SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                       FOR THE COUNTY OF  LOS ANGELES

          SOCIETE CIVILE SUCCESSION RICHARD )                 Case No.    BS059900          
         GUINO, a French Trust, ALAN RENOIR, an

   individual, as the sole heir of Jean Renoir, and                     PETITION FOR ENTRY OF A
   JACQUES RENOIR, an individual, as the heir                     CALIFORNIA COURT JUDGMENT
    of one-half of Claude Renoir, Jr.’s estate,                           UNDER THE UNIFORM FOREIGN-
                                                                                         JUDGMENT RECOGNITION ACT

   RED STAR CORPORATION, a British  Virgin)
   Islands corporation, JEAN-EMMANUEL
   RENOIR, an individual, LOUISE
   HERNANDEZ, an individual,                               


    Petitioners Socite Civile Succession Richard Guino (‘SOCIETE Civile”), Alain  Renoir and Jacques Renoir 
respectfully submit this petition to obtain a California Judgment  against respondents based upon entry of a foreign judgment, as more fully set forth below:

                                              THE HISTORICAL BACKGROUND
   In 1969, Richard Guino, the assistant of the famous French painter Pierre-Auguste  Renoir, filed suit in France 
Against the Renoir estate seeking a determination of ”comnaon authorship” as to the Renoir statues on which he
collaborated with Pierre-Auguste Renoir. The Supreme Court in France decreed in 1973 that the Renoir statues were 
co-authored by Richard  Guino and awarded the Guino family one-half interest in those statues

            In 1982, the Guinos and Renoirs entered into an agreement to implement the Court  judgment. The agreement (known as the Convention) provides that the Guino family is to control   production, quality control and custody of the original plaster casts relative to the pertinent statues. 

 The Convention also provides that the Renoirs agree to ‘give all plasters tat they hold” to the   caster “SUSSE.” Under the Convention, the Guinos were given exclusive rights to create  subsequent editions, and the Renoir successors renounced the right to produce and market these  sculptures.

                                      THE BACKGROUND OF THE FRENCH LITIGATION

        On April 18, 1995, the Guino family, by and through Socite Civile, brought suit in the  District Court at Paris (hereinafter referred to as “the French Action”) against Jean-Emmanuel.
Renoir, Claude Renoir, Jr., Dido Renoir, The Galley Rodeo, Paul Renoir and Louis Hernandez.’
Each of the defendants named in the French Action received actual notice of the  complaint and had an opportunity to defend themselves. Indeed, defendants Jean-Emmanuel

 Renoir, Red star Corporation, Louis Hernandez, Paul Renoir and Mrs. Sophie Renoir-Doisne were
 represented in the French Action by counsel.
 The French Action arose from the sale and distribution by respondents of counterfeit  Guino/Renoir statues. In that suit, Socite Civile alleged (and the Paris Court later found) tat the statues were either outright counterfeits or works made from illegally retained casts in violation of Article 122-4 of the French Literary and Artistic Property Code. Article 122-4 of that French  statute prohibits a fill or partial reproduction of a work without the authorization of the author or his legal representative.

During the course of the French Action, it was revealed that Mr. Alain Renoir (the sole

heir to the estate of Dido Renoir and Jean Renoir) and Mr. Jacques Renoir (the heir of cine-haif of Claude Renoir, Jr.’s estate) had no involvement in any wrongful actions. As a consequence, those  parties voluntarily realigned themselves as party-plaintiffs and joined Socite Civile in the litigation as co-plaintiffs against the remaining defendants Jean-Emmanuel Renoir, Red star

Corporation, Louise Hernandez, The Gallery Rodeo, Mr. Paul Renoir, and Mi-s. Sophie Renoir­Doisne.


On April 8,1998, the District Court at Paris, 3d Chamber, Section 2, rendered a  Judgment against respondents arising from their sale and distribution of counterfeit Renoir/Guino  statues in the United States. A true and correct certified copy of the April 8 Judgment and its  English translation are collectively attached hereto as Exhibits A and B. . Pursuant to the April 8 Judgment, the French District Court found in pertinent part as
 S follows: (I) “the production and marketing of the sculptures from shared works by Richard  GUINO and Pierre Auguste RENOIR,2 without the authorization of their beneficiaries,  constitutes acts of forgery,” (2) “REDSTAR CORPORATION and the RODEO GALLERY, by  producing and/or marketing works made from the shared works of Messrs. RENOIR axid GUINO   have become jointly responsible,” and (3) “Mr. Jean-Emmanuel RENOIR and Mrs.  HERNANDEZ, by promoting forged castings and issuing certificates of authenticity have also  become jointly responsible 

 The April 8 Judgment ordered Jean-Emmanuel Renoir, Mrs. Louise Hernandez,  Red star Corporation (“Respondents”) and The Gallery Rodeo to pay to Socite Civile, Mr. Alain  Renoir and Mr. Jacques Renoir (“Petitioners”) “the amount of THREE MILLION FRANCS  (F 3,000,000).” Id. The April 8 Judgment also ordered Respondents “to pay the amount of  THIRTY THOUSAND FRANCS (F 30,000)” to Petitioners. Id. atp. 21. 

 In addition to awarding monetary damages, pursuant to articles 15 ad 16 of the Hague  Convention of March 18, 1970, the April 8 Judgment directs the issuance of Letters Rogatory  requiring Respondents to ‘submit all accounting elements in support of the castings undertaken of the works, [including] the log of castings, the sales accounting, and any specific detail on the  nature of the promotion and distribution transactions undertaken.” Id.

 Respondents were notified of entry of the April 8 Judgment.

The pertinent works are
Head of Little Venus”, “Medium Washwoman”, “Head of’   Venus Vetrix”, “Bust of Mrs. Renoir”, "Large Maternity”, “Bust of Paris”, “Little Standing Venus and base of the Judgment of Paris” and “The Blacksmith” (collectively, the “Works”).

*** Respondents have failed to pay any amounts due and owing under the April 8 Judgment arid have otherwise failed to comply with their executory obligations there under.

The April 8 Judgment is final, conclusive and enforceable. It has not been vacated,  modified, stayed, or set aside.
  By reason of the foregoing, Petitioners are entitled to enforcement of the April 8  Judgment in the United States.

                                                            PRAYER FOR RELIEF

WHEREFORE, Petitioners pray for entry of a Judgment by this Court that incorporates the   terms of the April 8 Judgment as follows:  For the sum of $ 488,560.00, which represents Three Million Francs (F 3,000,000)  as of April 8,1998, together with interest thereon at the legal rate from April 8, 1998;  For the sum of$ 4,885.60, which represents Thirty Thousand Francs (P30,000) as of April 8, 1998, together with interest thereon at the legal rate from April 8, 1998;

 For the issuance of Letters Rogatory directing Respondents to submit all accounting elements in support of the castings undertaken of the Works, a log of the castings, an  accounting of the sales, information on the promotion and distribution of the Works, and the name of the company (or companies) assigned to cast and store the Works;

For costs of suit herein incurred: and  For such other and further relief as the Court may deem proper.

Dated: October ,4, 1999                                       LOEB & LOEB LLP
                                                                          PETER S. SELVIN

                                                                           LISA L. HORLICK
                                                                           Attorneys for Petitioners
                                                                           Socite Civile Succession Richard Guino,
                                                                           Alain Renoir, and Jacques Renoir

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