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Electronically Filed2/16/2021 11:52 AMSeventh Judicial District, Fremont CountyAbbie Mace, Clerk of the CourtBy: Eileen Parker, Deputy Clerk123456Mark L. Means (ISB 7530)MEANS LAW and MEDIATIONMEANS-LAW429 SW 5th Ave, Suite 110Meridian, ID 83642Telephone: 208.794.3111Facsimile: 1.866.228.3429Email: mlm@means-law.comIcourt Email: icourtlaw@gmail.comWebsite: www.means-law.comAttorney for LORI NORENE (DAYBELL) VALLOWIN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OFTHE STATE OF IDAHO, IN AND FOR THE COUNTY OF FREMONTMAGISTRATE DIVISION789101112131415STATE OF IDAHO,PLAINTIFFVs.LORI NORENE VALLOW AKA LORI NORENEDAYBELL,DEFENDANTCase No: CR22-20-838C R22-20-0755EXPERT WITNESS(ES) DISCLOSURE RE: IRONWOOD INSIGHTSDOB: 1973161718TO: STATE OF IDAHO and ATTORNEY FOR PLAINTIFF:19COMES NOW DEFENDANT LORI NORENE VALLOW (DAYBELL), by and through her Attorney of202122Record, Mark L. Means and pursuant to Idaho Criminal Rule 16 1 and provides notice her expertwitness(es) disclosures as follows:IRONWOOD INSIGHTS. See attached Expert information, expertise, contact information,accreditations, awards, publications, etc.232425261 Idaho Rules of Evidence 702, 703, and or 705.PG. 1
123IRONWOOD INSIGHTS has been retained by the above Defendant and is expected totestify and offer factual and expert opinion in accordance with the relevant statutes, laws,findings, recommendations, opinions, evidence, issues, errors and or omissions, ethical issues,45legal analysis, cultural, etc., regarding all aspects of this case and specifics into scientific survey6results of local areas regarding the public opinion towards Defendant(s), the pending criminal7case(s) and the like. They will offer reasonable inferences, opinions, scientific survey results, an8expert report 2. findings, or the like incorporated herein by reference. Their testimony will9include the nature and extent of errors, omissions, malpractice, misstatements, incorrect1011assumptions, unfounded opinions, opinions, etc., or the like and the correlations of said12opinions relevant to the Motion to Transfer the Trial. DEFENDANT reserves the right to amend13this disclosure if necessary, to allow the full presentation of evidence/testimony by this Expert.14If counsel wishes for more information regarding said Expert, please advise Counsel for15Mrs. Lori Vallow (Daybell) at your earliest convenience.1617DATED this16day of February 2021.181920Mark L. MeansAdvocate for Mrs. Lori Norene Vallow (Daybell)2122232425262 Report will be produced to Plaintiff and Defense Counsel Mr. John Priorupon receipt to Means Law Office, PLLC.PG. 2
CERTIFICATE OF SERVICE123The undersigned certifies that on this16day of February 2021, I caused atrue and correct copy of the FOREGOING document to be forwarded by the method(s)indicated below, to the following:456789MADISON COUNTY PROSECUTING ATTORNEY159 E. Main St.P.O. Box 350Rexburg, ID 83440Email: mcpo@madison.id.usxEfileMr. John PriorEmail: john@jpriorlaw.comxEfile10111213DATED this16day of February 2021.ByMr. Mark L. Means14151617181920212223242526PG. 3
Welcome to Ironwood Insights GroupPage1of 6RONVWDDDNSICHTSWELCOME TO IRONWOOD INSIGHTS GROUP'»in2“72:5;\\\\‘ \\ ‘I'/373///Why Ironwood?There are hundreds of ways to conduct market research. It takesexperience, knowledge and dedication to know how to conduct the righttype of research for your specific needs. No black boxes, no proprietaryalgorithms,just hard-nosed research using all the latest technology,methodologies and analytic techniques.https://ironwoodinsights.com/”25/202 l
Welcome to Ironwood Insights GroupPage 2of 6Insights that provide clarity and drive action.What We Provide For Our ClientsResearch DesignThrough a consultative process, ourprofessionals will design a tailored researchstrategy that will achieve your specific goals.LEARN MOREData CollectionWith a combination of time honored practicesand modern technologies. we collect accuratedata that leads to sound decisions.LEARN MOREAnalytics & ReportingWe use a full complement of tools and knowhow to analyze y0ur survey data and design asolution that best addresses your business.LEARN MORELET'S WORK TOGETHERhttps://ironwoodinsights.com/1/25/2021
Welcome to Ironwood insights H4,’V7-:aPage 3‘,4,f,. .IV,-of 6. ." :a'inl{\1CaOur Experience is UnmatchedWe've Helped Other BusinessesJust Like YoursIronwood Insights Group is a robust team of players that coversresearch design, strategy, implementation and analytics. Our seasoned9m" ��Rfifé’d‘iecé’rfi‘it}? 591913W938l 93m i”vent re.this excrtland‘gonsi er their contributions vital in the change of venueBased eumeyswirstapitaésasmi Wmfldeewdhecmedbmstfongteam magismmfistohapine wésHentsénals/aitwwblfivsieglcdec's'ortfieir data they provide, and their assistance in presentingWe‘re Himmsuasérvea seumrfewy mailmareount to my successas a jury expert.Dr. Mykol HamiltonJury 2021
Page 4 of 6Welcome to Ironwood Insights GroupA 2019A2018TOPCOMPANY TOPCOMPA NY‘fOTM‘WResearch,Quantitativeas seen infor,,Advertising ResearchOUIRKISseen mOSA 2019A2019MAGAZINEM PANYTOPCWPWTOPC?orResearchOnline ResearchcTelephone(IS seen InISQUIRKMAGAZINEas seen InAAAAAAAAAABLUEBOOKMadam;— AResearch Servce: Director,msL‘mpICEOMPANY.-.lawman"3.Amm.:E TOP COMPAméhttps://ironwoodinsights.com/mTOP COMPANYI.ATracking Resentch‘Consume: Reseauh1/25/2021
Page 5 of 6Welcome to Ironwood Insights Group AE mp828 ResearchEum—mp � WP COMPANYNY;IElTelephone ResearchtCONTACTLet's Get To WorkSend us a message. We'll connect you withone of our specialist and get started onbuilding your plan.CONNECT WITH USRESEARCH DESIGNYour Objectives Are OurObjectivesWe use a number of research solutions tocollect the richest type of data that isalways based around your needs.https://ironwoodinsights.com/1/25/2021
Page 6 of6Welcome to Ironwood Insights GroupLEARN MOREInfo@ironwoodinsights.com801 insights.com/ 2021Ironwood Insights Group1/25/2021
Data CollectionPage l of llRONWCODDNSICHTSDATA COLLECTIONQualitative MethodsWe offer a myria& llEinimmghxaasmm& the diverseneeds of our clients, their targeted audience and the strategicobjectives. As you design a qualitative research plan it's critical toconsfléfllfiefififiaeélfiflm each study. A good qualitativeresearcher should have a variety of tools at hand — instead of dependingon one methodology for every onl/2 5/202 l
Page 2 of llData CollectionFocus groups continue to provide invaluable revelations to our clients in theback room, as they hear and see participants immediate reactions to theirconcepts, products and services.Online Focus GroupsAn ideal methodology when wanting to bring a small group together for aquick dive that results in actionable findings.Online Bulletin BoardsEliminates client and moderator travel, while gaining deep insights with anoption of video/photo creative assignments to gain a completeunderstanding of preferences, usage. and emotions surrounding a productor service.ln-Depth InterviewsA preferred methodology when sharing sensitive information or views thatmay be unique across targeted participants.What's The Best Method For Your Next Study?Download our Qualitative Methodology Grid to get a better idea of whereyour efforts are best directed. Our qualitative grid compares the variousmethodologies across attributes like Scheduling, Duration, Travel,Number of Participants and more.DOWNLOAD THE GUIDEhttpszllironwood insights.com/data-collection”25/202 l
Page 3 ofData Collectionll11".‘4"atiyll'fl.‘Q'fii! 1Ironwood OnlineOnline surveygfigseggcgilng 9§LWEO ME 8 2 ERES§§W Theyprovide quick results and offer options not available via the phone, likemeasuring satisfaction levels while watching a video clip, viewingpoteig’gaimgmmflons and ranking logos based on desirability. We“39‘PfiM8 n 0 accessexpegencit’galtan%n§%1%: nMonitor Age Gender,pAnd Geographic Distributions(desktop,Study FieldingBegin With Soft LaunchCheck Data For Accuracy And integrityAddress Areas Of ConcernStratify Sample Over Field PeriodExclusion Of Deceptive RespondersPattern Recognition Traps For Straight Liners And TreeingTiming Variance From The Average n1/25/2021
Page 4 of l lData CollectionData Checks -VarianceInDataEliminating Repeat AttemptsIP Address CheckUnique IDs And PasswordsReal Time Report Portal w/ Dashboard24/7 Access To DataReview Quotas And MarginalsView Data Dispositions and ction1/25/2021
Page 5 of l iData Collectionii it:,5.i,Online SamplesAt Ironwood Insights Group we know that online sampling is as much artas it is science. We only partner with the panels that guarantee quality,can clearly identify sourcing methods and provide 24/7 support.With multiple panels at our disposal, we provide representative samplesacross the country and around the world. We have fielded hundreds 25/2021
Page 6 ofData Collectionllonline studies ranging from 60 minute in-depth automotive projects, toshort mobile-only projects with teens.i‘ “‘2";A)is ‘9'Telephone ResearchAll telephone studies are conducted in call centers which are 100%TCPA and HIPAA compliant and use the latest data collection softwareand hardware. Our wholly owned and operated call centers located inhttps://ironwoodinsights.com/dala-collectionl /2 5/202 l
Data CollectionPage 7 of llUT, CO, WY, ID and TX feature 250 seats and are staffed by the finestinterviewers and supervisors in the country.OuPert§sL9n§gaegergsfisggsoilsstmgm swarms“tight ship” but provide our interviewers a fun and enjoyable atmospherewhere they can learn, grow and collect accurate data for our clients.TrainingCollecting quality data is ourhighestTo that end, we adhere toof mtervnewers wrtgriority.an emphasrs on accurate recording ofthe bggqan 'in-depth probing of open ends.resp nsesgagingCATI ProgrammingAll CATl programming is thoroughly tested internally and by clients prior tofielding.FieldingSample is dialed over a period of days, evenly across shifts to ensure properrepresentation of the population.MonitoringInterviewers are monitored continuously via silent audio to ensure qualityand accuracy.Data SafeguardsData is reviewed after soft launch to ensure all responses are capturedaccurately and in the correct locations.Interviewer Analysisinterviewer statistics are analyzed and evaluated individually on a daily basisto identify variances between interviewers and to identify opportunities foradditional training.Online ReportingReal-time reporting for all studies is available via our report portal; includingstudy dashboard, quotas, dialing statistics and ction1/25/2021
Page 8 ofData Collectionllmg3vLg.»“:9!LL,ii“gigs"FMail SurveysIronwood partners with mail-houses across the country to provide fullservice printing, mailing and fulfillment. From simple postcards to fullsurveys with BRE and return scanning, we have you tionl /25/202
Data CollectionPage 9 of ll\ Au-Interactive Voice ResponseOur IVR solution offers flexible, fast, and affordable engagement withcustomers or respondents. IVR can be deployed for a variety ofpurposes. Programmed using CfMC/Survox Software, allows forflexibility and management tools necessary to successfully execute 25/2021
Page 10 of l lData CollectionIVR project, including the ability to begin a survey using IVR, but have thecall transferred to a live agent upon mentions of “hot topics" that need amore live and personal touch.A costtive way to interact withoneoutbExes:our cmers via inbound orOnyTransac onal surveys a call-in number on the back of a receipt)Customer service surveyssatisfaction surveysGe InCuEtomessur n as our incentive processingpartrmi‘figisaaugwgmmgsoffer your reSpondents a wide variety ofincentive options (from Amazon to Uber Eats, and of course Cash) at theconclusion of a survey. Incentive redemption egmilsm be sent almostimmediately as a respondents completes a survey or they can bebatched and sent at specific time interm'ShSoiifioIWincssimple for respondents to redeem their gifts and is flexible forcustomers to maximize effectmfeséa "1935899- We'“ conned YOU Withone of our specialist and get started onbuilding your plan.CONNECT WITH USANALYTICS&REPORTINGStructured Reports BySeasoned ection1/25/2021
Data CollectionPagell of llWith several decades of experience. weprovide not just insight but soundperspective to our clients.LEARN MOREinfo@ironwoodinsights.com801 -569-01 07FacebookLinkedinCopyright 2021 Ironwood insights n1/25/2021
Page l of5Analytics & ReportingRONW@DNSICHTSANALYTICS8:REPORTINGWe Help Uncover Relevant InsightsDriver AnalysisMultiple regressionLogitPLSTree analysisBayesian NetworksProduct Design, Pricing and Volumetric ModelsConjoint and discrete choiceMax-diffVanWestendorp analysisFactor/Cluster Segmentation AlgorithmsLatent classEnsembleK-meansPLSSmart crosstabsNon-verbal Emotional -reporting1/25/202 l
0Page 2 of 5é%?E'&;§.4Analytics & d-reporting1/25/2021
Analytics & ReportingPage 3 of 5Text AnalyticsOuriffifitwggmpach clientproprietaryfwwmimv‘e’igbased on their own needs. Data can befrom reviewpulledwebsites,social media, business intelligence, traditional data collection, includingor any other data source.focusrg‘raclacué)I gggfilgrigtlons,Explcfimofieaalimanmmmsstand what "Big Data" has to offer and how itcan Mbifiawgecisions, answer company questions, measurebusiness rfiféflgrfilfiflflflseful whenit is conveyed and understood properly.We will create custom data visualization dashboards to give you theerfect blend ofvisual elements and analytics.Quality Score9. 38I ninglQ5/2021
Analytics & ReportingPage 4 of 5Custom Data Visualization DashboardsOur experience is our PromiseOurPegs'xsausmwmr fiuamssssnmsleiksxmshave several decades of experience. Most have worked on the clientside — advertising, PR and business consulting. We provide not justinsightlbmwombbeamfmm job fielding our mixed-modesurvey in several cities across the U.S. We tasked theIronwood team with a challenging set of quotas in order toobtain a sample that over-represented people with lowerincomes and people of color. They expertly executed thesample management, fielding of both a web and phoneversion of the survey, in multiple locations and languages.and ensured that we received accurate data in a cs-and-reportingl 125/202]
Analytics & ReportingPage 5 of 5Their expertise fielding surveys is further complimented bytheir friendly and professional interactions with the client.Vanessa OddoAssistant Professor, State UniversityLet's Get To WorkSend us a message. Let's get started onbuilding your research strategy.CONNECT WITH USinfo@ironwoodinsights.com801 -569-01 07FacebookLinkedinCopyright 2021 Ironwood Insights porting1/25/2021
Attorney for LORI NORENE (DAYBELL) VALLOW . IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OF . THE STATE OF IDAHO, IN AND FOR THE COUNTY OF FREMONT . . MADISON COUNTY PROSECUTING ATTORNEY x Efile 159 E. Main St. P.O. Box 350 . Rexburg, ID 83440 . Email:mcpo@madison.id.us. Mr. John Prior x Efile Email: john@jpriorlaw.com . DATED this .
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