VIRGINIA

IN The CIRCUIT COURT OF THE CITY OF ALEXANDRIA

JANICE WOLK GRENADIER (JWG)

Plaintiff / Pro Se
V. Case No. CL 1900 - 2675

WELLS FARGO NATIONAL ASSOCIATION,

CEO Charles W. Scharf WELLS FARGO N.A.
BANK OF AMERICA, f/k/a - as successor-in-interest to LaSALLE BANK,
OCWEN LOAN SERVICING LLC aka PHH aka OCWEN MORTGAGE SERVICING, INC.
New Residential Investments
NewRez LLC
TROUTMAN PEPPER HAMILTON SANDERS LLP
S. Mohsin Reza TROUTMAN SANDERS LLP
Judge Donald R Alexander
Trustee Services Of Virginia, LLC. Virginia Beach, Virginia 23452
Brock & Scott, PLLC
Brian Campbell Brock & Scott, PLLC
BWW Law Group aka BIERMAN, GEESING, WARD & Wood, LLC.
EQUITY TRUSTEES, LLC
Howard Norman Bierman Partner BWW Law Group
Equity Trustees, LLC
McCabe Weisberg Conway LLC aka Surety Trustees LLC
Surety Trustees LLC aka McCabe Weisberg Conway LLC
Abby Moynihan
McCabe Weisberg Conway LLC aka Surety Trustees LLC
AG Mark Herring
Consumer Financial Protection Bureau / CFPB

Defendants

MOTION FOR JUDGE H. THOMAS PADRICK RECUSE and VACATE ALL ORDERS

UNDER THE CODE OF ETHICS, JUDICIAL CANONS,

UNITED STATES CONSTITUTION and the VIRGINIA CONSTITUTION

CHIEF JUSTICE LEMONS HAS DESIGNATED JUDGE PADRICK FOR

JANICE WOLK GRENADIER City of Alexandria, VA. amd MARY JONES of Suffolk VA.
Both women Has Engaged in Years-Long Effort to Expose What They Sees as Corruption in the
Virginia Judiciary and Law Enforcement Community

That the acts & actions of Chief Justice Donald Lemons is knowledgeable, with knowledgeable
intent to harm is racist, predatory & demeaning to women and men seeking JUSTICE
The appropriate authorities investigating the criminal acts and actions
Include and not limited to: Janice Wolk Grenadier, Rhetta Daniels, Mary Jones, Linda Kennedy,
Edwina Rogers, Jackie Bogle Meuse, Bev Hennager, Renae Jennings, Geraldine Dwyer, Elizabeth
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 Skarlatos, Natalia Dalton, Erica Winslow, Rhonda Kirshmann, Kimberly Lowe, Yolanda Bell, Robin
Ruffin, Yaki Cahoon, Brian Clark, Micheal Field, Justin Wolfe, Said Chahmoune, Joseph Rick Perry,
Isidoro Rodriguez, Matthew Skarlatos, Kevin McBride and many many moore not listed

That all Judges, Lawyers’ have an obligation under

Professional Code of Ethics & Judicial Canons
are mandated to report all criminal activity to the appropriate authorities

That Judge Thomas Patrick has called Janice a “VEXATIOUS” litigant

Janice Wolk Grenadier now includes in this Recusal Documents the CRIMES against her

Judge Padrick and lawyers now have the information in this document that shows
the crimes against Janice Wolk Grenadier
Judge Padrick as well as all Lawyers now have an obligation
by Law under 18 U.S. Code § 4 - Misprision of felony
Whoever, having knowledge of the actual commission of a felony cognizable by a court
of the United States, conceals and does not as soon as possible make known the same to
some judge or other person in civil or military authority under the United States, shall be
fined under this title or imprisoned not more than three years, or both.

by the Judicial Canons to hold the opposing Lawyers and Judges Accountable for the Malicious,
Knowledgeable, with Knowledgeable Intent to Harm they have done to Janice Wolk Grenadier

THAT JUDGE PADRICK TELLS MARY JONES YOU WILL “Hoist your own Petard1”

It is Poet Justice what Chief Justice Donald Lemons has demanded of Judge Padrick to do
to Janice Wolk Grenadier and Mary Jones in Suffolk, Virginia

"Hoist with his own petard" is a phrase from a speech in William Shakespeare's play
Hamlet that has become proverbial. The phrase's meaning is literally that a bomb-maker is
blown up ("hoist" off the ground) by his own bomb (a "petard" is a small explosive device),
and indicates an ironic reversal, or poetic justice

In Marshall v. Jerrico, Inc., 100 S. Ct. 1610 (1980), the Supreme Court of the United States
said, "The Due Process Clause entitles a person to an impartial and disinterested tribunal in
both civil and criminal cases. . . The neutrality requirement helps to guarantee that life, liberty, or
property will not be taken on the basis of an erroneous or distorted conception of the facts or the
law. At the same time, it preserves both the appearance and reality of fairness . . . "(p. 1613)

Include and not limit for Ignoring the use of False and Fraudulent Documents filed by lawyers against
the home, and for his friends Chief Justice Donald Lemons, Ret. Chief Judge Donald Haddock
Judge Padrick Called JWG NAMES and USED his WORDS
no different then he did to Mary Jones to INTIMIDATE

1
Transcripts For Mary Jones on or around Page 29 Lines 11-14
2
 JUDGES AND LAWYERS JUDGING JUDGES AND LAWYERS CORRUPTION

Justice John F. Molloy wrote a book that was published in 2004,

The Fraternity: Lawyers and Judges in Collusion

an attorney in Arizona who went on to serve as a judge on the Arizona Superior Court bench. He is
probably best known for his time serving as Chief Justice to Court of Appeals for the State of
Arizona, where he authored the famous Miranda decision that was subsequently appealed to the
U.S. Supreme Court and overturned, resulting in what is known today as the "Miranda Rights"
which law enforcement now quotes to suspected criminals upon arrest. Stated:

The legal profession has evolved dramatically during my 87 years. I am a second-generation lawyer
from an Irish immigrant family that settled in Yuma. My father, who passed the Bar with a fifth-grade
education, ended up arguing a case before the U.S. Supreme Court during his career.

The law changed dramatically during my years in the profession. For example, when I accepted my first
appointment as a Pima County judge in 1957, I saw that lawyers expected me to act more as a referee
than a judge. The county court I presided over resembled a gladiator arena, with dueling lawyers
jockeying for points and one-upping each other with calculated and ingenuous briefs

That was just the beginning. By the time I ended my 50-year career as a trial attorney, judge and
president of southern Arizona's largest law firm, I no longer had confidence in the legal fraternity I had
participated in and, yes, profited from.

I was the ultimate insider, but as I looked back, I felt I had to write a book about serious issues in the
legal profession and the implications for clients and society as a whole. The Fraternity: Lawyers and
Judges in Collusion was 10 years in the making and has become my call to action for legal reform.

Disturbing evolution

Our Constitution intended that only elected lawmakers be permitted to create law. Yet judges create
their own law in the judicial system based on their own opinions and rulings. It's called case law, and it
is churned out daily through the rulings of judges. When a judge hands down a ruling and that ruling
survives appeal with the next tier of judges, it then becomes case law, or legal precedent. This now
happens so consistently that we've become more subject to the case rulings of judges rather than to
laws made by the lawmaking bodies outlined in our Constitution.

This case-law system is a constitutional nightmare because it continuously modifies constitutional

intent. For lawyers, however, it creates endless business opportunities. That's because case law is
technically complicated and requires a lawyer's expertise to guide and move you through the system.
The judicial system may begin with enacted laws, but the variations that result from a judge's
application of case law all too often change the ultimate meaning.

Lawyer domination

When a lawyer puts on a robe and takes the bench, he or she is called a judge. But in reality, when
judges look down from the bench they are lawyers looking upon fellow members of their fraternity. In
any other area of the free-enterprise system, this would be seen as a conflict of interest.

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 When a lawyer takes an oath as a judge, it merely enhances the ruling class of lawyers and judges.
First of all, in Maricopa and Pima counties, judges are not elected but nominated by committees of
lawyers, along with concerned citizens. How can they be expected not to be beholden to those who
elevated them to the bench?

When they leave the bench, many return to large and successful law firms that leverage their names
and relationships.

The Dark Side A law treatise on judging

By Caroline George Dougles, J.D. x-wife to
Congressman & New Hampshire Supreme Court Chief Judge Charles G. Douglas, III

Country Club Rules of Judges

Private Court Club Rules and Responsibilities (unwritten, unspoken, yet mandatory)

1. Members pledge their first allegiance to judges. This means unquestionable loyalty.

2. Members pay dues and all Court Financial Obligations promptly.

3. Members volunteer help to insiders over outsiders, and may expect reciprocity (Eventually). a member
favor begets a reciprocal obligation back to the member or his designate.

4. Favors (and these rules) are mentally noted and tallied, not recorded or formally written down.

5. Members practice conformity, they may not descent outside the club. They must practice loyalty to all
judges, but especially those who support them with fees and case referrals. All members (plus others
who function in any part of the court system) are to treat every judge as a top-boss.

6. Maintain and promote exclusivity. Do not help outsiders, as they are competition for legal fees, and are
not really qualified to appear in court without a member. Outsiders represent dangerous wild cards,
requiring ultimate control and Swift and Harsh punishment.

7. Ordinary citizens will obey and give deference to all members, especially judges, (regardless of judicial
error, mistake, or bias.) members hold an inherent superiority over lay people in court.

8. Keep club disciplinary business business within the clubhouse. This means no whistleblowing, public
criticism are Judges complaints.

9. Speak nicely to other members in court - practice unnatural civility in the face of adversity. While
obnoxious, manipulative behavior is understood to be part of the professional legal persona, it is to be
masked with Ritualistic Clubhouse language and customs in court.

10. Club rules and the honor code are all members, but they are secret and have a flexible interpretation
for different circumstances and people (depending on Rank, Chits, and Judicial Favors.)

11. Club membership means this class is more qualified than any other to handle legal problems. Lay
people need legal technicians are not to be trusted. To maintain order and law, it is an obsessive
requirement that lay people be deferential at all times, and they be made to respect a judge by
showing difference as they obey.

12. Loss of control over lay people means anarchy. Each lay individual is to be treated as a threat to be
controlled by the entire profession / system. Diligence and maintaining control is a professional
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 obsession.

For this book, the powerful in this club are called INSIDERS or OL’BOYS. If a club member is very connected,
privileged and influential, I may refer to him using both terms (INSIDER and OL”BOY- capitalized or not. What
is not capitalized in this club are individuals, common people, outsiders, most court users and member
whistleblowers.

Special thanks was given to Linda Kennedy who lost her license to practice law for standing up and
speaking out. Linda Kennedy also did an intervene in support of JWG CASE NO: 1:17-cv-1106 HEH
USDC of the Eastern Division (Alexandria) JWG sued 43 Federal Judges for ignoring the information included
in this recuse and other information.
https://judicialpedia.com/listing/civil-rights-constitutional-judge-henry-hudson/

Judge POSNER Could not have said it any better for how JWG is being treated:

Posner: Most judges regard pro se litigants as 'kind of trash

not worth the time'
BY DEBRA CASSENS WEISS
SEPTEMBER 11, 2017, 11:57 AM CDT
Judge Richard Posner cites boredom with judging as well as rebuffed
efforts to aid pro se litigants in a new interview explaining his
decision to suddenly retire from the Chicago-based 7th U.S. Circuit
Court of Appeals.
Posner, 78, told the Chicago Daily Law Bulletin last week that he
decided to retire because of conflicts with his colleagues over the
treatment of pro se litigants, who represent themselves. In a new
interview with the New York Times, Posner elaborated on his concerns
about the treatment of such litigants.

“The basic thing is that most judges regard these people

as kind of trash not worth the time of a federal judge,” Posner said.
In the 7th Circuit, staff lawyers review appeals from pro se litigants, and their recommendations are
generally rubber-stamped by judges, he noted.
Posner wanted to give the pro se litigants a better shake by reviewing all of the staff attorney memos
before they went to the panel of judges. Posner had approval from the director of the staff attorney
program. “But the judges, my colleagues, all 11 of them, turned it down and refused to give me any
significant role. I was very frustrated by that,” Posner said.

Posner has written about the pro se issue in an upcoming book, and its publication “would be
particularly awkward” if he remained on the court because it “implicitly or explicitly” criticizes the other
judges, he said.

5
Posner said he began to focus on the problems of pro se litigants about six months ago when
he “awoke from a slumber of 35 years.” He decided to write the book and “realized, in the course
of that, that I had really lost interest in the cases,” he told the Times.
“And then I started asking myself, what kind of person wants to have the same identical job for 35
years? And I decided 35 years is plenty. It’s too much. Why didn’t I quit 10 years ago? I’ve written
3,300-plus judicial opinions.”
https://www.abajournal.com/news/article/posner_most_judges_regard_pro_se_litigants_as_kind_of_tr
ash_nor_worth_the_t

When will the Predatory Judiciary Fall Like Catholic Priests?

RICHARD LEE ABRAMS 29 MARCH 2021
https://citywatchla.com/index.php/cw/los-angeles/21447-when-will-the-predatory-judiciary-fall-like-catholic-pries
ts

MY TURN--The common element of predatory abusers is their

power over their victims.

Whether it is the husband who beats his wife or the judge who
steals a widow’s income, the abuser’s power over the victim is
crucial. The maxim that power tends to corrupt applies to
individuals and to the institutions. For generations priests
abused young boys. The abusive nature of Catholic schools
was no secret in the 1950's, but the Church was too powerful to
stop.

Slowly, our society has been turning against predators, but the battle is far from over as the hideous murder of
George Floyd proved. Officer Derek Chauvin’s deliberate 7 minute 46 second murder by kneeing on George
Floyd’s neck was such a depraved act that we have no word for it.

Under the doctrine of defense of others, a by-stander would have been legally justified to put a bullet into Officer
Derek Chauvin, but we all know that person would have been instantly murdered by the other senior cop.
Barbarism is too mild to explain why the other officers did not save George Floyd. When Black Lives Matters says
that the problem is systemic, they are correct. The only officers who even questioned Chauvin were the trainees.
The longer an officer is subjected to the system, the more acceptable a vicious murder becomes.

The Courts Are America’s Most Maliciously Predatory Institution

While there are varying degrees of judicial abuse from state to state, overall the judiciary has become America’s
most abusive institution. None of the other predators would have thrived for so many decades without judicial
protection. The courts protected the Catholic Church, the Boy Scouts, predators in entertainment, law
enforcement, etc.

When the videotaped beating of Rodney King gave the Los Angeles County District Attorney no choice but to
prosecute his buddies in the LAPD, the appellate court protected the officers. Through machinations which
should have fooled no one, the appellate courts gave three options for the trial: (1) Simi Valley, a bedroom
community for cops, (2) Riverside and (3) far away Alameda County. Since the police, their friends in the DA’s
6
office and Judge Weisberg all wanted the officers acquitted, they selected Simi Valley. Fifty-four people paid with
the lives for this judicial manipulation to protect predators from the consequences of their actions.

Why society has recently moved against some powerful predators is somewhat a mystery. The courts
themselves are as corrupt as ever, but now they allow the prosecutions of Harvey Weinstein, priests and Scout
leaders, etc. The courts have to ask whether the constant mowing down of one predatory institution after
another can be stopped. While the judges sit all smug knowing that they get to alter facts and the law at will,
they should remember that the worm turns. California’s judiciary faces a question not of if, but of when.

Like the Slave Holding Confederate States, California’s Courts Are among the Most Vicious

California has a tripartite judicial system: (1) the courts themselves, (2) the Commission on Judicial Performance
(CJP), and (3) the State Bar. Each is dominated by the same individual, Tani Gorre Cantil-Sakauye, Chief Justice
of the California Supreme Court. Too much power in one person’s hands results in too much corruption. Under
an absurd interpretation of Cal. Const. Article VI Section 10, the judges may do what they will inside their
courtrooms except step on the toes of a more powerful judge. Along with the doctrine of judicial immunity, the
role of the CJP is to protect abusive judges, while the State Bar acts like a mafia hit man on attorneys who
complain about corruption.

Predators Have to Be Driven out

In the last days of the Third Reich, Hitler ordered the continued extermination of Jews. Auschwitz accelerated its
genocide. In the face of the advancing Red Army, the Nazi predators continued unabated. That is the nature of
predators. Derek Chauvin proceeded with his murder knowing that he was being videoed.

Most Americans are unaware of the crimes which the courts perpetrate each day. We hear statistics about the
disproportionate number of minorities who are incarcerated and naively think, “They must deserve it,” just as
Germans thought Jews and Gypsies should be carted off to camps. Unless one has experienced Family Court,
one has no idea how families are fodder for the judges’ profit and amusement. The Probate-Conservatorship
Court is run to enrich the judges and their avaricious coterie of mediators and court appointed attorneys, while
stealing the life savings of the elderly. As lawyer Thomas Girardi shows, attorneys can steal hundreds of millions
of dollars from clients as the judges remain silent. The judges and the State Bar knew what Girardi was doing
since he wisely became their benefactor. Now, they are scrambling to cover their tracks. Will Thomas Girardi be
to the courts what Dr. Larry Nassar was to the Olympics?

As with the #MeToo Movement, the submerged anger against the judges is akin to the molten lava beneath a
seemingly dormant volcano. Bill Cosby was advertising Jell-O to children; now he’s in prison. The statute of
limitations to sue Catholic Priests and Scout leaders was abated. Judicial immunity does not extend to money
laundering with its offshore bank accounts, gifts from attorneys, insurance companies and banks. Louis XVI,
slavery, the Third Reich are gone. The judges should fear that when victims turn on them, mercy for the predators
will not be the number one goal.

(Richard Lee Abrams is a Los Angeles attorney and a CityWatch contributor. He can be reached at:
Rickleeabrams@Gmail.com. Abrams’ views are his own and do not necessarily reflect the views of CityWatch.)

THE SUPREME COURT OF THE UNITED STATES OF AMERICA

The phrase “Equal justice under law” is engraved above the entrance of the United States Supreme

7
Court building in Washington, D.C. It is hardly “Equal justice under law” when the Supreme Court blatantly
discriminates against a class of litigants who represent themselves by putting a rule in place disallowing the
pro se litigants from the oral argument process. It is blatantly unfair to be collecting filing fees from pro se
litigants to file their cases while at the same time refusing to allow them the same opportunity to participate in
the oral argument process afforded to represented litigants. This is blatant systemic discrimination based on
class. The Supreme Court should either remove the engraving “Equal justice under law” from the Supreme
Court building, or it should remove its discriminatory Rule 28(8) and allow pro se litigants to equally present
oral arguments before the court. The Supreme Court cannot have it both ways.

THE VIRGINIA LEGISLATURE SECRECY OF CHOOSING JUDGES

Virginia Legislature - Courts of Justice
Virginia Judicial Interviews Go “Off the Rails”
“This is a f**king shitshow”

when the SECRECY of CHOOSING JUDGES IS CHALLENGED By: The Public

THIS SHOWS HOW AND WHERE THE CORRUPTION IN THE COURTS OF VIRGINIA STATE

Twice a year and maybe more the Courts of Justice of Virginia choses NEW JUDGES and RENEWS old
Judges, and the JIRC committee members.

This is done as SECRETLY as they can. The information is difficult to find on the site and emails with
the times of the meeting are not usually on auto email as other meetings are.

You should remember when a complaint of a Judge or lawyer is made all should take it very seriously,
in Virginia it is ignored.

That Justice in Virginia is only available for the very Rich and Powerful. JudicalPedia.com was
launched in July of 2020 to show this.

That it is so rampant in Virginia that more and more people are standing up and speaking out - This is
just one of the people’s videos for February of 2021:

https://www.youtube.com/watch?v=2lfoZjGQvM0&t=190s Where the Court’s of Justice for just

questioning having an applicant to become a Circuit Court Judge questioned for the City of
Alexandria Circuit Court Judgeship goes “CRAZY”

After watching this - you might understand how and why we have a corrupt Judiciary in Virginia - NO
TRANSPARENCY and Judges chosen who will do as the “OLD BOYS NETWORK” wants them to do.

Also Reported By:

Home Virginia Politics VIDEO: Virginia Judicial Interviews Go “Off the Rails”; “Like a
8
 courtroom drama”;... VIRGINIA POLITICS VIDEO: Virginia Judicial Interviews
● Go “Off the Rails”; “Like a courtroom drama”; “This is a f**king shitshow”
https://bluevirginia.us/2021/02/virginia-judicial-interviews-go-off-the-rails-like-a-courtroom-dram
a-this-is-a-fking-shitshow

Wow, what on earth is going on here?!? Can’t wait to see the video…

9
● General Assembly’s judicial interviews devolve into ‘s***show’
By Ned Oliver -February 10, 202
https://www.virginiamercury.com/2021/02/10/general-assemblys-judicial-interviews-devolve-into-
sshow/

● Channel 12 VIRGINIA MERCURY

General Assembly’s judicial interviews devolve into ‘s***show’
https://www.nbc12.com/2021/02/10/general-assemblys-judicial-interviews-devolve-into-sshow/

GENERAL ASSEMBLY General Assembly judicial interview devolves into spectacle

NED OLIVER The Virginia Mercury
https://dailyprogress.com/news/state-and-regional/govt-and-politics/general-assembly-judicial-interview-devolv
es-into-spectacle/article_757f0d64-6ca4-11eb-8770-231ac7ac2eea.html?utm_medium=social&utm_source=email
&utm_campaign=user-share

Ned, a Lexington native, has more than a decade’s worth of experience in journalism,
beginning at The News-Gazette in Lexington, and including stints at the Berkshire Eagle, in
10
Berkshire County, Mass., and the Times-Dispatch and Style Weekly in Richmond. He is a graduate of Bard
College at Simon’s Rock, in Great Barrington, Mass. Contact him at noliver@virginiamercury.com
noliver@virginiamercury.com
Virginia Courts in Brief

Virginia's Judicial System’s mission appears to ensure that unless you are “RICH and POWERFUL”
with the right connections to the “HOOKERS” Club or the “OLD BOY’S NETWORK” you have no
chance to win in an Honest Court in Virginia, as they do not exist.

The Judges are all chosen by the Courts of Justice in “SECRET” and when a case becomes an issue
they bring in a retired Judge to “FIX IT” for the appropriate party of Virginia's Judicial System to assure
that the disputes are handled the way Chief Justice Lemons wants.

The present system consists of four levels of courts: the Supreme Court, the Court of Appeals, the circuit
courts, and the district courts. In addition, magistrates serve as judicial officers with authority to issue various
types of processes. The courts are organized into 31 judicial circuits and 32 similar judicial districts. More than
2,600 people, including judges, clerks, and magistrates, work within the judicial branch of government with the
goal of providing the citizens of the Commonwealth prompt, efficient service.

In December of 2020 the following Judges were questioned by the public:

The Public was treated rudely and ignored. That in January the Judges were re-appointed with no discussion
by the Courts of Justice.

Judge Link

JIRC Members Judge James E
Plowman & citizen Terrie N
Thompson Virginia Courts of
Justice renewal
https://www.youtube.com/watch?v=1dxrZ8kccL4&t=336s
Judicial inquiry review commission aka the JIRC. Reviews the judicial
complaints in Virginia. It basically ignores your complaint of a Judge.

https://www.youtube.com/watch?v=wkt9DZsiUQc&t=555s
Judge Kemler citizens speak at
City of Alexandria Chief Judge Kemler citizens speak at Virginia Judicial
Virginia Judicial Review 11Dec20
Review 11Dec20

Cases of Complaint Mike Field, Janice Wolk Grenadier, Natalia Dalton, Said
Chamone and many more

11
 https://www.youtube.com/watch?v=QY-8lfejP1Y&t=40s
Judge John Tran Fairfax County,
Virginia Judicial Review
Judge John Tran rewarded a Judgeship for what he did to Janice Wolk
Grenadier through the law firm DiMuroGinsberg where Ben DiMuro
announced years ago his donation of 10% of his estate to the Virginia State to
buy his and his buddies freedom of the Ethics Rules and other Rules of the
VSB

https://www.youtube.com/watch?v=fsjM3KC6Quc&t=42s

Judge Carroll A. Weimer Jr Prince

William County, Virginia Judicial Judge Carroll Weimer of PWC further supported and empowered Divorce
Reviews Lawyer Ilona Ely Freedman Grenadier Heckman in the Sonia Grenadier Trust
Thefts through her law firm

https://www.youtube.com/watch?v=pNzcYCEa5LA&t=93s
Judge Pamela O’Berry Judicial
Review Part
The state of Virginia held Judicial Reviews
reviews for the following year December 11, 2020

Judge Pamela O’Berry -
Chesterfield VA Part 2 11Dec20
Judicial Reviews
https://www.youtube.com/watch?v=XP2GUWhQetE&t=29s
On Friday, December 11, 2020 the Virginia courts of justice Senate and
delegates heals The Judicial reviews. Virginia and South Carolina are the only
two states where the legislature chooses their judges. All other states vote on
there judges. The public has the ability to have a say in their Judges.

Matt Skarlatos speaks our against
Judge Thomas P. Sotelo Fairfax
Va
https://www.youtube.com/watch?v=tbUByHOdHT0&t=45s
Virginia judicial reviews by the courts of justice committee of the Virginia
legislature on December 11, 2020

COMES NOW Janice Wolk Grenadier Plaintiff requests the recusal of Judge Padrick who was chosen
by Chief Judge Donald Lemons. That the appropriate authorities be contacted about the collusion of lawyers
and Judges to harm both Janice Wolk Grenadier, Mary Jones and Lawyer Rhetta Daniels et al.

That under the color of law the Judicial Canons, the Professional Code of Ethics and the United States and
Virginia Constitution right to Due Process has been violated. This is a pattern and practice of the State of
12
Virginia to Cover-up the wills of the “Rich and Powerful” also known as “The Old Boys Network”.

Denial of Rights Under Color of Law Violates Plaintiffs Rights—18 U.S.C. §242; 18 U.S.C. §245; 42 U.S.C. §19832.
Federal law provides that it is a crime to violate Constitutional Rights of a citizen under the Color of Law. You
can be arrested for this crime and you can also be held personally liable for civil damages. Bill of Rights and the
Four Basic Freedoms are being Violated:

1. Freedom of speech 2. Freedom of worship 3. Freedom from want 4. Freedom from fear

Attempting to coerce or deceive a citizen to surrender his Constitutional Rights is a Federal Crime

That in the past the courts were able to marginalize and with the press not reporting, able to keep these cases
private and use illegal jailing, large financial sanctions, intimidation, name calling, and threats to control those
seeking justice in the courts.

Today there are several outlets to expose such behavior and to investigate the “pay to play” or the exchange of
FAVOR for what the Judges do.

That the courts when targeting a person, create a situation so there is no funding for a lawyer and all lawyers
are afraid to touch them as they are aware they will lose their Bar License to practice.

JWG through implied covenant of good faith and Fair Dealing continued to fight for a Fair Court hearing to
have her evidence put into the record and fairly judged.. The State of Virginia is paid for services in the Court
that are being denied to JWG and Mary Jones. JWG because she is Catholic and not one of them. The
discrimination and segregation among white exist the power Hierarchy by a member of one that is considered
by others inferior to the other. That the United States Constitution et al calls for Blind Justice / Equal Justice to
all, not to just those with money.

The defendant’s “flagrantly violated” their Fiduciary responsibility to the Judicial System to deal in Good Faith
while Plaintiff who continued to deal in Good Faith. The actions can be proven factually by Orders, Letters,
Documents filed in the court and other. That the constitutional Right of Due Process has been denied time and
time again to Plaintiff and now Judge Padrick continues this practice in Cases:

2
18 U.S.C. §242 provides that Whoever, under color of any law, statute, ordinance, regulation, or custom, willfully subjects any person in any State,
Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution
or laws of the United States, or to different punishments, pains, or penalties, on account of such person being an alien, or by reason of his color, or
race, than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned not more than one year, or both; and if bodily
injury results from the acts committed in violation of this section or if such acts include the use, attempted use, or threatened use of a dangerous
weapon, explosives, or fire, shall be fined under this title or imprisoned not more than ten years, or both; and if death results from the acts committed
in violation of this section or if such acts include kidnapping or an attempt to kidnap, aggravated sexual abuse, or an attempt to commit aggravated
sexual abuse, or an attempt to kill, shall be fined under this title, or imprisoned for any term of years or for life, or both, or may be sentenced to death.

18 U.S.C. §245 provided that Whoever, whether or not acting under color of law, intimidates or interferes with any person from participating in or
enjoying any benefit, service, privilege, program, facility, or activity provided or administered by the United States; [or] applying for or enjoying
employment, or any perquisite thereof, by any agency of the United States; shall be fined under this title, or imprisoned not more than one year, or
both, and if death results or if such acts include kidnapping or an attempt to kidnap, aggravated sexual abuse or an attempt to commit aggravated
sexual abuse, or an attempt to kill, shall be subject to imprisonment for any term of years or for life or may be sentenced to death.

42 U.S.C. §1983 provides every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the
District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in
equity, or other proper proceeding for redress.
13
The State of Virginia has a Fiduciary Duty to insure the rights and safety of JWG in the Court system. Plaintiff
has been harmed by the false statements which are considered defamatory – that Plaintiff has “ THE TRUTH”
which is an absolute defense . The First Amendment of the U.S. Constitution was designed to protect
Freedom of the press. The 1964 case New York Time Co. v. Sullivan radically changed the nature of libel law
by establishing a suit for libel you needed to prove that the information was wholly and patently false or that it
was published “with reckless disregard of whether it was false or not”

“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)” Loving v. Virginia, 388 U.S. 1 (1967) was a landmark civil rights decision of the United States
Supreme Court against discrimination. Which includes being discriminated against because the
Judge’s, lawyers, elected officials and government employees have decided you are not a part of or
one of them.

The right of access to the courts is basic to our system of government, and it is well established today that it is
one of the fundamental rights protected by the Constitution. In Chambers v. Baltimore & Ohio Railroad, 207
U.S. 142, 28 S.Ct. 34, 52 L.Ed. 143 (1907), “The right to sue and defend in the courts is the alternative of
force. In an organized society it is the right conservative of all other rights, and lies at the foundation of orderly
government. It is one of the highest and most essential privileges of citizenship, and must be allowed by each
state to the citizens of all other states to the precise extent that it is allowed to its own citizens. Equality of
treatment in this respect is not left to depend upon comity between the states, but is granted and protected by
the Federal Constitution.”207 U.S. at 148, 28 S.Ct. at 35 (citations omitted). It is clear that the Court viewed the
right of access to the courts as one of the privileges and immunities accorded citizens under article 4 of the
Constitution and the fourteenth amendment

Judge Thomas Padrick continually called Janice Wolk Grenadier a

“VEXATIOUS” litigant the following information will show it is with CAUSE.

WHAT IS BEING IGNORED or is UNKNOWN TO JUDGE THOMAS PADRICK

“THE PAST”

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 Jewish lawyer Ilona Grenadier Heckman, EX-Husband David Mark Grenadier
Erica Grenadier Lewis and their “GANG”

The following is the crimes that began in December 1988 against Janice Wolk Grenadier:

REAL ESTATE AND MONIES CONVERTED FOR THE PERSONAL USE OF DIVORCE LAWYER ILONA
GRENADIER HECKMAN WITH THE HELP OF FAMILY, LAWYERS AND OTHERS

RELIEF SHOULD BE FOR , COMPENSATORY, PUNITIVE, GENERAL, SPECULATIVE, SPECIAL,

INCIDENTAL AND CONSEQUENTIAL, STATUTORY, AGGRAVATED, LEGAL, BAD FAITH, EX
NEGLIGENCE, MALPRACTICE, FRAUD, ABUSE OF PROCESS, MALICIOUS PROSECUTION, TORTS
AND CONFLICT OF LAW, THEFT OF MONEY AND REAL ESTATE, EMOTIONAL DISTRESS, EXEMPLARY

DAMAGES PLUS MONIES COLLECTED AND OWED JANICE WOLK GRENADIER WITH HER
OWNERSHIP OF AT LEAST 24.5 % OF THE 49% OF GRENADIER INVESTMENT (GIC), MONROE AVE
PARTNERSHIP, SOUTHWAY TERRACE FOR FRAUD ON THE COURT AND KNOWLEDGEABLE FRAUD
WITH INTENT TO HARM BY DIVORCE LAWYER ILONA GRENADIER, HER FAMILY, HER LAWYERS,
STEP SON DAVID MARK GRENADIER FROM ON OR AROUND DECEMBER OF 1986

Plaintiff Janice Wolk Grenadier complains against the captioned Defendants 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 :

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 DIVORCE LAWYER ILONA ELY FREEDMAN GRENADIER HECKMAN.

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, Duffett & 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 ½ 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.

INTRODUCTION

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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, 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, joint and several liability,
malpractice, Bribery, Abuse of her Oath of Office, Conspiracy, Collusion, Gang like activity mirror image to the
Klue Klux Klan, 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, 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 courtroom. This is untrue. That the immunity is lost for
actions that are for personal 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
17
(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)).

SOME OF THE PARTIES WHO COLLUDED

6. TROUTMAN PEPPER HAMILTON SANDERS aka Mays & VALENTINE - Jim Arthur helped Lawyer and
Law Firm of Divorce Lawyer Ilona Grenadier Heckman steal Money and Real Estate from Janice Wolk
Grenadier and Sonia Grenadier, Employer of several lawyers who conspired to harm Janice. That ignored
their responsibilities per the Professional Code of Ethics – Mislead and STOLE $30,000. From JWG

7. ERIKA ELY LEWIS – Daughter to Divorce Lawyer Ilona Ely Grenadier Heckman, Married to Timberlake
Lewis. Took ownership of GIC through a Liquidation Agreement done by a lawyer not licensed in Virginia and
without JWG signature Exhibit shows Real Estate and other business with IEG.

8. TIMBERLAKE LEWIS – Husband to Erika Ely Lewis, partner it appears to several businesses’ including
Real Estate with IEG and Erika. That the appearance is that money from properties by law and by right owned
by JWG due to being divorced without a property settlement help to purchase other properties in California et
al

9. DAVID MARK GRENADIER - Ex-Husband to Janice Wolk Grenadier. Divorced in June of 2000 with no
property settlement agreement. Conspired with his mother Ilona to manipulate and steal from Janice starting in
December of 1986.

10. 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 – Albert’s 1st cousin. That the evidence and documents will show as a lawyer
through her law firm stole money, real estate and Herman Grenadier’s 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. –

11. GRENADIER, STARCE, DUFFET & LEVI P.C. - Employer of several lawyers who conspired to harm
Janice. That ignored their responsibilities per the Professional Code of Ethics

12. DIMURO GINSBERG - Employer of several lawyers who conspired to harm Janice. That ignored their
responsibilities per the Professional Code of Ethics Attorneys Ben DiMuro, Andrea Mosley, John Tran, Hillary
Collyer Ben Dimuro in April of 1989 met with JW and her then husband David to discuss a fire that he was
representing GIC/Monroe Ave partnership for the overage on the insurance.

Wrote a threatening letter that JWG was trying to Extort money from Ilona ~ Money that Ilona owed JWG from
malicious manipulation, and stealing it from JWG. That he used his power to manipulate an investigation by the
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Commonwealth Attorney Randy Sengel who after JWG corporates with the Police declared JWG innocent and
that she was only going after monies and Real Estate owed to her by right and by Virginia and Federal Law.

Past President of the Virginia State Bar VSB President-elect

Bernard J. DiMuro and his wife, Sandy, have designated 10% of their estate to the Virginia Law Foundation.
DiMuro is the first Virginia attorney to make a gift of this kind to the VLF, according to VLF Executive Director
Sharon Tatum. DiMuro said he wanted to make a law-related donation to an entity with the ability to administer
the funds effectively.

A Big part of the Old Boy’s Network and through Collusion and Power has kept everyone in check to protect his
paying client Ilona

Lied in Respondents’ Joint Motion to Dismiss Petition for Appeal Dated Feb 2, 2011 in the Supreme Court
of Virginia on Page 2 Paragraph 2 ~ Here, Petitioner has failed to ensure that the record contains either
transcripts or a written statement of facts

13. MICHEAL WEISER, ESQ – Commissioner of Accounts, Lied in Respondents’ Joint Motion to Dismiss
Petition for Appeal Dated Feb 2, 2011 in the Supreme Court of Virginia on Page 2 Paragraph 2 ~ Here,
Petitioner has failed to ensure that the record contains either transcripts or a written statement of facts

14. PARKER, SIMON & KOKOLIS, LLC - Employer of several lawyers who conspired to harm Janice. That
ignored their responsibilities per the Professional Code of Ethics

15. ALPS INSURANCE – Insurance Co.by all appearance to the above attorneys. The only Insurance Co. that
the VSB (Virginia State Bar) has on their website. Has ignored all attempts by JWG to collect on the
malpractice of above lawyers.

16. Many other unknown and known actors

BACKGROUND

19. Janice met Defendants David, Ilona and Erika around March of 1985. That Janice was naive and in many
ways very easily manipulated by David and Ilona. At the time she met David she was still filling the effects of
having not finished college due to her apartment being broken into and raped, and now a failed marriage.

20. That David and Ilona started their manipulation with knowledgeable intent around December of 1986.

21. That the first lie that Janice can recall was February 14, 1986. Ilona was very specific having just married
Jerome (Jerry) Heckman the 1st cousin to Judge Albert Grenadier who had just passed March of 1985. Ilona
stated and was so excited how Jerry had added her to his will. Janice found this odd, but in or around April of
2014 learned that what Jerry had done that day was give up his rights to a property she by all appearance had
stolen from Sonia Grenadier – and taken a portion of $521.000. Pay off for the sale of a portion of the property.

22. That David and Ilona started a Real Estate Partnership called GIC in or around 1985 that Janice started
contributions thru loans, advice along with a partnership call Bellefonte Ave on or around December of 1986.
23. That David and Janice would marry in September of 1988 which in or around 1998 Janice would learn that
David never loved her – and that he and Ilona had used her, manipulated her and she was no longer needed.
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That JWG has Taped conversations - that state “She never WORSHIPED him the way Mary Drake did” Mary
Drake is the girlfriend he took up with.

24. That in or around March of 1990 Janice would learn that money had been stolen out of a Trust Account of
Sonia Grenadier through the Grenadier Law firm.

25. That Lawyer Ilona would tell Janice she is to speak to no one about this. Everything goes through her, that
she will handle everything as an attorney through Grenadier Law. The slippery slope, the manipulation of the
fear as Ilona made it clear to Janice who was pregnant and just had a miscarriage that if she spoke about this
to anyone that David would go to jail and be raped repeatedly – and that my child would being visiting him in
jail. Ilona knew of my rape and used it to manipulate and to protect herself from being found out.

26. Janice was manipulated by Ilona into believing that it was David who stole the money. That in or around
May of 2008 - Ilona would admit to Janice that David did not steal the money which only left Ilona - Which the
slippery slope of the Criminal Acts, the Knowledgeable intend of the extreme Divorce Lawyer Ilona Grenadier
Heckman would go for money started to unravel, that the :”TRUTH” supposedly your best defense would all of
a sudden have no meaning to the Judiciary in Virginia and Washington DC. The thefts with the help of the 9
Judiciary began in or around November of 1983 with the Forgery of Sonia Grenadier’s name on an
Amendment to her Trust giving Ilona Grenadier access once Judge Albert Grenadier died and the COVER UP
to protect one of their own began in or around 1990 with the help of Fagelson et al law firm and Mays &
Valentine aka Troutman Sanders.

27. Then on or around September 3rd of 1997 on an unexpected cab ride to the airport as David was
supposed to drive Janice to the airport and was late, Janice was outside waiting and not in her home. Janice
had called him to find out where he was – David started yelling at Janice and saying a cab was on the way.
Janice can presume now his disappointment the money it appears he and Ilona spent to have Janice killed has
come back to haunt them. When Janice got in the cab and the driver could hear David yelling he said to Janice
hang up the phone, hang up the phone if you don’t hang up the phone I will pull over and hang it up for you.
Janice hung up the phone, the driver than said we can take care of that for $5,000.00 – you don’t have it – then
$2,000 we can work it out. Janice was handed a phone number, Janice tossed it in the trash can thinking it had
been a set up – Janice now believes without question it was to be a hit and today she was to be dead. Janice
has never been questioned by the City of Alexandria Police or the FBI even though she has reached out
several times with her information.through Commonwealth Attorney Brian Porter & Sheriff Lawhorene (who had
her tortured in jail)That in February / March of 1998 Nancy Dunning who would open her front door in 2003
came to Janice on different occasions to check on her safety. The question now arises was Nancy aware of the
outcome that was meant for Janice in September of 1997.

28. That the above is important because where Janice live’s in a circle around Janice thier have been 5 known
Murder type hits – Dr. Rixsey, John Doe, Nancy Dunning ( Nancy came to Janice’s home twice to check on
Janice, now believed Nancy knew more and was from what Nancy said afraid of what could happen and
maybe knew what was going to happen to her) Ron Kirby and Ruth Ann Lodato. That all five have strong
connections to the Old Boys Network. That the appearance and whith the Facts Janice knows that the people
who have been charged and found guilty of these charges of murder and the reson behind them was
fabricated to protect the Old Boys Network of Virginia. That further situations / evidence will show that
thoughout Northern Virginia hit men are hired and it is a pattern and practice of the Old Boys Network in
Virginia – to either have someone killed or to Bully them till they committ Suicide.

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29. November 1997 That Lawyer Ilona in collusion with David Grenadier, Andrea Grenadier, Robin Grenadier
passed a rumor around that caused David Grenadier to pull a gun in the home with Janice’s girls in the
home.

30. That on or around November 17, 1997 David, Ilona and Erika would sign a Liquidation agreement of
several properties that are all owned in Virginia and a Virginia Partnership done by a Lawyer not licensed or
never has been licensed to act as a lawyer in Virginia. Ilona being a divorce lawyer knew the law and acted
criminally as she had done with the Sonia Grenadier Estate for personal financial gain using her law firm and
POWER of the men she married to manipulate / Scheme / Scam those that were not as strong or did not know
the law or who would ignore the law for her.

31. That in or around June of 2000 David and Janice were divorced without a property settlement.

STATEMENT OF FACTS

33. That on or around September 5, 2007 the Slippery Slope of the Cover up of Ilona Grenadier Heckman with
the help of the other Defendants would begin with September 5, 2007 - Janice Filed with the Alexandria Circuit
Court a Motion for Reinstatement of the Bill of Complaint of 28 E Bellefonte Ave Partnership. The notification to
the parties to be served through the Sheriff’s office. The court date for the Motion to be heard was on
September 12, 2007.

34. On or around September 12, 2007 - Motions Day Judge Kloch hears the case. This resulted in the Filing of
the Motion for Default filed on September 21, 2007. As the Motion for Default goes into more detail Ilona was
disingenuous in court claiming she hadn’t been served. But, Ilona couldn’t have known of the court date unless
she was served. Ilona admitted in court to Judge Kloch that David Grenadier’s attorney Mr. Michael Weiser
was aware of the court date because Ilona had faxed the information to Wieser. Judge Kloch kept passing it
over to give Mr. Weiser the chance to show up. He then sent a clerk down to the Sheriff’s office who then came
back and according to Judge Kloch said that Ms. Ilona Grenadier nor Mr. Weiser had been served according to
their (the Sheriff’s) records. Janice explained to the Judge the only way Ilona could be there was if she was
served. Mrs. Ilona Grenadier admitted to having the information and faxing it to Mr. Weiser. At which point he
dismissed everything to be re-heard. Ilona a lawyer had not been telling the truth when she said she
hadn't served been served. The Slippery Slope begins for a fight for Judge with Jurisdiction that is not
ruling on Favoritism and Cronyism.

35. After Court Janice went down to the Sheriff’s office. Janice was given a copy of Ilona’s service. Mr.
Weiser’s papers were not in the box, and as his office is basically the same building they couldn’t say whether
he had been served or not. To this day the papers are missing and have never been returned to JWG. It should
be noted that Mr. Weiser’s office is in the same building as the CourtHouse and Sheriffs, who claim to not have
served him.`

36. September 21, 2007 - Janice filed for the Motion for Default, and The Motion to Reinstate (just in case) for
October 10, 2007. - Motion for Default filed (written by federal Judge in DC)

37. October 10, 2007 – All the Alexandria Judges have recused themselves from hearing it and they need to
bring in an impartial Judge. This is the start of shopping for Judges that would rule in favor of Lawyer
Ilona. Even when Ilona would brag afterwards about her relationship with the Judge and how he had called her
when he was practicing law and she would help him out

21
38. October 17, 2007 Letter from Diane Fiske – After informing Janice that the Judges had recuse
themselves she would be finding Judge’s to hear the case. Judge Frank A. Hoss was available for November
28, 2007 at 10.00 am. At the time of this letter the Judges were:

1. Judge Donald M. Haddock – We learned in the Spring of 2008 he had recused himself from
hearing the case, yet continued to choose the Judges after declaring his “LOVE” for Ilona.
2. Judge John E. Kloch – Ilona had lied to him in court on September 5, 2007 – He could have
heard the Motion for Default as he knew the truth – Recused himself with letter of apology and
Statement Appellant deserved a fair hearing and that “The appearance of Justice was just as
important as Justice itself”
3. Judge Lisa Bondareff Kemler – Her Father was our pediatrician for Janice’s girls, David had
gone to Hebrew School with her, His father and her father were good friends, Janice had shown
her and her husband Real Estate.

39. November 15, 2007 – Letter from Diane Fiske that the Motions Date had been changed to Wednesday,
December 5, 2007 @ 10.00 am - this had been filed on September 21, 2007 – Is now being heard on
December 5, 2007. Where most Motions are heard 7 days later this took 2.1/2 months to be heard. By all
appearance due to the need of shopping for a Judge.

● The three (3) attached letters from Diane Fiske court administrator shows the City of Alexandria Circuit
Court did not make a mistake. The actions of the City of Alexandria Circuit Court were knowingly
and malicious to shop for Judges that would Rule in favor of attorney Ilona Grenadier Heckman.
That Judge Hoss from Prince William County had in 1990 recused himself from hearing any cases that
involved Ilona Grenadier Heckman. By all appearance he knew it was inappropriate for him to hear this
case. In the Motion to Re-Open due to the Fraud on the Court is signed by Judge Hoss of Prince
William County. That once Judge Hoss by all appearance recused himself a 2nd time. The
Judge’s in the Circuit Court cannot say any longer a mistake was made. The Judge’s in the Circuit
Court of Alexandria knew exactly what they were doing. That they knew of the Supreme Court rule
Supreme Court Rule §17.1-105(B) and chose not to follow the rules

● Dated: October 17, 2007, November 15, 2007 That pertains to Judge Frank Hoss who had recused
himself back in 1990 and by all appearance recused himself again.

● Dated: May 13, 2008 sent just a few days after Chief Judge Haddock explains to Appellant “You will
never get a fair Trial “WE LOVE ILONA'' These letters expose the collusion of the Circuit Court
Judges in the State of Virginia – FRAUD ON THE COURT – TREASON on the Court. This by all
appearance shows the disingenuous behavior of the Supreme Court of Virginia in ignoring their own
Rules and Laws to protect one of their own.

● December 5, 2007 - Judge Thomas A. Fortkort. Denied Janice’s Motion for Default. It should be noted
the Motion for Default was a suggestion & outlined by a Federal Judge from DC.
●
● December 2007 - Janice Asked Diane Fiske Several times about a Fair Judge – she informs Janice 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): Learn of June of 2010 of the Supreme Court of Virginia:

22
 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

40. February 8, 2008 - Janice receives a Letter From Ilona Grenadier (on her law firm stationary) to Janice
Wolk Grenadier, Ilona Grenadier asserts ownership of 75% of a property Known as 28 East Bellefonte Ave,
Alexandria, VA 22305. Janice felt threatened by the letter which is full of misleading and deceitful
statements.

41. February 13,2008 – Judge Brown hears Motions * Ilona is not in court Heather Jenquien represented
her. Motions to compel -

42. February 26, 2008 – Filed with Clerk of Courts following letter: Because keep in mind all Judge’s had
recuse themselves and all Motions had to go through Diane Fiske as she needed to shop for a judge or it had
to be on a day they had a visiting Judge that would rule in collusion with Judge Haddock’s “LOVE” for Ilona.
The letter asks Ilona for dates to get back to Diane Fiske to file a Motion as no Motion’s could be filed without
everyone’s ageing on the date before Diane found a Judge.

43. February 27, 2008 - Ilona Grenadier filed on February 27, 2008 with the Circuit Court of The City of
Alexandria an Answer to The Amended Bill of Complaint claiming 75% ownership of the property at 28 East
Bellefonte Ave., Alexandria, VA 22305 which is a documented lie. Most of Ilona Grenadiers statements in the
Answer to The Amended Bill of Complaint were disingenuous which Plaintiff has supplied documentation to
VSB for the purpose of establishing the truth. The following are the lies Ilona Grenadier Filed with the Circuit
Court of Alexandria
1. 75% ownership
2. That plaintiff has provided no proof of actual payment for expenses - provided 3 times to defendants
3. JWG Bankruptcy caused by Bellefonte as JWG in & out - Which now JWG realizes she would never
had been in and out if it wasn’t for the manipulation and lies of Ilona Grenadier
4. 4 times Ilona - “Defendant, Ilona Ely Grenadier, denies that JWG owns or owned 50%of East
Bellefonte

44. The document on February 27, 2008 by Ilona Ely Grenadier a lawyer was riddled 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 Ilona Grenadier which had several conflicting
statements. The amount of money Ilona Grenadier put into the property can be established by an accounting
done by Ilona Grenadier. 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 Ilona Grenadier had. Ilona Grenadier 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.

45. March 5, 2008 – File 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

23
 2. For all the untruths told in the Answer to Bill of Complaint by defendant and Counterclaim and
CrossComplaint filed on February 27, 2008.

3. For the letters Lawyer Ilona sent bullying, threatening attached to the February Response to Ilona Ely
Grenadier/GIC Motion to Quash Janice’s Amended Complaint / 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.

46. March 5, 2008 – Filed Motion to Change Date for: Notice of Deposition and to Set Date for Trial – As
Lawyer Ilona would not respond to any correspondence.

47. March 11, 2008 – Plaintiff files – Praecipe - remove Motions for March 12, 2008 no visiting Judges. As
ordered by Judges Chambers.

1. Clerk of the Court will please remove from the docket on March 12, 2008 Janice Wolk Grenadiers
Motion to Compel as there isn’t a visiting judge available to hear it.
2. This again shows that the Circuit Court Judge’s had recused themselves. That Janice though out the
case voiced her concern on getting a fair Trial. To the deaf ears of the Circuit Court of Alexandria who
took the arrogant view of doing whatever they wanted to do.

48. April 30, 2008 – Parcipe re-file to have Motion for Default heard as Diane Fiske has found a date that
works for the Judge’s of Alexandria to find a Judge of there choice – for May 7, 2008

49. May 7, 2008 – Motions heard by Judge Brown – Ilona after court informs me after he has ruled in her favor
allowing her to file false papers as an attorney in the Alexandria Circuit Court of law What good friends she and
Judge Brown are – and how he called her all the time for legal advice.

50. On or around May 7, 2008 After Court ~

1. Lawyer Iloan Grenadier again brags about her relationship with the Judge’s - That she has in the
past & continues to give Free legal advice to Judge Brown.

2. Lawyer Ilona Grenadier explains to Janice why no one has anything to do with Janice’s
children is because Janice raised them Catholic. In 19 years she has seen the girls once by her
choice.

3. Lawyer Ilona states: That Janice should be grateful to her for the listing on Holland Road. So
Lawyer Ilona could steal the commission

4. That Ilona doesn’t believe David Stole the money from Sonia Grenadier’s Trust - which only left
Ilona Grenadier and her law firm to steal the most likely over $95,000.00 and Real Estate

5. Janice introduces herself to Judge Haddock after he speaks with Ilona – he explains to Janice “I
could never get a fair trial as they all Love Ilona” JWG turns to Diane Fiske shocked by the
statement and expresses Janice can’t believe he just said that to me.

6. Again Janice asks Diane Fiske about getting Judge’s that aren’t friends of Lawyer Ilona’s.

24
51. May 13, 2008 – Letter from Diane P Fiske that the case would be heard by Judge John J. McGrath. This
letter shows the following Judge’s in the letterhead:

1. Donald M. Haddock
2. John E. Kloch (Retired) which means at the time Judge McGrath was chosen Judge Kloch and
Judge McGrath were working together.
3. Lisa Bondareff Kemler

52. June 18, 2008 – JWG Files: Motion for Default - Ilona has lied in the Admissions USING THE
STANDARD A FEDERAL JUDGE HAD ADVISED JWG TO USE

A. For Ilona 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 Lawyer
Ilona and Counterclaim and Cross Complaint

C. For lies in Admissions by Lawyer Ilona

D. For the letters Lawyer Ilona sent Bulling & Threatening Janice if Janice didn’t drop suit

1. Motion for Trial by Jury – Due to comments made by Judge Haddock & Lawyer Ilona Grenadier

A. Judge Haddock telling Janice she could never get a fair trial as they all “LOVE” Ilona

B. Lawyer Ilona informing Janice all the Judges were friends of hers & Lawyer Ilona gave them
free legal advice when they called her

53. July 2, 2008 – Motion to be heard July 9, 2008 to include:

1. Motion for Trial by Jury

2. Motion to Compel
3. Motion for Default

54. July 28,2008 1 st Complaint - Virginia Bar Complaint Outline / Ilona Ely Freedman Grenadier Heckman
VSB Docket # 09-NAT-076104

1. That Lawyer Ilona lied in court on September 12, 2007 All facts can be found in the Motion for
Default Dated September 21, 2009 Which a copy was sent in with the complaint

2. Letter from Mrs. Ilona Grenadier suggesting Janice had better drop the suit Dated February 8, 2008

3. Ilona presented false statements in her Counter Claim and Cross Complaint which can be proven
through her own documentation. These false statements were filed and are in Court Record.

55. July 9, 2008 – Judge Howe Brown (as Lawyer Ilona calls him a very good friend she often gives free legal
advice to) – rules :

1. Denies motion for Default

25
 2. Denies motion for Trial by Jury
3. And makes both sides work on response’s in the Motion to Compel- Even though Janice had 110%
Answered

56. Spring of 2008 Diane Fiske again advised Janice the only way anyone else would choose a Judge was if
they couldn’t find one then it would go to the Supreme Court and they would then choose the Judge. Which
was incorrect / deliberate misleading, Obstruction of Justice.

The minute in September of 2007 when the Judge’s had recuse themselves is when the Supreme Court
should have been choosing the Judges, not the Judge’s themselves or Diane Fiske should have been
choosing the Judge. The Head Judge - Judge Haddock was talking and hugging Ilona while I was
talking with Diane Fiske about Fair Judge’s that were arm's length. When Ilona left I turned to Judge
Haddock and introduced myself which he then went on to inform me “ I (Janice) wouldn’t get a fair
trial because they all “Loved Ilona” “.

Judge Haddock is the Head Judge at the Alexandria Circuit Court. I then turned to Diane Fiske – in
shock – and said I can’t believe Judge Haddock just told me “I would never get a Fair Trial because
they loved Ilona”.

57. August 4, 2008 Janice received a letter from Mr. James C. Bodie saying they would not be taking action
against Ilona. Janice then did pursue it and asked them to review it again after sending in more information.
Janice was also turned down on the review. I was basically told because Ilona wished for a different outcome
her behavior was acceptable to the Virginia Bar, Lying in court, Lying in court documents.

58. September 11, 2008 – Thursday Judge John McGrath (chosen by Judge Donald Haddock and
working with Judge Kloch) Court Date - As Justice Douglas would call it “Kangaroo Court”

A. Conference in Judges Chambers – Only Ilona & Janice didn’t include David – Janice in retrospect
was told by another member of the Old Boys Network that she would lose and now realizes how this
and other actions had been discussed and decided to protect one of their own.
B. Judge Kloch hanging outside the door during the conference and the trial. Who if he didn’
C. Sonia Grenadier Trust – brought up in opening By Ilona & David and Janice was questioned about it
by Ilona – Janice was denied entering evidence or bring it up
D. Judge McGrath – Won’t let Janice bring up Sonia Grenadier Trust & Doesn’t understand it – won’t
take time to understand
E. Judge – Warns Janice on how Janice can question Ilona
F. David Grenadier lies under oath – move on per Judge McGrath perjury by David or Ilona was/is
acceptable by the courts
G. Judge McGrath & Judge Kloch had a very friendly Lunch at Jackson 20 – to discuss how to show
appearance of being fair but, to SCREW Janice, as she is no longer one of the Old Boys Network.

59. Janice is sure something is off and contacts Randy Sengel – Commonwealth’s Attorney – Informs me that
Judge McGrath has done a lot of work in Alexandria Circuit Court

60. Janice Calls JIRC Commission –Donald Curry good friend to Judge McGrath was raised in Arlington

61. Alexandria Circuit Court – Yes McGrath is from Harrisonburg – But, has several ties to Alexandria & is
working w/ Judge Kloch – guess they just didn’t think that was important
26
62. Janice Files complaints w/JIRK Commission of course I didn’t have all the information and Donald Curry
who makes decision is friends w/ everyone

63. September 22, 2008 – Monday - File Motion for Reconsideration With new evidence that had been
dropped off at Appellants house - A letter that David Ellsberg the Settlement attorney for Bellefonte had me
write him that showed I was loaning the money to Ilona / David / GIC

64. September 24, 2008 - Diane hears back from Judge McGrath – doesn’t want to see new evidence or any
Exhibits – Faxed to him – never seeing Exhibits immediately Denies

65. October 21, 2008 – Janice Mailed from Alexandria Virginia a complaint against Judge John McGrath to his
good friend Donald Curry w/ the JIRC Commission, after a phone conversations with Mr. Curry, where Mr.
Curry informed Janice “sending a complaint would be a waste of time as Judge McGrath was a good friend of
his”.

66. October 23, 2008 – Donald R Curry Counsel for JIRC sends Janice the following( after telling Janice on
the phone not to bother with a complaint :

“This is in response to your complaint dated October 21, 2008. Based upon what you have submitted
and alleged, we have found no basis for a conclusion that there has been a violation of the Canons. A
mere “belief” that an ex parte communication occurred, without more, does not provide a sufficient
basis for Commission action. Please be advised, moreover, that the judge about whom you complaint is
a retired judge from the 26th Circuit. “

67. October 27, 2008 – Janice Fax to Randy Sengel with copy of Complaint and response to JIRC
Commission. How outrageous it was. – Randy suggested Janice address members directly.

68. November 12, 2008 – Janice Reached out to each member of the Courts of Justice by Phone or Fax

1. Judge Larry D. Willis

2. Honorable Virginia L. Cochran
3. James F. Fisher Esq
4. William I Fitzgerald
5. Judge Cleo E. Powell
6. Olivia A. Welsh
7. Kenneth Motero 804-786-6634 - Boss to Donald Curry
8. Tim Kaine - Governors’ office 804-786-2211
9. Bob McDonnel - Attorney General 804-786-2071
10. Donald Curry – General Assembly
11. Department of Human Resources Mgt 804-225-2131 Carol Supreme court - HR

Virginia House of Delegates – Courts of Justice

1. Dave Albo – Chair
2. Pamela Burham

Virginia Senate –
1. Henry L. Marsh III – Chair – Contact Comm operations (804) 698-7450
27
Delegate - Alexandria
1. David Englin – 804-698-1045 703-549-3203

Senator
1. Patsy Ticer 804-698-7530 703-549-5770 Spoke with detail to Peggy Fax# 703-739-6761 - Gave me
Mr Henry Marsh’s number - information

Congress
1. James Moran

69. November 12, 2008 – Fax to Henry Marsh – Jackie Parker copy of complaint

70. November 12, 2008 – Fax to Dave Albo after horrid conversation. Dave Albo supports the corruption by all
appearance and actions of the Judiciary, the Government and Elected Officials.

71. November 12, 2008 – Fax: Donald Curry adding letter date May 8, 2008 that Ilona had written to Janice,
that Judge McGrath had used in making his decision on this little meeting prior to court. Which in 45 minutes
he would never had found in a file that was about 8 – 10 inches in paper work.

72. November 13, 2008 –Letter from Donald Curry that the letter I had sent didn’t change his mind that there
should be an inquiry into Judge John McGrath.

73. November 13, 2008 – letter from Henry L. Marsh lll - He referred me to The Chief Justice of the Virginia
Supreme Court as he was in charge of Substitute Judges. – Chief Justice Leroy Rountree Hassell, Sr. 100
North Ninth Street, Richmond, VA 23219.

74. December 8, 2008 - Fax info to Donald Curry he is of no help

75. December 8, 2008 – Calls to Chief Justice Leroy Rountree Hassell Sr. requesting a meeting – spoke with
Chief Deputy Clerk – Leslie David to put the complaint in writing.

76. December 10, 2008 – Letter from Donald Curry of Judicial Review they are not looking at my complaints –
They are friends of the Judges.

77. December 18, 2008 – Reach out to John McGrath to get him to do the right thing – no word back From the
letter – Pleading with him to do the right thing and reconsider the Motion for Reconsideration or at least be
respectful and look at the new evidence. Sent him several emails giving him more evidence and do the right
thing.

78. December 18, 2008 – Janice learn from the internet that Judge John Kloch is now working with Judge john
McGrath Jr. with a firm called Judicial Solutions’ PC *In a Letter from Judge John Kloch –Which even makes
this more of a conflict of interest. Not an arm's length situation. If it isn’t enough to have the Commonwealth’s
Attorney tell you Judge John McGrath has done a lot of work in the Alexandria Courts.

79. April 29, 2009 ~ Virginia Bar Complaint #2 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
28
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.

JWG attached much evidence to this of Ilona being very disingenuous. With all her statements she made and
how she misled 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 has been combined and looked at
together.

***Appellant feels 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.

*** An attorney who teaches Ethics for the VSB helped Appellant to write complaint

80. In the later part of 2008 – 2009 Janice reached out to Karen, Andrea, Robin Grenadier and the family of
Ruth Grenadier to apologize and inform them of the “TRUTH” of what Ilona an attorney had stolen from the
Sonia Grenadier Trust. Through the Grenadier et al law firm. After Ilona informed JWG that JWG should be
grateful to Lawyer Ilona for Lawyer Ilona giving Janice the listing on the property called Holland Road it started
to became clear to Janice the manipulation and the lies and collusion of Lawyer Ilona and 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 Lawyer Ilona will be able to show through pay stubs, through financial
statements and accountings done by Janice that it was with her knowledge this money was stolen out of her
law firm. That trying to silence Janice is about the “TRUTH” of the Money, Real Estate and other things stolen
from the Sonia Grenadier Trust -

81. The facts – The accountings cannot be changed. Ilona Grenadier / Lawyer / has been misleading and
manipulating family members, lawyers, judges since the death of Judge Albert Grenadier.

82. On or around February 9, 2009 an email 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.
29
 Love,

83. On or around April 16, 2009 Threatening Letter from Ben DiMuro charging JWG with acts of Extortion. The
Slippery Sloop of the Corruption in the Old Boys Network goes into full force

84. July 2009 _ Letter Chief Justice Supreme Court of Virginia - ignored

85. June 21, 2010 - Letter to Patricia L. Harrington – Supreme Court Clerk - ignored

86. August 2010 Virginia Attorney – Calls Diane Fiske – she confirms all the Judge’s in The Alexandria
Circuit Court had recuse themselves in September of 2007

87. July 2010 Janice Confirms the Rule 17.105 (b) with the Supreme Court

88. July 12, 2010 e-mail to Lawyer Ilona that Janice was filing Motion for Default to be heard on September
21, 2010 – which was originally to be heard on July 28, 2010

89. July 13, 2010 – File Motion

90. July 26, 2010 w/ 4 min left Michael Wieser files he can’t be there – in collusion with Judge’s by all
appearance and ex-parte communications

91. On or around July 28, 2010 – Ilona files Opposition – weren’t we supposed to be in court on the 28th ?
when she knew

92. August 4, 2010 – After being reprimanded by the Circuit Court about contacting everyone – being treated
rudely now every time Janice calls the Alexandria Circuit Court – Janice files Motion to be heard on August 11,
2010

93. August 11, 2010 – Judge Kloch – visiting Judge

94. August 11, 2010 – Janice is informed my The Circuit Court they will not take her phone calls or any
messages from her

95. August 12, 2010 – Janice receives an e-mail - Judge Kloch – Decides to recuse himself – works with
Judge McGrath

96. Quote from Judge Kloch’s letter “I believe strongly that the appearance of justice is equally important
as justice itself”

97. January 20, 2011 - Janice Appeal to Supreme Court - Record # 110156

98. February 2, 2011 Lawyer Ilona -Letter Ben Dimuro Giving notice file dismiss of Petition for Appeal

99. February 3, 2011 IEG By Lawyers Ben Dimuro / Michael Wieser Joint Motion to Dismiss Petition for
Appeal

30
100. February 8, 2011 Janice Petitioner’s Response to Respondents Joint Motion to Dismiss Petition: For
Appeal - 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 to Made a part of Record in accordance to
Supreme Court Rule 5:11 (c) (1) and (2).

101. February of 2011 after many phone calls starting on around November 3, 2008 with assistant to Patsy
Ticer a meeting is had –even though I live walking distance in Alexandria – to have meeting I had to go down
to Richmond which she was still toooo busy to meet with me and set me up with an older women who claimed
to be her assistant – I would find out later that was a “LIE” Instead: set me up with Martha Kent x-wife of
Judge Kent.

I will not be spineless like Martha Kent and Patsy Ticer and allow a bunch of overgrown “BULLIES” to control
me as they have them. After listening to my story – she said to me

● “ Do you know who I am?” no

● “I am the x – wife of Judge Donald Kent” Martha Kent
● “I have walked in your shoes – you can’t win this”
● “ Me and My family can’t get a fair trial either”
● “ You are no longer one of them

That is when a few more pieces of the puzzle as to who was the King of the Old Boys Network started falling
into place – Who was behind this - it is and was her x-husband Judge Donald Kent best friend to Judge Donald
Haddock – on the bench at the same time as Judge Grenadier. Judge Haddock chose all my Judges and
stated to me “You will never win this – WE LOVE ILONA” - Judge Haddock and Judge Kent by all
appearance have done everything they could for there “LOVE” Judge Donald Kent was a Judge when Judge
Albert Grenadier was in the City of Alexandria by all appearance, and supports the “LOVE” Judge Haddock
has for Lawyer Ilona.

102. February 10, 2011 Ilona Joint Brief in Opposition to Petition for Appeal

103. March of 2011 – City of Alexandria police, Fire and Ambulance come to the home of Janice Wolk
Grenadier while she is on travel – Janice is supposedly “DEAD” in the home? There is no record of this in
the City of Alexandria. Two neighbors have confirmed this with Janice and the one who convinced the police to
not hack down her door but to allow him to open it with the key he had. It was not till June of 2011 when
Janice’s neighbor shared this with her she became aware of it. When researched there is no record yet two
other neighbors have confirmed this.

104. May 4, 2011 Supreme Court of Va Letter to Janice May 24, 2011 Oral Argument

105. May 24, 2011 Janice does: Oral Argument in Richmond

106. June 20, 2011 Supreme Court Deny Petition– Ruling against their own LAW Va. Code 17.105(b) to
protect one of their own, for the “LOVE” of Judge Donald Haddock.

107. June 27, 2011 Janice Petition for Rehearing

31
108. September 20 , 2011 Supreme Court Deny Petition for Rehearing

109. September 21, 2011 Janice Letters to Judges Brown - McGrath - Fortkort - Dawkins - Haddock - That
Janice planed on suing them 110. September 27, 2011 Janice Letter Sengel & Haddock for Grand Jury
111. September 29, 2011 Sengel Letter to Janice no Grand Jury

112. October 11, 2011 Janice Files Praecipe to be heard in front of Regular Grand Jury

113. October 5, 2011 Commonwealth Attorney Randy Sengel Letter to Janice no not going to let me in front of
Regular Grand Jury

114. October 6, 2011 Janice letter to Sengel October 6, 2011 - Janice - letter to Ed Semonian – Clerk of Court
of the City of Alexandria

115. October 7, 2011 Sengel email receipt of letter and sent Ed Semonian his letter

116. October 11, 2011 Refused Grand Jury - Grand Jury Case # M01101482 – October 2011 - Denied
access to the Grand Jury and kidnapped with witness into another courtroom. Even with a Demand from
the Supreme Court Justice Cynthia Kinser to Be allowed into the Grand Jury to request a Special Grand Jury
to review the Corruption

117. October 14, 2011 Janice Letter to Judge Haddock

118. October 14 , 2011 Sengel Letter Judge Haddock retires end of December 31, 2011

119. October 20, 2011 Janice files in the Eastern District Court of Virginia
Complaint-Conspiracy to interfere with the Civil Rights 18 USC 241 & 42 USC 1983 Illegal Actions to
Deny Access to Grand Jury. Trial by Jury. & More Emergency Motion for injunctive Relief

120. October 31, 2011 Janice Letter to Judge Lee exposing the Corruption – Ignored a pattern and practice of
the Judiciary

121. November 9, 2011 Fed Court Order: a. Deny Request for in forma Pauperis due to claim is Frivolous-
which is and still is libel and slander to a ProSe Litigant. Denial of Due Process to someone for Being Poor.

122. November 16, 2011 Letter from the Circuit Court of Alexandria that the Supreme Court had conflicts with
the date of December 12, 2011 due to schedule conflicts. – The Circuit Court of Alexandria had not filed
documents in a timely manner

123. November 21, 2011 Supreme Court Letter Judge Potter to sit on Grand Jury of February 13, 2012 -
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.” Order from the Supreme Court for Judge Potter to assist Alexandria
Circuit Court

124. November 23, 2011 Janice Files with Fed Court:

32
 i. Petition for Reconsideration of the “Frivolous” Order of 9 November 2011 Complaint - Conspiracy to
Interfere with the Civil Rights 18 USC 241 & 42 ISC 1983 Illegal Actions to Deny Access to Grand Jury
Trial By Jury

125. ** Janice - Learns about the Magistrate can also bring charges - Calls City of Alexandria Magistrate BALL
to learn that he requires a Police Report - Janice then calls Detective Pak to ask for Police Report #
126. In the month of November of 2011 Janice Police 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. Janice
believes there to be an obvious Collusion between Randy Sengel, Ben DiMuro to assist Lawyer Ilona in
intimidation of Janice.

127. December 20, 2011 Ms. Slaughter Federal Judge Bruce Lee’s Secretary lies to Janice

128. December 21, 2011 File Motion to be heard in Federal Court January 6, 2012 - denied as Judge Lee is
out of town?

129. December 22, 2011 File in the Supreme Court of Virginia - Petition for Writ of Error Coram Vobis -
Alexandria Court Illegal Actions to Deny Citizen Right to Trial by Jury and Grand Jury

130. January 4, 2012 Letter Randy Sengel Commonwealth Attorney to Judge Potter informing him to refuse
Janice in front of the Grand Jury as Janice is not one of his witness’s

131. Janice contacts Supreme Court regarding letter and informed anyone can write to a Judge from

132. January 4, 2012 Letter from City Attorney Meghan S. Roberts threatening Janice with legal action over
$200. For infractions of code a gutter & RV parked in my driveway. Collusion with Randy Sengel in attempt to
Scare Janice and try to distract and cause more harm. Spring Street Gutters / RV Case # GV 12 – 3028 -
Question should be: How often does an attorney write a threatening letter over $200. to a homeowner?

133. January 4, 2012 Letter from Meghan S. Roberts threatening Plaintiff with legal action over $200. For
infractions of code a gutter & RV parked in my driveway. Collusion with Randy Sengel in attempt to
scare/intimidate JWG.

134. Megan S. Roberts attorney for the City of Alexandria, abusive actions towards JWG are RETRIBUTION
and RETALIATORY ACTIONS for JWG exposing corruption by several taxpayer paid employees of the
Courts of the City of Alexandria. RETALIATORY actions are not legal. Megan S. Roberts in collusion with The
actions of the City of Alexandria, Judges, Commonwealth Attorney, Clerk of Court, VSB, JIRC, Courts of
Justice, the Democratic party, 25 Supreme Court of Virginia has acted intentionally, willfully, wantonly, and
maliciously in their collusion to protect Ilona Ely Freedman Grenadier Heckman founding partner to the law firm
Grenadier, Anderson, Stracae, Duffett & Kiesler, the late wife of Judge Albert Grenadier, from being held
responsible for her and her law firms criminal activity.

135. A few days prior to Thanksgiving 2011 (right after receiving documents in the Mail from Judge Clark) a
Code Inspector showed up at JWG home asking how she was coming with getting the gutter reattached and
the RV moved. JWG explained her financial difficulties and that she would in the next few weeks have the RV
moved and the gutter fixed. He informed her not to worry and call him when it was completed. That with a
moratorium on City workers working on Saturday –
33
 The Saturday after Thanksgiving they come back to the home and add additional fees.

These “fines'' came after JWG contacted the Virginia Supreme Court after being blocked from
exercising her RIGHT to speak to the Regular Grand Jury, blocked by both the Presiding Chief Judge
Donald M. Haddock of the City of Alexandria Circuit Court, and by the City of Alexandria
Commonwealth Attorney Randy Sengel.

136. That the actions of Megan S. Roberts coincide with the actions of other Government employees
(Judges, Commonwealth Attorney Randy Sengel, Clerk of Court Ed Semonian, etc.) to maliciously intimidate
JWG, this is just one of the many scare tactics they are using, to try and scare JWG from following through
with suits against other Government employees and complaints against them with other state agencies.

137. January 7, 2012 Letter Janice to Meghan S.Roberts that Janice has no intention of paying and reason
why

138. January 18, 2012 Motion for sanctions against Randy Sengel commonwealth attorney for letter to Judge
Potter - ignored

139. January 18, 2012 Praecipe to be heard on January 25, 2012

140. January 20, 2012 Letter from Law Clerk Circuit Court of Alexandria that my Motion for Sanctions against
Mr. Sengel would be heard by Judge Potter

141. February 2012 Filed: 26 Motion filed to demand Ed Semonian Clerk of Court answer simple questions
about Grand Jury - Since Alexandria has shown in the past not to follow the rules of the courts It was
reasonable for Janice to ask basic questions which he refused to answer. Most likely he doesn’t know the basic
rule

142. Praecipe filed on Feb 1 for Motion to be heard on February 8, 2012 by the new Judge - Judge Clark who
had not recused himself from hearing this case.

143. February 2, 2012 Letter Circuit Court of Alexandria Motion Sanctions against Ed Semonian to be heard
at 9am February 13, 2012

144. February 13, 2012 The kidnapping of Janice 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
GateKeepers of the Grand Jury – Treason of our Constitution by Judge Richard Potter and Randy Sengel

145. On or around March 9, 2012 Rick @ Neal R. Gross & Co., Inc informs Janice she can’t get access to
transcripts without permission from Clerk of Court Lucy S. Janice then has to Fax Neal R Gross copy of
Appeal.

146. City of Alexandria in collusion to intimidate Janice, files suit against Janice again to take focus off the
issue of the criminal actions of Ilona, an attorney.

34
147. On the morning of May 14, 2012 JWG delivers a letter to Ms. Roberts is on the list to be sued with other
Government employees and lawyers that have prevented JWG from due process her United States
Constitutional Rights, her Virginia State Constitutional and her Civil Rights.

148. May 14, 2012 Ms. Roberts has the Code Enforcement Lawmaster do a statement and in turn files suit
against JWG. Mailing out a letter with the suit documents saying Janice had not responded to the $450. the
City ALLEGES the JWG owed. JWG never received a letter from Ms. Roberts in regard to the $450.00. Ms.
Roberts’ actions in November and May are abusive and RETALIATORY against Janice for her exposing
Alexandria Corruption to Virginia’s Chief Justice. Janice filed a Counterclaim and Cross-Complaint. – Which
was denied by Judge from Arlington who lied in court? Just one more day of “Kangaroo Court” to try and
intimated Janice.

149. On or around September 26, 2012 Ilona and Ilona’s attorneys show Orders by a Judge that did not have
Jurisdiction and this can be proven by attorneys own affidavits that show more 27 phone calls to Judges
chambers than to clients. This is Michael Weiser and John Tran. Lawyer Ilona and Ilona’s attorneys once again
wish to cover up the truth and mislead the courts.

150. October 2012 – Janice’s documents submitted into the record are mailed back to her by Judge’s Kemler,
Dawkins and Clark. The box about 4” thick has been x-rayed and shows the documents but, never opened

151. In the 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 JWG and
get sexual inappropriate pictures of JWG or to rape one of JWGs daughters or to plant drugs on JWGs
daughter or in home to give Circuit Court Judges information to make Janice incompetent to file any
other documents. Mr. Stuart said the Lawyer Ilona will go to any length to harm JWG or JWGs daughters. That
Lawyer Ilona will continue to do what she can to distract Janice from becoming successful and moving on with
Janice's life. That Lawyer Ilona is greedy. That all Lawyer Ilona’s actions are deliberate to cause harm to JWG.
When the Alexandria Police were called they informed JWG they were instructed by Commonwealth
Attorney Randy Sengel to not take any reports of the issue.

152. On or around May 16, 2013 Janice requested a car that she had purchased and was in the name of
Janice's daughter returned or the right to pick it up. Lawyer Ilona in collusion with David Grenadier tried to
intimidate and dare Janice to report them to the police for by all appearance forging documents with the
DMV to get a title and sell the car.

153. On or around July 16, 2013 Lawyer Ilona in collusion with Andrea and Robin/Racheal Grenadier the day
after Defendants father dies – again attacks Defendant in emails which re-enforces the hate of Catholics
that Ilona her and family have. Lawyer Ilona again trying to distract from Lawyer Ilona’s criminal actions. This
is most likely in regard to the fact that the law by an attorney was pointed out to Janice that she owns 24.5% of
all properties GIC has as funds were co-mingled and Lawyer Ilona used an attorney not licensed in Virginia for
the Liquidation Agreement and JWG never signed off.

154. On or around July 12, 2013 after learning of the conflicts and disingenuous behavior of Lawyer Ilona in
Janice’s Forced Bankruptcy. Defendant revisited all the evidence and filed to re-open her Divorce as no
property settlement had been done. That Ilona an attorney had 28 written one that was not signed that was
only a benefit to Lawyer Ilona. As an attorney Ilona acted again willfully to protect herself and for personal
financial gain.

35
155. The law leaves little question that Fraud in procuring a settlement agreement can justify setting aside the
agreement and judgment. Which there was none. E.g., In re Marriage of Modnick, 33 Cal. 3d 897, 191 Cal.
Rptr. 629 (1983); Compton v. Compton, 101 Idaho 328, 612 P.2d 1175 (1980); Anderson v. Anderson, 399
N.E.2d 391 (Ind. Ct. App. 1979); Daffin v. Daffin, 567 S.W.2d 672 (Mo. 1978).

Fraud in procuring a settlement can also be the basis for an independent tort action.
Hall v. Hall, 455 So. 2d 813 (Ala. 1984); In re Benge, 151 Ariz. 219, 726 P.2d 1088 (Ct. App. 1986);
Dale v. Dale, 66 Cal. App. 4th 1172, 78 Cal. Rptr. 2d 513 (1998); Den v. Den, 222 A.2d 647 (D.C.
1966); Oehme v. Oehme, 10 Kan. App. 2d 73, 691 P.2d 1325 (1984); Burris v. Burris, 904 S.W.2d 564
(Mo. 1995); Carney v. Wohl, 785 S.W.2d 630 (Mo. Ct. App. 1990); Hess v. Hess, 397 Pa. Super. 395,
580 A.2d 357 (1990). See also Vickery v. Vickery, 1996 WL 255755 (Tex. Ct. App., December 5, 1996)
(wife awarded $9 million against husband for fraudulently procuring divorce and marital settlement
agreement, and $450,000 against husband’s attorney), affirmed over dissent in light of Schleuter v.
Schleuter, 975 S.W.2d 584 (Tex. 1998), Vickery v. Vickery, 999 S.W.2d 342 (Tex. 1999). See generally,
Robert G. Spector, Marital Torts: The Current Legal Landscape, 33 Fam. L. Q. 745, 757 (1999); Cary L.
Cheifetz, The Future of Matrimonial Torts: The Unmapped Landscape, 15 Fair$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).

156. Lawyer Ilona 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 husband’s attorney),
affirmed over dissent, Vickery v. Vickery, 999 S.W.2d 342 (Tex. 1999).

157. 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
36
 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).

158. On or around September 4, 2013 Lawyer Ilona filed a Motion to Intervene into Janice’s divorce again
for willful acts that were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless for personal
protection from the illegal actions to date of Lawyer Ilona.

159. On or around September 11, 2013 Janice responded to Lawyer Ilona’s Motion to Intervene.

160. The Divorce is never given an open hearing in the open court – instead Judge Clark rules from
Chambers as all Federal Judges have. That the appeal was denied and the Supreme Court denied extra
time for a response as I was jailed and unable to respond.

161. That Lis Pendens were filed on the Real Estate still owned to protect Janice’s interest as Ilona had sold off
many parcels illegally.

162. On or around December 24, 2013 Lawyer Ilona and Loretta Miller aka (Leah Lax Miller, Muggy Cat and
Billy Sullivan) in collusion attacked Janice for being Catholic. The following is just one of many emails and a
blog jwgrenadierisalair.blogspot.com (by all appearance taken down while JWG was illegally jailed) which is
riddled with lies – again to harm Janice and Janice’s children and distract Janice and all from the
TRUTH. – Again when Police are called they are not to take any reports – I should just ignore the threats on
me and my children.

37
A page out of Divorce Lawyers Ilona’s gang BLOG has done:

Now here is something really funny and intersting about Janice Wolk Grenadier. Well actually a few funny
things. Today she was seen naked in her back yard building an ice alter to her Dark Lord Satan. She was doing
this in the freezing rain. The scary part was she had icicles hanging from her oversized nipples and from her
pubic hair. She then took a large icicle and began to masterbate with it until it melted.

A neighbor had seen Janice Wolk Grenadier walking out of a sex shop Friday night with a large bag filled with
sex toys and two very large women who looked like Amazons. They were seen driving to a gay bar in which
Janice and the two women frequent and have pajama parties afterwards. She left Saturday morning with her
hair disarray and a smile on her face. A dog collar could be seen around her neck and welts on her arms and
legs. We don't think she is the dominant one in this relationship. Family services should have taken her kids
away from her years ago. She neglected them for her sexual pleasures and alcohol addiction.

Janice Wolk Grenadier adores her Fuher Adolf Hitler who was also bi-sexual. Janice Wolk Grenadier has been
seen wearing a painted on mustache just like her idol and walking around wearing a Swasticka on

her rare selfie of Janice Wolk Grenadier This classless woman should be put away in a padded
cell so she can't hurt anyone else. Someone please call the authorities to have her institutionalized for her
safety and for the safety of others. Remember she carries a gun!

Sunday, January 5, 2014

Janice Wolk Grenadier supports the Anti Christs Obama and Hillary Clinton

38
Not only is Janice Wolk Grenadier a traitor to the American people by being a card carrying Commie
Pinko but she is also supporting the Anti Christs Obama and Hillary Clinton. Yes we said it here, Anti
Christs meaning plural. Why is Janice doing this? Because they are not only going to let her keep her
hairy vag but they are going to give her the chance to grow a penis as well. Well penises. Yes, Janice
Wolk Grenadier will have 6 penises all over her body including one over her vagina. The other 5 will be
as so: one in the palm of each hand, one on the bootom of each foot and one right where a tramp
stamp would be on her back. That way when Janice Wolk Grenadier dies, she can go to Allah's heaven
and have her 72 virgins. These 72 virgins will be a mix of males and females that she can rape with all
of her penises and then the next morning at sun up they become virgins again. We have figured it out
that the fetal body of little Joshua that Janice keeps in the basement of her home is going to be the
vessel for the Dark Lord Satan himself to resurrect in a human body to carry out the apocolypse. That
way, Janie Wolk Grenadier is guaranteed her 6 penises.

Proof she supports the Anti Christ is in her letters she has posted and her other posts of Hillary's and
Obama's support defending both on everything Loretta Lax Miller fought against including the
ObamaCare and Islamic Terrorism which Obama and Hillary support. Janice is for the destruction of
the Catholic Church's values of having Nuns despense birthcontroll pills. Janice supports this by
supporting Hillary Rodham Clinton and Barack Husein Obama. Everything Obama stands for is to
destroy American Family Values and Janice has no values and worships Satan

We at Muggy Cat take the religious stand that Janice is the Anti Christ and does not beleive in God and
the wonders God has done on this Earth. Maybe Janice should move to sin city Las Vegas and sell her
soul as well as her fugly body on the strip since she is whoring for Satan.

-----Original Message----- From: JWG To: muggycatscreams ; leahlax1234

Sent: Wed , Jan 1, 2014 10:45 am
Subject: Re: i agree with you

You FUCKEN JEWS!!!!!! ALL OF YOU . DICK FARREL JOSH COHEN, LEAH LAX AKA LORETTA LAX
MILLER AND THE REST OF YOU FUCKEN 30 JEWS. Hitler was right! Ya'll deserve to die! YOU SHOULD BE
PLACED IN A BIG OVEN.

Warmly,

JW Grenadier

We hope that you join us on Friday, January 10th, 2014 outside of Janice Wolk Grenadier's house to
protest her anti-American pro-Satan values. Email us at muggycatscreams@aol.com for Janice Wolk
Grenadier's address. We are expecting at least 200 people so don't forget to bring Holy Water from
your church to purify and sactify the land of the supporter of the Anti Christ and the mother of the
vessel of Satan. We will have a prayer session to pray for her lack of soul but do not look her straight
in the eyes or you will be turned to stone.

Posted by muggy cat at 8:48 AM

39
Email ThisBlogThis!Share to TwitterShare to Facebook Labels: CIA, FBI, Hillary Rodman Clinton,
Janice Wolk Grenadier, KGB, leah lax, MI5, MI6, My Pillow Pack, Obama, virginia law 2010
That the above is just 1 pages out of almost 200 printed out pages of slander and Libel of Janice by
Plaintiffs. Janice felt the e-mails that bear her name THAT JANICE DID NOT WRITE should hold a lot of
wait in what Janice will be able to prove.

THIS BLOG RUINED JWG CHANCE OF FINANCING FOR HER COMPANY MY

PILLOW PACK - and then BWW Law Group came along to hammer the nail in the
Coffin.

165 A. That Janice requested an injunction would not substantially injure other interested parties and This blog
has hurt no one but Janice and her ability to market and advertise a Child Friendly product. This blog and other
actions were deliberate willful acts that are and were malicious, violent, oppressive, fraudulent, wanton, or
grossly reckless. That the hacking and killing of Janice’s computers was malicious and has also prevented
Janice the right to market her product.

165B. That the public interest would be furthered by the injunction – the HATE CRIME OF THIS is sinful and
that this court cannot see that becomes questionable to the rational of fairness. That the sexual and in
appropriate photos of Hillary Clinton and Michele Obama in there blogs – The racist and religious overtures of
HATE BY DEFENDANTS is so obvious that to have to go any further would show Bias by this court and any
one of normal moral value. . “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)” Loving v. Virginia, 388 U.S. 1 (1967) was a landmark civil rights decision of the
United States Supreme Court against discrimination. Which includes being discriminated because the Judge’s,
lawyers, elected officials and government employees have decided you are not a part of or one of them

163. That in December of 2015 a new blog which is still on the web along with continuing e-mails making the
harassment the slander and libel a continuing occurrence by Ilona Grenadier Heckman and her gang the blog
is janicewolkgrenadierinjail.blogspot.com That Janice viewed it as recently as November 11, 2015 – where
Ilona and her gang is calling Janice a Terrorist.

164. The false and illegal legal fees fined against me so Ilona and the Old Boys Network could further
harm me, by attorneys who have lied in court, lied in court documents, lied to the Supreme Court of
Virginia, ex-parte communications, City of Alexandria Police Report: ignoring the law - with the help of the
Commonwealth's attorney's office took the report

165. That Lawyer Ilona filed Cases in The City of Alexandria and Prince William County to have the Lis
Pendens removed using Ben DiMuro and Andrea Mosley both that would continue to lie in court and in
court documents to mislead the courts from the “TRUTH” using their influence on the Judge’s to
illegally threaten jail as shown in the Orders from both Judges and to illegally jail me for legal fees by
Judge Clark.

166. Divorce Lis Pendens Case # 1400 2193 – Just a miscarriage of further Justice where the Affidavit of
Legal fees has more calls to Judge’s chambers than to their own client. Illegal ex-parte communications.

167. Prince William County - Divorce Lis Pendens Case # 14-2185 and 14-2185 1 – I was allowed by the
Judge to record the court hearing. The sheriffs on the end of the tape can be heard saying to erase it.
40
None of the Judges who heard this case allowed witness’s to speak – nor did they have Jurisdiction due to
Bias all Orders were and are “VOID” – even with the Judgments the lawyers were given – Legal Collection
agencies have refused to enforce when they have seen the evidence of corruption.

168. A police report with the help of the Commonwealth's attorney was done: and tampered with to
prevent “DUE PROCESS” Police Report in the City of Alexandria by JW Grenadier October 10, 2014
Notes - Case No. 14 - 142420

169. On Friday October 10, 2014 Janice Wolk Grenadier went to the courthouse to file a motion to have a court
appointed attorney. 34

170. Janice went to the courthouse to file my Motion for an emergency hearing - The Clerk politely explained I
needed to call the Judge's chambers to set it up. I am actually by their Order of October 12, 2014 forbidden to
call Judges Chambers, write to Judges Chambers etc. This is just one case where they are allowing outrages
legal fees and trying to put me in jail no on October 22, 2014.

171. I went to the Commonwealth's attorney’s office where even though they are attorneys they don't look into
anything that does not come to them through the police. I have called the police several times to report the
corruption and the man they had hired to harm me, along with the Leah Lax bullying. The police would come to
my house and say well we aren't allowed to write a report. That Randy Sengel Commonwealth Attorney had
ordered no one was to write a report on my complaints. So I called the police right there at the CourtHouse and
had them come there and take the report.

172. Officer M, Vaccaro #2371 and P. Taylor #1979 his supervisor / training officer was with him. The crime was
headlined as "Criminal Corruption in the Courthouse is what you are claiming" me "YES" this report was
taken in the Clerk’s office. I gave them the pictures of my evidence that was stolen out of my file and the Order
that came with it, The attached documents and since my files were in the court house right there I asked if they
would like to go through them. They were not interested in doing that. Replied "This will be turned over to the
White Collar Crime division, that this was above their job" the Case No is 14 - 142420

173. After the report they wanted me out of the Court House, They said that I did not have to leave but, it was
best for me. They insisted I had done something to be removed that the Commonwealth Attorney's office did
not want me in the building. When I asked why and what was said they refused real comment and admitted I
had done nothing wrong.

174. The Commonwealth attorney’s office has said several times they would not put me in front of the Grand
Jury to ask for a Special Grand Jury that I had to go through the Police as is in my attached documents about
the Corruption in Northern Virginia- yet it has always been the Commonwealth Attorney who blocked me from a
police report in regard to the corruption.

175. I gave them copies of documents showing criminal intent for the officers to open the case. The document
with the Box of Evidence and the Order from Judge Clark, Kemler & Dawkins is modified by the Notes that
were filed in my Statement of Facts in November of 2012

41
 VIRGINIA IS BEING WATCHED BY THE FBI OR THAT IS THE APPEARANCE

Other Links: Virginia Rated 47th and 49th in

Corruption - Daily Beast rated Virginia second most
Corrupt State -

http://www.loudountimes.com/index.php/news/article/region_survey_finds_virginia_second_most_corrupt_s
tate987/ - State Integrity Gave them an F - 47th most corrupt States - http://www.stateintegrity.org/virginia

176. The FOIA request was completely redacted by the City Attorneys - This was in collusion with the
Commonwealth's Attorney whose suggestion it was to call the police.

177. That a Judge with Jurisdiction has never been had in this case. All Judge’s were improperly chosen
with or by Judge Haddock

178. Jailing JWG on the pretense of legal fees that Alps Insurance said they were paying, for lawyers who had
lied in almost if not all documents submitted to the court, the affidavit of legal fees showing more calls to
Judge’s chambers than to their own clients. Most importantly we do not have debtors prisons in the
United States of America – Janice was jailed illegally on October 22, 2014 – After sneaking out documents
was released early on November 14, 2015 Janice stated the Following:

That your actions have 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 I 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.

179. JAILING AND USING WARFARE TYPE TOUTURE October 22 – Nov 12, 2015 14 days Solitaire
Confinement – till around 5pm on election day which is Torture

42
What is Solitary Confinement? In the early nineteenth century, the U.S. led the world in a new practice of
imprisoning people in solitary cells, without access to any human contact or stimulation, as a method of
rehabilitation. The results were disastrous, as prisoners suffered severe psychological harm. The practice was
all but abandoned. Over a century later, it has made an unfortunate comeback. Instead of torturing prisoners
with solitary confinement in dark and dirty underground holes, prisoners are now subjected to solitary
confinement in well-lit, sterile boxes. The psychological repercussions are similar to

CCR's Challenges to Solitary Confinement In May 2012, the Center for Constitutional Rights (CCR) filed a
lawsuit against the state of California for its use of prolonged solitary confinement in the infamous Pelican Bay
prison. Ashker, et al. v. Governor, et al., is a federal class action challenging prolonged solitary confinement
and deprivation of due process, based on the rights guaranteed under the Eighth and Fourteenth
Amendments, at Pelican Bay In Wilkinson v. Austin, the U.S. Supreme Court unanimously ruled in
support of CCR’s claims that prison officials cannot confine prisoners in long-term solitary
confinement in a super maximum prison without first giving them the opportunity to challenge their placement.

Solitary Confinement is Torture The devastating psychological and physical effects of prolonged solitary
confinement are well documented by social scientists: prolonged solitary confinement causes prisoners
significant mental harm and places them at grave risk of even more devastating future psychological harm and
at times, these harms were found to be permanent or persist even after one was released from solitary.
Researchers have demonstrated that prolonged solitary confinement causes a persistent and heightened state
of anxiety and nervousness, headaches, insomnia, lethargy or chronic tiredness, nightmares, heart
palpitations, fear of impending nervous breakdowns and higher rates of hypertension and early morbidity.
Other documented effects include obsessive ruminations, confused thought processes, an oversensitivity to
stimuli, irrational anger, social withdrawal, hallucinations, violent fantasies, emotional flatness, mood swings,
chronic depression, feelings of overall deterioration, as well as suicidal ideation.

Exposure to such life-shattering conditions clearly constitutes cruel and unusual punishment – in
violation of the Eighth Amendment to the U.S. Constitution. Further, the brutal use of solitary has been
condemned as torture by the international community. Juan Mendez, the United Nations Special Rapporteur on
torture and other cruel, inhuman or degrading treatment or punishment, concluded that even 15 days in solitary
confinement constitutes torture or cruel, inhuman or degrading treatment or punishment, and 15 days is the
limit after which irreversible harmful psychological effects can occur. Other independent human rights bodies at
the UN have also expressed concern about Pelican Bay prison and the overall use of solitary in U.S. prisons.
However, many prisoners in the United States have been isolated for far longer than just 15 days – JWG
was only a few hours short of 15 days in Solitary Confinement

1. Denied phone calls till 10 pm on 1st day

2. Woken up every 2 hours at night

3. Not allowed out of cell till 2 or 3 am for one hour, left in cell for over 24 hours limit.

4. When tried to make phone calls the calls through system did not work and could not get help

5. Sat down and was told I had less rights than someone who murdered someone by City
employee Jonathan Teumer and Lt Rea – for sneaking out the documents that got me out of jail
early. The actions were deliberate and evil to intimidate me further. That Mayor Euille was given
such documents as well as all other State officials

43
 6. Denied access to Priest and when I did see him and asked for my cross or rosary – He
explained he had been told by Lt. Rea it would have to be if she deemed it appropriate for me to
have. He did not understand or had never seen such a situation where it went through a Sheriff
like Lt. Rea. This action was pure evil. No Advocate

7. Denied mail returned to sender – saying I was not there – my mail I did received had been
opened – I requested a copy of the court order and was denied

8. Denied phone calls to lawyers

9. Stripped searched – patted down – men watching me shower

10. JWG was lied to consistently by the Sheriffs – especially Lt Rea and Capt. Williams

11. Moved around to try and disorient me and show control. They had

12. The Magistrate when finally I was allowed in front of him and warned me “If I did not stop this it
would only get worse for me? Which I took as a personal threat on my life and on my children’s
lives – Which I took as a personal threat on my life and on my children’s lives –Especially with
the knowledge of at least 5 known hits in the City of Alexandria – and the Supreme Court
Justice Cynthia Kinser being forced to retire early – Gift to the Democrats letting Fundraiser
Michael Gardner out of jail – who had by DNA results found guilty of molesting young girls in
McLean – only to turn around and try to hire one of those hit men to kill the girls – Do it the
Virginia Way as Senator Mark Warner would say in his Campaign

13. Denied appropriate forms for filing of complaints and requests

14. All Avery v. Johnson rights denied

15. Denied my documents on my day of court, prior to going to court.

16. Judge Clark in Court stated “Ms. Grenadier I have no choice but to release you “ and then
turned to Lawyer Michael Weiser and stated “I am sooooo very sorry I can not collect your
legal fees for you – you will need to do a judgment against her for collection” As Lawyer
Ben DiMuro et al were no shows after lying in court, lying in court documents et al.

17. The head Sheriff assured me I would be released within 2 hours of getting back to the jail – I
was not released till after 8 pm over 8 hours from getting back from the Court. The apparent
reason was to further try to intimidate me and further the mental anguish of false imprisonment
and to try and enforce the EVIL POWER they believe they have in controlling a single mom who
told the “TRUTH”, and did not spinelessly walk away from the Old Boys Network.

180. That the defendants Orders they claim to be judgments are “VOID” that not one Judge from
September of 2007 or before have had Jurisdiction and ruled by the law. That Janice a poor person has
been denied even her basic rights to Due Process. That the collusion and the harm that the Plaintiffs have
caused was done willfully with knowledgeable intent to harm Janice and her girls for being Catholic and no
longer party to the Old Boys Network as she was told many occasions and listed here in this Counter
Complaint Cross Complaint. That the State and Federal law , the Professional Code of Ethics is very clear on
Judicial Misconduct and when a Judge Does Not have Jurisdiction, that is Treason on the Courts, Fraud on the
Courts what the Judges have done since on or around September of 2007.

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 GENERAL ALLEGATIONS

181. 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.2d672 (Mo. 1978).

182. 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.

183. 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
JWG. 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.

184. 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 intent to defraud JWG 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 an agreement.

185. 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

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186. As acceptance of economic torts becomes more prevalent, plaintiffs have been casting the net wider to
sue not only offending spouses 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 defendant’s 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.

187. 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 husband’s 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:

188. 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.”).

189. The court then concluded that the divorced mother stated a cause of action: 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. Barenkamp’s 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
Barenkamp’s 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.

190. 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)
46
(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 husband’s attorney),
affirmed over dissent, Vickery v. Vickery, 999 S.W.2d 342 (Tex. 1999).

191. 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.

192. 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.

193. 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:

194. 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.

195. 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.

196. 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).

197. 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 Divorce Lawyer Ilona Grenadier Heckman. That
the claim in Bankruptcy court was that with no Property Settlement all Real Estate unless otherwise stated was
47
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. The collusion of Mother & Son who also created a
Fraud through the Mother’s 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.

198. 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 Plaintiff’s signature and that the
Properties were held in Trust by Divorce lawyer Ilona Grenadier Heckman who with knowledgeable
intent to cover up who had an interest in the properties signed most documents as Trustee. The
collusion / enterprise was with the intent to defraud and manipulate Plaintiff as she had done with Sonia
Grenadier.

199. 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 Ilona’s actions
were with the knowledgeable intend inclusion of David to defraud Plaintiff.

200. That Rule 1:1 is not enforceable under the Due Process when the appearance of an “inequitable
Judgment” But, here we don’t have an inequitable judgment we have no Property Settlement along with
statements of the Defendant's attorney 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 (today’s 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
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 Hammond 16 West Bellefonte Ave 44 East Taylor Run Pkwy 1813 Leslie Ave 54 East Taylor Run Pkwy
61 East Taylor Run Pkwy 33 South Gordon 2943 Sycamore Ave 2945 Sycamore Ave 415 East Delray
Ave 224 Guthrie Ave 322 E. Hume Ave 710 Four Mile Rd 707 Four Mile Rd 713 Four Mile Rd 715 Four
Mile Rd 628 Notabene Dr 636 Notabene Dr 638 Notabene Dr

3. Southway / Southampton Terrace at least 24.5 % $3,100,000.00 ( 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 least24.5% $ 500,000.00 (an accounting for rents income, etc) TBD 2014
Market Value $2,4 million Rental Inc. mthly $ 16,000 PP 400.000. ILONA HAS SOLD THIS
PROPERTY with out my signature

5. Real Estate 2nd 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 done in 2017 – and some funds represent the equity in the other
properties – so the real numbers cannot be established till after the information from the Subpoenas.
ALL Subpoenas have been DENIED

201. 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.

202. The memorandum Further goes on to say “When reviewing a trial court’s 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.

203. 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,

49
204. 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 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.

205. 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 Severance 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.

206. That the letter written with an apology by Judge Kloch states “The appearance of Justice is just as
important as Justice itself.”

207. In October of 2012 Judge Clark refused to recuse himself and awarded legal fees riddled with ex parte
communications in a 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 had said were held in Judge’s 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
the Judge's chambers came down and said take them or we will throw them out. On October 13, 2012
Defendant 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.

208. The City of Alexandria then to intimidate JWG further filed charges against Janice for a gutter
hanging from the earthquake and for allowing a friend to park an RV in her driveway which was totally legal.
That Ben DiMuro in collusion with Commonwealth Attorney Randy Sengel 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.

209. 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 didn’t work to intimidate and scare JWG off, December of 2012
Mark/Michael Stuart as a friend of Ilona’s 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.

50
210. When that didn’t work December of 2013 Ilona’s 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 Ilona’s 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.

211. 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 Grenadier’s
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 knowledgeable intent to harm by David and Ilona.

212. 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.

213. That a Divorce Attorney with Knowledgeable intend to defraud and at her finger tips Judge’s with Chief
Judge Haddock’s declaration “You cannot get a fair trial, we LOVE Ilona” in 2008 after he had chosen Judge’s
that were his and Ilona’s close friends. That Judge Clark’s 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
51
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)”

214. 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.”

215. “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.” Kenner v. C.I.R., 387 F.3d 689 (1968); 7 Moore’s 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.”

216. 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.

217. 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.

218. 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
Defendant’s lawyer and was ignored that Plaintiff was reopening divorce for Fraud.

2. On or around July 12, 2013 Subpoena was filed in the COA Clerk's 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
52
 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 Defendant’s mother ( Ilona Ely Freedman Grenadier Heckman
widow of the late Judge Albert Grenadier and a lawyer/Founding Partner of Grenadier,
Anderson, Starace, 49 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 Judge’s to protect the “LOVE” that Judge Haddock (whom Judge Clark took his place) the
slippery slope restarted.

219. 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 Alexandria’s clerk’s 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 Clerk’s office after what was around ½ hour of waiting prior to being able to file, believes the
Clerk’s office conferred with the Judge’s chambers..

220. The dockets for the Divorce case have been altered and doctored.

221. 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 the court recognizes the discrepancies in the Circuit Court of
Alexandria in Fairness to the Plaintiff.

53
 FIRST CLAIM FOR RELIEF INTENTIONAL FRAUDULENT TRANSFER AND RECOVERY OF
MONEY AND REAL ESTATE

222. That Lawyer Ilona has manipulated and profited while harming JWG

223. 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]

1. Becoming insolvent because of the transfer;

2. Lack or inadequacy of consideration;

3. Family, or insider relationship among parties;

4. The retention of possession, benefits or use of property in question;

5. The existence of the threat of litigation;

6. The financial situation of the debtor at the time of transfer or after transfer;

7. The existence or a cumulative effect of a series of transactions after the onset of debtor’s financial
difficulties;

8. The general chronology of events;

9. The secrecy of the transaction in question; and

10. Deviation from the usual method or course of business.

11. The money traveled over State lines my all appearance

12. That Ilona changed her name or used a fraudulent name in California to confuse – that is appears to be
with knowledgeable intend

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

224. Incorporated into this is all of the above.

225. 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.

54
226. That inefficient council / overpaid council can be proven that each and every lawyer knows or should have
known I had to have a Property Settlement with my divorce.

227. 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.

228. 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 Janice’s 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 didn’t work.

229. 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

230. Incorporated into this is all of the above.

231. 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 Janice’s back.

232. 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.

233. 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.

234. That Divorce Lawyer did not have to act criminally; she did so voluntarily and with knowledgeable intent.

FOURTH CLAIM FOR RELIEF COLLUSION

235. Incorporated into this is all of the above.

236. 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.

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

238. 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.

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 FIFTH CLAIM
FOR RELIEF MALICIOUS PROSECUTION, OBSTRUCTION OF JUSTICE

239. Incorporated into this is all of the above. 240. 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.

241. That the Judge’s to date have 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”/

242. 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.

243. 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.

244. October 2012 – Janice’s 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 Judge’s Kemler, Dawkins and Clark. The box about 4” thick has been x-rayed and
shows the documents but, never opened still In the box

245. 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 Judge’s went to jail. “CASH for LAWYERS” is just as illegal

SIXTH CLAIM FOR RELIEF ALTER EGO

246. Incorporated into this is all of the above.

247. 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 Trust’s 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

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 SEVENTH CLAIM FOR RELIEF VIOLATIONS OF THE
CIVIL RIGHTS ACT OF 1871 (42 USC § 1983. 1985, 1986)

248. Incorporated into this is all of the above.

249. That Ilona’s 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.

250. That the rights of Janice in the courts were denied to her for being “Blacked Balled” by the Old Boys
Network order by all appearances by Judge Donald Kent and Judge Donald Haddock.

EIGHTH CLAIM FOR RELIEF RACKETEERING

AND CORRUPT ORGANIZATIONS ACT OF 1970 ( 18 USC § 1962)

251. Incorporated into this is all of the above.

252. 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 Judge’s is sick. That the facts, the documents show

253. 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 – Judge’s 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.

254. 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 Janice’s daughters, or to plant drugs
on Janice’s daughter or in the home to give Circuit Court Judge’s 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 Janice’s daughters. That Lawyer Ilona will continue to do what she can to
distract Janice from becoming successful and moving on with Janice’s life. That Lawyer Ilona is a “Greedy
Jew” that all Lawyer Ilona’s actions are deliberate to cause harm to Janice. When the Alexandria Police were
called they informed Janice they were instructed by Commonwealth Attorney Randy Sengel to not take
any reports of the issue.

255. That on June 14, 2017 Mark / Michael Stuart would reserve at the shooting of Republican Senators and
Congressman to be further ignored by the Judiciary when Janice would ask for a restraining ”Order” as he was
hired to harm Janice or her girls at the request or DEMAND of Judge James Clark

NINTH CLAIM FOR RELIEF LIBEL AND SLANDER

256. Incorporated into this is all of the above.

57
257. That when Ilona acting in collusion on her and her friends blog lied stating I was the “antiChrist” a
“homosexual” while trying to sell a family friendly product “My Pillow Pack” further harmed me with their lies.
258. That the Blog still on the internet from IEG et al’s GANG still today has a Blog on the internet as well as
Radio Shows

259. That Ilona and her lawyers lied in court, in court documents slandering the truth and defaming Janice.

260. That all claims and times are toling.

TENTH CLAIM FOR RELIEF FALSE IMPRISONMENT

261. Incorporated into this is all of the above.

262. Judge James Clark illegally Jails Plaintiff: That Judge Clarks actions turned back time. Giving me
less rights than 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.

263. 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 55 filed for by the lawyers, but was filed by Divorce
Lawyer Ilona Grenadier Heckman with no discovery or fairness in the courtroom allowed by her
“FRIEND” Judge James Clark.

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

265. That in CASE NO. 1500-3661 filed by Divorce Lawyer Ilona Grenadier Heckman for legal fees that
are not Judgements – Judge James Clark has personally in Judge’s Chambers chosen a Trustee, not
giving Plaintiff any Discovery to show the “TRUTH”

ELEVENTH CLAIM FOR RELIEF TURNOVER OF PROPERTY

SOLD / AND OR STILL COLLECTING RENTS AS TRUSTEE

266. Incorporated into this is all of the above

267. 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.
58
TWELFTH CLAIM FOR RELIEF FRAUD ON THE COURT BY LAWYERS AND JUDGES

268. Incorporated into this is all of the above

269. That the evidence and the orders themselves by the Judge clearly show FRAUD ON THE COURT. That
the willingness of Judges to protect their 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.

270. 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."

271. Further U.S. constitution Article II Section 4: the President, Vice President and ALL CIVIL officers of the
United States, shall be removed from office on impeachment for, and of, treason, bribery, and or other high
crimes and misdemeanors.

THIRTEENTH CLAIM FOR RELIEF Honest Services Fraud 18 USC § 1961

271. Incorporated into this is all of the above

272 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

ILONAS “GANG” Run by

Judges, Lawyers, Lorretta Lax Miller and Muggy Cats

ILONAS “GANG” Run by

Judges, Lawyers, Lorretta Lax Miller and Muggy Cats

That the intent was to harm me physically, mentally and ruin my child Friendly business “My Pillow Pack”.
They succeeded with the help of Judge Lawyer Howard Bierman of BWW Law Group.

That a blogs, radio shows and harassing emails, with a new blog done after I was released from Jail.

That the Civil Rights “HATE CRIME” came under DC Jurisdiction and JUDGE BERYL
HOWELL protected her fellow JEWISH FRIEND Ilona Grenadier Heckman and Jerome
Heckman, Ilona’s husband by allowing these crimes as she is allowing the SPRING

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STREET Crimes for more JEWISH FRIENDS and to ensure her good Friend Ilona WINS
by RUINING Janice Wolk Grenadier

28 U.S.C. § 1343(a)(3) (1993) provides as follows:

(a) The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any
person: . . . (3) To redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of
any right, privilege or immunity secured by the Constitution of the United States or by any Act of Congress providing for
equal rights of citizens or of all persons within the jurisdiction of the United States.
28 U.S.C. § 1331 (1993) provides that “district courts shall have original jurisdiction of all civil actions arising under the
Constitution, laws or treaties of the United States”

a) The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any
person: (1) To recover damages for injury to his person or property, or because of the deprivation of any right or privilege
of a citizen of the United States, by any act done in furtherance of any conspiracy mentioned in section 1985 of Title 42;
(2) To recover damages from any person who fails to prevent or to aid in preventing any wrongs mentioned in section
1985 of Title 42 which he had knowledge were about to occur and power to prevent;
(3) To redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of any right,
privilege or immunity secured by the Constitution of the United States or by any Act of Congress providing for equal
rights of citizens or of all persons within the jurisdiction of the United States; (4) To recover damages or to secure
equitable or other relief under any Act of Congress providing for the protection of civil rights, including the right to vote.
Any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of
Columbia.

Plaintiff Janice Wolk Grenadier complains against the captioned Defendants ( ILIONA GRENADIER
HECKMAN, GRENADIER ANDERSON STRARACE DUFFETT & KEISLER, PC, COMMONWEALTH OF
VIRGINIA Mark Herring, LAX MILLER –aka- LEAH LAX –aka- MUGGY CAT –aka- BILLY SULLIVAN
Presidential Candidate for 2016 CAMPAIGN FOR LORETTA LAX MILLER And all employees/volunteers
) to seek relief for the violation of Federal and Constitutional rights under Title 42 § 1983, and under the Bill of
Rights the Four Basic Freedoms are being Violated

1. Freedom of speech 2. Freedom of worship 3. Freedom from want 4. Freedom from fear

INTRODUCTION

This is an action for appropriate relief pursuant to the common law, statute and/or Constitution of the United
States of America, for impermissible restraints upon the Plaintiff’s constitutionally protected property,
entitlements and other Constitutional rights, in Violation of a person’s Civil Rights under 18 USC Sec 249 and
the Civil Rights Act of 1964. Plaintiff will show statements made by Defendants are Slanderous, Libel and
Defamation of Character of Plaintiff. The False statements that have been published as Fact and
communicated through several emails will show defamation. That the statements have forever ruined the
reputation of Plaintiff and her ability to promote a family friendly child product. The retaliation of Defendants to
prevent the “TRUTH” coming out of IGH. That the Treason on the Courts by the Judge’s and the Judge’s they
supervise were willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly
reckless because the Plaintiff was Catholic.

60
That JWG was denied her constitutional right of Due Process in the courts of Virginia for being Catholic. That
under Title 42 § 1983 will show violation of rights protected by the Constitution and created by Federal Statute
that persons employed by the State of Virginia acting under color of state law violated
Plaintiffs Constitutional rights. That two Chief Judges (Chief Justice The Honorable Cynthia D. Kinser and
Hon. Lisa Bondareff Kemler, Presiding Judge, Chief Judge) who are or should be held responsible for the
actions of the Judges beneath them in there subversion. That they are ultimately responsible for the actions in
their courts and both are Jewish and have allowed Judges under their supervision to rule in Favoritism and
Cronyism and for attorneys to be disingenuous in the documents that they filed in court, and under Judge’s
order did not file documents entered into the record in the Plaintiff’s file in the Circuit Court of Alexandria. The
new evidence under the Blog, jwgrenadierisalair.blogspot.com and the actual actions of the Judges shows the
collusion and the discrimination against Plaintiff for being Catholic.

JWG through Orders and documents filed in the clerk’s office the City of Alexandria and the Supreme Court of
Virginia will show the pattern of this Hate and illegal Treason on the Courts and to Plaintiff. The documentation
will show the shoddy unlawful and unethical behavior of the above Judges. “That the appearance of Justice is
as important as Justice itself” the appearance and actions of the above Judges will show to be willful acts that
were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless because the Plaintiff was
Catholic.
PARTIES
Plaintiff – Janice Wolk Grenadier (JWG) is the Victim of the above Defendants since October of 1985, and LLM
since May of 2013 when she began stalking Janice Wolk Grenadier . The Circuit Court Judges and the
Supreme Court of Virginia since prior to but took notice of such discrimination in September of 2007.

Defendant Ilona Ely Freedman Grenadier Heckman (IGH) a lawyer is guilty of the following and this can be
proven with documents and witness’s 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
Defendant Ilona.

THE ABOVE IS THE MOTIVATION OF ILONA GRENADIER HECKMANS going to the extremes that she is
to stop the Truth from coming in front of a Judge. All actions from the IGH and her firm have been willful
acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless. That if tried as
Jim Arthur did 5 years in jail, could go to jail and loose her license to practice law. The VSB is ignoring her
actions as she with the interest off her Trust account, dues and other donations pays the salaries of the
employees of the Virginia State Bar. Ben DiMuro her lawyer is a past President of the VSB and has donated
10% of his estate to them when he dies
61
 .
Defendant GRENADIER ANDERSON STRARACE DUFFETT & KEISLER, PC (GAS) a law firm in Virginia
with licensed partners in the District of Columbia. The firm consists of Ilona Grenadier Heckman founding
partner, Charles Anderson, Arlene Starace, Benton S. Duffett III, Shirly Keisler, Elaine Vadas, John T. Winkler
II, Lisa L. Levi, Carole A. Rubin, Carrie M. Patterson, Carolyn M. Abbate, Katherine D. Smith, Eric R. Nouri –
are all aware of this situation and are inclusion to protect Defendant IGH. All actions from the law firm have
been willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless.

Defendant State of Virginia should be held responsible for the actions of the collusion of the roles the
following agencies of the State were in collusion to prevent Plaintiff’s Constitutional right to Due Process – City
of Alexandria, Circuit Court Judges, Commonwealth Attorney, State Police, The Legislature of Virginia, City of
Alexandria Police, VSB, JIRC all Supreme Court Justices and Chief Justice The Honorable Cynthia D. Kinser
Plaintiff learned from LLM of her being Jewish and by all appearance from the blog that she also was in
collusion because of Plaintiff being Catholic. This was new evidence to Plaintiff. Circuit Court Hon. Lisa
Bondareff Kemler, Presiding Judge, Chief Judge Plaintiff has been aware all along this defendant was Jewish.
That her last signed Order was irrational and Treason on the Court. She went to Hebrew school with Plaintiff’s
x husband. Her father was Plaintiff’s girl’s pediatrician, and Plaintiff resisted naming her in this Treason. With
a very heavy heart Plaintiff has to look at the facts and realize her motivation is because I am Catholic. Her
actions in October of 2012 returning documents that had been filed in Court, to prevent the Truth and the
accounting of what Ilona Grenadier Heckman was responsible to Plaintiff was Treason on the Court. All
actions will show to have been willful acts that were and are malicious, violent, oppressive, fraudulent, wanton,
and grossly reckless.

The State of Virginia Attorney’s General alone was aware of these actions and refused to give the state police
the power to investigate. That when Attorney fees are awarded to attorneys with more billable hours to Judge’s
Chambers then to their clients and such bills were found acceptable to the Supreme Court of Virginia. The
State of Virginia’s Treason on the Courts by Judges, attorneys and their representatives will show to have been
willful acts that were and are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless. Justice is
supposed to be blind. In Bullock 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." But not only are trial judges required to be fair
and impartial, they must also 'satisfy’ the appearance of justice. The trial judge's 'appearance,' or conduct and
behavior, appearance of bias alone is grounds for reversal even if the trial judge is, in fact, completely
impartial.

LORETTA LAX MILLER –aka- LEAH LAX –aka-MUGGY CAT –aka- BILLY SULLIVAN (LLM et al)
Presidential Candidate for 2016 Emails will show started stalking JWG in May of 2013, is involved in
stalking, hacking of Plaintiff’s computer and e-mail. Is responsible for the BLOG:
jwgrenadierisalair.blogspot.com.

That she has on her personal and others to campaign Facebook, Twitter and Blogs supported the site since
the start of it. That her personal comment on the first written page is similar to other behavior in e-mails of hers
to try and act as if she is not Muggy Cat or Billy Sullivan – emails will show how this can be and should be
questioned. All actions will show to have been willful acts that were and are malicious, violent, oppressive,
fraudulent, wanton, and grossly reckless.
62
The Stalking and Malicious Treatment of Plaintiff by Defendants Ilona and Defendant Leah Lax et al along with
others This e-mail alone sent by Presidential Candidate for 2016 with the collusion of lawyer Ilona Ely
Freedman Grenadier and other e-mails that were falsified in a website jwgrenadierisalair.blogspot.com say
Plaintiff is racist against others is enough to prove liable intent – Yet Plaintiff has supplied other evidence in her
defense. This email is not the only one Plaintiff will enter into evidence at the appropriate time several e-mails
similar in nature to this. The Hate defendants have for Catholics, Christians, Muslims, Homosexuals and with
the picture of and the talk of First Lady Michele Obama having a penis you could add in my opinion African
Americans. No matter what your opinion on Hillary Clinton or Michele Obama are – the disrespect is
disgusting and according to the law liable.

That Leah Lax et al made a fool of the FBI – With this e-mail strand – E-mailing Plaintiff as Billy
Sullivan aka Muggy Cats that she was going to harm herself for me? The following initials have been
used FBI (Federal Bureau of Investigations), JWG(Janice Wolk Grenadier), LLM /MC (Leah Lax aka
Muggy Cats/ Billy Sullivan) The e-mails that are missing Plaintiff has copies of – but, have been
deleted off her computer by all appearance Leah Lax et al which it will be shown in court has hacked
Plaintiff’s computer. The e-mails will show that Plaintiff contacted the FBI even though all the
evidence pointed to one more of Defendant Ilona lawyers games in trying to intimidate Plaintiff and to
supply information to Circuit Court Judges in the hopes of destroying Plaintiff. Plaintiff cooperated
with the FBI in regard to Leah Lax et al and her game.. All e-mails will prove that Plaintiff has never
lowered herself to the level of Defendants. Plaintiff doesn’t have to because Plaintiff has the
“TRUTH”

That the Judges and attorneys have ignored the Laws and Rules of the Supreme Court of Virginia, the
Constitution of Virginia and the United States of America Constitution.

The-mail strand EXHIBIT under LLM shows the actions of Leah Lax et al is one in the same Muggy Cats /
Billy Sullivan. That Plaintiff concerned for Leah Lax et al contacted the FBI to keep her safe. That the personal
actions of Leah Lax et al are willful acts that were and are malicious, violent, oppressive, fraudulent,
wanton, and grossly reckless. that Plaintiff will show she worked in collusion with Defendant Ilona a lawyer.

63
CAMPAIGN FOR LORETTA LAX MILLER and all employees/volunteers – LLM et al has made statements
on her Blog, Twitter and Facebook thanking by all appearance her campaign/employees/volunteers in
slandering and defamation of JWG. All actions from the campaign have been willful acts that were and are
malicious, violent, oppressive, fraudulent, wanton, and grossly reckless.

That Plaintiff will be able to show that Leah Lax et al and her Campaign is a Fraud. She has yet to file a
Financial disclosure with the FEC and collecting donations since 2011, and has several outlets that she is
collecting money for her campaign this is a quote off of her Piryx site.
I affirm that the following statements are true and accurate:

Contributions to LORETTA MILLER are not deductible as charitable contributions for federal income
tax purposes. Contributions from foreign nationals and federal government contractors are
prohibited. LORETTA MILLER is registered with the Federal Election Commission as an
independent expenditure committee. Accordingly, we may accept unlimited contributions from
individuals, corporations, and other organizations. Your contribution is not subject to FEC
limits. LORETTA MILLER spending is independent, and it does not make contributions to, or
coordinate its spending with, any candidates or political parties

BACKGROUND

JWG Attaches Exhibit the Emergency Restraining Order and Injunction filed on January 22, 2014 along with
the notarized Filed Complaint with the FEC filed with the Emergency Restraining Order and Injunction.
History Plaintiff in September of 2007 went to Court in the City of Alexandria Virginia. Plaintiff had followed
all the rules of filing and service. Defendant Ilona, a lawyer lied in court to the Judge, and the Judge
reprimanded Plaintiff telling her not to re-file until October 2007. Plaintiff that night met a Federal Judge from
this court. He informed Plaintiff of her rights –He informed Plaintiff “You shouldn’t be crying you should be
rejoicing – You have just won your case – No Judge likes a lawyer lying to him in court” on a napkin he outlined
what I was going to put in Plaintiff’s Motion for Default. That Motion for Default was not heard until December
of 2007 when the Judges could find a retired Judge to rule in the favor of Defendant Ilona this practice would
continue and continues today. The Judges and the evidence shows this is not the last time the documents and
statements in court by Defendant Ilona and others have not been disingenuous all the way to the Supreme
Court of Virginia.

The slippery slope that would open up the truth of how Plaintiff 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. The Law is very clear that the Judges who have acted by ruling in
Favoritism and Cronyism and not by the Rules of the Supreme Court. “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)”

Plaintiff is aware of and understands the difficulties for any Judge in this case. But, the law has been abused
and broken by the State of Virginia’s judicial system and Plaintiff will be able to show this is not a unique
situation but, normal practice in the State of Virginia. The difference is they have not been able to kill Plaintiff
64
or break Plaintiff, and Plaintiff prays this court look at the evidence in documents and gives Plaintiff the right to
be heard. “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)”
“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 Constitution of the United States A fundamental, guarantee that all legal proceedings will be fair and that
one will be given notice of the proceedings and an opportunity to be heard before the government acts to
take away one's life, liberty, or property. Also, a constitutional guarantee that a law shall not be
unreasonable, Arbitrary, or capricious.

The constitutional guarantee of due process of law, found in the Fifth and Fourteenth Amendments to the U.S.
Constitution, prohibits all levels of government from arbitrarily or unfairly depriving individuals of their basic
constitutional rights to life, liberty, and property. The Due Process Clause of the Fifth Amendment ratified in
1791, asserts that no person shall "be deprived of life, liberty, or property, without due process of law." This
amendment restricts the powers of the federal government and applies only to actions by it. The Due Process
Clause of the Fourteenth Amendment, ratified in 1868, declares,"[N]or shall any State deprive any person of
life, liberty, or property, without due process of law" (§ 1). This clause limits the powers of the states, rather
than those of the federal government.

Plaintiff can show harm and the harm that has forever been done to her from the actions of the above
Defendants. Plaintiff may not have put all information in the best order – but, has done the best she can do.
She has done it with a pure heart and honest way and still has not had her day in court to be heard. Plaintiff
has still had not had due process Boddie v. Connecticut, 401 U.S. 371 (1971), was a case before the United
States Supreme Court giving the right to due process and to be heard.

Plaintiff’s ability to perform simple every day work has been stripped of her by the actions of the above
Defendants with her social media, her computers and e-mail being hacked and this court is looking the other
way.
Claim 1
Breach of Contract – Implied Covenant of Good Faith and Fair Dealing – Breach of
Contractual Duty of Good Faith and Fair Dealing

By virtue of the facts stated above, defendants have violated their contractual duty of good faith and fair
dealing. Plaintiff has paid fees to these courts and not received Due Process.

The above defendants and defendant’s representatives breached their contractual duty of good faith and fair
dealing when Judges ruled in Favoritism and Cronyism. When Judge’s did not have Jurisdiction and chose
friends/other Judges who would not follow the rules but would rules as told.

That the above defendants Breach of Contract includes not limited to their involvement being disingenuous in
documents filed with the courts and Orders. The documents will speak for themselves the defendants were
aware of these breaches as lawyers and Judges.

65
Plaintiff through implied covenant of good faith and Fair Dealing continued to follow the Rules of the Courts.

The defendant’s “flagrantly violated” their Fiduciary responsibility to the Judicial System and Plaintiff to deal in
Good Faith while Plaintiff continued to deal in Good Faith. The actions will be proven factually by Orders,
Letters, Documents filed in the court and other. That the constitutional Right of Due Process has been denied
time and time again.

Claim 2

Violation Title 42 § 1983 Civil Rights Statue

Civil Rights Act of 1968 enacted 18 USC 245

Defendants used unfair/unconscionable means to try and intimitad and scare Plaintiff – They have acted as the
Klue Klux Klan would have in the past. Plaintiff is aware that Plaintiff must show that Plaintiff can prove each
element of alleged facts in her claims. That to seek relief for the violation of a person’s Federal and
Constitution rights under Title 42 § 1983 it allows Plaintiff to her rights contained in the United States
Constitution as defined by Federal Law.

Plaintiff has been discriminated against for being Catholic That Civil Rights Act of 1968 enacted 18 USC 245
prevents discrimination due to Religion That this is a Hate Crime and “Hate crime laws are colorblind” Fact
the case which the Supreme Court upheld hate crimes of the First amendment attach, Wisconsin v. Mitchell,
508 U.S. 476(1993) involved a white victim.

Plaintiff has been discriminated against for being black balled by the Old Boy’s Network / Judicial Community
due to her x-husband being the son of the late Judge Albert Grenadier whom was the Husband to Defendant
Ilona a lawyer who has also intervened into Defendants Divorce. That the discrimination and segregation
among white exist the power Hierarchy by a member of one that is considered by others inferior to the
other.

Claim 3
Consumer Protection Act

The State of Virginia was paid for services in the Court that were denied Plaintiff because she was Catholic.
That the discrimination and segregation among white exist the power Hierarchy by a member of one that is
considered by others inferior to the other.

Claim 4
Breach of Fiduciary Duty
Unjust Enrichment/Constructive Trust

That the State of Virginia had a Fiduciary Duty to insure the rights and safety of Plaintiff in the and through the
Court system. Plaintiff has been harmed by the false statements which are considered defamatory – that
Plaintiff has “ THE TRUTH” which is an absolute defense .

66
That the First Amendment of the U.S. Constitution was designed to protect Freedom of the press. The 1964
case New York Times Co. v. Sullivan radically changed the nature of libel law by establishing a suit for libel you
needed to prove that the information was wholly and patently false or that it was published “with reckless
disregard of whether it was false or not”

Claim 5

Injunctive / Declaratory Relief

That Plaintiff now needs to pray this court grants temporary or permanent injunctive relief as Plaintiff’s
reputation has been harmed for life. That Plaintiff as anyone else in the United States should have easy
and fair access to the courts. That no one should be denied access and fair treatment due to race,
age, sexual orientation.
To warrant preliminary injunctive relief, the moving party must show

Substantial likelihood of success on the merits – Plaintiff believes she has provided this court with
the information needed to outline the actions of both defendants and the Criminal actions of all the
Defendants along with documentation that should without doubt assure this court

That she would suffer irreparable injury if the injunction were not granted – Plaintiff has a child
friendly product that has been for ever harmed by the loss of Social Media, the blog
jwgrenadierisalair.blogspot.com the e-mails that were created by or from the hacking of Plaintiff’s
computer that state the following –

AGAIN PLAINTIFF HAS NEVER SAID THIS! Plaintiff WILL BE PROVE These e-mails to BE THE
FRIVOLOUS imaginative of Defendants to permanently harm Plaintiff. Just the name of the blog
itself is offensive and violates Plaintiffs’ Constitutional rights – and is libel and defamation of
character of Plaintiff - jwgrenadierisalair.blogspot.com

Thursday, January 9, 2014

Janice Wolk Grenadier wishes death on Loretta Lax Miller's son who is going in for surgery
If you want to read what sick piece of garbage Janice Wolk Grenadier aka Granny Panties is, you should read
the newest email sent to us by her.

-----Original Message-----
From: JWG <jwgrenadier3@aol.com>
To: muggycatscreams <muggycatscreams@aol.com>; leahlax1234< leahlax1234@aol.com>
Sent: Wed , Jan 8, 2014 1:40 pm
Subject: I hope your son DIES
I hope your son dies during his surgery tomorrow! It will be one less JEW BOY out there. He should have died
at childbirth. You can bury your son and then die after!

67
Warmly,
JW Grenadier

What kind of sick piece of garbage does that? What kind of sick, evil, and sadistic person would tell a mother
that they hope her kid dies during surgery? This shows what kind of sick, sadistic evil piece of filth that Janice
Wolk Grenadier is and should be put away for her sick actions. Who would wish a person death? Janice Wolk
Grenadier would.

We here at Muggy Cat want to wish your son a healthy recovery on his surgery Ms. Lax Miller. We are so sorry
you are being harassed by that sick woman.
Posted by muggy cat at 11:21 AM

Monday, January 6, 2014

This explains it's self
-----Original Message-----
From: JWG <jwgrenadier3@aol.com>
To: muggycatscreams <muggycatscreams@aol.com>
Sent: Tue , Jan 7, 2014 12:15 am
Subject: Re: Had it with you!

Look you Jew Bastard I had it with you and now you are going to pay.

Warmly,
JW Grenadier

Sunday, January 5, 2014

Is this the writing of a crazy woman
-----Original Message-----
From: JWG <jwgrenadier3@aol.com>
To: muggycatscreams <muggycatscreams@aol.com>; leahlax1234 <leahlax1234@aol.com>
Sent: Sun , Jan 5, 2014 9:45 pm
Subject: YOU FUCKING JEWS
You refuse to take my side. I wrote to you about my problems and you called me names
"Me and My family had nothing to do with your girls because you raised them Catholic" by - Jewish attorney Ilona Ely
Freedman Grenadier Heckman - of Grenadier, Anderson, Starace, Duffet & Kiesler
Israel wants the United States of America to defend them - yet some of the most powerful Jews in the Washington DC
area - are discriminating against Catholics, Corrupting the Judicial System, and Cheating the IRS. - My personal opinion
is we need to be friends with Israel - But, they have to have the same respect for other religions - and for the Laws and the
Rules of the Supreme Courts and the United States of America's Constitution - Very powerful Jews in the DC area Ilona
68
Ely Freedman Heckman and Yoav Katz are using their money and power to buy their war around the Judicial System and
cheat the IRS! you can read more at www.valaw2010.blogspot.com
Now you tell Ilona to give me my money.
No one is going to believe you. They will believe me because I tell the TRUTH! and you Jews all lie. Jews like you belong in
your graves. I deserve that money!
I have a gun and I know how to use it!
When Hillary gets into office, I am going to make sure all of you FUCKING JEWS are put into concentration camps to die. I
support Hillary and she hates you FUCKING JEWS!
Warmly,
JW Grenadier

This letter came to us here at Muggy Cat at 9:45 PM EST. Doesn't this show the kind of obsession that Janice
Wolk Grenadier has against anyone that doesn't agree with her. What is next? Is she going to go after our
families? However she went after her family or should we say ex-family who disowned her. We have posted
previous letters that Janice Wolk Grenadier had sent to her family in previous blog posts.

Now here is something really funny and intersting about Janice Wolk Grenadier. Well actually a few funny
things. Today she was seen naked in her back yard building an ice alter to her Dark Lord Satan. She was doing
this in the freezing rain. The scary part was she had icicles hanging from her oversized nipples and from her
pubic hair. She then took a large icicle and began to masterbate with it until it melted.

A neighbor had seen Janice Wolk Grenadier walking out of a sex shop Friday night with a large bag filled with
sex toys and two very large women who looked like Amazons. They were seen driving to a gay bar in which
Janice and the two women frequent and have pajama parties afterwards. She left Saturday morning with her hair
disarray and a smile on her face. A dog collar could be seen around her neck and welts on her arms and legs. We
don't think she is the dominant one in this relationship. Family services should have taken her kids away from
her years ago. She neglected them for her sexual pleasures and alcohol addiction.

Janice Wolk Grenadier adores her Fuher Adolf Hitler who was also bi-sexual. Janice Wolk Grenadier has been
seen wearing a painted on mustache just like her idol and walking around wearing a Swasticka on her rare selfie

of Janice Wolk Grenadier

This classless woman should be put away in a padded cell so she can't hurt anyone else. Someone please call the
authorities to have her institutionalized for her safety and for the safety of others. Remember she carries a gun!

Sunday, January 5, 2014

69
Janice Wolk Grenadier supports the Anti Christs Obama and Hillary Clinton

Not only is Janice Wolk Grenadier a traitor to the American people by being a card carrying Commie Pinko but
she is also supporting the Anti Christs Obama and Hillary Clinton. Yes we said it here, Anti Christs meaning
plural. Why is Janice doing this? Because they are not only going to let her keep her hairy vag but they are
going to give her the chance to grow a penis as well. Well penises. Yes, Janice Wolk Grenadier will have 6
penises all over her body including one over her vagina. The other 5 will be as so: one in the palm of each hand,
one on the bootom of each foot and one right where a tramp stamp would be on her back. That way when Janice
Wolk Grenadier dies, she can go to Allah's heaven and have her 72 virgins. These 72 virgins will be a mix of
males and females that she can rape with all of her penises and then the next morning at sun up they become
virgins again. We have figured it out that the fetal body of little Joshua that Janice keeps in the basement of her
home is going to be the vessel for the Dark Lord Satan himself to resurrect in a human body to carry out the
apocolypse. That way, Janie Wolk Grenadier is guaranteed her 6 penises.

Proof she supports the Anti Christ is in her letters she has posted and her other posts of Hillary's and Obama's
support defending both on everything Loretta Lax Miller fought against including the ObamaCare and Islamic
Terrorism which Obama and Hillary support. Janice is for the destruction of the Catholic Church's values of
having Nuns despense birthcontroll pills. Janice supports this by supporting Hillary Rodham Clinton and
Barack Husein Obama. Everything Obama stands for is to destroy American Family Values and Janice has no
values and worships Satan.

We at Muggy Cat take the religious stand that Janice is the Anti Christ and does not beleive in God and the
wonders God has done on this Earth. Maybe Janice should move to sin city Las Vegas and sell her soul as well
as her fugly body on the strip since she is whoring for Satan.

-----Original Message-----

From: JWG <jwgrenadier3@aol.com>

To: muggycatscreams <muggycatscreams@aol.com>; leahlax1234 <leahlax1234@aol.com>

Sent: Wed , Jan 1, 2014 10:45 am

Subject: Re: i agree with you

You FUCKEN JEWS!!!!!! ALL OF YOU . DICK FARREL JOSH COHEN, LEAH LAX AKA LORETTA
LAX MILLER AND THE REST OF YOU FUCKEN 30 JEWS. Hitler was right! Ya'll deserve to die! YOU
SHOULD BE PLACED IN A BIG OVEN.

70
Warmly,

JW Grenadier

We hope that you join us on Friday, January 10th, 2014 outside of Janice Wolk Grenadier's house to protest her
anti-American pro-Satan values. Email us at muggycatscreams@aol.com for Janice Wolk Grenadier's address.
We are expecting at least 200 people so don't forget to bring Holy Water from your church to purify and sactify
the land of the supporter of the Anti Christ and the mother of the vessel of Satan. We will have a prayer session
to pray for her lack of soul but do not look her straight in the eyes or you will be turned to stone.
Posted by muggy cat at 8:48 AM
Email ThisBlogThis!Share to TwitterShare to Facebook Labels: CIA, FBI, Hillary Rodman Clinton, Janice
Wolk Grenadier, KGB, leah lax, MI5, MI6, My Pillow Pack, Obama, virginia law 2010

That the above is just 3 pages out of almost 200 printed out pages of slander and Libel of

Plaintiff by Defendants. Plaintiff felt the e-mails that bear her name THAT PLAINTIFF DID NOT

WRITE should hold a lot of wait in what Plaintiff will be able to prove.

That an injunction would not substantially injure other interested parties and This blog has hurt no one
but Plaintiff and her ability to market and advertise a Child Friendly product. This blog and other actions were
deliberate willful acts that are and were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.
That the hacking and killing of Plaintiff’s computers was malicious and has also prevented Plaintiff the right to
market her product.

That the public interest would be furthered by the injunction – the HATE CRIME OF THIS is sinful and
that this court cannot see that becomes questionable to the rational of fairness. That the sexual and in
appropriate photos of Hillary Clinton and Michele Obama in there blogs – The racist and religious overtures of
HATE BY DEFENDANTS is so obvious that to have to go any further would show Bias by this court and any
one of normal moral value. . “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)” Loving v. Virginia, 388 U.S. 1 (1967) was a landmark civil rights decision of the
United States Supreme Court against discrimination. Which includes being discriminated because the Judge’s,
lawyers, elected officials and government employees have decided you are not a part of or one of them.

Claim 6

Common Law Fraud 12 U.S.C 1972

On several occasions Plaintiff asked the courts to review and asked for a Special Grand Jury to look into the
allocations of misconduct. Plaintiff was to go in front of the Grand Jury with her witness’s – But, instead was

71
kidnapped in a different Court Room and Grand Jury was dismissed prior to her being allowed into ask for the
Special Grand Jury..

Claim 7

Negligence – the negligent infliction of emotional distress; the intentional infliction of emotional
distress

The defendant’s had a legal duty to use reasonable care in statements posted on the internet about Plaintiff.
They did not do this. They have posted several lies about Plaintiff and others. They have done ruined
Plaintiff reputation and should be held financially and legally responsible for their actions.

The defendant’s malicious actions caused great emotional distress to Plaintiff. By the Commonwealth
Attorneys orders of the City of Alexandria police to never take a complaint from Plaintiff? Plaintiff has been
harmed by the false statements which are considered defamatory – that Plaintiff has “ THE TRUTH” which
is an absolute defense . That the First Amendment of the U.S. Constitution was designed to protect Freedom
of the press. The 1964 case New York Times Co. v. Sullivan radically changed the nature of libel law by
establishing a suit for libel you needed to prove that the information was wholly and patently false or that it was
published “with reckless disregard of whether it was false or not”. Plaintiff has been put into an unfair and
dangerous position to protect herself and her girls.

The actions of the actors to cause this emotional distress were malicious, violent, oppressive, fraudulent,
wanton, or grossly reckless.
Claim 8
Constructive Fraud

The defendants were deceptive of material misrepresentations of past and existing facts and remained silent
when a duty to speak existed.

The defendant’s actions were Arbitrary and Capricious absence of a rational connection between the facts
found and the choice’s made, made choices that were not in accordance with the law.

Claim 9
Civil Conspiracy

The Collusion of the Defendants actions show collusion to harm Plaintiff from and was done with malicious,
violent, oppressive, fraudulent, wanton, or grossly reckless intentions.

Defendants Civil Conspiracy to Commit Tortious Interference with Contractual Relations abuse of process,
intentional infliction of emotional distress,

Civil conspiracy to commit injurious falsehood with jwgrenadierisalair.blogspot.com that Plaintiff has a
“protected characteristic” which will be proven as to why Plaintiff was sought out by Defendant and that factor
is why Plaintiff was targeted by Defendants

72
Defendants were in collusion of civil conspiracy to intentionally inflict emotional distress.

Claim 10
The Four Basic Freedoms Guaranteed by the Bill of Rights

Plaintiff will prove a violation of Plaintiff's Bill of Rights the Four Basic freedoms are being Violated:

he Four Freedoms
1. Freedom of speech 2. Freedom of worse 3. Freedom from want 4. Freedom from fear

Plaintiff will show the actions of the Defendants were actions that were willful acts were malicious, violent,
oppressive, fraudulent, wanton, or grossly reckless That the defendants were acting under the color of State
and Federal law. That the Constitutional Rights of due process are factual allegations that will be proven
through documents, letters, e-mails and actions of defendants. That defends had been given notice, and this
court is aware of with the threat from Defendant Ilona’s attorney. That Defendants never filed a response, in
regard to the Restraining Order and Injunction. Defendants were notified on or around January 22, 2014 and
Order was not written until January 31, 2014 with NOT ONE Defendant responding or disputing Plaintiff’s
facts.

Plaintiff incorporates information filed in this court:

January 23, 2014 Emergency Restraining Order w/FEC Complaint

January 24, 2014 Verified Complaint - to be amended

January 24, 2014 Request for Emergency restraining Order and Injection with other Evidence

January 31, 2014 2nd Request for Emergency Restraining Order and Injunction with Other Evidence

February 2, 2014 3rd request for Emergency Restraining Order and Injection with Other Evidence and to go in
front of a Judge.

February 3, 2014 Motion to be heard by a Judge

February 6, 2014 4th Request for EMERGENCY RESTRAINING ORDER and INJUNCTION WITH OTHER
EVIDENCE and to be heard by a Judge “The appearance of Justice is as Important as Justice itself”

February 10, 2014 EMERGENCY RECONSIDERATION OF ORDER Jan 31, 2014

5th Request from Plaintiff to be heard by a Judge to explain VERY complicated Situation of Request for
Emergency Restraining Order and Injunctions

73
 15 W. SPRING STREET
ILLEGAL FORECLOSURE

THIS WILL SHOW THE ILLEGAL AND CRIMINAL COLLUSION OF

THE HEADS of BANKS OF 2008 WHO HAVE NOW MOVED TO THE HEADS SERVICERS
TO CONTINUE THE SCHEME OF THEFT OF HOMES FROM THE AMERICAN PEOPLE WITH NO
STANDING AND NO ABILITY TO SHOW STANDING EXCEPT WITH MADE UP DOCUMENTS (INSIDERS
OF OCWEN/PHH HAVE CONFIRMED THIS), FORGED DOCUMENTS, USE OF FAKE LAWYER NUMBERS
ON ASSIGNMENTS, Made UP ASSIGNMENTS, FALSE and MISLEADING ADVERTISING, the SALE OF
SERVICING OF FORECLOSED LOANS FOR FINANCIAL GAIN, THAT ONCE A LOAN IS FORECLOSED
ON THE LOAN IS NOT TAKEN OFF THE BOOKS - IT IS SOLD TO ANOTHER SERVICER, ET AL

THAT THE BANKS CO-MINGLED LOANS ON FINANCIAL STATEMENTS by all appearance and now this
accounting is being done by the SERVICERS as seen between OCWEN/PHH and NEWREZ LLC

THAT THE ABOVE FEDERAL PLAINTIFFS CAN VERIFY THROUGH THEIR OWN WEBSITES, PAST
SUITS, THE US GOVERNMENT ACCOUNTABILITY OFFICE (GAO) REPORT TO CONGRESSIONAL
REQUESTERS 2011 FINANCIAL CRISIS REVIEW OF FEDERAL RESERVE SYSTEM FINANCIAL
ASSISTANCE TO AMERICAN INTERNATIONAL GROUP INC. 3 (GAO), The 2010 CONGRESSIONAL
OVERSIGHT PANEL JUNE OVERSIGHT REPORT * THE AIG RESCUE, ITS IMPACT ON MARKETS, AND
THE GOVERNMENT’S EXIT STRATEGY4
and THE 2011 The FINANCIAL CRISIS INQUIRY REPORT 5 WHICH REUTERS Reported:

SEC order helps maintain AIG bailout mystery 6:

● SEC Agreed with AIG to keep some bailout terms sealed

● SEC granted “confidential treatment”
● SECrecy order stays in place until November 2018

BY ALL APPEARANCE WHERE SOME OF THE “SECRET” AIG MONIES WENT

Government Bailout Money Received

Banks Receiving Bailout funds 9 Banks gave 5,000 bonuses of at least $1 Million
Citi gave 738 bonuses of $1 Million with Reported loss of $18 Billion
Banks Receiving Bailout Funds: 6 Banks paid more in bonuses than they earned in Profits7

Banks $ Amount

Bank of America $ 1,535,002,662,031

Citi $ 2,920,896,888,595

3
https://www.gao.gov/new.items/d11616.pdf
4
https://fraser.stlouisfed.org/files/docs/historical/fct/cop_report_20100610.pdf
5
https://www.govinfo.gov/content/pkg/GPO-FCIC/pdf/GPO-FCIC.pdf
6
https://mobile.reuters.com/article/amp/idUSN1116982020100111
7
From The Con
74
 Goldman Sachs $ 874,552,426,455

JP Morgan Chase $ 460,982,382,326

Morgan Stanley $ 2,287,966,932,941

Wells Fargo Bank $ 198,712,559,776

THAT the $251 BILLION the banks paid as reported by Forbes to the Government to not go to jail looks like
pocket change

THAT THE APPEARANCE IS THE FORECLOSURE LAWYERS FOR BUSINESS and PERSONAL
FINANCIAL GAIN HAVE COLLUDED TO “COVER-UP” THE LACK OF STANDING

How Much of the above money went to these bonuses the Executives / CEO’s included in this complaint? Why
wouldn’t the Execurtives move to a regulated business by. Recuters

The CFPB has on its site:

COMPLAINTS:

Option One Showing 27,176 matches out of 1,744,719 total complaints

American Home Mortgage Servicing Showing 18,754 matches out of 1,744,719 total complaints
PHH Mortgage Showing 3,261 matches out of 1,744,719 total complaints
OCWEN Mortgage Showing 3 0,219 matches out of 1,744,719 total complaints
75
Wells Fargo Bank Showing 80,785 matches out of 1,744,719 total complaints
Bank of America Showing 119,746 matches out of 1,744,719 total complaints

12 U.S. Code § 265 Insured banks as depositaries of public money; duties; security; discrimination between banks
prohibited; repeal of inconsistent laws

12 U.S. Code § 2605 Servicing of mortgage loans and administration of escrow accounts

15 U.S. Code § 77q. Fraudulent interstate transactions

15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES, § 1692d - Harassment or abuse, § 1692e -False or
misleading representations, § 1692f - Unfair practices, § 1692g - Validation of debt, § 1692j -Furnishing certain
deceptive formFair Debt. Collection Act (FDCPA), § 806 Harassment, § 807 False and misleading, § 808 Unfair
practices,
§ 809 Validation of debts, § 812 Furnishing deceptive forms, et al

18 USC § 371 Conspiracy

18 USC § 1341 Frauds and Swindles
18 USC § 1343 Fraud by Wire,
18 USC §1344 Bank Fraud
18 USC §1346 Honest Services
18 USC § 1348 Securities and commodities fraud
18 USC §1349 Attempt and Conspiracy Sarbanes – Oxley Act
18 U.S. Code § 666 - Theft or bribery concerning programs receiving Federal funds

26 U.S.C. § Section 61 A (1)

26 U.S.C. § Section 108 (i)
26 U.S.C. § Section 451
26 U.S.C. § Section 1033
U.S.C Section 1.751, CFR 1.752
SEC Rule 1122 AB
Regs. Sec. 1.707-3(b)(2) Disguised sales of property to partnership

Virginia Fraud Against Taxpayers Act. CODE OF VIRGINIA FALSE CLAIMS; CIVIL PENALTY Virginia Code
Ann. § 8.01-216.3 (A)(1)-(A-4), 8.01-216.3 (A)(7)

31 U.S.C. § 3729 Federal False Claims Act Violation of the Consent Order in 2014 with the DOJ and 48 states
including Virginia.

That when OCWEN issued the 1099-A it did not use a company it would have and did use a name that could be a “Payer
Agent” ? ALL FDCPA “debt collections” of JWG were denied.

This is the ENRON game with a twist:

1. Take Bad Assets written down to 10% of the original appraised value
2. Recap them by pulling them into CMBS
3. Originate loans to anyone by taking the title up front - under the IRS Rules for installment sale
4. Now the pool of crap is properly capitalized

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 5. Now amortize the bad Bank OREO by 10% annually to keep within range of a qualified investment
6. Assign the amortized amount annually to Consumers as pass-through investors
7. and then issue a 1099 A to close out these like-kind exchanges in the year of disposition
8. Where the title held by a BANK TRUSTEE A is released to the payees agent OCWEN
9. For the LLC to recast Itself by paying your withholding taxes on the Phantom earnings

The IRS calls these tax promoters and liquidation schemes “genius” intended to beat the best intent of Congress who is
the authoritative guidance under Title 26. These are passed through Investments. JWG did not agree to a pass through
Investment.

That JWG claims against OCWEN et al for ABUSE AND FRAUDULENT PROCESS by Officers of the Court acting to
wrongly take real estate of the Petitioner located at 15 Spring Street, Alexandria, Virginia (22301) under color of law and
fraudulent trustee process, to intimidate and cause a wrongful auction on August 17, 2017 and now October 5, 2017
(stating information requested in 2012 will be given to JWG on or around October 2, 2017) , to wrongfully take JWG’s
real estate without right established by AUTHENTIC DOCUMENTS as REQUIRED BY LAW.

Theft by deceptive taking taking: the attorney and trustee acts, under color of law, are intentionally designed to harass
and intimidate plaintiff to wrongfully deprive her of her lawful rights of ownership, by Brock & Scott PLLC on or around
March 30, 2018,

NEW EVIDENCE SHOWS SECURITY & COMMODITIES FRAUD, THE LACK OF STANDING & FRAUD
ON THE COURT BY LAWYERS

THAT ALL ACROSS AMERICA “WE THE PEOPLE” are paying on “FAKE” MORTGAGES
THAT THE BANKERS of 2008 are now THE SERVICERS of 2020

THAT These “FAKE” Mortgages have been in the Public since the MULTI-STATE settlement with
Lynn Szmoniak, Esq., December 12, 2012 (Exhibit 2 )
In the USDC District of South Carolina (Rock Hill) C.A. No. 10-cv-01465-JFA
THAT THIS SHOWS NOTHING HAS CHANGED except
THE BANKS have turned it over to the SERVICERS to do the DIRTY WORK -
INCLUDING & NOT LIMITING it to the EXECUTIVES of the BANKS
now being the EXECUTIVES of the SERVICERS

THE QUESTIONS FOR ALL AMERICANS: Are you paying on a “FAKE” loan?
Where is the accounting of the “TARP” MONEY

NEW EVIDENCE SHOWS

VIOLATIONS OF United States CONSTITUTION & VIRGINIA STATE CONSTITUTION
VIOLATION OF AMERICANS 4 FREEDOMS of Speech, Worship, Want & FEAR

FRAUDULENT CONVEYANCE with FRAUD ON THE COURT/ IDENTITY THEFT / DOCUMENTS

KNOWINGLY FILED IN THE CITY OF ALEXANDRIA FORGED / MISLEADING and DAMAGES, FRAUD
ON THE COURT A PATTERN & PRACTICE
with DEFENDANTS LAWYERS

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 That the Attorney’s Duty to the Court Against Concealment, Nondisclosure and Suppression of Information as
Coextensive with the Duty Not to Allow Fraud To Be Committed upon the Court 8

For ABUSE AND FRAUDULENT PROCESS by Officers of the Court acting to wrongly take real estate by theft of
JWG located at 15 Spring Street, Alexandria, Virginia (22301) under color of law and fraudulent trustee process, to
intimidate and cause a wrongful auction on August 17, 2017 and now October 5, 2017 (stating information requested in
2012 will be given to Plaintiff on or around October 2, 2017) , to wrongfully take petitioner’s real estate without right
established by AUTHENTIC DOCUMENTS as REQUIRED BY LAW. FOR THE taking on March 30, 2018 with an
illegal and fraudulent FORECLOSURE.

THEFT BY DECEPTIVE taking: the attorney and trustee acts, under color of law, are intentionally designed to harass
and intimidate plaintiff to wrongfully deprive her of her lawful rights of ownership,

THAT the Defendants, individually and jointly are acting in bad faith, for their own financial interests (and not that of
any client) to perpetuate a financial law-scam for their own advantage against the Plaintiff under color of law, including
breach of fiduciary duty to this plaintiff/homeowner indicating a LACK OF DUTY OF CARE, FAIR DEALING AND
GOOD FAITH that is A PATTERN AND PRACTICE OF DEFENDANTs

Co-Defendant conspiracy to enrich themselves: SERVICER OCWEN AND FORECLOSURE LAWYERS BWW Law
GROUP, MCCABE WEISBERG & CONWAY, BROCK & SCOTT and TROUTMAN PEPPER HAMILTON
SANDERS (AND OTHERS) APPEAR to have designed a fraudulent ‘foreclosure’ scam that takes personal financial
ADVANTAGE of homeowners by FRAUD under color of law, without a bonafide client (in this case, Wells Fargo
Mortgage Co.) THE Defendant’s acts seek to BENEFIT themselves, as officers of the court, by manipulating the “trustee”
system, to illegally move homeowner property into foreclosure auction, where the officers of the court are the
sole-beneficiaries. This FRAUDULENT SCHEME, uses illegal intimidation and improper auction process (of Virginia
real estate) TO generate excessive profits for their own law-corporate/trustee POCKETS

In this case, pursuant to Wells Fargo CEO office statements to Plaintiff / JWG and CRPB on or around August 11, 2017,
there is no Plaintiff / Wells Fargo loan underlying the OCWEN and co-defendant's actions.

Servicer-Company, OCWEN/PHH fraudulently stated, “ we have a copy of a note we get to collect on.” For reasons
demonstrated herein, that statement is untrue, and all defendants have refused to produce any such instrument. Under
color of law, the Defendants fraudulently acted to ‘collect’ a non-existent Wells Fargo “loan” by hiring Foreclosure
Lawyers/Defendants/BWW/MCW and Brock & Scott,” who ignored the Fourth Circuit stay on said property which put
JWG in Bankruptcy to stop foreclosure, then the request/ demand of OCWEN not to Foreclose to Brock & Scott
(conversation is taped and can be heard https://www.youtube.com/watch?v=00gWnLp11vI) – by improperly
implementing foreclosure and auction proceedings for their joint-profit, by acts and omissions that are illegal and
unethical under the laws of Virginia.
OCWEN WITH OCWEN LAWYERS MALICIOUSLY INTERFERED WITH the rights and real property interests
of the Plaintiff, and have cause extensive damage and irreparable harm as a result, for which the plaintiff seeks
compensatory and punitive damages for the Defendant’s joint illegal acts of pretext, by lawyers and trustees, under color
of law. That OCWEN used its own employees to impersonate that they had Power of Attorney for Wells Fargo Bank.

COMES NOW Plaintiff Janice Wolk Grenadier (JWG) and or the UNITED STATES OF AMERICA ℅ Department of
Justice / AG William Barr, SECURITIES AND EXCHANGE COMMISSION, CONSUMER FINANCIAL
PROTECTION BUREAU (CFPB) et al reserves the right to amend this Complaint and to add additional Parties per
FRCP Rule 15. That Amended Verified Complaint corresponds with attached Exhibits filed and should be used as with the
Verified Complaint. Plaintiff Janice Wolk Grenadier complains against the captioned Defendants as follows:

INTRODUCTION

8
The extent to which it is regarded as council's duty to advise the court as to matters relevant to the proper decision of the
case of which opposing counsel is ignorant or which he has overlooked turns on the degree to which the old idea that
litigation is a game between the lawyers has been supplanted by the more modern view that the lawyer is a Minister of
Justice. H. Drinker, legal ethics 76 (1953)
78
That the American Citizens have had their rights violated by a government that is supposed to protect them from
schemes that are obvious FRAUD by BANKS, SERVICERS & LAWYERS. That the courts / judges have a financial
interest if they have a Vanguard or other money market account.

OCWEN/PHH Mortgage:

● Ocwen failed to provide any accounting or proof of JWG prior payments had been properly credited, and
refused to accept JWG payments or otherwise communicate with JWG.
● OCWEN caused damages including the imposition of late charges for JWG purported nonpayment,
charges for "forced insurance on the property," and interest and costs related to untimely property tax
payments and property inspections.
● OCWEN employees have stated the following of OCWEN’s acts and actions in collusion with lawyers to
harass and further mentally abuse homeowners: Do not answer phones, Turn off Fax machines etc. That
the lawyers did not respond to the OCWEN employees questions and requests.
● OCWEN past employees state clearly: after the purchase of PHH that OCWEN was going to be going
into Bankruptcy and or Closing its doors.
● The appearance is that OCWEN is moving its assets into NewRez, a subsidiary of New Residential
Investments Corp. you then have , Mr. Cooper / COOP on the Stock Market, and Brookfield BAM on the
stock market. After PHH took over it moved 15 W. Spring St. as an alleged loan to NewRez. This loan
should not exist, as Wells Fargo Bank N.A. according to the Foreclosure and their lawyer Troutman
Sanders, Syed Mohsin Reza was the owner of the loan alleged on the property
● WELLS FARGO BANK in a notarized statement states no ownership and or any record of any loan or
interest in Spring St.

That the appearance of the facts that insiders have shared with JWG and with the acts and actions of OCWEN / PHH is
moving its assets to NewRez that was once owned by PHH. That further shows that investors, shareholders of owner The
Residential Investment Corp may not know loans that do not exist and or should not exist are being moved and or counted
as assets on OCWEN / PHH as well as New Rez and the question becomes:
How many do non existing assets accounted for - for which companies etc. is a Question all Plaintiffs should be concerned
with as they are supposed to protect the public from these Schemes.

The documents filed against the home at Spring St. also shows it being on the balance sheet of Wells Fargo / Bank of
America aka LaSalle Bank.

Stay granted and violated. That on August 8, 2017 a “STAY” in Appeal No. 16- 2459 in the Fourth Circuit Court of
Appeals which Defendant OCWEN Loan Servicing LLC along with BWW LAW GROUP, a/k/a BIERMAN, GEESING,
WARD & Wood, LLC. HOWARD N. BIERMAN , EQUITY TRUSTEES, LLC. MARK R. GALBRAITH , WELLS
FARGO, BANK OF AMERICA, f/k/a - as successor-in-interest to LaSALLE BANK, are Defendants. With a Claim
Wells Fargo is the Note Holder while Wells Fargo informs CFPB they have nothing to do with a loan at 15 W.
Spring St., Alexandria VA 22301 and or with Janice Wolk Grenadier. That Wells Fargo Bank went as far as to file
a such a statement in the Circuit Court of the City of Alexandria, and then to OVERNIGHT prior to court to JWG
a STATEMENT THAT WELLS FARGO BANK HAD NO SUCH DOCUMENTS

WELLS FARGO BANK employee went so far as to investigate including with Mers and other sites and stated very
clearly to JWG “NO SUCH LOAN EXISTS, DO NOT GIVE UP YOUR FIGHT”.

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That OCWEN foreclosed on Janice Wolk Grenadiers home of now 29 years with Forged, Fake Fraudulent Documents.
The foreclosure took place On or around March 30, 2018 (JWG is still in the home) then sent a Fraudulent IRS 1099-A,
(February 2019). The lawyers for OCWEN - TROUTMAN SANDERS
have used an agent Micheal Martinez to harass and try to get JWG to do a short sale after the Foreclosure with all
appearances for personal gain for lawyers at Troutman Sanders aka Mays & Valentine (Lawyer Syed Mohsin Reza. The
alleged loan has now been transferred to NewRez LLC by OCWEN /PHH as of on or around August 26, 2019,
remember this loan was foreclosed on by Wells Fargo Bank N.A. on or around March 31, 2018. That lawyer Syed
Mohsin Reza on February 27, 2020 sent JWG a malicious, threatening letter, after having stated in court on or around
August of 2019 that “ WELLS FARGO BANK N.A.” owned the alleged loan. On December 7, 2018 Wells Fargo Bank
N.A. filed in the City of Alexandria Court that it was unable to locate any Information on such loan and or home. On
August 7, 2019 in a notarized letter Wells Fargo N.A. No documents, records, or other materials exist for Janice Wolk
Grenadier and or the property at 15 W. Spring Street, Alexandria, VA 22301. That Janice Wolk Grenadier owns stock in
OCWEN / PHH merge on or around October 4, 2018, NewRez LLC (OCWEN is moving its Assists which includes and
not limited to loans that do not EXIST or should not such as Spring St.) aka New Residential
Investments Corp, Wells Fargo Bank and Mr. Cooper. JWG filed 42 Complaints between 2017 - 2019 Ignored by the
CFPB.

Defendant lack of standing. That on or around 2013, Defendant OCWEN (only has Servicing Rights not the Right to
assign) became aware of its lack of standing to pursue any type of foreclosure action on Plaintiff’s home, located at 15 W.
Spring Street, Alexandria VA 2230, but they nevertheless, for their own financial profit and gain, pursued illegal
collection remedies that have wrongfully harmed this Plaintiff. That Evette Morales who signed as attorney in Fact for
Wells Fargo Bank is an employee of OCWEN. The person who notarized the document that gave Surety Trustee aka
McCabe Weisberg and Conway the right to Foreclose has the same title as Evette Morales and seems to be office mates.
Further Wells Fargo Bank denies every giving Evette Morales any type of POWER OF ATTORNEY to decide who
has foreclosure POWER. Evette is a Contract Management Coordinator at OCWEN Financial Corporation. This job
advertises for a salary of $30,000 - $36,000 approx. That OCWEN/PHH employee stated clearly that OCWEN
employee’s jobs were gaged on how many documents were done in an hour. That the working conditions were like
a sweatshop. Employees let go were replaced with employees in India. The employees were told by Lawyers to
leave customers on hold, turn off FAX machine’s so they could not receive documents, not to answer the phones.
The foreclosure lawyers depended on the employees to create “FAKE and FRAUDULENT” documents for them to
put their names on as reviewing them.

That in or around 2014, OCWEN to avoid any criminal charges – no different then in the past with Wells Fargo Bank and
Bank of America did a consent ORDER to cease and desist the criminal activity. The Securities and Exchange
Commission (“Commission”) deems it appropriate that cease-and-desist proceedings be, and hereby are, instituted
pursuant to Section 21C of the Securities Exchange Act of 1934 (“Exchange Act”) against Ocwen Financial Corp.
(“Ocwen” or “Respondent”).9

That OCWEN has violated the Consent ORDER that was also signed by the Attorney General of Virginia.

That the CFPB has filed a new Complaint against OCWEN on or around April 20, 2017: in the USDC of the Southern
District of Florida West Palm Beach Division Case No. 9:17 –cv- 80495 - CFPB v. OCWEN FINANCIAL
CORPORATION a Florida Corporation , OCWEN MORTGAGE SERVING, INC, a US Virgin Islands corporation AND
OCWEN LOAN SERVICING LLC a Delaware Corporation Page 2 Paragraph 2 States: The bureau brings this action
against the Defendants under: (1)Sections 1031 and 1036 of the CFPA , 12 USC §§ 5531, 5536; (2) Sections 807 (2)(a),

9
Https://www.sec.gov/litigation/admin/2016/34-76938.pdf
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807(10), and 808 of the Fair Debt Collection Practices Act, 15 USC §§ 1692e(2)(a), 1692e(10), and 1692f (the
“FDCPA”); (3) Section 6 and 19 of the Real Estate Settlement Procedures Act (RESPA), 12 USC §§ 2605, 2617, and the
regulations, promulgated thereunder at Regulation X, 12 C.F.R. part 1024 (“Regulation X”); (4) Section 105(a) of the
Truth and Lending Act (“TILA”), 15 USC § 1604(a), and the regulations promulgated thereunder act Regulation Z, 12
C.F.R. part 1026 (“Regulation Z”): and (5) Section 3(b) of Homeowners Protection Act of 1998, 12 USC § 4902(b)(the
“HPA”). PLAINTIFF INCORPORATES THIS COMPLAINT into THIS COMPLAINT that shows the UNCLEAN
HANDS OF OCWEN AND DEFENDANTS TO COVER UP criminal activity.

This Government and this Court is aware of the UNCLEAN hands and have supported the Banks and Servicers
criminal activity ignoring the American Citizen.

The scheme and artifice between the Defendants who intentionally and willfully scheme to defraud Plaintiff, was for the
purpose of using color of law and misuse of the Trustee function, to obtain money, attorney fees, and plaintiffs property
for their own benefit by materially false and fraudulent pretense, representations and promises, by intentionally defrauding
both the Plaintiff and Wells Fargo Bank by collecting on a non-existent loan, which they knew was not collectible, was
written off by the bank, and which they interfered with refinancing to cause harm to Plaintiff and opportunity for
themselves.
Manner and means. During the relevant period, Defendants schemed to foreclose on 15 W. Spring St, Alexandria VA
22301 with knowledge aforethought and despite questions raised in court that there is no valid loan documentation in
existence as required for foreclosure under law. Through deceptive practices foreclosed on March 30, 2018.

The knowing acts and omissions of BWW, MWC, Brock & Scott, Troutman, AG Herring et al show a pattern and
practice of law firms, government enabling and covering up for each other for their own self-profit. The defendants
represent Foreclosure Mills across America – when law firms and trustees operate fraudulently to cause and create
unnecessary foreclosures – as in this case, solely for their own financial gain.

The knowledgeable acts and actions described herein violate Rules of court, federal law, and the United States
Constitution, by denying Plaintiff's/ JWG fundamental right to Due Process and ownership of property. Under a pattern of
‘legal mortgage fraud’ in administration/collection.

Here, so-called lawyer “Trustees” are attorneys who operate as joint lawyers in the same shared office space, who double
dip by churning illegitimate collection, sale, attorney, and trustee fees in violation of Rules of Ethics and self-dealing, by
churning closed and settled collection accounts into their own profit.

Here, the involved lawyers failed to disclose they operate both as collection lawyers, trustee, and foreclosure lawyers,
without disclosure and in violation of fiduciary and ethical duties.

The “ Servicer”, the lawyer and the trustee all worked in collusion to provide false and misleading information to defraud
the Plaintiff.
81
Wire Fraud. The scheme was transmitted by interstate wire communications in writings, emails, telephone calls,
facsimiles all in violation of Section 1343 of Title 18 of the United States Code.

This action’s for appropriate for relief pursuant to the common law, statute and/or Constitution of the United States of
America, for impermissible restraints upon the Plaintiff’s constitutionally protected property, in Violation of the Fair Debt
Collection Practices Act (FDCPA) (15 U.S.C 1692, ET SEQ.), also for Breach of Contract, Honest Service under 18
U.S.C. § 1346 for the Breach of Fiduciary duty to defraud a homebuyer / owner and deprive her of the right to honest
services without fraud.

Pursuant to the Federal Civil False Claims Act, 31 U.S.C. § 3729 et seq.(to preserve the right of the Government to
become a party to the suit as a Relator in the protection of many others) That the Defendants pursued and continue to
pursue foreclosure actions using false and fabricated documents, particularly mortgage assignments to conceal that they
are missing critical documents, namely, the mortgage assignments. Without lawfully executed mortgage assignments, the
value of the mortgages and notes held by the trusts is impaired because effective assignments are necessary for the trust to
foreclose on its assets in the event of mortgage defaults. When the trustee banks discovered that the mortgage assignments
were missing, the trustee banks, together with an associated servicing company, default Management Company and/or
mortgage loan documentation company (OCWEN), devised and operated a scheme and artifice to replace the missing
assignments with fraudulent, fabricated assignments. The purpose of this scheme was to meet the evidentiary requirements
imposed by courts in the foreclosure cases and to conceal from trust shareholders the true, impaired value of the assets of
each of the alleged trusts, crippled by the missing assignments and related documents, creating illegal foreclosure.

That all this was disclosed in 2010 and the bad behavior of the banks is now the bad behavior of the Servicers. The
Servicers have a front door and by all appearance one set of books for the SEC et al and one for the back door of
fraudulent fake mortgages. That past employee stated they were instructed to create “FAKE” assignments that consisted
of “FAKE” bar numbers as the one Spring St. Exhibit 2.

Wells Fargo and Bank of America f/k/a LaSalle Bank presently claim they have no loan (including the loan number
claimed by OCWEN), or any other loan under the name Janice Wolk-Grenadier aka Janice Wolk Grenadier or under her
Social Security number. Wells Fargo stated such to the CFPB. Wells Fargo bank has filed in the City of Alexandria and
Notarize letter stating it has no loan. Exhibit 5

Through the attached documentation, Plaintiff shows the shoddy unlawful and unethical practices of this server, the
attorneys and their representatives, including the nonproduction of any original note documents. Defendants and their
representatives either generated or rely on loan documents that are forged, robo-signed, or reversed-engineered., and in a
manner that is arbitrary and capricious in dealing with the Plaintiff.

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The Fraud carried out by the Defendants in this case includes, inter alia:
● Mortgage assignments with forged signatures of the individuals signing on behalf of the grantors, and forged
signatures of the witnesses and the notaries by all appearance;
● Mortgage assignments with signatures of individuals signing as corporate officers for banks and mortgage
companies that never employed them by all appearance;
● Mortgage assignments prepared on behalf of grantors who had never themselves acquired ownership of the
mortgage and notes by a valid transfer, including assignments where the grantor was identified as “Bogus
Assignee for Intervening Assignments” and
● Mortgage assignments notarized by notaries who never witnessed the signatures that they notarized.
● 1099 to the IRS that the IRS has deemed a Fraud Exhibit 6
● SEC as a stockholder the playing of double accounting to enhance each financial statements by all appearance
● False Advertising the home with the wrong address for Wells Fargo Bank and claiming Wells Fargo Bank was
the owner of the home on HudForeclosed. Stated contact Wells Fargo Bank at 800 S Broad St. Meriden,
CT 6450 Tel 860-368-3400 or 860-368-3400 all Fraudulent Nos. The principle a California Lawyer not
practicing stated the information came from the Bank. the Bank denies any knowledge of such a listing
especially since they don’t own such home. On around May / June of 2020
● Troutman Pepper Hamiltons Sanders lawyer S. Mohsin Reza requested I do a “SHORT SALE” after the home
was foreclosed with his partner Micheal Marteniz. Mr. Reza even gave him my daughter's phone number to
harass her.
● Troutman Pepper Hamiltons Sanders lawyer S. Mohsin Reza interfered with the answers that Wells Fargo Bank
supplied to the CFPB
● Troutman Pepper Hamiltons Sanders lawyer S. Mohsin Reza did the accounting I requested and never got from
OCWEN it is not readable and does not make note of monies sent to the company
● Troutman Pepper Hamiltons Sanders lawyer S. Mohsin Reza lied in the City of Alexandria Circuit Court when he
stated Wells Fargo Bank owned this loan. Or Wells Fargo Bank is lying.

There is nowhere for a homeowner to go for “REAL HELP”. The appearance and the facts show the Government and the
courts have disenfranchised homeowners of all rights.

BANKS, SERVICERS and LAWYERS

WELLS FARGO NATIONAL ASSOCIATION, as Trustee for Option One Mortgage Loan Trust 2005-2, Asset- Backed
Certificates, Series 2005-2 Has stated clearly and has filed in the court they have no information regarding any loan.
They further researched it in Mers which shows no documentation under JWG SS#, address or name.

CEO Charles W. Scharf WELLS FARGO N.A., has the responsibility of Wells Fargo to ensure integrity and to protect
the name of Wells Fargo N. A. et al That “FAKE”
83
BANK OF AMERICA, f/k/a - as successor-in-interest to LaSALLE BANK, State no knowledge of such loan, yet
documents filed against home and letter through BWW Law Group appears that the alleged loan was in the National
Foreclosure Settlement

OCWEN LOAN SERVICING LLC aka PHH aka OCWEN MORTGAGE SERVICING, INC. aka Ocwen Financial
Corporation, NMLS#: 1849337 Ocwen USVI Services, LLC, NMLS#: 2726 PHH Mortgage CorporationForeclosed on
or around March 30, 2018 stated Wells Fargo Bank is the owner of such loan in court - in phone calls. Stated to Broke
and Scott not to Foreclose. Has never provided accounting that was readable. That moved such loan to NewRez LLC in
Plaintiffs Name, SS# and address NewRez around September of 2019 after foreclosing on March 30, 2018.

●
OCWEN LOAN SERVICING, LLC, aka PHH a Delaware limited liability company, on December 31, 2012
purchased Homeward Residential Service (f/k/a name changed from American Home Mortgage Servicing Inc
February 17, 2012). American Home Mortgage Servicing Inc was purchased by Option One Mortgage servicing
May 17, 2008) Option One lost their right do to business in December of 2008. Has suites against it all across
America, including a suit by the CFPB in Florida for the same criminal activity against JWG. Foreclosed on or
around March 30, 2018 stated Wells Fargo Bank is the owner of such loan in court - in phone calls. Stated to
Broke and Scott not to Foreclose. Has never provided accounts that were readable. That moved such loan to
NewRez LLC in Plaintiffs Name, SS# and address. OCWEN LOAN SERVICING LLC aka PHH aka OCWEN
MORTGAGE SERVICING, INC. Foreclosed on or around March 30, 2018 stated Wells Fargo Bank is the owner
of such loan in court - in phone calls. Stated to Broke and Scott not to Foreclose. Has never provided accounts
that were readable. That moved such loan to NewRez LLC in Plaintiffs Name, SS# and address.
OCWEN’s Known Issues;

Zimmerman Reed Lawyers https://www.zimmreed.com/case/ocwen-mortgage-errors-illegal-foreclosures/

States:

OCWEN MORTGAGE FORECLOSURES & PAYMENT PROBLEM RealServicing is a proprietary loan servicing platform
Ocwen used to process and apply payments and communicate information to borrowers – and it’s alleged they loaded
inaccurate information into the system resulting in the platform generating scores of errors. Using this inaccurate
information, Ocwen did not accurately account for homeowners payments or the amounts due under the home loans they
serviced, failed to correctly process and provide for required foreclosure mitigation protection to homeowners, failed to
timely and properly respond to homeowners’ requests for information in regards to their loans, and in many instances
wrongfully and improperly instituted foreclosure proceedings against them.

The following include common complaints from homeowners:

● Disputes concerning the amounts due and owing on the loan after a transfer to Ocwen
● Account disputes and inaccuracies provided by Ocwen through its customer website
● Payment application issues
● Escrow accounting issues
● Loan modification process issues, including, issues related to Ocwen’s failure to properly document loan
modification terms
● Wrongful foreclosure (e.g., authority to foreclose, amounts alleged to be due and owing)
● Failure by Ocwen to adequately respond to customer inquiries
● Backdating of homeowner correspondence

MAHANY LAW https://www.mahanyertl.com/2019/ocwen-fraud-investigations/

84
States:

MahanyLaw is investigating Ocwen and hopes to file one or more national class action complaints against the company
within coming weeks.

Specifically, we are investigating the following allegations of wrongdoing:

1. Use of a proprietary software known to trigger unsupported fees and speed foreclosures (REAL Servicing);
2. Knowing use of infirm loan data,
3. Illegal foreclosures,
4. Failure to credit borrowers’ payments,
5. Mismanagement of escrow accounts,
6. Manufactured force-placed insurance,
7. Delayed termination of private mortgage insurance,
8. Charges for additional products without consent,
9. Mishandling accounts for deceased borrowers, and
10. Failure to correct errors identified by the borrower.

We agree. In our opinion, Ocwen has taken fraud and abuse to a new level.

We hoped that Ocwen had finally met its demise in 2015. That year investors sold off their stock in the company causing
the company’s value to plummet. Over one hundred trusts holding $82 billion of mortgages gave Ocwen the boot. Their
reasons?

● Using trust funds to pay off Ocwen’s obligations owed under a regulatory settlement. Instead of paying
what they owe, the trusts say that Ocwen pushed the payments onto them;Gross conflicts of interests.
Ocwen used corporate affiliates such as Altisource and Home Loan Servicing Corporation to further enrich
itself and hurt borrowers and the trusts;
● Failing to comply with foreclosure and consumer protection laws;
● Engaging in illegal and improper loan modification and advance recovery practices;
● Improper records practices;
● Failing to properly communicate with borrowers; and
● Failing to properly pay the trusts.

In other words, it isn’t just homeowners who claimed they were the victims of Ocwen fraud. It is the investors who own the
loans too.

NEW RESIDENTIAL INVESTMENTS CORP Traded on the Stock Market as NRZ. NewRez LLC is a subsidiary

MICHAEL NIERENBERG Chairman of the Board, Chief Executive Officer & President at New Residential
Investment Corp. Formerly Chairman of the Board, Chief Executive Officer & President / Bank of America Corp.
Former Global Head of Mortgages & Securitized Products, Fortress Investment Group LLC
Former Managing Director

NewRez LLC As of on or around August 26, 2019 Servicer for Loan No. 7143312465 a loan created by OCWEN
Fraudulently for Janice Wolk Grenadier without her permission done with a lost Assignment with a Att BarCode
belonging to Judge Donald Alexandra of Tallahassee Florida.

BARON SILVERSTEIN President of NewRez LLC

BRUCE JOHN WILLIAMS CEO NewRez LLC

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KEVIN HARRIGAN Past President; CEO NewRez LLC

How They Connect:

NAME NOW HISTORY

Charles W. Scharf 2019 CEO & President Wells 2017 - 2019 The Bank of New York Mellon Corp
Fargo Bank Chairman & CEO
2012 - 2016 Visa Inc
2004 - 2011 JPMorgan Chase & Co CEO
2000 - 2004 Bank One Corp CFO
One Equity Partners LLC
1999 - 2000 Citigroup Inc CFO Global Corporate &
Investment Bank Division
1995 - 1999 Salomon Smith Barney, Inc CFO
Primerica, Inc
Commercial Credit Corp

Brian Thomas CEO /President Bank of America
Moynihan US Trust, Bank of America Private
Wealth Management Chairman &
CEO
Bank of America Private Bank
President
2008 Merrill Lynch & Co. CEO
2008 - 2009 QuaiSec
-2014 US Trust Co., N.A. Director & President
1993 - 2004 FleetBoston Financial Corp Deputy General
Counsel, Executive VP
Countrywide Bank President Global Corporate
FIA Card Services President
Edwards & Angell LLP Professional
Bank of America London Branch President & CEO
LaSalle Bank Midwest NA President
Bank of America NA Troonto Branch Director &
President Global Wealth

Glenn A. Messina CEO OCWEN/PHH 2011 PHH Corp. President / CEO / Consultant & COO
Megallen Advisors LLC Principal 2002 - 2011 General Electric Company CEO / CFO

1996 - 1998 GE Capital Mortgage Services, Inc CFO

MICHAEL New Residential Investment Corp 2013 Fortess Investment Group LLC Managing Director
NIERENBERG 2013 Bank of America Corp Global Head of Mortgages
& Securitized Products
2008 - Merrill Lynch MD & Head-Global Mortgages &
Securitized Products
2006 - 2008 Bear Stearns & Co Inc. Director

Baron Silverstein 2020 President of NewRez LLC 2008 Merrill Lynch Managing Director, Global
Mortgages & Securitized Products Group
2008 JPMorgan Chase & Co Co-Head, US RMBS
Mortgage Finance Department
2008 Bear Stearns & Co., Inc

Bruce John Williams 2020 CEO NewRez LLC C- Bass Investment Management LLC Co-Chief
1996 - Current Credit-Based Asset Executive Officer
Servicing & Securitization LLC Shellpoint Partners LLC Co- CEO & Director

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 CEO 2016 Shellpoint Advisors LLC Co-CEO
1995 - 1996 Citicorp Securities Managing Director

Kevin Harrigan Member, Executive Management of 2013 NewRez LLC President, CEO
NewRez LLC

TROUTMAN PEPPER HAMILTON SANDERS AKA TROUTMAN SANDERS aka Mays & Valentine Represents
OCWEN and in past created a FRAUD ON THE COURT in representing Wells Fargo and claiming Wells Fargo Bank
owned a loan in the name of Janice Wolk Grenadier which Wells Fargo has denied to JWG and the CFPB. That this law
firm “Swindled” $30,000 in a Cover Up of monies stolen through a trust account and the worked in collusion to cover up
with Divorce Lawyer Ilona Grenadier Heckman and Ben DiMuro her lawyer. Involved in the theft of Trust Accounts with
Divorce Lawyer ilona Grenadier Heckman colluding to insure no justice for Janice Wolk Grenadier

S. Mohsin Reza TROUTMAN PEPPER HAMILTON SANDERS Lawyer who with his apparent Agent Micheal
Martinez after a foreclosure with a home that is not in her name colludes for a short sale. Lied in Court in the City of
Alexandria. Has unclean hands has violated the Professional Code of Ethics 3.3 Candor of with the court, 8.0 – 8.5
Responsibility to report the criminal activity of Judges and other lawyers. Mr. Reza has colluded and conspired with
others to harm Plaintiff. He is guilty of USC § 4 Misprision of a Felony with his e-mail where he conspires with other
lawyers. Lawyer who with his apparent Agent Micheal Martinez after a foreclosure with a home that is not in her name
colludes for a short sale.

Judge Donald R Alexander Lawyer whom Att BarCode is on the “FAKE” Lost Assignment. Through the Judicial
Canons he has and had an obligation to report the crime to the appropriate authorities.

Trustee Services Of Virginia, LLC. - Filed for a False and illegal Foreclosure knowingly with collusion of Troutman
Sanders and Brock & Scott by all appearance

Brock & Scott, PLLC Law firm oversight for Trustee Service of Virginia LLC. Had knowledge Wells Fargo N.A. had
no knowledge of such loan as stated by documents filed in the court.

Brian Campbell Lawyer Brock & Scott, PLLC Had knowledge Wells Fargo N.A. had no knowledge of such loan as
stated by documents filed in the court.

BWW Law Group aka BIERMAN, GEESING, WARD & Wood, LLC. Had knowledge Wells Fargo N.A. had no
knowledge of such loan as stated by documents filed in the court. Sent letter that Spring Street was part of National
Foreclosure Settlement through Bank of America

EQUITY TRUSTEES, LLC a subsidiary of BWW Law Group filed documents that it appears Lawyer Howard
Bierman’s name had been forged

Howard Norman Bierman Partner BWW Law Group Equity Trustees, LLC Had knowledge Wells Fargo N.A. had
no knowledge of such loan as stated by documents filed in the court. Sent letter that Spring Street was part of National
Foreclosure Settlement through Bank of America. Appears to have with knowledge allowed documents filed against
Spring St. to be foreclosed forged with his name.

McCabe Weisberg Conway LLC aka Surety Trustees LLC Knowing tried to foreclose illegally on Spring St. aka
McCabe Weisberg Conway LLC appears to be hired by OCWEN and only OCWEN even though they falsely advertised
home for sale by Wells Fargo Bank who Wells Fargo CEO office claimed/stated that no loan existed at Wells Fargo Bank,
in a taped phone call on August 11, 2017 (taped by both sides). Knowingly tried to foreclose illegally on Spring St.
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Surety Trustees LLC aka McCabe Weisberg Conway LLC knowingly tried to foreclose illegally on Spring St. which
shares office space with lawyers MCC and which is owned by lawyers of MCC - with the City of Alexandria. They
purport to be the “substitute Trustee” for a Note they refuse to produce regarding 15 West Spring Street, Alexandria, VA.
They ignored JWG requests to produce the original note and other documentation, in violation of State and Federal Law.
Knowingly tried to foreclose illegally on Spring St

Abby Moynihan McCabe Weisberg Conway LLC aka Surety Trustees LLC Knowingly tried to foreclose illegally
on Spring St.

AG Mark Herring Attorney General's Office has an obligation under the law to protect citizens from Foreclosure
Schemes and Scams and instead his office has refused all meetings.

The shoddy unlawful and unethical behavior from these banks, attorneys, agents, employees, and representatives, all who
willfully refused to produce the note because the alleged documents they rely upon for their actions are forged,
robo-signed, or reversed engineered.

BACKGROUND AFTER FORECLOSURE On MARCH 31, 2018

Complainant is entitled to the relief for the following reasons:

1. That Plaintiff can show that the Defendant Wells Fargo Bank N. A. had no standing to foreclose and OCWEN
using Identity Theft, Money Laundering, Insurance Fraud and many other criminal acts foreclosed on 15 W.
Spring St., Alexandria, VA 22301
2. That you can hear OCWEN telling Brock & Scott not to Foreclose on Spring St. @ Brock and Scott / OCWEN
conversation March 2019 Admits OCWEN had told them to not Foreclose conv starts at about 6 min and 40
sec https://www.youtube.com/watch?v=00gWnLp11vI&t=1127s

3. That you can then see the Foreclosure taped: The Foreclosure by Wells Fargo NOT OCWEN a total SCAM
March 2018 https://www.youtube.com/watch?v=82tllotwvW0
4. The Deed attached shows the property in the name of Wells Fargo N.A. et al with an odd caveat for OCWEN.
5. That Troutman Sanders then approached JWG on or around April 4, 2019 Troutman Sanders Lawyer S. Moshin
Reza asking JWG to do a short sale on a home that had been foreclosed. That Micheal Martinez appears to be an
agent of Troutman Sanders whose investors in the Foreclosure properties are located in Florida and New Jersey.
Further Mr. Martinez stated “Wells Fargo will is easy to deal with and will do almost anything we want”
paraphrase.
6. That in or around November of 2018 both Bank of America and Wells Fargo Bank responded to subpoenas that
neither had any documentation to being a party to a loan on 15 W. Spring Street, Alexandria, VA 22301 Exhibit
7. That on or around August 8, 2019 Wells Fargo Bank did a notarized document that they had no documentation.
Exhibit
8. That OCWEN the loan servicer did a fraudulent 1099 to the IRS that is under investigation. Exhibit

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 9. That PHH on or around August 26, 2019 Sent Letter stating Loan Servicing Moved to NewRezLLC.
NewRez LLC was created by PHH in or around 2008 and sold prior to PHH moving to OCWEN in
2018 to New Ressidential Investment Corp traded as NRZ. Investors can be seen Exhibit
10. According to insiders of OCWEN: OCWEN is going out of business or into Bankruptcy and is moving
any and all assets. The top 10 investors by CNN on or around Jan 30, 2020 of Wells Fargo Bank,
Bank of America, OCWEN and New Residential Investment Corp.
11. On January 5, 2020 in Wells Fargo’s research they looked towards Mers to show the loan history - they
did not believe me at first this alleged loan is nowhere to be found in Mers (even though they have filed
documents against the home putting it in a Mtg Back Sec that it did not meet the criteria), FNMA,
Freddie Mac, my personal credit report since around 2012 show no none ownership of any loan. Exhibit
#
12. The CFPB / JWG have requested documentation that shows OCWEN / Wells Fargo Bank / Bank of
America to give some type of document and all have been denied. The documents provided have had no
substance.
13. On or around April 29, 2019 10 a motion and a letter to the COA Clerk of Court of the Fraud was filed in
this court with the Clerk of Court Clerk. Hon. Edward Semonian Jr., City of Alexandria Circuit Court - 510
King Street 3rd Floor, Alexandria, VA 22314 ed.semonian@alexandriava.gov (703) 746-4044

RE: DEMAND to remove the “ILLEGAL, FRAUDULENT FILING” TO MISLEAD on the ownership of a alleged loan
on 15 W. Spring St., Alexandria, VA 22301

The law is clear and included in this letter that three (3) assignments were filed illegally against 15 W. Spring Street,
Alexandria, VA 22301 due to not being prepared properly by a lawyer, but by a lay person acting as a lawyer and using
another's Florida State Bar No. This includes the VA Code that rules the Clerk's Office, as well as stated in the Virginia
State Bars code of Professional Conduct for Practicing Law without a license.

HISTORY OF FRAUDULENT DOCUMENTS AGAINST SPRING ST

1. Filed on or around February 4, 2009 against 15 W. Spring Street, Alexandria, VA 22301 Document No.
190003603 000551 000075 “Notice of Assignment of Deed of Trust” Virginia fraud on the court with the
basics of Virginia fraud claim requires proof of:

(1) a false representation, that the loan went to a Mtg Back Security that was closed prior to the loan being created
(2) of a present, material fact, the Assignment was done by a non-lawyer Rob Meharg
(3) made intentionally and knowingly, That Docx person Lorraine Brown went to jail for the “Black Market”
Back Door loans
(4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in or around
December of 2012

10
The full letter can be found attached in the 1st Amended Complaint Exhibit 2 pages 4 - 9
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 (5) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the Mtg Back
Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4, 2005
(6) resulting damage. Illegal Foreclosure on March 30, 2019

2. Filed on or around June 18, 2009 against 15 W. Spring Street, Alexandria, VA 22301 Document NO.
090012907 000253 000076 “Notice of Assignment of Deed of Trust” Virginia fraud on the court with the
basics of Virginia fraud claim requires proof of:

(1) a false representation, that the loan went to a Mtg Back Security that was closed prior to the loan being created
(2) of a present, material fact, the Assignment was done by a non-lawyer Rob Meharg
(3) made intentionally and knowingly, That Docx person Lorraine Brown went to jail for the “Black Market”
Back Door Mortgage Back Securities for the “Back Room” for financial gains of Banks and Servicers
(4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in or around
December of 2012
(5) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the Mtg Back
Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4, 2005
(6) resulting damage. Illegal Foreclosure on March 30, 2019

3. Filed on or around April 22, 2013 against 15 W. Spring Street, Alexandria, VA 22301 Document No.
130014851 000586, 000587 000071 “Affidavit of Lost Assignment” Virginia fraud on the court with the
basics of Virginia fraud claim requires proof of:

Sister Nora Nash states: OCWEN and Altisource, through a systematically designed process, induce foreclosures and
then sell these foreclosed homes on HUBZU.com so they can earn listing commissions, Buyer's Premium, Escrow
Fees, Web Technology Fee, Property Preservation Fees, Title Insurance Fees, Closing Coordination Fees and more!

(1) a false representation, After BWW Law Group failed at foreclosure and questions asked, and evidence of the
fraud presented to Servicer and Lawyers they created by a non-lawyer a “Affidavit of Lost Assignment” using a
Judge Donald Alexander in Florida Bar number
(2) of a present, material fact, That Wells Fargo Bank in phone calls and written to CRPB and this court no
ownership or any involvement in any loan with 15 W. Spring St. Alexandria, VA 22301
(3) made intentionally and knowingly, the Facts are clear JWG had disclosed to Howard Bierman of BWW Law
Group the Fraud
(4) with intent to mislead, The filing with the Commissioner, and the foreclosure itself showed OCWEN et al
believe they are above the law as long as there is financial gain for lawyers
(5) reasonable reliance by the party misled, and The foreclosure on March 30, 2018

April 4, 2019 at Prince Georges MD - Courthouse Mohsin Reza of

Troutman Sanders asks JWG “Are you interested in a short sale” JWG
stated clearly “NO” and then asked by Mr. Reza “if I had gotten a recent call
about selling the home” you will notice this TEXT sent March 23, 2019.
Michael as he states has contacted me in the past and even had been given my
daughters phone number in the past. The Question Becomes: “BLACK
MARKET” by lawyers and WHO ELSE harassing and forcing short sales
on illegal foreclosures

March 29, 2018 Phone call between OCWEN, Janice Wolk Grenadier and
Brock & Scott aka Trustee Services Of Virginia, LLC., where OCWEN
informs Brock & Scott and Brock & Scott acknowledge that on or around
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March 22, 2018 they had received notice from OCWEN not to foreclose. They then received from the Investor that no matter what
they were to foreclose - ignoring whatever OCWEN said. https://www.youtube.com/watch?v=00gWnLp11vI&t=562s

On March 30, 2018 OCWEN Loan Servicing held an illegal foreclosure on 15 W. Spring St., Alexandria VA 22301. The property
owner then and legally still today is Janice Wolk Grenadier. Video March 30, 2018 The foreclosure
https://www.youtube.com/watch?v=82tllotwvW0

On or around April 6, 2018 a Trustee Deed was filed on the property that Wells Fargo Bank National Association, as Trustee for
Option One Mortgage Loan Trust 2005-2, Asset Backed Certificates, Series 2005-2 Trustee for Option One (Mtg Back Security does
not exist) see attached

On or around December 8, 2018 Wells Fargo Bank N. A. would file in the courthouse of the City of Alexandria in response to a
Subpoena by JWG that they had no interest in this foreclosure or this home - see attached

On or around February 3, 2019 Janice received from OCWEN a Fraudulent 1099-A Acquisition or Abandonment of Secured
Property Information Returns that stated they “OCWEN” not Servicing, not LLC only OCWEN is / was the lender on the loan
(OCWEN on its own does not exist as an entity). The IRS has deemed this 1099 from evidence presented to be “FRAUDULENT”
and has told Janice Wolk Grenadier to ignore such 1099 while Criminal Investigation is starting. See attached - It should be noted
Janice Wolk Grenadier is still in home.

OCWEN Entities found: Ocwen Loan Servicing, which is licensed to service mortgages in the state, used unlicensed affiliate
offshore companies to “perform activities considered residential mortgage loan servicing.” Ocwen Financial Solutions Private
Limited, operating out of a location in India, and Ocwen Business Solutions, operating out of a location in the Philippines, to
conduct “servicing” activities on residential mortgage loans. VA SCC states OCWEN is Licensed as:

F1991993 OCWEN BUSINESS SOLUTIONS, INC. Foreign Corporation Active

F1995820 OCWEN FINANCIAL INSURANCE SERVICES, INC. Foreign Corporation Active

F1564386 OCWEN FINANCIAL SOLUTIONS PRIVATE LIMITED Foreign Corporation Active

T0206161 OCWEN LOAN SERVICING, LLC Foreign Limited Liability Company Active

OCWEN filed a 1099-A Acquisition or Abandonment of Secured Property with the IRS where Ocwen was not a secured
creditor.

Ocwen Financial Corporation is a provider of residential and commercial mortgage loan servicing, special servicing, and
asset management services, which has been described as "essentially debt collectors, collecting monthly principal and
interest from homeowners". Ocwen is headquartered in West Palm Beach,

Florida, with additional offices in Addison, Texas, Orlando, Florida, Houston, Texas, Rancho Cordova, California, St.
Croix, U.S. Virgin Islands, and Washington, D.C. It also has support operations in the Philippines and India.

Ocwen under 26 U.S.C. § 7434 willfully filed fraudulent 1099 information returns with the IRS 26 U.S.C. § 7434. Civil
damages for fraudulent filing of information returns11. That OCWEN never lent any money to Janice Wolk Grenadier thus
11
26 USC § 7434. Civil damages for fraudulent filing of information returns(a) In general If any person willfully files a fraudulent information return with respect
to payments purported to be made to any other person, such other person may bring a civil action for damages against the person so filing such return.(b) Damages In
any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to the plaintiff in an amount equal to the
greater of $5,000 or the sum of—(1) any actual damages sustained by the plaintiff as a proximate result of the filing of the fraudulent information return (including any
costs attributable to resolving deficiencies asserted as a result of such filing),(2) the costs of the action, and(3) in the court’s discretion, reasonable attorneys’ fees.(c)
Period for bringing action Notwithstanding any other provision of law, an action to enforce the liability created under this section may be brought without regard to
the amount in controversy and may be brought only within the later of—(1) 6 years after the date of the filing of the fraudulent information return, or(2) 1 year after the
date such fraudulent information return would have been discovered by exercise of reasonable care.(d) Copy of complaint filed with IRS Any person bringing an
action under subsection (a) shall provide a copy of the complaint to the Internal Revenue Service upon the filing of such complaint with the court.(e) Finding of court
to include correct amount of payment The decision of the court awarding damages in an action brought under subsection (a) shall include a finding of the correct
91
suffered no financial loss and was not a secured creditor under any state property laws. That the Trustee Deed and
OCWEN acting as the Servicer at all times stated clearly that Wells Fargo Bank was the lender and or Wells Fargo Bank
National Association, as Trustee for Option One Mortgage Loan Trust 2005-2, Asset Backed Certificates, Series 2005-2
Trustee for Option One (Mtg Back Security does not exist) see attached.

Banks: All Banks state in writing to Janice Wolk Grenadier and the CFPB they have no knowledge, no information and
no involvement in or on a loan against Janice Wolk Grenadier and or 15 W. Spring St., Alexandria VA 22301

● Bank of America aka LaSalle Bank

● Wells Fargo

That on or around April 3, 2019 Wells Fargo Bank N. A. made it clear they are cooperating and most likely working with
OCWEN and supporting the “Black Market” Mortgage Back Securities and the “FRAUD”

(6) resulting damage. The foreclosure on March 30, 2019 was and is Common law theories of negligence, gross
negligence, payment by mistake, unjust enrichment, money had and received, breach of fiduciary duty, breach of
contract, misrepresentation, deceit, fraud, and aiding and abetting, Retaliation and Retribution, RICO &
Racketeering, the cruelty of the acts and actions are and where willful acts were malicious, violent, oppressive,
fraudulent, wanton or grossly reckless, any of the foregoing all acts and actions have been knowledgeable
by lawyers, banks and Servicers et al ;

The VSB: https://www.vsb.org/pro-guidelines/index.php/unauthorized-practice-rules/rule-6/

Violating Unauthorized Practice of Law Rule 6 Real Estate Practice 6-1010 (B) (C),UPR 6-102 (A), UPR 6-103 (A)
(B) UPR 6-106 UPC 6-1 UPC 6-2 UPC 6-4 UPC 6-8

I asked for a response prior to May 1, 2019 due to a court hearing on May 6, 2019 in regard to the Commissioners Case
CASE NO. CW 1800 1465 where I have filed a Motion for the Judge to remove the Assignments and I would
appreciate your support of such actions. I WAS IGNORED.

1. That in May June of 2020 the home was listed for Sale the home with the wrong address for Wells Fargo Bank
and claiming Wells Fargo Bank was the owner of the home on HudForeclosed. Stated contact Wells Fargo Bank
at 800 S Broad St. Meriden, CT 6450 Tel 860-368-3400 or 860-368-3400 all Fraudulent Nos. The principle a
California Lawyer not practicing stated the information came from the Bank. the Bank denies any knowledge of
such a listing especially since they don’t own such a home. On around May / June of 2020
2. To harass and try to embarrass Plaintiff the beginning of May 2020 this MeMe was put on the internet - This is the
pattern and practice to just keep throwing things at one person to see if you can break them and shut them up? Or
maybe your goal and this “GANG” is hoping I will commit suicide. I will not. Or maybe you think I will
become afraid of you - You can go to my blog VALaw2010.blogspot.com or to the new website I have founded
JudicialPedia.com to see I am not running. I am Standing Up and Speaking Out against the corruption

amount which should have been reported in the information return.(f) Information return For purposes of this section, the term “information return” means any
statement described in section 6724(d)(1)(A).(Added Pub. L. 104-168, title VI, § 601(a), July 30, 1996, 110 Stat. 1462; amended Pub. L. 105-206, title VI, § 6023(29),
July 22, 1998, 112 Stat. 826.) A prior section 7434 was renumbered 7437 of this title. 1998—Subsec. (b)(3). Pub. L. 105-206 substituted “attorneys’ fees” for “attorneys
fees”. Pub. L. 104-168, title VI, § 601(c), July 30, 1996, 110 Stat. 1462, provided that: “The amendments made by this section [enacting this section and renumbering
former section 7434 as 7435 of this title] shall apply to fraudulent information returns filed after the date of the enactment of this Act [July 30, 1996].”
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 BACKGROUND PRIOR TO FORECLOSURE

Plaintiff incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

On February 4, 2005 JWG took out an alleged loan from Mortgage and Equity Funding Corporation. The alleged loan in
question went immediately to Option One Mortgage Corporation for servicing.

Option One was purchased by American Home Mortgage Servicing Inc. on or around May 9 17, 2008
American Home Mortgage Servicing Inc. was purchased by Homeward Residential on or around February 17, 2012.

Homeward Residential transferred to OCWEN and Plaintiff’s alleged loan was transferred Tuesday February 19, 2013
(the day prior Monday February 18, 2013 was a Federal Holiday for Presidents day with the Banking industry closed.)
On or around December 18, 2012 BWW-Law Group sent Plaintiff a letter stating that Bank of America owned her loan.
BWW-Law was sending the letter under an obligation under Section IV.D.6 of the National Mortgage Settlement, which
Wells Fargo was not a party to.

Robo-Signers. On or around December 28 of 2012 Bank of America representatives denied ever owning such a loan.
Bank of America purchased LaSalle Bank October 1, 2007. February 24, 2009 and February June 18, 2009 Bank of
America f/k/a LaSalle Bank filing - Notice of Assignment of Deed of Trust using nationally known Robo-signers Linda
Green (VP) [Ex 5], Tywannia Thomas ( Asst. VP ), and Korell Harp (VP). Exhibit 2 is both Assignments

Linda Green. It was proven in the USA and Lynn E. Szymoniak vs. American Home Mtg et al that Linda Green was not
employed by American Home Serving, Inc. and did not have any authority to sign.

Tywannia Thomas. She did not sign all of the documents that her name is affixed on the DOCX – prepared assignments.
The use of several different corporate titles exists.
93
Korell Harp. Also did not sign all the documents to which his name is affixed.

Affixing or submitting false signatures on a mortgage document is a violation of federal and state law, and those
signatures are without authority to complete the transaction. According to a mortgage fraud notice prepared jointly by the
Federal Bureau of Investigation and the Mortgage Bankers Association, submitting false mortgage assignments and
forging signatures violates potentially eight federal criminal statutes. Specifically: (1) 18 U.S.C. §1001 – Statements or
entries generally; (2) 18 U.S.C. § 1010 - HUD and Federal Housing Administration transactions; (3) 18 U.S.C. § 1014 –
Loan and credit applications generally; (4) 18 U.S.C. § 1028 – Fraud and related activity in connection with identification
documents; (5) 18 U.S.C. § 1341 – Frauds and swindles by mail; (6) 18 U.S.C. § 1342 – Fictitious name or address; (7) 18
U.S.C. § 1343 – Fraud by wire; and (8) 18 U.S.C. § 1344 10 – Bank Fraud. See FBI Mortgage Fraud Notice (available at
http://www.mbaa.org/FBIMortgageFraudWarning.htm); see, also, Truth in Lending Act, title 1 of the Consumer Credit
Protection Act, as amended 15 U.S.C. § 1601 et seq. ; Mortgage Fraud.

False or fraudulent notary acknowledgements are also a violation.

The signatures contained on the assignments filed in Foreclosure are fraudulent, in violation of Federal and Virginia law,
and therefore they do not serve to assign the note and mortgage properly, they lack the essential authority for Defendants
to act on note and mortgage and Defendants cannot foreclose.

The practice of fraudulent mortgage assignments is widespread across the United States. Defendants have the knowledge
of the serious problems of their fraudulent actions to cover up / conceal this problem. That nothing has changed since
2010.

Defendants Use of Fake Documents, False Officer Titles and Forged Signatures violates Federal Lending Law, State
Mortgage Fraud law and Notary Fraud law.

Title. On or around December 28 / 31, 2012 JWG called BWWLaw Group and asked who owned the loan on 15 W.
Spring Street? According to a letter on December 18, 2012, the owner was Bank of America –but Bank of America denied
such ownership. BWWLaw group referred Plaintiff back to the Homeward Residential that BWW Law Group had no
knowledge who owned the loan.

Plaintiff / JWG was in the process of applying for the Government Independent Foreclosure Review and learned about the
possibility of this break in the chain of title.

The HAMP Program. In 2008 and thereafter, Plaintiff Homeward on a Deed Mortification thru the programs offered by
Congress. The Servicers reaped excessive false rewards for losing/processing refinance documents because of a flaw in a
financial incentive for servicers document handling, motivating Servicers to delay, loose paperwork etc. Servicers of loans
such as the Plaintiffs, received money per application /and document/ but not per person, creating a reward for negligent
and fraudulent corporate/organizational bad behaviors that deprived or deterred homeowner refinancing, such as occurred
here.

Improper interference with Plaintiff's HAMP Application. On or around January 28, 2013, Homeward Mortgage sent
Plaintiff a Notice of Servicing Transfer (RESPA) and Welcome to OCWEN Loan Servicing, LLC [ Ex 8 ]

Homeward Mortgage servicing was the servicer of Plaintiff loan till February 18, 2013. February 19, 2013 OCWEN
became the servicer. Homeward Mortgage supervisor had advised Plaintiff on three different occasions that all documents
were in place for the HAMP Modification. Homeward then kept coming back with issues that Plaintiff had been told by
94
Homeward that they were cleared up. Homeward supervisor had left Plaintiff a message that the foreclosure of her home
had been stayed.

February 19, 2013 Plaintiff phoned OCWEN to confirm that there had not been any issue that the foreclosure had been
stayed as the BWW Law Group still showed it active on BWW Law website. OCWEN informed Plaintiff she would need
to re-submit documents for the HAMP Program – but to “ignore the foreclosure date because a “foreclosure sale cannot be
conducted” until after the evaluation of the HAMP program is complete and a borrower found ineligible. As long as
Plaintiff was being considered for the HAMP the foreclosure could not go forward” Plaintiff went over this statement
three times with the agent at OCWEN. OCWEN could not have been more helpful and was reassuring about the
foreclosure not going ahead. The phone conversation was close to an hour going over everything.

February 20, 2013 Plaintiff phoned OCWEN again and went through the fact the foreclosure was still on the website
schedule of BWWLaw Group, and would OCWEN please contact BWWLaw? OCWEN again reassured Plaintiff they
could not foreclose as the process had begun with OCWEN and it was illegal to foreclose.

February 20, 2013 Plaintiff sent emails to BWW Law Group after being unable to reach BWWLaw group on the phone
about the pending foreclosure. BWWLaw Group informed Plaintiff that the alleged owner of the loan (Equity Trustees)
had made the decision and planned to move forward to foreclose on Plaintiff's property. In December 2012 (two months
earlier) BWWLaw Group had no idea who owned Plaintiff’s loan or who had the original note.

Plaintiff continued to try to contact BWWLaw Group through phone calls and emails. through the end of business
February 20, 2013.

She made phone calls to OCWEN and supervisors at OCWEN, who were at a loss as to how to help Plaintiff. OCWEN
claimed to have never seen a situation like this. OCWEN kept informing Plaintiff that BWW Law group could not
foreclose prior to or on April 17, 2013 and only thereafter if Plaintiffs’ documents had not been received by OCWEN.
Phone calls are taped

With no other recourse, and based on BWWLaw Group bad faith, Plaintiff was forced to file involuntary Bankruptcy
February 21, 2013 to protect her interest in the property. Video available

On February 21, 2013 Plaintiff/ JWG could not get through to a voice-mail or anyone at BWWLaw group, which at
times blocked Plaintiffs calls and emails. Plaintiff took a copy of the receipt for the bankruptcy to the address of the
alleged “owner” of the loan (according to lBWWLaw Group – was “Equity Trustees” with an address of 2020 14th Street
N., Suite 250 Arlington Va 22201. Plaintiff delivered the bankruptcy receipt in person, because on the website for
BWWLaw, showed only addresses in Richmond, VA and Bethesda, Md.

February 21, 2013. Plaintiff / JWG was shocked to discover that BWW Law group and Equity Trustees LLC ``shared”
the same office! The actions of BWW Law (by refusing to turn over a copy of Plaintiff’s original note and other
information) but/while concealing that they ‘sharing’ offices with the foreclosure trustee, indicates egregious self-interest
and malicious intent to defraud Plaintiff. Here, they actively (by omission and affirmative acts) intentionally interfered and
violated Plaintiffs rights to participate and reap the rewards of the Government backed HAMP program, by actively
setting her up for foreclosure in violation of law.. These Actions of Equity Trustees LLC, BWWLaw Group and other
defendants were and are willful acts that are self-interest, malicious, violent, oppressive, fraudulent, wanton, and grossly
reckless in light of the fiduciary nature of the law/firm/trustee duties.

On February 22, 2013 Plaintiff e-mailed Allison Melton, an associate at BWW Law requesting a copy of the Spring
Street original note, and Allison (an associate with BWW Law Group) denied her request
95
On March 1, 2013 Plaintiff returned to the offices of BWW- Law Group and Equity Trustees, LLC to hand deliver a
“qualified written request” under the Federal Servicer Act, which is a part of the Real Estate Settlement Procedures Act,
12 U.S.C. 2605 (e). Requesting by law the information Plaintiff had been denied by Defendants.

The letter at page 4, reminds Equity Trustees of the mandatory duty to acknowledge receipt of this qualified written
request within 20 business days, pursuant to 12 U.S.C. Section 2605 (e) (1)(A) and Reg. X Section 2500.21 (e)(1). Equity
Trustees LLC “shares” offices with BWWLaw Group, and is owned by lawyers, who are expected to be cognizant of the
federal and state laws regarding their “specialty.” Here self-interest and greed seem to 13 have motivated the law
firm/lawyers to violate federal law/rights and fiduciary duties owed to the Plaintiff because they controlled the documents
and intentionally kept them from the Plaintiff.

Plaintiff is an Entrepreneur and as a result of Defendant’s improper interference she lost funding because BWW Law
advertised her home for foreclosure February 7, 2013. Plaintiff worked diligently with Homeward and OCWENt o prevent
foreclosure and by filing for Bankruptcy.

BWW-Law group f/k/a Bierman, Geesing, Ward & Wood, LLC acted in its own best interest by putting it’s own best
interests and that of the other lawyers, before the best interest of the Plaintiff.

Robo-Signers. Jacob Geesing is a partner of BWW Law Group and since October 13, 2010 is publicly known as “The
Robo Trustee.”

Attorney Howard N. Bierman, also of BWW Law Group is also publicly known as a Robo Signer includes in 4
different signatures on Plaintiffs forged documents by the BWW Law Group.

Documents filed against 15 W. Spring St. by BWWLaw Group Deed of Appointment of substitute Trustee June 2, 2006
Deed of appointment of Substitute Trustee prepared by BWW- Law Group on or around March 23, 2012 – but, not signed
by BWW-Law Group – Signed by April King VP reading – Wells Fargo Bank, N.A. as Trustee for Option One Mortgage
Loans Trust 2005-2 Asset Backed Certificates, Series 2005-2 ( Option One Mortgage shuts down and is sold on or around
May 17, 2008 to AHMSI) [Ex 18 ] By: American Home Mortgage Servicing Inc. (AHMSI)

The absence of any valid promissory note( necessary for enforcement on a secured interest), and the recent Wells Fargo
CEO/office representation that there is no bank interest, and that Wells Fargo is not involved in the lawyer
collection/foreclosure/auction process – demonstrate improper Defendant actions on a loan which is no longer enforceable
or supported in law.

BWW-Law Group and Equity Trustees LLC acted in bad faith and apparent self interest when both ignored all
correspondence from Plaintiff.

On or Around May 17, 2012 Plaintiff learned Mark R. Galbraith was representing Wells Fargo. 14

Plaintiff reached out to Mr. Galbraith by phone and e-mail. Mr. Galbraith also refused to answer any questions in regard if
Wells Fargo had the original Note for 15 West Spring Street, Alexandria, Va. 22301.

Other Documents filed in Court-- February 4, 2005 – Deed of Trust – Mortgage Equity Funding Corp July 9, 2007 -
Corporation Assignment of Deed of Trust – Prepared by Option One Mortgage Corp December 18, 2007 – Loan
Mortification Agreement – Option One Mortgage

96
Lawyer overcompensation based on unacceptable and inappropriate practices. It has been well documented in U.S.
Congressional oversight that lawyer practices, such as the lawyer/trustees in this case ( who ignored the Servicing
Companies conversations with this homeowner) – are unethical practices lawyers engage in who are afraid of losing
foreclosure income and assets payable to their law firm - practices involving foreclosure, banks, eviction or closing,
including Robo-signing.

The U.S. House Committee on Oversight and Government Relations, in response to inquiry from Congressman Elijah
Cummings, wrote from theFederal Housing Finance Agency on May 13, 201, a letter which establishes ( as improper
practices) the acquisition of real estate using illegitimate foreclosure practices - a lawyer practice of self-interest, such as
occurred in this case. Page 3 describes as “Attorney Misconduct”, self-dealing and inappropriate practices, which
itemizes the practices in this case as “unacceptable” and shows Forms 104DC submitted to Freddie Mac by the Servicers
that S & B (Shapiro & Burson LLP) were paid to the lawyers - 2009 - $ 3,369,146.14 By – FREDDIE MAC’S
SERVICERS 2010 - $ 6,342,051.30 By - FdREDDIE MAC’S SERVICERS In the First quarter of 2011 - $ 1,746,816.13
By – FREDDIE MAC’S SERVICERS The amounts are not broken out into separate categories for the type of matter
handled, but include payments for services provided for foreclosures, bankruptcies, eviction, and closings in Maryland and
Virginia.

The Question then becomes what is the difference between BWW-Law Group f/k/a BIERMAN, GEESING, WARD &
Wood, LLC and Shapiro & Burson LLP and now McCabe Weisberg and Conway? When you search the Internet for
Maryland and Virginia you see no difference in the criminal activities of both law firms. The answer will come after a
FOIA request for the 104DC will be submitted to Freddie Mac.

On or around Judge James Clark of the City of Alexandria for “Friendship” and other illegal reasons give Divorce lawyer
Ilona Ely Freedman Grenadier the right to foreclose on 15 W. Spring St, Alexandria VA 22301 – This Fraud included the
help of DiMuroGinsberg, Troutman Sanders aka Mays & Valentine (1990 stole $30,000 from plaintiff to help cover up
thefts of lawyer Ilona Grenadier Heckman and James Arthur with false and fraudulent, misleading information) and K

Once again forcing Janice Wolk Grenadier into Bankruptcy.

What this does is show the FORECLOSURE MILLS / LAWYERS collusion to make it a pattern and practice to ensure
the MURDER of and or the homeless of Janice Wolk Grenadier who continues to STAND UP and SPEAK OUT of the
corruption with even illegally jailing her and holding her in solitary confinement for 14 days. October 22, 2014 –
November 12, 2014 – 22 days Janice illegally jailed and tortured in the City of Alexandria, Solitary Confinement till 5pm
on Election day Tuesday, November 4, 2014. Illegally Jailed to:

1. Silence her and stop exposure of e-mails between herself and Mark Warner’s office on the corruption in the
Judiciary. Janice went to Mark Warner for help instead he had her jailed, at the same time it was exposed his “Pay
to Play '' with a Federal Judgeship for a favor. Being ignored by the Senate Ethics Committee.
2. To Bully / scare her into either committing Suicide or to turning the other check of the corruption and not
holding Virginia and the Federal Judiciary, the Government and Elected Officials accountable, as well as the
criminal acts and actions of the Old Boys Network in Virginia That the law is very clear: That Judge Clarks
actions have turned back time. Giving me less rights than 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.

3. That on October 22, 2014 I 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".
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 Furthermore the right by placing me 16 "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. Further: The system is one where
the Lawyers and Judges have set it up to protect each other and line each others pockets with Cash.

That the lack of duty of care, fair dealing and Good Faith when dealing with homeowners as the Big Banks negotiated
their way out of Jail and paid the United States Government $251 Billion Dollars should not be ignored. That the
questions are does the $251 Billion compel improper for influence or favor of the Judiciary? Further that vested by the
Constitution and the Oath of Office taken by the Judiciary, the Government and the Elected Officials are bound by the
unique Oath of Office that they take to “preserve, protect and defend the Constitution of the United States of America”
and ensure Due Process in our courts.

That despite disclaimers and legal arguments, banks can’t walk away from their duty of due care and good faith. That the
documents filed against 15 W. Spring Street, have been forged in conflict with the law to enhance the balance sheet of
Bank of America aka LaSalle Bank, Wells Fargo, Option One and Equity Trustees that this alone should be a concern of
all Judges. That it shows an illegal conversion of loans to enhance the balance sheet, while harming the title of the home at
the same time. A loss that occurred because of their failure to perform those duties is a loss to the bank – not the customer
/ homeowner who knew nothing about the “problem” Hence the arguments of servicers (and the undisclosed principals for
whom they act), banks and trustees of REMIC Trusts and even trustees on deeds of trust and self proclaimed mortgagees
and beneficiaries on deeds of trust should be rejected if the homeowner has alleged, based upon ultimate facts upon which
relief could be granted, that the entity failed to act in good faith and due care.

That the Exhibits filed with this case showed the lack of care taken in legal documents filed against the home.

That since this lawsuit was filed Defendant OCWEN in the original suit have ignored the rules of the Fourth Circuit
Court, and have never filed a response or properly put notice into the Court as to the appearance of the lawyers without
badgering from the court.

The court has an obligation to a pro se “poor person” of care, fair dealing and Good Faith.

That the Banks and Lawyers also had a duty of care, fair dealing and Good Faith.

Troutman Pepper Hamilton Sanders aka Troutman Sanders aka Mays & Valentine swindled with the help of Divorce
Lawyer Ilona Grenadier Heckman $30,000. For monies Divorce Lawyer Ilona admitted in 2008 of stealing out of her law
firm from using a forged Trust Addendum to the Sonia Grenadier Trust (mother of the late Judge Albert Grenadier her 2nd
husband and her third husband Judge Grenadier’s 1 st cousin c. 9 months after his death by all appearance colluded with
her). The Note for the money “borrowed” is still with the Grenadier Starace Duffett & Levi Law firm due after 30 years in
2020. The only copy demanded as my lawyer sits in Ilona’s safe according to Ilona who stated at the time “Let me keep
this for safe keeping” who Janice / Plaintiff was naive and trusted her.

That Wells Fargo and OCWEN lawyers colluded with Divorce Lawyer Ilona Grenadier Heckman in the City of
Alexandria Case No. CL1500 – 3661 to ensure and help Lawyer Ilona deny Plaintiff, all Plaintiff rights and monies owed
to Janice from being divorced without a Property Settlement. The settlement would have resolved this case. That
TroutmanSanders aka Mays & Valentine has a real fright of being held accountable for collusion of the thefts from
Plaintiff / Janice.

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The following e-mail states clearly how Troutman Sanders relationships with Judges are how they ignore the law.

Further Mohsin Reza profile on the Troutman Sanders states he is an expert at: Mohsin Reza’s practice focusing on
representing corporate clients in complex litigation in state and federal courts. Mohsin represents financial institutions in
various commercial, consumer, and lender liability disputes, including lawsuits involving claims brought under the Fair
Credit Reporting Act, the Fair Debt Collection Practices Act, the Equal Credit Opportunity Act, the Truth-in-Lending Act,
the Telephone Consumer Protection Act, the Real Estate Settlement Procedures Act, the Uniform Commercial Code, and
state consumer protection statutes. Mohsin also represents small and large businesses in defending against and asserting
claims of negligence, breach of contract, fraud, civil conspiracy, and business torts. Furthermore, he has experience
representing clients in estate litigation and probate matters.

That Wells Fargo, Option One, Equity Trustees, Bank of America all in one way or another have claimed ownership of a
loan. BWW Law Group, Howard Bierman and several bad actors from McCabe Weisberg & Conway, Michael Weiser
ESQ, DiMuroGinsberg, Parker Simon & Kokolis LLC, McQuireWoods, TroutmanSanders LLP, Grenadier Starace duffett
& Levi PC, Hunoval Law, OCWEN have all acted as Debt collectors under the “FDCPA” Fair Debt Collection Practices
Act. And the “CFPB” Consumer Financial Protection Act of 2010 which has independent litigating authority to
commence civil actions to address violations of the “Federal Consumer Financial Laws”, with DOJ, FTC and others
having additional oversight.

Violating: all the 15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES Current through Pub. L. 114-38. (See
Public Laws for the current Congress.) 15 SC § 1692 - § 1692d - Harassment or abuse § 1692e - False or misleading
representations § 1692f - Unfair practices § 1692g - Validation of debts § 1692j - Furnishing certain deceptive forms

Further Violating with Knowledgeable intend: FDCPA Laws & Guidelines of the Fair Debt Collection Act and debt
collection services in your area. Table of Contents 801 Short title 804 Acquisition of location information 805
Communication in connection with debt collection 806 Harassment or abuse 807 False or misleading representations 808
Unfair practices 809 Validation of debts 812 Furnishing certain deceptive forms 801 15 USC 1601 note 801. Short Title
This title may be cited as the "Fair Debt Collection Practices Act." 802. Congressional findings and declaration of purpose
(a) There is abundant evidence of the use of abusive, deceptive, and unfair debt collection practices by many debt

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collectors. Abusive debt collection practices contribute to the number of personal bankruptcies, to marital instability, to
the loss of jobs, and to invasions of individual privacy. (b) Existing laws and procedures for redressing these injuries are
inadequate to protect consumers. As Lawyers the Defendants and others know their wrong doing. (c) Means other than
misrepresentation or other abusive debt collection practices are available for the effective collection of debts. (d) Abusive
debt collection practices are carried on to a substantial extent in interstate commerce and through means and
instrumentalities of such commerce. Even where abusive debt collection practices are purely intrastate in character, they
nevertheless directly affect interstate commerce. (e) It is the purpose of this title to eliminate abusive debt collection
practices by debt collectors, to insure that those debt collectors who refrain from using abusive debt collection practices
are not competitively disadvantaged, and to promote consistent State action to protect consumers against debt collection
abuses.

That OCWEN using the name and Scheme as WELLS FARGO BANK as their employee has shopped lawyers and now
hired McCabe Weisberg and Conway/ Brock & Scott to ignore suits and Foreclose. On or around May 17, 2017 a letter
was received by them that stated clearly that Wells Fargo had no instruments that should have been standing, which is
what Plaintiff has been claiming.

Which would be followed with a letter to Foreclose on July 20, 2017

That on or around July 9, 2017 a Motion to Stay Foreclosure by Wells Fargo, OCWEN by McCabe Weisberg & Conway
was filed by Janice with this court as an Emergency Stay due to the shopping of a law firm that would Foreclose while
still in court. The following Documents filed with it should be incorporated here in. (That a Reconsideration and EnBanc
has been filed)

That MCW letter dated July 18, 2017 from McCabe Weisberg & Conway LLC which was received on the 21st of July
2017.

The Letter seemed misleading and with all the above had been done to deny Janice and Janice’s Constitutional Rights
Janice created a Trust and on July 25, 2017 did a Quick Claim Deed of 15 W. Spring Street, Alexandria VA 22301 into the
Trust. Janice mailed a copy to OCWEN.

On or around Friday July 28, 2017 Janice would receive Occupant; Homeowner and Janice Wolk Grenadier letters stop
your foreclosure.

On or around Tuesday August 1, 2017 Janice would receive a letter from McCabe Weisberg & Conway LLC that they
were foreclosing on 15 W. Spring St., Alexandria VA 22301 on August 17, 2017. That with such a misleading
letter on or around May 21, 2017 the research of the misleading and appearance of criminal acts and actions of many sent
Janice to learn that the SEC which forwarded Janice to CRPB, the DOJ, the FTC, 15 USC 1692 and the FDCPA protected
Janice from PREDATORY ACTS and ACTIONS of Wells Fargo, Option One, Equity Trustees, Bank of America all in
one way or another have claimed ownership of a loan. BWW Law Group, Howard Bierman and several bad actors from
McCabe Weisberg & Conway, Michael Weiser ESQ, DiMuroGinsberg, Parker Simon & Kokolis LLC, McQuireWoods,
TroutmanSanders LLP, Grenadier Starace duffett & Levi PC, Hunoval Law and OCWEN.

Virginia has no regulations for Deceptive and Abusive practices by debt collectors so Janice is protected by the Federal
Fair Debt Collection Practices Act (FDCPA).

The Statute of Limitations to collect on a debt is 3 – 5 years from the last payment accepted.

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According to OCWEN the last payment not returned was 3, 152 days from June 16, 2017, with the last payment in 2008
that the Statute of Limitations on Collection had run out.

That Plaintiff only did the Trust / Quick Claim Deed due to the Predatory acts and actions of Defendants, Defendants
lawyers and others.

Janice / Plaintiff moved the property prior to any notification of the new foreclosure date (which according to the FDCPA
and others the date is illegally done) and or a Judgment that a Re-Consideration with an ENBANC, and Oral Arguments is
filed.

That on August 9, 2017 Janice would receive a phone call from OCWEN that the Foreclosure had been canceled as of
August 4, 2017 – Phone conversations is taped and can be heard

That on August 11, 2017 after sending email and several unreturned phone calls from McCabe (Remember this scheme
and artifice of OCWEN to say one thing and do another Janice was and still is a VICTIM Of with BWW Law Group. The
McCabe et al would not return calls to confirm Foreclosure was removed from their schedule.

That on August 11, 2017 from OCWEN she learned that the foreclosure was never removed, that OCWEN and McCabe
had schemed no differently illegally and in collusion to try and deceive Janice that the Foreclosure had been removed
from the schedule. That this illegal practice by OCWEN and Lawyers acting as Foreclosure Mills to further line their
pockets is a pattern and practice all across America.

That on August 11, 2017 Janice would call the CEO of Wells Fargo’s office to ensure he was aware of the CRIMINAL
ACTIVITY of his Servicer and Lawyers. Janice would learn in a taped conversation that Wells Fargo has no loan under
the Loan No. given by OCWEN, under her name as Janice Wolk Grenadier or Janice Wolk-Grenadier or under her Social
Security No.

That Janice / Plaintiff on several occasions offered to settle and why should opposing sides settle or consider a settlement
when they know with or without the Truth the duty of care, fair dealing and Good Faith the Judges will ignore all criminal
acts and actions by the Banks and Lawyers as shown in the above e-mail.

That Plaintiff / Janice is still willing to try and settle this matter. At this point the home is in a Trust and protected by the
law / Statute of Limitations of Collections on a loan.

That on August 17, 2017 at or around 10:00 am Plaintiff would receive notice from MWC that the FRAUD allegations
have been taken seriously and the foreclosure put on hold.

That immediately a new foreclosure date of October 5, 2017 would be rescheduled with no information requested on who
the employee of OCWEN is.

CAUSES OF ACTION

Count 1
18 USC § 371 Conspiracy, Federal False Claims Act, 31 U.S.C. § 3729 (a)(1)(A); 31 U. S. C. § 3729 (a)1(B); 31
U.S.C. § (a)(1)(C) 18 USC §1349 Attempt and Conspiracy forms Fair Debt. Collection Act (FDCPA) § 806
Harassment, § 807 False and misleading, § 808 Unfair practices, § 809 Validation of debts, § 812 Furnishing
deceptive forms, et al

101
JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

Defendants and others known and unknown did knowingly and unlawfully combine, conspire, confederate, and agree to
commit the following offenses against Janice Wolk Grenadier a. to, directly and indirectly, corruptly give, offer, and
promise a thing of value, that is, among other things, cash or cash equivalents, with intent to influence illegal acts, to
commit and aid in committing, and to collude in, and allow fraud, and make opportunity for the commission of any fraud,
on the United States,

PURPOSES OF THE CONSPIRACY to ensure the COVER UP of Divorce Lawyer Ilona Grenadier Hackman’s crimes
as attached in Exhibit Criminal Complaint filed with the Department of Justice et al.

Manner and Means of the Conspiracy: Includes Elected Officials, the Government and the Judiciary to protect one of
their own.

OVERT ACTS: That divorce lawyer Ilona Grenadier Heckman has been on a Criminal Spree stealing out of her law firm
that Janice can document starting on or around November of 1983 wit the forgery of Sonia Grenadier Heckman. That the
defendants are two of many USED to try and silence, mislead and act criminally to protect the accountable $30 MILLION
if not more that Ilona stole through her law firm from Sonia Grenadier the mother of the late Judge Albert Grenadier and
then Janice Wolk Grenadier which by the Banks, the Servicers lawyers involvement has created the scheme and artifice to
prevent Janice any type of financial where for all.

This is a claim for treble damages and forfeitures under the False Claims Act, 31 U.S.C. § 3729 et seq. 2

The Defendants created, sold or participated in Mortgage backed securities. The Mortgage backed Securities were
composed of mortgages bundled to create the securities in which the mortgages lacked the requisites to create a secured,
real estate debt obligation, namely:

The legally binding assignments from the originating bank to the securities trust and, and finally, to the foreclosure agent

Recording of Title in the Cities Clerk's office

Original Note and Mortgage, signed by both borrower and lender. The prospectus for each mortgage-backed securities
trust, and other public statements, falsely represented that the trust held good title to the mortgages and notes bundled in
the securities.

By Virtue of the wrongful conduct alleged here including, but not limited to, the false signatures used in manufactured
mortgage assignments, or stating the person had POWER OF ATTORNEY which does not exist each of the
mortgage-backed securities sold to the Treasury, or other entity funded by the U.S. government, violated state and federal
laws and furthered an effort to transfer impaired securities to the Treasury, or other government funded entity. Defendants
and their agents and employees falsely represented that they held good title to 15 W. Spring Street. Defendants received
millions of dollars in U.S. government funds to provide services involving fraudulent mortgage assignments. Accordingly,
the Defendants and their agents and employees knowingly presented or caused to be presented a false or fraudulent claim
for payment or approval from the government entity purchasing the mortgage-backed securities.

Defendants and their agents and employees falsely represented that they had good title to 15 W. Spring Street. When in
Fact they had in their knowledgeable fraudulent actions created a cloud on the Title making the home unsellable.

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Defendants acted in concert to create fraudulent legal documentation to conceal that the trust was missing title to the asset,
thus impairing the value of the security sold to the treasury, or other government funded entity. Each of the
mortgage-backed securities sold to the Treasury, or other government funded entity, was in violation of state and federal
law.

THE GOVERNMENT (AG Eric Holder, Ben Bernanke & ) SELLS OUT THE AMERICAN PEOPLE

The Financial Crisis Inquiry Report: Final report of the National Commission on the Causes of the Financial
Economic Crisis in the United State of America https://www.govinfo.gov/content/pkg/GPO-FCIC/pdf/GPO-FCIC.pdf -
This link will take you to the Official Government Edition.

Some of the Banks that received the SECRET Bail out through AIG

Banks $ Amount CEO 2008 Where he is today

Bank of America $ 1,535,002,662,031 CEO, President & Chairman Currant Board Member
Kenneth D. Lewis Emeritus Member, Board of
Jan 1971 - 2009 Trustees
4.21M 2009
9.86 M 2008 2013 CEO Countrywide
23.6M 2007 Bank
27.9M 2006
2009 Merrill lynch
LaSalle Bank Chairman, President
& CEO

Citi $ 2,920,896,888,595 Vikram Pandit American banker CEO of The Orogen Group
and investor who was the CEO of https://www.globenewswire
Citigroup from December 2007 to .com/news-release/2018/10/
16 October 2012 and is the current
02/1588561/0/en/EXL-Ann
chairman
Citigroup Global 21012 ounces-150-Million-Strateg
Smith Barney Inc 2009 ic-Investment-from-The-Or
Citi Institutional 2007 ogen-Group.html
1983-2005 Morgan Stanley
President / CPP EXL Announces $150
Million Strategic
9.55 M 2012 Investment from The
14.9 M 2011 Orogen Group
$1 M 2010
129K 2009 Vikram S. Pandit, Chairman
38.2M 2008 and CEO of The Orogen
3.16 M 2007 Group, appointed to EXL’s
Board of Directors

Goldman Sachs $ 874,552,426,455 The 2008 financial crisis hit the
global economy hard, and
Goldman Sachs Chairman and
CEO Lloyd Blankfein, who led
the company through it, said it
may still take institutions a while
Senior Chairman
Chief Executive OfficerJun
1, 2006 - Sep 30, 2018
Vice Chairman, Equities
DivisionApr 1, 2002 - Jan

103
 to recover. 1, 2004
2007 $ 54M Co-Head of the Fixed
2008 $40.9M Income, Currency &
2009 $1.03 M Commodities Division1997
2010 $14.1 M - Feb 1, 2002
2011 $16.2 M Head, Currency &
2012 $13.3 M Commodities Division
2013 $19.9 M 1994 - 1997
2014 $22.2 M President, Chief Operating
2015 $ 22.6 M Officer Director
2016 $ 20.2 M
2017 $ 23.4 M

JP Morgan Chase $ 460,982,382,326 Jamie Dimon JPMorgan Chase & Co.

Current
He is chairman and CEO of Chairman & Chief
JPMorgan Chase, the largest of
the big four American banks, and Executive Officer Dec 31,
was previously on the board of 2006 - Current
directors of the Federal Reserve
Bank of New York.

2019 $31.6 M
2018 $ 30 M
2017 $ 28.3 M
2016 $27.2 M
2015 $ 18.2 M
2014 $27.7 M
2013 $11.8 M
2012 $ 18.7 M
2011 $23.1 M
2010 $20.8 M
2009 $ 1.32 M
2008 $35.8 M
2007 $28.9 M
2006 $39.1 M

Morgan Stanley $ 2,287,966,932,941 John J. Mack Chairman, Morgan

Stanley (Jun 30, 2005 - Jan 1,
2012)

2009 $1.25 M
2008 $1.24 M
2007 $ 41.8 M

Wells Fargo Bank $ 198,712,559,776 John Stumpf became CEO of

Wells Fargo in June 2007 and its
chairman in January 2010. In
2012, Stumpf's total compensation
was $22.87 million with a base
salary of $2.8 million, $3,300,000
in cash bonuses, $12.5 million in
stock granted, and $15,000 in
other compensation
● $21.3M 2016

104
 ● $19.3M 2015
● $21.4M 2014
● $19.3M 2013
● $22.9M 2012
● $19.8M 2011
● $19M 2010
● $21.3M 2009
● $9.04M 2008
● $14.8M 2007
● $11.8M 2006

Then 5,000. of the Executives received at least $1 MILLION in bonus each

CASES YOU CAN’T IGNORE

Other then the Two CFPB Cases Above:

Case Link Plaintiff Defendants

105
https://judicialpedia.com/listing/be
ar-stearns-mortgage-pass-through-
certificates-litigation-850-securitie
s-commodities/
BEAR STEARNS MORTGAGE
PASS-THROUGH
CERTIFICATES LITIGATION
/ : 850 Securities/Commodities
Date
September 18, 2008
City/County
New York
Type of Case
850Securities/Commodities Class
Action Complaint for Violation of
the Securities Act of 1933
Case Number
1:09-cv-06172-LTS Lead case:
1:08-cv-08093-LTS Member case:
(View Member Case) Related
Case: 1:08-cv-08093-LTS Cause:
15:78m(a) Securities Exchange
Act
Judges Judge Laura Taylor Swain
https://judicialpedia.com/listing/ca
rvelli-v-ocwen-financial-who-regu
lates-whom-whos-regulating-the-b
anks-servicers-foreclosure-complai
nts-up-states-the-cfpb/
Carvelli v OCWEN Financial Who
Regulates Whom? Who's
Regulating the BANKS &
SERVICER'S? FORECLOSURE
COMPLAINTS UP STATES THE
Public Employees' Retirement System of
Mississippi
Pension Trust Fund For Operating
Engineers individually
Pension Trust Fund For Operating
Engineers
and on behalf of all others similarly
situated
The State of Oregon, by and through the
Oregon State Treasurer and the Oregon
Public Employee Retirement Board on
behalf of the Oregon Public Employee
Retirement Fund
Iowa Public Employees' Retirement
System
San Antonio Fire & Police Pension Fund
City of Fort Lauderdale Police & Fire
Retirement System
Karen A. Carvelli
University of Puerto Rico Retirement
System
Ryan Huseman
Structured Asset Mortgage Investments II, Inc.
Bear Stearns Alt-A Trust 2006-6
Bear Stearns ARM Trust 2006-4
Bear Stearns Mortgage Funding Trust 2006-AR2
Structured Asset Mortgage Investments II
Trust 2006-AR7
Structured Asset Mortgage Investments II
Trust 2006-AR6
Bear Stearns Alt-A Trust 2006-5
Bear Stearns Mortgage Funding Trust
2006-AR5
Bear Stearns Alt-A Trust 2006-8
Bear Stearns Mortgage Funding Trust
2006-AR4
Structured Asset Mortgage Investments II
Trust 2006-AR8
Bear Stearns Mortgage Funding Trust
2006-AR3
Bear Stearns Alt-A Trust 2006-7
Bear Stearns Alt-A Trust 2007-I
Bear Stearns Mortgage Funding Trust
2007-AR1
Bear Stearns Arm Trust 2007-3
Bear Stearns Mortgage Funding Trust
2007-AR3
Bear Stearns Arm Trust
Michael B. Nierenberg
Thomas F. Marano
The Bear Stearns Companies Inc.
Bear, Stearns & Co. Inc.
Bear Stearns Arm Trust 2007-1
Jeffrey L. Verschleiser
Jeffrey Mayer
Ocwen Financial Corporation
Ronald M. Faris
Michael R. Bourque Jr.
106
CFPB
Date
April 21, 2017
City/County
West Palm Beach
Type of Case
Cause: 15:0077 Securities Fraud
Nature of Suit: 850
Securities/Commodities
https://judicialpedia.com/listing/fe
deral-housing-finance-agency-v-jp
morgan-chase-co-et-al-nature-of-s
uit-850-securities-commodities-we
re-you-told-to-not-make-payments
-by-your-servicer/
Federal Housing Finance
Agency v. JPMorgan Chase &
Co. et al Nature of Suit: 850
Securities/Commodities Were
you told to not make payments
by your Servicer?
Date
September 2, 2011
City/County
New York City
Type of Case
Cause: 15:77 Securities Fraud /
850 Securities/Commodities
Jurisdiction: U.S. Government
Plaintiff
Federal Housing Finance Agency as
Conservator for the Federal National
Mortgage Association and the Federal
Home Loan Mortgage Corporation
FEDERAL HOUSING FINANCE
AGENCY, AS CONSERVATOR FOR
THE FEDERAL NATIONAL
MORTGAGE ASSOCIATION AND
THE FEDERAL HOME LOAN
MORTGAGE CORPORATION
JPMorgan Chase & Co., JPMorgan Chase Bank
N.A.
J.P. Morgan Mortgage Acquisition Corporation
J.P. Morgan Securities, LLC formerly known as,
J.P. Morgan Securities Inc.
Bear Stearns & Co., Inc.Structured Asset
Mortgage Investments II Inc.
Bear Stearns Asset Backed Securities I LLC
WAMU Asset Acceptance Corporation
WAMU Capital Corporation
Washington Mutual Mortgage Securities
Corporation also known as Washington
MutualMortgage Securities Corporation
Long Beach Securities Corporation
Citigroup Global Markets, Inc.
Credit Suisse Securities (USA) LLC
Goldman, Sachs & Co.
David M. Duzyk, Louis Schioppo, Jr.
Christine E. Cole, Edwin F. McMichael
William A. King, Brian Bernard
Matthew E. Perkins, Joseph T. Jurkowski, Jr.,
Samuel L. Molinaro, Jr. Thomas F. Marano
Kim Lutthans, Katherine Garniewski
Jeffrey Mayer, Jeffrey L. Verschleiser
Michael B. Nierenberg
Richard Careaga, David Beck, Diane Novak,
Thomas Green, Rolland Jurgens
Thomas G. Lehmann, Stephen Fortunato
Donald Wilhelm, Michael J. Kula
Craig S. Davis, Marc K. Malone
Michael L. Parker, Megan M. Davidson
David H. Zielke, Thomas W. Casey
John F. Robinson, Keith Johnson
Suzanne Krahling, Larry Breitbarth
Marangal I. Domingo, Troy A. Gotschall
Art Den Heyer, Stephen Lobo
J.P. Morgan Acceptance Corporation I
EMC Mortgage LLC formerly known as
EMB Mortgage Corporation
RBS Securities Inc. (f/k/a Greenwich
Capital Markets Inc.)
The Clearing House Association L.L.C.
107
https://judicialpedia.com/listing/in-
re-bear-stearns-mortgage-pass-thro
ugh-certificates-litigation-850-secu
rities-commodities-jurisdiction-fed
eral-question/
In Re: BEAR STEARNS
MORTGAGE PASS-THROUGH
CERTIFICATES LITIGATION /
850 Securities/Commodities
Jurisdiction: Federal Question /
Date
September 18, 2008
City/County
New York
Type of Case
850 Securities / Commodities
Case Number
1:08-cv-08093-LTS - Related
Case: 1:09-cv-06172-LTS Related
Case No. 1:09-cv-06172-LTS Case
in other court: Supreme
Court-County of New York,
602426- 08
Judges Judge Laura Taylor Swain
https://judicialpedia.com/listing/jo
hn-hancock-life-insurance-compan
y-u-s-a-et-al-v-jp-morgan-chase-co
-850-securities-commodities/
John Hancock Life Insurance
Company (U.S.A.) et al v. JP
Morgan Chase & Co / 850
Securities/Commodities
Date
April 23, 2012
City/County
New York City
Type of Case
850 Securities/Commodities
Case Number
1;12-cv-03184- RJS Case in other
New Jersey Carpenters Health Fund on
behalf of itself and all others similarly
situated
Boilermaker Blacksmith National
Pension Trust
Policemen's Annuity and Benefit Fund
of the City of Chicago
Public Employees' Retirement System of
Mississippi
New Jersey Carpenters Health Fund
Police and Fire Retirement System of the
City of Detroit
Police and Fire Retirement System of the
City of Detroit
The State of Oregon, by and through the
Oregon State Treasurer and the Oregon
Public Employee Retirement Board on
behalf of the Oregon Public Employee
Retirement Fund
Iowa Public Employees' Retirement
System
San Antonio Fire & Police Pension Fund
City of Fort Lauderdale Police & Fire
Retirement System
John Hancock Life Insurance Company
(U.S.A.)
John Hancock Life Insurance Company
(U.S.A.) Separate Account 6A
John Hancock Life Insurance Company
(U.S.A.) Separate Account 131
John Hancock Funds II
John Hancock Variable Insurance Trust
John Hancock Sovereign Bond Fund
John Hancock Bond Trust
John Hancock Strategic Series
John Hancock Income Securities Trust
Bear Stearns Mortgage Funding Trust
2006-AR1
Structured Asset Mortgage Investments
II, Inc.
Jeffrey L. Verschleiser
Michael B. Nierenberg
Jeffrey Mayer
Thomas F. Marano
Joseph T. Jurkowski
Bear Stearns & Co., Inc.
JP Morgan Chase, Inc.
Bear Stearns Asset Backed Securities I,
LLC
EMC Mortgage Corporation
Matthew E. Perkins
Samuel L. Molinaro, Jr.
Kim Lutthans
Katherine Garniewski
The McGraw-Hill Companies, Inc
Moody's Investors Service, Inc.
J.P. Morgan Securities, Inc.
ADR Provider
The State of Oregon, by and through the
Oregon State Treasurer and the Oregon
Public Employee Retirement Board on
behalf of the Oregon Public Employee
Retirement Fund
JP Morgan Chase & Co.
JPMorgan Chase Bank N.A
J.P. Morgan Mortgage Acquisitions Corp.
J.P. Morgan Securities, LLC
formerly known as
J.P. Morgan Securities Inc
J.P. Morgan Acceptance Corporation I
Chase Mortgage Finance Corporation
Chase Home Finance LLC
EMC Mortgage LLC formerly known as
EMC Mortgage Corporation
Bear Stearns and Co., Inc.
Bear Stearns Asset Backed Securities I LLC
Structured Asset Mortgage Investments II Inc.
WAMU Asset Acceptance Corp.,
Washington Mutual Mortgage Securities Corp.
WAMU Capital Corp.,
Long Beach Securities Corp.
108
court: Supreme Court- New York
County, 650195-12 Cause:
28:1441nr Notice of Removal
Judges Judge Richard J. Sullivan
https://judicialpedia.com/listing/ly
nn-e-szymoniak-hero-whistleblow
er-illegal-foreclosure-still-happeni
ng-with-fake-mortgage-back-secur
ities/
LYNN E SZYMONIAK
"HERO" Whistleblower
ILLEGAL FORECLOSURE
STILL HAPPENING WITH
"FAKE" MORTGAGE BACK
SECURITIES
Date
June 4, 2010
City/County
USA Ex Rel Lynn E. Symoniak
California, State of
Delaware State of
Florida State of
Hawaii State of
Illinois State of
Indiana State of
Massachusetts State of
Minnesota State of
Montana State of
Nevada State of
New Hampshire State of
New Jersey State of
New Mexico State of
New York State of
North Carolina State of
Oklahoma State of
Banc of America Securities LLC
CSE Mortgage, LLC
Deutsche Bank Securities Inc.
John Barren, David Beck
Sara Bonesteel, Domenic A. Borriello
Richard Careaga, Jerome A. Cipponeri
Christine E. Cole, Craig S. Davis
Art Den-Heyer, Marangal I. Domingo
David M. Duzyk, Katherine Garniewski
Troy A. Gotschall, Patricia A. Jehle
Juliana C. Johnson, Rolland Jurgens
Joseph T. Jurkowski, Jr., Michael D. Katz
William A. King, Marc R. Kittner
Michael J. Kula, Thomas G. Lehmann
Stephen Lobo,Richard D. Lodge
Kim Lutthans, Marc K. Malone
Thomas F. Marano, Jeffrey Mayer
Edwin F. McMichael, Samuel L. Molinaro, Jr.
Michael B. Nierenberg
Diane Novak, Michael L. Parker
Matthew E. Perkins, Louis Schioppo, Jr.
Jeffrey A. Sorense, Jeffrey L. Verschleiser,
Thomas L. Wind, David H. Zielke
Greenwich Capital Markets, Inc.
also known as RBS Greenwich Capital
Merrill Lynch & Co.
UBS Securities LLC formerly known as
UBS Warbug LLC
Brian Bernard, Megan M. Davidson
Eric Ferren,Stephen Fortunato
Donald Wilhem
Merrill Lynch, Pierce, Fenner & Smith Inc.
JP Morgan Chase Bank, N.A
ThirdParty Defendant
Federal Deposit Insurance Corporation
Movant
Ocwen Loan Servicing, LLC
Defendant
American Home Mortgage Servicing Inc
Saxon Mortgage Services Inc
Lender Processing Services Inc
Docx LLC
CitiMortgage Inc
formerly known as
Citi Residential Lending Inc
formerly known as
AMC Mortgage Services Inc
Wells Fargo Home Mortgage
Formerly known as
109
Rock Hill
Type of Case
FORECLOSURE
Case Number
0:10-cv-01465-JFA Related Cases
0:15-mc-000062-JFA
0:13-cv-00464-JFA
Judges Judge Joseph F.
Anderson, Jr
https://judicialpedia.com/listing/sti
chting-pensioenfonds-abp-v-jpmor
gan-chase-co-et-al-850-securities-c
ommodities/
Stichting Pensioenfonds ABP v.
JPMorgan Chase & Co. et al /
850 Securities/Commodities
Date
February 24, 2013
City/County
New York City
Type of Case
: 850 Securities/Commodities case
is hereby designated for inclusion
in the Pilot Project Regarding Case
Management Techniques for
Complex Civil Cases in the
Southern District of New York (the
Pilot Project),
Case Number
1:12-cv-01398-LAK Case in other
court: State Court- Supreme,
653383-11 Cause: 28:1441nr
Notice of Removal
Judges
Judge Lewis A. Kaplan
Rhode Island State of
Virginia State of
District of Columbia
Chicago City of
New York City of
Stichting Pensioenfonds ABP
ThirdParty Plaintiff
JPMorgan Chase Bank N.A
America's Servicing Company
Bank of America Corporation
as successor in interest to Lasalle Bank
Bank of New York Mellon Corporation
Citibank National Association
Deutsche Bank National Trust Company
Deutsche Bank Trust Company Americas
HSBC USA National Association
JP Morgan Chase Bank National
Association
US Bank National Association
Wells Fargo Bank National Association
JPMorgan Chase & Co.
JPMorgan Chase Bank N.A.
J.P. Morgan Mortgage Acquisition Corp.
J.P. Morgan Securities, LLC formerly known as
J.P. Morgan Securities Inc
J.P.Morgan Acceptance Corporation I
EMC Mortgage LLC formerly known as
EMC Mortgage Corporation
Bear Stearns Asset Backed Securities I LLC
WAMU Asset Acceptance Corp.,
Washington Mutual Mortgage Securities Corp.
WAMU Capital Corp.,
Long Beach Securities Corp
Banc of America Securities Corp.
Banc of America Securities LLC
Credit Suisse Securities LLC
Credit Suisse Securities (USA) LLC
David Beck, Brian Bernard
Richard Careaga, Thomas W. Casey
Christine E. Cole, David M. Duzyk
Stephen Fortunato, Michael J. Giamapaolo,
Rolland Jurgens
William A. King, Edwin F. McMichael
Louis Schioppo, Jr., Katherine Garniewski
Thomas Green, Joseph T. Jurkowski, Jr
Thomas Lehmann, Kim Lutthans
Thomas F. Marano, Jeffrey Mayer
Samuel L. Molinaro, Jr., Michael B. Nierenberg,
Diane Novak
Matthew E. Perkins, John F. Robinson
Jeffrey Verschleiser, Donald Wilhelm
David H. Zielke
Structured Asset Mortgage Investments lI, Inc.
Bear Stearns and Co. Inc.
Structured Asset Mortgage Investments II Inc
ThirdParty Defendant
110

https://judicialpedia.com/listing/po
well-et-al-v-ocwen-financial-corpo
ration-et-al-29-u-s-code-%c2%a7
%e2%80%af1109-liability-for-bre
ach-of-fiduciary-duty/
Powell et al v. Ocwen Financial
Corporation et al 29 U.S. Code
§ 1109.Liability for breach of
fiduciary duty
Date
March 5, 2018
City/County
New York
Type of Case
Cause: 29:1109 Breach of
Fiduciary Duties, Nature of Suit:
791 Labor: E.R.I.S.A, Jurisdiction:
Federal Question
Case Number
1:18-cv-01951-VSB-SDA
Judges
Assigned to: Judge Vernon S.
Broderick
Referred to: Magistrate Judge
Stewart D. Aaron
Breach of Contract – Implied Covenant of Good Faith and Fair Dealing –
Breach of Contractual Duty of Good Faith and Fair Dealing Honest Services 18 U.S.C. § 1346
JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint
Ronald E. Powell as Trustee of The
United Food & Commercial Workers
Union & Employers
Midwest Pension Fund
Robert O'Toole
as Trustee of The United Food &
Commercial Workers Union &
Employers
Midwest Pension Fund
Robert Wilson
as Trustee of The United Food &
Commercial Workers Union &
Employers
Midwest Pension Fund
Brian Jordan
as Trustee of The United Food &
Commercial Workers Union &
Employers
Midwest Pension Fund
Donald G Schaper
as Trustee of The United Food &
Commercial Workers Union &
Employers
Midwest Pension Fund
William R. Seehafer
as Trustee of The United Food &
Commercial Workers Union &
Employers
Midwest Pension Fund
COUNT 2
Federal Deposit Insurance Corporation
as Receiver for Washington Mutual Bank
ThirdParty Defendant
Federal Deposit Insurance Corporation
in its Corporate Capacity
Ocwen Financial Corporation
Ocwen Loan Servicing, LLC
Ocwen Mortgage Servicing, Inc
Altisource Portfolio Solutions, S.A.
Altisource Residential Corporation
Altisource Asset Management Corporation
Assurant, Inc.
Standard Guaranty Insurance Company
American Security Insurance Company
Voyager Indemnity Insurance Company
American Bankers Insurance Company of Florida
HomeSure Services, Inc
Cross Country Homes Services, Inc.
HomeSure of America, Inc.
Homesure Protection of Virginia Inc
Wells Fargo Bank, N.A.
Altisource Solutions, Inc.
REALHome Services and Solutions, Inc.
Altisource Online Auctions, Inc.
Southwest Business Corporation
111
By virtue of the facts stated above, defendants have violated their contractual duty of good faith and fair dealing. Honest
Service under 18 U.S.C. § 1346 the Defendants schemed to foreclose on Plaintiff’s home with forged documents, with
knowledgeable intent of Fraud.

The above defendants and defendant’s representatives breached their contractual duty of good faith and fair dealing when
they refused to provide the requested original Note.

The above defendants Breach of Contract includes not limited to their involvement with breaking the chain of title and
creating a situation where JWG could not sell the home . The documents speak for themselves the defendants were aware
of these breaches.

JWG through implied covenant of good faith and Fair Dealing continued to work with the different Servicing groups even
after they continued to lose paperwork, and make false claims, and advertise her home for a Foreclosure Sale.

The defendant’s “flagrantly violated” their Fiduciary responsibility to JWG to deal in Good Faith while JWG continued to
deal in Good Faith.

That a Breach of Contract was created when the documents by Wells Fargo, Bank of America were forged, by known robo
signers.

That now Wells Fargo Bank and Bank of America claim no alleged ownership while a Servicer needs an employer to
foreclose – needs a contract to show it has any type of STANDING. OCWEN has used it’s own employees to fraudulently
sign rights over to Surety Trustees who must know as it states right on it – OCWEN employees. AS Debt Collectors that
they state clearly they are, they need to ensure that the debt they are collecting is a legitimate debt and owned by
OCWEN. MCW was informed that it was not a legitimate debt owned by OCWEN.
Count 3
Violation of the Fair Debt Collection Practices Act (FDCPA)
(15 U.S.C 1692, ET SEQ.) § 1692e - False or misleading representations § 1692f - Unfair practices § 1692g -
Validation of debt § 1692j - Furnishing certain deceptive forms forms Fair Debt. Collection Act (FDCPA) § 806
Harassment, § 807 False and misleading, § 808 Unfair practices, § 809 Validation of debts, § 812 Furnishing
deceptive forms, et al

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That there is no debt as the statute of limitations for collection has run out, the banks Wells Fargo and Bank of America
have stated they have no loan that they can account for.

Defendants used unfair/unconscionable means to try and foreclose illegally and unethically on 15 West Spring Street
while Plaintiff was under the production of the HAMP program as described in paragraph

That the statute of limitations to collect on any type of debt has passed

That the documents filed against t the home by OCWEN, BWW Law Group, Brock and Scott, MCW are fraudulent as
Wells Fargo in a taped conversation out of the CEO’s Executive office states very clearly they have no loan under the
Loan No. of OCWEN, under the name Janice Wolk Grenadier or Janice Wolk – Grenadier or under Janice’s social security
No.

112
Further Stating that Evette Morales who signed as Attorney in Fact for Wells Fargo Bank does not have a Power of
Attorney to do such act for 15 W. Spring St. Alexandria VA 22301.

Further to ignore the STAY as issued by the 4th Circuit is in direct conflict of the lawyers Professional Code of Ethics
Cinder with the court 3.3 Further a self reporting group Lawyers and Judges have an obligation to report criminal activity
by Servicers and Banks. The appearance is OCWEN, BWW Law Group, Brock and Scott and MCW is further lining their
pockets as well as being a party to the Cover Up of Divorce Lawyer Ilona Grenadier Heckman’s Criminal Spree.

Further even the Attorney General's Office has stated to OCWEN this Foreclosure should not take place as an
investigation is underway.

Count 4
Wrongful Foreclosure Threat – Failure to Comply with HAMP rules

JWG incorporates herein by reference all of the allegations contained in the above a. Paragraphs of this Complaint

HAMP PROHIBITS A PARTICIPATING server from taking several actions including the following:

Proceeding with a foreclosure sale. Any foreclosure sale must be suspended and no new foreclosure action may be
initiated during the trial period, and until the borrower has been considered and found ineligible for other available
foreclosure prevention options.

Requiring a borrower to make an initial contribution payment pending the processing of the trial period plan before the
plan starts.

Soliciting borrowers to opt out of consideration for HAMP during the temporary review period.

Reporting borrowers as delinquent to credit reporting bureaus without explanation. For borrowers who are current when
they enter a trial period, the servicer should report the borrower current but on modified payment if the borrower makes
timely payments during the trial period. For borrowers who are delinquent when they enter the trial period, the servicer
should report in such a manner that accurately reflects the borrower’s current workout status.

Assessing prepayment penalties for full or partial prepayment as part of the modification.

The HAMP rules were expressed to JWG several times by AHMSI, Homeward and OCWEN - that you could not
be foreclosed on while you were being considered for the program.

It is documented that lawyers are nervous of losing the financial gain of Foreclosures stopping due to their illegal and
unethical practices. That if the homeowner gets into the HAMP program and an adjustment is made to the loan – the
lawyer loses an extra $50,000 or more. he gets from a foreclosure.

BWW Law group and now McCabe Weisberg and Conway, Brock and Scott Pllc had no other motivation to foreclose on
Plaintiff except for personal financial gain, greed and the exposure of their illegal and unethical practices and for COVER
UP of others criminal activity as stated in the CFPB Complaint of

The attached emails will back up these intentions being malicious, violent, oppressive, fraudulent, wanton, or
grossly reckless.

113
JWG after Defendants lawyers Troutman Sanders aka Mays & Valentine attached themselves to the Cover Up of Divorce
Lawyer Ilona Grenadier Heckman’s Criminal Spree to help deny Janice any and all Justice in the courts in collecting her
monies owed her from the THEFT of Ilona she is unable to if there was a loan qualify.

That the defendants have impeded with their lawyers the ability for Janice to earn a living

The BWW Law Group, the MCW, PARKER, SIMON & KOKOLIS LLC, the Brock and Scott Lawyers attached
emails in the Exhibits back up their intentions being malicious, violent, oppressive, fraudulent, wanton, or grossly
reckless.

Count 5
Consumer Protection Act

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

Bank of America and Wells Fargo used representatives to use unfair or deceptive acts or practices in forgery and robo
signing / FORGERIES of documents were deliberate with knowledgeable acts and actions to COVER UP criminal
behavior.

The deceptive acts of BWW Law Group, MCW, Brock and Scott, PARKER, SIMON & KOKOLIS LLC, and Troutman
Sanders aka Mays & Valentine lawyers for OCWEN have caused JWG the loss of Funding for her company, and monies
due her from her divorce and the opportunity to meet the guidelines needed for the Hamp Loan.

That the defendants OCWEN is directly involved in helping to cover up the Criminal spree of divorce lawyer Ilona
Grenadier Heckman and now with the help of MCW LLC, BWW Law Group and Brock and Scott PLLC

Count 6
Breach of Fiduciary Duty - Unjust Enrichment/Constructive Trust

JWG incorporates herein by reference all of the allegations contained in the above a. Paragraphs of this Complaint

BWW Law, MCW, PARKER, SIMON & KOKOLIS LLC, and Brock & Scott breached its Fiduciary Duty when it put
its financial gain above the law and the rights of Plaintiff.

BWW Law, MCW, PARKER, SIMON & KOKOLIS LLC, and Brock & Scott breached its Fiduciary Duty when it
ignored the HAMP rules for financial gain and greed.

Bank of America and its representatives breached its Fiduciary Duty with the Robo Signing / forgery of documents
breaking the chain of title on 15 West Spring Street.

Well Fargo and its representative breached its Fiduciary Duty with the Robo Signing / forgery of documents breaking the
chain of title on 15 West Spring Street.

MCW LLP, PARKER SIMON & KOKOLIS LLC, BWW Law Group, Howard Bierman, and Mark Galbraith, Brock &
Scott breached their Fiduciary Duty with the refusal of production of the original Note or any proof of the right to
Foreclose on 15 West Spring Street.

114
OCWEN and the above as well as BWW Law, MCW, PARKER SIMON & KOKOLIS LLC, and Brock & Scott have
and had a responsibility of good faith and fair dealings that they have ignored.

Further the double dipping and filing of fraudulent documents against 15 W. Spring St with their Trustee company

That documentation from JWG since on or around 2010 has been requested and ignored.

Stating that Wells Fargo is the Note Holder while Wells Fargo informs CFPB they have nothing to do with a loan at 15 W.
Spring St., Alexandria VA 22301 and or with Janice Wolk Grenadier. See Exhibits

Defendant lack of standing. That on or around 2013, Defendant OCWEN became aware of its lack of standing to pursue
any type of foreclosure action on JWG’s home, located at 15 W. Spring Street, Alexandria VA 2230, but they nevertheless,
for their own financial profit and gain, pursued illegal collection remedies that have wrongfully harmed this JWG.

That Evette Morales who signed as attorney in Fact for Wells Fargo Bank is an employee of OCWEN. The person who
notarized the document that gave Surety Trustee aka McCabe Weisberg and Conway the right to Foreclose has the same
title as Evette Morales and seems to be office mates. Further Wells Fargo Bank denies every giving Evette Morales any
type of POWER OF ATTORNEY to decide who has foreclosure POWER. Evette is a Contract Management Coordinator
at OCWEN Financial Corporation. This job advertises for a salary of $30,000 - $36,000 approx.

That in or around December 2013 - 2014 OCWEN to avoid any criminal charges – no different then in the past with Wells
Fargo Bank and Bank of America did a consent ORDER to cease and desist the criminal activity.

That OCWEN has violated the CONSENT ORDER that was also signed by the Attorney General of Virginia. That the
OAG’s of the State of Virginia’s office has requested this illegal Foreclosure be put on HOLD For further investigation.

That the CFPB filed this Complaint against OCWEN on or around April 20, 2017: in the USDC of the Southern District
of Florida West Palm Beach Division Case No. 9:17 –cv- 80495 - CFPB v. OCWEN FINANCIAL CORPORATION a
Florida Corporation , OCWEN MORTGAGE SERVING, INC, a US Virgin Islands corporation AND OCWEN LOAN
SERVICING LLC a Delaware Corporation - Defendants Page 2 Paragraph 2 States: The bureau brings this action against
the Defendants under: (1)Sections 1031 and 1036 of the CFPA , 12 USC §§ 5531, 5536; (2) Sections 807 (2)(a), 807(10),
and 808 of the Fair Debt Collection Practices Act, 15 USC §§ 1692e(2)(a), 1692e(10), and 1692f (the “FDCPA”); (3)
Section 6 and 19 of the Real Estate Settlement Procedures Act (RESPA), 12 USC §§ 2605, 2617, and the regulations,
promulgated 29 thereunder at Regulation X, 12 C.F.R. part 1024 (“Regulation X”); (4) Section 105(a) of the Truth and
Lending Act (“TILA”), 15 USC § 1604(a), and the regulations promulgated thereunder act Regulation Z, 12 C.F.R. part
1026 (“Regulation Z”): and (5) Section 3(b) of Homeowners Protection Act of 1998, 12 USC § 4902(b)(the “HPA”).

That this complaint shows that CFPB knew the acts and actions of OCWEN and that they had UNCLEAN HANDS and
yet allowed the foreclosure shows the COVER UP criminal activity. That JWG as an Intervener should be allowed.

The Government and this Court is aware of the UNCLEAN hands and have supported the Banks and Servicers criminal
activity ignoring the American Citizen.

The scheme and artifice between the Defendants who intentionally and willfully scheme to defraud Plaintiff, was for the
purpose of using color of law and misuse of the Trustee function, to obtain money, attorney fees, and plaintiffs property
for their own benefit by materially false and fraudulent pretense, representations and promises, by intentionally defrauding
both JwG and Wells Fargo Bank by collecting on a nonexistent loan, which they knew was not collectible, was written off
by the bank, and which they interfered with refinancing to cause harm to Plaintiff and opportunity for themselves..
115
 Count 7
Injunctive / Declaratory Relief

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That JWG now needs to pray this court grants temporary or permanent injunctive relief as JWG resides in the
property and as Defendants are seeking, through illegal and unlawful means and without satisfying the necessary
legal standing requirements to institute a foreclosure, take possession, custody, and control of the Property.

Count 8
Common Law Fraud12 U.S.C 1972

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

On several occasions JWG sent money to the Servicing agency of Wells Fargo and Bank of America to only have funds
returned and agreement squashed.

It is very well documented that the Mortgage Servicer’s were instructed to not take any payments and to "work with you"
only after borrowers fall behind in payments. Once borrowers fall behind on purpose and at the lender's request,
foreclosure proceedings begin in earnest. The Foreclosure lawyers and their friends are the beneficiary in the game, as is
seen above with the amount of money Shapiro and Burson have reported making from being one of Freddie Mac
Servicers.

The defendants or their representatives on several occasions made false statements of material facts. ie OCWEN – “Ignore
the Foreclosure it is illegal for them to as you are in the HAMP program process”

The defendants and or their representatives making these statements knew or should have known it to be untrue;

JWG to whom the statement was made had a right to rely on the statement; but, fortunately knew how deceitful the
defendants had been in the past.

JWG relied on the statement for as long as time permitted.

JWG believes the statement was made for the purpose of inducing the other party to be able to Foreclose on JWG’s home
and gain financially.

JWG relied on the Banks and their representatives at Homeward and OCWEN to not foreclose and to give JWG's legal
right to the opportunity to get Funding for her company and the opportunity to keep her home.

These statements made – created a situation that Plaintiff was not able to get the funding needed for her company, giving
her the income to qualify for a loan.

Count 9
Negligence – the negligent infliction of emotional distress;
the intentional infliction of emotional distress

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint
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The defendant’s had a legal duty to use reasonable care to protect the Chain of Title to the property at 15 West Spring
Street. By not doing this simple act the defendant’s malicious actions caused great emotional distress to Plaintiff.

That Evette Morales who claims to have a Power of Attorney from Wells Fargo Bank and signs as Attorney in Fact,
OCWEN and its attorneys have shown no employee contract with Wells Fargo on alleged loan as Wells Fargo and Bank of
America have claimed no ownership in alleged loan and further Wells Fargo Bank claims never to have given such Power
of Attorney.

The actions of the actors to cause this emotional distress were malicious, violent, oppressive, fraudulent, wanton, or
grossly reckless.

The defendants failed in their duty and unreasonably caused emotional distress to JWG with intentional infliction of
emotional distress. The negligence is sufficient to support this cause of action.

The defendants were negligent in all actions against JWG and 15 West Spring Street not following the law and the Rules
of the HAMP program.

The defendants had a Fiduciary Duty to JWG, the public and 15 West Spring Street.

Count 10
Constructive Fraud,,18 USC § 1341
Frauds and Swindles 18 USC § 1343 Fraud by Wire, 18 USC §1344
Bank Fraud 18 USC §1346 Honest Services 18 USC § 1348 Securities and Commodities fraud

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The defendants were deceptive of material misrepresentations of past and existing facts and remained silent when a duty
to speak existed.

That in 2014 OCWEN in a consent ORDER was commanded to cease and desist all criminal activity and in return would
not be pressed with criminal charges. OCWEN did not follow the Consent Order and continues illegal foreclosures.

That on or around April 20, 2017 the CFPB filed a new suit in the USDC of Southern District of Florida West Palm
Beach Division Case No. 937-cv- 80495 which claims it has not stopped their criminal activities.

The CFPB has on its site:

COMPLAINTS:

Option One Showing 27,176 matches out of 1,744,719 total complaints

American Home Mortgage Servicing Showing 18,754 matches out of 1,744,719 total complaints
PHH Mortgage Showing 3,261 matches out of 1,744,719 total complaints
OCWEN Mortgage Showing 3 0,219 matches out of 1,744,719 total complaints
Wells Fargo Bank Showing 80,785 matches out of 1,744,719 total complaints
Bank of America Showing 119,746 matches out of 1,744,719 total complaints

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The CFPB further States:

Mortgage Servicer’s Widespread Errors, Shortcuts, and Runarounds Cost Borrowers Money,
Homes

APR 20, 2017

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today sued one of the country’s
largest nonbank mortgage loan servicers, Ocwen Financial Corporation, and its subsidiaries for failing
borrowers at every stage of the mortgage servicing process. The Bureau alleges that Ocwen’s years of
widespread errors, shortcuts, and runarounds cost some borrowers money and others their homes. Ocwen
allegedly botched basic functions like sending accurate monthly statements, properly crediting payments, and
handling taxes and insurance. Allegedly, Ocwen also illegally foreclosed on struggling borrowers, ignored
customer complaints, and sold off the servicing rights to loans without fully disclosing the mistakes it made in
borrowers’ records. The Florida Attorney General took a similar action against Ocwen today in a separate
lawsuit. Many state financial regulators are also independently issuing cease-and-desist and license revocation
orders against Ocwen for escrow management and licensing issues today.

"Ocwen has repeatedly made mistakes and taken shortcuts at every stage of the mortgage servicing process,
costing some consumers money and others their homes," said CFPB Director Richard Cordray. "Borrowers
have no say over who services their mortgage, so the Bureau will remain vigilant to ensure they get fair
treatment."

Ocwen, headquartered in West Palm Beach, Fla., is one of the nation’s largest nonbank mortgage servicers.
As of Dec. 31, 2016, Ocwen serviced almost 1.4 million loans with an aggregate unpaid principal balance of
$209 billion. It services loans for borrowers in all 50 states and the District of Columbia. A mortgage servicer
collects payments from the mortgage borrower and forwards those payments to the owner of the loan. It
handles customer service, collections, loan modifications, and foreclosures. Ocwen specializes in servicing
subprime or delinquent loans.

The CFPB uncovered substantial evidence that Ocwen has engaged in significant and systemic misconduct at
nearly every stage of the mortgage servicing process. The CFPB is charged with enforcing the Dodd-Frank
Wall Street Reform and Consumer Protection Act, which protects consumers from unfair, deceptive, or abusive
acts or practices, and other federal consumer financial laws. In addition, the Bureau adopted common-sense
rules for the mortgage servicing market that first took effect in January 2014. The CFPB’s mortgage servicing
rules require that servicers promptly credit payments and correct errors on request. The rules also include
strong protections for struggling homeowners, including those facing foreclosure. In its lawsuit, the CFPB
alleges that Ocwen:

● Serviced loans using error-riddled information: Ocwen uses a proprietary system called REALServicing
to process and apply borrower payments, communicate payment information to borrowers, and
maintain loan balance information. Ocwen allegedly loaded inaccurate and incomplete information into
its REALServicing system. And even when data was accurate, REALServicing generated errors
because of system failures and deficient programming. To manage this risk, Ocwen tried manual
workarounds, but they often failed to correct inaccuracies and produced still more errors. Ocwen then
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 used this faulty information to service borrowers’ loans. In 2014, Ocwen’s head of servicing described
its system as “ridiculous” and a “train wreck.”
● Illegally foreclosed on homeowners: Ocwen has long touted its ability to service and modify loans for
troubled borrowers. But allegedly, Ocwen has failed to deliver required foreclosure protections. As a
result, the Bureau alleges that Ocwen has wrongfully initiated foreclosure proceedings on at least 1,000
people, and has wrongfully held foreclosure sales. Among other illegal practices, Ocwen has initiated
the foreclosure process before completing a review of borrowers’ loss mitigation applications. In other
instances, Ocwen has asked borrowers to submit additional information within 30 days, but foreclosed
on the borrowers before the deadline. Ocwen has also foreclosed on borrowers who were fulfilling their
obligations under a loss mitigation agreement.
● Failed to credit borrowers’ payments: Ocwen has allegedly failed to appropriately credit payments
made by numerous borrowers. Ocwen has also failed to send borrowers accurate periodic statements
detailing the amount due, how payments were applied, total payments received, and other information.
Ocwen has also failed to correct billing and payment errors.
● Botched escrow accounts: Ocwen manages escrow accounts for over 75 percent of the loans it
services. Ocwen has allegedly botched basic tasks in managing these borrower accounts. Because of
system breakdowns and an over-reliance on manually entering information, Ocwen has allegedly failed
to conduct escrow analyses and sent some borrowers’ escrow statements late or not at all. Ocwen also
allegedly failed to properly account for and apply payments by borrowers to address escrow shortages,
such as changes in the account when property taxes go up. One result of this failure has been that
some borrowers have paid inaccurate amounts.
● Mishandled hazard insurance: If a servicer administers an escrow account for a borrower, a servicer
must make timely insurance and/or tax payments on behalf of the borrower. Ocwen, however, has
allegedly failed to make timely insurance payments to pay for borrowers’ home insurance premiums.
Ocwen’s failures led to the lapse of homeowners’ insurance coverage for more than 10,000 borrowers.
Some borrowers were pushed into force-placed insurance.
● Bungled borrowers’ private mortgage insurance: Ocwen allegedly failed to cancel borrowers’ private
mortgage insurance, or PMI, in a timely way, causing consumers to overpay. Generally, borrowers must
purchase PMI when they obtain a mortgage with a down payment of less than 20 percent, or when they
refinance their mortgage with less than 20 percent equity in their property. Servicers must end a
borrower’s requirement to pay PMI when the principal balance of the mortgage reaches 78 percent of
the property’s original value. Since 2014, Ocwen has failed to end borrowers’ PMI on time after learning
information in its REALServicing system was unreliable or missing altogether. Ocwen ultimately
overcharged borrowers about $1.2 million for PMI premiums, and refunded this money only after the
fact.
● Deceptively signed up and charged borrowers for add-on products: When servicing borrowers’
mortgage loans, Ocwen allegedly enrolled some consumers in add-on products through deceptive
solicitations and without their consent. Ocwen then billed and collected payments from these
consumers.
● Failed to assist heirs seeking foreclosure alternatives: Ocwen allegedly mishandled accounts for
successors-in-interest, or heirs, to a deceased borrower. These consumers included widows, children,
and other relatives. As a result, Ocwen failed to properly recognize individuals as heirs, and thereby
denied assistance to help avoid foreclosure. In some instances, Ocwen foreclosed on individuals who
may have been eligible to save these homes through a loan modification or other loss mitigation option.
● Failed to adequately investigate and respond to borrower complaints: If an error is made in the
servicing of a mortgage loan, a servicer must generally either correct the error identified by the
borrower, called a notice of error, or investigate the alleged error. Since 2014, Ocwen has allegedly
routinely failed to properly acknowledge and investigate complaints, or make necessary corrections.
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 Ocwen changed its policy in April 2015 to address the difficulty its call center had in recognizing and
escalating complaints, but these changes fell short. Under its new policy, borrowers still have to
complain at least five times in nine days before Ocwen automatically escalates their complaint to be
resolved. Since April 2015, Ocwen has received more than 580,000 notices of error and complaints
from more than 300,000 different borrowers.
● Failed to provide complete and accurate loan information to new servicers: Ocwen has allegedly failed
to include complete and accurate borrower information when it sold its rights to service thousands of
loans to new mortgage servicers. This has hampered the new servicers’ efforts to comply with laws and
investor guidelines.

The Bureau also alleges that Ocwen has failed to remediate borrowers for the harm it has caused, including
the problems it has created for struggling borrowers who were in default on their loans or who had filed for
bankruptcy. For these groups of borrowers, Ocwen’s servicing errors have been particularly costly.

Through its complaint, filed in federal district court for the Southern District of Florida, the CFPB seeks a court
order requiring Ocwen to follow mortgage servicing law, provide relief for consumers, and pay penalties. The
complaint is not a finding or ruling that the defendants have actually violated the law.
The lawsuit is available at:
https://files.consumerfinance.gov/f/documents/20170420_cfpb_Ocwen-Complaint.pdf

The CFPB has ignored the criminal activity of OCWEN / PHH Mortgage. That not only should a civil suit but a
criminal investigation from what the insiders have stated should be immediately filed

The defendant’s actions were Arbitrary and Capricious absent a rational connection between the facts found and the
choice’s made, made choices that were not in accordance with the law.

Count 11
Civil Conspiracy, Theft by deceptive taking Illegal Conversion of Real Estate

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The Collusion of the Defendants to prevent JWG from the chance at the HAMP refinance, of the loan for her company,
was done with malicious, violent, oppressive, fraudulent, wanton, or grossly reckless intentions.

Defendants Civil Conspiracy to Commit Tortious Interference with Contractual Relations abuse of process, intentional
infliction of emotional distress,

Civil conspiracy to commit injurious falsehood by advertising 15 West Spring St in the newspaper for a Foreclosure Sale
that violated the Law and Rules of HAMP. That Wells Fargo Bank has an alleged loan that Wells Fargo Bank denies.

That the foreclosure now leaves a cloud on the title for life.. One that was illegally, fraudulently offered for Sale by BWW
Law Group, MCW, PARKER, SIMON & KOKOLIS LLC, AND AKA Surety Trustees, and OCWEN. That the title is
riddled with defects from Judges, lawyers and Banks.

205. That the apparent Conversion would be for Personal Financial Gain of lawyers, Servicers that had no Bank Authority
to sell such property, and to COVER UP criminal activity as established in The 2013 – 2014 Consent Order by OCWEN
where it is called to Cease and Desist from criminal fraudulent violations by the CFPB.

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That all knowledgeable ACTS and ACTIONS by the Defendants and others were for deceptive, malicious acts for illegal
taking of Real Estate.

Defendants were in collusion of civil conspiracy to intentionally inflict emotional distress.

Count 12
18 U.S. Code § 666 – Theft or bribery concerning programs receiving Federal funds

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The clients of OCWEN Bank of America aka LaSalle Bank, Wells Fargo all received by appearance monies in bail outs,
while paying in the Billions to the DOJ for executives to not go to jail.

That indirectly or directly through clients have received Federal Funds by all appearances.

That payday’s to Lawyers are ensured prior to anyone else being paid in the scheme and 33 artifice of fraud on
homeowners as Lawyers and as Trustees

Count 13
Sarbanes – Oxley Act

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That OCWEN and their lawyers had a responsibility to act in a timely manner that information that Plaintiff has requested
since 2012 Plaintiff has still to this date not received.

The “Corporate and Auditing Accountability, Responsibility, and Transparency Act: that set new United States Federal
Law that expanded requirements for all U.S. Public company boards, management and public accounting firms. There are
also a number of provisions of the act that also apply to privately held companies.

That JWG believes under this act the accounting of OCWEN, Wells Fargo, Bank of America and others in this Complaint
failed.

That in or around Trust Assignment Fraud Letter to SEC , Posted on July 14, 2010 Which you can see nothing has
changed since her suit was won. That the allegations in this suit and the facts are no different than what was happening in
2010 –

1. OCWEN was Ordered to Cease and Desist in the 2014 Consent Order between OCWEN and the CFPB and 48
other States
2. CFPB in a new Suit against OCWEN alleges the same criminal behavior of FRAUD - WHEN DO THE JUDGES
STAND UP AND SPEAK OUT FOR THE AMERICAN CITIZEN? STOPPING THE ILLEGAL ACTS AND
ACTIONS OF THE SERVICERS, THE BANKS AND THE LAWYERS
3. The Banks were given Bail outs, the Servicers the opportunity to follow the law all have instead continued the
criminal activity, Frauds through today.

LYNN E. SZYMONIAK, ESQ.

The Metropolitan, PH2-05
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403 South Sapodilla Avenue
West Palm Beach, Florida 33401

April 15, 2010

Mary L. Schapiro, Chairman

Robert S. Khuzami, Director, Division of Enforcement
Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549
enforcement@sec.gov

Re: Mortgage-Backed Trusts Missing Critical Documents

Dear Chairman Schapiro and Director Khuzami:

This is a report of suspected fraud involving mortgage-back securities. Certain mortgage backed trusts have been
using forged and fraudulent mortgage assignments in foreclosure actions in Florida, and throughout the United States.
These assignments are most often produced by employees of Lender Processing Services, Inc., (“LPS”), a mortgage
default management company located in Jacksonville, FL. LPS produced several million Mortgage Assignments, using its
own employees to sign as if they were officers of the original lenders The fraud includes:

● Mortgage assignments with forged signatures of the individuals signing on behalf of the grantors, and
forged signatures of the witnesses and the notaries;
● Mortgage assignments with signatures of individuals signing as corporate officers for corporations that
never employed them in any such capacity;
● Mortgage assignments prepared and signed by individuals as corporate officers of mortgage companies
that had been dissolved by bankruptcy years prior to the Assignment;
● Mortgage assignments prepared with purported effective dates unrelated to the date of any actual or
attempted transfer (and in the case of trusts, years after the closing date of the trusts);
● Mortgage assignments prepared on behalf of grantors who had never themselves acquired ownership of the
mortgages and notes by a valid transfer, including numerous such assignments where the grantor was
identified as “Bogus Assignee for Intervening Assignments ;” and
● Mortgage assignments notarized by notaries who never witnessed the signatures that they notarized. Trust
officers used these fraudulent mortgage assignments to conceal the fact that the trusts are missing critical
documents, namely, the mortgage assignments that were supposed to have been delivered to the trusts at
the inception of the trust.

These trusts suffered the following economic harm:

The Trusts paid substantial fees to the Trustees for Document Custodial Services including fees for obtaining and retaining
a Mortgage Assignment for each of the properties in the trust. The Assignment was supposed to have been “in recordable
form” – that is, legally sufficient to allow the Trustee to foreclose in the event of default. These services were never
provided. In each trust identified herein, many if not all of the Mortgage Assignments were never obtained, or were
obtained and lost.

Because the Assignments were not obtained and/or retained, the Trusts incurred significant additional expenses:

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i) each Trust paid, and will continue to pay, hundreds of thousands of dollars in fees to mortgage servicers, document
preparation companies and law firms to prepare and record “Replacement Assignments” including Assignments that were
prepared with false information regarding dates and signers;

ii) each Trust paid, and will continue to pay, hundreds of thousands of dollars in fees to the default management company
and to law firms retained by the mortgage servicing companies and/or default management company (usually, Lender
Processing Services) to litigate the issue of the standing of the trust to file the foreclosure action because the Assignment
to the Trust that established standing was missing or never obtained. 35 In many cases, because the Assignments were not
obtained and/or retained, the Trust could not successfully foreclose when loans in the Trust defaulted.

In many cases, where the Trust has successfully foreclosed, it had no legal right to do so and the Trust has been or will be
exposed to claims for wrongful foreclosure by former homeowners and claims of fraud by subsequent purchasers. In many
cases, where mortgage servicing companies or law firms representing the Trust attempted to collect amounts due from
defaulting homeowners of properties in the trust, the debt collection activities violated the Federal Fair Debt Collection
Practices Act because the Trust had no right to pursue collection or foreclosure where it lacked a valid Assignment.

In many cases, particularly where the loan originator is a mortgage company that is no longer in existence, it may not be
possible to ever obtain a valid Assignment to the Trust. Long after the Trustees and Servicers became aware that critical
documents, the Assignments, were missing, the Trustees and Servicers failed to disclose that information to the Certificate
Holders and to the SEC.

Attached hereto are examples of fraudulent Assignments. Many (over 100,000) of these are signed by Linda Green.
From an examination of the signatures, it is apparent that many different employees signed the name Linda Green.
Job Titles attributed to Green include the following:

• Vice President, Loan Documentation, Wells Fargo Bank, N.A., successor by merger to Wells Fargo Home Mortgage,
Inc.;
• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for American Home Mortgage Acceptance,
Inc.;
• Vice President, American Home Mortgage Servicing as successor-in interest to Option One Mortgage Corporation; •
Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for American Brokers Conduit;
• Vice President & Asst. Secretary, American Home Mortgage Servicing, Inc., as servicer for Ameriquest Mortgage
Corporation; • Vice President, Option One Mortgage Corporation;
• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for HLB Mortgage;
• Vice President, American Home Mortgage Servicing, Inc.;
• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for Family Lending Services, Inc.;
• Vice President, American Home Mortgage Servicing, Inc. as successor-in-interest to Option One Mortgage Corporation;
• Vice President, Argent Mortgage Company, LLC by Citi Residential Lending Inc., attorney-in-fact; • Vice President,
Sand Canyon Corporation f/k/a Option One Mortgage Corporation;
• Vice President, Amtrust Funsing (sic) Services, Inc., by American Home Mortgage Servicing, Inc. as Attorney-in fact;
and
• Vice President, Seattle Mortgage Company.

Other LPS employees similarly used job many different job titles and claimed to be officers of many different mortgage
companies on Mortgage Assignments. Korell Harp and Tywanna Thomas used a variety of conflicting job titles on
Assignments of Mortgages in 2008 and 2009, holding themselves out to be officers of numerous different banks and
mortgage-related entities, often using numerous conflicting titles in the same week.

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Titles attributed to Korell Harp include Vice President of American Home Mortgage Servicing, Inc. as
successor-in-interest to Option One Mortgage Corporation; Vice President of American Brokers Conduit; Vice President
of Argent Mortgage Company, LLC; and Vice President of Mortgage Electronic Registration Systems, Inc. Titles
attributed to Tywanna Thomas include Assistant Vice President of Option One Mortgage Corporation, Assistant
Vice President of American Home Mortgage Servicing, Assistant Vice President of Mortgage Electronic Registration
Systems, Assistant vice President of Argent Mortgage Company, LLC, Assistant Vice President of Deutsche Bank
National Trust Company, Assistant Vice President of Sand Canyon Corporation and Assistant Vice President of American
Home Mortgage Acceptance.

Regarding the Attachments - Not attached for reference only

SECTION ONE – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE AMERICAN HOME
MORTGAGE ASSETS TRUSTS Section One includes Mortgage Assignments prepared by LPS EMPLOYEES
purporting to showing mortgages transferred to American Home Mortgage Assets Trusts

SECTION TWO – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE AMERICAN HOME
MORTGAGE INVESTMENT TRUSTS Section Two includes Mortgage Assignments prepared by LPS EMPLOYEES
purporting to showing mortgages transferred to American Home Mortgage Investment Trusts

SECTION THREE – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE HARBORVIEW

MORTGAGE LOAN TRUSTS Section Three includes Mortgage Assignments prepared by LPS EMPLOYEES
purporting to show mortgages transferred to HarborView Mortgage Loan Trusts

SECTION FOUR – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE SOUNDVIEW HOME
LOAN TRUSTS Section Four includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show
mortgages transferred to Soundview Home Loan Trusts

SECTION FIVE – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE AMERIQUEST MORTGAGE
SECURITIES TRUSTS Section Five includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show
mortgages transferred to Ameriquest Mortgage Securities Trusts

SECTION SIX – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE ARGENT SECURITIES
TRUSTS Section Six includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages
transferred to Argent Securities Trusts

SECTION SEVEN – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE GSAA HOME EQUITY
TRUSTS Section Seven includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages
transferred to GSAA Home Equity Loan Trusts

SECTION EIGHT – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE HS1 ASSET
SECURITIZATION TRUSTS Section Eight includes Mortgage Assignments prepared by LPS EMPLOYEES purporting
to show mortgages transferred to HS1 Asset Securitization Trusts

SECTION NINE – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE IXIS REAL ESTATE
TRUSTS Section Nine includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages
transferred to Ixis Real Estate Trusts

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SECTION 10 – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE LONG BEACH MORTGAGE
TRUSTS Section Ten includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages
transferred to Ameriquest Long Beach Mortgage Trusts

SECTION 11 – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE MORGAN STANLEY ABS
CAPITAL 1 TRUSTS Section Eleven includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to
show mortgages transferred to Morgan Stanley ABS Capital 1 Trusts

SECTION 12 – DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE NOVASTAR MORTGAGE

FUNDING TRUSTS Section Twelve includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show
mortgages transferred to Novastar Mortgage Funding Trusts

SECTION 13 – DEUTSCHE BANK NATIONAL TRUST CO. AS TRUSTEE SAXON ASSETS SECURITIES
TRUSTS Section Thirteen includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show
mortgages transferred to Saxon Assets Securities Trusts

SECTION 14 – DEUTSCHE BANK NATIONAL TRUST CO. AS TRUSTEE OTHER TRUSTS WITH MISSING
ASSIGNMENTS Section Fourteen includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show
mortgages transferred to WAMU 2005-AR2, QUEST 2005-X1

SECTION 15 – DEUTSCHE BANK TRUST CO. AMERICAS AS TRUSTEE MISCELLANEOUS TRUSTS Section
Fifteen includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages transferred to:
MSIX 2006-1, MORGAN STANLEY, MSAC, 2007-NC3, MSHEL 2007-1, MSHEL 2007-2, 2007-3, MERITAGE
2005-2, JP MORGAN ACQUISITION TRUST, IMAC SECURED ASSETS CORP, GSR MORT. LOAN TRUST, BCAP
LLC TRUST, CARRINGTON, SERIES 2005 OPT2

SECTION 16 – BANK OF NEW YORK AS TRUSTEE AMERICAN HOME MORTGAGE INVESTMENT TRUST
2004-4 Section Sixteen includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages
transferred to American Home Mortgage Investment Trust 2004-4.

SECTION 17 – CITIBANK, N.A. AS TRUSTEE AMERICAN HOME MORTGAGE ASSETS TRUSTS &
INVESTMENT TRUSTS Section Seventeen includes Mortgage Assignments prepared by LPS EMPLOYEES purporting
to show mortgages transferred to American Home Mortgage Assets Trusts.

SECTION 18 – CITIBANK, N.A. AS TRUSTEE BEAR STEARNS ALT-A TRUSTS Section Eighteen includes
Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages transferred to Bear Stearns ALT-A
Trusts

SECTION 19 – CITIBANK, N.A. AS TRUSTEE STRUCTURED ASSET MORTGAGE INVESTMENT TRUSTS

Section Nineteen includes Mortgage Assignments prepared by LPS Employees purporting to show mortgages transferred
to Structured Asset Mortgage Investment Trusts

SECTION 20 – CITIBANK, N.A. AS TRUSTEE WAMU TRUSTS & BNC MORTGAGE LOAN TRUST Section
Twenty includes Mortgage Assignments prepared by LPS Employees purporting to show mortgages transferred to WAMU
Trusts and BNC Mortgage Loan Trusts

SECTION 21 – HSBC BANK, N.A. AS TRUSTEE DEUTSCHE ALT-A & ALT-B SECURITIES TRUSTS Section
Twenty-One includes Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages transferred to
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Deutsche Alt-B Securities Mortgage Loan Trust, Series 2006- AB3; Deutsche Alt-A Securities Mortgage Loan Trust,
Series 2006-AR5

SECTION 22 – HSBC BANK, N.A. AS TRUSTEE ACE SECURITIES CORP. HOME EQUITY LOAN TRUST; SG
MORTGAGE SECURITIES TRUST, OPTION ONE MORTGAGE LOAN TRUST Section Twenty-Two includes
Mortgage Assignments prepared by LPS EMPLOYEES purporting to show mortgages transferred to ACE Securities
Corp. Home Equity Loan Trust, Series 2006- OP1; and SG Mortgage Securities Trust Series 2006 OPT2; and Option One
Mortgage Loan Trust Series 2007-HL1

SECTION 23 – JPMORGAN CHASE BANK, N.A. AS TRUSTEE STRUCTURED ASSET MORTGAGE

INVESTMENTS TRUST Section Twenty-Three includes Mortgage Assignments prepared by LPS EMPLOYEES
purporting to show mortgages transferred to Structured Asset Mortgage Investments II, Inc., Series 2006-AR5.

SECTION 24 – LASALLE BANK, N.A. AS TRUSTEE MORGAN STANLEY & BEAR STEARNS MORTGAGE
LOAN TRUSTS & OTHERS Section Twenty-Four includes Mortgage Assignments prepared by LPS Employees
purporting to show mortgages transferred to Morgan Stanley Mortgage Loan Trust 2006-6AR; Morgan Stanley ABS
Capital MSAC 2007-HE6; Bear Stearns Asset-Backed Securities 1, LLC, Series 2004-FR3; Series 2004-HE; 2005- HE9;
2006-HE2; 2006-HE7; 2007-HE1; Series 2007-HE5; Bear Stearns Asset-Backed Securities Trust 2005-4; Securitized
Asset Investment Loan Trust, Series 2004-7.

SECTION 25 – U.S. BANK, N.A. AS TRUSTEE MASTER TRUSTS Section Twenty-Five includes Mortgage
Assignments prepared by LPS Employees purporting to show mortgages transferred to MASTR Adjustable Rate
Mortgages Trust 2006-OA1; MASTR Adjustable Rate Mortgages Trust 2007-1; MASTR Asset-Backed Securities Trust
2007-HE2

SECTION 26 – U.S. BANK, N.A. AS TRUSTEE STRUCTURED ASSET INVESTMENT & STRUCTURED ASSET
SECURITIES TRUSTS Section Twenty-Six includes Mortgage Assignments prepared by LPS Employees purporting to
show mortgages transferred to Structured Asset Investment & Structured Asset Securities Trusts, including Series 2005-3,
2005-10, 2006 BNC2, 2006 BNC3 and 2006 BNC6

SECTION 27 – U.S. BANK, N.A. AS TRUSTEE MISC. OTHER TRUSTS Section Twenty-Seven includes Mortgage
Assignments prepared by LPS Employees purporting to show mortgages transferred to American Home Mortgage
Investment Trust 2005-4; and 6 GSAA Home Equity Trust 2006-9.

SECTION 28 – WELLS FARGO BANK AS TRUSTEE ABFC TRUSTS Section Twenty-Eight includes Mortgage
Assignments prepared by LPS Employees purporting to show mortgages transferred to several ABFC Trusts

SECTION 29 – WELLS FARGO BANK AS TRUSTEE MASTR ASSET-BACKED SECURITIES TRUSTS Section
Twenty-Nine includes Mortgage Assignments prepared by LPS Employees purporting to show mortgages transferred to
MASTR Asset-Backed Securities Trust 2003-OPT2 and 2005- OPT1

SECTION 30 – WELLS FARGO BANK AS TRUSTEE OPTION ONE MORTGAGE LOAN TRUSTS Section Thirty
includes Mortgage Assignments prepared by LPS Employees purporting to show mortgages transferred to over 25 Option
One Mortgage Loan Trusts

SECTION 31 – WELLS FARGO BANK AS TRUSTEE SECURITIZED ASSET-BACK SECURITIES and/or

RECEIVABLES TRUSTS Section Thirty-One includes Mortgage Assignments prepared by LPS Employees purporting to
show mortgages transferred to six Securitized Asset-Backed Receivables Trusts
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SECTION 32 – WELLS FARGO BANK AS TRUSTEE SOUNDVIEW HOME LOAN TRUSTS Section ThirtyTwo
includes Mortgage Assignments prepared by LPS Employees purporting to show mortgages transferred to four
SoundView Home Loan Trusts

SECTION 33 – WELLS FARGO BANK AS TRUSTEE MISC. OTHER TRUSTS Section Thirty-Three includes
Mortgage Assignments prepared by LPS Employees purporting to show mortgages transferred to other trusts that use U.S.
Bank at Trustee.

Thank you for your attention to this matter. While I am concerned about the defrauded investors, particularly the pension
funds that have invested in these trusts, I am also concerned about the homeowners who are losing their homes to
bank/trustees who use these Assignments without disclosing the issue of the missing Trust documents.

Yours truly,

Lynn E. Szymoniak, Esq.

That the above letter further points out and shows that this criminal activity has been going on for a long time.
That Banks, the Servicers and the Lawyers have been given chance after chance to clean up their act, but, find it cheaper
to pay off the Government, Government agencies who by all appearance take the money and pocket it for personal use.
Count 14
Title 26, U.S. Code. The Internal Revenue Code (IRC)
is the body of law that codifies all federal tax laws, including income, estate, gift, excise, alcohol, tobacco, and
employment taxes. U.S. tax laws began to be codified in 1874, but there was no central, comprehensive source for
them at that time

Material false claims under SEC enforced 1122 AB

26 U.S.C. § Section 61 A (1), 26 U.S.C. § Section 108 (i), 26 U.S.C. § Section 451, 26 U.S.C. § Section 1033, U.S.C
Section 1.751, CFR 1.752, SEC Rule 1122 AB
Regs. Sec. 1.707-3(b)(2) Disguised sales of property to partnership

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

CAUSES:

[1] Disguised Sale Rule under the IRC title 26 used in manipulative method and means for ill gotten gains

[2] Violations of the Federal rules on partnerships and pass through taxable income in a constructive liquidation

● where denying the pass through investor a proration distribution credited as a earn out over a set term
● The mortgagor is a pass through for the amounts booked at settlement and not disbursement
● Resulting in the attribution of ordinary and causal to compelled abandonment under tax payer form 1099
A

[3] Deceptive Practices that succeed by failing to properly disclose the correct character of the subject matter transaction.

● Whereas parties are foreclosing on the good faith understanding of default by mortgagor in default
● Wherefore the good faith understanding is lost under the doctrine of extinguishment
● Where by the instruments are cancelled for ORDINARY INCOME and title transferred under the the
instruments TRANSFER RIGHTS IN THE PROPERTY
127
 ● TRANSFER IS AFFIRMED at the origination the TRUSTEE sale whereby GRANTEE paid to TRUSTEE
CONSIDERATION
● The Consideration is for a credit back from date of the reversion [fictitious foreclosure ] backdating ot the
date of the orginal loans settlement

[4] For material violations by way of willful avoidance of a pass through right and entitlement to disclosures mandated by
assignment Pro Tanto

● Including life estate contracted by irrevocable transfers of the title for which the mortgagor is
TRANSFEROR under a QUALIFIED INVESTMENT
● Whereas the Qualified Property is by Transferors holding the reversion upon all properties having been
argued and amortized to a basis in asset of zero
● A sale for assets held in a constructive liquidation at zero is taxable to the attribution as 1099 A recipient
treated as ordinary at time of disposition .

[5] Material false claims under SEC enforced 1122 AB

● Government actor withheld as indispensable parties under the vendors understanding holding in 1122 AB
● Material false claims made under the FDCPA Federal debt collections practices act used for assessing
consumers in conventional foreclosures
● Using the state in the role of tax gather for the IRS to satisfy state budget liabilities

[6] Public sector entering the private side and violating the the taking provisions and "no capitation" guarantees afforded
on the fifth and fourteenth amendments

● DUE PROCESS denied where the trier of fact is a beneficial interest under a NOMINEE
● Whereas MERS conceals the government obligations owed to its depositors as Qualified Investments
● Wherefore the title secured Qualified deposits levered against the benefits payable to its state Municipal
Employees Retirement System.

[7] Violations of GAAP and Non Recognition Rules for final sale accounting rule barring a subsequent recovery on a
default using the accrual method of accounting.

● Whereas the consumer is a Mortgagor for a debt converted into a reversionary interest as equity and
● Lender , lender's successors and successor of lender are the seller for title transferred into trust to a third
party as trustee under the installment method.
● In violation of IRC Title 26 by tax matter partnerships to satisfy third party antecedent debt assigned to
mortgagors prorated shares of third party commercial obligations owed as "receivables to offshore
financial institutions.

That when OCWEN Fraudulently did the 1099, then sold the loan to NEWREZ LLC it violated § 1.707-3
Disguised sales of property to partnership; general rules.
Count 15
26 CFR § 1.707-3 - Disguised sales of property to partnership; general rules.
A disguised sale Regs. Sec. 1.707-3(b)(2)
JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

The partnership has incurred or is obligated to incur debt to acquire the money or other consideration necessary to permit
it to make the transfer, taking into account the likelihood that the partnership will be able to incur the debt (considering
such factors as whether any person has agreed to guarantee or otherwise assume personal responsibility for the debt);

128
The partnership holds money or other liquid assets, beyond the reasonable needs of the business, which are expected to be
available to make the transfer (taking into account the income that will be earned from those assets);

Partnership distributions, partnership allocations, or control of partnership operations is designed to effect an exchange of
the burdens and benefits of property ownership;

The transfer of money or other consideration by the partnership to the partner is disproportionately large in relationship to
the partner's general and continuing interest in partnership profits;or

The partner has no obligation to return or repay the money or other consideration to the partnership or has such an
obligation but it is likely to become due at such a distant point in the future that the present value of that obligation is
small in relation to the amount of money or other consideration transferred by the partnership to the partner.

Caution: Note that the disguised sale regulations apply to deemed sales from the partner to the partnership, from the
partnership to a partner, and among the partners.

KNOW A MORTGAGE FROM A DISGUISED SALE

The partnership has incurred or is obligated to incur debt to acquire the money or other consideration necessary to permit
it to make the transfer, taking into account the likelihood that the partnership will be able to incur the debt (considering
such factors as whether any person has agreed to guarantee or otherwise assume personal responsibility for the debt);

The partnership holds money or other liquid assets, beyond the reasonable needs of the business, which are expected to be
available to make the transfer (taking into account the income that will be earned from those assets);

Partnership distributions, partnership allocations, or control of partnership operations is designed to effect an exchange of
the burdens and benefits of property ownership;

The transfer of money or other consideration by the partnership to the partner is disproportionately large in relationship to
the partner's general and continuing interest in partnership profits;or
The partner has no obligation to return or repay the money or other consideration to the partnership or has such an
obligation but it is likely to become due at such a distant point in the future that the present value of that obligation is
small in relation to the amount of money or other consideration transferred by the partnership to the partner.

Caution: Note that the disguised sale regulations apply to deemed sales from the partner to the partnership, from the
partnership to a partner, and among the partners.

The following facts and circumstances may prove the existence of a disguised sale (Regs. Sec. 1.707-3(b)(2)):

● The timing and amount of a subsequent transfer are determinable with reasonable certainty at the time of the
earlier transfer;
● The transferor has a legally enforceable right to the subsequent transfer;
● The partner's right to receive the transfer of money or other consideration is secured in any manner (taking into
account the period during which it is secured);
● Any person has made or is legally obligated to make contributions to the partnership to permit the partnership to
make the transfer of money or other consideration;

129
 ● Any person has loaned or has agreed to loan the partnership the money or other consideration necessary to permit
it to make the transfers, taking into account whether any such lending obligation is subject to contingencies
related to the results of partnership operations;

Janice Wolk Grenadier has two issues a

Divorce without a Property Settlement and Illegal Foreclosure

That if Judge Padrick wants to call JWG names - he should know what JWG has been through. That the
above and the exhibits require the Judge and Lawyers to report the criminal activity against me.

That the acts and actions, what the documents state, what the Judges and Lawyers have said to me and
their criminal acts and actions. Janice Wolk Grenadier has been ruined. Do you want me to THANK
THEM or do I STAND UP and SPEAK OUT? Janice launched JudicialPedia.com and will continue to
fight for Justice. For MY Federal and Virginia Constitutional Rights to a FAIR TRIAL and JUSTICE.

I am willing to sit down and talk - but, the opposing side can’t do that. They can’t deal with Law and
the Constitution.

TROUTMAN PEPPER HAMILTON SANDERS1213

Lawyer Jim ARTHUR, SWINDLES

$30,000.00 THIRTY THOUSAND DOLLARS FROM JANICE WOLK GRENADIER IN THEIR

COVER-UP OF THEFTS/ EMBEZZLED / MONEY LAUNDERING / PENSION THEFT

Total Loss $2,484,119.00

FROM TRUST ACCOUNTS OF THE ELDERLY: KNOWN SONIA GRENADIER, William M. and Evelyn
GALVIN / Athena Associates Pension Fund, James R. RODES, Sr., Abbey J. MINTZ, Reginald H. ROBERTSON,
Nancy BRANDT, Fred BONNETT, Herbert BILLOWITZ
More Information can be Read at:
https://judicialpedia.com/listing/criminal-trust-theft-by-lawyer-jim-arthur-of-troutman-pepper-hamilton-sanders-a
ka-mays-valentine-cover-up-of-trust-theft-by-divorce-lawyer-ilona-ely-freedman-grenadier-heckman-of-sonia-gre
nadier/

Troutman Sanders has according to their website have 4 offices and 282 professionals closer han Virginia
Beach, yet the appearance is they bring an attorney that is good friends with the Judge 4 ½ hours to ensure a
win. This is the same in the Mary Jones case, Judge Padrick is friends of the opposing attorneys.
That Judge Padrick also made it clear is conversation with Judge Haddock prior to the past hearing. It has
now been disclosed to Judge Padrick in this document his LOVE LOVE LOVE for Ilona

12
Aka Mays & Valentine
13
https://judicialpedia.com/listing/criminal-trust-theft-by-lawyer-jim-arthur-of-troutman-pepper-hamilton-sanders-aka-mays-v
alentine-cover-up-of-trust-theft-by-divorce-lawyer-ilona-ely-freedman-grenadier-heckman-of-sonia-grenadier/
130
 ARGUMENT WHY JUDGE PADRICK SHOULD RECUSE

This RECUSE raises important questions about access to the judicial system for pro se litigants and
how a trial court must consider a pro se litigant’s good-faith attempt to cure perceived deficiencies in
complaints and how a pro se litigant is treated in the courtroom.

In this case, the court has denied Janice Wolk Grenadier's efforts to fix a deficiency denied her by the
Commissioners Hearing. If there was a deficiency as she was denied all Subpoenas. Several times this
court has rejected JWG efforts for Justice and a Fair hearing.

The right to discovery has been denied without any explanation. If the court rejects the complaint and a Trial
by Jury of the amended complaint it will be viewed as an abuse of discretion.

Importantly, the court disregarded its obligation under Foman v. Davis, 371 U.S. 178 (1962). There, the
Supreme Court instructed that the “outright refusal to grant the leave without any justifying reason appearing
for the denial is not an exercise of discretion; it is merely abuse of that discretion and inconsistent with the spirit
of the Court Rules.” Id. at 182.

It is Factual Troutman Pepper Hamilton Sanders shows up and STATES whatever it wants and you smile at
them and say Thank you.

Then as you did to Mary Jones, you treat me as a 2nd class citizen calling me names trying to Intimidate me.
For this reason is enough for you to have to recuse. Mary Jones transcript is attached in Exhibits.

Janice Wolk Grenadier engaged in a years-long effort to expose certain conduct that JWG sees as corruption
by the judiciary (Judges, Lawyers) and law enforcement.

JWG can identify personal and financial relationships that undermine the perception of judicial impartiality.

1. The monies Lawyer Grenadier and DiMure donated to the VSB and Judge Donald Haddock
2. The question comes how does the advertising of your Mediation on the Supreme Court site
3. Do you owe for the issue in 2013 when you were almost blocked from continuing as a Judge
4. Your conversation with Judge Haddock is the most disturbing and should be for you also after reading
his collusion to ensure that JWG was harmed
131
 5. The Fact you were chosen to silence me and Mary Jones

Judicial Canons and the Rules of Professional Conduct that have been Violated

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.”

A judge shall not allow family, social, political or other relationships to influence the judge's judicial conduct
or judgment. A judge shall not lend the prestige of judicial office to advance the private interests of the
judge or others; nor shall a judge convey or permit others to convey the impression that they are in a
special position to influence the judge. A judge shall not testify as a character witness.

CANONS OF JUDICIAL CONDUCT

Canon 1 A Judge shall uphold the integrity and independence of the judiciary.
Canon 2 A Judge shall avoid impropriety and the appearance of impropriety in all of the Judge’s activities.
Canon 3 A Judge shall perform the duties of judicial office impartially and diligently.

Disciplinary Responsibilities:

● A judge who receives reliable information indicating a substantial likelihood that another judge has
committed a violation of the Judicial Canons should take appropriate action. A judge having knowledge
that another judge has committed a violation of these Canons that raises a substantial question as to
the other judge's fitness for office should inform the Judicial Inquiry and Review Commission.

● A judge who receives reliable information indicating a substantial likelihood that a lawyer has
committed a violation of the Code of Professional Responsibility should take appropriate action.
A judge having knowledge that a lawyer has committed a violation of the Code of Professional

132
 Responsibility that raises a substantial question as to the lawyer's honesty, trustworthiness or fitness as
a lawyer in other respects should inform the Virginia State Bar.

● The legal profession is largely self-governing. Although other professions also have been
granted powers of self-government, the legal profession is unique in this respect because of the
close relationship between the profession and the processes of government and law
enforcement. This connection is manifested in the fact that ultimate authority over the legal
profession is vested largely in the courts.

You can’t change the Truth - The Truth is the actions of the Judges, Under Illinois and Federal law, when
any officer of the court has committed “fraud upon the court”, the orders and judgment of that court are
void, of no legal force or effect.” “Citation: 93F. 2d 313 (2d Cir. 1937) Any judgment procured by fraud is
null and void. An erroneous judgment may be attacked collaterally. Affirmed”
All Judges in Virginia also have a BAR License and must follow the Professional Code of Ethics

Bar Admission And Disciplinary Matters

An applicant for admission to the bar, or a lawyer already admitted to the bar, in connection with a bar
admission application, any certification required to be filed as a condition of maintaining or renewing a license
to practice law, or in connection with a disciplinary matter, shall not:

(a) knowingly make a false statement of material fact;

(b) fail to disclose a fact necessary to correct a misapprehension known by the person to have arisen in the
matter;
(c) fail to respond to a lawful demand for information from an admissions or disciplinary authority, except that
this Rule does not require disclosure of information otherwise protected by Rule 1.6; or
(d) obstruct a lawful investigation by an admissions or disciplinary authority.

Rule 8. 2 Judicial Officials

A lawyer shall not make a statement that the lawyer knows to be false or with reckless disregard as to
its truth or falsity concerning the qualifications or integrity of a judge or other judicial officer.

[1] False statements by a lawyer concerning the qualifications or integrity of a judge can unfairly undermine
public confidence in the administration of justice. To maintain the fair and independent administration of justice,
lawyers are encouraged to continue traditional efforts to defend judges and courts unjustly criticized.

Rule 8. 3 REPORTING MISCONDUCT

a) A lawyer having reliable information that another lawyer has committed a violation of the Rules of
Professional Conduct that raises a substantial question as to that lawyer's honesty, trustworthiness or
fitness to practice law shall inform the appropriate professional authority. (b) A lawyer having
reliable information that a judge has committed a violation of applicable rules of judicial conduct that
raises a substantial question as to the judge's fitness for office shall inform the appropriate authority.

(c) If a lawyer serving as a third party neutral receives reliable information during the dispute
resolution process that another lawyer has engaged in misconduct which the lawyer would otherwise
be required to report but for its confidential nature, the lawyer shall attempt to obtain the parties'

133
written agreement to waive confidentiality and permit disclosure of such information to the appropriate
professional authority.

(d) This Rule does not require disclosure of information otherwise protected by Rule 1.6 or information
gained by a lawyer or judge who is a member of an approved lawyer's assistance program, or who is a
trained intervenor or volunteer for such a program or committee, or who is otherwise cooperating in a
particular assistance effort, when such information is obtained for the purposes of fulfilling the
recognized objectives of the program.

(e) A lawyer shall inform the Virginia State Bar if:

(1) the lawyer has been disciplined by a state or federal disciplinary authority, agency or court in any
state, U.S. territory, or the District of Columbia, for a violation of rules of professional conduct in that
jurisdiction;

(2) the lawyer has been convicted of a felony in a state, U.S. territory, District of Columbia, or federal
court ;

(3) the lawyer has been convicted of either a crime involving theft, fraud, extortion, bribery or perjury,
or an attempt, solicitation or conspiracy to commit any of the foregoing offenses, in a state, U.S.
territory, District of Columbia, or federal court.

The reporting required by paragraph (e) of this Rule shall be made in writing to the Clerk of the
Disciplinary System of the Virginia State Bar not later than 60 days following entry of any final order or
judgment of conviction or discipline.

Rule 8.4 Misconduct

It is professional misconduct for a lawyer to:

(a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another
to do so, or do so through the acts of another;

(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

134
(e) knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of
judicial conduct or other law.

Rule 8.5 Disciplinary Authority; Choice Of Law

(a) Disciplinary Authority. A lawyer admitted to practice in this jurisdiction is subject to the disciplinary
authority of Virginia, regardless of where the lawyer's conduct occurs. A lawyer not admitted in
Virginia is also subject to the disciplinary authority of Virginia if the lawyer provides, holds himself out
as providing, or offers to provide legal services in Virginia. By doing so, such lawyer consents to the
appointment of the Clerk of the Supreme Court of Virginia as his or her agent for purposes of notices
of any disciplinary action by the Virginia State Bar. A lawyer may be subject for the same conduct to
the disciplinary authority of Virginia and any other jurisdiction where the lawyer is admitted.

(b) Choice of Law. In any exercise of the disciplinary authority of Virginia, the rules of professional
conduct to be applied shall be as follows:

○ (1) for conduct in connection with a proceeding in a court, agency, or other tribunal
before which a lawyer appears, the rules to be applied shall be the rules of the
jurisdiction in which the court, agency, or other tribunal sits, unless the rules of the
court, agency, or other tribunal provide otherwise;
○ (2) for any other conduct, the rules of the jurisdiction in which the lawyer’s conduct
occurred; and

○ (3) notwithstanding subparagraphs (b)(1) and (b)(2), for conduct in the course of
providing, holding out as providing, or offering to provide legal services in Virginia,
the Virginia Rules of Professional Conduct shall apply

That Plaintiff as a ProSe litigant has done her best to learn the rules and follow the Law, follow the Rules to be
Discriminated by all Defendant. The Judicial system has an “incestuous” relationship that has created a
“privileged class”, a violation of Blind / Equal Justice for all.

The Corruption in the Virginia Courts starts with the Top Court, the Supreme Court of Virginia that is backed by
the Courts of Justice in the Virginia Legislature. Then trickles down to the Court of Appeals, the Circuit Courts
and the General Districts.

The Virginia State BAR, the ‘JIRC” Judicial Inquiry and Review Commission. In a 20 year study it shows that
there are no consequences for Judges who ignore the Canons.

Justice Donald Lemons has chosen Ret Judge H. Thomas Padrick for the Mary Jones Case and Janice Wolk
Grenadier cases, to ensure “Friends of the Court “ are allowed to steal everything from us,

135
That the Judges H. Thomas Padrick appears to have a working and possible close relationship with Chief Justice
Donald Lemons and the Supreme Court.

That this court and these Judges have acted in extrinsic Fraud on the Court. “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.” “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 court
and 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)”
Defendants are attorneys officers of the court who have been allowed to ignore the law and rules of the Supreme
Court of the United States of America “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)”
“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
judge should ever rule by Favoritism and Cronyism for the sake of Personal Retaliation and Retribution. Loving
v. Virginia, 388 U.S. 1 (1967) was a landmark civil rights decision of the United States Supreme Court against
discrimination. Which includes being discriminated against because the Judge’s, lawyers, elected officials and
government employees have decided you are not a part of their race or social hierarchy. That the discrimination
and segregation among white exist the power Hierarchy by a member of one that is considered by others
inferior to the other.

Justice is supposed to be blind. In Bullock 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." But not only are trial
judges required to be fair and impartial, they must also 'satisfy’ the appearance of justice and this includes all
Defendants. The trial judge's 'appearance,' or conduct and behavior, appearance of bias alone is grounds for
reversal even if the trial judge is, in fact, completely impartial. “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),

“If two or more persons conspire to injure, oppress, threaten or intimidate any person in any State Territory,
Commonwealth, or District in the free exercise of enjoyment of any right or privilege secured to him by
the Constitution or laws of the United States

The Collusion of the Defendants actions show collusion to harm Plaintiff and was done with malicious,
violent, oppressive, fraudulent, wanton, or grossly reckless intentions. Defendants Civil Conspiracy to
Commit Tortious Interference with Contractual Relations abuse of process, intentional infliction of emotional
distress, Civil conspiracy to commit injurious falsehood with jwgrenadierisalair.blogspot.com that Plaintiff has
136
a “protected characteristic” which will be proven as to why Plaintiff was sought out by Defendant and that
factor is why Plaintiff was targeted by Defendants to deny any rights to protect the Criminal Spree of Divorce
Lawyer Ilona Grenadier Heckman Defendants were in collusion of civil conspiracy to intentionally inflict
emotional distress.

It is illegal for two or more persons (ie; court officers or any defendant)to conspire for the purpose of
impeding, hindering, obstructing, or defeating in any manner, the due course of justice in any State or Territory,
with intent to deny to any citizen the equal protection of the laws, or to injure him or his property for lawfully
enforcing, or attempting to enforce, the right of any person, or class of persons, to the equal protection of the
laws... Griffin v. Breckenridge, 403 U.S. 88, 102, 91 S.Ct. 1790, 1798, 29 L.Ed.2d 338 (1971) and 42 U.S.C.
Sec. 1985(2) (1976). Also See Kush v. Rutledge, U.S. 103 S.Ct. 1483, 1485, 75 L.Ed.2d 413 (1983).

A Pro Se Litigant

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)”

Relief Requested

1. Judge Thomas Padrick to recuse and a Judge actively engaged in a court, not a retired Judge who has
close ties to the Old Boys Network be chosen.
2. That Justice Donald Lemons who has by all appearance empowered the corruption recuse himself in
choosing a Judge and one of arm's length choose a Judge .
3. VACATE all ORDERS FOR CASES CW1800 1465 and CL 1800-1733 due to the Argument set forth as
to why Judge Thomas Pardrick was chosen and his relationship with Judge Donald Haddock.
137
 4. That the Judge looks at the FACT Troutman Pepper Hamelton Sanders states Wells Fargo Bank
Foreclosed on this home - THERE are PHONE CALLS, WELLS FARGO has filed in the court and
done a NOTARIZED LETTER that they had nothing to do with a loan on Spring St. Brock & Scott were
told by OCWEN not to foreclose.. The Commissioner of Accounts ignored all this information for
FRIENDSHIP.

​Dear Heavenly Father,

I come before You in Jesus' name. Father, thank You for seeing everything that is going on in my life.
Thank You for always taking care of me. I know You have a good plan for my life, and You have
promised that all things will work together for my good because I love You and am called according to
Your purpose.
Father, You see what's going on in my life. You see ___the acts and actions of Judge and
Lawyers________, and You see that this is unjust. And Father, righteousness and justice are the
foundation of Your throne.
So Father, because You are righteous and just, I know that You are ready to move on my behalf. I
believe that You are ready to reverse this situation for me according to Your Word.
So, Father, I ask in Jesus' name first that You, the God of all comfort, would comfort me during this
season.
I charge the angels of God to minister to me right now in Jesus’ name. I bind away every lie, plot, and
trick of the enemy off of my life and I lose healing, wholeness, life, truth, and holy vindication into my
life.
I speak to the hidden things the Father desires to reveal, and I command them to be revealed right now
in Jesus’ name. I decree the light of the Holy Spirit must shine into this situation right now.
I​ decree divine reversal for the cause of righteousness, truth, and justice right now in Jesus’ name. I
decree that no weapon formed against me shall prosper, and every tongue that rises against me in
judgment I shall condemn. This is my heritage, for I am a servant of the Lord. My righteousness is of
the Lord.
I decree that nothing shall in any way harm me or my family.
I decree in the name of Jesus that the enemy may come against me one way, but he’ll flee before me
seven ways. I decree that this giant must fall right now in Jesus’ name and that this situation works out
for my good.
I call forth promotion for myself because of this fight. I decree that this situation will result in blessing
AND INCREASE for me in Jesus’ Name.
A men

I, Janice Wolk Grenadier, Plaintiff in this action. I personally set forth the allegations of fact and I hereby
declare under penalty of perjury that each of said allegations is true and correct to the best of my knowledge

138
Respectfully submitted
April 5, 2021
/s/ Janice Wolk Grenadier
Janice Wolk Grenadier
15 W. Spring St.
Alexandria, VA 22301
202-368-7178
jwgrenadier@gmail.com
That a copy on or around April 5, 2021 has been electronically (email) to the court and or through
USPS mail been sent to.
WELLS FARGO NATIONAL
ASSOCIATION, as
Trustee for Option One Mortgage
Loan Trust 2005-2, Asset- Backed
Certificates, Series 2005-2
420 Montgomery Street
San Francisco, CA 94104
888-878-5865
CEO Charles W. Scharf
WELLS FARGO N.A.
420 Montgomery Street,
San Francisco, CA 94104
BANK OF AMERICA, f/k/a -
as successor-in-interest to
LaSALLE BANK,
100 North Tryon Street,
Charlotte, NC 28255.
704-386-5681
OCWEN LOAN SERVICING LLC
aka PHH aka OCWEN
MORTGAGE SERVICING, INC.
1661 Worthington Road #100
West Palm Beach, Fl 22409
(877) 226-2936
New Residential Investments
1345 Ave of the Americas
45th Floor
New York, NY 10105
Tel: 212-479-3150
ir@newresi.com
Certificate of Service
NewRez LLC
6250 Old Dobbin Ln Suite 100,
Columbia, MD 21045
(888) 673-5521
TROUTMAN SANDERS LLP
401 9th Street, N.W. Ste 1000
Washington DC 20004
S. Mohsin Reza
TROUTMAN SANDERS LLP
401 9th Street, N. W. ste 1000
Washington, D.C. 20004
mohsin.reza@troutman.com
202-274-1927
Judge Donald R Alexander
Fla BAR # 1079
PO Box 15164,
Tallahassee, FL 32317-5164
Office: 850-488-9675
xyzauh@gmail.com
Trustee Services Of Virginia,
LLC.
484 Viking Drive, Suite #203
Virginia Beach, Virginia 23452
Brock & Scott, PLLC
484 Viking Drive, Suite 3
Virginia Beach VA 23452
Brian Campbell
Brock & Scott, PLLC
5431 Oleander Drive
Wilmington, NC 28403
Ph : 910-392-4988 x1206
Brian.Campbell@brockandscott.co
m
BWW Law Group aka
BIERMAN, GEESING, WARD &
Wood, LLC.
2101 Wilson Boulevard 402
Arlington, VA 22201
Phone: (703) 243-5903
howie.bierman@bww-law.com
EQUITY TRUSTEES, LLC
2101 Wilson Boulevard 402
Arlington, VA 22201
Phone: (703) 243-5903
Howard Norman Bierman
Partner BWW Law Group
Equity Trustees, LLC
2101 Wilson Boulevard 402
Arlington, VA 22201
Phone: (703) 243-5903
McCabe Weisberg Conway LLC
aka Surety Trustees LLC
1727 KING STREET, SUITE 318,
ALEXANDRIA, VA, 22314
571-449-9350
Surety Trustees LLC
aka McCabe Weisberg Conway
LLC
139
1727 KING STREET, SUITE 318,
ALEXANDRIA, VA, 22314
Abby Moynihan
McCabe Weisberg Conway LLC
aka Surety Trustees LLC
April 5, 2021
/s/ Janice Wolk Grenadier
Janice Wolk Grenadier
1727 KING STREET, SUITE 318,
ALEXANDRIA, VA, 22314
amoynihan@mwc-law.com
AG Mark Herring
Attorney General's Office
202 North Ninth Street
Richmond, Virginia 23219
Phone: (804) 786-2071
Consumer Financial Protection
Bureau / CFPB
1700 G St NW
Washington, DC 20552
140