I need to write up a motion to dismiss on grounds of insanity. I am uploading the facts of the case as well as what I have written so far. Any help fixing what I have written would be greatly appreciated.

Facts:

Lee Wang is a 32-year-old female. She was born and raised in China with an extremely strict father and was raised with traditional Chinese values. She immigrated to the United States when she was 17 years old to attend Columbia University in New York. She had a 4.0 GPA and was an honors graduate, and then I'm paying a master's in chemistry from Columbia University, graduating with honors and a 3.9 GPA. When Wayne was a child her father was extremely verbally and occasionally physically abusive, criticizing Link for being a female. Wing always wanted a son and was very upset from the day she was born that she was a female. Wing's father objected to wank moving to the United States and objected to her going to college. her father, to this day, is still very critical and difficult with her. when we became a citizen of the US and after graduating from college attained a job as a chemist with a salary of $125,000 with Sundew Pharmaceuticals, Inc. and Cambridge, Hamilton.

one day in the fall of 2012 when was arrested for larceny for stealing a $2 bracelet from Macy's department store in Cambridge. She hired noted criminal defense attorney Jasper Diment. Wayne told them she had no idea why she stole the bracelet. She had $100 in cash in her purse and a credit card with a large credit limit. when was extremely troubled and embarrassed by her arrest. she cried Non-Stop. She was barely able to compose herself at her arraignment in Hamilton State Superior Court.

At first, I thought Wayne was just overwhelmed with guilt. She began to tell him about her upbringing and her father, but Diment didn't really believe it would Aid in her offense. Diment began to pursue a case defense strategy around Wayne attaining a lenient criminal diversion deposition which was appropriate for first-time criminal offenders who are unlikely to offend again in the future. Wang, at first appeared to be an excellent candidate for this deposition.

Wang had an unusual habit. she would telephone damn it from work to ask questions about her case, but would always pretend to be calling about "her friend." Diment played along with it at first, but as the weeks went on the Habit annoyed Diment. In the beginning, he thought Wayne was protecting herself from possible work reprisals which might accompany her employer learning about her rest, overhearing her telephone conversations, Etc.

After Diment applied for the diversionary program, Lang was arrested for a second shoplifting incident. This time it was a $100.00 watch from Lord & Taylor's Department store. Again, Wang had no explanation for why she would steal again, and absolutely no recollection of the specifics of the incident.

Diment sent Wang to. Aillie concluded that "Wang suffers from a form of mental illness or disorder called the "Dissociative Identity Disorder/Multiple Personalities, DSM5." He has the personality of "the friend" who is a badly behaved criminal and is the opposite of the high achieving individual Wang was, in reality. He concluded that Wing developed this personality to cope with the internal stress and Trauma she suffered as a child as a result of the abusive conduct of her father. he said that

(1) the genuine shame that Wing exhibits due to her arrests,

(2) the fact that she was very able to pay for the items, and

(3) the possible severe consequences that the rest could have on her career, which she worked extremely hard to accomplish.

Diment is preparing a motion to dismiss the charges on the basis of the insanity defense. Hamilton follows the MPC (Insanity Defence) Model Penal Code's criteria for insanity, Which states that a person is not responsible for criminal conduct if, at the time of such conduct as a result of mental disease or defect, he lacks substantial capacity either to appreciate the criminality [wrongfulness] of his conduct or to conform his conduct to the requirements of law. The motion to dismiss the charges is a motion designed to persuade the judge that Wayne has a valid defense.

Write up the motion for dismissal of the charges, supporting facts of the case, and of the law.

So what I have written so far

In the case of Lee Wang, who is facing larceny charges for shoplifting incidents, I am submitting this motion to dismiss the charges based on the insanity defense. Reasons for themotion for dismissal, if the court is to consider Wang's mental condition, she lacked substantial capacity to conform her conduct to the law during the shoplifting incidents. This motion aligns with the Model Penal Code's criteria for insanity, Which states that a person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect, he lacks substantial capacity either to appreciate the criminality [wrongfulness] of his conduct or to conform his conduct to the requirements of law.

The following facts have been found by a medical professional. Through Dr. Alvin Aille's forensic psychiatric examination, he has concluded and diagnosed Ms. Wang with "Dissociative Identity Disorder/Multiple Personalities, DSM5." You may know this disorder better as multiple personality disorder which it was referred to and called until 1994 when the name was changed. When better knowledge and understanding was gained of the condition.

DSM5 is extremely rare and where there are no less than two and sometimes more very distinct and different identities or states of personality, occupy an individual. These personalities alternately are in control of the individual. Somewhat like a possession experience is how one may describe it. During the time of the other personality in control, there is a memory loss experience that can not be explained through normal memory loss or forgetfulness by the person. (Dissociative Identity Disorder (Multiple Personality Disorder), 2021)

Modern research has found that one of the leading causes of DID comes from a psychological response to protect oneself from interpersonal and environmental stresses. Many of the interpersonal and environmental stressors linked to DSM5 are emotional neglect or abuse during early childhood years which leads to excessive interference with the young child's personality development. As a number as many as up to 99% of the patients who have developed dissociative disorders come from a history of recurring, overpowering, and often life-threatening disturbances or traumas at a sensitive developmental stage of childhood (usually before age 6). (Begum, 2023)

Through his examination, Dr. Aille has seen Ms. Wang's four signs of truthfulness to her claim and her condition. Dr. Aille states that the chances that Wing is faking this illness (factitious disorder) is extremely unlikely due to.

1. Dissociative Identity Disorder Diagnosis: Dr. Alvin Aille's forensic psychiatric examination diagnosed Wang with Dissociative Identity Disorder (DID), also known as Multiple Personality Disorder according to DSM-5.

2. Childhood Trauma and Coping Mechanism: Aille's evaluation links Wang's development of a criminal personality ("the friend") to coping with childhood trauma and abusive conduct from her father. This provides a basis for understanding her seemingly inexplicable criminal behavior.

3. Genuine Shame and Consequences: Aille's assessment emphasizes Wang's genuine shame about her arrests, her ability to pay for the stolen items, and the potentially severe consequences on her hard-earned career. These factors counter the argument that Wang is faking her mental illness.

4. Relevance to Legal Standard: The diagnosed mental disorder, according to Aille, affected Wang's capacity to appreciate the wrongfulness of her actions or conform to legal requirements at the time of the offenses.

I strongly request the judge understand that Wang's mental state should absolve her of criminal responsibility. The case hinges on whether the court accepts the presented evidence of DID as a valid basis for an insanity defense. We request charges dropped, the defendant pay restitution, and treatment ordered. This will lead to restorative justice, as well as justice through Rehabilitation.