April 3rd, 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) Defendant’s Reply to Plaintiff’s Objection to Defendant’s Verified Motion to

Reconsider 3/8/19 Order Granting Stalking Order Extension; and

2) Defendant’s Declaration and Affidavit in Support of Reply to Plaintiff’s

Objection to Defendant’s Verified Motion to Reconsider 3/8/19 Order Granting
Stalking Order Extension

Thank you for your attention to this matter.

Sincerely,

Paul J. Maravelias

CC: Simon R. Brown, Esq.

 THE STATE OF NEW HAMPSHIRE

ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY

Docket No. 473-2016-CV-00124

Christina DePamphilis
v.
Paul Maravelias

REPLY TO PLAINTIFF’S OBJECTION TO DEFENDANT’S VERIFIED MOTION TO

RECONSIDER 3/8/19 ORDER GRANTING STALKING ORDER EXTENSION

NOW COMES Paul Maravelias (“Defendant”) and respectfully submits the within Reply to

Plaintiff’s above-referenced 3/29/19 Objection. In support thereof Defendant states as follows:

I. IN RESPONSE TO MARAVELIAS’S 5,000+ WORD MOTION TO RECONSIDER

DISCUSSING MANIFOLD DUE PROCESS, CONSTITUTIONAL, AND
STATUTORY DEFECTS WITH THE COURT’S LEGALLY ERRONEOUS
EXTENSION ORDER, PLAINTIFF’S OBJECTION CONTAINS TWO
DESOLATE SENTENCES OF NON-BOILERPLATE CONTENT.

1. Plaintiff has filed another meritless, burdensome, and vexatious pleading, entitled

“Plaintiff’s Objection to Defendant’s Verified Motion to Reconsider 3/8/19 Order Granting

Stalking Order Extension”, docketed 3/29/19.

2. Plaintiff does have a right to bring meritorious legal contentions in opposition to

Maravelias’s legal self-defense of his besieged constitutional rights. However, in such an event,

the New Hampshire Rules of Professional Conduct mandate that Plaintiff and counsel make “a

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
good faith argument for an extension, modification or reversal of [the] existing law” which

Maravelias’s Motion to Reconsider cites as requiring the Court to reverse its 3/8/19 Order.

3. Maravelias’s 3/21/19 Motion to Reconsider cites numerous constitutional and

statutory laws for the basis of his claims for relief. Plaintiff’s Objection makes zero attempt to

address any of these compelling arguments. Insofar as Plaintiff despises any human being’s

rights other than hers and wishes to abolish American constitutional law to enable her legal

abuse campaigns against innocent individuals, she must at least endeavor to make a good-faith

argument “for an extension, modification or reversal of [the] existing law”. See Rule 3.1, N.H.

Rules of Prof. Cond., supra.

4. Plaintiff disappointingly tenders the following embarrassing threadbare sentence

as the entirety of substance to her Objection:

“Defendant had fair notice of the assertions made in the Motion to Extend, and the Court
could rely upon ample evidence and testimony to support ‘good cause’ to extend the Order.”

5. In failing to provide any meaningful response to any of Maravelias’s multiple

compelling arguments showing the necessity to reverse the Court’s 3/8/19 extension, Plaintiff

only validates Maravelias’s incontrovertible arguments.

6. Insofar as Plaintiff offers the above-quoted limited response to the first argument

in Maravelias’s Motion to Reconsider, she contributes nothing of legal merit. The legislature

specifically included the following provision in RSA 633:3-a, III-c. for stalking order extensions:

“The court shall state in writing, at the respondent's request, its reason or reasons for
granting the extension.”

7. If the plain language of the statute did not clarify well-enough the obvious due

process implications thereof, this Court explicitly clarified in open court that the “focus” of the

2/12/19 Hearing was “limited” to the paragraphs it cited when granting the Motion to State

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
Reasons – the parts of Plaintiff’s Motion to Extend which “moved” Judge Leonard (e.g.,

primarily, the now-exposed “following” lie).

8. Therefore, and for the reasons stated in Maravelias’s Motion to Reconsider, the

Court deprived him of an opportunity to prepare and give a full rebuttal to the allegations that

were noticed as being considered for extension. Plaintiff’s exiguous one or two sentences on this

topic do not contravene Maravelias’s arguments; rather, they merely exemplify how a sore bad-

faith litigant might attempt to make some dismissive, futile remarks about this gaping injustice.

II. PLAINTIFF’S EXIGUOUS OBJECTION ESPOUSES AN INCRIMINATING

SILENCE ON MARAVELIAS’S CRUCIAL ARGUMENT THAT THIS COURT
MUST FULLY ADJUDICATE MARAVELIAS’S HEREUNTO-IGNORED
LEGAL ARGUMENTS BECAUSE THE CURRENT NEW HAMPSHIRE
SUPREME COURT IS A BIASED, MALIGNANT THRONG OF ACTIVIST-
TYRANTS ACTING IN CLEAR BAD-FAITH, BOUND TO DENY MARAVELIAS
A FAIR AND FULL OPPORTUNITY TO VINDICATE HIS ATTACKED
CONSTITUTIONAL RIGHTS ON APPEAL

9. Maravelias expresses his gratitude to Plaintiff for this opportunity to include more

critical materials into the record before this trial court rules upon the Motion to Reconsider.

10. Paragraph 24 of Defendant’s 3/21/19 Motion to Reconsider is repeated.

11. Many recent objective indicators suggest the New Hampshire Supreme Court has

been acting with unfairness, hostile subjectivity, and corrupt bad-faith against Maravelias. There

is a traceable fact-pattern of libel, harassment, extortion, and criminal deprivation of rights under

color of law which Justices Lynn, Hicks, Basset, and Hantz-Marconi have consummated against

pro se Maravelias in the past few months. This vile conduct has transpired primarily within two

appeals with the parties: Paul Maravelias v. David DePamphilis (2018-0376), and the instant-

case appeal of the 2018 extension, Christina DePamphilis v. Paul Maravelias (2018-0483). At all

material times, Maravelias was pro se and litigating against lawyer-represented DePamphilis.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 12. Our current shameful Supreme Court is pissed-off by the rare appearance of a

young pro se litigant with zero legal training who relentlessly and competently fights “the

system” for his own rights to be respected. It apparently angers the four complicit Supreme Court

justices that Maravelias does not capitulate to the unchecked feminist tyranny of family courts

and privileged lawyers who disparage the rights of the innocent through nominally non-criminal

“protective” order statutes enacted by an authoritarian, globalist legislature gradually to erode the

fundamental natural rights New Hampshire citizens have enjoyed since long before ratifying the

United States Constitution in June 1788.

A. The New Hampshire Supreme Court Has Surreptitiously, Purposefully, and

Nervously Withheld Publication of Their Secret Legal-Abuse Orders Against
Maravelias, Inexplicably Excluding their Final Orders in 2018-0376 and 2018-
0483 From the Public Supreme Court Website Containing Final Orders In All
Non-Confidential Cases

13. The Supreme Court’s recent conduct to abuse, defame, and harass Maravelias has

been sub rosa without any accountability to the public legal community. This is reminiscent of

the apartheid courts of South Africa or the secretive Nazi Volksgerichtshof “People’s Court”.

14. As evidence, Defendant refers to his accompanying Declaration and Affidavit in

Support of Reply to Plaintiff’s Objection to Defendant’s Verified Motion to Reconsider 3/8/19

Order Granting Stalking Order Extension. The Supreme Court’s despicable and unilateral

tyranny against Maravelias is being done in secret, hoping to elude the public’s attention.

15. The Supreme Court’s embarrassing, self-censored, law-ignoring Final Orders

against Maravelias in 2018-0376 and 2018-0483 are already preserved in this Court’s record of

the case at bar, having been attached as Exhibits B and A respectively to Plaintiff’s 1/24/19

Verified Motion to Extend.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 B. The New Hampshire Supreme Court Has Been Abusing Paul Maravelias With
Baseless, Punitive, Secret Orders to Extort Thousands of Dollars From Him,
Ordering Him to Pay DePamphilis Extraordinary Appellate “Attorney’s Fees”
Without Making Any Finding Whatsoever Maravelias’s Appeal Was “Frivolous”

16. This Court must adjudicate Maravelias’s ignored constitutional arguments

because his only right of direct appeal is to a law-breaking, extortionate judicial body that has

been financially abusing him. This abuse is bound to continue if Maravelias appeals this case.

17. The New Hampshire Supreme Court recently ordered Paul Maravelias to pay

David DePamphilis $4,900 in attorney’s fees for the good-faith, meritorious Supreme Court

appeal case itself (2018-0376) of Judge Coughlin’s underlying reckless order to Maravelias to

pay DePamphilis over $9,000 of attorney’s fees in relation to a truthful and necessary 2017

stalking petition filed against DePamphilis, which the Supreme Court affirmed without making a

single reference to the record to support the false accusation Maravelias acted in “bad-faith”.

18. Maravelias cannot exercise his legal right of direct appeal to the Supreme Court

without fearing more patently unreasonable extortionary harassment from the said: an unchecked

throng of arbitrary tyrants with contempt-of-court police powers, who are abusing said power to

order financially-struggling Maravelias to surrender his scant funds to a rich 50-year-old

executive without making a single specific finding of fact supporting the outrageous judicial act.

19. It is vital that the record in this case preserve a paper trail of these despotic, illegal

abuses committed by our state’s highest Court, for review by the United States Supreme Court:

a. David DePamphilis orchestrated the Supreme Court’s recent extortionate act in 2018-
0376 by filing a 12/28/18 post-trial Motion entitled “Appellee’s Request for Taxation
of Costs and the Award of Attorneys’ [sic] Fees”. Maravelias does not have a readily
available scanned copy and therefore asks the Court to take judicial notice thereof.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 b. On 12/31/18, Maravelias filed “Appellant’s Objection to Appellee’s Request for
Taxation of Costs and Award of Attorney’s Fees” in 2018-0376, attached as Exhibit A.

c. On 1/28/19, Maravelias filed his “Appellant’s Motion to Reconsider” (Exhibit B) in

2018-0483, the appeal of the 2018 extension in the instant case. This Motion exposed
the Supreme Court’s dishonest, fallacious, libelous, and bad-faith conduct prejudicing
Maravelias as evident in their 1/16/19 Order. This Motion had the effect of angering
the biased Supreme Court into their further acts of retaliation against Maravelias.

d. On 2/21/19, the Supreme Court issued unpublished orders both in 2018-0376 (Exhibit
C) and 2018-0483 (Exhibit D). In 2018-0376, they casually granted DePamphilis’s
demented motion for appellate attorney’s fees without making a single factual or
conclusory finding that Maravelias’s appeal itself was “frivolous or in bad-faith”. In
2018-0483, they blanket-denied Maravelias’s flustering, incriminating Motion to
Reconsider. I.e., the bad-faith Supreme Court purposefully tarried in their decision on
DePamphilis’s extortionate motion to monitor Maravelias’s reaction to their secretive
legal abuse in 2018-0483. After being exposed as liars, libelers, and fact-ignorers in the
1/28/19 Motion to Reconsider, they abused their power to retaliate against Maravelias
by granting the unheard-of appellate attorney’s fees on the same day.

e. On 2/26/19, Maravelias submitted an explosive “Motion to Reconsider Anomalous,

Arbitrary Rule 23 Award of Appeal Attorney’s Fees” in 2018-0376 (Exhibit E) using
first-person language to the complicit justices. Maravelias included the following
prayer for relief, “If denying the requested reconsideration, state specific facts and
reasons why this appeal was allegedly ‘frivolous or in bad faith’;”.

f. On 3/29/19, the Supreme Court issued an unpublished two-sentence Order (Exhibit F)

blanket-denying the Motion to Reconsider, offering zero factual findings to support the
baseless allegation Maravelias’s appeal was “frivolous”, and ordering him to pay
DePamphilis $4,900.00 of attorney’s fees.

20. DePamphilis has recently moved the Supreme Court to repeat said unilateral

extortionate tyranny against Maravelias even in this case, where Maravelias is the

Defendant. On 3/22/19, DePamphilis filed a Motion in 2018-0483 begging them to order

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
Defendant Maravelias to pay DePamphilis for all attorney’s fees in that appeal, months after the

Supreme Court refused on 1/16/19 to overturn the 2018 extension of this stalking order, enabling

DePamphilis to continue abusing Maravelias with bold lies without ever being held accountable.

21. If our criminal Supreme Court’s behavior in 2018-0376 is any indication, they

will soon order destitute Maravelias to pay his rich abuser for daring to exercise his right to

appeal this outrageous stalking order when extended in 2018, after said stalking order was

proven false with video and photographic evidence at the 2018 hearing. Maravelias cannot afford

to expose himself to the arbitrary whims of these extortionate tyrants if unnecessary. Ergo, if this

Court continues to ignore Maravelias’s constitutional arguments, it subjects him to further undue

harassment, extortion, and legal abuse. This Court must adjudicate said arguments in full.

22. Clearly, this Court cannot ignore Maravelias’s legal arguments within his 2/14/19

Motion to Dismiss and 3/21/19 Motion to Reconsider without greatly prejudicing him,

necessitating another futile appeal to the bad-faith New Hampshire Supreme Court.

23. Defendant Maravelias takes this opportunity to proffer a prescient plea to the

Honorable Stephen G. Breyer to grant a foreseeable Petition for Writ of Certiorari to the

Supreme Court of the United States of America if and when, expectedly, 1) this trial court

declines to stop abusing Maravelias’s federal constitutional rights as argued in the numerous

pleadings and oral argument before this Court on the instant restraining order extension, and 2)

the activist, bad-faith New Hampshire Supreme Court likewise hears and wrongly affirms this

protective order extension in late 2019, defenestrating Maravelias’s pro se federal constitutional

arguments carelessly into the wind as part of an objective pattern of harassment, extortion, and

judicial tyranny which New Hampshire’s highest court has been inflicting against defenseless

Maravelias.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 WHEREFORE, Defendant Paul Maravelias respectfully prays this Honorable Court:

I. Grant this Motion;

II. Deny Plaintiff’s 3/29/19 Objection to Defendant’s Verified Motion to Reconsider
3/8/19 Order Granting Stalking Order Extension;
III. Grant Defendant’s 3/21/19 Motion to Reconsider 3/8/19 Order Granting Stalking
Order Extension; and
IV. Grant any further relief as may be deemed just and necessary.

Respectfully submitted,

PAUL J. MARAVELIAS,

April 3rd, 2019 in propria persona

CERTIFICATE OF SERVICE

I, Paul Maravelias, certify that a copy of the within Defendant’s Reply to Plaintiff’s Objection to
Defendant’s Verified Motion to Reconsider 3/8/19 Order Granting Stalking Order Extension was
forwarded on this day through USPS Certified Mail to Simon R. Brown, Esq., counsel for the
Petitioner, Christina DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.

______________________________
April 3rd, 2019

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
EXHIBIT A
 THE STATE OF NEW HAMPSHIRE
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
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
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
 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
 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”.

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 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
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
 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
 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
 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 B
 THE STATE OF NEW HAMPSHIRE
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
 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
 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
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
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
 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
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
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
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
 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
 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.

Respectfully submitted,

PAUL J. MARAVELIAS,
in propria persona

Dated: January 28th, 2019

11
 CERTIFICATE OF SERVICE AND RULE 26(7) COMPLIANCE

I, Paul Maravelias, certify that a copy of the foregoing Appellant’s Motion for
Reconsideration was sent on this day via first-class mail, postage prepaid, to Simon R.
Brown, Esq., counsel for the Plaintiff-Appellee, Christina DePamphilis, P.O. Box 1318,
Concord, NH, 03302-1318.

Certification, further, is made of this document’s compliance to word-count limitation,

2,997 words being contained, exclusive of the herein addendum-certificate. See N.H.
Sup. Ct. R. 22(2), 26(7).

January 28th, 2019 __________________________________

12
EXHIBIT C
EXHIBIT D
EXHIBIT E
 THE STATE OF NEW HAMPSHIRE
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
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
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
[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
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 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
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
You Are in Violation of the 7th, 8th, and 14th Amendments to the U.S. Constitution

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

Respectfully submitted,

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
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 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
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
EXHIBIT F