Motion for Independent Analysis of Evidence

Filed: 06/06/2025 16:59:53 Anne Taylor Law, PLLC Fourth Judicial District, Ada County Anne C. Taylor, Attorney at Law Trent Tripple, Clerk of the Court
By: Deputy Clerk-Waters, Renee 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,
MOTION FOR INDEPENDENT

V. ANALYSIS OF EVIDENCE

BRYAN C. KOHBERGER,

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby requests the Court for an Order pursuant to I.C.R. 16 (b) (4) and (5), allowing an independent test of the evidence which relates to the above-entitled matter and is in the possession of Moscow Police Department. Specifically, the Acer Laptop and Samsung phone belonging to Bryan Kohberger.

MOTION FOR INDEPENDENT ANALYSIS OF EVIDENCE Page-1

The items requested should have a continued chain of custody from Moscow Police Department to defense expert, █████████████ █████████████ The items shall be hand delivered or sent via Fed Ex shipping to █████████████ █████████████ and returned directly to Moscow Police Department through Fed Ex shipping. If either item of evidence is damaged or lost during the transportation of such items, the Defense will stipulate to extractions done by the State and / or photographs of the items.

Further, during such time as the items of evidence are in the possession or under the care and control of the Defense, all items will be handled with care while preserving the items and maintaining chain of custody This motion is made on the grounds that Mr. Kohberger has a Constitutional Right to confront the State's evidence, conduct an independent investigation and prepare and present his defense in his jury trial.

DATED this 6 day of June, 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 6 day of June, 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 MOTION FOR INDEPENDENT ANALYSIS OF EVIDENCE Page-2