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JUDICIAL BRANCH
SUPERIOR COURT
Rockingham Superior Court Telephone: 1-855-212-1234
Rockingham Cty Courthouse/PO Box 1258 TTY/TDD Relay: (800) 735-2964
Kingston NH 03848-1258 http://www.courts.state.nh.us
Notice to Amy Anderson: If you do not comply with these requirements you will be considered in
default and the Court may issue orders that affect you without your input.
Send copies to:
Paul Maravelias 34 Mockingbird Hill Rd Windham NH 03087
Amy Anderson 2 Cardiff Rd Windham NH 03087
BY ORDER OF THE COURT
NOTICE TO DEFENDANT
Case Name: Paul Maravelias v Amy Anderson
Case Number: 218-2019-CV-00158
You have been served with a Complaint which serves as notice that this legal action has been filed
against you in the Rockingham Superior Court. Review the Complaint to see the basis for the
Plaintiff’s claim.
Each Defendant is required to electronically file an Appearance and Answer 30 days after service.
You may register and respond on any private or public computer. For your convenience, there is also
a computer available in the courthouse lobby.
If you are working with an attorney, they will guide you on the next steps. If you are going to
represent yourself in this action, go to the court’s website: www.courts.state.nh.us, select the
Electronic Services icon and then select the option for a self-represented party.
1. Complete the registration/log in process. Click Register and follow the prompts.
2. After you register, click Start Now. Select Rockingham Superior Court as the location.
3. Select “I am filing into an existing case”. Enter 218-2019-CV-00158 and click Next.
4. When you find the case, click on the link and follow the instructions on the screen. On the
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the instructions to complete your filing.
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A person who is filing or defending against a Civil Complaint will want to be familiar with the Rules of
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documents filed in your case.
If you have questions regarding this process, please contact the court at 1-855-212-1234.
NHJB-2678-Se (07/01/2018)
Filed
File Date: 2/4/2019 10:14 AM
Rockingham Superior Court
E-Filed Document
THE STATE OF NEW HAMPSHIRE
JUDICIAL BRANCH
http://www.courts.state.nh.us
1
Paul J. Maravelias
34 Mockingbird Hill Rd
2
Windham, NH 03087
Telephone: (603) 475-3305
3
paul@paulmarv.com
4
THE STATE OF NEW HAMPSHIRE
5
ROCKINGHAM, SS. SUPERIOR COURT
6
7
) Case No. Pending
8 ) 218-2019-CV-00158
)
9 )
PAUL MARAVELIAS, ) COMPLAINT
a natural person
10 )
Plaintiff, )
ORIGINAL VERIFIED
11 )
COMPLAINT FOR INJUNCTION,
v. ) DECLARATORY RELIEF, AND
12 ) COMPENSATORY DAMAGES
AMY ANDERSON, )
13 a natural person )
) JURY TRIAL DEMANDED
14 Defendant. )
)
) Date Action filed: 2/4/2019
15
)
16
17 I. PRELIMINARY STATEMENT
19 P with Complaint and brings this action without the benefit of counsel against the
20 individual Defendant Amy Anderson ( Defendant . This action seeks to protect and
24 interfere tortiously with a concurrent civil protective order case in the Circuit Court, unrelated
9
II. JURISDICTION AND VENUE
10
2. Subject matter jurisdiction exists pursuant to RSA 491:7.
11
3. The Court has personal jurisdiction over Defendant because Defendant
12
committed tortious acts in the State of New Hampshire and as all parties are residents of the
13
State of New Hampshire.
14
15 4. Venue is appropriate as all parties reside within Rockingham County in the State
16 of New Hampshire and Defendant has committed tortious acts entirely or substantially within
17 said county.
18 III. PARTIES
21
6. Defendant AMY ANDERSON is a natural person who, upon information and
22
belief, resides at 2 Cardiff Road, Windham, New Hampshire 03087.
23
24
12 series of explosive telephonic tirades against Paul Maravelias and his parents, culminating in
16 Maravelias exceeds the scope of this action. Plaintiff summarizes as follows. Christina
17 DePamphilis riddled her protective order petition with malicious falsity. An audio recording
18 and incidental cell-phone video have subsequently disproven two major allegations of her
20 him. Nonetheless, the Circuit Court granted the restraining order petition on 2/7/17.
21
12. Defendant Amy Anderson attended all three 2017 Hearings held on the
22
protective order petition the DePamphilis family filed against Maravelias.
23
24
17 the following language featuring Defendant Amy Anderson and falsely accusing Maravelias
18 of various bad-acts:
19
Harassment of Christina, Her Family, and Their Friends
20
21 Amy Anderson, a friend of the DePamphilis family, has attended all hearings in support of
Christina and David DePamphilis. The Andersons are the same family to whom
22 Maravelias sent a copy of the vile letter in March 2017 (see ¶2(a)) and a text message
disparaging David DePamphilis and falsely alleging that David was about to be removed
23 from his home by the Department of Health and Human Services for poor parenting. In an
act of apparent intimidation, on July 3, 2018, Maraveli
24
2
18. al 1/24/19 Motion to Extend included the
3
following language featuring Defendant Amy Anderson and falsely accusing Maravelias of
4
various bad-acts:
5
7
Amy Anderson, a friend of the DePamphilis family, has attended most of the hearings in
8 support of Christina and David DePamphilis. The Andersons are the same family to whom
Maravelias sent a copy of the vile letter in March 2017 (see ¶2(a)) and a text message
9 disparaging David DePamphilis and falsely alleging that David was about to be removed
from his home by the Department of Health and Human Services for poor parenting. In an
10
daughter and family while they were in the Dunkin Donuts in Windham. Learning that she
11 may be a witness in this matter, Maravelias recently sent a letter to Mrs. Anderson
concerning the incident at Dunkin Donuts, posing discovery questions to her, setting a
12
deadline for response, and threatening to file a defamation suit against her if she did not
comply with his deadline.
13
16 the window to respond to emails and compose a legal document on his laptop. Maravelias was
17 drafting his objection to most recent legal abuse motion against him.
18
20. The legal address of the Dunkin Donuts is now 1 Delahunty Rd due to recent
19
land development. The building, owned by Cafua Realty Trust Liv, LLC, has indoor security
20
cameras which, upon information and belief, are expected to have captured footage validating
21
all of Plaintiff s factual stipulations regarding the date 7/3/18 hereinafter.
22
21. At one time during his routine patronage of the local Dunkin Donuts on 7/3/18,
23
Maravelias
24
11 Microsoft Word on his laptop and continued writing his legal document.
12 26. At no times material did Maravelias ever effectuate any video or audio
14
27. he took no recordings
15
whatsoever on 7/3/18, and 2) he was present at the Dunkin Donuts from 4:10pm EDT
16
6:11pm EDT on 7/3/18.
17
28. At all times material, Defendant Amy Anderson and her family members had
18
clear view of seated Maravelias and were able to observe that he was never operating any
19
videocamera, smartphone camera, and/or any other device to record them.
20
29. stay at the Dunkin Donuts on 7/3/18 was any
21
DePamphilis actor present, nor their attorney, Simon R. Brown, Esq., nor anyone who was in
22
communicational privy to the DePamphilis family, other than Defendant and her family.
23
24
10 This is a private communicate between you and me. I have not contacted you since I
asked for your help back in, if I remember correctly, April 2017. I believed my continued
11 righteous actions over time would speak louder than any words.
I am writing to offer a good-faith attempt at procuring some responses from you which
12
-intentions in people. I am slow to
judge, and I do not jump to conclusions without having my facts straight.
13
Y
14 defamatory legal attack against me and my rights. This exciting new attack becomes moot if
the Supreme Court rules favorably on my appeal in the coming weeks or days.
15
You were me
16
the Dunk
17
I am sorry they have brought you into their insecure attacks on me. Clearly the attacks
have been adopting an ever-worsening bizarre, deranged nature. Having a donut/coffee
18 peacefully to myself and working through emails is reminiscent of my other terrible
my abusers have dishonestly
19 contorted your true words or invented statements you never said. At this point, I have no
reason to believe you have circulated a false accusation now causing legal ramifications for
20 me.
4
I am sympathetic to you for what must be a stressful dilemma: the undeniable facts of
5 the perjurious legal abuse, and the subjective factors of your years-long friendship to the
now-criminals.
6
I have borne no animosity neither towards you nor your family. I was disappointed in
May and June that you either did not attend or were not invited to the embarrassing and
7 thoroughly backfired spectacle of the 2018 DePamphilis attack on me, where I masterfully
exposed the truth of the case in court. Unsurprisingly, my abusers came alone all three days.
8 That is on YouTube.
9 If you choose to respond, please inform me of your answers to the questions by email or
text message. I hope you can enlighten me. I presently perceive you as someone with
10 sympathies for my abusers, but as a rational and ethical adult, who obviously perceives the
injustice and shameful deception of their attacks on me, like everyone else does by now. If
11 you choose not to respond, I would sadly have to assume you yourself have spread the false
7/3/18 accusation which now injures me.
12 Without your answers, the DD security footage will be necessary. I would likely be
unable to obtain it absent a court-ordered discovery request inside a civil case. My chances
13 are slim-to-none of getting that from the incompetent joke-of-a-court in Derry within the
existing case. So, unfortunately, I would have to initiate a defamation action against you in
14 Superior Court to get it. That would be the worst- ond and all
else fails with my discovery work regarding this new 7/3/18 false accusation. In such event, I
15 would pursue declaratory/injunctive relief only, and not seek any damages, even if
16
I unfortunately also must give you a deadline, 1/27/19, after which I will consider your
non-
17
court will need to schedule a hearing within 30 days and because I think
the effort I have taken in
18 this letter not to approach you with a formal demanding legal tone. I have confidence in your
ability to help me discover the truth in this legal matter now prolonged by the entertaining
19 liars.
20 Kind Regards,
21 Paul J. Maravelias
34 Mockingbird Hill Rd
22 Windham, NH 03087
paul@paulmarv.com
(603) 475-3305
23
24
5
restraining order. Did you attend any of these? If so, which ones?
6
2. Did you see me at Dunkin Donuts in Windham on July 3 rd, 2018?
7
3. Did you see me recording anybody? If so, what was I using to make the
recording?
8
4. Did I notice you when you were in your car?
9
20 13. Is there anything else you would like to say in connection to the above
questions?
21
22
23
32. Defendant never responded to Maravelias.
24
20 36. On 1/24/19,
21 Extend the restraining order against Maravelias the same day it was filed
22 .
23 37. The Circuit Court granted the extension because of the content of said motion
24 and the allegations stipulated therein, including Defendant s false and defamatory statements.
12 d.
e. The legal process of fighting the false restraining order is enormously costly and
13
time-consumptive for Maravelias, an impecunious pro se defendant therein.
14 f. Maravelias lives in constant fear of further legal harassment and must make
significant changes to his daily life to prepare for and fend-off false accusations.
15
The DePamphilis family has made numerous false reports to the police that
16 Maravelias has violated the restraining order, causing Maravelias to endure
costly and stressful interactions with the police.
17 been frivolous and baseless; accordingly, Maravelias has never been convicted
of violating the restraining order. In December 2017, Maravelias was falsely
18 arrested when maliciously alleged to have violated the restraining order. The
charges were dropped and the false arrest was annulled, after Maravelias spent
19
three days in jail awaiting arraignment.
20 g. The restraining order, though constitutionally invalid, facially asserts Orwellian
-amendment-protected speech conduct and
21 causes him to fear expressing himself in public.
22 h. The restraining order causes extreme emotional and psychological suffering for
Maravelias as it wrongly damages his reputation and casts him in a false light.
23
24
4
V. CAUSES OF ACTION
5
COUNT 1: DEFAMATION
6 RSA 644:11
7
41. Paragraphs 1 through 40 are incorporated by reference and repeated herein as
8
though fully set forth.
9
42. Defendant made certain statements to third parties about Paul Maravelias s
10
alleged conduct at Dunkin Donuts on 7/3/18. To wit, Defendant communicated that Plaintiff
11
recorded her daughter and family in an act of intimidation and harassment on 7/3/18
12
at Dunkin Donuts.
13
43. The said statements were false and defamatory.
14
15 44. The said defamatory statements were made without any valid privilege.
17
46. The said defamatory statements were made about and concerning the Plaintiff.
18
47. Defendant acted maliciously and tortiously, wantonly and outrageously, outside
19
the boundaries of decency and in a manner shocking to the conscience, with reckless
20
disregard for the truth and while purposefully knowing the falsity of her statements.
21
48. Defendant acted with actual malice. When given an opportunity to recant or
22
clarify her false representations, Defendant instead communicated Maravelias s private letter
23
24
9 51. Defendant committed this tortious act a second time, persisting in her
10 defamatory conduct, after receiving Maravelias s private 1/15/19 letter, whereupon she took
11 no action to cure her defamatory conduct but in fact conspired with the DePamphilis actors to
15 were caused to have lower esteem for the Plaintiff as a result of said statements.
16
53. As a direct and proximate result of Defendant Amy Anderson s tortious conduct,
17
Paul Maravelias has suffered actual damages and is entitled to a money judgment against
18
Defendant in an amount within the jurisdictional limits of this court to be determined upon the
19
trial of this action but presently believed to be in excess of $15,000.
20
COUNT 2: DEFAMATION PER SE
21
54. Paragraphs 1 through 40 are incorporated by reference and repeated herein as
22
though fully set forth.
23
24
3
Chagnon v. Union Leader Co., 103 N.H. 426, 441 (1961), cert. denied, 369 U.S. 830 (1962).
4
56. However, when defamatory statements allege acts unlawful or suggestive of
5
moral turpitude, they constitute defamation per se and authorize the award of generic
6
damages without requiring the plaintiff to show specific harm. the defamatory
7
publication charged the plaintiff with a crime or with activities which would tend to injure
8
him in his trade or business, commonly called libel per se, he can recover as general damages
9
all damages which would normally result from such a defamation, such as harm to his
10
Id. See Lassonde v. Stanton, 157 N.H. 582, 592-
11
Chagnon, supra, at 441; See Lassonde, 157 N.H. at 593.
12
57. Defendant communicated false and defamatory statements about Maravelias
13
accusing him of unlawful and/or morally turpitudinous conduct.
14
15 58. Defendant s defamatory statements to the authors of the 1/11/19 and 1/24/19
16 Motions to Extend included the allegation that Maravelias harassed and intimidated
21
60. Defendant knew the content and wording of DePamphilis s Motion to Extend
22
and intentionally collaborated with DePamphilis to extend a stalking restraining order
23
against Maravelias by and through her defamatory conduct.
24
9
66. The third parties to whom Defendant communicated defamatory statements
10
were caused to have lower esteem for the Plaintiff as a result of said statements.
11
67. Defendant s defamatory statements against Maravelias were of an intent nature
12
to bring Maravelias into hatred, contempt, or ridicule and cause him to be shunned or avoided,
13
to injure his good name, credit, and reputation, and cause him to suffer great mental anguish
14
and personal and public humiliation.
15
68. Defendant acted maliciously and tortiously, wantonly and outrageously, outside
16
the boundaries of decency and in a manner shocking to the conscience, with reckless
17
disregard for the truth and while purposefully knowing the falsity of her statements.
18
19 69. As a direct and proximate result of Defendant Amy Anderson s tortious conduct,
20 Paul Maravelias has suffered actual damages and is entitled to a money judgment against
21 Defendant in an amount within the jurisdictional limits of this court to be determined upon the
23
24
5 71. False Light is a common-law tort. The New Hampshire Supreme Court has not
6 yet affirmatively recognized it, but has only addressed the tort in dicta; See Hamberger v.
7 Eastman, 106 N.H. 107 (1964), noting four distinct torts comprising the broad invasion of
8 privacy tort law: (1) intrusion upon the plaintiff's physical and mental solitude or seclusion;
9 (2) public disclosure of private facts; (3) publicity which places the plaintiff in a false light in
10 the public eye; and (4) appropriation, for the defendant's benefit or advantage, of the plaintiff's
11 name or likeness.
12
72. The Second Restatement of Torts, Section 652E assigns liability for false light
13
invasion of privacy when one gives publicity to a matter concerning another that places the
14
other before the public in a false light if (a) the false light in which the other was placed
15
would be highly offensive to a reasonable person, and (b) the actor had knowledge of or
16
acted in reckless disregard as to the falsity of the publicized matter and the false light in which
17
the other would be placed. See Young v. Plymouth State Coll., 1999 WL 813887, (D.N.H.
18
Sept. 21, 1999) (New Hampshire federal district court applying the elements of the tort as
19
provided in the Second Restatement). The publicity element of the tort is satisfied if one
20
makes
21
the matter must be regarded as substantially certain to become one of
22
Restatement (Second) of Torts § 652D (1977). See e.g. Robinson v. Caronia Corp., (D.N.H.
23
Jan. 4, 1996).
24
12 76. Defendant knew the falsity of the light in which she cast Maravelias and/or
14 77. At all times material, Defendant knew the DePamphilis restraining order
15 litigation against Maravelias is a highly publicized matter and that Maravelias habitually posts
16 the legal documents of said case, from both sides thereof, on his website, for the public s
17 inspection.
18
78. Furthermore or in the alternative, Defendant committed the four invasion of
19
privacy common law torts pursuant to the Supreme Court s rehearsals in Hamberger, supra.
20
79. Defendant intruded upon the mental solitude and/or seclusion of Maravelias
21
while he was peacefully sipping coffee at Dunkin Donuts and publicly disclosed statements
22
about his behavior which amounted to the disclosure of private facts.
23
24
13 83. The New Hampshire Supreme Court has affirmatively recognized the common-
14 law tort of intentional infliction of emotional damage. Such a claim must allege 1) a defendant
15 acted intentionally or recklessly, 2) their conduct was extreme and outrageous, and (3) as a
16 result, defendant caused the plaintiff severe emotional distress. See Morancy v. Morancy, 134
18
84. Defendant intentionally and/or recklessly circulated false representations about
19
Maravelias for the purpose of causing severe distress, pain, and anguish to Maravelias.
20
85. Defendant intentionally and/or recklessly endeavored to inject her defamatory
21
statements about Maravelias into DePamphilis s public 1/11/19 Motion to Extend the
22
restraining order for the purpose of causing severe distress, pain, and anguish to Maravelias.
23
24
14 89. By cause of and as a direct and proximate result of the foregoing tortious
16 90. Defendant s conduct was extreme and outrageous, willful, wanton and
17 malicious, and for the sole purpose of causing severe distress, pain, and anguish to Maravelias
19
91. As a direct and proximate result of Defendant Amy Anderson s tortious conduct,
20
Paul Maravelias has suffered actual damages and is entitled to a money judgment against
21
Defendant in an amount within the jurisdictional limits of this court to be determined upon the
22
trial of this action but presently believed to be in excess of $15,000.
23
24
7 94. Plaintiff Maravelias is entitled to a declaratory judgment that he did not, in fact,
9 95. Declaratory relief is urgent and necessary as Plaintiff s constitutional rights are
10 presently wrongfully restricted due to the extended restraining order and because Defendant s
11 allegations are material to an upcoming Circuit Court hearing on the restraining order where
12 Defendant is not a party. Maravelias therefore has limited discovery rights pertaining to
14
96. Plaintiff is without adequate alternate remedy at law.
15
EQUITABLE INJUNCTIVE RELIEF
16
97. Paragraphs 1 through 40 are incorporated by reference and repeated herein as
17
though fully set forth.
18
19 98. Plaintiff does not have an adequate remedy at law entitling him to an injunction
20 enjoining Defendant from communicating false statements about Maravelias s conduct around
21 her daughter and family on 7/3/18 which she knows to be false or which she communicates
23
24
6
WHEREFORE, Plaintiff Paul Maravelias respectfully requests this Honorable Court:
7
I. Enter a money judgment against Defendant on all Counts of Action for
8 general, compensatory, and enhanced compensatory damages in an amount
within the jurisdictional limits of this court to be determined upon the trial
9
of this action but presently believed to be in excess of $15,000;
10
II. Award Plaintiff the reasonable costs and disbursements of this action;
11
III. Enter declaratory judgment determining that Paul Maravelias never
12 recorded , intimidated , or harassed Defendant s daughter or family
on 7/3/18;
13
IV. Grant an injunction against Defendant Amy Anderson restraining her from:
14
20
21
22
23
24
4
PAUL J. MARAVELIAS,
5
in propria persona
6
10
11
/s/ Paul J. Maravelias Dated: February 4th, 2019
12
Paul J. Maravelias
34 Mockingbird Hill Rd
13
Windham, NH 03087
paul@paulmarv.com
14
603-475-3305
15
16
17
18
19
20
21
22
23
24
Select One:
As Counsel for:
WITHDRAWAL
As Counsel for
Type of Representation: (Select one)
Appearance:
Notice of withdrawal was sent to my client(s) on: at the following address:
OR
For e-filed cases:
✔ I state that on this date I am sending a copy of this document as required by the rules of the court. I am
electronically sending this document through the court’s electronic filing system to all attorneys and to all other
parties who have entered electronic service contacts (email addresses) in this case. I am mailing or hand-
delivering copies to all other interested parties.
218-2019-CV-00158
THE PLAINTIFF INTENDS TO ATTACH YOUR PROPERTY, AS SET FORTH IN THE ABOVE
MOTION FOR PERMISSION TO DO SO, TO SECURE ANY JUDGMENT OR DECREE THE
PLAINTIFF MAY OBTAIN IN THIS ACTION. YOU HAVE THE RIGHT TO OBJECT TO THE
ATTACHMENT, AND TO HAVE A HEARING AS TO WHETHER IT SHOULD BE MADE. IF YOU DO
WISH TO OBJECT AND HAVE A HEARING, YOU SHOULD FILE A WRITTEN OBJECTION
DETAILING THE REASONS THEREFOR, TOGETHER WITH A REQUEST FOR A HEARING, WITH
THE CLERK OF COURT NOT LATER THAN 30 DAYS AFTER YOU HAVE BEEN SERVED WITH
THE MOTION TO ATTACH.
IF YOU FAIL TO OBJECT BY THAT DATE, YOU WILL BE DEEMED TO HAVE WAIVED ANY
OBJECTION.
IF YOU TRANSFER ANY PROPERTY AFTER RECEIVING THIS NOTICE, AND BEFORE THE
ATTACHMENT, IF ALLOWED, IS MADE, YOU WILL BE SUBJECT TO THE PROVISIONS OF RSA
511-A: 6.
EVEN IF YOU DO NOT OBJECT TO THE ATTACHMENT, YOU SHOULD FILE AN APPEARANCE
AND ANSWER WITH THE CLERK OF COURT BY 30 DAYS AFTER YOU HAVE BEEN SERVED
UNLESS YOU ARE WILLING THAT THE PLAINTIFF HAVE JUDGMENT BY DEFAULT.
The Plaintiff is granted permission to make the above attachment(s) within days.