Dec NOUX

1 KEITH R.
HUMMEL (admitted pro hac vice)

khummel@cravath.com
2 JUSTIN C. CLARKE (admitted pro hac vice)
jcclarke@cravath.com
3
JONATHAN MOONEY (admitted pro hac vice)
4 jmooney@cravath.com
CRAVATH, SWAINE & MOORE LLP
5 825 Eighth Avenue
New York, NY 10019
6 Telephone: (212) 474-1000
Facsimile: (212) 474-3700
7
8 JOE H. TUFFAHA (Bar No. 253723)

joe.tuffaha@ltlattorneys.com
9 PRASHANTH CHENNAKESAVAN (Bar No. 284022)
prashanth.chennakesavan@ltlattorneys.com
10 LTL ATTORNEYS LLP
11 300 South Grand Avenue, Suite 3950
Los Angeles, CA 90071-3426
12 Telephone: (213) 612-8900
Facsimile: (213) 612-3773
13
Attorneys for Defendant and
14 Cross-Complainant Nouvel, LLC
15
SUPERIOR COURT OF THE STATE OF CALIFORNIA
16
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
17
WILLIAM B. PITT, an individual, and Case No. 22STCV06081
18
MONDO BONGO, LLC, a California
limited liability company, DECLARATION OF JOE TUFFAHA
19
IN SUPPORT OF DEFENDANT AND
20 Plaintiffs, CROSS-COMPLAINANT NOUVEL,
LLC’S EX PARTE APPLICATION
21 vs. FOR AN ORDER CONTINUING (1)
THE MAY 15, 2024 HEARING ON
22 ANGELINA JOLIE, an individual, and CROSS-DEFENDANTS MARC-
NOUVEL, LLC, a California limited OLIVER PERRIN, SAS FAMILLES
23 liability company, YURI SHEFLER, an PERRIN, AND SAS MIRAVAL
24 individual, ALEXEY OLIYNIK, an PROVENCE’S MOTION TO QUASH
individual, SPI GROUP HOLDING FOR LACK OF PERSONAL
25 LIMITED, a Cyprus private limited JURISDICTION AND (2) THE
company, and TENUTE DEL MONDO DEADLINE FOR NOUVEL, LLC TO
26 B.V., a Netherlands private limited FILE ITS OPPOSITION TO THE
company, MOTION TO QUASH
27
Defendants.
28
DECLARATION OF JOE TUFFAHA

1 NOUVEL, LLC, a California limited Filed concurrently with Ex Parte
liability company, Application and Proposed Order
2
Cross-Complainant,
Judge: Hon. Lia Martin
3 vs. Dept.: 3
4 WILLIAM B. PITT, an individual, Date: April 17, 2024
MONDO BONGO, LLC, a California Time: 8:30 A.M.
5 limited liability company, MARC-
Action Filed: February 17, 2022
OLIVIER PERRIN, an individual, SAS
6 Trial Date: None set.
MIRAVAL PROVENCE, a French limited
7 liability company, SAS FAMILLES
PERRIN, a French limited liability
8 company, ROLAND VENTURINI, an
individual, GARY BRADBURY, an
9 individual, WARREN GRANT, an
10 individual, SAS PETRICHOR, a French
limited liability company; VINS ET
11 DOMAINES PERRIN SC, a French
company; SAS MIRAVAL STUDIOS, a
12 French limited liability company; SASU
LE DOMAINE, a French limited liability
13 company; SAS DISTILLERIES DE LA
14 RIVIERA, a French limited liability
company, and ROES 1-10.
15
Cross-Defendants.
16
17
18
19
20
21
22
23
24
25
26
27
28
2
1 I, Joe Tuffaha, declare as follows:
2 1. I am an attorney at the law firm of LTL Attorneys, LLP and counsel for Defendant
3 and Cross-Complainant Nouvel, LLC (“Nouvel”) in the above-captioned action. I am a member
4 in good standing of the State Bar of California. I have personal knowledge of the facts and
5 circumstances set forth in this declaration and, if called as a witness, I could and would
6 competently testify to such facts under oath.
7 2. I submit this declaration in support of Nouvel’s ex parte application for an order
8 continuing (1) the May 15, 2024 hearing on Cross-Defendants Marc-Oliver Perrin, SAS Familles
9 Perrin, and SAS Miraval Provence’s (the “Perrin Cross-Defendants”) motion to quash for lack of
10 personal jurisdiction; and (2) the deadline for Nouvel to file its opposition to the Perrin Cross-
11 Defendants’ motion to quash.
12 3. Nouvel filed its First Amended Cross-Complaint (“FACC”) on August 9, 2023.
13 The Perrin Cross-Defendants moved to quash Nouvel’s FACC on September 20, 2023. A true and
14 correct copy of the Perrin Cross-Defendants’ motion to quash is attached hereto as Exhibit 1.
15 4. Nouvel served its First Set of Requests for Production Re: Jurisdiction on the Perrin
16 Cross-Defendants on September 28, 2023. True and correct copies of Nouvel’s September 28,
17 2023 jurisdictional discovery requests are attached hereto as Exhibit 2.
18 5. Nouvel’s requests seek discovery concerning the Perrin Cross-Defendants’ contacts
19 with California that relate and give rise to Nouvel’s claims, including: (1) documents concerning
20 the Perrin Cross-Defendants’ actions aimed at California to exclude Nouvel from the governance
21 of its sole investment, which they exploited to plunder the assets of that investment; (2) documents
22 concerning the Perrin Cross-Defendants’ contracts with parties in California that relate to
23 Nouvel’s claims against them; and (3) documents concerning the Perrin Cross-Defendants’
24 successful effort aimed at California to assume control of the key revenue-generating asset within
25 Nouvel’s sole investment. See Exhibit 2.
26 6. On October 30, 2023, the Perrin Cross-Defendants served responses and objections
27 to Nouvel’s jurisdictional discovery requests, objecting on the basis that, among other things,
28 French Law No. 68-678 of July 26, 1968 (the “French Blocking Statute”) prohibits them from
3
1 providing discovery except through the Hague Evidence Convention. The parties met and
2 conferred and were able to agree on the scope of discovery for many requests, but reached an
3 impasse on the objection based on the French Blocking Statute and on the scope of certain RFPs.
4 During meet and confers, counsel for the Perrin Cross-Defendants stated to counsel for Nouvel
5 that in the event the Court ordered discovery to proceed through the Hague Convention, the Perrin
6 Cross-Defendants would work collaboratively with Nouvel on a schedule that would permit
7 Nouvel to obtain the discovery in advance of a hearing on the motion to quash.
8 7. On January 22, 2024, Nouvel moved to compel the production of complete
9 responses to Nouvel’s jurisdictional discovery requests and to overrule the Perrin Cross-
10 Defendants’ objection based on the French Blocking Statute and their position that they will
11 produce discovery only in response to a letter of request under the Hague Evidence Convention.
12 8. The Perrin Cross-Defendants filed an opposition to Nouvel’s motion to compel. A
13 true and correct copy of the Perrin Cross-Defendants’ opposition is attached hereto as Exhibit 3.
14 9. In their opposition, the Perrin Cross-Defendants argued that the jurisdictional
15 discovery as to them should proceed through the procedures set forth in the Hague Convention.
16 See Exhibit 3. In doing so, the Perrin Cross-Defendants represented to the Court that the Hague
17 Convention provided an “alternative means of securing” (id.) jurisdictional discovery and that
18 Nouvel could “obtain timely and appropriately tailored jurisdictional discovery through the Hague
19 Convention.” (Id. at 6 (emphasis added)). The Perrin Cross-Defendants emphasized that the
20 parties’ dispute regarding how to proceed was “over the proper procedure for jurisdictional
21 discovery,” (id. at 2 (emphasis in original)), and provided assurance that the Hague Convention
22 provides “amply suitable procedures,” (id. at 9), for conducting the at-issue discovery which
23 Nouvel “should be required to at least try,” (id.). The Perrin Cross-Defendants affirmatively
24 stated that they “assert[] without equivocation that [they] will comply with Hague procedures.”
25 (Id.)
26 10. On March 4, 2024, the Court considered the parties’ arguments and issued its ruling
27 on Nouvel’s motion to compel. A true and correct copy of the Notice of Ruling is attached hereto
28 as Exhibit 4.
-4-
1 11. The Court directed that “Nouvel should proceed with jurisdictional discovery under
2 the Hague Convention,” and explicitly stated that “the information requested [by Nouvel] is
3 fundamental and important to the litigation.” (Id. at 5.) The Court further held that “Nouvel
4 should be able to obtain what is necessary to oppose the motion to quash or substantially the same
5 evidence under the Hague Convention.” (Id. at 8.)
6 12. Subsequent to the Court’s ruling, Nouvel reached out to the Perrin Cross-
7 Defendants to work cooperatively in preparing a draft letter of request for international judicial
8 assistance to obtain jurisdictional discovery pursuant to the Hague Convention.
9 13. Concurrently, given the time that will be required for issuance of the letter of
10 request, its execution by French authorities, the Perrin Cross-Defendants’ production of
11 documents, and Nouvel’s review of those documents, Nouvel asked the Perrin Cross-Defendants
12 if they would stipulate to continue the motion to quash hearing, currently scheduled for May 15,
13 2024, until after Nouvel receives jurisdictional discovery from the Perrin Cross-Defendants.
14 Without a continuance, Nouvel’s opposition to the motion to quash would be due and the hearing
15 on the motion to quash would be held prior to the production of any jurisdictional discovery from
16 the Perrin Cross-Defendants.
17 14. The Perrin Cross-Defendants refused to stipulate to a continuance, taking the
18 position that Nouvel should be required to brief and argue their motion to quash without obtaining
19 any discovery at all under the Hague Convention.
20 15. During a meet and confer with counsel for Nouvel, counsel for the Perrin Cross-
21 Defendants offered three reasons why they had changed their position and would insist that the
22 parties brief and argue, and the Court hear, their motion to quash in the absence of jurisdictional
23 discovery.
24 16. First, they argued that “the ground has shifted” because the Court granted motions
25 to quash filed by Defendants SPI Group Holding Limited and Yuri Shefler. But those motions
26 were granted only after SPI Group Holding Limited, Shefler, and the other foreign defendants
27 produced extensive documents in jurisdictional discovery. SPI Group Holding Limited, Shefler,
28 and the other foreign defendants produced 1691 documents in jurisdictional discovery. In
-5-
1 contrast, the Perrin Cross-Defendants have not produced a single document to Nouvel in
2 jurisdictional discovery.
3 17. Second, the Perrin Cross-Defendants argue they should not be required to produce
4 jurisdictional discovery in advance of a hearing on their motion to quash because Nouvel did not
5 share a draft letter of request under the Hague Convention and motion for the issuance thereof
6 until the third week after the Court ruled on its motion to compel. But counsel for Nouvel argued
7 five hearings on dispositive motions in this action in the intervening period and acted as diligently
8 as possible under the circumstances.
9 18. Third, the Perrin Cross-Defendants argue that even if Nouvel obtains the discovery
10 sought, it can never satisfy its burden to show that this Court may exercise jurisdiction over them,
11 especially in light of the allegations in the First Amended Cross-Complaint.
12 19. By email on April 8, 2024, Nouvel informed the Perrin Cross-Defendants that if
13 they maintain their unreasonable position, Nouvel will be forced to move ex parte to continue the
14 hearing date and the briefing schedule on their motion to quash until after Nouvel obtains
15 jurisdictional discovery under the Hague Convention.
16 20. A true and correct copy of the parties’ email correspondence, referenced in
17 Paragraphs 12-14 and 19, is attached hereto as Exhibit 5.
18 21. Good cause exists to grant this application because this Court has already ordered
19 Nouvel to “proceed with jurisdictional discovery under the Hague Convention” against the Perrin-
20 Cross-Defendants. See Exhibit 4. The Court has also already deemed the discovery sought
21 “fundamental and important to the litigation” and held that “Nouvel should be able to obtain what
22 is necessary to oppose the motion to quash or substantially the same evidence under the Hague
23 Convention.” (Id.) Despite the Court’s ruling, the Perrin Cross-Defendants have refused to
24 stipulate to a continuance of the hearing date on the motion to quash to allow the time needed for
25 execution of a letter of request under the Hague Convention and have taken the plainly
26 unreasonable position that the parties should be required to brief and to argue their motion to
27 quash without any jurisdiction discovery at all under the Hague Convention. To conserve the
28 parties’ and the Court’s resources, this Court should order a continuance to allow sufficient time
-6-
1 for the execution of a letter of request under the Hague Convention and the production of
2 jurisdictional discovery to Nouvel.
3 22. Attached hereto as Exhibit 6 is a true and correct copy of a document titled
4 “France – Central Authority (Art. 2) and practical information” from the website of the Hague
5 Conference on Private International Law.
6 23. On April 16, at 9:17 AM, counsel for Nouvel gave all counsel of record for parties
7 that have appeared in this action notice via email of this ex parte application; the time, date, and
8 location of the hearing; and the relief requested. As of the execution of this declaration, counsel
9 for Nouvel have not received any responses. Counsel for the Perrin Cross-Defendants previously
10 informed Nouvel’s counsel that they will oppose the ex parte application. A true and correct copy
11 of the email correspondence discussed in this paragraph is attached hereto as Exhibit 7.
12 24. It is my understanding that Plaintiffs and Cross-Defendants William B. Pitt and
13 Mondo Bongo, LLC and Cross-Defendant Warren Grant, are represented by William Savitt,
14 Jonathan M. Moses, Sarah K. Eddy, Adam L. Goodman, Jessica L. Allen, and Remy Grosbard of
15 Wachtell, Lipton, Rosen, & Katz, 51 West 52nd Street, New York, NY 10019, Tel: (212) 403-
16 1000, Fax: (212) 403-2000, Email: wdsavitt@wlrk.com, jmmoses@wlrk.com, skeddy@wlrk.com,
17 algoodman@wlrk.com, jlallen@wlrk.com, rkgrosbard@wlrk.com; and John V. Berlinski of Bird,
18 Marella, Rhow, Lincenberg, Drooks & Nessim, LLP, 1875 Century Park East, 23rd Floor, Los
19 Angeles, CA 90067-2561, Tel: (310) 201-2100, Fax: (310) 201-2110, Email:
20 jberlinski@birdmarella.com, BTeachout@birdmarella.com, jcherlow@birdmarella.com,
21 fwang@birdmarella.com, skosmacher@birdmarella.com, KMeyer@birdmarella.com,
22 PYates@birdmarella.com, Rattarson@birdmarella.com.
23 25. It is my understanding that Cross-Defendants Roland Venturini and Gary Bradbury
24 are represented by William Savitt, Jonathan M. Moses, Sarah K. Eddy, Adam L. Goodman,
25 Jessica L. Allen, and Remy Grosbard of Wachtell, Lipton, Rosen, & Katz, 51 West 52nd Street,
26 New York, NY 10019, Tel: (212) 403-1000, Fax: (212) 403-2000, Email: wdsavitt@wlrk.com,
27 jmmoses@wlrk.com, skeddy@wlrk.com, algoodman@wlrk.com, jlallen@wlrk.com,
28 rkgrosbard@wlrk.com; and Laura Brill and Katelyn Kuwata of Kendall Brill & Kelly LLP, 10100
-7-
1 Santa Monica Blvd., Suite 1725, Los Angeles, CA 90067, Tel: (310) 556-2700, Fax: (310) 556-
2 2705, Email: lbrill@kbkfirm.com, kkuwata@kbkfirm.com.
3 26. It is my understanding that Cross-Defendants Marc-Olivier Perrin, SAS Miraval
4 Provence, SAS Familles Perrin, SAS Petrichor, Vins Et Domaines Perrin SC, SASU Le Domaine,
5 and SAS Distilleries de la Riviera are represented by Mark T. Drooks from Bird, Marella, Rhow,
6 Lincenberg, Drooks & Nessim, LLP, 1875 Century Park East, 23rd Floor, Los Angeles, CA
7 90067-2561, Tel: (310) 201-2100, Email: mdrooks@birdmarella.com; and S. Gale Dick, Randall
8 W. Bryer, and Phoebe H. King of Cohen & Gresser LLP, 800 Third Avenue, New York, NY
9 10022, Tel: (212) 957-7600, Email: sgdick@cohengresser.com, rbryer@cohengresser.com,
10 pking@cohengresser.com.
11 27. It is my understanding that Cross-Defendants SAS Miraval Studios is represented
12 by Mark T. Drooks from Bird, Marella, Rhow, Lincenberg, Drooks & Nessim, LLP, 1875 Century
13 Park East, 23rd Floor, Los Angeles, CA 90067-2561, Tel: (310) 201-2100, Email:
14 mdrooks@birdmarella.com.
15 28. It is my understanding that Defendant and Cross-Complainant Angelina Jolie is
16 represented by Paul D. Murphy and Daniel N. Csillag of Murphy Rosen LLP, 100 Wilshire Blvd.,
17 Suite 1300, Santa Monica, CA 90401, Tel: (310) 899-3300, Fax: (310) 399-7201, Email:
18 pmurphy@murphyrosen.com, dcsillag@murphyrosen.com.
19
20 I declare under penalty of perjury under the laws of the State of California that the
21 foregoing is true and correct.
22 Executed on April 16, 2024 in Los Angeles, California, USA.
23
24 /s/ Joe Tuffaha

Joe Tuffaha
25
26
27
28
-8-
EXHIBIT 1
1 Mark T. Drooks - State Bar No. 123561
mdrooks@birdmarella.com
2 BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
DROOKS, LINCENBERG & RHOW, P.C.
3 1875 Century Park East, 23rd Floor
Los Angeles, California 90067-2561
4 Telephone: (310) 201-2100
5 S. Gale Dick (admitted pro hac vice)
Phoebe H. King (admitted pro hac vice)
6 Randall W. Bryer (admitted pro hac vice)
COHEN & GRESSER LLP
7 800 Third Avenue
New York, NY 10022
8 Telephone: (212) 957-7600
9 Attorneys appearing specially to challenge jurisdiction
on behalf of Cross-Defendants Marc-Olivier Perrin,
10 SAS Miraval Provence and SAS Familles Perrin
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
13 WILLIAM B. PITT, an individual, and CASE NO. 22STCV06081

MONDO BONGO, LLC, a California limited
14 liability company, SPECIALLY APPEARING CROSS-
DEFENDANTS MARC-OLIVIER
15 PERRIN, SAS MIRAVAL PROVENCE
Plaintiffs, AND SAS FAMILLES PERRIN’S
16 MOTION TO:
vs.
17 ANGELINA JOLIE, et. al., (1) QUASH FOR LACK OF PERSONAL
JURISDICTION; AND
18 Defendants.
(2) DISMISS OR STAY FOR FORUM
19 NON CONVENIENS
AND RELATED CROSS-ACTIONS
20
[Filed Concurrently with Declaration of Marc-
21 Olivier Perrin and [Proposed] Order]
22 Date: December 15, 2023

Time: 9:00 a.m.
23 Dept.: 16
RESERVATION NO.: 257294386007
24
Assigned to Hon. Lia Martin
25 Dept. 16
26 Action Filed: February 17, 2022
27
28
CROSS-DEFENDANTS’ MOTION TO QUASH

1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
2 PLEASE TAKE NOTICE that on December 15, 2023 at 9:00 a.m., or as soon thereafter
3 as this matter may be heard, in Courtroom 16, located at 111 North Hill Street, Los Angeles,
4 California 90012, Cross-Defendants Marc-Olivier Perrin, SAS Miraval Provence and SAS
5 Familles Perrin will and hereby do move this Court for an order quashing service of the Summons
6 and First Amended Cross-Complaint filed by Cross-Plaintiff Nouvel, LLC, on the grounds that
7 Cross-Defendants Marc-Olivier Perrin, SAS Miraval Provence and SAS Familles Perrin are not
8 subject to personal jurisdiction in this Court or, in the alternative, severing the claims against
9 Marc-Olivier Perrin, SAS Miraval Provence and SAS Familles Perrin and staying or dismissing
10 the claims under the doctrine of forum non conveniens.
11 This motion is made pursuant to California Code of Civil Procedure sections 410.10,
12 410.30(a), 418.10(a), and 1048(b), and the Due Process Clauses of the California and United
13 States Constitutions, on the grounds that this Court lacks personal jurisdiction over Marc-Olivier
14 Perrin, SAS Miraval Provence and SAS Familles Perrin and, alternatively, that California is an
15 inconvenient forum in which to litigate Nouvel’s claims.
16 This motion is based on this Notice of Motion, the accompanying Memorandum of Points
17 and Authorities, declaration of Marc-Oliver Perrin filed concurrently herewith, the pleadings and
18 papers on file in this matter, and such other matters as may be presented to the Court at the
19 hearing.
20 DATED: September 20, 2023 Mark T. Drooks
BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
21 DROOKS, LINCENBERG & RHOW, P.C.
23 Phoebe H. King (admitted pro hac vice)
Randall W. Bryer (admitted pro hac vice)
24 COHEN & GRESSER LLP
25 By: /s/ Mark T. Drooks

26 Mark T. Drooks
Attorneys appearing specially to challenge
27 jurisdiction on behalf of Cross-Defendants Marc-
Olivier Perrin, SAS Miraval Provence and SAS
28 Familles Perrin
2
1 TABLE OF CONTENTS
Page
2
MEMORANDUM OF POINTS AND AUTHORITIES ...................................................................7
3
I. INTRODUCTION ..................................................................................................................7
4
II. BACKGROUND ....................................................................................................................8
5
A. Procedural History ......................................................................................................8
6
B. Jurisdictional Allegations and Facts .........................................................................10
7
III. ARGUMENT .......................................................................................................................11
8
A. This Court Lacks Personal Jurisdiction over the French Cross-Defendants. ...........11
9
1. The French Cross-Defendants Are Not Subject to General
10 Jurisdiction in California. .............................................................................11
11 2. The French Cross-Defendants Are Not Subject to Specific

Jurisdiction in California. .............................................................................12
12
a. The French Cross-Defendants Did Not Direct Activity to
13 California or Purposefully Avail Themselves of California’s
Forum Benefits. ................................................................................13
14
b. Nouvel’s Claims Do Not Arise Out of or Relate to the
15 French Cross-Defendants’ Contacts with California........................17
16 c. The Court’s Exercise of Jurisdiction Over the French Cross-

Defendants Would Not Be Reasonable. ...........................................18
17
B. In the Alternative, the Court Should Sever the French Cross-Defendants and
18 Dismiss or Stay Any Action Against These Parties on Forum Non
Conveniens Grounds. ...............................................................................................19
19
1. France Is an Adequate Alternative Forum. ..................................................20
20
2. The Private and Public Interest Factors Support a Dismissal or Stay. .........21
21
a. The Private Interest Factors Favor Dismissal. .................................21
22
b. The Public Interest Factors Favor Dismissal....................................22
23
3. Nouvel’s Choice of Forum Is Entitled to Minimal Deference. ....................22
24
IV. CONCLUSION ....................................................................................................................23
25
26
27
28
3
1 TABLE OF AUTHORITIES
2 Page(s)
3 Cases
4 Archibald v. Cinerama Hotels,
5 15 Cal. 3d 853 (1976) .............................................................................................................. 23
6 In re Auto. Antitrust Cases I & II,

135 Cal. App. 4th 100 (2005) ................................................................................ 11, 12, 15, 16
7
Axiom Foods, Inc. v. Acerchem Int’l, Inc.,
8 874 F.3d 1064 (9th Cir. 2017) ..................................................................................... 12, 13, 15
9 Behrens v. Arconic, Inc.,
No. 19-CV-2664, 2020 WL 1250956 (E.D. Pa. Mar. 13, 2020) ............................................. 22
10
11 Boaz v. Boyle & Co.,
40 Cal. App. 4th 700 (1995) .............................................................................................. 20, 22
12
Burdick v. Superior Ct.,
13 233 Cal. App. 4th 8 (2015) .......................................................................................... 13, 14, 16
14 Cal-State Bus. Prod. & Servs., Inc. v. Ricoh,
12 Cal. App. 4th 1666 (1993), as modified (Feb. 4, 1993) ..................................................... 20
15
Daimler AG v. Bauman,
16
571 U.S. 117 (2014) ................................................................................................................ 11
17
Dangoor v. Peterson’s Stampede Dodge Chrysler Jeep, LLC,
18 No. 2:19-CV-01793, 2019 WL 6357252 (C.D. Cal. Aug. 8, 2019) .................................. 14, 15
19 David L. v. Superior Ct.,

29 Cal. App. 5th 359 (2018), as modified (Dec. 17, 2018) ................................... 12, 13, 15, 16
20
David v. Medtronic, Inc.,
21 237 Cal. App. 4th 734 (2015), as modified (June 26, 2015) ............................................. 19, 20
22
Elite Semiconductor, Inc. v. Anchor Semiconductor, Inc.,
23 No. 5:20-CV-06846, 2021 WL 3037701 (N.D. Cal. July 19, 2021) ....................................... 16
24 Farina v. SAVWCL III, LLC,

50 Cal. App. 5th 286 ......................................................................................................... 16, 17
25
Free Conferencing Corp. v. T-Mobile US, Inc.,
26 No. 2:14-CV-07113, 2014 WL 7404600 (C.D. Cal. Dec. 30, 2014) ...................................... 15
27
Gambra v. Int’l Lease Fin. Corp.,
28 377 F. Supp. 2d 810 (C.D. Cal. 2005) ..................................................................................... 20
4
1 Goodyear Dunlop Tires Operations, S.A. v. Brown,
564 U.S. 915 (2011) ................................................................................................................ 11
2
Kashef v. BNP Paribas S.A.,
3 No. 16-CV-3228, 2022 WL 1617489 (S.D.N.Y. May 23, 2022) ............................................ 22
4 Klein v. Superior Ct.,
5 198 Cal. App. 3d 894 (1988) ................................................................................................... 23
6 LG Chem, Ltd. v. Superior Ct. of San Diego Cnty.,

80 Cal. App. 5th 348 (2022), review denied (Oct. 12, 2022) .................................................. 17
7
Love v. The Mail on Sunday,
8 No. 05-CV-7798, 2006 WL 4046166 (C.D. Cal. Mar. 21, 2006) ........................................... 18
9 Nat’l Football League v. Fireman’s Fund Ins. Co.,
10 216 Cal. App. 4th 902 (2013) ............................................................................................ 20, 23
11 In re Nouvel, LLC,
22-MC-00004, 2022 WL 2901715 (C.D. Cal. July 22, 2022) ................................................ 22
12
Peacock v. Willis,
13 No. 06-CV-432, 2006 WL 3060134 (E.D. Cal. Oct. 27, 2006) .............................................. 15
14 Picot v. Weston,
780 F.3d 1206 (9th Cir. 2015) ................................................................................................. 13
15
16 Proofpoint, Inc. v. Vade Secure, Inc.,
No. 19-CV-04238, 2020 WL 504962 (N.D. Cal. Jan. 31, 2020) ............................................ 21
17
Rivelli v. Hemm,
18 67 Cal. App. 5th 380 (2021) ........................................................................................ 11, 12, 17
19 Santa Barbara Smokehouse, Inc. v. AquaChile, Inc.,
No. 19-CV-10733, 2020 WL 13328094 (C.D. Cal. July 7, 2020) .................................... 15, 16
20
21 Schwarzenegger v. Fred Martin Motor Co.,
374 F.3d 797 (9th Cir. 2004) ............................................................................................. 13, 18
22
Sec. Alarm Fin. Enterprises, L.P. v. Nebel,
23 200 F. Supp. 3d 976 (N.D. Cal. 2016) .................................................................................... 14
24 St. Paul Fire and Marine Ins. Co. v. AmerisourceBergen Corp.,

80 Cal. App. 5th 1 (2022) .................................................................................................. 19, 20
25
Stangvik v. Shiley Inc.,
26
54 Cal. 3d 744 (1991) ............................................................................................ 20, 21, 22, 23
27
Swenberg v. Dmarcian, Inc.,
28 68 Cal. App. 5th 280 (2021), review denied (Nov. 23, 2021) ................................................. 14
5
1 Vons Cos., Inc. v. Seabest Foods, Inc.,
14 Cal. 4th 434 (1996)............................................................................................................. 18
2
Walden v. Fiore,
3 571 U.S. 277 (2014) .......................................................................................................... 13, 16
4 Wargaming.net Ltd. v. Blitzteam LLC,
5 No. 20-CV-02763, 2021 WL 3619956 (C.D. Cal. Jan. 20, 2021) .......................................... 18
6 Wright v. Jackson,
No. 3:17-CV-01694, 2018 WL 2329730 (S.D. Cal. May 23, 2018) ....................................... 15
7
Ziegler v. Indian River Cnty.,
8 64 F.3d 470 (9th Cir. 1995) ..................................................................................................... 18
9 Statutes
10
28 U.S.C. § 1782 ..................................................................................................................... 19, 22
11
Cal. Code of Civ. Proc. § 410.10 .................................................................................................. 11
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Cal. Code of Civ. Proc. § 410.30(a) .......................................................................................... 8, 20
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Cal. Code of Civ. Proc. § 418.10 .................................................................................................... 8
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Cal. Code of Civ. Proc. § 1048(b) ............................................................................................. 8, 19
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1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I. INTRODUCTION
3 Cross-Defendants Marc-Olivier Perrin (“Perrin”), SAS Familles Perrin (“Familles Perrin”),
4 and SAS Miraval Provence (“Miraval Provence”) (collectively, “the French Cross-Defendants”) 1
5 do not belong in this Court or this case. All of the French Cross-Defendants are residents of
6 France with virtually no connection to California, let alone any suit-related contacts with the
7 forum that would permit the exercise of personal jurisdiction over them. The alleged conduct that
8 purportedly gives rise to the claims against them occurred in France and relates to the management
9 and assets of two European entities: SA Château Miraval (“Château Miraval”), a French company
10 with whom the French Cross-Defendants do business in France, and Quimicum S.à r.l
11 (“Quimicum”), Château Miraval’s Luxembourgish parent company, with which none of the
12 French Cross-Defendants are alleged to have any contractual or other legal relationship.
13 Nouvel’s First Amended Cross-Complaint (“FACC”) does nothing to cure these
14 jurisdictional deficiencies and indeed highlights the fundamentally foreign nature of this dispute.
15 Nouvel does not allege that the French Cross-Defendants are subject to general jurisdiction in
16 California, nor could it: Perrin is not domiciled in California, and neither Familles Perrin nor
17 Miraval Provence have continuous or systematic contacts with this jurisdiction that might render
18 them essentially at home here. Nouvel also fails to establish specific jurisdiction. Nouvel has
19 identified almost no contacts between the French Cross-Defendants and the forum, and the few it
20 alleges are deficient as a matter of law. Beyond wholly conclusory jurisdictional allegations,
21 Nouvel alleges only that Perrin took a singular (undated) trip to visit Nouvel representatives in
22 California; sent correspondence to a California resident (William B. Pitt) and to Nouvel, allegedly
23 at Nouvel’s request; and caused harm to Nouvel in the state as part of an ill-defined alleged
24 conspiracy. These sparse contacts are insufficient to establish the substantial connection with the
25
1
Perrin, Familles Perrin, and Miraval Provence adopt this collective term for purposes of this
26 memorandum of points and authorities, but note that the First Amended Cross-Complaint purports
to name numerous allegedly foreign individuals and entities, including Cross-Defendant Roland
27 Venturini who is also an alleged French domiciliary and has separately moved to quash the First
28 Amended Cross-Complaint for lack of personal jurisdiction.
7
1 forum required by California law and the Due Process Clause. Further, Nouvel has not shown and
2 cannot show that any of its claims arose from or relate to the French Cross-Defendants’ few
3 sporadic alleged contacts with the forum. Finally, the exercise of personal jurisdiction here would
4 be unreasonable and would not comport with traditional notions of fair play and substantial
5 justice. Nouvel alleges that French parties, acting in France, caused harm to a French entity
6 (Château Miraval) and its Luxembourgish holding company (Quimicum), which in turn affected a
7 California shareholder (Nouvel). This attenuated and fortuitous chain cannot form a plausible
8 basis to hale the French Cross-Defendants in this fundamentally foreign dispute into a California
9 court. Service of the Summons and First Amended Cross-Complaint therefore must be quashed
10 pursuant to California Code of Civil Procedure § 418.10 for lack of personal jurisdiction.
11 Even if there were a plausible basis for exercising personal jurisdiction over the French
12 Cross-Defendants, which there is not, the claims against them should be severed and dismissed or
13 stayed on the grounds of forum non conveniens. The courts of France provide a sufficient and
14 more convenient alternate forum for the dispute involving the French Cross-Defendants. Further,
15 the center of gravity of this dispute is unquestionably France—the location of most of the Cross-
16 Defendants, witnesses, and alleged events—not California. This was true for the original Cross-
17 Complaint, but is even more so now with the addition of five new French cross-defendants.
18 Indeed, before filing the Cross-Complaint, Nouvel initiated legal proceedings and threatened
19 additional actions against the French Cross-Defendants in France to address the same harms
20 alleged in this California action. The Court therefore should sever the claims against the French
21 Cross-Defendants and dismiss or stay the claims pursuant to California Code of Civil Procedure
22 §§ 1048(b) and 410.30(a).
23 II. BACKGROUND
24 A. Procedural History
25 This case concerns the ownership and management of European entities Château Miraval
26 and Quimicum. Château Miraval is a French company that owns an estate and wine business in
27 the south of France. (FACC ¶ 37.) Quimicum is a Luxembourgish holding company and the sole
28 shareholder of Château Miraval. (Id. ¶ 38.) In 2008, Pitt and Angelina Jolie purchased
8
1 Quimicum, and its interest in Château Miraval, through their respective California investment
2 companies, Mondo Bongo, LLC (“Mondo Bongo”) and Nouvel. (Id. ¶¶ 69–71.) In 2013, to
3 improve the quality of its winemaking, Château Miraval entered into a business relationship with
4 Familles Perrin. (Id. ¶ 74.) Château Miraval and Familles Perrin created a new entity, Miraval
5 Provence, as a joint venture to, among other things, operate the estate’s vineyards, and market and
6 distribute the wine produced at Château Miraval. (Id.)
7 In October 2021, Jolie purported to sell Nouvel to Dutch company Tenute del Mondo B.V.
8 (“Tenute”), a subsidiary of the Stoli Group (formally known as SPI Group Holding Limited),
9 which is incorporated in Cyprus. (Id. ¶¶ 159, 201.) The transaction gave the Stoli Group an
10 indirect interest, via Tenute and Quimicum, in Château Miraval. (See, e.g., ¶¶ 39, 159, 211.)
11 Neither Nouvel, Tenute, nor the Stoli Group are alleged to have any contractual relationship with
12 any of the French Cross-Defendants.
13 In February 2022, Pitt and Mondo Bongo initiated this lawsuit against Jolie and Nouvel
14 following Jolie’s allegedly unlawful sale and wrongful transfer of Nouvel to Tenute. (See
15 generally Feb. 17, 2022 Compl.) On June 3, 2022, Pitt and Mondo Bongo amended the Complaint
16 to add Tenute, the Stoli Group, Yuri Shefler, the controlling shareholder of the Stoli Group, and
17 Alexey Oliynik, Nouvel’s manager. (See June 3, 2022 Am. Compl.; FACC ¶¶ 26, 170, 199–200.)
18 The Stoli Group initiated litigation in multiple forums, mostly in France and Luxembourg.
19 This campaign included Nouvel’s Cross-Complaint in this action, filed on September 6, 2022,
20 against Pitt, Mondo Bongo, and several additional parties, including the French Cross-Defendants,
21 Roland Venturini, Gary Bradbury, and Warren Grant (as well as “Roes 1-10”).
22 On February 16, 2023, the French Cross-Defendants filed a Motion to Quash the Summons
23 and Cross-Complaint for lack of personal jurisdiction or, in the alternative, to sever and dismiss or
24 stay the claims against the French Cross Defendants on the grounds of forum non conveniens.
25 On August 9, 2023, ten months after first initiating this action against the French Cross-
26 Defendants, Nouvel filed the First Amended Cross-Complaint, adding yet more foreign cross-
27 defendants. (See, e.g., FACC ¶¶ 21, 62–66 (asserting claims against SAS Petrichor, Vins et
28 Domaines Perrin SC, SAS Miraval Studios, SASU Le Domaine, and SAS Distilleries de la
9
1 Riviera).) The claims against the French Cross-Defendants are largely unchanged: the First
2 Amended Cross-Complaint asserts eight causes of action against these parties, which are premised
3 on allegations that the French Cross-Defendants assisted Pitt and Mondo Bongo in imposing a
4 shareholder deadlock at Quimicum, wasting Château Miraval’s corporate assets, and
5 misappropriating Château Miraval’s trademarks. The First Amended Cross-Complaint does
6 nothing to cure jurisdictional deficiencies identified by the French Cross-Defendants in their prior
7 Motion to Quash or change the foreign locus of this dispute.
8 B. Jurisdictional Allegations and Facts
9 Perrin, the president of both Miraval Provence and Familles Perrin (FACC ¶ 74), is a
10 French citizen who lives and works in France. (Id. ¶ 42; Decl. of Marc-Olivier Perrin in support
11 of Motion to Quash (“Perrin Decl.”) ¶¶ 1–2.) Perrin has never studied, resided, or been employed
12 in California. (Perrin Decl. ¶ 3.) He has never personally owned any property, had a bank
13 account, or registered a car in California. (Id.)
14 Familles Perrin and Miraval Provence are both limited liability companies organized and
15 existing under the laws of France that have their registered office in Orange, France. (Perrin Decl.
16 ¶¶ 4, 6; see also FACC ¶¶ 43–44.) Neither entity has offices, business records, or employees in
17 California; neither holds bank accounts or property in California; and neither is registered to do
18 business in California or has a registered agent to accept service of process in California. (Perrin
19 Decl. ¶¶ 5, 7.)
20 Nouvel alleges that each of the French Cross-Defendants “committed the acts alleged
21 herein in, or with effects in, California by directing communications to California residents, Pitt
22 and Mondo Bongo, including to discuss, perpetrate and further the acts alleged herein with the
23 intention to harm Nouvel,” and that Miraval Provence and Familles Perrin “suppl[y] wine
24 products to the United States, including California.” (FACC ¶¶ 56–58.) Beyond these
25 generalities, the 362-paragraph First Amended Cross-Complaint alleges few actual forum-related
26 actions by any of the French Cross-Defendants: a single visit to California by Perrin to discuss
27 business with representatives of Nouvel; emails between Perrin and Pitt concerning the operations
28 of Miraval Provence, a French joint venture, and unrelated to the present action; and email
10
1 exchanges between Perrin and Nouvel, as to which the Cross-Complaint does not specify the
2 number, date, or subject matter beyond asserting they were “about the business.” (Id. ¶¶ 77, 117.)
3 III. ARGUMENT
4 A. This Court Lacks Personal Jurisdiction over the French Cross-Defendants.
5 A California court may exercise personal jurisdiction over a foreign defendant only if it is
6 consistent with “the Constitution of this state or of the United States.” Cal. Code of Civ. Proc. §
7 410.10. These principles permit the exercise of jurisdiction only if a “defendant’s minimum
8 contacts with the forum state are such that the maintenance of the suit does not offend the
9 traditional notions of fair play and substantial justice.” Rivelli v. Hemm, 67 Cal. App. 5th 380, 391
10 (2021) (internal quotation marks omitted). Where, as here, “the nonresident defendant is from
11 another nation rather than another state,” California courts are especially “cautious in [the]
12 application of the law of personal jurisdiction.” In re Auto. Antitrust Cases I & II, 135 Cal. App.
13 4th 100, 109 (2005).
14 Nouvel bears the burden of establishing a basis for the exercise of personal jurisdiction
15 over the French Cross-Defendants. See id. at 110. It cannot satisfy that burden by mere
16 allegations, but must instead “provide affidavits and other authenticated documents in order to
17 demonstrate competent evidence of jurisdictional facts.” Id.
18 1. The French Cross-Defendants Are Not Subject to General Jurisdiction in
19 California.
20 General jurisdiction exists only if the defendant’s contacts with the forum are so
21 “continuous and systematic” that the defendant is “essentially at home” in California. Goodyear
22 Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011). “For an individual, the
23 paradigm forum for the exercise of general jurisdiction is the individual’s domicile.” Id. at 924. A
24 corporation is “at home” for these purposes in its “place of incorporation and principal place of
25 business.” Daimler AG v. Bauman, 571 U.S. 117, 137 (2014).
26 No plausible argument can be made that the French Cross-Defendants are “at home” in
27 California. Perrin is a French national who lives and works in France, and Familles Perrin and
28 Miraval Provence are French companies, each with its principal place of business in France.
11
1 (FACC ¶¶ 42–44; Perrin Decl. ¶¶ 2, 4, 6.) Consequently, Nouvel has not alleged, and cannot
2 show, that any of the French Cross-Defendants is subject to general jurisdiction in California.
3 2. The French Cross-Defendants Are Not Subject to Specific Jurisdiction in
4 California.
5 The “primary focus” of a court’s specific jurisdiction analysis centers on “the relationship
6 of the defendant to the forum state.” Rivelli, 67 Cal. App. 5th at 391; see also Axiom Foods, Inc.
7 v. Acerchem Int’l, Inc., 874 F.3d 1064, 1068 (9th Cir. 2017) (a defendant is subject to specific
8 jurisdiction only if its “suit-related conduct” creates a “substantial connection with [California]”
9 (quoting Walden v. Fiore, 571 U.S. 277, 284 (2014))).
10 California courts have adopted three requirements for the exercise of specific jurisdiction
11 over a nonresident defendant: “(1) the defendant must either purposefully direct his activities
12 toward the forum or purposefully avail himself of the privileges of conducting activities in the
13 forum; (2) the claim must be one which arises out of or relates to the defendant’s forum-related
14 activities; and (3) the exercise of jurisdiction must comport with fair play and substantial justice,
15 i.e. it must be reasonable.” Axiom Foods, 874 F.3d at 1068 (cleaned up); accord David L. v.
16 Superior Ct., 29 Cal. App. 5th 359, 366 (2018), as modified (Dec. 17, 2018). Nouvel has the
17 burden of satisfying the first two prongs of this test. See Rivelli, 67 Cal. App. 5th at 393. Nouvel
18 “must do more than merely allege jurisdictional facts”; rather, it “must present evidence sufficient
19 to justify a finding that California may properly exercise jurisdiction over the defendant.” In re
20 Auto. Antitrust Cases, 135 Cal. App. 4th at 110. Only if Nouvel meets its burden––which it
21 cannot––does the burden shift to the French Cross-Defendants to show that the exercise of
22 jurisdiction would be unreasonable. See Rivelli, 67 Cal. App. 5th at 393.
23 In this “defendant-focused” inquiry, “the relationship between the nonresident defendant,
24 the forum, and the litigation ‘must arise out of contacts that the defendant himself creates with the
25 forum State.’” Axiom Foods, 874 F.3d at 1068 (quoting Walden, 571 U.S. at 284) (cleaned up).
26 Further, the analysis must examine “the defendant’s contacts with the forum State itself, not the
27 defendant’s contacts with persons who reside there.” Id. (quoting Walden, 571 U.S. at 285).
28 Thus, “a defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient
12
1 basis for jurisdiction.” Id. (quoting Walden, 571 U.S. at 286). “[E]ach defendant’s contacts with
2 the forum state must be assessed individually.” Burdick v. Superior Ct., 233 Cal. App. 4th 8, 24
3 (2015).
4 a. The French Cross-Defendants Did Not Direct Activity to California or
5 Purposefully Avail Themselves of California’s Forum Benefits.
6 Nouvel cannot satisfy the first prong of the specific jurisdiction test because it cannot
7 establish that the French Cross-Defendants purposefully availed themselves of the privilege of
8 conducting activities in California or purposefully directed activities toward California. See, e.g.,
9 Axiom Foods, 874 F.3d at 1068. The “purposeful availment” analysis requires that the defendant
10 “purposefully avail[ed] itself of the privilege of conducting activities within the forum State, thus
11 invoking the benefits and protections of its laws.” Schwarzenegger v. Fred Martin Motor Co., 374
12 F.3d 797, 802 (9th Cir. 2004); see also Picot v. Weston, 780 F.3d 1206, 1212 (9th Cir. 2015) (“A
13 defendant must have ‘performed some type of affirmative conduct which allows or promotes the
14 transaction of business within the forum state.’”). The “purposeful direction” test, also called the
15 “effects test,” requires that the defendant “(1) committed an intentional act, (2) expressly aimed at
16 the forum state, (3) causing harm that the defendant knows is likely to be suffered in the forum
17 state.” Axiom Foods, 874 F.3d at 1069. “‘[R]andom, fortuitous, or attenuated’ contacts will not
18 suffice”; rather, the defendant’s “intentional conduct” must create a “substantial connection” with
19 the forum. Id. at 1068–69 (quoting Walden, 571 U.S. at 284, 286); see also David L., 29 Cal. App.
20 5th at 373. In addition, “[t]he proper question is not where the plaintiff experienced a particular
21 injury or effect but whether the defendant’s conduct connects him to the forum in a meaningful
22 way.” Walden, 571 U.S. at 290.
23 Nouvel’s allegations fall far short. The First Amended Cross-Complaint contains very few
24 potentially relevant allegations, none of which come close to asserting specific actions by the
25 French Cross-Defendants that create a substantial relationship between themselves and California.
26 The First Amended Cross-Complaint alleges (i) attenuated and vaguely alleged interactions with
27 California residents, (ii) in-forum effects on Nouvel, and (iii) that the French Cross-Defendants
28 “conspired” with Pitt and Mondo Bongo to interfere with Quimicum’s governance and deplete or
13
1 misappropriate Château Miraval’s assets. (FACC ¶¶ 15, 56–58, 117–118.) Both individually and
2 collectively, these alleged contacts with the forum are fatally deficient. 2
3 First, the First Amended Cross-Complaint alleges only two types of contacts with
4 California residents: correspondence allegedly sent to individuals in California (namely, alleged

5 “constant communication between Perrin, in France, and Pitt, in California” and email exchanges
6 between Perrin and Nouvel “about the business”) (FACC ¶¶ 77, 117); and a single trip by Perrin to
7 California “to meet with Nouvel’s representatives to discuss Chateau Miraval’s business” (FACC
8 ¶ 117). These allegations are insufficient to render the French Cross-Defendants subject to
9 jurisdiction in California. 3
10 To begin, emails with a California resident “d[o] not create an affiliation between [the non-
11 resident] and California, but rather, between [the non-resident] and Plaintiff.” Sec. Alarm Fin.
12 Enterprises, L.P. v. Nebel, 200 F. Supp. 3d 976, 986 (N.D. Cal. 2016). Despite Nouvel’s self-
13 serving assertion that Perrin communicated with Pitt while Pitt was “in California,” California’s
14 incidental connection to these alleged communications (about a business located in France) is
15 underscored by Nouvel’s own pleading, which concedes that, throughout this period, Pitt traveled
16 extensively: he made “countless promotional appearances, jetting-setting [sic] around the world.”
17 (FACC ¶ 6.) “[T]he fact that Plaintiff happened to be a resident of California and happened to be
18 located in California when Defendants [contacted] him is insufficient to establish specific
19 jurisdiction.” Dangoor v. Peterson’s Stampede Dodge Chrysler Jeep, LLC, No. 2:19-CV-01793,
20 2019 WL 6357252, at *3 (C.D. Cal. Aug. 8, 2019).
21 Nor do Nouvel’s alleged emails with the French Cross-Defendants “about the business”
22
2
Nor can Nouvel rely on its boilerplate and conclusory jurisdictional allegations, which are nearly
23 identically pleaded as to all French Cross-Defendants. (FACC ¶¶ 56–58.) Such “vague and
24 conclusory assertions of ultimate facts” cannot support the exercise of personal jurisdiction.
Swenberg v. Dmarcian, Inc., 68 Cal. App. 5th 280, 291 (2021), review denied (Nov. 23, 2021)
25 (citation omitted).
26 3
The communications and travel to California are attributed to Perrin, with no indication whether
he was acting individually or on behalf of Familles Perrin or Miraval Provence. Nouvel has thus
27 provided no basis for the Court to evaluate “[e]ach defendant’s contacts with the forum state . . .
28 individually,” as the law requires. Burdick, 233 Cal. App. 4th at 24.
14
1 (located in France) or a singular alleged meeting in California with Perrin (at Nouvel’s request)
2 establish personal jurisdiction in California. Courts have routinely held that such attenuated
3 contacts do not suffice. See, e.g., David L., 29 Cal. App. 5th at 374 (holding that allegations of
4 text messages, phone calls, and at least two trips to the forum were insufficient to establish
5 personal jurisdiction); Wright v. Jackson, No. 3:17-CV-01694, 2018 WL 2329730, at *2 (S.D. Cal.
6 May 23, 2018) (finding allegations that “Defendants sent and received some calls, emails, and
7 physical mail to and from Plaintiff while Plaintiff was in California” insufficient to establish
8 personal jurisdiction). Furthermore, by its own admission, Nouvel initiated these alleged
9 communications with the French Cross-Defendants after Jolie and Nouvel “sought to become
10 more involved in Chateau Miraval’s finances and operations.” (FACC ¶ 117.) It is black-letter
11 law that a defendant does not purposefully avail itself of a forum where plaintiff “initiated contact
12 with Defendants.” Peacock v. Willis, No. 06-CV-432, 2006 WL 3060134, at *10 (E.D. Cal. Oct.
13 27, 2006); see also, e.g., Axiom Foods, 874 F.3d at 1068; Dangoor, 2019 WL 6357252, at *3 n.2
14 (“Defendants’ calls to Plaintiff, which were made in response to Plaintiff’s initial inquiry, are
15 merely contacts with someone who resides in California and are thus insufficient to establish
16 specific jurisdiction.”); Free Conferencing Corp. v. T-Mobile US, Inc., No. 2:14-CV-07113, 2014
17 WL 7404600, at *11 (C.D. Cal. Dec. 30, 2014) (defendant’s “e-mails to [plaintiff’s] executives,
18 which were sent in response to inquiries from [plaintiff], are nothing more than ‘contacts with
19 persons who reside [in the forum]’” (quoting Walden, 571 U.S. at 285)).
20 Second, Nouvel apparently seeks to premise jurisdiction on the in-forum effects of foreign
21 conduct resulting in “harm [to] Nouvel.” (FACC ¶¶ 56–58, 129.) But “[s]imply directing conduct
22 at a plaintiff knowing that she has significant California connections does not satisfy the minimum
23 contacts inquiry.” David L., 29 Cal. App. 5th at 374; see also Axiom Foods, 874 F.3d at 1070
24 (holding that “individualized targeting” of a California plaintiff and defendant’s knowledge of the
25 plaintiffs’ forum connection and foreseeable harm in California were insufficient); In re Auto.
26 Antitrust Cases, 135 Cal. App. 4th at 122 (the foreseeability of in-forum harm from out-of-forum
27 conduct “is not sufficient to establish jurisdiction under the effects test”); Santa Barbara
28 Smokehouse, Inc. v. AquaChile, Inc., No. 19-CV-10733, 2020 WL 13328094, at *6 (C.D. Cal. July
15
1 7, 2020) (“That Plaintiffs live in California, and suffered alleged financial harm in California, is
2 not a basis for personal jurisdiction.” (cleaned up)). Application of personal jurisdiction on this
3 basis is precisely what Walden forecloses. See Walden, 571 U.S. at 290 (“The proper question is
4 not where the plaintiff experienced a particular injury or effect but whether the defendant’s
5 conduct connects him to the forum in a meaningful way.”). Nouvel must show that Perrin,
6 Familles Perrin, and Miraval Provence each created a substantial connection with California, not
7 with Nouvel. Id. (“Mere injury to a forum resident is not a sufficient connection to the forum.”).
8 California must be “the focal point of the tort.” In re Auto. Antitrust Cases, 135 Cal. App. 4th at
9 122.
10 Here, the focal point of virtually all of the alleged tortious conduct by the French Cross-
11 Defendants is Europe, specifically, Château Miraval in France and Quimicum in Luxembourg.

12 The alleged actions, if they occurred at all, manifestly were directed at Château Miraval and
13 Quimicum. They touched California only because Nouvel is located there—that is, they are
14 contacts “between the plaintiff . . . and the forum State,” not “contacts that the ‘defendant himself’
15 creates” with the forum. David L., 29 Cal. App. 5th at 371 (quoting Walden, 571 U.S. at 284).
16 Third, for similar reasons, to the extent that Nouvel seeks to confer jurisdiction by
17 characterizing the French Cross-Defendant’s alleged conduct as part of a “conspiracy” with

18 California residents Pitt and Mondo Bongo, that effort fails. (See FACC ¶¶ 1, 9, 222, 347–362.)
19 California law requires that personal jurisdiction be “based on forum-related acts that were
20 personally committed by each nonresident defendant.” See In re Auto. Antitrust Cases, 135 Cal.
21 App. 4th at 113 (emphasis added). “The purposes and acts of one party—even an alleged co-
22 conspirator—cannot be imputed to a third party to establish jurisdiction over the third party
23 defendant.” Id.; see also Burdick, 233 Cal. App. 4th at 24 (holding that jurisdiction was lacking
24 despite assertion that the defendant was “a principal participant in this plan to injure
25 Californians”); Elite Semiconductor, Inc. v. Anchor Semiconductor, Inc., No. 5:20-CV-06846,
26 2021 WL 3037701, at *9 (N.D. Cal. July 19, 2021) (conclusory allegations of conspiracy with a
27 California company were insufficient to establish jurisdiction over foreign domiciliary); Farina v.
28 SAVWCL III, LLC, 50 Cal. App. 5th 286, 295 (2020) (explaining that “[p]ersonal jurisdiction is
16
1 determined defendant by defendant,” requires an assessment of “each defendant’s individual
2 contacts with a forum,” and, “[e]ven when plaintiff alleges a conspiracy . . .[,] the purposes and
3 acts of one party cannot be imputed to others”).
4 b. Nouvel’s Claims Do Not Arise Out of or Relate to the French Cross-
5 Defendants’ Contacts with California.
6 Nouvel also has not met its burden to show that its claims “arise out of or relate to” the
7 French Cross-Defendants’ alleged contacts with California. LG Chem, Ltd. v. Superior Ct. of San
8 Diego Cnty., 80 Cal. App. 5th 348, 364 (2022) (cleaned up), review denied (Oct. 12, 2022).
9 Where, as here, no such connection exists, the claims must be dismissed for lack of jurisdiction.
10 See id. (“When there is no such connection, specific jurisdiction is lacking regardless of the extent
11 of a defendant’s unconnected activities in the State.”).
12 Nouvel’s cross-claims against the French Cross-Defendants are based on alleged conduct
13 in Europe and European-focused harm: allegedly tortious conduct in France in connection with
14 the assets, business, and management of Château Miraval, a French entity (Counts 3, 5, 10, and
15 11), and to the governance and articles of incorporation of Quimicum, a Luxembourgish entity
16 (Counts 1, 7, 8, 9). None of the claims are based on the skeletal (and jurisdictionally insufficient)
17 contacts between these French Cross-Defendants and California. See Rivelli, 67 Cal. App. 5th at
18 401 (concluding that in-state business activity to procure and execute a California business
19 transaction was not related to causes of action for fraud and breach of fiduciary duty in the
20 management of the resulting California business). The alleged correspondence and singular
21 meeting in California, by Nouvel’s own account, related to ordinary-course business activities.
22 (See FACC ¶ 77 (alleging that Perrin and Pitt were in “constant communication” about the
23 business and highlighting an email between Perrin and Pitt to “brainstorm[] about their options for
24 Chateau Miraval’s new wine labels and bottles”); id. ¶ 117 (alleging that Nouvel communicated
25 with Perrin “about the business” via email and during one in-person meeting).) They therefore
26 cannot serve as the basis for jurisdiction in this case, which brings claims for allegedly tortious
27 conduct concerning entities in Europe.
28 Any potential argument that personal jurisdiction exists because Familles Perrin and
17
1 Miraval Provence “suppl[y] wine products to the United States, including California,” (FACC ¶¶
2 57–58), is similarly deficient because the claims against the French Cross-Defendants do not arise
3 from or relate to the alleged supply of “wine products” to the United States. See, e.g., Love v. The
4 Mail on Sunday, No. 05-CV-7798, 2006 WL 4046166, at *4 (C.D. Cal. Mar. 21, 2006) (“To the
5 extent that [defendant] had any contact with California, those contacts were tangential to the
6 contracts into which [defendant] entered with exclusively European companies,” which were the
7 basis for the action).
8 c. The Court’s Exercise of Jurisdiction Over the French Cross-
9 Defendants Would Not Be Reasonable.
10 Even if Nouvel could establish that the French Cross-Defendants had sufficient suit-related
11 contacts with California to create a substantial connection with the forum, this Court should still
12 quash the cross-claims against them because the exercise of personal jurisdiction would be
13 unreasonable and would not comport with traditional notions of fair play and substantial justice.
14 Schwarzenegger, 374 F.3d at 802. California courts consider several factors to determine if the
15 exercise of jurisdiction would be reasonable, including “the burden on the defendant, the interests
16 of the forum State, . . . the plaintiff’s interest in obtaining relief . . .[,] the interstate judicial
17 system’s interest in obtaining the most efficient resolution of controversies[,] and the shared
18 interest of the several States in furthering fundamental substantive social policies.” Vons Cos.,
19 Inc. v. Seabest Foods, Inc., 14 Cal. 4th 434, 476 (1996), abrogated on other grounds by Bristol-
20 Myers Squibb Co. v. Superior Ct. of Cal., San Francisco Cnty., 582 U.S. 255 (2017) (internal
21 quotation marks omitted); see also Ziegler v. Indian River Cnty., 64 F.3d 470, 475 (9th Cir. 1995).
22 These factors weigh heavily against the exercise of jurisdiction here. First, litigation in
23 California, a foreign forum thousands of miles away from home, would impose a “substantial
24 burden” on the French Cross-Defendants. See Wargaming.net Ltd. v. Blitzteam LLC, No. 20-CV-
25 02763, 2021 WL 3619956, at *5 (C.D. Cal. Jan. 20, 2021). Second, the claims against the French
26 Cross-Defendants concern actions in France, principally affecting a French wine business. France
27 has a greater sovereign interest than California in adjudicating a dispute that predominantly
28 concerns conduct by French parties relating to a French business and its Luxembourgish holding
18
1 company. California’s interest in the dispute is diluted by the fact that the plaintiff’s beneficial
2 owner, the Stoli Group, is a foreign entity. Third, the convenience and availability of an
3 alternative forum (France) favors dismissal. As explained in Part III.B, infra, the doctrine of
4 forum non conveniens provides an independent basis to dismiss or stay the cross-claims because
5 France is an available and more convenient forum for this dispute. Further, Nouvel is pursuing
6 various actions in European courts and also obtained an order pursuant to 28 U.S.C. § 1782 to
7 obtain discovery in aid of foreign proceedings, largely relating to the same conduct and injuries
8 asserted in the First Amended Cross-Complaint. (See Part III.B.3, infra). Thus, Nouvel cannot
9 plausibly argue that it has a strong interest in pursuing duplicative litigation in California.
10 Because the exercise of specific jurisdiction over the French Cross-Defendants would be
11 contrary to fair play and substantial justice, the Court should quash the First Amended Cross-
12 Complaint against them.
13 B. In the Alternative, the Court Should Sever the French Cross-Defendants and Dismiss
14 or Stay Any Action Against These Parties on Forum Non Conveniens Grounds.
15 Even if the French Cross-Defendants were subject to personal jurisdiction in California
16 (they are not), the Court should sever the claims as to those parties and dismiss or stay the claims
17 under the doctrine of forum non conveniens. At its core, this case is about events and parties
18 located in Europe, predominantly France. Further, the central issues are being or may soon be
19 litigated in European courts. The relevant private and public factors thus heavily favor resolving
20 these disputes in France.
21 The Court has broad authority to sever claims “in furtherance of convenience” or when
22 “conducive to expedition and economy.” Cal. Code of Civ. Proc. § 1048(b) (permitting severance
23 of causes of action to further judicial economy and/or convenience); cf. St. Paul Fire and Marine
24 Ins. Co. v. AmerisourceBergen Corp., 80 Cal. App. 5th 1, 13–14 (2022) (noting “the power
25 inherent in every court to control the disposition of the causes on its docket with economy of time
26 and effort for itself, for counsel, and for litigations” (quoting Landis v. N. Am. Co., 299 U.S. 248,
27 254 (1936))); David v. Medtronic, Inc., 237 Cal. App. 4th 734, 740 (2015), as modified (June 26,
28 2015) (affirming severance of parties and dismissal on forum non conveniens grounds where
19
1 “[u]ntil that point [of severance], no single alternative forum existed”).
2 Where “in the interest of substantial justice an action should be heard in a forum outside
3 this state, the court shall stay or dismiss the action in whole or in part on any conditions that may
4 be just.” Cal. Code of Civ. Proc. § 410.30(a); see also St. Paul Fire, 80 Cal. App. 5th at 13 (“A
5 stay under the forum non conveniens doctrine effectuates the trial court’s inherent power, in its
6 discretion, to stay proceedings when such a stay will accommodate the ends of justice.” (internal
7 quotations omitted)); Cal-State Bus. Prod. & Servs., Inc. v. Ricoh, 12 Cal. App. 4th 1666, 1675
8 (1993), as modified (Feb. 4, 1993) (a trial court may in its discretion “decline to exercise
9 jurisdiction over a cause and parties otherwise properly before it if it concludes the action may be
10 more appropriately and justly tried elsewhere”).
11 In considering a forum non conveniens challenge, a court first “determine[s] whether a
12 suitable alternative forum exists”; if so, the court “consider[s]” the “private interests of the parties
13 and the public interest in keeping the case in California.” Nat’l Football League v. Fireman’s
14 Fund Ins. Co., 216 Cal. App. 4th 902, 917 (2013) (internal quotations and citations omitted)
15 (citing Stangvik v. Shiley Inc., 54 Cal. 3d 744, 751, 754 (1991)).
16 1. France Is an Adequate Alternative Forum.
17 In assessing the adequacy of an alternative foreign forum, courts consider two sets of
18 issues, both of which clearly demonstrate that France is an adequate alternative forum here. First,
19 a foreign forum is suitable if “adjudication in the alternative forum is by an independent judiciary
20 applying what American courts regard, generally, as due process of law.” Boaz v. Boyle & Co., 40
21 Cal. App. 4th 700, 711 (1995). France is unquestionably a proper forum under this standard. See,
22 e.g., Gambra v. Int’l Lease Fin. Corp., 377 F. Supp. 2d 810, 817 (C.D. Cal. 2005) (holding France
23 is “an adequate alternative forum” and citing cases).
24 Second, the parties seeking stay or dismissal must be subject to personal jurisdiction in the
25 alternative forum, and the action cannot be barred by a shorter statute of limitations. See Stangvik,
26 54 Cal. 3d at 751–52. The French Cross-Defendants are all French parties subject to jurisdiction
27 in that country’s courts. And these parties would, if the motion were granted on forum non
28 conveniens grounds, each agree to exclude from any statute of limitations calculation the period
20
1 from the filing of Nouvel’s Cross-Complaint until 30 days after the dismissal of its First Amended
2 Cross-Complaint. See id. at 752 (granting forum non conveniens motion based on defendants’
3 stipulation to “toll[] . . . the statute of limitations during the pendency of the actions in
4 California”).
5 2. The Private and Public Interest Factors Support a Dismissal or Stay.
6 a. The Private Interest Factors Favor Dismissal.
7 “The private interest factors are those that make trial and the enforceability of the ensuing
8 judgment expeditious and relatively inexpensive, such as the ease of access to sources of proof,
9 the cost of obtaining attendance of witnesses, and the availability of compulsory process for
10 attendance of unwilling witnesses.” Stangvik, 54 Cal. 3d at 751.
11 All of these factors heavily favor dismissal or stay as to the French Cross-Defendants.
12 Again, France is indisputably the center of gravity in this case. Virtually all of the alleged events
13 relating to the French Cross-Defendants took place in France and relate either to a French
14 company, Château Miraval, or to its Luxembourgish corporate parent, Quimicum. If anything, the
15 First Amended Cross-Complaint—which alleges a separate scheme involving five additional
16 French entities—further cements that this dispute belongs in France, not California. It follows that
17 key witnesses and documents are located in Europe, and many witnesses are likely beyond the
18 Court’s subpoena power, requiring the parties to secure these witnesses’ attendance through the
19 Hague Convention. See Proofpoint, Inc. v. Vade Secure, Inc., No. 19-CV-04238, 2020 WL
20 504962, at *2 (N.D. Cal. Jan. 31, 2020) (“[T]he increased costs and added delays associated with
21 proceeding under the Hague Convention and involving the French judiciary . . . in the discovery
22 process of this case would be unduly expensive and time consuming[.]”). Similarly, obtaining the
23 attendance of foreign witnesses at trial in California and conducting depositions in multiple
24 locations could be costly for the parties and inconvenient for non-party witnesses. Thus, “the ease
25 of access to sources of proof, the cost of obtaining attendance of witnesses, and the availability of
26 compulsory process for attendance of unwilling witnesses” support dismissal. Stangvik, 54 Cal.
27 3d at 751.
28 Additionally, the French Blocking Statute could complicate the parties’ ability to secure
21
1 evidence located in France and also reflects France’s sovereign interest in the collection and use of
2 evidence located within France. The blocking statute makes it a crime “to request, to investigate
3 or to communicate . . . documents or information relating to economic, commercial, industrial,
4 financial or technical matters” for use in a foreign proceeding. Behrens v. Arconic, Inc., No. 19-
5 CV-2664, 2020 WL 1250956, at *1 (E.D. Pa. Mar. 13, 2020) (quoting Article 1bis of Law No. 80-
6 538); see also Kashef v. BNP Paribas S.A., No. 16-CV-3228, 2022 WL 1617489, at *3 (S.D.N.Y.
7 May 23, 2022). By contrast, Nouvel has not identified any similar impediments to discovery if the
8 action were to proceed in France. Indeed, Nouvel has already obtained evidence in the United
9 States in aid of foreign proceedings pursuant to a 28 U.S.C. § 1782 action. 4 See In re Nouvel,
10 LLC, 22-MC-00004, 2022 WL 2901715 (C.D. Cal. July 22, 2022). In addition, having already
11 initiated closely related legal proceedings in France (FACC ¶ 210), Nouvel cannot credibly claim
12 to be inconvenienced by litigating in that forum.
13 b. The Public Interest Factors Favor Dismissal.
14 The relevant public factors also favor dismissal. In brief, “the jurisdiction with the greater
15 interest should bear the burden of entertaining the litigation.” Stangvik, 54 Cal. 3d at 757.
16 France indisputably has a greater interest in resolving this dispute than California. As
17 noted, the case relates to the management and assets of a French entity and alleged actions by
18 French parties within France. As to the French Cross-Defendants, the only connections to
19 California are communications with Californians—unrelated to the underlying dispute—and a
20 single visit to the state. Because “the torts alleged in this case have nothing to do with California,”
21 the Court should dismiss the claims as against the French Cross-Defendants on forum non
22 conveniens grounds. Boaz, 40 Cal. App. 4th at 713.
23 3. Nouvel’s Choice of Forum Is Entitled to Minimal Deference.
24 Courts considering forum non conveniens challenges sometimes apply a presumption in
25
26 4
In its original Cross-Complaint, Nouvel alleged that it had sought documents in a § 1782 action
“that [would] allow Nouvel to pursue remedies in France for the mismanagement of Chateau
27 Miraval.” (Sept. 6, 2022 Cross-Compl. ¶ 155.) Nouvel’s operative pleading omits that allegation,
28 presumably to avoid drawing attention to its efforts to pursue duplicative litigation in Europe and
California.
22
1 favor of a plaintiff’s choice of forum when the plaintiff is a California resident. See Stangvik, 54
2 Cal. 3d at 753; but see Nat’l Football League, 216 Cal. App. 4th at 924 (“One of the purposes of
3 the enactment of section 410.30 [of the California Code of Civil Procedure] was to give less
4 weight to the plaintiff’s domicile or residence.” (internal quotation marks omitted)). However,
5 this presumption carries limited weight where, as here, the “nominal California resident sues on
6 behalf of foreign beneficiaries,” Archibald v. Cinerama Hotels, 15 Cal. 3d 853, 859 (1976), and
7 “the foreign forum was chosen by [the] Plaintiff[] first.” Klein v. Superior Ct., 198 Cal. App. 3d
8 894, 905 (1988).
9 The First Amended Cross-Complaint makes clear that the nonresident Stoli Group—and
10 not Nouvel itself—is directing the present action as part of a multi-forum campaign of litigation
11 against the cross-defendants. After Stoli purported to buy Nouvel, it notified the cross-defendants
12 of its intention to “pursue all legal remedies available to it,” and has made good on its threats by
13 causing Nouvel to initiate actions in France. (FACC ¶ 210.) Given the tenuous links between this
14 litigation and the forum, “it is unconscionable to force [the French Cross-Defendants] to defend
15 themselves simultaneously in two or more actions on two continents in two languages and under
16 two different legal systems.” Klein, 198 Cal. App. 3d at 905.
17 IV. CONCLUSION
18 For the foregoing reasons, Perrin, Familles Perrin, and Miraval Provence respectfully
19 request that Nouvel’s Summons and First Amended Cross-Complaint be quashed for lack of
20 jurisdiction or, in the alternative, that the claims against them be severed and dismissed or stayed
21 on the grounds of forum non conveniens.
22
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1 DATED: September 20, 2023 Respectfully submitted,
2 Mark T. Drooks
BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
3 DROOKS, LINCENBERG & RHOW, P.C.
4
S. Gale Dick (admitted pro hac vice)
7
Mark T. Drooks
9
10 jurisdiction on behalf of Cross-Defendants Marc-
Olivier Perrin, SAS Miraval Provence and SAS
11 Familles Perrin
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1 PROOF OF SERVICE
2 William B. Pitt, et al. v Angelina Jolie, et al.
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 September 20, 2023, I served the following document(s) described as
7 SPECIALLY APPEARING CROSS-DEFENDANTS MARC-OLIVIER PERRIN,
SAS MIRAVAL PROVENCE AND SAS FAMILLES PERRIN’S MOTION TO: 1)
8 QUASH FOR LACK OF PERSONAL JURISDICTION; AND (2) DISMISS OR STAY FOR
FORUM NON CONVENIENS 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)
11 to be sent from e-mail address dthrockmorton@birdmarella.com to the persons at the e-
mail addresses listed in the Service List. I did not receive, within a reasonable time after
12 the transmission, any electronic message or other indication that the transmission was
unsuccessful.
13
I declare under penalty of perjury under the laws of the State of California that the
14 foregoing is true and correct.
15 Executed on September 20, 2023, at Los Angeles, California.
16
17
18 Debra L. Throckmorton
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1 SERVICE LIST
William B. Pitt, et al. v Angelina Jolie, et al.
2 Case No. 22STCV06081
3 Laura Brill Jonathan M. Moses
Katelyn A. Kuwata Adam L. Goodman
4 Daniel Barlava Remy Grosbard
KENDALL BRILL & KELLY LLP Jessica L. Allen
5 10100 Santa Monica Boulevard WACHTELL, LIPTON, ROSEN & KATZ
Suite 1725 51 West 52nd Street
6 Los Angeles, CA 90067 New York, NY 10019
Telephone: (310) 556-2700 Telephone: (212) 403-1000
7 Email: lbrill@kbkfirm.com Email: JMMoses@wlrk.com
Email: kkuwata@kbkfirm.com Email: ALGoodman@wlrk.com
8 Email: dbarlava@kbkfirm.com Email: JLAllen@wlrk.com
Counsel for Plaintiffs and Cross- Email: RKGrosbard@wlrk.com
9 Defendants William B. Pitt and Mondo Counsel for Plaintiffs and Cross- Defendants
Bongo, LLC, Cross-Defendant Warren William B. Pitt and Mondo Bongo, LLC, Cross-
10 Grant, and appearing specially to Defendant Warren Grant, and appearing
challenge jurisdiction on behalf of Cross- specially to challenge jurisdiction on behalf of
11 Defendants Roland Venturini and Gary Cross-Defendants Roland Venturini and Gary
Bradbury Bradbury
12
Paul D. Murphy Joe Tuffaha
13 Daniel N. Csillag Prashanth Chennakesavan
MURPHY ROSEN LLP LTL ATTORNEYS LLP
14 100 Wilshire Blvd., Ste. 1300 300 South Grand Ave., Ste. 1400
Santa Monica, CA 90401 Los Angeles, CA 90071
15 Telephone: (310) 899-3300 Telephone: (213) 612-8900
Email: dcsillag@murphyrosen.com Email: joe.tuffaha@ltlattorneys.com
16 Email: pmurphy@murphyrosen.com Email: prashanth.chennakesavan@ltlattorneys.com
Counsel for Defendant and Cross- Counsel for Defendant and Cross-Complainant
17 Complainant Angelina Jolie Nouvel, LLC and appearing specially to
challenge service and jurisdiction on behalf of
18 Defendants SPI Group Holding Ltd., Tenute del
Mondo B.V., Yuri Shefler, and Alexey Oliynik
19
Keith R. Hummel John V. Berlinski
20 Justin C. Clarke BIRD, MARELLA, BOXER, WOLPERT,
Jonathan Mooney NESSIM, DROOKS, LINCENBERG &
21 CRAVATH, SWAINE & MOORE LLP RHOW, P.C.
Worldwide Plaza 1875 Century Park East, 23rd Floor
22 825 Eighth Avenue Los Angeles, CA 90067
New York, NY 10019 Telephone: (310) 201-2100
23 Telephone: (212) 474-1000 Facsimile: (310) 201-2110
Email: khummel@cravath.com Email: jberlinski@birdmarella.com
24 Email: jcclarke@cravath.com Email: BTeachout@birdmarella.com
Email: jmooney@cravath.com Email: jcherlow@birdmarella.com
25 Counsel for Defendant and Cross- Email: Kmeyer@birdmarella.com
Complainant Nouvel, LLC and appearing Email: Pyates@birdmarella.com
26 specially to challenge service and Email: RAttarson@birdmarella.com
jurisdiction on behalf of Defendants SPI Counsel for Plaintiffs and Cross-Defendants
27 Group Holding Ltd., Tenute del Mondo William B. Pitt and Mondo Bongo, LLC and
B.V., Yuri Shefler, and Alexey Oliynik Cross-Defendant Warren Grant
28
26
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WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al.
Case Number: 22STCV06081 Case Type: Civil Unlimited Category: Other Breach of Contract/Warranty (not
fraud or negligence)
Date Filed: 2022-02-17 Location: Stanley Mosk Courthouse - Department 16
Reservation
Case Name: Case Number:
WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al. 22STCV06081
Type: Status:
Motion to Quash Service of Summons RESERVED
Filing Party: Location:
Marc Olivier Perrin (Cross-Defendant) Stanley Mosk Courthouse - Department 16
Date/Time: Number of Motions:
12/15/2023 9:00 AM 1
Reservation ID: Confirmation Code:
257294386007 CR-P7XAP5BDSUW2VTBWB
Fees
Description Fee Qty Amount
Motion to Quash Service of Summons 60.00 1 60.00
Credit Card Percentage Fee (2.75%) 1.65 1 1.65
TOTAL $61.65
Payment
Amount: Type:
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Account Number: Authorization:
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Payment Date:
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2 BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
DROOKS, LINCENBERG & RHOW, P.C.
4 Telephone: (310) 201-2100
Facsimile: (310) 201-2110
5
800 Third Avenue
8 New York, NY 10022
Telephone: (212) 957-7600
9
Attorneys appearing specially to challenge jurisdiction
10 on behalf of Cross-Defendants Marc-Olivier Perrin,
SAS Miraval Provence and SAS Familles Perrin
11
12
13
14
WILLIAM B. PITT, an individual, and CASE NO. 22STCV06081
15 MONDO BONGO, LLC, a California limited
liability company, DECLARATION OF MARC-OLIVIER
16 PERRIN IN SUPPORT OF CROSS-
Plaintiffs, DEFENDANTS MARC-OLIVIER
17 PERRIN, FAMILLES PERRIN, AND
vs. MIRAVAL PROVENCE’S MOTION TO
18 (1) QUASH FOR LACK OF PERSONAL
ANGELINA JOLIE, et. al., JURISDICTION; AND (2) DISMISS OR
19 STAY FOR FORUM NON CONVENIENS
Defendants.
20 [Filed Concurrently with Cross-Defendants’
Motion to Quash and [Proposed] Order]
21 AND RELATED CROSS-ACTIONS
Date: December 15, 2023
22 Time: 9:00 a.m.
Dept.: 16
23
24 Assigned to Hon. Lia Martin
Dept. 16
25
27
28
DECLARATION OF MARC-OLIVIER PERRIN

1 DECLARATION OF MARC-OLIVIER PERRIN
2 I, Marc-Olivier Perrin, declare as follows:
3 1. I am president of SAS Miraval Provence (“Miraval Provence”) and SAS
4 Familles Perrin (“Familles Perrin”) and a named cross-defendant in this case. I make this
5 declaration as a special appearance in support of the motion to quash service of the
6 Summons and Cross Complaint filed by Cross-Plaintiff Nouvel, LLC, on the ground that
7 Miraval Provence, Familles Perrin, and I are not subject to the jurisdiction of this Court.
8 Unless otherwise stated, I have personal knowledge of the facts set forth herein, which are
9 known by me to be true and correct, and if called as a witness, I could and would
10 competently testify thereto.
11 2. I am a French citizen and I live and work in France.
12 3. I have never studied, resided, or been employed in California. I have never
13 personally owned property in California, had a bank account in California, or registered an

14 automobile in California.
15 4. Familles Perrin is a French société par actions simplifiée (“SAS”), or joint
16 stock company, organized and existing under the laws of France. Its registered office is
17 located in Orange, France.
18 5. Familles Perrin has no offices, business records or employees in California.
19 It has no bank accounts and owns no property in California. It is not registered to do

20 business in California and does not have a registered agent to accept service of process in
21 California.
22 6. Miraval Provence is a French SAS organized and existing under the laws of
23 France. Its registered office is located in Orange, France.

24 7. Miraval Provence has no offices, business records or employees in
25 California. It has no bank accounts and owns no property in California. It is not registered
26 to do business in California and does not have a registered agent to accept service of
27 process in California.
28 8. Miraval Provence, Familles Perrin, and I have not consented to the exercise
2
1 of jurisdiction by the courts of the State of California.
2 I declare under penalty of perjury under the law the State of California that the
3 foregoing is true and correct, and that I executed this declaration on February 2023, in
4
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Marc
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1 PROOF OF SERVICE
3
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 September 20, 2023, I served the following document(s) described as
7 DECLARATION OF MARC-OLIVIER PERRIN IN SUPPORT OF CROSS-
DEFENDANTS MARC-OLIVIER PERRIN, FAMILLES PERRIN, AND MIRAVAL
8 PROVENCE’S MOTION TO (1) QUASH FOR LACK OF PERSONAL
JURISDICTION; AND (2) DISMISS OR STAY FOR FORUM NON CONVENIENS
9 on the interested parties in this action as follows:
10 SEE ATTACHED SERVICE LIST
11 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s)
to be sent from e-mail address dthrockmorton@birdmarella.com to the persons at the e-
12 mail 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
13 unsuccessful.
foregoing is true and correct.
15
Executed on September 20, 2023, at Los Angeles, California.
16
17
18
Debra L. Throckmorton
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1 SERVICE LIST
Bradbury Bradbury
12
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28
5
[DECLARATION OF MARC-OLIVIER PERRIN
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WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al.
Case Number: 22STCV06081 Case Type: Civil Unlimited Category: Other Breach of Contract/Warranty (not
fraud or negligence)
Date Filed: 2022-02-17 Location: Stanley Mosk Courthouse - Department 16
Reservation
Case Name: Case Number:
WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al. 22STCV06081
Type: Status:
Motion to Quash Service of Summons RESERVED
Filing Party: Location:
Marc Olivier Perrin (Cross-Defendant) Stanley Mosk Courthouse - Department 16
Date/Time: Number of Motions:
12/15/2023 9:00 AM 1
Reservation ID: Confirmation Code:
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Fees
Description
Description Fee
Fee Qty
Qty Amount
Amount
Motion to Quash Service of Summons 60.00 1 60.00
Credit Card Percentage Fee (2.75%) 1.65 1 1.65
TOTAL $61.65
$61.65
Payment
Amount: Type:
$61.65 AmericanExpress
Account Number: Authorization:
XXXX6081 255345
Payment Date:
1969-12-31
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EXHIBIT 2
1 KEITH R. HUMMEL (admitted pro hac vice)
khummel@cravath.com
3
5 825 Eighth Avenue
New York, NY 10019
6 Telephone: (212) 474-1000
7 Facsimile: (212) 474-3700
8 JOE H. TUFFAHA (State Bar No. 253723)

9 PRASHANTH CHENNAKESAVAN (State Bar No. 284022)
11 300 S. Grand Avenue

Suite 3950
12 Los Angeles, California 90071-3426
Telephone: (213) 612-8900
13

16 COUNTY OF LOS ANGELES
17 WILLIAM B. PITT, an individual, and Case No. 22STCV06081
18 MONDO BONGO, LLC, a California
limited liability company, DEFENDANT AND CROSS-
19 COMPLAINANT NOUVEL, LLC’S
Plaintiffs, FIRST SET OF REQUESTS FOR
20 PRODUCTION TO CROSS-
vs. DEFENDANT MARC-OLIVIER
21 PERRIN RE: PERSONAL
ANGELINA JOLIE, an individual, and JURISDICTION
22 NOUVEL, LLC, a California limited
liability company, YURI SHEFLER, an Judge: Hon. Lia Martin
23
individual, ALEXEY OLIYNIK, an Dept.: 16
24 individual, SPI GROUP HOLDING
LIMITED, a Cyprus private limited Action Filed: February 17, 2022
25 company, and TENUTE DEL MONDO Trial Date: None set.
B.V., a Netherlands private limited
26 company,
27 Defendants.
28
DEFENDANT AND CROSS-COMPLAINANT NOUVEL, LLC’S FIRST SET OF REQUESTS FOR

PRODUCTION TO CROSS-DEFENDANT MARC-OLIVIER PERRIN RE: PERSONAL JURISDICTION
liability company,
2
Cross-Complainant,
3 vs.
4 WILLIAM B. PITT, an individual,
6
limited liability company, VINS ET
company, SAS MIRAVAL STUDIOS, a
12 French limited liability company, SASU
13 company, SAS DISTILLERIES DE LA
15
Cross-Defendants.
16
17
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24
25
26 Propounding Party: Defendant and Cross-Complainant Nouvel, LLC

27 Responding Party: Cross-Defendant Marc-Olivier Perrin
28 Set No.: One

1 Pursuant to Sections 2031.010, et seq., of the California Code of Civil Procedure,
2 Defendant and Cross-Complainant Nouvel, LLC demands that Cross-Defendant Marc-Olivier
3 Perrin produce and permit Defendant and Cross-Complainant Nouvel, LLC to inspect and to copy
4 the documents described in the following requests for production (each, a “Request,” and
5 collectively, the “Requests”) on or before October 30, 2023, at the offices of LTL Attorneys LLP,
6 300 S. Grand Avenue, Suite 3950, Los Angeles, California 90071.
7 DEFINITIONS
8 1. Unless otherwise specified, the relevant time period for these requests is January 1,
9 2013, through the present.

10 2. “Affiliate”, in relation to a given Person, shall refer to any Person that controls, is
11 controlled by, or is under common control with, such Person.
12 3. “Campari Group” shall refer to Davide Campari-Milano N.V., a Dutch public

13 company with a corporate office at Via F. Sacchetti, 20 – 20099 Sesto San Giovanni, Milan, Italy.
14 4. “Chateau Miraval” shall refer to SA Chateau Miraval, a company established and

15 having its registered office in F-83570 Correns, Domaine de Miraval, France.
16 5. “Chateau Miraval Estate” or “Estate” shall refer to the 1300-acre country estate in
17 the south of France consisting of a manor house, vineyards, and numerous other buildings that is
18 owned by Chateau Miraval.
19 6. “Communications” means any act or instance of transferring, transmitting, passing,

20 delivering, or giving information by oral, written, or electronic means, including, but not limited
21 to, by notes, letter, telegram, facsimile, electronic mail, electronic message (including text
22 message), or voicemail.
23 7. “Document(s)” means the full and broadest scope of documents and things
24 discoverable under California law and includes, without limitation, all writings (as defined in
25 Section 250 of the California Evidence Code) and any written material, whether typed,
26 handwritten, printed or otherwise, and whether in draft or final form, of any kind or nature, or any
27 photograph, photostat, microfilm or other reproduction thereof, including, without limitation, each
28 note, memorandum, letter, telegram, telex, circular, release, article, report, prospectus,

1 memorandum of any telephone or in-person conversation, any financial statement, analysis,
2 drawing, graph, chart, account, book, notebook, draft, summary, diary, transcript, computer data
3 base, computer printout or other computer generated matter, and other data compilations, and any
4 other documents or electronically stored information in any medium from which information can
5 be obtained, whether directly or, if necessary, after translation into a reasonably usable form.
6 Electronic mail, instant messages, text messages, voice mail and any pictures, video, or sound
7 recorded by any means are included within the definition of the terms “Document” or
8 “Documents.” A draft or non-identical copy, including a copy with handwritten notes, is a
9 separate Document within the meaning of the term.

10 8. “Equity Investee” shall refer to any other Person in which a Person or any of its
11 subsidiaries or Affiliates has an equity or similar interest or investment.
12 9. “Familles Perrin” shall refer to Cross-Defendant SAS Familles Perrin, a French

13 company whose registered office is at La Ferrière, Route de Jonquières, 84100 Orange, France and
14 SAS Famille Perrin, a French company whose registered office is at La Ferrière, Route de
15 Jonquières, 84100 Orange, France.
16 10. “SAS Petrichor” or “Petrichor” shall refer to SAS Petrichor, a French limited
17 liability company that has its registered address at 2321 Route de Jonquières 84100, Orange,
18 France.
19 11. “Vins et Domaines Perrin” shall refer to Vins et Domaines Perrin SC, a French
20 company that has its registered address at 2321 Route de Jonquières 84100, Orange, France.
21 12. “Distilleries de la Riviera” shall refer to SAS Distilleries de la Riviera, a French

22 limited liability company that has its registered address at 2321 Route de Jonquières 84100,
23 Orange, France.
24 13. “Fleur de Miraval” shall refer to SAS Fleur de Miraval, a French company whose
25 registered office is at 26-28 Rue des Lombards 51190 Le Mesnil-sur-Oger, France.
26 14. “Le Domaine” shall refer to Le Domaine Skincare, a French limited liability
27 company with its registered office at 2321 Route de Jonquières 84100, Orange, France.
28
-2-
1 15. “Miraval Provence” shall refer to Cross-Defendant SAS Miraval Provence, a joint
2 venture between Chateau Miraval and Familles Perrin headquartered at La Ferrière, Route de
3 Jonquières 84100, Orange, France.
4 16. “Miraval Studios” shall refer to SAS Miraval Studios, a French company whose
5 registered office is at F-83570 Correns, Domaine de Miraval, France.
6 17. “Mondo Bongo” shall refer to Plaintiff and Cross-Defendant Mondo Bongo, LLC,
7 a limited liability company incorporated under the laws of California, having its registered office
8 at 9100 Wilshire Boulevard, STE 1000W, Beverly Hills, California 90212.
9 18. “Mr. Bradbury” shall refer to Cross-Defendant Gary Bradbury.

10 19. “Mr. Grant” shall refer to Cross-Defendant Warren Grant.
11 20. “Mr. Pitt” shall refer to Plaintiff and Cross-Defendant William B. Pitt.
12 21. “Mr. Venturini” shall refer to Cross-Defendant Roland Venturini.
13 22. “Ms. Bird” shall refer to Terry Bird.
14 23. “Ms. Jolie” shall refer to Defendant Angelina Jolie.
15 24. “Mr. Oliynik” shall refer to Defendant Alexey Oliynik.
16 25. “Nouvel” shall refer to Defendant and Cross-Plaintiff Nouvel, LLC, a limited
17 liability company under the laws of California, established and having its registered office at 500
18 Capitol Mall, Suite 1600, Sacramento, California, 95814.
19 26. “Person” or “Persons” shall mean any natural person or any legal person, including
20 but not limited to any business, legal, or governmental entity or association and includes that
21 Person and, as applicable, each and all of (a) his or her present and former employees, agents, or
22 representatives; (b) his or her present and former attorneys, accountants, or advisors; (c) any
23 professional employed or retained by him or her; (d) any entity over which he or she exercises
24 control; and (e) any other Persons acting or purporting to act on his or her behalf.
25 27. “Quimicum” shall refer to Quimicum S.à r.l, a limited liability company (société à
26 responsabilité limitée), established and having its registered office at L-5365 Munsbach, 6C, rue
27 Gabriel Lippmann, Grand Duchy of Luxembourg.
28
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1 28. “SCEA Miraval” shall refer to SCEA Miraval, a French company whose registered
2 office is at 83143 Le Val, 4515 Route de Barjols, Domaine de Miraval, France.
3 29. The terms “You” and “Your” shall refer to Cross-Defendant Marc-Olivier Perrin
4 and any of your current or former agents, attorneys, accountants, employees, partners or other
5 persons occupying similar positions or performing similar functions, acting either individually or
6 collectively; and all persons either acting or purporting to act on behalf of the above.
7 INSTRUCTIONS
8 1. CCP §§ 2017.010–2017.020, 2031.010–2031.320 are hereby incorporated by
9 reference and apply to each of the following instructions,

10 2. The following rules of construction apply to all Requests:
11 a. The terms “any,” “all,” “each,” and “every” should be understood in either
12 their most or least inclusive sense as necessary to bring within the scope of a
13 Request all Documents or Communications that might otherwise be construed to be
14 outside of its scope.
15 b. The terms “and” and “or” shall be construed either disjunctively or
16 conjunctively as necessary to bring within the scope of a Request all Documents or
17 Communications that might otherwise be construed to be outside of its scope.
18 c. The terms “concern,” “concerning,” “relate,” and “relating to” shall be
19 construed as broadly as possible and shall mean and include, without limitation,
20 constituting, comprising, setting forth, summarizing, reflecting, stating, supporting,
21 weakening, describing, recording, noting, embodying, mentioning, studying,
22 analyzing, discussing, or evaluating, directly or indirectly.
23 d. The term “including” shall be construed as broadly as possible and shall
24 mean “including without limitation.”
25 e. The use of a verb in any tense, mood, or voice shall be construed as the use
26 of the verb in all tenses, moods, or voices, as necessary to bring within the scope of
27 a Request all Documents or Communications that might otherwise be construed to
28 be outside of its scope.
-4-
1 f. The use of the singular form of any word shall be taken to mean the plural
2 as well as the singular, and the use of the plural form of any word shall be taken to
3 mean the singular as well as the plural.
4 g. The use of the masculine gender shall include the feminine, neuter, and any
5 other genders.
6 3. Produce all Documents described below which are in Your possession, custody, or
7 control, including those Documents in the possession, custody, or control of Your present or
8 former attorneys or counsel, advisors, investigators, accountants, employees or other agents, as
9 well as any other Persons or entities acting on Your behalf, wherever located and in whatever form
10 they may exist.
11 4. Produce all Documents in their entirety, without deletion or excision, and along
12 with any attachments, regardless of whether You consider the entirety of any such Documents or
13 attachments to be responsive to any Request.
14 5. In objecting to any Request, identify the specific grounds for the objection and the
15 part of the Request objected to, and state with specificity which Documents will be withheld and
16 which Documents will be produced notwithstanding such objection.
17 6. If any Document responsive to these Requests is withheld or redacted by You

18 under a claim of privilege, provide a privilege log describing the basis for the claim of privilege
19 and all information necessary for Nouvel and the Court to assess the claim of privilege.
20 7. If You are unable to answer or respond fully to any Request, answer or respond to
21 the extent possible and specify the reason(s) for Your inability to answer or respond in full. If
22 You have no Documents responsive to a particular Request, so state.
23 8. You must comply with your obligations under CCP § 2031.230 in all respects,
24 including your obligation to set forth the name and address of any natural person or organization
25 known or believed to have possession, custody, or control of any Documents that have been
26 destroyed, lost, misplaced, stolen, or which are not in Your possession, custody, or control.
27 9. Subject to any protocol governing the production and use of ESI that may be
28 agreed to by You and Nouvel or ordered by the Court, all Documents shall be Bates labeled and
-5-
1 shall be produced electronically in single page Group IV TIF format (except that Microsoft Excel,
2 PowerPoint, and structured data files shall be produced in native format), with load files
3 containing, for each Document, extracted searchable text and all available metadata for at least the
4 following fields: BEGBATES; ENDBATES; BEGBATESATT; ENDBATESATT; All
5 Custodians; File Name; Email Importance; File Type; File Size; Page Count; Author; Subject;
6 From; To; CC; BCC; Sent Date; Received Date; Date Appointment Start; Date Appointment End;
7 Time Zone Processed; MD5 Hash; and Redaction.
8 REQUESTS FOR PRODUCTION
9 Request for Production No. 1:

10 All Documents and Communications concerning any visits or trips You or any of Your
11 agents or representatives made to the State of California that in any way concerned Nouvel,
12 Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries, Affiliates or Equity
13 Investees, including Miraval Provence, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval
14 Studios, Le Domaine, or Distilleries de la Rivera.
17 agents or representatives made to the State of California to meet with Mr. Pitt, Mondo Bongo,
18 Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their agents, representatives, or Affiliates.
20 All Documents and Communications, including records of any telephone calls or video
21 calls, concerning any Communications between You, Familles Perrin, Vins et Domaines Perrin, or
22 any of Your or their subsidiaries, Affiliates, or Equity Investees, including Miraval Provence,
23 SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la
24 Rivera, or any of Your or their agents or representatives, on the one hand, and any Person located
25 in the State California, on the other hand, concerning Nouvel, Mondo Bongo, Quimicum, Chateau
26 Miraval, or any of their subsidiaries, Affiliates or Equity Investees, including Miraval Provence,
28 Rivera.
-6-
3 calls, concerning any Communications between You, Familles Perrin, Vins et Domaines Perrin, or
4 any of Your or their subsidiaries, Affiliates or Equity Investees, including Miraval Provence,
6 Rivera, or any of their agents or representatives, on the one hand, and Mr. Pitt, Mondo Bongo, Mr.
7 Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their agents, representatives, or Affiliates, on the
8 other hand.

10 All Documents and Communications concerning any contracts, arrangements, or
11 understandings, oral or in writing, between You, Familles Perrin, Vins et Domaines Perrin, or any
12 of Your or their subsidiaries, Affiliates, or Equity Investees, including Miraval Provence, SCEA
13 Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera, on
14 the one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or of their
15 Affiliates, on the other hand.
17 All Documents and Communications concerning the effect on Ms. Jolie or Nouvel of any
18 of the acts or transactions alleged in the Second Amended Complaint or the First Amended Cross-
19 Complaint.
21 All Documents and Communications concerning (1) any obligations, including
22 indemnification obligations, that You, Familles Perrin, Vins et Domaines Perrin, or any of Your or
23 their subsidiaries, Affiliates, or Equity Investees, including Miraval Provence, SCEA Miraval,
24 Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera owe to; or
25 (2) any rights, including indemnification rights, that You, Familles Perrin, Vins et Domaines
26 Perrin, or any of Your or their subsidiaries, Affiliates, or Equity Investees, including Miraval
27 Provence, Fleur de Miraval, SCEA Miraval, Petrichor, Miraval Studios, Le Domaine, or
28
-7-
1 Distilleries de la Rivera have against Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel,
2 Ms. Bird, or any of their Affiliates.
4 All Documents and Communications concerning Your involvement in, assistance to, or
5 contribution to, any directive, order or request made from California by Mr. Pitt, Mondo Bongo,
6 Mr. Grant, their agents, representatives, or Affiliates, or any Person located in the State of
7 California to Mr. Venturini or Mr. Bradbury concerning Nouvel, Quimicum, Chateau Miraval, or
8 any of their subsidiaries, Affiliates, or Equity Investees, including Miraval Provence, Fleur de
9 Miraval, SCEA Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera.

12 contribution to, any action, Communication, order, directive, or request made from California by
13 Mr. Pitt, Mondo Bongo, Mr. Grant, their agents, representatives, or Affiliates, or any Person
14 located in the State of California in connection with efforts or plans to control, direct, supervise, or
15 oversee Quimicum, Chateau Miraval, or any of their subsidiaries, Affiliates, or Equity Investees,
16 including Miraval Provence, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le
17 Domaine, or Distilleries de la Rivera, or any of their presidents, managers, officers, or directors.
20 contribution to, any actual or contemplated efforts in the State of California by Mr. Pitt, Mondo
21 Bongo, Mr. Grant, their agents, representatives, or Affiliates, or any Person in the State of
22 California to block or prevent Nouvel, Ms. Jolie, or Ms. Bird from supervising, overseeing,
23 governing, obtaining information about, or participating in the affairs of Quimicum, Chateau
24 Miraval, or any of their subsidiaries, Affiliates, or Equity Investees, including Miraval Provence,
26 Rivera.
27
28
-8-
2 All Documents and Communications concerning any involvement or participation by You
3 or any of Your agents, representatives, or Affiliates in responding to any request, including any
4 request for information, made by Nouvel, Ms. Jolie, or Ms. Bird, concerning Quimicum, Chateau
6 Vins et Domaines Perrin, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le
7 Domaine, or Distilleries de la Rivera.
10 contribution to any actual or contemplated actions in or Communications from the State of
11 California by Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or of their agents,
12 representatives, or Affiliates, or any Person located in the State of California relating to the
13 payment, or lack thereof, of dividends from Chateau Miraval or Quimicum.
16 contribution to any actual or contemplated efforts in the State of California by Mr. Pitt, Mondo
17 Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, their agents, representatives, or Affiliates, or any
18 Person located in the State of California to renovate, to oversee or supervise renovations to, to
19 make improvements to, to oversee or supervise improvements to, to make additions to, or to
20 oversee or supervise any additions to the Chateau Miraval Estate or to any buildings,
21 constructions, or attachments on or near the Estate.
23 All Documents and Communications concerning the expected or actual effect of any actual
24 or contemplated renovations, improvements to, or additions to the Chateau Miraval Estate, or to
25 any buildings, constructions, or attachments on or near the Estate, on Ms. Jolie or Nouvel.
27 All Document and Communications concerning Your involvement in, assistance to, or
28 contribution to any action, Communication, order, direction, or request made by Mr. Pitt, Mondo
-9-
2 Person located in the State of California concerning the shareholder deadlock at Quimicum, the
3 appointment of directors of Quimicum, or the appointment of directors of Chateau Miraval.
5 All Documents and Communications concerning the expected or actual effect of the
6 shareholder deadlock at Quimicum on Ms. Jolie and Nouvel.
8 All Documents and Communications concerning any contracts, agreements, arrangements,
9 or understandings, oral or in writing, between You, Familles Perrin, Vins et Domaines Perrin,
10 Miraval Provence, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or
11 Distilleries de la Rivera, on the one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie,
12 Nouvel, Ms. Bird, their agents, representatives, or Affiliates, or any Person located in the State of
13 California, on the other hand, concerning Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or
14 any of their subsidiaries, Affiliates or Equity Investees, including Miraval Provence, SCEA
15 Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera, or
16 any intellectual property currently or previously owned by Chateau Miraval.
19 calls, concerning any Communications between You or any of Your agents or representatives and
20 any Person located in the State of California concerning (1) the Long-Term Trademark License
21 Agreement between Chateau Miraval and Miraval Provence and any amendments thereto; (2)
22 Miraval Provence’s rights in or registrations of any intellectual property of Chateau Miraval; (3)
23 the rates that Familles Perrin charges Miraval Provence for bottling; (4) the creation or registration
24 of any entity whose legal or trade name contains the word “Miraval” or a similar word; or (5) the
25 use of Chateau Miraval’s assets by Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine,
26 Distilleries de la Rivera, or any entity in which Mr. Pitt, Mondo Bongo, Mr. Grant, or any of their
27 subsidiaries, Affiliates, or Equity Investees hold an equity interest.
28
-10-
2 All Documents and Communications concerning the effect on Ms. Jolie or Nouvel of
3 (1) the Long-Term Trademark License Agreement between Chateau Miraval and Miraval
4 Provence and any amendments thereto; (2) Miraval Provence’s rights in or registrations of any
5 intellectual property of Chateau Miraval; (3) the rates that Familles Perrin charges Miraval
6 Provence for bottling; (4) the creation or registration of any entity whose legal or trade name
7 contains the word “Miraval” or a similar word; or (5) the use of Chateau Miraval’s assets by Fleur
8 de Miraval, Petrichor, Miraval Studios, Le Domaine, Distilleries de la Rivera, or any entity in
9 which Mr. Pitt, Mondo Bongo, Mr. Grant, or any of their subsidiaries, Affiliates or Equity
10 Investees hold an equity interest.
12 All Documents and Communications concerning the registration of any trademark in the
13 United States that is registered by Chateau Miraval or that uses the name “Miraval” or a similar
14 word.
16 All Documents and Communications concerning any financial payments, transfers, or
17 transactions between You, Familles Perrin, Vins et Domaines Perrin, Miraval Provence, SCEA
19 any of Your or their subsidiaries, Affiliates, or Equity Investees, on the one hand, and Mr. Pitt,
20 Mondo Bongo, Mr. Grant, Nouvel, Ms. Jolie, or Ms. Bird, or their agents, representatives, or
24 transactions between You, Familles Perrin, Vins et Domaines Perrin, Miraval Provence, SCEA
26 any of Your or their subsidiaries, Affiliates, or Equity Investees, on the one hand, and any Person
27 located in the State of California, on the other hand, related to Quimicum, Chateau Miraval, Vins
28 et Domaines Perrin, or any of their subsidiaries, Affiliates, or Equity Investees, including Miraval
-11-
1 Provence, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or
2 Distilleries de la Rivera.
4 All Documents and Communications concerning the reduction of Chateau Miraval’s
5 ownership interest in Miraval Provence from 50% to 49.97%, as evidenced by the reduction in the
6 number of shares in Miraval Provence held by Chateau Miraval from 5,000 to 4,997 in 2021.
8 All Documents and Communications concerning the distribution agreement between
9 Miraval Provence and Campari Group and its effect on Nouvel.

11 All Documents and Communications concerning any negotiations with Ms. Jolie that
12 reflect contacts with California concerning the sale of her interest in Quimicum and Chateau
13 Miraval.
15 All drafts of agreements with Ms. Jolie concerning the sale of her interest in Quimicum
16 and Chateau Miraval.
19 contribution to any action, Communication, order, direction, or request concerning shareholder
20 loans or other financial contributions made by Pitt, Mondo Bongo, Jolie, or Nouvel to Quimicum,
21 Chateau Miraval, or any of their Affiliates, subsidiaries, or Equity Investees, including Miraval
25 Documents sufficient to identify all businesses or any Affiliates thereof in which You have
26 an equity interest that distribute wine produced by Chateau Miraval or its subsidiaries and are
27 incorporated or headquartered in the State of California.
28
-12-
2 All Documents and Communications concerning Your business activities in California.
4 All Documents that You have signed that contain a forum-selection clause subjecting You
5 to the jurisdiction of a California court.
7 All Documents and Communications concerning any voluntary appearance You made at a
8 court proceeding in California.

10 All Documents and Communications concerning any real estate or other physical or
11 intangible assets located in California that You have or held an interest in, and/or own or owned
12 individually, or through an Equity Investee.
14 All Documents and Communications concerning any bank accounts in California in which
15 You have or had an interest and/or owned, individually, or through an Equity Investee, at any time
16 between October 2012 and the present.
18 All Documents and Communications You intend to rely upon in support of Your motion to
19 quash filed on September 20, 2023.
20
21
22
23
24
25
26
27
28
-13-
1 DATED: September 26, 2023 CRAVATH, SWAINE & MOORE LLP
Keith R. Hummel
2 Justin C. Clarke
Jonathan Mooney
3
4 LTL ATTORNEYS LLP

Joe H. Tuffaha
5 Prashanth Chennakesavan
6
7 By: /s/ Jonathan Mooney

8 JONATHAN MOONEY
Attorneys for Defendant and Cross-Complainant
9 NOUVEL, LLC
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-14-
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 New York, New York. My business address is 825 Eighth Avenue,
4 New York, NY 10019.
5 On September 26, 2023, I served true copies of the following document(s) described as
6 DEFENDANT AND CROSS-COMPLAINANT NOUVEL, LLC’S FIRST SET OF
REQUESTS FOR PRODUCTION RE: JURISDICTION TO CROSS-DEFENDANT
7 MARC-OLIVIER PERRIN on the interested parties in this action as follows:
8 John V. Berlinski William Savitt (admitted pro hac vice)

BIRD, MARELLA, BOXER, Jonathan M. Moses (admitted pro hac vice)
9 WOLPERT, NESSIM, Sarah K. Eddy (admitted pro hac vice)
DROOKS, LINCENBERG & Adam L. Goodman (admitted pro hac vice)
10 RHOW, P.C. Jessica L. Allen (admitted pro hac vice)
1875 Century Park East, Suite 2300 Remy Grosbard (admitted pro hac vice)
11 Los Angeles, CA 90067 WACHTELL, LIPTON, ROSEN & KATZ
Tel: (310) 201-2100 51 West 52nd Street
12 Email: jberlinski@birdmarella.com New York, NY 10019
Tel: (212) 403-1000
13 Fax: (212) 403-2000
Email: wdsavitt@wlrk.com, jmmoses@wlrk.com,
14 skeddy@wlrk.com, algoodman@wlrk.com,
jlallen@wlrk.com, rkgrosbard@wlrk.com
15
Attorneys for Plaintiffs and Cross-Defendants William B. Pitt and Mondo Bongo, LLC and Cross-
16
Defendant Warren Grant
17
Laura Brill (SB No. 195889) William Savitt (admitted pro hac vice)
18 Katelyn Kuwata (SB No. 319370) Jonathan M. Moses (admitted pro hac vice)
KENDALL BRILL & KELLY LLP Sarah K. Eddy (admitted pro hac vice)
19 10100 Santa Monica Blvd., Suite 1725 Adam L. Goodman (admitted pro hac vice)
Jessica L. Allen (admitted pro hac vice)
Los Angeles, CA 90067 Remy Grosbard (admitted pro hac vice)
20 Tel: (310) 556-2700 WACHTELL, LIPTON, ROSEN & KATZ
21 Fax: (310) 556-2705 51 West 52nd Street
Email: lbrill@kbkfirm.com New York, NY 10019
22 Email: kkuwata@kbkfirm.com Tel: (212) 403-1000
Fax: (212) 403-2000
23 Email: wdsavitt@wlrk.com, jmmoses@wlrk.com,
skeddy@wlrk.com, algoodman@wlrk.com,
24 jlallen@wlrk.com, rkgrosbard@wlrk.com
25 Attorneys appearing specially to challenge jurisdiction on behalf of Cross-Defendants Roland
Venturini and Gary Bradbury
26
27
28
PROOF OF SERVICE
1
Paul D. Murphy (SB No. 159556) Mark T. Drooks (SB No. 123561)
2 Daniel N. Csillag (SB No. 266773) BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
MURPHY ROSEN LLP DROOKS, LINCENBERG & RHOW, P.C.
3 100 Wilshire Blvd., Suite 1300 1875 Century Park East, Suite 2300
4 Tel: (310) 899-3300 Tel: (310) 201-2100
Fax: (310) 399-7201 Email: mdrooks@birdmarella.com
5 Email: pmurphy@murphyrosen.com,
dcsillag@murphyrosen.com S. Gale Dick (admitted pro hac vice)
Attorneys for Defendant and Cross- Phoebe H. King (admitted pro hac vice)
7 Complainant Angelina Jolie COHEN & GRESSER LLP
800 Third Avenue
Tel: (212) 957-7600
9 Email: sgdick@cohengresser.com,
rbryer@cohengresser.com, pking@cohengresser.com
10

12 SAS Miraval Provence, and SAS Familles Perrin
13 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. I did
14 not receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful.
15
16
17
18
Executed on September 26, 2023, in New York, New York.
19
/s/ Jonathan Mooney
20 JONATHAN MOONEY
21
22
23
24
25
26
27
28
-2-
PROOF OF SERVICE
khummel@cravath.com
3
5 825 Eighth Avenue
New York, NY 10019
6 Telephone: (212) 474-1000
7 Facsimile: (212) 474-3700


Suite 3950
Telephone: (213) 612-8900
13

vs. DEFENDANT SAS MIRAVAL
21 PROVENCE RE: PERSONAL
23
26 company,
27 Defendants.
28

PRODUCTION TO CROSS-DEFENDANT SAS MIRAVAL PROVENCE RE: PERSONAL JURISDICTION
liability company,
2
Cross-Complainant,
3 vs.
6
15
Cross-Defendants.
16
17
18
19
20
21
22
23
24
25

27 Responding Party: Cross-Defendant SAS Miraval Provence
28 Set No.: One

2 Defendant and Cross-Complainant Nouvel, LLC demands that Cross-Defendant SAS Miraval
3 Provence produce and permit Defendant and Cross-Complainant Nouvel, LLC to inspect and to
4 copy the documents described in the following requests for production (each, a “Request,” and
7 DEFINITIONS






12 9. “Familles Perrin” shall refer to Cross-Defendant SAS Familles Perrin, a French

13 company whose registered office is at La Ferrière, Route de Jonquières, 84100 Orange, France and
14 SAS Famille Perrin, a French company whose registered office is at La Ferrière, Route de
15 Jonquières, 84100 Orange, France.
18 France.

23 Orange, France.
28
-2-
8 19. "Mr. Perrin” shall refer to Cross-Defendant Marc-Olivier Perrin.
28
-3-
1 29. The terms “You” and “Your” shall refer to Cross-Defendant SAS Miraval
2 Provence, a joint venture between Chateau Miraval and Familles Perrin headquartered at La
3 Ferrière, Route de Jonquières 84100, Orange, France, and any of its current or former agents,
4 attorneys, accountants, employees, partners or other persons occupying similar positions or
5 performing similar functions, acting either individually or collectively; and all persons either
6 acting or purporting to act on behalf of the above.
7 INSTRUCTIONS

-4-
5 other genders.
10 they may exist.

-5-

11 directors, officers, employees, agents or representatives made to the State of California that in any
12 way concerned Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries,
13 Affiliates or Equity Investees, including You, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval
14 Studios, Le Domaine, or Distilleries de la Rivera.
17 directors, officers, employees, agents or representatives made to the State of California to meet
18 with Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their agents,
19 representatives, or Affiliates.
22 calls, concerning any Communications between You, any of Your subsidiaries, Affiliates, or
23 Equity Investees, or any of Your or their directors, officers, employees, agents or representatives,
24 on the one hand, and any Person located in the State California, on the other hand, concerning
25 Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries, Affiliates or
26 Equity Investees, including You, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le
27 Domaine, or Distilleries de la Rivera.
28
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3 calls, concerning any Communications between You, any of Your subsidiaries, Affiliates or
5 on the one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of
6 their agents, representatives, or Affiliates, on the other hand.
9 understandings, oral or in writing, between You, any of Your subsidiaries, Affiliates, or Equity
10 Investees, or any of Your or their directors, officers, employees, agents or representatives, on the
11 one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their
16 Complaint.
19 indemnification obligations, that You, any of Your subsidiaries, Affiliates, or Equity Investees, or
20 any of Your or their directors, officers, employees, agents or representatives owe to, or (2) any
21 rights, including indemnification rights, that You, any of Your subsidiaries, Affiliates, or Equity
22 Investees, or any of Your or their directors, officers, employees, agents or representatives have
23 against Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their Affiliates.
-7-
1 any of their subsidiaries, Affiliates, or Equity Investees, including You, Fleur de Miraval, SCEA
2 Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera.
9 including You, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or
10 Distilleries de la Rivera, or any of their presidents, managers, officers, or directors.
17 Miraval, or any of their subsidiaries, Affiliates, or Equity Investees, including You, SCEA
18 Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera.
20 All Documents and Communications concerning any involvement, assistance, or
21 contribution in responding to any request, including any request for information, made by Nouvel,
22 Ms. Jolie, or Ms. Bird, concerning Quimicum, Chateau Miraval, or any of their subsidiaries,
23 Affiliates, or Equity Investees, including You, Vins et Domaines Perrin, SCEA Miraval, Fleur de
24 Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera by You, any of Your
25 subsidiaries, Affiliates, or Equity Investees, or any of Your or their directors, officers, employees,
26 agents or representatives.
27
28
-8-
4 California by Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their
5 agents, representatives, or Affiliates, or any Person located in the State of California relating to the
27 or understandings, oral or in writing, between You, any of Your subsidiaries, Affiliates, or Equity
-9-
1 one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, their agents,
2 representatives, or Affiliates, or any Person located in the State of California, on the other hand,
3 concerning Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries,
4 Affiliates or Equity Investees, including You, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval
5 Studios, Le Domaine, or Distilleries de la Rivera, or any intellectual property currently or
6 previously owned by Chateau Miraval.
10 Equity Investees, or any of Your or their directors, officers, employees, agents or representatives
11 and any Person located in the State of California concerning (1) the Long-Term Trademark
12 License Agreement between You and Chateau Miraval and any amendments thereto; (2) Your
13 rights in or registrations of any intellectual property of Chateau Miraval; (3) the rates that Familles
14 Perrin charges You for bottling; (4) the creation or registration of any entity whose legal or trade
15 name contains the word “Miraval” or a similar word; or (5) the use of Chateau Miraval’s assets by
16 Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, Distilleries de la Rivera, or any entity
17 in which Mr. Pitt, Mondo Bongo, Mr. Grant, or any of their subsidiaries, Affiliates, or Equity
18 Investees hold an equity interest.
20 All Documents and Communications concerning the registration by any Person other than
21 Chateau Miraval of any trademark in the United States that is already registered by Chateau
22 Miraval or that uses the name “Miraval” or a similar word.
25 transactions between You, any of Your subsidiaries, Affiliates, or Equity Investees, or any of Your
26 or their directors, officers, employees, agents or representatives, on the one hand, and Mr. Pitt,

-10-
4 or their directors, officers, employees, agents or representatives, on the one hand, and any Person
6 et Domaines Perrin, or any of their subsidiaries, Affiliates, or Equity Investees, including You,
8 Rivera.

11 ownership interest in You from 50% to 49.97%, as evidenced by the reduction in the number of
12 shares in You held by Chateau Miraval from 5,000 to 4,997 in 2021.
14 All Documents and Communications concerning the distribution agreement between You
15 and Campari Group and its effect on Nouvel.
17 All Documents and Communications that reflect contacts with California concerning any
18 negotiations with Ms. Jolie concerning the sale of her interest in Quimicum and Chateau Miraval.
26 Chateau Miraval, or any of their Affiliates, subsidiaries, or Equity Investees, including You,
28 Rivera.
-11-
2 Documents sufficient to identify all of Your Equity Investees or any Affiliates thereof that
3 distribute wine produced by Chateau Miraval or its subsidiaries and are incorporated or
4 headquartered in the State of California.
8 All agreements that You have signed that contain a forum-selection clause subjecting You

16 individually or through an Equity Investee.
19 You have or had an interest and/or owned, individually or through an Equity Investee.
23
24
25
26
27
28
-12-
Keith R. Hummel
2 Justin C. Clarke
Jonathan Mooney
3
4 LTL ATTORNEYS LLP

Joe H. Tuffaha
6

8 JONATHAN MOONEY
9 NOUVEL, LLC
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1 PROOF OF SERVICE
REQUESTS FOR PRODUCTION RE: JURISDICTION TO CROSS-DEFENDANT SAS
7 MIRAVAL PROVENCE on the interested parties in this action as follows:

Tel: (212) 403-1000
13 Fax: (212) 403-2000
15
16
17
Fax: (212) 403-2000
26
27
28
PROOF OF SERVICE
1
4 Tel: (310) 899-3300 Tel: (310) 201-2100
800 Third Avenue
Tel: (212) 957-7600
10


15
16
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19
/s/ Jonathan Mooney
20 JONATHAN MOONEY
21
22
23
24
25
26
27
28
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PROOF OF SERVICE
khummel@cravath.com
3
5 825 Eighth Avenue
New York, NY 10019
6 Telephone: (212) 474-1000
7 Facsimile: (212) 474-3700


Suite 3950
Telephone: (213) 612-8900
13

vs. DEFENDANT SAS FAMILLES
21 PERRIN RE: PERSONAL
23
26 company,
27 Defendants.
28

PRODUCTION TO CROSS-DEFENDANT SAS FAMILLES PERRIN RE: PERSONAL JURISDICTION
liability company,
2
Cross-Complainant,
3 vs.
6
15
Cross-Defendants.
16
17
18
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20
21
22
23
24
25

27 Responding Party: Cross-Defendant SAS Familles Perrin
28 Set No.: One

2 Defendant and Cross-Complainant Nouvel, LLC demands that Cross-Defendant SAS Familles
3 Perrin produce and permit Defendant and Cross-Complainant Nouvel, LLC to inspect and to copy
4 the documents described in the following requests for production (each, a “Request,” and
7 DEFINITIONS







14 France.

19 Orange, France.
24 14. “Miraval Provence” shall refer to Cross-Defendant SAS Miraval Provence, a joint
25 venture between Chateau Miraval and Familles Perrin headquartered at La Ferrière, Route de
26 Jonquières 84100, Orange, France.
-2-
6 19. "Mr. Perrin” shall refer to Cross-Defendant Marc-Olivier Perrin.

26 29. The terms “You” and “Your” shall refer to Cross-Defendant SAS Familles Perrin, a
27 French company whose registered office is at La Ferrière, Route de Jonquières, 84100 Orange,
28 France and SAS Famille Perrin, a French company whose registered office is at La Ferrière, Route
-3-
1 de Jonquières, 84100 Orange, France, and any of its current or former agents, attorneys,
2 accountants, employees, partners or other persons occupying similar positions or performing
3 similar functions, acting either individually or collectively; and all persons either acting or
4 purporting to act on behalf of the above.
5 INSTRUCTIONS
27
28
-4-
5 other genders.
10 they may exist.

-5-

11 directors, officers, employees, agents or representatives made to the State of California that in any
12 way concerned Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries,
13 Affiliates or Equity Investees, including Miraval Provence, SCEA Miraval, Fleur de Miraval,
14 Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera.
17 directors, officers, employees, agents or representatives made to the State of California to meet
18 with Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their agents,
19 representatives, or Affiliates.
24 on the one hand, and any Person located in the State California, on the other hand, concerning
25 Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries, Affiliates or
26 Equity Investees, including Miraval Provence, SCEA Miraval, Fleur de Miraval, Petrichor,
27 Miraval Studios, Le Domaine, or Distilleries de la Rivera.
28
-6-
3 calls, concerning any Communications between You, any of Your subsidiaries, Affiliates or
5 on the one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of
6 their agents, representatives, or Affiliates, on the other hand.
9 understandings, oral or in writing, between You, any of Your subsidiaries, Affiliates, or Equity
11 one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their
16 Complaint.
19 indemnification obligations, that You, any of Your subsidiaries, Affiliates, or Equity Investees, or
20 any of Your or their directors, officers, employees, agents or representatives owe to, or (2) any
21 rights, including indemnification rights, that You, any of Your subsidiaries, Affiliates, or Equity
22 Investees, or any of Your or their directors, officers, employees, agents or representatives have
23 against Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their Affiliates.
-7-
1 any of their subsidiaries, Affiliates, or Equity Investees, including Miraval Provence, Fleur de
2 Miraval, SCEA Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera.
9 including Miraval Provence, SCEA Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le
10 Domaine, or Distilleries de la Rivera, or any of their presidents, managers, officers, or directors.
19 Rivera.
21 All Documents and Communications concerning any involvement, assistance, or
22 contribution in responding to any request, including any request for information, made by Nouvel,
23 Ms. Jolie, or Ms. Bird, concerning Quimicum, Chateau Miraval, or any of their subsidiaries,
24 Affiliates, or Equity Investees, including Miraval Provence, Vins et Domaines Perrin, SCEA
25 Miraval, Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera by
26 You, any of Your subsidiaries, Affiliates, or Equity Investees, or any of Your or their directors,
27 officers, employees, agents or representatives.
28
-8-
4 California by Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, or any of their
5 agents, representatives, or Affiliates, or any Person located in the State of California relating to the
27 or understandings, oral or in writing, between You, any of Your subsidiaries, Affiliates, or Equity
-9-
1 one hand, and Mr. Pitt, Mondo Bongo, Mr. Grant, Ms. Jolie, Nouvel, Ms. Bird, their agents,
2 representatives, or Affiliates, or any Person located in the State of California, on the other hand,
3 concerning Nouvel, Mondo Bongo, Quimicum, Chateau Miraval, or any of their subsidiaries,
4 Affiliates or Equity Investees, including Miraval Provence, SCEA Miraval, Fleur de Miraval,
5 Petrichor, Miraval Studios, Le Domaine, or Distilleries de la Rivera, or any intellectual property
6 currently or previously owned by Chateau Miraval.
10 Equity Investees, or any of Your or their directors, officers, employees, agents or representatives
11 and any Person located in the State of California concerning (1) the Long-Term Trademark
12 License Agreement between Chateau Miraval and Miraval Provence and any amendments thereto;
13 (2) Miraval Provence’s rights in or registrations of any intellectual property of Chateau Miraval;
14 (3) the rates that You charge Miraval Provence for bottling; (4) the creation or registration of any
15 entity whose legal or trade name contains the word “Miraval” or a similar word; or (5) the use of
16 Chateau Miraval’s assets by Fleur de Miraval, Petrichor, Miraval Studios, Le Domaine,
17 Distilleries de la Rivera, or any entity in which Mr. Pitt, Mondo Bongo, Mr. Grant, or any of their
18 subsidiaries, Affiliates, or Equity Investees hold an equity interest.
20 All Documents and Communications concerning the registration by any Person other than
21 Chateau Miraval of any trademark in the United States that is already registered by Chateau
22 Miraval or that uses the name “Miraval” or a similar word.
26 or their directors, officers, employees, agents or representatives, on the one hand, and Mr. Pitt,

-10-
4 or their directors, officers, employees, agents or representatives, on the one hand, and any Person
6 et Domaines Perrin, or any of their subsidiaries, Affiliates, or Equity Investees, including Miraval

11 ownership interest in Miraval Provence from 50% to 49.97%, as evidenced by the reduction in the
12 number of shares in Miraval Provence held by Chateau Miraval from 5,000 to 4,997 in 2021.
14 All Documents and Communications concerning the distribution agreement between
15 Miraval Provence and Campari Group and its effect on Nouvel.
17 All Documents and Communications that reflect contacts with California concerning any
18 negotiations with Ms. Jolie concerning the sale of her interest in Quimicum and Chateau Miraval.
26 Chateau Miraval, or any of their Affiliates, subsidiaries, or Equity Investees, including Miraval
-11-
2 Documents sufficient to identify all of Your Equity Investees or any Affiliates thereof that
3 distribute wine produced by Chateau Miraval or its subsidiaries and are incorporated or
4 headquartered in the State of California.
8 All agreements that You have signed that contain a forum-selection clause subjecting You

16 individually or through an Equity Investee.
19 You have or had an interest and/or owned, individually or through an Equity Investee.
23
24
25
26
27
28
-12-
Keith R. Hummel
2 Justin C. Clarke
Jonathan Mooney
3
4 LTL ATTORNEYS LLP

Joe H. Tuffaha
6

8 JONATHAN MOONEY
9 NOUVEL, LLC
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1 PROOF OF SERVICE
REQUESTS FOR PRODUCTION RE: JURISDICTION TO CROSS-DEFENDANT SAS
7 FAMILLES PERRIN on the interested parties in this action as follows:

Tel: (212) 403-1000
13 Fax: (212) 403-2000
15
16
17
Fax: (212) 403-2000
26
27
28
PROOF OF SERVICE
1
4 Tel: (310) 899-3300 Tel: (310) 201-2100
800 Third Avenue
Tel: (212) 957-7600
10


15
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/s/ Jonathan Mooney
20 JONATHAN MOONEY
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PROOF OF SERVICE
EXHIBIT 3
2 BIRD MARELLA LLP rd
1875 Century Park East, 23 Floor
Telephone: (310) 201-2100
4
800 Third Avenue
Telephone: (212) 957-7600
8
SAS Miraval Provence, SAS Familles Perrin, SAS
10 Petrichor, Vins et Domaines Perrin SC, SASU Le
Domaine, and SAS Distilleries de la Riviera
11
12
13
liability company, SPECIALLY APPEARING CROSS-
15 DEFENDANTS MARC-OLIVIER
PERRIN, SAS MIRAVAL PROVENCE,
Plaintiffs,
16 AND SAS FAMILLES PERRIN’S
MEMORANDUM OF POINTS AND
vs.
17 AUTHORITIES IN OPPOSITION TO
NOUVEL LLC’S MOTION TO COMPEL
ANGELINA JOLIE, et al.,
18 FURTHER DISCOVERY RESPONSES
Defendants.
19 Filed Concurrently with Separate Statement,
Declaration of S. Gale Dick, and Declaration
20 of Quentin de Margerie
21 Date: March 4, 2024
22 Time: 9:00 a.m.
Dept.: 16
23 Assigned to Hon. Lia Martin
24 RESERVATION NO.: 134640636368

27
28
PERRIN, MIRAVAL PROVENCE, AND FAMILLES PERRIN’S OPPOSITION TO NOUVEL’S MOTION TO

COMPEL
1 TABLE OF CONTENTS
2 MEMORANDUM OF POINTS AND AUTHORITIES ....................................................... 1

3 I. PRELIMINARY STATEMENT ................................................................................ 1
4 II. BACKGROUND ........................................................................................................ 1
5 III. ARGUMENT.............................................................................................................. 3
6 A. The French Cross-Defendants Should Not Be Ordered to Break
French Law. ..................................................................................................... 3
7
B. The Court Should Deny Nouvel’s Motion to Compel as to the
8 Disputed Requests. .......................................................................................... 9
9 1. Legal Standard. ................................................................................... 10
10 2. Nouvel’s Motion on RFPs 10–12 and 15 should be denied. .............. 10
11 3. Nouvel’s Motion on RFP 23 should be denied. ................................. 12
12 4. Nouvel’s Motion on RFPs 5 and 17 Should Be Denied..................... 13
13 5. Additional Issues Raised by Nouvel. ................................................. 15
14 IV. CONCLUSION ........................................................................................................ 15
15
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25
26
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2
COMPEL
1 TABLE OF AUTHORITIES
2 Page(s)
3 Cases
4
1880 Corp. v. Superior Court,
5 57 Cal. 2d 840 (1962)................................................................................................... 15
6 In re Air Cargo Shipping Servs. Antitrust Litig.,
7 278 F.R.D. 51 (E.D.N.Y. 2010) ..................................................................................... 8
8 Am. Home Assurance Co. v. Societe Commerciale Toutelectric,

104 Cal. App. 4th 406 (2002) ................................................................................ 3, 4, 8
9
In re Auto. Antitrust Cases I & II,
10 135 Cal. App. 4th 100 (2005) ................................................................................ 10, 11
11
Behrens v. Arconic, Inc.,
12 2020 WL 1250956 (E.D. Pa. Mar. 13, 2020) ................................................................. 9
13 Burdick v. Superior Ct.,
233 Cal. App. 4th 8 (2015) .......................................................................................... 10
14
15 Burger King Corp. v. Rudzewicz,
471 U.S. 462 (1985) ..................................................................................................... 14
16
Casey v. Hill,
17 79 Cal. App. 5th 937 (2022) ........................................................................................ 13
18
Connex R.R. LLC v. AXA Corp. Sols. Assurance,
19 2017 WL 3433542 (C.D. Cal. Feb. 22, 2017) ........................................................ 4, 7, 8
20 David L. v. Superior Ct.,
29 Cal. App. 5th 359 (2018) .................................................................................. 11, 13
21
22 eMag Sols., LLC v. Toda Kogyo Corp.,
2006 WL 3783548 (N.D. Cal. Dec. 21, 2006) ............................................................. 12
23
Epic Commc’ns, Inc. v. Richwave Tech., Inc.,
24 179 Cal. App. 4th 314 (2009) ...................................................................................... 14
25
Kashef v. BNP Paribas S.A.,
26 2022 WL 1617489 (S.D.N.Y. May 23, 2022)............................................................ 8, 9
27 Medimpact Healthcare Sys., Inc. v. IQVIA Holdings Inc.,
2020 WL 1433327 (S.D. Cal. Mar. 24, 2020) ............................................................. 11
28
3
COMPEL
1 MGI Digital Tech. S.A. v. Duplo U.S.A.,
2023 WL 6814579 (C.D. Cal. Aug. 24, 2023) ...................................................... passim
2
3 Minpeco, S.A. v. Conticommodity Servs., Inc.,
116 F.R.D. 517 (S.D.N.Y. 1987) ................................................................................... 8
4
Nissan Motor Co. v. Nissan Computer Corp.,
5 89 F. Supp. 2d 1154 (C.D. Cal. 2000) ......................................................................... 14
6 Proofpoint, Inc. v. Vade Secure, Inc.,
7 2020 WL 1911195 (N.D. Cal. Apr. 20, 2020) ............................................................... 8
8 Richmark Corp. v. Timber Falling Consultants,

959 F.2d 1468 (9th Cir. 1992).................................................................................... 5, 6
9
Robin Singh Educ. Servs., Inc. v. Nathan Cepelinski,
10
2021 WL 945243 (C.D. Cal. Jan. 26, 2021) ................................................................ 10
11
Salt River Project Agric. Improvement & Power Dist. v. Trench France SAS,
12 303 F. Supp. 3d 1004 (D. Ariz. 2018)........................................................................ 5, 9
13 Santa Barbara Smokehouse, Inc. v. AquaChile, Inc.,
14 2020 WL 13328094 (C.D. Cal. July 7, 2020) .............................................................. 13
15 Societe Nationale Industrielle Aérospatiale v. U.S. Dist. Ct. for S. Dist. of

Iowa,
16 482 U.S. 522 (1987) ............................................................................................... 3, 4, 5
17
Suzuki Motor Co. v. Superior Ct.,
18 200 Cal. App. 3d 1476 (1988)........................................................................................ 4
19 Vuksanovich v. Airbus Americas Inc.,
21-cv-03454 (JHR), Dkt. No. 94 (S.D.N.Y. Nov. 4, 2022) ........................................... 9
20
21 Walden v. Fiore,
571 U.S. 277 (2014) ..................................................................................................... 11
22
Wheeler v. Alison,
23 2014 WL 7157626 (E.D. Cal. Dec. 15, 2014) ............................................................. 14
24
Yamashita v. LG Chem, Ltd.,
25 62 F.4th 496 (9th Cir. 2023) ........................................................................................ 14
26 Zehia v. Superior Ct.
45 Cal. App. 5th 543 (2020) .................................................................................. 11, 12
27
28
4
COMPEL
1 Statutes
2 Cal. Code of Civ. Proc. § 2030.410 ................................................................................... 12
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
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22
23
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5
COMPEL
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I. PRELIMINARY STATEMENT
3 In seeking jurisdictional discovery from the French Cross-Defendants, Nouvel had a
4 choice. Nouvel could have respected French sovereignty and worked with the French Cross-
5 Defendants to engage in lawful and appropriately limited discovery, sparing the Court another
6 contentious motion in this sprawling litigation. Nouvel refused. Instead, Nouvel asks the Court to
7 force the French Cross-Defendants to: commit a crime under French law; disregard the sovereign
8 interests of France, which French authorities have already concluded are implicated by these
9 specific discovery requests and parties; and dismiss as a tiresome obstacle a treaty to which both
10 France and the United States are signatories—all in pursuit of discovery far beyond what Nouvel
11 is entitled to for purposes of opposing the French Cross-Defendants’ motion to quash.
12 Nouvel’s Motion to Compel (“Mot.”) flaunts international comity, judicial resources,
13 California procedure, and simple good sense. We respectfully ask the Court to deny the Motion in
14 its entirety.
15 II. BACKGROUND
16 Specially Appearing Cross-Defendants Marc-Olivier Perrin, SAS Familles Perrin, and SAS
17 Miraval Provence (collectively, the “French Cross-Defendants”) are citizens of France subject to
18 French law. The jurisdictional basis for the cross-claims against them is extraordinarily thin.
19 Nouvel alleges that the French Cross-Defendants engaged in conduct in France that impacted
20 French company SA Château Miraval, which in turn impacted Luxembourgish company
21 Quimicum S.à r.l., which in turn impacted a California company. On September 20, 2023, the
22 French Cross-Defendants moved to quash the First Amended Cross-Complaint (“FACC”) for lack
23 of personal jurisdiction and forum non conveniens.
24 In response, Nouvel served these parties with a total of 176 requests for production
25 (“RFPs”) and interrogatories (collectively, the “Requests”), under the guise of “jurisdictional”
26 discovery. 1 The French Cross-Defendants objected to the Requests because, among other things,
27
1
Mr. Perrin received 34 RFPs and 26 interrogatories. Miraval Provence and Familles Perrin each
28 received 32 RFPs and 26 interrogatories.
1
COMPEL
1 they vastly exceed the scope of permissible jurisdictional discovery and would require the French
2 Cross-Defendants to break French law. Specifically, French Law 68-678 of July 26, 1968 (the
3 “Blocking Statute”) forbids the production of certain categories of French documents and
4 information for use in foreign legal proceedings except through procedures set forth in
5 international treaties such as the Hague Convention of 18 March 1970 on the Taking of Evidence
6 Abroad in Civil or Commercial Matters (“Hague Convention”), to which both the United States
7 and France are signatories. (Declaration of Quentin de Margerie in Support of Opposition to
8 Nouvel’s Motion to Compel (“de Margerie Decl.”) ¶ 7).) Violation of the Blocking Statute is a
9 criminal offense punishable by fines and/or imprisonment. (Id. ¶ 11.)
10 As required by the Blocking Statute, on November 14, 2023, the French Cross-Defendants
11 gave notice of Nouvel’s Requests to the relevant French agency, the Service de I’information
12 Stratégique et de la Sécurité Économiques (“SISSE”). (Declaration of S. Gale Dick in Support of
13 Opposition to Nouvel’s Motion to Compel (“Dick Decl.”) Ex. 1.) On November 21, 2023, SISSE
14 determined that the Blocking Statute applied to the Requests. (Id.) SISSE did not prohibit the
15 French Cross-Defendants from producing documents altogether; it merely stated that discovery
16 must proceed via the Hague Convention. (Id.) SISSE explicitly reminded the French Cross-
17 Defendants that the statute “is a penal law of public order and of strict interpretation in its
18 application.” (Id.) 2 The French Cross-Defendants promptly notified Nouvel of SISSE’s
19 determination. (Dick Decl. Ex. 2.) Confoundingly, Nouvel makes no mention of SISSE’s
20 directive in its 400-plus-page submission.
21 Notwithstanding this dispute over the proper procedure for jurisdictional discovery, the
22 French Cross-Defendants negotiated with Nouvel as to the scope of this discovery in an effort to
23 avoid, or at least narrow, the need for judicial intervention. After protracted negotiations, the
24 parties reached agreement as to some, but not all, of the RFPs. Nouvel’s RFPs therefore fall into
25
26
27
2
SISSE recently reiterated both its instruction to proceed through the Hague Convention and its
28 warning of potential penal consequences of not doing so. (Dick Decl. Ex 3, at 4–5.)
2
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1 two buckets: (1) the Agreed Requests (RFPs 1–4, 6, 14, 16, 18–22, and 34) 3; and the Disputed
2 Requests (RFPs 5, 10–12, 15, 17, and 23), which are before the Court because Nouvel rejected the
3 French Cross-Defendants’ reasonable counterproposals.
4 III. ARGUMENT
5 A. The French Cross-Defendants Should Not Be Ordered to Break French Law.
6 Nouvel cannot dispute that the Blocking Statute forbids the French Cross-Defendants from
7 producing documents unless Hague Convention procedures are used. (Dick Decl. Exs. 1, 3; de
8 Margerie Decl. ¶ 7.) The relevant French authorities have expressly confirmed the applicability of
9 this prohibition and reminded the French Cross-Defendants that they face criminal sanctions
10 unless they proceed through the Hague Convention. (Dick Decl. Exs. 1, 3.) This determination
11 should end the inquiry: discovery must proceed through the Hague Convention and the French
12 Cross-Defendants should not be compelled to break the law.
13 If the Court were not inclined to adopt SISSE’s conclusion, California law and
14 international comity require a “particularized analysis” of the following factors before compelling
15 foreign citizens to violate foreign law: (1) the importance to the litigation of the documents
16 requested; (2) the degree of specificity of the requests; (3) whether the information originated in
17 the United States; (4) the availability of alternative means of securing the information; and (5) the
18 extent to which important interests of the United States or a foreign nation are at stake. Societe
19 Nationale Industrielle Aérospatiale v. U.S. Dist. Ct. for S. Dist. of Iowa, 482 U.S. 522, 543–44 &
20 n.28 (1987) (“Aérospatiale”) 4; Am. Home Assurance Co. v. Societe Commerciale Toutelectric, 104
21 Cal. App. 4th 406, 425–26 (2002) (adopting Aérospatiale in the context of merits discovery). The
22 Ninth Circuit also considers the hardship faced by the foreign national and the likelihood of
23 compliance with “enforcement by action of either state.” MGI Digital Tech. S.A. v. Duplo U.S.A.,
24 2023 WL 6814579, at *3 (C.D. Cal. Aug. 24, 2023). This analysis decisively favors the use of
25
3
Nouvel’s Separate Statement only reflects the text of the RFPs served on Mr. Perrin.
26 Accordingly, the RFP numbers referenced correspond with the numbering in the RFPs served on
Mr. Perrin. The RFPs served on Miraval Provence and Familles Perrin bear different numbering.
27
4
Except as otherwise specified, internal quotation marks, citations, alterations, and subsequent
28 history are omitted from the authorities cited in this brief.
3
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1 Hague Convention procedures, particularly given that the Court has yet to determine whether it
2 has jurisdiction at all.
3 Factor 1: Importance of the Documents. “Where the outcome of litigation ‘does not
4 stand or fall on the present discovery order, or where the evidence sought is cumulative of existing
5 evidence,’ courts have generally been unwilling to override foreign laws.” Id. (quoting Richmark
6 Corp. v. Timber Falling Consultants, 959 F.2d 1468, 1475 (9th Cir. 1992)). Nouvel argues that
7 this factor favors discovery pursuant to the California Code because the Requests seek discovery
8 related to a dispositive issue, i.e., personal jurisdiction. (Mot. at 5.) But quashing service here
9 would not determine any party’s substantive rights; it would simply mean that Nouvel would have
10 to pursue them in another jurisdiction. Moreover, neither the U.S. Supreme Court nor the
11 California Supreme Court have determined whether Aérospatiale applies in the context of
12 jurisdictional discovery at all. Aérospatiale, 482 U.S. at 524 (noting that personal jurisdiction was
13 not disputed in the litigation). 5 Furthermore, much of what Nouvel seeks is cumulative of
14 evidence already in its position or otherwise available. Several RFPs call for communications
15 with Nouvel itself (which Nouvel presumably has). Others seek communications with Mr. Pitt or
16 other California residents who are subject to the Court’s jurisdiction and will be or have been
17 subject to discovery. (RFPs 3, 4, 18, and 20.) And Nouvel, which argues that jurisdiction exists
18 here because the French Cross-Defendants “direct[ed] communications to California residents, Pitt
19 and Mondo Bongo,” (FACC ¶¶ 56–58), has already obtained substantial discovery from Mr. Pitt
20 and is poised to receive more. As stated in a case Nouvel itself cites, “the fact that Plaintiffs
21 should already have most if not all responsive documents weighs against” compelling discovery
22 through the California Code in the comity analysis. Connex R.R. LLC v. AXA Corp. Sols.
23 Assurance, 2017 WL 3433542, at *15 (C.D. Cal. Feb. 22, 2017).
24
25 5
Cf. Am. Home, 104 Cal. App. 4th at 426; Suzuki Motor Co. v. Superior Ct., 200 Cal. App. 3d
26 1476, 1484 (1988) (noting that Aérospatiale held that the Hague Convention “is not the only
means of obtaining discovery from a foreign defendant once the district court has obtained
27 jurisdiction over the defendant.” (emphasis in original)). Because the balance of comity factors
requires discovery via the Hague Convention, the Court need not decide whether Aérospatiale
28 applies to jurisdictional discovery disputes.
4
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1 Factor 2: Specificity of the Requests. The second comity factor considers the specificity
2 of the requests, including whether they are “reasonably limited in time.” Richmark, 959 F.2d at
3 1475. Because Nouvel’s Requests are “broad [and] generalized” rather than “specific [and]
4 limited,” this factor favors use of the Hague Convention. Salt River Project Agric. Improvement
5 & Power Dist. v. Trench France SAS, 303 F. Supp. 3d 1004, 1008 (D. Ariz. 2018) (citing
6 Richmark, 959 F.2d at 1475).
7 Nouvel’s insistence that its requests are “narrowly tailored to the [French] Cross-
8 Defendants’ contacts with California,” (Mot. at 5), is fantasy. Although the Agreed Requests
9 reflect good-faith efforts at compromise, they are not narrow. 6 Among other things, they span a
10 nearly six-year period and call for production of “all” documents and communications with known
11 Californians concerning the conduct alleged in the First Amended Cross-Complaint to be tortious.
12 (E.g., RFPs 3 and 4). And, as discussed below, the Disputed Requests are indefensibly sweeping
13 in scope, seek documents unrelated to Nouvel’s claims—let alone to jurisdiction—and are vague
14 to the point of being unintelligible. See infra at Part III.B. Nouvel’s requests are far from the
15 “simple interrogatories or requests for admissions” for which the Supreme Court held it would be
16 reasonable to “refuse to insist upon the use of Convention procedures.” Aérospatiale, 482 U.S. at
17 546.
18 Factor 3: Location of Information and Parties. Where, as here, the information sought
19 and the parties who will produce it are located in a foreign country and subject to foreign law, this
20 factor weighs in favor of Hague Convention procedures “since those people and documents are
21 subject to the law of that country in the ordinary course of business.” MGI Digital, 2023 WL
22 6814579, at *4 (citing Richmark, 959 F.2d at 1475). Nouvel’s assertion that “many responsive
23 documents likely originated” in California and were then sent to France, (Mot. at 6), is wrong: the
24 French Cross-Defendants and their documents are located in France and are subject to French law.
25 This factor thus plainly weighs in favor of denying Nouvel’s Motion.
26
6
27 Nouvel cites these compromises as “telling evidence” that all of its RFPs are “narrowly tailored.”
(Mot. at 6.) This is nonsense. Compromise as to the Agreed Requests cannot cure the overreach
28 in the Disputed Requests.
5
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1 Factor 4: Alternate Means of Obtaining the Information. Where a “substantially
2 equivalent” alternative means of obtaining the information exists, “there is little or no reason to
3 require a party to violate foreign law.” Richmark, 959 F.2d at 1475. Because the Hague
4 Convention offers a substantially equivalent alternative, this factor weighs against Nouvel’s
5 Motion. Nouvel’s argument to the contrary is wrong on every level.
6 According to Nouvel, Hague Convention discovery in France essentially forbids pretrial
7 discovery unless each document sought is specifically enumerated. (Mot. at 7.) This is
8 misleading. In reality, France will not reject letters of request if the documents sought “(i) are
9 sufficiently defined and (ii) have a direct link with the dispute at stake.” (De Margerie Decl. ¶¶
10 29, 32.) In any event, Nouvel’s argument only relates to one of several effective channels for
11 Hague Convention discovery in France. Other options include the appointment of a
12 commissioner—an efficient process that permits pretrial discovery. (Id. ¶ 36.) None of these
13 Hague Convention options prohibit requests for “categories of documents.” (Id. ¶¶ 5, 27–33.)
14 Nouvel could thus obtain timely and appropriately tailored jurisdictional discovery through the
15 Hague Convention. It just prefers to bypass the proper channels and force the French Cross-
16 Defendants to violate French law. Its blanket refusal even to try lawful options belies the mantra
17 that its requests are “narrowly tailored.” 7
18 Nouvel’s assertion that Hague Convention procedures could take “up to” six months, (Mot.
19 at 7), is also misleading. Its own sources suggest that the process could take as little as two
20 months, (Mooney Decl. Ex 12 at 10–11), and other Hague options are “significantly faster” than
21 letters of request, (De Margerie Decl. ¶ 36). Further, Nouvel itself is to blame for any delay: had
22 it initiated Hague Convention procedures soon after serving its discovery requests (nearly four
23 months ago), that process would likely have been completed by the time this Motion is decided.
24 Factor 5: Balance of National Interests. The “most important” of the comity factors,
25 Richmark, 959 F.2d at 1476, requires “the court to . . . determine whether or not disclosure would
26 affect important substantive policies or interests of either the United States or France,” MGI
27
7
Further, the assertion that French judges theoretically “may” sua sponte reject even mutually
28 stipulated discovery requests is unsupported by any authority. (De Margerie Decl. ¶ 34.)
6
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1 Digital, 2023 WL 6814579, at *5.
2 France unquestionably has a strong interest in enforcing its laws, including the Blocking
3 Statute. (De Margerie Decl. ¶¶ 5, 17–26.) “French Courts have acknowledged” the Blocking
4 Statute’s “particular importance in the French legal framework” and “[i]n recent years, French
5 policymakers have shown a strong interest in strengthening the administration” of the law. (Id. ¶¶
6 12, 17.) Critically, SISSE has made clear that declining to follow Hague Convention procedures
7 in this matter specifically would “prejudic[e] French interests.” (Dick Decl. Ex 3 at 4.)
8 Nouvel belittles the French Blocking Statute as “pretextual” and asks the Court to question
9 France’s sincerity. (Mot. at 9–10.) But its own cases describe France’s interest as “strong.” See
10 MGI Digital, 2023 WL 6814579, at *5 (“strong”); Connex, 2017 WL 3433542, at *15–16
11 (“strong” and “substantial”). Nouvel grounds its condescension on the purported lack of
12 enforcement by French authorities. (Mot. at 8–9.) However, the statute has been enforced
13 criminally, including in at least one case involving discovery requests made in California, and is
14 often applied in civil cases. (De Margerie Decl. ¶¶ 15, 16.) Moreover, the landscape has
15 materially changed, and the 2022 amendments to the Blocking Statute clearly reaffirm France’s
16 strong sovereign interest. (De Margerie Decl. ¶¶ 21–26.) Finally, France’s sovereign interest in
17 Nouvel’s discovery requests is not hypothetical: SISSE has twice made clear the relevance of the
18 Blocking Statute and French sovereign interests to this specific case, these specific discovery
19 requests, and these specific French parties. (Dick Decl. Exs. 1, 3.)
20 To be sure, California also has an interest in adjudicating matters before its courts. But
21 that interest is not diminished by the use of Hague Convention procedures and does not outweigh
22 France’s interests here. First, Nouvel’s concern about “fairness in the discovery process,” (Mot. at
23 9), is misplaced. Such “fairness” concerns arise where a French litigant uses the Blocking Statute
24 and Hague Convention as a shield while pursuing “the full range of free discovery provided by”
25 U.S. rules. MGI Digital, 2023 WL 6814579, at *5. Here, the risk of this imbalance is nil because
26 only Nouvel is seeking discovery. And even if there were such a risk, this factor would “not
27 weigh heavily in either direction.” Id.
28 Second, the interest of U.S. courts in deploying U.S. discovery procedures is afforded less
7
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1 weight in private civil litigation as opposed to “criminal or civil enforcement proceedings in which
2 the United States government is the party moving to compel.” Minpeco, S.A. v. Conticommodity
3 Servs., Inc., 116 F.R.D. 517, 523 (S.D.N.Y. 1987).
4 Third, California’s interest in “vindicating California plaintiffs’ rights,” (Mot. at 8), is
5 diminished here because Nouvel is now beneficially owned by a foreign conglomerate and, as
6 described by its manager, it “is a holding company for European assets that has no business
7 operations in California (or anywhere).” (Dick Decl. Ex. 4 (Alexey Oliynik’s Opp. to Pls.’ Mot.
8 to Compel (“Oliynik Opp.”)) at 11 (emphasis in original).) Nouvel’s authorities only underscore
9 the remote nature of California’s interest here. Cf. Proofpoint, Inc. v. Vade Secure, Inc., 2020 WL
10 1911195, at *5 (N.D. Cal. Apr. 20, 2020) (plaintiffs sought discovery from, among others, a
11 California subsidiary of a French entity); Connex, 2017 WL 3433542 at *1, *16 (finding “strong
12 local interests” in litigation involving a fatal in-forum train crash); In re Air Cargo Shipping Servs.
13 Antitrust Litig., 278 F.R.D. 51, 54 (E.D.N.Y. 2010) (“[A] case involving violations of antitrust
14 laws whose enforcement is essential to the country’s interests in a competitive economy.”).
15 California’s judicial system would not be undermined by requiring these foreign and
16 foreign-owned parties to comply with the treaty obligations of the United States. Cf. Am. Home,
17 104 Cal. App. 4th at 425 (“Treaties such as the Hague Convention are the supreme law of the
18 land[.]”). This factor weighs in favor of use of the Hague Convention.
19 Factor 6: Hardship to the French Cross-Defendants. This factor considers the effect of
20 the discovery order on the foreign party. MGI Digital, 2023 WL 6814579, at *5. Fear of criminal
21 prosecution constitutes a “weighty excuse for nonproduction.” Id. (quoting Societe Internationale
22 Pour Participations Industrielles Et Commerciales, S. A. v. Rogers, 357 U.S. 197, 211 (1958)).
23 Unable to dispute that it wants the Court to compel the French Cross-Defendants to commit a
24 crime, Nouvel trivializes the risks and mischaracterizes the French legal landscape. For example,
25 Nouvel ignores SISSE’s directive to the French Cross-Defendants—a crucial fact of which it was
26 well aware. (Dick Decl. Exs. 1, 2.) Nouvel also overlooks SISSE’s legal duty to report violations
27 of the Blocking Statute to the public prosecutor. (De Margerie Decl. ¶¶ 5, 24.)
28 Further, even if Blocking Statute prosecutions are rare, “the laws still exist and Defendants
8
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1 and the producing entities could expose themselves to potential liability.” Kashef v. BNP Paribas
2 S.A., 2022 WL 1617489, at *4 (S.D.N.Y. May 23, 2022). The risk of criminal sanction
3 “represents a hardship to Defendants,” id., and this factor favors use of the Hague Convention.
4 Factor 7: Likelihood of Compliance. “If a discovery order is likely to be unenforceable,
5 and therefore to have no practical effect, [this] factor counsels against requiring compliance with
6 the order.” MGI Digital, 2023 WL 6814579, at *6. Because the French Cross-Defendants
7 “assert[] without equivocation that [they] will comply with Hague procedures,” this factor
8 counsels in favor of discovery through “Hague procedures.” Salt River, 303 F. Supp. 3d at 1010.
9 Balance of Factors. In sum, the applicable factors heavily favor international comity,
10 respect for sovereignty, and discovery through the recognized and amply suitable procedures
11 established by the Hague Convention. See MGI Digital, 2023 WL 6814579 (ordering discovery
12 through Hague Convention procedures); Salt River, 303 F. Supp. 3d at 1010 (same). 8 Nouvel
13 should be required to at least try this route. If its far-fetched parade of horribles materializes, the
14 Court will have at least respected French sovereignty and can then oversee discovery pursuant to
15 the California Code, should Nouvel renew its Motion.
16 B. The Court Should Deny Nouvel’s Motion to Compel as to the Disputed Requests.
17 Notwithstanding Nouvel’s refusal to pursue the proper procedure for discovery, the French
18 Cross-Defendants tried to reach agreement with Nouvel on scope. 9 The Agreed Requests more
19 than satisfy any jurisdictional discovery obligations here. With respect to the Disputed Requests,
20 the French Cross Defendants also offered: (1) all Miraval-related contracts with pertinent
21 California residents, even contracts that do not form the basis of Nouvel’s claims; (2) all contracts
22 with California residents that relate to the alleged tortious conduct; (3) all communications with
23 known California residents concerning the alleged tortious conduct; and (4) all other
24
25 8
See also Behrens v. Arconic, Inc., 2020 WL 1250956, at *9 (E.D. Pa. Mar. 13, 2020) (same);
Kashef, 2022 WL 1617489, at *4 (declining to compel noncompliance with French law);
26 Vuksanovich v. Airbus Americas Inc., 21-cv-03454 (JHR), Dkt. No. 94 (S.D.N.Y. Nov. 4, 2022)
27 (granting joint application to appoint commissioner under the Hague Convention).
9
If the Court denies the Motion on the grounds that the Hague Convention should be followed, it
28 need not decide on the proper scope of the Disputed Requests.
9
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1 communications (regardless of whether they were sent to Californians) discussing the effects of
2 the alleged tortious conduct on Ms. Jolie or Nouvel.
3 Nouvel rejected these proposals, even though they exceed the scope of permissible
4 jurisdictional discovery. Instead, Nouvel also demands, among other things, documents and
5 communications (i) exchanged between European individuals about European conduct; (ii)
6 concerning agreements and “understandings” with California residents, even if not relevant to
7 Nouvel’s cross-claims; and (iii) potentially relevant to jurisdiction over other cross-defendants.
8 The Court should deny Nouvel’s Motion to compel as to the Disputed Requests. Under no
9 circumstances should the Court compel production of documents beyond those specified in the
10 counterproposals offered to Nouvel and articulated in the French Cross-Defendants’ Separate
11 Statement.
12 1. Legal Standard.
13 A plaintiff opposing a motion to quash is entitled only to “discovery of the jurisdictional
14 facts necessary to sustain its burden of proof.” In re Auto. Antitrust Cases I & II, 135 Cal. App.
15 4th 100, 127 (2005); see also Burdick v. Superior Ct., 233 Cal. App. 4th 8, 30 (2015)
16 (“[D]iscovery must be limited to the issue of specific personal jurisdiction.”). 10 Because the
17 Disputed Requests go far beyond these limitations, the Court should deny Nouvel’s Motion in its
18 entirety. See, e.g., Robin Singh Educ. Servs., Inc. v. Nathan Cepelinski, 2021 WL 945243, at *12
19 (C.D. Cal. Jan. 26, 2021) (denying jurisdictional discovery requests that “do not seek information
20 directly relevant to whether Defendant had sufficient contacts with California residents to establish
21 personal jurisdiction in this case”).
22 2. Nouvel’s Motion on RFPs 10–12 and 15 should be denied.
23 RFPs 10–12 and 15 are clear attempts to obtain merits discovery. They seek, among other
24
10
Counsel for Nouvel previously asserted that “the only jurisdictional discovery to which
25 Plaintiffs could conceivably be entitled is that which concerns [defendant’s] contacts with
26 California that relate to Plaintiffs’ claims.” (Dick Decl. Ex. 5 (Yuri Shefler’s Opp. to Pls.’ Mot. to
Compel (“Shefler Opp.”)) at 5.) Nouvel now takes the wholly irreconcilable position that
27 jurisdictional discovery encompasses “all” documents on certain topics, irrespective of their
relevance to California contacts. (Compare id., with Mot. at 12–13, 14–15.) This goes beyond
28 what the Court ordered in connection with the Shefler motion.
10
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1 things “all documents and communications” concerning:
2 • the involvement of the French Cross-Defendants’ or their “Affiliates” in “actual or
contemplated” efforts to block Nouvel from “supervising,” “overseeing,” or
3 “governing,” or to respond to any requests about, nine European entities, seven of
which Nouvel is not alleged to have any right to supervise, govern, or obtain
4
information from (RFPs 10 and 11);
5
• “actual or contemplated” actions relating to the governance of or dividends paid by
6 European entities Château Miraval and Quimicum (RFPs 12 and 15).
7 In demanding these documents, Nouvel stretches the effects test for jurisdiction well
8 beyond its limits. Nouvel badly misstates that standard, asserting that jurisdiction exists where a
9 “foreign defendant knew the results of the conduct would be felt in the forum state.” (Mot. at
10 13.) 11 Nouvel is wrong, and the law is clear: “that the defendant knew or should have known that
11 its intentional acts could cause harm in this state—is not sufficient to establish jurisdiction under
12 the effects test.” In re Auto. Antitrust, 135 Cal. App. 4th at 122. In fact, after Walden v. Fiore,
13 571 U.S. 277 (2014) and subsequent California and Ninth Circuit decisions, “[i]t is no longer
14 enough . . . to base specific jurisdiction on a defendant’s individualized targeting of a plaintiff
15 known to reside in the forum state.” David L. v. Superior Ct., 29 Cal. App. 5th 359, 373 (2018).
16 Nouvel also ignores the attenuated nature of the supposed effects here: a purported injury suffered
17 in California by virtue of Nouvel’s alleged ownership interest in Quimicum. Having chosen to
18 hold an interest in a French entity through Quimicum, Nouvel could more logically be said to have
19 incurred injury (if at all) in Luxembourg.
20 Nouvel’s cited authorities are not to the contrary. Fighter’s Market (Mot. at 12–13) was
21 premised on the “now outdated individualized targeting” theory of jurisdiction put to rest by
22 Walden and subsequent decisions. See, e.g., Medimpact Healthcare Sys., Inc. v. IQVIA Holdings
23 Inc., 2020 WL 1433327, at *10 (S.D. Cal. Mar. 24, 2020) (Judge Curiel, the author of Fighter’s
24 Market, noting that continued citation to Fighter’s Market is “misplaced”) (citing cases). And
25 Zehia v. Superior Ct. 45 Cal. App. 5th 543 (2020), (Mot. at 13), is easily distinguished. Zehia
26
11
27 Because the parties have not fully briefed the proper standard for personal jurisdiction, which is
directly relevant to this motion, the Court should, in the first instance, order briefing and argument
28 on the motion to quash before deciding any discovery motions.
11
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1 involved defamatory statements sent to members of a California-based ethnic minority to which
2 the plaintiff belonged, such that “the [alleged] reputational injury to [plaintiff] would not have
3 occurred but for the fact that” they were received by Californians. Id. at 557. In other words, “the
4 ‘effects’ caused by the statements . . . connected [defendant’s] conduct to California, not just to a
5 plaintiff who lived there.” Id. Nouvel has not and cannot identify any similar link between the
6 French Cross-Defendants’ conduct and the forum.
7 Even with the law squarely on their side, the French Cross-Defendants sought a
8 compromise by offering Nouvel “all Documents and Communications discussing the effect on Ms.
9 Jolie or Nouvel” of certain foreign conduct. (See Separate Statement at 60, 72, 83, and 100.)
10 Nouvel’s insistence that this offer is “improper,” (Mot. at 13), makes no sense. These are
11 precisely the documents that might bear on Nouvel’s “effects” theory of jurisdiction. Indeed,
12 Nouvel agreed to the same approach for many other Requests and cannot explain why a different
13 principle should govern here. (See Separate Statement at 45, 85, 103, and 127 (RFPs 6, 14, 16,
14 and 19).)
15 3. Nouvel’s Motion on RFP 23 should be denied.
16 RFP 23, which seeks “[a]ll Documents and Communications” concerning a reduction in
17 Château Miraval’s ownership interest in Miraval Provence, manifestly seeks merits discovery. It
18 cannot plausibly be said to be tailored to jurisdictionally relevant facts. It seeks “all” documents,
19 without limitation, regarding foreign conduct involving foreign entities two and three levels
20 removed from Nouvel. The RFP makes no mention of Nouvel or any other California resident, or
21 any act committed in or directed to the forum. See eMag Sols., LLC v. Toda Kogyo Corp., 2006
22 WL 3783548, at *3 (N.D. Cal. Dec. 21, 2006) (jurisdictional discovery “is not an authorization for
23 discovery into the merits of the case, or for discovery into the alleged conspiracy among the
24 defendants”).
25 Nouvel tries to justify this request by selectively quoting and mischaracterizing an excerpt
26 of an interrogatory response by Mr. Pitt and Mondo Bongo—not the French Cross-Defendants.
27 But an interrogatory answer is only admissible against the responding party, see Cal. Code of Civ.
28 Proc. § 2030.410, and Mr. Pitt and Mondo Bongo’s answer cannot be attributed to or used against
12
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1 the French Cross-Defendants. Moreover, the interrogatory answer undercuts Nouvel’s assertion
2 that it was the intended “target[].” (Mot. at 14.) Omitted from Nouvel’s characterization of the
3 response is Plaintiff’s explanation that the share transfer resulted from “the threat posed by the
4 Stoli Group” (a Cypriot company)—not Nouvel. (Compare Mooney Decl. ¶ 3, with Dick Decl. ¶
5 5.) This makes sense, as Nouvel itself “is a holding company for European assets that has no
6 business operations.” (Dick Decl. Ex. 4 (Oliynik Opp.) at 11 (emphasis in original).)
7 Even if the requested discovery showed that Nouvel was indirectly and deliberately
8 harmed by the share transfer, it would be insufficient to establish jurisdiction. See supra Part
9 III.B.2; see also Santa Barbara Smokehouse, Inc. v. AquaChile, Inc., 2020 WL 13328094, at *6
10 (C.D. Cal. July 7, 2020) (“That Plaintiffs live in California, and suffered alleged financial harm in
11 California, is not a basis for personal jurisdiction.”).
12 4. Nouvel’s Motion on RFPs 5 and 17 Should Be Denied.
13 Requests 5 and 17 are extraordinarily broad. They seek not only suit-related contracts
14 between the French Cross-Defendants and California residents, but (i) “[a]ll Documents and
15 Communications,” (ii) concerning “contracts, arrangements, or understandings, oral or in
16 writing,” 12 (iii) including negotiation histories, (iv) regardless of whether they have anything to do
17 with Nouvel’s claims against the French Cross-Defendants, (v) including agreements to which the
18 French Cross-Defendants are not party, as well as (vi) contracts, agreements, arrangements, or
19 understandings with any person in California if they relate to certain various separate entities and
20 business ventures. 13
21 Nouvel’s defenses of these sweeping requests fail. First, Nouvel looks in vain to the
22 “purposeful availment” test for specific jurisdiction. (Mot. at 11–12.) That test is principally used
23 for claims sounding in contract, not torts. See, e.g., Casey v. Hill, 79 Cal. App. 5th 937, 965
24
12
25 Despite repeated requests, Nouvel has never clarified the vague and overbroad terms
“understandings” and “arrangements.” (See, e.g., Declaration of Jonathan Mooney in Supp. of
26 Nouvel’s Mot. to Compel (“Mooney Decl.”) Ex. 9 at 6, 10, 25, and 39.)
13
27 Nouvel essentially acknowledged that these RFPs seek merits discovery. (See Mooney Decl.
Ex. 9 at 3–4 (asking the French Cross-Defendants to agree to “produce documents responsive to
28 Nouvel’s RFP No. 5 in merits discovery”).)
13
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1 (2022); David L., 29 Cal. App. 5th at 367. Regardless, Nouvel’s authorities do not support its
2 demands. All involved far more extensive California contacts and clearer links to the claims at
3 issue. See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 480 (1985) (negotiating history of
4 contract contemplating 20-year relationship with “continuing and wide-reaching” forum contacts
5 was relevant to jurisdiction in breach of contract case); Epic Commc’ns, Inc. v. Richwave Tech.,
6 Inc., 179 Cal. App. 4th 314, 329 (2009) (where foreign resident negotiated agreement in California
7 that called for “ongoing performance of services in California,” availment test was met in
8 litigation “arising from the alleged nonperformance of that agreement”); Nissan Motor Co. v.
9 Nissan Computer Corp., 89 F. Supp. 2d 1154, 1159 (C.D. Cal. 2000) (contracts with five
10 California companies as well as active solicitation of additional business).
11 Second, these RFPs are both overly broad and impermissibly speculative. Nouvel seeks
12 “all Documents and Communications” concerning unspecified contracts, arrangements, and

13 understandings that are not identified or alleged to exist in the First Amended Cross-Complaint.
14 Nouvel’s Motion does no more than postulate that these arrangements exist and vaguely hint that
15 they are related to the causes of action. (Mot. at 13.) This is not enough. Nouvel is not entitled,
16 in the context of jurisdictional discovery, to information about the existence, negotiation history,
17 and performance of hypothetical agreements, arrangements, and understandings (whatever that
18 means) that do not form the basis of its claims. Because RFPs 5 and 17 are “little more than a
19 fishing expedition seeking support for jurisdictional theories,” the Motion should be denied.
20 Yamashita v. LG Chem, Ltd., 62 F.4th 496, 507–08 (9th Cir. 2023).
21 Third, the Motion asks the Court to extend Nouvel’s already expansive requests to reach
22 unexecuted contracts, (Mot. at 13–14), which are not sought by the RFPs themselves. (Compare
23 Separate Statement at 33 and 108–09 (text of RFPs 5 and 17), with id. at 34–40 and 109–115
24 (Nouvel’s justification for its requests), and Mot. at 13–14 (same).) The Court should deny the
25 request on this basis alone, as a plaintiff may not expand its discovery requests in a motion to
26 compel. Wheeler v. Alison, 2014 WL 7157626, at *3 (E.D. Cal. Dec. 15, 2014).
27 Finally, Requests 5 and 17 must be rejected because they seek contracts to which the
28 French Cross-Defendants are not a party. (See Separate Statement at 33, 109 (seeking contracts
14
COMPEL
1 entered into by numerous other foreign entities, some of which are cross-defendants and others
2 which are not even parties to this litigation).) California law only permits discovery from the
3 party at issue and does not allow discovery from one defendant to try to defeat motions to quash
4 filed by other defendants. See 1880 Corp. v. Superior Court, 57 Cal. 2d 840, 843 (1962). (See
5 also Dick Decl. Ex. 5 at 9 (Shefler Opp.).)
6 5. Additional Issues Raised by Nouvel.
7 Nouvel’s Motion includes two additional assertions that are easily refuted. First, Nouvel
8 repeatedly cites the Court’s order granting Mr. Pitt and Mondo Bongo’s Motion to Compel
9 following an October 19, 2023 hearing. (See, e.g., Mot. at 13, 14, and 15 (citing Mooney Decl.
10 Ex. 15).) But that Order concerned far narrower discovery requests and did not implicate the
11 Blocking Statute. 14
12 Second, Nouvel concludes its Motion with an irrelevant red herring. Although the French
13 Cross-Defendants asserted that they should not have to produce duplicative communications with
14 Mr. Pitt and Mondo Bongo (from whom Nouvel sought similar discovery) or Nouvel itself, in
15 order to reach compromise, they abandoned the position that documents already produced by Mr.
16 Pitt and others “suffice for Nouvel to oppose their motion to quash.” (Mot. at 15.) Indeed, they
17 agreed to produce communications with these parties, subject to the use of the proper procedures.
18 IV. CONCLUSION
19 For the foregoing reasons, Perrin, Familles Perrin, and Miraval Provence respectfully urge
20 the Court to deny Nouvel’s Motion to Compel on the grounds that discovery should proceed
21 through the procedures set forth in the Hague Convention and because the Requests are beyond
22 the scope of permissible jurisdictional discovery in California.
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14
The Court’s prior Order applied to a dispute alleging wrongful acquisition of Nouvel, a
25 California LLC, whereby the Court ordered a foreign defendant to produce documents concerning
26 his involvement in the negotiation of the transaction to acquire the California LLC and documents
regarding his subsequent control of the California LLC. That transaction was decidedly
27 California-focused: the target was a California entity, the seller was Californian, and the
agreements at issue were governed by California law and had California forum-selection clauses.
28 The discovery at issue here is diametrically different.
15
COMPEL
1
2 DATED: February 20, 2024 Respectfully submitted,
3 Mark T. Drooks
BIRD MARELLA LLP
4
Phoebe H. King (admitted pro hac vice)
COHEN & GRESSER LLP
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8
By: /s/ Mark T. Drooks
9 Mark T. Drooks
10
jurisdiction on behalf of Cross-Defendants Marc-
11 Olivier Perrin, SAS Miraval Provence, SAS
Familles Perrin, SAS Petrichor, Vins et Domaines
12 Perrin SC, SASU Le Domaine, and SAS Distilleries
de la Riviera
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COMPEL
1 PROOF OF SERVICE

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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 20, 2024, I served the following document(s) described as SPECIALLY
7 APPEARING CROSS-DEFENDANTS MARC-OLIVIER PERRIN, SAS MIRAVAL
PROVENCE AND SAS FAMILLES PERRIN’S MEMORANDUM OF POINTS AND
8 AUTHORITIES IN OPPOSITION TO NOUVEL LLC’S MOTION TO COMPEL
FURTHER DISCOVERY RESPONSES on the interested parties in this action as follows:
9
10
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s) to be
11 sent from e-mail address dthrockmorton@birdmarella.com to the persons at the e-mail addresses
listed in the Service List. I did not receive, within a reasonable time after the transmission, any
12 electronic message or other indication that the transmission was unsuccessful.
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Executed on February 20, 2024, at Los Angeles, California.
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17 /s/ Debra L. Throckmorton
Debra L. Throckmorton
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COMPEL
1 SERVICE LIST

Bradbury Bradbury
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COMPEL
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COMPEL
EXHIBIT 4
2 BIRD, MARELLA, RHOW,
LINCENBERG, DROOKS & NESSIM, LLP
4 Telephone: (310) 201-2100
Facsimile: (310) 201-2110
5
800 Third Avenue
Telephone: (212) 957-7600
9
SAS Miraval Provence, SAS Familles Perrin, SAS
11 Petrichor, Vins et Domaines Perrin SC, SASU Le
Domaine, and SAS Distilleries de la Riviera
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liability company, NOTICE OF RULING RE NOUVEL
17 LLC’S MOTION TO COMPEL FURTHER
Plaintiffs, DISCOVERY RESPONSES
18
vs. Assigned to Hon. Lia Martin
19 Dept.: 3
ANGELINA JOLIE, et. al., Date: March 4, 2024
20 Time: 9:00 a.m.
Defendants.
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Action Filed: February 17, 2022
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NOTICE OF RULING RE NOUVEL LLC’S MOTION TO COMPEL

1 TO ALL PARTIES AND TO THEIR RESPECTIVE COUNSEL OF RECORD:
2 PLEASE TAKE NOTICE THAT on March 4, 2024, at 9:00 a.m. in Department 3 of the
3 above-captioned court, Cross-Complainant Nouvel LLC’s Motion to Compel Further Discovery
4 Responses From Cross-Defendants Marc-Olivier Perrin, SAS Miraval Provence and SAS
5 Familles Perrin came on for hearing before the Honorable Lia Martin. Following argument, the
6 Court adopted without modification its [Tentative] Ruling denying Nouvel’s Motion to Compel.
7 A copy of the Court’s Minute Order is attached hereto as Exhibit A and a copy of the Court’s
8 [Tentative] Ruling is attached hereto as Exhibit B.
9
DATED: March 5, 2024 Mark T. Drooks
10 BIRD, MARELLA, RHOW,
LINCENBERG, DROOKS & NESSIM, LLP
11
12
Mark T. Drooks
14 Attorneys appearing specially to challenge
jurisdiction on behalf of Cross-Defendants Marc-
15 Olivier Perrin, SAS Miraval Provence, SAS
16 Familles Perrin, SAS Petrichor, Vins et Domaines
Perrin SC, SASU Le Domaine, and SAS Distilleries
17 de la Riviera
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3927884.1
2
NOTICE OF RULING RE NOUVEL LLC’S MOTION TO COMPEL
EXHIBIT A
3
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 3
22STCV06081 March 4, 2024

WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al. 9:00 AM
Judge: Honorable Lia Martin CSR: Ingrid J. Saracione, CSR # 11960

Judicial Assistant: A. Cisneros ERM: None
Courtroom Assistant: V. Ponce Deputy Sheriff: None
APPEARANCES:
For Plaintiff(s): Adam L. Goodman (Telephonic); Brandon Ross Teachout (Telephonic)
For Defendant(s): Randall W. Bryer (Telephonic); Justin C. Clarke (Telephonic); Daniel Nathan
Csillag (Telephonic) -- See additional appearances below.
NATURE OF PROCEEDINGS: Hearing on Motion to Compel Further Discovery Responses

Request for Production Re: Personal Jurisdiction from Cross-Defendants Marc-Olivier Perrin,
SAS Miraval Provence and SAS Familles Perrin; Filed by Deft/Cross-Complaint Nouvel, LLC;
(CRS #6368)
Order Appointing Court Approved Reporter, Ingrid J. Saracione, CSR # 11960, as Official
Reporter Pro Tempore is signed by the Court and filed this date with the original forwarded to
the e-Court Scanning Unit.
Counsel appearing via LACourtConnect are e-mailed a copy of the Court's [Tentative] Ruling on
Cross-Complainant Nouvel LLC’s Motion to Compel Further Responses to Requests for
Production re: Personal Jurisdiction by the Court Staff this date.
Motion to Compel Further Discovery Responses Request for Production Re: Personal
Jurisdiction from Cross-Defendants Marc-Olivier Perrin, SAS Miraval Provence and SAS
Familles Perrin; Filed by Deft/Cross-Complaint Nouvel, LLC; (CRS #6368) is held and argued.
The Court adopts its [Tentative] Ruling on Cross-Complainant Nouvel LLC’s Motion to Compel
Further Responses to Requests for Production re: Personal Jurisdiction.
Nouvel’s Motion to Compel Further Responses to Jurisdictional Discover from Perrin Cross-
Defendants is DENIED as fully reflected in the Court's Ruling on Cross-Complainant Nouvel
LLC’s Motion to Compel Further Responses to Requests for Production re: Personal Jurisdiction
issued by the Court, signed by the Court, and filed this date with the original forwarded to the e-
Court Scanning Unit; also available for printing through the e-Court System.
Minute Order Page 1 of 2

4
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 3
22STCV06081 March 4, 2024

WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al. 9:00 AM
Judge: Honorable Lia Martin CSR: Ingrid J. Saracione, CSR # 11960

Judicial Assistant: A. Cisneros ERM: None
Courtroom Assistant: V. Ponce Deputy Sheriff: None
Specially appearing Perrin Cross-Defendants are to give notice and e-file proof of notice with the
Court.
Additional appearances for Defendant(s):

Mark T. Drooks (Telephonic)
Phoebe H. King and S. Gale Dick (Telephonic)
Jonathan Mooney (Telephonic)
Joedat Hani Tuffaha (Telephonic)
Minute Order Page 2 of 2

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EXHIBIT B
6
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
DEPARTMENT 3
TENTATIVE RULING
WILLIAM B. PITT, ET AL., Case No.: 22STCV06081
Plaintiff [Tentative] Ruling on Cross-

Complainant Nouvel LLC’s Motion to
vs. Compel Further Responses to Requests
for Production re: Personal Jurisdiction
ANGELINA JOLIE, ET AL.,
Defendant Hearing Date: March 4, 2024
TO CROSS-COMPLAINANT NOUVEL, LLC, CROSS-COMPLAINANT’S

ATTORNEYS OF RECORD, CROSS-DEFENDATNS MARC-OLIVIER
PERRIN, SAS MIRAVAL PROVENCE AND SAS FAMILLES PERRIN AND
CROSS-DEFENDANTS’ ATTORNEYS OF RECORD:
Defendant and Cross-Complainant Nouvel LLC’s (“Nouvel”) operative cross-

complaint is the First Amended Cross-Complaint (“FAXC”) filed on August 9,
2023 against Plaintiffs Pitt and Mondo Bongo, Perrin, SAS Miraval Provence, SAS
Families Perrin, Roland Venturini, Gary Bradbury, Warrant Grant, SAS Petrichor,
Vins et Domaines Perrin SC, SAS Miraval Studios, SAS Le Domaine and SAS
Distilleries de La Riviera.
Nouvel’s FAXC alleges (1) tortious interference with contractual relations; (2)
tortious interference with prospective economic advantage; (3) tortious
interference with prospective economic advantage; (4) tortious interference with
prospective economic advantage; (5) tortious interference with prospective
economic advantage; (6) breach of the duty of good faith; (7) trespass to chattels;
(8) abuse of right; (9) in the alternative, aiding and abetting tortious interference
with contractual relations; (10) in the alternative, aiding and abetting tortious
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interference with prospective economic advantage; and (11) civil conspiracy to
tortiously interfere with prospective economic advantage.
Cross-Complainant Nouvel LLC’s Motion to Compel Further Responses to

Requests for Production
Nouvel moves to compel further responses from Cross-Defendants Marc-Oliver

Perrin, SAS Familles Perrin and SAS Mirval Provence (“Perrin Cross-
Defendants”) to Nouvel’s Requests for Production re: Personal Jurisdiction on
Perrin Cross-Defendants.
Meet and Confer
According to Nouvel LLC, parties engaged in telephonic meet and confer

discussions and were unable to reach an agreement regarding RFP Nos. 5, 10-12,
15, 17 and 23 (“Disputed RFPs”) or whether Nouvel LLC was required to proceed
under the Hague Convention due to the French Blocking Statute. (Mooney Dec.,
¶4.)
Moving party Counsel’s declaration fails to satisfy the declaration requirement

under CCP §2016.040. Counsel’s declaration was required to “state facts showing
a reasonable and good faith attempt at an informal resolution of each issue
presented by the motion.” (CCP §2106.040.) No details are provided as to what
was discussed, the parties’ positions, the outcome of the telephonic conferences,
the number of telephonic conferences or the dates of the telephonic conferences.
Perrin Cross-Defendants’ counsel confirms that parties met and conferred

regarding the requests for production, that the parties resolved any dispute as to the
scope of RFP Nos. 1-4, 6, 14, 16, 18-22 and 34, but they could not resolve their
dispute regarding the propriety of RFP Nos. 5, 10-12, 15, 17 and 23. (Dick Dec.,
¶3.) Perrin Cross-Defendants also confirm that the parties were unable to resolve
their differences regarding whether the French Blocking Statute required Nouvel to
conduct discovery in accordance with the Hague Convention.
The parties have sufficiently satisfied the meet and confer requirement. The
parties are at an impasse as to whether the French Blocking Statute should require
Nouvel LLC to proceed under the Hague Convention.
8
Legal Standard on Motions to Compel Further Responses to RFPs
CCP § 2031.310
(a) On receipt of a response to a demand for inspection, copying, testing, or
sampling, the demanding party may move for an order compelling further response
to the demand if the demanding party deems that any of the following apply:
(1) A statement of compliance with the demand is incomplete.
(2) A representation of inability to comply is inadequate, incomplete, or
evasive.
(3) An objection in the response is without merit or too general.
(b) A motion under subdivision (a) shall comply with each of the following:
(1) The motion shall set forth specific facts showing good cause justifying
the discovery sought by the demand.
(2) The motion shall be accompanied by a meet and confer declaration under
Section 2016.040.
(3) In lieu of a separate statement required under the California Rules of
Court, the court may allow the moving party to submit a concise outline of the
discovery request and each response in dispute.
(c) Unless notice of this motion is given within 45 days of the service of the
verified response, or any supplemental verified response, or on or before any
specific later date to which the demanding party and the responding party have
agreed in writing, the demanding party waives any right to compel a further
response to the demand.
… (h) Except as provided in subdivision (j), the court shall impose a monetary
sanction under Chapter 7 (commencing with Section 2023.010) against any party,
person, or attorney who unsuccessfully makes or opposes a motion to compel
further response to a demand, unless it finds that the one subject to the sanction
acted with substantial justification or that other circumstances make the imposition
of the sanction unjust.
Where a party is seeking to compel further responses to requests for

document production, the burden is on the moving party to show both relevance to
the subject matter and specific facts justifying discovery. (CCP §2031.310(b)(1);
Kirkland v. Supr. Ct. (2002) 95 Cal.App.4th 92, 98 (“Once good cause was shown,
the burden shifted to Kirkland to justify his objection”); Glenfed Develop. Corp. v.
Supr. Ct. (1997) 53 Cal.App.4th 1113, 1117.) Once good cause is established by
the moving party, the burden then shifts to the responding party to justify any
objections made to document disclosure. (Hartbrodt v. Burke (1996) 42
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Cal.App.4th 168, 172-174.)
A plaintiff is entitled to conduct jurisdictional discovery in order “to develop the

facts necessary to sustain this burden” in response to a motion to quash. (Mihlon v.
Superior Court (1985) 169 Cal.App.3d 703, 710.) A request to conduct
jurisdictional discovery may only be denied if there is no showing that discovery
would likely produce evidence of additional “contacts.” (Beckman v. Thompson
(1992) 4 Cal.App.4th 481, 486–487.)
Legal Standard under Societe Nationale Industrielle Aerospatiale v. U.S.

District Court for Southern District of of Iowa (“Aerospatiale”) for Application
of Hague Convention or Local Rules of Procedure
In Societe Nationale Industrielle Aerospatiale v. U.S. District Court for Southern

District of of Iowa (“Aerospatiale”), 482 U.S. 522 (1987), the Supreme Court
clarified that the Hague Evidence Convention (“Hague Convention”) applied to a
request for information from a foreign national who was a party to federal
litigation in Iowa, that the Hague Convention was not mandatory or exclusive, that
the party seeking discovery was not required to proceed under the Hague
Convention as a first resort and that the Hague Convention was merely an
alternative to the civil procedure rules of the court where the litigation was filed.
(Aerospatiale, supra, 482 U.S. at 540, 542, 547.)
Thus, the Hague Convention and the court’s local civil procedure rules are both
options to conduct discovery on a foreign nation. (Id. at 547; American Home
Assurance Co. v Societe Commerciale Toutelectric (2002) 104 Cal.App.4th 406,
426-427.) Whether the principles of international comity require application of the
Hague convention require a particularized analysis of the respective interests of the
foreign and requesting nations. Thus, to determine whether the Hague Convention
or local civil procedure rules should apply, the Court must balance several factors:
(1) the importance to the…litigation of the documents or other information
requested; (2) the degree of specificity of the request; (3) whether the information
originated in the United States; (4) the availability of alternative means of securing
information; and (5) the extent to which noncompliance with the request would
undermine important interests of the United States, or compliance with the request
would undermine important interests of the state where the information is located.
(Aerospatiale, supra, 482 U.S. at 544, fn 28.)
10
In addition to the five factors specifically identified by the US Supreme Court in
Aerospatiale, the Ninth Circuit has also included two additional factors: (1) the
extent and the nature of the hardship that inconsistent enforcement would impose
upon the person and (2) the extent to which enforcement by action of either state
can reasonably be expected to achieve compliance with the rule prescribed by the
state. (Richmark Corp. v. Timber Falling Consultants (1992) 959 F.2d 1468,
1475.)
Applying Aerospatiale factors, the Hague Convention should apply
The party asserting that the Hague Convention should apply bears the burden of
persuasion on whether considerations of comity favor application of the Hague
Convention in a particular case. (American Home Assurance Co., supra, 104
Cal.App.4th 406, 427.) As such, Perrin Cross-Defendants must establish that the
factors articulated under Aerospatiale and Richmark Corp. balance in favor of
application of the Hague Convention.
(1) Importance to the…litigation of the documents or other information

requested
Nouvel is seeking jurisdictional discovery to establish the threshold issue of the

Court’s personal jurisdiction over the Perrin Cross-Defendants. For that reason
alone, the information requested is fundamental and important to the litigation.
Perrin Cross-Defendants argue that the information requested is not significant
because it does not go to the substantive issues raised by the litigation.
However, information need not go to the substantive issues raised by the litigation
in order to be “important.” Thus, in Richmark, post-judgment discovery into a
judgment debtor’s assets was deemed “crucial.” Procedural issues, like standing
and personal jurisdiction, are important precisely because they are fundamental and
litigation cannot proceed if they are absent. The outcome of this litigation therefor
“stands or falls” on the present discovery order. (Richmark Corp., supra, 959 F.2d
at 1475 (discovery relevant to execution of judgment is “crucial”).)
In opposition, Perrin Cross-Defendants point out that neither Aerospatiale nor any
other US Supreme Court or California Supreme Court case has determined that the
analysis of Aerospatiale applied to jurisdictional discovery. Aerospatiale involved
substantive discovery on foreign defendants who had already answered and
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submitted to the court’s jurisdiction. (Aerospatiale, supra, 482 U.S. at 522.)
While no United States Supreme Court case or California Supreme Court case has
applied Aerospatiale to jurisdictional discovery, the United States Third Circuit
Court of Appeals has done so. “We agree with the majority of trial courts'
decisions that there should be no exception to the Aerospatiale holding for
jurisdictional discovery.” (In re Automotive Refinishing Paint Antitrust Litigation,
358 F.3d 288, 302 (2004).)
As explained in Automotive, Aerospatiale’s holding was not based on the type of

discovery at issue and there is no basis to exempt jurisdictional discovery from its
scope. “[T]he distinction drawn by the appellants between “merits” discovery and
“jurisdictional” discovery, predicated on a false dichotomy of having and not
having jurisdiction, amounts to no real difference because the court has jurisdiction
for either type of discovery. The undisputed presence of personal jurisdiction in
Aerospatiale is, therefore, tangential to its holding and irrelevant to the issue of
whether Aerospatiale applies also to jurisdictional discovery.” (Id. at 303.) In
addition, the nature of jurisdictional discovery weighs in favor of applying
Aerospatiale to jurisdictional discovery. (Id. (narrow scope of jurisdictional
discovery would support rejection of “first resort” rule as to Hague Convention).)
This factor weighs against application of the Hague Convention and in favor
of disclosure under the CCP.
(2) Specificity of the Request.
“A second consideration in evaluating a discovery request is how burdensome it

will be to respond to that request. Generalized searches for information, the
disclosure of which is prohibited under foreign law, are discouraged.” (Richmark
Corp., supra, 959 F.2d at 1475.)
Theoretically, jurisdictional discovery should inherently be limited and specific but

like any discovery, it is subject to abuse. According to Perrin Cross-Defendants,
Nouvel’s jurisdictional discovery is overbroad, spanning six years and reaching far
beyond issues relevant to specific jurisdiction.
“The relevant time period for measuring the nature and quality of a nonresident
defendant's contacts with the forum for purposes of specific jurisdiction is at the
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time the plaintiff's cause of action arose.” (Strasner v. Touchstone Wireless Repair
& Logistics, LP (2016) 5 Cal.App.5th 215, 226.) According to the allegations of
the FAXC, Pitt and Perrin Cross-Defendants conspired to take control of Miraval’s
wine business and interfere with Nouvel’s and Miraval’s interests after Jolie filed
for divorce in 2016. As such, the relevant time period of jurisdictional discovery
arguably extends back to 2016, eight years ago. The six-year time span is
therefore reasonable.
The jurisdictional discovery propounded by Nouvel is extremely broad and it is not

narrowly tailored. The issue is not whether the requests are “relevant” under CCP
§2017.010 but whether they are “specific” or “generalized” and the burden that
responding will be imposed on Perrin Cross-Defendants. Here, the jurisdictional
discovery is broad and generalized, and on that basis, responding fully to the
discovery would impose a significant burden.
This factor weighs in favor of applying the Hague Convention.
(3) Whether the information originated in the United States/Location of

information sought
“The fact that all the information to be disclosed (and the people who will be
deposed or who will produce the documents) are located in a foreign country
weighs against disclosure, since those people and documents are subject to the law
of that country in the ordinary course of business.” (Richmark Corp., supra, 959
F.2d at 1475.)
Perrin Cross-Defendants are undisputedly French residents and claim their

responsive documents are located in France. Nouvel’s only response is that some
of the responsive documents must have “originated in the United States.”
However, based on Richmark Corp., the relevant question is where the information
sought is located, as opposed to where it “originated.”
This factor weighs in favor of application of the Hague Convention.
(4) Availability of alternative means of securing information
“If the information sought can easily be obtained elsewhere, there is little or no
reason to require a party to violate foreign law. In this circuit [Third Circuit], the
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alternative means must be ‘substantially equivalent’ to the requested discovery.”
(Richmark Corp., supra, 959 F.2d at 1475.)
The Perrin Cross-Defendants argue Nouvel can obtain substantially the same
information through the Hague Convention as it may under the CCP. However,
based on the declaration of Quentin De Margerie, the information obtainable
through the Hague Convention or under French law would be far more limited than
that which is available under the CCP. (De Margerie Dec., ¶¶27-35.)
For example, De Margerie concedes that “general investigation measures that are
tantamount to ‘fishing expeditions’ are not allowed under French law. (Id. at ¶33.)
However, under California law, “fishing expeditions” are expressly authorized by
statute—i.e., the Discovery Act provides for discovery of matters “reasonably
calculated to lead to the discovery of admissible evidence. (CCP § 2017.010;
Gonzalez v. Sup.Ct. (City of San Fernando) (1995) 33 Cal.App.4th 1539, 1546.)
However, Nouvel need not go on a fishing expedition for jurisdictional discovery.

Nouvel is seeking discovery on the very limited issue of personal jurisdiction.
Based on De Margerie’s testimony regarding what is available, Nouvel will be able
to obtain document discovery on jurisdictional issues on a more limited scale than
under the CCP. (De Margerie Dec., ¶¶27-35.) Nouvel should be able to obtain
what is necessary to oppose the motion to quash or substantially the same evidence
under the Hague Convention.
This factor weighs in favor of the Hague Convention.
(5) The extent to which noncompliance with the request would

undermine important interests of the United States, or compliance with
the request would undermine important interests of the state where the
information is located/Balancing of national interests
According to Richmark Corp., “[t]his is the most important factor. We must assess
the interests of each nation in requiring or prohibiting disclosure, and determine
whether disclosure would affect important substantive policies or interests” of
either the United States or France. (Richmark Corp., supra, 959 F.2d at 1476.)
Perrin Cross-Defendants rely heavily on the French Blocking Statute to establish

that this factor weighs in favor of applying the Hague Convention. The text of the
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Blocking Statute is as follows: “Subject to international treaties or agreements and
to the laws and regulations in force, it is forbidden for any person to request, seek,
or disclose, in writing, orally, or in any other form, documents or information of an
economic, commercial, industrial, financial, or technical nature aimed at the
constitution of evidence for or in connection with foreign judicial or administrative
proceedings.” (Mooney Dec., Ex. 2.)
The United States Supreme Court considered this same Blocking Statute in
Aerospatiale, as did the California Court of Appeals in American Home Assurance
Co. v. Societe Commerciale Toutelectric. As explained American Home Assurance
Co., the French Blocking Statute purportedly criminalizes discovery outside of the
Hague Convention. (American Home Assurance Co., supra, 104 Cal.App.4th at
426.)
In Aerospatiale, the Supreme Court found the Blocking Statute did not justify a
blanket requirement that the Hague Convention be the exclusive means to obtain
discovery from the foreign defendant or that it be the discovery procedure of first
resort. (Aerospatiale, supra, 482 U.S. at 544, fn 29.) “The blocking statute thus is
relevant to the court's particularized comity analysis only to the extent that its
terms and its enforcement identify the nature of the sovereign interests in
nondisclosure of specific kinds of material.” (Id.)
“When a state has jurisdiction to prescribe and its courts have jurisdiction to
adjudicate, adjudication should (subject to generally applicable rules of evidence)
take place on the basis of the best information available. Blocking statutes that
frustrate this goal need not be given the same deference by courts of the United
States as substantive rules of law at variance with the law of the United States…On
the other hand, the degree of friction created by discovery requests and the
differing perceptions of the acceptability of American-style discovery under
national and international law, suggest some efforts to moderate the application
abroad of U.S. procedural techniques, consistent with the overall principle of
reasonableness in the exercise of jurisdiction.” (Id. (quoting Restatement, §437,
Reporter’s Note 5, pp. 41-42).)
In two letters from the Strategic Information and Economic Security Service
(“SSIE”), the SSIE informed Perrin that responding to the subject jurisdictional
discovery outside of the Hague Convention would violate the French Blocking
Statute, a penal law that carries with it a potential prison sentence of six months
9
15
and a fine of $18,000 euros. (Dick Dec., Exs. 1 and 3.) The discovery in question
could trigger criminal prosecution of the Perrin Cross-Defendants. Although it
seems highly unlikely given that Cross-Defendants could only identify two such
instances, it is a consideration that weighs in favor of the Hague Convention. (De
Margerie Dec., ¶¶13-16.)
This is a significant factual distinction from the circumstances in both American

Home Assurance Co. and Aerospatiale. While defense counsel informed witnesses
in American Home Assurance Co. that they would be in violation of the Blocking
Statute if they testified, it does not appear from the opinion that they were ever
warned directly by the French government that doing so would violate the statute.
(American Home Assurance Co., supra, 104 Cal.App.4th at 421.) Likewise, there
was no such direct warning from the French government in Aerospatiale.
(Aerospatiale, supra, 482 U.S. at 528, fn. 10.)
In addition, California’s interest in this dispute as to Perrin Cross-Defendants is

much more limited than the interest raised in Aerospatiale or American Home
Assurance. Aerospatiale involved a plane crash that occurred in Iowa and
accusations that the foreign defendants had manufactured and sold a defective
plane that caused personal injury. American Home Assurance involved a dispute
over performance bonds issued by an American company to a Florida corporation
wholly owned by a French corporation. The bond was issued for construction in
California.
Here, Nouvel is allegedly no longer owned by a California resident but remains a

California LLC. Nouvel is allegedly now a holding company for European assets.
(Dick Dec., Ex. 4, p. 11.) There are no public safety issues involved in this action
as there were in Aerospatiale. The dispute is also focused entirely on the
ownership, sale and management of Miraval, which is located in France. The
matter is a civil matter, not a criminal matter.
In addition, the discovery in question is jurisdictional discovery. The Court

jurisdiction over the Perrin Cross-Defendants has not been established or
conceded. This is another significant fact that distinguishes this case from
Aerospatiale and American Home Assurance. The Court’s interest in allowing all-
out discovery in the context of personal jurisdictional discovery is less than its
interest in cases where personal jurisdiction, a threshold issue, is conceded and the
discovery pertains to substantive issues or post-judgment issues.
10
16
(6) Extent and the nature of the hardship that inconsistent

enforcement would impose upon the person
If Perrin Cross-Defendants were likely to face criminal prosecution in France for

complying with this Court’s order, this would weigh against disclosure under the
CCP. (Richmark Corp., supra, 959 F.2d at 1477.) Perrin Cross-Defendants would
be exposed to potential criminal prosecution. Even if the likelihood is low, the
SSIE has expressly warned Perrin Cross-Defendants that responding to the
discovery outside of the Hague Convention would be a violation of the Blocking
Statute and that it is “essential to use…the Hague Convention.” (Dick Dec., Exs. 1
and 3.) Certainly, disclosure would not be entirely without any potential
consequence.
(7) Likelihood of compliance/Extent to which enforcement by action of

either state can reasonably be expected to achieve compliance with the
rule prescribed by the state
“If a discovery order is likely to be unenforceable, and therefore to have no

practical effect, that factor counsels against requiring compliance with the order.”
(Richmark Corp., supra, 959 F.2d at 1478.) Here, there is no indication that Perrin
Cross-Defendants would refuse to comply with a discovery order under the CCP,
or that the order would be unenforceable for any other reason. Thus far, Perrin
Cross-Defendants have participated in the meet and confer attempts in good faith
and reached agreement with Nouvel on the Agreed Requests.
This factor weighs does not weigh in favor of application of the Hague
Convention.
Conclusion
Balancing the Aerospatiale factors, Nouvel should proceed with jurisdictional

discovery under the Hague Convention. While the requested jurisdictional
discovery is important to this litigation, all other factors weigh in favor of applying
11
17
the Hague Convention.
Accordingly, Nouvel’s Motion to Compel Further Responses to Jurisdictional

Discover from Perrin Cross-Defendants is DENIED.
Specially appearing Perrin Cross-Defendants are to give notice.
[It is so ordered.]
Dated: March 4, 2024

______________________
Hon. Lia Martin
Judge of the Superior Court
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1 PROOF OF SERVICE

3
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 March 5, 2024, I served the following document(s) described as NOTICE OF
7 RULING RE NOUVEL LLC’S MOTION TO COMPEL FURTHER DISCOVERY
RESPONSES on the interested parties in this action as follows:
8
9
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s) to be
10 sent from e-mail address dthrockmorton@birdmarella.com to the persons at the e-mail addresses
listed in the Service List. I did not receive, within a reasonable time after the transmission, any
11 electronic message or other indication that the transmission was unsuccessful.
13
Executed on March 5, 2024, at Los Angeles, California.
14
15
16 /s/ Debra Lynn Throckmorton
Debra Lynn Throckmorton
17
18
19
20
21
22
23
24
25
26
27
28
3927884.1
19
PROOF OF SERVICE
1 SERVICE LIST

Bradbury Bradbury
12
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28
3927884.1
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PROOF OF SERVICE
EXHIBIT 5
From: Randall Bryer <RBryer@CohenGresser.com>
Sent: Tuesday, April 9, 2024 6:08 PM
To: Jonathan Mooney; S. Gale Dick; Phoebe King; Mark T. Drooks
Cc: Keith Hummel; Justin C. Clarke; Joe Tuffaha; Prashanth Chennakesavan; Chibunkem
Ezenekwe
Subject: Re: Pitt, et al. v. Jolie, et al.; LASC Case No. 22STCV06081
You don't often get email from rbryer@cohengresser.com. Learn why this is important
[EXTERNAL EMAIL] This email originated from outside of the LTL Attorneys organization. DO NOT CLICK links or open attachments
unless you recognize the sender and know the content is safe.
Jonathan,
We are still deliberating internally but are available to meet and confer on Thursday from 11AM onward.
Best,
Randall
From: Jonathan Mooney <jmooney@cravath.com>

Sent: Monday, April 8, 2024 5:15 PM
To: Randall Bryer <RBryer@CohenGresser.com>; S. Gale Dick <SGDick@CohenGresser.com>; Phoebe King
<PKing@CohenGresser.com>; Mark T. Drooks <mdrooks@birdmarella.com>
Cc: Keith Hummel <KHummel@cravath.com>; Justin C. Clarke <jcclarke@cravath.com>;
joe.tuffaha@ltlattorneys.com <joe.tuffaha@ltlattorneys.com>; prashanth.chennakesavan@ltlattorneys.com
<prashanth.chennakesavan@ltlattorneys.com>; Chibunkem Ezenekwe <cezenekwe@cravath.com>
Subject: RE: Pitt, et al. v. Jolie, et al.; LASC Case No. 22STCV06081
Randall,
We are disappointed that your clients are unwilling to continue the briefing and hearing dates until after the court rules
on Nouvel’s motion for an order to issue a letter of request under the Hague Convention.
As you know, a party opposing a motion to quash for lack of jurisdiction is entitled to take jurisdictional discovery as a
matter of right. In re Auto. Antitrust Cases I and II, 135 Cal. App. 4th 100, 127 (2005) (“A plaintiff attempting to assert
jurisdiction over a nonresident defendant is entitled to an opportunity to conduct discovery of the jurisdictional facts
necessary to sustain its burden of proof.”).
In opposing Nouvel’s motion to compel, you represented to the court that that the Hague Convention provided an
“alternative means of securing” jurisdictional discovery (Opp. at 6) and that Nouvel could “obtain timely and
appropriately tailored jurisdictional discovery through the Hague Convention” (id. at 6). You specifically represented to
the court that your clients “assert[] without equivocation that [they] will comply with Hague procedures”. (Id. at 9.)
But you now take the position that Nouvel should be required to brief and to argue your clients’ motion to quash
without obtaining any discovery at all under the Hague Convention. That position is plainly unreasonable. Notably,
although you argued in opposing Nouvel’s motion to compel that “much of what Nouvel seeks is cumulative of evidence
already in its position or otherwise available” (Opp. at 4), the court nevertheless held that “the information requested is
1
fundamental and important to the litigation” (Order at 5). The court further held that “Nouvel should be able to obtain
what is necessary to oppose the motion to quash or substantially the same evidence under the Hague
Convention”. (Id. at 8 (emphasis added)). Yet your clients now seek to contravene the court’s order by requiring Nouvel
to oppose their motion to quash in the absence of necessary discovery under the Hague Convention.
The parties have cooperated on briefing and hearing schedules to date. Requiring complete briefing and a hearing on
your clients’ motion to quash in the absence of any jurisdictional discovery would impose an undue burden on the
parties and the court. We remain hopeful that your clients will agree to continue the briefing and the hearing on the
motion to quash until after Nouvel obtains jurisdictional discovery from them. And we are willing to move ex parte to
advance the July 23, 2024 hearing date on Nouvel’s motion for an order to issue a letter of request if the parties can
reach agreement on a reasonable continuance. However, if your clients maintain their unreasonable position, Nouvel
will not passively engage in burdensome briefing and argument in relation to the May 15 hearing on your clients’ motion
to quash. Instead, Nouvel will move ex parte to continue the hearing date and the briefing schedule on your clients’
motion to quash until after Nouvel obtains jurisdictional discovery under the Hague Convention.
If you maintain your position that Nouvel should be required to brief and to argue your clients’ motion to quash in the
absence of any jurisdictional discovery under the Hague Convention, please provide times later this week when you are
available to meet and confer.
Jonathan Mooney
Cravath, Swaine & Moore LLP
825 Eighth Avenue | New York, NY 10019
T: 212-474-1460
jmooney@cravath.com

Sent: Friday, April 5, 2024 5:20 PM
To: Jonathan Mooney <jmooney@cravath.com>; S. Gale Dick <SGDick@CohenGresser.com>; Phoebe King
Cc: Keith Hummel <KHummel@cravath.com>; Justin C. Clarke <jcclarke@cravath.com>; joe.tuffaha@ltlattorneys.com;
prashanth.chennakesavan@ltlattorneys.com; Chibunkem Ezenekwe <cezenekwe@cravath.com>
Jonathan,
Thanks for the revised drafts. We are still reviewing and will get back to you.
On the question of a continuance, we cannot agree to a schedule that would push the hearing on our motion to quash
to late 2024 or even 2025, for reasons already stated in this email chain. Unless we can figure out a way to proceed with
a shorter continuance, we must retain the current hearing date. We are prepared to meet and confer with you on this
issue. Given that the Court pushed the motion to quash hearing back to May 15, we are also prepared to give you some
relief on your April 12 opposition deadline. We are willing to give you seven of the additional 12 days in the schedule
(i.e., until April 19).
To be clear, we agree that the parties should continue to work collaboratively on the letter of request and the
unopposed motion, so that we can move expeditiously if the Court orders a continuance on May 15. To that end, we
think you should keep the July 23, 2024 hearing date, which we understand to be the soonest date you were able to
secure, and move ex parte for an order advancing the hearing to May 15.
Best,
Randall
2
Randall Bryer
800 Third Avenue

New York, NY 10022
+1 212 324 3518
rbryer@cohengresser.com | view bio
www.cohengresser.com
New York | Paris | Washington DC | London
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Sent: Thursday, April 4, 2024 10:37 PM
Randall, Thank you for your edits. We have accepted nearly all of them. To increase the likeliho od that the request is granted by the French judiciary, o ur position is that the request sh ould state that the discovery so ught is “fundamental and imp ortant to the litigation”, as the
Randall,
Thank you for your edits. We have accepted nearly all of them. To increase the likelihood that the request is granted by
the French judiciary, our position is that the request should state that the discovery sought is “fundamental and
important to the litigation”, as the court ruled in its March 4, 2024 order on Nouvel’s motion to compel. So we restored
that language in the drafts.
We understand from your emails that the Perrin Cross-Defendants are willing to agree to a continuance of limited
duration. As you know, it can be challenging to secure a hearing date within the next few months in Los Angeles
Superior Court. We have diligently sought to reserve the earliest possible hearing date for a motion for an order to issue
a letter of request. We were able to secure a hearing on July 23, 2024. Please let us know if you agree to continue the
briefing and hearing dates until after the motion is heard.
Jonathan Mooney
T: 212-474-1460
jmooney@cravath.com

Sent: Wednesday, April 3, 2024 11:24 PM
3
Jonathan,
Please find attached our proposed edits to the letter of request and the motion. Our edits are geared towards trying to
make both documents as streamlined, accurate, and noncontentious as possible. Additionally, we are unable to
formally join the motion, so it should be styled as an unopposed motion rather than a joint one.
With respect to the continuance, we continue to believe that an open-ended adjournment is inappropriate and unfair
for our clients. As previously noted, the Court’s recent jurisdictional rulings make clear that our clients do not belong in
the case, and an indefinite delay in the hearing serves only to delay this inevitable and long-awaited result. Indeed, you
have not alleged facts that, if proven through the discovery you seek, would provide a basis for personal jurisdiction over
these parties.
With that said, we want to keep the Hague Convention process moving in the event the Court disagrees, and we would
support filing the motion and letter of request once they are finalized.
Please let us know if you would like to discuss any of the above.
Best,
Randall
Randall Bryer
800 Third Avenue

New York, NY 10022
+1 212 324 3518

Sent: Saturday, March 30, 2024 12:06 AM
4
Randall, Please see attached a draft letter of request and a draft motion for the issuance thereof. We disagree with your statement that Nouvel could have in itiated Hague Convention proceedings when you firs t informed us of the SISSE’s po sition regarding the French Blocking Statu
Randall,
Please see attached a draft letter of request and a draft motion for the issuance thereof.
We disagree with your statement that Nouvel could have initiated Hague Convention proceedings when you first
informed us of the SISSE’s position regarding the French Blocking Statute. The parties had not reached agreement
concerning the scope of discovery at that time, and it took the parties several months to reach such agreement with
respect to just the majority of Nouvel’s RFPs. On a related note, as the court did not reach the issue of the disputed
RFPs in its ruling on Nouvel’s motion to compel, in the interest of compromise and conserving the parties’ and the
court’s resources, we propose including the Perrin Cross-Defendants’ proposed constructions of those RFPs in the letter
of request and have done so in the attached draft.
With respect to the continuance, we share your interest in ensuring that the Perrin Cross-Defendants’ motion to quash
is heard as soon as Nouvel receives jurisdictional discovery from the Perrin Cross-Defendants and has an opportunity to
analyze it. Please let us know your clients’ position concerning a continuance.
Jonathan Mooney
T: 212-474-1460
jmooney@cravath.com

Sent: Thursday, March 28, 2024 4:21 PM
Counsel,
We appreciate your offer to share a draft letter of request for international judicial assistance. We look forward to
reviewing your draft letter and accompanying papers.
With that said, we are not inclined to agree to an open-ended continuance of our clients’ motion to quash. Our clients
have been in this litigation for over a year and a half—on jurisdictional allegations that are clearly insufficient,
particularly in light of the court’s recent rulings on your clients’ own motions to quash. This hearing needs to take
place. Relatedly, we do not understand why you did not reach out to us to initiate this process until three weeks after
the court’s denial of Nouvel’s motion to compel. Indeed, as we have previously noted, discovery could likely have been
completed or well underway had you initiated Hague Convention proceedings when we first informed you of the SISSE’s
position regarding the blocking statute. Given the delay, and without having seen a draft of the letter of request, we are
not presently in a position to stipulate to a boundless continuance.
Best,
Randall
Randall Bryer
5
800 Third Avenue
New York, NY 10022
+1 212 324 3518

Sent: Wednesday, March 27, 2024 11:44 AM
To: S. Gale Dick <SGDick@CohenGresser.com>; Phoebe King <PKing@CohenGresser.com>; Randall Bryer
<RBryer@CohenGresser.com>; Mark T. Drooks <mdrooks@birdmarella.com>
Subject: Pitt, et al. v. Jolie, et al.; LASC Case No. 22STCV06081
Counsel, As the court has now ruled on Nouvel’s motion to co mpel and Plain tiffs’ demurrer to Nouvel’s Firs t Amended Cross- Comp liant, N ouvel will later th is week share a draft letter of request for international judicial as sis tance to obtain jurisd ictional discov
Counsel,
As the court has now ruled on Nouvel’s motion to compel and Plaintiffs’ demurrer to Nouvel’s First Amended
Cross-Compliant, Nouvel will later this week share a draft letter of request for international judicial assistance
to obtain jurisdictional discovery from the Perrin Cross-Defendants pursuant to the Hague Convention and a
draft motion for the issuance thereof.
The hearing for the Perrin Cross-Defendants’ motion to quash is currently scheduled for May 3. Given the time
required for issuance of the letter of request, its execution by French authorities, the Perrin Cross-Defendants’
production of documents, and Nouvel’s review of those documents, please let us know if the Perrin Cross-
Defendants will stipulate to continue the hearing to a later date.
Thank you,
Jonathan Mooney
T: 212-474-1460
jmooney@cravath.com
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.
6
7
EXHIBIT 6
4/16/24, 11:03 AM HCCH | Authority
AUTHORITY
France - Central Authority (Art. 2) and practical information

Central Authority(ies):
Ministry of Justice
Contact details:
Address: Ministère de la Justice

Direction des Affaires Civiles et du Sceau
Département de l’entraide, du droit international privé et européen
(DEDIPE)
13, Place Vendôme
75042 Paris Cedex 01
Telephone: +33 (1) 44 77 61 05
Fax: +33 (1) 44 77 61 22
E-mail: entraide-civile-internationale@justice.gouv.fr
General website: www.justice.gouv.fr

www.entraide-civile-internationale.justice.gouv.fr
Contact person: Mrs. Tania Jewczuk, Head of Department:

tania.jewczuk@justice.gouv.fr
Mrs. Catherine Rumeau, Deputy Head of Department:
catherine.rumeau@justice.gouv.fr
Languages spoken by staff: French, English
Practical Information
https://www.hcch.net/en/states/authorities/details3/?aid=500 1/7
Blocking statutes: Yes, there are two European instruments of this nature:
- Council Regulation (EC) No 2271/96 of 22 November 1996
protecting against the effects of the extra-territorial application of
legislation adopted by a third country, and actions based thereon
or resulting therefrom (see, Article 5(1)).
- Directive 95/46/EC of the European Parliament and of the Council
of 24 October 1995 on the protection of individuals with regard to
the processing of personal data and on the free movement of such
data (See, Art. 25(1)).
In addition, two Articles of the law n°68-678 of July 26, 1968
(Articles 1 and 1 bis) - introduced by a law of 16 July 1980 - prevent
"savage" requests for the purpose of obtaining evidence outside of
mutual legal assistance framework.
The provisions of Article 1 of this law aim to prohibit, "subject to
international treaties or agreements", the communication to
foreign public authorities of documents or information of an
economic, commercial, industrial, financial or technical nature, the
disclosure of which may affect the sovereignty, security, essential
economic interests of France or public order, specified by the
administrative authority as necessary.
Under Article 1 of the French Blocking Statute, "subject to
international treaties or agreements and to the laws and
regulations in force, it is prohibited for any person to request, seek
or communicate, in writing, orally or in any other form, documents
or information of an economic, commercial, industrial, financial or
technical nature for the purpose of gathering evidence in or in
connection with foreign judicial or administrative proceedings.”
The resulting prohibition is particularly broad. It applies :
- even if the communication of the document or information does
not affect the sovereignty, security, public order or essential
economic interests of France,
- even if this search is not acted upon,
- and even if the prosecuted person is neither French nor a French
resident.
In a decision dated 28 March 2007, the Paris Court of Appeals (9th
Chamber B), reversing a judgment of acquittal rendered by the
Paris Criminal Court on 1 June 2006, convicted a lawyer of the
offense of communicating economic, commercial, industrial,
financial or technical information aimed at obtaining evidence for
foreign proceedings without complying with the requirements of
the Hague Convention, and ordered him to pay a fine of 10,000
euros. The Court of Cassation upheld this ruling: in a decision dated
12 December 2007, the Court of Cassation (Criminal Division)
dismissed the appeal filed against the decision of the Paris Court of
Appeal.
Chapter I
(Letters of Requests)
Transmission of Letters of Requests: Letters of Request are sent directly from a judicial authority in the
requesting State to the Central Authority of the requested State.
Authority responsible for informing of the Judicial authority competent to execute the request.
time and place of the execution of Letter of
Request
(Art. 7):
Presence of judicial personnel at the Declaration of applicability.

execution of the Letter of Request (Art. 8):
The French Code of Civil Procedure expressly permits the
possibility for the requesting foreign judge to be present during the
execution of the Letter of Request (article 741), without the need to
obtain authorisation from anyone.
Privileges and duties existing under the law No declaration of applicability.

of States other than the State of origin and
the State of execution
(Art. 11):
Translation requirements The French Government will execute only those Letters of Request
Arts 4(2) and 33): which are in French or accompanied by a translation into French.
Costs relating to execution of the Letters of No.

Request
(Arts 14(2)(3) and 26):
Time for execution: Between 2 and 6 months, approximately.
Pre-trial discovery of documents Letter of Request may be executed subject to certain conditions
Art. 23): (qualified exclusion).
Information about domestic rules on the - European Judicial Network in Civil or Commercial Matters - France.
taking of evidence:
- Articles 132 à 322 of the French Code of Civil Procedure -
Legifrance.
Witness examination under Chapter I
Should Letters of Request include specific French national law has no requirements in this respect.
questions to be used during witness
examination or only a list of matters to be
addressed?
Is it a public or private hearing? Public hearing.
Do the judicial authorities "blue-pencil" Yes.

Letters of Requests (i.e. rephrase,
restructure and / or strike out objectionable
questions or offensive wording so that a
Letter of Request may be executed under
the laws of the requested State)?
Is the witness provided in advance with a The judge is not obliged to provide the witness with a list of the
copy of the questions / matters to be questions/matters to be addressed as contained in the Letter of
addressed as contained in the Letter of Request, but there is no prohibition against doing so. However,
Request? according to article 212 of the French Code of Civil Procedure,
"witnesses may not read any draft".
Are documents produced by the witness No.

authenticated by the court?
Is an oath generally administered to the Yes.

witness?
Can the witness be made subject to further Yes, but a second Letter of Request is necessary.
examination and recall?
Are there sanctions for non-appearance of Under Article 207 of the French Code of Civil Procedure, “Defaulting
witness? witnesses and those who, without legitimate reason, refuse to
testify or take an oath may be sentenced to a civil fine of up to
3,000 euros.”
Must interpreters who assist with the No. The oath is only to be taken by judicial experts when they are
witness examination be court-certified? entered on the list established by the Court of Appeals.
How is the testimony transcribed? In accordance with Article 219 et seq. of the French Code of Civil
Procedure, witness testimonies are recorded in a transcript
("procès-verbal"), dated and signed by the requested judge and by
the clerk who prepared it.
Chapter II
(Taking of evidence by diplomatic officers, consular agents and commissioners)
Article 15 Applicable.
Article 16 Applicable. See conditions and competent authority.
Article 17 Applicable. See conditions and competent authority.
Article 18 No declaration of applicability (i.e., a diplomatic officer, consular

agent or commissioner may not apply for appropriate assistance to
obtain evidence by compulsion).
Taking of evidence by video-links

(under either chapter)
Chapter I
Are there legal obstacles to the use of video No.

links?
Conducting hearings directly, by Under Chapter I of the Convention, pursuant to Article 27 (b) and
videoconference: (c) of the Convention and articles 747-1 and 747-2 of the French
Code of Civil Procedure, France permits a foreign judicial authority
to conduct a hearing directly on French territory, including via
videoconference, without compulsion or sanction, provided that
the French Central Authority has given its prior permission. The
hearing may be conducted on the premises of a French Court, but
this is not mandatory.
Technology used: Pursuant to Article R. 111-7, paragraph 2 of the Code of Judicial

Organization :
“The technical specifications of the audiovisual telecommunication
means used must guarantee a reliable, loyal and confidential
transmission with respect to third parties.
They are determined by order of the Minister of Justice.”
The transport network currently used by the Ministry of Justice is
the RNIS network (Integrated Services Digital Network / ISDN),
belonging to the commutated telephone network. The required
speed is 256 kbps.
Level of interpretation required: France makes use of the services of accredited professional
interpreters, but also relies on the parties and their legal counsel.
Simultaneous or in sequence interpretation: No preference.
Interpretation required in which No information available.

jurisdiction?
Who pays for the interpretation? Pursuant to Article 748 of the French Code of Civil Procedure, which
applies to incoming Letters of Request, the costs incurred by
interpreters are to be borne by the foreign (requesting) authority.
How would a request for evidence be Should a witness refuse to attend a videoconference hearing
handled if witness not willing? conducted by the judicial authority, it remains for the judicial
authority to determine the consequences. While Article 207 of the
French Code of Civil Procedure provides that "Defaulting witnesses
and those who, without legitimate reason, refuse to testify or take
an oath may be sentenced to a civil fine of up to 3,000 euros",
French national law provides that in civil matters, the use of
videoconference is subject to the consent of all parties.
Chapter II
Are there legal obstacles to the use of video No.

links?
Technology used: No information available.
Level of interpretation required: No information available.
Simultaneous or in sequence interpretation: No information available.
Interpretation required in which No information available.

jurisdiction?
Who pays for the interpretation? No information available.
Other Information
Bilateral or multilateral agreements - Supplementary agreements to the Hague Convention of 1 March

1954 were concluded with: Austria (1979), Bosnia and Herzegovina
(1969), Croatia (1969), Germany (1961), Poland (1967), Serbia
(1969), Slovenia (1969), The Former Yugoslav Republic of
Macedonia (1969).
- Bilateral conventions on judicial co-operation: Algeria (1962),
Australia (1922), Bahamas (1922), Belgium (1956), Benin (1975),
Brazil (1996), Bulgaria (1989), Burkina Faso (1961), Cameroon
(1974), Canada (1922 and Agreement with Quebec of 9 September
1977), Central African Republic (1965), Chad (1976), China (1987),
Congo, Côte D'Ivoire (1961), Czech Republic (1984), Djibouti (1986),
Egypt (1982), Gabon (1963), Hungary, Italy (1955), Lao People's
Democratic Republic (1956), Lithuania (1928), Luxembourg (1870),
Madagascar (1973), Mali (1962), Morocco (1957), Mauritania (1961),
Monaco (1949), Mongolia (1994), Niger (1977), New Zealand (1922),
Romania (1974), Russian Federation (1936), San Marino (1967),
Senegal (1974), Slovakia (1984), Switzerland (1913), Togo (1976),
Tunisia (1972), United Arab Emirates (1991), United Republic of
Tanzania (1922), Uruguay (1991), Vietnam (1999).
- Council Regulation (EC) No. 1206/2001 of 28 May 2001 on
cooperation between the courts of the Member States in the taking
of evidence in civil or commercial matters.
Useful links: http://www.entraide-civile-internationale.justice.gouv.fr/
Competent authorities (Art. 17) Ministère de la Justice

Direction des Affaires Civiles et du Sceau
Département de l’entraide, du droit international privé et européen
(DEDIPE)
13, Place Vendôme
75042 Paris Cedex 01
Phone : + 33 (1) 44 77 61 05 - fax : + 33 (1) 44 77 61 22
E-mail : entraide-civile-internationale@justice.gouv.fr
General website : www.justice.gouv.fr
www.entraide-civile-internationale.justice.gouv.fr
Additional authorities (Art. 24) Not applicable.
This page was last updated on: 27 February 2023
Conventions (incl. Protocols and Principles)
Convention of 18 March 1970 on the Taking of Evidence Abroad in Civil or Commercial Matters [20]
EXHIBIT 7
Lynette Suksnguan
From: Joe Tuffaha

Sent: Tuesday, April 16, 2024 9:17 AM
To: wdsavitt@wlrk.com; jmmoses@wlrk.com; skeddy@wlrk.com; algoodman@wlrk.com;
jlallen@wlrk.com; rkgrosbard@wlrk.com; jberlinski@birdmarella.com;
BTeachout@birdmarella.com; jcherlow@birdmarella.com; fwang@birdmarella.com;
skosmacher@birdmarella.com; KMeyer@birdmarella.com; PYates@birdmarella.com;
Rattarson@birdmarella.com; mdrooks@birdmarella.com; lbrill@kbkfirm.com;
kkuwata@kbkfirm.com; sgdick@cohengresser.com; Randall Bryer; Phoebe King;
pmurphy@murphyrosen.com; dcsillag@murphyrosen.com
Cc: Keith Hummel; Justin C. Clarke; Jonathan Mooney; Prashanth Chennakesavan
Subject: Pitt, et al. v. Jolie, et al.; LASC Case No. 22STCV06081 | Notice of Ex Parte Application
Counsel,
Please take notice that at 8:30 a.m. on April 17, 2024, Nouvel, LLC will appear ex parte at Department 3, Stanley Mosk
Courthouse, 111 North Hill Street, Los Angeles, CA 90012, to seek an order continuing (1) the May 15, 2024 hearing on Cross-
Defendants Marc-Oliver Perrin, SAS Familles Perrin, and SAS Miraval Provence’s motion to quash for lack of personal
jurisdiction and (2) the deadline for Nouvel, LLC to file its opposition to the motion to quash. Please let us know if you oppose
or will appear.
JOE TUFFAHA
Los Angeles | San Francisco | New York | Orange County
LTL ATTORNEYS LLP

Direct: 213-805-8075 | Fax: 213-612-3773
joe.tuffaha@ltlattorneys.com | www.ltlattorneys.com
CONFIDENTIALITY NOTICE
The information in this e-mail (including attachments, if any) is confidential information intended only for the use of the individual or entity to whom it is
addressed, and may be privileged. The information herein may also be protected by the Electronic Communications Privacy Act, 18 USC Sections 2510-
2521. Any review, use, disclosure, distribution, or copying of this e-mail is prohibited except by or on behalf of the intended recipient. If you have received this
email in error, please notify the sender immediately by reply email, delete this email, and do not disclose its contents to anyone. Thank you.

Dec NOUX

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1 KEITH R.

HUMMEL (admitted pro hac vice)

8 JOE H. TUFFAHA (Bar No. 253723)

DECLARATION OF JOE TUFFAHA

3 and Cross-Complainant Nouvel, LLC (“Nouvel”) in the above-captioned action. I am a member

6 competently testify to such facts under oath.

7 2. I submit this declaration in support of Nouvel’s ex parte application for an order

11 Defendants’ motion to quash.

12 3. Nouvel filed its First Amended Cross-Complaint (“FACC”) on August 9, 2023.

17 2023 jurisdictional discovery requests are attached hereto as Exhibit 2.

18 5. Nouvel’s requests seek discovery concerning the Perrin Cross-Defendants’ contacts

25 Nouvel’s sole investment. See Exhibit 2.

7 Nouvel to obtain the discovery in advance of a hearing on the motion to quash.

8 7. On January 22, 2024, Nouvel moved to compel the production of complete

12 8. The Perrin Cross-Defendants filed an opposition to Nouvel’s motion to compel. A

14 9. In their opposition, the Perrin Cross-Defendants argued that the jurisdictional

5 evidence under the Hague Convention.” (Id. at 8.)

8 assistance to obtain jurisdictional discovery pursuant to the Hague Convention.

10 request, its execution by French authorities, the Perrin Cross-Defendants’ production of

16 the Perrin Cross-Defendants.

17 14. The Perrin Cross-Defendants refused to stipulate to a continuance, taking the

19 any discovery at all under the Hague Convention.

8 as possible under the circumstances.

11 especially in light of the allegations in the First Amended Cross-Complaint.

15 jurisdictional discovery under the Hague Convention.

17 Paragraphs 12-14 and 19, is attached hereto as Exhibit 5.

2 jurisdictional discovery to Nouvel.

5 Conference on Private International Law.

11 of the email correspondence discussed in this paragraph is attached hereto as Exhibit 7.

12 24. It is my understanding that Plaintiffs and Cross-Defendants William B. Pitt and

16 1000, Fax: (212) 403-2000, Email: wdsavitt@wlrk.com, jmmoses@wlrk.com, skeddy@wlrk.com,

17 algoodman@wlrk.com, jlallen@wlrk.com, rkgrosbard@wlrk.com; and John V. Berlinski of Bird,

19 Angeles, CA 90067-2561, Tel: (310) 201-2100, Fax: (310) 201-2110, Email:

20 jberlinski@birdmarella.com, BTeachout@birdmarella.com, jcherlow@birdmarella.com,

21 fwang@birdmarella.com, skosmacher@birdmarella.com, KMeyer@birdmarella.com,

23 25. It is my understanding that Cross-Defendants Roland Venturini and Gary Bradbury

27 jmmoses@wlrk.com, skeddy@wlrk.com, algoodman@wlrk.com, jlallen@wlrk.com,

2 2705, Email: lbrill@kbkfirm.com, kkuwata@kbkfirm.com.

3 26. It is my understanding that Cross-Defendants Marc-Olivier Perrin, SAS Miraval

9 10022, Tel: (212) 957-7600, Email: sgdick@cohengresser.com, rbryer@cohengresser.com,

11 27. It is my understanding that Cross-Defendants SAS Miraval Studios is represented

15 28. It is my understanding that Defendant and Cross-Complainant Angelina Jolie is

21 foregoing is true and correct.

22 Executed on April 16, 2024 in Los Angeles, California, USA.

24 /s/ Joe Tuffaha

12 COUNTY OF LOS ANGELES, CENTRAL DISTRICT

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

22 Date: December 15, 2023

26 Action Filed: February 17, 2022

CROSS-DEFENDANTS’ MOTION TO QUASH

25 By: /s/ Mark T. Drooks

11 2. The French Cross-Defendants Are Not Subject to Specific

16 c. The Court’s Exercise of Jurisdiction Over the French Cross-

6 In re Auto. Antitrust Cases I & II,

19 David L. v. Superior Ct.,

24 Farina v. SAVWCL III, LLC,

6 LG Chem, Ltd. v. Superior Ct. of San Diego Cnty.,

24 St. Paul Fire and Marine Ins. Co. v. AmerisourceBergen Corp.,

3 Cross-Defendants Marc-Olivier Perrin (“Perrin”), SAS Familles Perrin (“Familles Perrin”),

4 A. This Court Lacks Personal Jurisdiction over the French Cross-Defendants.

5 Purposefully Avail Themselves of California’s Forum Benefits.

4 California residents: correspondence allegedly sent to individuals in California (namely, alleged

11 Defendants is Europe, specifically, Château Miraval in France and Quimicum in Luxembourg.