Motion for Protective Order
25PR002411: IN THE MATTER OF: PUETT FAMILY TRUST 06/17/2026 Hearing on Motion - Other Motion for Protective Order in Department 129
Tentative Ruling
MOTION FOR PROTECTIVE ORDER; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF STEVEN H. KUHN; PROOF OF SERVICE
Filed: 4/17/2026
Re: The Puett Family Trust, dated February 28, 2026
Moving Party: Respondent/Co-Settlor Charles Puett Attorney: Steven Kuhn, (415) 937-7358
Responding Party: Scott Kiernan, Petitioner/Trustee Attorney: Madeline Giles, (916) 558-6000
NOTICE: Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative ruling may be downloaded off the courts website. If the party does not have online access, they may call the dedicated phone number for the Probate Department at (916) 875-2529 between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00 p.m. the court day before the hearing, no hearing will be held.
Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings. The Department 129 Zoom Link is https://saccourt-cagov.zoomgov.com/my/sscdept129 and the Zoom Meeting ID is 161 3352 9231. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED.
Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.pdf.
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25PR002411: IN THE MATTER OF: PUETT FAMILY TRUST 06/17/2026 Hearing on Motion - Other Motion for Protective Order in Department 129
A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Courts Approved Official Reporter Pro Tempore list.
Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporters Office and an official reporter will be provided.
TENTATIVE RULING Movant and Objector/Respondent Charles P. Puetts (Respondent) motion for protective order is CONTINUED as follows.
Respondent is the co-settlor and surviving settlor of the Puett Family Trust dated February 28, 2007, which Respondent created with his spouse, Betsy D. Puett. They were married from December 27, 1997 until Ms. Puetts death on November 9, 2024. Prior to Ms. Puetts passing, she and Petitioner executed an amendment on March 10, 2017. The trust was restated on December 7, 2017, and amended again on November 7, 2024.
When Ms. Puett died, Respondent became the sole trustee, until his removal on June 10, 2025 due to his incapacity. Petitioner Scott Kiernan (Petitioner) then became successor trustee pursuant to the trust terms. On July 16, 2025, Petitioner filed a Petition to Determine Ownership of Real Property and Personal Property as it relates to the trust. Respondent filed an objection to Petitioners petition on August 25, 2025.
On December 3, 2025, Petitioner filed a Petition for Order Enforcing No-Contest Clause. Respondent then filed a special motion to strike (anti-SLAPP) on January 28, 2026, which was denied.
Respondent now moves to strike the discovery sets propounded on him on March 16, 2026, or to limit the discovery to 35 special interrogatories and 35 requests for admission. Petitioner opposes.
Respondent, as the party responding to the discovery requests, is permitted to bring forth this motion for protective order under Code of Civil Procedure sections 2030.090, 2033.080, 2023.010, and 2031.060.
A motion for protective order must include adequate meet and confer efforts and demonstrate good cause. (Code Civ. Proc., § 2030.090(a)-(b), 2033.080(a)-(b), and 2031.060(a)-(b).) Meet and confer efforts require that counsel attempt to talk the matter over, compare their views,
SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO
25PR002411: IN THE MATTER OF: PUETT FAMILY TRUST 06/17/2026 Hearing on Motion - Other Motion for Protective Order in Department 129
consult, and deliberate. (Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1294.) The Court finds that the parties did not adequately meet and confer. Respondent indicates he attempted meet and confer efforts by sending a seven-page letter detailing the concerns with the discovery, to which Petitioners counsel expressed disagreement, stating, I do not believe it will be meaningful to engage on each point youve raised, as I do not see us reaching agreement. (Steven Kuhn Declaration, Exhibit 11.) While Petitioners opposition papers substantively detailed the disagreements and alleged deficiencies of Objectors counsels meet and confer letter, no such descriptions or discussion was attempted as part of the meet and confer efforts. This is not sufficient to establish the parties attempted to talk the matter over, compare their views, consult, and deliberate. (Id.)
The motion is CONTINUED to August 26, 2026, at 1:30 p.m. in Department 129 at the William R. Ridgeway Family Relations Courthouse. The parties may file a joint statement detailing their meet and confer efforts no later than August 1, 2026.
This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; CRC, Rule 3.1312.)