Joint Appendix - LawMemo

Plaintiff’s failure to file a timely charge of discrimination, a
necessary condition precedent to suit.
SECOND DEFENSE
To the extent Plaintiff has not filed her Complaint
within ninety (90) days of the date she received her Notice of
Right to Sue from the EEOC, her claims under Title VII, as
amended, are untimely.
THIRD DEFENSE
To the extent Plaintiff seeks recovery under Title VII,
as amended, for events that are not like or related to the
allegations in her EEOC charge she has failed to satisfy a
necessary condition precedent to suit.
FOURTH DEFENSE
To the extent Plaintiff’s claims occurred beyond the
applicable statutes of limitations period, those claims are
barred.
FIFTH DEFENSE
Plaintiff’s claims for equitable relief may not be tried
before a jury.
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