Court Filing
Anne Taylor Law, PLLC 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, Plaintiff, CASE NUMBER CR01-24-31665 V. 2nd NOTICE OF FILING DEFENDANT'S BRYAN C. KOHBERGER, PROPOSED JURY INSTRUCTIONS UNDER SEAL Defendant. COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby submits to the Court two additional proposed jury instructions. DATED this 14 day of May, 2025. an ANNE C. TAYLOR ANNE TAYLOR LAW, PLLC 2nd NOTICE OF FILING DEFENDANT'S PROPOSED JURY INSTRUCTIONS UNDER SEAL Page 1 CERTIFICATE OF DELIVERY I hereby certify that a true and correct copy of the foregoing was personally served as indicated below on the 14 day of May, 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 Dunl 2nd NOTICE OF FILING DEFENDANT'S PROPOSED JURY INSTRUCTIONS UNDER SEAL Page 2 PUBLIC SENTIMENT DEFENDANT'S REQUESTED INSTRUCTION NO. In reaching your final sentencing verdicts, you must treat the defendant as a uniquely individual human being. Further, you must not be influenced by prejudice or bias of any sort against the defendant or the prosecution, and you must not consider any public opinion or community sentiment for or against the defendant or the prosecution. Your decisions may not be the result of any irrational or arbitrary emotional response. Rather, each of your final sentencing verdicts reflect your individual reasoned moral determination. GIVEN REFUSED ACCEPTED MODIFIED COVERED HONORABLE STEVEN J. HIPPLER NOT EXPLAINING BUT RESPECT DEFENDANT'S REQUESTED INSTRUCTION NO. There is no requirement that you explain or justify to your fellow jurors why your individual reasoned moral judgment leads you to a particular decision on a count. Nevertheless, it is your duty as jurors to consult with one another and to deliberate on all the counts. While you are not required to agree with the determinations, opinions, feelings, or thoughts of other jurors, you must deliberate with your fellow jurors. After deliberating, if a juror disagrees with the rest of the jurors, that disagreement must be respected by the other jurors and will be respected by the Court. Ultimately, each of you must deliberate and decide for yourself the appropriate sentence based on your individual and reasoned moral judgment. GIVEN REFUSED ACCEPTED MODIFIED COVERED HONORABLE STEVEN J. HIPPLER