Roush

I. Background

A. The Assault Investigation In 2010, Jennifer Roush began working as a career services advisor at the Visalia, California campus of San Joaquin Valley College. (Docket Entry No. 35-4 at 98). In 2019, Roush’s ex-boyfriend, Richard Ramirez, assaulted Roush in her office at the College. (Docket Entry No. 45-3 at 165). At least three of Roush’s co-workers witnessed Ramirez come onto campus and enter Roush’s office the day of the assault: Timberly Ferris, Bianca Leal, and Stacey Elenes. (Id. at 43–44). In 2019, the Tulare County District Attorney’s Office began investigating Ramirez in

connection with the assault. (Docket Entry No. 45-5 at 18). The D.A.’s Office informed Roush that: (1) some of her co-workers would be subpoenaed in March 2020 to testify about the assault before a grand jury, (Docket Entry No. 45-3 at 31); (2) the co-workers could choose when and where they wanted to be served with the subpoenas, (id. at 31, 45); and (3) the grand jury proceeding was “highly confidential” and should not be discussed “with anybody,” (id. at 79). Roush informed two of her supervisors that College employees would be served with subpoenas and would have to miss…