"A claim is considered reasonably related to conduct complained of in the EEOC [or DHR] charge if, for instance, it 'would fall within the reasonably expected scope of an EEOC [or DHR] investigation of the charges of discrimination.'" Amin v. Akzo Nobel Chems., Inc., 282 F. App'x 958, 961 (2d Cir. 2008) (quoting Alfano v. Costello, 294 F.3d 365, 381 (2d Cir. 2002)). Distilled to its essence, "the reasonably related standard means that loose pleading is permitted before the EEOC" or DHR.

Claims are considered "reasonably related" to claims that were alleged before the EEOC if they "would fall within the reasonably expected scope of an EEOC investigation of the charges of discrimination." Amin v. Akzo Nobel Chems., Inc., 282 Fed. Appx. 958, 961 (2d Cir. 2008) (citing Alfano v. Costello, 294 F.3d 365, 381 (2d Cir.2002)). Many of the allegations in Plaintiff's Amended Complaint were not raised before the EEOC and are not reasonably related to claims that were.

Internal or informal complaints of discrimination on a basis prohibited by Title VII are protected activity. See Amin v. Akzo Nobel Chems., Inc., 282 F. App'x 958, 961 (2d Cir. 2008) (Summary Order); Raniola v. Bratton, 243 F.3d 610, 624-25 (2d Cir. 2001). To the extent Sharpe is relying on her 1999 and 2003 DHR complaints, these activities undisputably constitute protected activity.

" Hubbard v. Total Comm., Inc., 347 Fed.Appx. 679, 680-81 (2d Cir. 2009); see also Martinez v. New York City Dept. of Educ., 2008 WL 2220638, at *11 (S.D.N.Y. May 27, 2008); 42 U.S.C. § 2000e-3(a). It is clearly established that "informal complaints to supervisors constitute protected activity under Title VII." Sclafani v. PC Richard Son, 668 F. Supp. 2d 423, 437 (E.D.N.Y. 2009); see generally Amin v. Akzo Nobel Chemicals, Inc., 282 Fed.Appx. 958, 961 (2d Cir. 2008); Cruz v. Coach Stores, Inc., 202 F.3d 560, 566 (2d Cir. 2000); Sumner v. U.S. Postal Serv., 899 F.2d 203, 209 (2d Cir. 1990). To satisfy the "protected activity" element of the prima facie case, a plaintiff need not establish that the underlying conduct was in fact a violation of Title VII, but rather need only show that she had a "good faith, reasonable belief" that the conduct was unlawful.

Plaintiff's retaliation claim under Title VII is subject to the same burden shifting analysis established in McDonnell Douglas. Amin v. Akzo Nobel Chemicals, Inc., 282 Fed.Appx. 958, 961 (2d Cir. 2008); Slattery v. Swiss Reinsurance Am. Corp., 248 F.3d 87, 94 (2d Cir. 2001). a. A Prima Facie Case of Retaliation

The Court finds that Ciotti's EEOD complaint constituted a protected activity because even “informal complaints to management as to discrimination on a basis prohibited by Title VII are protected activity,” Amen v. Akzo Novel Chemicals, Inc., 282 Fed.Appx. 958, 961 (2d Cir. 2008) (summary order), and the City does not allege that Ciotti lacked a “reasonable belief' that the complained-of conduct violated the law, Kelly, 716 F.3d at 14.

Defendants do not dispute that in seeking accommodations, taking FMLA leave, and submitting various discrimination complaints to EDC, Tieu engaged in protected activity. See Pl. Opp. at 20, 29 (listing protected activities); Weixel v. Bd. of Educ. of City of New York, 287 F.3d 138, 149 (2d Cir. 2002) (seeking an accommodation is a protected activity under the ADA); Amin v. Akzo Nobel Chemicals, Inc., 282 F. App'x 958, 961 (2d Cir. 2008) ("Informal complaints to management as to discrimination on a basis prohibited by Title VII are protected activity."). Nor do they contest that Defendants knew of her protected activity.

Internal complaints constitute a protected activity. See, Amin v. Akzo Nobel Chems., Inc., 282 Fed.Appx. 958, 961 (2d Cir. 2008). However, as discussed above, Plaintiff's contention that Thomas retaliated against them by failing to conduct a proper investigation does not amount to an adverse action for a claim of retaliation.

” Lebowitz v. N.Y.C. Dep't of Educ., 407 F.Supp.3d 158, 174 (E.D.N.Y. 2017) (quoting Williams v. N.Y.C. Hous. Auth., 458 F.3d 67, 70 (2d Cir. 2006)); see also Amin v. Akzo Nobel Chems., Inc., 282 Fed.Appx. 958, 960-61 (2d Cir. 2008); Tanvir v. N.Y.C. Health & Hosps. Corp., 480 F. App'x. 620, 621 (2d Cir. 2012) . “A claim is considered reasonably related if the conduct complained of would fall within the scope of the EEOC investigation which can reasonably be expected to grow out of the charge that was made.” Fitzgerald v. Henderson, 251 F.3d 345, 359-60 (2d Cir. 2001) (internal quotation marks and citation omitted). “In this inquiry, ‘the focus should be on the factual allegations made in the [EEOC] charge itself, describing the discriminatory conduct about which a plaintiff is grieving.'” Williams, 458 F.3d at 70 (alteration in original) (quoting Deravin v. Kerik, 335 F.3d 195, 201 (2d Cir. 2003)). “Generally, courts dismiss claims that are so qualitatively different from the allegations contained in an EEOC charge that an investigation would not likely encompass the new allegations.” Senno v. E

Eubanks , 2021 WL 1110587, at *14 (quoting Rivera , 743 F.3d at 24 ); see also Amin v. Akzo Nobel Chems., Inc. , 282 F. App'x 958, 961 (2d Cir. 2008) (summary order). "However, while such complaints may be informal, they cannot be so vague or ‘generalized’ that the employer could not ‘reasonably have understood [ ] that the plaintiff's complaint was directed at conduct prohibited by Title VII.’ " Bowen-Hooks v. City of New York , 13 F. Supp. 3d 179, 222 (E.D.N.Y. 2014) (quoting Rojas v. Roman Catholic Diocese of Rochester , 660 F.3d 98, 108 (2d Cir. 2011) ).