1 BIRD, MARELLA, BOXER, WOLPERT, NESSIM,

DROOKS, LINCENBERG & RHOW, P.C.

2 John V. Berlinski (Bar No. 208537)
jberlinski@birdmarella.com
3 1875 Century Park East, 23rd Fl.
Los Angeles, CA 90067
4 Telephone: (310) 201-2100
Facsimile: (310) 201-2110
5
WACHTELL, LIPTON, ROSEN & KATZ
6 Jonathan M. Moses (admitted pro hac vice)
Adam L. Goodman (admitted pro hac vice)
7 Remy Grosbard (admitted pro hac vice)
Jessica L. Allen (admitted pro hac vice)
8 51 West 52nd Street
New York, NY 10019
9 Telephone: (212) 403-1000
Facsimile: (212) 403-2000
10
Attorneys for Cross-Defendant Warren Grant
11

12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
14
WILLIAM B. PITT, an individual, and Case No. 22STCV06081
15 MONDO BONGO, LLC, a California limited
liability company, WARREN GRANT’S REQUEST FOR
16
JUDICIAL NOTICE IN SUPPORT OF
Plaintiffs, DEMURRER TO FIRST AMENDED
17
CROSS-COMPLAINT OF NOUVEL, LLC;
v.
18 MEMORANDUM OF POINTS AND
ANGELINA JOLIE, et al., AUTHORITIES
19
Defendants. Filed concurrently with Demurrer,
20
Declarations, Notice of Joinder, and Proposed
21 Order
and RELATED CROSS-ACTIONS.
22 Judge: Hon. Lia Martin
Dept: 16
23 Date: January 24, 2024
Time: 9:00 a.m.
24

25 Reservation ID: 900048070166

Action Filed: February 17, 2022
26 Trial Date: Not yet set

27

28

GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF

DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

2 PLEASE TAKE NOTICE that, pursuant to Sections 452 and 453 of the California

3 Evidence Code and Rule 3.1306 of the California Rules of Court, Cross-Defendant WARREN

4 GRANT respectfully request that this Court take judicial notice of the following documents:

5 1. Declaration of Professor André Prüm in support of Warren Grant’s demurrer to

6 Nouvel’s First Amended Cross-Complaint, a true and correct copy of which is

7 attached as Exhibit A to the concurrently filed declaration of John Berlinski (the

8 “Berlinski Declaration”); 1

9 2. Article 710-15 of the Luxembourg Company Law of 10 August 1915, as amended,

10 with a certified English translation, a true and correct copy of which is attached as
11 Exhibit B to the Berlinski Declaration;
12 3. Articles of Association of Quimicum S.à r.l., adopted on March 25, 2013, a true
13 and correct copy of which is attached as Exhibit C to the Berlinski Declaration and
14 which is publicly available at https://gd.lu/rcsl/36B7M9 (as of Sept. 20, 2023);
15 4. Articles 6-1 and 1134 of the Luxembourg Civil Code, with a certified English
16 translation, a true and correct copy of which is attached as Exhibit D to the
17 Berlinski Declaration;
18 5. Excerpts of a treatise by Alain Steichen titled Précis de Droit des Sociétés (Éd.
19 Saint-Paul, 6th ed. 2018), with a certified English translation of those excerpts, a
20 true and correct copy of which is attached as Exhibit E to the Berlinski Declaration;
21 6. A Luxembourgish civil court case, captioned Cour d’appel, No. 43424 (July 13,
22 2018), with a certified English translation, a true and correct copy of which is
23 attached as Exhibit F to the Berlinski Declaration;
24 7. Excerpts of a treatise by Georges Ravarani titled La Responsabilité Civile des
25 Personnes Privées et Publiques (Pasicrisie, 3rd ed. 2014), with a certified English
26 translation of those excerpts, a true and correct copy of which is attached as Exhibit
27
1
28 For ease of reference, the Declaration of Professor André Prüm also has been concurrently filed
with the demurrer as a standalone document.
-2-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 G to the Berlinski Declaration;

2 8. A Luxembourgish civil court case, captioned Cour d’appel, PAS. 29, at 241 (May

3 5, 1993), with a certified English translation, a true and correct copy of which is

4 attached as Exhibit H to the Berlinski Declaration;

5 9. A Luxembourgish civil court case, captioned Cour d’appel, No. CAL-2021-00076

6 (Dec. 21, 2022), with a certified English translation, a true and correct copy of

7 which is attached as Exhibit I to the Berlinski Declaration;

8 10. A Luxembourgish commercial court case, captioned Cour d’appel, PAS. 29, at 483

9 (March 23, 2021), with a certified English translation, a true and correct copy of
10 which is attached as Exhibit J to the Berlinski Declaration;
11 11. Minutes of the Annual General Meeting of the Shareholders of Quimicum S.à r.l.
12 held on September 8, 2020, a true and correct copy of which is attached as Exhibit
13 K to the Berlinski Declaration;
14 12. Letter from Mondo Bongo to the District Court of Luxembourg and Nouvel
15 (Docket No. TAL-2022-06390), dated Feb. 17, 2023, with a certified English
16 translation, a true and correct copy of which is attached as Exhibit L to the
17 Berlinski Declaration;
18 13. Letter from Nouvel to the District Court of Luxembourg and Mondo Bongo
19 (Docket No. TAL-2022-06390), dated Feb. 21, 2023, with a certified English
20 translation, a true and correct copy of which is attached as Exhibit M to the
21 Berlinski Declaration;
22 14. An Order of the District Court of Luxembourg (Docket No. TAL-2023-01395),
23 dated March 10, 2023, with a certified English translation, a true and correct copy
24 of which is attached as Exhibit N to the Berlinski Declaration;
25 15. A Luxembourgish civil court case, captioned Cour d’appel, PAS. 34, at 376 (Jan. 7,
26 2009), with a certified English translation, a true and correct copy of which is
27 attached as Exhibit O to the Berlinski Declaration;
28
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GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 16. A Luxembourgish civil court case, captioned Cour d’appel, No. CAL-2019-00922

2 (March 4, 2020), with a certified English translation, a true and correct copy of

3 which is attached as Exhibit P to the Berlinski Declaration;

4 17. A Luxembourgish commercial court case, captioned Cour d’appel, PAS. 36, at 71

5 (Feb. 15, 2012), with a certified English translation, a true and correct copy of

6 which is attached as Exhibit Q to the Berlinski Declaration;

7 18. A Luxembourgish commercial court case, captioned Cour d’appel, PAS. 36, at 214

8 (Nov. 30, 2011), with a certified English translation, a true and correct copy of

9 which is attached as Exhibit R to the Berlinski Declaration;

10 19. A Luxembourgish commercial court case, UBS v. Luxalpha, captioned Cour
11 d’appel, PAS. 37, at 361 (Dec. 23, 2014), with a certified English translation, a true
12 and correct copy of which is attached as Exhibit S to the Berlinski Declaration;
13 20. A Luxembourgish civil court case, captioned Tribunal civil de Luxembourg, PAS.
14 3, at 537 (Aug. 10, 1891), with a certified English translation, a true and correct
15 copy of which is attached as Exhibit T to the Berlinski Declaration;
16 21. Article 1240 of the French Civil Code, with a certified English translation, a true
17 and correct copy of which is attached as Exhibit U to the Berlinski Declaration;
18 22. A French civil court case, captioned Cour de Cassation, No. 08-16.790 (July 7,
19 2009), with a certified English translation, a true and correct copy of which is
20 attached as Exhibit V to the Berlinski Declaration;
21 23. Articles L233-22 and L225-252 of the French Commercial Code, with a certified
22 English translation, a true and correct copy of which is attached as Exhibit W to the
23 Berlinski Declaration;
24 24. An Order of the District Court of Luxembourg (Docket No. TAL-2023-01395),
25 dated July 19, 2023, with a certified English translation, a true and correct copy of
26 which is attached as Exhibit X to the Berlinski Declaration; and
27

28
-4-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 25. Summons for Urgent Proceedings issued by Nouvel to Mondo Bongo and

2 Quimicum S.à r.l. to appear before the District Court of Luxembourg, dated June

3 28, 2022, a true and correct copy of which is attached as Exhibit Y to the Berlinski

4 Declaration.

5 This request is based on this notice, the accompanying memorandum of points and

6 authorities, the concurrently filed declaration of John V. Berlinski, and all other documents,

7 filings, pleadings, and evidence before this Court.

8
/s/ John V. Berlinski
9 DATED: September 20, 2023 By:
BIRD MARELLA P.C.
10 John V. Berlinski
11 WACHTELL, LIPTON, ROSEN & KATZ
Jonathan M. Moses (admitted pro hac vice)
12 Adam L. Goodman (admitted pro hac vice)
Remy Grosbard (admitted pro hac vice)
13 Jessica L. Allen (admitted pro hac vice)
14 Attorneys for Cross-Defendant Warren Grant
15

16

17

18

19

20

21

22

23

24

25

26

27

28
-5-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 INTRODUCTION

2 Cross-Defendant Warren Grant respectfully requests that the Court take judicial notice of

3 the following documents in support of his concurrently filed demurrer to the First Amended

4 Cross-Complaint of Nouvel:

5 1. Declaration of Professor André Prüm in support of Warren Grant’s demurrer to

6 Nouvel’s First Amended Cross-Complaint, a true and correct copy of which is

7 attached as Exhibit A to the concurrently filed declaration of John Berlinski (the

8 “Berlinski Declaration”);

9 2. Article 710-15 of the Luxembourg Company Law of 10 August 1915, as amended,

10 with a certified English translation, a true and correct copy of which is attached as
11 Exhibit B to the Berlinski Declaration;
12 3. Articles of Association of Quimicum S.à r.l., adopted on March 25, 2013 (the
13 “Quimicum Articles”), a true and correct copy of which is attached as Exhibit C to
14 the Berlinski Declaration and which is publicly available at
15 https://gd.lu/rcsl/36B7M9 (as of Sept. 20, 2023);
16 4. Articles 6-1 and 1134 of the Luxembourg Civil Code, with a certified English
17 translation, a true and correct copy of which is attached as Exhibit D to the
18 Berlinski Declaration;
19 5. Excerpts of a treatise by Alain Steichen titled Précis de Droit des Sociétés (Éd.
20 Saint-Paul, 6th ed. 2018), with a certified English translation of those excerpts, a
21 true and correct copy of which is attached as Exhibit E to the Berlinski Declaration;
22 6. A Luxembourgish civil court case, captioned Cour d’appel, No. 43424 (July 13,
23 2018), with a certified English translation, a true and correct copy of which is
24 attached as Exhibit F to the Berlinski Declaration;
25 7. Excerpts of a treatise by Georges Ravarani titled La Responsabilité Civile des
26 Personnes Privées et Publiques (Pasicrisie, 3rd ed. 2014), with a certified English
27 translation of those excerpts, a true and correct copy of which is attached as Exhibit
28 G to the Berlinski Declaration;
-6-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 8. A Luxembourgish civil court case, captioned Cour d’appel, PAS. 29, at 241 (May

2 5, 1993), with a certified English translation, a true and correct copy of which is

3 attached as Exhibit H to the Berlinski Declaration;

4 9. A Luxembourgish civil court case, captioned Cour d’appel, No. CAL-2021-00076

5 (Dec. 21, 2022), with a certified English translation, a true and correct copy of

6 which is attached as Exhibit I to the Berlinski Declaration;

7 10. A Luxembourgish commercial court case, captioned Cour d’appel, PAS. 29, at 483

8 (March 23, 2021), with a certified English translation, a true and correct copy of

9 which is attached as Exhibit J to the Berlinski Declaration;

10 11. Minutes of the Annual General Meeting of the Shareholders of Quimicum S.à r.l.
11 held on September 8, 2020 (the “Quimicum Meeting Minutes”), a true and correct
12 copy of which is attached as Exhibit K to the Berlinski Declaration;
13 12. Letter from Mondo Bongo to the District Court of Luxembourg and Nouvel
14 (Docket No. TAL-2022-06390), dated Feb. 17, 2023, with a certified English
15 translation, a true and correct copy of which is attached as Exhibit L to the
16 Berlinski Declaration;
17 13. Letter from Nouvel to the District Court of Luxembourg and Mondo Bongo
18 (Docket No. TAL-2022-06390), dated Feb. 21, 2023, with a certified English
19 translation, a true and correct copy of which is attached as Exhibit M to the
20 Berlinski Declaration;
21 14. An Order of the District Court of Luxembourg (Docket No. TAL-2023-01395),
22 dated March 10, 2023, with a certified English translation, a true and correct copy
23 of which is attached as Exhibit N to the Berlinski Declaration;
24 15. A Luxembourgish civil court case, captioned Cour d’appel, PAS. 34, at 376 (Jan. 7,
25 2009), with a certified English translation, a true and correct copy of which is
26 attached as Exhibit O to the Berlinski Declaration;
27 16. A Luxembourgish civil court case, captioned Cour d’appel, No. CAL-2019-00922
28 (March 4, 2020), with a certified English translation, a true and correct copy of
-7-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 which is attached as Exhibit P to the Berlinski Declaration;

2 17. A Luxembourgish commercial court case, captioned Cour d’appel, PAS. 36, at 71

3 (Feb. 15, 2012), with a certified English translation, a true and correct copy of

4 which is attached as Exhibit Q to the Berlinski Declaration;

5 18. A Luxembourgish commercial court case, captioned Cour d’appel, PAS. 36, at 214

6 (Nov. 30, 2011), with a certified English translation, a true and correct copy of

7 which is attached as Exhibit R to the Berlinski Declaration;

8 19. A Luxembourgish commercial court case, UBS v. Luxalpha, captioned Cour

9 d’appel, PAS. 37, at 361 (Dec. 23, 2014), with a certified English translation, a true
10 and correct copy of which is attached as Exhibit S to the Berlinski Declaration;
11 20. A Luxembourgish civil court case, captioned Tribunal civil de Luxembourg, PAS.
12 3, at 537 (Aug. 10, 1891), with a certified English translation, a true and correct
13 copy of which is attached as Exhibit T to the Berlinski Declaration;
14 21. Article 1240 of the French Civil Code, with a certified English translation, a true
15 and correct copy of which is attached as Exhibit U to the Berlinski Declaration;
16 22. A French civil court case, captioned Cour de Cassation, No. 08-16.790 (July 7,
17 2009), with a certified English translation, a true and correct copy of which is
18 attached as Exhibit V to the Berlinski Declaration;
19 23. Articles L233-22 and L225-252 of the French Commercial Code, with a certified
20 English translation, a true and correct copy of which is attached as Exhibit W to the
21 Berlinski Declaration;
22 24. An Order of the District Court of Luxembourg (Docket No. TAL-2023-01395),
23 dated July 19, 2023, with a certified English translation, a true and correct copy of
24 which is attached as Exhibit X to the Berlinski Declaration; and
25 25. Summons for Urgent Proceedings issued by Nouvel to Mondo Bongo and
26 Quimicum S.à r.l. to appear before the District Court of Luxembourg, dated June
27 28, 2022, a true and correct copy of which is attached as Exhibit Y to the Berlinski
28 Declaration.
-8-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 LEGAL STANDARD

2 Pursuant to California Evidence Code § 453, “[t]he trial court shall take judicial notice of

3 any matter specified in Section 452 if a party requests it and: (a) [g]ives each adverse party

4 sufficient notice of the request, through the pleadings or otherwise, to enable such adverse party to

5 prepare to meet the request; and (b) [f]urnishes the court with sufficient information to enable it to

6 take judicial notice of the matter.”

7 ARGUMENT

8 I. The Court should take judicial notice of documents referenced and incorporated
9 into Nouvel’s First Amended Cross-Complaint (Exhibits C and K).

10 The Court should take judicial notice of the Quimicum Articles (Exhibit C) and the
11 Quimicum Meeting Minutes (Exhibit K), which are incorporated by reference into Nouvel’s First

12 Amended Cross-Complaint.

13 California Evidence Code § 452 authorizes the Court to take judicial notice of “[f]acts and
14 propositions that are not reasonably subject to dispute and are capable of immediate and accurate

15 determination by resort to sources of reasonably indisputable accuracy.” Cal. Evid. Code

16 § 452(h). Nouvel has alleged the accuracy and truthfulness of the Quimicum Articles and the

17 Quimicum Meeting Minutes by repeatedly and extensively referencing and quoting these

18 documents in its First Amended Cross-Complaint. See ¶¶ 224–32, 293–300, 323–28 (quoting and

19 bringing claims premised on the Quimicum Articles); see also ¶¶ 95–96 (summarizing and quoting

20 the Quimicum Meeting Minutes). 2 Moreover, the Quimicum Articles were publicly filed in

21 Luxembourg and are available on a Luxembourgish government website, while the Quimicum

22 Meeting Minutes were approved and signed by Nouvel’s proxyholder (its attorney, Laurent

23 Schummer), as well as the Chairman, Scrutineer, and Secretary of Quimicum. See Ex. K at 8.

24 These documents are therefore “not reasonably subject to dispute” and “capable of immediate and

25 accurate determination.” Cal. Evid. Code § 452(h). The Court should, therefore, take judicial

26 notice of these documents in their entirety. See, e.g., Salvaty v. Falcon Cable Television, 165 Cal.

27

28 2
Citations to ¶ are of Nouvel’s First Amended Cross-Complaint.
-9-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 App. 3d 798, 800 n.1 (1985) (demurrer properly sustained where trial court took judicial notice of

2 contract, because “[g]iven the references to the agreement in the complaint, [defendants] were

3 entitled to present the trial court with the complete document”); Dryden v. Tri-Valley Growers, 65

4 Cal. App. 3d 990, 997 (1977) (demurrer properly sustained where trial court took judicial notice of

5 two letters “incorporated” in the complaint); see also Ingram v. Flippo, 74 Cal. App. 4th 1280,

6 1285 n.3 (1999) (taking judicial notice of documents which complaint “excerpted quotes from . . .

7 and summarized parts of” and which “form[ed] the basis of the allegations” was “essential” to

8 evaluate complaint).

9 In addition, since these exhibits have been incorporated into the First Amended Cross-
10 Complaint, the Court may treat these exhibits as if they had been attached to the pleading and may

11 take notice of facts appearing in them. See The Rutter Group, Cal. Prac. Guide Civ. Pro. Before

12 Trial Ch. 7(I)-A (“‘Face of the complaint’ includes matters shown in exhibits attached to the

13 complaint and incorporated by reference . . . .”); id. (“[F]acts appearing in exhibits attached to the

14 complaint are given precedence over inconsistent allegations in the complaint”.).

15
II. The Court should take judicial notice of court filings in Luxembourg proceedings
16 between Nouvel and Mondo Bongo (Exhibits L–N, X, and Y).

17 The Court should take judicial notice of the following court filings in Luxembourg

18 proceedings between Nouvel and Mondo Bongo: (1) court filings in the form of letters docketed

19 by Mondo Bongo and Nouvel with the District Court of Luxembourg (Exhibits L and M);

20 (2) orders of the District Court of Luxembourg (Exhibits N and X); and (3) a summons issued by

21 Nouvel to Mondo Bongo to appear before the District Court of Luxembourg (Exhibit Y). Because

22 the existence of these court filings is “not reasonably subject to dispute,” the Court should take

23 judicial notice of these exhibits. Cal. Evid. Code § 452(h).

24 In Java Oil Ltd. v. Sullivan, 168 Cal. App. 4th 1178 (2008), for instance, the Court of

25 Appeal took judicial notice of numerous orders in a case between the parties to the California

26 action that they had previously litigated in Gibraltar. Id. at 1181 n.1. Likewise, in TSMC N. Am.

27 v. Semiconductor Mfg. Internat. Corp., 161 Cal. App. 4th 581 (2008), the Court of Appeal took

28 judicial notice of a Beijing court’s ruling and the parties’ related filings. Id. at 597 n.7. The Court
-10-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 may also take judicial notice of undisputed facts within these court filings. See Friends of Shingle

2 Springs Interchange, Inc. v. Cnty. of El Dorado, 200 Cal. App. 4th 1470, 1484 (2011) (court is not

3 precluded from taking judicial notice of documents containing undisputed facts).

4 III. The Court should take judicial notice of Luxembourgish and French law (Exhibits
5 A, B, D–J, and O–W).

6 The Court should take judicial notice of the following sources of Luxembourgish and

7 French law: (1) the declaration of Professor André Prüm (Exhibit A); (2) Luxembourgish and

8 French statutes (Exhibits B, D, U, and W); (3) excerpts from treatises regarding Luxembourgish

9 law (Exhibits E and G); and (4) Luxembourgish and French caselaw (Exhibits F, H–J, O–T, and
10 V).

11 California Evidence Code § 452(f) authorizes the court to take judicial notice of “[t]he law

12 of . . . foreign nations.” In taking judicial notice, “[a]ny source of pertinent information, including

13 the advice of persons learned in the subject matter, may be consulted.” Id. § 454(a)(1); see also id.

14 § 452(b)(1) (“Where the subject of judicial notice is the law of an organization of nations, a

15 foreign nation, or a public entity in a foreign nation and the court resorts to the advice of persons

16 learned in the subject matter, such advice, if not received in open court, shall be in writing.”).

17 Courts therefore may consider the written opinions of experts, as well as treatises and other

18 published materials, to ascertain and take judicial notice of foreign law. See, e.g.,

19 Volkswagenwerk Aktiengesellschaft v. Super. Ct. (Thomsen), 123 Cal. App. 3d 840, 852–

20 53 (1981) (taking judicial notice of law of West Germany, based on relevant materials submitted

21 by parties and other published sources), abrogated on other grounds by Am. Home Assurance Co.

22 v. Société Commerciale Toutélectric, 104 Cal. App. 4th 406 (2002); see also In re Chichernea’s

23 Est., 66 Cal. 2d 83, 87 (1967) (taking judicial notice, pursuant to predecessor statute of Cal. Evid.

24 Code § 452, of Romanian law, based on “opinions of eminent authorities” and “reported decisions

25 of the highest Rumanian courts”). Similarly, courts may consider foreign statutes and caselaw.

26 See In re Chichernea’s Est., 66 Cal. 2d 83; Rockefeller Tech. Invs. (Asia) VII v. Changzhou

27 Sinotype Tech. Co., 24 Cal. App. 5th 115, 132 (2018) (taking judicial notice of Civil Procedure

28 Law of China), rev’d and remanded on other grounds, 9 Cal. 5th 125, 460 P.3d 764 (2020).
-11-
GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 CONCLUSION

2 For the foregoing reasons, Grant respectfully requests that the Court take judicial notice of

3 Exhibits A through Y in support of his concurrently filed demurrer.

6 DATED: September 20, 2023 By:

BIRD MARELLA P.C.
7 John V. Berlinski
8 WACHTELL, LIPTON, ROSEN & KATZ
Jonathan M. Moses (admitted pro hac vice)
9 Adam L. Goodman (admitted pro hac vice)
Remy Grosbard (admitted pro hac vice)
10 Jessica L. Allen (admitted pro hac vice)
11 Attorneys for Cross-Defendant Warren Grant
12

13

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26

27

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GRANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEMURRER TO FIRST AMENDED CROSS-COMPLAINT OF NOUVEL
 1 PROOF OF SERVICE

2 William B. Pitt and Mondo Bongo, LLC v. Angelina Jolie, et al.

Case No. 22STCV06081
3
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
4
At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Los Angeles, State of California. My business address is 1875 Century
Park East, 23rd Floor, Los Angeles, CA 90067-2561.
6
On September 20, 2023, I served the following document(s) described as WARREN GRANT’S
7
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO FIRST
8 AMENDED CROSS-COMPLAINT OF NOUVEL, LLC; MEMORANDUM OF POINTS
AND AUTHORITIES on the interested parties in this action as follows:
9 SEE ATTACHED SERVICE LIST
10 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused the document(s) to be
sent from e-mail address mwilson@birdmarella.com to the persons at the e-mail addresses listed
11
in the Service List. I did not receive, within a reasonable time after the transmission, any
12 electronic message or other indication that the transmission was unsuccessful.

13 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
14
Executed on September 20, 2023, at Los Angeles, California.
15

16

17
Maria Wilson
18

19

20

21

22

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27

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-13-
PROOF OF SERVICE
 1 SERVICE LIST
William B. Pitt and Mondo Bongo, LLC v. Angelina Jolie, et al.
2 22STCV06081
3
Paul D. Murphy Attorneys for Defendant and Cross-
4 Daniel N. Csillag Complainant
MURPHY ROSEN LLP Angelina Jolie
5 100 Wilshire Blvd., Suite 1300
Santa Monica, CA 90401
6 Email: pmurphy@murphyrosen.com
Email: dcsillag@murphyrosen.com
7

8 Keith R. Hummel Attorneys for Defendant and Cross-

Justin C. Clarke Complainant
9 Jonathan D. Mooney Nouvel, LLC
CRAVATH, SWAINE & MOORE LLP
10 Worldwide Plaza
825 Eighth Avenue
11
New York, NY 10019
12 Email: khummel@cravath.com
Email: jcclarke@cravath.com
13 Email: jmooney@cravath.com

14 Joe Tuffaha
Prashanth Chennakesavan
15
LTL ATTORNEYS LLP
16 300 South Grand Avenue, Suite 1400
Los Angeles, CA 90071
17 Email: joe.tuffaha@ltlattorneys.com
Email: prashanth.chennakesavan@ltlattorneys.com
18
Mark T. Drooks Appearing specially to challenge
19
BIRD, MARELLA, BOXER, WOLPERT, NESSIM, jurisdiction on behalf of Cross-
20 DROOKS, LICENBERG &rdRHOW, P.C. Defendants
1875 Century Park East, 23 Floor Marc-Olivier Perrin, SAS Miraval
21 Los Angeles, CA 90067 Provence, and Families Perrin.
Email: mdrooks@birdmarella.com
22
S. Gale Dick
23
COHEN & GRESSER
24 800 Third Avenue
New York, NY 10022
25 Email: sgdick@cohengresser.com

26

27

28
-14-
PROOF OF SERVICE
 1 Laura W. Brill Appearing specially to challenge
Katelyn A. Kuwata jurisdiction on behalf of Cross-
2 KENDALL BRILL & KELLY LLP Defendants
10100 Santa Monica Blvd., Suite 1725 Gary Bradbury and Roland Venturini
3
Los Angeles, CA 90067
4 Email: lbrill@kbkfirm.com
Email: kkuwata@kbkfirm.com
5

10

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PROOF OF SERVICE