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THE STATE OF NEW HAMPSHIRE

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

SUMMONS IN A CIVIL ACTION

Case Name: Paul Maravelias v Amy Anderson


Case Number: 218-2019-CV-00158

Date Complaint Filed: February 04, 2019


A Complaint has been filed against Amy Anderson in this Court. A copy of the Complaint is attached.

The Court ORDERS that ON OR BEFORE:


March 23, 2019 Paul Maravelias shall have this Summons and the attached Complaint
served upon Amy Anderson by in hand or by leaving a copy at his/her
abode, or by such other service as is allowed by law.
April 13, 2019 Paul Maravelias shall electronically file the return(s) of service with this
Court. Failure to do so may result in this action being dismissed without
further notice.
30 days after Defendant Amy Anderson must electronically file an Appearance and Answer or other
is served responsive pleading form with this Court. A copy of the Appearance and
Answer or other responsive pleading must be sent electronically to the
party/parties listed below.

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

February 06, 2019 Maureen F. O'Neil


Clerk of Court
(126564)

NHJB-2678-Se (07/01/2018) This is a Service Document For Case: 218-2019-CV-00158


Rockingham Superior Court
2/6/2019 2:27 PM
THE STATE OF NEW HAMPSHIRE
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 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
“What would you like to file?” screen, select “File a Response to Civil Complaint”. Follow
the instructions to complete your filing.
5. Review your Response before submitting it to the court.

IMPORTANT: After receiving your response and other filings the court will send notifications and
court orders electronically to the email address you provide.
A person who is filing or defending against a Civil Complaint will want to be familiar with the Rules of
the Superior Court, which are available on the court’s website: www.courts.state.nh.us.
Once you have registered and responded to the summons, you can access documents electronically
filed by going to https://odypa.nhecourt.us/portal and following the instructions in the User Guide. In
that process you will register, validate your email, request access and approval to view your case.
After your information is validated by the court, you will be able to view case information and
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

Court Name: Rockingham - Superior Court

Case Name: Paul Maravelias v. Amy Anderson

Case Number: 218-2019-CV-00158


(if known)
COMPLAINT
Requested: Jury Trial (as allowed by law) Bench Trial
1. Plaintiff’s Name Paul Maravelias
Residence Address 34 Mockingbird Hill Rd, Windham, NH 03087
Mailing Address (if different)
Telephone Number (Home) (Mobile) (603) 475-3305

2. Defendant’s Name Amy Anderson


Residence Address 2 Cardiff Rd, Windham, NH 03087
Mailing Address (if different)

3. First thing that happened (in one sentence):


Claim amount: $15,000.00. See attached Complaint.

4. Second thing that happened (in one sentence):

5. Third thing that happened (in one sentence):


TurboCourt.com Form Set #3159439

Continue on using separately numbered paragraphs (attach additional sheets if necessary).


NHJB-2688-Se (07/01/2018) Page 1 of 2
This is a Service Document For Case: 218-2019-CV-00158
Rockingham Superior Court
2/6/2019 2:27 PM
Case Name: Paul Maravelias v. Amy Anderson
Case Number:
COMPLAINT
For the reasons stated in this Complaint, I request that the Court issue the following orders:
A. Describe the orders you want the Court to make:
See attached Complaint.

B. All other relief the Court deems fair and just.

Paul Maravelias /s/ Paul Maravelias 2/4/19


Name of Filer Signature of Filer Date
(603) 475-3305
Law Firm, if applicable Bar ID # of attorney Telephone
34 Mockingbird Hill Rd paul@paulmarv.com
Address E-mail
Windham, NH 03087
City State Zip code
TurboCourt.com Form Set #3159439

NHJB-2688-Se (07/01/2018) Page 2 of 2


Filed
File Date: 2/4/2019 10:14 AM
Rockingham Superior Court
E-Filed Document

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

18 1. NOW COMES the Plaintiff Paul Maravelias (hereinafter,

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

21 legal right to live free from malicious harassment as orchestrated

22 through defamatory conduct. Defendant has persisted in unlawful and

23 defamatory conduct to disparage publicly Maravelias s reputation, obstruct justice, and

24 interfere tortiously with a concurrent civil protective order case in the Circuit Court, unrelated

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -1- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
This is a Service Document For Case: 218-2019-CV-00158
Rockingham Superior Court
2/6/2019 2:27 PM
1
to this action, in which Maravelias is a party. This conduct has caused actual damage to
2
Maravelias. This action seeks equitable relief restraining Defendant from persisting in said
3
course of conduct and seeks declaratory judgment stipulating the falsity of De
4
defamatory statements. Furthermore, this action seeks compensatory damages to remunerate
5
Maravelias for the injuries suffered as a result of Defendant Amy Anderson gross
6
misconduct, and to discourage the Defendant from committing further unlawful and/or
7
tortious acts against Maravelias.
8

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

19 5. Plaintiff PAUL MARAVELIAS is a natural person with residence at 34

20 Mockingbird Hill Road, Windham, New Hampshire 03087.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -2- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
IV. FACTUAL ALLEGATIONS
2
7. generically acquainted prior to 2017 by common
3
siblings in the Windham School District and shared friends. Maravelias admired and
4
respected Defendant Amy Anderson and her family until he discovered her tortious conduct.
5
8. Defendant Amy Anderson is a neighbor and close friend of David DePamphilis.
6
Their respective families are neighbors and close friends.
7
9.
8
protective order petition against Paul Maravelias. Maravelias had respectfully invited
9
Christina to dinner weeks-prior and never again interacted with her after that day, 12/12/16.
10

11 10. Immediately prior to the 12/28/16 petition, David DePamphilis performed a

12 series of explosive telephonic tirades against Paul Maravelias and his parents, culminating in

13 David DePamphilis threatening on

14 unspecified legal action against Maravelias.

15 11. A full description of the DePamphilis restraining order litigation against

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

19 restraining order petition. Maravelias called it a defamatory harassment campaign against

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -3- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
13. Christina DePamphilis has subsequently made vulgar, incitative cyberbullying
2
social media posts identifying and directed against Paul Maravelias depicting her, her
3
boyfriend, and David DePamphilis middle-fingering Maravelias. Christina DePamphilis
4
committed this conduct against Maravelias in June 2017 after he had been romantically
5
rejected and legally abused by her false accusations. In response to this cruel behavior,
6
Maravelias did not react or take-the-bait to violate the bad- .
7
Defendant knew of the DePamphilis actors said harassment conduct at all times material.
8
14. Recently, on 1/11/19, the DePamphilis actors filed a Motion to Extend the
9
duration of their restraining order against Maravelias.
10
15. On 1/24/19, the DePamphilis actors re-filed their Motion to Extend with altered
11
content after the Circuit Court dismissed-without-prejudice their initial 1/11/19 filing. The
12
first 1/11/19 Motion was non-compliant with court rules requiring sworn/signed verification.
13

14 16. Defendant Amy Anderson appears in both 1/11/19 and

15 final 1/24/19 Motions to Extend in materially significant ways as detailed hereunder.

16 17. original 1/11/19 Motion to Extend included

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -4- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1

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

14 19. On 7/3/18, Maravelias was at the

15 . He purchased some victuals and seated himself near

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -5- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
22. Maravelias glanced out the window either then or very shortly thereafter,
2
making eye contact with Defendant Amy Anderson.
3
23. Defendant Amy Anderson was sitting in her vehicle and was visible to
4
Maravelias through the window.
5
24. Having recognized her, Maravelias waved to the Defendant with his right hand.
6
She then returned the gesture. There was zero further contact between Maravelias and
7
Defendant. At no time was there any contact or interaction between Maravelias and any of
8
or anyone else who may have accompanied Defendant.
9

10 25. Immediately after the hand-wave, Maravelias redirected his eyeballs to

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

13 recording of anyone or anything.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -6- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
30.
2
read the part accusin Defendant Amy Anderson
3
daughter Rachel Anderson and the Anderson family at the Dunkin Donuts on 7/3/18.
4
31. On 1/15/19, Maravelias mailed a written interrogatory and accompanying letter
5
to Defendant Amy Anderson. The content of said letter and interrogatory were as follows:
6

8 Re: Witten Interrogatory

9 Dear Mrs. Anderson:

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.

21 Appended to my signature is a list of simple questions I would appreciate if you could


answer for me. You are not compelled to answer the questions, but otherwise I will likely
22 need to subpoena you and Rachel to t
school, and that might pose an inconvenience for both of you. I will also be videotaping the
full proceeding, and I would prefer your names not need to be tainted by public association
23
with the exposed criminal false accusers.
24

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -7- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1 The Motion also references you in the following ways. It repeats the debunked

2 be removed from his home by the


emember, the deceptive lie the small
3 WPD officer had mislead me with was similar, but meaningfully different. It also said you

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -8- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
FOR AMY ANDERSON
2
Submitted: 1/15/2019 Christina DePamphilis v. Paul Maravelias (473-2016-CV-124)
3

4 1. Mrs. Anderson, on 5/3/18, 5/4/18, and 6/8/18, there were hearings at

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

10 5. Did we wave to each other?

11 6. Can you remember if I had headphones on or not?

12 7. Did you come inside the building, or stay in the car?

13 8. Did you see me interacting with anybody, or was I eating/working on


laptop by myself, not interacting with anybody?
14
9. Did your daughter Rachel come inside?
15
10. At any time, did she express to you that she believed I had been
16 recording her or anybody?

17 11. Did you or your family members fe


behavior on 7/3/18? If so, how?
18
12. Did you tell anyone else about this part of your day on July 3 rd, 2018? If
19 so, whom did you tell and what did you say?

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES -9- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
33. Maravelias addressed his above mailing to Defendant Amy Anderson only. He
2
used her residential address as represented hereinabove. Maravelias never sent, shared, nor
3
mentioned his communication to Defendant with any other person until the filing of this suit.
4
34. On 1/24/19, nine days after Maravelias mailed his letter to Defendant,
5
Maravelias electronically re the same
6
day. He observed that DePamphilis had altered the part mentioning Defendant to differ from
7
the analogous text in the original 1/11/19 Motion to Extend. To wit, the resubmitted 1/24/19
8
Motion to Extend 1) changed the phrase [Defendant] has attended all hearings to
9
[Defendant] has attended most of the hearings
10
Learning that she may be a witness in this matter, Maravelias recently sent a letter to
11 Mrs. Anderson concerning the incident at Dunkin Donuts, posing discovery questions to
her, setting a deadline for response, and threatening to file a defamation suit against her if
12
she did not comply with his deadline.
13
35. In his 1/15/19 letter to Defendant, declared intention not to seek
14
damages was a byproduct of his then-ignorance that Defendant Amy Anderson 1) was
15
actively conspiring with the DePamphilis family to defame and legally abuse Maravelias, and
16
2) would intentionally inflict emotional harm while revealing the willfulness of her
17
defamatory conduct by communicating to DePamphilis private letter, itself to
18
fuel another spurious allegation against Maravelias of in the 1/24/19 Motion.
19

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.

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 10 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
38. If the 1/24/19 Motion to Extend had not been granted, the restraining order
2
against Maravelias would have expired on 2/5/19.
3
39. The restraining order extended as a direct and proximate result of Defendant
4
currently restricts titutional
5
rights and quotidianly injures him. These restrictions and injuries non-extensively include:
6
a. The restraining order prohibits Maravelias from driving through certain parts of
7
his neighborhood necessitating burdensome route adjustments.
8 b. The restraining order prohibits Maravelias from picking-up or dropping-off his
sister at his own alma mater, Windham High School, imposing extensive
9 burdens upon the Maravelias family.
10 c. Maravelias, a semi-frequent flier, is restricted from enrolling in TSA-Pre ®
during the pendency of the restraining order, causing burdensome and costly
11 inconveniences.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 11 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
40. The aforementioned 1/11/19 and 1/24/19 Motions to Extend are public court
2
documents. The allegations contained therein are visible to the general public.
3

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.

16 45. The said defamatory statements were made as assertions of fact.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 12 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
to the DePamphilis actors so as to give rise unto another spurious and defamatory accusation
2
against Maravelias of harassment to fuel their course of restraining order abuse.
3
49. The defamatory statements were designed to cause and did in fact cause an
4
injurious civil restraining order against Plaintiff to be extended.
5
50. Defendant made defamatory statements about Maravelias to other individuals
6
and to the public by using DePamphilis s initial 1/11/19 Motion to Extend as a high-visibility
7
broadcast mechanism.
8

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

12 amplify the language against Maravelias in DePamphilis s resubmitted 1/24/19 Motion to

13 Extend, a high-visibility public broadcast mechanism for Defendant s defamatory statements.

14 52. The third parties to whom Defendant communicated defamatory statements

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 13 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
55. In defamation suits
2

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

17 Defendant s daughter and family by recording them.

18 59. Defendant s defamatory statements represented Maravelias as a

19 person making strange, alarming, and unnecessary f a random

20 teenage girl in public which is morally turpitudinous and/or unlawful.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 14 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
61. Stalking is a criminal act and connotes a state of moral turpitude.
2
62. Recording someone in public in an intimidating or harassing fashion
3
constitutes a criminal act of Disorderly Conduct per RSA 644:2, II.(a).
4
63. Recording someone in public in an harassing
5
connotes a state of moral turpitude.
6

7 64. Defendant s defamatory statements constitute defamation per se.

8 65. The harmful nature of Defendant s defamatory statements is self-evident.

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

22 trial of this action but presently believed to be in excess of $15,000.

23

24

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 15 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1 COUNT 3: FALSE LIGHT INVASION OF PRIVACY
Restatement (Second) of Torts § 652E
2

3 70. Paragraphs 1 through 40 are incorporated by reference and repeated herein as

4 though fully set forth.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 16 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
73. Defendant s defamatory conduct intentionally placed Maravelias in a public
2
light by excogitating a deliberate scheme to infuse her defamatory statements into
3
DePamphilis s public 1/11/19 Motion to Extend, and to retain and amplify them thereafter in
4
DePamphilis s re-filed public 1/24/19 Motion to Extend.
5
74. Defendant placed Maravelias in a public light which was false, communicating
6
to the public at large falsely that Maravelias recorded and intimidated Defendant s
7
daughter and family at Dunkin Donuts on 7/3/18.
8
75. The false light represented Maravelias as a harassing and intimidating
9
person making strange, alarming, and unnecessary recordings of a random teenage girl in
10
public and is highly offensive to a reasonable person.
11

12 76. Defendant knew the falsity of the light in which she cast Maravelias and/or

13 acted with reckless disregard as to the falsity of said publicized matter.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 17 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
80. The said statements were false and tended to place Maravelias in a false,
2
negative light before the public, and appropriated Maravelias s name and likeness. Defendant
3
willfully caused the statements to appear in DePamphilis s two public Motions to Extend the
4
restraining order.
5
81. As a direct and proximate result of Defendant Amy Anderson s tortious conduct,
6
Paul Maravelias has suffered actual damages and is entitled to a money judgment against
7
Defendant in an amount within the jurisdictional limits of this court to be determined upon the
8
trial of this action but presently believed to be in excess of $15,000.
9
COUNT 4: INTENTIONAL INFLICTION OF EMOTIONAL DAMAGE
10

11 82. Paragraphs 1 through 40 are incorporated by reference and repeated herein as

12 though fully set forth.

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

17 N.H. 493, 496 (1991).

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 18 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
86. Defendant intentionally and/or recklessly endeavored to cause the DePamphilis
2
restraining order to be extended as a direct and proximate result of her defamatory statements
3
for the purpose of causing severe distress, pain, and anguish to Maravelias.
4
87. Defendant intentionally and/or recklessly failed to respond to Maravelias s
5
polite written interrogatory request and letter and instead shared the aforesaid communication
6
with DePamphilis in an orchestrated manner to amplify the 1/24/19 defamatory Motion to
7
Extend for the purpose of causing severe distress, pain, and anguish to Maravelias.
8
88. After receiving Maravelias s 1/15/19 letter indicating the contents of
9
DePamphilis s original 1/11/19 Motion to Extend, Defendant intentionally and/or recklessly
10
failed to effectuate the removal of her past defamatory statements from DePamphilis s re-filed
11
1/24/19 Motion to Extend for the purpose of causing severe distress, pain, and anguish to
12
Maravelias.
13

14 89. By cause of and as a direct and proximate result of the foregoing tortious

15 conduct, Defendant caused Maravelias severe emotional distress.

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

18 through a deliberate campaign of defamatory harassment and intimidation.

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 19 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1 DECLARATORY JUDGMENT
2
92. Paragraphs 1 through 40 are incorporated by reference and repeated herein as
3
though fully set forth.
4
93. By reason of the foregoing, there is a live and justiciable controversy between
5
the Defendant, on one hand, and the Plaintiff, on the other hand.
6

7 94. Plaintiff Maravelias is entitled to a declaratory judgment that he did not, in fact,

8 record , harass , or intimidate Defendant s daughter or family on 7/3/18.

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

13 Defendant s defamatory conduct in said Circuit Court case.

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

22 with reckless disregard to the truth or falsity thereof.

23

24

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 20 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
VI. DEMAND FOR JURY TRIAL
2
99. The Plaintiff respectfully demands a jury trial as allowed by law on all issues
3
raised in this Complaint.
4

5 VII. PRAYER FOR RELIEF

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

15 i. Communicating to any person statements about Paul Maravelias she


believes to be false,
16
ii. Communicating to any person statements about Paul Maravelias with
17 reckless disregard to the truth or falsity of said statements; and
18
V. Grant any further relief as may be deemed just and proper.
19

20

21

22

23

24

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 21 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1
Respectfully submitted,
2

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

COMPLAINT AND REQUEST FOR INJUNCTION, PAUL MARAVELIAS


DECLARATORY RELIEF, AND COMPENSATORY DAMAGES - 22 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
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

Court Name: Rockingham Superior Court


Case Name: Paul Maravelias v. Amy Anderson
Case Number: 218-2019-CV-00158
(if known)
APPEARANCE/WITHDRAWAL
APPEARANCE
Type of appearance (Select One)
✔ Appearance Limited Appearance (Civil cases only)
If limited appearance, scope of representation:

Select One:
As Counsel for:

(Name) (Address) (Telephone Number)

(Name) (Address) (Telephone Number)

(Name) (Address) (Telephone Number)


✔ I will represent myself (self-represented)

WITHDRAWAL
As Counsel for
Type of Representation: (Select one)
Appearance:
Notice of withdrawal was sent to my client(s) on: at the following address:

A motion to withdraw is being filed.


Limited Appearance: (Select one)
I am withdrawing my limited appearance as I have completed the terms of the limited
representation.
The terms of limited representation have not been completed. A motion to withdraw is being
filed.

NHJB-2318-Se (07/01/2018) Page 1 of 2


This is a Service Document For Case: 218-2019-CV-00158
Rockingham Superior Court
2/6/2019 2:27 PM
Case Name: Paul Maravelias v. Amy Anderson
Case Number:
APPEARANCE/WITHDRAWAL

For non e-filed cases:


I state that on this date I am mailing by U.S. mail, or Email (only when there is a prior agreement of the
parties to use this method), or hand delivering a copy of this document to:

Other party Other party’s attorney

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.

Paul Maravelias /s/ Paul Maravelias 02/04/2019


Name of Filer Signature of Filer Date
(603) 475-3305
Law Firm, if applicable Bar ID # of attorney Telephone
34 Mockingbird Hill Rd paul@paulmarv.com
Address E-mail
Windham NH 03087
City State Zip code

NHJB-2318-Se (07/01/2018) Page 2 of 2


Filed
File Date: 2/4/2019 10:14 AM
Rockingham Superior Court
E-Filed Document

218-2019-CV-00158

This is a Service Document For Case: 218-2019-CV-00158


Rockingham Superior Court
2/6/2019 2:27 PM
Case Name: Paul Maravelias v. Amy Anderson
Case Number:
MOTION TO ATTACH WITH NOTICE

NOTICE TO THE DEFENDANT

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.

Plaintiff or Plaintiff’s Lawyer

FOR COURT USE ONLY


ORDER

The motion to attach is denied.

The Plaintiff is granted permission to make the above attachment(s) within days.

Date Presiding Justice

NHJB-2714-Se (07/01/2018) Page 2 of 2

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