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Jolie Cross

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1 WACHTELL, LIPTON, ROSEN & KATZ

Jonathan M. Moses (admitted pro hac vice)


2 Adam L. Goodman (admitted pro hac vice)
3 Remy Grosbard (admitted pro hac vice)
Jessica L. Allen (admitted pro hac vice)
4 51 West 52nd Street
New York, NY 10019
5 Telephone: (212) 403-1000
Facsimile: (212) 403-2000
6

7 KENDALL BRILL & KELLY LLP


Laura W. Brill (195889)
8 lbrill@kbkfirm.com
Katelyn A. Kuwata (319370)
9 kkuwata@kbkfirm.com
10 10100 Santa Monica Blvd., Suite 1725
Los Angeles, CA 90067
11 Telephone: (310) 556-2700
Facsimile: (310) 556-2705
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Attorneys for Plaintiffs and Cross-Defendants
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William B. Pitt and Mondo Bongo, LLC
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
15 COUNTY OF LOS ANGELES, CENTRAL DISTRICT

16 WILLIAM B. PITT, an individual, and Case No. 22STCV06081


MONDO BONGO, LLC, a California
17 limited liability company, PLAINTIFFS AND CROSS-
18 DEFENDANTS WILLIAM B. PITT AND
Plaintiffs, MONDO BONGO, LLC’S ANSWER AND
19 AFFIRMATIVE DEFENSES TO
v.
DEFENDANT AND CROSS-
20 ANGELINA JOLIE, an individual, COMPLAINANT ANGELINA JOLIE’S
NOUVEL, LLC, a California limited liability CROSS-COMPLAINT
21
company, YURI SHEFLER, an individual,
22 ALEXEY OLIYNIK, an individual, SPI
GROUP HOLDING LIMITED, a Cyprus Judge: Hon. Lia Martin
23 private limited company, TENUTE DEL Dept: 16
MONDO, B.V., a Netherlands private
24 Cross-Complaint Filed: October 4, 2022
limited company, and ROES 1-10,
Trial Date: Not yet set
25 Defendants.
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27 and RELATED CROSS-ACTIONS.

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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT


1 Plaintiffs and Cross-Defendants WILLIAM B. PITT and MONDO BONGO, LLC hereby

2 answer the unverified Cross-Complaint filed by Defendant and Cross-Complainant ANGELINA

3 JOLIE as follows:

4 GENERAL DENIAL

5 1. Pursuant to § 431.30(d) of the California Code of Civil Procedure, Pitt and Mondo

6 Bongo both deny, generally and specifically, each and every allegation set forth in Jolie’s Cross-

7 Complaint, and further deny that Jolie is entitled to any relief whatsoever.

8 2. The only thing that Jolie’s Cross-Complaint gets right is that she and Pitt

9 purchased Château Miraval as a “loving home for their six children.” As set forth in Plaintiffs’

10 Second Amended Complaint, Pitt and Jolie had a mutual and binding commitment, reflected by

11 their conduct and statements to one another over time, that they would hold Miraval together and,

12 if the time came, that they would sell their interests separately only with the other’s consent. As

13 Jolie said to Pitt referencing Miraval, “I agree it all has to go if it goes.” Consistent with that

14 agreement, the California LLCs through which Pitt and Jolie respectively owned their interests in

15 Miraval—Mondo Bongo and Nouvel—were parties to a written contract that provided each entity

16 with a right of first refusal over any sale of their interests in Miraval.

17 3. In reliance on these commitments, Pitt devoted his time and his resources to

18 renovating the Miraval estate and building a highly successful wine business. Jolie, though

19 supportive of Pitt’s efforts on behalf of the family, did none of the work necessary for Miraval’s

20 success. Instead, she allowed Pitt to pour money and sweat equity into the business in reliance on

21 her promise to hold Miraval together, as well as the contractual rights her holding company

22 Nouvel owed his. By the time of their separation, Pitt’s investment exceeded Jolie’s by nearly

23 $50 million.

24 4. When the couple decided to divorce, Jolie initially recognized the restrictions on

25 her ability to sell her stake in Miraval. Thus, she sought to reach an agreement with Pitt as to the

26 terms of a buyout. Jolie promised Pitt that she would “leave with what I put in and nothing

27 additional.” Jolie recognized this meant that—despite their nominal 50-50 interest in Miraval—a

28 68-32 allocation of proceeds between Pitt and herself would be fair. In recognition of the
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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT
1 contractual rights she and Nouvel owed Pitt and Mondo Bongo, and the promises she made Pitt

2 even after their separation, Jolie acknowledged that there were only “two ways forward.” Pitt and

3 Jolie could sell Miraval jointly, or Pitt could buy her out.

4 5. But in the summer of 2021, amid a heated child custody dispute with Pitt, Jolie

5 terminated buy–out discussions with Pitt and secretly purported to sell a 50% stake in the family

6 home and family business to the Russia-affiliated spirits conglomerate Stoli Group, which is

7 owned and controlled by billionaire Yuri Shefler. Shefler, who has been designated as an

8 “oligarch in the Russian Federation” by the U.S. Treasury Department, had previously sought to

9 buy Miraval, and Pitt had turned him down.

10 6. Pitt learned of Jolie’s putative sale to Stoli by way of a press release announcing

11 that Stoli was “thrilled to have a position alongside Brad Pitt as curators” of Miraval rosé. That

12 was by design: Jolie collaborated in secret with Shefler and his associates to pursue and then

13 consummate the purported sale, ensuring that Pitt would be kept in the dark as Stoli and Jolie

14 knowingly violated Pitt’s and Mondo Bongo’s contractual rights and forced a stranger into Pitt’s

15 family home.

16 7. Jolie now makes excuses about her decision to break off discussions with Pitt and

17 pursue this secret putative sale to Shefler and Stoli. Jolie’s excuses will not be borne out. Her

18 decision to terminate negotiations with Pitt was intentional and pretextual. As will be

19 demonstrated at trial, Jolie’s actions were unlawful, severely and intentionally damaging Pitt and

20 unjustly enriching herself.

21 AFFIRMATIVE DEFENSES

22 Pitt and Mondo Bongo further plead the following separate and additional

23 defenses. In pleading these defenses, Pitt and Mondo Bongo do not in any way agree or concede

24 that they have the burden of proof or of persuasion as to any of them. Additionally, Pitt and

25 Mondo Bongo have not completed their investigation and discovery of all the facts and

26 circumstances surrounding the subject matter of the Cross-Complaint. Accordingly, Pitt and

27 Mondo Bongo reserve the right to amend, modify and plead such further affirmative defenses and

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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT
1 take such other actions as necessary and proper for their defense upon completion of their

2 investigation.

3 FIRST AFFIRMATIVE DEFENSE

4 (Failure to State a Claim Upon Which Relief May be Granted)

5 The Cross-Complaint, and the sole cause of action therein, fails to state a claim

6 upon which relief can be granted.

7 SECOND AFFIRMATIVE DEFENSE

8 (Breach)

9 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in

10 part, because Jolie breached her implied-in-fact contract with Pitt and breached, in her capacity as

11 the alter ego of Nouvel, the implied covenant of good faith and fair dealing in the Quimicum

12 Articles.

13 THIRD AFFIRMATIVE DEFENSE

14 (Declaratory Relief Improper)

15 The Cross-Complaint, and the sole cause of action therein, is not a proper matter

16 for declaratory relief.

17 FOURTH AFFIRMATIVE DEFENSE

18 (Injunctive Relief Improper)

19 The Cross-Complaint, and the sole cause of action therein, is not a proper matter

20 for injunctive relief.

21 FIFTH AFFIRMATIVE DEFENSE

22 (Unclean Hands)

23 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in

24 part, by the doctrine of unclean hands.

25 SIXTH AFFIRMATIVE DEFENSE

26 (Unjust Enrichment)

27 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in

28 part, based on principles of unjust enrichment.


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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT
1 SEVENTH AFFIRMATIVE DEFENSE

2 (Estoppel)

3 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or

4 in part, based on principles of estoppel.

5 EIGHTH AFFIRMATIVE DEFENSE

6 (Laches)

7 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in

8 part, by the doctrine of laches.

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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT
1 PRAYER FOR RELIEF

2 WHEREFORE, Pitt and Mondo Bongo pray for judgment in their favor and against Jolie

3 as follows:

4 1. For the Court to declare that:

5 a. Jolie is awarded no relief on the Cross-Complaint;

6 b. Jolie’s Cross-Complaint shall be dismissed with prejudice; and

7 c. Judgment on the Cross-Complaint shall be entered in favor of Pitt and

8 Mondo Bongo and against Jolie.

9 2. For Pitt and Mondo Bongo’s costs of suit incurred herein, including reasonable

10 attorneys’ fees, as permitted by law; and

11 3. For such other and further relief as the Court may deem just and proper.

12

13 DATED: June 1, 2023 KENDALL BRILL & KELLY LLP


Laura W. Brill
14

15 By: /s/ Laura W. Brill


Laura W. Brill
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17 WACHTELL, LIPTON, ROSEN & KATZ


Jonathan M. Moses (admitted pro hac vice)
18 Adam L. Goodman (admitted pro hac vice)
Remy Grosbard (admitted pro hac vice)
19 Jessica L. Allen (admitted pro hac vice)
51 West 52nd Street
20 New York, NY 10019
Telephone: (212) 403-1000
21 Facsimile: (212) 403-2000
22 Attorneys for Plaintiffs and Cross-Defendants
William B. Pitt and Mondo Bongo, LLC
23

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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT

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