AL'JIHAD : MESSENGERS (Angels & Devil) IN THE SKY (Captured Picture) AL'JIHAD Seventh Edition - Coker College copy - Page 410

(Discharge) charges In The Court Of Common Pease Of Cuyahoga County, Ohio on December 15, 2006 within Plaintiff right to re-file Wrongful Termination Charges. 50. Plaintiff – Imam Mahdi Five Claims/Accounts are not time barred of Defendant L’Oreal USA, Inc. (The Court also made clear that Title VII’s Limitations period does not bar the recovery of damages for actions for that portion of the hostile environment claim that falls outside the period for filing a timely charge – Ohio Employment Practices Law § 21:13). 51. Answer of Defendant L’Oreal USA Inc./L’Oreal USA Products Inc. denies each and every allegation not hereto fore expressly admitted in this Plaintiff Complaints. Plaintiff (Imam Mahdi) Rebuttals are justified against Defendant (L’Oreal USA Inc.) denials of Plaintiff Complaints. Defendant has no controvert or no defense against Plaintiff Imam Mahdi, in which the U.S. Constitution, Bill of Rights, Binder – I (Exhibit – 1 to Exhibit – A), and Binder – II (Exhibit – B to Exhibit – S) shall be justified documentations in court in favor of the Plaintiff. Defendant First Defense Not Justified 52. Defendant: The Complaint fails to state a claim upon which relief can be granted. 53. Plaintiff: sought mitigation at lease twice through EEOC against L’Oreal USA Inc., but L’Oreal USA Inc. acted out of bad faith and rejected mitigations. Defendant Second Defense Not Justified 54. Defendant: L'Oreal at all times acted in good faith and without intent to discriminate against Plaintiff. “AL’JIHAD”– by, Imam Mahdi . © ® ™ : Of 842 Pages Is 410