Footnote 239

Such blunderbuss charges occasionally appear in reported cases. See, e.g., Ray v. Trans States Airlines, Inc., No. 4:01-CV-93 (CEJ), 2002 U.S. Dist. LEXIS 22658 (E.D. Mo. Oct. 10, 2002) (granting summary judgment to employer where employee alleged harassment based on race, religion, gender, national origin, and color). For a federal judge's reaction to complaints like these, see Michael Bologna, Judges Warn Employment Lawyers Against Motions for Dismissal, Summary Judgment, 19 Empl. Discrim. Rep. (BNA) 595 (Dec. 4, 2002) (quoting Judge Ruben Castillo, federal district court judge in the N.D. Ill., who criticized plaintiffs' lawyers "for filing wide-ranging claims alleging discrimination on multiple levels--a strategy akin to 'throwing a plate of spaghetti at the wall to see what sticks."').