Financial timeline declaration 7 3 05 1

1. SECTION TWO.
A Financial Timeline Declaration of the
efforts of the Redmond parents to defend
themselves and their daughter, Geraldine,
from the personal vendetta of Stephen
Gaggero.
November 9, 2001 to July 11, 2005
We declare under penalty of perjury under the laws of the State of
California, that the foregoing is true and correct to the best of our
knowledge.
Executed this 2011 at California.
SMLLC v Redmond et al.
John A. And Maureen C. Redmond
August 6, 2005

2. Date
12/27/01 We loan Geraldine from refinancing personal residence
$30,501.47.
11/9/01 Including the above, we loan a net $68,520.00 to
Geraldine. She, in conjunction with her training income,
to used these funds to keep Somerset Farms afloat.
John Redmond (JAR) and Maureen Redmond (MCR)
only able to help because his tax preparer business
increased about 30% in 2002, over 2001.
(mainly large IRS audits).
We never expected that we would have to help Geraldine
10/11/02 to this extent.
SMLLC monthly min. rent schedule 2002 $83,500.00
Somerset Farms/Geraldine 2002 payments $85,116.00
Somerset Farms 2002 gross income $49,819.09
Somerset Farms 2002 loan payable to Geraldine $66,544.22
Somerset Farms 2002 net loss $75,188.35
Geraldine 2002 gross personal training income $111,880.00
JAR/MCR 2001/2 personal loans to Geraldine-net $68,520.00
(SFLLC Source….AES)
9/20/02 Letter from JAR to S.Gaggero, “There is no more
money available from her parents”.
1/20/03 JAR deposition page 56,
“At some stage, we basically said we had done all we
could for her that year. We had a prior problem, a
personal one with the family, with one daughter who
has panic attacks and swallowing problems, and we
were…..we had a therapist who was helping that
daughter,and we needed funds to go there”.
Our 2002 unreimbursed medical expenses were
$25,570.00(Sch.A 2002 1040 and adj.).

3. 10/4/02 When Geraldine terminated the boarders and left the
facility, we had no idea what had happened. JAR
had been to the facility about 5 times..2 contract
meetings, 2 personal visits, and a September 21,2002
meeting with S.Gaggero and Marsha Adamson, the
bookkeeper,who had a serious and prolonged
argument over costs.
MCR had been to the facility about 3 times. JAR had
an agreement with S.Gaggero that he would be called
if there were serious problems. Gaggero never called.
9/18/02 Letter from S.Gaggero to Jay, John and Maureen,
“I guess I should have called you, John, but I was
hopeful I could work it out with Jay and Marsha and
not trouble you”.
10/11/02 At the time of the first writ of attachment, we were
unaware of what was happening. We had to call
Chatfield to send us information.
Also, JAR was in the very hectic period of the last filing
extension. All these late filing clients have complex
10/15/02 returns which require major attention. It was not until
late..9 p.m…October 15,2002 that he finished the last
filing and delivery to the LAX airport post office.
It is important to understand that JAR is a sole
proprietor who had no payroll after April.
MCR was equally busy. Her clients that year
(parents with autistic children) were extremely
demanding and required MCR’s attention well into
the evening.
That was our situation when we learned,10/14/02, from our
bank that our 3 bank accounts had been seized.
This included our social security, and the funds to
pay our mortgage, plus a lien on our house.
10/16/2002 October 16, 2002 was a shattering experience. We
have no money. We have no bank accounts.
Checks previously written are bouncing.
The mortgage has to be paid.
There is a lien on the house.

4. Neither of us had any prior experience of this form
of legal assault, without any notice whatsoever.
We have no lawyer, and no money to hire a lawyer.
10/22/02 Jeffrey Cowan had helped Geraldine with boarder
terminations, but that had been completed.
With great difficulty we reconstructed our life,
opened new bank accounts, etc.
Jeffrey Cowan’s law firm required $5,000.00
advance. The only way we could obtain this was
from JAR’s niece in England.
We still had no detailed knowledge of what had
happened, despite a number of requests. The
bookkeeper, Marsha Adamson, did not provide
final bookkeeping until Nov.12,2002.(Gaggero
received the same information in November, 2002).
Our agreement with Jeffrey Cowan was that we
would do much of the groundwork to analyse
Marsha Adamson’s information (the bookkeeper’s
final reports) for him to review.
12/16/02 It was not until Dec. 16, 2002 that we were able to
complete our initial analysis and present it to
J.Cowan.
It showed that the first writ of attachment by S.Gaggero
was grossly exaggerated, inaccurate and deceptive.
12/31/02 But the lien was on our house, and our cash flow
was appalling and would not recover until tax season.
.
1/13/03 C.C.P. 998 settlement offer…$25,209.00.
By the middle of January, 2003, we had done
enough analysis to conclude we owed no money to
Gaggero. In order to stop the suit, we offered
$25,209.00 to cover damages and legal expenses.
Gaggero refused to settle. There is no factual reason
why he did not settle. All relevant information was
known to both parties.

5. All costs from this date on, are no more than a
“teach Geraldine and her parents a lesson”.
We were defending ourselves with both hands tied
behind our backs. We now knew that we had right
on our side. However, we knew little about
Gaggero and how implacable he could be.
1/20/03 Depositions of JAR and MCR.
This was our first comprehension of the extent of
harassment by Gaggero. This was turning a
mundane landlord/tenant dispute into a serious
fraud, theft, etc.,etc.,etc.
2/1/03 By February, 2003 we were running behind in our
payments to J.Cowan’s law firm, Hennelly and
Grossfeld, LLP. We gave a proposal that
included income from tax season and possible sale
of JAR’s share of a restaurant.
4/3/03 This offer was not accepted, and substitutions of
attorney were given to us to sign. Once again the
timing could not have been worse, as JAR was in
last phase of tax season. We asked for an extension
but it was not given. J.Cowan’s letter is dated April
3, 2003.
4/16/03 True to their method of operation, Gaggero
launched an additional writ of attachment, trying to
force it through before we got representation, to
secure an additional lien on personal home, additional
“damages” and legal expenses.
Now they further exaggerate damages….
$109,709.54 and legal expenses of $106,680.74
(Mr.Chatfield has been working very hard!!).
Jeffrey Cowan, the Hennelly and Grossfeld
departing lawyer, fires off a parting letter, dated
April, 2003, warning Chatfield of unprofessional
conduct.
“Today, you filed, and personally served,

6. a motion to amend the complaint, with a hearing
on April 23, 2003. By setting your motion on
minimum notice ( making defendants’ opposition due
on April 11), you are trying to capitalize on our
unavailability. Such conduct is unprofessional, see,e.g.
Los Angeles County Superior Court Rule 7.12(b)(1)
(“The timing and and manner of service of papers
should not be used to the disadvantage of the
party receiving the papers”).
“p.s….this is another example of how plaintiff has
unnecessarily incurred legal fees in this action”.
4/10/03 Direct, letter to Redmonds from Chatfield to resolve
case. JAR replied, but no meeting. Letter sent in last days
of tax season. This appears deliberate, to try and take
advantage of Redmonds’ inexperience on such legal
negotiations.
As an aside, this was exactly the tactics used in
October,2002.
Fortunately, we were able to sign on with Resch,
Polster, Alpert & Berger,LLP.
5/1/2003 Resch, Polster, Alpert & Berger had asked for a
deposit of $10,000.00. We were able to do this
with funds from just completed tax season.
However, there were no additional funds to pay
current expenses. To resolve this major problem,
we intensified JAR negotiations with partners in
Santa Monica restaurant, “The Two Drops of
5/12/03 Scotch”. This share was sold May 12, 2003 for
$60,000.00.
6/4/03 Michael Baum now took over the case. We had
little detailed knowledge of what developed over
the period through August, 2003, other than a
mediation meeting where we were delighted to hear

7. such phrases as, “A classic case of overreach”,
and, “Net income is net income”, in response to
the deceptive clause 5(RGA) in the contract.
The $60,000.00 plus $10,000.00 retainer was going
fast. We are not knowledgeable enough to
understand the expenditures in 2003. We did
know that we had another financial crisis.
Trial was set for Sept. 2003. We are not aware of
the circumstances of this decision, but our lawyers
were not ready for trial, and we did not have the
trial expenses. Discussion with M .Baum and a new
bankruptcy lawyer, Steve Stanley, charter the only
course, which was for Geraldine to go into
9/8/03 Chapter 7 bankruptcy.
Why Geraldine’s bankruptcy lasted from Sept. 8,
2003 until May, 2005 is beyond our
comprehension. All we knew is that we had, due to
Chatfield’s disruption and delay, to find additional
fees for Geraldine. She had no money.
The C.7 stayed the trial, but we continued to pay
large monthly legal fees to Resch, Polster, and by
November, 2003 we were once again in serious
financial trouble. The new trial was set for Jan.,
2004. Once again, discussions with M.Baum
and S,Stanley led to our filing Chapter 13 just
prior to the trial date. We had, to our knowledge,
done no preparation for trial, despite having spent
$70,000.00 in 2003, and we now owed fees which
we did not have, to Resch, Polster.
To our knowledge,
no new information had come to the surface since our
Jan. 13, 2003 998 offer.
12/31/03 We refused to sign “substitutions of attorney” with Resch,
Polster, for fear of additional “dirty tricks” and
unprofessional conduct from Chatfield.

8. Jan.2004 This Chapter 13 break gave us time to breathe, and to
consider how we were to continue the fight. We had no
intention whatsoever, of giving in. We knew Chatfield/
Gaggero were trying to destroy us. Chatfield sent two
unbelievably hostile letters, making it clear that Gaggero
wanted our house, and that they intended to pursue assets
wherever they might be. This included assets in England!
We do not have assets in England, period. We had
answered all questions on our depositions, and in fact,
under oath, JAR had answered that question in the
Chapter 13 hearing.
6/9/04 C 13 dismissed.
This desperate strategy bought us time to re-group. By
March/April, 2004 we are able to write to M. Baum re
continuing representation.
M. Baum’s terms were:-
(a) by April 29, 2004 retainer of $25,000.00
(b) by May 7, 2004 balance of $17,300.00
(c) by April 26, 2004 signed “substitutions of attorney”.
Once again, a desperate effort to survive:-
(a) $17,300.00 check deadline met with income from tax
season.
(b) We borrowed $23,500.00 from a friend to meet the
$25,000.00 retainer deadline.
(c) We reluctantly signed the “substitutions of attorney”.
We do not know why, but other than Geraldine’s
marathon C7 activity, nothing much happened until
October, 2004.
We believe the Chatfield/Gaggero strategy was to pursue
Geraldine and prevent her from obtaining what was a
necessary C7 protection, before the main trial..
October-
December, 2004 At last we had a trial date..Dec,13, 2004. Our budget for
pre-trial and trial was $50,000.00. This was to come from

9. the $25,000.00 retainer that Resch, Polster had. In
addition, JAR had been appointed executor to one of his
clients, and this fee of $26,000.00 was anticipated in Feb.
2005. However,pre-trial expenses came in at $42,500.00,
thus posing a further financial crisis.
The trial was delayed due to other factors until June 6,
2005. This gave us time, once again, to see how we
could stay in the fight. All this time, we had equity in
our house, but we had never been able to access this
because of the unsecured lien. In May, 2005, our
lawyers, Resch, Polster, realizing our financial situation,
recommended that we accept a small $25,000.00
damages settlement, and fight over legal expenses.
We reluctantly agreed.
Jan.2005 In January, 2005 we had contacted a special department
in Wells Fargo, who pre-qualified us for a loan. This was
put on hold through tax season, and opened up in
May, 2005. Our intention was to pay off the $75,000.00
lien, put aside the $25,000.00 for the agreed damages, and
to have approximately $40,00.00 for legal fees. As of the
end of June, 2005, our retainer has been exhausted, and
we were then starting to owe Resch, Polster. At this stage
we had no knowledge what future legal expenses would be
required.
Once again, the Chatfield/Gaggero harassment continued.
Chatfield found out we were refinancing, and threatened to
sue both Wells Fargo and the Escrow company, if the loan
went through before the final judgement on legal fees.
Once again, we are prevented from putting on a necessary
defense due to the writ of attachment that was put on the
property in a most dubious manner in October, 2002.
July 11, 2005 Chatfield/Gaggero put temporary protective order on our
assets/house. Once again we are prevented from accessing
our equity and defending ourselves.
Nothing important or significant has come to the surface
since January, 2003.

10. Everything since, has been harassment.
Declaration of John A. Redmond & Maureen C. Redmond August 6, 2005.

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