Motion to Temporarily Seal State Response

CLRK CASE

JUN BY

OF 29 NO

DIST.

2023 CR29-22-2805

LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No. 2613 CT
PM3 DEPUTY

PROSECUTING ATTORNEY. LATAH

ASHLEY S. JENNINGS, ISB No. 8491: 53
SENIOR DEPUTY PROSECUTING ATTORNEY

Latah County Courthouse P.O. Box 8068 Moscow, Idaho 83843-0568 (208) 883-2246 paservice@latah.id.us
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 No. CR29-22-2805 Plaintiff,
MOTION TO TEMPORARILY

V. SEAL STATE'S RESPONSE

TO DEFENDANT'S SECOND

BRYAN CHRISTOPHER KOHBERGER, MOTION TO COMPEL

Defendant. DISCOVERY The State of Idaho, by and through the Latah County Prosecuting Attorney, respectfully moves the Court pursuant to Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124 for a Temporary Order Sealing State's Response to Defendant's Second Motion to Compel :
Discovery herein because release or disclosure would:
1. Interfere with enforcement proceedings;
2. Deprive a person of a right to a fair trial or an impartial adjudication;
2. Constitute an unwarranted invasion of personal privacy,
3. Disclose the identity of a confidential source; and / or
MOTION TO TEMPORARILY SEAL STATE'S RESPONSE

TO DEFENDANT'S SECOND MOTION TO COMPEL DISCOVERY 1

4. Disclose investigative techniques and procedures.

The State seeks this protection pending a hearing on the matter.

Wherefore, the State respectfully prays that the Court seal from public disclosure the State's Response to Defendant's Second Motion to Compel Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

Dated this gath day of June, 2023.

Ashley Jennings Senior Deputy Prosecuting Attorney
MOTION TO TEMPORARILY SEAL STATE'S RESPONSE

TO DEFENDANT'S SECOND MOTION TO COMPEL DISCOVERY 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL STATE'S RESPONSE TO DEFENDANT'S SECOND MOTION TO COMPEL
DISCOVERY was served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law E-filed & Served / E-mailed PO Box 9000 Faxed Coeur D Alene, ID 83816-9000 Hand Delivered Dated this 29 day of June, 2023.

:
MOTION TO TEMPORARILY SEAL STATE'S RESPONSE

TO DEFENDANT'S SECOND MOTION TO COMPEL DISCOVERY 3