KEITH R.

HUMMEL (admitted pro hac vice)

1 khummel@cravath.com
JUSTIN C. CLARKE (admitted pro hac vice)
2 jcclarke@cravath.com

3 JONATHAN MOONEY (admitted pro hac vice)

jmooney@cravath.com
4 CRAVATH, SWAINE & MOORE LLP
375 Ninth Avenue
5 New York, New York 10001
Telephone: (212) 474-1000
6 Facsimile: (212) 474-3700

7
JOE H. TUFFAHA (Bar No. 253723)
8 joe.tuffaha@ltlattorneys.com
PRASHANTH CHENNAKESAVAN (Bar No. 284022)
9 prashanth.chennakesavan@ltlattorneys.com
LTL ATTORNEYS LLP
10
300 South Grand Avenue, Suite 3950
11 Los Angeles, CA 90071-3426
Telephone: (213) 612-8900
12 Facsimile: (213) 612-3773

13 Counsel for Defendant and

Cross-Complainant Nouvel, LLC
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, NOUVEL, LLC’S NOTICE OF
18
MOTION AND MOTION TO
Plaintiffs, COMPEL NON-PARTY CAMPARI
19
AMERICA LLC’S COMPLIANCE
vs.
20 WITH SUBPOENA TO PRODUCE
ANGELINA JOLIE, an individual, and PERSON(S) MOST
21 NOUVEL, LLC, a California limited KNOWLEDGEABLE AND PRODUCE
liability company, YURI SHEFLER, an DOCUMENTS; AND REQUEST FOR
22 individual, ALEXEY OLIYNIK, an
MONETARY SANCTIONS
individual, and TENUTE DEL MONDO
23 B.V., a Netherlands private limited
Filed concurrently with Declaration of Joe
company,
24 Tuffaha; Separate Statement; Request for
Defendants. Judicial Notice; and Proposed Order
25
NOUVEL, LLC, a California limited Judge: Hon. Lia Martin
26 liability company, Dept.: 3
Cross-Complainant, Date: April 2, 2025
27
vs. Time: 9:00 a.m.
28 Reservation No.: 527603391894

1
NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 WILLIAM B. PITT, an individual, Action Filed: February 17, 2022
1 MONDO BONGO, LLC, a California Trial Date: None set.
limited liability company, MARC-
2 OLIVIER PERRIN, an individual, SAS
MIRAVAL PROVENCE, a French limited
3 liability company, SAS FAMILLES
PERRIN, a French limited liability
4 company, ROLAND VENTURINI, an
individual, GARY BRADBURY, an
5 individual, WARREN GRANT, an
individual, SAS PETRICHOR, a French
6 limited liability company; VINS ET
DOMAINES PERRIN SC, a French
7 company; SAS MIRAVAL STUDIOS, a
French limited liability company; SASU
8 LE DOMAINE, a French limited liability
company; SAS DISTILLERIES DE LA
9 RIVIERA, a French limited liability
company, and ROES 1-10.
10 Cross-Defendants.
11 TENUTE DEL MONDO, B.V., a
Netherlands private limited company
12
Cross-Complainant,
13 vs.

14 WILLIAM B. PITT, an individual,

MONDO BONGO, LLC, a California
15 limited liability company, and ROES 1-10.
Cross-Defendants.
16

17

18

19

20

21

22

23

24

25

26

27

28
2
NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
1 PLEASE TAKE NOTICE that on April 2, 2025, at 9:00 a.m., or as soon thereafter as the
2 matter may be heard, in Department 3 of the above-captioned Court, located at 111 North Hill

3 Street, Los Angeles, CA 90012, Defendant and Cross-Complainant Nouvel, LLC (“Nouvel”) will

4 and hereby does move the court for an order compelling non-party Campari America LLC

5 (“Campari”) to produce its person(s) most knowledgeable and produce documents pursuant to

6 Code of Civil Procedure (“CCP”) § 1987.1, CCP § 2020.030, and CCP § 2025.480 (“Motion”).

7 PLEASE ALSO TAKE NOTICE that at the date and time set for the hearing on said
8 Motion, Nouvel shall and hereby does move, pursuant to CCP § 1987.2, CCP § 2030.030, and

9 CCP § 2025.480, for an award of monetary sanctions against Campari in a sum to be determined

10 on the grounds that Campari has failed to comply with the deposition subpoena and any opposition

11 to such motion would lack in substantial justification pursuant to CCP §§ 2023.030(a) and

12 2025.480(j).

13 The Motion and request for sanctions are based on this Notice, attached Memorandum of
14 Points and Authorities, Declaration of Joe Tuffaha, Request for Judicial Notice, concurrently filed

15 Separate Statement as required under C.R.C. Rule 3.1345, all records and papers on file, matters

16 of which the Court may take judicial notice, and such other evidence or argument of counsel, as

17 the Court may permit.

18

19

20

21

22

23

24

25

26

27

28

3
NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 Dated: July 29, 2024
1 Respectfully submitted,
2 By: /s/ Joe H. Tuffaha
3 LTL ATTORNEYS LLP
Joe H. Tuffaha (Bar No. 253723)
4 joe.tuffaha@ltlattorneys.com
Prashanth Chennakesavan (Bar No. 284022)
5 prashanth.chennakesavan@ltlattorneys.com
300 South Grand Avenue, Suite 3950
6 Los Angeles, CA 90071
Telephone: (213) 612-8900
7 Facsimile: (213) 612-3773
8 CRAVATH, SWAINE & MOORE LLP
Keith R. Hummel (admitted pro hac vice)
9 Justin C. Clarke (admitted pro hac vice)
Jonathan Mooney (admitted pro hac vice)
10 375 Ninth Avenue
New York, NY 10001
11 Telephone: (212) 474-1000
Facsimile: (212) 474-3700
12

13 Attorneys for Defendant and Cross-

Complaint Nouvel, LLC
14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

4
NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 TABLE OF CONTENTS
1 MEMORANDUM OF POINTS AND AUTHORITIES ................................................................... 8

2 I. PRELIMINARY STATEMENT ........................................................................................... 8

3 II. FACTUAL BACKGROUND ................................................................................................ 8
4 III. LEGAL STANDARD ......................................................................................................... 11
5 IV. ARGUMENT ....................................................................................................................... 11
6 A. Nouvel’s Subpoena Seeks Relevant Information that is Proportional to the
Needs of the Case. ................................................................................................... 11
7
1. Documents Concerning Contracts and Agreements with Campari
8 (RFP Nos. 1, 3, 5 and 7). ............................................................................. 13
9 2. Documents Concerning Campari’s Involvement in Efforts by Pitt to
Harm Nouvel, Tenute and/or Stoli (RFP Nos. 6 and 8)............................... 15
10
3. Documents Related to or Concerning the Litigation (RFP Nos. 9–
11 11). ............................................................................................................... 16
12 4. Campari’s Specific Objections Should be Disregarded Because the
RFPs are Relevant and Narrowly Tailored. ................................................. 17
13
5. Campari’s General Objections are Without Merit. ...................................... 17
14
B. Nouvel Properly Served Campari. ........................................................................... 19
15
1. Campari is Subject to California Discovery. ............................................... 19
16
2. Campari is Required to Identify a California PMK. .................................... 21
17
V. MONETARY SANCTIONS ............................................................................................... 22
18
VI. CONCLUSION.................................................................................................................... 23
19

20

21

22

23

24

25

26

27

28

5
NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 TABLE OF AUTHORITIES
1
Cases
2
Garcia v. Bellflower Unified School Dist. Governing Bd.,
3 220 Cal. App. 4th 1058 (2013) .................................................................................................... 18

4 Gonzalez v. Superior Court,

33 Cal. App. 4th 1539 (1995) ...................................................................................................... 11
5
In re Morelli,
6 11 Cal. App. 3d 819 (1970) ......................................................................................................... 19

7 Kirkland v. Super. Ct.,

95 Cal. App. 4th 92 (2002) ......................................................................................................... 11
8
Moore v. Mercer,
9 4 Cal. App. 5th 424 (2016) .......................................................................................................... 17

10 Pac. Gas & Elec. Co. v. State Bd. Of Equalization,

134 Cal. App. 2d 149 (1955) ...................................................................................................... 19
11
Toyota Motor Corp. v. Super. Ct.,
12 197 Cal. App. 4th 1107 (2011) .............................................................................................. 19, 20

13 Twin Lock, Inc. v. Superior Ct. In & For Los Angeles Cnty.,
52 Cal.2d 754 (1959) ................................................................................................................... 19
14
Yelp, Inc. v. Hadeed Carpet Cleaning, Inc.,
15 289 Va. 426 (2015) ..................................................................................................................... 20

16 Statutes

17 Code of Civil Procedure § 1985(a) ............................................................................................ 18, 21

18 Code of Civil Procedure § 1987.1 ................................................................................... 3, 11, 20, 22

19 Code of Civil Procedure § 1987.1(a)-(c) ......................................................................................... 11

20 Code of Civil Procedure § 1989 ................................................................................................ 19, 20

21 Code of Civil Procedure § 2017.010 ............................................................................................... 11

22 Code of Civil Procedure § 2020.030 ......................................................................... 3, 11, 18, 20, 22

23 Code of Civil Procedure § 2020.030(a) ............................................................................................. 3

24 Code of Civil Procedure § 2020.310(e) ..................................................................................... 21, 22

25 Code of Civil Procedure § 2020.510 ................................................................................... 20, 21, 22

26 Code of Civil Procedure § 2020.510(a)(1) ...................................................................................... 22

27 Code of Civil Procedure § 2023.010(d) ........................................................................................... 22

28 Code of Civil Procedure § 2023.010(h) ........................................................................................... 22

6
NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 Code of Civil Procedure § 2025.230. .................................................................................. 19, 20, 21
1 Code of Civil Procedure § 2025.260 ............................................................................................... 20

2 Code of Civil Procedure § 2025.480(a) ........................................................................... 3, 11, 20, 22

3 Code of Civil Procedure § 2025.480(j)........................................................................................ 3, 22

4 Code of Civil Procedure § 2025.480 (k) .................................................................................... 20, 22

5 Code of Civil Procedure § 2031.310(b)(1) ...................................................................................... 11

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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NOUVEL’S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 MEMORANDUM OF POINTS AND AUTHORITIES

2 I. PRELIMINARY STATEMENT

3 Nouvel, LLC (“Nouvel”) properly served a deposition subpoena on nonparty Campari

4 America LLC (“Campari”) requiring it to designate a witness qualified to testify regarding

5 specified topics and to produce documents. The scope of the subpoena is narrow, seeking

6 information regarding a distribution agreement executed in or around September 2023 between

7 Campari and Chateau Miraval. Campari has refused to designate a witness to appear for the

8 scheduled deposition and has refused to produce documents. Instead, Campari has erroneously

9 challenged service of the subpoena.

10 Campari’s challenge fails because Campari has not claimed that it has no California

11 representative who (1) can appear at a deposition or (2) has control over the responsive

12 documents, and has failed to follow the statutory procedure of designating a person most

13 knowledgeable. Additionally, Campari has represented as recently as March of 2024 in court

14 filings that it is a resident of California (contrary to its assertions otherwise here). Campari’s

15 additional objections to the document requests and deposition topics are also without merit.

16 Accordingly, Nouvel respectfully requests an order compelling Campari to comply with Nouvel’s

17 subpoena and awarding monetary sanctions in an amount to be determined.

18 II. FACTUAL BACKGROUND

19 In 2008, Nouvel, a California LLC then owned by Angelina Jolie, and Mongo Bongo, a

20 California LLC owned by Brad Pitt, jointly purchased Chateau Miraval, an estate and vineyard in

21 the south of France, through the holding company Quimicum. (Nouvel’s First Amended Cross

22 Complaint (“FACC”) ¶¶ 69–70.) In 2013, Chateau Miraval partnered with Cross-Defendant

23 Familles Perrin to establish a 50-50 winemaking joint venture—Cross-Defendant Miraval

24 Provence—which is run by Cross-Defendant Marc Perrin. (Id. ¶ 74.) In the next decade, Miraval

25 Provence became highly profitable, generating tens of millions of euros per year in profits.

26 (Id. ¶ 79.)

27 After Jolie filed for divorce from Pitt in 2016, Pitt and Mondo Bongo began a retaliatory

28 campaign to exclude Nouvel from participating in the jointly-owned business. (FACC ¶ 93.) As

8
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 part of this campaign, Pitt has caused Chateau Miraval to enter into disadvantageous business

2 deals that financially benefit him and his friends (id. ¶ 14), while keeping Nouvel and Jolie in the

3 dark about Chateau Miraval’s finances and operations (id. ¶¶ 3, 93, 143, 151.) To date, Pitt has

4 squandered Chateau Miraval’s profits on wasteful vanity projects (id. ¶ 115 (“€1,106,658 on a

5 swimming pool, and €2,963,207 on ‘garment works’ . . . €1 million per year for years on end

6 reconstructing stone walls using stone masons from Croatia”)); allowed Miraval Provence to

7 violate a written contract by registering Chateau Miraval’s extremely valuable intellectual

8 property in the name of Miraval Provence (id. ¶¶ 119, 126); diverted Chateau Miraval’s resources

9 to his own side businesses that exploit Miraval’s name, image and premises (id. ¶ 130–44); and

10 given away the controlling share of Miraval Provence to Familles Perrin (id. ¶¶ 150–53) – all for

11 below-market or no compensation to Chateau Miraval. (Id. ¶¶ 126, 152.)

12 On September 24, 2021, Jolie sold Nouvel to Tenute del Mondo, B.V. (“Tenute”), a

13 subsidiary of the Stoli wine and spirits conglomerate. (FACC ¶ 159.) In an effort to peaceably

14 coexist as joint owners, representatives of Tenute spoke with representatives of Mondo Bongo and

15 Marc Perrin to discuss the future of Chateau Miraval. (Id. ¶ 163.) During these meetings, Tenute

16 introduced a detailed plan for Miraval to leverage Stoli’s established distribution network in an

17 effort to diversify and expand Miraval’s presence worldwide. (Id. ¶¶ 160, 164.) Indeed, Tenute

18 purchased Nouvel with the expectation of working with Pitt to harness the Stoli Group’s

19 distribution expertise and expand Miraval’s production and profitability. (Id. ¶ 162.) Initially,

20 Perrin eagerly acceded to this plan. (Id. ¶¶ 163–64.) However, Pitt could not tolerate anyone else

21 exercising control over Chateau Miraval and fiercely opposed any such collaboration. (Id. ¶ 166.)

22 To cement his total control over Miraval, Pitt ordered Perrin to stop speaking to Nouvel, Tenute,

23 and the Stoli Group. (Id.)

24 Pitt’s campaign to exclude Nouvel, Tenute and Stoli from participation in Miraval came to

25 a head when Pitt caused Chateau Miraval to enter into an exclusive ten-year distribution contract

26 with Campari America LLC (“Campari”)—closing the door entirely on Tenute, Stoli and Nouvel’s

27 participation in Miraval. Nouvel alleges that Pitt has deprived Nouvel of information about the

28 Chateau Miraval business to hide his poor financial decisions and obvious acts of self-dealing.

9
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 (FACC ¶ 93.) Chateau Miraval’s contractual ties to Campari, or its affiliates, at the hands of Pitt

2 may be yet another installment in his systematic ploy to cause economic harm to Nouvel. 1

3 To discern facts regarding the distribution agreement, on May 2, 2024, Nouvel served a

4 deposition subpoena on Campari requiring it to designate an individual or individuals most

5 qualified to testify regarding nine topics at a deposition scheduled for June 3, 2024, and to produce

6 documents. (Ex. 1 2). The document requests and deposition topics are narrowly tailored to seek

7 information regarding this agreement and Campari’s possible involvement in Pitt’s scheme to

8 plunder Chateau Miraval’s assets and value.

9 Campari responded to the subpoena by letter dated May 29, 2024. (Ex. 3). The letter

10 challenges service of the subpoena on the grounds that Campari is purportedly not domiciled, and

11 therefore not subject to compulsory process, in California. Campari also asserts that Nouvel’s

12 service on its registered agent in California is insufficient for the same reason. The letter further

13 attaches objections to the substance of the subpoena requests, addressed in the accompanying

14 Separate Statement. Campari did not designate any witnesses and did not appear for the scheduled

15 deposition. By email on May 31, 2024, counsel for Nouvel sought confirmation as to whether

16 Campari would be producing documents pursuant to the subpoena and whether Campari would be

17 appearing for the scheduled deposition. (Ex. 4.) Counsel for Campari responded by email on the

18 same day stating that “Campari intends to stand on its objections and is not appearing” at the

19 scheduled deposition. (Id.) Counsel for Nouvel and for Campari subsequently met-and-conferred

20 by phone on June 6, 2024 and July 9, 2024. (Tuffaha Decl. ¶ 11.) However, Campari has not

21 moved from its position and maintains its refusal to appear for a deposition and produce records.

22

23

24

25 1
Nouvel also suspects that Cross-Defendants and Campari may have conspired with Southern
26 Glazer, the largest U.S. alcohol distributor, to harm Nouvel. That entity is reportedly facing
several government investigations and lawsuits regarding alleged anti-competitive conduct and
27 abuse of its monopoly power, which exposes Chateau Miraval to reputational damage.

28 2
The exhibits are attached to the concurrently filed declaration of Joe Tuffaha.

10
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 III. LEGAL STANDARD

2 California Code of Civil Procedure section 1987.1 states in relevant part: “If a subpoena

3 requires the attendance of a witness or the production of books, documents, electronically stored

4 information, or other things . . . at the taking of a deposition, the court, upon motion reasonably

5 made by any . . . [ party] . . . may make an order directing compliance with it.” Cal. Code Civ.

6 Proc. § 1987.1(a)-(c) (applicable to deposition subpoenas under Cal. Civ. Proc. Code § 2020.030);

7 see Cal. Civ. Proc. Code § 2025.480(a). A motion to compel should be granted where “good

8 cause justif[ies] the discovery sought”. Cal. Code Civ. Proc. § 2031.310(b)(1). Good cause is

9 established through a “fact-specific showing of relevance”. Kirkland v. Super. Ct., 95 Cal. App.

10 4th 92, 98 (2002) (citation omitted). For discovery purposes, information should be regarded as

11 “relevant” to the subject matter if it might reasonably assist a party in evaluating the case,

12 preparing for trial or facilitating settlement. See Gonzalez v. Superior Court, 33 Cal. App. 4th

13 1539, 1546 (1995); see also Cal. Code Civ. Proc. § 2017.010 (“[A]ny party may obtain discovery

14 regarding any matter, not privileged, that is relevant to the subject matter involved in the pending

15 action or to the determination of any motion made in that action, if the matter either is itself

16 admissible in evidence or appears reasonably calculated to lead to the discovery of admissible

17 evidence.”).

18 IV. ARGUMENT

19 A. Nouvel’s Subpoena Seeks Relevant Information that is Proportional to the

Needs of the Case.
20
Nouvel’s requests for production readily meet the good cause standard because each
21
request is narrowly tailored to the discovery sought regarding Campari’s involvement in and
22
knowledge of Pitt’s plan to harm Nouvel and use Chateau Miraval for his personal ventures and
23
benefit. Over the years Chateau Miraval has become a profitable business, yielding renowned rosé
24
wines and bolstering the value of its trademarked name as Miraval wines gained success. (FACC
25
¶ 113.) However, Nouvel has yet to see the fruits of its investment. (Id. ¶ 114.) The dividends
26
that should have been paid to Quimicum were improperly redirected into Pitt’s vanity projects and
27
businesses in which Mondo Bongo holds an ownership interest (but in which Nouvel holds little or
28

11
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 no interest) (id. ¶ 115–16); Chateau Miraval’s valuable intellectual property assets were

2 misappropriated (id. ¶ 119); and Pitt gave away the controlling share of Miraval Provence to

3 Familles Perrin (id. ¶¶ 148–150, 152). Pitt has systematically entered into ventures and deals that

4 seek to harm Nouvel and divert Chateau Miraval’s resources to prevent Nouvel from receiving the

5 benefits and profits it is rightfully entitled to.

6 After months of promising discussions between Perrin and Stoli concerning the growth of

7 the Miraval brand and establishment of a successful distribution network, the discussions abruptly

8 ceased. (FACC ¶¶ 163–66.) Shortly thereafter, Pitt caused Chateau Miraval to enter into a 10-

9 year exclusive distribution agreement with Campari. Nouvel does not know what the terms of this

10 agreement are—whether they are favorable to Chateau Miraval (and subsequently to Nouvel as a

11 50% owner), provide for payments or kickbacks that will benefit Pitt or Mondo Bongo or contain

12 an endorsement component from which solely Pitt will profit—and whether this agreement is yet

13 another installment of Pitt devaluing Chateau Miraval’s worth as part of his rancorous crusade

14 against Nouvel. Nouvel has no knowledge of the contract’s provisions, or negotiations leading up

15 to its completion, nor does it understand how, in the midst of the dispute between Plaintiffs and

16 Nouvel, Campari secured the right to be the sole distributor of one of the most successful rosés on

17 the market.

18 Nouvel’s RFPs are narrowly tailored in scope to obtain exactly this information. Nouvel’s

19 RFPs seek documents concerning the contracts and agreements between Campari and Chateau

20 Miraval, documents concerning Campari’s involvement in efforts by Pitt to harm Nouvel, Tenute,

21 and Stoli and documents in Campari’s control concerning this litigation. The RFPs are not unduly

22 burdensome and are directly proportional to the needs of the case because they seek information

23 about Miraval—the subject matter around which the entire litigation is centered. The Court

24 should order Campari to produce documents responsive to Nouvel’s RFP Nos. 1, 3, and 5–11, as

25 well as deposition topics numbers 1–9.

26

27

28

12
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 1. Documents Concerning Contracts and Agreements with Campari

2 (RFP Nos. 1, 3, 5 and 7).

3 Nouvel RFP Nos. 1, 3, 5 and 7 seek all documents and communications concerning the

4 contracts and agreements between Campari and Chateau Miraval, Miraval Provence, Mr. Pitt,

5 Mondo Bongo, Mr. Perrin and/or Familles Perrin, and, specifically, the exclusive distribution

6 agreement executed in or around September 2023 between Campari and Chateau Miraval:

7 • RFP No. 1: All Documents, things or other Communications concerning

or regarding the exclusive distribution agreement executed in or around
8 September 2023 between You, Campari Group, or any of Your or its
parents, subsidiaries, or affiliates, on the one hand, and Chateau Miraval,
9 Miraval Provence, or any of their parents, subsidiaries, or affiliates, on the
other hand, concerning the distribution of Miraval wines in the United
10 States and French markets.

11 • RFP No. 3: All Communications between You and Chateau Miraval,

Miraval Provence, Mr. Pitt, Mondo Bongo, Mr. Perrin, Familles Perrin,
12 Mr. Venturini, Mr. Bradbury, or Mr. Grant.

13 • RFP No. 5: All of Your, Campari Group’s, or any of Your of its parents’,
subsidiaries’, or affiliates’ agreements, including contracts, term sheets,
14 letters of intent, or memoranda of understanding, with Chateau Miraval,
Miraval Provence, Mr. Pitt, Mondo Bongo, Mr. Perrin and/or Familles
15 Perrin.

16 • RFP No. 7: All Documents and Communications concerning financial

terms, including financial statements, distributions, and revenue, between
You and Chateau Miraval, Miraval Provence, or any of their parents,
17 subsidiaries, or affiliates.
18 These requests are narrowly tailored to seek information relevant as to whether this is yet
19 another instance of Pitt causing Chateau Miraval to enter into an unfavorable agreement that

20 harms Nouvel—one of the key allegations in Nouvel’s FACC.

21 Pitt and his co-conspirators have consistently entered into ventures for their own gain at
22 the expense of Nouvel, ranging from Miraval Studios to a cosmetics line to other alcohol brands,

23 whereby Chateau Miraval’s name, image and assets are used to benefit Pitt’s self-serving

24 enterprises from which Nouvel sees no profit. (FACC ¶¶ 130–144.) Understanding the

25 framework under which Pitt bound Chateau Miraval’s most successful and profitable product to a

26 long-term, exclusive agreement with Campari is relevant to whether Pitt has agreed to yet another

27 venture on unfavorable terms to harm Nouvel. (See id.) These requests are narrowly tailored to

28 the “financial terms including financial statements, distributions, and revenue” and “contracts,

13
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 term sheets, letters of intent, or memoranda” with Campari, and especially the “exclusive

2 distribution agreement executed in or around September 2023”—the scope and terms of Campari’s

3 relationship and contractual (and financial) tethers to Chateau Miraval are directly related to the

4 allegations made in Nouvel’s FACC concerning the Cross-Defendants scheme to exploit Chateau

5 Miraval’s assets to their own benefit and Nouvel’s detriment.

6 Information regarding this distribution agreement is especially critical given that Perrin

7 and Nouvel’s parent, Tenute, were actively planning a joint effort to grow and develop the Miraval

8 brand, including by utilizing Stoli’s strong distribution network and global presence. (FACC

9 ¶¶ 163–65.) However, these conversations abruptly ceased at the hands of Pitt’s commitment to

10 stonewalling Tenute and Stoli, and Perrin’s fear of losing unchecked use of Chateau Miraval’s

11 name, brand and value. (Id. ¶¶ 148–49.) These requests are relevant to ascertaining Pitt’s

12 reasoning for entering into a long-term exclusive distribution contract and whether Campari was

13 aware of Pitt’s malicious intent to harm Nouvel and thwart any cooperation with Tenute and Stoli

14 through the exclusive distribution agreement.

15 The requests concerning these communications also seek information from a specific set of

16 individuals and entities. RFP No. 3 seeks “[a]ll Communications between You and Chateau

17 Miraval, Miraval Provence, Mr. Pitt, Mondo Bongo, Mr. Perrin, Familles Perrin, Mr. Venturini,

18 Mr. Bradbury, or Mr. Grant”. Nouvel is seeking documents concerning the specific individuals it

19 alleges were in charge of or part of the continued stratagem to misappropriate Chateau Miraval’s

20 assets for their personal gain. Miraval Provence is the partnership between Familles Perrin, led by

21 Marc Perrin, and Chateau Miraval to make and market Chateau Miraval’s wine (FACC ¶¶ 11,

22 74)—the subject of the distribution agreement with Campari. Nouvel alleges that Marc Perrin,

23 Familles Perrin and Miraval Provence diverted Chateau Miraval resources to illegitimate projects

24 and misappropriated the value of Chateau Miraval’s intellectually property assets. (FACC ¶¶ 22,

25 119–44.) Communications between these specific Cross-Defendants and Campari is relevant to

26 determine whether this was another instance of Pitt’s self-dealing. Similarly, Nouvel alleges that

27 Mr. Venturini, Mr. Bradbury and Mr. Grant worked with Pitt and Mondo Bongo to similarly divert

28 Chateau Miraval resources to projects that lack any legitimate purposes and benefit entities in

14
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 which Pitt or Mondo Bongo holds an ownership interest, but Nouvel does not. (FACC ¶¶ 21–22,

2 111–19, 126, 129.) The communications that Nouvel seeks are narrowly tailored to the key

3 individuals/entities at issue in this litigation that Nouvel alleges caused harm to it, making this

4 request proportional to the needs of the litigation.

5 2. Documents Concerning Campari’s Involvement in Efforts by Pitt to

6 Harm Nouvel, Tenute and/or Stoli (RFP Nos. 6 and 8).

7 RFP Nos. 6 and 8 concern Campari’s involvement in efforts by Pitt to harm Nouvel,

8 Tenute and/or the Stoli Group:

9 • RFP No. 6: All Documents and Communications regarding the

intellectual property of Chateau Miraval or Miraval Provence.
10
• RFP No. 8: All Documents, things or other Communications concerning
11 or referring to Nouvel, Mr. Venturini, Mr. Bradbury, Mr. Shefler, Ms.
Jolie, Mr. Oliynik, Quimicum, and/or Tenute del Mondo.
12
These RFPs are about Campari’s involvement in another potential avenue by which Pitt
13
sought to harm Nouvel and enrich himself. Shortly after Jolie filed for divorce, Pitt deliberately
14
entered into business deals designed to isolate or harm Nouvel and benefit him and his co-
15
conspirators. (FACC ¶ 14.) For example, Pitt allowed Marc Perrin to register Chateau Miraval’s
16
trademarks in the name of Miraval Provence, which violated a written contract expressly
17
prohibiting such registrations. (Id. ¶¶ 119–20, 126.) Pitt and Perrin concealed their true intentions
18
by telling Nouvel that Miraval Provence registered the trademarks temporarily in anticipation of a
19
potential transaction with luxury goods manufacturer LVMH. (Id. ¶ 127.) The “transaction”
20
never materialized, and now Perrin, Familles Perrin and Miraval Provence claim that they own
21
Chateau Miraval’s trademarks, for which they paid nothing. (Id.) Nouvel seeks to understand
22
whether Pitt allowed Campari to similarly obtain the right to use Chateau Miraval’s valuable
23
intellectual property for no value. As to Campari’s specific objection that RFP No. 6 is vague as
24
to the “scope of ‘the intellectual property of Chateau Miraval or Miraval Provence’”, (Ex. 3 at 10),
25
Nouvel’s FACC makes clear that the intellectual property at issue is Chateau Miraval’s trademarks
26
and lists the specific trademarks which have been misappropriated. (FACC ¶¶ 80, 119–29.) As
27
such, the request is clear on its face.
28

15
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 In another instance, Pitt “was supportive” of Perrin’s suggestion to give Familles Perrin a

2 controlling share in Miraval Provence, the revenue-generating asset of Chateau Miraval, for no

3 compensation. (Tuffaha Decl. ¶ 12; RJN at 4.) Perrin has admitted to causing Familles Perrin to

4 improperly take control of Miraval Provence “to prevent a hostile takeover” accompanied by

5 Nouvel’s change in control. (Tuffaha Decl. ¶ 12; RJN at 4.) Understanding the origin and nature

6 of the business relationship between Chateau Miraval and Campari, and Campari’s knowledge of

7 the dispute between the direct and indirect shareholders of Chateau Miraval, will allow Nouvel to

8 ascertain whether Campari was complicit in Pitt’s stratagem. These requests are sufficiently

9 particularized given that Nouvel cannot ascertain the full extent of Pitt and his coconspirators’

10 misconduct because of their intentional concealment.

11 3. Documents Related to or Concerning the Litigation (RFP Nos. 9–11).

12 RFP No. 9 seeks documents concerning the litigation and RFP Nos. 10 and 11 seek

13 documents concerning specific correspondences between representatives of the Stoli Group or

14 Tenute del Mondo, and representatives of the Campari Group:

15 • RFP No. 9: All Documents, things or other Communications concerning

the Litigation.
16
• RFP No. 10: All Documents and Communications concerning or relating
17 to the October 2022 email correspondence between Fabio Di Fede and the
Stoli® Group.
18
• RFP No. 11: All Documents and Communications concerning or relating
19 to the September 2023 letter (attached as Exhibit 1) sent to Campari
Group.
20
These RFPs are about Campari’s knowledge of, and exploitation of, the dispute between
21
Chateau Miraval’s shareholders, and whether this was a factor in executing the distribution
22
agreement at issue. Documents in Campari’s possession concerning the litigation are plainly
23
relevant because the extent to which Campari was aware of the litigation before and after entering
24
into the distribution and agreement is important to determining Campari’s participation in Pitt’s
25
efforts to harm Nouvel (see section IV.A.2 supra). The correspondence at issue in these requests
26
between Nouvel’s General Manager and Campari Group’s General Counsel would have certainly
27
placed Campari on notice of the active litigation between the shareholders of Chateau Miraval.
28
Furthermore, one of the correspondences at issue references possible criminal acts by Pitt, as well
16
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 as the other acts which are at the center of Nouvel’s civil claims against Pitt (see section II supra).

2 These requests are therefore relevant and particularized because they seek documents tethered to

3 the litigation or related, specific correspondences.

4 4. Campari’s Specific Objections Should be Disregarded Because the

5 RFPs are Relevant and Narrowly Tailored.

6 For the aforementioned reasons, Campari’s objections regarding overbreadth, undue

7 burden, vagueness and ambiguity are without merit. As explained in Section IV.B., Nouvel

8 properly effectuated service on Campari, rendering Campari’s ineffective service objection

9 irrelevant. And the targeted scope of these requests undermines any argument that collecting

10 responsive documents would be burdensome to Campari.

11 5. Campari’s General Objections are Without Merit.

12 The Court should also disregard Campari’s general objections and the boilerplate

13 objections Campari raises in response to all of Nouvel’s requests for production.

14 Confidentiality and privilege. Campari’s general confidentiality, attorney-client privilege,

15 work product doctrine and right to privacy objections, (Ex. 3 at 2), are unpersuasive. The

16 protective order in place in this matter allows for clear procedures by which Campari may

17 properly designate the documents it produces as confidential. (See Protective Order, attached to

18 Ex. 1, at 8 (“Any Information that may be produced by a non-Party witness in discovery in the

19 Proceeding pursuant to subpoena or otherwise may be designated by such non-Party as

20 “Confidential” under the terms of this Stipulation and Protective Order, and any such designation

21 by a non-Party shall have the same force and effect, and create the same duties and obligations, as

22 if made by one of the undersigned Parties hereto”.)) As to attorney client privilege and work

23 product, Campari may produce redacted documents and provide a privilege log, as is customary in

24 commercial litigation.

25 Party production and Nouvel’s possession. Campari’s general objection that “the

26 requested documents, to the extent they exist, should be obtained from the parties in the case”,

27 (Ex. 3 at 3), should be disregarded because Nouvel is entitled to seek production from both

28 Campari and parties to the litigation. See Moore v. Mercer, 4 Cal. App. 5th 424, 447 (2016)

17
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 (“[T]he broad scope of permissible discovery is equally applicable to discovery of information

2 from a nonparty as it is to parties in the pending suit”). Furthermore, the requests that Nouvel has

3 propounded to parties to this litigation differ in time, scope, and custodians from those which

4 Nouvel propounds to Campari. (Tuffaha Decl. ¶ 7.) Similarly, Campari’s general objection that

5 Nouvel’s subpoena is overbroad and unduly burdensome because it “seeks production of

6 documents or information already in Nouvel’s possession” should also be disregarded because

7 Nouvel may seek information and documents from parties or non-parties, even that which Nouvel

8 already has in its possession. Garcia v. Bellflower Unified School Dist. Governing Bd., 220 Cal.

9 App. 4th 1058, 1066 (2013) (finding no abuse of discretion in trial court’s order for defendant to

10 produce records already in plaintiff’s possession).

11 Date range. Campari objects to the timeframe of Nouvel’s subpoena and contends that

12 Nouvel “fails to specify why the time period beginning on January 1, 2019 is relevant to any or all

13 of the requests.” (Ex. 3 at 3.) This objection is unpersuasive. Jolie divorced Pitt in 2016, which

14 marked the beginning of Pitt’s campaign to harm Nouvel. Because of Pitt’s efforts to hide

15 information regarding the business from Nouvel, Nouvel does not know the full extent to which

16 any other entity has been involved in Pitt’s schemes. Accordingly, the time period beginning on

17 January 1, 2019 seeks to capture Campari’s involvement with Pitt’s early efforts to harm Nouvel.

18 Persons or entities not properly attributable to Campari America. Campari generally

19 objects to Nouvel’s requests because they seek “documents from persons or entities whose actions

20 and/or knowledge are not properly attributable to Campari America, in whole or in part, and/or

21 whom Campari America does not control, including but not limited to Campari Group (which

22 does not exist as a legal entity), Davide Campari - Milano N.V., and Campari France”. (Ex. 3

23 (repeated throughout Campari’s responses).) Campari is mistaken. As discussed herein, Nouvel

24 seeks records and deposition testimony. This procedure requires production of records in control

25 of the subpoenaed party, not merely in his or her custody. See Cal. Code Civ. Proc. § 1985(a)

26 (witness subpoenaed to attend hearing must bring “any books, documents, electronically stored

27 information, or other things under the witness’s control”) (emphasis added) (applicable to

28 deposition subpoenas under Cal. Code Civ. Proc. § 2020.030)).

18
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 B. Nouvel Properly Served Campari.

2 Campari challenges service of the subpoena on the ground that Campari is not incorporated

3 or headquartered in California and therefore not subject to process in California. Campari’s

4 objections fail because (1) Campari is subject to California discovery, and (2) Campari is required

5 to identify a California PMK objections are untimely because it failed to designate a person most

6 knowledgeable under California Code of Civil Procedure § 2025.230.

7 1. Campari is Subject to California Discovery.

8 Campari challenges service of the subpoena on the ground Campari is not incorporated or

9 headquartered in California 3 and therefore not subject to process in California. In support of this

10 conclusion, Campari cites CCP § 1989 and two California cases: Twin Lock, Inc. v. Superior Ct. In

11 & For Los Angeles Cnty., 52 Cal.2d 754,761-62 (1959) and Toyota Motor Corp. v. Super. Ct., 197

12 Cal. App. 4th 1107, 1110 (2011).

13 Section 1989 precludes compelling non-resident witnesses to appear in California. It does

14 not—as Campari suggests—serve as blanket immunity from service for corporations registered to

15 do business in the state. In Twin Lock, the defendants gave notice that they would depose certain

16 non-resident officers of plaintiff Twin Lock in California. At issue was whether the applicability

17 of section 1989 was limited to persons summoned by means of a subpoena, or whether it also

18 applied to persons summoned by notice of deposition. The court held that section 1989 applied to,

19 and nullified, the notices to appear.

20 In Toyota, the plaintiffs noticed depositions of five Toyota employees as individuals. All

21 five employees resided in Japan. The trial court issued an order compelling Toyota to produce

22 them for depositions in California, but the Court of Appeal reversed, holding that the residency

23

24 3
Contrary to its assertion that it is not headquartered in California, Campari asserted in a federal
court filing from March 7, 2024, that Campari’s “principal place of business [is] at 1255 Battery
25
Street, Suite 500, San Francisco, California 94111.” (Ex. 1 to RJN (Campari Complaint) at ¶ 3.)
26 Because “[a] corporation’s residence is generally deemed to be where its principal place of
business is”, Campari is a resident of California, and therefore amenable to process there. Pac.
27 Gas & Elec. Co. v. State Bd. Of Equalization, 134 Cal. App. 2d 149, 152–53 (1955); In re Morelli,
11 Cal. App. 3d 819, 831 (1970) (“[R]esidence under Code of Civil Procedure, section 1989
28 clearly is residence in fact and not domicile.”).

19
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 limitation set forth in CCP § 1989 applies to discovery, and that CCP § 2025.260 does not permit

2 depositions of parties or their officers, directors, managing agents, or employees to be taken at a

3 place more distant than that permitted by CCP § 1989. (197 Cal.App.4th at 1109, 1113-14.). The

4 court of appeal expressly stated: “We express no opinion, however, as to whether our analysis or

5 the conclusions we have reached in this opinion would or should extend or apply to a court order

6 made pursuant to section 2025.230 which provides for the circumstance where ‘[ ] the deponent

7 named is not a natural person . . . .’” Toyota, 197 Cal. App. 4th 1125 n. 20.

8 Nouvel has not issued subpoenas to any individual Campari employee. It has issued a

9 subpoena duces tecum pursuant to Code Civ. Proc. § 2020.510 to Campari—the corporate entity.

10 Because Campari is not a natural person, it is required to designate an officer, director, managing

11 agent, employee, or agent to appear at the deposition, produce responsive documents, and sit for a

12 deposition about the documents. The practice is routine in this State. The responding party has a

13 duty to produce the person most knowledgeable (“PMK”) who is currently in its employ. A PMK

14 deponent must comply with document requests. Cf. Cal. Civ. Proc. Code § 1987.1 (applicable to

15 deposition subpoenas under Cal. Civ. Proc. Code § 2020.030); Cal. Civ. Proc. Code §

16 2025.480(a), (k). When a request for documents is made, the witness or someone in authority is

17 expected to make an inquiry of everyone who might be holding responsive documents or everyone

18 who knows where such responsive documents might be held.

19 Notably, Campari has not claimed that it has no California representative who can appear

20 at a deposition. The out-of-state authority on which Campari relies highlights that the analysis

21 focuses on the location of relevant witnesses. In Yelp, Inc. v. Hadeed Carpet Cleaning, Inc., 289

22 Va. 426 (2015), Yelp, a California company, received a third-party subpoena duces tecum in

23 Virginia, where it is registered to do business. Id. at 431. The court concluded that only

24 employees in California had access to the documents. Id. at 431 n. 1; see also id. at 440,

25 concurrence n. 2 (Mims, J., concurring in part and dissenting in part) (noting that majority relies

26 on conclusion that only California employees had access to the documents). Applying Virginia

27 statute, the court concluded that the trial court lacked the authority to compel Yelp to make a non-

28 resident witness appear for deposition and produce documents in California.

20
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 Campari has presented no evidence—such as an employee declaration—that it has no

2 California employees, or that California-based employees do not have access to the documents. It

3 dances around the issue by claiming without supporting evidence that responsive documents are

4 “not located in the state.” (Ex. 3 at 1.) Campari misses the point. Under California law, the issue

5 is not whether documents are “located” in the state. Where a party issues a “records and

6 testimony” subpoena pursuant to Section 2020.510, the responding party has an obligation to

7 produce anything in its control, regardless of whether a California-based representative has

8 custody. (See Code Civ. P. § 1985 (a) [a witness must bring documents “under the witness’s

9 control”] [emphasis added]). 4

10 Campari has designated a registered agent to accept service; has not demonstrated it has no

11 California employees; and has not demonstrated that its California employees do not have access

12 to the responsive documents. As such, it must be compelled to designate a California-based

13 employee or agent to appear at a deposition and produce relevant documents.

14 2. Campari is Required to Identify a California PMK.

15 Nouvel seeks to depose the person(s) most knowledgeable (“PMK”) at Campari regarding

16 Nouvel’s Categories of Examination for Deposition, which sought to depose the PMK(s) as to (1)

17 the distribution agreement at issue (Topics 2–3), (2) Campari’s involvement in Pitt’s scheme to

18 harm Nouvel (Topic 1, 5), and (3) Campari’s communications related to or concerning this

19 litigation (Topics 6–9). California law plainly requires that Campari designate a PMK before

20 lodging an objection. See Cal. Code Civ. Proc. § 2020.310(e) (“If the deponent is an organization,

21 the subpoena shall describe with reasonable particularity the matters on which examination is

22 requested. The subpoena shall also advise the organization of its duty to make the designation of

23 employees or agents who will attend the deposition, as described in Section 2025.230.”); Cal.

24 Code Civ. Proc. § 2025.230 (“[T]he deponent shall designate and produce at the deposition those

25 of its officers, directors, managing agents, employees, or agents who are most qualified to testify

26
4
27 In contrast, a subpoena for records alone under Section 2020.410 is directed at a “custodian.”
Thus, where only records are subpoenaed, a responding corporation would only have an obligation
28 to produce documents within the custody of its California employees.

21
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 on its behalf as to those matters to the extent of any information known or reasonably available to

2 the deponent.”); see also Cal. Code Civ. Proc. § 2020.510(a)(1) (providing that the requirements

3 of CCP § 2020.310 are applicable to records and testimony subpoenas). Campari has a statutory

4 duty to designate the PMK(s) for each of the topics Nouvel lists in its Subpoena for Testimony and

5 Production of Documents. (Ex. 3 (Attachment 4 of Subpoena).) A PMK deponent must also

6 comply with document requests. Cal. Civ. Proc. Code § 1987.1 (applicable to deposition

7 subpoenas under Cal. Civ. Proc. Code § 2020.030); Cal. Civ. Proc. Code § 2025.480(a), (k).

8 Campari has done neither. Campari’s objections based on service grounds are thus premature.

9 V. MONETARY SANCTIONS

10 Campari’s failure to provide PMK deponents and to produce documents responsive to

11 Nouvel’s RFPs amounts to misuse of the discovery process. Cal. Code Civ. P. § 2023.030(a).

12 Misuses of the discovery process include, but are not limited to, the following: 1) failing to

13 respond or to submit to an authorized method of discovery; and 2) making or opposing,

14 unsuccessfully and without substantial justification, a motion or to limit discovery. See Cal. Code

15 Civ. Proc. § 2023.010(d) and (h).

16 California Code of Civil Procedure § 2025.480(j) further provides:

17 The court shall impose a monetary sanction … against any party, person, or attorney
who unsuccessfully makes or opposes a motion to compel an answer or production,
18 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.
19

20 In this case, Campari failed to comply with Nouvel’s subpoena to provide a PMK

21 regarding certain categories and produce documents. Despite meet-and-confer efforts, Campari

22 has maintained its refusal to comply with the subpoena on the basis of its erroneous challenge to

23 service (see Tuffaha Decl. ¶¶ 10-11), Campari has provided neither any dates for deposition nor

24 produced any documents. Therefore, Campari has engaged in misuse of the discovery process and

25 monetary sanctions are appropriate. As such, Nouvel requests monetary sanctions against

26 Campari in an amount to be determined.

27

28

22
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 1 VI. CONCLUSION

2 Based on the foregoing, Nouvel respectfully requests that the Court order Campari to

3 comply with Nouvel’s subpoena by designating and producing a witness or witnesses most

4 qualified to testify regarding the nine specified deposition categories. In addition, Nouvel requests

5 that the Court order Campari to produce all documents responsive to the subpoena’s Requests for

6 Production Nos. 1, 3, and 5-11. Finally, Nouvel requests that the Court sanction Campari in an

7 amount to be determined for forcing Nouvel to file this motion.

8
Dated: July 29, 2024
9
Respectfully submitted,
10
By: /s/ Joe H. Tuffaha
11
CRAVATH, SWAINE & MOORE LLP
12 KEITH R. HUMMEL (admitted pro hac vice)
13 (N.Y. Bar No. 2430668)
JUSTIN C. CLARKE (admitted pro hac
14 vice) (N.Y. Bar No. 5076096)
JONATHAN MOONEY (admitted pro hac vice)
15 (N.Y. Bar No. 5648191)
Worldwide Plaza
16 375 Ninth Avenue
17 New York, NY 10001
Telephone: (212) 474-1000
18 Facsimile: (212) 474-3700

19 LTL ATTORNEYS LLP

JOE TUFFAHA
20
(Bar No. 253723)
21 joe.tuffaha@ltlattorneys.com
PRASHANTH CHENNAKESAVAN
22 (Bar No. 284022)
prashanth.chennakesavan@ltlattorneys.com
23 300 South Grand Avenue, Suite 3950
Los Angeles, CA 90071
24
Telephone: (213) 612-8900
25 Facsimile: (213) 612-3773

26 Counsel for Defendant and

Cross-Complainant Nouvel, LLC
27

28

23
NOUVEL'S MOTION TO COMPEL DISCOVERY RESPONSES FROM NON-PARTY CAMPARI AMERICA
 Journal Technologies Court Portal

Court Reservation Receipt

Reservation
Reservation ID: Status:
527603391894 RESERVED

Reservation Type:
Motion to Compel Discovery (not Further Discovery) - 1 Number of Motions:
moving party, 1 motion 1
Case Number: Case Title:
22STCV06081 WILLIAM B. PITT, et al. vs ANGELINA JOLIE, et al.
Filing Party: Location:
Nouvel, LLC (Defendant) Stanley Mosk Courthouse - Department 3

Date/Time: Confirmation Code:

April 2nd 2025, 9:00AM CR-HHOTX9NCYAME7QUVF

Fees
Description Fee Qty Amount

Motion to Compel Discovery (not Further Discovery) - 1 moving party, 1 0.00 1 0.00
motion

TOTAL $0.00

Payment
Amount: Type:
$0.00 NOFEE

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