such a state agency). Title VII's charge filing provision accommodates this deferral requirement by extending the time period required to file a charge with the EEOC from 180 to 300 days where the aggrieved person initially instituted proceedings with such a state agency. See 42 U.S.C. § 2000e-5(e)(l). 8 . Compare Casavantes v. Cal. State Univ., Sacramento, 732 F.2d 1441, 1443 (9th Cir.1984) (concluding that under Title VII an intake questionnaire constituted a charge because it met the EEOC regulations governing the substantive content of a charge); with Dorn v. Gen. Motors, 131 Fed.Appx. 462, 470 n. 7 (6th Cir.2005) (unpub.) (ruling that the ADEA requires "a formal charge, not an inquiry or complaint”). 9 . Compare Holowecki v. Fed. Express Corp., 440 F.3d 558, 568-69 (2d Cir.2006) (<HOLDING>); with Bost v. Fed. Express Corp., 372 F.3d
holding an intake questionnaire to constitute a charge under the adea upon application of the manifestation of intent test although the eeoc did not consider the questionnaire to be a charge and the aggrieved person subsequently filed a formal charge holding that where the writings on file were insufficient to constitute an effective charge a charge had not been effectively filed despite the fact that the eeoc had assigned the case a charge number holding that plaintiffs filing with the eeoc constituted a formal charge because the plaintiff attached a statement to the filed intake questionnaire that included a request for the agency to act holding that based on plain language in box 2 plaintiffs intake questionnaire could not be construed as timely eeoc charge holding in accordance with other circuits that an intake questionnaire may serve as a charge of discrimination if the circumstances of the case demonstrate that the charging party manifested the intent to activate the administrative process