The doctor convicted of involuntary manslaughter over the death of Michael Jackson has asked to be released from jail pending his appeal.
Dr Conrad Murray, who is serving a four-year sentence, said he should be freed on his own recognisance or on bail with electronic monitoring.
He said he is not a danger to society, will not run off and wants to work to help support his seven children.
His lawyer, J Michael Flanagan, said in a motion Dr Murray knows he cannot work as a physician but would find other employment.
He suggested the sentence and his treatment in prison are extremely harsh for a man with no prior criminal record.
He said Dr Murray is being held in solitary confinement and is chained to a table when he meets his lawyers. He added he deeply sorry for Jackson's death.
The pop legend died in June 2009 from an overdose of the anaesthetic propofol administered by Dr Murray.
Mr Flanagan admitted his client had made some errors of judgement but said he never intended to harm his patient.
Dr Murray's appeal has not yet been filed but the motion gives an insight into some of the issues that will be raised.
These include a claim that Superior Court Judge Michael Pastor should have allowed testimony about Jackson's financial condition.
Mr Flanagan said the exclusion of that evidence "seriously compromised the defendant's ability to demonstrate the desperate situation which was guiding the decisions and choices of both Mr Jackson and Dr Murray".
"Mr Jackson was an uncooperative patient who made decisions and demands based upon his particular needs, one of which was his extremely precarious financial situation complicated by drug addiction."
Mr Flanagan added it would be unfair to keep Dr Murray in jail while his appeal is being heard as the whole process could take more than a year.
An appeal hearing has been set for February 24.