Motion to Temporarily Seal Exhibits 1 and 2

CASE NO CR 29-22-2805

20230 2023 October 24 3:02 CLERK OF DISTRICT COURT p.m
LATAH COUNTY

LATAH COUNTY PROSECUTOR'S OFFICE aal
RV DEPUTY

WILLIAM W. THOMPSON, JR., ISB No. 2613
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 8th AND 9th
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 8th and 9th 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

8th AND 9th 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 8th and 9th Supplemental Requests for Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

Dated this 24th day of October, 2023.

Ashley Jennings Jo Senior Deputy Prosecuting Attorney
MOTION TO TEMPORARILY SEAL EXHIBITS 1

AND 2 OF THE STATE'S RESPONSE TO DEFENDANT'S

8th AND 9th 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 THE STATE'S RESPONSE TO DEFENDANT'S 8th AND 9th 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 Dated this 24 day of October, 2023.

Jaced
MOTION TO TEMPORARILY SEAL EXHIBITS 1

AND 2 OF THE STATE'S RESPONSE TO DEFENDANT'S

8th AND 9th SUPPLEMENTAL REQUESTS FOR DISCOVERY 3