Motion for Leave to File Additional Motions

Electronically Filed
2/24/2025 5:30 PM

Fourth Judicial District, Ada County Anne Taylor Law, PLLC Trent Tripple, Clerk of the Court
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,
DEFENDANT'S MOTION FOR LEAVE

V. ΤΟ FILE ADDITIONAL MOTIONS

CHALLENGING THE DEATH

BRYAN C. KOHBERGER, PENALTY

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby moves the Court for leave from the court's Sealed Order Governing Further Criminal Proceedings and Notice of Trial Setting filed 10/09/2024. Defense Counsel is asking for leave to file two additional motions challenging the death penalty. Good cause exists for these motions to be filed and heard.

DEFENDANT'S MOTION FOR LEAVE TO FILE ADDITIONAL

MOTIONS CHALLENGING THE DEATH PENALTY PAGE-1

Should the Court require a hearing on this matter, counsel requests a hearing to present oral argument, evidence and / or testimony in support thereof.

DATED this 24 day of February, 2025.

an
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 February, 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
DEFENDANT'S MOTION FOR LEAVE TO FILE ADDITIONAL

MOTIONS CHALLENGING THE DEATH PENALTY PAGE-2