In an urgent filing to the Hague-based court today, British lawyer John Jones is asking appeals judges to reject Libya's request to suspend an order that Tripoli surrender Seif al-Islam to the court.
Libyan authorities are appealing the international court's right to try Gadhafi's one-time heir apparent, saying that he should face justice at home.
Jones says that Seif al-Islam could be executed in Libya before the appeal is completed if he is not handed over to the court.