b50130 rpf corruption motion w exhibit 1 and all atts.pdf

8/9/2019 b50130 RPF Corruption Motion w Exhibit 1 and all atts.pdf

1/319


2/319


3/319

Attachment 145, Page 1 of 1


4/319

EXHIBIT 1


5/319

Motion for Investigation of Judge Baldwin’s CorruptionWith Plea to Jurisdiction

Page 1 of 147

IN THE SUPERIOR COURT OF COWETA COUNTY

STATE OF GEORGIA

John Harold Murphy, Plaintiffvs. Civil Action No. 12V-413

Nancy Michelle Murphy, Defendant

The Fondling and Sexual Misconduct Accusation against MichelleMurphy was Fabricated and used Fraudulently in the Courts

Part 1 of Motion for an Investigation, Public Disclosure and

Termination of the Corruption of Judge A. Quillian Baldwin, Jr.

and those participating in and initiating his corruption, by financing, andotherwise providing incentive to those persons and entities engaging in

fraud, perjury, false statements, false swearing and other conduct inviolation of the LAW*


6/319


Page 2 of 147

Pictured Left to right; Jack Murphy, age 16; John Harold Murphy, the father; Renee L. Haugerud,

the stepmother and the lead negotiator; Michelle Murphy, the mother; and Thomas Murphy, age

14 (or, “family”) Photo taken in Utah on Jan. 1, 2015. They met to work this out fairly!

This Motion includes a request for the immediate disqualification / suspension of

Judge Baldwin, until he is provided his protections under the LAW* that

accompany the more appropriate, permanent removal of his judicial authority.

This case is about John Harold Murphy and Renee L. Haugerud attempting to take

Jack Murphy, age 16 and Thomas Murphy age 14 from the mother who raised these

children since they were toddlers without the physical presence of John Harold

Murphy. There was and is no legal basis for the taking of the children from their

mother, so the Glover & Davis lawyers, with the assistance of others, fabricated the

most despicable of all reasons, i.e., one of the children had been fondled.

1. Had Judge Baldwin followed the LAW* the children would have never been

subjected to the consequences of the May 27, 2014 illegal arrest and other

despicable conduct, as the “Transporters” and the children would never been

subjected to incarceration that was approved by Judge Baldwin, after the failed

parenting of John Harold Murphy, Renee L. Haugerud, the guardian ad litem,

Elizabeth “Lisa” F. Harwell and their experts.

1.1 This case was driven into its current posture by the corruption of Judge

Baldwin that was motivated by financial and political influence rather than the

LAW*. No family should be subjected to the type of mistreatment to which Judge

Baldwin’s judicial corruption subjected Michelle Murphy, Jack Murphy and

Thomas Murphy.


7/319


Page 3 of 147

1.1.1 After Michelle Murphy informed John Harold Murphy that she would not

yield to his request for her and the children to move to Tennessee to live near

Renee Haugerud’s home on Lookout Mountain, they began to force Michelle

Murphy to surrender custody of the children, as they had threatened.

1.1.1.1 The efforts of John Harold Murphy and Renee Haugerud to obtain

custody of Jack and Thomas were in two very different arenas. They and their

cadre of lawyers have a unified tactic, i.e., to financially deplete the resources

of Michelle Murphy to cause her submission and to benefit from the corruption

of Judge Baldwin. There were contempts adjudicated by Judge A. Quillian

Baldwin, Jr., accompanied by his not allowing Michelle Murphy to present

evidence.

1.1.1.2 One vital aspect of Judge Baldwin’s corruption included his Order

that allowed the removal of Jack and Thomas from the jurisdiction of the court

to any place in the world. The draconian nature of that Order was combined

with an Order that Michelle Murphy could not have any contact with the

children.

1.1.1.3 John Harold Murphy and Renee L. Haugerud began their financial

assault upon Michelle Murphy’s family of Jack and Thomas with the cadre of

lawyers financed with funds derived from Renee L. Haugerud, that were paid

to Taylor Drake of Glover & Davis, and a cadre of lawyers with financial and

political associations with Judge Baldwin. These payments to persons to

assist John Harold Murphy in breaching the 2006 Divorce Decree Settlement

Contract expanded to Kilpatrick Townsend & Stockton LLP, another law firm,

to numerous “expert witnesses,” to investigators and a public relations expert,

Patrick Crosby, who attempted to deceptively distort information to the media.


8/319


9/319


Page 5 of 147

Included here is a Plea to Judge Baldwin’s Personal Jurisdiction while Seeking his

Disqualification and Other Relief that is Necessary for Michelle Murphy to have

equal access to Jack Murphy and Thomas Murphy immediately.

Before this Motion was served, Judge Baldwin and counselfor John Harold Murphy were Provided the following

Documents in hope of immediately providing Michelle

Murphy her contractual rights that were established in the

2006 Divorce Decree. This would provide Murphy immediate access to her

children and allow John and Michelle to equally decide the best interest of the

children without the money grabbers for Renee’s pocketbook. Judge Baldwin and

Elizabeth “Lisa” Harwell should relinquish their control to John and Michelle. This

motion is supported by the recently provided documents.

1. The Information from the Executive Director of Elevations that

Michelle Murphy should have access to Jack and Thomas.

2. The Accusation of Fondling was Fabricated

3. Motion requesting Access to Jack & Thomas for Response to Motion

for Summary Judgment.

4. The following Affidavit from Joyanna Silberg, Ph D.

I, Joyanna L. Silberg, being duly sworn attest to the

following opinions.

If

called upon as a witness, I am competent to testify to the

information and opinion contained herein.


10/319


Page 6 of 147

I am a clinical psychologist licensed by the State of Maryland,

and have received temporary licenses to practice in North Carolina,

Ohio, New Jersey, California, and South Dakota. I have 30 years of

experience in trauma, therapy with maltreated children, domestic

violence, sexual abuse, children of divorce, high conflict divorce

scenarios, psychological testing, forensic evaluation, and severe

psychiatric disturbance in children. I have trained Maryland, New York,

Virginia, and California court personnel on how to deal with situations

when allegations of abuse arise in family court, and I have presented

workshops around the world in these issues. I have trained Guardians

ad litem in Maryland through the Maryland Volunteer Lawyer's

Association on child abuse and domestic violence. I have served as an

expert witness in multiple Maryland Counties, and around the country

on issues related to the mental health of children, and have been court-

ordered to treat and evaluate children who are caught in custody

disputes in Anne Arundel County, Baltimore County, Baltimore City,

Harford County, and Charles County. I have served on National Think

Tanks regarding these issues. I am also an international expert on child

therapy and dissociative disorders in children and sexual abuse and have

edited two books, The Dissociative Child, and Misinformation on Child

Sexual Abuse and Adult Survivors. My book The Child Survivor came

out in 2013. I am internationally recognized as an expert on these issues

and have been invited to speak in Norway, Finland, Sweden, Germany,

New Zealand, Great Britain, and The Netherlands. A summary of my


11/319


Page 7 of 147

professional qualifications is accurately set forth in my curriculum vitae

attached and incorporated herein.

I have reviewed the following documents: Affidavit of Michelle

Murphy, Affidavit of Jack Murphy, affidavit of Thomas Murphy,

Affidavit of Jan Franks, Affidavit of Clarence Massie, Materials

provided by H. Elizabeth King related to Custody Evaluations, transcript

of May 27' 2014 Hearing, Copy of letter to John and Renee from Jack

Murphy, July 31 Emergency Motion for Relief, and The Motion for

Summary Judgment and Response to Motion for Summary Judgment.

On January 12, 2015 I assessed Michelle Murphy in my office for four hours. During this time, I evaluated her capacity for parenting by

interviewing her about key dimensions of parenting including discipline,

nutrition, academic support, individualized attention to the child's needs,

basic values, and knowledge of the individual strength and weaknesses

of each of her children. It was clear from my assessment that her parenting

style and parenting knowledge is excellent and that she uses a direct

educational approach to teaching children proper behavior, and she is

deeply committed to their progress and strengths. She discussed the

allegation of sexual abuse that had been made against her, and she stated

that both boys have denied it and that in her last meeting with her ex-

husband and his wife both of them acknowledged that they knew this was

not true. While the source of this accusation is unclear, it is clear that this

is not a relevant concern at this point in time.

During this interview, she also discussed with me the current status

of the children's placement at a program entitled Elevations. Based on


12/319


Page 8 of 147

the children's report to her, she supports the children's placement in this

program and believes that they will succeed even better if she can

participate in this treatment. She affirmed for me that the director, Judith

Jacques, stated to her that she agreed that mother's involvement in the

treatment would be of great assistance to the children. Although I

attempted to confirm that for myself, I did not receive any calls back or

return messages from Judith Jacques. Nonetheless, as a professional who

works in both an inpatient and residential program I am very aware how

important both parents roles are in participating in the therapy so that

gains made in treatment can be sustained.

I assume the reason I did not hear back from Ms. Jacques is that Michelle

Murphy was not able to supply the legal consent for her to speak with

me and so she was not allowed from a legal perspective to verify this

viewpoint that Ms. Murphy should be involved in treatment. Should the

court question whether this approach is recommended by the center I

suggest the court inquire directly from Ms. Jacques as to her

recommendations in this regard.

It is my professional opinion to a high degree of psychological

certainty that their mother's involvement in their treatment will

facilitate these boys ' r ecovery and make discharge planning much

easier . Without the center even observing how she interacts with her

children, they will be unable to provide confident recommendations

regarding the mother’s involvement post discharge. Clearly the

intensive therapy and assessment that the boys have now received at


13/319


Page 9 of 147

Elevations obviates any need for the previous assessments that the

court had ordered.

It is clearly in the best interest of the children to move in the

direction of a more normalized family life with access to all of the parents

that love them.

Joyanna Silberg, Ph. D.

Disclosure of Reports of Psychologist Related to John and Renee

before the May 27, 2014 Proceeding.

The psychologist’s report about the parenting skills of John Harold Murphy and

Renee L. Haugerud provided to Judge A. Quillian Baldwin, Jr. should be included

in the record in order that two matters may be reviewed. First, the report will support

or repudiate the appropriateness of the transfer of custody temporarily by Judge

Baldwin and second, the reliability of the opinions of the psychologist, who was

selected by Elizabeth “Lisa” F. Harwell.

Unconscionable Restriction upon Michelle Murphy’s Access to her Children

1.2 It is unconscionable that the stepmother, Renee L. Haugerud, has access to the

children that Michelle Murphy does not have when it is the stepmother’s financial

resources that have and are funding substantial portions of the corruption that

resulted in Jack and Thomas, at the behest of John Harold Murphy and the Glover

& Davis lawyers, being snatched away from Michelle Murphy in a Gestapo type of

proceeding on May 27, 2014.

1.2.1 The conduct of Judge Baldwin at the May 27, 2014 hearing that was

retaliatory conduct resulting from counsel’s exposure of the violations of the


14/319


Page 10 of 147

protections provided to Michelle Murphy and her counsel by the Code of Judicial

Conduct, the Uniform Superior Court Rules, Constitutional provisions of the

United States and State of Georgia equivalent, First Amendment, Equal

Protection, Due Process protections, statutes, decisional law, Georgia Code of

Professional Conduct (or, collectively or separately, “LAW*”).

The Absence of an Enforceable Case Management Rule Promotes Corruption

1.2.2 The absence of the protections afforded Michelle Murphy and other

similarly situated persons of an unenforced case management plan, Uniform

Superior Court Rule 3.1 and the Recusal mandates of Rule 25 are the systematic

violation of the LAW* that have historically provided the politically associatedlawyers the option to judge-shop. Judicial oversight of the rights of children has

an extremely low priority in the State of Georgia that sinks below the line of

human decency when administered by Judge Baldwin.

1.2.3 The violations of the protections of LAW* inflicted upon Michelle

Murphy were pursued by Taylor Drake, the Glover & Davis lawyer, in order to

select Judge A. Quillian Baldwin, Jr., to whom the Glover & Davis P.A. law firm

members have financially contributed directly, and of more importance, bundled

money and political benefits for years.

1.2.4 The selection of Judge Baldwin in this case was to provide the Glover &

Davis lawyers a return on their financial and political investment in the judicial

authority of Judge Baldwin that these lawyers have cultivated over the years.

1.2.5 Enforcement of a case management plan is as vital to the LAW* as having

a representative cross-section of the community on the jury. In this modification

of custody case, Judge Baldwin serves as both the jury and the judge. The opinion


15/319


Page 11 of 147

of a judge in this type of case on appeal is only reversible under the “abuse of

discretion” standard.

Michelle Murphy Could Not Afford a Lawyer who Participates in Judge

Baldwin’s Judicial Corruption.

1.2.6 For these reasons Judge Baldwin could not remove himself, or provide a

hearing on his disqualification that would have exposed his disqualification.

1.2.7 Michelle Murphy could not afford a politically embedded lawyer to

compete with the approximate million dollars that has been spent on behalf of

John Harold Murphy from sources originating from Renee L. Haugerud.

1.2.8 Michelle Murphy was required to accept representation from lawyerswho were such political outsiders that they were illegally convicted by Judge

Baldwin of indirect criminal contempt and Michelle Murphy was adjudicated to

be in contempt for seeking protections provided by LAW*.

1.2.8.1 Michelle Murphy is currently ordered by Judge Baldwin to be held

in the Coweta County Jail until she signs the custody evaluator, Nancy

McGarrah’s contract granting this custody evaluator full immunity from

liability from any civil action filed by Michelle Murphy against her.

1.2.8.2 Nancy McGarrah is the custody evaluator who stated falsely,

according to John Harold Murphy, that John Harold Murphy told her that one

of the children stated that one of the children had been fondled.

1.2.8.3 The contempt Order against Michelle Murphy has been affirmed

with an opinion of Court of Appeals Judge Christopher McFadden serving

with the panel of Judge Boggs and Presiding Judge Doyle. A petition for writ


16/319


Page 12 of 147

of certiorari has been filed with the Supreme Court of Georgia. A motion to

disqualify this Court of Appeals panel was denied.

1.2.9 The ability of Judge Baldwin to obtain hefty financial and political

support would diminish substantially if he refused to allow himself to be judge-

shopped. Currently he is near the top of his financial and political funders’

shopping list. The word on the street is that Judge Baldwin delivers even when

he is appointed as a surrogate for another type of political necessity, as appointing

the judge to preside in the Brian Nichols case.

1.2.10 Judge Baldwin is the Chief Judge of the Coweta Judicial Circuit; he

should not attempt at the same time to be the Political Chief and surrogate to

others attempting to carry out their political agenda.

1.2.11. It is the systematic attacks upon such aspects of the political structure

of the judicial misconduct that does not provide protection to litigants without

money that should be provided to them by LAW* that offended Judge Baldwin

to the extent that he engaged in overt, corrupt tactics affecting Michelle Murphy.

1.2.11.1 In the view of Judge Baldwin, as demonstrated by his conduct,

counsel for Michelle Murphy were supposed to succumb to his

administration of a system that did not provide Michelle Murphy the

protection of LAW*


17/319


Page 13 of 147

1.2.11.2 On the street, they call it, “No Money; No Justice.” Often, on

appeal, it is called, “judicial discretion;” here, we identify the financial and

political decision making of Judge Baldwin and its numerous facets simply

as, “judicial corruption.”

Michelle Murphy Must Have State Empowered Investigative Assistance

1.3 At this stage, Michelle Murphy requires an investigator empowered and

compensated by the State of Georgia to expose immediately the corruption that

resulted from such despicable judicial conduct that even some of the participants

with Judge Baldwin are ashamed.

1.3.1 Judge Baldwin has substantial assistance in sustaining his corruption.

1.3.1.1 It has been impossible for Michelle Murphy’s counsel to preserve a

record in this case that exposes the corruption, as the basic modus operandi of

Judge Baldwin’s protective shield is very simple; he does not allow Michelle

Murphy to produce evidence and Judge Baldwin requires his approval before

any motion can be filed by Michelle Murphy’s counsel. Judge Baldwin also

obtains assistance from others in secreting his misconduct and the misconductof those who participate in his corruption.

Protectors of Judge Baldwin’s Corruption

1.3.1.2 Examples of protectors of Judge Baldwin’s judicial corruption was

exposed around the events of the “Blame Yourself! Blame Yourself! Blame

Yourself!” May 27, 2014 proceeding.

1.3.1.3 It was necessary for Judge Baldwin to prevent Michelle Murphy

from presenting even her direct examination before he orchestrated the

May 27, 2014 judicially directed, snatch and grab of Jack Murphy and Thomas


18/319


Page 14 of 147

Murphy that he perfected with Deputy Sheriffs, whom he prearranged to be

present in the courtroom.

1.3.1.4 Judge Baldwin performed his take-down stunt before the full array

of Glower & Davis lawyers, the Kilpatrick Townsend & Stockton LLP lawyers

and the cadre of Kilpatrick Townsend & Stockton LLP gawkers who came

from Atlanta to Newnan just to observe the take-down. The expression on the

face of Judge Baldwin as he sought an approving view from these lawyers and

their supporting gawkers was that of a professional, Saturday night, small town

wrestler as the wrestler exchanged looks with the ring-side revelers seeking

approval and looks from the wrestler, starting with the suffering of his

opponent lying unconscious on the mat, bleeding and maybe praying that there

would not be another knee-drop to his back in response to the approval from

the ring-side revelers.

1.3.1.5 After the May 27, 2014 temper tantrum, counsel for Michelle

Murphy requested that the court reporter allow counsel to purchase the audio

recording of the proceeding. Nan Freeman, the court reporter, refused by

stating that the audio recording was her work product.

1.3.1.6 After Michelle Murphy filed a plea for a change of heart by Judge

Baldwin, it was then necessary for counsel to file a freedom of information

request to obtain the four “Blame Yourself!” omitted pages from the transcript

that Nan Freeman had sworn was complete when she filed the transcript, even

though the critical pages were not included.

1.3.1.7 It is understandable that Nan Freeman wished to protect Judge

Baldwin; it is not understandable that she would provide an oath that she had


19/319


Page 15 of 147

provided a complete transcript when she omitted the highly relevant four pages

that punctuated the conduct of Judge Baldwin that was against the LAW*

1.3.1.8 After a threat by counsel for Michelle Murphy to bring an action to

obtain the audio recording of the proceeding, Judge Baldwin e-mailed counsel

for Michelle Murphy and asked that Nan Freeman not be sued, as she did not

have the money to afford the litigation. There was a motion to disqualify Judge

Baldwin based, in part, upon that request to protect Nan Freeman.

1.3.1.9 This request by Judge Baldwin for immunity for Nan Freeman was

both conduct that is against the LAW* and conduct that is personally insulting

to counsel for the mother of Jack and Thomas.

1.3.1.10 Judge Baldwin just did not get that it was corruption that counsel

for Michelle Murphy was resisting and not an opportunity to participate in the

corruption.

1.2.1.11 Counsel did file the necessary action against Nan Freeman and

the Board of Court Reporting that resulted in obtaining all of Nan Freeman’s

audio recordings.

1.3.1.12 The deposition of Nan Freeman was taken on November 22, 2014

and preserved with a video and transcript of the deposition. Nan Freeman,

during the deposition, confessed to illegally charging for her transcripts. The

transcript, with exhibits, is Attachment 154.

1.3.1.13 The District Attorney of the Coweta Judicial Circuit failed to

return phone calls relating to bringing an action against Nan Freeman to

recover the illegally taken funds that Judge Baldwin had approved, without

reading the illegal vouchers for Nan Freeman to receive payment from the

counties in the Coweta Judicial Circuit.


20/319


Page 16 of 147

1.3.1.14 If counsel for Michelle Murphy had yielded to the request of

Judge Baldwin, the illegal conduct of Nan Freeman would not have been

disclosed.

1.3.1.15 Counsel for Michelle Murphy, at that stage of correcting the Nan

Freeman illegal conduct, then attempted to talk with an employee of the Board

of Court Reporters, who had, in the past, provided helpful information to

counsel. That employee of the State of Georgia did not return counsel’s calls.

After several unsuccessful attempts, Cynthia Clanton, an employee of the State

of Georgia’s Administrative Office of the Courts, returned counsel for

Michelle Murphy’s call that had been left for a person who is employed by the

State of Georgia to administer matters relating to court reporters.

1.3.1.16 Counsel for Michelle Murphy had experience dealing with

Cynthia Clanton of the Administrative Office of the Courts during the time

that counsel was marshalling information in another case involving then Chief

Superior Court Judge Amanda Williams of the Brunswick Judicial Circuit.

During the Williams case, Cynthia Clanton prohibited Millard Farmer from

talking with the State of Georgia employed, Director of the Georgia

Commission on Dispute Resolution about some of the money that the Clerk of

Court in Glynn County collected and did not return to litigants who, under an

Order of Judge Williams, were illegally required to pay an additional filing

fee.

1.3.1.17 On the recent occasion involving Nan Freeman and Judge Baldwin,

Cynthia Clanton refused to allow Millard Farmer to talk with the employee of

the Board of Court Reporting without first submitting questions to her. This

conduct was perceived by Millard Farmer as Cynthia Clanton’s effort to assist


21/319


Page 17 of 147

further exposure of the illegal conduct of Nan Freeman and thereby Judge

Baldwin.

1.3.1.18 This information is included in this motion seeking assistance for

investigation of the corruption of Judge Baldwin, as Millard Farmer strongly

suspects that Cynthia Clanton has provided assistance to persons assisting

Judge Baldwin in his corruption, including Nan Freeman and others. It is not

the function of Cynthia Clanton to assist persons compensated by the State of

Georgia in avoiding detection from their illegal conduct.

1.3.1.19 There is a large amount of competent investigative work that is

required by the State of Georgia empowered investigators to determine the

persons who have assisted Judge Baldwin’s law clerk, Melissa Sams, and

others actively participating in Judge Baldwin’s corruption and who

participated by concealing aspects of his ex parte corruption conduct, as Julia

Harris, Judicial Assistant, is believed to have knowledge. Julia Harris was

subpoenaed to testify at the March 17, 2014 proceeding. Michelle Murphy was

not allowed to present her evidence at that March 17, 2014 proceeding. False

statements to the State of Georgia funded investigators will be a criminal act

that will loosen the tongues of these participants, as Nan Freeman’s tongue

was somewhat loosened between the time that she answered, under oath, the

Complaint filed against her and the time of her deposition.

1.3.2 The May 27 “Blame Yourself!” proceeding is only the tip of the Iceberg.

1.3.2.1 The only direct evidence about the hinted fondling and sexual

misconduct were the affidavits of unequivocal denial by Michelle Murphy,

Jack Murphy and Thomas Murphy.


22/319


Page 18 of 147

1.3.2.2 On May 27, 2014, these persons were in the courtroom, awaiting an

opportunity to testify. Judge Baldwin denied Michelle Murphy, Jack Murphy

and Thomas Murphy the right to testify or to present their evidence directly or

from their witnesses.

1.3.2.3 At the May 27, 2014 proceeding and numerous earlier hearings,

Judge Baldwin intentionally denied Michelle Murphy, Jack Murphy and

Thomas Murphy the protections provided to them by LAW*.

1.3.2 .4 Corruption, and not LAW*, dominated the conduct of Judge A.

Quillian Baldwin, Jr. in this case.

1.3.2.5 A substantial part of the funding that motivated the corruption that

dominated the judicial decision making and motivated benefits derived from

corruption in this case, came directly and indirectly from present and future

anticipated funding from the assets of Renee L. Haugerud, her controlled

Galtere, Ltd, and other entities in which Renee L. Haugerud participated

directly and indirectly.

The Lust for the Money Derived from the Financial Interests of Renee L.

Haugerud Prevented Dispute Resolution

1.3.2.6 There are evasion of state and federal tax consequences that are

suspected, involving assets that have supported this litigation and the lifestyle

of John Harold Murphy, Renee L. Haugerud and others that require

sophisticated investigation, as, correct or not, it has been reported that St.

Thomas provides special income tax credits to individuals with children, as

children assist in establishing residency associated with tax exemptions that

otherwise could not be claimed.


23/319


Page 19 of 147

1.3.2.7 The lust of the Glover & Davis lawyers for attorney fees prevented

any fair attempts to resolve the dispute that created this case either before or

at any time during the litigation.

1.3.2.8 Renee L. Haugerud, before the litigation began, told Michelle

Murphy that she should just surrender Jack and Thomas to John Harold

Murphy, as she and John were going to get the children from her.

1.3.2.9 The financial strength of Renee L. Haugerud and the willingness of

John Harold Murphy to make false statements and gain assistance from

Superior Court Judge Louis Jack Kirby presented what the litigation has

resulted in accomplishing – the financial devastation of Michelle Murphy. This

was only possible with the corruption and the absence of the protections of the

LAW* provided to Michelle Murphy.

Judge Baldwin Engaged in Judicially Corrupt Conduct.

1.3.2.10 Judge Baldwin engaged in much of his LAW* violations in order

to protect the interest of those participating in the universe of Judge Baldwin’s

corruption.

1.4 Make no mistake in understanding that Judge Baldwin and the Guardian ad

Litem, Elizabeth “Lisa” F. Harwell maliciously attempted to alienate Jack and

Thomas from Michelle Murphy. Judge Baldwin maliciously violated the LAW*.

Judge Baldwin’s absence of knowledge of the LAW* admittedly contributed to his

reliance upon those participating in and motivating his corruption. Judge Baldwin

attempted to gain status with those whom he used to assist him in furtherance of his

corruption.


24/319


Page 20 of 147

1.4.1 This is to plainly state that the conduct of Judge Baldwin in administering

the LAW* was corrupt. This motion is to provide the background of information

supplied to Judge Baldwin that he failed to fairly adjudicate that supports that an

investigation should be funded by the government to rid the Coweta Judicial

Circuit of the corruption that resulted in the conduct of Judge Baldwin.

1.4.2 Judge Baldwin substituted the protections provided by LAW*to Michelle

Murphy and her counsel to prevent evidence at critical stages of the litigation

with one of his temper tantrums, threats, or broken commitments to allow

evidence at a later time, or other violations of the LAW*.

1.4.3 The allegations of fondling and sexual abuse of the children against

Michelle Murphy were maliciously fabricated, fraudulently included in the

record and presented to Judge Baldwin and the appellate judges in order to

overshadow and thereby justify the corruption of Judge Baldwin and his

participants by upholding the contempt convictions against Michelle

Murphy and her counsel and for other illegal purpose.

1.4.4 Michelle Murphy and her counsel do not know for certain who originated

the fabrication, as there was no direct testimony that it even occurred. Those who

spread the fabricated accusation, having access to its untruthfulness, are known.

1.4.5 The symbol of our system of justice certainly weeps profusely to

represent sorrow for the suffering that Jack Murphy, now age 16, and Thomas

Murphy, now age 14, have endured as the result of the corruption of Judge

Baldwin and his participants.


25/319


Page 21 of 147

1.4.6 We should deeply regret the failure of our justice system to eradicate the

corruption of Judge Baldwin and his participants for failing to provide Michelle

Murphy the protections that the LAW* should have accorded Michelle Murphy,

her counsel, Jack Murphy and Thomas Murphy after the filing of the initial

motion to disqualify Judge Baldwin and Elizabeth “Lisa” F. Harwell, the

guardian ad litem, who illegally took money provided to her in trust, that, as a

part of Judge Baldwin’s corruption, was approved without a requested hearing.

1.4.7 This modification of custody case is not the first time that the Coweta

Judicial Circuit deprived Michelle Murphy of justice.

1.4.8 If Michelle Murphy had not been required to share five different judges

in obtaining her 2006 Divorce Decree, as the consequence of the absence of a

Rule 3.1 case management plan, John Harold Murphy, with false swearing,

would not have been able to secret $180,000 from Michelle Murphy until the day

after the divorce settlement contract was signed. John Harold Murphy would also

have never been able to cheat Michelle Murphy on the child support calculations

that were different than the recorded agreement made to Judge No. 2 of 5. More

about the deprivation that occurred during the 2006 Divorce proceedings later.

The Treatment of Michelle Murphy at the May 27, 2014 Hearing

1.4.9 The conduct of Judge Baldwin in choosing to treat Michelle Murphy as

he did at the May 27, 2014 “Blame Yourself!” proceeding is conduct that was so

evil that it is beyond conduct is only punishable as a violation of the LAW*.

On June 1, 2014, Michelle Murphy explained the May 27, 2014 “Blame

Yourself!” conduct of Judge Baldwin and its foreseeable consequences and those

who were participating in his conduct as follows.


26/319


Page 22 of 147

Personally appeared before the undersigned, an officer duly

authorized by law to administer oaths, Nancy Michelle Murphy, who

after being duly sworn, states as follows.

1. I am the mother of Jack Malachi Murphy (or, “Jack Murphy”),

age 15 and Thomas Emerson Murphy (or, “Thomas Murphy”), age 13.

2. John Harold Murphy brought this action to modify custody

against me after I refused to move to the Chattanooga Tennessee area

with the children. Neither I nor the children wished to move to that

area that the children knew better than I did, as they frequently visited

John Harold Murphy and Renee L. Haugerud there at her home and

they hate the area.

3. The Glover & Davis Complaint for Modification of John Harold

Murphy stated that I was threatening to move to South Carolina.

4. On Sunday after the Tuesday, May 27, 2027 event, John Harold

Murphy and Renee L. Haugerud took my sons, Jack and Thomas,

against their will, with them to St. Thomas, Virgin Islands. Jack and

Thomas were physically pulled from my arms in the courthouse on

Tuesday, May 27, 2014, while I attempted to explain the decision of

Judge Baldwin to both of Jack and Thomas, which Judge Baldwin did

not even announce to me in a rational tone.

5. After Judge Baldwin, with his arm fully extended, pointing his

finger in my face, screamed at me that he was giving temporary

custody of Jack and Thomas to their father and stormed out of the

courtroom, I went to the small room outside the courtroom door where

Jack and Thomas had been waiting to testify at the hearing. Thomas


27/319


Page 23 of 147

was crying, and shaking, saying, “No! No way! We’re not going with

him! Jack was saying, “No way!”

6. Thomas was white knuckling the chair. I leaned down to be with

him. He flung his arms around my neck and said, “I am not going! I

hate him!” Jack came over to us; his face had a look I had never seen,

and he was shaking and very upset. We were all crying. John Murphy

was leaned against the wall, watching, while I was trying to comfort

the boys the best I could.

7. Jack and Thomas chose to come to court to talk to the judge of

their own volition. They were devastated that Judge Baldwin would not

allow their voices to be heard. They wanted to tell Judge Baldwin

personally what was happening to their lives because of the false

statements that their father had made under oath about them and their

mother.

8. The bailiff, with my sons being emotionally distraught, said to

Thomas, “Do you want to go to juvi (juvenile detention) young man,

‘cause I’ll take you there if you don’t let go of your mother.” [that

deputy took on the demeanor of Judge Baldwin] Thomas responded

that he did not care, he’d rather go there than with his father. The

bailiff said, “I will take your mom to jail.”

9. I was disgusted and broken hearted for my sons that John Murphy

would stand there, watching, and allow this terrifying experience

inflicted upon his 13 and 15 year old sons. I told the bailiff that he was

not going to take them to juvi. I asked him where was his compassion,

and to leave them alone. I was ordered to leave the building or they


28/319


Page 24 of 147

would put me in jail. There were three attorneys for John Murphy and

Renee Haugerud standing in the entrance of the room, looking down

on us; two of them were laughing. This upset my sons so much. Thomas

told them to shut up and quit laughing at us. It was the most horrific

and unimaginable experience of my life and I still cannot believe that

Jack and Thomas had to experience it.

10. While all of this was happening, John Murphy just leaned against

the wall, with his hands behind his back and watched, expressionless.

That alone was incomprehensible to me.

11. I was escorted out to my car by another deputy sheriff, who was

very kind. Her eyes were filled with tears as she led me to my car.

12. My sons, Jack and Thomas are so emotionally distraught about

Judge Baldwin taking them from me. They have lived alone with me as

their primary custodial parent, in our home for fifteen years. They are

electronically texting and calling me as much as possible. They have

told me that their father, John Harold Murphy, has threatened to take

away their phones if they continue to text me.

13. Thomas, age 13, is currently physically sick with a sinus infection

and was forced to fly from Chattanooga to Atlanta and then transfer to

another plane to St. Thomas. Thomas needs to be with me so I can

address his illness with his pediatrician in Newnan, who has treated

him for years and knows him very well. Jack and Thomas are both

extremely distraught by being held against their will by their father

and Renee L. Haugerud.


29/319


Page 25 of 147

14. The attached electronic messages are some of the true and

accurate messages that I have received. Each of their texts break my

heart, because I feel the distress of Jack and Thomas. The portion of

these electronic messages that are attached to my Emergency Motion

to the Georgia Supreme Court that is to be filed on Monday, June 2,

2014 are also true and accurate copies of text messages that I have

received. Also attached is a true and accurate copy of an email which

I sent to John Murphy, asking that he take Thomas immediately to a

doctor, as he was very sick. This 1st day of June, 2014.

A sampling of the e-mail exchanges attached to the affidavit of

Michelle Murphy that were presented to Judge Baldwin follow. The

affidavit and other information provide in the motion is relevant to this

motion to support that the corruption of Judge Baldwin resulted while

he had full knowledge of the conduct of the participants in his

corruption that support the malicious nature of the corruption.


30/319


Page 26 of 147

Judge Baldwin is not deserving of a downward departure from the maximum

discipline

1.5 The absence of remorse by Judge Baldwin in not providing a hearing to

determine the consequences of his illegal behavior, by not allowing a hearing to

correct his conduct, is as indicative of the intent of Judge Baldwin’s corruption as

was the May 27, 2014 hearing, the August 13, 2013 hearing and his consistent denial

of the protections of the LAW* to Michelle Murphy and to her counsel.

1.5.1 Michelle Murphy should never have been subjected to the “Blame

Yourself!” pronouncement by Judge Baldwin, even if the pronouncement had

been delivered in a judicial manner instead of in a street fight delivery tone with

the accompanying physical gyrations of Judge Baldwin. Michelle Murphy, nor

any mother, can be blamed for attempting to protect the lives of Jack and Thomas

from Judge Baldwin and his corrupt participants.1.5.1.1 Nan Freeman should be appropriately reminded of her participation

in the corrupt conduct of Judge Baldwin. It was not until the conduct of this


31/319

Motion for Investigation of Judge Baldwin’s Corruption With Plea to Jurisdiction

Page 27 of 147

official court reporter was addressed that she produced the omitted four pages

of a transcript that she had certified to be complete, in which she omitted the

“Blame Yourself! Blame Yourself! Blame Yourself !” pronouncement of Judge

Baldwin at the May 27, 2014 hearing.

1.5.1.2 It was the open records request of Larry King that obtained those

four pages of the transcript.

1.5.1.3 It was only counsel for Michelle Murphy’s resistance to the request

of Judge Baldwin not to bring the action against Nan Freeman that also

produced the evidence now preserved with the complete audio recordings of

the transcripts of Nan Freeman. These audio recordings are available upon

request from Millard Farmer and will be a part of the record in the Superior

Court of Troup County in Michelle Murphy vs. Nan Freeman, et al .

1.5.1.4 The video recording of the deposition of Nan Freeman will also be

available in the Superior Court of Troup County, and, upon request, to the Law

Office of Millard Farmer. The video recordings are an important teaching aid.

The transcript of the deposition is included as Attachment 154.

1.5.1.5 The personal lives of A. Quillian Baldwin, Jr. and those who

participated in alluring Judge Baldwin into such a gestapo type of proceeding

came to a fork in the road of life on that infamous May 27, 2014 day.

The Fork in the Road

1.5.1.6 The fork in the road that Judge Baldwin ultimately took led to two

teams of “Transporters” coming into the bedrooms of Jack and Thomas in the

dark of the morning at 6:00 a.m. on September 28, 2014 and taking them into

custody.


32/319


Page 28 of 147

1.5.1.7 Michelle Murphy, Jack Murphy and Thomas Murphy had no more

opportunity to speak about these children being captured by the “Transporters”

in the dark of the night and taken to Utah and placed in separate confinement

units than Judge Baldwin provided them on May 27, 2014.

1.5.1.8 The “Transporters” Arrived, Unannounced, in the Bedrooms of Jack

Murphy and Thomas Murphy at 6:00 a.m. on September 28, 2014.

1.5.1.8.1 At 6:00 a.m., Jack and Thomas were asleep, in what they believed

and were always told to be their secure bedrooms, at the mansion of Renee L.

Haugerud on Lookout Mountain, TN.

1.5.1.8.2 Very unexpectedly to Jack Murphy, then age 15, two men, unknown

to Jack Murphy, appeared at his bedside to awaken him. The two men announced,

“Brush your teeth, go to the bathroom and put on your clothes.”

1.5.1.8.3 Jack inquired. “Who are you? What are you doing here?”

1.5.1.8.4 Jack received no truthful responses about his pending fate. Jack was

shown no documents.

1.5.1.8.5 Jack’s guardian ad litem, Elizabeth “Lisa” F. Harwell, explained

nothing to Jack, as he was alarmed and dazed by the intrusion of these two men,

who are called “Transporters.”

1.5.1.8.5.1 Certainly, rational people, at this point, wish to know how

this then fifteen (15) year old popular high school student who advanced with

his class in school and tested to be quite normal by a psychologist whom

Michelle Murphy employed to provide information to the Court on

May 27, 2014 that Judge Baldwin would not allow, could have deteriorated

to a mental condition requiring him to be awakened in the dark hours of the


33/319


Page 29 of 147

morning, with no explanation, and removed from what he was told to be a

secure place, by two unknown “Transporters.”

1.5.1.8.4.2 Contemporaneously, with the arousing of Jack Murphy, a man and a

woman approached Thomas Murphy in his bedroom and took him into custody in

much the same unexpected manner in which Jack was approached and taken into

custody.

1.5.1.8.4.2.1 Jack and Thomas were placed into two separate cars with the

separate teams of “Transporters” and taken to the Atlanta Airport.

1.5.1.8.4.2.2 Jack was escorted through the Atlanta Airport separately from

Thomas.

1.5.1.8.4.2.3 One of Jack’s transporters held tightly onto Jack’s clothing as

they passed through the Atlanta Airport. Jack and Thomas were in custody of two

teams that were each composed of two “Transporters” they had never seen

before. They only know that Renee L. Haugerud was in her bedroom when they

were captured and their father was crying when they left.

1.5.1.8.4.2.4 Jack and Thomas, who had never been separated over a few days

at a time since their birth, never saw each other again until approximately five

weeks later.

1.5.1.8.4.2.5 Thomas was placed at Elevations RTC in Syracuse, Utah; Jack

was initially placed in Viewpoint Center, an assessment center in Syracuse, Utah,

before being placed in Elevations RTC.

1.5.1.8.4.2.6 Elevations RTC identifies itself as follows.

What is Elevations RTC? See, http://www.elevationsrtc.com/

When parents are in crisis with a troubled teen, Elevations Residential Treatment Center (RTC) can offer

guidance, support and relief. We help boys and girls from ages of 13-17 overcome challenges stemming


34/319


Page 30 of 147

from mental health problems, emotional disorders, learning disorders, substance abuse, and other underlying

issues. From depression to addiction to bullying, Elevations RTC is a leading treatment center in America,

helping troubled teens regain their self-worth through proven therapeutic methods. Call today at

855.290.9681.

1.5.1.8.4.2.7 Jack and Thomas will later learn that this trauma that they endured

was a part of Judge Baldwin’s retaliation against his mother’s attorney, Millard

Farmer and his mother, for raising issues about this Judge’s violations of the

Code of Judicial Conduct, the Uniform Superior Court Rules and the laws of

Georgia, as counsel for Michelle Murphy sought Due Process from a jurist who

was not handpicked, in violation of the law, without running the risk of being

judged by such fabricated assertions as the falsely asserted fondling accusation

that Michelle Murphy and the children were prepared to defend and expose on

May 27, 2014.

1.5.1.9 This country does not accept the fork in the road that Judge Baldwin

took or takes.

1.5.1.10 High priced lawyers and fancy legal arguments cannot smother or

remove from memory the lessons of history that people learned with far more

sacrifice than the contempt of court convictions.

The High Price for Paid for a State Mandated Case Management Plan

1.5.1.11 Michelle Murphy, Larry King and Millard Farmer paid an extremely

high price to change the failure of the Coweta Judicial Circuit to adhere to the

Uniform Superior Court Rule 3.1 case management requirement; however,

that made a change that is a large step toward ending the judge-shopping

system that initially corrupted Judge Baldwin.

1.5.1.12 The next large step that involves issues in this case is to have the

judges in the Coweta Judicial Circuit and throughout the State learn from the

http://www.elevationsrtc.com/choose-residential-treatment-center-therapeutic-options/http://www.elevationsrtc.com/choose-residential-treatment-center-therapeutic-options/


35/319


36/319


Page 32 of 147

1.5.1.16 On Friday afternoon, July 25, 2014, Taylor Drake sent to counsel

for Michelle Murphy, John Harold Murphy’s threat to breach the Settlement

Agreement that was memorialized before Judge A. Quillian Baldwin to

provide Michelle Murphy child support for Jack and Thomas.

1.5.1.17 John Murphy mandated that Michelle Murphy will not receive

August child support, because Judge Baldwin took the children from her at a

hearing which was so devoid of due process that even the prisoners at

Guantánamo Bay during the last six years have been provided fairer hearings

with less irate judges.

1.5.1.18 Counsel for Michelle Murphy responded to Taylor Drake

with the thought process of Michelle Murphy and those of any rational

person as follows.

The Settlement Agreement incorporated and made the Order of the Court in the 2006

Divorce Decree provides as follows.


37/319


Page 33 of 147

The threat, without any legal authority to breach the agreement, or the letter’s

attempts to shift the obligation to defend John Harold Murphy’s conduct upon

counsel for Michelle Murphy is the typical, we got our hand-selected judge and

millions of dollars to litigate you in ground, Taylor Drake/Glover & Davis John

Harold Murphy/Renee L. Haugerud strategy.

The upcoming of that “we have the judge and the money” strategy was first

identified to counsel for Michelle Murphy when Taylor would not discuss a


38/319


Page 34 of 147

disposition to the dispute of the parties without rushing to the courthouse to select

Judge Baldwin,

It was at that first meeting, over strong protest of counsel for Michelle Murphy,

that Judge Baldwin signed, without reading an order appointing a guardian ad litem

with the power to change temporary custody of the children without approval of the

Court.

Elizabeth “Lisa” F. Harwell, at the insistence of Taylor Drake attempted to

perform this illegal temporary change of custody act. It was necessary for Michelle

Murphy to defy the illegal “order” of Elizabeth “Lisa” F. Harwell and enroll the

children in the public schools of Coweta County in order to resist the illegal conduct

of Elizabeth “Lisa” F. Harwell supported by Taylor Drake on behalf of John Harold

Murphy. The event creating this illegal conduct by the guardian ad litem occurred

because of one of John Harold Murphy/Renee L. Haugerud power plays that

terminated the transportation that they had been providing for the children to attend

a private school in Atlanta after Michelle Murphy refused to move to Chattanooga,

Tennessee that resulted in the Modification of Custody Complaint being filed by

Taylor Drake.

The signing of the appointment of the guardian ad litem order without reading it and

the false statement of Judge Baldwin in defending the motion to disqualify him was

so bad that Stephen E. Hudson on page 14 in his January 22, 2014 Appellees’ brief

for John Harold Murphy in the Court of Appeals made a false assertion about the

conduct of Judge Baldwin not reading the Order before signing it. That false

assertion by Stephen E. Hudson was to support a false statement made by Judge

Baldwin in his Order denying the motion for his disqualification. (V2, p.307) That

denial by Judge Baldwin was yet another Birt, Issacs disqualification of Judge


39/319


Page 35 of 147

Baldwin ground. Conspicuously, the Glover & Davis lawyer who was present when

the Order was signed and who struck through the statement did not sign the brief of

Stephen E. Hudson, (p. 14) yet, he permitted the brief to be filed and go uncorrected.

Tell me Mr. Farmer just what does the following monetary commitment in the

Settlement Agreement memorialized before Judge Baldwin mean?

The questions in rapid sequences became: What do you think, Mr. Farmer? Rent is

due on the children’s and my home. You know; the alimony stops in September, Mr.

Farmer?

Don’t you know, Mr. Farmer; nobody listens to you and that study by that Emory

Law Professor, Joanna Shepherd, about the evil of money influencing judges?

Don’t you know Mr. Farmer that the studies about the authorities disciplining judges

about their demeanor does not apply to Georgia?

Don’t you know Mr. Farmer that you cannot expect equality from a judge who would

not allow evidence on a motion to disqualify a guardian ad litem after being

informed that the guardian ad litem was engaging in OCGA § 16-6-19 Adultery,

taking money held in trust in violation of Uniform Superior Court Rule 24.9 (8) (g)

and trying her personal cases before Coweta Judicial Circuit Judge Louis Jack

Kirby who suggested to John Harold Murphy that he employ Taylor Drake.

Don’t you get it Mr. Farmer, it is not Jack Murphy, age 15 and Thomas Murphy,

age 13 whose best interest that is being adjudicated, It is the benefits that the bank

account can derive to the contributors of those who sell their political influence to

wealthy client, not persons with the status of a hair stylist who was moved from

California to the Coweta Judicial Circuit in order that John Harold Murphy could

do such things a getting away with secreting $180,000 in stock options until the day

after the settlement agreement was memorialized before Judge A. Quillian Baldwin,


40/319


Page 36 of 147

Jr. in open court.

Don’t you understand Mr. Farmer how much that I gave up to get the right to free

my children for John Harold Murphy who was engaging in habitual acts of adultery

throughout New York City, Georgia and California? Mr. Farmer. I have devoted my

time to the getting the children through the stressful false statement of John Harold

Murphy that Renee L. Haugerud finances. I have not taken the time to build my hair

styling business.

Mr. Farmer, you do remember that you told me that I had to save the $5,000

contempt fine money to stay out of jail, if the appeal does not work. You remember

that we had to pay that filing fee in Fulton County to sue Nan Freeman to get the

audio to send to those people. We had to pay $300 for that expert witness for that

May 27, 2014 hearing when Judge Baldwin had the temper tantrum and we not allow

you to put up any witnesses, or for you to question me. He only allow Taylor Drake

to ask me questions that did not present me an opportunity to present my defense,

followed by Judge Baldwin treating me like I was some animal.

Mr. Farmer, you remember that you told me that we had to pay for those records

that Judge Baldwin ordered us to pay, or have that contempt appeal dismissed.

Mr. Farmer, please tell me why I will not be treated like I was treated when Judge

Baldwin made me pay for those records that could not even be considered on that

appeal because the records were for things that occurred after the appeal was filed.

Mr. Farmer, Do you know when we will get a judge who will allow us to present

evidence and not spend the time telling us how fair that he is, when he will never

allow us to present evidence of his bias to another judge?

Please answer me Mr. Farmer! Please answer me Mr. Farmer!

Is this just another chapter in that book that you are calling, No money, No equal


41/319


Page 37 of 147

justice, Mr. Farmer?

Mr. Farmer. I have devoted my time to the getting the children through the stressful

false statement of John Harold Murphy that Renee L. Haugerud finances. I have not

taken the time to build my hair styling business.

Don’t you understand, Mr. Farmer John Harold Murphy is morally corrupt and he

now has the money that Renee L. Haugerud supplies to corrupt others?

Don’t you understand, Mr. Farmer the reason that Judge Baldwin would not even

allow you to ask John Harold Murphy where he lived at that hearing?

Don’t you understand Mr. Farmer that Judge Baldwin has not requested that even

H. Elizabeth King to interview the children in private even once since he had the

temper tantrum and had the Deputy Sheriff take the children, without any

explanation to the children to the SUV Limousine.

Tell me Mr. Farmer, have you ever seen any judge at any time engage in the conduct

that Judge Baldwin permitted and engaged in at the May 27, 2014 hearing?

Tell me Mr. Farmer have you ever observed any judge at any time order a lawyer

arrested as Larry King was arrested on the day that he attempted to file and explain

the reason for his plea to the personal jurisdiction of Judge Baldwin?

.


42/319


Page 38 of 147

1.6 There were attempts to obtain a hearing to present evidence of the

detriment to the lives of Jack and Thomas while they were in St. Thomas,

USVI, but first, we should document the initial appointment by Judge

Baldwin of Melissa Griffis as the initial guardian ad litem, who resigned, and

who, as an act of retaliation against Michelle Murphy for seeking to disqualify

her, provided Judge Baldwin an Order to appoint Elizabeth “Lisa” Harwell as the

guardian ad litem.

After omitting the introductory comments referring to Tinker to Evers to Chance,

the disqualification motion follows.

1.8 The conduct of Kirby to Drake to Baldwin in this case was not

ethical or legal and this is where the Baseball's Sad Lexicon transforms

into Justice’s Sad Lexicon.

1.9 Judge Jack Kirby recommended that his friend and former client,

John Murphy, employ the law firm of Glover & Davis’s Taylor Drake in

this litigation.

1.9.1 Judge Jack Kirby knew both John Murphy and Glover & Davis’s

Taylor Drake extremely well.

1.9.2 Judge Jack Kirby knew that Glover & Davis’s Taylor Drake would know

how to judge shop for a judge with whom they had a good, ongoing earwigging

relationship.

1.9.3 Judge Jack Kirby knew that Glover & Davis had survived a Court of

Appeals test to its judge selection shenanigans, as this law firm had not been

caught in its Mayor & Aldermen of Savannah v. Batson-Cook Co., 2012 Ga.

LEXIS 488 (Ga. May 29, 2012) judge selection shenanigans at that time.

1.9.4 Judge Jack Kirby knew that he was providing sound legal advice to his

friend, John Murphy when he gave him the legal advice to hire Glover & Davis’s

Taylor Drake instead of the other lawyer who had represented John Murphy in


43/319


Page 39 of 147

Nancy Michelle Murphy v. Delia Tedder Crouch, Civil Action No. 08V2137 in

the Superior Court of Coweta County, Georgia.

1.9.5 The law of Georgia prohibits a Superior Court Judge from practicing

law. John Murphy came to Judge Jack Kirby for legal advice that belonged to

the people of the State of Georgia, not to Judge Jack Kirby to exchange for such

social pleasures provided to him by John Murphy with his expensive toys, as his

50 foot Hedge-Fun boat.

1.10 Melissa Griffis, the Guardian ad Litem whom Judge Baldwin

appointed, appears before Judge Jack Kirby on a regular basis

representing her private practice clients who seek discretionary decisions

from Judge Jack Kirby. Melissa Griffis knows that Judge Jack Kirbyrecommended that John Murphy employ Glover & Davis’s Taylor Drake

for this litigation. Kirby to Drake to Baldwin works fine for Melissa

Griffis. This connection is what some people call one of the benefits of

being, nearer, my judge, to thee.

1.11 Melissa Griffis and Glover & Davis’s Taylor Drake were

co-fundraiser organizers for a current candidate for Superior Court

Judge, Emory Palmer.

1.11.1 Judge Baldwin attended the Emory Palmer fundraiser in LaGrange onlya few nights before he appointed Melissa Griffis as Guardian ad Litem.

1.11.2 Members of the law firms of Taylor Drake and Melissa Griffis also have

recently contributed substantially to Judge Baldwin’s reelection committee,

although Judge Baldwin has no opposition.

1.11.3 In the Order of Judge Baldwin denying the disqualification motions of

Michelle Murphy, Judge Baldwin goes to an extreme to make a point about the

contributions to him by Melissa Griffis’ law firm. On pages 3 and 4 of the Order

of Judge Baldwin he states as follows.


44/319


Page 40 of 147

. . . The amount received from Ms. Griffis’ firm was received almost a month

after her appointment.

1.11.4 This raises the question of, just what was Judge Baldwin’s point?

1.11.4.1 The appointment of Ms. Griffis occurred on April 26, 2012; the time

for the qualification to the reelection of Judge Baldwin closed, with him having

no opposition on May 25, 2012.

1.11.4.2 What was Judge Baldwin’s point about Ms. Griffis’ firm making a

contribution almost a month after her appointment? Was Judge Baldwin’s point

that Ms. Griffis’ firm was getting its due to him late?

1.11.4.3 Was Judge Baldwin’s point that Ms. Griffis’ firm was waiting until it

was certain that he would have not opposition before placing its bet?

1.11.4.4 Whatever the point that Judge Baldwin was attempting to make, we all

now know, as the holiday season song goes, Santa Clause is “checking his list to

find out who is naughty or nice.” Please, understand that in-kind fundraising

parties for friends are not adequate; you must get these financial gifts in on time

in order that they will not look so strange and require so much explaining in

Court Orders.

1.11.4.5 In Melissa Griffis’ defense, she might retort to Judge Baldwin, we

wanted to wait to see if you would be disqualified from serving in my bread and

butter guardian ad litem appointment.

1.12 In open court, on the morning when Taylor Drake arranged to have Judge

Baldwin appoint a guardian ad litem, Judge Baldwin, during the case

assignment, first called the calendar and then sent one of the cases that he

selected down the hall to another judge. This type of case assignment does not


45/319


Page 41 of 147

comply with Uniform Superior Court Rule 3.1. This is the ad hoc, unpublished

“case assignment” of the Coweta Judicial Circuit system.

1.13 Judge Baldwin makes a deceptively fraudulent, legally incorrect

statement about USCR 3.1 compliance in his Order refusing to disqualify himself.

This statement is as follows.

1.14 In an oral open records request to the Clerk of Court of the Superior

Court of Coweta County, as authorized by OCGA § 50-18-70 et seq., as amended

by the 2012 House Bill 397, counsel for Michelle Murphy was advised that there

was no case assignment plan by the Judges of the Coweta Judicial Circuit in the

records o f the Clerk of Court the Superior Court of Coweta County, i.e., there

was no document relating to USCR 3.1 compliance for counsel for Michelle

Murphy to view in order that the rule was followed.1.14.1 Based upon the oral information received from the Clerk of Court,

counsel for Michelle Murphy made the following assertion in the motion to

disqualify Judge Baldwin. If Judge Baldwin wished to dispute this factual

representation in the disqualification motions, an assignment of the matter to

another judge for a hearing was his remedy.

8.4 The Superior Court of Coweta County has no documented “Method

of Assignment” plan. emphasis supplied


46/319


Page 42 of 147

8.1 The train of judicial responsibility ran off the tracks when the judges

in the Coweta/Troup segment of the Coweta Judicial Circuit made the

decision to disregard the Uniform Superior Court Rule 3.1 in order that

the judges may select the cases that they wish to address and shuffle to

another judge the cases that they do not want to address.8.2 This Unif. Super. Ct. R. 3.1 violation system is sanctioned by the

domestic relations bar in the Coweta/Troup segment of the Coweta

Judicial Circuit for two primary reasons.

8.2.1 This Unif. Super. Ct. R. 3.1 violation system is sanctioned by the domestic

relations lawyers as they understand that a large majority of the domestic

relations decisions are made based upon the discretion of the judges, and

challenges to judges have a detrimental effect upon the rights of their clients.8.2.2 This Unif. Super. Ct. R. 3.1 violation system is also sanctioned, as these

judges have developed employment opportunities for the core of firms with a

substantial domestic relations practice by appointing some members of these

firms as guardians ad litem and requiring litigants to pay the appointed

guardians ad litem fees based upon their highest level of fees.

* * *

8.4.1 Judge Quillian Baldwin shares the responsibility for failing to adopt a

“Method of Assignment’ plan in the Superior Court of Coweta County.

8.4.2 This illegal conduct by Judge Quillian Baldwin is a legal basis upon

which to disqualify him from picking and choosing the cases that he wishes to

address.

8.4.3 The failure of the Superior Court of Coweta County to adopt a “Method

of Assignment” plan provides no continuity of judicial oversight for domestic

relations cases.


47/319


Page 43 of 147

8.4.4 Due to the failure of the Superior Court of Coweta County to adopt a

“Method of Assignment” plan provides these judges great incentive to appoint a

guardian ad litem to fulfill the role that the judge is elected and sworn to fulfill.

Such conduct adds thousands of dollars into the pockets of lawyers who litigants

are required to pay on the threat of contempt of court.

8.5 In this case, Judge Quillian Baldwin has engaged in each of the evils

that the “Method of Assignment” rule is designed to prevent.

1.14.2 If Judge Baldwin has a documented plan for case assignments approved

by a majority of the judges that is filed in the records of the Clerk of Court of

Coweta, he has the obligation to produce it.

1.14.3 If such a plan is not filed with the Clerk of Court in the records of the

Court, it is not a USCR 3.1 compliant plan and Judge Baldwin should be

sanctioned by the Judicial Qualifications Commission for knowingly making such

a statement to protect his conduct in the motion to disqualify him. Certainly,

Judge Baldwin must have heard about Mayor & Aldermen of Savannah v.

Batson-Cook Co., 2012 Ga. LEXIS 488 (Ga. May 29, 2012).

2. Memorandum of Law 2.1 The removal of Melissa Griffis as Guardian ad Litem does not resolve the

conduct of Kirby to Drake to Baldwin.

2.2 The appointment of Melissa Griffis as Guardian ad Litem is only the symptom

of the judicial corruption that surrounds the Case Assignment issues in the Coweta

Judicial Circuit and the unethical conduct of Judge Baldwin, in this case.

2.2.1 Admittedly, the unethical misconduct of Judge Baldwin has adequate

company in the Coweta Judicial Circuit.


48/319


Page 44 of 147

2.2.2 It was just unfortunate for Judge Baldwin that Judge Jack Kirby selected

the Glover & Davis judge shoppers to call upon Judge Baldwin to pay the Piper

in this matter.

2.2.3 John Murphy’s financial statement indicates that John Murphy makes

and average of $625 month in political contributions. This is a interesting

invitation for those who bundle such funds. This invitation follows.

2.3 John Murphy has no viable cause of action in his Complaint for

Modification of Custody or in the Alternative, Parenting Time.

2.3.1 John Murphy’s only claim is that his spouse is a multi-millionaire and

that he can better financially provide for Thomas and Jack than Michelle Murphy

who must provide for these two children with the money that she receives as child

support, alimony, as a hair stylist and with the gratuitous funds that John Murphy

and his spouse provide.

2.3.2 The problem of the children being provided more financial support does

not require a change of custody, only a change of child support.

2.3.3 There was absolutely no emergency identified or proven in order for

Taylor Drake to obtain the appointment of a guardian ad litem.

2.4 The elimination of Melissa Griffis as Guardian ad Litem does not

address the core problem created by the Kirby to Drake to Baldwin issue.

It is necessary to eliminate Melissa Griffis as the Guardian ad Litem asa step toward addressing the unethical conduct created by the Glover &

Davis judge selection process and thereby Guardian ad Litem selection

process.


49/319


Page 45 of 147

2.5 To the eyes of counsel for Michelle Murphy, Judge Kirby to

Glover & Davis’s Taylor Drake to Judge Baldwin was “fleeter than

birds” and beginning the process of “ruthlessly pricking” in route to

Thomas, Jack and Michelle Murphy’s Chance at justice.

2.6 Whether Tinker to Evers to Chance, or Kirby to Drake to

Baldwin; neither the base runner nor Michelle Murphy, ever had a

Chance and the feigned potential scorekeeper, Melissa Griffis, does not

possess the fortitude to do anything but what is necessary to please Judge

Kirby and Judge Baldwin, who are each attempting to please John

Murphy.

2.7 If Melissa Griffis possessed an ounce of fortitude she would have

taken action for her numerous private clients to correct the USCR 3.1

violations in the Coweta Judicial Circuit and the events would have neveroccurred that led to Mayor & Aldermen of Savannah v. Batson-Cook Co.,

2012 Ga. LEXIS 488 (Ga. May 29, 2012).

2.8 It must be stated clearly, Melissa Griffis has no obligation to

exhibit an ounce of fortitude so long as she chooses not to attempt to serve

in an appointed fiduciary capacity, such as a guardian ad litem, when the

case involves a close friend of a judge, from whom on a regular basis she

seeks discretionary rulings in her private cases. When she is appointed

in these incidences, it is a deficiency in the fortitude of a lawyer torepresent a client involved in such a situation who fails to act, regardless

of the personal friendships of that lawyer.

2.9 Judge Kirby was so anxious to accommodate and please John

Murphy and his, many times over millionaire, spouse that he illegally, in

violation of OCGA §19-3-58, performed a marriage ceremony for the two

without a valid marriage license. See, Deposition of Judge Jack Kirby p.

42 – 48.

2.10 The performance of the illegal marriage ceremony for John

Murphy together with providing John Murphy legal advice about the

selection of counsel relates to the Justice’s Sad Lexicon’s aspect of Kirby

to Drake to Baldwin. There is not a clean hand in the crowd. Each is


50/319


Page 46 of 147

beholding in various degrees and ways to the other, and to the purse

strings of John Murphy’s spouse.

2.11 The reality is that Melissa Griffis was appointed Guardian ad

Litem for the illegal Coweta Judicial Circuit case assignment system.

2.11 Each of the Pleadings in this Litigation are Incorporated and Made a Part of this Motion for the Disqualification of Melissa Griffis.

2.12 It is imperative that this motion be litigated with the full array of

information that led to Justice’s Sad Lexicon’s Kirby to Drake to Baldwin

refrain. The following documents, together with the attachments to the

documents that have been filed with the Clerk of Court in this case are

incorporated and made part of the information in support of this motion.

John Murphy’s Summons

John Murphy’s Complaint for Modification, et al. Answer of Michelle Murphy with Counterclaim and Third Party

Complaint

John Murphy’s Motion for Appointment of Guardian ad Litem

Michelle Murphy’s Response to John’s Motion for Guardian ad Litem

John Murphy’s Motion for Immediate Relief

Michelle Murphy’s Response to Motion for Immediate Relief

Preliminary Domestic Relations Financial Affidavit of John Murphy

John Murphy’s Rule Nisi for April 26, 2012

Notice of Appearance of Millard Farmer and Larry King

Order Appointing Melissa Griffis as Guardian Ad Litem

Motion for Mercy Disqualification of Judge Baldwin

Request of Child Under Age 14 as to Custodial Parent – Jack Murphy

Request of Child Under Age 14 as to Custodial Parent – Thomas Murphy

First Amended Motion to Disqualify Judge Baldwin

Domestic Relations Financial Affidavit of Michelle Murphy

Addendum to First Amended Motion to Disqualify Judge Baldwin

Order Denying Motion to Disqualify Judge Baldwin

3. Melissa Griffis Should be Disqualified as Guardian ad Litem for the minor

children, Jack Murphy and Thomas Murphy.


51/319


Page 47 of 147

3.1 The improper conduct of Judge A. Quillian Baldwin, Jr. in designating Melissa

Griffis as the Guardian ad Litem for the minor children, Jack Murphy and Thomas

Murphy in this case justifiably subjected Melissa Griffis to careful scrutiny by

counsel for Michelle Murphy. Kirby to Drake to Baldwin attempt to add “to

Griffis” to Justice’s Sad Lexicon and counsel for Michelle Murphy detected that

Melissa Griffis was a slow base runner in life’s fortitude test when she evaded

providing information to the court reporter and otherwise evaded full disclosure.

This is not to say that Melissa Griffis is a bad person; she is just not a person with

the fortitude to evade becoming Kirby to Drake to Griffis to Baldwin. 3.2.1 Judge Baldwin’s conduct was extremely unfair to Melissa Griffis, as well

as to the parties in this litigation, as Judge Baldwin created an enormous amount

of otherwise avoidable litigation expenses. If Judge Baldwin had just adhered to

the law established by USCR 3.1, the plague identified in Mayor & Aldermen of

Savannah v. Batson-Cook Co., 2012 Ga. LEXIS 488 (Ga. May 29, 2012) would

not be frequently occurring in the Coweta Judicial Circuit. USCR 3.1 is not a

draconian rule that deprives judges of power; it is a filter for lawyers’ judge

shopping and judges’ litigant shopping.

3.2.2 While it was Judge Baldwin who first placed Melissa Griffis in an unfair

ethical dilemma, it was Melissa Griffis who sealed her fate of being eligible to be

designated as a lawyer acting unethically, who should not be allowed to serve as

the Guardian ad Litem in this case and should be a suspect in future cases.

3.2.2.1 Melissa Griffis, at a minimum, had the ethical obligation to disclose

to counsel for Michelle Murphy that only a few nights before being appointed

Guardian ad Litem, she and Taylor Drake hosted a fundraiser for a candidate


52/319


Page 48 of 147

for a Superior Court Judge that Judge Baldwin and retiring Judge Allen B.

Keeble attended.

3.2.2.2 Counsel for Michelle Murphy knew that Melissa Griffis practiced

before Judge Baldwin on a regular basis and had never challenged the manner

in which Judge Baldwin and other judges in the Coweta Judicial Circuit judge

shop for litigants and/or that the lawyers judge shop for judges. Lawyers

outside the circuit have a difficult time in detecting this type of conduct, which

can be utilized to subject their clients to prejudice. See Mayor & Aldermen of

Savannah v. Batson-Cook Co., 2012 Ga. LEXIS 488 (Ga. May 29, 2012)

3.2.2.3 Melissa Griffis had the ethical obligation to allow counsel for

Michelle Murphy to record the questioning of her after the conduct of

Judge Baldwin in appointing her as Guardian ad Litem and providing that she

would immediately receive $5,000 and $250 per hour for her services.

3.2.2.4 It is relevant that the standing order relating to fees for mediators,

including attorneys who serve in this capacity, in the Coweta Judicial Circuit

provides $150 per hour for the first two hours and $75 per hour for each

additional hour. Nan Newman, an attorney in the same law firm as Melissa

Griffis, with far more years’ experience than Michelle Griffis, is a qualified

mediator. See, Attachment 5, page 5 that, in part, states as follows.


53/319


Page 49 of 147

3.2.2.5 It is also relevant to note that in the Final Divorce Decree that the

Court only awarded Michelle Murphy, a person who at that time had nooutside income, less than a third of the attorney fees that she had to pay her

attorney.

3.2.2.6 A full disclosure of the history of the fees awarded to Melissa Griffis

by the Court in comparison to the fees that she charges her clients is also

relevant, as the Court does not consistently award Melissa Griffis $250 per

hour in her private cases. This is not a plea for a cheaper fee from Melissa

Griffis but this is for its weighing in determining if Judge Baldwin was

attempting to award Melissa Griffis a gift of funds over and above her value

to compensate for the fruits of her sponsoring campaign events attended by

Judges Baldwin and Keeble.

3.2.2.7 The questioning of Melissa Griffis was justified, as Ju