In Federal Express Corp. v. Holowecki, the United States Supreme Court determined that any document which can reasonably be construed as a request for action and appropriate relief on the employee's behalf – including a completed EEOC intake questionnaire form accompanied by a 6-page affidavit – can constitute a "charge" under the Age Discrimination in Employment Act ("ADEA"), even though the EEOC did not notify the employer or conduct an investigation or conciliation. The Court held that a statement in the affidavit which asked the EEOC to "[p]lease force Federal Express to end their age discrimination plan" satisfied the requirement of a request for action, and the filing of the intake questionnaire established that the plaintiff had exhausted her administrative remedies (a prerequisite to filing suit in court).