Court Filing
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. AMENDED NOTICE PURSUANT TO BRYAN CHRISTOPHER KOHBERGER, IDAHO CODE §18-4004A Defendant. COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney, and hereby gives notice to the Court, the defendant and his counsel, pursuant to Idaho Code §18- 4004A, that as of this point in time, and based on the information known to the State to date, the following statutory aggravating circumstances, pursuant to Idaho Code §19-2515 (9), appear to exist in this case as to the crimes of Murder in the First Degree as charged in Counts II, III, IV and V of the Indictment herein: 1. Idaho Code §19-2515 (9) (b) – at the time the murder was committed the defendant also committed another murder; and / or AMENDED NOTICE PURSUANT TO IDAHO CODE §18-4004A: Page -1- 2. Idaho Code §19-2515 (9) (e) – the murder was especially heinous, atrocious or cruel, manifesting exceptional depravity; and / or 3. Idaho Code §19-2515 (9) (f) – by the murder, or circumstances surrounding its commission, the Defendant exhibited utter disregard for human life; and / or 4. Idaho Code §19-2515 (9) (i) – the defendant, by his conduct, whether such conduct was before, during or after the commission of the murder at hand, has exhibited a propensity to commit murder which will probably constitute a continuing threat to society. The State gives this notice based on the fact that it has not identified or been provided with any mitigating circumstances sufficient to prohibit the triers of fact from considering all penalties authorized by the Idaho legislature including the possibility of a capital sentence. Consequently, considering all evidence currently known to the State, the State is compelled to file this notice of intent to seek the death penalty. The State will continue to review additional information as it is received and reserves its statutory right to amend or withdraw this notice. Respectfully submitted this 9th day of October, 2024. 2204 William W. Thompson, Jr. Prosecuting Attorney AMENDED NOTICE PURSUANT TO IDAHO CODE §18-4004A: Page -2- CERTIFICATE OF DELIVERY I hereby certify that true and correct copies of the AMENDED 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 AMENDED NOTICE PURSUANT TO IDAHO CODE §18-4004A: Page -3-