Professional Documents
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LOS N. Hill: L LVD
LOS N. Hill: L LVD
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
[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) :
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
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)
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):
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.
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):
[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):
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.
DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yuri Shetler; Alexey Oliynik et al. 22STCV06081
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.
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):
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
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
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Executed on July 18, 2023, at Los Angeles, California.
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/s/ Carla K. Rossi
15 Carla K. Rossi
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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
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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
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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
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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
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PROOF OF SERVICE