Court Filing
Electronically Filed 8/23/2025 1:23 PM Second Judicial District, Latah County Julie Fry, Clerk of the Court By: Larinda Valdon, Deputy Clerk Leander L. James, ISB No. 4800 JAMES, VERNON & WEEKS, P.A. 1626 Lincoln Way Coeur d'Alene, ID 83815 Tel (208) 667-0683 Fax: (208) 664-1684 Email: ljames@jvwlaw.net Attorneys for Plaintiffs IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE STATE OF IDAHO IN AND FOR THE COUNTY OF LATAH KAREN LARAMIE, an individual; Case No. CV29-25-0755 STACY CHAPIN, an individual; JAMES CHAPIN, an individual; and MAIZIE CHAPIN, an individual, DECLARATION OF MAIZIE CHAPIN IN SUPPORT OF MOTION FOR TEMPORARY RESTRAINING ORDER AND INJUNCTION Plaintiffs, vs. the CITY OF MOSCOW, a municipal corporation, Defendant. I, Maizie Chapin, declare as follows: 1. I am over the age of 18 and competent to testify to the matters set forth herein. My testimony is based upon my personal knowledge. 2. I am the biological triplet sibling of Ethan Chapin (hereafter " Ethan "). Ethan, Maddie Mogen, Kaylee Goncalves, and Xana Kernodle (Victims) were stabbed to death by Bryan Kohberger (Kohberger) on November 13, 2022, in the house where M. CHAPIN DECLARATION: 1 Maddie, Kaylee, and Xana resided and Ethan was visiting, 1122 King Road in Moscow, Idaho. 3. Kohberger has admitted to stabbing the four Victims. 4. Upon information and belief, the Defendant, the City of Moscow, has released and is in the process of releasing still images and body camera footage (video media) related to the police investigation of the homicide of the Victims to third parties in response to requests for examination of public records under Idaho's Freedom Information Act law. 5. Upon information and belief, the images being released include but are not limited to: 1.1. Images of the interior of the private room where Ethan was murdered; 1.2. Death scene images of the scenes of the murders, the victims, pools of blood, blood platters, dried blood and personal items and property of Ethan and the other Victims; 1.3. Images of the witnesses; and 1.4. Video media containing sounds of the witnesses, including sobbing and their statement to law enforcement officials. 6. The release of the death scene images is horrific-made worse by the fact that, on August 17, 2025, I inadvertently came across an investigation photo on the internet (from an unknown source) and recognized the feet of my deceased brother, Ethan. 7. I am personally haunted by the photos and lose sleep nightly, wondering what will show up on my computer and iPhone. A redacted photo is just as traumatizing M. CHAPIN DECLARATION: 2 because my brother is still in the picture, clear or not. It is devastating to me, and continues to reopen a wound that has yet to heal. 8. Once these images, including images of the bedrooms (death scene images), are released to the public, they are published, republished and circulated on the Internet, causing me actual, threatened and ongoing irreparable harm in the form of extreme emotional distress with physical manifestations, including shaking, sobbing and sleeplessness. When I inadvertently ran across the death scene image of Ethan, it shattered my world and caused me emotional damage to the point I could not function. I see and resee that released death scene image over and over in my mind, which causes me continuing profound emotional injury. I will never be able to get that image out of my mind. I now live in constant fear that I will inadvertently encounter more of these images and have them forever imprinted on my mind. 9. Ethan and I were supposed to graduate together. Now, instead of graduation photos, I see photos of his death scene. The fact that some of these photos have been released, and more may be released, is devastating to me and causes me ongoing great harm. 10. The idea that the City of Moscow may release more of the death scene photos of the Victims is extremely traumatizing to me. I now live in fear that these will be released to the World for everyone to see. Some of the media, bloggers and others in this case have shown that they will use images like death scenes for their own financial gain with no regard to the damage it does to me and my family members. M. CHAPIN DECLARATION: 3 11.In addition to those who will misuse these images, I think about Mr. Kohberger seeing these images online. The prospect that these images may be seen by my brother's murderer, and perhaps enjoyed by him, causes me irreparable and great injury of the most profound kind. 12. The images are not just photographs and body camera footage-they are painful reminders of my brother's life taken too soon, a profound loss, and final moments, which I have tried not to think about. Releasing more of these death scene images of the Victims will increase my pain and loss. Even the thought of releasing more of these images is greatly damaging and injurious to me. 13. I struggle to deal with the loss of my triplet brother. There were always three of us. Now there are only two. That reality has caused me a deep emotional wound. The City's release of images of the crime scene and the death scene greatly opened that wound further. Continued release of these images will open the wound yet further, irreparably injuring me. 14. Every single time anything is released regarding this murder case, the uptick in news articles, media requests and comments that keep this case top of the news is unbearable. I can no longer sleep. 15. The thought that these images may be released, and some have already been released, causes me psychological pain and anxiety, with physical manifestations, including shaking, sobbing and serious sleep disturbances. I spend most nights trying to push the images out of our minds. No one should have access to these images. Releasing them is an unwarranted invasion of my privacy and into the lives of my family; the images are graphic and cause tremendous pain and M. CHAPIN DECLARATION: 4 sadness. I am at a loss for understanding why anyone would release them, let alone feel the need to look at them. Losing my brother, my triplet, is a catastrophic loss to our entire family, and the photos are a gross reminder of that loss. 16. To the best of my knowledge, all of the parents and family members of the Victims are against the release of death scene images of the Victims because of the great emotional trauma and harm the release of the images has and will cause them. 17. The fear of seeing these images online has caused me extreme anxiety in everyday life. It brings back memories of an incredible triplet life with a brother who is no longer here. Even the thought of crime scene photos being released or being on the internet takes me back to that day of horror. It is a tremendous and heartbreaking loss for me and my family to live in fear, worry and sickness that we will inadvertently see death scene photos of Ethan and other Victims. Just the words alone-death scene photos-cause me emotional distress. 18. I worry that Hunter (my other surviving triplet sibling) will see more of these images. I do not want Hunter, nor myself, to endure the gruesome images of our triplet brother during his final days alive, because seeing them will cause irreparable, great, permanent harm. 19. I witnessed Hunter's great and irreparable emotional injury upon learning that some of the images of the crime scene and death scene had been released, and more may be released. He visibly expressed great agitation, sadness, fear and anguish. He was so emotionally damaged that he has been unable to speak out or join this lawsuit. 20. My family and I are experiencing extreme emotional distress with physical M. CHAPIN DECLARATION: 5 manifestations because the City has released some of these images and intends to release others, including the body camera footage. The more images released, the greater our emotional distress and harm. 21. Releasing these images and video media is an unwarranted invasion of my privacy and the privacy of my family. 22. Continued release of these images and video media will cause us further extreme emotional distress, embarrassment, and irreparable harm. I HEREBY CERTIFY AND DECLARE under penalty of perjury pursuant to the law of the State of Idaho that the foregoing is true and correct. DATED this day of August, 2025. man Cep MAIZIE CHAPIN M. CHAPIN DECLARATION: 6