Court Filing
Electronically Filed 3/31/2025 2:08 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 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, AMENDED NOTICE OF FILING V. DECLARATION IN SUPPORT OF DEFENDANT'S OBJECTION ΤΟ BRYAN C. KOHBERGER, THE STATE'S MOTION IN LIMINE Defendant. RE: TEXT MESSAGES AND TESTIMONY COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby files the accompanying Declaration of Josiah Roloff in support of their Objection to the State's AMENDED NOTICE OF FILING DECLARATION IN SUPPORT OF DEFENDANT'S OBJECTION TO THE STATE'S MOTION IN LIMINE RE: TEXT MESSAGES AND TESTIMONY Page 1 Motion in Limine RE Text Messages and Testimony filed with the Court on March 17, 2025. DATED this 31 day of March, 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 31 day of March, 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 AMENDED NOTICE OF FILING DECLARATION IN SUPPORT OF DEFENDANT'S OBJECTION TO THE STATE'S MOTION IN LIMINE RE: TEXT MESSAGES AND TESTIMONY Page 2 I, Josiah Roloff, declare as follows: 1. I am over the age of 18 and competent to testify in this matter. 2. I am currently the President and Senior Digital Forensics Examiner at Roloff Digital Forensics LLC, a private digital forensics firm headquartered in Spokane, Washington. My firm provides digital forensic services and consulting in legal matters involving electronic evidence, including evidence derived from computers, mobile phones, memory cards, other electronic devices, and datasets from third-party electronic service providers. 3. My background in digital forensics includes a professional certificate in computer forensics from Oregon State University and New Technologies, Inc. (NTI); the Certified Computer Examiner (CCE) credential from the International Society of Forensic Computer Examiners; the EnCase Certified Examiner (EnCE) certification from Guidance Software; and multiple certifications from Cellebrite, including the Cellebrite Certified Logical Operator (CCLO), Cellebrite Certified Physical Analyst (CCPA), and Cellebrite Certified Mobile Examiner (CCME). I also hold an associate degree in applied science in network engineering from Spokane Community College and a bachelor's degree in liberal studies with an emphasis in program management from Whitworth University. A summary of my qualifications is included in my attached Curriculum Vitae. 4. I have worked exclusively in the field of digital forensics since 2003. During this time, I have conducted examinations on thousands of digital evidence items, including hard drives, CDs, DVDs, floppy diskettes, thumb drives, flash cards, magnetic tapes, tablet devices, cellular phones, SIM cards, PDAs, smartphones, feature phones, and data obtained from internet service providers, cloud storage providers, and cellular service providers. I have worked on over 1,500 digital forensics cases involving these types of media. 5. In addition to my work as a digital forensics examiner, I regularly lecture on topics related to general and mobile digital forensics and their application in legal proceedings. In 2015, I co-authored the mobile forensics chapter in the Chapman and Hall / CRC publication Mobile Devices: Tools and Technologies. I have been recognized as a computer, digital, and mobile forensics expert in numerous United States District Courts, military courts, and state courts nationwide. I have been retained or appointed as an expert consultant and expert witness in both criminal and civil matters, on behalf of both prosecution and defense. I have never failed to qualify as an expert in any civilian or military court. 6. My firm's clients include the United States Navy, Marine Corps, Army, Air Force, and Coast Guard; numerous federal and state public defender offices; and private attorneys throughout the United States, Europe, and Asia. I have examined digital evidence in cases involving allegations of homicide, sexual exploitation, solicitation, sexual assault, unauthorized system access, voyeurism, insider trading, espionage, kidnapping, arson, threats against government officials, and robbery, among other charges. Page 1 of 2 7. As President of Roloff Digital Forensics, I lead a team of digital forensics examiners and support staff who specialize in investigating alleged internet-related crimes and digital evidence obtained from electronic sources. Since founding the firm, we have examined thousands of computer hard drives, mobile devices, and electronic datasets. We regularly advise attorneys on our findings and compare those findings against law enforcement and third-party forensic reports. 8. I've been retained as a Digital Forensic Examiner (DFE) to assist Ms. Anne Taylor, Esq. and the defense team in the Idaho vs. Bryan Kohberger case. 9. I have reviewed the documents titled " DM 11.13 Bubble Format " and " BM 11.13 Bubble Format ", which contain data extracted from mobile devices used by individuals identified as “ DM ” and “ BM, ” respectively. These documents reflect periods of activity on the mobile devices that would require user interaction with the device for them to occur, specifically for the date of November 13, 2022. 10. The documents include artifacts and content demonstrating a variety of user interactions, including: • Incoming and outgoing native text messages • Incoming and outgoing Snapchat message artifacts, indicated by the application identifier “ com.toyopagroup.picaboo " • Voice and video calls conducted via Snapchat and the native phone dialer • Creation, modification, and deletion of multimedia files such as images and videos • Application usage logs showing when specific apps were opened and closed • Internet browsing artifacts and “ cookie ” data showing access to particular websites or internet-based services I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, skill, and belief. 3/26/2025 Josiah P. Roloff, EnCE, CCE, CCLO, CCPA, ССМЕ Date President, Roloff Digital Forensics, LLC Page 2 of 2