You are on page 1of 25


Ilona Heckman a lawyer with Grenadier, Anderson, Starace, Duffitt and Kiesler Individually and As Trustee fo the Ilona Grenadier Heckman Revocable Trust Plaintiff Case No. CL 14-2185 Vs. Janice Wolk Grenadier Defendant RESPONSE TO: Petition to Quash Lis Pendens, for an award of Attorneys Fees and Sanctions and for other Relief And Defendants Request : 1. For the Judges of the Courts of Prince William County to recuse themselves if any conflict of interest / Judicial interest exists. To follow the rules of the Supreme Court of Virginia 17.1 -105(b) that a Judge be requested that does not have a working professional or personal friendship type relationship with Ben DiMuro / DiMuroGinsberg or Ilona Ely Freedman Grenadier Heckman / Grenadier,. Anderson, Starace Duffett and Kiesler.

2. This court should be aware of the following: FBI cautions residents of public corruption in Va. WASHINGTON (WUSA) -- The Federal Bureau of Investigation's (FBI) Washington Field Office is looking to identify any public corruption occurring in Northern Virginia. The FBI says public corruption can occur "when a public official, at any level of government local, state or federal does any official act in exchange for money, or other free goods or services, for private gain. Public corruption could also include public employees who take something of value for their own personal gain, thereby violating the public's trust." The FBI says many of their investigations into public corruption start once they receive a tip from someone. If you want to help identify potential criminal activity, the Washington Field

Office has set up a Northern Virginia Public Corruption Hotline at 703-686-6225 and you can also e-mail them at Some of the examples of corruption include: Government officials such as DMV employees, city inspectors, taxing or zoning assessors or other regulatory agency employees, or even town councils or mayors; Contracting officials at all levels, including those who manage government contracts or regulatory permits; or, school resource officers who manage school accounts; Local officials colluding with real estate investors to rig the bidding process at foreclosure auctions; A person representing the judicial branch - a judge, member of the jury or court personnel; or, A person representing law enforcement, who steals drugs from criminals, embezzles government funds, falsifies records or smuggles contraband 3. Defendant reminds this court that under the Preamble, A Lawyers Responsibilities reads in part:
A lawyers conduct should conform to the requirements or the law, both in professional service to clients and in the lawyers business and personal affairs. A lawyer should use the laws procedures only for legitimate purposes and not to harass or intimidate others. A lawyer should demonstrate respect for the legal system and for those who serve it, including judges, other lawyers and public officials. While it is a lawyers duty to uphold legal process. In the mature of law practice, however, conflicting responsibilities are encountered. Virtually all difficult ethical problems arise from conflict between a lawyers responsibilities to clients, to the legal system and to the lawyers own interest in remaining an upright person while earning a satisfactory living. the legal professions relative autonomy carries with it special responsibilities of selfgovernment. The profession has a responsibility to assure that its regulations are conceived in the public interest and not in furtherance of parochial or self-interested concerns of the bar. Every lawyer is responsible for observance of the Rules of Professional Conduct. A lawyer should also aid in securing their observance by other lawyers. Neglect of these responsibilities compromises the Independence of the profession and the public interest which it serves, Maintaining the Integrity of the Profession Rule 8.3 Reporting Misconduct Is very clear if a lawyer knows of another lawyers illegal actions they are required to report such actions to the appropriate authorities. Rule 8.4 Misconduct: It is professional misconduct for a lawyer to: (a) Violate or attempt ot violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; 2

(b) Commit a criminal or deliberately wrongful act that reflects adversely on the lawyers honesty, trustworthiness or fitness to practice law; (c) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation which reflects adversely on the lawyers fitness to practice law; (d) State or imply an ability to influence improperly or upon irrelevant grounds any tribunal, legislative body, or public official; or (e) Knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.

4. Defendant suggests and will show cause as to why the Lis Pendens could be amended with Plaintiffs portion of the Bristow Road property going into Escrow till a jury trial, Allowing Defendant Due Process by given the legal and appropriate time for Interrogatories, Production of Documents, Admissions, Depositions, and Subpoenas of documents from others. Plaintiff has filed with this Response a COUNTERCLAIM & CROSS BILL OF COMPLAINT FOR DAMAGES SINCE DECEMBER OF 1985 FOR AN OBVIOUS HATE CRIME as well as other Damages.

5. Defendant asks for immediate Sanctions, Cost of Expenses, and other Relief this court may find available to Defendant for the Plaintiff and Plaintiffs attorneys deliberately after being notified that Defendant would need the appropriate time to issue subpoenas to Plaintiff to assure Plaintiffs availability to call to the stand. That Plaintiff filed this suit and informed Defendant 2 days later so Plaintiff would not have the time available to be able to file a subpoena for Plaintiff and others. That Defendant was improperly served by Plaintiff. That Defendant through emails will show she has given notice and made available and offered to release the Bristow Road Property with Plaintiff funds being held in escrow.

JW Grenadier
to Ben, John, Ilona, AEB66, Andrea Mr. Dimuro,

Mar 21 (12 days ago)

As you are aware I will need 10 days to subpoena Ilona to be sure she is at the hearing and available to call and question. Please consider this your notice to advise me with enough time to have her and others subpoena's issued. As I stated earlier - I am available to meet with those when needed to settle this - or to sign any documents necessary for Ilona's funds to go into escrow. Not to be rude or disrespectful but, blunt right back at you - maybe it is time for you and Ilona to do the right thing. You can't change the TRUTH, the documents support the TRUTH. The games ya'll are playing and the things you are saying and doing to try and take people away from the TRUTH, is despicable. The TRUTH is going to come out, and it has been coming out for a long time, and now the FBI is looking into the games being played in the courts in Alexandria and Northern Virginia. You and Ilona may feel you are above the law -(and believe me - I understand why you do and should when the Judges ruling the way they have) but, you and the Judge's aren't above the law. It may seem you own the Virginia State Bar, the JIRC, Grand Jury etc and have all the friends in high places you both need - but, that can also change overnight. When Ilona started having you represent her - one of the many attorneys who have helped me with documents and filing complaints said to me " You are lucky Ilona is a "B" but, Ben is upstanding man he will do the right thing" I have been looking to see that man that a close friend of yours says is there. Mistakes by all have been made - But, the slippery slope is getting recognized and with the mistakes being what they are - a lot of people could pay a very high price for Ilona's greed and illegal actions. Please keep me advised on how you would like to proceed. Warmly, JW Grenadier
Ben Dimuro <> To: "JW Grenadier (" <> Cc: Andrea Moseley <> Wed, Mar 26, 2014 at 4:37 PM

Here are the pleadings petition to quash lis pendens and notice of motion for April 4.
Bernard J. DiMuro DiMuroGinsberg, PC 1101 King Street, Suite 610 Alexandria, Virginia 22314 703.684.4333 703.548.3181 (fax) Not Mot and Pet Quash LP.pdf 4306K

JW Grenadier <> To: Ben Dimuro <>

Wed, Mar 26, 2014 at 4:57 PM

Mr. DiMuro,

I will be requesting an extension of time as to the ignoring that I asked for 10 days to be able to file a subpoena for Ilona to be there and for me to have the right to call her as a witness. The Truth and the remedies for her illegal and criminal actions along with your intentional filing to prevent your client being there and called to the stand. Warmly, jw JW Grenadier
JW Grenadier <> To: Ben Dimuro <> Wed, Mar 26, 2014 at 5:46 PM

Mr. DiMuro, All your documents will not download - I will have to wait till I am served to respond. Warmly, Jw JW Grenadier

6. Defendant will include in this filing the documents that support the illegal actions of Plaintiff as an attorney. These actions as Plaintiff has pointed out in Plaintiffs complaint have been supported by other Judges in the State of Virginia. Which is why the mistake and misleading documents by Plaintiff needs to stop now. That the slippery slope that the Judicial Community being mislead by Plaintiff and Plaintiffs attorneys is in complete violation of the Professional Code of Conduct by the VSB. Judge Kloch in his letter of apology and to recuse himself wrote The appearance of Justice is as important as Justice itself. When a judicial officer acts entirely without jurisdiction or without compliance with jurisdiction requisites he may be held civilly liable for abuse of process even though his act involved a decision made in good faith, that he had jurisdiction. State use of Little v. U.S. Fidelity & Guaranty Co., 217 Miss. 576, 64 Do. 2d 697. Under Va. Code 8.01-271.1 Defendant can show through documents that Defendant has been forced by the Judges to a higher standard than Plaintiff and Plaintiffs attorneys. The perfect example is the e-mail strand above that shows Plaintiff and Plaintiffs attorneys deliberate filing and notification of filing to Defendant. This is not the first or second time this game has been played;. That if this court choses to enforce upon Defendant Plaintiffs request that Defendant must request permission from a Judge to file documents that once again

Defendants fundamental rights as an American Citizen will have been violated by this court, and due process ignored.

7. Defendant will show that the cause of action filing the Lis Pendens with new
information was the appropriate and right thing to do. The slippery slope that would open up the truth of how Defendant 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 . That Plaintiff a lawyer is guilty of the following criminal actions: of being involved in , Perjury, Obstruction of Justice, Aiding and abetting obstruction of Justice, Fraud on the Court, Involvement of Forgery, Theft of money from the Sonia Grenadier Trust account through her law office for great personal gain over $10 Million in Real Estate, Theft of Herman Grenadier, malpractice, Bribery, Abuse of her Oath of Office, Conspiracy, Collusion, Miscarriage of Justice, preventing Due Process, conflict of interest related to the practice of law, violating code of ethics, has liability to her victims, has violated Plaintiffs Religious, Political, United state Constitutional, Virginia Constitutional and Civil Rights, Breach of Fiduciary Duties, RULES OF PROFESSIONAL CONDUCT, Title 18 US code 241 Conspiracy against rights, and 242 Deprivation of rights under color of law, Retaliatory & Retribution actions, Treason, Title VI Civil Rights Act of 1964 Title VI, 42 U.S.C. 2000d et seq., was enacted as part of the landmark Civil Rights Act of 1964, 18 USC 912. With her Intention to 18 USC 1341 -Frauds and swindles, Defraud, Breach of Contract, Arbitrary and Capricious behavior, Committed Fraud on the Court, 18.2-498.3. Misrepresentations prohibited, 18.2-172 - Forging, uttering, etc., other writings et al. All of above charges will be proven with letters, documents, witnesses who have also been harmed by the actions of Plaintiff.

8. Defendant will show that she has been denied Due Process - complains against
the Plaintiff in defendants COUNTERCLAIM & CROSS BILL OF COMPLAINT to

seek relief for the violation of Federal and Constitutional rights under Title 42 1983, and under the Bill of Rights the Four Basic Freedoms are being Violated:

1. 2. 3. 4.

Freedom of speech Freedom of worship Freedom from want Freedom from fear

9. Defendant will show the right to Re-open her divorce which never had a property settlement due to Fraud by Plaintiff and David Grenadier. Which Plaintiff as a Divorce attorney should know the law. Plaintiff failed to mention the version of a property settlement and separation Plaintiff as an attorney had done which Defendant refused to sign which was a conflict of interest by Plaintiff as an attorney. 10. . Plaintiff failed to mention or include Plaintiffs Intervene into the recently opened divorce procedures, once again not telling the TRUTH, purposely misleading this court as Defendant will show this is common practice of Plaintiff and Plaintiffs attorneys lying in documents and misleading the court from the TRUTH. 11. Defendant in the Counterclaim / Cross Complaint evidence will show that Plaintiffs professional by appearance also includes corruption in her cases. Defendant will call witnesses of the abuse and over charge from her law firm. Plaintiffs quote about how lawyers decided when to settle a case was We look at how much money there is for legal fees, when that is used up, we settle 12. Defendant will show this involves a Hate Crime by Plaintiff which some e-mails included Plaintiffs attorney calling the Pope a Wonker and other intimidating statements in regard to the Defendant being Catholic. Two of the most recent which involves Plaintiffs friend Loretta Lax Miller running for President of the United States of America in 2016 (a Federal Law suit in the District of Columbia has been filed and is on appeal)

The Parties

The Victims of Defendant: 2. SONIA & Herman GRENADIER Mother to the late Albert Grenadier, Grandmother to David Grenadier, Great Grandmother to Plaintiffs girls, Aunt to Jerry Heckman. Victim to Ilona & her Law Firm - Malicious Manipulation, Involvement in Forgery on a Trust Addendum, Stealing of Trust Funds, Real Estate, Garden at King David, Herman Grenadiers body moved at King David by Ilona Grenadier 3. Judge Albert Grenadier died without a will or did he?

4. Ruth Grenadier Subitzky - Sister to Albert, daughter to Sonia & Herman Grenadier, married to Sy Subitzky 4 children (Amy, Scotty, Neil, Maida ) Defendant will show Plaintiff was involved in the theft and cover up of inheritance to Ruth and her family.

5. Janice Wolk Grenadier (Defendant) and her girls - Married David Grenadier under the illusion of love and manipulation. Mentally abused by David with the help of Plaintiff. The evidence will show the collusion of the two of them till just recently even forging a car title of Defendants to sell the car. Plaintiff will show that she put more money into GIC a Real Estate partnership than David did, which is a part of the opening of the Divorce in 2000 for a property settlement. That the law is very clear and that Plaintiff has broken the law as an attorney, acting as an attorney for Defendant in several situation as well as manipulating Defendant to lie on Plaintiffs behalf. Defendant will show that the Truth only started coming out in 2008 and is believed to have most of the pieces to the puzzle of the deception and manipulative actions that were and are still willful acts that are malicious, violent, oppressive, fraudulent, wanton, or grossly reckless of Plaintiff.

The Truth The Facts

1. On or around November 30, 1983 Plaintiff was involved in the forging of the Sonia Grenadier Trust Addendum giving Plaintiff Power of Attorney should anything happen to Albert Grenadier. 2. In March of 1985 Albert Grenadier dies. 3. On or around May 20, 1985 Jim Arthur informs Sonia Grenadier about the Trust and her will 4. On or around July 23, 1985 GIC is established between Plaintiff and David Grenadier 5. Soon after July 23, 1985 by all appearance and evidence the Stealing of funds from the Sonia Grenadier Trust begin by Plaintiff a lawyer or the Grenadier et al law firm for the personal benefit of Plaintiff

6. On or around December 9, 1985 a letter with the Grenadier et al letter head is written for the benefit of Sonia Grenadier establishing the relationship between the Grenadier et al law firm 7. On or around December 6, 1985 Official letter written to Plaintiff from Jim Arthur that the Addendum is forged and not enforceable with the collusion of Jim Arthur Plaintiff and her law firm continues to control Sonia Grenadier Trust 8. On or around February 14, 1986 (new evidence recently learned) Plaintiff took a property called Bristow Road and put it in Plaintiffs name along with Alberts sister Ruth Subitzkys name. Claiming Plaintiff put Ruths name on such property out of the goodness of Plaintiffs heart. Which reviewing the title and documents in Prince William County it is in conflict with the evidence that this property was ever taken legally out of the Trust that was established after the death of Herman Grenadier. By all appearance Plaintiff knowingly used the forged Trust addendum to transact this theft of by appearance and documents from land records That an accounting needs to be done to established where funds that were by appearance received in 1986 went for a part of the sale of this land. If more money was stolen at this time by the Plaintiff and or Grenadier et al law firm. By appearance this started out as 500+ acres with disbursement of sale at 3 different times

1. August 1983 of $81,000 2. October 4, 1984 of $200,000. 3. February 1986 of $521,063.50. Leaving the approx. 193 acres that are being sold at this time. 9. On or around March 18, 1986 Plaintiff an attorney knowing the Addendum is forged by all appearance donates Herman Grenadiers Garden at King David and by all appearance steals Herman Grenadiers body and moves it to a Garden Plaintiff claims to own. Plaintiff told Defendant that Plaintiff used the Garden donated on Plaintiffs tax return as a donation. (this is all new evidence that came out around July of 2011) Plaintiff wrote to the children of Ruth Subitzky who is buried with her brother, father, and mother that a stranger was in her garden that Plaintiff claims to have never given permission to be buried. Not only did Plaintiff an attorney steal Ruths father from his resting place, Plaintiff an attorney stole his Garden donating it and by appearance taking it as a personal tax deduction. King David show Plaintiffs signature and claims Plaintiff used a Trust agreement to sign for and for the actions above. Plaintiff then went on to file a false report with the State of Virginia on or around January or February of 2012 after knowing that she had signed the appropriate documents for Ruth Subitzky her sister-in-law to be buried with her family. Plaintiffs relationship with Ruth was also as a client and Ruth paid for Plaintiffs services. By all appearance Plaintiff met with Ruths children in or around April of 2011 and hinted to an issue, but waited till the statute of limitations of 3 years to turn over any files that Plaintiff had on Ruth to the family could be enforced. These acts and other actions of Plaintiff have been willful acts that were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless

10. On or around December of 1986 with Defendant not being aware of the manipulative personality of Plaintiff and Plaintiffs son gets into a partnership called 28 E. Bellefonte Ave. Defendant is deceived in loaning GIC $3,600. (aka David Grenadier). Which with the money by all appearance received from the manipulation and sale of part of the Bristow Rd. property in February of 1986 this loan and the extra funds in renovation Plaintiff paid should be considered Fraud by the Plaintiff. Plaintiff was well aware Defendant was receiving a $30.000. settlement check at this time. Plaintiff manipulated as much of that money as Plaintiff could to her benefit is now clear with this new evidence. 11. On or around August 24, 2987 Jim Arthur at the request of Plaintiff sends letter to Sonia Grenadier to start selling off property that she owns by all appearance this would give Plaintiff and or her law firm more funds to steal from.

12. On or around the fall of 1989 Sonia Grenadier starts requesting an accounting of her funds. 13. On or around October 30, 1989 Plaintiff / GIC purchased a property called Southway Terrace in Triangle Va for approx. $2.9 million dollars (approx. 80 condo units). This was purchased with no money down and Plaintiff/ GIC walking away with approx. $40,000 after settlement costs. The property at the time appraised for $3.2 million. The Plaintiff / GIC was offered $100,000 to flip the contracts and declined. Plaintiff / GIC (David) were present at all walk thrus and inspections. In 2007 Tax assessments Southway was valued at $8,537,200. 14. On or around March 2, 1990 Jim Arthur sends letter to David Grenadier / Grenadier Investment Co. revoking authority to act as agent in matters for the Sonia Grenadier Trust. This is to include Plaintiff. 15. The manipulation and the intimidation and willful acts that were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless against Defendant go into full force by Plaintiff. Plaintiff is aware and knows more than Plaintiff lets on and is able to manipulate Plaintiff knowing Defendant is pregnant and is emotionally still scared by a miscarriage at 5 months in April of 1989. That Plaintiff was raped in college and understands Justice after sitting through a trial by Jury with her rapiest going to jail for 6 years. That Plaintiff was sensitive to the word rape and the outcome of it. Plaintiff would say to Defendant if you dont do this you could be visiting your husband and taking your children to see him the day after he had been raped Plaintiff knew how to control Defendant, and manipulate Defendant, because of Defendants strong family values. 16. That Plaintiff was upset about the letter written on or around December 9, 1985 to a car dealer ship on Plaintiffs law firm stationary establishing the relationship of Plaintiff and her law firm with the Sonia Grenadier Trust. 17. That Plaintiff sent Defendant by all appearance to represent her law firm in the accounting of funds stolen through her law firm to Jim Aruthur at Fagelson et al law firm. 18. That Defendant at this time found $54,000 approx. possible $65,000 missing yet Plaintiff tells Jim Arthur around much less.


19. That Plaintiff on or around July 5, 2014 went into labor delivering her fist little girl at 4.45 pm on July 6, 2014 in an emergency C-section with a room full of Children heart specialist from Georgetown. That Plaintiff was dealing with the life of her first child after losing one at 5 months in April of 1989. Plaintiff calls Defendant at approx. 9.00 am on the morning of July 7, 1990 prior to Plaintiff knowing the outcome of her daughters heart issue and her daughter still in intensive care unit. Tells Defendant I have come up with a solution to the theft of funds Defendant will need to sign over $30,000. Commission and in return David will sign a Not to Defendant for 10% interest and due in 30 Years again If you do not agree to this and I am not able to negotiate this deal than you and A will be visiting him in jail as that is where Robin wants to see him, you will be visiting him most likely after he had been raped the night before Defendant agreed. Plaintiff never asked how A was. Plaintiff at this point established a Client relationship with Defendant, that has now been reviled with all the new evidence since May of 2008 was to protect Plaintiff and Plaintiffs law firm. 20. On or around November 14, 1990 Plaintiff informs Defendant Plaintiff is working out a settlement of $40,000 stolen - $8,000 in interest to be paid back to the Sonia Grenadier Trust. (Plaintiff from Defendants accounting at this point is aware that much more was stolen from the Sonia Grenadier Trust new evidence shows from Plaintiffs accounting and Yoav Katz accounting most likely $95.000 or more was stolen out of the Sonia Grenadier Trust by Plaintiff an attorney and through her law firm.) That this will be paid back by Defendant $30,000. (with a note in return which Plaintiff will do, and the Defendant must give up client of land due to privacy of this matter needed) That David Grenadier will then sign a note for $18,000. The Truth now know and as the facts have exposed themselves these acts by Plaintiff with deliberate and manipulative willful acts that were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless. 21. On or around November of 1991 the property called Holland Road went to settlement with the $30,,000 commission being assigned to the Jim Arthur for Sonia Grenadier Trust. Negotiated by Plaintiff acting as Defendants attorney Plaintiff creating the note for the $30,000. Insisting on keeping all copies for the safety of it. Defendant losing a client that Defendant needed. These acts by Plaintiff as an attorney were deliberate and manipulative willful acts that were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless. 22. On November 6, 1991 Defendant had her second C-section and delivered her second little girl M. with no let up on of the manipulation by Plaintiff as an attorney whose actions were deliberate and manipulative willful acts that were and are

ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless to protect herself and only her. 23. Shortly after the birth of M Defendant takes girls ( A is approximately 19 months and M is about 2 months) to visit Sonia Grenadier great grandmother. D uring visit Sonia trips on a toy Defendant is told by Plaintiff that Robin is accusing Defendant of trying to kill Sonia and she is no longer allowed by the family to have any type of relationship with Sonia Sonia Grenadier died never seeing her gr eat grand daughters again. Defendant believes this was partially a lie by Plaintiff to protect Plaintiff from the whole Truth coming out. 24. On or around January 23, 1992 a letter from Jim Arthur now with Mays and Valentine outlines the negotiated settlement to prevent legal action. This settlement was 100% negotiated by Plaintiff as an attorney for David Grenadier in reality the evidence now shows Plaintiff was acting in only Plaintiffs self-interest. 25. On or around October 21, 1992 in a refinance funds from 28 E. Bellefonte were taken from Defendant to pay down a loan for Southway Terrace that benefitted only Plaintiff. David Elsberg attorney for the settlement had Plaintiff write a letter detailing where the funds were going and that it was a loan to GIC. 26. On or around October 20, 1993 Jim Arthur goes to jail for what Plaintiff has done for 5 years. 27. On or around May 25, 1994 James Korman of Bean, Kinney & Korman negotiates a new settlement with Plaintiff acting as Davids attorney. In letter mentioning the $30,000. Paid by Defendant. 28. On or around November 17, 1997 Plaintiff using an attorney not licensed to do business in Virginia does a Liquidation Agreement for GIC. Plaintiff a divorce attorney is well aware of the fact that Defendant has co-mingled more funds than her husband David Grenadier had personally put into the partnership. Plaintiff again through manipulation and lies knowing divorce is looming that her son is about to leave Plaintiff has David sign such agreement. Partnership Liquidation Agreement did not hold up to the law when 28 E. Bellefonte Ave was sold. Plaintiffs actions again were for personal gain and willful acts. 29. In the fall of November 1998 Plaintiff in a letter dated May 2008 shows collusion in a rumor that was being spread that David Grenadier was sleeping with his sister


Andrea. Due to this David pulled a gun in Defendants home with Defendants girls in the home. 30. In or around 2001/2002 Plaintiff manipulate Federal Bankruptcy by lying again about the money that was borrowed by Plaintiff / GIC to purchase Southway Terrace in the refinance of property 28 E. Bellefonte. Again actions that were deliberate and manipulative willful acts that were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless to protect herself and only her. Which now constitutes the reopening of Defendants divorce the Fraud that has been since 1986 against Defendant by Plaintiff that with the new evidence is obvious to a lay person. 31. On or around September 12, 2007 Plaintiff lied in court which resulted in the Filing of the Motion for Default filed on September 21, 2007. 32. On or around Mary of 2008 Judge Donald M. Haddock Defendant learned in the Spring of 2008 he had recused himself from hearing the case. When he informed Defendant You will never get a fair trial we LOVE ILONA then went on to choose Judges to rule for Ilona. 33. Sometime in December of 2007 ~ Defendant spoke with Diane Fiske Several times about a Fair Judge Defendant was mislead by Judges Chambers that 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): Defendant Learned of this in 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.

34. On or around February 8, 2008 ~letter from Plaintiff (on her law firm stationary) to Defendant , Plaintiff asserts ownership of 75% of a property Known as 28 East Bellefonte Ave, Alexandria, VA 22305. Defendant also felt threatened by the letter which is full of misleading and deceitful statements.

35. On or around February 27, 2008 ~ Plaintiff lied in filings with the Circuit Court of The City of Alexandria in 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 Plaintiffs statements in the Answer to The Amended Bill of Complaint were disingenuous which Defendant has supplied documentation to VSB for the purpose of establishing the truth. The following are the lies Plaintiff Filed with the Circuit Court of Alexandria 1. 75% ownership 2. That defendant has provided no proof of actual payment for expenses ~ provided 3 times to Plaintiff 3. Defendants Bankruptcy caused by Bellefonte as Defendant in & out ~ Which now Defendant realizes Defendant would never had been in and out if it wasnt for the manipulation and lies of Plaintiff an attorney. 4. The document on Februaary 27, 2008 by Plaintiff 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 Plaintiff which had several conflicting statements. The amount of money Plaintiff put into the property can be established by an accounting done by Plaintiff. 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 Plaintiff had. Plaintiff 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. The pleadings by Plaintiff an attorney were all lies. 36. On or around March 5, 2008 defendant Files 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 Plaintiff and Counterclaim and Cross-Complaint filed on February 27, 2008. 3. For the letters Plaintiff sent bulling, threatening attached to the February Response to Ilona Ely Grenadier/GIC Motion to Quash Plaintiffs Amended Complaint / From February 8, 2008. 4. For the non response to letters to try and set a new date for depositions or to set a trial date.


37. On or around May 7, 2008 Motions heard by Judge Brown This is the turning point of the case and the Truth coming out of Plaintiffs lies and manipulations Plaintiff after court informs Defendant after Judge Brown has ruled in Plaintiffs favor allowing Plaintiff to lie in documents, to file false papers as an attorney in the Alexandria Circuit Court of law Plaintiff informs Defendant What good friends Plaintiff and Judge Brown are and how Judge Brown called her all the time for legal advice. Again this could be true or it could be just one more way Plaintiff tried to intimidate Defendant. 9 On or around May 7, 2008 After Court ~ 1. Plaintiff an attorney again brags about relationship with the Judges ~ That Plaintiff has in the past & continues to give Free legal advice to Judge Brown. 2. Plaintiff explains to Defendant why Plaintiff and no one in her family has anything do to with Defendants children it is because Defendant is Catholic and raised them Catholic. In 19 years she has seen the girls once by her choice. That in 23 years Plaintiff has seen granddaughters maybe 3 times by Plaintiffs chose. 3. Plaintiff then explains to Defendant that Defendant should be grateful to her for the listing on a property called Holland Road. Which Plaintiff to protect herself & her law firm manipulated the commission to pay back money stolen from the Sonia Grenadier Trust over $95,000 with a forged Trust agreement, that Plaintiff was involved with the forgery

4. Plaintiff then goes on to rub into Defendants face how Plaintiff had manipulated Plaintiff into believing it was David who stole the money from the Sonia Grenadiers Trust ~ which only left Plaintiff and her law firm to steal over $95,000.00 38. On or aroung June 18, 2008 defendant Files: 1. Motion for Default ~ Plaintiff has lied in the Admissions A. For Plaintiff lying in court to Judge Kloch on September 12, 2007 ~ Motion for Default B. For Motion for Default filed in February for Lying in the Answer to Bill of Complaint by defendant and Counter claim and Cross Complaint C. For lies in Admissions D. For the letters Plaintiff sent Bulling & Threatening Defendant if Defendant didnt drop suit. 2. Motion for Trial by Jury Due to comments made by Judge Haddock & Plaintiff

A. Judge Haddock telling Defendant she could never get a fair trial as they all LOVE Ilona B. Ilona informing Defendant all the Judges were friends of Plaintiff & Plaintiff gave them free legal advice when they called Plaintiff 39. In the later part of 2008 2009 Defendant reached out to Karen, Andrea, Robin Grenadier and the family of Ruth Grenadier to apologize and inform them of the TRUTH of what Plaintiff an attorney had stolen from the Sonia Grenadier Trust. Through the Grenadier et al law firm. After Plaintiff informed Defendant that Defendant should be grateful to Plaintiff for Plaintiff giving Defendant the listing on the property called Holland Road it started to became clear to Defendant the manipulation and the lies and collusion of Plaintiff and Defendants x-husband David Grenadier to steal, lie, cheat and that the collusion now is clear that it started back in October of 1986 and has continued through this case. That Plaintiff will be able to show through pay stubs, through financial statements and accountings done by Plaintiff that it was with her knowledge this money was stolen out of her law firm. That trying to silence Defendant is about the TRUTH of the Money, Real Estate and other things stolen from the Sonia Grenadier Trust The facts The accountings cannot be changed. Ilona Grenadier / Plaintiff / Lawyer / has been misleading and manipulating family members, lawyers, judges since the death of Judge Albert Grenadier. 40. On or around February 9, 2009 an e-mail from Andrea Grenadier:
Thanks, Janice! Interesting point about only inheriting a few thousand from dad. Ilona had re-written dad's will, as you know, after she had promised him that she would "take care of" his children. Of course, we all found out what "take care of" meant to her! The several thousand dollars we inherited wasn't actually that much -- it was from an insurance policy that dad had, and it was about $1,200. She was incredibly pissed when she found out that she had missed that, because she wanted everything. Dad's former secretary, Agnes Wilkes, knew that there was an earlier will, and so did Jack Duvall. Ilona said they were both lying. My grandfather's mistake was in trusting too much, and not putting his property in a bypass trust. But when he died, my parents were splitting up, and there was no reason to believe that dad would marry someone like Ilona. My grandfather would have been highly distressed to know that someone stole his grandchildren's inheritance, but this doesn't seem to bother Ilona, who has constantly lied to me, and told me there wasn't anything. Love, A

41. On or around April 16, 2009 Threatening Letter from Ben DiMuro charging Defendant with acts of Extortion.

42. On or around April 29, 2009 ~ Virginia Bar Complaint #2 (Written with the help of a lawyer who teaches ethics for the VSB) With the first Complaint Ilona had broken the Ethics rule on Knowingly Filing false information with the courts, making false statements in Court, recording documents along with Admissions statements that were disingenuous, and lying in Court. She now had broken the Ethics Rule 1.16 (d) and (e) by refusing to give me the NOTE that she as my lawyer had written and had insisted on being the only one to hold on to it. I attached much evidence on this complaint of Ilona being very disingenuous. With all her statements she made and how she mislead all the other attorneys with the truth of the amount of funds that were stolen from the Sonia Grenadier Trust. I have also shown how she personally financially benefited from all of these actions, my millions of dollars in Real Estate. *** These complaints by my understanding from Mr. Edward L. Davis have been combined and looked at together. ***My feelings are from his letter he doesnt even understand the complaints nor is he looking at the evidence that has been provided to show that Ilona is lying. 43. On or around January 20, 2011 ~ Plaintiff Appeals to Supreme Court ~ Record # 110156 44. On or around February 2, 2011 ~ Letter Ben Dimuro Give notice file dismiss of Petition for Appeal

45. On or around February 3, 2011 ~ Respondents Joint Motion to Dismiss Petition for Appeal Due to Plaintiff not filing Statement of Facts ~ Ben DiMuro and Michael Wieser attorneys lie in documents to the Supreme Court of Virginia 46. On or around February 8, 2011 Petitioners Response to Respondents Joint Motion to Dismiss Petition For Appeal on Page 2 Respondents state Petitioners state Petitioner failed to ensure that the record contains either a transcript or a written statement of facts necessary to permit resolution of appellate issues is fatal to her appeal. Accordingly, the Petition should be dismissed for Petitioners non compliance with rule 5:11 Petitioner filed Court Statement of Facts for October 13, 2010 & October 20, 2010 Order o Made a part of Record in accordance to Supreme Court Rule 5:11 (c) (1) and (2).


47. On or around November 21, 2011 Supreme Court Letter ~ Judge Potter from Prince William County to sit on Grand Jury of February 13, 2011 There is one matter, In Re: Grand Jury Request of Janice Wolk Grenadier, scheduled that the Judges have recused themselves from hearing.

48. On or around November 21, 2011 Order from the Supreme Court for Judge Potter to assist Alexandria Circuit Court 49. In the month of November of 2011 Plaintiff Calls Records in Alexandria to learn ~ There is no Police report # for the Extortion investigation brought on by Randy Sengel commonwealths attorney which there is a letter from Ben DiMuro April 16, 2009 charging Plaintiff with acts of Extortion. JWG believes there to be Collusion between Randy Sengel ~ Ben DiMuro to assist Plaintiff in intimidation of Defendant.

50. On or around January 4, 2012 Letter from Meghan S. Roberts threatening Plaintiff with with legal action over $200. For infractions of code a gutter & RV parked in Plaintiffs driveway. By all appearance in Collusion with Randy Sengel in attempt to intimidate Defendant for Plaintiff.

51. On or around February 13, 2012 Kidnapping of JW in court room 4 from the Grand Jury Final Order by Judge Richard Potter ~ Denied in front of the Grand Jury he and Randy Sengel Commonwealth Attorney are now the Gate Keepers of the Grand Jury

52. On or around March 9, 2012 Rick @ Neal R. Gross & Co., Inc informs Plaintiff she cant get access to transcripts without permission from Clerk of Court Lucy S. Plaintiff then has to Fax Neal R Gross copy of Appeal. 53. City of Alexandria in collusion to intimidate Defendant files suit against Defendant again to take focus of the issue of the criminal actions of Plaintiff an attorney.. 54. On or around September 26, 2012 Plaintiff and Plaintiffs attorneys show Orders by a Judge that did not have Jurisdiction and this can be proven by attorneys own affidavits that show more phone calls to Judges chambers than to clients. This is

Michael Weiser and John Tran. Plaintiff and plaintiffs attorneys once again wish to cover up the truth and mislead the courts. 55. In the December / January time frame of 2012 & 2013 Plaintiff in collusion with others as a favor or hired a gentleman that goes by the name of Mark Stuart who informs Defendant he was to drug Defendant and get sexual inappropriate pictures of defendant or to rape one of Defendants daughters or to plant drugs on defendants daughter or in home to give Circuit Court Judges information to make Defendant incompetent to file any other documents. Mr. Stuart said the Plaintiff will go to any length to harm Defendant or Defendants daughters. That she will continue to do what she can to distract Defendant from becoming successful and moving on with Defendants life. That Plaintiff is greedy. That all Plaintiffs actions are deliberate to cause harm to Defendant. When the Alexandria Police were called they informed Defendant they were instructed by Commonwealth Attorney Randy Sengel to not take any reports of issue. 56. On or around May 16, 2013 Defendant requested a car that she had purchased and was in the name of Defendants daughter returned or the right to pick it up. Plaintiff in collusion with David Grenadier tried to intimidate and dare Plaintiff to report them to the police for by all appearance forging documents with the DMV to get a title and sell the car. 57. On or around July 16, 2013 Plaintiff in collusion with Andrea and Robin/Racheal Grenadier the day after Defendants father dies again attacks Defendant in e-mails which re-enforces the hate of Catholics that Plaintiff her and family have. Plaintiff again trying to distract from Plaintiffs criminal actions. This is most likely in regard to the fact that the law by an attorney was pointed out to Plaintiff that she owns 24.5% of all properties GIC has as funds were co-mingled and Plaintiff used an attorney not licensed in Virginia for the Liquidation Agreement and Defendant never signed off. 58. On or around July 12, 2013 after learning of the conflicts and disingenuous behavior of Plaintiff in Defendants Forced Bankruptcy. Defendant revisited all the evidence and filed to re-open her Divorce as no property settlement had been done. That Plaintiff an attorney had written one that was not signed that was only a benefit to Plaintiff. As an attorney Plaintiff acted again willfully to protect herself and for personal financial gain. 59. The law leaves little question that Fraud in procuring a settlement agreement can justify setting aside the agreement and judgment. Which there was none. E.g., In re

Marriage of Modnick, 33 Cal. 3d 897, 191 Cal. Rptr. 629 (1983); Compton v. Compton, 101 Idaho 328, 612 P.2d 1175 (1980); Anderson v. Anderson, 399 N.E.2d 391 (Ind. Ct. App. 1979); Daffin v. Daffin, 567 S.W.2d 672 (Mo. 1978). Fraud in procuring a settlement can also be the basis for an independent tort action. Hall v. Hall, 455 So. 2d 813 (Ala. 1984); In re Benge, 151 Ariz. 219, 726 P.2d 1088 (Ct. App. 1986); Dale v. Dale, 66 Cal. App. 4th 1172, 78 Cal. Rptr. 2d 513 (1998); Den v. Den, 222 A.2d 647 (D.C. 1966); Oehme v. Oehme, 10 Kan. App. 2d 73, 691 P.2d 1325 (1984); Burris v. Burris, 904 S.W.2d 564 (Mo. 1995); Carney v. Wohl, 785 S.W.2d 630 (Mo. Ct. App. 1990); Hess v. Hess, 397 Pa. Super. 395, 580 A.2d 357 (1990). See also Vickery v. Vickery, 1996 WL 255755 (Tex. Ct. App., December 5, 1996) (wife awarded $9 million against husband for fraudulently procuring divorce and marital settlement agreement, and $450,000 against husbands attorney), affirmed over dissent in light of Schleuter v. Schleuter, 975 S.W.2d 584 (Tex. 1998), Vickery v. Vickery, 999 S.W.2d 342 (Tex. 1999). See generally, Robert G. Spector, Marital Torts: The Current Legal Landscape, 33 Fam. L. Q. 745, 757 (1999); Cary L. Cheifetz, The Future of Matrimonial Torts: The Unmapped Landscape, 15 Fair$hare 4 (August 1995). The courts are especially harsh with spouses that commit fraud who are attorneys. Anderson v. Anderson, 399 N.E.2d 391 (Ind. Ct. App. 1979); Scholler v. Scholler, 10 Ohio St. 2d 98, 462 N.E.2d 158 (1984); Webb v. Webb, 16 Va. App. 486, 431 S.E.2d 55 (1993). 60. Plaintiff in all actions has made herself a party to this divorce Thus, where a spouse and another person act in concert for the common purpose of defrauding the other spouse, an action for conspiracy will lie. Conspiracy was also accepted in Dale v. Dale, 66 Cal. App. 4th 1172, 78 Cal. Rptr. 2d 513 (1998), where the wife sued for breach of fiduciary duty, fraud, constructive fraud, intentional and negligent misrepresentation, conversion, conspiracy, fraudulent conveyance, constructive trust, and declaratory relief. In this case, the wife claimed that after the husband was served with divorce papers, he and his bookkeeper withhold from billing patients, withheld monies received as payments to the accounts receivable, falsified ledgers, financial statements, and income tax returns, and otherwise acted in concert to artificially reduce the value of the husbands medical practice. The California appellate court upheld the wifes claims. Accord Liles v. Liles, 289 Ark. 159, 711 S.W.2d 447 (1986) (wife awarded damages for husbands attorneys fraud and misrepresentation in wifes suit to set aside property settlement agreement); Carney v. Wohl, 785 S.W.2d 630 (Mo. Ct. App. 1990) (upholding wifes claim of fraudulent misrepresentation against husband and husbands father); Vickery v. Vickery, 1996 WL 255755 (Tex. Ct. App., December 5, 1996) (wife awarded $9 million against husband for fraudulently procuring divorce and marital settlement agreement, and $450,000 against


husbands attorney), affirmed over dissent, Vickery v. Vickery, 999 S.W.2d 342 (Tex. 1999). 61. Another possible avenue for recovery against a spouse and a third party for economic fraud is the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-64 (Supp. 1999). Claims under RICO in the divorce context are also scarce, but not unheard of. The strongest RICO case is Perlberger v. Perlberger, 1998 WL 76310, 1998.EPA.1313 (E.D. Pa. February 24, 1998). In this case, a woman filed a civil RICO claim against her ex-husband, his law practice associates, and his accountants for allegedly participating in a fraudulent scheme to conceal his true income during the divorce action. According to the wife, the fraudulent scheme began in 1986 when the husband decided to divorce the wife. He devised a scheme whereby he would initiate an extra-marital affair for the purpose of shielding his assets and income from scrutiny during divorce. The husband, an attorney, began an affair with a client, and purchased a home in her name. He then left his law firm and instead of using his own assets (a capital account the former firm owed him), he used his girlfriends assets to establish a credit line for a new firm. He was then able to argue that his new firm was not a marital asset. He also paid his girlfriend an inflated salary, and had another attorney, Rothenberg, hold all the assets to the new firm. The court stated: Here, Plaintiffs RICO claim is based on Defendants alleged mail and wire fraud. Although the alleged fraudulent scheme perpetrated by the Defendants may be accurately described as garden variety fraud, such a characterization is not fatal to Plaintiffs RICO claim under the current state of the law. Defendants next argue that they have not found any cases in Pennsylvania in which civil RICO has been used to attack a divorce decree, child support order, or alimony award. (Accountant Defs. Mot. at 3.) Although the Court also has not found any such Pennsylvania cases, the Court has found a number of Federal cases where courts have entertained civil RICO claims relating to family law matters. E.g., Grimmett v. Brown, 75 F.3d 506 (9th Cir. 1996); Calcasieu Marine Nat. Bank v. Grant, 943 F.2d 1453 (5th Cir. 1991). With Tabas as guidance and with the decisions of other courts in mind, the Court will not dismiss Plaintiffs RICO claim on policy grounds. Perlberger represents a small but growing handful of cases where a spouse asserts civil RICO in the divorce context. See Smith v. Johnson, 173 F.3d 430 (6th Cir. 1999) (unpublished table decision); DeMauro v. DeMauro, 115 F.3d 94 (1st Cir. 1997); Grimmett v. Brown, 75 F.3d 506 (9th Cir. 1996); Calcasieu Marine National Bank v. Grant, 943 F.2d 1453 (5th Cir. 1991); Evans v. Dale, 896 F.2d 975 (5th Cir. 1990); DuBroff v. DuBroff, 833 F.2d 557 (5th Cir. 1987); Dibbs v. Gonsalves, 921 F. Supp. 44 (D.P.R. 1996); Reynolds v. Condon, 908 F. Supp. 1494 (N.D. Iowa 1995); Streck v. Peters, 855 F. Supp. 1156 (D. Haw. 1994); Hibbard v. Benjamin, No. 90-1-361-WF, 1992 WL 300838 (D. Mass. Sept. 21, 1992); Capasso v. Cigna Insurance Co., 765 F. Supp. 839 (S.D.N.Y. 1991).

62. On or around September 4, 2013 Plaintiff filed a Motion to Intervene into Defendants divorce again for willfully for personal protection from the illegal actions to date of Plaintiff that have been willful acts. 63. On or around September 11, 2013 Defendant responds to Plaintiffs Motion to Intervene. 64. On or around December 24, 2013 Plaintiff and Loretta Miller aka (Leah Lax Miller, Muggy Cat and Billy Sullivan) in collusion attack Defendant for being Catholic. The following is just one of many e-mails and a blog which is riddled with lies again to harm Defendant and Defendants children and distract Defendant and all from the TURTH.

From: <> To:

Tue, Dec 24, 2013 at 2:05 PM

want to hear something more scarier I contacted Ilona Ely Freedman Grenadier Heckman your witch hunt is over <>
you know what YOU DIDN"T HELP JEWS

Tue, Dec 24, 2013 at 10:39 AM






That Leah Lax et al made a fool of the FBI With this e-mail strand attached under The Amended Verified Complaint field in the United States District Court For the District of Columbia The following Exhibits that are attached include the Letters and E-mails that back all the information above and more included in this Response of the Criminal Actions of Plaintiff against Defendants Exhibit s: 1. United States District Court for the District of Columbia Amended Verified Complaint Collusion ofPlaintiffs Hate crime against Catholics 2. The information on the Property Bristow Road 3. Documents regarding Defendants Divorce Plaintiffs Intervene, Defendants Response, the information the Car 4. E-mails Robin Grenadier sent the day after Defendants Father died there are more of these that show the Hate 5. The collusion of Plaintiff in misleading the Federal Bankruptcy Court by Plaintiff 6. Letter showing the money was a loan to 28 E. Bellefonte with the settlement on October 21, 2014 7. Information on the GIC properties 8. A partial accounting that was done on or around September 20, 2012 and submitted into evidence in court of what Plaintiff owed Defendant at that time. This will need to be revised with all the new evidence from that time.

This case needs to be heard with a Jury Trial as requested in Counterclaim and Cross Complaint filed on April 3, 2014. That Defendant and this court should need more discovery done to actually determine the ownership of the 22.5 % that Plaintiff claims to own. That by the appearance of the title information it is questionable about Plaintiffs right due to the apparent use of a forged Addendum. Plaintiffs continue behavior as a lawyer which should hold her to a higher standard has been ignored by the courts to date. That the Lis Pendens with the manipulation of Defendant by Plaintiff in the

repayment of money stolen out of Plaintiffs law firm, with Plaintiffs knowledge by all appearance should first go to re-paying note that Plaintiff refuses to turn over to defendant. That Plaintiff has clearly benefited financially, has not been held accountable for Plaintiffs actions that are similar if not the same as Jim Arthurs who went to jail for 5 years, and from all of Plaintiffs other questionable actions. That settlement should be allowed to go forward and Defendant agrees to sign documents releasing this one property and Plaintiffs funds should be escrowed as was discussed at one point in an e-mail with other owners. Dated this April 3, 2014 ________________________ Janice Wolk Grenadier Pro Se 15 West Spring Street Alexandria, Virginia 22301 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