Murphy_Freeman_Court Reporting Fraud_First Amended Complaint w Atts

IN THE SUPERIOR COURT OF TROUP COUNTY STATE OF GEORGIA

Nancy Michelle Murphy, Plaintiff, vs. Civil Action No. 15-CV0109 Nan Freeman and Freeman Reporting, Inc., Defendants [Only two Defendants remaining after Fulton Superior Court transfer]

Demand for a Jury Trial by twelve persons.

First Amended Complaint

Nancy Michelle Murphy (or, “Michelle Murphy,”) after transfer of this case to

the Superior Court of Troup County, here amends her original Superior Court

of Fulton County filed action against Nan Freeman and Freeman Reporting,

Inc. (or, collectively, “Nan Freeman,” “Nan” or “Nanny”).

There are issues embedded within each of the causes of action that affects the

damages that should be awarded against Nan Freeman. The embedded issues in

each cause of action are (1) the proportion of the tortious conduct by Nan Freeman

that can be attributed to her violation of the LAW* by intentionally participating

in the illegal conduct of Judge Baldwin in order to deprive Michelle Murphy and

her children of their protections under the LAW* by Nan Freeman’s reckless and

wanton disregard of consequences that evinced an intention to inflict injury upon

Michelle Murphy --- (2) the proportion of Nan Freeman’s tortious conduct that

is attributed to her intent to obtain illegal financial and employment benefits for Michelle Murphy v. Nan Freeman Amended Complaint Page 1 of 55

herself --- (3) the proportion of Nan Freeman’s tortious wrongdoing that is

attributed to her fraud and negligent misrepresentation. --- (4) the damages caused

to Michelle Murphy as the result of Nan Freeman’s illegal and unethical conduct

that included Nan Freeman’s participation in attempting to secret and otherwise

participate in the illegal conduct and other violations of the Code of Judicial

Conduct by Judge A. Quillian Baldwin, Jr.

Michelle Murphy seeks damages, including punitive damages and other relief

for Nan Freeman’s fraud, negligent misrepresentation, breach of contract,

conversion. unjust enrichment, negligence and inequitable conduct, including

intentional tortious conduct and for false, illegal certification of an official

transcript of a court proceeding by using authority bestowed upon Nan Freeman

by the State of Georgia and, Judges in the Coweta Judicial Circuit.

1. Introduction --- Summary of Illegal and Tortious, including the intentional tortious conduct and other actionable Conduct by Nan Freeman that has damaged Michelle Murphy.

1.1 Nan Freeman was designated by Chief Judge A. Quillian Baldwin, Jr. as his

officially qualified State of Georgia Court Reporter in the Coweta Judicial Circuit

under authority provided to Judge Baldwin by OCGA §15-14-1 to both appoint

and vacate the appointment of an official court reporter, a position that Nan

Freeman held. The laws of Georgia, as the result of bestowing the authority of an

official court reporter upon Nan Freeman, restricted her conduct and regulated the

compensation that she could legally receive from individuals and government

entities.

1.1.1 Nan Freeman has engaged in two primary broad categories of illegal

and tortious conduct affecting and damaging Nancy Michelle Murphy (or,

“Michelle Murphy”) Michelle Murphy v. Nan Freeman Amended Complaint Page 2 of 55

1.1.2 The illegal and tortious conduct of Nan Freeman that necessitates the

causes of action brought in this case against Nan Freeman and Freeman

Reporting, Inc., her solely owned corporate entity, (or, “Nan Freeman”

collectively or separately) are summarily identified in this Amended

Complaint.

1.2 Each of the primary categories of illegal and tortious conduct by Nan

Freeman justify the relief sought in this Amended Complaint, including punitive

damages.

1.1.2 The conduct of Nan Freeman that primarily only affected Michelle

Murphy and her two children, J.M., age 16 and T. M., age 14, is one of the large

categories of the illegal and tortious, including intentional tortious conduct by

Nan Freeman that justified the relief sought.

1.2.2 The other primary category of illegal and tortious conduct by Nan

Freeman while substantially affecting Michelle Murphy and her two children,

J.M. and T. M., also sustainably affected, and remains to potentially affect all

persons in the State of Georgia and particularly persons in the Coweta Judicial

Circuit and State of Georgia who rely upon its court system and equitable

enforcement of the laws of Georgia. Nan Freeman has engaged in theft by

taking from Michelle Murphy and people in the Coweta Judicial Circuit and

State of Georgia.

1.3 This case against Nan Freeman is a civil action brought by an individual

litigant who was damaged by this official court reporter, Nan Freeman, whose

conduct should have been in part prevented by the Board of Court Reporting of

the Judicial Council of Georgia (or, “Board of Court Reporting”) and the Judicial

Qualifications Commission State of Georgia. (“JQC”). Both Nan Freeman and

Michelle Murphy v. Nan Freeman Amended Complaint Page 3 of 55

Judge A. Quillian Baldwin, Jr. apparently were able to exert and obtain political

influence to evade effective regulatory action to timely correct the illegal conduct

of Nan Freeman and Judge Baldwin that require Michelle Murphy to bring this

action to recover her damages.

1.3.1 These are two regulatory agencies, the Board of Court Reporting and

the JQC that should have brought the conduct of Nan Freeman and

Chief Judge A. Quillian Baldwin within the bounds of the LAW* long before

the necessity of this case against Nan Freeman by Michelle Murphy.

1.3.2 If Chief Judge A. Quillian Baldwin, Jr. had not been engaged in

conduct in violation of the Code of Judicial Conduct and the LAW* there

would have been no necessity for Nan Freeman to have failed to provide

sections of the record in the transcripts, for counsel of Michelle Murphy. It also

would not have been necessary for counsel for Michelle Murphy to have

requested that the calendar call be recorded and to have been refused

permission for Michelle Murphy to purchase copies of Nan Freeman’s audio

recordings of Judge Baldwin’s loud, provocative screaming that followed

Judge Baldwin being caught engaging in violations of protections provided to

litigants by the Code of Judicial Conduct, the Code the Uniform Superior Court

Rules, the Constitutional provisions of the United States and State of Georgia

equivalent, First Amendment, Equal Protection, Due Process

protections, statutes, decisional law, Georgia Code of Professional Conduct,

the Court Reporter Code of Professional Ethics (or, collectively, or separately,

“LAW*”.)


1.4 It was the effort of Nan Freeman and Judge Baldwin to defend their legally

indefensible, illegal and unethical conduct that necessitated this case against Nan

Freeman.

1.4.1 The Board of Court Reporting has two full time, State of Georgia paid

employees who should be accessible to persons having questions about the

regulations governing the propriety of the conduct of official court reporters,

as is Nan Freeman. There can be no check and balances of the authority

provided to these state actor official court reporters without access to Board of

Court Reporting employees excepting through written questions to a political

buffer.

1.4.1.1 These State of Georgia employees for the Board of Court

Reporting should not be shielded from providing information to persons

seeking information about official court reporters who are charging fees

regulated by the Board of Court Reporting.

1.4.1.2 There is something going wrong involving official court reporters

in Georgia, such as Nan Freeman, who is participating and being unjustly

enriched by engaging in criminal conduct in illegally charging for her work

product and failing to accurately record court proceedings.

1.4.1.3 Persons affected by the inability of the Board of Court Reporting

in the State of Georgia to regulate official court reporters without litigation

are entitled to investigate the need for changes at the Board of Court

Reporting. This need for the Board of Court Reporting to take action is being

shielded.

1.4.1.4 These Board of Court Reporting employees, for political reasons,

in violation of the LAW* are shielded by Cynthia Hinrichs Clanton, General


Counsel of the Administrative Office of the Courts (AOC) and as staff of the

Judicial Council of Georgia.

1.4.1.5 These Board of Court Reporting employees should freely and

openly discuss regulations relating to violations by official court reporters

without Cynthia Hinrichs Clanton requiring that she screen the written

subject content of the inquiry sought to be made of the State of Georgia

employee of the Board of Court Reporting.

1.4.1.5.1 Cynthia Hinrichs Clanton, in matters involving the Coweta

Judicial Circuit, required that each question to the Board of Court

Reporting’s employees be presented to her in writing before obtaining

responses at a later time from the employees.

1.4.1.5.2 Cynthia Clanton will not allow the employees to discuss

matters by telephone. or in person. This conduct by Cynthia Clanton

creates suspicion that the employees have information that should not be

disclosed to the public, or that the employees are just political appointees

who cannot fulfill their job requirements and their ineptness is being

concealed.

1.4.1.5.3 Nan Freeman testified at her deposition that she could never

get anyone at the Board of Court Reporting to talk with her on the

telephone. The accuracy of her testimony could be relevant to the amount

of punitive and other damages sought from her.

1.4.1.6 The shielding conduct of Cynthia Hinrichs Clanton is not isolated

to the conduct of Nan Freeman. In another case involving the illegal

collection of funds by a Judge who was ultimately disciplined and removed

as a judge, and a Clerk of Court. In that case, Cynthia Clanton refused to


allow discussion with employees of the State of Georgia about false

information provided to the public relating to the reimbursement of illegally

collected funds from the public.

1.4.1.6. The conduct of Cynthia Hinrichs Clanton could be interpreted as

conduct engaged in by Cynthia Clanton in furtherance of an elective position

that she seeks with other entities. (See, Cynthia Clanton’s “Candidate’s

Campaign Message,” State Bar of Georgia website,

http://www.gabar.org/newsandpublications/election/Clanton.cfm )

1.4.1.7 This type of shielding conduct relating to Nan Freeman by Cynthia

Hinrichs Clanton deterred earlier and more complete detailed disclosure of

Nan Freeman’s illegal conduct, that, in part, is interference by the Board of

Court Reporting in addressing unethical and illegal official court reporter

conduct, which is allowing government entities and litigants, as Michelle

Murphy to become victims of breach of contract, fraud, negligent

misrepresentation, and of the unjust enrichment of Nan Freeman through

secreting of her obligations to the public.

1.4.1.8 The conduct of the Board of Court Reporting that allowed Nan

Freeman to assist Judge Baldwin in violating the protections due Michelle

Murphy with violations of the LAW*, in particular, was the by-product of

the Coweta Judicial Circuit not having the Uniform Superior Court Rule 3.1

mandated case management plan that should have been corrected when first

noticed to the courts.

1.5 The Compensation that Nan Freeman is allowed to receive while serving as

an Official Court Reporter is designated by the Board of Court Reporting.


1.5.1 The certificate that Nan Freeman affixes to the transcripts requires that

in all further proceedings, the courts must assume the transcript to be true,

complete and correct.

1.5.2 Litigants are required by the law of Georgia to pay Nan Freeman to

obtain her transcripts of court proceedings. Litigants have no choice as to the

official court reporter who litigants must employ.

1.5.3 The requirement of the certificate that Nan Freeman must attach to her

official transcripts is very easy to understand and would be very easy for the

Board to randomly audit, instead of employing persons who fail in their

regulatory obligations to the extent that the courts of the State of Georgia have

been infected with illegal conduct by court reporters such as Nan Freeman.

1.5.4 OCGA § 5-14-5 requires the following of Nan Freeman that the Board

of Court Reporting, the District Attorney of Coweta County and Judge Baldwin

failed to require of Nan Freeman before she was unjustly enriched for work that

did not comply with the laws of Georgia that affects the lives of numerous

people.

OCGA § 15-14-5. Duty to transcribe; certificate. It shall be the duty of each court reporter to transcribe the evidence and other proceedings of which he has taken notes as provided by law whenever requested so to do by counsel for any party to such case and upon being paid the legal fees for such transcripts. The reporter, upon delivering the transcript to such counsel, shall affix thereto a certificate signed by him reciting that the transcript is true, complete, and correct. Subject only to the right of the trial judge to change or require the correction of the transcript, the transcript so certified shall be presumed to be true, complete, and correct.


1.5.5 Nan Freeman, as a part and parcel of her habitual violation of the laws

of Georgia, did not provide Michelle Murphy’s transcripts with an

OCGA § 5-14-5 required certificate containing the certification that the

transcript is “true, complete and correct. . ” as required by OCGA § 5-14-5. -

-- The transcript provided and paid for by Michelle Murphy was not true or

complete or correct. Nan Freeman has never provided to Michelle

Murphy, or other litigants, the required certificate that is an indication of

the pattern of her illegal conduct. 1.5.6 Michelle Murphy and her counsel

have been held in contempt of court based upon the transcripts of Nan Freeman.

1.5.7 The contempts rendered by Judge A. Quillian Baldwin, Jr. have been

financially detrimental and created great emotional stress to Michelle Murphy.

1.5.8 Judge Baldwin has rendered Orders detrimental to Michelle Murphy and

her two children based upon the illegal transcripts of Nan Freeman.

1.5.8.1 Nan Freeman failed to provide the initial part of the court

proceedings on May 27, 2014, when Judge Baldwin committed to J. M. and

T. M., whose current and future wellbeing were at stake at that hearing, that

he would allow them to testify.

1.5.8.2 Instead of obtaining evidence as required by LAW*, Judge

Baldwin, after the May 27, 2014 hearing, was willing only to receive

information from Elizabeth “Lisa” F. Harwell, the so designated guardian ad

litem, who is an individual who engaged in violations of the laws of Georgia

and was attempting to justify the illegal conduct of Judge Baldwin.

1.5.8.3 Judge Baldwin after committing to counsel for Michelle Murphy that

there would be a hearing to determine the well documented abuse of the

children by John Harold Murphy that was acquiesced in and allowed by


Renee L. Haugerud making alcoholic drinks and tobacco products available

to the children.

1.5.8.3.1 Nan Freeman’s May 27, 2014 transcript does not reflect the

names or identifies of the people who had evidence and were waiting to

testify about the basis for the decision that Judge Baldwin was to make.

1.5.8.3.2 There is no question but that the illegally prepared transcript of

Nan Freeman conceals the illegal and Code of Judicial Conduct violations

by Judge Baldwin, with omissions from the transcript prepared and

illegally certified by Nan Freeman. The conduct of Nan Freeman

interferes with the protected liberty interest of Michelle Murphy and her

children that Judge Baldwin has breached, together with his other

violations of protections due Michelle Murphy by the LAW*.

1.5.8.3 The children being allowed to testify was critical for the hearing

to comply with the LAW*, as either the custody evaluator, Nancy McGarrah,

made a false statement, or John Harold Murphy had made a false statement

to Nancy McGarrah attesting to an accusation that he told Nancy McGarrah

that one of the children told him that one of the children had been fondled

by Michelle Murphy.

1.5.8.3.1 The substance of the false accusation as evidence was critical.

1.5.3.3.2 The commitment of Judge Baldwin at the beginning of the May

27, 2014 hearing to allow the children to testify, which Nan Freeman

failed to transcribe, was critical.

1.5.8.3.3 The fondling never occurred and was never alleged by the

children, as now acknowledged by John Harold Murphy. This fondling

accusation was a litigation tactic of the Kilpatrick Townsend & Stockton


LLP lawyer, William R. Poplin, Jr., and the Glover & Davis lawyer,

Taylor Drake.

1.5.8.3.4 John Harold Murphy knew the statement regarding fondling

made by Nancy McGarrah was untrue when he heard the statement of

Nancy McGarrah as she was testifying.

1.5.8.3.5 Even with John Harold Murphy knowing the fondling statement

was untrue, his Kilpatrick Townsend & Stockton LLP lawyer, William R.

Poplin, Jr. continued to use the false statement in pleadings to the Court

of Appeals of Georgia in violation of the LAW*.

1.5.8.3.6 The absolutely untrue fondling accusation was used to the

Court of Appeals by William R. Poplin, Jr. as a justification for the illegal

conduct and violations of the LAW* by Judge Baldwin in not allowing

counsel for Michelle Murphy to present evidence.

1.5.8.3.7 Nan Freeman has never transcribed the broken commitment of

Judge Baldwin on May 26, 2014 to these children, Michelle Murphy and

to counsel. This omitted conduct by Judge Baldwin was just one instance

of Judge Baldwin’s broken commitments to Michelle Murphy and her

counsel that he would allow evidence at a later time. In making these, “I-

will-allow-your-evidence-later” commitments, Judge Baldwin never

allows the evidence in the most critical matters. On May 27, 2014, Nan

Freeman negligently or intentionally did not preserve the statement by

Judge Baldwin that became just one in a series of the broken commitments

by Judge Baldwin.

1.5.3.3.7 That information was both a commitment by Judge Baldwin to

allow the children to testify at the May 27, 2015 proceeding, and an Order


from Judge Baldwin to remove the children from the courtroom and to

place them in a witness room.

1.5.3.3.8 Nan Freeman deprived Michelle Murphy of a transcript of the

critical, broken commitment and Order that should have been available to

Michelle Murphy to present to the JQC and to the appellate courts, along

with Judge Baldwin’s failure to allow Michelle Murphy to present any

evidence, as he went into his monstrous temper tantrum that included four

transcript pages that Nan Freeman also failed to produce until after she

filed her defective certificate and subsequently received a Freedom of

Information Act Request to obtain an audio recording of the May 27, 2014

proceedings.

1.5.3.3.9 The omitted pages, now supported by the audio recording of the

Code of Judicial Conduct violations by Judge Baldwin, that subsequently

were provided in an “Addendum” transcript follows.

Transcript of Proceedings before

the Honorable A. Quillian Baldwin, Jr., Judge, at the Coweta County Courthouse

Newnan, Georgia on the day 27th of May, 2014

ADDENDUM [REPORTER’S NOTE: This addendum is being filed because this final objection, made after the judge’s ruling, although taken down at the time, was inadvertently omitted from the main transcript.]

MR. DRAKE: Thank you. MR. FARMER: Your Honor, may we have an


immediate review for -- THE COURT: No. MR, KING: May we go on the record, Your

Honor, and state that you have not allowed Ms. Murphy to present a defense to this contempt, that you have, as a sanction, transferred custody. In no case in the State of Georgia has a sanction ever transferred custody of the children.

MS. MURPHY: (Unintelligible.) MR. KING: And we want to put that on the

record as an objection to the conduct of the Court and the ruling of the Court that has just been made that we have been denied due process of law. We’ve been denied the opportunity to present witnesses to this Court about these children, and we sternly and strongly object.

THE COURT: Well, let me just tell you this,

both to you, and Mr. Farmer, and to Ms. Murphy: If y’all would do what you were supposed to do, you wouldn’t be having this problem so --

Wait just a minute. Blame yourself (indicating); blame

yourself (indicating); blame yourself (indicating).

That’s what we’re doing. I told her the last time --

MS. MURPHY: I haven’t -- THE COURT: Don’t -- be quiet, please,

ma’am.


MS. MURPHY: (Unintelligible.) THE COURT: Be quiet. I told her -- If you speak up again, I’m going to put you

in jail. Do you understand me? I told her the last time to go see this --

see this doctor, and I told y’all then that if she didn’t do it, I was going to consider taking the children and putting them with her (sic). He (sic) hasn’t done it. I told you that the last time, and I’m tired of this stuff.

If y’all had done what you were supposed to

do, if y’all had done your job, if you had done your job, this thing would have been over two years ago. It wouldn’t have all the expense involved. And y’all haven’t been doing your job, and you need to be -- you need to be checking on that instead of checking on what I’m doing. Okay? You’re not doing your job.

All right. That’s it. MR. FARMER: May I respond? We have the children here to present

evidence. We wish to present evidence, and you’re preventing us from presenting evidence.

THE COURT: It’s over with. Stop taking

down. (Proceedings concluded.)


1.5.3.3.10 The Addendum did not contain a certificate or any type of oath as to completeness. 1.5.3.3.11 Before filing the Addendum, Nan Freeman provided the

following certificate with the transcript of the May 27, 2014 proceedings: STATE OF GEORGIA

COUNTY OF TROUP

I, Nan D. Freeman, being a Certified Court Reporter and Notary Public in and for the State of Georgia at Large, certify that the foregoing transcript is a true record of the proceedings and exhibits in the case of John Harold Murphy v. Nancy Michelle Murphy, Case Number 2012-V-413 in the Superior Court of Coweta County; that I am neither a relative nor employee nor attorney nor counsel of any of the parties, nor a relative nor employee of such attorney or counsel, nor financially interested in the action. This certification is expressly withdrawn and denied upon disassembly, photocopying or duplication in any manner or upon certification of the foregoing transcript or any part thereof including exhibits, if any, by any person or entity other than by the undersigned official certified court reporter. This certification is further expressly withdrawn and denied absent the original signature and the original seal of the undersigned official court reporter, as set out below.


1.5.3.3.12 The original certificate states only that the transcript is a

“true record” absent the required OCGA § 5-14-5 certification

that the transcript is signed, “reciting that the transcript is true, complete,

and correct.”

1.5.3.3.13 The certificate of Nan Freeman goes to great extent to state

that Nan Freeman is not a relative nor employee of any of the parties.

1.5.3.3.14 Nan Freeman’s conduct can be correctly perceived as

protection of the conduct of Chief Judge A. Quillian Baldwin, Jr. The

violation of the law by Judge Baldwin is central in the litigation, as Chief

Judge Baldwin, since his first day in this case, has violated the law and the

Code of Judicial Conduct. It is Chief Judge Baldwin who Nan Freeman

wished to protect, as is now evident.

1.5.3.3.15 The transcript of the May 27, 2014 court proceedings, falsely

certified, was so crucial that during counsel for Michelle Murphy’s

over 40 years of representing clients throughout Georgia, and in more than

ten States before hundreds of judges, counsel has never observed any

judge engage in conduct equivalent to the conduct that Judge Baldwin

exhibited on May 27, 2014 in the Murphy v. Murphy case.

1.5.3.3.16 When Chief Judge Baldwin eventually recused himself from

the case, most likely due to the presentation of the audio recordings, Judge

Baldwin, with full knowledge of the illegal conduct of Nan Freeman,

obtained a position for her with the newly appointed judge in the Coweta

Judicial Circuit, Judge W. Travis Sakrison, while also obtaining a position

with Judge Sakrison for his judicial assistant, Julia Harris,


1.5.3.3.17 On a previous occasion when counsel for Michelle Murphy

requested that Nan Freeman takedown the call of the calendar by Judge

Baldwin, as potential evidence that Judge Baldwin was evading the

Uniform Superior Court Rule 3.1 mandated case management plan, Nan

Freeman approached Judge Baldwin in chambers and informed him of the

request, that would have documented Judge Baldwin’s violations of

Uniform Superior Court Rule 3.1.

1.5.3.3.18 On that occasion, Judge Baldwin, in a full courtroom of

litigants and counsel, yelled at and threatened to put counsel for Michelle

Murphy in jail for begging that the calendar call be recorded. The calendar

call was not recorded as the result of Nan Freeman’s ex parte, chamber

communication with Judge Baldwin. This conduct by Nan Freeman is just

one of the incidences in which she interfered with the constitutional

protections of Michelle Murphy. Provided a choice of official court

reporters, Michelle Murphy would never have engaged Nan Freeman after

she first discovered that she violated the law.

1.5.3.3.19 As the result of the extensive and expensive litigation efforts

of counsel for Michelle Murphy --- opposed and labeled “frivolous” by

Judge Baldwin and counsel for John Harold Murphy --- a case

management plan has now been enacted by the Coweta Judicial Circuit.

1.6 Individual litigants are required to use the Official Court Reporter for all

court proceedings and to pay the fees charged by the Court Reporter in order to

obtain a transcript of a proceeding.

1.6.1 Nan Freeman’s illegal use of her status as the Official Court Reporter

resulted in compensation for herself to the detriment of Michelle Murphy, the


counties in the Coweta Judicial Circuit and other litigants. Nan Freeman

engages in fraudulent conduct from which she derives financial benefits. Nan

Freeman engaged in some of her fraudulent behavior and interference with the

constitutional rights of Michelle Murphy to retain a favored status with Judge

Baldwin, the person on whom her status as an official court reporter depends.

1.6.1.1 Nan Freeman engages in this aspect of her fraudulent conduct by

using several deceptively fraudulent methods.

1.6.1.2 Nan Freeman knows that Chief Judge Baldwin signs without

reading, or, by designating his judicial assistant or law clerk, to audit Nan

Freeman’s request for payments to the counties and therefore she can and

has consistently included a request for funds in excess of those provided and

authorized for her to receive by law, as the counties pay the submissions

without auditing. In this aspect of Nan Freeman’s fraudulent conduct, Nan

Freeman, on a regular basis, has stolen money from governmental entities

for the entire time that she has been an official court reporter for the Coweta

Judicial Circuit.

1.6.1.2.1 The misconduct of Judge Baldwin is relevant to showing how

the habitual, fraudulent interference with the constitutional protections

conduct by Nan Freeman occurred.

1.6.1.3 Nan Freeman’s years of experience in the courtroom have taught

her that counsel for litigants who require transcripts for the protection of their

clients’ rights and litigants who have been sent to prison in criminal cases,

do not know of Nan Freeman’s violation of the law in charging more than

she is allowed by law, or omitting portions of transcripts. Nan Freeman sends

in the United States Mail, by electronic transmissions and otherwise, her


requests for payments, that are required to be paid in order for litigants to

obtain and use the transcripts and for takedown fees that she charges without

a description of the basis for the charge. By engaging in this deceptive,

fraudulent conduct, Nan Freeman engages in theft by taking of money from

all litigants who have paid for transcripts obtained from her during the time

that she has been an official court reporter in the Coweta Judicial Circuit.

Nan Freeman’s requests for payment of takedowns also allows Nan Freeman

to deceptively, fraudulently and illegally take money from litigants as a part

of her fraudulent theft of funds relating to her position as an official court

reporter in the Coweta Judicial Circuit.

1.6.1.4 Nan Freeman and other official court reporters in the State of

Georgia have been able to steal money from litigants and counties, as the

Board of Court Reporting has no effective auditing system, and, from all

appearances, the Board is essentially a political parking area for members

and employees who have not developed a system to prevent the detriment to

litigants that Nan Freeman and other official court reporters have used to

violate the laws of the State of Georgia. The people of Georgia should not

be required to pay for the political debts to the members of the Board of

Court Reporting through illegal payments to official court reporters.

1.6.1.5 Michelle Murphy should not have been required to suffer the

detriment of having her counsel being required to stand up to Judge Baldwin

by refusing not to bring an action against Nan Freeman.

1.6.1.6 It is of great political advantage for lawyers such as the Willis

McKenzie LLP lawyer, Mark Lawrence Degennaro, on behalf of Troup

County, to act as he did in this case in resisting providing the Freedom of


Information Request for the audio recordings of the May 27, 2014 hearing,

and,, as the Glover & Davis lawyer, Nathan Lee, lawyer for Coweta County

has done by not attempting to recover the illegal money stolen from Coweta

County by Nan Freeman. The Glover & Davis lawyers prefer to conceal the

illegalities of Judge Baldwin with illegal transcripts, as this would gain

benefit for the Glover & Davis lawyers litigating against Michelle Murphy.

1.6.1.7 In addition to the money that Nan Freeman obtains illegally that

she has been caught stealing, Nan Freeman received an annual payment from

the State of Georgia for performing as an official court reporter. Nan

Freeman has received this money from the State of Georgia that the Board

of Court Reporting has not sought to recover, or to monitor. Nan Freeman is

compensated by the State of Georgia to be an official court reporter who

follows the law, not a person who violates the law with each work product

that she produces by acts of fraudulent and illegal conduct that she uses for

her unjust enrichment.

1.6.1.7.1 Judge Baldwin engaged in a violation of the Code of Judicial

Conduct by referring Nan Freeman, as an official court reporter, to a

newly appointed judge in the Coweta Judicial Circuit at a time that Judge

Baldwin had information that the appointment would both eliminate that

judge as a potential judge in Michelle Murphy’s underlying case and

financially benefit Nan Freeman for engaging in illegal conduct in not

producing complete transcripts involving Judge Baldwin proceedings.

1.6.1.8 Nan Freeman also receives payments for her court appearances

based upon her attendance from the county in which she attended court ---

these fees must be approved by the Judge Baldwin and are authorized


without Judge Baldwin even knowing the amount that Nan Freeman is due

for the time for which Judge Baldwin was authorizing payment.

1.7 In evaluating the motive of Nan Freeman in not accurately and promptly

providing transcripts and audio recordings that depicted her illegal conduct, it is

relevant to identify the interest of Chief Judge A. Quillian Baldwin, Jr., who was

also participating in violations of Code of Judicial Conduct and other illegal

conduct that was to be reported by Nan Freeman.

1.7.1 Chief Judge A. Quillian Baldwin, Jr. was illegally selected by counsel

opposing Michelle Murphy to preside in a modification of child custody case

in the Superior Court of Coweta County. --- John Harold Murphy v. Michelle

Murphy, Civil Action No. 12V-413 (or, “Murphy v Murphy.”).

1.7.2 Counsel opposing Michelle Murphy was able to select Judge Baldwin

because the Glover & Davis lawyer, Taylor Drake, was able to make a false

assertion that Michelle Murphy was threatening to move to South Carolina with

the children, and in the absence of a Uniform Superior Court Rule 3.1 case

management plan, selected Judge Baldwin to preside in the case on the morning

after Judge Baldwin had attended a political fundraiser sponsored by Taylor

Drake and Melissa Griffis, who Judge Baldwin appointed as the guardian ad

litem over strong objection by counsel for Michelle Murphy.

1.7.3 Michelle Murphy and her counsel, as all lawyers, are required to

exclusively rely upon the Official Court Reporter as their source of the official

transcripts to provide to the appellate courts.

1.7.4 Judge Baldwin and Nan Freeman most likely never thought that either

would be caught violating the LAW*. Judge Baldwin and, most likely, Nan

Freeman, expected the jail and contempt threats to Michelle Murphy and her


counsel would eventually protect them from their exposure of actionable

conduct for their illegal conduct. Never had Judge Baldwin encountered a

mother, as Michelle Murphy, with only the income of that of a hairstylist, who

was willing to drain her assets to withstand the million dollar legal effort by a

father and his new wife, Renee L. Haugerud to strip the mother of her now 14

and 16 year old children, whom the Michelle Murphy had physically cared for

since the children were toddlers.

1.7.5 The mother knew John Harold Murphy, his new spouse, Renee L.

Haugerud, a hedge fund operator, and the guardian ad litem, Elizabeth “Lisa”

F. Harwell, well enough to know that these individuals would not properly

protect the best interest of the children, as each had engaged in criminal conduct

in violation of the laws of Georgia.

1.7.6 Never did Michelle Murphy believe that this trio of persons to whom

Judge Baldwin entrusted the children would so abuse the children that they

would engage “Transporters” to snatch the two children from their beds in the

dark of the early morning hours and without any explanation, have the children

flown on two separate planes and taken to Utah and placed in Elevations, RTC,

a “residential treatment center,” separate from each other without even a phone

call to their mother.

1.7.6.1 This conduct may protect the best interest of the reputation of hedge

fund of Renee L. Haugerud, but it is a monument to the necessity of having

the conduct of persons engaging in the conduct of Nan Freeman and Judge

Baldwin addressed by an unbiased court.

1.7.5.2 According to other children who have had their parents treat them

in this manner, after the children return from such institutions, they live in


fear of being again treated in such a manner and are therefore taught to make

false statements both about the threats and about the conduct of their

caretakers.

1.7.5.3 Such treatment is most always a lifetime scarring upon the children.

2. Procedural Background Relevant to the Illegal Conduct of Nan Freeman

2.1 The Superior Court of Fulton County, upon motion of Nan Freeman, based

upon jurisdictional grounds, ordered the case against Nan Freeman transferred to

the Superior Court of Troup County after the persons affiliated with the Board of

Court Reporting of the Judicial Council of Georgia, the Fulton County

jurisdictional defendants, were voluntarily dismissed without prejudice.

2.1.1 The current style of this case used here now eliminates the dismissed

Fulton County jurisdictional defendants.

2.1.1.1 The case against Nan Freeman was initiated in the Superior Court

of Troup County on February 13, 2015.

2.1.2 During most of the time relevant to the causes of action in this

Complaint, Nan Freeman was an official court reporter serving the Coweta

Judicial Circuit. --- Nan Freeman, at times relevant to this Complaint, was

mostly the official court reporter for Chief Judge A. Quillian Baldwin, Jr.---

Some of Nan Freeman’s illegal and other actionable conduct, as evidence of

her pattern of engaging in illegal conduct, includes the time that Nan Freeman

was the official court reporter for Judge Allen B. Keeble and other judges

serving in the Coweta Judicial Circuit.

2.1.2.1 On March 4, 2015, after Judge Baldwin refused to waive service

of a subpoena, counsel obtained subpoenas that were served upon Judge


Baldwin and his former Administrative Assistant, Julia Harris, for their

attendance at depositions noticed for March 14, 2015.

2.1.3 On March 12, 2015, Nan Freeman filed her First Amended Answer and

Affirmative Defenses raising new defenses --- this filing occurred after

Michelle Murphy noticed the depositions of Chief Judge A. Quillian Baldwin

Jr., recused from presiding over Murphy v. Murphy, and Julia Harris, Judge

Baldwin’s former judicial assistant.

2.1.3.1 These depositions were delayed by the Attorney General’s motion

for a protective order that was defective, as the motion of the AG, the lawyer

for the parties, did not contain an oath from the parties seeking the protective

order. Based upon the AG’s commitment to provide an affidavit from the

persons sought to be deposed, an informal agreement to delay the depositions

was reached. The affidavits have not been provided and therefore the issue

relating to the protective order has not been resolved.

2.1.3.2 There is an unanswered inquiry to the Attorney General, if the

Attorney General provided assistance to counsel for Nan Freeman and

thereby Nan Freeman in defending her illegal conduct that has deprived the

State of Georgia of money due to the State of Georgia for Nan Freeman not

performing under the requirements for an official court reporter as she is

compensated by the State of Georgia to perform under the supplementary

compensation provided to her by the State of Georgia..

2.1.3.3 The evidence sought from Judge Baldwin and Julia Harris relates

to the fraud, negligent misrepresentations, breach of contract, illegal

authorizations for compensation, theft by taking and conversion from the

State of Georgia by Nan Freeman that forms a pattern of such illegal conduct


by Nan Freeman that supports the damages including punitive damages

sought by Michelle Murphy and the recovery by the State of Georgia with a

potential RICO action’s five year statute of limitations.

2.1.3.4 The State of Georgia has paid Nan Freeman annual compensation

for years. The payment requires that she adhere to the standards of an official

court reporter, which she has breached. In addition to Nan Freeman being

unjustly enriched by violating the LAW,* the State of Georgia has a vested

interest in the Attorney General of Georgia maintaining the integrity of the

judicial proceedings by supporting full exploration of Judge Baldwin’s

authorization of payments of the illegally and fraudulently obtained

payments to Nan Freeman. The Attorney General should not be seeking a

protective order to prevent the evidence from Judge Baldwin and Julia

Harris, or in any manner assisting Nan Freeman in defense of her and Judge

Baldwin’s legal defense.

2.1.3.5 Counsel, on behalf of Michelle Murphy, contracted with Nan

Freeman to takedown and to thereafter transcribe the proceedings at each of

the hearings where Nan Freeman was the official court reporter in the

Murphy v. Murphy case. This contract provided specific compensation for

Nan Freeman and quality standards that were established by the State of

Georgia.

2.1.3.6 In accordance with the contract, Nan Freeman rendered invoices

to Michelle Murphy’s counsel, who, on her behalf, paid the amounts

requested by Nan Freeman on each of the occasions that Nan Freeman had a

contract to provide Michelle Murphy for takedown and transcription of the

court proceedings.


2.1.3.7 The financial detriment to Michelle Murphy created by the illegal

conduct of Nan Freeman is far greater than the amount of the illegal charging

of Michelle Murphy and the cost of catching Nan Freeman engaging in fraud

and theft by taking.

2.1.3.8 Nan Freeman knew the necessity of providing Michelle Murphy

an accurate transcript, as she had observed the inequitable treatment that

Michelle Murphy and her counsel received from Judge Baldwin. It was this

intentional conduct by Nan Freeman that exposes her assistance to Judge

Baldwin in depriving Michelle Murphy and her children of their protections

under the LAW*.

2.1.3.9 After the action was brought against Nan Freeman by Michelle

Murphy, Judge Baldwin maintained that counsel for Michelle Murphy would

be required to obtain another court reporter, as Judge Baldwin could not

obtain a court reporter in matters involving Michelle Murphy. Nan

Freeman’s illegal conduct results in predictable and foreseeable, ancillary

detriment to Michelle Murphy and the best interest of her children. Nan

Freeman’s conduct in refusing to timely provide Michelle Murphy the audio

recording and the omitted portions of the transcript was an intentional act by

Nan Freeman designed to participate with Judge Baldwin in his violation of

the LAW*.

2.1.3.9.1 Nan Freeman’s conduct interfered with the constitutional

protections provided to Michelle Murphy.

2.1.3.10 Nan Freeman was selected, retained by, and served as the sole

discretion of Chief Judge A. Quillian Baldwin, Jr., as an official court

reporter for Chief Judge A. Quillian Baldwin, Jr., in all of the in-court


proceedings in Murphy v. Murphy until Chief Judge Baldwin recused

himself, excepting one, when she was absent and the proceed was reported

by another reporter until Judge Baldwin recessed the hearing during the

cross-examination of Dr. Patricia Jones Nice by counsel for Michelle

Murphy.

2.1.3.11 Judge Baldwin, after the exposure of the illegal conduct of Nan

Freeman, even recommended that Coweta Judicial Circuit Judge W.

Sakrison use Nan Freeman and Julia Harris in his newly established court

office. Nan Freeman intentionally agreed to take the position with Coweta

Judicial Circuit Judge W. Sakrison while knowing that this would both delay

the right to a hearing of Michelle Murphy and disqualify Coweta Judicial

Circuit Judge W. Sakrison, who did recuse himself.

2.1.3.12 Chief Judge Baldwin did not recuse himself until after Michelle

Murphy brought over twenty (20) motions for his disqualification in the

Superior Court of Coweta County, sought judicial regulatory actions against

Chief Judge Baldwin and tendered to the Clerk of the Superior Court of

Coweta County two comprehensive motions identifying the corruption of

Chief Judge Baldwin and some of those participating in his corruption,

including but not limited to the illegal and other intentional conduct of Nan

Freeman.

2.2 During the Murphy v. Murphy case in the Superior Court of Coweta County,

there were initially two systemic issues relating to the disqualification of Chief

Judge Baldwin to serve as the judge in the case --- each issue required accurate,

unbiased court reporting, which Nan Freeman did not provide, in order to reduce

the litigation expenses of Michelle Murphy to obtain the disqualification of Chief


Judge Baldwin, for preservation of a record and to diminish the prejudice to

Michelle Murphy and her counsel for addressing the illegal, systemic practices of

Judge Baldwin.

2.2.1 There was the primary “judge-shopping” systemic issue involving the

Judges of the Superior Court of Coweta County’s systemic, intentional

violations of the mandate of Uniform Superior Court Rule 3.1. --- The Coweta

Judicial Circuit did not have a legally required, Uniform Superior Rule 3.1 case

management plan; therefore, Clerk of Superior Court of Coweta County, Cindy

Brown, did not randomly assign judges as would have been required by an

enacted Rule 3.1 case management plan.

2.2.1.1 The absence of the Rule 3.1 mandated case management plan

allowed Taylor Drake of Glover & Davis to select Chief Judge Baldwin as

the judge for the case and for Chief Judge Baldwin to accept his being hand-

picked as the judge, in furtherance of the fraudulent conduct of Taylor Drake

and Glover & Davis in which Judge Baldwin participated for the benefits

that the Glover & Davis lawyers politically provided to him.

2.2.1.2 The Glover & Davis law firm was able to engage in its habitually

illegal and unethical modus operandi of judge-shopping to obtain Judge

Baldwin when that conduct was financially beneficial to this law firm ---

such conduct by Glover & Davis was perceived to be in furtherance of its

business model of marketing political influence with Superior Court judges.

2.2.1.3 In the Murphy v Murphy case, the Glover & Davis lawyer did this

by feigning the need for an immediate hearing based upon the false

representation in the record of the case that Michelle Murphy was

threatening to take the children out of school and move to South Carolina. -


-- Any such out-of-state move by any domestic relations litigant was already

known to Chief Judge Baldwin to be prohibited by the Standing Order of the

Coweta Judicial Circuit. --- At the time that the Glover & Davis lawyers filed

the case for John Harold Murphy, he was living in Lookout Mountain,

Tennessee and currently has taken the children to St. Thomas, USVI where

this father can best secret his alcoholism and abuse of Michelle Murphy’s

children while obtaining substantial tax benefits for his current hedge fund

spouse, Renee L. Haugerud and her business entities, including Galtere, Ltd.

2.2.1.4 An aspect of the illegal judge-shopping by the Glover & Davis

lawyers was exposed by the Supreme Court of Georgia in Mayor &

Aldermen of Savannah v. Batson-Cook Co., 291 Ga. 114 (2012), a case

originating in the Superior Court of Troup County.

2.2.1.5 The hand-selection of Judge Baldwin and his immediate

appointment of Melissa Griffis as the guardian ad litem, without an

evidentiary hearing, and over strong objection by counsel for Michelle

Murphy, occurred on the morning after the Glover & Davis lawyer and

Melissa Griffis co-sponsored a political judicial rally for Emory Palmer, a

candidate for a Coweta Judicial Circuit vacant judgeship. The political

gathering was attended and supported by Judge Baldwin, in an open seat

Superior Court Judge election.

2.2.1.6 Nan Freeman, the court reporter who covered the hearings in

Murphy v Murphy, knew of the strong priority of Chief Judge Baldwin to

continue presiding in that case and of the persistent efforts by the Glover &

Davis lawyer to retain Chief Judge Baldwin on the case, as he prohibited

counsel for Michelle Murphy from presenting evidence on such crucial


issues as his May 27, 2014 temporary change of custody. In presenting the

completed transcript of this May 27, 2014 hearing, Nan Freeman, with the

authority and rights vested in her by the State of Georgia to serve as an

Official Court Reporter, certified falsely that it was a true record of the

proceedings, when, in addition to not taking down Judge Baldwin’s

commitment to allow the children to testify, she had actually excluded four

(4) pages of the most relevant Code of Judicial Conduct and legal violating

conduct of Judge Baldwin. (Murphy v. Murphy, Tr. May 27, 2014, p. 42).

2.2.1.7 Nan Freeman knew so well that counsel for Michelle Murphy was

attempting to obtain a record to support the violation of the Rule 3.1

mandated case management plan, that on August 6, 2013, when Michelle

Murphy’s counsel requested that the call of the calendar be recorded,

Nan Freeman, in order to prevent the taking-down of the calendar call that

could have documented violations of the newly enacted case management

plan, intentionally went into chambers to inform Judge Baldwin that counsel

for Michelle Murphy had requested the recording of the calendar call. As the

result of that intentional, ex parte communication to Judge Baldwin by Nan

Freeman to intentionally omit a transcript which would reflect violations of

Rule 3.1, Judge Baldwin came into open court, yelled at Michelle Murphy’s

counsel and threatened to place Millard Farmer in jail for attempting to

explain the need for the record. (Murphy v. Murphy, Tr. Aug. 6, 2013, pp. 3-

5, that conduct is supported by an audio recording of Judge Baldwin’s

hollering. There was no transcript of the judge-selection of cases conduct on

that day and a transcript was never allowed of any future calendar calls.


2.2.1.8 Nan Freeman’s conduct violated her obligation of equitable

conduct to both parties to the litigation, as the Glover & Davis lawyers and

their client, John Harold Murphy, wished to retain Judge Baldwin in the case

and thereby wished to conceal their and his method of judge-shopping by

lawyers and case-shopping by judges.

2.2.2 The other systemic issue involved the more than 20 motions on behalf

of Michelle Murphy to disqualify Judge Baldwin, beginning on May 1, 2012,

and the seeking of persistent regulatory actions, beginning on

November 25, 2013, to have Judge Baldwin disqualified --- the first of these

disqualifying motions occurred within five (5) days of the first chambers

conference after the Murphy v Murphy case was filed in the Superior Court of

Coweta County and continued until February 2, 2015, with the tendered

pleadings clearly identifying the fraudulent and false accusation used against

Michelle Murphy.

2.2.2.1 At the first hearing in Murphy v Murphy, a feigned emergency

hearing that was converted into a conference in chambers, Judge Baldwin

signed, without reading, an Order prepared by Taylor Drake, the Glover &

Davis lawyer appointing Melissa Griffis as the guardian ad litem with the

illegal authority to temporarily change custody of Michelle Murphy’s

children without judicial approval, or a hearing, and over strong objection

from counsel for Michelle Murphy.

2.2.2.2 The first in-chambers conference in Murphy v Murphy set the

agenda of the entirety of the proceedings that followed and resulted in the

case against Nan Freeman


2.2.2.3 It is highly relevant to identify that attorneys for clients who

litigate systemic issues involving judicial conduct that attempts to mask

judicial bias are often subjected to the type of treatment that Judge Baldwin

inflicted upon Michelle Murphy. It is the exception that the official court

reporter will intentionally engage in conduct that is supportive of the illegal

conduct of the judge, as did Nan Freeman in her actions that instituted this

litigation, that, as the litigation progressed, uncovered the longstanding,

illegal conduct of the court reporter that Judge Baldwin, his judicial assistant,

and his law clerk apparently supported, as the hostility of their exchanged

messages, that were eventually obtained from Nan Freeman, reflect. This

type of conduct is also reflected by no one in Judge Baldwin’s chambers

auditing the authorizations for compensation of Nan Freeman which were

submitted to counties for payment to Nan Freeman.

2.2.3 Incorporated Information The factual information contained in this

section and the following sections and the attachments is to be considered in each

of the causes of action, just as all information contained in this Complaint is to be

considered as part of each of the causes of action and relief requested in this

Complaint. It is only for the purpose of organization that the headings of the

various sections identify the information as associated with the causes of action

against Nan Freeman, the event, explanation or relief sought.

Informal and Administrative Attempts to resolve the Issues.

2.2.4 Michelle Murphy initially sought informal relief from Nan Freeman by

counsel for Michelle Murphy requesting to purchase a copy the audio recording

of the testimony that Nan Freeman would use to produce a transcript. Nan

Freeman refused this request on behalf of Michelle Murphy.


2.2.4.1 Next, a Freedom of Information Act request was made to Troup

County for a copy of the audio recording. This request was denied. Then, a

request to the Board of Court Reporting of the Judicial Council of Georgia

was made. This request was denied. These informal and administrative

attempts left Michelle Murphy only the option for the relief sought with this

Court.

2.2.4.2 Nan Freeman was then advised that she would be sued if she

did not allow Michelle Murphy to purchase a copy of the audio recording

The Plaintiff

2.3. The plaintiff is Michelle Murphy, the mother of J. M. age 16 and T. M, age

14, and is the defendant in an underlying modification of child custody action

brought against her in the Superior Court of Coweta County.

2.3.1 The action was brought by one of the lawyers who was recommended

to the former husband of Michelle Murphy by Judge Louis Jack Kirby, also a

judge in the Coweta Judicial Circuit. Judge Louis Jack Kirby is the judge who

officiated at the wedding of John Harold Murphy and Renee L. Haugerud with

an illegally obtained marriage license, and, who, while in private practice,

represented John Harold Murphy in his divorce from Michelle Murphy. John

Harold Murphy secreted $180,000 in stock options from Michelle Murphy until

a day after Michelle Murphy agreed to a settlement agreement before Judge

Baldwin. Michelle Murphy lost her marital share of these stock options.

2.3.2 Taylor Drake is the Glover & Davis suggested lawyer, who knew how

to select Judge A. Quillian Baldwin as the judge, because at the time of Judge

Baldwin's selection by Taylor Drake, the Coweta Judicial Circuit did not have

a Uniform Superior Court Rule 3.1 mandated case management plan and at that


time, the Glover & Davis lawyers had not been caught judge-shopping, as one

of their methods of judge shopping was revealed in Mayor & Aldermen of

Savannah v. Batson-Cook Co., 291 Ga. 114 (2012).

2.3.3 After divorcing Michelle Murphy, John Harold Murphy married a

wealthy hedge fund operator, Renee L. Haugerud, who has directly or indirectly

spent an approximate million dollars financing John Harold Murphy's attempt

to take over custody of the two children who have lived in the home with

Michelle Murphy, a hair stylist, since they were toddlers when John Harold

Murphy abandoned them for the life of a single person in New York City, where

he primarily lived until he located Renee L. Haugerud.

The Defendant

2.3.4 Nan Freeman is a court reporter, Certificate Number 1939, whose

conduct is governed by the Board of Court Reporting of the Judicial Council of

Georgia. Nan Freeman is a resident of Troup County Georgia and waived

service that is perfected with service upon her attorney.

2.3.5 Nan Freeman’s license to serve as an official court reporter is controlled

by the Board of Court Reporting of the Judicial Council of Georgia and her

employment in the Coweta Judicial Circuit was controlled in the case involving

Michelle Murphy, by Chief Judge A. Quillian Baldwin, Jr..

2.3.6 Freeman Reporting, Inc. is an exclusively owned corporation of Nan

Freeman, who is its registered agent for service at 106 Carter Street LaGrange,

GA 30240. Nan Freeman and her license as an official court reporter is

necessary to the only business functions of Freeman Reporting, Inc., that at

times includes it identity on bills for the services of Nan Freeman, as a licensed

court reporter. The license of Nan Freeman to serve as an official court reporter


is ultimately controlled by the Board of Court Reporting of the Judicial Council

of Georgia.

Jurisdiction and Venue

2.3.7 The Superior Court of Troup County has jurisdiction over the subject

matter of this action.

2.3.8 Venue is proper in this Court.

Additional Factual Information Incorporated as an Integral Part of the Causes of Action in the Complaint 2.4 The Board of Court Reporting, as authorized by OCGA § 15-14-24, was

created by the Judicial Council of Georgia to define and regulate the practice of

court reporting in Georgia.

2.4.1 Nan Freeman, and other official court reporters, have learned how to

engage in illegal conduct against counties, the State of Georgia and individuals,

such as Michelle Murphy, as often it is in the best personal interest of the judge

who provides the court reporter the authority to become the official court

reporter, to obtain illegal concessions from the official court reporter.

2.4.2 It would have been extremely difficult to present to the regulatory

authorities the illegal conduct of Judge Baldwin that followed his failure to

allow any evidence without the audio recordings that memorialized the pattern

of the yelling and refusal to allow the presentation of evidence on behalf of

Michelle Murphy, without all of the audio recordings that were expensive to

obtain through this litigation.


2.4.3 Nan Freeman knew on several occasions that her violations of her legal

responsibilities to Michelle Murphy were not in the best interest of Judge

Baldwin’s attempts to conceal his violations of the LAW*.

2.4.4 On those occasions Nan Freeman willfully and intentionally or through

reckless and wanton conduct and with disregard of the consequences, violated

the rights of Michelle Murphy that caused Michelle Murphy to suffer great

mental pain and anguish together with other damages.

2.5 There was a particularized need for the audio recordings, as the trial judge,

with false statements in his Orders, attempted to justify his unjustifiable, unethical

screaming at Michelle Murphy and her counsel. This unethical conduct by the

trial judge is integrated into and is a part of the trial judge's illegal deprivation of

other statutory and constitutional rights of Nancy Michelle Murphy and her

children, ages 16 and 14. The conduct of this official court reporter deprived

Michelle Murphy of her right to counsel and Millard Farmer, of their statutory

and constitutional rights, as each have been held in criminal contempt, with a

record of the court proceedings that does not fully reflect the detrimental effect of

personal animosity of the trial judge against them for attempting to exercise their

constitutional protections.

2.5.1 As the result of the ex parte communication of Nan Freeman to prevent

the recording of the calendar call early in the litigation, the transcription of the

calendar call was prevented and counsel for Nancy Michelle Murphy was

abusively treated by Judge Baldwin in open court.

2.5.2 Judge Baldwin came into the courtroom apparently mad about the

request to have the calendar call taken down, as he certainly believed that it

was in furtherance of a challenge to the biased judge selection conduct in


violation of Uniform Superior Court Rule 3.1 and the connection between the

private cases of the guardian ad litem, Elizabeth "Lisa" F. Harwell, who was

caught converting trust funds by counsel for Michelle Murphy, and Judge Louis

Jack Kirby.

2.5.3 The transcript by Nan Freeman picks up at that point, as follows. This

transcript does not reveal Judge Baldwin hollering, “Do you understand me? Do

you understand me?” at Millard Farmer, who was standing at the bench, only a

foot or so away from Judge Baldwin, in a courtroom packed with people, where

Judge Baldwin was performing in order to deter other lawyers from bringing

actions exposing his illegal conduct.



First Cause of Action

[By Michelle Murphy against Nan Freeman for fraud and/or alternatively negligent misrepresentation ]

2.6 As supported by information contained in this Amended Complaint and

information contained in this and each of the other following causes of action that

are incorporated as a part of this First Cause of Action, Michelle Murphy

summarily identifies the causes for fraud and/or alternatively negligent

misrepresentation by Nan Freeman for which Michelle Murphy seeks damages

from Nan Freeman as follows.

2.6.1 Nan Freeman, at all relevant times supporting this and other causes of

action in matters that first originated during Nan Freeman’s obligation as an

official court reporter, assigned and contracted to fulfill her obligations in John

Harold Murphy v. Nancy Michelle Murphy, in the Superior Court of Coweta

County, Civil Action No 12V-413, engaged in fraud and/or alternatively

negligent misrepresentation, damaging Michelle Murphy.

2.6.1.1 As a method of engaging in her pattern of fraud and/or

alternatively, negligent misrepresentation conduct, Nan Freeman used the

authority of Superior Court Chief Judge Baldwin in attempts to intimidate

Michelle Murphy and her counsel from bringing an action against her that

would expose her fraud and/or alternatively negligent misrepresentation

conduct in order to recover for the damages inflicted upon Michelle Murphy

and her counsel.

2.6.1.2 Nan Freeman, as part of her fraud and/or alternatively, negligent

misrepresentation conduct, prejudiced the judicial assistant and law clerk of

Judge Baldwin, who advocated for Nan Freeman against Michelle Murphy

and her counsel. Michelle Murphy v. Nan Freeman Amended Complaint Page 39 of 55

2.6.1.3 Nan Freeman’s fraud and/or alternatively, negligent

misrepresentation conduct was an active part of Nan Freeman’s conduct

throughout the proceedings for which Nan Freeman served as the official

court reporter.

2.6.1.4 Nan Freeman, as a part of her fraud and/or alternatively, negligent

misrepresentation, made her requests for payment for official court reporting

work for Michelle Murphy with documents that did not identify the basis for

the charges that Michelle Murphy was required by law to pay if Michelle

Murphy was to pay for the takedown, and/or was to receive a transcript of a

proceeding.

2.6.1.4.1 These requests charged and collected fees from Michelle

Murphy that were illegal and not due, but the fraud and/or alternatively,

negligent misrepresentation of Nan Freeman could not be detected from

observing the documents supplied by Nan Freeman that were intended to

conceal the fraud and/or alternatively, negligent misrepresentation

2.6.1.4.2 Nan Freeman was able, in part, to engage in her deceptive fraud

and negligent misrepresentation and other illegal actionable conduct by

failing to adhere to legal page margins and to include the required number

of characters allowed per line, and, the required number of qualifying lines

for compensation per page. This conduct was systematically

accomplished by the use of a template that was designed to produce a

transcript which did not qualify for the compensation which she claimed,

and which did not contain a certificate that complied with the laws of

Georgia.



misrepresentation charged Michelle Murphy for transcripts accompanied by

certificates feigned to be as required by law, while the feigned certificates

include almost one page of information, for which Nan Freeman charges,

that is not required by law, or the legally required certificate. Michelle

Murphy relied upon the preservation of the court proceedings by the official

court reporter and could not determine from her location in the courtroom

when Nan Freeman was taking down the proceedings. This allowed Nan

Freeman to engage in her fraud and/or alternatively, negligent

misrepresentation without being detected.


misrepresentation conduct was reckless and with wanton disregard of

consequences and may evince an intention to inflict injury upon Michelle

Murphy and her two children.

2.6.1.7 Nan Freeman places her signature on an official appearing

certificate, omitting required information and including other information

that is not required, for which she apparently charges as part of the

compensation that she collects as a part of her unjust enrichment, fraud

and/or alternatively, negligent misrepresentation conduct. At no time does

Nan Freeman provide the certificate required of an official court reporter by

the law of Georgia. The failure to provide the required certificate is a part of

the pattern of fraud and/or alternatively negligent misrepresentation by Nan

Freeman.

2.6.1.8 A part of the continuous fraud and/or alternatively, negligent

misrepresentation conduct of Nan Freeman occurred surrounding Nan


Freeman’s obligation and conduct relating to a May 27, 2014 proceeding in

Murphy v. Murphy.

2.6.1.9 Nan Freeman used a deceptive physical appearance that gave the

appearance that she was fulfilling her legal obligations in the courtroom,

including being located at her reporting station with her equipment, that was

a scheme or an artifice to defraud Michelle Murphy and thereby her counsel

and the appellate courts and all other courts. On May 27, 2014, Nan Freeman

failed to take down and accurately and completely transcribe the orders,

assurance to Michelle Murphy, her children and her counsel that the children

would be allowed to testify at the May 27, 2014 proceeding and thereby

deceptively engaged in actionable fraud and/or alternatively, negligent

misrepresentation conduct, creating damages sought here by Michelle

Murphy.

2.6.1.10 At the time of the May 27, 2014 proceeding, Nan Freeman was

a person known to Michelle Murphy and her counsel as the official court

reporter who was assigned to the case as the official reporter that Michelle

Murphy, through her counsel, contracted to report and transcribe the

proceeding on May 27, 2014.

2.6.1.11 Nan Freeman, as a part of her fraud and/or alternatively,

negligent misrepresentation conduct, requested that Michelle Murphy make

payment to her for work which Nan Freeman deceptively failed to perform

while appearing to perform as required by the Board of Court Reporting

Rules and Regulations.

2.6.1.12 In addition to not recording and transcribing the first part of the

proceeding, while deceptively appearing to be recording the court


proceedings, Nan Freeman, as a part of her fraud and/or alternatively,

negligent misrepresentation, provided Michelle Murphy, opposing counsel

and the Court a certificate stating that the transcript of the May 27, 2014

proceedings provided to the parties, which Nan Freeman was compensated

to produce, was a true record of the proceedings.

2.6.1.13 Nan Freeman, who personally transcribed the transcript from a

recording that she produced, as a part of her fraud and/or alternatively,

negligent misrepresentation conduct, omitted the four pages of Judge

Baldwin’s massive temper tantrum that no human in attendance could forget.

Nan Freeman engaged in fraud and/or alternatively, negligent

misrepresentation conduct by attempting to have Judge Baldwin use his

authority as the presiding Judge to influence counsel for Michelle Murphy

not to bring an action against Nan Freeman that ultimately provided counsel

Murphy the information to learn of as substantial portion of the fraud and/or

alternatively negligent misrepresentation conduct of Nan Freeman, much of

which was verified during the deposition of Nan Freeman where she

continued to conceal her fraud and/or alternatively negligent

misrepresentation by first making false statements and frequently feigning

that she did not remember.

2.6.1.14 Nan Freeman, on another occasion, on August 6, 2013, in

furtherance of obtaining acceptance by Judge Baldwin for her illegal conduct

and as a part and parcel of her fraud and/or alternatively, negligent

misrepresentation conduct involving Michelle Murphy, went secretly into

the chambers of Judge Baldwin to inform him that counsel for Michelle

Murphy wished for the calendar call to be taken down that could been used


to support the continuing violations of Judge Baldwin involving the newly

enacted case management plan.

2.6.1.15 Nan Freeman’s fraud and/or alternatively negligent

misrepresentation was intentional, and in reckless and wanton disregard of

consequences that evinced an intention to inflict injury on Michelle Murphy,

which were the consequences of her pattern of fraud and/or alternatively

negligent misrepresentation of Nan Freeman.

2.6.1.16 Nan Freeman, as a part of her fraud and/or alternatively

negligent misrepresentation conduct violated her contractual and other legal

obligations requiring that Nan Freeman take down the complete court

proceedings that included, but were not limited to, the courtroom orders and

directive of Judge A. Quillian Baldwin, Jr. Nan Freeman was a person known

to Michelle Murphy and her counsel as an official court reporter and upon

whom Michelle Murphy and her counsel had no legal option but to rely for

complete transcription of the courtroom proceedings.

2.6.1.17 After the May 27, 2014 proceeding that is described in more detail

earlier in this Amended Complaint, Nan Freeman’s fraud and/or

alternatively, negligent misrepresentation was used to obtain payment for a

transcription of that May 27, 2014 proceeding with a request for payment

document that did not identify the basis for the charges in a manner that it

could be determined that Nan Freeman was deceptively and fraudulently

seeking illegal compensation for her work and for the transcript that did not

contain the opening Order of Judge Baldwin to Michelle Murphy and her

children and Judge Baldwin’s representations to Michelle Murphy’s counsel

concerning the scope of evidence that would be allowed at the proceeding.


2.6.1.18 Nan Freeman, as a part of her fraud and/or alternatively,

negligent misrepresentation, also did not transcribe the last four pages of the

May 27, 2014 proceeding until she was caught by counsel for Michelle

Murphy in not including those pages in the transcript that she provided to the

Court and counsel with her certificate that the transcript was a “true record

of the proceedings.”

2.6.1.19 Nan Freeman omitted four (4) pages from the transcript, as a part

of her fraud and/or alternatively, negligent misrepresentation and did not

include the objections on the record by counsel for Michelle Murphy, Judge

Baldwin’s uncontrolled hollering at Michelle Murphy and her counsel, and

counsel’s statement to Judge Baldwin that counsel had available ready

evidence to present on behalf of Michelle Murphy and that Michelle Murphy

had not even been provided an opportunity to testify on direct examination.

2.6.1.20 With the May 27, 2014 transcript, as with all of the transcripts of

previous proceedings in Murphy v. Murphy which Nan Freeman produced,

Nan Freeman did not provide Michelle Murphy a legal certificate even

though Nan Freeman deceptively charged Michelle Murphy an illegal

amount that Michelle Murphy paid, as she did not know that Nan Freeman

had engaged in her fraud and/or alternatively, negligent misrepresentation

and omitted the two most relevant parts of the proceeding and was illegally

charging Michelle Murphy, as Nan Freeman had illegally charged Michelle

Murphy for the transcripts of each of the hearings, as a part of the pattern of

illegal conduct of Nan Freeman since the time that she had been an official

court reporter in the Coweta Judicial Circuit that was continuously plagued


with the fraud and/or alternatively, negligent misrepresentation of Nan

Freeman.


misrepresentation, sought and obtained assistance from Judge Baldwin in

furtherance of secreting from Michelle Murphy that through her fraud and/or

alternatively, negligent misrepresentation, she collected money from

Michelle Murphy for work of an official court reporter that violated the laws

of Georgia, as identified to Nan Freeman by the Board of Court Reporting.

2.6.1.22 The refusal by counsel for Michelle Murphy to yield to the request

of Judge Baldwin not to seek action against Nan Freeman resulted in

prejudice to Michelle Murphy and her attempts to obtain recovery of her

children, as Judge Baldwin vindictively accelerated this illegal conduct

directed toward Michelle Murphy.

2.6.1.23 At all times that counsel for Michelle Murphy was requesting Nan

Freeman to allow Michelle Murphy to purchase the audio recording of the

court proceeding, Nan Freeman and Judge Baldwin were attempting to

muscle up on Michelle Murphy by first seeking to have Michelle Murphy

waive her protections under the LAW* --- when that failed, Judge Baldwin

began accelerating the consequences of Nan Freeman’s fraud and/or

alternatively, negligent misrepresentation conduct.

2.6.1.24 Nan Freeman apparently believes that her association with Judge

Baldwin justifies her illegal conduct, fraud and/or alternatively, negligent

misrepresentation that involved Nan Freeman’s illegally interfering with the

constitutional protections that the LAW* provided to Michelle Murphy in


her attempts to protect her children from the detriment that Judge Baldwin

has created in this family’s life.

2.6.1.25 At all times excepting August 13, 2013, when another reporter,

Alice Moore, was assigned to the case for that one hearing, Nan Freeman

engaged in the fraud and/or alternatively, negligent misrepresentation

conduct as the official court reporter during the Murphy v. Murphy case.

2.6.1.26 Nan Freeman engaged in further fraud and/or alternatively,

negligent misrepresentation involving Michelle Murphy in the manner in

which she deceptively violated her contractual and legal obligation to

Michelle Murphy to accurately transcribe complete and accurate

documentation of the courtroom proceedings, by Nan Freeman placing in the

United States Mail requests for payment to counsel for Michelle Murphy that

indicated that she sought payment for fulfillment of the contractual and legal

obligation from Michelle Murphy for the work product of an official court

reporter who complied with the law.


misrepresentation, did not itemize the financial obligation of Michelle

Murphy to Nan Freeman for her official court reporting work in a manner

that Michelle Murphy could determine whether or not the requested payment

was legal and in fulfillment of the legal obligation of Nan Freeman when the

documents purporting to be transcripts of proceedings transcribed by Nan

Freeman did not include the legally required certificate, and, more

detrimentally, did not include a complete transcription of the orders and

directives of Judge A. Quillian Baldwin, Jr. in the courtroom

on May 27, 2014.


2.6.1.28 Michelle Murphy made payment to Nan Freeman to transcribe and

provide to Michelle Murphy the entirety of the May 27, 2014 proceeding in

a format and with a certificate in accordance with the laws of Georgia; now

Michelle Murphy has information that Nan Freeman not only illegally

charged her and required her to engage in conduct detrimental to Michelle

Murphy in order to determine that Nan Freeman would never produce the

needed transcript. Judge Baldwin, as retaliation, has refused to allow

Michelle Murphy to contact her children since May 27, 2014. This conduct,

without a complete transcript, has created great mental anguish and suffering

by Michelle Murphy that is continuing.

2.6.1.29 Nan Freeman engaged in a long standing pattern of fraud and/or

alternatively, negligent misrepresentation in charging fees for her work as an

official court reporter that are illegal under the laws of Georgia.

2.6.2 Nan Freeman engaged in the actionable fraud and/or alternatively,

negligent misrepresentation conduct, as more specifically identified in this

Amended Complaint and its attachments. Each of the attachments to the

Amended Complaint are incorporated and made a part of this Cause of Action.

2.6.3 Nan Freeman engaged in her actionable fraudulent and illegal conduct

including the interference with the constitutional protections against Michelle

Murphy, numerous other persons and governmental entities that are presently

not each identifiable to Michelle Murphy and those who were victims of Nan

Freeman’s fraud and/or alternatively, negligent misrepresentation, by illegally

overcharging with documents requiring payment from them that were

transferred in the United States Mail.


2.6.4 Nan Freeman was able to engage in her fraud and/or alternatively,

negligent misrepresentation conduct, in part, as she was an Official Court

Reporter, with income supplemented by the State of Georgia, in the Coweta

Judicial Circuit of Georgia (or “Coweta Circuit”) that included the counties of

Coweta, Troup, Meriwether, Heard and Carroll ( or, “County Entities.”)

2.6.5 The nature of fraud and/or alternatively, negligent misrepresentation,

illegal conduct of Nan Freeman is such that the extent of the fraudulent

violations of the LAW* by Nan Freeman and those participating with her has

yet to be discovered by Michelle Murphy, as Nan Freeman and those

participating with her are engaged in an ongoing attempt to secret their

violations of the Law* with others who were violating protections provided to

Michelle Murphy and her minor children as more specifically identified

throughout this Amended Complaint, in violation of the LAW*.

2.6.6 The unconstitutional fraud and/or alternatively, negligent

misrepresentation conduct initiated by Nan Freeman, one of the official court

reporters for the Coweta Judicial Circuit and her exclusively owned

corporation, Freeman Reporting, Inc., was at times perfected under color of law

by assistance of state actors includes, but is not limited to, secreting of audio

recordings of court proceedings that depict Judge A. Quillian Baldwin, Jr.’s

violations of the Code of Judicial Conduct that the transcripts cannot

adequately depict. There is also a complete absence of recording in any manner

of the Order and oral commitments of Judge Baldwin during courtroom

proceedings on May 27, 2014 after Court was called to order and he arrived on

the bench.


2.6.7 The e-mail of Judge Baldwin to counsel for Michelle Murphy, seeking

legal protection for Nan Freeman and the other e-mails exchanged by persons

working in the chambers of Judge Baldwin are included as Attachment 1. The

statement in the e-mail by Judge Baldwin that Nan Freeman cannot afford

counsel is a false representation made by Judge Baldwin, as an advocate for

Nan Freeman. --- It is the integrity of our judicial system that cannot afford the

conduct of Nan Freeman.

Second Cause of Action [By Michelle Murphy for the Breach of Contract by Nan Freeman]

2.7 Nan Freeman, as described in information in this Amended Complaint and

other Causes of Action that are incorporated and made a part of this Second Cause

of Action, had a contract with Michelle Murphy to take down and thereafter

transcribe the entirety of each of the courtroom proceedings in the Superior Court

of Coweta County case of John Harold Murphy v. Nancy Michelle Murphy Civil

Action No 12V-413, excepting an August 13, 2013, court proceeding when

another reporter, Alice Moore, was assigned to the case for only that one hearing.

2.7.1 Judge Baldwin made the selection of the official court reporter with

whom Michelle Murphy was required to enter into a contract, if Michelle

Murphy desired that the courtroom proceedings be taken down.

2.7.2 Even though Michelle Murphy had very limited resources, she and her

counsel felt that it was necessary that the official court reporter, Nan Freeman,

be employed for each of the courtroom proceedings.

2.7.3 As the case continued, it became even more imperative that Michelle

Murphy have a contract with the official court reporter, as she and her counsel,

very unjustifiably, were being held in criminal contempt of court.


2.7.4 The Board of Court Reporting of the Judicial Council of Georgia and

the laws of the State of Georgia establish the methods that the official court

reporter may use to take down proceedings and the requirements for the

transcript, the fees that the court reporter is allowed to charge for the court

reporter’s service and the certificate that must accompany the transcript, that

also determines the nature of the content of the information contained in the

transcript.

2.7.5 Both Nan Freeman and Michelle Murphy were contractually bound by

the Rules and Regulations of the Board of Court Reporting.

2.7.6 Nan Freeman charged Michelle Murphy on each occasion that she

produced a transcript for Michelle Murphy. The charges of Nan Freeman to

Michelle Murphy were in violation of the Rules and Regulations of the Board

of Court Reporting, and, thereby, the contract that Nan Freeman had with

Michelle Murphy.

2.7.7 Michelle Murphy was damaged financially and otherwise on each of

the occasions that Nan Freeman was the official court reporter for a proceeding

involving Michelle Murphy, and, at other times, by the conduct of Nan

Freeman before or after courtroom proceedings.

2.7.8 The conduct of Nan Freeman in breaching the contractual relationship

that she had with Michelle Murphy was conduct that was reckless and in

wanton disregard of consequences that evinced an intention to inflict injury

upon Michelle Murphy and her counsel that affected the representation that

Michelle Murphy received.

2.7.9 Nan Freeman breached the contractual relationship that she had with

every litigant who contracted with her in cases in which Nan Freeman acted as


the official court reporter during the entirety of the time that she was an Official

Court Reporter in the Coweta Judicial Circuit.

2.7.10 Nan Freeman’s conduct in breaching contracts affected the lives of

persons for a long number of years.

2.7.11 While Nan Freeman has offered a portion of the money that she

illegally took from Michelle Murphy, she has not shown remorse to Michelle

Murphy and her children or to the others from whom she has illegally taken

money.

2.7.12 Michelle Murphy seeks an accounting from Nan Freeman for the

amount of money that this reporter has taken from each litigant and

governmental entity in the Coweta Judicial Circuit on each occasion that other

persons obtained a transcripts from Nan Freeman. transcripts that were

produced while acting as an official court reporter.

Third Cause of Action.

[By Michelle Murphy against Nan Freeman for Conversion and Unjust Enrichment] 2.8 Nan Freeman, as described in information in this Amended Complaint and

other Causes of Action that are incorporated and made a part of this Third Cause

of Action, without consent or permission, illegally converted an unknown amount

of funds obtained through a process of law from Michelle Murphy and converted

these funds to her personal use and thereby Nan Freeman also became

unjustly enriched.

2.8.1 Nan Freeman secreted the amount of funds that she illegally took from

Michelle Murphy and other persons and entities until she was caught engaging

in this illegal conduct by counsel for Michelle Murphy. Michelle Murphy v. Nan Freeman Amended Complaint Page 52 of 55

2.8.2 Michelle Murphy is entitled to an accounting and for recovery of these

funds that were illegally taken from her.

2.8.3 The conduct of Nan Freeman in converting funds that Michelle Murphy

was illegally required to pay to Nan Freeman was in such reckless and wanton

disregard of consequences that evinced an intention to inflict injury upon

Michelle Murphy and her counsel that affected the representation that Michelle

Murphy received.

Fourth Cause of Action

[By Michelle Murphy for the negligence of Nan Freeman]

2.9 Nan Freeman, as described in information in this Amended Complaint and

other Causes of Action that are incorporated and made a part of this Fourth Cause

of Action maintains that she negligently took money belonging to Michelle

Murphy and retained the money.

2.9.1 Michelle Murphy seeks recovery for the portion of the money that the jury

determines was negligently taken from Michelle Murphy.

2.9.2 The conduct of Nan Freeman that the jury determines to be attributed

to negligence was taken in such reckless and wanton disregard of consequences

that evinced an intention to inflict injury upon Michelle Murphy and her

counsel that affected the representation that Michelle Murphy received.

Fifth Pled Right of Recovery from Nan Freeman 2.10 Michelle Murphy is entitled to be awarded punitive damages against Nan

Freeman as provided by OCGA §51-12-5.1, as her actions showed that she acted

with the entire want of care, which would raise the presumption of conscious

indifference to consequences. Michelle Murphy v. Nan Freeman Amended Complaint Page 53 of 55

Millard Farmer

Prom: Julia Harris [email protected]> on behalf of Quillian Baldwin<[email protected]>

Sent Thursday, June 191 2014 11:26AMTo: [email protected]: Robertson, Beth; [email protected]; Taylor Drake ([email protected]};

[email protected] Murphy y. Murphy 12-V-413; Coweta County Superior Court

Dear Millard:

Nan Freeman has discussed with me your latest emails back and forth and she is deeplyconcerned about having to deal with a law suit which she cannot afford.

I have told her since this has become so stressful for her, that we should turn over a copy ofher audio recording of the hearing you are concerned with. As far as I can tell, you are notlegally entitled to the audio recording. However, Nan is willing to turn a copy over of suchrecording by placing a sealed copy in the Murphy case, File No. 12-V-41 3, in the Clerk ofCourt's Office along with an unsealed copy to be a part of the public record of which you oranyone else can review the audio recording at your pleasure.

i will file an order instructing the Clerk that the sealed recording shall not be opened exceptin open court but that you may review the unsealed recording wherever you would like inthe courthouse. This should satisfy your request. However, you, Mr. King1 anyone on yourstaff or employed by you, may not download or copy said recording in any way whatsoever.

By having the copies in the file, the unsealed copy will be available for use in an appeal orany other proceeding along with the original. Despite what Nan is willing to do, if you file alaw suit against Ms. Freeman, she will not voluntarily give you directly or file with the clerk'soffice, copies of said audio recording. Of course, you already have a copy of the transcriptas legally required by law.

We look forward to your immediate response.

Attachment 1, Page 1 of 1i

Attachment 2, Page 1 of 1

Documents

Murphy_Freeman_Court Reporting Fraud_First Amended Complaint w Atts