WILLIAM J. MARTINEZ, District Judge.
John F. Sullivan of the Law Office of John F. Sullivan, III, PC, pursuant to 18 U.S.C. § 4241, respectfully requests this Court enter an order to help determine the mental competency of the Defendant. Counsel submits this request based upon an expert who examined the Defendant on two occasions and administered a battery of tests. He expressed concern about her level of competency. Moreover, this request is also based upon jail medical personnel, his own contact and the reports from family members. All of the above leads to a belief that there is reasonable cause to believe the Defendant may be suffering from a mental disease or defect, likely from brain trauma occurring in two car accidents, rendering her mentally incompetent to the extent that she is unable to understand the nature and consequences of the proceedings against her or to assist properly in her defense. Assistant United States Attorney Colleen Covell objects to this request and believes the Defendant to be malingering and is competent.
WHEREFORE, based upon the above, the Defendant respectfully requests this Court enter an order to have the Defendant examined and competency determined and for all other relief proper in the premises.