Court Filing
Electronically Filed 4/2/2025 4:15 PM Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court By: Jennifer Keyes, Deputy Clerk LATAH COUNTY PROSECUTOR'S OFFICE WILLIAM W. THOMPSON, JR., ISB No. 2613 PROSECUTING ATTORNEY ASHLEY S. JENNINGS, ISB No. 8491 SENIOR DEPUTY PROSECUTING ATTORNEY JOSHUA D. HURWIT, ISB. No. 9527 SPECIAL DEPUTY PROSECUTING ATTORNEY Latah County Courthouse 522 S. Adams Street, Ste. 211 Moscow, ID 83843 Phone: (208) 883-2246 paservice@latahcountyid.gov IN THE DISTRICT COURT OF THE FOURTH DISTRICT OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA STATE OF IDAHO, Case No. CR01-24-31665 Plaintiff, STATE'S FIRST SUPPLEMENTAL REQUEST FOR DISCOVERY V. DISCLOSURE BRYAN C. KOHBERGER, Defendant. TO: THE DEFENDANT, BRYAN CHRISTOPHER KOHBERGER, AND COUNSEL PLEASE TAKE NOTICE that the undersigned, pursuant to Rule 16 (C) of the Idaho Criminal Rules and Idaho Code 18-207, requests discovery and inspection of the information, data, and materials listed in the attached Sealed Exhibit S-1. This is a continuing request pursuant to Idaho Criminal Rule 16 (j). STATE'S FIRST SUPPLEMENTAL REQUEST FOR DISCOVERY DISCLOSURE 1 While this First Supplemental Request applies to all of the defendant's expert witnesses, the specific basis for this request is that the Defendant's disclosures of the reports of the Forensic Psychiatric Evaluation by Dr. Eileen Ryan and the Neuropsychological Evaluation by Rachel Orr appear to be incomplete. The reports do not appear to be accompanied by all (i) the results and tests conducted as part of the examinations, Idaho Crim R. 16 (c) (2) and (ii) “ the facts and data for th [e] opinions ” contained in the reports, Idaho Crim. R. 16 (c) (4). As such, they do not afford the State " a complete opportunity to consider the substance of such testimony and prepare for rebuttal ” through its own experts. Idaho Code I.C. § 18-207. Accordingly, the State requests that defendant immediately produce the underlying data, evaluation, and examination results as outlined in Sealed Exhibit S-1. DATED this 2nd day of April 2025. JOSHUA D. HURWIT Special Deputy Prosecuting Attorney STATE'S FIRST SUPPLEMENTAL REQUEST FOR DISCOVERY DISCLOSURE 2 CERTIFICATE OF DELIVERY I hereby certify that true and correct copies of the STATE'S FIRST SUPPLEMENTAL REQUEST FOR DISCOVERY DISCLOSURE were served on the following in the manner indicated below: Anne Taylor Mailed Attorney at Law E-filed & Served / E-mailed PO Box 2347 Faxed Coeur d'Alene, ID 83816 info@annetaylorlaw.com Hand Delivered Dated this 2nd day of April 2025. S acee STATE'S FIRST SUPPLEMENTAL REQUEST FOR DISCOVERY DISCLOSURE 3