Cas. Ins. Co. v. Johnson, 207 Mont. 409, 673 P.2d 1277, 1280-81 (1984) (giving a criminal conviction preclusive effect against a third party because the third party’s rights derived from the convicted insured’s insurance and because of an identity of interest at the time of the criminal trial); New Jersey Manufacturers Ins. Co. v. Brower, 161 N.J.Super. 293, 391 A.2d 923, 926 (App.Div.1978) (finding privity in part because the victim “stood in the shoes” of the insured for the purposes of recovering proceeds); In the Matter of Nassau Ins. Co., 78 N.Y.2d 888, 573 N.Y.S.2d 447, 577 N.E.2d 1039, 1040 (1991) (following D’Arata’s holding that criminal convictions bar third parties from claiming insurance proceeds); State Farm Fire & Cas. Co. v. Reuter, 299 Or. 155, 700 P.2d 236, 241 (1985) (<HOLDING>). Decisions to the contrary are both less
holding victim waived physicianpatient privilege by authorizing her doctor to release her medical records to the department of criminal investigation because the information contained in her medical records was no longer confidential between herself and her physician holding that the thirteenyearold victims twomonth delay in reporting her rape is explained by and completely consistent with the all too common circumstances surrounding sexual assault on minors  fear of disbelief by others and threat of further harm from the assailant holding evidence of sexual assault relevant to show defendants motive in kidnapping victim holding that the victim of a sexual assault was in privity with her assailant because of her status as a claimant and potential judgment creditor of the convicted insured holding that against her will in the rape statute means without her consent and that the fact that the victim was under the age of consent was sufficient to establish that element