The short answer is that you can't open documents in Photoshop with Scripting Bridge.
Apple's docs really spell it out like it is. All classes must have a container, which is a mutable array, that they need to be added to before they can be acted upon, as shown in the generated header...
@interface photoshopCS4Application : SBApplication
- (SBElementArray *) documents;
- (SBElementArray *) fonts;
- (SBElementArray *) notifiers;
... and that is the complete list of top-level containers available to us. The open command requires a photoshopCS4OpenOptions to be generated and populated. Because the API doesn't expose the array to store the newly created photoshopCS4OpenOptions object, we can't use a newly created photoshopCS4OpenOptions object. Therefore we can't make a target document and by extensions can't use the open command in Scripting Bridge. The same can be said of all the commands that require some kind of options object.
The only workaround that I have sorted out is to either open a document with native Applescript called from Cocoa or objc-appscript, and then parse the documents array looking for the one just opened. It's not ideal, but then neither is Scripting Bridge because it requires application developers write their scripting APIs in a very specific way that is not native to the OSA framework.