Notice of Appearance and Bail Reduction Motion

Filed: 01/12/2023 16:08:01 Second Judicial District, Latah County Julie Fry, Clerk of the Court
By: Deputy Clerk-Dodge, Tonya Anne C. Taylor, Public Defender Kootenai County Public Defender PO Box 9000 Coeur d'Alene, Idaho 83816
Phone: (208) 446-1700; Fax: (208) 446-1701
Bar Number: 5836 iCourt Email: pdfax@kcgov.us Assigned Attorney:
Anne Taylor, Public Defender Bar Number: 5836
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF LATAН

STATE OF IDAHO CASE NUMBER CR29-22-0002805

Plaintiff,
NOTICE OF APPEARANCE,

V. REQUEST FOR TIMELY

PRELIMINARY HEARING, MOTION

BRYAN C. KOHBERGER, FOR BAIL REDUCTION AND NOTICE

OF HEARING

Defendant.

COMES NOW, Anne Taylor, Public Defender, and pursuant to court appointment hereby appears for and on behalf of Bryan C. Kohberger, the above-named Defendant in the above entitled matter, and requests that a preliminary hearing be scheduled in accordance with the time limits set forth in Idaho Criminal Rule 5.1.

Counsel hereby moves for reduction of the bail set in this matter on the grounds that it is excessive, and further, notice is hereby given that counsel will present argument in support of the motion to reduce bond at the time of the preliminary hearing status conference and / or preliminary hearing scheduled in this matter if the Defendant is in custody. Counsel intends to
NOTICE OF APPEARANCE, REQUEST FOR

TIMELY PRELIMINARY HEARING MOTION

FOR BAIL REDUCTION AND NOTICE OF HEARING Page-1

present evidence and / or argument in support of all applicable factors outlined in Idaho Criminal Rule 46. Counsel further notifies counsel and the court that such request will be heard at the preliminary hearing status conference unless the case proceeds to hearing. If the case proceeds to hearing, bond shall be addressed at the time of the preliminary hearing.

Counsel hereby moves the court for an order shortening time for bond to be addressed if timing is insufficient.

The Defendant hereby demands a speedy jury trial as guaranteed to him by the Sixth and Fourteenth Amendments to the United States Constitution, Art. I Sections 7, 13 and 18 of the Idaho Constitution, and I.C. § 19-3501.

Notice is further given that the Defendant herewith asserts all rights accorded him or her under the Fifth, Sixth, and Fourteenth Amendments to the Constitution of the United States and under Article I, § 13 of the Constitution of the State of Idaho and all prophylactic measures imposed upon the State pursuant to said constitutional provisions; including, but not necessarily limited to, the right to remain silent and the right to counsel. NO AGENT OF THE STATE OR
PERSON ACTING IN SUCH CAPACITY IS TO QUESTION THE DEFENDANT IN
REGARD TO ANY ACT, WHETHER CHARGED OR UNCHARGED.

DATED this 11 day of January, 2023.

ANNE C. TAYLOR, PUBLIC DEFENDER

ΚΟΟΤΕΝΑI COUNTY PUBLIC DEFENDER

an
BY:

ANNE TAYLOR

PUBLIC DEFENDER

ASSIGNED ATTORNEY

NOTICE OF APPEARANCE, REQUEST FOR

TIMELY PRELIMINARY HEARING MOTION

FOR BAIL REDUCTION AND NOTICE OF HEARING Page-2

CERTIFICATE OF DELIVERY

I hereby certify that a true and correct copy of the foregoing was personally served as indicated below on the 11 day of January, 2023 addressed to:
Kootenai County Prosecuting Attorney –via iCourt: kcpaicourts@kcgov.us Dul
NOTICE OF APPEARANCE, REQUEST FOR

TIMELY PRELIMINARY HEARING MOTION

FOR BAIL REDUCTION AND NOTICE OF HEARING Page-3