Court Transcripts

Check out the dim-witted duo of Watertown Officers Mafhoum and Unsworth.

The 2/26 transcript has Mafhoum fearing fire and Judge Garner coaching both boys. It also has Unsworth’s fixation on the number 23.

The 3/13 has Mafhoum babbling about how can’t possibly live in NH because the house is full of mice and the furnace is broken. Also, he was confused by a pallet of paperwork that was all electronic and he didn’t have a real estate lawyer.

3/13 has Unsworth struggling to figure out what the criminal violation was that he charged her with.

3/13 features Tim Bradl teaching the boys what an actual threat is.

3/18 Judge Garner explains to the boys the basics of civil rights and government petitioning

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2/26/20206 EX PARTE

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3/13/2026 TWO-PARTY HEARING

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3/18/2026 VERDICT HEARING

Ex Parte Hearing

February 26, 2026

2606RO00082

BMC Judge John Garner

West Roxbury Courthouse

POLICE DISPATCHER: 100 on primary.

OFFICER 1: 100.

DISPATCHER: 100, West Roxbury District Court would like to know if you can have an OFFICER go over there for a hearing on a 258E against a member of the Watertown PD.

OFFICER 1: Yeah, I’ll go over. Is there an ETA?

DISPATCHER: They didn’t specify, but I’ll let them know you’re on the way.

OFFICER 1: 100, copies. I’m on the way.

DISPATCHER: Copy that, 100.

OFFICER 1: 100, at the court.

DISPATCHER: Copy that, 100.

JUDGE: Thank you. I’ll try this podium.

CLERK: Do you solemnly swear to tell the truth, the whole truth, and nothing but the truth, so help you God?

MAFHOUM : Yes, I do.

JUDGE: Are you Officer Khalil Mafhoum? Good afternoon, Officer Khalil Mafhoum.. You are seeking a restraining order,abuse prevention order against Amy Dubé, correct?

MAFHOUM : Yes, your Honor. That’s correct.

JUDGE: How do you know Ms. Dubé?

MAFHOUM : She was my ex-girlfriend.

JUDGE: Okay. And when did the relationship end?

MAFHOUM : Ended in 2018, so it lasted from 2016 to 2018.

JUDGE: 2018.

MAFHOUM : Yes, your Honor.

JUDGE: Okay, let me just take a look at your affidavit. Hold on one second.

(Paper shuffling and keyboard typing)

JUDGE: Officer Mr. Mafhoum I’ve read your affidavit and reviewed the other paperwork that I have here.

JUDGE: Could you step over here?

(MAFHOUM steps aside from the mics, as Judge Garner directed him to,

so whatever was discussed between them is muffled)

JUDGE: So, as a police officer, you probably know that I can only issue this order if I find that you are in reasonable fear of imminent bodily harm, as the law says. Reasonably fear imminent bodily harm. So she’s making all these letters and notices and that kind of stuff.

MAFHOUM : Yes, your Honor. I’ve gone to the clerk’s office before to apply for a harassment prevention order.

JUDGE: Yeah, harassment.

MAFHOUM : Yeah, but I was told to file under a 209A.

JUDGE: Okay. But you’re also asking for the non-abuse...

MAFHOUM : Yes, your Honor.

JUDGE: Okay, so she’s your ex-girlfriend, but you’re not married and you don’t have children together.

MAFHOUM : No, your Honor.

JUDGE: Okay, so she’s harassment. What is she saying in these notices that she sends to you?

MAFHOUM : She says she’s going to get me fired.

JUDGE: She’s going to get you fired?

MAFHOUM : Yes, your Honor. She’s contacted my employer because she says that I’ve abused her in some way and that I’m unfit for duty. So I found out about it through my employer.

JUDGE: Right. And what else?

MAFHOUM : And on my last... on my last employer, she’s claiming that I married her because she says that I needed help to get a visa.

JUDGE: Right.

MAFHOUM : And on my last employer, I was a civil servant. She sent a list of those things to them.

JUDGE: Okay.

MAFHOUM : And on my last employer, I was a civil servant. She sent a list of those things to them. And she just continues this harassment.

JUDGE: Okay. Do you have copies of the letters that she sent?

MAFHOUM : Yes, your Honor. She sent them on her phone.

JUDGE: Do you have a copy of it?

MAFHOUM : Yes, your Honor. I have them in my hand.

(JUDGE reviews copies)

JUDGE: Officer Khalil Mafhoum , so he went into the clerk’s office to apply for harassment, but someone said no, you’ve gotta apply for a restraining order because they were in a relationship before. But it sounds more like a harassment issue than a 209A.

JUDGE: And I think I can issue the harassment instead of the restraining order.

CLERK: Oh, okay.

JUDGE: Does Amy Dubé have a child?

MAFHOUM : Yes, your Honor. I think she gave birth to a daughter.

JUDGE: When did she send this?

MAFHOUM : She sent it this Friday to my house, my previous home.

JUDGE: What address is that?

MAFHOUM : That was on Manchester Street.

JUDGE: Manchester Street?

MAFHOUM : Yes, your Honor.

JUDGE: And when was that?

MAFHOUM : That was back in 2022. 2022.

MAFHOUM : Yes, your Honor.

JUDGE: So let me ask you this. For me to issue the harassment, I have to find that you’re in imminent fear. And I’m actually going to look at the harassment side rather than the restraining order side.

JUDGE: But I have to find, because this is a one-party hearing, I have to find that you’re in

imminent fear of harassment. So that means something that’s happened very recently, in the last week or two.

MAFHOUM : Yes, your Honor.

JUDGE: So tell me what’s happened in the last couple of weeks.

MAFHOUM : So she sent out a couple of letters to the Watertown police department.

JUDGE: Watertown police department?

MAFHOUM : Yes, your Honor.

JUDGE: And?

MAFHOUM : She said that... she sent it February 13th, 2026.

JUDGE: Okay.

MAFHOUM : And she said every 10 to 15 minutes, someone is going to show up to my house and fire a fire...

JUDGE: Okay.

MAFHOUM : ...to show up to my house and fire a fire.

JUDGE: Okay. And this is regarding you now, right?

MAFHOUM : Yes, your Honor. She sent a message that she’s going to talk to my manager and tell him she’s going to have some contact with some police officers and they’re going to fire me.

JUDGE: These are all on February 13th?

MAFHOUM : Yes, your Honor.

JUDGE: And what did they say?

MAFHOUM : They... they mock the police and they talk about... she has copies of my email, all of them.

JUDGE: Okay.

MAFHOUM : I’m so afraid for my house and my life. My wife is crying.

JUDGE: Right.

MAFHOUM : I have two children to feed. My wife doesn’t work, I’m the sole earner. I don’t want to lose my job. I don’t want to lose my

house.

JUDGE: Right.

MAFHOUM : Not to mention that she’s writing letters like that that say that we’re sleeping and she’s coming to our house and firing a

fire.

JUDGE: She said that?

MAFHOUM : No, no. I’m saying what my wife is afraid of. She said that... when we go to sleep, or when our house is on fire... this

person shows up.

JUDGE: Is the captain here now?

MAFHOUM : Yes, your Honor.

JUDGE: Is he here?

MAFHOUM : Yes, your Honor.

JUDGE: Let me bring him up for a moment here. So you go back over there. What’s the gentleman that’s with you? What’s his name?

MAFHOUM : Captain Daniel Unsworth.

JUDGE: Unsworth?

MAFHOUM : Yes, your Honor.

JUDGE: Captain Unsworth, can you come up?

(CAPTAIN DANIEL UNSWORTH approaches)

JUDGE: Right up front there. Could you swear in?

CLERK: Do you solemnly swear to tell the truth, the whole truth, and nothing but the truth, so help you God?

UNSWORTH: Yes, I do.

JUDGE: And what’s your name again?

UNSWORTH: My name, your Honor, is Dan Ellsworth. I’m a captain with the Watertown PD.

JUDGE: Okay. Captain Unsworth, so Officer Khalil Mafhoum here is here seeking a harassment order.

JUDGE: In order for me to issue the order, I have to find that there have been three separate incidents directed at him intended to cause him fear, intimidation, abuse, or damage his property in some way. Collectively, they have to do just that.

JUDGE: Each of the incidents have to be willful and malicious in nature. That means they can’t be accidental and they have to be motivated out of revenge or cruelty.

JUDGE: Captain, Officer Khalil Mafhoum said that you have some information about that... the particular aspects of the communications?

UNSWORTH: Yes, your Honor. Again, we have... based on my research, my investigation, we have contact in person going directly to Officer Khalil Mafhoum’s residence in 2022. That car that you saw delivered...

JUDGE: Oh, in the most recent as I said...

UNSWORTH: Of course. Of course. Yes. This is a one-sided, an ex-parte order. In order for me to issue it, I have to find that there is an imminent fear.

UNSWORTH: Of course. So, to the best of my research in the last 10... from February 13th through February 24th...

JUDGE: Of this year?

UNSWORTH: Yes. In the last 10 days or so, we’ve received 23 emails sent to the Chief of Police, the City Manager, the City Council,

Secretary of State, District Attorney’s office, post, Homeland Security.

JUDGE: And what’s the nature of those communications?

UNSWORTH: They’re all indicating that Officer Mafhoum is not fit for duty as a member of the police department. Other statements we’ve researched that indicate they’re not accurate.

Indicate he’s had marriages for profit to help folks gain visas.

UNSWORTH: We’ve, of course, before Officer Khalil Mafhoum was hired as a police officer, we conducted a thorough investigation into his background. Since this has arisen, we’ve further delved into the background to confirm that many of these statements, all these statements appear to be misleading.

UNSWORTH: Again, Officer Khalil Mafhoum I’ve had in my office clearly distressed. I know the family is experiencing some distress. And again, I’ve got a list here of the different folks that have been contacted. And it appears to be a clear pattern.

UNSWORTH: Officer Khalil Mafhoum was employed by the state police, the state police were contacted.

UNSWORTH: Officer Khalil Mafhoum was employed by the Suffolk County Sheriff’s Department, they were contacted. Investigated all these same allegations to no avail, and here we are again, the third employer in law enforcement again contacted.

UNSWORTH: As of late, again we note the time frame is important to note. Friday the 13th is when we received the first email. That was the day leading into school break. The last email we received was on the 24th, two days ago. And you know on Friday the 13th, that was the day leading into school vacation. School vacation finished up, then we had two snow days. And that was the last day we received a communication.

UNSWORTH: The person involved here, Ms. Dubé, is a teacher we believe in the Lynn public schools. So the timing coincides.

UNSWORTH: And we’re concerned about the nature of the content of the messaging... appears to be... we’re concerned about health issues for that person.

JUDGE: Okay. All right. Thank you very much. Thank you.

JUDGE: Officer Khalil Mafhoum , so again I have to find that those emails and those contacts that were made to those other agencies and departments concerning you left you with a state of fear and anxiety, abused you in some way, caused you harassment in some way.

JUDGE: Is that your testimony today?

MAFHOUM : Yes, your Honor. Yes, your Honor. I couldn’t sleep, your Honor. My wife was crying, putting stress on our marriage. I have two children, my wife, like I mentioned, doesn’t work, I’m the sole earner. I work a lot of hours to keep the lights on and a roof over our heads.

MAFHOUM: And it’s not fair that at every chance this person gets, defamation of character, all this negative emails are shooting me in a negative light.

MAFHOUM: It’s unfair.

MAFHOUM: I have no contact with this person. I don’t have anything to do with her. We’ve never even lived together. And she just would not leave me alone. And I don’t even know what it will take.

MAFHOUM: I actually attempted to get a restraining order against her in the court of Manchester, district court, New

Hampshire.

MAFHOUM: And instead of filing for harassment prevention, I did the 209A and it did not... they granted it temporarily but it didn’t continue.

MAFHOUM: Your Honor, I words cannot express what it’s doing to my marriage and what state of mind it’s putting me in.

JUDGE: All right. Thank you, Officer Khalil Mafhoum. Hold on one second.

(judge reviews notes)

JUDGE: Based on your testimony and the testimony I’ve heard from the captain, the court is going to issue the order.

JUDGE:So, Ms.Dubé is ordered not to abuse you, she’s not to contact you directly, indirectly, or through a third party.

JUDGE: She’s to stay at least 100 yards away from you, away from your residence, away from your workplace. The locations of those will not appear on the order itself.

JUDGE: She’s to surrender any firearms that she has to the police department once she’s served with the order.

JUDGE: This is a temporary order as I explained to you. It expires on March 12th at 4:00 in the afternoon. If you want to extend the order further at that time, depending on what the judge hears, a judge could extend the order for a year.

JUDGE: On that day, you should be in the courtroom at 10:00. The hearing will be held at 10:00.

JUDGE: She’ll be served with a copy of the order, she can appear if she wants to. You’ll get a copy of the order, you should keep it on your person at all times.

JUDGE:If anything gives you any concerns for your safety, you should call the police.

JUDGE: Do you have any questions?

MAFHOUM : No, your Honor. Thank you so much.

JUDGE: All right. You can go back to the clerk’s office and get copies.

MAFHOUM : Thank you, your Honor.

Two Party Hearing

March 13, 2026

2606RO00082

BMC Judge John Garner

West Roxbury Courthouse

CLERK: May we read on the file the notice of appearance on behalf of the defendant. Thank you.

DEFENSE COUNSEL: Good morning, Madam Clerk. Good morning, Your Honor.

JUDGE JOHN GARNER: Good morning.

MAFHOUM: Good morning.

CLERK: Do you solemnly swear or affirm the testimony you’re about to give in the matter now in

hearing should be the truth, the whole truth, and nothing but the truth, so help you God?

**Witnesses:** I do.

CLERK: Thank you.

JUDGE: Alright, good morning.

**Mr. Mafoum / DEFENSE COUNSEL::** Morning, Counsel. Morning, sir. Morning, Your Honor.

JUDGE: Um, sir, you are here, um, seeking to extend this order. Are you against Ms.

Dubé?

MAFHOUM: Yes, Your Honor.

JUDGE: Alright. Uh, let me—and you’re opposed to that, obviously?

BRADL: Yes, we are, Your Honor.

JUDGE: Okay. Let me just take a look at what I have here. Hold on one second.

(Pause)

JUDGE: Alright, thank you for your patience. Uh, Mr. Mafhoum, um, I read your affidavit.

JUDGE: In order for me to continue this order, I have to find again that you’re suffering from harassment from Miss Dubé.

JUDGE: And the law defines harassment as three or more incidents directed to you, intended to cause you fear, intimidation, abuse, or damage your property in some way.

JUDGE: Collectively, all three of those have to do just that. Each of the instances has to be willful and malicious in nature.

JUDGE: Willful meaning they weren’t accidental, and malicious meaning they’re motivated out of revenge or cruelty.

JUDGE: So, you wrote in your affidavit about the contacts you say Ms. Dubé made with your employers. Can you tell me a little bit about those contacts?

MAFHOUM: Yes, Your Honor. Uh, so just a little bit of a refresher. Uh, I had a dating relationship with the defendant, uh, started in 2016, uh, on and off ended in 2018.

MAFHOUM: The defendant contacted my previous employer, Mass State Police, upon the relationship ending. also I had items left in my residence, uh, time living in Brockton.

MAFHOUM: Again, I moved on to work for the Suffolk County Sheriff’s Department. The defendant contacted immigration enforcement as well, sent anonymous emails to my previous employer stating that all my marriages are fraud.

MAFHOUM: Um, I had been married prior, my current wife is here, I’m married with children right now. Um, again, I decided to—I moved and changed my address purposely so she doesn’t see where I live and what I do.

MAFHOUM: And she’s constantly researching, looking for where I live. We were surprised upon bringing our daughter home after she was born, uh, my wife goes out to get the mail, there’s a hate letter directed at my wife and my child.

JUDGE: And when was that?

MAFHOUM: This was in, um, um, 2022, sir.

JUDGE: Alright.

MAFHOUM: So I attempted to, uh, get a restraining order against her. Um, the order wasn’t continued;

MAFHOUM: However, the defendant admitted to creating a website under my name, contacting all my previous employers.

MAFHOUM: Again, I had no contact with the defendant since 2022, uh, October of 2022. Again, on February 13th, uh, this year, emails started during that snowstorm, um, school vacation.

MAFHOUM: Emails started flooding the Watertown City Manager, 9 Watertown City Council members, the Chief of Police...

MAFHOUM: I neglected to say that I transferred from the Suffolk Sheriff’s Department to the Watertown Police Department. Um, again, the Homeland Security, Secretary of State, Executive Director of POST, Middlesex DA’s office, several media outlets...

MAFHOUM: All emails detailed my marriages and claimed falsely that I married related to a release and also the detailed release from the state police.

MAFHOUM: Again, Watertown PD is aware of this. During my background investigation, they re-opened a background investigation again, um, and chosen to retain me.

MAFHOUM: On February 26th, I filed a report with the West Roxbury station E5 with Officer Pat Kelly, and the same day I came here and filed a harassment prevention order before this court,

MAFHOUM: Your Honor. I believe the order was served on February 27th, and the next day, more emails followed violating that order. On February 28th—

JUDGE: On 2/28?

MAFHOUM: Uh, one email February 28th.

JUDGE: And you got an email?

MAFHOUM: Uh, my employer stated seeing that email, sir.

MAFHOUM: So I have my Captain here, he can testify to the amount of emails and the contents of those emails.

MAFHOUM: Again, they’re talking about me, “Khalil this, Khalil that,” “he shouldn’t be hired,” “he’s on the Brady list,” which I’m not,

MAFHOUM: Your Honor, I’ve never lied to court on any of my cases making me a liability to any case she touches.

MAFHOUM: And this is also in the post that she posted online. She’s posting all my business, my private life, she’s going looking up my deed. I own a property in New Hampshire, Your Honor. I personally—

JUDGE: Why is she doing all this?

MAFHOUM: Your Honor, because she’s literally attaching these things to the emails stating that I’m violating residency requirements for a police officer.

MAFHOUM: She’s gone and found my deed.

MAFHOUM: I just refinanced the house trying to renovate the home so it’d be valuable for rent. We have a family member interested.

MAFHOUM: All of these things are constantly looking up where I am.

MAFHOUM: I’m in a new address right now that I’m so afraid that she would find out.

MAFHOUM: And, um, again, Your Honor, 4 emails on March 1st, 9 emails on March 2nd. It was clear that even the restraining order at this point would not stop the pattern of harassment.

MAFHOUM: On March 4th, a complaint was sought and issued for violation of the harassment order by the Waltham District Court since it went after all the councilors and high command staff in Watertown.

MAFHOUM: Um, after consultation with Tim Freder, a supervisor with the Middlesex County DA’s office, we went out and asked for a professional opinion, and the advice was to do that.

MAFHOUM: Lieutenant Ken Swift, he’s a lieutenant in charge of the detective unit, attempted to contact the defendant for further information, he found himself under attack.

MAFHOUM: A sergeant from Boston PD, Nancy Celluci, who oversees domestic violence cases followed up an investigation—even though that sergeant never contacted the defendant, found herself under attack.

MAFHOUM: Captain Unsworth, who is here with me right now to testify to this matter, found himself under attack.

MAFHOUM: The defendant has come to my residence in Brockton, Manchester, seeks my current address,

MAFHOUM: She has contacted my last three employers, made statements that are not accurate.

MAFHOUM: My wife is here also to testify how greatly it’s affecting our family and livelihood, Your Honor.

JUDGE: And what about the other officers being under attack?

MAFHOUM: Uh, emails.

MAFHOUM: for example, the email for Lieutenant Kenneth Swift claimed that he is shadow tracking the defendant, which was not true.

MAFHOUM: Uh, all these emails, the contents, the amount, the intensity, Your Honor, it’s been over eight and a half years.

MAFHOUM: I’m afraid that if this person doesn’t get what she wants, I don’t know what she might do. I do not know.

MAFHOUM: It’s been eight and a half years, no contact, I have never gone, never talked to her, blocked her everywhere.

MAFHOUM: I’m married, have two children, I work hard.

MAFHOUM: I’m just constantly attempting to sabotage my job, to get me to lose my income.

MAFHOUM: And anybody here that their employer gets flooded by emails setting them in a negative light, dragging their name through the mud, Your Honor, would be alarmed, would be in fear.

MAFHOUM: I don’t know what to do. I’ve tried switching states, moved back, moving on with my life, and the defendant does not.

MAFHOUM: From recent action, she can access my financial information and access data by researching

MAFHOUM: I understand a lot of it is public record—but when you go after a specific person, consistently looking and researching, and trying to see how much they made that year, and copy screenshots, attach stuff, and post stuff online, constantly looking up where they moved to, what they’re doing, what they’re refinancing, what business... that’s just targeting me, Your Honor, and my family.

MAFHOUM:I ‘m afraid that if she doesn’t get what she wants, she takes it to the next level.

MAFHOUM: Through her hatred towards my family and me, and her inability to let go of the past and move forward, she would do the unthinkable. I’m tired of looking over my shoulder, Your Honor.

MAFHOUM: I’m tired of trying to hide every place I move to, afraid that one day she might show up at my front door.

MAFHOUM: I don’t know how my wife would react to that if she would just show up. I’m constantly looking over my shoulder.

MAFHOUM: I don’t understand what is it going to take, Your Honor.

MAFHOUM: I’m literally here pleading with the court, asking please to extend the order.

MAFHOUM: This person just wants to hurt me whichever way she can.

JUDGE: Alright, thank you, Mr. Mafhoum. Now counsel, do you have any questions?

BRADL: Um, Judge, could I be heard, uh, in the nature of a motion to dismiss for failure to state a claim first?

JUDGE: No.

BRADL: Sir, um, you wrote in your affidavit that, uh, she hasn’t been in contact with you since 2022, right?

MAFHOUM: Since she sent me the letters.

BRADL: And everything you’re talking about is her emailing other people about you, not emailing you, correct?

MAFHOUM: Uh, me and my financial, with my...

BRADL: Answer my question. Correct or not?

MAFHOUM: Yeah. Yes. Yes.

BRADL: Okay. So you’ve had no contact with her?

MAFHOUM: Since 2022.

BRADL: Okay. So all the emails that you’re talking about were to third parties, right?

MAFHOUM: Yeah, my direct supervisors.

BRADL: Yeah, City Manager? Homeland Security? Department of Secretary of State? Is the answer yes?

MAFHOUM: Yes. Yes, sir. Sorry, sir.

BRADL: So you haven’t had any contact since 2022. You’re mad because she’s contacting your employers about whether you should be in a certain position, right?

MAFHOUM: Uh, she’s contacting trying to get me fired.

BRADL: Okay. Has she ever communicated any threats to you directly?

MAFHOUM: Well, they don’t have to be direct, they’re directed at my employment.

MAFHOUM: So it’s putting me in fear. It’s putting me in fear automatically.

JUDGE: If you can answer the question, you can answer the question.

JUDGE: Do the best you can.

JUDGE: If you don’t know the answer to the question—

MAFHOUM: That’s the answer.

JUDGE: Counsel?

BRADL: You’re a law enforcement officer, you know what a threat is, right?

MAFHOUM: I know what a threat is.

BRADL: Has she ever made a threat to you?

MAFHOUM: In the past, yes.

BRADL: Since 2022, has she ever made a threat to you?

MAFHOUM: Um, no.

BRADL: Has she ever uttered any sort of fighting words to you?

BRADL: You know what fighting words are?

MAFHOUM: Yeah, online, the website she posted.But no, not to me directly again, but posted online, there were definitely fighting words.

BRADL: So she posted things online to the world calling you Officer Giglio and quote-unquote...

MAFHOUM: We can go and see it for yourself, check my name on Google. Uh, I do not know, sir. I do not know that. I didn’t even bother looking at it.

BRADL: So Miss Dubé is posting things about you related to whether or not you should be employed after your history with the State Police, correct?

MAFHOUM: Yeah, more... yes. Yes.

BRADL: And did you recently retaliate against her by calling her school in Lynn, Massachusetts, saying that she was suicidal and she needed a wellness check?

MAFHOUM: Never. Never, Your Honor. On my family, on my children, never. I would never do that, Your Honor. I wouldn’t be here.

BRADL: Now why did you file this in West Roxbury court?

MAFHOUM: Because I live in West Roxbury, sir.

BRADL: Where do you live?

KHALIL MAFHOUM: Uh, can’t say that.

BRADL: So alright then, no, that’s fine. You live in West Roxbury.

MAFHOUM: Yes, sir.

BRADL: So isn’t it true that you have a deed to a property in Manchester, New Hampshire—

JUDGE: Counsel, where are you going with this?

BRADL: Well, he lives in Manchester, New Hampshire. He has a deed that just was in effect 2/17/26 that says that borrower Khalil Mafoum is currently residing in Manchester, New Hampshire.

BRADL: So the venue here is improper, he doesn’t live in West Roxbury, he does live in Boston. And I just want to question him about it.

JUDGE: Your answer under oath is that you live in West Roxbury?

MAFHOUM: Yes, sir.

BRADL: So sir, isn’t it true that on 2/17/2026, and you have the paper there if you can look along...you caused a deed to issue and a mortgage issue in which you indicated, or caused to have indicated, that you are currently residing at 110 North Bend Drive, Manchester, New Hampshire.

MAFHOUM: Sir, that was a refinance. I refinanced the house. That’s wrong.

MAFHOUM: I refinanced the house and they sent a big pallet of paperwork.

MAFHOUM: Uh, the house did not appraise what it needed to be.

MAFHOUM: We were thinking about selling it, because it’s sitting there and needs work, and

MAFHOUM: We wanted to either renovate, sell, renovate, rent... we don’t want to leave the property sitting idle, Your Honor.

MAFHOUM: They sent us a pile of paperwork, sign here, and everything is electronic.

MAFHOUM: I don’t have a real estate attorney or anything.

MAFHOUM: I just wanted the loan to go through as quickly as possible so I can get rid of this property.

MAFHOUM: Because I’m working so hard and this has been a shackle to my foot.

MAFHOUM: Because I don’t live there, I have to go and take care of the property.

MAFHOUM: I have problems with the furnace, problems with rodents...

JUDGE: The question is that you don’t live there?

MAFHOUM: No, I’m not... my primary residence.

MAFHOUM: It’s not my primary residence, Your Honor.

MAFHOUM: I go there to care for the property.

JUDGE: Your answer under oath is that you live in West Roxbury.

MAFHOUM: Yes, sir. Yes, sir

JUDGE: Alright, next question.

BRADL: So when you need to get something done,

BRADL: You’re saying that you resort to whatever it takes and creating any sort of documents that you need to be done?

MAFHOUM: No, no, Your Honor, no I—

JUDGE: Mr. Mafhoum, hold on. Move on, counsel, please.

BRADL: That’s all I have, Your Honor.

JUDGE: Did you have another witness, sir?

MAFHOUM: Yes, Your Honor.

MAFHOUM: My wife, and my Captain here, Your Honor.

JUDGE: You wanna call your Captain?

UNSWORTH: Good morning, sir. I’m a Police Captain of Watertown PD.

JUDGE: He made some references about you receiving some emails from Miss Dubé.

UNSWORTH: Yeah, so beginning on the 13th of February.

UNSWORTH: I haven’t received emails personally,

UNSWORTH: They’ve all been forwarded to me from the Chief of Police.

JUDGE : What was the nature of those emails?

UNSWORTH: Um, okay. I have an email here, it’s sent to Boston Internal Affairs, a lieutenant with the Watertown Police Department, the Boston Globe, our nine City Councilors, and the City Manager.

UNSWORTH: States the 28th of February, 1:47 PM: “I am filing this formal complaint against Sergeant Detective Nancy Celluci to Boston, because she has conspired with Officer Khalil Mafhoum to weaponize the court system against a civilian whistleblower. She utilized her professional influence to facilitate court shopping...” indicating that it was improper to come before your local bench.

UNSWORTH: There’s allegations regarding “enabling retaliation, protected activity, conspiracy to circumvent prior judicial rulings, strategic litigation warfare.”

JUDGE: So the writer is alleging that this other individual employed by the Boston Police Department Is acting...

UNSWORTH: And that particular email... I have additional emails. March 1st, 2026, 7:34 AM. To many of the same recipients.

UNSWORTH: “Please accept this formal addendum to my previous correspondence regarding 258E filing by Khalil Mafhoum. In my earlier notice, I flagged the pattern of lack of candor regarding the petitioner’s residency and conflicting birth years. I am now providing the court and law enforcement agencies with additional finding that confirms this pattern is a matter of public record...”

UNSWORTH: There’s content here I don’t even understand, Your Honor.

UNSWORTH: Some of it just goes on and on.

UNSWORTH: There’s emails that refer to members of Watertown PD “shadow tracking.”

UNSWORTH: None of us know what that means.

UNSWORTH: I’m not sure I can make sense of all the emails, Your Honor, to be honest with you.

UNSWORTH: But I believe my count is accurate, there’s at least 14 since the order was issued.

UNSWORTH: Naturally, we’ve reached out to the DA’s office looking for advice. How do we... what do we do going forward? We wanted an independent party looking at this.

UNSWORTH: Naturally, we understand we’re being accused of not being objective in this matter. So we went, that’s part of the reason we came before your court.

UNSWORTH: It appeared we had a criminal violation of the harassment order, we went to the Middlesex County District Attorney’s office.

UNSWORTH: They opined that they believe a crime had occurred, to wit the violation of the harassment order, and that elements of the crime occurred in Watertown because of so many of the recipients.

UNSWORTH: The nine City Councilors, the City Manager, they’re done.

UNSWORTH: They’re not interested in handling any more messages.

UNSWORTH: We went to the Waltham District Court, explained all the circumstances...the Waltham District Court issued a complaint.

UNSWORTH: I believe Miss Dubé has been issued a summons for the violation.

UNSWORTH: We didn’t want to have officers go making an arrest on probable cause at a school.

UNSWORTH: She’s a teacher at the school, or at her home. We didn’t want to force a confrontation.

UNSWORTH: We’d like this to stop and move on.

JUDGE: Alright. Counsel, do you have a question?

BRADL: Yes. What’s your name, sir?

UNSWORTH: Unsworth. Captain Unsworth.

BRADL: Good morning, sir.

BRADL: Captain, do you know anything about a telephone call to the Lynn schools alleging that Miss Dubé is suicidal and needs a wellness check in the middle of her day teaching?

UNSWORTH: I did make a phone call

UNSWORTH: I don’t know that any of that content is inaccurate.

BRADL: And what call did you make?

UNSWORTH: I made a call to the Human Resources division of the Lynn Public Schools.

UNSWORTH: When we received the emails, “A. Dubé at Lynn Public Schools,” I wanted to confirm... I’m conducting a criminal investigation, I wanted to confirm where these emails are coming from.

BRADL: What’s the crime?

UNSWORTH: Violation of the harassment order.

BRADL: How so?

BRADL: What’s the act that is a violation of the order?

UNSWORTH: Look, anyone of us would feel harassed.

BRADL: No, no, no, no, no. What’s the act that is a violation of the order?

JUDGE: Counsel, let him—let me answer the question, Judge.

UNSWORTH: Emails sent to the City Manager, the nine City Councilors... the recipients list goes on and on, Secretary of State, Homeland Security, the ACLU

UNSWORTH: Alleging again that he married five times for profit.

UNSWORTH: If that’s the case, he failed miserably, he’s working midnight shifts at Watertown PD.

BRADL:: Okay. He was fired from the State Police for lack of candor and for trying to pay off someone that he hit in a State Police cruiser and then didn’t report the crash to the State Police in violation of policy. Correct?

UNSWORTH: I don’t know... I don’t know all the details are accurate.

BRADL: Okay, what part of it do you know that’s accurate?

UNSWORTH: I know that our background investigators conducted a thorough

background investigation. We spoke with the State Police, of course.

BRADL: That’s not what I asked.

JUDGE: I have enough on this. Okay. Thank you.

BRADLE: Um, so you said to the court that she committed a violation of the order.

BRADL: What’s the violation of the order?

UNSWORTH: If you look at the order specifically, it indicates that if criminal harassment occurs after the order is issued, that’s a violation of the order.

BRADL: Okay. And so you take it that she’s emailing third parties who are government

officials,

BRADL: She’s petitioning the government, and

BRADL: You as a Lieutenant in the police department think that’s criminal harassment?

UNSWORTH: Actually, we went to the DA’s office first.

BRADL: So I’m not really clear here. This is a private order.

BRADL: So you’re here advocating for him, you’re going to the District Attorney’s office advocating for him.

BRADL: Then you caused to file a complaint in the Waltham court on his behalf?

UNSWORTH: I know the prosecutors... the Watertown PD prosecutors...

BRADL: Well who signed the application?

UNSWORTH: I believe it was Sergeant Ryan.

BRADL: Okay.

BRADL: So your position is that emails petitioning the government about someone and their past, and whether they should be hired or not, is criminal harassment?

UNSWORTH: Uh, that’s a dramatic oversimplification.

BRADL: You know what a legal criminal threat is, correct?

BRADL: Are there any threats in any of the emails that you’re mentioning here?

UNSWORTH: Um, not threats to his physical well-being.

BRADL: Well, isn’t that what a legal threat is?

UNSWORTH: Uh, no, I mean there’s other ways of threatening folks, their livelihood, their ability to support their family.

BRADL: Right, and you can threaten to sue someone.

BRADL: You can threaten to report them to their boss.

BRADL: You can do all sorts of things that aren’t crimes, right?

BRADL: That’s really the nature of what you’re advocating for this gentleman, isn’t it?

BRADL: That he’s afraid he’s gonna get in trouble.

BRADL: He’s afraid he’s gonna get sued.

BRADL: Or he’s afraid he’s going to get embarrassed, right?

BRADL: And that’s pretty speculative isn’t it, because it’s never happened, has it?

UNSWORTH: Um, that’s not also clear.

BRADL: I mean, we can worry that she’s going to drive a Sherman tank through his

house.

BRADL: Do we have any information that that’s going to happen?

JUDGE: Do you have any further questions?

BRADL: No further questions.

JUDGE: Thank you very much, Captain. You can step down.

JUDGE: Anything else, Mr. Mafhoum?

JUDGE: Uh, on behalf of Ms. Dubé, is there any evidence you’d like the court to hear or see?

BRADL: Could I be heard, Judge, at this point...

BRADL: Before any further testimony is taken, on the notion that they failed to state a valid claim.

JUDGE: Okay.

BRADL: Thank you, Your Honor.

BRADL: So Judge, everything they’ve said is pretty much an admission to violating the anti-SLAPP statute, which is for the record 231 § 59H, where you would try to suppress someone’s rights to petition the government.

BRADL: She hasn’t contacted him;

BRADL: His own admission is since 2022 she hasn’t contacted him.

BRADL: So here she’s petitioning the government.

BRADL: It’s literally in the First Amendment that she can petition the government.

BRADL: It might not be something that you would do or I would do, but the question is whether it’s protected, and it’s 100% protected activity.

JUDGE: Is she petitioning the government because of government policy or a government proposal, or is she petitioning the government because those government agents or authorities are his employer?

BRADL: So she’s petitioning the government. What her real intent is is not really part of the equation,

Your Honor. It’s: can she do it?

BRADL: She can petition the government under the First Amendment.

BRADL: Number two, we have to look at the framework of the 258E standards.

BRADL: The issue is under 258E and *O’Brien v. Borowski*, which I’m sure the court’s familiar with,

BRADL: It has to be threats or fighting words. And here there are no threats.

BRADL: It says right in *O’Brien v. Borowski* that it’s not like, “Oh, she’s threatening to sue me, she’s threatening to get me in trouble with my boss.”

BRADL: It’s a true criminal threat. It’s literally the legal definition of threat, and she’s threatening nothing that is actionable under 258E.

BRADL: It has to be either a true threat or fighting words, which fighting words isn’t really applicable here.

BRADL: She has never contacted him.

BRADL: She knows from his past that he’s on the POST commission,

BRADL: She knows a bunch of other things that I’m not going to throw out there to smear him,

BRADL: But regardless of what it is, she’s acting on it to government officials.

BRADL: And that is completely protected activity, Your Honor. The idea that they can file this to suppress that is completely wrong, an absolute violation of the anti-SLAPP statute, and it runs completely afoul of *O’Brien v. Borowski*.

BRADL: I can see how the court in an ex-parte fashion, with all the bells and whistles that you heard, would issue something.

BRADL: You know, “the attack, the verbal assault, weaponizing”...

BRADL: It’s just not anywhere near any of these types of activities.

BRADL: There’s not even one of them, and of course, they need three of them.

BRADL: If the gentleman feels that my client is lying about him, he has the ability to sue in civil court. He has the ability to say that she’s slandering him and lying about him.

BRADL: It’s not threats, it’s not fighting words, and I ask you to deny the request for the order, Your Honor.

MAFHOUM: Your Honor, I would like to say something briefly. I just have my wife

here to testify...

JUDGE: No.

JUDGE: I’m all set.

JUDGE: Thank you anyways.

JUDGE: So here’s what the court’s gonna do. I’m gonna take the matter under advisement, which means I have to extend the order for a couple days.

JUDGE: Uh, I want to review the very fine legal issues that have been raised.

BRADL: Could I suggest maybe a Zoom appearance, Your Honor?

JUDGE: That’s fine.

BRADL: Thank you. And Judge, just another thing I should say is that my client only got pages one and two of the restraining order when it was served at her house, and if I could just make sure we have the third one.

JUDGE: Alright, so the court’s gonna extend the order for one week.

JUDGE: The court will review those issues and I’ll have a decision, and we’ll have a further hearing.

BRADL: Actually, I’m going to have to make it the 18th, which is Wednesday.

JUDGE: Uh, and you both can appear on Zoom, alright, on that day.

BRADL: Could I just check my date, Your Honor, if I may?

BRADL: Thank you. Judge, I have an arraignment in Haverhill at 9:00, but could we maybe do an 11:00 Zoom or anything after that at some point a little bit later in the morning? Or I can go on at 9:00 and push that, if that’s easier. I’ll be here at 9:00 on Zoom.

JUDGE: Alright, thank you.

JUDGE: Alright, Mr. Mafhoum, as I said, the order has been extended until next Wednesday, the 18th of March.Um, it will be heard again at 9:00 AM on that day. You can appear virtually.

JUDGE: You certainly can appear in court if you’d like, um, but you can appear via

Zoom on that date. You can get the links from the clerk’s office itself. All the same conditions apply,

ma’am. Uh, we’ll see you both back next Wednesday. Thank you both very much.

BRADL: Thank you, Madam Clerk. Thank you, Your Honor.

CLERK: Your order has been extended until next Wednesday, March 18th, 2026. Documents should

show these parties can jump on Zoom via that date. This will go before Judge Garland.

CLERK: Miss Dubé, you can step up to the seat in the courtroom, get a copy from the court officer,

and you can go to the clerk’s office to get as many copies as you need, okay.

BRADL: Alright, thank you.