Amended Complaint Against Judge John J. Coughlin, Exposed Civil-Rights Abuser and Lawbreaking Tyrant

1 PAUL J.
MARAVELIAS, pro se
34 Mockingbird Hill Rd
2 Windham, NH 03087
Telephone: (603) 475-3305
3
Email: [email protected]
4
UNITED STATES DISTRICT COURT
5 FOR THE DISTRICT OF NEW HAMPSHIRE
6
)
7 PAUL MARAVELIAS, )
a natural person, )
8
)
Plaintiff, ) Civil No. 1:19-CV-143(SM)
9
)
10 v.
)
) Date Action Filed: 2/11/2019
11 JOHN J. COUGHLIN,
a natural person, in his individual and )
) JURY TRIAL DEMANDED
12 official capacities,
)
13 GORDON J. MACDONALD, )
a natural person, in his official capacity as )
14 )
Attorney General of New Hampshire,
15 )
PATRICIA G. CONWAY, )
16 a natural person, in her official capacity as )
Rockingham County Attorney, )
17 )
TOWN OF WINDHAM, ex rel., ) FIRST AMENDED VERIFIED
18 WINDHAM POLICE DEPARTMENT, ) COMPLAINT FOR
municipal entities, )
19 DECLARATORY AND
) INJUNCTIVE RELIEF
20 GERALD S. LEWIS,
)
a natural person, in his official capacity as
Chief of Police of the Town of Windham, )
21
)
22 Defendants. )
)
23
24 PRELIMINARY STATEMENT
25 1. NOW COMES Plaintiff PAUL MARAVELIAS (“Plaintiff”) with Complaint
26 and brings this action joining two substantially related claims. The first matter is predominant
27
and exigent: this action seeks a preliminary injunction against Defendants to enjoin them from
28
enforcing an illegal state court order abusing Maravelias’s federal constitutional rights.
FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

DECLARATORY AND INJUNCTIVE RELIEF 34 MOCKINGBIRD HILL RD WINDHAM, NH 03087
-1-
1 Defendants issued a baseless court order against Maravelias ultra vires, in total absence of
2 statutory or equitable authority, masquerading as “extended terms” of a preexisting civil

3
protective order, to newly criminalize his “possession” of public internet “social media
4
communications” necessary as exhibits in ongoing state court proceedings for his own
5
defense. Defendants have threatened they will enforce these illegal “extended terms” to
6
7 the protective order and will arrest Maravelias for his imminently anticipated lawful
8 speech activity, causing irreparable injury in catastrophic violation of his civil rights.
9 See Plaintiff’s forthcoming Motion for Preliminary Injunction. This action seeks declaratory
10
relief and a permanent injunction preventing enforcement of Defendants’ said unlawful order
11
against Plaintiff. The second component of this action seeks declaratory judgment that NH
12
RSA 633:3-a, III-c., pertaining to the legal standard for extending civil stalking protective
13
14 orders after initial expiration, is facially invalid in violation of the First and Fourteenth
15 Amendments to the Constitution of the United States of America.

16
JURISDICTION AND VENUE
17
2. This action arises under 42 U.S.C. § 1983 and the United States Constitution.
18
19 Subject matter jurisdiction exists pursuant to 28 U.S.C. §§ 1331 and 1343 in that the instant
20 case arises under questions of federal constitutional law.
21
3. This Court has supplemental jurisdiction over Plaintiff’s state law claims
22
pursuant to 28 U.S.C. § 1367(a).
23
24 4. Personal jurisdiction exists whereas all individual parties are natural citizens
25 within the federal boundaries of the United States of America.
26
5. Claims herein for injunctive relief are authorized pursuant to 28 U.S.C. § 1343
27
28 and Rule 65 of the Federal Rules of Civil Procedure.

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1 6. Claims herein for declaratory relief are authorized pursuant to the Declaratory
2 Judgment Act, 28 U.S.C. §§ 2201-02.

3
7. Venue is appropriate per 28 U.S.C. § 1391 as Defendants’ material conduct has
4
occurred and is occurring substantially within the State of New Hampshire, in which all
5
6 parties reside.
7
PARTIES
8
8. Plaintiff PAUL MARAVELIAS is a natural person over 18 years of age residing
9
within the Town of Windham and Rockingham County in the State of New Hampshire. He is
10
11 a recent Dartmouth College graduate in Economics and employed as a software engineer. He
12 resides with his parents and sister at 34 Mockingbird Hill Road, Windham, NH 03087.
13
9. Defendant JOHN J. COUGHLIN is a natural person and judicial officer within
14
the judicial branch of the State of New Hampshire. He is a Senior Active Status judge at 10th
15
16 Circuit Court – District Division – Derry, 10 Courthouse Ln, Derry, NH 03038. Defendant
17 JOHN J. COUGHLIN was acting under color of New Hampshire state law at all times
18 material. JOHN J. COUGHLIN is being sued in his individual and official capacities.
19
10. All other Defendants are being sued in their official capacities only.
20
21 11. Defendant GORDON J. MACDONALD is the Attorney General of the State of
22 New Hampshire with the official address of 33 Capitol St, Concord, NH 03301. Under NH
23
RSA 7:6, he “shall have and exercise general supervision of the criminal cases pending before
24
the supreme and superior courts of the state” and “with the aid of the county attorneys” …
25
shall enforce the criminal laws of the state.” He has authority to enforce the illegal order
26
27 against Maravelias in question.
28

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1 12. Defendant PATRICIA G. CONWAY is the County Attorney for Rockingham
2 County, NH with the official address 10 NH-125, Brentwood, NH 03833. She has authority to
3
enforce the illegal order against Maravelias in question in Rockingham County.
4
13. Defendant TOWN OF WINDHAM is a municipal entity in the State of New
5
6 Hampshire which maintains and operates the Windham Police Department (“WPD”), a law
7 enforcement agency. WPD is responsible for the training, conduct, employment, supervision,
8 and retention of its officers and employees. The TOWN OF WINDHAM is responsible for
9
overseeing WPD and ensuring its personnel comply with the laws and constitution of the
10
United States of America. At all times material, the officers, personnel, and employees of the
11
12 TOWN OF WINDHAM were acting and continue to act under color of New Hampshire state
13 law as applied through the customs, usages, and policies of said town.
14
14. Defendant GERALD S. LEWIS is an employee of the TOWN OF WINDHAM
15
as Chief of Police at the Windham Police Department. The three aforesaid entities are
16
hereinafter referred to as the “Windham Defendants”. Defendant GERALD S. LEWIS is
17
18 responsible for the training, conduct, employment, supervision, and retention of his
19 subordinate officers and employees and has a duty to ensure said personnel comply with the
20 laws and constitution of the United States of America. Defendant GERALD S. LEWIS has
21
been acting and continues to act under color of state law as applied through the customs,
22
usages, and policies of the Town of Windham at all times material.
23
24
25
26
27
28

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1 FACTUAL ALLEGATIONS
2 Procedural Background
3
15. In January 2018, Plaintiff was subject to a preexisting New Hampshire civil
4
stalking protective order restraining him from contacting the petitioner in that action,
5
Christina DePamphilis. The underlying state Circuit Court case is Christina DePamphilis v.
6
7 Paul Maravelias (473-2016-CV-00124). On 1/5/18, DePamphilis moved to extend the stalking
8 order against Maravelias another year to February 2019, pursuant to RSA 633:3-a, III-c.
9
16. Maravelias has long maintained the said “protective” order litigation is an
10
illegitimate, bad-faith campaign of malicious harassment orchestrated by DePamphilis’s
11
12 father David DePamphilis. Maravelias claims DePamphilis committed perjury to obtain the
13 order. During cross-examination, DePamphilis even admitted that Maravelias never actually
14 spoke certain words to her which she claimed (maliciously) in her petition he said.
15
17. The Windham Defendants possess an audio recording proving that Maravelias
16
never spoke certain words that DePamphilis falsely put into Maravelias’s mouth to obtain the
17
18 stalking order. They are aware of the content and significance of said audio recording.
19
18. The Windham Defendants took part in the establishment of said fraudulent
20
stalking order and have a credibility-related interest in its existence. David DePamphilis
21
testified on 1/5/17 that WPD officers told him “you need to file a restraining order [against
22
23 Maravelias]” after Maravelias had asked Christina DePamphilis on a date, got rejected, then
24 never once contacted her ever after that day. On 4/20/17, Windham officer Christopher van
25 Hirtum remorselessly told Maravelias in person he “doesn’t blame” DePamphilis for filing the
26
(false) restraining order and boldly claimed he “would have done the same”.
27
28

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1 19. In June 2017, Christina DePamphilis posted incitative bullying/harassment
2 social media posts identifying and directed against Paul Maravelias, middle-fingering him
3
with her father and boyfriend. Maravelias’s final contact with DePamphilis had been asking-
4
her-out once to dinner, which she declined. Maravelias commented at trial she was trying to
5
“bait” him to violate her “bad-faith” “stalking order”. She was trying to provoke a jealous
6
7 reaction and cruelly cause more trouble for Maravelias.
8 20. Maravelias collected screenshots of DePamphilis’s public internet social media

9
harassment conduct to use for his self-defense at the protective order extension hearing. Other
10
individuals shared with him other “social media exhibits” from DePamphilis which supported
11
12 Maravelias’s case against the civil protective order.
13 21. In May and June 2018, Defendant JOHN J. COUGHLIN presided over a three-
14
day trial at Derry, NH District Court on DePamphilis’s extension motion.
15
16 22. Defendant JOHN J. COUGHLIN admitted many of Maravelias’s social media
17 image evidentiary exhibits, including DePamphilis’s vulgar cyberbullying post against
18 Maravelias, inter alia.

19
23. On 6/15/18, Defendant JOHN J. COUGHLIN granted the stalking order
20
extension against Maravelias, extending said order to 2/5/19.
21
22 The Orwellian Summer 2018 “Extended Terms” or “Further Conditions”
23
24. On 7/2/18, DePamphilis filed a certain Motion in the District Court which is the
24
25 critical foundation of this action. She filed a “Motion for Modification of Stalking Final Order
26 of Protection to Include Further Conditions”, attached as Exhibit A.
27
28

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1 25. In said Motion, she sought that Defendant JOHN J. COUGHLIN modify her
2 stalking order against Maravelias to include the following additional criminally-enforceable

3
provision:
4
“Respondent [Maravelias] shall not gain access to or possess any
5 of Petitioner’s [DePamphilis’s] social media communications
6 either directly or through a third party;”
7 26. Hereinafter, Plaintiff refers to the above provision as the “extended terms”. Two
8
other such “further conditions” were sought and granted, but this action disregards them.
9
10 27. On 7/5/18, Maravelias filed an Objection to DePamphilis’s Motion. Maravelias
11 pointed-out that she was attempting to criminalize Maravelias’s mere possession of her
12 “social media exhibits” – by then, record-admitted evidentiary public court exhibits which
13
proved, in one part, that she was incitatively cyberbullying Maravelias with vulgar gestures,
14
and therefore lied about having “fear” of him for the stalking order.
15
16 28. Maravelias’s 7/5/18 Objection (Exhibit B – redundant exhibits therefrom
17 omitted) spoke of the unconstitutional overbreadth and vagueness of the requested terms,
18
noting that Defendant JOHN J. COUGHLIN had no legal authority to grant such draconian,
19
Orwellian “extended terms” against Maravelias by the procedural mechanism of a civil
20
stalking order, which is purposed to prevent physical following/stalking.
21
22 29. In response to Maravelias’s 7/5/18 Objection, DePamphilis filed a Reply on
23
7/12/18 which proposed a minor concession in her requested “further conditions”, that
24
Maravelias should not “knowingly [gain access to or possess…]”. This 7/12/18 Reply is
25
attached as Exhibit C.
26
27
28

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1 30. On 7/16/18, Maravelias filed a Surreply to DePamphilis’s 7/12/18 Reply
2 (Exhibit G), noting that her requested further terms were still outrageously illegal,
3
unconstitutional, unwarranted, and draconian.
4
Defendant JOHN J. COUGHLIN Scribbles “Granted” on The Lawyer-Represented
5
Female Petitioner’s Unprecedented “Extended Terms” Motion
6
31. On 8/7/18, Defendant JOHN J. COUGHLIN DENIED Maravelias’s Objection
7
(Exhibit D) and GRANTED (Exhibit E) DePamphilis’s original 7/2/18 Motion
8
9 criminalizing Maravelias to “gain access to or possess” his accuser’s “[public] social media
10 communications”, even including public court exhibits where she made vulgar, incitative
11
cyberbullying posts to harass Maravelias, which proved she lied about having “fear” of
12
Maravelias to get a false, vindictive “stalking” order against him.
13
14 32. In his Order granting the “extended terms”, Defendant JOHN J. COUGHLIN
15 did not write a single word of statutory authority or legal reasoning for his shocking, reckless
16 order, nor wrote any response to Maravelias’s objection arguments whatsoever. Judge
17
Coughlin merely scribbled, “Respondent’s objection is DENIED”, on Maravelias’s 7/5/18
18
Objection and criminalized Maravelias to possess his own court exhibits.
19
20 33. Unlike issuing regular Stalking/DV civil protective orders and hearing
21 occasional extension requests thereof, granting indiscriminate “social media possession”
22
“extended terms” to such civil orders is not a task commonly performed by judicial officers.
23
24 34. Never in the entire life of Defendant JOHN J. COUGHLIN nor in the entire
25 history of the State of New Hampshire has a trial court previously granted “extended terms”
26 to an RSA 633:3-a civil protection order forbidding a respondent from “possessing” “directly
27
or through a third party” a petitioner’s “social media” as Defendants did on 8/7/18.
28

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1 35. Paragraph 41 of Maravelias’s 7/5/18 Objection explicitly forewarned Defendant
2 COUGHLIN that granting the “extended terms” would constitute an extrajurisdictional act
3
divesting of absolute judicial immunity.
4
The Inexplicable Procedural Anomalies of Defendant JOHN J. COUGHLIN’s Heedless
5
Post-Trial Orders, Showing His Bad-Faith and Patently Unreasonable Conduct
6
36. Defendant JOHN J. COUGHLIN, sua sponte, granted DePamphilis’s original
7
7/2/18 Motion and not even DePamphilis’s concessively ameliorated “further condition” as
8
9 conceded in her subsequent 7/12/18 Motion, in light of the 7/5/18 Objection. See Exhibit F.
10
37. The date “8/7/18” appears on Defendant COUGHLIN’s “granting” (Exhibit E)
11
DePamphilis’s original 7/2/18 Motion and on Defendant COUGHLIN’s denying-as-moot
12
DePamphilis’s 7/12/18 Reply containing her concessively ameliorated terms (Exhibit F).
13
14 38. However, inexplicably, the date “7/13/18” appears on Defendant COUGHLIN’s
15
four-word “Respondent’s objection is DENIED” ruling on Maravelias’s 7/5/18 Objection.
16
39. The day prior, on 7/12/18, Maravelias appeared before Defendant COUGHLIN
17
18 in a civil case as non-lawyer representative for Maravelias’s friend, a true stalking victim.
19
40. These facts suggest the mere renewed sight of Maravelias animated Defendant
20
COUGHLIN to 1) rub-out an immediate vindictive, mercurial “denied”-scribbling on
21
Maravelias’s pending objection within 24 hours of seeing Maravelias’s face and 2) later return
22
23 to the matter, after nearly one full month, to formalize his automatic granting DePamphilis’s
24 “extended terms” pleading: the more punitive version, even, which she herself had amended.
25
41. The non-responsive four-word nature of Defendant COUGHLIN’s 7/13/18 order
26
and all other foregoing facts indicate Maravelias was deprived his right to be fully heard.
27
28

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1 42. The totality of his judicial acts with Maravelias in 2018 uncovers a fact-pattern
2 suggesting Defendant COUGHLIN acted with hostile bias and in bad-faith. In further support,
3
Plaintiff repeats and incorporates by reference the judicially noticeable 10/31/18 pleading
4
filed in the 10th Circuit Court – Dist. Div. – Derry, entitled “Respondent’s Motion to Set
5
Aside Judgement” in 473-2016-CV-124 (available at the web URL: https://bit.ly/2VNfpsp).
6
7 Defendants’ Live and Imminent Threats as of May 2019, Since February 2019, to
Arrest Maravelias and Enforce the Illegal Order
8
9 43. On 1/24/19, DePamphilis moved the Circuit Court to extend her order again,
10 granted the same day. Defendants’ 8/7/18 “extended terms” are still in-effect.
11
44. In fall 2018, Plaintiff Maravelias had been a pro se litigant in two related appeal
12
cases in the New Hampshire Supreme Court regarding the DePamphilis/Maravelias parties.
13
14 45. On 2/8/19, Plaintiff Maravelias met with Sgt. Bryan Smith at the Windham
15
Police Department. Sgt. Smith, a WPD officer and Town of Windham employee, revealed
16
Defendants are now investigating Maravelias for violating the “extended terms” of the order.
17
18 46. For compelling detail on the threat of irreparable injury expected from
19 impending enforcement of these unlawful “extended terms”, Plaintiff Maravelias incorporates

20 by reference his forthcoming Motion for Preliminary Injunction and attached “Declaration in
21
Support” to be filed therewith, containing an assortment of verbatim quotes from the recent
22
2/8/19 conversation at WPD between Maravelias and Sgt. Smith.
23
24 47. In said conversation, Sgt. Smith produced a copy of an exhibit Maravelias
25 attached to a December 2018 Reply Brief Maravelias filed in one of his NH Supreme Court
26
appeals. Sgt. Smith asserted that it was one of DePamphilis’s social media communications
27
and that he would likely “arrest” Maravelias if his investigation fails to establish that the said
28
Exhibit had been part of any earlier court hearing.
- 10 -
1 48. The Exhibit in question is an image which proves DePamphilis boldly lied about
2 another part of her “stalking” accusations against Maravelias, where she falsely asserted it
3
was socially inappropriate for Maravelias to say hello to her at a 2015 graduation ceremony
4
Maravelias attended for his sister.
5
6 49. Sgt. Smith specifically identified Defendants’ 8/7/18 extended terms to the
7 protective order and explained he may arrest Maravelias for violating said terms.
8
50. Sgt. Smith said that he would likely “arrest” Maravelias if Maravelias was in
9
“possession” of certain public materials from “social media”, ostensibly referring
10
11 Maravelias’s own Supreme Court Reply Brief exhibit. In such an event, Defendants will
12 criminally prosecute Maravelias for violating the “extended terms” by possessing what they
13 claim is a public social media communication by DePamphilis, which is lawful for any other
14
person to possess.
15
16 51. Responding to Plaintiff’s Original Complaint, the Windham Defendants filed an
17 Answer on 4/17/19 itself confirming their unlawful enforcement threat is still ongoing, live,
18 and imminent. Maravelias is subject to a current criminal investigation for violating the
19
“extended terms”. Defendants will arrest Maravelias on “probable cause” that he rightfully
20
possessed public social media exhibits. See Answer, ECF Doc. #8, ¶83, 92, 97, 109, 118.
21
22 Past and Present Actual Harm and Injury Suffered by Maravelias As a Result of
Defendants’ Illegal Enforcement Threats
23
24 52. Ever since Defendants imposed the “extended terms”, Maravelias has feared
25 criminal prosecution and felt compelled to chill his public speech. In the 2/8/19 conversation,
26 Maravelias indicated he has felt compelled to forfeit defending his falsely maligned reputation
27
(from the underlying protective order) in certain ways he would pursue were the illegal
28
“extended terms” not constantly threatening his free speech with criminal penalties.
- 11 -
1 53. Defendants have stated to Maravelias their intention to engage in a course of
2 conduct affecting his constitutional interest. They have proven they are actively and
3
imminently threatening said interests by virtue of their current criminal investigation.
4
54. Maravelias has trembled in fear of punishment to take acts amounting to the
5
6 introduction of otherwise-lawful public internet images into his state court briefs/pleadings
7 which would otherwise benefit his position, because of the unlawful “extended terms”.
8
55. In order to attempt to comply with the unlawful “extended terms”, Maravelias
9
has been compelled to destroy and dispose of his own property as well as take elaborate pains
10
11 that other “third parties” do not cause Maravelias to commit a crime by virtue their own
12 “possession” or “gaining access” conduct.

13
56. Maravelias has suffered extreme emotional distress and trauma in connection
14
with being subject to such unlawful, arbitrary terms and not even being able to know the
15
16 precise legal functioning or definition of its vague terms “social media communication”,
17 “through a third party”, and “possess”. He lives in constant confusion and fear as a result.
18
Maravelias Has Possessed His Own Court-Admitted Evidentiary Exhibits and Plans to
19 Make Imminent Lawful Speech Acts Violating The Illegal “Extended Terms”
20 57. Maravelias delivered his 11/1/18 Appellant’s Brief to the Supreme Court. It
21
contained an appendical trial court exhibit depicting Christina DePamphilis’s incitative
22
middle-finger cyberbullying post, a “social media communication”, to Maravelias.
23
24 58. Maravelias denies “possessing” such “social media” which was not a previously
25 admitted court exhibit. However, Maravelias openly admits he has possessed the “middle-
26
fingers” social media post trial court exhibit.
27
28

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1 59. The Windham Defendants’ Answer alleges they have “communicated to
2 Plaintiff that [they] would not construe the possession of previously submitted court exhibits
3
to be a violation of the ‘extended terms.’” Answer, ¶69. However, the Windham Defendants’
4
previous “communications” (i.e., the 2/8/19 Sgt. Smith-Maravelias meeting at WPD) arguably
5
entailed no legal requirement of truthfulness. See e.g., Frazier v. Cupp, 394 U.S. 731 (1969).
6
7 60. The Windham Defendants’ Answer declines to stipulate that they will not
8 construe the extended terms as including “possession of previously submitted court exhibits”;
9
rather, only that they “have communicated” the said “to Plaintiff” in the past. This alarming
10
fact further prognosticates an imminent unlawful enforcement.
11
12 61. The “extended terms” contain no implicit exception for public court exhibits.
13
62. Maravelias will not chill his speech forever. He intends soon to violate the
14
“extended terms” by obtaining certain “social media” artifacts and using them in public
15
16 speech acts to prove the DePamphilis stalking order is nothing but a fraudulent legal
17 harassment mechanism extended in 2018 by a biased, rogue judge.
18
The Windham Defendants Are Acting in Bad-Faith with Disregard of Statutory and
19 Constitutional Law
20 63. Plaintiff respectfully alleges the Windham Defendants are acting in bad-faith
21
due to their personal credibility-interest in the false stalking order they themselves ignorantly
22
encouraged DePamphilis to pursue in December 2016, to the extent that they did.
23
24 64. The Windham Defendants enforce a stalking order they know was fraudulently
25 obtained, due to their possession and awareness of the aforementioned 2016 audio recording.
26
65. All Defendants have an obligation to know and follow the law, including the
27
28 United States Constitution, the “supreme law of the land”. U.S. CONST., Art VI, cl. 2.

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1 66. Given Maravelias’s 2/8/19 conversation with Sgt. Smith and, irrefutably, the
2 content of this very lawsuit, the Windham Defendants are now knowledgeably aware that
3
enforcing the “extended terms” is irredeemably unlawful in violation of the U.S. Constitution.
4
67. Despite this, the Windham Defendants’ Answer reconfirms their live, unabated
5
6 investigation and promises to enforce the “extended terms” by arrest on probable cause
7 Maravelias has violated said “extended terms”. They admit they are contemplating criminal
8 prosecution of Maravelias under RSA 633:3-a, I(c) as the statutory enforcement vehicle of the
9
“extended terms” and reveal that they are aware of the contents of said statute. Answer, ¶71.
10
11 68. The Windham Defendants’ non-existent excuse even within state law to persist
12 in threatening federally unconstitutional enforcement entails a further aspect of their alleged

13 bad-faith. The state civil stalking order criminal enforcement statute, RSA 633:3-a, I(c).,
14
confers standing upon Defendants to criminally prosecute “a single act of conduct that both
15
violates the provisions of the [civil] order and is listed in paragraph II(a).” (Emphasis added)
16
17 69. “Paragraph II(a)” of RSA 633:3-a does not include “possession” nor anything
18 remotely similar. It is a fully exclusive listing for purposes of RSA 633:3-a, I(c).
19
70. The Orwellian “extended terms” are criminally unenforceable, as Defendants
20
know, yet they persist in their imminent threats to arrest Maravelias on probable cause he has
21
22 engaged in constitutionally protected conduct violating the “extended terms”.
23
71. While violation of the “extended terms” is enforceable through a motion for
24
contempt in Derry Circuit Court, Defendants should be aware they are not criminally
25
enforceable because Paragraph 7 of Maravelias’s 7/16/18 Surreply (Exhibit G) noted this.
26
27 72. It is unknown by what legal authority Windham Defendants purport to derive
28
their alleged limiting construction of the “extended terms” to exclude “possession of

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1 previously submitted court exhibits”. Understandably baffled by the nightmarish disaster
2 Defendant JOHN J. COUGHLIN has created for them by his reckless abuse of power, the
3
Windham Defendants are enforcing the “extended terms” under an arbitrary set of halfway
4
principles consistent with neither federal constitutional law nor state statutory law.
5
6 73. The Windham Defendants threaten to institute criminal proceedings against
7 Maravelias they do not believe they could ever possibly result in a valid criminal conviction.
8
The 2018 NH Supreme Court Appeal and The Inapplicability of Rooker-Feldman
9
74. In the underlying case, Maravelias appealed the 2018 stalking order extension to
10
11 the New Hampshire Supreme Court (No. 2018-0483). They affirmed the extension.
12
75. The overriding thrust of the appeal was to vacate the 2018 extension of the
13
stalking order, not to challenge the constitutionality of Defendants’ “extended terms”.
14
15 76. The Supreme Court’s Final Order did not adjudicate any claim regarding the
16 “extended terms”. They neither affirmed nor reversed the “extended terms”. They affirmed
17 the extension of the underlying stalking order without ever addressing the “extended terms”.
18
77. Maravelias briefed his challenge to the “extended terms”, giving the NH
19
20 Supreme Court an opportunity to review the said. However, the they predictably excused
21 themselves from adjudicating these claims, retorting that the issue was not adequately briefed.
22
78. Maravelias had previously filed a 10/12/18 Motion in the appeal for an increased
23
brief word limit due to the necessity of compressing essentially two separate appeals into one
24
25 (both the overall extension of the order and the “extended terms”). The Supreme Court
26 DENIED the modest word limit increase request on 10/24/18 with no explanation.
27
79. Maravelias’s incorporates by reference his “Brief of Appellant” in 2018-0483.
28

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1 80. The Supreme Court denied Maravelias a full and fair opportunity to challenge
2 the “extended terms”. This is irrelevant for Rooker-Feldman inquiry. Questions of whether
3
Maravelias could have, should have, or actually did raise issues belong to preclusion law.
4
Rooker-Feldman, however, is a jurisdictional bar rendered inapplicable by the non-existence
5
of any final state court judgment adjudicating the constitutionality of the “extended terms”.
6
7 81. At the filing of this action, no state court, appellate or otherwise, had expressed
8 an opinion nor rendered any judgment on the constitutionality of the “extended terms”.
9
82. Maravelias’s said appeal also afforded the NH Supreme Court an opportunity to
10
11 adjudicate Maravelias’s facial overbreadth and void for vagueness challenges to RSA 633:3-a,
12 III-c. As with the “extended terms”, the Supreme Court declined to adjudicate these claims.
13
83. At the filing of this action, no state court, appellate or otherwise, had rendered
14
any judgment on Maravelias’s arguments that RSA 633:3-a, III-c. is facially overbroad and
15
16 void for vagueness.
17 84. The New Hampshire Supreme Court has been acting against Maravelias in bad-
18
faith. They have mysteriously redacted or self-censored their Final Orders in both of
19
Maravelias’s appeals from the public Supreme Court website in seeming shyness to disclose
20
their tyrannical sophistry against Maravelias to the public. They have retaliated against
21
22 Maravelias’s speech through an unprecedented punitive “Rule 23” order amounting to
23 extortion against Maravelias in the amount of $4,900.00. Maravelias hereby repeats and
24
incorporates by reference his forthcoming suit in this Honorable Court challenging Supreme
25
Court Rule 23, Paul Maravelias v. Supreme Court of New Hampshire, et al.
26
27 85. The NH Supreme Court has been failing to obey the proper de novo standard of
28 review to federal constitutional claims. Accordingly, even if the New Hampshire Supreme

- 16 -
1 Court had, in fact, adjudicated the claims Maravelias now brings here to challenge the
2 “extended terms”, Rooker-Feldman would still not apply.

3
86. Christina DePamphilis committed fraud and criminal falsification to obtain the
4
stalking order, the extension thereof, and the “extended terms”. Maravelias alleged the same
5
6 in the underlying proceedings.
7
87. Since the filing of this action, DePamphilis obtained another final extension of
8
the stalking order in Derry Circuit Court on 3/8/19. Multiple motions are pending. The
9
underlying case is ongoing and not “ended”.
10
11 88. Maravelias has not initiated an appeal of the recent 2019 extension. The
12
“extended terms” are still in effect, never having been adjudicated in the NH Supreme Court.
13
89. Defendant JOHN J. COUGHLIN, as an officer of the New Hampshire Circuit
14
15 Court, had no general equitable powers within the RSA 633:3-a civil protective order case.
16
90. DePamphilis had a clearly defined statutory right to petition Defendant
17
COUGHLIN to extend the stalking order in 2018. However, she had no state or federal
18
statutory, constitutional, equitable, or common-law right to the “extended terms” granted.
19
20 91. Defendant JOHN J. COUGHLIN’s 8/7/18 Order granting the “extended terms”
21 is not a judicial act nor a state court “judgment”. It did not adjudicate any claim to a “right”.
22
92. Defendant JOHN J. COUGHLIN’s 8/7/18 Order contained no opinion or finding
23
24 on the constitutionality of the “extended terms” granted therein.
25
26
27
28

- 17 -
1 COUNT 1
VIOLATION OF THE FIRST AMENDMENT TO THE
2
UNITED STATES CONSTITUTION (42 U.S.C. §1983)
3 Defendants’ “Extended Terms” Within a Standard Civil
4 Stay-Away Order Abridge Maravelias’s Free Speech and Press Rights
5
93. All paragraphs hereinabove are repeated herein as though fully set forth.
6
7 94. The First Amendment to the U.S. Constitution guarantees that “Congress shall
8 make no law . . . abridging the freedom of speech”. It is incorporated against the states.
9
95. Defendants’ civil “stalking” “protective” order against Maravelias in its current
10
form, through their “extended terms” granted on 8/7/18 with no explanation at all, violates
11
12 Maravelias’s constitutionally protected free speech and press rights.
13 96. The “extended terms” constitute a prior restraint against Maravelias exercising
14
his protected freedoms to speech and press, even absent the imminent enforcement threat. By
15
possessing, publicizing, or expressing himself with certain evidentiary exhibits deemed
16
DePamphilis’s “social media communications”, Defendants will punish Maravelias with
17
18 criminal prosecution – nominally, for violating a civil stalking protective order pursuant to
19 RSA 633:3-a.
20
97. Defendants are now likely to arrest Plaintiff Maravelias because of his
21
publication to the New Hampshire Supreme Court of a Reply Brief containing an appendical
22
23 exhibit alleged to be a “social media communication” of DePamphilis. This exhibit shows that
24 DePamphilis lied to obtain a false “stalking” protective order by which Defendants’ 8/7/18
25 Order against Maravelias, imposing the “extended terms”, operates to begin with.
26
98. Defendants’ 8/7/18 “extended terms” are not narrowly tailored to serve a
27
28 significant governmental interest. The governmental interest behind civil stalking protective

- 18 -
1 orders is to protect true victims of stalking from violent acts, not to criminalize the process of
2 a respondent in such a proceeding from defending himself in the court system, using public
3
evidentiary exhibits from “social media” to defend himself against claims of “stalking”.
4
99. Defendants’ 8/7/18 extended terms do not appropriate any alternative channel by
5
6 which Maravelias could defend himself in the legal system where his accuser’s public “social
7 media exhibits” are profitable for his legal self-defense in the court system.
8
100. Defendants’ 8/7/18 extended terms do not appropriate any alternative channel by
9
which Maravelias could publicly share said “social media” evidentiary materials (e.g., on the
10
11 internet) to defend his name and reputation from defamatory and false “stalking” accusations,
12 without fearing criminal prosecution by the State of New Hampshire.

13
101. Defendants’ extended terms therefore implicate Maravelias’s right to be free
14
from reputational and social stigma. Said terms have chilled Maravelias’s public speech
15
16 which he would have otherwise made to defend his name from the false stalking accusations
17 both in the court system and on the internet, where necessitating exhibits from “social media”.
18 They also implicate his right to be left alone, since Defendants will arrest him for
19
“possession” and any lawful expression evidencing “possession”.
20
102. The above is neither theory nor speculation: Sgt. Smith asserted to Maravelias
21
22 on 2/8/19 his Supreme Court Reply Brief exhibit is inculpatory evidence of “possession”.
23
103. Defendants’ extended terms are unconstitutionally overbroad because they
24
prohibit, chill, and regulate a significant amount of legitimate speech even if some possible
25
applications of them could prevent unlawful speech.
26
27 104. Defendants’ extended terms are unconstitutionally overbroad for being both
28
overinclusive and underinclusive. As-applied, the extended terms do not prohibit any

- 19 -
1 unprotected criminally threatening or obscene speech, but rather prohibit public speech
2 necessary for Maravelias to defend himself within the New Hampshire court system.
3
105. The United States Supreme Court’s decision in Packingham v. North
4
Carolina, 582 U. S. ___ (2017) illustrates the irredeemably unlawful nature of Defendants’
5
6 despotic “social media possession” prohibition against Plaintiff. The Packingham court
7 nullified a North Carolina criminal statute prohibiting convicted sex offenders from accessing
8 certain social media sites. By comparison, Plaintiff here is subject to a civil “stalking”
9
“protective” order – issued without even the allegation of any criminal conduct – and is
10
thereby bound to Defendant JOHN J. COUGHLIN’s arbitrary “extended terms” themselves
11
12 more restrictive than the nullified North Carolina statute in Packingham (i.e., prohibiting
13 Maravelias’s mere ongoing “possessing [any]” “social media” screenshots or exhibits, as
14 opposed to newly “accessing [certain]” social media, as with the North Carolina statute).
15
106. Defendants, acting under color of state law, have threatened to and will enforce
16
and implement the above-identified “extended terms” against Plaintiff Maravelias, in
17
18 violation of his First Amendment rights to freedom of speech and press.
19
107. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff
20
Maravelias has and will suffer irreparable harm and injury, which will continue absent relief.
21
Wherefore, Plaintiff respectfully prays the Court grant the relief set forth hereunder in the
22
23 section entitled “Prayer for Relief”.
24
COUNT 2
25 VIOLATION OF PART I, ARTICLE 22
26 OF THE NEW HAMPSHIRE CONSTITUTION
27
28

- 20 -
1 109. Plaintiff repeats the aforecited authorization for his state law claims under this
2 Court’s supplemental jurisdiction, which arise from the same set of facts and
3
transactions/occurrences giving rise to the federal causes of action in this Complaint.
4
110. Part I, Article 22 of the New Hampshire Constitution offers even broader
5
6 protections for free speech rights than the U.S. Constitution.
7
111. Accordingly, the Defendants, acting under color of state law, have threatened to
8
and will enforce and implement the above-identified “extended terms” against Plaintiff
9
Maravelias, in violation of his rights under Part I, Article 22 of the NH Constitution.
10
11 112. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff
12
13
14
section entitled “Prayer for Relief”.
15
16
COUNTS 3, 4, AND 5
17 VIOLATION OF SUBSTANTIVE AND PROCEDURAL DUE-PROCESS
UNDER THE FOURTEENTH AMENDMENT TO THE
18
UNITED STATES CONSTITUTION (42 U.S.C. §1983)
19
20
21 114. The Fourteenth Amendment guarantees that “no state shall make or enforce any
22 law which shall abridge the privileges or immunities of citizens of the United States; nor shall
23
any state deprive any person of life, liberty, or property, without due process of law…”.
24
Count 3: The “Extended Terms” Violate Due Process Since They Are
25
Unconstitutionally Vague
26
115. Defendants’ nominal “extended terms” against Maravelias violate and disparage
27
28 his rights guaranteed by the Fourteenth Amendment to the U.S. Constitution. Said terms are

- 21 -
1 unconstitutionally vague, in violation of due process protections, for failing to define what
2 counts as “possession” of a “social media communication”, what counts as “third party”

3
“possession” of the same, what counts as “direct” “possession” of the same, or even what
4
counts as a “social media communication” to begin with (e.g., whether usage of a social
5
media app itself is necessary to “possess” such a “communication”, or whether a static
6
7 photographic “screenshot” reproduction of a “social media communication” visualized on
8 another’s device is itself a “communication” or merely an indication or record of such a
9 “communication” existing elsewhere).

10
116. The vagueness of Defendant’s extended terms terms invites arbitrary and
11
12 discriminatory enforcement, and they are unintelligible a person of average intelligence.
13 117. Defendants’ present and imminent threat to criminally enforce the illegal order
14
already underscores the untenable problems of vagueness in their extended terms. In
15
Maravelias’s 2/8/19 conversation with Sgt. Smith, there was disagreement whether the Reply
16
Brief exhibit is a “social media communication”.
17
18 118. On its face, the extended terms appear to criminalize Maravelias’s mere
19
“possession” of public court exhibits, necessarily “depriving” him of that property by forcing
20
him to relinquish and discard said property lest he face criminal punishment.
21
22 119. Defendants’ extended terms against Maravelias also produce the absurd result
23 that Christina DePamphilis’s possessing her own “social media communications”

24
automatically criminalizes Maravelias, since he has access to public court documents where
25
her said “communications” are already entered as exhibits and/or since he has a legal right
26
subpoena them from her; therefore, Maravelias could be said to “possess” by a “third-party”
27
28

- 22 -
1 (DePamphilis herself) the said “communications”, according to reasonable interpretation of
2 the vague term “third-party [possession]” in Defendants’ outrageous 8/7/18 extended terms.
3
120. The same can be said for virtually any instance of Maravelias’s friend or family
4
member merely reading a copy of his Supreme Court briefs or viewing the record of the case.
5
6 121. Defendants’ vague extended terms contain zero due-process protection
7
mechanisms by which Maravelias would not be require automatically to discard and not
8
“possess” any items which might be “social media communications” even if they are public
9
court exhibits for his own cases.
10
11 Count 4: The “Extended Terms” Violate Procedural Due Process Since They
Contained No Advanced-Noticed Starting Effective Date and Therefore
12
Inescapably Entrap Their Subject into Committing a Crime
13
122. Defendants’ extended terms against Maravelias are worded such that it would be
14
impossible to obey them. Since they contain no effective starting date, they took-effect and
15
16 began to criminalize any “possession” of public court exhibits as soon as Judge Coughlin
17 signed the Order, before notifying Maravelias that the extended terms were granted. The
18 extended terms contain no practical procedures for compliance, such as a provision that
19
certain things currently in “possession” must be destroyed or relinquished by a certain time.
20
123. Since Maravelias cannot un-destroy destroyed items, it cannot be argued that
21
22 Maravelias could have temporarily destroyed such exhibits pending Judge Coughlin’s ruling.
23
Count 5: The “Extended Terms”, Masquerading Under the Procedural Guise of
24 a Common Civil Protective Order, Violate Substantive Due Process Since They
are Ultra Vires Issued in Complete Absence of Legal Authority
25
124. First, Defendant JOHN J. COUGHLIN acted in reckless defiance of statutory
26
27 authority on 8/7/18 when he ordered the extended terms against Maravelias by and through
28

- 23 -
1 “further conditions” to a civil stalking protective order. New Hampshire state law precisely
2 regulates said civil protective orders and enumerates the types of relief which may be granted.
3
125. Defendants’ extended terms are in excess of the permitted forms of relief for NH
4
civil stalking protective orders. The local NH district courts have jurisdiction over civil
5
6 stalking protective orders under RSA 633:3-a. RSA 633:3-a, III-a states, “The types of relief
7 that may be granted [with such civil protective orders] … shall be the same as those set forth
8 in RSA 173-B [the similar statute controlling Domestic Violence protective orders]”.
9
126. RSA 173-B:5 exclusively enumerates the forms of additional relief New
10
11 Hampshire state courts may grant in such DV or stalking protective orders, as follows:
12 “(a) Protective orders:

13 (1) Restraining the defendant from abusing the plaintiff.
(2) Restraining the defendant from entering the premises and curtilage where the plaintiff resides,
14 except when the defendant is accompanied by a peace officer and is allowed entry by the plaintiff
for the sole purpose of retrieving personal property specified by the court.
15
(3) Restraining the defendant from contacting the plaintiff or entering the plaintiff’s place of
16 employment, school, or any specified place frequented regularly by the plaintiff or by any family
or household member.
17 (4) Restraining the defendant from abusing the plaintiff, plaintiff’s relatives, regardless of their
18 place of residence, or plaintiff’s household members in any way.
(5) Restraining the defendant from taking, converting, or damaging property in which the plaintiff
19 may have a legal or equitable interest.
(6) Directing the defendant to relinquish to the peace officer, in addition to the relief specified in
20
RSA 173-B:5, I, any and all deadly weapons…
21 (7) Granting the petitioner exclusive care, custody, or control of any animal owned, possessed,
leased, kept, or held by the petitioner….
22 (b) Other relief including, but not limited to:
(1) Granting the plaintiff the exclusive use and possession of the premises and curtilage of the
23
plaintiff’s place of residence…
24 (2) Restraining the defendant from withholding items of the plaintiff’s personal property specified
by the court. A peace officer shall accompany the plaintiff in retrieving such property to protect
25 the plaintiff.
26 (3) Granting to the plaintiff the exclusive right of use and possession of the household furniture,
furnishings, or a specific automobile…
27 (4) Ordering the defendant to make automobile, insurance, health care, utilities, rent, or mortgage
payments.
28
(5) Awarding temporary custody of the parties’ minor children to either party or, where

- 24 -
1 appropriate, to the department, provided that: …
(6) Establishing visitation rights with regard to the parties’ minor children. …
2 (7) Directing the defendant to pay financial support to the plaintiff or minor children, unless the
defendant has no legal duty to support the plaintiff or minor children.
3
(8) Directing the abuser to engage in a batterer’s intervention program or personal counseling. …
4 (9) Ordering the defendant to pay the plaintiff monetary compensation for losses suffered as a
direct result of the abuse which may include, but not be limited to, loss of earnings or support,
5 medical and dental expenses, damage to property, out-of-pocket losses for injuries …
6 (10) Ordering the defendant to pay reasonable attorney’s fees.”
7
127. Absolutely nowhere in either the New Hampshire civil stalking protective order
8
statute nor the procedurally-controlling DV protective order statute are Defendants authorized
9
to enjoin broad prophylactic injunctions against the free speech and due process rights to
10
11 “possess” public “social media communications” from the internet for one’s legal defense.
12
128. Second, as an officer of the NH local Derry District Court, Defendant JOHN J.
13
COUGHLIN did not have any general equitable jurisdictional power to enjoin such terms
14
against Maravelias even if they were not otherwise unconstitutional. The NH local District
15
16 Court has jurisdiction over such civil stalking protective order cases pursuant to RSA 502-
17 A:14, “Civil Causes. – I. Exclusive Jurisdiction” which states, “all district courts shall have
18 original and exclusive jurisdiction of civil cases in which the damages claimed do not exceed
19
$1,500”. The NH District Court does not have general equitable powers, which is reserved to
20
the NH Superior Court. See RSA 498:1, “Jurisdiction”, which states “the superior court shall
21
have the powers of a court of equity in … cases in which there is not a plain, adequate and
22
23 complete remedy at law; and in all other cases cognizable in a court of equity”. Thus,
24 Defendant JOHN J. COUGHLIN, within a civil stalking protective order case, had no legal
25 authority to grant relief not specifically authorized by the controlling statute(s) therefor.
26
27
28

- 25 -
1 129. Accordingly, Defendant JOHN J. COUGHLIN’S 8/7/18 order granting the
2 extended terms against Maravelias constitutes an arbitrary, despotic act done ultra vires in
3
total absence of constitutional, statutory, and jurisdictional authority.
4
130. Defendant JOHN J. COUGHLIN’S conduct was extreme and outrageous,
5
6 malicious, wanton and reckless, shocking to the conscience, completely outside the
7 boundaries of propriety and lawfulness, and contemptuous of the moral ethos of the State of
8 New Hampshire and the United States of America.
9
131. Defendants acted willfully, knowingly, and maliciously in a coordinated effort
10
11 to disparage pro se Paul Maravelias’s federal constitutional rights by unilateral acts of judicial
12 tyranny: Maravelias’s 7/5/18 Objection articulately warned Defendants of the illegality of the
13 proposed extended terms and that granting them would be in excess of legal authority. See
14
Paragraphs 23 through 25 of Maravelias’s 7/5/18 Objection. (Exhibit B)
15
16 132. Jointly regarding Counts 3, 4, and 5, the Defendants, acting under color of state
17 law, have threatened to and will enforce and implement the above-identified “extended terms”
18 against Plaintiff Maravelias, in violation of his Fourteenth Amendment due process rights.
19
133. Jointly regarding Counts 3, 4, and 5, as a direct and proximate result of
20
Defendants’ unlawful conduct, Plaintiff Maravelias has and will suffer irreparable harm and
21
22 injury, which will continue absent relief. Wherefore, Plaintiff respectfully prays the Court
23 grant the relief set forth hereunder in the section entitled “Prayer for Relief”.
24
25 COUNT 6
VIOLATION OF EQUAL PROTECTION UNDER THE FOURTEENTH
26 AMENDMENT TO THE UNITED STATES CONSTITUTION (42 U.S.C. §1983)
27
28

- 26 -
1 135. The Fourteenth Amendment guarantees that “no state shall ... deny to any person
2 within its jurisdiction the equal protection of the laws.”

3
136. Never before in history has a NH Circuit Court ordered a civil stalking order
4
respondent not to “possess” “directly or through a third-party” “social media
5
6 communications” of a petitioner.
7
137. Since Defendants’ extended terms were issued without any legal authority (See
8
supra), other NH civil stalking protective order respondents are not – nor ever have been –
9
ordered in a fashion which similarly-situated Maravelias has been ordered here.
10
11 138. Equivalently, no other petitioners in such actions are enabled to have their
12
opponents “ordered” to not “possess” public internet evidence as part of their opposing case,
13
as similarly-situated DePamphilis has been enabled here.
14
15 139. Defendant JOHN J. COUGHLIN did not even attempt to justify his 8/7/18 order
16 nor make any specific findings of fact or law harmonizing the extended terms to the particular
17 contours of the Maravelias-DePamphilis case. He just reflexively scribbled “DENIED” on
18
Maravelias’s Objection and “GRANTED” on DePamphilis’s original Motion.
19
20 140. Accordingly, Defendants’ extended terms violate the Equal Protection clause,
21 since similarly situated petitioners and respondents in New Hampshire civil stalking
22 protective order proceedings are currently accorded inconsistent, unequal rights.
23
24
25 and implement the above-identified “extended terms” against Plaintiff Maravelias, in
26 violation of his Fourteenth Amendment equal protection rights.
27
28
- 27 -
1 Wherefore, Plaintiff respectfully prays the Court grant the relief set forth hereunder in the

3
4 COUNT 7
EX POST FACTO LAW UNDER ARTICLE II § 10 cl. 1 OF
5 THE UNITED STATES CONSTITUTION (42 U.S.C. §1983)
6
7
8 144. Since Defendants’ extended terms did not contain any effective start date, they
9 became enforceable with the underlying stalking order in relation to all times said stalking
10
order was in effect, whether before the 8/7/18 granting of said terms or not.
11
12 145. The extended terms therefore violate the Ex Post Facto clause of the U.S.
13 Constitution, criminalizing Maravelias for any “possession” after the protective order was
14 extended but before the “extended terms” were granted.

15
16
and implement the above-identified “extended terms” against Plaintiff Maravelias, in
17
18 violation of the Ex Post Facto clause of the U.S. Constitution.
19
20
21
22
24
COUNT 8
25 NH RSA 633:3-A, III-C. IS FACIALLY OVERBROAD IN
26 VIOLATION OF THE FIRST AMENDMENT TO THE U.S. CONSTITUTION
27 148. All paragraphs hereinabove are repeated herein as though fully set forth.
28

- 28 -
1 149. Defendants’ unlawful extended terms against Maravelias are in-effect by the
2 existence of an extended civil stalking protective order, extended pursuant to RSA 633:3-a,
3
III-c. In relevant part, the said statute reads:
4
“Any order under this section shall be for a fixed period of time not to exceed one year, but may
5
be extended by order of the court upon a motion by the plaintiff, showing good cause, with notice
6 to the defendant, for one year after the expiration of the first order and thereafter each extension
may be for up to 5 years, upon the request of the plaintiff and at the discretion of the court. The
7 court shall review the order, and each renewal thereof and shall grant such relief as may be
necessary to provide for the safety and well-being of the plaintiff.” (Emphasis added)
8
9
150. Maravelias has standing to bring this facial challenge. He was affected by RSA
10
633:3a, III-c. in the past and could likely be in the future. However, he is not currently subject
11
to any current criminal prosecutions under RSA 633:3-a.
12
13 151. This statute permits extension of such protective orders if plaintiff’s “well-
14 being” primarily would be jeopardized without an extension, even if concern for “safety” is
15
minimal. The Oxford English Dictionary defines “well-being” as “the state of being
16
comfortable, healthy or happy.” Therefore, if a petitioner merely alleges she would be
17
18 “uncomfortable” or “unhappy” without the extension, the state court is required to extend it.
19 152. Said protective orders inflict extensive restrictions against a subject’s

20
constitutional rights, such as no-contact and firearms relinquishment orders.
21
22 153. The statute is therefore facially overbroad in violation of the First Amendment,
23 because it enables trial courts to extend such protective orders based on a respondent’s
24 constitutionally protected non-threatening public speech which could “discomfort” the

25
petitioner, thereby triggering the overbroad “well-being” standard for extension.
26
27 154. The statute’s language is therefore not narrowly-tailored to serve a significant
28 governmental interest. It does not grant respondents any alternative channels to express

- 29 -
1 themselves in public which could “discomfort” or “displease” petitioners without being
2 punished by extended-duration restrictions of their constitutional rights. The overbroad statute

3
therefore has a chilling effect against appropriate speech to such protective order respondents.
4
155. The “well-being” standard in the statute is overbroad also because it is not
5
6 narrowly-tailored to serve the actual governmental interest of the statute, which is not
7 preventing “displeasure” or “discomfort” of petitioners, but rather protecting them from

8 “stalking” – conduct causing a “reasonable person to fear for their physical safety”.
9
See RSA 633:3-a, I.
10
11 156. The “well-being” standard in the statute inescapably renders it a content-based
12 speech regulation, since a respondent’s public expression which is “displeasing” to the

13 petitioner would alone satisfy the “well-being” standard for extending it, whereas agreeable
14
public speech not upsetting the petitioner would not trigger the “well-being” standard.
15
16 157. The statute is both overinclusively and underinclusively not narrowly tailored.
17 First, it punishes respondents’ acts of public expression which are not contrary to the
18 governmental interest of preventing stalking (e.g., publicly disagreeing with the fact that a
19
stalking order was issued). Second, it fails to equally punish new stalking order defendants
20
with its overbroad “well-being” extension standard. Cf. RSA 633:3-a, III-a, the more stringent
21
legal standard for initial issuance of a stalking order requiring a “stalking course of conduct”,
22
23 as opposed to mere indication that granting the order serves a petitioner’s “well-being”.
24
158. This overbroad “well-being” standard is applied in every single stalking order
25
extension case under RSA 633:3-a, III-c. There are no constitutionally valid ways for NH
26
courts to implement this statute without disobeying it. Even if the statute simply read “safety
27
28 or well-being” instead of “safety and well-being”, courts would at least have some leeway to

- 30 -
1 avoid an unconstitutionally broad application in every case. However, the statute’s plain
2 language implies it is substantially overbroad necessarily for every single application thereof.
3
159. Defendants, acting under color of state law, are enforcing a facially overbroad
4
statute, RSA 633:3-a, III-c., in violation of the First Amendment to the U.S. Constitution.
5
6 Wherefore, Plaintiff respectfully prays the Court grant the relief set forth hereunder in the

8
COUNT 9
9 NH RSA 633:3-A, III-C. IS FACIALLY VOID FOR VAGUENESS IN VIOLATION
10 OF THE FOURTEENTH AMENDMENT TO THE U.S. CONSTITUTION
11
12
161. “A statute can be impermissibly vague for either of two independent reasons.
13
14 First, if it fails to provide people of ordinary intelligence a reasonable opportunity to
15 understand what conduct it prohibits. Second, if it authorizes or even encourages arbitrary and
16 discriminatory enforcement.” Hill v. Colorado, 530 U.S. 703,732 (2000).
17
162. The language of RSA 633:3-a, III-c. is unintelligible and so loosely constrained
18
19 that arbitrary, discriminatory enforcement thereof is inevitable. Not only is the term “well-
20 being” too vague, but also the extent to which the preceding term “safety” narrows or
21 qualifies “well-being”.
22
163. This vagueness is substantially likely or guaranteed to complicate every stalking
23
24 order extension case brought before NH state courts, regardless of the particular facts of such
25 cases. The statute provides zero guidance on how trial court judges should interpret “well-
26 being”, or on what conduct beyond threatening speech or actual violence would permit
27
extension not necessarily to serve a plaintiff’s “safety”, but rather their “well-being”.
28

- 31 -
1 164. For instance, one judge might consider a “well-being” order ridiculous and far
2 in-excess-of the legislative counter-stalking intent, calibrating his or her judgements to the
3
statute’s broad “safety” context, even applying ejusdem generis to constrain “well-being”
4
thereby. However, another judge might reject this interpretation, “safety and well-being” not
5
being a list, and adopt the plain meaning of the word “well-being”.
6
7 165. The statute’s vagueness is not only semantic but also syntactic, fraught with
8 meaningful ambiguity between the co-possible constructions “shall grant such relief as may
9
be necessary to provide for the (safety and well-being)” and “… relief as may be necessary to
10
provide for the safety, and (relief as may be necessary to provide for the) well-being”. The
11
12 former interpretation begets tautology, the latter overbroad plaintiff-sycophancy. Both
13 interpretations are reasonable but produce vastly different legal outcomes.
14
166. The comparable protective order laws of no other US state discard the initial-
15
issuance-standard for something pointlessly different for extension, as does New Hampshire’s
16
unconstitutionally defective statute. For example, the analogous Massachusetts statute for
17
18 extension of Civil Harassment Orders, M.G.L. 258E §3(d), states in relevant part that “the
19 court [may extend] the [harassment] order … as it deems necessary to protect the plaintiff
20 from harassment.” Id. It does not switch the legal standard to something different and
21
overbroad when it concerns extension, requiring a “stalking course of conduct” for an original
22
order but only vague “interest in well-being” for subsequent extensions, as with the defective
23
24 New Hampshire statute. Cf. also 19-A M.R.S. 4007(2), the analogous Maine statute
25 controlling extension of DV protective orders following civil adjudications of “abuse”: “the
26 court may extend an order, upon motion of the plaintiff, for such additional time as it
27
determines necessary to protect the plaintiff … from abuse.”
28

- 32 -
1 167. That a statute’s unintelligibility to an average person and propensity for arbitrary
2 enforcement violates the due process rights guaranteed by the Fourteenth Amendment is
3
pellucid – especially here, where said vague statute controls the extension of court orders
4
severely limiting other federal constitutional rights.
5
6 168. Defendants, acting under color of state law, are enforcing an unconstitutionally
7 vague statute, RSA 633:3-a, III-c., in violation of the Fourteenth Amendment to the U.S.
8 Constitution. Wherefore, Plaintiff respectfully prays the Court grant the relief set forth
9
hereunder in the section entitled “Prayer for Relief”.
10
11 PRAYER FOR RELIEF
12
13 WHEREFORE, Plaintiff Paul Maravelias respectfully requests this Honorable Court:
14 I. Issue a preliminary injunction prohibiting all non-judicial Defendants and their

officials, employees, and agents from implementing or enforcing the said
15
“extended terms” to the civil protective order against Maravelias in New
16 Hampshire Circuit Court Case No. 473-2016-CV-00124;
17
II. Enter a declaratory judgment that Defendants’ said criminally-enforceable
18 “extended terms” violate Maravelias’s civil constitutional rights as guaranteed by
the First Amendment to the U.S. Constitution;
19
20 III. Enter a declaratory judgment that Defendants’ said criminally-enforceable
“extended terms” violate Maravelias’s civil constitutional rights as guaranteed by
21
Part I, Article 22 of the New Hampshire Constitution;
22
IV. Enter a declaratory judgment that Defendants’ said criminally-enforceable
23
“extended terms” violate Maravelias’s due process and equal protection rights as
24 guaranteed by the Fourteenth Amendment to the U.S. Constitution;
25
V. Enter a declaratory judgment that Defendants’ said “extended terms” to the civil
26 protective order are in excess of NH state statutory protective order law;
27
VI. Enter a declaratory judgment that Defendants’ said “extended terms” to the civil
28 protective order violate the Ex Post Facto clause of the U.S. Constitution;

- 33 -
1 VII. Enter a declaratory judgment that New Hampshire RSA 633:3-a, III-c. is
unconstitutionally overbroad on its face in violation of the First and Fourteenth
2
Amendments to the U.S. Constitution;
3
VIII. Enter a declaratory judgment that New Hampshire RSA 633:3-a, III-c. is
4 unconstitutionally vague on its face in violation of the Fourteenth Amendment to
5 the U.S. Constitution;
6 IX. Enter a permanent injunction to prevent future unlawful conduct by Defendants;

7
X. Award Plaintiff the reasonable costs and disbursements of this action;
8
9 XI. Grant any further relief as may be deemed just and proper.
10
11
12 I, Paul Maravelias, declare that all factual stipulations within the foregoing
First Amended Verified Complaint are true and accurate to the best of my
13 knowledge as of 5/6/2019.
14
15 Respectfully submitted,
16
17 PAUL J. MARAVELIAS
18
in propria persona
19
20
21
22
23
24 /s/ Paul J. Maravelias, pro se Dated: May 6th, 2019
25 Paul J. Maravelias
34 Mockingbird Hill Rd
26 Windham, NH 03087
[email protected]
27 603-475-3305
28

- 34 -
1 CERTIFICATE OF SERVICE
2 I, Paul Maravelias, certify that a timely provided copy of this document is being sent on
3 this date to all counsel of record for the Defendants pursuant to the rules of this Court.
4 /s/ Paul J. Maravelias, pro se Dated: May 6th, 2019

5 Paul J. Maravelias
6
7
8
9
10
11
12
13
14
15
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18
19
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21
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- 35 -
EXHIBIT A
EXHIBIT A
EXHIBIT A
EXHIBIT B
EXHIBIT B
THE STATE OF NEW HAMPSHIRE
ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY
Docket No. 473-2016-CV-00124
Christina DePamphilis
v.
Paul Maravelias
RESPONDENT’S OBJECTION TO PETITIONER’S MOTION FOR MODIFICATION OF

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

DOCUMENTED ILLEGAL BEHAVIORS AND EMPOWER HER TO CONTINUE VIOLATING
THE LAW, AND IS BUT ANOTHER PREDICTABLE ACT IN HER CONTINUED CAMPAIGN
OF LEGAL HARASSMENT AGAINST MARAVELIAS
1
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
EXHIBIT B
2. As this Court will remember, Christina DePamphilis has cruelly bullied the victim, Mr.
Maravelias, with incitative, vulgar, and insulting posts on her public social media profile(s)
during the pendency of her criminally falsified “stalking” order against the victim/Respondent.
3. She now seeks to have this Court outlaw Maravelias’s mere possessing a record of her
behavior.
4. In particular, in June 2017, Petitioner posted an inflammatory picture of her boyfriend
directly addressing the victim and making incitative comments against him (6/19/18).
5. After failing to elicit any response from Maravelias that would violate her bad-faith
“stalking” order against him, she then posted a rehearsed image of herself, her father David
DePamphilis, and her 21-year-old boyfriend Matthew LaLiberte, all middle-fingering the victim,
and also making an incitative comment against the victim which identified him.
6. Viewed in the light of her acts of criminal harassment (RSA 644:4) against Mr.
Maravelias, the Petitioner’s present motion to prohibit Maravelias from “gaining access” to or
even “possessing” these public posts, even from “third parties”, is a risible perversion of
propriety.
7. Essentially, Christina DePamphilis wishes to be legitimated by this Court to continue
her vulgar harassment of Mr. Maravelias while injunctively restraining him from even using her
outrageous public social media exhibits for legal purposes to defend himself. This Court should
feel insulted by such a disrespectful and inappropriate attempt to abuse its power.
8. The Petitioner’s continued conduct of filing baseless motions against the victim is for
no valid purpose beyond solely to harass him; this Court should impose sanctions against her
accordingly for such repeated and patently unreasonable motions against Mr. Maravelias.
2
EXHIBIT B
9. Furthermore, the Petitioner’s motion attempts to excuse her generic illegal behaviors,
past and future, demonstrated on her social media, in which Mr. Maravelias is not the victim.
10. In the Motion to Extend Hearing, this Court accepted inter alia a relevant evidentiary
exhibit of the “minor” Petitioner – a picture from her social media. In this post, she had pictured
herself, at age 16, holding a purse in her right hand and an open bottle of vodka in her left while
leaving a party at “4:43am”, with her parked, about-to-be-driven car in the background.
11. Christina DePamphilis also documented her psychoactive substance abuse, her private
sexual behaviors1, and her further underage alcoholic consumption in other social media
postings.
12. Thus, the Petitioner’s current desire to handcuff Maravelias in his public free speech
rights to third-parties is but a panicked “futile attempt” to avoid responsibility for her pictured
acts of law-breaking and perjury2, should Maravelias discontinue his magnanimous decline so-
far to lawfully document said public postings on the web, as he lawfully threatened to do in a
November 2017 response to Attorney Brown’s out-of-the-blue threatening letter3.
1
If this Court were to grant Petitioner’s Motion and thereby enter the enterprise of unlawfully policing private
conducts of speech, it would at least be equitable for the Court to order Christina DePamphilis to cease and desist
making improper posts revealing her private sexual behaviors before peers. Upon information and belief, this
behavior is socially unacceptable, and is considered disturbing by her peers. It is not practiced by other youth, even
by ones who picture themselves violating state laws on alcohol/marijuana consumption. While the latter is at least
somewhat socially acceptable, the Petitioner has caused discomfort to her peers with her unwanted social media
indications of her private sex life. These should never be publicly posted on social media, especially given her age.
2
Christina DePamphilis maintained her false claim under oath on 5/3/18 that she has “fear for her physical safety”
of Mr. Maravelias, despite her abusive, harassing, and unlawful conduct victimizing Mr. Maravelias. Indeed, this
Court has validated Christina DePamphilis’s hurtful law-breaking, in wrongfully granting an extension on her
Stalking Order. That matter is pending this Court’s review in a reconsideration pleading filed by Respondent.
3
Maravelias has every right to publicly republish her legally-public postings, as acknowledged by the mere
existence of the instant motion by Petitioner, the daughter of David DePamphilis, to injunct against said right.
3
EXHIBIT B
13. The Petitioner requests that it be unlawful for Maravelias to even “possess” her social
media postings. This is so absurd that it would criminalize Mr. Maravelias for merely owning his
copy of this Court’s own public evidence exhibits from this case which he used at Hearing.
14. Thus, it would also violate the “Right to Know” law (91-A), guaranteeing access to
public court records, e.g. Christina DePamphilis’s posting of herself middle-fingering her victim.
15. While it is strongly speculated that there are many photographs in existence of the 17-
year-old female Petitioner which are already quite unlawful for anyone to even possess4, these
are most certainly not the public social media postings in question, which are fully lawful for
legal use.
B. PETITIONER’S MOTION DISHONESTLY OMITS PARTS OF MARAVELIAS’S ALLEGED

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

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

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

window late at night to escape to a party in secret;
e. A video wherein Christina brags of “passing” a field sobriety test a police officer
administered to her when pulled over returning from said party;
f. A photograph proving she was indeed at her Salisbury beach house in February 2017,
and therefore feloniously perjured before this Court on 5/4/18 when so denying; and
g. A video picturing Christina intoxicated on a ski lift and casually joking about the
danger thereof, revealing she later took rescue snowmobile escort down the mountain.
50. Maravelias is not “obsessed” with a delinquent law-breaker. His mind has not been
“preoccupied at all with [her]”, as written to Attorney Brown in the November 2017 letter. He has
11
EXHIBIT B
not disseminated any of the aforementioned exhibits. This shows his clemency and non-obsession.
If this Court will illegally injunct further against Maravelias’s free speech rights through shameful
diktats, he will make broader exercise of the free speech rights he still has.
51. Furthermore, since Maravelias has been sent the social media exhibits in question by
independent third parties who support him, the instant Motion to further abuse Maravelias is an
incredibly foolhardy act by the Petitioner. It is suspected that these third parties too will discontinue
their independent magnanimity in allowing Christina DePamphilis to grow in her delinquency
without public correction or documentation of the said.
CONCLUSION
“To extend the Stalking Order in this case would show plaintiffs all across the great State of New
Hampshire that you can come to court to get a restraining order against someone – to shut them up when
they say things you disagree with.” – Paul Maravelias, 6/8/18 Hearing Closing Argument
52. Mr. Maravelias enjoys enormous validation of his trenchant determination from months
ago that the DePamphilis bad-faith “stalking order” abuse against him has been but a cowardly
attempt to restrict his speech, having nothing at all to do with a “fear for personal safety”.
53. The Petitioner’s shameful, panicked, and obscurantist Motion decisively confirms this.
54. The said is a but veiled attempt to criminalize Maravelias’s quotidian existence. It is a
nefarious scheme to conduce an innocent human life into doubtless imprisonment. It is a cowardly
contrivance birthed of the perverse validation this Court’s errors have tortiously bestowed upon
Maravelias’s abusers, and lacks any legal merit. It is beyond shameful that David and Christina
DePamphilis still machinate against the victim such dishonest abuse-stratagems which cowardly
masquerade under the misleading optics of protectivism.
12
EXHIBIT B
EXHIBIT C
EXHIBIT C
EXHIBIT C
EXHIBIT D
EXHIBIT E
EXHIBIT F
EXHIBIT G
EXHIBIT G
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 PETITIONER’S REPLY TO RESPONDENT’S OBJECTION TO PETITIONER’S

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

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

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

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

Amended Complaint Against Judge John J. Coughlin, Exposed Civil-Rights Abuser and Lawbreaking Tyrant

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What is the nature of the complaint being filed?

What is the nature of the complaint being filed?

What arguments does the plaintiff make against extending the stalking order terms?

What arguments does the plaintiff make against extending the stalking order terms?

1 PAUL J.

25 1. NOW COMES Plaintiff PAUL MARAVELIAS (“Plaintiff”) with Complaint

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

2 statutory or equitable authority, masquerading as “extended terms” of a preexisting civil

15 Amendments to the Constitution of the United States of America.

20 case arises under questions of federal constitutional law.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

2 Judgment Act, 28 U.S.C. §§ 2201-02.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

8 20. Maravelias collected screenshots of DePamphilis’s public internet social media

17 image evidentiary exhibits, including DePamphilis’s vulgar cyberbullying post against

18 Maravelias, inter alia.

26 of Protection to Include Further Conditions”, attached as Exhibit A.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

2 stalking order against Maravelias to include the following additional criminally-enforceable

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

19 impending enforcement of these unlawful “extended terms”, Plaintiff Maravelias incorporates

12 “possession” or “gaining access” conduct.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

17 harassment mechanism extended in 2018 by a biased, rogue judge.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

12 in threatening federally unconstitutional enforcement entails a further aspect of their alleged

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

2 “extended terms”, Rooker-Feldman would still not apply.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

12 without fearing criminal prosecution by the State of New Hampshire.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

13 Maravelias’s mere ongoing “possessing [any]” “social media” screenshots or exhibits, as

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

2 counts as “possession” of a “social media communication”, what counts as “third party”

8 another’s device is itself a “communication” or merely an indication or record of such a

9 “communication” existing elsewhere).

23 that Christina DePamphilis’s possessing her own “social media communications”

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

12 “(a) Protective orders:

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

2 within its jurisdiction the equal protection of the laws.”

26 violation of his Fourteenth Amendment equal protection rights.

2 section entitled “Prayer for Relief”.

14 extended but before the “extended terms” were granted.

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS

19 152. Said protective orders inflict extensive restrictions against a subject’s

24 constitutionally protected non-threatening public speech which could “discomfort” the

FIRST AMENDED VERIFIED COMPLAINT FOR PAUL MARAVELIAS