work environment,” although she did not include a separate hostile work environment count. Compl. ¶¶ 1, 9. Even when a “claim is not set forth ... in a separate count,” courts have addressed the validity of that claim as if the plaintiff listed the count. Ficken v. Golden, 2005 WL 692019, at *6 (D.D.C. Mar.24, 2005) (adjudging the validity of a defamation claim even though the plaintiff did not list it as a separate count). Furthermore, the plaintiff provides factual support for this claim throughout her complaint, pointing to Ridgely’s hostile and hurtful treatment of her from .2004 until her departure. Compl. ¶¶ 10-13. Such factual statements are sufficient to allege a claim so long as they provide notice of that claim. Freeman v. Fallin, 254 F.Supp.2d 52, 59 n. 4 (D.D.C.2003) (<HOLDING>). Because the plaintiff expressly identified a
holding despite collective allegations in complaint the complaint was not deficient under rule 8a because it stated with sufficient particularity facts establishing a causal connection between the defendants actions and the constitutional deprivation holding that the plaintiffs complaint was valid because despite general allegations it provided notice holding that a plaintiff may present unsubstantiated factual allegations on appeal provided they are consistent with the complaint to show that the complaint should not have been dismissed holding that the complaint did not satisfy the notice pleading requirements of federal rule of civil procedure 8a because the complaint gave the defendants no notice of the specific factual allegations presented for the first time in the plaintiffs opposition to summary judgment holding that the district court did not err in finding that the plaintiff failed to provide adequate notice of new allegations where the plaintiffs complaint gave the defendants no notice of the specific factual allegations presented for the first time in the plaintiffs opposition to summary judgment