Motion to Temporarily Seal Exhibits

CASE NO CR 29-22-2805

2023 September 14 3:21
CLERK OF DISTRICT COURT P.M.

LATAH COUNTY

AM

LATAH COUNTY PROSECUTOR'S OFFICE BY DEPUTY

WILLIAM W. THOMPSON, JR., ISB 2613

PROSECUTING ATTORNEY

JEFF NYE, ISB 9238

SPECIAL ASSISTANT ATTORNEY GENERAL

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843
Phone: (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 A AND B OF

STATE'S MOTION TO TAKE

JUDICIAL NOTICE OF GRAND

JURY RECORD PENDING

HEARING

V.

BRYAN CHRISTOPHER KOHBERGER,

Defendant.

COME 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 for a Temporary Order Sealing Exhibits A and B of the State's Motion to Take Judicial Notice of Grand Jury Record 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 EXHIBITS A AND B OF STATE'S MOTION TO TAKE
JUDICIAL NOTICE OF GRAND JURY RECORD 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 undersigned seek this protection pending a hearing on the matter.

Wherefore, the State respectfully prays that the Court seal from public disclosure Exhibits A and B of the State's Motion to Take Judicial Notice of the Grand Jury Record herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

14 day of September, 2023.

RESPECTFULLY SUBMITTED this William W. Thompson, Jr.

Prosecuting Attorney
MOTION TO TEMPORARILY SEAL EXHIBITS A AND B OF STATE'S MOTION TO TAKE
JUDICIAL NOTICE OF GRAND JURY RECORD PENDING HEARING 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL EXHIBITS A AND B OF STATE'S MOTION TO TAKE JUDICIAL NOTICE OF
GRAND JURY RECORD PENDING HEARING were served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law X E-filed & Served / E-mailed PO Box 9000 Faxed Coeur D Alene, ID 83816-9000 Hand Delivered Dated this 14 day of September, 2023.

Se
MOTION TO TEMPORARILY SEAL EXHIBITS A AND B OF STATE'S MOTION ΤΟ ΤΑΚΕ
JUDICIAL NOTICE OF GRAND JURY RECORD PENDING HEARING 3