The following excerpt is from Washington v. Honeywell, Inc., 94 F.3d 654 (9th Cir. 1996):
While Washington's administrative complaint challenged only events on and after December 13, 1991, his legal complaint offers evidence of earlier events. For substantially the same reasons that events otherwise barred by the statute of limitations are admissible, the doctrine of administrative exhaustion does not prevent Washington from submitting evidence of the earlier events in support of his administratively exhausted claims. There need only be a "fit" between the administrative and legal complaints. Ong v. Cleland, 642 F.2d 316, 318 (9th Cir.1981); see also Green, 883 F.2d at 1476.
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