murphy_motion to rescind judicial appointment_with attachments_252 pages

In the Sixth Judicial Administrative District

Involving a case originating in the IN THE SUPERIOR COURT OF COWETA COUNTY

STATE OF GEORGIA

John Harold Murphy Plaintiff Civil Action No. 12V-413

Nancy Michelle Murphy, Defendant

Motion for Administrative Judge Matthew O. Simmons to Rescind the Appointment of Senior Judge William Ison

to Serve as Judge in the Case in the Superior Court of Coweta County of John Harold Murphy vs. Nancy Michelle Murphy, Case No. 2012-V-413

The Order sought to be rescinded is Attachment 1

Nancy Michelle Murphy (or, “Michelle Murphy”) moves the Administrative

Judge for the Sixth Judicial Administrative District, Judge Matthew O.

Simmons, to rescind his Appointment of Senior Judge William Ison to serve in

the Superior Court of Coweta County case of John Harold Murphy vs. Nancy

Michelle Murphy, Civil Action No. 12V-413.

The impeccable judicial reputation of Judge Matthew O. Simmons has been

threatened and abused by the absence of an investigation and full disclosure of

the nature of the nexus of Judge William Ison to the Coweta Judicial Circuit’s

systemic violations of case management and specifically to Chief Judge A.

Quillian Baldwin, Jr.

Judge Ison participated in systemic violations of the rights of persons to a

representative cross-section on juries --- Millard Farmer spent a substantial

portion of his legal career addressing systemic discrimination and illegal

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judicial conduct that resisted providing persons those rights throughout the

State of Georgia and specifically in Clayton County. The Coweta Superior

Court’s violation of the case management mandate was perpetrated with the

same type of illegal conduct which resulted in unconstitutional jury

composition. Judge Matthew O. Simmons has been deceptively caused to act

much as a conduit for the failed responsibilities of our judicial system.

In executing the Appointment Order, the Administrative Judge for the

Sixth Judicial Administrative District, Matthew O. Simmons was unaware

of issues that render the appointment of Judge William Ison both

prejudicial to Michelle Murphy and an unintended violation of the Code

of Judicial Conduct, as the appointment has the extremely detrimental effect

of judicial misconduct instigated by Chief Judge Baldwin.

The essential aspect of the appointment of the judge in this case is that this

is a modification of custody case where the judge serves both as the trier of fact

and law.

This case involves over twenty (20) motions to disqualify Chief Judge A.

Quillian Baldwin, Jr.

Chief Judge Baldwin and each of the judges in the Coweta Judicial Circuit

have recused themselves in this case.

There is a systemic issue that gave rise to disqualification motions that were

necessary to protect the rights of Michelle Murphy and her two children. The

systemic issue is the judge-shopping violations by the judges in the Coweta

Judicial Circuit.

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Judge William Ison was one of the Senior Judges in the State of Georgia

who financially benefitted from the systemic absence of a Uniform

Superior Court Rule 3.1 mandated case management in the Coweta

Judicial Circuit.

Chief Judge Baldwin selected Senior Judge William Ison to serve in the

Coweta Judicial Circuit in order that the other judges in the circuit could

participate in the political benefits of both shopping cases and being judge-

shopped.

Larry King is a lawyer who practiced for many years in the Superior Court

of Clayton County.

Judge Matthew O. Simmons is unknowingly being set up to participate in

the furtherance of the unfairness and failure of the legal obligations of the

Judicial Qualification Commission, the staff of the Sixth Judicial

Administrative District and others presently unknown to counsel for Michelle

Murphy, who failed to present Due Process quality information to Judge

Matthew O. Simmons before borrowing his rope.

The treatment of Judge Matthew O. Simmons brings to mind an incident

that counsel vividly remembers. --- It occurred when a Georgia Assistant

Attorney General, with this scared, then inexperienced, counsel following,

rushed into the chambers of United States District Court for the Northern

District of Georgia Judge Newell Edgefield and the Assistant Attorney General

politely made this request to Judge Edenfield, “Judge, we need this Order

signed immediately, Judge XX is not in and his clerk stated that you could issue

the Order.”

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With a stare that was stronger than a laser beam, Judge Edenfield pulled his

glasses away from the papers that he had read and stated, “You are not going

to borrow my rope to hang this man; I am not Judge XX, I am Judge Newell

Edenfield! Brief the case. Set the case for a hearing and then you may return.”

Judge Matthew O. Simmons should not lend his rope or his reputation to the

conduct that has scarred the lives of Michelle Murphy’s children, our judicial

system and the integrity of others.

The scars left by this corruption will remain long after the retirement of the

adults who have engaged in this mockery of justice.

Judge Matthew O. Simmons executed the Order appointing Senior Judge

William Ison without information that comports with the Due Process

protection of the United States Constitution, the protections of the Uniform

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

(or, “LAW*”).

Just being a judge is not a qualification for being assigned as the trier of fact

to an ongoing case burdened with the violation of the LAW* and the

consequences inflicted upon the children and this mother. The issue is who is

an appropriate judicial officer to rescue a case rampant with corruption to the

extent that Judge Matthew O. Simmons is being asked to rubber stamp a former

and current participant in violation of the Coweta Judicial Circuit’s systematic

violations of the Uniform Superior Court Rule 3.1 mandates for a case

management plan.

No juror, as Judge Ison would be, could ever be qualified as Judge Ison has

been qualified as the trier of fact in a rubber stamped process.

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Few people understand that John Harold Murphy and his hedge fund

operating spouse have spent over an estimated One Million Dollars with at least

three law firms and over six lawyers in attempting to take these children from

their mother, a hair stylist, who has now exhausted all of her disposable assets.

Our system of justice cannot tolerate such treatment of this mother and her

children.

Judge William Ison is being qualified to become the trier of fact of the

conduct of Chief Judge A. Quillian Baldwin, Jr. and other judges in the Coweta

Judicial Circuit, who have each recused themselves.

See, Attachments 161-163. It was not until the “Corruption Motion” was

tendered that Judge Baldwin and all of the other judge in the Coweta Judicial

Circuit recused themselves. Judge Baldwin would not allow the motion to be

filed. See, Attachment 164.

Judge William Ison has been appointed by Chief Judge A. Quillian

Baldwin, Jr. and financially rewarded to participate in the illegal judge

selection process in the Coweta Judicial Circuit. Judge Ison, as a Senior Judge,

will seek additional appointments in the Coweta Judicial Circuit that could be

curtailed, or terminated if he rules favorably to Michelle Murphy. Judge Ison

has a history of participating in the systematic under-representation of African

American persons on juries and the discrimination of persons on juries in

Clayton County.

Judge Ison also, in a case involving counsel for Michelle Murphy, dismissed

an action without allowing a hearing in a case involving a lawyer illegally

charging for services that is similar to the conduct of Nan Freeman, the court

reporter who is a relevant witness in the case of Michelle Murphy.

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Michelle Murphy has a pending civil action against Nan Freeman that

involves the unethical conduct of Judge Baldwin. Michelle Murphy has also

referred the criminal conduct of Nan Freeman for investigation. That case has

been referred by the Attorney General of Georgia to the District Attorney in

Cobb County, Vic Reynolds, who has assigned an investigator to audit the

charges against Nan Freeman brought by Michelle Murphy. A transcript of Nan

Freeman’s deposition is Attachment 154.

Time is of the essence for the appointment of a qualified judge. --- Judge

William Ison, as a Senior Judge, who has a continuing financial interest in the

systemic violations of the law by Chief Judge Baldwin, from which Judge Ison

has financially benefited. This financial interest of Judge Ison in pleasing the

judges in the Coweta Judicial Circuit, including Chief Judge Baldwin and Judge

Louis Jack Kirby, has not terminated and continues with his appointment.

There is a time sensitive need for the appointment of a judge in the

underlying case who can immediately resolve the issues that result from the

judicial misconduct and violations of the law by Judge Baldwin.

The core issue about the appointment of Judge William Ison is that he

would come to the case with the same disqualifying issues with which Chief

Judge Baldwin exited the case in his eventual recusal.

It took from May 1, 2012, the date of the first of twenty (20) disqualifying

motions until his recusal on February 9, 2015, a week short of two years and

nine months, to obtain his recusal. Even when Judge Baldwin recused himself,

he continued his disqualifying conduct by leaving in place his Order that

prohibited counsel for Michelle Murphy from filing motions, responding to the

perjurious affidavit of John Harold Murphy that he filed on February 11, 2014,

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and other pleadings. All of this occurred while Judge Baldwin left in place his

retaliatory Order that, according to its administration by John Harold Murphy

and Renee L. Haugerud, prohibits Michelle Murphy from contacting her

children, or even talking to them on the telephone.

Neglect in addressing abusive conduct toward children and women by

judges, appellate courts, or an agency such as the Judicial Qualification

Commissions, is the same as the abuse of children which is permitted when left

unaddressed by DFACS. Make no mistake in understanding, there is ample

evidence that John Harold Murphy and Renee L. Haugerud, his spouse, have

abused the children of Michelle Murphy.

There is an audience of good people who will at some time address the

despicable conduct that Michelle Murphy and her children have endured as the

result of the failure of the protections to which this family was entitled.

The children who have been released from Elevations RTC and similar

confinement facilities tell the sad story of such confinement by inept parents.

All of this conduct by John Harold Murphy and his spouse, Renee L.

Haugerud, while John Harold Murphy is under a still effective Order of the

Court that requires the following protections for the children that have been

breached by John Harold Murphy

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Judge Baldwin’s restriction upon Michelle Murphy filing any pleading

without his prior consent has prohibited Michelle Murphy from obtaining

a contempt action against John Harold Murphy to enforce that portion of

the Order of the Court or the child support payments that have not been paid to

her since August of 2013.

Michelle Murphy has been deprived of approximately $21,000 in child

support payments that has consumed her disposable assets and renders it

detrimental to her to begin litigating to remove Senior Judge Ison, who is as

disqualified as was Judge Baldwin when the case began. Each were financially

benefiting from a politicalized absence of a mandated case management plan.

Michelle Murphy has made systematic changes in the mandated Rule 3.1

case management plan and is entitled to compensation for the cost of making

those systematic changes in the Coweta Judicial Circuit. The difficulty now is

administering the case management plan with a corrupt judge.

Now, unknown to Judge Matthew O. Simmons, he was requested to

rubber stamp Senior Judge William Ison becoming the juror and judge of

the conduct of Judge Baldwin, who was more than once, Senior Judge

William Ison’s paymaster and who will again seek compensation from Judge

Baldwin and other judges in the Coweta Judicial Circuit.

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In appointing Senior Judge William Ison to the case, Judge Matthew O.

Simmons was required to make a judicial decision, which certainly appears not

to have occurred, as the appointment appears to be a rubber stamp of an

administrative act that deserved judicial consideration of the task at hand for

this trier of fact.

The modification of custody case began with Judge A. Quillian Baldwin, Jr.,

over strong objection of counsel, after being selected in an illegal judge-

shopping scheme, illegally delegating his judicial authority to determine

temporary custody to a guardian ad litem.

Judge Matthew O. Simmons was asked to lend his rope to a crowd who

metaphorically have gathered for a lynching of the rights of all mothers and

children when the more politically and financially connected litigant invades

the courthouse to obtain a modification of custody of children with the use of

now admitted fraudulently used statement.

The prime protection that the Code of Judicial Conduct provides to both

judges and the public is simply stated in Canon 3.

E. Disqualification. (1) Judges shall disqualify themselves in any proceeding in which their impartiality might reasonably be questioned, including but not limited to instances where: Commentary: Under this rule, judges are subject to disqualification whenever their impartiality might reasonably be questioned, regardless of whether any of the specific rules in Section 3E(1) apply.

This Canon applies to both Senior Judge Ison and Judge Matthew O.

Simmons.

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http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&cad=rja&uact=8&sqi=2&ved=0CCUQFjAB&url=http%3A%2F%2Fwww.thefreedictionary.com%2Fmetaphorically&ei=9wQMVevOAoSZgwSzlYKIBg&usg=AFQjCNEmK4iiG7YERPh5HOhJHEXLBAsn2g&bvm=bv.88528373,d.eXY

This case began with Judge Baldwin signing an Order, over strong objection

of counsel for Michelle Murphy. Judge Baldwin appointed a guardian ad litem,

who, upon exposure, resigned and provided Judge Baldwin an Order to sign

appointing another guardian ad litem, who almost immediately transferred trust

funds to her personal use in violation of Uniform Superior Court Rule 24.9

(8)(g). That guardian ad litem resided on premises with her husband where

marijuana was used and kept, and she further engaged in adultery. This was not

the type of individual that Michelle Murphy had raised her children to trust and

respect and certainly not a person who was capable of deciding the best interest

of the children.

The depth of and extent of Judge Baldwin’s corruption stymied protection

by the Judicial Qualifications Commission. Judge Baldwin attempted to

prevent the civil action against the court reporter who provide a false

certification of a record that did not contain four (4) pages of the most relevant

violations of the Code of Judicial Conduct by Judge Baldwin that was not

recovered until the combined Open Records Request of Larry King and a civil

action brought against the Court Reporter.

The ability of the Director of the Judicial Qualification Commission, Judge

Ronnie Joe Lane, has apparently also been stymied, whether by the absence of

funds, absence of support of an investigator, or the absence of support of a

commission that is willing to address the unconstitutional politicization of the

judiciary to the extent that Judge Baldwin, as the exclusive trier of fact, has

engaged in corruption that any competent judge would remove as a juror.

Michelle Murphy moves the Administrative Judge for the Sixth Judicial

Administrative District, Matthew O. Simmons, to rescind his Appointment of

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Senior Judge William Ison to serve in the Superior Court of Coweta County

case of John Harold Murphy vs. Nancy Michelle Murphy Civil Action No.

12V-413.

Larry King and his secretary/paralegal/administrative assistant, Lulu

Svec, became active participants in issues relating to matters involving

Judge Baldwin and other judges in the Coweta Judicial Circuit when Larry

King served as an expert witness in the case of Michelle Murphy v. Delia

Tedder Crouch, Superior Court of Coweta County, Civil Action File

08V2137. In that case, a judge executed a QDRO Order that deprived

Michelle Murphy of a substantial amount of money after Michelle Murphy

was already deprived of $180,000 as the result of a false affidavit of John

Harold Murphy. Lulu Svec participated in preparing documents for Larry

King’s use as an expert witness in the malpractice case against Michelle

Murphy’s former attorney in the divorce. The underlying divorce case

involved Judge Allen B. Keeble, Judge E. Byron Smith, Judge Quillian

Baldwin, Judge Dennis Blackmon and Judge William F. Lee, Jr., each of

whom dealt with the “subject matter” of that litigation, in segments

involving Michelle Murphy and John Harold Murphy.

The absence of a USCR 3.1 case assignment system was a total disaster, in

addition to being used for unethical purposes, as the five judges who served

John Murphy and Michelle Murphy, demonstrate.

After the resolution of that malpractice case, the litigious John Harold

Murphy, who by then was married to a hedge fund operator who provided him

funding and resources to engage in litigation against the mother of the two

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children that she raised since they were toddlers. Michelle Murphy is a hair

stylist.

Larry King is one of the lawyers who has been held in contempt of court by

Chief Judge Baldwin.

The holding of Larry King in contempt of court in the pending Murphy case

in Coweta County was such an affront to Larry King that he sought comfort

and assistance from his friend, who is now the Administrative Judge for the

Sixth Judicial Administrative District, Matthew O. Simmons. The

affidavit of Larry King that is relevant evidence to establish the illegal conduct

of Chief Judge Baldwin relating to the pending contempt orders of Judge

Baldwin against Michelle Murphy and Millard Farmer is Attachment 96.

Lulu Svec worked on the pending case of Michelle Murphy with Larry King

and Millard Farmer from May 1, 2012 until, after Larry King’s retirement

from the practice of law, she became employed as the Administrative

Assistant for the Administrative Judge for the Sixth Judicial Administrative

District, Matthew O. Simmons. Since the case did not terminate with the

retirement of Larry King from the practice of law and the close of his office,

this case of Michelle Murphy is the only case that Lulu Svec had to take to

her home to complete during her off hours, if called upon. --- Lulu Svec,

willingly or not, will be called upon to produce information for Michelle

Murphy, as John Harold Murphy has threatened to seek attorney fees from

Michelle Murphy.

Judge Matthew O. Simmons should have been provided this information in

order that he not designate Judge Ison to serve in this case.

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Judge Simmons’ current Administrative Assistant, Lulu Svec, met with

Michelle Murphy and worked on this case as Larry King’s secretary since the

case was initiated in April, 2012 until Larry King retired from the practice of

law in September, 2014. Lulu Svec was employed as Larry King’s secretary

for more than twenty-five years.

. Request for Relief

1. Counsel for Michelle Murphy and Millard Farmer requests that Judge

Matthew O. Simmons rescind the designation of Judge William Ison and not

designate any Senior Judge to preside in the case involving Michelle Murphy.

2. Counsel for Michelle Murphy and Millard Farmer requests that Judge

Matthew O. Simmons seek the investigative information from the Judicial

Qualification Commission relating to Judge Baldwin and Judge Louis Jack

Kirby.

3. Counsel for Michelle Murphy and Millard Farmer requests an opportunity

to present evidence to Judge Matthew O. Simmons relating to the designation

of Judge William Ison.

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4. Counsel for Michelle Murphy and Millard Farmer requests such other and

further relief as justice requires.

Respectfully submitted,

��Millard Farmer Georgia Bar No. 255300 P.O. Box 1728 Atlanta, GA 30301-1728 (404) 688-8116 [email protected] Counsel for Nancy Michelle Murphy and Millard Farmer

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List of Attachments

Att. 1 Order Designating Senior Judge William Ison as Judge in Murphy v. Murphy, Superior Court of Coweta County, No. 2012-V-413 Att. 96 Affidavit of Larry King, October 7, 2013 Att. 154 Transcript of Deposition of Nan Freeman, Official Court Reporter to Judge A. Quillian Baldwin, Jr., November 22, 2014

Att. 161 Voluntary Recusal Order of Judge A. Quillian Baldwin, Jr., February 9, 2015 Att. 162 Order of Recusal of Judge John T. Simpson, Judge Dennis Blackmon and Judge William G. Hamrick III, February 11, 2015 Att. 163 Order of Recusal of Judge Jack Kirby, Judge Emory L. Palmer and Judge W. Travis Sakrison, February 19, 2015 Att.164 Part 1 of Motion for an Investigation, Public Disclosure and

Termination of the Corruption of Judge A. Quillian Baldwin, Jr. (Tendered on January 30, 2015 with a Request for Permission to File,

But Not Permitted to be Filed)

Attachment 1

Order Designating Senior Judge William Ison as Judge in Murphy v. Murphy,

Superior Court of Coweta County Civil Action No. 2012-V-413

March 18, 2015

Order Designating Senior Judge William Ison as Judge in Murphy v. Murphy,

Superior Court of Coweta County Civil Action No. 2012-V-413

March 18, 2015

Attachment 96

Affidavit of Larry King October 7, 2013

Attachment 96

Affidavit of Larry King October 7, 2013

Attachment 96, Page 1 of 23

Superior Court of Coweta County and styled Nancy Michelle Murphy, Plaintiff

vs. Delia Tedder Crouch, Civil Action No. 08-V-2137. The Amended Affidavit

that I provided in that litigation is Attachment 3.

4. The legal malpractice litigation involved the 2006 Final Decree of Divorce

that included a Settlement Agreement that was made a part of the Final Decree

in the Superior Court of Troup County styled Murphy v. Murphy, Civil Action

04-CV-494. This final decree is the decree that John Harold Murphy seeks to

have modified in this current litigation.

5. In connection with the legal malpractice litigation the following materials

are included in the materials that I reviewed.

5.1 I reviewed the Complaint and the attachments to the Complaint, which

include some of the following documents that I identify that I have read.

5.2 I reviewed the December 20, 2006 Final Decree of Divorce of the

Superior Court of Troup in Murphy v. Murphy, Civil Action 04-CV-494 and

Exhibit A to the Final Decree of Divorce, a Settlement Agreement, made a

part of that Order.

5.3 I reviewed the April 24, 2007 Qualified Domestic Relation Order

Regarding AXA Equitable Life Insurance Company Pension, which is

referred to at times in the Complaint as the AXA QDRO.

5.4 I reviewed the December 2, 2008 letter to Michelle Murphy from Sheila

Labita, CEBS with AXA Equitable.

5.5 I reviewed the Domestic Relations Financial Affidavit provided by

John Murphy to the Court on November 22, 2005.

5.6 I reviewed the transcript of the August 7, 2006 hearing, where the

settlement agreement was read in open court.

5.7 I reviewed the transcript of the October 18, 2006 hearing relating to the

enforcement of the settlement agreement.


5.8 I reviewed the transcript of the November 15, 2006 hearing relating to

the enforcement of the settlement agreement.

5.9 I reviewed by scanning the certified copy of the entire record of the

Superior Court of Troup County in Murphy v. Murphy, Civil

Action 04-CV-494 and selected documents in that record to read in their

entirety and thumbed through other documents to view the nature of the

document.

5.10 I reviewed the Billing Statement of Delia Tedder Crouch to Michelle

Murphy for legal services provided in connection with a domestic relation

matter that involved litigation in the Superior Court of Troup in Murphy v.

Murphy, Civil Action 04-CV-494 and in the implementing of the Final

Decree if Divorce in that litigation.

5.10.1 During the divorce litigation five (5) different Superior Court

Judges were involved in segments of the litigation.

5.10.2 Neither party sought to remove any of the five judges from the

case.

5.10.3 Each of the five (5) judges served, as the judges appeared on

hearing days, or as they were available for particular segments of the

divorce litigation.

5.11 That litigation was settled with a confidential settlement agreement

that I did not negotiate, or participate in negotiating.

5.12 My experience with the post-divorce malpractice litigation provided

me the knowledge and understanding of the issues between the parties such

that I accepted the request for my participation as counsel in the modification

for custody action that John Harold Murphy filed against Nancy Michelle

Murphy.


5.12.1 In my attempt to promptly resolve the dispute in this litigation,

after Renee Haugerud was made a party to the litigation, but before her

answer was due or she had retained counsel, I reached out to her with a

letter that resulted in her calling me. I offered to meet with me at her

convenience at her home in Chattanooga, Tennessee. I extended this

invitation, as she had been implemental in resolving the dispute in the

malpractice case. After a cordial conversation, she refused to meet with

me in an attempt to reach a resolution in this case.

6. I began representing Nancy Michelle Murphy when John Harold Murphy

brought this current action against Nancy Michelle Murphy and have

represented her continually since that time with Millard Farmer.

7. Based upon my extensive knowledge of domestic relations law and

lengthy experience with litigation, the initial incident of

Judge A. Quillian Baldwin, Jr. signing an order that was reported to me that he

did not read designating a guardian ad litem with authority not authorized by

the Uniform Superior Court Rules, and the process by which

Judge A. Quillian Baldwin, Jr. was obtained to be the judge in the case, I was

an active decision maker with Millard Farmer and Nancy Michelle Murphy in

making the determination that a motion to disqualify Judge A. Quillian

Baldwin, Jr. was necessary as an initial step in obtaining a fair proceeding for

Nancy Michelle Murphy and her two children.

8. Throughout this litigation, I have been an active decision maker with

Millard Farmer and Nancy Michelle Murphy in continuing to pursue the

disqualification of Judge A. Quillian Baldwin, Jr.

8.1 The reasons for the disqualification of Judge A. Quillian Baldwin, Jr.

have escalated at each phase of this litigation. Nancy Michelle Murphy, nor


her counsel have ever been treated equally with John Harold Murphy, Renee

Haugerud and their counsel.

8.2 The inequality of treatment received by Nancy Michelle Murphy and

her counsel has never been legally justified.

9. Never have I been so certain that Judge A. Quillian Baldwin, Jr. should

have been and now should be disqualified as on Thursday, October 3, 2013.

9.1 On that Thursday, October 3, 2013, I realized that the conduct of

Judge A. Quillian Baldwin, Jr. was more vindictive against

Nancy Michelle Murphy and everyone assisting her than just his vendetta

against Millard Farmer for his ill-perceived role of being the most active

participant in attempts to disqualify Judge A. Quillian, Jr. There is no legal

basis for the vindictiveness and bias that Judge A. Quillian Baldwin, Jr. has

exercised against Nancy Michelle Murphy and her counsel.

9.2 Millard Farmer has been the scribe, expressing the law and the facts

marshalled by the team of people who have attempted to assist Nancy

Michelle Murphy and her two children. Beginning with the initial

disqualification motion there was and is uniformity of belief by the legal

team supporting Nancy Michelle Murphy that Judge A. Quillian Baldwin, Jr.

is disqualified to serve in any capacity in this litigation.

10. On Thursday, October 3, 2013 I appeared in Courtroom B of the

Superior Court of Coweta County. I appeared to answer the call of the calendar

call in Murphy v. Murphy.

10.1 The Thursday, October 3, 2013 calendar posted and sent to counsel

from the Clerk of Court of Coweta County does not indicate that a motion for

contempt is on the Thursday, October 3, 2013 calendar, as the

“Prosecutor/Plaintiff” Taylor Drake of Glover& Davis did not obtain and serve

a Rule Nisi upon either Nancy Michelle Murphy, or her counsel.


10.2 The case was requested to be placed on the calendar by

“Prosecutor/Plaintiff Attorney Drake, Taylor.” The calendar also designated as

a movant, “Prosecutor/Plaintiff Harwell, Elizabeth F., GAL.” A true and

accurate clip from the Murphy v. Murphy segment of the Superior Court of

Coweta County calendar for Thursday, November 3, 2013 is as follows.

10.3 Upon call of the calendar above the Court proceeded to hear a Motion

for Contempt against only Nancy Michelle Murphy that was filed on

August 29, 2013. This Motion for Contempt was for an Indirect Contempt

based upon allegations that occurred outside the presence of the Court. The

motion sought criminal and other sanctions against Nancy Michelle Murphy.

10.4 Upon the call of the calendar above the Court also proceeded to hear an

Amended Motion for Contempt that was filed against Nancy Michelle Murphy

on September 27, 2013. The Glover & Davis lawyers did not even serve me

with a copy of this motion as their “Certificate of Service” clearly shows as

follows.


10.5 The September 27, 2013 Amended Motion for Contempt only apprised

me as follows about the disposition that was sought against “Defendant’s

lawyer.” Note “lawyer” is in the singular and not “lawyers” in the plural. There

are two lawyers for Nancy Michelle Murphy. A charging document must

identify the person who is being charged. When the defendant has two lawyers

the charging document cannot require either lawyer to guess who is charged

with the alleged contemptuous conduct. The term “sanction” further does not

define the scope of punishment sought that places the charged party on notice

if the charges must be proven beyond a reasonable doubt. The snip below is

from the September 27, 2013 Amended Complaint.


The Amended Motion for Contempt, Containing Distinct and Very Different Grounds for Contempt was Filed on Friday, September 27, 2013, Just Six (6) Days, that included a Saturday and a Sunday, Before the Thursday, October 3, 2013 Hearing, which was Twenty five (25) Days before a Response was Due on Monday, October 28, 2013

10.6 It was and is my strong legal opinion that Nancy Michelle Murphy

should not be assessed blame for the attempted due process violation of the

“Prosecutor/Plaintiff” Taylor Drake of Glover & Davis.

10.6.1 The time between the filing of the Amendment to the Motion for

Contempt by the “Prosecutor/Plaintiff” Taylor Drake of Glover& Davis

and the hearing was so short that even the “Prosecutor/Plaintiff”

Taylor Drake of Glover & Davis did not have his witnesses present for the

hearing, only served one lawyer, did not obtain or serve a Rule Nisi and

did not serve a Notice of Hearing upon any lawyer for Nancy Michelle

Murphy.

10.6.2 The challenges that I attempted to address on behalf of

Nancy Michelle Murphy are legal issues that any lawyer is entitled to raise

without having his professional reputation attacked by being cited for

contempt of Court, as I was cited by Judge A. Quillian Baldwin, Jr.

10.6.3 In my more than thirty-seven years of practicing domestic

relations and other areas of law, I have appeared at thousands of calendar

calls, but unexpectedly and unbeknownst to me at the time of this

Thursday October 3, 2013 calendar call, I was about to experience a type

of judicial treatment that I had never before observed. I have never

experienced or even observed such judicial conduct as was about to be

directed toward me to the detriment of Nancy Michelle Murphy.


The Motion for Indirect Contempt, brought with Due Process Service Deficiency Seeking Criminal Sanctions which are Reflections upon Professional Reputations 10.7 The Motion for Contempt on the Thursday, October 3, 2013 calendar

was filed on August 29, 2013, by the “Prosecutor/Plaintiff” Taylor Drake of

Glover& Davis on behalf of John Harold Murphy.

10.7.1 The “Prosecutor/Plaintiff” Taylor Drake of Glover & Davis on

September 12, 2013 served a Notice of a Thursday, October 3, 2013

Hearing for only the original August 29, 2013 Motion for Contempt.

10.7.2 The “Prosecutor/Plaintiff” Taylor Drake of Glover & Davis

never served a Rule Nisi for the Thursday, October 3, 2013 hearing upon

Nancy Michelle Murphy nor her counsel for their appearance on

Thursday, October 3, 2013 for a hearing on the August 29, 2013 Motion

for Contempt.

10.7.3 The “Prosecutor/Plaintiff” Taylor Drake apparently never even

obtained a Rule Nisi for the Thursday, October 3, 2013 hearing on the

August 29, 2013 Motion for Contempt.

10.7.4 The “Prosecutor/Plaintiff” Taylor Drake of Glover & Davis in

most, if not all, of his previous hearings has included a Rule Nisi and has

never to my memory filed just a “Notice of Hearing.” The bench book

distributed by the Judicial Council provides guidance that in contempt

actions, due process requires a Rule Nisi as opposed to the quite different,

Notice of Hearing. Motions seeking Indirect Contempt against a person

provide very distinct statutory and constitutional protections.


The Amended Motion for Contempt, Due Process Service of Charges, Adequate Time to Respond, Identity of Charged Party and an Independent Jurist not Embroiled in the Issues Deficiency.

10.8 The “Prosecutor/Plaintiff” Taylor Drake of Glover & Davis, on

September 27, 2013 filed an Amended Motion for Contempt. This was only

six days, including a Saturday and a Sunday before the

Thursday, October, 3, 2013 calendar date, and thirty (30) days before a

response was due.

10.8.1 The “Prosecutor/Plaintiff” Taylor Drake of Glover & Davis

never served a Notice of Hearing nor a Rule Nisi for the Thursday,

October 3, 2013 hearing upon Nancy Michelle Murphy nor her lawyers

for their appearance at a hearing on the Amended Motion for Contempt

that contained a completely different array of charges for contempt. The

charging documents even failed to identify the name of “defendant’s

lawyer. [Note: “lawyer” is singular and there are two lawyers] The

Certificate of Service on the Amended Complaint accurately reflects that

the charging Amended Contempt document was not served upon me as it

was only served upon Millard Farmer, one of the two lawyers for Nancy

Michelle Murphy.

10.8.2 The Amended Motion for Contempt was based upon an ex parte

communication that the Glover & Davis lawyers had with

Judge A. Quillian, Jr. that resulted in a modification of the custody of the

children by changing the scheduled visitation days of John Harold Murphy

from the schedule set out in the 2006 Final Divorce Decree and as further

modified by the pronouncement in open Court that John Harold Murphy

can take the children anywhere he wishes, even to “Russia” during his

visitation period.


The Constitutional and Statutory Detriment of the Due Process Service Deficiency 11. Nancy Michelle Murphy has a limited amount of financial resources that

she can appropriate to this litigation without affecting the welfare of the

children.

11.1 Counsel for Nancy Michelle Murphy subpoenaed the school

principal of the children, a teacher of the children and another witness who

had extensive knowledge of this family for the last “hearing” when

Judge Baldwin abruptly terminated the hearing with the witnesses of

Nancy Michelle Murphy left waiting to testify, but not allowed. The

testimony of these witnesses was relevant to the issue of whether a “custody

evaluator” was necessary. The affidavit of Dr. Jan Franks, the principal of

Arnall Middle School, is Attachment 1. The affidavit of Polly Craft is

Attachment 2.

11.2 A Rule Nisi permits an opportunity to subpoena a key witness, Renee

Haugerud, whose counsel has refused to allow her deposition and to take the

deposition of Elizabeth “Lisa” F. Harwell after she produces her financial

and other records for which she filed a motion to quash.

11.3 The Response to the August 29, 2013 Motion for Contempt and the

Amendment to the August 29, 2013 Motion for Contempt present defenses

that could have been presented if Nancy Michelle Murphy and “defendant’s

lawyer,” if identified, had been provided due process notice.

11.4 The defective due process notification and statutory protections were

clearly identified in Michelle Murphy’s “Notice of Supersedeas and Plea as

to the Absence of Jurisdiction and Unconstitutional Due Process Nature of

the Alleged “Contempt” Actions Filed by the Glover & Davis Lawyers.”


11.5 The “Amendment” to the Motion for Contempt that was filed on

September 27, 2013 contained neither a Notice of Hearing nor a required

Rule Nisi, as the Amendment was also an Indirect Contempt seeking

criminal sanctions.

11.6 Neither Nancy Michelle Murphy nor Millard Farmer were

subpoenaed to appear at the calendar call or hearing. Neither appeared.

Thursday, October 3, 2013 in the Superior Court of Coweta County 12. That morning before court began, I filed the First Amendment to the

Response of Michelle Murphy to John Murphy’s Motion for Contempt. In open

court, after the calendar call of the Murphy case, I filed the Notice of

Supersedeas and Plea as to the Absence of Jurisdiction and Unconstitutional

Due Process Nature of the Alleged “Contempt” Actions Filed by the Glover &

Davis Lawyers.

12.1 Upon entering the courtroom, I sat on the wood bench on the far right

side.

12.2 I observed Nan Freeman, the court reporter, set up. As soon as she

had applied her last piece of duct tape to her wires, she returned to her desk.

12.3 I was aware that Judge A. Quillian Baldwin, Jr. had threatened to put

Millard Farmer in jail for attempting to have the court reporter take down the

calendar call. This previous event occurred as follows according to the sworn

testimony supporting the “Friday, September 13, 2013 Addendum to

Wednesday, August 28, 2013 Amendment to the Monday, August 19, 2013

Consolidated Motions for Disqualification of Judge A. Quillian

Baldwin, Jr.” that was pending awaiting a decision by Judge A. Quillian

Baldwin, Jr. That Amendment to the August 19, 2013 disqualification

motion states as follows.


4.1.2 The transcript of that August 6, 2013 hearing documents the following portion of the transcript before the lawyers, their clients and other persons awaiting a full call of the calendar.


4.1.3 There was a very quiet, conversational speaking tone by counsel for John Murphy to Judge Baldwin. It was Judge Baldwin who yelled; at one point, “…I’m going to put you in jail. Do you understand me? Do you understand me?...” very loudly to Millard Farmer, who was standing still and motionless in amazement of the apparent no reason other than bias resulting from the disqualification motions for such conduct by Judge Baldwin.

12.4 In order to avoid any confrontation with Judge A. Quillian Baldwin

about obtaining a recording of the calendar call, long before Court began, I

informed the court reporter that I understood Judge Baldwin's position about

taking down the call of the calendar and was not raising that issue again. I

then pointed to the Murphy case on the calendar and stated that I wanted my

announcement on this case taken down and everything said during the case

taken down.

12.5 In the “Notice of Supersedeas and Plea as to the Absence of

Jurisdiction and Unconstitutional Due Process Nature of the Alleged

“Contempt” Actions Filed by the Glover & Davis Lawyers” document that I


filed in open Court, the following explanation of counsel’s fear that

Judge A. Baldwin, Jr. would not allow issues of law to be presented to the

Court was made.

2.2 Nancy Michelle Murphy, Millard Farmer and Larry King, while reserving all rights, enter this notification of a plea as to the lack of jurisdiction of the court and a plea as to the statutory and constitutional authority of Judge A. Quillian Baldwin, Jr. to proceed with the following items that the Glover & Davis lawyers have requested that the Clerk of the Superior Court Coweta County place on the list of matters to be called for hearing today. This is an informational notice that documents placed on the calendar of the Court for Thursday, October 3, 2013 do not provide Nancy Michelle Murphy, Millard Farmer and Larry King their constitutionally protected rights. After appropriate notice and charging documents, and a continuance of time, they will respond fully.

12.6 I then gave the court reporter my business card, exchanged

pleasantries and she agreed to my request for the takedown of all matters.

13. The calendar call began without the presence of the court reporter.

13.1 When Judge A. Quillian Baldwin, Jr. called the Murphy case, I

immediately stood and stated that I had made arrangements for the court

reporter to take down my announcement and requested that the Murphy

announcement be made when the court reporter returned. Judge Baldwin

complied with my request and called the remainder of the calendar. Judge

Baldwin then apparently asked for someone to retrieve the court reporter, as

she appeared and the Murphy case was called at the end of the calendar.

14. In response to the calendar call I was prepared to make my announcement

in the following order.


14.1 I wanted to provide Judge Baldwin of the dates of the pending

disqualification motions that were awaiting a ruling by him and that Uniform

Superior Court Rule 25 required Judge Baldwin to cease acting on the matter

until he ruled upon the disqualification motions. The following documents

relating to the disqualification of Judge A. Quillian Baldwin, Jr. are pending

and awaiting a ruling by Judge Baldwin or an independent judge assigned to

hear the motions. These disqualification motions are summarily identified as

follows.

July 2, 2012 Consolidated Motions for Disqualification of Judge A. Quillian Baldwin, Jr.

Monday, August 19, 2013 Consolidated Motions for Disqualification of Judge A. Quillian Baldwin, Jr., Constitutional Challenges to Uniform Superior Court Rule 25 et seq. and for Other Uses as Allowed by Law August 28, 2013: Amendment to Monday, August 19, 2013 Consolidated Motions for Disqualification of Judge A. Quillian Baldwin, Jr., Initiated with this Judge’s “I’ll Put You in Jail” Threats that Motivated John Murphy to Sic the Deputy Sheriff of Coweta County on the Mother of the Children whom She Raised Since John Murphy Abandoned the Family Friday, September 13, 2013 Addendum to Wednesday, August 28, 2013 Amendment to the Monday, August 19, 2013 Consolidated Motions for Disqualification of Judge A. Quillian Baldwin, Jr.

14.2 After informing Judge Baldwin of the pending disqualification

motions, I wanted to advise the Court that the required personal service and

a Rule Nisi, had been given and that the matter was not before the Court.


14.3 I wanted to advise the Court that it had no jurisdiction, as the

Amended Motion for Contempt attempted to add what could be one of two

parties, identified as the “lawyer” for Nancy Michelle Murphy. The adding

of one of possible two new parties to the motion for contempt was a violation

of the rights of the newly added party but was additionally prejudicial to

Nancy Michelle Murphy, as such conduct is detrimental to Michelle Murphy

to have Judge Baldwin allowing the Glover & Davis lawyers attacking her

lawyer.

14.4 I wanted to advise the Court that the August 23, 2013 Order was on

appeal and that any contempt of that Order was superseded by the appeal.

14.5 Additionally, I wanted to advise the Court that the

September 27, 2013 motion was not noticed nor ripe for hearing on October

3, 2013.

15. At some point during my monotone announcement of the above

statements of what I felt to be an initial consideration, Judge Baldwin stated

something like, “I hold you in contempt. I am tired of all this stuff you all are

doing. I order you incarcerated until you pay $1000.00 attorney fees as a

purge.”

15.1 The transcript being prepared by Nan Freeman, the court reporter, of

the exact language use by Judge A. Quillian Baldwin, Jr. is being sought to

obtain the exact language.

15.2 After this pronouncement by Judge A. Quillian Baldwin, Jr., I

walked towards the Sheriff and Clerk with my right hand in my right pocket

to retrieve the money.

15.3 The deputy, a white male raised in Clayton County who graduated

from Jonesboro High School 1995, grabbed my right biceps as I attempted

to obtain the purge money. I felt as if I was in his custody while I obtained


the money from my pocket and as I paid the purge to the Deputy Clerk in

open court.

15.4 After paying the $1,000, I stated, “let the record reflect that I have

paid the purge to the Clerk of Court.”

15.5 Judge Baldwin seemed frustrated that I could immediately purge the

contempt by paying the $1,000.

15.6 Other matters on the calendar were handled after I paid the $1,000.

15.7 Judge Baldwin took a break around 10:00 a.m. and stated that the

Murphy case would be dealt with when he returned from break. I sat at

counsel table during the break.

After the Contempt for Reciting the Basis for the Court not Proceeding

16. I rely on the transcript for a more comprehensive statement of the events

that followed; however, the following accounting of the events is accurate to

the best of my knowledge and belief.

16.1 I made as my opening, a statement of some of the issues. It became

obvious that any further identification of these due process and statutory

protections or the disqualification motions that were not yet ruled upon

would result in me being held in contempt of court once again.

16.2 The contempt action affected my presentation of issues to the Court,

as it was unpredictable to me when, or what would ignite the fury of

Judge A. Quillian Baldwin, Jr. once again. Judge Baldwin had held me in

contempt for merely reciting some of the constitutional and statutory

protections accorded persons charged as Nancy Michelle Murphy and one of

the two lawyers for Nancy Michelle Murphy.

16.3 The “Prosecutor/Plaintiff” Taylor Drake of Glover & Davis called

John Harold Murphy as his first witness. Taylor Drake attempted to present

the issues raised in the August 29, 2013 Motion for Contempt relating to


visitation and the issues raised in the September 27, 2013 Amended Motion

for Contempt relating to the alleged noncooperation with the custody

evaluator with only the testimony of John Harold Murphy.

16.4 It is relevant to note that John Harold Murphy only provided a

verification that the facts were “true and accurate to the best of his

knowledge and belief” to support the motion for Contempt and the Amended

Motion for Contempt.

During the Direct Examination of John Harold Murphy, Judge Baldwin Informed Counsel that he Wished to Speak with Counsel in Chambers 17. During John Harold Murphy’s testimony, Judge A. Harold Murphy stated

that he wished to talk to counsel in chambers. The court reporter did not proceed

to chambers, or take down the communications that occurred in chambers.

17.1 As counsel walked down the hallway with Judge Baldwin to his

chambers, he stated, "I did not want to embarrass anyone out there, but I

can’t do anything about the failure to cooperate with the evaluator unless I

hear from her." (Meaning the Custody Evaluator). The Custody Evaluator

was selected by Elizabeth “Lisa” F. Harwell, who took money from the

guardian ad litem trust account as explained under oath in the “Response of

Michelle Murphy to Counsel for Elizabeth “Lisa” F. Harwell, Teresa E.

Lazzaroni of Hawkins Parnell Thackston & Young’s Motion on behalf of

Guardian ad Litem Elizabeth “Lisa” F. Harwell’s Request for Protective

Order and Motion to Quash Michelle Murphy’s Subpoena for Deposition

and Production of Evidence and Notice of Deposition”

1.2 The subpoenaed documents from Elizabeth “Lisa” F. Harwell, in part, relate to the illegal conversion of trust funds to the personal use of Elizabeth “Lisa” F. Harwell. This conduct is a violation of Uniform Superior Court Rule 24.9 (8) (g), and


thereby OCGA §16-8-2 and Georgia Rules of Professional Conduct Rule 1.15(I) 1.2.1 Uniform Superior Court Rule 24.9 (8) (g) provides as follows.

g. Payment of GAL Fees and Expenses. It shall be within the Court's discretion to determine the amount of fees awarded to the GAL, and how payment of the fees shall be apportioned between the parties. The GAL's requests for fees shall be considered, upon application properly served upon the parties and after an opportunity to be heard, unless waived. In the event the GAL determines that extensive travel outside of the circuit in which the GAL is appointed or other extraordinary expenditures are necessary, the GAL may petition the Court in advance for payment of such expenses by the parties. emphasis supplied

1.2.2 Elizabeth “Lisa” F. Harwell took the money that was provided in trust to Melissa Griffis, the first guardian ad litem appointed by Judge Baldwin, which she apparently transferred to Elizabeth “Lisa” F. Harwell in trust. The funds were subject to the protections of Uniform Superior Court Rule 24.9 (8) (g), and thereby OCGA §16-8-2 and Georgia Rules of Professional Conduct Rule 1.15(I) The street language for this conduct is “stealing.”

1.2.2.1 The street analogy of the conduct of Elizabeth “Lisa”

F. Harwell would be a company employee taking money from

the cash register for the employee’s personal use, with a written

company policy against such conduct, after the employee had

worked a few days before the employee’s paycheck was due later

in the week.

1.2.2.2 The message from Judge Baldwin to the people in the

Coweta Judicial Circuit is that the Chief Judge believes that it is


permissible for a court appointed fiduciary to engage in such

conduct because the conduct of the guardian ad litem is being

challenged by counsel who is also challenging the judge’s ethical

conduct for converting to the judge’s personal benefit, legally

protected rights belonging to a litigant.

1.2.2.3 A political benefit is a thing of value that a judge cannot

accept in exchange for denying a litigant rights protected by law.

17.2 Instead of coaching Taylor Drake about the evidence that he needed,

Judge Baldwin could have done the one thing that a jurist is required to do:

ask if counsel for John Harold Murphy had additional evidence to present. If

the “Prosecutor/Plaintiff” Taylor Drake did not have further evidence, a

dismissal was appropriate rather than Judge Baldwin taking over a portion

of the prosecution of a motion which was unconstitutionally before him.

18. Judge A. Quillian Baldwin, Jr. would not have been constitutionally

accorded the opportunity to engage in the conduct in which he engaged on

Thursday, October 3, 2013, if Uniform Superior Court Rule 25 was facially

constitutional, as this Rule has been consistently challenged in this litigation.

The challenge is as follows.

Uniform Superior Court Rule 25, as applied and facially violates the

protections afforded The Michelle Murphy and Children Parties in this case and

to others in all cases under the United States Constitution, equal protection U.S.

Const. amend. XIV, § 1 and State of Georgia Constitution Bill or Rights equal

protection (Ga. Const. Art. I, § 1, ¶ 2)

Uniform Superior Court Rule 25, as applied and facially, violates the

protections afforded the Michelle Murphy and Children Parties in this case and

to others in all cases under the United States Constitution due process, U.S.


Attachment 154

Transcript of Deposition of Nan Freeman, Official Court Reporter to Judge A. Quillian Baldwin, Jr.

November 22, 2014

Attachment 154

Transcript of Deposition of Nan Freeman, Official Court Reporter to Judge A. Quillian Baldwin, Jr.

November 22, 2014

1 IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA

2 NANCY MICHELLE MURPHY, )

3 ) Plaintiff, )

4 ) v. ) CIVIL ACTION FILE

5 ) NO. 2014CV241705 NAN FREEMAN and FREEMAN )

6 REPORTING, INC., ) )

7 Defendants. ) _____________________________)

89 * * *10 Videotape Deposition of

NAN DUBOSE FREEMAN,11 (individually and as

30(b)(6) representative of12 Freeman Reporting, Inc.)13

November 22, 201414 9:44 a.m.15

5180 Lone Oak Road16 Hogansville, Georgia17

By Marcia Arberman, RPR, CCR B-10591819 ***************************************************20212223 VERITEXT LEGAL SOLUTIONS24 1075 Peachtree Street, NE - Suite 362525 Atlanta, Ga 30309

Page 1

Veritext National Court Reporting CompanyToll Free: 855.282.1018 404.817.9606


E X A M I N A T I O N

Page2

Cross-Examination by Mr. Farmer 53

E X H I B I T S4

Plaintiff's5 Exhibit Description Page6 1 Notice of Deposition 57 2 Payments from the State of Georgia to 13

Freeman Reporting, Inc. from 2010 to8 20139 3 9-22-12 Freeman Reporting, Inc. 23

invoice to Farmer10

4 6-19-14 e-mail to Farmer from Harris 3811 (Judge Baldwin's secretary)12 5 Certificate page of 5-27-14 49

transcript13

6 6-10-14 Freedom of Information 5014 request letter15 7 6-12-14 letter to King from Freeman 5016 8 Transcript addendum 5117 9 6-5-14 Freeman Reporting, Inc. 66

invoice to Farmer18

10 10-16-13 Freeman Reporting, Inc. 7419 invoice to Farmer20 11 8-12-14 letter to Farmer from 85

Skandalakis2122232425

Page 31 APPEARANCES OF COUNSEL:2 On behalf of the Plaintiff:3 MILLARD C. FARMER, JR., ESQ.

151 Nassau Street4 Atlanta, GA 30303

Phone: (404) 688-81165 [email protected] On behalf of the Defendants:7 KENNETH LAMAR GORDON, ESQ.

5180 Lone Oak Road8 Hogansville, GA 30230

Phone: (706) 637-45589 [email protected]

10 Also Present:11 Nancy Michelle Murphy

Kimellen Tunkle12 Spencer Bush, Videographer13141516 * * *171819202122232425

Page 41 MR. FARMER: I think maybe we'll let the2 parties identify themselves.3 I'm Millard Farmer, and I represent4 Nancy Michelle Murphy. And with me is Paralegal5 Kimellen Tunkle, and with me is Nancy Michelle6 Murphy, who is the Plaintiff.7 MR. GORDON: Ken Gordon, attorney to8 Nan Freeman, and my client Nan Freeman.9 MR. FARMER: And Freeman Reporting,

10 Inc., right?11 MR. GORDON: Right.12 MR. FARMER: And this is a deposition.13 It's taken by agreement. And we got a Notice of14 Deposition that we have some documents that15 we'll probably be able to substitute for during16 the deposition unless there's some dispute about17 the documents. And I will ask that this be made18 a part of the deposition, if you will.19 You want to identify these as -- how20 would we like to identify the -- how would we21 like to identify the --22 MR. GORDON: The notice?23 MR. FARMER: No, just Plaintiff's 1?24 MR. GORDON: Yeah, that would be fine.25 MR. FARMER: We'll just mark this for

Page 51 Plaintiff's Exhibit 1.2 THE REPORTER: Should I mark it now?3 MR. FARMER: You may mark it now, if you4 will.5 (Whereupon, marked for identification,6 Plaintiff's Exhibit No. 1.)7 MR. FARMER: If you will, please swear8 the witness.9 NAN DUBOSE FREEMAN,

10 having been first duly sworn, was deposed and11 testified as follows:12 CROSS-EXAMINATION13 BY MR. FARMER:14 Q Would you state your name, please?15 A Nan DuBose Freeman.16 Q And are you here in the capacity of also17 representing Freeman Reporting, Inc.?18 A Yes, sir.19 Q And would you please tell us what is20 Freeman Reporting, Inc.?21 A I'm a court reporter. And that's the22 name I'm incorporated under.23 Q And are you the owner -- or what is the24 owner status of Freeman Reporting, Inc.?25 A I'm the owner, I guess.

2 (Pages 2 - 5)Veritext National Court Reporting Company

Toll Free: 855.282.1018 404.817.9606Attachment 154, Page 2 of 53

Q Okay. And you're here in the capacity2 to represent Freeman Reporting, Inc. also?3 A Yes, sir.4 Q And would you tell us a little bit about5 your experience and occupation?6 A Well, I'm a court reporter. I was7 certified several years ago. And I have been working8 first as a freelance and shortly after, an official.9 Q In -- in your ownership of Freeman

10 Reporting, Inc., did you have other reporters working11 for you, or do you have employees of Freeman12 Reporting, Inc.?13 A No, sir. I'm a sole reporter.14 Sometimes I will help people find a reporter. Or I15 will -- if I need to be away, I will just give the job16 to somebody. I don't employ anybody. I have a17 typist, but she's under contract. You know, she's a18 contract worker.19 Q And what type of contract is she under?20 A I mean, we don't -- it's not a signed21 contract. But she just -- you know, she's not an22 employee. She's self-employed as well.23 Q You have an oral agreement with her?24 A Yes, sir.25 Q And does she do your -- all of your

Page 71 typing, primarily all of it, or would you explain?2 A It depends. It helps me to have her to3 type when I'm busy in court and so forth. It just4 depends. I send her some. I do some -- I do a lot of5 it myself.6 Q And who -- who is she?7 A Patricia Britt.8 Q And where does she live?9 A Oklahoma.

10 Q Say it again.11 A Oklahoma.12 Q And how does she get the material,13 working out of Oklahoma?14 A I mail her the recording, and she15 e-mails me the transcripts.16 Q And did she participate in preparation17 of any of the transcripts in the case of Harold --18 Harold Murphy against Nancy Michelle Murphy?19 A Not that I recall. I don't believe she20 did in any of those.21 Q So you think --22 A I think I did them all.23 Q You did it all.24 And what is your arrangement with the25 person in Oklahoma? How does that -- how does that

Page 81 work?2 A I pay her by the page.3 Q But does she work for a company or4 how --5 A No. No, she doesn't. As far as I know,6 I'm the only court reporter she types for.7 Q Okay. And how did you locate her?8 A I've just known her all my life.9 Q All right. And where did she live

10 before Oklahoma?11 A She's lived several places. Austin,12 Texas; Tallahassee, Florida; in Georgia.13 Q And where in Georgia did she live?14 A Washington.15 Q And -- and for the -- what year were you16 certified, the first year that you were certified as a17 reporter?18 A I believe 1996.19 Q And do you -- are you employed as the20 court reporter in the Coweta Judicial Circuit?21 A I am now, yes.22 Q And what period of time have you been23 employed in that capacity?24 A I have a hard time remembering this. I25 think it was in 1999.

Page 91 Q And who employed you?2 A Well, I'm self-employed, actually. But3 I've worked for two different judges.4 Q Okay. And what two judges have you5 worked for?6 A Allen Keeble and Quillian Baldwin.7 Q And what period of time have you worked8 for each of those judges?9 A All right. Best I can remember, I

10 started with Judge Keeble in 1999, and I think I11 worked with him through 2011. And I've worked with12 Judge Baldwin since the beginning of 2012, I believe.13 (Whereupon, a cell phone rang.)14 MR. FARMER: Just a second.15 Okay. The cell phones -- the cell16 phones are off. We had a cell phone17 interruption there.18 BY MR. FARMER:19 Q I got interrupted with the cell phone20 and diverted. You were telling me that you worked21 with Judge Keeble and --22 A Yes.23 Q -- then what?24 A I think I worked from him -- for him25 from 1999 till 2011 -- through 2011. In 2012 I began



to work for Judge Baldwin.2 Q And was it Judge Baldwin and3 Judge Keeble that selected you? Is that the basis for4 that employment? How does that work?5 A I don't really know. I think6 Judge Keeble's former court reporter was moving away7 and she suggested me. I don't really know the process8 because I was only involved in being employed. I9 don't know what went on behind the scenes.

10 Q All right. Do you have any special11 arrangement with them or just that you're going to12 do the -- you're going to do their work, or how does13 that work?14 A I'm not sure. I think -- I think that15 they maybe -- I'm not sure about this. Maybe they16 submit something to the State. I don't really know.17 Q And you -- as I understand, you receive18 a stipend from the State of Georgia; is that right?19 A Define "stipend." For you -- I mean, I20 know that -- I mean, I know what it means to me. What21 do you mean?22 Q It means -- what I'm trying to say, it23 means that you get money from the State of Georgia.24 A Yes, sir.25 Q And what money is that, and how does

Page 111 that money -- how do you get the money from the State2 of Georgia?3 A To my knowledge, the only thing I get4 from the State of Georgia is because of -- we go to5 five different counties. I get a small check because6 I go to five counties. That's all I know.7 Q And does that amount to around three to8 four thousand dollars a year in the last years?9 A That requires math. I'm not sure.

10 Q Okay. But it's -- the State -- the11 State -- I will show you this -- this State of Georgia12 record just so you can look at it. It shows that13 Freeman Reporting received $3,840 in 2013.14 A Okay.15 Q And it's DOAS-Court. I don't know what16 that means. Do you -- how did you apply for or how17 did you receive that money?18 A I don't know what that is.19 MR. GORDON: Department of20 Administrative Services.21 A Okay. I would say it's possibly the22 amount that I get from the State for the five counties23 I cover.24 BY MR. FARMER:25 Q And do you make an application -- when

Page 121 you say you, you mean Freeman Reporting? Is that what2 you mean?3 A Well, that's -- that's who gets the4 check.5 Q That's what I'm asking.6 A Yes, sir.7 Q Because it is a different entity from8 you individually. You understand that?9 A I do, right.

10 Q And then you understand in -- that you11 got $4,160 in 2010.12 A That's what that says. I don't -- I13 don't know.14 Q Okay. But is that -- is that consistent15 with your memory?16 A I never totaled it that I remember.17 Q And when do you receive that?18 Monthly?19 A Yes, sir.20 Q And is it a flat rate or is it part of21 a -- or is it part of a -- is it part of -- according22 to how much work you do or is it --23 A Honestly, I don't know. It comes with24 the job. And it's just a monthly amount.25 Q So it is a flat rate, not -- not --

Page 131 A Yes.2 Q -- according to how many jobs?3 A No, sir.4 Q I'm going to identify these two things5 as Plaintiff's Exhibit --6 MS. TUNKLE: It's just one. It's only7 one page.8 (Previously marked for identification,9 Plaintiff's Exhibit No. 2.)

10 BY MR. FARMER:11 Q One page. It's two copies. It's12 Plaintiff's Exhibit 2. If you will, just take a look13 at Plaintiff's Exhibit 2 and see if that's consistent14 with what -- the information you've been discussing15 with us. And it's on the -- projected on the screen.16 A What's -- what's on the screen, that's17 certain. I have no idea if that's the total I got a18 year or not, but that's what that says.19 Q And is that separate from other money20 that you receive?21 A Yes, sir.22 Q And do you receive -- do you receive23 other money from the County that's on a flat-fee24 basis?25 A I receive money from the Counties,



yes.2 Q And is it based on a flat fee?3 A Some is.4 Q It is?5 A Some of it is.6 Q Say it again.7 A Some of it is.8 Q Well, is some of it not?9 A Yes.

10 Q Okay. Explain to me that.11 A I get a per diem for the day that I'm in12 court from the County that I serve in that day, and13 then I get paid by the page for transcripts.14 Q Do you -- do you understand the basis15 for the -- for that pay?16 A I don't --17 Q Do you know how much you receive per18 day?19 A Yes, sir.20 Q And is that -- who is that set by?21 A I don't know. The State, I guess. I22 really don't know exactly who sets it.23 Q Do you know who sets the amount per page24 that you're paid?25 A Same entity. I don't know if it's the

Page 151 Board of Court Reporting or the legislature. I'm not2 sure.3 Q Do you keep up with that amount?4 A How do you mean?5 Q Do you -- are you familiar with what6 you're entitled to receive?7 A Oh, yes, sir.8 Q And will you explain to us how that --9 how much -- how does that work? If you go to court,

10 you're there a part of a day or if you go to --11 A I get paid a per diem for going that12 day. If we stay longer than a certain number of13 hours, I get more. I don't -- and I think it's more14 than eight hours I get a certain amount; more than15 nine, I get a little bit more. I don't remember those16 two amounts.17 Q Do you bill the County? Or who do you18 bill to get --19 A I bill the County.20 Q And what kind of billing records do you21 have for that?22 A I just have the invoices that I pay --23 that I send to them.24 Q Okay. So in these documents that we're25 requesting in this notice to bring to the deposition,

Page 161 you would have records to support that?2 A I believe so.3 Q And how do you itemize that to the4 County?5 A I itemize the per diem for how many days6 of -- usually I try to bill by the week. Sometimes --7 excuse me, sometimes -- anyway, I just bill by the day8 for the County. And then when I submit transcripts, I9 usually list the case and the case number and the

10 date, and then I -- the amount based on the pages.11 Q And do you get that in addition to what12 you're compensated by the parties if the parties buy13 the --14 A Well, that would be a civil case. The15 County has nothing to do with that.16 Q So you receive that amount only in17 criminal cases?18 A I think I charge the same page rate, but19 I don't bill the County for the civil -- civil20 transcripts. I bill them for the day that I'm in21 court but not for the transcript.22 Q All right. So let's -- so we understand23 it, on the per diem rates, you bill the County for24 both civil and criminal; am I correct?25 A Yes, sir. Yes, sir.

Page 171 Q And then, of course, for the criminal2 cases, you bill the County on the page limit,3 right?4 A Yes, sir.5 Q And is the page limit that you bill the6 County for, is it the same as the page limit that you7 bill individuals for?8 A Yes, sir.9 Q And do you bill the individuals for the

10 per diem rate?11 A No, sir.12 Q So the individuals do not pay the13 per diem rate for the County?14 A That's correct.15 Q And do you submit that to the judge for16 approval?17 A Yes, sir.18 Q And you submitted it in the case of John19 Harold Murphy versus Michelle Murphy?20 A Now, I have for the per diem. I do not21 submit my bill for a civil case transcript to him.22 Q All right. Do you submit the23 per diem --24 A Yes. I do that but not for the25 transcript --



Q And --2 A -- or for the takedown -- excuse me --3 or for the takedown in a civil case.4 Q So as I -- just so we're clear about it,5 in a civil case, the County does pay for you coming?6 A Providing for the court reporter. The7 County pays for me to be there.8 Q And the County is not reimbursed if the9 parties in the civil case pays you for the takedown or

10 anything like --11 A No, sir.12 Q The County is not reimbursed? That's13 just a --14 A No, sir.15 Q And if -- if the parties agree to pay16 for the takedown -- one of the parties agree to the17 takedown and then they order the transcript --18 A Uh-huh (affirmative).19 Q -- do you charge for the takedown plus20 the transcript, or do you just charge for the21 transcript?22 A For the takedown and the transcript.23 Q Two separate things?24 A Yes, sir.25 Q And how do you account for the time that

Page 191 you spend for the takedown?2 A I usually keep a record of it.3 Q Do you -- do you include that record in4 your billing?5 A Do you mean do I put down how many6 minutes it was or --7 Q Right.8 A No, I don't.9 Q And how does a person know how much time

10 is --11 A I usually keep a record of it, and I12 bill it. If they question me, I can go back and look.13 Q Okay. So you would have that record14 that you could --15 A I would assume so. I can't swear that I16 would have it on every one, but I would -- I would17 imagine I could or I could at least do the math to18 figure it out.19 Q So do you have it in the -- in the20 transcripts that we're dealing with, John Harold21 Murphy versus Michelle Murphy?22 A I can't answer. I don't know.23 Q Would you have originally kept it?24 A I believe so.25 Q And are you the record keeper?

Page 201 A Yes, sir.2 Q You do all of the record and all of the3 billing yourself?4 A Yes, sir.5 Q And do you -- so in the Murphy case, as6 I understand, you -- you did all of the --7 A To the best of my recollection, yes.8 Q To the best of your recollection?9 A Yes, sir.

10 Q You did both the record keeping and you11 did the actual typing of the transcripts?12 A I do believe I did. I'm not -- I can't13 say 100 percent, but I'm pretty sure I did.14 Q And in the takedown part of it, it's for15 the time that you actually were involved in taking16 down the --17 A To the best of my knowledge.18 Q And if two parties are a party to the19 case, is that divided --20 A Yes, sir.21 Q -- between the two parties?22 A I'm sorry. Yes, sir, it is.23 Q And explain that for the transcript and24 for the takedown. Explain to me how that works.25 A Okay.

Page 211 Q Let's say two parties in the case --2 A All right.3 Q -- and both -- and they split the --4 split the amount.5 A Okay. In this case, as I recall, I6 divided the takedown in half and charged each party7 for one-half the takedown. And in this case because8 you both -- both sides ordered the transcript pretty9 much on the same day, I remember the first day

10 discussing it, and I don't remember if I discussed it11 any more than that. But I do remember I divided -- I12 took everything and divided it by 2.13 In some cases the party that orders it14 first you would charge the copy -- I mean the original15 and two copies. Later the other party orders it, and16 I would charge them a copy rate.17 In this case, as I recall, you pretty18 much both ordered it at the same time, and I divided19 it in half so that each party paid the same amount.20 Q And if -- if in a -- if in a case21 involving someone else, say, not the Murphy case --22 A Uh-huh (affirmative).23 Q -- one party orders it and a week later24 or two weeks later the other party orders it, do25 you -- do you give the party the credit -- that



ordered it first credit for the -- when the other2 party pays for it?3 A I don't understand what you're asking.4 Q All right. It's not a very clear5 question.6 As I understand, if the person orders it7 afterwards, you're only charging for the copy?8 A As a rule, yes, I would say pretty much9 that's the case.

10 Q Okay. And is there any provision for11 that in the Rules, or how do you --12 A Not that I know of. But I don't think13 that's an uncommon practice.14 Q By uncommon practice, how do you --15 A Among court reporters. I do believe16 other court reporters bill that way, where they divide17 it totally in half.18 Q All right. I understand, the "totally19 in half" part.20 A Yes, okay.21 Q I'm talking about where one party orders22 it earlier.23 A Oh, yes, sir. And sometimes it's months24 later when the other party orders the copy.25 Q And so then if you order it later --

Page 231 A Yes.2 Q -- you only pay -- you only pay for one3 copy?4 A That's my understanding. I mean, that's5 how I charge. That's my understanding of the way it's6 supposed to be.7 Q And where do you obtain that8 understanding?9 A Well, I just know that the copy rate --

10 the original and two copies is one charge and the copy11 rate is another. And if the other party has already12 ordered it and I've submitted it to them, the other13 party is entitled to a copy if they participated in14 takedown.15 Q So the person that orders it first is16 charged at a higher rate?17 A As a rule. But in this case I divided18 it in half because --19 Q This case meaning Murphy v. Murphy?20 A -- yes, sir -- because pretty much it21 was ordered at the same time.22 (Previously marked for identification,23 Plaintiff's Exhibit No. 3.)24 BY MR. FARMER:25 Q I'm going to show you what I marked as

Page 241 Plaintiff's Exhibit --2 MR. FARMER: 4 are we up to?3 MS. TUNKLE: 3, I think.4 BY MR. FARMER:5 Q 3, 3. I'm going to -- I'm not going to6 mark this as an exhibit, but I'm going to show you the7 transcript of the proceedings.8 A Yes, sir.9 Q And I'm going to show you that. If you

10 prefer, here's a -- (hands document to the witness.)11 A This is fine.12 MR. GORDON: Yeah, we're okay.13 MR. FARMER: I'm trying to hand it to14 her.15 MR. GORDON: Oh, you're trying to hand16 it to her?17 MR. FARMER: Yes.18 BY MR. FARMER:19 Q And I'm going to ask, if you will, if20 you will explain --21 A Okay. Evidently in this one you ordered22 first. In the other -- it appears in this one -- I23 must have been mistaken. It appears in this one you24 must have ordered it first and I mailed you an25 original and one. I made a mistake, I guess, in that.

Page 251 That was from my memory.2 Q So that billing is incorrect? Is that3 what you're telling me?4 A No, sir. I'm saying I was incorrect5 when I said that I thought that I had to have every --6 Q All right. Do you have records to7 support the ordering of that transcript?8 A I'm not sure. I would have to look9 back. I don't know. I usually take an oral order.

10 And I may or may not have made a note. I don't know.11 You could have mailed me -- sent me an e-mail. I12 don't remember.13 Q Was there a division of the takedown in14 that -- on that occasion?15 A Yes, sir.16 Q And you're telling me that they did17 not -- that they did not order?18 A I'm saying from looking at this, it19 appears that they would have ordered it later. I20 don't know.21 Q Do you have records to support that?22 A I'd have to look and see.23 Q Can you provide those records for us?24 A I'll see if I can. I don't know that I25 do. I'll see.



I would say based on that, that that is2 what I did and that is what occurred.3 Q And do you have any -- do you have any4 rule to rely upon that allows you to do that?5 A Not that I'm -- not that I can think of6 right now.7 Q Are you familiar with the -- are you8 familiar with the basis for charging fees that the9 State has?

10 A I don't know that I know what you11 mean.12 Q Okay. The State controls the Board of13 Court Reporting --14 A Yes.15 Q -- through the Council -- the Superior16 Court judges? They control the fees; is that right?17 A As far as I know.18 Q And are you familiar with those rules?19 A I guess I am. I've told you what I20 understand.21 Q Okay. Have you examined the fees that22 you charged in the Murphy case to Michelle Murphy to23 see if you were in compliance with the Board of Court24 Reporters' rules?25 A When I made my bill, it was my

Page 271 understanding that I was --2 Q Okay. But since that time --3 A -- in compliance.4 Q -- we've said that you did not -- that5 you had not charged correctly. And I'm asking you,6 have you examined to see if you did charge7 correctly?8 A Based on the pages, I charged9 correctly.

10 Q Based on the fee that you collected, did11 you charge correctly?12 A Based on the fee that I charged by the13 page, I believe that I charged correctly.14 Q Well, did you charge incorrectly by any15 other basis?16 A Could you be more specific?17 Q Yes. The law, it's not just a page18 requirement. You understand that?19 A Yes, sir.20 Q It's other requirements --21 A Yes, sir.22 Q -- for the charges.23 A Uh-huh (affirmative).24 Q Have you looked at -- since you know25 that we said you didn't charge --

Page 281 A Yes, sir.2 Q -- that you overcharged --3 A Uh-huh (affirmative).4 Q -- have you looked to see if you5 overcharged?6 A Yes, I did.7 Q Yes, you did look or, yes, you did8 overcharge?9 A Yes, I did look.

10 Q Okay.11 A And it's my understanding that I made a12 mistake and that instead of having space for13 63 characters, I had space for 61. So it was two14 characters per line.15 Q And did that make a difference in the16 billing?17 A I think it probably would. It probably18 would. But it would just depend on the transcript as19 to what difference it would make because of20 different -- different --21 Q Did you calculate to see what difference22 that it would make?23 A It could be figured. Yes, sir.24 Q Did you figure it?25 A I have looked at it. Yes, sir.

Page 291 Q Okay. And what did you determine?2 A I can't tell you per transcript. But I3 recalculated, and it appeared to me it was less than4 $45.5 Q But you did --6 A -- for all of them.7 Q But you say you -- that's what you8 calculated? You overcharged by $45?9 A If I reconfigured the page, it appeared

10 that that's what it would be.11 Q And when did you reconfigure -- when did12 you make those calculations?13 A Within the last two or three months. I14 don't know. I don't know the date.15 Q Was that after the complaint was16 filed?17 A Yes, sir.18 Q And did you calculate the reason for19 that overcharge?20 A As I said, instead of having space for21 63 characters on a line, I had space for 61.22 Q And how did you -- how do you make those23 determinations of what you had?24 A I counted per space on a line.25 Q And when you -- before you billed it,



how did you make the calculation?2 A I just used the template that I had set3 up. And evidently at some point it was set up4 incorrectly.5 Q Okay. What kind of template do you6 have?7 A It's just something I've had set up a8 long time. I had -- when I bought my first computer,9 I had help. I had to learn Word. I used Microsoft

10 Word.11 Q Okay. Which version? 210?12 A I've used different ones but --13 Q Okay. When you first set it up.14 A This would be a much earlier version. I15 don't know what version it was.16 Q Okay.17 A And I've continued to use that. I18 just -- I found out from the person I bought my19 computer from -- somebody in their office. The person20 I bought it from didn't know anything about Word, but21 there was somebody in the office that showed me the22 legal template. And I just used it and kind of had to23 figure it out myself.24 I was new in LaGrange. I didn't know25 anybody. I was new in LaGrange. I didn't know

Page 311 anybody to ask. I didn't really know anybody. I just2 set it up by myself. I remember counting spaces. I3 remember working to get the thing set up.4 And at some point I guess inadvertently5 it changed from 63 to 61. I don't know. I don't6 really know when -- when -- I don't know when it7 became 61 characters. I don't know if it was from the8 beginning or when. I don't know.9 Q And who did you buy the computer from?

10 A I don't remember. It's the company11 that's been out of business. I can tell you where12 they were located many years ago, but --13 Q All right.14 A -- they've been out of business for a15 long time.16 Q Where were they located?17 A LaGrange.18 Q And where in LaGrange?19 A Off of Whitesville Road on Lukken20 Industrial Boulevard.21 Q And when you set it up, did you continue22 using the same program all the way through when you23 did the Murphy case?24 A Well, I -- oh, with the Murphy case,25 yes, sir, as far as I remember.

Page 321 Q Okay. From the time you had the2 computer?3 A I just used -- as far as I remember, I4 haven't changed the template -- I used the -- I used5 the same version as far as I remember.6 Q For approximately how many years?7 A The whole time I've been a court8 reporter probably.9 Q And since we don't know that, tell us.

10 A Well, I said 1996.11 Q Okay. Since 1996?12 A As far as I know, yes.13 Q And you've used the same version of14 Word?15 A No, sir. I've just used the same16 template.17 Q The same template?18 A Yes, sir.19 Q And what font do you use?20 A 12. 12 Courier. Whatever that --21 whatever the Courier is and 12, size 12, whatever that22 is.23 Q Okay. And what version of Word did you24 use in preparing the Murphy transcripts?25 A I'm not sure. Maybe 2010. I'm not

Page 331 sure.2 Q And what version do you use now?3 A Same.4 Q And do you use the same template now?5 A Yes, sir. Well, I've changed it now,6 but I --7 Q How did you change the template?8 A I changed the left margin by two spaces,9 or to allow for two more spaces.

10 Q And is that -- did you use the same11 template in preparing the criminal transcripts for the12 State?13 A Pretty much, yes, sir.14 Q During all that time?15 A Yes, sir.16 Q So you would have overcharged them the17 same as you did --18 A I don't know. I don't know -- I don't19 know. I haven't gone back to count spaces on every20 transcript. I don't know.21 Q You see the requests that we have made.22 Do you have those transcripts?23 A I should.24 Q All of the transcripts for the State?25 A As far as I know, yes. Well, not for



the State but for the Counties, yes.2 Q For the Counties?3 A Yes, sir.4 Q And so all of those would be5 available?6 A As far as I know, yes.7 Q And who approves of the payment to the8 County?9 A I submit my bill to the judge. And he

10 signs it, but he does --11 Q The judge meaning? By name who?12 A Well at first, it was Allen Keeble.13 Q All right.14 A Now it is Quillian Baldwin. And15 sometimes it might be a senior judge if I reported for16 him.17 Q But you submit it to Judge Baldwin?18 A Yes, sir.19 Q And does -- how do you submit the --20 the -- how do you submit the billings to21 Judge Baldwin?22 A I just give it to him, and he signs it.23 And then I submit it to the County.24 Q Are you with him when he signs them?25 A I can't say I've been with him every

Page 351 time.2 Q No. I mean --3 A I might have left them with the4 secretary. But usually he signs it in my presence.5 Q Okay. And what does he do as far as6 checking it?7 A Well, he doesn't go through the8 transcripts and count the pages.9 Q Has he ever looked at -- has he ever

10 looked at the transcripts?11 A Not to my knowledge except what he sees12 in court.13 Q Okay. But what I'm saying is, he's14 never seen that you comply with the law?15 A Not to my knowledge.16 Q And has anybody ever brought it to your17 attention that you don't comply with the law other18 than in the case we brought against you?19 A Never.20 Q Have you ever been audited by the21 County?22 A No, sir.23 Q They have never made any audit to the24 County?25 A Not to my knowledge.

Page 361 Q When we first brought this to2 Judge Baldwin's attention or he first -- I don't know3 whether we brought it to his attention or he heard it4 from somebody that you would probably be subject to5 litigation about this --6 A Yes, sir.7 Q Do you remember that?8 A Of course.9 Q And did you bring it to his attention?

10 A Yes, sir.11 Q And what did he say at that time?12 A Goodness, I don't remember.13 Q Well, about what -- what was the --14 what was the gist of the conversation?15 A I can't tell you. I don't remember.16 Q How did you bring it to his attention?17 A I went to his office as far as I know.18 No. I believe we talked on the phone.19 Q You called him on the phone?20 A I did not. But he called me.21 Q Okay. What did he --22 A That's the best of my memory.23 Q Okay.24 A I don't really remember exactly.25 Q Okay. Anyway, y'all communicated?

Page 371 A Yes, sir.2 Q And what was that communication?3 A I really don't remember, Mr. Farmer.4 Q Okay. Well, it had to be something.5 A I just told him -- I honestly do not6 remember what he said.7 Q Okay. But how did the conversation8 begin?9 A I honestly do not remember. I remember

10 I told him.11 Q And did you tell him you couldn't afford12 the litigation?13 A I don't think I needed to tell him, but14 I don't remember.15 Q Did -- did he tell you he would do16 anything about it?17 A I don't remember that he told me he18 would do anything about it.19 Q Was there any kind of understanding that20 he was going to do something about it?21 A I really don't think so.22 Q Did you request that he did anything --23 do anything about it, or did he do it on his own?24 A I can't -- I don't believe I would have25 asked him to do anything about it.



MR. FARMER: I'm going to ask you to2 mark this as Plaintiff's Exhibit 4.3 (Whereupon, marked for identification,4 Plaintiff's Exhibit No. 4.)5 BY MR. FARMER:6 Q I ask you to take a look at Plaintiff's7 Exhibit 4 and see if you can -- if you can read that8 and tell me if you've seen that document before.9 A I have seen this before.

10 Q All right. And when was the first time11 that you had seen it or learned anything about it?12 A I guess when I was copied on it.13 Q Okay. And did Judge Baldwin copy you on14 it?15 A His secretary did.16 Q And we're talking about Plaintiff's17 Exhibit 4? He sent you a copy of that?18 A Yes, sir.19 Q It's on the screen. And are the20 statements in there correct? (Reading) Nan Freeman21 discussed with me your latest e-mail -- our latest22 e-mails back and forth; is that correct?23 A Yes, that's correct.24 Q And --25 A And I was deeply concerned.

Page 391 Q Say it again.2 A And I was deeply concerned.3 Q Okay. In the second paragraph -- is4 that -- is that statement in the second paragraph5 correct?6 A It is. But I -- before this I think I7 suggested to you that I -- that's how I would like to8 do it, to put a sealed copy in the Clerk's file.9 Q But not give it to me for my use as I

10 chose?11 A That's correct because I didn't think it12 should be disseminated in any manner, taken out of --13 anything taken out of context.14 Q The third paragraph.15 A I believe that's what he decided to16 do.17 Q Is that true and correct?18 A As far as I know.19 Q And the last paragraph or20 next-to-the-last paragraph.21 A Well, that's what he said.22 Q And did you have a conversation with him23 after this?24 A I've talked to him a lot after this.25 Q About this incident.

Page 401 A I remember -- do you mean after the2 e-mail or after he filed those?3 Q We're going to go through all of it, so4 you can begin after the e-mail and then after5 everything else.6 A Well, I'm sure we did. I don't remember7 a specific conversation. I don't remember a specific8 conversation.9 Q But I'm not asking about specific

10 conversations. Did you discuss it with him?11 A Well, I just expect we did, but I12 can't -- I do not have a firm recollection of a13 particular -- any particular conversation.14 Q And the part in here about "Ms. Freeman,15 she will not voluntarily give you directly or file16 with the Clerk's office copies of the audio17 recording" --18 A That's what he said.19 Q Well, is that true?20 A At that time it was true.21 Q Was it true after the hearing on that22 day? Did I approach you and ask you to let me23 purchase those audio recordings on the -- after the24 27th hearing?25 A The 27th of?

Page 411 Q May.2 A Yes, you did.3 Q And did you respond to me when I --4 A I said no. And you asked why. And I5 said, because I don't believe I'm required to.6 Q And did I ask you politely to let me7 purchase them?8 A You asked me. I won't say it was9 impolite.

10 Q Did I say "please, Nan"?11 A I don't remember.12 Q Would you like -- would you like to hear13 the audio on that?14 A I've heard it before. But I don't15 remember if you said the word "please."16 Q Okay. You wouldn't dispute it if you17 heard the audio of that request?18 A If I heard the audio, no, sir, I would19 not.20 MS. TUNKLE: Do you want to play it?21 You said "Nan, please."22 THE WITNESS: I don't dispute that he23 said "please."24 BY MR. FARMER:25 Q All right.



A I just don't remember that you -- I do2 not remember that you said "please."3 Q Okay, good enough. But you're not4 disputing it?5 A I'm not disputing it. I don't know6 whether you did or not.7 Q Okay, okay. And you would not let me8 have it?9 A I would not. I did not release it that

10 day. No, sir.11 Q And -- and you weren't going to release12 it until something was done to make you release it; is13 that right?14 A That is probably not true.15 Q What were you -- what were you -- when16 were you going to release it to me without me doing17 anything to require you to do it?18 A When you said you were going to sue me,19 I decided it was not worth it. And so I decided at20 that point that I would like to give it to you to21 avoid a lawsuit.22 Q Okay. So until I said that I was going23 to sue you, you were not going to do it.24 A Well, it's my understanding that I25 wasn't required to.

Page 431 Q Okay. But you weren't going to do it2 unless I sued you or unless I threatened --3 A I won't --4 Q -- to sue you?5 A -- say that. But I did not want to be6 sued, and so I didn't think it was worth it.7 Q Okay.8 A So I was willing to release it. Because9 it was my work product and it was mine, if I wanted

10 to, I could.11 Q Okay. Did you discuss with anybody that12 gave you the opinion that you're not required to13 release it?14 A Did I discuss with anybody --15 Q Yes.16 A -- that I was not required -- well, I17 did talk to Judge Baldwin about it but --18 Q What did Judge Baldwin say?19 A He said different things at different20 times.21 Q Okay. What did he say about that?22 A First he said he didn't care if I did or23 not. Another time he said he wasn't going to let me.24 And another time he said that he would do it.25 Q Was he discussing it with someone else

Page 441 that was giving him advice about it?2 A I can't answer that. I don't know.3 Q Well, did he indicate to you that he4 would?5 A Discuss it with someone?6 Q Yeah.7 A Not that I recall.8 Q Was the information that I wanted to9 get, was it something that was different from what was

10 in the transcript?11 A I don't know what you wanted to get.12 Q Okay. Did the audio depict something13 differently than what I could have obtained by reading14 the transcript?15 A It's my opinion that it did not.16 Q So it's your opinion that when you first17 released the transcript, you gave everything to us?18 A I don't know what you mean by that.19 Q All right.20 A I did not give you the recording.21 Q Okay. Did you give us all of the22 information that took place up until -- before -- that23 there was a request for a Freedom of Information24 request obtained in the transcript from --25 A I don't understand the question at

Page 451 all.2 Q Okay. Did you leave out part of the3 testimony? Did you leave out "blame yourself, blame4 yourself, blame yourself"? Did you leave that out?5 A I don't remember.6 Q Okay.7 A I don't know what -- I don't know.8 Q Okay. If you will, I'm going to show9 you this transcript of the hearing, and I'm going to

10 ask -- see if you certified that to be correct.11 A Yes, I did.12 Q Is the "blame yourself, blame yourself"13 in there?14 A I'll have to read it.15 Q Read it. Look toward the end.16 A Pardon me?17 Q Look toward the end and --18 A Well, how will I know --19 Q Okay. Wherever you would like. I was20 just --21 A Would it be what the judge said?22 Q Yes.23 MR. GORDON: I'm going to step out one24 minute --25 MR. FARMER: Yes.



MR. GORDON: -- while she reviews that.2 MR. FARMER: Do you want to take a3 break?4 MR. GORDON: No. I'm good.5 MR. FARMER: Okay.6 MR. GORDON: I want to speak to my7 secretary a minute.8 MR. FARMER: Okay, good. We won't do9 anything too damning till you get back.

10 MR. GORDON: Can you make some11 representations to her as to the fact that what12 you're looking for is not in this transcript to13 kind of speed this up a little bit?14 MR. FARMER: It absolutely is not.15 MR. GORDON: Okay.16 MR. FARMER: She absolutely left out17 stuff. Let's put it that way --18 MR. GORDON. Okay. She's looking for19 that conversation that you mentioned a moment20 ago --21 MR. FARMER: Right.22 MR. GORDON: -- between you and the23 judge?24 MR. FARMER: Between the judge and the25 lawyers and Michelle Murphy.

Page 471 MR. GORDON: Okay. And did you go back2 and -- after you got the recordings have those3 parts that -- the missing transcript4 transcribed?5 MR. FARMER: We'll -- let me get -- I'll6 get to it.7 MR. GORDON: Okay. I was just trying to8 help move forward.9 MR. FARMER: Yeah, I know. I know it.

10 But I just want to make sure she's clear about11 this admission.12 A I don't see "blame yourself, blame13 yourself, blame yourself."14 BY MR. FARMER:15 Q Was that a rather dramatic point in the16 transcript?17 A I don't see it in here.18 Q Can I -- let me let you listen to it --19 A Okay.20 Q -- and see if you can -- just a second.21 And you did take down this part of22 the -- you used -- what type of recording method were23 you using?24 A I'm a voice writer.25 Q Say it again.

Page 481 A I'm a voice writer.2 Q Okay. Meaning that you speak into a3 microphone and have an audio recording of it?4 A Yes, sir.5 Q And you did type this yourself?6 A As far as I remember.7 Q So you were there when it took place?8 (Audio recording played.)9 BY MR. FARMER:

10 Q You did hear "please"?11 A Of course. And I didn't deny you said12 that. I just didn't --13 Q Okay. I just wanted to make sure you --14 A -- remember the -- I did not remember15 verbatim.16 Q Okay. You do -- do you now remember17 that taking place, "blame yourself," in the courtroom?18 A I think I do. But I must have already19 been -- the judge must have already said we were off20 the record or that the case was over.21 Q Did you hear that?22 A I did hear that.23 Q Do you see any place that says he's off24 the record?25 A Not in this trans -- oh, not -- well, I

Page 491 have this where he says, I'm sorry, that's the end of2 this hearing today.3 Q Did you record this?4 A It's on -- it's on my digital recording.5 My digital recording, I mean, it also -- it also6 records what you said to me afterwards, and that7 wasn't part of the proceedings.8 Q But you did -- you did see that? You9 did have this in your digital recording?

10 A Yes, sir.11 Q And you didn't transcribe it?12 A Not to my knowledge. Is this the one13 where I did an amended transcript?14 Q You certified it was a complete record.15 A I did. And I admitted the mistake, and16 I corrected it by an amended transcript.17 (Whereupon, marked for identification,18 Plaintiff's Exhibit No. 5.)19 BY MR. FARMER:20 Q I'm going to show you Plaintiff's21 Exhibit 5, and I'm going to ask you if that is your22 certification it's complete?23 A Yes. It's the certificate that's on the24 back of this, but I also --25 Q "Back of this" meaning?



A "Back of this" meaning this transcript2 of May 27th, 2014. But I also submitted an amended3 transcript. And I admitted that I made an error, and4 I submitted an amended transcript or an addendum.5 Q Now --6 A I believe I called it an addendum.7 Q Did you do that -- I'm going to show you8 this. Did you do that before there was a Freedom of9 Information request by Larry King for this document?

10 A No, sir. I don't believe I did. I11 believe that I -- I believe I was not aware until I12 received that from Mr. King.13 (Whereupon, marked for identification,14 Plaintiff's Exhibit No. 6.)15 BY MR. FARMER:16 Q I'm going to show you what's been marked17 for purposes of identification 6 and ask you if that18 is the Freedom of Information request that was19 necessary to be made to get this part of the20 transcript.21 A As far as I recollect, yes.22 Q And I'm going to show you Plaintiff's23 Exhibit 7 --24 (Whereupon, marked for identification,25 Plaintiff's Exhibit No. 7.)

Page 511 BY MR. FARMER:2 Q -- and ask if you can identify that3 document to us. It is the letter that you wrote to4 Larry King.5 A That appears to be the letter I sent to6 him.7 Q Do you have any question about that8 being --9 A It looks to be the same.

10 Q And I'm going to show you a document11 that we would identify as Plaintiff's Exhibit 8 and12 see if you can identify this as a document that you13 sent.14 (Whereupon, marked for identification,15 Plaintiff's Exhibit No. 8.)16 A It appears to be.17 BY MR. FARMER:18 Q Did you certify that document?19 A I believe I did.20 Q Would you show me the certification?21 A It appears to me that this is the one22 that I sent by e-mail. And I wouldn't necessarily put23 a certificate on an e-mail, a transcript I send out by24 e-mail.25 Q Okay. Well, where is the certificate?

Page 521 A It would be on the hard copy that I2 mailed to you and it would be on the hard copy that I3 mailed to Mr. Drake and it would be on the hard copy4 that was submitted to the Clerk.5 Q All right. Can you -- can you show me6 where -- will that -- will you produce that hard copy7 to me? Do you have a copy of it?8 A I should have. Not with me. I don't9 have it with me.

10 Q Okay. Is it filed with the Court?11 A It's my understanding it is. I mailed12 it to be.13 Q And was there a certificate on it?14 A I would expect so.15 Q And can you provide that certificate?16 A Not today.17 Q Okay. But you will provide it?18 A I would think so, yes. As far as I19 know, I can provide it.20 Q Now, this is the case in which there21 were a number of motions to disqualify the judge.22 You're familiar with that?23 A I don't -- I don't know too much about24 what goes on outside the courtroom.25 Q Well, in the courtroom you know there

Page 531 were -- there were -- there was a lot of efforts to2 disqualify Judge Baldwin? You know that, don't you?3 A I know that you did try to disqualify4 him. I do not know how many motions you filed. I5 don't -- I don't -- I haven't looked through that6 trial.7 Q I understand. But you know there was a8 big issue about disqualifying him, right?9 A Well, I've heard you say that, yes.

10 Q Okay. And you believe it, don't you?11 A I have no reason to disbelieve it, but I12 don't know.13 Q Okay. But you know that was a big --14 that was an issue in the case?15 A I know that was an issue in the case.16 Q And you know that this was a crucial17 point in the case, in which custody of the children18 was transferred that you omitted from the record,19 right?20 A I don't understand.21 Q Okay. The "blame yourself," you know22 that's when the children were being taken away by the23 deputy sheriffs.24 A Okay.25 Q You remember that?



A I remember that, yes.2 Q You remember the deputy sheriffs were3 there in the courtroom taking the children away,4 snatching them away from Ms. Murphy?5 A I didn't witness that. That was not in6 the courtroom.7 Q You were not in the courtroom when this8 took place?9 A I was in the courtroom, but I never saw

10 the children that I remember.11 Q Okay. Did you see --12 A I think that was all outside the13 courtroom as far as I know.14 Q Okay. But did you see the deputies15 being ordered to take them?16 A Yes.17 Q You heard that, Judge Baldwin ordering18 the deputies to take the children?19 A I believe I did. I don't believe it's20 in the transcript.21 Q So you know that that segment of what22 took place in the courtroom, you know that that23 segment is relevant to his demeanor and to his ability24 to treat both sides fairly?25 A I can see where you -- where that would

Page 551 be your understanding. If the judge had told me that2 the case was over, I would have probably stopped.3 Q But you knew after that that the4 hollering was -- it wasn't over when he was still5 hollering at the people, didn't you?6 A I don't remember. I really don't7 remember.8 Q Well, you knew it would be relevant to9 us to have him hollering like that at us and hollering

10 like that at our client Ms. Murphy?11 A I can see where you would say that,12 yes.13 Q That's all I'm saying.14 A I can see where you would --15 Q You could see --16 A I can see where you would say that.17 Q And in representing her, you could see18 where it would be fair for me to say that in19 representing her, can't you?20 A Where you would -- where you would --21 Q Where it was the lawyer's duty to do22 that in representing her, you would say that, wouldn't23 you?24 A I'm not an attorney. I can't answer25 that.

Page 561 Q Okay. Had you -- does Judge Baldwin2 holler like that frequently at people?3 A I can't say that. I don't -- not --4 not --5 Q Well, you're there. You're his6 reporter. Does he?7 A I don't think so. I don't know. I8 mean, I've -- I've -- I've heard him raise his voice9 more than once, but I can't say --

10 Q I know you heard him raise his voice one11 other time to me when you went to get the -- to get12 him to prevent from us taking down the call of the13 calendar, didn't you? You heard it that day, didn't14 you?15 A I don't remember his raising his voice16 about that.17 Q Okay. Let -- just a second. Let me see18 if I can play that for you.19 You remember when we had a hearing and I20 said -- I came to you before the hearing and I said I21 would like for you to take down the call of the22 calendar? You remember that day, don't you?23 A I remember you doing that twice.24 Q Okay. And --25 (Audio recording played.)

Page 571 BY MR. FARMER:2 Q So you -- he was hollering at me on that3 day, right?4 A He had raised his voice, yes.5 Q Would you say he was substantially6 raising his voice?7 A That's a matter of opinion, I guess.8 Q Okay. In the matter of your opinion,9 how would you say?

10 A It was louder than his normal voice.11 Q Was -- do you remember the courtroom12 being full of other lawyers and other people waiting13 to have their case heard?14 A It was a calendar -- it was a calendar15 call, so yes. I mean, all the cases that were on the16 calendar and the people that were present that day17 were in the courtroom, yes.18 Q It wasn't necessary for him to holler19 that loud for me to hear him, was it?20 A I don't know. I would say you didn't21 respond the first time or the second time.22 Q So you say that he was justified in23 hollering? Is that what you're trying to say?24 A No. I'm not -- I'm just saying25 that maybe he wanted -- I don't know what Judge --



what was in Judge Baldwin's mind. I don't know.2 Q But you know he wasn't acting in a3 normal manner in hollering like that at me at a bench4 conference? We were at a bench conference, right?5 A Yes, sir.6 Q We were standing a few feet away from7 him, right?8 A Yes, sir.9 Q And I wasn't jumping up and down and

10 flapping my arms at him or anything like that, was11 I?12 A Not that I remember.13 Q All right. I wouldn't do that. You14 don't see me do things like that, do you?15 A I've never seen you flap your arms,16 no.17 Q Okay. Well, so -- and you heard him18 threaten to put me in jail, didn't you?19 A I heard that at the bench -- I mean, I20 heard it on that recording, but it was at a bench21 conference.22 Q Right. And -- and all of that started23 with me asking you before the hearing started, would24 you please take down the calendar call?25 A I don't know that that's what --

1 Q You remember before the hearing started2 I came to you and said --3 A Yes. I --4 Q -- Nan, would you please take down?5 A Yes.6 Q And you had done that on a previous7 occasion for me?8 A Yes, sir.9 Q You had taken down the call of the

10 calendar?11 A Yes, sir.12 Q And -- and so what happened after I13 asked you to please take down the call of the calendar14 and I would pay you?15 A The first time, I took it down.16 Q No, the second time.17 A Second time.18 Q This "do you understand" hollering time.19 A You asked me. And the judge said he20 wasn't going to have the calendar call taken down.21 Q Okay. Well, where did you go after --22 where did you go after I asked you to take it down?23 A I'm sure I went in the back.24 Q Okay. Who did you go in the back and25 see?

Page 601 A Well, I did tell the judge that you2 asked --3 Q All right. That's what --4 A -- for the calendar call.5 Q -- I'm getting at.6 A I told him the first time, and I told7 him the second time.8 Q Okay. What did he say the second9 time?

10 A I really do not remember.11 Q Okay. Well, what did he say the first12 time?13 A I don't remember.14 Q Okay. Well, why was it a big -- why was15 it a big thing about it taken down the second time?16 A I have no idea.17 Q Why -- why didn't you want to take it18 down?19 A I don't know what you mean by that. If20 the judge -- I mean, if the judge -- I would not have21 not taken it down.22 Q Okay. Well, why didn't you take it down23 then?24 A Because the judge told you in the25 courtroom that we weren't going to take it down.

Page 611 Q Okay. But he told me that after you2 went and had a conference with him, right?3 A It was after I went and had -- after I4 told him that, yes.5 Q Okay, yes. Well, why did -- why did he6 not want to take it down?7 A I don't -- I can't answer for him.8 Q Do you understand there's an issue in9 this case about judge shopping and about judge

10 selecting of cases? Do you understand that, that11 there was -- that what happens is that the judge12 selects who he chooses to give a particular case to13 and that the lawyers select who they want -- what14 judge they want to hear the case? Do you understand15 that to be an issue?16 A I'm not privy to any of that, but I17 understand that that's what you say.18 Q Okay. That's all I'm asking. You19 understand that that was the issue that I was20 raising?21 A I understand that's what you say, yes.22 Q And you understand that taking down the23 calendar call is something that would document that24 supporting information that I was trying to obtain?25 Do you understand that?



A I understand that's what you're saying.2 I don't know if --3 Q Okay.4 A I don't know if it could be used for5 that or not.6 Q I understand. I'm not asking you to do7 the -- I'm not asking you to do -- let me play you a8 little bit of the first part when he comes out so you9 will understand a little bit.

10 (Audio recording played.)11 BY MR. FARMER:12 Q So what I understand is, this was13 Judge Baldwin not wanting the record taken down, not14 you not wanting to take it down.15 A I don't know a court reporter that would16 delight in taking down a calendar call. That's a hard17 thing to do.18 Q Okay. I'm not --19 A But if I had been -- if -- if the judge20 had wanted it taken down or he had not said we're not21 going to take it down, I would have taken it down --22 Q Okay.23 A -- at your request.24 Q Okay. So did you attempt to keep it25 from being taken down?

Page 631 A Not to my knowledge.2 Q Okay. So it was Judge Baldwin's3 decision that he wasn't going to let you take down the4 -- not going to have a record of the call of the5 calendar?6 A I would not tell the judge what to do.7 Q I understand. So I just want to make8 sure. It was his decision and not your decision?9 A Of course. I would not tell the judge

10 what to do.11 Q And you had been around a lot of12 calendar calls for Judge Baldwin, and you've been in13 the Superior Court of Coweta County and other courts14 in the Coweta Judicial Circuit a long number of times,15 right?16 A Yes, sir, but not as many with17 Judge Baldwin.18 Q But a substantial number?19 A Probably so by that time.20 Q And you know that when they call the21 calendar, Judge Baldwin says who the case -- who --22 which one they're going -- you go let Judge so-and-so23 hear this case; is that right?24 A No, sir, not to my knowledge. I don't25 remember him saying, you go to this judge or that

Page 641 judge.2 Q They all stay in there? They don't --3 they all stay in the same room and are heard by him;4 is that right?5 A Honestly, I don't pay that much6 attention to the calendar call.7 Q But you understand that the cases are8 assigned for a hearing at the calendar call? If9 they're in there for a hearing, they're assigned for

10 who's going to hear them, right? They have more than11 one judge there when they have a call of the calendar,12 right?13 A Not every time, no, sir.14 Q Okay. But sometimes they do, right?15 A They have been. But since I believe16 2013 cases are assigned.17 Q Yeah, since we brought the issue.18 A I don't know --19 Q Okay. I understand.20 A -- about that. I don't know about21 that.22 Q I understand. After we -- after we23 brought the issue and had to appeal it, I understand24 they changed the calendar -- the --25 A I don't know anything about that. That

Page 651 has happened all outside my presence and outside my2 knowledge.3 Q Okay. I'm not asking you about that.4 But before that time they did assign them to different5 judges at the calendar call?6 A I don't know that. I don't know how7 they --8 Q You didn't ever see it done?9 A I don't know if I did or not. I was not

10 paying attention. I didn't think that was relevant to11 me. I just -- I took down the cases that came before12 the judge I was working for that day.13 Q And you've never seen them assign the14 case to a judge other than the one that's calling the15 calendar?16 A I can't say that. As I say --17 Q Right.18 A -- I did not pay attention. It could19 have happened. I don't know.20 Q Okay. But I understand that in 2013 you21 say it changed.22 A I believe that's the year that they --23 they changed it. I don't know.24 Q They started a judge -- they started a25 case management --



A I don't know. That -- that does not --2 that is not something I'm included in. I just know3 that they started what they said was case assignment.4 That doesn't -- it doesn't really affect me except5 that I take down what the judge that I work for that6 day hears. That's all I know.7 Q So if you're there for Judge Baldwin8 calling the calendar and the case goes to another9 judge, you don't take it down?

10 A I don't take it down if it's before11 another judge, no, sir, because I'm not in that12 courtroom.13 Q And is there another reporter assigned14 to the other judge?15 A I would think so.16 Q But do you know?17 A I'm not in that courtroom. I can't say.18 But I would assume that that judge would have a court19 reporter.20 Q I want to show you an invoice, and I21 want you to explain this to me, if you will.22 MR. FARMER: This is going to be23 Plaintiff's Exhibit 9.24 (Whereupon, marked for identification,25 Plaintiff's Exhibit No. 9.)

Page 671 MR. FARMER: Y'all need to take a break?2 MR. GORDON: Yeah, before or after this3 exhibit. It's your choice.4 MR. FARMER: You can take it now.5 MR. GORDON: Huh?6 MR. FARMER: You can take it now.7 MR. GORDON: Okay.8 Just hold on.9 THE WITNESS: Okay.

10 THE VIDEOGRAPHER: This is the end of11 Video 1. We're going off the record at12 11:06 a.m.13 (Whereupon, a recess was taken.)14 THE VIDEOGRAPHER: We are back on the15 record. This is the beginning of Video 2 at16 11:14 a.m.17 BY MR. FARMER:18 Q You do understand that having the call19 of the calendar taken down, that that would be a20 relevant bit of information to determine if the -- if21 the judges were taking the case according to a case22 management plan or if they were taking it -- randomly23 assigning them when the calendar was called? You24 could understand that? That would document it?25 That's all I'm asking.

Page 681 A If it had been assigned to a different2 judge, I guess it would. But I don't -- I just -- I3 don't know. Like I say, I don't pay attention to the4 calendar call. It doesn't -- it doesn't affect me as5 a rule.6 Q But -- so you don't -- you didn't even7 know that there was a case management plan before the8 2013 era after that?9 A I just knew that I went with a judge to

10 a courtroom for his calendar call and for the cases11 that he heard that day. I -- it just didn't -- it12 didn't apply to me. All I knew was to take down the13 cases that I was asked to take down before that14 particular judge.15 Q But you knew it was an issue for me to16 have it taken down, to have the call of the --17 A At some point I think -- I'm sorry. I18 didn't mean to interrupt. At some point I think I19 realized that from you, but I don't really -- I don't20 know. I just -- it didn't appear to apply to me21 except if you wanted it taken down. And if the judge22 had wanted -- had -- the judge said he wasn't going to23 have it taken down, so I didn't take it down the24 second time.25 Q Can you imagine any reason for the judge

Page 691 not having it taken down?2 A I don't think I should be thinking what3 the judge would be -- me try to tell you what the4 judge is thinking. I don't know.5 Q Okay. Had he ever told you before not6 to take down a calendar call?7 A I had never been asked to except the one8 time by you, and he did not tell me not to that9 time.

10 Q So after he saw it was being used is11 when he said, don't take it down?12 A No, sir. He said -- I did not know --13 as far as I remember, I did not know until we got in14 the courtroom that I would not be taking it down.15 Q But you knew you had requested --16 A I knew that you had requested it, yes.17 Q And you knew that Nan Freeman had18 requested to Judge -- had alerted Judge Baldwin that I19 wanted it taken down?20 A I did tell Judge Baldwin you wanted it21 taken down. "Alert," I don't know. That's your22 word.23 Q Okay. And did he say anything about24 what he was going to do?25 A I don't recall his saying anything about



what he was going to do. I don't recall. To the best2 of my recollection, I went in the courtroom and I was3 going to take it down. But I cannot say that for4 sure.5 Q So it was totally Judge Baldwin6 preventing it being taken down?7 A Well, I just would not tell the judge8 what to do.9 Q Right. So you assume that you were told

10 not to take it down?11 A All I remember is him calling y'all to12 the bench for a bench conference.13 Q And did you know what happened as a14 result of that?15 A I did not take down the calendar call.16 Q Okay. And was it because he told you17 not to?18 A He did not look at me and say, Nan,19 we're not -- I'm not going to have you take down the20 calendar call that I remember. What I remember was,21 he said, we're not going to have the calendar call22 taken down. But I don't know that he said it -- I23 don't know that he addressed that to me.24 Q He said it to me.25 A That's what I remember from that

Page 711 recording.2 Q Okay. And when he was hollering "do you3 understand," he was hollering at me, right?4 A I would say the recording speaks for5 itself. I don't know.6 Q And what would it speak to itself? Was7 it to somebody else he was speaking?8 A If you were the person he was asking if9 you understood and you didn't answer, I guess that's

10 who he was saying it to.11 Q What was it for me to understand about12 him saying he wasn't going to do it?13 A I don't remember. He said something.14 And he said, do you understand? I don't remember what15 exactly came before that.16 Q Did he say, I'm going to put -- he was17 asking me did I understand that he was going to put me18 in jail.19 A Oh, is that what he said? Okay. I20 don't remember exactly what he said before that.21 Q Had you ever seen him put anybody in22 jail or ordered them held in contempt of court and23 taken into custody?24 A Probably. But I don't specifically --25 Q Attorneys.

Page 721 A -- remember.2 Q Attorneys.3 A One.4 Q Which one?5 A Larry King.6 MR. GORDON: Say it again.7 THE WITNESS: Larry King.8 BY MR. FARMER:9 Q Let's see if this is the case. He was

10 co-counsel also representing Ms. Murphy?11 A At that time, yes.12 Q Other than Ms. Murphy's lawyers, have13 you ever seen him, say, ordering somebody held in14 contempt, a lawyer held in contempt, and tell him he15 was going to put him in jail?16 A I can't say that for sure. I don't17 remember.18 Q Okay. But do you ever remember him19 doing it?20 A I don't think so. But I can't say -- I21 can't say that he did or he didn't. I don't22 remember.23 (Audio recording played.)24 BY MR. FARMER:25 Q Were you there taking that down?

Page 731 A As far as I remember.2 Q Was Larry King making any movements that3 wasn't -- that were unusual at the time, or was --4 A I don't recall anything unusual about5 that, but I --6 Q Does the audio reflect accurately what7 was taking place?8 A I'm sure it does.9 Q And did they take him -- did the sheriff

10 take custody of him?11 A I don't remember him going back, but I12 don't know.13 Q Did he -- did he -- did he take -- did14 he take control of him?15 A I don't remember.16 (Audio recording played.)17 BY MR. FARMER:18 Q At that point did the sheriff come up to19 him and he agreed to pay the thousand dollars?20 A I don't remember that. I remember him21 agreeing to pay the thousand dollars.22 Q Do you remember Judge Baldwin after that23 saying he had gotten mad and done this?24 A I don't remember that.25 Q If that's reflected in the transcript --



A Okay.2 Q -- it would be -- it would be accurate,3 right?4 A I would think so, yes.5 Q I'm going to show you an invoice. And6 it's October the 14th --7 MS. TUNKLE: October 3rd transcript.8 BY MR. FARMER:9 -- for the October 13th transcript.

10 MS. TUNKLE: October 3rd transcript.11 BY MR. FARMER:12 Q October 3rd transcript. But it's an13 October 16 invoice. And I'm going to show you this.14 It's going to be Plaintiff's Exhibit 10.15 (Whereupon, marked for identification,16 Plaintiff's Exhibit No. 10.)17 BY MR. FARMER:18 Q And I will ask if you will explain this19 transcript. Before I ask that, though, let me just20 understand this about the transcript. As I21 understand, you invoice the people to pay. That's a22 requirement, that they pay you for your work?23 A Yes.24 Q And you invoiced us in Atlanta, Fulton25 County, at our address in Atlanta?

Page 751 A Yes.2 Q And we were required to pay on the basis3 of this invoice; is that correct?4 A That's my understanding.5 Q Okay. And we -- and we had to pay the6 amount of the invoice; is that correct?7 A That would be my understanding.8 Q And you knew that we were located in9 Fulton County, Atlanta when you required us to pay

10 that invoice?11 A Yes, sir.12 Q And we -- and it was paid to you from13 Atlanta, Fulton County?14 A As far as I know. I don't know where15 you were when you signed the check.16 Q Okay. But that's where the demand for17 payment was made?18 A I mailed it to the address that was on19 your card. At one time I think I mailed it to a wrong20 ZIP code, and we got that straightened out.21 Q But at all times it was sent to Fulton22 County, Atlanta?23 A It was.24 Q Yes.25 A But it was taken down in

Page 761 Coweta County.2 Q Yes. But the payment was required to be3 made -- the demand for payment was made with the4 invoice; is that right?5 A It was made with you --6 Q That's right.7 A -- at the address you gave me.8 Q Right. And it was -- in other words,9 if -- and we paid you every time?

10 A There was one that evidently y'all11 misplaced. But that got straightened out. But all12 the work was done in Coweta County, and I billed it to13 you at your office address.14 Q In Atlanta, Fulton County?15 A If that's where your office is.16 Q And if we had not paid you, we wouldn't17 get the transcript?18 A No. I think I mailed the transcript19 with the bill. I didn't require --20 Q Okay. But I'm talking about --21 A -- payment upfront. I didn't even22 require a down payment.23 Q But essentially it was a necessity to24 get the future transcripts that you be paid? It was a25 demand for payment? It was a legal --

Page 771 A Yes, sir. Yes, sir.2 Q You were legally requiring us to pay3 it?4 A Yes, sir.5 Q And that demand was made pursuant to6 your authority to act as the court reporter for --7 that was designated for the court proceedings,8 right?9 A Yes. I took it down.

10 Q These are not private transcripts or11 anything like that or --12 A No, sir.13 Q -- depositions?14 A I didn't do any of that in Atlanta.15 Q And these were all for official court16 reporter transcripts?17 A Yes, sir.18 Q All right. Now, if you will look at19 that invoice and explain that to me, if you will.20 A All right. It's billed to you. It's in21 this case. The hearing date appears to have been22 October 3rd. And I expect that I charged the opposing23 counsel the same amount of money.24 Q And now let's look at that. And how25 many pages -- the page numbers of that?



A It appears to me that that would have2 been 117 pages if the certificate is on the next page.3 Q Just assuming raw page numbers, not the4 legal page numbers that are -- that you are -- the5 legal page numbers are not the page numbers that6 you're entitled to charge for, are not the page7 numbers that are on the bottom of the page, right? In8 other words, you can't charge for a page until you9 have so many lines on it?

10 A 13.11 Q And so the number at the bottom of the12 page doesn't reflect the legal amount that you're able13 to charge for, does it?14 A Would you explain your question?15 Q Yeah, okay. You've got to have16 63 characters per line --17 A Correct.18 Q -- before it's a line, right?19 A Correct.20 Q And then you have to have 25 lines per21 page --22 A Correct.23 Q -- before it's a page, right?24 A Correct.25 Q Now, some of the pages in the 116 may

Page 791 not have met those qualifications?2 A That's correct.3 Q So the 116 would be the outside high4 number of pages that were in that transcript that we5 were to be due to pay for, right?6 A I would say I base it on 117 pages.7 Q Okay. We'll give you your -- for this8 hypothetical to be 117 pages.9 A I'm just saying what the certificate --

10 Q Okay.11 A But what you're saying is -- it would --12 the number of characters on a line.13 Q Okay, okay. Now, half of the cost of14 that would be what?15 A It appears it would be 352.86. There16 may be some postage added in that.17 Q Okay. And what provision -- and how did18 you -- how do you support that?19 A I don't have my figures in front of me,20 so I can't tell you.21 Q Okay. The full price would be -- add a22 page to it. The full price would be 438.48 plus --23 minus -- minus your characters. You didn't have the24 number of characters per line.25 A I understand what you're saying.

Page 801 Q Okay. And that equals 434 dollars2 and -- $424.56?3 A I can't say. I don't --4 Q Okay. I'm just saying --5 A -- have it in front of me.6 Q I'm just saying, if you'd go with me7 with the math.8 A I don't know.9 Q Okay. Let's let you do the math.

10 A All right. Well, what I -- I expect11 what I did was, I added the original and two copies12 for one -- for one party and I added $1.51 for the13 other and I divided it in half, that way.14 Q Where do -- how do you show that you15 divided in half where you say in the billing it's16 one-half cost of the transcript?17 A Because I added the rates together and I18 multiplied it times the number of pages.19 Q Okay. Can you document that?20 A Not here today.21 Q Okay. But you'll be able to document22 it?23 A I believe so.24 Q And what would you -- what will you be25 able to document?

Page 811 A I believe that I would -- I would2 document that I used the 3.78 page rate and $1.51 page3 rate, added it together, multiplied it times the4 number of pages and divided by two. And I probably5 have half the postage in there.6 Q Okay. And would you say on that because7 of the format you'd use that you would be using an8 incorrect number of pages?9 A I cannot say specifically, but I would

10 think so, yes. I think it would affect the number of11 pages.12 Q So you -- so this is an overbilling?13 A It would be in that case because I made14 a mistake in my line --15 Q Okay. Whatever --16 A -- my characters per line.17 Q Excuse me. I'm sorry. She's told me18 not to try to talk over you, and I'm trying to19 remember.20 So you -- for whatever reason you have21 collected -- if -- with your format you're using, you22 collected an illegal amount of money on that?23 A An incorrect amount, yes.24 Q And it's illegal?25 A It's incorrect.



Q Well, is it legal?2 A It's incorrect.3 Q Okay. But "is it legal" is my question.4 A It's incorrect. I made a mistake.5 Q Okay. But were you legally allowed to6 do it?7 A I made a mistake. And that's all I can8 say. I made a mistake in the number of characters per9 line by two characters per line.

10 Q Is it in -- was -- was what you charged11 in conformity with the requirements that you are12 required to -- that you're required to charge or13 allowed to charge?14 A I had 61 characters per line of the Q&A.15 And that is what -- instead of 63.16 Q And does that affect the number of17 pages?18 A Yes, sir.19 Q And have you checked to see how much it20 affected the number of pages on that particular21 transcript?22 A I have. I don't have it with me.23 Q And did you check it as far as the24 colloquy? Is the colloquy different from the A&Q?25 A Yes.

Page 831 Q And did you check to see how much you'd2 overcharged for the colloquy?3 A I just did the entire transcript. I4 didn't do one and then the other.5 Q Do you know it's a different rate for6 colloquy -- a different requirement for colloquy than7 it is for A&Q?8 A Yes. The colloquy is indented.9 Q Did you make account for that when you

10 were seeing how much you were overcharging?11 A Yes, I did.12 Q And did you make -- then the A&Q you13 kept separately?14 A No, I did not.15 Q Now, as I understand what you're telling16 me, that would have been the way that you billed17 everybody that you were billing for transcripts and18 proceedings before Judge Baldwin during that time19 period.20 A I expect so. I have not counted every21 line on every transcript, no.22 Q Of course, we notified you that you23 overcharged us.24 A Yes, sir.25 Q Have you notified other people that you

Page 841 overcharged them?2 A I've told the judge that I had --3 Q "The judge" meaning?4 A I told Judge Baldwin --5 Q Okay.6 A -- that I had 61 characters per line7 instead of 63.8 Q What did he say?9 A I don't recall.

10 Q Okay. Well, what did he say?11 A I don't recall what he said.12 Q Okay. Did he -- did he say that that's13 wrong?14 A I don't recall what he said.15 Q Okay. Go ahead.16 A And I've told Mr. Skandalakis.17 Q When did you tell Mr. Skandalakis?18 A I had gone in his office to see some --19 one of the victims' assistants. She had -- she had20 something she was going to give me totally unrelated21 to court. And she wasn't there. And I just happened22 to see Ms. Kirby and Mr. Skandalakis.23 Q Meaning Judge Jack Kirby?24 A No, sir.25 Q Ms. --

Page 851 THE REPORTER: I'm sorry, Judge who?2 MR. FARMER: I'm trying to ask her.3 BY MR. FARMER:4 Q Was it Judge Jack Kirby? Which Kirby5 did you --6 A Ms. Kirby and Mr. Skandalakis.7 Q Okay. Are you referring to the spouse8 of Judge Jack Kirby?9 A She's married to Jack Kirby, yes.

10 Q Okay, which I don't think her name is11 Ms. Kirby, but whatever her name is. I don't know12 what -- okay.13 A She's not Mr. Kirby.14 Q All right, okay. Was that after the15 publicity about the court reporter?16 A I don't recall. Probably so. Maybe so.17 I don't remember when I went in there. I mean, I18 just -- I don't remember when I went in there. But I19 remember I told them. It probably was. I don't know.20 But, I mean, I didn't go in there about that. I21 didn't even go in to see them.22 (Whereupon, marked for identification,23 Plaintiff's Exhibit No. 11.)24 A I've read this.25 BY THE WITNESS:



Q Okay. Explain what you're looking at in2 that Plaintiff's Exhibit 11.3 A It's a letter from Pete Skandalakis to4 you.5 Q What is the content of that letter?6 A It says he's read your letter regarding7 me and he's listened to the audio recording and8 reviewed the pleadings and the transcripts that you9 furnished. And he says he notes that you have filed a

10 civil suit against me. And he said he's reserving11 further action until the civil suit is resolved.12 Q And was the time that you saw him before13 or after that letter?14 A Oh, I can't say. I don't know. I don't15 know the date.16 Q Did he say he knew anything about the17 complaint filed against you?18 A Not that I remember. I honestly don't19 remember what day I went in there. I don't know if it20 was before or after this.21 Q Okay. You know it was after the22 complaint was filed against you?23 A Oh, I feel sure it was after that, yes.24 Q Because that's the first time that you25 had counted to see if you were in conformity with the

Page 871 requirements of the Board of Court Reporters?2 A I don't know that. When I set up my3 transcript to begin with, I may have. I don't4 remember.5 Q After that did you ever check to see if6 you were billing people correctly?7 A I never knew that I wasn't.8 Q But did you ever check to see if you9 were billing them in conformity with the law?

10 A I can't say that I looked to see if11 every time I billed somebody I had space for12 63 characters on a line.13 Q Did you have any system by which you14 could make that determination?15 A I could do it every time I do a16 transcript, but I haven't.17 Q How could you do it then?18 A Every time I did a transcript I could19 count the spaces on a line.20 Q Other than manually counting it, did you21 ever do -- and randomly ever check to see if you were22 ever doing any of them?23 A Not that I remember. I don't know if I24 did or not.25 Q Did your typist that was typing some of

Page 881 the transcripts for you, did she ever -- or he --2 whoever it was -- did that person ever check to see if3 it was in conformity with the law?4 A I doubt it.5 Q So as I understand, had you been to6 seminars or anything for court reporters during this7 period of time?8 A Yes, sir.9 Q And at the seminars had you ever been

10 instructed or had you ever been given information as11 to what the charges would be?12 A Not that I recall.13 Q And are there other court reporters in14 the Coweta Judicial Circuit that are using the format15 that you used to charge, or are they using a different16 format, template?17 A I've never talked to them about what18 format they use. Well, I take that back. I may have19 talked to one or two, but we haven't discussed that.20 Q Have you talked to them since this case21 has been filed?22 A Yes.23 Q And who did you talk with?24 A I talked to -- I know I talked to25 Judge Simpson's court reporter.

Page 891 Q And who would that be?2 A Her name is Sheryl Lee.3 Q And where is she located?4 A She lives in Carrollton.5 Q And what was that conversation?6 A Unlike me, she had somebody she7 replaced, and she got her template from them. And I8 think hers is in compliance. I think hers is in9 compliance.

10 Q Who else did you talk with?11 A None of the other court reporters in the12 circuit that I recall.13 Q Were there court reporters that you14 talked with or professionals you talked to that were15 outside of the circuit?16 A Yes.17 Q And who were they?18 A Alice Moore.19 Q And what -- what was that20 conversation?21 A To my knowledge, hers is in compliance.22 But that's all I remember.23 Q And what system was she using to24 determine why she was in compliance?25 A I don't know. She uses Word Perfect,



and I use Word.2 Q And did you talk to her before the case3 was filed or anything -- any reporter before this4 matter was called to your attention by us before we5 filed the complaint?6 A I'm not sure.7 Q Since the time that the complaint was8 filed, since the time that you've known that you've9 overcharged, have you used any other system to correct

10 that other than just manually counting?11 A Changing the margins.12 Q Okay. And have you checked to see if13 that corrected your overcharging?14 A You mean did I count the spaces after I15 did that? Yes.16 Q Do you randomly check them?17 A I don't understand.18 Q Do you randomly check to see if you're19 overcharging according to the state law for a reporter20 that's working for a court?21 A After I changed the margins, I used22 that. But I don't go around counting lines on every23 transcript.24 Q Do you do any other compliance checks to25 see if you are complying with the law?

Page 911 A I don't know if I do or not. I don't2 know what you mean.3 Q Okay. Well, there are other compliance4 other than line checks, right?5 A Like numbers of lines and amount per6 page. I don't know what else you mean.7 Q Okay. Well, there are other8 requirements for what you can bill for, right?9 A I don't know what you mean.

10 Q Okay. The only requirements that you11 understand as far as the legal right to charge as the12 court reporter is designated by the Court?13 A I don't know if you're referring to14 anything specific or not.15 Q I'm referring to any. Are there any16 other requirements other than the line count and the17 page count that you're familiar with?18 A I don't know if you're referring to19 anything specific or not. And if you are, I don't20 know what it is.21 Q Okay. So you don't know of any other --22 any requirements other than line count and page23 count?24 A As I sit here right this minute, that's25 all I know of, but I don't -- you may have something

Page 921 in mind, and I don't know what it is.2 Q Have you ever checked for any things3 other than those line counts and page numbers?4 A I don't know because I don't know what5 you mean.6 Q Okay. Have you checked the criminal7 court for the criminal cases? Have you checked to see8 if you overbilled on each of those in any of those9 cases?

10 A On each of those, no.11 Q You haven't checked?12 A Not on each of those, no.13 Q Any of them?14 A Not really.15 Q Did Mr. Skandalakis, did he say that he16 had checked on any to see if you were overbilling the17 County?18 A He did not tell me that he had or he had19 not.20 Q And it's the County that has to pay for21 that in criminal cases; am I right?22 A That's what I understand. That's who I23 bill.24 Q Did you notify the County paymaster or25 the County Board of Commissioners that you had

Page 931 overcharged them during this same period of time?2 A No, I have not.3 Q Other than the -- other than the4 communication with Pete Skandalakis and his assistant,5 have you notified any other lawyers that you6 overcharged them?7 A I don't believe so.8 Q Did you think it was unusual that9 Judge Baldwin was writing me about you charging

10 Ms. Murphy too much money for the transcripts that she11 was having to pay? Did you think there was anything12 unusual about him being protective of you and not13 being protective of her for costs that she was having14 to pay?15 A I don't know what you're speaking16 about.17 Q Okay. Well, you know, it's Ms. Murphy18 that has to pay for this.19 A I understand.20 Q And you understand that she is a mother21 that's trying to protect the right of her children?22 You understand that from being at the hearings, don't23 you?24 A I understand that she has her side and25 the other side has his side and --



Q And her side is that she's trying to2 protect the right of her children, right?3 A That's what you-all are doing, yes.4 Q And you understand that the other side5 has a very substantial amount of money and that she6 earns her money as a hairstylist? You understand7 that, don't you?8 A I don't know anything about the parties9 and their finances. I know Ms. Murphy is a

10 hairstylist from the court proceedings.11 Q And you know that Judge Baldwin has said12 that he wasn't going to provide any -- may not be able13 to provide any money to her for attorney's fees? You14 know that?15 A I don't remember.16 Q You don't remember that part of the17 transcript?18 A I'm not saying it's not there. I just19 don't remember.20 Q Do you know that the cost per page that21 you've overcharged is about 12 cents a page? Have you22 figured that out?23 A I haven't figured it out per page.24 Q Okay. How much -- have you figured out25 per page how much you've overcharged with that

Page 951 format?2 A I know from refiguring -- from3 refiguring them -- I don't know per transcript. I4 don't know -- but I know the total from all of them.5 Q Do you know how much you have charged6 Ms. Murphy for your transcripts?7 A Altogether? No, sir.8 Q Do you know how many criminal9 transcripts you've produced during this period of time

10 that you used that format?11 A No, sir.12 Q Did -- has Mr. Skandalakis or anybody on13 his behalf approached you about the amount that you14 overcharged the County since that initial conversation15 with you?16 A Pardon me? Would you say that again?17 Q Since the initial conversation, has he18 approached you any other time?19 A No, sir.20 Q Did he say he was going to do anything21 about it?22 A He didn't tell me.23 Q Did he mention anything about that it24 was wrong for you to do that or illegal for you to do25 that?

Page 961 A He just heard what I said. That's all I2 know. He heard me. That's all I know.3 Q And what did he respond?4 A I really don't remember.5 Q Does Judge Baldwin sentence people for6 stealing?7 A I'm sure he does.8 Q Have you ever -- have you heard him9 sentence people for stealing?

10 A Yes.11 Q And does he sentence them to prison for12 stealing?13 A Some people. Not everybody.14 Q But some he sentences to prison?15 A Yes.16 Q And if they say they made a mistake in17 stealing, does he say, I'm not going to sentence18 you?19 A I honestly don't remember anything like20 that.21 Q Is mistake to stealing, is that a22 defense?23 A I'm not a lawyer. I don't know.24 Q Okay. Do you consider it to be a25 defense?

Page 971 A I can't say.2 Q What -- what -- what defense do you3 consider that you have to taking -- violating the law4 and overcharging people as you've overcharged and5 overcharging the County as you've overcharged?6 A I made a mistake on my line -- my spaces7 per line.8 Q And the Board of Court Reporters doesn't9 say that if you make a mistake that you don't -- that

10 you can overcharge, do they?11 A I have not read that.12 Q Okay. You're not aware of them saying13 that?14 A I'm not aware of them saying that.15 Q Back to my question about Judge Baldwin16 wanting to protect your money. What is your financial17 situation as far as income per year approximately?18 A I honestly don't know.19 Q Approximately.20 A I have somebody do my taxes. I honestly21 don't know. I honestly don't know.22 Q Okay. Well, what is your estimated23 income?24 A I can't answer that. I don't know.25 Q You don't have any round number?



A No, sir.2 Q Within $10,000 you can't tell me?3 A I really don't know.4 Q Well, what was the basis of5 Judge Baldwin's information that you couldn't afford6 the litigation?7 A I don't know. I don't know what he8 knows about --9 Q Okay. Did you have any basis for -- did

10 you provide him any basis for making that statement?11 A Not that I recall.12 Q Did you feel that the letter to the13 lawyer that he won't provide attorney's fees for14 defending Ms. Murphy, do you feel like him attempting15 to protect you from paying her back the money you owe16 him -- did you feel like that that was inappropriate17 conduct on his part?18 A I really don't know what you're19 referring to there.20 Q Okay. You overcharged her, right?21 A That's what you claimed. And I say I22 have 61 characters per line instead of 63.23 Q Okay. And you've admitted you24 overcharged?25 A I admitted I made a mistake.

Page 991 Q Okay. But it's overcharged, right?2 A Yes.3 Q Okay. Now, do you -- do you feel that4 Judge Baldwin was justified in saying that I shouldn't5 attempt to recover that?6 A I didn't know that he said that.7 Q Okay. Did you think that he was trying8 to prevent me from bringing the litigation against9 you?

10 A All I know is what's in that e-mail.11 Q Okay. Do you think he was trying to12 prevent me from having information about his demeanor13 toward me and, in effect, toward Ms. Murphy with his14 hollering and all like that by keeping me from having15 the audio transcripts?16 A I don't know. I don't know. I can't17 speak for Judge Baldwin.18 Q But did you have an opinion as to19 what -- what was his motivation in doing that?20 A I don't know. I told him that I didn't21 think I was required to produce my recordings to you.22 That's all I know.23 Q Did he ever tell you he's consulting24 with other people about what he did in this matter?25 A Not that I recall. I'm not sure. And I

Page 1001 don't -- I don't know what you mean. And I don't -- I2 really don't know what he's done. I don't see him3 much outside the courtroom or --4 Q And outside when you go back there to5 ask him not --6 A Well, I go in his office. I mean, I go7 in his office and I do see him. And I did tell him8 that I was -- that you had asked me to take down the9 calendar call.

10 Q But you never told him you couldn't11 afford the litigation?12 A I don't know if I did or not. I don't13 know.14 Q Would it have been accurate if you did15 tell him that?16 A Probably so.17 Q What assets do you have?18 A I have money that I save that's in the19 bank.20 Q What -- what -- what --21 A I can't tell you how much it is. I22 don't know. I have some IRA's that I put aside.23 That's basically it.24 Q Okay. What -- what -- what value25 roughly?

Page 1011 A I really don't know.2 Q Are you in a financial position to3 refund the money that you've overcharged to all of4 the -- to the County and to people?5 A I don't know how much it is, so I don't6 know.7 Q What Counties have you overcharged8 beside -- charged money for that you're not allowed by9 statute to other than Coweta and Troup? What other

10 Counties?11 A I don't know how many.12 Q Okay.13 A And I don't know how many transcripts.14 I don't know which ones. But there are five counties15 in our circuit.16 Q So you possibly could have been involved17 with all five of those Counties?18 A Possibly.19 Q Are you aware of this issue of court20 reporters overcharging, that a -- court reporters for21 the County over the state of Georgia? Are you aware22 of that issue in other Counties?23 A I remember the -- some in24 Cherokee County were, but that's all I know.25 Q Do you know they're being criminally



prosecuted?2 A I just know that charges were brought.3 Q Criminal charges?4 A As far as I know.5 Q Okay. RICO.6 A I don't know --7 Q Do you know what RICO is?8 A Not really.9 Q Okay. They're RICO charges.

10 A I see.11 Q Do you understand the importance of12 Michelle Murphy not having to use her assets in an13 attempt to get what's legally deserved for her as far14 as you are concerned as a court reporter?15 A I know that if you had brought it to my16 attention and I had looked into it, if I had found out17 I was, it wouldn't have had to have been a lawsuit.18 Q Okay. I brought it to your attention.19 A Yes, but in a lawsuit.20 Q Okay. Huh?21 A In a lawsuit.22 Q Okay. I brought it to your attention23 about the County.24 A Pardon?25 Q I brought it to your attention about the

Page 1031 Counties, that you've overcharged the Counties?2 A Yes.3 Q I brought it to your attention --4 A Well, you say -- I say that I possibly5 could in my making my mistake, but I haven't looked.6 Q But you possibly --7 A Yes, possibly.8 Q Have you brought -- and you haven't9 brought it to the attention of those people that you

10 overcharged, have you?11 A I told Mr. Skandalakis that my lines12 were two characters short.13 Q And that's -- did you tell him that by14 virtue of that that you had overcharged the County and15 that he's on knowledge that you've overcharged the16 Counties and he's not doing anything about it? Is17 that what you're telling me?18 A I did not tell him that, no. I told him19 the truth, that my lines were two characters short.20 Q And that you had overcharged?21 A No, I did not say that.22 Q You didn't say that?23 A No. I said I don't know what effect24 that would have on all my transcripts.25 Q And what did he say at that time?

Page 1041 Forget it, Nan? You're my friend, and I'm not going2 to charge you for stealing?3 A No, he did not say that.4 Q Okay.5 A I don't remember exactly what he said.6 Q Okay. Has he done anything to your7 knowledge about it?8 A Not to my knowledge.9 Q You know the Freedom of Information

10 request was made to the County attorneys?11 A No, I do not.12 Q You know I showed you the Freedom of13 Information request earlier?14 A You mean the letter from Mr. King?15 Q Yes.16 A Okay. Oh, I'm sorry, I don't understand17 what you're saying.18 Q Okay. That's addressed to the County19 attorneys, right?20 A Oh, okay. I see that now. Yes.21 Q And none of the County attorneys have22 approached you as far as --23 A They have not approached me, no.24 Q And you know the Glover & Davis lawyers25 are the attorneys for Coweta County? Did you know

Page 1051 that?2 A I did not. But I see it now. I didn't3 notice. I just read the body of the letter. I didn't4 read who all it was addressed to.5 Q Have you ever been to any fundraisers6 for money or campaign parties or anything for any of7 the judges?8 A Not that I recall ever.9 Q Do you make campaign contributions to

10 any of them?11 A No, sir.12 Q Do you remember on the tran -- on the13 day of the hearing that there was "blame yourself,14 blame yourself"? That's what I call the "blame15 yourself" hearing. Do you remember that day?16 A I heard that recording. I don't -- I17 assume that was the day -- that last hearing that I18 reported.19 Q That's right. Do you remember at the20 start of that hearing --21 A Uh-huh (affirmative).22 Q -- that I asked Judge Baldwin -- I said,23 Judge Baldwin, I have the children here.24 Judge Baldwin came in and sat on the bench. Do you25 remember that?



A Yes.2 Q I said, Judge Baldwin, I have the3 children here, and they want to -- they would like to4 testify. Do you remember that?5 A More from hearing something about what6 you said later.7 Q But you do -- you do -- do -- now you do8 remember that?9 A I believe so. But I believe it's more

10 from what you said.11 Q And did you record that and provide that12 in the transcript?13 A I don't think I started reporting then14 because you were setting up a screen like that one15 over there and the deputies told you that they had16 one, and there was a lot of commotion over on that17 side of the courtroom. And the judge asked where your18 client was. And you said she's outside. And at some19 point I think maybe the judge said, we'll wait for20 your client. And so I thought we were not starting21 yet.22 And then you stood up and began to talk.23 And I realized that I needed to take that down. But24 up until that time, I thought we were waiting for your25 client to come into the courtroom. That's what -- as

Page 1071 I recall, it was said, we'll wait for your client.2 Q There's no transcript of Judge Baldwin3 when he was sitting on the bench and I was telling him4 that Jack and Thomas were here and wanted to5 testify?6 A I don't believe so because I don't7 believe that I would have been alerted that we had8 started the hearing yet.9 Q But when Judge Baldwin came into the

10 court, you heard him say "order in the court, all11 rise"?12 A I don't think he says either one of13 those things.14 Q No, no, the bailiff.15 A Probably so but --16 Q Okay. But you heard that?17 A I can't say I did.18 Q Okay. That's --19 A I would assume it was said.20 Q That's a symbol that court has begun,21 right?22 A Yes. But it's not necessarily the23 symbol for me to begin taking down.24 Q So you don't take down stuff until Judge25 Baldwin tells you to? Or what is the signal to tell

Page 1081 you?2 A He said, we'll wait for your client to3 get in here. I did not begin taking down at that4 point because you-all were setting up a screen, I5 didn't take down "Your Honor, we're setting up" --6 whatever you said, like "Your Honor, we're setting up7 a screen because we have some exhibits" or whatever8 you were saying. I did not take that down. I did not9 take down the deputy saying "we have a screen and we

10 can let it down." I did not take any of that down.11 Q Did you take down that we had Jack and12 Thomas there, who wanted to testify and wanted to talk13 to the judge?14 A I don't believe so because I thought we15 were waiting for your client to come into the room16 before we began the proceedings.17 Q But you do know it happened?18 A I do vaguely remember that, yes. But I19 did not take it down because I thought we were waiting20 for your client to come into the courtroom.21 Q Did you notice anything strange about22 the courtroom on that day as far as the number of23 deputies and everything in that courtroom?24 A No, sir.25 Q Did you know the case was specially

Page 1091 set -- just that case was specially set for that2 day?3 A I may have. I don't remember.4 Q Did you -- did you see Judge Baldwin5 when he was hollering "blame yourself"? Did you see6 his motions and movement?7 A I don't remember.8 Q You don't remember whether you saw him9 or you didn't see him?

10 A I don't remember seeing it.11 Q You don't remember seeing his12 gestures?13 A I do not remember seeing his gestures.14 Q Do you consider those gestures to have15 been hostile?16 A I didn't see them.17 Q You didn't see any gestures?18 A I don't remember seeing anything.19 Q Did you consider that communication by20 Judge Baldwin to be hostile?21 A I saw a lot of hostility in the22 courtroom in every one of these hearings on both23 sides.24 Q And by Judge Baldwin?25 A By every party.



Q And by the judge?2 A By the judge and by each attorney and3 sometimes a client.4 Q From all -- from the beginning to the5 end?6 A At first I don't think I was so much7 aware of hostility. I had just come into the case,8 and I didn't have any expectation. But I began to see9 it, yes.

10 Q After the -- after the motion to11 disqualify -- after the motions to disqualify --12 A I don't know.13 Q You don't know when?14 A I don't know when they were filed. I15 don't know anything about those motions.16 Q Was that an unusual amount of hostility17 by Judge Baldwin?18 A I've seen him -- I don't know if you'd19 say -- I don't think so. I mean, I don't know. It20 depends on his cases. I mean, I've heard him21 reprimand people before.22 Q I'm not saying a reprimand. I'm talking23 about hostility.24 A That's your -- that's really your word,25 I think.

Page 1111 Q Okay.2 A And I adopted it a minute ago, but3 that's really your word.4 Q I understand it's my word --5 A Yes.6 Q -- but since I'm the one that's asking7 the questions --8 A Well, I would say that's your perception9 of it, yes.

10 Q Okay. Would that perception be11 accurate?12 A That's -- according to your definition,13 I would just say -- I would just say that the feelings14 went both ways with everybody. It was -- it was just15 a very -- it was uncomfortable for me. I'm not used16 to that level of animosity or whatever you want to17 call it from all the parties in a case.18 Q And the judge?19 A Well, yes.20 Q And to the parties?21 A Yes. It seemed to be a little22 infectious.23 Q A little what?24 A Infectious.25 Q Okay. Tell me what you mean by

Page 1121 "infectious."2 A Well, one would lead to another to3 another. It seemed to go in a triangle.4 Q Between the parties and the judge?5 A Yes, between the parties and between the6 parties and the judge sometimes.7 Q And you never saw him hostile to8 Taylor Drake, did you?9 A I don't know that I saw him hostile to

10 you. But that's -- like I say, that's your words.11 Q Heard him being hostile? Did you ever12 hear him being hostile to Taylor Drake?13 A I just -- I don't -- I don't know how to14 answer that because I just --15 Q Am I putting you in a bad position with16 this question?17 A I don't know. I just don't -- I don't18 remember him -- I just don't remember him -- I don't19 remember many of the exchanges between him and20 Taylor Drake because Mr. Drake usually did what he21 said.22 Q Would you consider defending somebody23 from a judge who was giving illegal orders -- would24 you consider that to be the obligation of the25 lawyer?

Page 1131 A I don't know what an illegal order is,2 but --3 Q Okay. One that the law doesn't --4 A Well, I understand what you're saying,5 but I wouldn't know which one was illegal and which6 one was not. But, I mean, I think you should do the7 best job for your client within the law.8 Q Were you there the day that he ordered9 me put in jail when I wasn't even there? I was in

10 Mississippi on another case, trying another case.11 Were you there that day, the same day he put12 Larry King --13 A I know you weren't there. I was there14 that day.15 Q Did you hear him order me held in16 contempt, put in jail?17 A I don't remember about the jail, but he18 probably did. I don't know. I do remember -- I do19 remember something about that exchange, but I don't20 remember specifically.21 Q Do you remember that he ordered22 Ms. Murphy to be put in jail that day?23 A Well, I think it was upon payment of a24 fine or something.25 Q Well, that's put in jail till you do it,



right?2 A I guess. I don't know.3 Q I mean, that's put in jail, isn't it?4 A I don't -- I don't know. I didn't -- I5 don't know what goes on outside the courtroom.6 Q Okay. But you took that down, didn't7 you?8 A I did.9 Q And he did say put her in jail until a

10 certain thing happened?11 A Probably so. That's probably right.12 Q So you did hear him ordering, put her in13 jail, right?14 A I assume if that's what he said, I heard15 it.16 Q Okay. And you know she wasn't there?17 A Yes.18 Q And you know the day that he took the19 children away from -- had the deputy sheriffs take the20 children away from her, you know that she wasn't21 allowed to put up evidence on that day, that only22 Taylor Drake was allowed to cross-examine her and he23 stopped the cross-examination. You remember that,24 don't you?25 A I do.

Page 1151 Q And you know that she wasn't -- I wasn't2 allowed to put up her witnesses?3 A I know that that was -- her testimony4 was the last testimony.5 Q And you know that when they sequestered6 the witnesses and put the witnesses outside the7 witness room that Betty King, the custody evaluator,8 was sitting outside the witness room to be put up?9 A No, I did not know that.

10 Q You didn't know it?11 A No, sir.12 Q You didn't take that down?13 A I don't remember. If it was in the14 transcript or if you said it, I may have known it at15 the time. I don't remember it today.16 Q And when you talk about putting up the17 screen, you know we were talking about putting up the18 screen for our witnesses to present up evidence for19 our witnesses, don't you?20 A I know you said -- as I recall, you said21 maybe you were going to have exhibits. I don't -- I22 don't remember --23 Q Right. And that would have been for24 testimony?25 A I would assume so, yes.

Page 1161 Q And that never was allowed, was it?2 A It never happened.3 Q Right. And she was on the stand4 presenting information when he ordered -- said he was5 stopping the hearing?6 A Who was on the stand? Who is "she"?7 Q Ms. Murphy.8 A Yes.9 Q She was trying to explain why she didn't

10 have the money to fulfill the order when that took11 place as you remember?12 A As I remember, she was explaining why13 she didn't comply with the judge's order.14 Q And she hadn't finished that explanation15 when he aborted the testimony; is that correct?16 A I don't know what else she had to say.17 Q Okay. But she hadn't finished? She was18 still -- she was still attempting to answer his19 questions when he stopped?20 A As I recall, Mr. Drake was questioning21 her, and the judge said he wanted to ask something or22 something to that effect.23 Q He took over, right? And that was24 before I got to question her, right?25 A He began to ask questions before you

Page 1171 questioned her.2 Q And I never got a chance to ask the3 questions, did I?4 A No, sir.5 Q And he stopped her from answering6 questions, didn't he? He stopped her from giving her7 answers, didn't he?8 A He stopped Mr. Drake's examination --9 Q -- which was her answers to his

10 questions, right?11 A To Mr. Drake's questions, yes, but then12 the judge asked questions.13 Q And he stopped her from answering --14 explaining all of her answer to him?15 A To Mr. Drake, yes.16 Q To the judge? Stopped -- the judge17 asked her a question, and then he stopped right in the18 middle of the questions and stopped and ordered the19 children to go with him?20 A Well, he asked if she had complied with21 his order, and he determined that she had not.22 Q Well, now, you don't know what he23 determined, do you?24 A Well, I guess I don't know what he25 determined. But I believe he said -- my understanding



was -- you have not -- this is me paraphrasing --2 you've not done what I asked.3 Q Right. But if he had asked her to do4 something that was illegal or asked her to do5 something that was impossible, she was entitled to6 defend that in your view of the law, right? I mean,7 do you think a person is entitled to a defense?8 A Yes, sir.9 Q And do you think a person is entitled to

10 explain their defense?11 A I would think so.12 Q And did you see her trying to explain13 her defense when he stopped and took the children14 away?15 A She was answering Mr. Drake's16 questions.17 Q Okay. And was she trying to explain her18 defense in doing so?19 A Probably so. I don't remember exactly20 what she was saying.21 Q And did you remember Larry King saying22 that he had witnesses that they wanted to present and23 testify?24 A I don't remember. Was that in the25 addendum?

Page 1191 Q Yes, it was.2 A Okay.3 Q Do you remember him saying -- that took4 place, right?5 A Whatever is in the addendum, I remember6 that. I mean, I would remember --7 Q Judge Baldwin did not allow it, did8 he?9 A I don't believe he did.

10 MR. FARMER: Can we have just a few11 minutes?12 THE WITNESS: Certainly.13 BY MR. FARMER:14 Q Before we take that, is there something15 you would like to explain that I have not asked you16 that may explain the reason for your conduct that you17 haven't told me about?18 A When we come back from the break, can I19 answer that --20 Q Yes, yes.21 A -- and you give me a chance to think22 about it?23 Q I'm going to -- I'm going to give you a24 closing statement.25 A All right. Thank you.

Page 1201 Q Okay. Take a break.2 A Okay.3 THE VIDEOGRAPHER: This is the end of4 Video 2. We're going off the record at5 12:20 p.m.6 (Whereupon, a recess was taken.)7 THE VIDEOGRAPHER: This is the beginning8 of Video 3. We are on the record at 12:25 p.m.9 BY MR. FARMER:

10 Q Ms. Freeman, have you ever noticed Judge11 Baldwin -- had any information about Judge Baldwin12 suffering from any type of illness or being under any13 type of medication?14 A I know he sees doctors from time to15 time, but no. I mean, I don't know about any16 medication he takes. I don't know anything about his17 health situation.18 Q All right. And what does he -- what19 type of doctors or what type of thing? Do you know20 what his --21 A I don't know.22 Q But you don't know of anything -- you23 don't know of any medical excuse that he would have24 for his behavior?25 A I don't know anything about his medical

Page 1211 situation.2 Q All right. But I mean from seeing him3 in the courtroom, you don't know of any medical reason4 for any of his behavior?5 A I really don't know about6 Judge Baldwin's medical issues. I don't know7 anything -- I don't know if he has them, what he has.8 I don't know.9 Q Do you -- do you report proceedings in

10 which Lisa Hollowell is the guardian ad litem? Have11 you reported any other proceedings other than this one12 in which --13 A I don't remember about her being a14 guardian ad litem in other cases, but I don't -- I15 never paid attention. And sometimes I don't know who16 a guardian is. I don't -- I don't know.17 Q Have you ever participated in any case18 in the Coweta Judicial Circuit at any time in which a19 person was required to go to a custody evaluator?20 A I believe so. But I don't know for21 sure.22 Q Okay. And who? What --23 A I really don't know. I really don't24 know. I think I've heard that term.25 Q Outside of this case?



A I believe I've heard that term before,2 but I really don't know.3 Q You don't remember ever taking down4 testimony from a custody evaluator?5 A I can't -- I can't remember any, but I6 can't remember that I haven't either.7 Q Okay. So you don't --8 A I could have. I just don't remember.9 Q You don't remember any type of case

10 where --11 A Well, I've heard psychologists, I know,12 and I've heard guardians ad litem.13 Q Okay.14 A Custody evaluator I may have. I don't15 know. I just never paid much attention. I just took16 down what was -- what -- you know, what was on the17 stand at that time.18 Q Do you realize how the cost of19 litigation could affect the right of a mother to20 defend herself and defend her children?21 A I would think it affects any lawsuit of22 any type, yes, the defense. Yes, I can.23 Q And do you realize how the treatment --24 the disposition of a judge picking up the children25 there in the courtroom like that, turning them over to

Page 1231 the deputy sheriff in the courtroom -- have you ever2 seen Judge Baldwin do that before?3 A I don't remember it. But I haven't4 worked for him, you know, but a few years.5 Q But a few. In all the years that you've6 seen him, have you ever seen him do that?7 A I don't remember that.8 Q You don't remember seeing any other9 judge do that?

10 A I don't remember any -- I don't remember11 that, but I do --12 Q Do you know what happened to the13 children after they left that day?14 A No, sir. I would have no way to know.15 Q Do you know that they are in a lock-down16 facility in Utah where they cannot -- where they17 cannot see their mother and they cannot talk to18 anybody outside of the -- outside of the facility19 where they are?20 A I have no knowledge of any of that.21 Q Do you know that people in that22 lock-down facility, according to the people in23 Tennessee where they had been sent, that they have24 been psychologically and physically injured in that25 facility?

Page 1241 A I have no way -- I know nothing about2 where they are. I know nothing about those3 children.4 Q You remember when it was determined5 that -- the children were in St. Thomas that there was6 going to be a hearing, that we were requesting a7 hearing? Do you remember that?8 A No, I don't.9 Q You remember that when -- that we were

10 requesting to have a hearing and Judge Baldwin said he11 couldn't obtain a court reporter? Do you remember12 that?13 A I wasn't involved with it.14 Q So you didn't tell him that you15 wouldn't -- you refused --16 A Oh. Well, I told him I didn't think it17 was appropriate for me to report it.18 Q And it wouldn't have been, would it?19 A I don't believe so.20 Q And why wouldn't it have been21 appropriate?22 A Because you're bringing a lawsuit23 against me.24 Q Because you were overcharging, right?25 A Is that the only reason you brought the

Page 1251 lawsuit?2 Q No. Because you wouldn't give the audio3 recordings.4 A But you sued me anyway even though you5 got it.6 Q I remain -- we remained overcharged.7 You know that, don't you?8 A Yes.9 Q Okay. And in other words, you took --

10 A But if you had brought that to my11 attention, I would have corrected it at the time.12 Q Okay. We brought it to your attention.13 Have you corrected it for all the other people?14 A No, sir.15 Q Okay. So as we stand here today, the16 children are in -- when they went to St. Thomas and17 they were coming back, we were supposed to have a18 hearing. And assuming that Judge Baldwin never asked19 you, did he ask you about getting another court20 reporter to --21 A No, sir.22 Q -- cover the hearing?23 A I don't believe he did.24 Q Do you know that he wouldn't allow a25 hearing for the -- to support the testimony of the



child that came back and gave the video and said that2 John Murphy was and Renee Murphy were allowing the3 children to have alcoholic beverages at Fox's Bar4 in -- near the -- off near St. Thomas?5 A I don't know anything about that.6 Q Did you know that -- have they ever told7 you that Judge Baldwin would not let me file any8 pleading in his court now unless I send it to him9 first for his approval? Did you know that?

10 A I don't. I mean, I've heard something11 about that, but I don't know anything about it.12 Q Okay. What have you heard about that?13 A I believe -- I really don't know. I14 just remember -- I don't know that I was specifically15 told, but I believe I heard it discussed. But I can't16 remember.17 Q Who did -- how did you hear it18 discussed?19 A I don't remember. Maybe I -- I believe20 I heard maybe that Cindy had asked -- Cindy Brown, the21 Clerk in Coweta, had asked Judge Baldwin -- I just22 believe I was present when that was discussed with23 somebody. She didn't know what to do, maybe that she24 had been asked to file something and she asked Judge25 Baldwin about it. I really --

Page 1271 Q I was downstairs waiting to file2 something, and she wouldn't file it.3 A I don't know. It's something to that --4 Q He was upstairs with a case.5 Remember?6 A Well, I just remember hearing something.7 Q Okay.8 A But, I mean, I wasn't a party to that9 conversation, I don't think.

10 Q I know, but you were listening, though.11 A Well, no. I just think I had -- I heard12 it in passing. But I was not party to the13 conversation. I just --14 Q But he wouldn't -- but he said, no, he15 wasn't going to allow it to be filed.16 A I don't remember.17 Q And it was --18 A I just know that Cindy had asked him --19 I'm sorry. I didn't mean to interrupt. I know that20 Cindy had asked him what to -- as I recall, Cindy21 asked him what to do, and that's all.22 Q What did he say?23 A I don't -- I don't even know if he was24 the person saying it. I don't know. I just remember25 something about it. You asked me how I knew, and I

Page 1281 think that was it.2 Q Okay. And who was -- who was the3 conversation from Cindy directed to? Was it --4 A I may have heard Judge Baldwin talking5 to somebody. I really -- maybe a bailiff. I don't6 know. I'm not -- I can't say for sure.7 Q Do the bailiffs stay in his chambers8 when he goes off the bench during hearings?9 A I don't know.

10 Q Well, what was the occasion for you11 being in his chambers?12 A It might have even been in the hall,13 Mr. Farmer. I don't -- it might have even been in the14 hall. Or I might have been in the hall and -- I just15 don't know.16 Q So you are familiar that he said that I17 could not file any more pleadings that he didn't18 approve of?19 A I'm aware of something to that effect.20 I don't know that I have --21 Q Okay.22 A -- been told specifically or seen23 anything specific, but I was aware, vaguely aware,24 yes.25 Q Did you know those pleadings that he

Page 1291 wouldn't allow me to file documented his conduct?2 A No, sir, I did not.3 Q Did you know those pleadings that he4 wouldn't allow me to file documented things about5 where the children are being treated now and how the6 children are being held away from Ms. Murphy and that7 she's not even been allowed to know where they are8 located?9 A No, sir, I did not.

10 Q Did you know that he has never issued11 such an order in the time he's been there on the12 bench? Have you ever heard him issue an order like13 that, that a lawyer can't file a pleading?14 A No. But I would have no knowledge of15 anything like that.16 Q I understand. I'm asking, did you know17 that?18 A No, sir. But I would have no way of19 knowing.20 Q Have you seen anything in the time that21 you've been reporting to justify him saying that a22 lawyer couldn't file a pleading in a case without23 showing it to him?24 A Would you repeat --25 Q Yes.



A Would you repeat that? I'm sorry.2 Q Yes. In the time you've been reporting3 this case --4 A Yes, sir.5 Q -- have you seen anything that took6 place in any of the reporting that would justify him7 saying that the pleading could not be filed, that the8 lawyer couldn't file a pleading until after he9 approved of it?

10 A I just don't think I'd be in a position11 to judge that. I have no idea about -- I have no idea12 about any of it. I don't know what's -- I don't know13 that he's ever done it. I don't know that he hasn't.14 I'm not in a position to judge that.15 Q But I'm asking -- you're around -- but16 you're in the courtroom more than 90 percent of the17 people in the world in Coweta County, and I'm asking,18 have you -- have you seen anything that would justify19 that in this case?20 A In this case?21 Q Yes.22 A I don't know. I just don't -- that's23 not -- I just don't think that's anything I'm in a24 position to judge.25 Q Do you think -- in your view of -- I'm

Page 1311 trying to get a position of your value system. Do you2 think that a lawyer should have to submit a pleading3 to the judge before they're given permission to file4 it with the Clerk of Court?5 A I don't know what the law is. I don't6 know what's required. I don't know how that works.7 Q Forget about the law. As a matter of8 fairness, do you think he would be willing to tell one9 side that they could file something and the other side

10 that they couldn't?11 A I would think he would have to tell the12 same to both sides.13 Q And if he didn't, do you think that14 would be some showing of unfairness?15 A I would think that would be your16 perception. I just don't think that -- I don't think17 that I'm in a position to say that because it doesn't18 have to do with me, and I just think that's between19 the judge and the parties or the parties' attorneys.20 Q Your job depends on Judge Baldwin; am I21 correct?22 A He's the -- he's the judge I work for.23 Q And if he said, I don't want you24 anymore, you're fired, you're gone, right?25 A That's true.

Page 1321 Q So your job is depending totally upon2 him?3 A I could leave if I wanted to.4 Q I understand that. But if you wanted to5 keep your job, it would be dependent on6 Judge Baldwin?7 A Of course.8 Q And your income is dependent upon9 Judge Baldwin?

10 A As long as I work in his courtroom,11 yes.12 Q And if you didn't work -- if he wouldn't13 employ you in the Coweta Judicial Circuit, there's not14 another available place for you to obtain employment15 in the Coweta Judicial Circuit?16 A Not today.17 Q Have you had -- do you have any nephews?18 Nieces?19 A Yes, sir.20 Q What age are those children?21 A I'm not sure exactly. Probably early22 thirties to 16 or 17.23 Q Were you around them as they grew up?24 A Somewhat. They don't live near me.25 Q I know. But, I mean, they were part of

Page 1331 your extended family?2 A Certainly.3 Q If they were separated from their4 parents and not allowed to see their parents, do you5 think that would -- considering who their parents6 were, would that affect their well-being?7 A I would think it would if the parent --8 I mean, it would depend on the parents. But, yes, I9 would think so.

10 Q Can you ever justify any reason that --11 anything that you know about this case that12 Michelle Murphy could not even talk to her children on13 the telephone?14 A I don't -- I don't know any --15 Q Do you know of any evidence that you've16 heard that would say that she was not justified in17 talking to the children on the telephone after that18 hearing when he did the "blame yourself"?19 A I don't remember anything in particular20 one way or the other.21 Q Okay. But --22 A I don't --23 Q -- do you know of anything? I'm not24 saying, do you remember it? I'm going to say, do you25 know of anything?



A Outside of the courtroom, I don't know2 much about this at all.3 Q I know, but you were in the courtroom.4 From anything you know in the courtroom or anything5 you know in life, do you know of anything that would6 justify that?7 A I can't say that I do, but I don't --8 Q Okay.9 A I can't say that I don't either. I

10 don't know -- I don't know Ms. Murphy. I don't11 know --12 Q I understand.13 A I don't even know all the accusations14 probably. I don't know.15 Q You've been in -- you've been in the16 courtroom and you've taken it down and you've heard as17 much as Judge Baldwin has heard in the courtroom,18 haven't you?19 A I was not there for one of the hearings20 that I know of. And I don't know about what -- I21 don't know about what didn't happen in the22 courtroom.23 Q But if it happened in the courtroom --24 A Yes, sir.25 Q -- you're familiar with it?

Page 1351 A Yes, sir.2 Q Do you know of anything that happened in3 the courtroom that would justify her not even knowing4 whether they were dead or alive or not?5 A No, sir.6 Q I'm going to let you make a closing7 statement. And then if you have more, I'll come back.8 A I don't think I have anything else I9 want to say.

10 Q He can examine you.11 MR. GORDON: I have no questions.12 THE REPORTER: Before we go off the13 record, I just wanted to ask each attorney if14 you want to order the transcript.15 MR. FARMER: Yes.16 MR. GORDON: Yes.17 MR. FARMER: Simultaneous.18 THE REPORTER: I wrote "both said yes."19 MR. GORDON: She wants to read and sign.20 THE REPORTER: Okay.21 THE VIDEOGRAPHER: This concludes the22 deposition. We are going off the record at23 12:42 p.m.2425

Page 1361 C E R T I F I C A T E23 I hereby certify that the foregoing transcript

was reported, as stated in the caption; that the4 witness was duly sworn and elected to reserve

signature in this matter; that the colloquies,5 questions and answers were reduced to typewriting

under my direction; and that the foregoing pages 16 through 135 represent a true, correct, and complete

record of the evidence given.7 The above certification is expressly withdrawn

and denied upon the disassembly or photocopying of the8 foregoing transcript, unless said disassembly or

photocopying is done under the auspices of Veritext9 Legal Solutions, and the signature and original seal

is attached thereto.10 Pursuant to Article 10B of the Rules and

Regulations of the Board of Court Reporting of the11 Judicial Council of Georgia, I make the following

disclosure: That I am a Georgia Certified Court12 Reporter and Registered Professional Reporter, here as

an independent contractor for Veritext Legal13 Solutions; that I was contacted by the offices of

Veritext Legal Solutions to provide court reporting14 services for this deposition; that I will not be

taking this deposition under any contract prohibited15 by Georgia law; and that I am not disqualified as a

reporter for a relationship of interest under the16 provisions of O.C.G.A. 9-11-28(c).

This the 8th day of December, 2014.1718

__________________________________19 MARCIA ARBERMAN, CCR-B-10592021 * * *22 (Reporter disclosure made pursuant to

Article 10.B. of the Rules and Regulations of the23 Board of Court Reporting of the Judicial Council of

Georgia.)2425

Page 1371 Murphy v. Freeman2 Nan Freeman3 INSTRUCTIONS TO THE WITNESS4 Please read your deposition over5 carefully and make any necessary corrections.6 You should state the reason in the7 appropriate space on the errata sheet for any8 corrections that are made.9 After doing so, please sign the errata

10 sheet and date it.11 You are signing same subject to the12 changes you have noted on the errata sheet,13 which will be attached to your deposition.14 It is imperative that you return the15 original errata sheet to the deposing16 attorney within thirty (30) days of receipt17 of the deposition transcript by you. If you18 fail to do so, the deposition transcript may19 be deemed to be accurate and may be used in20 court.2122232425 1968318



Murphy v. Freeman2 Nan Freeman3 E R R A T A4 - - - - -5 PAGE LINE CHANGE6 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _7 Reason:_______________________________________8 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _9 Reason:_______________________________________

10 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _11 Reason:_______________________________________12 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _13 Reason:_______________________________________14 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _15 Reason:_______________________________________16 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _17 Reason:_______________________________________18 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _19 Reason:_______________________________________20 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _21 Reason:_______________________________________22 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _23 Reason:_______________________________________24 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _25 1968318

Page 1391 Murphy v. Freeman2 Nan Freeman3 ACKNOWLEDGMENT OF DEPONENT4 I, ______________________, do5 hereby certify that I have read the foregoing6 pages and that the same is a correct7 transcription of the answers given by8 me to the questions therein propounded,9 except for the corrections or changes in form

10 or substance, if any, noted in the attached11 Errata Sheet.1213 __________ ________________________14 DATE SIGNATURE1516 Subscribed and sworn to before me this17 ____________ day of ______________, 20__.1819 My commission expires: _________________20 ____________________________21 Notary Public22232425 1968318



IN THE SUPERIOR COURT OF FULTON COUNTYSTATE OF GEORGIA

Nancy Michelle Murphy,

Plaintiff,vs.

Civil Action No. 2014CV241705Nan Freeman andFreeman Reporting, Inc.,

Defendants

Notice of Deposition of Nan Freeman, Individually,and in her Capacity as

30(b)(6) Representative of Freeman Reporting, Inc.

To: Kenneth Gordon, Esq.P.O. Box 1088LaGrange, GA 30241-1088Kenbigstar@aot corn

This is notification that at 9:00 a.ni. on Saturday, November 22, 2014, at theoffices of Kenneth Gordon, Esq., located at 5180 Lone Oak Road, Hogansville,Georgia, counsel for Nancy Michelle Murphy, will proceed to take the depositionupon oral examination of Nan Freeman, individually, pursuant to OCGA §9-11-30 and the laws of Georgia, and, as in her capacity as the representative ofFreeman Reporting, Inc., pursuant to OCGA §9-11-30(b)(6) and the laws ofGeorgia.

The scheduling of this deposition was pursuant to agreement of counsel.

The 30(b)(6) representative should be required to testif, about the preparation of

transcripts, software programs used and billing procedures in all cases in which

PLAINTIFF'SEXH7


Nan Freeman or any reporter employed by Freeman Reporting, Inc., acted as Official

Court Reporter for any Court in the State of Georgia.

The deposition will be taken before a notary public or some other officer dulyauthorized by law to take depositions and may be recorded by videotaping and bystenographic means. The oral examination will continue from day to day until its

completion.

Pursuant to OCGA §9-1 1-30(b)(5), Nan Freeman and Freeman Reporting, Inc.

are requested to produce:

Accurate copies of the transcripts of proceedings in which Nan Freeman

was the Official Court Reporter in the case of John Harold Murphy y. Nancy

Michelle Murphy, No. 2012-V-413 in the Superior Court of Coweta County.

Invoices to counsel for Nancy Michelle Murphy and John Harold Murphy

for transcripts of proceedings in which Nan Freeman was the Official Court Reporter

in the case of John Harold Murphy y. Nancy Michelle Murphy, No. 2012-V-413 in

the Superior Court of Coweta County.Invoices from Freeman Reporting, Inc., for transcripts of proceedings

billed to the governing authorities of the Counties of Carroll, Troup, Meriwether,Heard and Coweta for transcripts produced between April 1, 2012 and June 25, 2014.

Invoices from Freeman Reporting, Inc., for transcripts of proceedingsbilled to any entity of the State of Georgia for transcripts produced betweenApril 1, 2012 and June 25, 2014.

Any written communications between Nan Freeman and Judge A.Quillian Baldwin, Jr., and/or his agent relating to the case of John Harold Murphyy. Nancy Michelle Murphy, No. 2012-V-413 in the Superior Court of CowetaCounty.

Page 2 of4


6. Any written communications between Nan Freeman and Judge A.Quillian Baldwin, Jr., andlor his agent relating to the above-styled litigation in which

Nan Freeman and Freeman Reporting, Inc. are defendants, either before or after the

Complaint was filed in the Superior Court of Fulton County.

Any attorney representing Nan Freeman or Freeman Reporting, Inc., is invited to

be in attendance and participate in accordance with applicable law.

All such persons, as allowed by law, may attend the deposition and participate as

allowed by law.

This 13th day of November, 2014.


Millard FarmerGeorgia Bar No. 255300

P.O. Box 1728Atlanta, GA 30301-1728(404) 688-8116rnillardfarrner@rnillardfarrner. cornCounsel for Nancy Michelle Murphy

Page 3 of 4


I hereby certiFy that I have this day served a copy of the foregoing Notice ofDeposition of Nan Freeman, Individually, and as 30(b)(6) Representative ofFreeman Reporting, Inc., upon counsel for the opposing parties by electronic mail

and United States Postal Service with adequate first-class postage attached thereon,

addressed as follows.

Kenneth Gordon, Esq.P.O. Box 1088LaGrange, Georgia 30241Kenbigstar@aot corn

This 13th day of November, 2014.

CERTIFICATE OF SERVICE

aehh' TaM*-Millard Farmerrnillardfarmer@millardfarmer. cornCounsel for Nancy Michelle Murphy

Page 4 of 4


Fiscal Year 2013 Detail Payments

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Records: i to i Of IOrganizationçJcEpIL COUTS

Vendor Name q Payment Amount DescriptionFREEMAN REPORTING INC

Funding Source54460.00 OOAS-CCURT REPORTER STATE/OTHER

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Records: i to I of IOrganization Vendor Neme Pay litent Amount Description Funding SourceSUPERIOR CCUtT FREEMAN REPORTING INC y3,840OO DOS-CCURT REPORTER STATE/OTHER

Records: I to i of IOrganization Vendor Name y Payment Amount Description Funding SourceSUPERIOR CCUSTS FREEMAN REPORTING INC '3S4'j»)O DOAS-COURT REPORTER STAT E CT H E S

Records: i IO I of IOrganization - Vendor Neme Pyifleuit Amount Description Funding SourceSUPERIOR COURTS FREEMAN REPORTING INC 3.54000 DOAS-COURT REPORTER sTATE/OTHER


September 22, 2012

Federal ID Number: 01-0566702

INVOICE NO. 12-188

Mr. Millard FarmerAttorney at LawP.O. Box 1728Atlanta, GA 30303

FREEMAN REPORTING, INC.Certified Court Reporters

P.O. Box 3387LaGrange, GA 30241

706-812-8348

DUE UPON RECEIPT

In the matter of: Murphy V. Murphy, et a!Jurisdiction: Superior Court of Coweta CountyCase Number: 2012-V-4 13Date; August 30, 2012

One-half of takedowOriginal and one copy of transcriptPostage

TRANK YOU

$ 54.14328.86

TOTAL $ 385.00


Millard Farmer

Prom: Julia Harris [email protected]> on behalf of Quillian Baldwin<[email protected]>

Sent Thursday, June 191 2014 11:26AMTo: [email protected]: Robertson, Beth; [email protected]; Taylor Drake ([email protected]};

[email protected] Murphy y. Murphy 12-V-413; Coweta County Superior Court

Dear Millard:

Nan Freeman has discussed with me your latest emails back and forth and she is deeplyconcerned about having to deal with a law suit which she cannot afford.

I have told her since this has become so stressful for her, that we should turn over a copy ofher audio recording of the hearing you are concerned with. As far as I can tell, you are notlegally entitled to the audio recording. However, Nan is willing to turn a copy over of suchrecording by placing a sealed copy in the Murphy case, File No. 12-V-41 3, in the Clerk ofCourt's Office along with an unsealed copy to be a part of the public record of which you oranyone else can review the audio recording at your pleasure.

i will file an order instructing the Clerk that the sealed recording shall not be opened exceptin open court but that you may review the unsealed recording wherever you would like inthe courthouse. This should satisfy your request. However, you, Mr. King1 anyone on yourstaff or employed by you, may not download or copy said recording in any way whatsoever.

By having the copies in the file, the unsealed copy will be available for use in an appeal orany other proceeding along with the original. Despite what Nan is willing to do, if you file alaw suit against Ms. Freeman, she will not voluntarily give you directly or file with the clerk'soffice, copies of said audio recording. Of course, you already have a copy of the transcriptas legally required by law.

We look forward to your immediate response.

Attachment 1, Page 1 of 1i


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CERTI FICATE

STATE OF GEORGIA )

COUNTY OF TROUP )

I, Nan D. Freeman, being a Certified Court Reporter

and Notary Public in and for the State of Georgia at Large,

certify that the foregoing transcript is a true record of the

proceedings and exhibits in the case of John Harold Murphy y.

Nancy Michelle Murphy, Case Number 2012-V-413 in the Superior

Court of Coweta County; that I am neither a relative nor

employee nor attorney nor counsel of any of the parties, nor

a relative nor employee of such attorney or counsel, nor

financially interested in the action.

This certification is expressly withdrawn and

denied upon disassembly, photocopying or duplication in any

manner or upon certification of the foregoing transcript or

any part thereof including exhibits, if any, by any person or

entity other than by the undersigned official certified court

reporter. This certification is further expressly withdrawn

and denied absent the original signature and the original

seal of the undersigned official court reporter, as set out

below.

WITNESS my hand and seal at LaGrange, Troup County,

Georgia, this the 5th day of June, 2014.

Nan D. Freeman, CCR, B-1939

42


LK/ls

LARRY KINGATTORNEY AT LAW

210 North McDonough Streetp Ø. Box 1648

Jonesboro, Georgia 30237(770) 471-3835Fax (770) 471-8200

Email [email protected]

June 10, 2014Via Federal ExpressNathan Thomas Lee and Jerry Ann ConnerCounty Attorneys for Coweta CountyGlover & Davis, P.A.10 Brown StreetNewnan, GA 30264

Via Federal ExpressC. Jerry WillisCounty Attorney for Troup CountyWillis McKenzie LLP300 Smith StreetLaGrange, GA 30240

Certified Mail - #7010 0290 0002 1291 9517Return Receipt Requested

Nan D. FreemanFreeman Reporting, Inc.p. 0. Box 3387LaGrange, GA 30241

Dear Mr. Lee, Ms. Conner, Mr. Willis and Ms. Freeman:.

Pursuant to the prcÑisibns of the Georgia Open Records Act (0.C.G.A. 50-18-70 et seq.), pleaseprovide this office with the following items in your possession, custody and control.

All audio recordings of any and all hearings p'resided over by Chief Judge A. Quillian Baldwin, Jr. in civilaction rile number 2012-V-413, Coweta County Superior Court, titled John Harold Murphy y. Nancy MichelleMurphy.

All documents relating to the supplemental salary paid by Coweta County for Superior Court Judges forthe past three (3) years.

3, All documents relating to the supplemental salary paid by Troup County for Superior Court Judges forthe past three (3) years.

This firm acknowledges their financial obligation to pay forthe materials requested and will pay uponreceipt of an invoice all fees required for the retrieval and copying of the requested records pursuant to theGeorgia Open Records Act.

The Georgia Open Records Act requires a response time within three (3) business days. . If access tothe records being requested will take longer than three (3) days, please contact thìs office with informationabout when the records can be expected.

If you deny any or all of this request, please cite each specific exemption you feel justifies the refusalto release the information. Thank you.

Attachment 5, Page 1 of iAttachment 154, Page 45 of 53


P.O. Box 3387LaGrange, GA 30241

706-812-5348

June 12,2014

Mr. Larry KingAttorney at LawP.O. Box 1648Jonesboro, GA 30237

Re: Open records request, June 10, 2014John Harold Murphy vs. Nancy Michelle MurphyCivil Action Number 2012-V-4] 3

Dear Mr. King:

The audio recording ola court reporter is the personal property of the court reporter and the work productof the court reporter for use in producing the transcript of a proceeding. The certified transcript ¡s theofficia] record of the proceeding.

When requested by the panics, transcripts have been produced and a copy provided to each party, with theoriginal and a copy having been filed in the office of the Clerk of Superior Court in Coweta County.

IPLAINTIFF'S

Attachment 6, Page 1 of i

I have fulfilled my responsibility as required.

Yours truly,

,, j,,Nan D. l:'reeman


IN THE SUPERIOR COURT OF COWETA COUNTY

STATE OF GEORGIA

JOHN HAROLD MURPHY,

Plaintiff

vs. CASE NUMBER: 2012-V-413

NANCY MICHELLE MURPHY,

De fendant

Transcript of Proceedings

before

the Honorable A. Quillian Baldwin, Jr., Judge,

at the Coweta County Courthouse

Newnan, Georgia

on the day 27t of May, 2014

PJDDENDUM


P.O. Box 3387LaGrange, Georgia 30241

(706) 812-8348


PROCEEDINGS

[REPORTER'S NOTE: This addendum is being filed because

this final objection, made after the judge's ruling,

although taken down at the time, was inadvertently

omitted from the main transcript.]

MR. DRAKE: Thank you.

MR. FARMER: Your Honor, may we have an immediate

review for --

THE COURT: No.

MR, KING: May we go on the record, Your Honor, and

state that you have not allowed Ms. Murphy to present a

defense to this contempt, that you have, as a sanction,

transferred custody. In no case in the State of Gebrgia

has a sanction ever transferred custody of the children.

MS. MURPHY: (Unintelligible.)

MR. KING: And we want to put that on the record as

an objection to the conduct of the Court and the ruling

of the Courtthat has just been made that we have been

denied due process of law. We've been denied the

opportunity to present witnesses to this Court about

these children, and we sternly and strongly object.

THE COURT: Well, let me just tell you this, both

to you, and Mr. Farmer, and to Ms. Murphy: If y'all

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would do what you were supposed to do, you wouldn't be

having this problem so --

Wait just a minute.

Blame yourself (indicating); blame yourself

(indicating); blame yourself (indicating)

That's what we're doing. I told her the last

time --

MS. MURPHY: I haven't --

THE COURT: Don't -- be quiet, please, ma'am.

MS. MURPHY: (Unintelligible.)

THE COURT: Be quiet.

I told her --

If you speak up again, I'm going to put you in

jail. Do you understand me?

I told her the last time to go see this -- see

this doctor, and I told y'all then that if she didn't do

it, I was going to consider taking the children and

putting then with her (sic). He (sic) hasn't done it.

I told you that the last tine, and I'm tired of this

stuff.

If y'all had done what you were supposed to

do, if y'all had done your job, if you had done your

job, this thing would have been over two years ago. It

wouldn't have all the expense involved. And y'all

haven't been doing your job, and you need to be -- you

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need to be checking on that instead of checking on what

I'm doing. Okay? You're not doing your job.

All right. That's it.

MR. FARMER: May I respond?

We have the children here to present evidence.

We wish to present evidence, and you're preventing us

from presenting evidence.

THE COURT: It's over with. Stop taking down.

(Proceedings concluded.)

4


June 5,2014

Federal ID Number: 01-0566702

INVOICE NO. 14-108

TO:Mr. Millard FarinerAttorney at LawP.O. Box 1728Atlanta, GA 30301

In the matter of: Murphy y. MurphyJurisdiction: Superior Court of Coweta CountyCase Number: 2012-V-413Date: May 27, 2014

One-half of takedown $ 21.65One-half cost of tnnscript 116.85

TOTAL $ 138.50

THANK YOU


P.O. Box 3387UGrange, GA 30241

706-812-8348

DUE UPON RECEIPT

0:rÇt

(Q-


October 16,2013

Federal ID Number: 0 l-0566702

INVOICE NO. 13-148

TO:Mr. MiHard FannerAttorney at LawP.O. Box 1728Atlanta, GA 30301

In tite matter of: Murphy y. MurphyJurisdiction: Superior Court of Coweta CountyCase Number: 2012-V-413Date: October 3,2013

One-half cost oftranscripL S 352.86

TI-lANK YOU!


RO. Box 3387LaGrange, GA 30241

706412-8348

DUE UPON RECEIPT


PETER J. SKANDALAKIS

Millard FarmerAttorney at Lawp. 0. Box 1728Atlanta, Georgia 30301-1728

Dear Millard:

I have read your letter of July11, 2014 regarding court reporter, Ms. Nan Freeman,listened to the audio recording and reviewed the pleadings and transcripts furnished along withyour letter.

I note you have flied, on behalf of your client Nancy Murphy, a civil suit in Fulton Countyagainst Ms. Freeman and against the Program Manager, the Chairperson, and each Member ofthe Board of Court Reporting of the Judicial Council of Georgia seeking Declaratory Judgment,Injunctive and other Relief, Civil Action No.2014 CV 2482210, pertaining to the same conductas set forth in your letter and accompanying documents.

Due to the aforementioned litigation, i am reserving further action concerning thismatter until the civil suit is resolved. Please let me know when your civil case is concluded andthe results of that litigation.

Sincerely,

LMstrict AttorneyCoweta Judicial Circuit

August 12, 2014

Carroll County CourthousePO Box 338Carroilton, GA 30112phone: (710) 830-2171Fax: (770) 830.2170

Coweta Co. Justice CenterPO Box 1918Newnan, GA 30264Phone: (770) 254-7300Fax: (770) 254-7305

FL SaLL

Heard County CourthousePo Box 730Franldin, GA 30217Phone: (706) 675-0955Fac (706) 675-0958

Peter J. SkandalakisDistrict Attorney

PJS:bwc

¡8ITMedwether County CourthousePo BoxSZOGreenville. GA 30222Phone: (706) 672-1302Fax: (706) 672-1201

MONIQUE F. KIRBYChief Assistant

UNOA W. liPTONVictim Assistance Director

Troup Co. Government Center100 RIdley Ave. SuIte 3500LaGrange, GA 30240Phone: (706) 298-3708Fax: (706) 298-3709Attachment 154, Page 53 of 53

Attachment 161

Voluntary Recusal Order of Judge A. Quillian Baldwin, Jr.

February 9, 2015

Attachment 161

Voluntary Recusal Order of Judge A. Quillian Baldwin, Jr.

February 9, 2015

Attachment 162

Order of Recusal

Judge John T. Simpson, Judge Dennis Blackmon and Judge William G. Hamrick III

February 11, 2015

Attachment 162

Order of Recusal Judge John T. Simpson, Judge Dennis Blackmon

and Judge William G. Hamrick III

February 11, 2015

Attachment 163

Order of Recusal

Judge Jack Kirby, Judge Emory L. Palmer and Judge W. Travis Sakrison

February 19, 2015

Attachment 163

Order of Recusal Judge Jack Kirby, Judge Emory L. Palmer

and Judge W. Travis Sakrison

February 19, 2015

Attachment 164

Part 1 of Motion for an Investigation, Public Disclosure and Termination of the Corruption of Judge A. Quillian Baldwin, Jr.

Tendered on January 30, 2015 with a

Request for Permission to File, But Not Permitted to be Filed

Attachment 164


Tendered on January 30, 2015 with a

Request for Permission to File, But Not Permitted to be Filed

Attachment 164


Attachment 164


Motion for Investigation of Judge Baldwin’s Corruption With Plea to Jurisdiction Page 1 of 147

IN THE SUPERIOR COURT OF COWETA COUNTY STATE OF GEORGIA

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

Nancy Michelle Murphy, Defendant

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


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

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

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

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.


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.


Page 4 of 147

1.1.1.4 Michelle Murphy, a hair stylist, could not financially afford to

defend herself against this conglomerate of foes, none the least of which was

Judge A. Quillian Baldwin, Jr., as John Harold Murphy, with Judge Baldwin’s

tacit approval, ceased making child support payments that were necessary for

Michelle Murphy to use to protect Jack and Thomas.

1.1.1.5 On May 27, 2014, Judge Baldwin transferred temporary custody to

John Harold Murphy with a June 5, 2014 Order. John Harold Murphy took

advantage of that Order in an attempt to alienate the children from their mother

by removing the children thousands of miles from their home in Newnan, GA

to St. Thomas, USVI where he abandoned the parenting discipline of Michelle

Murphy and attempted to gain favor with Jack and Thomas by providing them

a lifestyle that included serving them alcoholic beverages and making

alcoholic beverages available to them on a regular basis.

It took Michelle Murphy until the January 1, 2015 family meeting in Utah to establish an admission that the fondling and sexual misconduct accusations against her were fabricated and fraudulently used in the Courts. The meeting

resulted in disclosure of another fraudulent fabrication. That admission, known to

Michelle Murphy, was that Taylor Drake’s initial reason for an immediate hearing

was knowingly fabricated in order to select Judge Baldwin. The reason stated for the

immediate hearing was fraudulently fabricated by Taylor Drake, i.e., Michelle

Murphy was not threatening to take Jack and Thomas out of school and move to

South Carolina. That was a Taylor Drake statement to obtain an immediate hearing

in order to select Judge Baldwin. John Harold Murphy states that he did not allege

that fear.


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 counsel for 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.


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


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


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 ' recovery 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


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


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 associated

lawyers 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


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 lawyers

who 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


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*


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 misconduct

of 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


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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


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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.


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


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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.


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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.


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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.


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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.


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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.


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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


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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


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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.


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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.


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


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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.


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


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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


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/


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misconduct of Judge Baldwin and adhere to the LAW* that mandates

disqualification. The corruption of Judge Baldwin has yet to yield to that

change that will happen at some point in time, as even Judge Baldwin has not

presented himself for examination under oath for the violations that required

his disqualification from the beginning of the case until this very moment.

1.5.1.13 It took more than ten years to change the underrepresentation of

African American persons on juries in the Coweta Judicial Circuit, and that

did not occur without the assistance of the federal courts. Counsel for Michelle

Murphy endured each of those ten years, as Judge Baldwin, then a lawyer in

private practice, never raised the issue to the knowledge of counsel. It also took

a number of years to remove United States District Court Judge Jack Camp,

another judge with roots to the Glover & Davis P.A. Some of the false

swearing involved in this case may have opened the very difficult federal court

door to address Chief Judge Baldwin’s corruption that is accomplished with

his participants.

1.5.1.14 The corruption of Judge Baldwin will be even easier to explain to

the public than the conduct of the Judge Amanda Williams, if the same

investigative assistance is provided to Michelle Murphy.

1.5.1.15 Taylor Drake and the Glover & Davis lawyers had no more than dislocated Jack and Thomas to St. Thomas, USVI when Taylor Drake wrote a letter to Millard Farmer and asked that he provide him the reason that John Harold Murphy should not terminate the child support that John Harold Murphy contractually agreed to provide to Michelle Murphy that was only conditioned upon the children reaching a designated

age. Millard Farmer replied to that letter as included below.


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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.


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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


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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


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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,


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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


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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?

.


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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


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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 Kirby recommended 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 only

a 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.


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. . . 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


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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 of 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


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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.


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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.


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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 as a step toward addressing the unethical conduct created by the Glover & Davis judge selection process and thereby Guardian ad Litem selection process.


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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 never occurred 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 to represent 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


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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.


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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


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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.


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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 no

outside 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 Judge Baldwin

had not allowed any evidence about the selection of a guardian as litem and

the $5000 retainer and $250 per hour ordered for the services of Melissa

Griffis is above the justifiable hourly rate for the professional services of

Melissa Griffis.


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3.2.2.8 The recorded questioning of Melissa Griffis at the initial meeting

with Melissa Griffis and Taylor Drake, after the appointment by Judge

Baldwin, was prohibited jointly by Melissa Griffis and Taylor Drake, as they

refused to allow the court reporter to take down the conference.

3.3 On Tuesday, May 1, 2012, counsel for the Michelle Murphy and Children

Parties met with the Guardian ad Litem, appointed by Judge Quillian Baldwin,

Melissa Griffis, and with counsel for the Haugerud/Murphy Parties, Taylor Drake.

3.4 When Taylor Drake entered the conference room at the law office of Melissa

Griffis, where the court reporter was set up to record the meeting, Taylor Drake, in

a loud voice for the size of the room, the prevailing calm and his usual demeanor,

proclaimed, “We are not going to allow this to be recorded.” Melissa Griffis and

Taylor Drake had met before they entered the conference room at the law office of

Melissa Griffis.

3.5 This Freudian slip of “WE” by Taylor Drake in speaking of the Guardian ad

Litem as “WE” brought to mind one of the oldest stories floating around in the

Coweta Judicial Circuit about judicial/lawyer misconduct.

3.6 The story setting begins at a trial in Carrollton, Georgia many years ago when

Judge Samuel J. Boykin was presiding at a trial in which his brother, Shirley C.

Boykin, was representing the plaintiff.

3.6.1 As one might imagine, the trial was going quite well for Shirley C. Boykin

and his client.

3.6.2 The lawyer for the well-heeled defendant was not a slow learner, and

asked for a chambers conference with Judge Samuel J. Boykin and his brother,

Shirley C. Boykin.


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3.6.3 The lawyer for the defendant stated that he wished to make an offer of

settlement. The two Boykin brothers agreed that an offer of settlement would be

appropriate.

3.6.4 The defense lawyer made a substantial offer of settlement that put a large

smile on Shirley C. Boykin’s face.

3.6.5 No sooner had the lawyer completed his offer, Judge Samuel J. Boykin

arose from his chair and blurted, “WE can’t accept that offer. WE must have

more. Offer US more!”

3.7 The “WE” and the “US” at the May 1, 2012 conference at the guardian at

litem’s office was very quickly identified as Taylor Drake, counsel for the

Haugerud/Murphy Parties and Melissa Griffis, the appointed Guardian ad Litem.

3.8 The “WE” and the “US” refused to allow the court reporter to take down

the conference.

3.9 The Refusal of the “WE” and the “US” to Allow a Recording of the May 1,

2012 Conference with the Guardian ad Litem was the Same Signal that

Judge Quillian Baldwin Inadvertently Sent at the April 26, 2012 In-Chambers

Conference.

3.10 Counsel for the Michelle Murphy and Children Parties, after the conference

with Taylor Drake and Melissa Griffis, went a-trekking for information once again.

Not only did counsel for the Michelle Murphy and Children Parties find the smoking

gun, counsel found the owners of the gun.

3.11 Counsel for Michelle Murphy found that Taylor Drake is the Chairman of the

Election Campaign Committee of Emory Palmer, who is a lawyer seeking to be

elected judge in the Coweta Judicial Circuit. This was no secret. Melissa Griffis is

a member of Emory Palmer’s Election Campaign Committee. Melissa Griffis


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admitted this to counsel for the Michelle Murphy and Children Parties at the May

1, 2012 conference when questioned by counsel for the Michelle Murphy and

Children Parties.

3.12 At the May 1, 2012 conference, counsel for the Michelle Murphy and

Children Parties emphatically informed Melissa Griffis that she had a serious

conflict of interest in attempting to be the guardian ad litem in this case when she

regularly appeared before Judge Quillian Baldwin and Judge Jack Kirby

representing clients in her private domestic relations practice.

3.13 Melissa Griffis was told, in no uncertain terms, that she would not be allowed

to serve as the Guardian ad Litem without an appellate order approving her

appointment. Melissa Griffis steadfastly stated that she would proceed in the case.

3.14 In order to marshal information, the Rubber Soles and the Souls of Counsel

for the Michelle Murphy and Children Parties Once Again Hit the Street.

3.15 The facts learned on this second trek even shocked counsel for the Michelle

Murphy and Children Parties.

3.16 A reasonable person can surmise that Judge Quillian Baldwin, by

appointing Melissa Griffis with a hefty advance and hourly rate, is transferring

funds belonging to litigants to supporters of his chosen candidate, Emory Palmer.

3.17 Shame, Shame, Shame on both Judge Quillian Baldwin and Melissa Griffis

for not initially disclosing this fact to counsel for Michelle Murphy.

3.18 Shame, Shame, Shame on the conduits of the support of

Judge Quillian Baldwin for Emory Palmer or any candidate for political office.

3.19 A few days before the April 26, 2012 conference at Melissa Griffis’ office,

Taylor Drake, Melissa Griffis and others sponsored a fundraising event for Emory

Palmer.


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3.20 Judge Quillian Baldwin, in violation of the Code of Judicial Conduct,

attended the fundraiser for Emory Palmer at the Del’Avant in LaGrange, Georgia

and within days thereafter, executed an Order submitted by the sponsor of the

fundraiser without reading the Order, or hearing any evidence. Cannon 2 of the

Georgia Judicial Code of Conduct provides that “A. Judges shall respect and

comply with the law and shall act at all times in a manner that promotes public

confidence in the integrity and impartiality of the judiciary.”

3.21 Judge Allen B. Keeble also showed strong support for Emory Palmer by

attending the fundraiser.

3.22 Melissa Griffis has contributed to and offered strong support for

Emory Palmer, whom Judge Quillian Baldwin is obviously publically supporting by

his attendance at the fundraiser for Emory Palmer sponsored by the Campaign

Committee to Elect Emory Palmer.

3.23 A prudent person would think that Judge Quillian Baldwin could have waited

a little longer than two days to have doled out a large financial plum to Melissa

Griffis and Taylor Drake, or at least could have heard evidence on the matter that,

at least, would have given the appearance of fairness.

3.24 Melissa Griffis had an ethical obligation not to participate in the unethical

conduct of Judge Baldwin, who issued the Order that provided her money.


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4. The Conduct of Judge A. Quillian Baldwin, Jr. is a Detriment to the Michelle

Murphy and Children Parties, which Melissa Griffis Should have Detected

and/or at a Minimum Should Have Inquired.

4.1 The detriment to the Michelle Murphy and Children Parties by

Judge Quillian Baldwin was his signing of an Order that he had never read, that

counsel for the Michelle Murphy and Children Parties were not even provided an

opportunity to read after Taylor Drake filled in blanks and struck through portions

on a previously sent draft and stuck it into the hands of Judge Quillian Baldwin to

hastily sign.

4.2 This conduct by Judge Quillian Baldwin was both an appearance of an illegal

act and actual illegal conduct. This conduct resulted in an Order that leaves

confused at best even the fact that Judge Quillian Baldwin stated that Michelle

Murphy would not be required to pay for the guardian ad litem.

4.3 When counsel for the Michelle Murphy and Children Parties stated that the

Order appointing the guardian ad litem would require Michelle Murphy to pay fees

that she could not financially afford, as she could not compete with the

Haugerud/Murphy Parties’ well-heeled financial condition and cannot afford the

added expenses of a guardian ad litem, Taylor Drake, counsel for John Murphy,

contrary to a correct statement of the facts, stated to Judge Baldwin and counsel for

Michelle Murphy that there was no provision in the proposed Order requiring

Michelle Murphy to share in the cost of the guardian ad litem.

4.4 This statement about the potential liability to Michelle Murphy under the

proposed Order was strongly disputed by counsel for the Michelle Murphy and

Children Parties. Judge Quillian Baldwin then agreed that John Murphy would be


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required to pay the guardian ad litem fees; however the Order has not be corrected

to reflect this oral statement.

4.5 Taylor Drake did not fully include this protection from liability for the fees of

guardian ad litem to Michelle Murphy in the draft Order that he had prepared and

that was finalized by Taylor Drake partly striking through a portion of the draft

order with a pen. Counsel for the Michelle Murphy and Children Parties were not

provided an opportunity to view the content struck through or the handwritten

inserts into the previously prepared Order by Taylor Drake and Judge Quillian

Baldwin never read the Order to determine if his change had been included.

4.6 The following portions of the Order, executed, but not read by Judge

Quillian Baldwin leaves Michelle Murphy potentially liable to pay the costs for the

GAL in the following provisions.

The Court shall provide for the parties’s responsibility for payment of fees to the appointed experts. Order Appointing guardian ad litem Attachment 1 p. 3 In the event the GAL determines that extensive travel outside of the circuit in which the GAL is appointed or other extraordinary expenditures are necessary, the GAL may petition the Court in advance for payment of such expenses by the parties. Order Appointing guardian ad litem Attachment 1 p. 4

4.7 The following changes struck through with a pen by Taylor Drake, without

counsel for the Michelle Murphy and Children Parties having an opportunity to

review the modifications did not clearly eliminate the potential of Michelle Murphy

being required to pay compensation to the appointed guardian ad litem. It is not

known if the $8,000 to be paid by the Plaintiff was changed to $5,000 before or after


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Judge Quillian Baldwin signed the Order that he did not read or initial the change.

Michelle Murphy should not be subjected to having a judge who engages in this type

of conduct create matters that add additional unnecessary attorney fees and

litigation expenses for her.

4.8 There are other aspects of the Order that violate the statutory and

constitutional rights of Michelle Murphy, Jack Murphy and Thomas Murphy. The

following paragraph is not authorized by Uniform Superior Court Rule 24.9 and

violates the rights of Michelle Murphy, Jack Murphy and Thomas Murphy in that it

delegates the authority of the Court to a guardian ad litem.

The GAL may make temporary recommendations/adjustments during the pendency of this action regarding custody and parenting time and the parties shall follow said recommendations of the GAL. emphasis supplied Order Appointing guardian ad litem Attachment 1, p. 4

4.9 The above clause included in the Order appointing the guardian ad litem denies

Michelle Murphy, Jack Murphy and Thomas Murphy the protections afforded to

each by the United States Constitution due process, U.S. Const. amend. XIV, § 1

and State of Georgia Constitution Bill of Rights due process protection


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(Ga. Const. Art. I, § 1, ¶ 1), and the laws of Georgia.

4.10 The above clause included in the Order appointing the guardian ad litem denies

Michelle Murphy, Jack Murphy and Thomas Murphy the protections afforded to

each by the United States Constitution equal protection, U.S. Const. amend. XIV, §

1 and State of Georgia Constitution Bill or Rights equal protection (Ga. Const.

Art. I, § 1, ¶ 2). and the laws of Georgia.

4.11 A guardian ad litem is not statutorily or constitutionally authorized to make

temporary . . . adjustments during the pendency of this action regarding custody .

. .

4.12 Judge Quillian Baldwin illegally abrogated his judicial responsibility to

counsel for the Michelle Murphy and Children Parties.

4.13 Michelle Murphy, Jack Murphy and Thomas Murphy were victimized by

judges in the Coweta Judicial Circuit failing to give proper attention to their judicial

obligations, e.g., Delia T. Crouch not adequately reviewing an order prepared by

Jack Kirby while he was in private practice representing John Murphy in the

original divorce. This type of shoddy, irresponsible legal work by Delia T. Crouch

resulted in creating hours of attorney fee costs to Michelle Murphy in the original

divorce action. This causes undersigned counsel to be protective, as it is obvious

from reading those transcripts that this Court fails to protect litigants.

5. Judge Quillian Baldwin Provided the Michelle Murphy and Children Parties the Equivalent of a McDonald’s Drive-Through Service; there is one Difference -- McDonald’s Provides a Legal Service.

5.1 Judge Quillian Baldwin provided the Michelle Murphy and Children Parties a

McDonald’s drive-through window type of justice in a case in which Judge Quillian

Baldwin had never read a pleading, never seen an affidavit and never heard a stitch


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of evidence, long before the time set for a response by counsel for the Michelle

Murphy and Children Parties, under conditions that did not constitute an

emergency. There is a standing Order of the Court that protects the rights of the

parties. See, Attachment 5.

5.2 Counsel for the Michelle Murphy and Children Parties initially expressed and

still express strong opposition to the appointment of any guardian ad litem. The

Court was not supplied any evidence to support such appointment that will create

an additional large amount of attorney fees for Michelle Murphy.

5.3 Counsel for the Michelle Murphy and Children Parties attempted to explain

the detriment caused to the Michelle Murphy and Children Parties of the

appointment of a guardian ad litem at this stage in the proceedings, when counsel

was cut off by Judge Quillian Baldwin from exercising even an effective right of

allocution on behalf of the Michelle Murphy and Children Parties.

5.4 Even a quick reading of Taylor Drake’s request in his one page form motion

for a guardian ad litem will reveal that he did not ask for Judge Quillian Baldwin to

squelch, as he did, the Michelle Murphy and Children Parties’ statutory and

constitutional rights. The motion request of Taylor Drake for John Murphy was as

follows.

In the event Defendant Nancy Michelle Muphy (“Defendant”) does not consent to this Court granting this Motion [the Motion for a guardial ad litem] and if Plaintiff and Defendant are unable to agree on the individual who will serve as the guardian ad literm in this case, Plaintiff requests this Court allow him to present evidence on April 26, 2012 at 9:00 a.m. to support this motion being granted. Attachment 2, Motion for Appointment of Guardian ad litem, p.1

5.5 Once Taylor Drake detected that Judge Quillian Baldwin had bitten his verbal


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bait, he apparently abandoned his written commitment to present evidence on his

motion for the guardian ad litem, if the motion was opposed, as it was strongly

opposed.

5.6 Judge Quillian Baldwin provided McDonald’s drive-through window type of

justice by informing counsel for the parties that he would grant Taylor Drake’s

motion to appoint a guardian ad litem without being presented any type of legal

necessity for the guardian ad litem. The Motion for Appointment for Guardian ad

Litem was a bare bones motion and contained no facts and did not comply with Unif.

Sup. Ct. R. 6.1. Judge Quillian Baldwin never even took a look at the motion or the

Complaint and was provided no evidence to support the motion; nor, was Michelle

Murphy provided thirty days to respond to the motion. USCR 6.1 in part, is as

follows.

6.1. Filing In civil actions every motion made prior to trial, except those consented

to by all parties, when filed shall include or be accompanied by citations of supporting authorities and, where allegations of unstipulated fact are relied upon, supporting affidavits, or citations to evidentiary materials of record.

5.6.1 The only apparent judgment in deciding the issue made by Judge Quillian

Baldwin was his preconceived judgment of the status of the counsel for the

parties, as made through the glasses of his prejudicial, illegal bias and haste to

quit fulfilling his judicial obligation to the people in the Coweta Judicial Circuit.

5.6.2 Judge Quillian Baldwin signed the Order prepared by Taylor Drake

without reading the Order and figuratively told counsel for the Michelle Murphy

and Children Parties to pull down to the next McDonald’s type of drive-through

window to pick up Taylor Drake’s Order.


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6. Judge E. Byron Smith, Judge Allen B. Keeble, Judge A. Quillian Baldwin, Jr. and Judge Dennis Blackmon Each Violated Uniform Superior Court Rule 3.1 in the Original Divorce Case that John Murphy brought against Michelle Murphy. 6.1 If there is doubt about the wisdom of USCR 3.1, one only needs to view the

documents in the initial divorce proceedings in this case, which Judge Baldwin

inaccurately maintains, as follows, in his Order denying his Disqualification.

6.2 Judge Dennis Blackmon was the judge who entered the divorce decree, as the

following excerpts from the Final Decree in John Harold Murphy v. Nancy Michelle

Murphy; Civil Action File No. 2004-CV-494, in the Superior Court of Troup County,

Georgia. Attachment 13 contains the Final Decree in John Harold Murphy v. Nancy

Michelle Murphy; Civil Action File No. 2004-CV-494, in the Superior Court of

Troup County, Georgia that, in part, identifies Dennis Blackmon as the Judge.

* * *


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* * *

6.3 The entry of the child support in the final decree rendered by Judge Dennis

Blackmon was $1,500 per month for each of the two children, rather than the $3,000

per month for the two children with two years difference in their ages that was


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announced at a hearing over which Judge Baldwin presided.

6.4 The relevance of the difference in the agreed amount in open court of $3,000

per month in child support for Michelle Murphy and the $1,500 per child per month

amount in the written agreement prepared by Jack Kirby is that there is a two year

difference in the ages of the children. First, the following is the open court statement

of the agreement before Judge Baldwin, which was followed by the written

agreement and the final decree before Judge Dennis Blackmon.

* * *

6.4 Judge Kirby’s statement about this issue at his deposition follows.

Page 10, Line 15:

15: A. I don't remember the terms, but I'm sure

16: they're on the record.

17: Q. Right. And there's one point in there

18: where the children -- in the transcript there the

19: children were involved, the minor children were given

20: child support of $3,000. It reflects it in -- I'm

21: just asking you to assume that.

22: A. Okay.

23: Q. And then in the written agreement it ended

24: up being memorialized in the written agreement as


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25: $1500 per child. Do you have any independent memory

00011:

01: of how that took place or anything?

02: A. Not really, no.

6.5 The far more substantial detriment to Michelle Murphy during the divorce

proceedings, in violation of USCR 3.1, in which the case was switched among four

or five judges, relates to the failure of John Murphy to disclose stock options that he

held that were worth more than $180,000. This $180,000 in stock options was

omitted from the settlement that Jack Kirby was able to have enforced. The

Disclosure by John Murphy on his sworn financial affidavit was as follows, which

shows a complete absence of disclosure of this asset.

* *

*

4.5.1 The deposition testimony by Judge Kirby about John Murphy’s failure to

disclose the stock option asset, in part, was as follows.

Page 11, Line 9: 09: Q. Okay. And then there was some dispute 10: about the discovery in that case. Do you have any -- 11: about stock options not being revealed. Do you have 12: any memory of anything about that? 13: A. Not really, no. I mean, the thing I 14: remember most is I believe Ms. Crouch took about a 15: ten-hour deposition of my client, twelve maybe. We 16: started about 10:00 in the morning and finished about


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17: 9:30, 10:00 at night in her office. I remember that. 18: Q. Are you familiar with that she consumed 19: about $38,000 of Michelle Murphy's money representing 20: her? * * * Page 23, Line 1: 01: Q. Well, it depends on who writes them. When 02: I write them they're facts. You felt that way when 03: you wrote them, didn't you, your pleadings? 04: A. I intended for my pleadings to be factual, 05: and I was pretty scrupulous about making sure they 06: were. 07: Q. And you can appreciate that I'm the same? 08: A. Well, no, I really can't. 09: Q. Okay. Tell me why you can't. 10: A. Well, in one thing I read in your 11: pleadings in this case was that I intentionally 12: helped John Murphy secret assets accusing me of 13: illegal and unethical conduct. That's a lie. 14: Q. You didn't know about the stock options? 15: A. Whatever I knew about I revealed. I 16: didn't help anybody hide anything. Life is too 17: short, Mr. Farmer. That ain't the way I work, and I 18: thought you knew me better than that. 19: Q. Well, you did know that it came up that it 20: wasn't revealed in discovery about the stock? 21: A. I don't honestly remember that. I mean, I 22: don't. I'm not saying it didn't, I just don't 23: remember it. 24: Q. If you read the transcripts and you did 25: see that there was a -- it was revealed that he 00024:


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01: didn't disclose the stock options -- 02: A. The transcript of what? 03: Q. The transcripts of the proceedings. 04: A. Of which proceedings? 05: Q. Of the proceedings in the divorce. 06: A. In court or in a deposition or -- 07: Q. In the court. 08: A. Okay. And so it came up in what way? 09: Q. It came up that Ms. Crouch says there were 10: stock options, and it came up as to whether the stock 11: options were an asset or not, and you would agree 12: that stock options are an asset? 13: A. Potentially. It depends on the stock 14: option. You know, some are exercisable, some are 15: not, some if you exercise them it would cost you 16: money. It just depends on the circumstances at the 17: time. 18: Q. But it would be -- you're supposed to 19: disclose them as an asset, right? 20: A. Possibly, yeah. 21: Q. I mean, if the stock options had the 22: potential of being as much as over $100,000 in value 23: they certainly should be? 24: A. Absolutely. 25: Q. And if those weren't disclosed then it 00025: 01: would be either -- it would be the client secreting 02: the assets if the client knew about them, or if the 03: client knew about them it would be lawyer's 04: obligation to disclose them? 05: A. If the client tells the lawyer about 06: assets the lawyer has got an obligation to disclose


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07: them. There's no question about that. What you're 08: suggesting is that he revealed them to me and I had 09: an obligation to disclose them and I didn't, and 10: that's a lie. 11: Q. Okay. And there's the transcript. I'm 12: not going to get you -- I'm not going through the 13: transcripts. But after it was -- if, in fact, the 14: issue is brought up to the Court that it wasn't known 15: at the time that there was stock options at the time 16: y'all made the agreement it wasn't known to Ms. 17: Crouch and it wasn't disclosed in the discovery, and 18: if the issue comes up at the affirmation of the 19: settlement agreement that there was stock options 20: that weren't disclosed would it be your obligation 21: then to continue to advocate that the agreement not 22: be modified to include the stock options, would that 23: be -- as an advocate would it be the position that 24: the lawyer should take? 25: A. Well, I think as an advocate you represent 00026: 01: your client's interest, and if there's an agreement 02: been made then you pursue the agreement. If there's 03: some fraud in inducing the agreement then that's the 04: other client's lawyer's obligation to pursue. [emphasis supplied] [ See, e.g., Georgia Rules of Professional Conduct R. 3.3 (a)(4) and 3.3 (b)] 05: Q. Right. We understand that. But if, in 06: fact, that you -- at that time it's disclosed that it 07: wasn't disclosed, that it wasn't disclosed in the 08: discovery, and at that time if there had been a 09: settlement agreement without that disclosure and 10: there was stock options then would that be the


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11: obligation of an advocate to advocate that the 12: agreement not been amended to? 13: A. Mr. Farmer, once the disclosure is made I 14: don't think it's the lawyer's job for the disclosing 15: party to lay down his sword and shield and just to 16: agree to whatever. You know, it is certainly ripe 17: for discussion before the Court, it's right for, you 18: know, perhaps her filing a motion to modify the 19: agreement or to withdraw consent to the agreement, 20: but I don't think I would have had an obligation to 21: advise my client that since you didn't reveal these 22: stock options you have to do this, that, or the 23: other. [emphasis supplied] I mean, at some point the judge has got to 24: make a decision about something like that. 25: Q. I understand your position. And if the 00027: 01: amount was $180,000 the value of the stock options in 02: the realm of the amount of money that was available 03: in that divorce for division that would be a 04: substantial amount of money? 05: A. In my book $180,000 is a substantial 06: amount of money under any circumstances.

6.6 After the time of the divorce of John Murphy and Michelle Murphy, Jack Kirby

became a Superior Court Judge in the Coweta Judicial Circuit in January of 2007.

After becoming a Superior Court Judge, he maintained a close friendship with John

Murphy that Judge Kirby described as follows. This friendship included visits into

the home of John Murphy and Renee L. Haugerud in Tennessee and a little Hedge

FUN boat ride on the Tennessee River with John Murphy.


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Page 12, Line 12: 12: Q. After the term, after you obtained the 13: divorce, they finally obtained a divorce, did you 14: have any relationship with him after that time? 15: A. Yeah. We continued a personal 16: relationship. We're friends. 17: Q. And what type of relationship was that 18: during that time? 19: A. We're friends. 20: Q. Okay. But I know there are friends and 21: friends. There are friends that say hello, and there 22: are friends -- 23: A. We're good friends. 24: Q. Visited in his home? 25: A. I have. 00013: 01: Q. And when did that start? 02: A. At the time I started representing him 03: during the divorce. He was already a friend of Kyle 04: Lovejoy who was my associate at the time. I think 05: that's how he came to hire me.

* * *

Page 38, Line 4: 04: Q. When you go do you visit in their home? 05: A. We have. 06: Q. And is that the one on North Bragg, the 07: house on North Bragg? 08: A. I don't know. It's right at the top of 09: incline railway. 10: Q. Looked at the railroad down? 11: A. Yeah. 12: Q. A fairly sizable house?


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13: A. A big, old house. * * * Page 36, Line 14: 14: Have you ever 15: flown on his or Renee's or the company's airplane? 16: A. No. But I've been for a ride on the boat. 17: Q. Okay. On the -- what do they call that, 18: the Hedgefun? 19: A. I don't think I've heard the name of it to 20: tell you the truth. 21: Q. Hedgefun, f-u-n? 22: A. It may be, yeah. That may be right. 23: Q. The 20 -- what is it, 35 foot or 25 foot 24: long boat? 25: A. It's a big, old boat. 00037: 01: Q. And where would that ride take place? 02: A. We were in -- is the Tennessee River in 03: Chattanooga? 04: Q. Yeah. I think it is. 05: A. We just rode down the river and back a few 06: hours. 07: Q. And was that on a social occasion -- 08: A. Yeah. 09: Q. -- that you were visiting Tennessee? 10: A. Yeah. 11: Q. You and your spouse and Renee and John. 12: Were other people there? 13: A. Yeah. * * * Page 48, Line 8: 08: Q. And are you familiar with the use of the


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09: plane, of John's plane -- 10: A. (Witness shakes head negatively.) 11: Q. You've never flown in it? 12: A. No. 13: Q. Never knew anybody that did fly in it? 14: A. John. 15: Q. Excuse me? 16: A. John. 17: Q. John? 18: A. Yeah. I understand that he uses it to get 19: his children for visitation. That's what I've been 20: told. * * * Page 49, Line 1: 01: Q. (By Mr. Farmer) Have you ever observed 02: the children in any way, John's children? 03: A. At the wedding. 04: Q. Right. But just children are children 05: running around at the wedding? 06: A. Right. 07: Q. Nothing about their behavior or conduct? 08: A. No. I know who they are, that's it. I 09: don't think I have even talked to them during the 10: divorce.

6.7 On November 30, 2005, Judge Allen B. Keeble rendered the Order that, in part,

is as follows.


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6.7 On February 15, 2006, Judge E. Byron Smith presided at a hearing. See

Attachment 11, which, in part of the February 15, 2006 discovery hearing in the

divorce heard before Judge E. Byron Smith, which contains the following opening

and concluding comments by Judge E. Bryon Smith.

* *

*


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6.8 On August 7, 2006 the following hearing took place before Judge Baldwin. This

Transcript is Attachment 12.

* * *

6.9 On December 20, Judge Dennis Blackmon granted the final decree in the

divorce, as indicated below.


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6.10 After the final decree of divorce, Michelle Murphy filed a legal malpractice

action against her lawyer, who participated with John Murphy in resolving. This

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

in the Superior Court of Coweta County, Georgia.

6.11 Judge William F. Lee, Jr. presided in that litigation after the Final Decree

was filed by entering a QDRO and other orders, as indicated below. See Attachment

14


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6.12 For Judge Baldwin to assert in the Order denying his disqualification in

which he, at a minimum, denied Michelle Murphy an opportunity to present

evidence, the following is an absolute, knowingly made misleading assertion of

compliance with the application of USCR 3.2. Judge Baldwin stated, in part, as

follows in Attachment 15.

6.13 Yes, Judge Allen B. Keeble, Judge E. Byron Smith, Judge Quillian Baldwin,

Judge Dennis Blackmon and Judge William F. Lee, Jr. each dealt with the “subject

matter” of this litigation, involving the same parties.

6.14 The case assignment system is a total disaster, in addition to being used for

unethical purposes, as the five judges who served John Murphy and Michelle

Murphy demonstrate.

7. Epilogue

7.1 The domestic relations obligations and responsibilities of the Superior

Court of Coweta County to litigants are in disarray. This disarray is created and


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caused by the inattention to the requirements and disobedience of the law by Judge

Quillian Baldwin, Judge Jack Kirby, Judge Allen B. Keeble and, to some extent

each of the judges in the Coweta Judicial Circuit.

7.1.1 These judges, while acting in concert, and, in failing to act as provided

by law, have created a situation whereby domestic relations cases in the Superior

Court of Coweta County are treated much the same as bus loadings at the

Greyhound bus station in a large metropolitan area. The difference is that the

Uniform Superior Court Rules, the laws of Georgia and constitutional

protections govern the manner in which domestic relations proceedings should

be handled.

7.1.2 This situation in the Superior Court of Coweta County exists because

these judges do not follow the law and protect the rights of litigants. Counsel for

Michelle Murphy only has standing at this time to address the disarray in the

domestic relations proceedings in the Superior Court of Coweta County

attributed to Judge Quillian Baldwin by bringing this motion to disqualify Judge

Quillian Baldwin. If this motion does not initiate the necessary changes to

terminate the unconstitutional and illegal disarray, other actions will follow.

7.1.3 This disarray also exists in the Superior Court of Troup County. An

example of the disarray occurred in the Superior Court of Troup County when

John Murphy filed for his divorce against Michelle Murphy in John Harold

Murphy v. Nancy Michelle Murphy File No. 2004-CV-494. In that case, Jack

Kirby represented John Murphy and the following five different Coweta Circuit

Judges issued Orders at various times, Judge Allen B. Keeble, Judge Quillian

Baldwin, Judge Dennis Blackmon, Judge E. Byron Smith and Judge William F.

Lee, Jr.


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7.1.4 The results of this conglomerate of judges together with the malpractice

of Michelle Murphy’s attorney cost Michelle Murphy thousands of dollars, as

John Murphy failed to disclose assets during discovery and the Court refused to

require a reopening of a settlement agreement announced to the Court.

Subsequent litigation did not recover this amount, but addressed aspects of

malpractice by Delia Tedder Crouch. See, Nancy Michelle Murphy v Delia

Tedder Crouch, in the Superior Court of Coweta County, Civil Action No.

08V2137.

7.1.5 This Motion seeks to disqualify Melissa Griffis in all related matters

among, or between the following (“Haugerud/Murphy Parties”), John Harold

Murphy (or, “John Murphy”), his spouse and controller of his income, Renee

Lynn Haugerud (or, Renee L. Haugerud”) and her hedge fund business, Galtere,

Ltd. Galtera Aircraft, LLC and associated entities (or “Galtere”), together with

additional other third party defendants in any litigation, individually and

collectively, as parties with interests affecting the rights of the “Michelle Murphy

and Children Parties” Nancy Michelle Murphy, (or, “Michelle Murphy”), her

minor children, Jack Malachi Murphy (or, “Jack Murphy”), age 13, and

Thomas Emerson Murphy (or, “Thomas Murphy”), age 11, individually

and collectively.

7.1.6 The saddest part about the dispute among the Haugerud/Murphy Parties

and the Michelle Murphy and Children Parties is that counsel for the Michelle

Murphy and Children Parties warned Taylor Drake, counsel for the

Haugerud/Murphy Parties that the one thing that would expand this litigation

and separate these parties further than they had ever been apart was for him to

seek a guardian ad litem.


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7.1.6.1 This guardian ad litem issue was John Murphy’s battle flag to

signify to the Michelle Murphy and Children Parties his political association

with Judge Jack Kirby that would affect the decisions by this Court. Counsel

for the Michelle Murphy and Children Parties pleaded with Taylor Drake to

forego seeking a guardian ad litem until the parties could engage in mending

fences. John Murphy is a huff, puff and bluff negotiator who has no feeling

about how many people, including his children, that he damages, as he

attempts to prevail with his huff, puff and bluff negotiation tactics. Taylor

Drake who only met John Murphy on the morning of the calendar call, did not

understand that by satisfying John Murphy’s psychological need to engage in

huff, puff and bluff negotiation that Taylor Drake was creating a very serious

situation for John Murphy’s source of income, Renee L. Haugerud.

7.1.6.2 John Murphy, to disrupt the dispute resolution progress that Renee

L. Haugerud and Michelle Murphy were making, wanted to have a guardian

ad litem appointed to frustrate the attempt by Michelle Murphy to reach out to

Renee L. Haugerud in order to resolve small disputes in an equitable manner.

The plan was that if small disputes could be resolved and trust established that

this would evolve into all disputes being resolved without litigation. One of the

main obstacles in resolving all disputes is John Murphy’s psychological need

to recover from his “father’s remorse” in secreting assets from Michelle

Murphy during the divorce and in abandoning his minor children when they

were high maintenance toddlers. This conduct by John Murphy left

Michelle Murphy to raise the children alone while John Murphy was moving

from bed to bed with other women until he finally married Renee L. Haugerud,

who could financially afford his lifestyle and ego by feigning that John Murphy


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was some kind of executive consultant with Galtere. The reality is that John

Murphy is best at disposing of Renee L. Haugerud’s money and causing her

trouble. Unfortunately, John Murphy, with Renee L. Haugerud’s consent, has

used assets not belonging to him for his personal use without paying either gift

or income tax on the assets. This is a problem that huff, puff and bluff

negotiating will not solve.

7.1.6.3 John Murphy facades his judicial/political strength to be derived

from Renee L. Haugerud’s multimillion dollar wealth. Her business entities

funnel non-tax paid assets to his personal uses. John Murphy’s legal and

social clout derive from his personal association with Coweta Judicial Circuit

Superior Court Judge Jack Kirby, who has been continually involved with

John Murphy since the time before he became a judge and represented John

Murphy in his divorce against Michelle Murphy. The accuracy of “Judge

Jack” providing John Murphy legal support has a short shelf life.

7.1.6.4 Only discovery will reveal John Murphy’s feigned judicial power

associated with whom the children refer to as “Judge Jack” and his illegal,

tax-free schemes in concert with Renee L. Haugerud’s businesses and her

other fiduciary responsibilities.

7.2 Let’s reflect upon Baseball's Sad Lexicon, Tinker to Evers to Chance

While the saddest of possible words for the New York Giants fans

Tinker to Evers to Chance played by the rules against their foe,

In contrast, Kirby to Drake to Baldwin made their own rules as they would go It was USCR 3.1 that they always chose to ignore. Yes, Kirby to Drake to Baldwin is the icon for rule violations, as we all know.

Justice's Sad Lexicon


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Kirby to Drake to Baldwin, a trio of well-educated foe

Kirby to Drake to Baldwin

Their education allows each to be a licensed pro


These words to Thomas, Jack and Michelle mean trouble galore.

The Kirby to Drake to Baldwin game is played with rules they ignore


The saddest of possible words for Thomas, Jack and Michelle,

Dealing with their conduct is nothing but pure trouble.


It is their money and power game that justice must restrain

Tinker, Evers and Chance, we desperately need your refrain Thomas and Jack cannot sustain the Kirby to Drake to Baldwin power game.

8. Request for Relief

8.1 Counsel for the Michelle Murphy and Children Parties request that Melissa

Griffis be disqualified from serving as a guardian ad litem or in any capacity in this

case.

8.2 Counsel for the Michelle Murphy and Children Parties request that a

qualified jurist provide an evidentiary hearing in this matter related to the

disqualification of Melissa Griffis, and, if Melissa Griffis resigns, that an evidentiary

hearing be provided to determine the conduct of the other parties that is related to

the appointment and conduct of Melissa Griffis.

8.3 Counsel for the Michelle Murphy and Children Parties request such other

and further relief as justice requires. END


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1.3.1 Melissa Griffis resigned and instead of allowing a hearing to resolve the

appointment of another guardian she provided Judge Baldwin an Order that he

signed appointing Elizabeth “Lisa” F. Harwell as the guardian ad litem. (XXXX)

Somewhat consistent with the conduct of persons assisting Judge Baldwin,

counsel for Michelle Murphy was not provided a copy of the appointment of

Elizabeth “Lisa” F. Harwell when Judge Baldwin executed the Order and only

learned of the Judge Baldwin’s Order sometime later when an employee of

Elizabeth Lisa Harwell informed counsel for Michelle Murphy of the Order.

1.3.2 A motion to disqualify Elizabeth “Lisa” Harwell, similar to the motion to

disqualify Melisa Griffis was filed.

1.3.3 The first encounter with Elizabeth “Lisa” F. Harwell in this case

occurred as documented in a pleading to the Court and was as follows.

A Sucker punch was again delivered to the system of justice.

A motion to disqualify Judge Quillian Baldwin and Melissa Griffis, due to the

conduct of Judge Quillian Baldwin, calmed the litigation waters for a few days.

Then, Taylor Drake of Glover & Davis contrived another litigation strategy in order

that he could deliver yet another sucker punch to the justice system.

This round of sucker punches by the Glover & Davis lawyer was a motion to have

Michelle Murphy held in contempt of Court for not reimbursing John Murphy for

one-half of the deductible portion of medical care for the children that John Murphy

had agreed to pay. The motion was based upon yet another false statement

sponsored by the Glover & Davis Lawyer.

In a bench conference, on the day that the motion for contempt was scheduled, Judge


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Quillian Baldwin explained to Taylor Drake that the matter of his disqualification

was on appeal and that he therefore would make no ruling upon the motion for

contempt. Once again, the litigation waters had calmed.

The Glover & Davis lawyers were not satisfied that they had been restrained from

delivering sucker punches to the justice system with the motion for contempt. The

Glover & Davis lawyers developed a new strategy to deliver their sucker punches to

the justice system.

The new strategy was to have John Murphy deprive the children of transportation

from Newnan to Atlanta to the schools that the children had planned to attend.

For two previous years, John Murphy had provided this transportation, except for

the last month of the previous school year when the driver of the children began

making extremely sexual, scary and dangerous comments to Michelle Murphy while

the driver was having a mental breakdown. The driver, after mental health care,

apologized to Michelle Murphy, but has been directed not to have contact with her.

The children were all prepared to being their schooling in Atlanta this school year,

but John Murphy had not informed the children or Michelle of the transportation

arrangements, although the children, John Murphy and Michelle Murphy had

attended an orientation meeting at one of the schools together.

Counsel for Michelle Murphy, on August 8, 2012, e-mailed Taylor Drake of Glover

& Davis to inquire about the transportation arrangements for the children

attendance at the Atlanta schools. This e-mail is Attachment 28.

In the e-mail, counsel for Michelle Murphy even offered, with his wife and others, to

drive the children to school while the dispute was resolved.

Taylor Drake, in an August 8, 2012 letter, responded by not only stating that John

Murphy would not provide transportation for the children, but that he would not


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allow counsel for Michelle Murphy and his wife to drive the children to school until

the issue could be resolved. Taylor Drake further classified Michelle Murphy’s

defense to the sexually inappropriate conduct of the driver as being “insulting

behavior” to the driver. This letter is Attachment 29.

There were additional exchanges of e-mails, where counsel for Michelle Murphy

attempted to resolve the transportation issue. Attachment 30.

Counsel for Michelle Murphy offered various alternatives and sought to meet with

Taylor Drake in order to resolve the dispute. Taylor Drake failed even to talk with

counsel for Michelle Murphy about resolving the transportation issue or about

enrolling the children in the public schools.

There were a series of e-mail communications that are included here as Attachment

31.

Counsel for Michelle Murphy eventually was able to obtain an agreement for Taylor

Drake to meet with counsel for Michelle Murphy to resolve some disputes.

On Thursday, August 23, 2012 counsel for Michelle Murphy traveled from Atlanta

to Newnan to meet with Taylor Drake and Elizabeth “Lisa” F. Harwell at the time

and location arranged by them. The meeting was to be a dispute resolution meeting.

Counsel for Michelle Murphy, at the beginning of the meeting, informed Elizabeth

“Lisa” F. Harwell that he believed that he could make better progress in resolving

some of the disputes if she was not present. She agreed to leave the meeting, but

strangely said she would wait downstairs rather than return to her office, which was

only a block away.

Counsel for Michelle Murphy began by disclosing to Taylor Drake the problem that

The Howard School had created by refusing to provide Jack Murphy’s transcript

from last school year. Attachment 32


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Counsel for Michelle Murphy then began to explain to Taylor Drake the efforts that

counsel had made to assist in adjusting the children to the public school system.

Counsel explained the communications counsel had with the Principal of Arnall

Middle School and the high regard that counsel had for the Principal.

A person then knocked on the door of the conference room where counsel for

Michelle Murphy and Taylor Drake were discussing issues and called Taylor Drake

from the room. Elizabeth “Lisa” F. Harwell entered the conference room and just

stood strangely at the door, saying, “well, I guess ya’ll want me back.” Counsel for

Michelle Murphy replied, “No, we don’t,” to which Elizabeth “Lisa” F. Harwell

stated, “Taylor does” and remained in the room.

Taylor Drake and others came hastening into the room with a telephone, stating that

they had arranged for some kind of call from Judge Quillian Baldwin.

Counsel for Michelle Murphy then realized that Elizabeth “Lisa” F. Harwell had

caused counsel for Michelle Murphy to drive from Atlanta to Newnan under the

extremely false pretense that Taylor Drake would finally sit down and discuss a

resolution to some of the issues with counsel for Michelle Murphy.

In all the time that counsel for Michelle Murphy has practiced law, he has never

been treated in such manner by two lawyers who counsel for Michelle Murphy has

known for many years. The conduct by these lawyers was unethical to the extent that

it was immoral.

When Judge Quillian Baldwin came on the speaker phone, counsel for Michelle

Murphy began literally yelling, before Taylor Drake started discussing matters that

counsel was unprepared to discuss, in an attempt to explain how counsel had been

tricked into coming to Newnan from Atlanta to participate in the ambush arranged

by Taylor Drake and Elizabeth “Lisa” F. Harwell.


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The ironic aspect of the conduct of Taylor Drake and Elizabeth “Lisa” F. Harwell

is that counsel for Michelle Murphy could have explained to Judge Quillian Baldwin

in a rational manner the issue that only resulted in a loud, nearly irrational

exchange, due to the frustration of counsel being tricked into coming from Atlanta

to Newnan for what counsel expected to be a session to exchange information face

to face rather than through written communications that polarize the parties and

their counsel.

1.7 It was at a hearing after Taylor Drake’s stunt of snookering counsel for Michelle Murphy to drive from Newnan to Atlanta to engage in a conference that Millard Farmer initiated to discuss resolving issues, that the illegal taking of money from the trust fund by Elizabeth “Lisa” F. Harwell was revealed to the Court in the following the cross-examination by Millard Farmer.

MS. HARWELL: I have billed, probably somewhere around a thousand dollars, which is not what I should be due --

MR. FARMER: Okay. MS. HARWELL: -- out of all the motions -- MR. FARMER: Excuse me. MS. HARWELL: -- that I’ve had to read. THE COURT: Wait just a minute. MR. FARMER: The answer to the question is yes or

no. MS. HARWELL: Yes. I have billed; I have

verification -- MR. FARMER: Have you put that money into your

personal account? MS. HARWELL: I have put the money that it cost

me to drive up to Chattanooga and to get a hotel room so that I could meet with the children and meet them for the first time, which is the only contact I’ve had


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directly with the children. MR. FARMER: And how much did you put into your

account? MS. HARWELL: I cannot give you an exact figure. THE COURT: All right. Now, look, look. Wait

just a minute; wait just a minute. She is the guardian ad litem now. Mr. Murphy is

responsible for paying all of her fees -- Wait just a minute now. MR. FARMER: Incorrect. Incorrect statement of

the law. THE COURT: I thought she was; I thought -- MR. FARMER: No. THE COURT: I thought y'all agreed to -- MR. FARMER: No. THE COURT: I thought he agreed to pay that. MR. FARMER: But you signed a different order.

When he handed you that order, you didn’t read it; it made my client liable.

THE COURT: I thought we changed it -- MR. FARMER: No. THE COURT: -- and corrected that. MR. FARMER: No, sir. THE COURT: Well, is that the deal? What is the

deal about paying -- MR. DRAKE: I thought my client was going to pay

it up front and we’d allocate it at the very end. That’s what’s been happening.

MR. FARMER: Allocated at the very end is not -- MR. DRAKE: It could be zero, Millard. Your

client may have to pay zero. It doesn’t mean that she’s obligated to pay --

MR. FARMER: I know. MR. DRAKE: It means the Court has consideration

to consider who’s responsible for -- THE COURT: All right. Look, look. Wait a

second. I’m going to get this straight right now. From now on, if you take a draw off of that


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money, please inform Mr. Farmer of these things. It would just be a matter of copying him with whatever you’re doing. And make sure the other side is informed.

I am not aware that I have to approve these expenditures, but if -- more than likely, unless it was out the wazoo somewhere, I would probably approve anything -- any of the guardians ad litem that I * * *

WITNESS my hand and seal at LaGrange, Troup County, Georgia, this the 29th day of November, 2012. Nan D. Freeman, CCR, B-1939 My commission expires April 12, 2013

1.7.1 The only invoice that Elizabeth “Lisa” ever provided to counsel for

Michelle Murphy is Attachment 155. If she has obtained money from John

Harold Murphy, Renee L. Haugerud, or on behalf of them, she is obligated by

“Law*” to provide counsel for Michelle Murphy a copy, as directed by Judge

Baldwin on November 15, 2012.


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1.8 July 31, 2014 Emergency Motion for Relief from John Harold Murphy and Renee L. Haugerud Contributing to the Delinquency of Minors

Photos are included since Judge Baldwin, as a rule, does not read pleadings.

Pictured is Michelle Murphy’s child, on Oct 20, 2013, at the Hospital after Alcohol Poisoning at the Home Shared by John Harold Murphy and Renee L. Haugerud. The $5,335.25 bill for the emergency hospital stay was guaranteed by Renee L. Haugerud, who was shown as the natural mother in the hospital records. The hospital bill, in part, is attached. See, Attachment 121. 1. Michelle Murphy’s child recovered from the October 20, 2013 alcohol

poisoning by coming home to his mother and living in an environment where he was

not treated like an adult living in a small body. Make no mistake in understanding

the danger of alcohol and tobacco. The Georgia Department of Human Resources


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considers that a parent allowing minor children, ages 13 and 15, to use alcohol

and tobacco, as contributing to the delinquency of a minor. This Court should,

also! There is now adequate proof.

Michelle Murphy’s children once again need to be returned to the home of Michelle

Murphy to be freed from the addiction of alcohol that once plagued their father,

John Harold Murphy and one of his parents. These children are far too young to

become subjected to alcohol dependency that is being initiated by John Harold

Murphy now sharing shots of alcohol with them and otherwise leaving a large open

bar available to the children without any responsible adult supervision. John Harold

Murphy is also providing the children cigars to smoke with him.

1.1 Michelle Murphy pleas to the personal jurisdiction of Judge Baldwin, while, as

an emergency, informs the Court of the immediate need for a judge to address the

urgent needs of the best interest of the children.

1.1.1 Counsel for Michelle Murphy only on Wednesday, July 30, 2014 obtained

confirmation of the alcohol aspect of the abusive treatment of these minor

children. Counsel seeks immediate assistance from the Court before publically

distributing the supporting evidence in order to obtain public support to protect

the best interest of the children. If Judge Baldwin had not permitted the

children to leave the State of Georgia, the Georgia Department of Human

Resources could address the abusive treatment of these children. That remedy,

for all of its deficiencies, is unavailable for the protection of these children.

Without the Court’s immediate intervention of providing a fair jurist to hear

this issue, the only remedy is assistance from the people of Georgia by all means

possible. This is a problem that Judge Baldwin created.


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1.1.1.1 There is a danger that the October 20, 2013 alcohol poisoning of

some of the children staying in the home of John Harold Murphy and Renee L.

Haugerud could reoccur, as the alcohol bars are never secured by being

locked or with an adult being present after the children’s initial mixed

alcoholic beverages and shot drinking sessions with John Harold Murphy.

1.1.1.2 There are three children who are being subjected to abusive

treatment by John Harold Murphy serving and jointly sharing with the three

minor children mixed “pain killer” alcoholic drinks and shots of alcohol.

1.1.1.3 Renee L. Haugerud is both knowledgeable about John Harold

Murphy providing alcoholic drinks to the three minor children in their home

and is familiar with the children being provided alcoholic drinks when they go

out to eat in public restaurants, including Foxy’s Bar in the British Virgin

Islands, where they go every weekend.

When the children are in the custody of Michelle Murphy, she takes them to

Church on Sunday. When the children are in the custody of John Harold

Murphy, he and Renee L. Haugerud get drunk on the boat every Sunday, and

take the children along in their island/bar hopping, drunken stupor. Allowing

the children to drink hard liquor and smoke Cuban cigars is John Harold

Murphy’s substitute for attending church and providing a loving home

environment.

1.1.1.4 Renee L. Haugerud stood idly by and watched John Harold Murphy

jump onto Thomas Murphy to take his cell phone from him in order that he

could not report his abusive treatment to his mother.

1.1.1.5 Renee L. Haugerud is very aware that the alcoholic bars at her

houses remain unsecure once her and John Harold Murphy’s participation in


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the minor children’s drinking ends. It was her unsecured, open alcohol bar

that resulted in the October 20, 2013 alcohol poisoning of one of the children.

1.1.1.6 This conduct of John Harold Murphy in preparing and sharing

alcoholic drinks with the three minor children and otherwise making alcoholic

drinks available to them has long been within the knowledge of Renee L.

Haugerud. This type of evidence was secreted from the Court by its failure to

allow counsel for Michelle Murphy to present testimony at the May 27, 2014

hearing and most likely this evidence was secreted from the “custody

evaluator.”

1.1.1.7 The Taylor Drake/Glover & Davis lawyers have threatened

Michelle Murphy with criminal contempt of court for attempting to learn about

the conduct of John Harold Murphy and Renee L. Haugerud that is

contributing to the delinquency of minor children.

1.1.1.8 Two of the three minor children to whom John Harold Murphy

serves mixed alcoholic drinks and shots of alcohol, were forcibly placed in the

temporary custody of John Harold Murphy by Judge A. Quillian Baldwin, Jr.,

at the May 27, 2014 hearing with a June 5, 2014 Order that prohibited

Michelle Murphy from contacting the children.

The Critical Emergency Needs of the Children are stated in the above paragraphs! Counsel for Michelle Murphy seeks to present newly obtained evidence to a fair jurist. Judge Baldwin has failed the people of the State of Georgia. These children need to be returned to the Public Schools of Coweta immediately.

1.1.1.9 The newly obtained evidence supports that the children of Michelle

Murphy have not been provided a single hour of academic counseling during

the entire summer and spend very little time with John Harold Murphy and

Renee L. Haugerud, who are “horrible” parents.


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1.1.1.10 The June 5, 2014 Order was obtained after a hearing where

Michelle Murphy and the children were not allowed to present any evidence

about the danger of the children being with John Harold Murphy for any

length of time away from their home in Georgia. Neither Michelle Murphy,

nor the children were allowed to present any evidence to the absolute false

accusations that the Taylor Drake/Glover & Davis lawyers sponsored that

Michelle Murphy had fondled one of the children.

1.1.1.11 The Taylor Drake/Glover & Davis lawyers deceived Judge Baldwin

at two hearings where Michelle Murphy was not allowed to present any

evidence. These lawyers also sponsored false statements to the appellate

courts.

1.1.1.12 It was political and financial favoritism of Judge Baldwin, that,

when legally addressed, heightened the bias of Judge Baldwin to the level of

him being unable to fulfill his role of a jurist who could listen to evidence that

could have prevented the past months of deprivation of the children of Michelle

Murphy and one of their friends.

1.2 Upon information from a reliable informant, Millard Farmer, counsel for

Michelle Murphy, has evidence that Jack Murphy, age 15, Thomas Murphy, age 13

and a friend, who is also a minor, have been staying in homes shared by John Harold

Murphy and Renee L. Haugerud in St. Thomas, USVI, Minnesota and Tennessee.

1.2.1 The friend of the children who is staying with John Harold Murphy and

Renee L. Haugerud is from Coweta County and is one of the three children being

served mixed alcoholic drinks and shots of alcohol.

1.2.1.1 The children need an immediate, sequestered opportunity to visit

with an impartial jurist. A meeting with the persons from the Coweta County


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Sheriff’s Department is not a viable substitute, as the Glover & Davis law firm

represents the Sheriff of Coweta County. Elizabeth “Lisa” F. Harwell is also

as person who should not participate, as she is an extremely poor decision

maker, who is detrimental to the best interest of the children, as she attempts

to defend her illegal conduct with additional illegal conduct.

1.2.1.2 The Sheriff’s Deputies have twice taken the children and delivered

them to John Harold Murphy. The children fear that the deputies, as John

Harold Murphy has informed the children, will place them in a detention

center, if they tell anyone about his conduct.

1.2.2 Without an immediate removal of the children from John Harold Murphy

and Renee L. Haugerud, the lives of these children are headed toward the alcohol

addiction, and roaming for sex life, involving the abusive treatment to women,

for which John Harold Murphy left his two children and Michelle Murphy to

engage.

1.2.2.1 The Priest of the children’s church is willing to assist the Pastor of

Taylor Drake’s church, or any jurist willing to assist the children in being

protected, as they can provide information about the conduct of John Harold

Murphy and Renee L. Haugerud to the Court. This Priest and Pastor spend

their lives attempting to protect the best interest of children.

1.2.2.2 The children of Michelle Murphy do not wish for any type of

punishment to be inflicted upon John Harold Murphy and Renee L. Haugerud,

as they have observed that type of conduct against their mother. The children

do strongly wish to be freed from John Harold Murphy and Renee L. Haugerud

in order that they may return to their home with their mother, Michelle

Murphy.


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1.2.2.3 This statement of the feelings of the children about punishment for

John Harold Murphy and Renee L. Haugerud does not reflect the sentiment of

counsel for Michelle Murphy. These two people are placing scars upon the

lives of these children that will remain throughout their lives.

1.2.2.4 The social worker at the hospital, after the October 20, 2013

incident, informed John Harold Murphy that he should not have unsecured

access to alcoholic beverages in the house with the children. 1.2.2.5 Be

assured, that the social worker never believed that John Harold Murphy would

not only continue to provide the children access to an unsecured, fully stocked

bar, but would share shots of alcohol with the children at a bar while the

mother of the children was prohibited by Judge Baldwin with contacting the

children.

1.2.2.6 The warning provided to John Harold Murphy at the hospital was

inadequate, as was the scare of the near death of the child inadequate to deter

the behavior of both John Harold Murphy and Renee L. Haugerud.

1.2.2.7 These persons are endangering the lives of these children and

certainly creating lifetime health problems for them relating to alcohol and

tobacco. These children need academic preparation for the coming school

year; Judge Baldwin placed the children in an environment that prevented

their academic preparation for the upcoming school year and endangered

their health for the remainder of their lives.

1.2.3 The Murphy/Haugerud houses have fully stocked, unsecured alcoholic

bars, just as the house in which the children and their friends were staying when

one of the children was taken to the hospital for emergency treatment in October


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of 2013 after the child suffered alcohol poisoning that required emergency

hospital care and his stomach pumped.

1.2.3.1 After the October 2013 incident, the danger of an unlocked, fully

stocked, alcoholic bar provided Michelle Murphy reason for additional care

to determine the possibility that the children may be accessing alcohol from

an unlocked, fully stocked bar without the knowledge of John Harold Murphy

and Renee L. Haugerud during their visits.

1.2.3.2 In October of 2013, John Harold Murphy offered a defense to the

social worker at the hospital for the alcohol poisoning of the pictured child on

the first page. The defense of John Harold Murphy was that he “fell asleep”

while looking at television and that Renee L. Haugerud was upstairs working

on the computer while the children and their guest were having a drinking

contest.

1.2.3.3 Even if true, the defense of John Harold Murphy to the October 20,

2013 alcohol poisoning of the child was available evidence that Judge Baldwin

should have heard and about which John Harold Murphy and Renee L.

Haugerud should have been questioned.

1.2.3.4 Judge Baldwin should inquire of Nancy McGarrah and H. Elizabeth

King, the so called “custody evaluators,” if their testing of John Harold and

interviewing of Renee L. Haugerud provided any warning of the conduct of

John Harold Murphy and Renee L. Haugerud relating to supplying the

children with hard liquor.

1.2.3.4.1 The Court should be reminded that both of the “custody

evaluators” had completed their testing of John Harold Murphy and their

interview of Renee L. Haugerud.


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1.2.3.4.2 The Court should bring the “custody evaluators” into Court to

inquire if the Murphy/Haugerud couple revealed during their evaluations

that they left an unlocked, fully stocked bar available to children visiting in

their home and if they provided the children with alcoholic beverages.

1.2.3.4.3 Both of the “custody evaluators,” without any request from the

Court, should have informed the Court that these people were a risk to

engage in serving shots of alcohol to these minor children visiting with them,

if their testing revealed such possibility.

1.2.3.5 As much as John Harold Murphy wishes to obtain the children for

himself and Renee L. Haugerud, he cannot restrain himself from becoming

unglued. This may be the reason that the children do not wish him punished;

as the children may understand something that the “custody evaluators”

didn’t. John Harold Murphy cannot control his behavior as it relates to the

use of alcohol and his treatment of women. This conduct is becoming more

noticeable in aging athletes who have played football, as John Harold Murphy

did.

1.2.3.6 We know that the contempt motion of John Harold Murphy to

require Michelle Murphy to academically dope the children and the custody

evaluator attempts were, as the Court was informed, bogus attempts to

detrimentally affect Michelle Murphy and the children by leading Judge

Baldwin astray.

1.2.3.7 The children, who professed love for John Harold Murphy, should

not be discouraged. Yet, the children must be protected from his behavior and

conduct to their mother in always attempting to financially require her to

suffer as she attempts to provide for the children.


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1.2.3.7 Such conduct by John Harold Murphy is an integral part of his

incurable illness involving his behavior toward women.

1.2.3.8 There is available evidence that since the children have been with

John Harold Murphy and Renee L. Haugerud that John Harold Murphy has

continually made unjustified, detrimental comments to the children about

Michelle Murphy that are designed to make the children dislike their mother.

Adverse comments about John Harold Murphy are just one of the things for

which John Harold Murphy has threatened to have Michelle Murphy held in

contempt of court.

1.2.4 The parents of the visiting minor have not provided John Harold Murphy

and Renee L. Haugerud consent to provide their minor child alcoholic beverages.

Most likely, they do not have knowledge of the conduct, or their desire to correct

this conduct is overcome by the financial offers for the child.

1.2.5 In addition to serving each of the children, including the visiting minor,

with the “pain killer” alcoholic drinks on a frequent basis, John Harold Murphy

provides each of the children, including the visiting minor, with shots of alcoholic

drinks from the open bar located in the homes that John Harold Murphy shares

with Renee L. Haugerud, who is aware that the visiting minor child, and the

children of Michelle Murphy are drinking shots of alcohol with John Harold

Murphy. This statement is not to eliminate in any manner that the children do not

otherwise consume alcoholic drinks from the unlocked bar in the absence of John

Harold Murphy and Renee L. Haugerud.

1.2.6 The simplistic answer to this alcohol problem is not to lock the bar, as

the alcohol problem is only the symptom of the apparently incurable problem


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that John Harold Murphy has with his relationship with women that becomes his

problem in depriving Michelle Murphy of her children.

1.2.7 The children of Michelle Murphy fear both short term and long term

retaliation, as John Harold Murphy has made a direct threat about the

consequences of disclosure of this drinking issue once he becomes aware that the

confidential informant provided enough information about the children to

require further inquiry on behalf of the children’s safety. One thing is fortunate:

it doesn’t require as much money to obtain a confidential informant in St. Thomas

as it does in Chattanooga.

1.2.8 John Harold Murphy was an alcoholic who maintains that he has

recovered. There is great fear that the children will become addicted to alcohol,

as John Harold Murphy once was, or that there will be a less successful recovery

from alcohol poisoning.

1.2.9 The children have consistently begged to be returned to Coweta County

to be with Michelle Murphy.

1.2.10 The operation of a motorized all-terrain vehicle by the children creates

an even greater fear about these young bodies being laden with the residual effect

of alcohol.

1.2.11 One of the children has already had several wrecks this summer on the

motorized, all-terrain vehicle.

1.2.12 The minor child from Newnan, who is visiting the children, according

to an unconfirmed report that is not documented in the recorded information

which is available to the Court, has been offered fully paid tuition to a private

school if he will go to school outside the State of Georgia with Jack Murphy and

Thomas Murphy.


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1.2.13 The confidential informant does not wish to endanger this offer, if the

offer is true, and the promise of further financial benefits provided to the minor

child. The financial status of the parents of the child is such that they are in awe

of the financial benefits that John Harold Murphy and Renee L. Haugerud have

provided and are continuing to provide to their minor child.

1.2.14 The confidential informant has asked that the alcohol drinking

problem not be disclosed until the minor child returns home to Coweta County.

1.3 School is about to begin in Coweta County and Jack Murphy, age 15, and his brother, Thomas Murphy, age 13, need to be returned to their teachers in Coweta County, who have great confidence in these children and in Michelle Murphy’s dedication to educating them. The children’s alcohol dependency needs to subside. Alcohol and tobacco are not the only problem that creates the contribution to the delinquency of these minor children by John Harold Murphy and Renee L. Haugerud.


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1.3.1 The abusive exposure to alcohol is just one of the detrimental ways in which the children are being psychologically tortured, as John Harold Murphy and Renee L. Haugerud attempt to gain favor with the children by exposing them to a lifetime of alcohol and tobacco dependency


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Hey PaPa & Renee if im not back home by June 21st 2014 I will never speak to you again. I will leave & you will never find me. I don’t ever want to ever live with you like I have said 100 times. And how could you say that my mom molested me that is the biggest lie I have ever hear. & I just to let you know all of those weekends that I didn’t come was because you took me & Thomas from a safe & loveing environment. You have no respect for me or any of my decisions. & plus I am tired of Renee saying she doesn’t have anything to do with this. That is all I have to say Jack Murphy, age 15

1.3.2 The issue is that John Harold Murphy and Renee L. Haugerud are

contributing to the delinquency of minor children and endangering them in

jurisdictions where the influence of Renee L. Haugerud’s money with the

governmental authorities and the unavailable financial cost to Michelle Murphy

prohibit Michelle Murphy from stopping the illegal conduct of John Harold

Murphy and Renee L. Haugerud. Judge Baldwin created this situation.


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1.3.3 The conduct of John Harold Murphy and Renee L. Haugerud require an

immediate hearing before a judge who replaces Judge Baldwin. There is not

enough time for Judge Baldwin to recover from being constantly duped by the

Taylor Drake/Glover & Davis lawyers. The children tried and failed to protect

themselves with their earlier messages. This matter requires immediate, strong

regulatory action that must result in the children of Michelle Murphy being

brought back to Coweta County to be supervised by their mother, Michelle

Murphy.

1.4 These three children were served mixed “pain killer” alcoholic drinks by John Harold Murphy with the approval of Renee L. Haugerud as the result of four deficiencies of our judicial system.

1.4.1. The Superior Court of Coweta County’s absence of a Uniform Superior

Court Rule 3.1 Case Management Plan that allowed Taylor Drake to select the

judge of his choice. – This resulted in an immediate, justifiable absence of

confidence by counsel for Michelle Murphy in the Court as favoritism that was

illegal, was initially granted to the Taylor Drake/Glover & Davis lawyer.

1.4.2 The failure of Judge A. Quillian Baldwin, Jr. to allow Michelle Murphy

to present evidence at all crucial times, combined with attacks by Judge Baldwin

upon her counsel.

1.4.3 The failure to disqualify Elizabeth “Lisa” Harwell as guardian ad litem

after it came to the attention of Judge Baldwin that she converted trust funds to

her personal use in violation of Uniform Superior Court Rule 24.9 (8)(g) and the

knowledge of her violation of OCGA §16-6-19.

1.4.4 Judge Baldwin being duped into appointing the “custody evaluator”

expert witness for the money bags of John Harold Murphy and Renee L.


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Haugerud rather than using his numerous years of experience that have most

likely taught him that the academic doping of children is no substitute for the

judgment of school teachers and a mother who see the children daily. This hands-

on judgment was that the tutors employed by Michelle Murphy were a better

solution for the children adjusting to their new school than multiple medications

from a once addicted psychiatrist who testified after lunch under the influence of

so such medication that her cross-examination was stopped by Judge Baldwin

with a break and never allowed to continue.

1.5 Judge Baldwin came within one witness of learning the truth about Elizabeth

King, the so called “custody evaluator’s” spoliation of evidence, illegal testimony

conduct and the absence of any ability of Elizabeth King to perform any test that

provides any information concerning the false allegation of fondling.

1.5.1 It was H. Elizabeth King who refused to come to the home of Michelle

Murphy and examine her and the children as Elizabeth King and any associate

wished. There is also information that can be provided about the conduct of

Renee L. Haugerud taking one of the children to a nude beach when he was 9

years old and about Renee L. Haugerud’s payment of $60 per hour for the

children to rub her feet.

1.5.2 Judge Baldwin, on May 27, 2014, had all of the witnesses in the

courthouse who could have presented the highest and best evidence of the legal

issues that could have alerted Judge Baldwin to the detriment to the children of

the results that the Taylor Drake/Glover & Davis lawyers wanted; instead, he

lost his temper and engaged in irrational conduct.


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1.5.3 Rather than using the best system of justice in the world to resolve the

issues, Judge Baldwin decided to succumb to the Taylor Drake/Glover & Davis

lawyers’ financial trap that Michelle Murphy could not afford.

1.5.4 Judge Baldwin does not understand until this day the cost to Michelle

Murphy to obtain expert witnesses to expose the “custody evaluators” and to

take their depositions, as no jurist would ever send the children to a previous

offender’s house with an unsecure, open bar thousands of miles from the Court,

where the children could be served shots of alcohol.

1.5.4.1 Judge Baldwin would not commit to providing Michelle Murphy any

litigation fees; quite the opposite, Judge Baldwin consistently warned counsel

for Michelle Murphy that he did not plan to award attorney fees.

1.5.4.2 The custody evaluators were selected by Elizabeth “Lisa” F.

Harwell. The attached bill from Elizabeth “Lisa” F. Harwell indicates some

of the fees received and being sought by Elizabeth “Lisa” Harwell. See,

Attachment 122.

1.5.4.3 If Elizabeth “Lisa” F. Harwell has allowed the alcohol shot sharing

and other abusive treatment of the children to occur without a notice to

counsel for Michelle Murphy and the Court, she should be removed

immediately. If Judge Baldwin was noticed, he did not share this contribution

to the delinquency to minors with counsel for Michelle Murphy.

1.5.4.4 The guardian ad litem, who failed the children when they needed to

be protected from the alcohol abuse, cannot be trusted, as the children also

need protection from this so called “guardian ad litem” whose shift should

have ended when she was caught converting trust money for her use without a

prior approval. USCR 24.9 (8) (g).


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1.5.4.5 If Elizabeth “Lisa” F. Harwell had been a fast food worker who had

worked a complete week and took money from the cash register to cover for

her wages before her paycheck arrived and was caught, she would have been

fired and charged with theft, as this guardian ad litem should have been

treated. Money in a trust account of a lawyer and a guardian ad litem is

governed by the Uniform Superior Court Rule 24, et seq.

1.5.5 In his June 5, 2014 Order, Judge Baldwin made a temporary custody

change a specific form of punishment for Michelle Murphy that more specifically

is punishment of the children. The punishment phase of the May 27, 2014 hearing

should now end.

1.5.6 During one of the children’s visit with John Harold Murphy and Renee

L. Haugerud that preceded the May 27, 2014 hearing, John Harold Murphy

informed the child that if Renee L. Haugerud was subpoenaed in this case, he

would have Nancy Michelle Murphy put in jail. Renee L. Haugerud was in

Georgia going to the Atlanta Airport in route to St. Thomas, USVI with one of

the children at that time and feared service of a subpoena upon her, as her

location in Georgia was detected.

1.5.7 It is the New York based companies of Renee L. Haugerud that supply the

medical insurance for the children, that, once the litigation began, increased the

amount of the medical costs that Michelle Murphy is required to pay.

1.5.8 It is Renee L. Haugerud who goes with John Harold Murphy to consult

with cardiac medical care providers throughout the world related to his medical

condition.


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1.5.9 It was Renee L. Haugerud who swore falsely to obtain her marriage

license in order for Judge Louis Jack Kirby to perform an illegal marriage

ceremony for her and John Harold Murphy.

1.5.10 It was Renee L. Haugerud who made a false statement to the process

server by using a fictitious name in order to evade service of process.

1.5.11 It was Renee L. Haugerud who provided a false affidavit to Peter A.

Durham relating to an ownership interest in real property in the State of Georgia.

1.5.12 It was Renee L. Haugerud who used corporate assets in order to

transport the children to visit with her and John Harold Murphy.

1.5.13 It was the funds derived from Renee L. Haugerud which paid for the

attendance of the children at the private school in Atlanta and the transportation

of the children from Newnan to Atlanta each school day.

1.5.14 At the time that John Harold Murphy filed for modification of custody,

all of these funds were terminated.

1.5.15. Renee L. Haugerud, a/k/a Lauree Smith, is the Chief Investment

Officer of Galtere, Ltd, a registered investment advisor that is headquartered

in New York City. Galtera N.A., Inc. is the sub-advisor to Galtere, Ltd.

(Affidavit of Renee Haugerud, a/k/a Lauree Smith) (R-495)

Renee Haugerud, contrary to her affidavit, (R-495) apparently provided to evade

jurisdiction of the Court, jointly holds title to real estate in Georgia with John H.

Murphy by virtue of a Security Deed that vests title in them until the debt of Ebonie

S. Wilson is paid and the Security Deed is satisfied in the real estate record of

the Clerk of the Superior Court of Troup County.


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1.5.16 The Court is reminded of the false statements that Renee Haugerud, a/k/a

Lauree Smith and John Harold Murphy made in obtaining their marriage license.

First, on the left, below, is the Application, followed on the right by the Marriage

License signed by Coweta Judicial Circuit Judge Jack Kirby., to the Addendum

to the First Amended Motion to Disqualify Judge Baldwin. (R-223, 224)

1.5.17 The Court should also be reminded of another false statement that Renee

Haugerud, a/k/a Lauree Smith made to another state actor.

The process server provides, in part, the following sworn information.


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1.5.18 Judge Baldwin was a poor decision maker in appointing a guardian

ad litem who attempted to use the illegal authority provided to Melissa Griffis in

order to attempt to change custody temporarily for the children to go to a school

in Atlanta at the request of Taylor Drake and John Harold Murphy.

1.6 Judge Baldwin was a poor decision maker; in fact, he is an unethical decision

maker, in appointing a guardian ad litem who appeared on a regular basis before

Judge Louis Jack Kirby, the person who represented John Harold Murphy during

the divorce.


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1.6.1 The decision making by Elizabeth “Lisa” F. Harwell to attempt to change

custody temporarily was poor on both a legal basis and on a practical basis, as

it was John Harold Murphy who withdrew the transportation that he had been

providing for the children to go to the Atlanta school.

1.7 Since the filing of the Complaint for Modification, John Harold Murphy has attempted to obtain custody of the children by depriving Michelle Murphy and the children of financial resources. This continued with the July 25, 2014 letter threat (Attachment 123) of Taylor Drake Response to the July 25, 2014 Letter Threat of Taylor Drake

1.7.1 On Friday afternoon, July 25, 2014, Taylor Drake sent John Harold

Murphy’s threat to breach the Settlement Agreement that he memorialized before

Judge A. Quillian Baldwin to provide Michelle Murphy child support.

1.7.1.1 John Murphy threatens that Michelle Murphy will not receive

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

during the month of August at a hearing that 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. The Settlement Agreement

provides as follows.


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The threat, without any legal authority to breach the agreement, and 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-the-ground, Taylor Drake/Glover & Davis

John Harold Murphy/Renee L. Haugerud strategy.

1.7.1.2 The August child support due from John Harold Murphy was paid.


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1.7.1.3 The preview of that “we have the judge and the money” strategy was

first identified to counsel for Michelle Murphy when Taylor Drake would not

discuss a disposition to the dispute of the parties without rushing to the

courthouse to select Judge Baldwin.

1.7.1.4 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.

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

attempted to adjudicate this illegal temporary change of custody. 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.

1.7.1.6 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.

1.7.1.7 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


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Appeals, made a different false statement in an attempt to defend the conduct

of Judge Baldwin, in signing without reading the illegal Order..

1.8 Incorporated Provision 1.8.1 This July 31, 2014 Emergency Motion for Relief from John Harold Murphy

and Renee L. Haugerud Contributing to the Delinquency of Minors supplements,

without replacing and incorporates all previous motions, including supporting

affidavits attached to previous motions to disqualify Judge A. Quillian Baldwin, Jr.

None of the disqualification motions are waived in order to obtain this required

emergency relief that is in the best interest of the children.

The Affidavit of Millard Farmer is attached.

1.9 Request for Relief

1.9.1 Michelle Murphy requests that a judge other than a judge in the Coweta

Judicial Circuit, and other than a senior judge who has served by designation in the

Coweta Judicial Circuit, be designated to adjudicate this matter, and her counsel

request that Judge Baldwin immediately disqualify himself and allow another Judge

to proceed with the rescue of the children.

1.9.2 Michelle Murphy requests that the children be returned to Coweta County

immediately for investigative purposes.

1.9.3 Michelle Murphy requests that her counsel be immediately allowed to

interview the children.

1.9.4 Michelle Murphy requests that the children be returned to Coweta County

immediately in order that they may be begin this school year.

Michelle Murphy requests that the Court rescind its June 5, 2014 Order.

1.9.5 Michelle Murphy requests that she be allowed to present evidence in support


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of this emergency motion.

1.9.6 Michelle Murphy requests that she be granted such other and further relief

as justice requires.

2. Entities of the State of Georgia should and are requested here to provide investigative assistance immediately, as Judge Baldwin and many others

participating with him are state actors who have and are violating the LAW*.

2.1 The corruption of Judge Baldwin is not limited to one act of corruption, or just

one type of conduct, nor is Judge Baldwin’s corruption limited to a restricted time

period, or to one case. The corruption of Judge Baldwin is wide-ranging in its time,

type, participants, victims, amount, consequences and triggering events.

2.2 The corruption of Judge Baldwin has been contagiously detrimental to those

who would not otherwise engage in such conduct.

2.2.1 Judge Baldwin is engaging in ex parte communication even as this motion is being written if information provided to Millard Farmer is correct.

2.2.2 John Harold Murphy and Renee are attempting to game the system of justice even as this motion is being written if information provided to Millard Farmer is correct.

2.3. The corruption of Judge Baldwin is funded, in its major part, in the Coweta

County area by the financial and political benefits provided to Judge Baldwin by the

Glover & Davis lawyers, by the benefits solicited by Glover & Davis while acting

as money and political bundlers for the interest of Judge Baldwin, and by the County

Attorney of Coweta County, who is a Glover & Davis associate.

2.4 The Corruption of Judge Baldwin and the Participants in Judge Baldwin’s

corruption, with Acts of Omission and Acts of Commission, are, in part, preventing


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the parties in this case from “fairly resolving the issues” in this case, as John Harold

Murphy and Renee L. Haugerud are most predictably awaiting more benefits from

the corrupt conduct of Judge Baldwin that they hope will delay and enhance their

bargaining position for a disposition of the case which is financially beneficial to

them and prevent regulatory action against them.

2.5 There are over twenty (20) documents seeking to disqualify Judge Baldwin in

this case. On each of those occasions, Judge Baldwin was provided an opportunity

to adhere to the LAW* and thereby refer the disqualification attempts for a hearing

before an independent judge who would have provided Judge Baldwin an

opportunity to answer to the disqualifying charges under oath at a hearing. Counsel

for Michelle Murphy was entitled under the LAW* to question Judge Baldwin about

his ex parte communications, about his signing orders without reading the orders,

having knowledge of the content of the orders, or without the orders being based

upon evidence recited in the orders.

2.5.1 Judge Baldwin has never, no not once, allowed counsel for Michelle

Murphy to present the charges relating to the disqualification of Judge Baldwin

to an independent judge who would have allowed Judge Baldwin to answer under

oath to the disqualification charges.

2.5.1.1 It was necessary for counsel for Michelle Murphy to prepare a fully

completed Petition of Mandamus in an attempt to obtain a response from Judge

Baldwin to the numerous pending motions to disqualify him. This Petition for

Mandamus was provided to the Attorney General’s Office in order to obtain a

waiver of service. It is included here, without its attachments, as


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Attachment 156. The petition was never filed, as the Attorney General was

successful in obtaining perfunctory responses from Judge Baldwin.

2.5.2 These twenty (20) or more opportunities provided to Judge Baldwin to

address his disqualifying conduct, place the corrupt conduct of Judge Baldwin in

a status of requiring Judge Baldwin’s permanent removal as a judge without any

further State of Georgia compensation to him for any reason, as he has inflicted

enough financial damage to the State of Georgia and persons involved in the

justice system to require swift and imperative action against his deliberate

conduct in violating the LAW*.

2.6 Chief Judge Baldwin has corrupted the integrity of the judicial process in

this case and in the State of Georgia to the extent that the consequences of his

conduct must be addressed to the fullest extent allowed by LAW*.

2.6.1 The Glover & Davis lawyers have directly contributed money and also

bundled money from others to provide Judge Baldwin the necessary financial and

political support to engage in his corruption.

2.6.1.1 The consequences of the corruption of Judge Baldwin extends far

beyond the boundaries of this case.

2.6.1.2 Examples of the extent of the corruption of Judge Baldwin and

those who are participating in and benefiting from his corruption are identified

in this motion in order to identify the consequences of the conduct.

2.6.1.3 Judge Baldwin has assisted and approved of corruption by his

inaction and conduct that has lowered the integrity of the judicial system, and

provided benefits, in violation of the LAW* to the clients of those who

participated in Judge Baldwin’s corruption.


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2.6.1.3.1 It is relevant that Nathan Lee of Glover & Davis is the attorney for

Coweta County, which supplements Judge Baldwin’s salary. Nathan Lee, as

the county attorney, is in the position to advocate for the supplement to the

salary of Judge Baldwin.

2.6.1.3.2 During the litigation of this case informants have attempted to

assist Michelle Murphy by providing information about the consequences of

the corruption of Judge Baldwin his participants, the Glover & Davis

lawyers, in addition to the exposed Mayor & Aldermen of Savannah v.

Batson-Cook Co., 291 Ga. 114 (2012) case. The bundlers of financial

contributions to Judge Baldwin and other members of the judiciary

according to information provided information a client of the Glover &

Davis lawyers, Otis Jones was that he was given a mandatory sentence to

jail in Coweta for an driving in the influence of alcohol.

2.6.1.3.3 It is reported that another client of Nathan Lee, the Sheriff of

Coweta County, allowed Otis Jones, a money and political bundler, to come

by the jail on each morning of his sentence and sign in and then leave. This

was a violation of the law not accorded to poor people who are not politically

associated with the Sheriff or Nathan Lee.

2.6.1.3.4 Among the other things reported was that while Judge was

assigned as case, Judge Superior Court Judge Louis Jack Kirby as a favor,

with knowledge of the District Attorney, intervened in the case without a

case management plan and changed the bond of a person who was charged

with the murder of an infant to allow the charged person to visit with another

child of the mother of the child that was killed.

That conduct is explained as follows.


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2.7 Information about Coweta Judicial Circuit Judge Kirby came to Millard

Farmer’s attention while investigating the conduct of Judge Kirby, as his conduct

related to the judge shopping of Judge Baldwin by Taylor Drake, the Glover & Davis

lawyer, in the John Murphy v. Nancy Michelle Murphy litigation. 2.7.1 Casey Allen Spradlin, who, with a substantial amount of supporting

evidence, was indicted by the Grand Jury of Meriwether County for brutally

murdering an infant.

2.7.2 Casey Allen Spradlin was acquitted in a trial in the Superior Court of

Meriwether County in which Judge Baldwin presided and the Sheriff of Coweta

County, a family friend of the Spradlin family, and an employee of the Sheriff of

Coweta County, testified as a character witness for Casey Allen Spradlin.

2.7.3 After being indicted for malice murder and related child abuse charges,

Casey Allen Spradlin was provided a $100,000 bond by the Superior Court of

Meriwether County. The bond was conditioned, in part, upon him not having

contact with another young child with whom he had been associated during the

time that he was associated with the deceased infant. That conditional bond was

legally filed and is in the records of the Superior Court of Meriwether County.

2.7.4 This information is not about the conditional $100,000 bond that Casey

Allen Spradlin was provided.

2.7.5 Millard Farmer was informed of this information, in bits and pieces, by a

reliable source and has since confirmed the information that he received with the

District Attorney, who provided him other information.

2.7.6 The information, that Millard Farmer believes to be accurate, is that Judge

Louis Jack Kirby, after the indictment of Casey Allen Spradlin, without

additional evidence or a judicial hearing, was approached and asked to remove


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the conditions of the $100,000 bond that prevented contact by Casey Allen

Spradlin with the other surviving child.

2.7.7 Judge Kirby, either orally or with an unfiled Order, acquiesced in

allowing the removal of the bond condition preventing contact with the surviving

child.

2.7.8 After Casey Allen Spradlin was informed that Judge Kirby acquiesced in

allowing the removal of the condition of no contact with the surviving child,

Casey Allen Spradlin visited with the surviving child before the trial. The

surviving child was not injured during the visits.

2.7.9 A reasonable person can assume that Judge Kirby, without notice to any

of the adverse parties, even his wife, who is an assistant district attorney, removed

the conditions of the bond that allowed Casey Allen Spradlin contact with the

surviving child.

2.7.10 A reasonable person can assume that the removal of the bond condition

was a political favor that was intended to be secreted from the public, as the

removal of the bond’s condition was not recorded in the public records of

Meriwether County.

2.7.11 The District Attorney, upon specific request in an e-mail from Millard

Farmer, although he has confirmed other information related to the case to

Millard Farmer, will not confirm or deny if he was notified of the no contact

conditions being removed from the bond before Judge Kirby removed the no

contact conditions of the bond. It is seriously doubtful that the District Attorney

would have participated in any such conduct and most likely, the District


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Attorney’s failure to respond to Millard Farmer’s request is in protection of his

friend, Judge Kirby.

2.7.12 There is also no indication in the records of the Superior Court of

Meriwether County that any notice was provided in any manner to the public or

to the Georgia Department of Family and Children Services about the change of

the bond’s no contact conditions.

2.7.13 It is suspected that the conditions of the bond were secretly removed,

or evaded, in an agreement with the Sheriff of Coweta County, a friend of the

extended Spradlin family.

2.7.14 The illegal and thereby unethical conduct of Judge Kirby occurred by

the modification of the bond not being filed in the records of the Superior Court

of Meriwether County, as the original Order relating to the conditional bond was

filed.

2.7.15 The modification of the bond may have affected the validity of the

bond. If the restricted conditions of the bond were secreted without an Order, this

raises other ethical and legal issues.

2.7.16 It is suspected that the bond was modified by Judge Kirby as a

politically motivated judicial favor, not supported by evidence that the District

Attorney was allowed to contest.

2.7.17 Had this change of conditions of the bond been determined to be in the

best interest of society, an Order modifying the bond conditions would have

alerted persons having an interest in the other minor child, such as the

Department of Family and Children Services and other relatives of the surviving

minor child.


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2.7.18 The minor child was protected by the condition of the bond that was

apparently justified when the judicial determination was made that the bond

should be conditional. That once protected child had an unprotected interest in

Judge Louis Jack Kirby breaching the judicial process apparently for the benefit

of political favor to him.

2.7.19 The uninvestigated aspect of this complaint against Judge Kirby

involves whether or not Judge Baldwin, the trial judge in the Spradlin murder

case, had knowledge of the process of the modification of the bond either before

or after it occurred, and, if he did have knowledge, did he exercise his obligation

either before or after it happened, to report the incident.

2.7.20 Judge Baldwin was assigned to try the murder case; the question is;

was it the consistent violations of the Uniform Superior Court Rule 3.1 case

management rule that resulted in a judge-shopping arrangement that opened the

window of opportunity for this illegal and unethical conduct by Judge Kirby to

modify the conditions of the bond while Judge Baldwin was assigned the case?

2.7.21 For whatever reason that it was determined that the first child died a

brutal death, the surviving child did not deserve to be placed at risk after the

murder indictment until it was adjudicated, whether or not Casey Allen Spradlin

had a defense to the brutal murder with malice of the infant that the jury indicted

him for committing.

2.7.22 Judge Kirby has a History of Not Acting Judicially Prudent

2.7.23 The Supreme Court recently identified the instance of Coweta Judicial

Circuit Judge Dennis Blackmon disqualifying Judge Kirby for not acting

judicially prudent in Horn v. Shepherd, 294 Ga. 468, 469-470 (2014). The Horn


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case refers to a deposition that Millard Farmer took of Judge Kirby in the Murphy

case.

2.7.24 Melissa Griffis, mentioned in the Horn case, was the first guardian ad

litem appointed by Judge Baldwin in the Murphy case in the Order presented to

him by Taylor Drake of Glover & Davis that Judge Baldwin signed without

reading.

2.7.25 After refusing a court reporter recorded conference, and being

challenged, Melissa Griffis resigned without a hearing on her disqualification;

however, in order to leave her footprints in the case, with her resignation, she

recommended the appointment of Elizabeth “Lisa” F. Harwell, a lawyer who

regularly appears before Judge Kirby in her private domestic relations cases, to

replace her as guardian ad litem.

2.7.26 The conduct of Judge Louis Jack Kirby is relevant to the conduct of

Chief Judge A. Quillian Baldwin, Jr., as Judge Kirby, under the current Uniform

Superior Court Rule 3.1 case assignment in the Coweta Judicial Circuit, is

assigned to the Superior Court of Coweta County in a disproportionate number

of cases, as he is married to Monique Lynn Fouque, an assistant district attorney,

who is primarily assigned to the Superior Court of Troup County.

2.7.27 Judge Kirby has a conflict of interest with his spouse, Monique Lynn

Fouque being a lawyer in the Office of the District Attorney in Troup County that

eliminates Judge Kirby from appearing in criminal cases in Troup County.

2.7.28 Superior Court Judge Louis Jack Kirby, before becoming a judge,

represented John Harold Murphy in the 2006 divorce case against Michelle

Murphy.


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2.7.29 After Louis Jack Kirby became a judge, Millard Farmer deposed Judge

Kirby relating to his association with John Harold Murphy. In that case, he

verified that while he was a Superior Court Judge, he had recommended Melissa

Griffis and Taylor Drake of Glover & Davis as counsel for John Murphy to

employ for a modification of custody case against Michelle Murphy.

2.7.30 This recommendation by Judge Kirby to John Harold Murphy relating

to the employment of counsel came at the time that there was an absence of a

Uniform Superior Court Rule 3.1 mandated case management plan that allowed

judge-shopping in the Coweta Judicial Circuit.

2.7.31 Judge Kirby had knowledge that the Superior Court of Coweta County

did not have a Uniform Superior Court Rule 3.1 case management plan and that

the attorneys suggested to John Harold Murphy knew how to judge-shop and

obtain the judge of their choice.

2.7.32 This illegal judge-shopping process in the Coweta Judicial Circuit was

accomplished frequently, but was challenged and upheld in the Court of Appeals

by Mayor & Aldermen of Savannah v. Batson-Cook Co., 310 Ga. App. 878

(2011), until reversed by the Supreme Court of Georgia in May of 2012 in Mayor

and Aldermen of Savannah v. Batson-Cook Co. 291 Ga. 114 (2012).

2.7.33 The judge-shopping issue in the Coweta Judicial Circuit is another

case, not directly involving Judge Baldwin or Judge Kirby. The charges in that

case were not made public.

2.7.34 These examples are to emphasize that the people who bundle money

and political influence at the request of the Glover& Davis lawyers obtain

benefits that are corruption and similar to the corruption that has deprived

Michelle Murphy, Jack Murphy and Thomas Murphy of justice.


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2.7.35 It was the corruption of Judge Baldwin that provided the Order that

that had the Deputy Sheriffs to come to the home of Michelle Murphy to pick up

Jack and Thomas for visitation with John Harold Murphy before Michelle

Murphy ever received the Order of Judge Baldwin changing the days of

visitation.

2.7.36 That corruption was corruption in which the Sheriff, who is

represented by Nathan Lee, a Glover & Davis lawyer, and the client of Taylor

Drake, the Glover & Davis lawyer, participated with Judge Baldwin in disrupting

the lives of Michelle Murphy, Jack Murphy and Thomas Murphy.

2.7.37 There is a pattern of these illegal acts that are little different than the

false affidavit that Michael William Warner, a Glover & Davis lawyer, provided

in order to garnishee the funds in the bank account of the wife of Millard Farmer

during the holiday season on behalf of John Harold Murphy and thereby

potentially affect credit scores and professional reputations.

2.7.38 Adequate funding for governmental investigative assistance is

required, as Judge Baldwin failed to allow the testimony of Peter A. Durham, a

Glover & Davis lawyer, about the financial benefits provided to Judge Baldwin

over the years under the guise of campaign contributions, even when Judge

Baldwin had no opposition. See, Attachment 157, Notice to Produce. 2.7.39 Judge Baldwin prohibits discovery and other evidence about his

corruption that makes it easy for Judge Baldwin to make such false statements as

he made about money originating from the law firm of Melissa Griffis in

responding to the first motion to disqualify him.


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2.8 During the holiday season, the Glover & Davis lawyers attempted to intimidate Millard Farmer and his family. Besides being unprofessional, such conduct is just a stupid manner of dealing with opposing counsel.

2.8.1 Counsel for Michelle Murphy, although aggrieved about the perjurious

statement made during the holiday season by Michael Williams Warner and

sponsored by the other Glover & Davis PA lawyers in order to garnishee and

thereby place a hold on funds in the accounts, attribute the ability of these lawyers

and John Harold Murphy to engage in such conduct to Judge Baldwin, as he

signed the Order that they chose to use to garnishee the bank accounts instead of

serving Millard Farmer with a copy of the Order that Judge Baldwin did not have

served upon Millard Farmer.

2.8.2 The garnishment upon the bank account of Millard Farmer’s wife, Elvira

Dimitrij, that, in addition to the financial frustration that it created, cost nearly a

thousand dollars more than the amount of $1,250 that was provided to John

Harold Murphy by the unserved Order of Judge Baldwin, and, once again, has

created additional litigation ancillary to this modification of custody case.

2.8.3 Millard Farmer, as counsel for Michelle Murphy, is entitled to service of

the Orders of Judge Baldwin that are provided to the Glover & Davis lawyers

that Julia Harris, the judicial assistant, and Melissa Sams, the law clerk and the

Glover & Davis lawyers did not serve upon Millard Farmer. This is not the first

time that Michael Williams Warner, a Glover & Davis lawyer, and the assistants

to Judge Baldwin have failed to provide counsel for Michelle Murphy with

service of Judge Baldwin’s Orders. On the last occasion, the Glover & Davis

lawyers had the Deputy Sheriffs of Coweta come to the home of Michelle


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Murphy to pick up the children based upon an Order about which she and the

children knew nothing.

2.8.4 There have been very few lawyers in the Coweta Judicial Circuit who

have engaged in the conduct of not serving documents upon opposing counsel,

or in delivering documents in a deceptive manner so as to delay service in time

for opposing counsel to act before it was too late.

2.8.5 This motion is the forerunner of an attempt to terminate the birthplace

and home base of this type of judge-shopping, protected corruption. The Coweta

Judicial Circuit, until the recent flurry of Glover & Davis judge-shopping, has

never been plagued by the corruption involving Judge Baldwin that overshadows

any judge instigated misconduct that has darkened the history of justice in the

Coweta Judicial Circuit since counsel for Michelle Murphy has been practicing

law, except for the approximate ten (10) years that Millard Farmer litigated the

underrepresentation of African American persons on grand and traverse juries in

the Coweta Judicial Circuit that was not resolved until a decision by the United

States Court of Appeals for the Eleventh Circuit.

2.8.6 Larry King provided two affidavits that relate to the conduct of Judge

Baldwin and the false statements of counsel participating in the corrupt conduct

of Judge Baldwin. See, Attachment 96, attached hereto. Judge Baldwin told

Larry King that he had never before sentenced a lawyer for contempt of court

before sentencing Larry King and Millard Farmer for criminal contempt.

2.8.7 It was when Judge Baldwin sentenced Larry King and Millard Farmer for

contempt that it became obvious that Judge Baldwin did not criminally sentence

Larry King for his conduct, but he sentenced Larry King, Michelle Murphy and

Millard Farmer on that day for the fair administration of the Law that they sought


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to obtain on behalf of the children of Michelle Murphy and all of the people in

the Coweta Judicial Circuit.

3. Two Different Sets of Books, Documenting One Transaction, is another timeworn, but nevertheless true, identity of an Attempt to Hide Corruption that is and of itself, Corruption. 3.1 Judge A. Quillian Baldwin, Jr. has mandated that there be two sets of books of

the pleadings which counsel attempts to file on behalf of Michelle Murphy in this

case. One set is kept by the Clerk of Superior Court of Coweta and is available to

the public. The other documents, which are tendered to the Clerk of Court, by Order

of Judge A. Quillian Baldwin, Jr., cannot be made part of the record in this case

unless Judge Baldwin specifically grants a Request by counsel for Michelle Murphy

that the tendered document be allowed to be filed. Judge Baldwin will not permit

Nancy Michelle Murphy to file any new action, motions, or petitions without his

approval of the document that counsel for Michelle Murphy seeks to file. See the

October 20, 2014 Order of Judge Baldwin, Attachment 145 to this motion.

3.2 This Order by Judge Baldwin has resulted in him denying the right of counsel

for Michelle Murphy to file three motions to disqualify him. (Motions tendered on

October 27, 2014, November 28, 2014 and December 20, 2014) Before counsel for

Michelle Murphy can have the proposed filing retained by the Clerk of Court,

counsel for Michelle Murphy must present the proposed filing to Judge Baldwin for

his approval after first serving the proposed filing upon opposing counsel. There is

no such illegal requirement placed upon opposing counsel and this illegal restraint

was placed upon Michelle Murphy’s counsel without an opportunity for a hearing

and was itself the subject of a motion to disqualify Judge Baldwin. If the proposed

document is rejected for filing by Judge Baldwin, the Clerk of Court does not retain


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an official record of the document for appellate review and the document is not

available for the public to review. This conduct prevents the media from having

access to the documents that identify each aspect of the corruption of Judge Baldwin

and the participants in his corruption.

3.3 The children are currently still incarcerated in Elevations RTC in Utah, as the

result of the absence of a hearing. Jack and Thomas, two quite normal children,

were arrested in the Coweta Superior Courthouse as they awaited to testify on

May 27, 2014 until they were ultimately taken to St. Thomas, USVI. As the result

of Judge Baldwin turning over their parenting to John Harold Murphy, Renee L.

Haugerud, Elizabeth “Lisa” F. Harwell and their experts, the children are

incarcerated in Utah at a cost of $24,000 per month.

3.4 The conduct of Judge Baldwin was the result of his corruption.

3.4.1 The June 7, 2012 denial of disqualification Order was appealed to the

Court of Appeals and was not adjudicated on the substance of the conduct of

Judge Baldwin, but upon procedural grounds.

3.4.2 It is relevant to here state that violations of the Code of Judicial

Conduct can occur even if the violations of the Code are not reversible legal

error. There are two different standards for each of these violations

3.4.3 The June 7, 2012 Order disputed other facts in the affidavit supporting

the disqualification motion and further violated the Uniform Superior Court Rule

25, et seq. as Judge Baldwin did not refer the motion to another judge and did not

cease acting on the merits of the case, as required by USCR 25.3

3.4.4 The lynchpin in all appellate matters in this case is Judge Baldwin’s

violations of the Canons of the Code of Judicial Conduct (or, “Canons”) and the

Glover & Davis lawyer’s selection of Judge Baldwin. The Glover & Davis judge


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shopping selection of Judge Baldwin was doable with a combined feigned

“emergency” motion (V1 p.13) and the absence of a Uniform Superior Court

Rule 3.1 case management plan. (V2 p.310; V3 pp. 436, 447, 506) Glover &

Davis lawyers engage in a pattern of judge selection conduct. Superior Court

Judge Louis Jack Kirby knew of this when he suggested Taylor Drake as counsel

for John Harold Murphy. See, Mayor & Aldermen of Savannah v. Batson-Cook

Co., 291 Ga. 114 (2012).

Judge Baldwin, at that August 30, 2012 hearing, issued the following threat

to Michelle Murphy, whom he knew could not afford the litigation. But let me just talk again to the parties. Do y'all

want to keep putting all this money out here,

fussing about this thing?

I mean, again, if you don't have anything to fear,

if everything is all right, and everything's been

done the way it's supposed to be done, you don't

have anything to fear about losing custody of the

children.

And I just wanted to know if y'all really want to

just keep dragging this out like this. You know,

y'all can spend money to kingdom come, that kind

of thing. And there's no kind of guarantee that


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I'm going to award any attorney's fees, you know,

to cover any of this stuff. There's nothing that

requires me to do that. And so I just want y'all

to think about that. (Tr. Aug. 30, 2012, p. 29, lines 2-15)

It was at the next hearing that Elizabeth “Lisa” F. Harwell, an attorney who

appears before Judge Kirby on a regular basis with her private clients,

(Tr. Aug. 30, 2012, p. 68, line 9) was caught by counsel for Michelle Murphy

converting funds to her personal use in violation of USCR 24.9(8)(g). As a part

of the corruptive conduct of Judge Baldwin, he approved of the violation of the

LAW by Elizabeth “Lisa” F. Harwell (Tr. Nov 15, 2012,

p.30, l. 9-p.33, l. 22).She then began attempting to get Judge Baldwin to Order

the employment of another expert psychologist, called a “custody evaluator.”

There are no special circumstances to justify this unnecessary expense. This was

yet another expensive, unnecessary “expert witness” litigation tactic in which

Michelle Murphy could not afford to equally participate and litigate.

Those costs were paid from the funds originating from and/or controlled by

Renee L. Haugerud. Elizabeth “Lisa” F. Harwell selected the “custody

evaluator,” not experts for the best interest of the children, as their lives were

being tormented by the snatch and grab litigation tactics of the John Harold


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Murphy and Renee L. Haugerud cadre of lawyers, investigators and experts who

cannot even legally turn up an untidy lawn.

Judge Baldwin, who was very ruffled by the disqualification motions’

disclosure of his conduct and the appeal of his Order denying them, began to

participate with the Glover & Davis lawyers, who were using the tremendous

disparity in income and wealth of the parties as a detriment to Michelle Murphy.

In his June 7, 2012 Order, Judge Baldwin disputed the relevant facts contained

in the supporting affidavit. (V2 p.306) See, Isaacs v. State, 257 Ga. 126 (1987);

Birt v. State 256 Ga. 483 (1986). Judge Baldwin opposed each disqualification

motions that he denied with a travesty of justice Order that was filed on

December 4, 2013, without referring the matter to another judge. (V17, p.3827)

3.4.5 The motion to disqualify Judge Christopher McFadden also identifies the

ability of counsel for Michelle Murphy to obtain appellate relief. This motion is

included here, without attachments, as Attachment 158. Court of Appeals panel with Judge McFadden written punished Millard

Farmer and Larry King by Order them to pay $2,500 to John Harold Murphy for

delaying the litigation. Can anyone imagine the fate of Michelle Murphy if she

had not obtained the information about the fabricated foundling on January 1,

2014. The Court of Appeal Rule used to fine Larry King and Millard Farmer


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provided them no due process rights. There was no delay that was not either

created by the corruption of Judge Baldwin or the Court of Appeals in attempting

to apply retroactively a statute.

It was necessary for Michelle Murphy to present a ready to file Petition for a

mandamus to the Attorney General to waive service before Judge Baldwin

following the advice of the Attorney General denied the motion with the

December 4, 2013. See, the attached petition for mandamus, without

attachments, that was presented to the Attorney General. Attachment 156

The disqualification motions affected the contempt adjudications; more accurately stated, the disqualification motions were Judge Baldwin’s corruptive motivation for the contempt adjudications.

After Judge Baldwin’s June 7, 2012 denial of his disqualification, Judge

Baldwin clothed himself with a Teflon armor attitude and declared as follows.

And I’m not going to recuse myself. I’ll tell you

right now, I’m not going to recuse myself. And I’m

going to put in there -- because y’all have already

had your chance on recusal. It’s been appealed. They

upheld me staying in this case and not recusing

myself. And we’re just going to keep it like

that.[emphasis supplied] (Tr. Oct. 3, 2013, p. 17) See, Murphy v.


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Murphy, 322 Ga. App. 829 (2013)

Counsel for Michelle Murphy has never understood if the above statement of

Judge Baldwin. This statement could be a part of Judge Baldwin’s absence of

knowledge about the law, or it could be a sophisticate cover for the statement

that Judge Baldwin made on August 13, 2013 when he informed counsel that

he was a classmate of the soon to be Chief Justice Hugh Thompson. Judge

Baldwin after identifying the relationship stated that after this case that he

was going to contact Justice Thompson and ask that he eliminate appeals of

disqualification motions until the end of domestic relations cases. If Judge

Baldwin did make the request and discussed the case, this should be revealed

to counsel for Michelle Murphy. Certainly, Justice Thompson had no role in

the conduct of Judge Baldwin, but it is difficult to determine the reason that

Judge Baldwin continually made the same statement that a lawyer is only

granted one opportunity to seek a recusal. It is expected that Judge Baldwin

used the same line about being a personal friend of Chief Judge Thompson

with other persons who have been assisting Judge Baldwin in what is nothing

more than aspects of his corruption.

Sticking by that manifesto that a lawyer can only file one motion, regardless

of later events, but failing to perform his non-discretionary, sworn duty, Judge


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Baldwin refused to obey the non-discretionary dictates of Uniform Superior

Court Rule 25, et seq. (Recusal) and never entered an order adjudicating any

other disqualification motions that were filed on June 13, 2012 (V3, p.436); July

2, 2012 (V3, p.502); Aug. 19, 2013 (V10, p.1904); Aug. 28, 2013 (V11, p.2195);

Sept. 13, 2013 (V12, p.2321); Oct. 7, 2013 (V14, p.2890); and Nov. 26, 2013

(V17, p.3639) until December 4, 2013 when he entered yet another Order in

which he, as he did in his June 7, 2012 denial of his disqualification motion,

once again opposed by disputing his disqualification motion’s affidavits with

both deceptive and false statements. (V17 p.3827)

Adding grounds to his disqualification and thereby his corruption in the

unadjudicated, pending disqualification motions, Judge Baldwin, with the

motions pending, and without adhering to USCR 25.3 to “temporarily cease to

act upon the merits of the matter and shall immediately determine the timeliness

of the motion and the legal sufficiency of the affidavit, and make a

determination, assuming any of the facts alleged in the affidavit to be true,

whether recusal would be warranted” proceeded with the Glover & Davis

request to hear the merits at an August 13, 2013 hearing. That hearing resulted

in the August 23, 2013 Order.

Baldwin never read before signing and filing the ex parte obtained August 23,


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2013 Order. (V11 p.2214) Judge Baldwin defends the ex parte letter delivered

by Michael Williams Warner (V14, p.2752) that accompanied the proposed

August 23, 2013 Order.

THE COURT I’m just tired of things -- Like I

noticed in this thing y’all talk about some kind

of ex parte conversations. I don’t think I have

had any ex parte conversations with Mr. Drake

about this anytime lately if I ever had any. I

don’t think, since the beginning of this case I

have, partly because of all the stuff that’s been

going on in the State about ex parte

conversations. * * * And I don’t believe I

have had any ex parte conversations, and I don’t

see how y’all could know about any unless you

supposedly have my phones bugged or his phone

bugged. (Tr. Oct. 3, 2013, p.15, lines 4-17).

Before Michelle Murphy received or learned of the ex parte supported

August 23, 2013 Order, a deputy sheriff, whose office is represented by Glover

& Davis PA, came to the home of Michelle Murphy to get the children to comply


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with the modified visitation, nunc pro tunc to August 13, 2013. (V14, p. 2702)

The August 23, 2013 Order was obtained with an ex parte communication to

Judge Baldwin, containing facts not in evidence and false statements, not

provided to counsel for Michelle Murphy, until after the Order was obtained and

filed. (Tr. Oct. 3, 2013, p. 19, lines 12-23)

On August 29, 2013, the Glover & Davis lawyers filed a Motion for Indirect

Criminal Contempt accompanied only with a “notice of hearing” without a Rule

Nisi or subpoena requiring that Michelle Murphy attend a hearing. (V12,

p.2243), Michelle Murphy responded on September 23, 2013 to that contempt

motion with detailed, supporting affidavits refuting the motion. (V14, p.2721)

That motion and the Amended Contempt were abuses of the criminal process.

A proceeding on the motion occurred on October 3, 2013 without a Rule Nisi

or subpoena for any person to attend. The response, with support of affidavits

from the children, with a recorded cell phone conversation by one of the children

with John Harold Murphy, clearly indicated that John Harold Murphy could not

sustain an indirect criminal contempt, even if he had provided the due process

required service, as he consented to the children not visiting, as he was in St.

Thomas on his visitation time. (V14, pp. 2743, 2758, 2763)

After John Murphy and the Glover & Davis lawyers orchestrated the Deputy


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Sheriff’s illegal display of force to the children gimmick that did not result in

an incident, and the Glover & Davis lawyer realized after obtaining the response,

supported by the affidavits of the children and their mother, that John Harold

Murphy had made a false statement under oath, they changed their attack.

The Glover & Davis lawyers then attempted to use the August 23, 2013 Order,

while it was on appeal to the Supreme Court of Georgia (V14 p.2774) as the

basis for the hasty, illegal filing on Friday, September 27, 2013 of an Amended

Contempt Motion (V14 p.2779) The Amended Contempt Motion was one

shoddy piece of legal work apparently designed only to take additional

advantage of Judge Baldwin while also initiating a threat of incarceration action

against Michelle Murphy and her lawyers to appease Murphy/Haugerud.

The Amended Contempt Motion was not supported with a notice of hearing

that would have been an infirm due process notice to a person charged with the

October 3, 2013 indirect contempts. (V14 p.2807)

The Amended Contempt Motion did not include a Rule Nisi

The Amended Contempt Motion did not subpoena any person.

The Amended Contempt Motion was not even copied to Larry King.

The Amended Contempt Motion stated that it was for contempt of

“Defendant’s lawyer” [singular] when Michelle Murphy had two lawyers and


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the lawyer charged was not named. (V14, p.2782)

The Amended Contempt Motion was not a charging document that comported

with the LAW to the extent that it could legally be adjudicated. (V14, p.2817)

The Thursday, October 3, 2013 court calendar posted and sent to counsel from

the Clerk of Court of Coweta County did not indicate that the Amended Motion

for Contempt, or any motion for contempt, was on the Thursday, October 3, 2013

calendar, as the “Prosecutor/Plaintiff” Taylor Drake of Glover& Davis did not

obtain from the Judge, or any Clerk, a Rule Nisi to have served upon the persons

charged. (V14 p. 2807) See, Crocker v. Crocker, 132 Ga. App. 587, 589 (1974)

Michelle Murphy, Larry King and Millard Farmer filed a comprehensive

response to the September 27, 2013 Amended Motion for Contempt.

(V16, p.3334) The response pled to the jurisdiction of Judge Baldwin to hear the

Amended Contempt Motion.

Judge Baldwin abrogated his judicial authority in all relevant matters in the

entirety of this case to the Glover & Davis lawyers. It is unconscionable, but

certainly not unpredictable that Judge Baldwin delegated the preparation of the

contempt orders to the Glover & Davis lawyers.

It is unconscionable that the Taylor Drake included false findings of fact in

the Order that he prepared for Judge Baldwin to sign. The Glover & Davis


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lawyer included the findings in the Order that Judge Baldwin may or may not

have read before singing, as on previous occasions Judge Baldwin did not read

the orders that he signed.

The November 19, 2013 Order falsely states, without evidence that

“Defendant and her lawyers had reasonable and sufficient notice of the hearing.”

Again, the Order states that “The Court further finds that Defendant had

reasonable notice of the hearing but failed to appear and present evidence.”

The ironic aspect of this finding that Defendant “failed to present evidence”

is the August 23, 2013 Order that “Defendant” is accused of violating resulted

from a hearing on August 13 where Michelle Murphy and each of her counsel

did appear, but Judge Baldwin aborted the hearing for a personal commitment

and never allowed Michelle Murphy to present any evidence, including the

principal and teacher from the children’s school, who awaited all of the hearing

to testify. Shore v. Shore, 253 Ga. 183 (1984) and its progeny.

There was absolutely no evidence to support that Michelle Murphy, Larry

King or Millard Farmer were provided a Rule Nisi, a subpoena to appear or any

other notice that fulfills the requirements of due process.

Judge Baldwin doesn’t read the orders that he signs, and, worse, has such little


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understanding of the law relating to contempt that on October 3, 2013, he

initially held Larry King in contempt for just attempting to explain the

impropriety of Judge Baldwin beginning the hearing with the shoddy papers that

the Glover & Davis lawyers filed without the vaguest understanding of the due

process protections associated with criminal prosecutions, albeit the prosecution

for contempt.

The inability of Judge Baldwin even to allow Larry King to explain the due

process protections involved in contempt actions speaks the reason that Uniform

Superior Court Rule 3.1 was never implemented in the Coweta Judicial Circuit

and the reason that due process protections in the court is at such a low level

that orders drafted by political friends are signed without reading.

Cannon 2A, 2B, Canon 3E of the Code of Judicial Conduct are substantive

grounds for recusal or disqualification of a judge. These grounds should be

assessed in light of two well-recognized principles of LAW*. First, no one

has a right to select the judge of their choice, and a judge, of course, has no

right to select the cases over which the judge presides. See Uniform Superior

Court Rule 3.1. Yet, that is what happened in this case and happened in the

Coweta Judicial Circuit on a regular basis. (V3 pp.447-448)

Persons accused of conduct that subjects them to incarceration are entitled to


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a trier of fact who is not biased. Judge Baldwin and the contempt convictions do

not open the first gate to uphold the contempt convictions under the Cole v.

Arkansas, 333 U.S. 196 (1948) standard of adequate notice of the charges and

under the In re Winship, 397 U. S. 358, requirement that to support a criminal

conviction the record must reasonably support a finding of guilt beyond a

reasonable doubt.

Judge Baldwin not only deprived the Michelle Murphy, Millard Farmer and

Larry King of a fair hearing, he deprived the them of an opportunity to file a

motion for new trial before a fair jurist, when, after the November 19, 2013

contempt Order, he denied all of the disqualification motions that were pending

before the November 19, 2013 Order., thereby not allowing another judge to

take over this case. With Judge Baldwin remaining in the case there is no

possibility for the applicants to obtain a fair ruling on a motion for new trial that

reviews the criminal contempt convictions under a different standard. See,

Walker v. State, 292 Ga. 262, 264-265 (Ga. 2013) This was Judge McFadden’s

Fayette County basis for granting a new trial.

In particular, Section (B) (7) of Canon 3 of the Georgia Code of Judicial

Conduct forbids a judge from considering an ex parte communication:

Judges shall accord to every person who has a legal interest in a


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proceeding, or that person's lawyer, the right to be heard according to law.

Judges shall not initiate or consider ex parte communications, or consider

other communications made to them outside the presence of the parties

concerning a pending or impending proceeding.

Ex parte communications “are presumed to have been in error.”

"[W]hen the court considers facts not properly in evidence, the other party has

rights that cannot be protected fully if he is thus denied the privilege of cross-

examination. Arnau v. Arnau, 207 Ga. App. 696, 697 (Ga. Ct. App. 1993)

The law relating to indirect contempt is clear. Michelle Murphy, Millard

Farmer and Larry King were accorded no due process protections that Crocker

v. Crocker, 132 Ga. App. 587, 589 (1974) identifies must be provided:

In cases of constructive contempt of court, where the alleged

contumacious conduct is disobedience to a mandate of the court, not an

act in the presence of the court or so near thereto as to obstruct the

administration of justice, the law requires that a rule nisi issue and be

served upon the accused, giving him notice of the charges against him,

and that he be given an opportunity to be heard. [citations omitted]

Judge Baldwin’s adjudication of the contempts incarcerates Michelle Murphy

for defending her family, and her lawyers for defending her. (V17, p.3624)


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Memorandum of LAW to Request for Investigator of Corruption “Corruption” Defined It is relevant to offer a few definitions of “corruption,” as corruption is the conduct

that this Motions seeks investigating.

It is ironic that the root cause of the corruption that this motion seeks to obtain

assistance in having investigated and thereafter being the basis for his prompt

permanent removal from office is the corruption of Judge Baldwin who must

approve of this motion before the Clerk of the Superior Court of Coweta County

will not file without the approval of Judge Baldwin.

Corruption is dishonest actions that destroys people's trust in the person or group, as the news of “corruption” in how your bank is run, that makes you close your account and invest your money somewhere else.

The noun “corruption” comes from Latin — com, or "with, together," and

rumpere, meaning "to break." Corruption breaks your trustworthiness, your good

reputation with others, like the news of corruption in former Mayor of Atlanta, Bill

Campbell’s office that shocked all, but those who had ever dealt with Bill Campbell

either in court, or in his capacity as mayor.

When you corrupt something that society requires to be pure or honest, you take

away those qualities from all courts. To prevent judicial corruption we have the Code

of Judicial Conduct, Rules of Court, the Constitution of Georgia and United States,

the statutes of Georgia and United States (or, collectively the “law”)

Corruption is wrongdoing on the part of an authority or powerful party through

means that are illegitimate, immoral, or incompatible with ethical standards.

Corruption often results from patronage and is associated with bribery of different

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Page 142 of 147

types such as exchange of positions of power, or other things of value.

Former Georgia Supreme Court Justice Charles Weltner admonishes state actors

in a concurrence in the case before him “That that here is a timeworn, but never the

less true, expression that illustrates the case at hand. You cannot be a little pregnant.”

City of Atlanta v. J. A. Jones Constr. Co., 260 Ga. 658, 662 (Ga. 1990).

We were likewise warned in Mayor & Aldermen of Savannah v.

Batson-Cook Co., 291 Ga. 114 (2012), another Glover & Davis PA case of the law

firm in this case that was also involved judicial corruption. That case also resulted

from judge shopping that occurred during the absence of a Uniform Superior Court

Rule 3.1 case management plan.

Acts of Omission and Commission Defined. The level of Corruption by those participating with Judge A. Quillian Baldwin, Jr.

in his corruption was involved different levels of culpability. For that reason to

emphasis those differences, acts of “omission” and “commission” are identified.

2.2.1 The are more synonyms for the word “omission” than for ‘commission’, but

the range of interpretations of the word “commission” is wider than for “omission”.

Dictionaries advise use that an omission can be an oversight, lapse, slip, error,

blunder, faux pas, something deliberately or accidentally left out or not done,

something neglected, involving apathy toward or neglect of duty. In Catholic

teaching that is the religion of Nancy Michelle Murphy, Jack Murphy, age 16 and

Thomas Murphy, age 14, her children, an ‘omission’ is a “failure to do something

one can and ought to do. If this happens advertently and freely, it is considered a

sin.”


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In criminal law, an omission is a ‘failure to act’, which can amount to an “actus

reus”, Latin for guilty act. However, an omission can give rise to liability when the

law ‘imposes a duty to act’ and the defendant is in breach of that duty. Jurists have

often taken the view that “a failure to act might be morally indefensible”, and

therefore a liability may be imposed when such failure is “sufficiently

blameworthy”.

The word “commission” has several meanings, but in this context the synonyms

used are, “order, command, directive, charge, contract, assignment”. The “act of

committing” is seen as a positive act undertaken consciously. It is an “authoritative

order, charge, or direction; authority granted for a particular action or function.” In

assigning blame for governmental decisions that have contributed to a loss of

revenues for the government and, in direct consequence, to pecuniary gains to

private individuals or firms, one will have to make a distinction between acts of

“omission” and “commission”.

Be it a judicial inquiry, an administrative inquiry or a legislative inquiry, any

inquiry into a loss of revenue to government and a consequential pecuniary gain

has to understand and bring out these distinctions, since every such case need not

be a criminal act. Further, in inquiring into decisions that involve a loss of

revenue to government or that involve a misuse of the taxpayer's money, one

must also make a distinction between the costs imposed by inefficiency and those

imposed by malfeasance or corruption. Inefficiency is not necessarily a criminal

act, as corruption is, even if its fiscal implications are the same.

In this case those participating in the corruption of Judge A. Quillian Baldwin, Jr.

engaged in acts of omission and commission that may have had a similar impact on

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Page 144 of 147

the public. Moreover, there are deliberate acts of corruption as well as unintended

acts of inefficiency that have also imposed a burden on Michelle Murphy.

Investigation of this conduct and its disclosure should consider nuances. Everyone

involved in the decision making chain involved in the corruption by Judge Baldwin

should not be tarnished, or left untarnished with the same brush. The culpability and

liability of those who were merely negligent is less than that of those who

consciously intended their failure to act for fear of the political consequences of

taking some action in returning government funds.

The guilt by association of those whose acts of omission contributed to the

enrichment of those really guilty of acts of commission must be viewed in the correct

perspective, i.e., the conduct of Julia Harris and Melissa Sams should not be judged

in the same manner as the conduct of Elizabeth “Lisa” F. Harwell; just as the conduct

of the Assistant District Attorney should not be judged in the same manner as that

of the District Attorney in not acting to recover the funds that Nan Freeman and

Freeman Court Reporting, Inc. illegally took from the counties and litigants in the

Coweta Judicial Circuit. While the culpability of these state actors should be judged

differently, the investigation of each of the participants should be with the same

urgency and vigor, as time is critical in rectifying the wrongs inflicted upon Michelle

Murphy and her children.

The Affidavit of Millard Farmer is attached.

7. Request for Relief 7.1 PLEASE UNDERSTAND: This family can resolve this dispute if John Harold

Murphy and Judge Baldwin allow Michelle Murphy contact with the children as


Page 145 of 147

provided in the 2006 Divorce Decree and immediate access to visitation with Jack

and Thomas.

7.2 Michelle Murphy and her counsel request that Judge Baldwin allow this family

to continue resolving their dispute by immediately removing the no contact

provision of the August 23, 2014 Order and specifically allowing Michelle Murphy

the rights of visitation that John Harold Murphy has with the children at Elevations

RTC in Utah and by informing John Harold Murphy that he must immediately

provide Michelle Murphy her back and presently due child support payments.

7.3 Counsel for Michelle Murphy requests an opportunity to visit with Jack and

Thomas in order to obtain information necessary to defend the motion for summary

judgment.

7.4 Michelle Murphy and her counsel request, upon the completion of the other

part of the response to the Motion for Summary Judgment, that Judge Baldwin deny

the motion for summary judgment.

7.5 Michelle Murphy and her counsel request that a State of Georgia compensated

investigator immediately be provided to investigate the corruption of Judge Baldwin.

7.6 Michelle Murphy and her counsel request that Chief Judge A. Quillian

Baldwin, Jr. be required to submit to questions under oath relating to cases over

which he has presided that were not assigned to him under a written, filed with the

Clerk of Court, Unif. Super. Ct. R. 3.1 Method of Assignment, plan.

7.7 Michelle Murphy and her counsel request that counsel be permitted to present

evidence in support of this motion and matters relating to the facts contained in this

motion before an independent jurist.

7.8 Michelle Murphy and her counsel request that all Orders entered in this case

before the filing of this motion be vacated.

mailto:[email protected]

mailto:[email protected]

CERTIFICATE OF SERVICE

I hereby certify that I have this day I perfected service of a copy of the foregoing

Motion to Rescind electronically as follows.

Taylor B. Drake Glover & Davis, P.A. P. O. Drawer 1038 Newnan, GA 30265 [email protected]

Michael W. Warner Glover & Davis, P.A. P. O. Drawer 1038 Newnan, GA 30265 [email protected]

Peter A. Durham Glover & Davis, P.A. P. O. Drawer 1038 Newnan, GA 30265 [email protected]

Stephen E. Hudson Ga. Bar No. 374692 Kilpatrick Townsend & Stockton LLP 1100 Peachtree Street, Suite 2800 Atlanta, Georgia 30309-4528 [email protected]

William R. Poplin, Jr. Ga. Bar No. 584535 Kilpatrick Townsend & Stockton LLP 1100 Peachtree Street, Suite 2800 Atlanta, Georgia 30309-4528 [email protected]

Teresa E. Lazzaroni [email protected] trial court counsel for Elizabeth F. Harwell

Elizabeth F. Harwell Harwell, Brown & Harwell, PC Newnan, GA

[email protected]

This 21st day of March, 2015.


��Millard Farmer Georgia Bar No. 255300 P.O. Box 1728 Atlanta, GA 30301-1728 (404) 688-8116 [email protected] Counsel for Nancy Michelle Murphy and Millard Farmer

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