PWC IEG v Final 1 Heading Responce to Petition to Quash Lis Pendens March 29, 2014 8.09 Pm

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1 VIRGINIA: IN THE CIRCUIT COURT FOR PRINCE WILLIAM COUNTY 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 Attorney’s 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. http://www.wusa9.com/story/news/local/2014/02/18/fbi-cautions-residents-of-public- corruption-in-northern-virginia/5585877/ 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

Transcript of PWC IEG v Final 1 Heading Responce to Petition to Quash Lis Pendens March 29, 2014 8.09 Pm

Page 1: PWC IEG v Final 1 Heading Responce to Petition to Quash Lis Pendens March 29, 2014 8.09 Pm

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VIRGINIA:

IN THE CIRCUIT COURT FOR PRINCE WILLIAM COUNTY

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 Attorney’s 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.

http://www.wusa9.com/story/news/local/2014/02/18/fbi-cautions-residents-of-public-

corruption-in-northern-virginia/5585877/

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

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Office has set up a Northern Virginia Public Corruption Hotline at 703-686-6225 and you can

also e-mail them at [email protected].

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 Lawyer’s

Responsibilities reads in part:

“A lawyer’s conduct should conform to the requirements or the law, both in professional service to clients and in the lawyer’s business and personal affairs. A lawyer should use the law’s 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 lawyer’s 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 lawyer’s responsibilities to clients, to the legal system and to the lawyer’s own interest in remaining an upright person while earning a satisfactory living.” “the legal profession’s relative autonomy carries with it special responsibilities of self-government. 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;

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(b) Commit a criminal or deliberately wrongful act that reflects adversely on the lawyer’s honesty, trustworthiness or fitness to practice law;

(c) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation which reflects adversely on the lawyer’s 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 Plaintiff’s 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 Plaintiff’s attorneys

deliberately after being notified that Defendant would need the appropriate time

to issue subpoenas to Plaintiff to assure Plaintiff’s 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 e-

mails 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 [email protected]

Mar 21 (12 days ago)

to Ben, John, Ilona, AEB66, Andrea

Mr. Dimuro,

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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 <[email protected]> Wed, Mar 26, 2014 at 4:37 PM To: "JW Grenadier ([email protected])" <[email protected]>

Cc: Andrea Moseley <[email protected]>

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 <[email protected]> Wed, Mar 26, 2014 at 4:57 PM To: Ben Dimuro <[email protected]>

Mr. DiMuro,

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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 <[email protected]> Wed, Mar 26, 2014 at 5:46 PM To: Ben Dimuro <[email protected]>

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 Plaintiff’s

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 Plaintiff’s 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

Plaintiff’s attorneys. The perfect example is the e-mail strand above that show’s

Plaintiff and Plaintiff’s attorney’s 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 – Plaintiff’s request that Defendant

must request permission from a Judge to file documents that once again

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Defendant’s 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

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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. Freedom of speech

2. Freedom of worship

3. Freedom from want

4. 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 Plaintiff’s

attorneys lying in documents and misleading the court from the TRUTH.

11. Defendant in the Counterclaim / Cross Complaint evidence will show that

Plaintiff’s professional by appearance also includes corruption in her cases.

Defendant will call witnesses of the abuse and over charge from her law firm.

Plaintiff’s 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 Plaintiff’s attorney calling the Pope a “Wonker” and other intimidating

statements in regard to the Defendant being Catholic. Two of the most recent

which involves Plaintiff’s 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)

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The Parties

The Victims of Defendant:

2. SONIA & Herman GRENADIER Mother to the late Albert Grenadier,

Grandmother to David Grenadier, Great Grandmother to Plaintiff’s 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 Grenadier’s

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 Defendant’s 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

Plaintiff’s 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.

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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 Plaintiff’s name along with Albert’s sister

Ruth Subitzky’s name. Claiming Plaintiff put Ruth’s name on such property out of

the goodness of Plaintiff’s 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 –

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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 Grenadier’s Garden at King David and by all

appearance steals Herman Grenadier’s body and moves it to a Garden Plaintiff

claims to own. Plaintiff told Defendant that Plaintiff used the Garden donated on

Plaintiff’s 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

Ruth’s 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 Plaintiff’s

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. Plaintiff’s relationship with Ruth was also as a client and Ruth paid for

Plaintiff’s services. By all appearance Plaintiff met with Ruth’s 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 Plaintiff’s 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.

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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 don’t 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 Plaintiff’s 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.

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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 Plaintiff’s 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 Defendant’s accounting at this point is aware that

much more was stolen from the Sonia Grenadier Trust – new evidence shows from

Plaintiff’s 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

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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. During 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 great –

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 Plaintiff’s 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 David’s 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. Plaintiff’s 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

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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 chose’s Judge) Is if they can’t 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

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a documented lie. Most of Plaintiff’s 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. Defendant’s Bankruptcy caused by Bellefonte as Defendant in & out ~ Which

now Defendant realizes Defendant would never had been in and out if it

wasn’t 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 Plaintiff’s 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.

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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 Plaintiff’s lies and

manipulations – Plaintiff after court informs Defendant after Judge Brown has

ruled in Plaintiff’s 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 Judge’s ~ 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 Defendant’s 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 Plaintiff’s 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 Defendant’s face how Plaintiff had manipulated

Plaintiff into believing it was David who stole the money from the Sonia Grenadier’s

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 didn’t drop suit.

2. Motion for Trial by Jury – Due to comments made by Judge Haddock & Plaintiff

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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 Defendant’s 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.

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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 doesn’t 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 Petitioner’s Response to Respondents Joint

Motion to Dismiss Petition For Appeal on Page 2 Respondents state “Petitioner’s

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 Petitioner’s 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).

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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 commonwealth’s 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

Plaintiff’s 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

can’t 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 Plaintiff’s 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

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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 Plaintiff’s 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

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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 husband’s 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 husband’s medical practice. The California

appellate court upheld the wife’s claims. Accord Liles v. Liles, 289 Ark. 159, 711 S.W.2d

447 (1986) (wife awarded damages for husband’s attorney’s fraud and

misrepresentation in wife’s suit to set aside property settlement agreement); Carney v.

Wohl, 785 S.W.2d 630 (Mo. Ct. App. 1990) (upholding wife’s claim of fraudulent

misrepresentation against husband and husband’s 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

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husband’s 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 girlfriend’s 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, Plaintiff’s 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 Plaintiff’s 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 Plaintiff’s 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).

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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 jwgrenadierisalair.blogspot.com

which is riddled with lies – again to harm Defendant and Defendants children

and distract Defendant and all from the TURTH.

From: [email protected] <[email protected]>

Tue, Dec 24, 2013 at 2:05 PM

To: [email protected]

want to hear something more scarier I contacted Ilona Ely Freedman Grenadier Heckman your witch hunt is over

From:[email protected] <[email protected]>

Tue, Dec 24,

2013 at 10:39

AM

To: [email protected]

you know what YOU DIDN"T HELP JEWS YOU ARE THE KIND THAT WOULD TURN THEM IN BECAUSE ONE PERSON DID SOMETHING TO YOU THAT WAS JEWISH.

YOU MADE YOUR BED AND YOU LIED IN IT ! THIS FAMILY REJECTED YOU FOR NOT BEING

JEWISH. YOU STUPID GOY. YOU WERE REJECTED .. GET

THAT INTO YOUR THICK SKULL. NOW YOU ARE MAKING UP STORIES AND SPREADING

LIES! BLAMING ALL JEWS LIKE HITLER FOR NOT LIVING ON EASY STREET. WELL

GET OFF YOUR ASS. GOOD YOU LOST ALL YOUR MONEY MAKES YOU HUMBLE. AND GOOD YOU GOT A WHIPPING FROM A JEWISH LAWYER WHO WAS SMARTER THEN YOURS. GOOD FOR HER. I WOULD HIRE HER IN A HEART BEAT. SHE WENT AFTER A JEW HATING NAZI AND SHE WON. AND I HOPE SHE GAVE HER GRANDSON A GOOD TALKING TO FOR MARRYING A GOY IN THE FIRST PLACE AND HE SHOULD HAVE KEPT HIS ZIPPER UP AND NOT HAVE HAD SEX WITH A MENTALLY SICK PIECE OF CRAP LIKE YOU.

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YOU ARE THE NAZI WORSE A MUSLIN LOVING NAZI! YOU HATE YOURSELF THAT IS WHY YOU HATE JEWS YOU ARE BLOCKED! -

The Words of Presidential candidate Leah Lax et al –

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 ofPlaintiff’s Hate

crime against Catholics

2. The information on the Property Bristow Road

3. Documents regarding Defendants Divorce – Plaintiff’s

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.

Conclusion

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 Plaintiff’s

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

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repayment of money stolen out of Plaintiff’s law firm, with Plaintiff’s 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 Plaintiff’s actions that are similar if not the same as Jim Arthurs who

went to jail for 5 years, and from all of Plaintiff’s 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 [email protected] 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