Exhibit S-1 State Response to Discovery

Filed: 1/2/2025 Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Deputy Clerk-Smith, Margaret
EXHIBIT S-1

State's Response to " Defendant's 21st Supplemental Request for Discovery: Exhibit T ” filed on 12/27/24
UNDER SEAL WITH THE COURT

EXHIBIT S-1 1

EXHIBIT S-1

State's Response to " Defendant's 21st Supplemental Request for Discovery: Exhibit T " filed on 12/27/24
UNREDACTED

The State's responses are provided in blue. The State will continue to supplement its discovery responses as additional information is received.

422. High quality photographs or scans of the latent prints of Jack Ducoeur collected in the case. Scans should be made at a minimum resolution of 1000 ppi and saved in a non-proprietary, non-destructive format such as TIF (no compression). Images should be individually scanned and NOT submitted in Multi-page formats. The photographs or scans must include both sides of any lift cards. Scans of the backside of the lift card that only include text or diagrams may be done at lower resolutions and saved in any non- proprietary format such as JPEG or PDF.

If the fingerprints were only photographed or scanned, as is the case for fingerprints developed with dye stains or chemical processes, then copies of the original digital image files should be submitted. Any enhanced images used for comparison should also be included. A scale should be included in each photograph or scan.

This item does not exist. To date, the latent prints for Jack Ducoeur have not been collected.

The State will attempt to collect Jack Ducoeur ' s latent prints and if collected will provide this item upon receipt.

423. Results of all testing and comparisons conducted in this case with the latent prints of Jack Ducoeur.

This item does not exist. To date, the latent prints for Jack Ducoeur have not been collected.

The State will attempt to collect Jack Ducoeur's latent prints and if collected and analyzed will provide this item upon receipt.

EXHIBIT S-1 1

EXHIBIT S-1

State's Objection to Defendant's Motion to Compel I.C.R. 16 (b) (7) Material and for Sanctions
UNDER SEAL WITH THE COURT

EXHIBIT S-1 1

IDAHO

███ POLICE

STATE

IDAHO STATE POLICE FORENSIC SERVICES

700 South Stratford Drive, Ste 125 Meridian, ID 83642-6202
Phone: (208) 884-7170
Fax: (208) 884-7197
FORENSIC FIELD SERVICES REPORT

Case Agency (s): Agency Case No (s): Laboratory Case No.:
MOSCOW POLICE DEPARTMENT 22-M09903 M2022-4843

Date (s) of Offense: Investigating Officer (s): Report No.:
11/13/2022 Dustin Blaker 25 Analyst:
Tara Martinez Case Name (s):
Suspect-BRYAN KOHBERGER Victim-MADISON M MOGEN Victim-XANA A KERNODLE Victim-ETHAN J CHAPIN Victim-KAYLEE J GONCALVES 1630 NE Valley Rd. # G201 Field Notes:
On 12/30/22 at approximately 0705 PST, Forensic Scientists (FS) Hailey Youngling, Jennie Ayers and I responded to 1630 NE Valley Rd, # G201, Pullman, Washington to assist in a homicide investigation.

Jeffory Talbott with Idaho State Police District 2 (ISP D2) and Dustin Blaker with Moscow Police Department arrived to the residence with us. Deputy Chief Dawn Daniels with Washington State University Police Department (WSU PD) was present upon our arrival. The scene was not secured at this time. The temperature was approximately 33 degrees Fahrenheit and the weather was snowy and wet.

1630 NE Valley Rd # G201 is a beige six-plex apartment building with a maroon / brown colored " G " on the exterior. Apartment # G201 is on the second floor on the east side of the building. The second floor staircase is flush with the surrounding sidewalk and has a single flight of stairs going up. The entryway to apartment # G201 is directly east of the staircase.

The interior of apartment # G201 was well kept and sparsely furnished. There are two bedrooms, one bathroom with a separate water closet, a living room and a kitchen. The entryway door enters to the living room. The living room was furnished with a two-seat sofa on the east wall. There was a coffee table and a rug in front of the sofa. On the west wall, there was a television stand with a television and various books on the interior shelving. In the southwest corner of the living room, there was a disconnected air conditioning type unit. The south wall of the living room has a door that opens to the exterior patio. To the north of the television stand, there was a table with one lamp, powered off. On the north wall of the living room, there is a closet. East of the closet (on the north side of the apartment) are two bedrooms, one on the west side, one on the east side. The northwest bedroom was unfurnished and was locked prior to entry. There are two empty 2-door closets located on the west Page 1 of 3
800-631-6989 CRO1-24- 31665 STATE'S

009323 EXHIBIT

S-1

PENGAD

Laboratory Case Number: M2022-4843 Report No.: 25 wall. The door to the northeast bedroom is in the northwest corner of the room. Along the west wall there was a table that contains a computer tower and electronics. A bed was against the north wall.

The east wall contains two 2-door closets. To the south of the closet, there was a stool with folded white towels, a small white trash bin and a white laundry basket. The bathroom is located to the south of the northeast bedroom. The kitchen is located to the south of the bathroom. There was a fridge in the northwest corner of the kitchen. To the east of the fridge is a sink. The stove and oven was on the east wall. There were various kitchen appliances on the counter including a dishrack, an electric can opener, a microwave, coffee makers and a bean grinder. The kitchen cabinets contained various food items, dishes, cooking utensils, pots and pans. On the south wall of the kitchen, there was a table with shelving and one stool.

I photographed the exterior and interior of the apartment for overall location, identification and condition.

FS Ayers captured images using the LizQ Imaging System.

FS Ayers performed presumptive tests for the presence of blood on 51 areas inside the apartment.

Positive results, indicating the presence of blood, were obtained on two stains from the bedding of the northeast bedroom. A cutting was collected from a pillow in the northeast bedroom (marker B) and a mattress cover was collected from the bed in the northeast bedroom (marker C). A third stain (marker A) was collected from the kitchen countertop but was not tested, due to the size and condition.

Blood was not detected on twelve stains tested in the kitchen, fifteen stains tested in the northeast bedroom, seventeen stains tested in the bathroom, and five stains tested in the living room.

I collected eleven items from the apartment. I collected five items from the north wall closet: one nitrile type black colored glove (marker 1), one " Walmart " receipt with one " Dickies " tag (marker 2), two " Marshalls " receipts (marker 3), one dust canister from " Bissell PowerForce " vacuum (marker 4), eight possible hair strands from the head of the " Libman " broom (marker 5). I collected one " FireTV " stick with cord and plug from the living room television (marker 6). I collected one possible hair strand from the east wall in the bathroom (marker 8) and one possible hair strand inside the shower drain in the bathroom (marker 9). I collected three items from the northeast bedroom: one possible animal hair strand (marker 7), one possible hair strand from the computer pad in the northeast bedroom (marker 10), and one possible hair strand from a pillow in the northeast bedroom (marker 11). FS Ayers collected one computer tower in the northeast bedroom (marker 12).

We cleared the scene at approximately 1933 PST.

All evidence was turned over to Deputy Chief Daniels at approximately 2022 PST on 12/30/22.

1475 NE Glenn Terrell Mall, Wilson Short Hall, Room 12 Field Notes:
On 12/30/22 at approximately 2116 PST, Forensic Scientists (FS) Hailey Youngling, Jennie Ayers and I responded to 1475 NE Glenn Terrell Mall, Wilson Short Hall, Room 12, Puilman, Washington to assist in a Page 2 of 3 009324

Laboratory Case Number: M2022-4843 Report No.: 25 homicide investigation. Jeffory Talbott (ISP D2), Lawrence Mowery (Moscow Police Department) and Deputy Chief Daniels (WSU PD) arrived to the office with us. The scene was secured by Tim Snell, Leslie Lehman (ISP D1) and WSU PD.

Room 12 has four desks. There was also a filing cabinet and shelving.

I took photographs for overall location, identification and condition.

No items were collected or tested.

We cleared the scene at approximately 2155 PST.

I transferred digital images to Talbott (ISP D2) on 12/31/22 at approximately 0910 PST.

FS Ayers provided a thumb drive with LizQ images to Talbott (ISP D2) on 12/31/22 at approximately
1148 PST.

I uploaded all digital images, excluding those from the LizQ System, to the digital imaging system on
01/03/23.

DISPOSITION:

Digital images are being retained by ISP Forensic Services.

REMARKS:

I declare under penalty of perjury pursuant to the law of the State of Idaho that the foregoing is true and correct.

Jau my Tara Martinez / Forensic Scientist
Issue Date: 03/21/2023 Page 3 of 3 009325

22-M09903 # 25 M2022-4843

MOSCOW POLICE DEPARTMENT Page 1 of 29 py
FIELD SERVICES ANALYSIS NOTES

Case: M2022-4843 Examiner: Tara Martinez Dates of Analysis: 12 / 29 / 22-3 / 21 / 2023 Scene Personnel Task Value Scene Response Date 12/29/2022 Person Tara Martinez Total travel time 10.50 Total time on Scene (s) 16.65 # of Locations 2 Scene Response Date 12/29/2022 Person Hailey Youngling Total travel time 10.50 Total time on Scene (s) 16.65 # of Locations 2 Scene Response Date 12/29/2022 Person Jennie Ayers Total travel time 10.50 Total time on Scene (s) 16.65 # of Locations 2 General Crime Scene Task Value Response Event / Location 1630 NE Valley Rd. # G201 Pullman. WA Photography Yes Image # 5891 to Image # 6141 Total # of Images 251 ALS Exam No Sketch / Diagram No # of Presumptive Blood Tests 51 # of Biological Stains / Items 3 Collected Other test (s) performed No Other item (s) collected yes # of Other item (s) collected 12 Type (s) of Other Evidence nitrile glove, receipts (3), vacuum dust canister, possible hair strands (13), Fire TV stick, computer tower Response Event / Location 1630 NE Valley Rd. # G201 Pullman. WA Photography Yes Image # 8118 to Image # 8528 Total # of Images 411 ALS Exam No Sketch / Diagram No Other test (s) performed No Response Event / Location 1475 NE Glenn Terrell Mall, Wilson Short Hall, Room 12, Pullina: WA.

Photography Yes Image # 8529 to Image # 8583 Total # of Images 55 ALS Exam No Sketch / Diagram No Other test (s) performed No General Notes Task Value
C: \ inetpub \ wwwroot \ ILIMS \ Reports \ MSSQL \ FS MATRIX.rpt Page 1 of 2 009326

22-M09903 # 25 M2022-4843

MOSCOW POLICE DEPARTMENT Page 2 of 29
FIELD SERVICES ANALYSIS NOTES

Case: M2022-4843 Examiner: Tara Martinez Dates of Analysis: - 3/21/2023 General Notes Entry # 2 added to add additional photos taken with another camera. A testing info is in Entry # 1-only photos are in Entry # 2.

Verification of Accompanying Personnel Task Value Information Verified yes Verified By: Hailey Youngling Date Reviewed by Accompanying 02/17/2023 Responder Notes from Accompanying 01/24/2023 HMY: for the # of presumptive tests, I think the ter should be 51, since marker A Responder wasn't tested just collected- update 52 to 51 in the report, " FS Ayers performed a presumptive test for the presence of blood on 52 areas inside the apartment "
In the report: " East of the closet are two bedrooms, one on the west side, one on the east side " Maybe add something about the bedrooms also being north, maybe " East of the closet, on the north side of the apartment, are two bedrooms, one on the west side, one on the east side "?

Information Verified yes Verified By: Jennifer (Jennie) Ayers Date Reviewed by Accompanying 02/27/2023 Responder Notes from Accompanying 02/15/23 JA Responder In both locations, change FS to Forensic Scientists (plural) " AC " unit- spell out to air conditioning double check that items in apartment are past tense For presumptive blood, changed to " performed presumptive tests " (plural) In opening paragraph for office, change " arrived to the residence " to " arrived to the office " or something similar " # G201 is well kept " change to " was "; " living room is furnished " change to " was "; " northwest bedroom is unfurnished " change to " was ":
LizQ Imaging Task Value LizQ Imaging Location 1630 NE Valley Road, # G201 # of Captures 14 # of sphericals 14 LizQ Total Images Captured 1386 General Notes Outdoor captures (221 and 234) did not have low / high. Indoor capares all included low / high.

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22-M09903 # 25 M2022-4843

MOSCOW POLICE DEPARTMENT Page 3 of 29
ISPFS CRIME SCENE RESPONSE

Call out received date: 12/28/22 time: 1102 by: Jennie Ayers Location 1360 NE Valley Rd Pullman WA
Agency: SP D2 INV Agency Case #:
Search Warrant obtained N Incident Date: 11/13/22
Details: Search warrants to be executed at suspect's apartment.

and office. Looking for blood, trace, khife, anything else to the suspect to scene and / or victims. will coordinate with WA agency.

* any additional requests for processing shall be documented in the case notes * ******
Date: 12/3012022
ISPFS Personnel: Jennie Ayers Enroute: 0529 PST
Tara Martiniz Arrived: 0711 PST
Halley Youngling Clear: 2055 PST
Crime Type: Back to ISPFS:
ISPFS Lab #: M2022 4843 m 2022 4870
Scene Security: [] entry log () barrier tape () Officer (s) posted
Weather: Snow / Rain / Windy / Clear / Cloudy / Cold / Hot Temperature: 33 ° F
Briefed by: Walk through:
Officers / Detectives Present:
Victim / Suspect / Subject: Bryan Konberger DOB: 11/21/1994
Victim / Suspect / Subject: DOB:
Victim / Suspect / Subject: DOB:
Victim / Suspect / Subject: DOB:
Vehicle (s):
Coroner: Arrival:
Mortuary: Arrival:
Body bag seal #:
XPhotography Presumptive Blood test (s) ☑ Trace Evidence [] Video [] Blood enhancement [] Footwear / Tire Tracks [] Sketch [] Bloodstain Pattern Analysis () Latent Print Processing [] Location / Dimensions [] Shooting Reconstruction [] Major Case Prints [] ALS exam (note unit & nm) () Firearms Evidence [] LizQ [] 5541- GIMI Foray M Digital images numbered 8118 to $ 583 A Digital images uploaded to martinez ✗ digital transfer _thumb drive / CD / DVD T. images Digital images provided to agency via: transferred conveyed to Talbott to tallbutt an 12131/2072 Results of processing / chemical tests 0910 PST @approx.

Page of 2 Initials ۱۹
TOTAL PAGES: 1 OF 31723

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MOSCOW POLICE DEPARTMENT Page 4 of 29
ISPFS CRIME SCENE RESPONSE

BRIEFING NOTES

ISPFS Lab #: M2022 4843
Briefed by: Blaker (moscow PD), Talbott (ISP D2)
Investigative information: Suspect + to be arrested & W0200 EST.

Soft entoe into suspect's apartment-phuto & Liza, then prosecutor on will indo do walkt through , consists of 2 bedrooms, 1 bath Kitchen, living room, os balcony per schematic.

Types of evidence included in search warrant / consent:
[DNA (blood, saliva, semen, hair, other bodily fluids) or items that may bear DNA [] Latent prints (fingerprints, palm prints, sole prints) or items that may bear impressions [] MCP's Electronics [) Tire Impressions [] Firearms / Firearms related ☑ Clothing [] Footwear Impressions [) Blunt weapons [] Indicia of ownership ✔Trace (hair, fiber, shavings, etc.) Sharp edged weapons [] Drugs / Paraphernalia [] Additional requests / information from investigating agency: Electronics, handwriten journals wsu oftice-computer swabs of mouse & phone wilson Short Haul 1475 Glen Garg Terrell mau Pullman WA
12/21/22 wsu folice to assist as apartment and office are bot on wsu property Page 2 of 2 Initials thy
TOTAL: 2 OF 403172 19

009329

22-M09903 # 25 M2022-4843

MOSCOW POLICE DEPARTMENT Page 5 of 29 LizQ Capture Notes
Date: 12/30/22 Lab Number: M2022-4843
Location: 1630 NE Voley Rd Analyst (s): Jennie Ayers # 6201
CAPTURE #

ROOM or GENERAL LOCATION OF LIZQ DIMENSIONS FOR ITEM IN LOCATION FOR LOW (HIGH AREA (Room / Location) PHOTOGRAMMETRY (LxWxH) cm ) N of Sidewalk N & sighten 32 inches Item: on radiator north 221 building w of staircase ladins W: 6.5 inches
G to 6201 H: 16 inches wall livias S. of coffee table L: 62 inches Item: radiator w: lencho South 222 223 room H: 20.75 inches wall living room eus
L: 62 inches thes Item: radiator 225
Kitchen Center of kitchen w: 6 inches 204 on suuth 45
H: 20.75 inches wall living roo
VE m / approx. Center of L: 72 inches Item: Desk
Bedram W: 23.25inchus 226 2245 room H: 36 inches top
NW aprox Center of L: 32inches Item: raduttor 228 229
Bedroom. W: 6. Sinches on north eus roum H: 16 inches wall
Bathroom Just east of the L: 26 inches Item: radiator 230 231 toilet roum wall w: 4.nches on East 229 045
H: 14 inches Wall 리지
Nend E. Side of hallway L: 62 inches Item: radiator 233 of living w: le inches on south wall 232
H: 20.75 inches radiator 245 room balcony west of door L: Item:
W: 234

near railing
H:

L: Item:
W:

H:

L: Item:
W:

H:

L: Item:
W:

H:

Images turned over to Talbott at 1148 PST 12/31/2022 by J. Ayers Page of Initials m 19 Homy
TOTAL: 3 OF 18 1700

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MOSCOW POLICE DEPARTMENT Page 6 of 29 Presumptive Chemical Tests for Blood
Date: 12/30/22 Time: 1543 PST Lab Number: M2022-4843
Chemical Lot #: 1200-33620 Analyst (s): J. Ayers Control (known blood) result: O-Tol POS: Blue / Green NEG No immediate color change Control (known blood) result: Phenol POS (Pink (circle results)
RESULTS COLLECTION

INCONCLUSIVE NO

COLLECT COLLECTED

COLLECTION

POSITIVE NEGATIVE CUTTING

MARKER #

OR GENERAL DESCRIPTION OF STAIN AND / OR SWAB ITEM

IDENTIFIER SURFACE, LOCATION BY

white towel from Shelf Of Kitchen Table. Diluted X red Drown irregular stain Unuble dark red Spot, small mall-flaked Ayers Jotest A off surface upon touch west of X 1. Collected, wlotest Sink, Kitchen Counter Pizza cutter, top drawer west of Sink, East of fridge X reddish Scratchnin metal side Sock panel med inregulaner of drawer Ecty-seand X приго west of sink KITCH En 3/32 screw driver from ut bottom drawer, west of sink X PROM brown spot Ajax bottle of soap, near bottom edge on west side of Sink X ALL Small dark stain Ajax bottle of Soap, near bottom, linear stain X switch on north wall of Kitchen behind Sink. dark X reddish Stain Switch on north wall of Kitchen behind sink, small X dark reddish stain Pink / redirnegular Stain on edge of Plate. From dream X Cabinet west of sink Evidence turned over to at Evidence S & S-Y / N Page of ти 19 Ами
TM31723

TOTAL: 4 OF 18

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MOSCOW POLICE DEPARTMENT Page 7 of 29 Presumptive Chemical Tests for Blood
Date: 12/30/2022 Time: Lab Number: M2022-4843
Chemical Lot #: 1200-33620 Analyst (s): J. Ayers Control (known blood) result: O-Tol POS: Blue / Green NEG: No immediate color change Control (known blood) result: Phenol POS Pink (circle results)
RESULTS COLLECTION

INCONCLUSIVE NO COLLECTED

COLLECT

COLLECTION

MARKER # POSITIVE NEGATIVE CUTTING

OR GENERAL DESCRIPTION OF STAIN AND / OR SWAB ITEM

IDENTIFIER SURFACE, LOCATION BY

Microwave on Counter in Kitchen, NE corner. dark) back Eve long Stain in groux273 ( dark discoloration in of counter tile Just south of X microwave crange drip South wall of Kitchen East of window X NE bedroom. NeCloset. Interior of north door. Dark red stainst X Multiple, Irregular and pieces Small red brown stain on Exterior door of NE Closet X In NE bedroom. (nurth door) Edge of South door of NE Closet In NE bedroom, vem small X ned brown stain Interior of South closet door North door. faint stains Swipe X marks. Ne room Two small reddish brownimegular Stain. inside of South Closet X North EAST PROM m 1032) Irregular reddish brown stain.

Inside south closet of Nt roun X north side of vertical wall in center White towel on black / brown