Court Filing
CR 29-22-2805 CASE NO. 2023 July 25 2:50 CLERK OF DISTRICT COURT p.m LATAH COUNTY PROSECUTOR'S OFFICE LATAH COUNTY ам 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 EXHIBITS 1 AND 2 OF THE STATE'S RESPONSE TO V. DEFENDANT'S 5th AND 6th SUPPLEMENTAL REQUESTS BRYAN CHRISTOPHER KOHBERGER, FOR 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 Exhibits 1 and 2 attached to the State's Response to Defendant's 5th and 6th Supplemental Requests 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 EXHIBITS 1 AND 2 OF THE STATE'S RESPONSE TO DEFENDANT'S 5th AND 6th SUPPLEMENTAL REQUESTS 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 Exhibits 1 and 2 attached to the State's Response to Defendant's 5th and 6th Supplemental Requests for Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124. Dated this day of July, 2023. Ashley Sun Ashley Jennings Senior Deputy Prosecuting Attorney MOTION TO TEMPORARILY SEAL EXHIBITS 1 AND 2 OF THE STATE'S RESPONSE TO DEFENDANT'S 5th AND 6th SUPPLEMENTAL REQUESTS FOR DISCOVERY 2 CERTIFICATE OF DELIVERY I hereby certify that true and correct copies of the MOTION TO TEMPORARILY SEAL EXHIBITS 1 AND 2 OF THE STATE'S RESPONSE TO DEFENDANT'S 5th AND 6th SUPPLEMENTAL REQUESTS 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 25th day of July, 2023. Dated this MOTION TO TEMPORARILY SEAL EXHIBITS 1 AND 2 OF THE STATE'S RESPONSE TO DEFENDANT'S 5th AND 6th SUPPLEMENTAL REQUESTS FOR DISCOVERY 3