March 21st, 2019

Robin E. Pinelle, Circuit Clerk

NH Circuit Court Paul Maravelias
10th Circuit – District Division – Derry 34 Mockingbird Hill Rd
10 Courthouse Lane Windham, NH 03087
Derry, NH 03038

RE: Christina DePamphilis vs. Paul Maravelias

Docket No. 473-2016-CV-00124

Dear Clerk Pinelle,

Please find enclosed the following pleadings to be filed in the above-referenced case:

1) Respondent’s Verified Motion to Reconsider 3/8/19 Order Granting

Stalking Order Extension;

2) Paul Maravelias’s Verification Affidavit to Motion to Reconsider

Please note the opposing party has filed their own Motion to Reconsider on 3/18/19.
I shall file a separate Objection thereto pursuant to the Court’s rules on or before 3/28/19.

Thank you for your attention to this matter.

Sincerely,

Paul J. Maravelias

CC: Simon R. Brown, Esq.

Hon. Robert S. Stephen
John J. Coughlin
 THE STATE OF NEW HAMPSHIRE

ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY

Docket No. 473-2016-CV-00124

Christina DePamphilis
v.
Paul Maravelias

VERIFIED MOTION TO RECONSIDER

3/8/19 ORDER GRANTING STALKING ORDER EXTENSION

Paul Maravelias (“Respondent”) respectfully requests The Honorable Court reconsider its 3/8/19 Order
extending the stalking order for one year. Maravelias acknowledges the good and noble intentions of the
current Court, but humbly argues its Order is more appealable than appealing. In support, he states as follows:

I. THE STALKING ORDER EXTENSION IS LEGAL ERROR

A. The Court’s Extension Order is Illegal and Prejudicial Because It Relies Substantially Upon
an Allegation Found Only at Paragraph 15 of Petitioner’s Motion to Extend, Whereas the
Court Narrowed the Scope of the Hearing to Paragraphs 12, 13, 22-24, and 27

1. On 2/7/19, the Court granted Maravelias’s Motion to State Reasons for Granting Extension,
stating it found Paragraphs “12, 13, 22-24, and 27” of DePamphilis’s 1/24/18 Verified Motion to Extend
constituted “good cause to extend the Stalking Final Order of Protection”.

2. At the 2/12/19 Hearing on the extension, the Court verbally clarified its intention with granting
the Motion to State Reasons was to have a more “focused” hearing.

3. On 3/8/19, the Court issued an Order extending the stalking order based solely on its finding:

“Mr. Maravelias continued efforts at disparaging Ms. DePamphilis and her family
by making offensive and hateful statements in public postings on the internet”

4. Paragraphs 12 and 13 of DePamphilis’s Motion to Extend do not notice any such allegation;
they paraphrased the Supreme Court’s summary of Maravelias’s past truthful “offensive” statements he had
made in his testimony, not on the internet, at the first extension. Paragraphs 22-24 forged the now-exposed
“following” false accusations. Paragraph 27 accused Maravelias of attaching a public social media exhibit to
an appellate brief to show DePamphilis lied. An allegation about “statements” “on the internet” appears
nowhere in the paragraphs to which this Court strictly constrained the legal scope of the extension case.

1 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

 B. This Error Is Prejudicial and Violates Maravelias’s Due Process Rights Under the U.S.
Constitution, Amend. XIV and the N.H. Constitution, Pt. I, Art. 2 and 15, Inter Alia
5. This Court signaled Maravelias to prepare a case in rebuttal of certain enumerated accusations.
Maravelias then persuasively countered them at trial. Now the Court is ambushing Maravelias with an
extension based on different allegations, against which he would have prepared a defense had the Court not
specifically narrowed the hearing’s scope to other specific allegations.
6. “It is well settled that a ‘defendant is entitled to be informed of the theory on which the
plaintiffs are proceeding and the redress that they claim as a result of the defendant’s actions.’” Morancy v.
Morancy, 134 N.H. 493 (1991). Here, the Court had explicitly limited the parts of Plaintiff’s “theory” to be
considered for the extension. The Court even made extensive interventive commentary at hearing to narrow
the focus thereof and prohibit discussion of topics beyond the cited Motion to Extend paragraphs; the Court
interjected to limit both parties, at times, when they began to stray outside the six paragraphs in subject matter.
7. The Court’s error of extending based on a non-anticipatable allegation of Maravelias making
“offensive” statements on the “internet” violates Maravelias’s due process rights under the 14th Amendment of
the U.S. Constitution and Part I, Articles 2 and 15 of the State Constitution. The latter states in relevant part,
“No subject shall be deprived of his property, immunities, or privileges, put out of the protection of the law,
exiled or deprived of his life, liberty, or estate, but by the judgment of his peers, or the law of the land․” N.H.
CONST. Pt. I, Art. 15. “Law of the land in this article means due process of law.” Petition of Harvey, 108
N.H. 196, 198, 230 A.2d 757 (1967). Federally, “no State shall make or enforce any law which shall abridge
the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life,
liberty, or property, without due process of law.” U.S. CONST, Amend. XIV. “It hardly bears mentioning that
a restraining order restrains [the defendant’s] liberty ... from a number of legal activities”, McCarthy v.
Wheeler, 152 N.H. 643,645 (2005), including disparaging Maravelias’s 2nd Amendment rights and even
restricting his “fundamental right to freedom of movement”, State v. Porelle, 149 N.H. 420 (2003).

8. As it stands, this Court’s Order extends a stalking order disparaging Maravelias’s rights and
reputation 1 where Maravelias was never given a fair opportunity to be fully heard in his defense 2,3. It
egregiously violates the notion of “fundamental fairness” that the Court would bait Maravelias into preparing a

1
The Court’s Order worshipfully caresses Ms. DePamphilis’s emotions by punishing Mr. Maravelias for his “offensive” personal beliefs and
statements made in public, but see State v. Veale, 158 N.H. 632 (2009), recognizing a personal liberty interest against reputational or social stigma by
and through governmental determinations such as stalking protective orders, implicating due-process protections for reputational aspects alone. It is
Maravelias whose reputation is wrongly “disparaged” by the existence of an “offensive” and “hateful” governmental “restraining order”, and whose
legal rights are being violated.
2
Cf. N.H. CONST, Pt. I, Art. 15, “Every subject shall have a right to produce all proofs that may be favorable to himself … and to be fully heard in
his defense.”
3
Cf. Code of Judicial Conduct Canon 2, Rule 2.6

2 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

defense limited to “X”, only to penalize him thereafter based on “Y”. At hearing, Maravelias said he wished to
take more time to prepare his case, call other witnesses, dispute further contested matters within the Motion to
Extend, review the original circumstances of the stalking order, and deliver a longer cross-examination and
testimony than he did – all of which were prohibited or severely restricted by the Court’s recurring insistence
that the hearing be “focused” in content to the six cited paragraphs and not go-on a second day.
9. Maravelias’s disallowed extended self-defense would have rebutted the relied-upon Paragraph
15 allegation about public internet speech to third-parties. In view of the Court’s subsequent extension based
on an allegation extraneous to the Court’s articulated “focus”, the Court’s rushing and restriction of
Maravelias’s case caused him even greater prejudice than the Paragraph-15-reliance alone, in isolation.

C. As-Applied Through the Court’s Present Reasoning for Extending the Stalking Order, RSA
633:3-a, III-c. Violates Fundamental Rights Guaranteed By the 1st and 14th Amendments to
the U.S. Constitution and Part I, Articles 22, 15, and 2 of the N.H. Constitution
i) The As-Applied Violation of Freedom of Speech
10. Absent reversal, the Court’s order stands to caricaturize New Hampshire family courts into a
risible laughing-stock of Orwellian tyranny, feminist-Marxist speech-police, and punitive misandry to chill
public expressive conduct – an embarrassing spectacle profitable for all Americans to appreciate the modern
state of civil “protective” order statutes and the insidious terrorism against personal liberty into which they
have shamefully suppurated.
11. This Court’s order openly punishes Maravelias’s public self-defensive speech on the “internet”
– comments repudiating DePamphilis’s false accusations of “stalking” which this subjective Court finds
“offensive” and “hateful” – and continues a “stalking protective order” stripping Maravelias of his
fundamental constitutional rights because he engaged in such “offensive” political speech 4 in public. It is
lamentable that this Court would commit such rampant desecration of Maravelias’s freedom of speech under
Pt. I, Art. 22 of the State Constitution and the 1st Amendment of the U.S. Constitution. To constitutionally
attribute extension to a defendant’s public speech-acts, such speech must evince an objective likelihood of
imminent crime or violence. Here, it is undisputed Maravelias made no such unprotected speech.
12. Since Maravelias’s public “comments” on the “internet”, made in response to and about the
existence of this very same court case and unjust restraining order, do not fall into any categories lacking
First Amendment protection (e.g., threats of violence or “fighting words”), the Court’s extension is
unconstitutional. The Court cannot lawfully extend a stalking order because a defendant communicated his

4
Criticizing a governmental determination - a wrongful “stalking” restraining order maligning Maravelias’s name – is political speech.

3 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

corroborated opinion to others in public that he has been legally abused and harassed through a false
restraining order built upon wild lies that have been subsequently disproven. 5 The Court’s reasoning that non-
threatening “offensive” speech equals “hostility” and therefore ongoing risk tantamount to “stalking” is
beyond absurd. If equally applied to all citizens, this legal reasoning would doubtlessly burden the speech of
every human being who has ever lived, save perhaps Mother Theresa, with a potential “stalking” order.

ii) The As-Applied Violation of Equal Protection and the Principle of Stare Decisis
13. This Court has been applying unequal, inconsistent interpretation schemes of RSA 633:3-a in
civil stalking order decisions. In other stalking cases from the last year, this Court has explicitly clarified
“disparaging”, “offensive” words alone with zero threatened violence do not amount to present or ongoing risk
sufficient to sustain a stalking order. In other similar cases, the Court has adopted this proper constitutional
interpretation of RSA 633:3-a even where the “offensive”, “hateful” communications were made directly to a
petitioner, as opposed to third-party political self-defensive speech in a public forum, the case of Maravelias’s
alleged “offensive” comment(s). See generally Village of Willowbrook v. Olech, 528 U.S. 562 (2000).
14. Here, the Court disparately punishes Maravelias with continued stalking order extension solely
based on the accusation he made “offensive” comments in public, themselves purposed to decry the perverse
injustice of this very stalking order. Accordingly, the Court’s extension is unconstitutional and contumelious
towards the core tenets of our common law legal system; See U.S. CONST., Amend. XIV, supra, and N.H.
CONST, Pt. I, Art. 2 and 15. “The first question in an equal protection analysis is whether the State action in
question treats similarly situated persons differently.” Longchamps Electric, Inc. v. New Hampshire State
Apprenticeship Council, 145 N.H. 502, 506 (2000). “The equal protection guarantee is essentially a direction
that all persons similarly situated should be treated alike.” Lennartz v. Oak Point Associates, P.A., 167 N.H.
459, 462 (2015). As previously stated, the Court’s attitude towards “offensive” statements within stalking
order cases has taken drastically different turns for different yet identically situated defendants. Since
Maravelias is an older male and pro se litigant, he is statistically likely to suffer such unequal, prejudiced
judicial outcomes. 6,7,8 The Court’s unequal application of the law also violates stare decisis: if non-threatening

5
Maravelias assumes the Court refers to comments made on a YouTube video of the 2018 Hearing on the past extension in this case. However, the
Court’s order does not even identify the specific “offensive” comment(s) and is therefore unconstitutionally vague regardless. (See infra)
6
Jennifer L. Peresie, Female Judges Matter: Gender and Collegial Decisionmaking in the Federal Appellate Courts, 114 Yale L.J. (2005).
“[Plaintiffs in sexual harassment and sex discrimination cases] were significantly more likely to win when a female judge was on the bench. This
effect was independent of judicial ideology—the presence of both liberal and conservative female judges increased the probability that plaintiffs
prevailed on panels of varying ideological composition.” Available at: https://digitalcommons.law.yale.edu/ylj/vol114/iss7/5
7
Basile, S. (2005). A Measure of Court Response to Requests for Protection. Journal of Family Violence, 20, 171-179. (Finding strong bias against
males in civil protective order cases in proximate Gardner, MA trial court)
8
Quintanilla, V. D., Allen, R. A. and Hirt, E. R. (2017), The Signaling Effect of Pro se Status. Law and Social Inquiry, 42: 1091-1121.
doi:10.1111/lsi.12261 (Finding a significant systemic disadvantageous effect of proceeding pro se attributable to an inherent signaling effect from the
title and to the socialization of the legal profession)

4 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

“offensive” words to third-parties in public are not considered “safety” threats to plaintiffs in similar stalking
cases, there is no rational basis that they should be here. See Black’s Law Dictionary (9th ed. 2009), p. 1537.

D. As-Applied Through the Court’s Present Extension of the Order, RSA 633:3-a, III-c. Is
Unconstitutionally Vague
15. The Court has failed to identify what specific alleged “offensive and hateful statements” on the
“internet” by Maravelias it finds warrant extension. This defect alone renders the extension legally erroneous
and reversible: when issuing RSA 633:3-a protective orders, trial courts are required to make specific factual
findings in support. 9 Due process naturally requires that this apply also to extensions of such orders. The
Court’s vague 3/8/19 Order – the current application of RSA 633:3-a, III-c. – fails to adequately notify
Maravelias, a person of ordinary intelligence, of what kinds of self-defensive public “statements” of opinion
are likely to cause extension of a stalking order. It is unclear that Maravelias defending his wrongly-defamed
name to third-parties on the internet amounts to concern for the “well-being” of the false-accuser Petitioner, or
what constitutes as “hateful”. The statute for extension, as-applied, is therefore unconstitutionally vague. 10

E. The Court Cannot Lawfully Grant Any Stalking Order Extension Because RSA 633:3-a, III-
c. is Facially Unconstitutional
i) Substantial Overbreadth and Vagueness in Violation of the 1st Amendment to the
Federal Constitution and Pt. I, Art. 22 of the State Constitution
16. A statute is facially overbroad if “a substantial number of its applications are unconstitutional,
judged in relation to the statute’s plainly legitimate sweep.” United States v. Stevens, 559 U.S. 460, 473
(2010). See also Doyle v. Comm’r, N.H. Dep’t of Resources & Economic Dev., 163 N.H. 215, 220-21 (2012).
Such is the case with RSA 633:3-a, III-c., which inexplicably widens the legal standard for stalking order
extension to mere service towards a plaintiff’s “well-being”. Any constitutionally protected speech-act or
lawful act at all by a defendant with which a plaintiff merely disagrees enables and requires the Court to
extend the stalking order: e.g., even a defendant’s basic act of appearing as an adverse party or asserting he has
never “stalked” the plaintiff, which is often undeniably true in such civil cases where a disturbingly low
“preponderance of evidence” standard applies for obtaining such stalking protective orders in the first place.
See RSA 633:3-a, III-a. Pampering a plaintiff’s personal contentment and mental happiness (serving their
“well-being”) far exceeds the legitimate governmental purpose of RSA 633:3-a to protect victims from
stalking. The Court’s Order admits that its finding “good cause” for the extension “directly relates to [serving
the] well-being of the plaintiff”, citing the controlling case law MacPherson v. Weiner, 158 N.H. 6, 9 (2008).

9
See Kiesman v. Middleton, 156 N.H. (2007), Fillmore v. Fillmore, 147 N.H. 283 (2001), Fisher v. Minichiello, 155 N.H. (2007), etc.
10
See Hill v. Colorado, 530 U.S. 703 (2000). Extending a restraining order because a defendant makes “offensive” or “hateful” comments to third-
parties about a remorseless liar legally abusing said defendant “invites arbitrary enforcement” of these vague, undefined, subjective terms. Id.

5 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

 17. Therefore, all stalking order extensions, let alone a substantial number thereof, are plagued by
unconstitutional overbreadth. Such “well-being” extensions punish defendants through constrained rights
without narrowly serving any legitimate governmental interest. Given the plain language of the statute, there
are no set of circumstances wherein the RSA 633:3-a, III-c. would require trial courts validly and narrowly to
service the governmental interest of prevention of stalking in an extension case as opposed to overinclusively
coddling a plaintiff’s mental “well-being”. Separately, the “safety and well-being” language is substantially
vague rendering the statute unconstitutional on its face regardless of overbreadth. Maravelias repeats his
hereunto-ignored robust argumentation on these two points previously submitted to this Court at ¶28-60 of his
First-Amended Memorandum of Law in Support of Objection to Petitioner’s Motion to Extend.

ii) Substantial Violation of Equal Protection Rights Under the 14th Amendment to the
U.S. Constitution and Pt. I, Art. 2 of the N.H. Constitution
18. Maravelias repeats his argumentation at ¶48-50 (discussing the lack of narrow-tailoring in the
“safety and well-being” language through the lens of the “underinclusiveness” doctrine) and rephrases it into a
facial challenge on the grounds of state and federal constitutional Equal Protection rights. The legal standard
for a new stalking order at RSA 633:3-a, III-a. (to show the plaintiff has been “stalked”) is much higher and
more stringent than the standard for extension at RSA 633:3-a, III-c. (merely to show that such extension
would serve a plaintiff’s “safety and well-being”). New stalking defendants and past stalking defendants
facing another new extension are “similarly situated” for purposes of equal protection, as are new stalking
plaintiffs and plaintiffs seeking an extension of a stalking order. To concede comparatively broader rights to
stalking plaintiffs seeking a further extension violates the Equal Protection rights of new stalking plaintiffs not
already having a protective order; similarly, affording new stalking defendants broadened comparative
protection of liberty interests violates the Equal Protection rights of stalking defendants facing further
extension. Unlike a criminal conviction of guilt proven beyond all reasonable doubt, a civil finding of
“stalking” on the “preponderance of evidence” standard cannot lawfully distinguish between past and new
stalking defendants for purposes of the “similarly situated” element of Equal Protection analysis. Therefore, no
possible set of circumstances exists where the lowered extension standard of RSA 633:3-a, III-c. is not facially
unconstitutional. This impinges upon the fundamental rights inherently limited by stalking protective orders.
F. The Court’s Extension Errs to Adduce an Iota of Credibility to Christina DePamphilis’s
Wild Representations, Where Gaping Swaths of Her Testimony and Verified Motion Were
Revealed as Fantastical Contrivances, Flabbergasting Falsehoods, Inexplicable Self-
Contradictions, and/or Phantasmagorical Hallucinations

6 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

 19. With all due respect, if the Court declines to find Christina DePamphilis in criminal contempt
for willful perjury and falsification, the Court must embrace a view wherein her mental sanity is drastically
impaired. 11 The 2018 record already attests to Christina DePamphilis’s underage usage of illegal psychoactive
narcotic drugs. 12 In light of this and the above, the Court erred to find her “credible”.

II. THE 8/7/18 “EXTENDED TERMS” MUST BE IMMEDIATELY DISSOLVED

A. The Court Embarrassingly Misidentifies its Own 8/7/18 Judicial Order Not Granting
Petitioner’s 7/12/18 Ameliorated Terms, But Rather the More Punitive Original 7/2/18 Terms

20. The Court misidentifies its own 8/7/18 Order not granting Petitioner’s 7/12/18 Reply (where
the ameliorated “knowingly” and “about her” improvements were conceded) but rather impetuously granting
the more-punitive terms requested in Petitioner’s original 7/2/18 Motion. Perhaps the Court realized John J.
Coughlin’s shocking misconduct, panicked, and seized the damage-control opportunity to retroactively
pretend the ameliorated terms were granted, hoping nobody would notice. If an honest oversight, this Court’s
lackadaisical, dismissive effortlessness here is reminiscent of John Coughlin’s thoughtless scribbling-off on
the illegal Orwellian terms in the first place. With all due respect, this is a denigrating mockery of pro se
Maravelias’s basic legal rights. This Court so nonchalantly handles his potential criminalization and arrest for
“possessing” pieces of paper in his own legal brief, crucially dependent on the exact version of the terms. The
Court had even learned the Windham Police were actually criminally investigating this demented travesty. As
it goes without saying, the Court cannot uphold the constitutionality of terms it never in fact granted. 13

11
Assuming dubitante that Christina DePamphilis never willfully lied, she necessarily: 1) asserted-as-fact that “Maravelias followed” her on 10/23/18
to “cheer practice” (Verified Motion) and asseverated with “10 out of 10” certainty the face of the allegedly-pursuing vehicle in Windham was
Maravelias’s (sworn testimony), when Maravelias was in fact in Concord, 2) swore under penalty of perjury that her Verified Motion alleging
multiple summertime “following” incidents was true and accurate to the best of her knowledge, only to testify that there was only one such believed
summertime “following” incident, 3) asserted in her Verified Motion that the 10/23/18 “following” vehicle was Maravelias’s, when in fact she
testified it was a completely different, white vehicle she had no idea if Maravelias had ever owned or driven, while intimately knowing his “two”
“black” cars he owns and routinely drives, 4) inexplicably changed the time of the alleged 10/23/18 “following” accusation from “7:00pm” (Verified
Motion) to “4:00pm” (sworn testimony), otherwise indicative of an attempt to bait Maravelias into preparing a suddenly-non-responsive evidentiary
defense, 5) mysteriously happened to guess that Maravelias might have Google phone location history proving where he was and thus coincidentally
consciously premeditated an absurd and failed attack against Maravelias’s phone location evidence predicated on the notion that he had “multiple
phones”, using an arcane two-year-old police search record of his family member’s house as apparent support, 6) said that she was referenced in the
web description of Maravelias’s book “David the Liar”, then admitted she was not in fact referenced therein, 7) said she continues to be “stalked” by
Maravelias “every day”, even though she could not name a single instance Maravelias attempted to interact with her in years, apart from the
“following” false accusation, 8) asserted-as-fact in her Verified Motion that Maravelias “intimidated” and “harassed” her friend by “recording” the
friend at Dunkin Donuts, even though she was not there and admitted to having no idea whether this was true or false, 9) admitted that she had no
evidence whatsoever to suggest that the alleged summertime “following” incident involved Maravelias, not ever identifying nor even seeing the
driver, 10) admitted Maravelias never submitted criminal complaints about her to the “Windham” and “Salem” police departments, which she had
asserted-as-fact in her Verified Motion, 11) stalked and gained illicit access to Maravelias’s private business product support web forum to monitor
his communications, 12) testified that, although she knew Maravelias’s false arrest in 2017 in connection with her “stalking order” was annulled, not
prosecuted, and legally accepted as “false”, she still wished that the defamatory internet record of said false arrest “should” appear as the “first” result
in a Google search for Maravelias’s name as opposed to elsewhere on the first page, not even endeavoring to conceal her outrageous bad-faith
motivations of retaliatory slander and libel, inter multa exempla alia. That this Court would esteem such a litigant as anything less than a mentally
disturbed individual and/or a brazen perjuring felon – let alone “credible” – strains the scope of legal error and approaches judicial misconduct.
See Appellant’s Brief in 2018-0483 for comprehensive summary of the record documenting Christina DePamphilis’s drug and alcohol use.
12

See John Coughlin’s 8/7/18 hand-written Order on the final page of DePamphilis’s 7/12/18 Reply proposing the slightly-ameliorated terms: “The
13

Court granted The The [sic] Petitioner’s Motion for Modification of Stalking Final Order of Protection on 8/7/18”; Cf. John Coughlin’s 8/7/18 hand-

7 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

 B. The Court Must Dissolve the Extended Terms 1) Because They are Made Ultra Vires Outside
this Court’s Subject-Matter Jurisdiction, Without Any Statutory or Legal Authority
Whatsoever, in Violation of RSA 173-B:5, and 2) Due to Their Rampant Unconstitutionality
21. Maravelias here repeats the federal constitutional arguments he asserted to this Court by
submitting as an exhibit his Original Verified Complaint and related papers in Paul Maravelias v. John J.
Coughlin, et al., N.H. Fed. Dist. Ct. Case No. 1:19-CV-143. The Court’s Order makes zero specific response
to these robust arguments, indicating it has not properly carried-out its duty to respect fundamental rights.
22. The insane “indirect” “possession” of “social media [exhibits]” terms also violate Pt. I, Art. 2,
15, 19, 22, and 23 of the N.H. Constitution. 14 Ordering Maravelias immediately not to “possess” “directly or
through a third-party” “social media” exhibits (i.e., Maravelias’s public court exhibits where Christina
DePamphilis insults and middle-fingers Maravelias baiting an unlawful reaction) necessarily compels the
destruction of his own private property, in violation of Art. 2, 15, and 19, criminalizes Maravelias’s speech
adopting such legally favorable exhibits and any others in violation of Art. 2, 15, and 22, criminalizes any
retroactive possession or possession prior to receiving notice of the Court’s order in violation of Art. 2, 15, and
23, and deprives of him “liberty” and “property” without jury trial nor by the “law of the land” as neither RSA
633:3-a nor 173-B:5 permit protective orders to act as vessels for such tyrannical, arbitrary terms.
C. The Court’s Judicial Officer Has Committed and Will Continue to Commit a Federal Felony
Crime Under 18 U.S.C. §242 If It Does Not Dissolve the Outrageous “Extended Terms”
23. Maravelias understands that political pressure exerted within New Hampshire’s highly
fraternized judicial branch disincentivizes the Court from doing the right thing, in light of Maravelias’s current
federal lawsuit against John Coughlin for granting the “extended terms” in 2018. Maravelias preserves legal
notice of these bad-faith motivations and cautiously reminds that any state judicial officer’s deprivation of
federal rights under color of law, willful or not, is a felony crime. See 18 U.S.C. §242. Judicial immunity does
not apply where a judge exceeds subject matter jurisdiction. See Stump v. Sparkman, 435 U.S. 349 (1978). 15
Accordingly, the Court’s judicial officer would also be civilly liable to Maravelias under 42 U.S.C. §1983.

III. THE N.H. SUPREME COURT’S CURRENT BAD-FAITH AND HOSTILE BIAS
AGAINST MARAVELIAS, THE FUTILITY OF APPEAL, AND GENERIC FAIRNESS

written Order on the final page of DePamphilis’s Original 7/2/18 Motion containing the original more-punitive terms lacking the words “knowingly”
and “about her”: “granted as to Petitioner’s Request for Relief A.; B1; B2; B3 John J. Coughlin”.
14
If appellate issue preservation on these state constitutional challenges to the “extended terms” should ever pass into dispute, Maravelias demands in
fairness his single paragraph here suffice to preserve these issues in light of Dist. Div. R. 3.11(E), imposing a strained 10-page limit on this document.
15
Ordering a civil defendant not to “possess” public court exhibits and internet pages constituting “social media” “directly or through a third party” is
an unheard-of abuse of power rarely or never performed by a judicial officer; it is therefore not a “judicial act” within the U.S. Supreme Court’s test
for determining the scope of judicial immunity. Indeed, issuing such draconian criminalization of private legal self-defense conduct under the guise of
a concomitant “stalking restraining order” has never happened before ever in any jurisdiction anywhere in the history of the universe.

8 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

 A. This Court Must Adjudicate Maravelias’s Legal Arguments Since the Corrupt N.H. Supreme
Court Has Been Acting with Sickening Prejudice and Personal Bias Against Maravelias,
Bound to Reject His Appeals No Matter How Irrefutably Correct His Legal Arguments Are
24. Put bluntly, our state’s Supreme Court is currently pissed-off by Maravelias and his
commitment to exposing John J. Coughlin’s dishonest, self-interested, and criminal acts of injustice. As a
result, they have been childishly retaliating against Maravelias through sordid acts of financial extortion 16,
willful libel 17, and criminal judicial terrorism 18. Maravelias has zero-chance of winning any appeal whatsoever
before such biased activist-tyrants; this Court is his only hope for fairness. Maravelias has noticed an
unfortunate tendency of trial court judges to ignore a pro se defendant’s legal arguments, issue orders confined
to threadbare finding-of-fact on-the-merits favoring the politically expedient party, and reflexively relegate
any potential legal error to the Supreme Court for resolution – as if pestered by the Lukan importunate
widow. 19 This mentality perverts justice and prejudices Maravelias, whose appellate strivings in the current
malicious Supreme Court are guaranteed to end only in futile financial loss.

B. The Court’s Extension Shocks the Conscience and Assaults Fairness Given the “Offensive”
and “Hateful” Slander Campaign DePamphilis Continues to Wage Against Maravelias

“Whoever secretly slanders his neighbor, him I will destroy.” – Psalm 101:5

25. This Court improperly usurps a stalking order as punishment for alleged defamatory conduct to
magnify the injustice against Maravelias, the victim of DePamphilis’s outrageous slander and libel. David
DePamphilis has been personally approaching people he believes know Paul Maravelias to perpetuate a vile,
tortious campaign to defame and harass Maravelias. E.g., DePamphilis has recently approached teenage
employees of a local coffee shop – complete strangers – “warning” them Paul Maravelias is a “pedophile” 20,
emailed a Windham state representative claiming Maravelias’s asking-out a girl to dinner in 2016 represented
a likelihood Maravelias “may sexually assault her”, caused language describing Maravelias as a “sexual
predator” and “piece of shit stalker” to appear on public internet pages when one Googles Maravelias’s name,

16
To wit, the Supreme Court not only declined to reverse the outrageous fee award against Maravelias for a truthful stalking petition, but recently
issued an unheard-of Order instructing Maravelias to pay for DePamphilis’s attorney’s fees for the good-faith Supreme Court appeal case itself!
17
See Appellant’s Motion for Reconsideration in 2018-0483, indicating where Robert Lynn’s Court patently mischaracterized transcribed testimony.
18
See Id., exposing Robert Lynn’s unapologetic calpestation of Maravelias’s rights without even making a single reference to Maravelias’s chief
arguments and evidence in the appeal case. E.g., the Supreme Court’s shameful Order willfully omitted any reference to DePamphilis’s incitative
“middle-finger” bullying/harassment post against Maravelias proving she had no “fear”, exposing Justice Lynn’s unscrupulous feminist activism.
19
E.g., the Court’s 3/8/19 Order addresses absolutely none of Maravelias’s multiple legal arguments for dismissal in his 2/14/19 Motion to Dismiss.
20
DePamphilis’s reprehensible “pedophile” slander against Maravelias is an artifact of cognitive dissonance and psychological projection.
DePamphilis’s own son Nicolas, in his twenties, has been in an intimate homosexual anal relationship with a 17-year-old boy named Nate since Nate
was only 16 years of age. While 16 is the age of consent, Nate ostensibly weighs less than David’s daughter and has the physical semblance of an
emaciated pre-pubescent young girl; See e.g. https://goo.gl/AsBZuV, https://goo.gl/SoitTA, https://goo.gl/h2aw1J, https://goo.gl/YtSrK8, etc. It is for
this reason it comforts David DePamphilis to slander Paul Maravelias a “pedophile”, as DePamphilis knows Maravelias embraces healthy, natural,
and orderly sexual preferences for humans of substantial somatosexual maturity who are also female. Therefore, DePamphilis’s delusional
“pedophile” slander against Maravelias functions as a cognitive-dissonance-reduction coping mechanism for paternal feelings, plausibly homophobic,
of shame, bitterness, and rage. Psychopathology aside, DePamphilis’s criminal slander against Paul Maravelias is contemptible and must be ceased.

9 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

etc. When Maravelias brought a stalking petition against DePamphilis to address even worse stalking conduct,
Judge John J. Coughlin, a prince of perversity and exposed civil rights abuser, judicially abused Maravelias, an
impecunious 22-year-old, ordering $9,000 payment of rich 49-year-old business executive DePamphilis’s
attorney’s fees. This partisan, despotic, corrupt judiciary has prostrated itself in utter sycophancy to a sadistic
defamer assaulting Maravelias’s reputation, and this Court now punishes Maravelias with a baseless continued
restraining order for his public speech merely defending himself against DePamphilis’s libelous legal abuse.

IV. MARAVELIAS’S CONCESSION TO CHILL HIS OWN SPEECH IN EXCHANGE FOR

RESTORATION OF HIS FUNDAMENTAL FEDERAL CONSTITUTIONAL RIGHTS

26. Regarding Maravelias’s constitutionally protected conduct of vindicating his own wrongly
disparaged name on the internet, Petitioner was displeasured primarily by two artifacts: 1) a YouTube video of
Maravelias’s testimony at the public 2018 extension hearing, and 2) a public court document she herself
submitted, allegedly containing her address. If the Court reconsiders and terminates indefinitely this stalking
order within 30 days of this Motion, Maravelias hereby agrees that he will, within 10 days of the Clerk’s
notice of such order ending this case, 1) remove from the web Petitioner’s own offensive court pleading (viz.,
the 1/5/18 Motion to Extend) and 2) remove the YouTube video of Maravelias’s 2018 testimony.
27. It is under duress of continued wrongful loss of constitutional rights that Maravelias
begrudgingly offers to restrict his public expression in this way, solely to please the arbitrary whims of New
Hampshire judicial officers. Maravelias expects this compelling fact to heighten SCOTUS interest once the
activist, bad-faith NH Supreme Court renders its obligatory screw-Maravelias appeal-rejecting Order in utter
blindness to fact and law, if the instant Motion is denied and another necessary NHSC appeal pursued.

WHEREFORE, Respondent Paul Maravelias respectfully prays this Honorable, Well-Meaning Court:
I. Grant this Motion, including any further relief as may be deemed just and necessary;
II. Reconsider and totally dissolve the extension of the Stalking Order, ending this case;
III. If not granting Prayer II, dissolve the 8/7/18 extended terms; and
IV. Make a finding to identify the certain “offensive” “internet” comment(s) causing extension.

CERTIFICATE OF SERVICE – I, Paul Maravelias, certify by signature hereunder that this document was sent this
day to Simon R. Brown, Esq., counsel for the Petitioner, Christina DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.

Respectfully submitted,

PAUL J. MARAVELIAS,

in propria persona March 21st, 2019

10 PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087

 PAUL MARAVELIAS’S VERIFICATION AFFIDAVIT TO MOTION TO RECONSIDER

NOTARY ACKNOWLEDGMENT

STATE OF NEW HAMPSHIRE – COUNTY OF ROCKINGHAM

On this ___ day of March 2019, before me, _________________________, the undersigned officer,
personally appeared ________________________, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument and acknowledged that he/she executed the
same for the purposes therein contained, who being by me first duly sworn, on his oath, deposes and says:

All factual stipulations within the attached Motion to Reconsider are

true and accurate to the best of my knowledge as of 3/21/2019.
[affiant’s statement of facts]

__________________________________
[signature of affiant]

Paul J. Maravelias
[typed name of affiant]

34 Mockingbird Hill Rd, Windham, NH 03087

[address of affiant]

In witness whereof I hereunto set my hand and official seal.

____________________________________
Notary Public

My commission expires: ________________