In Ellis v. U.S. Security Associates, 169 Cal. Rptr. 3d 752 (Cal. Ct. App. 2014) (No. A136028), plaintiff filed a sexual discrimination and harassment claim against her former employer under the California Fair Employment and Housing Act.  The trial court dismissed the claim as untimely, finding that plaintiff had signed an application for employment in which she agreed that any claim or lawsuit must be filed no more than six months after the alleged action, and further agreed that she was waiving any statute of limitations to the contrary.  A California court of appeals reversed, holding that the limitations provision in plaintiff’s employment application was unenforceable because it was unreasonable and against public policy.  The court reasoned that although parties generally can contract to shorten applicable limitations periods, such agreements are only reasonable if the contractually shortened periods still provide a party sufficient time to investigate and effectively pursue a judicial remedy.  Here, the court found that six months was too short, in part because it might not provide plaintiff sufficient time to exhaust her administrative remedies, and therefore, was unreasonable and against public policy.