FILED

JAN 17 2023
1

JILL E
WHITMAN
2

6
IN THE SUPERIOR COURT OF THE STATE OF
WASHINGTON
7
IN AND FOR THE COUNTY OF WHITMAN

IN THE MATTER OF APPLICATION SW NO. 12-29-2022A

9

FOR SEARCH WARRANT

10 MOTIONAND ORDER TO UNSEAL
WARRANTRETURN
11

Clerk's Action Required

12

13

14

MOTION
15 COMES NOW, the State ofWashington, by and through Denis Tracy, Whitman
County
16 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.
17

18

BASIS

19

These warrants were issued and served in Washington State, because a suspect in the
20 crimes
resided and worked here during the time ofthe murders. These warrants and associated
21
applications
were sealed, due to the sensitive nature of the investigation at that time. Since then, an extensive
22
probable cause affidavit has been unsealed in Latah County , Idaho,which has alleviated the need for
23 sealing ofthe Return of Service here in Washington.

24

25

M & to Un- Seal Return

DENIS P.TRACY
Page of2 WHITMAN COUNTY PROSECUTOR
Box Colfax , WA 99111
( 509) 397-6250 ( 509) 397-5659 FAX
 1

DatedJanuary17, 2023.
2

3
Presented by:

5
Denis P. Tracy W BA# 20383

Prosecuting Attorney
6

ORDER
8

Itis ordered that the Return of Service of Search Warrant in this

9 matter is hereby Un- sealed.
10

Dated this
11
DayofJanuary, 2023.

12

13

Judge Gary Libey

14

15

16

17

18

19

20

21

22

23

24

25

M & to Un- Seal Return

DENIS P. TRACY
Page 2 of2
WHITMAN COUNTY PROSECUTOR
Colfax , WA 99111
(509) 397-6250 ( 509) 397-5659 FAX
 FILED

JAN 17 2023

E
WHITMAN
2

6
INTHE SUPERIORCOURT OF THE
STATE OF WASHINGTON
7 IN AND FOR THE COUNTY OF
WHITMAN
8

IN THE MATTER OF
9 APPLICATION SW NO. 12-29-2022A
FOR SEARCH WARRANT
10 MOTIONAND ORDER FOR
ORIGINAL
SEARCH WARRANT AND SEARCH
WARRANT APPLICATIONTO
REMAIN
SEALEDBUT A REDACTED
VERSION
12
BE PROVIDEDFORPUBLIC
RELEASE

13 Clerk's Action Required

14

15

MOTION
16
COMES NOW, the State of Washington, by and through
Denis Tracy, Whitman County
17 Prosecuting Attorney, and moves the court for an Order to keep sealed
the Search Warrant and
Search Warrant Application numbered SW NO.
18 12-29-2022A,but to allow the State to file
redacted versions which replace the victim witnesses
19
names with initials, pursuant to GR 15.
20

BASIS
The Washington State Constitution recognizes that victims of
21
crimes have rights, and states
that Effective law enforcement depends on cooperation
22
from victims of crime." Wash. Const. art.
. The Washington State Legislature has recognized that
there is a severe and detrimental
23
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
24

25

M & to Seal and Redact

Page of 3 DENISP.TRACY
WHITMAN COUNTY PROSECUTOR
Colfax, WA 99111
( 509) 397-6250 (509) 397-5659
FAX
 cooperate with law enforcement and prosecutorial agencies . RCW 7.69.010 . Ina
1 criminal
proceeding ,the law requires that a reasonable effort is made to ensure that victims,
2
survivors of
victims ,and witnesses of crimes have the right [t o receive protection from harm
and threats of
3
harm arising out of cooperation with law enforcement and prosecution
efforts. RCW 7.69.030 (5)
4 Washington Courts have long acknowledged that a victim's initials can be substituted for their

5
name.See State v. Mansour, 14 Wn.App.2d 323 (2020).
The basis for this motion is that there are two surviving victims/witnesses
6
of a now notorious
and much publicized murder/burglary in Moscow , Idaho, whose full names are
listed inthis search
7
warrant and search warrant application . These warrants were issued and served in
Washington
8 State, because a suspect in the crimes resided and worked here during the time ofthe
murders.
9
These warrants and associated applications were sealed, due to the sensitive nature ofthe
investigation at that time. Since then, an extensive probable cause affidavit has
10 been unsealed in
Latah County , Idaho, which has alleviated much ofthe need for sealing here in
Washington . But
the documents filed in Latah County have not disclosed the surviving
victims names, only their
12
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
13
warrant applications which
14
become publicly available from this court.
The State is asking the Court to consider the usual factors : ( 1) showing ofthe
15
need for
sealing the records,and where that need is based on a right other than an
accused's right to a fair
16
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
17
method for curtailing open access
must be the least restrictive means available for protecting the threatened
18
interests; (4) the court
must weigh the competing interests of the proponent of closure and the public ;
19 and (5) the order
must be no broader in its application or duration than necessary to
serve its purpose.
20
The State contends that the need to protect victim identification is
important to their safety ,
21 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
22

warrant and application for warrant with only the surviving victims names redacted
23 and replaced
with initials. This is a very minor closure of a court document
24
in order to protect a very important

25

M & to SealandRedact
DENIS P. TRACY
Page 2 of3
WHITMAN COUNTY PROSECUTOR
Colfax, WA 99111
(509) 397-6250 ( 509) 397-5659 FAX
 1

victim interest. Finally,the order will be no broader in application than

2
necessary to serve its
purpose,and the public will still havethe pertinent informationat its
disposalinorder to understand
3
the proceedings of the court.
4

DatedJanuary17, 2023.
5

Presented by:
7

P. WSBA# 20383
9
ProsecutingAttorney

10

11 ORDER

Itis ordered that the Search Warrant and Application For Search
Warrant already filed in
12

this matter shall remain sealed, but the State shall immediately file
13
redacted versions of those
documents with the surviving victim's names redacted and replaced with
14 initials.
15

Datedthis
Day ofJanuary, 2023.
16

17

18

Gary
19

20

21

22

23

24

25

M & to Seal and Redact

DENISP.TRACY
Page 3 of3
WHITMAN COUNTY PROSECUTOR
PO Colfax, WA99111
(509) 397-6250 ( 509) 397-5659 FAX
 1
FIL D
2
JAN 17 2023
3
JILL
WHITMAN COUNTY
CLERK
4

7
SUPERIORCOURT, WHITMANCOUNTY, WASHINGTON

8
STATE OF WASHINGTON ) SWNO: 2-29-2022 A
9

COUNTY OF WHITMAN SEARCH WARRANT¹

10 ( Residence)

TO ANY PEACE OFFICER IN THE STATE OF WASHINGTON :

11

12
Uponthesworncomplaintmadebeforeme, there is probable cause to believethat thecrime(s)
13
ofMurder in the first degree and Burglary , per Idaho Code has been committed , in Idaho, and that
14 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
16
appears about to be committed; is concealed in or on certain premises.
Inmakingthis determination, this court didnotconsider the information inthe Supplemental
17

DisclosurereDNA Test as evidence supporting the existence ofprobable cause. This court alsodoes
18

not consider the information in that Supplemental Disclosure to be exculpatory.

19

20
YOU ARE COMMANDEDto :

21
1. Search, within 10 days ofthis date, the premises described as follows:
22
Apartment located at 1630 NE Valley Rd, #G201, Pullman, WA.
23 1630 NE Valley Road is a three story , multiple occupancy apartment building in
24
Pullman, WA which is tan and white in color . Apartment G201 is located on the
25
northeast corner of the second story of this building . The door to G201 is located on
the east side ofthe second story landing and is designated by the numbers "201 on
26

27

28

SEARCH WARRANT
Page of4
 1 the door. The door is white, with a swinging screen door on the outside of the main
2
door to the residence .

4
2. Seize, iflocated, evidenceofthe above-listed crimes, including:

1. Blood, or other bodily fluid or human tissue or skin cells , or items with blood or other
5

6
bodily fluid or human tissue or skin cells on the items.
7

8 2. Knives, sheaths, or other sharp tools, including any dagger , dirk, or sword, and any written
9
indicia of ownership of same, including sales receipts.

10

3. Any images, whether digital or on paper or any other format ,which show Ethan Chapin ,
11

Kaylee Goncalves , Xana Kernodle, Madison Mogen and/or

12

and/or the house at 1122 King Road, Moscow, ID and/ or the surrounding
13
neighborhood.
14

15
4. Clothing, including but not limited to dark shirt(s), dark pant(s), mask(s ) , shoes with
16 diamond patternsole.
17

18
5. Trace evidence including DNA from blood or skin cells or other source, footprints,

19
fingerprints , hair (whether human or animal/ dog).

20

6. Datacompilations (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
21

data compilations showing details ofthe 1122 King Roadhouse, its location,and/or any
22

23
information about Ethan Chapin, Kaylee Goncalves, Xana Kernodle, Madison Mogen,
24
B.F. and/ or D.M. and data compilations showing the location of
25 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
27 applications on cell phones or computer towers/laptops/tablets . As example, but not
intendedto bean exclusive list of data compilations being sought: ledgers, papers, lists,
28

SEARCH WARRANT
Page 2 of4
 ,
books, notes ,letters, calendars , address books, contact lists,diaries,tapes ,photographs
-data associated
2 videos, emails,text messages, social media posts/messages, andmeta
3
therewith .

ofthe above
7. Electronic digital devices or digital storage devices which may contain any
5
/tablets,external hard
data compilations, including cell phones, computer towers/laptops
device
drives, CD/DVD/Thumbdrive or other data storage devices. This includes any
6

which may contain :

7

, social
9
Evidence ofother accounts associated with this device including email addresses
be accessed
10 media accounts,messaging app" accounts,and other accounts that may
device;
11 through the digitaldevice that will aid in determiningthe possessor/user ofthe
,read,
12 Photographs, images,videos,documents, and related data created, accessed
betweenthe
13
modified, received, stored, sent,moved, deleted or otherwise manipulated
above dates
14
to a review ofother
Evidence ofuse of the device to conduct internet searches relating
15
to avoid
murders or violent assaults/stabbing and/or cutting of people, as well as how
16
Road house, its
detection afterthe commission of such crimes; details of the 1122 King
of the victims Ethan
location/neighborhood, and/or information about one or more
17

, and/or
Chapin, Kaylee Goncalves, Xana Kernodle, Madison Mogen B.F.
18

19
D.M.

above
20
Information that can be used to calculate the position of the device between the
routes and
21 dates, including location data; GPS satellite data ; GPS coordinates for
and
22 destination queries between the above -listed dates; app data or usage information
, and
23
related location information ;IP logs or similar internet connection information
with their
images created, accessed or modified between the above-listed dates, together
24

metadata and EXIF tags

25
times
Evidence ofthe identity ofthe person in possession ofthe device on or about any
,
that items of evidentiary value , located pursuant to this warrant, were created modified
26

accessed or otherwise manipulated . Such evidence may be found in digital

27

28

SEARCH WARRANT
Page 3 of4
 1 communications , photos and video and associated metadata, IP logs ,documents,social
2
media activity ,and similar data;
3

4
Also, passwords, phrases, codes, patterns, fingerprints,and/or usernames to
operate any such device.

8. Indicia ofresidence in, or ownership or possession of,the premises and any of the above
6

items, including mail, receipts , identification, bills,rental agreements , licensing documents

7

8
and other personal property whose owner/possessor may be readily determined.
9

Assistance from any law enforcement agencies from the State of Idaho or the federal
10

withsuch
government,or any technical specialist associated with or employed by or contracted
11

12
law enforcement agencies, including but not limited to the Moscow Police Department, Idaho
13
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
14

15
media for the best and least intrusive method of securing digital evidence that the warrant
16
authorizes for seizure , and to assist in securing such evidence .
17

18

Promptly return this warrant to me or the clerk ofthis court;the return mustinclude an
19

20

inventory of allproperty seized.

A copy ofthe warrant and a receipt for the property taken shall be given to the person from
21

22
whom or from whose premises property is taken . Ifno person is found in possession , a copy and
23
receipt shall be conspicuously posted at the place where the property is found .
24

25
Date/Time
26
Signature
27 SUPERIOR COURT JUDGE

28
PrintedJudge's Name:

SEARCH WARRANT
Page 4 of4
 FILED

1 JAN 17 2023
2 JILLE
WHITMAN

7
SUPERIOR COURT, WHITMAN COUNTY , WASHINGTON

8
STATEOF WASHINGTON ) SW
9
REDACTED
COUNTYOF WHITMAN APPLICATION FOR SEARCH WARRANT
10
(Residence)

11 Declaration

12
Dawn Daniels , Assistant Chief WSU Police Department , declare that have personal

13
knowledge ofthe matters herein and/or am relying on witness statements , information provided

14
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
15

stated herein :
16
the basisofthe following, I believe there is probable cause that Bryan Kohberger has
17
committedthe crime(s) of Murder First Degree, Idaho Code (IC) 18-4001, 4002 , 4003, 4004, and
18
Burglary, IC 18-1401, 1403 in Moscow, Idaho, and that:
19
Evidence of those crimes ;

20
Contraband
, the fruits ofa crime, or thingsotherwisecriminallypossessed
;

21
Weapons or other things by means of which a crime has been committed or reasonably
22
appears about to be committed ;
A person for whose arrest there is probable cause , or who is unlawfully restrained ;
23

24

25 is locatedin, on, at, or aboutthe followingdescribedpremises, vehicle or person:

26 Apartment located at 1630 NE Valley Rd, # G201, Pullman , WA .

27
1630NE Valley Road is a three story, multiple occupancy apartment building in Pullman,
WA whichis tan and white in color. Apartment G201 is located on the northeast corner ofthe
28

ApplicationForSearchWarrant Page 1
 1
secondstoryofthis building. The door to G201is locatedon the east side ofthe secondstory

2 landingand is designated by the numbers 201" on the door. The door is white, witha swinging

3
screen door on the outside of the main door to the residence .

Affiant
5

( 1) I am a policeofficer at WashingtonState UniversityPoliceDepartment, and have

6
beenso employedsince July 20, 1998. I attended and successfullycompletedthe

7
440-hourWashingtonState CriminalJustice TrainingCommission'sBasicLaw
EnforcementAcademy. While at the academy, I completedcourses in CriminalLaw,
8 CriminalProceduresand other investigativecourses. Sincethe academy, I have
continuedmy educationin variouslaw enforcementrelated fields including Officer
9
InvolvedShooting, EvidenceCollection, and Threat Assessment. I haveinvestigated
andassistedinthe serviceof over 50 search warrants.
10

12
Personsprovidinginformation
:

13

Moscow, Idaho Police Officer Sgt. Dustin Blaker. Sgt. Blaker's swornstatementis
14

attachedhereto as Exhibit A , and is hereby incorporatedin this applicationfor search

15
warrant. Sgt. Blaker identifieshis experience and training in his statement.
16
2. Other officers and witnesses are identified in Sgt. Blaker'sswornstatement.
17

18
The Investigation

19 I was contacted by Moscow police officers and asked to assist their investigation into the
20 recent murder of four people in Moscow, Idaho. Sgt. Blaker of the Moscow Police Department
21
has developed probable cause to believe that a resident of Whitman County , Bryan Kohberger,
22
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
23

cause to believe that evidence ofthose crimes will be located in Kohberger's apartment at 1630
24

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
25

Sgt. Blaker , which is hereby incorporated herein by this reference, just as iffully set forth here.
26

27

28

ApplicationForSearchWarrant Page 2
 1

2 Basedon allthe foregoinginformation, I believethat evidenceof the above- listed

3
crime(s) exists at the above-described location, and that there is probable cause to searchthat
locationfor evidence ofthe above-listedcrimes, including:
4

1. Blood, or otherbodily fluid or humantissue or skin cells , or items with blood or other
6

bodily fluid or human tissue or skin cells on the items.

7

8
2. Knives, sheaths , or other sharp tools, including any dagger , dirk , or sword, and any written
9
indicia ofownership of same, including sales receipts.
10

Chapin,
11 3. Any images, whether digital or on paper or any other format, which show Ethan

KayleeGoncalves, Xana Kernodle, Madison Mogen

B.F. and/ or
12

13
and/or the house at 1122 King Road, Moscow, ID and/or the surrounding
.
neighborhood
14

15

4. Clothing, including but not limited to dark shirt (s ), dark pant(s), mask (s ), shoes with
16
diamond pattern sole.
17

18
5. Trace evidence including DNA from blood or skin cells or other source, footprints ,
19
fingerprints , hair (whether human or animal/ dog )
20

21
6. Data compilations (whether digital/ electronic or on paper or other format ) showing an

22
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
23

information about Ethan Chapin , Kaylee Goncalves, Xana Kernodle , Madison Mogen,
24

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,
25

including wi-fi logs and data or meta- data associated with photos, social media posts, or
26

27
applications on cell phones or computer towers/laptops /tablets . As example, but not
28

Application For Search Warrant Page 3

 1
intended to be an exclusive list of data compilations being sought: ledgers, papers, lists,
2 books, notes, letters, calendars, address books, contact lists, diaries, tapes, photographs,
3
videos, emails, text messages, social media posts/messages, andmeta-data associated
therewith
4

7. Electronic digital devices or digital storage devices which may contain any ofthe above
6

data compilations, including cell phones, computer towers/ laptops/tablets, externalhard

7

drives, CD/DVD/Thumbdrive or other data storage devices. This includes any device
which may contain:
8

10
Evidence of other accounts associated with this device including email addresses , social
11 media accounts, messaging app accounts, and other accounts that may be accessed
12 through the digital device that will aid in determining the possessor/user of the device;

13
Photographs, images, videos, documents, and related data created, accessed, read,
14
modified, received, stored, sent, moved, deleted or otherwise manipulated betweenthe
above dates;
15

Evidenceofuse ofthe deviceto conductinternet searches relatingto a review ofother

16

murdersorviolentassaults/ stabbingand/or cuttingofpeople, as well as howto avoid

17

detectionafterthe commissionofsuchcrimes; details ofthe 1122KingRoadhouse, its

18
location/ neighborhood, and/ or informationaboutone or moreofthe victims Ethan
19
Chapin, KayleeGoncalves, Xana Kernodle, MadisonMogen B.F. and/ or

20
D.M.
21 Information that can be used to calculate the position ofthe device between the above
22 dates , including location data; GPS satellite data; GPS coordinates for routes and
23
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

images created, accessed or modified between the above-listed dates , together with their
25

metadata and EXIF tags;

26

Evidenceofthe identityofthe person inpossessionofthe deviceon or aboutany times

27
that itemsofevidentiaryvalue, locatedpursuantto this warrant, were createdmodified,
28

ApplicationFor SearchWarrant Page

 1
accessed or otherwise manipulated . Such evidence may be found in digital

2 communications, photos and video and associated metadata, IP logs, documents, social

3
media activity, and similar data

Also, passwords, phrases, codes, patterns, fingerprints , and/or user namesto

5

operate any such device.

6

8. Indicia ofresidence in, or ownership or possession of, the premises and any of the above
items , including mail , receipts , identification , bills , rental agreements , licensing documents
8

9
and other personal property whose owner/possessor may be readily determined .
10

11

12

Inaddition, I am asking the court to authorize , in the service of the search warrant , the use of
13

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
14

15
law enforcement agencies , including but not limited to the Moscow Police Department , Idaho
16
State Police, FBI, Idaho State Police Forensic Services .
17

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
18

19
the warrant authorizes for seizure , and to assist in securing such evidence.
20

21

SupplementalDisclosure re DNA Test

22

23 I have been informed by Detective JR Talbott ofthe Idaho State Police, that :

24
1. On November 13 , 2022 , a sheath was recovered at the King Road Residence under or

25
next to the body of MadisonMogen. The Idaho State Crime Labobtained a male
26

DNA profile (Suspect Profile) from the sheath. (This is also referred to in Sgt.
27

Blaker's sworn statement Exhibit A.)

28

Application For Search Warrant Page

 1

2
2. On December 27 , 2022 , law enforcement agents / officers in Pennsylvania recovered
3

trash that originated from the Kohberger family residence . That trash was sent to the
4

5
Idaho State Crime Lab for testing. On December 28 , 2022 , the Idaho State Lab
6 reported that a DNA profile was obtained from the trash ; it was compared to the
7 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
8

of the Suspect Profile . At least 99.9998% of the male population would be expected
10

11
to be excluded from the possibility of being the biological father of the source of the
12 SuspectProfile.

13 This information is being provided to the court pursuant to my duty and obligation to be fully
14 candid with the court . I do not believe this information is exculpatory for the suspect. However,
15 ifthe court believes it is exculpatory , then the court should consider this supplemental disclosure
16
in its evaluation of the existence of probable cause , or lack thereof.

17 But I am specifically asking the court to NOT considerthis supplemental disclosure as evidence
18 supporting the existence of probable cause. Thereason for this request is that ifthe dna test
19
results are held inadmissible at some point, such a rulingwould not impact the findingof

20
probable cause for this warrant, so long as this courtis satisfied as to probable cause regardless
ofthe dna test result.
21

22

23

24

25

26

27

28

ApplicationFor Search Warrant Page 6

 1

I certify underpenaltyof perjuryunderthe lawsofthe State of Washingtonthatthe

foregoingis true and correct.
3

Signed this 29th day of December, 2022 , at Pullman, WA

5

Declarant's Signature:
6

7
Declarant's Full Name : Dawn Daniels

8 Agency Badge/ Serial or Personnel # : 302

Agency Name : Washington State University Police Dept.
9

10
day of reviewedand considered the above application,
11 submitted to me under penalty ofperjury.

12
Signature
:
SUPERIOR COURTJUDGE

PrintedJudge's Name:
13

14

15

Issuance of Warrant Approved:

16
WhitmanCounty ProsecutingAttorney
17

18
By:

19
[ Prosecutorname] , WSBA#
Senior DeputyProsecutingAttorney
20 CriminalDivision

21

22

23

24

25

26

27

28

ApplicationForSearchWarrant Page
 ExhibitA

Statement of Dustin Blaker

The below information is provided by Sergeant (SGT) Dustin Blaker I ama 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 of2000. 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 ofthe 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 Smithand I entered the King RoadResidence through the bottom floor door onthe
northside ofthe 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 ofthe hallway. As I approachedthe 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 oftwo 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 was a dog in the room when Moscow Police
body camera ) there

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 atan 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 ofthe
knife sheath .

As part ofthe investigation,numerous interviews were conducted by Moscow Police

Department Officers, Idaho State Police Detectives, and FBI Agents.Two ofthe interviews

included (hereafter ) ,and hereafter

and inside the King RoadResidence at the time of the homicides
and wereroommates tothe victims bedroomwas located on the east side ofthe first

floor ofthe King RoadResidence.

Based onnumerous interviews conducted by MPD Officers , ISP Detectives , and FBI
Agents as well as my review of evidence, I have learned the following:

the evening ofNovember 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
 Goncalvesand Mogen at approximately 1:56a.m.from downtown Moscow (infront ofthe Grub
Truck) tothe King RoadResidence.

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 intheir
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 ofthe
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
leftthe scene.

The combination of statements to law enforcement, reviews of forensic

downloads ofrecords 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
 secondfloor). This is consistentwith statementregardingthe suspect'spathof
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 1was 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 at4:20 a.m.
These sightings show Suspect Vehicle 1 makes an initial three passes by the 1122 King Road
residence andthen 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.

Itcan 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 1is 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. ata 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 RiverDrive 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 1to 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
is a2011-2016 white
have been reviewing information on persons in possession of a vehicle that
Hyundai Elantra.

Investigators were given access to video footage on the Washington

State University

(WSU ) campus located in Pullman, WA . WSU maintains

a series ofsurveillance cameras on and
near its campus.A review ofthat video indicated that at approximately 2:44 a.m. on November
13,2022,a white sedan,which was consistent with the description ofthe White Elantra known
as Suspect Vehicle 1,was observed on WSU surveillance cameras travelling north on southeast
is
Nevada Street at northeast Stadium Way.At approximately 2:53 a.m., a white sedan,which
consistent with the description ofthe White Elantra known as Suspect Vehicle 1,was observed
traveling southeast on Nevada Street inPullman, WA towards
SR 270. SR 270 connects

Pullman,Washington to Moscow,Idaho.This camera footage from Pullman,WA

was provided
the vehicle observed in
to the same FBI Forensic Examiner.The Forensic Examiner identified
Pullman, WA as being a 2014-2016 Hyundai Elantra.
description of
At approximately 5:25 a.m.,a white sedan ,which was consistent with the
Suspect Vehicle 1,was observed on five cameras in Pullman, WA and
on WSU Campus
Road in
cameras .The first camera that recorded the white sedan was located at 1300 Johnson
Road
Pullman.The white sedan was observed traveling northbound on Johnson Road.Johnson
leads directly back to West Palouse River Drive inMoscow which intersects with Conestoga
and northwest on
Drive The white sedan was then observed turning north on Bishop Boulevard
SR 270. At approximately 5:27 a.m.,the White Elantra was observed oncameras
traveling

8
 at Grimes Way,Stadium Drive at
northbound onStadium Way at Nevada Street, Stadium Way
Wilson Road, and Stadium Way at Cougar Way.

:
Depiction showing Moscow andPullman

)
Depiction showing White Elantra's path oftravel (not to scale

9
Legend

White Elantra

seen leavingWSU
Campus

White Elantra

seenReturning
to

Campus

1630NEValley
Washington
Road
State
University

Washington
Arrowsare
State
camera University

locations and

indicate

vehicle

directionof
travel

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).

10
 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 providedhis 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 .

OnOctober 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 ofthe stop , Kohberger was the sole
occupant andwas 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 experienceand
communication with Washington law enforcement,I knowthat 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 bya 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 informationto
understandhow emotions and psychological traits influence decision making when committing
a crime.

As part ofthis investigation, law enforcement obtained search warrants to determine

cellulardevices that utilized cellular towers in close proximity to the King Road Residenceon
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 warrantreturns. A query of the 8458 Phone in these returns did not show the 8458 Phone
utilizingcellular tower resources in close proximity to the King RoadResidence between 3:00
a.m.and5:00a.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
particulararea 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 notplan to commit the offense on that particular day

13
 OnDecember23, 2022, Cpl. Payne applied for and was granted a search warrant for
historicalphone records betweenNovember 12, 2022 at 12:00 a.m. and November 14,at 12:00
a.m.forthe 8458 Phoneheld by the phone provider AT&T (approximately 24 hours proceeding
and followingthetimes 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 anarea
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
 Belowis a depiction (not to scale) of the possibleroute taken basedoffof 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, andthe 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 andthe 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 atthe
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 PenRegister Trap and
Trace on the 8458 Phone to aid inefforts to determine if Kohberger stalked any ofthe victims in
this case prior to the offense, conducted surveillance on the King Road Residence, was in contact
with anyofthe victims associates before orafterthe alleged offense,any locationsthatmay
contain evidence ofthe murders that occurred on November 13, 2022, the locationof the white
Elantra registered to Kohberger, as well as the location ofKohberger.

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 ofthe traffic stop during this time (Farm Road and Pullman Highway)

17
 Further analysis of the cellular data provided showed the 8458 Phone utilized cellular
resourceson 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 Phoneutilized
cellular resources that would provide coverage to Kate's Cup ofJoe 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 ofJoe 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
the8548Phone
.

At approximately 12:46 p.m., the 8458 Phone then utilized cellular data in the area ofthe
Albertson's grocery store at400 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.

The KingRoad Residence contained a significant amount of blood from thevictims

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
19
 the victims or from Goncalves dog. It is likelythat some trace evidence was transferredto 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 stillbe
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 ofthe listed crimes.

Evidence ofthe 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 canremain 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 berecovered 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 asuses
of socialmedia websites and internet searches/browsing.

Device-generated data also includes information regarding the user identity at any
particulardate 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 havebeen removed, and information abouthow that offsite storage is being used. If
thedevice is synced with other devices, itwill 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

evidencemaybepresent.

22
 As with othertypes of evidence, the context, location, and data surroundinginformation

in the devicedata is often necessary to understand whether evidence falls within the scopeofthe
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 ofthe 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 andmedia, 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 dataalso mean that searches can
take days oreven 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
underthe 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. and
/ or

D.M.

Informationthat can be usedto calculate the position ofthe device between the above
dates, including location data; GPS satellite data; GPS coordinates for routes and
destinationqueries betweenthe above-listed dates; app data or usage information and
related location information; IP logs or similar internet connection information, and

24
 images created, accessedor modifiedbetween the above-listed dates, together withtheir
metadataand EXIFtags;

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 . Suchevidence 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

andis 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 isthe
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 .

Basedonallofthe above information, I am seeking asearch warrantfor the Kohberger

Residence, to searchfor:

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
indiciaofownership ofsame, including sales receipts.
3. Any images, whether digitalor on paperor any other format, which show Ethan Chapin,

KayleeGoncalves, Xana Kernodle, MadisonMogen B.F. and

/ or

and/ or the house at 1122 King Road, Moscow , ID and/ or the surrounding

.
neighborhood

4. Clothing, includingbutnot limited to dark shirt(s) , dark pant(s), mask(s), shoes with
diamondpatternsole.
5. Trace evidence including DNA from bloodor skincells 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 ofthe 1122 King Roadhouse, 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
 includingwi-fi logs and data or meta-data associatedwith photos, social media posts,or
applications on cell phones or computertowers/laptops/tablets. As example, but not
intendedto be an exclusivelist ofdata compilationsbeingsought: ledgers, papers, lists,
books, notes, letters, calendars, address books, contact lists, diaries, tapes, photographs,
videos, emails, textmessages, socialmedia posts/messages, and meta-dataassociated
therewith

7. Electronic digital devices or digital storage devices which may contain any ofthe above
data compilations, includingcell phones, computertowers/laptops/tablets, external hard
drives, CD/DVD/ Thumbdrive or other data storage devices. This includesany device
which may contain:

Evidence of other accounts associated withthis device including email addresses,social

mediaaccounts, 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 ofuse of the device to conduct internet searches relating to a review of other
murders or violent assaults / stabbing and/or cutting ofpeople , 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 ofthe victims Ethan
Chapin, Kaylee Goncalves , Xana Kernodle, Madison Mogen, B.F. and/ or

D.M.

e 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 ofthe 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 ofthe above
items .

I am seeking a search warrant for Kohberger's office at WSU to search for:

1. Any images,whether digital or onpaper or any other format,which show Ethan Chapin,
Kaylee Goncalves,Xana , Madison Mogen B.F. andor

and/ or the house at 1122 King Road, Moscow , and/or the surrounding

.
neighborhood

2. Data compilations (whether digital/electronic or onpaper 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,socialmedia 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 , andrelated data created , accessed ,read,

modified,received, stored , sent , moved,deleted or otherwise manipulated between the

above dates

Evidenceofuse ofthe device to conduct internetsearches relating to areview ofother

murders orviolentassaults/ stabbing and/or cutting of people, as well as how to avoid

detectionafterthe commissionofsuch crimes; details ofthe 1122 King Roadhouse,its

location/neighborhood, and/or informationaboutone ormore ofthe victims Ethan

Chapin, Kaylee Goncalves, Xana Kernodle, Madison Mogen, B.F. and/or

Informationthat 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 betweenthe above-listed dates; app data or usage informationand
related locationinformation; IP logs or similar internetconnection 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. Indiciaof ownership or possession or right to use of, the office premises and any ofthe
above items.

Based offthe 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 . Itis 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 offof 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 ofthe students who utilizes this office . On December 29, 2022 Investigators visited the

30
office and Kohberger's nameinon the outside. Basedoffthe above information, I am also

seekinga search warrantfor 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

declareunderpenaltyofperjurypursuantto the lawsofthe StatesofIdaho,

Washington, and Pennsylvania , that the foregoing is true and correct .

Date Affiant

SUBSCRIBEDand SWORNtobefore methis ofDecember,2022.

LORY
Not

Residingat Adams
DAH
STATE Commissionexpires

31
 FILED
JAN 03 2023
1

JILL
2 COUNTY CLERK

SUPERIOR COURT, WHITMAN COUNTY, WASHINGTON

4

STATE OF WASHINGTON SW NO. 12-29-2022A( amended)

5

6
COUNTY OF WHITMAN Returnof Service of Search Warrant
( ResidenceandStorage Closet)
7

8
per
order
9
ISSUED BY: SUPERIOR COURT JUDGE GARY J. LIBEY
10

DATE ISSUED: 12-29-2022

11

DATE SERVED : 12-30-2022

12

SERVED BY: ASST. CHIEF DAWN DANIELS , 302

13

14 HOW SERVED: IN PERSON

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ITEMS SEIZED: All seized from Residence and currently stored at WSU PD
16

17 1. One nitritetypeblack glove

2. 1 Walmart receipt with one Dickiestag
18
2 Marshallsreceipts
19
Dustcontainer from Bissell Power Force" vacuum

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5. 8 possiblehair strands
6. FireTV stick with cord/plug
21
7. 1 possible animal hair strand

22 8. 1 possiblehair

9. 1 possible hair
23
10.1 possiblehair

24 11. 1 possible hair strand

12. 1 computer tower
25
A. 1 collection ofdark redspot ( collected withouttesting)
26 B. 2 cuttings from uncased pillow of reddish/brownstain (
larger stain tested)
C. 2 top and bottom of mattress cover packaged separately bothlabeled
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multiplestains ( one tested)
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Return of Service of Search Warrant

Page 1
 1

Declarant's Signature :
2
Declarant's Full Name: DawnDaniels

3 Agency Badge/ Serial or Personnel# : 302

Agency Name Washington State University Police Dept.
4

Returnof ServiceofWarrantApproved:
5
WhitmanCounty ProsecutingAttorney
6

By:
7
[ Prosecutor name] , WSBA #
Senior Deputy Prosecuting Attorney
8
CriminalDivision
9

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Return of Service of Search Warrant

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