that Ridgely created a hostile work environment starting in 2003 and that the hostility manifested itself through isolation, subjection to public ridicule and harmful treatment that was so severe it caused psychological illness. Compl. ¶¶ 10, 12-13. In addition, following her first formal EEO complaint in March 2005, the plaintiff alleges that Ridgel/s treatment toward her became “more hostile and hurtful.” Id. ¶ 12. The plaintiff has alleged some conduct in support of her claim, specifically Ridgely’s actions toward her and overall negative treatment in the workplace, and thus, the facts in the plaintiffs complaint support.her hostile work environment claim. Powell v. Castaneda, 390 F.Supp.2d 1, 11 (D.D.C.2005); see also Kriesch v. Johanns, 468 F.Supp.2d 183, 187-88 (D.D.C.2007) (<HOLDING>). Therefore, the court denies the defendant’s
holding that the plaintiffs complaint was valid because despite general allegations it provided notice holding reasonable suspicion is based on totality of circumstances holding that under the totality of the circumstances the facts provided sufficient support to defeat a motion to dismiss despite being broad allegations holding that the government bears the burden of proving voluntary consent under the totality of the circumstances recognizing inferential factual allegations to defeat a motion to dismiss