v. Kwong Wah Restaurant, 83 F.3d 498, 505 (1st Cir.1996); Gooding v. Warner-Lambert Co., 744 F.2d 354, 358 (3d Cir.1984)). Courts in this circuit have found that a “plaintiff who commences a Title VII action before receiving a right-to-sue letter may nonetheless maintain the action upon subsequent receipt of the letter.” Civil Serv. Employees Ass’n, Inc., Local 1000, AFSCME, AFL-CIO v. New York State Dept. of Parks, Recreation & Historic Pres., 689 F.Supp.2d 267, 276 (N.D.N.Y. 2010) (finding that “while this practice is discouraged,” the plaintiff subsequently obtained a right-to-sue letter which “cured the defect caused by its failure to receive notice of its right to sue prior to filing this action”); Blanke v. Rochester Telephone Corp., 36 F.Supp.2d 589, 592 n. 1 (W.D.N.Y.1999) (<HOLDING>). Plaintiff indicated the he obtained a release
holding that plaintiff complied with plain language of the notice requirement when notice was mailed within statutory period although it was not received until after holding notice of balance due satisfies notice and demand requirements holding that although it was not clear why plaintiff apparently filed the complaint in this action prior to his receipt of the righttosue notice since issuance of a righttosue notice is not a jurisdictional requirement however the eeocs subsequent issuance of the notice satisfies the statutory requirements in this case holding that upon receipt of the important notice a conclusive presumption of notice was established holding that issuance of an order to show cause satisfied this requirement