Unlimited Case Limited Case: Superior Court of California, County of Los Angeles
Unlimited Case Limited Case: Superior Court of California, County of Los Angeles
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Prashanth Chennakesavan, State Bar No. 284022, 300 S. Grand Ave, 39th Floor, Los
Angeles, CA 90071.
✖ Notice of Intent to Appear by Telephone, by (name): K. Hummel; J. Clarke; J. Mooney; P. Chennakesavan; J. Tuffaha
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. ✖ This statement is submitted by party (name): Nouvel, LLC
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. ✖ The cross-complaint, if any, was filed on (date): July 10, 2023
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. ✖ The following parties named in the complaint or cross-complaint
(1) ✖ have not been served (specify names and explain why not):
Service underway for Petrichor;Vins et Domaines Perrin;Miraval Studios;Le Domaine;Distilleries de la Riviera
(2) have been served but have not appeared and have not been dismissed (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in ✖ complaint ✖ cross-complaint (Describe, including causes of action):
Plaintiffs claim inter alia breaches of purported implied-in-fact contract, quasi-contract, Luxembourg law and tortious
interference concerning the sale of Nouvel to Tenute. Nouvel claims inter alia tortious interference, breach of the duty of good
faith and civil conspiracy in connection with Cross-Defendants' misuse of the assets of the Parties' joint investment.
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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 [indicate 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.)
Nouvel alleges that Cross-Defendants tortiously interfered with Nouvel's rights and devalued Nouvel's investment in Chateau
Miraval, a French wine business in which Nouvel and Plaintiff Mondo Bongo are 50/50 joint owners. Nouvel seeks damages in
excess of $350 million and specific performance. Plaintiffs allege that Defendants improperly participated in Jolie's sale of
Nouvel to Tenute and that Defendants disrupted Plaintiffs' economic relationship with Chateau Miraval and other entities.
(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 ✖ a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. ✖ No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
This case involves numerous Defendants challenging personal jurisdiction and will involve complex discovery.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
June 10-14, 2024 - K. Hummel trial in Vitaworks v. Glanbia (D. Del. No. 19-2259); July 22-26, 2024 - K. Hummel trial in
Vitaworks v. Prinova (D. Del. No. 19-2260); November 4-8, 2024 - K. Hummel trial in Vitaworks v. Glanbia (D. Del. No. 21-0327)
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):
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. 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.
Bankruptcy ✖ Other (specify): Parties may move to quash on personal jurisdiction and service of process grounds.
Status:
14. Bifurcation
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):
✖ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Nouvel will file a demurrer to Plaintiffs' Second Amended Complaint. If any claims survive the demurrer, Nouvel expects that
the claims will be susceptible to dismissal in summary judgment.
16. Discovery
a. The party or parties have completed all discovery.
b. ✖ The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Nouvel, LLC Deposition and Written Discovery Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
b. ✖ After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
The parties set a schedule for briefing demurrers and motions to quash.
Joe Tuffaha
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
2
STATE OF CALIFORNIA
3 COUNTY OF LOS ANGELES
4 I am employed in the County of Los Angeles State of California. I am over the age of 18,
and not a party to the within action. My business address is 300 South Grand Ave., Suite 3950, Los
5 Angeles, CA 90071.
13
[X] BY ELECTRONIC MAIL I transmitted the above-listed document(s) to the e-mail
14 address set forth above on this date.
15 Executed on July 18, 2023, at Los Angeles, California.
16 [X] (State) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
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18 Erika Santoyo
19 Print Name Signature
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PROOF OF SERVICE