Electronically Filed

6/10/2020 10:51 AM
Seventh Judicial District, Madison County
Kim Muir, Clerk of the Court
By: Angie Wood, Deputy Clerk

1 Mark L. Means (ISB 7530)

MEANS LAW and MEDIATION
2 MEANS-LAW
P.O. Box 544
3 Caldwell, ID 83606
Telephone: 208.794.3111
4 Facsimile: 1.866.228.3429
Email: mlm@means-law.com
5 Website: www.means-law.com
Attorney for LORI NORENE DAYBELL
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IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OF
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THE STATE OF IDAHO, IN AND FOR THE COUNTY OF MADISON
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9 STATE OF IDAHO, Case No: CR 33-20-0302

PLAINTIFF
10 MOTION FOR RELEASE TO DEFENSE
Vs. COUNSEL RE: Search Warrant No.: 2020-68.
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12 LORI NORENE VALLOW,

AKA LORI NORENE DAYBELL
13 DEFENDANT
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15 COMES NOW THE DEFENDANT, Mrs. Lori Vallow (Daybell), by and through her Attorney

16 of Record, Mark L. Means and moves this Court for an order of release to Defense Counsel the
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filed documents, exhibits, pleadings, warrants, applications, affidavits, corresponding orders,
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and/or records presented to the above Court in regards to the Search Warrant No. 2020-68
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issued/signed by the Court on 6/5/2020. Please note that by way of this Motion DEFENDANT
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21 does not requests this matter be unsealed but released said records/documents to said Counsel

22 under seal and or order of this Court.

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DATED this 10 day of June 2020.
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Mr. Mark L. Means
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PG. 1
1 CERTIFICATE OF SERVICE
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The undersigned certifies that on this 10 day of June 2020, I caused a true
3 and correct copy of the FOREGOING document to be forwarded by the method(s) indicated
below, to the following:
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MADISON COUNTY PROSECUTING OFFICE x Efile (Court Service Email)
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159 E. Main St.
6 P.O. Box 350
Rexburg, ID 83440
7 Email: rwood@co.madison.id.us
COURT SERVICE EMAIL: mcpo@co.madison.id.us
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DATED this 10 day of June 2020.
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By
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Mr. Mark L. Means
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PG. 2