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JOHN J. HENNELLY, SBN 137164
JEFFREY W. COWAN, SBN 157474
HENNELLY & GROSSFELD LLP
17383 Sunset Boulevard, Suite 420
Pacific Palisades, California 90272
Tel: (310) 573-7800
Fax: (310) 573-7806
Attorneys for Plaintiff
Geraldine Redmond
VENTUHA
SUPERIOR COURT
FILED
NOV 2 7 2002
ANTP Executive11;0`ifitr;annrciserk"Y: •
CASE NO. D 292677
GERALDINE REDMOND'S
MEMORANDUM OF POINTS AND
AUTHORITIES IN OPPOSITION TO
DEFENDANT STEVEN GAGGERO'S
MOTION TO SEAL DOCUMENTS
FILED IN THIS ACTION
DECLARATION OF GERALDINE
REDMOND
[Evidentiary objections to the
Declaration of David Blake Chatfield
filed separately]
Date: December 11, 2002
Time: 8:30 a.m.
Dept: 41
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF VENTURA
GERALDINE REDMOND,
Plaintiff, •
vs.
STEVE GAGGERO, an individual;
Defendant.
1
Geraldine Redmond's Opposition to Steven Gaggero's Motion to Seal the File

2. I. INTRODUCTION
Geraldine Redmond is a reserve police officer who teaches horseback riding for a living.
With financial help from her parents, Ms. Redmond (through a company she controls) leased an
equestrian facility for one year from a company controlled by Defendant Steven Gaggero. Ms.
Redmond and her parents guaranteed the lease.
The lease contained a complicated formula for calculating the rent. One provision
required that Ms. Redmond's company pay 90% of certain fees received to Mr. Gaggero's
company— a point that the Redmonds did not understand when they did the deal. This term
transformed the agreement into a money-losing proposition. By late September 2002, Ms.
Redmond began shutting down her business.
Defendant Steven Gaggero is a businessman with his own, full-time general counsel. In
September and October of 2002, Mr. Gaggero tried to intimidate Ms. Redmond into complying
with certain contractual terms that she and her company were unable to honor. This included
screaming, using profanity, threatening "I will get you," and stalking Ms. Redmond by
following her around the equestrian center.
Mr. Gaggero's conduct was so severe that Ms. Redmond, a trained peace officer, found
herself forced to seek (in pro se) a C.C.P. § 527.6 restraining order so that she could remove her
property (and property entrusted to her) from the equestrian center (where she had been living
and running her business) without concern for her safety. The Court granted Ms. Redmond's
ex parte application (on October 4) and issued a TRO after it questioned Ms. Redmond at
length. It also set an OSC for October 21, 2002 after determining that this would give Ms.
Redmond enough time to finish removing property from the equestrian center. Meanwhile, Mr.
Gaggero sued Ms. Redmond, her parents and her company for breach of the lease. [Ms.
Redmond has asserted an affirmative defense that the lease is unconscionable.]
Ms. Redmond finished removing her property from the equestrian center just before the
October 21 OSC hearing on her restraining order. Before the Court took the bench on October
21, the parties' counsel conferred, and Mr. Gaggero's counsel represented that Mr. Gaggero
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Geraldine Redmond's Opposition to Steven Gaggero's Motion to Seal the File
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3. would not have any future direct communications with Ms. Redmond. As a result, Ms.
Redmond advised the Court that she had finished removing her property and no longer needed
injunctive relief to protect herself from Mr. Gaggero. She further consented to having the
action dismissed — which the Court did without prejudice.
Mr. Gaggero then asked the Court (Commissioner Pattie) to seal the file in this action,
as his opposition papers had requested. The Court denied the request.
II. THE COURT SHOULD NOT SEAL MS. REDMOND'S PETITION OR THE
MAP SHE WAS ORDERED TO DRAW BECAUSE MR. GAGGERO HAS NOT
SHOWN AN OVERRIDING INTEREST THAT OVERCOMES THE RIGHT OF
PUBLIC ACCESS.
Ms. Redmond respectfully submits that Mr. Gaggero's motion to seal (1) the petition
that Ms. Redmond filed, and (2) the map that the Court ordered her to draw of Mr. Gaggero's
residence should be denied because Mr. Gaggero has not carried his burden of showing that all
of CRC Rule 243.1's requirements have been satisfied.
A. No Privacy Interest
First, Mr. Gaggero has not established that he has a cognizable privacy interest in either
his address or the map that the Court ordered Ms. Redmond to draw. There is no competent
evidence that Mr. Gaggero does not disclose his address to third parties and that it (or the map
of his premises) is private information. Nor has Mr. Gaggero submitted any evidence of how
the subject information might cause him "embarrassment and emotional trauma."
B. Ms. Redmond's Statements Are Not False or Defamatory
Second, Mr. Gaggero has not shown that any of the statements in Ms. Redmond's
petition are false. The submitted declarations from Mr. Gaggero and his fiancée do not
conclusively disprove the testimony of Ms. Redmond, a sworn peace officer; they just
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Geraldine Redmond's Opposition to Steven Gaggero's Motion to Seal the File
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contradict it.' Statements from other witnesses (mostly former clients of Ms. Redmond who
have been affected by the shutting down of her business) who never saw the events that Ms.
Redmond testified about in her petition prove nothing.
And, Mr. Gaggero's claim in his opposition papers that Ms. Redmond made the same
accusations against him that she used when she obtained a § 527.6 TRO against her husband
during a (temporary) period of marital discord is false — as a brief review of the two documents
evidences. Mr. Gaggero also ignores that the Court questioned Ms. Redmond at length before
issuing the TRO against Mr. Gaggero.
Mr. Gaggero further incorrectly concludes that Ms. Redmond's statements are
defamatory. (Motion, p. 3:20) Aside from not having been proven false, the litigation
privilege protects Ms. Redmond's statements and bars any claim of defamation. C.C. § 47(b).
C. The Lack of Prejudice To Mr. Gaggero
Third, Mr. Gaggero has not shown prejudice if the file is not sealed. Because Ms.
Redmond authorized the dismissal of her action once it become moot, there are no factual
findings that prejudice Mr. Gaggero.
For these reasons, Mr. Gaggero has not met his burden of showing that he has an
overriding interest that overcomes the right of public access in these documents, that this
interest supports sealing the subject documents, prejudice to the overriding interest if the file is
not sealed, and that no less restrictive means exist to achieve the overriding interest. CRC Rule
243.1. The motion therefore lacks merit and should be denied.
III. CONCLUSION
Mr. Gaggero has not established any— let alone all — of the elements that CRC Rule
243.1 requires for a file to be sealed. Ms. Redmond therefore respectfully asks that the Court
Some of Mr. Gaggero's denials and statements raise more questions than they answer. For
example, Mr. Gaggero admits to having spoken to Ms. Redmond in an "agitated" manner. (Gaggero
Declaration, ¶ 18, filed in opposition to the OSC re Injunction)
4
Geraldine Redmond's Opposition to Steven Gaggero's Motion to Seal the File

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deny Mr. Gaggero's motion to seal portions of the file in this action.
Respectfully submitted,
DATED: November 26, 2002 HENNELLY & GROSSF LflLLP
By:
JEFFREY W. COWAN
Attorneys for Plaintiff
GERALDINE REDMOND
5
Geraldine Redmond's Opposition to Steven Gaggero's Motion to Seal the File
— ASHARE REDMOND Pkadings Opp_Mot 2 Seal He by Gaggcro.wpd

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DECLARATION OF GERAI,DINE "JAY" REDMOND
1. My name is Geraldine Redmond. I am a reserve police officer for the Los
Angeles Police Department, and am the Plaintiff in this action. I have personal knowledge and
if called upon to do so could and would competently testify to the following:
2. On October 4, 2002 I sought and received a TRO against Steven Gaggero.
When I applied for the TRO against Mr. Gaggero, the Court (Commissioner John H. Pattie
presiding) questioned me extensively before issuing it. I truthfully answered all of his
questions. Before issuing his order, Commissioner Pattie also instructed me to draw a map
showing where Mr. Gaggero lives, and he then had it included with my papers in this lawsuit.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct, and that I executed this declaration on Novembera42002, at
Pacific Palisades, California.
Geraldine Redmond
6
Geraldine Redmond's Opposition to Steven Gaggero's Motion to Seal the File
alSHARF,REDMOND:Pieuitngs Opp_Mot 2 Seal File by Gaggero.wpd

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PROOF OF SERVICE
I am over the age of eighteen years and not a party to this action; my business address is
17383 Sunset Boulevard, Suite 420, Pacific Palisades, California 90272.
On November 26, 2002, I served the following described document(s) on the interested
parties in said action as indicated on the attached Service List.
GERALDINE REDMOND'S MEMORANDUM OF POINTS
AND AUTHORITIES IN OPPOSITION TO DEFENDANT
STEVEN GAGGERO'S MOTION TO SEAL DOCUMENTS
FILED IN THIS ACTION
[X ] [BY MAIL] by placing a copy of said document for collection and mailing on the date
indicated above, in a sealed envelope(s), addressed as set forth on the attached service list,
pursuant to ordinary business practices. I am "readily familiar" with this firm's practice of—
collecting and processing correspondence for mailing. Under that practice it would be
deposited with the U.S. Postal Service at Pacific Palisades, California on that same day in the
ordinary course of business. I am aware that on motion of the party served, service is presumed
invalid if the postal cancellation date or postage meter date is more than 1 day after the date of
deposit for mailing this affidavit.
[ [BY PERSONAL SERVICE] by placing the original a copy of said
document (s) for collection and mailing on the date indicatede, in a sexed envelope(s),
addressed as set forth on the attached service list, and delivered to each addressee by a
messenger employed by Magnum Courier Service.
[ l [BY FACSIMILE] by transmitting a true copy by facsimile transmission at the time
indicated on the transmission report from facsimile telephone number (310) 573-7806 to a
facsimile machine maintained by the party on whom it was served, at the facsimile machine
telephone number indicated on the attached service list. The transmission was reported a s
complete and without error. The transmission report which was properly issued by the
transmitting facsimile machine is attached to the file copy of this document.
[ X [STATE] I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
[ ] [FEDERAL] I declare under penalty of perjury that the foregoing is true and correct and
I am employed in the office of the member of the Bar of this Court at whose direction the
service was made.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed this 26th day of November, 2002, at Pacific Palisades,
California.
1 "r"
'ON LCk K)-1-.)
YVONNE WATERS
ICaption-POS-Harassment.wpd]
Wile No: •1
2

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SERVICE LIST
Attorney for Defendants
Stephen M. Gaggero
David Blake Chatfield, Esq.
LAW OFFICES OF DAVID BLAKE
CHATFIELD
425 Zeno Way
Oak Park, CA 91377
Tel: (818) 879-1289
Fax: (818) 879-9138
3

9. ";?::.•
ARAM. JOSEPH 02.09.96 JANIS VS 1111INC. 304Axtins
Page 6$
A Yes. 4
2 Q What type of dechiour
3 A Wee St snide thy were garbs remit!
4 listed roe& lade. He lama Aad hi iambi lie isaillik 147
• lets that switeii.46erAliadiles146/61,143i
• ii."&;ir•V4,ts.;A,,Y,- 7
J1011.441.11p.
7 ;Hob so, ogiesestie lesteetA4 '
• pima % ate Mee elera muIllseted Mk-
", 41. htlizari;":=11•Mle." sNO. =••
9 best tie Waists wen &sick eel Ale type
to attenuant sedipbe Ishii..LS*1m Inaba
. . • .
tt stafflkollat. •
:2 Q Dsyouironas7dirputesemptieskdern..
3 Blaschsrd aid arose elst emends* Bob Mks a
• lb Wake decorator?
1 A Aleektely.lbere was • ersoletill belated
• when Steam Blasebard sad Rails Name venom tei
7 nowAsd. nab. Blaschard unjust, yes hem 4
psycho•ram. Ile wailed gobs trash ••
it And be was berating Bob because he bred this .
o lady. who wasn't rally as banter thunder. who Wu
going la decorate • eaulti-reBBse dollar bun with staff A
2 eve of swap setts andjush weal* wail beaus this
3 was going la Lippe. to Me -.This h sot Ms drums. Th.st
4 14 sot 44484 AS upped to be Lan:cake here.
5 And finally. Ferree stepped is between Robb
Page 67
havelted with doe isolsespise ibe oink. se lb,
2 Pc•ritl•
„. 3 .13. breve! big isibei is le tie
tip• ,
iris .
12
~titat
416. . lir
.27. v,
401 0•14*^V.14,
-.1Yuppilee
Ctisse semtimer
asierscdos este= sot is
it ttos wowed phut
it Ms. Itetkeds: dell I We tie vadat wk.
13 phase.
14 (Recent mi.)
13 Ms. Roasted.: Well.l so eat sure 1 esiesesed the
1• question. Yoe haveasked bin ix dears dm were Node.
17 Is the Trade. nibs fsc more add?
it M. Robertson: Wd. se.The IrkenI his tete as
le about chutes. Bat l Adel gest* those b d is be boo
20 the ',proved set arises.
21 Now 1 so *skim if they on tie suet. din be
C11111 kit ate.
23 Q not I am= lid doe specificsdos of the
24 type of loadscepiag wasn't o. the approved pis?
23 A That's tiered. That's meat.
Per 66
t and Bluebird. I thought Blanchard was rig to his her, I ;
2 really did. H. was Wally psychs. I was surpeied that
Vila didn't all hie eft or bold blot due. Fame had ter
step In between the two of thee. They were Wag •
Robb - She was gang at it full feu. And they wen sot .
s protecting be: la any way. ,
Q Do yos know bow that dispose got resolved?
A I know Roble detested the bore.
Q Did either Michael Farms oe Bob Vila my
sayt►iag h year praises to Steve 11114140441c000rralag
a that episode?
A Jost to calm down sad sot lit we easy slunk
stuff.
Q Do you recall - Well. strike that.
Any other decisions the you recall Bleached
ankles owe he came back la the project is he '92?
A They redesigoed the mienWks«. walt• fro.
what lb* orIglaal plans called for. I thIsh the ortgbal
plans called for tbisteszl 'eh So boons 45 degree ang11
as roe enter It. I don't real that then was • shower 4
stall • rranvusest Is the original plans. So that changed:
The interior planter in the *tarsall eras to
b. dry planter, and Steven had this damn et having trees
growing kaki. the house. So he wasted that plaster to bt,
• live plaster so be pot big trees in then. lb was Idgisly
esge 68
1 Q And the Wake piaalet, under the stairway,
2 wasn't specified is the plans; corned
3 A There was • Osier specified on the plans.
a II Iva to be a dry planter. It was supposed to be,
3 esseedally, as *pubs that was rig So be Wed list you
6 read pet polled plases WO sad tab the pluts oat of
7 11. Ile changed amt. Thal became • We wateepesofed
• that.
• We aided...* GIs /me Beam osier lb. bare.
10 We were resettled the waste factor was gobs to be
II considerably heavier than what wit &aped. He wasted
12 waterkee babied ht. It so they could water the
13 pleats.
1 a That's -Those ars the hetances I was
13 refming to.
16 Q The second banana about the charge treat •
*7 dry plaster to • Ulnas plaster. that was s chute from the
IS approved plans: correct/
1• A Thaes cermet.
20 Q Okay.
21 Aad do you recaU as iastaace where •
22 Mr. Bleached directed the a very loge tee be isstalkd
23 is that planer Woe It was complesely waterproofed/ '
24 A ' I du% believe the happened. I fully
23 believe that the plaster had been waterproofed prior to say