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 CASE NUMBER: CR01-24-31665 Plaintiff, FILED UNDER SEAL V. EXHIBIT 4 IN SUPPORT OF OBJECTION TO STATE'S MOTION IN BRYAN C. KOHBERGER, LIMINE RE: AT & T TIMING ADVANCE Defendant. RECORDS COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby files under seal Exhibit 4 in Support of their Objection to the State's Motion in Limine RE: AT & T Timing Advance Records: FILED UNDER SEAL – EXHIBIT 4 IN SUPPORT OF OBJECTION TO STATE'S MOTION IN LIMINE RE: AT & T TIMING ADVANCE RECORDS Page 1 • Exhibit 4 – Certificate of Authenticity of Records, FBI report from SA Ballance, and screenshot of records provided to Defense DATED this 8 day of April, 2025. 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 8 day of April, 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 FILED UNDER SEAL – EXHIBIT 4 IN SUPPORT OF OBJECTION TO STATE'S MOTION IN LIMINE RE: AT & T TIMING ADVANCE RECORDS Page 2 3891003 SNG 11760 US HWY 1, SUITE 300 NORTH PALM BEACH, FL 33408-3029 (800) 635-6840 (888) 938-4715 (Fax) CERTIFICATE OF AUTHENTICITY OF DOMESTIC RECORDS PURSUANT TO FEDERAL RULES OF EVIDENCE 902 (11) AND 902 (13) I, Stephen Gordon, attest, under penalties of perjury by the laws of the United States of America pursuant to 28 U.S.C. § 1746, that the information contained in this certification is true and correct. I am employed by AT & T, and my title is Director-Compliance. I am qualified to authenticate the records attached hereto because I am familiar with how the records were created, managed, stored, and retrieved. I state that the records attached hereto are true duplicates of the original records in the custody of AT & T. I further state that: a. All records attached to this certificate were made at or near the time of the occurrence of the matter set forth by, or from information transmitted by, a person with knowledge of those matters, they were kept in the ordinary course of the regularly conducted business activity of AT & T, and they were made by AT & T as a regular practice; and b. Such records were generated by AT & T's electronic process or system that produces an accurate result, to wit: 1. The records were copied from electronic device (s), storage medium (s), or file (s) in the custody of AT & T in a manner to ensure that they are true duplicates of the original records; and 2. The process or system is regularly verified by AT & T, and at all times pertinent to the records certified here the process and system functioned properly and normally. I further state that this certification is intended to satisfy Rules 902 (11) and 902 (13) of the Federal Rules of Evidence. April 3, 2024 Stephen Gordon Date Signature DEFENDANT'S EXHIBIT NO. 4 IDENTIFICATION / EVIDENCE CASE NO. CR01-24-31665 DATE: 4/8/25 OFFICIAL RECORD FD-1057 (Rev. 5-8-10) UNCLASSIFIED Document All signatures participants have have been digitally verified signed by a. certified FBI information system. FEDERAL BUREAU OF INVESTIGATION Electronic Communication Title: (U) To document Additional Records from Date: 04/22/2024 AT & T CC: BANKS JENNIFER I From: SALT LAKE CITY Contact: Nicholas J. Ballance, 208-433-3537 Approved By: A / SSRA JACOBSON EDWARD I Drafted By: Nicholas J. Ballance Case ID #: 9A-SU-3683464-CAST (U) Bryan Christopher Kohberger Subject; Moscow Police Department assistance, Ethan Chapin Victim (Deceased); Madison Mogen Victim (Deceased); Xana Kernodle Victim (Deceased); Kaylee Goncalves Victim (Deceased); EXTORTION AGGRAVATED OR OVERT THREATS Synopsis: (U) To document additional certified records received from AT & T Enclosure (s): Enclosed are the following items: 1. (U) AT & T Records Details: On April 3, 2024, Cellular Analysis Survey Team (CAST) Certified Special Agent (SA) Ballance received additional certified records from AT & T. These records will be attached to the 1A section of this serial. UNCLASSIFIED Moscow Idaho (1).zip 5 items Name Last modified File size X 12086611224 Timing Advance.xlsx Apr 1, 2024 270 KB X 12089811278 Timing Advance.xlsx Apr 1, 2024 316 KB X 12089957846 Timing Advance.xlsx Apr 1, 2024 495 KB X Moscow ID LOCDBOR_Geofence.xlsx Apr 1, 2024 1 MB X WAL00505 WAL00523 Timing Advance.xlsx Apr 1, 2024 26 MB