Bernard Madoff’s lawyers will have a tough time convincing the U.S. Court of Appeals for the Second Circuit to order their client released on bail until he is sentenced June 16, because the standards for post-conviction release are high and hard to meet.

Ira Sorkin and Daniel Horwitz of Dickstein Shapiro filed papers in the circuit Friday arguing that Southern District Judge Denny Chin should not have revoked Mr. Madoff’s bail on Thursday, which sent him off to the Metropolitan Correctional Center following his guilty plea.