The April 11 complaint filed in San Mateo County Superior Court alleges that Pooroushasb Parineh "willfully and maliciously fired two gun shots to the head of Parima" at their Woodside mansion on Fox Hill Drive on April 13, 2010.
The children allege in the complaint that their mother survived this attack for "some period of time," and that their father acted out of a motive to cash in on life insurance policies that would have paid out with Ms. Parineh's death.
Pooroushasb Parineh has been in county jail on a no-bail status on charges of premeditated murder for financial gain since his arrest in Sunnyvale on June 17, 2010, by deputies from the San Mateo County Sheriff's Office. He is the only suspect in the case.
Prosecutors alleged that Mr. Parineh, a real estate investor, had several properties in foreclosure, no liquidity and "enormous debt" at the time of his wife's death.
If Mr. Parineh, who was 64 at the time, is convicted, the apparently planned nature of the crime would make him subject to the death penalty or life in prison without the possibility of parole, according to the state penal code.
Among the damages from the death of their mother are the loss of her love, companionship, comfort, affection, society, solace, income and moral support, Ms. Parineh's children say in the complaint.
Austiag Hormoz Parineh resides in Orange County, and Austiaj and Khashayar Parineh in San Francisco County, according to the complaint.
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