Filed:02/14/2024 09:57:29

First Judicial District, Kootenai County

Jennifer Locke, Clerk of the Court
By: Deputy Clerk Schertz, Alyssa
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STANLEY T. MORTENSEN
Kootenai County Prosecuting Attorney
501 N. Government Way/P.O. Box 9000
Coeur d'Alene, D 83816-9000
Telephone Number: (208) 446-1800
Email: KCPAICOURTS@kcgov.us

IN THE DISTRICT COURT OF THE FIRST JUDICIAL DISTRICT OF THE STATE OF

IDAHO, IN AND FOR THE COUNTY OF KOOTENAI

STATE OF IDAHO, Case No. CR28-23-7131

Plaintiff, Grand Jury No. ADMIN28-23-2

VS. AMENDED INDICTMENT

DANIEL CHARLES HOWARD, Agency Case: 21-05307 K.C.S.O.

DOB:11/14/1965
SSN: XXX-XX-0569
Fingerprint #: 2800130573
Defendant.

DANIEL CHARLES HOWARD is accused by the Grand Jury of Kootenai County, by this

Indictment, of the crimes of Count I, Domestic Battery, Idaho Code §18-918(2)(a), 18-903, and

Count IT, Murder of the First Degree, Idaho Code §18-4001, 18-4003(a), committed as follows:

COUNT I

That the Defendant, DANIEL CHARLES HOWARD, on or about the 10" day of July,

2020, in Kootenai County, Idaho did, in committing a battery, inflict a traumatic injury or injuries

AMENDED INDICTMENT 1
upon the person of Kendy Howard, to wit: redness to her ear and bruising to her chest and arm and

where Kendy Howard and the Defendant were household members;

COUNT II

That the Defendant, DANIEL CHARLES HOWARD, on or about the 2nd day of

February, 2021, in Kootenai County, Idaho, did unlawfully, deliberately, with malice aforethought

and with premeditation, kill Kendy Howard, a human being, to wit: by asphyxiating her, all of

which is contrary to the form, force and effect of the statute in such case made and provided and

against the peace and dignity of the People of the State of Idaho.

DATED this 24 day of January, 2024.

STANLEY T. MORTENSEN
Kootenai County Prosecuting Attorney

Arthur Verharen
Deputy Prosecuting Attorney

CERTIFICATE OF MAILING

I hereby certify that on the 24th day of January, 2024, a true and correct copy of the
foregoing was caused to be delivered as follows: mailed faxed hand delivered emailed
JusticeWeb ICourts

Defense Counsel
Jason Garret Johnson

AMENDED INDICTMENT - 2