Motion to Temporarily Seal Exhibit C

CASE NO CR 29-22-2805

2023 September 12
CLERK OF DISTRICT COURT 11:26

LATAH COUNTY

a.m.

LATAH COUNTY PROSECUTOR'S OFFICE DEPUTY

WILLIAM W. THOMPSON, JR., ISB 2613 BY

PROSECUTING ATTORNEY

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843
Phone: (208) 883-2246 paservice@latah.id.us
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 C OF

SUPPLEMENT TO STATE'S

NOTICE OF INTENT NOT TO

CROSS-EXAMINE DEFENSE

WITNESSES, DISTRICT COURT

DECISION, AND RECORDS TO

EXPLAIN WITNESS CONTACT

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 C of the Supplement to State's Notice of Intent Not to Cross-Examine Defense Witnesses, District Court Decision, and Records to Explain Witness Contact herein because release or disclosure would:
MOTION TO TEMPORARILY SEAL EXHIBIT C OF SUPPLEMENT TO STATE'S NOTICE OF
INTENT NOT TO CROSS-EXAMINE DEFENSE WITNESSES, DISTRICT COURT DECISION, AND
RECORDS TO EXPLAIN WITNESS CONTACT PENDING HEARING 1

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 C of Supplement to State's Notice of Intent Not to Cross-Examine Defense Witnesses, District Court Decision, and Records to Explain Witness Contact herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

RESPECTFULLY SUBMITTED this 12 day of September, 2023.

William W. Thompson, Jr.

Prosecuting Attorney
MOTION TO TEMPORARILY SEAL EXHIBIT C OF SUPPLEMENT TO STATE'S NOTICE OF
INTENT NOT TO CROSS-EXAMINE DEFENSE WITNESSES, DISTRICT COURT DECISION, AND
RECORDS TO EXPLAIN WITNESS CONTACT PENDING HEARING 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL EXHIBIT C OF SUPPLEMENT TO STATE'S NOTICE OF INTENT NOT TO
CROSS-EXAMINE DEFENSE WITNESSES, DISTRICT COURT DECISION, AND
RECORDS TO EXPLAIN WITNESS CONTACT 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 12th day of September, 2023.

S

MOTION TO TEMPORARILY SEAL EXHIBIT C OF SUPPLEMENT TO STATE'S NOTICE OF
INTENT NOT TO CROSS-EXAMINE DEFENSE WITNESSES, DISTRICT COURT DECISION, AND
RECORDS TO EXPLAIN WITNESS CONTACT PENDING HEARING 3