PATRICK RICHARDSON, Plaintiff, v. SEXUAL ASSAULT/SPOUSE ABUSE RESOURCE CENTER, INC., ET AL., Defendants., 764 F. Supp. 2d 736

Summary

Plaintiff ex-husband served a request for production of documents on defendant spouse abuse resource center, seeking files pertaining to communications between his ex-wife and defendant, an unlicensed counselor. The court held that 1) the same rationale for extending the psychotherapist-patient privilege to licensed social workers applied to an unlicensed counselor working under the supervision of a licensed social worker; 2) the privilege had not been waived; and 3) the counselor had standing to assert the privilege on behalf of her patient, who was not a party to the action.