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¶¶ 11–12 (App. 2005) (finding no violation of former version of One-Expert Rule where psychiatrist performing a psychological examination was “more akin to a ‘witness to the facts giving rise to the action’ than to an expert ‘retained for testimonial purposes’” (quoting Rule 26(b)(4) cmt.

¶6 “We review a trial court’s decision whether to strike jurors for cause for abuse of discretion.” ¶ 46 (2005) (opinion corrected on denial of reconsideration, ).

¶18 Our appellate courts have not provided particularly clear guidance on the meaning of “independent expert.” Two opinions of this court have accepted the Committee Comment’s definition of “independent expert,” although neither focused directly on whether an expert was “independent” because the expert was “retained.” -74, ¶¶ 9-12, -44 (App. 2005) (holding that an expert presenting opinions formed as a result of statutory duties was more akin to a fact witness than an expert witness); Ariz. Dep’

“We review a trial court’s rulings on voir dire of prospective jurors for abuse of discretion.” ¶ 36, opinion corrected on denial of reconsideration, P.3d 1240 (2005).

Rather, a petition to declare a person an SVP “seeks a declaration of the person’s current status.” ¶8 , see also A.R.S.

15 filing date because that was when defendant acquired vested right to assert affirmative defense of contributory negligence); see also In re Commitment of Frankovitch, 211 Ariz. 370, ¶ 8, (rejecting argument that operative date for determining applicability of statute eliminating right to jury trial in sexually violent persons cases is date petition was filed to have person committed as sexually violent; “operative date” is date person is found sexually violent