Court Filing
Filed: 03/31/2025 11:19:36 Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court By: Deputy Clerk-Waters, Renee LATAH COUNTY PROSECUTOR'S OFFICE WILLIAM W. THOMPSON, JR., ISB No. 2613 PROSECUTING ATTORNEY ASHLEY S. JENNINGS, ISB No. 8491 SENIOR DEPUTY PROSECUTOR Latah County Courthouse 522 S. Adams Street, Ste. 211 Moscow, ID 83843 Phone: (208) 883-2246 paservice@latahcountyid.gov 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 No. CR01-24-31665 Plaintiff, Defendant's Objections to the SEALED STATE'S JURY QUESTIONNAIRE PROPOSALS V. BRYAN C. KOHBERGER, Defendant. COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney, and pursuant to the Court's October 9, 2024, Scheduling Order, submit the following proposals for a jury questionnaire. The State acknowledges and appreciates the Court providing us with a draft Jury Questionnaire. The Court's draft, in fact, parallels closely with the draft questionnaire the State had separately been developing. It is the State's proposal that the Court use its draft questionnaire with the following additions or changes: 1. In " PART I. GENERAL BACKGROUND " the State proposes that the Court add the following questions: STATE'S JURY QUESTIONNAIRE PROPOSALS 1 a. What is your race or ethnic group? b. Please list any civic, political, social, religious or charitable organizations to which you belong. This is covered in # 15 of Court's proposed and Defendant's Proposed. c. Do you have any bumper stickers or decals affixed to your vehicles? Yes No If “ yes, ” please describe: d. What type of books do you read? e. What is the last book you have read or are currently reading? f. Please state hobbies and major recreational activities which are most important to you? 2. In “ PART III. EDUCATION ” the State proposes that the Court add the following: a. Have you or anyone close to you had any experience, training, or involvement in the following areas: (CHECK THOSE THAT APPLY). SELF FAMILY FRIEND NO Police / law enforcement Court system Coroner's office Psychology / mental health Medicine Medical research or testing facility If " yes, ” please explain the experience or involvement for all areas selected. b. If you have you ever had any training or education in law, please describe what kind of training or education you have had: с. If you have any relatives or close friends who have had any training or education in law, what is your relationship to that person? d. How often do you talk to that person about things that relate to law? STATE'S JURY QUESTIONNAIRE PROPOSALS 2 e. What is that person's occupation and where does he / she work? 3. In " PART IV. GENERAL ATTITUDES AND KNOWLEDGE OF THE LAW " the State proposes that the Court add the following: a. The Defendant, victims or witnesses may come from a different racial, ethnic, cultural or social background than you. Would this if true affect your decision making as a juror in this case? Yes No If yes, please explain: b. Have you, or any member of your family, or close friend, ever been involved in a lawsuit? Yes No If yes, please describe the nature of the lawsuit, your role and its outcome: c. Have you, or any member of your family, or close friend ever been witness in a court case? Yes No Please describe your experience being a witness: d. Which best describes how you behave when you believe you were correct about something? (Check One). Always hold my ground Generally hold my ground Generally hold my ground, but can be swayed by forceful arguments Generally am swayed by others Almost always am swayed by others e. The State would recommend that the following be included in 43: Was there anything in your prior jury experience that upset or bothered you to the extent that jury service was an unsatisfactory experience? Yes No If yes, please describe: f. In recent years, Idaho's Legislature revised its law on procedures to be used in invoking the death penalty and how death penalties may be carried out. STATE'S JURY QUESTIONNAIRE PROPOSALS 3 What, if anything, are you aware of regarding the Legislature's actions? What are your personal feelings, if any, regarding the Legislature's revisions? The State would also suggest that the Court consider substituting the following for question 61 appearing on page 16 of the Court's draft: (61). Have you ever discussed this case with anyone? Yes No If " yes, " who did you discuss it with? What did you say? What did they say? Was there any discussion about the guilt or innocence of Bryan Christopher Kohberger? Yes No If yes, what was said? In addition to the above suggestions for inclusion, the State would also suggest that the Court consider adding Dylan Mortensen and Bethany Funke to the list of victims appearing under item 54 at page 14 since they are victims of the burglary charge. With Ms. Batey's departure from the Attorney General's Office, the State is in the process of identifying additional counsel to assist with trial. We anticipate that will be accomplished by the first of next month and we will be able to apprise Court and Counsel at that point. STATE'S JURY QUESTIONNAIRE PROPOSALS 4 In sum, the State concurs with far and away the majority of the Court's proposed jury questionnaire and respectfully submits the above suggestions and recommendations for the Court's consideration. RESPECTFULLY SUBMITTED this 24th day of March 2025. 2224 William W. Thompson, Jr. Prosecuting Attorney STATE'S JURY QUESTIONNAIRE PROPOSALS 5 CERTIFICATE OF DELIVERY I hereby certify that true and correct copies of the STATE'S JURY QUESTIONNAIRE PROPOSALS were served on the following in the manner indicated below: Anne Taylor Mailed Attorney at Law E-filed & Served / E-mailed PO Box 2347 Faxed Coeur D Alene, ID 83816 Hand Delivered Dated this 24th day of March 2025. Se Jacie STATE'S JURY QUESTIONNAIRE PROPOSALS 6