Manoharan v. Columbia Univ. Coll. of Physicians & Surgeons, 842 F.2d 590, 593 (2d Cir.1988). The burden of establishing this prima facie case in employment discrimination cases is “minimal.” Hicks, 509 U.S. at 506, 113 S.Ct. 2742; see also McGuinness v. Lincoln Hall, 263 F.3d 49, 53 (2d Cir.2001). Plaintiffs complaints to Tuffey in April, May, and June 1998 each alleged that she was being discriminated against on the basis of her sex, and as such constitute Title VII protected activities. See Cruz v. Coach Stores, Inc., 202 F.3d 560, 566 (2d Cir.2000) (“[T]he law is clear that opposition to a Title VII violation need not rise to the level of a formal complaint in order to receive statutory protection....”); Summer v. United States Postal Serv., 899 F.2d 203, 209 (2d Cir.1990) (<HOLDING>). It is undisputed that defendants were aware
holding that protected activities include making complaints to management holding that written but not oral internal complaints are protected based on the inclusion of the verb filed holding without discussion of the verbalwritten distinction that plaintiffs oral complaints were protected activity holding that informal complaints to superiors about discrimination constitute protected activity holding that underlying complaints filed by several plaintiffs all contained express allegations of property damage and that because all complaints arose from the same set of circumstances the allegations in any single complaint can be inferred in the other complaints