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CMST

This case management statement was submitted by SAS Miraval Studios, appearing specially to challenge jurisdiction. Nouvel, LLC brings cross-claims against SAS Miraval Studios regarding the assets and management of Chateau Miraval and Quimicum in France. Nouvel alleges that SAS Miraval Studios and other cross-defendants spent Chateau Miraval's money to benefit a vanity project of plaintiff William Pitt, misappropriated Chateau Miraval's intellectual property, and diverted profits that should have been split evenly between the companies. SAS Miraval Studios denies the allegations and requests a jury trial if its motion to quash for lack of jurisdiction is denied.

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0% found this document useful (0 votes)
43 views8 pages

CMST

This case management statement was submitted by SAS Miraval Studios, appearing specially to challenge jurisdiction. Nouvel, LLC brings cross-claims against SAS Miraval Studios regarding the assets and management of Chateau Miraval and Quimicum in France. Nouvel alleges that SAS Miraval Studios and other cross-defendants spent Chateau Miraval's money to benefit a vanity project of plaintiff William Pitt, misappropriated Chateau Miraval's intellectual property, and diverted profits that should have been split evenly between the companies. SAS Miraval Studios denies the allegations and requests a jury trial if its motion to quash for lack of jurisdiction is denied.

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HollyRuston
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
You are on page 1/ 8

CM-110

ATTORNEY OR PARTY WITHOUT ATTORNEY 208537


STATE BAR NUMBER: FOR COURT USE ONLY
NAME: John V. Berlinski
FIRM NAME: BIRD, MARELLA, RHOW, LINCENBERG, DROOKS & NESSIM, LLP
STREET ADDRESS: 1875 Century Park East, 23rd Floor
CITY: Los Angeles STATE: CA ZIP CODE: 90067
TELEPHONE NO.: (310) 201-2100 FAX NO.: (310) 201-2100
EMAIL ADDRESS: [email protected]
ATTORNEY FOR (name): SAS Miraval Studios, appearing specially to challenge jurisdiction

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: 9:00 a.m. 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): SAS Miraval Studios, appearing specially to challenge jurisdiction
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):
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, LLC brings cross-claims against specially appearing SAS Miraval Studios regarding the assets and management of
Chateau Miraval and Quimicum. Claims: (2, 5) Tortious Interference (TI) with Prosp. Econ. Advantage; (7) Trespass to
Chattels; (10) Aiding and Abetting TI with Prosp. Econ. Advantage; (11) Civil Conspiracy to TI with Prosp. Econ. Advantage.
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):
Specially appearing Cross-Defendant SAS Miraval Studios limits this description to the allegations against it: Nouvel alleges
that SAS Miraval Studios and other Cross-Defendants spent Chateau Miraval's money to benefit a Pitt vanity project,
misappropriated Chateau Miraval's intellectual property, diverted profits that should have been split evenly between Nouvel,
LLC and Mondo Bongo, LLC, and "intermeddled with the quality or value of Nouvel's Quimicum shares."
(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 its motion to quash is denied, specially appearing Cross-Defendant SAS Miraval Studios 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: John V. Berlinski; Julia B. Cherlow
b. Firm: BIRD, MARELLA, RHOW, LINCENBERG, DROOKS & NESSIM, LLP
c. Address: 1875 Century Park East, 23rd Floor, Los Angeles, CA 90067
d. Telephone number: (310) 201-2100 f. Fax number: (310) 201-2100
e. Email address: [email protected] g. Party represented: SAS Miraval Studios, spec. appearing
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): SAS Miraval Studios has moved to quash on jurisdictional grounds.
Status: Hearing on pending motion August 30, 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):
Specially appearing Cross-Defendant Miraval Studios has moved to quash service of the FACC for lack of personal
jurisdiction. 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 Cross-Defendant Miraval Studios is 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):
Specially appearing Cross-Defendant SAS Miraval Studios has not met and conferred with the other parties, as it has
moved to quash service. It has submitted this statement per the instructions of the Court at the December 11, 2023
hearing. This statement does not constitute its consent to this Court’s jurisdiction or a waiver of its 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

John V. Berlinski
(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 Pitt v. Jolie
Case No. 22STCV06081
3
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
4
At the time of service, I was over 18 years of age and not a party to this action. I
5 am employed in the County of Los Angeles, State of California. My business address is
1875 Century Park East, 23rd Floor, Los Angeles, CA 90067-2561.
6
On February 29, 2024, I served the following document(s) described as CASE
7 MANAGEMENT STATEMENT on the interested parties in this action as follows:
8 SEE ATTACHED SERVICE LIST
9 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s)
to be sent from e-mail address [email protected] to the persons at the e-mail
10 addresses listed in the Service List. I did not receive, within a reasonable time after the
transmission, any electronic message or other indication that the transmission was
11 unsuccessful.
12 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
13
Executed on February 29, 2024, at Los Angeles, California.
14
15
16
Cheryl J. Cinnater
17
18
19
20
21
22
23
24
25
26
27
28
1 SERVICE LIST
Pitt v. Jolie
2 Case No. 22STCV06081
3 Paul D. Murphy Laura W. Brill
Daniel N. Csillag Daniel Barlava
4 MURPHY ROSEN LLP KENDALL BRILL & KELLY LLP
100 Wilshire Boulevard, Suite 1300 10100 Santa Monica Boulevard, Suite 1725
5 Santa Monica, CA 90401 Los Angeles, CA 90067-4013
Telephone: (310) 899-3300 Telephone: (310) 556-2700
6 Email: [email protected] Email: [email protected]
Email: [email protected] Email: [email protected]
7 Counsel for Defendant and Cross- Counsel appearing specially to challenge
Complainant Angelina Jolie jurisdiction on behalf of Cross-
8 Defendants Roland Venturini and Gary
Bradbury
9
Joe Tuffaha Keith R. Hummel
10 Prashanth Chennakesavan Justin C. Clarke
LTL ATTORNEYS LLP Jonathan Mooney
11 300 South Grand Avenue, Suite 1400 CRAVATH, SWAINE & MOORE LLP
Los Angeles, CA 90071 Worldwide Plaza
12 Telephone: (213) 612-8900 825 Eighth Avenue
Email: [email protected] New York, NY 10019
13 Email: Telephone: (212) 474-1000
[email protected] Email: [email protected]
14 Counsel for Defendant and Cross- Email: [email protected]
Complainant Nouvel, LLC and Email: [email protected]
15 Defendant Tenute del Mondo B.V. and Counsel for Defendant and Cross-
specially appearing to challenge Complainant Nouvel, LLC and
16 jurisdiction on behalf of Defendants Yuri Defendant Tenute del Mondo B.V. and
Shefler, Alexey Olivnik and SPI Group specially appearing to challenge
17 Holding, Ltd. jurisdiction on behalf of Defendants Yuri
Shefler, Alexey Olivnik and SPI Group
18 Holding, Ltd.
19 Mark Drooks S. Gale Dick
BIRD, MARELLA, RHOW, Phoebe King
20 LINCENBERG, DROOKS & NESSIM, Randall Bryer
LLP COHEN & GRESSER LLP
21 1875 Century Park East, 23rd Floor 800 Third Avenue
Los Angeles, CA 90067-2561 New York, NY 10022
22 Telephone: 310 201-2100 Telephone: (212) 707-7263
Email: [email protected] Email: [email protected]
23 Counsel appearing specially to challenge Email: [email protected]
jurisdiction on behalf of Cross- Email: [email protected]
24 Defendants Marc-Olivier Perrin, SAS Counsel appearing specially to challenge
Miraval Provence, Familles Perrin, SAS jurisdiction on behalf of Cross-
25 Petrichor, Vins et Domaines Perrin SC, Defendants Marc-Olivier Perrin, SAS
SASU Le Domaine, and SAS Distilleries Miraval Provence, Familles Perrin, SAS
26 de la Riviera Petrichor, Vins et Domaines Perrin SC,
SASU Le Domaine, and SAS Distilleries
27 de la Riviera
28

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