WEST PALM BEACH, Fla. (WJHL) – Defense attorneys for a Southwest Virginia woman accused of killing a woman in Florida in 1990 while dressed as a clown are asking a bond be set for her ahead of her trial.

According to a motion filed in Palm Beach County court Monday, defense attorneys for Sheila Keen-Warren, the former owner of the Purple Cow restaurant in Kingsport, are asking that a bond be set so she may be released from jail before her trial begins.

“There is no reliable physical or testimonial evidence that she committed this crime, yet Ms. Keen-Warren has been incarcerated without a bond since October 4, 2017,” the motion reads. “Any continued restrictions on her liberty are both punitive and a violation of the presumption of innocence.”

The motion includes transcriptions of eyewitness accounts to investigators, three of whom said they believed the killer clown in question to be a tall, skinny man.

Court documents also reference the accounts of two Publix employees who worked near the scene of the 1990 shooting. Both said that a woman had purchased flowers and balloons “similar” to the flowers found at the scene.

The motion notes that neither Publix employee was able to identify the woman they described when placed in front of a photo line-up that included Keen-Warren.

However, the motion also mentions the owner of a costume shop in West Palm Beach who told investigators that two of her employees had sold a woman a clown costume two days before Marlene Warren was shot.

Both employees were shown multiple photo line-ups that included Keen-Warren, but were unable to say with complete certainty that she was the woman who had bought the costume, according to the motion.

The motion calls attention to the recovery of the car used in the murder and also to the fact that the case had gone through several sets of detectives over the years before Keen-Warren was arrested.

In 2017, Keen-Warren was charged with first-degree murder in the death of her husband’s then-wife, Marlene Warren, in Florida.

Keen-Warren and Michael Warren were married a decade after Marlene was killed. They lived in Abingdon, Virginia when Keen-Warren was extradited to Florida on the murder charge.

Keen-Warren has been incarcerated in Florida since her 2017 arrest.

Keen-Warren’s defense argues that under the Florida Constitution, “unless charged with a capital offense or an offense punishable by life imprisonment and the proof of guilt is evident or the presumption is great, every person charged with a crime . . . shall be entitled to pretrial release on reasonable conditions.”

The motion asks that even if the state finds that the burden of proof required to hold Keen-Warren is met, she should be granted bond in order to fulfill the purpose of bail by other means.

“In this case, the proof is not evident, and the presumption is not great,” the motion reads.

“She is neither a danger to the community nor a flight risk,” the defense writes. “Sheila Keen-Warren is an innocent woman. Considering her ties to the community, her lack of criminal history and the lack of any reliable evidence implicating her in this offense, this court should release Ms. Keen-Warren on a reasonable monetary bond.”

Her attorneys ask that the court set a bond of $50,000 or place her on Palm Beach Sheriff’s Office in-house arrest.

You can read the full motion filed in court below: