Gabriella Vargas Notice

Electronically Filed
8/17/2023 9:29 AM
Second Judicial District, Latah County
Julie Fry, Clerk of the Court
Anne C. Taylor, Public Defender By: Tamzen Reeves, Deputy Clerk
Kootenai County Public Defender

PO Box 9000
Coeur d’Alene, Idaho 83816
Phone: (208) 446-1700; Fax: (208) 446-1701
Bar Number: 5836
iCourt Email: [email protected]
Elisa G. Massoth, PLLC

Attorney at Law
P.O. Box 1003
Payette, Idaho 83661
Phone: 208-642-3797; Fax: 208-642-3799
Assigned Attorney:
Anne C. Taylor, Public Defender, Bar Number: 5836
Jay W. Logsdon, Chief Deputy Public Defender, Bar Number: 8759
Elisa G. Massoth, Attorney at Law, Bar Number: 5647
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF LATAH
STATE OF IDAHO CASE NUMBER CR29-22-2805
Plaintiff,
NOTICE OF FILING DECLARATION
V. OF GABRIELLA VARGAS IN SUPPORT
OF DEFENDANT’S THIRD MOTION
BRYAN C. KOHBERGER, TO COMPEL
Defendant.
COMES NOW, Bryan C. Kohberger, by and through his attorney of record, Anne C.
Taylor, Public Defender, and hereby files the attached Declaration of Gabriella Vargas in
support of the Defendant’s Third Motion to Compel.
DATED this ___17____ day of August, 2023.
ANNE C. TAYLOR, PUBLIC DEFENDER

KOOTENAI COUNTY PUBLIC DEFENDER
BY: _________________________________
ANNE TAYLOR
PUBLIC DEFENDER
ASSIGNED ATTORNEY
NOTICE OF FILING DECLARATION OF GABRIELLA VARGAS IN
SUPPORT OF DEFENDANT’S THIRD MOTION TO COMPEL Page 1
CERTIFICATE OF DELIVERY
I hereby certify that a true and correct copy of the foregoing was personally served as
indicated below on the __17____ day of August, 2023 addressed to:
Latah County Prosecuting Attorney –via Email: [email protected]

Elisa Massoth – via Email: [email protected]
NOTICE OF FILING DECLARATION OF GABRIELLA VARGAS IN

SUPPORT OF DEFENDANT’S THIRD MOTION TO COMPEL Page 2
Anne C. Taylor, Public Defender
Kootenai County Public Defender
PO Box 9000
Coeur d’Alene, Idaho 83816
Phone: (208) 446-1700; Fax: (208) 446-1701
Bar Number: 5836
iCourt Email: [email protected]
Elisa G. Massoth, PLLC

Attorney at Law
P.O. Box 1003
Payette, Idaho 83661
Phone: 208-642-3797; Fax: 208-642-3799
Assigned Attorney:
Anne C. Taylor, Public Defender, Bar Number: 5836
Jay W. Logsdon, Chief Deputy Public Defender, Bar Number: 8759
Elisa G. Massoth, Bar Number: 5647
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE

STATE OF IDAHO, IN AND FOR THE COUNTY OF LATAH
STATE OF IDAHO CASE NUMBER CR29-22-2805
Plaintiff,
DECLARATION OF GABRIELLA
V. VARGAS
BRYAN C. KOHBERGER,
Defendant.
1. I, Gabriella Vargas, am an adult, over the age of 18, and I have personal knowledge of the facts
set forth in this Declaration.
2. I have been engaged as an expert in the above-entitled matter since August of 2023.
3. My educational background is in Administration of Justice and Criminology. I have spent my

professional career working for the California court system, law firms, insurance and finance
firms. I got my start in this field after receiving unexpected DNA results in the spring of 2018.
DECLARATION OF GABRIELLA VARGAS Page - 1

4. I am an investigative genetic genealogist specializing in Hispanic and African American
ancestry, degraded DNA, and endogamy. I founded DNA-ID and have run the business since
the spring of 2020. Prior to my own company, I spent several years doing Investigative Genetic
Genealogy (IGG) for other companies such as the DNA Doe Project and Identifinders
International.
5. While working for those companies I held the role of team leader, senior forensic genealogist,
teacher, mentor, case auditor, intake specialist and lab liaison.
6. I have taught IGG fundamentals, best research practices and procedures, DNA data analysis,
and trained incoming genealogists.
7. I have contracted with the University of New Haven to provide a structured practicum for
students, collaborated on cases with the National Center for Missing and Exploited Children
and the Washington Attorney General’s office, as well as provided education, training and case
collaboration to the Australian Federal Police for the development of their IGG program,
standards, and practices.
8. Through extensive and skilled genealogical research and analysis, I have successfully provided
law enforcement with over 50 crime-solving investigative leads.
9. I work with law enforcement, nationwide, in an effort to identify previously unknown DNA
contributors, through a process known as investigative genetic genealogy, IGG. This technique
has revolutionized cold case investigations and transformed the way violent crime suspects
and skeletal remains are identified.
10. The sole focus of the traditional law enforcement databases, like CODIS, is to compare crime
scene DNA against the genetic profiles for those who are known offenders with prior
convictions. This process only utilizes twenty genetic markers and, therefore, limits the power
of DNA analysis, which can and does lead to cases going cold. Investigative genetic genealogy
combines advanced DNA testing with traditional genealogy research, in an effort to identify a
previously unknown DNA contributor in a family tree.
11. The DOJ recommends that law enforcement seek out investigative genetic genealogy services,
only after all other investigative methods have been exhausted. It is widely known within my
industry that many agencies use this technique as the first and only method.
12. The IGG process starts when law enforcement agencies reach out to genealogists seeking
collaboration on a case and then contract with the individual for services.
13. Chain of custody is best maintained when the requesting agency sends the crime scene DNA
sample to a private lab that is capable of genotyping or whole genome sequencing. Once the
sample arrives at the lab, the genealogist usually takes lead on the case until the person of
interest is identified. The lab creates a genetic profile of the unknown DNA contributor, and a
raw data file containing hundreds of thousands of genetic markers is generated and sent to the

genealogist. This file is then uploaded to the public direct-to-consumer DNA databases,
GEDmatch and Family Tree DNA, where autosomal comparisons are made between the
subject and thousands of individuals, who have voluntarily contributed their DNA profiles to
the databases and opted-in to law enforcement matching. A list of matches, who are
biologically related to the subject, is displayed with some basic identifying information and
the amount of DNA shared between the individuals. Tools within the databases allow for
further analysis of the DNA data and the ability to predict the most likely relationship between
the match and the unknown DNA contributor. In depth research on family history, structure,
and DNA data alignment is conducted and family trees for each match are built back and then
forward in time. These trees are analyzed by the genealogist for common ancestors, surnames,
locations, and any other significant clues that provide insight into identifying the person of
interest. Throughout the process, other tools can be used to further analyze Y-DNA and
mtDNA, ethnicity, one-to-one and multiple kit comparisons, triangulation, and chromosome
segments.
14. These database tools have known loopholes that allow a genealogist to see matches that have
explicitly declined to participate in law enforcement matching. This is not a glitch in the
programming causing this by accident. It is a standard feature within the tools that essentially
tricks the system into displaying all matches as opposed to only those who have consented to
law enforcement matching. This is not a loophole nor is it something you will stumble upon.
Using the tool this way requires effort and knowledge.
15. Databases for law enforcement cases require a fee be paid in order to upload the genetic profile,
this is not the same for consumers who are not charged. Many in the field have been known to
upload to these sites as a regular consumer to avoid paying the associated fees and to bypass
having opted out matches. In addition, some databases restrict law enforcement uploading
cases; however that has not prevented it from happening.
16. I am aware that law enforcement has obtained results in ways prohibited by the terms of use
and prohibited by their own policies.
DATED this ______

17th day of August, 2023.
____________________________________
GABRIELLA VARGAS

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Electronically Filed

Kootenai County Public Defender

Elisa G. Massoth, PLLC

STATE OF IDAHO CASE NUMBER CR29-22-2805

DATED this _17__ day of August, 2023.

ANNE C. TAYLOR, PUBLIC DEFENDER

Latah County Prosecuting Attorney –via Email: [email protected]

NOTICE OF FILING DECLARATION OF GABRIELLA VARGAS IN

Elisa G. Massoth, PLLC

IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE

STATE OF IDAHO CASE NUMBER CR29-22-2805

3. My educational background is in Administration of Justice and Criminology. I have spent my

DECLARATION OF GABRIELLA VARGAS Page - 1

DECLARATION OF GABRIELLA VARGAS Page - 2

DATED this ______

DECLARATION OF GABRIELLA VARGAS Page - 3

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