Los Angeles, California (CNN) -- Dr. Conrad Murray is "hanging on by a thread" financially and could not afford to defend himself against charges in Michael Jackson's death if he loses his medical license, according to his lawyer.
"His ability to pay for his own defense depends almost entirely on his ability to continue to treat patients in Nevada and Texas," defense attorney Ed Chernoff said in a court filing Thursday.
The California Medical Board will ask a judge Monday to bar Murray -- formerly Jackson's doctor -- from seeing patients in California as a condition of his bail.
When Murray pleaded not guilty to involuntary manslaughter in February, Los Angeles County Judge Keith Schwartz ordered him not to use any anesthesia on patients, as a condition of his $75,000 bail. The judge refused a prosecution request to suspend his medical license.
The Los Angeles coroner concluded Jackson died of "acute propofol intoxication."
Murray told investigators he gave Jackson propofol, a powerful anesthetic, to help him sleep.
California Attorney General Jerry Brown filed a document last week arguing that Murray's treatment of Jackson "demonstrated a serious lack of judgment that should prohibit him from practicing medicine."
Murray's lawyer argued the state is trying to "take another bite at the apple" since the case has been moved to a different judge. They must show "changed circumstances" since bail was first set at the arraignment on February 8, Chernoff said in the filing.
"It cannot be based on a conclusion by the subsequent judge that the first judge simply got it wrong," Chernoff said.
Murray resumed his medical practice in Texas and Nevada last fall, but hasn't had a California patient since Jackson's June 25, 2009 death, Chernoff said.
"As a practical matter, an order that prohibits Defendant from practicing medicine in California will have no effect on the citizens of California," the filing said.
"The order would be a shallow one, designed only to prove a point rather than make a difference," Chernoff said in the filing.
The suspension of his California license, however, would have a "domino effect" on his practices in other states, he said.
"If his Honor restricts his California license even temporarily, then by application of Texas law, Dr. Murray's Texas license to practice medicine shall also be similarly revoked," he said.
The loss of his practices in Las Vegas, Nevada, and Houston, Texas, "would be financially and personally devastating," he said.
"He will likely be faced with the inability to adequately defend himself of the charges facing him in the Superior Court of California."
Murray's defense "will be scientifically based" and requires "intensive attorney work and fees," he said.
"Dr. Murray's financial difficulties as a result of the investigation into this case have already been well publicized," Chernoff said. "He is, without fear of overstatement, hanging on by a thread."
Chernoff also made an argument similar to one successfully used by lawyers for the doctors charged in actress Anna Nicole Smith's death. The judge refused last year to suspend their medical licenses, ruling the medical board should use its own authority to do so.
Attorney General Brown "wants this court to take away defendant's medical license so that the medical board does not have to go through the trouble," Chernoff said.
The constitutions of California and the United States "require due process and at a minimum this means a hearing before an impartial forum."