Motion to Temporarily Seal Exhibit 1

CLRK CASE

JUN BY

-- NO

OF 29

DIST.

2023 229-22-2805
LATAH COUNTY PROSECUTOR'S OFFICE

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

PROSECUTING ATTORNEY.

LATAH: 52

ASHLEY S. JENNINGS, ISB No. 8491
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

SEAL EXHIBIT 1 OF THE

V. STATE'S SUPPLEMENTAL

RESPONSE TO DEFENDANT'S

BRYAN CHRISTOPHER KOHBERGER, 4th SUPPLEMENTAL REQUEST Defendant. FOR 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 Exhibit 1 attached to the State's Supplemental Response to Defendant's 4th Supplemental Request for 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;
MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF

THE STATE'S SUPPLEMENTAL RESPONSE TO

DEFENDANT'S 4th SUPPLEMENTAL REQUEST FOR DISCOVERY 1

2. Constitute an unwarranted invasion of personal privacy,
3. Disclose the identity of a confidential source; and / or
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 Exhibit 1 attached to the State's Supplemental Response to Defendant's 4th Supplemental Request for Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

Dated this 29th day of June, 2023.

Ashly in Ashley Jennings Senior Deputy Prosecuting Attorney
MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF

THE STATE'S SUPPLEMENTAL RESPONSE TO

DEFENDANT'S 4th SUPPLEMENTAL REQUEST FOR DISCOVERY 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL EXHIBIT 1 OF THE STATE'S SUPPLEMENTAL RESPONSE TO

DEFENDANT'S 4th SUPPLEMENTAL REQUEST FOR DISCOVERY were 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 EXHIBIT I OF

THE STATE'S SUPPLEMENTAL RESPONSE TO

DEFENDANT'S 4th SUPPLEMENTAL REQUEST FOR DISCOVERY 3