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1. 8056436094; Aug-2703 2:45PM; Page 1
Sent By: ;
David Blake Chatfield Bar No. 88991
Law Offices of David Blake Chatfield
425 Zeno Way
Oak Park, CA 91377
phone (818) 879-1289
fax (818) 879-9138
Attorneys for Plaintiff, Sulphur Mountain Land and Livestock Co. .
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF VENTURA
SULPHUR MOUNTAIN LAND AND Case No.: CIV 214702
LIVESTOCK CO. LLC,
SUPPLEMENTAL DECLARATION OF
Plaintiff, DAVID CHATFIELD IN SUPPORT OF
PLAINTIFF'S OPPOSITION TO THE
v. MOTION TO COMPEL THE FURTHER
DEPOSITION OF STEPHEN M.
JOHN REDMOND; MAUREEN REDMOND; GAGGERO
GERALDINE REDMOND; SOMERSET
FARMS LLC. etc., et al.,
Defendants.
I, David Blake Chatfield, declare as follows,
1. I am an attorney duly licensed to practice before all courts within the State of California.
2. I am counsel of record for SULPHUR MOUNTAIN LAND AND LIVESTOCK CO. LLC.
In this matter and make this declaration in support of the Plaintiffs Opposition to the
Defendant's Motion to Compel the Further Deposition of Stephen M. Gaggero.
3. On August 13, 2003 I sent a letter to Mr. JabIon offering to show defendants' counsel
a document granting Sulphur Mountain Land and Livestock Co. LLC the right to lease the
premises. In this letter, I advised Mr. JabIon that this is a private and confidential document
which is subject to plaintiffs and third parties right of privacy, which they are unwilling to waive.
Supplemental Declaration of David Chatfield
Date: August 29, 2003
Time: 8:30 a.m.
Dept.: 32
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Sent By: ; 8056436094; Aug-27-03 2:45PM; Page 2
However, I indicated our willingness to show defendants' counsel the document, without your
making any copies of it. I have not received any response to the letter. (A copy of the August
13, 2003 letter is attached hereto as exhibit "A")
4. Upon returning from vacation, and having had no response to the August 13.2003
letter, I sent Mr. Jablon a letter on August 26, 2003 again offering to show counsel for
defendants the document granting plaintiff the right to lease the premises. To date, Mr. Jablon
has not responded to this letter. (A copy of the August 26, 2003 letter is attached hereto as
exhibit "B".)
I declare under penalty of perjury that the above is true and correct to the best of my
knowledge. I have personal knowledge of the above stated facts and if called as a witness
would competently so testify.
/I
I make this declaration on August 27, 2003 tura, Ca ► ornia
Davi • Blake C , declarant
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•"••••••sN
DECLARATION OF DAVID CHATFIELD

3. Ve Trul yours,
Sent By: ; 8056436094; Aug-27-03 2:46PM; Page 4/7
C YID BLAKE CHATFIELL
425 ZENO WAY
OAK PARK, CALIFORNIA 21377
(518) 879-1289
FAX (810) 579-9138
DAVID SLAK2 CHATFIELD
tmAILI 7 0:12 AAAAA c@vAHOO.0014
August 13, 2003
Andrew Jablon, Esq.
Resch, Polster, Alpert & Berger
10390 Santa Monica Blvd. 4th Floor
Los Angeles, CA 90025
via fax
Re: Sulphur Mountain v. John Redmond
Dear Mr. Jablon,
At the deposition of Mr. Gaggero we discussed that there is a document which exists
granting Sulphur Mountain Land and Livestock Co. LLC the right to lease the premises.
As we further advised you, this is a private and confidential document which is subject
to plaintiffs and third parties right of privacy, which they are unwilling to waive.
However, our client is willing to show you the document, without your making any
copies of it, if you agree to a stipulation of fact that Sulphur Mountain Land and
Livestock Co. LLC had the right to enter into the subject lease with your clients.
We look forward to hearing from you on the above. As you are aware, I will be out of
town and will not return to the office until August 25, 2003. Please direct your inquiries
to Mr. Bezek in my absence.
David Blake Chatfie d
DBC/kt

4. Sent By: ;
DAVID BLAKE CHATFIELD
....
CMAIL1 DAVIONLAKECED .COM
8058436094; Aug-27-03 2:46PM; Page 6/7
1 yip BLAKE CHATFIEL
1125 ZENO WAY
OAK PARK, CALIFORNIA 91377
(8111) 879.1289
rwx (19 1 8) 879.9138
August 26, 2003
Andrew Jablon, Esq.
Resch, Polster, Alpert & Berger
10390 Santa Monica Blvd. 4th Floor
Los Angeles, CA 90025
via fax
Re: Sulphur Mountain v. John Redmond
Dear Mr. Jablon,
On August 13, 2003, we advised you that there is a document which exists granting
Sulphur Mountain Land and Livestock Co. LLC the right to lease the premises. As we
further advised you, this is a private and confidential document which is subject to
plaintiffs and third parties right of privacy, which they are unwilling to waive.
We further advised you that, our client is willing to show you the document, without your
making any copies of it, if you agree to a stipulation of fact that Sulphur Mountain Land
and Livestock Co. LLC had the right to enter into the subject lease with your clients.
We invited to respond to Mr. Bezek in my absence and Mr. Bezek has related that he .
has not heard from you. We again are awaiting to hear from you regarding the above.
...

5. 8056436094; Aug-27-03 2:47PM; Page 7/7
Sent By: ;
2
PROOF OF SERVICE
(CCP §§ 1013a, 2015.5)
STATE OF CALIFORNIA )
)ss.
COUNTY OF VENTURA )
I am employed In the aforesaid County, State of California; I am over the age of eighteen years and
not a party to the within entitled action; on August 27, 2003, I served the document titled
SUPPLEMENTAL DECLARATION OF DAVID CHATFIELD IN SUPPORT OF
PLAINTIFF'S OPPOSITION TO THE MOTION TO COMPEL THE FURTHER
DEPOSITION OF STEPHEN M. GAGGERO
on the Interested parties in this action by placing a true copy thereof, enclosed in a sealed envelope,
addressed as follows:
Michael Baum, Esq.
Andrew Jablon, Esq.
Resch, Poister, Alpert & Berger
10390 Santa Monica Blvd. 4 Floor
Los Angeles, CA 90025
(310) 552-3209
BY MAIL I placed such envelope for deposit in the United States mail for service by the United States Postal Service,
with postage thereon fully prepaid. As follows: I am "readily familiar" with the firm's practice of collection and
processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that
same day with postage thereon fully prepaid at Ventura, California in the ordinary course of business. f am aware that
on motion of the party ierved, service is presumed invalid if postal cancellation date or postage meter date is more than
one day after date of deposit for mailing in affidavit.
X (BY FACSIMILE) I transmitted from a facsimile transmission machine whose telephone number is (805) 643-6094
the following documents described above to whose facsimile transmission machine telephone number is noted above.
The above-described transmission was reported as complete without error by a transmission report issued by the
facsimile transmission machine upon which the said transmission was made Immediately following the transmission. A
true and correct copy of the said transmission report is attached hereto and incorporated herein by this reference.
x By depositing the envelop with Federal Express for overnight delivem postage prepaid.
X STATE I declare under penalty of perjury under the laws of the State of California that the foregoing is true and
correct.
Executed on August 27, 2003 at Ventura, California.
WWII&aber
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