MOHAMMAD ZAMIRI LIVING TRUST

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

Tentative Ruling

NOTICE OF MOTION AND MOTION OF FARAH ZAMIRI TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES – GENERAL, SET ONE; REQUEST FOR MONETARY SANCTIONS

Filed: 4/10/2026

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

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

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.

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 further responses by Azar Zamiri (“Respondent”) regarding Petitioner’s request for responses to form interrogatories, set one. 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 served Respondent with the form interrogatories, set one, on January 16, 2026, and responses were due March 20, 2026. (Memorandum of Points and Authorities [“MPA”], 2:9-12; Declaration of Stephanie Steevie [“Steevie” Decl.], ¶ 3.) Petitioner indicates the responses provided were “largely deficient” and not code-compliant. (MPA, 2:13-14.) Petitioner’s counsel asserts that informal meet and confer efforts to resolve the matter prior to the filing of this motion were unsuccessful. (MPA, 2:17-27.) Petitioner initially sought sanctions totaling $4,185. (MPA, 6:7-10.) 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, §

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

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

2024.020. (Opposition, 2:6-12.) Respondent further argues that the responses were sufficient, and Respondent was not required to respond to form interrogatories 17.1, 50.1, 50.2, 50.3, 50.4, 50.5, and 50.6. (Opposition, 3:28-4:1.) Petitioner withdrew her motion to compel as to form interrogatories 17.1, 50.1, 50.2, 50.3, 50.4, 50.5, and 50.6 on May 29, 2026. Respondent seeks sanctions totaling $2,500. (Opposition, 6:6-7.)

In reply, Petitioner again asserts Respondent’s responses lack merit and warrant sanctions. (Reply, 3:3, 5:7-17.)

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 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).)

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.

Petitioner alleges the responses to the form interrogatories 12.1, 12.2, 12.3, and 15.1 remain insufficient. Respondent objected to interrogatories 12.1, 12.2, and 12.3 on the basis that the term ‘incident’ was vague and ambiguous. However, Petitioner indicates the definition was provided as, “the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding.” (MPA, 3:21-22.) Petitioner further indicates the definition of ‘incident’ was provided as part of the meet and confer efforts, and “plainly refers to the acquisition and ownership of the five assets at issue in this litigation ” (Id., at 3:23-24.) It is unclear whether this additional definition was provided at any point prior to

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

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

the meet and confer efforts. Nonetheless, the definition provided at the time of the service of the form interrogatories does not plainly and unambiguously include “the acquisition and ownership” of various property. Thus, the Court denies the motion to compel further response as to interrogatories 12.1, 12.2, and 12.3.

The request to compel further response to form interrogatory 15.1 is granted. Respondent simply maintains the interrogatory is “not applicable.” This does not comply with Code Civ. Proc., § 2030.210 (a)(1)-(3) as it is not a valid objection, nor does the response provide a “complete and straightforward” response. (Code Civ. Proc., § 2030.220 (a).) The motion to compel further response to form interrogatory 15.1 is granted.

The motion is GRANTED in part. No later than July 22, 2026 at 10 a.m. shall Respondent serve the requested response to interrogatory 15.1.

The request for sanctions by both parties is denied as the motion and opposition were made with substantial justification.

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