Motion to Amend Notice Pursuant to Idaho Code 18-4004A

Electronically Filed
10/9/2024 5:16 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.

PROSECUTING ATTORNEY

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843 (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,

Plaintiff, Case No. CR01-24-31665
V.

MOTION FOR LEAVE TO

AMEND NOTICE PURSUANT

BRYAN CHRISTOPHER KOHBERGER, TO IDAHO CODE §18-4004A

Defendant.

COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney, and respectfully moves the Court for leave to amend its June 26, 2023, “ Notice Pursuant to Idaho Code §18-4004A ” by withdrawing the Idaho Code §19-2515 (9) (g) aggravating factor. The proposed " Amended Notice Pursuant to Idaho Code §18-4004A ” is attached hereto.

In support of this motion, the State has continued to review this case and prepare for upcoming pre-trial motions practice and trial, and the State has determined that the remaining four aggravating factors contained in the State's “ Notice Pursuant to Idaho Code §18-4004A ” adequately reflect the State's interest and position on penalty.

MOTION FOR LEAVE TO AMEND NOTICE

PURSUANT TO IDAHO CODE §18-4004A-1

WHEREFORE, the State respectfully prays that the Court grant leave for the State to file the attached " Amended Notice Pursuant to Idaho Code §18-4004A. ” RESPECTFULLY SUBMITED this 9th day of October, 2024.

William W. Thompson, J.

Prosecuting Attorney
MOTION FOR LEAVE TO AMEND NOTICE

PURSUANT TO IDAHO CODE §18-4004A-2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION FOR LEAVE TO AMEND NOTICE PURSUANT TO IDAHO CODE §18-4004A was 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 9th day of October, 2024.

Kim K Workman KimK. Workman
MOTION FOR LEAVE TO AMEND NOTICE

PURSUANT TO IDAHO CODE §18-4004A-3