Motion Requesting Release of Grand Jury Materials

CLRK CASE

MAY BY

OF -- NO

19
DIST,

Anne C. Taylor, Public Defender 2023 CR Kootenai County Public Defender CT PO Box 9000 PM3 29-22-2805
. DEPUTY

Coeur d'Alene, Idaho 83816 LATAH: 02
Phone: (208) 446-1700; Fax: (208) 446-1701
Bar Number: 5836 iCourt Email: pdfax@kcgov.us Assigned Attorney:
Anne C. Taylor, Public Defender, Bar Number: 5836 Jay W. Logsdon, Chief Deputy Public Defender, Bar Number: 8759 Elisa G. Massoth, Bar Number: 5647
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 NUMBER CR29-22-2805

Plaintiff,
MOTION REQUESTING RELEASE OF

V. GRAND JURY MATERIALS UNDER

QUALIFIED PROTECTIVE ORDER

BRYAN C. KOHBERGER,

Defendant.

COMES NOW, Bryan C. Kohberger, by and through his attorney, Anne C. Taylor, Public Defender, hereby moves the Court for an order to allow for release of the Grand Jury materials to be disclosed pursuant to a Qualified Protective Order as follows:
1. The materials, and any and all information contained therein, shall be disclosed only to:
A. All Legal Counsel representing Bryan Kohberger and the Latah County Prosecuting Attorney's Office; further all persons on Mr. Kohberger's defense team and the Office of the Latah County Prosecuting Attorney shall observe the terms of the Qualified Protective Order issued in conjunction with this Qualified Protective Order;
MOTION REQUESTING RELEASE OF GRAND JURY

MATERIALS UNDER QUALIFIED PROTECTIVE ORDER Page-1

B. Any expert witness, investigator or consultant of Bryan Kohberger's defense team and the Latah County Prosecuting Attorney's Office for whom access to the materials is necessary to perform a duty with respect to this case;
C. Any personnel of the Court and court reporters retained to record and transcribe testimony in this case;
2. The materials, and any and all information contained therein, shall be used only for the purpose of litigating this action.

3. The production of the materials shall not constitute a waiver of any privilege or other claim or right of withholding or confidentiality which by Bryan Kohberger may have.

DATED this 19 day of May, 2023.

ANNE C. TAYLOR, PUBLIC DEFENDER

ΚΟΟΤΕΝΑI COUNTY PUBLIC DEFENDER

an
BY:

ANNE TAYLOR

PUBLIC DEFENDER

ASSIGNED ATTORNEY

CERTIFICATE OF DELIVERY

I hereby certify that a true and correct copy of the foregoing was personally served as indicated below on the 19 day of May, 2023 addressed to:
Latah County Prosecuting Attorney -Via iCourt: paservice@latahcountyid.gov Jeff Nye, Deputy Attorney General – via iCourt: jeff.nye@ag.idaho.gov Ingrid Batey, Deputy Attorney General – via iCourt: ingrid.batey@ag.idaho.gov
Elisa Massoth-via iCourt: legalassistant@kmrs.net Dul
MOTION REQUESTING RELEASE OF GRAND JURY

MATERIALS UNDER QUALIFIED PROTECTIVE ORDER Page-2