Motion to Temporarily Seal Exhibit A

CLRK CASE

JUN BY

--TOR NO

OF 27

DIST.

2023 CR29-22-2805

LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR. CT

PM3 DEPUTY

PROSECUTING ATTORNEY.

LATAH: 25

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843
Phone: (208) 883-2246 ISB No. 2613 paservice@latahcountyid.gov
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 A OF THE

V. STIPULATION FOR

BRYAN CHRISTOPHER KOHBERGER, PREPARATION AND RELEASE

Defendant. OF TRANSCRIPT AND RECORD
OF GRAND JURY

PROCEEDINGS WITH

CONDITIONS

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), Idaho Criminal Rule 6, and Idaho Code §19-1112 and §74-124 for a Temporary Order Sealing Exhibit A attached to the Stipulation for Preparation and Release of Transcript and Record of Grand Jury Proceedings with Conditions 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 A OF THE STIPULATION

FOR PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD

OF GRAND JURY PROCEEDINGS WITH CONDITIONS 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 A attached to the Stipulation for Preparation and Release of Transcript and Record of Grand Jury Proceedings with Conditions herein under the provisions of Idaho Court Administrative Rule 32 (g) (1), Idaho Criminal Rule 6, and Idaho Code §19-1112 and §74-124.

th RESPECTFULLY SUBMITTED this 27 day of June, 2023.

WILLIAM W. THOMPSON, JR.

Prosecuting Attorney....

MOTION TO TEMPORARILY SEAL EXHIBIT A OF THE STIPULATION

FOR PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD

OF GRAND JURY PROCEEDINGS WITH CONDITIONS 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL EXHIBIT A OF THE STIPULATION FOR PREPARATION AND RELEASE OF
TRANSCRIPT AND RECORD OF GRAND JURY PROCEEDINGS WITH

CONDITIONS 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 27th day of June, 2023.

Dated this Mallas
MOTION TO TEMPORARILY SEAL EXHIBIT A OF THE STIPULATION

FOR PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD

OF GRAND JURY PROCEEDINGS WITH CONDITIONS 3