Expert Witness Disclosure

Electronically Filed
9/5/2024 2:48 PM

Second Judicial District, Latah County Julie Fry, Clerk of the Court Anne Taylor Law, PLLC By: Tamzen Reeves, Deputy Clerk Anne C. Taylor, Attorney at Law
Bar Number: 5836 PO Box 2347 Coeur d'Alene, Idaho 83816
Phone: (208) 512-9611 iCourt Email: info@annetaylorlaw.com Jay W. Logsdon, Interim Public Defender Kootenai County Public Defender's Office PO Box 9000 Coeur d'Alene, Idaho 83816
Phone: (208)446-1700 Elisa G. Massoth, PLLC Attorney at Law P.O. Box 1003 Payette, Idaho 83661
Phone: (208) 642-3797; Fax: (208)642-3799 Assigned Attorney:
Anne C. Taylor, Public Defender, Bar Number: 5836 Jay W. Logsdon, Chief Deputy Public Defender, Bar Number: 8759 Elisa G. Massoth, Attorney at Law, Bar Number: 5647
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF LATAН

STATE OF IDAHO CASE NUMBER CR29-22-2805

Plaintiff,
EXPERT WITNESS DISCLOSURE

V.

BRYAN C. KOHBERGER,

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, and pursuant to Idaho Criminal Rule 16, makes the following expert witness disclosures.

1. Barbara C. Wolf, M.D.

9601 Mid Summer Lane Leesburg, FL 34788
EXPERT WITNESS DISCLOSURE PAGE 1

Dr. Wolf is expected to testify to the findings outlined in her affidavit filed with the court on September 5, 2024 in the Defendant's Motion to Strike State's Notice of Intent to Seek Death Penalty on Grounds of Vagueness in Balancing Aggravators and Mitigators.

Dr. Wolf's Curriculum Vitae is attached hereto.

2. Aliza Plener Cover University of Idaho, College of Law 501 Front Street, Boise, ID 83702 A complete statement of all opinions to be expressed and the basis and reasons therefore are contained in Ms. Cover's law article Narrowing Death Eligibility in
Idaho: An Empirical and Constitutional Analysis, 57 IDAHO L. REV. 559 (2022).

Ms. Cover's Curriculum Vitae is attached hereto.

DATED this 5 day of September, 2024.

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 5 day of September, 2024 addressed to:
Latah County Prosecuting Attorney –via Email: paservice@latahcountyid.gov Elisa Massoth – via Email: legalassistant@kmrs.net Dul 1
EXPERT WITNESS DISCLOSURE PAGE 2

CURRICULUM VITAE

Barbara C. Wolf, M.D.

Office of the Districts 5 & 24 Medical Examiner 809 Pine Street Leesburg, FL 34748
Phone: ██████████████
Fax: ██████████████
www.medicusforensics.com e-mail: ███████████████████████████████
EDUCATION

College / Medical School: Boston University Six Year Program in Liberal Arts and Medical Education, Boston University School of Medicine, Boston, MA 1978 Α.Β., 1980 M.D.

POSTGRADUATE TRAINING

Residency: Anatomic Pathology, Mallory Institute of Pathology and Boston Veterans Administration Hospital, Boston, MA 1980-1982 Anatomic Pathology, New England Deaconess Hospital, Boston, MA and Lahey Clinic Medical Center, Burlington, ΜΑ 1982-1984 Clinical Pathology (Hematology), New England Deaconess Hospital, Boston, MA 4 / 1984-6 / 1984 1

Fellowship: Hematopathology, Mallory Institute of Pathology, under the direction of Dr. Richard S. Neiman, 1984-1985 LICENSURE State of Florida (# ME 83748) Commonwealth of Massachusetts (# 53067-inactive) State of New York (# 1821841-inactive) State of New Jersey (# 61810-inactive) CERTIFICATIONS American Board of Pathology, Forensic Pathology, May 31, 1994 American Board of Pathology, Hematology, May 26, 1987 American Board of Pathology, Anatomic Pathology, November 17, 1984 National Board of Medical Examiners, July 1981
PROFESSIONAL POSITIONS

Oct. 2018-present Interim District Medical Examiner, District 24, State of Florida, serving Seminole County July, 2011-present District Medical Examiner, District 5, State of Florida Oct. 2008-July, 2011 Interim District Medical Examiner, District 5, State of Florida 2007-present Chief Medical Examiner, District 5, State of Florida, serving Marion, Lake, Sumter, Hernando and Citrus counties Nov. 2004-Oct. 2007 Associate Medical Examiner, District 21, State of Florida, serving Lee, Hendry and Glades Counties 2

Oct. 2001-Oct. 2004 Deputy Chief Medical Examiner, District 15, State of Florida, serving Palm Beach County 1999-2001 Director of Forensic Medicine, Medicolegal Investigation Unit, New York State Police 1997-2001 Chief Medical Examiner, Rensselaer County, NY 1991-2001 Coroner's Pathologist, Albany, Clinton, Columbia, Delaware, Dutchess, Essex, Franklin, Fulton, Greene, Herkimer, Montgomery, Oneida, Orange, Saratoga, Schenectady, Schohaire, St. Lawrence, Ulster, Warren and Washington Counties 1996-1998 Staff Pathologist, Albany Medical Center (part-time), Albany, NY 1991-1996 Director of Department of Anatomic Pathology, Albany Medical Center, Albany, NY 1990-1995 Director of Hematopathology Division and Hematopathology Fellowship Program, Albany Medical Center, Albany, NY 1992-1993 Director, Autopsy Service, Albany Medical Center, Albany,
NY

1990 Director of Hematopathology Division, Mallory Institute of Pathology, Boston, MA 1989 Assistant Director, Mallory Institute of Pathology, in charge of educational activities 1986-1989 Staff Pathologist, Mallory Institute of Pathology and Research Pathologist, New England Deaconess Hospital, Boston, MA 1985-1986 Staff Pathologist, New England Deaconess Hospital, Boston, MA 3

ACADEMIC APPOINTMENTS

2010-present Adjunct Professor of Pathology, University of Central Florida College of Medicine, Orlando, FL 1998-2001 Adjunct Professor of Pathology and Laboratory Medicine, Albany Medical College, Albany, NY 1996-1998 Professor of Pathology and Laboratory Medicine, Albany Medical College, Albany, NY 1990-1996 Associate Professor of Pathology and Laboratory Medicine, Albany Medical College, Albany, NY 1990 Associate Professor of Pathology, Boston University School of Medicine, Boston, MA 1986-1990 Assistant Professor of Pathology, Boston University School of Medicine, Boston, MA 1985-1986 Instructor in Pathology, Harvard Medical School, Boston, ΜΑ 1984-1986 Instructor in Pathology and Biology of Disease, Boston University School of Medicine, Boston, MA 1982-1984 Clinical Fellow in Pathology, Harvard Medical School, Boston, MA 1980-1982 Instructor in Pathology and Biology of Disease, Boston University School of Medicine, Boston, ΜΑ
SCIENTIFIC APPOINTMENTS AND COMMITTEES

2017-present Board of Directors, National Association of Medical Examiners 4

2017-present National Association of Medical Examiners International Relations Committee 2016-present Chair, National Association of Medical Examiners Inspection and Accreditation Committee 2016-present National Association of Medical Examiners Strategic Planning Committee 2015-present Florida Medical Examiners Commission 2015-present Florida Sheriff's Association Cold Case Advisory Commission 2015 Co-Chair, National Association of Medical Examiners Standards, Inspection and Accreditation Committee 2015 National Association of Medical Examiners Nominating Committee 2015 President, Florida Association of Medical Examiners 2013-2015 President Elect, Florida Association of Medical Examiners 2012-present Staff member, International Firearms Specialist Academy 2012-2014 Florida Chapter, American Professional Society on the Abuse of Children 2012-2014 Co-Chair, Florida State Child Abuse Death Review Committee 2011-present Chair, Forensic Medicine Committee, Florida Division, International Association for Identification 2011-present National Association of Medical Examiners, Inspection and Accreditation Committee 2011-present National Association of Medical Examiners Certified Accreditation Inspector 2011-2014 Florida Coalition Against Domestic Violence 2008-present District 5 Child Death Review Team, FL 5

2008-present Faculty Member, National District Attorneys Association 2008-present Instructor, Practical Homicide Investigation ® 2005-present Consultant, Royal Barbados Police Force 2005-2007 District 21 Child Death Review Team, FL 2004-2014 Florida State Child Abuse Death Review Committee 2004 Palm Beach County Fetal and Infant Mortality Review Team, FL 2004 Palm Beach County Child Fatality Review Team, FL 2001-present Consultant in Forensic Pathology, Medicolegal Investigation Unit, New York State Police 1993-2001 Albany County Task Force on Child and Sexual Abuse, Albany, NY 1998-2001 Warren and Washington Counties Child Death Review Committee, NY 1994-2001 Albany County Child Death Review Committee, Albany, NY 1997-2001 Montgomery County Child Death Review Committee, NY 1998-2001 Dutchess County Child Death Review Committee, NY 1991-1995 Pathology Chair, Eastern Cooperative Oncology Group 1989-1991 Pathology Co-chair, Eastern Cooperative Oncology Group 1987-1995 Director, Pathology Coordinating Office and Central Histology Laboratory, Eastern Cooperative Oncology Group 1991-1995 Faculty Senate, Albany Medical Center, Albany, NY 1991-1995 Academic Governing Council, Albany Medical Center, Albany, NY 6

1991-1995 Operating Room Committee, Albany Medical Center, Albany, NY 1991-1995 Executive Committee, Albany Medical Center, Albany, NY 1991-1995 Infection Control Committee, Albany Medical Center, Albany, NY 1991-1994 Chair, Surgical Review Committee, Albany Medical Center 1987-1989 Pathology Chair, National Gastrointestinal Cancer Consortium 1986-1990 Review Pathologist, National Surgical Adjuvant Project for Breast and Bowel Cancer 1986-1989 Chair, Head and Neck Pathology Subcommittee, Eastern Cooperative Oncology Group 1985-1995 Hematopathology Subcommittee, Eastern Cooperative Oncology Group 1989-1990 Quality Assurance Committee, Mallory Institute of Pathology, Boston, MA 1987-1990 Tumor Committee, Boston City Hospital, Boston, MA
GOVERNMENT APPOINTMENTS

1993-2001 New York State Commission on Quality of Care for the Mentally Disabled Medical Review Board 1994-2001 New York State Commission on Corrections Medical Review Board 2015-present Florida Medical Examiners Commission 7

HOSPITAL APPOINTMENTS

1990-1998 Pathologist, Albany Medical Center, Albany, NY 1987-1990 Associate Scientist, Research Staff, New England Deaconess Hospital, Boston, MA 1986-1990 Pathologist, Mallory Institute of Pathology, Boston City and University Hospitals, Boston, MA 1985-1986 Pathologist, New England Deaconess Hospital, Boston, MA 1985-1986 Pathologist, New England Baptist Hospital, Boston, MA
RESEARCH ACTIVITIES AND GRANTS

1982-1983 American Cancer Society Regular Clinical Fellowship 1984-1986 American Cancer Society Junior Faculty Fellowship 1986 Aid for Cancer Research Award 1986 Biochemical Research Support Grant, “ Non-Hodgkin's Lymphomas of the Gastrointestinal Tract ”, NIH 1986-1990 NIH NCI POI CA4470405 “ The Pathology of Colorectal Cancer " (Glenn Steele, Jr., M.D., Principal Investigator) 6.1.875.31.90 1986-1995 NCI CA 2111514 “ The Eastern Cooperative Oncology Group " (Douglass Tormey, M.D., Ph.D., Principal Investigator) 1991-1995 NIH NCI R01 CA5551801 “ AIDS Related Lymphomas Clinical and Biologic Studies ” (Leo Gordon, M.D., Principal Investigator) 7.16.917.15.94 8

STUDY SECTIONS

1992 NIH / NCI Specialized Programs of Research Excellence in Breast Cancer 1993 NIH / NCI RFA for Breast Cancer Tumor Registry
EDITORIAL REVIEW BOARDS

1989 Human Pathology (guest editor) 1989-1994 American Journal of Clinical Pathology 2003-2015 American Journal of Forensic Medicine and Pathology 2004-2006 Journal of Forensic Sciences (guest editor) 2007-2020 Journal of Forensic Sciences
VISITING PROFESSORSHIPS

November, 1990 Hartford Hospital, Hartford, CT October, 1992 Melrose-Wakefield Hospital, Melrose, MA October, 1992 Nassau County Medical Center, NY April, 1994 Bay State Medical Center, Springfield, MA 9

ויים AWARDS AND HONORS

1974 Presidential Scholar
College: National Merit Scholarship, 1974 Graduation with Honors (Summa Cum Laude), 1978
Medical School: Elizabeth K. Moyer Award for Excellence in Anatomy, 1977 Graduation with Honors (Magna Cum Laude), 1980 Dean Eleanor Tyler Memorial Award for Excellence in Six Year Program in Liberal Arts and Medical Education, 1980 American Medical Women's Association Achievement Award, 1980 ויייייי 2007-2010, 2015 Consumer Research Council America's Top Pathologists (Forensic Pathology) 2017 National Association of Medical Examiners STAR Award (Service, Time, Attitude & Respect) 2019 National Association of Medical Examiners Setting the Standards Award 2020 American Academy of Forensic Sciences Award of Merit, Journal of Forensic Sciences Editorial Board, 2007-2020
PROFESSIONAL SOCIETIES

1978-present Phi Beta Kappa 1979-present Alpha Omega Alpha 1988-1995 Society for Hematopathology 10

1987-present American Society of Clinical Pathologists 1988-present College of American Pathologists 1986-1995 New England Society of Pathologists 1987-1998 US / Canadian Academy of Pathology 1989-1998 Arthur Purdy Stout Society of Surgical Pathologists 1990-1995 European Association for Hematopathology 1991-present Association of Directors of Anatomic and Surgical Pathology (Emeritus member since 1995) 1991-1995 New England Cancer Society 1992-1995 American Society of Clinical Oncology 1994-2001 New York State Association of County Coroners and Medical Examiners 1994-present National Associations of Medical Examiners (Fellow since 2008) 1993-present American Academy of Forensic Sciences (Fellow since 2004) 2004-present International Association for Identification 2001-present Florida Association of Medical Examiners 2006-present Florida Medical Association 2007-2019 Lake-Sumter Medical Society 2008-2020 Marion County Medical Society 2010-2019 American Professional Society on the Abuse of Children 2010-2019 Florida Chapter, American Professional Society on the Abuse of Children 2018-2020 Seminole County Medical Society 11

2020-present Physicians ' Society of Central Florida
WORKSHOPS AND INVITED LECTURES

1990-1995 Course Director, United States / Canadian Academy of Pathology short course, “ Disorders of the Spleen ".

1991 Propp / Olson Symposium, Albany Medical College, “ New Immunohistologic and Molecular Techniques in the Diagnosis of Lymphoproliferative Disorders ”, Albany, NY 1992 National Society for Histotechnology, “ Topics in Forensic Pathology ", Albany, NY 1992-1995 Workshop Director, American Society of Clinical Pathologists Meeting, “ Application of DNA Ploidy and Cell Cycle Analysis in Surgical Pathology ” 1993 New York State Association of County Coroners and Medical Examiners, “ Acquired Immunodeficiency Syndrome, " Lake Placid, NY 1993 New York State Association of County Coroners and Medical Examiners, “ Medicolegal Investigation of Child Abuse " 1993 New York State Association of Public Health Laboratories, " Disorders of the Spleen " 1993 New York State Police Academy Major Crimes Seminar, " Child Abuse and Sex Related Deaths, ” Albany, NY 1993-1997 Moderator of Child Abuse seminar required for licensure for New York State physicians 1994 New York State Police Academy Sex Offense Seminar, " Sex Related Deaths, " Albany, NY 1994 New York State Association of County Coroners and Medical Examiners, “ Transportation Fatalities " 12

1994 Marist College Symposium on Forensic Sciences, “ Child Abuse " and " Traffic Fatalities, ” Poughkeepsie, NY 1994 State University of New York, University of Albany, " Forensic Pathology, " Albany, NY 1995 Crime Scene and Evidence Technician Course, Capital Region Police Departments, Albany, NY 1995 Annual Tri-State International Association for Identification Educational Conference and Training Seminar, Albany, NY 1995, 1997 Course Director, United States / Canadian Academy of Pathology short course, “ Forensic Sciences and the Pathologist " 1995 United States / Canadian Academy of Pathology Specialty Conference, Forensic Medicine: Past and Future; DNA profiling, Toronto, Canada 1995 New Jersey Medical Examiner Office “ AIDS-Related Deaths, " Newark, NJ 1995 Colby College Forensic Sciences Seminar, “ Forensic Serology, " Waterville, ME 1995 Evidence Collection / Forensics Regional Information Sharing Conference, “ The Changing Role of the Medical Examiner at the Scene, ” Albany, NY 1995 New York State Police Henry F. Williams Homicide Seminar, “ DNA in Criminal Investigations, " Albany, NY 1995 Conference Co-Director, Illinois County Coroners ' Association 1995 Quinnipiac School of Law, “ Forensic Evidence in Sexual Assaults and Other Crimes, " New Haven, CT 1995 Commission on Security and Cooperation in Europe (U.S.

Congress Helsinki Commission), “ Mass Graves and Other Atrocities in Bosnia, ” Washington, DC 1996 University of New Haven Forensic Science Program Arnold 13

Markle Symposium, “ Post-mortem Changes and Time of Death, " New Haven, CT 1996 Conference Co-Director, Illinois County Coroners ' Association 1996 New York State Association of County Coroners and Medical Examiners, “ Time of Death, Exhumations and
DNA "

1996 State University of New York Conference Telemedicine Reality and Virtual Realty II, “ New Developments in the Forensic Sciences, ” Syracuse, NY 1996 New York State Attorney General's Inspectors, “ Investigation of Deaths and Injuries, ” Albany, NY 1996 New York State Division of Criminal Justice Service Crime Scene Course, “ Death Investigation, ” Albany, NY 1996 Philadelphia Center for Legal Education Conferences on Expert Witnesses, Bermuda 1996 Florida Inspector General's Training Workshop, “ Forensic Pathology, ", Orlando FL 1997 Crime Scene and Evidence Technician Course, Capital Region Police Departments, Albany, NY 1997 Marist College Basic Crime Scene Evidence Technician Course " Forensic Pathology Overview ” and “ Time of Death, " Poughkeepsie, NY 1997 Washington County Mandated Reporter's Conference, " Child Abuse ", NY 1997-2001 Capital District Forensic Officers ' Group Course, “ Death Investigation and DNA, ” Albany, NY 1997 Massachusetts Academy of Trial Attorneys, “ The Use of Expert Witnesses, " Boston, MA 1997 Indiana State Coroner's Association Seminar Lecturer, Evansville, IN 14

1998 New York State Police Major Crimes Seminar, “ Forensic Pathology, ", Albany NY 1998 National Association of Criminal Defense Lawyers, " Forensic Pathology: New Tools for the Defense, ” Santa Monica, CA 1998 Annual Tri-State International Association for Identification Educational Conference and Training Seminar, Albany, NY 1998 New York State Attorney General's Inspectors, “ Investigation of Deaths and Injuries, ” Albany, NY 1998 Crime Scene and Evidence Technician Course, Capital Region Police Departments, Albany, NY 1998 SEAK National Expert Witness and Litigation Seminar, " Collection and Control of Trace Evidence, ” Hyannis, MA 1998 New York State Defender's Association Annual Conference, " Forensic Pathology: New Tools for the Defense, " Corning, NY 1998-2003 New York State Police Henry F. Williams Homicide Seminar, " Child Deaths, ” Albany, NY 1998 MAGLOCLEN Information Sharing Conference, “ The Changing Role of Forensic Science ", Albany, NY 1998 New York State Correctional Health Care Symposium, “ The Sudden In-Custody Death Syndrome, " Saratoga, NY 1999 New York State Sexual Assault Nurse Examiner Association Symposium, " Patterns of Injury, ” Albany, NY 1999 New York State Association of County Coroners and Medical Examiners Spring Conference, “ The Crime Scene and Trace Evidence, " Saranac Lake, NY 1999 Indiana State Coroners ' Association Conference, “ Child Abuse, " Evansville, IN 15

1999 New York Prosecutors Training Institute Seminar, “ Use of the Medical Examiner to Enhance Domestic Violence Prosecution, " Syracuse, NY 1999 New York State Association of County Coroners and Medical Examiners Fall Conference, “ Gunshot Wounds, " Albany, NY 2000 Warren & Washington Counties Multidisciplinary Team Conference, " Child Abuse Injuries and Photographic Documentation, " Glens Falls, NY 2001 2000 New York State Association of