State’s Initial Response to Defendant’s Motions RE: Chaperones and Implementing Safety Plan
LATAH COUNTY PROSECUTOR’S OFFICE
WILLIAM W. THOMPSON, JR.
PROSECUTING ATTORNEY
Latah County Courthouse
P.O. Box 8068
Moscow, Idaho 83843-0568
Phone: (208) 883-2246
ISB No. 2613
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF LATAH
STATE OF IDAHO,
Plaintiff,
V.
STEVEN JAMES SITLER,
Defendant.
Case No. CR-2005-02027
STATE’S INITIAL RESPONSE TO
DEFENDANT’S “MOTIONS RE:
CHAPERONES AND IMPLEMENTING
SAFETY PLAN”
COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney, and respectfully submits this initial response to the Defendant’s “Motions RE: Chaperones and Implementing Safety Plan” filed herein on the afternoon of August 3, 2016.
In support of his motion, the Defendant submitted affidavits of one of his attorneys, Mark Monson, and of his wife, Katie Sitler. On review, those affidavits contain only selective facts and observations (some of which may be inaccurate) and do not afford the Court a complete picture of all that has occurred in this case. In an initial attempt to remedy that and afford the Court a more complete factual history, the State respectfully submits the attached IDOC “C-Notes” for the period of December 23, 2015, to July 14, 2016. This document was disclosed to the defense by the State on July 26, 2016, as part of the State’s response to the Defendant’s Request for Discovery.
In addition to the above-referenced C-Notes, the State also respectfully submits the attached “Sitler Case Synopsis and Timelines” prepared by Sr. Probation and Parole Officer Christine Jensen which summarizes IDOC’s C-Notes from the initiation of this case more than a decade ago. This document was sent by letter (copy also attached) to Mr. Wullenwaber on December 15, 2015.
Because both the C-Notes, and the synopsis, contain confidential and sensitive information regarding this case and victims of the Defendant, the State is submitting them under seal and respectfully prays that the Court preserve them under seal.
The State, having just received Defendant’s new filing, is awaiting additional input from representatives of the Idaho Department of Correction and will supplement its response as appropriate. Unfortunately, due to prearranged vacation and personal leave schedules, some of the involved IDOC staff may not be able to respond until shortly before or at the time of the hearing currently scheduled for August 17, 2016.
Respectfully submitted this 5th day of August, 2016.
