2019 Federal Lawsuit Against Criminal NH Supreme Court Justices For Their Fraudulent Extortion of Paul Maravelias (2019-CV-00487-JL)

Case 1:19-cv-00487-JL Document 1 Filed 05/06/19 Page 1 of 29
1 PAUL J. MARAVELIAS,/?ro
34 Mockingbird Hill Rd
2 Windham, NH 03087 ,
Telephone:(603)475-3305 t fi. :
3
Email: paul@paulmarv.com
4 2019 MAY-b A 10: 31
UNITED STATES DISTRICT COURT
5 FOR THE DISTRICT OF NEW HAMPSHIRE
7 PAUL MARAVELIAS, Civil No.

a natural person,
8
Date Action Filed: 5/6/19
Plaintiff,
9
V.
10
11 SUPREME COURT OF
NEW HAMPSHIRE, COMPLAINT
12 a governmental entity in the State of New
Hampshire,
13
ROBERT J. LYNN,
14
a natural person, in his individual and ORIGINAL VERIFIED
15 official capacities as Chief Justice ofthe COMPLAINT FOR

Supreme Court of New Hampshire, EQUITABLE RELIEF AND
16
COMPENSATORY DAMAGES
Defendants.
17
18
PRELIMINARY STATEMENT
19
20 1. NOW COMES Paul Maravelias ("Plaintiff) with Complaint and seeks redress
21 for Defendants' extortionate floccinaucinihilipilification of a citizen's basic civil right to file

22
an appeal in New Hampshire's only appellate court. Defendants have promulgated their
23
unconstitutional "Supreme Court Rule 23" and fraudulently usurped it as an unlawful excuse
24
to command pro se 23-year-old Maravelias to pay $4,900.00 to a prevailing party-simply for
25
bringing an appeal, Maravelias's first appearance ever in the NH Supreme Court. Despite
26
27 accepting, hearing, and adjudicating said appeal on its full merits in 2018, Defendants now
28 target Maravelias in a bad-faith campaign ofretaliatory harassment and intimidation, newly
implying - without specifically finding-that the appeal had been "frivolous or in bad faith".
ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

RELIEF AND COMPENSATORY DAMAGES -1- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1 2. This is a civil rights action brought under 42 U.S.C. §1983 and federal question
2 jurisdiction to redress Defendants' specific conduct and challenge the generic constitutionality
of N.H. Sup. Ct. R. 23. Defendants underhandedly conspired with Maravelias's rich 50-year-
old lawyer-represented opponent in the appeal to commandeer a limited request for attorney's
fees(in connection with one single motion)and furtively twist the said into a coercive
bludgeon forcing Maravelias to pay his opponent's whole bill for the entire litigation.
8 Defendants are weaponizing "Rule 23" as an indiscriminate vessel of oppressive pecuniary
^ chastisement in wanton nonobservance of Maravelias's constitutional due process rights.

10
3. Maravelias initiated the appeal to Defendants when a local NH judge made-up
11
^2 and cited a non-existent case to award fees and costs against Maravelias, including an
13 erroneously itemized expense the opponent had incurred months-before Maravelias initiated
the underlving action. The local judge subsequently scribbled "denied" on Maravelias's
motion to reconsider, refusing to correct the plain accounting error. Defendants now dare to
16
claim Maravelias filing an appeal in such circumstances was "frivolous" and are baselessly
17
extorting him $4,900.00 to punish his mere attempt to not be extorted in the first place.
18
19 4. Defendants' acts are a retaliation against Maravelias for his public critical
20
speech about them. Defendants' conduct is without any statutory authority and in shocking
21
excess of appellate jurisdiction. Acting in an enforcement capacity. Defendants now credibly
22
threaten to imprison impecunious Maravelias unless he surrenders $4,900.00 of his besieged
24 monetary property in capitulation to Defendants' arbitrary, non-judicial, legislative diktats.
25 JURISDICTION AND VENUE

26 .. . .
5. This action anses under 42 U.S.C. § 1983 and the United States Constitution.
27
Subject matter jurisdiction exists pursuant to 28 U.S.C. §§ 1331 and 1343 in that the instant
28
case arises under questions offederal constitutional law.
ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE paUL MARAVELIAS

RELIEF AND COMPENSATORY DAMAGES - 2- 34 MOCiCiNGBIRD HILL RD WINDHAM, NH 03087
1 6. This Court has supplemental jurisdiction over Plaintiffs state law claims
2 pursuant to 28 U.S.C. § 1367(a). Personal jurisdiction exists whereas all parties are entities or
natural citizens within the federal boundaries ofthe United States of America.
7. Claims herein for injunctive relief are authorized pursuant to 28 U.S.C. § 1343
6 and Rule 65 of the Federal Rules of Civil Procedure. Claims herein for declaratory relief are
7 authorized pursuant to the Declaratory Judgment Act, 28 U.S.C. §§ 2201-02.

8
8. Venue is appropriate per 28 U.S.C. § 1391 as Defendants' material conduct has
9
been and is occurring within the State ofNew Hampshire, where all individual parties reside.
10
11 PARTIES
12
9. PlaintiffPAUL MARAVELIAS is a natural person residing in the Town of
13
Windham in the State of New Hampshire. He is a 23-year-old Dartmouth College graduate in
14
Economics currently employed as a software engineer. He resides with his parents and sister
15
at 34 Mockingbird Hill Road, Windham, NH 03087.
10. Defendant SUPREME COURT OF NEW HAMPSHIRE is a governmental

18
entity in the State of New Hampshire authorized by Pt. II, Art. 73-a. ofthe N.H. Constitution.
19
It exists at One Charles Doe Drive, Concord, NH 03301. Its officers, agents, and employees
20
2j were acting and continue to act under color ofstate law at all material times.
11. Defendant ROBERT J. LYNN is the Chief Justice of the Supreme Court of New
23
Hampshire and a resident ofthe Town of Windham in the State of New Hampshire. He was
24
and is acting under color of state law at all material times. His address is One Charles Doe
25
Drive, Concord, NH 03301. Pursuant to Pt. II, Art. 73-a. of the N.H. Constitution, he
26
27 "make[s] rules governing the ... practice and procedure to be followed in all [state] courts",
28 rules which "have the force and effect oflaw". He is the administrative head of all New
Hampshire courts and has a duty to obey and ensure his subordinates obey the laws and
ORIGINAL VERIRED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

RELIEF AND COMPENSATORY DAMAGES -3- 34 MOCKINGBIRD HILL RD WINDHAM,NH 03087
1 Constitution of the United States of America. Defendant ROBERT J. LYNN is being sued in
2 his individual and official capacities.
FACTUAL ALLEGATIONS
5 Background of the Case: Maravelias Rightfully Files a Necessary Protective Order

Petition on 12/8/2017 Against David DePamphilis in NH State Courts
12. On 12/8/17, Maravelias filed a Stalking Petition against David DePamphilis in

7
g Salem Circuit Court seeking a no-contact prohibition for one year. Hundreds or thousands of
9 such petitions are filed every year. Many ofthem are totally fnvolous and should never be
^^ filed. Maravelias went above-and-beyond by ensuring his meritorious petition's allegations

11
were not only painstakingly accurate, but also factually provable by evidence.
12 ■■
j3 13. Salem Circuit Court accepted the Stalking Petition and scheduled it for a hearing
14 after a same-day judicial inspection thereof. By contrast, fnvolous stalking petitions are
^^ denied on-the-spot in said preliminary judicial review and never scheduled for hearing.
16
14. David DePamphilis is an affluent 50-year-old Executive Vice President(VP)
17
jg and Chief Operating Officer(COO)at a multinational leasing company, NFS Leasing, Inc.
19 Paul Maravelias was an unmarried 22-year-old software programmer living with his family.
20
15. Maravelias's restraining order petition alleged DePamphilis had made
21
threatening phone calls "screaming like a madman" to Maravelias and his father Theodore in
22
23 December 2016. The petition alleged DePamphilis used his daughter's social media to make
24 public cyberbullying posts directed to Maravelias: to wit, that DePamphilis middle-fingered
25 Maravelias along with his daughter's new boyfnend to incite Maravelias to an unlawful
26
response by jealousy(Maravelias had asked-out the daughter and been romantically rejected).
27
The petition also alleged DePamphilis indirectly sent an unwanted, threatening letter to
28

RELIEF AND COMPENSATORY DAMAGES -4 - 34 MOCKINGBIRD HILL RD WINDHAM,NH 03087
1 Maravelias. Finally, Maravelias alleged his belief that DePamphilis "got in his car and went
2 marauding after [Maravelias] in [their] neighborhood" on the night of 3/21/17.
16. Judge John J. Coughlin presided over a February 2018 Hearing on Maravelias's
petition. DePamphilis appeared lawyer-represented and moved to dismiss the case.
^ 17. The trial court denied the motion to dismiss, allowing Maravelias to proceed.
7
18. Maravelias provided ample evidentiary support for his allegations. He 1)
8
g produced DePamphilis's harassing "middle-fingers" cyberbullying social media post,2)

10 brought his father to testify to DePamphilis's threatening, profane phone-calls, and, inter alia,
11 3)submitted a letter DePamphilis himself wrote wherein DePamphilis admitted to getting in

12
his vehicle to look for Maravelias on 3/21/17, the proper interpretation of which was disputed.
13
19. Judge Coughlin later denied the Stalking Petition with a stunning reality-
14
15 disowning finding that Maravelias provided "no credible evidence" to support his allegations.
16 The record however indicates DePamphilis contested little-to-none of manifold accepted

17
"evidence" Maravelias submitted to the same judge- solely the legal import thereof.
18
20. Judge John J. Coughlin is the same state judicial officer currently being sued in
19
20 the 42 U.S.C. § 1983 lawsuit Maravelias v. Coughlin et al.(1:19-CV-00143)for acts taken in

21 a separate Maravelias-DePamphilis dispute. It is Plaintiffs position that Judge Coughlin's
patently unreasonable, oppressive conduct against Maravelias in favor of DePamphilis is

23
objectively discernible through a history ofacts evincing a pattern of hostile bias.
24
The Lower State Court Orders Maravelias to Pay His Alleged-Stalker Over $9,000 in
Costs and Attorney's Fees to Punish the Truthful,First-and-Only Petition
26
21. Ostensibly perceiving Judge Coughlin's typhlotic favoritism, DePamphilis's
27
attorney filed a "Motion for Award of Attorney's Fees" on 3/8/18. This included an affidavit
28
itemizing legal expenses, requesting a total of$9,029.51 in fees and costs.

1 22. One ofthe itemized costs was dated "10/25/201T\ months before Maravelias
2 ever even initiated his restraining order petition against DePamphilis on 12/8/2017.
23. After Maravelias's Objection and Reply, Judge John J. Coughlin granted
DePamphilis's attorney's fees motion on 5/11/18, finding Maravelias's stalking petition was
6 "in bad faith" and that Maravelias's "positions were patently unreasonable".
7
24. Legally,"patently unreasonable" means "even iftrue, giving rise to reliefin no
8
possible set of circumstances". The same local court has subsequently granted protective
9
orders based offthe very same theories Judge Coughlin called "patently unreasonable".
10
11 25. Judge Coughlin did not make a single specific factual finding explaining how
12
Maravelias's petition was "in bad faith". Judge Coughlin repeated the reality-disowning
13
comment that Maravelias "did not provide any credible evidence ofthe allegations as set forth
14
^^ in the Petition"- as ifan uncontested full color screenshot of David DePamphilis middle-
fingering and cyberbullying Maravelias on his daughter's social media(which Judge
17 Coughlin admitted as evidence) was not "credible evidence" of said allegation
18
The Lower State Court Dreams-Up and Cites a Non-Existent Law Case, and Later
19 Refuses to Correct Its Erroneous Order
20
26. Judge Coughlin cited "Harkeem v. NH Dept of Employment Security, 117 N.H.
21
687(1977)" as support for the attorney's fees award. Embarrassinglv. there is no such case in
22
existence. Upon information and belief. Judge Coughlin took two cases and portmanteaued
23
24 the plaintiff of one with the defendant ofanother to contrive this non-existent fantasy case
25
27. Maravelias filed a Motion for Reconsideration on 5/21/18. Besides legal
26
argument on the illegality ofthe attorney's fees award, Maravelias objected that Judge
27
Coughlin incorrectly ordered payment including DePamphilis's erroneously itemized
28
"10/25/17" expense from months before Maravelias even initiated the case.

RELIEF AND COMPENSATORY DAMAGES -6 - 34 MOCKINGBIRD HILL RD WINDHAM,NH 03087
1 28. Judge John J. Coughlin totally ignored Maravelias's arguments and scribbled
2 "denied'* on the Motion for Reconsideration, failing to give any further specific explanation.
29. Faced with Judge Coughlin's reckless, fact-amnestic, and patently unreasonable
conduct, Maravelias intended to appeal the order to undo the wrongful plunder of his money.
^ After Consulting with His Lawyer, Maravelias Appeals the Unexplainahle Attorney's
j Fees Award to the New Hampshire Supreme Court
g 30. Any reasonable person in Maravelias's circumstance would file an appeal.
9
31. Maravelias consulted with his attorney retained in a separate matter, Richard E.
10
Samdperil, Esq., about Judge Coughlin's shocking fee award. Attorney Samdperil thought an
11
appeal would have considerable likelihood of success and opined that a defacto "one-bite"
12
^^ rule makes a punitive fee award quite bizarre on the first-and-only action a litigant ever took.
32. On7/2/18, Maravelias filed a Rule 7 Notice Mandatory of Appeal with

15
Defendants. Maravelias's appeal challenged both the fee award and the denial ofthe stalking
16
petition. Defendants chose to accept and docket the appeal as Case No. 2018-0376.
17
18 33. Maravelias personally knew his stalking petition was not "in bad faith" nor was
^^ "patently unreasonable". Maravelias was certain he would win the appeal.

20
Defendants Affirm the Underlying Attorney's Fees Award in a Secret "Final Order"
21 Mysteriously Redacted from Their Public Website Listing All Other Final Orders
34. After full briefing on both sides. Defendants fully adjudicated and resolved said
23
appeal in a Final Order dated 11/30/18, attached as Exhibit A.
24 "
25 35. After devoting multiple pages of discussion to affirm the stalking petition denial,
26 Defendants affirmed the punitive fees award merely with the following rushed, bald assertion:
22 "To the extent that the plaintiff argues that he did not act in bad faith, based upon
2g our review ofthe record, we conclude that the trial court's determination is
supported by the evidence and not legally erroneous'

RELIEF AND COMPENSATORY DAMAGES - 7- 34 MOCKINGBIRD HILL RD WINDHAM,NH 03087
1 36. Defendants neglected to cite any such supporting part ofthe "record".
2
37. Defendants' Final Order acknowledged the indisputably erroneous 10/25/17
expense and noted that DePamphilis waived it in his Opposing Brief. Therefore, the excessive
original monetary amount ofthe award was corrected onlv because Maravelias brought an
5 appeal to Defendants.
7
38. Defendants' Final Order contained no indication they found Maravelias's appeal
8
"frivolous" or "in bad-faith". Defendants frequently use a boilerplate one-page Final Order to
9
dispose oftruly "fiivolous" appeals. See e.g., Exhibit B. Defendants treated Maravelias's
10
1j appeal as a meritorious, rightful appeal all the way through its final adjudication on the merits.
12
39. Defendants post their "Other Final Orders" on the New Hampshire Supreme
13
Court public website flittps://www.courts.state.nh.us/supreme/finalorders/2018/index.htm).
14
Defendants' clerk confirmed by phone the Final Orders/Opinions of all appeals fully briefed
15
jg and resolved on the merits are published on said site. Defendants even appear to include the
17 aforementioned one-page boilerplate Final Orders disposing ofcompletely meritless appeals.
18
40. Defendants have uniquely, specifically self-censored their 11/30/18 Final Order
19
in Maravelias's appeal for inexplicable exclusion from said site. They have not uploaded nor
20
2j published said routine Final Order where all such others appear. Another analogous Final
22 Order dated 11/30/18(2018-206)appears under "November 30" on said site.
23
The Origins of the Fraudulent "Rule 23 Attorney's Fees" Extortion Conspiracy
24
41. Before the appeal was decided, both Maravelias and DePamphilis filed Motions
25
2g to Strike portions ofthe other's brief(s). DePamphilis's such motions, as they often baselessly
27 do, contained a robotic prayer for attorney's fees.
28

RELIEF AND COMPENSATORY DAMAGES -8- 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1 42. Defendants' 11/30/18 Final Order granted in-part and denied in-part
2 DePamphilis's 10/19/18 Motion to Strike, stating,

3
"To the extent that the defendant requests attorney's fees in connection with the
4 motion [DePamphilis's 10/19/18 Motion to Strike], the request is denied without
prejudice to the defendant moving for attorney's fees pursuant to Supreme Court
Rule 23".
43. N.H. Supr. Ct. R. 23 is entitled "Taxation of Costs; Waiver; Attorney's Fees'
and provides in its final part:
9 "In the interest ofjustice in extraordinary cases, but not as a matter ofright, the supreme
jQ court in its sole discretion may award attorney's fees related to an appeal to a prevailing
party if the appeal is deemed by the court to have been frivolous or in bad faith.
11
44. Neither Defendants' Final Order nor DePamphilis's 10/19/18 Motion to Strike
12
23 ever mentioned, requested, or contemplated punitive attorney's fees against Maravelias
14 beyond the limited scope ofthe one single motion. Prayer C of DePamphilis's Motion stated,
^^ "Award Mr. Depamphilis his attorney's fees in connection with having to file the
25 instant motion:"(Exhibit C)(Emphasis added)
17
45. N.H. Supr. Ct. R. 25 allows a party to move to summarily dismiss an appeal at
18
any time if it were "frivolous or in bad faith". DePamphilis never made such a motion.
19
20 46. 29 days after Defendants' Final Order, DePamphilis filed a 12/28/18 pleading in
21 the ended case entitled "Appellee's Request for Taxation of Costs and the Award of
22
Attorney's Fees". He sought attorney's fees 1)again in connection with filing his 10/19/18
23
Motion to Strike, and 2)newly in connection with filing his 10/19/18 Objection to
24
Maravelias's Motion to Strike. DePamphilis's 12/28/18 Motion requests at Paragraph 23:
25
25 "It is submitted that the two described pleadings were fnvolous and, accordingly,
Mr. DePamphilis should be awarded his attomevs' fees associated with having to
27 respond to them."(Exhibit D)(Emphasis added)
28

1 47. DePamphilis's 12/28/18 pleading never requested any attorney's fees beyond
2 attorney's fees in connection with DePamphilis two 10/19/18 pleadings. Further, only
DePamphilis's 10/19/18 Motion contained a prayer for limited attorney's fees in connection
4
with its filing. DePamphilis's 10/19/18 Objection, however, did not, waiving the claim.
5 ■■
5 48. On 12/31/18, Maravelias filed an Objection to DePamphilis's 12/28/18 request.
7 (Exhibit E)DePamphilis's request was baseless; Maravelias exposed it as riddled with

8
factual falsity and vexatious intent. Maravelias incorporated by reference his 12/10/18 letter to
9
DePamphilis's attorney which brought to light his rampant misrepresentation conduct,
10
fraudulent assertions offact, and willful mischaracterizations ofthe record.(Exhibit F)
11
12 Defendants Play "Wait-and-See" for Almost Three Months,Then Retaliate Against

Maravelias for His Motion for Reconsideration in No.2018-0483 By Means of Punitive
13
Extortion Masquerading as Lawful "Appeal Fees" in No.2018-0376
14
49. Maravelias had initiated a second appeal(2018-04831 to Defendants on 8/15/18
15
in relation to the separate DePamphilis-Maravelias matter. Defendants issued a Final Order in
16
17 that appeal on 1/16/19. The separate 2018-0483 Maravelias-DePamphilis appeal was about
18 1.5 months ahead ofthe 2018-0376 appeal underlying this action.

19
50. In 2018-0483. Maravelias filed a Motion for Reconsideration on 1/28/19.
20
(Exhibit G)
21
22 51. Defendants did nothing on DePamphilis's 12/28/18 request until months later,
23
after receiving Maravelias's stirring Motion for Reconsideration in the separate case exposing
24
Defendants' libel and mischaracterization offact in their 1/16/19 Final Order in 2018-0483.
25
26 52. Conjunctively on 2/21/19, Defendants issued two one-page Orders in both
27 Maravelias-DePamphilis appeal cases

28

RELIEF AND COMPENSATORY DAMAGES - 10 - 34 MOCKINGBIRD HILL RD WINDHAM,NH 03087
1 a. In 2018-0483 (the separate appeal), they blanket-denied Maravelias's Motion for
2 Reconsideration with zero specific discussion.(Exhibit H)
b. In 2018-0376 (the underlying appeal), they GRANTED DePamphilis's 12/28/18 request
with the following explanation:"The defendants request for taxation of costs and the
6 award of attorney's fees is granted. Rule 23. ... On or before March 4, 2019,the
7 defendant shall file an itemization ofthe attorney's fees that he is seeking."(Exhibit I)
Defendants Deny Maravelias a Hearing,Allow ^DePamphilis's 3/4/19 Itemization to

^ Surreptitiously Metastasize to Include Fees for the Entire Appeal,and Deprive
jQ Maravelias of Any Opportunity to Respond
11 53. In response, Maravelias filed a 2/26/19 "Motion to Reconsider Anomalous,
Arbitrary Rule 23 Award of Appeal Attorney's Fees".(Exhibit J)

13
54. Directly addressing Defendants, Maravelias noted their abrogation of his
14
constitutional rights, reiterated the meritorious and necessary nature of his appeal, and
16 apprised them oftheir partisan bad-faith conduct-including, but not limited to, failing to
^2 correct their overt mischaracterizations of Maravelias's transcribed testimony in their 2018-

18
0483 Final Order to malign Maravelias.
19 "
2q 55. Maravelias explicitly requested a "Hearing on this matter" in said Motion.
21
56. On 3/4/19, DePamphilis, by attorney, filed a jaw-dropping "Appellee's
22
Itemization of Attorney's Fees and related Affidavit".(Exhibit K)
23
24 57. DePamphilis's itemization included everv single hour his attornev worked in
25 the entire totalitv of the months-long litigation from "07/05/2018" to "12/28/2018".
totaling $4.900.00. even including the time the lawyer spent reading the "Supreme Court's
27
[4-page] order denying Mr. Maravelias' appeal" and "conimunicat[ing] with client re: same'
28 "
ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE pauL MARAVELIAS

RELIEF AND COMPENSATORY DAMAGES - 11 - 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
1 58. By contrast, DePamphilis's itemization reveals that an absolute maximum of
2 $530.00 in fees were connected with the filing ofthe two 10/19/18 pleadings for which his
granted 12/28/18 request sought reimbursement.
59. Simon R Brown, DePamphilis's attomey, submitted a sworn affidavit with the
6 itemization indicating he intended to seek "legal fees in the amount of$4,900.00 through
7 December 28, 2018,for 43.0 hours of billed time spent in the defense ofthis appeal" and that
8
he knew these fees exceeded the limited scope ofthe 10/19/18 pleadings.(Exhibit K)
9
60. Defendants received this itemization and had a duty to ensure that the total
10
j2 amount requested was consistent with the relief actually sought and granted
12
61. On 3/29/19, Defendants issued an Order giving rise this action, stating:
13
'After review, the plaintiffs motion for reconsideration ofthe February 21, 2019 order
conceming attomey's fees is denied. The defendant is hereby awarded attomey's fees
2^ pursuant to Rule 23 in the amount of$4,900."(Exhibit L)
1 ft
Defendants Ignore Maravelias's Constitutional Arguments and Refuse to Make a
17 Single Finding of Fact in Support of The Alleged '^Rule 23 Award"
18 62. Defendants' 3/29/19 Order ignored or denied Maravelias's request for a hearing.
19 ..
63. Defendants' 3/29/19 Order indicates that they ignored, did not hear, or otherwise
20
never adjudicated Maravelias's federal constitutional claims in the 2/26/19 Motion.
21
22 64. Defendants' threadbare two-sentence 3/29/19 Order contained zero factual

23
findings justifying their commandment that Maravelias pay his opponent $4,900.00.
24 "
25 65. Defendants were aware of Maravelias's 2/26/19 written request to Defendants to
26 "state specific facts and reasons why this appeal was allegedly 'frivolous or in bad faith"
27
66. Defendants' 3/29/19 Order deprived Maravelias an opportunity to respond to
28
DePamphilis's 3/4/19 itemization and the amount sought.

1 This Action is Properly Before This Court
2 67. Defendants will enforce their unlawful Order if Maravelias does not relinquish
his monetary property. Accordingly, Defendants' violation offederal law is ongoing.
68. Defendants cite their own Rule 23 as the legal authority for their 3/29/19 Order.
^ 69. On 5/1/19, DePamphilis's attorney emailed Maravelias "conceming payment of

7
the attorney's fees ordered by the Supreme Court" demanding the "status of payment
8"
g 70. Plaintiff lives near the Massachusetts border and heavily engages in interstate
10 commerce on a routine basis. His employer is out-of-state
11
71. An individual can bring an action in federal court against a state's highest court
12
in relation to its enforcement and/or promulgation ofa court rule aggrieving said party. See
13
e.g. Supreme Court ofN.H. v. Piper, 470 U.S. 274(1985)(New Hampshire Supreme Court
14
15 Rule 42 deemed unconstitutional in violation ofthe Privileges and Immunities Clause). It
16 occurs most frequently in the context of challenges to state supreme court bar admission rules.
17
72. The Rooker-Feldman doctrine prohibits federal district courts from reviewing
18
final state courtjudgments where the proceedings are of a judicial nature. The doctrine does
19
20 not preclude generic facial challenges to unconstitutional court rules nor actions connected
21 with a state court's "non-judicial" proceedings, such as if acting in a legislative or
enforcement capacity. See District ofColumbia Ct. ofAppeals v. Feldman,460 U.S. 462
23
(1983)(allowing general attack on the constitutionality ofthe D.C. Bar admission rule).
24 "
25 73. Defendants' 11/30/18 Final Order upholding the underlying $9,000 attorney's
26 fees award was a "judicial proceeding". Plaintiff is not attempting to seek unavailable review
22 thereof. He describes it here solely to narrate Defendants' pattem of bad-faith misconduct.

28

1 74. Defendants'"judicial proceedings" ended there. In their current particular
2 application of Rule 23 to force Plaintiff baselessly to pay $4,900 of attorney's fees for the
3
appeal itself. Defendants are acting in a non-judicial legislative and enforcement capacity.
4
Defendants themselves promulgate "Rule 23", not the legislature. Defendants themselves
5
threaten to enforce their unlawful commandment with contempt of court powers.
6
7 75. The legal definition of a "judgment" is "the official and authentic decision of a
o
court ofjustice upon the respective rights and claims ofthe parties to an action or suit therein
9
litigated and submitted to its determination.
10 ■■
11 76. Since a "judgment"requires a both a "claim" and a "right", and since Rule 23
12 specifically advises such appeal fee awards are "not... a matter ofright". Defendants'
^^ extortionate commandment to Plaintiff under Rule 23 is not a "final state courtjudgment".

14
77. Defendants did not even attempt to adorn their reckless conduct with the visage
15
of a "judicial inquiry". They made no specific findings offact, ignored Maravelias's request
16
for a hearing, and cited zero case law or statutes in connection with the "Rule 23" award.
\g Defendants' Fraudulent Conduct in Perspective
19 78. Defendants did not make any plain finding "deeming" Maravelias's appeal to be
on
"fiivolous" or "in bad-faith". Their heedless 2/21/19 order merely "granted" DePamphilis's
21
fraudulent motion for extraordinary appellate attorney's fees and quipped,"See Rule 23'
22 ■■
23 79. Defendants did not make any specific findings offact from which a finding of
24 the appeal as "fnvolous" or "in bad faith" could be inferred.
25
80. The allegation that Maravelias's appeal to Defendants was "frivolous" or "in
26
bad-faith" is logically nullified by the erroneous predating 10/25/17 expense from the
27
2g underlying fee award which DePamphilis himself waived in his appellate Opposing Brief.
81. Maravelias's appeal to Defendants was not "frivolous" nor "in bad-faith".

1 82, Maravelias soon anticipates needing to file an appeal in the NH Supreme Court
2 in a separate matter. Defendants' conduct has caused Maravelias to fear vindicating his legal
rights in his state's only appellate forum will result in further monetary extortion and abuse.
83. Defendants' act is unprecedented. Paul Maravelias is the single pro se Appellant
6 in the entire 143-year modem history of the New Hampshire Supreme Court to be ordered
7 under Rule 23 to pay a prevailing party's full attomey's fee bill.

8
9 CAUSES OF ACTION
10
11 COUNTS 1 AND 2
VIOLATION OF THE FIRST AMENDMENT TO THE
12
UNITED STATES CONSTITUTION (42 U.S.C. 81983)
13
Defendants' Unprecedented Retaliatory Extortion Denies Maravelias's
Fair Access to the Courts and Unlawfully Punishes His Disagreed-With Speech
15
84. All paragraphs hereinabove are repeated herein as though fully set forth.
16
2 <7 85. The First Amendment guarantees "Congress shall make no law ... abridging the
18 freedom ofspeech, or ofthe press; or the right... to petition the Government for a redress of
grievances". It applies to the states. Stromberg v. California, 283 U.S. 359(1931).

20
COUNT 1: FIRST AMENDMENT RETALIATION
21
22 86. "[T]he law is settled that as a general matter the First Amendment prohibits
23 government officials from subjecting an individual to retaliatory actions ... for speaking out.
24 Mercado-Berrios v. Cancel-Alegria,611 F.3d 18, 25 Cir. 2010)(quoting Hartman v.

25
Moore,547 U.S. 250,256(2006))."Claims ofretaliation for the exercise of First Amendment
26
rights are cognizable under § 1983."Powell v. Alexander, 391 F.3d 1, 16(1®^ Cir. 2004).
27
28 87. A plaintiff asserting a retaliation claim under the First Amendment must show 1)
he engaged in constitutionally protected conduct, 2)the government took an adverse action

1 against him, and 3)the protected conduct was a "substantial" or "motivating factor" in the
2 government's decision to take the adverse action. Mount Healthy City Sch. Dist. Bd. ofEduc.
^ Doyle,429 U.S. 274,287(1977); Hartman v. Moore,547 U.S. 250,256,126 S.Ct. 1695,

4
164 L.Ed.2d 441 (2006); Centro Medico del Turabo, Inc. v. Feliciano deMelecio, 406 F.3d 1.
5
10(P'Cir. 2005); Davignon v. Hodgson,524 F.3d 91, 106 Cir. 2008).
6
7 88. Plaintiffs court filings to Defendants are protected speech. Defendants'"$4,900'

8
order, masked as a valid "Rule 23 attorney's fees award", is an adverse act against Plaintiff.
9
89. Temporal proximity can satisfy the causation element ofthe First Amendment
10
Yj retaliation doctrine even amid factual circumstances far less compelling than Defendants' two
12 concomitant knee-jerk Orders here, issued in two separate appeals coincidentally on the same
day, 2/21/19. See e.g., Philip v. Cronin,537 F.3d 26, 33(P'Cir. 2008). Reading between the
14
lines of Defendants' two non-responsive 2/21/19 Orders, one can easily imagine Defendant
15
LYNN'S haughty persiflage muttered among his complicit colleagues,''who the hell does this
16
j^ kid think he is","we'II show it to that pro se bastardfor standing upfor his rights", etc.
^^ 90. Plaintiffs 1/28/19 Motion for Reconsideration to Defendants in 2018-0483 was

19
firm in tone but does not authorize Defendants' retaliatory acts. Absent "fighting words",
20
offensive speech to governmental actors is protected from retaliation. See e.g., Greene v.
21
Barber, 310 F.3d 889,895-97 {6^^ Cir. 2002)(calling a police officer an "asshole" and
22
23 "stupid" protected from retaliation). The furthest Maravelias went was to call Defendants-
24 accurately-the "Holy Feminist Court" in his prayer for relief. This does not come close.
25
91. Defendants issued an unlawful order wrongly depriving Maravelias of$4,900 in
26
Defendants' subjective displeasure with Maravelias's speech and in punitive retaliation
27
2g therefor- chiefly, for Maravelias's 1/28/19 Motion for Reconsideration and his 2/26/19
"Motion to Reconsider Anomalous, Arbitrary Rule 23 Award of Appeal Attorney's Fees".

1 92. Defendants wrongfully retaliated against Plaintiff and thereby disparaged and
2 violated Plaintiffs First Amendment rights, and continue to do so.

3
COUNT 2: VIOLATION OF RIGHT TO PETITION
4
5 93. The First Amendment's Right to Petition clause is incorporated against the
^ states. Edwards v. South Carolina, 372 U.S. 229(1963). The First Amendment protects
7
citizens' right to access state courts and prosecute civil actions. Bill Johnson's Restaurants,
8
Inc. V. Nat'l Labor Relations Ed.,461 U.S. 731, 734(1983)."[T]he Petition Clause protects
9
^^ the right ofindividuals to appeal to courts and other forums established by the government for
j1 resolution of legal disputes." Borough ofDuryea, et al. v. Guarnieri, 564 U.S. 379(2011).
12
94. Defendants issued an unlawful order punishing Maravelias for rightfully filing a
13
non-fiivolous, properly intended Rule 7 Mandatory Appeal in New Hampshire's only
14
15 appellate court. Defendants' acts have been and are currently repressing Maravelias's First
16 Amendment-protected usage of his only available appellate forum. Defendants' Orders are
17
public and have a similar repressive effect to all potential appellants. Maravelias fears bad
18
faith extortion and punitive abuse of power should he petition the government for redress(by
19
appealing) in an ongoing NH Circuit Court case where his rights have been violated anew.
20
21 95. Defendants' conduct is in violation of Plaintiffs Right to Petition.
22
COUNTS
23
VIOLATION OF PART I. ARTICLES 22 AND 32 OF THE
24 NEW HAMPSHIRE CONSTITUTION (28 U.S.C. S 1367(a))
25
96. All paragraphs hereinabove are repeated herein as though fully set forth.
26
27 97. All claims brought herein under state constitutional law are directed exclusively
28 towards Defendant ROBERT J. LYNN in his individual capacity only, consistent with
ORIGINAL VERIOED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

RELIEF AND COMPENSATORY DAMAGES - 17 - 34 MOCICINGBIRD HILL RD WINDHAM,NH 03087
1 Pennhurst State School and Hospital v. Halderman,465 U.S. 89, 106, 121 (1984). Plaintiff
2 brings all federal constitutional claims herein against all Defendants.
98. Ft. I, Art. 22 and 23 ofthe NH Constitution provide equal or greater protections
for the right to petition and for freedom ofspeech than the federal First Amendment.
6 99. Counts 1 and 2 are repeated herein as though fully set forth. Defendants' acts
^ referenced therein also violate Plaintiffs rights under N.H. CONST.,Pt. I, Art. 22 and 32.
8"
9 COUNTS 4.5 AND 6
VIOLATION OF THE FOURTEENTH AMENDMENT TO
THE UNITED STATES CONSTITUTION(42 U.S.C. $1983)
11
22 100. All paragraphs hereinabove are repeated herein as though fully set forth.
1
^^ 101. The Due Process Clause ofthe Fourteenth Amendment prohibits a state from
14
depriving a person of"life, liberty, or property, without due process oflaw.""This guarantee
15
has both substantive and procedural components." Pagan v. Calderdn,448 F.3d 16, 32(f
16
22 Cir. 2006).
^^ 102. Plaintiffclaims two liberty or property interests which Defendants are depriving
19
without valid due process. First, Maravelias's $4,900.00 US dollars is a monetary property
20
interest. Second, wrongly implying Maravelias filed a "frivolous or bad-faith" appeal
21
infringes on his personal liberty interest and right to be free from social or reputation stigma,
22
23 which Defendants recognized in State v. Veale, 158 N.H. 632,638-39,972 A.2d 1009(2009)
COUNT 4: VIOLATION OF SUBSTANTIVE DUE PROCESS

25
103. "The substantive due process guarantee functions to protect individuals from
27 particularly offensive actions on the part ofgovernment officials, even when the government
28 employs facially neutral procedures in carrying out those actions. Pagan v. Calderon,448
F.3d 16, 32 Cir. 2006)(citing Daniels v. Williams,474 U.S. 327, 331, 106 S.Ct. 662,88
ORIGINAL VERIHED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

1 L.Ed.2d 662(1986))."[C]onscience-shocking conduct is an indispensable element of a
2 substantive due process challenge". DePoutot v. Raffaelly,424 F.3d 112(P* Cir. 2005)
104. Defendants conduct is conscience-shocking because they 1)accepted and fully
adjudicated Maravelias's appeal, 2)knowingly observed that said appeal was necessary, ata
5 bare minimum,to correct the erroneous 10/25/17 cost the trial court failed to correct, and 3)
7 months later, after being angered by Maravelias's speech in a separate case, fraudulently held
o
the appeal as "fnvolous or in bad faith" to grant retaliatory punishment against Maravelias.
9
j^ 105. Defendants conduct is also conscience-shocking because their acts are criminal
jj Theft by Extortion(RSA 637:5), exercising unlawful control over Maravelias's monetary
12 property and threatening punishment and reputational harm by contempt of court powers.
13
106. Further exacerbating their extreme and outrageous conduct, Defendants 1)
14
denied Maravelias a hearing on the Rule 23 Motion, 2)failed to make a single finding offact.
15
jg upon request, explaining why the appeal was possibly "fnvolous or in bad faith", 3)failed to
17 make an explicit finding that the appeal was "fnvolous or in bad faith" in the first place, and
1^ 4)ordered punitive payment of DePamphilis's entire attomey'^s fees bill, whereas the function
19
of Rule 23 is intended to be deterrent and not compensatory.
20 "
2j 107. All the above was subsequent to Defendants' initial abuse ofpower,issuing a
22 shocking "screw-Maravelias" affirmation in the underlying appeal so utterly baseless that they
23 intentionally self-censored it from their Final Orders webpage to avoid public backlash.
24
Accordingly, it is beyond peradventure that Defendants conduct is "truly outrageous,
25
uncivilized, and intolerable". Hasenfus v. LaJeunesse, 175 F.3d 68, 72(1®' Cir. 1999).
26
27 108. Defendants violated Maravelias's substantive due process rights under the
28 Fourteenth Amendment through their reckless conduct, and continue to do so.
ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE RAUL MARAVELIAS

1 COUNT 5: VIOLATION OF PROCEDURAL DUE PROCESS
2 109. Defendants are aware and have stated that "under the fourteenth amendment.
3
procedural due process applies [where] an individual faces a potential deprivation ofa liberty
4
or property interest." State v. Gibbons, 135 N.H. 320, 321,605 A.2d 214(1992).
5
6 110. Defendants denied Maravelias due process oflaw when they rejected or ignored
1 his written 2/26/19 request for a pre-deprivation hearing. Where a rightful extraordinary
o
application of Rule 23's appeal-fees-punishment is distinguished from criminal extortion

9
solely by the factual question ofthe "frivolity" or "bad-faith" nature of conduct, the right to
10
^^ hearing was paramount. Cf. Codd v. Velger,429 U.S. 624,97 S.Ct. 882,51 L.Ed.2d 92(1977)
j2 (pre-deprivation hearing not necessary for due process where there was a factual dispute).
13
111. Procedural due process requires "some form of hearing" before deprivation of
14
property. Memphis Light, Gas and Water Div. v. Craft,436 U.S. 1,19(1978). When an
15
appellate court volunteers itself as an original fact-finder to determine whether to command a
16
j2 pro se 23-year-old Appellant to pay $4,900 to his rich lawyer-represented Executive VP &
1g COO victimizer, it must at least grant an evidentiary hearing allowing said Appellant to cross-
19 examine the Appellee on the purported factual grounds ofthe alleged "fnvolous" or "bad-
20
faith" conduct. This holds especially true under the circumstances for two compelling reasons:
21
112. First. Defendants gave no opportunitv whatsoever for Maravelias to respond to
22
23 or contest DePamphilis's wildly fraudulent 3/4/19 Itemization of Appeal Costs and Affidavit,
24 the origin ofthe "$4,900.00" figure. DePamphilis's 3/4/19 itemization deceptively furthered
95
his original 12/28/18 request for attorney's fees (solely in connection with filing two motions)
26
all-the-sudden to the expanded realm of DePamphilis's entire attomev fee bill for the entire
27
anneal, start-to-finish. Defendants accepted at face value DePamphilis's hyperextended
28
"$4,900" figure and denied Maravelias's requested hearing. Having exhausted his single

1 Motion for Reconsideration pursuant to N.H. Supr. Ct. R. 22, Maravelias's only remedy to
2 challenge the fees itemization was the hearing he requested, which Defendants denied.
113. Second,since Maravelias had repeatedly exposed DePamphilis's other
fraudulent and malicious litigation conduct, the due process right to cross-examine at a
6 physical hearing was "even more important". Greene v. McElroy,360 U.S. 474(1959)."The
7 policy ofthe Anglo-American system of Evidence has been to regard the necessity oftesting
8
by cross-examination as a vital feature ofthe law."Id.
9
114. In such circumstances, the right to physical witness cross-examination is
10
j2 paramount for fair fact-finding. Even if Defendants'"Rule 23" extortion were justified, their
12 refusal to hold an evidentiary hearing suffocated Maravelias's ability to correct the excessive
^^ "$4,900.00" amount."In almost every setting where important decisions turn on questions of
14
fact, due process requires an opportunity to confront and cross-examine adverse witnesses.
15
Goldberg v. Kelly^ 397 U.S. 254,269(1970). See also ICC v. Louisville & Nashville R.R., 227
16
U.S. 88,93-94(1913). Q!§ 7(c)ofthe Administrative Procedure Act,5 U.S.C. § 556(d)
^^ 115. Denying Maravelias a hearing deprived him of an "opportunity [to be heard]

19
which must be granted at a meaningful time and in a meaningful manner." Armstrong v.
20
Manzo,380 U.S. 545,552(1965). Further, as Defendants made zero reference to Maravelias's
21
specific arguments, rebuttals, and requests, it is dubitable that Defendants even gave more
22
23 than a careless glance at Maravelias's 12/31/18 Objection and 2/26/19 Motion to Reconsider
24 Defendants' exiguous, knee-jerk,"screw-Maravelias" orders amount to a shameful abjuration
of Maravelias's right to be fully heard - whereas the requested in-person hearing would have
26
forced Defendants to listen
27 "
2g 116. Furthermore, Defendants violated due process when they justified their Order
under "Rule 23" without making any explicit finding Maravelias's appeal was "fnvolous or in
ORJGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

1 bad faith" as Rule 23 requires. See Roadway Express, Inc. v. Piper,447 U.S. 752(1980)."In
2 this case, the trial court did not make a specific finding as to whether counsel's conduct
3
constituted or was tantamount to bad faith, a finding that should precede any sanction under
4
the court's inherent powers."Id.(Emphasis added).
5
5 117. Defendants violated Maravelias's procedural due process rights under the
7 Fourteenth Amendment through their acts and negligence, and continue to do so.
8
COUNT 6: VIOLATION OF EQUAL PROTECTION CLAUSE
9
10 118. To state an equal protection violation claim, plaintiffs must "identify and relate
11 specific instances where persons situated similarly 'in all relevant aspects' were treated
12
differently, instances which have the capacity to demonstrate that [plaintiffs] were 'singled ...
13
out for unlawful oppression.'" Dartmouth Review v. Dartmouth College, 889 F.2d 13, 19(U'
14
Cir. 1989).
15
16 119. Defendants' erratic, hyperactive punishment of Maravelias is objectively

17
inconsistent with the way similarly situated litigants in the past have been treated. For
18
example, the New Hampshire Supreme Court entertained a Rule 23 attorney's fees request in
19
Funtown USA,Inc. v. Town ofConway, 129 N.H. 352(1987). First, said Rule 23 request was
20
2^ properly introduced and adjudicated as one "to require [defendant] to pay plaintiffs [entire]
22 fees incurred in defending this appeal", not as a limited fees request for a certain motion and
23 later surreptitiously metastasized into covering the whole appeal as with Defendants' 3/29/19
24
Order. Second,in Funtown,the court allowed both parties a fair opportunity to be heard and
25
adjudicated the request in a full opinion (as opposed to a two-sentence procedural order).
26
Third,the Funtown court denied the request, concluding,"the amount of attorney's fees
2g awarded was quite large and by no stretch ofthe imagination could it be said that the appeal

1 [thereof] was fnvolous, particularly in view ofthe fact that the defendant has prevailed on one
2 ofthe issues it raised."
120. There can be no question "$9,029.51" is a "quite large" sum for a 22-year-old,
nor that Maravelias indeed "prevailed on one ofthe issues" his appeal raised as DePamphilis
6 waived the erroneous 10/25/17 expense in his Opposing Brief. Accordingly, the same factors
7 present in Funtown through which "by no stretch of the imagination could it be said that the
o
appeal was frivolous" were present in Maravelias's appeal. Defendants are therefore violating
9
Maravelias's Amendment right to equal application oflaws and placing him into an
10
indiscriminate "class-of-one". See Village ofWillowbrook v. Olech, 528 U.S. 562(2000).
12 121. In more recent case law, Defendants have given fair-warning to dispel actual
^^ misconduct yet have capriciously extorted Appellant Maravelias with zero warning-after he
14
committed no misconduct. In Branch Banking and Trust Company v. Samson Duclair & a
15
(NHSC Case No. 2015-0545), Defendants warned as follows.
16
"At this time, we deny the lender's request for attorney's fees and other sanctions.
17
However,if in future cases the defendants continue to press issues that have been
18 finally resolved or are not properly before us, we will entertain a properly
jp supported motion for attorney's fees."Id.
20 122. By comparison. Defendants' 3/29/19 Order does not even retroactively identify
21 any specific misconductjustifying their $4,900 fees award, let alone grant Maravelias a fair-
22
warning to desist in any future misbehavior, as Defendants' dispensed in Branch Banking.
23
123. In fact, it is impossible to discern a single instance in historv where the New
24
25 Hampshire Supreme Court has ever granted a Rule 23 attorney's fees sanction against a pro se
26 litigant. See e.g., Indorfv. Indorf, 132 N.H.45,47(1989)(denying Rule 23 fee award request
27
against pro se litigant); Walker v. Walker^ 119 N.H. 551 (1979)(not granting award of appeal
28

1 attorney's fees even after "the fourth time the plaintiff has litigated these same issues and the
2 fourth time he has been denied relief), etc.
124. To the extent the Defendants caused or permitted DePamphilis's original
12/28/18 request(seeking fees in connection with his the 10/19/18 pleadings) to blossom into
6 a fraudulent, surreptitious request on 3/4/19 for comprehensive appeal attorney's fees-four
7 months after the Final Order- Defendants violated equal protection by failing to reject the de
o
facto untimely request. See e.g., In the Matter ofTanya Braga-Pillsbury and Mickey Pillsbury
9
(NHSC Case No. 2018-0560), where Defendants squarely denied an untimely "fnvolous
10
^^ appeal" attorney's fees request a few days before extorting Maravelias here.
12 125. Accordingly, Defendants' conduct is in blatant disregard for the equal rights of
^^ Plaintiff, who has been treated much differently than similarly situated individuals. By
14
subjecting Maravelias into a "class-of-one"- a target oftheir bad-faith anger and meritless
15
subjective fmstration - Defendants have violated and continue to violate the Equal Protection
16
Clause ofthe U.S. Constitution.
17
18
COUNT 7
19 VIOLATION OF PART L ARTICLES 2 AND 15 OF THE
new HAMPSHIRE CONSTITUTION (28 U.S.C. S 1367(all
21 126. All paragraphs hereinabove are repeated herein as though fully set forth.
22
127. Pt. I, Art. 2 and 15 ofthe NH Constitution provide equal or greater protections
23
for procedure and substantive due process rights and equal protection rights than the federal
24
Fourteenth Amendment.
25
26 128. Counts 4,5 and 6 are repeated herein as though fully set forth. Defendants' acts
27
referenced therein also violate Plaintiffs rights under N.H. CONST.,Pt. I, Art. 2 and 15.
28

1 COUNTS 8 AND 9
VIOLATION OF THE EIGHTH AMENDMENT TO THE
2
UNITED STATES CONSTITUTION (42 U.S.C. $1983)
3
129. AH paragraphs hereinabove are repeated herein as though fully set forth.
4
5 130. The Eighth Amendment guarantees that "excessive bail shall not be required,
6 nor excessive fines imposed, nor cruel and unusual punishments inflicted".
7
COUNT 8: VIOLATION OF EXCESSIVE FINES CLAUSE
8
9 131. In a dramatically fortuitous coincidence. Defendants issued their extortionate
10 "Rule 23" Order against Maravelias one day after the United States Supreme Court finally
^^ incorporated the Excessive Fines Clause ofthe Eighth Amendment against the states in Timbs
12
V. Indiana, 586 U.S. (2019)on February 20 ,2019.
13 ■■
14 132. Defendants 3/29/19 Order and general conduct in both Maravelias-DePamphilis
15 appeals indicates that they are acting with the intention to punish and deter Maravelias. While
the Excessive Fines Clause "does not apply to awards of punitive damages in cases between
17
private parties," Browning-Ferris Industries v. Kelco Disposal, Inc., 492 U.S. 257,260
18
(1989), Defendants' Order purporting to be a "Rule 23"fees award is distinct from punitive
19
2q damages in a regular civil suit. The language of Rule 23 itselfconfirms said awards are solely
21 at the Defendants'"discretion", unlike the legal "right" to just money damages in a civil suit.
22
133. Further, as previously detailed. Defendants' Rule 23 extortion conspiracy
23
against Maravelias was never lawfully expanded to include punitive reimbursement for the
24
entire appeal as opposed to solely the 10/19/18 pleadings. The relief requested on 12/28/18 by
25
26 DePamphilis and granted by Defendants on 2/21/19-even if that alone were not federally
27 unlawful- would give rise to a maximum "fine" of$530.00, not $4,900.00. See supra.
28

1 134. Accordingly, Defendants' 3/29/19 Order imposes an excessive fine against
2 Maravelias in violation ofthe Eighth Amendment to the U.S. Constitution.

3
COUNT 9: CRUEL AND UNUSUAL PUNISHMENT
4
5 135. All paragraphs under Count6 are repeated as though fully set forth.
6
136. Defendants' said excessive fine is separately and additionally a cruel and
7
unusual punishment. Both the "cruelty" and "unusualness" thereof are plain from the
8
^ aforesaid. Accordingly, Defendant's 3/29/19 Order imposes a cruel and unusual punishment
10 against Maravelias in violation ofthe Eight Amendment.
11
COUNT 10
12 VIOLATION OF FART I. ARTICLE 33 OF THE
NEW HAMPSHIRE CONSTITUTION (28 U.S.C. S 1367faD
14 137. All paragraphs hereinabove are repeated herein as though fully set forth
15
138. Ft. I, Art. 33 of the NH Constitution provides equal or greater protections
16
against governmental imposition ofexcessive fines or cruel and unusual punishment than the
17
federal Eighth Amendment.
18
19 139. Counts 8 and 9 are repeated herein as though fully set forth. Defendants' acts
20
referenced therein also violate Plaintiffs rights under N.H. CONST., Ft. I, Art. 33.
21
COUNTS 11 AND 12
22
N.H.SUPREME COURT RULE 23 IS FACIALLY INVALID IN VIOLATION
23 OF THE FOURTEENTH AMENDMENT TO THE U.S. CONSTITUTION
2^ (28 U.S.C S 1331.13431
25 140. All paragraphs hereinabove are repeated as though fully set forth.
26
COUNT 11: SUBSTANTIAL VIOLATION OF DUE PROCESS CLAUSE
27
2g 141. Rule 23 lacks any explicit due process requirements for the fact-finder(the New
Hampshire Supreme Court) to obey. While one would aspire the competent judicial

1 providence ofa state's highest court would suffice to ensure such elementary necessities be
2 observed regardless, all experience hath shewn the contrary.
142. All applications, or a substantial number,of Rule 23 are likely to abrogate a
party's due process rights absent specific requirements that 1)the court make specific findings
6 offact and state its reasoning for granting any Rule 23 appellate attorney' fees order, 2)hold
7 an evidentiary hearing ifthe "bad faith" or "fiivolous" nature of an appeal is disputed, and/or
o
3)include an explicit time limit expressed in days after which a party cannot move for Rule
9
23 attorney's fees. Cf. Federal Rules of Civil Procedure, Rule 11(c), establishing certain due
10
^^ process provisions for sanctions missing from Defendants' Rule 23 {e.g., requiring that the
^2 court "describe the sanctioned conduct and explain the basis for the sanction"). Cf. also
13 Federal Rules of Appellate Procedure, Rule 38 court ofappeals determines that an
14 appeal isfrivolous, it may, after a separatelyfiled motion or noticefrom the court and
^^ reasonable opportunity to respond, awardjust damages and single or double costs to the
16
appellee''')(requiring notice and a "reasonable opportunity to respond")
17 ■■
18 COUNT 12: UNCONSTITUTIONAL VAGUENESS
19
143. "A statute can be impermissibly vague for either oftwo independent reasons.
20
First, if it fails to provide people of ordinary intelligence a reasonable opportunity to
21
understand what conduct it prohibits. Second, if it authorizes or even encourages arbitrary and
22
23 discriminatory enforcement." Hill v. Colorado, 530 U.S. 703(2000)

24
144. Defendants' Rule 23 stands virtually alone among the comparable civil
25
procedure rules of other jurisdictions because it fails to specify what kind(s) of"attorney's
26
fees" are authorized and under what occasions. It does not narrow recovery to "reasonable'
27
2g attorney's fees, which would imply a certain deterrent but not fully compensatory amount
Nor does Rule 23 distinguish on its face between attorney's fees in connection with a certain

1 "frivolous or bad-faith" pleading and that for an entire appeal case from start to finish. This
2 ambiguity encourages "arbitrary enforcement", as is currently visible to anyone aware of

3
Defendants' recent course of conduct.
4
^ 145. Comparable courts oflaw do not retain such problematic vagueness in their
6 operative rules governing sanctions for improper litigation conduct. For example,PROP 11,
7 supra, leaves no uncertainty that the monetary sanction is limited to "the reasonable expenses,
o
including attorney's fees, incurred for the motion". The language specifying the relief to be
9
granted in ERA? 38,supra, likewise leaves no ambiguity. Compare "award just damages and
10
^^ single or double costs".Id., with "award attorney's fees", N.H. Supr. Ct. R.23.
12 146. Defendants acted in concert and are jointly and severally liable for their conduct
^^ described in all foregoing Counts. As a direct and proximate result ofthereof, Maravelias has
14
suffered and continues to suffer actual harm and injury, including but not limited to the
15
expenses associated with filing this action, opportunity costs of lost time, emotional injury
16
and fear, and wrongful reputational damage.
17
18
PRAYER FOR RELIEF
19
20 WHEREFORE,PREMISES CONSIDERED,Plaintiff Paul Maravelias respectfully

21 requests this Honorable Court:
22
23 I. Enter declaratoryjudgment on all foregoing Counts in favor of Plaintiff;

24 II, Enter a permanent injunction prospectively restraining all Defendants and their
2^ officials, employees, and agents from enforcing their unlawful order against
Plaintiff issued 2/21/19 and finalized 3/29/19 in NH Supreme Court Case No.
26 2018-03^76;
27 --
III. Enter a compensatory moneyjudgment against Defendant ROBERT J. LYNN,in
28 his individual capacity, to recompense Plaintiffs proximately caused actual
damages;

1
IV. Award Plaintiff the reasonable costs, fees, and disbursements ofthis action;
2
3 V. Grant any further relief as may be deemed just and proper.
7 I, Paul Maravelias, declare that all factual stipulations within the foregoing
Original Verified Complaint are true and accurate to the best of my
8
knowledge as of5/6/2019.
9
10
11
12
Respectfully submitted.
13
14 PAUL J. MARAVELIAS,
15
in propria persona
16
17
18
19
20
/
21
i
fs/ Paul J. Maravelias. pro se Dated: May 6"^, 2019
22
Paul J. Maravelias
23
34 Mockingbird Hill Rd
24 Windham, NH 03087
paul@paulmarv.com
25 603-475-3305
26
27
28

RELIEF AND COMPENSATORY DAMAGES -29 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
EXHIBIT A
THE STATE OF NEW HAMPSHIRE
SUPREME COURT
In Case No. 2018-0376, Paul Maravelias v. David

DePamphilis,the court on November 30, 2018, issued the
following order:
The plaintiffs motion to strike the defendant's brief is denied. The

defendant's motion to transfer the record and exhibits from the trial court is
denied. The appealing party is obligated to provide the record upon appeal.
Bean v. Red Oak Prop. Mgmt., 151 N.H. 248, 250 (2004). The defendant's motion
to strike exhibits and argument that are not part of the record is granted in part
and denied in part. To the extent that the defendant seeks to strike exhibits
appended to the plaintiffs reply brief that were not admitted by the trial court,
and argument relying upon them, the motion is granted. To the extent that the
defendant requests attorney's fees in connection with the motion, the request is
denied without prejudice to the defendant moving for attorney's fees pursuant to
Supreme Court Rule 23.
Having considered the briefs and that portion of the record properly
submitted on appeal, we conclude that oral argument is unnecessary in this
case. See Sup. Ct. R. 18(1). We affirm.
The plaintiff, Paul Maravelias, appeals orders of the Circuit Court

(Coughlin, J.), following a three-day bench trial, ruling in favor of the defendant,
David DePamphilis, on his stalking petition, see RSA 633:3-a (Supp. 2017), and
awarding the defendant attorney's fees and costs. We construe the plaintiffs
brief to contend that the trial court was compelled to find in his favor on the
stalking petition and that it erred by awarding the defendant attorney's fees and
costs.
We first address whether the trial court erred as a matter of law in denying
the stalking petition. In reviewing a trial court's decision rendered after a trial on
the merits, we uphold the trial court's factual findings and rulings unless they
lack evidentiary support or are legally erroneous. O' Malley v. Little, 170 N.H.
272, 275 (2017). We do not decide whether we would have ruled differently than
the trial court, but rather, whether a reasonable person could have reached the
same decision as the trial court based upon the same evidence. Id. Thus, we
defer to the trial court's judgment on such issues as resolving conflicts in the
testimony, measuring the credibility of witnesses, and determining the weight to
be given evidence. Id. We review the trial court's application of the law to the
facts de novo. Id.
EXHIBIT A
The offense of stalking includes "[p]urposely, knowingly, or recklessly
engag[ing] in a course of conduct targeted at a specific person which would cause
a reasonable person to fear for his or her personal safety," when the targeted
person "is actually placed in such fear." RSA 633:3-a, I(a). "Course of conduct"
is defined as "2 or more acts over a period of time, however short, which
evidences a continuity of purpose." RSA 633:3-a, II(a). Such acts are not limited
to those that are targeted against the person directly, but include threats against
the targeted person's immediate family. Fisher v. Minichiello, 155 N.H. 188, 191-
92 (2007). However, such acts do not "include conduct that was necessary to
accomplish a legitimate purpose independent of making contact with the targeted
person." RSA 633:3-a, II(a).
In this case, the plaintiff based his December 2017 stalking petition upon
"three major incidents"': (1) in December 2016, the defendant made angry
telephone calls to the plaintiff and his father after the plaintiff attempted to give
the defendant's daughter a Maserati sports car for her sixteenth birthday; (2) in
March 2017, the defendant checked to ascertain whether the plaintiff was within
the vicinity of the defendant's property, drove toward the police station, and
spoke with a police officer after he received an anonymous letter, which the
plaintiff later admitted to have "aided in" composing, that excoriated the
defendant, his daughter, and her boyfriend in obscene terms; and (3) in June
2017, the defendant's daughter posted a photograph on a social media site
depicting her, her boyfriend, and the defendant making an obscene hand gesture
and captioned it "did Dartmouth teach you how to do this," a reference to the
plaintiff's alma mater. We note that the plaintiff testified that he had had no
direct contact with the defendant since December 2016.
Neither the plaintiff nor his father testified that the defendant threatened
them during the December 2016 "angry" phone calls. The plaintiff testified that
he was out of the country when the defendant received the anonymous letter and
did not learn that the defendant had searched around his house and driven
toward the police station until months after the fact. The plaintiff testified that
the defendant's daughter, and not the defendant, posted the photo and caption,
which the plaintiff had previously characterized as "puerile" and "risible." He
further testified that the only reason he saw the photo was because he was
tracking the daughter's social media sites. To the extent that the plaintiff likens
his situation to those in Fisher and State v. Simone, 152 N.H. 755 (2005), we
disagree. See Fisher, 155 N.H at 189 (stating defendant left 45 minute voice mail
message threatening plaintiff with retaliation and kept plaintiff's staff on phone
for hours); Simone, 152 N.H. at 760 (stating defendant called plaintiff up to 20
times a day and told plaintiff that he was suicidal and out of control).
The plaintiff argues that the trial court erred by finding no credible
evidence that the "three major incidents"' occurred. However, the trial court
found that he "did not provide any credible evidence of the allegations set forth in
the petition . . . that the . . . Defendant committed acts of stalking as defined
2
EXHIBIT A
under RSA 633:3-a,"(emphasis added), not that the acts themselves never
occurred. To the extent that the trial court paraphrased this finding in its order
on attorney's fees, this did not alter the original finding. Moreover, the trial court
found "that any action(s) taken by the [defendant] were reasonable and necessary
and for a legitimate purpose[,] i.e. protection of his minor daughter and family."
See RSA 633:3-a, II(a).
The plaintiff raises a number of additional arguments in his brief regarding

the denial of his petition. As the appealing party, he has the burden of
demonstrating reversible error. Gallo v. Traina, 166 N.H. 737, 740 (2014). Based
upon our review of the record, we conclude that the trial court's determination
that the acts identified by the plaintiff did not constitute stalking is supported by
the record and not legally erroneous. See O' Malley, 170 N.H. at 275.
We next address whether the trial court erred in awarding the defendant
attorney's fees and costs. Although the general rule in New Hampshire is that
parties pay their own attorney's fees, an award of attorney's fees is appropriate
when one party has acted in bad faith, vexatiously, wantonly, or for oppressive
reasons. Fat Bullies Farm, LLC v. Devenport, 170 N.H. 17, 30 (2017). When
attorney's fees are awarded against a private party who has acted in bad faith,
the purpose is to do justice and vindicate rights, as well as to discourage
frivolous lawsuits. Id.
We will not overturn the trial court's decision concerning attorney's fees
absent an unsustainable exercise of discretion. Id. To warrant reversal, the
discretion must have been exercised for reasons clearly untenable or
unreasonable to the prejudice of the objecting party. Id. We give tremendous
deference to a trial court's decision regarding attorney's fees. Id. If there is some
support in the record for the trial court's determination, we will uphold it. Id. To
the extent that the plaintiff argues that RSA 633:3-a does not authorize an award
of attorney's fees, statutory authority is not required for an award of attorney's
fees based upon a litigant's bad faith. See id.
In this case, the trial court found that the plaintiff's "stalking petition . . .
was oppressive, vexatious, arbitrary, capricious and/or in bad faith" and that the
plaintiff's "positions were patently unreasonable." Contrary to the plaintiff's
argument, attorney's fees may be awarded when the party has filed only one
action against the other party in bad faith. See Keenan v. Fearon, 130 N.H. 494,
502 (1988)(stating that court may award counsel fees in any action commenced,
prolonged, required or defended without any reasonable basis in the facts
provable by evidence, or any reasonable claim in the law as it is, or as it might
arguably be held to be). To the extent that the plaintiff argues that the trial
court's denial of the defendant's motion to dismiss at the close of the plaintiff's
case precluded its subsequent finding that the plaintiff acted in bad faith, the
standards for each determination are distinct. See Kukene v. Genualdo, 145
N.H. 1, 4 (2000)(stating denial of summary judgment does not per se preclude
3
EXHIBIT A
finding of bad faith). To the extent that the plaintiff argues that he did not act in
bad faith, based upon our review of the record, we conclude that the trial court's
determination is supported by the evidence and not legally erroneous. See Fat
Bullies, 170 N.H. at 30.
To the extent that the plaintiff argues that a $61.95 expense dated October
25, 2017, was erroneously included in the trial court's award, the defendant
waives this expense in his brief.
Any remaining issues raised by the plaintiff in his brief either are not
sufficiently developed, see State v. Blackmer, 149 N.H. 47, 49 (2003), or
otherwise do not warrant further discussion, see Vogel v. Vogel, 137 N.H. 321,
322 (1993).
Affirmed.
Lynn, C.J., and Hicks, Bassett, and Hantz Marconi, JJ., concurred.
Eileen Fox,
Clerk
Distribution:
10th N.H. Circuit Court - Derry District Division, 473-2017-CV-00150
Honorable John J. Coughlin
Honorable David D. King
Mr. Paul Maravelias
J Simon R. Brown, Esquire
Timothy A. Gudas, Supreme Court
Allison R. Cook, Supreme Court
File
4
EXHIBIT B
SUPREME COURT
In Case No. 2018-0353, State of New Hampshire v. Melissa

Ramos, the court on March 15, 2019, issued the following order:
Having considered the brief, the memorandum of law, and the record
submitted on appeal, we conclude that oral argument is unnecessary in this
case. See Sup. Ct. R. 18(1). We affirm.
The defendant, Melissa Ramos, appeals an order of the Superior Court

(Ignatius, J.) determining the amount of restitution she owes. See RSA 651:63
(Supp. 2018). She contends that the trial court erred in valuing a certain piece of
stolen property.
As the appealing party, the defendant has the burden of demonstrating

reversible error. Gallo v. Traina, 166 N.H. 737, 740 (2014). Based upon our
review of the trial court’s well-reasoned order, the defendant’s challenges to it,
the relevant law, and the record submitted on appeal, we conclude that the
defendant has not demonstrated reversible error. See id.
Affirmed.
Lynn, C.J., and Hicks, Bassett, Hantz Marconi, and Donovan, JJ.,
concurred.
Eileen Fox,
Clerk
EXHIBIT C
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
EXHIBIT D
Eileen Fox, Clerk of Court
EXHIBIT E
December 31st, 2018
New Hampshire Supreme Court
One Charles Doe Drive Paul Maravelias
Concord, NH 03301 34 Mockingbird Hill Rd
Windham, NH 03087
RE: Paul Maravelias vs. David DePamphilis

Case No. 2018-0376
Dear Clerk Fox:
Enclosed please find an original and seven copies the herein Appellant’s Objection to Appellee’s
Request for Taxation of Costs and 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.

EXHIBIT E
SUPREME COURT
NO. 2018-0376
PAUL MARAVELIAS
V.
DAVID DEPAMPHILIS
APPELLANT’S OBJECTION TO APPELLEE’S REQUEST FOR TAXATION OF

COSTS AND AWARD OF ATTORNEY’S FEES
Plaintiff-Appellant Paul Maravelias respectfully submits the within Objection and, in

support, represents as follows:
1. On 12/28/18, Appellee filed a Motion entitled “Appellee’s Request for Taxation

of Costs and the Award of Attorneys’ [sic] Fees” in this case.
2. This case itself arises from a punitive attorney’s fees award against Maravelias
for filing a truthful Stalking Petition against David DePamphilis in 2017.
3. For context, the evidence-corroborated circumstances thereof included (1)

DePamphilis’s “senseless bullying” in December 2016 “caus[ing] [Maravelias] mental
anguish” (A8) by making (2) telephone calls of such profanity and hostility to cause
Maravelias’s father Theodore to testify he “feared” for his son’s safety and felt
“threatened” (T166,182,205), (3) DePamphilis’s vulgar middle-finger social media post
with his daughter against Maravelias in June 2017, attempting to incite Maravelias to an
unlawful response by taunting him with her new boyfriend (Brief18-19;A6), (4) David
DePamphilis’s profane verbal explosion at Maravelias in the courtroom, requiring Judge
1
EXHIBIT E
Coughlin to warn David DePamphilis by penalty of criminal contempt (See Brief 33,34),
(5) DePamphilis’s wild internet libel of Maravelias, calling Maravelias a “sexual
predator” himself or through a third party (See Brief at 33, T77), among many other
frightening acts.
4. Despite all the above, this Court neither issued a final protective order nor
even reversed the trial court’s shocking award of attorney’s fees, itself granted by a
judge (Hon. John J. Coughlin) whose automatic, prejudicial bias against Maravelias
has been extensively documented. See 10/31/18 Motion to Set Aside Judgement,
A115 in Appendix of Defendant’s Brief in No. 2018-0483.
5. Appellee now advances a request for attorney’s fees in this appeal case.
Appellant objects to this idiosyncratic request of David DePamphilis, who has continued
to victimize and harass Paul Maravelias and his family since the filing of the petition.1
6. Maravelias’s challenge in this appeal to the underlying fees award was

meritorious in its validity as a legal claim and compellingly necessary, regardless of this
Court’s subsequent unwillingness to reverse.
7. Per N.H. Sup. Ct. R. 23, this case does not approach the “extreme”
circumstances required for an award of attorney’s fees at the appellate level. Further,
DePamphilis’s request for taxation of costs should be denied as well, since the instant
appellate litigation addressed an important question of public policy (i.e., stalking
victims’ liability for potential legal costs in connection with seeking court relief) and was
doubtlessly a good-faith attempt to restore over $9,000 an impecunious 22-year-old
believed was extorted from him by a rich 49-year-old Executive COO who owns two
opulent homes and five cars: David DePamphilis, who has, besides his alleged stalking
1
For example, David DePamphilis has recently pioneered a campaign to humiliate and defame
Maravelias’s younger teenage sister. As a 49-year-old man, David DePamphilis recently
solicited communications with multiple teenage girls at Windham High School and exhorted
them to “not be friends” with Maravelias’s 17-year-old sister in a cruel attempt to sabotage her
social life out of bitter filial envy.
2
EXHIBIT E
acts, persisted in a bitter campaign of legal abuse and harassment of Mr. Maravelias due
to resentful filial envy.
8. While Maravelias composed all briefs and pleadings in this case by himself with
zero outside assistance, he did consult with at least one New Hampshire practicing
attorney before initiating the appeal. Maravelias was advised that his appeal was
meritorious, that the trial court’s award of fees was stunningly unexpectable, and that a
“one-bite” rule always applied in this attorney’s experience where, even if an actor does
once act in bad faith, punitive fees award should only follow a sustained course of
conduct. Maravelias, on the other hand, never once acted in bad faith.
9. Given his lawyer’s blessing, Maravelias pursued this appeal in good faith,
righteously indignant that his funds had been judicially stolen from him by David
DePamphilis – the same man who excogitated a malvagious scheme to reduce Maravelias
under the tyranny of a false stalking restraining order for vindictive harassment purposes
in 2016, absent any and all circumstances of actual stalking. See No. 2018-0483.
10. Although DePamphilis’s new motion for award of attorney’s fees in this
appellate case does not warrant further discussion and is totally groundless, Maravelias
addresses it in further detail to serve the interest of thoroughness.
A. DePamphilis’s Motion Either Misquotes the Trial Court’s Order or Proves

That Maravelias’s Argument Was Correct About the Trial Court Having
Blindly Ignored the Facts in Prejudice of Maravelias
11. On Page 2 of his Motion, DePamphilis quotes Judge Coughlin’s Order

appending a full-stop period after the words “did not provide any credible evidence of the
allegations as set for in the Petition.” This contradicts this Court’s 11/30/18 Order which
defended Judge Coughlin’s Order by stipulating that this clause was qualified by the
ensuing “that the … Defendant committed acts of stalking as defined under RSA 633:3-
a” phrase. See 11/30/18 Order at 2-3.
3
EXHIBIT E
12. In other words, since Maravelias did corroborate his true accusations with
physical evidence and only generated legal dispute about the legal significance of his
accurate factual allegations, his truthful conduct cannot be construed as misleading or
made in bad faith, as DePamphilis’s Motion deceptively attempts to argue.
13. DePamphilis’s Motion, however, does usefully elucidate the injustice that
Judge Coughlin did, in fact, intend to suggest Maravelias had provided “no credible
evidence” that his “allegations” even occurred; indeed, this is what all parties understood
the trial court to mean. DePamphilis’s Motion therefore aids Maravelias’s argument that
Judge Coughlin has habitually disfavored Maravelias through fact-amnestic blindness,
undermining both the affirmed and the now-sought requests for award of attorney’s fees.
B. Appellee DePamphilis Persists in Bold Falsity to Accentuate His New Request

for Appellate Attorney’s Fees with the False Semblance of Reasonableness
14. Appellee and his counsel have persisted in unethical misrepresentation

misconduct in the 12/28/18 Motion. Maravelias invites The Honorable Court to review
his 12/10/18 letter sent to Attorney Brown warning him to cease and desist the unethical
falsity misconduct, attached to Maravelias’s 12/17/18 Objection in Case No. 2018-0483.
(i) Maravelias’s 10/9/18 Motion to Strike was Necessary, Correct, and

Insufficiently Contested by DePamphilis
15. Maravelias filed a Motion to Strike in this case, accurately noting that
DePamphilis’s Brief 1) violated some of the new formatting requirements set forth in the
2018 updated rules and, far more significantly, 2) mysteriously blurred his own text
messages in an appendical exhibit while leaving the interlocutors’ contents plainly legible
at different parts within the same screenshot images.
4
EXHIBIT E
16. DePamphilis dishonestly contradicts himself at Paragraph at 18 of his Motion,
asserting Maravelias’s above claims “lacked any merit or factual basis”, although
DePamphilis himself conceded “admittedly, the [text messages were] smudged in places,
obscuring some of the messages” in Paragraph 5 of his 10/22/18 Objection to Appellant’s
Motion to Strike. Further, this Court may behold with its own eyes the strangely specific
obfuscation which appears at strategic-seeming locations throughout APP38-47 of
DePamphilis’s Appendix.
17. Disturbingly, Appellee DePamphilis never offered any explanation

whatsoever for Maravelias’s forensic analysis suggesting foul-play (See 10/9/18 Motion
to Strike at Paragraph 13), including obvious rasterization artifacts and the irregular
nonexistence of blurring on what would appear to be a single strategically desirable page.
18. That Maravelias’s Motion to Strike was meritorious and truthful is beyond
dispute, even by DePamphilis’s own admission in his 10/22/18 Objection. DePamphilis
continues his unmitigated habit of bold dishonesty when claiming Maravelias’s Motion to
Strike “claims lacked any merit or factual basis” (Motion¶18).
(ii) Maravelias Did Not Introduce Four (4) Non-Record Exhibits, As

DePamphilis Knows Yet Still Falsely Claims
19. DePamphilis claims that Maravelias “improperly included four (4) exhibits
that were not part of the record” to his Reply Brief. (Motion¶20)
20. While one exhibit (Reply Brief Appendix, A6) was arguably non-record,
DePamphilis exaggerates and invents rulings which this Court never, in fact, made.
DePamphilis claims this Court “granted DePamphilis’s Motion to Strike these exhibits
[plural]” at Paragraph 22. However, this Court’s 11/30/18 Order partially granted
DePamphilis’s Motion only insofar “to the extent that [exhibits were appended] that were
not admitted by the trial court”.
5
EXHIBIT E
21. Since DePamphilis cites a second and third exhibit (A34,35) which were
unquestionably part of the trial court’s record (to wit, Maravelias’s signed 4/13/18
Objection to Respondent’s Brief on Motion for Award of Attorney’s Fees, A14-35), his
claim of plural “improper exhibits” is false.
22. DePamphilis’s Motion fails to specify what the fourth alleged non-record
exhibit was, unsurprisingly, because there was none.
23. DePamphilis regurgitates the argument that, since the trial court had not
accepted a certain photograph as a primary exhibit at trial, the said exhibit became
eternally prohibited from being appended as a relevant exhibit in a later legal pleading
when newly necessary within the subsequent attorney’s fees litigation two months after
the underlying stalking trial and related evidentiary ruling therein. Maravelias has already
responded to DePamphilis’s unfounded argument.
24. Appellee DePamphilis knows that Maravelias did not include four (4) non-
record exhibits, and that only one of the exhibits was arguably non-record. This
constitutes yet another example of his misrepresentation misconduct in the place of
legitimate legal argumentation.
(iii) Other False and/or Misleading Statements
25. Appellant Maravelias dialectically tabulates other outrageous content of

DePamphilis’s 12/28/18 Motion as follows:
DePamphilis’s
Maravelias Response
Statement
“for stalking Mr. False and irrelevant.

DePamphilis’s Maravelias never remotely “stalked” DePamphilis’s
teenage daughter, daughter, nor ever interacted with, communicated with,
6
EXHIBIT E
Christina nor even saw her after a 12/12/16 romantic rejection,
DePamphilis” (¶10) which was the first and only time Maravelias had
expressed interest to her.
See Case No. 2018-0483, including the “Statement of

Facts” section of Maravelias’s Brief therein, reviewing
the history of DePamphilis’s excruciating falsity in
slandering Maravelias a “stalker”. Since Paul
Maravelias is a respectable gentleman and honorable
eldest son, it has nourished David DePamphilis’s
resentful envy to calumniate Maravelias with falsified
legal abuse bearing the “stalking” nomenclature.
Maravelias never threatened “retaliation” other than

civil litigation for defamation and abuse of process if
DePamphilis’s stalking order abuse against Maravelias
came to fruition. Maravelias’s personal-safety-oriented,
truthful stalking petition had nothing to do with his
“Maravelias had
hereunto-mercifully-unfulfilled threat to sue Christina
vowed legal
DePamphilis on or before December 27th, 2019 for libel,
retaliation if a
slander, misrepresentation, false imprisonment, false
stalking order was
light, IIED, abuse of process, attempted and/or actual
entered against
conversion, and/or other torts which she has committed
him” (¶11)
against Maravelias in her self-professed empowered
feminist “independency” [sic]. See Brief, 38-39.
It is David DePamphilis who has threatened illegitimate

stalking restraining order litigation as a form of
7
EXHIBIT E
malicious retaliation against Maravelias. On 12/23/16,
after Maravelias texted DePamphilis to “stop harassing
[Maravelias’s] parents”, DePamphilis texted
Maravelias’s parents saying, “that’s the last straw”, and
promising he would now take “legal action”. Although
Maravelias at that time hadn’t interacted with
DePamphilis’s daughter since the rejected dinner
invitation 11 days prior, the threatened legal retaliation
David promised turned out to be an absurd stalking
petition regarding DePamphilis’s daughter, not David, 5
days thereafter on 12/28/16.
See Brief, 15-16; A8. See also Reply Brief, 15;

Defendant’s Brief in 2018-0483, 12
True but irrelevant. Christina DePamphilis’s vulgar

and sexual activities, which she has openly documented
“repeatedly calling on public social media and even bragged about, became
Christina necessary to reference on a few occasions to strengthen
DePamphilis vulgar Maravelias’s pertinent legal arguments. For an example
and sexually- of a pertinent legal argument Maravelias needed to
charged names” make in his self-defense which necessarily referenced
(¶11) Christina DePamphilis’s self-documented 16-year-old
vulgar and sexual activity, see top of Page 23,
Defendant’s Brief in No. 2018-0483.
“establishing False. Paul Maravelias’s book webpage at

webpages davidtheliar.com merely accomplishes its purpose 1) to
8
EXHIBIT E
denouncing Mr. provide information about his eponymous philosophical
DePamphilis” (¶11) book and 2) post public legal documents/legal updates
regarding DePamphilis’s perjury-fueled legal
persecution of Paul Maravelias.
By now, the falsity of DePamphilis’s legal abuse has

been manifoldly documented by an audio recording, a
happenstance video recording from 2013, his own
daughter’s harassing social media conduct against
Maravelias, and a host of other now-exposed facts,
including his daughter’s rampant lying under oath. See
Defendant’s Brief in 2018-0483, 23-25.
It is DePamphilis who has slandered Maravelias on the

web, baselessly libeling Maravelias a “sexual predator”
himself or through a third party. See Brief at 33, T77.
Maravelias has never been remotely accused of any act
by anyone which would even approach warranting this
defamatory-per-se characterization.
WHEREFORE, for the reasons hereinabove set forth, Plaintiff-Appellant Paul

Maravelias respectfully requests this Honorable Court:
1) Deny Appellee’s 12/28/18 Motion;

2) Deny Appellee’s 12/28/18 request for taxation of costs2;
2
For increased convenience in the event this Court does approve granting DePamphilis’s $65.45
brief-printing cost, Maravelias certifies he has included $3.50 with this pleading as mailed to
Appellee, which covers this $65.45 cost less the $61.95 awarded expense, already erroneously
paid, which Defendant has waived.
9
EXHIBIT E
3) Deny Appellee’s 12/28/18 request for award of appellate attorney’s fees; and
4) Grant any further relief as shall be deemed just and proper.
Respectfully submitted,
PAUL J. MARAVELIAS,
in propria persona
____________________________________
Dated: December 31st, 2018
CERTIFICATE OF SERVICE
I, Paul Maravelias, certify that a copy of the foregoing Appellant’s Objection to

Appellee’s Request for Taxation of Costs and Award of Attorney’s Fees was sent on this
day via first-class mail, postage prepaid, to Simon R. Brown, Esq., counsel for the
Defendant-Appellee, David DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.
December 31st, 2018 __________________________________
10
EXHIBIT F
Simon R. Brown, Esq. December 10th, 2018
Preti, Flaherty, Beliveau & Pachios, LLP
PO Box 1318 Paul Maravelias
Concord, NH 03302-1318 34 Mockingbird Hill Rd
Windham, NH 03087
VIA E-MAIL AND FIRST-CLASS MAIL
RE: New Hampshire Rules of Professional Conduct vis-à-vis

Representation in Christina DePamphilis v. Paul Maravelias, etc.
Dear Attorney Brown:
I write to remind you of certain New Hampshire Rules of Professional Conduct incumbent
upon you as a practicing attorney admitted to the New Hampshire Bar. At this point in time, it is
my intention solely to offer you a good-faith reminder of these rules and respectfully demand
your future compliance therewith.
I reference the following rules:
Rule 3.1. Meritorious Claims and Contentions

A lawyer shall not bring or defend a proceeding, or assert or controvert an issue
therein, unless there is a basis in law and fact for doing so that is not frivolous,
which includes a good faith argument for an extension, modification or reversal of
existing law. …
Rule 3.3. Candor Toward the Tribunal

(a) A lawyer shall not knowingly:
(1) make a false statement of fact or law to a tribunal or fail to correct a false
statement of material fact or law previously made to the tribunal by the lawyer;
(2) fail to disclose to the tribunal legal authority in the controlling jurisdiction
known to the lawyer to be directly adverse to the position of the client and not
disclosed by opposing counsel; or
(3) offer evidence that the lawyer knows to be false. If a lawyer, the lawyer’s
client, or a witness called by the lawyer, has offered material evidence and
comes to know if its falsity, the lawyer shall take reasonable remedial
measures, including, if necessary, disclosure to the tribunal. A lawyer may
1
EXHIBIT F
refuse to offer evidence, other than the testimony of a defendant in a criminal
matter, that the lawyer reasonably believes is false.
Rule 3.4. Fairness to Opposing Party and Counsel

A lawyer shall not:
(a) unlawfully obstruct another party’s access to evidence or unlawfully alter,
destroy or conceal a document or other material having potential evidentiary
value. A lawyer shall not counsel or assist another person to do any such act;
(b) falsify evidence, counsel or assist a witness to testify falsely, or offer an
inducement to a witness that is prohibited by law;
(c) knowingly disobey an obligation under the rules of a tribunal except for an
open refusal based on an assertion that no valid obligation exists; …
(e) in trial, allude to any matter that the lawyer does not reasonably believe is
relevant or that will not be supported by admissible evidence, assert personal
knowledge of facts in issue except when testifying as a witness, or state a
personal opinion as to the justness of a cause, the credibility of a witness, the
culpability of a civil litigant or the guilt or innocence of an accused;
Rule 4.1. Truthfulness in Statements to Others

In the course of representing a client a lawyer shall not knowingly:
(a) make a false statement of material fact or law to a third person; or
(b) fail to disclose a material fact to a third person when disclosure is necessary
to avoid assisting a criminal or fraudulent act by a client, unless disclosure is
prohibited by Rule 1.6.
2004 ABA Model Rule Comment

RULE 4.1 TRUTHFULNESS IN STATEMENTS TO OTHERS
Misrepresentation
[1] A lawyer is required to be truthful when dealing with others on a client’s

behalf, but generally has no affirmative duty to inform an opposing party of
relevant facts. A misrepresentation can occur if the lawyer incorporates or affirms
a statement of another person that the lawyer knows is false. Misrepresentations
can also occur by partially true but misleading statements or omissions that are
the equivalent of affirmative false statements. For dishonest conduct that does not
amount to a false statement or for misrepresentations by a lawyer other than in the
course of representing a client, see Rule 8.4.
Statements of Fact
2
EXHIBIT F
[2] This Rule refers to statements of fact. Whether a particular statement should
be regarded as one of fact can depend on the circumstances. Under generally
accepted conventions in negotiation, certain types of statements ordinarily are not
taken as statements of material fact. Estimates of price or value placed on the
subject of a transaction and a party’s intentions as to an acceptable settlement of a
claim are ordinarily in this category, and so is the existence of an undisclosed
principal except where nondisclosure of the principal would constitute fraud.
Lawyers should be mindful of their obligations under applicable law to avoid
criminal and tortuous misrepresentation.
Rule 8.4. Misconduct

It is professional misconduct for a lawyer to:
(a) violate or attempt to violate the Rules of Professional Conduct, knowingly

assist or induce another to do so, or do so through the acts of another; …
(c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation;
… or
(f) knowingly assist a judge or judicial officer in conduct that is a violation of
applicable rules of judicial conduct or other law.
With all due respect, some of your conduct in relation to these rules has been disturbing.
Since you are an intelligent person, I need not enumerate every single instance of your conduct
which would appear to violate these rules. Rather, I shall illuminate a few salient examples and
entrust the identification of similar acts to your imagination.
A. Groundless, Robotic Demands for Attorney’s Fees in Response to Lawful,

Necessary, and Legitimate Adversarial Conduct
The most recent manifestation of unprofessional conduct, doubtlessly the sine qua non of
this letter, has been your predictable plea for punitive attorney’s fees appended to nearly every
response to any and all pleadings I might enter into any ongoing case. This behavior has been
noted not only in the appellate cases, but also within the above-referenced Derry trial court case,
wherein I am not even the movant, but the defendant. My pleadings are completely legitimate
and necessitated by your client’s bad-faith, falsification-fueled legal pursuit of me; accordingly,
such requests are baseless. As I remember, the first instance of this behavior traces back to your
April 2018 response to my necessary, legally meritorious, and indeed correct Motion to Dismiss
and Vacate Stalking Order, on which the incompetent laughing-joke-of-a-court in Derry never
ruled.
3
EXHIBIT F
Most recently, you rehearsed such a petty prayer at the end of your objection to my Motion
for Recusal and Reconsideration, likewise a necessary, valid motion containing high-quality
argumentation, supported by a potpourri of uncontested facts, necessary to preserve fairness and
integrity in these proceedings.
You are aware that such requests for attorney’s fees are valid in response solely to frivolous
conduct, not to weighty legal arguments necessary for the defense of my basic rights and
property. Given the tyrannical acts of injustice the rogue Judge Coughlin will evidently do to me
upon an unsupported accusation of “bad-faith” conduct, I interpret your routinely unsuccessful
prayers for undue fees in this case as coercive threats against my financial property. I refuse to
cower to such threats which have as their object that I should surrender my legal self-defense,
allowing your client to traduce my good name and assault my constitutional rights without
opposition.
Abetting the pursuit of false, vindictive “stalking” restraining order litigation against an
innocent young man and then treating said defendant’s attempts at legal self-defense as
automatic “frivolous” behavior is gaslighting, not permissible attorney conduct. It is without any
legitimate purpose and is a continuation of the familiar gaslighting tactics waged against me by
your client. It differs from professional attorney conduct. In the latter, a lawyer focuses on
contesting the legal arguments proposed in the opponent’s pleadings. If you disagree with my
reasoned legal arguments, I welcome you to challenge them in your responsive pleadings.
By authority of Professional Conduct Rule 3.1, demand, thus, is made that you cease and
desist including such prayers for such relief in your pleadings, themselves frivolous, unless made
in response to truly “frivolous” conduct (e.g., conduct wherein the opposing party petitions the
Court to grant relief for which there is no arguable basis in the law). In contrast to frivolous
conduct, I exactingly cite the legal authorities by which I am entitled to the requested relief in all
my pleadings entered in either Court.
B. Willful and/or Negligent Mischaracterizations of Fact
Repeating your client’s testimony favorable to your position and falsely representing the
record are distinct practices. Moreover, repeating assertions later proven by tangible evidence to
have been complete falsehoods constitutes misconduct for two separate reasons: 1) because the
underlying representation comes to be known by you to be false, and 2) because it abets in the
continued commission of a crime (see RSA 641:1, 641:2, 641:3, and 173-B:3, IV.)
As a generic warning, Rules 3.3, 3.4, and 4.1 prohibit you from composing shockingly
partisan, incomplete, and frequently outright-dishonest Statement of Facts sections, such as those
found in both of your opposing briefs in the two appellate cases. Nearly every sentence you have
4
EXHIBIT F
written in such sections presents a fact which I directly contradict somewhere in the record,
though you persistently neglect to present the opposing testimony. You have even asserted
unsupported facts within the questions-presented and argument headings of your briefs. Worse,
at times, my contradictions have taken the form of incontrovertible physical evidence seen and
understood by you. These examples would be the most likely to land you in hot water.
In general, I would refer you to the following excerpt from A Guide to Appellate Advocacy
in New Hampshire (Lisa Wolford, Esq. & Stephanie Hausman, Esq., 2014):
“It is not wise, however, to omit facts that are relevant but not helpful to your case,
because your opponent will invariably expose the omission. Similarly, it will not
help your case to mischaracterize or misstate the facts by presenting them in a manner
that unfairly favors your case or unfairly disfavors your opponent’s. To do so
compromises your credibility before the Court.”
I offer a few specific examples, starting with the lie about your client’s female child feeling
“scared” at a party at my house 5 years ago. Let us assume you believed the accusation from the
2016 stalking petition and had a reasonable good-faith belief that it was true. At the 5/3/18
Hearing, precisely at 1:25:48 in the recording (https://youtu.be/ErHhybEI_3w?t=5145), upon
your initial seeing my casual photograph from that same party, you witnessed the laughable
spectacle of how vastly contrary reality actually is compared to your client’s delusional and/or
perjurious representations thereof.
You made a smiling, laughing, tongue-in-cheek expression upon discovering yet another
indication of your clients’ rabid falsity, as if such revelations have become frequent sources of
entertainment for you, doubtlessly similar to unseen reactions you must have had to the Turkey
Trot video, to my parents’ letters revealing the exculpatory content of my audio recording, to
images of your client’s female daughter’s wild/licentious/intemperate behaviours, or to the June
2017 middle-fingers menagerie, inter alia. During cross, you attempted to twist my self-
defensive exposition of your client’s perjury somehow to your advantage by insinuating I was
“secretly taking photos” of your then “12-year-old” client. But the record reflects I contradicted
this, stating, “Without her knowledge? I had the camera right there. She can see that I’m take –
snapping pictures around my [own summer family] party [at my house].” (T449)
Despite knowing of the falsity of the underlying accusation, and despite knowing that the
photo was not “secret” or “surreptitious”, you went ahead and called it just that on Page 9 of
your opposing brief.
Similar characterizations repeating the now-documented perjury that I “approached”

David’s female child at the 2013 Turkey Trot, “made her scared”, and “wanted to walk with her”
are dangerous acts of misconduct for you, since you watched the video and observed the
incontrovertible proof of your clients’ extreme falsity, in that instance even ten-times more
5
EXHIBIT F
severe than the 2013 party lie.1 Repeating the audio-recording-documented falsehood that
“Maravelias told her he would return when she was 18” on Page 10 of your brief, even when
your client admitted that I did not say those “direct” words (T95), and when I testified multiple
times to never saying this, is treading on thin ice.
At times, your false representations of fact wander into such territory of indefensible
exaggeration or distance from even the words of your own client that you open yourself to civil
defamation liability beyond the scope of the Professional Rules of Conduct. Examples include
“recruited his sister” (Page 9), insinuating the heretofore-unseen delusion that there was
“mediation” (Page 10) between my parents and your client in 2016 after your client’s female
child attended another party at my house, claiming-anew that there “had been no recent contact
[prior to 12/12/16]” (Page 10, see T276), attributing to me, baselessly, the attachment of “social
media posts” to a letter I did not write (Page 40), claiming that I “made or possessed recordings
of [David’s female child] without her knowledge since she was 12 years old” (Id.) (a reference to
my sister taking a video on her cell-phone of an outdoor sporting event), etc.
This conduct does not reflect upon the integrity of your profession, nor the diligence
expected by the Bar Association of all its practicing attorneys. The misrepresentation-conduct
mentioned above is merely the tip of an iceberg that is doubtlessly violative of the rules I have
cited.
You may in some cases retort, and it might possibly be, that honest human error caused
prejudicial misrepresentations which you objectively would have known were false, such as
inverting the temporal order of my 12/8/17 stalking petition against David DePamphilis and my
12/15/17 false, annulled arrest in the third paragraph of your 3/27/18 trial court pleading replying
to my objection, or telling the court first that you heard about my recording motion “five minutes
ago” (T6:9, in Maravelias v. DePamphilis), at “8:01am” that day (T12:9), then shortly thereafter
admitting that you were given telephonic notice the prior day (T12:11), where the timeliness of
notice was a material issue. Instances like these might actually concern honest human errors on
your part, although, combined with the larger portion of misrepresentation conduct which is
doubtlessly negligent and reckless, they are not helpful for you.
C. Unhinged Inventions of Baseless Calumnies Not Even Alleged by Your Client
As far as I can remember, your client’s female child has never been my “family or
household member”, nor my “current or former sexual or intimate partner” (thank God). I do not
1
You even claimed the video “depicted only the face of Maravelias’s sister” (Page 10), when the
Supreme Court was given the video and can see for themselves that both the face of your client’s
female child and myself appear in the video.
6
EXHIBIT F
recall anyone ever accusing me of “abuse” or bringing an RSA 173-B Domestic Violence
restraining order petition against me.
Despite this, you have persisted in libelous, patently unreasonable conduct, quoting RSA
173-B:5, I. on Page 41 of your opposing brief in a deceptive attempt to fool the Supreme Court
into equating putative acts of my third-party speech exposing your client’s female child’s
documented criminal, harassing, and bullying behavior against me with “abuse” of her. This
cowardly absurdism violates Professional Conduct Rules 3.1 and 3.3, and likely others. Your
misconduct is willful and reckless, as you had already libelously accused me of “abuse” in your
7/2/18 Motion to Criminalize Paul Maravelias Possessing a Computer Screenshot of My Client
Middle Fingering Him with Her 21 Year Old Boyfriend After She Lied About Having ‘Fear’ and
Got a False Stalking Order Against Him, and I had already corrected your, at best, groundless
legal error in my 7/5/18 objection (A164) by the time you renewed this libel months later on
11/21/18.
Even the “abuse” antics and the estopped, self-contradicting “obsession” sophistries do not,
of course, exceed in severity of misconduct the good old “likely sexual assaulter” dirt from last
year – an accusation likewise alleged nowhere in the record even by your expert slanderer client,
nor by his female child. I will not forget Mr. Samdperil’s outraged reaction to this pathetic
vituperation of yours against my august personal dignity. Indeed, two years have not elapsed
since this shameful act of unsupported misrepresentation somehow found its way into a legal
document bearing your signature, and, thus, bearing your entire professional reputation, itself in-
the-works for longer than I have been alive.
When are you not straining compliance with these rules, it is a true pleasure to litigate with
you. I am a great admirer of your courtroom personality. I have reciprocated your (outside-of-
legal-content) interpersonal gentility far more than your hurtful slander would warrant. I imagine
you have been increasingly frustrated throughout the course of representing David DePamphilis
and his female child in his legal pursuit of me. In fairness, your noticeable frustration is quite
understandable, given their subsequent reckless behaviors and now-documented falsity, of which
you could have had little knowledge in Spring 2017. I sympathize that they have made your job
quite difficult. I encourage you, however, not to permit this understandable, noticeable
frustration of yours negatively affect the professionalism of your conduct.
Kind regards,
Paul J. Maravelias
7
EXHIBIT G
SUPREME COURT
NO. 2018-0483
CHRISTINA DEPAMPHILIS
V.
PAUL MARAVELIAS
APPELLANT’S MOTION FOR RECONSIDERATION
Defendant-Appellant Paul Maravelias respectfully submits the within Motion for

Reconsideration pursuant to Rule 22 and represents as follows:
1. Supreme Court Rule 22(2) states: “The [motion for reconsideration] shall state
with particularity the points of law or fact that … the court has overlooked or
misapprehended and shall contain such argument in support of the motion …” The
Court’s 1/16/19 Order overlooked and/or misapprehended the following points of fact
and law.1
A. While Unctuously Blandishing the Trial Court’s Libel that Maravelias

Caused “Reasonable Fear”, This Court Willfully Ignored and Did Not Once
Mention Maravelias’s Primary Defense that Fearless Christina DePamphilis
Incitatively Cyber-Bullied Maravelias on her Public Social Media with
Vulgar Middle-Finger Gestures, With Her Boyfriend
1
Maravelias does not take it personally that this Court injuriously libels him. Given this Court’s other
shocking ruling in 2018-0376, affirming a punitive fees award against Maravelias claiming “the record
supported” he acted “in bad faith” but without making one single citation to any such a part of the record,
Maravelias understands his mere existence as a competent non-lawyer party aggravates this Court.
Maravelias regrets he irks this Court’s noted ideological feminist objectives as reviewed in this document.
Nor could Maravelias note Judge Coughlin’s misconduct through objective factual analysis without
offending the old-boys’-club of bar-admitted judges and attorneys of which Maravelias is not a member.
1
EXHIBIT G
2. In its current form, this Court’s Order signals the New Hampshire public to the
following alarming reality of our judiciary system:
a. A female can come to court and file a “stalking petition” against a guy who
asked her out to dinner two-weeks prior (Maravelias), and never spoke to
her again thereafter. (T27,28,35-36,451:17-18)
b. After complaining of “fear” and obtaining a Final Order, she can publicly
bully her alleged “stalker” with jealousy-inducing provocations from her
boyfriend on social media (A13), and two days later – failing to elicit any
restraining order violation – up-the-ante with an insulting, vulgar middle-
finger taunting post showing her father approving of her boyfriend.
(A11;Brief21,22)
c. The female can then extend the protective order another year, even though
the alleged “stalker” never once violated the “protective” order, and despite
his vociferous pleadings about her fearless bullying him – indicative of
malicious legal abuse, but not of any legitimate need for “protection”.
d. Then, the alleged “stalker” can appeal the extension by himself, pro se,
writing a Brief containing the following giant heading intentionally placed
into the Brief’s high-visibility positional limelight:
“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”
e. Then, the New Hampshire Supreme Court will completely ignore and not
even mention Plaintiff’s outrageous, bad-faith behavior anywhere at all in
its Order rejecting Defendant’s argument of abuse of discretion.
2
EXHIBIT G
3. Perhaps this Court is comfortable disclosing its current misandrist modus operandi
to the public in such a conspicuous fashion. However, Maravelias respectfully urges the
Court to reconsider its 1/16/19 Order which overlooked the end-all-be-all facts of
Christina DePamphilis’s public vulgar harassment of Maravelias, showing 1) she does
not, nor ever did, have any “fear” of Maravelias, and that 2) there was zero evidentiary
support sustaining the trial court’s finding of “good cause” to extend a “protective” order
which DePamphilis baited Maravelias to violate, satisfying the legal standard for
reversal.
4. Christina DePamphilis, as if subject to some sort of Jezebelian demonic

possession, committed inexplicable cruelty against Maravelias in her provocative social
media bullying of him, silent-months after he respectfully invited her to dinner, was
rejected, and never spoke to her again, and then was branded a “stalker” based on
disproven lies. Her conduct was intentionally directed to Maravelias (T74,76) and
guaranteed to reach him by commonality of Windham acquaintances/family members
regularly viewing said public social media sites.
B. This Court Tries to Have it Both Ways While Noting in 2018-0376 that David
DePamphilis Did not Personally “Post” the Vulgar, Incitative Bullying Post
Because His “Daughter” Did, but Then Completely Omitting Any and All
Mention Thereof in Its Obligatory Screw-Maravelias Order Here, Where
Said Conduct Was Even More Legally Significant in This Case
5. Maravelias and the public understand that, as a legal attribute of appellate review,
the Supreme Court “view[s] the evidence in the light most favorable to the plaintiff”.
Fisher v. Minichiello, 155 N.H. 188, 190 (2007). But the Court routinely presents an
objective summary of the facts/evidence of the case in its Orders before engaging legal
analysis (“viewing”) thereof.
6. In its 1/16/19 Order, the Court attacks Maravelias with three-and-a-half pages (p.
3-7) of one-sided factual rehearsals dramatically slanted to disparage Maravelias and, at
times, outright mischaracterizes the record (See infra), while never mentioning once – not
3
EXHIBIT G
a single time – Maravelias’s admitted evidence/facts favorable to his legal positions2,
chief among them Christina DePamphilis’s reckless incitative harassment and bullying.
7. In its Final Order in Paul Maravelias v. David DePamphilis (2018-0376), the

Court noted that “[DePamphilis’s] daughter posted a photograph … making an obscene
hand gesture and captioned it … [as to] reference to [Maravelias] … the defendant’s
daughter, and not the defendant posted the photo and caption”.
8. The public inevitably notes the following. In one appeal involving the parties, this
Court insulated lawyer-represented David DePamphilis by blaming his daughter alone
for the act, apparently exculpating David of his participation. But in the other related
appeal, this Court adopts the perennial feminist tactic of simply ignoring facts which hurt
one’s feelings, not even mentioning the said facts anywhere, even as these facts were
more essential to Maravelias’s appeal in this case.
9. Having nervously skirted the giant elephant in the room – Christina DePamphilis’s
wild harassment of Maravelias, not the reverse – the Court later reminds in its Order that
nobody “has [a] First Amendment right to inflict unwanted and harassing contact on
another person” while rejecting Maravelias’s as-applied constitutional challenge. State v.
Mott, 692 A.2d 360, 365 (Vt.1997). The Court legally errs to rhetorically crucify
Maravelias for “aiding in the composition” of a nasty letter not sent to the Plaintiff (itself
a vast “exaggeration” of his involvement, See T401-403), and for his stern response to
Attorney Brown’s outrageous legal threat – also not to the Plaintiff – while
simultaneously failing to hold the female Plaintiff accountable whatsoever for her brazen
acts of “unwanted and harassing contact” pointedly directed against Maravelias, by
omitting even the slightest mention of her conduct.
10. Maravelias is content if this Court chooses not to revise its Order, and accordingly
renders all-the-more facile Maravelias’s efforts for the New Hampshire public to expose
2
This Court’s Order does partially address Maravelias’s abstract legal arguments, but totally ignores all
his supremely relevant facts and arguments pertaining to Christina DePamphilis’s malicious conduct,
documented falsity, and self-portrayed lawbreaking, as detailed infra.
4
EXHIBIT G
its highest court’s present ideological modus operandi. However, Maravelias respectfully
urges the Court to reconsider.
C. Page 8 of the Court’s Order, the Logical Crux of its Affirmation, Makes
Gaping Legal Errors and Gigantic Jumps of Reasoning Which Do Not Follow
The “Sole Purpose” Finding
11. With all due respect to The Honorable Court, the central legal argument of its
Order makes no sense. All aspects of the Court’s affirmation are logically predicated
upon its principal finding: “Based upon this course of conduct, the trial court reasonably
found that the defendant’s ‘sole purpose’ in writing, or aiding in writing, the letters and
email was to further stalk and harass the plaintiff.”
12. This finding is factually unsupportable, legally erroneous, and logically defective:
a. The “purposes” of Maravelias 1) private-email-to-close-mentor and 2)

solicited response to a legal threat letter are implicitly self-defensive, valid
“purposes” of 1) reporting misconduct while protecting one’s reputation to
esteemed mentors (T419,421-422) and 2) deterring a lawsuit, respectively.
b. Assuming it were logically possible to additionally impute a purpose of

“stalking and harassment” to said honorable communications, it would
surpass insanity to uphold Judge Coughlin’s amplified verbal posturing that
those were the “sole purposes”, as if 1) edifying one’s close mentor about a
believed-criminal in her honor society and 2) responding to a legal threat
letter to deter litigation are not themselves “purposes”, regardless of
whether or not they are “legitimate” purposes.
c. Further, the record indicates it is impossible to impute any “purpose” of

“stalking and harassment” beyond the communications’ patently legitimate
purpose(s), since Maravelias had no intention nor expectation that plaintiff
would ever discover said communications (T406-407,422); he even
5
EXHIBIT G
explicitly demanded confidentiality in his private email (A92). The March
2017 letter’s author did similarly (A79), regardless of the weak extent of
Maravelias’s collaboration with her.
13. Declining to correct this Court’s “sole-purpose” finding – a necessary foundation

to all its subsequent affirmation-reasoning – would titillate the New Hampshire public to
know their high-court esteems the act of sending a private email to one’s mentor warning
of subordinate misconduct constitutes an unlawful “sole purpose of stalking and
harassing” said uncontacted female malefactor, whose underage drinking conduct – at the
very least – is manifest in one of Maravelias’s admitted-though-ignored exhibits3
(A18;T371,372).
14. There is no distinguishing factor here which would not apply this Court’s same
conclusion to any email – private or public – sent by anyone to any supervisor
complaining of any subordinate’s unlawful misconduct, even when accompanied by
attached evidentiary corroboration as in Maravelias’s email. Even reporting a crime to the
police could be an act of “stalking”. Maravelias being subject to a stalking order is not a
distinguishing factor since, if his private email itself is inherently “stalking” as this
Court’s Order suggests, then any similar person sending such an email would commit a
crime or, at least, an act auspicious to the issuance of a civil protective order. Inflamed
into rare-form by its personal distaste for Maravelias, this Court would set precedent
impossibly contumelious towards the cherished First Amendment rights of all citizens.
15. The Court cites State v. Craig, 167 N.H. (2015), a case which asserts this Court’s
Order here is erroneous. As this Court paraphrased, the Craig court established
“circumstances in which [defendant knows] the [plaintiff] is likely to view the
3
This Court’s Order even uses terms like Christina DePamphilis’s “alleged” [alcohol consumption]
“alleged” sexual relationship, or “alleged” perjury to evade irrefutable facts attested in the record. But see
T60,364,370-372,418,450;A18,84; T421:18,A167-196; T275:25;A21,24,28,159,189,192,201,221.
This overtly partisan judicial conduct is why the public has little lasting faith in our judiciary.
6
EXHIBIT G
statements” are required for certain categories of order-violative, and thus
constitutionally unprotected, “indirect” communication.
16. Paragraph 12(c) supra is repeated. Maravelias’s private, legitimate

communications could not have been “indirect communications”, because he never knew
nor intended that Plaintiff would view them. See also T471-473.
The “Reasonable Fear for Personal Safety” Finding
17. This Court next invites the public to believe any reasonable person could find that
said response letter and private email represent “reasonable basis to fear for [plaintiff’s]
personal safety”, and that “without a protective order, the plaintiff’s safety and well-being
would be in jeopardy”. Hereunder, let it be hypothetically granted that Maravelias’s
private communications were, impossibly, for the “sole purpose of stalking and
harassing” someone who was not the recipient thereof.
18. This Court does not cite any legal authority or supporting factual basis for its
strange reasoning (e.g., if Maravelias had made threatening communications to a third-
party, then that might support such a finding). Rather, to make the logical jump between
A (Maravelias’s self-defensive private speech to third-parties) and B (physical danger to
the female plaintiff), this Court offers the following threadbare sentence: “Moreover, in
view of the fact that the defendant engaged in this conduct while already subject to a
court order specifically restraining him from stalking or abusing the plaintiff or members
of her family, the trial court’s finding [about reasonable fear for personal safety] is
likewise reasonable”.
19. The Court’s dispositive reasoning here must equivalently assert, incorrectly, that
any and all conduct violating any stalking order also amounts to causing reasonable fear
for the plaintiff’s safety. “Abuse”, defined in RSA 173-B as family-or-intimate-partner-
acts only, cannot apply here. Therefore, the only contingent requirement in this Court’s
logic for conduct creating “fear for personal safety” is that there be stalking-order-
violative “stalking”. “Stalking” is already defined as conduct placing a reasonable
7
EXHIBIT G
person in fear for their physical safety or criminally violating any protective order,
so this Court’s logic for affirming the “reasonable fear” finding is defective circular
reasoning, even if wrongly assuming Maravelias actually did violate the Order by
writing private, non-threatening communications to recipients wholly separate from
the Plaintiff.
20. If this Court were correct, then RSA 633:3-a I.(c) (adding all protective order
violations to the definition of “stalking”, not requiring that said violations induce
reasonable fear) would not exist, because RSA 633:3-a I.(a) would already capture any
course of conduct causing someone “to fear for [their] personal safety”, whether
committed in violation of an extant Order or not.
21. In other words, according to this Court’s flawed reasoning, if Maravelias outright
violated the stalking order by texting the plaintiff, “I hope you have a nice day, and sorry
about all the legal trouble”, such a stalking-order-violation would also amount to creating
“fear for her personal safety and that of her family members”. No intellectually honest
Court could possibly entertain such an absurd notion.
D. The Court’s Rejection of Maravelias’s As-Applied Constitutional Challenge

Relies on Inapposite Case Law and is Tainted by Legal Error
22. Predicated upon the false “sole-purpose” finding discussed supra, this Court
legally erred in finding Maravelias’s speech-acts lacked constitutional protection.
23. The Court first cites Heffron in support, a foreign-jurisdiction case under very
different laws, which holds “posts … directed at a person protected by a protective order
… were not constitutionally protected”. Nowhere in the record was Maravelias accused
of “directing” his cited communications to the Plaintiff.
24. The Court then cites another foreign-jurisdiction case, Childs, where a man was
labeled a “stalker” of his son’s mother because he asked the police to check on the well-
being of his own son. He’d formerly been found to have “abused” the woman. This case
8
EXHIBIT G
is totally inapposite, as Maravelias isn’t subject to any DV order nor sought any “well-
being checks”.
E. The Court Does Not Anywhere Address the Orwellian Extended Terms Issue,
On Which Maravelias Sufficiently Presented Extensive Argument
25. See A156-177,182-196;Brief54-57.
F. Without Correcting Its Order, the Court Renders the Specific Due-Process
Requirements of Dist. Div. R. 1.4(f) Protecting Public’s Right to Access
Courts a Mere Thing of Wax if Dist. Div. R. 1.1 Can Authorize Illegal
Discretionary Restrictions
26. The Court’s Order disparages the controlling law at Rule 1.4(e), “no court or
justice shall establish notice rules, requirements or procedures that are different than
those established by this rule”, and the three-step process at Rule 1.4(f) then necessitating
“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” – both which Judge Coughlin violated.
27. This Court’s suggestion that the trial court could apply Dist. Div. R. 1.1 to evade
the specific requirements – which it didn’t - is logically synonymous with finding trial
courts may sustainably violate any party’s legal rights should they so whim upon any
allegation of “good cause”.
G. The Court Overlooks and Mentions Nowhere a Near-Totality of Maravelias’s

Evidence and Facts, Wildly Mischaracterizing the Record in Spots by
Claiming Maravelias Testified to Things He Never Did
28. The Court commits tortious libel to claim Maravelias “admitted to using login
credentials of other persons to gain access to the plaintiff’s social media accounts and
take ‘screenshots’ from them”. Perhaps this mischaracterization of the record was an
honest mistake; regardless, Maravelias politely demands it be corrected.
9
EXHIBIT G
29. At T359, Maravelias explained other people supportively supplied him social
media images documenting Christina DePamphilis’s unlawful substance usage, they
using their own “login credentials”, he then physically effectuating the “screenshots” in
their presence. Nowhere does the record indicate Maravelias obtained his supporters’
“login credentials” and used them to gain access to accounts not his, as this Court’s Order
invents while striving to malign Maravelias.
30. Beyond this and other aforementioned striking omissions, the Court:
a. Overlooked and mentioned-nowhere Christina DePamphilis’s falsity in

lying about the 2013 Turkey Trot incident as exposed by the content of the
casual incidental video Maravelias’s sister was taking (See Brief24,25);
b. Overlooked and mentioned-nowhere Christina DePamphilis’s lies or self-

contradictions under oath when questioned about her cyber-bullying
Maravelias (See Brief24);
c. Overlooked and mentioned-nowhere Christina DePamphilis’s admissions

of having falsely put words in Maravelias’s mouth in the petition (See
A187;T377-379);
d. Overlooked and mentioned-nowhere Christina DePamphilis’s underage

alcohol consumption further validating Maravelias’s email and occasional
jibes against his legal abuser while testifying – “justified, merited, and
appropriate” (T411) insults against an unrepentant criminal falsifier, for
which Maravelias firmly offers zero apology (See A18);
e. Overlooked and mentioned-nowhere Christina DePamphilis’s severe

neurotic/delusional accusatory propensities and vivid false memories (See
Brief25,26);
10
EXHIBIT G
f. Overlooked and mentioned-nowhere that Judge Coughlin irrefutably
contradicted himself and composed a disingenuous order (See Brief49-50);
and
g. Overlooked and mentioned-nowhere that on 5/2/18, when Maravelias

wrongly believed he’d won and had his freedom back, he didn’t use his
liberty in any way contrary to the restraining order’s spirit, and went for a
peaceful recreational walk, able to finally focus on other matters and move-
on in life (See Brief49;T357:2-5,303:17-22,475).
WHEREFORE, for the reasons hereinabove set forth, Defendant-Appellant Paul

Maravelias respectfully requests this Holy Feminist Court:
1) Grant this Motion;

2) Upon reconsideration of its 1/16/19 Order, grant Maravelias the relief requested in
his Brief, namely:
a. Reverse the trial court’s 6/15/18 extension order and 8/7/18 order, ending
this case; and
b. Retroactively annul the original stalking order dated 2/7/17, issuing
declaratory relief that it was error to find Paul Maravelias had ever stalked
the daughter of David DePamphilis.
PAUL J. MARAVELIAS,
in propria persona
Dated: January 28th, 2019

11
EXHIBIT H
EXHIBIT I
EXHIBIT I
Eileen Fox, Clerk of Court
EXHIBIT J
February 26th, 2019
New Hampshire Supreme Court
One Charles Doe Drive Paul Maravelias
Concord, NH 03301 34 Mockingbird Hill Rd
Windham, NH 03087
RE: Paul Maravelias vs. David DePamphilis

Case No. 2018-0376
Dear Clerk Fox:
Enclosed please find an original and seven copies of Appellant’s Motion to Reconsider
Anomalous, Arbitrary Rule 23 Award of Appeal 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.

EXHIBIT J
SUPREME COURT
NO. 2018-0376
PAUL MARAVELIAS
V.
DAVID DEPAMPHILIS
PAUL MARAVELIAS’S MOTION TO RECONSIDER ANOMALOUS,

ARBITRARY RULE 23 AWARD OF APPEAL ATTORNEY’S FEES
“All tyranny needs to gain a foothold is for

people of good conscience to remain silent.”
Dear Mr. Lynn, Ms. Hantz-Marconi, Mr. Bassett, and Gary:
I, Paul Maravelias, respectfully command you, this Court, to reconsider and reverse
your insane order forcing me to pay my opponent’s attorney’s fees for this meritorious
and necessary appeal. You have already wrongly forced me, an impecunious 23-year-old,
to pay my rich 50-year-old victimizer $9,000 extorted dollars in the underlying matter.
You are unwise to permit your subjective frustration with me to pass into retaliatory
judicial acts. All I’ve done is defend myself, my safety, and my rights. You are
committing judicial misconduct, unchecked tyranny, and plain theft. Since I could not
afford an attorney and proceeded pro se, you’ve felt empowered to devastate and oppress
me howsoever you should whim. Between the two related appeals, you’ve blindly
ignored facts and dispelled convincing legal arguments, consummating a conspicuous
bias of misandry and hostility towards pro se litigants.
1
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
EXHIBIT J
You Are in Violation of N.H. Supr. Ct. R. 23
You cannot grant “extraordinary” appeal fees award per Rule 23 without “deem[ing]
[the appeal] to have been frivolous or in bad faith”. Your non-descript 2/21/19 Order
neglected to make any such finding. You made zero factual findings or legal conclusions
which would support the notion that this appeal was frivolous or in bad-faith, regardless
of your findings on the merits of my underlying 2017 Stalking Petition. Ergo, you break
the law and commit judicial misconduct to grant a Rule 23 award of appellate fees
without any specific supportable findings that this appeal was “frivolous or in bad-faith”.
It is an untenable contention that the instant appeal was “frivolous or in bad-faith” for
the same overlooked reasons propounded within my 12/31/18 Objection to
DePamphilis’s cruel, illegitimate Motion for Rule 23 appellate fees.1
You Are, and Have Been, Acting in Bad-Faith against Me - not Vice-Versa
You won’t fool the public. It is abundantly clear you purposefully tarried in this case,
2018-0376, to see if I would cower-down and not call-out your 1/16/19 shameful
sophistry in 2018-0483, wherein your conduct reached patently false characterizations of
the record at times. After I punctuated my 1/28/19 Motion for Reconsideration in that
case2 with the fond appellation “Holy Feminist Court”, you improperly retaliated against
me in this case. You punished me through an unfounded Rule 23 appeal attorney’s fees
award. Such a rare, nearly-unheard-of thing is supposed to be limited to “extraordinary
cases” of a truly “frivolous or bad-faith” appeal.
Your Order rejecting my said 2018-0483 Motion for Reconsideration and Order
granting the Rule 23 fees here (after two months of malingering) were issued on the same
day, 2/21/19. You have validated my observation you are “inflamed into rare form by
1
My initial 12/31/18 Objection substantively addressing this outrageous scheme by DePamphilis
may be found here: https://goo.gl/uoKN62
2
This pleading, my 1/28/19 Motion for Reconsideration in the other case, 2018-0483, which
apparently struck a negative chord with this sensitive Court, may be found here:
https://goo.gl/Q7TE9f
2
EXHIBIT J
[your] personal distaste for [me]”. You are ruling according to your emotion rather than
fact and law.
You are acting with capricious bad-faith against me.
You’ve put your petty disgruntlement at a 22/23-year-old standing up for his rights
and reputation ahead of your legal duty. You have let your personal frustration with me
trump your legal duty to stick to the four-corners of the law with objectivity and sanity.
If you force me to pay DePamphilis’s appeal fees, the New Hampshire public will
know their Supreme Court is nothing more than a bunch of butthurt bullies who rule
according to their childish emotions. People will be terrified to exercise their legal right
to appeal; already, they will be terrified to file meritorious stalking petitions where the
gender politics don’t jive with this Holy Feminist Court, given your outrageous
underlying ruling in this appeal.
You even tacitly signaled to DePamphilis within the very first paragraph of your
11/30/18 Final Order in this case that you wanted him to motion for Rule 23 appeal
attorney’s fees against me. You have willfully perpetuated the John Coughlin-
DePamphilis conspiracy against me to abuse my good name and extort me of funds. This
injustice is a concerted effort, if not by design then in-effect.
Magnifying the present extortion against me into additional appeal attorney’s fees
terrorism will make even bigger headlines exposing your recent behavior.
2018-0376 Was a Beyond-Meritorious and Necessary Appeal
Here is a hard, objective fact: many appeals filed at this Court, especially by pro se
litigants, are so far from being meritorious contentions that you don’t even address the
substance of said appeals. You just drop the standardized “As the appealing party,
plaintiff has the burden of demonstrating reversible error…” paragraph with the legal
citations and call it a Final Order. E.g. recently, Case Nos. 2018-0289, 2018-0209, 2018-
0090, 2017-0666, 2018-0042, 2017-0733, etc.
3
EXHIBIT J
In this appeal, there were two separate weighty legal issues which you addressed in a
4-page order. You did not drop the standard blurb as you would for a frivolous or
meritless appeal. Instead, you addressed the appeal on the merits and engaged my
important arguments.
“In this case there was a genuine question of statutory construction; therefore, it
cannot be said that either party acted in bad faith by requesting that this court reconcile
their dispute, cf. Funtown USA, Inc. v. Town of Conway, 127 N.H. 312, 499 A.2d 1337
(1985). Attorney’s fees are denied.” Appeal of Janice M. Parmelee, 127 N.H. 758 (1986).
In the instant appeal, there was not one but were two genuine, compelling questions 1) of
statutory and case law application to a trial court’s found-facts in a stalking petition, and
the legal sufficiency for a restraining order, and 2) of the propriety of a punitive
attorney’s fees award against someone filing a personal-safety-oriented stalking petition,
in light of the extensive case law indicating said award was inappropriate.
Therefore, this appeal was obviously beyond meritorious and could not be further
from a “frivolous or bad-faith” action, no matter what you say about the underlying
matter. The public understands this and readily comprehends the impropriety of your
current retaliatory judicial tyranny against me.
Don’t continue to destroy the public’s faith in you. By your own responsive legal
argumentation, you have indicated this appeal was not “frivolous”. Within the first
paragraph of your 11/30/18 Order, you represented your wishful design to watch
DePamphilis continue to defame my name and extort my money, irked unto upholding
the underlying fee award without citing a single iota of support for your finding
sustaining Coughlin’s “bad-faith” finding.
You are not acting as passive appellate arbitrators here. Rather, your behavior is
reflective of offended, partisan tyrants who have a clear agenda.
4
EXHIBIT J
You Are in Violation of the 7 , 8 , and 14th Amendments to the U.S. Constitution
th th
Fees of this nature would be legal, not equitable. This is a suit at common-law, and
the value of the attorney’s fees is over $20. I have a 7th Amendment right to a trial by
jury. I ought to have all the protections and rights as if sued for fees as damages. But as it
stands, an insolent and arbitrary kangaroo court is extorting me of thousands of dollars I
do not have3, without a single word of reasoning or factual findings by which Rule 23
could lawfully apply.
Rule 23, at least as-applied right now, is federally unconstitutional. Presently, there
are no due process protections in place to prevent a throng of arbitrary tyrants from
manipulating my financial property at the whims of their impulsive, vindictive fleshly
lusts. You have not offered me any hearing on the appellate attorney’s fees motion,
unlike the unjust underlying trial-court fees award. You have not cited any specific facts
or arguments in DePamphilis’s Rule 23 Motion or my Objection thereto. I have no right
to direct appeal to a higher court in this state, since there is none. You are therefore either
acting against controlling law (Rule 23) or depriving me of liberty and property without
due process of the law, against the 14th Amendment.
You are also imposing excessive fines and inflicting cruel, unusual punishment in
violation of the 8th Amendment. You may retort, “this is not a criminal matter, it is not
done in the name of a state’s executive government, it is a civil equitable remedy, not a
legal punishment”, etc. For SCOTUS preservation, I state my argument to the contrary.
You are a governmental entity in the State of New Hampshire punishing me with an
3
For what it is worth, I have been financially devastated by John Coughlin’s underlying
outrageous and illegal order forcing me to pay $9,000 in legal fees to my rich victimizer– a man
who legally abused me through proven-false lies about “stalking” and who himself thereafter
engaged in frightening “stalking” behaviors against me for which I rightly sought court
protection. I cannot afford to pay this demonstrable lawbreaker, who owns two houses and is
employed as the executive COO of a leasing company, an additional unjust fees award.
5
EXHIBIT J
arbitrary fees award without any specific factual findings on how my appeal was
“frivolous or in bad-faith”.
The cruelty is implicit through your obvious retaliatory motives, and the unusualness
extreme. In my research, I could not find one single comparable instance of a Rule 23
appellate fees award by this Court. I challenge you to illuminate the last time in history
this Court granted such an extraordinary measure, so that we may observe the striking
comparison to my meritorious and necessary appeal here.
Your Other Lawbreaking and Misbehavior, Showing the True Directionality of the
So-Called “Bad-Faith” Conduct
Gary, you promised you would “behave”. Being sworn-in on January 31st, 2006, you
said,
“I promise to behave. Part I, Article 8 provides in part that ‘All power residing
originally in, and being derived from the people, all magistrates and officers of
government are their substitutes and agents and at all times accountable to them.’ I
promise to never, ever, forget that.”
Gary, when you individually committed tortious libel against me in your 1/4/19 Order
denying my friend’s non-lawyer representation motion in her appeal, you knew this Court
did not uphold the baseless allegation my “conduct as a litigant” in filing my elaborately
evidenced 2017 Stalking Petition was “patently unreasonable”. Instead, this Court
declined to reverse the finding of “bad faith” – very different. But you made up a
fictitious, non-existent appellate finding to libel me and stroke your peevish ego4 – “for
the sole purpose of stalking and harassing” me, as I assume from your logic in 2018-
0483.
4
See pages 3 and 4 of your 11/30/18 Final Order in this case, upholding the fees award on the
“bad faith” grounds exclusively, mentioning nowhere “patently unreasonable”. You cited this
appeal case, not John Coughlin’s underlying order, for support of your “found to be … patently
unreasonable” libel. I have never filed any patently unreasonable nor bad-faith legal action.
6
EXHIBIT J
In failing to conceal your personal displeasure with me and ruling according to such
rank emotions, you and your three culpable colleagues forget that you are “accountable”
to the people of New Hampshire.
You cannot fulfill your accountability to the people of New Hampshire while failing
to offer a single reason, finding, or stated basis whatsoever sustaining your unilateral
commandment to a 23-year-old pro se litigant that he reimburse his rich victimizer’s
appeal fees. Ironically, your outrageous conduct is no different than Judge Coughlin’s
impetuous order of attorney’s fees in the underlying matter, done at the mere drop-of-a-
hat when the rich man’s lawyer files a baseless motion for them, without either court ever
listening to my responsive objection pleadings nor addressing the content thereof
anywhere. But see Code of Judicial Conduct, Canon 2 Rule 2.6.
Mr. Lynn, your words from April were as follows:
“My priorities as Chief Justice will be first and foremost to focus on the
Supreme Court’s core responsibility of resolving the cases before us fairly,
impartially, and expeditiously, with reasoned decisions that get it right in terms of
applying the law to the facts.”
Sadly, Mr. Lynn, you have abandoned your commitment to “reasoned decisions”.
You committed a criminal violation of RSA 644:11 against me when you failed to correct
your demonstrably false characterization of my testimony in the related case, 2018-0483,
which I signaled was “tortious libel” in my 1/28/19 Motion for Reconsideration. In fact,
you didn’t offer a single word in response to that significant defect whatsoever, rather
flatly denying the Motion while ignoring and not addressing its contents.5
5
That act of yours constitutes an unscrupulous abuse of your judicial immunity. If anyone else
composed and publicized a verifiably false statement alleging I said things in court which I did
not say, which “will tend to expose [me] to public hatred, contempt or ridicule”, I could sue such
a person to recover damages for this tortious act of defamation per se. Here, you act with
shameful boldness and disregard for my good reputation, as if you think you are above the law.
7
EXHIBIT J
Here, your 2/21/19 Order offers zero reasoning whatsoever how my meritorious
appeal could be found “frivolous or in bad-faith”. It just says the one-sentence,
“[DePamphilis’ biddings] [are] granted.”
Such may be the modus operandi of an intemperate kangaroo court. However, it

cannot be the reasonable and lawful behavior which New Hampshire citizens expect of
their highest court.
We expect “reasoned decisions”.
If you commit this outrageous and unreasonable deed, the entire landscape of New
Hampshire appellate litigation will shift into an unthinkable paradigm of fear and
repression. Wronged parties considering appeal will think-twice about exercising their
legal right to correct our corrupt trial courts’ grave errors. If New Hampshire’s Supreme
Court merely dislikes you, you will be forced to pay thousands of dollars in legal fees and
wind-up double-screwed, compared to cowering in fear and simply not exercising your
right to appeal.
8
EXHIBIT J
WHEREFORE, I respectfully request this Holy Feminist Court:
1) Reconsider and reverse its 2/21/19 Order granting appellate attorney’s fees6;
2) Deny Appellee’s 12/28/18 request for award of appellate attorney’s fees;
3) Hold a Hearing on this matter;
4) If denying the requested reconsideration, state specific facts and reasons
why this appeal was allegedly “frivolous or in bad faith”; and
5) Grant any further relief as shall be deemed just and proper.
PAUL J. MARAVELIAS,
in propria persona
____________________________________
Dated: February 26th, 2019
6
I have already paid Appellee his costs. As that is not as much an “extraordinary” measure as
attorney’s fees, I waive my objection to the sixty-bucks in costs.
9
EXHIBIT J
CERTIFICATE OF SERVICE AND RULE 26(7) COMPLIANCE
I, Paul Maravelias, certify that a copy of the foregoing Appellant’s Motion to Reconsider
Anomalous, Arbitrary Rule 23 Award of Appeal Attorney’s Fees was sent on this day via
first-class mail, postage prepaid, to Simon R. Brown, Esq., counsel for the Defendant-
Appellee, David DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.
Certification, further, is made of this document’s compliance to word-count limitation,

2452 words being contained. See N.H. Sup. Ct. R. 22(2), 26(7).
February 26th, 2019 __________________________________
10
EXHIBIT K
EXHIBIT K
EXHIBIT K
EXHIBIT K
EXHIBIT K
EXHIBIT K
EXHIBIT L

2019 Federal Lawsuit Against Criminal NH Supreme Court Justices For Their Fraudulent Extortion of Paul Maravelias (2019-CV-00487-JL)

Transféré par

Informations du document

Titre original

Copyright

Formats disponibles

Partager ce document

Partager ou intégrer le document

Options de partage

Avez-vous trouvé ce document utile ?

Ce contenu est-il inapproprié ?

Droits d'auteur :

Formats disponibles

2019 Federal Lawsuit Against Criminal NH Supreme Court Justices For Their Fraudulent Extortion of Paul Maravelias (2019-CV-00487-JL)

Transféré par

Droits d'auteur :

Formats disponibles

Case 1:19-cv-00487-JL Document 1 Filed 05/06/19 Page 1 of 29

7 PAUL MARAVELIAS, Civil No.

15 official capacities as Chief Justice ofthe COMPLAINT FOR

21 for Defendants' extortionate floccinaucinihilipilification of a citizen's basic civil right to file

28 target Maravelias in a bad-faith campaign ofretaliatory harassment and intimidation, newly

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

8 Defendants are weaponizing "Rule 23" as an indiscriminate vessel of oppressive pecuniary

^ chastisement in wanton nonobservance of Maravelias's constitutional due process rights.

24 monetary property in capitulation to Defendants' arbitrary, non-judicial, legislative diktats.

25 JURISDICTION AND VENUE

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE paUL MARAVELIAS

7 authorized pursuant to the Declaratory Judgment Act, 28 U.S.C. §§ 2201-02.

at 34 Mockingbird Hill Road, Windham, NH 03087.

10. Defendant SUPREME COURT OF NEW HAMPSHIRE is a governmental

ORIGINAL VERIRED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

2 his individual and official capacities.

5 Background of the Case: Maravelias Rightfully Files a Necessary Protective Order

12. On 12/8/17, Maravelias filed a Stalking Petition against David DePamphilis in

^^ filed. Maravelias went above-and-beyond by ensuring his meritorious petition's allegations

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

2 marauding after [Maravelias] in [their] neighborhood" on the night of 3/21/17.

petition. DePamphilis appeared lawyer-represented and moved to dismiss the case.

g produced DePamphilis's harassing "middle-fingers" cyberbullying social media post,2)

11 3)submitted a letter DePamphilis himself wrote wherein DePamphilis admitted to getting in

16 The record however indicates DePamphilis contested little-to-none of manifold accepted

20 the 42 U.S.C. § 1983 lawsuit Maravelias v. Coughlin et al.(1:19-CV-00143)for acts taken in

patently unreasonable, oppressive conduct against Maravelias in favor of DePamphilis is

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

17 Coughlin admitted as evidence) was not "credible evidence" of said allegation

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

32. On7/2/18, Maravelias filed a Rule 7 Notice Mandatory of Appeal with

^^ "patently unreasonable". Maravelias was certain he would win the appeal.

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

2 DePamphilis's 10/19/18 Motion to Strike, stating,

and provides in its final part:

23 ever mentioned, requested, or contemplated punitive attorney's fees against Maravelias

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE paUL MARAVELIAS

5 48. On 12/31/18, Maravelias filed an Objection to DePamphilis's 12/28/18 request.

7 (Exhibit E)DePamphilis's request was baseless; Maravelias exposed it as riddled with

12 Defendants Play "Wait-and-See" for Almost Three Months,Then Retaliate Against

18 1.5 months ahead ofthe 2018-0376 appeal underlying this action.

26 52. Conjunctively on 2/21/19, Defendants issued two one-page Orders in both

27 Maravelias-DePamphilis appeal cases

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

1 a. In 2018-0483 (the separate appeal), they blanket-denied Maravelias's Motion for

2 Reconsideration with zero specific discussion.(Exhibit H)

b. In 2018-0376 (the underlying appeal), they GRANTED DePamphilis's 12/28/18 request

7 defendant shall file an itemization ofthe attorney's fees that he is seeking."(Exhibit I)

Defendants Deny Maravelias a Hearing,Allow ^DePamphilis's 3/4/19 Itemization to

11 53. In response, Maravelias filed a 2/26/19 "Motion to Reconsider Anomalous,

Arbitrary Rule 23 Award of Appeal Attorney's Fees".(Exhibit J)

^2 correct their overt mischaracterizations of Maravelias's transcribed testimony in their 2018-

25 the entire totalitv of the months-long litigation from "07/05/2018" to "12/28/2018".

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE pauL MARAVELIAS

1 58. By contrast, DePamphilis's itemization reveals that an absolute maximum of

granted 12/28/18 request sought reimbursement.

22 64. Defendants' threadbare two-sentence 3/29/19 Order contained zero factual

ORIGINAL VERIFIED COMPLAINT FOR EQUITABLE PAUL MARAVELIAS

1 This Action is Properly Before This Court

his monetary property. Accordingly, Defendants' violation offederal law is ongoing.

^ 69. On 5/1/19, DePamphilis's attorney emailed Maravelias "conceming payment of

15 Rule 42 deemed unconstitutional in violation ofthe Privileges and Immunities Clause). It