b50130 RPF Corruption Motion W Exhibit 1 and All Atts PDF

Attachment 145, Page 1 of 1
EXHIBIT 1
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
Part 1 of Motion for an Investigation, Public Disclosure and
Termination of the Corruption of Judge A. Quillian Baldwin, Jr.
and those participating in and initiating his corruption, by financing, 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 Baldwins Corruption

With Plea to Jurisdiction
Page 1 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
Baldwins judicial corruption subjected Michelle Murphy, Jack Murphy and
Thomas Murphy.

Page 2 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 Haugeruds 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 Baldwins 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 Murphys 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 3 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 Baldwins
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 Drakes 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 4 of 147
Included here is a Plea to Judge Baldwins 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 Renees 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 5 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 courtordered 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

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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 exhusband 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 7 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 mothers involvement post discharge. Clearly the
intensive therapy and assessment that the boys have now received at

Page 8 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 psychologists 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 Murphys 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 stepmothers 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 counsels exposure of the violations of the

Page 9 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 10 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
Baldwins 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
McGarrahs 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 11 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 judgeshopped. 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 12 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 Murphys counsel to preserve a

record in this case that exposes the corruption, as the basic modus operandi of
Judge Baldwins 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 Murphys 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 Baldwins Corruption
1.3.1.2
Examples of protectors of Judge Baldwins 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
Page 13 of 147
Murphy that he perfected with Deputy Sheriffs, whom he prearranged to be

present in the courtroom.
1.3.1.4
Judge Baldwin performed his take-down stunt before the full array
of Glower & Davis lawyers, the Kilpatrick Townsend & Stockton LLP lawyers
and the cadre of Kilpatrick Townsend & Stockton LLP gawkers who came
from Atlanta to Newnan just to observe the take-down. The expression on the
face of Judge Baldwin as he sought an approving view from these lawyers and
their supporting gawkers was that of a professional, Saturday night, small town
wrestler as the wrestler exchanged looks with the ring-side revelers seeking
approval and looks from the wrestler, starting with the suffering of his
opponent lying unconscious on the mat, bleeding and maybe praying that there
would not be another knee-drop to his back in response to the approval from
the ring-side revelers.
1.3.1.5
After the May 27, 2014 temper tantrum, counsel for Michelle
Murphy requested that the court reporter allow counsel to purchase the audio
recording of the proceeding. Nan Freeman, the court reporter, refused by
stating that the audio recording was her work product.
1.3.1.6
After Michelle Murphy filed a plea for a change of heart by Judge
Baldwin, it was then necessary for counsel to file a freedom of information

request to obtain the four Blame Yourself! omitted pages from the transcript
that Nan Freeman had sworn was complete when she filed the transcript, even
though the critical pages were not included.
1.3.1.7
It is understandable that Nan Freeman wished to protect Judge
Baldwin; it is not understandable that she would provide an oath that she had

Page 14 of 147
provided a complete transcript when she omitted the highly relevant four pages
that punctuated the conduct of Judge Baldwin that was against the LAW*
1.3.1.8
After a threat by counsel for Michelle Murphy to bring an action to
obtain the audio recording of the proceeding, Judge Baldwin e-mailed counsel
for Michelle Murphy and asked that Nan Freeman not be sued, as she did not
have the money to afford the litigation. There was a motion to disqualify Judge
Baldwin based, in part, upon that request to protect Nan Freeman.
1.3.1.9
This request by Judge Baldwin for immunity for Nan Freeman was
both conduct that is against the LAW* and conduct that is personally insulting
to counsel for the mother of Jack and Thomas.
1.3.1.10
Judge Baldwin just did not get that it was corruption that counsel
for Michelle Murphy was resisting and not an opportunity to participate in the
corruption.
1.2.1.11
Counsel did file the necessary action against Nan Freeman and
the Board of Court Reporting that resulted in obtaining all of Nan Freemans
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 15 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 counsels calls.
After several unsuccessful attempts, Cynthia Clanton, an employee of the State
of Georgias Administrative Office of the Courts, returned counsel for
Michelle Murphys 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 Clantons effort to assist
Page 16 of 147
further exposure of the illegal conduct of Nan Freeman and thereby Judge
Baldwin.
1.3.1.18 This information is included in this motion seeking assistance for
investigation of the corruption of Judge Baldwin, as Millard Farmer strongly
suspects that Cynthia Clanton has provided assistance to persons assisting
Judge Baldwin in his corruption, including Nan Freeman and others. It is not
the function of Cynthia Clanton to assist persons compensated by the State of
Georgia in avoiding detection from their illegal conduct.
1.3.1.19 There is a large amount of competent investigative work that is
required by the State of Georgia empowered investigators to determine the
persons who have assisted Judge Baldwins law clerk, Melissa Sams, and
others actively participating in Judge Baldwins 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 Freemans 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.

Page 17 of 147
1.3.2.2
On May 27, 2014, these persons were in the courtroom, awaiting an
opportunity to testify. Judge Baldwin denied Michelle Murphy, Jack Murphy

and Thomas Murphy the right to testify or to present their evidence directly or
from their witnesses.
1.3.2.3
At the May 27, 2014 proceeding and numerous earlier hearings,
Judge Baldwin intentionally denied Michelle Murphy, Jack Murphy and

Thomas Murphy the protections provided to them by LAW*.
1.3.2 .4
Corruption, and not LAW*, dominated the conduct of Judge A.
Quillian Baldwin, Jr. in this case.

1.3.2.5
A substantial part of the funding that motivated the corruption that
dominated the judicial decision making and motivated benefits derived from
corruption in this case, came directly and indirectly from present and future
anticipated funding from the assets of Renee L. Haugerud, her controlled
Galtere, Ltd, and other entities in which Renee L. Haugerud participated
directly and indirectly.
The Lust for the Money Derived from the Financial Interests of Renee L.
Haugerud Prevented Dispute Resolution
1.3.2.6
There are evasion of state and federal tax consequences that are
suspected, involving assets that have supported this litigation and the lifestyle
of John Harold Murphy, Renee L. Haugerud and others that require
sophisticated investigation, as, correct or not, it has been reported that St.
Thomas provides special income tax credits to individuals with children, as
children assist in establishing residency associated with tax exemptions that
otherwise could not be claimed.
Page 18 of 147
1.3.2.7
The lust of the Glover & Davis lawyers for attorney fees prevented
any fair attempts to resolve the dispute that created this case either before or
at any time during the litigation.
1.3.2.8
Renee L. Haugerud, before the litigation began, told Michelle
Murphy that she should just surrender Jack and Thomas to John Harold
Murphy, as she and John were going to get the children from her.
1.3.2.9
The financial strength of Renee L. Haugerud and the willingness of
John Harold Murphy to make false statements and gain assistance from
Superior Court Judge Louis Jack Kirby presented what the litigation has
resulted in accomplishing the financial devastation of Michelle Murphy. This
was only possible with the corruption and the absence of the protections of the
LAW* provided to Michelle Murphy.
Judge Baldwin Engaged in Judicially Corrupt Conduct.
1.3.2.10
Judge Baldwin engaged in much of his LAW* violations in order
to protect the interest of those participating in the universe of Judge Baldwins

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 Baldwins 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.

Page 20 of 147
1.4.6
We should deeply regret the failure of our justice system to eradicate the
corruption of Judge Baldwin and his participants for failing to provide Michelle
Murphy the protections that the LAW* should have accorded Michelle Murphy,
her counsel, Jack Murphy and Thomas Murphy after the filing of the initial
motion to disqualify Judge Baldwin and Elizabeth Lisa F. Harwell, the
guardian ad litem, who illegally took money provided to her in trust, that, as a
part of Judge Baldwins 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
Page 22 of 147
was crying, and shaking, saying, No! No way! Were 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 Ill take you there if you dont let go of your mother. [that
deputy took on the demeanor of Judge Baldwin] Thomas responded
that he did not care, hed 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.

Page 24 of 147
14.
The attached electronic messages are some of the true and
accurate messages that I have received. Each of their texts break my

heart, because I feel the distress of Jack and Thomas. The portion of
these electronic messages that are attached to my Emergency Motion
to the Georgia Supreme Court that is to be filed on Monday, June 2,
2014 are also true and accurate copies of text messages that I have
received. Also attached is a true and accurate copy of an email which
I sent to John Murphy, asking that he take Thomas immediately to a
doctor, as he was very sick.
This 1st day of June, 2014.
A sampling of the e-mail exchanges attached to the affidavit of

Michelle Murphy that were presented to Judge Baldwin follow. The
affidavit and other information provide in the motion is relevant to this
motion to support that the corruption of Judge Baldwin resulted while
he had full knowledge of the conduct of the participants in his
corruption that support the malicious nature of the corruption.

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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 Baldwins 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 Murphys 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 27 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 Jacks 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 Jacks transporters held tightly onto Jacks 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 29 of 147
from mental health problems, emotional disorders, learning disorders, substance abuse, and other underlying
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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 Baldwins retaliation against his mothers attorney, Millard
Farmer and his mother, for raising issues about this Judges 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
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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 Baldwins 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 Murphys 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
Guantnamo 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 letters
attempts to shift the obligation to defend John Harold Murphys 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 childrens and my home. You know; the alimony stops in September, Mr.
Farmer?
Dont 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?
Dont you know Mr. Farmer that the studies about the authorities disciplining judges
about their demeanor does not apply to Georgia?
Dont 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.
Dont 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.

Dont 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.
Dont you understand, Mr. Farmer John Harold Murphy is morally corrupt and he
now has the money that Renee L. Haugerud supplies to corrupt others?
Dont 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?
Dont 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?

Page 37 of 147
1.6 There were attempts to obtain a hearing to present evidence of the

detriment to the lives of Jack and Thomas while they were in St. Thomas,
USVI, but first, we should document the initial appointment by Judge
Baldwin of Melissa Griffis as the initial guardian ad litem, who resigned, and
who, as an act of retaliation against Michelle Murphy for seeking to disqualify
her, provided Judge Baldwin an Order to appoint Elizabeth Lisa Harwell as the
guardian ad litem.
After omitting the introductory comments referring to Tinker to Evers to Chance,
the disqualification motion follows.
1.8 The conduct of Kirby to Drake to Baldwin in this case was not
ethical or legal and this is where the Baseball's Sad Lexicon transforms
into Justices Sad Lexicon.
1.9 Judge Jack Kirby recommended that his friend and former client,
John Murphy, employ the law firm of Glover & Daviss Taylor Drake in
this litigation.
1.9.1 Judge Jack Kirby knew both John Murphy and Glover & Daviss
Taylor Drake extremely well.
1.9.2 Judge Jack Kirby knew that Glover & Daviss 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 & Daviss
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 & Daviss 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 & Daviss 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 Baldwins 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 Baldwins 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 Baldwins point about Ms. Griffis firm making a
contribution almost a month after her appointment? Was Judge Baldwins point
that Ms. Griffis firm was getting its due to him late?
1.11.4.3 Was Judge Baldwins 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.

Page 43 of 147
2.2.2
It was just unfortunate for Judge Baldwin that Judge Jack Kirby selected
the Glover & Davis judge shoppers to call upon Judge Baldwin to pay the Piper
in this matter.
2.2.3
John Murphys 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 Murphys 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.
Page 44 of 147
2.5 To the eyes of counsel for Michelle Murphy, Judge Kirby to

Glover & Daviss Taylor Drake to Judge Baldwin was fleeter than
birds and beginning the process of ruthlessly pricking in route to
Thomas, Jack and Michelle Murphys 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 Justices Sad Lexicons aspect of Kirby
to Drake to Baldwin. There is not a clean hand in the crowd. Each is
Page 45 of 147
beholding in various degrees and ways to the other, and to the purse
strings of John Murphys 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 Justices Sad Lexicons 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 Murphys Summons
John Murphys Complaint for Modification, et al.
Answer of Michelle Murphy with Counterclaim and Third Party
Complaint
John Murphys Motion for Appointment of Guardian ad Litem
Michelle Murphys Response to Johns Motion for Guardian ad Litem
John Murphys Motion for Immediate Relief
Michelle Murphys Response to Motion for Immediate Relief
Preliminary Domestic Relations Financial Affidavit of John Murphy
John Murphys 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.
Page 46 of 147
3.1 The improper conduct of Judge A. Quillian Baldwin, Jr. in designating Melissa
Griffis as the Guardian ad Litem for the minor children, Jack Murphy and Thomas
Murphy in this case justifiably subjected Melissa Griffis to careful scrutiny by
counsel for Michelle Murphy. Kirby to Drake to Baldwin attempt to add to
Griffis to Justices Sad Lexicon and counsel for Michelle Murphy detected that
Melissa Griffis was a slow base runner in lifes 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 Baldwins 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
Page 47 of 147
for a Superior Court Judge that Judge Baldwin and retiring Judge Allen B.
Keeble attended.
3.2.2.2
Counsel for Michelle Murphy knew that Melissa Griffis practiced
before Judge Baldwin on a regular basis and had never challenged the manner
in which Judge Baldwin and other judges in the Coweta Judicial Circuit judge
shop for litigants and/or that the lawyers judge shop for judges. Lawyers
outside the circuit have a difficult time in detecting this type of conduct, which
can be utilized to subject their clients to prejudice. See Mayor & Aldermen of
Savannah v. Batson-Cook Co., 2012 Ga. LEXIS 488 (Ga. May 29, 2012)
3.2.2.3
Melissa Griffis had the ethical obligation to allow counsel for
Michelle Murphy to record the questioning of her after the conduct of

Judge Baldwin in appointing her as Guardian ad Litem and providing that she
would immediately receive $5,000 and $250 per hour for her services.
3.2.2.4
It is relevant that the standing order relating to fees for mediators,
including attorneys who serve in this capacity, in the Coweta Judicial Circuit
provides $150 per hour for the first two hours and $75 per hour for each
additional hour. Nan Newman, an attorney in the same law firm as Melissa
Griffis, with far more years experience than Michelle Griffis, is a qualified
mediator. See, Attachment 5, page 5 that, in part, states as follows.

Page 48 of 147
3.2.2.5
It is also relevant to note that in the Final Divorce Decree that the
Court only awarded Michelle Murphy, a person who at that time had 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.
Page 49 of 147
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.

Page 50 of 147
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. Boykins face.

3.6.5
No sooner had the lawyer completed his offer, Judge Samuel J. Boykin
arose from his chair and blurted, WE cant 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
litems 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 Palmers Election Campaign Committee. Melissa Griffis
Page 51 of 147
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.
Page 52 of 147
3.20
Judge Quillian Baldwin, in violation of the Code of Judicial Conduct,
attended the fundraiser for Emory Palmer at the DelAvant 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.

Page 53 of 147
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
Page 54 of 147
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 partiess 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
Page 55 of 147
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
Page 56 of 147
(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 McDonalds Drive-Through Service; there is one Difference
-- McDonalds Provides a Legal Service.
5.1 Judge Quillian Baldwin provided the Michelle Murphy and Children Parties a
McDonalds 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
Page 57 of 147
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 Drakes 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
Page 58 of 147
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 McDonalds drive-through window type of
justice by informing counsel for the parties that he would grant Taylor Drakes
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 McDonalds type of drive-through
window to pick up Taylor Drakes Order.
Page 59 of 147
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.

Page 60 of 147
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
Page 61 of 147
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 Kirbys 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

Page 62 of 147
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 Murphys 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
Page 63 of 147
17: 9:30, 10:00 at night in her office. I remember that.

Q. Are you familiar with that she consumed
18:
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.
A. Well, in one thing I read in your
10:
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?
A. Whatever I knew about I revealed. I
15:
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:
Page 64 of 147
01: didn't disclose the stock options -A. The transcript of what?
02:
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?
Q. It came up that Ms. Crouch says there were
09:
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.
Q. I mean, if the stock options had the
21:
22: potential of being as much as over $100,000 in value
23: they certainly should be?
24:
A. Absolutely.
Q. And if those weren't disclosed then it
25:
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
Page 65 of 147
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
Page 66 of 147
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.
Page 67 of 147
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?
A. We're friends.
19:
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?
Page 68 of 147
A. A big, old house.

13:
* * *
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?
A. I don't think I've heard the name of it to
19:
20: tell you the truth.
21:
Q. Hedgefun, f-u-n?
22:
A. It may be, yeah. That may be right.
Q. The 20 -- what is it, 35 foot or 25 foot
23:
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.
A. We just rode down the river and back a few
05:
06: hours.
07:
Q. And was that on a social occasion -A. Yeah.
08:
Q. -- that you were visiting Tennessee?
09:
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
Page 69 of 147
09: plane, of John's plane -A. (Witness shakes head negatively.)

10:
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.
Q. John?
17:
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.
Q. Nothing about their behavior or conduct?
07:
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.

Page 70 of 147
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.
*
*

Page 71 of 147
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.

Page 72 of 147
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

Page 73 of 147
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
Page 74 of 147
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.
Page 75 of 147
7.1.4
The results of this conglomerate of judges together with the malpractice
of Michelle Murphys 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.
Page 76 of 147
7.1.6.1
This guardian ad litem issue was John Murphys 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 Murphys psychological need to engage in
huff, puff and bluff negotiation that Taylor Drake was creating a very serious
situation for John Murphys 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 Murphys psychological need
to recover from his fathers 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
Page 77 of 147
was some kind of executive consultant with Galtere. The reality is that John
Murphy is best at disposing of Renee L. Haugeruds money and causing her
trouble. Unfortunately, John Murphy, with Renee L. Haugeruds 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. Haugeruds multimillion dollar wealth. Her business entities

funnel non-tax paid assets to his personal uses. John Murphys 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 Murphys feigned judicial power
associated with whom the children refer to as Judge Jack and his illegal,
tax-free schemes in concert with Renee L. Haugeruds businesses and her
other fiduciary responsibilities.
7.2 Lets 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
Page 78 of 147
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

Page 79 of 147
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 Baldwins 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
Page 80 of 147
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
Page 81 of 147
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 Murphys
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 Murphys transcript
from last school year. Attachment 32
Page 82 of 147
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 yall want me back. Counsel for
Michelle Murphy replied, No, we dont, 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.
Page 83 of 147
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 Drakes 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 Ive 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 Ive had
Page 84 of 147
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 didnt 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 wed allocate it at the very end.
Thats whats 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 doesnt mean that
shes obligated to pay -MR. FARMER: I know.
MR. DRAKE: It means the Court has consideration
to consider whos responsible for -THE COURT: All right. Look, look. Wait a
second. Im going to get this straight right now.
From now on, if you take a draw off of that
Page 85 of 147
money, please inform Mr. Farmer of these things. It

would just be a matter of copying him with whatever
youre 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.

Page 86 of 147
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 Murphys 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 Murphys 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
Page 87 of 147
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 Murphys 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 Courts 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.

Page 88 of 147
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 childrens 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 Foxys 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
Murphys 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 Murphys participation in
Page 89 of 147
the minor childrens 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.
Page 90 of 147
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
Page 91 of 147
Sheriffs 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 Sheriffs 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 childrens church is willing to assist the Pastor of
Taylor Drakes 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.
Page 92 of 147
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

Page 93 of 147
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.
Page 94 of 147
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
didnt. 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.
Page 95 of 147
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

Page 96 of 147
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 childrens safety. One thing is fortunate:
it doesnt 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.
Page 97 of 147
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
Murphys dedication to educating them. The childrens 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.

Page 98 of 147
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

Page 99 of 147
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
dont 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 didnt 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 doesnt 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. Haugeruds 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.

Page 100 of 147
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 Countys 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.
Page 101 of 147
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 handson 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 evaluators 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. Haugeruds 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.

Page 102 of 147
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
offenders 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).
Page 103 of 147
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 childrens 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.

Page 104 of 147
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

Page 105 of 147
of
Troup
County.
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.

Page 106 of 147
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.
Page 107 of 147
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
Murphys 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 Guantnamo Bay during the last six years have been
provided fairer hearings with less irate judges. The Settlement Agreement
provides as follows.

Page 108 of 147
The threat, without any legal authority to breach the agreement, and the letters
attempts to shift the obligation to defend John Harold Murphys conduct upon
counsel for Michelle Murphy is the typical, we-got-our-hand-selected-judge-andmillions-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.

Page 109 of 147
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

Page 110 of 147
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

Page 111 of 147
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 Baldwins 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 Baldwins
corruption, with Acts of Omission and Acts of Commission, are, in part, preventing
Page 112 of 147
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 Generals Office in order to obtain a
waiver of service. It is included here, without its attachments, as

Page 113 of 147
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 Baldwins 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 Baldwins corruption.
Page 114 of 147
2.6.1.3.1 It is relevant that Nathan Lee of Glover & Davis is the attorney for
Coweta County, which supplements Judge Baldwins 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.
Page 115 of 147
2.7
Information about Coweta Judicial Circuit Judge Kirby came to Millard
Farmers 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
Page 116 of 147
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 bonds 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

Page 117 of 147
Attorneys failure to respond to Millard Farmers 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 bonds 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.

Page 118 of 147
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

Page 119 of 147
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.

Page 120 of 147
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.
Page 121 of 147
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.

Page 122 of 147
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 Farmers 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 Baldwins Orders. On the last occasion, the Glover & Davis
lawyers had the Deputy Sheriffs of Coweta come to the home of Michelle

Page 123 of 147
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
Page 124 of 147
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 Murphys 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
Page 125 of 147
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 Baldwins
violations of the Canons of the Code of Judicial Conduct (or, Canons) and the
Glover & Davis lawyers selection of Judge Baldwin. The Glover & Davis judge
Page 126 of 147
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 t hreat
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
Page 127 of 147
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
Page 128 of 147
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

Page 129 of 147
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 Baldwins
corruptive motivation for the contempt adjudications.
After Judge Baldwins June 7, 2012 denial of his disqualification, Judge
Baldwin clothed himself with a Teflon armor attitude and declared as follows.
And Im not going to recuse myself.
Ill tell you
right now, Im not going to recuse myself.
And Im
going to put in there -- because yall have already

had your chance on recusal.
upheld
myself.
me
staying
And
in
were
that.[emphasis supplied]
this
just
Its been appealed.

case
going
to
not
keep
recusing
it
like
(Tr. Oct. 3, 2013, p. 17) See, Murphy v.

and
They
Page 130 of 147
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 Baldwins 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
Page 131 of 147
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 motions 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 ceas e 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,
Page 132 of 147
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 Im just tired of things
-- Like I
noticed in this thing yall talk about some kind

of ex parte conversations. I dont think I have
had any ex parte conversations with Mr. Drake
about this anytime lately if I ever had any. I
dont think, since the beginning of this case I
have, partly because of all the stuff thats been
going
on
in
conversations. *
the
*
State
about
ex
parte
* And I dont believe I
have had any ex parte conversations, and I dont

see how yall 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
Page 133 of 147
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
Page 134 of 147
Sheriffs 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
Defendants lawyer [singular] when Michelle Murphy had two lawyers and
Page 135 of 147
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
Page 136 of 147
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 co unsel
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 childrens 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 doesnt read the orders that he signs, and, worse, has such little
Page 137 of 147
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
Page 138 of 147
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 McFaddens
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
Page 139 of 147
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 crossexamination. 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 Baldwins adjudication of the contempts incarcerates Michelle Murphy
for defending her family, and her lawyers for defending her. (V17, p.3624)
Page 140 of 147
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
Campbells 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
Page 141 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.

Page 142 of 147
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
Page 143 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.
7.1 PLEASE UNDERSTAND: This family can resolve this dispute if John Harold
Murphy and Judge Baldwin allow Michelle Murphy contact with the children as
Page 144 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.
Page 145 of 147
Attachment 96
Affidavit of Larry King
Affidavit of Larry King
Attachment 96
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 Defendants
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
Saturday
and
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 defendants
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 defendants
lawyer, if identified, had been provided due process notice.
11.4
The defective due process notification and statutory protections were
clearly identified in Michelle Murphys 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 Murphys 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, Im 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 counsels 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 Judges Ill 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,
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 Murphys 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
cant 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 & Youngs Motion on behalf of
Guardian ad Litem Elizabeth Lisa F. Harwells Request for Protective
Order and Motion to Quash Michelle Murphys 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 employees personal use, with a written
company policy against such conduct, after the employee had
worked a few days before the employees 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 judges ethical
conduct for converting to the judges 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 Nan Freeman
Transcript of Nan Freeman
Attachment 154
Page 1
1
IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA
2
NANCY MICHELLE MURPHY,
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)
)
Plaintiff,
)
)
v.
)
)
NAN FREEMAN and FREEMAN
)
REPORTING, INC.,
)
)
Defendants.
)
_____________________________)
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CIVIL ACTION FILE

NO. 2014CV241705
* * *
Videotape Deposition of
NAN DUBOSE FREEMAN,
(individually and as
30(b)(6) representative of
Freeman Reporting, Inc.)
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November 22, 2014

9:44 a.m.
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5180 Lone Oak Road

Hogansville, Georgia
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By Marcia Arberman, RPR, CCR B-1059

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***************************************************
VERITEXT LEGAL SOLUTIONS

1075 Peachtree Street, NE - Suite 3625
Atlanta, Ga 30309
Veritext National Court Reporting Company
Toll Free: 855.282.1018
404.817.9606
Page 2
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EXAMINATION
Page
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Cross-Examination by Mr. Farmer
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EXHIBITS
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Plaintiff's
Exhibit Description
Page
1
Notice of Deposition
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2
Payments from the State of Georgia to 13
Freeman Reporting, Inc. from 2010 to
2013
3
9-22-12 Freeman Reporting, Inc.
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invoice to Farmer
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6-19-14 e-mail to Farmer from Harris 38

(Judge Baldwin's secretary)
Certificate page of 5-27-14
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transcript
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6-10-14 Freedom of Information

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request letter
6-12-14 letter to King from Freeman 50
Transcript addendum
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invoice to Farmer
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invoice to Farmer
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8-12-14 letter to Farmer from
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Skandalakis
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MR. FARMER: I think maybe we'll let the

parties identify themselves.
I'm Millard Farmer, and I represent
Nancy Michelle Murphy. And with me is Paralegal
Kimellen Tunkle, and with me is Nancy Michelle
Murphy, who is the Plaintiff.
MR. GORDON: Ken Gordon, attorney to
Nan Freeman, and my client Nan Freeman.
MR. FARMER: And Freeman Reporting,
Inc., right?
MR. GORDON: Right.
MR. FARMER: And this is a deposition.
It's taken by agreement. And we got a Notice of
Deposition that we have some documents that
we'll probably be able to substitute for during
the deposition unless there's some dispute about
the documents. And I will ask that this be made
a part of the deposition, if you will.
You want to identify these as -- how
would we like to identify the -- how would we
like to identify the -MR. GORDON: The notice?
MR. FARMER: No, just Plaintiff's 1?
MR. GORDON: Yeah, that would be fine.
MR. FARMER: We'll just mark this for
Page 5
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APPEARANCES OF COUNSEL:
On behalf of the Plaintiff:
MILLARD C. FARMER, JR., ESQ.
151 Nassau Street
Atlanta, GA 30303
Phone: (404) 688-8116
millardfarmer@millardfarmer.com
On behalf of the Defendants:
KENNETH LAMAR GORDON, ESQ.
5180 Lone Oak Road
Hogansville, GA 30230
Phone: (706) 637-4558
kenbigstar@aol.com
Also Present:
Nancy Michelle Murphy
Kimellen Tunkle
Spencer Bush, Videographer
***
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Plaintiff's Exhibit 1.
THE REPORTER: Should I mark it now?
MR. FARMER: You may mark it now, if you
will.
(Whereupon, marked for identification,
Plaintiff's Exhibit No. 1.)
MR. FARMER: If you will, please swear
the witness.
NAN DUBOSE FREEMAN,
having been first duly sworn, was deposed and
testified as follows:
CROSS-EXAMINATION
BY MR. FARMER:
Q
Would you state your name, please?
A
Nan DuBose Freeman.
Q
And are you here in the capacity of also
representing Freeman Reporting, Inc.?
A
Yes, sir.
Q
And would you please tell us what is
Freeman Reporting, Inc.?
A
I'm a court reporter. And that's the
name I'm incorporated under.
Q
And are you the owner -- or what is the
owner status of Freeman Reporting, Inc.?
A
I'm the owner, I guess.
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Attachment
154, Page 2 of 53
404.817.9606
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Q
Okay. And you're here in the capacity
to represent Freeman Reporting, Inc. also?
A
Yes, sir.
Q
And would you tell us a little bit about
your experience and occupation?
A
Well, I'm a court reporter. I was
certified several years ago. And I have been working
first as a freelance and shortly after, an official.
Q
In -- in your ownership of Freeman
Reporting, Inc., did you have other reporters working
for you, or do you have employees of Freeman
Reporting, Inc.?
A
No, sir. I'm a sole reporter.
Sometimes I will help people find a reporter. Or I
will -- if I need to be away, I will just give the job
to somebody. I don't employ anybody. I have a
typist, but she's under contract. You know, she's a
contract worker.
Q
And what type of contract is she under?
A
I mean, we don't -- it's not a signed
contract. But she just -- you know, she's not an
employee. She's self-employed as well.
Q
You have an oral agreement with her?
A
Yes, sir.
Q
And does she do your -- all of your
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work?
A
I pay her by the page.
Q
But does she work for a company or
how -A
No. No, she doesn't. As far as I know,
I'm the only court reporter she types for.
Q
Okay. And how did you locate her?
A
I've just known her all my life.
Q
All right. And where did she live
before Oklahoma?
A
She's lived several places. Austin,
Texas; Tallahassee, Florida; in Georgia.
Q
And where in Georgia did she live?
A
Washington.
Q
And -- and for the -- what year were you
certified, the first year that you were certified as a
reporter?
A
I believe 1996.
Q
And do you -- are you employed as the
court reporter in the Coweta Judicial Circuit?
A
I am now, yes.
Q
And what period of time have you been
employed in that capacity?
A
I have a hard time remembering this. I
think it was in 1999.
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typing, primarily all of it, or would you explain?

A
It depends. It helps me to have her to
type when I'm busy in court and so forth. It just
depends. I send her some. I do some -- I do a lot of
it myself.
Q
And who -- who is she?
A
Patricia Britt.
Q
And where does she live?
A
Oklahoma.
Q
Say it again.
A
Oklahoma.
Q
And how does she get the material,
working out of Oklahoma?
A
I mail her the recording, and she
e-mails me the transcripts.
Q
And did she participate in preparation
of any of the transcripts in the case of Harold -Harold Murphy against Nancy Michelle Murphy?
A
Not that I recall. I don't believe she
did in any of those.
Q
So you think -A
I think I did them all.
Q
You did it all.
And what is your arrangement with the
person in Oklahoma? How does that -- how does that
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Q
And who employed you?
A
Well, I'm self-employed, actually. But
I've worked for two different judges.
Q
Okay. And what two judges have you
worked for?
A
Allen Keeble and Quillian Baldwin.
Q
And what period of time have you worked
for each of those judges?
A
All right. Best I can remember, I
started with Judge Keeble in 1999, and I think I
worked with him through 2011. And I've worked with
Judge Baldwin since the beginning of 2012, I believe.
(Whereupon, a cell phone rang.)
MR. FARMER: Just a second.
Okay. The cell phones -- the cell
phones are off. We had a cell phone
interruption there.
BY MR. FARMER:
Q
I got interrupted with the cell phone
and diverted. You were telling me that you worked
with Judge Keeble and -A
Yes.
Q
-- then what?
A
I think I worked from him -- for him
from 1999 till 2011 -- through 2011. In 2012 I began
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154, Page 3 of 53
404.817.9606
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to work for Judge Baldwin.

Q
And was it Judge Baldwin and
Judge Keeble that selected you? Is that the basis for
that employment? How does that work?
A
I don't really know. I think
Judge Keeble's former court reporter was moving away
and she suggested me. I don't really know the process
because I was only involved in being employed. I
don't know what went on behind the scenes.
Q
All right. Do you have any special
arrangement with them or just that you're going to
do the -- you're going to do their work, or how does
that work?
A
I'm not sure. I think -- I think that
they maybe -- I'm not sure about this. Maybe they
submit something to the State. I don't really know.
Q
And you -- as I understand, you receive
a stipend from the State of Georgia; is that right?
A
Define "stipend." For you -- I mean, I
know that -- I mean, I know what it means to me. What
do you mean?
Q
It means -- what I'm trying to say, it
means that you get money from the State of Georgia.
A
Yes, sir.
Q
And what money is that, and how does
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you say you, you mean Freeman Reporting? Is that what

you mean?
A
Well, that's -- that's who gets the
check.
Q
That's what I'm asking.
A
Yes, sir.
Q
Because it is a different entity from
you individually. You understand that?
A
I do, right.
Q
And then you understand in -- that you
got $4,160 in 2010.
A
That's what that says. I don't -- I
don't know.
Q
Okay. But is that -- is that consistent
with your memory?
A
I never totaled it that I remember.
Q
And when do you receive that?
Monthly?
A
Yes, sir.
Q
And is it a flat rate or is it part of
a -- or is it part of a -- is it part of -- according
to how much work you do or is it -A
Honestly, I don't know. It comes with
the job. And it's just a monthly amount.
Q
So it is a flat rate, not -- not -Page 13
Page 11
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that money -- how do you get the money from the State
of Georgia?
A
To my knowledge, the only thing I get
from the State of Georgia is because of -- we go to
five different counties. I get a small check because
I go to five counties. That's all I know.
Q
And does that amount to around three to
four thousand dollars a year in the last years?
A
That requires math. I'm not sure.
Q
Okay. But it's -- the State -- the
State -- I will show you this -- this State of Georgia
record just so you can look at it. It shows that
Freeman Reporting received $3,840 in 2013.
A
Okay.
Q
And it's DOAS-Court. I don't know what
that means. Do you -- how did you apply for or how
did you receive that money?
A
I don't know what that is.
MR. GORDON: Department of
Administrative Services.
A
Okay. I would say it's possibly the
amount that I get from the State for the five counties
I cover.
BY MR. FARMER:
Q
And do you make an application -- when
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A
Yes.
Q
-- according to how many jobs?
A
No, sir.
Q
I'm going to identify these two things
as Plaintiff's Exhibit -MS. TUNKLE: It's just one. It's only
one page.
(Previously marked for identification,
BY MR. FARMER:
Q
One page. It's two copies. It's
Plaintiff's Exhibit 2. If you will, just take a look
at Plaintiff's Exhibit 2 and see if that's consistent
with what -- the information you've been discussing
with us. And it's on the -- projected on the screen.
A
What's -- what's on the screen, that's
certain. I have no idea if that's the total I got a
year or not, but that's what that says.
Q
And is that separate from other money
that you receive?
A
Yes, sir.
Q
And do you receive -- do you receive
other money from the County that's on a flat-fee
basis?
A
I receive money from the Counties,
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yes.
Q
And is it based on a flat fee?
A
Some is.
Q
It is?
A
Some of it is.
Q
Say it again.
A
Some of it is.
Q
Well, is some of it not?
A
Yes.
Q
Okay. Explain to me that.
A
I get a per diem for the day that I'm in
court from the County that I serve in that day, and
then I get paid by the page for transcripts.
Q
Do you -- do you understand the basis
for the -- for that pay?
A
I don't -Q
Do you know how much you receive per
day?
A
Yes, sir.
Q
And is that -- who is that set by?
A
I don't know. The State, I guess. I
really don't know exactly who sets it.
Q
Do you know who sets the amount per page
that you're paid?
A
Same entity. I don't know if it's the
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you would have records to support that?

A
I believe so.
Q
And how do you itemize that to the
County?
A
I itemize the per diem for how many days
of -- usually I try to bill by the week. Sometimes -excuse me, sometimes -- anyway, I just bill by the day
for the County. And then when I submit transcripts, I
usually list the case and the case number and the
date, and then I -- the amount based on the pages.
Q
And do you get that in addition to what
you're compensated by the parties if the parties buy
the -A
Well, that would be a civil case. The
County has nothing to do with that.
Q
So you receive that amount only in
criminal cases?
A
I think I charge the same page rate, but
I don't bill the County for the civil -- civil
transcripts. I bill them for the day that I'm in
court but not for the transcript.
Q
All right. So let's -- so we understand
it, on the per diem rates, you bill the County for
both civil and criminal; am I correct?
A
Yes, sir. Yes, sir.
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Board of Court Reporting or the legislature. I'm not

sure.
Q
Do you keep up with that amount?
A
How do you mean?
Q
Do you -- are you familiar with what
you're entitled to receive?
A
Oh, yes, sir.
Q
And will you explain to us how that -how much -- how does that work? If you go to court,
you're there a part of a day or if you go to -A
I get paid a per diem for going that
day. If we stay longer than a certain number of
hours, I get more. I don't -- and I think it's more
than eight hours I get a certain amount; more than
nine, I get a little bit more. I don't remember those
two amounts.
Q
Do you bill the County? Or who do you
bill to get -A
I bill the County.
Q
And what kind of billing records do you
have for that?
A
I just have the invoices that I pay -that I send to them.
Q
Okay. So in these documents that we're
requesting in this notice to bring to the deposition,
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Q
And then, of course, for the criminal
cases, you bill the County on the page limit,
right?
A
Yes, sir.
Q
And is the page limit that you bill the
County for, is it the same as the page limit that you
bill individuals for?
A
Yes, sir.
Q
And do you bill the individuals for the
per diem rate?
A
No, sir.
Q
So the individuals do not pay the
per diem rate for the County?
A
That's correct.
Q
And do you submit that to the judge for
approval?
A
Yes, sir.
Q
And you submitted it in the case of John
Harold Murphy versus Michelle Murphy?
A
Now, I have for the per diem. I do not
submit my bill for a civil case transcript to him.
Q
All right. Do you submit the
per diem -A
Yes. I do that but not for the
transcript --
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Q
And -A
-- or for the takedown -- excuse me -or for the takedown in a civil case.
Q
So as I -- just so we're clear about it,
in a civil case, the County does pay for you coming?
A
Providing for the court reporter. The
County pays for me to be there.
Q
And the County is not reimbursed if the
parties in the civil case pays you for the takedown or
anything like -A
No, sir.
Q
The County is not reimbursed? That's
just a -A
No, sir.
Q
And if -- if the parties agree to pay
for the takedown -- one of the parties agree to the
takedown and then they order the transcript -A
Uh-huh (affirmative).
Q
-- do you charge for the takedown plus
the transcript, or do you just charge for the
transcript?
A
For the takedown and the transcript.
Q
Two separate things?
A
Yes, sir.
Q
And how do you account for the time that
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A
Yes, sir.
Q
You do all of the record and all of the
billing yourself?
A
Yes, sir.
Q
And do you -- so in the Murphy case, as
I understand, you -- you did all of the -A
To the best of my recollection, yes.
Q
To the best of your recollection?
A
Yes, sir.
Q
You did both the record keeping and you
did the actual typing of the transcripts?
A
I do believe I did. I'm not -- I can't
say 100 percent, but I'm pretty sure I did.
Q
And in the takedown part of it, it's for
the time that you actually were involved in taking
down the -A
To the best of my knowledge.
Q
And if two parties are a party to the
case, is that divided -A
Yes, sir.
Q
-- between the two parties?
A
I'm sorry. Yes, sir, it is.
Q
And explain that for the transcript and
for the takedown. Explain to me how that works.
A
Okay.
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you spend for the takedown?

A
I usually keep a record of it.
Q
Do you -- do you include that record in
your billing?
A
Do you mean do I put down how many
minutes it was or -Q
Right.
A
No, I don't.
Q
And how does a person know how much time
is -A
I usually keep a record of it, and I
bill it. If they question me, I can go back and look.
Q
Okay. So you would have that record
that you could -A
I would assume so. I can't swear that I
would have it on every one, but I would -- I would
imagine I could or I could at least do the math to
figure it out.
Q
So do you have it in the -- in the
transcripts that we're dealing with, John Harold
Murphy versus Michelle Murphy?
A
I can't answer. I don't know.
Q
Would you have originally kept it?
A
I believe so.
Q
And are you the record keeper?
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Q
Let's say two parties in the case -A
All right.
Q
-- and both -- and they split the -split the amount.
A
Okay. In this case, as I recall, I
divided the takedown in half and charged each party
for one-half the takedown. And in this case because
you both -- both sides ordered the transcript pretty
much on the same day, I remember the first day
discussing it, and I don't remember if I discussed it
any more than that. But I do remember I divided -- I
took everything and divided it by 2.
In some cases the party that orders it
first you would charge the copy -- I mean the original
and two copies. Later the other party orders it, and
I would charge them a copy rate.
In this case, as I recall, you pretty
much both ordered it at the same time, and I divided
it in half so that each party paid the same amount.
Q
And if -- if in a -- if in a case
involving someone else, say, not the Murphy case -A
Q
-- one party orders it and a week later
or two weeks later the other party orders it, do
you -- do you give the party the credit -- that
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ordered it first credit for the -- when the other

party pays for it?
A
I don't understand what you're asking.
Q
All right. It's not a very clear
question.
As I understand, if the person orders it
afterwards, you're only charging for the copy?
A
As a rule, yes, I would say pretty much
that's the case.
Q
Okay. And is there any provision for
that in the Rules, or how do you -A
Not that I know of. But I don't think
that's an uncommon practice.
Q
By uncommon practice, how do you -A
Among court reporters. I do believe
other court reporters bill that way, where they divide
it totally in half.
Q
All right. I understand, the "totally
in half" part.
A
Yes, okay.
Q
I'm talking about where one party orders
it earlier.
A
Oh, yes, sir. And sometimes it's months
later when the other party orders the copy.
Q
And so then if you order it later --
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Plaintiff's Exhibit -MR. FARMER: 4 are we up to?

MS. TUNKLE: 3, I think.
BY MR. FARMER:
Q
3, 3. I'm going to -- I'm not going to
mark this as an exhibit, but I'm going to show you the
transcript of the proceedings.
A
Yes, sir.
Q
And I'm going to show you that. If you
prefer, here's a -- (hands document to the witness.)
A
This is fine.
MR. GORDON: Yeah, we're okay.
MR. FARMER: I'm trying to hand it to
her.
MR. GORDON: Oh, you're trying to hand
it to her?
MR. FARMER: Yes.
BY MR. FARMER:
Q
And I'm going to ask, if you will, if
you will explain -A
Okay. Evidently in this one you ordered
first. In the other -- it appears in this one -- I
must have been mistaken. It appears in this one you
must have ordered it first and I mailed you an
original and one. I made a mistake, I guess, in that.
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A
Yes.
Q
-- you only pay -- you only pay for one
copy?
A
That's my understanding. I mean, that's
how I charge. That's my understanding of the way it's
supposed to be.
Q
And where do you obtain that
understanding?
A
Well, I just know that the copy rate -the original and two copies is one charge and the copy
rate is another. And if the other party has already
ordered it and I've submitted it to them, the other
party is entitled to a copy if they participated in
takedown.
Q
So the person that orders it first is
charged at a higher rate?
A
As a rule. But in this case I divided
it in half because -Q
This case meaning Murphy v. Murphy?
A
-- yes, sir -- because pretty much it
was ordered at the same time.
(Previously marked for identification,
BY MR. FARMER:
Q
I'm going to show you what I marked as
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That was from my memory.

Q
So that billing is incorrect? Is that
what you're telling me?
A
No, sir. I'm saying I was incorrect
when I said that I thought that I had to have every -Q
All right. Do you have records to
support the ordering of that transcript?
A
I'm not sure. I would have to look
back. I don't know. I usually take an oral order.
And I may or may not have made a note. I don't know.
You could have mailed me -- sent me an e-mail. I
don't remember.
Q
Was there a division of the takedown in
that -- on that occasion?
A
Yes, sir.
Q
And you're telling me that they did
not -- that they did not order?
A
I'm saying from looking at this, it
appears that they would have ordered it later. I
don't know.
Q
Do you have records to support that?
A
I'd have to look and see.
Q
Can you provide those records for us?
A
I'll see if I can. I don't know that I
do. I'll see.
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I would say based on that, that that is

what I did and that is what occurred.
Q
And do you have any -- do you have any
rule to rely upon that allows you to do that?
A
Not that I'm -- not that I can think of
right now.
Q
Are you familiar with the -- are you
familiar with the basis for charging fees that the
State has?
A
I don't know that I know what you
mean.
Q
Okay. The State controls the Board of
Court Reporting -A
Yes.
Q
-- through the Council -- the Superior
Court judges? They control the fees; is that right?
A
As far as I know.
Q
And are you familiar with those rules?
A
I guess I am. I've told you what I
understand.
Q
Okay. Have you examined the fees that
you charged in the Murphy case to Michelle Murphy to
see if you were in compliance with the Board of Court
Reporters' rules?
A
When I made my bill, it was my
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A
Yes, sir.
Q
-- that you overcharged -A
Q
-- have you looked to see if you
overcharged?
A
Yes, I did.
Q
Yes, you did look or, yes, you did
overcharge?
A
Yes, I did look.
Q
Okay.
A
And it's my understanding that I made a
mistake and that instead of having space for
63 characters, I had space for 61. So it was two
characters per line.
Q
And did that make a difference in the
billing?
A
I think it probably would. It probably
would. But it would just depend on the transcript as
to what difference it would make because of
different -- different -Q
Did you calculate to see what difference
that it would make?
A
It could be figured. Yes, sir.
Q
Did you figure it?
A
I have looked at it. Yes, sir.
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understanding that I was -1

Q
Okay. But since that time -2
A
-- in compliance.
3
Q
-- we've said that you did not -- that
4
you had not charged correctly. And I'm asking you, 5
have you examined to see if you did charge
6
correctly?
7
A
Based on the pages, I charged
8
correctly.
9
Q
Based on the fee that you collected, did 10
you charge correctly?
11
A
Based on the fee that I charged by the
12
page, I believe that I charged correctly.
13
Q
Well, did you charge incorrectly by any 14
other basis?
15
A
Could you be more specific?
16
Q
Yes. The law, it's not just a page
17
requirement. You understand that?
18
A
Yes, sir.
19
Q
It's other requirements -20
A
Yes, sir.
21
Q
-- for the charges.
22
A
23
Q
Have you looked at -- since you know
24
that we said you didn't charge -25
Q
Okay. And what did you determine?
A
I can't tell you per transcript. But I
recalculated, and it appeared to me it was less than
$45.
Q
But you did -A
-- for all of them.
Q
But you say you -- that's what you
calculated? You overcharged by $45?
A
If I reconfigured the page, it appeared
that that's what it would be.
Q
And when did you reconfigure -- when did
you make those calculations?
A
Within the last two or three months. I
don't know. I don't know the date.
Q
Was that after the complaint was
filed?
A
Yes, sir.
Q
And did you calculate the reason for
that overcharge?
A
As I said, instead of having space for
63 characters on a line, I had space for 61.
Q
And how did you -- how do you make those
determinations of what you had?
A
I counted per space on a line.
Q
And when you -- before you billed it,
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how did you make the calculation?

A
I just used the template that I had set
up. And evidently at some point it was set up
incorrectly.
Q
Okay. What kind of template do you
have?
A
It's just something I've had set up a
long time. I had -- when I bought my first computer,
I had help. I had to learn Word. I used Microsoft
Word.
Q
Okay. Which version? 210?
A
I've used different ones but -Q
Okay. When you first set it up.
A
This would be a much earlier version. I
don't know what version it was.
Q
Okay.
A
And I've continued to use that. I
just -- I found out from the person I bought my
computer from -- somebody in their office. The person
I bought it from didn't know anything about Word, but
there was somebody in the office that showed me the
legal template. And I just used it and kind of had to
figure it out myself.
I was new in LaGrange. I didn't know
anybody. I was new in LaGrange. I didn't know
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Q
Okay. From the time you had the
computer?
A
I just used -- as far as I remember, I
haven't changed the template -- I used the -- I used
the same version as far as I remember.
Q
For approximately how many years?
A
The whole time I've been a court
reporter probably.
Q
And since we don't know that, tell us.
A
Well, I said 1996.
Q
Okay. Since 1996?
A
As far as I know, yes.
Q
And you've used the same version of
Word?
A
No, sir. I've just used the same
template.
Q
The same template?
A
Yes, sir.
Q
And what font do you use?
A
12. 12 Courier. Whatever that -whatever the Courier is and 12, size 12, whatever that
is.
Q
Okay. And what version of Word did you
use in preparing the Murphy transcripts?
A
I'm not sure. Maybe 2010. I'm not
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anybody to ask. I didn't really know anybody. I just

set it up by myself. I remember counting spaces. I
remember working to get the thing set up.
And at some point I guess inadvertently
it changed from 63 to 61. I don't know. I don't
really know when -- when -- I don't know when it
became 61 characters. I don't know if it was from the
beginning or when. I don't know.
Q
And who did you buy the computer from?
A
I don't remember. It's the company
that's been out of business. I can tell you where
they were located many years ago, but -Q
All right.
A
-- they've been out of business for a
long time.
Q
Where were they located?
A
LaGrange.
Q
And where in LaGrange?
A
Off of Whitesville Road on Lukken
Industrial Boulevard.
Q
And when you set it up, did you continue
using the same program all the way through when you
did the Murphy case?
A
Well, I -- oh, with the Murphy case,
yes, sir, as far as I remember.
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sure.
Q
And what version do you use now?
A
Same.
Q
And do you use the same template now?
A
Yes, sir. Well, I've changed it now,
but I -Q
How did you change the template?
A
I changed the left margin by two spaces,
or to allow for two more spaces.
Q
And is that -- did you use the same
template in preparing the criminal transcripts for the
State?
A
Pretty much, yes, sir.
Q
During all that time?
A
Yes, sir.
Q
So you would have overcharged them the
same as you did -A
I don't know. I don't know -- I don't
know. I haven't gone back to count spaces on every
transcript. I don't know.
Q
You see the requests that we have made.
Do you have those transcripts?
A
I should.
Q
All of the transcripts for the State?
A
As far as I know, yes. Well, not for
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the State but for the Counties, yes.

Q
For the Counties?
A
Yes, sir.
Q
And so all of those would be
available?
A
As far as I know, yes.
Q
And who approves of the payment to the
County?
A
I submit my bill to the judge. And he
signs it, but he does -Q
The judge meaning? By name who?
A
Well at first, it was Allen Keeble.
Q
All right.
A
Now it is Quillian Baldwin. And
sometimes it might be a senior judge if I reported for
him.
Q
But you submit it to Judge Baldwin?
A
Yes, sir.
Q
And does -- how do you submit the -the -- how do you submit the billings to
Judge Baldwin?
A
I just give it to him, and he signs it.
And then I submit it to the County.
Q
Are you with him when he signs them?
A
I can't say I've been with him every
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Q
When we first brought this to
Judge Baldwin's attention or he first -- I don't know
whether we brought it to his attention or he heard it
from somebody that you would probably be subject to
litigation about this -A
Yes, sir.
Q
Do you remember that?
A
Of course.
Q
And did you bring it to his attention?
A
Yes, sir.
Q
And what did he say at that time?
A
Goodness, I don't remember.
Q
Well, about what -- what was the -what was the gist of the conversation?
A
I can't tell you. I don't remember.
Q
How did you bring it to his attention?
A
I went to his office as far as I know.
No. I believe we talked on the phone.
Q
You called him on the phone?
A
I did not. But he called me.
Q
Okay. What did he -A
That's the best of my memory.
Q
Okay.
A
I don't really remember exactly.
Q
Okay. Anyway, y'all communicated?
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1
time.
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Q
No. I mean -3
A
I might have left them with the
4
secretary. But usually he signs it in my presence.
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Q
Okay. And what does he do as far as
6
checking it?
7
A
Well, he doesn't go through the
8
transcripts and count the pages.
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Q
Has he ever looked at -- has he ever
10
looked at the transcripts?
A
Not to my knowledge except what he sees 11
12
in court.
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Q
Okay. But what I'm saying is, he's
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never seen that you comply with the law?
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A
Not to my knowledge.
Q
And has anybody ever brought it to your 16
attention that you don't comply with the law other 17
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than in the case we brought against you?
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A
Never.
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Q
Have you ever been audited by the
21
County?
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A
No, sir.
Q
They have never made any audit to the 23
24
County?
25
A
A
Yes, sir.
Q
And what was that communication?
A
I really don't remember, Mr. Farmer.
Q
Okay. Well, it had to be something.
A
I just told him -- I honestly do not
remember what he said.
Q
Okay. But how did the conversation
begin?
A
I honestly do not remember. I remember
I told him.
Q
And did you tell him you couldn't afford
the litigation?
A
I don't think I needed to tell him, but
I don't remember.
Q
Did -- did he tell you he would do
anything about it?
A
I don't remember that he told me he
would do anything about it.
Q
Was there any kind of understanding that
he was going to do something about it?
A
I really don't think so.
Q
Did you request that he did anything -do anything about it, or did he do it on his own?
A
I can't -- I don't believe I would have
asked him to do anything about it.
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MR. FARMER: I'm going to ask you to

mark this as Plaintiff's Exhibit 4.
BY MR. FARMER:
Q
I ask you to take a look at Plaintiff's
Exhibit 4 and see if you can -- if you can read that
and tell me if you've seen that document before.
A
I have seen this before.
Q
All right. And when was the first time
that you had seen it or learned anything about it?
A
I guess when I was copied on it.
Q
Okay. And did Judge Baldwin copy you on
it?
A
His secretary did.
Q
And we're talking about Plaintiff's
Exhibit 4? He sent you a copy of that?
A
Yes, sir.
Q
It's on the screen. And are the
statements in there correct? (Reading) Nan Freeman
discussed with me your latest e-mail -- our latest
e-mails back and forth; is that correct?
A
Yes, that's correct.
Q
And -A
And I was deeply concerned.
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A
I remember -- do you mean after the
e-mail or after he filed those?
Q
We're going to go through all of it, so
you can begin after the e-mail and then after
everything else.
A
Well, I'm sure we did. I don't remember
a specific conversation. I don't remember a specific
conversation.
Q
But I'm not asking about specific
conversations. Did you discuss it with him?
A
Well, I just expect we did, but I
can't -- I do not have a firm recollection of a
particular -- any particular conversation.
Q
And the part in here about "Ms. Freeman,
she will not voluntarily give you directly or file
with the Clerk's office copies of the audio
recording" -A
That's what he said.
Q
Well, is that true?
A
At that time it was true.
Q
Was it true after the hearing on that
day? Did I approach you and ask you to let me
purchase those audio recordings on the -- after the
27th hearing?
A
The 27th of?
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Q
Say it again.
A
And I was deeply concerned.
Q
Okay. In the second paragraph -- is
that -- is that statement in the second paragraph
correct?
A
It is. But I -- before this I think I
suggested to you that I -- that's how I would like to
do it, to put a sealed copy in the Clerk's file.
Q
But not give it to me for my use as I
chose?
A
That's correct because I didn't think it
should be disseminated in any manner, taken out of -anything taken out of context.
Q
The third paragraph.
A
I believe that's what he decided to
do.
Q
Is that true and correct?
A
As far as I know.
Q
And the last paragraph or
next-to-the-last paragraph.
A
Well, that's what he said.
Q
And did you have a conversation with him
after this?
A
I've talked to him a lot after this.
Q
About this incident.
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Q
May.
A
Yes, you did.
Q
And did you respond to me when I -A
I said no. And you asked why. And I
said, because I don't believe I'm required to.
Q
And did I ask you politely to let me
purchase them?
A
You asked me. I won't say it was
impolite.
Q
Did I say "please, Nan"?
A
I don't remember.
Q
Would you like -- would you like to hear
the audio on that?
A
I've heard it before. But I don't
remember if you said the word "please."
Q
Okay. You wouldn't dispute it if you
heard the audio of that request?
A
If I heard the audio, no, sir, I would
not.
MS. TUNKLE: Do you want to play it?
You said "Nan, please."
THE WITNESS: I don't dispute that he
said "please."
BY MR. FARMER:
Q
All right.
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A
I just don't remember that you -- I do
not remember that you said "please."
Q
Okay, good enough. But you're not
disputing it?
A
I'm not disputing it. I don't know
whether you did or not.
Q
Okay, okay. And you would not let me
have it?
A
I would not. I did not release it that
day. No, sir.
Q
And -- and you weren't going to release
it until something was done to make you release it; is
that right?
A
That is probably not true.
Q
What were you -- what were you -- when
were you going to release it to me without me doing
anything to require you to do it?
A
When you said you were going to sue me,
I decided it was not worth it. And so I decided at
that point that I would like to give it to you to
avoid a lawsuit.
Q
Okay. So until I said that I was going
to sue you, you were not going to do it.
A
Well, it's my understanding that I
wasn't required to.
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that was giving him advice about it?

A
I can't answer that. I don't know.
Q
Well, did he indicate to you that he
would?
A
Discuss it with someone?
Q
Yeah.
A
Not that I recall.
Q
Was the information that I wanted to
get, was it something that was different from what was
in the transcript?
A
I don't know what you wanted to get.
Q
Okay. Did the audio depict something
differently than what I could have obtained by reading
the transcript?
A
It's my opinion that it did not.
Q
So it's your opinion that when you first
released the transcript, you gave everything to us?
A
I don't know what you mean by that.
Q
All right.
A
I did not give you the recording.
Q
Okay. Did you give us all of the
information that took place up until -- before -- that
there was a request for a Freedom of Information
request obtained in the transcript from -A
I don't understand the question at
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Q
Okay. But you weren't going to do it
unless I sued you or unless I threatened -A
I won't -Q
-- to sue you?
A
-- say that. But I did not want to be
sued, and so I didn't think it was worth it.
Q
Okay.
A
So I was willing to release it. Because
it was my work product and it was mine, if I wanted
to, I could.
Q
Okay. Did you discuss with anybody that
gave you the opinion that you're not required to
release it?
A
Did I discuss with anybody -Q
Yes.
A
-- that I was not required -- well, I
did talk to Judge Baldwin about it but -Q
What did Judge Baldwin say?
A
He said different things at different
times.
Q
Okay. What did he say about that?
A
First he said he didn't care if I did or
not. Another time he said he wasn't going to let me.
And another time he said that he would do it.
Q
Was he discussing it with someone else
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all.
Q
Okay. Did you leave out part of the
testimony? Did you leave out "blame yourself, blame
yourself, blame yourself"? Did you leave that out?
A
I don't remember.
Q
Okay.
A
I don't know what -- I don't know.
Q
Okay. If you will, I'm going to show
you this transcript of the hearing, and I'm going to
ask -- see if you certified that to be correct.
A
Yes, I did.
Q
Is the "blame yourself, blame yourself"
in there?
A
I'll have to read it.
Q
Read it. Look toward the end.
A
Pardon me?
Q
Look toward the end and -A
Well, how will I know -Q
Okay. Wherever you would like. I was
just -A
Would it be what the judge said?
Q
Yes.
MR. GORDON: I'm going to step out one
minute -MR. FARMER: Yes.
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MR. GORDON: -- while she reviews that.

MR. FARMER: Do you want to take a
break?
MR. GORDON: No. I'm good.
MR. FARMER: Okay.
MR. GORDON: I want to speak to my
secretary a minute.
MR. FARMER: Okay, good. We won't do
anything too damning till you get back.
MR. GORDON: Can you make some
representations to her as to the fact that what
you're looking for is not in this transcript to
kind of speed this up a little bit?
MR. FARMER: It absolutely is not.
MR. GORDON: Okay.
MR. FARMER: She absolutely left out
stuff. Let's put it that way -MR. GORDON. Okay. She's looking for
that conversation that you mentioned a moment
ago -MR. FARMER: Right.
MR. GORDON: -- between you and the
judge?
MR. FARMER: Between the judge and the
lawyers and Michelle Murphy.
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A
I'm a voice writer.
Q
Okay. Meaning that you speak into a
microphone and have an audio recording of it?
A
Yes, sir.
Q
And you did type this yourself?
A
As far as I remember.
Q
So you were there when it took place?
(Audio recording played.)
BY MR. FARMER:
Q
You did hear "please"?
A
Of course. And I didn't deny you said
that. I just didn't -Q
Okay. I just wanted to make sure you -A
-- remember the -- I did not remember
verbatim.
Q
Okay. You do -- do you now remember
that taking place, "blame yourself," in the courtroom?
A
I think I do. But I must have already
been -- the judge must have already said we were off
the record or that the case was over.
Q
Did you hear that?
A
I did hear that.
Q
Do you see any place that says he's off
the record?
A
Not in this trans -- oh, not -- well, I
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MR. GORDON: Okay. And did you go back

and -- after you got the recordings have those
parts that -- the missing transcript
transcribed?
MR. FARMER: We'll -- let me get -- I'll
get to it.
MR. GORDON: Okay. I was just trying to
help move forward.
MR. FARMER: Yeah, I know. I know it.
But I just want to make sure she's clear about
this admission.
A
I don't see "blame yourself, blame
yourself, blame yourself."
BY MR. FARMER:
Q
Was that a rather dramatic point in the
transcript?
A
I don't see it in here.
Q
Can I -- let me let you listen to it -A
Okay.
Q
-- and see if you can -- just a second.
And you did take down this part of
the -- you used -- what type of recording method were
you using?
A
I'm a voice writer.
Q
Say it again.
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have this where he says, I'm sorry, that's the end of

this hearing today.
Q
Did you record this?
A
It's on -- it's on my digital recording.
My digital recording, I mean, it also -- it also
records what you said to me afterwards, and that
wasn't part of the proceedings.
Q
But you did -- you did see that? You
did have this in your digital recording?
A
Yes, sir.
Q
And you didn't transcribe it?
A
Not to my knowledge. Is this the one
where I did an amended transcript?
Q
You certified it was a complete record.
A
I did. And I admitted the mistake, and
I corrected it by an amended transcript.
BY MR. FARMER:
Q
I'm going to show you Plaintiff's
Exhibit 5, and I'm going to ask you if that is your
certification it's complete?
A
Yes. It's the certificate that's on the
back of this, but I also -Q
"Back of this" meaning?
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A
"Back of this" meaning this transcript
of May 27th, 2014. But I also submitted an amended
transcript. And I admitted that I made an error, and
I submitted an amended transcript or an addendum.
Q
Now -A
I believe I called it an addendum.
Q
Did you do that -- I'm going to show you
this. Did you do that before there was a Freedom of
Information request by Larry King for this document?
A
No, sir. I don't believe I did. I
believe that I -- I believe I was not aware until I
received that from Mr. King.
BY MR. FARMER:
Q
I'm going to show you what's been marked
for purposes of identification 6 and ask you if that
is the Freedom of Information request that was
necessary to be made to get this part of the
transcript.
A
As far as I recollect, yes.
Q
And I'm going to show you Plaintiff's
Exhibit 7 -(Whereupon, marked for identification,
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A
It would be on the hard copy that I
mailed to you and it would be on the hard copy that I
mailed to Mr. Drake and it would be on the hard copy
that was submitted to the Clerk.
Q
All right. Can you -- can you show me
where -- will that -- will you produce that hard copy
to me? Do you have a copy of it?
A
I should have. Not with me. I don't
have it with me.
Q
Okay. Is it filed with the Court?
A
It's my understanding it is. I mailed
it to be.
Q
And was there a certificate on it?
A
I would expect so.
Q
And can you provide that certificate?
A
Not today.
Q
Okay. But you will provide it?
A
I would think so, yes. As far as I
know, I can provide it.
Q
Now, this is the case in which there
were a number of motions to disqualify the judge.
You're familiar with that?
A
I don't -- I don't know too much about
what goes on outside the courtroom.
Q
Well, in the courtroom you know there
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BY MR. FARMER:
Q
-- and ask if you can identify that
document to us. It is the letter that you wrote to
Larry King.
A
That appears to be the letter I sent to
him.
Q
Do you have any question about that
being -A
It looks to be the same.
Q
And I'm going to show you a document
that we would identify as Plaintiff's Exhibit 8 and
see if you can identify this as a document that you
sent.
A
It appears to be.
BY MR. FARMER:
Q
Did you certify that document?
A
I believe I did.
Q
Would you show me the certification?
A
It appears to me that this is the one
that I sent by e-mail. And I wouldn't necessarily put
a certificate on an e-mail, a transcript I send out by
e-mail.
Q
Okay. Well, where is the certificate?
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were -- there were -- there was a lot of efforts to

disqualify Judge Baldwin? You know that, don't you?
A
I know that you did try to disqualify
him. I do not know how many motions you filed. I
don't -- I don't -- I haven't looked through that
trial.
Q
I understand. But you know there was a
big issue about disqualifying him, right?
A
Well, I've heard you say that, yes.
Q
Okay. And you believe it, don't you?
A
I have no reason to disbelieve it, but I
don't know.
Q
Okay. But you know that was a big -that was an issue in the case?
A
I know that was an issue in the case.
Q
And you know that this was a crucial
point in the case, in which custody of the children
was transferred that you omitted from the record,
right?
A
I don't understand.
Q
Okay. The "blame yourself," you know
that's when the children were being taken away by the
deputy sheriffs.
A
Okay.
Q
You remember that?
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A
I remember that, yes.
Q
You remember the deputy sheriffs were
there in the courtroom taking the children away,
snatching them away from Ms. Murphy?
A
I didn't witness that. That was not in
the courtroom.
Q
You were not in the courtroom when this
took place?
A
I was in the courtroom, but I never saw
the children that I remember.
Q
Okay. Did you see -A
I think that was all outside the
courtroom as far as I know.
Q
Okay. But did you see the deputies
being ordered to take them?
A
Yes.
Q
You heard that, Judge Baldwin ordering
the deputies to take the children?
A
I believe I did. I don't believe it's
in the transcript.
Q
So you know that that segment of what
took place in the courtroom, you know that that
segment is relevant to his demeanor and to his ability
to treat both sides fairly?
A
I can see where you -- where that would
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Q
Okay. Had you -- does Judge Baldwin
holler like that frequently at people?
A
I can't say that. I don't -- not -not -Q
Well, you're there. You're his
reporter. Does he?
A
I don't think so. I don't know. I
mean, I've -- I've -- I've heard him raise his voice
more than once, but I can't say -Q
I know you heard him raise his voice one
other time to me when you went to get the -- to get
him to prevent from us taking down the call of the
calendar, didn't you? You heard it that day, didn't
you?
A
I don't remember his raising his voice
about that.
Q
Okay. Let -- just a second. Let me see
if I can play that for you.
You remember when we had a hearing and I
said -- I came to you before the hearing and I said I
would like for you to take down the call of the
calendar? You remember that day, don't you?
A
I remember you doing that twice.
Q
Okay. And -(Audio recording played.)
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be your understanding. If the judge had told me that

the case was over, I would have probably stopped.
Q
But you knew after that that the
hollering was -- it wasn't over when he was still
hollering at the people, didn't you?
A
I don't remember. I really don't
remember.
Q
Well, you knew it would be relevant to
us to have him hollering like that at us and hollering
like that at our client Ms. Murphy?
A
I can see where you would say that,
yes.
Q
That's all I'm saying.
A
I can see where you would -Q
You could see -A
I can see where you would say that.
Q
And in representing her, you could see
where it would be fair for me to say that in
representing her, can't you?
A
Where you would -- where you would -Q
Where it was the lawyer's duty to do
that in representing her, you would say that, wouldn't
you?
A
I'm not an attorney. I can't answer
that.
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BY MR. FARMER:
Q
So you -- he was hollering at me on that
day, right?
A
He had raised his voice, yes.
Q
Would you say he was substantially
raising his voice?
A
That's a matter of opinion, I guess.
Q
Okay. In the matter of your opinion,
how would you say?
A
It was louder than his normal voice.
Q
Was -- do you remember the courtroom
being full of other lawyers and other people waiting
to have their case heard?
A
It was a calendar -- it was a calendar
call, so yes. I mean, all the cases that were on the
calendar and the people that were present that day
were in the courtroom, yes.
Q
It wasn't necessary for him to holler
that loud for me to hear him, was it?
A
I don't know. I would say you didn't
respond the first time or the second time.
Q
So you say that he was justified in
hollering? Is that what you're trying to say?
A
No. I'm not -- I'm just saying
that maybe he wanted -- I don't know what Judge --
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what was in Judge Baldwin's mind. I don't know.

Q
But you know he wasn't acting in a
normal manner in hollering like that at me at a bench
conference? We were at a bench conference, right?
A
Yes, sir.
Q
We were standing a few feet away from
him, right?
A
Yes, sir.
Q
And I wasn't jumping up and down and
flapping my arms at him or anything like that, was
I?
A
Not that I remember.
Q
All right. I wouldn't do that. You
don't see me do things like that, do you?
A
I've never seen you flap your arms,
no.
Q
Okay. Well, so -- and you heard him
threaten to put me in jail, didn't you?
A
I heard that at the bench -- I mean, I
heard it on that recording, but it was at a bench
conference.
Q
Right. And -- and all of that started
with me asking you before the hearing started, would
you please take down the calendar call?
A
I don't know that that's what --
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A
Well, I did tell the judge that you
asked -Q
All right. That's what -A
-- for the calendar call.
Q
-- I'm getting at.
A
I told him the first time, and I told
him the second time.
Q
Okay. What did he say the second
time?
A
I really do not remember.
Q
Okay. Well, what did he say the first
time?
A
I don't remember.
Q
Okay. Well, why was it a big -- why was
it a big thing about it taken down the second time?
A
I have no idea.
Q
Why -- why didn't you want to take it
down?
A
I don't know what you mean by that. If
the judge -- I mean, if the judge -- I would not have
not taken it down.
Q
Okay. Well, why didn't you take it down
then?
A
Because the judge told you in the
courtroom that we weren't going to take it down.
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Q
You remember before the hearing started
I came to you and said -A
Yes. I -Q
-- Nan, would you please take down?
A
Yes.
Q
And you had done that on a previous
occasion for me?
A
Yes, sir.
Q
You had taken down the call of the
calendar?
A
Yes, sir.
Q
And -- and so what happened after I
asked you to please take down the call of the calendar
and I would pay you?
A
The first time, I took it down.
Q
No, the second time.
A
Second time.
Q
This "do you understand" hollering time.
A
You asked me. And the judge said he
wasn't going to have the calendar call taken down.
Q
Okay. Well, where did you go after -where did you go after I asked you to take it down?
A
I'm sure I went in the back.
Q
Okay. Who did you go in the back and
see?
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Q
Okay. But he told me that after you
went and had a conference with him, right?
A
It was after I went and had -- after I
told him that, yes.
Q
Okay, yes. Well, why did -- why did he
not want to take it down?
A
I don't -- I can't answer for him.
Q
Do you understand there's an issue in
this case about judge shopping and about judge
selecting of cases? Do you understand that, that
there was -- that what happens is that the judge
selects who he chooses to give a particular case to
and that the lawyers select who they want -- what
judge they want to hear the case? Do you understand
that to be an issue?
A
I'm not privy to any of that, but I
understand that that's what you say.
Q
Okay. That's all I'm asking. You
understand that that was the issue that I was
raising?
A
I understand that's what you say, yes.
Q
And you understand that taking down the
calendar call is something that would document that
supporting information that I was trying to obtain?
Do you understand that?
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A
I understand that's what you're saying.
I don't know if -Q
Okay.
A
I don't know if it could be used for
that or not.
Q
I understand. I'm not asking you to do
the -- I'm not asking you to do -- let me play you a
little bit of the first part when he comes out so you
will understand a little bit.
BY MR. FARMER:
Q
So what I understand is, this was
Judge Baldwin not wanting the record taken down, not
you not wanting to take it down.
A
I don't know a court reporter that would
delight in taking down a calendar call. That's a hard
thing to do.
Q
Okay. I'm not -A
But if I had been -- if -- if the judge
had wanted it taken down or he had not said we're not
going to take it down, I would have taken it down -Q
Okay.
A
-- at your request.
Q
Okay. So did you attempt to keep it
from being taken down?
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judge.
Q
They all stay in there? They don't -they all stay in the same room and are heard by him;
is that right?
A
Honestly, I don't pay that much
attention to the calendar call.
Q
But you understand that the cases are
assigned for a hearing at the calendar call? If
they're in there for a hearing, they're assigned for
who's going to hear them, right? They have more than
one judge there when they have a call of the calendar,
right?
A
Not every time, no, sir.
Q
Okay. But sometimes they do, right?
A
They have been. But since I believe
2013 cases are assigned.
Q
Yeah, since we brought the issue.
A
I don't know -Q
Okay. I understand.
A
-- about that. I don't know about
that.
Q
I understand. After we -- after we
brought the issue and had to appeal it, I understand
they changed the calendar -- the -A
I don't know anything about that. That
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A
Q
Okay. So it was Judge Baldwin's
decision that he wasn't going to let you take down the
-- not going to have a record of the call of the
calendar?
A
I would not tell the judge what to do.
Q
I understand. So I just want to make
sure. It was his decision and not your decision?
A
Of course. I would not tell the judge
what to do.
Q
And you had been around a lot of
calendar calls for Judge Baldwin, and you've been in
the Superior Court of Coweta County and other courts
in the Coweta Judicial Circuit a long number of times,
right?
A
Yes, sir, but not as many with
Judge Baldwin.
Q
But a substantial number?
A
Probably so by that time.
Q
And you know that when they call the
calendar, Judge Baldwin says who the case -- who -which one they're going -- you go let Judge so-and-so
hear this case; is that right?
A
No, sir, not to my knowledge. I don't
remember him saying, you go to this judge or that
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has happened all outside my presence and outside my

knowledge.
Q
Okay. I'm not asking you about that.
But before that time they did assign them to different
judges at the calendar call?
A
I don't know that. I don't know how
they -Q
You didn't ever see it done?
A
I don't know if I did or not. I was not
paying attention. I didn't think that was relevant to
me. I just -- I took down the cases that came before
the judge I was working for that day.
Q
And you've never seen them assign the
case to a judge other than the one that's calling the
calendar?
A
I can't say that. As I say -Q
Right.
A
-- I did not pay attention. It could
have happened. I don't know.
Q
Okay. But I understand that in 2013 you
say it changed.
A
I believe that's the year that they -they changed it. I don't know.
Q
They started a judge -- they started a
case management --
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A
I don't know. That -- that does not -that is not something I'm included in. I just know
that they started what they said was case assignment.
That doesn't -- it doesn't really affect me except
that I take down what the judge that I work for that
day hears. That's all I know.
Q
So if you're there for Judge Baldwin
calling the calendar and the case goes to another
judge, you don't take it down?
A
I don't take it down if it's before
another judge, no, sir, because I'm not in that
courtroom.
Q
And is there another reporter assigned
to the other judge?
A
I would think so.
Q
But do you know?
A
I'm not in that courtroom. I can't say.
But I would assume that that judge would have a court
reporter.
Q
I want to show you an invoice, and I
want you to explain this to me, if you will.
MR. FARMER: This is going to be
Plaintiff's Exhibit 9.
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A
If it had been assigned to a different
judge, I guess it would. But I don't -- I just -- I
don't know. Like I say, I don't pay attention to the
calendar call. It doesn't -- it doesn't affect me as
a rule.
Q
But -- so you don't -- you didn't even
know that there was a case management plan before the
2013 era after that?
A
I just knew that I went with a judge to
a courtroom for his calendar call and for the cases
that he heard that day. I -- it just didn't -- it
didn't apply to me. All I knew was to take down the
cases that I was asked to take down before that
particular judge.
Q
But you knew it was an issue for me to
have it taken down, to have the call of the -A
At some point I think -- I'm sorry. I
didn't mean to interrupt. At some point I think I
realized that from you, but I don't really -- I don't
know. I just -- it didn't appear to apply to me
except if you wanted it taken down. And if the judge
had wanted -- had -- the judge said he wasn't going to
have it taken down, so I didn't take it down the
second time.
Q
Can you imagine any reason for the judge
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MR. FARMER: Y'all need to take a break?

MR. GORDON: Yeah, before or after this
exhibit. It's your choice.
MR. FARMER: You can take it now.
MR. GORDON: Huh?
MR. FARMER: You can take it now.
MR. GORDON: Okay.
Just hold on.
THE WITNESS: Okay.
THE VIDEOGRAPHER: This is the end of
Video 1. We're going off the record at
11:06 a.m.
(Whereupon, a recess was taken.)
THE VIDEOGRAPHER: We are back on the
record. This is the beginning of Video 2 at
11:14 a.m.
BY MR. FARMER:
Q
You do understand that having the call
of the calendar taken down, that that would be a
relevant bit of information to determine if the -- if
the judges were taking the case according to a case
management plan or if they were taking it -- randomly
assigning them when the calendar was called? You
could understand that? That would document it?
That's all I'm asking.
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not having it taken down?

A
I don't think I should be thinking what
the judge would be -- me try to tell you what the
judge is thinking. I don't know.
Q
Okay. Had he ever told you before not
to take down a calendar call?
A
I had never been asked to except the one
time by you, and he did not tell me not to that
time.
Q
So after he saw it was being used is
when he said, don't take it down?
A
No, sir. He said -- I did not know -as far as I remember, I did not know until we got in
the courtroom that I would not be taking it down.
Q
But you knew you had requested -A
I knew that you had requested it, yes.
Q
And you knew that Nan Freeman had
requested to Judge -- had alerted Judge Baldwin that I
wanted it taken down?
A
I did tell Judge Baldwin you wanted it
taken down. "Alert," I don't know. That's your
word.
Q
Okay. And did he say anything about
what he was going to do?
A
I don't recall his saying anything about
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what he was going to do. I don't recall. To the best

of my recollection, I went in the courtroom and I was
going to take it down. But I cannot say that for
sure.
Q
So it was totally Judge Baldwin
preventing it being taken down?
A
Well, I just would not tell the judge
what to do.
Q
Right. So you assume that you were told
not to take it down?
A
All I remember is him calling y'all to
the bench for a bench conference.
Q
And did you know what happened as a
result of that?
A
I did not take down the calendar call.
Q
Okay. And was it because he told you
not to?
A
He did not look at me and say, Nan,
we're not -- I'm not going to have you take down the
calendar call that I remember. What I remember was,
he said, we're not going to have the calendar call
taken down. But I don't know that he said it -- I
don't know that he addressed that to me.
Q
He said it to me.
A
That's what I remember from that
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A
Q
A
Q
A
-- remember.
Attorneys.
One.
Which one?
Larry King.
MR. GORDON: Say it again.
THE WITNESS: Larry King.
BY MR. FARMER:
Q
Let's see if this is the case. He was
co-counsel also representing Ms. Murphy?
A
At that time, yes.
Q
Other than Ms. Murphy's lawyers, have
you ever seen him, say, ordering somebody held in
contempt, a lawyer held in contempt, and tell him he
was going to put him in jail?
A
I can't say that for sure. I don't
remember.
Q
Okay. But do you ever remember him
doing it?
A
I don't think so. But I can't say -- I
can't say that he did or he didn't. I don't
remember.
BY MR. FARMER:
Q
Were you there taking that down?
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recording.
Q
Okay. And when he was hollering "do you
understand," he was hollering at me, right?
A
I would say the recording speaks for
itself. I don't know.
Q
And what would it speak to itself? Was
it to somebody else he was speaking?
A
If you were the person he was asking if
you understood and you didn't answer, I guess that's
who he was saying it to.
Q
What was it for me to understand about
him saying he wasn't going to do it?
A
I don't remember. He said something.
And he said, do you understand? I don't remember what
exactly came before that.
Q
Did he say, I'm going to put -- he was
asking me did I understand that he was going to put me
in jail.
A
Oh, is that what he said? Okay. I
don't remember exactly what he said before that.
Q
Had you ever seen him put anybody in
jail or ordered them held in contempt of court and
taken into custody?
A
Probably. But I don't specifically -Q
Attorneys.
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A
As far as I remember.
Q
Was Larry King making any movements that
wasn't -- that were unusual at the time, or was -A
I don't recall anything unusual about
that, but I -Q
Does the audio reflect accurately what
was taking place?
A
I'm sure it does.
Q
And did they take him -- did the sheriff
take custody of him?
A
I don't remember him going back, but I
don't know.
Q
Did he -- did he -- did he take -- did
he take control of him?
A
I don't remember.
BY MR. FARMER:
Q
At that point did the sheriff come up to
him and he agreed to pay the thousand dollars?
A
I don't remember that. I remember him
agreeing to pay the thousand dollars.
Q
Do you remember Judge Baldwin after that
saying he had gotten mad and done this?
A
I don't remember that.
Q
If that's reflected in the transcript --
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A
Okay.
Q
-- it would be -- it would be accurate,
right?
A
I would think so, yes.
Q
I'm going to show you an invoice. And
it's October the 14th -MS. TUNKLE: October 3rd transcript.
BY MR. FARMER:
-- for the October 13th transcript.
MS. TUNKLE: October 3rd transcript.
BY MR. FARMER:
Q
October 3rd transcript. But it's an
October 16 invoice. And I'm going to show you this.
It's going to be Plaintiff's Exhibit 10.
BY MR. FARMER:
Q
And I will ask if you will explain this
transcript. Before I ask that, though, let me just
understand this about the transcript. As I
understand, you invoice the people to pay. That's a
requirement, that they pay you for your work?
A
Yes.
Q
And you invoiced us in Atlanta, Fulton
County, at our address in Atlanta?
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Coweta County.
Q
Yes. But the payment was required to be
made -- the demand for payment was made with the
invoice; is that right?
A
It was made with you -Q
That's right.
A
-- at the address you gave me.
Q
Right. And it was -- in other words,
if -- and we paid you every time?
A
There was one that evidently y'all
misplaced. But that got straightened out. But all
the work was done in Coweta County, and I billed it to
you at your office address.
Q
In Atlanta, Fulton County?
A
If that's where your office is.
Q
And if we had not paid you, we wouldn't
get the transcript?
A
No. I think I mailed the transcript
with the bill. I didn't require -Q
Okay. But I'm talking about -A
-- payment upfront. I didn't even
require a down payment.
Q
But essentially it was a necessity to
get the future transcripts that you be paid? It was a
demand for payment? It was a legal -Page 77
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A
Yes.
Q
And we were required to pay on the basis
of this invoice; is that correct?
A
That's my understanding.
Q
Okay. And we -- and we had to pay the
amount of the invoice; is that correct?
A
That would be my understanding.
Q
And you knew that we were located in
Fulton County, Atlanta when you required us to pay
that invoice?
A
Yes, sir.
Q
And we -- and it was paid to you from
Atlanta, Fulton County?
A
As far as I know. I don't know where
you were when you signed the check.
Q
Okay. But that's where the demand for
payment was made?
A
I mailed it to the address that was on
your card. At one time I think I mailed it to a wrong
ZIP code, and we got that straightened out.
Q
But at all times it was sent to Fulton
County, Atlanta?
A
It was.
Q
Yes.
A
But it was taken down in
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A
Q
Yes, sir. Yes, sir.

You were legally requiring us to pay
it?
A
Yes, sir.
Q
And that demand was made pursuant to
your authority to act as the court reporter for -that was designated for the court proceedings,
right?
A
Yes. I took it down.
Q
These are not private transcripts or
anything like that or -A
No, sir.
Q
-- depositions?
A
I didn't do any of that in Atlanta.
Q
And these were all for official court
reporter transcripts?
A
Yes, sir.
Q
All right. Now, if you will look at
that invoice and explain that to me, if you will.
A
All right. It's billed to you. It's in
this case. The hearing date appears to have been
October 3rd. And I expect that I charged the opposing
counsel the same amount of money.
Q
And now let's look at that. And how
many pages -- the page numbers of that?
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A
It appears to me that that would have
been 117 pages if the certificate is on the next page.
Q
Just assuming raw page numbers, not the
legal page numbers that are -- that you are -- the
legal page numbers are not the page numbers that
you're entitled to charge for, are not the page
numbers that are on the bottom of the page, right? In
other words, you can't charge for a page until you
have so many lines on it?
A
13.
Q
And so the number at the bottom of the
page doesn't reflect the legal amount that you're able
to charge for, does it?
A
Would you explain your question?
Q
Yeah, okay. You've got to have
63 characters per line -A
Correct.
Q
-- before it's a line, right?
A
Correct.
Q
And then you have to have 25 lines per
page -A
Correct.
Q
-- before it's a page, right?
A
Correct.
Q
Now, some of the pages in the 116 may
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Q
Okay. And that equals 434 dollars
and -- $424.56?
A
I can't say. I don't -Q
Okay. I'm just saying -A
-- have it in front of me.
Q
I'm just saying, if you'd go with me
with the math.
A
I don't know.
Q
Okay. Let's let you do the math.
A
All right. Well, what I -- I expect
what I did was, I added the original and two copies
for one -- for one party and I added $1.51 for the
other and I divided it in half, that way.
Q
Where do -- how do you show that you
divided in half where you say in the billing it's
one-half cost of the transcript?
A
Because I added the rates together and I
multiplied it times the number of pages.
Q
Okay. Can you document that?
A
Not here today.
Q
Okay. But you'll be able to document
it?
A
I believe so.
Q
And what would you -- what will you be
able to document?
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not have met those qualifications?

A
That's correct.
Q
So the 116 would be the outside high
number of pages that were in that transcript that we
were to be due to pay for, right?
A
I would say I base it on 117 pages.
Q
Okay. We'll give you your -- for this
hypothetical to be 117 pages.
A
I'm just saying what the certificate -Q
Okay.
A
But what you're saying is -- it would -the number of characters on a line.
Q
Okay, okay. Now, half of the cost of
that would be what?
A
It appears it would be 352.86. There
may be some postage added in that.
Q
Okay. And what provision -- and how did
you -- how do you support that?
A
I don't have my figures in front of me,
so I can't tell you.
Q
Okay. The full price would be -- add a
page to it. The full price would be 438.48 plus -minus -- minus your characters. You didn't have the
number of characters per line.
A
I understand what you're saying.
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A
I believe that I would -- I would
document that I used the 3.78 page rate and $1.51 page
rate, added it together, multiplied it times the
number of pages and divided by two. And I probably
have half the postage in there.
Q
Okay. And would you say on that because
of the format you'd use that you would be using an
incorrect number of pages?
A
I cannot say specifically, but I would
think so, yes. I think it would affect the number of
pages.
Q
So you -- so this is an overbilling?
A
It would be in that case because I made
a mistake in my line -Q
Okay. Whatever -A
-- my characters per line.
Q
Excuse me. I'm sorry. She's told me
not to try to talk over you, and I'm trying to
remember.
So you -- for whatever reason you have
collected -- if -- with your format you're using, you
collected an illegal amount of money on that?
A
An incorrect amount, yes.
Q
And it's illegal?
A
It's incorrect.
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Q
Well, is it legal?
A
It's incorrect.
Q
Okay. But "is it legal" is my question.
A
It's incorrect. I made a mistake.
Q
Okay. But were you legally allowed to
do it?
A
I made a mistake. And that's all I can
say. I made a mistake in the number of characters per
line by two characters per line.
Q
Is it in -- was -- was what you charged
in conformity with the requirements that you are
required to -- that you're required to charge or
allowed to charge?
A
I had 61 characters per line of the Q&A.
And that is what -- instead of 63.
Q
And does that affect the number of
pages?
A
Yes, sir.
Q
And have you checked to see how much it
affected the number of pages on that particular
transcript?
A
I have. I don't have it with me.
Q
And did you check it as far as the
colloquy? Is the colloquy different from the A&Q?
A
Yes.
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overcharged them?
A
I've told the judge that I had -Q
"The judge" meaning?
A
I told Judge Baldwin -Q
Okay.
A
-- that I had 61 characters per line
instead of 63.
Q
What did he say?
A
I don't recall.
Q
Okay. Well, what did he say?
A
I don't recall what he said.
Q
Okay. Did he -- did he say that that's
wrong?
A
I don't recall what he said.
Q
Okay. Go ahead.
A
And I've told Mr. Skandalakis.
Q
When did you tell Mr. Skandalakis?
A
I had gone in his office to see some -one of the victims' assistants. She had -- she had
something she was going to give me totally unrelated
to court. And she wasn't there. And I just happened
to see Ms. Kirby and Mr. Skandalakis.
Q
Meaning Judge Jack Kirby?
A
No, sir.
Q
Ms. -Page 85
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Q
And did you check to see how much you'd
overcharged for the colloquy?
A
I just did the entire transcript. I
didn't do one and then the other.
Q
Do you know it's a different rate for
colloquy -- a different requirement for colloquy than
it is for A&Q?
A
Yes. The colloquy is indented.
Q
Did you make account for that when you
were seeing how much you were overcharging?
A
Yes, I did.
Q
And did you make -- then the A&Q you
kept separately?
A
No, I did not.
Q
Now, as I understand what you're telling
me, that would have been the way that you billed
everybody that you were billing for transcripts and
proceedings before Judge Baldwin during that time
period.
A
I expect so. I have not counted every
line on every transcript, no.
Q
Of course, we notified you that you
overcharged us.
A
Yes, sir.
Q
Have you notified other people that you
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THE REPORTER: I'm sorry, Judge who?

MR. FARMER: I'm trying to ask her.
BY MR. FARMER:
Q
Was it Judge Jack Kirby? Which Kirby
did you -A
Ms. Kirby and Mr. Skandalakis.
Q
Okay. Are you referring to the spouse
of Judge Jack Kirby?
A
She's married to Jack Kirby, yes.
Q
Okay, which I don't think her name is
Ms. Kirby, but whatever her name is. I don't know
what -- okay.
A
She's not Mr. Kirby.
Q
All right, okay. Was that after the
publicity about the court reporter?
A
I don't recall. Probably so. Maybe so.
I don't remember when I went in there. I mean, I
just -- I don't remember when I went in there. But I
remember I told them. It probably was. I don't know.
But, I mean, I didn't go in there about that. I
didn't even go in to see them.
A
I've read this.
BY THE WITNESS:
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Q
Okay. Explain what you're looking at in
that Plaintiff's Exhibit 11.
A
It's a letter from Pete Skandalakis to
you.
Q
What is the content of that letter?
A
It says he's read your letter regarding
me and he's listened to the audio recording and
reviewed the pleadings and the transcripts that you
furnished. And he says he notes that you have filed a
civil suit against me. And he said he's reserving
further action until the civil suit is resolved.
Q
And was the time that you saw him before
or after that letter?
A
Oh, I can't say. I don't know. I don't
know the date.
Q
Did he say he knew anything about the
complaint filed against you?
A
Not that I remember. I honestly don't
remember what day I went in there. I don't know if it
was before or after this.
Q
Okay. You know it was after the
complaint was filed against you?
A
Oh, I feel sure it was after that, yes.
Q
Because that's the first time that you
had counted to see if you were in conformity with the
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the transcripts for you, did she ever -- or he -whoever it was -- did that person ever check to see if
it was in conformity with the law?
A
I doubt it.
Q
So as I understand, had you been to
seminars or anything for court reporters during this
period of time?
A
Yes, sir.
Q
And at the seminars had you ever been
instructed or had you ever been given information as
to what the charges would be?
A
Not that I recall.
Q
And are there other court reporters in
the Coweta Judicial Circuit that are using the format
that you used to charge, or are they using a different
format, template?
A
I've never talked to them about what
format they use. Well, I take that back. I may have
talked to one or two, but we haven't discussed that.
Q
Have you talked to them since this case
has been filed?
A
Yes.
Q
And who did you talk with?
A
I talked to -- I know I talked to
Judge Simpson's court reporter.
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requirements of the Board of Court Reporters?

A
I don't know that. When I set up my
transcript to begin with, I may have. I don't
remember.
Q
After that did you ever check to see if
you were billing people correctly?
A
I never knew that I wasn't.
Q
But did you ever check to see if you
were billing them in conformity with the law?
A
I can't say that I looked to see if
every time I billed somebody I had space for
63 characters on a line.
Q
Did you have any system by which you
could make that determination?
A
I could do it every time I do a
transcript, but I haven't.
Q
How could you do it then?
A
Every time I did a transcript I could
count the spaces on a line.
Q
Other than manually counting it, did you
ever do -- and randomly ever check to see if you were
ever doing any of them?
A
Not that I remember. I don't know if I
did or not.
Q
Did your typist that was typing some of
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Q
And who would that be?
A
Her name is Sheryl Lee.
Q
And where is she located?
A
She lives in Carrollton.
Q
And what was that conversation?
A
Unlike me, she had somebody she
replaced, and she got her template from them. And I
think hers is in compliance. I think hers is in
compliance.
Q
Who else did you talk with?
A
None of the other court reporters in the
circuit that I recall.
Q
Were there court reporters that you
talked with or professionals you talked to that were
outside of the circuit?
A
Yes.
Q
And who were they?
A
Alice Moore.
Q
And what -- what was that
conversation?
A
To my knowledge, hers is in compliance.
But that's all I remember.
Q
And what system was she using to
determine why she was in compliance?
A
I don't know. She uses Word Perfect,
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and I use Word.

Q
And did you talk to her before the case
was filed or anything -- any reporter before this
matter was called to your attention by us before we
filed the complaint?
A
I'm not sure.
Q
Since the time that the complaint was
filed, since the time that you've known that you've
overcharged, have you used any other system to correct
that other than just manually counting?
A
Changing the margins.
Q
Okay. And have you checked to see if
that corrected your overcharging?
A
You mean did I count the spaces after I
did that? Yes.
Q
Do you randomly check them?
A
I don't understand.
Q
Do you randomly check to see if you're
overcharging according to the state law for a reporter
that's working for a court?
A
After I changed the margins, I used
that. But I don't go around counting lines on every
transcript.
Q
Do you do any other compliance checks to
see if you are complying with the law?
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in mind, and I don't know what it is.

Q
Have you ever checked for any things
other than those line counts and page numbers?
A
I don't know because I don't know what
you mean.
Q
Okay. Have you checked the criminal
court for the criminal cases? Have you checked to see
if you overbilled on each of those in any of those
cases?
A
On each of those, no.
Q
You haven't checked?
A
Not on each of those, no.
Q
Any of them?
A
Not really.
Q
Did Mr. Skandalakis, did he say that he
had checked on any to see if you were overbilling the
County?
A
He did not tell me that he had or he had
not.
Q
And it's the County that has to pay for
that in criminal cases; am I right?
A
That's what I understand. That's who I
bill.
Q
Did you notify the County paymaster or
the County Board of Commissioners that you had
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A
I don't know if I do or not. I don't
know what you mean.
Q
Okay. Well, there are other compliance
other than line checks, right?
A
Like numbers of lines and amount per
page. I don't know what else you mean.
Q
Okay. Well, there are other
requirements for what you can bill for, right?
A
I don't know what you mean.
Q
Okay. The only requirements that you
understand as far as the legal right to charge as the
court reporter is designated by the Court?
A
I don't know if you're referring to
anything specific or not.
Q
I'm referring to any. Are there any
other requirements other than the line count and the
page count that you're familiar with?
A
I don't know if you're referring to
anything specific or not. And if you are, I don't
know what it is.
Q
Okay. So you don't know of any other -any requirements other than line count and page
count?
A
As I sit here right this minute, that's
all I know of, but I don't -- you may have something
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overcharged them during this same period of time?

A
No, I have not.
Q
Other than the -- other than the
communication with Pete Skandalakis and his assistant,
have you notified any other lawyers that you
overcharged them?
A
I don't believe so.
Q
Did you think it was unusual that
Judge Baldwin was writing me about you charging
Ms. Murphy too much money for the transcripts that she
was having to pay? Did you think there was anything
unusual about him being protective of you and not
being protective of her for costs that she was having
to pay?
A
I don't know what you're speaking
about.
Q
Okay. Well, you know, it's Ms. Murphy
that has to pay for this.
A
I understand.
Q
And you understand that she is a mother
that's trying to protect the right of her children?
You understand that from being at the hearings, don't
you?
A
I understand that she has her side and
the other side has his side and --
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Q
And her side is that she's trying to
protect the right of her children, right?
A
That's what you-all are doing, yes.
Q
And you understand that the other side
has a very substantial amount of money and that she
earns her money as a hairstylist? You understand
that, don't you?
A
I don't know anything about the parties
and their finances. I know Ms. Murphy is a
hairstylist from the court proceedings.
Q
And you know that Judge Baldwin has said
that he wasn't going to provide any -- may not be able
to provide any money to her for attorney's fees? You
know that?
A
I don't remember.
Q
You don't remember that part of the
transcript?
A
I'm not saying it's not there. I just
don't remember.
Q
Do you know that the cost per page that
you've overcharged is about 12 cents a page? Have you
figured that out?
A
I haven't figured it out per page.
Q
Okay. How much -- have you figured out
per page how much you've overcharged with that
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A
He just heard what I said. That's all I
know. He heard me. That's all I know.
Q
And what did he respond?
A
I really don't remember.
Q
Does Judge Baldwin sentence people for
stealing?
A
I'm sure he does.
Q
Have you ever -- have you heard him
sentence people for stealing?
A
Yes.
Q
And does he sentence them to prison for
stealing?
A
Some people. Not everybody.
Q
But some he sentences to prison?
A
Yes.
Q
And if they say they made a mistake in
stealing, does he say, I'm not going to sentence
you?
A
I honestly don't remember anything like
that.
Q
Is mistake to stealing, is that a
defense?
A
I'm not a lawyer. I don't know.
Q
Okay. Do you consider it to be a
defense?
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format?
A
I know from refiguring -- from
refiguring them -- I don't know per transcript. I
don't know -- but I know the total from all of them.
Q
Do you know how much you have charged
Ms. Murphy for your transcripts?
A
Altogether? No, sir.
Q
Do you know how many criminal
transcripts you've produced during this period of time
that you used that format?
A
No, sir.
Q
Did -- has Mr. Skandalakis or anybody on
his behalf approached you about the amount that you
overcharged the County since that initial conversation
with you?
A
Pardon me? Would you say that again?
Q
Since the initial conversation, has he
approached you any other time?
A
No, sir.
Q
Did he say he was going to do anything
about it?
A
He didn't tell me.
Q
Did he mention anything about that it
was wrong for you to do that or illegal for you to do
that?
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A
I can't say.
Q
What -- what -- what defense do you
consider that you have to taking -- violating the law
and overcharging people as you've overcharged and
overcharging the County as you've overcharged?
A
I made a mistake on my line -- my spaces
per line.
Q
And the Board of Court Reporters doesn't
say that if you make a mistake that you don't -- that
you can overcharge, do they?
A
I have not read that.
Q
Okay. You're not aware of them saying
that?
A
I'm not aware of them saying that.
Q
Back to my question about Judge Baldwin
wanting to protect your money. What is your financial
situation as far as income per year approximately?
A
I honestly don't know.
Q
Approximately.
A
I have somebody do my taxes. I honestly
don't know. I honestly don't know.
Q
Okay. Well, what is your estimated
income?
A
I can't answer that. I don't know.
Q
You don't have any round number?
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A
No, sir.
Q
Within $10,000 you can't tell me?
A
I really don't know.
Q
Well, what was the basis of
Judge Baldwin's information that you couldn't afford
the litigation?
A
I don't know. I don't know what he
knows about -Q
Okay. Did you have any basis for -- did
you provide him any basis for making that statement?
A
Not that I recall.
Q
Did you feel that the letter to the
lawyer that he won't provide attorney's fees for
defending Ms. Murphy, do you feel like him attempting
to protect you from paying her back the money you owe
him -- did you feel like that that was inappropriate
conduct on his part?
A
I really don't know what you're
referring to there.
Q
Okay. You overcharged her, right?
A
That's what you claimed. And I say I
have 61 characters per line instead of 63.
Q
Okay. And you've admitted you
overcharged?
A
I admitted I made a mistake.
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don't -- I don't know what you mean. And I don't -- I

really don't know what he's done. I don't see him
much outside the courtroom or -Q
And outside when you go back there to
ask him not -A
Well, I go in his office. I mean, I go
in his office and I do see him. And I did tell him
that I was -- that you had asked me to take down the
calendar call.
Q
But you never told him you couldn't
afford the litigation?
A
I don't know if I did or not. I don't
know.
Q
Would it have been accurate if you did
tell him that?
A
Probably so.
Q
What assets do you have?
A
I have money that I save that's in the
bank.
Q
What -- what -- what -A
I can't tell you how much it is. I
don't know. I have some IRA's that I put aside.
That's basically it.
Q
Okay. What -- what -- what value
roughly?
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Q
Okay. But it's overcharged, right?
A
Yes.
Q
Okay. Now, do you -- do you feel that
Judge Baldwin was justified in saying that I shouldn't
attempt to recover that?
A
I didn't know that he said that.
Q
Okay. Did you think that he was trying
to prevent me from bringing the litigation against
you?
A
All I know is what's in that e-mail.
Q
Okay. Do you think he was trying to
prevent me from having information about his demeanor
toward me and, in effect, toward Ms. Murphy with his
hollering and all like that by keeping me from having
the audio transcripts?
A
I don't know. I don't know. I can't
speak for Judge Baldwin.
Q
But did you have an opinion as to
what -- what was his motivation in doing that?
A
I don't know. I told him that I didn't
think I was required to produce my recordings to you.
That's all I know.
Q
Did he ever tell you he's consulting
with other people about what he did in this matter?
A
Not that I recall. I'm not sure. And I
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A
I really don't know.
Q
Are you in a financial position to
refund the money that you've overcharged to all of
the -- to the County and to people?
A
I don't know how much it is, so I don't
know.
Q
What Counties have you overcharged
beside -- charged money for that you're not allowed by
statute to other than Coweta and Troup? What other
Counties?
A
I don't know how many.
Q
Okay.
A
And I don't know how many transcripts.
I don't know which ones. But there are five counties
in our circuit.
Q
So you possibly could have been involved
with all five of those Counties?
A
Possibly.
Q
Are you aware of this issue of court
reporters overcharging, that a -- court reporters for
the County over the state of Georgia? Are you aware
of that issue in other Counties?
A
I remember the -- some in
Cherokee County were, but that's all I know.
Q
Do you know they're being criminally
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prosecuted?
A
I just know that charges were brought.
Q
Criminal charges?
A
As far as I know.
Q
Okay. RICO.
A
I don't know -Q
Do you know what RICO is?
A
Not really.
Q
Okay. They're RICO charges.
A
I see.
Q
Do you understand the importance of
Michelle Murphy not having to use her assets in an
attempt to get what's legally deserved for her as far
as you are concerned as a court reporter?
A
I know that if you had brought it to my
attention and I had looked into it, if I had found out
I was, it wouldn't have had to have been a lawsuit.
Q
Okay. I brought it to your attention.
A
Yes, but in a lawsuit.
Q
Okay. Huh?
A
In a lawsuit.
Q
Okay. I brought it to your attention
about the County.
A
Pardon?
Q
I brought it to your attention about the
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Forget it, Nan? You're my friend, and I'm not going

to charge you for stealing?
A
No, he did not say that.
Q
Okay.
A
I don't remember exactly what he said.
Q
Okay. Has he done anything to your
knowledge about it?
A
Q
You know the Freedom of Information
request was made to the County attorneys?
A
No, I do not.
Q
You know I showed you the Freedom of
Information request earlier?
A
You mean the letter from Mr. King?
Q
Yes.
A
Okay. Oh, I'm sorry, I don't understand
what you're saying.
Q
Okay. That's addressed to the County
attorneys, right?
A
Oh, okay. I see that now. Yes.
Q
And none of the County attorneys have
approached you as far as -A
They have not approached me, no.
Q
And you know the Glover & Davis lawyers
are the attorneys for Coweta County? Did you know
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Counties, that you've overcharged the Counties?

A
Yes.
Q
I brought it to your attention -A
Well, you say -- I say that I possibly
could in my making my mistake, but I haven't looked.
Q
But you possibly -A
Yes, possibly.
Q
Have you brought -- and you haven't
brought it to the attention of those people that you
overcharged, have you?
A
I told Mr. Skandalakis that my lines
were two characters short.
Q
And that's -- did you tell him that by
virtue of that that you had overcharged the County and
that he's on knowledge that you've overcharged the
Counties and he's not doing anything about it? Is
that what you're telling me?
A
I did not tell him that, no. I told him
the truth, that my lines were two characters short.
Q
And that you had overcharged?
A
No, I did not say that.
Q
You didn't say that?
A
No. I said I don't know what effect
that would have on all my transcripts.
Q
And what did he say at that time?
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that?
A
I did not. But I see it now. I didn't
notice. I just read the body of the letter. I didn't
read who all it was addressed to.
Q
Have you ever been to any fundraisers
for money or campaign parties or anything for any of
the judges?
A
Not that I recall ever.
Q
Do you make campaign contributions to
any of them?
A
No, sir.
Q
Do you remember on the tran -- on the
day of the hearing that there was "blame yourself,
blame yourself"? That's what I call the "blame
yourself" hearing. Do you remember that day?
A
I heard that recording. I don't -- I
assume that was the day -- that last hearing that I
reported.
Q
That's right. Do you remember at the
start of that hearing -A
Q
-- that I asked Judge Baldwin -- I said,
Judge Baldwin, I have the children here.
Judge Baldwin came in and sat on the bench. Do you
remember that?
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A
Yes.
Q
I said, Judge Baldwin, I have the
children here, and they want to -- they would like to
testify. Do you remember that?
A
More from hearing something about what
you said later.
Q
But you do -- you do -- do -- now you do
remember that?
A
I believe so. But I believe it's more
from what you said.
Q
And did you record that and provide that
in the transcript?
A
I don't think I started reporting then
because you were setting up a screen like that one
over there and the deputies told you that they had
one, and there was a lot of commotion over on that
side of the courtroom. And the judge asked where your
client was. And you said she's outside. And at some
point I think maybe the judge said, we'll wait for
your client. And so I thought we were not starting
yet.
And then you stood up and began to talk.
And I realized that I needed to take that down. But
up until that time, I thought we were waiting for your
client to come into the courtroom. That's what -- as
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you?
A
He said, we'll wait for your client to
get in here. I did not begin taking down at that
point because you-all were setting up a screen, I
didn't take down "Your Honor, we're setting up" -whatever you said, like "Your Honor, we're setting up
a screen because we have some exhibits" or whatever
you were saying. I did not take that down. I did not
take down the deputy saying "we have a screen and we
can let it down." I did not take any of that down.
Q
Did you take down that we had Jack and
Thomas there, who wanted to testify and wanted to talk
to the judge?
A
I don't believe so because I thought we
were waiting for your client to come into the room
before we began the proceedings.
Q
But you do know it happened?
A
I do vaguely remember that, yes. But I
did not take it down because I thought we were waiting
for your client to come into the courtroom.
Q
Did you notice anything strange about
the courtroom on that day as far as the number of
deputies and everything in that courtroom?
A
No, sir.
Q
Did you know the case was specially
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I recall, it was said, we'll wait for your client.

Q
There's no transcript of Judge Baldwin
when he was sitting on the bench and I was telling him
that Jack and Thomas were here and wanted to
testify?
A
I don't believe so because I don't
believe that I would have been alerted that we had
started the hearing yet.
Q
But when Judge Baldwin came into the
court, you heard him say "order in the court, all
rise"?
A
I don't think he says either one of
those things.
Q
No, no, the bailiff.
A
Probably so but -Q
Okay. But you heard that?
A
I can't say I did.
Q
Okay. That's -A
I would assume it was said.
Q
That's a symbol that court has begun,
right?
A
Yes. But it's not necessarily the
symbol for me to begin taking down.
Q
So you don't take down stuff until Judge
Baldwin tells you to? Or what is the signal to tell
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set -- just that case was specially set for that

day?
A
I may have. I don't remember.
Q
Did you -- did you see Judge Baldwin
when he was hollering "blame yourself"? Did you see
his motions and movement?
A
I don't remember.
Q
You don't remember whether you saw him
or you didn't see him?
A
I don't remember seeing it.
Q
You don't remember seeing his
gestures?
A
I do not remember seeing his gestures.
Q
Do you consider those gestures to have
been hostile?
A
I didn't see them.
Q
You didn't see any gestures?
A
I don't remember seeing anything.
Q
Did you consider that communication by
Judge Baldwin to be hostile?
A
I saw a lot of hostility in the
courtroom in every one of these hearings on both
sides.
Q
And by Judge Baldwin?
A
By every party.
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Q
And by the judge?
A
By the judge and by each attorney and
sometimes a client.
Q
From all -- from the beginning to the
end?
A
At first I don't think I was so much
aware of hostility. I had just come into the case,
and I didn't have any expectation. But I began to see
it, yes.
Q
After the -- after the motion to
disqualify -- after the motions to disqualify -A
I don't know.
Q
You don't know when?
A
I don't know when they were filed. I
don't know anything about those motions.
Q
Was that an unusual amount of hostility
by Judge Baldwin?
A
I've seen him -- I don't know if you'd
say -- I don't think so. I mean, I don't know. It
depends on his cases. I mean, I've heard him
reprimand people before.
Q
I'm not saying a reprimand. I'm talking
about hostility.
A
That's your -- that's really your word,
I think.
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"infectious."
A
Well, one would lead to another to
another. It seemed to go in a triangle.
Q
Between the parties and the judge?
A
Yes, between the parties and between the
parties and the judge sometimes.
Q
And you never saw him hostile to
Taylor Drake, did you?
A
I don't know that I saw him hostile to
you. But that's -- like I say, that's your words.
Q
Heard him being hostile? Did you ever
hear him being hostile to Taylor Drake?
A
I just -- I don't -- I don't know how to
answer that because I just -Q
Am I putting you in a bad position with
this question?
A
I don't know. I just don't -- I don't
remember him -- I just don't remember him -- I don't
remember many of the exchanges between him and
Taylor Drake because Mr. Drake usually did what he
said.
Q
Would you consider defending somebody
from a judge who was giving illegal orders -- would
you consider that to be the obligation of the
lawyer?
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Q
Okay.
A
And I adopted it a minute ago, but
that's really your word.
Q
I understand it's my word -A
Yes.
Q
-- but since I'm the one that's asking
the questions -A
Well, I would say that's your perception
of it, yes.
Q
Okay. Would that perception be
accurate?
A
That's -- according to your definition,
I would just say -- I would just say that the feelings
went both ways with everybody. It was -- it was just
a very -- it was uncomfortable for me. I'm not used
to that level of animosity or whatever you want to
call it from all the parties in a case.
Q
And the judge?
A
Well, yes.
Q
And to the parties?
A
Yes. It seemed to be a little
infectious.
Q
A little what?
A
Infectious.
Q
Okay. Tell me what you mean by
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A
I don't know what an illegal order is,
but -Q
Okay. One that the law doesn't -A
Well, I understand what you're saying,
but I wouldn't know which one was illegal and which
one was not. But, I mean, I think you should do the
best job for your client within the law.
Q
Were you there the day that he ordered
me put in jail when I wasn't even there? I was in
Mississippi on another case, trying another case.
Were you there that day, the same day he put
Larry King -A
I know you weren't there. I was there
that day.
Q
Did you hear him order me held in
contempt, put in jail?
A
I don't remember about the jail, but he
probably did. I don't know. I do remember -- I do
remember something about that exchange, but I don't
remember specifically.
Q
Do you remember that he ordered
Ms. Murphy to be put in jail that day?
A
Well, I think it was upon payment of a
fine or something.
Q
Well, that's put in jail till you do it,
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right?
A
I guess. I don't know.
Q
I mean, that's put in jail, isn't it?
A
I don't -- I don't know. I didn't -- I
don't know what goes on outside the courtroom.
Q
Okay. But you took that down, didn't
you?
A
I did.
Q
And he did say put her in jail until a
certain thing happened?
A
Probably so. That's probably right.
Q
So you did hear him ordering, put her in
jail, right?
A
I assume if that's what he said, I heard
it.
Q
Okay. And you know she wasn't there?
A
Yes.
Q
And you know the day that he took the
children away from -- had the deputy sheriffs take the
children away from her, you know that she wasn't
allowed to put up evidence on that day, that only
Taylor Drake was allowed to cross-examine her and he
stopped the cross-examination. You remember that,
don't you?
A
I do.
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Q
And that never was allowed, was it?
A
It never happened.
Q
Right. And she was on the stand
presenting information when he ordered -- said he was
stopping the hearing?
A
Who was on the stand? Who is "she"?
Q
Ms. Murphy.
A
Yes.
Q
She was trying to explain why she didn't
have the money to fulfill the order when that took
place as you remember?
A
As I remember, she was explaining why
she didn't comply with the judge's order.
Q
And she hadn't finished that explanation
when he aborted the testimony; is that correct?
A
I don't know what else she had to say.
Q
Okay. But she hadn't finished? She was
still -- she was still attempting to answer his
questions when he stopped?
A
As I recall, Mr. Drake was questioning
her, and the judge said he wanted to ask something or
something to that effect.
Q
He took over, right? And that was
before I got to question her, right?
A
He began to ask questions before you
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Q
And you know that she wasn't -- I wasn't
allowed to put up her witnesses?
A
I know that that was -- her testimony
was the last testimony.
Q
And you know that when they sequestered
the witnesses and put the witnesses outside the
witness room that Betty King, the custody evaluator,
was sitting outside the witness room to be put up?
A
No, I did not know that.
Q
You didn't know it?
A
No, sir.
Q
You didn't take that down?
A
I don't remember. If it was in the
transcript or if you said it, I may have known it at
the time. I don't remember it today.
Q
And when you talk about putting up the
screen, you know we were talking about putting up the
screen for our witnesses to present up evidence for
our witnesses, don't you?
A
I know you said -- as I recall, you said
maybe you were going to have exhibits. I don't -- I
don't remember -Q
Right. And that would have been for
testimony?
A
I would assume so, yes.
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questioned her.
Q
And I never got a chance to ask the
questions, did I?
A
No, sir.
Q
And he stopped her from answering
questions, didn't he? He stopped her from giving her
answers, didn't he?
A
He stopped Mr. Drake's examination -Q
-- which was her answers to his
questions, right?
A
To Mr. Drake's questions, yes, but then
the judge asked questions.
Q
And he stopped her from answering -explaining all of her answer to him?
A
To Mr. Drake, yes.
Q
To the judge? Stopped -- the judge
asked her a question, and then he stopped right in the
middle of the questions and stopped and ordered the
children to go with him?
A
Well, he asked if she had complied with
his order, and he determined that she had not.
Q
Well, now, you don't know what he
determined, do you?
A
Well, I guess I don't know what he
determined. But I believe he said -- my understanding
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was -- you have not -- this is me paraphrasing -you've not done what I asked.
Q
Right. But if he had asked her to do
something that was illegal or asked her to do
something that was impossible, she was entitled to
defend that in your view of the law, right? I mean,
do you think a person is entitled to a defense?
A
Yes, sir.
Q
And do you think a person is entitled to
explain their defense?
A
I would think so.
Q
And did you see her trying to explain
her defense when he stopped and took the children
away?
A
She was answering Mr. Drake's
questions.
Q
Okay. And was she trying to explain her
defense in doing so?
A
Probably so. I don't remember exactly
what she was saying.
Q
And did you remember Larry King saying
that he had witnesses that they wanted to present and
testify?
A
I don't remember. Was that in the
addendum?
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Q
A
Okay. Take a break.

Okay.
THE VIDEOGRAPHER: This is the end of
Video 2. We're going off the record at
12:20 p.m.
(Whereupon, a recess was taken.)
THE VIDEOGRAPHER: This is the beginning
of Video 3. We are on the record at 12:25 p.m.
BY MR. FARMER:
Q
Ms. Freeman, have you ever noticed Judge
Baldwin -- had any information about Judge Baldwin
suffering from any type of illness or being under any
type of medication?
A
I know he sees doctors from time to
time, but no. I mean, I don't know about any
medication he takes. I don't know anything about his
health situation.
Q
All right. And what does he -- what
type of doctors or what type of thing? Do you know
what his -A
I don't know.
Q
But you don't know of anything -- you
don't know of any medical excuse that he would have
for his behavior?
A
I don't know anything about his medical
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Q
Yes, it was.
A
Okay.
Q
Do you remember him saying -- that took
place, right?
A
Whatever is in the addendum, I remember
that. I mean, I would remember -Q
Judge Baldwin did not allow it, did
he?
A
I don't believe he did.
MR. FARMER: Can we have just a few
minutes?
THE WITNESS: Certainly.
BY MR. FARMER:
Q
Before we take that, is there something
you would like to explain that I have not asked you
that may explain the reason for your conduct that you
haven't told me about?
A
When we come back from the break, can I
answer that -Q
Yes, yes.
A
-- and you give me a chance to think
about it?
Q
I'm going to -- I'm going to give you a
closing statement.
A
All right. Thank you.
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situation.
Q
All right. But I mean from seeing him
in the courtroom, you don't know of any medical reason
for any of his behavior?
A
I really don't know about
Judge Baldwin's medical issues. I don't know
anything -- I don't know if he has them, what he has.
I don't know.
Q
Do you -- do you report proceedings in
which Lisa Hollowell is the guardian ad litem? Have
you reported any other proceedings other than this one
in which -A
I don't remember about her being a
guardian ad litem in other cases, but I don't -- I
never paid attention. And sometimes I don't know who
a guardian is. I don't -- I don't know.
Q
Have you ever participated in any case
in the Coweta Judicial Circuit at any time in which a
person was required to go to a custody evaluator?
A
I believe so. But I don't know for
sure.
Q
Okay. And who? What -A
I really don't know. I really don't
know. I think I've heard that term.
Q
Outside of this case?
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A
I believe I've heard that term before,
but I really don't know.
Q
You don't remember ever taking down
testimony from a custody evaluator?
A
I can't -- I can't remember any, but I
can't remember that I haven't either.
Q
Okay. So you don't -A
I could have. I just don't remember.
Q
You don't remember any type of case
where -A
Well, I've heard psychologists, I know,
and I've heard guardians ad litem.
Q
Okay.
A
Custody evaluator I may have. I don't
know. I just never paid much attention. I just took
down what was -- what -- you know, what was on the
stand at that time.
Q
Do you realize how the cost of
litigation could affect the right of a mother to
defend herself and defend her children?
A
I would think it affects any lawsuit of
any type, yes, the defense. Yes, I can.
Q
And do you realize how the treatment -the disposition of a judge picking up the children
there in the courtroom like that, turning them over to
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I have no way -- I know nothing about
where they are. I know nothing about those
children.
Q
You remember when it was determined
that -- the children were in St. Thomas that there was
going to be a hearing, that we were requesting a
hearing? Do you remember that?
A
No, I don't.
Q
You remember that when -- that we were
requesting to have a hearing and Judge Baldwin said he
couldn't obtain a court reporter? Do you remember
that?
A
I wasn't involved with it.
Q
So you didn't tell him that you
wouldn't -- you refused -A
Oh. Well, I told him I didn't think it
was appropriate for me to report it.
Q
And it wouldn't have been, would it?
A
I don't believe so.
Q
And why wouldn't it have been
appropriate?
A
Because you're bringing a lawsuit
against me.
Q
Because you were overcharging, right?
A
Is that the only reason you brought the
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the deputy sheriff in the courtroom -- have you ever 1

seen Judge Baldwin do that before?
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I don't remember it. But I haven't
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worked for him, you know, but a few years.
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But a few. In all the years that you've
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seen him, have you ever seen him do that?
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I don't remember that.
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You don't remember seeing any other
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judge do that?
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I don't remember any -- I don't remember 10
that, but I do -11
Q
Do you know what happened to the
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children after they left that day?
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No, sir. I would have no way to know. 14
Q
Do you know that they are in a lock-down 15
facility in Utah where they cannot -- where they
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cannot see their mother and they cannot talk to
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anybody outside of the -- outside of the facility
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where they are?
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A
I have no knowledge of any of that.
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Q
Do you know that people in that
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lock-down facility, according to the people in
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Tennessee where they had been sent, that they have 23
been psychologically and physically injured in that 24
facility?
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lawsuit?
Q
No. Because you wouldn't give the audio
recordings.
A
But you sued me anyway even though you
got it.
Q
I remain -- we remained overcharged.
You know that, don't you?
A
Yes.
Q
Okay. And in other words, you took -A
But if you had brought that to my
attention, I would have corrected it at the time.
Q
Okay. We brought it to your attention.
Have you corrected it for all the other people?
A
No, sir.
Q
Okay. So as we stand here today, the
children are in -- when they went to St. Thomas and
they were coming back, we were supposed to have a
hearing. And assuming that Judge Baldwin never asked
you, did he ask you about getting another court
reporter to -A
No, sir.
Q
-- cover the hearing?
A
I don't believe he did.
Q
Do you know that he wouldn't allow a
hearing for the -- to support the testimony of the
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child that came back and gave the video and said that
John Murphy was and Renee Murphy were allowing the
children to have alcoholic beverages at Fox's Bar
in -- near the -- off near St. Thomas?
A
I don't know anything about that.
Q
Did you know that -- have they ever told
you that Judge Baldwin would not let me file any
pleading in his court now unless I send it to him
first for his approval? Did you know that?
A
I don't. I mean, I've heard something
about that, but I don't know anything about it.
Q
Okay. What have you heard about that?
A
I believe -- I really don't know. I
just remember -- I don't know that I was specifically
told, but I believe I heard it discussed. But I can't
remember.
Q
Who did -- how did you hear it
discussed?
A
I don't remember. Maybe I -- I believe
I heard maybe that Cindy had asked -- Cindy Brown, the
Clerk in Coweta, had asked Judge Baldwin -- I just
believe I was present when that was discussed with
somebody. She didn't know what to do, maybe that she
had been asked to file something and she asked Judge
Baldwin about it. I really --
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think that was it.

Q
Okay. And who was -- who was the
conversation from Cindy directed to? Was it -A
I may have heard Judge Baldwin talking
to somebody. I really -- maybe a bailiff. I don't
know. I'm not -- I can't say for sure.
Q
Do the bailiffs stay in his chambers
when he goes off the bench during hearings?
A
I don't know.
Q
Well, what was the occasion for you
being in his chambers?
A
It might have even been in the hall,
Mr. Farmer. I don't -- it might have even been in the
hall. Or I might have been in the hall and -- I just
don't know.
Q
So you are familiar that he said that I
could not file any more pleadings that he didn't
approve of?
A
I'm aware of something to that effect.
I don't know that I have -Q
Okay.
A
-- been told specifically or seen
anything specific, but I was aware, vaguely aware,
yes.
Q
Did you know those pleadings that he
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Q
I was downstairs waiting to file
something, and she wouldn't file it.
A
I don't know. It's something to that -Q
He was upstairs with a case.
Remember?
A
Well, I just remember hearing something.
Q
Okay.
A
But, I mean, I wasn't a party to that
conversation, I don't think.
Q
I know, but you were listening, though.
A
Well, no. I just think I had -- I heard
it in passing. But I was not party to the
conversation. I just -Q
But he wouldn't -- but he said, no, he
wasn't going to allow it to be filed.
A
I don't remember.
Q
And it was -A
I just know that Cindy had asked him -I'm sorry. I didn't mean to interrupt. I know that
Cindy had asked him what to -- as I recall, Cindy
asked him what to do, and that's all.
Q
What did he say?
A
I don't -- I don't even know if he was
the person saying it. I don't know. I just remember
something about it. You asked me how I knew, and I
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wouldn't allow me to file documented his conduct?

A
No, sir, I did not.
Q
Did you know those pleadings that he
wouldn't allow me to file documented things about
where the children are being treated now and how the
children are being held away from Ms. Murphy and that
she's not even been allowed to know where they are
located?
A
No, sir, I did not.
Q
Did you know that he has never issued
such an order in the time he's been there on the
bench? Have you ever heard him issue an order like
that, that a lawyer can't file a pleading?
A
No. But I would have no knowledge of
anything like that.
Q
I understand. I'm asking, did you know
that?
A
No, sir. But I would have no way of
knowing.
Q
Have you seen anything in the time that
you've been reporting to justify him saying that a
lawyer couldn't file a pleading in a case without
showing it to him?
A
Would you repeat -Q
Yes.
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A
Would you repeat that? I'm sorry.
Q
Yes. In the time you've been reporting
this case -A
Yes, sir.
Q
-- have you seen anything that took
place in any of the reporting that would justify him
saying that the pleading could not be filed, that the
lawyer couldn't file a pleading until after he
approved of it?
A
I just don't think I'd be in a position
to judge that. I have no idea about -- I have no idea
about any of it. I don't know what's -- I don't know
that he's ever done it. I don't know that he hasn't.
I'm not in a position to judge that.
Q
But I'm asking -- you're around -- but
you're in the courtroom more than 90 percent of the
people in the world in Coweta County, and I'm asking,
have you -- have you seen anything that would justify
that in this case?
A
In this case?
Q
Yes.
A
I don't know. I just don't -- that's
not -- I just don't think that's anything I'm in a
position to judge.
Q
Do you think -- in your view of -- I'm
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Q
So your job is depending totally upon
him?
A
I could leave if I wanted to.
Q
I understand that. But if you wanted to
keep your job, it would be dependent on
Judge Baldwin?
A
Of course.
Q
And your income is dependent upon
Judge Baldwin?
A
As long as I work in his courtroom,
yes.
Q
And if you didn't work -- if he wouldn't
employ you in the Coweta Judicial Circuit, there's not
another available place for you to obtain employment
in the Coweta Judicial Circuit?
A
Not today.
Q
Have you had -- do you have any nephews?
Nieces?
A
Yes, sir.
Q
What age are those children?
A
I'm not sure exactly. Probably early
thirties to 16 or 17.
Q
Were you around them as they grew up?
A
Somewhat. They don't live near me.
Q
I know. But, I mean, they were part of
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trying to get a position of your value system. Do you

think that a lawyer should have to submit a pleading
to the judge before they're given permission to file
it with the Clerk of Court?
A
I don't know what the law is. I don't
know what's required. I don't know how that works.
Q
Forget about the law. As a matter of
fairness, do you think he would be willing to tell one
side that they could file something and the other side
that they couldn't?
A
I would think he would have to tell the
same to both sides.
Q
And if he didn't, do you think that
would be some showing of unfairness?
A
I would think that would be your
perception. I just don't think that -- I don't think
that I'm in a position to say that because it doesn't
have to do with me, and I just think that's between
the judge and the parties or the parties' attorneys.
Q
Your job depends on Judge Baldwin; am I
correct?
A
He's the -- he's the judge I work for.
Q
And if he said, I don't want you
anymore, you're fired, you're gone, right?
A
That's true.
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your extended family?

A
Certainly.
Q
If they were separated from their
parents and not allowed to see their parents, do you
think that would -- considering who their parents
were, would that affect their well-being?
A
I would think it would if the parent -I mean, it would depend on the parents. But, yes, I
would think so.
Q
Can you ever justify any reason that -anything that you know about this case that
Michelle Murphy could not even talk to her children on
the telephone?
A
I don't -- I don't know any -Q
Do you know of any evidence that you've
heard that would say that she was not justified in
talking to the children on the telephone after that
hearing when he did the "blame yourself"?
A
I don't remember anything in particular
one way or the other.
Q
Okay. But -A
I don't -Q
-- do you know of anything? I'm not
saying, do you remember it? I'm going to say, do you
know of anything?
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A
Outside of the courtroom, I don't know
much about this at all.
Q
I know, but you were in the courtroom.
From anything you know in the courtroom or anything
you know in life, do you know of anything that would
justify that?
A
I can't say that I do, but I don't -Q
Okay.
A
I can't say that I don't either. I
don't know -- I don't know Ms. Murphy. I don't
know -Q
I understand.
A
I don't even know all the accusations
probably. I don't know.
Q
You've been in -- you've been in the
courtroom and you've taken it down and you've heard as
much as Judge Baldwin has heard in the courtroom,
haven't you?
A
I was not there for one of the hearings
that I know of. And I don't know about what -- I
don't know about what didn't happen in the
courtroom.
Q
But if it happened in the courtroom -A
Yes, sir.
Q
-- you're familiar with it?
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CERTIFICATE
I hereby certify that the foregoing transcript
was reported, as stated in the caption; that the
witness was duly sworn and elected to reserve
signature in this matter; that the colloquies,
questions and answers were reduced to typewriting
under my direction; and that the foregoing pages 1
through 135 represent a true, correct, and complete
record of the evidence given.
The above certification is expressly withdrawn
and denied upon the disassembly or photocopying of the
foregoing transcript, unless said disassembly or
photocopying is done under the auspices of Veritext
Legal Solutions, and the signature and original seal
is attached thereto.
Pursuant to Article 10B of the Rules and
Regulations of the Board of Court Reporting of the
Judicial Council of Georgia, I make the following
disclosure: That I am a Georgia Certified Court
Reporter and Registered Professional Reporter, here as
an independent contractor for Veritext Legal
Solutions; that I was contacted by the offices of
Veritext Legal Solutions to provide court reporting
services for this deposition; that I will not be
taking this deposition under any contract prohibited
by Georgia law; and that I am not disqualified as a
reporter for a relationship of interest under the
provisions of O.C.G.A. 9-11-28(c).
This the 8th day of December, 2014.
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18
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23
__________________________________
MARCIA ARBERMAN, CCR-B-1059
***
(Reporter disclosure made pursuant to
Article 10.B. of the Rules and Regulations of the
Board of Court Reporting of the Judicial Council of
Georgia.)
24
25
Page 137
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A
Yes, sir.
Q
Do you know of anything that happened in
the courtroom that would justify her not even knowing
whether they were dead or alive or not?
A
No, sir.
Q
I'm going to let you make a closing
statement. And then if you have more, I'll come back.
A
I don't think I have anything else I
want to say.
Q
He can examine you.
MR. GORDON: I have no questions.
THE REPORTER: Before we go off the
record, I just wanted to ask each attorney if
you want to order the transcript.
MR. FARMER: Yes.
MR. GORDON: Yes.
MR. FARMER: Simultaneous.
THE REPORTER: I wrote "both said yes."
MR. GORDON: She wants to read and sign.
THE REPORTER: Okay.
THE VIDEOGRAPHER: This concludes the
deposition. We are going off the record at
12:42 p.m.
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Murphy v. Freeman
Nan Freeman
INSTRUCTIONS TO THE WITNESS
Please read your deposition over
carefully and make any necessary corrections.
You should state the reason in the
appropriate space on the errata sheet for any
corrections that are made.
After doing so, please sign the errata
sheet and date it.
You are signing same subject to the
changes you have noted on the errata sheet,
which will be attached to your deposition.
It is imperative that you return the
original errata sheet to the deposing
attorney within thirty (30) days of receipt
of the deposition transcript by you. If you
fail to do so, the deposition transcript may
be deemed to be accurate and may be used in
court.
1968318
35 (Pages 134 - 137)

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Murphy v. Freeman
Nan Freeman
ERRATA
----PAGE LINE CHANGE
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
Reason:_______________________________________
___ ___ ________________
1968318
Page 139
1
Murphy v. Freeman
2
Nan Freeman
3
ACKNOWLEDGMENT OF DEPONENT
4
I, ______________________, do
5 hereby certify that I have read the foregoing
6 pages and that the same is a correct
7 transcription of the answers given by
8 me to the questions therein propounded,
9 except for the corrections or changes in form
10 or substance, if any, noted in the attached
11 Errata Sheet.
12
13 __________
________________________
14 DATE
SIGNATURE
15
16 Subscribed and sworn to before me this
17 ____________ day of ______________, 20__.
18
19 My commission expires: _________________
20 ____________________________
21 Notary Public
22
23
24
25 1968318
36 (Pages 138 - 139)

Toll Free: 855.282.1018
Attachment
154, Page 36 of 53
404.817.9606
IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA
Nancy Michelle Murphy,

Plaintiff,
vs.
Civil Action No. 2014CV241705
Nan Freeman and

Freeman 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 1088
LaGrange, GA 30241-1088
Kenbigstar@aot corn
This is notification that at 9:00 a.ni. on Saturday, November 22, 2014, at the
offices of Kenneth Gordon, Esq., located at 5180 Lone Oak Road, Hogansville,
Georgia, counsel for Nancy Michelle Murphy, will proceed to take the deposition
upon 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 of

Freeman Reporting, Inc., pursuant to OCGA 9-11-30(b)(6) and the laws of
Georgia.
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'S
EXH7
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 duly
authorized by law to take depositions and may be recorded by videotaping and by
stenographic 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 proceedings
billed to any entity of the State of Georgia for transcripts produced between
April 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 Murphy
y. Nancy Michelle Murphy, No. 2012-V-413 in the Superior Court of Coweta

County.
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.
Respectfully submitted,
Millard Farmer
Georgia Bar No. 255300
P.O. Box 1728
Atlanta, GA 30301-1728
(404) 688-8116
rnillardfarrner@rnillardfarrner. corn
Counsel for Nancy Michelle Murphy
Page 3 of 4
CERTIFICATE OF SERVICE
I hereby certiFy that I have this day served a copy of the foregoing Notice of
Deposition of Nan Freeman, Individually, and as 30(b)(6) Representative of

Freeman 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 1088
LaGrange, Georgia 30241
Kenbigstar@aot corn
This
13th
day of November, 2014.
aehh' TaM*-
Millard Farmer
rnillardfarmer@millardfarmer. corn
Page 4 of 4
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FREEMAN REPORTING, INC.

Certified Court Reporters
P.O. Box 3387
LaGrange, GA 30241
706-812-8348
September 22, 2012
Federal ID Number: 01-0566702

INVOICE NO. 12-188
Mr. Millard Farmer
Attorney at Law
P.O. Box 1728
Atlanta, GA 30303
DUE UPON RECEIPT

In the matter of: Murphy V.
Murphy, et a!
Jurisdiction: Superior Court of Coweta County
Case Number: 2012-V-4 13
Date; August 30, 2012
One-half of takedow
Original and one copy of transcript
Postage
54.14
328.86
TOTAL
385.00
TRANK YOU
Millard Farmer
Prom:
Sent
To:
Cc:
Julia Harris cjharris@troupco.org> on behalf of Quillian Baldwin

<qbaldwin@troupco.org>
Thursday, June 191 2014 11:26AM
millardfarmer@millardfarmer.COm
Robertson, Beth; freemannd@hotmail.com; Taylor Drake (tdrake@gloverdaViS.Corfl};
eharwell@hbhlawyer.COm
Subject
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 deeply
concerned 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 of
her audio recording of the hearing you are concerned with. As far as I can tell, you are not
legally entitled to the audio recording. However, Nan is willing to turn a copy over of such
recording by placing a sealed copy in the Murphy case, File No. 12-V-41 3, in the Clerk of
Court's Office along with an unsealed copy to be a part of the public record of which you or
anyone 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 except
in open court but that you may review the unsealed recording wherever you would like in
the courthouse. This should satisfy your request. However, you, Mr. King1 anyone on your
staff 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 or
any other proceeding along with the original. Despite what Nan is willing to do, if you file a
law suit against Ms. Freeman, she will not voluntarily give you directly or file with the clerk's
office, copies of said audio recording. Of course, you already have a copy of the transcript
as legally required by law.
We look forward to your immediate response.
i
CERTI FICATE
1
2
STATE OF GEORGIA
COUNTY OF TROUP
I, Nan D. Freeman, being a Certified Court Reporter

5
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
10
11
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.
12
This certification is expressly withdrawn and

13
denied upon disassembly, photocopying or duplication in any
14
manner or upon certification of the foregoing transcript or
15
any part thereof including exhibits, if any, by any person or
16
entity other than by the undersigned official certified court
17
reporter.
18
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
19
below.
20
21
WITNESS my hand and seal at LaGrange, Troup County,

Georgia, this the
5th
day of June, 2014.
22
23
24
Nan D. Freeman, CCR, B-1939
25
42
LARRY KING
ATTORNEY AT LAW
210 North McDonough Street
p . Box 1648
Jonesboro, Georgia 30237
(770) 471-3835
Fax (770) 471-8200
Email larrykingandls@aol.com
June 10, 2014
Via Federal Express

Nathan Thomas Lee and Jerry Ann Conner
County Attorneys for Coweta County
Glover & Davis, P.A.
10 Brown Street
Newnan, GA 30264
Via Federal Express

C. Jerry Willis
County Attorney for Troup County
Willis McKenzie LLP
300 Smith Street
LaGrange, GA 30240
Certified Mail - #7010 0290 0002 1291 9517

Return Receipt Requested
Nan D. Freeman
Freeman Reporting, Inc.
p. 0. Box 3387
LaGrange, GA 30241
Dear Mr. Lee, Ms. Conner, Mr. Willis and Ms. Freeman:.
Pursuant to the prcisibns of the Georgia Open Records Act (0.C.G.A. 50-18-70 et seq.), please
provide 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 civil
action rile number 2012-V-413, Coweta County Superior Court, titled John Harold Murphy y. Nancy Michelle
Murphy.
All documents relating to the supplemental salary paid by Coweta County for Superior Court Judges for
the past three (3) years.
All documents relating to the supplemental salary paid by Troup County for Superior Court Judges for
the past three (3) years.
3,
This firm acknowledges their financial obligation to pay forthe materials requested and will pay upon
receipt of an invoice all fees required for the retrieval and copying of the requested records pursuant to the
Georgia Open Records Act.
The Georgia Open Records Act requires a response time within three (3) business days. . If access to
the records being requested will take longer than three (3) days, please contact ths office with information
about when the records can be expected.
If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal
to release the information. Thank you.
LK/ls
Attachment 5, Page 1 of i

P.O. Box 3387
LaGrange, GA 30241
706-812-5348
June 12,2014
Mr. Larry King

Attorney at Law
P.O. Box 1648
Jonesboro, GA 30237
Re:
Open records request, June 10, 2014

John Harold Murphy vs. Nancy Michelle Murphy
Civil 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 product
of the court reporter for use in producing the transcript of a proceeding. The certified transcript s the
officia] record of the proceeding.
When requested by the panics, transcripts have been produced and a copy provided to each party, with the
original and a copy having been filed in the office of the Clerk of Superior Court in Coweta County.
I have fulfilled my responsibility as required.
Yours truly,
,, j,,
Nan D. l:'reeman
IPLAINTIFF'S
Attachment 6, Page 1 of i
IN THE SUPERIOR COURT OF COWETA COUNTY
STATE OF GEORGIA
JOHN HAROLD MURPHY,

Plaintiff
CASE NUMBER:
vs.
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 3387

LaGrange, Georgia 30241
(706) 812-8348
PROCEEDINGS
2
3
4
[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.]
7
B
10
MR. DRAKE:
MR. FARMER:
Your Honor, may we have an immediate
review for --
11
THE COURT:
12
MR, KING:
13
Thank you.
No.
May we go on the record, Your Honor, and
state that you have not allowed Ms. Murphy to present a
14
defense to this contempt, that you have, as a sanction,
15
transferred custody.
16
has a sanction ever transferred custody of the children.
17
MS. MURPHY:
18
MR. KING:
In no case in the State of Gebrgia
(Unintelligible.)
And we want to put that on the record as
19
an objection to the conduct of the Court and the ruling
20
of the Courtthat has just been made that we have been

We've been denied the
21
denied due process of law.
22
opportunity to present witnesses to this Court about
23
24
25
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
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.
6
7
I told her the last
time -MS. MURPHY:
THE COURT:
10
MS. MURPHY:
11
THE COURT:
I haven't --
Don't -- be quiet, please, ma'am.

(Unintelligible.)
Be quiet.
12
I told her --
13
If you speak up again, I'm going to put you in
14
jail.
Do you understand me?
15
I told her the last time to go see this -- see
16
this doctor, and I told y'all then that if she didn't do
17
it,
18
putting then with her (sic).
19
I told you that the last tine, and I'm tired of this
20
stuff.
21
I was going to consider taking the children and

He (sic) hasn't done it.
If y'all had done what you were supposed to
22
do, if y'all had done your job, if you had done your
23
job, this thing would have been over two years ago.
24
wouldn't have all the expense involved.
25
haven't been doing your job, and you need to be -- you
It
And y'all
2
3
4
6
7
8
need to be checking on that instead of checking on what

I'm doing.
Okay?
You're not doing your job.
All right.
MR. FARMER:
That's it.
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.)
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

P.O. Box 3387
UGrange, GA 30241
706-812-8348
June 5,2014
0:
Federal ID Number: 01-0566702

INVOICE NO. 14-108
rt
(Q-
TO:
Mr. Millard Fariner

Attorney at Law
P.O. Box 1728
Atlanta, GA 30301
DUE UPON RECEIPT
Murphy y. Murphy
Case Number: 2012-V-413
Date: May 27, 2014
In the matter of:
One-half of takedown
One-half cost of tnnscript
TOTAL
THANK YOU
21.65
116.85
$ 138.50

RO. Box 3387
LaGrange, GA 30241
706412-8348
October 16,2013
Federal ID Number: 0 l-0566702
INVOICE NO. 13-148
TO:
Mr. MiHard Fanner

Attorney at Law
P.O. Box 1728
Atlanta, GA 30301
DUE UPON RECEIPT
In tite matter of: Murphy y. Murphy

Case Number: 2012-V-413
Date: October 3,2013
S 352.86
One-half cost oftranscripL
TI-lANK YOU!
PETER J. SKANDALAKIS
LMstrict Attorney
Coweta Judicial Circuit
MONIQUE F. KIRBY
Chief Assistant
UNOA W. liPTON
Victim Assistance Director
August 12, 2014
Millard Farmer
Attorney at Law
p. 0. Box 1728
Atlanta, 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 with
your letter.
I note you have flied, on behalf of your client Nancy Murphy, a civil suit in Fulton County
against Ms. Freeman and against the Program Manager, the Chairperson, and each Member of
the 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 conduct
as set forth in your letter and accompanying documents.
Due to the aforementioned litigation, i am reserving further action concerning this

matter until the civil suit is resolved. Please let me know when your civil case is concluded and
the results of that litigation.
Sincerely,
FL
SaLL
Peter J. Skandalakis
District Attorney
PJS:bwc
8IT
Carroll County Courthouse
PO Box 338
Carroilton, GA 30112
phone: (710) 830-2171
Fax:
(770) 830.2170
Coweta Co. Justice Center

PO Box 1918
Newnan, GA 30264
Phone: (770) 254-7300
Fax:
(770) 254-7305
Heard County Courthouse

Po Box 730
Franldin, GA 30217
Phone: (706) 675-0955
(706) 675-0958
Fac
Medwether County Courthouse Troup Co. Government Center

100 RIdley Ave. SuIte 3500
Po BoxSZO
LaGrange, GA 30240
Greenville. GA 30222
Phone: (706) 298-3708
Phone: (706) 672-1302
Fax:
(706) 298-3709
Fax:
(706) 672-1201
Attachment 155
Guardian ad Litem Billing
Guardian ad Litem Billing
Attachment 155
Attachment 156
Petition for Mandamus
Petition for Mandamus
Attachment 156
IN THE SUPERIOR COURT OF TROUP COUNTY

STATE OF GEORGIA

Petitioner
vs.
Civil Action No. ______________
A. Quillian Baldwin, Jr.,

in his official capacity as
Chief Judge of the Coweta Judicial Circuit
and as Presiding Judge in Civil Action No. 12V-413
in the Superior Court of Coweta County, Georgia,
Respondent
Petition for Mandamus with Memorandum of Law for an
Emergency Motion for Ruling on Mandamus Nisi
1.
Preface
1.1 The developmental years and lives of Jack Murphy, age 15 and
Thomas Murphy who will be age 13 on January 1, 2014, are perishable.
1.1.1
Chief Judge A. Quillian Baldwin, Jr. attempts to defend his political
persona, by wilfully violating the law; this conduct is a violation of the Canons of
the Code of Judicial Conduct and the laws of Georgia that unbalances the scales
of justice.
1.1.1.1
This petition for mandamus is to require Chief Judge Baldwin to
refer to another judge for adjudication the disqualification issues that he ruled
upon on June 7, 2012.
1.1.1.2
This petition for mandamus is to require Chief Judge Baldwin to rule
and otherwise comply with the Uniform Superior Court Rule 25, et seq., the
Canons of the Georgia Code of Judicial Conduct, the appellate decisions and
the law that he refuses to obey related to the pending disqualification motions
that were filed on June 13, 2012, July 2, 2012, August 19, 2013,
Petition for Mandamus with
Emergency Motion for Ruling
on Mandamus Nisi
Page 1 of 52
August
28,
2013,
September
13,
2013,
October
7,
2013
and
November 26, 2013.

1.1.1.3
This Petition for Writ of Mandamus further addresses the
disqualification of Chief Judge Baldwin based upon the violation of Uniform

Superior Court Rule 3.1 et seq. by which Chief Judge A. Quillian Baldwin, Jr.
was available for the Glover & Davis lawyer to select him and Uniform
Superior Court Rule 25 et seq.
1.1.1.4
The procedures for recusal are non-discretionary directives that
Chief Judge A. Quillian Baldwin failed to implement and obey. This Petition
seeks to have Chief Judge Baldwin to comply with the non-discretionary
procedures required by Uniform Superior Court Rule 25 et seq. and to nunc pro
tunc all orders to the date that the orders were originally required.
1.1.2
This Petition seeks to direct Chief Judge Baldwin to fulfill his obligations
under Hargis v. State, 319 Ga. App. 432, 437 (2012), self executing Georgia Code
of Judicial Conduct Canon 3 (E) (1) relating to his and others, acting at his behest,
ex parte, oral and written communications with the lawyers opposing
Michelle Murphy, some of which were contained in the letters to Chief Judge
Baldwin accompanying the Orders that were each prepared by the lawyers
opposing Michelle Murphy. The ex parte communications of Chief Judge
Baldwin include the ex parte communications of those associated with him.
1.1.2.1 The six or more lawyers who oppose Michelle Murphy in various
aspects of this litigation frequently orchestrate litigation gimmicks for Chief
Judge Baldwin to implement. These litigation gimmicks include emergencies

on Mandamus Nisi
Page 2 of 52
when there is no emergency, contempt motions unaccompanied by a Rule Nisi,

or justifiable cause.
1.1.2.2 The problem with defending this barrage of conduct by counsel for
John Harold Murphy, Renee L. Haugerud and the guardian ad litem, Elizabeth
Lisa F. Harwell, is that Judge Baldwin signs off on each of the litigation
gimmicks in a manner that is a violation of the Canons of the Code of Judicial
Conduct and the laws of Georgia.
1.1.2.3
The extensive record in this case was required to ward off the illegal
acts of omission and commission by Chief Judge Baldwin, the guardian ad

litem, Elizabeth Lisa F. Harwell, and counsel for John Harold Murphy and
Renee L. Haugerud.
(References to the Designated Record in this petition are cited by Volume
and page, V__, p. __. Transcripts are cited by date.)
This Petition is supported by the attached Affidavit of Millard Farmer and
two Affidavits of Larry King (or, Alfred Lawrence King, Jr.)(without
attachments). The Designated Record and all transcripts of proceedings
are electronically provided on the attached DVD, along with an index; the
records listed in the index are filed with the Clerk of the Superior Court
of Coweta County.
1.1.3
A writ requiring Chief Judge Baldwin to adhere to Uniform Superior
Court Rule 25, et seq., with all orders issued as the results of this Petition rendered
nunc pro tunc to the day that the order was originally due, can eliminate the
unlawfulness of Chief Judge Baldwin; his current level of defiance of the law
cannot be halted by any other method.

on Mandamus Nisi
Page 3 of 52
1.1.3.1 One sitting, as a witness before an impartial judge by Chief Judge

Baldwin eliminates him from the case by any measure of fairness, as there was
no defense to his lawless misconduct at any stage of the litigation.
1.1.3.2
The problem with the disqualification of Chief Judge Baldwin is that
when he refuses to rule upon the motions for disqualifications, there is no

method to obtain review of that conduct. This petition seeks to mandate an
adjudication on each of the motions to disqualify Chief Judge Baldwin as
required by Uniform Superior Court Rule 25. (Recusal)
1.1.4
This writ of mandamus is the last boundary that can contain Chief Judge
Baldwin before the resources of Michelle Murphy, these childrens custodial

parent since birth, are exhausted and she stands locked behind the doors of the
Coweta County Jail, as she resists the latest attempts by John Harold Murphy and
Renee L. Haugerud to deplete her financial and motherly personal resources. A
person with Michelle Murphys financial resources cannot withstand the
combination of the illegal conduct of Chief Judge Baldwin and being attacked by
these multimillionaire hedge fund operators who wish to add Jack and Thomas as
ornaments to Renee L. Haugeruds 21st life of entitlement. The irony of the
underlying case is that John Murphy only lived in the home until Thomas was 18
months old and Jack was 30 months old before he moved to New York, leaving
in Georgia Michelle Murphy, Jack, now 15, and Thomas, now almost 13.
1.1.4.1
Both the guardian ad litem, Elizabeth Lisa F. Harwell and the
current spouse of John Harold Murphy evade discovery in this case. The
guardian ad litem, a lawyer, evades discovery by lawyering up with another

on Mandamus Nisi
Page 4 of 52
lawyer filing for a protective order that would require Chief Judge Baldwin to
quash. Renee L. Haugeruds lawyer just refuses to allow her deposition.
1.1.4.2
Renee L. Haugerud, a/k/a Lauree Smith, provided a knowingly false
affidavit to Peter A. Durham relating to the real estate interest that she has in
Georgia. This information could be used for the purposes of having the Court
determine that it did not have jurisdiction of her in this litigation, in violation
of OCGA 16-10-20. This affidavit was provided to the Court.
1.1.4.3
Renee L. Haugerud, a/k/a Lauree Smith, interferes with the custody
of the children by transporting the children across the country where they
engage in alcoholic beverage parties.
1.1.4.4
Renee Haugerud, a/k/a Lauree Smith, participated with John Harold
Murphy in using Jack Murphy, Thomas Murphy and one of the childrens
friends, who was transported across state lines, as bartenders who mixed
alcoholic beverages that were served to adult guests at the party, who
participated in this conduct with these minor children.
1.1.4.5
This bartender event occurred before the alcohol poisoning due to
the consumption of vodka by Thomas Murphy, almost age 13, at the residence
of Renee L. Haugerud and John Harold Murphy in 2013 when they were both
in the household.
1.1.4.6
According to the mother of the friend of the children, Jack Murphy
and Thomas Murphy drank portions of the alcoholic beverages that they were
mixing and serving to adults, as these children were not supervised, as required
by law.

on Mandamus Nisi
Page 5 of 52
1.1.4.7
Renee L. Haugerud, a/k/a Lauree Smith participated with
John Harold Murphy in threatening Jack Murphy to sign a perjurious affidavit

relating to his conduct with alcoholic beverages in a location that the children
were transported across the state line in an aircraft under the control of
Renee Haugerud, a/k/a Lauree Smith.
1.1.4.8
This conduct by Renee Haugerud, a/k/a Lauree Smith, and
John Harold Murphy relating to the alcoholic beverages was contributing to the
delinquency of minor children to the extent that the mother of the friend who
made the trip has prohibited her son from traveling any longer in the care of
John Harold Murphy and Renee L. Haugerud, a/k/a Lauree Smith.
1.1.4.9
Renee L.Haugerud, a/k/a Lauree Smith, engages in her conduct of
making false statements in concert with John Harold Murphy to assist him in
his illegal endeavors, in which she has become an active participant. These
endeavors include, but are not limited to, the use of the assets of the Haugerud
Businesses for personal use without paying tax on the value of the asset used
for personal use. This conduct requires false statements by Renee L. Haugerud.
1.1.4.10
Renee L. Haugerud, a/k/a Lauree Smith, engages in concert with
John Harold Murphy in order to deprive Michelle Murphy of the child support
that is due for Jack Murphy and Thomas Murphy.
1.1.4.11
Renee L. Haugerud, a/k/a Lauree Smith, and John Harold Murphy
use an Eight million dollar plus jet airplane to travel between their various
living places and other temporarily leased places throughout the United States
with money originating from the businesses of Renee Haugerud, a/k/a
Lauree Smith.
on Mandamus Nisi
Page 6 of 52
1.1.4.12
One of the media releases posted on April 21, 2010 by Christina
H., identifies Renee L. Haugerud and John Harold Murphy as follows.

February 2009 Renee Haugerud and John Murphy have given $2 million to
the University of Tennessee at Chattanooga. Of the total, $1.5 million has
been given to establish the Renee Haugerud and John Murphy Global
Finance Center at the College of Business. Another $500,000 will go to the
universitys football program. The couple run Galtere Ltd where she is the
managing principal and chief investment officer. He is the chief
development officer. Murphy is an alumnus of University of Tennessee.
1.1.4.13 Renee L. Haugerud controls the company of which John Harold

Murphy is an employee, Galtera, N.A., Inc. and controls the company that owns
the aircraft that is used to remove the children from the State of Georgia. The
following is a photo of the type of aircraft that used to ferry the children.
1.1.4.14
The company of Renee L. Haugerud provides the healthcare
insurance that supplies the health insurance coverage that John Harold Murphy is
required to provide for Jack Murphy and Thomas Murphy under the terms of the
divorce decree.
1.1.4.15
Renee L. Haugerud was present in the household and was the other
adult responsible for the children and their two guests when Thomas Murphy
recently was taken to the hospital after consuming so much of John Harold
on Mandamus Nisi
Page 7 of 52
Murphys and Renee L. Haugeruds vodka that he suffered alcohol poisoning and
required that his stomach be pumped and other medical procedures. John Harold
Murphy also left uncorrected in the hospital records that Renee L. Haugerud was
the natural parent of Thomas Murphy.
1.1.4.16 Counsel for Michelle Murphy has sought on numerous occasions to
take the deposition of Renee L. Haugerud, who is living in the household with
John Harold Murphy. Peter A. Durham, her Glover & Davis lawyer has informed
counsel that he would not allow the taking of her deposition under any type of
agreement.
1.1.4.17
In the event that the Court continues to violate the law and proceed
in any matter in this case, the deposition of Renee L. Haugerud is required and the
deposition expenses should be paid by John Harold Murphy, who initiated this
action.
1.1.5
The information supplied about Renee L. Haugerud is relevant to
understanding the necessity for the disqualification of Chief Judge Baldwin in order
that Michelle Murphy can obtain the information necessary to defend against the
action initiated by John Harold Murphy against her.
1.1.5.1
In contrast to the wealth and financial resources that John Harold
Murphy and Renee L. Haugerud are using in order to torment the lives of
Michelle Murphy and her children, Michelle is a good custodial parent, who
tends to all of the household chores and the childrens school activities while
earning a living as a hairstylist.
1.1.5.2
Michelle Murphy has no political support to provide Chief Judge
Baldwin, her lawyers do not represent Coweta County, which provides a large
on Mandamus Nisi
Page 8 of 52
supplement to the salary of Chief Judge Baldwin, her lawyers do not contribute
around $9,000 to the elections campaigns of Chief Judge Baldwin when he is
unopposed and her lawyers do not represent multimillionaires in this litigation.
1.1.5.3
Even with this disparity in income and assets, Chief Judge Baldwin
required that Michelle Murphy pay John Harold Murphy $5,000 litigation cost
for the last contempt hearing that the Glover & Davis lawyers instigated against
Michelle Murphy and defendants lawyer without a constitutionally required,
due process Rule Nisi.
1.1.6
Since the day that Chief Judge Baldwin issued the August 23, Order that
John Harold Murphy relied upon to have the Deputy Sheriff come to the childrens
home and direct the children to meet John Harold Murphy at a location for him to
begin his newly modified visitation, the children, on numerous nights, have slept
on the floor of their mothers bedroom for fear that their mother would be taken
to jail and they would be taken away by John Harold Murphy. The fear that Chief
Judge Baldwin has brought into this home is a melting away of a perishable time
of the lives of these children.
1.2 Nancy Michelle Murphy (or, Michelle Murphy) requests that Mandamus
Nisi be granted and the Court hold a hearing, pursuant to OCGA 9-6-27, requiring
Chief Chief Judge A. Quillian Baldwin, Jr. to show cause why mandamus absolute
should not issue.
1.2.1
This petition is filed in the Superior Court, as the Supreme Court of
Georgia has decreed, excepting extremely rare circumstances, that a petition for
a writ of mandamus is one that should be filed initially in superior court. Brown
v. Johnson, 251 Ga. 436 (306 SE2d 655) (1983)
on Mandamus Nisi
Page 9 of 52
Gay v. Owens, 292 Ga. 480 (2013)

2.
Respondent
2.1 A. Quillian Baldwin, Jr. is the Chief Judge of the Coweta Judicial Circuit, and,
in particular, the trial judge in Civil Action No. 12V-413 that is pending in the
Superior Court of Coweta County, Georgia. The case is styled as follows.
John Harold Murphy, Plaintiff vs.
Nancy Michelle Murphy, Defendant vs.
Renee Haugerud, a/k/a Lauree Smith, Third Party Defendant
2.2 Chief Judge A. Quillian Baldwin is a resident of Troup County Georgia and
has his permanent office and Administrative Assistant located at the Troup County
Government Center,100 Ridley Avenue, LaGrange, GA 30240.
3.
Petitioner
3.1 Nancy Michelle Murphy is the petitioner who is the defendant in the Superior
Court of Coweta Civil Action No. 12V-413.
3.2 Michelle Murphy, who lives in Coweta County, Georgia is the custodial parent
of Jack Malachi Murphy (or, Jack Murphy), age 15 and Thomas Emerson Murphy
(or, Thomas Murphy), who will be age 13 on January 1, 2014.
3.3 Michelle Murphy is represented in Civil Action No. 12V-413 and in this
petition by Millard Farmer and Larry King.
Millard Farmer
P.O. Box 1728
(404) 688-8116

on Mandamus Nisi
Larry King
P. O. Box 1648
Jonesboro, GA 30237
(770) 471-3835
larrykingandls@aol.com
Page 10 of 52
4. Summary of the Necessity for a Writ of Mandamus

4.1 There is no alternative avenue of legal relief for the detrimental, ongoing
conduct of Chief Judge A. Quillian Baldwin, Jr. engaging in violations of the Canons
of the Georgia Code of Judicial Conduct other than this petition for writ of
mandamus, as the Judicial Qualifications Commission of Georgia is without
authority to remove a judge in a particular case.
4.1.1 It is important to emphasize that the Canons of the Georgia Code of Judicial
Conduct, in part, provide as follows.
Canon 3
Judges shall perform the Duties of Judicial Office Impartially and Diligently
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(l) apply. For example,
if a judge were in the process of apply.
(a) the judge has a personal bias or prejudice concerning a party or a party's lawyer
4.1.2
This canon is self-executing. See, Hargis v. State, 319 Ga. App. 432, 437
(2012).
4.2 The following omissions and commissions by Chief Judge Baldwin are
examples of conduct by Chief Judge Baldwin that cannot be prevented without a
writ of mandamus, considering the cadre of persons participating with Chief Judge
Baldwin in his acts of omission and commission that affect the constitutional and

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statutory rights of Michelle Murphy, and thereby Jack and Thomas, that are also
violations of the Canons of the Georgia Code of Judicial Conduct.
4.2.1
Chief Judge Baldwin refuses to rule upon numerous motions for his
disqualification and obviously refuses to follow the remaining dictates of Uniform

Superior Court Rule 25, et seq. (Recusal)
4.2.2 Chief Judge Baldwin refuses to refer any of the numerous disqualification
motions to another judge for adjudication and to rule upon the constitutional
challenges to Uniform Superior Court Rule 25, et seq.
4.2.3
Chief Judge Baldwin illegally holds counsel for Michelle Murphy and her
counsel in criminal contempt for attempting to present issues for adjudication in

violation of the Canons of the Georgia Code of Judicial Conduct.
4.2.4
Chief Judge Baldwin refuses to allow the court reporter to record the
calendar calls that memorialize the universe of judicial misconduct in violation of

the Canons of the Georgia Code of Judicial conduct by Chief Judge Baldwin.
4.2.5
Chief Judge Baldwin signs Orders relating to the relevant rights of
Michelle Murphy presented to him at times with ex parte communications by

counsel opposing Michelle Murphy, without reading the Orders, in violation of
the Georgia Code of Judicial Conduct.
4.2.6
As the result of signing Orders without reading before signing the Orders,
Chief Judge Baldwin has delegated his authority as a Superior Court judge to a
guardian ad litem that permitted the guardian ad litem to illegally, temporarily
modify custody and thereby illegally attempt to determine the school that the
children were to attend.

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4.2.7
Chief Judge Baldwin denied without a hearing a motion to disqualify a
guardian ad litem who has converted funds to her personal use in violation of
Uniform Superior Court Rule 24.9 (8) (g), and, thereafter allowed that guardian
ad litem, Elizabeth Lisa F. Harwell to select a custody evaluator.
4.2.8
Chief Judge Baldwin has ordered Michelle Murphy to cooperate with a
custody evaluator who requires Michelle Murphy, before discussing any

matters with her, to execute a contract that provides full immunity to the custody
evaluator and not just statutory, bad faith immunity. The e-mail indicating that
the psychologist designated by the Elizabeth Lisa Harwell, the guardian ad
litem, who was called out by counsel for Michelle Murphy for converting trust
funds to her personal use, required that the psychologist would not speak to either
party until the contract was signed follows. The psychologist, upon request from
counsel for Michelle Murphy, refused to communicate with counsel for Michelle
Murphy.
4.2.9
Chief Judge Baldwin ordered Michelle Murphy to be incarcerated until
she cooperated with the custody evaluator, who requires the signing of the
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contract containing, as just one of the repugnant to justice clauses, the following
provision.
4.2.10
Chief Judge Baldwin signs Orders presented to him with ex parte
communications by counsel opposing Michelle Murphy containing false findings

of facts, in violation of the laws of Georgia.
4.2.11 Chief Judge Baldwin engages in judicial conduct that is designed to
defend his disqualification and other conduct in violation of the Canons of the
Code of Judicial Conduct rather than fulfilling the oath required of all civil
officers and the additional OCGA 15-6-6 oath required to be upheld by Superior
Court judges, which follows.
"I swear that I will administer justice without respect to person and do
equal rights to the poor and the rich and that I will faithfully and
impartially discharge and perform all the duties incumbent on me as
judge of the superior courts of this state, according to the best of my
ability and understanding, and agreeably to the laws and Constitution
of this state and the Constitution of the United States.
4.3 Chief Judge Baldwin illegally made himself available for the Glover & Davis
lawyers to select as a judge by participating with other judges in the Coweta Judicial
Circuit in violating Uniform Superior Court Rule 3.1 (case management) by the
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Coweta Judicial Circuit to total absence of a non-discretionary directed case

management plan. This allowed the Glover & Davis lawyer to select Chief Judge
Baldwin as the judge in this case just as the Glover & Davis lawyers selected the
judge from the Coweta Judicial Circuit in Mayor and Aldermen of Savannah v.
Batson-Cook Co. 291 Ga. 114 (2012).
4.3.1
Pursuant to an Open Records request to the Clerk of the Superior Court of
Coweta County (V2, pp. 310-318) for all documentation reflecting the existence
of a Uniform Superior Court Rule 3.1 (case management) plan, Cindy Brown, the
Clerk of the Superior Court, responded that there was no documented case
management plan. (V3, p.447)
4.3.2
Coweta Judicial Circuit Superior Court Judge Louis Jack Kirby instructed
John Harold Murphy about the selection of his lawyer to bring the modification
action against Michelle Murphy. Once Chief Judge Baldwin was placed on notice
of Judge Louis Jack Kirby informing John Harold Murphy about selecting the
Glover & Davis lawyer and placed on notice about the method used to select him,
Chief Judge Baldwin refused to refer a motion for his disqualification based, in
part, on this information from another judge.
4.3.2.1
The guardian ad litem, Elizabeth Lisa F. Harwell, appears
regularly before Superior Court Judge Louis Jack Kirby by representing clients
in divorce cases not related to being a guardian ad litem.
4.3.2.1
The full relief sought in the Petition is required because counsel for
Michelle Murphy cannot appear before Judge Baldwin, as he without any legal
justification has held Larry King, Millard Farmer and Michelle Murphy in
contempt and continually indicates that he will place them in jail. Michelle
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Murphy cannot receive the constitutional right to counsel that she is guaranteed
with the Glover & Davis selected Chief Judge Baldwin presiding. Counsel for
Michelle Murphy also have constitutional guaranteed rights that cannot be
protected with Chief Judge Baldwin remaining in this case, as he is illegally
retaliating against counsel for bringing the disqualification motions and
attempting to protect the rights of Michelle Murphy.
5.
Michelle Murphy and the Children
5.1 The litigation in this case tells the story of Nancy Michelle Murphy, a hairstylist
by trade, and her children, Jack Murphy, age 15 and Thomas Murphy, who will be
age 13 on January 1, 2014, warding off the takeover acquisition of Jack and Thomas
by John Harold Murphy and Renee L. Haugerud, his hedge fund operating,
multimillionaire spouse, who sold short the commodity of children in her early life.
Renee L. Haugerud now feels the need to cover her earlier short sale with the lives
of Jack and Thomas, whom she seeks to have the Court snatch from the mother, who
has dedicated her life to them. John Harold Murphy did not live in the household of
the youngest child, Thomas Murphy, but for only four months before he obtained a
separate residence in another state. The children have expressed a strong desire to
live with their mother, as they have lived their entire lives. It is the failure of Chief
Judge Baldwin that has created turmoil in this familys household by allowing the
Glover & Davis lawyers to select him as the presiding judge in the absence of a
Uniform Superior Court Rule 3.1 case management plan and thereafter refusing to
timely adhere to Uniform Superior Court Rule 25, et seq. (Recusal)
5.2 These children, unlike other commodities that are sold short, cannot be
legally purchased to cover a short sale, even with lawyers who barter their
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judicial political status to effectuate a modification of custody for large legal

fees that these lawyers share in the political/judicial elections bartering proce ss.
5.3 This case is a classic example of politically purchased litigation bullying
by litigants with an enormous disparity of wealth and by Chief Judge Baldwin,
a recipient of in-kind, financially valuable, political benefits. John Harold
Murphy obtained the assistance of his 2006 divorce attorney, now Coweta
Judicial Circuit Superior Court Judge, Louis Jack Kirby, in selecting a lawyer
possessing the local political/judicial bartering status with a Coweta Superior
Court Judge. (V2, p.253) It was Jack Kirby, as the attorney, who represented
John Harold Murphy when he secreted $180,000 in stock option marital assets
from Michelle Murphy during the divorce litigation until after she agreed to a
settlement agreement that was memorialized and approved by Chief
Judge Baldwin, Judge 3 of 5 (V7, p.1294) in the divorce case. (V4, p. 748)
5.4 Judge 4 of 5, who presided at the final decree stage would not open the
settlement agreement memorialized before Judge 3 of 5 after discovery of the
false swearing of John Harold Murphy (V8, p.1651) without a threat of
detrimental consequences to Michelle Murphy.
5.5 When John Harold Murphy sought to obtain a modification of custody, as
guided by Judge Kirby, he employed Glover & Davis, which obtained Chief
Judge Baldwin. This Glover & Davis judge selection effectively exposes that
the Glover & Davis judge selection in Mayor & Aldermen of Savannah v.
Batson-Cook Co., 291 Ga. 114 (2012) was not an anomaly. After the first Court
of Appeals case, Mayor & Aldermen of Savannah v. Batson-Cook Co., 310 Ga.
App. 878, (2011) essentially held there was no error with the Coweta Judicial
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Circuit/Glover & Davis judge-selection, the Glover & Davis lawyers felt
confident in selecting Chief Judge Baldwin to fill their litigation goals. As in
Savannah, this judge selection was again easily accomplished due to the absence
of a Uniform Superior Court Rule 3.1 case management plan. (V3, p.437)
5.6 Chief Judge Baldwin was easily selected for this case by the Glover &
Davis lawyer falsely alleging an emergency with the sworn statement of
John Harold Murphy that Michelle Murphy was planning to move to
South Carolina. The Standing Order in the Coweta Judicial Circuit prevents such
a move, upon the filing of any type of domestic relations complaint witho ut the
feigned emergency hearing on the day that Chief Judge Baldwin was presiding,
which was used by the Glover & Davis lawyer to hand pick Chief Judge Baldwin
for this case. (V1, p.7) The selection of Chief Judge Baldwin occurred when he
was unopposed for reelection but before all of his campaign contributions had
been collected. (V7, p.1419)
5.7 The grievous errors of law, i.e., violation of the Canons of the Georgia Code
of Judicial Conduct, only identify the faade of the obstruction of justice that
has devastated the lives of Michelle, Jack and Thomas Murphy since they
refused to succumb to the Glover & Davis demand on behalf of John Harold
Murphy that the family move to Tennessee to live within ten (10) miles of John
Murphy and Renee L. Haugerud. (V8, p.1567)
5.8 Once privately with Chief Judge Baldwin, twice with affidavits, and on a
regular basis with their father, both children have elected to stay with
their mother.

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5.9 Chief
Judge
Baldwin
has
continually
threatened
and
blamed
Michelle Murphy and her counsel for attempting to exercise the legal right to
have a judge who is not biased, rather than have Chief Judge Baldwin, who
engaged in the following conduct.
5.9.1
Chief Judge Baldwin did not read the opposed Order before signing it that
granted the guardian ad litem unconstitutional authority to modify custody that

the guardian ad litem attempted to use. (V5, p. 901)
5.9.10
Upon motion, Chief Judge Baldwin did not disqualify the guardian ad
litem who did not comply with USCR 24.9(8)(g) when the guardian ad litem
converted funds to her personal (V8, p.1556), a portion of which Michelle Murphy
could ultimately be liable to pay.
5.9.11
Chief Judge Baldwin did not refer his USCR 25 disqualification
motions to another judge, as required; instead, he disputed the facts, with false
statements, in the first disqualification motion. (This was the only disqualification
Order that he entered, or ruled upon.V2, p.306) This mandate seek to have this
first disqualification motion referred to an impartial judge for a hearing, as
Uniform Superior Court Rule 25, et seq. required, but Chief Judge Baldwin
refuses to do.
5.9.12
Chief Judge Baldwin also designated this law-breaking guardian ad
litem, whom Michelle Murphy had attempted to disqualify due to her illegal
conduct, to select a custody evaluator. (V14, p. 2752) The contract of the custody
evaluator requires Michelle Murphy to be liable for large sums of money,
expensive litigation costs and to grant the evaluator, not just bad faith immunity,
but full immunity (V12, p. 2308) before the custody evaluator will even discuss
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the methods to be used for the evaluation. The custody evaluators contract
created a financial liability for Michelle Murphy that was not in the best interest
of the children. The custody evaluator is just another litigation scheme of the John
Harold Murphy lawyers after their selected judge, Chief Judge Baldwin, their
selected guardian ad litem and their expert psychiatrist witness each crashed and
burned when their misconduct ignited them.
5.9.13
The guardian ad litem, an attorney, obtained counsel who filed for a
protective order that has prevented the deposition of the guardian ad litem, who
has provided no financial records to counsel. (V12, p.2378, V13, p.2596)
5.9.14
Chief Judge Baldwins threats most frequently involve warning
Michelle Murphy, the party without adequate financial resources, about the
possibility of not being able to recover the attorney fees necessary to defend the
attempted takeover, modification action of these multimillionaires. Another
example follows.
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 I'm going to award any attorney's
fees, you know, to cover any of this stuff.
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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)
5.9.15 As the case progressed and Chief Judge Baldwins expressed the belief
that the Court of Appeals dismissal of the case provided him a safe harbor for
his conduct, Chief Judge Baldwin began threatening both Michelle Murphy and
her counsel with his, Ill put you in Jail, loud ultimatums, as occurred when
counsel attempted to have a calendar call taken down by the court reporter as a
part of documenting issues of the courts deviation from a USCR 3.1 case
management plan.
(Counsel for the parties and the guardian ad litem
came forward for a bench conference.)
THE COURT: Im telling him that Im not going to take
the whole calendar down on the record, that I will
take this down. And I will make sure that everybody
thats involved is here, is called, and its on the
record as to whether theyre here or not here. And if
theyve got any kind of objections or motions, any of
that kind of stuff will be taken down. But Im not
going to take down everything; on the calendar call,
Im not going to put everybody else called. That has
no bearing on his case whatsoever.
MR. FARMER: Your Honor, I am the person that makes
the determination of what are the issues in the case,
and I
THE COURT: No. I am the person that makes the
determination, and Im clear on that on the law. Now,
go have a seat, and Im going
MR. FARMER: Can you tell me what the law is that
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youre following?
THE COURT: Yeah. Im following the law that we say
every day. I decide what the issues are. Okay? Go have
a seat.
MR. FARMER: But Im entitled to preserve them, Your
Honor.
THE COURT: Youre entitled to preserve the issues of
your case.
MR. FARMER: My case.
THE COURT: And Ill be more than glad to do it.
MR. FARMER: My case.
THE COURT: Look, look.
MR. FARMER: My case deals with the way you call the
calendar.
THE COURT: Look, look, Millard. Dont argue with me.
Understand?
MR. FARMER: I just want to make sure the record is
clear.
THE COURT: If you keep arguing with me, now, Im going
to put you in jail. Im not going to mess with you
anymore. Okay? And I dont care. You can jump up and
down all you want, and you can make all the noise you
want to make, but you keep messing with me, and Im
going to put you in jail.
Do you understand me? Do you understand me?
Do you understand me? (Tr. Aug. 6, 2013) (V10, p.1929; V12
p.2327)
5.9.16
The jail threats of Chief Judge Baldwin on August 13, 2013, culminated
with a speech to Michelle Murphy that she was subject to being put in jail if she
did not physically force the fifteen and nearly thirteen year old children to visit
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with John Harold Murphy according to the terms of the 2008 divorce decree and
his modified conditions of the Standing Order. In parts, the speech was as follows.
I am ordering you to make them go. I don't care whether they jump up and
down, scream and holler, lock themselves in their room. Whatever they do,
you have got to make them go. Do you understand that?
* * *
If you don't do what I tell you to do -- and I'm telling you to see that they
go; I'm not giving them the option and I'm telling them they've got to go.
But if you don't do that, I'll put you in jail.
* * *
THE COURT: All right. Now, so he gets to see them whenever hes
supposed to see them. He can take them to Russia if he wants to during
that time. But he's got to have them back on time. (Tr. Aug. 13, 2013, p.
259; V11, pp.2080-81)
5.10
The ex parte obtained August 23, 2013 Order followed the August 13,
2013 modification of custody, i.e., visitation pronouncement at the hearing

where counsel for Michelle Murphy was not allowed to complete
cross-examination of John Harold Murphys impaired witness and Michelle
Murphy was prevented from producing any of her witnesses. See, Tr. Aug. 13,
2013, pp. 274, 276.
5.11
Chief Judge Baldwin, on October 3, 2013, after being served with a
Notice of Supersedeas and Plea as to the Absence of Jurisdiction and

Unconstitutional Due Process Nature of the Alleged Contempt Actions (V14,
p.2810), while admittedly mad, had Larry King taken into custody by the
Deputy Sheriff and arrested for contempt and fined $1,000 for attempting to
explain the motion addressing supersedeas, jurisdiction and the law of contempt.
(Tr. Oct. 3, 2013, pp. 7, 112; V14, p. 2850) That first, I was mad, contempt
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Page 23 of 52
was withdrawn, and another contempt and $1,000 fine imposed on Larry King
at the end of the October 3, 2013 hearing. (Tr. Oct. 3, 2013)
5.12
The oral pronouncement of indirect criminal contempts for alleged
conduct not in the presence of the Court and not proven beyond a reasonable
doubt, occurred at the October 3, 2013 hearing, at which neither Michelle
Murphy nor Millard Farmer were present, as there was no subpoena or Rule Nisi
requiring that they be present at the contempt hearing based upon the August 23,
2013, ex parte Order on appeal that resulted after the August 13, 2013 hearing,
where Michelle Murphy was not allowed to present evidence. Shore v. Shore,
253 Ga. 183 (1984). Chief Judge Baldwin stated:
But I am going to hold her in contempt and find
shes in contempt for not having them ready on
time.[Michelle Murphy allowed Thomas to shower and remove his
football practice uniform when he returned home from school. To
accommodate for this 30 minute delay, the driver for John Murphy returned
the children home 30 minutes late]
Also, its obvious that these -- this case was
discussed with the boys. And while I indicate the
parties
are
not,
the
attorneys
are
their
representatives and their agents, and they are bound
by such instructions, I believe, so Ill say shes
in contempt for that reason.
[Jack and Thomas Murphy provided affidavits to support that their mother
was not in contempt relating to visitation and their desire to remain with the
divorce decree custodial parent, their mother.
The affidavits also establish the change in visitation with the August 23,
2013 modification order. (V14, p. 2711)]

on Mandamus Nisi
Page 24 of 52
And Im also going to hold her in contempt for not

appearing at this hearing. If she had been here,
we could have resolved a lot of these issues.
[Michelle Murphy was provided no Rule Nisi or subpoena requiring her to
appear and answer to the charges of criminal contempt, as detailed by Larry
King to Chief Judge Baldwin when he first held Larry King in criminal
contempt.]
So what Im going to do is, Im going to hold her
in willful contempt of court for the reasons I just
stated, and Im going to let her purge herself -Im going to order her confined to the Coweta County
Jail until she purges herself from contempt by
complying with the order to cooperate with the
custody evaluation, [which required signing the contract] and
that she do so.
Im also going to require her to pay five thousand
dollars in attorneys fees [Requirement to pay attorney fee
awarded for the contempt hearing, without showing basis for fee with
payment due before released from jail is illegal See, Horn v Shepherd 292
Ga. 14 (2012)]
Now, shes got to do these things before shes
released -- and -Well, theres never been a fee
about how much he has paid to have to -- other than
attorneys fees -- and has paid the evaluator, but
were eventually going to have to talk to that
evaluator, and Ill deal with that at another time.
Im also -- Im sorry, Mr. King, but I believe
that you and Mr. Farmer should have required this
lady to be here. I know of no reason she couldnt
be here. So the -- so Im going to hold yall both
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in contempt. Again, Im going to fine you a thousand

dollars.
Im going to order you confined to the
jail until you pay a thousand dollars. You can pay
it now if you want to, and Ill have to draw up an
order about that.
Im also going to order Mr. Farmer -- Im going
to find him in contempt for not having his client
here, and also, because he evidently discussed this
case with these boys as his client was instructed
not to, and, evidently, it was all done in front of
him and his mother and Mr. Farmer, and so Im going
to order Mr. Farmer -- hold him in contempt, order
him confined to the Coweta County Jail until he
either -- until he purges himself by paying a
thousand dollars to the Court.
5.13
The errors of law in the case are easily defined; the more devastating
obstructions of justice designed to create large litigation costs to this mother in

order to defend the hostile takeover of her children are embedded in the
combined, continuous errors of law and judicial bullying threats by Chief Judge
Baldwin that are all-encompassing denials of due process, each of which is
violation of the Canons of the Georgia Code of Judicial Conduct that require
that Chief Judge Baldwin initiate the required first step for Michelle Murphy to
have the protections afforded to her by Uniform Superior Court Rule 25, et. seq.
5.14
As toxic as the bullying threats of Chief Judge Baldwin are, they do not
create the devastation that the read-without-signing, Glover & Davis prepared,
Orders of Chief Judge Baldwin create, reflecting only advocacy by Chief
Judge Baldwin against Michelle Murphy for his political bartering power and
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Page 26 of 52
retaliation, rather than being judicial decisions. The Orders abrogated judicial
authority to the lawyers.
5.15
There are two prime examples of the sign-without-reading, detrimental
effect of the Glover & Davis prepared Orders. The first example is the initial
appointment of the guardian ad litem Order that included content, about which
Chief Judge Baldwin had no idea. Tr. Nov. 15, 2012, p. 33, l. 13- p. 34, l. 35.
MR. FARMER: [to GAL] Have you put that money into
your personal account?
MS. HARWELL, [GAL]: 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 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.
Page 27 of 52

on Mandamus Nisi
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 [During the divorce, it meant that the
agreement before Judge 3 of 5, Baldwin, was different when it was
finalized before Judge 4 of 5 Judge Blackmon (V2, p.202]
5.16
The second prime example is the August 23, 2013 Order
(V11, p. 2187).
6. The Motion for Contempt of John Harold Murphy Documents the
Modification of Custody i.e., Visitation that the Glover & Davis Lawyer Had
Chief Judge Baldwin Order in his ex parte August 23, 2013 Order
6.1 This overtly seemingly trite matter is relevant to demonstrate that this is
one of the two ways that Chief Judge Baldwin modified the custody, i.e.,
visitation, when the ex parte letter (V15, p. 3005) was hand delivered with the
August 23, 2013 proposed Order, which was signed without reading.
6.2 The Glover & Davis lawyers wished to modify custody, i.e., visitation, to
accommodate the travel to Paris, France of John Harold Murphy and Renee L.
Haugerud and the speech, one visitation weekend later, of John Harold Murphy
to the UT Chattanooga Mocs football team. (V13, p. 2617) John Harold Murphy
Page 28 of 52
on Mandamus Nisi
and Renee L. Haugerud wished to display Jack and Thomas Murphy at the Mocs
speech. In the Motion for Contempt filed on August 28, 2013, after the August
23, 2013 Order was executed, John Harold Murphy swore (V11 p.2219)
supported by the Glover & Davis lawyers, that the weekend of August 16-18,
2013 was John Harold Murphys designated alternate visitation weekend (V12,
p. 2244). He sought to have Michelle Murphy held in contempt for not allowing
him visitation on that weekend, when, in actuality, he had excused the children
from having to travel to St. Thomas, where he was on Friday, August 16, 2013.
6.3 Jack Murphy, the 15 year old child, recorded the phone conversation with
his father on Friday, August 16, 2013 documenting that the children were
excused from visiting with him on that weekend (V14, p. 2744)
6.4 In order to modify visitation while attempting to shield the August 23, 2013
Order from appellate review, the Glover & Davis lawyer included the absolutely
contradictory statement, The physical custody of the children shall not be
changed at this time (V11, p. 2191). The statement is a self-serving defense of
the Glover & Davis lawyer, as Chief Judge Baldwin never read the ex parte
obtained August 23, 2013 Order. (V11 p.2214)
6.5 Chief Judge Baldwin defends the ex parte letter which accompanied the
proposed Order as follows.
THE COURT Im just tired of things -- Like I
noticed in this thing yall talk about some kind
of ex parte conversations. I dont think I have
had any ex parte conversations with Mr. Drake
about this anytime lately if I ever had any. I
dont think, since the beginning of this case I
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Page 29 of 52
have, partly because of all the stuff thats been

going
on
in
the
State
about
ex
parte
conversations. I used to talk to lawyers about
setting cases up and stuff like that. Now, I dont
do that; I get my secretary to do that, or my
clerk to do that. And I dont believe I have had
any ex parte conversations, and I dont see how
yall could know about any unless you supposedly
have my phones bugged or his phone bugged.
But, you know, its stuff like that that yall
put in these things that are absolutely untrue,
and Im fed up with it.
MR. KING: Chief Judge, the letter that was
submitted to you, the August the twenty-third
order,
from
Mr.
Drake
was
an
ex
parte
communication.
*
*
*
But those things are untrue. Yall said so many
untrue things about me, as well as other people,
but I know about me, in that first recusal that
you filed, it was just unbelievable.
Tr. Oct. 3, 2013, p. 15, l. 5- p. 16, l. 14 *
*
*
MR. KING:
Could I speak on the ex parte communications?
Its at page thirty-two of thirty-five of our
response. This is the letter that was submitted
to you, Judge Baldwin:
Also enclosed is an email I received from
the football coach at Arnold Middle School
detailing, contrary to what Ms. Murphy
represented to you under oath in court, he
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Page 30 of 52
is not aware of any practices involving any

player on his team on Saturday morning or
any other time during this weekend. [The letter
continued with a false statement about visitation that
contradicted the affidavit of Michelle Murphy (V14 p.2755)
(V15 p. 3042) that would have been available through her
testimony if Chief Judge Baldwin had allowed her to present
evidence.
6.5.1 That was an ex parte communication.
THE COURT: Well, let me just tell you this. I
didnt solicit the ex parte communication. I cant
do anything about what people write me.
Tr. Oct. 3, 2013, p. 119, l. 12- 25 emphasis supplied
7. The Illegal Conduct of Chief Judge A. Quillian Baldwin, Jr. Deprives
Michelle Murphy of her Right to Counsel that only the Writ of Mandamus can
Prevent by Requiring Chief Judge Baldwin to Follow the Law
7.1 Michelle Murphy is being deprived of her right to counsel in both the
underlying Civil Action No. 12V-413 Complaint for Modification of Custody, or in
the Alternative Parenting Time (or, Complaint for Modification) brought against
her by John Harold Murphy and in being defended of charges for criminal contempt
brought against her by John Harold Murphy.
7.2 Chief Judge A. Quillian Baldwin, Jr. deprived and continues to deprive
Michelle Murphy of her right to effective representation by her counsel, Larry King
and Millard Farmer, who are being subjected to charges of criminal contempt by
Chief Judge A. Quillian Baldwin, Jr. to the extent that the conduct of Chief Judge
Baldwin interferes with the right of Michelle Murphy to counsel and interferes with
the custodial obligations of Michelle Murphy to her children, Jack Murphy and
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Thomas Murphy. See, October 3, 2013 Transcript and the Affidavits of Larry King.
V14, p. 2832; V16, p. 3478
8.
The Law that Chief Judge Baldwin Refuses to obey
8.1 Chief Judge Baldwin dogmatically refused and maintains that he will not obey
Uniform Superior Court Rule 25, et seq., that dictates the conduct of Chief Judge
Baldwin which he refused to obey, and is as follows.
25.3. Duty of the trial judge
When a judge is presented with a motion to recuse, or disqualify,
accompanied by an affidavit, the judge shall 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. If it is found that the
motion is timely, the affidavit sufficient and that recusal would be
authorized if some or all of the facts set forth in the affidavit are true,
another judge shall be assigned to hear the motion to recuse. The
allegations of the motion shall stand denied automatically. The trial
judge shall not otherwise oppose the motion. In reviewing a motion to
recuse, the judge shall be guided by Canon 3(E) of the Georgia Code of
Judicial Conduct
8.2 Instead of ceasing to act, Chief Judge Baldwin, on the occasion of the first
motion to disqualify him, denied the motion by opposing the affidavit, falsely stating
that the affidavit was incorrect. Chief Judge Baldwin did not refer that first motion
to
another
judge
for
adjudication
of
the
facts
that
he
opposed.
See, Isaacs v. State, 257 Ga. 126 (1987); Birt v. State 256 Ga. 483 (1986).
8.3 On each of the following motions for his disqualification, Chief Judge Baldwin
refused to rule on the motions, including the constitutional challenge to Uniform
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Superior Court Rule 25, et seq. That refusal to rule upon the disqualification motions
is one of the bases for this petition.
8.3.1
Chief Judge Baldwin didnt just refuse to rule upon the disqualification
motions; in open court, Chief Judge Baldwin proclaimed as follows. [Under Chief
Judge Baldwins view, he is above the reach of the law]
And Im not going to recuse myself. Ill tell
you right now, Im not going to recuse myself.
And Im going to put in there -- because yall
have already had your chance on recusal. Its
been appealed. They upheld me staying in this
case and not recusing myself. And were just
going to keep it like that.[emphasis supplied] (Murphy v.
Murphy, 747 S.E.2d 21, 2013 Ga. App, granted Cert Petition,
S13G1651)
8.3.1.1
The they upheld me proclamation of Chief Judge Baldwin was
only a dismissal of an appeal because the legislature amended OCGA 5 6-34

(a)(11) while an appeal of Chief Judge Baldwins disqualification motion was
pending. The Supreme Court of Georgia has accepted a petition for writ of
certiorari to decide if the legislature could vacate jurisdiction once a case was
pending before an appellate court. This grant of the certiorari case does not
resolve the issues in this petition.
8.3.1.2
Chief Judge Baldwin began escalating his defiance of the Uniform
Superior Court Rule 25.3 Duty of a Judge by making threats to Michelle

Murphy that she would not be provided the financial assistance to repel the
attack upon her by John Harold Murphy, Renee L. Haugerud and Chief Judge
Baldwin.
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Now, I dont know if your client is paying you.

Yall may be eating all this stuff. But Ill
tell you what. Because of all this stuff, Im
unlikely to give you any attorneys fees so
yall are working on this thing on your own
money if youre doing all of this. [Oct. 3, 2013 Tr.pp.
17-18,emphasis supplied]
8.3.1.3
The threat to Michelle Murphy about not awarding her attorney fees
to defend the attack of John Harold Murphy and Renee L. Haugerud upon her
and the children occurred on more than one occasion. On another occasion,
Chief Judge Baldwin warned as follows.
[Millard Farmer] And if we're going to be placed
on trial for the whole whatever he claims this
morning, we have to have notice of the issues,
and he has to provide a sworn statement in
support of his motion which he's never done.
That's what he doesn't do with any of his
motions. He doesn't follow Uniform Superior
Court Rule 6.1 and the particular provisions of,
quote,
unquote,
classifying
something
as
emergency.
These children are in school; the children are
on their medication, and they're in public
school. Now, they are not, as Ms. Harwell wanted
them, transferred to the father in Atlanta who
lives in
Chattanooga,
but
has
a
condominium in Atlanta. And the mother has a
right to have them in a school she can afford.
He didn't want to provide the
transportation, and we tried to get them to
provide

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THE Court All right But look, look Just have a

seat a minute. Have Mr. Murphy and you have Ms.
Murphy come up here.
(The parties came forward and sat with their
respective counsel.)
THE COURT: You know, if anybody's obstructing
anything, it's you, Mr. Farmer.
Now, I'm talking now so dont interrupt me.
If anybody is obstructing anything, it's you.
And you may have a right legally to do the things
that you're doing. But if y'all don't have
anything to fear, if everything is okay, there's
no reason to do those things.
If our client is being the mother that she should
be, providing the children with -- I don't know
anything about what they're claiming about her;
okay?
I haven't gotten that far; I
haven't read anything about that
I don't know what they're claiming about her.
All I know is, is you don't pull all these stunts
that you're pulling -- that you can legally do.
We all have those kinds of things You know, one
of the most common things is asking for a jury
trial to delay things when it's either not going
your way or you want to drag it out. I've done
the same thing as a lawyer. So I'm not -- you've
got a right to do those things. But there's no
reason to do them if everything is okay, which
makes the thing look suspicious.
Tr. August 30, 2012, pp. 13-14.
8.3.1.4
Chief Judge Baldwin, later on the same day continued as follows

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Page 35 of 52
I have thought about this if y'all want to. I

hate to tell you, Mr. Farmer, but one of the
reasons you know, the easy thing to do, for most
judges, whether they think there's grounds for
recusal or not, is just capitulate and recuse
yourself and put it on some other judge. But one
thing, you had indicated that you were going to
try to recuse nearly everybody within a hundred
miles that tried to take up this case.
MR. FARMER: That's an exaggeration.
THE COURT: Well, maybe it was fifty miles; excuse
me.
MR. FARMER: No, we
THE COURT: Okay. But I'm trying to say
MR.FARMER: Trying to keep from violating Rule 3.1
THE COURT: Wait, wait, wait, wait, wait, wait.
You had indicated anybody in this circuit you
were going to try to recuse because of our method
of assigning cases. And so it didn't seem like
it seemed like, one thing, that the delay was
going to be constant. So I thought that was
probably a quicker way of dealing with it, plus,
I didn't think you had Now, we're not going to
argue about that. I personally did not think that
here were any grounds to recuse me. Some of the
things you said in there were absolutely untrue
about me, which I didn't appreciate. And I
pointed that out in the thing. They weren't
grounds for recusal, and I hadn't violated the
Code of Judicial Ethics, and things like that. I

on Mandamus Nisi
Page 36 of 52
don't care if you put stuff in that are

legitimate.
So, you know, I didn't take the easy way; I took
the hard way. But I thought it was probably the
most direct way of dealing with this since you
had made these comments about recusing. Now,
you've filed this thing to recuse Judge Keeble,
and he hasn't had anything to do with this case.
I don't even know how you can have it filed to
recuse a judge that hasn't even been involved in
the case. I didn't even read the thing. I saw
it, and I looked at it.
MR. FARMER: You should read it, Your Honor,
before you make that statement. There are
personal reasons to disqualify Judge Keeble that
are included in there.
THE COURT: Well, but he's not in the case. I
don't know how you can recuse somebody when
they're not in the case. But that's all right.
I'm --I'm not going to worry about that.
MR. FARMER: He gets in the case because Mr. -Glover and Davis's lawyers have moved for him to
have a hearing in this case on the twentieth to
strike certain grounds that are contained in the
pleadings.
THE COURT: I haven't seen that.
MR. FARMER:
I know. That's the reason I'm
telling you.
MR. DURHAM: Your Honor, Peter Durham on behalf
of I'm representing Renee Haugerud who is Mr.
Murphy's current wife. Ms. Haugerud got pulled
in as a third party defendant. That's a motion
Page 37 of 52

on Mandamus Nisi
to dismiss her from this case because she doesn't

belong in here anyway.
That has nothing to do with the custody of these
kids.
MR. FARMER: It does because you're attempting to
strike part of the pleadings filed on behalf of
Mr. Murphy.
THE COURT: All right. Look, look. Look, I'm not
making a decision about that; okay? I'm not the
one to make a decision about whether Judge Keeble
should be recused. I'm not making a decision
about their motion to dismiss the case against
Ms. -MR. FARMER: Haugerud.
THE COURT: Anyway, whatever her last name is.
And so that's not here. I did wonder -- I still
have my doubts about -- on one hand if there's
truly an emergency situation that these kids are
in danger or that kind of thing. Something has
to be done.
And I can tell you, when this is over with, when
I'm out of this, I'm going to have a discussion
with some of the members of the Supreme Court
that we need to look at these recusal rules and
at least have something that covers this type of
dilemma that we're in. I doubt that it comes up
very often.
But if there's truly some kind of thing that
something needs to be done for these young men
right now, then, you know, I don 't know how we
're going to deal with it because -- but I know
Page 38 of 52

on Mandamus Nisi
that -- Didn't Judge Blackmon sign the divorce

decree or something in this thing?
MR. DRAKE: Yes, sir.
THE COURT: After they had done the thing?
So, you know, one of the things, I reckon we
could do, but y'all would have to agree to it,
is just let me get out of the case and let Judge
Blackmon take it from here on and make a
decision. But y'all would have to agree, if we're
going to do that, to just move on and not be
filing any of these technical things like motions
to recuse and everything. He doesn't have a dog
in the fight. I'm sure he doesn't know these
people.
Transcript August 30, 2012, pp. 18-21.
8.3.1.5
Chief Judge A. Quillian Baldwin, Jr. is required by Uniform Superior
Court Rules 25, et. seq., OCGA 15-6-6, his oath of office, the decisions of
the Supreme Court of Georgia and the Court of Appeals of Georgia, to adhere
to the dictates of the following Uniform Superior Court Rule.
25.3. Duty of the trial judge
When a judge is presented with a motion to recuse, or disqualify,
accompanied by an affidavit, the judge shall 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. If it is found that the
motion is timely, the affidavit sufficient and that recusal would be
authorized if some or all of the facts set forth in the affidavit are true,
another judge shall be assigned to hear the motion to recuse. The
allegations of the motion shall stand denied automatically. The trial
Page 39 of 52

on Mandamus Nisi
judge shall not otherwise oppose the motion. In reviewing a motion to

recuse, the judge shall be guided by Canon 3(E) of the Georgia Code of
Judicial Conduct.
The Order, nunc pro tunc to August 13, 2013, by Chief Judge Baldwin is
Relevant
August 13, 2013 hearing, Michelle Murphy was not allowed to
present available evidence (Tr. Aug. 13, 2013, p. 274, lines
7-14, p, 276, lines 23-24).
See, Shore v. Shore, 253 Ga. 183 (1984)
August 16-18, 2013 was date of premodification, alternative
visitation weekend for John Harold Murphy (V14 p. 2698).
August 23, 2013 was the newly modified August 23, 2013
ordered first weekend of visitation for John Murphy. Also, no
Standing Order restriction (V14 p. 2699)
August 23, 2013 Order executed that was based upon ex parte
letter that Glover & Davis hand delivered with the Glover &
Davis prepared Order and the August 13, 2013 aborted hearing
that modified the Standing Order. (V11, p.2187).
September 23, 2013 Notice of Appeal of August 23, 2013
Order (V14, p. 2774).
September 27, 2013 Contempt Motion w/o Rule Nisi, filed
based upon August 23, 2013 Order (V14, p. 2774)
October 3, 2013 hearing on September 27, 2013 Amended
[indirect] Contempt motion that was based upon August 23,
2013 Order modification of custody, i.e., visitation. See, Shore
v. Shore, 253 Ga. 183 (1984) and its progeny. (Tr. Oct 3, 2013
Hearing) At that October 3, 2013 hearing, Chief Judge Baldwin
began holding the mother and the lawyers in indirect contempt
of court.)

on Mandamus Nisi
Page 40 of 52
8.3.1.6
Disqualification motions were pending against Chief Judge Baldwin
at all times. (V14, p. 2774) (V1, p.28; V2, p.188; V3, p.436; V10, p.1904; V11,
p.2195; V14, p.2890; V17, p.3639) Chief Judge Baldwin only denied the first
of the motions by opposing that initial disqualification motion with false
statements. (V10, 1935) See, Isaacs v. State, 257 Ga. 126 (1987), Birt v. State
256 Ga. 483 (1986).
9.
Additional Statement of the Underlying Case and Issues
John Harold Murphy, a resident of Tennessee, initiated this case against Nancy
Michelle Murphy with a Complaint for Modification of Custody, or in the
Alternative, Parenting Time. (V1, p.1) Michelle Murphys responses include her
Defenses, (V7, p.1290) Counterclaims, (V7, p.1336) Third Party Complaints
against Renee L. Haugerud (V7, p.1349), demand for jury trial (V1, p.132) and
Motions, as modified, to Disqualify Chief Judge A. Quillian Baldwin, Jr. (V1,
p.28; V2, p.188; V3, p.436; V10, p.1904; V11, p.2195; V14, p.2890).
9.1 The disqualification conduct of Chief Judge Baldwin and his violation of
USCR 25 is the all-encompassing, precipitating cause of this writ, as
Michelle Murphy has no other avenue for relief of the conduct of Chief
Judge Baldwin, who simply refuses to adjudicate the motions for his
disqualification.
10. Constitutional Infirmity of USCR 25 The conduct of Chief Judge
Baldwin in this litigation illustrates the consequence of the facial
unconstitutionality of Uniform Superior Court Rule 25 (Recusal) that is the
Georgia Uniform Superior Court Rule mandated, catch me within five (5) days
with an oath without using hearsay
on Mandamus Nisi
substitute for a constitutional, less
Page 41 of 52
procedurally restricted, judicial disqualification procedure that does not shield

a judge, i.e., trier of fact, from being questioned under oath about the trier of
facts disqualification and that can provide the movant protections accorded by
Ga. Const. Art. I, I, Para. X; Ga. Const. Art. I, 1; 1; Ga. Const. Art. I, 1,
2; United States Due Process and Equal Protection rather than
unconstitutionally subjecting aggrieved litigants to the detrimental, procedurally
required delays permitted by USCR 25 under the May 6, 2013 enacted version
of OCGA 5-6-34(a)(11) and the overruling by the Court of Appeals of Georgia
of the supplementary protection provided by the doctrines of Braddy v. State,
316 Ga. App. 292 (2012).
10.1
Establishing the facial unconstitutionality of USCR 25 et. seq. requires
no evidence.
10.2
The facial constitutionality, vel non of USCR 25 is to be adjudicated
under the existing procedural restrictions and other statutory and binding
decisions that weigh upon USCR 25 passing facial constitutional muster.
10.3
USCR 25 and the Disqualification of Chief Judge Baldwin USCR 25
now leaves Michelle Murphy burdened with the political, judicial bartering
conduct of a judge/trier of fact with biases and prejudices against her and her
counsel created by Chief Judge Baldwins refusal to refer his challenge to
another jurist. Any judge/custody trier of fact, even a knowledgeable Attila the
Hun, who, by modifying vel non custody for any period of time, can destroy the
lives of children before the bias of the judge/trier of fact can be reviewed by
another jurist or before the judge/trier of fact can even be voir dired to establish
a record of the trier of facts bias or other impediment to being a trier of fact.
on Mandamus Nisi
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10.4
The Chief Judge Baldwin standard of, catch-me-if-you-can, before-I-put-
you-and your lawyer in-the-can-and-thereby-weaken-you-into-submission,

prioritizes Chief Judge Baldwins political, i.e., financial and social interests
over the best interest of these children. This, Ill get you if you challenge me,
judicial misconduct, identifies the absence of an USCR 25 constitutional
enforcement mechanism. The value of being able to voir dire a challenged jurist
is coincidentally included in the record of the underlying case in response to a
challenge to counsel for Michelle Murphy. The 1977 transcript of the testimony,
also preserved on an audio tape, of the trial judge of William Henry Furman,
Furman v. Georgia, 408 US 238, taken when that judge was assigned as judge
in another death penalty case before USCR 25 was enacted, shows the value of
the voir dire of a challenged jurist, who maintains his absence of any bias. (V5,
pp.980, 1064) That testimony would never have been available under the five
day required oath, procedural noose of USCR 25.
10.5
No person could serve as a trier of fact on a jury, even diluted with eleven
other triers of facts, after making the threats that Chief Judge Baldwin made and
engaged in his conduct. USCR 25 tolerated Chief Judge Baldwin participating
in the Coweta Judicial Circuits failure to adopt and adhere to a USCR 3.1 case
management plan. (V2, p. 329) This refusal to adopt and enforce a USCR 3.1
plan permitted Chief Judge Baldwins selection by the Glover & Davis lawyer
in this case and Judge Lees selection in Savannah, infra.
10.7
Even if a judge is eventually disqualified during the appellate process,
after destroying an important portion of the developmental stages of the

childrens lives, the remaining status of the destructive, disqualification
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litigation can leave the emotionally and financially debilitated family in the due
process deprivation, appellate trap that results with a City of Mayor & Aldermen
of Savannah v. Batson-Cook, 318 Ga. App. 152 (2012) type of remand that
amounts to a detrimental, lingering effect of a disqualified judge.
10.8
USCR 25 fosters and encourages the politicizing of the judiciary that is
detrimental to the separation of powers and constitutional protections.

10.9
A facial constitutional challenge to USCR 25 was timely initiated in the
trial court, in the disqualification motions.

10.11 The tender developmental years of our youth deserve protection from a
disqualified trier of fact whom USCR 25 facially tolerates at the gavel in the
hands of an irate, retaliatory judge (Tr. Oct 3, 2013 hearing, pp. 6-10, 14-19, 21,
112-116; V14, pp.2837-2855), handpicked to be a judicial/political barterer.
10.12 At each phase of this litigation, Chief Judge A. Quillian Baldwin, Jr.
gives the appearance of being a judicial/political barterer. This judge has
opposed his disqualification with false statements in denial of the first motion,
not submitted to another judge (V10, 1935) and refused, without reading, to
adjudicate or refer any of the later disqualification motions.
11. Memorandum of Law
11.1 The August 23, 2013 Order of Chief Judge Baldwin changed custody, i.e.,
visitation. It is well established that the term "custody includes visitation rights.
OCGA 19-9-22 (1). Bennett v. Wood, 188 Ga. App. 630, 631 (1988).
11.2
Michelle Murphy was entitled to present the evidence of the detrimental
effect upon Jack and Thomas being jet-setted around the country on the
weekends when school is in session before Chief Judge Baldwin singly, without
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Page 44 of 52
allowing Michelle Murphys evidence, modified the Standing Order

implemented by the judges of the Coweta Judicial Circuit. Michelle Murphy was
also entitled to present evidence about other detrimental conduct of
John Harold Murphy and Renee L. Haugerud, including but not limited to
providing the children access to alcohol by serving as bartenders at Renee
Haugeruds functions. The August 23, 2013 Order is a house of cards order.
Disallowing Michelle Murphy to present evidence, reverses that Order and all
of its subsequent consequences. In Shore, the Supreme Court of Georgia held as
follows.
The trial court must consider all facts and conditions which present
themselves up to the time of rendering the judgment and not merely facts
and conditions which occur prior to the filing of the petition." We adhere
to the rule that where the issue is a material change in conditions
affecting the welfare of a child, it is error to refuse to hear any evidence
which might have some bearing upon that issue. Where the welfare of a
child is involved, relevant information must be received up until the very
time that the court rules. Shore v. Shore, 253 Ga. 183, 184 (1984)
11.3
Realistically, even Shore is swallowed by a larger fish that is the
disqualification of Chief Judge Baldwin, who abrogated his authority to the

lawyers representing John Harold Murphy and Renee L. Haugerud.
11.4
Just as Chief Judge Baldwin refused to allow his disqualification motion
to be heard, he refused to allow evidence about the disqualification of the

guardian ad litem, and, in denying the disqualification, about Elizabeth Lisa
F. Harwell converting money from the funds advanced in trust to the guardian
ad litem to her personal account. These funds are subject to distribution u pon
notice to the parties and approval by the Court.
Page 45 of 52
on Mandamus Nisi
11.5
After the filing of a comprehensive motion to disqualify Elizabeth
Lisa F. Harwell as guardian ad litem, Chief Judge Baldwin, as the wall of

disqualification began to crumble around him, denied the unopposed motion
without a hearing. Counsel for Michelle Murphy sought discovery from the
guardian ad litem in the form of a deposition and production of documents.
11.5.1
The guardian ad litem then engaged counsel who sought a protective
order; it was opposed. (V13, p. 2595) The guardian ad litem has acted against the
best interest of the children and as an illegal advocate for her primary paymaster,
John Harold Murphy, by assisting him and Glover & Davis in creating
unnecessary litigation costs.
11.5.2 The Uniform Superior Court Rule that governs the distribution of funds
to the guardian ad litem USCR 24.9(8)(g) is 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.
This USCR 24.9(8)(g) imposed a non-discretionary obligation upon the
guardian ad litem, as the guardian ad litem did not petition the Court in
advance for payments of expense.
11.5.1 The guardian ad litem is an attorney who is also subject to the Georgia
Rules of Professional Conduct Rule Rule 1.15(II) (a) Safekeeping Property.
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Page 46 of 52
11.5.2 The Court erred in failing to allow Michelle Murphy to present evidence
on the motion to disqualify the guardian ad litem and in not disqualifying the
guardian ad litem.
11.6
The self-executing Canons 2A, 2B, and 3E of the Code of Judicial
Conduct are substantive grounds for recusal or disqualification of a judge. After

Chief Judge Baldwin began his threats and expressions of bias toward counsel
for Michelle Murphy, he should have recused himself and not awaited the series
of disqualification motions. These grounds should be assessed in light of two
well-recognized principles of Georgia law.
11.6.1 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. Glover &
Davis and Chief Judge Baldwin, in concert, violated both aspects of these
principles of Georgia law in this case and it happens in the Coweta Judicial Circuit
on a regular basis. (V2, p.310 ) See Uniform Superior Court Rule 3.1.
11.7
The judge and the guardian ad litem are more relevant in a case involving
the modification of custody of minor children than in other cases, as they have
an extremely broad amount of discretion that is only reviewed by an abuse of
discretion standard. To modify the visitation of the children during the school
year from the home of the mother and permit their jet-setting around the country
is modification of the greatest magnitude. Michelle Murphy has been the
custodial parent since their birth. She and the children realize the detriment of
them being forced to trek around the country on alternating weekends with these
jetsetting multimillionaires for the reason that the never-modified child support
cannot provide the financial benefits to Michelle Murphy and the children that
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Page 47 of 52
the former husband has after marrying and going in business with a
multimillionaire hedge fund manager. This case requires a judge not tempted by
the political resources of a Glover & Davis lawyer chosen by a fellow judge,
Judge Jack Kirby.
11.8
Chief Judge Baldwins execution of the Order appointing the Guardian
ad Litem and his even worse Order denying his disqualification demonstrates,
without any doubt, in the mind of a reasonable person, that he is not an impartial
jurist.
11.9
Chief Judge Baldwins impartiality might, to say the least, reasonably
be questioned because he participates in a systemic practice of violating

USCR 3.1 that both permits lawyers to judge shop and judges to case shop. 11.10
This Court addressed the detriment of this type of conduct in Mayor &
Aldermen of Savannah v. Batson-Cook Co., 291 Ga. 114 (2012).
11.11 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. Const.
amend. XIV, 1 and State of Georgia Constitution Bill of Rights due process
protection (Ga. Const. Art. I, 1, 1)
11.11.1 The problem with a judge not accepting USCR 25 is explained well,
in Isaacs v. State, 257 Ga. 126, 128 (1987).
We also recognize that a judge who actively resists recusal may be fully
capable of even-handedly presiding if the motion is denied. Nevertheless,
we think that these factors are heavily outweighed by the necessity of
preserving the public's confidence in the judicial system. We therefore
on Mandamus Nisi
Page 48 of 52
hold that after a legally sufficient motion to recuse has been assigned for
hearing, the judge against whom the motion is directed may not oppose
the motion.
11.12
Counsel for Michelle Murphy is well-aware this Petition can illegally and
unconstitutionally suffer the same fate that motions to disqualify Chief Judge A.
Quillian Baldwin, Jr. suffered, if it is adjudicated by a jurist in the Coweta Judicial
Circuit, or a senior judge who has participated as a jurist in the Coweta Judicial
Circuit by appointment. The selection of cases by lawyers who barter political
support to judges is not a personal benefit that judges wishes to surrender.
11.13
The motion to disqualify Chief Judge Baldwin encompassed the systemic
issue of the non-discretionary dictates of Uniform Superior Court Rule 3.1 that is in
somewhat disfavor by all judges in the Coweta Judicial Circuit who allowed it to
operate. Its operation was very simple; the local lawyers with political strength could
select their judge, and the judges could preside over a case of their choosing, with a
politically favored lawyer. The detriment of the absence of adhering to the Uniform
Superior Court Rule 3.1 ran deeper than just judges in the Coweta Judicial Circuit
benefiting from the violation of USCR 3.1; there was a cadre of senior judges who
financially benefited from coming into the circuit and carrying out the bidding of the
local judges.
11.14
Any influx of senior judges to do the bidding of Chief Judge Baldwin in
this petition will be met with the same opposition that the bidding of the Judge in the
John Henry Furman case was met. Counsel for Michelle Murphy litigated for too
many years the conduct of judges who allowed jury composition discrimination that
is closely akin to USCR 3.1 violations.

on Mandamus Nisi
Page 49 of 52
11.15 The Supreme Court has established that petitions for writs of mandamus
should be initially filed in the Superior Courts.
Generally, the superior courts of this state have the power, in proper cases,
to issue process in the nature of mandamus, prohibition, specific
performance, quo warranto, and injunction, and hence the need to resort
to the appellate courts for such relief by petition filed in the appellate
courts will be extremely rare.
There may occasionally appear to be a need to file an original petition in
the Supreme Court to issue process in the nature of [*437] mandamus,
and perhaps quo warranto or prohibition, where a superior court judge is
named as the respondent. This appearance is misleading. Such petition
may be filed in the appropriate superior court. Being the respondent, the
superior court judge will disqualify, another superior court judge will be
appointed to hear and determine the matter, and the final decision may be
appealed to the Supreme Court for review.
Brown v. Johnson, 251 Ga. 436, 436-437 (Ga. 1983)
Also see, Gay v. Owens, 292 Ga. 480 (2013)
12.1
Nancy 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.
12.2
Nancy Michelle Murphy requests that the Emergency Motion for Ruling on
Mandamus Nisi be granted immediately.

12.3
Nancy Michelle Murphy requests that Respondent Chief Judge Baldwin be
ordered to show cause as to why mandamus absolute should not issue compelling
the Respondent to discharge his non-discretionary duty to rule upon each of the

on Mandamus Nisi
Page 50 of 52
motions for his disqualification by referring each of the matters to another judge, or,
for Judge Baldwin to recuse himself, nunc pro tunc, to April 10, 2012.
12.4
Nancy Michelle Murphy requests for mandamus absolute requiring Chief
Judge Baldwin to issue an order recusing himself, as he remained presiding in this

underlying case after he was placed on notice that he was selected in violation of
Uniform Superior Court Rule 3.1 (case management) plan and remained presiding
after he violated the self-executing Canons of the Georgia Code of Judicial Conduct
and is therefore disqualified, nunc pro tunc, to April 10, 2012.
12.5
Nancy Michelle Murphy requests that she be allowed to produce evidence in
support of this petition.

12.6
Nancy Michelle Murphy requests that she be awarded attorney fees for
bringing this action.

12.7
Nancy Michelle Murphy requests that the relief requested in this petition be
granted before Chief Judge Baldwin further violates her constitutional and legally
protected rights.
12.8
Nancy Michelle Murphy requests that she be granted such other and further
relief as justice requires. .

-
This 3rd day of December, 2013
Larry King
Millard Farmer
P. O. Box 1648
P.O. Box 1728
Jonesboro, GA 30237
(770) 471-3835
(404) 688-8116
on Mandamus Nisi
Page 51 of 52
I hereby certify that I have this day perfected service of a copy of the
foregoing Petition for Mandamus with Memorandum of Law for an
Emergency Motion for Ruling on Mandamus Nisi, by hand delivery as
follows.
Dennis R. Dunn
Assistant Attorney General
132 State Judicial Building
40 Capitol Square, S.W.
Atlanta, Georgia 30334
ddunn@law.ga.gov
Counsel for Chief Judge A. Quillian Baldwin, Jr.
who is authorized to accept and waive further service of process
for Chief Judge A. Quillian Baldwin, Jr.
This 3rd day of December, 2013.
Millard Farmer
(404) 688-8116
Larry King
(770) 471-3835
Attachment 157
Notice to Produce
Notice to Produce
Attachment 157
In the Superior Court of Coweta County

State of Georgia
John Harold Murphy,
Plaintiff
vs.
Civil Action No. 12V-413
Defendant
Nancy Michelle Murphys Notice to Produce
To:
Glover & Davis P. A.,

Peter A. Durham,
Renee L. Haugerud,
Taylor Drake and
John Harold Murphy
This is Notice to you pursuant to OCGA
24-13-27 to produce at the
hearing scheduled for Tuesday May 27, 2014 at 9:00 a.m. in the above
styled case, and from time to time and from term to term, or until the
above styled matter is concluded, the following documents, records, and
things which are or come into your possession, custody or control for use
as evidence by Nancy Michelle Murphy, her counsel Larry King and
Millard Farmer in this case.
1.
All documents evidencing payments to Peter A. Durham, Taylor Drake
and/or Glover & Davis P.A. relating attorney fees that you seek to recover for
litigation expenses, costs and attorney fees relating to the litigation in this case.
2.
All documents that you maintain support the value of the legal services
that you attempt to recover in this matter.

3.
All documents that reflect the persons or entities that have compensated
you for litigation expenses, costs and attorney fees during the litigation in this
case.
1
4.
All contributions, payments, or in-kind benefits provided to Judge A.
Quillian Baldwin or to elections committees for Judge A. Quillian Baldwin, Jr.

during the last ten (10) years by you or persons associated with the Glover &
Davis P.A.
4.
All contributions, payments, or in kind benefits provided to other judges
in the Coweta Judicial Circuit, or to elections committees for Judge A. Quillian

Baldwin, Jr. during the last ten (10) years by you or persons associated with the
Glover & Davis P.A.
This 24th day of May, 2014.
Larry King
P. O. Box 1648
Jonesboro, GA 30237
(770) 471-3835
Millard Farmer
P.O. Box 1728
(404) 688-8116
Certificate of Service
I certify that I have today served a copy of the foregoing Nancy Michelle
Murphys Notice to Produce, by electronic delivery as follows:
Michael W. Warner
Peter A. Durham
Taylor B. Drake
P.O.
Drawer
1038
P. O. Drawer 1038
P. O. Drawer 1038
Newnan, GA 30265
Newnan, GA 30265
10 Brown Street
mwarner@gloverdavis.com pdurham@gloverdavis.com
Newnan, GA 30265
tdrake@gloverdavis.com
Stephen E. Hudson
Ga. Bar No. 374692
Kilpatrick Townsend & Stockton LLP
1100 Peachtree Street, Suite 2800
shudson@kilpatricktownsend.com
William R. Poplin, Jr.

Ga. Bar No. 584535
rpoplin@kilpatricktownsend.com
Teresa E. Lazzaroni
tlazzaroni@hptylaw.com
trial court counsel for
Elizabeth F. Harwell
Harwell, Brown & Harwell, PC
Newnan, GA
eharwell@hbhlawyer.com
Judge A. Quillian Baldwin, Jr. is served

electronically at jharris@troupco.org
and qbaldwin@troupco.org
This 24th day of May, 2014.
Millard Farmer
P.O. Box 1728
(404) 688-8116
Larry King
P. O. Box 1648
Jonesboro, GA 30237
(770) 471-3835
Fax (770) 471-8200

1
Attachment 158
Ct. App. Rule 44 Disq. Motion
Ct. App. Rule 44 Disq. Motion
Attachment 158
IN THE COURT OF APPEALS

STATE OF GEORGIA
______________________________
Case No. A14A0700
______________________________
Appellant
vs.
John Harold Murphy and
Renee Haugerud,
Appellees
______________________________
Motion for Rule 44 and Due Process Disqualification
______________________________
Millard Farmer
P.O. Box 1728
(404) 688-8116
and
Larry King
P. O. Box 1648
Jonesboro, GA 30237
(770) 471-3835
Fax (770) 471-8200
Summary of Motion
This case was docketed on December 12, 2013 after it was transferred from
the Supreme Court of Georgia. The case includes the same parties before this
Court in an earlier case dismissed on jurisdictional grounds. Murphy v. Murphy,
322 Ga. App. 829 (2013) (or, Murphy 1) That dismissal occurred after there
was a statutory change in OCGA 5-6-34(a)(11) that this Court maintained
deprived it of jurisdiction when this Court applied the statutory change
retroactively.
The parties to Murphy 1 intensely litigated this Courts jurisdiction before the
statutory change in OCGA 5-6-34(a)(11).
The parties represented by Glover & Davis strongly urged the dismissal of
Murphy 1 from the initial filing. Nancy Michelle Murphy, with equal intensity,
urged that the Court hear the case and deny its dismissal.
The Court heard the case and denied the dismissal long before oral argument,
during which the jurisdiction was not an issue that was either raised by the Court,
or counsel for either party.
The issue in Murphy 1 was the disqualification vel non of Chief Judge A.
Quillian Baldwin, Jr. The standard of review in Murphy 1 was de novo.
Judge Christopher J. McFadden, unknown to counsel for Nancy Michelle

Murphy, advocated at times before May 6, 2013 for passage of a statute that he
would later maintain deprived Nancy Michelle Murphy retroactively of
jurisdiction to immediately have Chief Judge Baldwin disqualified in the
pending Murphy 1.
Between May and July of 2013, as before that time, counsel for Nancy
Michelle Murphy knew nothing of Judge Christopher J. McFaddens advocating
for passage of a revised version of the then existing OCGA 5-6-34(a)(11).
Counsel for Nancy Michelle Murphy had no notice that the changes in the statute
were being considered and no notice that any changes were occurring in any
jurisdictional issue in the then pending Murphy 1 case and therefore had no
opportunity to brief the issue before the Murphy 1 dismissal by this Court.
Statement of the Rule 44 and Due Process Motion
The issue in Murphy 1 was the disqualification of Chief Judge
A. Quillian Baldwin, Jr. The issue in this case involves the repercussions of the
proceedings in the trial court after the jurisdictional dismissal of Murphy 1. The
two cases are tightly connected.
Judge Christopher J. McFaddens involvement in the statutory change that
resulted in Murphy 1s vacating of jurisdiction raises the core issue of this Court
of Appeals Rule 44 and Due Process Disqualification Motion. The source,
available to counsel for Nancy Michelle Murphy, of Judge Christopher J.
McFaddens involvement is derived from the public records in this case, and a
published report in the State Bar of Georgia Journal. This source was identified
in the merits brief of Nancy Michelle Murphy in Supreme Court of Georgia Case
No. S13G1651.
This motion seeks to disqualify Judge Christopher J. McFadden and possibly
the two others panel members, Presiding Judge Sara L. Doyle and
Judge Michael P. Boggs, who were also on the initial panel in Court of Appeals
Case No. A13A0206, before Judge McFadden, writing for the full Court,
dismissed the appeal on jurisdictional grounds in Murphy 1. If Presiding Judge
Sara L. Doyle and Judge Michael P. Boggs knew of Judge McFaddens
involvement in the statutory change, or were otherwise involved in the change
of OCGA 5-6-34(a)(11) they, too, should be disqualified.
The information that serves as the basis for this motion first came to the
attention of counsel for Nancy Michelle Murphy while attempting legislative
history research in preparation for a petition for writ of certiorari of Murphy 1.
This knowledge by counsel for Nancy Michelle Murphy was obviously obtained
after Murphy 1 was decided. See Exhibit 3, Affidavit of Millard Farmer.
The State Bar of Georgias website contains a statement attributed to Jeff
Swart, a partner at Alston & Bird LLP, who according to the article in the State
Bar of Georgia Journal, serves as the chair of the Appellate Practice Sections
State Practice and Legislation Committee that provides the following legislative
inducement, historical information about the changes in the statute.
On May 6, the Governor signed legislation enacting into law the Sections
proposal to amend O.C.G.A. 5-6-34(a)(11) to restrict the types of orders
in child custody cases that can be directly and immediately appealed as a
matter of right. Under the legislation, which gained the unanimous
approval of both chambers of the General Assembly, parties in such cases
now have a right to immediately appeal only such orders that actually
affect child custody (including related contempt orders). Otherwise,
parties seeking appellate review in child custody cases will need to comply
with
the
discretionary
appeal
procedure
provided
by
O.C.G.A. 5-6-34(b). The purpose of the revision successfully proposed

by the Section was to reduce the appeals of collateral orders in child
custody cases, with the hope of achieving a corresponding reduction in

the time and expense required to bring such cases to final judgment. The
issue was first called to the Sections attention by Hon. Christopher
McFadden of the Court of Appeals of Georgia [who is a member of the
State Bar of Georgia Advisory Committee on Legislation] and was
thereafter noted by the Court in Collins v. Davis, 318 Ga. App. 265, 269
n.17, 733 S.E.2d 798, 801 n.17 (Oct. 30, 2012). The Section worked
closely with the Family Law Section on this proposal.
Emphasis supplied; see Exhibit 1
Nancy Michelle Murphy was not placed on notice that the Court was
considering the statutory change of OCGA 5-6-34(a)(11), as a jurisdictional
issue, and therefore was not provided an opportunity to brief the retroactivity of
the jurisdictional issue before Judge McFadden, writing for the whole Court,
held that the new version of OCGA 5-6-34(a)(11) and the overruling of Braddy
v. State, 316 Ga. App. 292 (1) (2012) deprived her of an immediate appellate
review before Chief Judge A. Quillian Baldwin, Jr. and a guardian ad litem, who
should have been disqualified, Elizabeth Lisa F. Harwell further disrupted this
familys life in this modification of custody case in which Judge Baldwin was
selected and retained by a Glover & Davis lawyer in a Superior Court without a
Uniform Superior Court Rule 3.1 case management plan.
Chief Judge Baldwins interpretation of Murphy 1, that created some of the
issues in the case that underlies Judge Baldwins disqualification as late as
Oct. 3, 2013, is as follows.
And Im not going to recuse myself.
Ill tell you
right now, Im not going to recuse myself.
And
Im going to put in there -- because yall have

already had your chance on recusal.
appealed.
Its been
They upheld me staying in this case and
not recusing myself.
And were just going to keep
it like that.[emphasis supplied

*
*
*
Now, I dont know if your client is paying you.
Yall may be eating all this stuff. But Ill tell
you what. Because of all this stuff, Im unlikely
to give you any attorneys fees so yall are
working on this thing on your own money if youre
doing all of this. [Oct. 3, 2013 Tr.pp. 17-18,emphasis supplied]
This case was pending before Judge Christopher J. McFadden and the panel
of Presiding Judge Sara L. Doyle and Judge Michael P. Boggs during the time
that Judge McFadden advocated a position to a State Bar of Georgia committee
for support of legislative change that this Court thereafter held, retroactively,
deprived it of jurisdiction. The ultimate result of the position being advocated
by Judge McFadden was the position that the Glover & Davis lawyers had
initially advocated against Nancy Michelle Murphy during the litigation. The
position of the Glover & Davis lawyers throughout the litigation was clear; they
wished to retain Judge Baldwin in the case. They were able to select Judge
Baldwin for the case due to the absence of a Uniform Superior Court Rule 3.1
case management plan in the Superior Court of Coweta County. They were able
to retain Judge Baldwin in the case as the result of the dismissal of the Murphy 1
appeal due to the Court of Appeals interpretation of the change to
OCGA 5-6-34(a)(11).
The
following
timetable
is
relevant
for
Judge
McFadden,
Presiding Judge Sara L. Doyle and Judge Michael P. Boggs to determine when
the advocacy for the change of OCGA 5-6-34(a)(11) by Judge McFadden
began and when Judge McFaddens advocacy for the change became known to
Presiding Judge Sara L. Doyle and Judge Michael P. Boggs.

Timeline of relevant dates.
In the Superior Court of Coweta County
April 11, 2012
Complaint for Modification of Custody with emergency
motion (V1 pp.1, 13) based upon the threat that Michelle Murphy planned a
move to South Carolina, an act prohibited by the Standing Order that was
active upon the filing of the Modification Complaint. V1 p.7
April 11, 2012
Rule Nisi on Emergency Motion before Judge Baldwin
V1 p.15
April 26, 2012
Appointment of Guardian ad Litem by Judge Baldwin in an
opposed Order that he did read, granting power for the guardian ad litem to
temporarily change custody without judicial approval, V1 p.23
May 1, 2012
Motion to Disqualify Judge Baldwin, V1 p.28
May 3, 2012
First Amended Motion to Disqualify Judge, V1 p.101
June 4, 2012
Addendum to First Amended Motion to Disqualify
Judge Baldwin, V2 p.188

June 7, 2012
Order Denying Motion to Disqualify, V2 p.310, that
disputed the facts in the Order without referring the motion to another judge
June 13, 2012
Appellant Nancy Michelle Murphys Notice of Appeal to
the Supreme Court of Georgia, V3, p.458. The jurisdiction was based upon a
constitutional attack to Uniform Superior Court Rule 25 ET. seq. (Recusal)
In the Supreme Court of Georgia:
July 27, 2012
Docketing Notice in the Supreme Court of Georgia
Aug. 7, 2012
Appellees Motion to Dismiss
Aug. 8, 2012
Appellants Response to Motion to Dismiss
Aug. 14, 2012
Brief of Appellant
Aug. 24, 2012
Appellees Reply to Response to Motion to Dismiss
Aug. 27, 2012
Transfer Order to the Court of Appeals of Georgia
In the Court of Appeals of Georgia

Sept. 18, 2012
Notice of Docketing-Direct Appeal
Sept. 18, 2012
Brief of Appellant
Sept. 18, 2012
Motion to Dismiss by Appellee
Sept. 18, 2012
Response to Motion to Dismiss
Sept. 24, 2012
Request for Oral Argument
Oct. 3, 2012
Appellees Renewed Motion to Dismiss
Oct. 4, 2012
Appellees Amended Renewed Motion to Dismiss
Oct. 10, 2012
Brief of Appellee
Oct. 10, 2012
Appellants Brief in Opposition to Motion to Dismiss
Oct. 11, 2012
Order Granting Appellants Request for Oral Argument
Oct. 15, 2012
Appellants Motion to Supplement Record
Oct. 17, 2012
Order Denying Motion to Supplement Record
Oct. 22, 2012
Reply Brief of Appellant
Oct. 30, 2012
Order Denying Appellees Motion to Dismiss
Jan. 22, 2013
Oral Argument before Judges Doyle, McFadden and Boggs
May 6, 2013
Amendment to OCGA 5-6-34(a)(11) Enacted
July 12, 2013
Opinion of the Court of Appeals Dismissing Appeal
July 15, 2013
Notice of Intention to File Certiorari
The disqualification issues involving Judges Doyle, McFadden and Boggs

arise from the May, 2013 enacted OCGA 5-6-34(a)(11) statute.
Judge McFadden, who wrote the opinion for the whole Court, reportedly
advocated for the statutory change that deprived Nancy Michelle Murphy of
jurisdiction in this case while the case was pending adjudication.
This issue is presented to the Court in order that Judge McFadden can disclose
if the State Bar of Georgia article is correct and if the other members of the panel
were knowledgeable about Judge McFaddens participation in the legislative
change that did not specifically include a retroactive exemption that became
immediately effective upon signature of the Governor.
The disqualification motion is based upon the self-executing Canons of
Judicial Conduct in general and specifically upon Canon 3 (E) (1) that provides
as follows.
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(l) apply.
*
This Canon is self-executing. See, Hargis v. State, 319 Ga. App. 432, 437
(2012).
Judicial maneuvering to affect jurisdiction to the detriment of a party before
the Court can be a violation of the Canons of the Code of Judicial Conduct that
disqualifies a judge from further participation in a case.
The issue is whether Judge McFadden, the advocate for the restriction upon
appeals supported by a segment of the domestic relations lawyers, created an
event where his impartiality might reasonably be questioned in furtherance
of the appearance that he could have been attempting to obtain acclaim for the
decision in Murphy 1 by delaying and not addressing the less popular decision
of disqualifying Judge Baldwin in a case where a hair stylist was being defended
against hedge fund operators, well-heeled with the Glover & Davis and
Kilpatrick Townsend & Stockton LLP lawyers.
It is these two competing conflicts that create the situation where impartiality
might reasonably questioned. Would a prudent lawyer representing Nancy
Michelle Murphy accept this juror?
All persons, including judges, have a right to advocate for changes in the law;
this motion is not to condemn that type of conduct; this statement must be
followed by a large however -- a judge has an ethical responsibility not to
serve as a jurist while, or after advocating for a change in the law that is
detrimental to a party in a case pending before the judge. The public, including
other lawyers, must have confidence in the division of the judicial branch of
government from the other branches, and litigants must have their due process
rights carefully guarded.
The issues involved in the underlying case that the Court of Appeals
dismissed on jurisdictional grounds, are identified to preview the detriment of
the dismissal to Nancy Michelle Murphy and her children, ages 15 and soon to
be 13, whom she has raised since their birth. This case is about the children, as
they have elected on numerous occasions to live with their mother (V1 pp.78,85)
although John Murphy and Renee L, Haugerud financially offer the children
much more to the extent of putting them in the private corporate jet of
Renee L. Haugeruds hedge fund and regularly flying them all over the country
and even overseas (V2 pp.213-214; V4 p.626); the children understand that the
extreme wealth of their father derived from Renee L. Haugerud is no substitute
for the mother who has cared for them without John Harold Murphy living in
the household since these children were toddlers.
At the time that Chief Judge Baldwin was selected by the Glover & Davis
lawyer for this case, the Supreme Court had not decided Mayor & Aldermen of
Savannah v. Batson-Cook Co., 291 Ga. 114 (Ga. 2012), a case where there also
was no Uniform Superior Court Rule 3.1 plan in the Coweta Judicial Circuit;
however, the City of Savannah record did not document an absence of a
USCR 3.1 plan in that case. See, City of Savannah n. 4. The record in this case
is supported by an Open Records request to and response from the Clerk of Court
that documents the absence of a USCR 3.1 plan. V2 pp.310-318, 447
The judge tampering in City of Savannah would have been extremely difficult
and unlikely to happen if there had been a USCR 3.1 plan. The absence of a plan
in the City of Savannah litigation permitted the Glover & Davis lawyers to
accomplish selecting the presiding judge, as the Glover & Davis lawyer did in
this case. It was between the affirming of the judge tampering by the Court of
Appeals and the reversal by the Supreme Court of Georgia in City of Savannah
that Judge Baldwin was selected in this case by the Glover & Davis lawyers and
that he signed, without reading, the Order appointing the guardian ad litem
which granted her the authority to temporarily change custody of the children
without judicial approval. The guardian ad litem appointed in the signedwithout-reading-Order co-sponsored, with the Glover & Davis lawyer, a
fundraising event for another candidate for judge attended by Judge A. Quillian
Baldwin, Jr. on the night before her appointment.
The illegal Appointment Order of the guardian ad litem assisted the Glover &
Davis lawyers in attempting to illegally take custody, albeit temporarily, of the
children whom Michelle Murphy has raised since their birth. It was necessary
for Nancy Michelle Murphy to defy the Order of the guardian ad litem.
The conduct of a judge, not designated by a USCR 3.1 plan, who signed the
Order without reading it, and when challenged, did not refer his conduct to
another judge to review, is worse than the conduct of a judge who signs a warrant
without reading it, as the judge signing the warrant is only violating Fourth
Amendment rights and not assisting in the trafficking of children. The Order
appointing the guardian ad litem placed the fate of the children in the hands of
a person, an attorney, who also took money prepaid to her in trust that Uniform
Superior Court Rule 24.9(g) prohibits her from taking without an order from the
Court, after notice to the parties. The illegal conduct of taking money in
violation of the law is not an acceptable character quality for a guardian ad litem,
but instead the conduct of a person who should be disciplined.
This thumbnail sketch of information is included to emphasize the detriment
of dismissal of Murphy 1. The merits brief of John Harold Murphy to the
Supreme Court of Georgia is also attached to further emphasize the detriment of
the dismissal. Exhibit 2. The exhibit attachments to the merits brief of John
Harold Murphy are also included. (Exhibit 2, pp. 20, 29, 37 and 40)
The Glover & Davis and Kilpatrick Townsend & Stockton LLP lawyers, in
responding to the merits brief of Nancy Michelle Murphy in the pending
certiorari case No. S13G1651, take issue with the identification of the
participation of Judge McFadden in advocating for the repeal of what he later
found to be the jurisdictional basis for a case pending before him, without
identifying this as a violation of the canons of the Code of Judicial Conduct.
These lawyers gave the issue the bold title of D. Ms. Murphy's "Lay in Wait"
Argument. Their response was as follows. (Exhibit 2, p. 15)
D. Ms. Murphy's "Lay in Wait" Argument
At the end of her brief, Ms. Murphy poses the following
"unanswered question" relative to the timing of the Court of Appeals'
decision in this case: "Did a judge or judges lay in wait from the time
of oral argument in January 2013, or from long before, until May of
2013 for the legislature to amend O.C.G.A. 5-6-34(a)(11) in order
to dismiss the case without resolving the issue of the disqualification
of Judge Baldwin ?" Pet'r's Br., at 16. Ms. Murphy's brief contains
other thinly-veiled suggestions that the Court of Appeals deliberately

manipulated its decision-making process to avoid addressing the
merits of the recusal issue. See, e.g., id. at 8. Leaving aside whether
her completely unsupported "lay in wait" comment violates Rule 29 by
impugning the judicial integrity of Judge McFadden, the other
panelists who heard oral argument, and the entire Court of Appeals
(all of whom joined in the opinion), Ms. Murphy fails to cite any
authority holding it is improper Judges who break the law set the
standard of conduct for those who are appointed to assist in resolving
domestic relations disputes.
The Glover & Davis and Kilpatrick Townsend & Stockton LLP highlight the
lay in wait term used in the merit brief of Nancy Michelle Murphy. The legal
issue is not if laying in wait occurred or was intended. The legal issue is could
the delay be interpreted as impartiality [that] might reasonably be questioned
as identified by the Canons of the Code of Judicial Conduct. The answer to this
is yes, or the Glover & Davis and Kilpatrick Townsend & Stockton LLP lawyers
would not have given the issue a section in their Response to the merits brief of
Nancy Michelle Murphy.
The conduct of the panel is reasonably being questioned, as it was the panel
who was making a decision with a de novo standard of review authority about
an issue involving a judge with the authority of a juror. The urgency of deciding
the issue before the panel was obvious. The decision by the panel to delay
requires this motion to disqualify the members of the panel from further serving
in litigation among the parties of Nancy Michelle Murphy, John Harold Murphy
and Renee L. Haugerud.
There was certainly an interest being advocated by Judge McFadden that
conflicted with the interest of Nancy Michelle Murphy, according to the State
Bar Journal, that could have been cured by a person presenting a position of
advocating for a restrictive change to OCGA 5-6-34(a)(11).
The issue is whether the panels impartiality might reasonably be questioned.
That question was also affirmatively answered when the Respondents merit
brief defended the conduct with a slam at counsel for Nancy Michelle Murphy
for raising the issue.
Request for Relief
Nancy Michelle Murphy requests that the motion for the disqualifications be
granted and for such other and further relief as justice may require.
s/Millard Farmer
Millard Farmer
P.O. Box 1728
(404) 688-8116
Larry King
P. O. Box 1648
Jonesboro, GA 30237
(770) 471-3835
I hereby certify that I have this day I perfected service of a copy of the foregoing
Motion for Rule 44 and Due Process Disqualification electronically as follows.
Taylor B. Drake
P. O. Drawer 1038
Newnan, GA 30265
tdrake@gloverdavis.com
Michael W. Warner
P. O. Drawer 1038
Newnan, GA 30265
mwarner@gloverdavis.com
Stephen E. Hudson
Ga. Bar No. 374692
shudson@kilpatricktownsend.com
Peter A. Durham
P. O. Drawer 1038
Newnan, GA 30265
pdurham@gloverdavis.com
William R. Poplin, Jr.

Ga. Bar No. 584535
rpoplin@kilpatricktownsend.com
Teresa E. Lazzaroni
tlazzaroni@hptylaw.com
counsel for
And Elizabeth Harwell
eharwell@hbhlawyer.com
This 17th day of December, 2013.
s/Millard Farmer
Millard Farmer
P.O. Box 1728
(404) 688-8116
Larry King
P. O. Box 1648
Jonesboro, GA 30237
(770) 471-3835
Attachment 159
Ct. of App. Opinion on Disq. Issue
Court of Appeals Opinion on Disq. Issue
Attachment 159

b50130 RPF Corruption Motion W Exhibit 1 and All Atts PDF

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Attachment 145, Page 1 of 1

IN THE SUPERIOR COURT OF COWETA COUNTY

The Fondling and Sexual Misconduct Accusation against Michelle

Motion for Investigation of Judge Baldwins Corruption

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

Motion for Investigation of Judge Baldwins Corruption

The efforts of John Harold Murphy and Renee Haugerud to obtain

One vital aspect of Judge Baldwins corruption included his Order

John Harold Murphy and Renee L. Haugerud began their financial

Michelle Murphy, a hair stylist, could not financially afford to

On May 27, 2014, Judge Baldwin transferred temporary custody to

Motion for Investigation of Judge Baldwins Corruption

Before this Motion was served, Judge Baldwin and counsel

1. The Information from the Executive Director of Elevations that

The Accusation of Fondling was Fabricated

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

The following Affidavit from Joyanna Silberg, Ph D.

Motion for Investigation of Judge Baldwins Corruption

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

Motion for Investigation of Judge Baldwins Corruption

professional qualifications is accurately set forth in my curriculum vitae

certainty that their mother's involvement in their treatment will

Motion for Investigation of Judge Baldwins Corruption

Disclosure of Reports of Psychologist Related to John and Renee

retaliatory conduct resulting from counsels exposure of the violations of the

The absence of the protections afforded Michelle Murphy and other

similarly situated persons of an unenforced case management plan, Uniform

The violations of the protections of LAW* inflicted upon Michelle

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

hearing on his disqualification that would have exposed his disqualification.

Michelle Murphy could not afford a politically embedded lawyer to

Michelle Murphy was required to accept representation from lawyers

Michelle Murphy is currently ordered by Judge Baldwin to be held

Nancy McGarrah is the custody evaluator who stated falsely,

The contempt Order against Michelle Murphy has been affirmed

with an opinion of Court of Appeals Judge Christopher McFadden serving

Motion for Investigation of Judge Baldwins Corruption

The ability of Judge Baldwin to obtain hefty financial and political

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

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

Motion for Investigation of Judge Baldwins Corruption

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

Judge Baldwin has substantial assistance in sustaining his corruption.

1.3.1.1 It has been impossible for Michelle Murphys counsel to preserve a

Examples of protectors of Judge Baldwins judicial corruption was

It was necessary for Judge Baldwin to prevent Michelle Murphy

from presenting even her direct examination before he orchestrated the

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

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

It is understandable that Nan Freeman wished to protect Judge

Motion for Investigation of Judge Baldwins Corruption

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

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

The District Attorney of the Coweta Judicial Circuit failed to

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

If counsel for Michelle Murphy had yielded to the request of

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

Counsel for Michelle Murphy had experience dealing with

misconduct were the affidavits of unequivocal denial by Michelle Murphy,

Motion for Investigation of Judge Baldwins Corruption