Nacchio was ordered to report on March 23 to a minimum security prison in Pennsylvania after his conviction on 19 counts of insider trading was reinstated by a federal appeals court last week.

In their motion, Nacchio's lawyers said new testimony from ex-Chief Financial Officer Robin Szeliga came to light in a deposition in a Securities and Exchange Commission lawsuit now pending against Nacchio and other former Qwest executives.

In her deposition, Szeliga testified that the she had advised Nacchio of a smaller risk of Qwest missing its year-end revenue targets for 2001 than the risk that prosecutors had presented to the Colorado federal jury that convicted him.

The same evidence was presented to a three-judge panel of 10th U.S. Circuit Court of Appeals, which overturned Nacchio's conviction on different grounds last year.

The full 10th Circuit court reinstated the conviction and six-year prison term.

Nacchio's attorneys said the 10th Circuit panel had considered the magnitude of risk presented by prosecutors to be "barely sufficient" to uphold his conviction.

"It is not in the interests of justice to send an innocent man to prison," Nacchio's lawyers wrote in the motion, filed late on Thursday, in Denver federal court.

Nacchio was convicted of selling $52 million in Qwest stock in 2001 before investors learned that the telecommunications company, which serves 14 mostly Western states, would miss its financial forecasts.

Qwest shares subsequently plummeted when the company restated $2.2 billion in revenue for 2000 and 2001.

(Reporting by Keith Coffman in Denver and Gina Keating in Los Angeles; Editing by Lincoln Feast)