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IN THE SUPREME COURT OF VIRGINIA

JANICE WOLK GRENADIER Petitioner / Appellant, v. ILONA ELY FREEDMAN GRENADIER HECKMAN (lawyer officer of the Court) And GIC GRENADIER INVESTMENT Ltd AND DAVID MARK GRENADIER ____________Respondents / Appellees MOTION FOR RECONSIDERATION FROM ORDER BY: Chief Justice The Honorable Cynthia D. Kinser Justices - The Honorable Donald W. Lemons - The Honorable S. Bernard Goodwyn - The Honorable LeRoy F. Millette, Jr. - The Honorable William C. Mims - The Honorable Elizabeth A. McClanahan - The Honorable Cleo E. Powell - Senior Justices - The Honorable Charles S. Russell - The Honorable Elizabeth B. Lacy The Honorable Lawrence L. Koontz, Jr. On February 22, 2013 Appellant Files this Emergency Motion to be responded to by 1pm on February 28, 2013 Record No. 122204 Circuit Court No. CH010654

COMES NOW Appellant gives the Supreme Court till Friday, February 28, 2013 to respond to this Reconsideration. On Friday February 28, 2013
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Appellant will turn over all information to the Federal Courts and Moodys the Financial group that rates the State of Virginal and the City of Alexandria and most other cities and counties in Virginia on their Bonds. The Corruption from the Circuit Court of Alexandria to the Supreme Court of Virginia is a disgrace to the State of Virginia. The following laws are very clear and Appellant has all back up to prove the willful acts that have been malicious, violent, oppressive, fraudulent, wanton, or grossly reckless of the Supreme Court of Virginia, JIRC, Circuit Court Judges, Lawyers, Legislatures, Government Employees 1. A pro se Appellant - . 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) When reviewing a pro-se pleading, 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, e.g. Harrison v. U.S. Postal Services 840 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)

2. 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 of Virginia. Plaintiff was informed this by the x-wife ( Martha Kent ) of Judge Kent for Plaintiffs Senator Patsy Ticer You are no longer one of
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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. 3. 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. Instead of 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. 4. The trial court of the Circuit Court of Alexandria erred when it allowed 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
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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)

5. 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 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. 6. 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
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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 all the 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 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
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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. 7. 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! 8. The trial court and the Supreme Court of Virginia has abused its discretion in 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 8.01 271.1 with the sanctions apposed on Plaintiff. 9. 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
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freedom that our Country has given the World. This basic Liberty is what our flag stand for 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 ) of appeal in the Supreme Court of Virginia. 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 if there 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 of Alexandria. 10. Judges, Defendants Attorneys bullying pro se Plaintiff saying

her filings were Frivolous? The facts are very clear and have never
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changed. The Plaintiffs due process has been violated by Judges, attorneys, state 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 the United States Supreme Court. Justice Brennan concurred 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. You cant change the Truth - The Truth is the actions of the Judges, 11. 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. 12. Citation: 93F. 2d 313 (2d Cir. 1937) Any judgment procured

by fraud is null and void. An erroneous judgment may be attacked collaterally. Affirmed 13. 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. 14. The constitutional guarantee of due process of law, found in the

Fifth and Fourteenth Amendments to the U.S. Constitution, prohibits


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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. 15. RULES OF PROFESSIONAL CONDUCT Truthfulness In Statements to Others In the course or representing a client a lawyer shall not knowingly: Make a false statement of fact or law; or 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) of Appeal Filed with the Supreme Court of Virginia 16. In Dealing with Unrepresented Persons

(a) In dealing on behalf of a client with a person who is not represented by 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
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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) Exhibits can be found in Appeal in the Supreme Court of Virginia

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. 17. 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.

18. This Motion is for reconsideration under Virginia law in conformity with the Constitution of the United States or the Commonwealth of Virginia. The Order was not signed by any Judge but it is the understanding of Appellant it should be considered the
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descions of all Justices. Which makes all Justices libel to the Treason of such Order. 19. A judgment may not be rendered in violation of constitutional protections. The validity of a judgment may be affected by a failure to give the constitutionally required due process notice and an opportunity to be heard. Earle v. McVeigh, 91 US 503, 23 L Ed 398. See also Restatements, Judgments ' 4(b). Prather v Loyd, 86 Idaho 45, 382 P2d 910. The limitations inherent in the requirements of due process and equal protection of the law extend to judicial as well as political branches of government, so that a judgment may not be rendered in violation of those constitutional limitations and guarantees. Hanson v Denckla, 357 US 235, 2 L Ed 2d 1283, 78 S Ct 1228. 20. It is a fundamental doctrine of law that a party to be affected by a personal judgment must have his day in court, and an opportunity to be heard. Renaud v. Abbott, 116 US 277, 29 L Ed 629, 6 S Ct 1194. Every person is entitled to an opportunity to be heard in a court of law upon every question involving his rights or interests, before he is affected by any judicial decision on the question. Earle v McVeigh, 91 US 503, 23 L Ed 398. 21. Appellant demands a copy of the judicial distribution sheet of the clerks office showing that documents were distributed as required to the judicial panel alleged to have participated in the order. 22. Appellant Demand a copy of the required clerk of the court's judicial bond holder and where it can be located at the Secretary of State's office. Naming the clerks of the court is coinsured as required under five USC 2902 through 2906.

23. Appellant Demands right to present oral arguments on the record and recording for future actions in the United States Supreme Court shouldn't be necessary.
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24. The retaliation from the following people against Appellant is a disgrace and embarrassment to all The Laws and the Rules are very clear and the extent that the following people have gone to harm Appellant and her girls is considered Treason. 25. Quote from Judge Klochs letter I believe strongly that the appearance of justice is equally important as justice itself 26. Judge Clark should have recused himself . His Orders are Void and Unconstitutional. 27. Appellant has yet to have a Judge with Jurisdiction to hear her case. 28. Michael Weiser in his Affidavit has more phone calls to Judges chambers then to his own client ex parte communication 29. Chief Justice The Honorable Cynthia D. Kinser Justices - The Honorable Donald W. Lemons - The Honorable S. Bernard Goodwyn - The Honorable LeRoy F. Millette, Jr. - The Honorable William C. Mims - The Honorable Elizabeth A. McClanahan - The Honorable Cleo E. Powell - Senior Justices - The Honorable Charles S. Russell - The Honorable Elizabeth B. Lacy - The Honorable Lawrence L. Koontz, Jr. by the Order are ruling on Favoritism and Cronyism and not the Rules and the Laws of the Supreme Court of Virginia puts the AAA rating with Moodys for Bond Funding in The City of Alexandria and the State of Virginia in a questionable situation. The facts are very clear that the state of Virginia is rated 47th and 49th in corruption and with the backup of my case and several others that the Judicial system has acted in Favoritism and Cronyism and not the Rules and the Laws of the Supreme Court of Virginia jeopardizes the State of Virginias bond rating.
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30. The Judicial Cannons are very clear and if the Justices of the Supreme Court of Virginia do not follow them - The State of Virginia is headed towards a state catastrophe. 31. CANONS OF JUDICIAL CONDUCT - That the Justices of the State of Virginia have to be reminded of their Oath of Office and the Canons of Judicial Conduct is a disgrace to the State of Virginia. Canon1 A Judge shall uphold the integrity and independence of the judiciary. Canon 2 A Judge shall avoid impropriety and the appearance of impropriety in all of the Judges activities. Canon 3 A Judge shall perform the duties of judicial office impartially and diligently. (Part Six, III of the Rules of the Supreme Court of Virginia integrates the Canons of Judicial Conduct for the State of Virginia stated above.)

Conclusion
The petition for reconsideration should be granted immediately. 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 Demands 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
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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,

Janice Wolk Grenadier Pro se Appllant 15 West Spring Street Alexandria, Virginia 22301 202-368-7178 jwgrenadier3@aol.com CERTIFICATE
Pursuant to Rule 5:17, I hereby certify that The appellant is Janice Wolk Grenadeir pro se 15 West Spring Street Alexandria, Virginia 22301 202-368-7178 jwgrenadier3@aol.com 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
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Alexandria, Virginia 22314 A copy of this has been e-mailed to John Tran, Michael Weiser and the Supreme Court of Virginia The 27th day of February 2013

Janice Wolk Grenadier

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