Konoski's court papers say he will offer evidence of Tarloff's "lack of criminal responsibility by reason of mental disease or defect." They also say Tarloff suffered from paranoid schizophrenia, depression, intrusive delusional thoughts of God and Satan, belief he is the Messiah and other mental disorders.
His imagined visions include "ghosts," "flakes" from the sky as a sign of God, feeling and seeing the word "Satan" in his mind, seeing images of God and Jesus on walls, and seeing the "eye of God" on the kitchen floor, the papers say.
Tarloff also hears God and the Devil talk to him, and he hears God respond when he prays, the court papers say.
The papers also mention two instances of sexual abuse as recalled by Tarloff - one by his grandmother and the other by a stranger who fondled him.
Konoski said he also filed notice of an "extreme emotional disturbance" defense "as a fallback." He said the difference is that an insane person does not know what he is doing is wrong, while one who is extremely disturbed emotionally knows what he is doing is wrong but can't control himself at that time.
Tarloff, who told police he has been in mental institutions at least 20 times, is charged with first- and second-degree murder in the death of Kathryn Faughey, 56, in her Upper East Side office on Feb. 12.
Tarloff is also charged with attempted murder and first-degree assault in the cleaver attack on Dr. Kent Shinbach, 70, who was hurt when he tried to help Faughey. Shinbach, whose office was near Faughey's, was Tarloff's therapist.
Tarloff told police he intended to rob Shinbach so he could get money to remove his mother from a nursing home and take her to Hawaii, but Faughey stepped in and he attacked her. He said he then attacked Shinbach.
Konoski said "the evidence is clear that he (Tarloff) did it, but the reasons he did it, what was behind it, are so crazy that we believe we have a very strong insanity defense."
"He was having visual and auditory hallucinations, communications with God telling him how to act," Konoski said. "He believed through prayer that God had approved what he was going to do at Dr. Shinbach's office to save his mother."
The lawyer said Tarloff, who is being held in the psychiatric ward at Bellevue Hospital, was examined there by his psychiatrist for eight to 10 hours on Feb. 27 and four to five hours on March 28.
