April 1st, 2019

Eileen Fox, Clerk of Court

New Hampshire Supreme Court Paul Maravelias
One Charles Doe Drive 34 Mockingbird Hill Rd
Concord, NH 03301 Windham, NH 03087

RE: Christina DePamphilis vs. Paul Maravelias

Case No. 2018-0483

Dear Clerk Fox:

Please find enclosed an original and seven copies of the following pleadings to be filed in
the above-referenced case:

1) Appellant’s Motion to Strike Appellee’s Request for Award of Attorneys’ Fees;

2) Appellant’s Objection to Appellee’s Request for Award of Attorneys’ Fees; and

3) Appellant’s Motion for Award of Fees and Costs

Thank you for your attention to this matter.

Sincerely,

Paul J. Maravelias

CC: Simon R. Brown, Esq.

 THE STATE OF NEW HAMPSHIRE

SUPREME COURT

NO. 2018-0483

Christina DePamphilis
v.
Paul Maravelias

APPELLANT’S MOTION TO STRIKE APPELLEE’S REQUEST

FOR AWARD OF ATTORNEYS’ FEES

NOW COMES Paul Maravelias (“Appellant”) and respectfully submits the

within Motion to Strike Appellee’s untimely 3/22/19 pleading. In support thereof

Appellant states as follows.

I. Appellee’s “Request” Is Woefully Untimely, Months-Past the “30 Days

Post-Order” Requirement of Rule 23, and Is Another Bad-Faith
Pleading DePamphilis Brings in Violation of the Court’s Rules

1. A party cannot come back to this Court months-later and petition for

fees within a done, closed case, whining about the opposing party’s disliked factual

positions. Rule 23 clearly states, “Costs will be deemed waived if a request for

taxation of costs with itemization is not filed within 30 days after the date on the

order in the case.” The Court’s Order here was dated 1/16/19, almost 3 months ago.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 2. Insofar as Appellee covertly attempts to request comprehensive

attorney’s fees as distinguished from the “costs” of filing Appellee’s two

illegitimate, vexatious, and unnecessary Motions to Strike certain exhibits in

Appellant’s Brief and Reply Brief, the following is stated in opposition.

3. First, the language of Rule 23 obviously places requests for

“extraordinary” attorney’s fees within the umbrella of the 30-day time limit. There

must doubtlessly be such a procedural time limit bearing upon such requests, and

“30 days” is the sole controlling deadline offered by Rule 23.

4. Second, Appellee’s request is disingenuous, being nothing more than

another bad-faith litigation tactic to harass Maravelias, or else she would have filed

the “request” long-ago. The DePamphilis actors are currently infuriated by the

course of recent trial court proceedings, where their daring lies within the recent

extension motion were dramatically exposed. Therefore, their apparent outlet of

retaliatory energy is an awkward return to this appellate Court with a baseless

extortionary “request” as another legal-terrorism offensive trick against Maravelias.

5. Appellee’s “request” for punitive fees within Appellant’s appeal is

completely untimely, violating Rule 23’s 30-day post-order deadline. Further, it is a

bad-faith retaliation tactic intended to punish Maravelias for expertly dismantling

her bold lies at the recent 2019 trial court extension Hearing, explaining the delay

and random-seeming timing of the “request”. Accordingly, it should be stricken.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
II. Appellee’s Motion Is Precluded by Collateral Estoppel, Even if It Were
Not Untimely, Since the Court Already Considered and Rejected the
Relief She Now Requests Months-Later

6. Appellee’s “request” bemoans that she allegedly needed to file two

Motions to Strike allegedly non-record content of Maravelias’s Brief and Reply

Brief. She had appended the obligatory DePamphilis prayer for attorney’s fees to

both said Motions. Regardless of the flawed or nonexistent merits of said Motions,

this Court DENIED the requested attorney’s fees relief in connection with filing

those two Motions. See 1/16/19 Order, first paragraph.

7. In the light most favorable to Appellee, there was a legitimate dispute

about evidentiary preservation. However, Maravelias’s position is that Appellee

brought those two Motions in bad-faith, ripe with patently unreasonable assertions.

8. The Court perceived that there was a legitimate dispute or else it

would have ordered sanctions against Appellee DePamphilis for bringing two

baseless Motions to Strike. The Court also denied Appellee’s baseless, bad-faith

request in December to dispose of this entire appeal because Maravelias stated some

in-record facts beneficial to his legal position which Appellee did not like.

9. Accordingly, the Court already denied the relief Appellee now

requests. Collateral estoppel applies. Appellee already litigated her contention about

the two motions and whether she was entitled to attorney’s fees for routine appellate

motion practice – an absurd contention to begin with.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 10. Therefore, as a matter of law, Appellee’s “request” has zero potential

legal viability. It should be stricken from the record, let alone denied substantively.

III. Appellee’s “Request” Attempts to Cheat the Court’s Rules by

Circumventing Rule 22. It Is Effectively a Motion to Reconsider
Brought Months After Rule 22’s 10-Day Post-Order Time Limit
Expired in January.

11. Since Appellee’s “request” repeats all sorts of tiresome, frivolous

argumentation attacking Maravelias’s character and heralding bold claims to

punitive fees against her legal abuse victim, she is making a fact-based argument on

the merits of said “request”. But this familiar exercise was already performed, ad

nauseum, throughout the course of the appeal. The Court’s Final Order denied the

“further relief” requested in Appellee’s two Motions to Strike, i.e. for “reasonable

attorney’s fees”.

12. Appellee therefore is asking the Court to reconsider its ruling on those

two Motions. However, Rule 22 imposes a 10-day post-order time limit for motions

to reconsider. See Rule 22(2). Though lawyer-represented and privileged, Appellee

must still obey the Court’s rules. She could have filed a timely Motion for

Reconsideration addressing this topic, but she declined to do so.

13. It is well-established that Appellee waived her opportunity to ask the

Court to reconsider any disagreed-with aspect of its final decision by failing to file a

timely post-trial motion with notice to the other party.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 14. By reason of the above, there is no possible way Appellee’s improper

3/22/19 “request” could procure relief without unscrupulously cheating around this

Court’s Rule 22. Thus, the “request” should be stricken in entirety.

WHEREFORE, Defendant-Appellant Paul Maravelias respectfully prays this

Honorable Court:

I. Grant this Motion;

II. Strike and do not consider Appellee’s 3/22/19 Request for Award of
Attorney’s Fees; and
III. Grant any further relief as may be deemed just and necessary.

Respectfully submitted,

PAUL J. MARAVELIAS,
April 1st, 2019 in propria persona

CERTIFICATE OF SERVICE
I, Paul Maravelias, certify that a copy of the within Appellant’s Motion to Strike
Appellee’s Request of Award of Attorneys’ Fees was forwarded on this day through
USPS Certified Mail to Simon R. Brown, Esq., counsel for the Plaintiff-Appellee,
Christina DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.

______________________________
April 1st, 2019

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

SUPREME COURT

NO. 2018-0483

Christina DePamphilis
v.
Paul Maravelias

APPELLANT’S OBJECTION TO APPELLEE’S REQUEST

FOR AWARD OF ATTORNEYS’ FEES

NOW COMES Paul Maravelias (“Appellant”) and respectfully submits the within

Objection to Appellee’s 3/22/19 “request” for “award of attorneys’ fees”. Maravelias

is the defendant in this case, attacked by movant DePamphilis, yet he somehow faces

an absurd, outrageous, and frivolous “request for fees”. Appellant is submitting a

contemporaneous Motion to Strike Appellee’s legally inappropriate, untimely

“request”. The following document challenges the substance of Appellee’s “request”.

In support thereof Appellant states as follows.

I. Wealthy, Obdurate Legal Abuser David DePamphilis Continues to

Attempt to Judicially Extort Money from Poor Maravelias for Simply
Defending Himself Against DePamphilis’s False and Defamatory Attacks

1. This appeal case has been closed, done, and over-with since almost three

months ago. The DePamphilis family, angry at having been exposed as extreme liars at

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
the recent trial court extension hearing, now returns to this Court to give a shot at

further financially abusing, extorting, and harassing Paul Maravelias, an impecunious

23-year-old who can’t afford to live apart from his family and whose scant income

currently goes largely to supporting his teenage sister.

2. Up unto this point, David DePamphilis – a rich 50-year-old business

executive – has committed the following acts of cruel judicial extortion through his

lawyers and legal attacks against Maravelias:

a. In 2016, having his daughter file a false stalking petition which Maravelias later
spent almost $10,000 to appeal while a 21-year-old student, an appeal this Court
rejected because Maravelias did not know to “preserve” legal arguments while
an ignorant pro se defendant in the trial court, before he got an appellate lawyer;

b. In 2017, causing Maravelias to be falsely arrested twice because Maravelias

pressed a button on his cell-phone to record himself and later sent a concerned
email to his teacher about someone’s criminal misconduct, necessitating further
thousands of dollars in unjust legal expenses for Maravelias;

c. In 2018, after threatening and harassing Maravelias to the point Maravelias filed
an honest stalking petition against him, using his lawyer to maneuver the
malleable despotic biddings of exposed tyrant judge John J. Coughlin to order
Maravelias to pay DePamphilis $9,000 of attorney’s fees based on a finding that
Maravelias’s “positions” were “patently unreasonable”, although the same exact
“positions” were recently adopted by the same trial court to issue
DePamphilis’s recent stalking order against Maravelias (see Exhibit A);

d. Causing Maravelias to have to spend thousands of dollars on the obligatory

appeal thereof to this Court and that of the fraudulent stalking order extension in

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 the instant case, in which DePamphilis and his daughter Christina incitatively
harassed/bullied Maravelias on the internet through vulgar gestures with
Appellee’s 22-year-old ex-boyfriend, whom she recently discarded so she can
have more sex partners in college;

e. Causing this Court, at the drop of a hat, to issue the demented extortionary
aberration in 2018-0376 which Maravelias confides this Court will soon correct
in response to the pending Motion to Reconsider, unless it wishes to make
national headlines of shame of reproach in the United States Supreme Court, etc.

3. After all this disgraceful criminal extortion DePamphilis has committed

against poor Maravelias through manipulating the legal system, Maravelias is destitute

and without funds to sponsor further tyrannical dispensations towards DePamphilis’s

meritless, frivolous legal abuse.

II. Appellee’s Contested Brief Appendix Materials Were Proper and

Unquestionably Part of the Trial Court’s Record, as Previously Shown

4. Appellee’s Motion is based upon a patently false assertion that

Maravelias submitted non-record exhibits. First, the argument that a legitimate

misunderstanding of evidentiary preservation warrants punitive fee award at the

appellate level is absurd. Rule 23 attorney’s fees are for “extraordinary” cases of

“frivolous or bad-faith” appeals. On the contrary, this appeal was ripe with compelling

constitutional issues and a shockingly unjust, fact-amnestic ruling from a clearly

corrupt trial court judge. It surpasses insanity to assert Maravelias should be punished

for defending himself by exercising his right to appeal such unlawful, criminal

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
despotism by Judge John J. Coughlin – an un-convicted federal lawbreaker (See 18

U.S.C. 242, inter alia).

5. Second, Maravelias did not submit any non-record exhibits. The

complained-of exhibits were from an earlier hearing in the stalking case, but they were

“preserved” in the trial court’s record nonetheless.

6. Maravelias’s 11/28/18 and 12/17/18 Objections to both of DePamphilis’s

meritless Motions to Strike are repeated and incorporated by reference.

III. Appellee’s Two Vexatious “Motions to Strike” Were Not Granted, As She
Falsely Claims They Were

7. The Court’s 1/16/19 Order states in relation to this matter:

“The plaintiff’s motions to strike exhibits to the defendant’s brief and reply brief are
granted in part and denied in part. Pages 197 to 221 of the appendix to the defendant’s
brief and pages 1 to 23 of the appendix to the defendant’s reply brief are stricken
because they consist of pleadings and documents that were not submitted to the
trial court in connection with the decisions that are the subject matter of the
present appeal, but were instead submitted in related matters. See Sup. Ct. R.
13(1). The remaining relief requested by the plaintiff in both motions is denied.”
(Emphasis added)

8. There is a legal difference between “granted” and “granted in part and

denied in part”. Appellee’s “request” makes patently false claims and is an example of

rule-breaking, fraudulent conduct. The Court DENIED the relief she now requests.

9. Further, the Court’s order adopted a never-before-seen limiting

interpretation of Rule 13. Maravelias cannot possibly be penalized for obeying the

plain language of Rule 13 in good-faith, before the Court’s strange interpretation

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
thereof was ever brought into existence; the contested materials were undisputedly

before the trial court when it considered it its underlying decision.

IV. Appellee’s Outrageous Requested Relief Violates Equal Protection Under

the 14th Amendment, Since Maravelias Can Cite Indistinguishable Appeal
Cases Where a Legitimate Dispute About Evidentiary Preservation Never
Resulted in Punitive Fee Award

10. As the Court knows, disputes over evidentiary and issue preservation

arise in many appeals. It is an inherent, routine aspect of appellate litigation. The same

goes for incendiary, offensive, and verifiably truthful comments against an opposing

party where legally relevant.

11. Even if Maravelias did commit an error by attaching materials from the

trial court record, it is positively ridiculous to say this renders his entire appeal

“frivolous and in bad-faith” for Rule 23 attorney’s fees.

12. When similar disputes have arisen in other appeals, the Court has not

issued punitive appellate fee orders to similarly situated parties or even to parties who

have openly and doubtlessly violated Rule 13 or other rules, unlike Maravelias. What

this Court did to Maravelias in its libelous 1/16/19 Order is “punishment enough” for

whatever sense of wrong this Court feels done against it by Maravelias’s mere legal

self-defense. The law and Maravelias’s constitutional rights must be respected;

accordingly, he must not be subject to arbitrary punitive extortionary acts done under

the penetrable excuse of Rule 23 attorney’s fees where totally inapplicable. Such

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
would disparage this Court’s 14th Amendment-mandated duty to apply the law equally

to all people.

V. Appellee Wants Maravelias to Literally Pay for Her Own Licentious and
Criminal Misconduct, Objectively Documented in the Record, Which She
Chose to Make into Relevant Legal Facts by The Certain Ways She
Attacked Maravelias

13. Appellee’s “request” is pure evil if not totally nonsensical. Beyond the

meritless complaint about Maravelias’s submission of record-preserved evidentiary

exhibits, Appellee’s “request” laments certain unflattering statements Maravelias made

within the course of litigation to discredit his legal abuser’s baseless attacks.

14. Christina DePamphilis, a movant, is responsible for her own poor

choices. She cannot legally attack Paul Maravelias by her father’s design with false

“stalking” accusations and then expect Maravelias not to advocate facts beneficial to

his legal position. Here, the DePamphilis actors animated their original 2016 legal

abuse by whining that Maravelias was a few years older than DePamphilis in 2016

when he kindly invited her to dinner. Maravelias rebutted this with legally relevant

testimony that she has had sexual relationships with older men his age, defeating her

argument his majority contributed to “fear”. There is even a record-admitted exhibit

she herself publicized bragging how far she and her ex-boyfriend moved the bed. Now

Christina DePamphilis has the audacity to whine to New Hampshire’s highest court

demanding that her legal abuse victim essentially pay-up for referencing her own

whoredom while defending himself from her false defamatory attacks!

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 15. The same is true of her documented alcohol and drug use (e.g. A18,

admitted as evidence by the trial court). It is the DePamphilis actors who are bringing

these unfortunate facts once again into the limelight, not Maravelias. Maravelias is just

defending his rights, property, livelihood, and reputation.

VI. Appellee’s Angry Attorney Persists in Remorseless Mischaracterizations of

the Record to Advance the Delusion that Unfavorable Facts about His
Client Aren’t True

16. Appellee’s baseless “request” is an attempt to pretend reality isn’t what it

is. Maravelias’s “offensive” characterizations of DePamphilis were record-admitted,

legally relevant facts. DePamphilis has never even denied most or all of those

undisputedly true facts, since she knows they have been shown to be true. An

Appellant cannot be punished for simply engaging in the adversarial process.

17. Appellee and counsel have committed unfettered misrepresentation

conduct in this case. See Maravelias’s 12/10/18 cease and desist letter to Attorney

Simon R. Brown, documenting examples of this vile conduct, attached as Exhibit A to

Maravelias’s 12/17/18 filing entitled Appellant’s Objection to Appellee’s Motion to

Dismiss and Strike Exhibits and Arguments Presented in Appellant’s Reply.

VII. Appellee Claims to Have Standing To Be Enriched Because of Maravelias’s

Alleged “Disrespect” to This Court

18. Paragraph 19 of the “request” claims Maravelias’s appellate pleadings in

this case were “disrespectful” to the Court. In reality, as mere a reading of

Maravelias’s brief reveals, he was excessively respectful to this Court. Regardless,

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
Appellee’s counsel needs to go back to law school and learn the three elements of

standing if he thinks his client is entitled to money for Maravelias’s alleged

“disrespect” to this Court.

VIII. Paul Maravelias Should Not Be Further Extorted and Financially Abused
for Mentioning Judge John J. Coughlin’s Alleged Criminal and Felonious
Acts, as Appellee Suggests

19. Paragraph 22 of Appellee’s meritless 3/22/19 “request” states in support

that Maravelias accused Judge Coughlin of felonious criminal conduct.

20. Appellant did indeed point-out Judge John J. Coughlin vile lawbreaking,

attempting to ban a certain public “social media” exhibit from being used in this

appellate case, a criminal violation of the witness tampering statute, among others.

21. Mr. Coughlin also committed federal crime (18 U.S.C. §242) when he

willfully violated Maravelias’s constitutional rights under color of state law; see A161.

22. It is John J. Coughlin who should be punished for his lawbreaking, not

the victim thereof: the Appellant who simply made legal arguments about the said.

IX. Appellee Has Made Repeated Scandalous, Burdensome, Baseless,

Vexatious, and Defamatory Attacks against Maravelias Under the Guise of
Legitimate Legal Pleadings and Now Accuses Maravelias of the Same
Thing in Reverse, an Example of Psychological Projection and
Delusionality

23. Maravelias repeats herein and incorporates his contemporaneously

submitted Appellant’s Motion for Award of Fees and Costs, showing that – if anyone

is owed a punitive appellate fees award – it is Appellant Maravelias.

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

Court:

I. Grant this Motion;

II. Deny Appellee’s 3/22/19 untimely “request” for attorneys’ fees; and
III. Grant any further relief as may be deemed just and necessary.

Respectfully submitted,

PAUL J. MARAVELIAS,
April 1st, 2019 in propria persona

CERTIFICATE OF SERVICE

I, Paul Maravelias, certify that a copy of the within Appellant’s Objection to

Appellee’s Request for Award of Attorneys’ Fees was forwarded on this day through
USPS Certified Mail to Simon R. Brown, Esq., counsel for the Plaintiff-Appellee,
Christina DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.

______________________________

April 1st, 2019

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

THE STATE OF NEW HAMPSHIRE

ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY

Docket No. 473-2016-CV-00124

Christina DePamphilis
v.
Paul Maravelias

MOTION FOR CLARIFICATION

NOW COMES Paul Maravelias (hereinafter, “Defendant”), on behalf of himself and those

similarly situated, and respectfully submits the within Motion for Clarification pursuant to U.S.

CONST., Amend. XIV, and N.H. CONST., Pt. I., Art. 1, 2, 8, 14, and 15. Maravelias

respectfully demands this Court apply the law equally at all times and not discriminate against

certain subjectively disliked individuals. In support thereof Maravelias states the following:

I. MARAVELIAS AND THOSE SIMILARLY SITUATED ARE INESCPABABLY

CONFUSED BY THIS COURT’S MIXED SIGNALS ON WHAT CONSTITUTES
VIABLE AND MERITORIOUS SUBSTANCE FOR CIVIL STALKING
PROTECTIVE ORDER RELIEF UNDER RSA 633:3-A

1. On 3/8/19, this Court granted a request to extend a stalking protective order

because the Defendant allegedly made “offensive and hateful” “statements” in public (on the

“internet”) to third-parties. See 3/8/19 Order. The Court reasoned that this behavior proves

“hostility” towards Plaintiff, therefore showing “legitimate concern” for her “safety” and that

such “fear for her safety” is “reasonable” because of the “offensive” statements in public.

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 EXHIBIT A

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

This Court held hearings thereon in February 2018. Maravelias alleged and corroborated that

David not only engaged in extreme offensive and hateful statements in public (which were also

defamatory, calling Maravelias a “sexual predator” and “piece of shit stalker”), but also

participated in incitative bullying/harassment posts on the internet, directed specifically to

Maravelias, containing vulgar gestures and instrumentalizing his daughter’s new boyfriend

which, situationally and in-context, could incite a violent or disorderly response.

3. Judge John J. Coughlin not only denied Maravelias’s Stalking Petition but even

forced Maravelias to pay DePamphilis over $9,000 in attorney’s fees, claiming that Maravelias’s

Petition was “patently unreasonable” and that Maravelias provided “no credible evidence” for his

accusations.1 See 5/11/18 Order in 473-2017-CV-00150. Maravelias then appealed. The biased,

activist, bad-faith Supreme Court refused to reverse. See NHSC Case No. 2018-0376.

II. BECAUSE OF THIS COURT’S INCONSISTENT APPLICATIONS OF THE

LAW, ALL POTENTIAL STALKING VICTIMS HAVE NO IDEA WHETHER
THEIR ALLEGATIONS ARE SUFFICIENT FOR A STALKING PETITION AND
MUST FEAR PUNITIVE, ARBITRARY ORDERS TO PAY THEIR POTENTIAL
STALKERS THOUSANDS OF DOLLARS IF THEY DO NOT PREVAIL

4. This Court must clarify whether proving a defendant made “offensive and hateful

statements in public” to “disparage” a plaintiff is a viable cause of action for claims to civil

protective order relief under RSA 633:3-a.

5. When Maravelias filed a Stalking Petition, alleging this same element and indeed

far more, and ultimately proved this element and far more, Judge John J. Coughlin committed

1
This Court’s finding surpassed insanity, since Maravelias provided witness testimony and even physical screenshot
evidence proving his allegation(s) beyond any and all doubt, regardless of whether they raised to the level of
stalking.

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 EXHIBIT A

extortionary judicial abuse against Maravelias by blindly declaring the petition “patently

unreasonable”.

6. “A claim is patently unreasonable when it is commenced, prolonged, required, or

defended without any reasonable basis in the facts provable by evidence or any reasonable claim

in the law as it is, or as it might arguably be held to be.” Glick v. Naess, 142 N.H. 172 (1998).

7. Here, it is irrelevant whether the parties’ claims against each other of “offensive

and hateful” comments, between the two stalking cases, are factually true. The instant question is

purely legal: if there is a “reasonable claim” in the law for a contention, it cannot be “patently

unreasonable”. See Glick, supra.

8. In one stalking case, Maravelias alleged David DePamphilis made offensive and

hateful statements to disparage Maravelias in public (and much worse). This Court issued an

Order on 5/11/18 (Coughlin, J) pronouncing the said allegation “patently unreasonable”: i.e., an

allegation which, even if proven true, is not an actionable contention for relief for RSA 633:3-a

stalking orders, requiring a “course of conduct” placing a person in fear of their “personal safety”

and permitting extension similarly only when there is ongoing concern for a plaintiff’s “safety”.

Compare RSA 633:3-a, III-a. with RSA 633:3-a, III-c.

9. But here, the Court’s recent extension 3/8/19 Order granted stalking order relief

based solely upon a finding that a defendant made “hateful and offensive” statements in public.

III. ABSENT CLARIFICATION AND RETROACTIVE CORRECTION, THE

COURT’S INCONSISTENT APPLICATION OF RSA 633:3-A VIOLATES
CONSTITUTIONAL EQUAL PROTECTION RIGHTS AND CHILLS THE
ABILITY OF STALKING VICTIMS TO PETITION FOR RELIEF

10. “No State shall make or enforce any law which shall abridge the privileges or

immunities of citizens of the United States; nor shall any State deprive any person of life, liberty,

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 EXHIBIT A

or property, without due process of law; nor deny to any person within its jurisdiction the equal

protection of the laws.” U.S. CONST, Amend. XIV. See also N.H. CONST, Pt. I, Art. 2, “All

men have certain natural, essential, and inherent rights among which are, the enjoying and

defending life and liberty; acquiring, possessing, and protecting, property; and, in a word, of

seeking and obtaining happiness. Equality of rights under the law shall not be denied or abridged

by this state on account of race, creed, color, sex or national origin.”

11. There is a class of citizens whose stalking order petitions have been denied and

another class whose petitions have been granted.

12. There is a class of citizens who have been ordered to pay attorney’s fees under the

exception to the regular American rule that each party pays their own fees: the “patently

unreasonable” contention exception. See LaMontagne Builders v. Bowman Brook Purchase

Group, 150 N.H. 270, 276 (2003).

13. There is a class of citizens who have not been ordered to pay attorney’s fees,

when requested by an opposing party under the “patently unreasonable” exception.

14. Further, Maravelias himself is individually entitled to 14th Amendment Equal

Protection rights according the U.S. Supreme Court’s established “class of one” of doctrine

which applies even in civil suits for money damages where no “fundamental rights” are at stake,

as they are here in the context of a restraining order. See generally Araiza, W.D., 2013.

“Flunking the class-of-one/failing equal protection.” Wm. & Mary L. Rev., 55, p.435. See also

Village of Willowbrook v. Olech, 528 U.S. 562 (2000).

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 EXHIBIT A

15. The Court’s acts against Maravelias in the context of stalking order relief under

RSA 633:3-a are logically incompatible and violate constitutional due process and equal

protection rights:

a) When Maravelias was a civil stalking plaintiff, his allegation that someone made
offensive and hateful comments against him, showing hostility and therefore
reasonable fear, was deemed “patently unreasonable” (i.e., an allegation which even
if true, cannot possibly result in civil protective order relief under RSA 633:3-a).

b) When Maravelias was a civil stalking defendant, the Court granted the stalking
order relief through exact same reasoning it previously rejected in Maravelias’s
petition and deemed “patently unreasonable”, forcing impecunious 22-year-old
Maravelias to pay his alleged-stalker over $9,000 dollars in attorney’s fees.

16. This Court’s orders necessarily either extort Maravelias wrongfully of over

$9,000 dollars or deprive Maravelias of his fundamental constitutional rights through a

wrongfully extended stalking order. Either one or the other must be true: there is no logically

possible way to harmonize this Court’s inconsistent, discriminatory conduct.

IV. THE COURT MUST EITHER DISSOLVE ITS PUNITITVE FEE AWARD
AGAINST MARAVELIAS OR DISSOLVE THE STALKING ORDER
EXTENSION AGAINST MARAVELIAS

17. Equal Protection demands that the Court cannot have it both ways. There have

been zero changes to the applicable statutory or case-law landscapes in the past few months

when the Court took the above-referenced, logically incompatible actions against Maravelias.

18. This Court has original jurisdiction over both actions. Regarding the 5/11/18

punitive fees award against Maravelias, this Court has full authority to reverse it. “A trial court,

however, has the authority to revisit an earlier ruling on a [motion] if it becomes aware that the

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

ruling may be incorrect.” Route 12 Books Video v. Town of Troy, 149 N.H. 569, 575 (2003) (in

the context of revisiting a motion to Dismiss).

19. The Supreme Court’s order in 2018-0376 has no preclusive effect as follows in

Paragraphs 20 and 21:

20. First, the Supreme Court’s appellate jurisdiction generically does not restrain this

Court from doing the right thing, upon new information, within this Court’s original jurisdiction.

I.e., the Supreme Court acknowledges the trial court’s authority and only acts upon reversible

error – a higher standard than actual error.

21. Second, the Supreme Court did not uphold the fees awards on the “patently

unreasonable” grounds; instead, they upheld it on the “bad-faith” grounds and offered one single

threadbare sentence noting that their “review of the record” caused them to feel Maravelias acted

in bad-faith, with zero specific references or citations whatsoever. The Supreme Court’s obvious

bad-faith, patently unreasonable screw-Maravelias order primarily concerned the other aspect of

that appeal, which were the merits of the stalking order dismissal, not the fees award.

22. Maravelias does not presently seek to relitigate or collaterally attack the dismissal

of his stalking petition, since the legal question of viability of offensive public speech for

stalking orders does not span the substantive fact-based question on the merits of whether David

DePamphilis actually committed such conduct in that particular stalking petition.

23. However, as a matter of law, the baseless fees award predicated upon the

allegation that Maravelias’s theory was “patently unreasonable” – the same exact theory this

Court has recently used to extend a stalking order against Maravelias – must unquestionably be

reversed.

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

V. CONCLUSION

24. If the Court stands-by its legal reasoning for extending the instant stalking order,

Paul Maravelias plans to file two new Stalking Petitions against both David DePamphilis

and Christina DePamphilis. Such petitions will proceed upon the Court’s own theory of relief

that the DePamphilis’ conduct against Maravelias has met and far-surpassed the communication

of “offensive and hateful” statements disparaging Maravelias in public, and thus a stalking order

shall issue lest the Court openly commit subjective discrimination against Maravelias as clear as

night-and-day, in violation of his 14th Amendment Equal Protection rights.

25. However, since Maravelias was wrongly penalized the first and only time he filed

a stalking petition, falsely accused of “bad-faith” and “patently unreasonable” conduct, he

therefore cautiously seeks this Court’s clarification first. Before filing any stalking petitions,

Maravelias wishes to confirm that alleging “offensive and hateful” statements made in public

shows “hostility” substantiating reasonable safety concern viable for civil stalking relief.

26. Maravelias intends to aggressively pursue this alarming Equal Protection

violation in both state and federal courts if this Court cannot resolve the injustice by either

reversing the stalking order extension or reversing the punitive fees award against Maravelias.

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

WHEREFORE, Defendant Paul Maravelias respectfully prays this Honorable Court:

I. Grant this Motion;

II. Clarify whether the allegation that a defendant’s public offensive and hateful
communications about a plaintiff cause said plaintiff reasonable fear for purposes
of RSA 633:3-a relief;

III. Depending on the Court’s clarification, either do one of the following:

a. Vacate and reverse its 3/8/19 Order granting extension in this case; or

b. Vacate and reverse its 5/11/18 Order in Paul Maravelias v. David

DePamphilis, 473-2017-CV-00150, forcing Maravelias to pay David
DePamphilis over $9,000 in attorney’s fees predicated upon the legal finding
Maravelias’s “positions” were “patently unreasonable”.

IV. Grant any further relief as may be deemed just and necessary.

Respectfully submitted,

PAUL J. MARAVELIAS,

March 28th, 2019 in propria persona

CERTIFICATE OF SERVICE

I, Paul Maravelias, certify that a copy of the within Defendant’s Motion for Clarification was
forwarded on this day through USPS Certified Mail to Simon R. Brown, Esq., counsel for the
Petitioner, Christina DePamphilis, P.O. Box 1318, Concord, NH, 03302-1318.

______________________________

March 28th, 2019

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

SUPREME COURT

NO. 2018-0483

Christina DePamphilis
v.
Paul Maravelias

APPELLANT’S MOTION FOR AWARD OF FEES AND COSTS

NOW COMES Paul Maravelias (“Appellant”) and respectfully submits the within

Motion for Award of Fees and Costs. Appellant submits this Motion in case the Court

does not grant his Motion to Strike Appellee’s similar 3/22/19 motion for fees and costs,

choosing to enter the merits of both parties’ requests for fees. In support thereof

Appellant states as follows:

I. Appellee and Counsel Have Rampantly Violated the Rules of Professional

Conduct in This Case, Causing Maravelias Actual Damage

1. This Motion proceeds on whatever legal grounds Appellee’s similar

“request” possibly could. The critical difference is that the Court has not already denied

the relief now-requested by Appellant, unlike Appellee’s improperly re-submitted request

for “fees” which are baseless and effectively an untimely motion to reconsider.

2. Maravelias had submitted a 12/10/18 cease and desist letter he sent to

Attorney Brown and attached it as Exhibit A to Appellant’s 12/17/19 Objection to

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
Appellee’s Motion to Dismiss and Strike Exhibits and Arguments Presented in

Appellant’s Reply. In this letter, Maravelias reviews examples of DePamphilis’s stunning

misconduct in this case, bringing baseless and dishonest contentions remorselessly even

after being politely corrected multiple times.

3. Maravelias has been forced to litigate in response to this patently

unreasonable and vile conduct. Accordingly, he should be awarded reasonable fees and

costs to reimburse the damage DePamphilis’s malicious misconduct has caused him.

II. Appellant Should be Reimbursed for Having to Respond to Appellee’s 3/22/19

“Request”, a Bad-Faith Harassment Mechanism to Burden and Overload Pro
Se Maravelias with Distracting Further Litigation, Forcing Him to Compose
More Pleadings In This Months-Finished Appellate Case at the Expense of
the Ongoing 2019 Trial Court Extension Case

4. Appellee knows the Court’s rules but chooses to violate them willfully to

harass, burden, and preoccupy Maravelias for a tactical advantage in the underlying

circuit court litigation currently active on her 2019 extension request.

5. Appellee is lawyer represented. Counsel knows that Rule 23 imposes a “30

day” time limit for such requests. Attorney Brown also knows that his “request” is

effectively a motion to reconsider this Court’s 1/16/19 ruling denying the outrageous fee

requests, and that Rule 22 imposes a “10 day” post-order limit for motions to reconsider.

6. Accordingly, Appellee’s 3/22/19 “request” is professional misconduct

which this Court should sanction. The angry DePamphilis actors are attempting to gain an

upper-hand in the circuit court proceedings by burdening pro se Maravelias’s strained

time, forcing him to respond to such frivolous, hostile, and untimely pleadings.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
III. DePamphilis’s Criminal Falsification Conduct to Harass and Defame
Maravelias Through This Stalking Order Has Recently Been Further-
Exposed in the Trial Court

7. Insofar as facts external to the appeal case should be considered in such

requests, the Court must adopt a reinforced view of DePamphilis’s bad-faith criminal

falsification. She recently moved the trial court to extend the stalking order for five years,

alleging the Maravelias “followed” her while driving to “cheer practice” in Windham on

London Bridge Road at “7:00pm” on “10/23/18”. At hearing, the DePamphilis legal

abusers inexplicably switched the alleged time to “4:00pm”. Then Maravelias reproduced

photographic and cell-phone-location-history evidence proving that, at that time, he was

actually miles-away in here Concord, at this very Supreme Court, filing a pleading!1

8. Such liars and unrepentant criminal fraudsters have no place in this Court,

attempting to usurp an inapplicable Rule to further extort and damage Maravelias.

9. Accordingly, Maravelias should be reimbursed, in the least, for costs

incurred in connection with having to respond to Appellee’s baseless 3/22/19 “request”.

IV. Appellee Has Usurped This Appeal as a Forum to Libel, Defame, and
Disparage Maravelias’s Honorable Reputation Rather than Focusing on
Relevant Legal Arguments.

10. As Appellant’s Reply Brief exposed, Appellee has habitually avoided

meaningful legal argument and substituted every opportunity with repetition of

1
See Maravelias’s 10/23/18 pleading in Paul Maravelias v. David DePamphilis (2018-0376), which Maravelias
coincidentally happened to be filing here in Concord around the same exact time DePamphilis chose to engineer the
exposed “following” falsehood, lying that Maravelias was “following” her to Windham HS “in his vehicle”.

3
PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
disproven, false, and immaterial libelous attacks against Maravelias. See Appellant’s

12/3/18 Reply Brief. Appellee’s 3/22/19 “request” is no different.

11. In view of this vile conduct, DePamphilis should be sanctioned. Maravelias

is owned reasonable fees and costs incurred in connection with defending DePamphilis’s

improper, vexatious, burdensome, and ad hominem litigation tactics at the appellate level.

WHEREFORE, Defendant Paul Maravelias respectfully prays this Honorable Court:

I. Grant this Motion;

II. Award Appellant fees and costs to sanction Appellee’s improper conduct;
III. Grant any further relief as may be deemed just and necessary.

Respectfully submitted,

PAUL J. MARAVELIAS,
April 1st, 2019 in propria persona

CERTIFICATE OF SERVICE
I, Paul Maravelias, certify that a copy of the within Appellant’s Motion for Award of Fees
and Costs was forwarded on this day through USPS Certified Mail to Simon R. Brown,
Esq., counsel for the Plaintiff-Appellee, Christina DePamphilis, P.O. Box 1318, Concord,
NH, 03302-1318.

______________________________

April 1st, 2019

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