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Privilege Waiver by: Disclosure to Therapist; and, in Rule 30(b)(6) Deposition Preparation

E-Discovery LLC

First , where the plaintiff designated her therapist as an expert witness on emotional distress damages, her disclosure of privileged attorney-client communications in otherwise privileged therapy sessions waived the privileges. Privileges may be “stacked.” 5, 2024)(Coulson, J.), at *2 (emphasis added).