VIRGINIA: IN T H E C I R C U I T COURT F O R T H E C I T Y O F A L E X A N D R I A JANICE W O L K GRENADIER, Plaintiff, v. ILONA E L Y FREEDMAN GRENADIER H E C K M A N , et al., Defendants. j Case No.

CHOI 0654 :

f;
ro

TJ
Vv"
i

'>>'<"> ' "', "

*

DEFENDANTS' OPPOSITION TO P L A I N T I F F ' S MOTION T O R E O P E N C A S E Defendants Ilona Grenadier and Grenadier Investment, Co. Ltd. ("Defendants"), by counsel, hereby oppose the Plaintiffs Motion to Reopen this case. Plaintiffs motion fundamentally fails to state any basis in fact or law to warrant the reopening of a closed case. Defendants adopt and incorporate the grounds set forth in the opposition filed by Defendant David M . Grenadier and seek sanctions in accordance with Va. Code 8.01-271.1 for Plaintiffs filing of this latest frivolous pleading. And as the Virginia Supreme Court has stated "sanctions can be used to protect courts against those who would abuse the judicial process". Oxenham v. Johnson, 241 Va. 281, 286, 402 S.E.2d 1, 3 (1991). Plaintiffs pleadings contain the contemptuous language and distorted representations that never serve a proper purpose and are intended solely to be derisive to the subjects of that language. The presence of such language in Plaintiffs motion to reopen a closed case constitutes an abuse of process for which this Court has broad discretion to apply the appropriate sanctions. Taboada v. Daly Seven, Inc., 272 Va. 211, 215-16, 636 S.E.2d 889, 891 (2006). This Court should craft the appropriate sanctions to compensate defendants for the costs of

having to respond to the vexatious litigation pursued by Plaintiff and bar the Plaintiff from this course of conduct, including the requirement that no further filing concerning the subject matter of Plaintiffs failed lawsuits shall be done absent approval from this Court, under penalty of contempt and for such other relief to which Defendants and the public may be entitled.

Respectfully submitted, ILONA G R E N A D I E R AND G R E N A D I E R INVESTMENT, CO. L T D . By Counsel

John M . Tran (VSB #24349) DIMUROGINSBERG, P.C. 1101 King Street, Suite 610 Alexandria, V A 22314 Tel: (703) 684-4333 Fax: (703) 548-3181 Defendants Ilona Grenadier and Grenadier Investment, Co. Ltd.

CERTIFICATE OF SERVICE I hereby certify that a true and accurate copy of the foregoing was delivered by first class mail, postage prepaid and as a courtesy, by electronic mail this 19 day of September, 2012, to the foregomg:
th

Janice Wolk Grenadier 15 W. Spring Street Alexandria, V A 22301 jwolkgrenadier@aol.com Plaintiff pro se Michael J. Weiser, Esq. (VSB #17630) 510 King Street, Suite 416 Alexandria, V A 22314 Tel: (703) 836-7003 Fax:(703) 548-4742 miwesq@erols.com

Counsel for Defendant David Grenadier

John M . Tran