.

1. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 1
RAYMOND H. AVER - SBN 109577
LAW OFFICES OF RAYMOND H. AVER
A Professional Corporation
12424 Wilshire Boulevard, Suite 720
Los Angeles, California 90025
Telephone: (310) 571-3511
Facsimile: (310) 571-3512
Attorneys for Defendants
JOHN A. REDMOND and MAUREEN C. REDMOND
UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA [LOS ANGELES DIVISION]
In re:
JOHN A. REDMOND and
MAUREEN C. REDMOND,
Debtors.
SULPHUR MOUNTAIN LAND AND
LIVESTOCK CO., LLC,
Plaintiff,
v.
JOHN A. REDMOND and
MAUREEN C. REDMOND,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Case No. LA 06-12188 EC
In Proceedings Under
Chapter 7
Adv. No. AD 08-01309 EC
DECLARATION OF GERALDINE REDMOND
IN SUPPORT OF DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, FOR SUMMARY
ADJUDICATION
Date: [To Be Scheduled]
Time:
Place: Courtroom 1639
Roybal Federal Building
255 East Temple Street
Los Angeles, California 90012

2. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 2
DECLARATION OF GERALDINE REDMOND
I, GERALDINE REDMOND, declare:
1. I am the adult daughter of John A. Redmond (“John
Redmond”) and Maureen C. Redmond (“Maureen Redmond”) (jointly,
the “Redmonds”), the defendants in the above-referenced adversary
proceeding.
Rental Of Hierba Residence
2. On or about September of 1999, I moved into the
residence located at 8711 Hierba Road, Aqua Dulce, California
91351 (“Hierba Residence”).
3. At the time that I moved into the Hierba Residence, the
Hierba Residence had many defects including a large hole in the
floor of the kitchen, and carpeting that was in poor condition.
4. By December 2000, I made various improvements and
repairs to the Hierba Residence, including having new carpet and
screens installed, fixing the hole in the kitchen floor, and
painting the living room and den areas. A true and correct copy
of pictures taken at Christmas 2000 which accurately show the
condition of the Hierba Residence at the time are collectively
attached as Exhibit A hereto.
5. While living at the Hierba Residence, my husband,
Jeffrey O’Haco caused a dog yard to be installed at the Hierba
Residence at a cost of roughly $5,000.00.
6. On or about February of 2001, the owner of the Hierba
Residence, Georgia Jorden (“Jorden”) and I agreed that Jorden

3. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 3
would take the dog yard as a credit toward any rent that was owed
by me. On or about the end of March 2001, my family and I moved
out of the Hierba Residence.
7. Unbeknownst to me, Jorden filed an unlawful detainer
action against me. Because I was never properly served with the
unlawful detainer complaint and I never had any actual notice
regarding the unlawful detainer action, a default was entered
against me.
Rental Of The Sulphur Mountain Facility
8. On or about September 2001, I responded to an
advertisement regarding a lease for an equestrian facility along
with a residence located at Canada Largo Road in Ventura County,
California (the “Facility”).
9. I subsequently had a meeting with Sulphur Mountain’s
managing agent, Stephen Gaggero (“Gaggero”). At this meeting, I
submitted an “Application To Lease” to Sulphur Mountain. A true
and correct copy of the “Application To Lease” is attached as
Exhibit B hereto. I did not discuss the “Application To Lease”
with my parents prior to submitting it to Gaggero, and I did not
show a copy of the “Application To Lease” to my parents at any
time.
10. At the time that I completed and submitted the
“Application To Lease,” I was not aware that Jorden, my previous
landlord, was claiming that I had been evicted, that my previous
landlord had brought a lawsuit against me, or that my previous
landlord had a judgment against me.

4. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 4
The Redmonds’ Guaranty Of The Facility Lease
11. Because my credit was poor, Sulphur Mountain required
that my parents, John Redmond and Maureen Redmond (jointly, “the
Redmonds”) guarantee the lease.
12. On or about October 2001, my parents and I met with
Gaggero to discuss a possible lease of the Facility. At no time
during this meeting was it ever discussed whether I had ever been
the subject of an eviction or a lawsuit, or whether there was a
judgment against me. Further, my parents did not tell Gaggero
they would pay the security deposit, the lease payments, or the
business overhead until my company was making a profit.
13. After this meeting, Gaggero prepared a draft lease that
he gave to me. I gave a copy of the draft lease to my father so
he could look it over. Throughout October 2001, Gaggero and I
exchanged several drafts of the lease for the Facility. My
father assisted me with these negotiations. My mother was never
involved with any negotiations of the lease for the Facility.
14. On or about October 2001, I had a second meeting with
Gaggero because under the lease, as drafted, I would not be able
to afford the rent without some sort of period of reduced rent at
the beginning so that I would be able to start generating income.
15. On or about November 23, 2001, Sulphur Mountain and
Somerset, LLC (“Somerset”) entered into an “Equestrian Facility
Lease” (the “Lease”), which was guaranteed by my parents and me.
The term of this lease was from January 1, 2002 until December
31, 2002, with three potential three year options to renew. A
true and correct copy of the Lease is attached as Exhibit C
hereto.

5. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 5
Formation Of LLC
16. I decided to form a limited liability company (“LLC”)
in order to protect myself from potential liability regarding any
accidents arising out of the Facility or the riding of horses at
the Facility. Originally, I planned to name the LLC “Somerset,
LLC.” However, after the Lease was executed, I discovered that
the name “Somerset, LLC” was not available for registration and
decided to name the LLC “Somerset Farms, LLC” instead.
17. Although my parents agreed to guarantee the Lease, it
was understood by all the parties that my parents were not “joint
venturers” with me and would not have any managerial or
administrative responsibility for Somerset, and that Somerset was
my business for which my parents were merely guarantors of the
Lease.
Hiring Of Marsha Adamson As Somerset’s Bookkeeper
18. On or about December 2001, I hired Marsha Adamson to do
the bookkeeping for Somerset. Ms. Adamson and I collected the
deposits and rental payments from the sub-lessors of the
Facility. Ms. Adamson prepared the monthly reports regarding the
Revenue Generating Activities (“RGA”) that were required under
the Lease and she prepared the financial records for Somerset.
My parents did not review the RGA and did not have any
involvement with the preparation of financial records of
Somerset.
19. On September 21, 2002, my parents, Ms. Adamson, and
I met with Gaggero. At this meeting Gaggero repeatedly claimed
that Somerset owed him money. Ms. Adamson defended Somerset by

6. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 6
saying that due to the RGA payments to Sulphur Mountain, Somerset
was not making any money. Gaggero was so rude to Ms. Adamson
that she ended up walking out of the meeting. Although, my
parents were present at this meeting, they did not actively
participate because they did not know what was going on with the
RGA that was at issue at the meeting. I did not propose a plan
to get caught up on the rent.
20. By October 2002, I realized that there was no way in
which Somerset could make a profit at the Facility under
Gaggero’s interpretation of the Lease. Thus, in or around
October 2002, I let the sub-lessees know that Somerset was not
going to be able to board their horses any longer. Later that
month, I moved out of the Facility.
Loans From The Redmonds To Geraldine Redmond
21. From 2001 to 2002, my parents loaned me approximately
$77,124.00.
22. On or about September 8, 2003, I caused to be filed a
petition for bankruptcy under Chapter 13. On October 20, 2003,
my bankruptcy case was converted from Chapter 13 to Chapter 7.
On July 29, 2005, I received my bankruptcy discharge.
23. My parents did not loan any money to me following my
bankruptcy.
Geraldine Redmond’s Use Of Her Parents’ Jackson Federal Bank
Account
24. On or about October 2001, my credit was so bad that I
was not able to open a checking account at a bank. My parents

7. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 7
allowed me to use their account, number 11-00038894, at Jackson
Federal Bank. From roughly October 2001 until October 2002, all
money deposited into the account was my money, including money
that I made from my work as a trainer. My mother would then
write checks out of this bank account in order to pay my personal
expenses.
Purchase/Ownership Of Ford Diesel Truck And Sooner Horse Trailer
25. On or about January 2002, I purchased a Ford Diesel 450
Truck (“Ford Diesel Truck”). The loan for the Ford Diesel Truck
was in both my father and my names because my credit was too bad
to get the loan by myself.
26. I made almost every payment for the Ford Diesel Truck
until 2005, when it was fully paid off. At that time, I
transferred title to the Ford Diesel Truck to myself. A true and
correct copy of some of the payments made payments that I made
via Western Union are attached hereto as Exhibit D hereto.
27. I never repaid my parents for any payments they made
for the Ford Diesel Truck.
28. In 1999, I purchased a Sooner horse trailer (the
“Sooner Horse Trailer”). The Sooner Horse Trailer was purchased
in my father’s name, but I made all but two of the payments for
it. On or about March 5, 2006, I visited my father and had him
sign over the Trailer to my name.
29. I never repaid my parents for any payments they made
for the Sooner Horse Trailer.
30. A true and correct copy of the 2002, 2003, and 2004
Federal depreciation schedules, from my Form 1040 Federal Income

8. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 8
Tax Returns, showing my ownership of the Ford Truck and the
Trailer are collectively attached as Exhibit E hereto.
31. I have personal knowledge of the facts set forth above,
and if called upon as a witness, I could and would competently
testify thereto under oath.
Executed this ___ day of October, 2009, at Los Angeles,
California. I declare under penalty of perjury under the laws of
the United States of America that the foregoing is true and
correct.
GERALDINE REDMOND

9. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 9
NOTE: When using this form to indicate service of a proposed order, DO NOT list any person or entity in
Category I. Proposed orders do not generate an NEF because only orders that have been entered are
placed on the CM/ECF docket.
PROOF OF SERVICE OF DOCUMENT
I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business
address is: 12424 Wilshire Boulevard, Suite 720, Los Angeles, California 90025
The foregoing document described “DECLARATION OF GERALDINE REDMOND IN SUPPORT OF
DEFENDANTS MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY
ADJUDICATION” will be served or was served (a) on the judge in chambers in the form and manner required by
LBR 5005-2(d); and (b) in the manner indicated below:
I. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) – Pursuant to
controlling General Order(s) and Local Bankruptcy Rule(s) (“LBR”), the foregoing document will be served
by the court via NEF and hyperlink to the document. On October 9, 2009, I checked the CM/ECF docket
for this bankruptcy case or adversary proceeding and determined that the following person(s) are on the
Electronic Mail Notice List to receive NEF transmission at the email address(es) indicated below:
X Service information continued on attached page
II. SERVED BY U.S. MAIL OR OVERNIGHT MAIL(indicate method for each person or entity served):
On October 9, 2009, I served the following person(s) and/or entity(ies) at the last known address(es) in
this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed
envelope in the United States Mail, first class, postage prepaid, and/or with an overnight mail service
addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be
completed no later than 24 hours after the document is filed.
X Service information continued on attached page.
III. SERVED BY PERSONAL DELIVERY, FACSIMILE TRANSMISSION OR EMAIL (indicate method for
each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on October 9, 2009 , I
served the following person(s) and/or entity(ies) by personal delivery, or (for those who consented in
writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here
constitutes a declaration that personal delivery on the judge will be completed no later than 24 hours after
the document is filed.
X Service information continued on attached page
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true
and correct.
October 9, 2009 Sharon Lee
Date Type Name Signature

10. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Law Offices of
Raymond H.
Aver, APC DECLARATION OF GERALDINE REDMOND
Page 10
SERVICE LIST
Via NEF
Raymond H Aver ray@averlaw.com
United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov
Via U.S. Mail
David Blake Chatfield
Westlake Law Group
2625 Townsgate Rd Ste 330
Westlake Village, CA 91361
Via Personal Service
Hon. Ellen Carroll
Bin Outside of Suite 1634