Motion to Temporarily Seal Exhibits

CASE NO CR 29-22-2805

2024 Maut 10 12:22 CLERK OF DISTRICT COURT Pim
LATAH COUNTY

LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No, 2613 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 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

V. SEAL EXHIBIT (S) 1 OF

" STATE'S

SECOND SUPPLEMENTAL

BRYAN CHRISTOPHER KOHBERGER, RESPONSE TO DEFENDANT'S

Defendant. FOURTH MOTION TO COMPEL
DISCOVERY " AND " STATE'S

SUPPLEMENTAL RESPONSE TO

DEFENDANT'S FIFTH MOTION

TO COMPEL DISCOVERY "

PENDING 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 (s) 1 of " State's Second Supplemental Response to Defendant's Fourth Motion to Compel Discovery " and " State's Supplemental Response to Defendant's Fifth Motion to Compel Discovery ” herein because MOTION TO TEMPORARILY SEAL EXHIBIT (S) 1 OF " STATE'S SECOND SUPPLEMENTAL RESPONSE TO DEFENDANT'S FOURTH MOTION TO COMPEL DISCOVERY " AND " STATE'S SUPPLEMENTAL RESPONSE
TO DEFENDANT'S FIFTH MOTION TO COMPEL DISCOVERY " PENDING HEARING 1

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 (s) 1 of " State's Second Supplemental Response to Defendant's Fourth Motion to Compel Discovery " and " State's 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.

RESPECTFULLY SUBMITTED this 10th_day of May, 2024.

Ashley Jennings Senior Deputy Prosecutor MOTION TO TEMPORARILY SEAL EXHIBIT (S) 1 OF " STATE'S SECOND SUPPLEMENTAL RESPONSE TO DEFENDANT'S FOURTH MOTION TO COMPEL DISCOVERY " AND " STATE'S 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 (S) 1 OF “ STATE'S SECOND SUPPLEMENTAL RESPONSE TO
DEFENDANT'S FOURTH MOTION TO COMPEL DISCOVERY ” AND “ STATE'S
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 May, 2024.

S

MOTION TO TEMPORARILY SEAL EXHIBIT (S) 1 OF " STATE'S SECOND SUPPLEMENTAL RESPONSE TO DEFENDANT'S FOURTH MOTION TO COMPEL DISCOVERY " AND " STATE'S SUPPLEMENTAL RESPONSE
TO DEFENDANT'S FIFTH MOTION TO COMPEL DISCOVERY " PENDING HEARING 3