Convicted murderer Joe O'Reilly has lodged 11 grounds of appeal against his conviction for the murder of his wife Rachel at their home in The Naul, Co Dublin.
He is claiming the trial was unsatisfactory and his conviction is unsafe.
It is believed O'Reilly will contend the evidence against him was insufficient to allow any more than a suspicion of guilt on his part and that the trial judge should, in those circumstances, have directed the jury to enter a not guilty verdict.
An appeal date has yet to be set but it is unlikely it will be heard before the new year. An application for a date may be made next month when the Court of Criminal Appeal will fix hearing dates for appeals.
O'Reilly (35), Baldarragh, The Naul, was convicted unanimously by a jury at the Central Criminal Court last July of the murder of his wife in October 2004. The couple had two children. O'Reilly had denied murder.
He was jailed for life by Mr Justice Barry White. He lodged an appeal against conviction and sentence in August last.
O'Reilly's grounds of appeal were lodged with the Court of Criminal Appeal this week and are believed to include arguments that evidence of mobile phone records and data relating to the location of his mobile phone on the date of his wife's murder should not have been permitted by the trial judge to go before the jury.
It is believed O'Reilly will also claim there was no evidence before the court that O2 Ireland was a licensed phone operator under the terms of the Postal and Telecommunications Service Act 1999 and that therefore the phone evidence was not legally before the jury.
O'Reilly is also believed to be contending that oral and written statements made by him to gardaí were made in circumstances which breached his rights, including rights to basic fair procedures.
He is also claiming, it is believed, that the trial judge should not have allowed evidence of interviews with him while in Garda custody to go before the jury in a manner where it was clear to the jury he had remained silent for most of the time he was being interviewed.
It is understood he will contend that an oral statement by him to gardaí on the day of the murder should have been excluded because at that time he was not cautioned and was likely to be a suspect. A further ground, it is believed, involves an argument that a witness statement by him should also have been excluded because he actually was at that stage a suspect.
Other grounds are understood to include claims that an analysis of CCTV footage about movements of cars on the date of the murder should not have been allowed to be put before the jury.
It is understood O'Reilly will claim that evidence from image analyst Andrew Laws relating to that CCTV footage was inadmissible and was also flawed because it only involved comparisons with a Fiat Marea car, the type of car driven by O'Reilly, and no other car.
O'Reilly is also arguing that the jury should not have heard evidence that he had spent the night with Nikki Pelley after a Late Late Show appearance with his wife's family concerning her murder.
It is understood it will also be argued that evidence about e-mails from a computer alleged by the prosecution to be O'Reilly's should have been excluded because their evidential value was outweighed by their prejudicial value.
The body of Rachel O'Reilly was found by her mother, Rose Callaly, in the bedroom of her home on October 4th, 2004. She had received several blows to the head from a blunt instrument.
