Is there any case law where an evidentiary privilege has been applied in the context of a medical malpractice case?

[20 Cal.3d 858] We do not deny the efficacy of the district's general proposition when applied to some situations. In a number of contexts in which evidentiary privileges generally provide a cloak of confidentiality, exceptions to such privileges have been recognized as to information that relates to an issue which has been posited by the party claiming the privilege's protection. Thus, for example, under current California statutes both the physician-patient privilege and the psychotherapist-patient privilege are subject to a "patient-litigant" exception (see Evid.Code, 996, 1016; cf. Evid.Code, 958, 972, subds. (a), (c)) and, in the constitutional realm, the privilege against [574 P.2d 775] self-incrimination has been held to be subject to a similar "waiver" exception as to matters which are directly relevant to litigation commenced by the holder of the privilege. (See, e. g., Shepherd v. Superior

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