Assembly. First, the statute leaves unclear whether, in a civil action, it protects against all compelled disclosure, regardless of its form, or whether it protects only against compelled testimonial disclosure. Second, the statute inexplicably grants the privilege exclusively to the clergy, regardless of whether the communicant consents to disclosure. See supra note 5. Third, the statute does not address whether the privi-Iege extends to counseling services provided by clergy, for a fee, in cases in which those counseling services differ from secular counseling only by their emphasis on "spiritual” issues, rather than psychopathological issues. Cf. Va. Code Ann. § 8.01-400.2 (Michie 1992) (psychologist-client privilege); Commonwealth v. Cronin, 2 Va.Cir.Ct. 488, 503 (Rich.1855) (<HOLDING>). 8 . As for Food Lion’s argument that
holding that names and address of private individuals appearing in files within the ambit of exemption 7c  are exempt from disclosure holding that the catholic church was not within a parishioners household holding that the government must provide the party seeking disclosure with a detailed index describing the documents the government claims are exempt from disclosure under foia holding that roman catholic priest was exempt from testifying as to what was confessed to him and expressing concern that compelled disclosure would deter individuals from seeking spiritual aid holding that where an authorized disclosure is voluntarily made to a nonfederal party whether or not that disclosure is denominated confidential the government waives any claim that the information is exempt from disclosure under the deliberative process privilege