I doubt anyone talked to anyone and heard anything directly. At best there was some overhearing as is always the case in a high-profile medical case. Could be that someone heard "hip dislocation and we need to check to ensure there is no posterior fracture" but did not register all of it. Still could be HIPPA if it was a nurse or anyone else who is covered by it but I doubt anyone prosecutes a doctor for speaking to another doctor in a fast moving case without confirming everyone in earshot is covered by the NDA.
HIPPA does not require an NDA. Doctors will talk with other doctors or health professionals when reviewing a case. All are bound by the HIPPA laws to keep the information confidential.
