Motion to Temporarily Seal Exhibit 1

CASE NO CR 29-22-2805

2023 Sept 6 10:49 am
CLERK OF DISTRICT COURT

LATAH COUNTY PROSECUTOR'S LATAH COUNTY

OFFICE

WILLIAM W. THOMPSON, JR., ISB No. 2613 BY
DEPUTY

PROSECUTING ATTORNEY

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@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 1 OF THE

STATE'S RESPONSE TO

V. DEFENDANT'S 7th
SUPPLEMENTAL REQUEST FOR

BRYAN CHRISTOPHER KOHBERGER, DISCOVERY

Defendant.

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 Response to Defendant's 7th 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;
2. Constitute an unwarranted invasion of personal privacy,
MOTION TO TEMPORARILY SEAL EXHIBIT 1

OF THE STATE'S RESPONSE TO DEFENDANT'S

7th SUPPLEMENTAL REQUEST FOR DISCOVERY 1

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 Response to Defendant's 7th Supplemental Request for Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

Dated this leth day of September, 2023.

gs Senior Deputy Prosecuting Attorney
MOTION TO TEMPORARILY SEAL EXHIBIT 1

OF THE STATE'S RESPONSE TO DEFENDANT'S

7th SUPPLEMENTAL REQUEST FOR DISCOVERY 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY SEAL EXHIBIT 1 THE STATE'S RESPONSE TO DEFENDANT'S 7th 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 6 day of September, 2023.

Dacia Teng Maciel
MOTION TO TEMPORARILY SEAL EXHIBIT 1

OF THE STATE'S RESPONSE TO DEFENDANT'S

7th SUPPLEMENTAL REQUEST FOR DISCOVERY 3