Motion to Temporarily Seal Exhibit A

CR29-22-2805

CASE IVU

7/4/23 2:15 PM

CLERK OF DISTRICT COURT

LATAH COUNTY PROSECUTOR'S OFFICE LATAH COUNTY

WILLIAM W. THOMPSON, JR., ISB No, 2613 JO
BY. DEPUTY

PROSECUTING ATTORNEY

ASHLEY S. JENNINGS, ISB No. 8491
SENIOR DEPUTY PROSECUTOR

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843
Phone: (208) 883-2246 ISB No. 2613 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 A OF THE

AMENDED STIPULATION AND

AMENDED ORDER FOR

PREPARATION AND RELEASE

OF TRANSCRIPT AND RECORD

OF GRAND JURY

PROCEEDINGS WITH

CONDITIONS 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 EXHIBIT A OF THE AMENDED
MOTION TO TEMPORARILY SEAL EXHIBIT A OF THE AMENDED STIPULATION AND
AMENDED ORDER FOR PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD OF
GRAND JURY PROCEEDINGS WITH CONDITIONS PENDING HEARING 1

STIPULATION AND AMENDED ORDER FOR PREPARATION AND RELEASE OF
TRANSCRIPT AND RECORD OF GRAND JURY PROCEEDINGS WITH CONDITIONS
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,
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 A OF THE AMENDED STIPULATION AND AMENDED ORDER FOR

PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD OF GRAND JURY
PROCEEDINGS WITH CONDITIONS herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

RESPECTFULLY SUBMITTED this day of July, 2023.

Ashley Jennings Senior Deputy Prosecutor
MOTION TO TEMPORARILY SEAL EXHIBIT A OF THE AMENDED STIPULATION AND
AMENDED ORDER FOR PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD OF
GRAND JURY PROCEEDINGS WITH CONDITIONS PENDING HEARING 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL EXHIBIT A OF THE AMENDED STIPULATION AND AMENDED ORDER FOR
PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD OF GRAND JURY
PROCEEDINGS WITH CONDITIONS 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 6 day of July, 2023.

Stev
MOTION TO TEMPORARILY SEAL EXHIBIT A OF THE AMENDED STIPULATION AND
AMENDED ORDER FOR PREPARATION AND RELEASE OF TRANSCRIPT AND RECORD OF
GRAND JURY PROCEEDINGS WITH CONDITIONS PENDING HEARING 3