Witness and Exhibit List for Motions Hearing

Filed: 01/09/2025 Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court Anne Taylor Law, PLLC By: Deputy Clerk-Waters, Renee 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 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 WITNESS AND

V. EXHIBIT LIST FOR MOTION (S)

HEARING ON 1/23/25

BRYAN C. KOHBERGER,

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorneys of record, will call the following witness (es) and intends on offering the following as evidence at the Motion (s) hearing scheduled for January 23-24, 2025, although not necessarily in the same order as listed.

DEFENDANT'S WITNESS AND EXHIBIT LIST

FOR MOTION (S) HEARING ON 1/23/25 PAGE 1

Witnesses:
1. Captain Dustin Blaker a. Captain Blaker's anticipated testimony relates to items that he relied upon in his Affidavit for Probable Cause for Arrest and Search Warrants as well as video footage identified during the course of the investigation.

2. Detective Lawrence Mowery a. Detective Mowery's anticipated testimony relates to items to what he relied on to prepare his Affidavits for Search Warrants, service of warrants, warrant inventories, and warrant returns, as well as video footage identified during the course of the investigation. Additionally, Detective is anticipated to testify about what he relied up on in his CASTviz Process.

3. Detective Cpl. Brett Payne a. Detective Brett Payne's anticipated testimony relates to items that he relied upon in his Affidavit for Probable Cause for Arrest and Search Warrants, service of warrants, warrant inventories, and warrant returns as well as video footage identified during the course of the investigation.

4. Matthew Gamette a. Mr. Gamette's anticipated testimony relates to the report and emails with the Idaho State Police Forensics Lab and Othram. He will be asked about policy and protocol.

5. Rylene Nowlin a. Ms. Nowlin's anticipated testimony relates to Idaho State Police Forensics Lab and its protocol; testing performed in the lab and work with Othram and the FBI as detailed in materials provided in discovery. She will testify about standards and policy.

6. Mr. Kohberger has previously filed exhibits and Affidavits with his pleadings. He will utilize those items in his hearing.

Expert Witnesses:
1. Dr. Leah Larkin a. Dr. Larkin is expected to testify about the IGG materials and in understanding how the State identified Mr. Kohberger as a suspect in the case. Dr. Larkin will testify about terms of use for various Genetic Genealogy databases as well as Department of Justice (DOJ) policy. She is expected to discuss the FBI search being outside of both database policy and DOJ policy.

2. Daniel Hellwig a. Mr. Hellwig is expected to testify consistent with the attached summary below.

Exhibit Disclosures:
Exhibit A: Powerpoint by Dr. Leah Larkin and her Curriculum Vitae.

DEFENDANT'S WITNESS AND EXHIBIT LIST

FOR MOTION (S) HEARING ON 1/23/25 PAGE 2

Exhibit B: Daniel Hellwig Curriculum Vitae and summary of his anticipated testimony.

We can provide a copy of Intermountain Forensics ' Accreditation upon request.

DATED this 9 day of January, 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 9 day of January, 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 Jeffery Nye, Deputy Attorney General – via Email: Jeff.nye@ag.idaho.gov Dul
DEFENDANT'S WITNESS AND EXHIBIT LIST

FOR MOTION (S) HEARING ON 1/23/25 PAGE 3

Genetic Genealogy An Overview
DEFENDANT'S

EXHIBIT NO. A

IDENTIFICATION / EVIDENCE

CCR01-24-31665

DATE: 1/9/25

How genetic genealogy works How forensic genetic genealogy differs Work products of GG / FGG

How genetic genealogy works How forensic genetic genealogy differs Work products of GG / FGG

There are three main " types " of DNA Mitochondrial DNA (mtDNA) Grandparents Great-Grandparents 2nd-Great-Grandparents 0 of 4 0 of 8 0 of 16 Y chromosome DNA (yDNA) 2nd Great Grandfather Great Grandfather 2nd Great Grandmother Paternal Grandfather Autosomal DNA (atDNA) 2nd Great Grandfather Great Grandmother 2nd Great Grandmother Father 2nd Great Grandfather Great Grandfather 2nd Great Grandmother Paternal Grandmother 2nd Great Grandfather Great Grandmother 2nd Great Grandmother
YOU

2nd Great Grandfather Great Grandfather 2nd Great Grandmother Maternal Grandfather 2nd Great Grandfather Great Grandmother 2nd Great Grandmother Mother 2nd Great Grandfather Great Grandfather 2nd Great Grandmother Maternal Grandmother 2nd Great Grandfather Great Grandmother 2nd Great Grandmother Parents Grandparents Great-Grandparents 2nd-Great-Grandparents 0 of 2 0 of 4 0 of 8 cof 116
Image: https://dnapainter.com/tree

Genetic genealogy begins with a DNA " kit ”
• Saliva or cheek swab
• Collects ± 100 µg DNA
• Mailed back to lab for analysis
Image: https://www.dnagenotek.com/US/products/collection-human/oragene-discover/600-series/OGR-600.html

The scientific test is called a “ microarray "
• Designed for biomedical research (unlike CODIS STRs)
• Targets ≥600,000 DNA SNP markers (single nucleotide polymorphism)
CTATGACO

GGGTGGGATA

• ≈100-200 ng DNA is best CAGICT
TCATATGACCCTT

illumina
Image: https://www.illumina.com/techniques/popular-applications/genotyping.html

Your person of interest has a family tree Great Great Great Great Great Great Great Great Grand - ==== Grand- Grand - == Grand- Grand - ==== Grand- Grand - === Grandfather mother father mother father mother father mother Grand- Grand- Grand- Grandfather = mother father mother Father == Mother Person of Interest

Your person of interest has DNA matches Great Great Great Great Great Great Great Great Grand - === Grand- Grand - == Grand- Grand - ==== Grand- Grand - ==== Grandfather mother father mother father mother father mother Grand- Grand- Grand- Grandfather mother father mother
DNA

Father ==== Mother Match Person
DNA DNA

of Match Match Interest
DNA DNA DNA DNA

Match Match Match Match

The database lists the DNA matches
• Shared DNA is measured in All (6023) Paternal (0) Maternal (0) Both (0) Filter Sort by Export CSV " centimorgans " (cM) Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided mtDNA: N / A 2nd Cousin-4th Cousin 72 CM 50 CM No Match
Link on Family Tree Match date: July 20 2023 Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
• Match lists sorted by cM, Not Provided Y-DNA: N / A 2nd Cousin-4th Cousin 56 CM 49 CM No Match mtDNA: N / A Link on Family Tree Match date: July 20 2023 not by biological Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided mtDNA: N / A 2nd Cousin-4th Cousin 56 CM 37 cM No Match relationship Link on Family Tree Match date: July 20 2023
MTDNA PLUS Y-DNA67

Ancestral Surnames | View Details Haplogroup Relationship Range Shared DNA Longest Block X Match
Y-DNA: 2nd Cousin-4th Cousin 54 CM 47 CM No Match mtDNA: Link on Family Tree Match date: July 20 2023 منم Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided Y-DNA: N / A 2nd Cousin-4th Cousin 50 CM 50 CM No Match mtDNA: N / A Link on Family Tree Ma English
Image: https://www.familytreedna.com/my/familyfinder/matches/detail-view

Relationship is loosely correlated to cM total Most distant common ancestors Assuming no pedigree collapse or endogamy, and that you're related in just one way, the Half GG-Aunt / Great furthest back you might need to go to find common ancestors for a match of 72cM is Uncle Great-Grandparent Aunt 8th-Great-Grandparent level or generation 11 on your pedigree chart.

208 887 4 485-1486 The connection may be closer.

103-284 186 Relationship probabilities (based on stats from The DNA Geek) Click on any relationship to view a histogram Enter the total n Half Great-Aunt Great-Aunt / New: View these relationships in a tree Half 1C2R / Uncle Grandparent Uncle 10 125 431 1754 850 2 16-269 184-668 984-2462 330-1467 33- 32% Half 3C 3C1R Half 2C2R 2C3R 72 28% 3C Half 2C1R 2C2R Half 1C3R Half 1C1R Half Aunt / Aunt / Uncle 1C1R Half 2C1R Uncle Parent 20 66 224 871 3485 1741 433 1 0-190 62-469 492-1315 2376-3720 1201-2282 102-980 14- 19% Half 2C 2C1R Half 1C2R 1C3R Person 15% 4C Half 3C1R 3C2R Half 3C Half 2C Half 1C Half Sibling Sibling 1C 2C 3 48 120 449 1759 2613 of 866 229 7 0-168 10-325 156-979 1160-2436 1613-3488 96-1397 41-592 0- Interest 4% 4C3R † 5C2R † 5C3R † 6C † 6C1R †
6C2R † 7C † 7C1R † 8C † 5C 4C1R

Half Niece / Niece / Nephew Child Half 3C1R Half 2C1R Half 1C1R Nephew 1C1R 2C1R 30 37 66 224 1740 3487 433 122 4 5C1R Half 3C2R 4C2R 3C3R 0-139 0-190 62-469 871 1201-2282 2376-3720 102-980 14-353 0- 492-1315 2% Half GG-Niece / Nephew † Half Great- Great-Niece / Half GG-Aunt / Uncle † 2C Half 1C1R 1C2R Half 3C2R Half 2C2R Half 1C2R Niece / Nephew Nephew Grandchild 1C2R 2C2R 30 27 48 125 431 850 1754 221 71 3 0-78 0-144 16-269 184-668 330-1467 984-2462 33-471 0-244 0- † this relationship has a positive probability for 72cM in thednageek's table of probabilities, but falls outside the bounds of the recorded cM range (99th percentile) Half GG-Niece / Great-Great- Great- Half 1C3R Nephew Niece / Nephew Grandchild 1C3R 2C3R 3C3R 4C3R 5C3R Half 3C3R Half 2C3R 60 208 117 51 27 19 13 0-120 420 887 25-238 0-154 0-98 0-60 0-30 103-284 186-713 485-1486
Images: https://dnapainter.com/tools/sharedcmv4

The database lists the DNA matches
• Many matches do not post All (6023) Paternal (0) Maternal (0) Both (0) Filter ↑ ↓ Sort by Export CSV trees Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided mtDNA: N / A 2nd Cousin-4th Cousin 72 CM 50 CM No Match
Link on Family Tree Match date: July 20 2023 Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
• Some matches use aliases or Not Provided Y-DNA: N / A 2nd Cousin-4th Cousin 56 CM 49 CM No Match mtDNA: N / A Link on Family Tree Match date: July 20 2023 have common names Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided mtDNA: N / A 2nd Cousin-4th Cousin 56 CM 37 cM No Match
Link on Family Tree Match date: July 20 2023
MTDNA PLUS Y-DNA67

Ancestral Surnames | View Details Haplogroup Relationship Range Shared DNA Longest Block X Match
Y-DNA: 2nd Cousin-4th Cousin 54 CM 47 CM No Match mtDNA: Link on Family Tree Match date: July 20 2023 منم Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided Y-DNA: N / A 2nd Cousin-4th Cousin 50 CM 50 CM No Match mtDNA: N / A Link on Family Tree Ma English
Image: https://www.familytreedna.com/my/familyfinder/matches/detail-view

We build a research tree for the matches Match 1 Match 2

We are looking for common ancestors John Smith Mary Jones Match 1 Match 2 John Smith Mary Jones

We trace descendant lines to find candidates John Mary Smith Jones 500
CM

175 225 275 150
CM

We trace descendant lines to find candidates John Mary Smith Jones 120
CM

50 75 100
CM CM CM

50
CM

We analyze trees with “ What Are the Odds " DNA match 3 50cM child DNA match 1 James 75cM
SCORE = 14

Unknown half-sib Unknown child Unknown child Hypothesis 1 DNA match 4
120CM

Anna John Smith & Mary DNA match 2 child Jones 100cM Unknown DNA match 5 child child 50cM
SCORE = 11

Matilda Unknown sibling Unknown child Unknown child Hypothesis 2
SCORE = 1 SCORE = 28

Unknown half-sib Unknown child Hypothesis 3 Hypothesis 4
SCORE = 2 STRONGEST SCORE = 50

Unknown sibling Unknown child Unknown child Hypothesis 5 Hypothesis 6
SCORE = 2 STRONGEST SCORE = 50 SCORE = 23 SCORE = 1

Unknown sibling Unknown child Hypothesis 7 Hypothesis 8 Hypothesis 9 Hypothesis 10
Image: https://dnapainter.com/tools/probability

Strategic testing is often needed DNA match 3 175cM child DNA match 1 225cM James
SCORE = 1

Unknown sibling Unknown child Hypothesis 1
SCORE = 191 SCORE = 102

Unknown half-sib Hypothesis 2 Hypothesis 3 DNA match 4 SCORE = 2 500cM Unknown child Unknown child Hypothesis 4 DNA match 2 275cM child John Smith & Mary SCORE = 14 Anna Unknown half-sib Unknown child Hypothesis 5 Jones
SCORE = 128 SCORE = 38

Unknown sibling Unknown child Hypothesis 6 Hypothesis 7
SCORE = 391 SCORE = 6,395

Unknown half-sib Hypothesis 8 Hypothesis 9 DNA match 5 child child 150cM
SCORE = 151

Matilda Unknown sibling Unknown child Hypothesis 10
SCORE = 8,539 SCORE = 344

Unknown half-sib Hypothesis 11 Hypothesis 12
SCORE = 2 STRONGEST SCORE = 19,472 SCORE = 107

Unknown sibling Hypothesis 13 Hypothesis 14 Hypothesis 15
Image: https://dnapainter.com/tools/probability

How genetic genealogy works How forensic genetic genealogy differs Work products of GG / FGG

How genetic genealogy works How forensic genetic genealogy differs Work products of GG / FGG

Forensic DNA is usually lower quality
• Less DNA available
• DNA may be a mixture of more than one person
• DNA may be degraded
• Non-human DNA contamination may be present

“ Next generation " genome sequencing can help Prep Sequence Analyze
Icons: https://www.illumina.com/systems/sequencing-platforms/novaseq.html

Next generation sequencing “ skims ” the DNA

NGS kits are modified via bioinformatics
• Fill in missing SNPs using statistics (imputation)
• Strip out SNPs not used by the genealogy databases to mimic a microarray file ||||
• Once the kit is uploaded and processed, the genealogy steps are the same as described earlier

Fewer databases allow forensic kits 25
• Estimates as of August '23 20 Kits
• AncestryDNA, 23andMe, & 15 of MyHeritage prohibit FGG Millions 10
• Grey bars indicate kits 5 opted in to forensic genealogy matching 0 AncestryDNA 23andMe MyHeritage GEDmatch Justice
DNA

How genetic genealogy works How forensic genetic genealogy differs Work products of GG / FGG

How genetic genealogy works How forensic genetic genealogy differs Work products of GG / FGG

Match lists
Kit 1: 1 Name Email Largest Total Gen Overlap Date Seg CM Compared
A 214.5 3571.4 1 N / A 2017-06-

04 All (6023) ↑ Paternal (0) ↑ Maternal (0) Both (0) Filter ↑ ↓ Sort by Export CSV
A 108.4

A 34.6

Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided mtDNA: N / A 2nd Cousin-4th Cousin 72 CM 50 CM No Match
Link on Family Tree Match date: July 20 2023
A 39.8

A 23.7

Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided Y-DNA: N / A 2nd Cousin-4th Cousin 56 CM 49 CM No Match mtDNA: N / A Link on Family Tree Match date: July 20 2023
A 14.6

A 37.8

Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided mtDNA: N / A 2nd Cousin-4th Cousin 56 CM 37 CM No Match A 46 Link on Family Tree Match date: July 20 2023
A 29.4 MTDNA PLUS Y-DNA67

Ancestral Surnames | View Details Haplogroup Relationship Range Shared DNA Longest Block X Match
Y-DNA: 2nd Cousin-4th Cousin 54 CM 47 CM No Match
A 43.7 mtDNA: Link on Family Tree Match date: July 20 2023
A 22८

Ancestral Surnames Haplogroup Relationship Range Shared DNA Longest Block X Match
Not Provided Y-DNA: N / A 2nd Cousin-4th Cousin 50 CM 50 CM No Match mtDNA: N / A Link on Family Tree Ma English

Research tree 2nd G Grandfather Great Grandfather 2nd G Grandmother > Paternal Grandfather 2nd G Grandfather > Great Grandmother ୦ 2nd G Grandmother > Father 2nd G Grandfather > Great Grandfather 2nd G Grandmother Paternal Grandmother 2nd G Grandfather > Great Grandmother 2nd G Grandmother > Person of Interest 2nd G Grandfather > Great Grandfather + Add relative 2nd G Grandmother > Maternal Grandfather 2nd G Grandfather Great Grandmother 2nd G Grandmother > Mother 2nd G Grandfather > Great Grandfather 2nd G Grandmother > Maternal Grandmother 2nd G Grandfather Great Grandmother 2nd G Grandmother
Image: https://www.ancestry.com

Descendant diagrams John Mary Smith Jones 500
CM

Person 175 225 275 of Interest?

150
CM

“ What Are the Odds " analysis DNA match 3 175cM child DNA match 1 225cM James
SCORE = 1

Unknown sibling Unknown child Hypothesis 1
SCORE = 191 SCORE = 102

Unknown half-sib Hypothesis 2 Hypothesis 3 DNA match 4 SCORE = 2 500cM Unknown child Unknown child Hypothesis 4 DNA match 2 275cM child John Smith & Mary SCORE = 14 Anna Unknown half-sib Unknown child Hypothesis 5 Jones
SCORE = 128 SCORE = 38

Unknown sibling Unknown child Hypothesis 6 Hypothesis 7
SCORE = 391 SCORE = 6,395

Unknown half-sib Hypothesis 8 Hypothesis 9 DNA match 5 child child 150cM
SCORE = 151

Matilda Unknown sibling Unknown child Hypothesis 10
SCORE = 8,539 SCORE = 344

Unknown half-sib Hypothesis 11 Hypothesis 12
SCORE = 2 STRONGEST SCORE = 19,472 SCORE = 107

Unknown sibling Hypothesis 13 Hypothesis 14 Hypothesis 15

Written report Description NamUs ID:
Date Body Found:
Race:
Gender:
Estimated Age:
Estimated PMI:
Location:
Agency of Jurisdiction

Forensic cases should also produce:
• Original microarray data or NGS FASTQ file
• Results of deconvolution (if needed)
• Results of enrichment (if needed)
• Results of bioinformatics (if needed)
• Processed file for upload to genealogy database (s)
• Contract with the database (s) & upload history
• Logins or kit numbers for database (s)

Fewer databases allow forensic kits 25
• Estimates as of August '23 20 Kits
• AncestryDNA, 23andMe, & 15 of MyHeritage prohibit FGG Millions 10
• Grey bars indicate kits 5 opted in to forensic genealogy matching 0 AncestryDNA 23andMe MyHeritage GEDmatch Justice
DNA

Leah LaPerle Larkin, Ph.D.

Genetic Genealogy Expert theDNAgeek@gmail.com — (925) 980-2460 www.theDNAgeek.com
OVERVIEW

Professional genetic genealogist, educator, and innovator
EDUCATION

Ph.D. in Botany, 2002 University of Texas at Austin Austin, TX B.A. in Biology, 1991 Swarthmore College Swarthmore, PA
PROFESSIONAL EXPERIENCE

Genetic Genealogy 2016- Founder and Lead Genealogist at The DNA Geek Livermore, CА Consulting services for unknown parentage searches, genealogy speaker and educator 2016- Author of The DNA Geek Blog (253 posts as of 24 July 2023) Highlighting the science, methods, and ethics of genetic genealogy 2023 Co-developer of BanyanDNA, an online tool for advanced genetic genealogy analyses 2018 Co-developer of the What Are the Odds? tool (WATO), a revolutionary tool for statistical analyses of autosomal DNA matches 2018 Genealogist for the TLC television show Taken at Birth 2017 Genealogy consultant for the TLC television show I Should Have Known 2016-2018 Editor, Journal of Genetic Genealogy Solicited manuscripts, coordinated peer reviews, edited papers for publication Scientific Editing and Grant Writing 2011-2015 Scientific Editor, Edanz Group Hong Kong Provided English-language scientific editing and publication-related services to clients globally 2011-2015 Scientific Editor, ISIS Group Cambridge, MA Revise and refine grant proposals to US funding agencies for primarily biomedical research scientists

Teaching and Assessment 2014 Freelance Pedagogy Writer (HS Biology), Pearson White Plains, NY Wrote instructional materials for 10-day professional development workshop for teachers 2013–2015 Freelance Content Specialist (K – 12 Math), Symmetry Barrington,