same. Clients, in this case Presidents of the United States, will avoid confiding in their lawyers because they can never know whether the information they share, no matter how innocent, might some day become “pertinent to possible criminal violations,” id. at 368. Rarely will White House counsel possess cold, hard facts about presidential wrongdoing that would create a strong public interest in disclosure, yet the very possibility that the confidence will be breached will chill communications. See Swidler, at-- -, 118 S.Ct. at 2086-87. As a result, Presidents may well shift their trust on all but the most routine legal matters from White House counsel, who undertake to serve the Presidency, to private counsel who represent its occupant. Unlike Jaffee, 518 U.S. at 10-11, 116 S.Ct. 1923 (<HOLDING>), and In re Sealed Case, 148 F.3d 1073, 1078-79
recognizing a federal psychotherapy privilege recognizing privilege recognizing a federal mediation privilege recognizing privilege under federal rules recognizing federal common law privilege for psychotherapistpatient communications but holding that litigant waived privilege by raising issue as to her psychological state