the discharge itself may become stigmatizing in the public eye.” Kramer v. S. Oregon Unix., No. 1:13-cv-00340-PA, 2014 WL 6810767, at *7 (D.Or. Dec. 1, 2014) (quoting Campanelli v. Bockrath, 100 F.3d 1476, 1482 (9th Cir.1996)). The statement and the discharge must share “some temporal nexus” to be considered “closely related.” Id. (citing Campanelli, 100 F.3d at 1483; Tibbetts v. Kulongoski, 567 F.3d 529, 537 (9th Cir.2009)). The performance evaluation occurred in May of 2009, more than two years before Hoy resigned from the YCSO in June of 2011. Although there is no bright-line rule for analyzing the temporal nexus, two events approximately twenty-five months apart are not sufficiently connected in time to create a nexus under Campanelli and its progeny. See Tibbetts, 567 F.3d at 538 (<HOLDING>). Moreover, Hoy’s resignation was based on the
holding that no federal nexus is required holding positive press release was not actionable where plaintiffs have not alleged that any of the historical representations in that press release were false holding that a nexus between the corporate officers or directors official activity and the matter for which indemnification is sought must be shown though no more than a nexus whether a nexus exists is a question of fact to be determined by the trial court considering all the circumstances surrounding the proposed indemnification holding that press release issued by acting director of office of rent stabilization regarding employee termination was within scope of directors official duties and absolutely privileged holding that a sixteenmonth span between termination and a press release which publicized the stigmatizing statement at issue severed the temporal nexus