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1. Declaration of Stephen M. Gaggero
I, Stephen M. Gaggero, declare as follows:
1. I am the managing director of Pacific Coast Management, Inc. ("PCM'), which is
an asset management company. One of the assets we manage is an equestrian facility
and 3,500 acres at the end of Canada Larga Road, for Sulphur Mountain Land and
Livestock Co., LLC. ("SMLLC").
2. In the fall of 2001, I negotiated a lease for the use of the equestrian facility
("Facility") with Geraldine Redmond, her father John Redmond, and her mother Maureen
Redmond, (the "Redmond's").
3. I am deeply offended and appalled by the temporary restraining order (TRO)
served on me at my home on the evening of October 8, 2002. I was served by two Ventura
County Sheriffs after they had spoken with most, if not all of the employees, residents and
clients at my office and the ranch, and while I was in a meeting with my accountant. This is
an embarrassment at best.
4. While I am not holding the Ventura County Sheriffs department or the court
responsible for this intrusion, if even a minor investigation had been ordered, it would have
shown, among other pertinent facts, that Geraldine (Jay) Redmond had recently sought
and obtained a TRO against her own husband, Jeff Ohaco, for his alleged "violent
behavior". This is the same man that she claims needs to be protected from me in her
petition for TRO. It would have also been found that she used much of the same
terminology in both of the petitions for TRO in order to obtain them immediately and without
question. (Please see petition for TRO against Jeff Ohaco attached hereto as exhibit "A")
5. The court would have also discovered that on the very day Geraldine was seeking
a TRO, counsel for PCM and SMLLC was filing a lawsuit and seeking a writ of attachment
against Geraldine and her parents for their default on their lease agreement with SMLLC,
their deceitful conduct, misappropriation of funds, refusal to pay over $60,000 due to
SMLLC and their clear and undeniable intent to cannibalize the equestrian facility and
abandon their thirty eight boarders and SMLLC. (Please see complaint and ex parte
application for writ of attachment attached hereto as exhibit "B").
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2. 6. Unfortunately, the writ of attachment was not issued until October 11, 2002, a
week too late, as Geraldine and her husband were able to damage, remove and secrete
assets from the equestrian facility day and night, without any fear that management might
stop them, as they had effectively restrained management by obtaining the TRO with false
statements. (See the declarations of Laurie Canty and Katrine Nielson attached hereto as
exhibits "C " and "D")
7. it is my opinion that Geraldine Redmond did not obtain the TRO because she
feared for her life, but simply to prevent me from being present while she damaged and
removed valuable assets from the Facility. Granting of the TRO has not only prevented me
from observing and documenting the conversion of property by Geraldine and her husband,
but it has also prevented me from being able to properly supervise and manage the asset
and repair and maintain the facility which she has apparently left in an unsafe and
deteriorating state. I have been unable to meet with maintenance staff or with the boarders
who are all in a state of panic. : he TRO ~vas also prevented me from accessing nearly 400
acres of pasture land which can only be accessed through the Facility. Geraldine and Jeff
have had experience in this, having been defendants in at least one prior unlawful detain&
action where they similarly left their premises in complete disrepair. (See the declaration of
former landlord Georgia Jordan attached hereto as exhibit "E")
8. The allegations about and against me that Geraldine Redmond made in her
petition for TRO are as far from the truth as one can possibly imagine and are horribly
slanderous to my personal character as well as my business reputation. I emphatically
deny each and every allegation made in the petition and Declaration of Geraldine Redmond
in support of the TRO. These allegations are untrue, unfounded, and wholly unsupported.
9. I would first like to address Geraldine's accusations of my being a "shady
businessman" that I have "1 1 names", and I that I am "currently under FBI investigation". I
am a professional, ethical and successful businessman. I have worked hard since a
teenager. I was a licensed general contractor and had my own company by the age of 19. I
began managing and investing in real property over twenty-five years ago. I make a
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3. meaningful contribution to society and the community through jobs, taxes, agriculture, and
charitable contributions. I support law enforcement agencies including the Ventura Police
Department Swat Team, who ! allow to use the Canada Larga facility for their long distance
sniper training. A dear friend for over twelve years, Diane McNair, is a detective on the Los
Angeles Police Department white-collar crime task force. Enclosed is her declaration as to
my business ethics and character. (Please see declaration of detective McNair attached
hereto as Exhibit "F").
10. In my life, I have only been known by my current name which was my name
given at birth, Stephen Michael Gaggero, and my adopted name from the age of 5,
Stephen Michael Blanchard. In 1993 I was reunited with my natural father. As a Christmas
gift to my family, I changed my name back to Gaggero. The court order became effective in
early 1994. (Please see order of the court re: name change attached hereto as Exhibit "G").
11. I am not, nor have I ever been under investigation by the FBI. My future father-
in-law, Dennis !_'/B:-ien, is a retired special agent of the FBI after having served fat over 25
years. After conducting his own inquiry at my request, he has assured me that G-_ ,ra!dine's
lle,gations are lintue and has made a declaration to that fact.
(Please see declaration of Dennis O'Brien attached hereto as Exhibit "H")
12. In response to Geraldine's description of the events that took place on
September 22nd, 24th, and October 3, 2002, I must first request the court read the
correspondence between the Redmond's, PCM, and me, dated September 11 th, 14th, 18th ,
20th. and 28th to fully understand the events leading up to these meetings (Please see
'otters dated September 11 th, 14th, 18th, 20th, and 28th attached hereto as Exhibits "11-5")
13. At all times from the inception of the lease in November 2001, until October 2,
2002, my desire, intent and actions were specifically to assist the Redmond's in their
efforts. Even after it became apparent that Geraldine had intentionally deceived her
parents, SMLLC and me, by among other things, failing to provide Somerset's books to
PCM. I believe she did this in order to conceal the fact that the Redmond's owed SMLLC
over $20,000 in percentage rent, to conceal the fact that she was writing bad checks to
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employees, suppliers, check cashing companies and others, totaling in excess of $10,000,
and to conceal the fact that she had spent the security deposits given to Somerset farms by
its 38 boarders.
14. To that end, on September 21 2002, at the meeting between the Redmond's,
Mark Maravelas (V.P. of finance for PCM) and me, at the request of Geraldine's father, I
agreed to work with the Redmond's to design a payment plan which would allow Geraldine
to pay the amounts due under the lease in monthly amounts and over a period of time she
could afford. Also at the request of Geraldine's father, I agreed to allow Geraldine to
continue living on the ranch with her 30 horses, 5 dogs, her son and her husband, even
after the lease had expired. Obviously, I had no motivation to treat Geraldine in any manner
except to be constructive and supportive. I had agreed to help devise a plan by which she
could live on the ranch as my neighbor, and to pay SMLLC as she could afford to.
15. Had I not agreed to entertain a plan by which Geraldine could repay the amounts
due over time and remain living on the ranch, i would have s:n-iply turned the matter over to
legal counsel for collection as her parents are jointly bound by the obligations of the lease.
Therefore, I would have had no reason to communicate with ,3eraldine on any of the dates
she alleges I conducted myself inappropriately. The only reason I communicated with
Geraldine after the meeting with Geraldine and her family on September 21st, was to work
out a payment plan that would help Geraldine get out of the mess she put herself and her
parents into.
16. Indeed, after it became apparent that Geraldine had no intention of living up to
her obligations, and didn't really want to work nit a payment plan or remain living on the
ranch, I sent the letter dated September 28, 2002 (se Exhibit "1-5"). Pursuant to the letter. I
waited until the end of the day on October 1, 2002 (by which time I had not received any
payments or communication what-so-ever from the Redmond's) before acting. On October
2, 2002 I turned the matter over to council for immediate collection, and I have not spoken
a word to Geraldine or her parents since.
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5. 17. As to Geraldine's allegations covering the period of time between the September
21, 2002 meeting and October 3, 2002, I declare as follows:
18.0n the evening of Sunday September 22, my fiance, Colleen O'Brier and I went
to the equestrian facility to verify the accuracy of a boarder schedule, which Geraldine had
filled out during our meeting of September 21, 2002. It should be known that this
information had been requested from Geraldine continuously for over four months and was
a critical factor in determining the percentage rent due SMLLC from the Redmond's. In
walking around the facility we found Geraldine's information to be completely inaccurate.
There were more horses than Geraldine had indicated and the locations of the horses were
incorrect. Geraldine drove up to us in a large water truck and turned off the engine. I
expressed disappointment with the inaccuracy of the boarder schedule and I insisted that
she provide me an accurate boarder schedule by Monday morning. Colleen and I were
standing approximately ten feet away from the water truck in order to see into the truck,
which is about seven feet of of the qrounca_ Geraldine never got out of the truck during our
discussion and I never approached her. She apologized and agreed to have an accurate
schedule to me by morning. Althoulh I sprJ,1E-1 ;n an agitated tone, I never screamed at her.
used profanity, or made any of the comments that she claims. I never threatened her in
any way, implied or otherwise. Colleen O'Brien has prepared her own declaration, which
will confirm these facts. (Please see declaration of Colleen O'Brien attached hereto as
Exhibit "J")
19. On Tuesday evening, September 24th , I saw Geraldine at the facility and asked if
she had the personal finan...-.1information she was supposed to be putting together so that
we could begin working on a payment plan. She told me that it was her last &fy with her
son, Jesse, and she was planning on meeting with her bookkeeper on Wednesday. I told
her that I thought she would be better off meeting with her parents, as they were jointly
responsible for the lease obligations and seemed better able to put a payment plan
together as they were both purportedly accountants. Geraldine agreed and assured me
she would meet with her father the following day, which was Wednesday the 25th. She
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then asked me if I wanted to meet her at either 4 or 6pm on Wednesday evening. I agreed
to meet with her at 6pm. During that brief conversation, I did not scream at her or threaten
her in any way. I was supportive, encouraging, friendly and kind in every aspect of my
conversation and demeanor.
20. On the morning of October 3, 2002, the day after I turned the matter over to
council, I went to the equestrian facility to document and photograph the condition of the
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facility as I told the Redmond's I would do in my letter of September 28' h- (I had not seen or
S ; heard from Geraldine since she left a message canceling our meeting that had been
9 scheduled for 6:00 PM on Wednesday a week earlier). Geraldine and her husband, Jeff
Ohaco, drove onto the Facility while I was there. I walked over to them as Jeff was
unhooking a horse trailer. I walked over to them specifically to speak to Jeff, because he
had called me the day before regarding three of my colts he was training and that I had
removed from the Facility the day before. I apologized to Jeff for removing the colts without
first informing him, exolaininc that I thought removing the colts from his training program
was best, given the way Geraldine seemed to be handling the current situation. I told Jeff
Chet would gladly pay him for any services due. ! then asked Jeff to kindly take his
belongings out of my fiance Colleen's tack room that she had been sharing with them, as I
was going to change the lock. During this entire discussion with Jeff, Geraldine was seated
in her truck and Jeff was standing outside the truck five feet away. I did not speak to, or
look at Geraldine at any time during this discussion, which was at all times very cordial.
Geraldine started her truck and she and Jeff drove approximately 75 yards to the tack
roc.m. I walked to my vehicle and drove to the tack room as well. I wa-Aac. up to Jeff and
handed him two fly masks that were his. I then stood Outside the tack room while they
removed their items for the next 2-3 minutes. During this exchange, I did not speak to,
much less threaten Geraldine Redmond.
21. Keeley Mircetic and Katrine Neilsen who are boarders at the Facility were
present at the time these conversations and events took place and will attest to the fact that
there was no hostility, screaming or threatening, not to mention the fact that Geraldine
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7. conveniently left out the fact that her husband, Jeff Ohaco, who is a large muscular
man, was present at all times and was actually the one to whom I was speaking.
(Please see declaration of Keeley Mircetic and Katrine Neilsen attached hereto as Exhibits
- K" and "L'').
22. Geraldine and Jeff each left the tack room. I then locked it and walked over to
Laurie Canty, who is the principal trainer and boarder at the Facility. At this moment,
7 Geraldine and Jeff drove up behind us, walked up to Laurie and served her a seven-day
S notice to quit. Geraldine was not shaken, scared or crying as she falsely claims in her
9 written declaration. She was in fact quite cold and deliberate. Laurie Canty has attested to
10 this in her own declaration. (See declaration of Laurie Canty attached hereto as exhibit "M - )
11 l In response to Geraldine's allegations that I have a "very violent history", that she
12 has witnessed me "pull people out of cars, take away their keys and race 60-100 mph after
13 I trespassers on the ranch", and of the unfounded, hearsay "stories" she has allecedly heard
bout "tying people up and dumping them down road", "removing renters items from
housing overnight and disposing of it", these accusations are outrageous, completely
6 untrue, wholly unsupported, and will be addressed in great detail in a defamation action i
1 7 will be filing against Geraldine Redmond, forthwith.
IS I have personal knowledge of the above stated facts and if called as a witness I
19 could and would competently so testify. I declare under penalty of perjury under the laws of
20 the State of California4at the above is true and correct.
tephen M. /aggero, declarant
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21 11 Dated this 14th day FM , in Ventura, California.• - 21 e
lj
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8. ARAL% JOSEPH 02.09-96 JANIS vs lbINC. 304A2(17/111
•
Page 65
A Yen. 4
2 Q What type of decision?'
3 A Walkolthal pent, Shay wentgettlag reedi
4 lusted raga whits timehannAsi be wasted Is mkt ;
1 nor that switches sod plia delialklits pct is culakr
• lentison
7 16b bid 1164 nut,
seC•114eillt• ,ailickawmnt
• iffaum•bilvelb•ii;&•• ano....+Iaboirnpai•Wm it -4-4
ent•nishisp Inn pig ill be met lb was beeind hi
tl sluff NM SM. •
2 Q Ds yes nun any disputa amides benne,
3 Blaachard sad mese she cossetting Bob Van hides ed
4 this Wain decorated
3 A Absolutely. There was • wearbeedd incident
s when Stun illaschard and Rabin Penises wen NM 601
one. Asa, again. Blanchard was jot. yes (saw, t
• psycho-nu. He was just gong erasy. •
e And he was boning Bob benne be hind this
o lady. who won't really an interior decanter, who was
i going to detente a naidtkoillies dollar boon with alit •
2 out of swap meets and junk yards. H. ousidol Wins this
was going to happen to his - Thh is sot Ms dream. That
4 h not what is supposed to be happeong bare.
5 And finally. Ferreet stepped is Warren Roble
Pose 66
1 and Blanchard. I thought Masehard was gang to his her. 1
2 really did. H. was totally psycho. I was surprised that
I Vila didn't call his off or hold hin down. Femme bad kr
step In between the two of them. 'Ilwy were kiting
I Robin - She wits going at it full forte. And they were sot •
s protecting her in any way. ,
Q Do you know bow that dispose got resolved?•
A I know Robin decorated the hose.
Q Did either Michael Fermat at Bob Vita say
faring is your ',resew* to Sieve Bleacimant coacernag
t than episode?
A Just to calm dolma earl not get as eruy almost
Muff.
Q Do you swill - Well, strike that.
My other decisions that you recall Bisachard
nuking osoe be came back is the project io late '927
A They redesigned the manta beithroom site fro.
what the original plans called for. I think the original
plans called for the Jamul toll Is bean • 45 degree snail
as you ester It. I doe! rand that there woe a shower 4
stall arrangement in tin original plan. So that changed:
The interior planter ha the stairwell was Is 44
be • dry planter, and Stereo bad this dream of bevies trees
growing inside the house. So he wasted that plaster to be
• Live plower so he put big trees la User*. lie was highly e
Page 67
I ionised with time indsomplog en the entwined the
2 ;wordy.
3 Ile 11144.#0,11is Islise is to audio',
4 ostualls Sitsragbribedasi
Ila wastiovia4d isfloggings's.* far
tit cossenakebeperiamfilistemist Isamillesi eft
II the "preyed Art
12 Mr. Rothstein Cseid 1 beve lit rain make
13 piton.
(Reaped stai.)
13 Ms. Ranson: Wed. I on mot sun 1 anierstaad the
16 qoados. Yes hue asked bin for changes that were nada.
12 Is the quoin sang far more el tied
12 Mr. Robertson Well. so. The winos has told nos
it about doors. Be. I idol gushy those led to be bow
20 the approved set of plots.
21 Now I as asking ((they see the same. rhea be
22 cos tense.
23 Q But I amass that the specification of the
24 type of Indscapiag loyal oa the approved phut
23 A That's correct. That's correct.
Page 68
Q Asd the interior plena. wader the stairway.
2 wasn't specified is the plan; coned?
3 A Then was • plaster specified es the plane.
a it was to be a dry planer. It was supplied to be,
3 easeotislly, as *peeing that was gang to be tiled that you
6 mold poi potted planes Sato and tales the plans oho of
7 Ii. He dinged that. That became - We waterproofed
• that.
9 Ws added sane Gin Lon Beam osier the haw.
to We were rammed the waste factor was gobs to be
considerably heavier tins wise was designed. He wooled a
12 wisterias 1.4.1.4 halo it as they could water the
13 plans.
14 That's -Moog are the lastaarea I was
15 referring to.
14 Q The mond issuer *bout the chugs boa a
ur dry planter toe !MSS piaster. that was • chaise from the
II approved pleas; correct?
to A That's awe act.
20 Q Okay.
21 And do yoga man an Sanwa whore f
22 Mr. Blaachard directed that • very large wee be 'smelled
23 is that planter before it was completely waterproofed?
24 A 1 deal belie,* that happened. I &fly
23 believe that tie plaster had bees waterproofed prior to as;