VIRGINIA:

CITY OF ALEXANDRIA CIRCUIT COURT

Janice Wolk Grenadier (JWG) CASE NO.

Plaintiff / Pro Se COMPLAINT FOR:

v. 1. INTENTIONAL FRAUDLENT TRANSFER AND

REVCOVERY OF MONEY AND REAL ESTATE
Divorce Lawyer Ilona Ely Freedman 2. CONSTRUCTIVE FRAUDULENT TRANSFER
Grenadier Heckman (IEG) OF REAL ESTATE
AKA TRUSTEE TO GIC
GRENADIER INVESTMENT 3. CONVERSION
Defendant 4. COLLUSION

5. MALISCIOUS PROSECUTION, OBSTRUCTION

OF JUSTICE

6. ALTER EGO

7. VIOLATIONS OF THE CIVIL RIGHTS ACT OF

1871 (42 USC 1983. 1985, 1986)

8. RACKETEERING AND CORRUPT

ORGANIZATIONS ACT OF 1970 ( 18 USC
1962)

9. LIBAL AND SLANDER

10. FALSE IMPRISIMENT

11. TURNOVER OF PROPERTY SOLD / AND OR

STILL COLLECTING RENTS AS TRUSTEE

12. FRAUD ON THE COURT BY LAWYERS AND

JUDGES

COMPLAINT AGAINST DIVORCE LAWYER ILONA ELY FREEDMAN GRENADIER

HECKMAN FOR $20 MILLION PLUS OWED JANICE WOLK GRENADIER AND OWNERSHIP
OF AT LEAST 24.5 % OF THE 49% OF GRENADIER INVESTMENT (GIC), MONROE AVE
PARTNERSHIP, SOUTHWAY TERRACE FOR FRAUD ON THE COURT AND KNOWLEDGABEL
FRAUD WITH INTENT TO HARM BY DIVORCE LAWYER ILONA GRENADIER AND HER STEP
SON DAVID MARK GRENADIER FROM ON OR AROUND DECEMBER OF 1986
AND DAUGHTER ERIKA ELY FREEDMAN LEWIS ON OR AROUND NOVEMBER 1987

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 COMES NOW PLANTIFF Janice Wolk Grenadier (JWG) reserves the right to amend Complain
and add additional Parties. Plaintiff Janice Wolk Grenadier complains against the captioned Defendant as
follows: to seek relief for the violation of Federal and Constitutional rights under Title 42 U.S Code
1981 &1983, Title 18 U.S. Code 241 & 242 and under the Bill of Rights the Four Basic Freedoms are
being Violated:
1. Freedom of speech
2. Freedom of worship
3. Freedom from want
4. Freedom from fear

That Plaintiff looks in this Court to RETURN TO HER PROPERTY AND MONEY that has been stolen
/ converted in an enterprise business by Ilona Grenadier, David Grenadier and Erika Ely Grenadier Lewis
et al. for personal financial gain, as well as a sick personal joy in torturing Catholics and other Christians
to feed her HATE of Catholics.

That Plaintiff incorporates the following cases as reference in evidence of the criminal collusion that
Divorce Lawyer Ilona Grenadier Heckman through FRIENDSHIP PERSONAL FINANCIAL GAIN
colluded in a mafia style :

Date Court Case No. Description

October 5, 1999 City of Alexandria CH99-1253 Divorce Janice Wolk Grenadier

David Grenadier Divorce Granted with no
Property Settlement agreement
April 20, 2001 City of Alexandria CH01 - 0654 The Money owed for the Bellefonte Partnership
10-11-2011 City of Alexandria M011001482 Grand Jury
10-20-2011 USDC of Virginia 1:11-cv-01136
GBL - JFA
01-31-2014 USDC of District 1:14-cv-00162 LLM Loretta Lax Miller
of Columbia
07-29-2013 USDC of District 1;13-cv-01152 Spring Street
of Columbia UNA
07-02-2014 USDC of Virginia 1:14-cv-00827 Spring Street Stayed as of September 29, 2016 in
LMB-TCB the 4th Circuit under an En Banc accepted
04-30-2014 City of Alexandria CL 1400 - 2193 Lis Pendens
03-13-014 Prince William CL 1400 2185 Lis Pendens
County & 1400 2185-
01
09-15-2015 City of Alexandria CL1500 - 3661 Illegally brought suit for Legal fees that were
gotten through FRAUD ON THE COURT
11-12-2015 USDC of Virginia 1:15-cv- 01497 Rico & Racketeering Stayed as of September 29,
GBL - IDD 2016 the 4th Circuit under an En Banc accepted

FROM HER BY DIVORCE LAWYER ILONA ELY FREEDMAN GRENADIER HECKMAN.

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 That since 2007 Plaintiff to her face from Judges or representatives of the Judges have
said to Plaintiff You cannot win this we LOVE Ilona, (Chief Judge Donald Haddock) (Ilona Grenadier
Heckman founding partner of Grenadier, Anderson, Starace, Duffet&Keisler PC is who Judge Haddock
LOVES) Me and My family cannot get a fair trial either, you cannot win this you are no longer one of
them (x-wife of Judge Donald Kent best friend to Judge Donald Haddock) The Dockets shows it would
at times take the Judges in the City of Alexandria over 2 months to find a Judge who would rule in
favor of Ilona an attorney lying in court, lying in court documents, theft of funds through her law firm the
Sonia Grenadier Trust and Plaintiff and her girls, bullying and threatening Plaintiff, involved in forgery,
hate of Catholics / Christians, gang like activity mirror imaging the Klue Klux Klan, Not once has
Plaintiff lost because she does not have the Law on her side, it is because of discrimination religious /
social / economic / hierarchy by the Defendants to protect one of their own.
Further Claims are outlined in this complaint.
DEMAND TRIAL BY JURY

INTRODUCTION

1. COMES NOW that on September 12, 2007 Ilona Grenadier Heckman a lawyer founding
partner of Grenadier, Anderson, Starace, Buffett& Keiser PC, widow to Judge Albert
Grenadier of the City of Alexandria and his 1st cousin Jerome Heckman, founding partner
of Keller Heckman an International law firm LIED IN COURT.

2. The Slippery Slope of the Judicial Misconduct, Criminal Misconduct, and

Discrimination for Religious, Social, Economic and Hierarchy, the Gang type
behavior similar to the Kul Klux Klan the Collusion of the Defendants began to
cover up the Lies, the attempt to harm Plaintiff and her girls American Born
Citizens through drugs and rape, to Slander Plaintiff, to prevent Due Process. The
purpose of the Old Boys Network and the Judiciary is to prevent one of their own Ilona
Grenadier Heckman from being held accountable for:

3. Perjury Va , 18.2-434 Obstruction of Justice, 18.2-460, Aiding and abetting

obstruction of Justice, 4.1-323, Fraud on the Court, 8.01-428, Involvement of Forgery
18.2-172, Theft of money from the Sonia Grenadier Trust account through her law office for
great personal gain over $10 Million in Real Estate 18.2-95, Theft of Herman Grenadier,
joint and several liability, malpractice, Bribery 18.2-447, Abuse of her Oath of Office,
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 Conspiracy 18.2-22, Collusion, Gang like activity 18.2-46.1, mirror image to the Klue
Klux Klan, Miscarriage of Justice, preventing Due Process- VA constitution and US Constitution,
conflict of interest related to the practice of law, violating code of ethics, has liability to her
victims, has violated Plaintiffs Religious, Political, Social, United state Constitutional, Virginia
Constitutional and Civil Rights, Breach of Fiduciary Duties, Violating 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 - Judicial Misconduct; Criminal
Misconduct; Mail Fraud; Honest Serves Fraud; Extortion; Harassment; Gang activity;
Racketeering; Retaliation; Discrimination; et al. not limited to: decisions made in bad faith for a
corrupt purpose, deliberately and intentionally failing to follow the law; Extrinsic fraud; Egregious
legal errors; Violation of Procedural Rules; Violation of Due Process; uttering, etc., other writings
et al. All of above charges will and can be proven with letters, documents, witnesses who
have also been harmed by the actions of Plaintiff.

4. This case started out a domestic issue, T0DAY THIS IS AN AMERICAN ISSUE, the
right of access to the courts to a pro se litigant without having their life threatened
and being Jailed by the Collusion, Racketeering of the Judicial Community. That
the Judicial Community polices itself, that Plaintiff has gone through all channels for help,
to be turned away. The Judicial Community has created a smoke and mirrors of
Immunity that they have tried to force on the American people, to believe that they are
above the law and cannot be held responsible for their actions in the court room. This is
untrue. That the immunity is lost for actions that are for personnel gain, that are willful
acts that are and were malicious, violent, oppressive, fraudulent, wanton and grossly
reckless. That Discrimination is color blind that there is discrimination for social,
economic and hierarch that exists in the Judicial Community to protect one of their own.
Those cases across this Great Country Judges and the Judicial Community are being
held accountable for their actions as Judges going to jail for Obstruction of Justice et al.

5. "Pro se plaintiffs are often unfamiliar with the formalities of pleading requirements.
Recognizing this, the Supreme Court has instructed the district courts to construe pro se
complaints liberally and to apply a more flexible standard in determining the sufficiency of
a pro se complaint than they would in reviewing a pleading submitted by counsel. See
e.g., Hughes v. Rowe, 449 U.S. 5, 9-10, 101 S.Ct. 173, 175-76, 66 L.Ed.2d 163 (1980)

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(per curiam); Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 595-96, 30 L.Ed.2d
652 (1972) (per curiam); see also Elliott v. Bronson, 872 F.2d 20, 21 (2d Cir.1989) (per
curiam). In order to justify the dismissal of a pro se complaint, it must be " 'beyond
doubt that the plaintiff can prove no set of facts in support of his claim which
would entitle him to relief.' " Haines v. Kerner, 404 U.S. at 521, 92 S.Ct. at 594
(quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)).

PARTIES
6. PLANTIFF JANICE WOLK GRENADIER (Janice) (JWG) Citizen, Born in the United
States of America giving her the rights as defined by the United States of America
Constitution, the Bill of Rights, The Laws and Rules of the Supreme Court. THE BASIC
RIGHT TO A FAIR TRIAL WITH OUT A BIAS JUDGE. Was illegally jailed and warfare
tortured used for two purposes prevent e-mails between Senator Mark Warner and herself
being exposed in regard to the corruption and for the cover up of the criminal actions of
Divorce Lawyer Ilona Grenadier Heckman, Erika Ely Lewis and David Mark Grenadier. The
Victim of a scheme by IEG to further line her pockets financially with the conversion / theft of
Real Estate and Money in an enterprise fashion no different than how a mafia boss stole. .

7. DEFENDANT ILONA GRENADIER HECKMAN (Ilona) Experienced a Divorce

Lawyer since 1967. Acted as lawyer to Janice Wolk Grenadier, manipulating money and Real
Estate from JWG and others. Widow to Judge Albert Grenadier and Jerome Heckman
Alberts 1st cousin. That the evidence and documents will show as a lawyer through her law
firm stole money, real estate and Herman Grenadiers body from his grave. Will further show
through evidence her believe that she is above the law and HATES Catholics, with the help
of the Judiciary, Government and Elected Officials because of whom she has been married to,
and men that are in LOVE with her that will Cover Up her criminal schemes, acts and
actions is above the law to date. The evidence will show a criminal spree since on or around
November of 1983 with the forging of Sonia Grenadier (mother to Judge Albert Grenadier and
Aunt to Jerome Heckman) on an Amended Trustee Agreement.

GENERAL ALLEGATIONS

9. . The use of rule 1:1 is unreasonable and inappropriate for denying Plaintiff a Property
Settlement. There is little question that fraud in procuring a settlement agreement can justify
setting aside the agreement and judgment. 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).

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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.

10. That even though David Grenadier is not a lawyer he worked in collusion with
Ilona Grenadier Heckman his mother a Divorce attorney with over 40 years
experience 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). That Ilona Grenadier Heckman who Intervened into the Divorce
is a Divorce attorney, who has in collusion with David Grenadier created a smoke
and mirrors that properties were not owned by Plaintiff. The Truth and the facts
are Plaintiff from around October 1986 worked as a partner and put money into the
properties without being paid back for her time or financial investment.
11. The concealment of marital assets during the divorce proceeding has also given rise to tort
actions. Swain v. Swain, 576 N.E.2d 1281 (Ind. Ct. App. 1991); Garrity v. Garrity, 399
Mass. 367, 504 N.E.2d 617 (1987). But see Beers v. Beers, 724 So. 2d 109 (Fla. 5th DCA
1998); Nederlander v. Nederlander, 205 Mich. App. 123, 517 N.W.2d 768 (1994); Smith
v. Smith, 113 N.C. app. 410, 438 S.E.2d 457 (1994); Schleuter v. Schleuter, 975 S.W.2d
584 (Tex. 1998); Gardner v. Gardner, 175 Wis. 2d 420, 499 N.W.2d 266 (Ct. App. 1993).
That Divorce attorney Ilona Grenadier Heckman with knowledgeable intend to
defraud Plaintiff used an attorney not licensed in Virginia to do a Liquidation
Agreement. That Divorce Lawyer Ilona Grenadier Heckman knew that Plaintiff
needed to sign such agreement.

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 12. That Ilona and David have hid the documents from loans and Real Estate from
Plaintiff to conspire against Plaintiff. This is and was a civil conspiracy and Civil
RICO. That on or around March of 2016 Janice learned that Judge James Clark
had a financial standing in all the loans through Burke & Herbert Bank. Judge
Clark once this was disclosed to him lied several times in regard to his relationship
and conspired with the others to make Janice homeless. That the actions of Burke
& Herbert and their collusion with Ilona dates to July 1997 by all appearance when
Taylor Burke was sanctioned by the FDIC for reckless behavior et al.

Civil Conspiracy

13. As acceptance of economic torts becomes more prevalent, plaintiffs have been casting the
net wider to sue not only offending spouse but also those who aided the offending spouse
in the fraud. One possible avenue of recovery is civil conspiracy. Key to this cause of
action is a defendants substantial assistance in a plan to defraud, with the knowledge that
such assistance is contributing to a common tortious plan. Thus, the doctrine is reserved
for application to facts which manifest a common plan to commit a tortious act where the
participants know of the plan and its purpose and take affirmative steps to encourage the
achievement of the result.
14. A case to allow a claim against an ex-spouse and a third party for fraud is Brown v.
Managed Care, Inc., No. M1999-02551-COA-R3-CV (Tennessee Court of Appeals,
February 1, 2000) (unreported). In this case, the divorced mother of a minor child claimed
that her former husband and his employer conspired to fraudulently understate the
husbands income, in order to defeat her attempts to have his child support obligation
increased to an appropriate amount. The trial court granted summary judgment to the
defendants, and the appellate court reversed. The court first reiterated the elements of
conspiracy:
15. Our courts have recognized a cause of action for a civil conspiracy to defraud. The Court
described the elements of the tort and what it takes to prove it in the following manner: A
conspiracy to defraud on the part of two or more persons means a common purpose,
supported by a concerted action to defraud, that each has the intent to do it, and that it is
common to each of them, and that each has the understanding that the other has that
purpose. The agreement need not be formal, the understanding may be a tacit one, and it is
not essential that each conspirator have knowledge of the details of the conspiracy.

(Citations omitted.) See also Restatement (Second) of Torts 876(b) (1977) (a person may be liable in tort
if he knows that the ... conduct [of another person] constitutes a breach of duty and gives substantial
assistance or encouragement to the other so to conduct himself.).

16. The court then concluded that the divorced mother stated a cause of action:
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If we take the allegations of the plaintiffs to be true (as we are obligated to do when reviewing a summary
judgment motion), then the defendants conspired to understate Mr. Barenkamps income from the very
moment his employment with Birman & Associates began. The acts performed in furtherance of the
conspiracy included the issuance of payroll checks to Kathy Barenkamp and of bonus checks to William
Barenkamp, as well as attempts to throw Charlotte Brown off the track when she called Birman &
Associates to confirm the circumstances of William Barenkamps employment. But all these acts would
be of no avail if Mr. Barenkamp had testified truthfully as to his income. We are unwilling to hold that the
very act required to consummate the fraud also had the effect of immunizing the defendants from liability
for it.

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.

17. 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).
18. That when Divorce Lawyer Ilona Grenadier Heckman Intervened into the Divorce
in order to protect her interests in properties, it became clear the actions of Ilona &
David were and are actions that were knowledgeable actions since October of
1986 to defraud Plaintiff.

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19. 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.
20. 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:

21. 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.

22. 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.
23. 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).

24. That no property settlement when many parcels of Real Estate were owned and
that the Defendant falsified his ownership in Bankruptcy court with the collusion of
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 Divorce Lawyer Ilona Grenadier Heckman. That the claim in Bankruptcy court was
that with no Property Settlement all Real Estate unless otherwise stated was
marital Property. Since there was no Property Settlement and Plaintiff had taken
an active role in management of Real Estate owned by GIC / Monroe Ave /
Southway Terrace then that should be considered 50 50 as 28 East Bellefonte
was even when the Deed read 50 50. That the collusion of Mother & Son whom
also created a Fraud through the Mothers Law Firm Grenadier Law et al with the
theft of over $95,000 from the Sonia Grenadier Trust. That the Scheme left
Plaintiff without properties that depending on how the accounting and notes are
counted put over $100,000 in cash towards GIC / Monroe Ave / Southway
Terrace. That there is no question that the documents, letters from Mother /
Lawyer Ilona Grenadier Heckman shows the expected involvement in properties
by Plaintiff.

25. That Mother and son were aware of and tried to hide from Plaintiff the part of the
enterprise that was rightfully hers. This was and will be demonstrated in the Loan
documents with Plaintiffs signature and that the Properties were held in Trust
by Divorce lawyer Ilona Grenadier Heckman who with knowledgeable intend to
cover up who had an interest in the properties signed most documents as Trustee.
The collusion / enterprise was with the intend to defraud and manipulate Plaintiff
as she had done with Sonia Grenadier.
26. That when Divorce Attorney Ilona Ely Freedman Grenadier Heckman at the time of
the divorce had 30 years experience and today has over 50 years knew the law
and did not Intervene to insure that there was a property settlement to protect her
interests yet since that time she has bullied, lied in court, lied in court
documents, lied in Bankruptcy court ( in or around the same time of divorce 1999 /
2000 time frame) involved with her attorneys at lying in court, lying in court
documents to the Supreme Court of Virginia. All Ilonas actions were with the
knowledgably intend inclusion of David to defraud Plaintiff.
27. That Rule 1:1 is not enforceable under the Due Process when the appearance of
an inequitable Judgment But, here we dont have an inequitable judgment we
have no Property Settlement along with statements of the Defendants attorney

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 that without a Property Settlement the property of 28 East Bellefonte should be
considered Marital property and that should be split 50/ 50 ignoring the how the
Deed is worded. This statement in the Bankruptcy Court was supported by Divorce
attorney Ilona Grenadier Heckman who has intervened into this case to further
defraud Plaintiff of her rights to Properties that should be included in a property
settlement. The properties include where owned at the time of the Separation and
the illegal Liquidation Agreement done between David Grenadier and Ilona
Grenadier to defraud Plaintiff of her rightful ownership due to her financial and
management work of properties which letters and other documents will show:

1. Sonia Grenadier Trust

1. Note $ 30,000.00 /10% Interest / Due in 30 years $602,318.57 26 years $ 403,768.33
(Prevented Plaintiff from losing her Law License and going to
Jail as Jim Arthur did 1993. 1990 due in 2020

2. Clients which Defendant loss due to the Note(10% int) $2,471,940.78

Plaintiff demanded acting as Defendants lawyer that she
Had to give up her client the very min cost to that was
The listings for the new homes (todays value with interest)

2. Real Estate
1. Bellefonte Ave Personal ownership 50% (10% int w/out my GIC 24.5%) $ 504,003.25
2. GIC Properties at least 24.5% $3,000.000.00
(accounting of sales, rents, depreciation etc needed) TBD
Properties located in the City of Alexandria zip codes 22301, 22305, 22314

1623 Francis Hammond 224 Guthrie Ave

16 West Bellefonte Ave 322 E. Hume Ave
44 East Taylor Run Pkwy 710 Four Mile Rd
1813 Leslie Ave 707 Four Mile Rd
54 East Taylor Run Pkwy 713 Four Mile Rd
61 East Taylor Run Pkwy 715 Four Mile Rd
33 South Gordon 628 Notaene Dr
2943 Sycamore Ave 636 Notabene Dr
2945 Sycamore Ave 638 Notabene Dr
415 East Delray Ave

3. Southway / Southampton Terrace at least 24.5 % $3,100,000.00

( an accounting for rents, depreciation, income etc needed) TBD
The apartments have Rental income of approx. $75.000 monthly
2014 Market Value $12.3 million Rental Inc. mthly PP $ 2,940,000
4. 404 E Monroe Ave at least 24.5% $ 500,000.00
(an accounting for rents income, etc) TBD
2014 Market Value $2,4 million Rental Inc. mthly $ 16,000 PP 400.000.
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 nd
5. Real Estate 2 Trust TBD
3. Bankruptcy Defendant would not have been in so is owed legal fees and expenses

1. Legal Fees $ 319,613.81

2. Expenses / Damages TBD

4.Stolen Car May 2013 David and Ilona sold car w/out Title or copy Title TBD

** Note numbers are approximate and some funds represent the equity in the other properties so the
real numbers cannot be established till after the information from the Subpoenas.

28. Further this is an ongoing Fraud by Divorce lawyer Ilona Grenadier Heckman
with the recent Sale of a Property called Bristow Road that she again signed
as Trustee, yet she had stolen from Sonia Grenadier the mother of Judge
Albert Grenadier.
29. The memorandum Further goes on to say When reviewing a trial courts
decision on appeal, we view the evidence in the light of the most favorable
to the prevailing party granting it the benefit of reasonable inferences The
Prevailing Party never went to court or filed a Brief with this court.
Favoritism and Cronyism was used in the back room decision making by a Judge
who did not have Jurisdiction. Statement is bias and shows the possible
discrimination of the court by ignoring the facts and the basis for an appeal.
30. The case was decided in a back room by Judge Clark who does not have personal
Jurisdiction. That Defendant has filed a suit in United States District Court For the District
of Columbia that he is a defendant in for:
VERIFIED COMPLAINT / CONSPIRACY
NOT A DOMESTIC PROBLEM AN AMERICAN PROBLEM
TREASON BY JUDGES, LAWYERS, ELECTED OFFICIALS, GOVERNMENT EMPLOYEES, STATE
EMPLOYEES
TO INTERFERE WITH CIVIL RIGHTS Title 18 U.S. Code 241 & 242; Title 42 U.S. Code 1981 & 1983
ILLEGEAL ACTIONS - Attempt to harm Plaintiff and her Girls through DRUGS, RAPE & SLANDER of Plaintiff to
prevent Due Process, Judicial Misconduct, Criminal Misconduct, Discrimination for Religious, Social, Economic,
Hierarch, Gang Type Behavior Similar to the Klue Klux Klan, , Tampering with Evidence, Mail Fraud, Violating the
Law and the Rules of the Supreme courts, Violation of the Judicial Cannons, Obstruction of Justice, Fraud on the
Court,

31. Judge Clark has lost subject-matter jurisdiction do to his financial standing as
Trustee on loans and the new evidence showing the collusion of Burke and
Herbert Bank (he states he does everything with them for Friendship with no
12
 Financial Gain not only is that disturbing it is a lie & territorial jurisdiction but not
personal Jurisdiction. Judge Clark took the place of Judge Donald Haddock (Best
friend Judge Donald Kent who works with the Virginia Legislator as to which
Judges are approved) in January of 2012 as by all appearance as a Thank you to
Judge Haddock he refused to hear motions appropriately put on the docket. The
motions pertained to a Direct order from Supreme Court Justice Cynthia Kinser
whom had chosen Judge Potter from Prince William County to assure and assist
the appearance of Defendant and her witness in front of the Grand Jury to ask for
a Special Grand Jury to look into the discrepancy in Defendants case. Judge
Haddock had stated in Court he was afraid that Plaintiff would be talking about him
and his actions in the Grand Jury.

32. That Judge Clark has been asked to recuse himself since the appearance of
recusing himself in January of 2012. The Circuit Court Judges of Alexandria
recused themselves in the case of Julian Dawkins due to the relationship of Judge
Dawkins, they have now recused themselves in the Charles Severence case due
to the relationship of Ruth Ann Ladto being the daughter of Judge Giammitorio and
the brother of Judge Bob Giammittorio. Yet they are hearing this case and
imposing irrational and unfair Orders against Plaintiff. David Grenadier is the son
of Judge Albert Grenadier and Ilona Grenadier Heckman the widow of Judge
Albert Grenadiers.

33. That the letter written with an apology by Judge Kloch states The appearance of
Justice is just as important as Justice itself.
34. In October of 2012 Judge Clark refused to recuse himself and awarded legal fees
riddled with ex parte communications in signed affidavit. He has allowed and
supported attorneys lying in court, lying in court documents. That in October of
2012 documents that had been appropriately filed in the courts backing everything
Defendant has said were held in Judges Chambers for 2 weeks. The documents
when Defendant went to check on her file were not in the file and when Defendant
asked where they were a representative from Judges chambers came down and
said take them or we will throw them out. On October 13, 2012 Defendant

13
 received her documents along with an Order signed by Judge Clark, Judge Kemler
who had recused herself in September of 2007 then formally in October of 2011,
Judge Dawkins who should have recused himself in the past formally recused
himself in October 2011 but, both Judges signed the Order dated October 12,
2012 that reads Defendant is not allowed to file in the Circuit Court any documents
pertaining to CHO10654 without permission, for only that case. Defendant still has
the box of evidence unopened to be opened in front of a Jury.
35. The City of Alexandria then to intimidate Defendant further filed charges
against Janice for a gutter hanging from the earth quake and for allowing a friend
to park an RV in her drive way which was totally legal. That Ben DiMuro in
collusion with Commonwealth Attorney RandySengel used Detective Pax of
the City of Alexandria police to intimidate Janice with Extortion charges
which she proved she was retaliation and retribution for telling the Truth and was
owed the money.

36. In March of 2011 when JWG was on Travel the police, fire, ambulance came to
15 W. Spring St. to break down the door luckily Defendants neighbors were
home and were allowed to use a key to let them in. Defendant was supposed to
be dead in the home? Several neighbors can attest to this. There is no police, fire
or ambulance report on this. When that didnt work to intimidate and scare JWG
off, December of 2012 Mark/Michael Stuart as a friend of Ilonas was hired to
drug Janice and get inappropriate pictures or to rape one of the girls or to plant
drugs on one of the girls or in their home.

37. When that didnt work December of 2013 Ilonas BFF Loretta Lax Miller aka
Muggy Cat aka Billy Sullivan presidential candidate for 2016 in collusion sent this
e-mail and started a blog riddled with lies about Janice. This e-mail states Ilonas
hate feelings about JWG being Catholic: Me and My family had nothing to do with
you and your girls because you raised them Catholic direct quote from Ilona in
May of 2008. There are several other Hate emails from the Ilona Grenadier
GANG which are actions similar to the Klu Klux Klan.

14
38. That Ilona Grenadier Heckman a professional Divorce Lawyer and founding partner of Grenadier
Starace Duffett & Kiesler practicing Divorce law for over 50 years knew what she was doing when
she used Neil Gurvitch a lawyer not licensed in Virginia to do a Liquidation agreement that needed
Janice Wolk Grenadiers signature for the substantial amount of money that Janice Wolk
Grenadier put into the properties owned during the marriage of David Grenadier & Janice Wolk
Grenadier. Ilona Grenadier at several points during the marriage acted as an attorney for Janice
or David and even wanting to control and have things her way wrote a property settlement. That
Janice was manipulated with knowledgably intend to harm by David and Ilona.

39. It is now known the marriage was a scheme to defraud. It was admitted David
never loved Janice and Janice was just right for the picture and David never
wanted children. The knowledgeable intend to defraud was always there, but the
evidence and truth of the extend did not come out until the talk of the Sale of
11713 Bristow Road, Manassas Va. April of 2014. The property sold by all
appearance with a cloud on the Title, which makes this a continuing Fraud from on
or around February 14, 1986 when Ilona Grenadier knowingly started with her lies
to defraud Janice. That Ilona admitted it was not David who stole the money which
only left her to have stolen it from the Sonia Grenadier Trust.
15
 40. That a Divorce Attorney with Knowledgeable intend to defraud and at her finger
tips Judges with Chief Judge Haddocks declaration You cannot get a fair trial,
we LOVE Ilona in 2008 after he had chosen Judges that were his and Ilonas
close friends. That Judge Clarks orders are and should be VOID due to
discrimination, unfairness, bias, prejudice and retaliation and retribution for
telling of the TRUTH which in America should be your best defense.

Plaintiffs have been discriminated against and treated with unfairness, bias and prejudice by this Court
and the opposing counsel. An uninterested, lay person, would question the partiality and neutrality of this
Court. 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) No man in this country is so high that he is above the law. No officer of the law
may set that law at defiance with impunity. All the officers of the government from the highest to the
lowest, are creatures of the law, and are bound to obey it. Butz v. Economou, 98 S.Ct. 2894 (1978);
United States v. Lee, 106 U.S. at 220, 1 S.Ct. at 261 (1882) Further it is the obligation of every Judge
to honor, abide by, and uphold not only the Constitution and laws of the State, but they are bound by the
laws and Constitution of the United States as well. State courts, like federal courts, have a
constitutional obligation to safeguard personal liberties and to uphold federal law. Stone v Powell, 428
US 465, 483 n 35, 96 S. Ct 3037, 49 L Ed. 2d 1067 (1976) 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)

41. Further the appearance is Fraud on the court by Lawyers and Judges
Whenever any officer of the court commits fraud during a proceeding in the court, he/she
is engaged in fraud upon the court. In Bulloch v. United States, 763 F.2d 1115, 1121
(10th Cir. 1985), the court stated Fraud upon the court is fraud which is directed to the
judicial machinery itself and is not fraud between the parties or fraudulent documents,
false statements or perjury. It is where the court or a member is corrupted or influenced
or influence is attempted or where the judge has not performed his judicial function thus
where the impartial functions of the court have been directly corrupted.

42. Fraud upon the court has been defined by the 7th Circuit Court of Appeals to embrace
that species of fraud which does, or attempts to, defile the court itself, or is a fraud
perpetrated by officers of the court so that the judicial machinery cannot perform in the
usual manner its impartial task of adjudging cases that are presented for adjudication.
16
 Kenner v. C.I.R., 387 F.3d 689 (1968); 7 Moores Federal Practice, 2d ed., p. 512,
60.23. The 7th Circuit further stated a decision produced by fraud upon the court is
not in essence a decision at all, and never becomes final.

43. Further the Memorandum goes on to say A pro se litigant appearing is no

less bound by the rules of procedure and substantive law then a defendant
represented by counsel Plaintiff has followed the Rules as the docket shows.
It is the Defendants whom have ignored the rules and the Laws of the Virginia
Supreme Court, of the United States Constitution and the Virginia Constitution.
This statement is bias and slanderous to the Plaintiff.
44. That Judge Clark did not have Jurisdiction in his Order of October 3, 2013. That
Judge Clark is tainted per his actions as is the other Judges in the Circuit Court of
Alexandria against Appellant. That Judge Clark has ignored his Oath of Office,
Cannons of Judicial conduct for the State of Virginia and Rules of Professional
Conduct of the Virginia State Bar since being sworn in by all appearance a Pay
Back for votes for him to tally more votes than the other applicants for position as
Judge in the Circuit Court of Alexandria.
45. The Facts are very clear in the documents filed and the appropriate fees Paid or
allowed through IFP:

1. On or around June 26, 2013 through e-mail and phone messages Plaintiff tried to contact Defendants
lawyer and was ignored that Plaintiff was re-opening divorce for Fraud.
2. On or around July 12, 2013 Subpoena was filed in the COA Clerks office w/cert of service to Defendants
3. On or around July 15, 2013 Yoav Katz / Katz & Co. was properly served w/cert of service to Defendants
4. On or around July 16, 2013 an Affidavit of service was filed in COA w/ cert of service to Defendants
5. On or around Aug 19, 2013 a Motion to Compel was filed in the COA w/cert of service to Defendants
6. On or around Aug 19, 2013 Plaintiff filed for Production of Documents
7. On or around Aug 26, 2013 Defendant decided to Respond approx. 60 days later
8. On or around Sept 5, 2013 Defendants mother ( Ilona Ely Freedman Grenadier Heckman widow of
the late Judge Albert Grenadier and a lawyer/Founding Partner of Grenadier, Anderson, Starace,
Duffett & Kiesler in the City of Alexandria. Represented as a Lawyer in the Washingtonian as a Big
Player with the Old Boys Network. Intervened into the case and Scheme of the Judges to protect
the LOVE that Judge Haddock (whom Judge Clark took his place) the slippery slope restarted.

46. The Defendant ignored with his lawyer all opportunities to object to the
Reopening of the Divorce, the Subpoena or to point out any deficiencies.
The City of Alexandrias clerks office questioned Plaintiff, reviewed all documents
prior to stamping them in, the Clerks confirmed Plaintiff had the right to file in her
Divorce case. The Clerks office after what was around hour of waiting prior to
being able to file, believes the Clerks office conferred with the Judges chambers..

17
 47. The dockets for the Divorce case have been altered and doctored.
48. The law is very clear a pro se litigant is to be given equal treatment if not
special treatment, especially in a case where the intervening Person is a
lawyer and has the financial ability to bring in as many powerful
unscrupulous lawyers to defend her criminal actions.

"Pro se plaintiffs are often unfamiliar with the formalities of pleading requirements. Recognizing this,
the Supreme Court has instructed the district courts to construe pro se complaints liberally and to
apply a more flexible standard in determining the sufficiency of a pro se complaint than they would
in reviewing a pleading submitted by counsel. See e.g., Hughes v. Rowe, 449 U.S. 5, 9-10, 101 S.Ct.
173, 175-76, 66 L.Ed.2d 163 (1980) (per curiam); Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct.
594, 595-96, 30 L.Ed.2d 652 (1972) (per curiam); see also Elliott v. Bronson, 872 F.2d 20, 21 (2d
Cir.1989) (per curiam). In order to justify the dismissal of a pro se complaint, it must be " 'beyond
doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to
relief.' " Haines v. Kerner, 404 U.S. at 521, 92 S.Ct. at 594 (quoting Conley v. Gibson, 355 U.S. 41,
45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). 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) No officer of the law may set that law at defiance with impunity. All the
officers of the government from the highest to the lowest, are creatures of the law, and are bound to obey it. Butz
v. Economou, 98 S.Ct. 2894 (1978); United States v. Lee, 106 U.S. at 220, 1 S.Ct. at 261 (1882) Further it is the
obligation of every Judge to honor, abide by, and uphold not only the Constitution and laws of the State, but they
are bound by the laws and Constitution of the United States as well. State courts, like federal courts, have a
constitutional obligation to safeguard personal liberties and to uphold federal law. Stone v Powell, 428 US 465,
483 n 35, 96 S. Ct 3037, 49 L Ed. 2d 1067 (1976)

This is being restated because it is important that court recognizes the discrepancies in the
Circuit Court of Alexandria in Fairness to the Plaintiff.

FIRST CLAIM FOR RELIEF

INTENTIONAL FRAUDLENT TRANSFER AND REVCOVERY OF MONEY
AND REAL ESTATE THROUGH Perjury Va , 18.2-434 Obstruction of
Justice, 18.2-460, Aiding and abetting obstruction of Justice, 4.1-323,
Fraud on the Court, 8.01-428, Involvement of Forgery 18.2-172,

49. Incorporated into this is all of the above.

50. The evidence is well documented which often you have to rely on circumstantial evidence
of fraud. To prove actual intent, the courts have developed badges of fraud, which, while
not conclusive, are considered by the courts as circumstantial evidence of fraud:[citation
needed]

18
 Becoming insolvent because of the transfer;
Lack or inadequacy of consideration;
Family, or insider relationship among parties;
The retention of possession, benefits or use of property in question;
The existence of the threat of litigation;
The financial situation of the debtor at the time of transfer or after transfer;
The existence or a cumulative effect of a series of transactions after the onset of debtors financial
difficulties;
The general chronology of events;
The secrecy of the transaction in question; and
Deviation from the usual method or course of business.

That the documents meet the above requirements of FRAUD by Divorce lawyer Ilona Grenadier et al

SECOND CLAIM FOR RELIEF

CONSTRUCTIVE FRAUDULENT TRANSFER OF REAL ESTATE
THROUGH TRUSTEE AGREEMENT SIGNED WITHOUT JANICE
WOLK GRENADIERS NAME, FRAUDLENT LIQUDATION
AGREEMENT, Perjury Va , 18.2-434 Obstruction of Justice, 18.2-
460, Aiding and abetting obstruction of Justice, 4.1-323, Fraud on the
Court, 8.01-428, Involvement of Forgery 18.2-172 ET AL
COLLOUSION OF BURKE & HERBERT BANK ET AL,

51. Incorporated into this is all of the above.

52. That the Sale of Real Estate in the Chapter 7 was done by Fraud on the Court by Reed
Smith. That the collusion with Ilona Grenadier was to harm me, and leave me and my girls
financially unstable she found willing partners in lawyers that were forced on Janice by the
courts.

53. That inefficient council / overpaid council can be proven that each and every lawyer know
or should have known I had to have a Property Settlement with my divorce.

54. That Burke and Herbert, Ilona Grenadier and others knew the Liquidation Agreement
would not hold up in court as is shown in the Bellefonte Property Deed when Ilona signed
as if under duress for signing and stating after her signature she should not have to sign due
to the Liquidation Agreement.

55. The Liquidation agreement was signed after Divorce Lawyer Ilona Grenadier and x-
husband David Grenadier had by all appearance hired a Hitman and pulled a gun in the
home. That Ilona had given David in or around June of 1997 the advice to move into the
basement do things for the kids, none of Janices laundry, or allow her to eat what he had
cooked to start the separation. The Liquidation agreement was signed in November of
1997, when killing me didnt work.

19
56. Ilona would then in December aa a lawyer write up a separation agreement and a property
settlement that she wanted me to sign I refused and no property settlement was ever
done.
THIRD CLAIM FOR RELIEF
CONVERSION

57. Incorporated into this is all of the above.

58. That Janice never legally gave up her property rights. Divorce Lawyer Ilona Grenadier
Heckman in a pattern and practice that started with Sonia Grenadier sold property /
conveyed property to her daughter Erika Lewis illegally and behind Janices back.
59. The Scheme to steal from Janice began in or around December of 1986 with the lie about
not having enough money for GIC portion of down payment and closing costs.

60. That with the conversion of Real Estate in the Liquidation agreement then the sale of it in
collusion with Burke & Herbert Bank using sale proceeds by all appearance to further
invest in California and other places.

61. That Divorce Lawyer did not have to act criminally she did so voluntarily and with
knowledgeable intend.
FOURTH CLAIM FOR RELIEF
COLLUSION

62. Incorporated into this is all of the above.

63. That the Collusion of David Mark Grenadier, Burke and Herbert Bank, Land Carroll Blair,
DiMuro Ginsberg, Michael Weiser Esq, Judge Haddock, Judge McGrath, Judge Kemler,
Judge Dawkins the Prince William County Judges, Judge Potter, this court have colluded
and worked hand in hand in the GANG RAPE of Janice Wolk Grenadier to enrich and do
the illegal and criminal dealing of Divorce Lawyer Ilona.

64. That Taylor Burke / Burke and Herbert when he was in July of 1997 was under
investigation by all appearance worked with Ilona to squash Janice to repair his standing
with the FDIC.

65. That the Judiciary, the Government and Elected Officials are as a pattern and practice
selling Justice to the highest bidder ignoring the United States Constitution, the Law and
Rules of the Supreme Court who is Empowering them to do so.

FIFITH CLAIM FOR RELIEF

MALISCIOUS PROSECUTION, OBSTRUCTION OF JUSTICE

66. Incorporated into this is all of the above.

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67. That Bankruptcy Lawyers, Judges, Ben DiMuro, Michael Weiser, Ilona Grenadier
Heckman, Andrea Mosley, Hillary Collyer, Ann Schmidt, John Tran et al all lied in court,
lied in court documents which was pointed out to the court that ignored it.

68. That the Judges to date of allowed Fraud on the Court by lawyers to maliciously cause
unnecessary pain and suffering of Janice to line their friends pockets or as Judge Clark did
for friendship/

69. Justice was Obstructed when every subpoena for information was denied Janice. That the
more Janice exposed the TRUTH and the collusion of all the more harm came to
Janice.

70. That the changing of dockets, the mailing back of evidence shows a pattern and practice of
Obstruction of Justice to further line the pockets of FRIENDS Bankers, Lawyers and
Judges.

71. October 2012 Janices documents submitted into the record, when she went to check
that they had been filed she is told to take them or they would throw them out, Janice
refused to take them and then they are mailed back to her by Judges Kemler, Dawkins and
Clark. The box about 4 thick has been x-rayed and shows the documents but, never
opened still In the box

72. The most recent case for legal fees was malicious and illegal. All legal fees awarded
where VOID due to Fraud on the court. Legal fees were in Orders and as Judge Clark
stated very clearly after Illegally jailing Janice and having her TORTURED in jail to his
best friend Michael Weiser I am so sorry I cannot collect your legal fees I have to let
her out of jail you will have to come back and get a not different then CASH for
KIDS in Pennsylvania where Judges went to jail. CASH for LAWYERS is just as
illegal.
73. That using the Fraud on the court by Judge James Clark Orders tried to silently, not giving
appropriate notice to Foreclose on an illegal Order as a Lawyer with the collusion of
Lawyers Foster Freedman who ignored the criminal acts of the lawyers and Judges to
report less knowledge of under oath testimony of Janice Wolk Grenadier. That Heba
Carter a lawyer gave less then 10 days notice of foreclosure to try and prevent a stoppage.

SIXTH CLAIM FOR RELIEF

ALTER EGO

74. Incorporated into this is all of the above.

75. That throughout the years starting in 1993 (this was right after David for the first time
stated he wanted a divorce) Ilona would start moving the properties in and out of Trusts
21
 under different names. She would take control of how the properties could be used. That
in doing so she was the alter ego of the trusts. This resulted in personal unjust enrichment,
fraud and harming the other partners with knowledgeable intend

SEVENTH CLAIM FOR RELIEF

VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1871
(42 USC 1983. 1985, 1986)
76. Incorporated into this is all of the above.

77. That Ilonas hate of Catholics was made clear in or around May of 2008 when she stated
very clearly Me and My family had nothing to do with your children because you raised
them Catholic the hate is proven in her collusion with Loretta Lax Miller in the blog
jwgrenadierisalair.blogspot.com that is down with a new one that went up as I got out of
jail.

78. That the rights of Janice in the courts were denied to her for being Blacked Balled by the
Old Boys Network order by all appearance by Judge Donald Kent and Judge Donald
Haddock.
EIGHTH CLAIM FOR RELIEF
RACKETEERING AND CORRUPT ORGANIZATIONS ACT OF 1970
( 18 USC 1962)

79. Incorporated into this is all of the above.

80. That the criminal enterprise of the Judiciary to harm those that do not have the money or
use lawyers that are not friends of the Judges is sick. That the facts, the documents show

81. That the Judiciary, the Government and Elected officials have created a You scratch my
back I will scratch your back or you buy me breakfast, lunch, dinner a weekend getaway
I will rule in your favor. Being the x-wife of a son of a Judge Judges at events et al I
have seen this behavior first hand. I have now lived the other side at the mercy of these
men and women who have done whatever they can to silence me. By the grace of God I
am still alive. RIP Nancy Dunning et al that were not so lucky.

82. December / January time frame of 2012 & 2013 Lawyer Ilona in collusion
with others as a favor or hired a gentleman that goes by the name of Mark Stuart who
informs Janice he was to drug Janice and get sexual inappropriate pictures of Janice, or to
rape one of Janices daughters, or to plant drugs on Janices daughter or in the home to
give Circuit Court Judges Kemler, Dawkins and Clark, information to make JWG
incompetent to file any other documents. Mr. Stuart said the Lawyer Ilona will go to any
length to harm Janice or Janices daughters. That Lawyer Ilona will continue to do what
she can to distract Janice from becoming successful and moving on with Janices life.
That Lawyer Ilona is a Greedy Jew that all Lawyer Ilonas actions are deliberate to
cause harm to Janice. When the Alexandria Police were called they informed Janice

22
 they were instructed by Commonwealth Attorney Randy Sengel to not take any
reports of issue.

NINTH CLAIM FOR RELIEF

LIBAL AND SLANDER
18.2-417.

83. Incorporated into this is all of the above.

84. That when Ilona acting in collusion on her and her friends blog lied stating I was the anti-
Christ a homosexual while trying to sell a family friendly product My Pillow Pack
further harmed me with their lies.

85. That Ilona and her lawyers lied in court, in court documents slandering the truth and me
defaming me.

TENTH CLAIM FOR RELIEF

FALSE IMPRISIMENT
86. Incorporated into this is all of the above.

87. Judge James Clark illegally Jails Plaintiff: That Judge Clarks actions turned back
time. Giving me less rights then a slave. Taking someone under Title 42 US Code
1994 and Title 18 US Code 1581(a): Whoever holds or returns any person to a condition
of PEONAGE, shall be fined under this title for imprisoned not more than 20 years or
both. That on October 22, 2014 Janice was placed in jail for failure to pay legal fees in 30
days which is a violation of my Thirteenth Amendment "Neither Slavery not involuntary
servitude, except as punishment for a crime where of the party shall have duly convicted,
shall exist within the United States, or any subject to their Jurisdiction". Furthermore the
right by placing me "under" a state Peonage / Involuntary Servitude violating the Fourth
Amendment right by malicious prosecution, false imprisonment and unconstitutional
arrest. This violation of my Eight Amendment Right as to Excessive Bail which in this
case constitutes "Restitution Bail" which further shows the knowledgeable malicious intent
to silence me till the election was over on November 4th. 2014. Bias, Retaliation and
Retribution to further line the Lawyers pockets by Judge Clark.

88. That on November 12, 2014 when Judge James Clark was forced to release Janice
early from jail he turned to his BEST FRIEND lawyer Michael Weiser and stated
very clearly I am so sorry I have to let her out of Jail, I cannot collect your legal fees
for you YOU will have to come back to get a Judgement to date no such
Judgment has been filed for.

89. By all appearance it was through the ORDERS of Judge James Clark Janice was to
be tortured in the City of Alexandria jail.

90. That in CASE NO. 1500-3661 filed by Divorce Lawyer Ilona Grenadier Heckman for
legal fees that are not Judgments Judge James Clark has personally in Judges
Chambers chosen a Trustee, not giving Plaintiff any Discovery to show the TRUTH
23
 ELEVENTH CLAIM FOR RELIEF
TURNOVER OF PROPERTY SOLD / AND OR STILL COLLECTING RENTS AS
TRUSTEE

91. Incorporated into this is all of the above

92. That the appearance is in 1983 from documentation that Janice has Ilona became Trustee
and is still collect rents et al. That Ilona is using profits and rents for by all appearance
other Real Estate or personal use / use by Erika Lewis her daughter et al.

TWELETH CLAIM FOR RELIEF

FRAUD ON THE COURT BY LAWYERS AND JUDGES

93. Incorporated into this is all of the above

94. That the evidence and the orders themselves by Judge clearly show FRAUD ON THE
COURT. That the willingness of Judges to protect them own is clearly in the Orders and
the acts and actions. .In e-mails that accidently I was included in between lawyers Do we
have to respond or will Judge Clark just take care of it. Lawyers do not have to respond
to the Appeals Court or the Supreme Court of Virginia Judges have agreed to further
RAPE JANCIE to take care of their own. The machinery of the court is broken, corrupt an
enterprise to protect their own.

95. In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated "Fraud
upon the court is fraud which is directed to the judicial machinery itself and is not fraud
between the parties or fraudulent documents, false statements or perjury. ... It is where the
court or a member is corrupted or influenced or influence is attempted or where the judge
has not performed his judicial function --- thus where the impartial functions of the court
have been directly corrupted."

XV1. THIRTEENTH CLAIM FOR RELIEF

Honest Services Fraud 18 USC 1961

96. The Scheme is Systemic denial of honest services of the court system, while perpetrating a
kickback scheme to gain favor with others, or financial gain. To be seen as a game player
with the Old Boys Network with the hope of pay raises, bonus and the payments towards
dinners, parties, portraits or whatever the Judge may request of the lawyers which give the
appearance of bribery.

RELIEF REQUESTED

97. Incorporated into this is all of the above.

24
 98. That Janice starts receiving immediately the monthly rent portion that belongs to her by
law. That by law with no Property Settlement 24.5% or properties still owned prior to
expenses the Est Rents for 404 E. Monroe Ave $16,000. The Est. Rents for Southampton
is $75,000. Monthly.

99. That Ilona Grenadier immediately has to turn over copies of all information and documents
to where each and every property stands the price if it was sold for and where the funds
went etc.

100. That once an accounting is done all monies by due Janice be paid to her.

101. That if this court cannot allow for the harm and the years that Ilona has schemed
and used the system that she is a member to harm Janice the appropriate authorities be
notified of the criminal acts and actions of all involved.

102. That under the Judicial Cannons and the Professional Code of Ethics it is required
in a self-policing profession to do the right thing. To alert the right authorities of criminal
acts and actions.

103. That the time needed for subpoenas and discovery be given to Janice to learn of the
scheme and the enterprise that Ilona has created with the money stolen from Janice, along
with Sonia Grenadier.

104. That any other relief this court deems appropriate be given to Janice

105. DEMAND TRIAL BY JURY

Date: October 31, 2016 Respectfully submitted,

/S/_____________________________
Janice Wolk Grenadier
15 West Spring Street
Alexandria, Virginia 22301
Telephone (202) 368-7178
Email jwgrenadier@gmail.com

CERTIFICATE OF SERVICE

Where is Janice on October 31, 2016 will have appropriately served through Hand Delivery, Personal
Service, USDC mail and e-mail delivered to:
Ilona Grenadier Heckman
649 South Washington Street
Alexandria, VA 22314
703-683-9000

October 31 , 2016

Janice Wolk Grenadier

25