should be considered in the equitable balancing process [and that] an aggrieved person seeking preliminary relief outside the statutory scheme for alleged Title VII violations would have to make a showing of irreparable injury sufficient in kind and degree to justify the disruption of the prescribed administrative process....”). In interpreting Sampson, however, numerous other courts have assumed that the “genuinely extraordinary” test for irreparable harm applies in all employee discharge cases, whatever the asserted basis for relief. See, e.g., Stewart v. United States Immigration & Naturalization Serv., 762 F.2d 193, 199-200 (2d Cir.1985); E.E.O.C. v. Anchor Hocking Corp., 666 F.2d 1037, 1040-44 (6th Cir.1981). But see E.E.O.C. v. Cosmair, Inc., 821 F.2d 1085, 1090 (5th Cir.1987) (<HOLDING>). Such a conclusion is predicated, in our
holding that administrative remedies must be exhausted prior to filing a claim in court holding that the prisoner has the burden of demonstrating he has exhausted his administrative remedies in his complaint holding that a party may gain judicial review without exhausting its administrative remedies where pursuit of administrative remedies would be futile where strict compliance would cause irreparable harm and where the applicable statute is alleged to be void on its face holding that if adequate administrative remedies are available it is improper to seek relief in court before those remedies are exhausted holding that irreparable harm is presumed where discharged employee has exhausted her administrative remedies and proceeds under a civil rights statute