1 Kristine L.

Adams (SBN 213819)

ATTORNEY AT LAW
2 14411 Poplar Drive
3 Tustin, CA 92780
Telephone: (949) 642-6222
4
Attorney for Respondent,
5 David Beresford-Redman
6
7 SUPERIOR COURT IN AND FOR THE STATE OF CALIFORNIA
8 COUNTY OF LOS ANGELES, WEST DISTRICT
9 SANTA MONICA COURTHOUSE
10
11 In re ) Case No: SS019546
)
12 )
) RESPONDENT DAVID BERESFORD-
13 Norma Paula De Ahlf ) REDMAN’S EVIDENTIARY
Petitioner ) OBJECTIONS TO AND MOTION TO
14 ) STRIKE PORTIONS OF
) DECLARATIONS FILED BY
15 ) PETITIONER NORMA PAULA DE AHLF
)
16 )
David Beresford-Redman, ) Hearing Information
17 ) Date: June 22, 2010
Respondent ) Time: 8:30 a.m.
18 ) Courtroom: A - 104
)
19 )
20
21
22 Respondent David Beresford-Redman hereby submits his Evidentiary Objections to
and Motion to Strike Portions of Declarations filed by Petitioner Norma Paul De Ahlf in support
23
of her Application for a Temporary Restraining Order on the grounds that the portions are
24
inadmissible. For the Court’s convenience, within are verbatim excerpts of the Declarations with
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a line drawn through each objectionable portion of the Declarations, followed by the grounds for
26
the objections. Attached as Exhibit A are true and correct copies of the Declarations.
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EVIDENTIARY OBJECTIONS TO AND MOTION TO STRIKE
 1 DECLARATION OF NORMA PAULA DE AHLF, PAGE 1:
2 9. Prior to her death, Monica was having problems in her marriage and would often confide in
3 me the most intimidate details of their marital strife. [OBJECTION NO. 1 Argumentative;
4 Speculative; No Foundation; Irrelevance]. For example, Monica shared with me that Bruce had
5 been having an ongoing extramartial relationship with another woman. [OBJECTION NO. 2:
6 Speculative; No Foundation; Irrelevance; Hearsay]. She shared with me that she was monitoring
7
his emails and phone calls to the other woman. [OBJECTION NO. 3: Speculative; No
8
Foundation; Irrelevance; Hearsay]. She shared with me that although Bruce and his father, David,
9
did not have a strong relationship, they were spending a lot of time together, speaking on the phone
10
several times a day. [OBJECTION NO. 4: Argumentative; Speculative; No Foundation;
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Irrelevance; Hearsay]. Monica shared with me her concerns that Bruce and his father, David, were
12
planning something. [OBJECTION NO. 5: Argumentative; Speculative; No Foundation;
13
Irrelevance; No Personal Knowledge; Hearsay]. Monica also shared with me that Bruce and his
14
father, David, had taken approximately $25,000.00 out of Monica and Bruce's joint account to pay for an
15
16 outstanding debt incurred by Bruce's father David. [OBJECTION NO. 6: Argumentative;

17 Speculative; No Foundation; No Personal Knowledge; Irrelevance; Hearsay]. Monica also

18 shared with me that Bruce and his father, David, took additional money from Bruce and Monica's joint

19 account and bought either stocks or bonds in Bruce's name alone. [OBJECTION NO. 7:

20 Argumentative; Speculative; No Foundation; No Personal Knowledge; Irrelevance;

21 Hearsay].
22
23 DECLARATION OF NORMA PAULA DE AHLF, PAGE 2:
24 10. Bruce was aware of the close relationship I shared with Monica. [OBJECTION NO. 8:
25 Argumentative; Speculative; No Foundation; Irrelevance] Bruce was aware that I knew about
26
the extramarital affair and well as the recent activities between he and his father regarding their joint
27
banking account. [OBJECTION NO. 9: No Foundation; Irrelevance; No Personal
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EVIDENTIARY OBJECTIONS TO AND MOTION TO STRIKE
 1 Knowledge; Prejudicial effect outweighs probative value to this matter;] Monica made it
2 known to Bruce that she was relaying everything that he was doing to me. [OBJECTION NO. 10:
3 Argumentative; No Foundation; No Personal Knowledge; Irrelevance; Prejudicial effect
4 outweighs probative value to this matter; hearsay] This made Bruce extremely angry at me.
5 [OBJECTION No. 11: Argumentative; No Foundation; Conclusory; Irrelevance;
6 Prejudicial effect outweighs probative value to this matter ]
7
8
11. Several weeks before their trip to Mexico, Monica told me that she was going to withdraw a
9
lot of money from their joint account. In the following several days, she withdrew the money, she
10
changed the locks of their house and threw Bruce's clothes in trashbags and out onto the street.
11
[OBJECTION NO. 12: Irrelevance; Prejudicial effect outweighs probative value to this
12
matter; No Foundation; No Personal Knowledge; Hearsay; Prejudicial effect outweighs
13
probative value to this matter]
14
15
16 12. She then took her children to Hawaii for several days to figure out how to handle her martial

17 problems and decide whether or not to leave Bruce. [OBJECTION NO. 13: Speculative;

18 Irrelevance; No Foundation; No Personal Knowledge; Prejudicial effect outweighs

19 probative value to this matter]

20
21 l3. Bruce constantly called Monica in Hawaii, trying to convince her to take him back.
22 [OBJECTION NO. 14: Argumentative; Irrelevance; No Foundation; No Personal
23 Knowledge; Prejudicial effect outweighs probative value to this matter]
24
25 14. When Monica and the kids returned from Hawaii, Bruce was at the house. [OBJECTION
26
NO. 15: Irrelevance; No Foundation; No Personal Knowledge; Prejudicial effect
27
outweighs probative value to this matter].
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EVIDENTIARY OBJECTIONS TO AND MOTION TO STRIKE
 1 15. Despite all of their problems, Monica cared deeply for Bruce and wanted to have her family

2 together. [OBJECTION NO. 16: Argumentative; Irrelevance; No Foundation; No Personal

3 Knowledge; Prejudicial effect outweighs probative value to this matter]. So, when Bruce
4 suggested that they go on a family trip to Mexico, she agreed. [OBJECTION NO. 17: Irrelevance;
5 No Foundation; No Personal Knowledge; Prejudicial effect outweighs probative value to
6 this matter]. Bruce made the reservations, he chose the hotel and completely planned the trip.
7
[OBJECTION NO. 18: Irrelevance; No Foundation; No Personal Knowledge; Prejudicial
8
effect outweighs probative value to this matter].
9
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16. I told her not to go on the trip because it was not where she wanted to travel to and I was
11
extremely suspicious that he would make travel arrangements since in their eleven years of marriage, he
12
had never planned a vacation or made the travel arrangements, Monica always did. [OBJECTION NO.
13
19: Argumentative; Conclusory; Irrelevance; No Foundation; No Personal Knowledge].
14
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16 18. Since her death, I have been running the restaurant with the help of her sisters, Carla and

17 Jeane. Bruce and his father, David, have never had anything to do with Zabumba. [OBJECTION NO.

18 20: Argumentative; Conclusory; Speculative; No Foundation; No Personal Knowledge]. I

19 would approximate that Bruce has been to the restaurant less than once a month for the seven years that I

20 have been working there. [OBJECTION NO. 21: Irrelevant; Speculative; Conclusory; No

21 Foundation; No Personal Knowledge; Improper Opinion; Prejudicial effect outweighs

22 probative value to this matter]. Bruce's father, David, has been to the restaurant less than four times
23 per year in all of the time that I have worked there. [OBJECTION NO. 22: Speculative; No
24 Foundation; No Personal Knowledge; Prejudicial effect outweighs probative value to this
25 matter].
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EVIDENTIARY OBJECTIONS TO AND MOTION TO STRIKE
 1 19. On May 29, 2010, at 10:00 p.m., I was working at Zabumba. The restaurant was closed that

2 day as I was preparing food for the memorial service we were holding for Monica the following day. The
3 doors were shut, the lights outside were turned off and the sign said closed. We were not open for
4 business. There were only a couple of us in the restaurant at the time. My car, which is known to Bruce
5 and his father [OBJECTION NO. 23: Conclusory; Speculative; No Foundation; No Personal
6 Knowledge; Prejudicial effect outweighs probative value to this matter], was the only car
7
parked next to Zabumba. [OBJECTION NO. 24: Speculative; No Foundation]. Further, neither
8
Bruce nor his father, David, would have any need either business or personal. for being at the restaurant.
9
[OBJECTION No. 25: Argumentative; Conclusory; Speculative; No Foundation; No
10
Personal Knowledge; Prejudicial effect outweighs probative value to this matter].
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Monica's sisters were recently granted temporary guardianship over the restaurant. [OBJECTION No.
12
26: No Foundation; No Personal Knowledge].
13
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21. He asked another one of the people helping us that day, in a very threatening way
15
16 [OBJECTION No. 27: Argumentative; Speculative; No Foundation; No Personal

17 Knowledge], "Where is Norma? I want to talk to Norma." He was very demanding. [OBJECTION

18 No. 28: Argumentative; Conclusory; Speculative; No Foundation; No Personal

19 Knowledge]. The employee came into where I was standing and was literally shaking. [OBJECTION

20 No. 29: Argumentative; No Foundation; No Personal Knowledge]. She told me that Bruce’s

21 father was there looking for me.

22
23 22. Bruce's father demanded that he speak to me. [OBJECTION No. 30: Argumentative;
24 Speculative; No Foundation; No Personal Knowledge; Prejudicial effect outweighs
25 probative value to this matter]. He looked at me, with his hand in his shirt, as if he had a weapon.
26
[OBJECTION No. 31: Argumentative; Speculative; No Foundation; No Personal
27
Knowledge]. I started to scream and yell, "Get out of here. I don't want this guy here. I don't want to
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 1 see this guy." The way he was holding something inside of his shirt and looking at me so menacingly

2 [OBJECTION No. 32: Conclusory; Argumentative; Speculative; No Foundation; No

3 Personal Knowledge], I honestly believed that he wanted to kill me. [OBJECTION No. 33:
4 Argumentative; Speculative; No Foundation].
5
6 24. I am afraid of him and fear that he will harm me because of all of the information I have
7
regarding his son and Monica. [OBJECTION No. 34: Argumentative; Speculative; No
8
Foundation; No Personal Knowledge; Prejudicial effect outweighs probative value to this
9
matter]. He has caused me severe emotional distress as I keep reliving the moment when he was staring
10
me down with his hand in his shirt as if he was hiding a weapon. [OBJECTION No. 35: Conclusory;
11
Argumentative; Speculative; No Foundation; No Personal Knowledge]. I truly thought that
12
he was going to shoot me. [OBJECTION No. 36: Conclusory; Argumentative; Speculative; No
13
Foundation]. I fear that if I do not have a restraining order against him, he will attempt to harm me in
14
some way. [OBJECTION No. 37: Conclusory; Argumentative; Speculative; No Foundation;
15
16 No Personal Knowledge].

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DECLARATION OF MICHAEL MELAIR, PAGE 1:
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1. My name is Michael Melair and my date of birth is March 20, 1963.
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2. I am a friend of Norma Paula De Ahlf. On May 29, 2010, I went to Zabumba to help Norma
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prepare for Monica's memorial the following day.
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26 3. At about ten p.m., I was back in the kitchen cleaning some of trays when I heard someone said,

27 ''Michael, can you get this guy to leave?" I walked into the front kitchen area when I saw an older man

28 standing there with his right hand in his shirt. It looked to me that he was holding a gun.

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EVIDENTIARY OBJECTIONS TO AND MOTION TO STRIKE
 1 [OBJECTION No. 38: Argumentative; Speculative; No Foundation]. I immediately became
2 concern that he would physically harm or shoot one of us. [OBJECTION No. 39: Argumentative;
3 Speculative; No Foundation].
4
5 4. I walked up to him and told him that we were closed and he said, "Is Norma here?" He looked
6 around to the kitchen area again repeating, "Is Norma here? I want to talk to Norma." When he saw her
7
[OBJECTION No. 40: No Foundation; No Personal Knowledge], he stated, "I want to talk to
8
Norma." During the entire exchange, he had his hand in his shirt as if he was concealing a weapon.
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[OBJECTION No. 41: Argumentative; Speculative; No Foundation].
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5. Bruce's father, David [OBJECTION No. 42: No Foundation; Prejudicial effect
12
outweighs probative value to this matter], created such panic in the restaurant that everybody
13
started yelling and screaming for him to get out of the restaurant. [OBJECTION No. 43:
14
Argumentative; Speculative; No Foundation; No Personal Knowledge]. Bruce's father, David
15
16 [OBJECTION No. 44: No Foundation; Prejudicial effect outweighs probative value to this

17 matter], left the restaurant soon thereafter. I immediately called 911.

18
19 6. There is no doubt in my mind that Bruce's father, David Beresford-Redman, went to the

20 restaurant to harm Norma. [OBJECTION No. 45: Argumentative; Speculative; No Foundation;

21 No Personal Knowledge; Prejudicial effect outweighs probative value to this matter]. As I

22 told the police [OBJECTION No. 46: No Foundation], I am not associated with either party in any
23 way but I strongly believe that he had a gun [OBJECTION No. 47: Argumentative; Speculative;
24 No Foundation; No Personal Knowledge] and came into the restaurant with a purpose to do harm
25 to Norma. [OBJECTION No. 48: Argumentative; Speculative; No Foundation; No Personal
26
Knowledge]
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EVIDENTIARY OBJECTIONS TO AND MOTION TO STRIKE