You are on page 1of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

VIRGINIA: IN THE CIRCUIT COURT FOR PRINCE WILLIAM COUNTY Ilona Heckman (lawyer) Individually and As Trustee of The Ilona Ely Grenadier Heckman Revocable Trust Plaintiffs vs. JANICE WOLK GRENADIER, Pro Se Defendant _________________________________
DEFENDANDT JANICE WOLK GRENADIERS FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF

MOTION FOR PRODUCTON OF DOCUMENTS FIRST REQUEST Case No. : CL 14-2185

Defendant, pursuant to Rule 4:9 of the Rules of the Supreme Court of Virginia requests that the Plaintiff produce the documents described below to Defendant at 15 West Spring Street, Alexandria, Virginia within twenty-one (21) days of service hereof. The requests are continuing in nature so as to require you to file supplementary responses if you obtain further or different information before trial. Definitions and Instructions
1. These requests relate to all documents in your possession, custody, or control, including documents which you have a right or privilege to examine up request or demand. 2. These requests should be construed as continuing in nature, requiring supplemental responses if further or different information responsive to any request is discovered or obtained at any time prior to trial, to the full extent provided in the Rules of the Supreme Court of Virginia. 3. When any copy of copies of any document responsive to a request is not identical to the original or any other copy thereof by reason of any notes, comments, markings, alterations or material contained thereon, deleted therefrom or attached thereto or otherwise, all such nonidentical copies should also be produced. 4. Documents should be produced in the order, as attached and in all other respects as they are maintained in the ordinary course including file folders or other identifying information.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

5. As to each document responsive to a request which is withheld on the ground of privilege, or for any other reason, please specify the date of the document (or if the precise date is not shown or ascertainable, the best approximation thereof); its title; the name and position of each person who prepared or assisted in preparing the document; the name and position of each person to whom the document was addressed or who has seen, has had possession or custody of. Or has had disclosed to him/her the contents of, the document or any copy thereof; the subject matter of the document; the grounds for withholding the document; if only a portion of such document is claimed to be privileged, a description of such reasonably segregable portion; and the specific numbered request(s) to which the document is responsive. 6. The use of the disjunctive includes the use of the conjunctive and the use of the conjunctive includes the use of the disjunctive. 7. Including means Including but not limited to. 8. The terms you and your refer to the Plaintiff et al and Plaintiffs law firm. 9. The term document or documents means the original, every nonidentical copy thereof, and every draft, of all writings or other things from which information can be gained, including but not limited to correspondence, letters, memoranda, affidavits, notes, files, reports, papers, books, records, publications, printed matter, contracts, agreements, computer printouts, appointment books, diary entries, desk calendars, tables, compilations, charts, recommendations, applications, forms, certificates, work papers, accounts, income tax returns, other records of obligations or expenditures, minutes, summaries or other records of or relating to any conference, meeting, visit interview or telephone conversation, transcripts, telegrams or telexes sent or received, photographs, newspaper clippings, sound recordings, audiotapes, videotapes, microfilm, microfiche, and information stored in a computer, and any other medium from which information may be obtained.

Requests 1. Any and all documents which in any way support the allegations contained in the Cross Complaint and hereinafter Plaintiff filed in this case. 2. Any and all documents either used by you, identified in or referred to by you in preparing your answers to Defendant First Set of Interrogatories served upon you. 3. All documents, exhibits, physical evidence or demonstrative evidence/exhibits which you may or will produce at the trial of this matter.
2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

4. All written statements or reports received from any expert witnesses with whom Plaintiffs, her attorneys, agents or employees have communicated regarding the allegations referred to in the Complaint. 5. Any documents, books, treatises or other material on which you, your expert witnesses or any other witnesses may rely on at the trial of this case, or of which they have knowledge. 6. All documents or correspondence which you have either received from any Defendant or which you sent to any or all Defendants in this case. 7. All documents or correspondence which you have received from any other persons not party to this action, which relate to, or in any way pertain to the allegations contained in the Complaint on your answers to Defendants First Set of Interrogatories or Defendants First Request for Admissions which have been served upon you. 8. All documents upon which you intend to rely in your presentation of this case or to prove your allegations or assertions claimed in this case. 9. All documents regarding any complaints against Plaintiff including any all complaints Plaintiff is aware of that were filed with the VSB against Plaintiff or any lawyers in Plaintiffs law firm since 1985. 10. All documents and conversations listed that Plaintiff has had with King David Memorial. 11. All documents and conversations in regard to any complaints Plaintiff field with the State of Virginia in regard to King David Memorial. 12. All documents and conversations in regard to Defendant with the City of Alexandria or Virginia Judicial system (including Federal ) or Law enforcement ( which includes any employee Judges. Commonwealth Attorney, Legislature etc . 13. All documents in any way related to Defendant in regard GIC, Real Estate or her relation with David Grenadier , Grenadier, Anderson, Starace, Duffett & Keisler, Jerome Heckman, Robin Grenadier, David Grenadier, Andrea Grenadier, Margo Heckman, Brian Grenadier, Karen Grenadier, Loretta Lax Miller (aka Muggy Cat, Billy Sullivan), in regard to Defendant and 28 East Bellefonte Ave, Alexandria, Virginia 22305, Chief Justice Cythia D. Kinser, Justices- Donald W. Lemons, S. Bernard Goodwyn, Leroy F. Milletter Jr., William C. Mims, Elizabeth A. McClanahan, Cleo Powell Senor Justices - Harry L. Carrico, Charles S. Russell, Elizabeth B. Lacy, Lawrence L. Koontz Jr., Clerk of Court Patricia L. Harrington and any other Supreme Court Employees of the State of Virginia. Any and all Virginia State Legislators Patsy Ticer her staff, Adam Ebbin and his staff, David Englin and his staff. Any
3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

all members of the Courts of Justice Henry Marsh, Dave Albo and all staff. Judicial Inquiry and Review Commission (JIRC) all staff and Donald Curry. The Virginia State bar staff and Edward Davis or James Michael McCauley. Any and all Circuit Court Judges and there staff Judge Donald M. Haddock, John Kloch, Lisa B. Kemler, Nolan B. Dawkins, Thomas A. Fortkort, J. Howe Brown, John J. McGrath Jr., James C. Clark, Richard Bowen Potter. Any and all correspondence with General District Court Judges Donald M. Haddock etc. Clerk of Court of the City of Alexandria and all staff Ed Semonian. Commonwealth attorney and all staff to Randy Sengel. Federal Judge Gerald Bruce Lee and all staff. Michael J. Weiser and his staff, Grenadier , Anderson, Starace, Duffett & Keisler, Heather Jenquine and anyone who works for Grenadier et al. Any and all employees of DiMuroGinsber Ben DiMuro, John Tran, Hillary J. Collyer and Ann Schmitt (attorney). 14. All documents in regard to donations of candidates for any and all elected offices in the City of Alexandria by Ilona Ely Freedman Grenadier, Grenadier, Anderson, Starace, Duffett & Keisler including attorneys and staff of Grenadier et al law firm (Charles A. Anderson, Arlene T. Starace, Benton S. Duffett, III, Shirly F. Keisler, Elaine M. Vadas, John T. Winkler II, Lisa L. Levi, Heather N. Jenquine, Carole A. Rubin, Andrew J. Harman, Carrie M. Patterson, Carolyn M. Abbate, Katherine D. Smith, Eric R. Nouri, David Mark Grenadier). 15. All documents and conversations with Michael J. Weiser or his office. 16. All documents in regard to donations of candidates for any and all offices in the City of Alexandria by DiMuroGinsberg and their staff Ben DiMuro, Nina J. Ginsberg, Jonathan R. Mook, John M. Tran, Michael E. Barnsback, Stephen L. Neal, Jr, Hillary J. Collyer, Stacey Rose Harris, Michael S. Lieberman, C. Thomas Hicks III, Sara M. Sakagami, Taylor S. Chapman.
Dated this April 3, 2014 _________________________________ Janice Wolk Grenadier Pro Se 15 West Spring Street Alexandria, Virginia 22301 jwgrenadier@gmail.com 202-368-7178

Certificate of Service I hereby certify that a true and accurate copy of the foregoing document was delivered on April 3, 2014 to Defendants attorney Ben DiMuro at DiMuroGinsberg PC 1101 King Street, Suite 610, Alexandria VA 22314. April 3, 2014 Janice Wolk Grenadier Pro Se
4