ROSEMARY M. COLLYER, United States District Judge
Najmah Rashad, a legal secretary at the Washington Metropolitan Area Transit Authority, requested accommodation to attend religious services on Friday afternoons. WMATA initially offered Ms. Rashad different accommodations than she requested, but it was ultimately able to accommodate her fully. Although it agreed to Ms. Rashad’s final proposal, WMATA stated more than once that the accommodation was granted despite being a burden on the Office of General Counsel and contrary to normal policy. Ms. Rashad filed a charge of discrimination and retaliation because of this message. She filed this lawsuit in June 2012, after completing the administrative process. In August 2012, WMATA terminated Ms. Rashad, and she added a claim of retaliatory discharge to her complaint.
WMATA has moved to dismiss, arguing that Ms. Rashad failed to state a claim in either count of her amended complaint. After her time for filing a second charge passed, WMATA filed a supplemental motion to dismiss, arguing that Ms. Rashad had failed to exhaust her administrative remedies before filing suit on Count II. Both parties have added exhibits to their briefs in addition to those mentioned in the Amended Complaint and, at oral argument, had no genuine dispute as to the relevant facts but disputed their legal significance. The Court will accordingly treat the motion as one for summary judgment. See Fed. R. Civ. P. 12(d).
Najmah Rashad is a resident of Maryland and a citizen of the United States. From January 2008 until August 2012, Ms. Rashad worked as a legal secretary in WMATA’s Office of the General Counsel (OGC). Ms. Rashad is of the Muslim faith. In December 2010, Ms. Rashad began working an Alternative Work Schedule (AWS), which gave her one day off every two weeks. She was assigned an AWS day off on alternate Tuesdays.
Wanting to attend the Muslim Jummah Prayer Service every Friday, on December 30, 2010, Ms. Rashad asked that her AWS day be changed from Tuesdays to Fridays. Susan Serrian, Manager of Legal Administrative Services, OGC, denied this request on January 12, 2011. See Def. Mot. [Dkt. 12], Ex. 1 [Dkt. 12-3] (1/12/11 Email from Serrian to Rashad). Ms. Serrian explained OGC’s policy that limited the number of administrative employees allowed off on any given day in order to assure coverage to the Office attorneys. She further explained that Fridays were already assigned to other members of the administrative staff and therefore no additional person could take Friday as an AWS day without compromising the work of the Office, which was understaffed. She also noted that two members of the administrative staff were experiencing medical problems which required recurrent absences, making it even more difficult to ensure secretarial coverage. Ms. Serrian reminded Ms. Rashad of Ms. Serrian’s recent memo to all staff about the difficulties of coverage under the circumstances and “indicating AWS privileges may be suspended in the near future for a period of time due to these medical situations.” Id. In the alternative, Ms. Serrian offered to permit Ms. Rashad to use annual leave if she needed a longer-than-scheduled lunch hour to attend Friday Jummah services and suggested that she could ask a colleague to switch AWS days. She also advised that Ms. Rashad could make a formal Request for Religious Accommodation under WMATA policy. Id.
Ms. Rashad adopted the last piece of advice and filed a Request for Religious Accommodation, asking for a permanent accommodation for “Jummah attendance on Fridays beginning Friday January 28, 2011. 7:00 am start time. Leave at 12:30. Use my personal leave.” Def. Mot., Ex. 2 [Dkt. 12-4] (Request for Religious Accommodation). Asked by Ms. Serrian for clarification, Ms. Rashad explained, “I am requesting to change my work hours on Friday to a start time of 7:00 a.m. and a departure time of 12:30 p.m., utilizing annual leave for the rest of the day.” Def. Mot., Ex. 3 [Dkt. 12-5] (1/21/11 Email from Rashad to Serrian). Thereafter, a lengthy memo from OGC to the WMATA Religious Accommodation Panel explained:
Ms. Rashad is requesting that she be allowed to utilize annual leave every Friday from 12:30 p.m. to the end of her work day so that she can attend the Jumu’ah congregational prayer. . . .
Ms. Rashad is a Legal Secretary and has been employed in COUN since January 27, 2008. She is responsible for providing litigation and other legal support to 5 COUN attorneys. COUN has four legal secretaries to support 22 attorneys. Currently, one of the secretaries is suffering from a serious medical condition which requires him to be absent 3-5 days per pay period, essentially making him a part-time employee. . . . In addition, COUN’s Office Manager is also on extended sick leave which is scheduled to last between 8 weeks and five months . . . . Making the situation more complicated is the fact that Ms. Rashad supports all three of COUN’s workers’ compensation attorneys [who] . . . typically handle a combined caseload of 300 cases. . . . Ms. Rashad is also responsible for supporting a civil litigation attorney and a general law attorney.
In her request for religious accommodation, Ms. Rashad indicates that she is willing to arrive at 7:00 a.m., leave at 12:30 p.m., and take “personal” leave every Friday so that she can attend Jumu’ah. COUN has serious doubts that Ms. Rashad will arrive at 7:00 a.m. and also questions her ability to accrue the annual leave necessary  for her every Friday absence. Within her first year of employment, Ms. Rashad established a pattern of taking unscheduled leave and regularly arriving late to work. This pattern has continued throughout . . . [She has been counseled and suspended from her prior AWS schedule as a result. And when she asked to begin work at 7:00 a.m., she was consistently late.] Given her past record of late arrivals, it is not reasonable to believe that Ms. Rashad can consistently arrive for work at 7:00 a.m. or that she can accrue the necessary annual leave to cover her proposed Friday absences.
Def. Mot., Ex. 5 [Dkt. 12-7] (1/25/11 Memo from COUN to WMATA Religious Accommodation Panel (misdated 2010)).
By letter dated March 14, 2011, the Religious Accommodation Panel denied Ms. Rashad’s specific request because of its impact on OGC’s business operations and suggested alternatives. See Def. Mot., Ex. 6 [Dkt. 12-8] (3/14/11 Letter from Quillen to Rashad). Pursuant to WMATA policy, the Panel had first invited Ms. Rashad to meet with the Panel to discuss her specific request, provide additional information, and discuss whether other accommodations were feasible. However, Ms. Rashad had arrived with legal counsel and “declined to attend the meeting unless he was also allowed to participate.” Id. at 1. The Panel had explained to Ms. Rashad and her lawyer that it offered “an internal, interactive and non-adversarial process, and third parties are not allowed to participate.” Id. at 1-2. In lieu of Ms. Rashad’s in-person discussion with the Panel, the Panel offered to submit written questions “to allow [Ms. Rashad] to clarify [her] request and in a further attempt to better understand the nature and scope of [her] request.” Id. Ms. Rashad agreed to this course of action. The Panel explained to Ms. Rashad, in the presence of her attorney, that the Panel was seeking her “personal responses.” Id. at 2. Instead, however, Ms. Rashad’s counsel sent the Panel an email that was “both substantively and procedurally unacceptable” and replete with legal argument. Id. at 2. On March 4, 2011, the Panel forwarded its questions directly to Ms. Rashad and set a deadline for response. Id. Her response was four days late and did not answer the questions but did offer two variations on her requested accommodation: to use leave without pay (“LWOP”), not personal leave, to cover Friday absences; or to come in earlier and/or work later. After considering these proposals, the Panel determined that:
[T]he requested accommodation would constitute an undue hardship for [WMATA] to the extent that it would create a shortage among qualified staff employees within the Office of General Counsel each Friday afternoon and would therefore require [WMATA] to incur more than de minimus costs. This is the case regardless of whether [Ms. Rashad] attempted to cover the absences by working additional hours outside of [her] regular shift (on Friday and/or on other days of the week), by using annual leave, or by some combination of these two approaches.
Id. The Panel offered two alternatives. First, it suggested that Ms. Rashad use up to two hours of annual leave each Friday, from 1:30 to 3:30 p.m., in addition to her lunch hour starting at 12:30, to attend Jummah prayers. Second, it suggested that she might report one half-hour early, at 8:00 a.m. each Friday, take leave from 12:30 to 3:30, and return to work until 5:30 p.m., one half-hour later than normal, which would reduce the amount of annual leave needed to cover her time off. Finally, the Panel advised that Ms. Rashad could appeal to, or file a complaint of religious discrimination with, the Director of the Office of Civil Rights. Id.
Before Ms. Rashad filed an appeal or complaint, OGC hired an additional legal secretary. On March 18, 2011, Ms. Serrian informed Ms. Rashad of the new hire and told her that AWS leave would be reinstated—it had been suspended due to understaffing—effective April 11, 2011. As a result, Ms. Serrian advised that
COUN will approve an AWS schedule which allows you to take the first Friday of each pay period off so that you can attend Jumu ’ah. On alternative Fridays, you will be allowed to leave at 12:30, as per your prior request, and utilize appropriate leave for the period of time ...