Paul Maravelias's Pro Se 2018 Appeal Brief (Christina DePamphilis v. Paul Maravelias, 2018-0483)

THE STATE OF NEW HAMPSHIRE
SUPREME COURT
2018 TERM
Case No. 2018-0483
CHRISTINA DEPAMPHILIS
Plaintiff-Appellee
vs.
PAUL MARAVELIAS
Defendant-Appellant
RULE 7 MANDATORY APPEAL OF STALKING FINAL ORDER

OF PROTECTION
From 10th Circuit Court – District Division – Derry
BRIEF OF DEFENDANT
Submitted by Defendant,
Paul J. Maravelias
34 Mockingbird Hill Rd
Windham, NH 03087
paul@paulmarv.com
603-475-3305
ORAL ARGUMENT
REQUESTED
TABLE OF CONTENTS
TABLE OF AUTHORITIES .................................................................. 6

TEXT OF RELEVANT AUTHORITIES .............................................. 9
QUESTIONS PRESENTED ................................................................ 10
STATEMENT OF THE CASE ............................................................ 12
STATEMENT OF FACTS ................................................................... 17
SUMMARY OF ARGUMENT ............................................................ 30
ARGUMENT ........................................................................................ 31
I. RSA 633:3-A, III-C. IS UNCONSTITUTIONAL

FACIALLY AND AS-APPLIED ........................................ 31
A. The “Safety and Well-Being” Language of 633:3-a, III-

c. is Overbroad .................................................................. 31
i. The Statute Regulates and Burdens Protected Speech

...................................................................................... 32
1. Maravelias’s 12/10/17 Email to Mrs. Smith is

Protected Speech ...................................................... 34
2. Maravelias’s 11/2/2017 Response to Attorney

Brown is Protected Speech ...................................... 34
3. The March 2017 Nasty Letter to David

DePamphilis ............................................................. 35
ii. The Statute Triggers Strict Scrutiny......................... 35

1. The Regulation is Content-Based ........................ 36
2
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
2. The Regulation Isolates Disfavored Speakers and is
Not Viewpoint-Neutral ............................................ 36
3. Forum Analysis .................................................... 37
iii. The Statute Fails Even Intermediate Scrutiny ........ 38

1. Tailoring Analysis ................................................ 38
2. The Governmental Interest Served is not

“Compelling” ........................................................... 42
3. Alternative Channels ............................................ 43
B. The “Safety and Well-Being” Language of 633:3-a, III-

c. is Impermissibly Vague ................................................ 43
i. Semantic Vagueness .................................................. 43
ii. Syntactic Vagueness................................................. 44
II. WHERE CHRISTINA DEPAMPHILIS

INCITATIVELY BULLIED PAUL MARAVELIAS ON
HER SOCIAL MEDIA AFTER LAUGHIBLY LYING
ABOUT HAVING “FEAR” OF HIM, EVIDENCE
SUPPORTING THE TRIAL COURT’S FINDING OF
“REASONABLE FEAR” WAS INSUFFICIENT ............ 46
III. THE TRIAL COURT COMMITTED AN

UNSUSTAINABLE EXERCISE OF DISCRETION IN
GRANTING THE STALKING ORDER EXTENSION .. 46
A. Good Cause for Stalking Order Extension was Not

Shown by a Preponderance of Evidence .......................... 46
3
B. The Trial Court Made Honest Verbal Comments at Trial
Proving its Subsequent Written Order was Shamefully
Disingenuous .................................................................... 49
IV. THE TRIAL COURT VIOLATED MARAVELIAS’S

DUE PROCESS RIGHTS ................................................... 51
A. Reversal is the Necessary Remedy to the Trial Court’s

Blatant Violation of the “30 Days” Hearing Requirement
of 633:3-a, III-c. ................................................................ 51
B. The Trial Court Illegally Limited Defendant’s

Guaranteed Right to Videotape the Entire Public Hearing
........................................................................................... 52
C. The Trial Court Violated the Statutory Advance Notice

Requirement and/or Other Substantive Due Process Rights
........................................................................................... 53
i. “Obsession” and the 6/8/18 Surprise-Photographs-

Exhibit .......................................................................... 53
ii. Ignored Motion to Dismiss ...................................... 53
V. JOHN J. COUGHLIN, THE TRIAL COURT JUDGE,

COMMITTED A RAMPANT SPREE OF BIASED AND
UNJUST CONDUCT AGAINST MARAVELIAS, BEING
LARGELY UNACCOUNTABLE TO AUTHORITY,
SINCE HE RETIRED DAYS LATER ............................... 54
VI. THE TRIAL COURT ERRED IN GRANTING

PLAINTIFF’S POST-TRIAL MOTION FOR
EXTENDED PROTECTIVE ORDERS ............................ 54
A.The Trial Court Transgressed Constitutional Rights and

Unsustainably Exercised Discretion ................................. 56
4
B. John J. Coughlin Personally Committed a Class B
Criminal Felony Violation of 641:5, I.(B) in Granting
Plaintiff’s Obscurantist Assault Against Maravelias’s
Public Freedom of Expression .......................................... 57
CONCLUSION ..................................................................................... 58
PRAYER FOR ORAL ARGUMENT .................................................. 60
APPENDIX ........................................................................................... 61
5
TABLE OF AUTHORITIES
Cases
STATE OF NEW HAMPSHIRE
Appeal of Martino, 138 N.H. 612 (1994) .................................................... 52

Doyle v. Comm’r, N.H. Dep’t. of Resources & Economic Dev., 163 N.H.
215,221 (2012) .................................................................................. 32, 38
Kenison v. Dubois, 152 N.H. 448,451,879 A.2d 1161 (2005) .................... 32
MacPherson v. Weiner, 158 N.H. 6,10 (2008) ...................................... 40, 49
McCarthy v. Wheeler, 152 N.H. 643,645 (2005) ............................ 33, 51, 52
State v. Allard, 148 N.H. 702 A.2d 506,510 (2002) ................................... 38
State v. Brobst, 151 N.H. A.2d 1253 (2004) ............................................... 33
State v. MacElman, 154 N.H. 304,307 (2006) ................................ 31, 32, 33
State v. Porelle, 149 N.H. 420 (2003) ......................................................... 33
State v. Zidel, 156 N.H. 684, 686 (2008) .................................................... 34
Stewart v. Murdock, (2015-0448) ............................................................... 42
COMMOMWEALTH OF MASSACHUSETTS
O'Brien v. Borowski, 461 Mass. 415 (2012) ............................................... 37
UNITED STATES OF AMERICA
American Legion Post 7 of Durham, N.C. v. City of Durham, 239 F.3d

601,607 (4th Cir. 2001) ............................................................................ 35
Ashcroft v. Free Speech Coal. 535 U.S. 234, 245 (2002) ..................... 34, 38
6
Boos v. Berry, 485 U.S. 312,322 (1988) ..................................................... 35
Broadrick v. Oklahoma, 413 U.S. 601 (1973)............................................. 33
Citizens United v. Fed. Election Comm’n, 130 S. Ct. 882,883 (2010) . 36, 37
Cohen v. California, 403 U.S. 15 (1971)..................................................... 34
Doe v. Harris, 772 F.3d 563 (2014) ............................................................ 38
Florida Star v. B.J.F., 491 U.S. 524,540 (1989) .......................................... 41
Hill v. Colorado, 530 U.S. 703,732 (2000) ................................................. 43
Pleasant Grove City v. Summum, 555 U.S. 460 129 S.Ct. 1125,172 L.Ed.2d
853 (2009) ............................................................................................... 37
Rutan v. Republican Party, 497 U.S. 62,74 (1990) ..................................... 40
Showtime Entertainment, LLC v. Town of Mendon, 769 F.3d 61,73 (1st Cir.
2014) .................................................................................................. 41, 42
Simon & Schuster, Inc. v. Members of N.Y. State Crime Victims Bd., 502
U.S. 105 (1991) ....................................................................................... 33
Sorrell v. IMS Health Inc., 131 S. Ct. 2664 (2011) .................................... 36
Terminiello v. City of Chicago, 337 U.S. 1,4 (1949) .................................. 35
Turner Broadcasting System, Inc. v. FCC, 512 U.S. 622,658,114 S.Ct.
2445, 129 L.Ed.2d 497 (1994) ................................................................ 37
Ward v. Rock Against Racism, 491 U.S. 791 (1989) ................................. 38
Constitutional Provisions
First Amendment to the Federal Constitution ........................... 32, 33, 34, 36

Fourteenth Amendment to the Federal Constitution ................................... 32
New Hampshire Constitution Part I, Article 22 .................................... 32, 38
7
Statutes
M.G.L. 258E §3(d) ...................................................................................... 45

M.G.L. 265 §43 ........................................................................................... 45
RSA 173-B in genere .................................................................................. 32
RSA 173-B:3 ............................................................................................... 53
RSA 633:3-a in genere .......................................................................... 32, 42
RSA 633:3-a, III-a ..................................................................... 38, 40, 41, 42
RSA 633:3-a, III-c ................................................................................ passim
RSA 641:5, I.(B).......................................................................................... 57
New Hampshire Rules of the Circuit Court - District Division
Circuit Court Rule 1.4 ................................................................................. 52
Academic Literature
Newberg and Waldman, 2012

(https://www.psychologytoday.com/us/blog/words-can-change-your-
brain/201208/the-most-dangerous-word-in-the-world) .......................... 39
Rook, K.S. (1984) ........................................................................................ 39
8
TEXT OF RELEVANT AUTHORITIES
Statutes
RSA 633:3-a ......................................................................... A223

RSA 173-B:3 ........................................................................ A226
RSA 641:5 ............................................................................ A227
M.G.L. 258E § 3 .................................................................. A227
M.G.L. 265 § 43 ................................................................... A227
New Hampshire Court Rules
Circuit Court Rule 1.4 .......................................................... A229
9
QUESTIONS PRESENTED
1. Is RSA 633:3-a, III-c. constitutional?
(T302;A48,A50,A162-163,A99-100)1
2. Was there sufficient evidence to support the trial court’s finding that
Christina DePamphilis had “reasonable fear” of Maravelias?
(T307,471,478,479,485,486;A43,46,118)
3. Did the trial court commit an unsustainable exercise of discretion

and/or an error of law in granting Plaintiff’s motion to extend
stalking order and/or her 7/2/18 post-trial motion for expanded
protective orders?
(A43,44,45,47,50,158,118,186)
4. Did the trial court violate Respondent’s procedural and/or

substantive due process rights?
1
T = Consecutively-numbered transcripts of May-June 2018 trial court Hearing.
A = Appendix herewith.
Example format: (Tx:y-z,a-b;A10-20) where y-z reference lines on transcript page x
and a-b reference whole consecutive transcript pages.
10
(T5-7,9:1-3,484:17-18,487-489;A48-50,63-65,111-114)
5. Did Judge John J. Coughlin commit a rampant pre-retirement spree

of unjust conduct marked by hostile prejudicial bias against
Maravelias and reflexive, typhlotic rejection of all his arguments,
quidquid sint?
(A45,51,115-126); Plain-error; Supreme Court Justices as

supervisory judges per Rule 54 and Code of Judicial Conduct
Rule 2.12 (B)
11
STATEMENT OF THE CASE
Overture
This appeal is a righteous young man’s exasperated plea for justice.
Maravelias apologizes in advance to this Honorable Court for wherever he
may fail in this legal brief to restrain his understandable righteous
indignation. He recites here a breviloquent case-summary with the bare
minimum of necessary facts, relegating further facts into the following
section.
DePamphilis’s December 2016 Delusions

In December 2016, David DePamphilis got angry with Paul
Maravelias. Paul had asked-out David’s daughter to dinner on 12/12/16.
(T27,276-277) Paul Maravelias never once spoke to or communicated with
her ever after that day. (T27,28,35-36,451:17-18) On 12/23/16, after 11
days of frightening, harassing conduct by David DePamphilis discussed in
the related case (2018-0376), Maravelias texted David DePamphilis to
“stop harassing [Maravelias’s] parents please”. (A197) As a result of this
text, David texted Paul’s parents the same night, promising, “that’s the last
straw”. (A186,198) Five days thereafter, on 12/28/16, Maravelias was
served a Stalking Temporary Order of Protection. But DePamphilis’s
daughter Christina, nominally, had filed a “stalking petition” against
Maravelias (473-2016-CV-124). Maravelias hadn’t interacted with her once
since 12/12/16 weeks prior (T226:15,27,28,35-36,451:17-18), the first and
only time Maravelias expressed an interest in her.
12
The Legal Abuse Begins
Outraged, Maravelias expedited the hearing and boldly appeared pro se
as a legally untrained, falsely accused 21-year-old college student. (T64)
His innocence and rhetorical skills were no match for the polished legal
scheming of Jerome Blanchard, DePamphilis’s first attorney-henchman.
Tyrant I: Robert S. Stephen

The DePamphilis actors got their stalking order on 2/7/17. It was Judge
Robert S. Stephen who granted this stalking petition against a dignified
and level-headed gentleman named Paul Maravelias. (A40)
The Censored Exculpatory Audio Recording

Maravelias happened to have a sentimental audio recording of his
12/12/16 dinner-date-proposal exchange, proving his gentlemanly verbal
appropriateness. (T276;A98) After Christina DePamphilis lied under oath
about what Maravelias had said, to make him sound like a “creepy” or
socially deficient person, Maravelias was disallowed to play his
exculpatory recording in court. (T277) Robert S. Stephen defied
Maravelias’s every vociferous assertion to the contrary, falsely claiming in
his Orwellian Order that Maravelias had mentioned the “age of consent”
while asking-out David’s 16-year-old daughter! (A40)
The First Arrest

David DePamphilis complained to the police about Maravelias’s
suppressed recording after abusing Maravelias with a falsified restraining
order. Robert S. Stephen approved search warrants and Windham PD
raided Maravelias’s Windham home and Dartmouth dorm room on 4/6/17,
13
whisking-away all Maravelias’s digital property in toto (cellphones, PCs,
USB-drives, etc). The police-state arrested Maravelias on 6/13/17 for
“wiretapping” (RSA 570-A): the crime of pressing a button on your
smartphone outdoors to voice record yourself the first time you ask out a
girl in your life, with the intention of sharing it with her, and later wanting
to play it to disprove contemptible false accusations. (T43,443)
The Futile Appeal

Maravelias was an economics major and a bright kid. But, he had no
idea what “issue preservation” was. He didn’t know he had 10 days to
preserve legal arguments in a motion for reconsideration. (T63:25) Once he
hired a top-notch attorney to appeal the ridiculous stalking order (2017-
139), it was apparently too late. This Court was compelled to affirm,
declining to review the appeal’s substance because its arguments were
unpreserved.
The Second Arrest

Maravelias emailed his beloved Windham High School mentor and
civics teacher, Mrs. Smith, on 12/10/17. (A91) Alas: Mrs. Smith runs the
WHS National Honor Society chapter. Maravelias attached evidence of
Christina DePamphilis’s legal falsification and substance-abuse crimes,
which disqualify her from ongoing NHS membership. (T419;A91-92) Now
Greg Iworsky, the WHS WPD resource officer, had married Heather
Newell, WPD’s prosecutor. Heather and another small, third-rate WPD
officer-tyrant caught wind of Maravelias’s private email to a public
employee. They pleasured themselves by arresting Maravelias on 12/15/17
14
for “stalking” DePamphilis’s daughter, whom Maravelias hadn’t seen for
almost a year nor knew even still existed. (T331,336-337)
They threw Maravelias in jail, purposely on a Friday night. Maravelias

had just bought his family a Christmas tree and was planning to decorate it
with his two siblings. An obese fat-acceptance-feminist nurse at
Rockingham County Jail forced Maravelias into solitary confinement after
he politely mentioned he’d be doing a three-day fast until the Monday
arraignment, so the jail didn’t need to waste food he wouldn’t eat. Rapists
and murderers inside the same jail enjoyed a bed to sleep on that night.
Heather Iworsky vitriolically slandered Maravelias at arraignment before
Tyrant I. They held the bizarre, illogical charge over Maravelias for as long
as they could, dropping it months thereafter in late May 2018.
(T331,337,384:9-12;A37)
The Extension
After repeated mid-order acts of cruel bullying, harassment, and indeed
stalking against Paul Maravelias (T278-280,299,307) (see also 2018-0376),
the relentless DePamphilis actors motioned the court on 1/5/18 to extend
their precious “stalking order” another year to February 2019. (A72) Judge
Sharon DeVries granted the preliminary extension on 1/12/18. (A10) The
trial court scheduled a hearing for 2/15/18 on Maravelias’s objection
thereto, 34 days after 1/12/18, and actually gave Maravelias his first
opportunity to proceed with the hearing on 2/20/18. (A222,151)
Tyrant II: John J. Coughlin

There was in those days a judge named John J. Coughlin.
15
Now John was presiding at Derry, fulfilling the last-days of his career:
for the extension case was transferred thither from Salem after Judge
Stephen’s recusal. A three-day hearing commenced 5/3/18 and finished
6/8/18. Judge John J. Coughlin granted the stalking order extension on
6/15/18. (A1)
Coughlin’s Career-Capstone Summer 2018 Orders against Maravelias

It came to pass that John J. Coughlin authored a written finding with
said Order. (A2) Before retiring on 9/5/18, Judge Coughlin also granted
DePamphilis’s post-trial motion requesting even more severe restrictions on
Maravelias’s public free-speech rights (A7), terrified that Maravelias could
expose the character of David DePamphilis’s perjuring
(T275:25,370;A21,24,28,189,192,201), substance-abusing (T60,364,371-
372,418,450;A18,84,167), bullying (T299:3,301:13,307:2-4,339,346-
347,371,476,483;A11,13,43,118), harassing (T164:21,
T299:3,482:25,485;A43,49,91), stalking (T70:10;A61-62,166), physically
unrecognizable (T353-355;A46¶20), lying
(T275:25,340:21,368:12,483:25;A62,91,187,189), law-breaking
(T421:18,A167-196), “independent” (T74:14,233:8) daughter Christina.
This appeal follows.
16
STATEMENT OF FACTS
David DePamphilis begat a daughter in 2000: Christina DePamphilis

(“Plaintiff-Appellee”), a high school senior turning 18 in a few days.
Paul Maravelias (“Defendant-Appellant”) is a 23-year-old author and

recent college graduate who is presently employed as a software engineer.
(A42) He’s had an unusual experience stemming from the first time he ever
asked a girl on a date. Maravelias does not drink alcohol, consume illegal
drugs, or commit perjury to abuse those who showed him kindness and
respect. (A43) He believes he differs from Christina DePamphilis in these
regards. (A43)
Social Pretext to December 2016

Both parties are Windham residents and were good friends before
David DePamphilis’s direful December 2016 devolution into the legal
abuser of Paul Maravelias. (T274,275;A98,102) David and his daughter
came to Maravelias’s house on 6/18/2016 for a family party. (T275:24,276)
David was “smoking cigars” with Maravelias’s dad (T38,39): this was the
last time Maravelias saw Christina DePamphilis prior to the 12/12/16
dinner-invitation. During cross-examination, Christina struggled to justify
her coming over Paul’s house mere months before calling him a “stalker”
with dramatic retellings of being “scared” by him since 2013. (T39)
The December 2016 Origin of the Stalking Petition

Maravelias needs not belabor the details of his 12/12/16 birthday-
exchange with DePamphilis’s daughter, by now reviewed ad nauseum in
17
both appellate cases. According to laborious design, Maravelias invited her
to dinner with an outlandish sports-car, which she said was “very sweet”.2
(A98) But DePamphilis’s wife clarified her daughter perceived Maravelias
as “a nice friend”. He left once rejected, saying, “I respect your feelings”
and “have a beautiful Christmas”. (T278:4;A98) There was not a hint of
impropriety, the slightest indication the daughter felt “scared”, nor the most
remote semblance of “stalking” whatsoever. (A98,31) In fact, Christina
DePamphilis had invited Maravelias back to her house on 12/12/16 for this
interaction, after he first came to the door and her mommy was in the
shower. (T157:21-158:12;A31) Maravelias, ever the gentleman, awaited
Mrs. DePamphilis.
Nor does Maravelias re-explain the history of David DePamphilis’s

subsequent December 2016 course of explosive, threatening, harassing,
profane, and frightening conduct against him and his parents – likewise
detailed in the related appeal (See 2018-0376).
The undeniable fact is Paul Maravelias had a normal family friends

relationship to Christina DePamphilis (T275) and transitory romantic
attraction which manifested in a cute birthday dinner date proposal and
ostentatious stunt with a fancy car. The undeniable fact is “she” filed a
stalking petition 16 days after Maravelias’s final contact with her, after her
By 2018, DePamphilis falsely portrayed Maravelias as some “spoiled rich kid”, and John
2
Coughlin “ordered” Maravelias to pay his abuser “9,000 dollars” which Maravelias didn’t “even
have … in his bank account”, still paying off “2016 taxes”. (T332)
18
father was angered by Maravelias’s challenging David DePamphilis’s
emotionally and verbally abusive antagonism.
Foolhardy Falsity: The Original Stalking Petition

The stalking petition dreamed up a host of absurd, malicious
dramatizations of history against Maravelias. He was falsely accused of
having “grabbed [her] arm” at “cheer practice” three years prior in 2013
(A150). It is telling that even in David’s December 2016 telephonic tirades,
where he accused Maravelias to his face of everything short of raping the
Sabine women, David never mentioned this alleged “arm-grabbing”
incident with his daughter nor the word “stalking” whatsoever.
Appellant bores-not this Court by reviewing similar defamatory drivel

from DePamphilis’s original stalking petition. A neurotic admixture of
[paraphrasing] “I think he hacked into my Twitter account” (T174:13), “he
was looking at me in his backyard” (T185:11), “he tried to talk to me at the
Turkey Trot once and I was scared” (A39) and similar cringeworthy
absurdities sustained the witch-hunt against Maravelias, an innocent suitor.
Judge Robert S. Stephen Slanders Maravelias a “Stalker”

On 2/7/17, Judge Robert S. Stephen confirmed once-more the
reputation he had already earned himself within the New Hampshire legal
community is deserved. Stephen granted the stalking petition, issuing an
Order against Maravelias scribbled in barely-legible chicken-scratching
penmanship. (A40) Judge Stephen opened his Order accusing that the
“Defendant has been obsessed with the Defendant”. (A40)
19
After failing to remember way back from law school the word
“Plaintiff”, Judge Stephen accused Maravelias’s stalking course of conduct
was based in two acts: that Maravelias
1) “drove [David’s daughter] home and attempted to drop the other

person off first” in 2013, and
2) “waited until she turned 16 which he referred to as the ‘age of

consent’ to her mother, offered [sic] her a brand new mazzaretti [sic]”.
(A40)
Paul Maravelias humbly demands this Court and anyone reading this
document meditate upon the disturbing fact that the above two reasons
are why a New Hampshire family court judge labeled Maravelias a
“stalker”.
In recklessly libeling Maravelias, Judge Stephen only memorialized his

own incompetence: in 2013, David DePamphilis himself had asked Paul
Maravelias to give his daughter a ride home from a restaurant they were at,
as a favor. (T286:21-13) If Paul Maravelias had truly been perceived as a
“stalker”, David DePamphilis would not have explicitly consigned his own
daughter into Maravelias’s vehicle, volunteering Maravelias to serve as Mr.
DePamphilis’s own filial spedizione chauffeur! (T287)
Secondly, Maravelias never “referred” to the young woman’s birthday

as her “age of consent”.
(T101:20,370:11,484:5,484:12,487:4;A29,31,98,106,192) Only a perverse
tyrant fully divorced from the most elementary tenets of justice would dare
20
to judicially shove words into a good young man’s mouth3 never spoken,
which said-young-man categorically denied ever speaking
(T101:20,370:11,484:5,484:12,487:4), and for which he assertively offered
indisputable physical evidence (his audio recording) as proof. Maravelias
lawfully played this audio recording for his parents on 10/21/17 in
Vermont; they testified in letters to the contents: that Maravelias never once
said anything remotely close to the disturbing “age of consent” comment
DePamphilis falsely accused. (A28-32) Further, the lie that Maravelias had
said this appeared nowhere in the stalking petition. (T489:14,491:6,492:7)
A stalking order thus exists against Maravelias because of a disprovable lie
that wasn’t even noticed in the petition.
Hypocrisy and Harassment: Christina DePamphilis’s Middle-Finger Post

Against Maravelias with her New 21-Year-Old Boyfriend
Having secured their falsified restraining order, the savage
DePamphilis actors escalated their psychological terrorism against Paul
Maravelias to a new level. On 6/19/17, Christina posted a picture on her
public social-media showing her new college-age boyfriend Matthew
LaLiberte making challenging comments against “P M”. (T79-82;A13)
Then, on 6/21/17 at 9:13pm, she posted a picture showing David

DePamphilis, herself, and her boyfriend standing together and middle-
fingering the camera, with the caption, “Did Dartmouth teach you how to
do this? [middle-finger emoji]” (T69,70,72-77;A11), which she confessed
3
Hurtfully, Judge Stephen’s libelous order-text in this regard appears as Mr. Maravelias’s
first public Google search result, being cited in this Court’s 7/28/17 Order in 2017-0139
21
was obviously targeted at Maravelias. (T74,76) This was days after she got
Maravelias arrested on 6/13/17 for trying to defend himself against her
false stalking accusations with his censored cell-phone voice recording.
(T349) She and her father were rubbing-in the all their legal abuse while
taunting Maravelias with Christina’s new 21-year-old (T146,147) boyfriend
– Maravelias’s age – endeavoring to create an even more provocative
aspect of jealousy. (T476)
Weeks prior, Christina DePamphilis had whined under-oath she was

“scared” of Maravelias and “afraid” “to set him off” – that “it’s like
walking on eggshells with him” (T67:10-11) – to get the stalking order she
later unsuccessfully baited him into violating. (T232:10-13)
Christina DePamphilis’s “Tipsytina69” Activities: A Rare Flash of

Honesty
In summer 2017, outraged female entities within the campus of
Windham youth supplied Maravelias with Christina DePamphilis’s
postings on her legally-public Instagram account she named “tipsytina69”,
a reference to drunken oral intercourse. (T239:16,359) These exhibits were
referenced frequently at hearing. They showed Christina DePamphilis was
quite beyond her green-age of 16 years: she would alcoholically
(T60,364;A18,167) and narcotically (T450:21;A167) intoxicate herself, and
brag about how far she and her 21-year-old boyfriend would displace the
bed during sexual intercourse, whereupon Christina visually emphasized in
red ink that the intercourse kinetically translated their bed over two feet
from the wall. (A221,159) Maravelias argued these posts contradicted the
deceptive “young-and-innocent” optics DePamphilis had falsely conjured
22
against Maravelias to win a “stalking” order, that they undermine her
dubious professions of “fear”, and that great irony exists in light of older-
Maravelias’s comparatively rectitudinous lifestyle.
Liar Caught Red-Handed: Maravelias’s May 2018 Cross-Examination of

Christina DePamphilis
Maravelias cross-examined DePamphilis at the 5/3/18 and 5/4/18
hearings.
On 5/3/18, Christina DePamphilis confessed that Maravelias has never

attempted to interact with her since December 2016. (T27:18) Maravelias
asked, “Please tell this Court the last time you were stalked by me.”
(T28:18-19) Christina memorably responded, “I continue to being [sic]
stalked every day.” (T28:20)
Christina said she believes Maravelias making any in-public comment

she would consider defamatory is an instance of “stalking” her. (T34)
When asked how she could possibly sustain her burden that Maravelias
“threat[ens]” her “personal safety”, she responded: “You just don’t stop…
[pause] you continue to… [pause] to send letters threatening to ruin my
career”, referencing Maravelias’s single November 2017 reply to David
DePamphilis’s outrageous legal bluff-threat letter to Maravelias. (T46:22-
24)
Paul Maravelias asked Christina DePamphilis: “Isn’t there a difference

between stalking, and people speaking their free minds about your actions
and accusations against them?” (T57:16-18) Christina slipped and tellingly
replied, “you can’t do that when I have a stalking order against you.”
23
(T57:19-20) Christina clarified Maravelias’s third-party self-defensive
speech-acts disagreeing with her stalking accusations are themselves further
acts “stalking”, because he is “further talking about me [her]”. (T58)
Maravelias challenged David DePamphilis’s daughter to name one

single incident he had actually stalked her. (T59) She replied, “such as my
eighth-grade graduation”. (T59:14) Maravelias then asked if she considered
his “casually coming up to [her] [at Maravelias’s sibling’s graduation] and
saying ‘hey, congratulations’” in 2015 to be “stalking”. Christina
DePamphilis failed to answer the question; she turned to the Court and
defeatedly opined, “he has a way of misinterpretating [sic] situations”.
(T59:17)
Christina DePamphilis lied multiple times: e.g., she first claimed she
“was the only one” “who knew” her harassing 6/21/17 middle-fingers post
was directed at Maravelias. (T72:16-17) Later, she admitted she “and [her]
[five-years-older] boyfriend” also knew. (T79:23-24) Another lie about the
post was noted: initially, she claimed it was just to “let [Maravelias] know”
that she knew he was viewing her page. (T70:15) Then Maravelias pulled-
out her 6/19/17 post which had already identified him. (T77:12-14,79:3-
7,79:21-24)
Some of Christina DePamphilis’s vile lies were exposed spectacularly.

Maravelias played a cell-phone video for the trial court his younger sister
happened to be taking at the 11/28/2013 Windham Turkey Trot walk-run
event. Christina had alleged in her stalking petition and while testifying that
Maravelias “came up to her” at this event and “tried to talk to [her]”,
24
making her “scared”. (T220:3-9;A38,39) Coincidentally, the video captured
this whole interaction4: Christina DePamphilis had actually noticed
Maravelias from across the crowd along with his sister, walked over to him
with a premeditated intention to find him shared by Maravelias’s sister
(T215:15-17, Video 0:47-1:24), and interrupted Maravelias’s conversation
with his friends, assertively exclaiming “Hi Paul!” (Video at 1:24)
Christina was even wearing a sweatshirt with the name of Maravelias’s
college on it and tried to win his approval by boasting, “I’m promoting your
college!” (Video at 1:28) Yet in her petition, this whole exchange was
dramatized into a delusional canard of Maravelias “stalking” DePamphilis!
(A39)
Christina DePamphilis’s Inaffidable Imaginations

In a frantic scurry of subsequent damage-control, Christina
DePamphilis further evidenced her lack of credibility – whether from lying
or deficient memory. She asserted Maravelias’s sister had said the words
“will you come see him with me” in the video she’d just watched. (T222)
Maravelias corrected her, since his sister never spoke those words (Video at
0:47), but Christina DePamphilis was so confident in her false, revisionist
memory that she challenged Maravelias, “you can replay it”. (T223)
Maravelias later argued that if she could “so extraordinarily contort and
misremember something that she observed five minutes prior, imagine, just
imagine [her stalking accusations from up to] three years prior”. (T343:1-9)
4
Appellant has uploaded the video to YouTube, currently in private (unlisted) mode, for this
Court to access: https://youtu.be/EAawoOcFGVg
25
The telling Turkey Trot video elicited another indication of the
teenage-girl-Plaintiff’s capacity for creative, reconstructive memory – the
component of her falsity not begotten of willful lying. She was convicted
Maravelias had mentioned somewhere in the record he “had a friend” take
the 2013 Turkey-Trot video, which his sister incidentally happened to take.
(T218,219) Maravelias later reminded he’d never said anything like this
anywhere, despite Christina DePamphilis’s steadfast certainty otherwise.
(T341,342) That Christina DePamphilis testified falsely to a highly specific
representation while firmly convicted of the truth thereof will be undeniable
when she inevitably fails in her opposing brief to cite where in the
“transcripts” Maravelias said that which she had a vivid though false
memory of him saying. (T219)
Christina DePamphilis also testified she “has suspicions” Maravelias

“flew a remote-controlled surveillance drone” to her “bedroom window”
during the stalking order. (T171) Her basis was that, one night, she “was
seeing lights in [her] window” around “12:30” (T171), but when she
“would open the window … nothing was there” (T172). She believed since
Maravelias “was the valedictorian” and “went to an Ivy League school” he
could have been “smart” enough to do this (T173,175), although she never
saw any such flying device (T181). She also checked to ensure Maravelias
had not installed “very microscopic” “hidden cameras” in her bedroom.
(T194)
26
Motion to Extend Allegation #1: Maravelias Was Mean on 11/2/17 in
Replying to Attorney Brown’s Threatening Letter
DePamphilis’s Motion to Extend the stalking order accurately alleged
Maravelias had made offensive communications to third-parties. (A72) In
replying to an outrageous legal threat by David DePamphilis, Maravelias
had responded to Attorney Brown that Christina was an “ugly and
disreputable whore”. (T409;A48,89) Deterring a lawsuit, Maravelias
asserted his right to publicize Christina’s social-media-documented acts of
lawlessness, which could “ruin her academic and professional career”, if
David sued him. Despite DePamphilis further “pursuing Maravelias
legally”, Maravelias never followed-through with the lawful retaliation he
mentioned only when provoked by DePamphilis’s threatening letter.
(T415:7)
Motion to Extend Allegation #2: Maravelias Wrote a Private Email to His

Own WHS Teacher
As mentioned supra, Maravelias emailed on 12/10/17 his close mentor,
Mrs. Smith, who runs the NHS chapter. (A91) Maravelias CC’d three
others of his close mentors; he did not communicate to the Plaintiff, nor to
any of her friends or family members. (A91)
Motion to Extend Allegation #3: Maravelias Had Communications with the

Author of a Nasty Letter Sent to David DePamphilis in March 2017
Maravelias did not write the nasty March 2017 letter but “knew about
it”. (T393;A17) A “girl from Windham” wrote David DePamphilis the
letter, purporting to be a “friend” of Maravelias. (A76) The author attacked
David DePamphilis for legally abusing Maravelias. (A76) In Maravelias’s
impolite 11/2/17 response letter to Attorney Brown, Maravelias corrected
27
DePamphilis’s false speculation that Maravelias was the author of the
March 2017 letter:
“Unlike the author, I had known in March that David’s wild daughter had
already been fucked raw by the man in secret at David’s beach house in February,
days before her ‘confirmation mass’ at my church.” (A88)
In responding to Attorney Brown’s vexatious legal threat, Maravelias’s

words were unwise and regrettably blunt. However, they were both truthful
and notable in proving Maravelias did not write the nasty March letter – the
author of which forewarned of a potential sexual relationship as an
overarching theme of her letter. I.e., the author was ignorant of what was
happening between DePamphilis’s barely-16-year-old daughter and her
college-age boyfriend. If Maravelias had written this letter, surely he would
have alluded to this salacious gossip of which the author was apparently
unaware.
Maravelias’s Self-Defense in the Extension Hearing

Maravelias elucidated that none the motion-to-extend accusations, true
or false, pertained to “stalking” the Plaintiff. (T476) Maravelias testified a
confirmed trial-court-level clerical error had given him the false impression
the stalking order had been vacated, during which time Maravelias did not
contact the Plaintiff whatsoever. (T475) Maravelias had filed two trial-court
motions: 1) a wrongly-denied motion for discovery (A110), and 2) a motion
to dismiss (A107), given the original order’s basis upon an unnoticed
allegation, arguing that due-process is again violated by extending such an
order. Judge Coughlin utterly ignored the motion to dismiss; he never
28
issued a ruling on it whatsoever, nor addressed its legal arguments
anywhere. (A49-50)
Judge John J. Coughlin’s Orders

On 6/15/18, after hearing all the facts propounded hereinabove, John
Coughlin composed an Order extending the stalking order. The full libel-
text of Judge Coughlin’s emetic judicial terrorism is appended. (A2) Then
DePamphilis motioned for extremified injunctive terms against Maravelias
on 7/2/18. (A152) John Coughlin predictably scribbled-off his seven-word
approval. (A7) Ostensibly insulted by Maravelias’s ten-page Motion for
Reconsideration, John Coughlin scribbled “denied” and retired on 9/5/18.
(A3)
29
SUMMARY OF ARGUMENT
Where the continued stalking order is birthed of unconstitutional law,

abuse of discretion, revisionist memory, criminal falsification, violation of
due process, and judicial misconduct (A115), Judge Coughlin’s 2018
Orders should be vacated, and the entire original stalking order
retroactively annulled ab initio.
Maravelias should get his freedom and reputation back. Between the
parties, finally, should be peace.
30
ARGUMENT
I. RSA 633:3-A, III-C. IS UNCONSTITUTIONAL

FACIALLY AND AS-APPLIED
Questions of constitutional law receive de novo review. State v.

MacElman, 154 N.H. 304,307 (2006).
A. The “Safety and Well-Being” Language of 633:3-a, III-c. is

Overbroad
RSA 633:3-a provides at III-c.,
“Any order … may be extended by order of the court upon a

motion by the plaintiff, showing good cause, with notice to the
defendant, for one year after the expiration of the first order and
thereafter each extension may be for up to 5 years, upon the request of
the plaintiff and at the discretion of the court. The court shall review
the order, and each renewal thereof and shall grant such relief as may
be necessary to provide for the safety and well-being of the plaintiff.
…”
Here, the statute can be reasonably interpreted to permit extension upon
a showing of “good-cause” that a plaintiff’s “well-being” primarily would
be jeopardized without extending the protective order, even if concern for
“safety” is minimal. Any other reading is impossibly tautological, as a
threat to an individual’s “safety” is also a threat to their “well-being”. The
31
legislature could have omitted the word “well-being”, but intentionally
appended it after “safety”.
Neither RSA 633:3-a nor RSA 173-B define the term “well-being”;
thus, dictionary reference is appropriate. See Doyle v. Comm’r, N.H. Dep’t.
of Resources & Economic Dev., 163 N.H. 215,221 (2012). On review, this
Court ascribes “the plain and ordinary meaning to regulatory text”. Kenison
v. Dubois, 152 N.H. 448,451,879 A.2d 1161 (2005). The Oxford English
Dictionary defines “well-being” as “the state of being comfortable, healthy
or happy.”5
Insofar as the trial court found Maravelias’s specifics acts of speech

jeopardized the comfort, health, or happiness (“well-being”) or “safety” of
the Plaintiff and therefore granted the extension, the statute is
unconstitutionally overbroad in violation of the First and Fourteenth
Amendments to the federal constitution and Part I, Article 22 of the state
constitution, as-applied and, concerning the “fundamental right” of free
speech, facially. See MacElman at 307.
i. The Statute Regulates and Burdens Protected Speech
By operation of the “safety and well-being” language of 633:3-a, III-c.,

the trial court extended a stalking order on the basis of Maravelias’s acts of
speech. Since civil stalking orders criminalize possession of firearms and
prohibit defendants from communicating directly or indirectly to plaintiffs,
the statute restricts constitutional rights. Further, the stalking statute
5
https://en.oxforddictionaries.com/definition/us/well-being
32
“implicates the fundamental right to freedom of movement”. State v.
Porelle, 149 N.H. 420 (2003). “It hardly bears mentioning that a restraining
order restrains one’s liberty ... from a number of legal activities.” McCarthy
v. Wheeler, 152 N.H. 643,645 (2005). In Maravelias’s case, the extended
stalking order criminalizes appearing at his own and his sister’s high
school, as well as his legitimate automobile passage through one of only
two roads connecting his Windham neighborhood to the outer world.
Though not a criminal prohibition, the stalking statute undeniably burdened
the exercise of Maravelias’s lawful speech through a civil restraining order
extension resultant of his lawful speech, as it does in general for all such
defendants.
The ambit of the federal First Amendment surpasses categorical

prohibitions and extends to such “statutes attempting to restrict or burden
the exercise of First Amendment rights.” Broadrick v. Oklahoma, 413 U.S.
601 (1973). Cf. State v. Brobst, 151 N.H. A.2d 1253 (2004) at 422-425,
applying the same under the state constitution. In New Hampshire, “a
statute is void for overbreadth if it attempts to control conduct by means
which invade areas of protected freedom.” MacElman at 310. In the context
of lawful-speech-related stalking order extension, 633:3-a, III-c. burdens
the exercise of protected freedoms. Cf. Simon & Schuster, Inc. v. Members
of N.Y. State Crime Victims Bd., 502 U.S. 105 (1991), invalidating a law
which imposed merely a “financial disincentive” to certain speech, let alone
a stalking order as incapacitating as the one against Maravelias.
Here, the regulated speech is protected. Since constitutionally

protected, non-threatening speech to third-parties permits extension under
33
the statute, the statute is overbroad. Facially, the overbroad language of the
statute is not narrowly tailored to serve the government’s interest in
effecting the cessation of stalking, discussed infra. As applied, Maravelias’s
three acts cited by the trial court and noticed in Plaintiff’s Motion to Extend
are protected, legitimate, lawful speech.
1. Maravelias’s 12/10/17 Email to Mrs. Smith is Protected

Speech
An email to a public employee expressing a viewpoint that alleged

criminal actions disqualify a person from said public employee’s honor
society does not fall into any of the recognized exceptions to
constitutionally protected speech. “As a general principle, the First
Amendment bars the government from dictating what we see or read or
speak or hear.” Ashcroft v. Free Speech Coal. 535 U.S. 234, 245 (2002);
see also State v. Zidel, 156 N.H. 684, 686 (2008). Maravelias’s email –
specifically requesting that it not be shared with the Plaintiff – does not fall
into any recognized First-Amendment exception, such as “violence”-
incitation or “obscenity”. Ashcroft at 245; Zidel at 686.
2. Maravelias’s 11/2/2017 Response to Attorney Brown is

Protected Speech
Maravelias’s private responsive communication to Attorney Brown

advancing a deterrent legal counterthreat does not constitute any form of
unprotected speech. While Maravelias incorporated a few scattered
profanities, this does not come close to “obscene” speech. Cf. Cohen v.
California, 403 U.S. 15 (1971), holding the phrase “fuck the draft”
displayed inside a courthouse as protected. “A function of free speech
34
under our system of government is to invite dispute. It may indeed best
serve its high purpose when it induces a condition of unrest, creates
dissatisfaction with conditions as they are, or even stirs people to anger.”
Terminiello v. City of Chicago, 337 U.S. 1,4 (1949).
3. The March 2017 Nasty Letter to David DePamphilis
Maravelias did not write the letter (See supra). It was not sent to the
Plaintiff. (T14) Maravelias’s private verbal communications with the
letter’s author are protected. Further, the letter itself does not contain any
obscene content nor fighting-words; it is protected speech regardless of
authorship. The US Supreme Court has noted that “citizens must tolerate
insulting, and even outrageous, speech in order to provide adequate
‘breathing space’ to the freedoms protected by the First Amendment.”
Boos v. Berry, 485 U.S. 312,322 (1988).
ii. The Statute Triggers Strict Scrutiny
“The amount of burden on speech needed to trigger First Amendment

scrutiny as a threshold matter is minimal.” American Legion Post 7 of
Durham, N.C. v. City of Durham, 239 F.3d 601,607 (4th Cir. 2001). Here,
Maravelias’s constitutional rights are manifoldly restricted because of
lawful speech. This far-exceeds the threshold of triggering constitutional
scrutiny. As the statute implicates “fundamental rights”, intermediate
scrutiny in-the-least applies. Further, strict scrutiny is the only valid form
review here, since 633:3-a, III-c. is content-based, discriminatory against a
disfavored group, and not viewpoint-neutral.
35
1. The Regulation is Content-Based
“The First Amendment requires heightened scrutiny whenever the

government creates ‘a regulation of speech because of disagreement with
the message it conveys.’” Sorrell v. IMS Health Inc., 131 S. Ct. 2664
(2011). “The First Amendment stands against attempts to disfavor certain
subjects or viewpoints or to distinguish among different speakers, which
may be a means to control content.” Citizens United v. Fed. Election
Comm’n, 130 S. Ct. 882,883 (2010).
Facially, that the statute invites courts to evaluate whether a

defendant’s public or third-party speech-acts undermine a plaintiff’s
“happiness” or “comfort” (“well-being”), and is therefore content-based, is
plain. Here, if Maravelias had responded to Attorney Brown on 11/2/17
saying, “in parting ways, I respect David’s daughter”, doubtlessly the
response would not have been used against Maravelias. Likewise, if
Maravelias’s 12/10/17 email to Mrs. Smith had been a generic salutation
email mentioning, “I have some legal problems with Ms. DePamphilis, but
she’s still a great person”, then the ridiculous accusation of “following-up”
on a “threat” within WPD’s baseless charge could not have existed (A37);
the email would be irrelevant to extension.
Therefore, the regulation is content-based, triggering strict scrutiny.
2. The Regulation Isolates Disfavored Speakers and is Not

Viewpoint-Neutral
36
The regulation’s lack of content-neutrality closely resembles its lack of
viewpoint-neutrality. Whereas Christina DePamphilis’s obscene, incitative
(unprotected6) middle-finger post (A11) directed to Maravelias entitled
Maravelias to no recourse under the statute, the same statute permitted
Maravelias’s non-incitative-nor-obscene (protected) speech in public or to
third-parties to motivate stalking order extension. Moreover, the statute’s
viewpoint-discrimination afflicts a certain group (stalking order defendants)
doubtlessly “disfavored” by society. See Citizens United, ibid., applying
strict-scrutiny review to laws that “disfavors specific speakers”. See also
Turner Broadcasting System, Inc. v. FCC, 512 U.S. 622,658,114 S.Ct.
2445, 129 L.Ed.2d 497 (1994). “Speaker-based laws demand strict scrutiny
when they reflect the Government’s ... aversion to what the disfavored
speakers have to say”. Id.
3. Forum Analysis
Maravelias’s 12/10/17 communication to Mrs. Smith’s public high-

school email account commands further protection as speech within a
“nonpublic forum” or, arguably, “limited public forum”. See Pleasant
Grove City v. Summum, 555 U.S. 460 129 S.Ct. 1125,172 L.Ed.2d 853
(2009). Even in a nonpublic forum, lack of viewpoint-neutrality triggers
strict scrutiny.
6
Cf. O'Brien v. Borowski, 461 Mass. 415 (2012). “Raising the middle finger may constitute
fighting words or a true threat.” Id at 429.
37
Because the “State Constitution provides at least as much protection as
the Federal Constitution”, strict-scrutiny-review is appropriate under both
corpora of law. State v. Allard, 148 N.H. 702 A.2d 506,510 (2002).
iii. The Statute Fails Even Intermediate Scrutiny
Even content-neutral regulations subject to intermediate scrutiny must

be “narrowly tailored to serve a significant governmental interest, and ...
leave open ample alternative channels for communication of the
information”. Doe v. Harris, 772 F.3d 563 (2014), citing Ward v. Rock
Against Racism, 491 U.S. 791 (1989). A statute fails intermediate scrutiny
if burdening “substantially more speech than is necessary to further the
government’s legitimate interests”. Ward at 799. Applying strict scrutiny,
the governmental interest advanced must be not only “significant”, but
“compelling”.
1. Tailoring Analysis
Where the statute’s standard for stalking order extension atrociously

exceeds the government’s presumed interest in the “cessation of stalking”
(See RSA 633:3-a, III-a.), it is overinclusively not-narrowly-tailored.
Although arguably intending to regulate unprotected (e.g., threatening)
speech, “the overbreadth doctrine prohibits the Government from banning
unprotected speech if a substantial amount of protected speech is prohibited
or chilled in the process.” Ashcroft at 237. See also Doyle at 221,
invalidating laws as facially overbroad under Part I, Article 22 of the State
Constitution where “a substantial number of its applications are
unconstitutional, judged in relation to the [law’s] plainly legitimate sweep”.
38
RSA 633:3-a, III-c. permits trial courts to extend any stalking order
where a plaintiff testifies she’d feel “uncomfortable” or “unhappy”
otherwise, since this alone shows by “good-cause” that an extension would
“provide for” her “state of being comfortable, happy, or healthy” (the
definition of “well-being”, supra). The language renders the facts of the
case – a defendant’s history of stalking, the level of expected unlawful
future behavior, etc. – completely irrelevant where a plaintiff’s mere
“comfort” or “happiness” is served by granting extension.
The draconian statute disowns any realistic model of human

psychology or sociology, in which one person’s lawful third-party-or-
public expressions might incidentally distress an individual holding
different views – even though the suppression of minor annoyance alone
triggers the dictionary definition of serving “well-being”. Negative social
experiences disfavor well-being. Rook, K.S. (1984)7 Seeing the word “no”
alone triggers unhealthy, uncomfortable, and unhappy neurotransmitters
and hormones.8
The statute burdens a woefully latitudinous fetch of protected speech

far beyond that necessary to promote “a cessation of stalking”. A potential
rebuttal pits the controlling context of “safety” and the generic context of
the statute against “well-being” as altogether constituting a legal standard
for extension higher than prevention of minor annoyance. But, such an
interpretation is tautologically illogical, since the legislature added the word
7
http://psycnet.apa.org/record/1984-25835-001
8
Newberg and Waldman, 2012 (https://www.psychologytoday.com/us/blog/words-can-
change-your-brain/201208/the-most-dangerous-word-in-the-world)
39
“well-being” and, thus, intently did not stop at “safety”. Regardless, such a
reading would separately demonstrate the statute’s unacceptable vagueness,
discussed infra.
Separately, reasonable alternatives to the “safety and well-being”

language which would equally advance the counter-stalking governmental-
interest evince the statute’s lack of narrow-tailoring. See Rutan v.
Republican Party, 497 U.S. 62,74 (1990). The statute could alternatively
permit stalking order extension upon a good-cause-showing such would
provide for a plaintiff’s “safety” only, or, better-yet, “as is necessary to
bring about a cessation of” (or simply “prevent”) “stalking”, to mirror the
language in subsection III-a. No possible circumstance currently allowing
extension would fail this more-narrowly-tailored test wherein the
governmental-interest involved is truly one of counter-stalking, rather than
of silencing annoying speech and effectively criminalizing a defendant’s
self-defensive speech itself caused by the stalking order, as in Maravelias’s
case. Such a narrowly-tailored alternative would not amount to the
necessity of re-proving new acts of stalking or showing protective-order
non-compliance to obtain extension, since the “good-cause” standard
already requires that the trial court consider the underlying circumstantial
provenance of the original stalking-order. See MacPherson v. Weiner, 158
N.H. 6,10 (2008).
Rather, RSA 633:3-a, III-c. surreptitiously supplants the original-

stalking-order legal standard (III-a) with a patently absurd legal standard
catering to “well-being” (III-c.), unrelated to the narrow counter-stalking
governmental-interest, when extension is concerned. Naturally, therefore,
40
the statute is also underinclusively not-narrowly-tailored. Statutes failing to
restrict an amount of harmful-to-the-governmental-interest speech
comparable to the amount restricted are not narrowly-tailored. See
Showtime Entertainment, LLC v. Town of Mendon, 769 F.3d 61,73 (1st Cir.
2014); Florida Star v. B.J.F., 491 U.S. 524,540 (1989). Here, if “safety and
well-being” actually is otherwise narrowly-tailored to serve the
governmental-interest, then so should the initial-stalking-order-issuance
legal standard of III-a adopt the lower good-cause-provision-for-“safety and
well-being” standard, rather than the higher-burden, more-stringent
standard currently within subsection III-a positively requiring “stalking”
and granting relief only as necessary “to bring about a cessation” thereof.
Instead, the illogical “safety and well-being” conundrum at III-c.

radically discriminates between groups of potentially indifferentiable
stalking order defendants. III-c. assaults the liberty-interests of extant
defendants through a much-lower “well-being” legal standard, while III-a
coddles the liberty-interests of new defendants, even though the liberty-
restricting nature of the one-year injunction-at-hand remains identical both
at III-a and III-c. Though civil, this villainously contravenes the precepts of
double-jeopardy. In fact, III-c. permits further extensions “for up to 5
years”, despite imposing a far lower legal standard than III-a!
In failing to be narrowly-tailored, the statute also discriminates against

stalking victims. Why should the State expect legitimate stalking victims
newly-seeking protective injunction to sustain a much higher burden than
those already granted a stalking order – for the same one-year protection? If
any difference in legal standard is appropriate between the two groups,
41
equity requires the reverse. This concern is exacerbated by New Hampshire
trial courts’ “extending” stalking orders by III-c. – lawfully or unlawfully –
months after their expiration. See Stewart v. Murdock, (2015-0448). The
overbroad language at III-c. creates an inequitable advantage for prior-
order-wielding plaintiffs and an indefensible disadvantage for prior-order-
subject defendants.
2. The Governmental Interest Served is not “Compelling”
The underinclusiveness aforementioned casts doubt on whether the

statute’s “proffered interest is truly forwarded by the regulation, or is in fact
substantial enough to warrant such regulation.” Showtime Entertainment,
LLC, supra. That is, if the “safety and well-being” standard were narrowly-
tailored to the interest, the interest would be compelling enough to warrant
usage of the same legal standard for original-stalking-order-issuance at
subsection III-a. This suggests the governmental-interest served is not
“compelling”, forming separate causal grounds for failure of strict-scrutiny.
Furthermore, wherever the “well-being” language could possibly
remain narrowly-tailored to the governmental-interest, such interest could
never be “significant”, and the statute would fail intermediate scrutiny
regardless. The presumed counter-stalking governmental-interest
motivating 633:3-a might be “significant”, but the obsequiously-catering-
to-the-epicurean-“comfort”-and-“happiness”-of-a-plaintiff interest (the
only interest to which “well-being” is narrowly-tailored) surely is not.
42
3. Alternative Channels
Nor does the legal standard at III-c. appropriate any imaginable

alternative manner a defendant may dare disagree with a plaintiff’s stalking
order within his public-or-third-party communications without suffering
greater likelihood of stalking order extension, where the plaintiff’s
“comfort” should be disturbed by knowing the defendant’s mere contrary
opinion.
B. The “Safety and Well-Being” Language of 633:3-a, III-c. is

Impermissibly Vague
“A statute can be impermissibly vague for either of two independent

reasons. First, if it fails to provide people of ordinary intelligence a
reasonable opportunity to understand what conduct it prohibits. Second, if it
authorizes or even encourages arbitrary and discriminatory enforcement.”
Hill v. Colorado, 530 U.S. 703,732 (2000). Here, the language of RSA
633:3-a, III-c. is unintelligible and so loosely constrained that arbitrary,
discriminatory enforcement thereof is inevitable. Not only is the term
“well-being” too vague, but also the extent to which the preceding term
“safety” narrows or qualifies “well-being”.
i. Semantic Vagueness
As applied, Paul Maravelias lacks the intelligence to discern which

behaviors are reasonably expected to minimize chances of order extension.
Whether he is simply to obey the order, avoiding/ignoring the Plaintiff as
43
he has, or must somehow appease her psychological “well-being” by tacitly
congratulating her felony-perjury-fueled legal abuse, is unclear.
Facially, the language creates even worse problems for trial courts. One
judge might think a “well-being” order ridiculous and far in-excess-of the
legislative counter-stalking intent, calibrating his or her judgements to the
statute’s broad “safety” context, even applying ejusdem generis to constrain
“well-being” thereby. However, another judge might reject this
interpretation, “safety and well-being” not being a list, and adopt the plain
meaning of the word “well-being” as this Court does on review.
ii. Syntactic Vagueness
The statute is fraught with meaningful syntactic ambiguity between the

co-possible constructions “shall grant such relief as may be necessary to
provide for the (safety and well-being)” and “… relief as may be necessary
to provide for the safety, and (relief as may be necessary to provide for the)
well-being”. The former interpretation begets tautology, the latter
overbroad plaintiff-sycophancy. This tremendous interpretation-dependent
leeway afforded trial courts in applying subsection III-c. sponsors
capricious, arbitrary extensions as perversely fact-amnestic as John
Coughlin’s against Maravelias in this case.
The Old Man’s 2003 death was not of natural causes. From on-high he
beheld the land before him. He witnessed not a frugal New England
citizenry of individualist “Live Free or Die” self-reliance, but rather the
44
infantilistic, progressivist corruption of all for which he stood. He glanced
farther to Boston and envied the dutiful balance of liberty-interest in
Massachusettensian law – embarrassingly, unlike its tyrannical
Novahantonian analog. He contemplated M.G.L. 265 §43, which sensibly
necessitates an actual “threat with the intent to place the person in imminent
fear of death or bodily injury” for “stalking”. Betrayed by his own people,
he then beheld M.G.L. 258E §3(d): the analogous civil “harassment” order
extension standard; for civil “stalking” orders do not exist. The
Commonwealth irrationally-abdicates-not its legitimate counter-harassment
governmental-interest, nor embellishes with flowery “well-being”
sophistry. Amazingly, it permits “the court [extend] the [harassment] order
… as it deems necessary to protect the plaintiff from harassment.” Id. The
more-proximate golden dome at Concord then robbed the Old Man’s gaze.
The insidious travesty of RSA 633:3-a, III-c. agonized his senile
consciousness. He threw himself down, ending his own life in ashamed
despair: for “death is not the worst of evils”.9
9
Upon extensive individual research, Appellant cannot find one single other state of
comparable protective-order-procedure which magically discards the initial-issuance-standard for
something pointlessly different for extension.
45
II. WHERE CHRISTINA DEPAMPHILIS INCITATIVELY
BULLIED PAUL MARAVELIAS ON HER SOCIAL
MEDIA AFTER LAUGHIBLY LYING ABOUT HAVING
“FEAR” OF HIM, EVIDENCE SUPPORTING THE
TRIAL COURT’S FINDING OF “REASONABLE FEAR”
WAS INSUFFICIENT
Fortunately for him, the Old Man never lived to see the day where a
New Hampshire trial court would continue criminalizing a young man’s
firearm-ownership because the 17-year-old girl who incitatively targeted
and bullied said citizen with her and her boyfriend’s middle-fingers on
social media claims to “fear” him. Judge John Coughlin’s peppering-in a
finding of “reasonable fear” (A2) was gratuitous under subsection III-c.,
obviously rooted upon insufficient evidence, and further indicative of his
biased, dismissive judicial misconduct against Maravelias, days before
retirement.
III. THE TRIAL COURT COMMITTED AN

UNSUSTAINABLE EXERCISE OF DISCRETION IN
GRANTING THE STALKING ORDER EXTENSION
A. Good Cause for Stalking Order Extension was Not Shown by a

Preponderance of Evidence
The trial court’s order is risibly ludicrous. This stalking order has
become an absurd and pointless self-fulfilling prophecy if Maravelias’s
46
non-Plaintiff-directed speech-acts decrying the injustice of the “staking”
order themselves cause it to be extended.
Analytically, the logic of the trial court’s order is as follows:
Premise #1 Paul Maravelias, believing himself falsely accused of

stalking and possessing an audio recording disproving the
accusations sustaining our original stalking order, dared
communicate privately to third-parties, not Christina
DePamphilis, about the injustice he believed we did against
him.
Premise #2 These private third-party communications of Paul

Maravelias protesting his own innocence somehow caused
Christina DePamphilis to have “reasonable fear”, even
though she only even found-out about them by-accident,
and even though she admitted to middle-fingering
Maravelias with her new boyfriend on public social media
to assert her “independency [sic]” (T74:14,233:8) to
Maravelias.
Premise #3 Despite Maravelias’s vociferous asseverations to be

repulsed by and disinterested in Christina DePamphilis,
including his inability to even physically recognize her in
the court parking lot and intuition that “she deserves to be
[his] girlfriend like Osama bin Laden deserves to be mayor
of Manhattan” (T357:14-16), and despite her own
attorney’s calling Maravelias’s a “previous obsession”
47
(A36), we are justified to fantasize Maravelias has a
“continuing” “obsession” “to this day” (A2) with
DePamphilis.
Premise #4 We should ignore Maravelias’s evidence of Christina

DePamphilis’s extreme falsity, such as the Turkey Trot
video, and our in-person comments to Maravelias were lies.
(See infra)
Conclusion Therefore, there is “good cause” to extend the stalking

protective order. Further, we include gratuitous, amplified
language about a “perverse obsession”, “sole purpose of
harassing/stalking” and “reasonable fear” in our order,
because pro se Paul Maravelias knew the law, dared hold
us accountable thereto, and generically pisses us off.
Premises 2-4 above are false. Any sensible adult having read the trial
court’s order, knowing the facts of this case, would find it illogical,
unsustainable, and simply outrageous. Furthermore:
• Christina DePamphilis’s relied-upon, obsessively-collected 1.5-

year-old photographs of Maravelias’s private home
bedroom/office pictured a pre-stalking-order state, since
Maravelias was living away at college immediately after
December 2016. (T447:3-14,455:7-10;A46-47)
• After Maravelias exposed her innumerable inconsistencies,
willful lies, and false memory, the trial court erred to attribute a
48
scintilla of credibility to Christina DePamphilis’s
representations, such as relying upon her self-serving assertion
she “fears” Maravelias. (A44)
• Upon Maravelias’s showing DePamphilis had submitted
countless false-or-otherwise-unfruitful police reports trying to
get him arrested mid-order (T483,A20), the trial court insensibly
failed to dismiss the obvious legal-harassment-purposed
“stalking” order against Maravelias.
• Given the early-May 2018 phenomenon where Maravelias
wrongly believed the order was annulled and went for a peaceful
victory-“walk” instead of contacting the Plaintiff whatsoever
(T357:2-5,303:17-22), only an unscrupulous tyrant like John
Coughlin would later libel him an “obsessed” “stalker” causing
“reasonable fear”.
• If the upheld-extension in MacPherson v. Weiner, ibid., was “a
close case” even where the defendant had actually violated the
stalking order and committed far-less-questionable original acts
of “stalking” (not asking-out a girl once, thereafter eternally
ignoring her), then the instant case miserably fails to even
approach warranting extension.
B. The Trial Court Made Honest Verbal Comments at Trial Proving

its Subsequent Written Order was Shamefully Disingenuous
Judge Coughlin revealed his honest impressions of Maravelias toward

the end of the Hearing, commenting to Maravelias:
49
“Well, let me ask you, is there any potential that this case could settle?
Because it looked like you’re willing to stay away and not have any contact
and otherwise comply with what is the order.” (T479)
“it appears that you do not want to have any contact and that you’re going
to do that on a voluntary basis.” (T479)
“you indicated that, you don’t want to have anything to do with the family,
you don’t want to have anything to do with this young woman, and you just
want to be left alone and you’re going to leave her alone. At least that’s my
impression” (T480)
Having listened to Maravelias testify, any rational adult would endorse

Judge Coughlin’s candid Billy-Joel-esque characterization of Maravelias’s
pacifist “leave-me-alone” outlook concerning the Plaintiff and her family.
However, seven mere days later in his demented 6/15/18 order, John
Coughlin took to a vomitous display of self-contradicting libel, bullshitting
that Maravelias has a “strange, perverse and unhealthy obsession” with the
Plaintiff “which … continues to this day”. (A2)
Additional self-contradictions aliunde in the transcript (T58:7-9,73:13-

19,308:12-18,468:19-20) are likewise indicative that John Coughlin’s
6/15/18 libelous abomination extension order was about as genuine as the
1919 World Series.
50
IV. THE TRIAL COURT VIOLATED MARAVELIAS’S DUE
PROCESS RIGHTS
A. Reversal is the Necessary Remedy to the Trial Court’s Blatant

Violation of the “30 Days” Hearing Requirement of 633:3-a, III-
c.
Given the trial court’s illegal abrogation of Maravelias’s due-process

“right” “to a hearing on the extension of any order under this paragraph to
be held within 30 days of the extension” as mandated by 633:3-a, III-c.., the
subsequent stalking order extension must inescapably be reversed. This
Court was abundantly clear in McCarthy v. Wheeler, 152 N.H. 643 (2005)
that dismissal of domestic violence petitions is the required remedy when
trial courts fail to obey statutory time-limit requirements. Such
requirements are compellingly necessary to provide defendants a baseline
level of due-process fairness where their basic liberties are at stake.
McCarthy bears striking factual similarity hereto and is doubtlessly

dispositive. Firstly, it was a domestic violence order reversed on appeal,
certainly more serious than a “stalking” order here where Defendant invited
Plaintiff and her mommy on a date while offering her a fancy car, got
rejected, and then never spoke to her ever again. Secondly, the McCarthy
trial court scheduled the first excess-of-30-day-requirement hearing for
9/16/04, 4 days beyond the 30-days-post-10/13/04-petition date. Here,
Maravelias’s rights were repudiated by the stalking order for 9 days after
2/11/18, the date 30-days post-1/12/18-extension.
51
“Where the legislature, out of liberty interest concerns, has mandated
time limits for holding hearings, we have held that personal jurisdiction
over a defendant is lost, absent waiver, if the case is not heard within the
statutory period.” Id., quoting Appeal of Martino, 138 N.H. 612 (1994).
The stalking statute is functionally identical to the domestic violence statute
in stipulating the court “shall” obey the time-limit. “Since these hearings
are designed to protect a defendant’s substantive rights, the court’s failure
to hold them must result in dismissal of the domestic violence petition.”
McCarthy, ibid. Accordingly, this Court must reverse the stalking order
extension.
B. The Trial Court Illegally Limited Defendant’s Guaranteed Right

to Videotape the Entire Public Hearing
The trial court illegally limited Maravelias’s right to videotape the

entire proceeding. (T9:1-3;A48) After Plaintiff objected to Maravelias’s
perfunctory videorecording-notice-motion, the trial court violated Circuit
Court Rule 1.4 by formally prohibiting Maravelias from including the
Plaintiff in his videotape of her own public court hearing. (A48,60)
Maravelias objected contemporaneously (T5-7) and post-facto through
pleadings (A48,60-64), identifying the further-Plaintiff’s-lying-enabling
prejudicial nature of letting her testify off-camera. Thus, reversal is the
appropriate remedy, exactly as Maravelias presciently apprehended at trial.
(T484)
52
C. The Trial Court Violated the Statutory Advance Notice
Requirement and/or Other Substantive Due Process Rights
i. “Obsession” and the 6/8/18 Surprise-Photographs-Exhibit
The trial court erred by relying upon Plaintiff’s unnoticed surprise-

photographs with which she ambushed Maravelias on the hearing’s last-day
to advance an unnoticed allegation of “obsession”, in violation of 173-B:3,
I. (A2), applicable to stalking cases. Both that allegation and the
Maravelias-privacy-assaulting bedroom-photographs themselves were
noticed nowhere in Plaintiff’s extension motion. Further, the absurd
“obsession” allegation should have been estopped. (A67-70)
ii. Ignored Motion to Dismiss
Maravelias invites this Honorable Court to ignore this paragraph if

disagreeing the “good-cause” standard could permit a trial court to refuse to
extend a stalking order because of a subsequent showing it was predicated
on totally-unnoticed, extra-petition allegations, even where said order won
this Court’s obligatory affirmation on the technicality-grounds of
insufficient issue preservation. Maravelias here repeats the facts and
arguments (T487-489) his ignored 3/29/18 Motion to Dismiss (A107)
rehearsed.
53
V. JOHN J. COUGHLIN, THE TRIAL COURT JUDGE,
COMMITTED A RAMPANT SPREE OF BIASED AND
UNJUST CONDUCT AGAINST MARAVELIAS, BEING
LARGELY UNACCOUNTABLE TO AUTHORITY,
SINCE HE RETIRED DAYS LATER
Taken altogether, Judge Coughlin’s judicial acts from both 2018

Maravelias-DePamphilis cases reveal a consistent pattern of bias and
prejudice. Put lightly, no remotely honest judge would order a stalking-
petitioner to pay his opponent’s itemized expense incurred and dated before
said petition was even filed and then utterly ignore the error after said
petitioner’s motion for reconsideration complained thereof (referencing
2018-0376). Lacking space here to analyze Judge Coughlin’s abounding
even-worse instant-case misconduct, Appellant Maravelias requests this
Court review his recent trial-court-level motion explicating the noted
disturbing phenomena. (A115)
This Court should reverse, as Maravelias was obviously not given a fair
shot.
VI. THE TRIAL COURT ERRED IN GRANTING

PLAINTIFF’S POST-TRIAL MOTION FOR EXTENDED
PROTECTIVE ORDERS
On 7/2/18, Plaintiff motioned for vastly expanded “protective” orders

against Maravelias. (A152) She hoped to criminalize Maravelias’s mere
possessing her “social media” artifacts wherein she bullied and harassed
54
Maravelias, which indicated her malicious prosecution and bold lack of
“fear” (A154). Maravelias extensively litigated against this outrageous
motion in responsive pleadings (A156), asserting the requested terms’
unconstitutionality (A161) and illegality (A182).
In predictable fashion, Judge John J. Coughlin, the natural-rights-

calpestating rebel and effeminate, sequacious houseboy-servant to daddy
David’s vindictive lust, scribbled-off his approval. Spineless Coughlin
might as well have prepended his Order, “Don DePamphilis, I am honored
and grateful that you have invited me to your daughter’s restraining order
hearing. I will extend it and grant any further requests. Don DePamphilis, I
pledge my ever-ending loyalty.”
John Coughlin pleasured himself with a last-laugh of recalcitrant

judicial abuse against Maravelias by not even granting Plaintiff’s
concessively amended, slightly-less-overbroad terms proposed in her
responsive 7/12/18 pleading (A180,8). Rather, Judge Coughlin ignored
Maravelias’s weighty responsive pleadings and affirmed motu proprio the
irrationally draconian terms in Plaintiff’s original 7/2/18 motion, which
even she was willing to partially ameliorate in light of Maravelias’s
subsequent counterarguments. (A7)
Maravelias’s meritorious legal counterarguments in these pleadings

endured a familiar fate: defenestrated into the wind, ignored insouciantly by
the trial court. Unsurprisingly, Judge Coughlin did not cite a word of legal
authority for his final judicial act against Maravelias. (A6) The temerarious
tyrant did not whim to betray the slightest indication he’d even read
55
Maravelias’s counter-pleadings at all, wherein Maravelias hopelessly
attempted to hold Judge Coughlin accountable to written laws and
constitutions guaranteeing certain rights.
Rather, John Coughlin whored himself on the exhilarating thrill of his

trademark “denied” and “granted” go-to scribblings (A3,4,5,6), knowing
himself sacrosanctly above the law, unobliged to offer a single further word
of justification for ablating Maravelias’s right to possess public court
exhibits profitable to his defense. After all, at that time, September 5th was
just days away. That plump post-retirement pension was so close John
Coughlin could taste it.
That such corrupt court-sponsored further-trampling of Maravelias’s

basic freedom of speech could occur in a nominally free country is surreal.
Judge Coughlin only profaned the public’s memory of his lackluster career
by consummating such cavalier insanity as one of his final judicial acts. Is
Maravelias a criminal for “possessing” “social media exhibits” in this very
brief for his own legal defense?
Maravelias here re-invites this Honorable Court to contemplate the

tragic absurdity that all this is transpired solely because he once invited a
girl to dinner and never once spoke to her after the day she rejected him.
(T27,28,35-36,451:17-18)
A. The Trial Court Transgressed Constitutional Rights and

Unsustainably Exercised Discretion
Maravelias satisfactorily explicated the unconstitutionality and

unsustainable improvidence of granting Plaintiff’s motion for expanded
56
terms in his responsive pleadings thereto (A161-163), especially regarding
the first term prohibiting Maravelias from directly or indirectly
“possessing” his legal abuser’s “social media communications” (A154). In
this brief, Maravelias advances similar arguments against the underlying
stalking order extension which are equally applicable to this separate order
granting expanded protective order terms. Lacking space for repetition
thereof, Maravelias here incorporates by reference those arguments.
(A157,182)
B. John J. Coughlin Personally Committed a Class B Criminal

Felony Violation of 641:5, I.(B) in Granting Plaintiff’s
Obscurantist Assault Against Maravelias’s Public Freedom of
Expression
Maravelias respectfully requests this Court address that Judge Coughlin

personally violated a criminal statute in granting the motion, as Maravelias
emphatically forewarned in his objection pleadings in this matter.
(A182,183)
57
CONCLUSION
WHEREFORE the foregoing compels the Defendant-Appellant, Paul

Maravelias, humbly to pray this Honorable Court:
I. Reverse the trial court’s 6/15/18 extension order, ending this case;
II. Reverse the trial court’s 8/7/18 order granting further injunctions;
and
III. Retroactively annul the original stalking order dated 2/7/17, if
possible, issuing declaratory relief that it was error to find Paul
Maravelias had ever stalked the daughter of David DePamphilis.
I, Paul Maravelias, certify that copies of the Derry District Court

decisions being appealed are attached hereto. See N.H. Sup. Ct. R. 16(3)(i).
Respectfully submitted,
PAUL J. MARAVELIAS ,
in propria persona
__________________________________
Paul J. Maravelias THE FIRST DAY OF NOVEMBER
34 Mockingbird Hill Road IN THE YEAR OF OUR LORD MMXVIII
Windham, New Hampshire 03087
paul@paulmarv.com
(603) 475-3305
58
CERTIFICATE OF SERVICE AND RULE 16(11) COMPLIANCE
I, Paul Maravelias, hereby certify that on this day were sent via first-
class mail two copies of the within Defendant’s Brief and accompanying
Appendix, postage prepaid, to Simon R. Brown, Esquire, Counsel for the
Plaintiff-Appellee, Christina DePamphilis, P.O. 1318 Concord, New
Hampshire, 03302-1318.
I, Paul Maravelias, hereby certify that this document was not drafted by
a limited-representation attorney. See N.H. Sup. Ct. R. 16(10).
Certification, further, is made of the foregoing document’s compliance

to word-count limitation, 9,493 words being contained, exclusive of the
herein addendum-certificate and of other addenda. See N.H. Sup. Ct. R.
16(11), 26(7).
November 1st, 2018
__________________________________
Paul J. Maravelias
59
PRAYER FOR ORAL ARGUMENT
The Appellant, Paul Maravelias, respectfully requests Oral Argument

before the full court pursuant to Rule 16(h). 15 minutes are requested.
60
APPENDIX
Trial Court Decisions
6/15/18 Order Granting DePamphilis’s Motion to Extend

Duration of Final Stalking Order of Protection .................... A1
Denial of Maravelias’s Motion for Reconsideration ............... A3
Denial of Maravelias’s Motion for Discovery ......................... A4
Denial of Maravelias’s Motion to Strike.................................. A5
Denial of Maravelias’s Objection to DePamphilis’s Motion for

Further Stalking Order Terms .............................................. A6
8/7/18 Order Granting DePamphilis’s First Motion for Further

Stalking Order Terms ........................................................... A7
8/7/18 Order Not Even Granting DePamphilis’s Responsive,
Ameliorated Motion for Further Stalking Order Terms ....... A8
1/12/18 Initial Extension of Stalking Order ............................. A9
Trial Court Exhibits
Christina DePamphilis’s 6/21/17 Middle-Finger Provocation

Posts Against Paul Maravelias on Social Media ................ A11
Christina DePamphilis’s 6/19/17 Social Media Post With Her
Boyfriend Targeting Maravelias ........................................ A13
Christina DePamphilis’s 12/12/16 Text Message to Paul
Maravelias Showing She Did Not Have “Fear” of Him .... A14
Evidence of Christina DePamphilis’s Social Media Accounts
Deleted Right Before Hearing ............................................ A15
61
Maravelias’s April 2018 Statement to WPD About the March
2018 Nasty Letter Sent to David DePamphilis .................. A17
Christina DePamphilis’s Age-16 “4:43am” Vodka Post ....... A18
Photograph of Christina DePamphilis Casually Socializing with
Paul Maravelias .................................................................. A19
Maravelias’s January 2018 Memo to WPD Regarding False and
Fruitless Stalking-Order-Violation Accusation .................. A20
Maravelias’s Criminal Complaint Against DePamphilis Perjury
and Theodore and Caroline Maravelias Letter-testimonies On
the Contents of Maravelias’s 12/12/16 Audio Recording They
Listened to In Vermont....................................................... A24
Excerpt from Christina DePamphilis’s Attorney’s April 2018
Pleading Alleging Maravelias Had a “Previous Obsession”
With Her ............................................................................. A36
May 2018 Nolle Prosequi of Baseless 12/15/17 WPD Arrest of
Maravelias .......................................................................... A37
Transcript Excerpt From 1/5/17 Hearing Indicating Christina
DePamphilis’s “Turkey Trot” Accusation Proven False by the
Cell-Phone Video ............................................................... A38
Excerpt from Original 12/28/16 Stalking Petition Copy Showing
Christina DePamphilis’s Claims about Being “Stalked” by
Maravelias at the 2013 Turkey Trot, Later Revealed to be a
Total Lie by His Sister’s Incidental Cell-Phone Video
Thereof, and Other False Accusations ............................... A39
Original Stalking Order
Judge Stephen’s 2/7/17 Stalking Order Finding of Facts Against

Maravelias .......................................................................... A40
62
Motion for Reconsideration Litigation
Maravelias’s 6/25/18 Motion for Reconsideration ................ A41

DePamphilis’s 7/2/18 Objection ............................................ A52
Maravelias’s 7/5/18 Reply to DePamphilis’s 7/2/8 Objection
............................................................................................ A58
Maravelias’s 7/5/18 Motion to Strike Part of DePamphilis’s
7/2/8 Objection ................................................................... A67
Underlying Stalking Order Extension Motion
DePamphilis’s 1/5/18 Motion to Extend Duration of Stalking

Final Order of Protection .................................................... A72
Maravelias’s 1/18/18 Objection to DePamphilis 1/5/18 Motion
to Extend ............................................................................. A97
Other Trial Court Motions
Maravelias’s 3/29/18 Motion to Dismiss and Vacate (Redundant

Exhibits Omitted) ............................................................. A107
Maravelias’s 5/29/18 Motion for Discovery ........................ A110
Maravelias’s 10/31/18 Motion to Set Aside Judgement ...... A115
Transcript Excerpts of Related Proceedings
63
Transcript Excerpt from 1/5/17 Hearing Showing “Arm-
Grabbing” Lie Against Maravelias .................................. A150
Transcript Excerpt from 2/15/18 Hearing in Paul Maravelias v.
David DePamphilis Indicating the Trial Court Scheduled That
Hearing Before the Renewal Motion in This Case, Further
Violating the 30-Days Requirement ................................. A151
Summer 2018 Post-Extention Litigation on DePamphilis’s Motion for

Expanded Protective Order Terms
DePamphilis’s 7/2/18 Motion to Amend Final Stalking Order of
Protection to Include Further Terms ................................ A152
Maravelias’s 7/5/18 Objection ............................................. A156
DePamphilis’s 7/12/18 Reply to Maravelias’s 7/2/8 Objection
.......................................................................................... A178
Maravelias’s 7/16/18 Reply to DePamphilis’s 7/12/18 Reply
and Criminal Complaint against Christina DePamphilis . A182
Miscellaneous
Maravelias’s 12/23/16 Text Message to David DePamphilis

Asking Him to “Stop Harassing” Maravelias’s Parents ... A197
Transcript Excerpt from the Paul Maravelias v. David
DePamphilis Hearing Indicating the Bad-Faith, Vindictive
Provenance of the Stalking Order in This Case by David
DePamphilis’s 2016 “Last Straw” Quote ......................... A198
Maravelias’s 4/13/18 Reply to DePamphilis’s Brief on Motion
for Award of Attorney’s Fees in Paul Maravelias v. David
DePamphilis, Showing Initial Falsification and Theft-Attempt
.......................................................................................... A199
64
Trial Court’s First Notice of Hearing for 2/15/18 ................ A222
Text of Relevant Authorities
New Hampshire Revised Statutes Annotated ...................... A223

General Laws of Massachusetts ........................................... A227
New Hampshire Rules of the Circuit Court – District Division
.......................................................................................... A229
65
A1 A1
A2 A2
A3 A3
A4 A4
A5 A5
A6 A6
A7 A7
A8 A8
A9 A9
A10 A10
On 6/21/17, the Plaintiff Christina DePamphilis pictured herself in the following post on her public
social media making vulgar gestures against the Defendant, Paul Maravelias.
It was targeted against Maravelias, and its caption read “Did Dartmouth [Defendant’s college] teach
you how to do this 🖕🏼” [Middle finger “emoji”].
This act of harassment was to taunt Maravelias that DePamphilis had successfully abused him with a
falsified restraining order, and cruelly bait Maravelias into violating it.
The man on the right is Matthew LaLiberte, DePamphilis’s boyfriend in his 20s.
Permalink for verification: http://bit.ly/2y0JFEF
A11 A11
A12 A12
Christina DePamphilis posted the following image on the same public social media account on
6/19/17 at 8:54pm, immediately prior to the vulgar incitation post pictured in the preceding exhibit.
This post pictures the boyfriend calling-out Defendant by initials “PM”, further removing any doubt
the posts were directed unto him.
A13 A13
The following is from Defendant’s Gmail SMS text-message backup and shows that the Plaintiff
actually texted him after his inviting her to dinner on 12/12/16 to “thank” him for the words and kind
gesture. The Plaintiff’s cell-phone number (603- ) is indicated. This shows there was never
any “fear”, and the subsequent “stalking” accusations have been completely fraudulent.
A14 A14
Evidence tampering documentation: social media account deleted right before 1/3/18 hearing in which
DePamphilis targeted Maravelias with the aforecited provocative, inciting gesture (6/21/17).
A15 A15
Evidence tampering documentation: deletion of both Instagram accounts of DePamphilis’s daughter
(“tipsytina69” and then renamed “tipssyytina”) containing other referenced postings:
A16 A16
Maravelias 4/18/17 statement about the letter received by David DePamphilis which was cited/reproduced
in Plaintiff’s motion to extend stalking order:
A17 A17
In July of 2017, 16-year-old Christina DePamphilis pictured herself in this posting. She is
evidently about to return home in her grey 2013 Jeep Wrangler (pictured in background) openly
carrying hard liquor in left hand in her possession. “gn” stands for “good night”, and the caption
reads, “in need of walk of shame number 2 lmk”.
The winter prior she complained about “fear” for “personal safety” while making false
accusations of “stalking”.
A18 A18
Cell-phone picture (and screenshot of metadata) taken by Maravelias at his own house on
6/29/13 depicting the comfortable and normal social dynamic between him and the liar Plaintiff
(pictured) at Defendant’s HS graduation party, contrary to her mendacious claim to this Court
about being “really nervous and uncomfortable” (Page 7 of 1/5/17 transcripts) in this same social
encounter, which was made to support her falsified Stalking Petition.
A19 A19
The following is a 1/25/2018 statement Maravelias submitted to Windham Police upon another
of DePamphilis’s malicious false accusations that Defendant had violated the protective order.
The police dismissed the frivolous, vexatious complaint, as they had done with other similar
DePamphilis false complaints made in March and September 2017. This shows DePamphilis’s
“protective” order is intended as nothing but a weapon of harassment and legal abuse against
Maravelias.
A20 A20
Paul Maravelias
1/25/18
Re: Statement on newest DePamphilis false accusation
On 1/25/18, Officer Dzierlatka called my cell to relay that David DePamphilis (or family member) had
accused me of violating the fraudulent stalking order with regards to his daughter. The accusation was
that on 1/20/18 I had seen one of DePamphilis’s automobiles on my street while driving myself and that
I aggressively accelerated at high-speed to reach and tailgate their vehicle at close-range at the same
time as David’s daughter was in his car. This is completely false as I did nothing of the sort. In fact, I
didn’t even see David’s vehicle this night.
The fraudulent stalking order forbids knowingly approaching the Plaintiff (David’s criminal perjurer
daughter) within 300 feet. Whenever I have seen the criminal, David, out driving, or his complicit
daughter, I have ignored their presence and minded my own business. I shall do the same if I ever
encounter them in public, which fortunately has not happened.
I informed Officer Dzierlatka that the accusation seemed malicious, given David’s past lies to police and
given my absolute lack of memory of seeing his vehicle on that night. I also stated that I am highly aware
of David’s vehicles when I do see them, and I would certainly remember if one was in front of me this
night.
I searched my Google phone location history records and found that I had returned to my house at 2206
EST for the last time that day. I did not leave my house again until around 0800 EST the following
morning. David alleges the incident occurred an hour and a half later around 2330 EST. I had been inside
my house for 1.5 hours at this point. My last excursion that day was to purchase a non-alcoholic
fermented beverage at Shaw’s before they closed at 10pm. My attached phone location history and
credit card transaction record all corroborate these memories. Even without this proof of my physical
absence, there is no proof beyond hearsay of any aggressive driving behaviors.
Some of David’s past accusations against me have been delusional, and some others intently malicious. I
will be collecting information from my family members on whether the car David associates with me
was even out on the road at all at this time. It is possible my sister was driving it, as it is a car I purchased
primarily for her usage and not mine. Depending on what I find, I may submit a criminal complaint
against David DePamphilis for violation of RSA 641:4, which criminalizes he who “knowingly gives or
causes to be given false information to any law enforcement officer with the purpose of inducing such
officer to believe that another has committed an offense”. David has already violated this law on
multiple occasions, from his initial falsified stalking petition against me to his bully-like sophistry on
9/5/17 that my seeing his wife at the supermarket was a violation of the “stalking” order which involves
only his utilized revenge-puppet daughter. This department needs to enforce this law against David by
arresting him and clarifying that police resources are not to be exploited to bully peaceful 22-year-olds.
Regards,
Paul Maravelias
A21 A21
A22 A22
A23 A23
The following is a criminal complaint Maravelias submitted to the Salem Police Department
regarding DePamphilis’s willful criminal perjury made to Salem District Court in order to obtain
the protective order in the present case. David DePamphilis suborned the Plaintiff, Christina
DePamphilis, to make materially false statements in a 1/5/2017 Hearing and in the original
falsified, bad-faith, vindictive Stalking Petition filed 12/28/2016.
A24 A24
November 1st, 2017 To: Windham Police Department
Paul J. Maravelias Cc:
34 Mockingbird Hill Rd Detective Jason Dzierlatka
Windham, NH 03087 Detective Christopher van Hirtum
In re David DePamphilis Criminal Complaint (felony Perjury under 641:1, felony

Conspiracy under 629:3, misdemeanor Defamation under 644:11, and misdemeanor
False Reports to Law Enforcement under 641:4)
______________________________________________________________________________
Fair and impartial public servants of Windham:

It has come to pass that my abuser David Nicholas DePamphilis of has severely
violated four criminal laws to wage his ongoing course of undue harassment against me.
The felon, David DePamphilis, lied to your police department in December 2016 when he filed a
false “stalking” petition against me through his daughter, to satisfy his own lust for revenge.
I submit proof that the crime of felony Perjury occurred decisively on January 5th, 2017 at Salem
District Court at around 1:30pm when David caused “a false material statement under oath or
affirmation” to be made when he did not “believe the statement to be true” (RSA 641:1 I. (a)).
My complaint is not semantic hairsplitting, petty revenge, or fighting over facts.
David’s willful crime has directly caused tremendous financial and emotional damage to
me, as well as the marked abuse of my property rights and destruction of my good record.
At the 1/5/17 stalking hearing, David suborned his attorney Jerome Blanchard and daughter
Christina to perjure the following falsehood about my normal, kind words to her while asking the
young woman out to dinner on her 16th birthday, before I left after her respectful decline:
“Q Did he use the phrase at any point during this conversation, age of
consent?
A Yes
Q What did he say?
A He said I was age of consent at 16.” (Page 27 of transcripts for Christina

DePamphilis vs. Paul Maravelias, Case No. 473-2016-CV-00124, attached as Exhibit C)
Though it is difficult for me to refrain from writing about how shockingly inaccurate their whole
dramatic canard about “stalking” was (we had been normal family friends), I need to stay
focused here on this certain specific criminal perjury.
A25 A25
Under the Perjury statute (641:1), only material willfully false representations are punishable.
The knowingly false accusation above was material: it directly caused the issuance of the
restraining order, in the words of Judge Stephen’s finding of stalking:
“[Maravelias] referred to [that day, her 16th birthday] as the ‘age of consent’” and “mentioned he
will wait until she is ready and be back when she is 18 years old”
(Stephen, Robert S. in Final Order 473-2016-CV-00124, attached as Exhibit D).
These specific false claims which caused the order (that I said I’d “be back” in two years and
mentioned a creepy sexual motivation behind my kind gesture) were not once mentioned in
David’s initial written “stalking” petition he had his daughter write on 12/28, nor during his
own verbal explosions and tirades against me and my family on 12/12 and 12/14. It is crystal
clear this was an intentional, willful “buzz-word” dreamed-up maliciously to get the order.
Now, let actionable proof be submitted of David’s outrageous perjury:
I had actually been taking a sentimental cell-phone recording of the 12/12/16 verbal exchange in
question. It was disallowed as evidence in the stalking hearing under the “wiretapping” statute.
Your department possesses this recording from when David vindictively had me arrested for it.
I played the recording for my parents in Norwich, VT on 10/21/2017, and I attach two letters
from them (Exhibits A and B) which indicate the contents of this audio recording: that I
absolutely never said the alleged things above. (Also that there was never any “fear”, etc.)
Unlike the recording itself, this testimony is indubitably admissible, actionable evidence.
My parents and I are happy to testify in person at court or come to the station to make a recorded
statement about the contents of this audio recording, which proves what I had and hadn’t spoken.
Thus I have hereunto submitted proof for all three elements of criminal perjury: that the false
statement was 1) material, 2) maliciously, knowingly false, and 3) indeed factually untrue.
David has additionally committed criminal Conspiracy under RSA 629:3. The statute reads,
“A person is guilty of conspiracy if, with a purpose that a crime defined by statute be committed,
he agrees with one or more persons to commit or cause the commission of such crime, and an overt
act is committed by one of the conspirators in furtherance of the conspiracy.”
David conspired with his daughter Christina and lawyer Jerome Blanchard to deliver the
referenced illegal and defamatory perjuries into the stalking hearing at Salem District Court.
Furthermore, he is guilty of a separate count of Conspiracy for suborning the falsehoods written
in the initial “stalking” petition, including that I had “insisted” with his daughter and even made
the creepy statement “you will learn to love me”. I had never said any such thing, as my audio
recording proves.
These certain malicious lies were misdemeanor crimes of False Reporting (641:4) but fell just
short of an additional count of felony Perjury, since they were not “material” representations,
A26 A26
unlike the aforementioned perjuries cited by the judge in the false finding of stalking. Exhibit E
shows the inclusion of these outrageous lies, among others, in the petition.
David has also committed criminal Defamation (644:11) against me, since the same referenced
act of Perjury also satisfies 644:11’s lower standard of Defamation, occurring when a person:
“purposely communicates to any person, orally or in writing, any information which he knows to
be false and knows will tend to expose any other living person to public hatred, contempt or
ridicule”.
As a victim of his false accusation and massive resulting injustice, I respectfully demand David
DePamphilis be arrested and prosecuted for felonious Perjury and Conspiracy, and misdemeanor
Defamation and False Reporting.
Nota bene: Although the daughter Christina DePamphilis orally delivered David’s perjury, David
suborned it to happen having premeditated the aforecited direct examination. He is liable under
accepted legal maxims respondeat superior and quid facit per alium facit per se. Still, his
daughter is knowingly complicit, and I request a warrant be issued for her arrest as well.
Thank you for your impartial professionalism as you attend to justice in this criminal matter.
Respectfully,
Paul J. Maravelias
_____________________________________________ ________________
A27 A27
10/23/2017
Theodore Maravelias
34 Mockingbird Hill Rd, Windham, NH 03087
To: Windham Police Department

Cc: Detectives Jason Dzierlatka and Christopher van Hirtum
Re: David DePamphilis Criminal Complaint (felony “Perjury” under 641:1 and
misdemeanor “False Reports to Law Enforcement” 641:4)
To whom it may concern:

We are respectfully requesting an arrest warrant be issued for David N. DePamphilis (
in Windham). We are outraged that he has delivered intentional lies to your department to
corrupt the course of justice, among other crimes.
On December 28th, 2016 David filed a “stalking” petition against our son Paul Maravelias
through his daughter Christina. David and his wife Laurie were unquestionably the originators of
this action, and even your prosecutor admitted this in court (10/6/17) during an unrelated matter.
David DePamphilis concocted a slew of intentional lies in the “stalking” petition against our son,
and then even more lies during the hearing. He suborned his daughter to perjure in court to get
revenge on our son with the stalking order.
Though DePamphilis dreamed-up too many lies to list here, Judge Robert S. Stephen cited one
particularly outrageous fallacy which directly caused the “stalking” order to be issued.
This intentional “false material statement” (the requirement in 641:1) was that, when my son had
nicely invited David’s daughter and wife to dinner, he:
“referred to [that day, her 16th birthday] as the ‘age of consent’ to her mother”
and
“mentioned he will wait until she is ready and be back when she is 18 years old” (quotes from
Judge Stephen’s finding of “stalking” in Christina DePamphilis v. Paul Maravelias, 473-2016-
CV-00124).
For sentimental reasons, my son had been audio taping the exchange in question on his cell-
phone.
On October 21st, 2017, I listened to this audio recording at Norwich in the State of Vermont.
A28 A28
The recording clearly documents the entirety of my son’s interaction with on them that day, and
that he never spoke anything remotely close to the disturbing, sexualizing “age of consent”
reference, nor states that he would “be back when she is 18”.
The recording also proves that David’s wife and daughter outright lied about many other facts,
such as saying that my son “insisted”.
We know these false statements by David constituted intentional perjury since DePamphilis had
screamed harassing insults and perverse expletives at me and my son over phone on December
12th (later that day) and then on December 14th: he never once then alleged that our son had said
something as creepy and disturbing as referencing his kind invitation as motivated by some sort
of sexual impulse on the brink of the girl’s legal age. David surely would have mentioned this
during his unhinged and threatening tirade, if my son had said this.
In fact, this particular damaging false accusation was not even in the original written stalking
petition, which included complaints of “stalking” as foolish as “I noticed Paul was looking at me
while seated in his backyard during a family party”. We were good family friends. That is
beyond insincere and disingenuous.
Clearly, the intentional perjury in question was only contrived by Mr. DePamphilis immediately
before the 1/5/17 stalking hearing, or else it would have certainly been included in the written
petition (12/28/16) and also in his verbal tirades against us on 12/12/16 and 12/14/16.
For the separate misdemeanor false police reporting charge, we refer to different falsehoods
about this exchange which were in the written stalking petition: that our son said “you will love
me” and “insisted” during his romantic expression.
The recording I listened to (while in the State of Vermont) proves this is false. These specific
lies caused the stalking order.
As I understand it, my son is also producing evidence of various alcohol crimes David has
committed with minors.
David DePamphilis is a vindictive and merciless man who has abused our son, caused great
stress for my family, and caused a miscarriage of justice against him by intentionally perjuring to
get the stalking order. I firmly believe that at the very least, this constitutes perjury.
We were family friends with this family for a long time. Instead of showing neighborly love and
understanding, he chose vindictiveness and was sadly willing to employ perjury to carry his
retaliatory actions out.
A29 A29
A30 A30
10/23/2017
Caroline Maravelias
34 Mockingbird Hill Rd, Windham, NH 03087
To: Windham Police Department
Cc: Detectives Jason Dzierlatka and Christopher van Hirtum
Re: David DePamphilis Criminal Perjury
To whom it may concern:
I’m a stay-at-home mother from Windham. I am indignant that my neighbor David DePamphilis has
slandered our son to the point of outright lying to the court (perjury) and to this police department to
obtain a false “stalking” restraining order against my son.
My husband and I are respectfully requesting for David to be arrested and prosecuted for his crime of
perjury and false police reporting, which we have proof of.
DePamphilis vindictively filed a “stalking” petition against our son through his daughter on 12/28/16.
This was two weeks after we had settled him down from his emotional outburst. He had a verbally
abusive explosion against my husband and son Paul after Paul had respectfully invited his daughter to
dinner on her birthday.
David got so angry that he willfully lied to the court that our son made creepy and disturbing, sexual
comments when he invited Christina to dinner and her mother as well. My son actually behaved like a
gentleman, and we have an audio recording which proves David lied outrageously to get the court order.
On 10/21/17, in Norwich, VT, I listened to the sentimental cell-phone recording my son Paul made of his
romantic invitation on 12/12/16 to David’s daughter. David and his daughter claimed in court that Paul
had said “you will learn to love me!”, that he was “insistent”, and that he even said downright weird,
frightening things like referencing the “age of consent”, suggesting sexual intercourse.
The judge actually attributed this last lie in his false finding of “stalking”, proving that David’s perjury
was absolutely material to the case and directly caused the perversion of justice against our son.
The audio recording I listened to confirmed my son’s testimony during the stalking hearings that he
absolutely never said any of these outrageous false accusations. He never once mentioned the “age of
consent” or any reason for his choice of that particular day at all. He was kind, respectful, and even
said “I respect your feelings” once Christina politely rejected him. David’s family members had actually
been happy to see Paul. The recording proves his daughter in fact invited him back, after Paul first went
to the door and her mother was in the shower.
The “stalking” petition and allegations in the court hearing paint a picture of my son so completely false
that my husband and I are outraged months later. Hearing the recording for the first time has validated
our outrage at David’s perjury. David’s wife and daughter were actually laughing and joking with Paul; I
heard Christina say “that’s so sweet”, “thank you”, “no, you’re fine”, etc. Laurie said she “appreciated”
the gesture. The dishonesty of this family in their delusions against my son two weeks later is absolutely
disturbing. To call his kind behavior “stalking” is appalling.
A31 A31
A32 A32
Exhibit C
Summary:
This is a reproduction of the referenced page from the stalking hearing transcripts. The entire
transcript is digitally attached in three separate PDF files. Please note that the transcripts are of
absolutely awful quality, though no errors in transcription affect in the referenced portions on
page 27 indicating DePamphilis’s testimony from 1/5/17. Red box emphasis to material perjuries
cited by judge is added.
A33 A33
Exhibit D
Summary:
This is a reproduction of Judge Stephen’s finding of “stalking” based upon the two specific
perjuries presently discussed, proving them “material” to an “official proceeding” under 641:1’s
requirement for Perjury.
These are the two intentional perjuries for which we submit proof of falsity and willfulness. We
do not have actionable proof of falsity and willfulness for the other material perjury referenced in
this finding (about the “dropping off” incident), so we restrict our demand for arrest and
prosecution to the basis of only the perjuries highlighted in red.
A scan of the full order is attached digitally.
A34 A34
Exhibit E
Summary:
This is an excerpt from David DePamphilis’s stalking petition filed vicariously through his
daughter Christina against Maravelias on 12/28/16. It is absolutely libelous and littered with
imagined, delusional false accusations against Maravelias. The area highlighted in red indicates
the misdemeanor false reports to law enforcement under 641:4 which Maravelias’s audio
recording proves as false, corroborating his accurate memory and testimony.
Since these false reports were not directly attributed in Stephen’s finding, they might not have
been “material” under the definition of Perjury. However, the form does indeed state, “I
understand making a false statement on this form will subject me to criminal penalties”. We
therefore demand imposition of such penalties for these false statements.
The full stalking petition is attached digitally. It also usefully reveals the shocking truth that the
outrageous “age of consent” perjury was never once mentioned here, since it was maliciously
dreamed-up right before the 1/5/17 stalking hearing but after this 12/28/16 written petition.
A35 A35
The following is an excerpt from Paragraph 6 of Plaintiff’s counsel’s defamatory Motion to
Strike in the related stalking case against David DePamphilis. While falsely libeling Maravelias
that he ever had an “obsession” or “stalked” the Plaintiff, it admits that these circumstances, true
or not, were “previous”. I.e., Plaintiff’s own counsel admits the alleged “stalking” circumstances
no longer exist.
A36 A36
The following is documentation that the alleged criminal violation of the protective order (mentioned in
Plaintiff’s Motion to Extend) has been fully dismissed as of 5/23/18, due to the baselessness and
outrageous unconstitutionality of the unlawful arrest, as Maravelias never violated the order. At bottom,
see “5/23/18 N P” (nolle prosequi) plus initials of Windham prosecutor in the matter.
A37 A37
A38 A38
A39 A39
A40 A40
A41 A41
ROCKINGHAM, SS 10th CIRCUIT – DISTRICT DIVISION – DERRY
Docket No. 473-2016-CV-124
v.
Paul Maravelias
MOTION FOR RECONSIDERATION
Paul Maravelias, the Respondent, in dutiful compliance with the customs necessitated by proper court
etiquette, restrains his justified indignation and submits respectfully this Motion for Reconsideration of
the Court’s unlawful 6/15/18 Order extending the Stalking Order in the above-referenced case.
1. Christina DePamphilis (hereinafter, the “Petitioner”) is a high school senior turning 18 this year. She
has pictured herself consuming and/or under the influence of alcoholic and other controlled substances
in social media artifacts submitted to this Court while complaining that Maravelias’s non-threatening,
lawful expressions made in private to other parties endanger her “personal safety”. She filed a
Stalking Petition against Mr. Maravelias in late 2016 after he respectfully invited her to dinner and
never spoke to her ever again after the day of her rejection. She complained of his older age in the
Petition and then pictured herself united to a 21-year-old boyfriend weeks later as a 16-year-old. At
the 5/3/18 Hearing, she said she feels she is being “stalked” by Mr. Maravelias “every single day”
because he continues to “mention [her and her legal action against him] to other people”.
2. Paul Maravelias (hereinafter, the “Respondent”) is a 23-year-old author and recent Ivy League
graduate who is presently employed as a software engineer. The first time he asked a young woman
1
A42 A42
out to dinner, she filed a vindictive Stalking Petition weeks later against him because her father David
DePamphilis had an argument with him and was extremely angry. The Petitioner later had Mr.
Maravelias arrested for attempting to defend himself against her false accusations in her Stalking
Petition. To disprove her malignant claims about what he had actually said to her, he introduced a
sentimental, happenstance cell-phone audio recording he had made with a popular Android
smartphone app outdoors during his date proposal to her. Unbeknownst to Mr. Maravelias, the victim,
this is apparently illegal in New Hampshire and called “wiretapping”. For context, unlike the “minor”
Petitioner, Maravelias has not had a drink in years, is chaste, and refrains from criminal perjury.
3. In a 6/15/18 Order signed by Judge John J. Coughlin, this Court extended Petitioner’s Stalking Order.
A. THIS COURT’S FINDING THAT THE PETITIONER HAS FEARED “FOR HER PERSONAL SAFETY” IS
LAUGHABLY ABSURD, GIVEN HER DOCUMENTED CONDUCT OF CRUELLY BULLYING MR.
MARAVELIAS ON THE INTERNET WITH VULGAR GESTURES DURING THE PENDENCY OF HER
FRAUDULENT STALKING ORDER, IN A FAILED ATTEMPT TO GET HIM TO VIOLATE IT AND HAVE
HIM ARRESTED, SHOWING HER MALICIOUS BAD-FAITH AND FULL CONFIDENCE THAT HE IS A
NON-VIOLENT AND LEVEL-HEADED PERSON
4. Petitioner’s testimony and Respondent’s accepted exhibits in this case both established that the
Petitioner made a public social media post specifically directed at Respondent on 6/21/17.
5. Her inciting, harassing, and vulgar post against Mr. Maravelias pictured herself with her father and
21-year-old boyfriend, all three parties middle-fingering the camera to insult Mr. Maravelias that he
had failed to have a relationship with Petitioner and was then subject to her falsified restraining order.
6. At the Hearing, Petitioner also confessed to posting another image wherein her boyfriend addressed
Mr. Maravelias with incendiary remarks. This was after the Petitioner lied about having “fear” of him.
7. To put it lightly, this Court’s conduct is shocking and reckless in condoning Christina DePamphilis’s
and David DePamphilis’s 1) willful legal abuse through a bad-faith Stalking Petition, 2) perjury about
having any “fear” of the Respondent, and 3) outright provocative bullying against Mr. Maravelias in
said social media post(s), by actually granting her Motion to Extend a Stalking Order wherein the
roles of victim and perpetrator are undeniably reversed.
2
A43 A43
8. This Court turns a blind eye to Petitioner’s public interpersonal terrorism against Mr. Maravelias on
social media and her documented illegal acts (such as her underage alcoholic intoxication pictured in
Respondent’s exhibit(s) and even in her own), but has no qualms about issuing a baseless extension
against Respondent even when the “personal safety” of the Petitioner was clearly never threatened.
9. This Court then dares the audacity to uphold its recent ruling inculpating Mr. Maravelias of “bad
faith” conduct in his honest Stalking Petition against David DePamphilis, in an Order dated 6/14/181.
10. This Court has woefully calpestated the natural rights of Respondent through inexcusable, biased
conduct and should expect to be sanctioned accordingly by higher state and/or federal authorities.
B. THE PETITIONER, CHRISTINA DEPAMPHILIS, HAS ABSOLUTELY NO CREDIBILITY, AS

MARAVELIAS IRREFUTABLY DOCUMENTED HER DELUSIONAL, REVISIONIST MEMORY AND/OR
OUTRIGHT WILLFUL LYING AT MULTIPLE OCCASIONS DURING THE HEARING; THE COURT
THEREFORE ERRS TO RELY UPON HER MATERIAL REPRESENTATIONS
11. This Court granted an extension on a Stalking Order in which the Petitioner’s lies or false
representations of fact, in whole or in part, are beyond dispute. Respondent submitted her testimony
transcript from the 1/5/17 Hearing wherein she admitted to falsely inserting words into Maravelias’s
mouth, confessing he never said the phrase “you will learn to love me” as she alleged in her Petition.
12. The Court also saw a cell-phone video of a 2013 Turkey Trot outdoor event showing Petitioner
walking across a crowd to interrupt Respondent’s conversation with friends and say hello to him,
when her false Petition perjuriously claimed that “he came up to [her]” and made her “scared”.
13. This Court sat back and watched as the Petitioner perjured during the Hearing, as Maravelias pointed
out in testimony, yet still granted her abusive extension. The Petitioner claimed the sole purpose for
her demeaning middle-finger post against Mr. Maravelias was “to let him know” that she knew he
could view the account. But, Maravelias then revealed a posting from her same social media account
two days prior to the 6/21/17 vulgar post, which had already directly identified Maravelias on 6/19/17.
1
Maravelias’s unnecessarily polite Motion to Reconsider in that matter had documented clear facts and points of law
overlooked by this Court’s oppressive award of attorney’s fees, even to the extent that one of the granted expenses was dated
from months before Maravelias even filed his truthful Stalking Petition. That this Court would wholly ignore this fact and all
others raised in a knee-jerk, thoughtless, nondescript, and hastily-scribbled rejection of said motion in entirety is reminiscent of
its reckless finding in the instant case. Clearly, this Court automatically disregards all of Maravelias’s presented facts and
arguments, and is but a slave unto the contrived optics of the side flashing a 17-year-old female before the Court and whining
baselessly about “victimization”. Thus, judicial malpractice has obstructed a fair outcome for Mr. Maravelias.
3
A44 A44
14. The 6/19 exhibit (which Petitioner didn’t know Respondent had) also shows her dishonesty in
claiming to be the “only one who knew” to whom the vulgar gestures were directed. Her boyfriend
addressed Maravelias in her 6/19 post; therefore, he and, by extension, David DePamphilis, all knew
exactly whom they were bullying in the 6/21/17 post2. For this Court to validate a bold liar of such
turpitude by extending her falsified order against the victim is shameful, rash, and utterly emetic.
15. This Court’s Order has thus endorsed a felony crime under the perjury statute (RSA 641:1): willful
misrepresentation of fact in a protective order case. Ergo, it is noted that this Court does not operate
whatsoever according to the laws of the land, but rather only to its arbitrary and capricious diktats3.
C. THE COURT’S ORDER IS BLATANTLY ERRONEOUS INSOFAR AS IT RELIES UPON A WRONG

FINDING THAT RESPONDENT HAS AN “OBSESSION” WITH THE PETITIONER “TO THIS DAY”,
WHICH NEGLIGENTLY IGNORES A MOUNTAIN OF EVIDENCE AND TESTIMONY TO THE
CONTRARY CONVENIENTLY IGNORED BY THE COURT’S ORDER
16. The Court cites Respondent’s wrongly-pluralized “letters” (Maravelias’s 11/2017 reply to Attorney
Brown’s legal threat) and “emails” (Maravelias’s private complaint email to an honor society) as
indications of a “strange, perverse and unhealthy obsession” he allegedly has for the Petitioner.
17. This wanton act of libel against Mr. Maravelias is highly disturbing, considering that both referenced
communications 1) enthusiastically declared his disgraced disinterest in the Petitioner, 2) were made
to parties other than Petitioner, and 3) fulfilled a legitimate purpose of responding to a legal threat and
complaining to a public honor society in a private email to a close mentor of his, respectively.
18. The Court unethically abuses its judicial immunity in libeling Maravelias in this fashion,
misconstruing his rightful “letter” and “email” completely out of context as “obsessive” acts. The
2
Respondent also noted for the Court that Christina DePamphilis deleted her public social media account containing these posts
mere days before filing her Motion to Extend on 1/5/18. Also, the Court’s “obsession” finding attempts to make a medical,
psychological finding when the testimony of an expert in the field would be necessary to sustain a finding of “obsession”.
3
This Court’s illegal misconduct with Stalking Orders is hardly new or unusual. For instance, this Court recently granted a
Stalking Final Order of Protection in Mary Peterson v. Richard Garrigus (431-2018-CV-0089) on 6/4/18 with a written Order
containing absolutely no specific findings of fact articulating a “stalking” “course of conduct” whatsoever. This flies in the face
of judicial requirements imposed by the NHSC. (See Fisher v. Minichiello, 155 N.H. 188, 193, 921 A.2d 385 (2007) “We have
interpreted RSA 633:3-a, II(a), since it ‘contains an enumerated list of prohibited conduct,’ to require trial courts to make
specific findings as to the course of conduct warranting a final stalking order.”, South vs. McCabe, 943 A.2d 779 (2008) “The
trial court failed to make such findings in this case. The final stalking order … gives no indication of either the facts or the
reasoning upon which the trial court based its decision. Both this court and the respondent are thus left to speculate as to the
precise nature of the trial court's findings, and whether sufficient evidence was in fact introduced to support them. We therefore
vacate the final stalking order and remand. Kiesman, 156 N.H. at 482, 937 A.2d at 919.”)
4
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record reflects they were actually self-defensive expressions begotten of the same false accusation of
“obsessive”, stalking behavior. Given these outrageous comments in its finding, it follows that the
Court too has a “stalking obsession” with Mr. Maravelias, since it has engaged in the exact same act
as his “letter” and “email”: i.e., writing in a detached, objective fashion about someone’s perceived
wrongdoing. If such acts of speech signify a “stalking obsession”, then everyone is a “stalker”.
19. Judicial estoppel prevents Petitioner from stating Respondent has an ongoing “obsession”, since even
her counsel termed it a “previous obsession” in a recent filing. Therefore, to fuel its verbal posturing
against Mr. Maravelias in its finding, this Court asserts an unspecified liberty to make representations
against him even beyond what Petitioner and counsel themselves alleged.
20. Respondent also testified amply to his disinterest in his legal abuser, the Petitioner, disclosing that her
recent corpulence inhibited his ability to even recognize her when seen in the Court parking lot.
D. THE COURT’S WRITTEN FINDINGS OF “REASONABLE FEAR” AND AN “OBSESSION” CONFLICT

WITH ITS ACCURATE STATEMENTS IN THE HEARING AND THUS FORM AN ABUSE OF DISCRETION
21. On 6/8/18, the Court accurately remarked while listening to Respondent’s closing argument,
“You indicated that you don't want to have anything to do with the family, you don't want to have anything
to do with this young woman, and you just want to be left alone and you're going to leave her alone - at
least that’s my impression, and that’s what you’ve indicated.” (Hon. John Coughlin, 12:03:02pm 6/8/18)
22. But, on 6/15/18, the Court impetuously defamed Maravelias with the following amplified verbal
posturing in its Order: “[Respondent’s acts of private speech] clearly demonstrate a strange, perverse and
unhealthy obsession by the Petitionee towards the Petitioner which … continues to this day.”
23. This inconsistency is confusing and inexplicable. The Court’s palpably insincere self-contradiction
regarding a “present” “obsession” by Respondent must therefore be estopped, and its Order vacated.
24. The same is true concerning the Order’s unsupported finding of “reasonable fear” given the Court’s
following 5/3/18 remark during cross-examination of Petitioner:
“I think you had a good point there in terms of posting this, and where it was posted, and the circumstances,
and the context, and whether or not she felt a concern for her personal safety or well-being.” (Hon. John
Coughlin, 2:42:57pm 5/3/18)
E. THE COURT WRONGFULLY BASED ITS EXTENSION DECISION ON PHOTOGRAPHS PETITIONER

INTRODUCED OF RESPONDENT’S PRIVATE SENTIMENTAL ARTIFACTS IN HIS BEDROOM FROM
YEARS AGO WHICH IN FACT DEPICTED HIS LONG-PRIOR ATTRACTION THERETO, BEFORE HER
5
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LEGAL ABUSE OF THE VICTIM WITH A FALSE STALKING PROTECTIVE ORDER, AND NOT AT ALL
NOT DURING THE PENDENCY OF THE STALKING ORDER
25. On 6/8/18, after the Petitioner had rested, she submitted four photographs of Respondent’s private
interior bedroom and office space, dated 4/6/17.
26. Respondent testified that the pictures snapshotted a state of existence from prior to his victimization
in the false “stalking” matter, since he had been living at college and not in the pictured space
substantially or entirely from late December 2016 through April 2017.
27. That the Court would bestow validation upon the Petitioner’s bad-faith, malicious attempt to humiliate
Mr. Maravelias with such irrelevant intrusions of his privacy by daring to libel him a further “stalker”
just because he once put a motivational quote on his wall constitutes a strange, perverse, and
unhealthy exercise of discretion by this Court in clear prejudice of the Respondent.
28. Respondent is victim of a corrupt judicial tyranny which violates his Fourteenth Amendment right to
privacy by injunctively penalizing him for exercising his full right to have “coke bottles” in his room
and “motivational phrases” on his wall, even regardless of these happenstances’ past-nature.
29. In the past year, Christina DePamphilis has 1) incessantly, falsely complained to the police to try to
get Maravelias arrested, 2) illicitly collected pictures of Maravelias’s private bedroom without his
knowledge, and 3) cruelly targeted Maravelias with vulgar, incitative gestures on the web – all while
Maravelias remained silent to her and ignored her attempts for attention. Who is the “stalker”?
F. THE SAID PHOTOGRAPHS WERE UNLAWFULLY OBTAINED BY WINDHAM POLICE IN TORTIOUS

EXCESS OF THE LIMITED TERMS OF THE SEARCH WARRANT GRANTED IN THE AUDIO
RECORDING MATTER IN WHICH PETITIONER FURTHER ABUSED MR. MARAVELIAS; THE COURT
MAY THEREFORE NOT LAWFULLY RELY UPON THEM
30. The said photographs were taken by Windham Police during an unconstitutional raid on Maravelias’s
house to seize his digital property for evidence of his banal sentimental cell-phone recording.
31. The terms of the search warrant were highly specific. Taking pictures of unrelated sentimental
objects/fixtures on the Respondent’s bedroom wall grievously exceeded the scope of the warrant and
violated Respondent’s Fourth Amendment and Fourteenth Amendment rights. The exclusionary rule
enjoins this evidence, taken illegally by a government agency, from being used against Respondent.
6
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G. THE COURT’S GRANTING PETITIONER’S EXTENSION MOTION IS ERRONEOUS SINCE HER
MOTION IS PATENTLY UNREASONABLE, AS RESPONDENT’S ALLEGED CONDUCT, EVEN IF
PROVEN, DOES NOT THREATEN HER “SAFETY OR WELL-BEING”
32. Petitioner’s Motion to Extend is rooted in her complaint that Maravelias sent an email to one of his
teachers and responded to an attorney’s threatening letter, claiming that she is a “disreputable whore”.
33. To find that Respondent’s provoked, offensive, and accurate language to a person who is not the
Petitioner could possibly constitute a threat to her “safety or well-being” is groundless and asinine.
H. THE COURT’S ORDER EGREGIOUSLY VIOLATES RESPONDENT’S STATE AND FEDERAL

CONSTITUTIONAL RIGHTS SINCE IT RELIES UPON HIS TWO ACTS OF CONSTITUTIONALLY
PROTECTED, LAWFUL SPEECH MADE FOR A LEGITIMATE PURPOSE
34. The Respondent denied authorship of Petitioner’s Exhibit 1, which was not sent to Petitioner’s whole
“family” but to David DePamphilis. Respondent’s only acts of speech cited in the Court’s order for
which he is actually responsible were made for legitimate, constitutionally valid purposes.
35. I.e., Respondent’s 1) response to Attorney Brown’s threatening letter and 2) private email to his high
school mentor who also runs the public honor society are acts of free speech lying entirely outside the
narrow categories of First Amendment protection exceptions, such as “fighting words” or obscenity.
I. THE COURT’S ORDER IS NULL AND VOID SINCE RESPONDENT WAS NOT GIVEN A FAIR TRIAL
I. (a) THE COURT ILLEGALLY LIMITED HIS RIGHT TO VIDEOTAPE THE HEARING AND ENABLED
PETITIONER THEREBY TO PERSIST IN HER DISHONEST, BAD-FAITH CONDUCT AGAINST THE VICTIM
36. In keeping with its known habit of delegating unto itself powers found nowhere in the law, this Court
granted the Petitioner’s obscurantist motion to limit Respondent’s right to videotape the entirety of the
public hearing on Petitioner’s Motion to Extend the Stalking Order in this case.
37. Respondent had shown the Court its own rule (District Court Rule 1.4) which permits any person to
“photograph, record and broadcast all court proceedings that are open to the public” and gave
“advance notice” as required. The rule further states in 1.4 (e), “no court or justice shall establish
notice rules, requirements or procedures that are different than those established by this rule.”
38. Since this Court operates entirely outside the boundaries fixed by written rules and laws, it
nonetheless granted Petitioner’s request to partially limit Respondent’s right to videotape, prohibiting
that the “minor” Petitioner be videotaped. The Court endorsed her pictured underage illegal substance
7
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consumption and online criminal harassment (RSA 644:4) of Maravelias by granting the extension,
yet made sure to protect her face from being videotaped in her own open-to-the-public Hearing. This
error substantially interfered with Maravelias’s right to a fair trial, since it enabled Petitioner to persist
in her storied dishonesty while testifying, without the accountability of being videotaped.
I. (b) THE COURT DISOBEYED THE WITHIN-30-DAYS HEARING REQUIREMENT OF 633:3-A III-c
39. The Petitioner filed her Motion to Extend on 1/5/18, with the temporary extended Stalking Order,
pending hearing, issued on 1/12/18 by Judge Sharon DeVries. Respondent objected, and a Hearing
was finally scheduled for Thursday 2/15/18 – 34 days thereafter. Furthermore, the Court did not
actually afford Respondent an opportunity to hold the Hearing until 2/20/18 – 39 days after extension.
40. Since the Court violated Respondent’s state and federal constitutional rights to a speedy trial, and
even violated the specific statutory requirement in RSA 633:3-A III-c, the extended Order is null and
void. (see Id., “A defendant shall have the right to a hearing on the extension of any order under this
paragraph to be held within 30 days of the extension.”)
J. THE COURT MAY NOT EXTEND AN ALREADY-ILLEGAL STALKING ORDER ISSUED IN PLAIN-
ERROR CONTRAVENTION OF PERTINENT STATUTORY LAW AS INTERPRETED BY THE SUPREME
COURT; THE COURT FAILED TO EVEN RULE ON A MOTION TO DISMISS ON THIS ISSUE
41. As documented in Respondent’s ignored 3/29/18 Motion to Dismiss, the original Stalking Order was
issued in violation of the advance notice requirement of RSA 173-B:3 as clarified by NHSC case law.
42. Thus, it is unfair to subject Respondent to a different and lower standard of Stalking Order extension
(633:3-a III-c.) predicated on a valid initial finding of stalking in principio (a higher standard under
633:3-a III-a.) when such an original finding of stalking was never lawfully made in this matter.
K. THIS COURT’S ACT OF IGNORING RESPONDENT’S TWO MOTIONS IN THIS CASE AND
NEGLIGENT FAILURE TO SPECIFICALLY ADDRESS HIS ARGUMENTS AND EVIDENCE IN ITS
FINDING CONSTITUTE A CLEAR VIOLATION INTER ALIA OF MARAVELIAS’S FOURTEENTH
AMENDMENT SUBSTANTIVE AND/OR PROCEDURAL DUE PROCESS RIGHTS
43. Respondent filed a Motion to Dismiss Extension and Vacate Stalking Order dated 3/29/18 and a
Motion for Discovery dated 5/29/18 in the case at bar. The opposing party filed reply briefs to both
motions. The Court heard oral argument on these motions from both parties on 6/8/18 at the Hearing.
8
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44. The Court’s 6/15/18 Order granting extension completely ignores these motions, as well as the legal
issues they raised. The Court simply cast them out into the wind, refusing to rule on them either way.
45. In neglecting to perform its required “ministerial act” of ruling on critical motions, the Court violated
Maravelias’s federal due process rights and state constitutional right “to be fully heard in his defense”.
L. THE STALKING STATUTE IS FACIALLY INVALID AND/OR INVALID AS APPLIED ACCORDING TO

THE STATUTORY OVERBREADTH AND/OR VAGUENESS DOCTRINES, AS THE COURT BASELESSLY
FOUND LAWFUL SPEECH TO THIRD PARTIES TO CAUSE “REASONABLE FEAR” AND THREATEN
PETITIONER’S “SAFETY AND WELL-BEING”
M. THE COURT’S FINDING THAT RESPONDENT’S COMMUNICATIONS CREATED “REASONABLE

FEAR” IS INCORRECT AND/OR INVALID, SINCE RESPONDENT NEVER EXPLICITLY THREATENED
PETITIONER NOR IMPLIED HARM TO ANYONE, AND SINCE NONE OF HIS CONDUCT WAS
OBJECTIVELY LIKELY TO BE FOLLOWED BY VIOLENCE OR CRIME
N. PETITIONER’S NEW SURPRISE-ACCUSATION OF “OBSESSIVE” CONDUCT WITH THE 4/6/17

PICTURES APPEARED NOWHERE IN HER EXTENSION MOTION; THE COURT AGAIN VIOLATED
RESPONDENT’S RIGHT TO ADVANCE NOTICE OF ACCUSATIONS BY RELYING ON THEM
O. THIS COURT’S ORDER IS INVALID INSOFAR AS IT IS PUNCTUATED BY AN ENTIRELY

UNSUPPORTED “SOLE PURPOSE OF HARASSING AND STALKING THE PETITIONER” COMMENT
WHICH IS BUT A PUSILLANIMOUS ACT OF VERBAL POSTURING TO MAKE THE OUTRAGEOUS
EXTENSION ORDER SOUND REASONABLE; THE COURT OPERATES WELL OUTSIDE ITS GENERAL
EQUITABLE POWERS IN SLANDERING MR. MARAVELIAS, THE VICTIM, AS ENGAGED IN THE
CRIME OF “STALKING” WITH SUCH GRATUITOUS OBITER DICTA EXPRESSED ALONGSIDE NO
FACTUAL BASIS THEREFOR WHATSOEVER
46. This illogical comment in the Court’s Order would have one believe that Mr. Maravelias’s choice to
respond to Attorney Brown’s letter threatening him with a lawsuit was not a “legitimate” “behavior”,
and that said act of responding to the threatening letter shows a “sole purpose” of “stalking” the
daughter of Attorney Brown’s client. While such a creative endeavor of absurdity might be humorous
elsewhere, it is right-appalling within a context where Respondent’s basic liberties are at stake.
47. This Court’s automatic, reflexive rejection of any and all of Mr. Maravelias’s evidence or arguments
in toto against Petitioner and/or her father in its findings has become an irrefutable pattern, especially
given its unsustainable exercise of discretion in the related Petition against Mr. DePamphilis which
completely ignored all of Mr. Maravelias’s truthful evidence (testimony, letters, and pictures) and
instead asserted an imagined, alternate reality wherein Maravelias gave “no credible evidence”.
9
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A56 A56
A57 A57
A58 A58
ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY
Docket No. 473-2016-CV-00124
v.
Paul Maravelias
REPLY TO PETITIONER’S OBJECTION TO RESPONDENT’S MOTION FOR

RECONSIDERATION
NOW COMES the Respondent, Paul Maravelias, and replies to Petitioner’s Objection to
Respondent’s Motion for Reconsideration dated 7/2/18. The Respondent prefaces this reply with
his apologetic regret for the Court regarding the volume of litigation paperwork in this case which
it must review. However, this is the sole fault of the Petitioner and her ongoing bad-faith conduct
of legal abuse and misrepresentation of crucial facts in filings, which necessitate correction for
defense of Respondent’s besieged rights. In support hereof, he represents as follows:
1. Petitioner’s objection challenged two of Respondent’s legal arguments within Heading I.
of his Motion for Reconsideration. Assuming that Petitioner’s objection to said arguments is
sound, the Court should still grant Respondent’s Motion for Reconsideration and vacate the
Stalking Order, due to his other valid, uncontested legal arguments in Headings A, B, C, D, E, F,
G, H, J, K, L, M, N, and O from the same Motion for Reconsideration.

1
A59 A59
2. Respondent’s two arguments in Heading I. of his Motion for Reconsideration were
nonetheless valid, and Petitioner commits various glaring errors while contesting them.
A. The Court’s Order Limiting Respondent’s Right to Videotape the Entirety of the Public
Hearing Was Illegal, as Respondent’s Motion for Reconsideration Accurately Argues
3. Paragraphs 10 through 14 of Petitioner’s objection are unoriginally self-plagiarized straight
from her identical 2/20/18 Motion opposing the video recording and contribute very little to the
legal question at bar.
4. Paragraph 10 of Petitioner’s objection filing does well to regurgitate the familiar verbal
contrivances of obscurantist posturing regarding the “minority” of the Petitioner, the “infatuation”
Respondent had had for her two whole years ago, and the fact that she had been a “high school
sophomore” two years ago.
5. However, these extraneous details are relevant to a focused legal question on whether the
Court violated a public recording right only in the Petitioner’s delusional fantasyland.
6. Petitioner then asserts that videotaping the full Hearing, including her, would have
“intimidated and victimized her”.
(i) Christina DePamphilis Claims She Would Have Been “Intimidated and Victimized”
to Have Been Recorded at Her Own Public Hearing Where She Chose to Accuse Paul
Maravelias of Stalking
7. Petitioner fails to explain why the lawful, routine condition of being video recorded in a
public building (something ubiquitously performed in everyday modern society, whether on
municipal security cameras, shopping mall/storefront cameras, social usage of cell-phones, etc.)
causes her to be “intimidated or victimized”.
8. Maravelias accurately inferred for the Court during the Hearing that Christina
DePamphilis’s confusing sensitivities regarding his recording her own accusatory Hearing betokened
2
A60 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087 A60
a manifest indication of bad-faith conduct: that she is a false-accuser, knows it, and is ashamed of her
abuse of Mr. Maravelias – and wants to keep it as hidden from the public eye as possible.
9. However, the question of whether or not being recorded at someone’s own public court
hearing causes them to feel “intimidated and victimized” is still completely irrelevant. The legal
error Maravelias’s Motion for Reconsideration raised did not have anything to do with the
Petitioner’s feelings. It was a question of law and court rules, and the Petitioner’s personal feelings
sadly are not relevant. Thus, the remainder of Petitioner’s objection is scrutinized for any actual
legal arguments against the validity of Respondent’s argument(s) concerning this question.
(ii) Christina DePamphilis Claims Maravelias Sharing the Recording of Her Own
Court Hearing Against Him is “Harassment” of Her Family
10. The Petitioner then claims in Paragraph 12 that Maravelias posting a recording of the
Hearing on the internet is “harassing” of “the DePamphilis family”.
11. The Hearing in question is a court case in which Christina DePamphilis attempts to extend
a Stalking Order, which Maravelias has long-maintained was begotten of her perjury in 2017.
12. The Hearing is already fully public, audio recorded, and open for attendance by any members
of the general public. Her statement that sharing a recording of said Hearing is “harassment” therefore
makes absolutely no sense. That is, unless if viewed in connection to her malicious bad-faith conduct
of woeful legal abuse against Mr. Maravelias. Then it makes perfect sense.
13. Christina DePamphilis evidences her own obsessive, stalking-type behaviors against Mr.
Maravelias in this section of her filing: she includes a footnote to Mr. Maravelias’s private business
software product online support forum, which requires user registration to participate. She links to
Maravelias’s post and falsely claims that he “boasted about posting the video to YouTube”. The full
text of Maravelias’s referenced-by-Petitioner post is as follows, and mentions “YouTube” nowhere:
3
“[quote="HomeTownCincy"]I knew I liked you guys! :D NRA instructor here, certified many people for CCW
licenses. Good to know some more fellow weather people that also have a knack for freedom.[/quote]
Please pray for my besieged rights to be restored to me expeditiously, along with my 2 firearms stolen by the
Windham, NH oath-breaker thug police. Since December 2016 I've been dealing with a psycho family in town
and their false-accusing pig daughter (first girl I ever asked on a date - big mistake) who have since been able to
strip me of my firearms by perjuriously whining about "stalking" and getting a criminally falsified restraining
order against me (see other thread I made).
This is how severely leftists and feminists have corrupted our system of laws: if I had shot someone dead in
cold-blood, it would have rightly been weeks or months since the criminal system proved me guilty of a crime
and formally deprived me my right to arms through due process of the law after a proved felony conviction of
homicide.
By comparison, in the civil court (technically non-criminal) "protective order" bullshit system, this one sore
vindictive man in town was able to have his fat daughter whine about "fear" in a 4-page "stalking petition"
containing outrageous and unverified lies against me, and 6 mere hours later cops came to my house to seize
firearms without any due process whatsoever, or even any accusation whatsoever that I'd committed any crime
(just typical whining-BS about "fear", such as, "In summer 2016 I was at Paul's house for his brother's
graduation party and he was looking at me in his backyard" - I kid you not).
The whole experience has me so infuriated that I'd possibly like to change career paths down the road to fight
this demented bullshit however I can, and have freedom back at least in New England. Moral of the story is to
steer-clear of neurotic feminists and modern women as much as possible. I'm only 22, so it is particularly sad
from my perspective to watch the sort of degenerative witch-hunt hatred continuously systematized into a
cultural attack on any sort of appropriate social expression of male sexuality (such as asking for a date). I'll
think twice before I ask a girl out to dinner again, and that's coming from a decently successful and physically
attractive (if I do say so myself) young man. Sad time for America.” – Maravelias’s private 5/16/2018 post at
http://wsv3.com/forums2/viewtopic.php?p=18222#p18222
14. Thus, the Petitioner lied to this Court in her 7/2/18 filing when claiming Respondent
mentioned “YouTube” in his post at the provided URL. He mentioned “YouTube” at the court
hearing itself; indeed, he has uploaded the video of his public Hearing there1, where one finds
countless other videos of civil Stalking court hearings, from New Hampshire2 and other states alike.
15. That the Petitioner, Christina DePamphilis, has been gaining illicit access to and prowling
Maravelias’s private web forums clearly demonstrates a strange, perverse, and unhealthy obsession
she has for the Petitionee, which continues to this day.
1
https://www.youtube.com/watch?v=ErHhybEI_3w, https://www.youtube.com/watch?v=eAIuzOJQWLY
2
E.g. https://www.youtube.com/watch?v=N12qa6q58OM, https://www.youtube.com/watch?v=Nxbc0mZoSws, etc.
4
A. (iii) Christina DePamphilis Finally Makes a Legal Argument About the Videotaping
Question in Paragraph 14, That it “Advances an Overriding Public Interest”
16. The only actual legal argument Petitioner advances against Respondent’s argument that the
Court violated the rules appears in Paragraph 14. She quotes a part of Circuit Court Rule 1.4(f) and
claims the injunction she requested “advances an overriding public interest”.
17. However recognizing that such an “overriding public interest” would have been necessary
to show before warranting the unusual injunction, the Petitioner fails to state what exactly that
public interest is. More importantly, neither did she ever at the Hearing nor in her 2/20/18 Motion.
18. The Petitioner alludes to her private interest in keeping her baseless stalking accusations
under-wraps. But, this is clearly not a “public interest”, nor was any service of any “public interest”
ever shown by Petitioner when debating this matter before the Court during the Hearing on this
matter.
19. Quite to the contrary, a compelling public interest in the reduction of wasteful false
accusations and in holding accusers accountable is served by the mandatory video recording of such
Hearings.
20. Circuit Court Rule 1.4(f) mandates in clear language:
“the party or person seeking to prohibit or impose restrictions beyond the terms of this rule on
the photographing, recording or broadcasting of a court proceeding that is open to the public
shall bear the burden of demonstrating: (1) that the relief sought advances an overriding public
interest that is likely to be prejudiced if the relief is not granted; (2) that the relief sought is no
broader than necessary to protect that interest; and (3) that no reasonable less restrictive
alternatives are available to protect the interest.”
21. At no point did the Petitioner highlight for the Court an “overriding public interest”
legitimizing the injunction; therefore, the Court erred in limiting the Respondent’s recording rights.
22. Furthermore, Circuit Court Rule 1.4(f) states:
5
“Any order prohibiting or imposing restrictions beyond the terms of this rule upon the
photographing, recording or broadcasting of a court proceeding that is open to the public
shall be supported by particularized findings of fact that demonstrate the necessity of the
court’s action.”
23. In granting the Petitioner’s request to limit the recording rights, the Court made no such
particularized findings of facts. Therefore, the Respondent’s recording rights were violated
regardless – even if an “overriding public interest” had been shown by Petitioner.
24. To the Court’s credit, it would have been impossible to author a “particularizing finding of
fact” elucidating the overriding public interest which the injunction served, since there never was
any indicated by Petitioner to begin with. The court rules were unquestionably violated.
25. The Petitioner makes sure to address the separate topic of whether this error is grounds for
reversal, likely given the palpable undeniability of said error. She advances a highly strange
argument in Paragraph 15 that, just because Respondent has access to audio recording transcripts
independently of his video recording, therefore the injunction against video recording did not enable
Petitioner to testify without the extra accountability of being videotaped while testifying. This
argument is clearly absurd. Respondent was prejudiced by the Court’s error.
B. The Court Did Violate the Hearing Requirements of RSA 633:3-A, III-c., as Respondent’s
Motion for Reconsideration Accurately Argued
26. In this portion of Petitioner’s objection, she raises all sorts of scattered, unrelated
diversions frantically skirting the only relevant fact that February 15th (the first Hearing date) is 34
days after January 12th (the extension date). This is the end-all-be-all of demonstrating that the
Court violated the statutory requirement of holding a “hearing” “within 30 days of the extension”.
27. Petitioner points out there is no speedy trial right in non-criminal cases. While this is true
within solely the Federal Bill of Rights, New Hampshire law specifically contains a statute
affording the right to hearing within 30 days, which was violated. Maravelias is also prepared to
6
advance well-supported legal arguments on appeal, if need be, that the nature of civil Stalking
injunctions and their impositions is “criminal-like”, and that therefore his Sixth Amendment rights
have indeed been violated. However, this endeavor is not presently necessary.
28. The Petitioner wrongly claims that Maravelias needed to have objected to the 30-days-
requirement violation, or even had an opportunity to. Maravelias was not afforded an opportunity to
be heard by this Court, after the 1/12 extension, until 2/15. The only objection he could have
possibly made at this point, after his right to a timely trial was already violated, would be to petition
the Court to invent a time machine, reverse the date two weeks, and reschedule the Hearing before
30 days elapsed on 2/11/18. Clearly, Maravelias never had the opportunity to object, and merely
expected the Court to fulfill its lawful duty after 1/12 to schedule a timely Hearing for him.
29. Furthermore, the Court specifically scheduled the Paul Maravelias v. David DePamphilis
Hearing for 8:30am – first on the docket – on 2/15, electing optionally to further delay the Hearing
on the instant case. Attorney Brown therefore insisted in moving forward with that case first.
30. Petitioner’s note that Maravelias declined the 2/20/18 opportunity to go forward is
absolutely misplaced; his rights under the statute to a hearing “within 30 days” had already been
violated, and his Motion for Reconsideration claims nowhere that the resultant extended
continuances into May and June were further violations of the rule.
31. Contrary to the Petitioner’s absolutely unsupported passing remark in Paragraph 23 that
“dismissal is not a remedy for any alleged deviation from the statute”, the Court is required to
dismiss the order extension if it violated Respondent’s rights and deprived him of a fair, timely
hearing. Indeed, the Supreme Court has vacated Stalking orders simply because the judge cited
unnoticed accusations found nowhere in the underlying petition in the finding of facts form –
exactly as has happened to Mr. Maravelias. See ignored Motion to Dismiss and South vs. McCabe,
943 A.2d 779 (2008)
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Docket No. 473-2016-CV-00124
v.
Paul Maravelias
MOTION TO STRIKE
NOW COMES the Respondent, Paul Maravelias, and moves this Court to strike portions of
Plaintiff’s 7/2/18 Objection to Respondent’s Motion for Reconsideration. In support thereof, the
Respondent states:
1. On 7/2/18, the Petitioner filed the aforementioned objection to which Respondent is
replying in a separate pleading.
2. Paragraph 11 of Petitioner’s said filing must be stricken from the Court’s record due to
various estoppels and improper presumption of facts not in evidence.
1
A. Judicial Estoppel Prohibits Petitioner’s Paragraph 11
“Allegans contraria non est audiendus”

“A person making contradictory allegations is not to be heard.” – Broom's Legal Maxims
3. Judicial estoppel is a form of estoppel which prohibits legal actors from taking self-
contradictory positions. “Courts have observed that ‘the circumstances under which judicial
estoppel may appropriately be invoked are probably not reducible to any general formulation of
principle[.]’” New Hampshire v. Maine, 532 U.S. 742, 750, 121 S.Ct. 1808, 1815, 149 L.Ed. 2d
968 (2001) (quoting Allen v. Zurich Ins. Co., 667 F.2d 1162, 1166 (4th Cir. 1982)).
4. The doctrine is however adopted through a few generic elements which the Court ought
to hold as applicable in this case.
5. American courts have interpreted three core elements of judicial estoppel:
1) The later position must be clearly inconsistent with the earlier one;
2) The earlier position was judicially accepted, creating the risk of inconsistent legal
determinations;
3) and the party taking the inconsistent position would derive an unfair advantage or impose
an unfair detriment to the opponent if not estopped.
See Wilcox v. Vermeulen, 2010 S.D. 29, ¶ 10, 781 N.W.2d 464, 468.
6. In Paragraph 6 of Attorney Brown’s 4/20/18 Motion to Strike filing in the related Paul
Maravelias v. David DePamphilis case, he wrote for the Court that the “Stalking Order is in
effect based on [Maravelias’s] previous obsession for [the Petitioner]”.
7. But, in Paragraph 11 of his 7/2/18 filing in this case, he claims that “Respondent’s
obsession with Christina has persisted” since “February 2017”.
8. Clearly, it was only this Court’s baseless, asinine, and unsupported act of libel on 6/15/18
to pronounce Mr. Maravelias as having a “strange, unhealthy, and perverse obsession [with
2
Plaintiff] to the present day” which gave Attorney Brown a sense of renewed validation to make
new and inconsistent claims against Mr. Maravelias which he knows to be entirely false – so
much so that he would not even bring himself to claim Maravelias has an ongoing “obsession”
with the Petitioner in the same 4/20/18 filing which is itself riddled with many other false
disparaging comments against Mr. Maravelias, though even they less blatantly false.
9. The continuity of the identity of the parties is not open for debate. David DePamphilis
testified that he “stands by what we [the Petitioner] said”, making reference to the Stalking
accusations against Mr. Maravelias. He is liable for her through the maxim of respondeat
superior. The Petitioner did not deny any of the claims made by Attorney Brown in the Stalking
case against her father. The DePamphilis legal actors have adopted fickle characterizations of
Maravelias which change with the winds of what they can reasonably expect to get away with in
a court filing.
10. Thus, the Petitioner’s later position (that Respondent has an “obsession”, 7/2/18) is
clearly inconsistent with the earlier one (that Respondent had a “previous obsession”, 4/20/18).
11. Moreover, “the earlier position was judicially accepted, creating the risk of inconsistent
legal determinations”; nowhere in the Court’s orders on the 4/20/18 Motion to Strike was a
finding of a “present obsession” made regarding Mr. Maravelias, nor in that whole case.
Furthermore, the Court made verbal comments during the Hearing in the instant case indicating
its recognition that there clearly is no “obsession”, and never adopted this new position now
advanced by Petitioner until doing so sua sponte in a baseless 6/15/18 Order.
12. Moreover, “the party taking the inconsistent position would derive an unfair advantage or
impose an unfair detriment to the opponent if not estopped”, since Petitioner grounds her 7/2/18
3
objection to Respondent’s Motion for Reconsideration in the absurd notion that he has a “present
obsession” with her.
13. Therefore, all the requisite elements are satisfied, and a judicial estoppel is created. Thus,
the Court ought to strike Paragraph 11 of Petitioner’s filing from the record.
B. Collateral Estoppel Prohibits Petitioner’s Paragraph 11
14. Whether or not the Respondent had an “obsession” was a specifically litigated issue in
the original 2017 hearings prior to Judge Stephen’s reckless issuance of a Stalking Order against
Mr. Maravelias because he invited a young woman to dinner and never spoke to her ever after
the day of the rejection; his finding of fact specifically mentions the term “obsession”.
15. On 1/5/18, Petitioner motioned the Court to grant an extension on the same Final Order
of Protection. This Motion contained the term “obsession” absolutely nowhere. I.e., it was
evident by then that Maravelias was only “obsessed” with getting his basic rights restored to him
and having this fraudulent legal abuse and harassment against him come to an end.
16. Therefore, a collateral estoppel is also created, since the issue of an “obsession” was first
litigated and then nowhere renewed in the Petitioner’s extension motion; thus, it is precluded.
17. Therefore, the Court should strike Paragraph 11 of Petitioner’s 7/2/18 objection.
C. Petitioner’s Paragraph 11 Assumes Facts Not Found in Evidence
18. The text to be stricken suggests Respondent “has issued writings to Christina’s parents,
her teachers, and others which directly and profanely impugned Christina’s character”.
19. Maravelias notified an honor society about his abuser’s criminal conduct and responded
to Attorney Brown’s threatening letter. But, he never issued writings to the Petitioner’s
“parents”.
4
20. This is not a legal argument; it is false assumption of fact non-existent in the record.
Thus, it should be stricken.
WHEREFORE, the foregoing compels the Respondent, Paul Maravelias, to pray this
Honorable Court:
I. Grant this Motion;
II. Strike Paragraph 11 of Petitioner’s Objection to Respondent’s Motion for

Reconsideration from the Court’s record; and
III. Grant such other relief as may be just and proper.
PAUL J. MARAVELIAS,
in propria persona
July 5th, 2018 __________________________________
5
ROCKINGHAM,SS SALEM DISTRICT COURT
Docket No. 473-2016-CV-124
v.
Paul Maravelias
'
PLAINTIFF S MOTION TO EXTEND DURATION OF STALKING FINAL
ORDER OF PROTECTION
NOW COMES the Plaintiff Christina DePamphilis, by and through her attorneys,
Preti, Flaherty, Beliveau & Pachios, PLLP, and hereby move this Court to extend the
duration of the Stalking Order issued against Defendant. In support of this Motion,
Plaintiff states as follows:
1. In an Order dated February 7, 2017, after hearing testimony over three
days, this Court(Stephen, J.) granted a Stalking Final Order of Protection against
Defendant.
2. The Stalking Final Order of Protection is in effect for one year and expires
on February 6,2018. Under RSA 633:3-A, III-c, a stalking order:
"may be extended by order of the court upon a motion by

the plaintiff, showing good cause, with notice to the
defendant, for one year after the expiration of the first order
and thereafter each extension may be for up to five years,
upon the request of the plaintiff and at the discretion of the
court. The Court shall review the order, and each renewal
thereof, and shall grant such relief as may be necessary to
provide for the safety and well-being of the plaintiff."
RSA 633:3-a, III-c.
1
12623464.1
A72 A72
3. The Stalking Final Order of Protection issued by this Court is necessary to
provide for the safety and well-being of Plaintiff, a 17-year old high school student.
4. Since the Court issued the Final Order of Protection in February 2017,
Defendant has waged a campaign of harassment against Christina DePamphilis and her
family, including but not limited to:
(a) participating in the composition of a profane and vile letter to the Depamphilis
family in March 2017, libeling the reputation of Plaintiff. See Exhibit A (letter);
(b) sending a letter to Plaintiff's counsel promising to "go nuclear and utterly
destroy (Christina's) academic and professional future..." See Exhibit B
(11/02/2017 letter);
(c) subsequently, on December 10, 2017, sending a defamatory e-mail to

Plaintiff's high school teachers, lamenting that he has had his firearms taken away
and again libeling Christina and seeking her removal from the National Honor
Society. This conduct resulted in Defendant's arrest for violating this Court's
Stalking Order. See Exhibit C (e-mail in question) and Exhibit D (Court
Summary reflecting Defendant's arrest for violating the Stalking Order); and
(d)despite warnings to cease and desist, waging an on-line campaign of

defamation against Plaintiff's father, offering online to provide a book to the
public entitled David The Liar. See Exhibit E (12/28/2017 screen shot).
5. Despite this Court's intervention, Defendant has been unwilling to abide
by the Stalking Final Order of Protection and to simply leave Plaintiff and her family
alone. Defendant's conduct since issuance of this Court's Stalking Order has been
harassing, criminal, defamatory, and utterly frightening to Plaintiff and her family.
6. Defendant continues to live in close proximity to Plaintiff. Only by
extending the Stalking Final Order of Protection for a further year (and longer if
necessary) will Christina's safety and well-being be protected.
7. Defendant objects to this Motion.
2
12623464.1
A73 A73
WHEREFORE,for the reasons set forth above, Plaintiffs Sarah Ferrante and Ron
Ferrante respectfully request this Honorable Court to:
A. Extend the Stalking Final Order of Protection for a further year (February
6, 2018 to February 2019); and
B. Grant such other and further relief as may be just and proper.
CHRISTINA DePAMPHILIS
By her attorneys,
PRETI,FLAHERTY,BELIVEAU
& PACHIOS,PLLP
Dated: January 5, 2018 By:

Simon R. Brown, NHBA #9279
57 North Main Street
P.O. Box 1318
Concord, NH 03302-1318
(603)410-1500
CERTIFICATE OF SERVICE
I hereby certify that on this 5th day of January 2018, I forwarded a copy of the
foregoing Motion to Extend Duration ofStalking Order to Defendant.
Simon R. Brown
3
12623464.1
A74 A74
Exhibit A
A75 A75
P.S. for David: Also sent copies to Amy Anderson and Alice
DiPrima, since Paul said they know about your other sick
abuses since they came to his court hearing against you
3/17/17 To: David Depamphilis
David, I'm a girl from Windham and I am so sickened and so outraged at YOU and your INSANE,
WHACK() parenting of Chrissy that I can't help but vent . I was already pissed at how you treated my
friend Paul when he asked her out but I've learned recently of something new that is just unbearable...
Does it not bother you that there's a FUCKING 20 YEAR OLD COLLEGE MALE, MATT
LALIBERTE,IN YOUR YOUNG DAUGHTER'S FUCKING BEDROOM???(See attached PICTURE I
saw on her social media). Did you even fucking know about this???? Do you seriously not know she has a
s azsz MAN-WHORE DOUCHEBAG • .., -as a
the als"(that means he's FUCKED 201- GtRLS an:
DAUGHTER IS NEXT). He almost TWENTY-ONE FUCKING YEARS OLD ano Is a. COLLEGE
SOPHOMORE at RPI. Don't act for one ripfucking second like you are ignorant that this has been
happening, you know full well and probably don't even give a shit. You just empower that spoiled nice-
girl-turned-whore to get whatever she wants, even if it means abusing others and causing GREAT
unhappiness for her own self when she GETS PLAYED BY a FUCKING OLD MAN (Matt LaLiberte
graduated WHS years ago and he's a KNOWN, REPUTABLE ASSHOLE). NOBODY respects him even girls
HIS OWN AGE.(Unlike Paul, since Matt is a fuckboy, why the FUCK does he need to come home from
college and try for some FUCKING 16-YEAR OLD girl. Makes you wonder huh?)
As I said I'm a friend of Paul Maravelias, the only guy who truly loved your daughter, who by comparison
you FUCKING ABUSED and LIED ABOUT to a court, getting a FUCKING RESTRAINING ORDER against him
through UES, and now you have someone just as old except a FUCKING FREAK WHORE DICKHEAD
STD-INFESTED MAN going off with your DAUGHTER?!?!!? Are you shitting me David -Paul told
me(and many others) every last DETAIL of your whackjob insane lunatic reaction at him when he asked
Chrissy out, and you pretended out of thin fucking air that he was some VIOLENT person, and row you
sit back and clap, widdle your fucking thumbs when an AL: 1 - 05-21-YEAR OLD tie SAVE a;-,e. - -
MAN-SLUT ASS,-OLE !,`A'7 A3OUT TO :UCK a -:
EXCUSE of a father.
You can't imagine how REPULSED anyone who knows about this is. Not that I'm much in the loop
socially with the current 10th grade, but I know there's NOONE dating someone THAT MUCH OF A
DICKHEAD MAN-SLUT WHORE,LET ALONE THAT MUCH FUCKING OLDER. And Chrissy of all fricken girls?
Always so young and innocent? It is sick and revolting, and you and Laurie just sit the fuck around and
do NOTHING, while my friend Paul deals with his property SIEZED BY COPS and a fucking UNJUST
RESTRAINING ORDER on his record, because he waited 5 fucking years for her and loved her, and you
flipped the fuck out at him And instead MATT THE 20 YEAR OLD FUCKBOY gets to TAKE ADVANTAGE
OF YOUR DAUGHTER as HIS NEXT PIECE OF PUSSY.this is sick beyond words.
I won't lie that I am mostly so pissed off because of the twisted, warped, sick comparison to how you
treated paul. I watched him for years love this girl and he would always talk about how he's waiting for
her, and working etc. I know he had good "other options". He showed me his recording when your EVIL
Page 1 of 9
A76 A76
BITCH wife Laurie lied "She's not allowed to date yet ... and there's 'such a huge' age difference". WOW,
I guess not when it comes to some fucking DICKHEAD SLUT with a "body count over 20"(my friends
words and total fact) of the SAME FUCKING AGE then the rules are different!
This is the same evil bitch CRAZY MOTHER who took Chrissy and a friend to see a FUCKING
PORNOGRAPHIC FILM. Are you fucking kidding me,"my mommy took me to go see fifty shades
darker!!" ??? "Wow,imagine what else my mommy would only get slightly-angry about!!!" I heard that
from my friend and she thought it was insane and shocking and sick that Laurie would do that. That
same friend was FUCKED by Matt LaLiberte when she was PISS DRUNK and she never wanted to do
it., tcza regrets NICE JOE DAVID, -- S.= ".'E MAN s ,̀'"0:2.7, DAUGHTER'S FUCXING
BEDROOM AND HERE'S THE PICTURE ATTACHED. And she fucking PUStX/..' t
I MAGINE WHAT OTHER FUCKING PICTURES EXIST!
1u mdne yuur ev7vanript, cnvz,ne. tir.k.4a.s.d.tnirl me that W)I1 and Chrissy LIED about him in
court to try to make him look like a creepy sex-crazed weirdo by claiming that as he was asking her out
on her birthday he claimed it was because it was her age of consent so they could have sex.(??) That is
FUCKING CRAZY and he NEVER said that, I listened to his WHOLE recording of that exchange, and how
FUCKING SICK that the guy who winds up in your daughter's bedroom is the REAL ONE WHOS THE
SEX-SEEKING FUCKBOY, a TWENTY YEAR OLD MAN who has a "body count in the 20s", while Paul stayed
a FUCKING VIRGIN for Chrissy. How fucking indescribably sick, twisted, and WARPED that you LIED about
him in this particular way, and the guy who gets to swoon your fucking YOUNG,16-YR-OLD daughter IS
I N FACT THE SAME HOOKUP-SEEKING SEX PLAYER FUCKHEAD LOSER that you made out my
innocent gentleman friend to be.
You've driven away a loving, self-sacrificial and respected guy and caused Chrissy to instead find a
FUCKING DICK MAN-WHORE ADULT who is probably teeming with more different STDs than number
years Paul has spent making himself attractive to your daughter according to her ACTUAL VALUES, which
it seems(and her friends tell me)shes now COMPLETELY LOST, and is on her way to become a FUCKING
WHORE, because of your parenting. Nice fucking job DAVID.You messed up your first child and now
,c1.. re Are;i on your to 00 it all over again (except you are WAY more personally guilty with Chrissy).
Paul told me when you screamed at him you called Chrissy a "young child" while he's an "adult" and
"she's a very quiet girl, doesn't party, a few years behind her peers, etc". WELL GUESS WHAT you
fucking hypocrite, have yourself a lookat the pictures of your daughter DRINKING and PARTYING WITH
WAY OLDER MEN from this January (attached). Looks like your either a real ignoramus or a total fucking
liar, huh? Oh but what, its definitely the second one, because you claimed that MY FRIEND said and did
things that he never did, to try to get a STALKING RESTRAINING order against him, and you FUCKING
KNEW you were lying because you apparently had your lawyer shut down his audio recording that
proved his innocence and that you all lied.
I hear Chrissy just had her confirmation and I remember mine. I remember that BEARING FALSE
WITNESS AGAINST YOUR NEIGHBOR is a mortal sin, and YOU CAUSED her to do it. YOU CAUSED a young
person to sin. From what I hear she doesn't give a red fuck about her values anymore and just went with
the flow at CCD. Like most of the other whorish girls. When I told that to Paul, he took it so hard (he
already knows most of this but I'm sending him a copy of this as well), because its clear his 5 years of
Page 2 of 9
A77 A77
sexual denial in her name are worth nothing if she goes off a becomes a WILD FUCKING ANIMAL like you
have caused David.
People are talking about this David, about you. Paul said he will make sure everyone knows what you
have done, and now with this new MATTHEW LALIBERTE 20 YEAR OLD MAN in your
daughter's EFFING BEDROOM and doing god knows what else, it has just because 100,000 times more
sick, disturbing, and backwards. You're an abusive, failure, liar parent, and really a criminal since you lied
to a court. also CHRISSY KNOWS that Matt is a fucking whore douchebag and has fucked over 20 other
girls including one of her OWN friends while she was PISS DRUNK, SHE KNOWS that and she DOESN"T
EVEN MIND. You heard that rigth. That is so fucking warped and sick that she's lost her values and every
D unce of self-respect iike that. What do you expect TrOM someone who would lie through her teeth
a bout a guy who sacrificed the world out of love for her. She's a sick bitch now and its YOUR FAULT,
because she used to always be the sweetest girl. JUST LIKE NICK, she was very in touch with god and
family. Now she's becoming and EVIL fucking slut who wants to "fit in" and its 100% HER PARENT'S fault.
I know for a fact you knew Paul well for years and had a good relationship and he had deep respect for
you (i know because he would talk about you and he looked up to you even, why I have no fucking clue)
before you destroyed it by being a maniacal asshole and legally ABUSING him through total LIES (and
you know it. You fuck well know it or else you wouldn't have planned with your lawyer to shut down his
audio recording you disgraceful liar and nervous suppressor of the truth).
Now,thanks to you DAVID, theres an unthinkable SCUMBAG FUCKBOY in your daughter's BEDROOM
w ho ON THE OTHER HAND, NEVER GAVE A HALF A FUCK ABOUT YOU or Laurie as parents (or even knew
you at all), let alone about Chrissy as anything more than his NEXT'BODY COUNT'. His next PUSSY
SCORE. a once INNOCENT, YOUNG,SWEET, 16-YEAR OLD GIRL. How fucking sick. Real great
parenting, you warped asshole. when she could have had a committed and loving guy (very rare in my
experience as a pretty, female adolesent millennial), you know, my friend Paul who you drove away with
a fucking FALSE restraining order because he respectfully asked out the girl he loved and did nothing
else. what an AWFUL,SICK crime to have on your conscience David.
How the fuck is it even possible that you've corrupted you daughter to have a FLING with a fucking 20
;ear oid COLLEGE MAN wrier! she could have had a different older guy, if that's what she likes, who
A NYONE in my grade would consider infinitely more attractive and better reputation and let alone who
loved her so genuinely (I can say that because Matt Paul arid I went to HS together, unlike Chrissy and
Matt oh yeah because HES FUCKING ALMOST 21 YEARS OLD)and who had actual MORALS for her. In a
few month he will be 21 WHEN SHE'S 16 —the SAME RIPFUCKING AGES with Paul when your shit wife
lied to him "oh she's too young to 'date'! and that's a big age difference!". Why don't you read that liar
q uote, take the attached picture of 20-YEAR-OLD MAN WHORE MATT LALIBERTE IN YOUR
DAUGHTERS BEDROOM,and roll it up and SHOVE IT up your sick failed parent asshole.
The insane thing David is Paul said you think yourself as a honorable, honest person. Paul told me that
you are so fucked up in the head that you have done what you have done according to a story in your
mind that says your actions follow morals and principles and your faith. Why dont you grow a fucking
pair and realize that he's telling TONS of people what you did to him through LIES, and now you're
letting this SICK BASTARD GO FUCK YOUR DAUGHTER, and everyone I talk to thinks your a maniacal
asshole ("derelict father" was a good one I heard spoken of you. I learned a new word).
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A78 A78
For Chrissy's sake and her sake atone, please take care of this fucking bastard DESPISED WHORE MAN-
SLUT and make sure this MAN never comes near your daughter again.
-Anonymous because I was told in confidence about Matts perverted sexual conquests of 20+ other girls
and about Chrissy's friend that he FUCKED WHILE SHE WAS PISS DRUNK AND REGRETTED IT A LOT by
that same person and this will maybe get around (since I'm sending it to Rachel's and Amber's moms)to
her so I don't want to say my name
-PS I am writing specifically to you David and I demand you do not share or communicate any part of this
to anyone else (people could probably guess who i am)
Relevant phone numbers:
Paul Maravelias(doubt he'd talk to you): 603-475-3305
MATTHEW LALIBERTE, I.e. 20-YEAR-OLD COLLEGE SLUT FUCKER OF OVER 20+ GIRLS, LAST SEEN IN YOUR
DAUGHTER'S BEDROOM:603-571-0438
Page 4 of 9
A79 A79
ALL from your daughter's VSCO which I also have one (imagine what pictures
exist that i DIDN'T come
across). Here's the 20 YEAR OLD ADULT MAN SLUT in your DAUGHTER'S FUCKING
BEDROOM:
Page 5 of 9
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Two more she posted with the ASSHOLE MAN,PENETRATOR OF WELL OVER TWENTY OTHER GIRLS:
Page 6 of 9
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Chrissy partying and drinking in general in January at a 3am secret Friday night
rager on 1/21 (just
because of your little "oh shes so innocent and doesn't party etc, stay away your
in college" asshole
quote to my respectable friend):
Page 7 of 9
A82 A82
BTW I know who this other loser is belo
w. His name is victor and he he's a tota
with girls and is a big user(much mor l slut has threesomes
e than pot). Little detail for you. At leas
t even he's not FUCKING 20.
Page 8 of 9
A83 A83
Its alcoholic(seagram's calypso colada). Not that a 16 year old drinking is ANYTHING EVEN NEAR the
facts of what else is happening
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A85
Amy Anderson
2 Cardiff Rd
Windham,
NH 03087
David
depamphilis
Windham, NH
03087
A85
Exhibit B
A86 A86
November 2nd, 2017 To: Simon R. Brown
Paul J. Maravelias
Windham, NH 03087
In re David DePamphilis criminal defamation and continued frivolous legal threats
Attorney Brown,
I am appalled though unsurprised that you continue to abet my abusive criminal defamer David
in externalizing his evident self-frustrations in the form of ridiculous legal threats against an
innocent young man.
I must say my tolerance for this continued pattern of David's criminal behavior is wearing quite
thin.
I am writing you to demand that your client David N. DePamphilis cease and desist from his
hurtful course of written and spoken defamation against my good name and sacred honor. His
defamatory conduct against me has been appalling, cowardly, and ironically hypocritical.
David's defamatory conduct has satisfied both criminal and civil thresholds for slander and libel.
I exude with excitement to prosecute these criminal and tortious acts in a court oflaw, should
David unwisely decide to continue his loathsome intimidation against me.
I have been the victim of David's willful libel in many forms, ranging from the falsehoods
included in the original written stalking petition for his ego-protectionary, false restraining order,
to those included in your reply brief in the appeal case which claimed that I was likely to
"sexually assault" David's fat daughter. This was an outrageous act of defamation to which not
even David's sexually experienced 16 year-old daughter once alluded in the entire stalking
petition.
David DePamphilis's willfully false libel has also reached the internet. I possess documentation
of him calling me "mentally ill", a "sexual predator", and a "piece of shit stalker".
This petty act was anteceded by a vulgar internet post of harassment which David made against
me on his daughter's social media, proffering forth his 48 year-old middle finger against his
college-student victim. This risible act of puerile instigation has evaporated any lasting iota of
adult empathy for David's harmful acts against me. Seemingly everyone in Windham has
become disgusted with his outrageous course ofimmature harassment and criminal defamation.
I correct or clarify the following matters of objective fact contained in your letter:
A87 A87
• Regarding websites, I created some template registrations in the winter before deciding
upon a final course of action. I gave David a chance to end his criminal harassment and
apologize, but he did not. Therefore I maintain daviddepamphilis.com which solely
forwards to my book website, davidtheliar.com. I no longer own any of the other
domains, nor posted defamatory content on them.
• David DePamphilis is indeed an extreme "criminal abuser","bipolar criminal", and

"sexual pervert". These are demonstrably true statements and therefore do not constitute
Defamation. I ejaculate with bursting excitement to corroborate the truth ofthese
statements before a court of law, should my abuser make a poor decision to take me
there.
This will be a true shitload offun for me,and I direfully hope David allows me to have it.
I've really sharpened my rhetoric about the man since the February "stalking" hearings.
• My responsible text message to Amy Anderson from March contained zero willfully false
statements. The investigating officer had mislead me with this false information that
David was being investigated by the DCYF. One thing is certain: David the negligent
parent has allowed his daughter's life to be endangered on multiple occasions. I possess
abounding evidence for this, and I fear not to use it against him under RSA 639:3.
• I never stated that I was "co-author" ofthe referenced letter. I actually said that I knew
about the letter, and "aided" its author in composition. I reject the term "co-author", since
that implies the words themselves were mine. My own words would have been far worse.
Since I've just re-read this letter for the first time in a while per your attachment, I'll add
the following derogatory, rightfully insulting note. Unlike the author, I had known in
March that David's wild daughter had already been fucked raw by the man in secret at
David's beach house in February, days before her "confirmation mass" at my church. The
Windham-gossip-object slut had secretly absconded there behind David's back with that
man to get her barely-legal guts scrambled by his highly experienced, adult sexual organ,
mere days after meeting him.
Also unlike the author of that letter, I derive tremendous satisfaction and happiness from
the referenced 21-year-old man-whore boyfriend. I absolutely revel in the shame and
stinging, embarrassing hypocrisy he brings to my criminal abuser David, who days prior
to her sexual penetration called his daughter a "child" in contrast to a 21 year-old "adult"
(me)in order to insult me. Think ofthe enormous validation her subsequent whoredom
brings to my comparative act of nicely asking out her and her mother to dinner, when I
had wrongly thought she was still a respectable person. Of all humans currently on earth,
only Jacob Sipos inspires greater gratitude in my heart than Mr. LaLiberte. I thank God
for him.
A88 A88
• I challenge you to substantiate your accusation that I characterized my upcoming book as
an attempt to "publicly shame" my abuser. These words appear nowhere on my site, and I
disagree with this characterization as the primary focus of my important work.
For the record, David is an insecure and pusillanimous enemy of truth — a veritable terrorist
against free speech. He whined to a corrupt police-state government when I dared introduce
proof of my true words he lied about, and now he fittingly panics at the sight of my honorable
literary endeavor like an effeminate, fretful little child. For further insight into the criminal's
boundless hypocrisy, you can ask David why he had changed his original career plan in the 90s.
I am excited that you embrace such a latitudinous legal definition of Defamation. This will
undoubtedly aid my prosecution of David DePamphilis for slanderous and libelous acts, should
he decide to further his undue legal intimidation against me.
While I am a level-headed and law abiding young adult who would never physically harm David
DePamphilis nor any other person, I assure you that massive personal and legal consequences
will ensue for this unrepentant criminal should he decide to "up the ante" with me.
I possess troves of reputationally damaging information and assorted digital artifacts of David's
family members which I have not shared. If David continues in this warped path of conflict-
sowing instigation, I shall certainly broaden my exercise offree speech to document the shame
and guilt of this evil man and his deranged family.
David has always strangely obsessed over his daughter's college acceptance and financial
achievement, a masculinizing fixation he never seemed to project onto either of his male sons. I
shall go nuclear and utterly destroy her academic and professional future by publishing these
embarrassing artifacts on the internet, should David dare challenge me legally. Up unto this point
I have held-off, since my mind is not preoccupied at all with that ugly and disreputable whore.
I'm a young man of high confidence and dignity; thus I have better things to do than look like I
am trying to get revenge against some pathetic 16 year-old delinquent. It's up to David whether
this magnanimity of mine in addressing his conduct alone should persist.
Demand: Please inform your client that if he does not write a public written apology for his acts
of criminal defamation against me by November 8th, confessing that only willful perjury
animated the issuance of his vindictive restraining order, and petitioning the court for its
discontinuation, then I shall most certainly pursue all legal avenues to address my abuser's
tortious conduct.
I also demand that David receive professional psychological intervention for his manifest mental
disturbances. His conduct has been consistent with Persecutory-type Delusional Disorder with
Bizarre Content(DSM-V,297.1 [F22]).
David sure has chosen the worst person possible as a scapegoated victim for his legal abuse. I
hope he keeps it up. He'll see where it gets him.
Indignantly,
Paul J. Maravelias
A89 A89
Exhibit C
A90 A90
U.:172/201.7 Windham School District Mail - Fwd: Petition for Dismissal of NHS Student (unlawful conduct,ethics violations, and
substance abuse)
Matthew Malila <mmalila@windhamsd.org>
Fwd: Petition for Dismissal of NHS Student(unlawful conduct, ethics violations, and
substance abuse)
1 message
Colleen Smith <csmith@windhamsd.org> Mon, Dec 11, 2017 at 8.08 AM

To: Matthew Malila <mmalila@windhamsd.org>
Forwarded message -----

From: Paul Maravelias <paul@paulmarv.com>
Date: Sun, Dec 10, 2017 at 12:58 PM
Subject: Petition for Dismissal of NHS Student (unlawful conduct, ethics violations, and substance abuse)
To: "csmith@windhamsd.org" <csmith@windhamsd.org>
Cc: "ryoconnor@windhamsd.org" <ryoconnor@windhamsd.org>,"knaroian@windhamsd.org"
<knaroian@windhamsd.org>,"smckenna@windhamsd.org" <smckenna@windharnsd.org>
Mrs. Smith,
I write you coldly in your function as an employee of the Windham School District, for which I pay in taxes and
therefore demand accountability. In this message, I try to cast aside from my mind your role as one of the most
influential people in my life. This is a painful message for me to write.
With regards to your headship of the WHS National Honor Society chapter, I respectfully demand that Christina
DePamphilis be dismissed at once according to her rampant violation of Article IV, Section 1, Part D of the
NHS Constitution.
Christina is a delusional criminal who has committed felony Perjury(RSA 641:1) and misdemeanor False Reports
to Law Enforcement(RSA 641:4) at the behest of her abusive father David. She lied to a court to obtain a
"stalking""protective" order against me in order to.satiate her father's vindictive lust to harass and intimidate
me
with fraudulent legal abuse. As a result, I have lost my firearms with no due process whatsoever. Even appearing
at my own alma mater to give you Christmas chocolates would be an arrestable offense.
Please see my attached criminal complaint PDF for proof of her crimes.
Christina is also an out-of-control abuser of alcohol and psychoactive substances. The attached PDF contains
proof for some of this, however if you need documentation on her addictive marijuana habits I shall happily
send further documentation.
Christina has also bullied and harassed me on her social media, engaging in slanderous criminal defamation (RSA
644:11) that I am a "stalker" and openly middle-fingering me along with her father and 21-year-old boyfriend in
an attempt to provoke a disorderly response out of me (a violation of RSA 644:4, the Harassment statute). Here
is the link. The caption of this now-deleted post had identified me as recipient.
I cannot even begin to express in this one email the extent to which this psychotic criminal has broken the law
to
destroy the young man which you, Mr. O'Connor, and all my other beloved mentors spent so much effort
building.
I have recently finished the manuscript for my new book about Mr. DePamphilis's psychotic crusade of legal
abuse against me,"David the Liar", wherein I analyze the numerous cultural, ethical, legal, and psychological
diseases which my story illuminates. I will send you a copy in January. I did a great job.
https://mail.google.corn/mail/u/0/?ui.--28cik.2f2965bf3b8dsver=gNJGSxrCYso.en.&view=pt&q=csmith%4Oviindhamsd.nrg&
qs=true&search=queryitth=16045b 1157... 1/2
A91 A91
1 t2i2j. Windham School District Mail - Fwd: Petition for Dismissal of NHS Student(unlawful
conduct,ethics violations, and substance abuse)
•
Please be welcomed to share any of this with your colleagues or contact me for further info
regarding the
dismissal. Please do not relay this in any manner which could be construed an "indirect
communication" to
Christina lest she and her vindictive father have me arrested.
It is an ongoing sore embarrassment to the National Honor Society that such a delinquent
paragon of dishonor
has managed to fool her teachers into granting admittance thereunto.
Please follow-up with me when possible.
Kind regards,
Paul Maravelias
Cell:
Colleen Smith
Humanities Teacher
National Honor Society Advisor
603-537-2400
This e-mail is intended solely for the person or entity to which it is addressed and may contain
confidential and/or
privileged information. Any review, dissemination, copying, printing, or other use of this e-mail
by persons or entities other
that the addressee is strictly prohibited. If you receive this e-mail in error, please notify the sender
immediately and delete
the material from any computer.
DavidDePamphilisCriminalComplaint.pdf
"—I 5148K
https://mail.google.cornimail/u/0/?ui=2&ik=2f2965bf3bStjsver9NJGSxrCYso.en &view=.04=cs
mith%40windhamsd.org&qs=true&search=query&th=16045b1157... 2/2
A92 A92
Exhibit D
A93 A93
10TH CIRCUIT - DISTRICT DIVISION - SALEM
CASE SUMMARY
CASE No. 473-2017-CR-03516
State v. PAUL MARAVELIAS 10th Circuit - District Division
Location:
- Salem
Filed on: 12/18/2017
Agency Case Number: 874-17-396-AR
§ NH Identification Number 05MSP95241
from DMV:
CASE INFORN TION
Offense Statute Deg Date Case Type: Criminal

Jurisdiction: Windham
1. Stalking - Notice of Order 633:3-a,I(c) MISDA12/11/2017 Case
12/18/2017 Pending
ChargeED: 1448431C ACN:00874001700000396001 Status:
Arrest: 12/15/2017
PARTY I FORMATION
Defendant MARAVELIAS,PAUL
34 MOCKINGBIRD HILL RD
WINDHAM, NH 03087
White Male Height 5'11" Weight 170
DOB: 05/24/1995 Age: 22
DL: NH 05MSP95241
Arresting Agency Windham Police Department

4 Fellows Road
Windham, NH 03087
DAT E: 1 Cm in
12/11/2017 Complaint Narrative at Filing

after being served an order pursuant to paragraph III-a ofthe Stalking Statute, did knowingly
engage in an act ofconduct that violates the provisions ofthe order, an act ofcommunication as
defined in RSA 644:4,11, in that he threatened to destroy CD's academic career to herfather's
attorney and thenfollowed up with an email tofour(4) Windham High Schoolfaculty members
attempting to get her in trouble in school and National Honor Society,
Charges: 1
12/18/2017 Video Arraignment/Bail Hearing
12/18/2017 Arrest Warrant Index #1
12/18/2017 Supp. Affidavit for Arrest Warrant Index #2
12/18/2017 Complaint As Accepted For Filing
12/18/2017 Orders and Conditions of Bail (Judicial Officer: Stephen, Robert S) Index #3
$2500 Cash/Surety
12/18/2017 Adult Order of Commitment(Judicial Officer: Stephen, Robert S) Index #4
12/18/2017 Transport Order Index #5

FOR 1/17
12/18/2017 Waiver of Counsel Index #6

will retain his own
01/17/2018 Trial Management Conference
PAGE 1 OF 1 Printed on 12/19/2017 at 2:00PM
A94 A94
Exhibit E
A95 A95
www.davidtheliar con 170%
Maravelias's David the Liar straddles the intersection of

autobiography, personal philippic, and sweeping theological
polemic while unfolding the non-fictional account of his
real-life abuser David DePamphilis of Windham,NH,USA.
DAV I
Written as an exchange of letters between Maravelias and a
trusted friend, David the Liar propounds a summary of
David's injurious crimes before delving into an incisive ethical,
psychological, and social analysis of the middle-age father who
seems but an ordinary and innocent man on the outside.
Maravelias dissects the universally relevant themes of mental
illness, paternal psychology, criminal defamation, deviant
sexuality, interfamilial dynamics, projective false accusation,
and situational ethics which his story acutely evokes in the
context of 21st-century upper-middle-class New England
reality.
Maravelias's discussion matures into a cultural, legal, and

finally theological commentary on the far-reaching ethical
considerations evoked by David's criminal villainy. Maravelias
emphatically criticizes a host of corruptions in present
American law and culture which enable victimization of the
innocent, deriving ultimately from an unnatural atmosphere of
modernist infantilism. David the Liar closes with a foray into
the analytical lens of Christian scholastic theology and the
framework it provides for rationalizing David's past, present,
and future. PA
[o] U III 0 CV °N
A96 A96
ROCKINGHAM, SS SALEM DISTRICT COURT
Docket No. 473-2016-CV-124
v.
Paul Maravelias
DEFENDANT’S OBJECTION TO EXTEND STALKING ORDER
INTRODUCTION
In December of 2016, the Plaintiff’s father David DePamphilis begun a series of harassing and
intimidating behaviors against the Defendant, Paul Maravelias, including revenge-threats of
unspecified “legal action” unless Defendant capitulated to DePamphilis’s deranged will.
Over two weeks thereafter on 12/28/16, DePamphilis suborned his daughter Christina, the
Plaintiff, to file a fraudulent stalking petition against Defendant. The said petition boasted a
litany of malicious, fabricated lies regarding Defendant’s kind and socially appropriate conduct.
The Plaintiff had actually never experienced “reasonable fear” as defined in 633:3-A.
In a woeful miscarriage of justice, the stalking petition was granted in a Final Order dated 2/7/17,
due to additional perjurious claims made by Plaintiff at Salem District Court in a 1/5/17 hearing.
As the Defendant’s conduct never threatened the “safety” or “well-being” (633:3-a, III-c) of the
Plaintiff in the first place, nor have his subsequent acts of truthful First-Amendment-protected
A97 A97
speech made to third-parties, the Defendant objects to Plaintiff’s motion to extend the said Final
Order of Protection submitted 1/5/18 and granted 1/12/18.
FACTUAL BACKGROUND
On 12/12/16, Defendant made a romantic proposal to Plaintiff after Plaintiff welcomed him to
her house. It was the third time Defendant had even seen Plaintiff in three years. The time prior,
Plaintiff had come to Defendant’s house. Plaintiff told Defendant she thought the gesture was
“very sweet” but declined. After Plaintiff politely rejected the dinner invitation, Defendant
wished her a “beautiful Christmas”, left, and never once spoke to her ever again.
On 12/28/16, Plaintiff filed a perjurious stalking order at the behest of her father David’s
psychotic outburst of rageful anger at Defendant. David’s unhinged mental state was evident by
the abusive, vitriolic verbal harassment he had waged telephonically against Defendant and
Defendant’s parents (vide Exhibit 1: Letter from Theodore Maravelias) as a result of Defendant’s
innocent gesture to his daughter.
The aforesaid stalking petition falsely claimed that Defendant had been imposing and insistent
during his invitation to dinner. On 1/5/17, Plaintiff perjured to the Court that Defendant had
mentioned the sexual “age of consent” as his reason for asking her out on her sixteenth birthday.
Judge Stephen cited this new false allegation – found nowhere in the written petition – as part of
his false finding of “stalking”. Defendant had said nothing of the sort during the polite exchange.
Fortuitously, Defendant had been cell-phone audio-recording the dinner date proposal in
question for sentimental reasons. Defendant Maravelias eagerly attempted to play his recording
during the stalking petition hearing, since it proves the audacious fallacy of the Plaintiff’s
A98 A98
malignant claims. Plaintiff’s counsel disallowed Defendant from playing his exculpatory audio
recording citing New Hampshire’s draconian “wire-tap” statute (570). The Defendant forbidden
to prove his complete innocence, the order was issued wrongly against him days thereafter.
Defendant’s subsequent acts of speech were fully compliant with the falsified stalking order. The
Plaintiff does not dispute that Defendant then made no further contact, neither direct nor indirect.
She only alleges acts of speech to third-parties, which fall outside the scope of the said order.
Plaintiff’s motion to extend the order establishes no basis whatsoever for any threatened “safety”
or “well-being” of the Plaintiff. Rather, Plaintiff’s abusive motion attempts to weaponize the
stalking statute as a cowardly instrument to assault Defendant’s First-Amendment-protected free
speech rights to third-parties, in order to silence his vocal public outspokenness about the
injustice which Plaintiff has done against him, for which she is criminally and civilly liable.
On 12/14/17, Defendant motioned the Court to annul the Final Order, since it was issued 1) in
violation of Supreme Court rules for factual findings in stalking orders, 2) on the basis of no true
“reasonable fear”, given Plaintiff’s subsequent online vulgar harassment and incitation against
Defendant, and 3) on the basis of demonstrable felony perjury. This motion is attached (vide
Exhibit 2: Defendant’s Annulment Motion) along with constituent original exhibits. Judge
Robert S. Stephen denied the said motion with no written explanation on 12/28/17, leaving
Defendant scant recourse for the injustice done against him.
In the said 12/14/17 annulment motion, Maravelias noted that he is appalled by Plaintiff’s
“physical deterioration and turpitudinous criminality”.
Given his utter personal disinterest in Plaintiff, and given the fraudulent aspect of said order’s
issuance ab initio, Defendant concludes that zero legal basis exists for extending the present
A99 A99
unconstitutional abridgement of his bodily liberty to movement, speech, and property ownership,
against which the extant Final Order of “Protection” categorically infringes.
THEREFORE, the reasons set forth above do impel the Defendant Paul Maravelias to pray this
Honorable Court:
I. Deny Plaintiff’s motion to extend the aforecited Final Order, effecting its expiration;
II. Vacate, annul, and reverse the Final Order, due to its initial fraudulence;
III. Hold the Plaintiff, Christina DePamphilis, in criminal Contempt of Court for acts of
perjury under oath, falsification, and injustice; and
IV. Grant such other and further relief as may be just and proper for the reparation of
Defendant’s unfairly damaged reputation proceeding from miscarriages of justice.
Paul J. Maravelias, in propria persona
January 18th, 2018 __________________________________
A100 A100
Exhibit 1: Letter from Theodore Maravelias
1/2/18
Testimony from Theodore G. Maravelias re:

Paul Maravelias vs. David DePamphilis
About a year ago, whenever the date of his daughter Christina’s

birthday was, I received a call from David DePamphilis whose family
had been good friends with us and our children for years.
Right away he started screaming at me in an unhinged manner at the
top of his lungs. For a moment, I was wondering if this was actually him.
After some time, I realized that it was him. David was screaming
vulgarity after vulgarity to the top of his lungs and I was in complete
and utter shock. The tone of his voice was violent in nature and was
absolutely unaffected by any sense of propriety or sanity.
I have never been spoken to that way by anybody in my life. The tone
of his voice was hate-filled and downright demonic.
I had mixed emotions all at once. At first, I was very offended and upset
that he thought he could talk to me in this manner. Yet at the same
time I could tell how unstable he was. I was in complete shock and I
was completely blindsided. I couldn’t believe that someone could talk
to me like that.
I was waiting for the punch line as to what was so bad that my son had
done. I was waiting for him to tell me something horrible. All he could
do was to tell me that my son had bought his daughter a car and that
he told her that he loved her.
A101 A101
Admittedly, I understood that what my son did was non-traditional and
might be misinterpreted. Nevertheless, I know my son would never
threaten or otherwise try to harm anyone- much less good family
friends. I knew that Dave knew that as well because of his exposure to
our family and to Paul over the years.
I had to use all of my training and experience as a health care recruiter

for over 20 years to try to assess and diffuse what I believed to be a
raving psychotic individual. In the day to day course of my job, I deal
with problem calls from healthcare professionals and I need to know
how to keep my cool and to bring clarity to a situation so that a
mutually beneficial solution can be reached. I have been the top
recruiter in my company for 14 years. All my work is done over the
phone and I have developed a very keen sense as to what somebody is
truly feeling. I feel that I have a pretty highly-developed ear as to what
someone’s intentions are. Voice inflections, what is said, what is not
said, tone of voice are all indicators that help me form a consistently
accurate assessment as to what a person is feeling.
With Dave DePamphilis’ erratic and thoroughly deranged diatribe
against me, I was able to assess that this man’s anger was so severe
that I was convinced, am even more convinced today, that he was not
in full possession of his faculties during that call and that he is
consequently prone to fits of uncontrollable rage.
His subsequent acts of persecution: (driving around our neighborhood
on March 21st, looking for Paul presumably to confront him and going
on social media with a message to Paul with Dave’s middle finger
extended) are indicators to me that he is trying to provoke and harass
my son. David DePamphilis’ demonstrative obsessive hatred and
vindictiveness against my son, have only served to confirm my initial
A102 A102
assessment of the level of danger that he poses to my son Paul and to
the rest of my family.
Under normal circumstances, Dave seems like a normal, rational
person. However, when he is angered, he turns into someone who I
believe is capable of violence, including homicide. It is not something
that I can prove a priori but it is my assessment based on the violent
tone and unhinged screaming that he inveighed against me.
I thought about going to the Windham Police Department whereas I
believed this possibly constituted criminal threatening. However, I was
convinced that if I did this, he would not have been open to a possible
compromise that would not involve a strategy of legal attacks against
my son. I was also fearful that he would potentially violently assault my
son either directly or indirectly.
Since that time, I regret not going to the police. As more examples of
Dave’s unending attempts to destroy my son’s reputation have evinced
themselves, I have become more and more fearful regarding the
physical safety of my son, and the physical safety of the rest of my
family.
I believe that any night could be our last night as I envision a heavily
armed Dave DePamphilis coming to our house in a homicidal rage. I
don’t believe this potential capacity to murder my son and my family is
far-fetched or is hyperbole. I know what I heard during that sadistic call
to me and I heard the very viable capacity for violence in his voice. I
can’t prove it, but any reasonable person would be in fear after having
endured the dehumanizing and humiliating verbal assault that I was
forced to endure. In order to protect my son’s life, and my family’s
lives, I pray the court would grant a restraining order against Dave
DePamphilis.
A103 A103
I realize that a restraining order is not a full-proof defense against a
pre-meditated armed assault against my family. However, it would give
us a certain peace of mind that it might make such a murderous
rampage less likely to happen. My fear and my family’s fear, will
probably not subside any time soon, but if this order is granted, at least
I will be assured that this court cares for the safety of my family and is
willing to enact common sense measures to protect us. If a restraining
order is not granted, and if my son or me and my family are murdered,
what confidence could future would-be victims have in our local judicial
system? Leaving my son and my family unprotected and therefore
exposed to a potentially lethal attack, would be a de facto death
sentence levied against my son and also perhaps other members in my
family. My son giving a gift to the defendant’s daughter and expressing
feelings of affection without any threat or intimidation, ought not to
warrant a de facto death sentence.
I ask the court to defend our right not to live in fear. Please protect us.
Please don’t expose us, through inaction, to this man’s uncontrollable
rage, which seems to me to knows no bounds. If you heard what I
heard during that call, you would conclude, as would any reasonable
person, that Dave DePamphilis represents a demonstrably clear and
present danger to my son Paul and to the rest of my family.
Theodore G. Maravelias
34 Mockingbird Hill Rd.
Windham, NH
A104 A104
Exhibit 2: Defendant's
Clear Form
Annulment Motion
JUDICIAL BRANCH
http://www.courts.state.nh.us
Court Name: 10th Circuit - District Division - Salem

Case Name:
Christina DePamphilis v. Paul Maravelias
Case Number:
(if known) 473-2016-CV-00124
MOTION: For Vacation and Annulment of Stalking Order
I,
state the following facts and request the following relief:
See attached Motion on Page 1.
Referenced Exhibits span following Pages 2-14.
Date Signature
Telephone Address
I certify that on this date I provided a copy of this document to (other party) or to
(other party’s attorney) by: Hand-delivery OR ✔ US Mail OR
E-mail (E-mail only by prior agreement of the parties based on Circuit Court Administrative Order).
Date Signature
ORDER
Motion granted. Motion denied.
Recommended:
Date Signature of Marital Master/Referee
Printed Name of Marital Master/Referee

So Ordered:
I hereby certify that I have read the recommendation(s) and agree that, to the extent the marital master/judicial
referee/hearing officer has made factual findings, she/he has applied the correct legal standard to the facts
determined by the marital master/judicial referee/hearing officer.
Date Signature of Judge
Printed Name of Judge
A105
NHJB-2201-DFP (08/29/2014) Page 1 of 1 A105
Top of Page
MOTION FOR VACATION AND ANNULMENT OF STALKING ORDER
1) The Plaintiff and her father fraudulently pursued this order in bad-faith, lying about having any “fear” of me:
I attach her social media post, made on 6/21/17 after obtaining the said order, wherein Plaintiff and father
provoke me with vulgar middle finger insults, identifying me publicly as recipient. They included Plaintiff’s
20-year-old boyfriend (now 21) to try to incite me into violating the stalking order on the basis of jealousy.
Their targeted provocation against me proves beyond question the utter absence of “genuine fear”, and that
the order was a malicious instrument of intimidation. I’ve obeyed the order trusting it will be annulled.
2) The said stalking order was issued in plain violation of established NH Supreme Court rules limiting
admissible factual basis in stalking orders. This Court’s finding in said order referenced the birthday incident
wherein I allegedly made creepy, intimidating comments to Plaintiff: to wit, mentioning her “age of consent”
and saying I’d “be back when she is 18”. These false accusations appeared nowhere in the stalking petition.
They were added circumventively by Plaintiff later on 1/5/17 in the hearing. But South v. McCabe (2007-
120) mandated that findings for stalking be limited to only those accusations alleged before the hearing in the
written petition, extending the identical existing rule for DV orders (In the Matter of Aldrich & Gauthier, 156
NH, 2007) to stalking orders. Thus, the said stalking order is erroneous even absent the Plaintiff’s perjury.
3) I produce new evidence that Plaintiff willfully lied about my conduct to obtain the order, according to her
father’s scheme. The order’s factual finding text specifically cites Plaintiff’s lie that I’d mentioned the “age
of consent” or said I’d be “back” while making a romantic proposal to her. At the hearing, I was disallowed
to play a sentimental cell-phone audio recording of this same exchange to prove the utter falsehood of the
aforecited claims. But, I have subsequently lawfully played it for my parents in Vermont. I attach my
criminal complaint against Plaintiff and her father David for criminal Perjury and False Reporting. This
includes my parents’ testimony of the recording’s contents, proving that I never once said anything close to
the alleged accusations which this Court specifically cited as forming a “course of conduct” in its finding.
4) I have zero ongoing interest in Plaintiff. I abhor her physical deterioration and turpitudinous criminality.
WHEREAS the said erroneous stalking order has unfairly damaged my good reputation, and whereas the false
facts illegally admitted into the stalking finding are hurtfully visible to anyone who internet searches my name,
and whereas I submit proof that no valid “reasonable fear” ever occasioned the perjurious stalking petition as
made evident by the Plaintiff’s subsequent reckless acts of harassment against me,
NOW THEREFORE, I, Paul Maravelias, do humbly pray this Honorable Court reverse, vacate, and annul the
said stalking order before its expiration on 2/7/18.
1
A106 A106
Docket No. 473-2016-CV-124
v.
Paul Maravelias
MOTION TO VACATE STALKING ORDER AND DISMISS MOTION TO EXTEND
NOW COMES the Defendant, Paul Maravelias, and moves this Court to vacate its Stalking
Order without any hearing, due to plain judicial error and deprivation of proper process. The said
order was issued in violation of established New Hampshire Supreme Court rules limiting admissible
factual basis for findings of stalking. Because of these errors, the Plaintiff must file a new Stalking
Petition if ongoing injunctive relief is desired. The Defendant relies upon the following facts:
I. The Court’s finding of stalking in said order relied upon a birthday incident wherein the
Defendant allegedly made two discomforting comments to Plaintiff during a romantic proposal: to
wit, mentioning her “age of consent” and saying he would “be back when she is 18” (Stephen, Robert
S in 2016-CV-124; vide Exhibit A).
II. These accusations, which the Defendant alleges are false to begin with, appeared nowhere
in Plaintiff’s Stalking Petition (vide Exhibit B).
III. They were only entered circumventively by Plaintiff later in a 1/5/17 hearing on her
Stalking Petition (vide Exhibit C).
A107 A107
IV. The New Hampshire Supreme Court mandated in South vs. McCabe, 943 A.2d 779
(2008) that findings of stalking be limited to only those facts alleged before the hearing within the
written petition, extending an identical existing rule for DV protection orders in In the Matter of
Aldrich & Gauthier, 930 A.2d 393 (2007) to stalking orders. In both cases, the appellate court
vacated a protective order which violated these rules in the same way the Plaintiff’s Stalking Order
does in this case. In South, the Supreme Court held:
“We agree with the respondent that the holding of Aldrich & Gauthier is applicable to civil
stalking proceedings by operation of RSA 633:3-a, III-a … Thus, on remand, the trial court
should limit its findings to the factual allegations specifically recited in the stalking petition,
despite its admission of other unnoticed allegations at the hearing on the petition.”
V. In this case, the two aforecited alleged comments made by Defendant were specifically
relied upon in Justice Stephen’s finding of a stalking course of conduct (vide Exhibit A).
VI. The said Stalking Order was therefore predicated on a trial court’s finding of stalking
made in clear violation of established rules. The resulting Stalking Order was therefore erroneous ab
initio, even absent any falsification of fact as Defendant claims.
VII. Since this error has deprived the Defendant of his due process right to be notified of the
accusations against him before the hearing, the Stalking Order is an artifact of clear judicial error.
Granting an extension on an erroneous or illegal order would necessarily reassert the same error.
VIII. 633:3-a III-c. permits extension of such orders “as may be necessary to provide for the
safety and well-being of the plaintiff”. This legal standard for Stalking Order extension differs from
granting one initially as described in 633:3-a I.; therefore, subjecting Defendant to a different legal
standard for Stalking Order extension predicated upon an erroneous original finding of stalking
would yet again violate due process rights and uphold a plain legal error.
A108 A108
IX. Thus, should the Plaintiff still feel there is cause to fear for her physical safety, the
Defendant deserves a fair, law-abiding trial on the original merits of a new Stalking Petition. The
Court may hear a new petition from the Plaintiff, but the Court cannot lawfully grant an extension on
an order issued in clear violation of pertinent law as interpreted in effectual Supreme Court rulings
on stalking and domestic violence injunctions.
THEREFORE, the reasons set forth above do impel the Defendant Paul Maravelias to pray this
Honorable Court:
I. Deny Plaintiff’s motion to extend the Final Stalking Order of Protection, effecting its
immediate expiration;
II. Vacate, annul, and reverse the original Final Stalking Order of Protection; and
III. Grant such other and further relief as may be just and proper for the reparation of
Defendant’s unfairly damaged reputation proceeding from miscarriages of justice.
PAUL J. MARAVELIAS,
in propria persona
March 29th, 2018 __________________________________
A109 A109
May 29th, 2018
Robin E. Pinelle, Circuit Clerk
NH Circuit Court Paul Maravelias
10th Circuit – District Division – Derry 34 Mockingbird Hill Rd
10 Courthouse Lane Windham, NH 03087
Derry, NH 03038
RE: Christina DePamphilis vs. Paul Maravelias

Docket No. 473-2016-CV-00124
Dear Clerk Pinelle,
Enclosed please find Respondent’s Motion for Discovery to be filed in the above-
referenced case.
Thank you for your attention to this matter.
Sincerely,
Paul J. Maravelias
CC: Simon R. Brown, Esq.
I, Paul Maravelias, certify that a copy of the present Motion for Discovery was
forwarded on this day through USPS Certified Mail to Simon R. Brown, Esq., counsel
for the Petitioner, P.O. Box 1318, Concord, NH, 03302-1318.
______________________________
A110 A110
Docket No. 473-2016-CV-00124
v.
Paul Maravelias
MOTION FOR DISCOVERY
NOW COMES the Respondent, Paul Maravelias, and moves this Court to grant certain relief
regarding the discovery of evidence in the current stalking order extension case. In support for this
Motion for Discovery, the Respondent asserts the following facts:
1. The Petitioner motioned the Court to extend the Stalking Order on 1/5/18. The Court held a Hearing
on that Motion on 5/3/18 and 5/4/18. A Continuance was scheduled to 6/8/18.
2. The underlying Stalking Order was first issued on the basis of allegations over Maravelias’s words
spoken to Petitioner in a 12/12/2016 in-person conversation. Maravelias has long-maintained the
accusations are false, and he purports to have an audio recording of the full conversation which clearly
proves the accusations were false.
3. Maravelias has attempted to play this audio recording in Court to advance his belief that the Petitioner
lied to the Court to obtain the Stalking Order. But, he has faced premeditated legal challenges by
Christina DePamphilis and her father David DePamphilis aimed to prevent this recording from ever
being played. These attempts to silence the recording have been successful.
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A111 A111
4. On 3/24/2017, David DePamphilis filed a criminal complaint with the Windham Police about
Maravelias’s cell-phone audio recording, which Maravelias had made for sentimental reasons during a
romantic proposal. As a result, the Windham Police arrested Maravelias on 6/13/17 for the audio
recording under the New Hampshire “wiretapping” statute (RSA 570-A). This was after Judge Robert
S. Stephen had issued a Stalking Order against Maravelias – an Order which contained a finding
asserting that Maravelias had indeed spoken the alleged antisocial phrases he vehemently denied ever
speaking, as he unsuccessfully attempted to demonstrate with his censored audio recording.
5. At the 5/3/18 Hearing, Maravelias attempted again to lawfully reproduce this audio recording with
Petitioner’s consent. Petitioner’s counsel objected, and an inconclusive legal argument regarding the
legality of playing the recording ensued. Petitioner’s counsel recommended that Maravelias “should
have briefed [the issue] before the Hearing”. The Court wished to see a “memorandum” on the issue.
6. The legal question at hand is whether the Court may permit Maravelias to play the recording and
admit it as evidence, with Petitioner’s consent.
7. Under the “wiretapping” statute, the Court may indeed lawfully permit the recording with Petitioner’s
consent. 570-A:2 (I) prefaces all its subsequent criminal prohibitions as follows:
“A person is guilty of a class B felony if, except as otherwise specifically provided in this chapter or
without the consent of all parties to the communication, the person: …” (Emphasis added)
8. Thus, the act of “disclosing” the “contents of any telecommunication or oral communication, knowing
or having reason to know that the information was obtained through the interception of a
telecommunication or oral communication in violation of this paragraph”, is not contrary to the statute
should the recorded parties consent to the disclosure at any future time, regardless of the interception’s
original lawfulness or unlawfulness.
9. Therefore, no criminal act is committed when and if Maravelias shall play the recording before this
Court, provided that the Petitioner consent to it.
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10. However, although the disclosure would not then contravene the statute, a separate legal question
exists regarding the evidentiary admissibility of the recording. This is due to the purported
unlawfulness of the original act of interception whence the current audio recording derives.
11. The exclusionary rule is a technical rule of evidence which generally prohibits the usage of unlawfully
obtained evidence in most official proceedings. However, the rule applies solely to criminal
prosecutions against citizens. “The exclusionary rule enjoins the Government from benefiting from
evidence it has unlawfully obtained.” United States v. Crews, 445 U.S. 463, 475 (1980).
12. Regardless of the scope of the exclusionary rule and of whether it would otherwise apply in a civil
stalking protective order case, New Hampshire law specifically mandates that it does not. RSA 173-
B:3 “Commencement of Proceedings; Hearing.” VIII. specifically states:
“In any proceeding under this chapter, the court shall not be bound by the technical rules of evidence
and may admit evidence which it considers relevant and material.”
13. Stalking Order hearings are proceedings under the said chapter above. The Stalking statute states:
633:3-a III-(a) “The types of relief that may be granted, the procedures and burdens of proof to be
applied in such proceedings, the methods of notice, service, and enforcement of such orders, and the
penalties for violation thereof shall be the same as those set forth in RSA 173-B.” (Emphasis added)
14. Therefore, any generic evidentiary rules which might otherwise prohibit the admission of the
consented-to reproduction of the audio recording do not apply in this case. Contingent upon the
consent of the Petitioner, the Court may and should permit Maravelias to produce this proof.
15. The recording is relevant within the Hearing on Petitioner’s Motion to Extend in many ways. Firstly,
if Maravelias never stated the alleged phrases, it demonstrates either that the Petitioner is a perjurer or
that her memory is grossly impaired. Secondly, it is relevant to Respondent’s Motion to Dismiss.
Thirdly, the Court may consider the underlying circumstances to any protective order extension.
16. The relief sought by the Respondent’s present Motion for Discovery is mandated by the New
Hampshire Constitution’s Bill of Rights at Article 15:
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A113 A113
“Every subject shall have a right to produce all proofs that may be favorable to himself; to meet the
witnesses against him face to face, and to be fully heard in his defense, by himself, and counsel.”
(Emphasis added)
17. Therefore, if the Petitioner does not consent to the reproduction of the said recording for this Court,
the Court should make appropriate inferences regarding the palpable terror which Maravelias’s true
record of his words creates for the DePamphilis family in light of their specific accusations against
him which are either fully confirmed or fully disproved by this audio recording.
THEREFORE, the reasons enumerated hereinabove compel the Respondent, Paul Maravelias, to pray
this Honorable Court:
II. Order the Petitioner, Christina DePamphilis, to consent to the disclosure of the said
auditory evidence as a formal process of Discovery requisite to her Motion to Extend;
III. Lawfully permit the reproduction of said evidence at the Hearing, presently scheduled for
6/8/18, should the Petitioner rightfully consent thereto, or infer the Petitioner’s bad faith
motivations of censorship to suppress true evidence purported to be contrary to her stalking
accusations against Maravelias, should she elect not to consent thereto; and
IV. Grant such other relief as may be just and proper.
PAUL J. MARAVELIAS,
in propria persona
May 29th, 2018 __________________________________
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A114 A114
Docket No. 473-2016-CV-00124
v.
Paul Maravelias
MOTION TO SET ASIDE JUDGEMENT
NOW COMES the Respondent, Paul Maravelias, and respectfully submits the within Motion
to Set Aside Judgement. In support thereof, he represents as follows:
1. Earlier in 2018, Judge John J. Coughlin oversaw a stalking order extension case
involving the parties. Plaintiff motioned to extend the stalking order on 1/5/18. The Court
granted the initial extension on 1/12/18 and scheduled a Hearing for 2/15/18, later continued to
5/3/18. Additional Hearing days were held on 5/4/18 and 6/8/18. John Coughlin granted the
stalking order extension on 6/15/18. Maravelias filed a Motion for Reconsideration on 6/25/18,
to which Coughlin gave a short-shrift one-world denial. The case is currently on appeal as
Supreme Court No. 2018-0483.
2. Maravelias was party to two other cases from the same approximate period over which
Judge Coughlin partially or fully presided: 1) as pro se Petitioner in Paul Maravelias v. David
DePamphilis (437-2017-CV-150) and 2) as Petitioner’s non-lawyer representative in Patti Cascio
v. John Chan (431-2018-CV-113).
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3. The summation of Judge Coughlin’s judicial activity around Mr. Maravelias throughout
these legal matters objectively evinces a common pattern of systematic bias, hostility, and
prejudice by which Judge Coughlin severely injured Maravelias through deprivation of basic
liberty and judicial libel, inter alia.
4. Maravelias files this Motion to Set Aside Judgement 1) solely in relation to the wrongful
stalking order extension in the instant case, birthed of judicial misconduct, and 2) solely on the
basis of the alleged bias and judicial misconduct.
5. That is, for the purposes of this motion, Maravelias does not 1) discuss the other weighty
legal and factual errors the trial court committed in the stalking order extension, nor 2) request
reversal of the false award of attorney’s fees Judge Coughlin wrongly issued against Maravelias.
These are matters of law currently under review by the Supreme Court.
6. Rather, Maravelias files the instant Motion to Set Aside Judgement for the first-time
seeking redress for disturbing indications hereunder of John Coughlin’s pre-retirement
misconduct, being obviously unable to do so prior to Coughlin’s 9/5/18 retirement.
7. Since Defendant Maravelias was not given a fair opportunity under Judge Coughlin’s
pre-retirement spree of dismissive, biased, and prejudiced conduct, Maravelias respectfully
requests this Court reverse the stalking order extension dated 6/15/18. See 6/15/18 Order
appended to Notice of Appeal, itself attached herewith.
A. The Timing of Judge Coughlin’s Orders Suggests Impure Motives
8. On 7/13/18, Coughlin went on a four-fold “denied”-scribbling-spree on Maravelias’s
pleadings, some of which had been pending for well-over two weeks awaiting his ruling. To wit,
Judge Coughlin reflexively denied 1) Maravelias’s 10-page Motion for Reconsideration, 2)
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Maravelias’s Motion to Strike, 3) Maravelias’s Reply to DePamphilis’s Objection to
Reconsideration, and 4) Maravelias’s Objection to DePamphilis’s outrageous motion for
expanded, draconian “stalking” order terms – all on the same day, 7/13/18.1
9. The day immediately prior on 7/12/18, Judge Coughlin had his final verbal interactions
with Maravelias when the Petitioner in Patti Cascio v. John Chan (431-2018-CV-113)
successfully motioned the Court to permit Mr. Maravelias to serve as her non-lawyer counsel in
that case.
10. Given the timing, it seems highly unlikely John Coughlin’s dismissive 7/13/18
outburst legally crucifying Maravelias every-which-way was anything but a retaliatory,
vindictive act, annoyed to see Maravelias appear once-more in his courtroom.2
11. It goes without saying that Maravelias comported himself with incredible respect
before Judge Coughlin throughout the entire history of all three cases. While Judge Coughlin
was likewise cautious to behave respectfully, amicably, and professionally during public court
proceedings outward-personality-wise, his reckless judicial actions are without any legitimate
purpose and constitute misconduct.
B. Judge Coughlin Contradicted His Honest Comments from the Hearing in His Fact-
Amnestic Extension Order, Highlighting the Dishonesty Thereof
1
The Supreme Court Notice of Appeal for this case is attached, containing all of Judge Coughlin’s
referenced Orders.
2
Upon information and belief, further indications of Judge Coughlin’s strange, perverse, and unhealthy
distaste for Maravelias were noted on 7/24/18. Maravelias attended the Roseanna Mullin v. Kimberly
Nichols (431-2018-CV-156) stalking hearing as a mere member of the public seated in the gallery. The
Petitioner failed to show up and the absurd case was dismissed; when the parties were departing,
Coughlin stared-down Maravelias with a facial expression of determined, enraged, though partially
confused, offense, as if Maravelias’s mere existence were somehow a threat to Coughlin’s authority.
Maravelias dared not acknowledge Coughlin’s non-verbal communication and proceeded straight out the
courtroom.
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12. After perceiving the undisputed fact that Christina DePamphilis incitatively bullied
and harassed Paul Maravelias with her 21-year-old boyfriend on 6/21/17 through social media by
targeting Maravelias in a public post with her and her boyfriend middle-fingering Paul
Maravelias, Judge Coughlin tossed-in a gratuitous finding in his 6/15/18 stalking-order-extension
Order, wholly unnecessary by RSA 633:3-a, III-c., that Christina DePamphilis had “reasonable
fear” of Maravelias, because Maravelias communicated to two third-parties disagreeing with the
stalking order he called “legal abuse”.
13. Coughlin’s reckless judicial libel against Maravelias, not a “stalker” but the victim of
DePamphilis’s fearless bullying, totally contradicted Coughlin’s honest comments and
impressions during trial (Transcript 73:12-18)3 wherein he indicated he understood Christina
DePamphilis clearly did not “fear” the young man she was calling-out and provocatively middle-
fingering on public social media along with her boyfriend, while she had a “stalking”
“protective” order against her victim.
14. Therefore, John Coughlin’s comment about “reasonable fear” in his 6/15/18
extension Order proves it was totally disingenuous and shamefully dismissive in Maravelias’s
prejudice.
15. Even more disturbingly, John Coughlin included in his Order the ridiculous verbal
posturing that Maravelias has a “strange, perverse and unhealthy obsession” with DePamphilis
“which … continues to this day”. See 6/15/18 Order in appended Notice of Appeal.
16. However, John Coughlin at-trial openly commented to Maravelias that he understood
the obvious fact Maravelias was repulsed by and disinterested in the false-accuser Plaintiff,
3
Referenced transcript pages are attached herewith
4
saying: “it appears that you do not want to have any contact and that you’re going to do that on a
voluntary basis … you indicated that, you don’t want to have anything to do with the family, you
don’t want to have anything to do with this young woman, and you just want to be left alone and
you’re going to leave her alone. At least that’s my impression”. (Transcript 479-480)
17. Accordingly, John Coughlin’s rash stalking order extension against Maravelias is
undeniably rooted in biased, dishonest judicial conduct. The above-noted disparities indicate
John Coughlin simply ignored the facts of the case in Maravelias’s prejudice.
C. Judge Coughlin Demonstrated his Bias Against Maravelias Through Negligent

Dismissiveness
18. In Paul Maravelias v. David DePamphilis (437-2017-CV-150), Coughlin denied
Maravelias’s meritorious petition, included an alternate-universe-imagining comment that
Maravelias provided “no credible evidence” to sustain his allegations (one of the allegations was
a reproduced-as-entered-exhibit social media post in which David DePamphilis had bullied
Maravelias), and ordered Maravelias to pay his abuser $9,000 of attorney’s fees. While this
outrageous injustice is mostly a matter of law outside the context of this motion and currently
under review by the Supreme Court, a certain notable phenomenon therefrom is profitable to the
narrow judicial-misconduct-showing discussion herewith.
19. Judge Coughlin ordered Paul Maravelias to pay one of DePamphilis’s itemized
expenses of “attorney’s fees” from before the stalking petition was ever filed. When Maravelias
noted this larcenous error in his 5/21/18 Motion for Reconsideration in that case, John Coughlin
reflexively denied the reconsideration in toto, claiming Maravelias did not indicate any
overlooked “facts” or “law” to challenge the Court’s decision.
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20. That Judge Coughlin wholly ignored Maravelias’s Motion for Reconsideration to the
extent of failing to undue his veritable larceny (i.e., assuming attorney’s fees were warranted, the
Court has no jurisdiction to order payment of extraneous costs incurred months before the
stalking petition was filed) is incontrovertible proof of his biased, prejudicial, and hostile
misconduct against Maravelias.
D. Judge Coughlin Deserted his Judicial Duty to Decide
21. John Coughlin failed to issue any ruling whatsoever on Maravelias’s 3/29/18 Motion
to Dismiss in this case, ignoring its compelling legal arguments in toto. This was a willful act of
negligence: oral argument from both parties spanned the last few minutes of the final 6/8/18
Hearing before Judge Coughlin, whereupon he “[took] the matter under advisement” to conclude
the Hearing.
22. Professional standards of judicial conduct do not permit Judge Coughlin simply to
issue a rash extension Order, wash his bloody hands in the river, and retire. Maravelias rightfully
expected a ruling on his Motion to Dismiss and an articulated basis in the law for the said ruling,
not a symbolic denial thereof by way of the extension Order, seized as a pathetic opportunity for
John Coughlin to finagle his way out of actually listening to and considering Maravelias’s legal
arguments.
23. Therefore, in this particular episode of John Coughlin’s conduct, Code of Judicial
Conduct Canon 2 Rule 2.7, Rule 2.3(A), Rule 2.5(A), and Rule 2.6(A) were violated.
E. Judge Coughlin Was Adamant to See the Parties Reach a Settlement, Foreshadowing
his Prejudicial Inability to Side Against the Younger, Lawyer-Represented Female Party
24. Towards the end of the 5/4/18 Hearing, Coughlin emphatically implored the parties to
see if they could settle the case and reach an agreement, dissolving the need for him to rule on
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the motion to extend the stalking order. (Transcript 295-297) Coughlin strangely and
emphatically reanimated the same request towards the end of the 6/8/18 Hearing: he actually had
the parties take a recess to see if they could work-out a settlement. (Transcript 479-480)
25. Viewed in the context of the subsequent judicial terrorism of his libelous, fact-
amnestic 6/15/18 Order against Maravelias, John Coughlin’s adamant fixations on evading
having to rule in this case are retrospectively suggestive of his identity-politics-rooted inability to
side against the younger, female, lawyer-represented party. The absurdity of the injustice he
prejudicially expected he’d otherwise have to do against Maravelias moved John Coughlin to
seek out a potential way out of prostrating himself before the altar of feminist false-victim-
advocacy. Clearly, male, 22-year-old, pro se Maravelias did not have a fair chance when Plaintiff
motioned to extend her already-criminally-falsified “stalking” order.
F. In His 2018 Pre-Retirement Decisions Against Maravelias and Other Stalking

Defendants, Judge Coughlin Demonstrated a Habit of Unlawfully Ignoring Facts and
Baselessly Amplifying His Orders’ Language with Wholly Unsupported Legal Buzz-
Words, Reminiscent of an Autistic Child Pretending to be a Firefighter or an Astronaut
26. Through examination of public records, Maravelias has scrutinized all of Judge
Coughlin’s 2018 stalking order conduct. The results are disturbing. They are further indicative
that Maravelias was prejudiced in this case.
27. The New Hampshire Supreme Court has clarified multiple times what expectations
are binding against judicial officers granting DV/stalking orders, per the relevant statutory due-
process requirements. The most basic of these requirements is that when issuing stalking orders,
judges must specifically cite which factual allegations were relied upon as forming a “course of
conduct” under RSA 633:3-a, II. (a) to sustain the finding of stalking. “We hold that when
issuing a stalking order in response to a civil petition filed pursuant to RSA 633:3-a, III-a, the
7
trial court must make findings on the record that a defendant engaged in two or more specific
acts ‘over a period of time, however short, which evidences a continuity of purpose.’” Fisher v.
Minichiello, 155 N.H. (2007) The Supreme Court readily vacates stalking orders where the
judge’s order “gives no indication of the facts upon which the trial court relied in issuing the
order, nor the reasoning”. Kiesman v. Middleton, 156 N.H. (2007). See also Fillmore v.
Fillmore, 147 N.H. 283 (2001).
28. John Coughlin’s pre-retirement conduct was incompetent and dismissive not only in
Maravelias’s case: throughout, Coughlin would 1) totally ignore his duty to substantiate his
stalking orders with particularized factual allegations against defendants and, as an improper
substitute therefor, 2) sprinkle-in amplified legal-sounding buzz-word terms in strange,
inapplicable places, without any factual corroboration whatsoever, in order to fool the casual
reader into the deceptive semblance that Judge Coughlin was being thorough and doing his job
properly. (Exhibit D)
29. For the period 1/1/8 – 9/1/18, Derry District Court granted 9 new stalking petitions
and 2 extant stalking order extensions, inclusive of the instant case. (Exhibit A) Judge Coughlin
authored all these decisions, except for the 431-2018-CV-46 stalking petition, which was granted
in an order written by Judge Elizabeth M. Leonard, and the 431-2018-CV-139 stalking petition,
which was handled by Judicial Referee Philip Cross. (Exhibit A)
30. For some reason, Judge Leonard and Referee Cross possess the competency to do
their jobs correctly and make specific reference to factual allegations sustaining a “course of
conduct” in their stalking orders (Exhibits B and C) whereas John Coughlin totally violated the
law, and committed judicial misconduct, by completely omitting any specific factual reference
whatsoever in 7 of the 8 stalking orders he issued. (Exhibit D) Only in one stalking order, 431-
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2018-CV-69, did Judge Coughlin make any reference at all to any specific allegation against a
defendant, noting that David Morehouse “stalked” Amy Callahan when Mr. Morehouse “pointed
a power drill” at Amy during an argument. (Exhibit D)
31. If John Coughlin’s dismissive incompetency in failing to substantiate his stalking
injunctions by itself were not concerning enough, the stalking orders in question indicate another
disturbing pattern: Coughlin’s meaningless stylistic embellishments with unsupported legal
buzz-words attempting to adorn said orders with a superficial gloss of seeming competency.
32. A perfect example is John Coughlin’s highly concerning 2/1/18 stalking order in
Patricia D’Avella v. Clint DePalmer (431-2018-CV-001):
“The Petitioner appeared, was sworn and testified. Upon consideration of the
evidence, the Court finds that the Plaintiff met her Burden of Proof by a
preponderance of the evidence with regards to the allegations as set forth in the
Petition and the Petitioner is in fear of her personal safety and the Petitionee
purposely, knowingly or recklessly engaged in such Course of Conduct.”
(Exhibit D)
33. Judge Coughlin mindlessly recited the patently non-specific “purposely, knowingly
or recklessly” language of RSA 633:3-a, I(a) and even went out of his way to pepper-in the legal
buzz-word “Course of Conduct”. But, unfortunately, none of this enables Mr. DePalmer to
understand what specific acts of his caused a New Hampshire trial court to label him a “stalker”.
34. This pattern of ridiculous, incompetent, and unsubstantiated judicial behavior is
repeated throughout all 7 of Coughlin’s 8 pre-retirement 2018 stalking orders. A particularly
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striking display of vapid, meaningless repetition of statutory language within an absolutely fact-
less Order is observed at Mary Peterson v. Richard Garrigus (431-2018-CV-89).4 (Exhibit D)
35. Given Judge Coughlin’s repeated pre-retirement misconduct with stalking orders, his
reckless 6/15/18 Order against Maravelias (blanket-referencing factual allegations not supporting
whatsoever his false legal claims that Maravelias put the Petitioner “in reasonable fear”, has a
“present” “obsession”, and communicated to third-parties for “the sole purpose of
harassing/stalking the Petitioner”) is clearly disingenuous, biased, and dismissive drivel. The
resultant extended stalking order against Maravelias is a product of clear injustice and must be
reversed.
H. Judge Coughlin Wrongly Crowned Himself with Self-Fantasized Clinical Credentials
36. Where Judge Coughlin was emotionally offended by Maravelias’s non-expert use of
the generic English word “psychotic” (Page 58 of Transcript of 2/15/18 Hearing in 473-2017-
CV-150, not attached), Judge Coughlin conferred upon himself clinical credentials to allege
“obsession” in his 6/15/18 extension Order against Maravelias.
37. Aside from the obvious dishonesty of Coughlin’s amplified verbal posturing that
Maravelias has a present-day “obsession”, and aside from the fact an allegation of an
“obsession” appeared nowhere in Plaintiff’s Motion to Extend, Judge Coughlin has no business
issuing such clinical declarations while lacking necessary credentials. There was no expert
4
It is worth mentioning that Mr. Garrigus, an amicable and peaceful senile man, has been languishing in
Rockingham County Jail since the summer because of Ms. Peterson’s specious accusation he violated
Coughlin’s outrageous “stalking” order. John Coughlin committed woeful judicial misconduct in that case
by allowing the matter to continue where Mr. Garrigus clearly lacked the mental capacity to even
understand what was happening, let alone testify in own self-defense (he did not). The Petitioner in that
case, Ms. Peterson, is a demonstrable vexatious litigant who filed a different stalking petition on 6/25/18
so incredibly ridiculous that even John Coughlin dismissed it immediately without a hearing. (431-2018-
CV-121) Unsurprisingly, the defendant in that case (where Coughlin behaved sensibly, denying the
petition on-the-spot) was female.
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psychologist testimony, no supporting letters from professionals, and most importantly, no
allegation of “obsession” in the Plaintiff’s extension motion. Coughlin’s foolhardy folly of
alleging “present-day obsession” further evidences his fact-amnestic bias against Maravelias.
I. Judge Coughlin Willfully, Criminally Violated RSA 641:5, I.(B) While Further Abusing
Maravelias’s Constitutional Rights
38. DePamphilis filed a Motion on 7/2/18 in the instant case petitioning for expanded
“protective” order terms which would criminalize Maravelias’s mere possession of court exhibits
for his self-defense: Petitioner’s “social media communications”, some of which document her
middle-fingering and harassing the victimized young man she falsely accused of “stalking” and
falsely claimed to “fear” (Defendant Maravelias).
39. On 8/7/18, Judge John J. Coughlin – the prince of perversity – granted this assault on
Maravelias’ First Amendment free-speech rights, despite Maravelias’s pellucid premonitions in a
prior objection pleading that such would be in direct violation of RSA 641:4, I.(B), which
prohibits the suppression of evidentiary exhibits being used or about to be used in a court case
(to wit, the Christina-DePamphilis’s-middle-fingers-bullying-post against Maravelias in use
within the ongoing Supreme Court appeal, No. 2018-0483):
641:5 Tampering With Witnesses and Informants. –

A person is guilty of a class B felony if:
I. Believing that an official proceeding, as defined in RSA 641:1, II, or investigation is
pending or about to be instituted, he attempts to induce or otherwise cause a person to:
(a) Testify or inform falsely; or
(b) Withhold any testimony, information, document or thing; or
(c) Elude legal process summoning him to provide evidence; or
(d) Absent himself from any proceeding or investigation to which he has been
summoned; or
II. He commits any unlawful act in retaliation for anything done by another in his
capacity as witness or informant; or
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III. He solicits, accepts or agrees to accept any benefit in consideration of his doing any
of the things specified in paragraph I.
40. John Coughlin therefore also violated criminal law as part of his rampant spree of
biased, prejudicial legal abuse against Mr. Maravelias.
J. Judge Coughlin Knowingly Violated Court Rules in Prejudice of Maravelias
41. Judge Coughlin’s knowing, reckless, and tortious violation of Maravelias’s
constitutional rights through unilateral acts of restraining-order tyranny are matters of law,
currently under Supreme Court review, which exceed the scope of the present motion.
42. However, Judge Coughlin’s willful violation of court rules in Maravelias’s prejudice
is relevant here and supports a view of Coughlin’s biased misconduct against Maravelias.
43. On 5/3/18, at the onset of the Hearing in the instant stalking order extension case,
Maravelias politely demanded the Court respect his incontrovertible right to videotape the entire
proceeding, guaranteed by Circuit Court Rule 1.4. Maravelias recited the rule to Judge Coughlin.
Coughlin willfully violated the court rules, prohibiting Maravelias from videotaping certain
aspects of the Hearing. (Transcript 5-9)
44. The New Hampshire Code of Judicial Conduct defines that:
“Law” denotes court rules as well as statutes, constitutional provisions and decisional law.
45. Through his willful violation of the Circuit Court Rules guaranteeing Maravelias’s
recording rights, and through his willful or negligent disobedience of the Supreme Court’s
mandate that stalking orders be rooted in specific factual findings, John J. Coughlin has
rampantly violated Code of Judicial Conduct Canon 2 Rule 2. (A) in the months immediately
prior to his 9/5/18 retirement:
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“A judge shall respect and comply with the law and shall act at all times in a manner that
promotes public confidence in the integrity and impartiality of the judiciary.”
K. The Proper Remedy for Coughlin’s Bias and Judicial Misconduct is to Set Aside
Judgement and Terminate the Stalking Final Order of Protection
46. As a generic fairness argument, since the stalking order extension was an obvious
product of Judge Coughlin’s undeniable dismissive, biased misconduct as extensively indicated
hereinabove, the stalking order extension should be reversed.
47. This is consistent with well-established federal case law. Where the New Hampshire
Family Court Rules do not specifically mention Motions to Set Aside Judgement, reference to
the Federal Rules of Civil Procedure Rule 60 (“Relief from a Judgement or Order”) is proper. It
permits relief from final judgement on the grounds of:
“(3) fraud (whether previously called intrinsic or extrinsic), misrepresentation, or

misconduct by an opposing party;” or
“(6) any other reason that justifies relief.”
48. Judge Coughlin’s violation of “law” while carrying out his judicial function, both
criminal statute and “law” as defined the Code of Judicial Conduct, constitutes a “fraud” upon
the Court. “It is thus fraud where the court or a member is corrupted or influenced or influence is
attempted or where the judge has not performed his judicial function.” Bulloch v. United
States, 763 F.2d 1115, 1121 (10th Cir. 1985). (Emphasis added)
49. For the foregoing reasons, this Honorable Court should reverse Judge Coughlin’s
6/15/18 Order extending the stalking order and his 8/7/18 Order approving DePamphilis’s
motion for further draconian terms thereto.
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WHEREFORE, the foregoing compels the Respondent, Paul Maravelias, to pray this Court:
II. Reverse its 6/15/18 Order granting Petitioner’s Motion to Extend Duration of
Stalking Final Order of Protection, terminating the Stalking Final Order of
Protection;
III. Perfunctorily reverse its 8/7/18 Order granting Petitioner’s Motion for
Modification of Final Stalking Order of Protection to Include Further Terms; and
IV. Hold a Hearing, if necessary, on this matter.
PAUL J. MARAVELIAS,
in propria persona
October 31th, 2018 __________________________________
14
EXHIBIT A
A list, as provided by the Administrative Office of the Courts, of all 1/1/18-9/1/18 stalking cases
at Derry District Court wherein a final order was issued or extended
EXHIBIT B
Judge Leonard’s 2018 Stalking Order, Properly Following the Law by Referencing Specific
Facts Underlying the Finding of Stalking
16
EXHIBIT C
Referee Cross’s 2018 Stalking Order, Properly Following the Law by Referencing Specific Facts
Underlying the Finding of Stalking
17
EXHIBIT D
John Coughlin’s 2018 Original Stalking Final Orders of Protection
18
19
20
21
22
23
24
REFERENCED TRANSCRIPT PAGES
25
A139 A139
A140 A140
A141 A141
A142 A142
A143 A143
A144 A144
A145 A145
A146 A146
A147 A147
A148 A148
A149 A149
A150 A150
A151 A151
A152 A152
A153 A153
A154 A154
A155 A155
A156 A156
Docket No. 473-2016-CV-00124
v.
Paul Maravelias
RESPONDENT’S OBJECTION TO PETITIONER’S MOTION FOR MODIFICATION OF

STALKING FINAL ORDER OF PROTECTION TO INCLUDE FURTHER CONDITIONS
NOW COMES the Respondent, Paul Maravelias, and moves this Court to deny Petitioner’s
baseless Motion for Modification of Stalking Final Order of Protection to Include Further
Conditions dated 7/2/18. In support thereof, he represents as follows:
1. On 7/2/18, David DePamphilis’s daughter, the Petitioner, filed the aforementioned
Motion to impose even more severe court-ordered restrictions on Maravelias’s public free-
speech rights, even after her outright lies, inconsistent statements, and vulgar acts of harassment
against Maravelias were undeniably exposed in numerous ways during hearings before this Court
on 5/3, 5/4, and 6/8 of this year.
A. PETITIONER CHRISTINA DEPAMPHILIS’S MOTION AIMS TO EXCUSE HER

DOCUMENTED ILLEGAL BEHAVIORS AND EMPOWER HER TO CONTINUE VIOLATING
THE LAW, AND IS BUT ANOTHER PREDICTABLE ACT IN HER CONTINUED CAMPAIGN
OF LEGAL HARASSMENT AGAINST MARAVELIAS
1
A157 A157
2. As this Court will remember, Christina DePamphilis has cruelly bullied the victim, Mr.
Maravelias, with incitative, vulgar, and insulting posts on her public social media profile(s)
during the pendency of her criminally falsified “stalking” order against the victim/Respondent.
3. She now seeks to have this Court outlaw Maravelias’s mere possessing a record of her
behavior.
4. In particular, in June 2017, Petitioner posted an inflammatory picture of her boyfriend
directly addressing the victim and making incitative comments against him (6/19/18).
5. After failing to elicit any response from Maravelias that would violate her bad-faith
“stalking” order against him, she then posted a rehearsed image of herself, her father David
DePamphilis, and her 21-year-old boyfriend Matthew LaLiberte, all middle-fingering the victim,
and also making an incitative comment against the victim which identified him.
6. Viewed in the light of her acts of criminal harassment (RSA 644:4) against Mr.
Maravelias, the Petitioner’s present motion to prohibit Maravelias from “gaining access” to or
even “possessing” these public posts, even from “third parties”, is a risible perversion of
propriety.
7. Essentially, Christina DePamphilis wishes to be legitimated by this Court to continue
her vulgar harassment of Mr. Maravelias while injunctively restraining him from even using her
outrageous public social media exhibits for legal purposes to defend himself. This Court should
feel insulted by such a disrespectful and inappropriate attempt to abuse its power.
8. The Petitioner’s continued conduct of filing baseless motions against the victim is for
no valid purpose beyond solely to harass him; this Court should impose sanctions against her
accordingly for such repeated and patently unreasonable motions against Mr. Maravelias.
2
9. Furthermore, the Petitioner’s motion attempts to excuse her generic illegal behaviors,
past and future, demonstrated on her social media, in which Mr. Maravelias is not the victim.
10. In the Motion to Extend Hearing, this Court accepted inter alia a relevant evidentiary
exhibit of the “minor” Petitioner – a picture from her social media. In this post, she had pictured
herself, at age 16, holding a purse in her right hand and an open bottle of vodka in her left while
leaving a party at “4:43am”, with her parked, about-to-be-driven car in the background.
11. Christina DePamphilis also documented her psychoactive substance abuse, her private
sexual behaviors1, and her further underage alcoholic consumption in other social media
postings.
12. Thus, the Petitioner’s current desire to handcuff Maravelias in his public free speech
rights to third-parties is but a panicked “futile attempt” to avoid responsibility for her pictured
acts of law-breaking and perjury2, should Maravelias discontinue his magnanimous decline so-
far to lawfully document said public postings on the web, as he lawfully threatened to do in a
November 2017 response to Attorney Brown’s out-of-the-blue threatening letter3.
1
If this Court were to grant Petitioner’s Motion and thereby enter the enterprise of unlawfully policing private
conducts of speech, it would at least be equitable for the Court to order Christina DePamphilis to cease and desist
making improper posts revealing her private sexual behaviors before peers. Upon information and belief, this
behavior is socially unacceptable, and is considered disturbing by her peers. It is not practiced by other youth, even
by ones who picture themselves violating state laws on alcohol/marijuana consumption. While the latter is at least
somewhat socially acceptable, the Petitioner has caused discomfort to her peers with her unwanted social media
indications of her private sex life. These should never be publicly posted on social media, especially given her age.
2
Christina DePamphilis maintained her false claim under oath on 5/3/18 that she has “fear for her physical safety”
of Mr. Maravelias, despite her abusive, harassing, and unlawful conduct victimizing Mr. Maravelias. Indeed, this
Court has validated Christina DePamphilis’s hurtful law-breaking, in wrongfully granting an extension on her
Stalking Order. That matter is pending this Court’s review in a reconsideration pleading filed by Respondent.
3
Maravelias has every right to publicly republish her legally-public postings, as acknowledged by the mere
existence of the instant motion by Petitioner, the daughter of David DePamphilis, to injunct against said right.
3
13. The Petitioner requests that it be unlawful for Maravelias to even “possess” her social
media postings. This is so absurd that it would criminalize Mr. Maravelias for merely owning his
copy of this Court’s own public evidence exhibits from this case which he used at Hearing.
14. Thus, it would also violate the “Right to Know” law (91-A), guaranteeing access to
public court records, e.g. Christina DePamphilis’s posting of herself middle-fingering her victim.
15. While it is strongly speculated that there are many photographs in existence of the 17-
year-old female Petitioner which are already quite unlawful for anyone to even possess4, these
are most certainly not the public social media postings in question, which are fully lawful for
legal use.
B. PETITIONER’S MOTION DISHONESTLY OMITS PARTS OF MARAVELIAS’S ALLEGED

“THREATNING QUOTE” TO OBFUSCATE THE FACT THAT HE WAS MERELY COUNTER-
THREATENING LAWFUL DETERRENT RETALIATION IF LEGALLY ATTACKED
16. The Petitioner seems quite fixated on the fact that Maravelias merely responded to
Attorney Brown’s provocative, threatening letter to him. Maravelias made a comment along the
lines that he would “go nuclear and utterly destroy [Christina’s] academic and professional future”.
17. Conveniently, Petitioner omits the second part of Maravelias’s actual sentence: “[share her
own public social media artifacts], should David dare challenge [Maravelias] legally”.
18. Thus, Petitioner’s counsel first provoked Maravelias with an absurd, causeless threat of
lawsuit, and Maravelias then lawfully counter-threatened to share Petitioner’s already-public social
media posts, which might have a negative effect on her future due to her own outrageous behaviors.
4
18 U.S.C. § 2251, RSA 649-A:3
4
C. PETITIONER’S MOTION HAS NO BASIS IN THE LAW WHATSOEVER, AS THE REQUESTED
RELIEF FAR EXCEEDS THE POWERS GRANTED TO THIS COURT BY THE LAW AND
WOULD FURTHER BLATANTLY ABUSE MARAVELIAS’S BASIC CONSTITUTIONAL RIGHTS
TO FREE SPEECH, PRESS, AND PETITION, AMONG OTHERS
“Free speech and Liberty of the press are essential to the security of Freedom in a State: They ought,
therefore, to be inviolably preserved.” – N.H. Const., Part I, Article 22
19. A Stalking Order – whether lawfully issued or not – does not grant a trial court unspecified
powers to enjoin broad prophylactic injunctions on First Amendment-protected speech against
Respondent. Petitioner’s Motion seeks no relief whatsoever regarding Maravelias’s conduct with
her, but rather his speech to third-party actors. This is shameful and cowardly.
20. “Only narrow categories of speech, such as defamation, incitement and pornography
produced with real children, fall outside the ambit of the right to free speech.” State v. Zidel, 156
N.H. 684, 686, 940 A.2d 255 (2008). As Petitioner’s requested terms seek to injunct against
Maravelias’s free speech rights in none of the aforecited unprotected categories5, but rather would
proscribe any and all communications with large classes of third party individuals, her motion must
be unquestionably denied.
21. If this Court were to abuse its power by granting such latitudinous injunctions against Mr.
Maravelias’s public speech to parties other than Petitioner, it would incur liability in federal – let
alone state-level – lawsuits for damages on the grounds of willful, reckless First Amendment
transgression. Since this Court is well-aware of the facts and circumstances of this case and has
demonstrated a repeated pattern of inexcusable conduct evincing a clear bias against Respondent, it
5
Insofar as the Petitioner falsely claims Maravelias’s 12/10/17 email regarding her conduct was “libelous”, the
proper remedy for defamation is recovery of damages through civil equity litigation – not a personal-safety-
exclusive Stalking Order. Mr. Maravelias is the victim, not the author, of libelous/slanderous expression.
5
would be liable for Section 42 U.S.C. § 1983 federal damages in violating Respondent’s
constitutional rights while acting under color of state law.
22. That such violations be knowing or willful is not a prerequisite element for § 1983 action.
23. While the Court has authority to issue specific orders of protection as enumerated on the
standard form for Stalking Orders requested by Petitioner prior to and not after any hearing, the
Court may do so only “as is necessary to bring about a cessation of stalking”. See RSA 633:3-a, III-
a. Furthermore, 633:3-a, II. narrows the legal definition “stalking” such that it “shall not include
constitutionally protected activity, nor shall it include conduct that was necessary to accomplish a
legitimate purpose independent of making contact with the targeted person”.
24. Therefore, the requested modifications to the Stalking Order are absolutely illegal. They
overwhelmingly exceed the Court’s statutory authority to prohibit solely acts of further “stalking”,
of which constitutionally protected speech (e.g., to own/use public social media postings or
communicate with public employees independent of contacting Petitioner) is not.
25. Furthermore, if the Court nonetheless asserted an undefined power to grant these expanded
injunctions against Respondent, it would violate plainly established protections on constitutional,
legitimate speech to third-parties who are not plaintiffs in any civil protective order. Such a court
order would be contemptuous of Part I, Article 22 of the State Constitution and the First and
Fourteenth Amendments of the Federal Constitution, inter alia.
26. The relief sought in Petitioner’s motion is unconstitutional for being impossibly vague and
woefully overbroad. “Courts are suspicious of broad prophylactic rules in the area of free
expression, and therefore precision of regulation must be the touchstone in an area so closely
touching our most precious freedoms”. Montenegro v. New Hampshire Div. of Motor Vehicles, 166
N.H. 215, 220 (2014). The sought expanded terms of protection fail to sustain any “precision of
6
regulation” standard, as they are impermissibly overbroad and confusingly vague. A statute is
considered unconstitutionally “‘overbroad’ in violation of the First Amendment if in its reach it
prohibits constitutionally protected conduct.” Grayned v. City of Rockford, 408 U.S. 104, 114
(1972).
27. The second and third sought orders of protection forbid that the Respondent should contact
Petitioner’s “present or future” “academic providers” or “employers”. In imposing such groundless
authoritarian sanctions against Maravelias, the Court would expect him to conjure a supernatural
ability to presciently discern through a crystal ball who might be her “future employer(s)” or who
might be her future/current “academic provider(s)”, a term which is in itself impossibly vague.
28. Clearly, these measures are wickedly crafted to outlaw any and all acts of constitutionally
protected, self-defensive speech Maravelias may take on the web or elsewhere to defend his own
wrongfully discredited name, traduced in envy by the Petitioner-attention-seeker, as any public act
of speech whatsoever could be visible to an “employer” or “academic provider”.
29. “The overbreadth doctrine prohibits the Government from banning unprotected speech if a
substantial amount of protected speech is prohibited or chilled in the process.” Ashcroft v. Free
Speech Coal., 535 U.S. 234, 237 (2002). Even if the requested additional injunctions did function to
prevent further acts of “stalking”, they are still egregiously overbroad and therefore unactionable
manifestations of the statute, due to the copious protected speech that would be simultaneously
criminalized. See Doyle v. Comm’r, N.H. Dep’t. of Resources & Economic Dev., 163 N.H. 215,
221 (2012), which holds laws facially overbroad under Part I, Article 22 of the State Constitution
where “a substantial number of its applications are unconstitutional, judged in relation to the [law’s]
plainly legitimate sweep”. Id.
7
30. This Court must observe the brutally evident reality that Christina DePamphilis finds
herself in a guilt-ridden panic-mode state, now that her outrageous acts of protective order
falsification have been documented by Maravelias at the Hearing, that the wrong order was actually
extended against him (perpetuating the injustice), and that he still has full right to make public
speech acts to document her crimes. This Court issues jail sentences routinely in its official duties:
why then should it protect a nefarious perjurer-criminal from natural consequences as
comparatively tepid as having the objective facts of her own public words further publicized?
D. PETITIONER’S CITATION OF RSA 173-B:5 IS INCOMPLETE, DECEPTIVE, AND INVALID
31. Paragraph 9 of David DePamphilis’s daughter’s Motion attempts to deceive this Court into
believing it has any legal authority whatsoever to grant her request. This is another act of the
Petitioner’s storied obscurantism and willful misrepresentation of facts.
32. RSA 173-B is the domestic violence statute, in which the operative legal term is “abuse”.
33. “Abuse” is defined in 173-B:1, I as certain acts performed exclusively “by a family or
household member or by a current or former sexual or intimate partner” of the victim.
34. Mr. Maravelias has never been a “family or household member” of Petitioner, nor one of
the many men who may honestly claim to have been her “sexual or intimate partner”, thankfully.
35. Thus, 173-B terminology pertaining to “abuse” is thoroughly inapplicable to the instant
case.
36. Although the procedural stipulations of 173-B are applied to Stalking protective orders
under 633:3-a, III-a, this does not mean specific language pertaining to physically violent domestic
“abuse” in 173-B may be absorbed into a very different case pertaining to alleged “stalking”.
37. The Petitioner attempts to fool this Court into adopting a strange interpretation of 173-B:5
by obscurantistically omitting the full text of the statute for essential context:
8
“I. A finding of abuse shall mean the defendant represents a credible threat to the safety of the
plaintiff. Upon a showing of abuse of the plaintiff by a preponderance of the evidence, the court
shall grant such relief as is necessary to bring about a cessation of abuse.” (Emphasis added)
38. The Petitioner dishonestly cherry-picks the last 8 words of the statute in Paragraph 9 of her
Motion – omitting even the majority of the quoted sentence, let alone the surrounding context – to
advance a preposterous interpretation thereof before this Court.6
39. That is, the Petitioner deceitfully conflates the statute controlling the original issuance of a
domestic violence restraining order with a nonexistent power of this Court to issue further stalking-
related injunctions against Mr. Maravelias without any form of due process inherent to the original
issuance of Stalking order terms of protection, such as a full and fair trial, the notice of criminal
consequences for perjurious accusations in the petition form, and a public notary taking the oath of
the Petitioner certifying the truth of his or her allegations.
40. The dishonesty of Petitioner’s Paragraph 9 conduct is extreme and willful. This Court
should impose sanctions for such blatant attempts to fool it into breaking the law, and the bar
association should be contacted regarding a potential Code of Attorney Conduct violation7.
41. Absolute judicial immunity exists where a judge acts within a “judicial capacity”. Stump v.
Sparkman, 435 U.S. 349 (1978). Since issuing unlawful injunctions against Respondent on the basis
of an inapplicable legal standard for a separate cause of action (as documented above) establishes a
framework in which the Court knows it acts outside of the law, such an act would be in excess of
any legitimate “judicial capacity” and would dissolve the ordinary shield of absolute judicial
immunity from federal Section 1983 and/or other litigation.
6
See the parallel language specific to Stalking orders in 633:3-a, III-a, which differs from 173-B’s text and again
pertains to the initial process of Stalking Petition filing and subsequent court order post-hearing, not an unfettered
right to grant further unnoticed prayers for relief found nowhere in the Petition nor ever raised at the Hearing.
7
See New Hampshire Rules of Professional Conduct Rule 1.1 (b)(1), Rule 4.1, and the 2004 ABA Model Rule
Comment on Rule 4.1
9
42. In further support of the Court’s inability to impose unlawful, unconstitutional restrictions
on the public speech of Respondent, see Exhibit A (Respondent’s May 2018 Motion to Dismiss
filed in the baseless criminal case against Respondent for his 12/10/17 National Honor Society
ethics complaint email, which Petitioner references in her Motion).
E. THE LEGAL SCOPE AND LEGISLATIVE HISTORY OF THE STALKING STATUTE CONCERN
PERSONAL SAFETY PROTECTION EXCLUSIVELY – NOT ENFORCING CRIMINAL
SANCTIONS FOR ACTS OF DISAGREEABLE SPEECH OR EVEN DEFAMATORY SPEECH.
43. The expanded terms requested by Christina DePamphilis have absolutely nothing to do
with protecting her physical safety. They are fretful, neurotic exasperations that the Court order
Maravelias 1) not possess public legal exhibits and 2) not make any communications to third-
parties. Even if this were a legitimate “protection” of someone’s “career” or “academics”, the law
affords this Court no ability to enforce random “protection” injunctions at its own despotic, nanny-
state volition, as requested.
44. The Stalking statute permits physical-violence-prevention-related protections exclusively.
F. PETITIONER’S ABUSIVE MOTION FALSELY ACCUSES THE RESPONDENT EXACTLY OF

HER OWN DISTURBING BEHAVIORS
45. When taking breaks from secretly collecting pictures of Maravelias’s private bedroom
without his knowledge and harassing him with vulgar middle-finger posts with her boyfriend, the
Petitioner Christina DePamphilis has been monitoring Maravelias’s online activity and gaining
access to material she is not intended to see. In a recent filing, she revealed that she has likely
hacked into Maravelias’s private business product support forum and accessed Maravelias’s private
postings on an off-topic discussion section therefrom.
46. Given the Petitioner’s disturbing and obsessive behaviors, Maravelias understandably feels
violated, uncomfortable, and utterly creeped-out. But, he dares not file another honest and truthful
Stalking petition – even as a victim of true stalking – since this Court has proven its undeniable
10
prejudicial hostility against Maravelias in forcing him to pay an opponent’s attorney’s fees in a
factually corroborated, truthful Petition filed against David DePamphilis.
47. Thus, at the very least, this Court ought not to unlawfully expand the abusive “terms of
protection” in the same extant Stalking Order it knows to be originated in falsification.
48. Furthermore, Respondent Maravelias has been absolutely magnanimous up to this point in
declining to exercise his right to disseminate DePamphilis’s outrageous social media postings. The
Court should perceive Maravelias’s good-character benevolence, and not further abuse his speech
rights through unilateral acts of judicial tyranny.
49. To prove this, Maravelias represents to have been sent the following social media postings
made by Christina DePamphilis, which he has opted never to share heretofore in any context:
a. A post showing Christina conspiring with her brother Nicolas DePamphilis over SMS
about where the two may consume an illegal drug without David DePamphilis
knowing;
b. A video of Christina forcing the slurred exclamation “I’m. So. High!” through an
intoxicated blur while sitting on a toilet at a party;
c. A highly inappropriate, suggestive video of Christina genuflecting on her knees and

sucking a frothy white fluid (hypothesized to be whipped cream) into her mouth which
then appears smeared on her face;
d. Photographs and videos of Christina climbing out of her second-story bedroom

window late at night to escape to a party in secret;
e. A video wherein Christina brags of “passing” a field sobriety test a police officer
administered to her when pulled over returning from said party;
f. A photograph proving she was indeed at her Salisbury beach house in February 2017,
and therefore feloniously perjured before this Court on 5/4/18 when so denying; and
g. A video picturing Christina intoxicated on a ski lift and casually joking about the
danger thereof, revealing she later took rescue snowmobile escort down the mountain.
50. Maravelias is not “obsessed” with a delinquent law-breaker. His mind has not been
“preoccupied at all with [her]”, as written to Attorney Brown in the November 2017 letter. He has
11
not disseminated any of the aforementioned exhibits. This shows his clemency and non-obsession.
If this Court will illegally injunct further against Maravelias’s free speech rights through shameful
diktats, he will make broader exercise of the free speech rights he still has.
51. Furthermore, since Maravelias has been sent the social media exhibits in question by
independent third parties who support him, the instant Motion to further abuse Maravelias is an
incredibly foolhardy act by the Petitioner. It is suspected that these third parties too will discontinue
their independent magnanimity in allowing Christina DePamphilis to grow in her delinquency
without public correction or documentation of the said.
CONCLUSION
“To extend the Stalking Order in this case would show plaintiffs all across the great State of New
Hampshire that you can come to court to get a restraining order against someone – to shut them up when
they say things you disagree with.” – Paul Maravelias, 6/8/18 Hearing Closing Argument
52. Mr. Maravelias enjoys enormous validation of his trenchant determination from months
ago that the DePamphilis bad-faith “stalking order” abuse against him has been but a cowardly
attempt to restrict his speech, having nothing at all to do with a “fear for personal safety”.
53. The Petitioner’s shameful, panicked, and obscurantist Motion decisively confirms this.
54. The said is a but veiled attempt to criminalize Maravelias’s quotidian existence. It is a
nefarious scheme to conduce an innocent human life into doubtless imprisonment. It is a cowardly
contrivance birthed of the perverse validation this Court’s errors have tortiously bestowed upon
Maravelias’s abusers, and lacks any legal merit. It is beyond shameful that David and Christina
DePamphilis still machinate against the victim such dishonest abuse-stratagems which cowardly
masquerade under the misleading optics of protectivism.
12
A169 A169
EXHIBIT A
A170 A170
A171 A171
A172 A172
A173 A173
A174 A174
A175 A175
A176 A176
A177 A177
A178 A178
A179 A179
A180 A180
A181 A181
Docket No. 473-2016-CV-00124
v.
Paul Maravelias
REPLY TO PETITIONER’S REPLY TO RESPONDENT’S OBJECTION TO PETITIONER’S

MOTION FOR MODIFICATION OF STALKING FINAL ORDER OF PROTECTION
NOW COMES the Respondent, Paul Maravelias, and replies to Petitioner’s Reply to
Respondent’s Objection to Motion for Modification of Stalking Final Order of Protection to
Include Further Conditions dated 7/12/18. In support thereof, he represents as follows:
A. CHRISTINA DEPAMPHILIS COMMITTED A CLASS B FELONY UNDER RSA 641:5 I. (B)

WHEN SHE FILED THE AFORECITED MOTION; THE COURT WOULD BE COMPLICIT IN
THE CRIME OF WITNESS AND INFORMANT TAMPERING TO GRANT SAID MOTION
1. As documented in a criminal complaint filed on this date with the Derry Police
Department (see Exhibit A), Christina DePamphilis committed a class B felony of “Tampering
With Witnesses and Informants” when she filed the instant motion in this Court on 7/2/18 to
prevent Maravelias from “possessing” her “social media communications”, parts of which she
knows constitute highly relevant legal exhibits that Maravelias is using in his defense both inside
this case and inside the recently-appealed decision of this Court to grant attorney’s fees against
him in Paul Maravelias v. David DePamphilis (473-2017-CV-150).

1
A182 A182
2. Therefore, by filing said motion, she “attempt[ed] to induce or otherwise cause
[Maravelias] to …withhold any testimony, information, document or thing” [certain social media
posts already entered as evidence exhibits] while “believing” and “knowing” that an “official
proceeding” was underway. See RSA 641:5 I.
3. Thus, if the Court were to grant her outrageous motion for modification of stalking order
terms, the individual judicial actor carrying out such wrongful granting would likewise commit a
count of class B felony 641:5 misconduct, as the Petitioner’s “social media communications” are
supremely relevant in indicating she had no fear of the Respondent (e.g., while cruelly deriding
him with her and her boyfriend’s middle fingers in an attempt to provoke an inflamed jealousy
response and/or stalking order violation), and are therefore material to this Court’s pending
ruling on Maravelias’s Motion for Reconsideration as well as to any appeal which may follow.
B. PETITIONER’S REPLY GRANTS MEANINGLESS CONCESSIONS IN A DECEPTIVE PLOY

TO MAKE HER REQUESTED FURTHER STALKING ORDER TERMS SEEM REMOTELY
REASONABLE
4. In unsatisfactory response to Respondent’s constitutional case law exposition of her
requested terms’ rampant violation of overbreadth and vagueness doctrines, she reassures that
her terms may be amended with additional “knowingly” and “about her” qualifications. With this
adjustment, she alleges her final proposed terms are reasonable requests having little to no
impact on Maravelias’s legitimate activities and having solely a valid protective function for her.
5. In reality, these seeming concessions are vapid and meaningless, as “knowing”
willfulness is already a necessary element to any violation of protective order terms. See RSA
633:3-a I. (c), which states, “knowingly ... engages in a single act of conduct that both violates
the provisions of the order and is listed in paragraph II(a)”.
2
6. Further, the Petitioner seeks injunctive prohibition of legitimate acts which are listed
nowhere in the enumerations of “paragraph II(a)” in 633:3-a constituting a “course of conduct”.
7. Thus, even if the Court did illegally grant the requested terms in part or in whole,
Maravelias could never be prosecuted for violating them, due to the “and is listed in paragraph
II(a)” stipulation of 633:3-a I. (c), supra.
8. Maravelias’s public speech “about” the Petitioner’s demonstrable acts of falsification and
restraining order abuse against him could be construed to be loosely “about her” yet are
nonetheless legitimate acts of First Amendment-protected speech made for purposes independent
of contacting the Petitioner or her academic providers or employers. However, as Respondent
already showed in his 7/5/18 objection filing, the Petitioner seeks these terms as a broad “catch-
all” injunction against Maravelias’s legitimate public speech, since said acts of speech could be
visible to anyone, including to “academic providers” or to “employers”.
9. Unsurprisingly, Petitioner entirely neglects to address this critical issue in her 7/12/18
filing, likely hoping the Court will overlook it.
10. Maravelias reiterates and incorporates by reference all arguments – most of which are
still uncontested by Petitioner – from his 7/5/18 objection filing which speak to the illegality and
unconstitutionality of the requested further stalking order provisions.
3
A185 A185
Exhibit A
July 16th, 2018 To: Derry, NH Police Department
Paul J. Maravelias
Windham, NH 03087
Re: Christina DePamphilis Criminal Complaint (Falsification in Official Matters and other
crimes)
______________________________________________________________________________
Dear public servants of New Hampshire,
I am the victim of numerous falsification-related crimes performed by Christina DePamphilis and

orchestrated by herself and her father David. After a December 2016 telephone argument David had
with me, he became inflamed in anger and ultimately conspired with his daughter to file a false, bad-
faith “Stalking Petition” against me containing willful lies.
This happened once I angered David by asking him on 12/23/16 to “stop harassing my parents” over
text. Then he said, “that’s the last straw”, meaning he would seek legal retaliation against me. His
daughter’s retributive, bad-faith “stalking petition” followed his “last straw” comment 5 days later.
When they filed this stalking petition on 12/28/16 containing numerous lies, I hadn’t ever spoken a
word to Christina DePamphilis since the day she politely romantically rejected me (12/12/16), over
two weeks prior. It was an unlawful, malicious retaliation-act birthed from her father’s frustration and
documented “last straw” quote. I am a victim of demonstrable protective order abuse.
Due to their subsequent acts of falsification and perjury, I have had a false stalking order issued against
me (which I’ve complied with), I was falsely arrested once (baseless charges were later dropped), and I
have had my name wrongly defamed as a “stalker”, including numerous other severe damages to me.
During the pendency of her fraudulent “stalking” order, Christina has made incitative, vulgar posts
directed towards me on public social media with her boyfriend. She identified me and was hoping to
get me to violate the “stalking order” so I’d be arrested and further abused/humiliated.
This was after lying about having “fear” of me; therefore, these posts were highly material to a recent
series of hearings in Derry for renewing the stalking order. In these recent 5/3/18, 5/4/18, and 6/8/18
stalking order extension hearings at Derry District Court, undeniable documentation of Christina’s
falsification crimes came to light. This forms the basis of the herein criminal complaint to Derry, NH
Police Department.
I am desperate for justice. The court has repeatedly failed to hold this false accuser accountable. Judge
John J. Coughlin recently granted Christina’s stalking extension against me in an act of blatant judicial
misconduct. Judge Coughlin retires on 9/5/18, so his surreal fact-amnestic abuse of discretion was
necessarily a dismissive CYA-act done with the assurance of no professional consequences.
Therefore, I now turn to the police for objective, unbiased law enforcing.
1
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During the 5/3/18 court hearing, Christina informed me of her “independency”. She insisted herself as
the original and free-will author of all these acts. She denied her father David “made” her do any of it.
Given her “independency” and personal culpability in these acts by her own insistence, I highlight
Christina DePamphilis’s specific crimes as follows for which I request prosecution.
COUNT #1: PERJURY (641:1) AND FALSE SWEARING (641:2)
Summary: As discovered on 6/8/18 at the Derry District Court hearing, Christina DePamphilis
committed Perjury and False Swearing in her original 12/28/16 stalking petition form. It is an “official
proceeding”, and the court notarizes the “oath” or “affirmation” of the petitioner.
Statute of limitations: The statute of limitation for Perjury (class B felony) is 6 years. Further, since
these crimes only came into legal documentation last month, the statute of limitations starts then
(5/4/18). See RSA 625:8 III. (e) Further, DePamphilis’s acts of falsification are part of an ongoing
course of conduct whose most recent offense was on 5/4/18 at the Derry District Court stalking order
hearing. See RSA 625:8 IV.
Specifics:
• Christina asserted in her petition that Maravelias had stated a certain weird, creepy comment to her:
that Maravelias said she would “learn to love me [him, Maravelias]”.
• On 6/8/18 in Derry, Maravelias documented for the court that on the 1/5/17 hearing, he had asked
DePamphilis if he had truly said the word “learn” to her (the alleged disturbing quote). She said
“no”. Then Maravelias said, “I’m just curious because it says in your [petition] I did”. Then she
said, “same idea”.
• The fact that Maravelias has been stripped of his rights and branded a stalker because a false
accuser chose to make up things he never said and excused herself by saying “same idea” is
unacceptable. The stalking petition form states, “I understand that making a false statement on this
petition will subject me to criminal penalties”. Christina’s own admission under oath proves her act
of willful perjury.
• This was a material misrepresentation, as the court erroneously found Maravelias had an
“obsession” with the false accuser, and wrongly issued the false stalking order on this finding.
• Even if not “material”, this statement was still a misdemeanor count of False Swearing (641:2).
Evidence and Proof (see enclosed USB drive and “Evidentiary Appendix” below):
A. 12/28/16 Stalking Petition in Christina DePamphilis vs. Paul Maravelias, (473-2016-CV-124)
“122816StalkingPetitionScan.pdf” in USB drive and hereinafter referenced multiple times
B. Page 30 and 31 of transcript of 1/5/17 hearing (Salem District Court, 473-2016-CV-124)
C. Transcript/recording of 6/8/18 hearing (Derry District Court, 473-2016-CV-124)
COUNT #2: PERJURY (641:1) OR FALSE SWEARING (641:2)
Summary: At the 5/3/18 hearing, Maravelias cross-examined Christina DePamphilis asking why she
2
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cruelly bullied him by directing vulgar middle-finger posts against him on her public social media page
with her boyfriend (6/21/17), while she had a “stalking” order against Maravelias and after falsely
claiming she was fearful of him in order to obtain said “stalking” order. She then intentionally lied
under oath about her purpose and intention with this 6/21/17 post, which was a crucially relevant,
material issue in this stalking order extension hearing on 5/3-4/18 and 6/8/18. Stalking orders are
supposed to be predicated upon a valid fear the petitioner has for their physical safety.
Specifics:
• DePamphilis first excused her behavior with the 6/21/17 post by claiming her purpose was solely
to “let you [Maravelias] know” she knew he was “stalking” [viewing] it.1
• The perjury was proven when Maravelias pulled out another exhibit a few minutes later she didn’t
know he had had: a different post she had made on 6/19/17.
• This 6/19/17 of hers had already directly identified Maravelias two days before her 6/21/17 middle-
finger post did.
• This 6/19/17 post pictured her boyfriend making a provocative statement directed towards
Maravelias, calling him out by initials. After nervously trying to skirt the issue, she did not deny
during cross-examination this was directed towards him.
• Therefore, Christina DePamphilis lied under oath on 5/3/18 about her purpose for the 6/21/17
middle-fingers post being just to “let [Maravelias] know” she knew he was looking at her public
account, as she had already “let [him] know” with the 6/19/17 post. Her purpose for the 6/21/17
middle-fingers post was actually to further bait Maravelias to violate her falsified “stalking” order.
• These misrepresentations were “material”, because the court went on to wrongly extend the
stalking order based on the absurd notion that DePamphilis had “reasonable fear for her personal
safety” [ostensibly, because Maravelias invited her to dinner two years prior, never spoke to her
again, and then dared to defend his defamed name in public contexts during the stalking order].
Demonstrating the sole purpose of harassment behind her posts countered the false claim that
DePamphilis was still “fearful”. Therefore, her intentional misrepresentations were material.
• Even if they were not material, she is still guilty of misdemeanor False Swearing (641:2).
Evidence and Proof:

A. 5/3/18 and 6/8/18 hearing audio recording/transcript
B. DePamphilis’s 6/21/17 and 6/19/17 social media posts
“2018POExtensionCaseExhibits.pdf” in USB drive and hereinafter referenced multiple times
COUNT #3: PERJURY (641:1) OR FALSE SWEARING (641:2)
1
Maravelias was of course monitoring her online activity, correctly anticipating defamatory content to
appear thereon, and documenting the said for legal purposes.
3
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Summary: On 5/3/18, Christina DePamphilis committed another act of perjury in relation to the same
highly relevant legal topic of her bullying posts against Maravelias on social media. She knowingly
lied about who “knew” about what the posts were for, and to whom they were directed [Maravelias].
Specifics:
• In her 6/21/17 vulgar harassment post against Maravelias, she included her father David
DePamphilis and boyfriend Matthew LaLiberte beside her, both middle-fingering the camera
[Maravelias, as the intended viewer].
• On cross-examination, Maravelias asked Christina DePamphilis “whose idea” this post was.
• To try to insulate her father2 and boyfriend, she first said “[she] was the only one who knew” that
the rehearsed picture was going to be directed to Maravelias. In other words, Christina dishonestly
alleged she alone knew what the circumstances of the picture even were, as if the two other men
she involved were just willingly cooperating with her rehearsed picture totally unaware of why.
• But then, when Maravelias revealed the earlier 6/19/17 post she didn’t know he had had, she
admitted that “between me and my boyfriend we understood who [sic] it was for”.
• Therefore, she willfully lied when she first said she was the “only one” knowing the intention of
these posts. She later contradicted her first statement admitting that “[her] boyfriend” also knew.
This specific area of factual questioning was absolutely critical and material in the stalking
extension hearing to prove that she actually did not have any “fear” of Maravelias.
• For the same reasons as in Count #2, these misrepresentations were “material”. Further, even if
they were not material, she is still guilty of misdemeanor False Swearing (641:2).
Evidence and Proof:

A. 5/3/18 and 6/8/18 hearing audio recording/transcript
B. DePamphilis’s 6/21/17 and 6/19/17 social media posts
COUNT #4: TAMPERING WITH WITNESSES AND INFORMANTS (641:5)
Summary: Two weeks ago, on 7/2/18 at Derry District Court, Christina DePamphilis filed a motion to
attempt to cause Maravelias (“a person”) to “withhold … testimony, information, document or [a]
thing”, while knowing and “believing that an official proceeding” is “instituted”. This is a class B
felony under RSA 641:5.
Specifics:
2
David DePamphilis, against whom Maravelias had filed a truthful stalking petition for his separate
behaviors against him not addressed herewith, which was wrongly not granted by the court.
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• Under the false guise of “protectivism” and using her false stalking order as a weapon against
Maravelias’s speech, Christina DePamphilis petitioned the Derry District Court on 7/2/18 to
expand the stalking order terms to prevent Maravelias from:
“gain[ing] access to or possess[ing] any of Petitioner’s social media communications either
directly or through a third party” (See DePamphilis 7/2/18 motion)
• DePamphilis knows that her social media posts documenting her wild bullying of Maravelias are
material exhibits to the ongoing restraining order litigation in Derry District Court.
• Furthermore, DePamphilis knows Maravelias’s intentions to appeal this case to the Supreme Court.
• She also attended the hearings on Maravelias’s stalking petition against David DePamphilis,
wherein the same social media posts were relevant given David’s participation therein.
• DePamphilis knows this other case is also ongoing litigation, as Maravelias has appealed to the
Supreme Court over the trial court’s outrageous act of granting David DePamphilis attorney’s fees.
• Thus, Christina DePamphilis’s abusive, bad-faith stalking order modification motion is an attempt
to illegalize Maravelias’s mere “possession” and legal use of relevant exhibits from her social
media account, already part of the public record in both stalking court cases, and crucially relevant
to ongoing and upcoming litigation.
• This is both a blatant violation of RSA 641:5 I. (b) and an act of supreme cowardice.
• Further, after being informed of the impropriety of her censorship-attempt-act in Maravelias’s

7/5/18 court objection to her motion, she filed a reply on 7/12/18 which reasserted her unlawful
attempt to have Maravelias barred from defending himself with said public legal exhibits picturing
her social media communications. Thus, Christina DePamphilis is guilty of two separate counts.
Evidence and Proof:

Nota bene: A and B alone should suffice, but C through G are included for further corroboration that
Christina knows about the supreme relevance of these same social media artifacts to both ongoing
official proceedings.
A. DePamphilis’s 7/2/18 “Motion for Modification of Stalking Final Order of Protection to Include
Further Terms” filed in 473-2016-CV-124, and her 7/12/18 follow-up reply
B. Maravelias’s exhibits from DePamphilis’s social media account, entered as evidence at the stalking
hearing (see “2018POExtensionCaseExhibits.pdf”)
C. The court’s order extending the stalking order and Maravelias’s Motion for Reconsideration in the
matter, indicating ongoing “official proceedings” and foreshadowing appeal
D. Transcript/audio recording of 6/8/18 stalking order extension hearing at Derry District Court where
Maravelias indicates intentions to appeal if wrong outcome perpetuates stalking order
F. A “Rule 7 Notice of Mandatory Appeal” which Maravelias filed with Supreme Court in the
simultaneous case against Christina’s father David regarding an improper award of attorney’s fees
(473-2017-CV-150), a case which Christina knows about and which also contains the referenced social
media exhibits she seeks to illegally censor
G. Transcript/audio recording from 5/3-4/18 hearing where Christina affirms she was present to
5
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witness the stalking case against her father where the same social media posts were entered as exhibits
H. Maravelias’s 7/5/18 objection court filing which called-out this misconduct before Christina
willfully reaffirmed her unlawful informant tampering attempt in her subsequent 7/12/18 legal reply
COUNT #5: FALSIFYING PHYSICAL EVIDENCE (641:6)
Summary: Christina DePamphilis deleted certain social media accounts of hers immediately prior to
court hearings in which she knew the content of said deleted accounts to be factually relevant and
material. Under oath at 5/3/18 and 5/4/18 hearings, DePamphilis did not deny deleting these accounts.
Statute of limitations: These deletions occurred in late 2017 (December) or the first days of 2018.
Thus, this crime occurred well-under 1 year ago.
Specifics:
• In 2017, Christina DePamphilis maintained two social media accounts online at

http://christinamamaria.vsco.co and http://www.instagram.com/tipsytina69/
• As admitted under oath on 5/3/18 and evidenced by her acts of bullying/harassment in June 2017,
she knew Maravelias was “viewing” the vsco.co account. She also stated she knew he was
gathering her exhibits to “use against [her]” in the legal matters.
• Paul Maravelias filed a stalking petition against David DePamphilis on 12/8/17. A hearing was
scheduled for 1/3/18.
• Christina DePamphilis motioned the court to extend her existing stalking order against Maravelias
for another year on 1/5/18.
• Immediately prior to the 1/3/18 hearing on the petition against her father and to her 1/5/18
extension motion on her stalking order against Maravelias, she deleted the accounts.
• The timing of the deletion is corroborated by DePamphilis’s 5/3-4/18 admissions under oath and by
the attached screenshots of the deleted account(s).
• Although Maravelias possessed screenshots of these social media exhibits, DePamphilis’s willful
deletion act prevented these posts from being objectively verified at the web link. Indeed, Christina
DePamphilis attempted to advance the absurd notion at the 5/4/18 hearing that Maravelias had
digitally manipulated his screenshot exhibits of her postings. Had she not deleted the actual internet
resources (her posts) in question, these false accusations could be disproved before the court.
• Therefore, it is proven beyond doubt that Christina DePamphilis “destroy[ed], conceal[ed] or

remove[d] any thing with a purpose to impair its verity or availability in such proceeding or
investigation”, while knowing and believing that an “official proceeding” was underway.
Evidence and Proof:

A. Transcript/audio recording of 5/3/18 and 5/4/18 Derry District Court hearings on stalking extension
6
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B. All of Maravelias’s exhibits from both stalking cases involving DePamphilis’s social media posts
(such as her 6/19/17 boyfriend post or her 6/21/17 middle-fingers post against Maravelias) (see
“2018POExtensionCaseExhibits.pdf” in USB drive enclosed)
C. Screenshots indicating the deletion of these accounts, independently verifiable by accessing the
aforementioned links
COUNT #6: PERJURY (641:1)
Summary: Christina DePamphilis willfully perjured at the 1/5/17 hearing that Maravelias had
mentioned her “age of consent” in his 12/12/16 conversation with her. On 2/7/17, Judge Robert S.
Stephen wrongly issued the false restraining order against Maravelias citing this specific lie: that
Maravelias had the said creepy, weird comment to Ms. DePamphilis. Further, she reaffirmed this
fallacy on 5/3/18 at Derry District Court.
Statute of Limitations:
6 years for class B felony Perjury under 641:1
Specifics:
• The Windham Police possess an audio recording of the very same verbal exchange proving
Maravelias had never mentioned anything remotely close to the phrase “age of consent”.
• Maravelias had been taking a sentimental audio recording of the exchange (a romantic dinner
invitation) due to its personal significance to him. He intended to share it with Ms. DePamphilis
afterwards; he didn’t know she and her father would victimize him as they later did.
• When Maravelias tried to use the recording to disprove Christina DePamphilis’s false,
manufactured “stalking” accusations against him, he was forbidden from playing it in court under
RSA 570. Maravelias’s abusers then had him arrested for merely recording his own conversation –
all the while the DePamphilis family got off with felony perjury and restraining order abuse against
Maravelias. This is a sick, warped injustice and must be rectified.
• Further, this shocking lie that Maravelias had spoken something as discomforting and awkward as
sexualizing reference was found nowhere in Christina DePamphilis’s stalking petition, which did
fully describe the same 12/12/16 verbal exchange. This stalking “buzz-word” lie was only
concocted later-on, for the hearing, in order to obtain the falsified stalking order.
• The materiality of this “age of consent” quote lie is beyond dispute, as Judge Stephen specifically
cited it in his finding of fact for the final stalking order against Maravelias.
Evidence/proof:
A. Transcript of 1/5/17 hearing
B. Final stalking order issued by Judge Stephen in 473-2016-CV-124
C. Maravelias’s 12/12/16 cell-phone audio recording file, possessed by Windham Police
D. Attached letters from Maravelias’s parents, who lawfully listened to the same recording in Vermont
7
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COUNT #7: HARASSMENT (644:4) AND DISORDERLY CONDUCT (644:2)
The facts rehearsed in Counts #2 and #3 also document beyond probable cause that Christina
DePamphilis has “insulted, taunted, or bullied” someone “in a manner likely to provoke a violent
response”, which is criminal Harassment in New Hampshire. Furthermore, her same vulgar incitation
social media posts against Maravelias constitute Disorderly Conduct under 644:2 II. (a).
However, these content-oriented infractions are trivial compared to the severity of Christina’s social
media posts when viewed in their falsification context of 1) lying about having “fear” of Maravelias to
obtain a false stalking order, and of 2) her deceitful perjuries under oath to excuse these posts in her
attempt to extend the stalking order, as formerly discussed in Counts #2 and #3.
COUNT #8: FRAUD BY ATTEMPT (629:1) OF THEFT BY DECEPTION (637:4) AND

FALSE SWEARING (641:2) AND/OR UNSWORN FALSIFICATION (641:3)
Summary: In Christina DePamphilis’s 12/28/16 stalking petition, she petitioned the court to order
Maravelias to pay her for “surveilance [sic] camera[s]” her father had installed outside their home. The
installation of these cameras had absolutely nothing to do with Maravelias’s lawful conduct of
appearing at his former-friends’ house on 12/12/16 to invite Christina to dinner, and then never appear
there again. As evidence shows, there was actually a separate and valid security incident at the
DePamphilis home not involving Maravelias whatsoever which motivated the installation of the
security cameras. At the hearing, DePamphilis mendaciously denied that this separate incident ever
happened.
Statute of limitations:
6 years for Attempt of Theft by Deception per RSA 625:8 (a) and/or (b), as “theft” is either a Class A
or B felony under 637:11, and as “the penalty for attempt is the same as that authorized for the crime
that was attempted”. See RSA 629:1 IV.
1 year for misdemeanor Unsworn Falsification, but starting on 4/13/18, the date of “discovery of the
offense”. See RSA 625:8 III. (e)
Specifics:
• In December 2016 text messages between Maravelias’s parents and DePamphilis’s parents,
Christina’s mother confessed that there had been an October 2016 security “incident” at night
outside the DePamphilis home.
• Christina DePamphilis independently documented the security “incident”, having nothing to do

with Maravelias, by posting on her “tipsytina69” account. On 10/20/16, she made a post with the
following text:
“im so fucking tired and annoyed theres people banging on my house at 1am and now tonight and my mom
walks out trying to be cool and scare them by saying shes calling the cops and dad goes out with a fake gun
OK i have so much american hw i dont have time for any of this and now my parents think these people are
8
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targeting me lol no but SICK COOL FUN ALRIGHT (:”
-Christina DePamphilis’s 10/20/16 post on “tipsytina69” Instagram account documenting security incident
• At the 1/5/17 hearing on her stalking petition, Judge Robert S. Stephen declared his confusion as to
why he would force Maravelias to pay for DePamphilis’s security camera expenses as part of her
petition. The judge also commented, “especially since he’s [Maravelias] alleging another incident
[the October 2016 security incident – the actual cause of the security camera installation]”
• DePamphilis, by her counsel Jerome Blanchard, then replied “yeah, well, there’s no evidence – we
contest that”.3
• DePamphilis therefore attempted to have Maravelias court-ordered to pay absolutely unrelated

expenses relating to security camera installation at her house, when none of his lawful, polite
conduct had caused the said installation, but rather a valid October 2016 security incident had.
• DePamphilis perjuriously denied that this incident ever happened and/or intentionally failed to
correct her misrepresentations.
• With her 10/20/16 social media post and false statement in court denying the incident taken in
conjunction, it is undeniable that Christina DePamphilis created or reinforced “an impression
which is false and which that person does not believe to be true” See RSA 637:4 II. (a)
• She also “fail[ed] to correct a false impression which [s]he previously had created or reinforced”
See RSA 637:4 II. (b)
• These false impressions were attempts to obtain or exercise “control over property of another
[Maravelias’s funds] by deception and with a purpose to deprive him thereof”. See RSA 637:4 I.
• Judge Stephen denied DePamphilis’s extortionary request; but, “a person commits theft under this
section notwithstanding that the victim has suffered no actual or net pecuniary loss.” See RSA
637:4 IV.
Evidence and Proof:

A. Pages 1-4 of a 4/13/18 post-trial filing Maravelias made in the Paul Maravelias v. David
DePamphilis stalking case entitled “Plaintiff’s Reply to Respondent’s Brief on Motion for Award of
Attorney’s Fees”, when that case had devolved solely into litigation over award of attorney’s fees
B. Christina DePamphilis’s 10/20/16 social media post on her “tipsytina69” Instagram account (exhibit
within 4/13/18 document)
C. Christina DePamphilis’s 12/28/26 stalking petition (in particular, Page 2 requesting ordered
financial compensation for the security equipment)
D. Transcripts of the 2/1/17 court hearing at Salem District Court, where DePamphilis raised her
request for “costs” to the court and perjuriously denied the existence of the ulterior motivating incident
E. Laurie DePamphilis’s 12/13/16 text message to Maravelias’s parents further corroborating the
falsely-denied October 2016 security incident (exhibit within the 4/13/18 document)
3
Note scrivener’s error in Page 209 of 2/1/17 transcript.
9
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COUNT #9: DEFAMATION (644:11) AND FALSE SWEARING (641:2)
Summary: Maravelias recognizes that, unfortunately, the vast majority of Christina DePamphilis’s
reckless defamatory conduct against him with her absurd “stalking” allegations may be insulated from
criminal prosecution due to the civil trial court’s error in issuing the falsified stalking order, thus
arguably forming a legal finding of “stalking”, however incorrect. Therefore, Maravelias limits his
criminal complaint for DePamphilis’s defamation to the following outrageous and unsubstantiated
additional claim she made in her 12/28/16 stalking petition, likely crafted solely to increase chance of
obtaining the temporary protective order pre-hearing for a strategic upper-hand.
Statute of limitations:
1 year for class B misdemeanor; however, beginning on 5/3/18, whereupon Christina DePamphilis
reasserted the same baseless defamatory comments at Derry District Court when questioned
thereabout. See RSA 625:8 IV.
Specifics:
• Christina DePamphilis claimed that there were “rumors of a knife incident” regarding Maravelias
when responding to a question on the court’s prewritten form asking if the Respondent had a
history of violence.
• Maravelias has never been party to a “knife incident”, nor has ever before been accused of being
party to any “knife incident”.
• When Maravelias asked DePamphilis about this outrageous comment in 5/3/18 cross-examination,
she was not able to tell the court any basis she had for making this written statement.
• She said “a friend” had told her, but she refused to name the supposed informant individual
• Christina DePamphilis made these comments while knowing they were false; further, they were
comments in a public court record which she knew would “tend to expose” Maravelias “to public
hatred, contempt or ridicule” (an accusation of violence).
• Furthermore, DePamphilis reinforced her accusation on 5/3/18, claiming anew that Maravelias had
“threatened someone with a knife”, which exceeds even her original defamatory comment that
there were “rumors of a knife incident”.
Evidence and Proof:

A. DePamphilis’s 12/28/16 stalking petition
B. Transcripts/audio recording of 5/3/18 hearing at Derry District Court
COUNT #10: UNLAWFUL INTOXICATION (179:10), UNLAWFUL POSSESSION OF

ALCOHOL (179:10), TRANSPORTING ALCOHOL BY A MINOR (265-A:45), AND/OR
POSSESSION OF CONTROLLED SUBSTANCE/INTOXICATION (318-B)
10
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A196 A196
1
continued unwanted contact and his Middlesex County 508 area code cell number, similar to
the aforecited harassing text message:
A8
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A198 A198
April 13th, 2018
Robin E. Pinelle, Circuit Clerk
NH Circuit Court Paul Maravelias
10th Circuit – District Division – Derry 34 Mockingbird Hill Rd
10 Courthouse Lane Windham, NH 03087
Derry, NH 03038
RE: Paul Maravelias vs. David DePamphilis

Docket No. 473-2017-CV-00150
Dear Clerk Pinelle,
Enclosed please find Plaintiff’s Reply to Respondent’s Brief on Motion for Award Of
Attorney’s Fees for filing in the above-referenced case.
Thank you for your attention to this matter.
Sincerely,
Paul J. Maravelias
CC: Simon R. Brown, Esq.
A199 A199
Docket No. 473-2017-CV-150
Paul Maravelias
v.
David DePamphilis
PLAINTIFF’S REPLY TO RESPONDENT’S BRIEF ON MOTION FOR AWARD OF

ATTORNEY’S FEES
Plaintiff Paul Maravelias respectfully submits the facts attested hereunder in response to
Respondent’s 3/27/18 filing with this Court entitled Respondent’s Reply to Petitioner’s
Objection to Motion for Award of Attorney’s Fees in the above-referenced case:
I. RESPONDENT DAVID DEPAMPHILIS HAS A HISTORY OF ATTEMPTED

MONETARY EXTORTION AGAINST PLAINTIFF BY MAKING FALISIFIED,
FRIVOLOUS MOTIONS TO THIS COURT
1. In his Objection to Respondent’s Motion for Award of Attorney’s Fees, the

Plaintiff/Petitioner asserted:
“[Respondent’s motion for award of attorney’s fees] is but a new manifestation of legal
harassment birthed from [DePamphilis’s] demonstrable history of falsification before this
Court to attempt to have Maravelias ordered to pay for random, undue expenses. Should it be
necessary, the Plaintiff Paul Maravelias shall submit documentation of DePamphilis’s said
past act of extortionary falsification against Maravelias, which was duly unsuccessful. This
known history underscores the bad-faith indeed of DePamphilis’s motion, which itself
wrongly claims bad-faith on the part of the Plaintiff.” (Emphasis added)
A200 A200
2. Given Respondent’s unreasonable and vexatious persistence in this new extortionary
attempt, the Plaintiff represents as follows to document DePamphilis’s past similar act of
falsification before this Court for undue ordered payment from Maravelias, showing a
course of conduct marked by bad-faith and vexatious hostility.
3. On 2/1/17, at the end of the stalking hearing held on the related case Christina DePamphilis
vs. Paul Maravelias (473-2016-CV-00124), the ruthless DePamphilis family motioned the
Court to order Maravelias to pay for DePamphilis’s recent home security measures, which
included including the installation of “security” “cameras” (Exhibit A).
4. The Court denied this motion, which was based upon an absurd insinuation that
Maravelias’s innocent conduct was the cause of these security measures. Maravelias’s prior
conduct at DePamphilis’s house in question had been to respectfully invite his daughter to
dinner; he never again contacted her after the romantic rejection, and there was never even
the slightest accusation of violent conduct on the behalf of the Plaintiff which would
motivate cautionary home security measures. In fact, David DePamphilis had even admitted
to the Court that Maravelias had compliantly acceded to DePamphilis’s verbal no-
trespassing order to him (Exhibit B). Rather, DePamphilis’s dramatic home security antics
were another bout of his delusional self-justification and cruel bullying against Maravelias.
5. David DePamphilis suborned his daughter Christina, by counsel, to criminally perjure
at the 2/17/17 Hearing about the true cause for the security camera installation:
6. Maravelias noted to the Court that there had actually been a valid security incident at the
DePamphilis home the prior October (2016) which DePamphilis knew did not involve him,
and that this in fact was the true basis for DePamphilis’s home security measures.
A201 A201
7. In response to Maravelias’s protest that ulterior and valid circumstances gave rise to the
security camera installation, presiding Justice Stephen denied DePamphilis’s motion for
forced monetary award from Maravelias, citing doubts about this different causal incident.
8. At this point, Christina DePamphilis, by attorney Jerome Blanchard, lied, that is, criminally
perjured, denying that this October 2016 incident had ever happened, with the following
words: “Yeah, well, there’s no evidence – we contest that.” (Exhibit A)1.
9. Maravelias knew about the incident in question, an intruder throwing “rocks” at
DePamphilis’s window at night, by Respondent’s wife’s own admission to the Maravelias
family through an SMS text message from December 2016.
10. In the above-referenced stalking case against DePamphilis, the Respondent himself
accidentally admitted the said text message in question, documenting the October 2016
incident and showing his family’s willful knowledge of it whilst denying it. (Exhibit C)
11. That this ulterior, valid October 2016 security incident at the DePamphilis home actually
happened is beyond question and is further documented by a social media post made by the
Respondent’s daughter Christina (Exhibit D), further proving the willful nature of her and
her father’s perjurious denial of said incident while asking for Court-ordered compensation
from Maravelias for the security camera installation falsely attributed to his acts.
12. Since the DePamphilis family has therefore willfully lied in the past in a failed attempt to
make Maravelias pay for home security measures under the absurd insinuation that his
innocent and honorable conduct was the cause thereof, when it was not, when they knew it
1
Nota bene: A scrivener’s error in the transcript wrongly misrepresents DePamphilis’s true words “we
contest that” as “we can attest to that”. For verification, the Court’s audio tape of the referenced 2/1/17
Hearing in 473-2016-CV-124 can be consulted; that the words were “we contest that” – a forceful denial
that there had been any ulterior security incident in October 2016 to motivate the same surveillance
cameras which DePamphilis was fraudulently trying to have Maravelias pay for – is indisputably clear in
the Court’s audio recording.
A202 A202
was not, and when they maliciously perjured about the true etiology of said measures to this
Court, therefore the Respondent’s present and renewed attempt at monetary extortion
should be denied and punitive measures against him imposed for his bad-faith falsification.
II. ARGUMENT IN REPLY
A. The Petitioner’s Stalking Petition against DePamphilis was thoroughly meritorious and
not brought in “bad faith”.
1. In Page 2 of his aforecited reply document, Respondent falsely claimed that the Petitioner
brought a Stalking Petition against him while Petitioner was “on bail for violating” the
falsified stalking order from the related case Christina DePamphilis vs. Paul Maravelias,
and that the Stalking Petition against DePamphilis was for “retaliation”.
2. In reality, the Plaintiff filed his Stalking Petition against DePamphilis on 12/8/17, which
was one week before DePamphilis’s criminally falsified yet extant order caused Maravelias
to be wrongly arrested on 12/15/17 on the false accusation that he had violated said order.
3. Respondent has full knowledge of the true order of these events, as this was scrutinized in
the Hearing against Respondent. Therefore, by mendaciously inverting the order of these
events, Respondent has again flaunted his shameless volition to lie willfully before this
Court in a baseless attempt to extort money out of the Plaintiff.
B. The Petitioner’s conduct at the Hearing did not whatsoever demonstrate any “bad
faith” of his Petition
4. On Page 4 of his aforecited reply document, Respondent maliciously quoted a statement
(“rumor of sexual violence”) which was never made by Maravelias in the said Hearing.
This appears to be a dishonest contortion of a cross-examination question Maravelias
proposed to DePamphilis concerning an incident which DePamphilis’s son Nicolas had
relayed to Maravelias’s brother Luke; to wit, that David DePamphilis had once exposed his
A203 A203
testicles to his son and joked about their visual semblance to “bubble gum”. This cross-
examination question was relevant since the topic of DePamphilis’s known pattern of
disregard for law was an element of Maravelias’s reasonable fear of him (vide RSA 645:1).
5. Respondent relies upon a social media posting the Plaintiff tried to introduce as further
support of the baseless accusation that Maravelias’s conduct represented bad-faith
motivations, falsely claiming that this evidence “was not permitted” by the Court.
6. Maravelias had actually attempted to introduce a pertinent and factual exhibit suggesting
DePamphilis approved of his daughter’s sexually licentious behaviors. This was indeed
accepted by the Court “for identification” purposes, even if not as a full evidentiary exhibit.
7. This became factually relevant when DePamphilis tried to excuse his hostile behaviors
against Maravelias on the grounds of being a protective father, when in fact Maravelias
never posed any sort of risk to his daughter, and when DePamphilis has not acted
“protective” in other parental contexts involving a college-age man penetrating his minor
daughter, in violation of the age of consent law imposed by said man’s legal residence in
the State of New York (vide “Sex offenses; lack of consent.” NY Penal Law § 130.05) 2.
8. The Petitioner’s intention was to indicate that Respondent David DePamphilis had openly
consented to his 16-year-old daughter Christina DePamphilis having a wild sexual
2
New York State Penal Law § 130.05 “Sex offenses; lack of consent”:
“1. Whether or not specifically stated, it is an element of every offense defined in this article that the
sexual act was committed without consent of the victim.
2. Lack of consent results from:
(a) Forcible compulsion; or
(b) Incapacity to consent; …
3. A person is deemed incapable of consent when he or she is:
(a) less than seventeen years old; or
(b) mentally disabled; or
(c) mentally incapacitated; or
(d) physically helpless;” (Emphasis added)
A204 A204
relationship with a 21-year-old man in 2017, said to be a “man whore” in a letter entered by
Respondent as evidence, as indicated by the social media post in question (Exhibit E).
DePamphilis’s approval of the said much-older boyfriend was pictured in his harassing and
vulgar social media post made against Maravelias in June 2017, wherein DePamphilis made
an obscene middle-finger gesture to Maravelias along with the said boyfriend in an
expression of solidarity therewith.
9. Therefore, the Petitioner’s exhibit demonstrating the sexual relationship between the man in
his 20s and DePamphilis’s barely 16-year-old daughter was highly relevant in this case to
contradict DePamphilis’s insinuation that his hostile stalking behaviors against Petitioner
were justified by his natural protectivism following from an older boy (Petitioner) making a
romantic advance to DePamphilis’s younger daughter – especially when Maravelias’s said
gesture to her had been entirely platonic, respectful, and non-sexual by comparison to the
womanizer boyfriend whom DePamphilis openly approved for his minor daughter.
10. The Respondent is therefore wrong to claim Petitioner submitted this evidence solely to
“embarrass” DePamphilis; it was factually relevant to Petitioner’s good-faith Petition.
C. The Petitioner’s allegations in his Stalking Petition against DePamphilis were factually
true and credible
11. If taken as an independent statement isolated from proper context, the Court’s finding that
“none” of the entered allegations had any “credibility” was plainly erroneous. Maravelias
produced irrefutable evidentiary artifacts of DePamphilis, among other intimidating acts,
bullying him on the internet on “6/21/17” and trying to find him the night of “3/21/17”. The
Respondent himself entered the referenced letter sent to Petitioner from “10/30/17”. Only
the extent or meaning of these acts was debated in light of the thresholds imposed by the
stalking statute; their veracity was fully established beyond any question of “credibility”.
A205 A205
12. The Court’s finding about “credibility” must be taken in contextual conjunction with its
immediately prior qualifying statement (which Respondent selectively omitted in his
original Motion) that the Petitioner “did not meet his burden of proof” for substantiating a
stalking “course of conduct” tantamount to creating “reasonable fear” (vide RSA 633:3-a).
13. Furthermore, the Court’s finding completely ignored the first and most essential factual
allegation of Petitioner’s Stalking Petition – Respondent’s profane telephonic harassment
and antagonism against the Maravelias family in December 2016 – which was amply
supported by the Petitioner’s testimony, the Petitioner’s father Theodore’s testimony, and,
in parts, the Respondent’s own confessions. Thus, the most significant factual allegation in
said Petition was clearly established as valid fact beyond any question of “credibility”.
14. This Court declining to issue a Stalking Order therefore does not translate into a finding
that Petitioner’s Petition was made in “bad faith” or solely for “vexatious” purposes.
15. On Page 2 of his aforecited reply brief, Respondent argues that Petitioner’s failure to fully
detail the evidence supporting DePamphilis’s act of vehicular stalking the night of 3/21/17
was a “willful misrepresentation of truth”. This is absurd, since the Petition’s claim on its
face was accurate, as conceded in the testimony of DePamphilis himself. Furthermore,
Petitioner openly detailed whence he obtained this information during his testimony during
the Hearing. There was nothing untruthful or misleading whatsoever about the
representations made in the Petitioner’s Petition.
16. Likewise, Petitioner’s declining to fully detail in his concise Petition the circumstances of
DePamphilis’s “persisted” contact in late 2017 in no way invalidates the truth of the same
claim in his Petition.
A206 A206
17. In the above two examples, Respondent’s counsel inconsistently defies his own argument
recently made in the related stalking case (473-2016-CV-124) that stalking hearings
functionally exist to explore the initial petition’s allegations in further detail; in this case,
the Petitioner made truthful claims which were later explored in further detail at the
Hearing.
18. The Petition’s stated fear of DePamphilis’s deadly weapon possession was in no way
“false” but in fact pointedly confirmed by Respondent’s testimony. That Respondent deems
this a “willful misrepresentation of truth” in his reply brief is a perjurious self-contradiction
of his own testimony delivered at the Hearing.
19. Respondent wrongly claims that the Petitioner asked him to “stop harassing [Petitioner]”
over SMS; this request was made in regard Petitioner’s parents. Respondent then
pointlessly notes that prior SMS communications with said parents had occurred before
Maravelias’s 12/23/16 ultimatum. Respondent willfully omits that the preceding consensual
communications (12/12/16 to 12/14/16) were merely the first stages in an escalation to
unwanted, repeated contact (after 12/14/16), which was clarified to DePamphilis over SMS
on 12/23/16. This supports the validity of Petitioner’s Petition, not the reverse.
D. The Petitioner’s statements and conduct before and during the Hearing are absolutely
consistent with his genuine fear of David DePamphilis and good-faith Stalking Petition
thereagainst
20. On Page 3 of his aforecited reply brief, Respondent cites a 11/2/17 email communication
from Petitioner to Respondent’s counsel as alleged indication of bad-faith in Maravelias’s
subsequent Stalking Petition. Respondent has dishonestly removed the cited quote from
proper context; as Petitioner testified, these comments were made in response to a
threatening letter made by DePamphilis warning of frivolous prosecution for recovery of
A207 A207
damages in civil court. Petitioner Maravelias’s quoted clarifications that he feels quite
confident to challenge any absurd and further legal abuse against him with counterclaims
for defamation (and other torts) against Respondent, his abuser, has absolutely nothing to
do with the personal-safety-oriented Stalking Petition made over a month thereafter.
21. Respondent has willfully omitted parts of this letter which in fact prove beyond question
that the Petitioner has indeed been fearful of Respondent David DePamphilis even long
before the meritorious Stalking Petition was filed against him, to wit:
“This petty act was anteceded by a vulgar internet post of harassment which David made
against me on his daughter’s social media, proffering forth his 48 year-old middle finger
against his college-student victim. This risible act of puerile instigation has evaporated any
lasting iota of adult empathy for David’s harmful acts against me”;
“I gave David a chance to end his criminal harassment and apologize, but he did not”; and
“I also demand that David receive professional psychological intervention for his manifest
mental disturbances. His conduct has been consistent with Persecutory-type Delusional
Disorder with Bizarre Content (DSM-V, 297.1 [F22]).” (Emphasis added)
These comments by Petitioner made over a month prior to his Stalking Petition are
absolutely consistent with his stated fear of David DePamphilis and, in the first case,
directly corroborate one of the primary factual allegations against DePamphilis in the said
Petition (i.e., his 6/21/17 act of obscene bullying against Maravelias over social media).
22. Likewise, as clarified during the Hearing, Petitioner’s former comments about “legal
retaliation” from a 2/1/17 hearing on the related case were made in reference to civil
prosecution to obtain monetary restitution for damages to him caused by DePamphilis’s
reckless criminal defamation that Maravelias has ever “stalked” his now-unattractive
daughter. To extend the scope of these comments to a personal-safety-oriented Stalking
Petition containing demonstrably true allegations is beyond erroneous.
A208 A208
23. On Page 4 of his aforecited reply brief, Respondent cites another email communication
from Respondent (1/5/18) as evidence against the good faith of Petitioner’s truthful
Petition. Respondent notes Petitioner’s declared confidence in his innocence, his natural
excitement to obtain a just outcome, and his assurance that the prospect of further legal
abuse against him would at least create opportunity to expose DePamphilis’s criminality
and falsification. To claim that these comments are not consistent with Petitioner’s claims
in his Stalking Petition is thoroughly absurd and utterly irrational; rather, quite to the
contrary, these comments underscore Petitioner’s confidence that DePamphilis is a
dangerous criminal who poses a threat against him.
24. Respondent willfully, selectively omitted other statements made by Petitioner in the said
communication which clearly document his good faith and fear of David DePamphilis:
“In December of 2016, your client David DePamphilis had a sociopathic meltdown of hostility
and verbal harassment against my family”;
“David has in fact stalked and abused me”; and
“I strongly recommend that the true stalker David focus on taking responsibility for his own
outrageous acts of intimidation or imagining some way to excuse them, rather than pour more
fire onto a raging conflagration of injustice, perjury, and interpersonal terrorism against me for
no sane reason whatsoever.”
These comments by Petitioner in said communication therefore amply corroborate the
validity of his meritorious Stalking Petition and are in no way inconsistent therewith.
III. CONCLUSION
25. It is DePamphilis who has behaved inconsistently with a man supposedly “in fear” of a
falsely alleged “stalker” when, inter alia, in 2017 he bullied Maravelias with obscene,
provocative middle-finger gestures on the Internet after winning a fraudulent Stalking
Order against him, the result of a falsified Stalking Petition made solely to attack
10
A209 A209
Maravelias’s reputation, proving DePamphilis’s absolute lack of “fear” and criminal abuse
of proper legal process. Respondent’s ironic accusation that Maravelias has done the same
against him is but a projective outlet for his own guilt from committing the same exact
crime; this cognitive dissonance phenomenon is widely noted in clinical psychology.
26. The Respondent’s Motion demonstrates his continued passion for antagonistic harassment
against the Petitioner while lacking any genuine cause whatsoever. Petitioner’s Stalking
Petition against DePamphilis was the product of valid fear buttressed by numerous factual
occurrences and digital artifacts, many of which DePamphilis did not even dispute during
the Hearing. For this reason, this Court declined to dismiss the Petition on two occasions: 1)
at the original filing of Petitioner’s Stalking Petition, and 2) when Respondent originally so
motioned at the conclusion of Petitioner’s testimony during the 2/15/18 Hearing. Thus,
Respondent’s subsequent Motion to recover fees has no legal merit whatsoever.
27. The Respondent’s herein Motion for Attorney’s Fees and his continued legal harassment
against Maravelias in the related case constitute “oppressive, vexatious, arbitrary,
capricious [and] bad faith conduct”. As a result, Petitioner Maravelias has been forced to
litigate against an opponent whose position was patently unreasonable. Mr. Maravelias has
incurred substantial legal and non-legal costs due to DePamphilis’s abuse of process for
which DePamphilis should be ordered to pay as the result of a civil complaint filed in
Superior Court. Nonetheless, it is not the role of the District/Family Court to arbitrate civil
damage claims transpired from falsified Stalking Petitions such as the one DePamphilis
filed against Maravelias on 12/28/16.
11
A210 A210
THEREFORE, the reasons enumerated hereinabove compel the Plaintiff Paul Maravelias to pray
this Honorable Court:
I. Deny Respondent’s Motion for Award of Attorney’s Fees;
II. Issue an Order finding that David DePamphilis and his daughter Christina have
formerly engaged in willful falsification of fact in a failed attempt to extort Court-
ordered payment from Maravelias, as irrefutably documented herewith; and
III. Hold the Respondent David DePamphilis, a 49-year-old Executive Vice President and
Chief Operating Officer at NFS Leasing, Inc., in Contempt of Court for willfully
misrepresenting material facts for the purpose of wrongful Court-ordered monetary
extortion of Maravelias, an unmarried 22-year-old software programmer presently
domiciled at his family’s home.
PAUL J. MARAVELIAS,
in propria persona
April 13th, 2018 __________________________________
12
A211 A211
Exhibit A
Transcript excerpt (pg. 204-209) from related case (473-2016-CV-124)
A212 A212
A213 A213
A214 A214
A215 A215
A216 A216
A217 A217
Exhibit B
Transcript excerpt (pg. 40-41) of David DePamphilis testimony from related case (473-2016-
CV-124)
A218 A218
Exhibit C
Excerpt from DePamphilis’s own exhibit showing admission and knowledge of the prior October
2016 security incident (SMS text message conversation between DePamphilis, wife, and
Maravelias’s parents)
A219 A219
Exhibit D
Social media post from Christina DePamphilis’s Instagram account (named “tipsytina69”)
further documenting said October 2016 security incident which she later perjuriously denied.
A220 A220
Exhibit E
Petitioner’s evidentiary exhibit from Hearing, demonstrating the sexual nature of the relationship DePamphilis
approved for his underage 16-year-old daughter, which was accepted by the Court “for identification” and
which Respondent falsely claims was irrelevant and therefore indicative of bad faith (second post was included
for positive identification purposes).
A221 A221
A222 A222
TEXT OF RELEVANT AUTHORITIES
New Hampshire Revised Statutes Annotated (RSA)

633:3-a Stalking. –
I. A person commits the offense of stalking if such person:
(a) Purposely, knowingly, or recklessly engages in a course of conduct targeted at a specific
person which would cause a reasonable person to fear for his or her personal safety or the safety
of a member of that person's immediate family, and the person is actually placed in such fear;
(b) Purposely or knowingly engages in a course of conduct targeted at a specific individual,
which the actor knows will place that individual in fear for his or her personal safety or the safety
of a member of that individual's immediate family; or
(c) After being served with, or otherwise provided notice of, a protective order pursuant to RSA
173-B, RSA 458:16, or paragraph III-a of this section, or an order pursuant to RSA 597:2 that
prohibits contact with a specific individual, purposely, knowingly, or recklessly engages in a
single act of conduct that both violates the provisions of the order and is listed in paragraph II(a).
II. As used in this section:
(a) "Course of conduct" means 2 or more acts over a period of time, however short, which
evidences a continuity of purpose. A course of conduct shall not include constitutionally
protected activity, nor shall it include conduct that was necessary to accomplish a legitimate
purpose independent of making contact with the targeted person. A course of conduct may
include, but not be limited to, any of the following acts or a combination thereof:
(1) Threatening the safety of the targeted person or an immediate family member.
(2) Following, approaching, or confronting that person, or a member of that person's immediate
family.
(3) Appearing in close proximity to, or entering the person's residence, place of employment,
school, or other place where the person can be found, or the residence, place of employment or
school of a member of that person's immediate family.
(4) Causing damage to the person's residence or property or that of a member of the person's
immediate family.
(5) Placing an object on the person's property, either directly or through a third person, or that of
an immediate family member.
(6) Causing injury to that person's pet, or to a pet belonging to a member of that person's
immediate family.
(7) Any act of communication, as defined in RSA 644:4, II.
A223 A223
(b) "Immediate family" means father, mother, stepparent, child, stepchild, sibling, spouse, or
grandparent of the targeted person, any person residing in the household of the targeted person,
or any person involved in an intimate relationship with the targeted person.
III. [Repealed.]
III-a. A person who has been the victim of stalking as defined in this section may seek relief by
filing a civil petition in the district court in the district where the plaintiff or defendant resides.
Upon a showing of stalking by a preponderance of the evidence, the court shall grant such relief
as is necessary to bring about a cessation of stalking. The types of relief that may be granted, the
procedures and burdens of proof to be applied in such proceedings, the methods of notice,
service, and enforcement of such orders, and the penalties for violation thereof shall be the same
as those set forth in RSA 173-B.
III-b. The minority of a plaintiff or defendant shall not preclude the court from issuing protective
orders under this section.
III-c. Any order under this section shall be for a fixed period of time not to exceed one year, but
may be extended by order of the court upon a motion by the plaintiff, showing good cause, with
notice to the defendant, for one year after the expiration of the first order and thereafter each
extension may be for up to 5 years, upon the request of the plaintiff and at the discretion of the
court. The court shall review the order, and each renewal thereof and shall grant such relief as
may be necessary to provide for the safety and well-being of the plaintiff. A defendant shall have
the right to a hearing on the extension of any order under this paragraph to be held within 30
days of the extension. The court shall state in writing, at the respondent's request, its reason or
reasons for granting the extension. The court shall retain jurisdiction to enforce and collect the
financial support obligation which accrued prior to the expiration of the protective order.
III-d. (a) A protective order issued pursuant to this section, RSA 173-B:4, or RSA 173-B:5 shall
not be construed to prohibit an attorney, or any person acting on the attorney's behalf, who is
representing the defendant in an action brought under this chapter, or in any criminal proceeding
concerning the abuse alleged under this chapter, from contacting the plaintiff for a legitimate
purpose within the scope of the civil or criminal proceeding; provided, that the attorney or person
acting on behalf of the attorney: identifies himself or herself as a representative of the defendant;
acknowledges the existence of the protective order and informs the plaintiff that he or she has no
obligation to speak; terminates contact with the plaintiff if the plaintiff expresses an
unwillingness to talk; and ensures that any personal contact with the plaintiff occurs outside of
the defendant's presence, unless the court has modified the protective order to permit such
contact.
(b) A no-contact provision in a protective order issued pursuant to this section shall not be
construed to:
(1) Prevent contact between counsel for represented parties; or
(2) Prevent a party from appearing at a scheduled court or administrative hearing; or
A224 A224
(3) Prevent a defendant or defendant's counsel from sending the plaintiff copies of any legal
pleadings filed in court relating to the domestic violence petition or related civil or criminal
matters.
(c) A violation of this paragraph may result in a finding of contempt of court.
IV. In any complaint, information, or indictment brought for the enforcement of any provision of
this statute, it shall not be necessary to negate any exception, excuse, proviso, or exemption
contained herein and the burden of proof of any exception, excuse, proviso, or exemption shall
be upon the defendant.
V. Any law enforcement officer may arrest, without a warrant, any person that the officer has
probable cause to believe has violated the provisions of this section when the offense occurred
within 12 hours, regardless of whether the crime occurred in the presence of the officer. A law
enforcement officer shall arrest a person when he has probable cause to believe a violation of the
provisions of this section has occurred within the last 12 hours when the offense involves a
violation of a protective order issued pursuant to RSA 173-B, RSA 458:16, or paragraph III-a of
this section.
VI. (a) Any person convicted of a violation of this section and who has one or more prior
stalking convictions in this state or another state when the second or subsequent offense occurs
within 7 years following the date of the first or prior offense shall be guilty of a class B felony.
(b) In all other cases, any person who is convicted of a violation of this section shall be guilty of
a class A misdemeanor.
VII. If any provision or application of this section or the application thereof to a person or
circumstance is held invalid, the invalidity does not affect other provisions or applications of this
section which can be given effect without the invalid provisions or applications, and to this end
the provisions of this section are severable.
VIII. (a) Upon proof that the victim and defendant were intimate partners or family or household
members, as those terms are defined in RSA 631:2-b, III, a conviction under this section shall be
recorded as "stalking-domestic violence."
(b) In addition to any other penalty authorized by law, the court shall levy a fine of $50 for each
conviction recorded as "stalking-domestic violence" under this paragraph. The court shall not
reduce or suspend any sentence or the payment of any fine imposed under this paragraph and no
fine imposed under this paragraph shall be subject to an additional penalty assessment. If the
court determines that the defendant is unable to pay the fine on the date imposed, the court may
defer payment or order periodic payments thereof. The clerk shall forward all fines collected
under this paragraph to the department of health and human services for the purposes of RSA
173-B:15. The provisions of RSA 618:8 and RSA 618:9 shall not apply to a fine imposed under
this paragraph.
A225 A225
173-B:3 Commencement of Proceedings; Hearing. –
I. Any person may seek relief pursuant to RSA 173-B:5 by filing a petition, in the county or
district where the plaintiff or defendant resides, alleging abuse by the defendant. Any person
filing a petition containing false allegations of abuse shall be subject to criminal penalties. Notice
of the pendency of the action and of the facts alleged against the defendant shall be given to the
defendant, either personally or as provided in paragraph III. The plaintiff shall be permitted to
supplement or amend the petition only if the defendant is provided an opportunity prior to the
hearing to respond to the supplemental or amended petition. All petitions filed under this section
shall include the home and work telephone numbers of the defendant, if known. Notice of the
whereabouts of the plaintiff shall not be revealed except by order of the court for good cause
shown. Any answer by the defendant shall be filed with the court and a copy shall be provided to
the plaintiff by the court.
II. (a) The minority of the plaintiff shall not preclude the court from issuing protective orders
against a present or former intimate partner, spouse, or ex-spouse under this chapter.
(b) A minor plaintiff need not be accompanied by a parent or guardian to receive relief or
services under this chapter.
III. No filing fee or fee for service of process shall be charged for a petition or response under
this section, and the plaintiff or defendant may proceed without legal counsel. Either a peace
officer or the sheriff's department shall serve process under this section. Any proceeding under
this chapter shall not preclude any other available civil or criminal remedy.
IV. The clerks of the circuit courts shall supply forms for petitions and for relief under this
chapter designed to facilitate pro se proceedings. All such petitions shall contain the following
words: I swear that the foregoing information is true and correct to the best of my knowledge. I
understand that making a false statement on this petition will subject me to criminal penalties.
V. [Repealed.]
VI. The findings of facts shall be final, but questions of law may be transferred from the circuit
court to the supreme court.
VII. (a) The court shall hold a hearing within 30 days of the filing of a petition under this section
or within 10 days of service of process upon the defendant, whichever occurs later.
(b) The time frame established in this paragraph may be extended for an additional 10 days upon
motion by either party for good cause shown. A recusal by the judge or any act of God or closing
of the court that interferes with the originally scheduled hearing shall not be cause for the
dismissal of the petition. The court shall reschedule any hearing under this section in an
expeditious manner.
VIII. In any proceeding under this chapter, the court shall not be bound by the technical rules of
evidence and may admit evidence which it considers relevant and material.
A226 A226
641:5 Tampering With Witnesses and Informants. –
A person is guilty of a class B felony if:
I. Believing that an official proceeding, as defined in RSA 641:1, II, or investigation is pending
or about to be instituted, he attempts to induce or otherwise cause a person to:
(a) Testify or inform falsely; or
(b) Withhold any testimony, information, document or thing; or
(c) Elude legal process summoning him to provide evidence; or
(d) Absent himself from any proceeding or investigation to which he has been summoned; or
II. He commits any unlawful act in retaliation for anything done by another in his capacity as
witness or informant; or
III. He solicits, accepts or agrees to accept any benefit in consideration of his doing any of the
things specified in paragraph I.
General Laws of Massachusetts

Part IV, Chapter 265, Section 43(a): Stalking; punishment
Whoever (1) willfully and maliciously engages in a knowing pattern of conduct or series of acts
over a period of time directed at a specific person which seriously alarms or annoys that person
and would cause a reasonable person to suffer substantial emotional distress, and (2) makes a
threat with the intent to place the person in imminent fear of death or bodily injury, shall be
guilty of the crime of stalking and shall be punished by imprisonment in the state prison for not
more than 5 years or by a fine of not more than $1,000, or imprisonment in the house of
correction for not more than 21/2 years or by both such fine and imprisonment. The conduct, acts
or threats described in this subsection shall include, but not be limited to, conduct, acts or threats
conducted by mail or by use of a telephonic or telecommunication device or electronic
communication device including, but not limited to, any device that transfers signs, signals,
writing, images, sounds, data, or intelligence of any nature transmitted in whole or in part by a
wire, radio, electromagnetic, photo-electronic or photo-optical system, including, but not limited
to, electronic mail, internet communications, instant messages or facsimile communications.
Part III, Title IV, Chapter 258E, Section 3: Filing of complaint; impounding of case record
information; filing fee; expiration of order; modification of order; time for filing;
nonexclusivity of remedy
(a) A person suffering from harassment may file a complaint in the appropriate court requesting
protection from such harassment. A person may petition the court under this chapter for an order
that the defendant:
(i) refrain from abusing or harassing the plaintiff, whether the defendant is an adult or minor;
A227 A227
(ii) refrain from contacting the plaintiff, unless authorized by the court, whether the defendant is
an adult or minor;
(iii) remain away from the plaintiff's household or workplace, whether the defendant is an adult
or minor; and
(iv) pay the plaintiff monetary compensation for the losses suffered as a direct result of the
harassment; provided, however, that compensatory damages shall include, but shall not be
limited to, loss of earnings, out-of-pocket losses for injuries sustained or property damaged, cost
of replacement of locks, medical expenses, cost for obtaining an unlisted phone number and
reasonable attorney's fees.
(b) The court may order that information in the case record be impounded in accordance with
court rule.
(c) No filing fee shall be charged for the filing of the complaint. The plaintiff shall not be
charged for certified copies of any orders entered by the court, or any copies of the file
reasonably required for future court action or as a result of the loss or destruction of plaintiff's
copies.
(d) Any relief granted by the court shall not extend for a period exceeding 1 year. Every order
shall, on its face, state the time and date the order is to expire and shall include the date and time
that the matter will again be heard. If the plaintiff appears at the court at the date and time the
order is to expire, the court shall determine whether or not to extend the order for any additional
time reasonably necessary to protect the plaintiff or to enter a permanent order. When the
expiration date stated on the order is on a date when the court is closed to business, the order
shall not expire until the next date that the court is open to business. The plaintiff may appear on
such next court business day at the time designated by the order to request that the order be
extended. The court may also extend the order upon motion of the plaintiff, for such additional
time as it deems necessary to protect the plaintiff from harassment. The fact that harassment has
not occurred during the pendency of an order shall not, in itself, constitute sufficient ground for
denying or failing to extend the order, or allowing an order to expire or be vacated or for refusing
to issue a new order.
(e) The court may modify its order at any subsequent time upon motion by either party;
provided, however, that the non-moving party shall receive sufficient notice and opportunity to
be heard on said modification. When the plaintiff's address is inaccessible to the defendant as
provided in section 10 and the defendant has filed a motion to modify the court's order, the court
shall be responsible for notifying the plaintiff. In no event shall the court disclose any such
inaccessible address.
(f) The court shall not deny any complaint filed under this chapter solely because it was not filed
within a particular time period after the last alleged incident of harassment.
(g) An action commenced under this chapter shall not preclude any other civil or criminal
remedies. A party filing a complaint under this chapter shall be required to disclose any prior or
A228 A228
pending actions involving the parties; including, but not limited to, court actions, administrative
proceedings and disciplinary proceedings.
Rules of the Circuit Court of the State of New Hampshire – District Division
GENERAL RULES
Rule 1.4. Photographing, Recording and Broadcasting
(a) Except as otherwise provided by this rule or by other provisions of law, any person, whether
or not a member of an established media organization, shall be permitted to photograph, record
and broadcast all court proceedings that are open to the public, provided that such person
provides advance notice to the presiding justice in accordance with section (c) of this rule that he
or she intends to do so. No person shall photograph, record or broadcast any court proceeding
without providing advance notice to the presiding justice that he or she intends to do so. In
addition to giving any parties in interest an opportunity to object, the purpose of the notice
requirement is to allow the presiding justice to ensure that the photographing, recording or
broadcasting will not be disruptive to the proceedings and will not be conducted in such a
manner or using such equipment as to violate the provisions of this rule.
(b) Official court reporters, court monitors and other persons employed or engaged by the court
to make the official record of any court proceeding may record such proceeding by video and/or
audio means without compliance with the notice provisions of section (a) of this rule.
(c) Any person desiring to photograph, record or broadcast any court proceeding, or to bring
equipment intended to be used for these purposes into a courtroom, shall submit a written request
to the clerk of the court or his or her designee, who, in turn, shall deliver the request to the
presiding justice before commencement of the proceeding, or, if the proceeding has already
commenced, at the first reasonable opportunity during the proceeding, so the justice before
commencement of the proceeding, or at an appropriate time during the proceeding, may give all
interested parties a reasonable opportunity to be heard on the request.
(d) Any party to a court proceeding or other interested person who has reason to believe that a
request to photograph, record or broadcast a court proceeding will be made and who desires to
place limitations beyond that specified by this rule upon these activities may file a written
motion seeking such relief. The motion shall be filed as far in advance of the proceeding as is
practicable. Upon the filing of such a motion, the court may schedule a hearing as expeditiously
as possible before the commencement of the proceeding and, if a hearing is scheduled, the court
shall provide as much notice of the hearing as is reasonably possible to all interested parties and
to the Associated Press, which shall disseminate the notice to its members.
(e) No court or justice shall establish notice rules, requirements or procedures that are different
than those established by this rule.
A229 A229
(f) At any hearing conducted pursuant to subsections (c) or (d) of this rule, the party or person
seeking to prohibit or impose restrictions beyond the terms of this rule on the photographing,
recording or broadcasting of a court proceeding that is open to the public shall bear the burden of
demonstrating: (1) that the relief sought advances an overriding public interest that is likely to be
prejudiced if the relief is not granted; (2) that the relief sought is no broader than necessary to
protect that interest; and (3) that no reasonable less restrictive alternatives are available to protect
the interest. Any order prohibiting or imposing restrictions beyond the terms of this rule upon
the photographing, recording or broadcasting of a court proceeding that is open to the public
shall be supported by particularized findings of fact that demonstrate the necessity of the court’s
action.
(g) The presiding justice retains discretion to limit the number of cameras, recording devices and
related equipment allowed in the courtroom at one time. In imposing such limitations, the
presiding justice may give preference to requests to photograph, record or broadcast made by a
representative of an established media organization that disseminates information concerning
court proceedings to the public. The presiding justice also may require representatives of the
media to arrange pool coverage.
(h) It is the responsibility of representatives of media organizations desiring to photograph,
record or broadcast a court proceeding to contact the clerk of court in advance of a proceeding to
ascertain if pool coverage will be required. If the presiding justice has determined that pool
coverage will be required, it is the sole responsibility of such media representatives, with
assistance as needed from the clerk or his or her designee, to determine which media
organization will provide the coverage feed. Disputes about pool coverage will not ordinarily be
resolved by the court, and the court may deny media organizations’ requests to photograph,
record or broadcast a proceeding if pool agreements cannot be reached. It also is the
responsibility of said person to make arrangements with the clerk of court or his or her designee
sufficiently in advance of the proceeding so that the set up of any needed equipment in the
courtroom, including equipment for pool coverage, can be completed without delaying the
proceeding. The court shall allow reasonable time prior to a proceeding for the set up of such
equipment.
(i) The court shall make all documents and exhibits filed with the court, and not sealed,
available for inspection by members of the public in a reasonably timely fashion, it being
recognized that the court’s need to make use of documents and exhibits for official purposes
must take precedence over their availability for public inspection. The court may elect to make
one “public” copy of an exhibit available in the clerk’s office.
(j) The exact location of all recording, photographing and broadcasting equipment within the
courtroom shall be determined by the presiding justice. Once established, movement of such
equipment within the courtroom is prohibited without the express prior approval of the presiding
justice. The court may prohibit the use of any equipment which requires the laying of cords or
wires that pose a safety hazard or impair easy ingress and egress from the courtroom. All
equipment used must operate with minimal noise so as not to disrupt the proceedings.
A230 A230
(k) Unless otherwise ordered by the presiding justice, the following standing orders shall apply
to all recording, photographing or broadcasting of proceedings within any courtroom:
(1) No flash or other artificial lighting devices shall be used.
(2) Set up and dismantling of equipment in a disruptive manner while court is in session is
prohibited.
(3) No recording, photographing or broadcasting equipment may be moved into, out of, or
within the courtroom while court is in session.
(4) Recording, photographing or broadcasting equipment must remain a reasonable distance
from the parties, counsel tables, alleged victims and their families and witnesses, unless such
person(s) voluntarily approach the position where such equipment is located. No such
equipment shall be used or set up in a location that creates a risk of picking up confidential
communications between lawyer and client or conferences held at the bench among the presiding
justice and counsel or the parties.
(5) All persons using recording, photographing or broadcasting equipment must abide by the
directions of court officers at all times.
(6) Interviews within the courtroom are not permitted before or after a proceeding.
(7) A person who has been granted permission to record, photograph or broadcast a court
proceeding shall not engage in any activity that distracts the participants or impairs the dignity of
the proceedings.
A231 A231

Paul Maravelias&#39;s Pro Se 2018 Appeal Brief (Christina DePamphilis v. Paul Maravelias, 2018-0483)

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Paul Maravelias&#39;s Pro Se 2018 Appeal Brief (Christina DePamphilis v. Paul Maravelias, 2018-0483)

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THE STATE OF NEW HAMPSHIRE

Case No. 2018-0483

RULE 7 MANDATORY APPEAL OF STALKING FINAL ORDER

TABLE OF AUTHORITIES .................................................................. 6

I. RSA 633:3-A, III-C. IS UNCONSTITUTIONAL

A. The “Safety and Well-Being” Language of 633:3-a, III-

i. The Statute Regulates and Burdens Protected Speech

1. Maravelias’s 12/10/17 Email to Mrs. Smith is

2. Maravelias’s 11/2/2017 Response to Attorney

3. The March 2017 Nasty Letter to David

ii. The Statute Triggers Strict Scrutiny......................... 35

3. Forum Analysis .................................................... 37

iii. The Statute Fails Even Intermediate Scrutiny ........ 38

2. The Governmental Interest Served is not

3. Alternative Channels ............................................ 43

B. The “Safety and Well-Being” Language of 633:3-a, III-

i. Semantic Vagueness .................................................. 43

ii. Syntactic Vagueness................................................. 44

II. WHERE CHRISTINA DEPAMPHILIS

III. THE TRIAL COURT COMMITTED AN

A. Good Cause for Stalking Order Extension was Not

IV. THE TRIAL COURT VIOLATED MARAVELIAS’S

A. Reversal is the Necessary Remedy to the Trial Court’s

B. The Trial Court Illegally Limited Defendant’s

C. The Trial Court Violated the Statutory Advance Notice

i. “Obsession” and the 6/8/18 Surprise-Photographs-

ii. Ignored Motion to Dismiss ...................................... 53

V. JOHN J. COUGHLIN, THE TRIAL COURT JUDGE,

VI. THE TRIAL COURT ERRED IN GRANTING

A.The Trial Court Transgressed Constitutional Rights and

STATE OF NEW HAMPSHIRE

Appeal of Martino, 138 N.H. 612 (1994) .................................................... 52

O'Brien v. Borowski, 461 Mass. 415 (2012) ............................................... 37

UNITED STATES OF AMERICA

American Legion Post 7 of Durham, N.C. v. City of Durham, 239 F.3d

First Amendment to the Federal Constitution ........................... 32, 33, 34, 36

M.G.L. 258E §3(d) ...................................................................................... 45

New Hampshire Rules of the Circuit Court - District Division

Circuit Court Rule 1.4 ................................................................................. 52

Newberg and Waldman, 2012

RSA 633:3-a ......................................................................... A223

New Hampshire Court Rules

Circuit Court Rule 1.4 .......................................................... A229

1. Is RSA 633:3-a, III-c. constitutional?

3. Did the trial court commit an unsustainable exercise of discretion

4. Did the trial court violate Respondent’s procedural and/or

5. Did Judge John J. Coughlin commit a rampant pre-retirement spree

(A45,51,115-126); Plain-error; Supreme Court Justices as

DePamphilis’s December 2016 Delusions

Tyrant I: Robert S. Stephen

The Censored Exculpatory Audio Recording

The First Arrest

The Futile Appeal

The Second Arrest

They threw Maravelias in jail, purposely on a Friday night. Maravelias

Tyrant II: John J. Coughlin

Coughlin’s Career-Capstone Summer 2018 Orders against Maravelias

This appeal follows.

David DePamphilis begat a daughter in 2000: Christina DePamphilis

Paul Maravelias (“Defendant-Appellant”) is a 23-year-old author and

Social Pretext to December 2016

The December 2016 Origin of the Stalking Petition

Nor does Maravelias re-explain the history of David DePamphilis’s

The undeniable fact is Paul Maravelias had a normal family friends

Foolhardy Falsity: The Original Stalking Petition

Appellant bores-not this Court by reviewing similar defamatory drivel

Judge Robert S. Stephen Slanders Maravelias a “Stalker”

Paul Maravelias's Pro Se 2018 Appeal Brief (Christina DePamphilis v. Paul Maravelias, 2018-0483)

Paul Maravelias's Pro Se 2018 Appeal Brief (Christina DePamphilis v. Paul Maravelias, 2018-0483)