Notice of Intent to Use 404b Evidence

Electronically Filed
2/4/2025 3:02 PM

Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Chynae Hull, Deputy Clerk
LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No, 2613
PROSECUTING ATTORNEY

ASHLEY S. JENNINGS, ISB No. 8491
SENIOR DEPUTY PROSECUTOR

Latah County Courthouse 522 S. Adams Street, Ste. 211 Moscow, ID 83843
Phone: (208) 883-2246 ISB No. 2613 paservice@latahcountyid.gov
IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA

STATE OF IDAHO, Case No. CR01-24-31665 Plaintiff,
NOTICE OF INTENT TO USE

I.R.E. 404 (b) EVIDENCE
BRYAN C. KOHBERGER,

Defendant.

COMES NOW the State of Idaho, by and through Ashley S. Jennings, Latah County Senior Deputy Prosecutor, and hereby gives notice, pursuant to Idaho Rule of Evidence 404 (b) (2), the State of Idaho intends to present evidence of crimes, wrongs or other acts, specifically:
• Video of traffic stop occurring at West Pullman Road / Farm Road in Moscow, Idaho on August 21, 2022, involving Bryan Kohberger and Latah County Sheriff's Office Corporal Darren Duke (discovered as AV000100);
NOTICE OF INTENT TO USE I.R.E. 404 (b) EVIDENCE 1

• Citation LTC3290000084 issued regarding same traffic stop (discovered as Bates 13012-13013).

The State intends to introduce this evidence for the purpose of proving Defendant's identity, vehicle, address, and phone number. This issue has been previously addressed by the Court in the December 15, 2023, “ Sealed Order Denying Motion to Dismiss Indictment on Grounds of Biased Grand Jury, Inadmissible Evidence, Lack of Sufficient Evidence, and Prosecutorial Misconduct ” (See Page 43).

RESPECTFULLY SUBMITTED this 4th day of February 2025.

asheup &. Jenning Ashley S. Jennings Sr. Deputy Prosecuting Attorney NOTICE OF INTENT TO USE I.R.E. 404 (b) EVIDENCE 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the NOTICE OF INTENT TO INTRODUCE I.R.E. 404 (b) EVIDENCE 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 Hand Delivered Dated this 4th day of February 2025.

Scen Jacie NOTICE OF INTENT TO USE I.R.E. 404 (b) EVIDENCE 3