Jolie Cross
Jolie Cross
Jolie Cross
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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
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
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.
5 The Cross-Complaint, and the sole cause of action therein, fails to state a claim
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.
15 The Cross-Complaint, and the sole cause of action therein, is not a proper matter
19 The Cross-Complaint, and the sole cause of action therein, is not a proper matter
22 (Unclean Hands)
23 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in
26 (Unjust Enrichment)
27 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in
2 (Estoppel)
3 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or
6 (Laches)
7 The Cross-Complaint, and the sole cause of action therein, is barred, in whole or in
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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:
9 2. For Pitt and Mondo Bongo’s costs of suit incurred herein, including reasonable
11 3. For such other and further relief as the Court may deem just and proper.
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PITT AND MONDO BONGO’S ANSWER TO JOLIE’S CROSS-COMPLAINT