MOHAMMAD ZAMIRI LIVING TRUST

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other to Compel Further Responses to Form Interrogatories Set One in Department 126

Tentative Ruling

NOTICE OF MOTION AND MOTION OF FARAH ZAMIRI TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; REQUEST FOR MONETARY 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 to Compel Further Responses to Form Interrogatories Set One 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 propounded various discovery requests on Respondent. Respondent’s purported deadline to respond was February 20, 2026. While timely responses were provided, Petitioner indicates Respondent’s responses were insufficient. (Memorandum of Points and Authorities [“MPA”], 2:12-17; Declaration of Stephanie Steevie [“Steevie” Decl.], ¶¶ 5, 10.) Petitioner’s counsel asserts at least three unsuccessful attempts at resolution prior to the filing of this motion. (MPA, 2:18-3:1.) Petitioner initially sought sanctions totaling $4,995. (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, 2:6-14.) Respondent further opposes the motion on substantive grounds, namely that each response to the special interrogatories is responsive and compliant. (Opposition, 25:22.) Respondent seeks sanctions totaling $5,000.

In reply, Petitioner argues that the responses are insufficient, 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

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other to Compel Further Responses to Form Interrogatories Set One in Department 126

continue meet and confer efforts.

“Any party may obtain discovery by propounding to any other party to the action written interrogatories to be answered under oath.” (Code Civ. Proc., § 2030.010 (a).) The party responding to written interrogatories shall responding in writing, and under oath, by any of the following: “(1) An answer containing the information sought to be discovered (2) An exercise of the party’s option to produce writings (3) An objection to the particular interrogatory.” (Code Civ. Proc., § 2030.210 (a)(1)-(3).) While the requests exceed the statutory maximum of specially prepared interrogatories, no such objection was made. (Code Civ. Proc., § 2030.030(c).)

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.

At issue in this matter are special interrogatories numbers 14, 20, 23, 24, 27, 32, 33, 38, 47, 48, 67, and 68, which Respondent’s responses merely state, “See documents produced in responses to Request for Production of Documents, Set No.1” (MPA, 3:26-27.), special interrogatories numbers 34, 56, 62, 69, 70, 78, 84, 88, and 94, which Respondent’s responses state, “unknown,” (MPA, 4:14.), and special interrogatories numbers 8, 9, 10, 11, 19, 29, 34, 35, 58, 59, and 74, which Petitioner alleges the responses lack merit and require further response or amendment.

Upon review of Petitioner’s supporting documentation (Steevie Decl., Exhibit 2), Respondent’s responses do not comply with Code Civ. Proc., § 2030.210 (a)(1)-(3), nor do the responses provide a “complete and straightforward” response as required by statute. (Code Civ. Proc., § 2030.220 (a); see also Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783-784 [“A party cannot state, ‘not applicable’ where the interrogatory is clearly applicable to him” or respond by stating “see my [responsive document].”].) Further response is required.

The motion to compel is GRANTED. No later than July 22, 2026 at 10 a.m. shall Respondent serve the requested responses on Petitioner’s counsel.

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