Maureen Mahoney says in an emergency motion filed Wednesday in Denver federal court that Nacchio isn't dangerous and won't flee.

Mahoney says she's moving swiftly to seek a Supreme Court review of his case and that the appeal will raise a significant question for the high court to review.

Nacchio was convicted in 2007 on 19 counts of insider trading and sentenced to six years in prison. A three-judge panel of the 10th U.S. Circuit Court of Appeals reversed the conviction, but the full appeals court later reinstated it.

A judge has since ordered him to report to prison by noon March 23.