Attorneys For Defendant and Cross-Complainant Tenute Del Mondo, B.V

1 KEITH R.
HUMMEL (admitted pro hac vice)

JUSTIN C. CLARKE (admitted pro hac vice)
2 JONATHAN MOONEY (admitted pro hac vice)
CRAVATH, SWAINE & MOORE LLP
3 Two Manhattan West
4 375 Ninth Avenue
New York, NY 10001
5 Telephone: (212) 474-1000
Facsimile: (212) 474-3700
6
JOE TUFFAHA (Bar No. 253723)
7 joe.tuffaha@ltlattorneys.com
8 PRASHANTH CHENNAKESAVAN (Bar No. 284022)
prashanth.chennakesavan@ltlattorneys.com
9 LTL ATTORNEYS LLP
300 South Grand Avenue, Suite 3950
10 Los Angeles, CA 90071
Telephone: (213) 612-8900
11 Facsimile: (213) 612-3773
12 Attorneys for Defendant and
Cross-Complainant
13 Tenute del Mondo, B.V.
14 SUPERIOR COURT OF THE STATE OF CALIFORNIA

15
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
16
WILLIAM B. PITT, an individual, and Case No. 22STCV06081
17
MONDO BONGO, LLC, a California
limited liability company, DEFENDANT AND CROSS-
18
COMPLAINANT TENUTE DEL
19 Plaintiffs, MONDO B.V.’S CROSS-COMPLAINT
FOR VIOLATION OF CAL. PENAL
20 vs. CODE § 496
21 ANGELINA JOLIE, an individual, and DEMAND FOR JURY TRIAL
NOUVEL, LLC, a California limited
22 liability company, YURI SHEFLER, an Judge: Hon. Lia Martin
23 individual, ALEXEY OLIYNIK, an Dept.: 3
individual, SPI GROUP HOLDING
24 LIMITED, a Cyprus private limited Action Filed: February 17, 2022
company, and TENUTE DEL MONDO Trial Date: None set.
25 B.V., a Netherlands private limited
company,
26
Defendants.
27
28
TENUTE DEL MONDO’S CROSS-COMPLAINT

1 NOUVEL, LLC, a California limited
liability company,
2
Cross-Complainant,
3 vs.
4 WILLIAM B. PITT, an individual,
MONDO BONGO, LLC, a California
5 limited liability company, MARC-
OLIVIER PERRIN, an individual, SAS
6 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
individual, SAS PETRICHOR, a French
10 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
RIVIERA, a French limited liability
14 company, and ROES 1-10,
15
Cross-Defendants.
16
TENUTE DEL MONDO, B.V., a
17 Netherlands private limited company,
18 Cross-Complainant,
vs.
19
WILLIAM B. PITT, an individual,
20 MONDO BONGO, LLC, a California
limited liability company, and ROES 1-10,
21
Cross-Defendants.
22
23
24
25
26
27
28

1 TENUTE DEL MONDO, B.V. (“Tenute”), a Dutch private limited company, by and
2 through its attorneys, upon knowledge as to itself and its own acts, and upon information and
3 belief as to all other matters, alleges against Cross-Defendants WILLIAM B. PITT (“Pitt”), an
4 individual; and MONDO BONGO, LLC (“Mondo Bongo”), a California limited liability
5 company; and ROES 1-10 as follows:
6 NATURE OF THE ACTION
7 1. This is a claim against Brad Pitt and his wholly owned investment company,
8 Mondo Bongo, under California Penal Code Section 496, for their participation in a scheme to
9 steal millions of dollars from Tenute, conceal that theft, and withhold the stolen property.
10 2. Chateau Miraval is a world-famous producer of wine, particularly an award
11 winning rosé wine, and owns a sprawling country estate in France. The Miraval estate was
12 purchased in 2008 by Pitt, through his investment company, Mondo Bongo, LLC, and Angelina
13 Jolie, through her investment company, Nouvel LLC. Mondo Bongo and Nouvel each owned
14 50% of Chateau Miraval through a Luxembourg company, Quimicum s.a.r.l. For many years
15 there was harmony between Pitt and Jolie, and together, they contributed millions to build the
16 Miraval brand into the highly profitable business it is today. That changed after Jolie filed for
17 divorce from Pitt in 2016. Pitt then began a vindictive campaign against his former wife, exerting
18 unlawful control over Chateau Miraval, excluding her from its operations, and depriving her and
19 Nouvel of the enormous profits generated by the business. Pitt caused Chateau Miraval’s funds
20 and assets to be spent on his personal expenses and to be diverted to his other business ventures
21 rather than be paid out as dividends and loan repayments that would flow through Quimicum to
22 Mondo Bongo and Nouvel, and ultimately back to Pitt and Jolie. That illegal conduct continued,
23 and even intensified, after Jolie sold Nouvel to Tenute, the wine-making arm of the international
24 beverage company, Stoli Group.
25 3. Using his unlawful control of Chateau Miraval, Pitt caused millions of its funds to
26 be spent on projects that benefit him personally, including more than $1 million on renovations for
27 a swimming pool that only he uses. Worse yet, Pitt has diverted the company’s assets to his side
28 businesses—which include a recording studio called Studio Miraval, a cosmetics line called Le
1
1 Domaine, and a gin brand called The Gardener—by funding them with Chateau Miraval’s money
2 and/or allowing them to use Chateau Miraval’s image, premises and assets for zero or below-
3 market compensation. All the while, Pitt and Mondo Bongo have deceitfully concealed these
4 wrongful uses of Chateau Miraval’s resources from Jolie, Jolie’s company, Nouvel, its manager,
5 Terry Bird, and Jolie’s successor-in-interest, Tenute. This theft has put millions of dollars in the
6 pockets of Pitt’s and Mondo Bongo’s business ventures, and has diverted dividends and loan
7 repayments to them that otherwise would have been paid out to Tenute as one of the ultimate
8 owners of Chateau Miraval.
9 4. Tenute, the owner of Nouvel, is entitled to its fair share of profits from Chateau
10 Miraval because the two entities in the chain of ownership between Tenute and Chateau Miraval—
11 Quimicum and Nouvel—are investment companies that pass their profits on to their shareholders.
12 Also, between 2009 and 2013, Tenute’s predecessor-in-interest, Jolie, made loans totaling €20
13 million to Chateau Miraval through Nouvel and Quimicum. These loans were made exclusively
14 for the purpose of supporting Chateau Miraval to become a profitable business, and were
15 specifically structured as loans instead of equity so the funds would be repaid once Chateau
16 Miraval became profitable. This arrangement also ensured that there would be no unfairness to
17 Pitt or Jolie if either loaned more money because any disproportionate investment would be
18 repaid. When Jolie sold her membership interest in Nouvel to Tenute, she also assigned her
19 shareholder loans to Tenute.
20 5. The net effect of Pitt’s and Mondo Bongo’s illegal conduct has been to reduce the
21 profits and repayments that Tenute receives from Chateau Miraval. In fact, it has not received any
22 payments as a result of Cross-Defendants’ conduct. Tenute files this Cross-Complaint to seek
23 redress for the illegal and malicious actions of Pitt and Mondo Bongo, including the monies Pitt
24 and Mondo Bongo diverted, treble damages, and punitive damages.
25 THE PARTIES AND OTHER RELEVANT ENTITIES
26 6. Defendant and Cross-Complainant Tenute is a Dutch private limited company that
27 has its registered office at Hoogoorddreef 15, 1001BA Amsterdam, Netherlands.
28 7. Plaintiff and Cross-Defendant William B. Pitt is an individual residing in Los
2
1 Angeles, California.
2 8. Plaintiff and Cross-Defendant Mondo Bongo, LLC is a limited liability company
3 organized and existing under the laws of California that has its registered office at 9100 Wilshire
4 Boulevard, STE 1000W, Beverly Hills, California 90212. Pitt is the sole member of Mondo
5 Bongo, holding 100% of its membership interest, and is also its sole manager.
6 9. SA Chateau Miraval (“Chateau Miraval”) is a French company that owns a 1300-
7 acre wine-producing estate in the south of France that has its registered office at F-83570 Correns,
8 Domaine de Miraval, France.
9 10. Defendant and Cross-Complainant Nouvel, LLC (“Nouvel”) is a limited liability
10 company organized and existing under the laws of California that has its registered office at
11 500 Capitol Mall, Suite 1600, Sacramento, California 95814. Angelina Jolie was the sole member
12 of Nouvel until October 2021, at which time Jolie transferred her 100% interest in Nouvel to
13 Defendant and Cross-Complainant Tenute. Nouvel is an investment company whose assets are its
14 loans to Quimicum and its 50% ownership interest in Quimicum.
15 11. Quimicum S.à r.l. (“Quimicum”) is a limited liability company organized and
16 existing under the laws of Luxembourg that has its registered office at 17 boulevard F.W.
17 Raiffeisen, L-2411 Luxembourg (Cloche d’Or), Grand Duchy of Luxembourg. Quimicum is the
18 100% owner of Chateau Miraval. Quimicum is a company whose assets are its shares of, and
19 loans to, Chateau Miraval. Nouvel and Mondo Bongo each own 50% of the shares of Quimicum.
20 JURISDICTION AND VENUE
21 12. This Court has personal jurisdiction over Pitt under California Code of Civil
22 Procedure § 410.10, because he conducted business in, is a resident of, and/or committed the acts
23 alleged herein in California.
24 13. This Court has personal jurisdiction over Mondo Bongo under California Code of
25 Civil Procedure § 410.10, because Mondo Bongo is a limited liability company organized and
26 existing under the laws of California with its principal place of business in California, and/or
27 because it committed the acts alleged herein in California.
28 14. This Court has subject matter jurisdiction because Tenute asserts claims under
3
1 California law and the amount in controversy exceeds this Court’s jurisdictional minimum of
2 $25,000.
3 15. Venue is proper under California Code of Civil Procedure § 395(a) because Pitt and
4 Mondo Bongo reside in the County of Los Angeles, California.
5 FACTUAL BACKGROUND
6 I. Pitt and Jolie Purchase Chateau Miraval and Revitalize Its Wine Business
7 16. In 2008, Pitt and Jolie purchased Chateau Miraval through their separate
8 investment companies. Pitt’s company, which he wholly owns, is named Mondo Bongo. Jolie’s
9 company, which she wholly owned at the time, is named Nouvel.
10 17. The couple did not buy Chateau Miraval, which is owned by the Luxembourg
11 company Quimicum, directly. Instead, Pitt and Jolie purchased all the shares of Quimicum for
12 €25 million, thereby also acquiring Chateau Miraval. Mondo Bongo initially purchased 60% of
13 Quimicum’s shares, and Nouvel purchased 40% of Quimicum’s shares. In 2013, Pitt voluntarily
14 caused Mondo Bongo to transfer 10% of the outstanding shares of Quimicum to Nouvel.
15 18. When Jolie and Pitt purchased Chateau Miraval, its wine business was not
16 generating a profit. They quickly got to work investing in the business and making improvements
17 to the property. In July 2009, Jolie loaned €4 million to Nouvel and caused Nouvel to loan the
18 same €4 million to Quimicum through a Loan Facility Agreement, which stipulated that
19 Quimicum would in turn loan the funds to Chateau Miraval. Pitt was aware of this loan and
20 caused Mondo Bongo to enter into a similar arrangement. In September 2011, Jolie caused
21 Nouvel to increase the loan facility to €10 million. Jolie later caused Nouvel to alter the Loan
22 Facility Agreement in two more instances: in 2013, Nouvel increased the amount of the loan
23 facility to €20 million; and in 2015, Nouvel and Quimicum agreed that the loans would mature on
24 December 31, 2023, unless mutually agreed otherwise. Each time that Nouvel loaned money to
25 Quimicum to be loaned in turn to Chateau Miraval, Jolie first loaned the same amount of money to
26 Nouvel. Accordingly, Jolie was the ultimate source of all the funds loaned to Chateau Miraval
27 through Nouvel and Quimicum. Pitt and Mondo Bongo both knew this. Indeed, Pitt was the
28 ultimate source of all the funds loaned to Chateau Miraval through Mondo Bongo. Both Jolie’s
4
1 and Pitt’s loans provided much-needed money to Chateau Miraval to fund improvements.
2 19. These contributions were structured as loans, not equity investments, so that once
3 Chateau Miraval became profitable the loans could be repaid to Nouvel and Mondo Bongo, and
4 ultimately to Jolie and Pitt, thereby accounting for any disproportionate contributions.
5 20. To improve the quality of its winemaking, Chateau Miraval entered into a business
6 relationship with SAS Familles Perrin, a well-known French winemaker. In March 2013, Chateau
7 Miraval and Familles Perrin created a new entity, Miraval Provence, as a joint venture to operate
8 the estate’s vineyards, and to market and distribute the wine produced at Chateau Miraval.
9 21. The business venture between Chateau Miraval and Familles Perrin was a success.
10 Miraval Provence’s profits grew, from around €1 million in 2013 to around €15 million in 2022.
11 22. Amidst the initial success of their investment, Pitt and Jolie married at Chateau
12 Miraval on August 23, 2014, surrounded by a small group of friends and family.
13 23. As is the case with many families, the couple divided up responsibilities. Pitt was
14 entrusted with overseeing the couple’s investment in Chateau Miraval. Pitt named two of his
15 trusted associates, Gary Bradbury and Roland Venturini, both of whom owe their livelihoods to
16 Pitt, as directors and officers of Chateau Miraval.
17 II. After Jolie Files for Divorce, Pitt Wrongfully Seizes Absolute Control of
18 Chateau Miraval and Moves To Financially Harm Jolie.
19 24. Despite the success of their wine business, Pitt and Jolie’s personal relationship
20 was suffering. Over the years, Pitt developed an addiction to alcohol, which contributed to his
21 increasingly destructive behavior towards Jolie and the rest of their family. On September 19,
22 2016, Jolie filed for divorce.
23 A. Pitt Blocks Jolie and Nouvel from Participation in Chateau Miraval
24 25. Chateau Miraval has never distributed any of the business’ profits to its
25 shareholders. Never. After filing for divorce, Jolie noticed that the business was spending large
26 sums of money on projects that did not appear to have a legitimate business purpose. She began to
27 insist on receiving information about Chateau Miraval’s finances and sought to exercise greater
28 supervision over its business. Pitt frequently resisted her requests and, over time, shut her out of
5
1 the business, and deprived her of information about Chateau Miraval’s finances.
2 26. Getting nowhere with Pitt, Jolie and Nouvel challenged Mondo Bongo and Pitt’s de
3 facto control of Chateau Miraval, and exclusion of them from its management, at a Quimicum
4 general shareholders meeting held on September 8, 2020. Nouvel stated that it was “highly
5 concerned that Mondo Bongo LLC, does, without a mandate and without concertation [French for
6 consultation] with Nouvel LLC, de facto run the Company and its subsidiaries and ignores any
7 rights of its co-shareholder in this respect”. Nouvel noted that it was “opposed to the fact that no
8 profits are ever distributed” to shareholders despite the fact that Chateau Miraval was profitable.
9 Nouvel requested that Quimicum analyze and submit proposals regarding distributing profits or
10 reimbursing existing shareholder loans.
11 27. Instead of being receptive to Nouvel’s proposals, Pitt steadfastly rejected them.
12 The dispute between the shareholders caused Quimicum’s sole director, a representative from
13 Ocorian (a management, administrative, and fiduciary services agent) to resign. Pitt and Mondo
14 Bongo then imposed a shareholder deadlock at Quimicum, preventing the election of Quimicum
15 directors.
16 28. Pitt did this for a reason. He knew that Quimicum’s bylaws provide that the
17 company acts through its directors, including to exercise oversight over Chateau Miraval. Under
18 Luxembourg law, Quimicum is unable to act if it has no directors. Pitt and Mondo Bongo knew
19 that as long as the deadlock at Quimicum exists, no one could place checks on Pitt’s diversion of
20 Chateau Miraval’s funds and resources into his self-serving side-projects or cause Chateau
21 Miraval to distribute its profits to its shareholders or repay its loans.
22 29. Pitt also ensured that Chateau Miraval’s board was fully stocked with his vassals—
23 people who would take direction from him and whom he could trust to execute his plans. Chateau
24 Miraval’s directors, Bradbury and Venturini, are entirely beholden to Pitt—he hired both of them
25 to work at Chateau Miraval; they both depend on him for their continued employment; they both
26 have longstanding relationships with him, including as his subordinates at Chateau Miraval; and
27 they both lack independence from him. Venturini, whose email nickname for Pitt is “Boss Pitt”, is
28 even paid by Pitt directly. Pitt’s control over these individuals further enabled his de facto control
6
1 of the company and theft of its assets.
2 B. Pitt Strips Chateau Miraval of Its Assets.
3 30. At the same time as they were solidifying their grip over Chateau Miraval and
4 blocking Jolie from participating in the business, Pitt and Mondo Bongo stepped up their efforts to
5 misappropriate the business’s assets for their own benefit. Pitt’s and Mondo Bongo’s scheme was
6 made possible by the absolute control they exercise over Chateau Miraval. Among the illegal acts
7 the Cross-Defendants pursued, and continue to pursue, are the following:
8 i. Diversion of Corporate Profits to Pitt Vanity Projects
9 31. With the complicity of Venturini and Bradbury, Pitt first ensured that Nouvel and
10 its owner would never see any of the profits from Chateau Miraval’s incredibly successful wine
11 business. Pitt diverted those profits, which should have been paid out as dividends and loan
12 repayments, to his side businesses and used them to fund a series of wasteful vanity projects that
13 benefitted him personally.
14 32. The wine business has been enormously profitable. The profits generated by
15 Miraval Provence, Chateau Miraval’s wine-making venture, have risen from around €1 million in
16 2013 to around €15 million in 2022. Because of this success, Miraval Provence has been able to
17 pay substantial annual dividends to Chateau Miraval. In total, between 2013 and 2022, Miraval
18 Provence has paid about €45 million in dividends to Chateau Miraval.
19 33. Not a penny of the tens of millions of euros that Chateau Miraval has earned over
20 the years has ever been used to repay its loans from Quimicum or otherwise been distributed to
21 Quimicum or its shareholders. Year after year, Chateau Miraval’s board, at Pitt’s direction, has
22 refused to pay dividends to Quimicum. Instead, Pitt uses the company’s funds as his own personal
23 pocket money to indulge his wasteful spending and to benefit his business ventures.
24 34. Pitt has caused Chateau Miraval to spend tens of millions of dollars on vanity
25 projects that have little, if any, business justification. For example, Chateau Miraval’s accounts
26 indicate that in 2020 alone, Chateau Miraval spent €4,034,980 on construction at a nearby house
27 that is owned by Chateau Miraval, €1,106,658 on a swimming pool, and €2,963,207 on “garment
28 works”. Following the divorce filing, only Pitt has stayed at the manor house owned by Chateau
7
1 Miraval and enjoyed the benefits of a personal lease on the property—Jolie never returned there.
2 Accordingly, Pitt is effectively charging personal expenses to the Chateau Miraval business.
3 35. Numerous expenses in the years following the divorce were incurred either over
4 Nouvel’s objection or without its knowledge. At Pitt’s direction, Chateau Miraval approved
5 budgets without seeking Jolie or Nouvel’s input or approval, and only told Jolie and Nouvel about
6 many renovations after they had been started or completed.
7 36. Alarmed by this spending and concealment of information, Jolie asked questions.
8 In August 2020, Jolie’s representatives had a lengthy call with Venturini to challenge his
9 authorization of spending on expenses for the sole benefit of Pitt. During this call, Venturini—
10 whom Pitt insisted on paying directly and not through Chateau Miraval—repeatedly responded in
11 substance, “What am I to do? He’s my boss.” Following this call, Venturini made no effort to put
12 a stop to Chateau Miraval’s spending on Pitt’s personal expenses.
13 37. Documents recently produced in this litigation demonstrate that Pitt and Mondo
14 Bongo have misappropriated millions of dollars of Chateau Miraval funds that should have been
15 used to distribute Chateau Miraval’s profits to Tenute through Nouvel and Quimicum or to repay
16 the loans Tenute holds.
17 ii. Pitt Schemes To Divert Chateau Miraval’s Resources To His Projects
18 38. Pitt has fleeced Chateau Miraval of its assets in favor of his personal business
19 endeavors. In an obvious case of self-dealing, Pitt and Mondo Bongo have set up side businesses
20 that exploit the name, image, premises and financial resources of Chateau Miraval—all without
21 sharing any returns with Nouvel and Tenute.
22 39. Miraval Studios. Chateau Miraval’s funds are being spent on renovations meant to
23 benefit a Pitt vanity project: a recording company located at the chateau named Miraval Studios
24 on which he is apparently collaborating with French producer Damien Quintard.
25 40. Miraval Studios is 40% owned by Pitt through Mondo Bongo, 50% by DQ
26 Holdings (Damien Quintard’s company) and only 10% by Chateau Miraval. Venturini, Pitt’s
27 handpicked director and CEO of Chateau Miraval, is the Managing Director of Miraval Studios.
28 Warren Grant, Pitt’s Hollywood business manager, is the studio’s Supplementary President.
8
1 41. While Mondo Bongo is a 40% owner of Miraval Studios, Nouvel and Tenute have
2 no direct ownership interest in the venture. They are relegated to a 5% indirect ownership,
3 through Chateau Miraval’s 10% interest. Thus, any money generated from Nouvel and Mondo
4 Bongo’s joint investment in Chateau Miraval that is used to benefit Miraval Studios is a straight-
5 up diversion of cash profits that should properly be split evenly between Tenute and Pitt.
6 42. Le Domaine and Distilleries de la Rivieria. Pitt has gone even further. On
7 August 6, 2021, Mondo Bongo and Vins et Domaines Perrin, a corporation controlled by the
8 Perrin family, established a company called Petrichor, of which they each own 50%. The same
9 day, Pitt and Perrin established Le Domaine, a cosmetics company, and Distilleries de la Riviera, a
10 gin maker. Distilleries de la Rivieria is wholly owned by Petrichor, Le Domaine is 95% owned by
11 Petrichor, and both are managed by Perrin. Neither Chateau Miraval, nor Quimicum, nor Nouvel,
12 nor Tenute has any ownership interest in Petrichor, Le Domaine, or Distilleries de la Riviera.
13 43. The link between these two ventures and Chateau Miraval is clear: In a December
14 12, 2021, report entitled “Domaine Miraval Update”, which was sent to Pitt’s business manager
15 Grant but not to Jolie, Novel or Tenute, the very first item is “Developing the two new projects:
16 Cosmetics and Spirits. . . .” Later in the report, Venturini candidly acknowledged that “[t]hese
17 two new joint ventures will require Chateau Miraval and I hope my participation”.
18 44. Chateau Miraval appears to play a crucial role in Le Domaine’s business: the
19 skincare products are reportedly made with grapes grown on the property’s vineyard. Pitt and
20 Perrin have also exploited the Chateau Miraval name extensively in their efforts to market Le
21 Domaine, apparently for no compensation. Pitt and Perrin feature the Miraval name prominently
22 throughout Le Domaine’s website, which includes pictures of Pitt and Perrin walking through the
23 estate’s vineyards and descriptions of how the two men “began exploring the treasures of the
24 vineyard, and saw its potential beyond wine-making”.
25 45. Pitt and Perrin’s other business, Distilleries de la Rivieria, which distributes The
26 Gardener Gin, also makes use of the Miraval name to promote its business. Indeed, the business
27 uses “MRVL” as its registered trade name. As with Le Domaine, Pitt relies heavily upon the
28 Chateau Miraval name and brand to market The Gardener Gin. The Wine Spectator linked the two
9
1 explicitly: “Meet The Gardener, a French Riviera–inspired spirit from the partners behind luxury
2 Provence rosé brand Miraval.”
3 III. Unable To Reach an Agreement with Pitt, Jolie Sells Her Interest in Nouvel.
4 46. Frozen out of participating as an equal partner in the governance of Quimicum and
5 Chateau Miraval, Jolie sold Nouvel to Tenute, a subsidiary of Stoli Group, a well-established wine
6 and spirits conglomerate, in October 2021. As part of the transaction, Jolie assigned to Tenute all
7 the loans she had made to Nouvel.
8 IV. Pitt Attempts To Drive Tenute Out
9 47. Pitt did not react well to having Tenute as a business partner. He was plainly
10 concerned that Tenute, a well-capitalized business with vast experience in the wine business,
11 would, understandably, want to participate in the business aspects of Chateau Miraval and would
12 discover the full extent of his misconduct. So, Pitt has pugnaciously caused Mondo Bongo to
13 resist all reasonable efforts to resolve the deadlock at Quimicum, and made sure that Bradbury,
14 Venturini, and Grant obstructed Tenute and Nouvel from participating in the business or obtaining
15 access to Chateau Miraval’s records. Pitt is desperate to stop Tenute (or any other new partner, for
16 that matter) from uncovering the systematic malfeasance and asset-stripping he orchestrated.
17 48. Bradbury, Venturini, and Grant willing went along with Pitt’s plan. Shortly after
18 Tenute acquired Nouvel, Venturini wrote to Grant: “On October 8th, we all learned that Mr Yuri
19 Scheffler and the Stoli Group via Tenute Del Mondo took over Nouvel LLC.” He continued:
20 “With the clear understanding that BP has been helping making decision on the ground in Chateau
21 Miraval since I have been here, we will, of course, continue taking direction from him.” Venturini
22 knew his orders—do what the “boss” (Pitt) says and shut out Tenute and the Stoli Group.
23 A. Pitt and Mondo Bongo Refuse To Resolve the Deadlock at Quimicum.
24 49. By June 2021, Quimicum’s director had resigned, leaving Quimicum directorless.
25 Under Luxembourg law, as discussed above, that means that Quimicum cannot take any action.
26 50. Over the course of the next few months, Tenute and Nouvel repeatedly sought to
27 engage with Pitt and Mondo Bongo in an effort to break the stalemate. Nouvel convened several
28 general meetings of the Quimicum shareholders in an effort to resolve the deadlock.
10
1 51. For example, on October 28, 2021, Nouvel proposed a board of two Nouvel
2 directors, two Mondo Bongo directors, and a director chosen “among reputed Luxembourg
3 independent directors”. Nouvel also identified its two director candidates, both of whom had
4 extensive experience in the wine and spirits industry, to Mondo Bongo. At the Quimicum board
5 meeting the following day, Mondo Bongo, through its lawyers, rejected Nouvel’s proposal out of
6 hand. Mondo Bongo’s lawyers instead proposed that Grant—who they incredibly claimed was a
7 “neutral person”—serve as Quimicum’s sole director. Nouvel, reasonably, rejected this
8 undisguised effort by Pitt and Mondo Bongo to assume complete control of Quimicum.
9 52. Mondo Bongo has voted against Nouvel’s proposals to appoint a functional board
10 of directors at Quimicum because it is in Pitt and Mondo Bongo’s interest to keep Quimicum
11 inactive. As long as Quimicum cannot properly supervise Chateau Miraval, Pitt and Mondo
12 Bongo can continue to create and to profit from companies in which they hold an interest (but in
13 which Tenute and Nouvel hold little or no interest) that misuse the Miraval name and can continue
14 to appropriate Chateau Miraval’s assets, thereby draining Quimicum’s only asset of value.
15 V. Pitt and Mondo Bongo’s Illegal Conduct Has Harmed Tenute
16 53. Pitt and Mondo Bongo’s illegal conduct has significantly harmed Tenute.
17 54. Tenute is harmed by the ongoing diversion of Chateau Miraval’s funds and assets.
18 As set forth above, Pitt and Mondo Bongo are responsible for causing millions of dollars of
19 Chateau Miraval funds to be spent on a host of personal vanity projects and other investments
20 designed to benefit Pitt and Mondo Bongo at the expense of Chateau Miraval and Tenute.
21 55. Tenute is also being harmed by its inability to participate economically in Chateau
22 Miraval’s ongoing financial success. Miraval Provence’s profits have steadily increased year after
23 year, and between 2013 and 2022, Miraval Provence distributed approximately 90 million euros in
24 dividends to its shareholders, of which approximately 45 million euros were provided to Chateau
25 Miraval. None of this money has been distributed to Quimicum’s shareholders, which means
26 Tenute has never received a penny of these profits. Nor has Tenute received a penny of repayment
27 for the millions of dollars in loans that Chateau Miraval owes Quimicum, which it in turn owes
28 Tenute as a result of its predecessor-in-interest, Jolie’s, investment into the chateau and wine
11
1 business. Pitt and Mondo Bongo have diverted all of the wine business’ profits to their own
2 purposes, including companies in which Mondo Bongo holds an ownership interest (but in which
3 Tenute holds little or no interest), thereby benefiting Mondo Bongo at Tenute’s expense.
4 FIRST CLAIM FOR RELIEF
5 Violation of Penal Code § 496
6 (Cross-Complainant Tenute Against Cross-Defendants William B. Pitt and Mondo Bongo,
7 LLC)
8 56. Cross-Complainant Tenute realleges and incorporates by reference each of
9 Paragraphs 1 through 55 as though fully set forth herein.
10 57. Penal Code § 496, subdivision (a) states: “Every person who buys or receives any
11 property that has been stolen or that has been obtained in any manner constituting theft or
12 extortion, knowing the property to be so stolen in obtained, or who conceals, sells, withholds, or
13 aids in concealing, selling, or withholding any property from the owner, knowing the property to
14 be so stolen or obtained” violates the Penal Code. Subdivision (c) permits any person injured by a
15 violation of subdivision (a) to “bring an action for three times the amount of actual damages, if
16 any, sustained by the plaintiff, costs of suit, and reasonable attorney’s fees”.
17 58. In Siry Investment, L.P. v. Farkhondehpour, (2022) 13 Cal. 5th 333 (hereinafter
18 “Siry”), the California Supreme Court outlined the scope of Section 496’s civil liability provision.
19 There, plaintiff and defendants established a business partnership to “renovate and lease space” in
20 a downtown Los Angeles building. Siry, 13 Cal. 5th at 339. Plaintiff was to receive
21 approximately 40% of the benefits of the partnership; the relevant defendants were to receive
22 approximately 50%; and others were to receive 10%. Id. at 339–40. Five years later, the
23 defendants created a new entity (“DTLA”) and asked the building’s tenants to pay rent directly to
24 DTLA instead of the partnership. Id. The defendants also “commenced charging personal and
25 other nonpartnership expenses to the partnership”. Id. The “net effect of these actions was to
26 direct [the third party property manager] to underpay plaintiff its cash distributions”. Id.
27 59. The Supreme Court explained that Section 496, subdivision (a)’s use of the “broad
28 phrase, ‘any manner constituting theft,’ includes theft of funds by false pretense”. Siry, 13 Cal.
12
1 5th at 349, 361. Speaking more broadly about the scope of the statute, the Court observed that
2 theft includes taking “the personal property of another”; “fraudulently appropriat[ing] property
3 which has been entrusted”; or “by any false or fraudulent representation or pretense [] defraud[ing]
4 any other person of money, labor or real or personal property”. Id. at 350.
5 60. The Supreme Court then held that the statute’s “unambiguous relevant language
6 covers fraudulent diversion of partnership funds”. Siry, 13 Cal. 5th at 361. In Siry, for example,
7 the defendants “‘received’ ‘property’ (the diverted partnership funds) belonging to plaintiff,
8 having ‘obtained’ the diverted funds ‘in a manner constituting theft’”. Id. (citations and alterations
9 omitted). The defendants “also ‘concealed’ or ‘withheld’ those funds (and/or aided in concealing
10 or withholding them) from plaintiff” and did so “‘knowing’ the diverted funds were ‘so …
11 obtained’”. Id. (citations and alterations omitted). Thus, the Court found that a violation of
12 Section 496 lies where a joint owner of a business knowingly takes unlawful steps to enrich itself
13 to its co-owner’s detriment.
14 61. Pitt and Mondo Bongo have engaged in conduct nearly identical to that in Siry.
15 They have diverted Chateau Miraval’s profits to their own purposes and have used Chateau
16 Miraval’s assets to fund and develop their own side businesses.
17 62. As in Siry, Tenute (through Nouvel) and Pitt (through Mondo Bongo) each own
18 substantial interests in Quimicum, which in turn owns Chateau Miraval. Tenute owns Nouvel and
19 is entitled to its share of the profits generated from Chateau Miraval. The two entities in the chain
20 of ownership between Tenute and Chateau Miraval—Nouvel and Quimicum—are investment
21 companies that ultimately pass their profits on to their shareholders. Thus, any profits distributed
22 from Chateau Miraval would ultimately flow to Tenute.
23 63. In addition, between 2009 and 2013, Tenute’s predecessor-in-interest, Jolie, made
24 loans totaling about €20 million to Chateau Miraval through Nouvel and Quimicum. At the time,
25 Chateau Miraval was losing money and required investment. Jolie, through Nouvel, and Pitt,
26 through Mondo Bongo, contributed their own funds, structured as loans, so that once Chateau
27 Miraval became profitable, the loans would be repaid to Nouvel and Mondo Bongo, and
28 ultimately to Jolie and Pitt, thereby accounting for any disproportionate investment. When Jolie
13
1 sold her membership interest in Nouvel to Tenute, she assigned the loans to Tenute. As the
2 successor-in-interest to Jolie, Tenute is entitled to repayment of the loans, which matured on
3 December 31, 2023.
4 64. As Jolie and Pitt desired, Chateau Miraval has become a famous, internationally
5 known brand and is very successful, in large part because of Jolie’s loans. Chateau Miraval’s
6 wine business, now housed in its joint venture, Miraval Provence, has seen profits rise year after
7 year. Because of this healthy, and increasing, profitability, Miraval Provence has been able to pay
8 substantial dividends to Chateau Miraval. In total, between 2013 and 2022, Miraval Provence has
9 paid about €45 million in dividends to Chateau Miraval. But despite the incredible success of
10 Chateau Miraval, to date, neither Nouvel nor Tenute has received a single penny from their
11 investment in Miraval or the repayment of any of their €20 million in loans to Chateau Miraval.
12 65. The reason is clear. Pitt and Mondo Bongo have turned Chateau Miraval into their
13 personal piggy bank. They have entered into a series of transactions using Chateau Miraval’s
14 funds that have deprived Tenute of the profits and loan repayments to which it is entitled.
15 Specifically, Cross-Defendants have diverted Chateau Miraval’s funds to a number of other
16 businesses in which Chateau Miraval (and by extension Nouvel and Tenute) have little or no
17 ownership interest and have used Chateau Miraval’s assets to fund their personal expenses.
18 66. Pitt and Mondo Bongo have misappropriated millions of dollars of Chateau
19 Miraval funds that should have been distributed to Tenute through Nouvel and Quimicum or to
20 repay Tenute’s loans to Chateau Miraval that had been made through Nouvel and Quimicum. Pitt
21 and Mondo Bongo have accomplished this by causing Grant, Bradbury and Venturi, who owe
22 their livelihoods to Pitt and will obey his commands without question, to use their positions as
23 employees and directors of Chateau Miraval and other entities to misappropriate these funds by
24 transferring them to Pitt and Mondo Bongo’s private ventures.
25 67. Pitt and Mondo Bongo have been able to conceal their conduct by refusing to allow
26 Jolie, Nouvel, and, now, Tenute to participate in the operations of Chateau Miraval and by
27 refusing to supply them with information about the business’s operations and finances. Pitt and
28 Mondo Bongo, who have equal ownership of Chateau Miraval with Tenute and Nouvel, have been
14
1 able to accomplish such concealment because they have unlawfully seized control of Chateau
2 Miraval and have ensured that Quimicum cannot exercise oversight of Chateau Miraval by
3 imposing a shareholder deadlock at Quimicum, Chateau Miraval’s parent. It has primarily been
4 though documents produced during this litigation that the true scope of Pitt and Mondo Bongo’s
5 misconduct has come to light.
6 68. Take, for example, Miraval Studios. On June 13, 2021, Venturini wrote an email to
7 Grant attaching a budget for the cost of constructing Miraval Studios’ studio space. The budget
8 indicated a whopping cost of over €2 million for construction. Venturini made clear in his email
9 that the enormous expenses associated with Miraval Studios would be intentionally concealed
10 from Tenute’s predecessor-in-interest, Jolie, writing, “[o]f course none of these info have gotten to
11 AJ for now”. Pitt fully supported the decision to conceal the enormous cost of Miraval Studios
12 from Jolie. In a June 28, 2021, message to Venturini about the Miraval Studios budget, he wrote:
13 “I believe we should no longer send AJ reports as she is trying to shop her shares.” Pitt and
14 Venturini sought to conceal the costs of Miraval Studios from Jolie for a simple reason: as
15 Venturini himself wrote, the “renovation and investment will be done by [Chateau Miraval]”.
16 69. As it turns out, a significant portion Miraval Studios’ expenses was borne by
17 Chateau Miraval despite Chateau Miraval’s mere 10% stake in Miraval Studios compared to
18 Mondo Bongo’s (owned by Pitt) much larger 40% stake. The other 40% is owned by a stranger to
19 Chateau Miraval and Tenute – Damian Quintard, a disc jockey who appears to have contributed
20 virtually nothing to the construction of the studio. A September 2021 spreadsheet about Miraval
21 Studios sent from Venturini to Pitt and Grant includes a column for expenses paid by Chateau
22 Miraval. That column shows that Chateau Miraval incurred expenses of over €200,000 to support
23 Miraval Studios. In the cover email attaching the spreadsheet, Venturini wrote to Pitt and Grant
24 that to make Miraval Studios profitable, Chateau Miraval would need to charge Miraval Studios
25 “only 30,000 euros in rent per year”, which Venturini described as “well below market prices”.
26 70. On November 4, 2021, Quintard and Grant, as members of the supervisory
27 committee of Miraval Studios, approved it obtaining a €750,000 loan from Chateau Miraval. The
28 loan contract provides that the interest rate on the loan is “zero point two percent (0.2%) per
15
1 year”—ridiculously below the market rate, particularly for a new business venture as risky as
2 Miraval Studios. Chateau Miraval’s recently published financial accounts show that Chateau
3 Miraval indeed made a loan of over 750,000 euros to Miraval Studios. Chateau Miraval’s funds
4 have thus apparently been loaned essentially for free to an entity in which Pitt and Mondo Bongo
5 hold an outsize equity interest and stand to benefit disproportionally from Tenute and Nouvel.
6 71. On December 12, 2021, Venturini provided an update to Grant about Miraval
7 Studios. He reported that the construction budget had grown to €3 million. He also explained
8 that, in addition to the €750,000 loan, Chateau Miraval had spent €162,000 on “management fees”
9 for Miraval Studios and would soon pay an additional €162,000 to Miraval Studios, without
10 specifying the purpose for such profligate spending. Venturini noted that the additional €162,000
11 would only be “paid once we receive the dividends from Miraval Provence”—candidly admitting
12 that the dividends were being diverted to Miraval Studios. More than a million euros of Chateau
13 Miraval’s funds that should have been distributed to Tenute or used to repay Tenute’s loans have
14 instead been diverted to a business entity in which Pitt and Mondo Bongo hold a significantly
15 greater interest than Tenute. Just as in Siry, this diversion of funds qualifies as theft.
16 72. Cross-Defendants also caused Chateau Miraval to spend millions on projects that
17 have no legitimate business justification. For example, Chateau Miraval’s accounts indicate that
18 in 2020 alone, Chateau Miraval spent €4,034,980 on construction at a nearby house that is owned
19 by Chateau Miraval, €1,106,658 on a swimming pool, and €2,963,207 on “garment works”. Pitt
20 himself directed all this spending. For example, when Venturini wrote to him on January 28,
21 2020, seeking approval to proceed with construction on the pool, Pitt wrote to him “Great.
22 Confirmed Thx Roland”. Following the divorce filing, only Pitt has stayed at the manor house
23 owned by Chateau Miraval and enjoyed the benefits of a personal lease on the property—Jolie
24 never returned and Tenute has never enjoyed any benefit from the estate. Accordingly, Pitt is
25 effectively charging personal expenses to the Chateau Miraval business. Just like the defendants
26 in Siry, who diverted partnership profits by charging personal expenses, Cross-Defendants have
27 diverted profits from Chateau Miraval (which would have flowed to Tenute) to Pitt’s personal use.
28 73. Tenute’s predecessor-in-interest, Ms. Jolie, loaned €20 million to Chateau Miraval
16
1 for the limited purpose of supporting Chateau Miraval to become profitable. After Chateau
2 Miraval began receiving millions in dividends from Miraval Provence each year, Pitt and Mondo
3 Bongo should have caused, through their de facto control of Chateau Miraval, those funds to be
4 distributed to Quimicum, either through dividends or the repayment of loans, for further payment
5 to Nouvel and Mondo Bongo to the benefit of Tenute and Pitt. Pitt and Mondo Bongo had no
6 right to redirect those funds to businesses like Miraval Studios in which Pitt and Mondo Bongo
7 held an outsize interest relative to Jolie or Tenute. Like the defendants in Siry, who asked tenants
8 to pay rent to DTLA instead of the original partnership, Pitt and Mondo Bongo have looted
9 Chateau Miraval by causing it to fund their ventures instead of Quimicum, which would have
10 distributed those funds as dividends ultimately flowing to Tenute and Pitt. Their conduct amounts
11 to embezzlement.
12 74. The diversion of money described in this Cross-Complaint were not innocent or
13 inadvertent errors. Pitt and Mondo Bongo acted intentionally and then concealed their conduct.
14 Without Nouvel’s or Tenute’s approval, Pitt and Mondo Bongo have “with careful planning and
15 deliberation”, Siry, 13 Cal. 5th at 362, diverted funds and assets away from Chateau Miraval, and
16 therefore Tenute, and into their own ventures. And because Pitt and Mondo Bongo have caused
17 Chateau Miraval to cover the expenses of Miraval Studios in a manner grossly disproportionate to
18 Chateau Miraval’s ownership interest, they have defrauded Chateau Miraval and Tenute to benefit
19 Mondo Bongo. The “net effect” of this conduct, as in Siry, 13 Cal 5th at 362–64, has been to
20 deprive Tenute entirely of any distributions and to “underpay” the loans made to Chateau Miraval.
21 Cross-Defendants therefore “received property” and also “concealed” and/or “withheld” funds (the
22 assets and funds of Chateau Miraval diverted to Miraval Studios) from Tenute, having obtained
23 those funds in a manner constituting theft. Indeed, to date, neither Pitt nor Mondo Bongo has
24 returned any of the wrongfully diverted assets.
25 75. The effect of this conduct on Tenute is apparent. Despite generating tens of
26 millions of euros from its regular operations, Chateau Miraval has neither distributed any funds
27 nor repaid the loans that Tenute made to it through Nouvel and Quimicum. Like the plaintiff in
28 Siry, Tenute “qualifies under section 496(c) as ‘[a]ny person who has been injured by a violation
17
1 of subdivision (a)’”. Siry,13 Cal.5th at 362. In Siry, the defendants caused partnership revenues
2 to be diverted to another entity (DTLA) and reduced the partnership’s profits by charging personal
3 expenses to the partnership. Here, Pitt and Mondo Bongo diverted Chateau Miraval’s funds to
4 their own entities; used Chateau Miraval’s funds for personal expenses; and completely deprived
5 Tenute of distributions or the repayment of its loans. Tenute was thus harmed by Pitt and Mondo
6 Bongo’s conduct in an amount according to proof, but no less than the $20 million in loans that
7 have not been repaid.
8 76. In sum, Pitt and Mondo Bongo are liable under section 496(c) for their criminal
9 conduct. Section 496(c) provides that they are liable not only for Tenute’s actual damage, but for
10 treble damages, attorneys’ fees, and costs, all of which Tenute demands. Cross-Defendants
11 engaged in their wrongful conduct with malice, oppression, or fraud. Accordingly, Tentue also
12 requests that punitive damages be awarded.
13 PRAYER FOR RELIEF
14 WHEREFORE, Cross-Complainant respectfully requests judgment and relief against
15 Cross-Defendants as follows:
16 A. For judgment in favor of Cross-Complainant and against Cross-Defendants;
17 B. For compensatory damages in an amount to be proven at trial;
18 C. For treble damages for Cross-Defendants’ violation of California Penal Code § 496;
19 D. For punitive and exemplary damages;
20 E. For attorneys’ fees and costs, as provided by law;
21 F. For pre- and post-judgment interest; and
22 G. For any other relief that the Court deems just and proper.
23
24
25
26
27
28
18
1 Dated: May 13, 2024
2 Respectfully submitted,
3 By: /s/ Prashanth Chennakesavan
4 CRAVATH, SWAINE & MOORE LLP

Keith R. Hummel (admitted pro hac vice)
5 (N.Y. Bar No. 2430668)
6 Justin C. Clarke (admitted pro hac vice)
(N.Y. Bar No. 5076096)
7 Jonathan Mooney (admitted pro hac vice)
(N.Y. Bar No. 5648191)
375 Ninth Avenue
9 New York, NY 10001
10 Telephone: (212) 474-1000
Facsimile: (212) 474-3700
11
LTL ATTORNEYS LLP
12
14 PRASHANTH CHENNAKESAVAN
(Bar No. 284022)
15 prashanth.chennakesavan@ltlattorneys.com
LTL ATTORNEYS LLP
16 300 South Grand Avenue, Suite 3950
Los Angeles, CA 90071
17 Telephone: (213) 612-8900
18 Facsimile: (213) 612-3773
19 Attorneys for Defendant and Cross-Complainant

Tenute del Mondo, B.V.
20
21
22
23
24
25
26
27
28
19
1 DEMAND FOR JURY TRIAL
2 Cross-Complainant Tenute del Mondo, B.V. demands a trial by jury as to all issues so
3 triable.
4 Dated: May 13, 2024
5 Respectfully submitted,
6 By: /s/ Prashanth Chennakesavan
7 CRAVATH, SWAINE & MOORE LLP

Keith R. Hummel (admitted pro hac vice)
8 (N.Y. Bar No. 2430668)
9 Justin C. Clarke (admitted pro hac vice)
(N.Y. Bar No. 5076096)
10 Jonathan Mooney (admitted pro hac vice)
(N.Y. Bar No. 5648191)
375 Ninth Avenue
12 New York, NY 10001
13 Telephone: (212) 474-1000
Facsimile: (212) 474-3700
14
LTL ATTORNEYS LLP
15
17 PRASHANTH CHENNAKESAVAN
(Bar No. 284022)
18 prashanth.chennakesavan@ltlattorneys.com
LTL ATTORNEYS LLP
19 300 South Grand Avenue, Suite 3950
Los Angeles, CA 90071
20 Telephone: (213) 612-8900
21 Facsimile: (213) 612-3773
22 Attorneys for Defendant and Cross-Complainant

Tenute del Mondo, B.V.
23
24
25
26
27
28
20
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
3
I am employed in the County of Los Angeles State of California. I am over the age of 18,
4 and not a party to the within action. My business address is 300 South Grand Ave., Suite 3950 Los
Angeles, CA 90071. E-mail: lynette.suksnguan@ltlattorneys.com
5
On May 13, 2024, I served the foregoing document(s) described as:
6 DEFENDANT AND CROSS-COMPLAINANT TENUTE DEL MONDO B.V.’S CROSS-
COMPLAINT AGAINST CROSS-DEFENDANTS WILLIAM B. PITT, MONDO BONGO,
7 LLC, AND ROES 1-10 on the interested parties in this action.
8 John V. Berlinski Jonathan M. Moses (admitted pro hac vice)
9 BIRD, MARELLA, RHOW, Adam L. Goodman (admitted pro hac vice)
LINCENBERG, DROOKS & Jessica L. Layden (admitted pro hac vice)
10 NESSIM, LLP WACHTELL, LIPTON, ROSEN & KATZ
1875 Century Park East, 23rd Floor 51 West 52nd Street
11 Los Angeles, CA 90067-2561 New York, NY 10019
Tel: (310) 201-2100 Tel: (212) 403-1000
12 Fax: (310) 201-2110 Fax: (212) 403-2000
13 Email: jberlinski@birdmarella.com, Email: jmmoses@wlrk.com, algoodman@wlrk.com,
BTeachout@birdmarella.com, jllayden@wlrk.com
14 jcherlow@birdmarella.com,
fwang@birdmarella.com,
15 skosmacher@birdmarella.com,
KMeyer@birdmarella.com,
16 PYates@birdmarella.com,
17 Rattarson@birdmarella.com
18 Attorneys for Plaintiffs and Cross-Defendants William B. Pitt and Mondo Bongo, LLC and
Cross-Defendant Warren Grant
19
Laura Brill (SB No. 195889) Jonathan M. Moses (admitted pro hac vice)
20
Katelyn Kuwata (SB No. 319370) Adam L. Goodman (admitted pro hac vice)
21 KENDALL BRILL & KELLY LLP Jessica L. Layden (admitted pro hac vice)
10100 Santa Monica Blvd., Suite 1725 WACHTELL, LIPTON, ROSEN & KATZ
22 Los Angeles, CA 90067 51 West 52nd Street
Tel: (310) 556-2700 New York, NY 10019
23 Fax: (310) 556-2705 Tel: (212) 403-1000
24 Email: lbrill@kbkfirm.com Fax: (212) 403-2000
Email: kkuwata@kbkfirm.com Email: jmmoses@wlrk.com, algoodman@wlrk.com,
25 jllayden@wlrk.com
26 Attorneys appearing specially to challenge jurisdiction on behalf of Cross-Defendants Roland

Venturini and Gary Bradbury
27
28
21
PROOF OF SERVICE
1 Mark T. Drooks (SB No. 123561) S. Gale Dick (admitted pro hac vice)
BIRD, MARELLA, RHOW, Randall W. Bryer (admitted pro hac vice)
2 LINCENBERG, DROOKS & Phoebe H. King (admitted pro hac vice)
NESSIM, LLP COHEN & GRESSER LLP
3 1875 Century Park East, 23rd Floor 800 Third Avenue
4 Los Angeles, CA 90067-2561 New York, NY 10022
Tel: (310) 201-2100 Tel: (212) 957-7600
5 Email: mdrooks@birdmarella.com Email: sgdick@cohengresser.com,
rbryer@cohengresser.com, pking@cohengresser.com
6
Attorneys appearing specially to Attorneys appearing specially to challenge jurisdiction
7 challenge jurisdiction on behalf of Cross- on behalf of Cross-Defendants Marc-Olivier Perrin,
8 Defendants Marc-Olivier Perrin, SAS SAS Miraval Provence, SAS Familles Perrin, SAS
Miraval Provence, SAS Familles Perrin, Petrichor, Vins Et Domaines Perrin SC, SASU Le
9 SAS Petrichor, Vins Et Domaines Perrin Domaine, and SAS Distilleries de la Riviera
SC, SAS Miraval Studios, SASU Le
10 Domaine, and SAS Distilleries de la
Riviera
11
12
Paul D. Murphy (SB No. 159556) Julia B. Cherlow (SB No. 290538)
13 Daniel N. Csillag (SB No. 266773) John V. Berlinski (SB No. 208537)
MURPHY ROSEN LLP BIRD, MARELLA, RHOW, LINCENBERG,
14 100 Wilshire Blvd., Suite 1300 DROOKS & NESSIM, LLP
Santa Monica, CA 90401 1875 Century Park East, 23rd Floor
15
Tel: (310) 899-3300 Los Angeles, CA 90067
16 Fax: (310) 399-7201 Tel: (310) 201-2100
Email: pmurphy@murphyrosen.com, Fax: (310) 201-2110
17 dcsillag@murphyrosen.com Email: jcherlow@birdmarella.com
jberlinski@birdmarella.com
18 Attorneys for Defendant and Cross-
Complainant Angelina Jolie Attorneys appearing specially to challenge jurisdiction
19
on behalf of Cross-Defendant SAS Miraval Studios
20
21 [X] BY ELECTRONIC SERVICE I transmitted the above listed document(s) to the e-mail
address set forth above on this date via One Legal
22
Executed on May 13, 2024 at Los Angeles, California.
23
[X] (State) I declare under penalty of perjury under the laws of the State of California that the
24 above is true and correct.
25
Lynette W. Suksnguan /s/ Lynette W. Suksnguan
26 Print Name Signature
27
28
22
PROOF OF SERVICE

Attorneys For Defendant and Cross-Complainant Tenute Del Mondo, B.V

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1 KEITH R.

HUMMEL (admitted pro hac vice)

14 SUPERIOR COURT OF THE STATE OF CALIFORNIA

TENUTE DEL MONDO’S CROSS-COMPLAINT

TENUTE DEL MONDO’S CROSS-COMPLAINT

5 company; and ROES 1-10 as follows:

6 NATURE OF THE ACTION

10 2. Chateau Miraval is a world-famous producer of wine, particularly an award

24 beverage company, Stoli Group.

8 owners of Chateau Miraval.

19 shareholder loans to Tenute.

22 payments as a result of Cross-Defendants’ conduct. Tenute files this Cross-Complaint to seek

24 and Mondo Bongo diverted, treble damages, and punitive damages.

25 THE PARTIES AND OTHER RELEVANT ENTITIES

26 6. Defendant and Cross-Complainant Tenute is a Dutch private limited company that

27 has its registered office at Hoogoorddreef 15, 1001BA Amsterdam, Netherlands.

28 7. Plaintiff and Cross-Defendant William B. Pitt is an individual residing in Los

2 8. Plaintiff and Cross-Defendant Mondo Bongo, LLC is a limited liability company

6 9. SA Chateau Miraval (“Chateau Miraval”) is a French company that owns a 1300-

8 Domaine de Miraval, France.

9 10. Defendant and Cross-Complainant Nouvel, LLC (“Nouvel”) is a limited liability

14 loans to Quimicum and its 50% ownership interest in Quimicum.

20 JURISDICTION AND VENUE

23 alleged herein in California.

27 because it committed the acts alleged herein in California.

4 Mondo Bongo reside in the County of Los Angeles, California.

9 company, which she wholly owned at the time, is named Nouvel.

16 Pitt, as directors and officers of Chateau Miraval.

18 Chateau Miraval and Moves To Financially Harm Jolie.

22 2016, Jolie filed for divorce.

23 A. Pitt Blocks Jolie and Nouvel from Participation in Chateau Miraval

10 reimbursing existing shareholder loans.

21 Miraval to distribute its profits to its shareholders or repay its loans.

2 B. Pitt Strips Chateau Miraval of Its Assets.

7 the Cross-Defendants pursued, and continue to pursue, are the following:

8 i. Diversion of Corporate Profits to Pitt Vanity Projects

13 benefitted him personally.

18 Provence has paid about €45 million in dividends to Chateau Miraval.

6 many renovations after they had been started or completed.

12 a stop to Chateau Miraval’s spending on Pitt’s personal expenses.

16 the loans Tenute holds.

17 ii. Pitt Schemes To Divert Chateau Miraval’s Resources To His Projects

21 sharing any returns with Nouvel and Tenute.

24 on which he is apparently collaborating with French producer Damien Quintard.

24 vineyard, and saw its potential beyond wine-making”.

2 Provence rosé brand Miraval.”

7 the loans she had made to Nouvel.

8 IV. Pitt Attempts To Drive Tenute Out

23 A. Pitt and Mondo Bongo Refuse To Resolve the Deadlock at Quimicum.

28 general meetings of the Quimicum shareholders in an effort to resolve the deadlock.

7 “neutral person”—serve as Quimicum’s sole director. Nouvel, reasonably, rejected this

15 V. Pitt and Mondo Bongo’s Illegal Conduct Has Harmed Tenute

4 FIRST CLAIM FOR RELIEF

5 Violation of Penal Code § 496

6 (Cross-Complainant Tenute Against Cross-Defendants William B. Pitt and Mondo Bongo,

8 56. Cross-Complainant Tenute realleges and incorporates by reference each of

9 Paragraphs 1 through 55 as though fully set forth herein.

13 to its co-owner’s detriment.

16 Miraval’s assets to fund and develop their own side businesses.

20 of ownership between Tenute and Chateau Miraval—Nouvel and Quimicum—are investment

22 from Chateau Miraval would ultimately flow to Tenute.

2 successor-in-interest to Jolie, Tenute is entitled to repayment of the loans, which matured on

3 December 31, 2023.