1 PAUL D. MURPHY (State Bar No.

159556)
pmurphy@murphyrosen.com
2 DANIEL N. CSILLAG (State Bar No. 266773)
dcsillag@murphyrosen.com
3 STELLA CHANG (State Bar No. 335851)
schang@murphyrosen.com
4 MURPHY ROSEN LLP
100 Wilshire Boulevard, Suite 1300
5 Santa Monica, California 90401-1142
Telephone: (310) 899-3300
6 Facsimile: (310) 399-7201

7 Attorneys for Defendant and

Cross-Complainant Angelina Jolie
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9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
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12 WILLIAM B. PITT, an individual, and CASE NO. 22STCV06081

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MONDO BONGO, LLC, a California

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13 limited liability company, [Hon. Lia Martin]

MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142

14 DEFENDANT AND CROSS-

Plaintiffs, COMPLAINANT ANGELINA JOLIE’S
15 REPLY IN SUPPORT OF MOTION TO
vs. COMPEL FURTHER RESPONSES
16 FROM WILLIAM B. PITT TO FIRST
ANGELINA JOLIE, an individual, and SET OF REQUESTS FOR
17 NOUVEL, LLC, a California limited PRODUCTION OF DOCUMENTS;
liability company, SUPPLEMENTAL DECLARATION OF
18 PAUL D. MURPHY
Defendants.
19 Date: August 1, 2024
Time: 9:00 AM
20 Dept.: 3

21 AND RELATED CROSS ACTIONS. Reservation ID: 640811717941

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 1 TABLE OF CONTENTS

2 I. INTRODUCTION ...................................................................................................................... 4

3 II. ARGUMENT ............................................................................................................................ 6

4 A. Pitt Fails To Address His Own Allegations And Jolie’s Other Defenses. ...................... 6

5 B. The Documents Are Discoverable On The Issue of Unconscionability As Well. .......... 8

6 C. Pitt Does Not Have A Privacy Right In His Abuse Of Jolie And Their Family. ............ 9

7 D. Jolie Is Entitled To Explore Her Theories In Discovery. .............................................. 12

8 E. Documents “Sufficient To Show” What Happened Are Grossly Insufficient. ............. 13

9 III. CONCLUSION ...................................................................................................................... 13

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MURPHY ROSEN LLP
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 1 TABLE OF AUTHORITIES

2 Page(s)
3 Cases
4 Cent. Valley Ch. 7th Step Found. v. Younger,
5 214 Cal.App.3d 145 (1989) ..................................................................................................... 9

6 County of Los Angeles v. Sup. Ct.,

65 Cal.App.5th 621 (2021) .............................................................................................. 10, 11
7
Irvington-Moore, Inc. v. Sup. Ct,
8 14 Cal.App.4th 733 (1993) .................................................................................................... 12
9 Kendall-Jackson Winery, Ltd. v. Sup. Ct.,
76 Cal.App.4th 970 (1999) ...................................................................................................... 7
10

11 Mattco Forge v. Arthur Young & Co.,

223 Cal.App.3d 1429 (1990) ................................................................................................... 7
12
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Nat’l Steel Prods. Co. v. Sup. Ct.,

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13 164 Cal.App.3d 476 (1985) ..................................................................................................... 7

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14 Owens v. Co. of Los Angeles,

220 Cal.App.4th 107 (2013) .................................................................................................... 9
15
Pacific Fertility Cases,
16
85 Cal.App.5th 887, 893 (2022) .............................................................................................. 7
17
TBG Ins. Servs. Corp. v. Sup. Ct,
18 96 Cal.App.4th 443 (2002) .................................................................................................... 12

19 Tylo v. Sup. Ct.,

55 Cal.App.4th 1379 (1997) .................................................................................................. 10
20
Wang v. Fang,
21
59 Cal.App.5th 907 (2021) .................................................................................................... 11
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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 I. INTRODUCTION

2 In William B. Pitt’s lawsuit against Angelina Jolie, he demands she pay him $67 million

3 plus punitive damages. (SAC ¶ 198.) 1 In support, Pitt argues that Jolie’s eventual sale of

4 Miraval to a third-party—which occurred only after Pitt refused to buy Jolie’s interest unless she

5 agreed to a newly expanded NDA covering his personal misconduct—was “vindictive,”

6 “malicious,” and done “to inflict harm on” him. (Id. at ¶¶ 8, 121, 148.) Pitt also includes

7 detailed allegations about his demand for a revised NDA, and affirmatively attempts to minimize

8 the revision’s importance. (Id. at ¶¶ 83-92.) These are Pitt’s allegations—not Jolie’s—and by

9 including them in his operative complaints, Jolie has the right to challenge their accuracy.

10 In his brief, Pitt does not address these points. In fact, despite a 15-page Opposition and

11 a 373-page Separate Statement, Pitt never once uses the word “punitive” or the phrase “punitive

12 damages.” He pretends his allegations that Jolie maliciously used a ruling in the child custody
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13 case as an excuse to sell to someone else do not exist. (SAC ¶ 93.) Instead, Pitt creates a straw
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14 man called the “NDA defense,” which he defines as limited solely to the doctrine of

15 unconscionability. (See Opp. at 5.) Pitt even self-declares that this is Jolie’s “primary defense.”

16 (Id. at 5 n.2.) With his straw man in place, Pitt devotes most of his Opposition to attacking it.

17 But Pitt’s descriptions of Jolie’s arguments and defenses are not correct. Jolie’s “primary

18 defense” is that there is no implied contract, period. Moreover, Jolie was not acting with malice

19 and the intent to hurt Pitt in response to any custody ruling; instead, it was Pitt that refused to

20 buy her interest unless he received his newly expanded NDA, enforceable by an $8.5 million

21 holdback specifically designed to force her silence about his abuse and cover-up. Regardless of

22 whether unconscionability separately supports the discovery requests (and it does, discussed

23 below), the discovery Jolie seeks is highly relevant to Pitt’s case-in-chief. That Pitt failed to

24 even address his own allegations itself demonstrates that the motion is meritorious.

25 Because the documents are clearly relevant, Pitt next tries to circumvent RFPs 1-54 on

26 the ground that he has a privacy interest in his abusive and controlling conduct toward Jolie and

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After Jolie filed her motion, plaintiffs filed a Third Amended Complaint (“TAC”). The
TAC does not alter the material allegations Jolie cited from the SAC as relevant to this motion.
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 1 their children. (Opp. at 16-19.) While Pitt cites to case law regarding general privacy interests,

2 such as the marital relationship, he does not explain why those cases apply here. Unlike those

3 cases, Jolie and Pitt are no longer married; Pitt sued Jolie, making them litigation adversaries;

4 and Jolie and their children were victims of Pitt’s purportedly “private” abuse and cover-up.

5 Jolie maintains their agreement failed when Pitt demanded she grant him an expanded, personal

6 NDA in direct response to Jolie filing her “Offer of Proof and Authority re Testimony Regarding

7 Domestic Violence” about the very conduct he now claims he has a right to keep private. While

8 Pitt advances what is effectively an outdated privacy-of-domestic-violence argument to shield

9 his abuse, his argument is not the law, at least not in this century, and he cites no authority that

10 would give him such unwarranted protections. In any event, he waived any privacy protections

11 when he sued Jolie. And as the Court previously ruled for Pitt’s motion to compel Jolie’s other

12 NDAs, any valid privacy interests can be addressed through the existing Protective Order.
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13 As for Pitt characterizing his own conduct toward his family as “incendiary” (Opp. at 1),
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14 that only proves Jolie’s point: Pitt needed to bury his misconduct to protect his career. Jolie has

15 no desire to litigate these issues and for years never publicly discussed any of it. Rather than

16 appreciate her discretion, Pitt sought to contractually mandate and enforce it. Because she

17 refused, he seeks to punish her, demanding $67 million plus punitive damages. In so doing, Pitt

18 placed his conduct squarely at issue. While Jolie sincerely wishes Pitt would end this litigation

19 and finally put their family on a clear path toward healing, that cannot happen while Pitt

20 relentlessly pursues her. Until he stops, Jolie has no choice but to prove his allegations wrong.

21 Here, this means Jolie needs to prove the real reason Pitt rejected the very deal he now

22 says he wanted: Because Miraval was the last bit of leverage and control Pitt held over Jolie, he

23 was not going to release that leverage unless Jolie first agreed to contractually bury his

24 misconduct on threat of an $8.5 million holdback. That’s the reason the sale did not go through,

25 and why the Court should compel Pitt to produce the evidence demonstrating exactly why

26 burying this misconduct was so important to him. The Court should grant Jolie’s motion.

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 1 II. ARGUMENT

2 A. Pitt Fails To Address His Own Allegations And Jolie’s Other Defenses.

3 In a footnote, Pitt notes that Jolie devotes much of her motion to detailing “painful”

4 details over their divorce and custody proceedings—dismissing them as having “no bearing on

5 the discovery at issue.” (Opp. at 8 n.6.) But of course Pitt’s abuse, control, and cover-up bear on

6 the issues in this case. Pitt’s allegations are that Jolie vindictively sold her interest in Miraval to

7 someone else as a direct result of a ruling in the custody proceeding (a ruling that was promptly

8 thrown out due to the judge’s unethical failure to disclose his frequent business dealings with

9 Pitt’s lawyers). (SAC ¶ 93.) By including the allegation, Pitt placed its truth at issue. Jolie will

10 use the documents she seeks to prove that the allegation is absolutely false. Jolie will also prove

11 the reason the deal did not go through is due to Pitt’s last-minute and unreasonable demand for

12 an expanded, personal NDA. Pitt also seeks punitive damages from Jolie. Whether he is entitled
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13 to such damages will turn on whether Jolie acted with malice.

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14 Rather than grapple with his own allegations, Pitt tries to sidestep them by suggesting

15 that Jolie never explained “why” she needs to present the jury with evidence of what Pitt hoped

16 to cover-up. (See Opp. at 14.) But Jolie did explain why; Pitt just ignores her explanation. That

17 evidence will show why Jolie’s sale to Pitt fell apart over Pitt’s demand to expand the NDA to

18 cover his years of abuse, denials, and cover-up—something that was so important to Pitt that he

19 was willing to imperil the entire transaction unless Jolie agreed to it. To prove this, Jolie will use

20 Pitt’s own contemporaneous communications describing and demonstrating exactly the behavior

21 he later sought to cover. As Jolie explained in her motion, abuse survivors are often discredited

22 and rarely believed on their word alone. (Motion at 17.) When Pitt saw in the Offer of Proof the

23 proffered testimony and his own hurtful emails demonstrating his past abuse of Jolie and their

24 children, he knew he needed to bury it all. In response, he demanded Jolie sign the expanded

25 NDA to prevent her from ever speaking of it. In light of Pitt’s years of denials and gaslighting of

26 his own family, Jolie was genuinely devastated by Pitt’s demand. Pitt’s candid discussions about

27 these issues will be powerful evidence of why Pitt was so desperate for his revised NDA, and

28 why Pitt’s demand for Jolie’s silence impacted her so deeply.

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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 Moreover, Jolie identified in her motion affirmative defenses she plans to assert in this

2 case beyond unconscionability, including unclean hands, estoppel, and breach of the implied

3 covenant of good faith and fair dealing. (Mot. at 15.) These legal issues revolve around the

4 same core argument. Jolie will argue that if Pitt did have an implied contract, Pitt breached that

5 contract’s implied covenant of good faith and fair dealing by conditioning his buy-out right on

6 Jolie agreeing to a punishing NDA—thus excusing her from seeking Pitt’s consent to sell to a

7 third party. She will also argue that Pitt triggered the defenses of unclean hands and equitable

8 estoppel when, in direct response to Jolie’s Offer of Proof, he conditioned his purchase on Jolie

9 agreeing to expand the NDA to cover his abuse of his family. See Kendall-Jackson Winery, Ltd.

10 v. Sup. Ct., 76 Cal.App.4th 970, 978-79 (1999) (unclean hands is established by “conduct that

11 violates conscience, or good faith, or other equitable standards of conduct”); Pacific Fertility

12 Cases, 85 Cal.App.5th 887, 893 (2022) (equitable estoppel “precludes a party from asserting
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13 rights he otherwise would have had against another when his own conduct renders assertion of
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14 those rights contrary to equity”). The worse Pitt’s conduct he hoped to bury with the revised

15 NDA, the stronger Jolie’s case for invoking these equitable defenses.

16 Rather than engage with the relevance of these defenses, Pitt claims that because Jolie

17 has not yet filed her answer and asserted her affirmative defenses, she cannot establish relevance

18 through them. (Opp. at 13-14.) Pitt’s position is blatantly wrong. See Mattco Forge v. Arthur

19 Young & Co., 223 Cal.App.3d 1429, 1436 n.3 (1990) (“[p]leading deficiencies generally do not

20 affect either party’s right to conduct discovery [citation] and this right . . . is particularly

21 important to a plaintiff in need of discovery to amend its complaint”); Nat’l Steel Prods. Co. v.

22 Sup. Ct., 164 Cal.App.3d 476, 492 (1985) (“Relevancy is a broader concept than relevancy to the

23 issues, the standard is relevancy to the subject matter, which is determined by potential, not

24 actual, issues in the case.”). Under California law, Jolie has the right to seek discovery to expand

25 and support her existing legal theories regardless of whether she has yet filed her answer.

26 But this motion is not the time to argue the merits of Jolie’s positions and affirmative

27 defenses. Instead, the issue presented here is whether RFPs 1-54 seek evidence that is relevant

28 or reasonably likely to lead to the discovery of admissible evidence on these issues. They do.

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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 B. The Documents Are Discoverable On The Issue of Unconscionability As Well.

2 The bulk of Pitt’s opposition is devoted to addressing unconscionability. While Jolie will

3 assert such a defense, it is only one of many legal arguments she will be asserting. For this

4 reason, in her motion, she does not feature it any differently than her other arguments and

5 defenses, and only identifies the legal doctrine twice, once on page 14 (“unconscionable”) and

6 again on page 15 (“unconscionability”). The reason Pitt focuses on this one defense is because

7 he thinks he can use it to limit the scope of discovery. According to Pitt, the issue of

8 unconscionability can only be decided based on facts and circumstances that pre-date the entry of

9 the implied contract, and not an “event that occurred after the formation of the parties’ contract.”

10 (Opp. at 13.) There are two problems with this argument. First, Pitt misconstrues

11 discoverability with admissibility of evidence at trial. It may well be that some of this evidence

12 ultimately is inadmissible at trial on the unconscionability defense, but that does not preclude
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13 Jolie from obtaining it, or inform whether it could lead to the production of other admissible
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14 evidence on unconscionability or on any of the other issues and affirmative defenses in the case.

15 Second, Pitt’s premise that the implied contract was fully formed before he demanded the

16 NDA in 2021 has not even been alleged, let alone definitively established. As Jolie highlighted

17 in her first demurrer, Pitt never alleges when the implied contract formed. Pitt even successfully

18 defended against that demurrer by arguing he need not plead the date when the contract came

19 into force—and he cited Jolie’s conduct during the 2021 negotiations to support its formation.

20 (See Pitt’s Opp. to Demurrer at 12 n.3 (“Jolie’s related argument that ‘most of [the] conduct

21 [relevant to the implied contract] occurred years after the alleged implied contract was formed

22 thus misses the mark”).) Now he takes the opposite position.

23 And that is not the only time Pitt’s Opposition takes a 180-degree change of position. On

24 May 17, 2024, Pitt convinced this Court to order Jolie to produce all non-disclosure, non-

25 disparagement, and confidentiality agreements (and related correspondence) Jolie, or any of her

26 entities, ever entered or proposed with any person for any reason over an eight year period—

27 2014 to 2022. Pitt’s rationale was that the NDAs and Jolie’s emails might bear on Jolie’s

28 argument that, to the extent Pitt’s alleged implied contract allowed him to demand a personal

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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 NDA covering his abuse, that implied contract is unconscionable. At the related hearing, the

2 Court agreed, stating that the evidence was potentially relevant “on that narrow issue of what is

3 considered unconscionable” although the Court was “not making any finding today about the

4 admissibility of any such documents.” (Cherlow Decl. ISO Pitt’s Opp., Exh. 2 at 6:9-15.) (Id. at

5 6:19-21.) In response, Jolie has now incurred significant time and expense gathering and

6 producing over 10,000 pages of responsive documents. (Supp. Murphy Decl. ¶ 2.)

7 Pitt now takes the opposite position, arguing with bolded letters that unconscionability is

8 an “objective” legal theory that can only be based on evidence “at the time [the contract] was

9 made.” (Opp. at 6, 13.) Since the plane incident occurred in 2016, he argues all of this later

10 evidence is irrelevant because by then the implied contract had already been entered. (Id. at 12-

11 14.) But as explained above, in opposition to the demurrer, Pitt successfully argued that

12 evidence regarding the implied contract’s formation was relevant through the 2021 negotiation,
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13 and in support of his motion to compel, he argued that eight years of NDAs entered long after
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14 the implied contract informs the unconscionability of that same contract. Pitt’s self-serving

15 reversals constitute classic judicial estoppel, barring him “from asserting a position in a legal

16 proceeding that is contrary to a position he . . . successfully asserted in the same or some earlier

17 proceeding. See Owens v. Co. of Los Angeles, 220 Cal.App.4th 107, 121 (2013).

18 C. Pitt Does Not Have A Privacy Right In His Abuse Of Jolie And Their Family.

19 Pitt spends the remainder of his brief arguing the right of privacy separately protects the

20 documents Jolie seeks, and at least requires a balancing of interests. He cites several cases for

21 the proposition that he has a broad privacy interest in “non-conviction law enforcement records,

22 medical records, his married life, drug and substance abuse treatment, and therapy,” (Opp. at 16),

23 but he never explains how the interests identified in the cases outweigh Jolie’s need to defend

24 herself. For example, Pitt cites to Younger for the proposition that law enforcement records

25 implicate privacy interests, but Younger does not analyze the arrestee’s own communications—it

26 discusses a governmental agency’s “official collection, retention, and dissemination of arrest

27 records.” Cent. Valley Ch. 7th Step Found. v. Younger, 214 Cal.App.3d 145, 162 (1989). Here,

28 Jolie seeks Pitt’s communications, which requires an entirely different balancing analysis.

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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 For married life, Pitt cites to Tylo, but that case does not help him either. In Tylo, the

2 plaintiff was an actress and the defendant was a production company that terminated her

3 employment when she informed them she was pregnant. Tylo v. Sup. Ct., 55 Cal.App.4th 1379,

4 1382-83 (1997). At deposition, the company asked questions “relating to her relationship with

5 her husband” and “her attempts to become pregnant,” arguing that it had the right to explore

6 other stressors in her life. Id. at 1383, 1386. The court rejected that argument, noting that

7 plaintiff had tendered her emotional distress damages only as they related to her wrongful

8 termination, and that invading the marital relationship could not be outweighed by mere

9 speculation that the relationship might have also caused emotional distress. Id. at 1388.

10 Tylo is a far cry from this case. Unlike in Tylo, where a married couple attempted to

11 protect their privacy from pure speculation, here, Jolie filed to divorce Pitt following his abuse of

12 her and their children; Pitt and Jolie are no longer married; and—because Pitt sued her—they are
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13 opposing litigants. Pitt cites no authority suggesting that formerly married but now adverse
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14 litigants can use their individual rights of privacy to shield from discovery criminal and tortious

15 behavior committed by one spouse against the other solely because they were formerly married.

16 That is also a dangerous proposition when, as here, physical and emotional abuse is alleged. It

17 would make a mockery of the justice system to permit an abuser to conceal the abuse of his ex-

18 wife and children under the guise of privacy when the discovery is sought by one of his victims.

19 Pitt also cites to the County of Los Angeles opioid litigation for the proposition that the

20 privacy of his medical and therapy records outweighs Jolie’s need for their production, but that

21 case again differs materially from this one. In that case, the government alleged a false and

22 deceptive marketing scheme to minimize the risk of opioid medications. County of Los Angeles

23 v. Sup. Ct., 65 Cal.App.5th 621, 626 (2021). The defendant (Johnson & Johnson) served

24 subpoenas on non-party counties seeking medical records on substance abuse for nearly 6,000

25 individuals—none of whom were parties. Id. at 628. The court held that Johnson & Johnson

26 failed to demonstrate that its interests in “‘such a vast production of medical information’

27 [citation] outweighed the significant privacy interests that the nonparty petitioners have

28 identified.” Id. at 530. In so holding, the court emphasized that “the patients whose records are

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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 being sought have not taken any litigation position that could possibly constitute a waiver of

2 their privacy rights.” Id. at 643 (emphasis in original).

3 Here, Jolie is not seeking third-party records—she is seeking Pitt’s own records. Further,

4 unlike in County of Los Angeles, Pitt is a party, and when he sued Jolie, he placed directly at

5 issue why he demanded an expanded NDA. He makes detailed allegations about the meaning of

6 the proposed NDAs and claims Jolie’s emotional reaction to the NDA was a “pretext.” (SAC at

7 ¶¶ 88, 92.) Jolie is entitled to challenge these allegations. Pitt’s non-privileged medical and

8 therapy documents that support Jolie’s theory are discoverable.

9 As for Pitt’s communications with his friends and business advisors, Pitt baldly asserts

10 that he had “a reasonable expectation of privacy with respect to communications with his closest

11 advisors about the most personal events of his life.” (Opp. at 17.) Pitt offers no legal authority

12 and no evidence to support his assertion. Absent such a showing, Pitt has failed to demonstrate a
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13 protectable privacy right on these communications about abuse and cover up, let alone a privacy
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14 right that cannot be adequately protected under the parties’ existing Protective Order.

15 Pitt also argues that the only countervailing interest Jolie asserts is “her alleged reaction

16 to receiving the proposed NDA language.” (Opp. at 17.) While Jolie’s need to prove that her

17 reaction was genuine is certainly a strong countervailing interest that alone overcomes Pitt’s

18 supposed privacy interest, it is only one of many. As Jolie stated in her motion and in this reply,

19 the discovery she seeks is also important to disproving Pitt’s case-in-chief, defending against

20 Pitt’s request for punitive damages, proving the allegations in Jolie’s Cross-Complaint, and

21 helping Jolie establish the factual predicates for her legal and equitable defenses in this case.

22 Finally, as this Court already ruled in compelling Jolie to produce eight years’ worth of

23 NDAs, any privacy interests can be adequately addressed through the existing Protective Order.

24 (See Cherlow Decl., Exh. 2 at 6:21-25.) If Pitt believes some documents reflect his protectable

25 privacy interests, he can designate them confidential. Pitt offers no reason why this approach

26 does not properly balance the parties’ interests, especially since this is the same approach Pitt

27 convinced this Court to adopt for Jolie’s NDA documents. See Wang v. Fang, 59 Cal.App.5th

28 907, 916 n.9 (2021) (“What is sauce for the goose is sauce for the gander.”).

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ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 D. Jolie Is Entitled To Explore Her Theories In Discovery.

2 Pitt also claims that Jolie is on a “sensationalist fishing expedition” (Opp. at 5) exploring

3 “wildly and impermissibly speculative” theories. (Opp. at 18.) But she is not. She is simply

4 defending herself from Pitt’s baseless allegations. And even if she was, California law expressly

5 allows for it. As one court explained, “In our discovery statutes the Legislature has authorized

6 fishing expeditions and thus the claim that a party is engaged upon a fishing expedition is not,

7 and under no circumstance can be, a valid objection to an otherwise proper attempt to utilize the

8 provisions of the discovery statutes.” Irvington-Moore, Inc. v. Sup. Ct, 14 Cal.App.4th 733, 739

9 n.4 (1993). As another court stated, the proponent of discovery “is entitled to discover any

10 nonprivileged information, cumulative or not, that may reasonably assist it in evaluating its

11 defense, preparing for trial, or facilitating a settlement. Admissibility is not the test, and it is

12 sufficient if the information sought might reasonably lead to other, admissible evidence.” TBG
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13 Ins. Servs. Corp. v. Sup. Ct, 96 Cal.App.4th 443, 448-49 (2002).

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14 If Pitt has his way, Jolie’s entire defense would be limited only to the information she

15 already knows. He even criticizes Jolie for “blindly surmising” what his communications might

16 show. (Opp. at 18.) Of course Jolie does not know exactly what Pitt’s communications will

17 show—that is the purpose of discovery. But what Jolie does know is that after she filed her

18 Offers of Proof detailing Pitt’s actions in black and white, he was terrified that the details would

19 leak into the public domain, and he demanded as a condition of his purchase that Jolie

20 contractually agree to bury it. If Pitt did not walk away from the deal because of the filing in the

21 custody case, then why did his own deal lawyer explain it this way: “Mr. Pitt and the Perrin

22 family [have decided] to step back from the agreement until an undefined future point” due to

23 “recent reports that during sealed legal proceedings currently taking place in California, [Jolie]

24 had submitted offers of proof relating to domestic violence.” (Murphy Decl., Exh. 2 at 2.)

25 Pitt’s narrative is that this case is just about a “business dispute.” (Opp. at 8 n.6.) But

26 that is Pitt’s theory. Jolie’s theory is that this case is about Pitt’s attempt to use Miraval as

27 leverage to control and enforce her silence. The jury will decide what the evidence shows, but

28 for now, Jolie is entitled to gather the evidence she needs to support her theory.

-12- PRINTED ON RECYCLED PAPER

ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 E. Documents “Sufficient To Show” What Happened Are Grossly Insufficient.

2 Rather than address the five specific categories of documents Jolie’s seeks through RFPs

3 1-54 (Mot. at 17-19), Pitt claims he actually agreed to give most of what Jolie seeks by agreeing

4 to produce documents concerning the proposed sale and the reasons Pitt proposed to modify the

5 scope of the NDA. (See Opp. at 15-16.) But Pitt contends that he did not use the NDA to

6 attempt to cover up any abuse. If all Pitt must produce are the documents that support his

7 version of why he demanded the NDA—which Jolie vociferously disputes—it is tantamount to

8 forcing Jolie, even in discovery, to accept his position. Again, that is not the law.

9 Nor is Pitt’s offer to give Jolie documents “sufficient to show everything that occurred on

10 the flight” in 2016 in any way sufficient. (See Opp. at 7, 18 (emphasis in original).) What Pitt

11 hoped to bury is far broader than what happened on that plane—it includes years of wrongful and

12 controlling conduct before and after that incident. The plane flight was horrific and harmful to
TELEPHONE 310-899-3300; FACSIMILE 310-399-7201
100 WILSHIRE BOULEVARD, SUITE 1300

13 Jolie and their children, but just as important was its aftermath, which is why his demand for a
MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142

14 modified NDA was especially hurtful to Jolie. Yet under Pitt’s proposal, he gets to limit the

15 topic to only what occurred on that plane and also gets to decide what is “sufficient” to show

16 that, and what is not. The Discovery Act does not give him that power.

17 III. CONCLUSION

18 Pitt chides Jolie for alleging that his demand for an NDA “nearly broke her.” (Opp. at

19 18, n.12.) But if an abuser (a) refused to take responsibility for his abuse, (b) denied it publicly

20 for years, (c) refused to allow the family to heal, and then (d) demanded as a condition of

21 purchasing the last asset the couple shared that the victim agree to expand a business NDA to

22 cover his personal, abusive conduct—this treatment would likely break anyone. Pitt can belittle

23 Jolie’s genuine reaction to his conduct all he wants, but by suing her, Jolie has the right to obtain

24 the discovery to prove him wrong. The Court should grant the motion and compel Pitt to

25 produce all the responsive, non-privileged documents.

26 DATED: July 25, 2024 MURPHY ROSEN LLP

27 By:
Paul D. Murphy, Daniel N. Csillag
28 Attorneys for Defendant and
Cross-Complainant Angelina Jolie
-13- PRINTED ON RECYCLED PAPER
ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES
 1 SUPPLEMENTAL DECLARATION OF PAUL D. MURPHY

2 I, Paul D. Murphy, declare:

3 1. I am an attorney duly licensed to practice law in the States of California and

4 New York. I am the managing partner at the law firm Murphy Rosen LLP, and counsel for

5 Defendant and Cross-Complainant Angelina Jolie. I submit this supplemental declaration in

6 support of Jolie’s Motion to Compel Further Responses from Plaintiff and Cross-Defendant

7 William B. Pitt. I have personal knowledge of the foregoing and if called upon as a witness, I

8 could and would competently testify to them.

9 2. On May 16, 2024, this Court granted Pitt’s motion to compel Jolie to produce

10 non-disclosure agreements, non-disparagement agreements, and/or confidentiality agreements

11 she entered or proposed during the period from January 1, 2024, through the date this lawsuit

12 was filed, February 18, 2022. The Court also ordered Jolie to produce all of her correspondence
TELEPHONE 310-899-3300; FACSIMILE 310-399-7201
100 WILSHIRE BOULEVARD, SUITE 1300

13 discussing these contractual terms. In response to the Court’s order, Jolie has now produced to
MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142

14 Pitt over 10,000 pages of documents.

15 I declare, under penalty of perjury, under the laws of the State of California, that the

16 foregoing is true and correct.

17 Executed this 25th day of July, 2024, at Santa Monica, California.

18

19 _______________________________
Paul D. Murphy
20

21

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25

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27

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-14- PRINTED ON RECYCLED PAPER

SUPPLEMENTAL DECLARATION OF PAUL D. MURPHY
 1 PROOF OF SERVICE

2 I, Christina M. Garibay, declare:

3 I am employed in the County of Los Angeles, State of California. I am over the age of
18 and not a party to this action. My business address is 100 Wilshire Boulevard, Suite 1300,
4 Santa Monica, California 90401-1142, (310) 899-3300.

5 On July 25, 2024, I served the document(s) described as DEFENDANT AND CROSS-
COMPLAINANT ANGELINA JOLIE’S REPLY IN SUPPORT OF MOTION TO
6 COMPEL FURTHER RESPONSES FROM WILLIAM B. PITT TO FIRST SET OF
REQUESTS FOR PRODUCTION OF DOCUMENTS; SUPPLEMENTAL
7 DECLARATION OF PAUL D. MURPHY on the interested parties in this action:

8
SEE ATTACHED SERVICE LIST
9

10 BY ELECTRONIC SERVICE: I caused the above-document(s) to be served via the Los

Angeles Superior Court’s electronic service provider, One Legal.
11
BY E-MAIL: Based on a court order or an agreement of the parties to accept service by
12 e-mail or electronic transmission, I caused the documents to be sent to the persons at the email
TELEPHONE 310-899-3300; FACSIMILE 310-399-7201

addresses listed above or on the attached service list. I did not receive within a reasonable time
100 WILSHIRE BOULEVARD, SUITE 1300

13 after the transmission, any electronic message or other indication that the transmission was
MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142

unsuccessful.
14
[State] I declare under penalty of perjury under the laws of the State of California that
15 the above is true and correct.

16 Executed on July 25, 2024, at Santa Monica, California.

17

18 Christina M. Garibay

19

20

21

22

23

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25

26

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-1- PRINTED ON RECYCLED PAPER

PROOF OF SERVICE
 1 SERVICE LIST

2 William B. Pitt, et al. v. Angelina Jolie, et al.

Los Angeles Superior Court Case No. 22STCV06081
3

4 John V. Berlinski Attorneys for Plaintiffs and Cross-

Julie B. Cherlow Defendants William B. Pitt, Mondo Bongo,
5 Brandon R. Teachout LLC and Cross-Defendant Warren Grant
Rebecca Attarson
6 BIRD MARELLA RHOW LICENBERG
DROOKS & NESSIM LLP
7
1875 Century Park East, 23rd Floor
8 Los Angeles, CA 90067
T: (310) 201-2100 F: (310) 201-2110
9 jberlinski@birdmarella.com
BTeachout@birdmarella.com
10 jcherlow@birdmarella.com
fwang@birdmarella.com
11 skosmacher@birdmarella.com
KMeyer@birdmarella.com
12 PYates@birdmarella.com
TELEPHONE 310-899-3300; FACSIMILE 310-399-7201

RAttarson@birdmarella.com
100 WILSHIRE BOULEVARD, SUITE 1300

13 kminutelli@birdmarella.com
MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142

Attorneys for Cross-Defendants Roland

14 Venturini and Gary Bradbury appearing
Jonathan Moses specially to challenge jurisdiction
15 Adam L. Goodman
Jessica L. Layden
16 Ioannis D. Drivas
WACHTELL, LIPTON, ROSEN & KATZ
17 51 West 52nd Street
18 New York, NY 10019
T: (212) 403-1000 F: (212) 403-2000
19 jmmoses@wlrk.com
algoodman@wlrk.com
20 jllayden@wlrk.com
iddrivas@wlrk.com Attorneys for Cross-Defendants Roland
21
Venturini and Gary Bradbury appearing
22 Laura W. Brill specially to challenge jurisdiction
Matthew P. Bernstein
23 Daniel Barlava
KENDALL BRILL & KELLY LLP
24 10100 Santa Monica Blvd., Suite 1725
Los Angeles, CA 90067
25
Telephone: (310) 556-2700
26 lbrill@kbkfirm.com
mbernstein@kbkfirm.com
27 dbarlava@kbkfirm.com
28

-2- PRINTED ON RECYCLED PAPER

PROOF OF SERVICE
 1 S. Gale Dick Attorneys appearing specially to challenge
Phoebe King jurisdiction on behalf of Cross-Defendants
2 Randall Bryer Marc-Olivier Perrin, SAS Miraval
COHEN & GRESSER Provence, and SAS Familles Perrin
3 800 Third Ave.
New York, NY 10022
4
sgdick@cohengresser.com
5 pking@cohengresser.com
rbryer@cohengresser.com
6 Attorneys for Defendant and Cross-
Joe H. Tuffaha Complainant Nouvel, LLC and appearing
7 Prashanth Chennakesavan specially to challenge jurisdiction on
behalf of Defendant Tenute del Mondo
8 LTL ATTORNEYS LLP B.V., SPI Group Holding, Ltd., Yuri
300 South Grand Avenue Suite 1400 Shelfer and Alexey Oliynik
9 Los Angeles, CA 90071
T: (213) 612-8900 F: (213) 612-3773
10 joe.tuffaha@ltlattorneys.com
prashanth.chennakesavan@ltlattorneys.com
11
Attorneys for Defendant and Cross-
12 Keith R. Hummel Complainant Nouvel, LLC and appearing
TELEPHONE 310-899-3300; FACSIMILE 310-399-7201

Justin C. Clarke specially to challenge jurisdiction on

100 WILSHIRE BOULEVARD, SUITE 1300

13 Jonathan Mooney behalf of Defendant Tenute del Mondo

MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142

CRAVATH SWAINE AND MOORE LLP B.V., SPI Group Holding, Ltd., Yuri
14 825 Eighth Avenue Shelfer and Alexey Oliynik
New York, NY 10019
15 T: (212) 474-1000 F: (212) 474-3700
khummel@cravath.com
16 jcclarke@cravath.com
jmooney@cravath.com
17 Attorneys appearing specially to challenge
jurisdiction on behalf of Cross-Defendants
18 Mark T. Drooks Marc-Olivier Perrin, SAS Miraval
Debbie Throckmorton Provence, and SAS Familles Perrin
19 Assistant to Mark Drooks
BIRD MARELLA, BOXER, WOLPERT,
20 NESSIM, DROOKS, LINCENBERG &
RHOW, P.C.
21
1875 Century Park East, Suite 2300
22 Los Angeles, CA 90067
Tel: (310) 201-2100
23 Fax: (310) 201-2110
mdrooks@birdmarella.com
24 dthrockmorton@birdmarella.com
25

26

27

28

-3- PRINTED ON RECYCLED PAPER

PROOF OF SERVICE