MEMORANDUM OPINION
Pro se Plaintiff, William T. Davis, brought the above-captioned action against his former employer, Defendant Gables Residential Services, Inc. (hereinafter “Defendant” or “Gables”), regarding his July 2003 termination. Plaintiffs Complaint alleges that his termination constituted retaliation for: (1) filing and successfully pursuing a Charge of Discrimination with the Equal Employment Opportunity Commission (“EEOC”); (2) voicing numerous complaints to Defendant’s management regarding working conditions; and (3) calling the Occupational Safety and Health Administration (“OSHA”) to report exposure to hazardous materials. While Plaintiff does not delineate particular legal grounds for his Complaint, he appears to assert a claim under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., as well as a wrongful discharge claim pursuant to District of Columbia common law.
On July 24, 2007, Defendant filed a Revised Motion for Summary Judgment, asserting that Defendant is entitled to judgment as a matter of law on all of Plaintiffs claims. 1 Following several extensions of *91 time in which to oppose that motion, Plaintiff filed a letter notice with the Court indicating that he opposes Defendant’s motion for summary judgment, but does not consider himself able to file a substantive response to Defendant’s motion. The Court has now conducted a searching review of Defendant’s Revised Motion for Summary Judgment, the transcript of Plaintiffs deposition in this matter, and the relevant statutes and case law, and concludes that no genuine questions of material fact exist, such that Defendant is entitled to judgment as a matter of law. While the Court is sympathetic to pro se Plaintiffs request that the Court deny Defendant’s motion for summary judgment, Plaintiffs own deposition testimony makes clear that there is no causal connection between Plaintiffs July 2003 termination and either his previous EEOC charge or his numerous complaints. Furthermore, Plaintiff admits that Defendant had a legitimate, non-retaliatory reason for terminating him in July 2003. The Court shall therefore grant Defendant’s Revised Motion for Summary Judgment on the merits.
I. BACKGROUND
The Court begins its discussion by noting that this Court strictly adheres to the text of Local Civil Rule 56.1 (identical to Local Civil Rule 7(h)) (formerly Rule 7.1(h)). The local rules for summary judgment “assist[ ] the district court to maintain docket control and to decide motions for summary judgment efficiently and effectively.”
Jackson v. Finnegan, Henderson, Farabow, Garrett & Dunner,
As noted above, the Court struck Defendant’s initial statement of material facts for failure to strictly comply with the Local Civil Rules, and Defendant has filed a compliant Revised Statement of Material Facts Not Genuinely at Issue (hereinafter “Def.’s Stmt.”), based primarily on Plaintiffs deposition transcript. That document does not include a clear chronological account of the relevant facts. The Court therefore sets forth such relevant facts as can be discerned from Plaintiffs Complaint and the transcript of Plaintiffs deposition. Plaintiff has not substantively responded to Defendant’s motion, and thus does not actually attempt to contravene the factual assertions included in Defendant’s Statement. As such, consistent with the Local Civil Rules, the Court “assumes that facts identified by the moving party in the statement of material facts are admitted.” LCvR 56.1; 7(h). However, the Court notes that the import of this assumption is tempered in the instant case because Defendant’s Statement only relies upon Plaintiffs deposition transcript and his July 21, 2003 EEOC Charge Questionnaire.
*92 A. The Parties and Plaintiffs Employment by Defendant
Defendant, Gables Residential Services, Inc., inter alia, “owns, develops and manages multi-family communities and mixed-use developments, as well as provides furnished corporate and short-term apartment accommodations nationwide.” See Gables Residential, “Company Overview,” available at http://www.gables.com/ aboutus/company-overview.aspx (last visited November 21, 2003). In November 2002, Gables took over management of the Marbury Plaza apartment complex located at 2300 Good Hope Road SE, Washington, DC, from a predecessor firm — H.G. Smithy. Def.’s Stmt. ¶¶ 10-11. Plaintiff was hired by H.G. Smithy at some point prior to November 1999, and was employed as chief engineer at the Oxford Manor apartment complex. Id. ¶ 10; Def.’s Mot. for Summ. J., Ex. 1 (Tr. of 4/26/07 Dep. of William T. Davis) (hereinafter “Davis Dep. Tr.”) at 24:1-25:5. In November 1999, an H.G. Smithy supervisor named Mr. Jurney terminated Plaintiffs employment at Oxford Manor. Def.’s Stmt-¶ 10. Plaintiff filed an EEOC charge regarding that termination on December 8, 1999, and the charge was settled through mediation on February 9, 2000. Id. Plaintiffs employment with H.G. Smithy was reinstated with no loss of pay, seniority, or vacation time, although Plaintiffs job location was changed from the Oxford Manor complex to Marbury Plaza. Id.; Davis Dep. Tr. at 21:15-22:1. Plaintiff was employed as a maintenance technician at Marbury Plaza until Gables took over management of the Marbury Plaza property. Def.’s Stmt. ¶ 11; Compl. at 1.
When it took over management, Gables retained Plaintiff as an at-will employee. Def.’s Stmt. ¶ 2; Davis Dep. Tr. at 52:7-14. Gables also retained most of H.G. Smithy’s management; however, Mr. Jurney — the individual who terminated Plaintiff in 1999 — was not retained. Def.’s Stmt. ¶ 11; Davis Dep. Tr. at 24:13-18. During his deposition Plaintiff testified that his supervisors remained the same after Gables took over management of Marbury Plaza. Davis Dep. Tr. at 33:19-34:4; 37:4-11. However, shortly after taking over, Gables hired Maurice Williams as chief engineer, and promoted Plaintiff to the position of assistant chief engineer. Def.’s Stmt. ¶ 12. Mr. Williams became Plaintiffs supervisor. Id. At the time of Plaintiffs termination in July 2003, the Marbury Plaza property manager was Deandra Fooks. Ms. Fooks became the property manager at some point after Plaintiff was transferred from Oxford Manor to Marbury Plaza, i.e., after Plaintiff filed his 1999 EEOC charge Id. ¶¶ 2, 13. During his deposition, Plaintiff testified that he received two commendations while employed by Gables, that his last evaluation at Marbury Plaza was excellent, and that he had never been written up or reprimanded. Davis Dep. Tr. at 63:15-21; 64:6-16.
B. Events Leading to Plaintiff’s Termination
On July 7, 2003, Ms. Fooks terminated Plaintiffs employment on the grounds of insubordination in connection with an incident that occurred between Plaintiff and Mr. Williams. Id. ¶¶ 2-3; Davis Dep. Tr. at 82:19-21. Specifically, on July 3, 2003, Plaintiff disagreed with Mr. Williams’ decision to name another employee as employee of the month, and challenged Mr. Williams. Def.’s Stmt. ¶ 3; Davis Dep. Tr. at 80:7-85:1. According to Plaintiff:
[Mr. Williams] told me he didn’t have to answer anything that I said. And when I kept on, he asked me, he said, why don’t you stop crying? He said, you want some tissue? That’s what he said and I got upset at him. But I never— what they said I said, I’ll kick your *93 behind all around here, and I’ll put my foot here and MF this and MF that.... It was all fabricated just to get rid of me. It was all personal.
Id. at 81:13-82:7. Plaintiff admits that the argument got “a little loud ... He raised his voice a little and I raised my voice a little,” but maintains that he never threatened Mr. Williams. Id. at 84:3-17; 89:11— 90:9. Plaintiff testified that before terminating Plaintiff, Ms. Fooks investigated the incident by discussing it with Plaintiff, Mr. Williams, and other witnesses. Id. at 48:10-50:10; 90:10-91:17. During his deposition, Plaintiff testified that the incident with Mr. Williams was one of the key reasons for his termination. According to Plaintiff, immediately following the incident, Mr. Williams “told the entire crew that if I wasn’t out of there by the end of the day, he was going to quit. And I believe that also put pressure on the manager because [Mr. Williams was] the chief engineer.” Id. at 18:4-18; Def.’s Stmt. ¶ 5.
In addition, Plaintiff testified that he had an intimate relationship with Ms. Fooks, which ended three months prior to Plaintiffs termination when Plaintiff questioned Ms. Fooks’ authority in front of other people at a staff meeting. Def.’s Stmt. ¶ 8; Davis Dep. Tr. at 46:5-48:9. According to Plaintiff, Ms. Fooks quit her job following that staff meeting, but returned to work the next week. Def.’s Stmt. ¶ 8; Davis Dep. Tr. at 46:5-48:9. Nevertheless, Plaintiff testified that
It was very uncomfortable having me around because some of the maintenance techs and things — she had questioned how she would be able to discipline me with our relationship. When our relationship ended, I believe that it made her very, very uncomfortable which may not have been the primary reason that she fired me, but I think that that has a lot to do with her decision.
Id. at 48:2-9.
Thus, according to Plaintiffs own deposition testimony, Mr. Williams and Ms. Fooks fired him “for their own personal reason. It had nothing to do with the betterment of the company. It was because both of them were uncomfortable having me around.” Id. at 82:12-15. Specifically, Plaintiff testified that he was terminated because Ms. Fooks was uncomfortable working with him following their break up, id. at 65:12-17, and that Mr. Williams claimed that Plaintiff threatened him during the July 3, 2003 incident “because he wanted to get rid of me, and he couldn’t do it with my job performance,” id. at 84:12-21.
C. Other Alleged Causes for Plaintiffs Termination
During his deposition, Plaintiff identified five reasons for his termination, including (1) his 1999 EEOC charge, id. at 13:13-15, and (2) the July 3, 2003 incident with Mr. Williams, id. at 18:4-19:6. Plaintiff also identified another three reasons for his termination: (3) his internal complaints about exposure to hazardous materials, id. at 13:17-14:8; (4) his calls to OSHA regarding exposure to hazardous materials, id. at 14:19-15:8; and (5) his filing of “charges” with the Wage and Hour Division of the Department of Labor, id. at 14:9-18.
Plaintiffs Complaint alleges that during his employment he “voiced [his] concerns about the safety factor involving maintenance techs working on boilers without training or licensing” and “about [his] exposure to hazardous materials (i.e.asbestos) without the benefit of training or protective covering.” Compl. at 1-2. According to Plaintiff, he spent approximately 75% of his working day behind *94 walls and in ceilings that contained asbestos. Id. During his deposition, Plaintiff testified that he and other members of the maintenance crew made internal oral complaints to Mr. Williams and Ms. Fooks about their exposure to hazardous materials, including asbestos and lead, and requested protective clothing and training. Def.’s Stmt. ¶ 19; Davis Dep. Tr. at 13:16-14:7; 29:21-33:18; 45:1-46:4. In addition, Plaintiff testified that he complained about being asked to work on a boiler without proper training or licensing. Id. at 85:18-88:19.
While Plaintiffs Complaint makes a reference to calling OSHA, it does not contain any factual allegations regarding the call. Compl. at 3. During his deposition, Plaintiff testified that he called OSHA twice in one day during late 2003, and complained about his exposure to asbestos and lead. Davis Dep. Tr. at 67:2-8,16-18. Plaintiffs Complaints were not made in writing, and Plaintiff testified that the gentleman who answered the phone “looked at his file and said, well, we were out there last year or a couple months ago and everything was fine, they passed the inspection.” Id. at 14:19-15:2. Plaintiff does not allege that he informed any member of Gables management of his alleged OSHA complaint, and there is no evidence that OSHA contacted Gables or otherwise initiated any investigation in response to Plaintiffs alleged calls. Def.’s Stmt. ¶ 37.
Finally, during his deposition, Plaintiff testified that he believes he was terminated in part because he called the Wage and Hour Division of the Department of Labor to complain about payment for on-call time and Gables’ alleged practice of allowing employees to take time off as compensation for overtime work, rather than paying employees overtime. Davis Dep. Tr. at 14:9-18; 55:2-8, 57:7-58:14. While Plaintiffs Complaint does not include any references to this call, it appears to have been made on or about January 14, 2003, six months prior to Plaintiffs termination. Def.’s Stmt. ¶ 28; Davis Dep. Tr. at 61:2-14. Plaintiff testified that he was told his complaint would be investigated, and that the next day he was told that the Wage and Hour Division had called Gables and determined that the company was “within their rights.” Id. at 59:11-60:5. Plaintiff does not assert that any member of Gables’ management knew of his phone call to the Wage and Hour Division. Def.’s Stmt. ¶ 29. During his deposition, Plaintiff testified that Gables changed its practice regarding on-call time in response to one of Plaintiffs complaints; however, Plaintiff did not specify whether the complaint was internal or one made to the Wage and Hour Division. Davis Dep. Tr. at 58:
Also during his deposition, Plaintiff was specifically asked whether any member of Gables management said anything to him that led him to conclude his termination was connected to his call to the Wage and Hour Division. Id. at 62:12-15. Plaintiff responded:
There was an offhand remark. It wasn’t direct. When I made a complaint to Mr. Williams once, he asked me, listen, do you want to work here? If you’re not happy working here ... we can remedy that or something to that effect which, to me, was saying if you don’t stop, we’re going to fire you.
Id. at 16-21. When pressed on whether Mr. Williams’ remark referred to Plaintiffs Wage and Hour Division complaint as opposed to his internal complaints, Plaintiff responded: “No, I was considered by Mr. Williams and most of the managers as a trouble maker because I made complaints about things ... Everything I complained about was illegal. It was just that I wasn’t considered what they call a team player.” Id. at 62:22-63:14.
*95 D. Procedural History
On July 21, 2003, Plaintiff completed and filed an EEOC Charge Questionnaire, stating that he had been retaliated against “[f]or past charges filed in 2000, also for questioning safety, i.e., working with asbestos without any protection, unsafe electrical wiring — on-call pay.” Def.’s Mot. for Siimm. J., Ex. 2 (7/21/03 EEOC Chg. Quest.). During his deposition, Plaintiff testified that the Charge Questionnaire did not lead to an EEOC Charge of Discrimination because the EEOC “said that it was not in their realm. It was not discrimination. If anything, it was wrongful termination.” Davis Dep. Tr. at 42:1-4. Plaintiff also testified that the EEOC told him that “after two and a half years, they couldn’t handle it for retaliation because it was too long a period had lapsed.” Id. at 43:1-7. According to Plaintiff, also in 2003, the EEOC gave him “a letter and it was something like ... not a right to sue, I don’t know the exact words — but they said I could sue in court and that’s my next step.” Id. at 43:11-22. Plaintiff does not have a copy of the letter, but recalled that it said he had two years from the date of the allegedly discriminatory incident in which to file suit. Id. at 44:7-13.
Plaintiff filed his Complaint in this action on July 7, 2005. Following discovery, Defendant filed its Revised Motion for Summary Judgment on July 24, 2007. On August 2, 2007, in compliance with
Fox v. Strickland,
Plaintiff did not do so, however, and on October 22, 2007, Defendant filed a Request for Ruling on Motion for Summary Judgment and Entry of Judgment. On November 15, 2007, the Court received a letter notice from Plaintiff, dated November 7, 2007, in which he indicates that he is unable to respond to Defendant’s motion because he lacks the expertise to do so, and does not have the resources to hire an attorney. Plaintiff requests that the court “deny the Defendant’s request for a summary judgment and allow [Plaintiff] the opportunity to prove [his] case in court.” See Notice, Docket No. [42], Nov. 15, 2007. Although Plaintiffs letter clearly establishes that he opposes Defendant’s Revised Motion for Summary Judgment, Plaintiff has not filed a substantive response to that motion, and apparently does not intend to do so. The Court therefore considers Defendant’s Revised Motion for Summary Judgment ripe for review.
II. LEGAL STANDARDS
A party is entitled to summary judgment if the pleadings, depositions, and affidavits demonstrate that there is no genuine issue of material fact in dispute and that the moving party is entitled to judgment as a matter of law.
See
Fed.R.Civ.P. 56(c);
Tao v. Freeh,
Although a court should draw all inferences from the supporting records submitted by the nonmoving party, the mere existence of a factual dispute, by itself, is not sufficient to bar summary judgment.
See Anderson v. Liberty Lobby, Inc., 477
U.S. 242, 248,
Importantly, “[w]hile summary judgment must be approached with specific caution in discrimination cases, a plaintiff is not relieved of her obligation to support her allegations by affidavits or other competent evidence showing that there is a genuine issue for trial.”
Morgan v. Fed. Home Loan Mortgage Corp.,
III. DISCUSSION
Although Plaintiffs Complaint does not specifically identify legal grounds or delineate causes of action, Defendant’s motion for summary judgment analyzes Plaintiffs Complaint as asserting a retaliation claim under Title VII, as well as a wrongful discharge claim pursuant to District of Columbia common law. In the absence of any indication that Plaintiff intended to assert other claims, the Court shall address each claim identified by Defendant in turn.
A. Plaintiffs Title VII Retaliation Claim
Plaintiffs Complaint alleges only that he believes that his termination was partially motivated by retaliation for his successful pursuit of his 1999 EEOC charge. Compl. at 3. The record does not identify the basis for Plaintiffs 1999 EEOC charge. Nevertheless, because Defendant assumes that Plaintiffs claim alleges retaliation for previous activities protected under Title VII, the Court makes that assumption as well. Defendant argues that Plaintiffs Title VII claim is time-barred because Plaintiff did not file an EEOC Charge of Discrimination. In addition, while not explicitly arguing so, Defendant suggests that it is entitled to summary judgment on Plaintiffs Title VII claim because Plaintiff cannot establish a causal connection between his 1999 EEOC Charge and his termination in July 2003 and because there was a legitimate, non-retaliatory reason for Plaintiffs termination.
1. Title VII’s Administrative Filing Requirements
“Title VII requires that a person complaining of a violation file an administrative charge with the EEOC and allow the agency time to act on the charge.”
Park v. Howard Univ.,
Defendant argues that Plaintiffs Title VII retaliation claim is time-barred because he never filed an EEOC Charge of Discrimination or brought a charge with the DCOHR. Defendant is correct that Plaintiff never filed a document entitled “Charge of Discrimination” with the EEOC; indeed, Plaintiff admitted as much *98 during his deposition. See Davis Dep. Tr. at 41:19-42:4. However, the record is also clear that Plaintiff filed a document entitled “Charge Questionnaire” with the EEOC on July 21, 2004, just fourteen days after his termination. See Def.’s Mot. for Summ. J.; Ex. 2. (7/21/03 EEOC Chg. Quest.). Plaintiffs Charge Questionnaire states that “[w]hen this form constitutes the only timely written statement of allegations of employment discrimination, the [EEOC] will ... consider it to be a sufficient charge of discrimination under the relevant statute(s).” Id. Plaintiffs Charge Questionnaire also includes his name and contact information, identifies Marbury Plaza as Plaintiffs employer, and contains Plaintiffs handwritten statement that he was terminated in retaliation for his previous EEOC charge. 2
The D.C. Circuit has considered such a Charge Questionnaire to be a sufficient charge of discrimination for purposes of Title VII, albeit in a case where the employer had express notice of the plaintiffs claims of discrimination.
See Carter,
Moreover, as discussed below, even assuming arguendo that Plaintiff had timely filed this action, Defendant would nevertheless be entitled to summary judgment on the merits of Plaintiffs Title VII retaliation claim.
*99 2. Proper Standards for Retaliation Claim
Claims of retaliation under Title VII are governed by the burden-shifting analysis of
McDonnell Douglas Corp. v. Green,
If Defendant is successful, then “the
McDonnell Douglas
framework — with its presumptions and burdens — disappear[s], and the sole remaining issue [is] [retaliation]
vel non.” Reeves v. Sanderson Plumbing Prods., Inc.,
3. Application to Plaintiffs Title VII Retaliation Claim
As Plaintiff proffers no direct evidence whatsoever that he was terminated in retaliation for his 1999 EEOC charge, the
McDonnell Douglas
framework applies.
See
Davis Dep. Tr. at 38:11-18. Plaintiff makes out a prima fa-cie case of retaliation by showing that (1) he engaged in statutorily protected activity; (2) his employer took an adverse personnel action against him; and (3) a causal connection exists between the two.
Car
*100
ney,
However, Plaintiffs Complaint and deposition testimony are less successful in demonstrating a causal connection between Plaintiffs 1999 EEOC charge and his July 2003 termination. “The causal connection component of the prima facie case may be established by showing that the employer had knowledge of the employee’s protected activity, and that the adverse personnel action took place shortly after that activity.”
Carney,
Furthermore, the “cases that accept mere temporal proximity between an employer’s knowledge of a protected activity and an adverse employment action as sufficient evidence of causality to establish a prima facie case uniformly hold that the temporal proximity must be ‘very close.’ ”
Clark County Sch. Dist. v. Breeden,
Even if Plaintiff could do so, however, Plaintiff himself admits that Defendant had a non-retaliatory reason for terminating him in July 2003. Specifically, Plaintiff asserts that he was fired because both Ms. Fooks and Mr. Williams were uncomfortable working with him, and be
*101
cause Mr. Williams threatened to quit if Plaintiff was not fired following the July 3, 2003 incident. Davis Dep. Tr. at 18:4-18, 48:2-9, 65:12-17, 82:12-15, 84:12-21. Plaintiffs own testimony thus supplies Defendant with evidence of a legitimate, non-retaliatory reason for his termination: that Ms. Fooks and Mr. Williams opted to terminate an at-will employee rather than continue an uncomfortable working situation. While Defendant “need not persuade the court that it was actually motivated by the proffered reasons,” it is significant that in this instance Plaintiff himself believes Defendant was motivated — at least in part — by this non-retaliatory reason.
Burdine,
B. Plaintiffs Wrongful Discharge Claim,
‘Wrongful discharge” in the District of Columbia has three distinct usages. In one, wrongful discharge is identical to breach of contract; discharge is wrongful if it violates contractual provisions.
See Nickens v. Labor Agency of Metro. Wash.,
As such, Plaintiffs wrongful discharge claim can only allege that his termination was wrongful because it was in violation of public policy. In general, under District of Columbia law, “an employer may discharge an at-will employee at any time and for any reason, or for no reason at all.”
Adams,
Although
Carl
held that the
Adams
exception might be extended to cover other public policy exceptions to the general rule of at-will employment,
see
In his Complaint and deposition testimony, Plaintiff alleges that he was terminated because,
inter alia,
he voiced internal complaints about exposure to hazardous materials and improper training regarding operating the boiler, he called the Wage and Hour Division regarding on-call pay and overtime pay, and he called OSHA regarding his exposure to hazardous materials. Plaintiffs wrongful discharge claim is deficient, however, because it does not identify any public policy purportedly violated by his termination. While Defendant goes to great lengths to demonstrate that Plaintiff cannot pursue an action for wrongful discharge based on various statutes,
see
Def.’s Mot. for Summ. J. at 26-29, such effort is ultimately unnecessary because in the absence of any identified public policy, the Court clearly cannot concluded that the public policy relied upon is “firmly anchored” in the Constitution or a statute or regulation.
Bowie,
Moreover, even assuming
arguendo
that Plaintiff could identify a clear public policy violated by his termination, and could show a “close fit” between the policy and his conduct,
Bowie,
As for Plaintiffs calls to OSHA and the Wage and Hour Division, Plaintiff does not allege that any member of Gables management was aware of either call, and there is no record evidence to that effect. Def.’s Stmt. ¶¶29, 37. In the absence of any evidence linking Plaintiffs calls to OSHA and the Wage and Hour Division to his termination, Plaintiff cannot establish that either call was a reason for his termination, let alone the sole or substantial reason. Ultimately, as discussed above, Plaintiff himself asserts that he was terminated, at least in part, because both Ms. Fooks and Mr. Williams were uncomfortable working with him, and because Mr. Williams threatened to quit if Plaintiff was not fired following the incident on July 3, 2003. Davis Dep. Tr. at 18:4-18, 48:2-9, 65:12-17, 82:12-15, 84:12-21. During his deposition, Plaintiff questioned whether the doctrine of at-will employment permitted Ms. Fooks to terminate Plaintiff because she and Mr. Williams were “uncomfortable having me around.” Davis Dep. Tr. at 82:6-18. The District of Columbia Court of Appeals has directly answered Plaintiffs question, stating that “the narrow exceptions to the ‘employment-at-will’ doctrine which [were] recognized in
Adams
and
Carl
were not designed to prevent an employer from terminating an at-will employee in order to eliminate unacceptable internal conflict and turmoil.”
Wallace,
IV. CONCLUSION
For the foregoing reasons, the Court shall grant Defendant’s [36] Revised Motion for Summary Judgment, and shall dismiss this case in its entirety. An appropriate Order accompanies this Memorandum Opinion.
Notes
. Defendant initially filed a Motion for Summary Judgment on July 13, 2007. By Order dated July 23, 2007, the Court denied that motion without prejudice because the corresponding Statement of Material Facts was drafted in narrative form, rather than in precise, individually numbered paragraphs to which pro se Plaintiff could easily respond. *91 sue Order, Docket No. [35], July 23, 2007. The Court ordered Defendant to file a revised Statement of Material Facts, along with a revised motion for summary judgment, if necessary. Defendant filed its Revised Motion for Summary Judgment on July 24, 2007.
. The EEOC's interpreting regulations specify the information that must be included in a "charge” of discrimination under Title VII, including that the charge must be in writing and be signed. See 29 C.F.R. § 1601.9. In addition, the EEOC’s regulations provide that a charge should include the full name, address and telephone number of the person making the charge, and the full name and address of the person against whom the charge is made, as well as a "clear and concise statement of the facts, including pertinent dates, constituting the alleged unlawful employment practices.” See id. § 1601.12. In addition, however, the regulations provide that a "charge is sufficient when the Commission receives from the person making the charge a written statement sufficiently precise to identify the parties, and to describe generally the action or practices complained of.” Id.
. Retaliation claims brought under the DCHRA are evaluated pursuant to the
McDonnell Douglas
framework and guided by Tide VII retaliation case law.
See Howard Univ. v. Green,