Each require to be modified 5

1. Each require to be modified
Declaration…John A Redmond
Declaration… Maureen C. Redmond
Declaration …Geraldine Redmond
This is a response to Second Amended Complaint Objecting to Discharge of
Debtor—General Allegations.
1. The “30 acre” equestrian facility was not “fully equipped”.
2.There was not a full-sized outdoor polo arena on the facility in September
2001.
3. We have stated in other declarations that parents have no knowledge until
2005 that Geraldine had submitted a credit application to Sulphur Mountain.
4. John A. Redmond has submitted a declaration on Georgia Jorden which
must question the validity of the Georgia Jorden declaration and “so-called”
eviction.
5. The Redmond parents have never been evicted or sued. There were no
judgements against us.
6. Parents told Gaggero that they were in the process of refinancing their
house and that they would give a loan to Geraldine Redmond. This loan of
$30.571.47 was given to her in January 2002.
7. John and Maureen Redmond explained their limited means with six
children and with one of their daughters having a chronic anxiety,
swallowing, panic attack disorder. Consequently it was completely
impossible that we would agree that we “would pay the security deposit,
pay the lease payments, and pay the business overhead until the company
was running on its own at a profit”.
8.Parents as “guarantors”. Unable to find any clause in the contract that they
would be liable for structural “improvements” of approximately $100,000. It
would appear that much of these improvements were because equestrian
facility was not “fully equipped”.
9. Geraldine, sole manager of Somerset Farms LLC sought legal advice on
termination of boarders in October 2002.
10. We have stated in another declaration that the Revenue Generating
clause “RGA” in the lease was not triggered, and Somerset Farms owed no
“RGA” to Sulphur Mountain. In fact, Sulphur Mountain incorrectly withheld
about $9,000 of so-called “RGA” payments from Somerset Farms LLC.
11. Sulphur Mountain made many wild projections as to money owed by
Somerset Farms LLC. There were no final numbers from Marsha Adamson,
the approved bookkeeper, until November 2002.

2. 12. There was a meeting with Gaggero on September 21, 2002. Redmond
parents knew little of what was going on, and were mere spectators to the
nasty confrontation between Gaggero and Marsha Adamson. Gaggero had
great difficulty understanding that Somerset Farms LLC had a significant
loss and was only surviving due to the funds that the parents were lending
Geraldine, plus loans to Somerset Farms LLC from Geraldine, obtained
from her personal training business.
13. When we finally received final bookkeeping from Marsha Adamson, it
was passed on to Chatfield.
14. At the Sept. 21, 2002 meeting we had no final financial figures, so it
would have been impossible “to propose a plan to get caught up on the rent”.
In fact Somerset Farms LLC was not behind on the rent. Timely payments
through September 2002. the overpayment of $9,000 of so-called “RGA”,
plus $16,000 of security deposits, confirmed the positive position.
15. A declaration from Geraldine confirms that the assets she removed from
the facility were her personal property and not Sulphur Mountain nor
Somerset Farms LLC property, and she did not remove them “secretly”, but
in full view , as she had been able to get a restraining order against Gaggero.
16. Somerset Farms LLC manager, Geraldine Redmond, with legal advice,
had terminated all boarders. This termination was immediate. However,
Sulphur Mountain/Gaggero encouraged boarders to stay at the facility until
the end of 2002, when he made a new contract with them. Therefore all
maintenance and repair expenses were the responsibility of Sulphur
Mountain/Gaggero.
17. Any boarder deposits that were with Somerset Farms LLC were none of
the landlord’s business.
18. The final issue of the issuance of a writ of attachment was with highly
improper communication and notification.
19. Somerset Farms LLC and the Redmonds had no alternative than to take
all the steps we have taken, because Sulphur Mountain/Gaggero incurred
$30,000 legal expenses in October 2002 and over $100,00 by April/May
2003, and a final $617,000 to the Ventura County Superior Court.
I have personal knowledge of the above facts and if called as a witness
I could and would competently so testify. I declare under penalty of perjury
that the above is true and correct.
I make this declaration on August 8. 2009 in Los Angeles County.
declarant