Courts around the country, faced with similar cases, have repeatedly reached this same conclusion and rejected such arguments. See, e.g., Ganny v. F.J.C. Security Services, Inc., No. 15-CV-1965 (JG)(JO), 2015 WL 4600745, at *4-5 (E.D.N.Y. July 28, 2015) ("[Plaintiff] knew as early as February 11, 2013, when he filed his NLRB charge, that Local 32BJ would not represent his grievance that the assignment to a non-HRA location violated the Settlement Agreement. The statute of limitations began to run at that point and Local 32BJ's refusal to take up the same grievance in September 2014 would not toll or otherwise preclude its running."); Dudich v. United Auto Workers Local Union No. 1250, 454 F. Supp. 2d 668, 678-79 (N.D. Ohio 2006) (denying continuing violation argument for hybrid § 301 claim based on repeated usage of incorrect seniority date because "[o]nce the original damage is lodged, the mere fact that the Defendants are ‘continuing’ to implement allegedly improper collective bargaining agreements does not convert Plaintiffs’ loss of jobs into a ‘continuing violation.’ ")

LSHV and the Union request that this Court take judicial notice of certain state administrative records: LSHV Exhibit E (NYSDHR complaint); LSHV Exhibit H (NYSDHR determination and order); LSHV Exhibit J (letter from NYSDHR to Plaintiff re final determination and order); and Union Exhibits G and H (NLRB charges). Courts in this District routinely take judicial notice of state administrative records, including NYSDHR records and NLRB charges; therefore, the Court will take judicial notice of LSHV Exhibits E, H, and J and Union Exhibits G and H. See Benjamin v. City of Yonkers, No. 13-cv-8699 (VB), 2014 WL 6645708, at *1, n.1 (S.D.N.Y. Nov. 24, 2014) (citing Vargas v. Reliant Realty, No. 13-cv-2341 (PGG), 2014 WL 4446165, at *1, n.2 (S.D.N.Y. Sept. 9, 2014); Evans v. N.Y. Botanical Garden, No. 02-cv-3591 (RWS), 2002 WL 31002814, at *4 (S.D.N.Y. Sept. 4, 2002)). See also Ganny v. F.J.C. Sec. Servs., Inc., No. 15-cv-1965 (JG) (JO), 2015 WL 4600745, at *1, n.3 (E.D.N.Y. July, 28, 2015) (taking judicial notice of NLRB charge and considering it on motion to dismiss) (citing Kavowras v. The New York Times Co., 328 F.3d 50, 57 (2d Cir. 2003)). As for LSHV Exhibits F, G, and I, however, it is not clear on their face that they are part of the administrative record, nor does LSHV proffer any sort of showing that these documents are publicly available.

Factual allegations contained in a plaintiff's memorandum of law are not accepted as true on a motion to dismiss. See Ganny v. F.J.C. Sec. Servs., Inc., No. 15–cv–1965, 2015 WL 4600745, at *4 (E.D.N.Y. July 28, 2015) (quoting Friedl v. City of New York, 210 F.3d 79, 84 (2d Cir.2000) ) (“[A] district court errs when it ... relies on factual allegations contained in legal briefs or memoranda in ruling on a 12(b)(6) motion to dismiss.”). This Court nevertheless takes judicial notice that SOCAR is the insurer of Cameroon Airlines because the undisputed fact is “integral” to the complaint.