Full opinion text
DECISION and ORDER CURTIN, District Judge. BACKGROUND Plaintiff Robert E. Neratko brings this employment discrimination action alleging disparate treatment and retaliation under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq. (“Title VII”). Plaintiff claims that the United States Postal Service (“USPS”), through the actions of the Postmaster and the Superintendent of Postal Operations at the West-field, New York, Post Office (“Westfield P.O.”), discriminated against him because of his sex and in retaliation for his internal complaints, his use of the union grievance procedures, and his use of the Equal Employment Opportunity (“EEO”) process with regard to defendant’s alleged sex discrimination. Plaintiff specifies a long list of allegedly discriminatory actions, including the unequal allocation of work assignments, the unequal scheduling of work hours, and the unequal application of disciplinary measures (Item 101; Item 109, ¶ 35; Item 232, at 19-78). Plaintiff originally filed three separate lawsuits, 85-CV-1259, 86-CV-462, and 95-CV-657. On November 12, 1986, the court consolidated 86-CV-462 with the present ease (Item 22). On September 7, 1988, plaintiff filed a Second Amended Complaint, which encompassed all of the relevant allegations contained in both cases. On May 17, 1996, the court consolidated 95-CV-657 with the present case (Item 224). Currently pending is defendant’s motion for summary judgment on all of plaintiffs claims (Item 226). In this consolidated action, plaintiff seeks: (1) declaratory judgment finding that the practices about which he has complained violate Title VII; (2) fairly exhaustive injunctive relief enjoining the USPS and any of its agents or employees from engaging in each of the practices which he alleges violates Title VII and directing the USPS to take specific action in the management of the Westfield P.O., both with respect to plaintiff and more generally; (3) compensation for all earnings, wages, pension, sick pay, fringe, and retirement benefits that plaintiff would have received but for the alleged discriminatory acts; and (4) an award of attorneys’ fees and costs associated with this action (Item 101, at 61-67; 95-CV-657, Item 1, at 6). In 1992, plaintiff sought to amend his complaint to allege new claims for compensatory and punitive damages pursuant to the Civil Rights Act of 1991 (Item 164). On December 27, 1994, this court denied plaintiffs motion (Item 206). Therefore, plaintiff’s remedies are limited to back pay, injunctive relief, and attorneys’ fees. Defendant contends that despite the extraordinary amount of time plaintiff has been afforded to prepare his submissions, he has failed to provide material evidence from which a finder of fact could find that plaintiff suffered adverse employment actions as a result of sex discrimination or in retaliation for his use of the EEO process (Item 249, at 1-6). Plaintiff argues that he has submitted evidence adequately disputing defendant’s affidavits such that summary judgment cannot be granted (Item 240, at 9-10). FACTS Plaintiff, a white male, was employed as a part-time flexible clerk (“PTF clerk”) at the Westfield P.O. during all times relevant to this action. Plaintiff is currently still employed by the USPS. Plaintiff was hired by the USPS as a PTF clerk in May 1983, and he was first assigned to the Jamestown, New York, Post Office (“Jamestown P.O.”).(Item 101, ¶¶ 13-14). Plaintiff transferred from the Jamestown P.O. to the Westfield P.O. in June 1984. Both sides agree that prior to the transfer, the Westfield Postmaster, Bal-dur Kutschke (“PM Kutschke”), told plaintiff that the PTF clerk position would involve both duties as a clerk and as a relief carrier. Plaintiff asserts that PM Kutschke advised plaintiff that both the clerk and the carrier work would be divided equally among all PTF clerks (Item 242, ¶ 6). Defendant contends that PM Kutschke told plaintiff that the Westfield P.O. needed a PTF clerk to replace a retired clerk who frequently filled in as a carrier, and he explained that plaintiff would be doing that carrying (Item 234, ¶ 6). Both sides also agree that prior to his transfer, plaintiff advised PM Kutschke that plaintiff was a member of the U.S. Air Force Reserves and would need to attend reserve training for one weekend a month and for two weeks during the summer (Item 242, ¶ 7; Item 234, ¶ 7). At the time of plaintiffs transfer, one of the PTF clerks at the Westfield P.O. was Colleen Howser, a female. Plaintiff contends that within several weeks of his transfer, he noticed that PTF Howser was not required to perform mail carrier duties (Item 240, at 2). Plaintiff claims that while he did not object to performing such carrier work, he believed that the work should be distributed equally among all PTF clerks (I'd). In July 1984, plaintiff asked the Superintendent of Postal Operations (“SPO”) at the Westfield P.O., Peter Nagle, why PTF Howser was not required to carry mail. Plaintiff claims that SPO Nagle explained that PTF Howser was “not a man ... [and] can’t carry the bag,” and that she was the second income in her family and therefore did not need the money (Id.; Item 242, ¶ 48). Plaintiff explains that this was not the first time that the management at the Westfield P.O. had been challenged for its failure to distribute relief carrier work equally to all PTF clerks. Several years earlier, PTF clerk Richard Seharf similarly complained that PTF Howser was not required to perform carrier work, and he filed an EEO complaint (Item 240, at 2-3; Item 244, Exh. A, at 124-25). On August 2, 1984, plaiptiff delivered a letter to PM Kutschke requesting that PTF duties be distributed equally among PTF clerks (Item 240, at, 3). Item 234, Exh. D). Plaintiff contends that from that day forward, the Postmaster and the SPO began a campaign to force plaintiff to conform his attitude to their policy that PTF Howser, as a female, should not be required to perform the more arduous jobs (Item 240, at 3). Plaintiff alleges that the most significant actions taken by the Postmaster and the SPO involved disparate scrutiny of plaintiffs work, .disparate impositions of disciplinary actions, reductions in, plaintiffs actual or potential work hours, and falsification of records (Id.). At the time plaintiff delivered this first letter of complaint to PM Kutschke, plaintiff indicated that he wished to appoint his father, Joseph Neratko, as his representative to resolve his' grievances with the Westfield P.O. (Item 234, ¶ 9 and Exh. D). Joseph Neratko had served as the last full-time Postmaster before PM Kutschke at the Westfield P.O. (Id. ¶ 9). Defendant contends that plaintiff lacked the legal right to appoint a grievance representative, because under plaintiffs union contract, only the American Postal Workers Union (“APWU”) could name a grievance representative for a bargaining unit employee, which did not happen until May 1985 (Id. ¶ 9). Defendant contends that plaintiff all but refused to deal ■with the Westfield P.O. management unless they would deal with Joseph Neratko (Id. ¶ 18). After the initial letter of complaint, Joseph Neratko contacted PM Kutschke in writing and' requested the opportunity to -discuss plaintiffs concerns of alleged discriminatory treatment (Item 101, ¶ 37). On August 17, 1984, Joseph Neratko sent a letter to the Buffalo Postmaster/SC Manager, William Miller, wherein he explained his belief that plaintiff was being discriminated against because of his sex, requested that the discriminatory treatment cease, and alleged that the adverse actions had been taken against plaintiff because of his prior complaints regarding job responsibilities among men and women (Id. ¶ 39 and Exh. 3; Item 234, Exh. D, at 41-42). On August 29, 1984, Joseph Nerat-ko sent a letter to the Postmaster General of the United States charging PM Kutschke and SPO Nagle with sex discrimination in the allocation of job responsibilities between the two PTF clerks at the Westfield P.O. and with retaliation against plaintiff for his complaints of illegal sex discrimination (Item 101, ¶ 40 and Exh. 4; Item 234, Exh. D, at 26-29). Defendant notes that in his letter to the U.S. Postmaster General, Joseph Neratko accused PM Kutschke of “serious violations of Postal Regulations and Postal Policy,” “clear cut fraud,” and “illegal hiring practices,” and questioned PM Kutschke’s “integrity, honesty and sincerity in the performance of his official duties,” (Item 234, ¶ 10). ■ ■' These allegations resulted in an investigation of the Westfield P .0. (Item 234, Exh. D, at 55). On September 12, 1984, PM Kutsch-ke replied to the charges, while also pointing out that Joseph Neratko and plaintiff had ulterior motives in attacking the Westfield P.O. management (Id. ¶ 11 and Exh. D). In his affidavit submitted in support of defendant’s motion for summary judgment, PM Kutsehke submits that in the fall of 1984 he was facing “an ambitious father and son team of antagonists, with the father having a score to settle with the Postal Service, or at least the Westfield office that had complained about the autocratic way he ran the office.” (Id. ¶ 12). PM Kutsehke further explains that plaintiff and his father chose to create their own grievance process despite reminders that they had 'to use the legitimate avenues of complaint, either union grievances or complaints with the EEO (Id.). Defendant attaches a large compilation of Joseph Nerat-ko’s correspondence to illustrate the “vituperative” style of his approach (Id., Exh. D and F). Joseph Neratko’s efforts to bring plaintiffs complaints to the attention of PM Kutsehke and SPO Nagle, as well as to their superiors in the USPS, continued throughout the first half of 1985. In February 1985, Joseph Ner-atko wrote additional letters to the Buffalo Postmaster and to the Director of Employee and Labor Relations in the Buffalo Post Office complaining that PM Kutsehke refused to allow Joseph Neratko to accompany his son in meetings with PM Kutsehke or to use reference materials located in PM Kutschke’s private office (Item 234, ¶ 15 and Exh. F). Defendant contends that Joseph Neratko had no authority to enter PM Kutschke’s private office for any purpose since he was neither an employee of the USPS, nor a properly appointed representative of plaintiff at that time (Id.). Joseph Neratko closed his letter to the Buffalo Postmaster stating “[i]n the event that I do not hear from your office in a reasonable time, I am inserting this letter, as a paid advertisement, in the local newspapers in Chautauqua County.” (Id. ¶ 16 and Exh. F). On December 13, 1984, plaintiff filed an informal EEO complaint of sexual discrimination (Item 101, ¶43 and Exh. 6). In his formal complaint, filed on January 23, 1995, plaintiff claimed that the allocation of work activities between himself and the other PTF clerk was discriminatory based on sex (Id., Exh. 8). Plaintiff claims that his filing of the EEO complaint exacerbated the harassment by PM Kutsehke and SPO Nagle (Item 240, at 3). For example, plaintiff asserts that the day after PM Kutsehke was advised of plaintiffs complaint, plaintiff was denied a regular step increase to his salary (Id.; Item 242, ¶ 22). Defendant submits that that decision was made on or around December 1, 1984, before plaintiff even filed his informal EEO complaint, and that the decision to deny plaintiff the step increase had been made in Buffalo, not Westfield (Item 249, at 42). Plaintiff alleges that other retaliatory actions by PM Kutsehke and SPO Nagle included a seven-day suspension on February 6, 1985, the hiring of a new female PTF clerk on April 1, 1985 (which reduced plaintiffs hours), a fourteen-day suspension on May 10, 1985, two additional suspensions in June 1989 (originally brought in 95-CV-657), the deliberate reduction, of work hours assigned to plaintiff, the deliberate assignment of more strenuous work, the refusal to loan plaintiff to other area post offices, and many additional disciplinary measures (particularly letters of warning) from 1985 to 1988 (Item 242, ¶ 23; Item 101, ¶¶ 49-61, 71, 82-134, 136-46). Furthermore, plaintiff contends that the Westfield P.O. management did not discipline other employees when they made mistakes in their work, and that this disparate treatment was also retaliatory in nature (Item 101, ¶ 135). Defendant contends that plaintiffs poor performance and unavailability were the causes of disciplinary actions and reduced hours, as well as the need to hire a new PTF clerk (Item 234, ¶¶ 25-32). Defendant claims that (1) starting on December 5, 1984, plaintiff told PM Kutsehke that he did not want to carry postal routes any more (Item 234, ¶ 25 and Exh. J); (2) plaintiff consistently made errors when he worked as a window clerk, resulting in his suspension from window service (Id. ¶ 25); (3) plaintiffs Air Force Reserve commitment made him unavailable for twelve Saturdays and two summer weeks each year (Id. ¶¶ 26 and 32); (4) plaintiff used sick leave and spread out his annual leave far more than other PTF clerks (Id. ¶ 26); and (5) plaintiff purposefully made himself unavailable for work in nearby postal offices (Id. ¶ 29). Plaintiff asserts that he never stated that he would not or did not want to carry mail (Item 242, ¶ 26) and that he advised PM Kutsehke of his desire to obtain additional hours by performing carrier work (Id. ¶ 27). Furthermore, he contends that there is sufficient evidence to prove that his hours were reduced as a result of sex discrimination and retaliation for his filing EEO charges, and not as a result of his unavailability or poor performance (Id. ¶¶ 29-30). Specifically, he submits that: (1) a memorandum from SPO Nagle to Ed Lott at USPS Labor Relations contains an admission of the retaliatory intent on the part of the Westfield P.O. management (Id. ¶ 30 and Exh. E); (2) the time cards for the years 1985 through 1988 show that plaintiff was assigned significantly fewer hours than other PTF clerks (Id. ¶¶ 32-36; Item 243); (3) a close analysis of his work hours demonstrates that his unavailability due to Air Force Reserve obligations and the use of sick and annual leave do not explain the disparity in hours worked (Id. ¶¶ 37-43); (4) statements made by PM Kutsehke and SPO Nagle in the presence of Westfield P.O. employees made it clear that females were favored and given preferences over males (Item 240, at 5-6; Item 244); (5) there is proof that female PTF clerks were assigned lighter clerk duties while male PTF clerks were asked to perform the more difficult and strenuous work, such as unloading and carrying; and (6) there is proof that the mistakes of other employees went unpunished, while plaintiff was frequently disciplined (Item 240, at 6-7). On December 31, 1987, this court granted defendant’s motion to dismiss the consolidated action in part, finding that plaintiffs claims of retaliation concerning events prior to the filing of his EEO complaint on December 13, 1984, are not viable under Title VII (Item 56). Despite this ruling, plaintiff has continued to allege that PM Kutsehke and SPO Nagle unjustly used disciplinary measures in retaliation for plaintiffs complaints of sex discrimination (Item 109, ¶ 20; Item 242, ¶ 66). Plaintiff argues that the actions of the Postmaster and SPO starting in August 1984 are evidence of defendant’s retaliatory intent for their conduct after December 13,1984 (Item 109, ¶ 20). DISCUSSION I. Summary Judgment Summary judgment is appropriate when “there is no genuine issue as to any material fact, and the moving party is entitled to a judgment as a matter of law.” Fed.R.Civ.P. 56(c); Citizens Bank v. Hunt, 927 F.2d 707, 710 (2d Cir.1991). When deciding a motion for summary judgment, the court must “resolve all ambiguities and inferences ... in the light most favorable to the party opposing the motion.” Shockley v. Vermont State Colleges, 793 F.2d 478, 481 (2d Cir.1986) (citations omitted). There is no genuine issue of material fact if, based upon the submissions to the court, no rational fact-finder could find in the non-movant’s favor. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). It is the function of the court to determine whether there is a genuine issue for trial, not to determine the truth of the matter. Carter v. Carriero, 905 F.Supp. 99, 102 (W.D.N.Y.1995) (Skretny, J.). When used properly, Rule 56 is a “vital procedural tool to avoid wasteful trials.” Capital Imaging v. Mohawk Valley Medical Associates, 996 F.2d 537, 541 (2d Cir.), cert. denied, 510 U.S. 947, 114 S.Ct. 388, 126 L.Ed.2d 337 (1993). In an employment discrimination action, where an employer properly shows a legitimate, non-discriminatory reason for the action at issue, a plaintiff may not avoid summary judgment by relying upon an inference of causation based upon the temporal proximity of the protected activity and the adverse action. Instead, the plaintiff must show sufficient evidence to support a rational finding that the legitimate, nondiscriminatory reasons proffered by the employer are false, and that more likely than not, discrimination was the real reason for the adverse action. See Van Zant v. KLM Royal Dutch Airlines, 80 F.3d 708, 714 (2d Cir.1996); see also McGuire v. United States Postal Service, 749 F.Supp. 1275, 1284 (S.D.N.Y.1990) (“Plaintiff may preclude summary judgment by producing evidence from which the trier of fact reasonably could draw an inference of discrimination.”). Conclusory allegations suggesting a causal relationship between the protected activity or the plaintiffs membership in a protected class and adverse employment actions will not defeat summary judgment. Van Zant, 80 F.3d. at 714. II. Exhaustion of Administrative Remedies Before reaching the merits of plaintiffs sex discrimination and retaliation claims, the court must consider defendant’s contention that plaintiff has not properly raised many of his claims in the EEO process. A district court may only hear those claims that either are included in an EEO charge or are based on conduct subsequent to the EEO charge which is “reasonably related” to that alleged in the EEO charge. Spurlock v. NYNEX, 949 F.Supp. 1022, 1027 (W.D.N.Y.1996) (Curtin, J.); Butts v. City of Neto York Dept. of Housing, 990 F.2d 1397, 1401 (2d Cir.1993) (quoting Stewart v. United States Immigration and Naturalization Service, 762 F.2d 193, 198 (2d Cir.1985)). This exhaustion requirement is designed to give the administrative agency the opportunity to investigate, mediate, and take remedial action to encourage the settlement of discrimination disputes through conciliation and voluntary compliance. If a complainant could litigate a claim not previously presented to and investigated by the EEO, then the exhaustion element of Title VII’s statutory scheme could easily be circumvented. Spurlock, 949 F.Supp. at 1027; Butts, 990 F.2d at 1401. The Second Circuit has identified three situations where claims not alleged in an EEO charge are sufficiently related to the allegations in the charge such that it would be unfair to bar such claims in an employment discrimination action brought under the federal civil rights laws: (1) where the conduct complained of would fall within the scope of the EEO investigation which could be reasonably expected to grow out of the charge of discrimination; (2) where the plaintiff alleges retaliation by the employer for filing the EEO charge; and (3) where the complaint alleges further incidents of discrimination carried out in precisely the manner alleged in the EEO charge. Spurlock, 949 F.Supp. at 1027 (citing Butts, 990 F.2d at 1402). Plaintiffs lengthy list of allegedly retaliatory employment actions appears in paragraph 35 of his pretrial statement (Item 109). Defendant has responded to these allegations of adverse employment action in a systematic fashion (Item 232, at 20^48; Item 234, ¶ 33). Specifically, defendant challenges many of plaintiffs claims by asserting that plaintiff failed to file an EEO complaint in connection with certain allegations (Item 234, ¶¶ 33(a)-(d), (f)-(m), (o), (v), (x)-(dd), (hh)-(mm)). Plaintiff has attached copies of his EEO complaints to his second amended complaint (Item 101, Exh. 8, 10-14); however, several EEO complaints appear to be missing. Furthermore, plaintiff has not responded to this aspect of defendant’s challenge, despite ample opportunity to do so. After a careful review of plaintiffs claims and the attached EEO complaints, it appears that many of them cannot be brought before this court due to plaintiffs failure to exhaust his administrative remedies. Plaintiffs first twelve allegations (Item 109, ¶¶ 35(a)-((); Item 232, at 20-26) must be dismissed for failure to exhaust because plaintiff has not demonstrated that: (1) he filed an EEO complaint raising any of these claims; (2) the conduct complained of falls within the scope of the EEO investigation which can reasonably be expected to grow out of a prior charge of discrimination; (3) the alleged conduct was retaliation for the filing of a prior EEO charge; or (4) that the conduct is merely a further incident of discrimination carried out in precisely the manner alleged in the EEO charge. See Butts, 990 F.2d at 1401-OS. Although many of these allegations involve claims of retaliation, they all predate plaintiffs first EEO complaint, and this court has already held that plaintiffs retaliation claims concerning events which precede the filing of plaintiffs December 13, 1984, EEO complaint cannot remain in this case (Item 56). Plaintiffs pretrial statement (Item 109) also contains a series of claims concerning defendant’s alleged sex discrimination. Plaintiffs claims concerning defendant’s sex discrimination in paragraphs 5 and 12 of his pretrial statement may go forward as part of his retaliation cause of action because he did file EEO complaints alleging unfair reprisal for each of these claims (Item 101, Exh. 6 and 15). In addition, plaintiffs claims in paragraphs 9-11,14, and 16-17 of his pretrial statement may proceed to the merits because plaintiff arguably filed EEO complaints either directly on point or arguably relevant to these claims (Item 101, Exh. 6, 10 (reasonably related to ¶¶ 9-11); Exh. 15 (reasonably related to ¶ 14); Exh. 11, complaint dated February 7, 1986 (reasonably related to ¶¶ 16-17)). To the extent that there is uncertainty as to whether plaintiff has satisfied the Butts and Spurlock tests regarding exhaustion of administrative remedies, this court simply construes all facts and resolves all ambiguities in favor of the plaintiff. Therefore, because defendant has not demonstrated that the cited EEO complaints do not relate to plaintiffs allegations of sex discrimination, the court must allow these claims to go forward on the sex discrimination causes of action. Plaintiffs claims concerning defendant’s discriminatory retaliation in paragraphs 35(p)-35(t) of his pretrial statement may go forward as part of plaintiffs retaliation cause of action because he did file EEO complaints alleging unfair reprisal for each of these claims (Item 101, Exh. 8, 10-14). Plaintiffs claims in paragraphs 35(m), ip), (u)-(v), (x)(ff), (hh)-(mm) of his pretrial statement may proceed to the merits because even though plaintiff did not file EEO complaints for each of these claims either at all or in a timely manner, plaintiff has alleged that defendant retaliated against him for filing complaints of sex discrimination. Thus, he may bring these claims without having filed separate EEO charges under Butts and Spurlock. Finally, plaintiffs claims in paragraphs 35(n), 35(w), and 33(gg) of his pretrial statement involving the hiring of an additional PTF clerk and the consequent reduction in plaintiffs work, the limiting of plaintiffs hours, and the issuance of an eighth letter of warning on October 2,1987, respectively, can go forward because defendant concedes that plaintiff filed EEO complaints either directly on point or arguably relevant to these claims (Item 232, at 27, 33-35, 43-44). Plaintiffs claims that his two suspensions in June 1989 were the product of both sex discrimination and reprisal, originally brought under 95-CV-657, may proceed to a discussion on the merits because it is evident that plaintiff brought both claims before the EEO. Both claims went through an administrative hearing (Item 234, Exh. H and I). In sum, the following claims may proceed to review on the merits, both for purposes of this summary judgment motion and in any further proceedings in this case: (1) plaintiffs claims in paragraphs 5, 9-12, 14, and 16-17 of his pretrial statement (Item 109) may go forward as part of plaintiffs sex discrimination cause of action; (2) plaintiffs claims in paragraphs 35(m)-(mm) of his pretrial statement may go forward as part of plaintiffs retaliation cause of action; (3) plaintiffs claims articulated in 95-CV-657 may go forward as parts of both plaintiffs sex discrimination and retaliation causes of action. Plaintiffs claims articulated in paragraphs 35(a)-(Z) of his pretrial statement are hereby dismissed. III. Plaintiff’s Allegations of Sex Discrimination at the Westfield P.O. Title VII makes it unlawful “for an employer ... to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual ... because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(1). In order to establish a claim of disparate treatment based on sex, a plaintiff must make out a prima facie case as set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973), and Texas Dep’t of Community Affairs v. Burdine, 450 U.S. 248, 252-53, 101 S.Ct. 1089, 67 L.Ed.2d 207 (1981); see also St. Mary’s Honor Center v. Hicks, 509 U.S. 502, 506, 113 S.Ct. 2742, 125 L.Ed.2d 407 (1993). Because plaintiff was never fired or denied a promotion, his prima facie ease is slightly different than the typical disparate treatment case. To meet his burden, plaintiff must demonstrate that: (1) he is a member of a protected class; (2) he was qualified for the job he performed; (3) he suffered an adverse employment action; and (4) the action occurred under circumstances giving rise to an inference of discrimination. “The burden of establishing a prima facie case ... is not onerous.” Fisher v. Vassar College, 114 F.3d 1332, 1335 (2d Cir.1997), cert. denied, — U.S. -, 118 S.Ct. 851, 139 L.Ed.2d 752 (1998) (quoting Burdine, 450 U.S. at 252-53, 101 S.Ct. 1089). “In fact, the plaintiffs burden of establishing a prima fa-cie case has been frequently described as ‘minimal.’” Fisher, 114 F.3d at 1335 (citations omitted). The plaintiffs prima facie case creates a presumption that the employer unlawfully discriminated against the employee, and the burden of production then shifts to the employer to articulate a legitimate, nondiscriminatory reason for the adverse employment action. St Mary’s, 509 U.S. at 506-07, 113 S.Ct. 2742. Although the burden of production shifts to the defendant at this point, “the ultimate burden of persuading the trier of fact that the defendant intentionally discriminated against the plaintiff remains at all times with the plaintiff.” Id. at 507, 113 S.Ct. 2742 (citation omitted). “Any legitimate, non-discriminatory reason will rebut the presumption triggered by the prima facie case. The defendant need not persuade the court that it was actually motivated by the proffered reasons.” Fisher, 114 F.3d at 1335-36 (citations omitted). Once the defendant satisfies this burden, the presumption of discrimination established by the prima facie case drops away and the trier of fact must proceed to the ultimate question: whether plaintiff has proven that defendant intentionally discriminated against him. St. Mary’s, 509 U.S. at 510-11, 113 S.Ct. 2742 (citations omitted). At this point, plaintiff must produce sufficient evidence to reasonably support a finding that he was harmed by the employer’s illegal discrimination. Fisher, 114 F.3d at 1337. a Title VII plaintiff may prevail only if an employer’s proffered reasons are shown to be a pretext for discrimination, either because the pretext finding itself points to discrimination or because other evidence in the record points in that direction' — or both. And the Supreme Court tells us that “a reason cannot be proved to be a ‘pretext for discrimination ’ unless it is shown both that the reason was false, and that discrimination was the real reason.” Id. at 1339 (quoting St. Mary’s, 509 U.S. at 515, 113 S.Ct. 2742) (emphasis in original). Although plaintiff has not explicitly addressed how his allegations create a prima facie claim of sex discrimination, his lengthy submissions do adequately allege that: (1) he is a member of a protected class (male employees); (2) he was qualified for the work he performed as a PTF clerk; (3) he suffered certain adverse employment actions; and (4) the Westfield P.O. management treated female PTF clerks of equal qualifications differently. Plaintiffs allegations concerning adverse employment actions due to sex discrimination can be consolidated into three general categories: the unequal distribution of work assignments, the unequal assignment of work hours, and the unequal use of disciplinary measures. A more detailed analysis of plaintiffs allegations concerning defendant’s sex discrimination follows below. A. Discriminatory Assignment of Mail Carrying Duties Plaintiff alleges that from June 1984 to on or about April 1, 1985, PM Kutschke and/or SPO Nagle allocated the outside relief carrier workload at the Westfield P.O. in such a way that plaintiff was required to perform all of the outside mail carrier relief duties (Item 109, ¶ 5 and at 21-22; Item 242, 1Í59). Furthermore, plaintiff alleges that PM Kutschke and/or SPO Nagle allocated outside relief carrier work in such a way that female PTF Howser did not perform relief carrier work (Id.). Plaintiff contends that PTF Howser performed tasks that were less physically strenuous than the relief carrier duties (Id.). Defendant argues that plaintiffs comparison of PTF Howser’s relief carrier duty with his own (Item 242, ¶ 59) is not persuasive because plaintiffs comparison covers merely half of the dates from only his second month at the Westfield P.O. (Item 249, at 49). Defendant argues that such a small sampling does not represent sufficient proof of discriminatory assignment of relief carrier duties (Id.). Defendant’s contention on this matter, however, does not rebut plaintiffs allegation. Rather, it merely attacks the sufficiency of plaintiffs proof on this point. Thus, defendant is really claiming that plaintiff has failed to make out a prima facie ease on this allegation. In viewing this issue in a light most favorable to plaintiff, the court reserves judgment on whether plaintiff has provided the court with a large enough sampling to support a reasonable inference of discriminatory job assignments. Defendant has offered several legitimate and nondiscriminatory reasons for the way in which mail carrier duties were assigned (See Item 234, ¶¶ 6, 25, Exh. J). However, many of defendant’s proffered reasons involve disputed facts and therefore cannot be resolved on a motion for summary judgment. However, defendant also contends that PTF How-ser’s versatility was the principal reason that there was any discrepancy between how often PTF Howser carried mail and how often plaintiff performed such work during plaintiffs first two months at the Westfield P.O. (Item 249, at 49-50). An employer may base an adverse employment action on the fact that one employee is more versatile than another. See Aungst v. Westinghouse Electric Corp., 937 F.2d 1216, 1221-22 (7th Cir. 1991) (acknowledging that employee versatility is a legitimate reason for taking adverse employment action). During the time period on which plaintiff has based his comparison of his duties with those of PTF Howser, PTF Howser had been trained as a “window clerk who had stamp accountability” (Item 249, at 49-50.). As a result, management often assigned PTF Howser jobs other than outside relief carrier work (Id.). Even when the court views these arguments in a light most favorable to plaintiff, plaintiff has failed to produce sufficient evidence to support a rational finding that defendant’s final proffered reason is mere pretext. Plaintiffs scant documentation regarding the assignment of relief carrier duties also does not support a rational finding that sex discrimination was more likely than not the reason for the discrepancy between his outside relief carrier duties and PTF Howser’s outside relief carrier duties. See Woroski v. Nashua, 31 F.3d 105, 109-10 (1994); Van Zant, 80 F.3d at 714 (plaintiff must produce sufficient evidence that defendant’s reasons are false and that sex discrimination was more likely than not the real reason). An employer may base an adverse employment action on the fact that one employee is more versatile than another. See Aungst, 937 F.2d at 1221-22. Defendant has proffered the legitimate reason that PTF Howser was more versatile as a postal employee and therefore was apt to work on various job duties (Item 249, at 49-50). Plaintiff has not addressed defendant’s position on this point. For that relevant time period, then, PTF Howser’s versatility appears to have been the reason for the discrepancy in assignment of outside relief carrier duties. B. Discriminatory Assignment of Strenuous Job Duties Plaintiff alleges that from June 1984 to April 1987, PM Kutschke and SPO Nagle required plaintiff to perform job duties which they did not require female PTFs Howser and Karlson to perform, or which they required PTFs Howser and Karlson to perform to a much lesser degree (Itém 109, ¶¶ 9, 10 and at 21, 23-24). These tasks included unloading mail trucks, dumping mail from sacks, stacking empty mail sacks, shoveling snow, and washing vehicles. Plaintiff alleges that these tasks were more “difficult, strenuous, dusty, dirty and or otherwise more undesirable” than those the women performed (Id. ¶ 10). Defendant argues that even if these claims are true, plaintiff failed to suffer any pecuniary harm (Item 232, at 36). A plaintiff alleging sex discrimination does not necessarily need to allege a pecuniary loss if the employer has materially altered the terms or conditions of the plaintiffs employment. See McCabe v. Sharrett, 12 F.3d 1558, 1564 (11th Cir.1994) (noting that assignment of duties involving “less responsibility and more menial tasks” may rise to the level of an adverse employment action); see also Monica v. New York City Off-Track Betting, 1995 WL 117879, at *3 (S.D.N.Y. Mar. 20, 1995), aff'd, 100 F.3d 941, 1996 WL 2061 (2d Cir.1996) (table). Allegations of inferior and less desirable work duties may constitute an adverse employment action. Thus, plaintiff has made out a prima facie case of discriminatory assignment of job duties. Defendant argues that plaintiff indicated on December 5,1984, that he no longer wanted to carry a mail route. Defendant contends that because of plaintiffs request, Westfield P.O.’s management assigned other, and perhaps less pleasant, work to plaintiff (Item 232, at 36-37). Plaintiff, however, denies that he ever requested to be taken off of outside relief carrier duty (Item 242, ¶ 26; Item 109, at 25). The dispute over whether plaintiff requested to be removed from carrier duty is a fact dispute; therefore, the court cannot grant defendant’s motion on this argument. Defendant also argues that management utilized plaintiff in the ways that it did because often “plaintiff could not be assigned to window duties because of his mistakes, [therefore] some less pleasant tasks would have been assigned to give him hours.” (Item 234, ¶ 33(y)). Defendant makes mention of the unsatisfactory nature of plaintiffs work performance throughout the record. (See e.g., Item 234, ¶¶ 25 and 33(e)). To prove plaintiffs poor work performance, defendant points to three letters of warning that plaintiff received within six months of starting work at the Westfield P.O. These three letters document plaintiffs errors in performing various tasks and his unacceptable attitude towards management (Item 234, Exh. D (letters of warning dated 8/9/84, 10/2/84, and 11/5/84)). Plaintiff contends that this rebuttal is pre-textual because PM Kutschke and SPO Na-gle meted out discipline in a sexually discriminatory way. As a result, according to plaintiff, defendant cannot rely on plaintiffs disciplinary record in order to justify adverse employment actions (such as the assignment of strenuous duties). In order for plaintiff to establish individual disparate treatment through comparative evidence, he must demonstrate that similarly situated employees who do not share plaintiffs protected characteristic were treated preferentially. See Shumway v. United Parcel Service, 118 F.3d 60, 63-64 (2d Cir. 1997). One court in this circuit has inferred a lack of discriminatory animus when the evidence demonstrates that employees in plaintiffs protected class were also treated better than plaintiff. See Davis v. Bowes, 1997 WL 655935, at *19 (S.D.N.Y. Oct.20, 1997), aff'd, 159 F.3d 1346 (table; text at Westlaw 1998 WL 477139 (2d Cir. July 22, 1998)) (finding that it weighed against female plaintiff that “defendants have pointed to instances where ... female [employees] with seniority comparable to plaintiffs have been promoted”). As in Davis, plaintiffs proof on this matter alleges that employees both inside and outside of his protected class were treated preferentially with respect to standards of discipline. In an effort to demonstrate pretext, plaintiff contends that “my [job] performance was no worse and in fact was better than many Post Office employees.” (Item 242, ¶ 61). In support of this position, plaintiff offers a detailed account of 122 incidents wherein other Westfield P.O. employees committed punishable work-related errors “for which no disciplinary action was taken.” (Id,.). However, plaintiff undermines his own argument on this point by stating that male employees committed 25 percent of the errors “for which no disciplinary action was taken.” Plaintiffs offer of proof on this allegation actually requires an inference that is adverse to his case. According to plaintiffs records, male postal employees (primarily Robert Testrake) committed errors with impunity on thirty-two separate occasions during a five and one half-year period (Id.). Even taken in a light most favorable to plaintiff, the proof on this point requires the conclusion that male PTFs were also able to avoid discipline when their job performance otherwise warranted it. (Id.; see also Item 249, at 22 (observing that plaintiff cannot claim that his gender caused him to receive unequal disciplinary attention “since men and women alike got off lightly.”)). Moreover, plaintiffs attempt to demonstrate pretext on this issue is also deficient in that he has failed to provide comparative data within the context of this allegation. Plaintiff ambiguously points out the ways in which his coworkers also made punishable mistakes, but fails to provide data that would allow the court to compare the ways in which PM Kutschke and SPO Nagle disciplined plaintiff with the ways in which they disciplined other postal employees. Defendant cites several cases from this circuit and others for support of the proposition that plaintiffs own insubordinate behavior constitutes a legitimate, nondiscriminatory reason for disparate treatment. In Olivares v. NASA, 934 F.Supp. 698, 703-04 (D.Md.1996), aff'd, 114 F.3d 1176, 1997 WL 288677 (4th Cir.1997) (table), the district court found that plaintiff, an employee who challenged his employer and supervisors over every aspect of his employment, could not defeat defendant’s motion for summary judgment by his mere conclusory allegations and opinions that the real motive for the adverse employment actions he experienced was his Mexican-American ethnicity. His contrariness and inability to get along with employers, supervisors, and co-workers fully qualified as legitimate, nondiscriminatory reasons for the adverse actions. In McCollum v. Bolger, 794 F.2d 602, 609-10 (11th Cir.1986), cert. denied, 479 U.S. 1034, 107 S.Ct. 883, 93 L.Ed.2d 836 (1987), another case involving USPS employees, the court found that the reason for the disparate treatment was not sex discrimination, but rather that plaintiff had a bad relationship with her supervisor, the Postmaster. Evidence that plaintiff disagreed with her superiors as to how her job should be performed and that she was “a combative, hostile, rude, vindictive and dictatorial employee” were the reasons for the adverse employment actions about which she complained. Id. at 610. The Eleventh Circuit explained that “Title VII prohibits discrimination; it ‘is not a shield against harsh treatment at the work place.’ Personal animosity is not the equivalent of sex discrimination and is not proscribed by Title VII. The plaintiff cannot turn a personal feud into a sex discrimination case by accusation.” Id. (internal citations omitted). Finally, in Meiri v. Bacon, 759 F.2d 989, 997 (2d Cir.), cert. denied, 474 U.S. 829, 106 S.Ct. 91, 88 L.Ed.2d 74 (1985), the Second Circuit found that defendant’s evidence of plaintiffs disregard for the legitimate authority of her superiors provided a legitimate, nondiscriminatory reason for her dismissal. Defendant contends that PM Kutschke’s own personal animosity toward plaintiff is a legitimate and nondiscriminatory reason for the adverse employment action. PM Kutsch-ke has testified that within months of having hired plaintiff, he dealt with “personal attacks” from plaintiff and what he perceived to be a “father and son team of antagonists” that succeeded in putting PM Kutschke “on the defensive.” (Item 234, ¶¶ 12, 18). Plaintiff has responded to this by averring that he was never “insubordinate to the SPO, the Postmaster, and/or to any other authority.” (Item 109, at 30). Plaintiffs insistence to the contrary, however, cannot alter the fact that PM Kutschke found plaintiffs conduct and attitude towards management to be offensive and “vituperative” (Item 234, ¶ 13). This court finds that plaintiff has not produced sufficient evidence to support a rational finding that defendant’s proffered reasons for its allegedly discriminatory distribution of job duties are false. Plaintiff has also failed to produce sufficient evidence to support a rational finding that sex discrimination was more likely than not the reason that he worked certain job details more than other female PTFs. Instead, defendant has clearly demonstrated that plaintiffs poor job performance and poor relationship with manage-, ment were the actual and legitimate reasons for the adverse employment action. C. Discriminatory Preference for Female Workers Plaintiff alleges that starting in June 1984, EM Kutschke sexually discriminated against plaintiff by treating the female PTFs preferentially. Specifically, plaintiff alleges that PM Kutschke often assisted female PTFs in their assigned tasks, but failed to give plaintiff the same assistance (Item 109, ¶ 11 and at 21, 24). Certain employment actions are so trivial or inconsequential that they cannot rise to the level of an" adverse employment action. See Harlston v. McDonnell Douglas Corp., 37 F.3d 379, 382 (8th Cir.1994) (plaintiff was not adversely affected by a reassignment that involved a change in - duties because such disruptions were “mere inconvenience”). Defendant concedes that on isolated occasions, PM Kutschke and SPO Na-gle assisted PTFs Karlson and Howser with certain tasks, such as lifting sacks of mail onto a counter top (Item 249, at 18-19). Defendant argues that plaintiff has failed to' make out a prima facie case on this claim because the female PTFs received this assistance only occasionally. Defendant maintains that this assistance was periodically necessary for the' completion of an isolated task; and was not rooted in a discriminatory favoring of women (Id.). Even accepting plaintiffs allegations as true, plaintiff has failed to allege an adverse employment action. In light of Harlston, the fact that management did not occasionally assist plaintiff with lifting -mail sacks onto counter tops does not demonstrate that plaintiff has suffered-an adverse employment action. This type of employment action represents the kind of de minimis matter that does not constitute an adverse employment action under Title VII. See Shabat v. Blue Cross Blue Shield of the Rochester Area, 925 F.Supp. 977, 989 (W.D.N.Y.1996), aff'd, 108 F.3d 1370, 1997 WL 138836 (2d Cir.1997) (table); Harlston, 37 F.3d at 382. Even if the court were to find that plaintiff has made out a prima facie case-with respect to this allegation, an employer’s decision to deny an employment benefit to an employee does not violate Title VII when that decision is motivated by. personal animosity. See McCollum, 794 F.2d at 609-10 (holding that supervisor’s personal animosity for employee is a legitimate and nondiscriminatory reason for adverse employment action). Furthermore, an employer’s decision to extend.employment benefits to certain employees does not violate Title VII when that decision is made on the basis of personal favoritism. See Benzies v. Illinois Dept. of Mental Health, 810 F.2d 146, 148 (7th Cir.), cert. denied, 483 U.S. 1006,107 S.Ct. 3231, 97 L.Ed.2d 737 (1987). To this effect, defendant asserts that if EM Kutschke and SPO Nagle avoided interacting with or assisting plaintiff; such choices were rooted in PM Kutschke and SPO Nagle’s personal animosity for plaintiff (Item 249, at 48). Defendant argues that any favoritism shown by PM Kutschke to female employees was a product of plaintiffs “caustic correspondence and insubordinate speech .... [N]o doubt Postmaster Kutschke and SPO Nagle preferred the company of anyone but plaintiff.” (Item 249, at 48). More precisely, defendant maintains that if PM Kutschke and SPO Nagle interacted with and. assisted PTFs Howser and Karlson more often than they did with plaintiff, that was because they preferred those employees as workplace company (Id.).. To the extent that plaintiff ambiguously alleges that PM Kutschke favored PTF How-ser because of their alleged intimate relationship outside work (ítem 242, ¶¶ 54-56; Item 109, at 24), defendant relies on DeCintio v. Westchester County Medical Center, 807 F.2d 304 (2d Cir.1986), cert. denied, 484 U.S. 825, 108 S.Ct. 89, 98 L.Ed.2d 50 (1987), wherein the Second Circuit ruled that “favoring a ‘paramour’ is not sex discrimination under Title VII” (Item 249, at 48). In sum, defendant concedes that certain PTFs received occasional extra assistance from PM Kutschke and SPO Nagle because of their physical limitations, not because of their sex. The court finds that plaintiff has failed to make out a prima facie case of discrimination on this claim. Even if plaintiff had satisfied his prima facie burden, defendant has demonstrated that management assisted and socialized with certain PTFs because they preferred the company of those workers over plaintiff. Plaintiff has failed to offer evidence that is sufficient to support a rational finding that defendant’s proffered explanation is false and has also failed to show that sex discrimination more likely than not motivated management to assist and to keep company with female PTFs. Rather, defendant has shown that management preferred certain workers as workplace company, and that this was more likely than not the reason for the allegedly adverse employment action. D. Discriminatory Training for Male and Female Employees Plaintiff also claims that female PTFs received different and superior post-hiring employment training. Plaintiff alleges that PTF Karlson received more training in work duties such as window duty, carrier route training, and casing (Item 109, ¶ 12 and at 21, 24-25; Item 242, ¶¶ 8-17). More precisely, plaintiff claims that management consistently misrepresented and falsely recorded the hours for his training sessions (Item 242, ¶¶ 8-17). For example, plaintiff points to the “numerous discrepancies between [my] training records and my time cards” (Id. ¶ 10). In this way, plaintiff alleges that management cheated him out of training hours by making it appear as though he had trained the requisite number of hours, when in fact he had not trained for the number of hours indicated on his records (Id. ¶¶ 10,18). Defendant argues in rebuttal that management trained plaintiff, as a transfer employee from the Jamestown P.O., not as a new hire. As such, defendant contends that plaintiff did not require a new regimen of training and that the Westfield P.O. training, though complete, should have functioned merely as a “refresher course” (Item 249, at 27). Defendant also states that it was and is common practice for post offices to record employee training “by the length of the training module and not according to the time clock” (Item 249, at 27-28). Defendant further maintains that plaintiffs on-the-job training remedied any discrepancies between the actual length of training sessions and management’s method for recording the time of training sessions. Defendant points out that plaintiff received much of hiS' training, as many as 120 hours, in the form of on-the-job training (Item 242, Exh. A (dated 6/24/86)). Plaintiff has undermined his own contentions on this issue by stating, through his representative (Joseph Neratko), that “I wish to emphasize the fact that both of these PTFs [both plaintiff arid an unnamed female PTF] in question, were trained in identical functions.” (Item 101, Exh. 8 (emphasis in original)). In another letter, plaintiffs representative stated “Robert E. Neratko, is a Postal Service employee, male ... trained in all functions and phases of the Westfield P.O. work” (Id., Exh. 7). These inconsistencies bring to light that plaintiff is arguing at cross-purposes with himself. That is to say, either plaintiff was adequately trained for all positions and therefore suffered an adverse employment action when management refused to assign him less strenuous jobs, or he was inadequately trained for some positions and therefore suffered no adverse employment action when management refused to assign him certain less strenuous tasks (Item 249, at 50 n. 19 (defendant’s argument on this point)). In addition to plaintiffs contradictory statements, plaintiff has also failed to provide the court with comparative evidence that demonstrates how management recorded the hours of his training sessions differently from the way management recorded the training sessions of female employees. Plaintiff has not produced sufficient evidence to support a rational finding that defendant’s proffered reasons for the allegedly fewer training hours and opportunities are false. Nor has plaintiff produced evidence sufficient to support a rational finding that sex discrimination was- more likely than not the reason that management recorded his training hours in the way that it did. Instead, defendant has shown that-management recorded plaintiffs training hours in' the same way that it recorded other employees’ training hours. Thus, any alleged deficiencies in training that would result from this recording method would affect male and female employees alike. Plaintiff has not offered any evidence to rebut this inference. E. Discriminatory Allocation of Hours Plaintiff alleges that from February 15, 1985, until April 1987, PM Kutschke and SPO Nagle sexually discriminated' against plaintiff by assigning female PTFs Howser and Karlson more work hours than they assigned plaintiff, and by declining to give plaintiff assignments for carrier and/or window duties despite plaintiffs willingness and continued requests to take on such assignments (Item 109j ¶ 14 and at 21, 25-26; Item 242, ¶¶ 29-43). Defendant points out that there is no evidence of a sexually discriminatory allocation of work hours even when evaluated in light of Patty Koenig’s submission concerning a comparative compilation of hours (See Item 243 (Ms. Koenig prepared this submission on plaintiffs behalf)). As noted earlier, in order for plaintiff-to establish individual disparate treatment-through comparative evidence, plaintiff must demonstrate that similarly situated employ-fees outside of plaintiffs protected class were treated preferentially. See Shumway, 118 F.3d at 63-64. One court in this circuit has inferred a lack of - discriminatory animus when the evidence ■ demonstrates that employees in plaintiffs protected class were also treated better than plaintiff. See Davis, 1997 WL 655935, at *19. Plaintiffs proof on this matter alleges that employees both inside and outside of his protected class were treated preferentially with respect to how many potential work hours they received. According to Ms. Koenig’s" documentation, Robert Testrake was= hired as a PTF in June 1986 and worked 893.7 hours in 1986. If PTF Testrake had worked a proportionate amount of hours for all of 1986, he would have worked approximately 1659 hours. Furthermore, PTF Testrake worked 1651.6 hours in 1987 and then worked 1599.95 hours in 1988 (Item 243, ■ at 26-31). Defendant notes that PTF Testrake’s average work hours as a male were nearly identical to the female PTFs’ work hours in their best years and higher than the female PTFs’ hours in their lowest years (Item 249, at 11). This argument is borne out by an examination of the relevant figures (Item 243, at 5-12 (regarding PTF Howser), at 13-17 (regarding PTF Karlson); Item 249, at 10-11). Defendant’s comparison bf PTF Testrake’s average work hours with those of female PTFs does not represent a legitimate nondiscriminatory reason for the adverse employment action;’ instead, this argument attacks plaintiffs attempt to make out a prima facie case on this claim. Specifically, that PTF Testrake’s work hours were equal to or superior to those of the female PTFs undermines plaintiffs contention that management limited plaintiffs work hours because of discriminatory animus. Presumably, if management shorted plaintiff hours because he was male, then management would have subjected Mr. Testrake to the same kind, of discrimination. Even if the- court were to find that plaintiff has carried his prima facie burden,' plaintiffs claim still fails’ to survive summary judgment. Defendant chálléhges the merits of the immediate claim by relying on Jones v. J.C. Penney Co., Inc., 889 F.Supp. 432, 440 (D.Kan.1995), where the court held that the actions of a part-time flexible employee who had advised her employer that she'would work only on certain days -and times, consequently allowing other part-time flexible employees to receive niore hours', resulted in her reduced working time. J‘one’s is directly on point with the present case. In Jones, the court explained that"’“[e]ven if a prima faéie case has been established, it has been' sufficiently rebutted in that the defendant has" clearly articulated legitimate, nondiserimina-tory reasons for its decisions ... [including] that plaintiffs ¡self-proscribed limitations, on her availability resulted in hqr. yedueed working time,” Id. .. Defendant asserts that plaintiff inevitably received fewer hours for PTF assignments because of his commitment to the military reserves and his use of sick leave and annual leave. As for plaintiffs military leave, management could not schedule plaintiff for twelve weekends a year, as well- as for two weeks in the summer. This commitment reduced plaintiff’s availability by a full month (Item 232, at 53-54; Item 233, ¶ 14 (Fike’s testimony)). Defendant asserts, without rebuttal, that Saturdays are a time slot when the USPS commonly calls upon its PTFs. The fact that plaintiff was unavailable for twelve Saturdays a year would have more likely than not caused him to receive fewer hours. In 1985, plaintiff took just under seventy hours of military leave, 112 hours of annual leave, a “full day leave without pay”, and six hours of sick leave. For that same year, PTF Howser took no military leave, 114 hours of annual leave, and no sick leave hours, and PTF Karlson took no military leave, eight hours of annual leave, and no sick leave (Item 243, at 5-25). Thus, in 1985, plaintiff was available for seventy-four fewer hours than PTF Howser (or 12.3 six-hour work days) and 180 fewer hours than PTF Karlson (or 30 six-hour work days). According to plaintiff, his unavailability was roughly equivalent to PTF Howser’s unavailability in both 1986 and 1987 (Item 243, at 8-12, 20-23). Defendant concedes that management would choose to schedule PTF Howser on the basis of legitimate reasons when there was a choice between scheduling PTF Howser and plaintiff (Item 249, at 49-50), Defendant states that management maintained this preference for scheduling PTF Howser because PTF Howser was more versatile and was the only certified 2Q4b supervisor in the Westfield P,0. (Id. at 35). Furthermore, management had greater confidence in PTF Howser’s skills and competency (Id. at 49-50). Defendant admits that management generally preferred to have PTF Howser at the office because she was a more pleasant coworker than plaintiff (Id. at 14-15, 48). Irrespective of plaintiffs thin proof on this claim, defendant has demonstrated that plaintiff would have received fewer hours than other PTFs because he was periodically unavailable, had a poor work performance record, and did not get along personally with management. Plaintiff has not produced sufficient evidence to support a rational finding that defendant’s proffered reasons for the adverse employment action are false. Nor has plaintiff produced sufficient evidence to support a rational finding that sex discrimination was more likely than not the reason that management allocated him fewer hours than female PTFs. Instead, defendant has demonstrated that management allocated the available PTF hours in the way that it did because of plaintiffs unavailability, poor work record, and poor personal relationship with management. F. Discriminatory Scheduling Plaintiff alleges that PM Kutschke and SPO Nagle created more favorable working' conditions for female employees than for plaintiff. Specifically, plaintiff alleges that PTF Howser did not work on holidays and often did not have to work during the afternoons, while plaintiff never received such accommodations because he is male (Item 109, ¶ 16 and at 21, 26-27). As the court has already noted, plaintiff must allege an adverse employment action in order to make out a prima facie case of employment discrimination under Title VII. Fisher, 114 F.3d at 1335. However, plaintiff may fail to make out a prima facie case of discrimination if he alleges employment actions that are too trivial or inconsequential to rise to the level of “adverse” employment actions. See Shabat, 925 F.Supp. at 989; Harlston, 37 F.3d at 382; Hicks v. Brown, 929 F.Supp. 1184 (E.D.Ark.1996) (concerning allegations too trivial and inconsequential to rise to adverse employment action). Lower courts have expressed growing doubt as to whether mere scheduling inconveniences constitute adverse employment actions. See Moss v. Advance Circuits, Inc., 981 F.Supp. 1239, 1246 (D.Minn.1997) (scheduling inconveniences do not rise to discriminatory adverse employment action); Victor v. Runyon, 1997 WL 461562, at *2 (E.D.Pa. July 31, 1997), aff'd, 151 F.3d 1027 (3rd Cir.1998) (table) (new work schedule that is merely inconvenient does not rise to discriminatory adverse employment action); Reilly v. Metro-North Commuter R.R. Co., 1996 WL 665620, at *13 (S.D.N.Y. Nov.15,1996) (questioning whether undesirable sch