THE STATE
OF NEW HAMPSHIRE
SUPREME
COURT
2018 TERM
Case No. 2018-0483
CHRISTINA DEPAMPHILIS
Plaintiff-Appellee
vs.
PAUL MARAVELIAS
Defendant-Appellant
RULE 7 MANDATORY APPEAL OF STALKING FINAL ORDER OF
PROTECTION
From 10th Circuit Court –
District Division – Derry
DEFENDANT’S REPLY BRIEF
Submitted by Defendant,
Paul J.
Maravelias
34 Mockingbird Hill Rd
Windham, NH 03087
paul@paulmarv.com
603-475-3305
ORAL ARGUMENT
REQUESTED
TABLE OF CONTENTS
STATEMENT
OF THE CASE AND FACTS
I.
RSA 633:3-A, III-C. IS UNCONSTITUTIONAL
A. The Issue Was Manifoldly Preserved
III.
THE TRIAL COURT VIOLATED MARAVELIAS’S DUE PROCESS RIGHTS
A. The
Anti-Videotaping Injunction Was Illegal and Prejudicial
B. The Untimely-Hearing
Issue Was Preserved, Not Waived
TABLE OF AUTHORITIES
Cases
Appeal of Martino, 138 N.H. 616 (1994).......................................................... 21
Keenan v. Fearon, 130 N.H. (1988)................................................................... 13
MacPherson v. Weiner, 158 N.H. (2008).......................................................... 17
McCarthy v. Wheeler, 152 N.H. 643 (2005)..................................................... 20
Mortgage Specialists v. Davey, 153 N.H. (2006)....................................... 13,
20
N.H. Dept’ of Corrections v. Butland, 147 N.H. 676 (2002)........................... 13
Palazzi Corp. v. Stickney, Comm’r, 136 N.H. (1992)................................ 14, 20
Ross v. Ross, 172 A.3d 1069 (2017)............................................................ 13,
20
Smith v. Shepard, 144 N.H. 262 (1999)...................................................... 14,
20
State v.
Demeritt, 148 N.H. 435 (2002)............................................................. 12
State v. Troy Burpee (2014-0179)...................................................................... 12
State v.
Tselios, 134
N.H. (1991)....................................................................... 20
Constitutional
Provisions
First Amendment to the Federal
Constitution....................................... 12,
15, 16
Second Amendment to the Federal
Constitution............................................... 15
New Hampshire Constitution Part I,
Article 15................................................. 14
Statutes
RSA 633:3-a, I.(c)............................................................................................... 16
RSA 633:3-a, III-c.................................................................................. 15,
16, 17
New Hampshire Rules of the Circuit
Court - District Division
Rule 1.4(f)............................................................................................................ 19
STATEMENT OF THE CASE AND FACTS
Maravelias relies upon his Brief-in-Chief’s statements of case
and facts. Seeing that Appellee’s brief takes indefensible, inflated liberties
with the record, Appellant hereinafter non-extensively corrects false factual
stipulations in Appellee’s brief crafted to disparage and defame Paul
Maravelias.
|
Falsehood |
Truth-from-record |
|
“[Maravelias]
followed through on his threat” (OB40)[1] |
Maravelias invites The Honorable Court to take a gander at what kind of activities Christina DePamphilis pictured herself doing on social media (A167) which Maravelias never publicized online nor attempted to introduce. (T414:3-4,415:7;A167) His private email to Mrs. Smith was not a fulfillment of any threat. (T413:23-24,415:7) |
|
“[six years ago] noticed
Maravelias displaying romantic feelings towards her when she was only 11
years old” (OB8) |
See direct
refutations at RApp6,7,9. See also
DePamphilis’s neurotic definition of “romantic overture” at T36-37. |
|
“Maravelias
surreptitiously took a photograph of her at a party at his house”, “secret
photo” (OB9) |
Maravelias was casually “snapping pictures” around his
own 6/29/13 graduation party she chose to attend, with the camera clearly
visible. (T449:20-22) |
|
“[directionality of]
hugs” (OB9) |
See T158-159 Christina DePamphilis was videotaped[2] bursting through the crowd at the 2013 Windham Turkey Trot to interrupt Maravelias’s conversation and give him a hug, three years before mendaciously re-fabulating this incident in a 2016 stalking petition. She finally got busted for her stalking-petition-falsity on 5/4/18 when this video was first played. (Brief24-26) |
|
“Maravelias
recruited his sister to secretly obtain Christina’s Twitter password,
allowing him to follow her private account”(OB9) and
similar falsehood at OB12 |
Maravelias debunked the false “Twitter hacking” accusations
countless times. (RApp4;T346) Comment: Regarding creepy online hacking, DePamphilis has been obsessively prowling Maravelias’s private discussion forum for owners of his software product, to which she somehow gained illicit access without being one of Maravelias’s customers. (A61¶13,A62) |
|
Maravelias wanted to
walk with Christina at the [2013] event” (OB10) |
See Video at
1:24, T379:12-17 Maravelias wanted to return to conversing with his school-friends after Christina DePamphilis rudely interrupted him exclaiming “Hi Paul!” and begged for further attention-validation, “I’m promoting your college!” [Re the Dartmouth sweater Maravelias had gifted her and his sister three-months-prior, which she was wearing] |
|
“at
Maravelias’ house in 2016, [he] stared at Christina so much” (OB10) |
Christina DePamphilis went to Maravelias’s house on 6/18/16 for a family party and normally greeted Maravelias, saying “hi” to him in his kitchen. (Brief17;T188) While “intentionally ignoring” her (T186:20), Maravelias was conversing in his backyard with two individuals; Appellee happened to be seated behind them. |
|
“Given their age difference … Christina thought Maravelias’
actions on her birthday were ‘insane’” (OB11) |
Mere weeks thereafter, in February 2017, as a barely-16-year-old, she secretly absconded to her father’s beach
house in Salisbury, Massachusetts with a 21-year-old man to have sex with
him, and did, in fact, have sexual
intercourse with him[3]
(Brief22,28;A88;T146:9-19,425:23,410:8)
- the same exact age difference
(16 and 21) as in Maravelias’s
platonic dinner-date-proposal inviting her mommy to tag-along too. (T143-145) Comment: Where Maravelias’s romantic traditionalism values finding a younger spouse and premarital abstinence therewith, DePamphilis called this ‘insane’ and preferred to fornicate with a man called a “college-age” “man-whore” (A76) in an exhibit she entered. Her exhibit alleges this man had slept with “over 20 other girls including one of her own friends”. (A77,78) |
|
“Christina had not had recent contact with
[him]” (OB10) |
See supra (came to his house earlier that year) |
|
“believed Maravelias
hacked into her social media in order to obtain photographs attached to the
letter” (OB12) |
Maravelias simply did not write the March 2017 letter (Brief27-28;T403,461-465;A17,88), as further proven by his noted inability to access such photographs. |
|
“[at
22], Maravelias chose to become confirmed at [Maravelias’s] church” (OB13)
(insinuating recent choice) |
Maravelias indicated he didn’t have time for religious
formalities while in school, and that 2018 was his first year out-of-school.
(T429,430) |
|
“a violation of state
criminal law” (OB14) |
Maravelias recorded his own conversation with an Android smartphone app “in the open outdoors” where there was no “expectation of privacy”. (T443) |
|
“This
frightened Christina” (OB15) |
“Christina” was not there at all at Shaw’s when Maravelias took a self-defensive cell-phone-video, correctly anticipating a false, frivolous police report by Laurie DePamphilis. (T229) |
|
Lamentations that
Maravelias insulted Christina DePamphilis outside court |
Maravelias’s free-speech-acts reacting to this legal-abuse outrage,
occasionally accurately insulting, were made to third-parties in private. (T422:20)
Only once did he use offensive language. (T426:15-18) |
It is disappointing that Appellee’s brief contains nine-parts
regurgitated, defamatory dramatization for every one-part actual legal
counterargumentation. Despite routine attempts to make it sound otherwise with alarmist,
emotional diction, Maravelias never “stalked” DePamphilis.[4] See RApp1-11, Maravelias’s 2017
extensive trial-court-exhibit disproof of the 12/28/16 stalking petition.
ARGUMENT-IN-REPLY
I.
RSA 633:3-A, III-C. IS UNCONSTITUTIONAL
A. The Issue
Was Manifoldly Preserved
There is not the shadow of plausibility to Appellee’s
suggestion that Maravelias failed to preserve the constitutional issue.
Firstly, Maravelias did raise the “First-Amendment issue” (T302) at-trial, complaining the “overbroad
stalking statute” would violate “free-speech rights” if extension were granted based
on his “talking to other people about [Appellee]” (T301-303). The trial court explicitly
announced it understood Maravelias was making “a free-speech argument” (T330-331)
(See also T58,468:19-20), even
directly questioning at closing-argument, “how do you reconcile your claim for
protected speech versus the stalking statute?” (T471) Making arguments verbally
“clear to the trial judge” sufficiently preserves issues for appellate review. See State v. Troy
Burpee (2014-0179), State v. Demeritt, 148 N.H. 435
(2002).
Appellee disregards the nature of an as-applied challenge. At
trial, pre-final-decision, a party is generally unable to advance this kind of
argument, which here depends on the court’s [third-party-speech-acts-based] reasoning
for extension. Though not expected therefore to raise this issue at-trial,
Maravelias went above-and-beyond. He presciently equipped the trial court to
consider this key issue even before the post-trial stage.
Secondly, even if Maravelias never raised the issue at-trial,
his Motion for Reconsideration preserved it. Here, Appellee’s brief runs afoul
of pertinent case law. “The defendants raised their argument ... in their [motion]
to reconsider … Thus, the defendants’ failure to raise the issue earlier did
not deprive the trial court of the opportunity to address it. Therefore, the
argument is preserved.” Ross v. Ross, 172 A.3d 1069 (2017). See Mortgage Specialists v. Davey, 153 N.H. (2006) at 786, 904 (“[issue preserved] if raised in
motion for reconsideration and failure to raise issue earlier did not deprive
trial court of opportunity to correct error”). Cf. N.H. Dept’ of Corrections v. Butland, 147
N.H. 676 (2002). “The
defendant never raised the issue [at-trial] … she could have raised the issue
in a motion for reconsideration”. Id.
Maravelias’s reconsideration-stage presentation of the
argument was not insufficiently developed nor limited to one heading.
Maravelias’s 6/25/18 Motion bifurcated the instant argument into two related headings
found at A50 and A48, mention of
which Appellee’s brief conveniently omits (citing only “A50” at OB21). While
Maravelias apportioned two whole gratuitous paragraphs on this issue (A48¶34-35),
the headings alone sufficiently articulated a concise, specific legal argument.
Decisively not an “off-hand reference” nor “laundry list”, it was a 1) seriously
presented constitutional issue with 2) articulated argument and 3) cited authority,
itself already developed at-trial. Cf.
Keenan v. Fearon, 130 N.H. (1988) at 499, where this Court declined to address claims
lacking these three attributes.
Further, in generic fairness, Maravelias was compelled to
argue laconically in his replete Motion for Reconsideration given the
10-page-limit incumbent thereon and the multifarious plethora of injustices here.
See Dist. Div. R. 3.11(E)(1).
Insofar as optimal appellate preservation prefers he have more thoroughly briefed
the constitutional issue pre-appeal, the aforecited rule is simply unfair and/or
unconstitutional under Part I, Article 15 of the state constitution.
Thirdly, the trial court did not sustainably nor lawfully
depose of the issue in denying Maravelias’s Motion for Reconsideration.
Appellee’s citation of Smith v. Shepard, 144 N.H. 262 (1999) is inapplicable since Maravelias did raise the issue at-trial before seeking
reconsideration. Regardless, the citation to Smith is meaningfully incomplete: although a court
may decline to address new issues or consider new evidence on a reconsideration
motion, it must then “set forth the exact basis for its denial of the motion
for reconsideration to allow for meaningful appellate review.” Smith, supra, citing Palazzi Corp. v.
Stickney, Comm’r, 136 N.H. (1992). “The exact basis for the
court’s denial of the motion for reconsideration is unclear. Accordingly, we
remand this issue for further resolution.” Id.
Here, Judge Coughlin’s legal basis for denying the Motion for Reconsideration
was nothing more than the vapid repetition of his favorite word: “Denied”. (A3)
The issue is preserved; Q.E.D.
B. The Statute
is Overbroad
Appellee does not contest Maravelias’s vagueness nor facial
overbreadth challenges of constitutionality. She disputes the as-applied
overbreadth claim on unclear grounds. First, she claims the statute “does not
address free speech”, but offers no support. Since the
trial court continued the criminalization of Maravelias’s second-amendment-protected firearm
possession, inter alia, based on his
third-party, objectively lawful speech-acts, the statute irrefutably burdened
the exercise of Maravelias’s free speech. (Brief32-34)
Appellee then asserts Maravelias’s referenced speech-acts lacked
First-Amendment protection to begin with. In support, she
cites a scatterbrained gallimaufry of totally inapplicable cases from foreign jurisdictions
extraneous to the legal question at-hand. These misplaced citations at OB26-27
merely indicate that other states have upheld the constitutionality of
restraining order direct-or-indirect-speech-to-victim prohibition terms. Nowhere
does Appellant Maravelias’s argument attempt to undermine the generic
constitutionality of final protective order terms where theoretically
appropriate; his argument rather concerns the unconstitutional overbreadth of
the allowable range of lawful speech-acts which may permit a trial court to
extend such restraining orders, specified in RSA 633:3-a, III-c.
Petitioner’s desperate, newfound allegation that Maravelias
“violated the order” is misplaced. Firstly, this needing-to-be-estopped allegation
appeared nowhere in her Motion to Extend, apart from referencing the 12/15/17
false arrest for Maravelias’s private email to Mrs. Smith – idiotic charges
later dropped. Secondly, even if Maravelias’s third-party speech-acts violated
the Order, that would render the statute more
overbroad, not less (newly implicating subsection I.(c), beyond solely III-c.), since the underlying third-party
non-threatening speech remains lawful, non-Plaintiff-directed, and protected. (See generally A170-177) Appellee does
not cite any recognized category of speech by which Maravelias’s
third-party communications would lose First-Amendment protection.
Contrary to her counsel’s assertion at the top of OB26, Maravelias’s
[two] communications were protected speech-acts compliant with the protective order.
As a futile last-resort, Appellee at OB25 calls the nasty March 2017 letter
“Maravelias’s letter to Christina’s father” and a “communication to [him]”,
though false and unsupported by evidence. By now, Maravelias, the Windham
Police, and the trial court itself have all disagreed with this impossible
assertion. (Brief28) Even in his profoundly insincere anti-defendant amplified
verbal posturing, invariably typical throughout his eight 2018 pre-retirement stalking
orders (See A121-124), Judge Coughlin
made no finding that any of Maravelias’s communications were “indirect
communications” to DePamphilis and thereby Order-violative. They were not; Appellee
herself admitted Maravelias has had no contact with her whatsoever since 2016.
(T27)
Appellee fantasizes that Maravelias is challenging the
constitutionality of the “good cause” standard in isolation, entirely missing
the point. She never addresses Maravelias’s actual overbreadth argument
regarding the extreme lack of narrow tailoring in the “safety and
well-being” language which ultimately controls the relief courts may grant on
extension. Appellee opines there was “good cause” to extend, recoursing to
familiar dramatics about Maravelias’s expressed-to-third-parties righteous indignation.
This is irrelevant to the constitutional question; Maravelias’s argument needs
not disturb this Court’s ruling in MacPherson v. Weiner, 158 N.H. (2008) that “good cause” is not unconstitutionally vague[5].
Trial courts read “good cause” in context with the subsequent
imperative commandment in 633:3-a, III-c. that they “shall … grant such relief as may be
necessary to provide for the [plaintiff’s] safety and well-being”. If a
plaintiff shows by “good cause” that extending the injunction will advance her “safety
and well-being”, the statute commands the trial court to do so. Thus,
Appellee’s disregard of Maravelias’s actual constitutional overbreadth argument
(pertaining to the improper substitution of “bring about the cessation of
stalking” with “provide for the safety and well-being”, remotely paralleled in
the comparable restraining order laws of no
other state in the United States of America) renders her counterargument
misplaced.
II.
THE TRIAL COURT UNSUSTAINABLY EXERCISED DISCRETION
GRANTING THE EXTENSION AGAINST MARAVELIAS, THE VICTIM OF DEPAMPHILIS’S
HARASSMENT
At OB30-32, Appellee’s counsel makes a vain attempt at spin-slandering
Maravelias with the estopped asininity regarding “obsession”, embarrassingly
skirting his own April 2018 “previous
obsession” comment (Brief47;A36,46,68-69) and disowning
any 30-second-clip of Maravelias’s testimony. To Attorney Brown’s credit, he had
already agreed to represent Christina DePamphilis before she got carried-away
with her jezebelian psychological terrorism and made her 6/21/17 here’s-my-21-year-old-boyfriend-and-my-dad-and-we’re-middle-fingering-you,
ha-ha-I-just-got-you-arrested-for-trying-to-disprove-my-lies, you-didn’t-snap-at-my-first-harassing-post-so-I’ll-bait-you-again
(A13), “Did-Dartmouth-teach-you-how-to-do-this-
”
(A11-12) incitative bullying social media post against Maravelias.
Attorney Brown is a competent trial lawyer and should
not be measured by his likening “slander” (OB31) to truthful-and-supported
negative statements about his 17-year-old perjuring criminal, drug-addict client (T275:25,370;A21,24,28,189,192,201)
(Brief23-25;T421:18,A167-196) (Brief22;T450:21;A167),
by his rank sycophancy to the textual onanism of Judge Coughlin’s biased order
(A115-149), nor by his witless claptrap that Maravelias’s [written frustration]
forms “legitimate concern for Christina’s safety” (OB32). Maravelias deeply
sympathizes that a New Hampshire attorney finds himself cornered into
necessarily stooping to this level of infantilistic, obscurantist absurdism,
preposterous-seeming to any average person. The extension was beyond
unsustainable.
III.
THE TRIAL COURT VIOLATED MARAVELIAS’S DUE PROCESS
RIGHTS
A. The Anti-Videotaping
Injunction Was Illegal and Prejudicial
In response to this preserved-at-trial (T5-7;9:1-3,484:17-19)
legal issue thoroughly briefed in Maravelias’s Motion for Reconsideration (A48-49),
7/5/18 responsive pleading (A60-64), and appellate brief (Brief52), Appellee merely
mobilizes more ridiculous, self-plagiarized (A53) variations on her egotistical
reality-denying “he’s-still-obsessed-with-me” theme, garnished with obligatory
reminders she was a “high school sophomore” in 2016 (OB34). Maravelias already panned
this same unavailing response to the instant legal issue
long-time-ago-in-a-trial-court-not-so-far-away. (A59-64)
Since the trial court did not support its anti-videotaping
order with “particularized findings of fact that demonstrate the necessity of
the court’s action” as mandated by Dist. Div. Rule 1.4(f), it broke the law (See A62-63) – willfully so (T9:1-3). Furthermore, Appellee never identified any
“overriding public interest” nor met the three requirements in the rule. Id.
Where a documented habitual speaker-of-untruths-under-oath (Brief23-26)
claims being videotaped “intimidates” her (OB34), the error removed an effective
dishonesty-deterrent (being filmed,
not just audio recorded, lying), prejudicing Maravelias.
B. The Untimely-Hearing
Issue Was Preserved, Not Waived
Maravelias could not possibly object contemporaneously to a committed-in-the-past
error. (A65¶28) Unlike a less-severe evidentiary or procedural error, the trial
court lost personal jurisdiction to grant the requested relief when
acting outside the statutory imperative “shall”-language temporal provision. See McCarthy v. Wheeler, 152 N.H.
643 (2005). Maravelias raised and
briefed this issue in his Motion for Reconsideration. (A49,64-65) Accordingly, Maravelias’s
silence thereabout at-trial did not deprive the court an opportunity to correct
its error of extending a stalking order without jurisdiction. See again
Ross, Mortgage
Specialists supra at
13. See also State v. Tselios, 134 N.H. (1991) at 407.
In fact, the trial court didn’t even commit the error’s actual prejudicial consummation
until finally granting the extension absent personal jurisdiction, after all hearings ended. The trial
court’s one-word denial of the reconsideration motion unlawfully failed to set
forth its reasoning anent this issue. See
again Smith, Palazzi Corp., ibid. Moreover, Plain
Error would doubtlessly otherwise apply.
The error prejudiced Maravelias every-which-way: 1) the
stalking order continued restraining his constitutional rights without due-process,
2) the resultant moratorium granted DePamphilis enough time to obsessively
collect her pictures of Maravelias’s private bedroom, illegally-relied-upon as
advance-noticed nowhere in her 1/5/18 extension motion, entered only at the
6/8/18 Hearing almost half-a-year-thereafter, and 3) the DePamphilis actors
were enabled to usurp improperly the Maravelias v. DePamphilis hearing
as an anti-Maravelias slander-free-for-all regarding this case, biasing Judge Coughlin by the time he first heard this
matter.
The shown prejudice authorizes remedial reversal of the extension
order. “Where the legislature has failed to provide a method of enforcing a
statutory mandate, we have looked to whether the party seeking relief has shown
prejudice.” Appeal of Martino, 138 N.H. 616 (1994).
CONCLUSION
WHEREFORE, Defendant-Appellant Paul Maravelias reverentially
prays The Honorable Court grant the relief requested in his Brief-in-Chief.
Respectfully submitted,
PAUL J. MARAVELIAS,
in propria persona
THE
THIRD DAY OF DECEMBER
Paul
J. Maravelias
IN THE YEAR OF OUR LORD MMXVIII
34 Mockingbird Hill Road
Windham, New Hampshire 03087
paul@paulmarv.com
(603) 475-3305
CERTIFICATE
OF SERVICE AND RULE
16 COMPLIANCE
I, Paul Maravelias, hereby certify that on this day were sent
via first-class mail two copies of the within Defendant’s Reply Brief and
accompanying Appendix, postage prepaid, to Simon R. Brown, Esquire, Counsel for
the Plaintiff-Appellee, Christina DePamphilis, P.O. 1318 Concord, New
Hampshire, 03302-1318.
I, Paul Maravelias, hereby certify that this document was not
drafted by a limited-representation attorney. See N.H. Sup. Ct. R. 16(10).
Certification, further, is made of the foregoing document’s
compliance to word-count limitation, 2,999 words being contained, exclusive of
the herein addendum-certificate and of other addenda. See N.H. Sup. Ct. R. 16(11), 26(7).
December 3rd,
2018
Paul J. Maravelias
PRAYER FOR ORAL ARGUMENT
The Appellant, Paul Maravelias, respectfully requests
Oral Argument before the full court pursuant to Rule 16(h). 15 minutes are
requested.
APPENDIX
Trial
Court Exhibits
Maravelias’s January 2017 Dialectic Disproof of DePamphilis’s Mendacious 12/28/16
Stalking Petition, Entered as Evidentiary Exhibit................................................. RApp1
Ongoing Trial Court Litigation on Maravelias’s
10/31/18 Motion to Set Aside Judgement (A115-149) Regarding Judge John J.
Coughlin Bias/Judicial Misconduct
Inexplicable 11/16/18 Two-Sentence Order Flatly Denying Maravelias’s
Motion, Shockingly Signed by Believed-To-Be-Retired Judge Coughlin Himself[6]........................... RApp12
Maravelias’s 11/21/18 Motion for Recusal and Reconsideration, Decrying the
Further Judicial Misconduct of Judge Coughlin Ruling on a Motion Analytically
Arguing His Own Material Misconduct, and Correcting DePamphilis’s Incorrect
Objection That Maravelias’s 10/31/18 Motion to Set Aside Judgement Was
“Untimely”.............................................. RApp14
[1] Record-citations identical to Appellee’s brief, with
addition of:
OB = Appellee DePamphilis’s 11/21/18 Opposing Brief
RApp =
Appendix herewith
[3] As crossing state lines engenders federal
jurisdiction where the sexual age-of-consent rises to 18, 16-year-old Christina
DePamphilis implicated herself and her 21-year-old boyfriend Matthew LaLiberte in
federal felony sex crimes under 18 U.S.C. § 2422, 2423 punishable by up to 30
years in federal prison, as well as an additional Massachusetts state-level felony
violation of M.G.L. 272§4, “Inducing person under Eighteen to have sexual
intercourse”.
As these two un-convicted sex offenders were off jollily honeying over the
nasty sty in Winter/Spring 2017, Paul Maravelias was finishing school stoic,
chaste, and overwhelmed into inadvertent long-duration fasting, having to
explain to friends why Windham Police was raiding his Dartmouth dorm room on
4/6/17 (because he’d pressed a button on his cellphone to record himself, and
later tried to disprove DePamphilis’s vile perjuries in court) – having been
falsely branded a “stalker” by an incompetent New Hampshire family court for
asking-out a girl on a date first-time in his life.
Then, a few months later, out-of-the-blue, Christina DePamphilis and her
boyfriend (and David DePamphilis) pleasured themselves with their cruel 6/21/17
social media bullying of Maravelias (Brief21-22;A11-13),
rubbing-in the boyfriend, baiting Maravelias to respond.
[4] Casual invitation for an after-work leisurely amble
to the Windham Police Department is extended to the reader, a place where he or
she may listen to the 12/12/16 audio recording and ascertain that Maravelias never
mentioned anything remotely close to
the creepy “age of consent” quote upon which Judge Stephen specifically predicated
the whole underlying stalking order.
[5] Still, only lack of vagueness – not overbreadth – of
“good cause” was decided there.
[6] The rank ineptitude of the Derry trial court in
unlawfully disclosing the residential whereabouts of the Plaintiff in this
mailed Order (in violation of RSA 173-B:3 I.) is redacted in this Appendix
herewith. This error seems to have been committed by Judge Coughlin himself, rather
than by the clerk, as it appears on the page of his Order (RApp13) and not on the
clerk’s boilerplate notice form thereof (RApp12).