Gough previously filed a motion seeking access to West's psychiatric records. This new motion again calls into question "whether she can accurately recall events" surrounding the killing of her son and "whether she played a more active role in the death of her son than she has acknowledged."

In addition, the filings now refer to West as a material witness. Gough questions why West almost immediately cremated her son's body and characterizes her behavior after the killing as "bizarre." He asks the state to disclose any evidence that West owns an insurance policy on the life of Santiago, which she's acknowledged, and whether she "stood to benefit financially" from his death.