CM-110

ATTORNEY OR PARTY W ITHOUT ATTORNEY (Name, Stale Bar number, and address) :
FOR COURT USE ONLY
Laura W . Brill (195889)
KENDALL BRILL & KELLY LLP
10100 Santa Monica Blvd ., Suite 1725
Los Angeles, CA 90067

TELEPHONE NO.: (310) 556-2700 FAX NO (Op6onal): (310) 556-2705

E-MAIL ADDRESS : lbrill@kbkfirm .com
ATTORNEY FOR (Name) . William B. Pitt; Mondo Bongo, LLC; Warren Grant
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STREET ADDRESS: 111 N. Hill St.
MAILI NG ADDRESS: 111 N. Hill St.
CITY AND ZIP CODE: Los Angeles; 90012

BRANCH NAM E: Stanley Mosk

PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC

DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yuri Shefler; Alexey Oliynik et al.

CASE MANAGEMENT STATEMENT CASE NUMBER:

(Check one): II] UNLIMITED CASE 0 LIMITED CASE 22STCV06081

(Amount demanded (Amount demanded is $25,000
exceeds $25 ,000) or less)

A CASE MANAGEMENT CONFERENCE is scheduled as follows :

Date: August 2, 2023 Time : 9 :00 a .m. Dept.: 16 Div.: Room:
Address of court (if different from the address above):

[KJ Notice of Intent to Appear by Telephone, by (name): Jonathan M. Moses, Wachtel! Lipton Rosen & Katz
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. D This statement is submitted by party (name) :
b. II] This statement is submitted jointly by parties (names) : W.B. Pitt & Mondo Bongo (Plaintiffs); W . Grant (Cross-Defendant)
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date) : Com . 2/17/22 , FAC 6/3/22 , SAC 6/21/23
b. [KJ The cross-complaint, if any, was filed on (date) : Jolie : 10/4/22; Nouvel: 9/6/22 , 7/10/23
3 . Service (to be answered by plaintiffs and cross-complainants only)
a. [KJ All parties named in the complaint 1u~s o~ooo 001t1,ileiF1& have been served, have appeared , or have been dismissed.
b. D The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):

(2) D have been served but have not appeared and have not been dismissed (specify names) :

(3) D have had a default entered against them (specify names) :

c. II] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served}:
Plaintiffs have named Roes 1-10 in their SAC . Plaintiffs reserve the right to identify these defendants, once ascertained ,
to the extent permitted under California law, and with leave of Court to the extent requ ired.

4. Description of case
a. Type of case in [KJ complaint D
cross-complaint (Describe, including causes of action):
Plaintiffs bring claims sounding in breach of contract and tortious interference ("Tl") arising out of the unlawful sale of Nouvel.
Claims: (1, 2 , 3, 4) Breach of Implied-In-Fact Contract, Quasi-Contract, and Implied Covenant; (5) Abuse of Rights under
Luxembourgish law; (6 & 7) Tl with Contractual Relations ; (8) Tl with Prospective Bus . Relations; and (9) Constructive Trust.
Page 1 of 5

Form Adopted for Mandatory Use Ca l. Rules of Court,

Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3 .720-3 .730
CM-1 10 [Rev. September 1, 2021 ] www.courls.ca.gov
 CM-110
PLAINTIFF/PETITIONER: William B. Prtt; Mondo Bongo, LLC CASE NUMBER:

DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yuri SheHer; Alexey Oliynik et al. 22STCV06081

4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [in dicate source and amount], estimated future medical expenses, lost
earnings to date. and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs limit this description to their claims. Jolie and Nouvel were obligated not to sell interest in a private family home and
wine business without Plaintiffs' consent. They nevertheless did by so, secretly, through a purported sale to Tenute del Mondo,
an entity controlled by Russian oligarch Yuri Shetler. Defendants have since attempted a hostile takeover of the business.
Plaintiffs seek specific performance unwinding the sale, a constructive trust, and other appropriate equ itable relief or damages.
D (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request w
a jury trial D
a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Pitt, Mondo Bongo, and Grant each request a jury trial.

6. Trial date
a. D The trial has been set for (date):
b. [Kl No trial date has been set. This case will be ready for trial withi n 12 months of the date of the filing of the complaint (if
not, explain):
This case involves numerous parties challenging personal jurisdiction and will involve complex discovery.

c . Dates on which parties or attorneys will not be available for trial (spe cify dates and explain reasons for unavailability):
October 2 - 4, 2024 (Religious Holiday); October 11 , 2024 (Religious Holiday); October 16 - 25, 2024 (Religious Holiday); April
14 -April 21 , 2025 (Religious Holiday); June 2 - 3, 2025 (Religious Holiday)

7. Estimated length of trial

The party or parties estimate that the trial will take (check one):
a. W days (spedfy number): 10 trial days
b. D hours (short causes) (specify) :

8 . Trial representation (to be answered for each party)

The party or parties will be represented at trial CK] by the attorney or party listed in the caption CK] by the following:
a. Attorney: Jonathan Moses; Adam Goodman
b. Firm: Wachtel! , Lipton, Rosen & Katz
c. Address: 51 West 52nd . St.
d . Telephone number: (212) 403-1000 f. Fax number: (212) 403-2000
e. E-mail address: JMMoses@wlrk.com; ALGoodman@wlrk.com g. Party represented : Pitt, Mondo Bongo; Grant
D Additional representation is described in Attachment 8.
9. Preference
D This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a . ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel CK] has D has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party D has D has not reviewed the ADR information package identified in rule 3.221 .
b. Referral to judicial arbitration or civil action mediation (if available).
(1) D
This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141 .1 1 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) D Plaintiff elects to refer this case to judicial arbitration and agrees to li mit recovery to the amount specified in Code of
Civil Procedure section 1141 .11.
(3) CK] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
California Rule of Court 3.811(b)(1 ); California Code of Civil Procedure§ 1775.5
CM- 110 [Rev. September 1, 2021) Page 2 of 5
CASE MANAGEMENT STATEMENT
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yu ri Shetler; Alexey Oliynik et al. 22STCV06081

10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):

The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):

D Mediation session not yet scheduled

D Mediation session scheduled for (date):
(1) Mediation [KJ
D Agreed to complete mediation by (date ):
D Mediation completed on (date ):

D Settlement conference not yet scheduled

(2) Settlement D Settlement conference scheduled for(date):

conference D D Agreed to complete settlement conference by (date):
D Settlement conference completed on (date):

D Neutral evaluation not yet scheduled

D Neutral evaluation scheduled for (date ):
(3) Neutral evaluation D D Agreed to complete neutral evaluation by (dale ):
D Neutral evaluation completed on (date ):

D Judicial arbitration not yet scheduled

(4) Nonbinding judicial D D Judicial arbitration scheduled fo r (date ):
arbitration D Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed on (date ):

D Private arbitration not yet scheduled

(5) Binding private D D Private arbitration scheduled for (date ):
arbitration D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date ):

D ADR session not yet scheduled

(6) Other (specify):

D ADR session scheduled for (date):
D D Agreed to complete ADR session by (date):
D ADR completed on (date ):

CM- 110 [Rev. September 1, 2021) Page 3 of 5

CASE MANAGEMENT STATEMENT
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yuri Shetler; Alexey Oliynik et al. 22STCV06081

11 . Insurance
a. D Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D Coverage issues will significantly affect resolution of this case (explain):

12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
D BankruptcyIT] Other (specify) : Parties are moving to quash on jurisdictional and service-related grounds.
Status: Some of Defs' and Cross-Defs' motions to quash were mooted by filing of amended complaints; parties intend to re-file.

13. Related cases, consolidation, and coordination

a. D There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
IT] Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name patty):

14. Bifurcation
D The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):

15. Other motions

[RJ The party or parties expect to file the following motions before trial (specify moving patty, type of motion, and issues):
Plaintiffs and Grant intend to file a demurrer to Nouvel's Cross-Complaint, and, as needed, move for summary judgment.
Plaintiffs and Grant also contemplate filing motions to compel and motions in limine, as needed.

16. Discovery
a. D The party or parties have completed all discovery.
b. [KJ The following discovery will be completed by the date specified (describe all anticipated discovery):

.E.fil\Y Descri lion

Plaintiffs Discovery relating to personal jurisdiction
Plaintiffs Document Discovery (not relating to personal jurisdiction) Per Code
Plaintiffs Depositions (not relating to personal jurisdiction) Per Code
Plaintiffs Expert Discovery Per Code

c. [RJ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Plaintiffs are seeking jurisdictional discovery from the Defendants challenging jurisdiction. While those Defendants have made
a limited document production to date, the production is deficient. If Defendants do not remedy those deficiencies, Plaintiffs
intend to seek relief. Plaintiffs also have filed motions to compel jurisdictional depositions. Plaintiffs also anticipate filing
motions to compel discovery from Jolie and Nouvel.

CM-110 [Rev. September 1, 2021) Page4 of 5

CASE MANAGEMENT STATEMENT
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yuri Shetler; Alexey Oliynik et al. 22STCV06081

17. Economic litigation

a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):

18. Other issues

W The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):

Given the number of parties, anticipated motions to compel and other pre-trial motions. jurisdictional issues, claims,
crossclaims, and matters of foreign law, Plaintiffs would like to raise whether this case should be designated as complex.

19. Meet and confer

a. W The party or parties have met and conferred with all parties on all subjects required by rule 3. 724 of the California Rules
of Court (if not, explain):
The parties met and conferred, except for the new cross-defendants that Nouvel just sued and that have not been served
as of the date of this filing.

b. D After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):

20. Total number of pages attached (if any): _1_ _ _ __

I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.

Date: July 18, 2023

/s/ Laura W. Brill

Laura W. Brill
(TYPE OR PRINT NAME) • (SIGNATURE OF PARTY OR ATTORNEY)

(TYPE OR PRINT NAME) • (SIGNATURE OF PARTY OR ATTORNEY)

D Additional signatures are attached.

CM-110(Rev. September 1, 2021) Page Sol 5

CASE MANAGEMENT STATEMENT
 MC-025
CASE NUMBER:
SHORT TITLE:
- Related Cases 22STCV06081

ATTACHMENT (Number) : - 13a

------
(This Attachment may be used with any Judicial Council form.)

The following actions are pending abroad where there are both overlapping parties to this litigation and related
matters being litigated:

In Luxembourg, four related actions are pending between plaintiff and cross-defendant Mondo Bongo and
defendant and cross-complainant Nouvel: (1) an action filed by Mondo Bongo against Nouvel on September
21, 2021, case no. TAL-2021-08991; (2) an action filed by Mondo Bongo against Nouvel on November 22,
2021, case no. CAL-2022-00252; (3) an action filed by Nouvel against Mondo Bongo on June 28, 2022, case
no. TAL-2022-06390; and (4) an action filed by Nouvel against Mondo Bongo on February 14, 2023, case no.
TAL-2023-01395.

In France, there are three related pending actions brought by Nouvel: (1) a proceeding filed by Nouvel in
February 2022 to obtain pre-suit discovery from Chateau Miraval under Article 145 of the French Code of
Civil Procedure; (2) a proceeding filed by Nouvel in February 2022 to obtain pre-suit discovery from
cross-defendant Miraval Provence under Article 145 of the French Code of Civil Procedure; and (3) per
Nouvel's First Amended Cross-Complaint(~ 210) and correspondence from Nouvel's counsel, Nouvel filed a
criminal complaint against cross-defendants Gary Bradbury and Roland Venturini on September 4, 2022.

(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 1 of 1
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use
Judicial Council of California
ATTACHMENT www.courtinfo.ca.gov

MC-025 [Rev. July 1, 2009] to Judicial Council Form

 1 PROOF OF SERVICE

2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

3 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Los Angeles, State of California. My business address is 10100 Santa
4 Monica Blvd., Suite 1725, Los Angeles, CA 90067.

5 On July 18, 2023, I served true copies of the following document(s) described as

6 1. CASE MANAGEMENT STATEMENT on the interested parties in this action

as follows:
7

8 SEE ATTACHED SERVICE LIST

9 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s) to be

sent to each interested party at the email addresses listed above or on the attached service list.
10
I declare under penalty of perjury under the laws of the State of California that the
11 foregoing is true and correct.

12
Executed on July 18, 2023, at Los Angeles, California.
13

14
/s/ Carla K. Rossi
15 Carla K. Rossi
16

17

18

19

20

21

22

23

24

25

26

27

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PROOF OF SERVICE
 SERVICE LIST
1
Joe H. Tuffaha Mark T. Drooks
2 Prashanth Chennakesavan BIRD MARELLA, BOXER, WOLPERT,
LTL ATTORNEYS LLP NESSIM, DROOKS, LINCENBERG &
3 300 S. Grand Avenue, Suite 3950 RHOW, P.C.
Los Angeles, CA 90071 1875 Century Park East, Suite 2300
4 Tel: (213) 612-8900 Los Angeles, CA 90067
Fax: (213) 612-3773 Tel: (310) 201-2100
5 Email: joe.tuffaha@ltlattorneys.com Fax: (310) 201-2110
prashanth.chennakesavan@ltlattorneys.com Email: mdrooks@birdmarella.com
6
Keith R. Hummel S. Gale Dick
7 Justin C. Clarke Phoebe King
Jonathan D. Mooney Randall Bryer
8 CRAVATH SWAINE AND MOORE LLP COHEN & GRESSER
825 Eighth Avenue 800 Third Ave.
9 New York, NY 10019 New York, NY 10022
Tel: (212) 474-1000 Tel: (212) 707-7263
10 Fax: (212) 474-3700 Fax: (212) 957-4514
Email: khummel@cravath.com Email: sgdick@cohengresser.com
11 jcclarke@cravath.com PKing@CohenGresser.com
jmooney@cravath.com RBryer@CohenGresser.com
12
Attorneys for Defendant and Cross-Complainant Attorneys appearing specially to challenge
13 Nouvel, LLC, and appearing specially to service and jurisdiction on behalf of Cross-
challenge service and jurisdiction on behalf of Defendants Marc-Olivier Perrin, SAS Miraval
14 Defendants SPI Group Holding Ltd., Tenute del Provence, and SAS Families Perrin
Mondo B.V., Yuri Shefler, and Alexey Oliynik
15

16 Paul D. Murphy
Daniel N. Csillag
17 MURPHY ROSEN LLP
100 Wilshire Blvd., Suite 1300
18 Santa Monica, CA 90401
Tel.: (310) 899-3300
19 Fax: (310) 399-7201
Email: pmurphy@murphyrosen.com
20 dcsillag@murphyrosen.com

21 Attorneys for Defendant and Cross-Complainant

Angelina Jolie
22

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PROOF OF SERVICE