends with him? Yes? 1023 00:57:45.719 --> 00:57:50.039 So there were some ongoing negotiations for some on some level some period of 1024 00:57:50.079 --> 00:57:52.360 time which led to the execution of this December or this October twelfth, two 1025 00:57:52.360 --> 00:57:55.320 thousand nine contract. Is that right? Repeat the question. Yeah, So 1026 00:57:55.360 --> 00:58:00.280 I think we've established that there were some conversation between your reps and the TENA 1027 00:58:00.400 --> 00:58:02.280 reps at some period of time in two thousand and nine which led up to 1028 00:58:02.320 --> 00:58:06.719 the October twelfth, two thousand and nine contract. Yeah, there had been. 1029 00:58:06.960 --> 00:58:08.480 Yeah, but you don't know strike that. You told me, you 1030 00:58:08.559 --> 00:58:12.320 don't know who was talking from your side unless it was Henry or Scott. 1031 00:58:12.400 --> 00:58:15.920 What about from the TNA side? Did you know who was handling the negotiations 1032 00:58:15.960 --> 00:58:20.119 over your contract on behalf of TNA? Yeah, they had an entertainment I 1033 00:58:20.159 --> 00:58:22.920 don't know if he was an entertainment attorney. I don't know what he was 1034 00:58:22.119 --> 00:58:25.119 there. Attorney name was Godlake. Okay, and where is he? C 1035 00:58:25.199 --> 00:58:29.400 n LA. He's in Malibu, California. Okay. Did you ever sit 1036 00:58:29.480 --> 00:58:32.039 and take phone calls on the radio for Bubba the love spun just like a 1037 00:58:32.119 --> 00:58:36.199 guest DJ or something like that, I remember, I don't know if it 1038 00:58:36.320 --> 00:58:37.760 was if it was at night. I don't know if it was a night 1039 00:58:37.840 --> 00:58:43.119 or during the day. He had a radio show, either during the day 1040 00:58:43.199 --> 00:58:45.519 or the night I sat in. I want to read you a portion of 1041 00:58:45.599 --> 00:58:47.039 one of those calls that's out there, and I think it's on YouTube where 1042 00:58:47.039 --> 00:58:50.559 you take a call from a fellow named at Lance in Boston and he asked 1043 00:58:50.599 --> 00:58:52.840 you how did you end up being with TNA? And you answered to him 1044 00:58:52.840 --> 00:58:54.000 and I'll Abreevie, you can find this, you said. You know, 1045 00:58:54.519 --> 00:58:58.199 it was the end of the year last year, and Vince was saying, 1046 00:58:58.239 --> 00:59:00.639 maybe you could come make a Monday night Ront Square Garden right up before you 1047 00:59:00.679 --> 00:59:02.960 go to Australia. And so at the time, I was talking to Dixie 1048 00:59:04.039 --> 00:59:06.679 Carter, you know, once every couple of days, thinking about going there. 1049 00:59:06.719 --> 00:59:08.280 And I'd been looking at TNA for three or four years thinking of going 1050 00:59:08.320 --> 00:59:10.400 there. But then all of a sudden, the more I watched it, 1051 00:59:10.480 --> 00:59:13.559 you know, the more I watched TNA, and the more Bubba got me 1052 00:59:13.599 --> 00:59:15.960 into it and started stirring it to a fever. Pitcher's head man, you 1053 00:59:15.039 --> 00:59:19.519 know what, I know the story at WW no disrespect. I know where 1054 00:59:19.519 --> 00:59:21.639 I'll end up. I know they'll make me the bab ruth of wrestling. 1055 00:59:21.679 --> 00:59:23.239 I'll do the whole merchandising deal and that will be great and I'll ride off 1056 00:59:23.280 --> 00:59:27.480 into the sunset and there's no disrespect in that. But then when I looked 1057 00:59:27.480 --> 00:59:30.320 over to TNA, I saw a whole bunch of energy there. I saw 1058 00:59:30.320 --> 00:59:32.880 a young, upstart company, brother and all kind of talent. And after 1059 00:59:34.079 --> 00:59:36.840 what I've been through, after the last couple of years, brother, not 1060 00:59:36.960 --> 00:59:38.760 only do I need to start my life over, this was like life after 1061 00:59:38.880 --> 00:59:43.360 life in the wrestling business. This was a chance for me to keep staying 1062 00:59:43.400 --> 00:59:46.239 in the business without being disrespected, to stay in this business and really participate 1063 00:59:46.320 --> 00:59:50.559 and basically have this whole other life in the wrestling business. And it's a 1064 00:59:50.639 --> 00:59:52.320 new life. It's not just fading into the sunset. I mean, I'm 1065 00:59:52.320 --> 00:59:55.480 really involved. I saw a chance to get over there and really get involved. 1066 00:59:55.519 --> 00:59:59.400 And Eric Bischoff made me realize how big of a monster vinces. You 1067 00:59:59.480 --> 01:00:00.960 know, They've got a show on Monday, which is called Raw, and 1068 01:00:01.039 --> 01:00:04.880 then Tuesdays are off, and then Wednesday, Thursday, Friday, Saturday, 1069 01:00:04.920 --> 01:00:07.360 Sunday, even on the Spanish stations, all these other shows point to the 1070 01:00:07.639 --> 01:00:12.719 main mothership, Monday Night Raw. And I was going, man, wwwwe 1071 01:00:13.079 --> 01:00:15.039 is such a big monster. Tena has so much energy into such a young 1072 01:00:15.079 --> 01:00:19.320 company. We've got to keep fighting the monster. And Eric just made me 1073 01:00:19.360 --> 01:00:22.360 calm down a bit because Randy Orton started in twenty eleven in the WWE the 1074 01:00:22.440 --> 01:00:27.679 same time Eric did, and right now Randy is in his prime nine years 1075 01:00:27.800 --> 01:00:30.119 later and TNA has only been around about salt and a half years. Brother, 1076 01:00:30.480 --> 01:00:32.880 If you put that in perspective, this is where the future is. 1077 01:00:32.960 --> 01:00:36.039 I mean, we have a show on right now. We are, as 1078 01:00:36.119 --> 01:00:38.440 we are talking called ten a Reaction. It's like a real inside edgy, 1079 01:00:38.519 --> 01:00:43.000 look real grainy, look at what really goes on back there. So I 1080 01:00:43.119 --> 01:00:45.039 think this is what the future is more wrestling, you know, a young 1081 01:00:45.119 --> 01:00:47.559 company. There are a bunch of guys that I don't have to deal with 1082 01:00:47.679 --> 01:00:51.440 the Hulk Cogans, I don't have to deal with the Goldbergs, no disrespect 1083 01:00:51.480 --> 01:00:53.079 intended. I don't have to deal with the Rock, no disrespect intended. 1084 01:00:53.320 --> 01:00:57.239 These guys are there to work. They don't care how big their contracts are. 1085 01:00:57.599 --> 01:01:00.800 These guys are laying it all on the line because they know when the 1086 01:01:00.840 --> 01:01:02.960 company grows, I'm going to treat people and Dixie Carter is going to treat 1087 01:01:04.000 --> 01:01:07.559 people different than anybody else as this company grows. If you guys are on 1088 01:01:07.639 --> 01:01:10.159 team Hogan and on team TNA, we are going to make sure all the 1089 01:01:10.199 --> 01:01:14.760 boats float. Brother, That's why I went there, and that's why you 1090 01:01:14.800 --> 01:01:15.840 went to TNA in two thousand and nine, because you wanted to go with 1091 01:01:15.960 --> 01:01:19.280 that company and you didn't want to go with WW. Isn't that true what 1092 01:01:19.320 --> 01:01:22.760 you said in the radio? No, sir, okay, explain to me 1093 01:01:22.840 --> 01:01:27.199 why what I just read, which is a recording of you on the radio, 1094 01:01:27.440 --> 01:01:35.159 is not accurate? Exactly well exactly exactly what not accurate? Why is 1095 01:01:35.199 --> 01:01:37.119 it not accurate? As working at TNA, I was on Bubba's show. 1096 01:01:37.480 --> 01:01:40.760 Now I'm putting Bubba over, I'm putting TNA over. It was a very 1097 01:01:40.880 --> 01:01:45.079 small local wrestling company. It wasn't a big national stage. I'm on TNA's 1098 01:01:45.119 --> 01:01:49.679 team. This is entertainment. It's not a It's not factual at all. 1099 01:01:49.760 --> 01:01:52.119 It's a radio show, which is entertainment. YEA, much like the you 1100 01:01:52.199 --> 01:01:55.199 know the internet that you read that you're reading and get a lot of your 1101 01:01:55.239 --> 01:01:59.320 information from. It's not factual. It's just a radio show. You all 1102 01:01:59.360 --> 01:02:02.400 say anything make TNA, Bubba or anybody look good. That I'm working with 1103 01:02:02.519 --> 01:02:07.719 on the show. It could have been the Louise Hay Show, you know, 1104 01:02:07.199 --> 01:02:12.440 and I could have said that the greatest commentator of all time and TENA 1105 01:02:12.559 --> 01:02:15.039 is going to be bigger than WWE. So at the time, I had 1106 01:02:15.079 --> 01:02:16.400 to do what I had to do to entertain the situation I was in, 1107 01:02:16.800 --> 01:02:20.920 which was I was working in TNA. I'm not going to sit there instead 1108 01:02:20.920 --> 01:02:23.960 of the WWE is so big and it's such a monster we could never overcome. 1109 01:02:24.320 --> 01:02:27.840 So you just have to take it into justice. Entertainment, it's not 1110 01:02:28.039 --> 01:02:31.360 factual. Do you doubt what I read was accurate. I'm happy to play 1111 01:02:31.360 --> 01:02:35.960 the clip for you if you think I've taken anything out of context or I'm 1112 01:02:36.039 --> 01:02:39.840 sure you can read brother. I agree. I think you can probably read 1113 01:02:39.920 --> 01:02:44.079 everything accurately. I'm just trying to explain to you that if it's on the 1114 01:02:44.239 --> 01:02:47.119 radio, if it's the TV, if it's the newspaper, internet, telephone, 1115 01:02:47.159 --> 01:02:51.800 telegraph, tele wrestler, it's not factual, brother, So nothing that 1116 01:02:51.920 --> 01:02:55.679 you did in those reality shows was factual. It's all lightly scripted, was 1117 01:02:55.760 --> 01:03:00.840 produced. Do you want your fans to know that they know it? They 1118 01:03:00.880 --> 01:03:04.639 do? Yeah, anybody that's got a half a brain knows that. But 1119 01:03:04.800 --> 01:03:07.239 they know it's entertainment. We tell them. We tell them as an exhibition, 1120 01:03:07.280 --> 01:03:10.239 it's entertainment. You know, Vince McMahon just got killed in the limousine. 1121 01:03:10.280 --> 01:03:13.840 We blew the car up and he died. Oh this is a little 1122 01:03:13.920 --> 01:03:15.679 different. This is radio. I mean, this wasn't a wrestling match. 1123 01:03:15.760 --> 01:03:19.079 This was a phone call from a fan of yours who wanted to know why 1124 01:03:19.119 --> 01:03:21.239 you were with TNA. Why don't you just tell him, Hey, my 1125 01:03:21.320 --> 01:03:23.760 back's messed up. I missed out on my window of opportunity with WW so 1126 01:03:23.840 --> 01:03:27.320 I'm going with TNA. Why didn't you just tell him that? Because you 1127 01:03:27.400 --> 01:03:30.960 say the high road and you entertain the people. That's what this business is 1128 01:03:30.960 --> 01:03:34.440 all about. It's entertaining. So at this time in October November timeframe of 1129 01:03:34.480 --> 01:03:37.320 two thousand and nine, when you've had you've had three surgeries by that point 1130 01:03:37.360 --> 01:03:43.000 in time with the folks at LSI correct. Wait, if you could show 1131 01:03:43.039 --> 01:03:45.800 me a timeline, I can be accurate, but you're probably right, assuming 1132 01:03:45.840 --> 01:03:47.760 that I'm right. At this time, you were negotiating a one million dollar 1133 01:03:47.920 --> 01:03:52.840 contract with TNA, and you were negotiating with the Condon Sports and entertainment group 1134 01:03:52.880 --> 01:03:57.800 for an Australian wrestling tour. Isn't that right? Assuming you're correct? Yes? 1135 01:03:58.639 --> 01:04:00.000 Okay? And how much were you supposed to be paid? I know 1136 01:04:00.079 --> 01:04:02.719 you've told me you were only paid half. How much were you supposed to 1137 01:04:02.760 --> 01:04:05.760 be paid for the wrestling tour in Australia? You know, I don't recall. 1138 01:04:06.039 --> 01:04:09.360 I know I only got half the money, whatever the amount was. 1139 01:04:09.480 --> 01:04:13.039 In fact, you probably saw in this agreement with TNA that your representatives actually 1140 01:04:13.440 --> 01:04:16.639 told TNA that you had entered into a tour agreement with Condon Sports and Entertainment, 1141 01:04:16.719 --> 01:04:20.800 and TNA basically said they granted you permission to fulfill that contract. Do 1142 01:04:20.880 --> 01:04:25.039 you remember that or do you remember reading that at page four? I think 1143 01:04:25.039 --> 01:04:27.000 I went along with it. You know, it was something that was in 1144 01:04:27.039 --> 01:04:30.039 the works before this was finalized, okay, And I you know all and 1145 01:04:30.159 --> 01:04:33.440 I know that they wanted to participate in Australia. If the tour had been 1146 01:04:33.559 --> 01:04:36.199 six would have been successful, all right. And so under Exhibit eight, 1147 01:04:36.280 --> 01:04:40.440 the contract with TNA, the miniment was going to pay you was one million 1148 01:04:40.559 --> 01:04:44.079 dollars. Do you see that at a compensation on page six? Yes? 1149 01:04:44.239 --> 01:04:47.920 And you were guaranteed a minimum of five hundred thousand dollars for talent appearances for 1150 01:04:48.039 --> 01:04:54.400 thirty three appearances, and then an additional fifteen thousand dollars for each appearance above 1151 01:04:54.480 --> 01:04:57.599 thirty three. Do you see that in the same paragraph. Yes, And 1152 01:04:57.719 --> 01:05:00.440 this is money you made in spite of the treatment, as you contend that 1153 01:05:00.599 --> 01:05:03.280 LSI. In other words, you were able to realize that amount of money, 1154 01:05:03.360 --> 01:05:08.400 that compensation, even while you were undergoing treatment at LSI. Isn't that 1155 01:05:08.480 --> 01:05:14.440 correct? Whoh oh, yeah, well, yeah, I stayed Indictionity Carter 1156 01:05:14.599 --> 01:05:16.159 was above gracious. You know, she paid me even when I was sitting 1157 01:05:16.159 --> 01:05:20.400 at home recovering. All right. There was a mention in this Condon Sports 1158 01:05:20.400 --> 01:05:26.199 agreement that there were two additional tours which were contemplated after the two thousand and 1159 01:05:26.280 --> 01:05:29.599 nine tour. I take it from what we've talked about, those tours never 1160 01:05:29.719 --> 01:05:33.079 happened. No, it was a nightmare. Okay, Now there was no 1161 01:05:33.199 --> 01:05:35.920 reason to go back over there. So, mister Boult, if I were 1162 01:05:35.960 --> 01:05:40.760 to play for you some footage from Brooks Show where you're on the video saying 1163 01:05:40.800 --> 01:05:43.480 I was supposed to be the main event next April with John Cena, but 1164 01:05:43.519 --> 01:05:46.719 I backed up because me and Eric have this deal going. You're saying, 1165 01:05:46.800 --> 01:05:50.800 if you said that it's just for entertainment purposes, it's not accurate. Well, 1166 01:05:50.840 --> 01:05:55.760 it's a high probability it's scripted for entertainment purposes. You know, we're 1167 01:05:55.760 --> 01:06:00.400 moving the storyline along for whatever was being contrived at the time. High highly 1168 01:06:00.440 --> 01:06:02.519 possible. If you did say something about a deal with Eric going, do 1169 01:06:02.679 --> 01:06:08.760 you know what deal you would have been referring to? Excuse me, did 1170 01:06:08.880 --> 01:06:14.360 you have a deal going with Eric Bischoff in two thousand and nine or Bishop 1171 01:06:14.440 --> 01:06:17.159 Hervey Entertainment? I mean you did, didn't you. We've been We're looking 1172 01:06:17.159 --> 01:06:19.480 at this contract with TNA. That's an Eric Bischoff deal, isn't it. 1173 01:06:19.920 --> 01:06:25.599 Well, yeah, and we also did a micro championship wrestling deal which was 1174 01:06:25.679 --> 01:06:29.880 mentioned in this TNA. That was Bishop Hervey. We also did a celebrity 1175 01:06:29.960 --> 01:06:32.840 championship wrestling deal which was part of the Bishop Bishoff Hervey deal. So there's 1176 01:06:32.840 --> 01:06:36.960 several ones. And the Australian Conden deal, Yeah, that was that was 1177 01:06:38.159 --> 01:06:41.320 one. Also. All right, we've got to take a break. He's 1178 01:06:41.360 --> 01:06:44.039 got to change tape. The time is four fifty eight. We're off the 1179 01:06:44.079 --> 01:06:48.320 record. Day one concluded at four fifty eight pm. We've decided to break 1180 01:06:48.360 --> 01:06:51.119 for the day and we'll reconvene. What time do you all want to get 1181 01:06:51.159 --> 01:06:56.280 back together tomorrow? After discussion, it was agreed among all parties present that 1182 01:06:56.320 --> 01:07:00.159 the video tape deposition will resume tomorrow, Thursday, July thirty first, two 1183 01:07:00.159 --> 01:07:02.519 thousand and fourteen, at nine thirty am.