Motion to Temporarily Seal Exhibit 1

CR29-22-2805

CASE NO.

1/22/24 @ 1:30 pm
DATE / TIME

LATAH COUNTY PROSECUTOR'S OFFICE LATAH COUNTY, CLERK OF DISTRICT COURT
WILLIAM W. THOMPSON, JR., ISB No. 2613 The
PROSECUTING ATTORNEY BY

Deputy 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 11th
SUPPLEMENTAL REQUEST FOR

BRYAN CHRISTOPHER KOHBERGER, DISCOVERY PENDING

Defendant. HEARING 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 11th 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 RESPONSE TO DEFENDANT'S 11th SUPPLEMENTAL
REQUEST FOR DISCOVERY PENDING HEARING 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 temporarily seal from public disclosure Exhibit 1 attached to the State's Response to Defendant's 11th Supplemental Request for Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

Dated this 22nd day of January, 2024.

ashleys. Junip Ashley Jennings Senior Deputy Prosecuting Attorney
MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF THE

STATE'S RESPONSE TO DEFENDANT'S 11th SUPPLEMENTAL
REQUEST FOR DISCOVERY PENDING HEARING 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF THE STATE'S RESPONSE TO DEFENDANT'S 11th SUPPLEMENTAL REQUEST FOR DISCOVERY PENDING HEARING 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 22nd day of January, 2024.

Song
MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF THE

STATE'S RESPONSE TO DEFENDANT'S 11th SUPPLEMENTAL
REQUEST FOR DISCOVERY PENDING HEARING 3