Draft 7/10/05 A Classsic Case of Overreach.
A Malicious Use of the Law.
SMLLC v Redmond et al.
The "legal " events of the period
October 1, 2002 to October 22, 2002.
This covers the actions of David Chatfield directed by Stephen
Gaggero, against John (JAR) and Maureen (MCR) Redmond.
( Activities against Geraldine Redmond are not covered in this
declaration).

In reviewing our legal files, we found the following letter from
Jeffrey Cowan to David Chatfield, dated April 2, 2003. The
following are excerpts from that letter:-
“Today, you filed and personally served a motion to amend the
complaint, with a hearing on April 23, 2003. By setting your
motion on minimum notice (making defendant’s 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 manner of
Service of papers should not be used to the disadvantage of the
Party receiving the papers”.
In the p.s. to the letter, Mr. Cowan concludes, “This issue is another
Example of how plaintiff has unnecessarily incurred legal fees in this
action”.
Let us look at how events of October 1, 2002 to October 22, 2002
meet these professional standards:-
First of all….Background:
(1) John A. and Maureen C. Redmond were guarantors to the
lease.
We had no day to day involvement in the operations of
Somerset Farms LLC. Geraldine was the manager.
(2) We had no lawyer and no warning that we needed a lawyer.
(3) Both John and Maureen were more than fully occupied in their
professional occupations. John, a sole proprietor tax preparer
with no staff after April 15, extremely busy meeting the last
October 15 filing deadline. Maureen, just as busy looking after
Autistic children, which involved extensive evening discussions
with parents.
(4) Chatfield filed a complaint and a writ of attachment against the
three of us and the LLC.
The dates of this activity were October 4 to October 11, 2002.
Notification:
(1) A message was left on Maureen’s answering machine
(310 745 1259) on April 8, 2002.

(2) Chatfield left a message at the tax office on April 8, 2002 with
Barbara Hazelhurst. He stated later, for the record, that she
was JAR’s assistant. That is incorrect. She has her own
business.
(3) On Friday October 11, 2002, Maureen called Chatfield and
asked him to send paperwork.
(4)On Friday October 11, 2002 at 2.30 p.m. John called Chatfield
and asked him to send paperwork.
(5)Friday October 11, 2002 server delivers papers at the tax office
to Barbara Hazelhurst at about 4.30 p.m. John was not
present.
(6)Tuesday October 15, 2002, Maureen finds two papers attached
to the front door at 12808 Greene Ave, and one paper was
delivered to the tax office at 142 Lincoln Blvd., Venice.
(7)Tuesday October 15, 2002 we find that our 3 bank accounts at
Jackson Federal Bank have been attached. This includes
Social Security.
(8)Received papers from attorney Harold Gould for Somerset
farms LLC.
(9) October 16, 2002 we had first meeting with attorneyJeffrey
Cowan.
However, we had no funds to retain him.
(10)October 18, 2002 John receives mailing ex parte(what does
that mean?) writ of attachment on 12808 Greene Ave and
bank accounts. Mailing from Oxnard, but no return address.
Maureen receives same on same date.
(11)October 21, 2002 John receives summons at his tax office.
Letter mailed October 17, 2002 from Oxnard. No sender
address.
(12) Checks start to bounce at Jackson Federal, including letters
from credit card companies.
(13) We are now one month behind on our mortgage. Hitherto, we
have had an immaculate record.
(14) Letters from suppliers and clients.
(15) To add insult to injury, we examine declaration of Mark
Maravelas, who “keeps the books and records for plaintiff”.
We find that number 9 “plaintiff prays for damages of
$63,110.19”.
However, if one reviews the details of his declaration, they
Only add up to $38,895.00.

Conclusion:
This was unprofessional conduct under 7.12(b)(1).
The way this first legal series of events was conducted has profound
implications:-
(1) A reasonable settlement will not be achieved.
(2) Stephen Gaggero will go to any legal lengths and pay any
sum of money to destroy the Redmonds.
(3) The clue to this vendetta lies in the restraining order incident.
(4) The Redmonds either have to surrender in an abject manner
or fight a goliath with no ability to access our equity in our
house.
.
Addendum:
We now have David Chatfield’s invoice no. 20021023 dated
October 23,2002 for $30,150.00. If one reviews this invoice, one
will note that actions were taken at a furious pace to get key
control features done before the Redmonds got legal
representation.
(1) This is equally malicious. Some of it reads like a KGB
examination. It talks about “asset search”, “investigator”,
“meeting with sheriff”, “research on Redmond court
records and history”.
(2) If Chatfield and Gaggero wanted to find out more about JAR in
a less expensive manner, they could have gone to 142 Lincoln
Blvd.,Venice ,CA 90291. On the window they would have seen
he was a licensed tax preparer, a Notary Public, a financial
representative and an insurance agent. Phone calls to
Sacramento and NASD would reveal that he had 22years in
taxes,
21 years as a notary public (I believe the FBI check you out
every time you renew your notary license), 15 years in
investments with the same broker, and 9 years in insurance.
(3)We note Chatfield’s travel and meeting with Georgia Jorden
and subsequent declaration. There is a major conflict in the

veracity of the facts between this declaration and a prior
declaration filed by Georgia Jorden.
Addendum Conclusion:
It is important, while reading these extravagant actions, to return to
basics.
This is a simple landlord/tenant dispute fought over one month’s rent,
a controversial clause 5 ( net income is net income), disputed
improvements and some repairs. Judges deal with such conflicts on
a daily basis.
This could have been resolved without recourse to the lawcourt.
As JAR said inhis September 20,2002 letter to Stephen Gaggero,
“In conclusion, you are a good businessman. We have both seen this
situation before. Let’s work out a solution and get on with our lives”.