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Criminal

This document is a declaration by Julia B. Cherlow in support of the plaintiffs' reply regarding a motion to strike portions of Tenute del Mondo, B.V.'s cross-complaint. The plaintiffs offered to withdraw their motion in exchange for Tenute agreeing not to seek damages related to the allegations in question, but Tenute rejected this offer. The case is ongoing in the Superior Court of California, with a trial date not yet set.

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153 views7 pages

Criminal

This document is a declaration by Julia B. Cherlow in support of the plaintiffs' reply regarding a motion to strike portions of Tenute del Mondo, B.V.'s cross-complaint. The plaintiffs offered to withdraw their motion in exchange for Tenute agreeing not to seek damages related to the allegations in question, but Tenute rejected this offer. The case is ongoing in the Superior Court of California, with a trial date not yet set.

Uploaded by

HollyRuston
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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1 BIRD, MARELLA, RHOW,

LINCENBERG, DROOKS & NESSIM, LLP


2 John V. Berlinski (State Bar No. 208537)
[email protected]
3 Julia B. Cherlow (State Bar No. 290538)
[email protected]
4 1875 Century Park East, 23rd Floor
Los Angeles, CA 90067-2561
5 Telephone: (310) 201-2100
Facsimile: (310) 201-2110
6
WACHTELL, LIPTON, ROSEN & KATZ
7 Jonathan M. Moses (admitted pro hac vice)
Adam L. Goodman (admitted pro hac vice)
8 Won S. Shin (pro hac vice pending)
Jessica L. Layden (admitted pro hac vice)
9 Ioannis D. Drivas (admitted pro hac vice)
51 West 52nd Street
10 New York, NY 10019
Telephone: (212) 403-1000
11 Facsimile: (212) 403-2000

12 Attorneys for Plaintiffs and Cross-Defendants


William B. Pitt and Mondo Bongo, LLC
13

14 SUPERIOR COURT OF THE STATE OF CALIFORNIA


COUNTY OF LOS ANGELES, CENTRAL DISTRICT
15

16 WILLIAM B. PITT, an individual; and CASE NO. 22STCV06081


MONDO BONGO, LLC, a California limited
17 liability company, DECLARATION OF JULIA B.
CHERLOW IN SUPPORT OF
18 Plaintiffs, PLAINTIFFS’ REPLY IN SUPPORT OF
MOTION TO STRIKE PORTIONS OF
19 vs. TENUTE DEL MONDO, B.V.’S CROSS-
COMPLAINT FOR VIOLATION OF CAL.
20 ANGELINA JOLIE, et al., PENAL CODE § 496

21 Defendants. [Filed concurrently with Plaintiffs’ Reply in


Support of Motion to Strike]
22
AND RELATED CROSS-ACTIONS Judge: Hon. Lia Martin
23 Dept.: 3
Date: April 30, 2025
24 Time: 9:00 a.m.

25 Reservation ID: 814483696267


Action Filed: February 17, 2022
26 Trial Date: Not yet set

27

28

DECLARATION OF JULIA B. CHERLOW IN SUPPORT OF PLAINTIFFS’ REPLY IN SUPPORT OF


MOTION TO STRIKE PORTIONS OF TENUTE DEL MONDO, B.V.’S CROSS-COMPLAINT
1 DECLARATION OF JULIA B. CHERLOW

2 I, Julia B. Cherlow, declare as follows:

3 1. I am an active member of the Bar of the State of California and a Partner with Bird,

4 Marella, Rhow, Lincenberg, Drooks & Nessim, LLP, attorneys of record for Plaintiffs William B.

5 Pitt and Mondo Bongo, LLC in this action. I make this declaration based upon personal

6 knowledge and, if called upon to do so, I could and would so testify.

7 2. Following receipt of Tenute del Mondo B.V.’s (“Tenute”) Opposition to Plaintiffs’

8 Motion to Strike Portions of Tenute’s Cross-Complaint (“Motion to Strike”), on February 20,

9 2025, counsel for Plaintiffs sent an email to counsel for Tenute that offered to withdraw the

10 Motion to Strike in exchange for a stipulation that Tenute would “not seek damages in connection

11 with the events underlying the[] allegations [challenged in the Motion to Strike].” A true and

12 correct copy of this correspondence is attached hereto as Exhibit A.

13 3. On February 22, 2025, counsel for Plaintiffs received an email from counsel for

14 Tenute that rejected Plaintiffs’ offer without explanation. See Ex. A.

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

16 foregoing is true and correct, and that I executed this declaration on February 26, 2025, at Los

17 Angeles, California.

18

19
Julia B. Cherlow
20

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2
DECLARATION OF JULIA B. CHERLOW IN SUPPORT OF PLAINTIFFS’ REPLY IN SUPPORT OF
MOTION TO STRIKE PORTIONS OF TENUTE DEL MONDO, B.V.’S CROSS-COMPLAINT
EXHIBIT A

3
From: Jonathan Mooney
To: John V. Berlinski
Cc: Keith Hummel; Justin C. Clarke; Joe Tuffaha; Prashanth Chennakesavan; Julia B. Cherlow
Subject: RE: Pitt MTS Tenute Cross-Complaint
Date: Saturday, February 22, 2025 5:09:02 PM

**EXTERNAL EMAIL MESSAGE**

John,

Plaintiffs are welcome to withdraw their motion to strike, but Tenute is not willing to stipulate to
waive any rights in exchange for that withdrawal.

Jonathan Mooney
Cravath, Swaine & Moore LLP
375 Ninth Avenue | New York, NY 10001
T: 212-474-1460
[email protected]

From: "John V. Berlinski" <[email protected]>


Date: February 20, 2025 at 9:11:12 PM AST
To: Keith Hummel <[email protected]>, [email protected]
Cc: "Julia B. Cherlow" <[email protected]>
Subject: Pitt MTS Tenute Cross-Complaint

Keith and Joe,

The thrust of Tenute’s Opposition to Plaintiffs’ Motion to Strike Portions of Tenute’s Cross-Complaint
is that the allegations of conduct that Pitt seeks to strike should not be stricken because they are
relevant to Pitt’s alleged criminal intent, as opposed to any claim for damages. To reduce the
burdens on the Court, we would be willing to withdraw our MTS in return for Tenute stipulating that
it will not seek damages in connection with the events underlying these allegations. Please let us
know as soon as possible if Tenute agrees.

Thank you,

John V. Berlinski
Partner

Bird, Marella, Rhow, Lincenberg, Drooks & Nessim, LLP


1875 Century Park East, 23rd Floor, Los Angeles, California 90067-2561
www.birdmarella.com • 310.201.2100 • LinkedIn • [email protected]

4
This e-mail is confidential and may be privileged. Use or disclosure of it by anyone other than
a designated addressee is unauthorized. If you are not an intended recipient, please delete this
e-mail from the computer on which you received it.

5
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 am
5 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 26, 2025, I served the following document(s) described as DECLARATION
7 OF JULIA B. CHERLOW IN SUPPORT OF PLAINTIFFS’ REPLY IN SUPPORT OF
MOTION TO STRIKE PORTIONS OF TENUTE DEL MONDO, B.V.’S CROSS-
8 COMPLAINT on the interested parties in this action as follows:

9 SEE ATTACHED SERVICE LIST

10 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 addresses listed in
11 the Service List. I did not receive, within a reasonable time after the transmission, any electronic
message or other indication that the transmission was unsuccessful.
12
I declare under penalty of perjury under the laws of the State of California that the
13 foregoing is true and correct.

14
Executed on February 26, 2025, at Los Angeles, California.
15

16
/s/ Paula S. Yates
17

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6
PROOF OF SERVICE
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 Matthew Bernstein
100 Wilshire Boulevard, Suite 1300 KENDALL BRILL & KELLY LLP
5 Santa Monica, CA 90401 10100 Santa Monica Boulevard, Suite 1725
Telephone: (310) 899-3300 Los Angeles, CA 90067-4013
6 Email: [email protected] Telephone: (310) 556-2700
Email: [email protected] Email: [email protected]
7 Counsel for Defendant and Cross- Email: [email protected]
Complainant Angelina Jolie Email: [email protected]
8 Counsel appearing specially to challenge
jurisdiction on behalf of Cross-Defendants
9 Roland Venturini and Gary Bradbury

10 Joe Tuffaha Keith R. Hummel


Prashanth Chennakesavan Justin C. Clarke
11 TUFFAHA CHENNAKESAVAN LLP Jonathan Mooney
515 S. Flower Street, 18th Floor CRAVATH, SWAINE & MOORE LLP
12 Los Angeles, CA 90071 Worldwide Plaza
Telephone: (213) 449-5230 825 Eighth Avenue
13 Email: [email protected] New York, NY 10019
Email: [email protected] Telephone: (212) 474-1000
14 Counsel for Defendant and Cross- Email: [email protected]
Complainant Nouvel, LLC and Defendant Email: [email protected]
15 Tenute del Mondo B.V., and specially Email: [email protected]
appearing to challenge jurisdiction on behalf Counsel for Defendant and Cross-
16 of Defendants Yuri Shefler and Alexey Complainant Nouvel, LLC and Defendant
Oliynik Tenute del Mondo B.V., and specially
17 appearing to challenge jurisdiction on behalf
of Defendants Yuri Shefler and Alexey
18 Oliynik
19 Mark Drooks S. Gale Dick
Debbie Throckmorton Phoebe King
20 Assistant to Mark Drooks Randall Bryer
BIRD, MARELLA, RHOW, LINCENBERG, COHEN & GRESSER LLP
21 DROOKS & NESSIM, LLP 800 Third Avenue
1875 Century Park East, 23rd Floor New York, NY 10022
22 Los Angeles, CA 90067-2561 Telephone: (212) 707-7263
Telephone: 310 201-2100 Email: [email protected]
23 Email: [email protected] Email: [email protected]
Email: [email protected] Email: [email protected]
24 Counsel appearing specially to challenge Counsel appearing specially to challenge
jurisdiction on behalf of Cross-Defendants jurisdiction on behalf of Cross-Defendants
25 Marc-Olivier Perrin, SAS Miraval Provence, Marc-Olivier Perrin, SAS Miraval Provence,
Familles Perrin, SAS Petrichor, Vins et Familles Perrin, SAS Petrichor, Vins et
26 Domaines Perrin SC, SASU Le Domaine, and Domaines Perrin SC, SASU Le Domaine,
SAS Distilleries de la Riviera and SAS Distilleries de la Riviera
27

28

7
PROOF OF SERVICE

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