bryan-kohberger-search-warrant.pdf

10

11

12

14

19

4

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6

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22

2

3

7

8

17

23

9

IN

THE

MATTER

OF

APPLICATION

FOR

SEARCH

WARRANT

24

1

25

IN

THE

SUPERIOR

COURT

OF

THE

STATE

OF

WASHINGTON

IN

AND

FOR

THE

COUNTY

OF

WHITMAN

FILED

JAN

17

2023

JILL

E

WHITMAN

SW

NO

.

12-29-2022A

M &

to

Un

-

Seal

Return

Page

of

2

MOTION

AND

ORDER

TO

UNSEAL

WARRANT

RETURN

Clerk's

Action

Required

MOTION

COMES

NOW

,

the

State

of

Washington

,

by

and

through

Denis

Tracy

,

Whitman

County

Prosecuting

Attorney

,

and

moves

the

court

for

an

Order

to

Un

-

seal

the

Return

of

Service

of

Search

Warrant

numbered

SW

NO

.

12-29-2022A

,

pursuant

to

GR

15

.

BASIS

These

warrants

were

issued

and

served

in

Washington

State

,

because

a

suspect

in

the

crimes

resided

and

worked

here

during

the

time

of

the

murders

.

These

warrants

and

associated

applications

were

sealed

,

due

to

the

sensitive

nature

of

the

investigation

at

that

time

.

Since

then

,

an

extensive

probable

cause

affidavit

has

been

unsealed

in

Latah

County

,

Idaho

,

which

has

alleviated

the

need

for

sealing

of

the

Return

of

Service

here

in

Washington

.

DENIS

P.

TRACY

WHITMAN

COUNTY

PROSECUTOR

Box

Colfax

,

WA

99111

(

509

)

397-6250

(

509

)

397-5659

FAX

10

11

12

14

16

13

15

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19

20

21

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9

17

22

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6

7

8

23

3

24

25

1

Dated

January

17

,

2023

.

Presented

by

:

Denis

P.

Tracy

Prosecuting

Attorney

W

BA

#

20383

ORDER

It

is

ordered

that

the

Return

of

Service

of

Search

Warrant

in

this

matter

is

hereby

Un

-

sealed

.

M &

to

Un

-

Seal

Return

Page

2

of

2

Dated

this

Judge

Gary

Libey

Day

of

January

,

2023

.

DENIS

P.

TRACY

WHITMAN

COUNTY

PROSECUTOR

Colfax

,

WA

99111

(

509

)

397-6250

(

509

)

397-5659

FAX

14

12

15

16

13

17

18

19

20

21

10

22

24

25

23

9

8

2

3

4

6

7

5

IN

THE

SUPERIOR

COURT

OF

THE

STATE

OF

WASHINGTON

IN

AND

FOR

THE

COUNTY

OF

WHITMAN

IN

THE

MATTER

OF

APPLICATION

FOR

SEARCH

WARRANT

FILED

JAN

17

2023

E

WHITMAN

SW

NO

.

12-29-2022A

MOTION

AND

ORDER

FOR

ORIGINAL

SEARCH

WARRANT

AND

SEARCH

WARRANT

APPLICATION

TO

REMAIN

SEALED

BUT

A

REDACTED

VERSION

BE

PROVIDED

FOR

PUBLIC

RELEASE

Clerk's

Action

Required

MOTION

COMES

NOW

,

the

State

of

Washington

,

by

and

through

Denis

Tracy

,

Whitman

County

Prosecuting

Attorney

,

and

moves

the

court

for

an

Order

to

keep

sealed

the

Search

Warrant

and

Search

Warrant

Application

numbered

SW

NO

.

12-29-2022A

,

but

to

allow

the

State

to

file

redacted

versions

which

replace

the

victim

witnesses

names

with

initials

,

pursuant

to

GR

15

.

M &

to

Seal

and

Redact

Page

of

3

BASIS

The

Washington

State

Constitution

recognizes

that

victims

of

crimes

have

rights

,

and

states

that

Effective

law

enforcement

depends

on

cooperation

from

victims

of

crime

."

Wash

.

Const

.

art

.

.

The

Washington

State

Legislature

has

recognized

that

there

is

a

severe

and

detrimental

impact

on

crime

victims

,

survivors

of

victims

,

and

witnesses

of

crime

and

[

and

yet

there

is

]

the

civic

and

moral

duty

of

victims

,

survivors

of

victims

,

and

witnesses

of

crimes

to

fully

and

voluntarily

DENIS

P.

TRACY

WHITMAN

COUNTY

PROSECUTOR

Colfax

,

WA

99111

(

509

)

397-6250

(

509

)

397-5659

FAX

14

10

12

16

13

17

18

19

15

20

21

22

23

24

4

5

8

9

25

1

2

6

7

3

cooperate

with

law

enforcement

and

prosecutorial

agencies

.

RCW

7.69.010

.

In

a

criminal

proceeding

,

the

law

requires

that

a

reasonable

effort

is

made

to

ensure

that

victims

,

survivors

of

victims

,

and

witnesses

of

crimes

have

the

right

[

t

o

receive

protection

from

harm

and

threats

of

harm

arising

out

of

cooperation

with

law

enforcement

and

prosecution

efforts

.

RCW

7.69.030

(

5

)

Washington

Courts

have

long

acknowledged

that

a

victim's

initials

can

be

substituted

for

their

name

.

See

State

v

.

Mansour

,

14

Wn.App.2d

323

(

2020

)

.

The

basis

for

this

motion

is

that

there

are

two

surviving

victims

/

witnesses

of

a

now

notorious

and

much

publicized

murder

/

burglary

in

Moscow

,

Idaho

,

whose

full

names

are

listed

in

this

search

warrant

and

search

warrant

application

.

These

warrants

were

issued

and

served

in

Washington

State

,

because

a

suspect

in

the

crimes

resided

and

worked

here

during

the

time

of

the

murders

.

These

warrants

and

associated

applications

were

sealed

,

due

to

the

sensitive

nature

of

the

investigation

at

that

time

.

Since

then

,

an

extensive

probable

cause

affidavit

has

been

unsealed

in

Latah

County

,

Idaho

,

which

has

alleviated

much

of

the

need

for

sealing

here

in

Washington

.

But

the

documents

filed

in

Latah

County

have

not

disclosed

the

surviving

victims

names

,

only

their

initials

.

These

victims

should

have

the

level

of

protection

that

can

be

provided

by

having

their

initials

substituted

for

their

full

names

in

the

search

warrants

and

search

warrant

applications

which

become

publicly

available

from

this

court

.

The

State

is

asking

the

Court

to

consider

the

usual

factors

:

(

1

)

showing

of

the

need

for

sealing

the

records

,

and

where

that

need

is

based

on

a

right

other

than

an

accused's

right

to

a

fair

trial

,

a

serious

and

imminent

threat

to

that

right

;

(

2

)

anyone

present

when

motion

is

made

must

be

given

an

opportunity

to

object

to

the

closure

;

(

3

)

the

proposed

method

for

curtailing

open

access

must

be

the

least

restrictive

means

available

for

protecting

the

threatened

interests

;

(

4

)

the

court

must

weigh

the

competing

interests

of

the

proponent

of

closure

and

the

public

;

and

(

5

)

the

order

must

be

no

broader

in

its

application

or

duration

than

necessary

to

serve

its

purpose

.

The

State

contends

that

the

need

to

protect

victim

identification

is

important

to

their

safety

,

health

and

well

-

being

and

that

victims

and

witnesses

rights

should

be

protected

vigorously

just

as

the

legislature

and

the

State's

founders

intended

.

The

proposed

method

is

to

file

a

complete

search

warrant

and

application

for

warrant

with

only

the

surviving

victims

names

redacted

and

replaced

with

initials

.

This

is

a

very

minor

closure

of

a

court

document

in

order

to

protect

a

very

important

M &

to

Seal

and

Redact

Page

2

of

3

DENIS

P.

TRACY

WHITMAN

COUNTY

PROSECUTOR

Colfax

,

WA

99111

(

509

)

397-6250

(

509

)

397-5659

FAX

10

11

12

13

15

14

16

17

18

19

20

21

22

23

9

24

25

8

6

1

2

4

5

7

3

victim

interest

.

Finally

,

the

order

will

be

no

broader

in

application

than

necessary

to

serve

its

purpose

,

and

the

public

will

still

have

the

pertinent

information

at

its

disposal

in

order

to

understand

the

proceedings

of

the

court

.

Dated

January

17

,

2023

.

Presented

by

:

P.

Prosecuting

Attorney

WSBA

#

20383

ORDER

It

is

ordered

that

the

Search

Warrant

and

Application

For

Search

Warrant

already

filed

in

this

matter

shall

remain

sealed

,

but

the

State

shall

immediately

file

redacted

versions

of

those

documents

with

the

surviving

victim's

names

redacted

and

replaced

with

initials

.

M

&

to

Seal

and

Redact

Page

3

of

3

Dated

this

Gary

Day

of

January

,

2023

.

DENIS

P.

TRACY

WHITMAN

COUNTY

PROSECUTOR

PO

Colfax

,

WA

99111

(

509

)

397-6250

(

509

)

397-5659

FAX

8

9

7

10

3

4

11

2

5

1

12

13

17

18

19

20

23

TO

ANY

PEACE

OFFICER

IN

THE

STATE

OF

WASHINGTON

:

Upon

the

sworn

complaint

made

before

me

,

there

is

probable

cause

to

believe

that

the

crime

(

s

)

14

of

Murder

in

the

first

degree

and

Burglary

,

per

Idaho

Code

has

been

committed

,

in

Idaho

,

and

that

evidence

of

that

/

those

crime

(

s

)

;

or

contraband

,

the

fruits

of

crime

,

or

things

otherwise

criminally

possessed

;

or

weapons

or

other

things

by

means

of

which

a

crime

has

been

committed

or

reasonably

appears

about

to

be

committed

;

is

concealed

in

or

on

certain

premises

.

16

In

making

this

determination

,

this

court

did

not

consider

the

information

in

the

Supplemental

Disclosure

re

DNA

Test

as

evidence

supporting

the

existence

of

probable

cause

.

This

court

also

does

not

consider

the

information

in

that

Supplemental

Disclosure

to

be

exculpatory

.

21

22

24

25

26

27

28

STATE

OF

WASHINGTON

)

COUNTY

OF

WHITMAN

SUPERIOR

COURT

,

WHITMAN

COUNTY

,

WASHINGTON

SW

NO

:

2-29-2022

A

FILD

JAN

17

2023

JILL

WHITMAN

COUNTY

CLERK

SEARCH

WARRANT¹

(

Residence

)

SEARCH

WARRANT

Page

of

4

YOU

ARE

COMMANDED

to

:

1.

Search

,

within

10

days

of

this

date

,

the

premises

described

as

follows

:

Apartment

located

at

1630

NE

Valley

Rd

,

#

G201

,

Pullman

,

WA

.

1630

NE

Valley

Road

is

a

three

story

,

multiple

occupancy

apartment

building

in

Pullman

,

WA

which

is

tan

and

white

in

color

.

Apartment

G201

is

located

on

the

northeast

corner

of

the

second

story

of

this

building

.

The

door

to

G201

is

located

on

the

east

side

of

the

second

story

landing

and

is

designated

by

the

numbers

"

201

on

2

3

4

5

6

7

8

1

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the

door

.

The

door

is

white

,

with

a

swinging

screen

door

on

the

outside

of

the

main

door

to

the

residence

.

2.

Seize

,

if

located

,

evidence

of

the

above

-

listed

crimes

,

including

:

1.

Blood

,

or

other

bodily

fluid

or

human

tissue

or

skin

cells

,

or

items

with

blood

or

other

bodily

fluid

or

human

tissue

or

skin

cells

on

the

items

.

2.

Knives

,

sheaths

,

or

other

sharp

tools

,

including

any

dagger

,

dirk

,

or

sword

,

and

any

written

indicia

of

ownership

of

same

,

including

sales

receipts

.

3.

Any

images

,

whether

digital

or

on

paper

or

any

other

format

,

which

show

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

and

/

or

and

/

or

the

house

at

1122

King

Road

,

Moscow

,

ID

and

/

or

the

surrounding

neighborhood

.

4.

Clothing

,

including

but

not

limited

to

dark

shirt

(

s

),

dark

pant

(

s

)

,

mask

(

s

)

,

shoes

with

diamond

pattern

sole

.

5.

Trace

evidence

including

DNA

from

blood

or

skin

cells

or

other

source

,

footprints

,

fingerprints

,

hair

(

whether

human

or

animal

/

dog

)

.

6.

Data

compilations

(

whether

digital

/

electronic

or

on

paper

or

other

format

)

showing

an

interest

in

,

or

planning

of

,

murder

,

violent

assault

,

stabbing

and

/

or

cutting

of

people

;

and

data

compilations

showing

details

of

the

1122

King

Road

house

,

its

location

,

and

/

or

any

information

about

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

and

data

compilations

showing

the

location

of

Bryan

Kohberger

,

or

the

cell

phone

with

number

509-592-8458

,

on

November

13

,

2022

,

including

wi

-

fi

logs

and

data

or

meta

-

data

associated

with

photos

,

social

media

posts

,

or

applications

on

cell

phones

or

computer

towers

/

laptops

/

tablets

.

As

example

,

but

not

intended

to

be

an

exclusive

list

of

data

compilations

being

sought

:

ledgers

,

papers

,

lists

,

B.F.

and

/

or

D.M.

SEARCH

WARRANT

Page

2

of

4

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

books

,

notes

,

letters

,

calendars

,

address

books

,

contact

lists

,

diaries

,

tapes

,

photographs

,

videos

,

emails

,

text

messages

,

social

media

posts

/

messages

,

and

meta

-

data

associated

therewith

.

7.

Electronic

digital

devices

or

digital

storage

devices

which

may

contain

any

of

the

above

data

compilations

,

including

cell

phones

,

computer

towers

/

laptops

/

tablets

,

external

hard

drives

,

CD

/

DVD

/

Thumbdrive

or

other

data

storage

devices

.

This

includes

any

device

which

may

contain

:

Evidence

of

other

accounts

associated

with

this

device

including

email

addresses

,

social

media

accounts

,

messaging

app

"

accounts

,

and

other

accounts

that

may

be

accessed

through

the

digital

device

that

will

aid

in

determining

the

possessor

/

user

of

the

device

;

Photographs

,

images

,

videos

,

documents

,

and

related

data

created

,

accessed

,

read

,

modified

,

received

,

stored

,

sent

,

moved

,

deleted

or

otherwise

manipulated

between

the

above

dates

Evidence

of

use

of

the

device

to

conduct

internet

searches

relating

to

a

review

of

other

murders

or

violent

assaults

/

stabbing

and

/

or

cutting

of

people

,

as

well

as

how

to

avoid

detection

after

the

commission

of

such

crimes

;

details

of

the

1122

King

Road

house

,

its

location

/

neighborhood

,

and

/

or

information

about

one

or

more

of

the

victims

Ethan

B.F.

and

/

or

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

D.M.

Information

that

can

be

used

to

calculate

the

position

of

the

device

between

the

above

dates

,

including

location

data

;

GPS

satellite

data

;

GPS

coordinates

for

routes

and

destination

queries

between

the

above

-

listed

dates

;

app

data

or

usage

information

and

related

location

information

;

IP

logs

or

similar

internet

connection

information

,

and

images

created

,

accessed

or

modified

between

the

above

-

listed

dates

,

together

with

their

metadata

and

EXIF

tags

Evidence

of

the

identity

of

the

person

in

possession

of

the

device

on

or

about

any

times

that

items

of

evidentiary

value

,

located

pursuant

to

this

warrant

,

were

created

modified

,

accessed

or

otherwise

manipulated

.

Such

evidence

may

be

found

in

digital

SEARCH

WARRANT

Page

3

of

4

1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

communications

,

photos

and

video

and

associated

metadata

,

IP

logs

,

documents

,

social

media

activity

,

and

similar

data

;

Also

,

passwords

,

phrases

,

codes

,

patterns

,

fingerprints

,

and

/

or

user

names

to

operate

any

such

device

.

8.

Indicia

of

residence

in

,

or

ownership

or

possession

of

,

the

premises

and

any

of

the

above

items

,

including

mail

,

receipts

,

identification

,

bills

,

rental

agreements

,

licensing

documents

and

other

personal

property

whose

owner

/

possessor

may

be

readily

determined

.

Assistance

from

any

law

enforcement

agencies

from

the

State

of

Idaho

or

the

federal

government

,

or

any

technical

specialist

associated

with

or

employed

by

or

contracted

with

such

law

enforcement

agencies

,

including

but

not

limited

to

the

Moscow

Police

Department

,

Idaho

State

Police

,

FBI

Idaho

State

Police

Forensic

Services

is

authorized

.

Assistance

from

a

technical

specialist

is

also

authorized

to

review

any

digital

devices

and

digital

media

for

the

best

and

least

intrusive

method

of

securing

digital

evidence

that

the

warrant

authorizes

for

seizure

,

and

to

assist

in

securing

such

evidence

.

Promptly

return

this

warrant

to

me

or

the

clerk

of

this

court

;

the

return

must

include

an

inventory

of

all

property

seized

.

A

copy

of

the

warrant

and

a

receipt

for

the

property

taken

shall

be

given

to

the

person

from

whom

or

from

whose

premises

property

is

taken

.

If

no

person

is

found

in

possession

,

a

copy

and

receipt

shall

be

conspicuously

posted

at

the

place

where

the

property

is

found

.

Date

/

Time

SEARCH

WARRANT

Page

4

of

4

Signature

SUPERIOR

COURT

JUDGE

Printed

Judge's

Name

:

6

7

9

8

10

5

11

3

4

12

13

14

1

2

16

15

18

17

19

20

21

25

22

23

26

24

27

28

FILED

JAN

17

2023

SUPERIOR

COURT

,

WHITMAN

COUNTY

,

WASHINGTON

STATE

OF

WASHINGTON

)

COUNTY

OF

WHITMAN

JILLE

WHITMAN

SW

REDACTED

APPLICATION

FOR

SEARCH

WARRANT

(

Residence

)

Declaration

Dawn

Daniels

,

Assistant

Chief

WSU

Police

Department

,

declare

that

have

personal

knowledge

of

the

matters

herein

and

/

or

am

relying

on

witness

statements

,

information

provided

by

my

fellow

officers

,

including

fellow

officers

from

the

State

of

Idaho

,

reports

,

and

other

material

I

have

gathered

in

my

investigation

,

and

that

I

am

competent

to

testify

to

the

matters

stated

herein

:

the

basis

of

the

following

, I

believe

there

is

probable

cause

that

Bryan

Kohberger

has

committed

the

crime

(

s

)

of

Murder

First

Degree

,

Idaho

Code

(

IC

)

18-4001

,

4002

,

4003

,

4004

,

and

Burglary

,

IC

18-1401

,

1403

in

Moscow

,

Idaho

,

and

that

:

Evidence

of

those

crimes

;

Contraband

,

the

fruits

of

a

crime

,

or

things

otherwise

criminally

possessed

;

Weapons

or

other

things

by

means

of

which

a

crime

has

been

committed

or

reasonably

appears

about

to

be

committed

;

A

person

for

whose

arrest

there

is

probable

cause

,

or

who

is

unlawfully

restrained

;

Application

For

Search

Warrant

is

located

in

,

on

,

at

,

or

about

the

following

described

premises

,

vehicle

or

person

:

Apartment

located

at

1630

NE

Valley

Rd

, #

G201

,

Pullman

,

WA

.

1630

NE

Valley

Road

is

a

three

story

,

multiple

occupancy

apartment

building

in

Pullman

,

WA

which

is

tan

and

white

in

color

.

Apartment

G201

is

located

on

the

northeast

corner

of

the

Page

1

1

second

story

of

this

building

.

The

door

to

G201

is

located

on

the

east

side

of

the

second

story

2

landing

and

is

designated

by

the

numbers

201

"

on

the

door

.

The

door

is

white

,

with

a

swinging

screen

door

on

the

outside

of

the

main

door

to

the

residence

.

3

4

5

6

7

8

9

10

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Affiant

(1) I

am

a

police

officer

at

Washington

State

University

Police

Department

,

and

have

been

so

employed

since

July

20

,

1998.

I

attended

and

successfully

completed

the

440

-

hour

Washington

State

Criminal

Justice

Training

Commission's

Basic

Law

Enforcement

Academy

.

While

at

the

academy

, I

completed

courses

in

Criminal

Law

,

Criminal

Procedures

and

other

investigative

courses

.

Since

the

academy

, I

have

continued

my

education

in

various

law

enforcement

related

fields

including

Officer

Involved

Shooting

,

Evidence

Collection

,

and

Threat

Assessment

. I

have

investigated

and

assisted

in

the

service

of

over

50

search

warrants

.

Persons

providing

information

:

Moscow

,

Idaho

Police

Officer

Sgt

.

Dustin

Blaker

.

Sgt

.

Blaker's

sworn

statement

is

attached

hereto

as

Exhibit

A

,

and

is

hereby

incorporated

in

this

application

for

search

warrant

.

Sgt

.

Blaker

identifies

his

experience

and

training

in

his

statement

.

2.

Other

officers

and

witnesses

are

identified

in

Sgt

.

Blaker's

sworn

statement

.

The

Investigation

I

was

contacted

by

Moscow

police

officers

and

asked

to

assist

their

investigation

into

the

recent

murder

of

four

people

in

Moscow

,

Idaho

.

Sgt

.

Blaker

of

the

Moscow

Police

Department

has

developed

probable

cause

to

believe

that

a

resident

of

Whitman

County

,

Bryan

Kohberger

,

committed

the

murders

and

burglary

. I

agree

with

Sgt

.

Blaker's

statement

that

there

is

probable

cause

to

believe

that

Kohberger

committed

the

murders

and

burglary

and

that

there

is

probable

cause

to

believe

that

evidence

of

those

crimes

will

be

located

in

Kohberger's

apartment

at

1630

NE

Valley

Rd

,

#

G201

in

Pullman

.

I

am

seeking

this

search

warrant

to

search

that

apartment

.

The

probable

cause

is

described

in

detail

in

the

attached

Exhibit

A

,

sworn

statement

of

Sgt

.

Blaker

,

which

is

hereby

incorporated

herein

by

this

reference

,

just

as

if

fully

set

forth

here

.

Application

For

Search

Warrant

Page

2

2

3

4

5

1

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Based

on

all

the

foregoing

information

, I

believe

that

evidence

of

the

above

-

listed

crime

(

s

)

exists

at

the

above

-

described

location

,

and

that

there

is

probable

cause

to

search

that

location

for

evidence

of

the

above

-

listed

crimes

,

including

:

1.

Blood

,

or

other

bodily

fluid

or

human

tissue

or

skin

cells

,

or

items

with

blood

or

other

bodily

fluid

or

human

tissue

or

skin

cells

on

the

items

.

2.

Knives

,

sheaths

,

or

other

sharp

tools

,

including

any

dagger

,

dirk

,

or

sword

,

and

any

written

indicia

of

ownership

of

same

,

including

sales

receipts

.

3.

Any

images

,

whether

digital

or

on

paper

or

any

other

format

,

which

show

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

and

/

or

B.F.

and

/

or

the

house

at

1122

King

Road

,

Moscow

,

ID

and

/

or

the

surrounding

neighborhood

.

4.

Clothing

,

including

but

not

limited

to

dark

shirt

(

s

)

,

dark

pant

(

s

)

,

mask

(

s

)

,

shoes

with

diamond

pattern

sole

.

5.

Trace

evidence

including

DNA

from

blood

or

skin

cells

or

other

source

,

footprints

,

fingerprints

,

hair

(

whether

human

or

animal

/

dog

)

6.

Data

compilations

(

whether

digital

/

electronic

or

on

paper

or

other

format

)

showing

an

interest

in

,

or

planning

of

,

murder

,

violent

assault

,

stabbing

and

/

or

cutting

of

people

;

and

data

compilations

showing

details

of

the

1122

King

Road

house

,

its

location

,

and

/

or

any

information

about

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

B.F.

and

/

or

D.M.

and

data

compilations

showing

the

location

of

Bryan

Kohberger

,

or

the

cell

phone

with

number

509-592-8458

,

on

November

13

,

2022

,

including

wi

-

fi

logs

and

data

or

meta

-

data

associated

with

photos

,

social

media

posts

,

or

applications

on

cell

phones

or

computer

towers

/

laptops

/

tablets

.

As

example

,

but

not

Application

For

Search

Warrant

Page

3

9

7

8

10

11

12

13

2

3

4

5

6

14

1

15

16

17

20

21

19

22

18

23

24

26

25

27

28

intended

to

be

an

exclusive

list

of

data

compilations

being

sought

:

ledgers

,

papers

,

lists

,

books

,

notes

,

letters

,

calendars

,

address

books

,

contact

lists

,

diaries

,

tapes

,

photographs

,

videos

,

emails

,

text

messages

,

social

media

posts

/

messages

,

and

meta

-

data

associated

therewith

7.

Electronic

digital

devices

or

digital

storage

devices

which

may

contain

any

of

the

above

data

compilations

,

including

cell

phones

,

computer

towers

/

laptops

/

tablets

,

external

hard

drives

,

CD

/

DVD

/

Thumbdrive

or

other

data

storage

devices

.

This

includes

any

device

which

may

contain

:

Evidence

of

other

accounts

associated

with

this

device

including

email

addresses

,

social

media

accounts

,

messaging

app

accounts

,

and

other

accounts

that

may

be

accessed

through

the

digital

device

that

will

aid

in

determining

the

possessor

/

user

of

the

device

;

Photographs

,

images

,

videos

,

documents

,

and

related

data

created

,

accessed

,

read

,

modified

,

received

,

stored

,

sent

,

moved

,

deleted

or

otherwise

manipulated

between

the

above

dates

;

Evidence

of

use

of

the

device

to

conduct

internet

searches

relating

to

a

review

of

other

murders

or

violent

assaults

/

stabbing

and

/

or

cutting

of

people

,

as

well

as

how

to

avoid

detection

after

the

commission

of

such

crimes

;

details

of

the

1122

King

Road

house

,

its

location

/

neighborhood

,

and

/

or

information

about

one

or

more

of

the

victims

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

and

/

or

B.F.

D.M.

Information

that

can

be

used

to

calculate

the

position

of

the

device

between

the

above

dates

,

including

location

data

;

GPS

satellite

data

;

GPS

coordinates

for

routes

and

destination

queries

between

the

above

-

listed

dates

;

app

data

or

usage

information

and

related

location

information

;

IP

logs

or

similar

internet

connection

information

,

and

images

created

,

accessed

or

modified

between

the

above

-

listed

dates

,

together

with

their

metadata

and

EXIF

tags

;

Evidence

of

the

identity

of

the

person

in

possession

of

the

device

on

or

about

any

times

that

items

of

evidentiary

value

,

located

pursuant

to

this

warrant

,

were

created

modified

,

Application

For

Search

Warrant

Page

3

2

4

5

6

1

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

accessed

or

otherwise

manipulated

.

Such

evidence

may

be

found

in

digital

communications

,

photos

and

video

and

associated

metadata

,

IP

logs

,

documents

,

social

media

activity

,

and

similar

data

Also

,

passwords

,

phrases

,

codes

,

patterns

,

fingerprints

,

and

/

or

user

names

to

operate

any

such

device

.

8.

Indicia

of

residence

in

,

or

ownership

or

possession

of

,

the

premises

and

any

of

the

above

items

,

including

mail

,

receipts

,

identification

,

bills

,

rental

agreements

,

licensing

documents

and

other

personal

property

whose

owner

/

possessor

may

be

readily

determined

.

In

addition

, I

am

asking

the

court

to

authorize

,

in

the

service

of

the

search

warrant

,

the

use

of

assistance

from

any

law

enforcement

agencies

from

in

the

State

of

Idaho

or

the

federal

government

,

or

any

technical

specialist

associated

with

or

employed

by

or

contracted

with

such

law

enforcement

agencies

,

including

but

not

limited

to

the

Moscow

Police

Department

,

Idaho

State

Police

,

FBI

,

Idaho

State

Police

Forensic

Services

.

I

am

also

asking

for

authorization

of

assistance

from

a

technical

specialist

to

review

any

digital

devices

and

digital

media

for

the

best

and

least

intrusive

method

of

securing

digital

evidence

that

the

warrant

authorizes

for

seizure

,

and

to

assist

in

securing

such

evidence

.

Supplemental

Disclosure

re

DNA

Test

I

have

been

informed

by

Detective

JR

Talbott

of

the

Idaho

State

Police

,

that

:

1.

On

November

13

,

2022

, a

sheath

was

recovered

at

the

King

Road

Residence

under

or

next

to

the

body

of

Madison

Mogen

.

The

Idaho

State

Crime

Lab

obtained

a

male

DNA

profile

(

Suspect

Profile

)

from

the

sheath

. (

This

is

also

referred

to

in

Sgt

.

Blaker's

sworn

statement

Exhibit

A.

)

Application

For

Search

Warrant

Page

10

11

12

13

16

19

14

17

20

15

21

22

23

2

5

8

9

18

24

3

4

6

25

7

26

27

1

28

2.

On

December

27

,

2022

,

law

enforcement

agents

/

officers

in

Pennsylvania

recovered

trash

that

originated

from

the

Kohberger

family

residence

.

That

trash

was

sent

to

the

Idaho

State

Crime

Lab

for

testing

.

On

December

28

,

2022

,

the

Idaho

State

Lab

reported

that

a

DNA

profile

was

obtained

from

the

trash

;

it

was

compared

to

the

Suspect

DNA

Profile

;

the

Lab

personnel

concluded

that

the

source

of

the

trash

dna

profile

was

a

male

and

was

not

being

excluded

as

the

biological

father

of

the

source

of

the

Suspect

Profile

.

At

least

99.9998

%

of

the

male

population

would

be

expected

to

be

excluded

from

the

possibility

of

being

the

biological

father

of

the

source

of

the

Suspect

Profile

.

This

information

is

being

provided

to

the

court

pursuant

to

my

duty

and

obligation

to

be

fully

candid

with

the

court

.

I

do

not

believe

this

information

is

exculpatory

for

the

suspect

.

However

,

if

the

court

believes

it

is

exculpatory

,

then

the

court

should

consider

this

supplemental

disclosure

in

its

evaluation

of

the

existence

of

probable

cause

,

or

lack

thereof

.

But

I

am

specifically

asking

the

court

to

NOT

consider

this

supplemental

disclosure

as

evidence

supporting

the

existence

of

probable

cause

.

The

reason

for

this

request

is

that

if

the

dna

test

results

are

held

inadmissible

at

some

point

,

such

a

ruling

would

not

impact

the

finding

of

probable

cause

for

this

warrant

,

so

long

as

this

court

is

satisfied

as

to

probable

cause

regardless

of

the

dna

test

result

.

Application

For

Search

Warrant

Page

6

6

7

8

9

2

5

10

3

11

1

4

12

13

14

15

16

17

18

21

19

22

23

20

24

25

26

27

28

I

certify

under

penalty

of

perjury

under

the

laws

of

the

State

of

Washington

that

the

foregoing

is

true

and

correct

.

Signed

this

29th

day

of

December

,

2022

,

at

Pullman

,

WA

Declarant's

Signature

:

day

of

reviewed

and

considered

the

above

application

,

submitted

to

me

under

penalty

of

perjury

.

By

:

Declarant's

Full

Name

:

Dawn

Daniels

Agency

Badge

/

Serial

or

Personnel

# :

302

Agency

Name

:

Washington

State

University

Police

Dept.

Signature

:

Issuance

of

Warrant

Approved

:

Whitman

County

Prosecuting

Attorney

Application

For

Search

Warrant

SUPERIOR

COURT

JUDGE

Printed

Judge's

Name

:

[

Prosecutor

name

] ,

WSBA

#

Senior

Deputy

Prosecuting

Attorney

Criminal

Division

Page

Exhibit

A

Statement

of

Dustin

Blaker

The

below

information

is

provided

by

Sergeant

(

SGT

)

Dustin

Blaker

I

am

a

duly

appointed

qualified

and

acting

peace

officer

within

the

County

of

Latah

,

State

of

Idaho

.

I

am

employed

by

Moscow

Police

Department

(

MPD

)

in

the

official

capacity

or

position

of

Sergeant

and

I

have

been

a

trained

and

qualified

peace

officer

for

approximately

twenty

-

two

years

.

I

attended

the

Idaho

Peace

Officers

Academy

from

January

2000

to

March

of

2000

and

then

completed

a

sixteen

-

week

field

training

program

where

I

was

released

in

July

of

2000.

During

my

sixteen

years

of

law

enforcement

,

have

attended

additional

training

to

include

Basic

Narcotics

training

which

trained

me

in

handling

high

level

cases

.

I

have

conducted

many

search

warrants

and

I

have

assisted

with

previous

homicide

investigations

while

at

the

Moscow

Police

Department

.

I

am

being

assisted

by

other

officers

of

the

Moscow

Police

Department

,

members

of

the

Idaho

State

Police

(

ISP

)

and

agents

of

the

Federal

Bureau

of

Investigation

(

FBI

)

.

On

November

13

,

2022

,

at

approximately

4:00

p.m.

,

Moscow

Police

Department

Corporal

(

CPL

)

Brett

Payne

and

I

responded

to

1122

King

Road

,

Moscow

,

Idaho

,

hereafter

the

King

Road

Residence

to

assist

with

scene

security

and

processing

of

a

crime

scene

associated

with

four

homicides

.

Upon

our

arrival

,

the

Idaho

State

Police

Forensic

Team

was

on

scene

and

was

preparing

to

begin

processing

the

scene

.

MPD

Officer

(

OFC

)

Smith

,

one

of

the

initial

responding

officers

to

the

incident

,

advised

he

would

walk

me

through

the

scene

.

OFC

Smith

and

I

entered

the

King

Road

Residence

through

the

bottom

floor

door

on

the

north

side

of

the

building

OFC

Smith

and

I

then

walked

upstairs

to

the

second

floor

.

OFC

Smith

directed

me

down

the

hallway

to

the

west

bedroom

on

the

second

floor

,

which

I

later

learned

1

(

through

Xana's

driver's

license

and

other

personal

belongings

found

in

the

room

)

was

Xana

Kernodle's

,

hereafter

"

Kernodle

room

.

Just

before

this

room

there

was

a

bathroom

door

on

the

south

wall

of

the

hallway

.

As

I

approached

the

room

,

I

could

see

a

body

,

later

identified

as

Kernodle's

,

laying

on

the

floor

.

Kernodle

was

deceased

with

wounds

which

appeared

to

have

been

caused

by

an

edged

weapon

.

Also

in

the

room

was

a

male

,

later

identified

as

Ethan

Chapin

,

hereafter

,

Chapin

.

Chapin

was

also

deceased

with

wounds

later

determined

(

Autopsy

Report

provided

by

Spokane

County

Medical

Examiner

Veena

Singh

dated

December

15

,

2022

)

to

be

caused

by

sharp

-

force

injuries

then

followed

OFC

Smith

upstairs

to

the

third

floor

of

the

residence

.

The

third

floor

consisted

of

two

bedrooms

and

one

bathroom

The

bedroom

on

the

west

side

of

the

floor

was

later

determined

to

be

Kaylee

Goncalves

,

hereafter

Goncalves

room

.

I

later

learned

(

from

review

of

Officer

Nunes

body

camera

)

there

was

a

dog

in

the

room

when

Moscow

Police

Officers

initially

responded

.

The

dog

belonged

to

Goncalves

and

her

ex

-

boyfriend

Jack

Ducoeur

.

found

out

from

Cpl

.

Payne's

interview

with

Jack

Ducouer

on

November

13

,

2022

that

he

and

Goncalves

shared

the

dog

.

OFC

Smith

then

pointed

out

a

small

bathroom

on

the

east

side

of

the

third

floor

.

This

bathroom

shared

a

wall

with

Madison

Mogen's

,

hereafter

Mogen

bedroom

which

was

situated

on

the

southeast

corner

of

the

third

floor

.

As

I

entered

this

bedroom

,

I

could

see

two

females

in

the

single

bed

in

the

room

.

Both

Goncalves

and

Mogen

were

deceased

with

visible

stab

wounds

.

I

was

later

advised

by

ISP

investigators

they

located

a

tan

leather

knife

sheath

laying

on

the

bed

next

to

Mogen's

right

side

(

when

viewed

from

the

door

)

.

The

sheath

was

later

processed

and

had

Ka

-

Bar

,

USMC

and

the

United

States

Marine

Corps

eagle

globe

and

anchor

insignia

stamped

on

the

outside

of

it

.

2

The

Idaho

State

Lab

later

located

a

single

source

of

male

DNA

left

on

the

button

snap

of

the

knife

sheath

.

As

part

of

the

investigation

,

numerous

interviews

were

conducted

by

Moscow

Police

Department

Officers

,

Idaho

State

Police

Detectives

,

and

FBI

Agents

.

Two

of

the

interviews

included

(

hereafter

)

,

and

hereafter

and

inside

the

King

Road

Residence

at

the

time

of

the

homicides

and

were

roommates

to

the

victims

bedroom

was

located

on

the

east

side

of

the

first

floor

of

the

King

Road

Residence

.

Based

on

numerous

interviews

conducted

by

MPD

Officers

,

ISP

Detectives

,

and

FBI

Agents

as

well

as

my

review

of

evidence

, I

have

learned

the

following

:

the

evening

of

November

12

,

2022

,

Chapin

and

Kernodle

are

seen

by

the

Sigma

Chi

house

on

the

University

of

Idaho

campus

at

735

Nez

Perce

Drive

from

approximately

9:00

p.m.

also

stated

that

Chapin

did

not

live

in

the

King

Road

Residence

but

was

a

guest

of

Kernodle

.

Goncalves

and

Mogen

were

at

a

local

bar

,

the

Corner

Club

at

202

N.

Main

Street

,

in

Moscow

Goncalves

and

Mogen

can

be

seen

on

video

footage

provided

by

the

Corner

Club

between

10:00

p.m.

on

November

12

and

1:30

a.m.

on

November

At

approximately

1:30

a.m.

Goncalves

and

Mogen

can

be

seen

on

video

at

a

local

food

vendor

called

the

"

Grub

Truck

at

318

S.

Main

Street

in

downtown

Moscow

.

The

Grub

Truck

live

streams

video

from

their

food

truck

on

the

streaming

platform

Twitch

which

is

available

for

public

viewing

on

their

website

.

This

video

was

captured

by

law

enforcement

.

A

private

party

reported

that

he

provided

a

ride

to

3

Goncalves

and

Mogen

at

approximately

1:56

a.m.

from

downtown

Moscow

(

in

front

of

the

Grub

Truck

)

to

the

King

Road

Residence

.

and

both

made

statements

during

interviews

that

indicated

the

occupants

of

the

King

Road

Residence

were

at

home

by

2:00

a.m.

and

asleep

or

at

least

in

their

rooms

by

approximately

4:00

a.m.

This

is

with

the

exception

of

Kernodle

,

who

received

a

DoorDash

order

at

the

residence

at

approximately

4:00

a.m.

(

law

enforcement

identified

the

DoorDash

delivery

driver

who

reported

this

information

)

.

stated

she

originally

went

to

sleep

in

her

bedroom

on

the

southeast

side

of

the

second

floor

.

stated

she

was

awoken

at

approximately

4:00

a.m.

by

what

she

stated

sounded

like

Goncalves

playing

with

her

dog

in

one

of

the

upstairs

bedrooms

,

which

were

located

on

the

third

floor

.

A

short

time

later

said

she

heard

who

she

thought

was

Goncalves

say

something

to

the

effect

of

"

there's

someone

here

.

"

A

review

of

records

obtained

from

a

forensic

download

of

Kernodle's

phone

showed

this

could

also

have

been

Kernodle

as

her

cellular

phone

indicated

she

was

likely

awake

and

using

the

TikTok

app

at

approximately

4:12

a.m.

stated

she

looked

out

of

her

bedroom

but

did

not

see

anything

when

she

heard

the

comment

about

someone

being

in

the

house

.

stated

she

opened

her

door

a

second

time

when

she

heard

what

she

thought

was

crying

coming

from

Kernodle's

room

.

then

said

she

heard

a

male

voice

say

something

to

the

effect

of

it's

ok

,

I'm

going

to

help

you

.

At

approximately

4:17

a.m.

,

a

security

camera

located

at

1112

King

Road

,

a

residence

immediately

to

the

northwest

of

1122

King

Road

,

picked

up

distorted

audio

of

what

sounded

like

voices

,

or

a

whimper

followed

by

a

loud

thud

.

A

dog

can

also

be

heard

barking

numerous

times

starting

at

4:17

a.m.

The

security

camera

is

less

than

fifty

feet

from

the

west

wall

of

Kernodle's

bedroom

.

stated

she

opened

her

door

for

the

third

time

after

she

heard

the

crying

and

saw

a

figure

clad

in

black

clothing

and

a

mask

that

covered

the

person's

mouth

and

nose

walking

towards

her

described

the

figure

as

or

taller

,

male

,

not

very

muscular

,

but

athletically

built

with

bushy

eyebrows

.

The

male

walked

past

as

she

stood

in

a

frozen

shock

phase

.

"

The

male

walked

towards

the

back

sliding

glass

door

.

locked

herself

in

her

room

after

seeing

the

male

.

This

leads

investigators

to

believe

that

the

murderer

left

the

scene

.

statements

to

law

enforcement

,

reviews

of

forensic

The

combination

of

downloads

of

records

from

and

phone

,

and

video

of

a

suspect

vehicle

as

described

below

leads

investigators

to

believe

the

homicides

occurred

between

4:00

a.m.

and

4:25

a.m.

During

the

processing

of

the

crime

scene

,

investigators

found

a

latent

shoe

print

.

This

was

located

during

the

second

processing

of

the

crime

scene

by

the

ISP

Forensic

Team

by

first

using

a

presumptive

blood

test

and

then

Amino

Black

,

a

protein

stain

that

detects

the

presence

of

cellular

material

.

The

detected

shoe

print

showed

a

diamond

-

shaped

pattern

(

similar

to

the

pattern

of

a

Vans

type

shoe

sole

)

just

outside

the

door

of

bedroom

(

located

on

5

second

floor

).

This

is

consistent

with

statement

regarding

the

suspect's

path

of

travel

.

As

part

of

the

investigation

,

an

extensive

search

,

commonly

referred

to

in

law

enforcement

as

a

video

canvass

,

"

was

conducted

in

the

area

of

the

King

Road

Residence

.

This

video

canvass

was

to

obtain

any

footage

from

the

early

morning

hours

of

November

13

,

2022

,

in

the

area

of

the

King

Road

Residence

and

surrounding

neighborhoods

in

an

effort

to

locate

the

suspect

(

s

)

or

suspect

vehicle

(

s

)

traveling

to

or

leaving

from

the

King

Road

Residence

.

This

video

canvass

resulted

in

the

collection

of

numerous

surveillance

videos

in

the

area

from

both

residential

and

business

addresses

.

I

have

reviewed

numerous

videos

that

were

collected

and

have

had

conversations

with

the

other

MPD

Officers

,

ISP

Detectives

,

and

FBI

Agents

that

are

similarly

reviewing

footage

that

was

obtained

.

A

review

of

camera

footage

indicated

that

a

white

sedan

,

hereafter

Suspect

Vehicle

1

,

was

observed

traveling

westbound

in

the

700

block

of

Indian

Hills

Drive

in

Moscow

at

approximately

3:26

a.m

and

westbound

on

Styner

Avenue

at

Idaho

State

Highway

95

in

Moscow

at

approximately

3:28

a.m.

On

this

video

,

it

appeared

Suspect

Vehicle

1

was

not

displaying

a

front

license

plate

.

A

review

of

footage

from

multiple

videos

obtained

from

the

King

Road

Neighborhood

showed

multiple

sightings

of

Suspect

Vehicle

1

starting

at

3:29

a.m.

and

ending

at

4:20

a.m.

These

sightings

show

Suspect

Vehicle

1

makes

an

initial

three

passes

by

the

1122

King

Road

residence

and

then

leave

via

Walenta

Drive

.

Based

off

of

my

experience

as

a

Patrol

Officer

this

is

a

residential

neighborhood

with

a

very

limited

number

of

vehicles

that

travel

in

the

area

during

the

early

morning

hours

.

Upon

review

of

the

video

there

are

only

a

few

cars

that

enter

and

exit

this

area

during

this

time

frame

.

Suspect

Vehicle

1

can

be

seen

entering

the

area

a

fourth

time

at

approximately

4:04

a.m.

It

can

be

seen

driving

eastbound

on

King

Road

,

stopping

and

turning

around

in

front

of

500

Queen

Road

#

52

and

then

driving

back

westbound

on

King

Road

.

When

Suspect

Vehicle

1

is

in

front

of

the

King

Road

Residence

,

it

appeared

to

unsuccessfully

attempt

to

park

or

turn

around

in

the

road

.

The

vehicle

then

continued

to

the

intersection

of

Queen

Road

and

King

Road

where

it

can

be

seen

completing

a

three

-

point

turn

and

then

driving

eastbound

again

down

Queen

Road

.

Suspect

Vehicle

1

is

next

seen

departing

the

area

of

the

King

Road

Residence

at

approximately

4:20

a.m.

at

a

high

rate

of

speed

.

Suspect

Vehicle

1

is

next

observed

traveling

southbound

on

Walenta

Drive

.

Based

on

my

knowledge

of

the

area

and

review

of

camera

footage

in

the

neighborhood

that

does

not

show

Suspect

Vehicle

1

during

that

timeframe

,

I

believe

that

Suspect

Vehicle

1

likely

exited

the

neighborhood

at

Palouse

River

Drive

and

Conestoga

Drive

.

Palouse

River

Drive

is

at

the

southern

edge

of

Moscow

and

proceeds

into

Whitman

County

,

Washington

.

Eventually

the

road

leads

to

Pullman

,

Washington

.

Pullman

Washington

is

approximately

10

miles

from

Moscow

,

Idaho

.

Both

Pullman

and

Moscow

are

small

college

towns

and

people

commonly

travel

back

and

forth

between

them

.

Law

enforcement

officers

provided

video

footage

of

Suspect

Vehicle

1

to

forensic

examiners

with

the

Federal

Bureau

of

Investigation

that

regularly

utilize

surveillance

footage

to

identify

the

year

,

make

,

and

model

of

an

unknown

vehicle

that

is

observed

by

one

or

more

cameras

during

the

commission

of

a

criminal

offense

.

The

Forensic

Examiner

has

approximately

35

years

law

enforcement

experience

with

twelve

years

at

the

FBI

.

His

specific

training

includes

identifying

unique

characteristics

of

vehicles

,

and

he

uses

a

database

that

gives

visual

clues

of

vehicles

across

states

to

identify

differences

between

vehicles

.

7

After

reviewing

the

numerous

observances

of

Suspect

Vehicle

1

,

the

forensic

examiner

initially

believed

that

Suspect

Vehicle

1

was

a

2011-2013

Hyundai

Elantra

.

Upon

further

review

,

they

indicated

it

could

also

be

a

2011-2016

Hyundai

Elantra

.

As

a

result

,

investigators

have

been

reviewing

information

on

persons

in

possession

of

a

vehicle

that

is

a

2011-2016

white

Hyundai

Elantra

.

Investigators

were

given

access

to

video

footage

on

the

Washington

State

University

(

WSU

)

campus

located

in

Pullman

,

WA

.

WSU

maintains

a

series

of

surveillance

cameras

on

and

near

its

campus

.

A

review

of

that

video

indicated

that

at

approximately

2:44

a.m.

on

November

13

,

2022

,

a

white

sedan

,

which

was

consistent

with

the

description

of

the

White

Elantra

known

as

Suspect

Vehicle

1

,

was

observed

on

WSU

surveillance

cameras

travelling

north

on

southeast

Nevada

Street

at

northeast

Stadium

Way

.

At

approximately

2:53

a.m.

,

a

white

sedan

,

which

is

consistent

with

the

description

of

the

White

Elantra

known

as

Suspect

Vehicle

1

,

was

observed

traveling

southeast

on

Nevada

Street

in

Pullman

,

WA

towards

SR

270.

SR

270

connects

Pullman

,

Washington

to

Moscow

,

Idaho

.

This

camera

footage

from

Pullman

,

WA

was

provided

to

the

same

FBI

Forensic

Examiner

.

The

Forensic

Examiner

identified

the

vehicle

observed

in

Pullman

,

WA

as

being

a

2014-2016

Hyundai

Elantra

.

At

approximately

5:25

a.m.

,

a

white

sedan

,

which

was

consistent

with

the

description

of

Suspect

Vehicle

1

,

was

observed

on

five

cameras

in

Pullman

,

WA

and

on

WSU

Campus

cameras

.

The

first

camera

that

recorded

the

white

sedan

was

located

at

1300

Johnson

Road

in

Pullman

.

The

white

sedan

was

observed

traveling

northbound

on

Johnson

Road

.

Johnson

Road

leads

directly

back

to

West

Palouse

River

Drive

in

Moscow

which

intersects

with

Conestoga

Drive

The

white

sedan

was

then

observed

turning

north

on

Bishop

Boulevard

and

northwest

on

SR

270.

At

approximately

5:27

a.m.

,

the

White

Elantra

was

observed

on

cameras

traveling

8

northbound

on

Stadium

Way

at

Nevada

Street

,

Stadium

Way

at

Grimes

Way

,

Stadium

Drive

at

Wilson

Road

,

and

Stadium

Way

at

Cougar

Way

.

Depiction

showing

Moscow

and

Pullman

:

Depiction

showing

White

Elantra's

path

of

travel

(

not

to

scale

)

9

Legend

White

Elantra

seen

leaving

WSU

Campus

White

Elantra

seen

Returning

to

Campus

1630

NE

Valley

Road

Arrows

are

camera

locations

and

indicate

vehicle

direction

of

travel

Washington

State

University

10

Washington

State

University

On

November

25

,

2022

,

MPD

asked

area

law

enforcement

agencies

to

be

on

the

lookout

for

white

Hyundai

Elantras

in

the

area

.

On

November

29

,

2022

,

at

approximately

12:28

a.m.

,

Washington

State

University

(

WSU

)

Police

Officer

Daniel

Tiengo

,

queried

white

Elantras

registered

at

WSU

.

As

a

result

of

that

query

he

located

a

2015

white

Elantra

with

a

Pennsylvania

license

plate

LFZ

-

8649

.

This

vehicle

was

registered

to

Bryan

Kohberger

hereafter

Kohberger

residing

at

1630

NE

Valley

Road

,

Apartment

201

,

Pullman

,

Washington

.

1630

NE

Valley

Road

is

approximately

three

-

quarters

of

a

mile

from

the

intersection

of

Stadium

Way

and

Cougar

Way

(

last

camera

location

that

picked

up

the

white

Elantra

)

.

That

same

day

at

approximately

12:58

a.m.

,

WSU

Officer

Curtis

Whitman

was

looking

for

white

Hyundai

Elantra's

and

located

a

2015

white

Hyundai

Elantra

at

1630

NE

Valley

Road

in

Pullman

in

the

parking

lot

.

1630

NE

Valley

Road

is

an

apartment

complex

that

houses

students

.

Officer

Whitman

also

ran

the

car

and

it

returned

to

Kohberger

with

a

Washington

tag

.

I

reviewed

Kohberg's

WA

state

driver

license

information

and

photograph

.

This

license

indicates

that

Kohberger

is

a

white

male

with

a

height

of

6

and

weighs

185

pounds

.

Additionally

,

the

photograph

of

Kohberger

shows

that

he

has

bushy

eyebrows

.

Kohberger's

physical

description

is

consistent

with

the

description

of

the

male

saw

inside

the

King

Road

Residence

on

November

Further

investigation

,

including

a

review

of

Latah

County

Sheriff's

Deputy

Corporal

(

CPL

)

Duke's

body

cam

and

reports

,

showed

that

on

August

21

,

2022

,

Bryan

Kohberger

was

detained

as

part

of

a

traffic

stop

that

occurred

in

Moscow

,

Idaho

,

by

CPL

Duke

.

At

the

time

,

Kohberger

,

who

was

the

sole

occupant

,

was

driving

a

white

2015

Hyundai

Elantra

with

Pennsylvania

plate

LFZ

-

8649

which

was

set

to

expire

on

November

30

,

2022.

During

the

stop

,

which

was

recorded

via

a

law

enforcement

body

camera

,

Kohberger

provided

his

phone

number

as

509-592-8458

,

hereafter

the

"

8458

Phone

as

his

cellular

telephone

number

.

Investigators

conducted

electronic

database

queries

and

learned

that

the

8458

Phone

is

a

number

issued

by

AT

& T .

On

October

14

,

2022

,

Bryan

Kohberger

was

detained

as

part

of

a

traffic

stop

by

a

WSU

Police

Officer

.

Upon

review

of

that

body

cam

and

report

of

the

stop

,

Kohberger

was

the

sole

occupant

and

was

driving

a

white

2015

Hyundai

Elantra

with

Pennsylvania

plate

LFZ

-

8649

.

11

November

18

,

2022

,

according

to

WA

state

licensing

,

Kohberger

registered

the

2015

white

Elantra

with

WA

and

later

received

WA

plate

CFB

-

8708

.

Prior

to

this

time

,

the

2015

white

Elantra

was

registered

in

Pennsylvania

,

which

does

not

require

a

front

license

plate

to

be

displayed

(

this

was

learned

through

communications

with

a

Pennsylvania

officer

who

is

currently

certified

in

the

State

of

Pennsylvania

)

.

Based

on

my

own

experience

and

communication

with

Washington

law

enforcement

,I

know

that

Idaho

and

Washington

require

front

and

back

license

plates

to

be

displayed

.

Investigators

believe

that

Kohberger

is

still

driving

the

2015

white

Elantra

because

his

vehicle

was

captured

on

December

13

,

2022

,

by

a

license

plate

reader

in

Loma

,

Colorado

(

information

provided

by

a

query

to

a

database

)

.

Kohberger's

Elantra

was

then

queried

on

December

15

,

2022

by

law

enforcement

in

Hancock

County

,

Indiana

.

On

December

16

,

2022

at

approximately

2:26

p.m.

,

surveillance

video

showed

Kohberger's

Elantra

in

Albrightsville

,

Pennsylvania

.

The

sole

occupant

of

the

vehicle

was

a

white

male

whose

description

was

consistent

with

Kohberger

.

Kohberger

has

family

in

Albrightsville

,

Pennsylvania

(

learned

through

TLO

which

is

a

search

and

locate

tool

database

query

used

by

law

enforcement

)

.

Based

on

information

provided

on

the

WSU

website

,

Kohberger

is

currently

a

Ph.D

Student

in

Criminology

at

Washington

State

University

.

Pursuant

to

records

provided

by

a

member

of

the

interview

panel

for

Pullman

Police

Department

,

we

learned

that

Kohberger's

past

education

included

undergraduate

degrees

in

psychology

and

cloud

-

based

forensics

.

These

records

also

showed

Kohberger

wrote

an

essay

when

he

applied

for

an

internship

with

the

Pullman

Police

Department

in

the

fall

of

2022.

Kohberger

wrote

in

his

essay

he

had

interest

in

assisting

rural

law

enforcement

agencies

with

how

to

better

collect

and

analyze

technological

data

in

public

safety

operations

.

Kohberger

also

posted

a

Reddit

survey

which

can

be

found

by

12

an

open

-

source

internet

search

.

The

survey

asked

for

participants

to

provide

information

to

understand

how

emotions

and

psychological

traits

influence

decision

making

when

committing

a

crime

.

As

part

of

this

investigation

,

law

enforcement

obtained

search

warrants

to

determine

cellular

devices

that

utilized

cellular

towers

in

close

proximity

to

the

King

Road

Residence

on

November

13

,

2022

between

3:00

a.m.

and

5:00

a.m.

After

determining

that

Kohberger

was

associated

to

both

the

2015

White

Elantra

and

the

8458

Phone

,

investigators

reviewed

these

search

warrant

returns

.

A

query

of

the

8458

Phone

in

these

returns

did

not

show

the

8458

Phone

utilizing

cellular

tower

resources

in

close

proximity

to

the

King

Road

Residence

between

3:00

a.m.

and

5:00

a.m.

Based

on

my

training

,

experience

,

and

conversations

with

law

enforcement

officers

that

specialize

in

the

utilization

of

cellular

telephone

records

as

part

of

investigations

,

individuals

can

either

leave

their

cellular

telephone

at

a

different

location

before

committing

a

crime

or

turn

their

cellular

telephone

off

prior

to

going

to

a

location

to

commit

a

crime

.

This

is

done

by

subjects

in

an

effort

to

avoid

alerting

law

enforcement

that

a

cellular

device

associated

with

them

was

in

a

particular

area

where

a

crime

is

committed

.

I

also

know

that

on

numerous

occasions

,

subjects

will

surveil

an

area

where

they

intend

to

commit

a

crime

prior

to

the

date

of

the

crime

.

Depending

on

the

circumstances

,

this

could

be

done

a

few

days

before

or

for

several

months

prior

to

the

commission

of

a

crime

.

During

these

types

of

surveillance

,

it

is

possible

that

an

individual

would

not

leave

their

cellular

telephone

at

a

separate

location

or

it

off

since

they

do

not

plan

to

commit

the

offense

on

that

particular

day

13

On

December

23

,

2022

,

Cpl

.

Payne

applied

for

and

was

granted

a

search

warrant

for

historical

phone

records

between

November

12

,

2022

at

12:00

a.m.

and

November

14

,

at

12:00

a.m.

for

the

8458

Phone

held

by

the

phone

provider

AT

&

T

(

approximately

24

hours

proceeding

and

following

the

times

of

the

homicides

)

.

On

December

23

,

2022

,

pursuant

to

that

search

warrant

,

Cpl

,

Payne

received

records

for

the

8458

Phone

from

AT

&

T

.

These

records

indicated

that

the

8458

Phone

is

subscribed

to

Bryan

Kohberger

at

an

address

in

Albrightsville

,

Pennsylvania

and

the

account

has

been

open

since

June

23

,

2022.

These

records

also

included

historical

cell

site

location

information

(

CSLI

)

for

the

8458

Phone

.

After

receiving

this

information

,

MPD

consulted

with

an

FBI

Special

Agent

(

SA

)

that

is

certified

as

a

member

of

the

Cellular

Analysis

Survey

Team

(

CAST

)

Members

of

CAST

are

certified

with

the

FBI

to

provide

expert

testimony

in

the

field

of

historical

CSLI

and

are

required

to

pass

extensive

training

that

includes

both

written

and

practical

examinations

prior

to

be

certified

with

CAST

as

well

as

the

completion

of

yearly

certification

requirements

.

Additionally

,

the

FBI

CAST

SA

that

I

consulted

with

has

over

fifteen

years

of

federal

law

enforcement

experience

,

which

includes

six

years

with

the

FBI

.

From

information

provided

by

CAST

,

investigators

were

able

to

determine

estimated

locations

for

the

8458

Phone

from

November

12

,

2022

to

November

13

,

2022

,

the

time

period

authorized

by

the

court

.

On

November

13

,

2022

at

approximately

2:42

a.m.

,

the

8458

Phone

was

utilizing

cellular

resources

that

provide

coverage

to

1630

Northeast

Valley

Road

,

Apt

G201

,

Pullman

,

WA

,

hereafter

the

Kohberger

Residence

.

"

At

approximately

2:47

a.m.

,

the

8458

Phone

utilized

cellular

resources

that

provide

coverage

southeast

of

the

Kohberger

Residence

consistent

with

the

8458

Phone

leaving

the

Kohberger

Residence

and

traveling

south

through

Pullman

,

WA

.

This

is

consistent

with

the

movement

of

the

white

Elantra

.

At

approximately

2:47

a.m.

the

8458

14

Phone

stops

reporting

to

the

network

,

which

is

consistent

with

either

the

phone

being

in

an

area

without

cellular

coverage

,

the

connection

to

the

network

is

disabled

(

such

as

putting

the

phone

in

airplane

mode

)

,

or

that

the

phone

is

turned

off

.

The

8458

Phone

does

not

report

to

the

network

again

until

approximately

4:48

a.m.

at

which

time

it

utilized

cellular

resources

that

provide

coverage

to

ID

state

highway

95

south

of

Moscow

,

ID

near

Blaine

,

ID

(

town

north

of

Genesee

)

.

Between

4:50

a.m.

and

5:26

a.m.

,

the

phone

utilizes

cellular

resources

that

are

consistent

with

the

8458

Phone

traveling

south

on

ID

state

highway

95

to

Genesee

,

ID

,

then

traveling

west

towards

Uniontown

,

ID

,

and

then

north

back

into

Pullman

,

WA

.

At

approximately

5:30

a.m.

,

the

8458

Phone

is

utilizing

resources

that

provide

coverage

to

Pullman

,

WA

and

consistent

with

the

phone

traveling

back

to

the

Kohberger

Residence

.

The

8458

Phone's

movements

are

consistent

with

the

movements

of

the

white

Elantra

that

is

observed

traveling

north

on

Stadium

Drive

at

approximately

5:27

a.m.

Based

on

a

review

of

the

8458

Phone's

estimated

locations

and

travel

,

the

8458

Phone's

travel

is

consistent

with

that

of

the

white

Elantra

.

Further

review

indicated

that

the

8458

Phone

utilized

cellular

resources

on

November

13

,

2022

that

are

consistent

with

the

8458

Phone

leaving

the

area

of

the

Kohberger

Residence

at

approximately

9:00

a.m.

and

traveling

to

Moscow

,

ID

.

Specifically

,

the

8458

Phone

utilized

cellular

resources

that

would

provide

coverage

to

the

King

Road

Residence

between

9:12

a.m.

and

9:21

a.m.

The

8458

Phone

next

utilized

cellular

resources

that

are

consistent

with

the

8458

Phone

traveling

back

to

the

area

of

the

Kohberger

Residence

and

arriving

to

the

area

at

approximately

9:32

a.m.

15

Below

is

a

depiction

(

not

to

scale

)

of

the

possible

route

taken

based

off

of

cellular

site

locations

:

This

is

Investigators

found

that

the

8458

Phone

did

connect

to

a

cell

phone

tower

that

provides

service

to

Moscow

on

November

14

,

2022

,

but

investigators

do

not

believe

the

8458

Phone

was

in

Moscow

on

that

date

.

The

8458

Phone

has

not

connected

to

any

towers

that

provide

service

to

Moscow

since

that

date

.

Based

on

my

training

,

experience

,

and

the

facts

of

the

investigation

thus

far

,I

believe

that

Kohberger

,

the

user

of

the

8458

Phone

,

was

likely

the

driver

of

the

white

Elantra

that

is

observed

departing

Pullman

,

WA

and

that

this

vehicle

is

likely

Suspect

Vehicle

1.

Additionally

,

the

route

of

travel

of

the

8458

Phone

during

the

early

morning

hours

of

November

13

,

2022

and

the

lack

of

the

8458

Phone

reporting

to

AT

&

T

between

2:47

a.m.

and

4:48

a.m.

is

consistent

with

16

Kohberger

attempting

to

conceal

his

location

during

the

quadruple

homicide

that

occurred

at

the

King

Road

Residence

.

On

December

23

,

2022

,

I

was

granted

a

search

warrant

for

Kohberger's

historical

CSLI

from

June

23

,

2022

to

current

,

prospective

location

information

,

and

a

Pen

Register

Trap

and

Trace

on

the

8458

Phone

to

aid

in

efforts

to

determine

if

Kohberger

stalked

any

of

the

victims

in

this

case

prior

to

the

offense

,

conducted

surveillance

on

the

King

Road

Residence

,

was

in

contact

with

any

of

the

victims

associates

before

or

after

the

alleged

offense

,

any

locations

that

may

contain

evidence

of

the

murders

that

occurred

on

November

13

,

2022

,

the

location

of

the

white

Elantra

registered

to

Kohberger

,

as

well

as

the

location

of

Kohberger

.

On

December

23

,

2022

pursuant

to

that

search

warrant

,

investigators

received

historical

records

for

the

8458

Phone

from

AT

&

T

from

the

time

the

account

was

opened

in

June

2022

.

After

consulting

with

the

CAST

SA

,

investigators

were

able

to

determine

estimated

locations

for

the

8458

Phone

from

June

2022

to

present

,

the

time

period

authorized

by

the

court

.

The

records

for

the

8458

Phone

show

the

8458

Phone

utilizing

cellular

resources

that

provide

coverage

to

the

area

of

1122

King

Road

on

at

least

twelve

occasions

prior

to

November

13

,

2022.

All

of

these

occasions

,

except

for

one

,

occurred

in

the

late

evening

and

early

morning

hours

of

their

respective

days

.

One

of

these

occasions

,

on

August

21

,

2022

,

the

8458

Phone

utilized

cellular

resources

providing

coverage

to

the

King

Road

Residence

from

approximately

10:34

p.m.

to

11:35

p.m.

At

approximately

11:37

p.m.

,

Kohberger

was

stopped

by

Latah

County

Sheriff's

Deputy

Corporal

Duke

,

as

mentioned

above

.

The

8548

Phone

was

utilizing

cellular

resources

consistent

with

the

location

of

the

traffic

stop

during

this

time

(

Farm

Road

and

Pullman

Highway

)

17

Further

analysis

of

the

cellular

data

provided

showed

the

8458

Phone

utilized

cellular

resources

on

November

13

,

2022

consistent

with

the

Phone

travelling

from

Pullman

,

Washington

to

Lewiston

,

Idaho

via

US

Highway

195.

At

approximately

12:36

p.m.

,

the

8458

Phone

utilized

cellular

resources

that

would

provide

coverage

to

Kate's

Cup

of

Joe

coffee

stand

located

at

810

Port

Drive

,

Clarkston

,

WA

.

Surveillance

footage

from

the

US

Chef's

Store

located

at

820

Port

Drive

,

Clarkston

,

WA

and

adjacent

to

Kate's

Cup

of

Joe

showed

a

white

Elantra

,

consistent

with

Suspect

Vehicle

1

,

drive

past

Kate's

Cup

of

Joe

at

a

time

consistent

with

the

cellular

data

from

the

8548

Phone

.

At

approximately

12:46

p.m.

,

the

8458

Phone

then

utilized

cellular

data

in

the

area

of

the

Albertson's

grocery

store

at

400

Bridge

Street

in

Clarkston

,

Washington

.

Surveillance

footage

obtained

from

the

Albertson's

showed

Kohberger

exit

the

white

Elantra

,

consistent

with

Suspect

Vehicle

1

,

at

approximately

12:49

p.m.

Interior

surveillance

cameras

showed

Kohberger

walk

through

the

store

,

purchase

unknown

items

at

the

checkout

,

and

leave

at

approximately

1:04

p.m.

Kohberger's

possible

path

of

travel

is

depicted

below

(

not

to

scale

)

18

Additional

analysis

of

records

for

the

8458

Phone

indicated

that

between

approximately

5:32

p.m.

and

5:36

p.m.

,

the

8458

Phone

utilized

cellular

resources

that

provide

coverage

to

Johnson

,

WA

.

The

8458

Phone

then

stops

reporting

to

the

network

from

approximately

5:36

p.m.

to

8:30

p.m.

That

is

consistent

with

the

8458

Phone

being

the

area

that

the

8458

Phone

traveled

in

the

hours

immediately

following

the

suspected

time

the

homicides

occurred

.

19

The

King

Road

Residence

contained

a

significant

amount

of

blood

from

the

victims

including

spatter

and

castoff

(

blood

stain

pattern

resulting

from

blood

drops

released

from

an

object

due

to

its

motion

)

which

,

based

on

my

training

,

makes

it

likely

that

this

evidence

was

transferred

to

Kohberger's

person

,

clothing

,

or

shoes

.

Based

on

the

locations

of

the

suspect

vehicle

and

the

8458

phone

immediately

following

the

murders

,

it

is

probable

that

Kohberger

went

home

to

his

residence

at

1630

NE

Valley

Rd

,

G201

.

At

that

time

,

it

is

likely

that

he

still

had

blood

or

other

trace

evidence

on

his

person

/

clothes

/

shoes

,

including

skin

cells

or

hair

from

the

victims

or

from

Goncalves

dog

.

It

is

likely

that

some

trace

evidence

was

transferred

to

areas

in

his

apartment

through

contact

with

the

items

worn

during

the

attack

.

One

likely

location

for

the

clothes

/

mask

/

shoes

that

he

was

wearing

during

the

attack

would

be

his

residence

.

While

I

believe

Kohberger

is

visiting

family

in

Pennsylvania

over

the

current

school

break

at

WSU

,

I

believe

he

intends

to

return

for

the

start

of

the

next

semester

,

so

I

expect

his

belongings

to

still

be

in

his

residence

at

1630

NE

Valley

Rd

,

G201

.

To

-

date

,

we

have

not

recovered

the

weapon

used

in

the

homicides

which

would

indicate

that

he

took

it

with

him

from

the

scene

.

Based

on

my

training

,

that

weapon

will

likely

contain

trace

evidence

on

it

,

such

as

blood

or

skin

or

hair

from

the

crime

scene

.

One

likely

location

for

the

weapon

or

any

sheath

for

the

weapon

would

be

his

residence

.

Based

on

my

training

and

experience

when

someone

plans

an

event

or

action

,

one

likely

location

for

doing

so

is

in

their

residence

or

office

.

One

would

not

want

to

conduct

such

planning

in

public

if

they

are

planning

a

criminal

act

,

and

so

it

is

even

more

likely

that

planning

of

a

criminal

act

would

be

done

one's

residence

or

office

.

These

murders

appear

to

have

been

planned

,

rather

than

a

crime

that

happened

in

a

moment

of

conflict

.

I

believe

it

likely

that

Kohberger

planned

his

actions

ahead

of

time

.

The

plans

may

have

included

a

review

of

other

murders

or

violent

assaults

/

stabbing

and

/

or

cutting

of

people

,

as

well

as

how

to

avoid

detection

after

the

commission

of

such

crimes

;

details

of

the

1122

King

Road

Residence

,

its

location

/

neighborhood

,

and

/

or

information

about

one

or

more

of

the

victims

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

and

/

or

D.M.

Further

based

on

my

training

and

experience

criminals

utilize

electronic

digital

devices

as

well

as

paper

or

other

media

in

conducting

planning

of

crimes

,

just

as

non

-

criminals

use

various

media

to

plan

activities

.

Therefore

there

is

probable

cause

to

believe

that

digital

devices

were

used

20

and

/

or

are

being

used

in

furtherance

of

the

listed

crime

(

s

)

or

to

avoid

detection

for

the

listed

crimes

,

and

likely

contain

evidence

of

the

listed

crimes

.

Evidence

of

the

crimes

described

in

this

application

could

be

contained

in

any

type

of

digital

device

.

The

terms

digital

device

"

and

"

device

"

include

all

devices

capable

of

capturing

and

/

or

storing

digital

data

,

such

as

computers

,

digital

cameras

,

modems

,

routers

,

external

memory

drives

,

thumb

drives

,

cellular

telephones

,

GPS

navigation

devices

,

etc.

Data

stored

on

digital

devices

and

media

can

be

easily

transferred

from

one

device

or

storage

media

to

another

.

Forensic

experts

and

others

with

experience

in

retrieving

and

analyzing

digital

data

have

established

the

following

:

Digital

devices

typically

retain

some

evidence

of

all

activity

taken

via

the

device

or

associated

media

;

and

,

as

such

,

could

contain

evidence

of

crime

.

For

example

,

data

,

whether

stored

intentionally

or

unintentionally

,

can

contain

evidence

of

knowledge

,

intent

,

efforts

to

conceal

,

sell

or

dispose

of

evidence

or

proceeds

of

criminal

activity

,

accomplice

identity

,

association

with

victims

,

or

geographic

location

of

the

device

possessor

at

particular

dates

and

times

.

This

information

can

be

in

numerous

forms

,

such

as

photographs

address

books

or

contact

lists

or

communications

with

others

through

means

such

as

phone

calls

,

email

,

instant

messaging

,

social

media

,

chat

sessions

,

or

other

digital

communications

.

Evidence

can

remain

on

the

device

or

media

for

indefinite

periods

of

time

after

the

communication

originally

took

place

,

even

if

deleted

by

the

user

.

Information

deleted

by

the

user

may

be

recovered

by

a

forensic

examiner

throughout

the

working

life

span

of

the

device

.

Digital

data

can

be

found

in

numerous

locations

,

and

formats

.

Evidence

can

be

embedded

into

unlikely

files

for

the

type

of

evidence

,

such

as

a

photo

included

in

a

document

or

21

converted

into

a

PDF

file

or

other

format

in

an

effort

to

conceal

their

existence

.

Information

on

devices

and

media

can

be

stored

in

random

order

;

with

deceptive

file

names

;

hidden

from

normal

view

;

encrypted

or

password

protected

;

and

stored

on

unusual

devices

for

the

type

of

data

,

such

as

routers

,

printers

,

scanners

,

game

consoles

,

or

other

devices

that

are

similarly

capable

of

storing

digital

data

.

Wholly

apart

from

user

-

generated

files

and

data

,

digital

devices

and

media

typically

store

,

often

without

any

conscious

action

by

the

user

,

electronic

evidence

pertaining

to

virtually

all

actions

taken

on

the

digital

device

,

and

often

information

about

the

geographic

location

at

which

the

device

was

turned

on

and

/

or

used

.

This

data

includes

logs

of

device

use

;

records

of

the

creation

,

modification

,

deletion

,

and

/

or

sending

of

files

;

and

uses

of

the

internet

,

such

as

uses

of

social

media

websites

and

internet

searches

/

browsing

.

Device

-

generated

data

also

includes

information

regarding

the

user

identity

at

any

particular

date

and

time

;

usage

logs

and

information

pertaining

to

the

physical

location

of

the

device

over

time

;

pointers

to

outside

storage

locations

,

such

as

cloud

storage

,

or

devices

to

which

data

may

have

been

removed

,

and

information

about

how

that

offsite

storage

is

being

used

.

If

the

device

is

synced

with

other

devices

,

it

will

retain

a

record

of

that

action

.

Digital

device

users

typically

do

not

erase

or

delete

this

evidence

,

because

special

software

or

use

of

special

settings

are

usually

required

for

the

task

.

However

,

it

is

technically

possible

to

delete

this

information

.

Digital

devices

can

also

reveal

clues

to

other

locations

at

which

evidence

may

be

found

.

For

example

,

digital

devices

often

maintain

logs

of

connected

digital

or

remote

storage

devices

.

A

scanner

or

printer

may

store

information

that

would

identify

the

digital

device

with

which

it

was

used

Forensic

examination

of

the

device

can

often

reveal

those

other

locations

where

evidence

may

be

present

.

22

As

with

other

types

of

evidence

,

the

context

,

location

,

and

data

surrounding

information

in

the

device

data

is

often

necessary

to

understand

whether

evidence

falls

within

the

scope

of

the

warrant

.

This

type

of

information

will

be

important

to

the

forensic

examiner's

ability

to

piece

together

and

recognize

evidence

of

the

above

-

listed

crimes

.

Digital

device

programs

frequently

require

passwords

,

phrases

,

codes

,

patterns

,

fingerprints

,

and

/

or

usernames

to

operate

.

Those

may

be

kept

inside

a

device

/

media

,

or

outside

in

some

other

area

known

to

the

user

.

So

,

in

addition

to

searching

a

digital

device

and

media

for

evidence

of

the

above

-

listed

crime

(

s

)

,

investigators

will

need

to

search

both

the

premises

searched

,

and

the

digital

device

(

s

)

for

this

information

.

The

forensic

examiner

may

also

need

the

following

items

in

order

to

conduct

a

thorough

and

accurate

search

of

the

devices

:

computer

hardware

,

software

,

peripherals

,

internal

or

external

storage

devices

,

power

supplies

,

cables

;

internet

connection

and

use

information

;

security

devices

;

software

;

manuals

;

and

related

material

.

digital

devices

and

media

can

contain

many

gigabytes

and

even

terabytes

of

data

.

Due

to

the

potential

for

an

extremely

large

volume

of

data

contained

in

devices

and

media

,

and

that

fact

that

evidence

can

be

stored

/

located

in

unanticipated

locations

or

formats

and

/

or

embedded

in

other

items

stored

on

the

device

/

media

,

investigators

typically

need

to

use

specialized

equipment

in

their

search

.

Such

large

volumes

of

data

also

mean

that

searches

can

take

days

or

even

weeks

to

complete

.

For

these

reasons

,

I

request

authority

to

remove

from

the

search

location

all

digital

devices

and

media

that

could

contain

evidence

authorized

for

seizure

under

the

warrant

for

subsequent

search

23

also

request

authority

to

obtain

assistance

from

a

technical

specialist

,

to

review

the

digital

device

(

s

)

and

digital

media

for

the

best

and

least

intrusive

method

of

securing

digital

evidence

that

this

warrant

authorizes

for

seizure

,

and

to

assist

in

securing

such

evidence

.

Based

on

all

the

foregoing

information

,

there

is

probable

cause

to

believe

that

evidence

of

the

above

-

listed

crimes

exists

in

the

below

described

digital

devices

and

that

there

is

probable

cause

to

seize

and

search

those

devices

for

the

evidence

of

the

above

crimes

for

the

date

range

August

21

,

2022

to

11:59

p.m.

on

November

14

,

2022

including

:

Evidence

of

other

accounts

associated

with

this

device

including

email

addresses

,

social

media

accounts

,

messaging

"

app

accounts

,

and

other

accounts

that

may

be

accessed

through

the

digital

device

that

will

aid

in

determining

the

possessor

user

of

the

device

;

Photographs

,

images

,

videos

,

documents

,

and

related

data

created

,

accessed

,

read

,

modified

,

received

,

stored

,

sent

,

moved

,

deleted

or

otherwise

manipulated

between

the

above

dates

;

Evidence

of

use

of

the

device

to

conduct

internet

searches

relating

to

a

review

of

other

murders

or

violent

assaults

/

stabbing

and

/

or

cutting

of

people

,

as

well

as

how

to

avoid

detection

after

the

commission

of

such

crimes

;

details

of

the

1122

King

Road

house

,

its

location

/

neighborhood

,

and

/

or

information

about

one

or

more

of

the

victims

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

B.F.

D.M.

Information

that

can

be

used

to

calculate

the

position

of

the

device

between

the

above

dates

,

including

location

data

;

GPS

satellite

data

;

GPS

coordinates

for

routes

and

destination

queries

between

the

above

-

listed

dates

;

app

data

or

usage

information

and

related

location

information

;

IP

logs

or

similar

internet

connection

information

,

and

24

and

/

or

images

created

,

accessed

or

modified

between

the

above

-

listed

dates

,

together

with

their

metadata

and

EXIF

tags

;

Evidence

of

the

identity

of

the

person

in

possession

of

the

device

on

or

about

any

times

that

items

of

evidentiary

value

,

located

pursuant

to

this

warrant

,

were

created

modified

accessed

or

otherwise

manipulated

.

Such

evidence

may

be

found

in

digital

communications

,

photos

and

video

and

associated

metadata

,

IP

logs

,

documents

,

social

media

activity

,

and

similar

data

;

Based

on

ISP

Investigators

view

of

the

apartment

on

December

27

,

2022

,

I

know

that

1630

NE

Valley

Road

is

a

three

story

,

multiple

occupancy

apartment

building

in

Pullman

,

WA

which

is

tan

and

white

in

color

.

Apartment

G201

is

located

on

the

northeast

corner

of

the

second

story

of

this

building

.

The

door

to

G201

is

located

on

the

east

side

of

the

second

story

landing

and

is

designated

by

the

numbers

201

"

on

the

door

.

The

door

is

white

,

with

a

swinging

screen

door

on

the

outside

of

the

main

door

to

the

residence

.

Kohberger

has

been

identified

as

the

occupant

of

this

apartment

on

leasing

documents

obtained

via

subpoena

as

part

of

this

investigation

.

Investigators

have

been

informed

via

the

postal

inspector

that

Kohberger

is

the

only

person

receiving

mail

at

Apartment

G201

,

this

leads

investigators

to

believe

he

is

the

sole

occupant

.

25

Based

on

all

of

the

above

information

,

I

conclude

that

there

is

a

probability

that

Kohberger

committed

the

four

murders

at

the

King

Road

Residence

.

I

have

probable

cause

to

believe

evidence

of

the

crimes

committed

at

the

King

Road

Residence

will

be

found

at

Kohberger's

Residence

located

at

1630

NE

Valley

Road

,

Apt.G201

,

Pullman

,

WA

.

I

have

probable

cause

to

believe

that

Bryan

Kohberger

committed

the

crimes

of

Murder

First

Degree

,

Idaho

Code

18-4001

,

4002

,

4003

,

4004

in

four

counts

and

Burglary

,

I.C.

18-1401

,

1403

,

all

Felonies

Mr.

Kohberger

has

been

charged

with

the

above

offenses

in

Latah

County

,

Idaho

.

Based

on

all

of

the

above

information

,I

am

seeking

a

search

warrant

for

the

Kohberger

Residence

,

to

search

for

:

1.

Blood

,

or

other

bodily

fluid

or

human

tissue

or

skin

cells

,

or

items

with

blood

or

other

bodily

fluid

or

human

tissue

or

skin

cells

on

the

items

.

2.

Knives

,

sheaths

,

or

other

sharp

tools

,

including

any

dagger

,

dirk

,

or

sword

,

and

any

written

indicia

of

ownership

of

same

,

including

sales

receipts

.

3.

Any

images

,

whether

digital

or

on

paper

or

any

other

format

,

which

show

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

B.F.

and

/

or

and

/

or

the

house

at

1122

King

Road

,

Moscow

,

ID

and

/

or

the

surrounding

neighborhood

.

4.

Clothing

,

including

but

not

limited

to

dark

shirt

(

s

)

,

dark

pant

(

s

),

mask

(

s

),

shoes

with

diamond

pattern

sole

.

5.

Trace

evidence

including

DNA

from

blood

or

skin

cells

or

other

source

,

footprints

,

fingerprints

,

hair

(

whether

human

or

animal

/

dog

).

6.

Data

compilations

(

whether

digital

/

electronic

or

on

paper

or

other

format

)

showing

an

interest

in

,

or

planning

of

,

murder

,

violent

assault

,

stabbing

and

/

or

cutting

of

people

;

and

data

compilations

showing

details

of

the

1122

King

Road

house

,

its

location

,

and

/

or

any

information

about

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

and

/

or

and

data

compilations

showing

the

location

of

Bryan

Kohberger

,

or

the

cell

phone

with

number

509-592-8458

,

on

November

13

,

2022

,

26

including

wi

-

fi

logs

and

data

or

meta

-

data

associated

with

photos

,

social

media

posts

,

or

applications

on

cell

phones

or

computer

towers

/

laptops

/

tablets

.

As

example

,

but

not

intended

to

be

an

exclusive

list

of

data

compilations

being

sought

:

ledgers

,

papers

,

lists

,

books

,

notes

,

letters

,

calendars

,

address

books

,

contact

lists

,

diaries

,

tapes

,

photographs

,

videos

,

emails

,

text

messages

,

social

media

posts

/

messages

,

and

meta

-

data

associated

therewith

7.

Electronic

digital

devices

or

digital

storage

devices

which

may

contain

any

of

the

above

data

compilations

,

including

cell

phones

,

computer

towers

/

laptops

/

tablets

,

external

hard

drives

,

CD

/

DVD

/

Thumbdrive

or

other

data

storage

devices

.

This

includes

any

device

which

may

contain

:

e

Evidence

of

other

accounts

associated

with

this

device

including

email

addresses

,

social

media

accounts

,

messaging

app

accounts

,

and

other

accounts

that

may

be

accessed

through

the

digital

device

that

will

aid

in

determining

the

possessor

/

user

of

the

device

;

Photographs

,

images

,

videos

,

documents

,

and

related

data

created

,

accessed

,

read

modified

,

received

,

stored

,

sent

,

moved

,

deleted

or

otherwise

manipulated

between

the

above

dates

Evidence

of

use

of

the

device

to

conduct

internet

searches

relating

to

a

review

of

other

murders

or

violent

assaults

/

stabbing

and

/

or

cutting

of

people

,

as

well

as

how

to

avoid

detection

after

the

commission

of

such

crimes

;

details

of

the

1122

King

Road

house

,

its

location

/

neighborhood

,

and

/

or

information

about

one

or

more

of

the

victims

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

and

/

or

B.F.

D.M.

Information

that

can

be

used

to

calculate

the

position

of

the

device

between

the

above

dates

,

including

location

data

GPS

satellite

data

;

GPS

coordinates

for

routes

and

destination

queries

between

the

above

-

listed

dates

;

app

data

or

usage

information

and

related

location

information

;

IP

logs

or

similar

internet

connection

information

,

and

images

created

,

accessed

or

modified

between

the

above

-

listed

dates

,

together

with

their

metadata

and

EXIF

tags

;

27

Evidence

of

the

identity

of

the

person

in

possession

of

the

device

on

or

about

any

times

that

items

of

evidentiary

value

,

located

pursuant

to

this

warrant

,

were

created

modified

accessed

or

otherwise

manipulated

.

Such

evidence

may

be

found

in

digital

communications

,

photos

and

video

and

associated

metadata

,

IP

logs

,

documents

,

social

media

activity

,

and

similar

data

;

Also

,

passwords

,

phrases

,

codes

,

patterns

,

fingerprints

,

and

/

or

user

names

to

operate

any

such

device

.

8.

Indicia

of

residence

in

,

or

ownership

or

possession

of

,

the

premises

and

any

of

the

above

items

.

I

am

seeking

a

search

warrant

for

Kohberger's

office

at

WSU

to

search

for

:

1.

Any

images

,

whether

digital

or

on

paper

or

any

other

format

,

which

show

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

,

Madison

Mogen

B.F.

and

or

and

/

or

the

house

at

1122

King

Road

,

Moscow

,

and

/

or

the

surrounding

neighborhood

.

2.

Data

compilations

(

whether

digital

/

electronic

or

on

paper

or

other

format

)

showing

an

interest

in

,

or

planning

of

,

murder

,

violent

assault

,

stabbing

and

/

or

cutting

of

people

;

and

data

compilations

showing

details

of

the

1122

King

Road

house

,

its

location

,

and

/

or

any

information

about

Ethan

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

and

/

or

and

data

compilations

showing

the

location

of

Bryan

Kohberger

,

or

the

cell

phone

with

number

509-592-8458

,

on

November

13

,

2022

,

including

wi

-

fi

logs

and

data

or

meta

-

data

associated

with

photos

,

social

media

posts

,

or

applications

on

cell

phones

or

computer

towers

/

laptops

/

tablets

.

As

example

,

but

not

intended

to

be

an

exclusive

list

of

data

compilations

being

sought

:

ledgers

,

papers

,

lists

,

28

books

,

notes

,

letters

,

calendars

,

address

books

,

contact

lists

,

diaries

,

tapes

,

photographs

,

videos

,

emails

,

text

messages

,

social

media

posts

/

messages

,

and

meta

-

data

associated

therewith

3.

Electronic

digital

devices

or

digital

storage

devices

which

may

contain

any

of

the

above

data

compilations

,

including

cell

phones

,

computer

towers

/

laptops

/

tablets

,

external

hard

drives

,

CD

/

DVD

/

Thumbdrive

or

other

data

storage

devices

.

This

includes

any

device

which

may

contain

Evidence

of

other

accounts

associated

with

this

device

including

email

addresses

,

social

media

accounts

,

messaging

"

app

"

accounts

,

and

other

accounts

that

may

be

accessed

through

the

digital

device

that

will

aid

in

determining

the

possessor

/

user

of

the

device

;

Photographs

,

images

,

videos

,

documents

,

and

related

data

created

,

accessed

,

read

,

modified

,

received

,

stored

,

sent

,

moved

,

deleted

or

otherwise

manipulated

between

the

above

dates

Evidence

of

use

of

the

device

to

conduct

internet

searches

relating

to

a

review

of

other

murders

or

violent

assaults

/

stabbing

and

/

or

cutting

of

people

,

as

well

as

how

to

avoid

detection

after

the

commission

of

such

crimes

;

details

of

the

1122

King

Road

house

,

its

location

/

neighborhood

,

and

/

or

information

about

one

or

more

of

the

victims

Ethan

B.F.

and

/

or

Chapin

,

Kaylee

Goncalves

,

Xana

Kernodle

,

Madison

Mogen

,

Information

that

can

be

used

to

calculate

the

position

of

the

device

between

the

above

dates

,

including

location

data

;

GPS

satellite

data

;

GPS

coordinates

for

routes

and

destination

queries

between

the

above

-

listed

dates

;

app

data

or

usage

information

and

related

location

information

;

IP

logs

or

similar

internet

connection

information

,

and

29

images

created

,

accessed

or

modified

between

the

above

-

listed

dates

,

together

with

their

metadata

and

EXIF

tags

Evidence

of

the

identity

of

the

person

in

possession

of

the

device

on

or

about

any

times

that

items

of

evidentiary

value

,

located

pursuant

to

this

warrant

,

were

created

modified

accessed

or

otherwise

manipulated

.

Such

evidence

may

be

found

in

digital

communications

,

photos

and

video

and

associated

metadata

,

IP

logs

,

documents

,

social

media

activity

,

and

similar

data

Also

,

passwords

,

phrases

,

codes

,

patterns

,

fingerprints

,

and

/

or

user

names

to

operate

any

such

device

.

4.

Indicia

of

ownership

or

possession

or

right

to

use

of

,

the

office

premises

and

any

of

the

above

items

.

Based

off

the

above

information

,

I

am

also

seeking

a

search

warrant

for

Kohberger's

office

on

the

Washington

State

University

Campus

.

I

have

probable

cause

to

believe

evidence

of

the

crimes

committed

at

the

King

Road

Residence

will

be

found

in

Kohberger's

office

located

on

the

WSU

campus

at

Wilson

-

Short

Hall

,

#

12

,

Pullman

,

WA

.

It

is

common

for

individuals

to

keep

documents

,

records

,

and

information

of

the

type

described

above

in

their

office

and

Kohberger's

office

is

the

other

location

identified

where

this

evidence

could

be

found

.

Based

off

of

the

WSU

website

Kohbergr's

office

is

inside

Wilson

-

Short

Hall

.

The

address

of

Wilson

-

Short

Hall

is

1475

Glenn

Terrell

Mall

,

Pullman

,

WA

99163.

Wilson

-

Short

Hall

is

a

four

-

story

brick

building

housing

multiple

offices

.

Kohberger's

office

is

#

12.

#

12

is

a

student

office

shared

by

Kohberger

and

two

fellow

WSU

students

,

Kai

-

Xuan

Chen

and

Nayoung

Ko

.

Kohberger

has

been

confirmed

to

be

one

of

the

students

who

utilizes

this

office

.

On

December

29

,

2022

Investigators

visited

the

30

office

and

Kohberger's

name

in

on

the

outside

.

Based

off

the

above

information

,I

am

also

seeking

a

search

warrant

for

Kohberger's

office

on

the

Washington

State

University

Campus

.

It

is

common

for

individuals

to

keep

documents

,

records

,

and

information

of

the

type

described

above

in

their

office

and

Kohberger's

office

is

the

other

location

identified

where

this

evidence

could

be

found

declare

under

penalty

of

perjury

pursuant

to

the

laws

of

the

States

of

Idaho

,

Washington

,

and

Pennsylvania

,

that

the

foregoing

is

true

and

correct

.

Date

SUBSCRIBED

and

SWORN

to

before

me

this

of

December

,

2022

.

LORY

STATE

Affiant

DAH

31

Not

Residing

at

Adams

Commission

expires

10

11

12

13

7

14

16

8

15

17

18

19

20

23

2

4

5

6

9

21

24

3

22

25

1

26

27

28

STATE

OF

WASHINGTON

COUNTY

OF

WHITMAN

ISSUED

BY

:

SUPERIOR

COURT

,

WHITMAN

COUNTY

,

WASHINGTON

SW

NO

.

12-29-2022A

(

amended

)

Return

of

Service

of

Search

Warrant

(

Residence

and

Storage

Closet

)

DATE

ISSUED

:

DATE

SERVED

:

SERVED

BY

:

HOW

SERVED

:

ITEMS

SEIZED

:

12-29-2022

12-30-2022

Return

of

Service

of

Search

Warrant

per

order

SUPERIOR

COURT

JUDGE

GARY

J.

LIBEY

ASST

.

CHIEF

DAWN

DANIELS

,

302

IN

PERSON

FILED

JAN

03

2023

JILL

COUNTY

CLERK

1.

One

nitrite

type

black

glove

2.

1

Walmart

receipt

with

one

Dickies

tag

2

Marshalls

receipts

Dust

container

from

Bissell

Power

Force

"

vacuum

5.

8

possible

hair

strands

6.

Fire

TV

stick

with

cord

/

plug

7.

1

possible

animal

hair

strand

8.

1

possible

hair

9.

1

possible

hair

10.

1

possible

hair

11.

1

possible

hair

strand

All

seized

from

Residence

and

currently

stored

at

WSU

PD

12.

1

computer

tower

A.

1

collection

of

dark

red

spot

(

collected

without

testing

)

B.

2

cuttings

from

uncased

pillow

of

reddish

/

brown

stain

(

larger

stain

tested

)

C.

2

top

and

bottom

of

mattress

cover

packaged

separately

both

labeled

multiple

stains

(

one

tested

)

Page

1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

By

:

Return

of

Service

of

Warrant

Approved

:

Whitman

County

Prosecuting

Attorney

Declarant's

Signature

:

Declarant's

Full

Name

:

Dawn

Daniels

Return

of

Service

of

Search

Warrant

Agency

Badge

/

Serial

or

Personnel

# :

302

Agency

Name

Washington

State

University

Police

Dept.

[

Prosecutor

name

] ,

WSBA

#

Senior

Deputy

Prosecuting

Attorney

Criminal

Division

Page