State

1 PAUL D. MURPHY (State Bar No.
159556)
[email protected]
2 DANIEL N. CSILLAG (State Bar No. 266773)
[email protected]
3 STELLA CHANG (State Bar No. 335851)
[email protected]
4 MURPHY ROSEN LLP
100 Wilshire Boulevard, Suite 1300
5 Santa Monica, California 90401-1142
Telephone: (310) 899-3300
6 Facsimile: (310) 399-7201
7 Attorneys for Defendant and Cross-Complainant

Angelina Jolie
8
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
11
12 WILLIAM B. PITT, an individual, and CASE NO. 22STCV06081

TELEPHONE 310-899-3300; FACSIMILE 310-399-7201
MONDO BONGO, LLC, a California

100 WILSHIRE BOULEVARD, SUITE 1300
13 limited liability company, [Hon. Lia Martin]

MURPHY ROSEN LLP
SANTA MONICA, CA 90401-1142
14 Plaintiffs, DEFENDANT AND CROSS-

COMPLAINANT ANGELINA JOLIE’S
15 vs. RESPONSIVE SEPARATE
STATEMENT IN SUPPORT OF
16 ANGELINA JOLIE, an individual, and OPPOSITION TO PLAINTIFFS’
NOUVEL, LLC, a California limited MOTION TO COMPEL FURTHER
17 liability company, RESPONSES AND PRODUCTION OF
DOCUMENTS
18 Defendants.
[Filed concurrently with Opposition to
19 Motion to Compel Further Responses and
Declaration of Paul D. Murphy with
20 exhibits]
21 Date: May 16, 2024

Time: 9:00 a.m.
22 Dept.: 3
23
AND RELATED CROSS ACTIONS. Reservation ID: 257097942103
24
25
26
27
28
PRINTED ON RECYCLED PAPER

JOLIE’S RESPONSIVE SEPARATE STATEMEINT IN SUPPORT OF OPPOSITION TO PITT’S MTC
1 Defendant and Cross-Complainant Angelina Jolie hereby submits her Responsive
2 Separate Statement in Support of Opposition to Plaintiffs Motion to Compel Further
3 Responses and Production of Documents opposition to Plaintiff and Cross-Defendants
4 William B. Pitt and Mondo Bongo, LLC’s (collectively, “Pitt”) Motion to Compel Further
5 Responses and Production of Documents responsive to Plaintiffs’ Second Set of Requests for
6 Production (the “Requests”).
7 REQUEST FOR PRODUCTION NO. 1:
8 All non-disclosure or non-disparagement agreements to which YOU are a party.
9 JOLIE’S RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
10 In addition to the general objections, Jolie objects to this request on the following
11 grounds: (a) the request is overbroad as any non-disclosure and non-disparagement agreements
12 other than those between Jolie and Pitt entered after Pitt’s physical and emotional abuse of
13 Jolie and their children have no relevance to this case; (b) the request seeks documents
MURPHY ROSEN LLP
14 protected from disclosure by the attorney-client privilege [and] the work product doctrine; and
15 (c) for the parties to any such agreements, the request seeks documents protected from
16 disclosure by their rights of privacy under the Constitution of the State of California.
17 Subject to the foregoing general and specific objections, Jolie responds as follows:
18 Jolie will produce any non-disclosure and non-disparagement agreements between Jolie and
19 Pitt, entered after Pitt’s physical and emotional abuse of Jolie and their children, regarding
20 their personal conduct.
21 PLAINTIFFS’ FACTUAL AND LEGAL REASONS FOR COMPELLING FURTHER
22 RESPONSE AND PRODUCTION:
23 The defined term “YOU” refers here to the Defendant, Angelina Jolie. The sole
24 question before the Court in connection with this Request, therefore, is whether Jolie’s non-
25 disclosure and/or non-disparagement agreements with third parties are relevant or likely to
26 lead to the discovery of admissible evidence in this lawsuit. The answer is “yes.”
27 Jolie—not Pitt—places an oversized emphasis on the importance of non-disparagement
28 clauses in this lawsuit. For example, to rationalize her wrongful refusal to sell her indirect
-2- PRINTED ON RECYCLED PAPER

1 interest in Château Miraval to Pitt, Jolie alleges that “the deal [for Pitt to purchase her stake in
2 Château Miraval] fell apart because Pitt demanded Jolie agree to a non-disparagement clause
3 covering his personal conduct as a condition of his purchase of the winery.” X-C ¶ 39. Jolie
4 asserts that this issue “goes to the very heart of this case,” and she seeks a declaratory
5 judgment that Pitt’s request rendered “unconscionable, void, and against public policy” the
6 former couple’s implied-in-fact contract providing that each of them would have a consent
7 right over any sale to a third party. Id. ¶¶ 39, 42(c). Jolie also recently filed her own Motion
8 to Compel in which she claims that Pitt and his winemaker partner Perrin’s suggested non-
9 disclosure provision was “cruel,” “hurtful,” caused her to “nearly shutdown,” and was the
10 reason she terminated her negotiations to sell her indirect interest in the winery to Pitt. Pitt, for
11 his part, asserts that these claims are pretextual.
12 To probe the veracity of this NDA defense at “the very heart of” Jolie’s case, Pitt
13 served this Request seeking NDAs to which Jolie is herself a party. These documents are
MURPHY ROSEN LLP
14 probative of whether Jolie actually viewed the provision requested by Pitt and Perrin as an
15 “abusive and controlling deal-breaker” that released her of any contractual obligations to Pitt.
16 Jolie, unsurprisingly, wants to shield these documents from discovery, and therefore agreed to
17 produce only those NDAs, if any, between Jolie and Pitt themselves. Jolie adamantly refuses
18 to produce other NDAs that she willingly entered into during the relevant time period,
19 presumably because she knows they will severely undermine her defenses.
20 If Jolie willingly entered into similar or more restrictive NDAs with third parties, for
21 example, that would cast serious doubt on her claim that she viewed Pitt’s request as so
22 unconscionable that it caused her to crater a $50+ million transaction that she was poised to
23 enter after months of negotiations. Documents showing the types of provisions that Jolie did
24 not find to be unconscionable (and the reasons why she found them acceptable) are therefore
25 relevant (or, at minimum, likely to lead to the discovery of admissible evidence) and should be
26 produced. That such documents exist is hardly speculative; Jolie herself proposed an even
27 broader NDA to Pitt in connection with their family litigation six months after Pitt and Perrin
28 proposed the NDA that Jolie now alleges caused her to “nearly shutdown” and pull out of the

1 deal. See SAC ¶ 88.
2 Jolie nonetheless bases her objection on her alleged subjective belief that the non-
3 disparagement provision requested by Pitt was uniquely objectionable because it would have
4 covered (broadly speaking) the details of the parties’ relationship. But this argument goes to
5 the probative weight of the documents requested, not the relevance, and accordingly has no
6 place at the discovery phase. Nor is the Request overbroad or excessive. Rather, it is laser-
7 focused on the NDAs themselves, a narrow set of documents that are readily available to Jolie.
8 The Request is reasonably calculated to lead to discovery of documents that will test
9 whether Jolie was truly so offended by the proposed NDA and her claim that she was entitled
10 to breach her contract with Pitt and improperly sell to the Stoli Parties, or whether (as Pitt
11 believes these documents will help show) her defense is pure pretext. “That is enough to
12 justify discovery.” Lipton v. Superior Ct., 48 Cal. App. 4th 1599, 1616 (1996).
13 JOLIE’S RESPONSE TO PLAINTIFFS’ FACTUAL AND LEGAL REASONS FOR

MURPHY ROSEN LLP
14 COMPELLING FURTHER RESPONSE AND PRODUCTION:
15 As the moving party seeking to compel the production of documents, Pitt has the
16 burden to make a “fact-specific showing of relevance” concerning the documents he seeks.
17 Glenfed Dev. Corp. v. Superior Court, 53 Cal.App.4th 1113, 1117 (1997). In RFP No. 1, Pitt
18 seeks to compel the production of over 16 years’ worth of contracts to which Jolie was a party
19 where the contract includes either a non-disparagement agreement or a non-disclosure
20 agreement (collectively referred to as “NDAs”). According to Pitt, these other NDAs with
21 other people about other matters unrelated to this lawsuit somehow test Jolie’s credibility
22 because Jolie asserts that Pitt’s agreement to buy her interest in Miraval fell apart when she
23 refused Pitt’s demand for an NDA to cover Pitt’s physical and emotional abuse of Jolie and
24 their children.
25 But Pitt’s argument is a non-sequitur. Its most obvious problem is that it attempts to
26 equate NDAs Jolie entered that do not cover Pitt’s abuse of their family with the NDA Pitt
27 himself demanded to cover-up his own abuse of Jolie and their children. There is no
28 connection between them at all—none. For this reason, these other NDAs do not probe Jolie’s

1 veracity regarding the impact of Pitt’s proposed NDA in any way. And contrary to Pitt’s
2 suggestion, Jolie does not contend in her Cross-Complaint that all NDAs are bad or
3 problematic, and she does not seek such a blanket ruling in this case. To the contrary, Jolie
4 was at all times agreeable to the original NDA Pitt proposed that was limited to the winery. It
5 was only after Pitt changed the language to cover his personal abuse of the family that Jolie
6 objected. Indeed, there is a stark difference between an NDA Jolie signed with a movie studio
7 or an employee, and the last-minute, expanded NDA her abusive ex-husband tried to force her
8 to sign to bury his criminal conduct.
9 Pitt’s related argument that Jolie asking others to enter NDAs covering aspects of her
10 private life is probative of Pitt asking Jolie to be silent about criminal conduct he committed is
11 a false equivalence. If Jolie hired someone to prepare meals for her family inside her home
12 and asked that person to enter an NDA so the person would not disclose to the tabloids what
13 her family ate every day (Motion at 14), that particular NDA has no relevance to how Jolie felt
MURPHY ROSEN LLP
14 when Pitt asked her to sign an NDA silencing her from speaking about her own life and the
15 painful events she experienced at Pitt’s hands.
16 Pitt’s request for the documents fails for other reasons as well. The law is clear that
17 “courts shall limit the scope of discovery if it determines that the burden, expense, or
18 intrusiveness of that discovery clearly outweighs the likelihood that the information sought
19 will lead to the discovery of admissible evidence.” C.C.P. § 2017.020. Here, the burden,
20 expense, and intrusiveness of Jolie having to gather and produce nearly two decades of
21 contracts clearly outweighs the likelihood that the information sought will lead to the
22 discovery of admissible evidence. Moreover, if the Court concludes that the evidence is
23 relevant and admissible, this will then result in a series of mini-trials for each and every
24 contract Pitt hopes to use. The Court is never going to allow such mini-trials. As a result, the
25 documents are not only irrelevant, but they are also not likely to lead to the discovery of
26 admissible evidence.
27 In fact, Pitt’s use of these documents at trial will be separately barred by Evidence
28 Code sections 786, 787 and 1101(a) because this is improper character evidence. Section 786

1 states that evidence “of traits of his character other than honesty or veracity, or their opposites,
2 is inadmissible to attack or support the credibility of a witness.” Section 787 states that, aside
3 from prior felony convictions, “Evidence of specific instances of his conduct relevant only as
4 tending to prove a trait of his character is inadmissible to attack or support the credibility of a
5 witness.” And Section 1101(a) states that “evidence of a person’s character or a trait of his or
6 her character (whether in the form of an opinion, evidence of reputation, or evidence of
7 specific instances of his or her conduct) is inadmissible when offered to prove his or her
8 conduct on a specified occasion.” Pitt’s theory is barred by each of these sections of the
9 Evidence Code. He will not be able to use prior instances of Jolie’s conduct (entering other
10 NDAs with other people about other matters) to prove that she should have been fine with
11 agreeing to his abusive NDA too.
12 Further, Pitt’s request is also overbroad as to time and scope. It seeks all NDAs Jolie
13 entered from January 1, 2007 through the present, but Jolie contends the NDA Pitt proposed
MURPHY ROSEN LLP
14 was problematic because it attempted to bury Pitt’s abuse. There is no relevance to contracts
15 she entered into with other people about issues unrelated to the abuse. At best, Pitt is entitled
16 to any NDAs Jolie entered with Pitt, which Jolie has agreed to give. Anything else is
17 overbroad as to time and scope.
18 Pitt’s demand for nearly two decades worth of contracts also intrudes on Jolie’s right of
19 privacy. When assessing a claimed privacy right, the “privacy interests [must] be specifically
20 identified and carefully comparted with competing or countervailing privacy and nonprivacy
21 interests in a balancing test.” Hill v. Nat’l Collegiate Athletic Ass’n, 7 Cal.4th 37-38 (1994).
22 As a starting point, courts must first “place the burden on the party asserting a privacy interest
23 to establish its extent and seriousness of the prospective invasion, and against that showing
24 must weigh the countervailing interest the opposing party identifies.” Williams v. Superior
25 Court, 3 Cal.5th 531, 557 (2017). “In weighing the privacy interests of the third party, the trial
26 court should consider the nature of the information sought, its inherent intrusiveness, and any
27 specific showing for a need for privacy, including any harm that disclosure of the information
28 might cause.” In re Marriage of Williamson, 226 Cal.App.4th 1303, 1319 (2014).

1 Here, most, if not all, of these agreements will be employment-related contracts that
2 include Jolie’s compensation or compensation she paid to third parties. These third parties
3 have their own privacy rights. Pitt has not even offered to give any form of notice whatsoever
4 to these third-parties to allow them the opportunity to protect their rights, nor does he
5 acknowledge that these other persons and entities have privacy rights here. Against this
6 sensitive information, Pitt has little countervailing interest in obtaining these documents.
7 Moreover, any negligible relevance is greatly outweighed by Pitt’s intrusion into Jolie’s and
8 these third parties’ privacy rights, with the balance in favor of protecting privacy rights—made
9 all the more problematic by the fact that such evidence has virtually no chance of being
10 admitted at trial.
11 Pitt wants to argue that because Jolie entered NDAs with other people, she could not
12 have been bothered by the NDA Pitt demanded she sign. But each and every one of these
13 other NDAs involve separate people, different interests, and unique facts. None will involve
MURPHY ROSEN LLP
14 NDAs that prohibit Jolie from speaking about Pitt’s abuse of her and their children. Forcing
15 Jolie to spend the time and expense of gathering and producing all of this documentation is
16 expensive, wasteful, and unreasonable—and the latest manifestation of Pitt’s abusive conduct
17 toward Jolie. The Court should not allow it.
19 DOCUMENTS and COMMUNICATIONS CONCERNING YOUR reasons for
20 entering or agreeing to any non-disclosure or non-disparagement agreements to which YOU
21 are a party.
24 grounds: (a) the use of the term “concerning,” standing alone and as defined by Plaintiffs,
25 renders the request grossly overbroad in time and scope; (b) the request is overbroad as any
26 non-disclosure and non-disparagement agreements other than those between Jolie and Pitt
27 entered after Pitt’s physical and emotional abuse of Jolie and their children have no relevance
28 to this case; (c) the request seeks documents protected from disclosure by the attorney-client

1 privilege [and] the work product doctrine; and (d) for the parties to any such agreements, the
2 request seeks documents protected from disclosure by their rights of privacy under the
3 Constitution of the State of California.
5 Jolie will produce any non-privileged documents and communications discussing or
6 referencing Jolie’s reasons for entering into non-disclosure and non-disparagement agreements
7 between Jolie and Pitt, entered after Pitt’s physical and emotional abuse of Jolie and their
8 children, regarding their personal conduct.
11 As an initial matter, Jolie objects that the defined term “CONCERNING” renders this
12 Request grossly overbroad in time and scope. For the avoidance of doubt, this Request seeks
13 only documents that set forth or explicitly reference Jolie’s reasons for entering or agreeing to
MURPHY ROSEN LLP
14 NDAs during the same time period for which she has agreed to produce documents in response
15 to other requests—not all documents that could conceivably relate to her thought process at the
16 time, let alone those concerning the underlying facts or events that may be covered by the
17 NDAs.

8 served this Request seeking those documents setting forth or referring to the reasons why Jolie
9 agreed to enter into NDAs with third parties. These documents are probative of whether Jolie
10 actually viewed the provision requested by Pitt and Perrin as an “abusive and controlling deal-
11 breaker” that released her of any contractual obligations to Pitt. Jolie unsurprisingly wants to
12 shield these documents from discovery, and therefore agreed to produce only those NDAs, if
13 any, between Jolie and Pitt themselves. Jolie adamantly refuses to produce other NDAs that
MURPHY ROSEN LLP
14 she willingly entered into during the relevant time period, presumably because she knows they
15 will severely undermine her defenses. Specifically, these documents are probative of Jolie’s
16 views about the many legitimate reasons for entering into NDAs—for instance, to avoid
17 negative publicity that could harm a business (i.e., the very reason that Pitt pleads he and
18 Perrin sought the non-disparagement provisions at issue here). Evidence that Jolie entered into
19 NDAs covering similar subjects for similar reasons as Pitt would, among other things,
20 undermine her contention that Pitt’s request rendered their implied-in-fact contract
21 unconscionable as a matter of public policy, a defense that is legally deficient in any event, but
22 which Jolie submits is at “the very heart of the case.” Accordingly, these documents should be
23 produced.

6 justify discovery.” Lipton, 48 Cal. App. 4th at 1616.
12 seeks to compel the production of over 16 years’ worth of “documents and communications”
13 about contracts to which Jolie was a party where the contract includes an NDA—specifically
MURPHY ROSEN LLP
14 demanding every “document and communication” reflecting the reason why she considered or
15 entered an NDA with any person over this time period. According to Pitt, Jolie’s reasons for
16 agreeing to other NDAs with other people about other matters will probe whether Jolie was
17 genuinely offended by Pitt asking for an NDA that prohibited Jolie from speaking about abuse
18 she and their children suffered at Pitt’s hands.
20 equate reasons Jolie entered NDAs that do not cover Pitt’s abuse of their family with the NDA
21 Pitt himself demanded specifically to cover-up his own abuse of Jolie and their children.
22 There is no connection between them at all—none. For this reason, these documents and
23 communications about other NDAs Jolie entered do not probe Jolie’s veracity regarding the
24 impact of Pitt’s proposed NDA in any way. And contrary to Pitt’s suggestion, Jolie does not
25 contend in her Cross-Complaint that all NDAs are bad or problematic, and she does not seek
26 such a blanket ruling in this case. To the contrary, Jolie was at all times agreeable to the
27 original NDA Pitt proposed that was limited to the winery. It was only after Pitt changed the
28 language to cover his personal abuse of the family that Jolie objected. Indeed, there is a stark

1 difference between an NDA Jolie entered with a movie studio or an employee, and the last-
2 minute, expanded NDA her abusive ex-husband tried to force her to sign to bury his criminal
3 conduct.
4 Pitt’s related argument that the reasons Jolie asked others to enter NDAs covering
5 aspects of her private life is probative of Pitt asking Jolie to be silent about the criminal
6 conduct he committed is a false equivalence. If Jolie hired someone to prepare meals for her
7 family inside her home and asked that person to enter an NDA so the person would not
8 disclose to the tabloids what her family ate every day (Motion at 14), that particular NDA has
9 no relevance to how Jolie felt when Pitt asked her to sign an NDA silencing her from speaking
10 about her own life and the painful events she experienced at Pitt’s hands.
MURPHY ROSEN LLP
16 “documents and communications” relating to these other NDAs clearly outweighs the
17 likelihood that the information sought will lead to the discovery of admissible evidence.
18 Moreover, if the Court concludes that the evidence is relevant and admissible, this will then
19 result in a series of mini-trials for each and every NDA and related “documents and
20 communications” Pitt hopes to use. The Court is never going to allow such mini-trials. As a
21 result, the documents are not only irrelevant, but they are also not likely to lead to the
22 discovery of admissible evidence.
23 In fact, Pitt’s proposed argument is going to be barred by Evidence Code sections 786,
24 787 and 1101(a). Section 786 states that evidence “of traits of his character other than honesty
25 or veracity, or their opposites, is inadmissible to attack or support the credibility of a witness.”
26 Section 787 states that, aside from prior felony convictions, “Evidence of specific instances of
27 his conduct relevant only as tending to prove a trait of his character is inadmissible to attack or
28 support the credibility of a witness.” And Section 1101(a) states that “evidence of a person’s

1 character or a trait of his or her character (whether in the form of an opinion, evidence of
2 reputation, or evidence of specific instances of his or her conduct) is inadmissible when
3 offered to prove his or her conduct on a specified occasion.” Pitt’s theory is barred by each of
4 these sections of the Evidence Code. He will not be able to use prior instances of Jolie’s
5 conduct (entering NDAs with other people about other matters) to prove that she should have
6 been fine with agreeing to his abusive NDA too.
7 Further, Pitt’s request is also overbroad as to time and scope. It seeks “documents and
8 communications” about all NDAs Jolie entered from January 1, 2007 through the present, but
9 Jolie contends the NDA Pitt proposed was problematic because it attempted to bury Pitt’s
10 abuse. There is no relevance to documents and communications about contracts she entered
11 into with other people covering issues unrelated to the abuse. At best, Pitt is entitled to
12 documents and communications concerning NDAs Jolie entered with Pitt, which Jolie has
13 agreed to give. Anything else is overbroad as to time and scope.

MURPHY ROSEN LLP
14 Pitt’s demand for nearly two decades worth of documents and communications about
15 these NDAs also intrudes on Jolie’s right of privacy. When assessing a claimed privacy right,
16 the “privacy interests [must] be specifically identified and carefully comparted with competing
17 or countervailing privacy and nonprivacy interests in a balancing test.” Hill v. Nat’l Collegiate
18 Athletic Ass’n, 7 Cal.4th 37-38 (1994). As a starting point, courts must first “place the burden
19 on the party asserting a privacy interest to establish its extent and seriousness of the
20 prospective invasion, and against that showing must weigh the countervailing interest the
21 opposing party identifies.” Williams v. Superior Court, 3 Cal.5th 531, 557 (2017). “In
22 weighing the privacy interests of the third party, the trial court should consider the nature of
23 the information sought, its inherent intrusiveness, and any specific showing for a need for
24 privacy, including any harm that disclosure of the information might cause.” In re Marriage
25 of Williamson, 226 Cal.App.4th 1303, 1319 (2014).
26 Here, most, if not all, of the NDAs will be employment-related contracts that include
27 Jolie’s compensation or compensation she paid to third parties. These third parties have their
28 own privacy rights. Pitt has not even offered to give any form of notice whatsoever to these

1 third-parties to allow them the opportunity to protect their rights, nor does he acknowledge that
2 these other persons and entities have privacy rights here.
3 Against this sensitive information, Pitt has little countervailing interest in obtaining
4 these documents. Moreover, any negligible relevance is greatly outweighed by Pitt’s intrusion
5 into Jolie’s and these third parties’ privacy rights, with the balance in favor of protecting
6 privacy rights—made all the more problematic by the fact that such evidence has virtually no
7 chance of being admitted at trial.
8 Pitt wants to argue that because Jolie agreed to enter NDAs with other people, she
9 could not have been bothered by the NDA Pitt demanded she sign. But each and every one of
10 these other NDAs involve separate people, different interests, and unique facts. None will
11 involve NDAs that prohibit Jolie from speaking about Pitt’s abuse of her and their children.
12 Forcing Jolie to spend the time and expense of gathering and producing all of this
13 documentation is expensive, wasteful, and unreasonable—and the latest manifestation of Pitt’s

MURPHY ROSEN LLP
14 abusive conduct toward Jolie. The Court should not allow it.
16 Any draft or executed non-disclosure or non-disparagement agreements that YOU, any
17 entity YOU control, or any PERSON acting on YOUR behalf, have requested or proposed that
18 any other PERSON sign or agree to, including non-disclosure or nondisparagement
19 agreements that were never signed or agreed to.
22 grounds: (a) the request is overbroad as any non-disclosure and non-disparagement agreements
23 other than those between Jolie and Pitt entered after Pitt’s physical and emotional abuse of
24 Jolie and their children have no relevance to this case; (b) the request seeks documents
25 protected from disclosure by the attorney-client privilege [and] the work product doctrine; and
26 (c) for the parties to any such agreements, the request seeks documents protected from
27 disclosure by their rights of privacy under the Constitution of the State of California.

1 Jolie will produce non-privileged drafts and executed non-disclosure and nondisparagement
2 agreements between Jolie and Pitt, entered after Pitt’s physical and emotional abuse of Jolie
3 and their children, regarding their personal conduct.
MURPHY ROSEN LLP
24 served this Request seeking NDAs to which Jolie requested third parties agree. These
25 documents are probative of whether Jolie actually viewed the provision requested by Pitt and
26 Perrin as an “abusive and controlling deal-breaker” that released her of any contractual
27 obligations to Pitt. Jolie unsurprisingly wants to shield these documents from discovery, and
28 therefore agreed to produce only those NDAs, if any, between Jolie and Pitt themselves. Jolie

1 adamantly refuses to produce other NDAs that she willingly entered into during the relevant
2 time period, presumably because she knows they will severely undermine her defenses.
3 Specifically, the scope, terms, and subject matter of NDAs that Jolie asked third parties
4 to enter into are highly relevant to Jolie’s defenses because they evidence non-disparagement
5 terms that Jolie believes are appropriate and not “unconscionable” to request from others. For
6 example, if Jolie conditioned her continued employment of an individual on that individual’s
7 agreement to an NDA covering what he or she witnessed in her home—including Pitt’s
8 treatment of her and her children—that would be highly probative of whether she truly
9 believed the provision requested by Pitt was an “unconscionable gag order.” The same is true
10 with respect to any NDA between Jolie and any third party with whom she is in a relationship
11 or who has assisted with the care of the couple’s children. To the extent that Jolie requested
12 this third party’s silence about her family or homelife, particularly in a circumstance where
13 there was no business justification, it would speak volumes about whether Jolie actually
MURPHY ROSEN LLP
14 viewed Pitt’s request linked to the Miraval business as the deal-ender she subsequently alleged
15 it to be. NDAs dealing with different subject matter are also likely to lead to admissible
16 evidence—namely, deposition testimony about why Jolie believed those subjects were
17 appropriate for NDAs while others were unconscionable. These documents should be
18 produced.

7 seeks to compel the production of over 16 years’ worth of contracts, whether executed or mere
8 drafts, where Jolie, any entity Jolie controls, or any of Jolie’s agents, proposed to include an
9 NDA in the contract. According to Pitt, these other NDAs with other people about other
10 matters unrelated to this lawsuit somehow test Jolie’s credibility because Jolie asserts that
11 Pitt’s agreement to buy her interest in Miraval fell apart when Jolie refused Pitt’s demand for
12 an NDA to cover Pitt’s physical and emotional abuse of Jolie and their children.
MURPHY ROSEN LLP
14 equate NDAs Jolie or entities she owned or controlled considered or entered that do not cover
15 Pitt’s abuse of their family with the personal NDA Pitt himself demanded to cover-up his own
16 abuse of Jolie and their children. There is no connection between them at all—none. For this
17 reason, other NDAs Jolie considered or entered with other people and entities do not probe
18 Jolie’s veracity regarding the impact of Pitt’s proposed NDA had on Jolie in any way. And
19 contrary to Pitt’s suggestion, Jolie does not contend in her Cross-Complaint that all NDAs are
20 bad or problematic, and she does not seek such a blanket ruling in this case. To the contrary,
21 Jolie was at all times agreeable to the original NDA Pitt proposed that was limited to the
22 winery. It was only after Pitt changed the language to cover his personal abuse of the family
23 that Jolie objected. Indeed, there is a stark difference between an NDA Jolie or an entity she
24 owned or controlled considered or entered with a movie studio, vendor, service professional or
25 an employee, and the last-minute, expanded NDA her abusive ex-husband tried to force her to
26 sign to bury his criminal conduct.
27 Pitt’s related argument that Jolie asking others to enter NDAs covering aspects of her
28 private life is probative of Pitt asking Jolie to be silent about the criminal conduct he

1 committed is a false equivalence. If Jolie hired someone to prepare meals for her family inside
2 her home and asked that person to enter an NDA so the person would not disclose to the
3 tabloids what her family ate every day (Motion at 14), that particular NDA has no relevance to
4 how Jolie felt when Pitt asked her to sign an NDA silencing her from speaking about her own
5 life and the painful events she experienced at Pitt’s hands. Even farther removed are actual
6 and draft NDAs with vendors and service professionals for Jolie’s businesses and business
7 interests.
13 contracts, even drafts that were never executed, clearly outweighs the likelihood that the
MURPHY ROSEN LLP
14 information sought will lead to the discovery of admissible evidence. Moreover, if the Court
15 concludes that the evidence is relevant and admissible, this will then result in a series of mini-
16 trials for each and every contract or draft contract Pitt hopes to use. The Court is never going
17 to allow such mini-trials. As a result, the documents are not only irrelevant, but they are also
18 not likely to lead to the discovery of admissible evidence.
19 In fact, Pitt’s use of these documents at trial will be separately barred by Evidence
20 Code sections 786, 787 and 1101(a) because this is improper character evidence. Section 786
21 states that evidence “of traits of his character other than honesty or veracity, or their opposites,
22 is inadmissible to attack or support the credibility of a witness.” Section 787 states that, aside
23 from prior felony convictions, “Evidence of specific instances of his conduct relevant only as
24 tending to prove a trait of his character is inadmissible to attack or support the credibility of a
25 witness.” And Section 1101(a) states that “evidence of a person’s character or a trait of his or
26 her character (whether in the form of an opinion, evidence of reputation, or evidence of
27 specific instances of his or her conduct) is inadmissible when offered to prove his or her
28 conduct on a specified occasion.” Pitt’s theory is barred by each of these sections of the

1 Evidence Code. He will not be able to use prior instances of Jolie’s and her businesses’
2 conduct (considering or entering other NDAs from other people about other matters) to prove
3 that Jolie should have been fine with agreeing to his abusive NDA too.
4 Further, Pitt’s request is also overbroad as to time and scope. It seeks all draft and final
5 NDAs Jolie considered from January 1, 2007 through the present, but Jolie contends the NDA
6 Pitt proposed was problematic because it attempted to bury Pitt’s abuse. There is no relevance
7 to NDAs Jolie or her businesses considered or entered with other people about issues unrelated
8 to the abuse. At best, Pitt is entitled to any NDAs Jolie entered or requested from Pitt, which
9 Jolie has agreed to give. Anything else is overbroad as to time and scope.
10 Pitt’s demand for nearly two decades worth of requested or entered NDAs from her and
11 her businesses also intrudes on Jolie’s right of privacy. When assessing a claimed privacy
12 right, the “privacy interests [must] be specifically identified and carefully comparted with
13 competing or countervailing privacy and nonprivacy interests in a balancing test.” Hill v.

MURPHY ROSEN LLP
14 Nat’l Collegiate Athletic Ass’n, 7 Cal.4th 37-38 (1994). As a starting point, courts must first
15 “place the burden on the party asserting a privacy interest to establish its extent and
16 seriousness of the prospective invasion, and against that showing must weigh the
17 countervailing interest the opposing party identifies.” Williams v. Superior Court, 3 Cal.5th
18 531, 557 (2017). “In weighing the privacy interests of the third party, the trial court should
19 consider the nature of the information sought, its inherent intrusiveness, and any specific
20 showing for a need for privacy, including any harm that disclosure of the information might
21 cause.” In re Marriage of Williamson, 226 Cal.App.4th 1303, 1319 (2014).
22 Here, most, if not all, of these proposed or entered agreements will be employment-
23 related contracts that include Jolie’s actual or proposed compensation or compensation she or
24 her businesses considered or paid to third parties. These third parties have their own privacy
25 rights. Pitt has not even offered to give any form of notice whatsoever to these third-parties to
26 allow them the opportunity to protect their rights, nor does he acknowledge that these other
27 persons and entities have privacy rights here. Against this sensitive information, Pitt has little
28 countervailing interest in obtaining these documents. Moreover, any negligible relevance is

1 greatly outweighed by Pitt’s intrusion into Jolie’s and these third parties’ privacy rights, with
2 the balance in favor of protecting privacy rights—made all the more problematic by the fact
3 that such evidence has virtually no chance of being admitted at trial.
4 Pitt wants to argue that because Jolie and her businesses considered or entered NDAs
5 with other people, she personally could not have been bothered by the NDA Pitt demanded she
6 sign. But each and every one of these other NDAs involve separate people, different interests,
7 and unique facts. None will involve NDAs that prohibit Jolie from speaking about Pitt’s abuse
8 of her and their children. Forcing Jolie to spend the time and expense of gathering and
9 producing all of this documentation is expensive, wasteful, and unreasonable—and the latest
10 manifestation of Pitt’s abusive conduct toward Jolie. The Court should not allow it.
12 All DOCUMENTS and COMMUNICATIONS CONCERNING the reasons that YOU,

13 any entity YOU control, or any PERSON acting on YOUR behalf, requested or proposed that
MURPHY ROSEN LLP
14 any other PERSON sign or agree to any non-disclosure or nondisparagement agreements,
15 including non-disclosure or non-disparagement agreements that were never signed or agreed
16 to.
19 grounds: (a) the use of the term “concerning,” standing alone and as defined by Plaintiffs,
20 renders the request grossly overbroad in time and scope; (b) the request is overbroad as any
21 non-disclosure and non-disparagement agreements other than those between Jolie and Pitt
22 entered after Pitt’s physical and emotional abuse of Jolie and their children have no relevance
23 to this case; (c) the request seeks documents protected from disclosure by the attorney-client
24 privilege [and] the work product doctrine; and (d) for the parties to any such agreements, the
25 request seeks documents protected from disclosure by their rights of privacy under the
26 Constitution of the State of California.
28 Jolie will produce any non-privileged documents and communications discussing or

1 referencing Jolie’s reasons for entering into proposed or entered non-disclosure and non-
2 disparagement agreements between Jolie and Pitt, entered after Pitt’s physical and emotional
3 abuse of Jolie and their children, regarding their personal conduct.
6 As an initial matter, Jolie objects that the defined term “CONCERNING” renders this
7 Request grossly overbroad in time and scope. For avoidance of doubt, this Request seeks only
8 documents that set forth or explicitly reference Jolie’s reasons for entering or agreeing to
9 NDAs during the same time period for which she has agreed to produce documents in response
10 to other requests—not all documents that could conceivably relate to her thought process at the
11 time, let alone those concerning the underlying facts of events that may be covered by the
12 NDAs.
MURPHY ROSEN LLP

3 served this Request seeking a narrow set of documents setting forth or referring to the reasons
4 why Jolie proactively requested NDAs from third parties. These documents are probative of
5 whether Jolie actually viewed the provision requested by Pitt and Perrin as an “abusive and
6 controlling deal-breaker” that released her of any contractual obligations to Pitt. Jolie
7 unsurprisingly wants to shield these documents from discovery, and therefore agreed to
8 produce only those NDAs, if any, between Jolie and Pitt themselves. Jolie adamantly refuses
9 to produce other NDAs that she willingly entered into during the relevant time period,
10 presumably because she knows they will severely undermine her defenses.
11 Specifically, these documents setting forth or referring to the reasons why Jolie
12 proactively requested NDAs from third parties are probative of Jolie’s views about the many
13 legitimate reasons for entering into NDAs—for instance, to avoid negative publicity that could
MURPHY ROSEN LLP
14 harm a business (i.e., the very reason that Pitt pleads he and Perrin sought the non-
15 disparagement provisions at issue here). Evidence that Jolie entered into NDAs covering
16 similar subjects for similar reasons as Pitt would undermine her contention that Pitt’s request
17 rendered their implied-in-fact contract unconscionable as a matter of public policy, a defense
18 that is legally deficient in any event, but which Jolie submits is at “the very heart of the case.”
19 Accordingly, these documents should be produced.

8 seeks to compel the production of over 16 years’ worth of “documents and communications”
9 about contracts where Jolie, any of her companies, or her agents, proposed to include an NDA
10 in a contract, whether that contract was ever executed or not—specifically demanding every
11 document reflecting the reason why Jolie and her businesses sought or agreed to an NDA with
12 any person over this time period. According to Pitt, Jolie’s and her businesses’ reasons for
13 requesting other NDAs from other people about other matters will probe whether Jolie was
MURPHY ROSEN LLP
14 genuinely offended by Pitt asking for an NDA that prohibited Jolie from personally speaking
15 about abuse she and their children suffered at Pitt’s hands. Even farther removed are actual
16 and draft NDAs with vendors and service professional for Jolie’s businesses and business
17 interests.
19 equate reasons Jolie and her businesses requested NDAs that do not cover Pitt’s abuse of their
20 family with the NDA Pitt himself demanded specifically to cover-up his own abuse of Jolie
21 and their children. There is no connection between them at all—none. For this reason, these
22 communications about other NDAs Jolie requested do not probe Jolie’s veracity regarding the
23 impact of Pitt’s proposed NDA in any way. And contrary to Pitt’s suggestion, Jolie does not
24 contend in her Cross-Complaint that all NDAs are bad or problematic, and she does not seek
25 such a blanket ruling in this case. To the contrary, Jolie was at all times agreeable to the
26 original NDA Pitt proposed that was limited to the winery. It was only after Pitt changed the
27 language to cover his personal abuse of the family that Jolie objected. Indeed, there is a stark
28 difference between an NDA Jolie or her businesses proposed or entered with a movie studio,

1 vendor, service professional or employee, and the last-minute, expanded NDA her abusive ex-
2 husband tried to force her to sign to bury his criminal conduct.
3 Pitt’s related argument that the reasons Jolie asked others to enter NDAs covering
4 aspects of her private life is probative of Pitt asking Jolie to be silent about the criminal
5 conduct he committed is a false equivalence. If Jolie hired someone to prepare meals for her
6 family inside her home and asked that person to enter an NDA so the person would not
7 disclose to the tabloids what her family ate every day (Motion at 14), that particular NDA has
8 no relevance to how Jolie felt when Pitt asked her to sign an NDA silencing her from speaking
9 about her own life and the painful events she experienced at Pitt’s hands.
MURPHY ROSEN LLP
15 documents and communications clearly outweighs the likelihood that the information sought
16 will lead to the discovery of admissible evidence. Moreover, if the Court concludes that the
17 evidence is relevant and admissible, this will then result in a series of mini-trials for each and
18 every proposed and actual contract—as well as related “documents and communications”—
19 Pitt hopes to use. The Court is never going to allow such mini-trials. As a result, the
20 documents are not only irrelevant, but they are also not likely to lead to the discovery of
21 admissible evidence.
22 In fact, Pitt’s proposed argument is going to be barred by Evidence Code sections 786,
23 787 and 1101(a). Section 786 states that evidence “of traits of his character other than honesty
24 or veracity, or their opposites, is inadmissible to attack or support the credibility of a witness.”
25 Section 787 states that, aside from prior felony convictions, “Evidence of specific instances of
26 his conduct relevant only as tending to prove a trait of his character is inadmissible to attack or
27 support the credibility of a witness.” And Section 1101(a) states that “evidence of a person’s
28 character or a trait of his or her character (whether in the form of an opinion, evidence of

1 reputation, or evidence of specific instances of his or her conduct) is inadmissible when
2 offered to prove his or her conduct on a specified occasion.” Pitt’s theory is barred by each of
3 these sections of the Evidence Code. He will not be able to use prior instances of Jolie’s and
4 her businesses’ conduct (requesting NDAs from other people about other matters) to prove that
5 she should have been fine with agreeing to his abusive NDA too.
6 Further, Pitt’s request is also overbroad as to time and scope. It seeks all documents
7 and communications about all NDAs Jolie and her businesses requested from January 1, 2007
8 through the present, but Jolie contends the NDA Pitt proposed was problematic because it
9 attempted to bury Pitt’s abuse. There is no relevance to communications about Jolie’s and her
10 businesses’ requested or entered NDAs with other people about issues unrelated to the abuse.
11 At best, Pitt is entitled to communications concerning NDAs Jolie entered with Pitt, which
12 Jolie has agreed to give. Anything else is overbroad as to time and scope.
13 Pitt’s demand for nearly two decades worth of communications also intrudes on Jolie’s
MURPHY ROSEN LLP
14 right of privacy. When assessing a claimed privacy right, the “privacy interests [must] be
15 specifically identified and carefully comparted with competing or countervailing privacy and
16 nonprivacy interests in a balancing test.” Hill v. Nat’l Collegiate Athletic Ass’n, 7 Cal.4th 37-
17 38 (1994). As a starting point, courts must first “place the burden on the party asserting a
18 privacy interest to establish its extent and seriousness of the prospective invasion, and against
19 that showing must weigh the countervailing interest the opposing party identifies.” Williams v.
20 Superior Court, 3 Cal.5th 531, 557 (2017). “In weighing the privacy interests of the third
21 party, the trial court should consider the nature of the information sought, its inherent
22 intrusiveness, and any specific showing for a need for privacy, including any harm that
23 disclosure of the information might cause.” In re Marriage of Williamson, 226 Cal.App.4th
24 1303, 1319 (2014).
25 Here, most, if not all, of these documents and communications will concern
26 employment-related contracts that include Jolie’s compensation or compensation she or her
27 businesses paid to third parties. These third parties have their own privacy rights. Pitt has not
28 even offered to give any form of notice whatsoever to these third-parties to allow them the

1 opportunity to protect their rights, nor does he acknowledge that these other persons and
2 entities have privacy rights here.
3 Against this sensitive information, Pitt has little countervailing interest in obtaining
4 these documents. Moreover, any negligible relevance is greatly outweighed by Pitt’s intrusion
5 into Jolie’s and these third parties’ privacy rights, with the balance in favor of protecting
6 privacy rights—made all the more problematic by the fact that such evidence has virtually no
7 chance of being admitted at trial.
8 Pitt wants to argue that because over the last two decades, Jolie and her businesses
9 proposed or entered NDAs with other people, she could not have been bothered by the NDA
10 Pitt demanded she sign. But each and every one of these other NDAs involve separate people,
11 different interests, and unique facts. None will involve NDAs that prohibit Jolie from
12 speaking about Pitt’s abuse of her and their children. Forcing Jolie to spend the time and
13 expense of gathering and producing all of this documentation is expensive, wasteful, and
MURPHY ROSEN LLP
14 unreasonable—and the latest manifestation of Pitt’s abusive conduct toward Jolie. The Court
15 should not allow it.
16
17 DATED: April 25, 2024 MURPHY ROSEN LLP
18
19 By:
Paul D. Murphy
20 Daniel N. Csillag
Stella Chang
21 Attorneys for Defendant and
Cross-Complainant Angelina Jolie
22
23
24
25
26
27
28

1 PROOF OF SERVICE
2 I, Christina M. Garibay, declare:
3 I am employed in the County of Los Angeles, State of California. I am over the age of
18 and not a party to this action. My business address is 100 Wilshire Boulevard, Suite 1300,
4 Santa Monica, California 90401-1142, (310) 899-3300.
5 On April 25, 2024, I served the document(s) described as DEFENDANT AND

CROSS-COMPLAINANT ANGELINA JOLIE’S RESPONSIVE SEPARATE
6 STATEMENT IN SUPPORT OF OPPOSITION TO PLAINTIFFS’ MOTION TO
COMPEL FURTHER RESPONSES AND PRODUCTION OF DOCUMENTS on the
7 interested parties in this action:
8
SEE ATTACHED SERVICE LIST
9
10 BY ELECTRONIC SERVICE: I caused the above-document(s) to be served via the

Los Angeles Superior Court’s electronic service provider, One Legal.
11
BY E-MAIL: Based on a court order or an agreement of the parties to accept service
12 by e-mail or electronic transmission, I caused the documents to be sent to the persons at the
email addresses listed above or on the attached service list. I did not receive within a
13 reasonable time after the transmission, any electronic message or other indication that the
MURPHY ROSEN LLP
transmission was unsuccessful.

14
[State] I declare under penalty of perjury under the laws of the State of California that
15 the above is true and correct.
16 Executed on April 25, 2024, at Santa Monica, California.
17
18 Christina M. Garibay
19
20
21
22
23
24
25
26
27
28

PROOF OF SERVICE
1 SERVICE LIST
2 William B. Pitt, et al. v. Angelina Jolie, et al.

Los Angeles Superior Court Case No. 22STCV06081
3
John V. Berlinski Attorneys for Plaintiffs and Cross-
4 BIRD MARELLA RHOW LICENBERG Defendants William B. Pitt, Mondo Bongo,
DROOKS & NESSIM LLP LLC and Cross-Defendant Warren Grant
5 1875 Century Park East, 23rd Floor
6 Los Angeles, CA 90067
T: (310) 201-2100 F: (310) 201-2110
7 [email protected]
[email protected]
8 [email protected]
[email protected]
9 [email protected]
[email protected]
10 [email protected]
[email protected]
11
Jonathan Moses (admitted pro hac vice)
12 Adam L. Goodman (admitted pro hac vice)
Jessica L. Layden (admitted pro hac vice)

13 Ioannis D. Drivas (pending pro hac vice

MURPHY ROSEN LLP
application)
14
WACHTELL, LIPTON, ROSEN & KATZ
15 51 West 52nd Street
New York, NY 10019
16 T: (212) 403-1000 F: (212) 403-2000
[email protected]
[email protected]
18
[email protected]
19
Mark T. Drooks Attorneys appearing specially to challenge
20 BIRD MARELLA RHOW LICENBERG jurisdiction on behalf of Cross-Defendants
DROOKS & NESSIM LLP Marc-Olivier Perrin, SAS Miraval
21 1875 Century Park East, Suite 2300 Provence, SAS Miraval Studios, SAS
Los Angeles, CA 90067 Familles Perrin, SAS Distilleries de la
22
Tel: (212) 957-7600 Riviera, Sas Petrichor, SASU Le Domaine,
23 [email protected] and Vins et Domaines Perrin SC
24
25
26
27
28

PROOF OF SERVICE
1 S. Gale Dick (admitted pro hac vice) Attorneys appearing specially to challenge
COHEN & GRESSER jurisdiction on behalf of Cross-Defendants
2 800 Third Ave. Marc-Olivier Perrin, SAS Miraval
New York, NY 10022 Provence, and SAS Familles Perrin
3
[email protected]
4
6
Joe H. Tuffaha Attorneys for Defendant and Cross-
7 Prashanth Chennakesavan Complainant Nouvel, LLC and appearing
LTL ATTORNEYS LLP specially to challenge jurisdiction on
8 300 South Grand Avenue Suite 1400 behalf of Defendant Tenute del Mondo
Los Angeles, CA 90071 B.V., SPI Group Holding, Ltd., Yuri
9 T: (213) 612-8900 F: (213) 612-3773 Shelfer and Alexey Oliynik
[email protected]
10
[email protected]
11
Keith R. Hummel
12 Justin C. Clarke
Jonathan Mooney
13 CRAVATH SWAINE AND MOORE LLP

MURPHY ROSEN LLP
825 Eighth Avenue

14
New York, NY 10019
15 T: (212) 474-1000 F: (212) 474-3700
[email protected]
[email protected]
17
18
19
20
21
22
23
24
25
26
27
28

PROOF OF SERVICE

State

Uploaded by

Copyright:

Available Formats

State

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

State

Uploaded by

Copyright:

Available Formats

1 PAUL D. MURPHY (State Bar No.

7 Attorneys for Defendant and Cross-Complainant

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

MONDO BONGO, LLC, a California

13 limited liability company, [Hon. Lia Martin]

14 Plaintiffs, DEFENDANT AND CROSS-

21 Date: May 16, 2024

PRINTED ON RECYCLED PAPER

2 Separate Statement in Support of Opposition to Plaintiffs Motion to Compel Further

3 Responses and Production of Documents opposition to Plaintiff and Cross-Defendants

6 Production (the “Requests”).

7 REQUEST FOR PRODUCTION NO. 1:

8 All non-disclosure or non-disparagement agreements to which YOU are a party.

9 JOLIE’S RESPONSE TO REQUEST FOR PRODUCTION NO. 1:

20 their personal conduct.

21 PLAINTIFFS’ FACTUAL AND LEGAL REASONS FOR COMPELLING FURTHER

22 RESPONSE AND PRODUCTION:

27 Jolie—not Pitt—places an oversized emphasis on the importance of non-disparagement

-2- PRINTED ON RECYCLED PAPER

11 his part, asserts that these claims are pretextual.

-3- PRINTED ON RECYCLED PAPER

13 JOLIE’S RESPONSE TO PLAINTIFFS’ FACTUAL AND LEGAL REASONS FOR

14 COMPELLING FURTHER RESPONSE AND PRODUCTION:

16 burden to make a “fact-specific showing of relevance” concerning the documents he seeks.

19 where the contract includes either a non-disparagement agreement or a non-disclosure

-4- PRINTED ON RECYCLED PAPER

8 to sign to bury his criminal conduct.

15 painful events she experienced at Pitt’s hands.

-5- PRINTED ON RECYCLED PAPER

6 her character (whether in the form of an opinion, evidence of reputation, or evidence of

11 agreeing to his abusive NDA too.

17 overbroad as to time and scope.

28 might cause.” In re Marriage of Williamson, 226 Cal.App.4th 1303, 1319 (2014).

-6- PRINTED ON RECYCLED PAPER

17 toward Jolie. The Court should not allow it.

18 REQUEST FOR PRODUCTION NO. 2:

19 DOCUMENTS and COMMUNICATIONS CONCERNING YOUR reasons for

20 entering or agreeing to any non-disclosure or non-disparagement agreements to which YOU

22 JOLIE’S RESPONSE TO REQUEST FOR PRODUCTION NO. 2:

-7- PRINTED ON RECYCLED PAPER

3 Constitution of the State of California.

5 Jolie will produce any non-privileged documents and communications discussing or

8 children, regarding their personal conduct.

9 PLAINTIFFS’ FACTUAL AND LEGAL REASONS FOR COMPELLING FURTHER

10 RESPONSE AND PRODUCTION:

22 Jolie—not Pitt—places an oversized emphasis on the importance of non-disparagement

-8- PRINTED ON RECYCLED PAPER

6 his part, asserts that these claims are pretextual.

-9- PRINTED ON RECYCLED PAPER

6 justify discovery.” Lipton, 48 Cal. App. 4th at 1616.

7 JOLIE’S RESPONSE TO PLAINTIFFS’ FACTUAL AND LEGAL REASONS FOR

8 COMPELLING FURTHER RESPONSE AND PRODUCTION:

10 burden to make a “fact-specific showing of relevance” concerning the documents he seeks.

18 she and their children suffered at Pitt’s hands.

-10- PRINTED ON RECYCLED PAPER

22 discovery of admissible evidence.

25 or veracity, or their opposites, is inadmissible to attack or support the credibility of a witness.”

-11- PRINTED ON RECYCLED PAPER

2 reputation, or evidence of specific instances of his or her conduct) is inadmissible when

6 been fine with agreeing to his abusive NDA too.