Phil Astin has pleaded not guilty to federal charges of improperly prescribing painkillers and other drugs to two patients other than Benoit, the professional wrestler who killed his family and himself in June. More federal charges against Astin are expected.

Attorney Manny Arora said in a motion in U.S. District Court in Atlanta that since being placed under house arrest, Astin has been unable to work and foreclosure notices and other liens have been placed on his real estate.

"Astin has become and is currently indigent," Arora wrote.

Arora said the cost of defending Astin would be expensive, running into the tens of thousands of dollars for copying medical documents alone.

There was no immediate ruling by the court.

Prosecutors have said Benoit, 40, strangled his wife with a cord, used a choke hold to strangle his 7-year-old son, placed Bibles next to the bodies and hanged himself on a piece of exercise equipment.

Authorities have said Astin prescribed a 10-month supply of anabolic steroids to Benoit every three to four weeks between May 2006 and May 2007.

Steroid use has lingered as a theory behind the killings, since anabolic steroids were found in Benoit's home and tests conducted by authorities showed Benoit had roughly 10 times the normal level of testosterone in his system when he died.

Some experts believe that use of testosterone can contribute to paranoia, depression and violent outbursts known as "roid rage."