JWG IEG Final W- Exhibits Appeal September 26, 2012 Bel v7 Dec 24, 2012

7/30/2019 JWG IEG Final W- Exhibits Appeal September 26, 2012 Bel v7 Dec 24, 2012

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IN THE

SUPREME COURT OF VIRGINIA

RECORD NO: ___________________

COMMONWEALTH OF VIRGINIA,

Janice Wolk Grenadier

Appellant,

v.

ILONA ELY FREEDMAN GRENADIER HECKMAN

And

GRENADIER INVESTMENT CO, LTD,

And

DAVID MARK GRENADIER

Appellees,

APPEAL FROM THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA

VIRGINIA - CASE # CH010654

(RULE 5:17)

Janice Wolk Grenadier [email protected]

15 West Spring Street

Alexandria, VA 22301

703-623-9655

pro se

Ilona Ely Freedman Grenadier Heckman, Esquire

Grenadier Heckman Starace Duffett

649 South Washington Street

Alexandria, Va 22314


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703-683-9000

Counsel for / pro se - Appellee - Ilona Ely Freedman Grenadier Heckman

& Grenadier Investment Co. LTD till approximately May 28, 2010

Benard J. Dimuro, Esquire (VSB # 18784) [email protected] J. Collyer, Esquire (VSB # 50952) [email protected]

John M. Tran, Esquire (VSB # 24349) [email protected]

DiMuroGinsburg

908 King Street, Suite 200


703-684-4333

Counsel for - Appellee - Ilona Ely Freedman Grenadier Heckman &

Grenadier Investment Co. LTD from approximately May 28, 2010

Michael J. Wiser, Esquire ( VSB #17630) [email protected]

510 King Street, Suite 416


703-836-7003

Counsel for Appellee David Mark Grenadier

SUBJECT INDEX

Assignment of Error

Question Presented

Nature of the Case and Material Proceedings in the Court of Trial

Parties

Statement of FactsArgument

Conclusion


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TABLE OF AUTHORITIES

CONSTITUTIONS

United States Constitution.. passimVirginia Constitution.......... passim

CASES:

Boddie v. Connecticut, 401 U.S. 371 (1971), was a case before

the United States Supreme Court

In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985),

Butz v. Economou, 98 S.Ct. 2894 (1978); United States v. Lee, 106 U.S.

at 220, 1 S.Ct. at 261 (1882)

Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5 L.Ed 257 (1821)

Davis v. City of Portsmouth, 579 F. Supp. 1205, 1209-10 (E.D. Va.

1983), affd, 742 F .2d 1448 (4th Cir. 1984)

Hallberg v Goldblatt Bros., 363 Ill 25 (1936),

Faretta v. California, 422 U.S. 806 (1975) United States Supreme Court

Harrison v. U.S. Postal Services840 F. 2d 1149, 1152 (4th Cir. 1988).

Under Illinois and Federal law,Citation: 93F. 2d 313 (2d Cir. 1937)

,Johnson v. Zerbst, 304 U.S. 458, 58 S.Ct. 1019(193

Janove v. Bacon, 6 Ill. 2d 245, 249, 218 N.E. 2d 706, 708 (1953)

Loving v. Virginia, 388 U.S. 1 (1967),[1]was a landmark civil

rights decision of the United States Supreme Court

In re Murchinson, 349 U.S. 133, 136 (1955)
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Pure Oil Co. v. City of Northlake, 10 Ill.2d 241, 245, 140 N.E. 2d 289

Rosenstiel v. Rosenstiel, 278 F. Supp. 794 (S.D.N.Y. 1967)

In re Sawyer, 124 U.S. 200 (1888),

Stone v Powell, 428 US 465, 483 n 35, 96 S. Ct 3037, 49 L Ed. 2d 1067

(1976)

U.S. v. Will, 449 U.S. 200, 216, 101 S. Ct. 471, 66 Ed.2d 392, 406 (1980);

STATUES:

Virginia Code 17.1-105(b) - Designation of judges passim

CANONS OF JUDICIAL CONDUCT

Canon1.....passimA Judge shall uphold the integrity and independence of the judiciary.Canon 2.passimA Judge shall avoid impropriety and the appearance of improprietyin all of the Judges activities.

Canon 3 ..passimA Judge shall perform the duties of judicial office impartially and diligently.

(Part Six, III of the Rules of the Supreme Court of Virginia integratesthe Canons of Judicial Conduct for the State of Virginia stated above.)RULES OF PROFESSIONAL CONDUCT

Preamble: A Lawyers Responsibilities...........passim

A lawyer is an officer of the legal system.

Rules 1.1 - 1.18: Client-Lawyer Relationship..... passimRules 3.1 - 3.9: Advocate*.............passim

Rules 4.1 - 4.4: Transactions with Persons other than Clients*passim


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(Part Six, II of the Rules of the Supreme Court of Virginia integrates the

Professional Guidelines and the Rules of Professional Conduct stated

above.)

EXHIBITS

A. The Case Document Action Details Page 19

B. Letter Dated February 8, 2008 from Defendant Ilona Page 20

C. Tax Record to show ownership of Southway Page 20

D. February 27, 2008 CounterClaim and Cross-Complaint. Page 20

E. Letter May 21, 2008 from Defendant Ilona Page 20

F. July 24, 2008 threatening e-mail to Plaintiff fromDefendant Ilona Page 21

G. Filed February 3, 2011 Respondents Joint Motion

to Dismiss Petition for Appeal Page 24

H. Front page Supreme Court of Virginia

Record No. 110156 Filed on February 18, 2012 Page 23

I. E-mails between Scotty Subitzky, Ilona Grenadier, Page 15

and Diane Brodsky

J. E-mails between Plaintiff, Amy Bird, Scotty Page 15

Subitzky, Jon Barker

K. The Interment Order and Authorization for Ruth

Subitzky to be buried next to her Mother, Father

and Brother the late Judge Albert Grenadier. Page 15

L. The Order by Judge Clark the Circuit Court of Alexandria refusingPlaintiff the Right to File her Opposition Page 18

M. A Copy of the Opposition to Order by Judge Clark on the Statement

of Facts for September 26, 2012 . Page 18


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ASSIGNMENT OF ERROR

1. The trial court of the Circuit Court of Alexandria erred when it granted

the defendants motion to impose monetary sanctions against the

plaintiff in violation of the Code of Virginia 8.01-271.1, on the

grounds that her Motion to Reopen the Case based upon Fraud on

the Court was not well grounded in fact nor warranted by existing law.

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)

2. The trial court of the Circuit Court of Alexandria erred when it granted

theAppellees motion to deny the Appellant due process under the

U.S. Constitution by entering an order to deprive her of any future of

legal documents without the permission of Judge Clark in the Circuit

Court of Alexandria. 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 reMurchinson, 349 U.S. 133, 136 (1955)


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3. The trial court of the Circuit Court of Alexandria erred by failing to

protect the Civil Rights of Plaintiff by ignoring Due Process, showing

favoritism to the Defendants and Defendants attorneys because of

who they are part of the Old Boys Network ofVirginia. Plaintiff was

informed this by the x-wife ( Martha Kent ) of Judge Kent for Plaintiffs

Senator Patsy Ticer You are no longer one of them. You cant get

a fair trial just like me and my family you need to drop this you

cant win 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 their race.

4. The trial court of the Circuit Court of Alexandria erred by failing to

follow Va. Code 17.1-105(b) after all judges recused themselves (or

were required to recuse themselves) from this matter because of

personal relationships between Defendants and the judges. Insteadof having the Chief Justice of the Supreme Court appoint an out of

Circuit Judge to hear the case, the Circuit Court of Alexandria (or its

clerk) selected a judge themselves. Appellants motions challenging

the appointment of the out of Circuit judges were denied and

judgment ultimately entered against her. All Orders in this case are

Void due to no Judge who has heard case has been appointed

appropriately by law. Judge Clark who heard this case on September

26, 2012 by his past actions should have recused himself.

5. The trial court of the Circuit Court of Alexandria erred when it allowed
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Ilona Appellee officer of the court and her attorneys, officers of the

Court to be disingenuous in court, in filing with the court, and the

Supreme Court. Especially where Ilona an officer of the court was

representing herself, and had in the past represented Plaintiff. 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, anduphold 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)

6. The trial court of the Circuit Court of Alexandria erred when it

returned Appellants documents that were summited into evidence

on September 26, 2012, through USPS mail on or around October

13, 2012. This evidence ( a white notebook) was entered into the

record with no objections from Appellees, or Appellees attorneys.

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


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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.

7. The trial court of the Circuit Court of Alexandria erred with it rulings In

denying access to pro se litigants such as myself to filing documents

with the Clerk of Courts office. The order is not rational nor would

such an Order be allowed if Plaintiff was an attorney or had an

attorney. Further, this policy puts Plaintiff before the court on an

unequal footing with Plaintiffs opponent, a due process violation.

,Johnson v. Zerbst, 304 U.S. 458, 58 S.Ct. 1019(193 ;Pure Oil Co.

v. City of Northlake, 10 Ill.2d 241, 245, 140 N.E. 2d 289

(1956);Hallberg v Goldblatt Bros., 363 Ill 25 (1936), the court

exceeded it's statutory authority. Rosenstiel v. Rosenstiel, 278 F.

Supp. 794 (S.D.N.Y. 1967) Plaintiffs opponent has the benefits of

being an attorney, the widow of a past Judge that has served with allthe Judges that have heard the case, and is now represented by

counsel, that was a past President of the Virginia State Bar, and has

donated 10% of his estate to the Bar when he passes. Along with the

Defendant Ilona & her counsel generously donating to the Judicial

fund for Judge Haddocks portrait after Judge Haddock informed

Plaintiff in May of 2008 You will never get a fair trial as we LOVE

ILONA and then in October of 2011 blocked Plaintiff from going in

front of the Grand Jury in the City of Alexandria as he stated I

believe you are going to talk about me . He then went on to demand


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Plaintiff to come back on December 12, 2010 which was postponed

to protect his retirement of December 31, 2010. Plaintiff was then

blocked in February of 2011 by Commonwealth Attorney Randy

Sengel and Supreme Court appointed Judge Richard Bowen Potter.

The right of self-representation in a civil case is a fundamental right

under the Constitution. I recognize that this argument is contrary to

dicta of this circuit: however, Faretta v. California, (422 U.S. 806) and

the history on which that decision is based, is apparent that the

fundamental right of self-representation extends to all matters, civil as

well as criminal.

8. The trial court of the Circuit Court of Alexandria erred when it served

an Order on Appellant signed by Judge Kemler, Judge Dawkins,

Judge Clark dated October 12, 2012 denying the Appellant due

process under the U.S. Constitution by entering an order to deprive

her of any future of legal documents with the Circuit Court of

Alexandria. ( Judge Kemler and Judge Dawkins by appearance had

recused themselves from this case ( Judge Kemler in September of

2007 and April of 2008 for Judge Dawkins), then in writing on or

around October 11, 2010 in an Order to the Supreme Court of

Virginia. Boddie v. Connecticut, 401 U.S. 371 (1971), was a case

before the United States Supreme Court. Plaintiff has not had her day

in Court!
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9. The trial court of the Circuit Court of Alexandria erred when it ignored

the fact Plaintiff had not been served properly by Defendants

attorneys, service of process was not made pursuant to statute and

Supreme Court Rules, Janove v. Bacon, 6 Ill. 2d 245, 249, 218 N.E.

2d 706, 708 (1953)

QUESTION PRESENTED

Question: Did the Circuit Court of Alexandria err by appointing an out

of Circuit judge, instead of have the Chief Justice of the Supreme Court

appoint an out of Circuit judge pursuant to Va.Code 17.1.105(B), when all

judges of the Circuit Court of Alexandria recused themselves (or were

required to recuse themselves) because of relationships between

Defendants and the Judges.

Answer: Yes. Thus, the judgment against Plaintiff should be

vacated and the matter remanded for trial before a new out of Circuit judgeappointed by the Chief Justice of the Supreme Court.

Question: Should Judge Clark have recused himself on September

26, 2012.

Answer: Yes by all appearance he had done so in the past:

1. January 25, 2012 not hearing a Motion filed appropriately with the

Clerks office

2. February 8, 2012 not hearing a Motion filed appropriately with the

Clerks office


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and had received a letter in May of 2012 stating he would be involved in a

suit against those that had prevented Plaintiff from a Fair trial and blocking

her on or around February 12, 2012 scheduled appearance in front of a

Grand Jury.

Question: Did the trial court abuse its discretionin finding that the

pleadings Plaintiff signed (a) were not well grounded in fact, (b) were

interposed for improper purpose, and (c) were not warranted by existing

law or a good faith argument for re-opening case, under 8.01 271.1with

the sanctions apposed on Plaintiff.

Answer: Yes. Plaintiff on July 26, 2012 filed to re-open the case

with, over 1,000 pages of Exhibits of evidence that she was due the money,

and that Fraud on the Court by Defendants (Ilona and officer of the court)

and their attorneys had taken place. Plaintiff as evidence presented the

Deed of Trust, Hud Is, canceled checks, bank statements, letters etc. for

monies due her.

Question: Have Janices Fundamental rights as an American

Citizen, under the United States Constitution, Civil Right Laws, Political,

Religious and Virginia Constitution been violated.

Answer: Yes: That Plaintiffs fundamental right to Due Process

the basic Freedoms that our country stands for. The right to due process

without Fraud from Lawyers, Judges, Judicial, Elected officials is a primary

component of Freedom. The right to a Fair Trial Due Process is the basic

Constitution right that has been the source of the light of freedom that our

Country has given the World. This basic Liberty is what our flag stand for


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and here is where the standard of Liberty is set for the rest of the World.

This case started out as a Real Estate Partnership where one partner took

advantage of another partner that partner Defendant Ilona appellee,

officer of the court showed how little integrity she has from how she stole

from the Sonia Grenadier Trust - not once but on several occasions, along

with using the Forged Trust Addendum to move Herman Grenadier from

his resting place, using forged trust addendum to donate his land and by

appearance took as a personal tax deduction. After allowing his daughter

Ruthie to be buried next to her brother the late Judge Albert Grenadier, to

then send an e-mail that she didnt give permission and filed a false

complaint with the State of Virginia. Ilona Appellee was also Ruthies

attorney, and waited 3 years after she was buried so the family couldnt get

her records from Ilona Appellee attorney, officer of the court.( Exhibits I, J,

K ) But, it is deeply saddening now to see how harsh the effects of

deprivation of basic freedoms, deprivation of constitutional rights are to

Plaintiffs freedom and basic human rights are to Plaintiffs freedom. On

September 26, 2012 Janice entered into evidence a Notebook of exhibits it

was accepted by the Judge who then asked Appellees attorneys ifthere

were any objections. They did not object. Plaintiff has included Exhibits as

she is not sure what has been removed from or included in her file from the

Clerks office in the City ofAlexandria.

Question : Were Judges, Defendants Attorneys bullying pro se

Plaintiff saying her filings were Frivolous?

Answer : Yes - The facts are very clear and have never changed.

The Plaintiffs due process has been violated by Judges, attorneys, state


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employees, city employees, elected officials. Plaintiffs case does not lack

legal merit. There is collusion between the above to prevent Plaintiffs due

process. Plaintiff has shown full documentation in Exhibits filed with Motion

to re-open her case. Boddie v. Connecticut, 401 U.S. 371 (1971), was a

case before theUnited States Supreme Court. Justice Brennanconcurred

on the ground that while denying indigents access to the courts for

nonpayment of a fee is a denial of due process, it is also a denial of equal

protection of the laws, and no distinction can be drawn between divorce

suits and other actions.

Nature of the Case and Material Proceedings in the

Court of Trial

What started out as a partnership agreement for a piece of Real Estate

has turned into a Constitutional right of Plaintiff for Due Process. By a

corrupt attorney Defendant Ilona Ely Freedman Grenadier Heckman that

since on or around September 7, 2007 has used bribery, friendships, lies,

intimidation, willfully with acts that were malicious, violent, oppressive,

fraudulent, wanton, or grossly reckless. The Exhibits which have been

added for ease, and because of the nature of the Judges handling of

Plaintiffs file with the Circuit Court of Alexandria Plaintiff is not sure all

documents will be forwarded to the Supreme Court. These documents

should be found in the file from July 26th filing of Motion, except for

Exhibits L & M the last two shows the Courts deliberate willful actions ofmalleus towards Plaintiff blocking her Opposition of the Judges Order on

the Facts of the Case. On September 26, 2012 Judge Clark took away

Plaintiffs basic Rights as an American Citizen to file documents in her case
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without his permission. In doing this Judge Clark set the appearance of a

Trustee relationship between Plaintiff and Judge, as he is aware of the

case and actions of the Defendant to be in value of close to 3 Million

dollars. Defendant Ilona Ely Freedman Grenadier Heckman since March of

1990 has acted with fraudulent behavior, manipulation of Plaintiff and the

Court has been disingenuous to protect her illegal actions in her law firm of

the financial theft from the Sonia Grenadier Trust, and Plaintiff.

PARTIES

1) Plaintiff (Appellant) Janice Wolk Grenadier a 50% Owner of 28

East Bellefont Avenue, Alexandria of which the other 50% is owned

by Grenadier Investment Co. Ltd. (GIC). She is divorced from

David Mark Grenadier. Victim of manipulation from lawyer Defendant

Ilona

2) Defendant (Appellee) David Grenadier is a 49% owner of GIC.

He is the stepson of Ilona Ely Freedman Grenadier Heckman and theson of the late Judge Albert Grenadier of the Circuit Court of

Alexandria.

3) Defendant (Appellee) - Ilona Ely Freedman Grenadier Heckman is

a 51% owner of GIC. She is a licensed attorney in Virginia and was

the wife of the late Judge Albert Grenadier. She through her law firm

is with holding a note that she wrote and kept the only copies when

she was by appearance working as attorney for Plaintiff. Ilona officer

of the court advised Plaintiff at the time she was not to talk to anyone

or to seek other legal advice in regard to the situation with the

stealing of funds from the Sonia Grenadier Trust out of her law firm.


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In the Exhibits B, C, D, E, F you will find letters and e-mails that are

inappropriate and disingenuous in content that Defendant Ilona

representing herself, in this case sent to Plaintiff to intimidate Plaintiff.

On or around July 26, 2011 E-mails (Exhibit I) between Scotty

Subitzky, Ilona Grenadier, and Diane Brodsky (4 pages ) You must

start on Page 4 and work towards page 1of the e-mails. The Sonia

Grenadier Trust is discussed along with the disingenuous statement

that Ilona a lawyer officer of the court didnt give permission for their

mother to be buried next to her mother, father, and brother and they

now needed to have her moved as Ilona officer of the court didnt

want strangers in her garden.

On or around August 10, 2011 E-mails (Exhibit J) between Plaintiff,

Amy Bird, Scotty Subitzky, Jon Barker trying to get information that

has been denied. Defendant Ilona filed a disingenuous complaint

with the State of Virginia saying she had not given permission for

Ruth Subitzky to be buried next to her Mother, Father and Brother.She also did not mention in the complaint the use of the forged Trust

Addendum, and refuses to disclose whose money she used to buy

the new garden with.

On or around May 20, 2012 Ilona an officer of the court signed The

Interment Order and Authorization ( Exhibit K ) for Ruth Subitzky to

be buried next to her Mother, Father and Brother the late JudgeAlbert Grenadier. Which she denies in Exhibit I and in her Complaint

to the State of Virginia saying King David Memorial of Falls Church,

had buried a stranger in her Garden without her permission. Where


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in truth by all appearance Defendant Ilona knowingly had used a

Forged Trust agreement to move Herman, donate his garden and

refuses to produce the checks used to purchase garden. Which at

the time out of Defendant Ilonas law firm money was being stolen

from the Sonia Grenadier Trust. This evidence is the nature of the

way Defendant Ilona has treated Plaintiff during these procedures

and has blocked Plaintiff from due process. Defendant Ilona holds a

note from when she worked as Plaintiffs lawyer, threatening her that

she was not to get other legal advice.

4) Defendant (Appellee) - Grenadier Investment Co. Ltd(GIC) a

Real Estate Investment Co. owned 51% by Ilona Grenadier Heckman

and 49% by David Grenadier.

5) Sonia Grenadier Innocent Victimthat Defendant Ilona through

her law firm created a situation to steal over $95,000. From her trust.

The follow is the Facts in re-guard to what has taken place against

Sonia Grenadier. This pertains to this case because it shows the

extent Defendant Ilona will go to steal and get away with the theft.

On or around October 16, 1973 Herman Grenadier died (with a last

will and testament) was buried in one of the lots he and Sonia (his

wife) owned at King David Memorial Garden

On or around May 2, 1975 a Trust called the Sonia Grenadier Trust was

created

On or around July 4, 1978 Albert Grenadier married Ilona Ely Freedman

On or around Novemer 30, 1983 an Amendment to the Sonia Grenadier

Trust was done giving Ilona Grenadier Trustee powers - The Trust

Amendment Sonias signature was forged.


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On or around March 29, 1985 Judge Albert Grenadier died being buried

in the Garden owned by Ilonas family at King David Memorial Garden

On or around May 20, 1985 Ilona was informed the amendment to the

Sonia Grenadier Trust was forged and VOID -On or around September 24, 1985 Ilona claims to have purchased her own

garden at King David Memorial Garden ( Ilona will not produce the checks

to show if she paid for the garden or it was paid for out of a checking

account with Judge Albert Grenadiers name and Sonia Grenadiers

account)

On or around September 25, 1985 Ilona moved Albert Grenadier out of

her families garden to her garden

On or around September 26, 1985 Ilona stole Herman Grenadier out of his

garden and moved him to hers using the Trust Amendment that was VOID

due to the forgery of Sonia Grenadiers name

On or around December 6, 1985 Jim Arther wrote to Ilona in regard to the

Sonia Greandier Trust and the mechanics of it -

On or around December 1985 Ilona Ely Freedman Grenadier married

Jerome (Jerry ) Heckman 1st cousin to the late Judge Albert Grenadier -

Albert according to his family considered Jerry a Wiesel. Jerrys mother

Pauline was Sonias sister

On or around March 18, 1986 Ilona Grenadier Sonia & Herman

Grenadiers Garden at King David using the Trustee agreement that she

was informed around May 20, 1985 that it was VOID she did not have

Trustee powers.

At one point Ruth Grenadier Subitzky (Alberts sister) became a paying

client of Ilona Grenadiers law firm

On or around May 17, 2008 Ruth Grenadier Subitzky died and with Ilonas

written permission was buried in her garden


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On or around May of 2008 Janice Wolk Grenadier learned that Ilona had

acted intentionally, willfully, wantonly, and maliciously in the manipulation of

her and Ruth, all the lawyers and everyone involved in the mismanagement

of the Sonia Grenadier Trust.

Ruths children met with Ilona at which time she mentioned an issue with

King David - JWG believes she was waiting for the 3 year time frame to

expire so she could legally dispose of all of Ruths files.

On or around July 26, 2011 Ruths children called JWG to help them with

an issue They had been contacted that a Stranger was in Ilonas garden

That Stranger Ilona was claiming not to know was their Mother

Ruths children got a call (Amy Bird) from King David that Ilona wanted her

mother dug up because she hadnt been given permission to be buriedthere. Which was untrue.

STATEMENT OF FACTS

On September 26, 2012 in the Circuit Court of Alexandria Judge

Clark presiding, Issued 3 Orders Sanctioning Plaintiff, and taking away

Plaintiffs rights to file documents in the Circuit Court of Alexandria. Judge

Clark the Circuit Court of Alexandria refused Plaintiff the Right to opposehis Order on the Statement of Facts that he filed on December 7, 2012.

His statement of Facts is fanciful in nature with no direct detail. In all 3

Orders on September 26, 2012 Judge Clark took away the basic liberties of

Plaintiff, due to the value of the case and his knowledge of the value of the

case he has created a Trustee type relationship with Plaintiff. (Exhibit M)

Is his Order denying Plaintiff the right to file an Opposition to his Order.

The affidavits from Defendants attorneys show conversations with Judges

Chambers which by all appearance is ex-parte communication with the

Judge.


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A Copy of the Plaintiffs Opposition to the Order entered by Judge

Clark ( ExhibitN )in regard to Plaintiffs Statement of Facts for September

26, 2012 . The opposition contains the unprofessional behavior to other

Plaintiffs that have tried to find Justice in the Circuit Court of the City of

Alexandria, and have also been threaten with bodily harm. This supports

Plaintiffs own discrimination by the Circuit Court and Clerks office in the

City of Alexandria.

This case started whenJanice Wolk Grenadier (Plaintiff) filed

claims in the Circuit Court of Alexandria (the Circuit Court) in September,

2007 against Defendants related to 28 East Bellefonte Avenue, Alexandria

VA (the Property) owned 50% by Plaintiff and 50% by GIC (which was

owned by Defendants Ilona and David ). Plaintiff alleged that Defendants

failed to pay their fair share of expenses related to the Property. Plaintiff

claimed damages of approximately $300,000,( damages for Bellefonte are

now around $530,000 without punitive damages & $ 2.25 million for the

note and loss of business) including interest compounded at 10%.Defendants Ilona and David were related to the late Judge Grenadier of the

Circuit Court. Defendant Ilona was disingenuous in court on September 7,

2007 about being served. Exhibit A shows Defendant Ilona a lawyer

(officer of the Court) representing herself had been appropriately served by

the Sheriffs in the City of Alexandria, and that she deliberately made false

statements to Judge Kloch about service. Which is where this slippery

sloop started.

At the time that Plaintiff filed suit, the judges of the Circuit Court were

Judge Donald Haddock, Judge Lisa Kemler, and Judge John Kloch. On


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or about September 22, 2007, Plaintiff was informed by Diane Fiske, the

Court administrator, that all three judges had recused themselves, i.e. (1)

Judge Kemler was a close friend of and grew up with Defendant David; (2)

Judge Haddock was a personal friend of Defendant Ilona; and (3) Judge

Kloch had a personal relationship with Defendant Ilona and her late

husband, Judge Grenadier.i1 The matter was assigned to out of Circuit

Court judges who were not appointed by the Chief Justice of the Supreme

Court as early as December, 2007 when out of Circuit Court Judge Thomas

A. Fortkort denied Plaintiffs motion for a default.

On February 8, 2008 Plaintiff received a letter( Exhibit B) from

Defendant Ilona a lawyer (officer of the Court) representing herself, the

correspondence clearly indicates defendants knowingly Fraud on the Court.

The letter is riddled with false statements. The correspondence is

malicious, violent, oppressive, fraudulent, wanton, and grossly reckless for

a lawyer. In Letter (Exhibit B) Defendant Ilona a lawyer (officer of the

Court) representing herself states on Page 2 Paragraph 2 to look at the

recent sale of Southway a property purchased by GIC (Exhibit C) This

Public record shows the ownership of Defendant Ilona a lawyer (officer of

the Court) still owned property as of September of 2008, and still owns

such property as of today according to Public Tax Records. On February

27, 2008 Defendant Ilona a lawyer (officer of the Court) representing

herself filed a Counterclaim - Cross Complaint (Exhibit D) that she owned

1Judge Kloch denied Plaintiffs motion for default on September 12, 2007 prior to recusing

himself.


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75% of property known as 28 E Bellefonte, along with several other

misrepresentations to the court.

On or around May 21, 2008 Plaintiff received another letter(Exhibit

E) from Defendant Ilona a lawyer (officer of the Court) representing herself

the letter is full of disingenuous statements. On page 1 bottom of the page

she alleges that in admissions after Plaintiff supplied information that she

admitted ownership of the 50 50%. Plaintiff if you look in the File On or

around September 21, 2007 when she filed her first Motion for Default due

to Plaintiffs lie about not being served for court on September 7, 2012 to

Judge Kloch that Plaintiff had filed all documents in the Motion for Default,

along with an accounting Defendant Ilona had done in regard to the

Property, showing she had never put more than approximately $3,800. Into

the Bellefonte Property taking out approximately $85,000. Again a

threatening and disingenuous letter from Ilona an officer of the court while

in litigation against Plaintiff. July 24, 2008 Plaintiff received threatening e-

mail (Exhibit F ) from Defendant Ilona a lawyer (officer of the Court)representing herself with response from Plaintiff. The e-mail represents the

unprofessional and how disrespect Defendant Ilona a lawyer (officer of the

Court) representing herself has for the basic rules of the Court. It really

speaks for itself the threats to Plaintiff. This e-mail goes into her actions

with the Sonia Grenadier Trust.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),


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In April, 2008, Judge Kloch retired and was replaced by Judge

Dawkins who was appointed on April 24, 2008 and sworn in on June, 2008.

In July, 2008, out of Circuit Court Judge Brown denied Plaintiffs motion for

a jury trial. After the decision, Defendant Ilona informed Plaintiff that

Judge Brown was her friend. This was never disclosed to Plaintiff before

Judge Browns decision. Judge John McGrath, an out of Circuit Court

judge, was chosen by the Circuit Court to hear the matter in May, 2008.

Judge McGrath dismissed the case in September, 2008.2

In June, 2010, Plaintiff learned of Va.Code 17.1.105(B). On July 13,

2010, Plaintiff filed a motion to set aside all decisions from September 17,

2007 forward because the out of Circuit Court judges were improperly

appointed. Plaintiff filed an addendum on August 4, 2010. Judge Kloch

denied Plaintiffs post-trial motion on August 11, 2010 (even though he had

recused himself in 2007 and retired in April, 2008) and then recused

himself and immediately vacated his decision on August 12, 2010.

Thereafter, Judge Dawkins denied Plaintiffs post trial motion on or aboutOctober 20, 2010 even though in June, 2010 Plaintiff was informed by

Diane Fiske that all judges of the Circuit Court had recused themselves.

On July 26, 2012 Plaintiff after learning that the actions of the court and

defendant Ilona an officer of the court were considered Fraud on the Court

2In his August 12, 2010 decision vacating his decision and recusing himself, Judge Kloch

disclosed a close business relationship with Judge McGrath through Judicial Solutions, a privatedispute resolution company based in Harrisonburg. Needless to say, this creates the inference

that Judge Kloch may have been involved in the selection of Judge McGrath the exact type of

appearance of impropriety that Va.Code 17.1.105(B) is designed to avoid, i.e. recused judges (or

judges who should be recused) selecting their successors instead of the Chief Justice of the

Supreme Court.


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and knowing she still had not had due process Boddie v. Connecticut,

401 U.S. 371 (1971), was a case before the United States Supreme Court.

filed to have the case re-opened.

On September 26, 2012 Plaintiff had all her fundamental rights

striped from her by Judge Clark of the Circuit Court of Alexandria. Judge

Clark blocked Plaintiff from calling Plaintiffs witness Ilona Grenadier (aka

Ilona Heckman) that had been served after Plaintiff had 3 times gone into

the Sheriffs office to confirm service. Plaintiff was informed if she had not

checked with the Sheriffs department and been as persistent the service

would not have occurred.

Plaintiff had filed a Les Pendens to protect her claim against

Defendant Ilona officer of the court, with this suit and a Note that Ilona

officer of the court had withwillful acts were malicious, violent, oppressive,

fraudulent, wanton, or grossly reckless in July of 1990 had Plaintiff agree to

a loan of $30,000. To reimburse the Sonia Grenadier Trust for monies

stolen out of the Grenadier Law Firm from the Trust. This protectedDefendant Ilona officer of the court being held responsible for over

$95,000. being stolen out of the Sonia Grenadier Trust to enrich defendant

Ilona officer of the court in Millions in Real Estate purchases with funds

taken from the Trust.

Judge Clark in Court with little respect to pro se Plaintiff refused to

explain rule 8.01-271.1 when plaintiff explained she did not understand the

rule with the sanctions. Plaintiff then went on to remind Judge Clark -

When reviewing a pro-sepleading, it is prudent to follow the federal

practice of liberally construing the allegations set out in the pleading to

determine whether the pleading asserts any valid causes of action. See,
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e.g. Harrison v. U.S. Postal Services840 F. 2d 1149, 1152 (4th Cir.

1988). The factual allegations should be viewed in the light most favorable

to the pleading party. Davis v. City of Portsmouth, 579 F. Supp. 1205,

1209-10 (E.D. Va. 1983), affd, 742 F .2d 1448 (4th

Cir. 1984)

Defendants attorneys on September 26, 2012 main concern was

getting the heading in pleadings to read Ilona Ely Freedman Grenadier

instead of Ilona Ely Freedman Grenadier Heckman as they presented it

to be malicious of Plaintiff to add Heckman to Defendant Ilonas name.

You will notice in the (Exhibit H ) which was filed with the Supreme Court

of Virginia on February 10, 2010 by Defendants own attorneys (DiMuro,

Collyer & Weiser) they use the name Heckman. This is just one more

example of the harassment of pro se Plaintiff. This disingenuous argument

by the attorneys was used for Sanctions against Plaintiff. Under Illinois

and Federal law,when any officer of the court has committed fraud upon

the court, the orders and judgment of that court are void, of no legal

force or effect.

Citation: 93F. 2d 313 (2d Cir. 1937) Any judgment procured by fraud is

null and void. An erroneous judgment may be attacked collaterally.

Affirmed

Plaintiff on September 26, 2012 reminded the court as part of her

Fraud on the Court that Respondents Joint Motion to Dismiss Petition for

Appeal filed on February 3, 2011(Exhibit G) by attorneys DiMuro, Collyer,

Weiser with the Supreme Court of Virginia. Page 2 Paragraph 2 States

Here, Petitioner has failed to ensure that the record contains either

transcripts or a written statement of facts. This statement is very


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disingenuous of the three (3) attorneys along with Defendant Ilona a lawyer

(officer of the Court) who had been representing herself. Fraud on the

Court, purposely misleading the Virginia Supreme Court of Virginia.

The word Frivolous, the Sanctions (which the bills include ex-parte

communication between Judges chambers and Defendants attorneys

which they are charging Plaintiff for, along with court costs to include the

time that when the Judge called roll Plaintiff stood up and said ready to

go Defendants said we prefer to be last by all appearance this had

been agreed upon prior to court, the court room was in lock down when the

case was heard last. The Sheriffs were not allowing any person into the

Court room during the Motions hearing. Not allowing Plaintiff to call her

witness to the stand, taking away Plaintiffs right to file documents with the

court were all willful acts that were malicious, violent, oppressive,

fraudulent, wanton, or grossly reckless to intimidate Plaintiff.

On around October 11, 2012 Plaintiff went to the Clerks officein the City of Alexandriato confirm Plaintiffs file was in Order. Plaintiff

found the Exhibits that the Judge had ordered into record where not in the

file. When Plaintiff questioned itJudges Chambers informed the Clerks

office after about 45 miniutes that Judge Clark was on the bench Plaintiff

would need to come back. Plaintiff went to the 4th floor to find that was a

lie. A clerk from Judges Chamber came down claiming she had been in

court on September 26, 2012 and


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1. The Judge never had them on the bench which is unture how would

the Judge have them if they hadnt been on the bench and he hadnt

received them in court?

2. They were never put into evidence - Judge Clark very clearly asked

Defendants lawyers if they had objections and niether attorney nor

defendant whom is a lawyer and was in the court room had an issue

with them being entered on the record.

3. Then it was Plaintiff could check the transcripts and they would say

that they were never entered into the record ( which means to Plaintiff

the transcripts have been tampered with)

4. Prior to leaving the court house Sheriff Kapetanis of the Alexandria

Sheriffs office escorted Plaintiff back into the Court house where

Plaintiff requested the notebooks back from Defendants lawyers if

they didnt wish to have them - They both in agreement informed

Plaintiff they needed them as they had been entered into the record

as evidence. Plaintiff walked away agreeing with them.

The Clerk from Judges chambers then gave Plaintiff the choice of taking

Plaintiffs Exhibits or they would be destroyed On October 13, 2012 in

the Mail Plaintiff received a Box which has not been opened from the

Circuit Court of Alexandria. It was x-rayed to show the notebook and

evidence that was entered into court on September 26, 2012.

The Supreme Court should check the file of Plaintiff to insure thather Statement of Facts filed on November 20, 2012 along with the

documents that were presented and accepted into Court record on

September 26, 2012. Pursuant to the Rules of the Supreme Court of


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Virignia. The filing was done with permission from Judge Clark as Ordered

by him on September 26, 2012.

ARGUMENT

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 andFourteenth 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.

The Trial Court on September 26, 2012 in its Order of sanctions under8.01 271. due to Janice in her filing for re-opening the case showed cause

that Appellees lied in Court on September 7, 2007 when Ilona Claimed she

had not been served. (Exhibit A) That Appellees Ilona an officer of the


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Court lied when she claimed 75% ownership of property misleading the

court in her Counter Claim Cross Complaint (Exhibit D). That the Judge

did not allow Plaintiff to call her witness, defendant Ilona to under oath

confirm Plaintiffs assertions.

RULES OF PROFESSIONAL CONDUCT Truthfulness In Statements to

Others In the course or representing a client a lawyer shall not knowingly:

(a) Make a false statement of fact or law; or

(b) Fail to disclose a fact when disclosure is necessary to avoid

assisting a criminal or fraudulent act by a client

Plaintiff Ilona July 7, 1990 fraudulently with malleus to protect herself and

her law firm lied to Plaintiff about the money that had been stolen out of the

Sonia Grenadier Trust. Defendant Ilona with malleus to intimidate Plaintiff

sent Letters and e-mails (Exhibits B, C, D, E, F).

In Dealing with Unrepresented Persons

(a) In dealing on behalf of a client with a person who is not representedby counsel, a lawyer shall not state or imply that the lawyer is

disinterested. When the lawyer knows or reasonable should know

that the unrepresented person misunderstands the lawyers role in

the matter, the lawyer shall make reasonable efforts to correct

misunderstandings.

(b) A lawyer shall not give advice to a person who is not represented by

a lawyer, other than the advice to secure counsel, if the interests of

such person are or have a reasonable possibility of being in conflict

with the interest of the client. ( Ilona Defendant officer of the court in

Exhibit B, D, E, F threaten Plaintiff she had better drop this case)


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Defendant Ilona an officer of the court in July of 1990 and for several years

acted as Plaintiffs lawyer in negotiating a loan to Defendant David to

protect Defendant Ilonas illegal and unprofessional behavior in the theft of

funds from the Sonia Grenadier Trust.

Supreme Court Rule 17.1-105(B) provides:

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.

In September, 2007, Plaintiff was informed that all judges of the

Circuit Court recused themselves because of their close relationship with

opposing parties and counsel. Nonetheless, as early as December, 2007,

the Circuit Court appointed various out of Circuit judges itself to adjudicate

the matter, including Judge McGrath to hear the case, instead of following

Rule 17.1-105(b). Thus, this Judge lacked jurisdiction to decide the

matter because the Chief Justice of the Supreme Court should have taken

responsibility to appoint a judge to hear the case in September, 2007.

Plaintiff learned of this in June, 2010 and preserved this point in her July

13, 2010 motion and August 4, 2010 addendum filed before the Circuit

Court.


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Here, not only has the Rule been violated, but the Circuit Court acted

with impropriety and created the appearance of impropriety by having

judges who recused themselves (or were required to recuse themselves)

because of personal relationships with Defendants select the out of circuit

judge, instead of the Chief Justice of the Supreme Court making the

selection. Even, assuming, for argument, the Judges did not formally

recuse themselves, if they were required to recuse themselves, they were

not permitted to circumvent the procedures of Rule 17.1-105(b) by

selecting an out of Circuit Court judge themselves. This violation is

particularly egregious when the interests of a per se party suing an attorney

are at stake. That Judge Clark through his actions of recuing himself in

the past and being put on notice Plaintiff planned on including him in a suit

for his actions in collusion for preventing Plaintiffs Constitutional Rights to

Due Process.

CONCLUSION

That Janice should be granted a new trial as she has not had her day

in court Boddie v. Connecticut, 401 U.S. 371 (1971), was a case before

the United States Supreme Court. That sanctions against Plaintiff should

be dismissed due to the Judge not having Jurisdiction, and that Plaintiff had

proven her case in documents submitted into Court when Motion filed on or

around July 26, 2012 and in Court on September 26, 2012. That the Les

Pendens should stay if full force and effect as Plaintiff has proven indocuments submitted on September 26, 2012 that Appellees without

punitive damages owe Plaintiff close to Three (3) million dollars for their

actions.
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The petition for appeal should be granted. All prior decisions and

the judgment against Plaintiff should be vacated and the Chief Justice

should reassign the case for trial before a Judge outside of the Circuit

Court, in a new Venue. The Plaintiff also prays the Supreme Court

appoints a Special Grand Jury to look into the actions of the Judges, the

elected officials, and the government officials that have by appearance

acted outside of their judicial or elected powers trying to prevent Plaintiff

from her birth right as an American citizen the Basic Liberty of Due

Process. The basic liberty that our Flag stands for and here is where the

standard of Liberty is set for the rest of the World. It is under the Oath that

each Justice has taken that this heavy burden lies on your shoulders to

protect the Rights of each and every Virginia Citizen.

Respectfully Submitted,


Pro se Appllant

15 West Spring StreetAlexandria, Virginia 22301

[email protected]

CERTIFICATE

Pursuant to Rule 5:17, I hereby certify that

The appellant is Janice Wolk Grenadeir pro se15 West Spring Street

Alexandria, Virginia 22301202-368-7178

[email protected]

The appellee is Ilona Ely Freedman Grenadier Heckman, Esquire & GrenadierInvestment Co Ltd was represented by Grenadier, Anderson, Starace & Duffett till
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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around May of 2010 the following counsel started representing Ilona Ely FreedmanGrenadier Heckman, Esq and Grenadier Investment Co Ltd

Dimuro Ginsburg PCJohn Tran EsquireBenard J. Dimuro, Esquire908 King Street Suite 200

Alexandria, Virginia, 22314703-684-4333

The appellee is David Mark Grenadier represented by:

Michael J. Weiser, Esquire

510 King Street Suite 416

Alexandria, Virginia 22314

A copy of this Petition for Appeal was mailed to the Clerk of the Supreme Court of

Virginia on December 24, 2012 and mailed to counsel for Appellees.

Appellant desire to state orally to a panel of this Court the reasonswhy the Petition for Appeal should be granted and wish to do so inperson.

This 24th day of December



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Documents

JWG IEG Final W- Exhibits Appeal September 26, 2012 Bel v7 Dec 24, 2012