Notice of Filing List of Stipulated Exhibits

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Named in this document

  • Bryan Kohberger Person
  • Brett Payne Person
  • Dylan Mortensen Person
  • Jay Logsdon Person
  • Connell, WA Location
  • Anne Taylor Person
  • Ashley Jennings Person
  • Dawn Daniels Person
  • Dustin Blaker Person
  • Elsa G. Massoth Person
  • Jennifer Keyes Person
  • Lawrence Mowery Person
  • Michael Lang Person
  • Mitch Nunes Person
  • Mr. Nye Person
  • Nick Ballance Person
  • Thomas Slovenski Person
Electronically Filed
1/29/2025 1:47 PM

Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Jennifer Keyes, Deputy Clerk 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 Jay W. Logsdon, First District Public Defender Idaho State Public Defender 1450 Northwest Blvd.

Coeur d'Alene, Idaho 83814
Phone: (208) 605-4575 Elisa G. Massoth, PLLC Attorney at Law P.O. Box 1003 Payette, Idaho 83661
Phone: (208) 642-3797; Fax: (208)642-3799 Assigned Attorney:
Anne C. Taylor, Attorney at Law, Bar Number: 5836 Jay W. Logsdon, First District Public Defender, Bar Number: 8759 Elisa G. Massoth, Attorney at Law, Bar Number: 5647
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,
NOTICE OF FILING LIST OF

V. STIPULATED EXHIBITS FOR

MOTIONS TO SUPPRESS AND MOTION

BRYAN C. KOHBERGER, FOR FRANKS ' HEARING

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and with stipulation of the State, hereby files lists of all exhibits admitted by stipulation during the various
NOTICE OF FILING LIST OF STIPULATED EXHIBITS FOR MOTIONS

TO SUPPRESS AND MOTION FOR FRANKS ' HEARING Page-1

Motions to Suppress and Motion for Franks Hearing held on January 23 and 24, 2025.

DATED this 29th day of January, 2025.

an No objection per email 1/29/25
ASHLEY JENNINGS ANNE C. TAYLOR

SENIOR DEPUTY PROSECUTOR 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 29 day of January, 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 Jeffery Nye, Deputy Attorney General – via Email: Jeff.nye@ag.idaho.gov Dual
NOTICE OF FILING LIST OF STIPULATED EXHIBITS FOR MOTIONS

TO SUPPRESS AND MOTION FOR FRANKS ' HEARING Page-2

Motion for a Franks Hearing EXHIBIT # Description Pleading Defendant's Exhibit Email Communications BETWEEN Detective Payne, FBI Agent Ballancve, and Defendant's Memorandum in Support for a Franks D1 Latah County Prosecutor's Office Hearing Defendant's Exhibit Email with additional PC Attachment from Defendant's Memorandum in Support for a Franks D1-B FBI Agent Nicholas Balance to Brett Payne Hearing Defendant's Exhibit Email with working draft for search warrant for AT & T from Brett Payne to FBI Agent Defendant's Memorandum in Support for a Franks D1-C Nicholas Balance Hearing Defendant's Exhibit Exhibit A Statement of Dustin Blaker Affidavit presented to a Judge in Defendant's Memorandum in Support for a Franks D2 Washington Hearing Defendant's Exhibit Affidavit for Search Warrant to Google 1.3.23 Defendant's Memorandum in Support for a Franks D3-A warrant Hearing Defendant's Exhibit Affidavit in Support of Arrest Defendant's Memorandum in Support for a Franks D3-B Hearing Defendant's Exhibit Transcript-5.23.24 Motion to Compel Defendant's Memorandum in Support for a Franks D4-A 2:38 p.m. Hearing Defendant's Exhibit Transcript-5.30.24 Motion to Compel Defendant's Memorandum in Support for a Franks D4-B 10:00 a.m. Hearing Defendant's Exhibit Defendant's Memorandum in Support for a Franks D5 CAST Report-Draft Hearing Defendant's Exhibit Defendant's Memorandum in Support for a Franks D6 CAST Report Hearing Defendant's Exhibit Affidavit of Tom Slovinski Defendant's Memorandum in Support for a Franks D7-A Hearing Defendant's Exhibit Affidavit of Sy Ray Defendant's Memorandum in Support for a Franks D7-B Hearing Defendant's Exhibit Officer Nunes Transcript and Summary Defendant's Memorandum in Support for a Franks D8-A Hearing Defendant's Exhibit Detective Mowery Transcript and Summary Defendant's Memorandum in Support for a Franks D8-B Hearing Defendant's Exhibit Detective Gooch Transcript and summary Defendant's Memorandum in Support for a Franks D8-C Hearing Defendant's Exhibit Emails with Vehicle Identification Expert Defendant's Memorandum in Support for a Franks D9 Hearing Defendant's Exhibit Affidavit in support of Search Warrant-UPS Defendant's Memorandum in Support for a Franks D10 Hearing Defendant's Exhibit Payne's IM Communications Defendant's Memorandum in Support for a Franks D11 Hearing Defendant's Exhibit BOLO Defendant's Memorandum in Support for a Franks D12 Hearing Defendant's Exhibit Supplemental Report 52 by Brett Payne Re Defendant's Memorandum in Support for a Franks D13 Test Runs Hearing Defendant's Exhibit SEALED Transcript of Grand Jury Hearing Defendant's Memorandum in Support for a Franks D14-A 5.15.23 Hearing Defendant's Exhibit SEALED Transcript of Grand Jury Hearing Defendant's Memorandum in Support for a Franks D14-B 5.16.23 Hearing Defendant's Exhibit Supplemental Report 152 by Officer Defendant's Memorandum in Support for a Franks D15-A Gunderson Re Dog Hearing Defendant's Exhibit Screen clip from Officer Nunes bodycam Defendant's Memorandum in Support for a Franks D15-B video of the dog upon arrival Hearing Defendant's Exhibit Defendant's Memorandum in Support for a Franks D16 Return on Warrant Hearing Defendant's Exhibit AT & T Records Provided Pursuant to Search Defendant's Memorandum in Support for a Franks D17 Warrant Hearing Defendant's Exhibit Cellebrite Report Defendant's Memorandum in Support for a Franks D18 Hearing

Defendant's Exhibit Department of Justice Interim Policy Defendant's Memorandum in Support for a Franks D19 Hearing Defendant's Exhibit Letter from Latah County Proswecuting Attorney dated 6/24/24 to Othram Defendant's Memorandum in Support for a Franks D20 regarding databases searched Hearing Defendant's Exhibit Transcript from Motion to Compel Hearing Defendant's Memorandum in Support for a Franks D21 on 5/30/24 Hearing Defendant's Exhibit Shoeprint outside of Dylan Mortensen's Defendant's Memorandum in Support for a Franks D22 room Hearing Defendant's Exhibit Transcript of AVoo088 file-Mortensen Defendant's Memorandum in Support for a Franks D23 interview 12/30/22 Hearing Defendant's Exhibit Order on Defendant's 4th and 5th Motions Defendant's Memorandum in Support for a Franks D24 to Compel Discovery (unredeacted) Hearing Defendant's Exhibit Lab Report 28 Defendant's Memorandum in Support for a Franks A Hearing Defendant's Exhibit Lab Report 29 Defendant's Memorandum in Support for a Franks D25-B Hearing Defendant's Exhibit Lab Report 30 Defendant's Memorandum in Support for a Franks D25-C Hearing Defendant's Exhibit Sealed Letters between Latah County Defendant's Memorandum in Support for a Franks D26 Prosecuting Attorney's Office and FBI Hearing Defendant's Exhibit Sealed Letter dated 11/28/23 from FBI to Defendant's Memorandum in Support for a Franks D27 Latah County Prosecuting Attorney Hearing Defendant's Exhibit Skivubsju CV; Ray CV Defendant's Memorandum in Support for a Franks D28 Hearing Defendant's Exhibit Defendant's Memorandum in Support for a Franks D29 Sy Ray Cases Hearing Defendant's Exhibit Mesaging with Payne Defendant's Memorandum in Support for a Franks D30 Hearing Defendant's Exhibit Lab Report 1/27/23 FBI Fibers hair-no Defendant's Memorandum in Support for a Franks D31 connection Hearing Defendant's Exhibit Lab Report 2/28/23 FBI Fiber / hair no Defendant's Memorandum in Support for a Franks D32 connection Hearing Defendant's Exhibit Biology Analysis notes, Photos, Neg Blood Defendant's Memorandum in Support for a Franks D33 Hearing Defendant's Exhibit DNA 1/23/23 Defendant's Memorandum in Support for a Franks D34 Hearing Defendant's Exhibit Defendant's Memorandum in Support for a Franks D35 ISP Forensics Hearing State's Exhibit S-1 Interview with Dylan Mortensen 11/17/22 State's Objection to Defendant's Amended Motion for Franks Hearing State's Objection to Defendant's Amended Motion for State's Exhibit S-2 Interview with Dylan Mortensen 12/1/22 Franks Hearing FBI SA Hille Report regarding video State's Objection to Defendant's Amended Motion for State's Exhibit S-3 surveillance Franks Hearing Screenshot from Mitch Nunes body camera State's Objection to Defendant's Amended Motion for State's Exhibit S-4 on 11/13/22 at 12:04:55 Franks Hearing ISP Forensic Biology Report 33 dated State's Objection to Defendant's Amended Motion for State's Exhibit S-5 5/23/23 Franks Hearing

Motion to Suppress Re: Genetic Inforamation EXHIBIT # DESCRIPTION Pleading Email between Gammett and Defendant's Memo in Support Mooney Re Contact for FBI of Motion to Suppress Genetic Defendant's Exhibit 1 Genology Info Reply to State's Objection to Arizona V. Mitcham Opinion from Motion to Suppress- Genetic Defendant's Exhibit A || Court of Appeals Information Defendant's Memorandum in Sealed Letters between Latah Support for a Franks Hearing County Prosecuting Attorney's but utilized in Motion to Defendant's Exhibit 26 Office and FBI Suppress IGG Defendant's Memorandum in Defendant's Exhibit Department of Justice Interim Support for a Franks Hearing D19 Policy but utilized in Motion to Suppress IGG Colorado v. Phillips, Order State's Objection to Denying Motion to Supress Defendant's Motion to Familial DNA Serach and Fruit Suppress Re: Genetic State's Exhibit S-1 Thereof Information

Motion to Suppress Re: AT & T First Warrant EXHIBIT # DESCRIPTION Pleading Defendant's Return of Warrant Receipt and Inventory and Reply to State's Objection to Exhibit A Order Defendant's Motion to Suppress (Court entered and Memorandum in Support this as Exhibit Re: AT & T First Warrant
S-2.1)

State's Objection to Defense State's Exhibit Affidavit for Search Warrant Re: AT & T (first Motion to Suppress re: AT & T S-1 warrant) First Warrant State's Objection to Defense State's Exhibit Search Warrant Re: AT & T (first warrant) dated Motion to Suppress re: AT & T S-2 12/23/22 First Warrant

Motion to Suppress Re: Pen Trap and Trace EXHIBIT # DESCRIPTION Pleading attached to Defendant's Return of Search Warrant, Affidavit, Exhibit A Receipt & Inventory, and Order (Court entered Reply to State's Objection to Defendant's this as exhibit Motion to Suppress and Memorandum in S2.1) Support re: Pen Trap and Trace Device Reply to State's Objection to Defendant's 12.23.22 Trap and Trace Warrant 509 Motion to Suppress and Memorandum in Defendant's 592-8458-Ballance
Exhibit B Support re: Pen Trap and Trace Device Defendant's Exhibit C (Court Reply to State's Objection to Defendant's entered this as Exhibit C AT & T form with warrant Motion to Suppress and Memorandum in exhibit 2.3) Support re: Pen Trap and Trace Device Affidavit for Search Warrant and Application for an Order for a Pen State's objection to Defendant's Motion to register or a Trap and Trace Device Suppress and Memorandum in Support
State Exhibit S-1 RE: Pen Trap and Trace Device Search Warrant and Order for a Pen Register or a Trap and Trace Device State's objection to Defendant's Motion to and Non-Disclosure Order pursuant Suppress and Memorandum in Support State Exhibit S-2 to I.C. 18-6722 RE: Pen Trap and Trace Device

Motion to Suppress Pennsylvania Search Warrant for Lamsden Dr., Albrightsville, PA and Statements Made EXHIBIT # DESCRIPTION Pleading Defendant's Search Warrant for 119 Lamsden Motion to Suppress and Memorandum in Support re:
Exhibit A Pennsylvania Search Warrant for 119 Lamsden Dr., Albrightsville, PA and statements made Defendant's Attest Warrant and Affidavit for Motion to Suppress and Memorandum in Support re:
Exhibit B Arrest Warrant 12/29/22 Pennsylvania Search Warrant for 119 Lamsden Dr., Albrightsville, PA and statements made State's Pennsylvania State Police Report State's Objection to Defendant's Motion to Suppress Exhibit S-1 (Initial Narrative) and Memorandum in Support re: Pennsylvania Search Warrant for 119 Lamsden Drive, Albrightsville, PA and Statements Made State's Pennsylvania State Police Report-State's Objection to Defendant's Motion to Suppress Exhibit S-2 General Offense Report and Memorandum in Support re: Pennsylvania Search Warrant for 119 Lamsden Drive, Albrightsville, PA and Statements Made State's Pennsylvania State Police Report-State's Objection to Defendant's Motion to Suppress Exhibit S-3 General Offense Report-PSP Special and Memorandum in Support re: Pennsylvania Emergency Response Team Event Search Warrant for 119 Lamsden Drive, Log Albrightsville, PA and Statements Made State's Application for Search Warrant State's Objection to Defendant's Motion to Suppress Exhibit S-4 and Memorandum in Support re: Pennsylvania Search Warrant for 119 Lamsden Drive, Albrightsville, PA and Statements Made State's Letter to Detective Payne from State's Objection to Defendant's Motion to Suppress Exhibit S-5 Pennsylvania State Police-Sgt. and Memorandum in Support re: Pennsylvania Michael Lang Search Warrant for 119 Lamsden Drive, Albrightsville, PA and Statements Made State's Pennsylvania State Police Report-State's Objection to Defendant's Motion to Suppress Exhibit S-6 General Offense Report regarding and Memorandum in Support re: Pennsylvania custody of Bryan Kohberger Search Warrant for 119 Lamsden Drive, Albrightsville, PA and Statements Made

Motion to Suppress re: Search Warrant for Mr. Kohberger's Person EXHIBIT # DESCRIPTION Pleading State's Objection to Defendant's Motion to Suppress and Affidavit for Search Warrant for Memorandum in Support re: search State's Exhibit S-1 Bryan Kohberger's Person warrant for Mr. Kohberger's person State's Objection to Defendant's Motion to Suppress and Search Warrant Dated 1/5/23 Memorandum in Support re: search State's Exhibit S-2 Re: Bryan Kohberger's Person warrant for Mr. Kohberger's person

Motion to Suppress re: Search Warrant for Defendant's Apartment EXHIBIT # DESCRIPTION Pleading Defendant's Exhibit A Application for Search Motion to Suppress and Memo Warrant; Motion and Order in Support re: Search Warrant to Un-sweal Return; Motion for Defendant's Apartment to Transfer Custody of Items;
Motions and Orders to Seal;
Search Warrant Return;
State's Exhibit S-1 Redacted Search Warrant for State's Objection to Defendant's Residence (Washington) Motion to Suppress and Memo in Support re: Search Warrant for Defendant's Apartment State's Exhibit S-2 Amended Statement by State's Objection to Defendant's Dawn Daniels, WSU Police Motion to Suppress and Memo Regarding Search for in Support re: Search Warrant Residence (Washington) for Defendant's Apartment

Motion to Suppress Re: Cell Phone / USB Moscow Police Forensic Lab EXHIBIT # Description Pleading Defendant's Exhibit A Affidavit for Search Defendant's Motion to Suppress Warrant and Search Cell Phone / USB File and Warrant, dated 1/9/2023. memorandum in Support re:
Moscow Police Forensic Lab Warrant Dated January 9, 2023

Motion to Suppress and Memo in Support RE: Apple Account Federal Grand Jury Subpoena and Search warrant dated August 1, 2023 EXHIBIT # DESCRIPTION Pleading Defendan't Apple-Preservation Letter, 12/21/2022. Apple Motion to Suppress and
Exhibit A Memo in Support RE: Apple Account Federal Grand Jury Subpoena and Search warrant dated August 1, 2023 Defendant's Apple-Subpoena Certification, 1/12/2023. Apple Motion to Suppress and
Exhibit B Memo in Support RE: Apple Account Federal Grand Jury Subpoena and Search warrant dated August 1, 2024 Defendant's Apple-Email Chane, 4/7/2023 to 4/13/2023. Apple Motion to Suppress and
Exhibit C Memo in Support RE: Apple Account Federal Grand Jury Subpoena and Search warrant dated August 1, 2025 Defendant's Apple Affidavit for Search Warrant and Apple Motion to Suppress and Exhibit D Search Warrant, 8/1/2023. Memo in Support RE: Apple Account Federal Grand Jury Subpoena and Search warrant dated August 1, 2026 Defendant's Apple-Affidavit, Return of Search Warrant, Apple Motion to Suppress and Exhibit E and Receipt and Inventory, 8/9/2023. Memo in Support RE: Apple Account Federal Grand Jury Subpoena and Search warrant dated August 1, 2027 State's Affidavit for Search Warrant Re: Apple dated State's Objection to Defendant's Exhibit S-1 8/1/23 including Exhibit A (Statement of Motion to Suppress and Memo Officer); and Exhibit B (Receipt for iPad Pro in Support re: Apple Account dated 1/5/18 (Federal Grand Jury Subpoena and Search Warrant dated August 1, 2023 State's Search Warrant Re: Apple dated 8/1/23 State's Objection to Defendant's Exhibit S-2 Motion to Suppress and Memo in Support re: Apple Account Federal Grand Jury Subpoena and Search Warrant dated August 1, 2023 State's Order for Return of Warrant dated August 14, State's Objection to Defendant's Exhibit S-3 2023 Motion to Suppress and Memo in Support re: Apple Account Federal Grand Jury Subpoena and Search Warrant dated August 1, 2023 State's Thumb Drive containing information from State's Objection to Defendant's Exhibit S-4 Apple Motion to Suppress and Memo in Support re: Apple Account Federal Grand Jury Subpoena and Search Warrant dated August 1, 2023

Motion to Suppress re: Amazon Account Federal Grand Jury Subpoenas and Warrants dated April 26, 2023, and May 9, 2023 EXHIBIT # DESCRIPTION Pleading Defendant's Amazon-Affidavit for Search Motion to Suppress and Memo in Exhibit A Warrant dated 4/26/2023 and support re: Amazon Account Amended Search Warrant dated Federal Grand Jury Subpoenas and
5/8/2023. Warrants dated April 26, 2023, and May 9, 2023 State's Exhibit S-1 Search Warrant Re: Amazon dated State's Objection to Defendant's
3/26/23 Motion to Suppress and Memo in support re: Amazon Account Federal Grand Jury Subpoenas and Warrants dated April 26, 2023, and May 9, 2023 State's Objection to Defendant's Motion to Suppress and Memo in support re: Amazon Account Federal Grand Jury Subpoenas and
Amended Search Warrant Re: Amazon Warrants dated April 26, 2023, and State's Exhibit S-2 dated 5/8/23 May 9, 2023 State's Objection to Defendant's Motion to Suppress and Memo in support re: Amazon Account Federal Grand Jury Subpoenas and
Affidavit for Search Warrant Re: Amazon Warrants dated April 26, 2023, and State's Exhibit S-3 (including Exhibit A) May 9, 2023 State's Objection to Defendant's Motion to Suppress and Memo in support re: Amazon Account Federal Grand Jury Subpoenas and Amazon Subscription Information for Warrants dated April 26, 2023, and State's Exhibit S-4 Bryan Kohberger May 9, 2023

Motion to Suppress and Memorandum in Support re: Google Warrants Dated 1-3-23, 1-24-23, and 2-24-23 EXHIBIT DESCRIPTION Pleading A Google Warrant One, 1/3/2023 – Affidavit for Motion to Suppress and Memorandum Search Warrant and Search Warrant. in Support re: Google Warrants Dated 1- 3-23, 1-24-23, and 2-24-23 B Google Warrant Two, 1/25/2023 – Affidavit for Motion to Suppress and Memorandum Search Warrant and Search Warrant. in Support re: Google Warrants Dated 1- 3-23, 1-24-23, and 2-24-24 C Google Warrant Three, 2/24/2023 – Affidavit for Motion to Suppress and Memorandum Search Warrant and Search Warrant. in Support re: Google Warrants Dated 1- 3-23, 1-24-23, and 2-24-25 D Return for Google Warrant Three, 3/14/2023. Motion to Suppress and Memorandum in Support re: Google Warrants Dated 1- 3-23, 1-24-23, and 2-24-26 E Receipt and Inventory for Google Warrant Three, Motion to Suppress and Memorandum
3/14/2023. in Support re: Google Warrants Dated 1- 3-23, 1-24-23, and 2-24-27 F Email between Lawrence Mowery and Google, Motion to Suppress and Memorandum
1/4/2023. in Support re: Google Warrants Dated 1- 3-23, 1-24-23, and 2-24-28