the reliability of her testimony or offend Davis’s right to confrontation. ¶ 23 Finally, the State has adequately demonstrated case-specific necessity for the requested accommodation. See Smith, 308 P.3d at 138-39 (requiring an adequate showing of necessity and stating that mere inconvenience to a witness is insufficient under Craig to supplant face-to-face testimony); see also State ex rel. Montgomery v. Padilla, 239 Ariz. 314, 317, ¶¶ 9-11, 371 P.3d 642, 645, 1 CA-SA16-0017, 1 CA-SA 16-0027, 2016 WL 1063284, at *3, ¶¶ 9-11 (Ariz.App. Mar. 17, 2016) (concluding the heightened standard of clear and convincing evidence of an individualized and case-specific need for an accommodation applied to minor victim witnesses under A.R.S. § 13-4253 (2010)); cf. Rogerson, 855 N.W.2d at 506-07 (<HOLDING>). In this case, E.P. is beyond the State’s
recognizing that most courts seem to require some impediment to testifying beyond mere unwillingness to travel and noting that a general consensus exists that mere convenience efficiency and costsaving are not sufficiently important holding that harm must be sufficiently severe and rise above mere harassment holding that the mere determination that removal was improper does not require a district court to award attorneys fees holding that mere negligence does not implicate the right to due process holding that mere expectancy is not property