of the statute did not recognize mere statements to a supervisor as a protected activity. Id.; see also Lambert v. Genesee Hospital, 10 F.3d 46, 55 (2d Cir.1993) (“The plain language of this provision limits the cause of action to retaliation for filing formal complaints, instituting a proceeding, or testifying, but does not encompass complaints made to a supervisor.”) (citations omitted). Other courts have found oral complaints to be protected activity, but it is difficult to draw guidance from these decisions be cause many of them do not specifically state whether the complaint in question was written or purely verbal, and none discusses the statute’s use of the verb “to file” and whether it requires a writing. See EEOC v. Romeo Community Schools, 976 F.2d 985, 989-90 (6th Cir.1992) (<HOLDING>); EEOC v. White & Son Enters., 881 F.2d 1006,
holding without discussion of the verbalwritten distinction that employees voicing of concern was protected activity holding without discussion of the verbalwritten distinction that plaintiffs apparently oral complaints to supervisors were protected activity holding that informal complaints to superiors about discrimination constitute protected activity 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 defendants mistaken belief that plaintiff had made apparently oral complaints to supervisors was grounds for suit