Emergency_Motion_for_Hearing_Murphy_CowetaCounty_Newnan_GA_Oct6_2014

IN THE SUPERIOR COURT OF COWETA COUNTY STATE OF GEORGIA

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

Nancy Michelle Murphy, Defendant Defendant

October 6, 2014 Emergency Motion for a Hearing about Return of Children to Mom in Coweta County, for a Protective Order to Prevent

Witness Intimidation, for a Hearing on Motions to Disqualify Judge Baldwin and Lisa Harwell, for a Hearing on the Response to Glover & Davis’ Instructions to Judge Baldwin about delaying a hearing on the

Pending Motions to Disqualify Judge Baldwin with A Plea to Personal Jurisdiction and Other Relief

Judge Baldwin’s 125 days of attempted alienation of Jack and Thomas from their Mom failed even when Jack and Renee supplemented their stay with alcoholic beverages Jack and Thomas want to come home immediately

1. Prologue Jack and Thomas on September. 23, 2014 stated,

“It is like a prison here! [with John and Renee] [Little did Jack and Thomas know that they were headed to a Utah Behavioral Prison]

Page 2 of 90 October 6, 2014 Emergency Hearing Motion, et al With Plea to Jurisdiction, etc.

I want to go back home so my Mom can raise me and so that I can get back to my life ”

September 23, 2014 photo of Thomas, age 13 and Jack age 15 is above A friend of Jack and Thomas who visited them on a trip back to

Newnan provided the following video support for the July 31, 2014 Emergency Motion that Judge Baldwin Refused to hear. Click Link

https://www.dropbox.com/s/smyeqx3og847u8r/trevor%20video0.mp4?dl=0

1.1 This picture message was about the living conditions of Jack and Thomas with John Harold Murphy and Renee L. Haugerud. As inhumane as living under the control of these two alcoholic adults, the manner in which they were forcefully placed in their present conditions in the Utah Behavioral Prison was more unconstitutional and illegal, as children have In re Gault, 387 U.S.1 federally constitutional protections that have been violated.

1.1.1 The photo message and a secret phone call from Jack was

broadcasted to the Free Jack and Thomas community meeting.

1.1.1 The humiliation of the published Message from Jack and Thomas that

was viewed by these hedge fund operators sent John, Renee and their

lawyers outside the bounds of the law to retaliate against the children,

Michelle Murphy and her counsel.

1.1.2 After the Free Jack and Thomas community movement obtained

traction, John, Renee, their lawyers and the supporters of Judge Baldwin

could no longer, without rebuttal, publically publish false information,

about Jack and Thomas, as a new dominant news media outlet, the Internet,

arrived in town and there were audio recordings of the transcripts of the

1.1.3 May 27, 2014 hearing, first secreted by the court reporter and audio

recordings of all the other hearings, that exposed the unstable state of


domestic relations justice in Coweta Court, as administered by Chief Judge

Baldwin.

1.1.4 John Harold Murphy’s recent conduct is subject to a contempt of

court action against John Harold Murphy. John failed to pay his contractual

child support obligation to Michelle Murphy for September, 2014 and

October, 2014. Judge Baldwin illegally indicated to the Taylor

Drake/Glover & Davis lawyers that he would not place John in jail for this

illegal conduct.

1.1.5 Renee L. Haugerud assisted and acted in concert with John Harold

Murphy’s contempt of court conduct that violated the following provision

of the Settlement Contract that was memorialized before Judge A. Quillian

Baldwin, Jr. and made the Order of the Court by Judge Blackmon.

That settlement contract, enforceable with a contempt action, is as follows.


1.1.6 In addition to failing to pay child support, that is financially

necessary for Mom to protect the best interest of the children, John Harold

Murphy, with the assistance of Renee L. Haugerud and funds derived from

the businesses of Renee L. Haugerud, without a hearing and without

permission of the Court and Michelle Murphy, according to information

derived from the State of Tennessee Department of Human Resources,

without conferring with Michelle Murphy and without informing Michelle

Murphy, committed Jack Murphy and Thomas Murphy to a behavioral

institution in Utah. Apparently, John Harold Murphy and Renee L.

Haugerud now will attempt to force Jack Murphy, age 15 and Thomas

Murphy age, 13 into submission of loving them with drugs, psychological

intimidation, restraints and, if necessary, physical force.

1.1.7 It is John Harold Murphy and Renee L. Haugerud who need mental

health care. How can any entities with a moral agenda allow such sick

hedge fund operators and Renee L. Haugerud’s Galtere Ltd. to invest their money?

1.1.7.1 Investors should investigate the moral illegal agenda of these

people.


2. The 125 days of Judge Baldwin’s Alienation Resulted in the following Isolation Incarceration for Jack and Thomas.

Island View Residential Treatment Center is a residential treatment facility in Utah that changed its name to Elevations RTC when it came under new ownership in May, 2014. Elevations RTC is a residential treatment center for emotionally disturbed adolescents located at 2650 West 2700 South in Syracuse, Utah. The program considers itself to be one of the nation’s leading Therapeutic Boarding Schools. Residential Treatment Program Before its closure, Island View treatment center provided subacute care to troubled adolescents experiencing mood and behavioral dysregulation, substance abuse, and difficulties at home or school. Care at the residential program costs upwards of $10,000 a month and requires a $10,000 deposit.] The 90-bed lockdown facility provides care to students ranging in age from 13 - 17.6 years. Elevations is licensed by the Utah Department of Human Services as an intermediate secure treatment program, which means a 24-hour group living environment for four or more individuals unrelated to the owner or provider, in a facility designed to physically restrict a person's ability to leave the program at their own free will. Most of the students there come from an upper-middle-class background. According to the program's website, the average length of stay at the treatment center is 8–10 months. Teenagers at the residential program are monitored 24 hours per day, seven days per week, by team directors and houseparent staff. While at the facility, students are generally only allowed to communicate with their parents.] Island View is akin to a cross between a reform school and psychiatric security hospital. According to an Order by the state of Oregon, Island View "seems about as restrictive a placement as can humanely exist."


There are restrictions on the use of telephone, internet, and so forth. There are no telephone calls to parents by the [students] during the first two weeks.

2.1 Life at the Syracuse campus is described, in a court proceeding, by an Island View therapist:

"There are locked doors on all the dormitories, and the school area, there are alarm doors in the back, and then there are staff down the hall towards the front, so it would be difficult for a kid to get past them, should that be an indication. They aren't allowed in the front lobby unaccompanied, so if a kid was wandering out there a staff would go with them. They are not allowed to travel across the campus or even be outside without staff presence. Typically, two staff if there's more, more than, I can't re ring the first two weeks. After the first two weeks telephone calls are generally limited to just parents. Any phone calls to anyone other than parents have to be approved by parents." [The therapist] also discussed disciplinary procedures. "At Island View girls are not be talking to boys unless they are in school, and only then it is supposed to be about school-related things. [The therapist] testified that there was a point at which [a] student was placed on communications restrictions where she was not allowed to talk to any resident. She was only allowed to talk to staff for at least a little while. Island View's records also indicated that when [a] student left campus with parents [he or] she was required to go through a "Change of Clothes Procedure" to search for contraband upon [his or] her return."

The program offers a range of critical support services to troubled teens, including a therapeutic, positive peer environment and individual, group and family therapy (generally by teleconference as most students are from out of the area). Specifically, residents receive subacute care involving intensive therapies, behavior modification, psychopharmacology, nursing assessment and intervention, diagnostic evaluation, and educational planning. Residents typically receive seven therapy sessions a week, in the form of five group, one individual, and one family therapy session. It should be noted, however, that the majority of the “therapy” is done with in groups and lead by the unit staff who are not licensed therapists. The program uses a “levels” structure - as a student’s


behavior improves, he or she is advanced to the next level with rewards such as extra phone privileges attached to each higher level.

At Island View, the majority of residents are organized into teams solely by gender. This structure typically consists of separate girls' teams and separate boys' teams of 15-19 adolescents each with specifically assigned milieu or residential staff, teachers and others

Restraints and Seclusion

Parents are required to authorize the facility to use behavior modification such as therapeutic holds and restraints. The program's enrollment agreement authorizes staff to therapeutically hold, restrain, control and detain residents by the exercise of necessary techniques and holds when deemed necessary. Therapeutic holding is a treatment technique that the facility uses to "remove a resident from environmental stimulation when other forms of intervention fail to assist the resident in gaining control." In the program's Authorization for Treatment and Emergency Medical Care, therapeutic holding is defined as when a "resident is physically held by staff members to prevent self-injurious behavior, harm to others, severe disruption of the therapeutic environment and/or destruction of physical property." And seclusion is defined as "the confinement of a resident from the therapeutic environment to the seclusion room or other room. The behavior must create a serious threat of harm to the resident, others, or be a serious disruption of the environment." The program's enrollment agreements have also authorized staff to use other "Special Treatment Procedures," which is a "technique used for residents whose behavior makes them dangerous to themselves or others and/or if a resident's behavior significantly disrupts the therapeutic environment. This technique is only used when ordered by a licensed clinician for a limited, specified period of time or until the resident regains control."

Parent Roles

The program's website at one point said the single most important variable for treatment failure or mediocre outcome is a parents' level of commitment to the process. Parents are coached by Island View


on how to respond to their "child's manipulative attempt[s]" to try "every conceivable way to draw" their parents into rescuing them from the program. When a child "puts up a stink," Island View reminds parents, "if you open one of those doors for him, because you feel bad for him or you think you want to help him, both you and Island View stand defeated. At that point, both you and us need to run after him, get him back into the corridor, be sure that door is locked and work on getting him down the hall toward the right door. All of that takes time and resources."

Parents are deterred from what Island View calls "Making a Deal under the Table" because it "sabotages treatment and renders [Island View] powerless in bringing about lasting change with the child." In the Frequently Asked Questions, some examples Island View gives parents of such a "deal" are when a parent, without the treatment team's approval and recommendation, "is pressured by the child into coming home for a visit" or "persuaded by Mr. Manipulation to come home for good as soon as he achieves" a certain level." According to Island View, it is also a problem when "[e]ven though the rules are that a resident on [a certain level] is restricted to one phone call home per week, and the therapist has a weekly phone session with the family, the parent calls [Island View] every day, inquiring of anybody she can get a hold of, about the general well-being of her child."

Island View's parenting manual also includes instructions for parents on how to deal with their child when that child complains about or asks to be signed out of the program. Parents are warned that shortly after their son or daughter enrolls at Island, he or she may deliberately "attempt to arouse feelings of guilt and anxiety within you." Island View calls this "GUILT-LOADING." The residential treatment center advises parents not to let "guilt-loading" overpower them because they "will help [their] son or daughter the most by no longer allowing him/her to manipulate the way out of consequences." One method of "guilt-loading," parents are told, is" the 'horror story' approach. It is simply misrepresenting, exaggerating, or making up stories. All designed to make you feel guilty. Typical examples are: “They are not feeding me. They are feeding us too much, they are going to turn me into a pig. There is never hot water for the showers.


My roommate is totally crazy, if you don’t get me out of here I’ll go mad. Nobody on the entire staff has talked to me for days. I’m the only sane person in this place. Compared to other kids here, I have no problems”, etc., etc., etc."

2.2 TV’s Dr. Phil is involved in lititation about the treatment Troubled teens and their families were featured on several Dr. Phil shows, who then offered them free therapy for the teen at Island View. A couple whose troubled daughter was featured on an episode of Dr. Phil is suing the television personality with claims that he had a hand in traumatizing her during treatment at Island View. In January 2014, the facility, its owners, and Dr. Phil were sued by the family of a student who had attended Island View after being featured on the show. The lawsuit, which alleged mistreatment at Island View, received extensive media coverage

2.2.1 A recent Complaint in part, states as follows.

Dr. Phil has shown himself to be a showman more interested in ratings than a psychologist devoted to healing," the complaint states. "Dr. Phil, on information and belief, was paid either in money or notoriety, or both, for endorsing not only Island View, but also a raft of CRC compounds just as abusive. Compounds like Island View market themselves as boarding schools, academies, therapeutic treatment centers, ranches, or wilderness experience designed to straighten out truant or failing teens. Their failures to do so are endemic and epidemic. They leave a trail of post-traumatic stress and nightmares. Their extravagant fees suggest great expertise and cloak minimal credentials. "S.M. was thrust into Island View without the slightest understanding of what she was getting into, and had no choice in the matter. For Dr. Phil, she represented one in a string of damaged teenagers that he boasted [of] helping, accompanied by his psychological opinions that such tough love was just the treatment they needed. There was no forum for complaint,


explanation, appeal, or grievance against the placement, before, during, or after it occurred. The only option was to bear it, for Island View, like all other such places was locked and closely guarded. Once confined, no contact with the outside world was allowed and [S.M.] knew that any disparaging remark or complaint about the prison would be punished by isolation and losing all privileges earned, meaning making the teenager start at the bottom anew to rise from level to level by successfully completing mindless tasks of blind obedience enforced by cruel punishment." For complete Complaint, as filed see, http://www.courthousenews.com/2014/01/30/64963.htm

2.2.2 Another Complaint, very relevant to the rights of Michelle Murphy,

Jack Murphy and Thomas Murphy identifies the constitutional right of this

family must be addressed, as addressed by another mother as follows.

On April 3, 2014, a Complaint was filed by a mother from Houston, Texas in Utah Federal Court against Aspen Education Group, Aspen Institute of Behavioral Assessment, Bain Capital, Guardians of Hope, Harris County Office of Human Resources and Risk Management, lead defendant Jack Nuszen, and Norma Willcockson, the alleged child trafficker that transported the teenage girl from Houston, Texas to Syracuse, Utah forcibly against her will to be locked up in Aspen RTC. In the lawsuit, the mom calls the place a private prison. [Jack and Thomas did not travel of their free will, or after as hearing where they were allowed due process rights.]

2.2.3 In 2014, another former student sued Island View, along with the

Provo Canyon School, for personal injuries, demanding $800,000. In the

federal lawsuit, the student claims Island View putting him into a "private

prison violates his constitutional rights to privacy, due process, both

procedural and substantive, equal protection, free speech, false


imprisonment, right to a speedy trial, freedom from seizure, involuntary

servitude, and cruel and unusual punishment.

You will note that Judi Jacques, the Associate Executive Director has been with the 2014 rebranded Institution since 1998. Ask Judi why Island View was rebranded in 2014 You will note that Judi Jacques, the Associate Executive Director, has been with the Institution since 1998.

1-855-290-9681, or Direct 801 773 0200 2.2.4 Children have constitutional rights. In re Gault, 387 U.S. 1 (1967)

2.2.4.1 Jack Murphy, age 15, Thomas Murphy age 13 and their mother Michelle Murphy were taken into the physical custody of the Deputy Sheriffs of Coweta County in the courtroom and were removed from the Coweta County Courthouse. See, West v. Davis No. 12-14805, 2014 WL 4402116 (11th Cir. Sept. 8, 2014) This


conduct for a second time activates 42 USC § 1983 actionable conduct by the Coweta County Deputy Sheriffs, who are represented by the Glover & Davis lawyers.

2.2.4.2 The question becomes, just what did Jack and Thomas do, besides

drink the alcoholic beverages, smoke the cigars that John and Renee bought

for them and sit around the campfire and thereby inhale the marijuana that

John placed on the fire after the children brought home the discovered

marijuana that they found growing close to the property of the home of

Renee L. Haugerud’s friend. John and Renee funded and participated in the

conduct of Jack and Thomas during the last 125 days or more, their obvious

plan must have been to buy their love with alcoholic drinks. This failed.

The real intolerable act that Jack and Thomas committed, with the consent

of their mother when they were with her in Newnan was not taking the

prescribed academic improvement, sleep and alertness medications that

John and Renee’s paid psychiatrist, Patricia Nice to prescribed for them.

This “pill pusher” psychiatrist returned to court in this case, after a lunch

break at a hearing, so under the control of medication that even Judge

Baldwin informed her that she was slurring her words. Judge Baldwin

would not allow counsel for Michelle Murphy to complete cross-

examination of her about her suspensions from the practice of medicine due

to her substance abuses and other information about the false statements in

her testimony.

2.3 The problem that John and Renee have with Jack and Thomas is that these children wish to live with their “My Mom,” Michelle Murphy, who has great parenting skills, as opposed to the illegal and unconscionable parenting conduct of John and Renee.


2.4 First let’s compare character traits of these two parents

Parenting Conduct of John and Renee L. Haugerud

Parenting Conduct of Michelle Murphy

John moved Michelle and the children from California to LaGrange in order to obtain a divorce with less financial benefit to Michelle Murphy and the children.

Michelle Murphy and the children did not wish to move from Newnan upon demand from the Taylor Drake/Glover & Davis lawyer to move to Chattanooga, TN or have the modification of Custody action brought. Michelle Murphy, refused

After moving Michelle and the children to LaGrange, John obtained an apartment in New York City where he engaged in bed hopping with women while he was married to Michelle Murphy

While John was bed hopping in New York City, Michelle Murphy cared for Jack and Thomas from the time that they were toddlers in an area of the country in which she had never lived.

John made a perjurious affidavit in divorce case about $180,000 value of stock options that were cashed a day after settle agreement signed

Michelle Murphy sacrificed litigating over her half share of the $180,000 stock options in order to obtain benefits that protected the children that John now violates.

John and Renee L. Haugerud gave perjurious affidavits to Probate Court of Troup County for these two out-of-state residents to obtain marriage license for Jack Kirby to use to marry them

It was during the deposition of Judge Louis Jack Kirby that Judge Kirby admitted the illegality of the conduct of John and Renee related to the marriage ceremony that he also illegally performed.


Renee L. Haugerud made a false statement under oath to avoid service of process in this court by denying that she had an interest in real property in this state. On another occasion Renee L. Haugerud used a false name and made a false statement to a process server for this Court.

Judge Baldwin held Michelle and her lawyer in contempt of court for not appearing at a hearing that they were not legally required to attend, as Michelle Murphy was not served or provided a Rule Nisi

Judge Louis Jack Kirby advised John to obtain Taylor Drake to represent him in the modification of custody case

It was the exposure of the political relationship that Taylor Drake has with Judge Baldwin that set off the retaliation by Judge Baldwin

John falsely swore in the Modification of Custody Complaint that Michelle Murphy was threatening to move to South Carolina with the children and that such move was a reason to modify custody

Michelle Murphy and the children

did not wish to move anywhere, as

their lives had adjusted to Newnan

John terminated transportation for the children to attend a private school in Atlanta for which he and Renee L. Haugerud had been paying

The Taylor Drake/Glover & Davis lawyer wrote Michelle Murphy a letter stating that she was just lazy in not driving the children to and from Atlanta each day while attempting to be a hair stylist.

John attempted to have Lisa Harwell temporarily transfer custody of the children to him after he terminated transportation to the school in Atlanta


John and Renee, during a regular visitation weekend flew the children and a friend to Minnesota to a ranch home of Renee when the children were much younger and introduced the children to alcoholic beverages, using them as sampling bartenders for guests visiting in their home

Michelle Murphy apologized to the parents of the friend of Jack and Thomas who flew to Minnesota for the alcoholic beverage party where Renee L. Haugerud had the children and their friend serving as bartenders, and allowed Jack and Thomas to sample the drinks.

When the children were younger, Renee paid Thomas $60 per hour to rub her feet and took Jack to walk with her and John on a nude beach near the Miami area.

Judge Baldwin refused to require the same examination of Renee L. Haugerud that he ordered of Michelle Murphy

John has purchased alcoholic beverages for Jack, Thomas and their 15 year old friend at Foxy’s Bar in the British Virgin Islands. The children visited Foxy’s Bar so frequently that the bartender knew their names and they know his name.

Michelle Murphy has and would never take the children, or any of their friends to a Bar, or any such place as Foxy’s Bar, where there are drug dealers selling drugs. Michelle Murphy has fought the prescription drugs that the Taylor Drake/Glover & Davis lawyer attempted to have Judge Baldwin order the children to take. John Harold Murphy, Renee L. Haugerud, the guardian ad litem, Lisa Harwell and the Taylor Drake/Glover & Davis lawyers have attempted with the force of law to get the children on prescription drugs. Michelle Murphy, even upon threat


There is a live internet webcam at Foxy’s Bar. The view above was captured on 8/7/2014.

of judicial action against her, won that legal battle. The children thrived in the public schools in Coweta County. Now they are in danger of being forced to take drugs in a lock-down facility in Utah.

John purchased alcoholic drinks for Jack, Thomas and their friend after the time that the social worker at Children’s Hospital warned John about keep alcohol beverages away from the children and keeping the open bar at his house locked.

Judge Baldwin would never allow the Coweta County educators for the children to explain to him what a dedicated mother that Michelle Murphy is and how the children are under good care by this Mom.


When Thomas was admitted to the hospital in October of 2013, John Harold Murphy informed the hospital that Renee L. Haugerud was the natural parent of Thomas Murphy. Michelle was not informed until the following morning that Thomas was admitted into the hospital. It was Jack who informed the hospital that his Mom, Michelle Murphy should be called

Judge Baldwin and the guardian ad litem, Lisa Harwell, had all of the information about October 2013 on May 27, 2013 when they would not allow evidence from the witnesses of Michelle Murphy, would not allow direct examination of Michelle Murphy and would not allow counsel for Michelle Murphy to examine the custody evaluator, H. Elizabeth “Betty” King, who was in the witness room awaiting to be called as a witness.

Thomas’ condition was very serious and resulted from John and Renee L. Haugerud leaving the alcoholic bar available to the children and a friend as John “slept” and Renee was upstairs.

The picture and hospital records of Thomas Murphy were notice enough of the danger of providing temporary custody of the children to John Harold Murphy whose residences and financial resources are derived from Renee L. Haugerud.


After a drunken boat ride back to St. Thomas, on an occasion with the children and a friend, John was so drunk that the children at first refused to get into the car with him. John forced the children into the car with him while he drove drunk to the home of Renee L. Haugerud

This information was provided to

Judge Baldwin and he refused to

allow Michelle Murphy to present

evidence as Elizabeth “Lisa”

Harwell informed Judge Baldwin

that it was not in the “best interest”

of the children to testify.

Instead of testifying, the children

had to deliver their message first

through a friend and then from the

back of a van parked on a road

where the children could not be

detected as they attempted to free

themselves from the abusive,

contributing to the delinquency of

minors’ treatment of John Harold

Murphy and Renee L. Haugerud.

Michelle Murphy spends hours

addressing the false information

that John Murphy makes about the

children and the facts of the case.

John Murphy and Renee through their lawyer and publicity agent, inform the public the John Harold Murphy is paying for the custody evaluator. This is untrue, as the Court Order states that the Court, at the end of the case, will allocate the costs. At the final hearing in this case, the

Court [Judge Baldwin] shall decide

whether to allocate the costs of this

evaluation between the parties.

“Plaintiff initially being responsible” and “whether to allocate the costs of this evaluation between the parties,” being determined by the biased Judge Baldwin, does not mean that Taylor Drake’s “client” is responsible for the costs.


John has a terrible influence upon the children. On one occasion when John was with the children and one of their friends, John began repeatedly using the “N” word. Jack politely asked John to not use that “N” word. John continued to use the “N” word. Renee L. Haugerud was on the phone with John when he was driving drunk and calling people, including the children the “N” word, as he pointed to people obtaining food from a dumpster in St. Thomas.

The good people of Coweta County

and the surrounding areas have

rallied to the support of Michelle

Murphy and if the phone calls of

support are any measure of the

effort that the people in the area

have to correcting the polarization

of the judiciary, justice is en route

to the Coweta Judicial Circuit and

the box car loading of children to

distant institutions and abusive

parents are ending.

On another occasion when Renee L. Haugerud had consumed too many alcoholic beverages to drive, she instructed Jack, age 15, who has a Georgia learner’s license, to drive her home.

Mothers Against Drunk Drivers:

please take notice of the need for

your support.

Renee maintains to the children that she is god and is in her 21st life of entitlement

Michelle Murphy are enjoy the support of their church in Newnan.

2.4.1 There is not a caretaker anywhere who would have stood down the

injustices inflicted upon Jack Murphy, age 15 and Thomas Murphy, age 13

against the Taylor Drake/Glover & Davis regime for as long as Michelle

Murphy and her supporters have.

2.4.2 The opposition that Michelle Murphy has made to the illegal and

unethical conduct of Judge Baldwin, the Glover & Davis lawyers, the


Kilpatrick Townsend & Stockton LLP lawyers, the guardian ad litem,

Elizabeth “Lisa” Harwell and others taken a heavy financial and

psychological toll upon the otherwise normal and healthy life of Michelle

Murphy, Jack Murphy and Thomas Murphy. With the help of their church

and community this family will survive, once the clutch of Judge Baldwin’s

politicalized judicial treatment is released from their throats.

2.5 It was a 15 year old kid who outwitted these hedge fund operators, the Glover & Davis lawyers, the Kilpatrick Townsend & Stockton lawyers and the guardian ad litem. 2.5.1 A financial investigator, the IRS and the Justice Department should

have a field day with the Galtere records.

2.5.2 Yea, Trevor Bishop! Yea, Trevor Bishop! Trevor, you and your friends brought the First Amendment to the United States Constitution back to Coweta County. You deserve the Pulitzer Prize for Journalistic Courage. 2.5.3 Those who purchase ink by the barrel and paper by the truck load

should honor you, Trevor Bishop, is as true friend and hero.

2.5.4 Trevor Bishop, you, your family and your friends will forever

remember the day that you stood down and exposed a judge who is violating

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

process constitutional protections.

2.5.5 Trevor Bishop, you and your family deserve the Protective Order

that this motion seeks.

2.5.6 Trevor Bishop, your friends, Jack and Thomas will someday be

free of these hedge fund operators and hopefully, the Coweta County judge

shopping type of justice. Hopefully, Jack and Thomas will have the

opportunity to show the character traits and skill that those who failed our

system of justice failed to show and be the role model that you were for


everyone in Coweta County.

2.5.7 The friends of Jack and Thomas have become Internet Reporters

and the public is no longer solely dependent upon media outlets that often

fear the lawyers who are representing Coweta County, the Sheriff, the

Probate Judge and the Clerk of Court, who are the selectors of the official

organ for very lucrative legal advertisements in the official organ for

Coweta County.

2.6 Thanks to the Free Jack and Thomas Supporters, at last, the news is out all over town

Judge Baldwin and the Glover & Davis lawyers for too long, have prevented the truth about the unfairness of the Glover & Davis

hand-selected Judges from being spread around. 2.6.1 With the Free Jack and Thomas Movement a foot, there is a now a

source of information and the case of John and Renee has run aground to

the extent that they had to place Jack and Thomas in isolation in Utah.

During the 125 days or more of the Judge Baldwin attempted alienation the

family of Michelle, Jack and Thomas have managed to survive the harshest

of judicial punishment conceivably administrated to anyone in our society

without due process of law.

2.6.2 Make no mistake in understanding, the conduct of John Harold

Murphy, Renee L. Haugerud, Elizabeth “Lisa” F. Harwell and Judge A.

Quillian Baldwin, Jr., whether they realize it or not, they are motivated by

illegal retaliation and vindictiveness. It is a disgrace that Jack and Thomas

are so brutally victimized.

2.6.3 Judge Baldwin attempted to do this by including a no contact

provision in the temporary change of custody Order. Judge Baldwin’s

Order writers, specifically, did not include a


no communication provision.

2.6.4 This Order, with legal assistance and interpretation of the Order

allowed Michelle Murphy, through various secret methods, to legally have

near daily communication with Jack and Thomas. This prevented the intent

of the Order drafters -- the alienation of the children from their mother -- to be minimized.

2.6.5 The truth about Jack and Thomas is that in just over one hundred

(125) days John and Renee have secretly placed Jack and Thomas in a

private “prison” in Utah. Doors lock behind them when they enter a room.

Children have been physically harmed at this facility, where forced

physical restraints have been used.

2.6.6 John, Renee, Elizabeth “Lisa” Harwell, the guardian ad litem, the

school at St. Thomas and Judge Baldwin could not silence the truth from

Jack and Thomas without the children being placed in the Utah RTC

“prison.”

2.7 Let’s examine the statement given by the principal of the school

attended by Jack and Thomas. Dr. Franks waited patiently to expand upon

this statement in Court. The Court would not allow any evidence from the

witnesses of Michelle Murphy at the August 6, 2013 hearing where the

witnesses awaited an opportunity to testify.

Affidavit of Jan Cox Franks Principal of Arnall Middle School

State of Georgia County of Coweta

Personally appeared before the undersigned, an officer duly

authorized by law to administer oaths, Jan Cox Franks, who after

being duly sworn, states under oath as follows.


Nancy Michelle M u r p h y (or, "Michelle Murphy"), the mot

her of Jack Malachi Murphy and Thomas Emerson Mu rphy,

requested and authorized that I release school records and fully

provide information available to me relating to her children to her

lawyer for use by the Court. Michelle Murphy explained that a

hearing is scheduled at 9:00 a.m. in the Superior Court of Coweta

Tuesday, August 6, 2013 related to matters i nvolving her, Jack

Murphy and Thomas Murphy.

I was informed that I would be subpoenaed to testify at the

hearing, if, in fact, the hearing occurred. I have been subpoenaed. I

understand that this affidavit may be tendered to the Court as part

of the record in this case.

I graduated from Mercer University in 1987 and I began my

teaching career in 1987. I came to the Coweta County School System

in 1994, teaching at Canongate Elementary School before being

named Assistant Principal at Northgate High School. In 2007, I

earned my doctorate in Educational Leadership from Argosy

University. I am currently starting my sixth year as Principal of Ellis

G. Arnall Middle School, located at 700 Lora Smith Road, Newnan,

Georgia.

Tuesday, August 6, 2013, the day of the scheduled hearing, is the

first day of the 2013-2014 school year in the Coweta County School

System. The first day of school places high demands upon a principal

of a school. I desire to honor the subpoena while fulfilling my


commitment to the parents and children attending the opening day of

school at Ell is G. Arnall Middle School.

I provide this affidavit after an extensive interview with Millard

Farmer, counsel for Michelle Murphy and Kimellen Tunkle, his

paralegal, in order to provide information about the scope of

testimony that I can provide the Court if the hearing occurs and if l

am allowed to be placed upon a thirty (30) minute call in order not

to disrupt my obligations as Principal at Arnall Middle School and

should the Court need my presence. I am very familiar with Jack and

Thomas Murphy, who are the children of Nancy Michelle Murphy

and John Harold Murphy.

I first became familiar with Michelle Murphy, Jack Murphy and

Thomas Murphy when the children enrolled at Arnall Middle School

about five days after the start of the school year in 2012. Jack and

Thomas enrolled without educational documentation due to the

unique situation when they transferred from a very small private

school in the Atlanta area. The school refused to release the transcript

of Jack Murphy for the 2011 - 2012 school year. It was reported to

me that it was not financially feasible for Michelle Murphy to obtain

the transcript from the private

school in Atlanta. This presented the problem of placing Jack

Murphy in the appropriate classes however, we were able to proceed

based on the limited information provided.

We placed Thomas in sixth grade classes with a special education

teacher in the core academic subjects such as literature class. The

special ed teacher is assigned to help special education students who


need additional accommodations in the least restrictive environment.

The teachers soon reported that Thomas did not need the co-teach

assistance and he was placed into a more appropriate class.

Jack Murphy was placed in eighth grade and was also identified

as a special education student. He was placed into classes with

special educational support. At the beginning, we felt this was an

accurate placement for him. Both boys showed steady progress.

The unique situation that Jack and Thomas faced when they began

attending Arnall required that we interface with Michele Murphy

more than we normally would with a parent. She was very concerned

that the boys would not transition well and wanted us to know her

children. She was concerned that the boys would not do well

academically and it would be a factor in the pending court case.

Michelle Murphy is what I classify as a “high frequency" parent.

We had frequent meetings with her and the children's teachers. As

we got to know them, we were able to tweak and adjust their

placement and academic expectations which we had for them. The

attached attendance records, transcripts, and CRCT scores are true

and accurate of their academic performance and attendance records

for the 2012- 2013 academic school year.

The educational advancements that they made during

the 2012-2013 should be celebrated. From where the boys came to

us at the beginning of the year, the CRCT indicated both boys had

progressed and were very capable students.

From the first day that the children were enrolled at Arnall until

the present time, Michelle Murphy has been a very active participant


as the custodial parent in the children's education. She regularly

logged into the Parent Portal, an online grading system, so she could

see the grades, homework and monitor their academic progress.

When there was a slip in the children's progress, I could expect to see

Michelle Murphy or receive a phone call to ascertain what could be

done to improve their grade. Michelle Murphy also contacted me to

obtain additional resources the boys could take to their dad's house

the week before the test to study for the CRCT.

Michelle Murphy has always been an advocate for the boys'

education and receptive to any educational resources that would help

them. She provided tutors to Thomas and Jack during the school year

and even engaged two excel lent teachers in the Coweta County

School System as tutors for Jack and Thomas during the summer

break. She felt that the children should be prepared for the upcoming

school year.

From the very beginning until today there is no question that

Michelle Murphy's heart is strongly devoted to the children's

education and wellbeing. At times, she even sought my parenting

advice about issues involving the children other than their

educational development, as I am a mother myself of older children,

and have years of experience of being involved with children in the

school system. I was readily accepted by Michelle Murphy, who

appeared to benefit from the guidance that I would offer.

In summary, the progress that Jack and Thomas made at Arnall

Middle School during the 2012-2013 school year was phenomenal. I


was excited and pleased when I received their CRCT scores and their

final grades at Arnall.

Millard Farmer and Kimellen Tunkle asked me about the absences

of the children from school. I have a computer program that tracks

the attendance of each child and the reasons for their excuses. The

absences of Jack and Thomas are not outside the State of Georgia

school attendance guidelines. When absences and tardiness occurred,

we were informed by Michelle Murphy of their necessity.

I am very confident that my professional relationship with

Michelle Murphy advanced her understanding of the bigger picture

of where the boys are going. The goal is for the children to accept

responsibility and take ownership of their educational progress and

begin becoming their own advocates. As Jack transitions to high

school for the 2013 school year and Thomas begins his year as a

seventh grader at Arnall, I know becoming an advocate for

themselves is a natural part of development and one that should be

developed. To see what Jack and Thomas have accomplished this

year, I see a very bright future for them and believe it has been a

concerted effort that has made this possible.


2.8 One of the teachers and tutors of the children gave the following

affidavit.

Affidavit of Polly Craft State of Georgia

County of Coweta

Personally appeared before the undersigned, an officer duly

authorized by law to administer oaths, Polly Craft, who after

being duly sworn, states under oath as follows.

Michelle Murphy, the mother of Jack Malachi Murphy and

Thomas Emerson Murphy, requested and authorized that I

provide information about her children for use by the Court. On

Tuesday, August 13, 2013, I am teaching at Arnall Middle

School.

I understand that this affidavit may be tendered to the Court as

part of the record in this case.


During the 2012/2013 school year I taught Jack Murphy

Language Arts and Literature that includes the subject area that

was formerly called English.

During the summer school break that just ended I tutored both

Jack Murphy and Thomas Murphy.

I have taught in the Coweta County School System for

seventeen years. Five of those years I taught in a program at the

high school level; since that time I have taught the seventh and

eighth grades.

For the last nine years, I have taught eighth grade Language

Arts and Literature at Ellis G. Arnall Middle School, located at

700 Lora Smith Road, Newnan, Georgia.

When Jack Murphy transferred to Arnall Middle School from

the private school in Atlanta in August of 2012, he was assigned

to my Language Arts and Literature class at Arnall Middle

School. As Jack was a student transferring from a different type

of school, I understood that an evaluation of his skill level was a

high priority.

I immediately detected that his writing skills were extremely

poor. He had good ideas which he could verbalize, but could not

write by hand on paper. Jack explained that he could only write

on his laptop, but not by hand. We initially allowed Jack to use

his laptop as we assessed his skills and he adjusted to being in a

new school environment. After approximately a month, we

weaned him from having to write only with the aid of his

computer.


Writing by hand with a designated level of proficiency is

required by the State of Georgia before the public school student

may advance into the ninth grade. This meant that if Jack was to

advance to high school that he would have to pass the test that

requires the student to compose thoughts in handwriting without

the use of a computer.

After numerous conferences with the professionals at Arnall

Middle School, Michelle Murphy recognized that in transferring

from Jack’s former private school to Arnall Middle School, it

would be beneficial for him to have individualized professional

assistance, as he also only had one school year to meet the State

of Georgia standards for progression from Arnall Middle School

to the ninth grade.

Michelle Murphy arranged for Jack and Thomas to be tutored

throughout the 2012/2013 school year.

During the 2012/2013 school year, I was very familiar with

Jack’s progress, as I understood the writing challenge that he

faced. I only became familiar with Thomas after the end of the

school year when I began tutoring him during the summer break.

During the school year, Jack’s tutors coordinated with both me

and Jack’s other teachers, to be sure that we addressed areas

where Jack most needed help. I was in weekly contact with Jack’s

tutors, and I believe the tutorial support was a contributing factor

in increasing Jack’s level of confidence.

By January of 2013, Jack met the State writing standards for

the eighth grade level. This was a dramatic improvement in his


writing skills from the first day that he entered my class. While

teachers in every subject area recognize the importance of their

subject area, I understand the essential necessity of good writing

skills for a student’s advance throughout their life and especially

in their academic endeavors.

Since passing the State writing standards necessary to enter the

eighth grade, Jack has grown amazingly, exceeding the State

passing grade on the CRCT test in Language Arts and Reading,

and scoring even higher in Science, Math and Social Studies.

After the end of the 2012/2013 school year, I was approached

by Michelle Murphy to tutor both Jack and Thomas during this

summer months, and to assist them in achieving academic

success. I tutored them each week, on Monday and Tuesday, for

an hour with each of them, individually. While I was tutoring

Jack, another tutor would be working with Thomas; after an hour,

we switched, and I would work with Thomas while she worked

with Jack.

We met all summer except one week when I was on vacation

with my family and another week when the children were with

their father and missed the tutoring sessions.

Having tutored Thomas for the summer, I can report that he has

both good communication skills and a solid understanding of the

basics. We focused on grammar, and some writing, which I felt

would place him in a comfortable position for the current school

year.

During the time that I was Jack’s teacher, Michelle Murphy


communicated with me on a very regular basis and certainly,

more frequently than most other parents. Michelle Murphy is very

engaged and involved in her children’s education, and is seriously

committed to promoting their education, asking for guidance

when needed.

With the commitment of Jack, Thomas, Michelle Murphy and

the tutors whom she has engaged for this present school year, the

children should continue to progress.

2.9 ---------- Forwarded message ----------

From: Stephanie King <[email protected]> Date: Sun, Aug 11, 2013 at 3:29 PM

Subject: Jack's math tutoring To:"[email protected]" <[email protected]>


To Whom It May Concern, I tutored Jack Murphy this summer on June 3, 4, 10, 11, 17, 24, 25 and on July 1, 15, 16 for one hour each day. I was paid $40 an hour for a total of $400. We reviewed all 8th grade math material that Jack scored lower than an 80% on during the 2012-13 school year and we previewed unit 1 of 9th grade math. I was asked and have agreed to tutor Jack every Wednesday for one hour at $40/hr starting on August 28 through December. I will be pre-teaching him 9th grade math so that he will be very successful in a non- collaborative setting when he starts the class in January. Stephanie King

2.10 It is relevant to compare the opportunities that Michelle Murphy, as a hair stylist with limited means, provided to Jack and Thomas during the summer school vacation before John Harold Murphy and Renee L. Haugerud contributed to the delinquency of Trevor Bishop, Jack Murphy and Thomas Murphy. 2.10.1 If Judge Baldwin had allowed Michelle Murphy to present evidence

at the May 27, 2014 hearing, even with his bias, he would have been

required to restrain his meltdown and not sent Jack Murphy and Thomas

Murphy with these hedge fund operators who drink heavily, and provide

alcoholic beverages for the children.

2.10.2 A reasonable person could make a case for John Harold Murphy

and Renee L. Haugerud intentionally attempting to get Jack Murphy and

Thomas Murphy dependent upon alcoholic beverages to the extent that

these minor children would choose to stay with them and become alienated

from their mother, Michelle Murphy.

2.10.3 When the alcoholic dependency failed, John Harold Murphy and


Renee L. Haugerud, according to the information obtained from the

Tennessee Department of Children’s Services, took the children to an

institution in Utah without consulting or even notifying their mother, who

is their custodial guardian.

2.10.4 Judge Baldwin, the guardian ad litem, Elizabeth “Lisa” F. Harwell

and the Glover & Davis lawyers, have been on notice since October, 2013

that John Harold Murphy and Renee L. Haugerud were placing the lives of

Jack and Thomas in the same danger that John and Renee place their lives

in by being alcoholics. It was the Taylor Drake/Glover & Davis lawyers

who, with very little effort, encouraged Judge Baldwin at each hearing not

to allow evidence on relevant issues. The telling aspect of Judge Baldwin

preventing evidence was that these were non-jury hearings where he was

preventing Michelle Murphy from presenting evidence. Essentially, what

was happening, was that Judge Baldwin was preventing evidence from

being heard by the public.

Thomas Murphy, October 21, 2013 2.11 While Jack and Thomas were visiting at one of the homes of John

Harold Murphy and Renee L. Haugerud located in Atlanta on a weekend in

October, 2013, Thomas Murphy almost died from alcohol poisoning. The

children obtained alcoholic beverages from an open alcohol bar. John was

“asleep” and Renee was upstairs.


2.11.1 Counsel for Michelle Murphy inquired of Taylor Drake the location

of Jack and Thomas on September 29, 2014. Taylor Drake and Elizabeth

“Lisa” F. Harwell would not reveal to counsel for Michelle Murphy the

location of Jack and Thomas. It was only the Tennessee Department of

Human Services that located the children on Friday, October 3, 1014 and

informed Michelle Murphy of their location.

2.11.2 The institution in Utah would not provide counsel for Michelle

Murphy any information about the presence of Jack Murphy and Thomas

Murphy.

2.11.3 Judge Baldwin sent Jack and Thomas to temporarily live with these

two alcoholics, John Murphy and Renee L. Haugerud, as punishment to their

Mom, with the assistance of the bad faith conduct of Elizabeth “Lisa” F.

Harwell.

2.11.4 Even the hired gun publicity person for John Murphy and Renee L.

Haugerud, could no longer publically defend the judicial conduct of Judge

A. Quillian Baldwin, Jr. and his advisors, Elizabeth “Lisa” Harwell, the

guardian ad litem and Melissa Sams, Judge Baldwin’s law clerk.

2.11.4 In their own way, each advisor of Judge Baldwin participated in

Judge Baldwin’s violations of the Code of Judicial Conduct, the Uniform

Superior Court Rules and the laws of Georgia. Once Trevor Bishop

informed the community about the conduct of John Murphy and Renee L.

Haugerud, none of Judge Baldwin’s friends and advisors could rescue him

from the quagmire into which the Taylor Drake/Glover & Davis lawyers

had led him.


2.11.5 The initial photo of Jack and Thomas on the first page of this

pleading, with the sign prepared by Jack and Thomas, was taken by a

friend. The disclosure of this photo and a phone call communication that

was broadcast live at a meeting of the Free Jack & Thomas movement

created the most illegal and serious retaliation by John Harold Murphy

and Renee L. Haugerud against Jack and Thomas since the May 27, 2014

Blame Yourself!

Blame Yourself!

Blame Yourself!

Temper Tantrum of Judge A. Quillian Baldwin. 3.1 Hear one of Judge Baldwin’s Temper Tantrum at the following link https://dl.dropboxusercontent.com/u/32260330/JudgeBaldwinAudio.mp4

4. Yes, Jack and Thomas, your mother, Michelle Murphy, should have

bought stock in the Chief Judge A. Quillian Baldwin, Jr. Politicalized

Judicial System, the Glover & Davis Bundling of political contributions to

judicial candidate’s scheme. Attachment 135 is a copy of the information

that Taylor Drake sent after Emory Palmer was elected. It was the Emory

Palmer fund raiser before the election that Judge Baldwin attended. The

following is Taylor Drake of Glover & Davis bundling effort from the

fundraiser sent to lawyers with pending case in the Superior Court of

Coweta County after Emory Palmer was elected.

4.1 A question remains as to whether the list was obtained without

payment.


4.2 There is also a substantial Salary Supplement to Judge Baldwin by

Coweta County that is represented by a Glover & Davis lawyer.

The Glover & Davis lawyers have been regular contributors to the election

committees of Judge Baldwin. Just before hand selecting Judge Baldwin

for this case, the Glover & Davis lawyers contributed to Judge Baldwin

even though he had no election opposition.

5. Yes Jack and Thomas, Judge Baldwin did sentence you to a Prisoner’s

Life. The saddest part about your prison, Jack and Thomas, is that Judge


Baldwin confined you to a life of potential alcoholic addiction that is a

prison which does not release it prisoners from its capture. Just look at PaPa

and Renee. They have money galore, but are in a prison of alcohol

addiction.

5.1 Funds Derived from the Hedge Fund Businesses of Renee L. Haugerud employed Patrick Crosby’s firm as their Public Relations and Media Consulting Firm to Oppose the Free Jack and Thomas Movement This was done in an attempt to spin the illegal conduct of Judge Baldwin in a way for it to appear that Michelle Murphy had a simple solution to Free Jack and Thomas. – Their hoax solution is for Michelle Murphy to just go to the custody evaluator selected by Lisa Harwell, who was caught illegally converting money held by her in trust to her personal use.

5.2 Patrick Crosby, before establishing his own Public Relation Firm was a Long-Time publicity spreader for the United States Attorney for the Northern District of GA

5.3 Crosby came to the first Free Jack and Thomas community meeting and stood in the shadows of the rear of the meeting in an attempt to develop a defense strategy for the temper tantrum conduct derived Order of Judge Baldwin. Crosby, then publicized a false statement. What else could he do? No rational person can defend Judge Baldwin’s conduct.

Patrick Crosby Expensive, Public

Relations and Media Consultant

Hired to Fight the Community Based Free

Jack and Thomas Movement

Crosby can publish and spread the lies of the Glover & Davis lawyers, but he can’t answer the real questions that is; Why will Judge Baldwin will not allow Jack, and Thomas to testify? Why do the children not wish to be with John and Renee and want to be with their mother?

5.4 While the classmates of Jack and Thomas are cutting blue ribbons


and painting posters on the weekends to inform the community of the need to support the Free Jack and Thomas movement, workers were hired to come outside a subsequent meeting of the Free Jack and Thomas movement to place a wad of papers on the cars of the people in the Free Jack and Thomas meeting.

5.4.1 Not so different from the Chicago Cub fans who throw back home

run balls of the opposing team, a flock of young people exited the meeting

and fetched the wad of papers and affixed blue Free Jack and Thomas

ribbons around the wad of papers containing the bell cow false statement of

the Glover & Davis lawyers and their expensive Public Relations Campaign.

The Taylor Drake, “my client is paying for the custody evaluation” false

statement characterizes the entirety of the conduct of the Glover & Davis

lawyers’ litigation strategy that their hand selected Judge Baldwin signs

onto without reading Orders that he signs.

5.4.2 Now, here is the false statement that Taylor Drake made to juice

Judge Baldwin up just before Judge Baldwin began to act as if he was a

prison warden, ordering deputy sheriffs to escort Michelle Murphy from the

premises while her children were delivered into their father’s waiting SUV

limousine.

6. “My client is paying for the custody evaluation,” Taylor Drake loudly proclaimed to Judge Baldwin. Taylor Drake knows this to be a false statement that he uses to deceive the public. 6.1 At a recent Free Jack and Thomas community meeting, counsel for Michelle Murphy read the truth about who would be liable for the custody evaluation from the Order of Judge Baldwin. It is the false statement from the Taylor Drake Glover & Davis lawyer that juiced up Judge Baldwin just before his temper tantrum erupted into even greater outburst that included his finger pointing, arm extended, shouting of “Blame Yourself! Blame Yourself! Blame Yourself!”


Taylor Drake and Judge Baldwin apparently only look at the down payment

when the make a purchase, as the Custody Evaluator Order that Taylor

Drake apparently prepared for Judge Baldwin to sign for each of the

custody evaluators states as follows.

Once the written custody evaluation is completed, it shall be

forwarded to the parties’ lawyers, the guardian ad litem, and to

Judge Baldwin. Plaintiff [John Harold Murphy] shall initially be

responsible for the costs associated with the custody

evaluation. At the final hearing in this case, the Court [Judge Baldwin] shall decide whether to

allocate the costs of this evaluation between the parties.

“Plaintiff initially being responsible” and “whether to allocate the costs of this evaluation between the parties,” being determined by the biased

Judge Baldwin, does not mean that Taylor Drake’s “client” is responsible

for the costs.

6.2 If Judge Baldwin had allowed counsel for Michelle Murphy to present

evidence, she and her counsel could have explained the nature of Taylor

Drake’s false statement to Judge Baldwin at the May 27, 2014 hearing.

Taylor Drake made the same type of false statement about the payment to

Elizabeth “Lisa” F. Harwell, the guardian ad litem at the second hearing

before Judge Baldwin.

6.3 The even more deceptive aspect of Taylor Drake’s false statement

about his “client” paying the costs of the custody evaluation is that the


Glover & Davis lawyer, Taylor Drake, did not explain the cost for Michelle

Murphy to take the deposition of the custody evaluator appointed by Lisa

Harwell and the cost to Michelle Murphy of having to employ an expert to

impeach Elizabeth Harwell’s appointed expert, Elizabeth King. The

testimony of the appointed custody evaluator, Elizabeth King, has been

denunciated when she previously testified in other cases.

6.4 These so call “custody evaluators” are talked about by the Taylor

Drake/Glover & Davis lawyers as if the work-product passes some type of

scientific test, or that it is accurate and not just another type of opinion by

a so-called expert that is not subject to verification by competent vetting.

Elizabeth King acknowledges the following “Limitations, Risks, and

Service” not provided in her contracts. She admits that the State of Georgia

has established no specific criteria and that the criteria that she employs

and the methods and procedures she utilizes have been chosen by her and

reflect in her judgment and the current state of the art in conducting child

custody evaluations. She then states that any questions about her methods

will only be answered during the initial evaluation session.

6.5 These Limitations will not qualify her as an expert witness under the

laws of Georgia. She provides on basis for the acceptance of her opinion as

and expert by the courts of Georgia while using her “criteria.”

6.6 In addition to the expensive fees for the custody evaluation, the


fee of H. Elizabeth King for her initial testimony fee at a court hearing is

$2000. The party requesting the deposition must pay for her preparation

time and appearance for testimony. Elizabeth King’s hourly fee is

$400. For testimony, she charges for either for a full day or one-half day

of her time.

6.7 Taylor Drake was required by the Rules of Professional Conduct to

truthfully represent to Judge Baldwin the liability of Michelle Murphy for

payments to the Custody Evaluator and the associated litigation costs.

Taylor Drake was deceptively dishonest in telling Judge Baldwin that his “client” was paying for the custody evaluator, when the party liable for paying the costs was to be decided at the close of the case by the judge whom Taylor Drake hand selected. 6.8 The publicity person opposing the Free Jack Murphy and Thomas

Murphy movement is being deceptive in distributing information that

Michelle Murphy is not having to pay for the custody evaluation.

If the “testing” conducted by the custody evaluator selected by Lisa

Harwell was worth a flip and could have been trusted to any degree, she

should have warned Judge Baldwin that John Harold Murphy and Renee L.

Haugerud would take Jack Murphy, age 15, and Thomas Murphy, age 13,

to the Virgin Islands and supply them alcohol and tobacco and then to

Minnesota, where their neighbor was growing marijuana that John Harold

Murphy would put on the campfire for everyone to partake.

6.9 Taylor Drake’s “custody evaluator” must have spent too much time on

such as studying the criteria used in evaluating the domestic violence by

the NFL Commissioner before that investigation was blown apart .


The Free Jack and Thomas movement actively supports Jack and Thomas.


6.10 Counsel for Michelle Murphy warned Taylor Drake and Judge

Baldwin that the Lisa Harwell/selected expert witness’ opinions would be

an embarrassment to any court. If the evaluation of John Harold Murphy

and Renee L. Haugerud ever occurred, which is doubtful, it is the source of

some of the embarrassment to the Court. If the examination of John Harold

Murphy and Renee L. Haugerud never occurred, or if it was never provided

to the Court before the May 27, 2014 meltdown of Judge Baldwin that

resulted in his temporary transfer of custody, then the bias expected from

Judge Baldwin is better exposed.

6.11 The reliability of the evaluation of John Harold Murphy and the

interview of Renee L. Haugerud is typical of the sham of the proceedings

before Judge Baldwin from the first day that he signed the initial Order

based upon John Murphy’s false assertion that Michelle Murphy was

threatening to move to South Carolina, until Judge Baldwin’s May 27, 2014

out of control, courtroom temper tantrums.

6.12 All of the attempts of Renee L. Haugerud, John Harold Murphy, the

Glover & Davis lawyers and Patrick Crosby, the PR person, to derail and

disrupt the community meetings of the Free Jack and Thomas movement

have failed and conversely have uncovered numerous other politically

motivated, egregious misconduct by the Taylor Drake/Glover & Davis

lawyers.

6.13 Those opposing the Free Jack and Thomas movement have

annihilated the First Amendment of United States Constitution protections

in the Coweta County area in order to suppress the illegal conduct and

unethical misconduct of Judge Baldwin that is financed with funds derived

from the hedge fund businesses of Renee L. Haugerud.


7. Yes Jack and Thomas, on May 27, 2014, while you were in the witness room, unknown to your Mom, Judge Baldwin was planning to capture you and have you unconstitutionally taken away by Deputy Sheriffs instead of allowing you to testify, or your In Re: Gault protections. Yes Jack and Thomas, Judge Baldwin, Elizabeth “Lisa” Harwell, John

Harold Murphy and Renee L. Haugerud have so wrecked your lives during the more than 125 days since they took you from your healthy

environment in Newnan that you have now been sent to Elevations RTC

that until May, 2014 was known as Island View Residential Treatment

Center, near Salt Lake City, Utah.


7.1 Jack and Thomas, the following took place in the Courtroom.

7.2 The motion to disqualify the first custody evaulator contained an

extensive amount of information about the cost that Michelle Murphy could

not afford, was, in part, as italized as follows.


1.7.5 If anyone believes that the ultimate cost for the custody evaluation

will not be used as a billy club to require Nancy Michelle Murphy to

surrender a right that she has, or be required to share in the payment of the

“custody evaluator,” they have not read the record of the divorce case. A

thumbnail reminder is as follows.

1.7.5.1 During the divorce there was a settlement agreement that was

announced before Judge Baldwin that he accepted relating to child

support. The agreement provided for $3,000 in child support. Due to the

absence of a Uniform Superior Court Rule 3.1, when the case reached

Judge 4 of 5, that agreement was converted to $1,500 per child with a

two year difference in the ages of the two children. That will cost Nancy

Michelle Murphy $36,000.

1.7.5.2 In the initial conference with Judge Baldwin when counsel for

Nancy Michelle Murphy explained that she could not afford the guardian

ad litem, after Taylor Drake agreed that John Harold Murphy would pay

for the guardian ad litem; Judge Baldwin signed an order without

reading it that was prepared by Taylor Drake. That Order made Nancy

Michelle Murphy liable with John Harold Murphy for paying the

guardian ad litem.

1.8 The cost for the deposition of the “custody evaluator” is prohibitive

for Nancy Michelle Murphy. If the “custory evaluator” provides a report

that is favorable to Nancy Michelle Murphy, Jack Murphy and Thomas

Murphy, she will be unable to afford the court testimony.


2. The Requirement for a “Custody Evaluator” in this Case is Only a Punitive Act Against Nancy Michelle Murphy by Judge Baldwin, at the Punitive Request of Elizabeth “Lisa” F. Harwell 2.1 The Coweta Judicial Circuit has numerous domestic litigation cases with

extremely difficult child custody issues and custody evaluators have not been

financially inflicted upon the litigants in any of the cases.

2.1.1 Elizabeth “Lisa” F. Harwell sought revenge against Nancy

Michelle Murphy and a billing opportunity for herself after the expert

witnesses of John Harold Murphy, a psychiatrist and a psychologist, failed

to provide the Court any justification for a modification. The only

information that Elizabeth “Lisa” F. Harwell secured was that Nancy

Michelle Murphy was opposed to the academic doping inflicted upon the

children by what the community calls a “pill pushing” doctor. This

psychiatrist has a history of substance abuse for which the psychiatrist has

been disciplined in Illinois.

2.1.2 For no reason relating to the best interest of the children and for

reasons relating to personal retaliation against Nancy Michelle Murphy

and her counsel, Elizabeth “Lisa” Harwell seeks to have the burden of the

“custody evaluator” inflicted upon Nancy Michelle Murphy and the

children.

2.1.3 Anyone who has followed this litigation and knows anything about

Judge Baldwin knows that Judge Baldwin doesn’t read orders that he signs

and that he gives little or no value to the opinion of a psychologist. Judge

Baldwin does not even keep current about the law and certainly knows little

about the discipline of psychology, as it relates to a psychologist using the

moniker of “custody evaluator.”


2.1.3.1 The employment of this psychologist will only require the

employment by Nancy Michelle Murphy of a psychologist to review the

reports and to testify. This is an expense that Nancy Michelle Murphy

cannot afford.

2.1.4 As soon as Judge Baldwin hears about the lifestyle and cult beliefs

of Renee L. Haugerud, this case ends, as no judge in the Coweta Judicial

Circuit is going to grant more visitation with adults who live as Renee L.

Haugerud and John Murphy live, even though they are multimillionaires.

2.1.5 Elizabeth “Lisa” F. Harwell became angry when she could not

inflict misery upon Nancy Michelle Murphy for the exposure of the illegal

attempt by Elizabeth “Lisa” F. Harwell to usurp the authority of a Superior

Court Judge and order that the children be required to stay with John

Harold Murphy during the first week of a school in Atlanta last year, and

ever angrier with the continual exposure of her illegal misconduct.

2.1.6 An important issue is that John Harold Murphy is too slick for

Nancy McGarrah.

7.3 In addition to detailing the costs of participating in a custody

evaulation with the evaulator being selected by an opponent appearing

before a hand picked judge, there have been numerous attempts to obtain a

certificate of immediate review from Judge Baldwin. He has denied each

motion to obtain a certificate of immediate review. An example motion for

such certificate of immediate review is Attachment 136. 7.4 The Code of Judicial Conduct and the Uniform Superior Court

Rules provide protections to litigants from the conduct of jurists such as

Judge Balwin; however, Judge Baldwin has never allowed any of the

numerous motions to disqualify him to be reviewed by an independent


jurist.

8. The latest gimmick of the Taylor Drake/Glover & Davis lawyers is

to file a motion to delay adjudication of a disqualification motion

accompanied by a request to brief the disqualification issue. This both

delays a prompt resolution and defeats the purpose of the jurist promptly

rendering an opinion and proceeding accordingly. The Taylor Drake/

Glover & Davis lawyers wrote the following letter to Judge Baldwin

requesting relief that he immediately granted.

GL OV E R & DAV I S , P.A .

ATTOR N E.YS AT LAW

ESTABLISHED 1 935

P.O. DRAWER 1038 I 0 BROWN STREET NEWNAN, GEO RGIA 30264

TELEPHONE (770) 683-

FACSIM ILE (7 70) 683-

www.gloverdavi

September 19, 2014

VIA ELECTRONIC MAIL ONLY

Honorable A. Quillian Baldwin, Jr. Coweta Judicial Circuit 100 Ridley Avenue Suite 2700 LaGrange, Georgia 30240

RE: John Murphy vs. Michelle Murphy

Civil Action No. 12-V-413 Superior Court of Coweta County


Dear Judge Baldwin:

The purpose of this letter is to reply preliminarily to the "September 11, 2014 Motion for Disqualification of Chief Judge A. Quillian Baldwin, Jr. Plea to Personal Jurisdiction and Other Relief ' filed by Michelle Murphy (the "September 11 Disqualification Motion"). My client intends to respond fully to the September 11 Disqualification Filing in accordance with the normal 30-day response time of Superior Court Rule 6.2.

As the Court will recall, in correspondence dated August 13,

2014, my client requested that he be given the full 30-day response period to reply to Ms. Murphy's August 11 Recusal Motion. My client requested the full response time, not because the August 11 Recusal Motion had any more merit than any of the multitude of prior recusal motions filed by Ms. Murphy (it does not), but rather to provide the Court with full briefing on (a) the impact and preclusive effect of the multiple intervening rulings in the various appeals and appellate motions Ms. Murphy unsuccessfully has pursued; and (b) additional judicial tools available to the Court to limit and manage Ms. Murphy's continued filing of repetitive, baseless motions.

On the afternoon of August 13, 2014, this Court gave Mr. Farmer

until 5:00 p.m. on August 18, 2014 to respond. Mr. Farmer failed to comply with the deadline established by the Court. When he did respond at 6:11 p.m., Mr. Farmer did not address the issues raised by Mr. Murphy as to which the Court had requested a response. Instead, and consistent with his typical approach, Mr. Farmer submitted yet another lengthy and frivolous disqualification request. Mr. Farmer's filing of yet another baseless request for disqualification confirmed precisely why it is imperative that this Court embrace and apply the full effect of the appellate rulings in this case

Honorable A. Quillian Baldwin, Jr. September 19, 2014

Page 2


and examine carefully the full range of judicial tools available for dealing with the continuing stream of frivolous filings by Ms. Murphy and Mr. Farmer.

Accordingly, on August 21, 2014, I notified the Court that my client would be responding to both of Mr. Farmer's overlapping and duplicative disqualification motions by September 22, 2014 (30 days after service of Mr. Farmer's August 18 Disqualification Filing).

On September 11, 2014, Mr. Farmer filed another lengthy and

frivolous disqualification motion, superseding and supplanting his August 11 and August 18 disqualification requests. As a result, my client hereby notifies the Court and counsel that, rather than filing multiple responses, he intends to file one single integrated response to all three of Ms. Murphy's most recent overlapping recusal requests ( i.e., the August 11 Recusal Motion, the August 18 Disqualification Filing, and the September 11 Disqualification Motion) by October 13, 2014 (30 days after service of the September 11 Disqualification Motion). If the Court desires an earlier consolidated response, please let me know.

Respectfully

submitted, GLOVER

& DAVIS, P.A. Attorneys for Plaintiff

cc: Millard Farmer, Esq. (via email

only) Elizabeth Harwell, Esq. (via email only)

8.1 The letter motions of the Taylor Drake/Glover & Davis lawyers follow

a pattern of their failure to adhere to the Uniform Superior Court Rule 6.1


that provides as follows.

USCR 6.1. Filing of Motions 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. In circuits utilizing an individual assignment system, the clerk shall promptly upon filing furnish a copy provided by the attorney of such motions and related materials to the judge.

8.2 Upon receiving the motion to disqualify him, Judge Baldwin’s

obligation was as follows.

USCR 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.

Canon 3(E) guides Judge Baldwin 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:

Judge Baldwin’s same day grant of an Order essentially granting himself a


continuance while he awaits for the Taylor Drake/Glover & Davis lawyers,

or some other party to write him an Order is a another disqualifying act by

Judge Baldwin.

8.3 The Order that Judge Baldwin signed in response to the letter motion

of the Taylor Drake/Glover & Davis lawyers is based upon OCGA §9-11-

6 (b) that is as follows.

9-11-6 (b) Extension of time

When by this chapter or by a notice given thereunder or by order of court an act is required or allowed to be done at or within a specified time, the parties, by written stipulation of counsel filed in the action, may extend the period, or the court for cause shown may at any time in its discretion (1) with or without motion or notice, order the period extended if request therefor is made before the expiration of the period originally prescribed or as extended by a previous order, or (2) upon motion made after the expiration of the specified period, permit the act to be done where the failure to act was the result of excusable neglect; provided, however, that no extension of time shall be granted for the filing of motions for new trial or for judgment notwithstanding the verdict.

8.4 The Judge Baldwin Order that allows him to await for a scribe


follows.

8.5 The Taylor Drake/Glover & Davis lawyers have found a way to violate

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

Code of Georgia with their most recent gimmick that counsel for Michelle

Murphy has never experienced.

8.6 The question in this case is, just what type of Custody Evaluation

would have ever cleared these two alcoholics, John Harold Murphy and

Renee L. Haugerud to have become the caretakers of Jack Murphy and

Thomas Murphy, as a priority to Michelle Murphy? The answer to that

question is the answer to the reason that only an incompetent lawyer would

have advised Michelle Murphy to have risked her financial resources by

signing a contract with any custody evaluator selected by Elizabeth “Lisa”

Harwell, who is the guardian ad litem who converted trust money to her

personal use in violation of Uniform Superior Court Rule 24.9(8) (g).


8.7 Yes, Jack and Thomas, your mother’s counsel attempted to allow

your Mom to present evidence to Judge Baldwin about the lifestyle in

which John Harold Murphy and Renee L. Haugerud, would be placing you

in the Virgin Islands, Minnesota, Tennessee, and New York.

9. Intimidation of Witnesses by the Taylor Drake/ Glover & Davis lawyers is Prevalent. This Motion Seeks a Protective Order 9.1 The Taylor Drake/Glover & Davis lawyers are actively attempting,

under the guise of litigation conduct, to threaten persons whom they admit

are potential witnesses for assisting in exposing to the public the abusive

treatment that Jack Murphy, age 15, Thomas Murphy, age 13 are receiving

by John Harold Murphy and Renee L. Haugerud.

9.2 The most recent intimidation conduct requires a Protective Order for

Plaintiff’s First Request for Production of Document and Things to Non-

Party Trevor Bishop, Attachment 137; and, Plaintiff’s First Request for

Production of Document and Things to Non- Party Christy Bishop,

Individually and on behalf of Trevor Bishop, Attachment 138.

Michelle Murphy seeks a Protective Order for these two requests in order

that these witnesses will not be further intimidated by those acting on behalf

of Renee L. Haugerud, who has previously engaged in acts designed to

deter the testimony of these witnesses.

9.2.1 The following Taylor Drake/Glover & Davis lawyers’ additional

letter to another person whom they have designated as a potential witness

follows.

9.2.2 Incidentally, this potential witness is a person who was victimized

by the custody evaluator whom Chief Judge A. Quillian Baldwin, Jr.


ordered Michelle Murphy to see, H. Elizabeth F. King the “custody

evaulator.”


* * * See complete letter at, Attachment, 131. 9.3 The failings of our judicial system create this necessity to bring

international attention to the unfairness of a judicial system to children. The

treatment of Jack Murphy and Thomas Murphy, with the appointment of

Elizabeth “Lisa” F. Harwell has been child abuse and legal malpractice by

Elizabeth “Lisa” F. Harwell, as she has not reported this conduct.

9.3.1 No competent guardian ad litem would have allowed Jack

Murphy, age 15, Thomas Murphy age 13 to have been forced into the car

driven by a drunk John Harold Murphy, to have ridden home, without

removing these children from the care of John Harold Murphy and Renee

L. Haugerud.


9.3.2 No competent guardian ad litem would have allowed Jack Murphy,

age 15, Thomas Murphy age 13 to have been whisked away to the Virgin

Islands without constant supervision.

9.3.3 It is a shame that Jack Murphy, age 15, and Thomas Murphy, age

13, have had to be the canaries in the coal mine to publically expose the

ineptness of the domestic relations system in the State of Georgia to protect

children.

9.3.4 This public attention to the judicial misconduct of Chief Judge

Baldwin has resulted and continues to result in information relating to other

perceived judicial misconduct, some of which involves Judge Louis Jack

Kirby and his appointment of Elizabeth “Lisa” F. Harwell, as the guardian

ad litem in other Coweta Judicial Circuit cases.

9.3.5 Some of the public accounts of judicial misconduct come from

outside the Coweta Judicial Circuit, about the conduct of guardians ad litem

and the unfairness of the so called “custody evaluators.”

9.4.The Contractual obligation of John Harold Murphy to Michelle Murphy

is memorialized in the Superior Court of Troup County Georgia. This final

decree and the Contractual Agreement made the Order of the Court is

Attachment 139.


9.5 As a part of the consideration for entering into this agreement that was

less than the oral agreement announced in open court and far less Michelle

Murphy’s one-half share of the $180,000 value of stock options that John

Harold Murphy, with a perjured affidavit, secreted from Michelle Murphy

until the day after the oral settlement agreement was announced in open

court, but not made the order of the Court until the settlement contract

providing Michelle Murphy $1,500 per month in child support was made

enforceable by contempt by the December 20, 2014 Order.9.5.1 The

financial aspects of the Settlement contract provide $1,500 per month , per

child, as child support until the children reach 18, die, marry, etc. None of

the conditions have occurred.

9.5.1 Taylor Drake and the Glover & Davis lawyers raised the issue of

John Harold Murphy not making the August 1, 2014 child support payment,


but thought better of this illegal act and John Harold Murphy made the

August 1, 2014 payment, as due.

9.5.2 After the Taylor Drake / Glover & Davis lawyers indicated that John

Harold Murphy would not provide Michelle Murphy her September 1, 2014

child support payment, counsel for Michelle Murphy sent the following

e mail to the Taylor Drake/ Glover & Davis lawyers

From: Millard Farmer <[email protected]> Sent: Friday, September 05, 2014 10:32 AM To: 'Taylor Drake' Subject: Second Request for waiver of service. This is a debt collection notice Hi Taylor, I will file the contempt petition today, as one of the remedies to collect the September 1, 2014 child support payment, if you do not commit to have the check sent today. The question is, will you waiver service, or do you wish from me to have it served? Your wait and see answer was not adequate. The rent payment is due and John Harold Murphy and Renee L. Haugerud are only attempting to make it difficult for Michelle. Millard [email protected] 404 688-8116

9.5.3 As the result of the e-mail from counsel for Michelle Murphy, the

Taylor Drake/Glover & Davis lawyers wrote the following letter Motion to

Chief Judge Baldwin seeking a pseudo-declaratory judgment without

complying with the Georgia Civil Practice Act or the Uniform Superior

Court Rules.

.



9.5.4 The letter Motion above is nothing but a pseudo-motion for a

declaratory Judgment. “Guidance from the Court” is a declaratory

judgment. There is nothing in the Order from the May 27, 2014 hearing

attempting to breach the settlement agreement contract that John Harold

Murphy had with Michelle Murphy.

9.5.5 Counsel for Michelle Murphy responded to the Glover & Davis

letter request for an advisory opinion as follows.

From Millard Farmer <[email protected]>

Sent: Friday, September 05, 2014 9:12 AM

To: 'Taylor Drake'; '[email protected]'; 'Peter Durham'

Cc: 'Quillian Baldwin'; 'Melissa Sams '

Subject: RE: Waiver of Service Request

Attachments: Order of Superior Court of Troup County Contractual Agreement.pdf


Hi Taylor,

If you wish, a declaratory ruling, advisory opinions or other relied, please

file motions with the Court.

A cut from the 2006 Judgment that you wish “clarified” is out-of-term.

There was no evidence to support any clarification, as Michelle Murphy

was not allowed to present evidence.

Michelle Murphy is entitled to the protection of the Civil Practice Act and

the Uniform Superior Court rules.

Courts are not short order take out services. The child support payment is

necessary for the upkeep of the residence of the children. See, the attached

contractual agreement that was made the order of the Court.

Follow the Order of the Court. There is no basis for your letter writing

campaign with the court. I will respond to your motions.

By responding to your letter, Millard Farmer, Larry King and Michelle

Murphy do not waive the protections provided to them by the supersedeas,

their pleas to the personal jurisdiction of Judge Baldwin.

Millard

[email protected] 404 688-8116 9.5.6 The Advisory Opinion of Chief Judge Baldwin that triggers a

motion for his disqualification, which incorporates all previous motions for

his disqualification is as follows.

9.5.7 From Chief Judge Baldwin to Counsel for the Parties: Dear Millard and Taylor: In response to your letters and emails concerning the payment of child support, I think the reason child support was not addressed at the May 27, 2014 hearing was, in the heat of the moment, no one thought to bring the issue up. It is


unfortunate that out of the three of us, one of us did not bring up the issue of child support because it would certainly make things easier at this point.

It seems to me that Millard is correct in that I cannot just summarily without a hearing, stay Mr. Murphy’s obligation to pay Ms. Murphy’s child support. However I do think that Mr. Murphy has several defenses to any contempt actions filed against him for such child support.

While I have not looked at the law about this in a while, it has been the

law in the past that the one who is in contempt is precluded from bringing an action of contempt against the other party. Also a defense to a contempt action is not being in willful contempt or having some reasonable excuse for not having paid child support.

Whether those are valid defenses in this case, I am not sure because I

haven’t had the opportunity to research them but before either one of you went to court on this child support issue, I suggest you look into those situations.

Yours Very Truly, A. Quillian Baldwin, Jr.

9.5.8 After obtaining the favorable advisory opinion, the Taylor

Drake/Glover & Davis lawyers brought two formal motions, neither of

which complied with Uniform Superior Rule 6.1’s affidavit requirements.

See Attachment 132. The Glover & Davis lawyers filed a

“Clarification” motion, after obtaining Chief Judge Baldwin’s illegal and

unethical advisory opinion on the child support funds being withheld

from Michelle Murphy, which funds are contractually required and

necessary to advocate for the best interest of the children, who have no

protection from the Court or the guardian ad litem.


See Attachment 133, which was filed to keep funds from Michelle

Murphy to fight the illegal and unethical conduct of Chief Judge Baldwin.

10. It was the public exposure of the Illegal Conduct of John Harold Murphy, Renee L. Haugerud and Regulatory Complaints about Chief Judge A. Quillian Baldwin, Jr. that Ignited the Combined, Most Severe Financial Attacks upon Michelle Murphy and upon her counsel. 10.1 The Taylor Drake/Glover & Davis lawyers sought to require Larry

King to post a $521,000 bond in order to retire from the practice of law.

See Attachment 130. 10.2 Michelle Murphy responded to this threat by the Taylor

Drake/Glover & Davis lawyers with notice that such action would result in

federal judicial protection. 10.2.1 Judge Baldwin did not bite into the bait of the Taylor

Drake/Glover & Davis lawyers and allowed Larry King to retire, as the

law clearly allowed. Larry King did not have to post a bond, although

Judge Baldwin did place a hand written asterisk on the typed order to a

hand note that Larry King would remain liable for the amounts claim if

the amount were ultimately adjudicated.


10.3 Renee L. Haugerud and her lawyers sought to Intimidate and Did Offer Financial Benefits to Witnesses of Michelle Murphy long before the letters to the potential witnesses and potential defendant identified earlier in this motion.

10.3.1 These earlier offers by and on behalf of Renee L. Haugerud

were to squelch the evidence against John Harold Murphy at a scheduled

legal proceeding and to deter any action against Renee L. Haugerud by

providing her counsel with a conflict of interest created by counsel’s

paymaster, Renee L. Haugerud.

10.3.2. It was reported to counsel for Michelle Murphy that both Renee

L. Haugerud and one of her counsel, who has been an observer at the

hearings and was aware of the legal issues, offered the services of a

lawyer to be paid by the interest of Renee L. Haugerud to the mother of

one of the prime witnesses about the illegal, abusive conduct of John

Harold Murphy that was endangering the lives and contributing to the

delinquency of Jack Murphy, age 15 and Thomas Murphy, age 13 and a

minor child who, at the specific invitation of and payment by Renee L.

Haugerud, had been visiting in the residence of Renee L. Haugerud, the

spouse of John Harold Murphy.

10.3.3 Make no mistake in understanding the above paragraph. It was

reported that William R. Poplin, Jr. of Kilpatrick Townsend & Stockton

LLP, was an active participant in the planning and participating in

conduct of Renee L. Haugerud.

10.3.4 In addition to placing the Federal Bureau of Investigation on

notice about the witness tampering conduct of Renee L. Haugerud, et al.,

an extensive emergency motion, as amended, was filed, with the


reservation of a challenge to the personal jurisdiction of Chief Judge

Baldwin. Fiduciaries such as Renee L. Haugerud cannot engage in the

conduct in which she engages and finances her attorneys and John Harold

Murphy to engage. There are forums to address their conduct.

NOTE: Chief Judge A. Quillian Baldwin, Jr. and the guardian ad litem, Elizabeth “Lisa” F. Harwell, were placed on notice of the Illegal Conduct of John Harold Murphy and Renee L. Haugerud in a Verified Legal Pleading concerning the conduct of Renee L. Haugerud relating to the attempt to interfere with a witness.

10.3.5 The emergency motion, as amended, placed Chief Judge A. Quillian

Baldwin, Jr. on notice of some of the following misconduct of John Harold

Murphy and Renee L. Haugerud. The conduct of John Harold Murphy and

Renee L. Haugerud endangered the health and welfare of the minor children

that contributed to the delinquency of the minor children in their custody.

10.3.6 The emergency motion, as amended, placed the guardian ad litem,

Elizabeth “Lisa” F. Harwell on notice of some of the following misconduct

of John Harold Murphy and Renee L. Haugerud. The guardian ad litem,

Elizabeth “Lisa” F. Harwell, acted in bad faith with a serious conflict of

interest, due, in part, to her appointment by Judge Louis Jack Kirby to

another paid appointment as guardian ad litem. It was Judge Kirby that

recommended that John Harold Murphy employ Taylor Drake.

10.4 That emergency, ancillary motion contained many attachments,

including affidavits and communications from the children of Michelle

Murphy that signaled their distress created by being with John Harold

Murphy and Renee L. Haugerud in St. Thomas, USVI.

10.5 The USVI equivalent to the Department of Family and Children

services was called to address the misconduct of John Harold Murphy and


Renee L. Haugerud. The investigator observed the busted lip of Thomas

Murphy, walked outside and talked with John Harold Murphy and came

back and took a photo of the opposite side of Thomas Murphy’s face.

10.5.1 That June 9, 2014 supplement identified the attack upon Thomas

Murphy, age 13 and information about Renee L. Haugerud requiring

Thomas Murphy, as punishment, to stay on the beach, getting sunburned,

until he smiled for a photo that she wished to take. This information was

enough to alert any competent guardian ad litem to obtain independent

information from the children.

10.5.2 Both of the motions were served upon the guardian ad litem,

Elizabeth “Lisa” F. Harwell, and the Taylor Drake/Glover & Davis lawyers.

10.5.3 These requests for a stay provided more than adequate notice to

the guardian ad litem, Elizabeth “Lisa” F. Harwell, to Renee L. Haugerud,

John Harold Murphy and the Taylor Drake/Glover & Davis lawyers that

John Harold Murphy and Renee L. Haugerud were engaged in abusive

conduct to the minor children, whose best interest Elizabeth “Lisa” F.

Harwell should have been protecting rather than using her appointment as

guardian ad litem for the purposes of her financial gain and benefit for her

other clients whom she represents before Superior Court Judge Louis Jack

Kirby and her appointments to other guardian ad litem positions.

Remember, it was Judge Louis Jack Kirby, who referred John Harold

Murphy, his former client, to Chief Judge Baldwin.

10.5.4 It is sad beyond words that it took the intestinal fortitude of a

young child, Trevor Bishop, to attempt to accomplish what Chief Judge

Baldwin and his so called guardian ad litem are paid to do. Trevor Bishop


and his family did not allow the immense wealth of Renee L. Haugerud to

reset their moral compasses.

11. Michelle Murphy filed her July 31, 2014 Emergency Motion for Relief from John Harold Murphy and Renee L. Haugerud Contributing to the Delinquency of Minors in the Superior Court of Coweta County.

11.1 That Superior Court of Coweta County motion was hand delivered

to the office of Chief Judge A. Quillian Baldwin, Jr. before it was filed on

Thursday, July 31, 2014. Chief Judge Baldwin was out of town on that day

at a conference.

11.1.2 In addition to being hand delivered to the office of Chief Judge

A. Quillian Baldwin, Jr., the Chief Judge of the Coweta Judicial Circuit, the

Emergency Motion was electronically sent to Melissa Sams, the law clerk

of Chief Judge Baldwin, to Julia Harris, the secretary of Chief Judge

Baldwin and to Chief Judge Baldwin, who does not know how to operate a

computer, or e-mail.

11.1.3 It is not believable that Chief Judge Baldwin did not have notice

of the Emergency Motion and that he chose to play golf rather than

attempting to have someone contact counsel for Michelle Murphy while

John Harold Murphy and Renee L. Haugerud were in Chattanooga before

they returned to St. Thomas, USVI.

11.2 On Monday, August 4, 2014, Chief Judge Baldwin initiated a

conference call to counsel for Michelle Murphy and counsel for John

Harold Murphy.

11.2.1 By the time of the conference call with Chief Judge Baldwin on

Monday, August 4, 2014, counsel for Michelle Murphy had obtained more


supporting information about John Harold Murphy and Renee L. Haugerud

contributing to the delinquency of minors, Jack Murphy, age 15 and

Thomas Murphy, age 14. The children had also been subjected to more

abusive treatment. This may seem minor to Chief Judge Baldwin, but this

is the reason that there must be a duty judge and the reason that Chief Judge

A. Quillian Baldwin, Jr. fails to fulfill his judicial responsibilities to the

people of Coweta County and people in the Coweta Judicial Circuit.

11.2.2 On Monday, August 4, 2014, Chief Judge A. Quillian Baldwin, Jr.

scheduled a hearing for the July 31, 2014 Emergency Motion of Nancy

Michelle Murphy. After the scheduling of that hearing, and the initial

procedural Order, Chief Judge Baldwin issued a new and quite different

procedural order that further deprived 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 (Ga. Const.

Art. I, § 1, ¶ 1), and the laws of Georgia that also 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.

11.2.3 As a part of the constitutional protections of Jack Murphy and

Thomas Murphy that are being protected are also those that Elizabeth

“Lisa” F. Harwell is required to protect under the children’s Sixth

Amendment and State of Georgia statutory protections.


11.2.3.1 John Harold Murphy and Renee L. Haugerud are requiring

the minor children engage in illegal conduct. The children are entitled to

legal counsel to protect them from being charged with illegal conduct.

11.2.3.2 Elizabeth “Lisa” F. Harwell is providing these minor

children ineffective assistance of counsel and is engaging in legal

malpractice and bad faith by not representing their best interest in her role

as a lawyer, and also violating their constitutional and statutory rights as

a custody decision maker.

11.2.4 When a guardian ad litem calls upon her malpractice insurance

carrier, as Elizabeth “Lisa” F. Harwell has, to defend her conduct during

her guardian ad litem services, the time has arrived for that guardian ad

litem to be replaced and the Court to provide a hearing on the

disqualification of the guardian ad litem whereby evidence is allowed;

Chief Judge Baldwin has failed to do this, as he prefers a guardian ad litem

whose independent judgment is weakened to the extent that Chief Judge

Baldwin illegal and unethical conduct is not exposed.

11.2.5 Consistent with Chief Judge Baldwin’s absence of understanding

appellate procedure, and/or his intentional deceptive statements of law,

Chief Judge Baldwin Order stated as follows to the public.

The Court of Appeals has upheld Judge A. Quillian Baldwin to be fairly and justly presiding over this case as well as the Guardian ad Litem, Elizabeth Harwell, to be representing the children.

11.2.5.1 Judge Baldwin’s above statement is a misstatement of law for

two reasons: first, the remittitur has not been returned to the Superior

Court of Coweta County; and, second, the Notice of Intention to file for

a Petition for Writ of Certiorari has been filed.


11.2.6 The disclosure of the confidential informant resulted in the illegal

conduct of Renee L. Haugerud and one of her attorneys in offering financial

benefits to potential witnesses and attempting to intimidate potential

witnesses. Most likely, this was included to determine the extent of the

knowledge that counsel for Michelle Murphy had obtained about the

misconduct of the lawyers.

11.2.6.1 The Order of Chief Judge Baldwin goes further as follows.

Fourth, the Guardian ad Litem (GAL) after her investigation of the allegations and the children shall report to the court and the parties by Monday, August 11, 2014 by 12:00 p.m. whether or not she recommends it is in the best interest of the children to participate in the hearing on Wednesday, August 13, 2014.

11.3.6 This provision of the Order substantially differs from the

commitment of Chief Judge Baldwin and is a violation of equal protection

and Due Process protections, as the Rule Nisi issued by the Court places the

burden upon Michelle Murphy to produce evidence as follows.

RULE NISI Defendant having filed a motion for emergency hearing based on allegations of abuse and neglect on the part of the Plaintiff, the Court has scheduled a hearing to resolve these concerns. The Defendant is ordered to show cause, if any she can, on Wednesday, August 13, 2014 at 10:00 a.m. at Coweta County Justice Center, 72 Greenville St., Newnan, Georgia 30264 in a courtroom to be designated that morning why her emergency relief should be granted.

11.3.7 The Taylor Drake/Glover & Davis lawyers in addition to

attempting to quench information in public forums brought a motion to have

Chief Judge A. Quillian Baldwin to disallow any hearing about the abusive

treatment of Jack Murphy, age 15 and Thomas Murphy, age 13. This Motion


of Taylor Drake to Cancel the August 13, 2014 Hearing, without its

attachments, is Attachment 134 11.3.8 At this stage of the attempts to disqualify Chief Judge A. Quillian

Baldwin, Jr., he has pretenses of fairness, as he is only attempting to hold

on to his Chief Judge and judicial position. It will be a disgrace upon the

judicial system worse than the recent disgrace inflicted upon the Ethics

Board and Attorney General of Georgia, if A. Quillian Baldwin, Jr. is

allowed to continuing placing scars upon the lives of Jack Murphy, age 15

and Thomas Murphy, age 13.

11.3.9 When litigants are not provided a process to determine the

fairness of our judicial system, they are only left with their First Amendment

protections to exercise in a public forum.

11.3.10 Michelle Murphy is gaining public support to “Free Jack and

Thomas.” The danger is, as the public support is revealing, there are other

“Jack and Thomas” victims of judicial misconduct.

11.3.11 This requirement upon Michelle Murphy emphasizes the

absence of Due Process protections accorded Michelle Murphy when, upon

objection from Taylor Drake, Chief Judge Baldwin would not allow counsel

to determine the residences of John Harold Murphy and when counsel

attempted to have the appearance of Renee L. Haugerud, Chief Judge

Baldwin would neither provide for her appearance, nor require her to appear

before the “custody evaluator,” as Michelle Murphy was ordered to appear.

11.3.12

The transcript of John Harold Murphy’s cross-examination, from its

beginning reflects as follows.

Examination


BY MR. FARMER: Q. Would you please state your name? A. John Murphy. Q. Would you please speak up? I’m sorry. We can’t hear you. A. John Murphy. Q. And would you please tell me where you have residences. MR. DRAKE: Your Honor, I object. That has absolutely – THE COURT: I agree. MR. DRAKE: -- nothing to do with the issue before this Court. THE COURT: Look, look. I swear. I’ve never – Gosh darn. I try to be as fair as I can be, but that has nothing to do with whether she needs a mental evaluation. Have you got some question that has something – MR. FARMER: Yes. I want to know where he lives. THE COURT: -- to do – Well, I’m sorry. But that’s not relevant. Look. You’ve asked him those questions before. MR. FARMER: No, I haven’t. THE COURT: Well, maybe you haven’t. I know the issue has come up before, but – MR. FARMER: The problem is this. THE COURT: Look. We’re not going to argue about that. We’re not going to talk about that. Do you want to ask him any questions that show that we should not require her to have a mental evaluation? MR. FARMER: Am I entitled to ask him where he has residences? THE COURT: No. That doesn’t have anything to with this hearing. BY MR. FARMER: Q. Do you live with someone – THE COURT: That doesn’t have anything to do with this – MR. FARMER: Your Honor, if they’re going to be in the house with him – THE COURT: That – that’s – Look. When we have the custody evaluation, you can bring that up all you want. That has nothing to do with the issue that we’re here for today. MR. FARMER: Your Honor, let me just make sure we understand each other. THE COURT: All right. I’m sorry, but it’s just – I don’t think – MR. FARMER: No. THE COURT: -- it could be any plainer. But go ahead. MR. FARMER: Okay. I understand. But what – THE COURT: Well, you said you didn’t understand.


MR. FARMER: I understand— THE COURT: Do you understand or not understand? MR. FARMER: I don’t understand, and I don’t accept that you’re being fair to us. THE COURT: Well, I’m sorry about that. Tr. March 17, 2014, p. 114, line 10 – p. 116, line 18.

11.3.13 The endangerment of the children extends to Jack Murphy, age

15, with a learners permit, driving Renee L. Haugerud home, as she was too

legally intoxicated to drive.

11.3.14 Counsel for Michelle Murphy attempted to impress upon Chief

Judge Baldwin the danger of not bringing the children back to Georgia

immediately. Chief Judge Baldwin is still mentally blinded by the political

and financial benefits that he has historically received from the Taylor

Drake/Glover & Davis lawyers.

11.3.15 Chief Judge Baldwin, instead of providing the children a

protective environment to reveal their abusive conduct, Chief Judge

Baldwin, over strong objection from counsel, chose to send Elizabeth “Lisa”

F. Harwell to interview the children.

11.3.16 The children, for just cause, do not trust Elizabeth “Lisa” F. Harwell,

as she was first deceptively introduced by John Harold Murphy and Renee

L. Haugerud to the children on her infamous trip to Chattanooga as a friend

of John Harold Murphy and Renee L. Haugerud. At the present time, Renee

L. Haugerud is truly a friend of John Harold Murphy (or, “Murph,” as she

calls him) and Renee L. Haugerud.

12. The disqualifying conduct of Chief Judge Baldwin at the Monday, August 4, 2014 phone conference. 12.1 As usual, Chief Judge Baldwin, at the beginning, feigned that his law

clerk, and supporting staff had not provided him information about the


emergency motion (filed on Thursday, July 31, 2014) until that Monday

morning and certainly none of his staff had talked with any of the Taylor

Drake/Glover & Davis lawyers. The Taylor Drake, et al, ex parte staff

conduit to Chief Judge Baldwin is not supported by evidence in this motion,

nor is it eliminated as later available evidence with this comment.

12.2 Upon oral request of Michelle Murphy, Chief Judge Baldwin refused

to allow counsel for Michelle Murphy to talk with Jack Murphy, age 15 and

Thomas Murphy, age 13 before the hearing set for Wednesday,

August 13, 2014 without Taylor Drake being on the phone call. This is

disqualifying conduct by Chief Judge Baldwin, as it is a continuum of the

biased conduct of Chief Judge Baldwin that is included in the previous

motions to disqualify Chief Judge Baldwin.

12.2.1 After the filing of the Emergency Motion, the children were

moved from Chattanooga, Tennessee to St. Thomas, USVI.

12.2.2 John Harold Murphy threatened Jack Murphy, age 15 with being

put in a foster home, if he made statements about him and Renee L.

Haugerud.

12.2.3 The children have reported that John Harold Murphy has

displayed to them a letter from Taylor Drake that John Harold Murphy

represented to be a letter from Chief Judge Baldwin. Threat, threat, threat is

the technique of John Harold Murphy, who, according to all recent reports,

is an alcoholic.

12.3 During the conference call on August 4, 2014, Chief Judge Baldwin

announced that he had a prejudged disposition that did not include the legal

standard of “in the best interest of the children.” Chief Judge Baldwin’s

prejudgment, without basing his judgment on legally obtained evidence, is


disqualifying conduct as it is a continuum of the biased conduct of Chief

Judge Baldwin that is included in the previous motions to disqualify Chief

Judge Baldwin.

12.4 Chief Judge Baldwin, in this case, either violates his oath of office,

or “the best of [his] ability and understanding,” and consistent with the laws

and Constitution of this State and the United States, is below the level of

him having the discretionary authority that the law provides him in this

case, and upon that ground should be disqualified.

12.5 Chief Judge Baldwin is charged with adhering to the following

aspects of the law that are highly relevant to his misconduct in this

litigation.

12.5.1 Chief Judge Baldwin violates The Georgia Code of Judicial

Conduct 12.6 Chief Judge Baldwin violates the Uniform Superior Court Rules 12.6.1 The bias of Chief Judge Baldwin has reached the point that he no

longer even makes the pretense of being fair. It is actually dangerous for

counsel for Michelle Murphy to appear before Chief Judge Baldwin with

him getting “mad” and engaging in untoward, irrational, retaliatory conduct

to counsel for attempting to exercise the statutory and constitutional rights

of Michelle Murphy and her counsel, Millard Farmer and her former counsel

Larry King.

12.6.2 Chief Judge Baldwin has ceased being a judicial officer who

provides either Michelle Murphy or her counsel, Millard Farmer, and

former counsel, Larry King, their statutory and constitutional protections,

as Chief Judge Baldwin has succumbed to acting only as a defiant violator

of the law.


12.7 This motion to disqualify Chief Judge Baldwin is required to protect,

as much as possible, Michelle Murphy, Jack Murphy, age 15, and Thomas

Murphy, age 13, their counsel, Millard Farmer, and former counsel, Larry

King, from the further consequences of the collectively motivated, illegal

conduct of Chief Judge Baldwin and the Taylor Drake/Glover & Davis

lawyers.

12.8 This motion to Disqualify Chief Judge Baldwin is timely filed

within five (5) statutory days of receiving the advisory opinion of Chief

Judge Baldwin on Friday, September 5, 2014.

13. Plea to Personal Jurisdiction of the Court, 13.1 Without submitting to the personal jurisdiction of the Court presided

over by Chief Judge A. Quillian Baldwin, Jr. and the authority of Elizabeth

“Lisa” F. Harwell, as the guardian ad litem, Michelle Murphy, her counsel,

Millard Farmer, and former counsel, Larry King, without waiving any of

their rights challenging the disqualification of Chief Judge Baldwin and

Elizabeth “Lisa” F. Harwell as the guardian ad litem, the personal

jurisdiction of the Court, or rights accorded by a supersedeas, while

expressly reserving all such rights, files this request on behalf of Michelle

Murphy, her counsel, Millard Farmer, and former counsel, Larry King.

13.2. Chief Judge Baldwin was selected by Taylor Drake in a Chief

Judge-shopping scheme that occurred when the Superior Court of Coweta

County did not have a Uniform Superior Court Rule 3.1 case management

plan.

13.2.1 After being attacked for violating the USCR 3.1 mandated case

management plan, the Coweta Judicial Circuit enacted a USCR 3.1 case

management plan.


13.2.2 The Clerk of the Superior Court of Coweta, as mandated by the

newly enacted USCR 3.1 plan, assigned this case to Chief Judge Dennis H.

Blackmon.

13.2.3 The Clerk of the Superior Court of Coweta County, after

confirming to the Court of Appeals that the Superior Court of Coweta

County did not have a USCR 3.1 plan, confirmed to the Court of Appeals

that Coweta Judicial Circuit Chief Judge Dennis Blackmon was appointed

under the newly enacted USCR 3.1 plan. (V7, p.1435)

13.2.4 The letter from the Clerk of Superior Court of Coweta confirming

to the Court of Appeals that this case was assigned to Coweta Judicial

Circuit Judge Dennis Blackmon follows.


13.2.5 As the result of the assignment of this case to Judge Dennis H.

Blackmon by the Clerk of Court of the Superior Court of Coweta County,

this Court, as presided over by Chief Judge Baldwin, does not have personal

jurisdiction of Nancy Michelle Murphy.


13.2.6 There was the absence of personal jurisdiction of the parties by

Chief Judge A. Quillian Baldwin, Jr. after the adoption by the Circuit Judges

of a USCR 3.1 plan and the assignment of the case to Judge Dennis

Blackmon.

13.2.7 Nancy Michelle Murphy again pleas to the personal jurisdiction

of this Court presided over by Chief Judge Baldwin and her subjection to

his appointee, Elizabeth “Lisa” F. Harwell, as guardian ad litem.

13.2.8 The Clerk of the Superior Court of Coweta County, after

confirming to the Court of Appeals that the Superior Court of Coweta

County did not have a USCR 3.1 plan, confirmed to the Court of Appeals

that Judge Blackmon was appointed under the newly enacted USCR 3.1

plan. (V7, p.1435)

13.2.9 Judge Blackmon rejected the appointment by the Clerk of Court

of the Superior Court (V8, p.1670) under the Circuit’s newly enacted

USCR 3.1 plan and, unbelievably, illegally, with no force and effect

illegally attempted to, “transfer” the case back to Chief Judge Baldwin (V7,

p.1503) without complying with USCR 3.1, that requires the Clerk of Court

to make the case assignments according to USCR 3.1.

13.2.10 Horn v. Shepherd, 294 Ga. 468, 472-473 (2014) on a relevant

judicial qualification issue, states, “no judge was authorized to rule on the

GAL's pending contempt motion against Husband . . . .”.

13.2.11 The hearing that resulted in the August 23, 2013 Custody

Evaluator appointment Order, as did the October 3, 2013 hearing that

resulted in the contempt Orders, occurred while there were four pending

disqualification motions against Chief Judge Baldwin, upon which he had


failed to rule or refer to another judge. (V3, p.436; V10, p.1904; V11,

p.2195; V14, p.2890) (infra, p. 26)

14. Conclusion 14.1 The conduct of Chief Judge A. Quillian Baldwin is far worse than just

a breach of his oath of office; his violations of the Code of Judicial

Conduct, his violations of the Uniform Superior Court Rules and his

violations of the laws of Georgia involving conduct should remove him

from this case and subject him to action that will prevent his continuing

misconduct.

14.2 After blocking the evidence of Michelle Murphy in the Court, with

the assistance of Chief Judge Baldwin, Jr., the Taylor Drake/Glover &

Davis lawyers presently attempt to block public information and violate the

United States First Amendment Constitutional Protections of Michelle

Murphy and the children.

14.3 This timely filed motion seeks to rectify the misconduct of Chief

Judge Baldwin by having him disqualified. The disqualification should be

nunc pro tunc to the time of the first disqualification motion, as

supplemented, and that motion is incorporated here by reference and

thereby made a part of this motion.

14.3.1 Chief Judge Baldwin has a history of signing Orders prepared by the

Taylor Drake/Glover & Davis lawyers without providing Michelle Murphy

the right to present evidence or have her pleadings considered before Chief

Judge Baldwin signs the Orders. On other occasions, Chief Judge Baldwin

signed relevant Orders without reading the Orders before he signed the

Orders. Such conduct is a violation of the Georgia Code of Judicial Conduct,


the laws of Georgia, the Uniform Superior Court Rules and thereby Chief

Judge Baldwin’s oath of office.

14.3.2 The Georgia Code of Judicial Conduct, in part, provides as

follows.

x E. Disqualification.

o (1) Judges shall disqualify themselves in any proceeding in which their impartiality might reasonably be questioned, including but not limited to instances where:

COMMENTARY:

� (a) the judge has a personal bias or prejudice concerning a party or a party's lawyer, or personal knowledge of disputed evidentiary facts concerning the proceeding; * * *

� (viii) any factor relevant to the issue of campaign contributions or support that causes the judge's impartiality to be questioned.

Ga. Code of Judicial Conduct 3

* * *


14.3.1.1 Chief Judge Baldwin had never provided counsel for

Michelle Murphy information about the advice that he has received

applicable to this proceeding before the court. Upon information and

belief, Chief Judge Baldwin has consulted with an individual about

aspects of this proceeding. This and other reasons related to the defense

of Chief Judge Baldwin related to his disqualification are viable reasons

that counsel for Michelle Murphy is entitled to examine Chief Judge

Baldwin under oath relating to this disqualification motion.

14.3.1.2 Chief Judge Baldwin, on March 4, 2014, as perfected on

March 5, 2014, violated the Georgia Code of Judicial as a part of his

continuum of violating the Canons of that Code. On those dates, as he

did at the hearing that resulted in the August 23, 2013 Order, Chief

Judge Baldwin untimely executed the Order that was filed on

March 5, 2014, setting a hearing. That Order set a hearing pursuant to

a motion supplemented by a letter request of the Taylor Drake/Glover

& Davis lawyers without Chief Judge Baldwin permitting counsel for


Michelle Murphy the statutorily allowed opportunity to respond before

the expensive, defective motion was set for a hearing. The request in

the motion to set a hearing on the “Rule 35” motion failed to present

Chief Judge Baldwin the legal necessity for the hearing, as provided by

Uniform Superior Court Rule 6.1. The issues that the requested

“Rule35” motion addressed are an integral part of matters pending on

appeal.

14.3.1.3 Chief Judge Baldwin executed on March 4, 2014 and filed

on March 5, 2014, the Order without reading Michelle Murphy’s timely

filed Response and Objections to setting a hearing on the defective

discovery motion; Chief Judge Baldwin’s law clerk never read the

Response and Objections of Michelle Murphy; Julia Harris, the

assistant to Chief Judge Baldwin, never read the Response and

Objection of Michelle Murphy and no one even told Chief Judge

Baldwin the content of the Response and Objection of Michelle

Murphy before the Order setting the hearing to determine if Chief Judge

Baldwin should permit a “Rule 35” examination was filed.

If anyone swears differently, including Chief Judge Baldwin, they commit

perjury.

14.3.1.4 Counsel for Nancy Michelle Murphy learned of the Order

being executed on March 6, 2014.

14.4. Chief Judge Baldwin violates the Uniform Rules of the Superior

Court

USCR Rule 3.1 provides as follows.

USCR 3.1. Method of assignment (Case Management)


In multi-judge circuits, unless a majority of the judges in a circuit elect to adopt a different system, all actions, civil and criminal, shall be assigned by the clerk of each superior court according to a plan approved by such judges to the end that each judge is allocated an equal number of cases. The clerk shall have no power or discretion in determining the judge to whom any case is assigned; the clerk's duties are ministerial only in this respect and the clerk's responsibility is to carry out the method of assignment established by the judges. The assignment system is designed to prevent any persons choosing the judge to whom an action is to be assigned; all persons are directed to refrain from attempting to affect such assignment in any way. If the order or the timing of filing is a factor in determining case assignment, neither the clerk nor any member of the clerk's staff shall disclose to any person the judge to whom a case is or will be assigned until such time as the case is in fact filed and assigned.

Chief Judge Baldwin was initially selected as the judge in this case in

violation of USCR 3.1 (case management).

Uniform Superior Court Rule 25 provides the method to be used after a

disqualification motion of a judge is filed.

Chief Judge Baldwin totally violates the mandates of the Rule 25 and

fails even to bring his conduct of rendering Orders based only upon

unsworn and unauthenticated assertions provided by the Taylor Drake/

Glover & Davis lawyers.

15.1. Incorporation Provision 15.1.1 This Motion, supplements, without replacing, and incorporates all

previous documents, including supporting affidavits attached to previous

motions to disqualify Chief Judge A. Quillian Baldwin, Jr., including but not

limited to the May 16, 2014 Consolidation Motion, August 11, 2014,

August 19, 2013 Consolidated Motion, and the August 28, 2013 amendment

to the August 19, 2013 Consolidated Motion, the Friday, September 13, 2013


Addendum, the October 7, 2013 Second Addendum and the

November 26, 2013, May 16, 2014 Motion to Disqualify Chief Judge A.

Quillian Baldwin, Jr., June 26, 2014 Consolidated Motion for the

Disqualification of Judge A. Quillian Baldwin, Jr., and August 11, 2014

Motion for Disqualification of Judge A. Quillian Baldwin, Jr. the July 31, 2014

Emergency Motion, the Addendum and all amendments to the July 31, 2014

Emergency Motion, Plea to Personal Jurisdiction and Other Relief, September

11, 2014 Motion to Disqualify Chief Judge A. Quillian Baldwin, Jr. and Plea

to the Personal Jurisdiction, and other relief, together with all information

supplied in those disqualification and other motions together with all relief

sought in those disqualification and other motions.

15.2 The Affidavit of Millard Farmer is attached.

16 Request for Relief 16.1 Michelle Murphy and her counsel request that the Court issue an

immediate Order directing the Jack Murphy and Thomas Murphy be

returned immediately to the jurisdiction of the Superior Court of Coweta

County.

16.2 Michelle Murphy and her counsel request that the attached Rule Nisi

be executed by the Court in order that an independent and fair jurist be

assigned to hear this motion.

16.3 Michelle Murphy and her counsel request that the Court issue an

immediate Order changing temporary custody to the status that it was

before the May 27, 2014 Order of the Court transferring temporary custody

of Jack Murphy and Thomas Murphy.

16.4 Michelle Murphy and her counsel request that the Court issue an


immediate Order directing that John Harold immediately pay the child

support payments due for September and October of 2014.

16.5 Michelle Murphy and her counsel request that her as-applied and

her facial challenge to the constitutionality of Uniform Superior Court

Rule 25 be granted and that Michelle Murphy and her counsel be allowed

to present evidence in support of this as-applied constitutional attack. 16.6 Michelle Murphy and her counsel request that Chief Judge A.

Quillian Baldwin, Jr. be disqualified from serving as a judge in this case.

16.7 Michelle Murphy and her counsel request that Chief Judge A.

Quillian Baldwin, Jr. grant their plea to the personal jurisdiction of Judge

Baldwin serving in this case.


Quillian Baldwin, Jr. be required to submit to questions under oath relating

to appointments of guardians ad litem and custody evaluators in the Coweta

Judicial Circuit.


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.

16.10 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.

16.11 Michelle Murphy and her counsel request that all Orders entered

in this case before the filing of this motion be vacated.

16.12 Michelle Murphy and her counsel request that Michelle Murphy

Attachment 130, Page 1 of 11




























In the Superior Court of Coweta County State of Georgia

John Harold Murphy, Plaintiff

vs. Civil Action No. 12V-413 Nancy Michelle Murphy, Defendant

Request for Certificate of Immediate Review of Nancy Michelle Murphy

r

This is the third Request for a Certificate of Immediate Review submitted to

Judge A. Quillian Baldwin, Jr. This Request is for Nancy Michelle Murphy and

her children to have an opportunity to have an appellate review of the illegal

action of Judge Baldwin. To paraphrase Judge Baldwin, if he is correct about

the law and his treatment of Jack Murphy, age 15 and Thomas Murphy age, 13,

Judge Baldwin has nothing to worry about presenting this to an appellate court

for review. If Judge Baldwin is not correct, justice will be served for this family

and the people living in the Coweta Judicial Circuit who do not believe in the

judge shopping techniques of the Taylor Drake/Glover & Davis lawyers.

A review of the conduct of Judge Baldwin on the merits, or through

regulatory authorities, will ready this case for a resolution by a jurist who

provides both sides to the litigation an opportunity to present evidence and not

just the side whose lawyers have contributed to the election campaign of the

judge who did not even have opposition.

One issue that this certificate would allow to be reviewed is whether Judge

A. Quillian Baldwin, Jr., a trial judge, may dilute Michelle Murphy’s appellate

1


jurisdiction by denying Michelle Murphy’s access to the Court by violation of

the protections of 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); 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.

There is no reported case within counsel’s knowledge where a Court has

been permitted to modify custody as punishment to the custodial parent.

Especially is this illegal when the custodial parent had been denied the right to

present evidence on the two central issues about which the punishment was

administered to Michelle Murphy, Jack Murphy and Thomas Murphy.

The failure of the Court to render an order memorializing the reason and the

Court’s authority resulted in an illegal arrest of Jack Murphy, age 15 and

Thomas Murphy, age 13 and their removal 3,000 miles away to St Thomas.

Text Messages from Jack Murphy, age 15, to Michelle Murphy from his first Tennessee and now St. Thomas Confinement with John Harold Murphy and Renee L. Haugerud

2


3


4


The conduct that motivated Jack Murphy to write the sampling of text

messages above to his mother, Michelle Murphy, created the illegal

modification of custody by Judge Baldwin, without allowing Michelle Murphy

to present evidence and requires an immediate recision of the transfer of

custody of Jack Murphy and Thomas Murphy to John Harold Murphy.

Judge Baldwin, in his June 5, 2014 Order, attempts to restrict all conduct of

these children that she has raised since their birth. Judge Baldwin does this to

protect his image rather than to serve justice. This is a dastardly act by Judge

Baldwin.

On Tuesday, May 27, 2014, at a scheduled hearing in the Superior Court of

Coweta County that the Glover & Davis lawyers and Judge Baldwin instigated,

Jack Murphy, age 15 and Thomas Murphy, age 13, appeared in court to testify

and/or be interviewed privately by Judge Baldwin. These children wanted to

tell Judge Baldwin about false statements that their father had made against

their mother relating to them and about the reasons that they refused to get in

the chauffeured limo sent to take them away from their friends and home to

visit with John Harold Murphy and Renee L. Haugerud, who informed Thomas

Murphy, age 13 that she was “god” and in her “21st life of entitlement.” 5


Jack Murphy and Thomas Murphy, long before the scheduled hearing,

provided the Court detailed affidavits about which John Harold Murphy falsely

swore that Michelle Murphy “made” them sign. It was after the sworn

statement by John Harold Murphy, that both Jack Murphy, age 15, and Thomas

Murphy, age 13, asked to talk to Judge Baldwin, as they both feared that Judge

Baldwin would require them to spend more time with John Harold Murphy and

Renee L. Haugerud.

When informed of the children’s request, Judge Baldwin announced that he

did not wish to interview the children, as he had previously interviewed them.

Judge Baldwin asked that the children be removed from the courtroom and

placed in a witness room.

Three of the Glover & Davis lawyers and at least two or more other persons

from Kilpatrick Townsend & Stockton LLP appeared at the hearing, as

courtroom gawkers, or as legal advisors for the Glover & Davis lawyers. There

were an unusual number of Deputy Sheriffs also in attendance. There was the

appearance of a nonjudicial atmosphere about the private courtroom where the

hearing was set; it appeared, as if someone had forecasted the events that were

about to unfold. As gawkers, or legal advisors awaiting the arrest of Jack

Murphy, age 15 and Thomas Murphy age 14, these persons exhibited an event

that should never observed in a democratic society. They each exited the

courtroom and went into view of the witness room, where Jack Murphy, age 15

and Thomas Murphy age, 13 were suffering in the arms of Michelle Murphy

before they were pulled away, as the Deputy Sheriff had threatened to take

Thomas Murphy to Juvenile Court if Thomas Murphy did not let go of his

mother.

6


After making one of their usual false and misleading statements about John

Harold Murphy paying for the custody evaluation, (the transcript is not yet

available; Michelle Murphy’s potential obligation for payment of costs of the

custody evaluation is contained in April 1, 2014 Order, V19, p. 4104), the

Glover & Davis lawyer, Taylor Drake, called Michelle Murphy as his first

witness. Taylor Drake began the cross-examination of Michelle Murphy.

Taylor Drake attempted to ask questions designed to prevent Michelle Murphy

from explaining the reason that she could not fulfill the Order of the Court to

become obligated to financial, time consuming and other requirements of

H. Elizabeth King, the Custody Evaluator, as identified in the contract of

H. Elizabeth King, the Custody Evaluator who required Michelle Murphy to

appear at her Cliff Valley Road office in Atlanta for hours, over a period of

days, as indicated in the record at V20, pp. 4442-4449.

Instead, Michelle Murphy had offered H. Elizabeth King, the custody

evaluator appointed by Elizabeth “Lisa” F. Harwell, an invitation that was

refused, for H. Elizabeth King to come into Michelle Murphy’s home in

Newnan and to interview her and the children, as she and any associate wished.

The Custody Evaluator acknowledged as follows in her papers to Michelle

Murphy:

7


Additionally, Michelle Murphy was warned of the time consuming,

emotional and financial drain which the evaluation would wreak on her and her

children.

V21, p. 4513.

For some non-judicial reason, during the testimony of Michelle

Murphy, Judge Baldwin went verbally, physically and emotionally

ballistic. He yelled, he shook his finger on a fully extended arm,

individually at Michelle Murphy and her counsel in a manner never

witnessed by counsel for Michelle Murphy during many years of practicing law

before many different judges. Maybe Judge Baldwin was uncontrollably mad

over the May 16, 2014 motion to disqualify him (V20, p.4181) and/or the

Response to the May 1, 2014 Glover & Davis motion for Contempt that also

included a plea to the personal jurisdiction of Judge Baldwin (V21, p. 4493)

These two documents in the supporting record for this motion explain this

entire litigation.

This May 27, 2014 emotional explosion by Judge Baldwin was not the only

time that Judge Baldwin hollered at Michelle Murphy and her counsel. This

occasion was many times worse than when Judge Baldwin hollered that he

8


would put counsel in jail for requesting that the court reporter take down the

calendar call that could support a violation of USCR 3.1 case management plan.

That episode occurred during a bench conference before a full courtroom (Tr.

Aug. 6, 2013 hearing; V10, p. 1929, V12, p. 2327, V21, pp. 4726-4728).

This May 27, 2014 pointing and hollering time was far worse than when

Judge Baldwin, at an August 13, 2013 hearing, threatened Michelle Murphy

with jail if she did not physically force Jack and Thomas, who were then almost

fifteen and almost thirteen years old, to visit with their father, which entailed

physically forcing them into the chauffeured limousines ordered by John

Harold Murphy to pick up the children and bring them to him or to an airport

to be flown to him in a private jet. (Tr. Aug. 13, 2013 hearing; V21, p. 4728).

John Harold Murphy was never ordered to appear in person to pick up his

children for visitation and counsel for Michelle Murphy was prevented by

Judge Baldwin from obtaining the testimony under oath of Renee L. Haugerud,

who finances John Harold Murphy.

The obviously uncontrolled conduct of Judge Baldwin was many, many

times worse than when he ordered Larry King arrested at a hearing on October

3, 2013, for attempting to explain documents that he was filing which detailed

a personal plea to the jurisdiction of Judge Baldwin; it was far worse than Judge

Baldwin’s other yelling and shaking finger episodes that began shortly after the

first motion to disqualify him was followed by additional disqualification

motions, identifying additional unethical and illegal conduct by Judge Baldwin.

As judicially inappropriate as was the yelling and gesticulating by Judge

Baldwin when he terminated the cross-examination of Michelle Murphy,

nothing was as unethically evil as what followed, as Jack Murphy, age 15

9


and Thomas Murphy, age 13, became victims of the punishment meted out

by Judge Baldwin during his apparently uncontrollable episode that was

focused upon Michelle Murphy and her counsel.

During his outrage of yelling and intimidating body movements, Judge

Baldwin orally ordered the Deputy Sheriffs to assist John Harold Murphy in

loading the children of Michelle Murphy into the limo of John Harold Murphy.

This illegal arrest of the children and accompanying conduct was an ad hoc

modification of custody of the children of Michelle Murphy without allowing

Michelle Murphy the right to present evidence of her good faith effort to

comply with the ex parte obtained August 23, 2013 Order (V11, p. 2187) that

resulted in the April 1, 2014 enforcement aspect of that August 23, 2013 Order

that was administered by the Deputy Sheriff of Coweta County before Michelle

Murphy even learned of the Order altering the visitation mandated by the

Divorce Decree.

Much as a boxer after an extremely physical ordeal, Judge Baldwin, after his

meltdown, quickly moved from the courtroom, as counsel attempted to make

an objection on the record. Judge Baldwin, after exiting through the door to his

chambers, turned around and shouted to counsel that the hearing was over and

instructed the court reporter to quit taking down the proceedings, failing to

allow counsel for Michelle Murphy to make a record of Judge Baldwin’s

conduct and present evidence. This abrupt termination was the second abrupt

termination of a hearing before counsel for Michelle Murphy was allowed to

present evidence, as reflected by the transcript of the August 13, 2013 hearing

at p. 276.

10


Counsel for Michelle Murphy attempted to contact Judge Baldwin in the

courthouse to obtain an Order; counsel was informed that Judge Baldwin was

no longer in the courthouse.

Nan Freeman refuses to sell counsel for Michelle Murphy the audio of the

episodes and will only say that the transcript will not be available for a couple

of weeks.

Michelle Murphy provided her affidavit to Judge Baldwin that is recorded in

the Superior Court of Coweta County.

Communications initiated by Glover & Davis counsel for John Harold

Murphy that were served upon all counsel and later followed by

communication between counsel for Michelle Murphy and Judge Baldwin, also

served upon all counsel, are recorded in the Superior Court of Coweta County.

John Harold Murphy, in a text book Church of Scientology fashion, whisked

the children away that morning from the courthouse in a large black SUV type

limousine, to the first of three of their five homes to which they were shuttled

in less than a week, one in Atlanta, one in Chattanooga, and then to St. Thomas.

The Glover & Davis lawyer brought this action against Michelle Murphy

because she would not move to Chattanooga to live near John Harold Murphy

and Renee L. Haugerud. The purported cause for the modification used with an

emergency motion by the Glover & Davis lawyer to judge shop for Judge

Baldwin was that Michelle Murphy was threatening to move to South Carolina

with the children.

The “parenting plan” of the Glover & Davis lawyer to store the children in a

private boarding school in Chattanooga, and the conduct of Judge Baldwin

identifies the reasons that these children knew well the dangers of visiting with

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John Harold Murphy and Renee L. Haugerud. These children, at their young

age, have moral values that John Harold Murphy and Renee L. Haugerud, who

tells the children that she is “god” and in her twenty-first year of entitlement,

lost many years ago.

The over four thousand pages of pleadings that were brought in search of

justice for Michelle Murphy, Jack Murphy, age 15 and Thomas Murphy

age, 13, tell a sad story of the judicial judge selection and shopping corruption

that could and did flourish due to the absence of a Uniform Superior Court Rule

3.1 case management plan. Judge Louis Jack Kirby instructed John Harold

Murphy about how to utilize this corruption door by selecting one of the

favored lawyers who knew the corruption door.

Judge Baldwin’s ordered jailing of Michelle Murphy prior to the

May 27, 2014 event did not break her fight for her children. This may have

enhanced the punishment by Judge Baldwin in modifying the custody of the

children without allowing evidence that could have reversed the modification

of custody on May 27, 2014.

Judge Baldwin frequently informed Michelle Murphy that her lawyers, Larry

King and Millard Farmer, were not acting in her interest, and that she should

forego her constitutional and statutorily protected protections by surrendering

to the will of Judge Baldwin, who has never provided this hair stylist any

litigation cost to fend off the attacks by these hedge fund operators.

Judge Baldwin ordered the modification of custody that allowed John Harold

Murphy to take the children out of the country; this did not break her fight.

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Judge Baldwin’s unethical conduct is contagious.

Nan Freeman, the court reporter, will not, upon payment to her, provide the

audio copies of the yelling events of Judge Baldwin, as she maintains that they

are her work product. Nan Freeman informs counsel that it will be a couple of

weeks before a transcript of the May 27, 2014 hearing will be available. (V22,

p. 4791)

Nan Freeman cannot disconnect from the unethically contagious conduct of

Judge Baldwin.

These children deserve better than the guardian ad litem who converted to

her personal use funds provided to the guardian ad litem in trust that were

restricted for use by Elizabeth “Lisa” F. Harwell only as provided by Uniform

Superior Court Rule 24.9 (8) (g) that requires an application to the Court with

prior notice to Michelle Murphy. Elizabeth “Lisa” F. Harwell. Judge Baldwin

without review of the supporting documents with prior notice to Michelle

Murphy approved of this illegal conduct that violated the law and the Georgia

Rules of Professional Conduct.

Jack Murphy, age 15 and Thomas Murphy, age 13, Deserved and Had

the right to talk to Judge Baldwin at the May 27, 2014 hearing before

Judge Baldwin had them taken in custody by the Deputy Sheriffs without

a written or filed order.

The June 5 Order relied upon an ex parte obtained August 23, 2013 Order

that was obtained while a motion to disqualify Judge Baldwin was pending.

This August 23, 2023 Order is also presently pending on appeal.

Judge Baldwin had the children arrested by the Coweta County Deputies as

if they were convicted criminals.

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Without submitting to the personal jurisdiction of the Court presided over by

Judge A. Quillian Baldwin, Jr. and the authority of Elizabeth “Lisa” F. Harwell,

as the guardian ad litem, Nancy Michelle Murphy, without waiving any of her

rights challenging the disqualification of Judge Baldwin and Elizabeth

“Lisa” F. Harwell as the guardian ad litem, the personal jurisdiction of the

Court, or rights accorded by a supersedeas, while expressly reserving all such

rights, files this request on behalf of Nancy Michelle Murphy in order to obtain

a Certificate of Immediate Review relating to the personal jurisdiction of the

Court presided over by Judge Baldwin in this case.

Time Sensitive Request of Certificate for Immediate Review As authorized by OCGA § 5-6-34(b), Nancy Michelle Murphy files this

Request for Certificate of Immediate Review of Judge A. Quillian Baldwin,

Jr.’s June 5, 2014 “Order.”

This 6th day of June, 2014.

Respectfully submitted,

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

Larry King Georgia Bar No. 419725 P. O. Box 1648 Jonesboro, GA 30237 (770) 471-3835 [email protected]

Counsel for Nancy Michelle Murphy

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Certificate of Service

I certify that I have today served a copy of the foregoing Request for

Certificate of Immediate Review, by electronic delivery as follows: Taylor B. Drake Glover & Davis, P.A. P. O. Drawer 1038 10 Brown Street Newnan, GA 30265 [email protected]

Michael W. Warner Glover & Davis, P.A. P.O. Drawer 1038 Newnan, GA 30265 [email protected]

Peter A. Durham Glover & Davis, P.A. P. O. Drawer 1038 Newnan, GA 30265 [email protected]

Stephen E. Hudson Ga. Bar No. 374692 Kilpatrick Townsend & Stockton LLP 1100 Peachtree Street, Suite 2800 Atlanta, Georgia 30309-4528 [email protected]

William R. Poplin, Jr. Ga. Bar No. 584535 Kilpatrick Townsend & Stockton LLP 1100 Peachtree Street, Suite 2800 Atlanta, Georgia 30309-4528 [email protected]

Teresa E. Lazzaroni [email protected] trial court counsel for Elizabeth F. Harwell Judge A. Quillian Baldwin, Jr. is served electronically at [email protected] and [email protected]

Elizabeth F. Harwell Harwell, Brown & Harwell, PC Newnan, GA [email protected]

This 6th day of June, 2014.

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

Larry King Georgia Bar No. 419725 P. O. Box 1648 Jonesboro, GA 30237 (770) 471-3835 Fax (770) 471-8200 [email protected]

Counsel for Nancy Michelle Murphy

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Emergency_Motion_for_Hearing_Murphy_CowetaCounty_Newnan_GA_Oct6_2014

Documents

free jack

jack age

friend of jack

prologue jack

photo of thomas

living conditions of

alcoholic beverages

emergency hearing motion