CM-110

ATTORNEY OR PARTY WITHOUT ATTORNEY 195889

STATE BAR NUMBER: FOR COURT USE ONLY
NAME: Laura W. Brill
FIRM NAME: KENDALL BRILL & KELLY LLP
STREET ADDRESS: 10100 Santa Monica Blvd., Suite 1725
CITY: Los Angeles STATE: CA ZIP CODE: 90067
TELEPHONE NO.: (310) 556-2700 FAX NO.: (310) 556-2705
EMAIL ADDRESS: [email protected]
ATTORNEY FOR (name): Roland Venturini; Gary Bradbury (specially appearing)

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

STREET ADDRESS: 111 N. Hill St.
MAILING ADDRESS: 111 N. Hill St.
CITY AND ZIP CODE: Los Angeles; 90012
BRANCH NAME: 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): UNLIMITED CASE LIMITED CASE 22STCV06081

(Amount demanded (Amount demanded is $35,000
exceeds $35,000) or less)

A CASE MANAGEMENT CONFERENCE is scheduled as follows:

Date: March 15, 2024 Time: 9:00am Dept.: 3 Div.: Room:
Address of court (if different from the address above):

Notice of Intent to Appear by Telephone, by (name):

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):
b. This statement is submitted jointly by parties (names): Roland Venturini & Gary Bradbury (specially appear. Cross-Defs.)
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):
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):

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

(3) have had a default entered against them (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):
Nouvel brings claims sounding in contract & tortious interference ("TI") arising out of alleged mismanagement of European
entities. Claims: (1, 9) TI w/ Contractual Relations & Aiding & Abetting thereof; (2-5, 10, 11) TI w/ Prospective Bus. Relations &
Aiding & Abetting & Civil Conspiracy thereof; (6) Breach of Duty of Good Faith; (7) Trespass to Chattels; (8) Abuse of Rights.
Page 1 of 5

Form Adopted for Mandatory Use

Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720–3.730
CM-110 [Rev. January 1, 2024] www.courts.ca.gov
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

DEFENDANT/RESPONDENT: Angelina Jolie; Nouvel, LLC; Yuri Shefler; 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 [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):
Cross-Complainant Nouvel brings claims relating to alleged mismanagement of and asset misappropriation at Chateau Miraval
(a French entity) and Quimicum (a Luxembourg entity). Cross-Defendants Venturini and Bradbury have moved to quash
Nouvel's First Amended Cross-Compl. ("FACC") for lack of personal jurisdiction or, in the alternative, to dismiss/stay on forum
non conveniens grounds.
(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):
If their motions to quash are denied, Venturini and Bradbury each requests 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):

c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):

7. Estimated length of trial

The party or parties estimate that the trial will take (check one)
a. days (specify number):
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney: Jonathan Moses; Adam Goodman
b. Firm: Wachtell, Lipton, Rosen & Katz
c. Address: 51 West 52nd. St. New York, NY 10019
d. Telephone number: (212) 403-1000 f. Fax number: (212) 403-1000
e. Email address: [email protected]; [email protected] g. Party represented: Venturini; Bradbury
Additional representation is described in Attachment 8.
9. Preference
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 has 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 has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 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) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) 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

Page 2 of 5
CM-110 [Rev. January 1, 2024]
CASE MANAGEMENT STATEMENT
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

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

10. c. In the table below, 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):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):

Settlement conference not yet scheduled

(2) Settlement Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date):
Settlement conference completed on (date):

Neutral evaluation not yet scheduled

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

Judicial arbitration not yet scheduled

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

Private arbitration not yet scheduled

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

ADR session not yet scheduled

ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):

Page 3 of 5
CM-110 [Rev. January 1, 2024]
CASE MANAGEMENT STATEMENT
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

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

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): Venturini & Bradbury moved to quash for lack of jurisd. (as have 8 other Cross-Defs).
Status: Venturini's motion is scheduled to be heard on June 7, 2024, and Bradbury's is scheduled to be heard on Aug. 7, 2024.

13. Related cases, consolidation, and coordination

a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.

b. A motion to consolidate coordinate wiII be filed by (name party):

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):

15. Other motions

The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Venturini and Bradbury have each moved to quash service of the FACC for lack of personal jurisdiction or, in the alternative,
dismiss/stay on forum non conveniens grounds. The determination of whether any other motions might be filed is premature.

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

c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Because Venturini and Bradbury are appearing specially, participation in matters relating to further prosecution of the action is
premature.

Page 4 of 5
CM-110 [Rev. January 1, 2024]
CASE MANAGEMENT STATEMENT
 CM-110
PLAINTIFF/PETITIONER: William B. Pitt; Mondo Bongo, LLC CASE NUMBER:

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

17. Economic litigation

a. This is a limited civil case (i.e., the amount demanded is $35,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. 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

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

19. Meet and confer

a. 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):
Venturini and Bradbury have not met and conferred with the other parties, as they have each moved to quash service of
the FACC for lack of personal jurisdiction. They have submitted this statement per the instructions of the Court at the
December 11, 2023 hearing. This statement does not constitute their consent to this Court’s jurisdiction or a waiver of
their right to move to quash service.

b. 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: February 29, 2024

/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)

Additional signatures are attached.

CM-110 [Rev. January 1, 2024]

CASE MANAGEMENT STATEMENT Page 5 of 5
 MC-025
CASE NUMBER:
SHORT TITLE:
Related Cases 22STCV06081
ATTACHMENT (Number): 13a
(This Attachment may be used with any Judicial Council form.)

(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 February 29, 2024, I served true copies of the following document(s) described as
CASE MANAGEMENT STATEMENT on the interested parties in this action as follows:
6

7 SEE ATTACHED SERVICE LIST

8 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.
9
I declare under penalty of perjury under the laws of the State of California that the
10 foregoing is true and correct.

11 Executed on February 29, 2024, at Los Angeles, California.

12

13 /s/ Carla K. Rossi

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: [email protected] Fax: (310) 201-2110
[email protected] Email: [email protected]
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: [email protected] Email: [email protected]
11 [email protected] [email protected]
[email protected] [email protected]
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 John V. Berlinski

Daniel N. Csillag BIRD MARELLA, BOXER, WOLPERT,
17 MURPHY ROSEN LLP NESSIM, DROOKS, LINCENBERG &
100 Wilshire Blvd., Suite 1300 RHOW, P.C.
18 Santa Monica, CA 90401 1875 Century Park East, Suite 2300
Tel.: (310) 899-3300 Los Angeles, CA 90067
19 Fax: (310) 399-7201 Tel: (310) 201-2100
Email: [email protected] Fax: (310) 201-2110
20 [email protected] Email: [email protected]
21 Attorneys for Defendant and Cross-Complainant Attorneys for Plaintiffs William B. Pitt and
Angelina Jolie Mondo Bongo, LLC and Cross-Defendant
22
Warren Grant
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PROOF OF SERVICE