Crediting plaintiff's allegations, as amplified by his opposing affidavit, for the purposes of this motion to dismiss, we find that the complaint states causes of action for discrimination and retaliation and is time-barred only in part. Plaintiff, a black man born in Haiti, emigrated to the United States in 1994 and received a bachelor's degree in forensic science in 2003. During the relevant time period, he held the title of Criminalist I-B at the Office of the Chief Medical...
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