Full opinion text
OPINION AND ORDER VAN ANTWERPEN, District Judge. I. INTRODUCTION Plaintiff Nicholas Gharzouzi (“Ghar-zouzi”) has brought this action pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e (“Title VII”) and the Pennsylvania Human Relations Act, 43 P.S. § 951 et seq. (“PHRA”), alleging that Defendants Northwestern Human Services of Pennsylvania (“NHS”), Richard Thomas (“Thomas”), John Ciavardone (“Ciavar-done”) , Jon C. Fogle (“Fogle”), Sally Sheaffer (“Sheaffer”), Alan Tezak (“Te-zak”) and Joanne Edwards (“Edwards”) discriminated against him on the basis of his Lebanese national origin. Defendants have moved for summary judgment as to all counts of Plaintiffs Amended Complaint, including Plaintiffs disparate treatment, hostile work environment and retaliation claims brought under Title VII and the PHRA and Plaintiffs claim for emotional distress damages. This Opinion considers Defendants’ Motion for Summary Judgment, filed on March 19, 2002; Plaintiffs Brief in Opposition to Defendants’ Motion for Summary Judgment, filed on April 12, 2002; and Defendants’ Reply Brief in Support of Motion for Summary Judgment, filed on April 17, 2002. We have jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331, 1334 and 1367. II. STANDARD OF REVIEW The court shall render summary judgment “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Fed.R.Civ.P. 56(c). An issue is “genuine” only if there is a sufficient evi-dentiary basis on which a reasonable jury could find for the non-moving party. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). A factual dispute is “material” only if it might affect the outcome of the suit under governing law. Id. at 248, 477 U.S. 242, 106 S.Ct. 2505, 91 L.Ed.2d 202. All inferences must be drawn, and all doubts resolved, in favor of the non-moving United States v. Diebold, Inc., 369 U.S. 654, 655, 82 S.Ct. 993, 8 L.Ed.2d 176 (1962); Gans v. Mundy, 762 F.2d 338, 341 (3d Cir.1985), cert. denied, 474 U.S. 1010, 106 S.Ct. 537, 88 L.Ed.2d 467 (1985). On motion for summary judgment, the moving party bears the initial burden of identifying those portions of the record that it believes demonstrate the absence of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). To defeat summary judgment, the non-moving party must respond with facts of record that contradict the facts identified by the movant and may not rest on mere denials. Id. at 321 n. 3, 477 U.S. 317, 106 S.Ct. 2548, 91 L.Ed.2d 265 (quoting Fed.R.Civ.P. 56(e)); see First Nat’l Bank of Pennsylvania v. Lincoln Nat’l Life Ins. Co., 824 F.2d 277, 282 (3d Cir.1987). The non-moving party must demonstrate the existence . of evidence that would support a jury finding in its favor. See Anderson, 477 U.S. at 248-49, 106 S.Ct. at 2505. In discrimination and retaliation cases, proof at summary judgment follows a well-established “burden-shifting” approach first set forth in McDonnell Douglas Corporation v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). Under this burden-shifting approach, once a plaintiff has established a prima facie case of discrimination or retaliation, the defendant must rebut an inference of wrongdoing with evidence of a legitimate, non-discriminatory or non-retaliatory reason for the action taken. Delli Santi v. CNA Ins. Co., 88 F.3d 192, 199 (3d Cir.1996); Weston v. Commonwealth of Pennsylvania, 251 F.3d 420, 432 (3d Cir.2001). If a defendant successfully meets its burden in a discrimination or retaliation case, then in order to avoid summary judgment, the plaintiff must present evidence of pretext or coverup, or show that discrimination played a role in the employer’s decision-making and had a determinative effect on the outcome. Fuentes v. Perskie, 32 F.3d 759, 764 (3d Cir.1994); Weston, 251 F.3d at 432. The ultimate burden to prove discrimination on the basis of the claimed protected elass-the burden of production-remains with the plaintiff at all times. See Barber v. CSX Distrib. Servs., 68 F.3d 694, 698 (3d Cir.1995). Notwithstanding the moving party’s burden, the Third Circuit urges special caution in granting summary judgment to an employer when its intent is at issue, particularly in discrimination and retaliation cases. Goosby v. Johnson & Johnson Med., Inc., 228 F.3d 313, 321 (3d Cir.2000). III. FACTUAL BACKGROUND On September 27, 1996, the Commonwealth of Pennsylvania Department of Public Welfare contracted with a corporation now known, as Northwestern Human Services of Pennsylvania (“NHS”) (then called Northwestern Human Services, Inc.) to manage, administer and operate the Allentown Secure Treatment Unit (“ASTU”), a treatment center for delinquent juveniles. Defendant Thomas was selected to be the director of the ASTU; his responsibilities included hiring the personnel necessary to fulfill NHS’s obligations under the contract. His direct supervisor was Defendant Tezak, the Juvenile Justice Director for NHS. In the fall of 1996, Thomas hired Gharzouzi as a Unit Life Coordinator on behalf of NHS; Ghar-zouzi was responsible for, among other things, safety and security concerns within the ASTU. In January of 1999, Gharzouzi was promoted to the position of Assistant Director; he remained in this position until his termination in September of 1999. Gharzouzi complains that beginning in 1997 Thomas discriminated against him and harassed him because of his Lebanese national origin. Plaintiff complains that Thomas mocked Plaintiffs manner of communication, including his accent and his hand gestures, and also told Plaintiff that he had to change his way of thinking. Plaintiff recalls at least ten incidents of alleged discrimination. Plaintiff first alleges that on July 17, 1997, he and Thomas discussed several issues and, during this conversation when Gharzouzi asked Thomas to explain something, Thomas told him that Gharzouzi did not understand due to the language barrier. The next allegedly discriminatory incident alleged occurred in October of 1997. In his notes for a meeting held on October 30, 1997, Gharzouzi indicated that the office of two employees “will” become another employee’s office and another room “will” be converted into the clinical office for the first two employees. Thomas commented to Gharzouzi that the word “will” was not appropriate and the use of the word showed “poor management skills.” Ghar-zouzi changed the wording of the memorandum, but at that time indicated to Thomas that he was simply informing the supervisors of the change and did not mean the word to be derogatory. Ghar-zouzi alleges next that in February -of 1998, Thomas confronted Gharzouzi during a meeting in front of co-workers; after the meeting, Thomas asked Gharzouzi why he did not agree with Thomas and stated that Gharzouzi was not a team player. Gharzouzi alleges that several times throughout that day, Thomas mocked the way that Gharzouzi talks and the gestures that Gharzouzi makes with his body. Gharzouzi then claims that on June 3, 1999, he and Thomas disagreed over whether particular students should be required to do community service work and that in the course of the disagreement, Thomas used an expletive, stating that he was the Director. Gharzouzi also asserts that on June 11, 1999 after a group meeting where Thomas was present and where Gharzouzi got into a disagreement with a staff nurse, Thomas reprimanded him for the way that he talked to the nurse; according to Plaintiff, Thomas told him that he was reprimanding him because Thomas thought that the way that he said things to the nurse and used his hands hurt her feelings. Plaintiff next alleges that on June 17, 1999, Thomas admonished Ghar-zouzi for planning the day and time of a party for one of their co-workers without seeking Thomas’s approval; according to Gharzouzi, Thomas stated that Gharzouzi needed to start learning “our way” of doing things and added that “the buck will stop here.” Plaintiff claims that on June 26, 1999 and July 15, 1999, Thomas directed Gharzouzi three times to rewrite a memorandum that Gharzouzi had prepared and stated that he did not know how to write a memorandum because of his “English language barrier.” Ghar-zouzi states that he has a Master’s Degree and is enrolled in post-graduate courses and has never before received any criticism regarding his use of the English language; he felt that he was being discriminated against and that these criticisms were making it impossible for him to do his job. According to Plaintiff, on June 28, 1999, he and Thomas got into a disagreement and Thomas told Gharzouzi that he was the director, that he did not want to hear any of Gharzouzi’s ideas and that if Gharzouzi wanted to keep his job, he would have to change his way of thinking; when Gharzouzi asked Thomas how he could change, Thomas did not offer any suggestions. Plaintiff states that on August 30, 1999, Thomas confronted Ghar-zouzi regarding various issues, including the way that Gharzouzi expresses.himself. Thomas complained of Gharzouzi’s use of language, his accent, his hand gestures and the way that he looked at people. Thomas mentioned that staff members were intimidated because Gharzouzi had hurt their feelings. Gharzouzi asked for specific instances where he had hurt staff members’ feelings. Thomas allegedly replied that if he did not want to work there, he could leave and that if he did not change these behaviors, he would fire him. Gharzouzi believed that Thomas was trying to make his job miserable so that he would quit. Towards the end of August or beginning of September, a decision was made to place two ASTU residents in a room together; one of the residents assigned to the room had a history of committing sex offenses and was older and physically larger than the other resident assigned to the room. According to Plaintiff, the entire team on duty that day discussed and made the decision to assign the two residents to the room. Defendants, on the other hand, contend that several staff members objected to the idea, but that Gharzouzi refused to accept their recommendations and, as the person in charge that morning, implemented the room change. On or about September 9, 1999, Ghar-zouzi called the corporate complaint hotline, which was part of the corporate compliance program. He spoke with Defendant Ciavardone, a Senior Vice-President of NHS. According to Plaintiffs deposition, his complaint concerned “what Rick Thomas was telling me and threatening me.” (N. Gharzouzi Dep. at 104.) According to Plaintiff, he stated that “Mr. Thomas said to me, if you go above me Pm going to fire you. They’re going to believe me, not you.” (Id.) Ciavardone told Gharzouzi to call Defendant' Fogle, the Corporate Director of Human Resources for NHS; Plaintiff left a message for Fogle. On the morning of September 10, 1999, Plaintiff called Thomas at home to tell him that he would not be able to make it to work that day because his knee was causing him discomfort and he did not believe that he could drive to work safely. At that time, Plaintiff had an ongoing knee condition for which he eventually had an ar-throscopy. According to Plaintiff, Thomas ordered Gharzouzi to come to work and also directed him to get a doctor’s excuse. Plaintiff did see his doctor that day and obtained an excuse from the doctor’s office. Thomas claims that he had previously requested that Gharzouzi be at work at 7 a.m. that morning in order to help transport some of the residents to the dentist’s office; according to Thomas, Gharzouzi knew that he was to tell Thomas sooner than that morning if he could not be at work that morning so that Thomas could arrange for other staff members to be present. Also on September 10, 1999, Thomas called Defendant Sheaffer, an Employee Relations Specialist employed by NHS. According to Sheaffer, Thomas reported (1) that staff members had alleged that Gharzouzi was engaging in union activity and (2) that Gharzouzi had inappropriately directed the placement of two residents to a room. Sheaffer then called Fogle to decide how to proceed with Thomas’s charges. She and Fogle decided that Fo-gle would inform Gharzouzi that he was being placed on administrative leave with pay while the allegations were investigated. According to Sheaffer, the seriousness of the two charges warranted placing Gharzouzi on administrative leave. First, any involvement by Gharzouzi with union organization would undermine the management’s position to remain union-free. Second, the room assignment appeared to have compromised the residents’ safety. According to Sheaffer, she and Fogle decided that she would conduct her investigation by interviewing staff members. They planned that the investigation would focus on the union allegations. Fogle left a phone message for Ghar-zouzi on his home answering machine. When Gharzouzi returned Fogle’s phone call, Fogle informed him that he should stay at home until further notice. Ghar-zouzi remained on administrative leave until his termination. While Gharzouzi was on administrative leave, Sheaffer interviewed various staff members. In the course of her investigation, Sheaffer also met with Gharzouzi twice, once with Ghar-zouzi alone and another time with Ghar-zouzi, Defendant Edwards, the Director of Human Resources for NHS, and Tezak. Based upon the interviews with NHS staff members and with Gharzouzi, Sheaffer, Edwards, Tezak and Michael Breslin (“Breslin”), a Senior Vice President for NHS, decided to offer Gharzouzi the option of resigning. On September 22, 1999, they presented him with this choice and allowed him until September 24, 1999 to make his decision; when he refused to resign, NHS terminated his employment. A letter dated September 27, 1999 and signed by Edwards confirms that effective September 24, 1999, he was terminated from his position as Assistant Director. On January 5, 2000, Gharzouzi’s attorney submitted a charge of discrimination, which Gharzouzi had signed and dated December 15, 1999, to the Equal Employment Opportunity Commission (“EEOC”). This charge of discrimination indicated Plaintiffs belief that he had been discriminated against and subjected to a hostile work environment because of his Lebanese origin and retaliated against; it mentioned only Defendants NHS and Thomas by name. On this form, Plaintiff indicated that he would also like to file the charge with the Pennsylvania Human Relations Commission (“PHRC”); the cover letter dated January 5, 2000 that accompanied the charge also indicated that Plaintiff was making a request for cross-filing with the PHRC. The cover letter and charge were each stamped as received by the EEOC on January 5, 2000. On February 11, 2000, the EEOC advised Plaintiffs counsel by letter that the charge, had been received. The later stated that “before we can actually docket your client’s charge and begin the EEOC investigation, we must first complete other intake processing for which we will require assistance from you and your client.” The letter further stated that “you will be informed as to the decision in this matter, and, if appropriate, what additional steps must be taken in order for EEOC to complete this process.” The letter assigned EEOC Investigator Genevieve Delaney (“Delaney”) to the matter. On April 14, 2000, Delaney sent a perfected draft charge to Gharzouzi; the letter indicated that he must send a signed copy of the revised charge within thirty-three days or his charge would be dismissed without an investigation or a mediation by the EEOC. This perfected draft charge included not only Defendant Thomas but also Defendants Ciavardone, Fogle, Sheaffer, Tezak and Edwards by name. The EEOC files contain two copies of this perfected charge, one signed by Gharzouzi on April 18, 2000 and date-stamped by the EEOC on April 21, 2000, and another signed by Gharzouzi on April 26, 2000 'with a May 5, 2000 cover letter from Plaintiffs counsel, both of which were date-stamped May 5, 2000. The EEOC forwarded the charge to the PHRC on May 9, 2000. The EEOC issued a Notice of Right to Sue on October 16, 2000 and Plaintiff filed his complaint in federal court within 90 days of that notice. IV. DISCUSSION A. Timeliness Issues As a preliminary matter, we address the timeliness issues raised by Defendants in their Motion for Summary Judgment. 1. Time Limits on Plaintiff’s Title VII Claims a.Filing Requirements Under Title VII In order to bring suit under Title VII, a plaintiff must have exhausted his/her administrative remedies by filing a timely charge of discrimination with the EEOC. For a charge to be timely, a plaintiff must normally file his/her charge of discrimination with the EEOC within 180 days after the alleged unlawful employment practice occurred. However, in a “deferral state” like Pennsylvania, that is, a state which has a state or local law prohibiting the practice alleged and establishing or authorizing the state or local authority to grant or seek relief from practices prohibited under Title VII, the plaintiff has not 180 but BOO days from the date of the alleged unlawful employment practice to file his/ her charge of discrimination with the EEOC. See Seredinski v. Clifton Precision Prods. Co., 776 F.2d 56 (3d Cir.1985). The extension of the filing time to 300 days holds regardless of whether the plaintiff ever files a charge with the state agency. See Colgan v. Fisher Scientific Co., 935 F.2d 1407, 1414-15 (3d Cir.1991). Ghar-zouzi thus had 300 days from the date of the alleged unlawful practice to file his EEOC claim. b. Defendants’ Position Defendants argue that Gharzouzi’s EEOC filing was not effected until May 1, 2000 when the EEOC formally docketed his charge and, thus, that Gharzouzi’s charge is timely only as to events occurring 300 days before May 1, 2000—that is, after July 14, 1999. Defendants accordingly argue that Plaintiffs allegations of harassment in 1997,1998 and through July 14, 1999 are time-barred and that he should only be able to seek relief for the harassment that he alleges occurred on August 30, 1999 and September 9, 1999. (Defs.’ Mot. for Sum. Judg. at 17-18.) c. Analysis of Timeliness of Plaintiff’s Title VII Claims We reject Defendants’ argument that the charge need have been formally docketed and assigned a charge number for the filing to have been effective. We find that Plaintiffs January 5, 2000 letter and charge of discrimination constitute an effective filing with the EEOC. i. Filing Requirements Under Title VII The Third Circuit recognizes “the prevailing jurisprudence that a charge [of discrimination filed with the EEOC] need not comply with a plethora of particular requirements.” Bihler v. The Singer Co., 710 F.2d 96, 99-100 (3d Cir.1983). The Code of Federal Regulations provides that “a charge is sufficient when the Commission receives from the person making the charge a written statement sufficiently precise to identify the parties, and to describe generally the practices complained of.” Edelman v. Lynchburg College, 535 U.S. 106, 122 S.Ct. 1145, 1148, 152 L.Ed.2d 188 (2002) (quoting and citing 29 CFR § 1601.12(b) (1997)). A communication to the EEOC in, or reduced to, wilting may constitute a charge if it provides notice to the EEOC “of a kind that would convince a reasonable person that the grievant has manifested an intent to activate the Act’s machinery.” Bihler, 710 F.2d at 99. The charge “must sufficiently inform the EEOC whether it is to investigate immediately or to await further communication from the [potential] plaintiff before investigation.” Bihler, 710 F.2d at 100. In determining whether a particular communication evinces the requisite intent, courts consider the content and effect of the communication, including what the EEOC does upon receiving the communication. See Gulezian v. Drexel Univ., No. CIV.A. 98-3004, 1999 WL 153720, at *3 (E.D.Pa. March 19, 1999). In distilled form, the case law requires that an EEOC charge contain two components: (1) a written statement precise enough to identify the parties and to describe generally the practices complained of and (2) the manifestation of an intent to activate the EEOC’s mechanisms. ii. Application of Law to Plaintiff’s Proposed Charge We find that the charge submitted by Plaintiff’s counsel on January 5, 2000 sufficiently describes the practices complained of and effectively evinces Plaintiffs intent to activate the EEOC’s investigatory mechanisms. Plaintiff completed a “Charge of Discrimination” form and added a typewritten attachment describing the allegedly discriminatory conduct. The attachment alleges that Plaintiff was discriminated against and harassed by his supervisor on the basis of his national origin, Thomas, and that he was retaliated against for complaining about Thomas’s conduct and names his employer NHS. These communications provide enough information as to the parties and as to the nature of his complaint to constitute an effective charge. Plaintiff also has evinced his intent to activate the EEOC’s involvement. He signed, dated and had notarized a form entitled “Charge of Discrimination,” added an attachment detailing the basis of his complaint against NHS and Thomas, and included a cover letter entitled “RE: Gharzouzi v. Northwestern Human Services” that referenced the attached charge of discrimination. The unambiguous nature of the communications distinguishes this case from cases like Bihler, where the court declined to hold that the communications at issue constituted a charge of discrimination because it was not clear that the plaintiff intended to activate the EEOC. In Bihler, the court concluded that the plaintiffs forwarding of a carbon copy of a letter that he had mailed to his employer indicating that he intended to institute legal proceedings if the employer-company did not rehire him did not constitute a charge of discrimination for administrative EEOC purposes. Unlike in Bih-ler, here, the content of the charge form itself, the cover letter and the attachment show Plaintiffs intent to file a charge with the EEOC and to begin EEOC proceed-' ings. Additionally, the EEOC’s response to Gharzouzi’s January 5, 2000 correspondence supports our finding that the letter, charge form and attachment constitute a charge of discrimination. On February 11, 2000, the EEOC wrote to Plaintiff, indicating that before it could docket the charge and begin the EEOC investigation, the EEOC needed to complete intake processing which might require Plaintiff to provide additional information. Although the letter stated that Plaintiff might be required to redraft the charge, the letter did not in any way indicate that the EEOC considered Plaintiffs January 5, 2000 communications to be anything other than a charge of discrimination. ■ Indeed, the letter did not state that Plaintiff was to do anything further in order to effect a charge; rather, it stated that next an EEOC investigator would contact Ghar-zouzi. Contrary to Defendants’ suggestions, this case differs from Gulezian v. Drexel Univ., No. CIV.A. 98-3004, 1999 WL 153720 (E.D.Pa. March 19, 1999). In Gulezian, the plaintiff argued that his completion of an intake questionnaire at the office of the EEOC constituted a charge of discrimination. The court rejected this argument. Because “[t]he EEOC clearly alerted plaintiff that further information and follow-up on his part were required to initiate a charge and gave plaintiff a written notice of a future appointment for an interview concerning the possible filing of a charge of discrimination ” (emphasis added) and then indicated that he needed to provide the agency with a written statement describing the basis for his discrimination claim, the court reasoned that the EEOC clearly did not consider the intake questionnaire to be a charge of discrimination and also concluded that no reasonable complainant could have believed it to be. Gulezian, 1999 WL 153720 at *3. Unlike in Gulezian, here, from the start, the EEOC unequivocally and consistently referred to Plaintiffs communications as a “charge” without qualifying the initiation of a charge of discrimination as a possible future event. Defendants point to our recent decision in Zysk v. FFE Minerals USA. Inc., 225 F.Supp.2d 482 (E.D.Pa.2001) in arguing that the EEOC’s failure to docket Plaintiffs January 5, 2000 correspondence and to assign it a charge number establishes that it does not constitute an effective charge of discrimination. Defendants misinterpret our opinion. Contrary to Defendants’ assertions, Zysk does not stand for the proposition that a charge of discrimination is effective only once docketed. In fact, in Zysk, we considered the plaintiff to have filed an effective charge as of the date on which the EEOC received the plaintiffs complaint, not on the later date when it was assigned a charge number and formally docketed. We concluded that where the plaintiff had submitted a nine-page, detailed, sworn complaint to the EEOC, the EEOC had more than enough information to begin its proceedings based on the complaint. See Zysk, 225 F.Supp.2d at 488. We reasoned that “common sense dictates that Plaintiff would believe his charge was filed with the EEOC on the date the agency received his sworn, detailed complaint,” id., 225 F.Supp.2d at 490, and were careful there to note that the failure to fill out an official EEOC form would not render the charge ineffective. See id., 225 F.Supp.2d at 489. With respect to the docketing of the charge and the assigning of a charge number, we remarked that “[h]aving assigned Plaintiffs claims against Defendant an official Charge number ..., the EEOC gave plaintiff every reason to believe that he had complied with the requirement to file with that agency within 300 days.” Id., 225 F.Supp.2d at 489. We further reasoned that “Plaintiff would know that he was protected from exceeding the 300-day statutory period as of the date he learned that a charge number had been assigned to his case.” Id., 225 F.Supp.2d at 490. In Zysk, then, we spoke of the docketing of the charge not as that which rendered the complaint effective, but rather as an indicator to the plaintiff that the charge had in fact been timely filed. Although the assigning of a charge number within the limitations period is a fairly good indicator that an effective charge has been received on time, but see Michelson v. Exxon Research and Eng. Co., 808 F.2d 1005, 1010-11 (3d Cir., 1987) (holding that where the writings on file were insufficient to constitute an effective charge, a charge had not been effectively filed, despite the fact that the EEOC had assigned the case a charge number), it is not, and Zysk does not stand for the proposition that it is, necessary for the EEOC to assign a charge number to a complaint before it is considered an effective charge of discrimination. Rather, as discussed supra at Section IV.A.l.c.i., what is required is that the EEOC receive a written communication from the plaintiff detailing the bases of the discrimination in a fashion sufficient to indicate his intent to activate the EEOC’s investigatory mechanisms. Accordingly, we hold that Plaintiffs January 5, 2000 correspondence contains enough information and sufficiently indicates his intent to constitute a charge of discrimination. All alleged acts of discrimination committed within 300 days of January 5, 2000, or after March 11, 1999, are within the 300-day limitations period. We deny Defendants’ Motion for Summary Judgment with respect to Plaintiffs Title VII claims on the grounds that they were not timely filed. iii. Consideration of Events Falling Outside of Limitations Period The only allegedly unlawful employment practices that fall outside of this time period are the three incidents that occurred on July 17, 1997, October 30, 1997 and in February of 1998. We consider whether there is any basis upon which these three events may nevertheless be considered with respect to either Plaintiffs retaliation claim or hostile work environment claim. Taking Plaintiffs retaliation claim first, although the 1997 and 1998 events relate to retaliation claim insofar as plaintiff might want to refer to them in order to provide a context for this claim, Plaintiff does not appear to allege that the 1997 and 1998 incidents form part of the basis for his retaliation claim. Rather, the actual discriminatory acts complained of are NHS’s suspension and termination of him. Each of these events relating to his retaliation claim occurred in September of 1999, well within the limitations period. Thus we need not consider whether the 1997 and 1998 occurrences may be considered for purposes of Plaintiffs retaliation claim. On the other hand, with respect to Plaintiffs hostile work environment claim, we presume that Plaintiffs position is that all of the events, including the 1997 and the 1998 incidents, form the basis for the claim. We will consider whether the 1997 and 1998 events may be considered even though they fall outside of the limitations period. We expect that Plaintiff would argue that the 1997 and 1998 events are part of an overall pattern of discrimination that worked to create a hostile work environment such that they should be considered, despite the fact that they fall outside of the limitations period. Under the “continuing violation theory,” a plaintiff “may pursue a Title VII claim for discriminatory conduct that began pri- or to the filing period if he can demonstrate that the act is part of an ongoing practice or pattern of discrimination of the defendant.” West v. Philadelphia Elec. Co., 45 F.3d 744, 754 (3d Cir.1995). A plaintiff must meet two requirements in order to establish that a claim falls within the continuing violations theory. “First, he must demonstrate that at least one act occurred within the filing period: The crucial question is whether any present violation exists.” Id. (internal quotations and citations omitted). “Next, the plaintiff must establish that the harassment is more than the occurrence of isolated or sporadic acts of intentional discrimination. The relevant distinction is between the occurrence of isolated, intermittent acts of discrimination and an on-going pattern.” Id. at 755 (internal quotations and citations omitted). “Once the plaintiff has alleged sufficient facts to support use of the continuing violation theory, ... the 300-day filing period becomes irrelevant — as long as at least one violation has occurred within that 300 days. Plaintiff may then offer evidence of, and recover for, the entire continuing violation.” Id. We find that Plaintiff has shown the existence of a present violation and meets the first prong of the continuing violation test. Indeed, Plaintiff alleges that several events occurred in June, July, August and September of 1999 that created a hostile work environment — all of which fall within the limitations period. However, we find that Plaintiff fails to establish the second prong of the continuing violation doctrine, that the events that occurred in 1997 and 1998 were part of a persistent and an ongoing pattern of discrimination. The next allegedly discriminatory act occurred in June of 1999, nearly two years from the July 17, 1997 event, more than a year-and-a-half from the time of the October 1997 event and over a year from the time of the February 1998 incident. The lapse of time between the 1997 and 1998 events and the events that occurred within the limitations period in the summer of 1999 is too great to support the application of the continuing violation theory with respect to the events in 1997 and 1998 falling outside the 300-day filing period. The 1997 and 1998 events are outside of the limitations period. We hold that any consideration of these events is barred. 2. Timeliness of Plaintiffs PHRA Claims a.Filing Requirements Under PHRA To bring suit under the PHRA, a plaintiff must have first filed an administrative complaint with the PHRC within 180 days of the date of the alleged act of discrimination. 43 PA. CONS.STAT. §§ 959(h). Absent circumstances justifying equitable tolling, if no complaint is filed with the PHRC within this time, then the plaintiff is precluded from seeking judicial relief. See Woodson v. Scott Paper Co., 109 F.3d 913, 925 (3d Cir.1997). In such a case, the court is deprived of jurisdiction over the PHRA claim. See Parsons v. Philadelphia Office of Drug and Alcohol Abuse, 833 F.Supp. 1108, 1112 (E.D.Pa.1993). This filing requirement is strictly interpreted and enforced. See Woodson, 109 F.3d at 925. b. Defendants’ Position Defendants argue that because the PHRC did not receive Plaintiffs charge of discrimination until May 9, 2000, more than 180 days after the date of Plaintiffs termination, Plaintiffs PHRA claims are thus time-barred and may not be considered by this court. (Defs.’ Mot. for Sum. Judg. at 19-21.) Plaintiff responds that his January 5, 2000 filing with the EEOC constitutes a contemporaneous filing with the PHRC pursuant to the work sharing agreement between the EEOC and the PHRC; he argues that having filed on January 5, 2000 — within 180 days of the date of his termination, September 24, 2000 — he has preserved his claims under the PHRA. (Pis.’ Response to Defs.’ Mot. for Sum. Judg. at 10-11.) c. Analysis of Timeliness of Plaintiffs PHRA Claims i. Filing Requirements Under PHRA We recognize that the mere filing of a charge with the EEOC is insufficient to satisfy the exhaustion requirements under the PHRA. See Woodson, 109 F.3d at 926. However, a plaintiff need not file separately with the PHRC in order for the state administrative remedies to be exhausted; the state law exhaustion requirements may be satisfied if a complaint filed with the EEOC is forwarded by the EEOC to the PHRC. See id. at 928. As a general rule, if the PHRC does not receive the complaint within 180 days from the date of the alleged act of discrimination, whether filed with the PHRC directly or filed first with the EEOC and later transmitted by the EEOC to the PHRC, the plaintiff is precluded from pursuing claims under the PHRA. See id., 109 F.Ed at 927. However, the PHRA statute of limitations is subject to equitable tolling. Where a plaintiff files a charge of discrimination with the EEOC within 180 days from the discriminatory act and also clearly indicates in his/her submission to the EEOC that he/ she is requesting cross-filing with the PHRC, the plaintiff may be allowed under equitable tolling principles to pursue the PHRA claims even if the complaint, due to a delay in the transmission of the charge from the EEOC to the PHRC, is forwarded, and arrives at, the PHRC after 180 days from the date of the discriminatory act have passed. Courts have held that the limitations period may be equitably tolled if the plaintiff indicates in the filing that is received by the EEOC within 180 days but is transmitted to the PHRC after 180 days his/her intent to dual-file, by checking the box on the EEOC form requesting that the complaint be cross-filed or so stating elsewhere, for instance, in a cover letter. See, e.g., Woodson, 109 F.3d at 926 n. 12 (“In this regard, we note that [plaintiff] Woodson’s case would be quite different if he had marked the box for the EEOC to cross-file and the EEOC had failed to transmit the charge because of a breakdown in the administrative system.)”; Carter v. Philadelphia Stock Exch., No. CIV.A. 99-2455, 1999 WL 715205, at *1 (E.D.Pa. August 25, 1999) (holding that failure of EEOC to transmit charge to PHRC within limitations period was subject to equitable tolling where plaintiff requested cross-filing in the cover letter attached to the EEOC charge, on the first page of the charge itself and on an official form used by the EEOC for requests for dual-filing); Forsburg v. Lehigh Univ., No. CIV.A. 98-CV-864, 1999 WL 124458, at *8 (E.D.Pa. March 4, 1999) • (finding plaintiff had exhausted administrative remedies under PHRA by filing a timely complaint with the EEOC where plaintiff checked box on EEOC form requesting cross-filing with the PHRC despite the fact that EEOC did not transmit the charge to the PHRC until after the expiration of the limitations period); Brennan v. Nat’l Tel. Directory Corp., 881 F.Supp. 986, 998 (E.D.Pa.1995) (finding equitable tolling appropriate where plaintiff indicated in her EEOC claim that the matter was to be filed with the PHRC but for reasons beyond her control the cross-filing did not occur). ii. Application of Law to Plaintiffs Charge Here, Plaintiff submitted his'charge to the EEOC on January 5, 2000, within the 180-day filing PHRA filing period, but the EEOC transmitted the charge to the PHRC on May 9, 2000, outside of the 180-day filing period. Despite the fact that Plaintiffs complaint was transmitted to the PHRC outside of the limitations period, we find that the limitations period was equitably tolled. We find that Plaintiffs communications sufficiently indicated his intent to dual-file. Plaintiff requested on the charge of discrimination form submitted by him to the EEOC and date-stamped as received by the EEOC on January 5, 2000 that the complaint also be filed with the PHRC. Plaintiff also indicated in his cover letter accompanying the form and date-stamped as received by the EEOC on January 5, 2000 that he was requesting cross-filing. Having filed the January 5, 2000 charge with the EEOC 103 days after the allegedly discriminatory act, Plaintiff could reasonably expect that his charge would be cross-filed within the 180-day period; the failure to meet the deadline for transmission to the PHRC was not his fault. Having found that the EEOC’s failure to transmit the charge to the PHRC within the 180-day period will not bar Plaintiffs claims based on the allegedly discriminatory acts occurring within that time period, we note that within the PHRA limitations period are all events that occurred 180 days prior to January 5, 2000, or, in other words, all the events that occurred between July 9, 1999 and January 5, 2000. We deny Defendants’ Motion for Summary Judgment as to Plaintiffs PHRA claims on the grounds that the charge was not timely filed. iii. Consideration of Events Falling Outside of PHRA Limitations Pe-nad Falling outside of the limitations period are the 1997, 1998, June 3, 1999, June 11, 1999, June 17, 1999, June 26 and June 28, 1999 events. Plaintiffs PHRA claims may not be based on these events unless they meet the continuing violation theory. As noted supra at Section IV.A.l.c.iii., each of the acts that Plaintiff alleges constitutes retaliation occurred in September of 1999; these acts are all within the 180-day PHRA limitations period and may form the basis of Plaintiffs claims. However, Plaintiffs hostile work environment claim includes the acts that occurred prior to July 9, 1999. For the same reasons discussed supra at Section IV.A.l.c.ni., the 1997 and 1998 events cannot be considered under a continuing violation theory; these acts are too remote in time from the events falling within the limitations period and are not sufficiently persistent to satisfy the second prong of the continuing violations theory. However, we find that for purposes of the PHRA, the events occurring before July 9, 2000 in June of 1999 satisfy the continuing violations criteria for purposes of Plaintiffs hostile work environment claim. There was a sufficient number of events in June (5 alleged), and these occurred on a sufficiently consistent basis (roughly a week apart) and close enough to the conduct that is within the limitations period to meet the continuing violation requirements. Therefore, we find that Plaintiff may base his PHRA hostile work environment claim on the incidents occurring in June of 1999, even though they technically fall outside of the limitations period. Assuming that Plaintiff can make out the hostile work environment elements, Plaintiff may then offer evidence of, and recover for, the entire continuing violation beginning in June of 1999 and continuing until his termination. 3. Timeliness of PHRA Claims With Respect to Individually Named Defendants a. Defendants’Position Defendants argue that even if the January 5, 2000 charge is considered the date that Plaintiffs charge was effected, the January 5, 2000 charge is not effective against Defendants Ciavardone, Fogle, Sheaffer, Tezak and Edwards for purposes of the PHRA because Plaintiffs January 5, 2000 communications named only NHS and Thomas, and not the other defendants. Plaintiffs argument appears to be that Pennsylvania administrative remedies were not exhausted with respect to these additional defendants because the charge that named them arrived at the PHRC on May 9, 2000, more than 180 days after the allegedly discriminatory practice and therefore outside of the limitations period. b. Filing Requirements Under PHRA “The filing of a charge before the EEOC [and, similarly, the transmission of the charge to the PHRC] serves to notify the charged party of the alleged violation and also bring the party before the EEOC [or the PHRC] to provide an avenue for voluntary compliance without resort to litigation.” Fuchilla v. Prockop, 682 F.Supp. 247, 266 (D.N.J.1987) (citing Glus v. G.C. Murphy Co., 562 F.2d 880, 888 (3d Cir.1977)). The Code of Federal Regulations provides that “ ‘a charge is sufficient when the Commission receives from the person making the charge a written statement sufficiently precise to identify the parties, and to describe generally the practices complained of.’ ” Edelman v. Lynchburg College, 535 U.S. 106, 122 S.Ct. 1145, 1148, 152 L.Ed.2d 188 (2002) (quoting and citing 29 CFR § 1601.12(b) (1997)). c. Application of Law to Plaintiffs PHRA Claims Against Individual Defendants Plaintiffs January 5, 2000 letter and charge mention only NHS and Thomas do not identify the additional parties. It is not sufficient to constitute a charge of discrimination against them. The record indicates that the first time that Ciavardone, Fogle, Sheaffer, Tezak and Edwards are mentioned in a charge is in the April 14, 2000 perfected draft charge signed by Plaintiff on April 18, 2000, date-stamped as received by the EEOC on April 21, 2000 and forwarded to the PHRC on May 9, 2000. Whether we use April 14, April 18, April 21 or May 9 as the date that the charge naming these additional plaintiff was effected, the charge is outside of the 180-day limitations period. Accordingly, the PHRA claims against these defendants are time-barred. In addition, principles limiting the exercise of pendant jurisdiction counsel against allowing Plaintiffs PHRA claims to go forward here. Although pendent party jurisdiction may be used in the federal employment context, see Stack v. Turnage, 690 F.Supp. 328, 333 (M.D.Pa.1988), case law establishes that courts ought not exercise pendent jurisdiction over state-law claims against individuals not properly named in the administrative charge. See Duva v. Bridgeport Textron, 632 F.Supp. 880, 885 (E.D.Pa.1985). As one district court has remarked, Congress has expressed a strong policy in favor of fostering reconciliation of discrimination complaints. This policy is embodied in an elaborate procedural mechanism which circumscribes the jurisdiction of district courts. Both the policy and its implementing mechanism could be subverted by exercising jurisdiction over state-law claims [against individuals not named in the administrative charge]. A complainant could partially by-pass the administrative stage simply by naming only one party as a respondent before the EEOC and then styling claims against other parties as state-law claims arising out of a nucleus of operative fact that is common with the claim presented to the EEOC. Duva, 632 F.Supp. at 885. Accordingly, we grant summary judgment as to Plaintiffs PHRA claims in favor of Defendants Ciavardone, Fogle, Sheaffer, Tezak and Edwards; the PHRA claims remain against NHS and Thomas only. 4. Validity of Claims Against Northwestern Human Services of Pennsylvania Defendants argue that Gharzouzi’s claims against Northwestern Human Services of Pennsylvania are barred by the statute of limitations. Section 706(f) of Title VII imposes a ninety-day statute of limitations once the notice of right-to-sue letter is issued. Defendants contend that Plaintiffs claims against NHS of PA are time-barred because this notice issued on October 16, 2000 and NHS of PA was not named as a defendant in this action until October 22, 2001 when Gharzouzi filed an amended complaint with leave of this Court. Defendants present in their Motion for Summary Judgment the same issues that this Court’s order dated October 10, 2001 resolved. In our order, we granted Plaintiff “leave to amend his complaint to name the Defendant as ‘Northwestern Human Services of Pennsylvania f/k/a Northwestern Human Service Inc. f/k/a Children’s Reach a/k/a/ and t/a Northwestern Human Services, and Northwestern Human Services Inc. f/k/a The Northwestern Corporation a/k/a and t/a Northwestern Human Services.’ ” We noted that there “leave to amend pleadings pursuant to Rule 15 shall not be given where such amendment would be futile” and recognized that “an amendment would be futile if a plaintiff is trying to add defendants after the statute of limitations period has expired.” See Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 9 L.Ed.2d 222 (1962); Jablonski v. Pan American World Airways, Inc., 863 F.2d 289, 292 (3d Cir.1988). We also noted that “had Plaintiff attempted to commence suit against Northwestern Human Services of Pennsylvania on September 21, 2001 (the date when plaintiff moved to amend his complaint), his claim would be time barred under 42 U.S.C. § 2000e-5(f).” However, we found that “plaintiffs amended complaint against Northwestern Human Services of Pennsylvania relate[d] back to the timely commencement of this action on January 12, 2001 pursuant to FRCP 15(c) and [was] thus not in violation of the statute of limitations.” In finding that the amended complaint related back to the commencement of the action on January 12, 2001, we found that the requirements of FRCP 15 were satisfied. We first found that “Northwestern Human Services of Pennsylvania ha[d] received notice of institution of this action because its. parent corporation and director ha[d] been named' as defendants.” Further, we found that “Northwestern Human Services of Pennsylvania knew or should have known that, but for a mistake concerning the identity of the proper party, the action would have been brought against it.” We reiterate these findings today. To state our conclusion otherwise, we find that within the requisite time period NHS of PA not only had notice of the lawsuit against Northwestern Human Services, but also had notice that Gharzouzi intended to join it, NHS of PA, in the case. Accordingly, we deny Defendants’ motion for summary judgment with respect to their claim that Plaintiffs federal claims against NHS of PA are time-barred. B. Title VII Claims Title VII “makes it unlawful for an employer ‘to discriminate against any individual with respect to his [or her] compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.’ ” Kunin v. Sears Roebuck & Co., 175 F.3d 289, 293 (3d Cir.1999) (citing 42 U.S.C. § 2000e-2(a)(l)). Plaintiff alleges under Title VII that he was subjected to a hostile work environment because of his national origin and was retaliated against for engaging in a protected activity. We consider each of Plaintiffs Title VII claims in turn. 1. Hostile Work Environment Claim a. Nature of Hostile Work Environment Claim The Supreme Court has “repeatedly made clear that although the statute [Title VII] mentions specific employment decisions with immediate consequences, the scope of the prohibition is not limited to economic or tangible discrimination and that it covers more than ‘terms’ and ‘conditions’ in the narrow contractual sense.” Faragher v. City of Boca Raton, 524 U.S. 775, 786, 118 S.Ct. 2275, 141 L.Ed.2d 662 (1998) (internal quotations and citations omitted). The Court thus recognized in Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57, 106 S.Ct. 2399, 91 L.Ed.2d 49 (1986) that sexual harassment so “severe or pervasive” as to “alter the conditions of [the victim’s] employment and create an abusive working environment” violates Title VII. See Meritor, 477 U.S. at 67, 106 S.Ct. 2399. First recognized by the Supreme Court in Meritor, a case in which the plaintiff claimed sexual harassment, the hostile work environment doctrine “is now established as a basis for various discrimination claims,” Cardenas v. Massey, 269 F.3d 251, 260 (3d. Cir.2001), including claims based on national origin. See generally Cardenas, 269 F.3d 251 (analyzing hostile work environment claim based on the plaintiffs status as a Mexiean-Ameri-ean); Abramson v. William Paterson College of New Jersey, 260 F.3d 265, 277 n. 5 (3d Cir.2001) (noting that the Third Circuit has construed Title VII to support claims of a hostile work environment with respect to national origin). b. Court’s Inquiry into Hostile Work Environment Claim A court considering a Title VII hostile work environment claim must generally consider “all circumstances regarding a plaintiffs employment, including the frequency and severity of any discriminatory conduct, the physically threatening or humiliating or offensive nature of such conduct, and the effect on the plaintiffs performance and psychological well-being.” Koschoff v. Henderson, 109 F.Supp.2d 332, 345 (E.D.Pa.2000) (citing Harris v. Forklift Sys., Inc., 510 U.S. 17, 114 S.Ct. 367, 126 L.Ed.2d 295 (1993)). The Third Circuit requires that a plaintiff alleging hostile work environment under Title VII show five conditions: (1) the employee suffered intentional discrimination because of his or her protected class (here, national origin); (2) the discrimination was pervasive and regular; (3) the discrimination detrimentally affected the plaintiff; (4) the discrimination would detrimentally affect a reasonable person of the same national origin in that position; and (5)the existence of respondeat superior liability. Andrews v. City of Philadelphia, 895 F.2d 1469, 1482 (3d Cir.1990). In considering whether Gharzouzi has established the elements of a hostile work environment claim, “the record must be evaluated as a whole” to decide whether he has proved his case because “particularly in the discrimination area, it is often difficult to determine the motivations of an action ... A discrimination analysis must concentrate not on individual incidents, but on the overall scenario.” Cardenas, 269 F.3d at 260-61 (internal quotations and citations omitted). Indeed, as the Third Circuit notes, “the advent of more sophisticated and subtle forms of discrimination requires that we analyze the aggregate effect of all evidence and reasonable inferences therefrom, including those concerning incidents of facially neutral mistreatment, in evaluating a hostile work environment.” Id., 269 F.3d at 261-62. c. Defendants’Position Defendants argue that summary judgment should be granted in favor of Defendants on Gharzouzi’s hostile work environment claim because Plaintiff fails to establish the necessary elements for a hostile work environment claim. First, Defendants argue that Plaintiff cannot show that the acts that Plaintiff alleges constitute harassment were in fact “motivated by an animosity for Lebanese people;” they argue that the incidents were “simply admonitions by a supervisor, Rick Thomas, [for Gharzouzi] to correct his behavior.” (Defs.’ Mot. for Sum. Judg. at 31.) Defendants likewise argue that Gharzouzi fails to demonstrate that the alleged harassment was pervasive and regular. (Id. at 32.) Defendants further argue that “even if the number and content of these conversations were enough to portray a pervasive, hostile environment, there is no evidence Gharzouzi was affected.” (Id. at 32-33.) Defendants finally argue that “any reasonably objective person with Gharzouzi’s background would not have perceived Thomas’s comments as discriminatory.” (Id. at 33.) d. Gharzouzi’s Allegations Gharzouzi points to eight incidents that he alleges created a hostile work environment. First, Gharzouzi alleges that on June 3, 1999, he and Thomas got into an argument about whether particular students should be required to perform community service. According to Gharzouzi, Thomas, who believed that the students should not be required to do community service, told Gharzouzi, who believed that the students should do community service, that Gharzouzi’s education was old and not up-to-date on this topic and also stated with the use of an expletive that he [Thomas] was the director. Plaintiff next alleges that on June 11, 1999, Thomas reprimanded him for the way he spoke to the staff nurse, saying that he believed that Ghar-zouzi had hurt her feelings; Thomas mentioned the way that Gharzouzi said things, the way that he used his hands, the way that he looked at her and his voice. According to Gharzouzi, on June 17, 1999, after Gharzouzi planned an office party for a co-worker, Thomas reprimanded Ghar-zouzi for planning the party without his approval and told Gharzouzi that he needed to start learning “our” way and added that the “buck will stop here.” On June 26 and July 15, 1999, Thomas directed Ghar-zouzi to rewrite a memorandum, allegedly telling him that he did not know how to write a memorandum due to his “English language barrier.” Gharzouzi stated that he felt at this time as though he was being harassed and that Thomas was making it impossible for him to do his job and was creating unhealthy working conditions. On June 28, 1999, Plaintiff alleges that Thomas confronted him regarding union issues and stated that he [Thomas] directed the place, that he did not want to hear any of Gharzouzi’s ideas and that if Ghar-zouzi still wanted to have a job at NHS, he would have to change his way of thinking. On August 30, 1999, according to Plaintiff, Thomas confronted Gharzouzi at which time Thomas mentioned the problem that he had with the way Gharzouzi talks, uses his hands and his accent. At this time, according to Gharzouzi, Thomas told him that he could leave if he did not want to work there. Finally, in September of 1999, Thomas confronted Gharzouzi about the room assignment decision. Gharzouzi explained that it was a team decision and Thomas allegedly replied that he was the director and that Gharzouzi had made a decision without being a team player. Gharzouzi alleges that Thomas stated that “the buck will stop here” and made other statements about Gharzouzi’s culture and mocked his accent and the use of his hands that Gharzouzi considered harassment. Gharzouzi’s deposition also indicates that Thomas “mocked my accent, the way I talk, the way I explain things. He mentioned to me numerous times the language barrier, numerous times told me this is America, we have to learn America’s culture. Every tíme I talked to him about something, he mocks me, you know the way he repeats what I said, but in different language. He makes fun about my body language; he makes fun about my decision-making.” (N. Gharzouzi Dep. at 49.) Gharzouzi’s hostile environment claim, then, is based upon the series of verbal encounters between him and Thomas spanning from June 3, 1999 until his termination in September of 1999. We consider whether Plaintiff meets each of the five conditions necessary under Andrews to establish a hostile work environment claim. e. Application of Andrews to Plaintiffs Hostile Work Environment Claim i. Existence of Intentional Discrimination Verbal ... harassment, no matter how unpleasant and ill-willed, is not prohibited by Title VII if not motivated by the plaintiffs membership in some protected group. See Koschoff v. Henderson, 109 F.Supp.2d 332, 346 (E.D.Pa.2000). Mistreatment that is not motivated by the plaintiffs protected class does not create a hostile environment. See id. Conduct motivated by a bad working relationship is not prohibited by Title VII. See id. “Nor are an employer’s actions when based upon a belief, even if mistaken, that an employee was insubordinate or otherwise acted improperly.” Id. “Likewise, seemingly discriminatory behavior when actually motivated by personal animosity is not prohibited by Title VII.” Id. Moreover, however inappropriate, “racial comments that are sporadic or part of casual conversation do not violate Title VII.” Al-Salem v. Bucks County Water & Sewer Auth., No. 97-6843, 1999 WL 167729, at *5 (E.D.Pa. March 25, 1999) (internal quotations and citations omitted). Rather, “[f]or racist comments, slurs and jokes to constitute a hostile work environment, there must be more than a few isolated incidents of racial enmity, meaning that instead of sporadic racist slurs, there must be a steady barrage of opprobrious racial comments.” Id. Nevertheless, a plaintiff need not demonstrate direct evidence of the alleged harasser’s motivation for discrimination against him. See Abramson v. William Paterson College of New Jersey, 260 F.3d 265, 277-78 (3d Cir.2001). The first prong of the Andrews test does not require fact-finder “to peer inside the harasser’s mind,” but “merely requires a showing that the offender’s behavior was ... based on a protected category.” Id. Because “discrimination is often masked in more subtle forms, it is often difficult to discern discriminatory animus” and “with respect to certain conduct, the intent to discriminate can be inferred.” Id. (internal quotations and citations omitted). We are cognizant of the fact that 'courts are not to consider the events that allegedly constitute a hostile environment in isolation. See supra at Section IV.B.l.b. Nevertheless, with respect to the first Andrews prong, courts will frequently look to see whether each of the alleged events can be said to have been motivated by discriminatory reasons. See, e.g., Al-Salem, 1999 WL 167729 at *6-7 (considering individually each of the events that allegedly constituted harassment). Having done this, we find as a matter of law, based on the record before us, that a jury could not reasonably find Thomas’s comments on June 3, 1999 and June 28, 1999 to be motivated by improper discriminatory animus. Gharzouzi can point to nothing in these conversations showing discriminatory animus. The record shows that on both June 3 and June 28, respectively, Thomas approached Gharzouzi regarding legitimate employment-related concerns, namely whether residents should be required to engage in community service and whether Gharzouzi was involved in union organizing. With respect to the June 3 incident, Thomas’s comments appear to be an attempt to explain to Gharzouzi that he believed that his approach to community service was misguided. Absent some showing that his conduct was actually motivated by improper discriminatory reasons, a supervisor like Thomas may express his dissatisfaction with an employee’s philosophy or methodology. Although his words may reflect contempt for his subordinate, the fact that Thomas may have utilized an expletive, without more, does not establish that his words were improperly motivated. See Al-Salem, 1999 WL 167729 at *6 (deciding that although the supervisor’s remark “look at me now ... I’m your supervisor” may have been arrogant or presumptuous and may have reflected a certain scorn for formal education and a distaste for the college educated, one could not reasonably find that remark was made because of the protected class to which plaintiff belonged). Similarly, with respect to the June 28, 1999 incident, Thomas’s remarks, wit