Khan v. City and County of San Francisco Department of Public Health

Background

Mahroofa Khan filed a joint discovery brief against the City and County of San Francisco Department of Public Health. Khan argued that many of the City’s responses to her requests for admission and interrogatories were insufficient and sought an order compelling further responses. The City maintained that most responses were sufficient and said it would provide further responses to a limited number of requests.

The court ruled that Khan’s request for relief was denied in part and granted in part.

Requests for Admission

Requests for admission are written discovery requests asking a party to admit or deny facts, the application of law to facts, opinions, or the authenticity of documents. Under Federal Rule of Civil Procedure 36, a responding party generally must admit, specifically deny, or explain why it cannot truthfully admit or deny the request.

The court denied Khan’s request for further responses to Requests for Admission Nos. 1, 12, 27, 44–46, 51, 66, and 72. The City had objected to and denied those requests, and the court held that a denial was a complete response. The City was not required to provide additional information supporting its denials in response to those requests.

The court also denied Khan’s request for further responses to Requests for Admission Nos. 6, 19, and 68. The City had admitted portions of those requests and denied other portions, which the court found complied with Rule 36.

For Request for Admission No. 7, the court directed Khan to identify the specific communication at issue by providing its date or a copy of the communication. Within seven days after Khan does so, the City must provide an amended response.

For Request for Admission No. 18, the court directed the parties to meet and confer in good faith to identify the document referenced in the request. The City must provide a further response by January 9, 2026.

For Requests for Admission Nos. 11, 36, 43, and 47, the court found that the City had not stated that it made the reasonable inquiry required when responding that it lacked sufficient information to admit or deny the requests. The City was ordered, if it had not already done so, to review documents within its control and make reasonable efforts to contact current and former employees who might have relevant information. It must then provide amended responses complying with Rule 36 by January 9, 2026.

For Requests for Admission Nos. 13 and 55, the court treated the City’s responses as denials because the City denied the underlying premise that Khan had made the relevant workplace complaints. The court found that no further responses were required, although the City could amend its answers to clarify them by January 9, 2026.

Interrogatories

Interrogatories are written questions that generally must be answered separately and fully under oath unless an objection applies. The City had agreed to provide a further response to Interrogatory No. 10, and the court ordered it to do so by January 9, 2026.

The court denied Khan’s requests for further responses to Interrogatory Nos. 3 and 7. The City’s response to Interrogatory No. 3 described alleged performance problems, including lateness and multiple absences, and Khan’s disagreement with that response did not justify compelling another response. For Interrogatory No. 7, the City stated that it had responded by producing responsive documents, and the court found no further response necessary.

For Interrogatory No. 6, the court overruled the City’s vagueness objection. It interpreted the interrogatory as asking for all formal and informal communications in which Khan reported unfair treatment, discrimination, harassment, or retaliation at work; the dates and recipients of those communications; and the City’s response. The court ordered the City to amend its response to provide that information by January 9, 2026.

Ruling

The court resolved the discovery dispute by denying in part and granting in part Khan’s request for relief. The order required the City to provide or amend particular discovery responses but did not require further responses to the requests the court found sufficient. The judge’s name is not legible in the provided opinion text; the signature identifies the judicial officer as a United States Magistrate Judge.