Superior Court of California, County of Los Angeles: (Check One)
Superior Court of California, County of Los Angeles: (Check One)
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name , State Bar number, and address):
FOR COURT USE ONLY
Paul D. Murphy (SB No. 159556) / Daniel N. Csillag (SB No. 266773)
MURPHY ROSEN LLP
100 Wilshire Blvd., Ste 1300
Santa Monica , California 90401
W Notice of Intent to Appear by Telephone, by (name): Paul D. Murphy and Daniel N. Csillag
INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided .
1. Party or parties (answer one):
a. w This statement is submitted by party (name): Defendant and Cross-Complainant Angelica Jolie
b. D 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) : February 17, 2022
b. w The cross-complaint, Jf any , was filed on (date): October 4 , 2022
3. Service (to be answered by plaintiffs and cross-complainants only)
a. [BJ Alt parties named in the complaint and cross-complaint 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. D 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 D
complaint m
cross-complaint
Ms. Jolie asserts one cause of action: Declaratory Relief
(Describe, including causes of action):
Page 1 of 5
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.}
Ms. Jolie contends that Plaintiffs' causes of action are frivolous, malicious, and part of a problematic pattern, and she has filed a
Cross-Complaint for declaratory relief seeking confirmation that Plaintiff Pitt's allegations that he and Ms. Jolie had a secret,
unwritten, unspoken contract for a consent right on the sale of their interests in the property is directly contrary to the written
record and, among other legal defects, violative of the Statute of Frauds and public policy.
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 CK] a jury trial D a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. CK] No trial dale has been set. This case wHI be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
The case is still not at issue, with several parties not served, and with expected demurrers and motions to quash service.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
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):
CK] 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):
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 Bankruptcy [TI Other (specify): Several parties have or are expected lo file motions to quash service.
Status:
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):
IT] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Ms. Jolie has is in the process of refiling her demurrer, and has reserved November 15, 2023. If not completely successful,
she intends to file a motion for summary judgment.
16. Discovery
a. D The party or parties have completed all discovery.
b. D The following discovery will be completed by the date specified (describe all anticipated discovery):
Description ~
c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
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):
b. CJ After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the fol owing
(specify) :
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternat ve 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 lime of
the case management conference, including the written authority of the party where required.
Paul D. Murphy
(TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY)
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MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142
[State] I declare under penalty of perjury under the laws of the State of
14 California that the above is true and correct.
15 Executed on July 18, 2023, at Santa Monica, California.
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Christina M. Garibay
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KATZ
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51 West 52nd Street
15 New York, NY 10019
T: (212) 403-1000 F: (212) 403-2000
16 [email protected]
17 [email protected]
[email protected]
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[email protected]
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[email protected]
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Joe H. Tuffaha Attorneys for Defendant Nouvel, LLC
21 Prashanth Chennakesavan and Appearing specially to challenge
LTL ATTORNEYS LLP jurisdiction on behalf of Defendant
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300 South Grand Avenue Suite 1400 Tenute del Mondo B.V.
23 Los Angeles, CA 90071
T: (213) 612-8900 F: (213) 612-3773
24 [email protected]
25 [email protected]
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Mark T. Drooks
7 BIRD MARELLA, BOXER, WOLPERT, Appearing specially to challenge
NESSIM, DROOKS, LINCENBERG & jurisdiction on behalf of Cross-
8 Defendants Marc-Olivier Perrin, SAS
RHOW, P.C.
9 1875 Century Park East, Suite 2300 Miraval Provence, and Familles
Los Angeles, CA 90067 Perrin
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Tel: (212) 957-7600
11 [email protected]
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TELEPHONE 310-899-3300; FACSIMILE 310-399-7201
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MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142
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