Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
(VSB # 18784)
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 Sheriffs 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 hadnt
been served. But, she couldnt have known of the court date unless she was served.
She admitted in court to Judge Kloch that David Grenadiers 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 Sheriffs 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 Sheriffs) 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 hadnt
been served
After Court Appellant went down to the Sheriffs office. Appellant was given a copy of
Mrs. Grenadiers service. Mr. Weisers papers were not in the box, and as his office is
basically the same building they couldnt 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 Judges 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
Judges in the Circuit Court cannot say any longer a mistake was made.
The Judges 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 choses
Judge) Is if they cant 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 Judges 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 Motions
could be filed without everyones 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. Plaintiffs Bankruptcy caused by Bellefonte as Plaintiff in & out ~ Which now
Plaintiff realizes she would never had been in and out if it wasnt 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 2nd 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
3. For the letters Defendant sent bulling, threatening attached to the February
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 isnt a visiting judge available
to hear it.
2. This again shows that the Circuit Court Judges 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 Judges 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 Judges - 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 doesnt believe David Stold the money from Sonia Grenadiers 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 cant believe he just said that to me.
6. Again I ask Diane Fiske about getting Judges that arent friends of Ilonas.
May 13, 2008 Letter from Diane P Fiske that the case would be heard by Judge
John J. McGrath. This letter shows the following Judges in the letter head:
1. Donald M. Haddock
2. John E. Kloch (Retired) which means at the time Judge McGrath was chosen
Default
B. For Motion for Default filed in February for Lying in the Answer to Bill of
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
Spring of 2008 Diane Fiske again advices Plaintiff the only way anyone else would
choose a Judge was if they couldnt 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 Judges had recuse themselves is when the Supreme Court should have
been choosing the Judges not the Judges 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 Judges that were arms length.
When Ilona left I turned to Judge Haddock and introduced myself which he then went
onto inform me I wouldnt 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 cant 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 26th 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
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-
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 didnt 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 isnt enough to have the Commonwealths Attorney tell you Judge
John McGrath has done a lot of work in the Alexandria Courts.
July 28,2008 1st 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 didnt include David
B. Judge Kloch hanging outside the door
C. Sonia Grenadier Trust brought up in opening By Ilona & David and I was
off at my house.
8. September 24, 2008 - Diane hears back from Judge McGrath doesnt want to see
new evidence or any Exhibits Faxed to him never seeing Exhibits immediately
Denies
9. Randy Sengel Commonwealths Attorney Informs me that Judge McGrath has
Arlington
11. Alexandria Circuit Court Yes McGrath is from Harrisonburg But, has several ties
to Alexandria & is working w/ Judge Kloch guess they just didnt think that was
important
12. File complaints w/JIRK Commission of course I didnt have all the information and
January
20
JWG
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 Petitioners 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
JWG
11
14 JWG
14 Sengel
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
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 witnesss
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
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.
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, Judges and the
Judges 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 Plaintiffs
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 Attorneys 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 Judges Chambers then to their clients and such bills were
found acceptable to the Supreme Court of Virginia. The State of Virginias 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 Virginias 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 defendants representatives breached their
contractual duty of good faith and fair dealing when Judges ruled in Favoritism
and Cronyism. When Judges 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
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 persons 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 Boys 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
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 Judges, 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 witnesss 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 defendants 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 defendants 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 defendants actions were Arbitrary and Capricious absence of a rational connection
between the facts found and the choices 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 -
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.
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:
This 30th day of April 2014
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