are plainly a reliable basis for a warrant applied for by one of their number.” United States v. Ventresca, 380 U.S. 102, 111, 85 S.Ct. 741, 747, 13 L.Ed.2d 684 (19 ished from this case. Although Smith and Jordan have an established hostile relationship like the defendant and victim in Cobble, there was no protective order in this case. Unlike the targets of the threats in Nassau who could, presumably, view the defendant’s account records, it is not clear Jordan could view Officer Hammock’s report. And there is nothing in the record to suggest that Smith, despite her frequent contact with law enforcement, ever discussed the proper police response to threats against a third party with any of those officers. Moreover, there are also some cases that support Smith’s vi 371, 373-74 (2011) (<HOLDING>). But this case can be distinguished from
holding that the term medical as used in the hearsay exception regarding statements made for the purpose of medical diagnosis or treatment includes emotional and mental health as well as physical health holding that a defendant had no intent to communicate his threats to a victim where he made them for the purpose of obtaining a diagnosis and treatment from mental health professionals holding psychotherapist liable for negligent failure to warn potential victim or her parents that the violenceprone patient undergoing psychiatric treatment by defendant had made threats against the victim whom he subsequently murdered holding a victims statements to emergency room doctor not testimonial where the purpose of the examination was for medical diagnosis and treatment holding that threats made in the presence of a law enforcement officer were sufficient evidence to indicate an intent to communicate because the victim had a protective order against the defendant and the defendant had just violated that order