Court Filing
Filed: 06/27/2025 10:22:05 Fourth Judicial District, Ada County Anne Taylor Law, PLLC Trent Tripple, Clerk of the Court Anne C. Taylor, Attorney at Law 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, Plaintiff, CASE NUMBER CR01-24-31665 V. 2nd NOTICE OF FILING DEFENDANT'S BRYAN C. KOHBERGER, ADDITIONS / OBJECTIONS TO THE JUROR QUESTIONNAIRE UNDER Defendant. SEAL COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby submits to the Court the Defendant's additional objections and additions to the Jury Questionnaire received in court on June 18th, 2025. 2nd NOTICE OF FILING DEFENDANT'S ADDITIONS / OBJECTIONS TO THE JUROR QUESTIONNAIRE UNDER SEAL Page-1 V. ATTITUDE REGARDING THE DEATH PENALTY Question 50, the Defense requests that the question include the below additional language: " If the defendant is found guilty of first-degree murder, it is possible that the jury will have to decide whether or not to impose life without parole or the death penalty. Before the jury.... " Question 53, the Defense requests that the question include the below additional language in section d. and g. " d. While I generally favor the death penalty, I can vote against imposing it if the State has not met its burden of proof that the death penalty should be imposed based on the facts, or if mitigating evidence presented convinces me life without parole is approriate, law, and Judge's instructions given in the case. ” “ g. While I generally oppose the death penalty, I can vote to impose it if the State has met its burden of proof that the death penalty should be imposed based on the facts, no mitigating evidence convinces me life without parole is appropriate, law and Judge's instructions given in the case. " Question 55, the Defense requests that the question include the following additional attorneys: • Ingrid Batey • Madison Allen Question 61, the Defense objects-The coverage of this case has been pervasive. It is in the media every day. There has been a lot of misinformation throughout the pendency and any prospective juror that has read, heard or watched the coverage cannot set aside what they have read, seen or heard. Bias runs deep and strong depending on many potential connections to the case or to stories read seen or heard. The change of venue was granted for this reason. Question 62, the Defense requests that the question be reworded to include the below additional language: " If you do not hear evidence during trial matching what you have heard from media or other sources prior to the trial (or hear evidence that differs from what you heard from sources outside of trial), how will that impact the evidence presented during trial when deciding about the case as a juror? ” DATED this 27 day of June, 2025. an ANNE C. TAYLOR ANNE TAYLOR LAW, PLLC 2nd NOTICE OF FILING DEFENDANT'S ADDITIONS / OBJECTIONS TO THE JUROR QUESTIONNAIRE UNDER SEAL Page-2 CERTIFICATE OF DELIVERY I hereby certify that a true and correct copy of the foregoing was personally served as indicated below on the 27 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 Du l 2nd NOTICE OF FILING DEFENDANT'S ADDITIONS / OBJECTIONS TO THE JUROR QUESTIONNAIRE UNDER SEAL Page-3