JACOBS vs AMEEN, et al.

request of the court or any other party.

(Cal. Rules Court, Rule 2.257(b).)

The proof of service of the motion fails to comply with Rule 2.257 because, even though the document was filed electronically, the electronic signature is not “unique to the declarant, capable of verification, under the sole control of the declarant, and linked to data in such a manner that if the data are changed, the electronic signature is invalid” or “[t]he declarant, before filing, has physically signed a printed form of the document.”

The motion is DROPPED.

Defective service deprives the court of jurisdiction to act. (Lee v. Placer Title Co. (1994) 28 Cal.App.4th 503, 509.)

RFAs (set one)

Furthermore, the motion to deem RFAs (set one) admitted would have been denied on the merits if jurisdiction existed. In the case at bar, Plaintiff personally served Zahid with the summons and first amended complaint (“FAC”) on October 14, 2025 at 4721 Large Oak Ct. Sacramento, CA 95841 (“Large Oak Address”). (Declaration of Adam Jacobs (“Jacobs Decl.”), Ex. C.) Plaintiff mail-served Zahid with the RFAs (set one) on October 24, 2025 at the Large Oak Address. (Id., Ex. A.) On November 13, 2025, Zahid filed his answer to the first amended complaint. The address on Zahid’s answer is 5546 Brinef Drive, Sacramento, CA 95841. (“Brinef Drive Address”).

Here, although Zahid had been personally served with the summons and FAC at the Large Oak Address, there is no showing that the Large Oak Address is actually Zahid’s mailing/service address. The Large Oak Address is merely the location at which Zahid was personally served with the summons and FAC. Section 128.7(a) requires that every pleading “shall state the signer’s address . . . .” Zahid’s answer shows his address as the Brinef Drive Address. Since Plaintiff mail-served Zahid with RFAs (set one) at the Large Oak Address, Plaintiff failed to properly serve Zahid with RFAs (set one).

RFAs (set two)

The motion to deem RFAs (set two) would have been dropped on the merits for the additional reason that the proof of service of the RFAs (set two) bears only a typed “/s/” signature, rather than original wet signatures or properly authenticated electronic signatures. This violates Rule 2.257.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV022511: JACOBS vs AMEEN, et al. 06/16/2026 Hearing on Motion to Deem Request for Admissions Admitted in Department 16C

Plaintiff’s request for monetary sanctions against Zahid is DENIED.

Defendant Anwar

Plaintiff moves to deem RFAs (set one) and RFAs (set three) admitted against Anwar. Anwar has opposed the motion on the merits, which waives any defects in service.

RFAs (set one)

Plaintiff served the RFAs (set one) on October 20, 2025. (Jacobs Decl., Ex. H.) On December 26, 2025, Anwar served verified responses to the RFAs.

In response to a motion to deem matters admitted, the Court shall deem matters admitted “unless it finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033.220.” (Code Civ. Proc. §2033.280, subd. (c).) Based upon the evidence provided in opposition, the Court finds that Anwar has served “before the hearing” on this motion, verified responses that substantially comply with Code of Civil Procedure section 2033.220. (Declaration of Ron Assadi (“Assadi Decl.”), Exs. D-G.) Accordingly, the motion is DENIED.

Plaintiff requests monetary sanctions against Anwar pursuant to Code of Civil Procedure section 2033.280(c) which states “[i]t is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion.” Here, Anwar’s failure to serve a timely response necessitated this motion. Accordingly, the Court will award Plaintiff $60 in monetary sanctions for the filing fee on the motion. Sanctions shall be paid by no later than July 7, 2026. If not paid by that date, Plaintiff may prepare for the Court’s signature a formal order granting the sanctions, which may then be enforced as a separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)

RFAs (set three)

The motion to deem matters admitted is DENIED. Anwar timely served responses to the RFAs. (Assadi Decl., Exs. H-I.) Plaintiff takes issue with the substance of Anwar’s responses. Plaintiff, however, did not file a motion to compel further responses to the RFAs or a separate statement as required by Cal. Rules of Court, Rule 3.1345.

Defendant Niran:

Plaintiff moves to deem RFAs (set two) admitted against Niran. Niran has opposed the motion

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV022511: JACOBS vs AMEEN, et al. 06/16/2026 Hearing on Motion to Deem Request for Admissions Admitted in Department 16C

on the merits, which waives any defects in service.

The motion to deem matters admitted is DENIED. Niran timely served responses to the RFAs. (Assadi Decl., Exs. B-C.) Plaintiff takes issue with the substance of Niran’s responses. Plaintiff, however, did not file a motion to compel further responses to the RFAs or a separate statement as required by Cal. Rules of Court, Rule 3.1345.

Plaintiff’s request for monetary sanctions against Niran is DENIED.

Anwar and Niran’s request for monetary sanctions is DENIED.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; CRC Rule 3.1312.)

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you must call the Law and Motion Oral Argument Request Line at (916) 874-2615 by 4:00 p.m. the Court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

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 16C Zoom Link is https://saccourt-ca-gov.zoomgov.com/j/16030877014 To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID 16030877014. 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

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV022511: JACOBS vs AMEEN, et al. 06/16/2026 Hearing on Motion to Deem Request for Admissions Admitted in Department 16C

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/courtreporters/docs/crtrp-13.pdf.

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 Court’s 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 Reporter’s Office and an official reporter will be provided.