Which kinds of counselors count as "psychotherapists" for purposes of the psychotherapist-patient privilege?

United States v. Skelton, 514 F.3d 433, 444-445 (5th Cir. 2008) (conviction for federal extortion offense; accused argued that district court erred in denying him an opportunity to ask specific "did you know" and "have you heard" questions during cross-examination of the Government's rebuttal character...During the cross-examination of a witness -- and during any examination of a witness who is a permissible target for impeachment -- the witness may be asked about specific acts that are indicative of the witness's untruthfulness if such acts are relevant to and probative of the witness' truthfulness or untruthfulness, unless the trial court determines that the acts inquired into are unduly prejudicial.

United States v. Marino, 277 F.3d 11, 26 (1st Cir. 2002) (upholding trial court's admission of the Hilton tapes as co-conspirator's statements because "the statements were made in furtherance of and in the course of....A statement falls within the hearsay exemption for statements of co-conspirators only if the statement was made in furtherance of the conspiracy.

United States v. Vartanian, 245 F.3d 609, 614 (6th Cir. 2001) (upholding trial court's admission of a witness's prior testimony in a civil action for violation of civil rights because it fell squarely within the....The hearsay exception for prior testimony applies in a criminal case only if the if the party against whom the testimony is now offered had an opportunity and similar motive to develop the testimony in the prior proceeding by direct, cross, or redirect examination. The exception applies in a civil action or proceeding only if the party against whom the testimony is now offered or a predecessor in interest had an opportunity and similar motive in the prior proceeding to develop the testimony by direct, cross, or redirect examination.