Angelina Jolie Says She Hasn't Returned to Winery Since 'Painful Events' That Led to Brad Pitt Divorce https://t.co/8KojRgbxZo
— People (@people) October 9, 2025
Angelina Jolie calls Brad Pitt NDA demand 'extremely painful,' seeks $33K in legal fees https://t.co/eYtyUnGVQT
— USA TODAY (@USATODAY) October 10, 2025
"We are gratified that the court ruled in Angelina’s favor. After Mr. Pitt fought for years to hide this crucial evidence, he must now produce documents and communications concerning abuse, lies to authorities, and years of cover up. His actions harmed Angelina and their children and are central to this case," Murphy said in a statement to JustJared.com.
He continued, "But I want to again emphasize that Angelina never wanted any of this. She never pressed charges, she left all their properties, and she is the one who tried to sell him the business in the first place. To this day, Mr. Pitt has never been held accountable for his actions and has at all times controlled Miraval and the winery, yet he still demands more."
"She wants this to end, the children want this to end, and Mr. Pitt should focus on healing their family, not pursuing lawsuits. If he does not, Angelina will defend herself in court by presenting the evidence necessary to demonstrate that Pitt’s allegations are demonstrably false," the statement concluded.
In a decision made Monday, Nov. 25, a judge ruled that Pitt, 60, must disclose documents that Paul Murphy, a lawyer for Jolie, 49, says will prove "communications concerning abuse, lies to authorities, and years of cover up" on Pitt's part.
These include emails, texts and other written communications, but nothing between him and his attorneys or therapists.
Pitt's legal team previously sought for her motion to be denied, calling the actress' requests "wide-ranging and intrusive," as well as a "sensationalist fishing expedition."
Murphy claims the documentation they're seeking to bring to light is "crucial evidence" that Pitt has "fought for years to hide." He adds in a statement Nov. 26, "His actions harmed Angelina and their children and are central to this case."
"But I want to again emphasize that Angelina never wanted any of this," continued Murphy. "She never pressed charges, she left all their properties, and she is the one who tried to sell him the business in the first place. To this day, Mr. Pitt has never been held accountable for his actions and has at all times controlled Miraval and the winery, yet he still demands more. She wants this to end, the children want this to end, and Mr. Pitt should focus on healing their family, not pursuing lawsuits."
"If he does not," the lawyer added, "Angelina will defend herself in court by presenting the evidence necessary to demonstrate that Pitt’s allegations are demonstrably false."
Reps for Pitt did not respond to PEOPLE's request for comment.
Judge Lia Martin said she was ‘inclined to’ grant Pitt’s motion.
Judge Martin said the NDAs might help her determine what is or isn't a reasonable non-disclosure request.
‘I don’t see this as a character question,’ Judge Martin said to attorneys on both sides in a Downtown Los Angeles court on Thursday.
‘There maybe agreements that [Jolie] entered into with people that may have terms similar or not. The court is not making any findings today about admissibility of the documents.’
The judge said she could render her final order as soon as Thursday afternoon.
Jolie’s attorneys disagreed with the judge’s tentative ruling and said Pitt’s demands for the NDA’s is being weaponized against the actress.
Paul Murphy, one of Jolie’s attorneys, said Pitt is seeking access to the NDAs as a tactic to hide ‘years of abuse’ the actor inflicted against his client and their six children.
‘He wanted to cover up his conduct because he could not stomach what he is covering up,’ Murphy said in court on Thursday. ‘Mr. Pitt’s abuse, his cover-up and actions gaslighting his children - that is what changed.’
Murphy asked the judge to consider several factors if she approves Pitt’s request, including to limit the release of NDAs signed by Jolie from 2014 to 2021, and not agreements related to her companies.
Murphy also argued Jolie should not be forced to turn over drafts of the NDAs because it would be 'a bridge way too far' and would keep the case from 'blowing up' into 'different sideshows.'
Pitt’s attorney, John Berlinski, said they should be allowed to view Jolie’s NDAs related to all of her businesses since actors often use their company names when signing agreements.
Berlinski also argued the NDAs would be relevant to the Miraval case since Jolie allegedly made others, including her staff, sign ‘gag orders’ to prevent them from talking about what they witnessed while they were employed at her home, including her treatment of Pitt and their children.
‘She was the one who weaponized the NDA and threatened to sue security guards simply if they testified,’ Berlinski said during Thursday’s hearing. ‘That’s significant.’
The Cross-Complaint, relying in part on a lengthy and detailed FBI report, describes some of the egregious facts Pitt was hoping to bury.
Through it all, Jolie never pressed charges as she believed the best course was for Pitt to accept responsibility and help the family recover from the post-traumatic stress he caused. Sadly, that did not happen. Instead, Pitt denied his abuse to authorities, while simultaneously allowing unnamed “close” sources to publicly deny that abuse for him, all while privately denying the children appropriate trauma-related care.
“Mr. Pitt’s continued attempt to equate common NDAs for security personnel and housekeepers covering confidential information employees learn at work, with him demanding an expanded NDA to ensure the continued coverup of his deplorable actions remains shameful. This case is not about NDAs in general, but about power and control. All Angelina has ever wanted was separation and health, with positive relationships between all members of their family, including Mr. Pitt. She looks forward to the day when he is finally able to let her go.”
A source close to the case adds that the former bodyguard Tony Webb who made the declaration was present on the tarmac when Pitt allegedly attacked Jolie and the children in the 2016 incident on a private plane which ended the marriage.
The source said: 'Webb is on Pitt's payroll and worked for the same security team whose other members stood on the Tarmac in LA and turned a blind eye to Pitt's actions that day.
'Webb's declaration also conveniently leaves out the fact that the second security guard mentioned in the declaration, though called to testify by Pitt, testified in favor of Angelina, not against her.'
In legal papers seen by Daily Mail.com, Jolie objects to and moves to strike the declaration of their former bodyguard, filed by Pitt on Wednesday.
The filing notes: 'Pitt clearly is trying to gain an unfair advantage by offering this contested evidence for the first time on reply when Jolie has no opportunity to respond.
The law is crystal clear that this form of evidence sandbagging grossly violates due process of law and should be struck. 'The general rule of motion practice is that new evidence is not permitted with reply papers.'
It adds: 'The Webb declaration has no relevance to this case or to the issue presented by Pitt's motion. In fact, the Webb declaration, which does not mention the word 'Miraval' a single time, serves to demonstrate exactly why other NDAs involving other parties and other circumstances are irrelevant and will—as Jolie predicted in her opposition brief— cause a mini-trial on each and every NDA Pitt claims is relevant to this case.
'The Webb declaration illustrates the point: Pitt is now claiming that conversations with two 'contractors' (security guards) about testimony in a different case are somehow relevant here. Jolie contests the testimony's relevance, its credibility (Webb works for Pitt), and its accuracy.
'To resolve this, the Court would have to have a mini-trial on this issue alone, yet none of it explains whether Pitt's demand for an expanded NDA from Jolie as a condition of purchasing her interest in Miraval was the reason the deal they had struck fell apart.
'If this evidence truly was relevant and material to Pitt's motion, he would have— indeed, was required to—offer it in his moving papers.
'That he did not do so tells the Court all it needs to know about the strength of Pitt's motion and, frankly, his true purpose in filing the Webb declaration—to create a press event and again put external pressure on Jolie. The declaration is irrelevant and violates Jolie's due process rights. The Court should strike the declaration. '
3. My work with Ms. Jolie began as individual assignments, typically on movie sets. In or around 2012, however, my work for her increased and I began running security for her and the family whenever they left the United States. My working relationship with Ms. Jolie also evolved in other ways. Initially, I took instruction either directly from her or from her then- personal assistant, a woman named Holly. Later, in the mid-to-late 2000s, I was introduced to a man named Michael Vieira who assumed a similar role for Ms. Jolie, and Mr. Vieira began providing me and my team with instruction and direction on behalf of Ms. Jolie. This sometimes included Mr. Viera telling me to present people with non-disclosure agreements on behalf of Ms. Jolie and obtain their signatures. For example, Mr. Viera often asked me to provide hotel staff with non-disclosure agreements and to get signatures from them.
6. Shortly before two SRS Global contractors testified in a court case that I understood was related to Ms. Jolie and Mr. Pitt’s divorce and the custody of their children, Mr. Vieira called me on my cell phone. At the time I received the phone call, I was in my home office located in Hereford, UK. During the call, Mr. Viera told me that he had heard that two contractors who had provided personal security for Ms. Jolie through SRS Global might be testifying in the family court case. Mr. Vieira then asked me to stop these two individuals from testifying. I understood that Mr. Viera was making this request on behalf of Ms. Jolie. I explained to Mr. Vieira that I had no power to stop them because they were independent contractors and not employees of SRS Global. Mr. Vieira then told me that his call should serve as a reminder that those individuals had entered into non-disclosure agreements with Ms. Jolie and that I should remind them of that and tell them that if they testified in the family law case, Ms. Jolie would sue them. I communicated this message to the two individuals over the phone and they both told me that they planned to testify. One of the two individuals, Ross Foster, specified that he intended to testify regardless of the NDA, if he received a court subpoena. When Mr. Foster told me this, he also told me that if asked, he would testify about statements he overheard that Ms. Jolie made to the children, encouraging them to avoid spending time with Mr. Pitt during custody visits.
7. I received a second phone call from Mr. Vieira shortly after the first, asking me whether Mr. Foster and the other individual about whom we had previously spoken were, in fact, going to testify. I told him that I believed that they were. Mr. Vieira once again asked me to remind them that they had signed non-disclosure agreements, and that if they testified, Ms. Jolie would sue them. Mr. Vieira also stated that Ms. Jolie may need to subpoena me to testify, though I never actually received a subpoena.
8. I understand that Mr. Foster and the other individual mentioned above were, in fact, subpoenaed, and that both did, in fact, testify in the Jolie/Pitt family law case.
CAREER HISTORY
Apr 97 – To Date Company Director
Since 1997 I have worked for my own companies with various business partners. My clients include many high profile VIP’s as well as company executives and their families. The work has been in various different theatres of operations in many different areas of the world.
Jan 95 – Apr 97 Security Consultant
From January 1995 I worked as a Security Consultant employed by many different companies, V.I.P’s and their families advising them on their security arrangements and providing Personal Protection when required.
Angelina Jolie and Brad Pitt bodyguards clash with paparazzi
The security chief for the Hollywood stars said the photographers had invaded the grounds of their French estate but the paparazzi claimed they were attacked in a neighbouring public forest.
Both sides have confirmed there was angry fistfight as the snappers tried snatch a picture that could sabotage the exclusive deal following the birth of Knox Leon and Vivienne Marcheline. Police were called after the altercation.
Tony Webb, who heads security at the 1,235-acre Chateau Miraval estate, said: "We caught the two and tried to escort them off the property, and the guy's just gone berserk, thrashing out, kicking and actually biting one of the security people, breaking his finger, drawing blood and screaming that he had Hepatitis C."
"In or around 2012, however, my work for her increased and I began running security for her and the family whenever they left the United StatesOmitting and misrepresenting material facts calls into question the veracity of the rest of his declaration.
03/12/2021 Notice ((UNDER SEAL) of intent to offer video recording of the deposition of Ross Foster at Trial pursuant to CCP 2025.620 and 2025.340 (M) )The claim that Angelina wanted to stop Ross Foster from testifying is verifiably false.
Filed by Petitioner
Nov. 28 5:43 PMMichael O. is Angelina's assistant, Rich and Darren are Brad's. They were all on Brad's Witness List, and there is no claim that Angelina did not want any of them to testify. They would know much more than security who only sees them during their trips abroad.
Between now and the start of the holidays/school break, Brad is requesting 30 to 60 minutes sessions to be scheduled as follows: 1 session with the twins, 1 sessions with the middle kids, 1 session with all 4, one session with the older boys and if they are not going to participate, another session with the 4 younger kids.
Darren, Michael O. or Richie can be present. The sessions will be at a home that is approximately 10 minutes from your clients residence.
There will be a request for a step-up in connection with the holidays/school break.
Please let me know good time for us to talk tomorrow.
WHEREAS Petitioner and Respondent understand and acknowledge that Knox will remain in Los Angeles while Vivienne is in New York and Respondent's visitation with Knox will continue pursuant to the status quo.
F, While Vivienne is in New York, Knox shall remain in Los Angeles and Respondent's visitation with Knox shall continue pursuant to the status quo.
Respondent shall have custody of the Minor Child(ren) he designates for four hours each day from June 8, 2018 through June 17, 2018. Respondent, in his sole discretion in advance, shall designate one Minor Child or two Minor Children to be with Respondent for the four hour period of time each day. During this ten day period, Respondent shall spend time with each child at least twice-The scheduled visits were very tightly controlled and monitored. There was no wiggle room for any deviation such as Angelina's alleged suggestion. In fact, the May 30 Order contained a strong incentive for Angelina to encourage the children to open up to Brad.
Dr. Trop shall be present with the Minor Child(ren) during Respondent's time, as arranged by Respondent and at Respondent's cost. Respondent shall also have the discretion to have a recreational facilitator present. Petitioner shall not be present during or interfere with Respondent's custodial time, Respondent shall make arrangements to have Dr. Trop available to meet with the Minor Child(ren) and/or Petitioner before and after visits.
The Court hereby provides notice to Petitioner that if the Minor Children remain closed down to their father and depending on the circumstances surrounding this condition, it may result in a reduction of the time that they spend with Petitioner and may result in the Court ordering primary physical custody to Respondent.
Petitioner shall forthwith arrange for a telephone call among Petitioner, the Minor Children, Maddox, Dr. Jeffrey Trop and Dr. Oren Boxer which shall take place on or before May 31, 2018 to explain the summer schedule to the Minor Children as set forth herein and to confirm the parties' mutual desire and support for the Court's Orders as set forth herein. Respondent shall make arrangements for Dr Trop to arrive in London on June 6 or 7, 2018. Petitioner shall make arrangements for Dr. Trop to meet with the Petitioner, the Minor Children and Maddox on June 7, 2018 in person to explain the summer schedule as set forth herein and to confirm the parties’ mutual desire and support for the Court's Orders as set forth herein. In both the telephonic and the in person meetings, Petitioner shall tell the Minor Children and Maddox:
a. The Court has detemined that not having a relationship with their father is hamful to them;
b, The Court has detennined that it is critical that each of them have a healthy and and strong relationship with their father and mother;
c. The Court has determined that each of them are safe with their father
"The position taken could even be seen as coming close to an ttempt to influence the course of future events relating to those or other proceedings, by suggesting that any public knowledge of information regarding the family situation would be a reason for abrogating the agreement."An NDA in other words. And again bearing in mind that the script for this was written before the start of 2021.
On Jun 16, 2021, at 8:40 AM, Tony Webb wrote:
Re: Termination
Hi Angie,
I decided to write to you directly as I didn't think it would be right just to accept the brief termination letter from Terry and walk away after 20 years with you and your family. I know it has been a very difficult time with everything that's been going on, and sadly we seem to have become very distant over the past couple of years. The lack of travel because of the virus not helping!
I know you blame me for a lot of things Ross has subsequently done, but he didn't work full time for me, he is a self employed security consultant and so is free to work for whoever. This is the same as for the rest of the guys. I can't control what they do or say, when not directly employed by my company.
In regards to the guys, I'm glad you have decided to continue with Matt Fletcher's services, as he is one of the best security consultants I have had the pleasure to employ and work with over the years.
Please take care and love always,
Tony x
From: AJ
Sent: Friday, June 25, 2021 6:30 PM
To: Tony Webb
Subject: Re: Termination
Thank you for your note.
Take good care
As ever
Angie
Sent from my iPhone
On June l9, 2020, Respondent served his Request for Evidentiary Hearing and Witness List Pursuant to Family Code Section 217 and California Rule of Court 5.1 l3. The parties agreed through counsel to serve Amended and Updated Witness Lists on August l7, 2020. Respondent submits this Amended Witness List setting forth the witnesses he may call at the hearing in this proceeding scheduled to commence October 5, 2020. Pursuant to agreement of counsel contact information is not included in this Amended Witness list. Witness contact information shall be sent to opposing counsel by email upon request. Time estimates shall be provided afier discovery is completed.
l. Respondent, William Bradley Pitt.
2. Petitioner, Angelina Jolie Pitt. Petitioner will be called on 776 and cross-examined.
3. Stan Katz Ph.D. Dr. Katz is expected to testify regarding his recommendations and his interactions and communications with the parties, the children, other professionals and third parties regarding the parties and the childrén and consistent with his deposition taken March 3, August 10 and September 8, 2020.
4. Oren Boxer, M.D. Dr. Boxer is expected to testify regarding his intefactions and communications with the parties, the children, Dr. Katz and third parties regarding the parties and the children.
5. Alan Yellin, Ph.D. Dr. Yellin is expected to testify regarding his interactions and communications with the parties, the children, Dr. Katz, other professionals and third parties regarding the parties and the children.
6. Melissa Brymer, Ph.D. Dr. Bryrner is expected to testify regarding her interactions and communications with the parties, the children, Dr. Katz, other professionals and third parties regarding the panics and the children.
7. Alyce LaViolette. Ms. LaViolette is expected to testify regarding her interactions and communications with the parties, the children, Dr. Katz, other professionals and third parties regarding the parties and the children.
8. Fred Luskin, PhD. Dr. Luskin is expected to testify regarding his interactions and communications with the parties, the children, Dr. Katz, other professionals and third parties regarding the parties and the children.
9. Bren Chasse. Ms. Chassc is expected to testify regarding her interactions and communications with the parties, the children, Dr. Katz, other professionals and third parties regarding the parties and the children.
10. Robin Deutsche, PhD. Dr. Deutsche will be called to testify as set forth on Respondent's Expert Witness Designation dated August l4, 2020.
ll. Daneen Scott. Ms. Scott is expected to testify regarding her interactions and communications with and observations of Petitioner, Respondent and/or the children.
12. Jillian Armenante. Ms. Armenante is expected to testify regarding her interactions and communications with and observations of Petitioner, Respondent and/or the children.
13. Ross Foster. Mr. Foster is expected to testify regarding his interactions and communications with and observations of Petitioner, Respondent and/or the children.
l4. Garreth Netherword. Mr. Netherword is expected to testify regarding his interactions and communications with and observations of Petitioner, Respondent and/or the children.
lS. William Thiel. Mr. Thiel is expected to testify regarding his interactions and communications with and observations of Petitioner, Respondent and/or the children.
16. Adam Dowell. Mr. Dowell is expected to testify regarding his interactions and communications with and observations of Petitioner, Respondent and/or the children.
l7. Rich Malchat. Mr. Malchat is expected to testify regarding his interactions and communications with and observations of Petitioner, ReSpondent and/or the children.
l8. Darren Laos. Mr. Laos is expected to testify regarding his interactions and communications with and observations of Petitioner, Respondent and/or the children.
19. Michael Oftedahl. Mr. Oftedahl is expected to testify regarding his interactions and communications with and observations of Petitioner, Respondent and/or the children.
20. Adama Kebe. Ms. Kebe is expected to testify regarding her interactions and communications with and observations of Petitioner, Respondent and/or the children.
21. Binta Bah. Ms. Baht is expected to testify regarding her interactions and communications with and observations of Petitioner, Respondent and/or the children.
DATED: August 17, 2020
Pursuant to Family Code section 2 I 7 and California Rules of Court, Rule 5.] l3, Petitioner, Angelina Jolie, hereby submits the following Witness List in connection with Respondent’s Request for Order for Modification of Child Custody.
l. Petitioner, Angelina Jolie.
2. Respondent, William Bradley Pitt.
3. Oren Boxer, PhD. is expected to testify about his work with the children and with Dr. Katz over the course of his work with this family.
4. Bren Chasse, LMFT is expected to testify about her work with the children, including their current psychological functioning and what interventions are necessary to address their respective needs.
5. Alyce LaViolette, MS, MFT is expected to testify about her individual work with the Respondent as well as the children and interactions with Dr. Katz over the course of her work with this family.
6. Stan Katz, Ph.D. is expected to testify about his work with this family as both an evaluator and a Parenting Coordinator, the recommendations stemming therefrom and the basis for his recommendations.
7. Frederic Luskin, PhD. is expected to testify about his individual work with the Petitioner and Respondent as well as the children and interactions with Dr. Katz over the course ofhis work with this family.
Dated: August l7, 2020
attn .: Franck le Mentec
Luxembourg, 6 April 2021 Furthermore, she feels unable to be part of a business centred around wine, given the part that alcohol played in harm to their family. She continues therefore to believe that the sale is in the best interests of all concerned, including the future of the Miraval business.
My client stays committed to the exit deal and has done all things possible to see the agreement come through. She was therefore upset and hurt to learn that on my telephone calls with you and Christophe Salin on 18 and 26 March 2021 (and the period in between, with calls nearly each other day}, you conveyed the wish of Mr Pitt and the Perrin family to step back from the agreement until an undefined future point.
Most disturbing of all was the reasoning given, and the reference made to recent reports that during sealed legal proceedings currently taking place in California, my client had submitted offers of proof relating to domestic violence.
Setting aside the fact that the legal proceedings in question were not initiated by my client; it would be entirely inappropriate for this to have any bearing on the sale of my client's stake in Miraval. The position taken could even be seen as coming close to an attempt to influence the course of future events relating to those or other proceedings, by suggesting that any public knowledge of information regarding the family situation would be a reason for abrogating the agreement. As you will be aware, financial autonomy is an extremely sensitive issue in cases of this nature. This suggestion has therefore caused my client acute distress and concern.
Furthermore, information regarding a serious family situation that led to the filing for divorce is not new to the parties concerned. The only new development is the presentation of evidence to a private court. My client has not spoken publicly about the events that led to the ending of her marriage in four and a half years, and has no intention of speaking. The position taken is therefore insensitive at the very least. It is extremely distressing to my client that the primary if not the sole concern that has been expressed is not the health and well-being of family members, but how this situation might affect a business. We were therefore expecting to receive your firm confirmation that you intend to proceed with the sale in April as agreed. Instead, on 3 April 2021 I received a phone from Frank Le Mentec setting out, on behalf of both Mr Pitt and Marc Perrin, a wish to renegotiate the terms of the agreement in a way that would defer payment of a substantial portion of the funds due to my client and further extend completion of the agreement.
We are waiting to receive your proposal in writing as requested. In the meantime, you will understand why this new proposal, unless clarified, could compound the impression of a wish to put undue and inappropriate pressure on my client.
We look forward to your urgent and prompt written response clarifying your position. We note however that any delay or suspension of completing the deal or any attempt to change the terms thereof at this stage would, to the least, constitute 'culpa in contrahendo' if not actually a breach for non-performance of a legally valid and binding agreement.
2. In the Stipulation and Order executed by the Court February 28, 2017 the parties stipulated that with with respect to their oldest child, Maddox Jolie-Pitt DOB 8/5/2001 because of his age and maturity, his preference shall be primary in determining his custody arrangements with Respondent.
3, Petitioner shall forthwith arrange for a telephone call among Petitioner, the Minor children, Children, Maddox, Dr. Jeffrey Trop and Dr. Oren Boxer which shall take place on or before May 31, 2018 to explain the summer schedule to the Minor Children as set forth herein and to confirm the parties' mutual desire and support for the Court's Orders as set forth herein. Respondent shall amake arrangements for Dr Trop to arrive in London on June 6 or 7, 2018. Petitioner shall make arrangements for Dr. Trop to meet with the Petitioner, the Minor Children and Maddox on June 7, 2018 in person to explain the summer schedule as set forth herein and to confirm the parties’ mutual desire and support for the Court's Orders as set forth herein. In both the telephonic and the in person meetings, Petitioner shall tell the Minor Children and Maddox:
a. The Court has detemined that not having a relationship with their father is hamful to them;
b, The Court has detennined that it is critical that each of them have a healthy and and strong relationship with their father and mother;
c. The Court has determined that each of them are safe with their father
Respondent shall have custody of the Minor Children fot a four consecutive 4 day period of time between July 8, 2018 and July 14, 2018 as follows. Either: Respondent shall designate the four day period of time. Respondent shall designate in his sole discretion one, two or three of the Minor Child(ren) to be with Respondent from 10:00 a.m. day one through 6:00 p.m. day two, Petitioner shall make arrangements and be responsible for the drop off of the designated Minor Child(ren) at Cosworth Park Hotel at 10:00 a.m. day one. Respondent shall return the Minor or cause the Minor Child(ren) to be returned 10 to Windlesham by 6:00 p.m. on day two, Respondent shall designate in his sole discretion one, two or three of the Minor Child(ren) to be with Respondent from 10;00 a.m. day three through 6:00 p.m. day four. Petitioner shall make arrangements and be responsible for the drop off of the designated Minor Child(ren) at Coworth Park Hotel at 10:00 a.m. day three. Respondent shall return the Minor Child(ren) or cause the Minor Child(ren) to be retumed to Windlesham by 6:00 p.m. on day four, Respondent shall have Dr. Boxer or Dr, Trop present, and may have a recreational facilitator present
In the alternative, at Respondent's option, Respondent may make arrangements to have the Minor Children participate in a four day program between July 8 and July 14, 2018 designed by Dr. Rebecca Bailey of Transitioning Families and the members of her support staff, to work with Respondent and the children, and shall pay the cost of same, Respondent shall provide notice to Petitioner that he is doing so and of the four day period, and Petitioner, shall make arrangements and be responsible for the drop off of the children at Coworth Park Hotel on the day and at the time designated by Respondent. Petitioner shall not be present during four day program unless requested by Dr. Bailey.
d. Respondent shall have custody of the Minor Children in California from July 21, 2018 to July 29, 2018, Petitioner shall be responsible for ensuring that the children return to Los Angeles on July 21, 2018, Respondent Shall be responsible for causing the children to return to Petitioner in London on July 29, 2018. Respondent shall designate and pay the cost of the children's transportation between London and Los Angeles, including the cost for assistants and security for the children, whether they travel commercially or privately. During this period, Respondent shall have the discretion to determine whether the children spend the night at Respondent's residence, the former family home ( "Briarcliff'), ot at Petitioner's residence ("DeMille") and may take them to Santa Barbara. If any of the children stay overnight at DeMille, Respondent shall arrange for appropriate child care and security, at Respondent's cost, and Respondent shall make arrangements to have the child or children return to Briarcliff in the moming. Respondent shall have either Daren Laos or Michael Ofstedahl present, and shall have the discretion to have a recreational facilitator present. Respondent shall make anangements to have Dr. Boxer and/or Dr. Trop spend some time with the Minor Children during this time period.
The Court hereby provides notice to Petitioner that if the Minor Children remain closed down to their father and depending on the circumstances surrounding this condition, it may result in a reduction of the time that they spend with Petitioner and may result in the Court ordering primary physical custody to Respondent.
Laura Wasser's Dec. 1, 2016 email to Lance Spiegel
I understand that Brad is frustrated but feel that it is incumbent upon us to help this family achieve their long-term reunification goals in a smooth and expeditious manner.
Is it not the end goal that within the next 6-12 months Brad is enjoying frequent and continuous contact with all of the children on a joint custodial basis?
Their statement announcing that they had hired Judge Ouderkirk in January 2017
"The parents are committed to act as a united front to effectuate recovery and reunification."
GQI was really on my back and chained to a system when Child Services was called. And you know, after that, we've been able to work together to sort this out. We're both doing our best. ., ... And fortunately my partner in this agrees. It's just very, very jarring for the kids, to suddenly have their family ripped apart.
In this hearing that was closed to the public, Jolie sought to introduce evidence of Pitt’s history of physical abuse of the family and control abuse of Jolie, as well as evidence of Pitt’s conduct toward the children.The above claim from Paul Murphy is also false. The Offer of Proof is mischaracterized and is not what Murphy makes it out to be. Everything having to do with abuse and trauma was on record even before the petition was filed.
Decaration of Laura Wasser Dec 6, 20164. It is my further understanding that since the Sept. 14, 2016 incident, the minor children have lived exclusively with Petitioner. Respondent has had weekly therapeutic visits with the minor children since Oct. 8, 2016. The frequency and duration of these visits have been determined by the minor children's therapists, who were put in place jointly by the parties immediately after the Sept. 14, 2016 incident. The therapists have been present during each of the Respondent's visits.
Oren Boxer MD, Ph.D., a highly regarded clinical neuropsychologist, "expected to testify about his work with the children and Dr. Katz over the course of his work with this family."
Bren Chasse LFMT, specializes in trauma, EMDR (Eye Movement Desensitization and Reprocessing, a psychotherapy treatment that was originally designed to alleviate the distress associated with traumatic memories) "Ms. Chasse is expected to testify about her work with the children, including their current psychological functioning and what interventions are necessary to address their respective needs."
Alyce LaViolette MS, MFT, therapy for Victims of Trauma with a Focus on Domestic Violence and Anger Management. "Ms. LaViolette is expected to testify about her individual work with Respondent as well as the children and interactions with Dr. Katz over the course of her work with this family."
Frederic Luskin, Ph.D. Director of the Stanford University Forgiveness Projects and has completed extensive research on the training and measurement of forgiveness therapy. "Dr. Luskin is expected to testify about his individual work with the Petitioner and Respondent as well as the children and interactions with Dr. Katz over the course of his work with this family."
The Cross-Complaint, relying in part on a lengthy and detailed FBI report, describes some of the egregious facts Pitt was hoping to bury. Jolie has not wished to publicly detail Pitt’s history of abuse, and even for this opposition, she respectfully directs the Court to her previously filed allegations detailing the first time Pitt physically abused the children, which prompted her to leave him. (See Cross-Complaint, ¶¶ 17-22.) The Cross-Complaint describes a father’s terrifying actions against his family—including children as young as eight years old—on a chartered flight where the family literally had no place to run and no place to hide. The conduct caused significant and ongoing post-traumatic stress.
When the flight landed, unbeknownst to Jolie, a still-unknown flight-crew member reported Pitt’s violence to the authorities.
Since Jolie filed for divorce in September 2016, she has focused squarely on helping their family heal. As part of that focus, she steadfastly chose not to publicly disclose the details of Pitt’s history of abuse and efforts to control her out of a wish to protect their family’s privacy, and to respect Pitt as father of their children.Clearly and unambiguously: She devoted years to bringing their family back together by helping to restore Brad's relationship with the children as their Dad, they are the Jolie-Pitt family, and she wanted to protect Brad.
GMAStronger together.
"We are focusing on the health of our family, and so we will be. We will be stronger when we come out of this because that's what we're determined to do as a family."
The FBI found probable cause to charge Pitt with a federal crime. (Id. at ¶ 22.) Although the U.S. Attorney’s Office ultimately declined to press charges, the FBI’s later internal review concluded that the investigation and charging decision repeatedly violated Jolie’s and their children’s victims’ rights.What is in their sights.
51. And Jolie agreed with Pitt’s suggestion to partner with the Perrin family and their plans for the business: “So exciting. Well handled my love,” she told Pitt. “Thank you.”
52. On March 21, 2013, Château Miraval S.A. entered into a 50-50 joint venture with Familles Perrin to develop a global wine business that would be associated with the Miraval estate.
137. From the moment Stoli purported to acquire Nouvel, Shefler and Oliynik have drummed up allegations that Pitt improperly authorized Château Miraval S.A. to transfer trademarks to Miraval Provence (the wine business that Château Miraval S.A. co-owns with Familles Perrin) for the sole purpose of diluting Nouvel’s indirect interest in the marks.
70. Their commitment to this strategy took on even more significance over the years, as rosé wine increased in popularity and Provence-based wines, like Miraval, became the acquisition targets of large spirits conglomerates.
138. These marks had always been subject to a long-term license, consistent with Pitt and Perrin’s winemaking partnership underlying the joint venture. In any event, as Jolie, Shefler, Tenute del Mondo, and Oliynik all know, Miraval Provence had begun registering marks in 2017, in connection with a third party’s interest in investing in the business. The third party was attracted to the “family involvement” in Miraval Provence and would have maintained the management and operational role of the Perrin family, as well as endorsement agreements with Pitt and Jolie.
69. Interviewed about the venture, Péters explained that Pitt was “involved 200% with everything.” Though Pitt “trust[ed] [Perrin and Péters] to make the wine,” he still “want[ed] to know, to understand the process.” And Pitt was “involved with everything else, the label, the packaging, the marketing.” Pitt also appeared in Miraval advertisements, agreeing as part of the joint venture with Perrin that Miraval could use Pitt’s own name and image to advance the Miraval brand, without seeking his market-rate endorsement fees.This contradicts the 3ACs' claims elsewhere that Perrin asked them to cap their endorsement fees -- only Brad appeared in a Miraval ad and it was largely a gift. Angelina has never appeared in a Miraval ad. The claimed endorsement agreements with both of them only came up as part of the sale to LVMH. They both agreed to continue to be publicly associated with Miraval until at least the announcement of the sale in 2021. And Brad evidently for a time after, similar to his deal with Mediawan for Plan B.
Nouvel 1ACC, July 2023Jolie’s and Pitt’s endorsement is what made the Miraval brand successful — more successful than Familles Perrin’s competing rosés.
139. While the potential deal fell through, Miraval Provence remained committed to expanding its business. Perrin, as president of Miraval Provence, thus developed a “revised strategy” for Miraval Provence to grow its product lines and increase its revenue. Pursuant to this revised strategy, Miraval Provence (and Perrin) would invest more to grow the brands of the existing and new product lines and would continue registering certain trademarks, including new marks for Miraval Provence’s new product lines. Perrin also asked Pitt and Jolie to cap their endorsement fees as established in the joint venture agreements in recognition of the investments made by the Perrin family in connection with this new strategy.
140. Jolie was aware of Perrin’s revised strategy, which was discussed by the various parties. In early 2018, Jolie, through her advisor Bird, was informed of these developments and asked whether she wanted Perrin to move these trademarks back to Château Miraval S.A. Neither Jolie nor Bird gave any indication that she did. And several days later, when Château Miraval S.A.’s CEO sent Jolie an update about the Miraval Provence business, including a reminder about the “registration of the [t]rademarks with [Miraval Provence],” Jolie told the CEO that she “need[ed] to spend time to review” his update, but was “very grateful to see and understand what the plans are and hope[d] to be helpful in moving forward.” Jolie never voiced any concern that Miraval Provence was registering the marks, and she agreed to cap her endorsement fee pursuant to Perrin’s revised strategy.
142. The negotiating history further confirms that Stoli knew Château Miraval S.A. did not have unencumbered control of the marks developed by and used for the joint venture. For example, in May 2021, Stoli executive Chris Caldwell wrote to Oliynik and others that he “understand[s] that Miraval trademarks are also owned at the SNC Miraval Provence level.”
Nouvel 1ACC
They told Nouvel that Miraval Provence had undertaken certain limited trademark registrations on a temporary basis because of a potential transaction with luxury goods manufacturer LVMH. In 2018, counsel for Quimicum and Chateau Miraval confirmed that Perrin and Miraval Provence had registered the trademarks exclusively for the purpose of pursuing a potential joint venture with LVMH. Counsel informed Nouvel that Chateau Miraval could seek the return of the trademarks at any time. Nouvel was never informed that these registrations were intended to be permanent, and never consented to Miraval Provence indefinitely, let alone permanently, owning the trademarks. As it turns out, the purported transaction with LVMH never materialized. But Miraval Provence did not return the trademarks to Chateau Miraval. Nouvel learned for the first time at the end of 2021 that Perrin, Familles Perrin, and Miraval Provence now claim that they own Chateau Miraval’s valuable trademarks and refuse to cancel the registrations even though the supposed reason for their temporary transfer never came to pass. As of today, Miraval Provence has not canceled any of these registrations, it maintains its ownership, and it continues to register more and more of Chateau Miraval’s trademarks. And again, Miraval Provence paid nothing for these trademarks it now claims to own.
Perrin benefits from this scheme in more ways than one. Beyond his unauthorized appropriation of 50% of the value of Chateau Miraval’s trademarks and his use of Chateau Miraval’s assets to subsidize other businesses in which he owns an equity interest, he has been charging Miraval Provence exorbitant rates for the bottling services provided by Familles Perrin. Under the contract that established Miraval Provence, Chateau Miraval is responsible for cultivating its vineyard, harvesting its grapes, and producing wine up through the vinification stage. Familles Perrin is responsible for bottling and selling the wine produced by Chateau Miraval. But Perrin has been charging Miraval Provence supra-market rates for bottling at Familles Perrin, often at rates over three times the industry standard. Whether Pitt is complicit in or ignorant of Perrin’s price-gouging is unknown to Nouvel, which is kept in the dark by Pitt.
67. In 2019, Miraval launched a new brand—Studio by Miraval—at a lower price point, which achieved millions in sales in its first year on the shelves and has enjoyed tremendous sales and volume growth in the years since.
68. In January 2020, Miraval began partnering with Rodolphe Péters, a revered champagne grower. Pitt’s idea, years in the making, was to establish the first champagne house devoted exclusively to rosé champagne. In October 2020, a sub-joint venture established under Miraval Provence released Fleur de Miraval, the first edition of the partnership’s rosé champagne.
132. In October 2021, within weeks of announcing that it had been acquired by Stoli, Nouvel (at the Stoli Parties’ direction) sought a corporate restructuring that would transfer Château Miraval S.A.’s interest in Miraval Provence, the joint venture that owns the wine business, out of Château Miraval S.A.—disempowering its existing directors and officers. Nouvel also attempted to transfer Miraval-related intellectual property to Cyprus, where SPI Group Limited is incorporated, as part of an unsound and legally questionable tax dodge.
Nouvel's 1ACC July 2023
On May 15, 2023, Chateau Miraval published its 2021 accounts, showing for the first time that Chateau Miraval now owns only 4,997 of Miraval Provence’s 10,000 shares, or a 49.97% ownership interest
Nouvel was never consulted about a potential transfer of any of Chateau Miraval’s interest in Miraval Provence or any increase in Miraval Provence’s share capital. Indeed, it appears that Nouvel was intentionally kept in the dark. Until reviewing the 2021 accounts, Nouvel understood that Chateau Miraval remained a 50% owner of Miraval Provence. Despite Nouvel’s demand for and explanation, Pitt and Mondo Bongo had remained silent.
Perrin, seeking to capitalize on Jolie’s and Pitt’s fame, has steadily been trying to increase his position in the business above what he is legally owed, including by improperly registering Chateau Miraval’s trademarks, and now apparently convincing Pitt to give him control of Miraval Provence.
But as part of their broader conspiracy to loot Chateau Miraval, Pitt now appears to have handed over control of Miraval Provence to Perrin altogether.
Miraval Provence’s 2022 financial accounts show that Miraval Provence has loaned 1,377,464 euros to SAS Fleur de Miraval. Fleur de Miraval is advertised as a collaboration between the Pitt, (Rodolphe) Peters (through SAS Champagne Pierre Peters) and Perrin families. Miraval Provence’s capital is therefore being used to support a partly owned subsidiary in a way that disproportionally benefits a 20% shareholder that has no connection to Nouvel.
AJ Motion to Compel April 2024
Ultimately, on September 8, 2021, Pitt stipulated to lifting the ATROs, but not before he started the process of secretly and illegally transferring shares in Miraval Provence (the subsidiary that owned the winery) from Chateau Miraval to the Perrin Family. The obvious purpose of the secret transfer was to try to wrest Jolie’s co-ownership and control of Miraval Provence from her, and give full control to Pitt’s good friend, Marc Perrin. Even though Pitt had a fiduciary duty to disclose in advance to Chateau Miraval’s owners the contemplated transfer of the shares, he never did. In discovery, Pitt does not dispute he made the transfer and that, not coincidently, the transfer secretly gave the Perrins control. Pitt’s transfer was grossly illegal. Unaware of Pitt’s unlawful dealings with the Perrin family, on October 4, 2021, Jolie sold Nouvel to Tenute del Mondo, a subsidiary of Stoli Group
149. In mid-December 2021, Shefler contacted Pitt directly, likewise feigning his “discover[y]” of the trademark registrations. “It is now apparent,” Shefler wrote, that “[Perrin] owns 50% of the brand equity . . . , leaving you and me with 25% share each.” Moreover, Shefler warned that in private discussions between Shefler and Perrin, Perrin had “suggested” cutting Pitt out of the wine business and “leaving [Pitt] behind.” When Pitt did not respond, Shefler raised the heat, making threats to Pitt, including that he would “bring to surface a fact that a woman with 6 kids [i.e., Jolie] has been deprived of 50% of her assets without her knowledge.”
52. The joint venture—named Miraval Provence—was initially set up as an SNC (société en nom collectif) and was changed to an SAS (société par actions simplifiée) in August 2021.
148. For example, shortly after entering the ownership structure of Miraval unannounced, Stoli suggested that Pitt could cede some of his stake in the wine business to Stoli in exchange for control of his home.
"Mr. Pitt's lawsuit against Ms. Jolie is an extension of a false narrative, and the truth of the situation has still not been made public," an insider now tells PEOPLE.
61. From March to May 2017, Pitt and Jolie, along with their respective business managers, Warren Grant and Terry Bird, worked out an $8 million loan from Pitt to Jolie for the purchase of Jolie’s new California home. In tandem, they discussed how to allot Pitt’s and Jolie’s respective ownership interests in Miraval in the event that Pitt bought out Jolie or of a joint sale. Throughout the discussions, Jolie and Bird promised Pitt that Jolie “[saw] Miraval as a center point for them and their grandchildren,” and that any sale would account for Pitt’s disproportionate investment.
62. In March and April 2017, Pitt and Jolie discussed exactly what the split would be the event of a joint sale, with Jolie at one point informing Pitt that she was amenable to a 68-32 split (reflecting Pitt’s and Jolie’s actual levels of investments). Jolie assured him, “I will only take what I put in” and “I don’t take anything you put in in the future.” “Again,” she reiterated, “I can’t imagine the day this is a reality. It’s a gift to our children in the end. It’s not even ours really. It’s an investment and business they will inherit.” In May 2017, Pitt agreed to provide Jolie with the $8 million loan for her new home in California.
63. Over the next few months, Pitt and Jolie continued to discuss how they would split the proceeds in the event of a joint sale of Miraval. Throughout the course of these negotiations, Jolie never questioned Pitt’s right to a large majority of the proceeds from any sale or suggested that she could or would sell her interest separately without Pitt’s and Mondo Bongo’s consent. To the contrary, she vowed to Pitt, “I agree it all has to go if it goes.”
64. Jolie also never expressed any doubts about the value of Pitt’s contributions to the business, or that Miraval reflects his vision. Instead, she proposed compensating Pitt for his role in overseeing the investment. As Jolie explained through Bird, Jolie did not want “to restrict [Pitt] creatively,” because she “believe[d] in his design” and “trust[ed]” that his decisions would “bring additional value to the property and business.” Bird conveyed this message to Pitt: Jolie would not seek any “control over the renovations and enhancements to the property and business.”
65. The 2017 discussions between Pitt and Jolie eventually stalled due to Jolie’s insistence that Pitt contribute many millions of dollars to her foundation.
53. Pitt and Perrin viewed Miraval Provence as a partnership between families. As Pitt told Perrin in an early exchange: “[W]e should always feature the idea of families.” Thus, the two family names were used on some of the initial labeling on the wine’s gift boxes and bottles:
Nouvel 1ACC
Nouvel suggested that the parties consider whether Chateau Miraval’s stake in Miraval Provence could be transferred to Quimicum to enhance communication and support for the wine business and to facilitate faster decision-making. Nouvel never advocated a risky tax strategy concerning intellectual property, but simply sought to discuss the optimal corporate structure for holding Miraval-related intellectual property,
The French Commercial Code and Chateau Miraval’s Articles of Association require Chateau Miraval to have a board comprised of at least three directors. But Chateau Miraval has had fewer than three directors since November 24, 2021. Thus, all its actions, directed by Pitt, that have been taken since that time have been taken without authority.
Mondo Bongo’s votes against Nouvel’s reasonable proposals to appoint directors have left Quimicum with no director since August 24,2021. As a consequence, Quimicum has had no registered office since Ocorian terminated its agreement with Quimicum on June 28, 2022. Mondo Bongo’s systematic voting against Nouvel’s proposals also has prevented Quimicum from publishing its annual financial statements since 2018. Due to Mondo Bongo’s negative votes, Quimicum is at risk of judicial liquidation
129. While Nouvel’s application for this purpose was pending, the Luxembourg Court of Appeal issued a ruling in Mondo Bongo’s separate action against Nouvel, in which Mondo Bongo sought the appointment of an escrow agent over a 10% interest in Quimicum which was purportedly transferred to Nouvel in 2013 for one Euro, rendering Nouvel a nominal 50-50 shareholder with Mondo Bongo. On November 9, 2023, the Luxembourg Court of Appeal determined to place the disputed 10% interest in Quimicum in escrow, pending a merits ruling in Luxembourg on the validity of the transfer itself. The court explained that “immediate implementation” of this protective measure was necessary to help break the deadlock at Quimicum and regularize its governance.
130. In particular, Nouvel has refused to waive its right to take legal action in the United States against any escrow agent. That matters because the fear of the cost of defending a suit by Nouvel in the United States has caused multiple qualified candidates to withdraw from consideration, including escrow agents that the court ordered be appointed on November 9, 2023, February 8, 2024, and March 12, 2024. At a recent hearing, the Luxembourg court admonished Nouvel’s counsel for its obstruction, urging Nouvel to waive the threat of litigation in the United States. Nouvel’s counsel refused, informing the court, as subsequently memorialized in a signed statement entered into the court record, that he was under “very clear instructions” from Nouvel not to do so.
131. Thus, Nouvel has repeatedly stymied Mondo Bongo’s efforts in connection with the election of Quimicum directors, leaving Quimicum without a functioning board after the transaction purportedly closed and undermining the family partnership to which Pitt and Jolie had agreed. Without a board, Quimicum has been unable to manage its affairs and has been placed at risk of judicial liquidation.
103. On June 30, 2021, at the Stoli Parties’ behest, Jolie filed an ex parte application asking the divorce court to lift the ATROs so that she could sell her interest in Nouvel (whose only asset was its downstream interest in Miraval). The court denied her application on the ground that Jolie had failed to demonstrate there was any threat of irreparable harm, as is required for ex parte relief.
104. Meanwhile, talks between Jolie and Tenute del Mondo—represented by Stoli director Alexey Oliynik, who described himself to Jolie’s team as acting as “instructed by Mr. Shefler”—continued to progress in secret. On July 9, 2021, Jolie and Tenute del Mondo executed an Exclusivity Agreement, drafts of which the parties had been exchanging since May 12, 2021.
105. The Exclusivity Agreement restricted both parties from communicating with Pitt, ensuring that Pitt would continue to be kept in the dark. Stoli committed that it would “not approach in any manner” Quimicum, Château Miraval, Miraval Provence, or any of their direct or indirect shareholders (i.e., Pitt)—not just for the duration of the Exclusivity Period (the time period for most other obligations in the agreement) but until “the completion of the Transaction.”
143. And in August 2021, Stoli asked that Jolie agree to make a “written request” to Miraval Provence within three days of signing the Purchase Agreement to demand that Miraval Provence cease its registration of all “Miraval IP.” Jolie did not agree to this request. And although the Purchase Agreement provides that the marks listed at Schedule 1 are “own[ed] exclusively, beneficially and of record” by Château Miraval S.A., early drafts of the Purchase Agreement indicate that Jolie insisted the agreement make explicit that Schedule 1 “is solely based upon . . . information publicly available,” and she struck Stoli’s attempt to add that the schedule is also based on information “provided by [Jolie].” Early drafts of the Purchase Agreement also show that Stoli asked Jolie to represent that Château Miraval S.A. not only owned the marks at Schedule 1 “exclusively, beneficially and of record,” but also owned them “free and clear of any Encumbrances.” Jolie struck that provision too, refusing to represent that Château Miraval S.A. owned any Miraval-related marks “free and clear of any Encumbrances.” Stoli, intent on keeping its negotiations with Jolie secret from Pitt, never reached out to Miraval Provence to inquire about the status of the marks despite Jolie’s representation to the California Superior Court that the ATROs needed to be lifted to allow due diligence.
Declaration of James Simon dated July 7, 2021
5. On July 6, 2021, after Petitioner’s ex parte application was denied, Petitioner filled an RFO for the same relief to lift the ATROS as they may apply to her sale of her separate property membership interest in Nouvel, LLC. That RFO, a copy of which is attached hereto as Exhibit “D”, is set for hearing on September 22, 2021, in Dept. 7.
6. As set forth in Mr. Schummer's declaration filed in support ofthe RFO (see, Exhibit "D” hereto), he is hopeful to keep the sale afloat by demonstrating to the Buyer Petitioner‘s good faith to go forward with the sale in that she has sought and is seeking relief from the ATROs, and will sign an Exclusivity Agreement with the addition of a condition precedent that the Agreement is subject to this Court lifting the ATROs as they may apply to the sale of her membership interest in Nouvel, LLC. However, time remains of the essence to lift the ATROs as soon as possible because the Buyer is anxious to finalize the sale and may at anytime pull out of the proposed sale.
12. Respondent’s counsel has been aware of Petitioner’s request that Respondent consent to lift the ATROs as they may apply to the sale of Petioner's separate property membership lnterest since Mr. Mannis’ email to counsel on June 25, 2021 (See, p 7 of Mannis declaration filed in support of Petitioner’s RFO (Exhibit “D” hereto). Despite several request thereafter‚ Petitioner has yet to receive Respondent’s response whether Respondent will consent to lift the ATROs as they may apply to the subject sale transaction, or a legal basis for Respondent to block the sale other than the existence of the ATRO.
Declaration of Laurent Schummer dated July 5, 2021
I am advised that under California law Ms. Jolie may not be able to sign the exclusivity agreement without first being relieved from the temporary restraining orders under California Family Code section 2040 (“ATROs”) even though Nouvel is‚ as I understand, Ms. Jolie's separate property, the parties‘ previously bifurcated and terminated their marital status, and the divorce proceeding is approaching five years since the initial filing and automatic issuance of the temporary restraining orders.
Declaration of Lance Spiegel dated June 29, 2021
2. I am familiar with all pleadings filed in this case‚ all discovery conducted in.this case and all orders filed in this case. The Petition for dissolution was filed September 19, 2016, listing the date of the parties marriage, August 14, 2014. On her Declaration of Disclosure Petitioner lists her ownership of Nouvel LLC, a California limited liability company formed in 2008 as her separate propcrty. It is my understanding that Nouvel LLC owns shares of Quimicum S.a.r.I., a Luxembourg corporation, which owns an interest in the French corporations Chateau Miraval SA and Miraval Provence SNC. Respondent owns an LLC, fonned prior to marriage, which owns sharcs in QuimicumS.a.r.I.. I have reviewed both Petitioner's and Respondent's Preliminary Declarations of Disclosure. Both parties list the above referenced LLCs as their separate property.
3. On June 18, 2021, I received an email from Petitioner's counsel, Joe Mannis, asking me to "confirm [his] belief that the ATROS are no longer in force given the length of Separation of the parties, etc." Thereafter I discussed with Mr. Mannis, and he indicated that Petitioner wished to "lift" the ATROs for estate planning purposes. Mr. Mannis also informed me that he would send a proposed stipulation to me. On June 25, I asked Mr. Mannis if his proposed stipulation had any implications on Petitioner trying to sell assets in France, and Mr. Mannis responded Petitioner was exploring sales involving the French assets.
f. The transaction agreements between the Stoli Parties and Jolie, by which the Stoli Parties consummated their purported purchase of Nouvel, further demonstrate the Stoli Parties’ connection to the California forum. Under both the Exclusivity Agreement that Tenute del Mondo and Jolie entered on July 9, 2021 (the “Exclusivity Agreement”), and the Membership Interest Purchase Agreement they entered on September 24, 2021 (the “Purchase Agreement”), Tenute del Mondo submitted to the “exclusive[]” jurisdiction of the California courts and for the parties’ disputes to be “governed by and construed in accordance with” California law. See Purchase Agreement § 9.11; Exclusivity Agreement § 11. In fact, early drafts of the Purchase Agreement indicate that it was the Stoli Parties that insisted the agreement be governed by California law, rejecting Jolie’s repeated suggestions that Delaware or New York law apply.
g. The Stoli Parties also have secured ongoing contractual benefits from Jolie, a California resident, through the Purchase Agreement. Under its terms, Tenute del Mondo—and the other Stoli Parties and their affiliates—are entitled to indemnification from Jolie for “all Losses” resulting from “any Liability of [Nouvel]” resulting from breaches of key representations and warranties, including Jolie’s authority to sell Nouvel, for three years after the closing of the purported deal. See Purchase Agreement § 7.2(a). Jolie is also required to “assist[]” Tenute del Mondo after the closing to “implement the transactions” to which the parties agreed—in other words, to assist Tenute del Mondo in rebuffing any challenges to the deal. Id. § 5.4. The Stoli Parties’ contractual relationship with Jolie in connection with their purported purchase of Nouvel is also ongoing pursuant to an addendum to the Purchase Agreement, which requires Jolie to cooperate with the Stoli Parties and to bear the cost of certain attorneys’ fees incurred in connection with ongoing litigation between Mondo Bongo and Stoli-controlled Nouvel in Europe. See Addendum to Purchase Agreement dated September 27, 2021 (the “First Addendum”) § 2. Moreover, in connection with the European litigation, the Stoli Parties, including Oliynik personally, were granted access to files of California-based Bird, and they secured a declaration from Jolie (executed in Los Angeles, California).
145. Shortly after signing the Purchase Agreement, Stoli, through Shefler, Nouvel, and Oliynik, commenced its takeover strategy. In initial messages to Pitt in October 2021, Shefler explained that he “admire[d] the work [Pitt] ha[d] done with Miraval” and “would be happy to support [Pitt’s] priority to preserve the Chateau as an artist community, where the greatest creative community could feel at home.” Shefler told Pitt: “I respect what you and Perrin have created and that was the exact reason why I did make that deal.” This sentiment was likewise reflected in internal Stoli communications, with one member of Tenute del Mondo’s negotiation team stating that she “[l]ove[d] Brad Pitt’s vision” to make Miraval a “center of all artists.”
