The following excerpt is from Missirlian v. Huntington Memorial Hosp., 662 F.2d 546 (9th Cir. 1981):
6 Because we focus on the elements of notice, we do not hold that the right-to-sue letter is the only possible form of adequate notice. For this reason, and because courts have the power to bar Title VII actions if the aggrieved party delays unnecessarily, Boone v. Mechanical Specialties Co., 609 F.2d 956, 958-59 (9th Cir. 1979), the hospital's fear that a plaintiff could extend the ninety-day period indefinitely by refusing to request a right-to-sue letter is groundless.
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