Curtis Bonnell is appealing his first-degree murder conviction in the 2009 death of his teenaged cousin, Hilary Bonnell.
The 32-year-old man from Esgenoopetitj First Nation lists nine reasons why he should be granted an appeal in a hand-written notice, filed with the Court of Appeal in Fredericton on Nov. 30.
Bonnell contends he should have been granted a change of venue for his trial, which was held at the Miramichi Court of Queen's Bench.
He also argues the judge should not have admitted his statements to police because officers violated his charter rights by questioning him when he was "not in condition to understand what was going on" and by not taking him to court within 24 hours of his arrest.
Bonnell also claims the trial judge made errors in giving his charge to the jury. Justice Fred Ferguson "should not have included first-degree murder in his charge … there was no evidence to support it," the document states.
Bonnell wants to present his case in writing and in person, according to his application.
He is serving an automatic life sentence with no chance of parole for 25 years for the first-degree murder conviction.
A jury found him guilty on Nov. 3, following a seven-week trial.
The Crown alleged Bonnell picked up his 16-year-old cousin Hilary the morning of Sept. 5, 2009, as she was walking along Micmac Road in the Esgenoopetitj First Nation after a party. Bonnell was accused of holding Hilary against her will, sexually assaulting her and killing her.
During the trial, the jury had watched a police video of Bonnell admitting to RCMP that he had killed Hilary in his backyard after they had sex, but his defence lawyered argued the confession was given under pressure from police.
Bonnell also led police to Hilary's body, which was buried in a remote wooded area near Tabusintac, the jury heard.
Bonnell has been in custody since November 2009.