Defendant Response to Discovery Request

Filed: 04/14/2025 14:49:52 Anne Taylor Law, PLLC Fourth Judicial District, Ada County Anne C. Taylor, Attorney at Law Trent Tripple, Clerk of the Court
PO Box 2347 By: Deputy Clerk-Holstine, Shannon 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,
DEFENDANT'S RESPONSE TO STATE'S

V. FIRST SUPPLEMENTAL REQUEST

FOR DISCOVERY

BRYAN C. KOHBERGER,

RE: TRANSFER OF TEST MATERIALS

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and hereby submits their response to the State's First Supplemental Request for Discovery as required by Idaho Criminal Rule 16.

DEFENDANT'S RESPONSE TO STATE'S FIRST SUPPLEMENTAL REQUEST

FOR DISCOVERY DISCLOSURE RE: TRANSFER OF TEST MATERIALS Page-1

Mr. Kohberger first responds that he has complied with discovery requests for experts as provided in the Idaho Criminal Rules. This specific request for additional materials related to ICR 16 (c) came for the first time on April 2, 2025. Mr. Kohberger responds specifically to part II. 1. of the State's Request:
Upon agreement from the Latah County Prosecuting Attorney's Office, the requested test materials will be provided between doctors directly. Dr. Orr will provide testing data to the State's expert, Dr. Christensen, who is a licensed psychologist. This method of disclosure is in compliance with the APA Ethics Code Standard 9.04 and 9.11. Dr. Orr must adhere to these ethical standards in releasing test materials (including protocols, test items, etc.) Dr. Orr will work directly with Dr. Christensen to transfer the requested materials once contact information has been exchanged.

DATED this 10 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 11 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
DEFENDANT'S RESPONSE TO STATE'S FIRST SUPPLEMENTAL REQUEST

FOR DISCOVERY DISCLOSURE RE: TRANSFER OF TEST MATERIALS Page-2