Motion to Seal Penalty Phase Expert Exhibits

Electronically Filed
5/27/2025 4:26 PM

Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Chynae Hull, Deputy Clerk
LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No. 2613
PROSECUTING ATTORNEY

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

JOSHUA D. HURWIT, ISB. No. 9527
SPECIAL DEPUTY PROSECUTING ATTORNEY

Latah County Courthouse 522 S. Adams Street, Ste. 211 Moscow, ID 83843
Phone: (208) 883-2246 paservice@latahcountyid.gov
IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF THE
STATE OF IDAHO IN AND FOR THE COUNTY OF ADA

STATE OF IDAHO, Case No. CR01-24-31665 Plaintiff,
MOTION TO SEAL EXHIBITS

V. ATTACHED TO STATE'S

SUPPLEMENTAL REBUTTAL

BRYAN C. KOHBERGER, DISCLOSURE RE: PENALTY

Defendant. PHASE EXPERT
(DR. JASON D. GAGE)

COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney and hereby moves the Court pursuant to Idaho Court Administrative Rule 32 (g) (1) and Idaho Code §74-124 (a) - (c) for an Order Sealing Exhibits S-1 and S-2 attached to “ State's Supplemental Rebuttal Disclosure Re: Penalty Phase Expert (Dr. Jason D. Gage) " filed on May 27, 2025. Exhibit S-1 is a neuropsychology evaluation completed by Dr. Gage. Exhibit S-1 contains private medical information which is exempted from public disclosure pursuant
MOTION TO SEAL EXHIBITS ATTACHED TO STATE'S SUPPLEMENTAL REBUTTAL
DISCLOSURE RE: PENALTY PHASE EXPERT (DR. JASON D. GAGE) 1

to I.C. 74-124 (c). Exhibit S-2 is a Curriculum Vitae which is exempted from public disclosure pursuant to I.C. 74-124 (a) and / or (b) and like filings have been sealed by this Court.

RESPECTFULLY SUBMITTED this 27th day of May 2025.

asneup &. ganings Ashley S. Jennings Senior Deputy Prosecuting Attorney
MOTION TO SEAL EXHIBITS ATTACHED TO STATE'S SUPPLEMENTAL REBUTTAL
DISCLOSURE RE: PENALTY PHASE EXPERT (DR. JASON D. GAGE) 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO SEAL EXHIBITS
ATTACHED TO STATE'S SUPPLEMENTAL REBUTTAL DISCLOSURE RE: PENALTY
PHASE EXPERT (DR. JASON D. GAGE) were served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law ☑ E-filed & Served / E-mailed PO Box 2347 Faxed Coeur D Alene, ID 83816 info@annetaylorlaw.com Hand Delivered Dated this 27th day of May, 2025.

MOTION TO SEAL EXHIBITS ATTACHED TO STATE'S SUPPLEMENTAL REBUTTAL
DISCLOSURE RE: PENALTY PHASE EXPERT (DR. JASON D. GAGE) 3