finds that Jackie’s argument that her communications are privileged is without merit. The court is unaware of any authority that holds that Virginia Code § 63.2-104.1 creates a patient-counselor privilege, and the court declines to do so in this ease. In addition, the statutory language permits disclosure of protected information in response to a court mandate, which provides further support for the court’s finding that the statute does not establish an evidentiary privilege. Even assuming that the court could find that this statute establishes a patienhcounselor privilege, it appears that Jackie may have waived such privilege by voluntarily disclosing the contents of her communications with Eramo and UVA to defendants. See United States v. Bolander, 722 F.3d 199, 223 (4th Cir.2013) (<HOLDING>). Accordingly, the court finds that Request
holding that production of documents without a claim of privilege waives the right to later claim that privilege holding that a patient waives the patientpsychotherapist privilege by voluntarily disclosing the substance of therapy sessions to third parties holding that an invocation of the advice of counsel defense waives the attorneyclient privilege holding that a party waives the attorneyclient privilege when it voluntarily consents to the disclosure of any significant part of the communication in issue holding that a claim for ineffective assistance of counsel waives attorneyclient privilege