VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA JANICE WOLK GRENADIER Plaintiff, v.

ILONA ELY FREEDMAN GRENADIER HECKMAN et al, And GRENADIER INVESTEMENT CO., LTD et al, And DAVID MARK GRENADIER Defendant PLAINTIFFS RESPONSE TO DEFENDANTS AFFIDAVIT ON LEGAL FEES FOR JOHN TRAN - OPPOISTION to FINAL ORDER & ORDERS on LIS PENDINS
On September 26, 2012 in a locked court room Judge James Clark by all appearance should have recused himself due to refusing on two occasions to hear Motions that had prevalence to Plaintiff victim of the City of Alexandria & Virginia Judicial system.. Cannon 2. Of the Judicial Conduct for the State of Virginia A Judge shall avoid impropriety and the appearance of impropriety in all of the Judges activities - Instead Judge James Clark called Plaintiffs Motion Frivolous and used cronyism and favoritism instead of the Law and Rules of the Supreme Court of Virginia. Judge James Clark by his Orders is only allowing Plaintiff to file documents with the Circuit Court of Alexandria with his approval, as Chief Judge Kemler and Judge Dawkins have recuse themselves. Judge Clark by his actions has created a Trustee type relationship with Plaintiff. Defendants owe Plaintiff close to $3 million dollars. Per the line item exhibits formally presented and handed to Judge and Defendants in court without any objections to Exhibits. The rules of Trustee fiduciary responsibility to Plaintiff and her asset is established by Judge Clarks Order . As Trustee to documents that Plaintiff is allowed to file he must at all times put Plaintiffs best interest before all else. He must examine all Facts and exhibits that Plaintiff has provided as a Trustee he has a special Fiduciary responsibility to Plaintiff and her asset as established in Exhibits. The Order strips Plaintiff of her fundamental rights as a Citizen in the United States of America. That demanding approval of anything Plaintiff files by Judge James Clark to protect his friends is in conflict with the Cannons for Judges along with the United States Constitution DUE PROCESS OF LAW. The following Claims against Defendants still stand as follows: 1. Defendants with damages not punitive damages owes Plaintiff close to $3 Million Dollars. 2. That DiMuroGinsburg lawyer officer of the Court John Tran lied about mailing and proper service of his Motions to Quash Lis Pendins et al. to Plaintiff ( in the book How To Tell If Someone is Lying they will touch there face or there face can turn red Mr. Trans face turned bright red as he told this court he had mailed Motions)

Case No. CH010654

3. That DiMuroGinsburg played the bait and switch with attorneys as Plaintiff had pointed out that Ben DiMuro & Hillary Collyer had lied (both lawyers officers of the Court) in there filing with the Supreme Court of Virginia as pointed out in court and documents in note book of Exhibits. Fraud on the court. 4. That Plaintiff has every attention of appealing all Orders to the Supreme Court of Virginia and will be sending out such notice. Even with that pointed out. Plaintiff should not have to pay more for John Trans or Michael Wiesers time then what is paid for either attorneys time by Defendants. Plaintiff believes 3 months bills showing what Defendants pay for attorneys times should be disclosed. Plaintiff should also not pay more than the hourly rate that Ben DiMuro and Hillary Collyer where paid as due to the Bait and switch which is backed up by the notice on the bills showing they reviewed all John Trans work. The following Facts are outlined and the Backup is included in Plaintiffs notebook of exhibits: which proves the Fraud on the Court. Evidence that was ignored in Judge Clarks ruling, and is not Frivolous, but has prevented Plaintiff from Brodie v. Connecticut Plaintiffs day in court.. The facts also show Plaintiff has been held to a higher standard of the Truth then Judges, Lawyers, Elected Officials, and government workers. 1. September 12, 2007 Ilona lawyer officer of the court lied in court to Judge Kloch on being served - in court th on September 26 Judge Clark refused Plaintiff to call her to the stand to testify to this 2. The criminal actions of Judge Kloch, Judge Haddock & Judge Kemler who then did not file the appropriate paper work with the Supreme Court to have Judges chosen at arms length .. The rules are very clear that when a judge recuses himself or herself they are to file the appropriate paper work with the Supreme Court through the Clerk of Courts office There friend Ed Semonian Elected official of the City of Alexandria, lawyer officer of the Court. Rule 17.1-105 (b)

3. In collusion the Judges and Clerk of Court Ed Semonian to protect Defendant they choose their friends and Defendants friends instead of the Supreme Court choosing the Judges per rule 17.1-105(b). 4. That Defendant (Ilona) a lawyer & officer of the court then mislead and lied in her Counter Claim Cross Complaint. Misleading the Court in her percentage of ownership. Of the Real Estate at issue 5. The Law When reviewing a pro se pleading, it is prudent to follow the federal practice of liberally construing the allegations set out in the pleading, to determine whether the pleading asserts any valid causes of action . th See e.g., Harrison v. U.S. Postal Service. 840 F. 2d 1149, 1152 (4 Cir. 1988) The factual allegations should be viewed in the light most favorable to the pleading party. Davis v. City of Portsmouth, 579 F. Supp. 1205, th 1209-10 (E.D. Va 1983) affd, 742 F. 2d 1488 (4 Cir 1984) 6. That the Judges chambers in 2007 & 2008 lied to Plaintiff on several occasions about the Rule 17.1-105 (b) taking again advantage of a Pro Se litigant telling her oh no the only way to get a Judge chosen by anyone other than the Judges was if they couldnt find a Judge to hear it. The complete opposite of the truth and misleading. Fraud on the Court. 7. That in May of 2008 when Plaintiff walked into Judges chambers and found Defendant Ilona in the arms of Chief Judge Haddock flirting and playing with him. Plaintiff introduces herself to Judge Donald M. Haddock to be informed by him We LOVE Ilona (Defendant) and you will not get a fair trial. 8. Plaintiff files on March 11, 2008 Praecipe to put on the record that there is no visiting Judge to hear Plaintiffs case so needs to be rescheduled. To document at the time Plaintiff believed to be criminal actions of the Circuit Court. 9. Plaintiff asks for a Trial by Jury Denied by Judge Brown 10. Defendant Ilona a lawyer, officer of the court lies in her Admissions.

11. Judge Brown who is chosen to hear case on three occasions which Defendant Ilona lawyer, officer of the court bragged about their friendship and all the free legal advice she gives him. 12. Judge Kloch who recused himself in September of 2007 shows back up August 11, 2010 to recuse himself nd the next morning - in his letter of recusing himself a 2 time he uses the point that his working with Judge McGrath he feels it inappropriate well he choose Judge McGrath as the trial Judge after he started or during his negotiations to work with Judge McGrath. Which the Judicial Cannons are very clear that this is inappropriate. As his letter stated he believed strongly The appearance of Justice is equally important as Justice itself. Fraud on the Court. Judge Kloch did the right thing and showed his integrity with his letter on August 11, 2010. 13. September 11, 2008 the day Judge McGrath heard the case Judge Kloch stood outside the negotiations in Judges chambers prior to the trial and then had a very friendly lunch with Judge Kloch at Jackson 20. Judge McGrath was disingenuous in the negotiations prior to trial and during the trial he ruled on cronyism and favoritism not on the Law or Rule of the Supreme Court of Va. He did not have Jurisdiction as he was chosen by Judges Haddock, Kemler and Kloch, and by appearance and timing Dawkins. 14. That Judge Dawkins lied in court on October 2010 saying he did not have to recuse himself as he was not a Judge in the Circuit Court at the time this case was heard which is a lie Judge Dawkins was appointed prior to Judge McGrath being chosen and sworn in prior to at least one of the Motions being herd by Judge Brown, Fraud on the Court 15. That Plaintiff emailed Commonwealth Attorney in regard to the Judges criminal actions. Commonwealth attorney to scare Plaintiff has her investigated for Extortion. Which according to the Alexandria Police they have no record number or incident number. According to Detective Pax there is no number and he did it as a favor for Randy Sengel Commonwealth Attorney Elected Official of the City of Alexandria Va. 16. That Plaintiff went to Patsy Ticer on several occasion to only be blown off till her persistence to meet with her Patsy Ticer set Plaintiff up with the x wife of Judge Kent to explain to Plaintiff that her family was no longer a party to the Old Boy Network that Plaintiff need to forget this and move on with her life - as with her and her family Plaintiff would never be able to get a fair trial in Virginia. 17. That in court on September 26 2012 the Law firm DiMuroGinsberg played the bait and switch game. The reason you didnt see Ben DiMuro or Hillary Collyer is for their criminal actions as lawyers officers of the court blanted lie to the Supreme Court of Virginia in misleading it that Plaintiff had not filed the appropriate paper work with the Courts of the facts. 18. That the JIRC committee when complaint was filed mailed it back the next day Judge McGrath and all the other Judges are good friends of Donald Currys (lawyer officer of the Court) so he has refused to do his job and investigate. 19. The VSB says just because you dont like the way your opposing Defendant an officer of the court lies in court or uses her friendships doesnt make it wrong 20. The ethics attorney for the VSB contacts Plaintiff outside his job with the VSB and has Plaintiff send the information to his home where he never looks at it a year later then threatens Plaintiff. 21. That Federal Court Judge Lee did not have Jurisdiction due to the Judicial Cannons Plaintiff can and will show he was disingenuous and had his staff Lie for him to Plaintiff. This is documented in the Federal Court. 22. That the Supreme Court of Virginia denying Plaintiffs appeal, Reconsideration, denying Motion to have the law disclosed as to why appeal was denied shows the collusion in the judicial system to protect their own in the State of Virginia. That the Supreme Court Clerk and Justice Lemon told Plaintiff to file Motion to have law disclosed is documented.
th

23. That Plaintiff was blocked by the criminal actions of Judge Donald Haddock, Randy Sengel, Judge Potter of going in front of a Grand Jury to ask for a Special Grand Jury to look into the criminal actions of all involved. Plaintiff has Exhibits provided to the Judges the following documentation in regard to the Money stolen out of the Sonia Grenadier Trust by Defendant, The Grenadier et al, law firm, for the enrichment of Defendants and Jerry Heckman lawyer officer of the court and husband to Defendant Ilona, nephew of victim Sonia Grenadier. 1. Trust agreement which Defendant was party to the forging of Sonia Grenadiers name 2. Several Letters that went to Sonia Grenadier went also to Defendant at her law firm. 3. That on May 20, 1985 Defendant on the second page of that letter had been notified and given notice that the amendment was illegally done due to the forgery of Sonia Grenadiers name 4. That December 6, 1985 it was agreed Defendant and her law firm would continue to act as agents of the Trust. 5. The letter on December 9, 1985 shows the Trusts business was being handled by the Law firm Grenadier et al 6. April 17, 1989 Contract from George Zimmerman to Sonia Grenadier signed by Sonia Grenadier to purchase land owned by the Trust. 7. Letter March 2, 1990 Removing Defendants as agent s for the Sonia Grenadier Trust, for the mismanagement out of the Grenadier et al Law Firm 8. August 8, 1990 Letter Jim Arthur met with Plaintiff - Page 7 last paragraph 6 sentences up from the bottom Ilona has no recollection that she was named or that David actually had signature authority. Defendant is a thief and a liar and this court continues to rule in cronyism and favoritism to protect her. 9. Settlement Sheet September 17, 1991 from Wolk & Associates assignment of commission as negotiated by Plaintiffs attorney Defendant Ilona Grenadier per her manipulation and lies. In Ilona Defendants role of malicious manipulation of Plaintiffs commission she worked as Plaintiffs attorney, had until May of 2012 when Plaintiff sent Defendant Ilona a letter canceling all legal obligations and asking for her files back. 10. Copies of Accountings and conversations in regard to the money stolen from the Sonia Grenadier Trust by Defendant Ilona and her Law firm. 11. Defendant Ilona a lawyer and officer of the Court knowing that she did not have a Power of Attorney for the Trust on or around March 18, 1986 (The letter states May 20, 1985 that the Trust addendum is forged and not in force) goes to King David and donates Herman & Sonia Grenadiers Garden. 12. Ilona has Herman moved to a new Garden Ilona claims to have purchased and donates and takes a tax deduction for Herman & Sonias Garden, which is a criminal action. 13. Ilona Defendant then waits 3 years to protect herself from liability to Ruth Subitzkys family and having them ask for her legal file back, to call King David and claim that Strangers are buried in her Garden that she did not give permission for. 14. That stranger who Defendant Ilona did sign permission to be buried there is Ruth Grenadier Subitzky sister to the late Judge Albert Grenadier, Daughter to Sonia & Herman Grenadier is now a stranger to Defendant. Emails and Permission signed by Ilona is in Exhibits 15. Ilona Defendant then filed such a report with the state. The state is aware but, because it is Ilona as the VSB, JIRC, Judges in the Circuit Court, Randy Sengel, Ed Semonian, The Supreme Court of Virginia Its ok the State of Virginia allows for the Judicial favorites to do as they please. Which is the message

the Supreme Court Justice Cynthia D. Kinser sent when she denied Plaintiffs appeal it is ok to rule by Favoritism & Cronyism not the Law and Rules when it comes to one of us. 16. The VSB code of Ethics is very clear that when an attorney or Judge knows of another attorney or Judges misconduct it is to be reported immediately. The Code of ethics Generally, codes of ethics forbid conflict of interests. Codes of ethics help to minimize problems with conflicts of interests because they can spell out the extent to which such conflicts should be avoided, and what the parties should do where such conflicts are permitted by a code of ethics (disclosure, recusal, etc). Thus, professionals cannot claim that they were unaware that their improper behavior was unethical -The VSB Duties to Court, Client, other Attorneys and Third parties is very clear on the Ethics and Oath of Office that Lawyers Judges, Elected Government officials take.

The Judicial Conduct for the State of Virginia in its Preamble is clear: 1. A Judge shall uphold the integrity and independence of the Judiciary. 2. A Judge shall avoid impropriety and the appearance of impropriety in all of the judges activitie. 3. A Judge shall perform the duties of Judicial office impartially and diligently. 4. A Judge may engage in extra-judicial activities design to improve the law, the legal system, and the administration of justice, and shall conduct and such extra-judicial activities in a manner that minimizes the risk of conflict with the judicial obligations. 5. A judge shall refrain from political activity inappropriate to the judicial office 6. A Judge pro tempore, retired judges, substitute judges and persons selected for judgeships are required to comply with the cannons.

By all appearance Judge James Clark has ruled on Cronyism and Favoritism not on the Laws or Rules of the Supreme Court of Virginia. Not one of Plaintiffs claims is frivolous or they would have listed them in the order. All claims are criminal actions of lawyers, judges, elected officials of the state of Virginia, according to the Cannons Judge Clark should have recused himself. By all appearance Judge Clark has worked in collusion with the other judicial officers of the court to prevent Plaintiff from getting her day in court per Brodie vs Connecticut. All orders should be VOID and a Judge with Jurisdiction should hear Motions by Plaintiff. Or that Defendants Lawyers should show past bills and Orders should be revised. Judge Clark by all appearance has made himself Trustee to Plaintiffs assist of the value of her law suit and has a special fiduciary responsibility to Plaintiff to review all documents, under the rules of a Trustee. October 4, 2012 Janice Wolk Grenadier Pro Se 15 West Spring Street Alexandria, Virginia 22301 Jwgrenadier3@aol.com 703-836-96555 Certificate of Service Documents have been delivered to Judges Chambers on October 4, 2012 for his approval as called for in Order. E-mailed copies have been sent to Defendants lawyers - Judge James Clark will decide if he is going to allow the Opposition to be filed and will have it filed stamped and sent to all parties involved as Trustee to Plaintiffs suit. : Ilona Grenadier/ GIC /Grenadier, Anderson, Starace, Duffett & Kiesler PC to Ben Dimuro at DimuroGinsburg, 1101 King Street, Suite 610, Alexandria, VA 22314 & David Grenadier to Michael J. Weiser, 510 King St., Suite 416, Alexandria, VA 22314. October 4, 2012 Janice Wolk Grenadier