Fourth Circuit (“Fourth Circuit”) has refused to limit the scope of the ultimate litigation, brought either by the EEOC or the plaintiff, exclusively to the charges in the original complaint in certain circumstances. In EEOC v. General Electric Company, 532 F.2d 359 (4th Cir.1976), the Fourth Circuit held that “the original charge is sufficient to support action by the EEOC as well as a civil suit under the Act for any discrimination stated in the charge itself or developed in the course of a reasonable investigation of that charge, provided such discrimination was included in the reasonable cause determination of the EEOC and was followed by compliance with the conciliation procedures fixed in the Act.” Id. at 366; see also EEOC v. Am. Nat'l Bank, 652 F.2d 1176, 1185-86 (4th Cir.1981) (<HOLDING>). The Fourth Circuit employs this doctrine to
holding that glc 152 15 provides that the only party immune from suit under the statute is the direct employer a special employer is not immune because the special employer is not liable for the payment of workers compensation and there was no agreement between the direct employer and the special employer that the special employer would be liable for the payment of such compensation holding that the definition of employer for title vii purposes does not encompass individu al supervisors even if such individuals are acting as agents of the employer holding that the expansion of the complaint against an employer to encompass its practices at its multiple locations was proper because the employer was given adequate notice of the practices under investigation and ample opportunity for conciliation holding that the employee must at least provide his employer with enough information for the employer to be put on notice that the fmla is a consideration holding that the employer was not the insurers agent