The defence team for WikiLeaks suspect Bradley Manning is intending to demonstrate at this month's military hearing that numerous warning bells were sounded about the US soldier's fragile emotional and mental stability before his arrest in May 2010 – but were consistently ignored by superiors.

David Coombs, the lawyer representing Manning in his Article 32 pre-trial proceedings that open at Ford Meade in Maryland on 16 December, has presented a list of 48 people he wants to call to give evidence in Manning's defence and mitigation. Manning has been charged with 36 counts relating to the transfer of state secrets from confidential databases in Iraq to the whistleblowing website WikiLeaks, charges that carry a maximum sentence of life in military custody.

Coombs has published details of the 48 individuals, though their names have been withheld in the heavily redacted document. They include military officers, computer experts, psychologists and FBI agents, as well as an unnamed individual who is clearly President Obama and another who is evidently the secretary of state Hillary Clinton.

In the document, Coombs paints a picture of Manning as a disturbed and lonely person as he worked as an intelligence analyst in Iraq. A psychiatrist who evaluated Manning shortly before his arrest will testify that he had concluded Manning was "at risk to himself and others" and that he should be banned from carrying a useable weapon.

Another potential witness, a psychologist, had seen Manning five months before his arrest, and found that he was "under a considerable amount of stress" and was "hypersensitive to criticism". The psychologist recommended that Manning be taken off the night shift and put on low-intensity duties.

Other witnesses will testify, Coombs writes, that Manning was struggling with being gay under the 'don't ask, don't tell' policy that existed at the time he was serving in Iraq. A fellow soldier will testify that "he was having gender identify (sic) issues" and that he was being teased by other soldiers over his sexuality and his short stature.

Several witnesses are set be used to cast light on Manning's erratic behaviour in the run-up to his arrest. Manning displayed "extreme emotional issues": he was once found curled up in a foetal position in a meeting room, rocking himself back and forth.

An army supervisor will give evidence that in December 2009 Manning had an angry outburst during a counselling session in which he flipped over a table and had to be restrained after he stepped towards a rack of weapons.

Despite all the warnings, Manning's deeply troubled state of mind, which was first revealed in a Guardian documentary, appears to have gone unnoticed and unacted upon by military commanders at Forward Operating Base Hammer, where Manning was stationed. Coombs writes that several witnesses will testify that warnings were not passed up the chain of command, and that Manning was allowed to retain access to confidential databases.

A potential witness asked that Manning be removed from his intelligence post, but found that his issues were not taken seriously "and no one took any steps to help him, or even recognise that he needed help".

It is not clear how many of the 48 individuals listed will be present at the hearing. Coombs notes that several of the individuals have so far refused to be interviewed by him ahead of the proceedings.

Obama is included on the defence list in order to raise the issue of "unlawful command influence". Coombs contends that the president exerted improper sway on the prosecution of Manning by making comments about him at a fundraising event in April in which he said Manning "broke the law".

Clinton is listed as someone who would testify that the publishing of hundreds of thousands of WikiLeaks embassy cables through papers that included the Guardian was not as damaging to US national security as some had suggested. The trove of secrets had been embarrassing for the US government, but "they did not represent significant consequences to foreign policy," she said.