Court Filing
Electronically Filed 3/24/2025 5:56 PM Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court Anne Taylor Law, PLLC By: Jennifer Keyes, Deputy Clerk Anne C. Taylor, Attorney at Law PO Box 2347 Coeur d'Alene, Idaho 83816 Phone: (208) 512-9611 iCourt Email: info@annetaylorlaw.com Elisa G. Massoth, PLLC Attorney at Law P.O. Box 1003 Payette, Idaho 83661 Phone: (208) 642-3797; Fax: (208)642-3799 Bicka Barlow Pro Hac Vice 2358 Market Street San Francisco, CA 94114 Phone: (415) 553-4110 Assigned Attorney: Anne C. Taylor, Attorney at Law, Bar Number: 5836 Elisa G. Massoth, Attorney at Law, Bar Number: 5647 Bicka Barlow, Attorney at Law, CA Bar Number: 178723 Jay W. Logsdon, First District Public Defender, Bar Number: 8759 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 NUMBER CR01-24-31665 Plaintiff, REPLY TO STATE'S RESPONSE TO V. DEFENDANT'S MOTION IN LIMINE # 13 BRYAN C. KOHBERGER, RE: CONDITIONS AS AGGRAVATOR Defendant. COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby replies to the State's Response to Motion in Limine 13 RE: Conditions as Aggravators filed with the Court on March 17, 2025. REPLY TO STATE'S RESPONSE TO DEFENDANT'S MOTION IN LIMINE # 13 RE: CONDITIONS AS AGGRAVATOR Page 1 The State has conceded it agrees with Mr. Kohberger's request in his motion to prevent the state from using his diagnosis and conditions thereof as aggravators in support of death should the case reach that stage. Mr. Kohberger's request finds basis in the caselaw cited in his Motion in Limine. The State's cited caselaw also supports his Motion that his diagnosis and conditions of autism not be used as aggravating factors. Mr. Kohberger has moved for, and it is unrefuted, that the State not use in support of aggravation, his diagnosis and characteristics of autism. The court should grant the motion as requested. DATED this 24 day of March, 2025. an BY: ANNE C. TAYLOR ANNE TAYLOR LAW, PLLC CERTIFICATE OF DELIVERY I hereby certify that a true and correct copy of the foregoing was personally served as indicated below on the 24 day of March, 2025 addressed to: Latah County Prosecuting Attorney –via Email: paservice@latahcountyid.gov Elisa Massoth – via Email: legalassistant@kmrs.net Jay Logsdon – via Email: Jay.Logsdon@spd.idaho.gov Bicka Barlow, Attorney at Law – via Email: bickabarlow@sbcglobal.net Jeffery Nye, Deputy Attorney General – via Email: Jeff.nye@ag.idaho.gov Dul REPLY TO STATE'S RESPONSE TO DEFENDANT'S MOTION IN LIMINE # 13 RE: CONDITIONS AS AGGRAVATOR Page 2