THE STATE OF NEW HAMPSHIRE

ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY

Docket No. 473-2016-CV-00124

Christina DePamphilis
v.
Paul Maravelias

MOTION TO STRIKE

NOW COMES Paul Maravelias (hereinafter, “Defendant”) and respectfully moves this

Honorable Court to strike from the record portions of Christina DePamphilis’s (hereinafter,

“Plaintiff”) 3/18/19 pleading entitled Plaintiff’s Verified Motion to Reconsider. In support

thereof Maravelias avers the following points of fact and law:

I. INTRODUCTION

1. On 3/8/19, this Court granted Plaintiff’s request to extend the stalking order. The

Court’s Order was markedly favorable to DePamphilis, even to the point of transgressing

Defendant’s fundamental free-speech rights. The Court’s Order openly punished Maravelias

because of his “offensive” expressive conduct to third-parties in public – “comments” he

allegedly made on the “internet” to defend himself against DePamphilis’s legal abuse.

2. On 3/21/19, Maravelias filed a Motion to Reconsider the Court’s extension.

3. Remarkably, Plaintiff filed her own Motion to Reconsider as well on 3/18/19.

Defendant is filing a contemporaneous Objection to the said frivolous pleading by Plaintiff.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 4. In her Motion to Reconsider, DePamphilis’s ungrateful bemoaning spans two

topics:

a. In Paragraphs 6 through 15 and Prayers for Relief A and B, she complains that the
Court’s amendment allows Maravelias to appear at his high school for “legitimate
and limited” purposes such as “voting” and “public events”, e.g., such as where
Plaintiff is totally absent.

b. Elsewhere in her Motion, she complains that the Court did not grant an even
longer punitive extension of the restraining order.

5. As a matter of law, Plaintiff is disallowed to advance the first above-referenced

category of complaints within her Motion to Reconsider. While she is theoretically allowed to

advance the second category within the Motion to Reconsider pertaining to the duration of the

extension, the other portions are in violation of the Court’s rules and should be stricken. A

motion for reconsideration cannot be usurped as an opportunity to inject new facts and advance

original legal arguments which could have been timely raised in the incident litigation. Here,

DePamphilis waived her opportunity to do so by failing to file a timely Objection to

Maravelias’s 3/8/19 Motion to Amend.

II. ARGUMENT

A. Plaintiff’s Contentions Opposing the Minor Stalking Order Amendment Violate

the Limited Legal Scope of a Motion to Reconsider Pursuant to Dist. Div. R.
3.11(E)

6. Plaintiff violates the Court’s rules in her 3/18/19 Verified Motion to Reconsider

while attacking the Court’s very modest concession to Maravelias to access a public building

where Plaintiff is absent. See New Hampshire Rules of the Circuit Court – District Division,

Rule 3.11(E), providing in relevant part:

“A motion for reconsideration or other post-decision relief shall be filed within ten (10) days of
the date on the clerk’s written notice of the order or decision which shall be mailed by the clerk
on the date of the notice. The motion shall state, with particularity, points of law or fact that the

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 Court has overlooked or misapprehended and shall contain such argument in support of the
motion as the movant desires to present; but the motion shall not exceed ten (10) pages. To
preserve issues for an appeal to the Supreme Court, an appellant must have given the Court the
opportunity to consider such issues; thus, to the extent that the Court, in its decision, addresses
matters not previously raised in the case, a party must identify any alleged errors concerning
those matters in a motion under this rule to preserve such issues for appeal. A hearing on the
motion shall not be permitted except by order of the Court.” (Emphasis added)

7. The plain language of the Court’s rule mandates that motions to reconsider

highlight “misapprehended” or “overlooked” points of fact of law exclusively. Such motions

cannot function as covert vessels for newfound legal contentions rooted upon original

stipulations of fact. Plaintiff’s Motion to Reconsider is filled to the brim with inappropriate and

previously unseen allegations of fact, even including a photographic exhibit and offering notary

verification to bait the Court to act upon such new inviable introductions of fact. This boldly

violates the Court’s aforecited rule and disparages Maravelias’s due process rights under U.S.

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

8. Plaintiff failed to file a timely Objection to Maravelias’s 3/8/19 Verified

Emergency Ex Parte Motion to Dismiss or Amend Stalking Order to Remedy Voter Suppression

Conspiracy Against Respondent within 10 days of its docketing.2 Accordingly, there is no

noticed, preserved adversarial dispute on this particular issue for the Court to possibly

“reconsider”. DePamphilis waived her opportunity to contest the sought amendment(s) relating

to Maravelias’s presence at his alma mater for limited and legitimate purposes.

1
The Court’s rule to this point, and the necessity of enforcing it, are natural consequences of constitutional due-
process protections. Where DePamphilis attempts to inject unilateral litigation content into an awkward motion to
reconsider, Maravelias is deprived of all his due process rights to face adverse witnesses, cross-examine, make
offers of proof, call his own witnesses, and/or have access to any of the discovery/evidentiary dispensations of a full
trial with both parties present. If the Court were to allow such adversarial conduct improperly transpire through the
unfair medium of a mere unitary Motion to Reconsider, Maravelias would be greatly prejudiced.
2
Maravelias emailed the submitted 3/8/19 Motion to counsel the following day on 3/9/19, affording ample notice
before the 10 days elapsed thereafter wherein she failed to exercise her right to file an Objection.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 9. Plaintiff cannot indicate any “overlooked” or “misapprehended” “points of fact or

law” where she did not raise any for the Court on this point. Although the emergency ex parte

relief did deprive Plaintiff of notice before the preliminary injunction, this fact alone in no way

disabled her from filing a timely Objection within 10-days of the 3/8/19 Motion3 to notice her

arguments in opposition to the sought amendment. In such an event, Maravelias would have had

the proper due-process right to file a Reply and ask the Court for a Hearing on the matter.

B. Plaintiff Had, and Still Has, Adequate Alternative Remedy to Seek Amendment of
the Stalking Order Without Improperly Usurping a Motion for Reconsideration
to Maravelias’s Injury

10. Despite Plaintiff’s failure to file a timely Objection to Maravelias’s 3/8/19 Motion

to Amend, she does not lack a statutory remedy. RSA 175-B:5, VIII.(b) provides:

“(b) If either party wishes the defendant to be excused from any provisions of an order of
protection, the remedy is to petition the court for modification of such order.”

11. Although the statute secures this necessary due process right to defendants

wishing to be excused from certain terms, DePamphilis certainly has shown no timidity in the

past from delegating to herself the inverse right. See DePamphilis’s 7/2/18 Motion to Amend the

stalking order – long after the 2018 extension ruling – seeking to criminalize Maravelias for

possessing public court exhibits documenting her online cyberbullying and middle-finger

harassment of Maravelias.

12. Similarly, Plaintiff can file a separate and proper motion to further attack

Maravelias’s rights and stifle Maravelias’s legitimate affairs in public in his town. However, she

cannot lawfully usurp a Motion to Reconsider the extension ruling as a forum for these new

absurd, bad-faith contentions.

3
See Dist Div. R. 1.8(D), staying motions for 10 days until “the court may act thereon”, leaving ample time for the
opposing party to file a timely Objection pleading, regardless of any preliminary ex parte action.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 C. The Doctrine of Res Judicata Bars Plaintiff from Litigating These Contentions

13. “The doctrine of res judicata ensures that ‘a final judgment on the merits of an

action precludes the parties or their privies from relitigating issues that were or could have been

raised in that action.’ Butland v. New Hampshire Dept. of Corrections, 229 F. Supp. 2d 75

(D.N.H. 2002), citing Allen v. McCurry, 449 U.S. 90, 94, 101 S. Ct. 411, 66 L. Ed. 2d 308

(1980).

14. In New Hampshire, the elements of res judicata are: “(1) the parties must be the

same or in privity with one another; (2) the same cause of action must be before the court in both

instances; and (3) a final judgment on the merits must have been rendered on the first action.”

Brzica v. Trs. of Dartmouth Coll., 147 N.H. 443, 454, 791 A.2d 990 (2002).

15. Notwithstanding her potential statutory remedy to seek further amendments to the

stalking order unfavorable to Maravelias by proper Motion, res judicata bars relitigation of

Maravelias’s 3/8/19 Motion to Amend within a disconnected motion to reconsider the stalking

extension request.

16. Between Maravelias’s 3/8/19 Motion raising the issue and Plaintiff’s inapposite

3/18/19 Motion to Reconsider the extension order, the parties are unquestionably identical.

Further, the “same cause of action” (a certain amendment to a RSA 633:3-a civil stalking order

pertaining to Defendant’s permission to appear in certain public buildings) is before the Court.

17. A “final judgment on the merits” was rendered when 1) the Court partially

granted Maravelias’s 3/8/19 Motion by amending the stalking order through the extension

decision issued that day, and 2) when 10 days had thence passed by 3/18/19, within which

DePamphilis possessed a right to file a timely Objection to contest Maravelias’s Motion to

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
Amend – a right she voluntarily forfeited, notwithstanding the Court’s exigent preliminary

injunction granted due to the imminent 3/12/19 Windham town election.

18. By forfeiting her opportunity to oppose Maravelias’s 3/8/19 Motion to Amend by

means of the standard common-law adversarial process of filing a rule-compliant Objection, res

judicata bars her subsequent re-litigation of that issue inside a motion for reconsideration.

D. Plaintiff’s Rule-Breaking, Scandalous Contentions Should Be Stricken from the

Court’s Record

19. The Court may strike a pleading where a party introduces redundant, immaterial,

impertinent, or scandalous matter. See, e.g., Fed. R. of Civ. Proc 12(f). A Motion to Strike is

particularly appropriate where a party usurps judicial pleading as a forum to launch baseless

defamatory attacks against an individual, as DePamphilis has done within the offending portions

of her Motion to Reconsider (e.g., her remorseless and criminal mischaracterization of

Maravelias at Paragraph 12). See, e.g., Magill v. Appalachia Intermediate Unit 08, 646 F. Supp.

339, 343 (W.D. Pa. 1986) (striking allegations that “reflect adversely on the moral character of

an individual” where “unnecessary to a decision on the matters in question”).

20. Paragraphs 6 through 15 and Prayers for Relief A and B of Plaintiff’s Motion to

Reconsider meet this standard. They are wholly “immaterial” and “impertinent” by virtue of

violating the Court’s rules while lacking legal viability. Further, DePamphilis commits unabated

criminal libel against Maravelias at Paragraphs 12 and 14 by hurling baseless vituperations

crafted to disparage Paul Maravelias’s noble reputation and character.

III. CONCLUSION

21. Accordingly, the instant Motion to Strike should be granted. The Court should not

tolerate inappropriate manners of legal contention, especially where DePamphilis is lawyer-

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
represented and expected to know and follow the Court’s rules. There is no valid reason pro se

“23-year-old” Maravelias should have greater knowledge of and respect for The Honorable

Court’s rules than DePamphilis’s 53-year-old bar-admitted attorney who has been practicing in

this state longer than the parties have been alive.

WHEREFORE, Respondent Paul Maravelias respectfully prays this Honorable Court:

I. Grant this Motion;

II. Strike from the record and not consider Paragraphs 6 through 15 and Prayers for
Relief A and B of Plaintiff’s Verified Motion to Reconsider filed 3/18/19;

III. 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 to Strike 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

ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY

Docket No. 473-2016-CV-00124

Christina DePamphilis
v.
Paul Maravelias

OBJECTION TO PLAINTIFF’S MOTION TO RECONSIDER

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

to Plaintiff’s 3/18/19 Motion to Reconsider. In support thereof Defendant states as follows.

I. CHRISTINA DEPAMPHILIS’S LAUGABLE “MOTION TO RECONSIDER” IS

LIKE SOMEONE WHO COUNTERFEITS A LOTTERY TICKET, STEALS
$500,000 FROM THE STATE, AND THEN SUES THE STATE’S LOTTERY
COMMISSION CLAIMING TO BE OWED EVEN MORE STOLEN MONEY

1. On 3/18/19, Plaintiff filed her own Motion to Reconsider the Court’s 3/8/19 Order

which was extensively favorable to her, openly punishing Maravelias’s lawful speech in public

in which he defended himself against her cruel, scandalous campaign of defamatory legal abuse

through the instant falsified restraining order.

2. Despite having been exposed as a boldface liar on multiple occasions, see

Appellant’s Brief in NHSC Case No. 2018-483, and despite the entire “following” gravamen of

her present extension case having been proven a total and utter fabrication, she now posits the

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
audacity to ask this Court extend the legal abuse even longer, and to further stifle Maravelias’s

legitimate, necessary, and rare business in his own town’s public building.1

3. DePamphilis’s Motion to Reconsider petitions the Court to extend the stalking

order for 5 years instead of 1 year. The said contention is beyond meritless, gratuitous, and

malevolent. DePamphilis’s Motion to Reconsider should not be well-taken by the Court. Indeed,

it is uncomfortably disrespectful to the Court that she would petition for such even-greater relief

even after the Court graciously allowed her to lie about “following” and not be held in contempt.

4. Maravelias respectfully argues that no extension at all should be granted, for the

many reasons noticed within his own 3/21/19 Motion to Reconsider.

II. BY OPPOSING THE MINOR AMENDMENT TO THE STALKING ORDER,

PLAINTIFF REAFFIRMS HER PATENTLY UNREASONABLE, BULLYING
CONDUCT AND MOTIVATIONS TO CRIMINALIZE MARAVELIAS’S
LEGITIMATE PRIVATE AFFAIRS HAVING NOTHING TO DO WITH HER

5. This entire component of DePamphilis’s Motion to Reconsider is inappropriate,

legally inapposite, and unactionable. Accordingly, it should be stricken from the Court’s record.

See Defendant’s 3/28/19 Motion to Strike filed herewith. Hereinafter, Maravelias opposes the

substance of Plaintiff’s opposition to the amendment, in case the Motion to Strike is not granted.

1
DePamphilis brings this contention even after criminally attempting to suppress Maravelias’s voting
activity, as explicated in Maravelias’s 3/8/19 Motion and reaffirmed by her guilty failure to file any
Objection thereto whatsoever. She made no attempt at all to counter Maravelias’s legal analysis which
concluded her and her attorney’s voter suppression conspiracy was indeed criminal. Instead, she includes
a baseless footnote at Page 2 of her Motion to Reconsider, alleging contrary to RSA 657:1 that the
Windham town website alludes to Absentee ballots being available to people subject to restraining orders.
Accordingly, Attorney Simon R. Brown commits his usual business of subterfuge and duplicity to
advance his baseless arguments, since the language “[persons having] an active protective order”
obviously refers to protected-party plaintiffs “having” such orders, not to the restrained defendants
thereof. See RSA 654:25, RSA 654:12, V.(b), and RSA 657:15, II., excluding from certain voter
registration lists the information of protected parties under RSA 173-B restraining orders. Either Attorney
Brown has inferior reading comprehension skills to a 23-year-old with zero legal training, or he is making
willful misrepresentations to the Court. And accordingly, all experience hath shewn the latter.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 6. The Court’s minor amendment to the stalking order is appropriate and narrow. If

anything, it does not go far enough to disencumber Maravelias of needing to constantly be on the

defensive against DePamphilis’s legal abuse mission to get him arrested for simply going about

his own private life, never contacting or going near her.

7. Christina DePamphilis and Maravelias’s sister are students at Maravelias’s high

school only for a few more weeks, until June. Maravelias’s “limited and legitimate” activities

within this short time which could involve his presence at his own alma mater are only: 1)

voting, 2) picking up/dropping off his sister from school, and 3) attending his sister’s graduation.

8. Absolutely none of these “limited and legitimate” potential activities in the next

10 weeks require Maravelias to come anywhere near David DePamphilis’s scary daughter.2

Consequently, there is no cause to make the stalking order against Maravelias any more punitive.

III. CHRISTINA DEPAMPHILIS AND HER ATTORNEY SIMON R. BROWN

SHOULD BE SANCTIONED, HELD IN CONTEMPT OF COURT, AND
CRIMINALLY CHARGED FOR THEIR CONTINUED WILLFUL FALSE
STATEMENTS IN LEGAL PLEADINGS AND FRAUDULENT
MISCHARACTERIZATIONS

9. The NH Rules of Professional Conduct and RSA Chapter 641, “Falsification in

Official Matters”, are herein repeated and incorporated by reference as though fully set forth.

2
On this point, at ¶11 of her Motion, DePamphilis regurgitates a ridiculous list of “public events”
Maravelias would have interest or connection with, then deceptively consummates the list with an
adverbially emphasized reference to “even Christina’s graduation” (emphasis added), which DePamphilis
knows is a valid “public event” Maravelias clearly plans to attend for his own sister. Attorney Brown
again manifests his routine deceitful chicanery before this Court, since he knows Maravelias’s sister
Deborah is also graduating in June, and that Maravelias would have most certainly made a separate
Motion anyway to permit him to attend his own sister’s graduation at his own high school where he
graduated as Valedictorian in 2013. Plaintiff’s misrepresentation conduct is patently unreasonable,
dishonest, and for the sole purpose of staking and harassing Paul Maravelias; accordingly, she should be
sanctioned.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 10. At ¶14 of her Motion, DePamphilis remorselessly realleges the long-debunked

falsehood that she was “forced to flee her 8th grade graduation due to Defendant’s concerning

behavior” 4 years ago in 2015. As previously shown at the 2018 extension, this baseless

allegation was about as true as her false allegation that Maravelias had “approached” her at the

“2013 Turkey Trot”, whereupon a cellphone video surfaced depicting Christina DePamphilis

running up to Maravelias, interrupting his conversation, and approaching him at that event – after

she asserted in her stalking petition the wild lie that the opposite had happened.

11. At ¶17 and ¶19 of her Motion, DePamphilis claims Maravelias “shows no signs of

ceasing his harassment of Christina and her family through the Internet”. This outrageous

contention imputes criminal intent to Maravelias’s protected free-speech conduct of documenting

her own legal abuse against Maravelias – sharing already-public court documents – by posting

copies on the internet of filings in this case. DePamphilis does not cite an iota of support for her

contention that Maravelias has committed “harassment” under RSA 644:4.

12. DePamphilis and her attorney should be sanctioned for wanton violation of Rule

3.1 of the New Hampshire Rules of Professional Conduct, prohibiting meritless and

unsubstantiated contentions. Punitive sanctions are all more necessary in light of DePamphilis’s

extreme and ongoing “harassment” of Maravelias, through the internet and other means.3,4

3
E.g., the act of posting incitative bullying posts against Maravelias on social media with vulgar gestures
and using Christina DePamphilis’s boyfriend as a failed incitation mechanism. This speech is not
protected and is the very essence of RSA 644:4, criminalizing of “harassment”, committed when one
“insults, taunts, or challenges another in a manner likely to provoke a violent or disorderly response”.
4
E.g. also, David DePamphilis recent and ongoing slander campaign against Paul Maravelias, touring
proximate coffee shops to tell strangers Maravelias is a “pedophile” and emailing state representatives to
advance similar false, defamatory representations to malign Maravelias’s reputation.

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PAUL MARAVELIAS – 34 MOCKINGBIRD HILL RD, WINDHAM, NH 03087
 13. Unabashedly, DePamphilis obviates her generic obscurantist dishonesty by

referring to Mstr. Nate Vigeant, David DePamphilis’s son’s intimate-partner boyfriend, as his

“son’s friend”. It is literally true that one’s wife, girlfriend, husband, or boyfriend can be

described as a “friend”. However, DePamphilis’s bizarre off-topic references to Master Vigeant

(who was only mentioned in a passing footnote in Maravelias’s 3/8/19 Motion) are deceptive and

totally unnecessary. Accordingly, they are suggestive of a homophobic motivation to disown

Mstr. Vigeant’s intimate-partner boyfriend relationship to DePamphilis’s son, as if this well-

known, undenied fact is something to be ashamed of.

IV. DEPAMPHILIS’S LEGAL ABUSE AND EXTORTION AGAINST MARAVELIAS

HAVE AMOUNTED TO HUNDREDS OF THOUSANDS OF DOLLARS IN LOSS
AND DAMAGES, YET SHE HAS THE AUDACITY TO BEG THE COURT TO
FURTHER ABUSE MARAVELIAS’S RIGHTS TO MINIMIZE HER FUTURE
SPECULATIVE “LEGAL FEES”

14. David DePamphilis, the rich 50-year-old business executive paying for and

pulling the strings behind his revenge-puppet daughter Christina to wage this illegitimate war of

legal abuse and defamatory harassment against Maravelias, asks the Court to abuse Maravelias’s

constitutional rights for 5 further years instead of 1 year because this might save him some

money in the future. See Plaintiff’s Motion to Reconsider, ¶20.

15. Paul Maravelias’s fundamental rights are more important than David

DePamphilis’s ability to purchase a third house or a sixth car.5,6

5
Last year, in April 2018, David DePamphilis requested this Court hold a Hearing on one of his Motions
in Paul Maravelias v. David DePamphilis. Once scheduled, DePamphilis filed a Motion to Continue so he
could enjoy his lavish vacation to Aruba undisturbed. In DePamphilis’s Motion to Continue, Simon R.
Brown ingeniously stated the following: “Mr. DePamphilis is scheduled to be out-of-state”.
6
David DePamphilis’s custom of using the instant restraining order legal abuse to financially extort
Maravelias has a long history. In the original stalking petition, the DePamphilis actors petitioned Judge
Stephen to force Maravelias to pay for DePamphilis’s “surveilance[sic] camera[s]”. Even Judge Stephen
was disturbed by such a meritless, absurd, and quickly-rejected request.

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

I. Grant this Motion;

II. Deny Plaintiff’s 3/18/19 Motion to Reconsider;
III. Grant Defendant’s 3/21/19 Motion to Reconsider 3/8/19 Order Granting Stalking
Order Extension; and
IV. Grant any further relief as may be deemed just and necessary.

Respectfully submitted,

PAUL J. MARAVELIAS,

March 28th, 2019 in propria persona

CERTIFICATE OF SERVICE

I, Paul Maravelias, certify that a copy of the within Defendant’s Objection to Plaintiff’s Motion
to Reconsider 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

ROCKINGHAM, SS 10TH CIRCUIT – DISTRICT DIVISION – DERRY

Docket No. 473-2016-CV-00124

Christina DePamphilis
v.
Paul Maravelias

ERRATA SHEET TO DEFENDANT’S OBJECTION TO

PLAINTIFF’S MOTION TO RECONSIDER

Paul Maravelias (“Defendant”) respectfully submits the within errata sheet to his 3/28/19

filing entitled “Objection to Plaintiff’s Motion to Reconsider”.

1. ERRATUM: Within the first sentence of Footnote 2 on Page 3, the word “no” is added
as follows: “…ridiculous list of ‘public events’ Maravelias would have no interest or
connection with, …”

Respectfully submitted,

March 29th, 2019 PAUL J. MARAVELIAS,

in propria persona

CERTIFICATE OF SERVICE

I, Paul Maravelias, certify that a copy of the within Errata Sheet to Defendant’s Objection to
Plaintiff’s Motion to Reconsider was emailed to Simon R. Brown, Esq., counsel for the
Petitioner, Christina DePamphilis, sbrown@preti.com.

______________________________

March 29th, 2019

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