1 BIRD, MARELLA, RHOW,

LINCENBERG, DROOKS & NESSIM, LLP

2 John V. Berlinski (State Bar No. 208537)
jberlinski@birdmarella.com
3 Julia B. Cherlow (State Bar No. 290538)
jcherlow@birdmarella.com
4 1875 Century Park East, 23rd Floor
Los Angeles, CA 90067-2561
5 Telephone: (310) 201-2100
Facsimile: (310) 201-2110
6
WACHTELL, LIPTON, ROSEN & KATZ
7 Jonathan M. Moses (admitted pro hac vice)
Adam L. Goodman (admitted pro hac vice)
8 Jessica L. Layden (admitted pro hac vice)
Ioannis D. Drivas (pro hac vice pending)
9 51 West 52nd Street
New York, NY 10019
10 Telephone: (212) 403-1000
Facsimile: (212) 403-2000
11
Attorneys for Plaintiffs and Cross-Defendants
12 William B. Pitt and Mondo Bongo, LLC

13
SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 COUNTY OF LOS ANGELES, CENTRAL DISTRICT

15

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

MONDO BONGO, LLC, a California limited
17 liability company, DECLARATION OF TONY WEBB

18 Plaintiffs, Filed concurrently with Reply Memorandum of

Points and Authorities and Reply Separate
19 vs. Statement

20 ANGELINA JOLIE, et al., Judge: Hon. Lia Martin

Dept.: 3
21 Defendants.
Date: May 16, 2024
22 Time: 9:00 A.M.
AND RELATED CROSS-ACTIONS Reservation ID: 257097942103
23
Action Filed: February 17, 2022
24 Trial Date: Not yet set

25

26

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DECLARATION OF TONY WEBB

 1 DECLARATION OF TONY WEBB

2 I, Tony Webb, declare as follows:

3 1. I am currently the owner of SRS Global Security Ltd. (“SRS Global”), a personal

4 security company based in London, England that I founded in 2006. Prior to that, I was a member

5 of the United Kingdom’s Royal Marines between 1979 and 1984, where I actively served in the

6 Falklands War and three tours of Northern Ireland. In 1985, I joined the British Army’s Special

7 Air Service (“SAS”), where I served as a corporal, sergeant, and chief instructor. I retired from

8 the SAS in 1995, with the commendation of an “exemplary record,” which I understand to be the

9 rough equivalent of retiring with an honor of valor from the Department of Defense in the United

10 States. Thereafter, I joined the private sector and later founded SRS Global. Attached hereto as

11 Exhibit 1 is a copy of my curriculum vitae. I have personal knowledge of the facts set forth

12 herein, which are known by me to be true and correct, and if called as a witness, I could and would

13 competently testify thereto.

14 2. Between 2000 and 2020, I provided varying degrees of personal security for

15 Angelina Jolie and her family, and I currently provide services for Brad Pitt. In the early years of

16 my working relationship with Ms. Jolie, I provided these services through a company called Task

17 Force Security. After I founded SRS Global, I provided my services through that company, and I

18 hired independent contractors, typically former military personnel, to assist me.

19 3. My work with Ms. Jolie began as individual assignments, typically on movie sets.

20 In or around 2012, however, my work for her increased and I began running security for her and

21 the family whenever they left the United States. My working relationship with Ms. Jolie also

22 evolved in other ways. Initially, I took instruction either directly from her or from her then-

23 personal assistant, a woman named Holly. Later, in the mid-to-late 2000s, I was introduced to a

24 man named Michael Vieira who assumed a similar role for Ms. Jolie, and Mr. Vieira began

25 providing me and my team with instruction and direction on behalf of Ms. Jolie. This sometimes

26 included Mr. Viera telling me to present people with non-disclosure agreements on behalf of Ms.

27 Jolie and obtain their signatures. For example, Mr. Viera often asked me to provide hotel staff

28 with non-disclosure agreements and to get signatures from them.

2
DECLARATION OF TONY WEBB
 1 4. At some point after Mr. Vieira became Ms. Jolie’s point-person for communicating

2 with me about security services, Ms. Jolie, through Mr. Vieira, required me and my independent

3 contractors to sign our own non-disclosure agreements to prevent us from discussing various

4 personal and professional details of her, and her family’s life. I would have no problem if my

5 non-disclosure agreement with Ms. Jolie were publicly disclosed.

6 5. Based on my close contact with Ms. Jolie’s family, including Mr. Pitt, I became

7 aware that Ms. Jolie and Mr. Pitt were divorcing in or around 2016. After their divorce, SRS

8 Global and I continued to provide security for Ms. Jolie, Mr. Pitt, and their children.

9 6. Shortly before two SRS Global contractors testified in a court case that I

10 understood was related to Ms. Jolie and Mr. Pitt’s divorce and the custody of their children, Mr.

11 Vieira called me on my cell phone. At the time I received the phone call, I was in my home office

12 located in Hereford, UK. During the call, Mr. Viera told me that he had heard that two contractors

13 who had provided personal security for Ms. Jolie through SRS Global might be testifying in the

14 family court case. Mr. Vieira then asked me to stop these two individuals from testifying. I

15 understood that Mr. Viera was making this request on behalf of Ms. Jolie. I explained to Mr.

16 Vieira that I had no power to stop them because they were independent contractors and not

17 employees of SRS Global. Mr. Vieira then told me that his call should serve as a reminder that

18 those individuals had entered into non-disclosure agreements with Ms. Jolie and that I should

19 remind them of that and tell them that if they testified in the family law case, Ms. Jolie would sue

20 them. I communicated this message to the two individuals over the phone and they both told me

21 that they planned to testify. One of the two individuals, Ross Foster, specified that he intended to

22 testify regardless of the NDA, if he received a court subpoena. When Mr. Foster told me this, he

23 also told me that if asked, he would testify about statements he overheard that Ms. Jolie made to

24 the children, encouraging them to avoid spending time with Mr. Pitt during custody visits.

25 7. I received a second phone call from Mr. Vieira shortly after the first, asking me

26 whether Mr. Foster and the other individual about whom we had previously spoken were, in fact,

27 going to testify. I told him that I believed that they were. Mr. Vieira once again asked me to

28 remind them that they had signed non-disclosure agreements, and that if they testified, Ms. Jolie

3
DECLARATION OF TONY WEBB
 1 would sue them. Mr. Vieira also stated that Ms. Jolie may need to subpoena me to testify, though

2 I never actually received a subpoena.

3 8. I understand that Mr. Foster and the other individual mentioned above were, in fact,

4 subpoenaed, and that both did, in fact, testify in the Jolie/Pitt family law case.

5 9. On June 13, 2021, Terry Bird, Ms. Jolie’s business manager, wrote to inform me

6 that SRS Global was terminated from its role of providing personal security services for Ms. Jolie,

7 and, effective that date, my services and those of SRS Global were “no longer . . . required.”

8 10. On June 16, 2021, I wrote an email to Ms. Jolie, thanking her for the work she had

9 provided to me and SRS Global over the prior two decades. I also wrote that I was sad that we

10 had become distant over the past few years, and that I knew she blamed me for what my

11 independent contractors had done, but that because they were self-employed, I could not control

12 what they did or said as they were not directly employed by SRS Global. Ms. Jolie responded

13 “Take good care. As ever. Angie.” That was my last communication with Ms. Jolie. A true and

14 correct copy of that exchange is attached as Exhibit 2 to this declaration.

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

16 foregoing is true and correct.

17 Executed May 7, 2024, at Hereford, United Kingdom.

18

19
Tony Webb
20

21

22

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4
DECLARATION OF TONY WEBB
EXHIBIT 1
 TONY WEBB
5('$&7('3,,
5('$&7('3,,

A professionally trained security consultant, with a wide practical and theoretical

knowledge. Highly motivated and extremely experienced in high risk situations.
Conducted a variety of demanding appointments that have required excellent leadership,
drive & organizational skills gained at the highest level within the British Special Forces.

CAREER HISTORY

Apr 97 – To Date Company Director

Since 1997 I have worked for my own companies with various business partners. My
clients include many high profile VIP’s as well as company executives and their families.
The work has been in various different theatres of operations in many different areas of
the world.

Jan 95 – Apr 97 Security Consultant

From January 1995 I worked as a Security Consultant employed by many different
companies, V.I.P’s and their families advising them on their security arrangements and
providing Personal Protection when required.

Jun 93 – Jan 95 22 Special Air Service

Team Task Instructor. Responsible for training S.A.S. soldiers for teaching tasks
overseas. The subjects included:
x Counter terrorist training
x Close Protection training
x Special Forces training
x Surveillance & Counter Surveillance
x Demolitions – Basic/Advanced
x Communications
x Close Quarter Battle (CQB) Techniques

Jan 85 – Jun 93 22 Special Air Service

Passed selection for 22 S.A.S. Deployed on various specialist tasks. Operations included
the African Continent, South & Central America, the Far East, and the Middle East,
including from December until April of 1991 in the Gulf War.
Other areas operations also included:
x Operational tours on the Counter Terrorist Team
x Training the Columbian presidential close protection team
x Training of various Far Eastern Armies in special forces tactics
x Covert tasks in various theatres of operations
x Training tasks teaching many different specialist skills

Jan 79 – Apr 84 Royal Marines

Joined 40 Commando RM. During this period I served in the Falklands War and two
operational tours of Northern Ireland. Left the Royal Marines 1984 for S.A.S. selection.

Exhibit 1
Page 1 of 2
 TONY WEBB
5('$&7('3,,
5('$&7('3,,

SPECIALIST & INSTRUCTOR QUALIFICATIONS

x S.A.S. V.I.P. Protection.

Qualified in all aspects of V.I.P. protection.
x S.A.S. Counter Terrorist Team.
Many tours completed with the Counter Terrorist Team.
x S.A.S. Demolitions Course.
Qualified to use all forms of modern explosive equipment.
x S.A.S. Signals Course.
Trained in all methods of radio communications.
x Methods of Entry.
Explosive and non-explosive methods of entry into strongholds.
x Covert & Internal Security.
Qualified in all aspects of covert and internal security.
x S.A.S. Advanced Driver.
All fast and evasive driving techniques covered.
x Surveillance Trained.
All methods of surveillance and anti-surveillance covered.
x S.A.S. Medic.
Trained in all emergency procedures.
x H.M. Forces Methods of Instruction, Field Firing & Skill at Arms.
Qualified to plan and instruct on all aspects of small arms and field firing.
x Negotiator.
Attended and passed, Police Negotiators course.
x Jungle Warfare Instructor.

x Combat Survival Instructor.

Exhibit 1
Page 2 of 2
EXHIBIT 2
From: AJ REDACTED/PII
Sent: Friday, June 25, 2021 6:30 PM
To: Tony Webb
Subject: Re: Termination

Thank you for your note.

Take good care

As ever
Angie

Sent from my iPhone

On Jun 16, 2021, at 8:40 AM, Tony Webb REDACTED/Pl! wrote:

Hi Angie,

I decided to write to you directly as I didn't think it would be right just to accept the brief termination
letter from Terry and walk away after 20 years with you and your family.

I know it has been a very difficult time with everything that's been going on, and sadly we seem to have
become very distant over the past couple of years. The lack of travel because of the virus not helping!

I know you blame me for a lot of things Ross has subsequently done, but he didn't work full time for me,
he is a self employed security consultant and so is free to work for whoever.
This is the same as for the rest of the guys. I can't control what they do or say, when not directly
employed by my company.

In regards to the guys, I'm glad you have decided to continue with Matt Fletcher's services, as he is one
of the best security consultants I have had the pleasure to employ and work with over the years.

Please take care and love always,

Tonyx

Tony Webb
SRS Global Security Ltd

This message contains information, which may be confidential and subject to legal privilege. If you are
not the intended recipient, you may not peruse, use, disseminate, distribute or copy this message. If you

1 Exhibit 2
Page 1 of 2
have received this message in error, please notify the sender immediately by email, facsimile or
telephone and return or destroy the original message. Thank you.

Exhibit 2
Page 2 of 2
2
 1 PROOF OF SERVICE

2 Pitt v. Jolie
Case No. 22STCV06081
3
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
4
At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Los Angeles, State of California. My business address is 1875 Century
Park East, 23rd Floor, Los Angeles, CA 90067-2561.
6
On May 9, 2024, I served the following document(s) described as DECLARATION OF
7 TONY WEBB on the interested parties in this action as follows:

8 SEE ATTACHED SERVICE LIST

9 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s) to be

sent from e-mail address kminutelli@birdmarella.com to the persons at the e-mail addresses listed
10 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 unsuccessful.
11
I declare under penalty of perjury under the laws of the State of California that the
12 foregoing is true and correct.

13 Executed on May 9, 2024, at Los Angeles, California.

14

15 /s/ Karen M. Minutelli

Karen M. Minutelli
16

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PROOF OF SERVICE
 1 SERVICE LIST
Pitt v. Jolie
2 Case No. 22STCV06081

3 Paul D. Murphy Laura W. Brill

Daniel N. Csillag Daniel Barlava
4 MURPHY ROSEN LLP Matthew Bernstein
100 Wilshire Boulevard, Suite 1300 KENDALL BRILL & KELLY LLP
5 Santa Monica, CA 90401 10100 Santa Monica Boulevard, Suite 1725
Telephone: (310) 899-3300 Los Angeles, CA 90067-4013
6 Email: pmurphy@murphyrosen.com Telephone: (310) 556-2700
Email: dcsillag@murphyrosen.com Email: lbrill@kbkfirm.com
7 Counsel for Defendant and Cross- Email: dbarlava@kbkfirm.com
Complainant Angelina Jolie Email: mbernstein@kbkfirm.com
8 Counsel appearing specially to challenge
jurisdiction on behalf of Cross-Defendants
9 Roland Venturini and Gary Bradbury

10 Joe Tuffaha Keith R. Hummel

Prashanth Chennakesavan
11 LTL ATTORNEYS LLP
300 South Grand Avenue, Suite 1400
12 Los Angeles, CA 90071
Telephone: (213) 612-8900
13 Email: joe.tuffaha@ltlattorneys.com
Email:
14 prashanth.chennakesavan@ltlattorneys.com
Counsel for Defendant and Cross-
15 Complainant Nouvel, LLC and Defendant
Tenute del Mondo B.V., and specially
16 appearing to challenge jurisdiction on behalf
of Defendants Yuri Shefler and Alexey
17 Oliynik
18
19 Mark Drooks
Debbie Throckmorton
20 Assistant to Mark Drooks
BIRD, MARELLA, RHOW, LINCENBERG,
21 DROOKS & NESSIM, LLP
1875 Century Park East, 23rd Floor
22 Los Angeles, CA 90067-2561
Telephone: 310 201-2100
23 Email: mdrooks@birdmarella.com
Email: dthrockmorton@birdmarella.com
24 Counsel appearing specially to challenge
jurisdiction on behalf of Cross-Defendants
25 Marc-Olivier Perrin, SAS Miraval Provence,
Familles Perrin, SAS Petrichor, Vins et
26 Domaines Perrin SC, SASU Le Domaine, and
SAS Distilleries de la Riviera
27
Justin C. Clarke
Jonathan Mooney
CRAVATH, SWAINE & MOORE LLP
Worldwide Plaza
825 Eighth Avenue
New York, NY 10019
Telephone: (212) 474-1000
Email: khummel@cravath.com
Email: jcclarke@cravath.com
Email: jmooney@cravath.com
Counsel for Defendant and Cross-
Complainant Nouvel, LLC and Defendant
Tenute del Mondo B.V., and specially
appearing to challenge jurisdiction on behalf
of Defendants Yuri Shefler and Alexey
Oliynik
S. Gale Dick
Phoebe King
Randall Bryer
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Telephone: (212) 707-7263
Email: SGDick@CohenGresser.com
Email: PKing@CohenGresser.com
Email: rbryer@cohengresser.com
Counsel appearing specially to challenge
jurisdiction on behalf of Cross-Defendants
Marc-Olivier Perrin, SAS Miraval Provence,
Familles Perrin, SAS Petrichor, Vins et
Domaines Perrin SC, SASU Le Domaine,
and SAS Distilleries de la Riviera

28

PROOF OF SERVICE