Motion to Temporarily Seal Exhibit

CASE NO. CR29-22-2805

4/10/2024 @, 1:24 pm
DATE / TIME

LATAH COUNTY, CLERK OF DISTRICT COURT

LATAH COUNTY PROSECUTOR'S OFFICE TSR

WILLIAM W. THOMPSON, JR., ISB No, 2613 BY PROSECUTING ATTORNEY Deputy ASHLEY S. JENNINGS, ISB No. 8491
SENIOR DEPUTY PROSECUTOR

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 EXHIBIT 1 OF STATE'S

THIRD SUPPLEMENTAL

V. RESPONSE TO DEFENDANT'S

FIFTH MOTION TO COMPEL

BRYAN CHRISTOPHER KOHBERGER, DISCOVERY PENDING

Defendant. HEARING 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 Exhibit 1 of the State's Third Supplemental Response to Defendant's Fifth Motion to Compel 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 STATE'S THIRD SUPPLEMENTAL RESPONSE
TO DEFENDANT'S FIFTH MOTION TO COMPEL DISCOVERY PENDING HEARING 1

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 Exhibit 1 of the State's Third Supplemental Response to Defendant's Fifth Motion to Compel Discovery herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

Anne Taylor has confirmed that the Defense does not have an objection to this motion.

RESPECTFULLY SUBMITTED this 10th day of June, 2024.

ashups. Ganings Ashley Jennings Senior Deputy Prosecutor
MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF STATE'S THIRD SUPPLEMENTAL RESPONSE
TO DEFENDANT'S FIFTH MOTION TO COMPEL DISCOVERY PENDING HEARING 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL EXHIBIT 1 OF STATE'S THIRD SUPPLEMENTAL RESPONSE TO

DEFENDANT'S FIFTH MOTION TO COMPEL 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 10th day of June, 2024.

MOTION TO TEMPORARILY SEAL EXHIBIT 1 OF STATE'S THIRD SUPPLEMENTAL RESPONSE
TO DEFENDANT'S FIFTH MOTION TO COMPEL DISCOVERY PENDING HEARING 3