MOHAMMAD ZAMIRI LIVING TRUST

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel in Department 126

Tentative Ruling

NOTICE OF MOTION AND MOTION OF FARAH ZAMIRI TO COMPEL DISCOVERY RESPONSES AND REQUEST FOR SANCTIONS

MOTION FILED: 4/16/2026

RE: The Mohammad Zamiri Living Trust dated July 19, 2022

MOVING PARTY: Petitioner and Co-Trustee Farah Zamiri Attorney: Tyson Hubbard, (916) 444-1000

RESPONDING PARTY: 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

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel in Department 126

Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/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.

TENTATIVE RULING Petitioner and Movant Farah Zamiri (“Petitioner”) seeks to deem responses admitted following the service of request for admissions on non-party Yasamin Zamiri. The motion is unopposed and DENIED as follows.

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

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 written interrogatories and requests for production of documents on Ms. Zamiri. Ms. Zamiri’s deadline to respond was February 20, 2026. Petitioner alleges no responses were provided. (Memorandum of Points and Authorities [“MPA”], 2:13-19; Declaration of Stephanie Steevie [“Steevie” Decl.], ¶ 5-6.) Petitioner’s counsel asserts informal resolution prior to the filing of this motion was unsuccessful. (MPA, 3:14-17.) Petitioner initially sought sanctions totaling $3,975. (MPA, 4:11-13.) 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, 2:8-14.) Respondent further argues that Ms. Zamiri various discovery requests were improper because Ms. Zamiri is not a party to the action. (Opposition, 2:24-26.)

In reply, Petitioner reiterates her position that the motion may still be heard as timely and Ms.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24PR002924: MOHAMMAD ZAMIRI LIVING TRUST 07/01/2026 Hearing on Motion - Other Motion to Compel in Department 126

Zamiri is a party to the action. (Reply, 5:4-11, 3:3-4.) While discovery procedures “are generally available for use” in probate accountings and special proceedings, Petitioner does not clearly establish the timeliness of her motion. (Coberly v. Superior Court of Los Angeles County (1965) 231 Cal.App.2d 685, 690.)

The motion is denied as it seeks discovery through an improper method to a non-party. Code of Civil Procedure, § 2020.010 establishes that a party may seek discovery from a non-party by oral deposition, written deposition, or deposition for production of business records. (Code Civ. Proc., § 2020.010(a)(1)-(3).) While Petitioner indicates that service of the petition and notice of hearing on Ms. Zamiri “is what brings a respondent before the probate court and is what triggers the discovery rules of the Code of Civil Procedure,” Petitioner cites no authority for this proposition. (Reply, 3:7-8.)

“A petitioner in a proceeding under Section 17200 may commence discovery upon a trustee in accordance with the same time periods set forth in the Civil Discovery Act Nothing in this section shall alter when a respondent in such a proceeding may commence discovery.” (Prob. Code, § 17201.1.) Additionally, while “[a] petitioner in a proceeding under Section 850 may commence discovery upon any person who receives notice of the hearing pursuant to subdivision (a) of Section 851,” the methods of discovery are still subject to the Civil Discovery Act. (Prob. Code, § 851.1.) Because Petitioner has not distinguished how Ms. Zamiri, who has not appeared as a respondent in this case, is a party to the action rather than merely “any person who receive[d] notice,” seeking discovery by way of requests for admission is improper. (Code Civ. Proc., § 2020.010(a).) The motion is denied on this basis.

Counsel for Respondent is admonished for filing an opposition on behalf of a party who is not counsel’s client. (See Daniel Near’s Response to Supplemental Meet and Confer Declaration of Tyson E. Hubbard, 6/26/2026, pg. 2 ¶ 4.3 [“Mr. Near has a single client ”].)

Because Petitioner improperly sought requests for admission from a nonparty, the circumstances reflect an award of sanctions would be unjust. The motion is denied in its entirety, including the requests for sanctions.

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