MOHAMMAD ZAMIRI LIVING TRUST

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel Respondent's Production of Documents in Department 126

Tentative Ruling

NOTICE OF MOTION AND MOTION OF FARAH ZAMIRI TO COMPEL RESPONDENT’S PRODUCTION OF DOCUMENTS; AND REQUEST FOR SANCTIONS

Filed: 4/8/2026

Re: The Mohammad Zamiri Living Trust dated July 19, 2022.

Moving Party: Petitioner/Co-Trustee Farah Zamiri Attorney: Tyson Hubbard, (916) 444-1000

Responding Party: Surviving Spouse Azar Zamiri Attorney: Dan Near, (916) 987-0808

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 court’s website. If the party does not have online access, they may call the dedicated phone number for the Probate Department at (916) 875-2526 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 126 Zoom Link is https://saccourt-cagov.zoomgov.com/my/sscdept126 and the Zoom Meeting ID is 160 5926 9604. 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-

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel Respondent's Production of Documents in Department 126

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.

TENTATIVE RULING Petitioner and Movant Farah Zamiri (“Petitioner”) seeks to compel document production by Respondent and surviving spouse Azar Zamiri (“Respondent”). The motion is GRANTED as follows.

Petitioner filed a Petition for Instructions on October 3, 2024, seeking confirmation of ownership of various shares of a corporation, and compelling execution of documents that would confirm the sale of the corporation in question. Petitioner filed a Petition for Instructions on October 3, 2024, seeking confirmation of ownership of various shares of a corporation, and compelling execution of documents that would confirm the sale of the corporation in question. A second petition for instructions was filed the same day, seeking determination of ownership of various real property assets allegedly held in trust.

Petitioner propounded various discovery requests on Respondent. Respondent’s purported deadline to respond was February 20, 2026. While timely responses were provided, Petitioner indicates Respondent did not produce any documents as part of this response. (Memorandum of Points and Authorities [“MPA”], 2:12-15; Declaration of Stephanie Steevie [“Steevie” Decl.], ¶ 5.) Petitioner’s counsel asserts at least three unsuccessful attempts at resolution prior to the filing of this motion. (MPA, 2:19-26.) Petitioner initially sought sanctions totaling $4,835. (Notice of Motion, 2:2.) Following additional meet and confer efforts, Petitioner seeks $14,225 in addition to the sanctions sought in this motion. (Supplemental Meet and Confer Declaration [“Supp. Decl.”], 7:7-8.)

In opposition, Respondent indicates that the motion was originally set for hearing on June 3, 2026, which does not comply with the timelines set forth in Code of Civil Procedure, § 2024.020. (Opposition, 2:22-28.) Respondent further argues that he did in fact produce the responsive documents “on the date and at the time specified by [Petitioner,]” and “[i]t was [Petitioner] who failed to be prepared to review Respondent’s responsive documents.” (Opposition, 4-6.) Respondent seeks sanctions totaling $2,500.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel Respondent's Production of Documents in Department 126

In reply, Petitioner again confirms that the documents have not been produced, and that the Court retains discretion to hear the untimely motion to compel. (Reply, 2:9, 4:24-27.)

This matter was continued on June 3, 2026 on the Court’s own motion to allow the parties to continue meet and confer efforts.

“Any party may obtain discovery by inspecting, copying, testing, or sampling documents, tangible things, land or other property, and electronically stored information in the possession, custody, or control of any other party to the action.” (Code Civ. Proc., § 2031.010 (a).)

“The party to whom a demand for inspection, copying, testing, or sampling has been directed shall respond separately to each item or category of item by any of the following: (1) A statement that the party will comply with the particular demand for inspection, copying, testing, or sampling by the date set for the inspection, copying, testing, or sampling pursuant to paragraph (2) of subdivision (c) of Section 2031.030 and any related activities. (2) A representation that the party lacks the ability to comply with the demand for inspection, copying, testing, or sampling of a particular item or category of item. (3) An objection to the particular demand for inspection, copying, testing, or sampling.” (Code Civ. Proc. § 2031.210(a).)

If a party fails to serve a timely response to a demand for inspection, copying, testing, or sampling, “[t]he party making the demand may move for an order compelling response to the demand.” (Code Civ. Proc., § 2031.300(b).) The party also “waives any objection to the demand.” (Id., at subd. (a).)

First, Respondent opposes on the grounds that the motion to compel is untimely. “Except as otherwise provided in this chapter, any party shall be entitled as a matter of right to complete discovery proceedings on or before the 30th day, and to have motions concerning discovery heard on or before the 15th day, before the date initially set for the trial of the action.” (Code Civ. Proc., § 2024.020(a).) “Except as provided in Section 2024.050, a continuance or postponement of the trial date does not operate to reopen discovery proceedings.” (Id., at subd. (b).) The register of actions reflects the Court granted all requests in Petitioner’s status report filed on May 4, 2026, including the request to reopen discovery. (Minute Order, May 12, 2026.) Thus, the Court declines to deny the motion on this basis.

Next, Respondent maintains that no date, time, or place was set to produce the documents. This is at odds with Petitioner’s documentation and thus rejected. (See Steevie Decl., Exhibit A.) Further, is unclear whether counsel produced the documents at Petitioner’s attorney’s office, or Respondent’s attorney’s office. (Opposition, 3:6-9.) Thus, both parties have demonstrated Respondent’s failure to produce the requested documents at the noticed time. The motion to compel production of documents is granted.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel Respondent's Production of Documents in Department 126

No later than July 22, 2026 at 10 a.m. shall Respondent produce the requested documents at Petitioner’s counsel’s office, or a mutually agreed upon time and place.

The motion is GRANTED. Sanctions are requested by both parties. Sanctions sought by Petitioner are mandatory and granted. Sanctions requested by Respondent are denied. (Code Civ. Proc., § 2031.320(b).)

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