You can't change the "TRUTH"

 The box with this sign - is the unopened box that the Circuit Court of the City of Alexandria - Virginia Judges - used to send back evidence they stole out of Victims File -

Media - Afraid to Report on Virginia Judicial Corruption -

Media afraid to report on Virginia's Judicial Corruption

The Media has admitted to being afraid to investigate the criminal Actions of the Old Boy Network, the Judicial and Elected official in Virginia  - What happened to Nancy Dunning et al could happen to them or someone close to them – So instead they have allowed for it to go unreported the Obstruction of Justice, the Tampering with evidence, the Ex-Parte communications, the lying in court, the lying in court documents and the lying in court documents to the Supreme Court of Virginia – Supreme Court Justice Cynthia Kinser will instead of being held responsible will be allowed to retire early with full benefits for the rest of her life with no regard to her responsibilities to the Citizens of Virignia -

 

 

IN THE SUPREME COURT OF VIRGINIA RECORD NO: ____110156 & 122204ADDITIONAL INFORMATION IN SUPPORT OF: MOTION TO RE-OPEN DUE TO FRAUD ON THE COURT BY THE SUPREME COURT OF VIRGINIA FOR RULING AGAINST THEIR OWN LAWS AND ALLOWING LAWYERS TO BE DISENGENOUS IN COURT IN CIRCUIT COURT FILINGS AND SUPREME COURT FILINGS FROM THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA VIRGINIA CASE # CH010654

IN THE SUPREME COURT OF VIRGINIA

RECORD NO:  ____110156 & 122204_______________

COMMONWEALTH OF VIRGINIA,

Janice Wolk Grenadier

                                    Appellant / Plaintiff

v.

ILONA ELY FREEDMAN GRENADIER HECKMAN Esq

And

GRENADIER INVESTMENT CO, LTD,

And

DAVID MARK GRENADIER

                                           Appellees / Defendants,

ADDITIONAL INFORMATION IN SUPPORT OF:

MOTION TO RE-OPEN DUE TO FRAUD ON THE COURT BY THE SUPREME COURT OF VIRGINIA

FOR RULING AGAINST THEIR  OWN LAWS AND ALLOWING LAWYERS TO BE DISENGENOUS IN COURT IN CIRCUIT COURT FILINGS AND SUPREME COURT FILINGS

  FROM THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA VIRGINIA  

CASE #  CH010654

Janice Wolk Grenadier    (JWG)                                                                                                                                      15 West Spring Street                                                                                                                                             Alexandria, VA 22301

jwgrenadier@gmail.com                                                                                                                                         202-368-7178                                                                                                                                                                  pro se

Ilona Ely  Grenadier Heckman, Esquire (IEG)                                                                                                            Grenadier Heckman Starace Duffett                                                                                                                                   649 South Washington Street                                                                                                                      Alexandria, Va 22314                                                                                                                                             703-683-9000                                                                                                                                                Counsel for / pro se - Appellee  - Ilona Ely Grenadier Heckman & Grenadier Investment Co. LTD till approximately May 28, 2010

Benard J. Dimuro, Esquire    (VSB # 18784)  bdimuro@dimuro.com                                                                                                                          Hillary J. Collyer, Esquire    (VSB # 50952) hcollyer@dimuro.com                                                                                                                                John M. Tran, Esquire    (VSB # 24349)     jtran@dimuro.com                                                                                                         DiMuroGinsburg                                                                                                                                               1101 King Street, Suite 600                                                                                                                Alexandria, VA 22314                                                                                                                                     703-684-4333                                                                                                                                              Counsel for - Appellee  - Ilona Ely Grenadier Heckman & Grenadier Investment Co. LTD from approximately May 28, 2010

Michael J. Wiser, Esquire ( VSB #17630)  mjwesq@erols.com                                                                                                                               510 King Street,  Suite 416                                                                                                                       Alexandria, VA  22314                                                                                                                                      703-836-7003                                                                                                                                               Counsel for – Appellee – David Mark Grenadier

COMES NOW IN SUPPORT OF Motion to re-open cases due to Fraud on the Court by the Supreme Court of Virginia Appellant points out certain facts that Supreme Court has and has had but, should have at hand when reviewing  Motion for Fraud on the Court:

September 5, 2007   - Filed with the Alexandria Circuit Court a Motion for Reinstatement of the Bill of Complaint of 28 E Bellefonte Ave Partnership. The notification to the parties to be served through the Sheriff’s office.  The court date for the Motion was on September 12, 2007. 

 September 12, 2007  -  Motions Day Judge Kloch hears the case.  This resulted in the Filing of the Motion for Default filed on September 21, 2007.  As the Motion for Default goes into more detail Mrs. Grenadier was disingenuous in court claiming she hadn’t been served.  But, she couldn’t have known of the court date unless she was served.  She admitted in court to Judge Kloch that David Grenadier’s attorney Mr. Michael Weiser was aware of the court date because she had faxed the information to him.    Judge Kloch kept passing it over to give Mr. Weiser the chance to show up.  He then sent a clerk down to the Sheriff’s office who then came back and according to Judge Kloch  said that  Ms. Ilona Grenadier nor Mr. Weiser had been served according to their (the Sheriff’s) records.  I explained to the Judge the only way Mrs. Grenadier could be there was if she was served.  Mrs. Ilona Grenadier admitted to having the information and faxing it to Mr. Weiser.  At which point he dismissed everything to be re-heard.    Mrs. Grenadier a lawyer had not been telling the truth when she said she hadn’t been served

After Court Appellant  went down to the Sheriff’s office.  Appellant was given a copy of Mrs. Grenadier’s service.  Mr. Weiser’s papers were not in the box, and as his office is basically the same building they couldn’t say whether he had been served or not. 

 September 21, 2007  - JWG  filed for the Motion for Default, and The Motion to Reinstate (just in case) for October 10, 2007.   -  Motion for Default filed (written by federal Judge in DC) 

October 10, 2007 – All the Alexandria Judges have recused themselves from hearing it and they need to bring in an impartial Judge.  This is the start of shopping for Judges that would rule in favor of Appellees.  Even when Ilona would brag afterwards about her relationship with the Judge and how he had called her when he was practicing law and she would help him out

October 17, 2007 Letter from Diane Fiske – After informing Plaintiff that the Judges had recuse themselves she would be finding Judge’s to hear the case.  Judge Frank A. Hoss was available for November 28, 2007 at 10.00 am. At the time of this letter the Judges were:  

1.    Judge Donald M. Haddock – We learned in the Spring of 2008 he had recused himself from hearing the case.

2. Judge John E. Kloch – Ilona had lied to him in court on September 5, 2007 – He could have heard the Motion for Default as he knew the truth – Recused himself with letter of apology and Statement Appellant deserved a fair hearing and that “The appearance of Justice was just as important as Justice itself”

3. Judge Lisa Bondareff Kemler – Her Father was our pediatrician for Appellants girls, David had gone to Hebrew School with her, His father and her father weregood friends/Appellant  had shown her and her husband Real Estate.

November 15, 2007 – Letter from Diane Fiske that the Motions Date had been changed to Wednesday, December 5, 2007 @ 10.00 am  -  this had been filed on September 21, 2007 – Is now being heard on December 5, 2007.  Where most Motions are heard 7 days later this took 2.1/2 months to be heard.  By all appearance due to the need of shopping for a Judge.

The three (3) attached letters from Diane Fiske court administrator shows the City of Alexandria Circuit Court did not make a mistake.  The actions of the City of Alexandria Circuit Court  were knowingly and malicious to shop for Judges that would Rule in favor of attorney Ilona Grenadier Heckman.  That Judge Hoss from Prince William County had in 1990 recused himself from hearing any cases that involved Ilona Grenadier Heckman.  By all appearance he knew it was inappropriate for him to hear this case.  The Order on  page 4 in  the Motion to Re-Open due to the Fraud on the Court is signed by Judge Hoss of Prince William County.  That once Judge Hoss by all appearance recused himself a 2^nd time.  The Judge’s in the Circuit Court cannot say any longer a mistake was made.  The Judge’s in the Circuit Court of Alexandria knew exactly what they were doing.  That they knew of the Supreme Court rule Supreme Court Rule §17.1-105(B) and chose not to follow the rules of the Supreme Court of Virginia.  Attached find Letters:

Dated:  October 17, 2007,   November 15, 2007 That pertain to Judge Frank  Hoss who had recused himself back in 1990 and by all appearance recuses himself again. 

Dated: May 13, 2008 sent just a few days after Chief Judge Haddock explains to Appellant “You will never get a fair Trial “WE LOVE ILONA””    These letters expose the collusion of the Circuit Court Judges in the State of Virginia – FRAUD ON THE COURT – TREASON on the Court. This by all appearance shows the disingenuous behavior of the Supreme Court of Virginia in ignoring their own Rules and Laws to protect one of their own.

December 5, 2007  - Judge Thomas A. Fortkort.  Denied Appellants   Motion for Default.  It should be noted the Motion for Default was a suggestion & outlined by  a Federal Judge from DC. 

December 2007  -  Appellant Asked Diane Fiske Several times about a Fair Judge – she informs Appellant  the only way anyone else (Supreme Court chose’s Judge) Is if they can’t find one.  Which is incorrect – the rule is the complete opposite –

            in accordance with §17.1-105(B): Learn  of June of 2010
If all the judges of any court of record are so situated in respect to any case, civil or criminal, pending in their court as to render it improper, in their opinion, for them to preside at the trial, unless the cause or proceeding is removed, as provided by law, they shall enter the fact of record and the clerk of the court shall at once certify the same to the Chief Justice of the Supreme Court, who shall designate a judge of some other court of record or a retired judge of any such court to preside at the trial of such case.

February 8, 2008  ~  Appellant receives a Letter  From Ilona Grenadier (on her law firm stationary) to Janice Wolk Grenadier,  Ilona Grenadier asserts ownership of 75% of a property Known as 28 East Bellefonte Ave, Alexandria, VA 22305.  Plaintiff also felt threatened by the letter which is full of misleading and deceitful statements. 

February 13,2008 – Judge Brown hears Motions  * Ilona is not in court Heather Jenquien represented her.  Motions to compel ~

February 26, 2008 – Filed with Clerk of Courts following letter:  Because keep in mind all Judge’s had recuse themselves and all Motions had to go through Diane Fiske as she needed to shop for a  judge or it had to be on a day they had a visiting Judge.

The letter asks Ilona for dates to get back to Diane Fiske to file a Motion as no Motion’s could be filed without everyone’s ageing on the date before Diane found a Judge.

February 27, 2008  - Ilona Grenadier filed on February 27, 2008 with the Circuit Court of The City of Alexandria an Answer to The Amended Bill of Complaint claiming 75% ownership of the property at 28 East Bellefonte Ave., Alexandria, VA 22305 which is a documented lie. Most of Ilona Grenadiers statements in the Answer to The Amended Bill of Complaint were disingenuous which Plaintiff has supplied documentation to VSB for the purpose of establishing the truth.  The following are the lies Ilona Grenadier Filed with the Circuit Court of Alexandria

1.     75% ownership

2.    That plaintiff has provided no proof of actual payment for expenses ~ provided 3 times to defendants

3.    Plaintiff’s Bankruptcy caused by Bellefonte as Plaintiff in & out ~ Which now Plaintiff realizes she would never had been in and out if it wasn’t for the manipulation and lies of Ilona Grenadier

4.    4 times Ilona ~ “Defendant, Ilona Ely Grenadier, denies that Plaintiff owns or owned 50%of East Bellefonte.

The document on Februaary 27, 2008 by Ilona Ely Grenadier a lawyer was rattled with Lies ~  The VSB ~ The Judges in Alexandria and her good friend ~ Judge Brown had no problem with that.

  This can be backed up with information/documentation from Admission statements from Ilona Grenadier which had several conflicting statements.  The amount of money Ilona Grenadier put into the property can be established by an accounting done by Ilona Grenadier. The Accounting shows the 25% down payment that was contributed in the purchase of the Bellefonte Property.  The documents that were filed with the Motion for Default in the Circuit Court of Alexandria can be used to verify the amount of ownership Ilona Grenadier had.  Ilona Grenadier had in her possession the documents which showed her ownership at the time she filed the pleadings.  Those pleadings were disingenuous and misleading when filed with The Circuit Court of Alexandria.

March 5, 2008 – File 2^nd Motion for Default – to be heard March 12, 2008 for the following reasons:

1. For all the reasons as stated in Motion for Default Dated September 21, 2007

2. For all the untruths told in the Answer to Bill of Complaint by defendant and Counterclaim and Cross-Complaint filed on February 27, 2008.

3. For the letters Defendant sent bulling, threatening attached to the February Response to Ilona Ely Grenadier/GIC Motion to Quash Plaintiff’s Amended Complaint / From February 8, 2008.

4. For the non response to letters to try and set a new date for depositions or to set a trial date.

March 5, 2008 – Filed Motion to Change Date for:  Notice of Deposition and to Set Date for Trial – As Defendants would not respond to any correspondence.

March 11, 2008 – Plaintiff files – Praecipe ~ Remove Motions for March 12 no visiting Judges.

1. Clerk of the Court will please remove from the docket on March 12, 2008 Plaintiff Janice Wolk Grenadiers Motion to Compel as there isn’t a visiting judge available to hear it.

2. This again show’s that the Circuit Court Judge’s had recused themselves. That Plaintiff though out the case voiced her concern on getting a fair Trial.  To the deaf ears of the Circuit Court of Alexandria who took the Arrogant view of doing whatever they wanted to do.

April 30, 2008 – Parcipe re-file to have Motion for Default  heard as Diane Fiske has found a date that works for the Judge’s of Alexandria to find a Judge of there choice – for May 7, 2008

May 7, 2008 – Motions heard by Judge Brown – Ilona after court informs me after he has ruled in her favor allowing her to file false papers as an attorney in the Alexandria Circuit Court of law  What good friends she and Judge Brown are – and how he called her all the time for legal advice.

May 7, 2008 After Court ~

1.    Iloan Grenadier again brags about her relationship with the Judge’s - That she has in the past & continues to give Free legal advice to Judge Brown.

2.    Ilona Grenadier explains to me why no one has anything do to with my children is because I raised them Catholic.  In 19 years she has seen the girls once by her choice.

3.    That I should be grateful to her for the listing on Holland Road.

4.    That she doesn’t believe David Stold the money from Sonia Grenadier’s Trust - which only left Ilona Grenadier and her law firm to steal the most likely over $95,000.00

5.    I introduce myself to Judge Haddock after he speaks with Ilona – he explains to me “I could never get a fair trial as they all Love Ilona”  I turn to Diane Fiske shocked by the statement and express I can’t believe he just said that to me. 

6.    Again I ask Diane Fiske about getting Judge’s that aren’t friends of Ilona’s.

May 13, 2008 – Letter from Diane P Fiske that the case would be heard by Judge John J. McGrath.  This letter show’s the following Judge’s in the letter head:

1. Donald M. Haddock
2. John E. Kloch (Retired)  which means at the time Judge McGrath was chosen Judge Kloch and Judge McGrath were working together.
3. Lisa Bondareff Kemler

June 18, 2010 – Plaintiff Files:

1.  Motion for Default - Ilona has lied in the Admissions

A.   For Ilona lying in court to Judge Kloch on September 12, 2007 ~ Motion for Default

B.   For Motion for Default filed in February for Lying in the Answer to Bill of Complaint by defendant and Counter claim and Cross Complaint

C.   For lies in Admissions

D.   For the letters Defendant sent Bulling & Threatening Plaintiff if Plaintiff didn’t drop suit.

2. Motion for Trial by Jury – Due to comments made by Judge Haddock & Ilona Grenadier

A.   Judge Haddock telling Plaintiff she could never get a fair trial as they all “LOVE” Ilona

B.   Ilona informing Plaintiff all the Judges were friends of hers & she gave them free legal advice when they called her

July 2, 2008 – Motion to be heard July 9, 2008 to include:

1. Motion for Trial by Jury
2. Motion to Compel
3. Motion for Default

July 9, 2008 – Judge Howe Brown – rules :

1. Denies motion for Default
2. Denies motion for Trial by Jury
3. And makes both sides work on response’s in the Motion to Compel

Spring of 2008   Diane Fiske again advices Plaintiff  the only way anyone else would choose a Judge was if they couldn’t find one then it would go to the Supreme Court and they would then choose the Judge.  Which was incorrect.  The minute in September of 2007 when the Judge’s had recuse themselves is when the Supreme Court should have been choosing the Judge’s not the Judge’s themselves or Diane Fiske should have been choosing the Judge.  The Head Judge - Judge Haddock was talking and hugging Ilona while I was talking with Diane Fiske about Fair Judge’s that were arms length.  When Ilona left I turned to Judge Haddock and introduced myself which he then went onto inform me  “ I wouldn’t get a fair trial because they all  “Loved Ilona” “.  Judge Haddock is the Head Judge at the Alexandria Circuit Court.  I then turned to Diane Fiske – in shock – and said I can’t believe Judge Haddock just told me “I would never get a Fair Trial because they loved Ilona”.

September 11, 2008 – Thursday  “Kangaroo Court “ with Judge John McGrath  (Exhibit 11 - Judge McGrath)

September 22, 2008 – Monday  - File Motion for Reconsideration With new evidence that had been dropped off at Appellants house - A letter that David Ellsberg the Settlement attorney for Bellefonte had me write him that showed I was loaning the money to Ilona  / David / GIC

October 21, 2008 – Mailed from Alexandria Virginia a complaint against Judge John McGrath to his good friend Donald Curry w/ the JIRC Commission.

October 23, 2008 – Donald R Curry Counsel for JIRC  sends Appellant the following( after telling Appellant on the phone not to bother with a complaint :

“This is in response to your complaint dated October 21, 2008.  Based upon what you have submitted and alleged, we have found no basis for a conclusion that there has been a violation of the Canons.  A mere “belief” that an ex parte communication occurred, without more, does not provide a sufficient basis for Commission action.  Please be advised, moreover, that the judge about whom you complaint is a retired judge from the 26^th Circuit. “

October 27, 2008 - Fax to Randy Sengel with copy of Complaint and response to JIRC Commission.  How out rages it was.  – His suggestion was I address members directly.

November 12, 2008 – Reached out to each member of the Courts of Justice by Phone or Fax –

1. Judge Larry D. Willis
2. Honorable Virginia L. Cochran
3. James F. Fisher Esq
4. William I Fitzgerald
5. Judge Cleo E.  Powell
6. Olivia A. Welsh
7. Kenneth Motero  804-786-6634  - Boss to Donald Curry
8. Tim Kaine  - Governors’ office  804-786-2211
9. Bob McDonnel  - Attorney General  804-786-2071
10. Donald Curry – General Assembly
11. Department of Human Resources Mgt 804-225-2131

   Carol Supreme court -  HR

Virginia House of Delegates – Courts of Justice

1.   Dave Albo – Chair

 2.  Pamela Burham

Virginia Senate –

1. Henry L. Marsh III – Chair – Contact Comm operations (804) 698-7450

Delegate - Alexandria

1. David Englin – 804-698-1045   703-549-3203

Senator

1. Patsy Ticer  804-698-7530  703-549-5770  Spoke with detail to Peggy  Fax# 703-739-6761   - Gave me Mr Henry Marsh’s number - information

Congress

1. James Moran

November 12, 2008 – Fax to Henry Marsh – Jackie Parker copy of complaint

November 12, 2008 – Fax to Dave Albo after horrid conversation.  J

November 12, 2008 – Fax Donald Curry adding letter date May 8, 2008 that Ilona had written to me, that Judge McGrath had used in making his decision on this little meeting prior to court.  Which in 45 minutes he would never had found in a file that was about 8 – 10 inches in paper work.

November 13, 2008 –Letter from Donald Curry that the letter I had sent didn’t change his mind that there should be an inquiry into Judge John McGrath.

November 13, 2008 – letter from Henry L. Marsh lll  - He referred me to The Chief Justice of the Virginia Supreme Court as he was in charge of Substitute Judges. – Chief Justice Leroy Rountree Hassell, Sr.  100 North Ninth street, Richmond, Va 23219.

December 8, 2008  - Fax info to Donald Curry he is of no help

December 8, 2008 – Calls to Chief Justice Leroy Rountree Hassell Sr. requesting a meeting – spoke with Chief Deputy clerk – Leslie David to put complaint in writing.

December 10, 2008 – Letter from Donald Curry they are not looking at my complaint

December 18, 2008 – Reach out to John McGrath to get him to do the right thing – no word back From the letter – Pleading with him to do the right thing and reconsider the Motion for Reconsideration or at least be respectful and look at the new evidence.  Sent him several e-mails giving him more evidence and do to the right thing.

December 18, 2008 – I learn from the internet that Judge John Kloch is now working with Judge john McGrath Jr. with a firm called Judicial Solutions’ PC *In Letter from Judge John Kloch –Which even makes this more of a conflict of interest.  Not an arms length situation.  If it isn’t enough to have the Commonwealth’s Attorney tell you Judge John McGrath has done a lot of work in the Alexandria Courts.

July 28,2008   1^st Complaint  ~ Virginia Bar Complaint  Outline / Ilona Ely Freedman Grenadier Heckman   VSB Docket # 09-NAT-076104

1. That Ilona lied in court on September 12, 2007  All facts can be found in the Motion for Default Dated September 21, 2009  Which a copy was sent in with the complaint
2. Letter from Mrs. Grenadier suggesting I had better drop the suit Dated February 8, 2008
3. Ilona presented false statements in her Counter Claim and Cross Complaint  which can be proven through her own documentation.  These false statements were filed and are in Court Record. 

 August 4, 2008  Appellant  received a letter from Mr. James C. Bodie saying they would not be taking action against Ilona.  Appellant then did pursue it and asked them to review it again after sending in more information.  I was also turned down on the review.  I was basically told because Ilona wished for a different outcome her behavior was acceptable to the Virginia Bar.

September 11, 2008 – Court Date

A.   Conference in Judges Chambers – Only Ilona & Janice didn’t include David

B.   Judge Kloch hanging outside the door

C.   Sonia Grenadier Trust – brought up in opening By Ilona & David and I was questioned about it by Ilona

D.   Judge McGrath – Won’t let me bring up Sonia Grenadier Trust & Doesn’t understand it – won’t take time to understand

E.   Judge – Warns me on how I question Ilona

F.    David Grenadier lies under oath – move on per Judge

G.   Judge McGrath & Judge Kloch had a very friendly Lunch at Jackson 20

7.    September 2008 – File Reconsideration with new evidence that had been dropped off at my house.

8.    September 24, 2008  - Diane hears back from Judge McGrath – doesn’t want to see new evidence or any Exhibits  – Faxed to him – never seeing Exhibits immediately Denies

9.    Randy Sengel – Commonwealth’s Attorney – Informs me that Judge McGrath has done a lot of work in Alexandria Circuit Court

10. JIRC  Commission – Donald Curry good friend to Judge McGrath was raised in Arlington

11. Alexandria Circuit Court – Yes McGrath is from Harrisonburg – But, has several ties to Alexandria & is working w/ Judge Kloch – guess they just didn’t think that was important

12. File complaints w/JIRK Commission of course I didn’t have all the information and Donald Curry who make’s decision is friends w/ everyone

April 29, 2009 ~ Virginia Bar Complaint #2 

With the first Complaint  Ilona had broken the Ethics rule on Knowingly Filing false information with the courts, making false statements in Court, recording documents along with Admissions statements that were disingenuous, and lying in Court.  She now had broken the Ethics Rule 1.16 (d) and (e) by refusing to give me the NOTE that she as my lawyer had written and had insisted on being the only one to hold on to it.

I attached much evidence on this complaint of Ilona being very disingenuous. With all her statements she made and how she mislead all the other attorneys with the truth of the amount of funds that were stolen from the Sonia Grenadier Trust.  I have also shown how she personally financially benefited from all of these actions, my millions of dollars in Real Estate.

*** These complaints by my understanding from Mr. Edward L. Davis have been combined and looked at together.

***Appellant feels  from his letter he doesn’t even understand the complaints nor is he looking at the evidence that has been provided to show that Ilona is lying.

*** An attorney who teaches Ethics for the VSB helped Appellant to write complaint

July 2009 _ Letter Chief Justice Supreme Court of Virginia

June 21, 2010  -  Letter to Patricia L. Harrington – Supreme Court Clerk

August 2010  Virginia Attorney – Calls Diane Fiske – she confirms all the Judge’s in The Alexandria Circuit Court had recuse themselves

July 2010 Janice Confirms the Rule with the Supreme Court

July 12, 2010  e-mail to Defendants that Plaintiff was filing Motion for Default to be heard on September 21, 2010 – to be heard on July 28, 2010

July 13, 2010 – File Motion

July 26, 2010 w/ 4 min left Michael Wieser files he can’t be there – in collusion with Judge’s by all appearance and ex-parte communications

July 20, 2010 – Ilona files Opposition – weren’t we supposed to be in court on the 28^th ? when she knew

August 4, 2010 – After being reprimanded by the Circuit Court about contacting everyone – being treated rudely now every time I call by the Alexandria Circuit Court – file Motion to be heard on August 11, 2010

August 11, 2010  – Judge Kloch – visiting Judge

August 11, 2010 – Plaintiff is informed my The Circuit Court they will not take her phone calls or any messages from her

August 12, 2010 – Plaintiff receives an e-mail - Judge Kloch – Decides to recluse himself – works with Judge McGrath

1. Quote from Judge Kloch’s letter “I believe strongly that the appearance of justice is equally important as justice itself”  How disingenuous Judge Kloch can be

January 20, 2011 - JWG Appeal to Supreme Court ~ Record # 110156

May 24, 2011 ~ Supreme Court Oral Argument by Janice Wolk Grenadier pro-se JWG Oral Argument

January

20           JWG                 Supreme Court Appeal Filed

February

2         IEG      Letter Ben Dimuro   Give notice file dismiss of Petition for Appeal

3           IEG     Respondents Joint Motion to Dismiss Petition for Appeal

8          JWG     Petitioner’s Response to Respondents Joint Motion to Dismiss Petition

                          For Appeal

10        IEG      Joint Brief in Opposition to Petition for Appeal

May

4     Supreme Court of Va     Letter to JWG  May 24, 2011 Oral Argument

24                JWG     Oral Argument in Richmond

 June

  20?            Supreme Court            Deny Petition – Ruling against their own Law

    27    JWG      Petition for Rehearing

September  2011

20?    Supreme Court     Deny Petition for Rehearing                                

21         JWG  Letters to   Brown - McGrath - Fortkort - Dawkins - Haddock -

                     That Appellant  planed on suing them

27    JWG   Letter Sengel & Haddock  for Grand Jury

29    Sengel  Letter to JWG  no  Grand Jury

October  2011

             JWG  Files Precipe to be heard in front of Regular Grand Jury Oct 11, 2011

5   Commonwealth Attorney Randy Sengel   Letter to JWG no not going to let me in front of Regular Grand Jury

6      JWG      letter to Sengel

6       JWG    letter to Ed Semonian – Clerk of Court of the City of Alexandria

7       Sengel   e-mail receipt of letter and sent Ed Semonian his letter

11    Refused Grand Jury

14   JWG       Letter to Judge Haddock

14   Sengel      Letter Judge Haddock retires end of December 31, 2011

20   JWG   files in the Eastern District Court of Virginia

                   Complaint-Conspiracy to interfere with the Civil Rights 18 USC 241 & 42 USC 1983 Illegal Actions to Deny Access to Grand Jury.  Trial by Jury.  & More Emergency Motion for injunctive Relief

31   JWG  Letter to Judge Lee

November 2011

9   Fed Court     Order Deny Request for in forma Pauperis due to claim is Frivolous

16  Letter from the Circuit Court of Alexandria  that the Supreme Court had conflicts with the date of December 12, 2011 due to schedule conflicts.

21   Supreme Court Letter   Judge Potter to sit on Grand Jury of February 13, 2011

21 Order from the Supreme Court for Judge Potter to assist Alexandria Circuit Court

23    JWG     Files with Fed Court

                     Petition for Reconsideration of the “ Frivolous” Order of 9 November 2011 Complaint~Conspiracy to Interfere with the Civil Rights 18 USC 241 & 42 ISC 1983 Illegal Actions to Deny Access to Grand Jury Trial By Jury

**  Janice -  Learns about the Majesty can also bring charges -  Calls City of Alexandria Majesty to learn that he requires a Police Report -  Janice then calls Detective Pak to ask for Police Report #

Janice Calls Records in Alexandria to learn -  There is no Police Report # for the Extortion investigation brought on by Randy Sengel commonwealth’s attorney which there is a letter from Ben DiMuro April 16, 2009 charging Appellent with acts of Extortion.  Appellant now knows of the Collusion between Randy Sengel - Ben DiMuro to stop Appellant.

December

20  Ms. Slaughter Federal Judge Bruce Lee’s Secretary lies to Appellant

21  File Motion to be heard in Federal Court January 6, 2012  - denied as Judge Lee is out of town?

22   File in the Supreme Court of Virginia  - Petition for Writ of Error Coram Vobis ~ Alexandria Court Illegal Actions to Deny Citizen Right to Trial by Jury and Grand Jury

January   2012

4  Letter Randy Sengel Commonwealth Attorney to Judge Potter informing him to refuse JW in front of the Grand Jury as Appellant is not one of his witness’s

JW contacts Supreme Court regarding letter and informed anyone can wright to a Judge from a

4   Letter from Meghan S. Roberts threatening me with legal action over $200. For infractions of code a gutter & RV parked in my driveway.  Collusion with Randy Sengel in attempt to  Scare JW.

7   Letter JW to Meghan S.Roberts no intention of paying and reason why

18  Motion for sanctions against Randy Sengel commonwealth attorney for letter to Judge Potter

18 Pracipe to be heard on January 25, 2012

20 Letter from Law Clerk Circuit Court of Alexandria that my Motion for Sanctions against Mr. Sengel would be heard by Judge Potter

February 2012

1     Motion filed to demand Ed Semonian Clerk of Court answer simple questions about Grand Jury -  Since Alexandria has shown in the past not to follow the rules of the courts It was reasonable for JW to ask basic questions which he refused to answer.  Most likely he doesn’t know the basic rule

2     Parecipe filed on Feb 1 for Motion to be heard on February 8, 2012 by the new Judge - Judge Clark who had not recused himself from hearing this case.

2  Letter Circuit Court of Alexandria  Motion Sanctions against Ed Semonian to be heard at 9am  February 13, 2012

13   The kidnapping of JWG in court room 4 from the Grand Jury Final Order by Judge  Richard Potter -  Denied in front of the Grand Jury he and Randy Sengel Commonwealth Attorney are now the Gate Keepers of the Grand Jury

The Circuit Court of Alexandria after leading Appellant on since October 11, 2012 wasted Appellants  time and others with a Micky Mouse / Kangaroo type hearing on February 13, 2011 - 

CONCLUSION

Judge Potter should never have been chosen by the Supreme Court of Virginia.  The actions of the Supreme Court are very clear. That the Treason on the Courts by the Supreme Court of Virginia, Judge’s and the Judge’s they supervise were willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless against Appellant.  That Appellant has demonstrated through all her filings that Appellant understands Justice and has every intention of being treated as an equal.  Appellant complains against all:

That the State of Virginia should be held responsible for the actions of the collusion of the roles the following agencies of the State were in collusion to prevent Plaintiff’s Constitutional right to Due Process – City of Alexandria, Circuit Court Judges, Commonwealth Attorney, State Police, The Legislature of Virginia, City of Alexandria Police, VSB, JIRC all Supreme Court Justices and Chief Justice The Honorable Cynthia D. Kinser Appellant learned from Loretta Miller et al of her being Jewish and by all appearance from the blog that she also was in collusion because of Plaintiff / Appellant being Catholic.  This was new evidence to Plaintiff/ Appellant.  Circuit Court Hon. Lisa Bondareff Kemler, Presiding Judge, Chief Judge Plaintiff/ Appellant has been aware all along this defendant was Jewish.  That her last signed Order was irrational and Treason on the Court.  With a very heavy heart Plaintiff/ Appellant has  to look at the facts and realize part of  the motivation is because  Appellant is Catholic. Her actions in October of 2012 returning documents that had been filed in Court, to prevent the Truth and the accounting of what Ilona Grenadier Heckman was responsible to Plaintiff / Appellant was Treason on the Court. All actions will show to have been willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless.   The State of Virginia Attorney’s General along was aware of these actions and refused to give the state police the power to investigate. That when Attorney fees are awarded to attorneys with more billable hours to Judge’s Chambers then to their clients and such bills were found acceptable to the Supreme Court of Virginia. The State of Virginia’s  Treason on the Courts by Judges, attorneys and their representatives will show to have been willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless. Justice is supposed to be blind. In Bullock v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated "Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury. ... It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function --- thus where the impartial functions of the court have been directly corrupted." But not only are trial judges required to be fair and impartial, they must also 'satisfy’ the appearance of justice and this includes the Supreme Court of Virgina.  The trial judge's 'appearance,' or conduct and behavior, appearance of bias alone is grounds for reversal even if the trial judge is, in fact, completely impartial.

The slippery slope that would open up the truth of how Plaintiff  since October of 1985 had been manipulate and that the actions were and are still willful acts that are malicious, violent, oppressive, fraudulent, wanton, or grossly reckless. The Law is very clear that the Judges who have acted by ruling in Favoritism and Cronyism and not by the Rules of the Supreme Court.  “Any judge who does not comply with his oath to the Constitution of the United States, wars against that Constitution and engages in violation of the Supreme Law of the Land. If a judge does not fully comply with the Constitution, then his orders are void, In re Sawyer, 124 U.S. 200 (1888), he is without jurisdiction, and he/she has engaged in an act or acts of treason.”  “U.S. v. Will, 449 U.S. 200, 216, 101 S. Ct. 471, 66 Ed.2d 392, 406 (1980); Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5 L.Ed 257 (1821)”

Plaintiff is aware of and understands the difficulties for any Judge in this case.  But, the law has been abused and broken by the State of Virginia’s judicial system and Plaintiff will be able to show this is not a unique situation but, normal practice in the State of Virginia.  The difference is they have not been able to kill Plaintiff  or break Plaintiff, and Plaintiff prays this court look at the evidence in documents and gives Plaintiff the right to be heard.  “No man in this country is so high that he is above the law. No officer of the law may set that law at defiance with impunity. All the officers of the government from the highest to the lowest, are creatures of the law, and are bound to obey it.” Butz v. Economou, 98 S.Ct. 2894 (1978); United States v. Lee, 106 U.S. at 220, 1 S.Ct. at 261 (1882)”  “Further it is the obligation of every Judge to honor, abide by, and uphold not only the Constitution and laws of the State, but they are bound by the laws and Constitution of the United States as well.”  “State courts, like federal courts, have a constitutional obligation to safeguard personal liberties and to uphold federal law.” Stone v Powell, 428 US 465, 483 n 35, 96 S. Ct 3037, 49 L Ed. 2d 1067 (1976)”  “Whenever any officer of the court commits fraud during a proceeding in the court, he/she is engaged in “fraud upon the court”. In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985),

The Constitution of the United States A fundamental, guarantee that all legal proceedings will be fair and that one will be given notice of the proceedings and an opportunity to be heard before the government acts to take away one's life, liberty, or property. Also, a constitutional guarantee that a law shall not be unreasonable, Arbitrary, or capricious.

The constitutional guarantee of due process of law, found in the Fifth and Fourteenth Amendments to the U.S. Constitution, prohibits all levels of government from arbitrarily or unfairly depriving individuals of their basic constitutional rights to life, liberty, and property. The Due Process Clause  of the Fifth Amendment ratified in 1791, asserts that no person shall "be deprived of life, liberty, or property, without due process of law." This amendment restricts the powers of the federal government and applies only to actions by it. The Due Process Clause of the Fourteenth Amendment, ratified in 1868, declares,"[N]or shall any State deprive any person of life, liberty, or property, without due process of law" (§ 1). This clause limits the powers of the states, rather than those of the federal government.

Plaintiff can show harm and the harm that has forever been done to her from the actions of the above Defendants.  Plaintiff may not have put all information in the best order – but, has done the best she can do.  She has done it with a pure heart and honest way and still has not had her day in court to be heard.  Plaintiff has still had not had due process  Boddie v. Connecticut, 401 U.S. 371 (1971), was a case before the United States Supreme Court  giving the right to due process and to be heard.  Appellant files the following Claims with the right to add additional:

Claim 1

Breach of Contract – Implied Covenant of Good Faith and Fair Dealing – Breach of Contractual Duty of Good Faith and Fair Dealing 

By virtue of the facts stated above, defendants have violated their contractual duty of good faith and fair dealing. Plaintiff has paid fees to these courts and not received Due Process.

1.    The above defendants and defendant’s representatives breached their contractual duty of good faith and fair dealing when Judges ruled in Favoritism and Cronyism.  When Judge’s did not have Jurisdiction and chose friends/other Judges who would not follow the rules but would rules as told.

2.     That the above defendants and State Breach of Contract includes not limited to their involvement  being disingenuous in documents filed with the courts and Orders. The documents will speak for themselves the defendants were aware of these breaches as lawyers and Judges.

3.    Plaintiff through implied covenant of good faith and Fair Dealing continued to follow the Rules of the Courts.

4.    The defendant’s “flagrantly violated” their Fiduciary responsibility to the Judicial System and  Plaintiff to deal in Good Faith while Plaintiff continued to deal in Good Faith. The actions will be proven factually by Orders, Letters, Documents filed in the court and other. That the constitutional Right of Due Process has been denied time and time again.

Claim  2

Violation Title 42 § 1983 Civil Rights Statue

Civil Rights Act of 1968 enacted 18 USC 245

Defendants used unfair/unconscionable means to try and intimitad and scare Plaintiff – They have acted as the Klue Klux Klan would have in the past. Plaintiff is aware that Plaintiff must show that Plaintiff can prove each element of alleged facts in her claims. That to seek relief for the violation of a person’s Federal and Constitution rights under Title 42 § 1983 it allows Plaintiff to her rights contained in the United States Constitution as defined by Federal Law.

Plaintiff has been discriminated against for being Catholic That Civil Rights Act of 1968 enacted 18 USC 245 prevents discrimination due to Religion  That this is a Hate Crime and “Hate crime laws are colorblind”  Fact the case which the Supreme Court upheld hate crimes of the First amendment attach, Wisconsin v. Mitchell, 508 U.S. 476(1993) involved a white victim. 

Plaintiff  has been discriminated against for being black balled by the Old Boy’s Network / Judicial Community due to her x-husband being the son of the late  Judge Albert Grenadier whom was the Husband to Defendant Ilona a lawyer who has also intervened into Defendants Divorce. That the discrimination and segregation among white exist the power Hierarchy by a member of one that is considered by others  inferior to the other.

Claim  3

Consumer Protection Act

 The State of Virginia was paid for serves in the Court that were denied Plaintiff because she was Catholic.  That the discrimination and segregation among white exist the power Hierarchy by a member of one that is considered by others  inferior to the other.

                                                             Claim 4

Breach of Fiduciary Duty

Unjust Enrichment/Constructive Trust

That the State of Virginia had a Fiduciary Duty to insure the rights and safety of Plaintiff in the and through the Court system. Plaintiff has been harmed by the false statements which are considered defamatory – that Plaintiff has “ THE TRUTH”  which is an absolute defense .  That the First Amendment of the U.S. Constitution was designed to protect Freedom of the press.  The 1964 case New York Times Co. v. Sullivan radically changed the nature of libel law by establishing a suit for libel you needed to prove that the information was wholly and patently false or that it was published “with reckless disregard of whether it was false or not”

. “Fairness of course requires an absence of actual bias in the trial of cases. But our system of law has always endeavored to prevent even the probability of unfairness. “In re Murchinson, 349 U.S. 133, 136 (1955)” Loving v. Virginia, 388 U.S. 1 (1967)  was a landmark civil rights decision of the United States Supreme Court  against discrimination. Which includes being discriminated because the Judge’s, lawyers, elected officials and government employees have decided you are not a part of or one of them. 

Claim  5

                                        Common Law Fraud12 U.S.C 1972

.On several occasions Plaintiff  asked the courts to review and asked for a Special Grand Jury to look into the allocations of misconduct.  Plaintiff was to go in front of the Grand Jury with her witness’s – But, instead was kidnapped in a different Court Room and Grand Jury was dismissed prior to her being allowed into ask for the Special Grand Jury..

Claim  6

Negligence – the negligent infliction of emotional distress; the intentional infliction of emotional distress

The defendant’s had a legal duty to use reasonable care in statements posted on the internet about Plaintiff.  They did not do this.  They have posted several lies about Plaintiff and others.  They have done ruined Plaintiff reputation and should be held financially and legally responsible for their actions.

The defendant’s malicious actions caused great emotional distress to Plaintiff.  By the Commonwealth Attorneys orders of the City of Alexandria police to never take a complaint from Plaintiff?  Plaintiff has been harmed by the false statements which are considered defamatory – that Plaintiff has “ THE TRUTH”  which is an absolute defense .  That the First Amendment of the U.S. Constitution was designed to protect Freedom of the press.  The 1964 case New York Times Co. v. Sullivan radically changed the nature of libel law by establishing a suit for libel you needed to prove that the information was wholly and patently false or that it was published “with reckless disregard of whether it was false or not”.  Plaintiff has been put into an unfair and dangerous position to protect herself and her girls.

 The actions of the actors to cause this emotional distress were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

Claim 7

Constructive Fraud

The defendants were deceptive of material misrepresentations of past and existing facts and remained silent when a duty to speak existed.

The defendant’s actions were Arbitrary and Capricious absence of a rational connection between the facts found and the choice’s made, made choices that were not in accordance with the law.

Claim 8

                                                            Civil Conspiracy

The Collusion of the Defendants actions show collusion to harm Plaintiff from and was done with malicious, violent, oppressive, fraudulent, wanton, or grossly reckless intentions.

Defendants Civil Conspiracy to Commit Tortious Interference with Contractual Relations abuse of process, intentional infliction of emotional distress,

Civil conspiracy to commit injurious falsehood with jwgrenadierisalair.blogspot.com that Plaintiff has a “protected characteristic” which will be proven  as to why Plaintiff was sought out by Defendant and that factor is why Plaintiff was targeted by Defendants

Defendants were in collusion of civil conspiracy to intentionally inflict emotional distress.      

Claim 9

The Four Basic Freedoms Guaranteed by the Bill of Rights

Plaintiff will prove a violation of Plaintiffs  Bill of Rights  the  Four Basic freedoms are

being Violated  -

                                          The Four Freedoms

                                     1.  Freedom of speech

                                               2.  Freedom of worship

                                     3.  Freedom from want

                                               4.  Freedom from fear

Plaintiff will show the actions of the Defendants were actions that were willful acts were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless  That the defendants were acting under the color of State and Federal law. That the Constitutional Rights of due process are factual allegations that will be proven through documents, letters, e-mails and actions of defendants.   That defends had been given notice, and this court is aware of with the threat from Defendant Ilona’s attorney. 

This court should move swiftly and that a Grand Jury should be instructed to have a Special Grand Jury look into the Criminal Actions of all involved.  That Sanctions and the demand to make Appellant whole financially for all her lose and because these actions were and still are willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless.  Appellant should be awarded appropriate damages for the actions of all involved and the claims for laws ignored and maliciously not followed .

Respectfully Submitted,

                                                          Janice Wolk Grenadier

                                                                    Pro se Appellant

                                                                    15 West Spring Street

    Alexandria, Virginia 22301

                                                                    202-368-7178

                                                                    jwgrenadier@gmail.com

CERTIFICATE of SERVICE

Pursuant to Rule 5:17, I hereby certify that

The appellant is Janice Wolk Grenadeir pro se

The appellee is Ilona Ely Freedman Grenadier Heckman, Esquire & Grenadier Investment Co Ltd was represented by Grenadier, Anderson, Starace & Duffett till around May of  2010 the following counsel started representing Ilona Ely Freedman Grenadier Heckman, Esq and Grenadier Investment Co Ltd

Dimuro Ginsburg PC

John Tran Esquire

Benard J.  Dimuro, Esquire

908 King Street  Suite 200

Alexandria, Virginia, 22314

703-684-4333

The appellee is David Mark Grenadier represented by:

Michael J. Weiser, Esquire

510 King Street Suite 416

Alexandria, Virginia 22314

A copy of this Motion was mailed to the Clerk of the Supreme Court of Virginia on April 30, 2014 e-mailed and mailed to counsel for Appellees.

.

This 30th day of April  2014

Janice Wolk Grenadier

As John F Kennedy said “The cost of freedom is always high, but Americans have always paid it.  And one path we shall never choose, and that is the path of surrender, or submission” and “There are risks and costs to action.  But, they are far less than the long range risks of comfortable inaction”