Bohsancurt v. Eisenberg
In Bohsancurt v. Eisenberg, 212 Ariz. 182, 212 Ariz. 182, 129 P.3d 471 (App. 2006), the Court rejected a similar argument about the admission of maintenance and calibration records for a breath-testing machine. That such records "may subsequently be used in DUI prosecutions," we found, "does not preclude them from qualifying as business records." Id. P18.
The Court was "not persuaded by Bohsancurt's arguments that the seminal issue under Crawford is whether the declarant can reasonably anticipate that his or her statement will likely be used at trial." 212 Ariz. 182, P28, 129 P.3d at 479.