"The Defendant, Dana Thompson, has a history of suffering from mental health issues which include Post-Traumatic Stress Disorder, severe anxiety, unspecified psychosis, schizophrenia, bi-polar disorder, including past suicide attempts and suicidal ideation," the sanity evaluation motion states. "As to such previous diagnosis, the Defendant has previously received treatment and continues to be treated for same. That the Defendant’s counsel has had opportunities to discuss this matter with the Defendant … and the nature of the charged offenses and the potential outcomes as applied to same … the Defendant, Dana Thompson, asserts that she has no memories or recollections regarding the dates surrounding the alleged incidents or even the alleged incidents occurring themselves."

The motion from the public defender goes on to explain how "the Defendant’s counsel believes that a bonafide doubt exists as to the Defendant’s fitness and ability to stand trial and/or assist in her defense. That based upon such discussions with the Defendant, Dana Thompson, Defense counsel believes that it may be necessary to raise a defense of insanity."