What is the burden of disclosing confidential communications between a patient and a litigant?

It is clear that the mere filing of a lawsuit does not trigger application of the patient-litigant exception (See In re Lifschutz (1970) 2 Cal.3d 415, 435-436, 85 Cal.Rptr. 829, 467 P.2d 557; Boling v. Superior Court (1980) 105 Cal.App.3d 430, 437-439, 164 Cal.Rptr. 432.) A court must look to what issues have been raised by the litigant who seeks to assert the privilege, including potential defenses to the litigant's cause of action. "[T]he burden rests upon the patient initially to submit some showing that a given confidential communication is not directly related to the issue he has tendered to court. [Citation.] A patient may have to delimit his claimed [ailment] or explain, in general terms, the object of the psychotherapy in order to illustrate that it is not reasonably probable that the psychotherapeutic communications sought are directly relevant to the mental condition that he has placed in issue. In determining whether communications sufficiently relate to the mental condition at issue to require disclosure, the court should heed the basic privacy interests involved in the privilege [citation];

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