a course of treatment and act on the patient’s response to the recommendation free from the possibility that someone other than the patient might complain in the future.” 10 As one commentator — in discussing third-party professional malpractice claims turning on the foreseeability of such injuries to nonpatients — has put it, “[t]he numbers of potential cases boggle the mind.” Cynthia Grant Bowman, The Manipulation of Legal Remedies to Deter Suits by Survivors of Childhood Sexual Abuse, 92 NW U L Rev 1481, 1488 (1998). The number seems only slightly less mind-boggling when the standard is knowledge of a substantial certainty rather than foreseeability. 11 See, e.g., OEC 504 (evidentiary privilege). See generally Jaffee v. Redmond, 518 US 1, 12-13, 116 S Ct 1923, 135 L Ed 2d 337 (1996) (<HOLDING>); State v. Miller, 300 Or 203, 209, 709 P2d 225
recognizing medical records contain the same protected confidential information as a physicians direct testimony about the communications recognizing privilege recognizing qualified privilege for confidential presidential communications recognizing application of federal deliberative process privilege to internal state communications recognizing federal privilege for confidential therapistpatient communications based in part on the fact that the relationship is protected in all 50 states and the district of columbia