David Grenadier

The full document with pictures can be seen at - http://www.scribd.com/doc/168700493/Divorce-Response-Final-Final-to-Interven-of-Grenadier-Sept-16-2013

VIRGINIA:

IN THE CIRCUIT COUR OF THE CITY OF ALEXANDRIA

JANICE WOLK GRENADIER

Plaintiff CH. NO. 99-1253

Vs. Response to Ilona to Intervene

DAVID MARK GREANDIER

Defendant

PLAINTIFF’S RESPONSE TO: The Grenadier Parties request to INTERVENE to protect their interest and file this OPPOSITION TO PLAINTIFF’S

Motion to Compel – The Production of Documents filed against Katz & Co.

Ilona * Grenadier Law Firm et al * Jerome Heckman * Keller Heckman * David Grenadier – “The Grenadier Parties”

GUILTY IS WHAT THIS INTERVEN SAYS ABOUT “THE GRENADIER PARTIES”

GUILTY AFRAID OF THE WHOLE TRUTH COMEING OUT

GUILTY THE DOCUMENTS REQUESTED WILL FURTHER PROVE THE FOLLOWING:

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. The Victims:

Janice Wolk Grenadier (Plaintiff) the day Ilona informed her she had come up with the solution to the money being stolen out of the Sonia Grenadier Trust to keep Defendant from going to jail and being raped, that Plaintiff needed to assign her $30,000 commission & Ilona would have Defendant sign a note for it – at 10% interest due in 30 years, Ilona forgot to ask how the baby was doing who was born with heart issues - * RIP - Herman, Sonia, Albert, Ruth Grenadier Family *the Girls * Sonia w/ the girls * Judge Albert Grenadier RIP

Defendant & Ilona “the Grenadier parties” owes Janice over $ 4 million dollars, without Punitive & exemplary damages for the malice; intend to harm, et al Janice and her daughters physically and personally for THEIR own financial gain. Ilona “The Grenadier Parties” is receiving an est. of $150,000 a month in Rental Income and has an est. of over $20 Million in Real Estate – THANKS TO –

the Sonia Grenadier Trust, Ruth Grenadier, Janice Wolk Grenadier

COME NOW – Ilona Grenadier Heckman, her law firm Grenadier, Anderson, Starace, Duffett & Keisler, the estate of Jerome Heckman (Lawyer and founding partner of Keller Heckman an International law firm) and Grenadier Investment Co. (“the Grenadier Parties”) inserting herself et al into this Divorce case further shows the involvement AND GUILT from day one of the collusion with Defendant. Which will be proven through legal documents, wills, that Ilona had amble opportunity to address any information prior to these claims to inform Plaintiff of any information that might have prevented this action.

The question once again is presented is Ben DiMuro and all his and his law firms representation “VOID” due to representing the interest of Plaintiff and her husband Defendant David back in 1990. On Monday April 9, 1990 Mr. Dimuro met with David Grenadier and Plaintiff regarding a fire at Monroe Ave. At his law office at 921 King St, Alexandria, Va. 22314. The following week there was another meeting with Mr. Dimuro. Plaintiff was married to Defendant at the time he was involved with representing the partnership, in a wrongful death suit against the Monroe Ave Partnership that GIC owned 50% of. Which David Grenadier owned 49%. Which Plaintiff now claims 24.5% of property due to Fraud and co-mingling of funds during her marriage to David Grenadier? This has on several occasions been brought to the attention of Mr. DiMuro and ignored by him and his law firm. The law is very clear on conflict of interest, aiding and abetting obstruction of Justice, and misuse of power/friendships in a Conflict of Interest, ex-parte communications, Fraud on the Court, Filing disingenuous documents with the courts, Rules of Professional contact and other illegal and unprofessional actions of a lawyer.

To address the Motion and what Mr. DiMuro and Ilona “the Grenadier Parties” say is law:

That Plaintiff is not allowed to file a Subpoena as she is pro se and in the State of Virginia only a lawyer can file and serve a subpoena is so ludicrous to even have to address such a statement should make everyone question the integrity and the knowledge of the law and our Constitution of the United States of America. While DiMuroGinsberg and Michael Weiser were spending all there time in either ex-parte communications with the Judge’s or with each other in a past case shows there intent on aiding and abetting the Judge’s in actions that are criminal and illegal outside their job acting as Judges – and Blind Justice. That in or around September of 2012 Plaintiff filed a similar Subpoena for Ilona of the “Grenadier Parties” to be in court. Neither party objected to the Subpoena saying Plaintiff could not file a subpoena per Virginia Law. A little legal fact: Federal Law over rides State Law, The Constitution over rides all laws that Plaintiff has the same rights as all attorneys acting pro se.

The Defendant and his attorney were notified of Plaintiffs intention’s to re-open the Divorce action through e-mail and telephone calls:

JW Grenadier <jwgrenadier@gmail.com>

Jun 26

to LMManitta, David

Ms Manitta,

I am contacting you to see if you are still representing David Grenadier in his divorce issues.

Warmly,

JW Grenadier

202-368-7178

JW Grenadier <jwgrenadier@gmail.com>

Jul 12

to LMManitta, David

I have attached a Subpoena I have filed today and will be filing other documents next week.

I contacted you to confirm you are going to be representing David along with phone calls to you. To this date I have had no response from you or David.

Any Questions you may have please let me know -

Warmly,

The Facts:

1. On or around June 26, 2013 through e-mail and phone messages Plaintiff tried to contact Defendant’s lawyer and was ignored

2. On or around July 12, 2013 Subpoena was filed in the COA Clerks office w/cert of service to Defendants

3. On or around July 15, 2013 Yoav Katz / Katz & Co. was properly served w/cert of service to Defendants

4. On or around July 16, 2013 an Affidavit of service was filed in COA w/ cert of service to Defendants

5. On or around Aug 19, 2013 a Motion to Compel was filed in the COA w/cert of service to Defendants

6. On or around Aug 19, 2013 Plaintiff filed for Production of Documents

7. On or around Aug 26, 2013 Defendant decided to Respond approx. 60 days later

The Defendant ignored with his lawyer all opportunities to object to 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. This should put to rest the argument that the Judge Clark’s ruling in any other case has any connection to Plaintiff’s Divorce.

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)”

The Question is why does Ilona “The Grenadier Parties” want to intervene? What Truths are they afraid of coming out? We shall go with some known Facts and New Evidence Plaintiff has:

1. New evidence as of 2013 will show in the estimated time period of 1984 - 1986 by all appearance Ilona “The Grenadier Parties” stole not only the property known as Bristow but, the money from the selloff of some of the land for approx $81,000., $200,000 & $521,000. Which would have belonged to the Sonia Grenadier Trust. Still owning part of the land it is understood it was Ilona who turned down two (2) - $10 million contracts, one that then came back after a lengthy study period and lowered their offer to approx. $7.5 million. The exposure of her illegal actions a few months ago her view from what I understand is to sell it for $1.7 million now. The research in the documents never shows her the right to any of the funds on the sale. That all funds should have gone into the Sonia Grenadier Trust. Harassing and inappropriate e-mails filed with this court shows the collusion of Ilona, the extend she will go to try and cover up her manipulation, thefts and disingenuous behavior as a lawyer. The Bristow property owned 45% Grenadier and 55% other by all appearance.

2. The new evidence is important because Ilona received this money illegally in or around February of 1986. It was in October of 1986 that the funds were borrowed from Plaintiff as Defendant claimed Ilona, GIC, himself did not have the money to purchase the Bellefonte property and they wanted Plaintiff as a partner – and then borrowed the money from Plaintiff.

3. The new evidence from the information Yoav Katz / Katz & Co. will also show that Ilona “The Grenadier Parties” intent on Tax Evasion. That the partnership of 49% and 51% was not how the tax losses most years were divided. That cash under the table to Defendant was given so Ilona “the Grenadier Parties” could use the tax losses. Which would have been through Yoav Katz / Katz & Co. collusion to deceive the IRS.

26 USC § 7201 - Attempt to evade or defeat tax Any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof shall, in addition to other penalties provided by law, be guilty of a felony and, upon conviction thereof, shall be fined not more than $100,000 ($500,000 in the case of a corporation), or imprisoned not more than 5 years, or both, together with the costs of prosecution.

4. The Slippery slope and the collusion of Ilona “The Grenadiers Parties” and the defendant's willful acts that were and still are malicious, violent, oppressive, fraudulent, wanton, or grossly reckless towards Plaintiff and her girls. Started that October 1986 and will be shown how they continue till today September 16, 2013.

5. The tax returns and other information that is known that Yoav Katz / Katz & Co have will further back up and show what monies where Stolen from the Sonia Grenadier Trust – and the Grenadier Family through the Ilona “The Grenadier Parties” that Plaintiff was the only one to pay back any of these funds through the malicious, violent, oppressive, fraudulent, wanton, or grossly reckless manipulation of Plaintiff from October of 1986.

§ 18.2-498.3. Misrepresentations prohibited.

Any person, in any commercial dealing in any matter within the jurisdiction of any department or agency of the Commonwealth of Virginia, or any local government within the Commonwealth or any department or agency thereof, who knowingly falsifies, conceals, misleads, or covers up by any trick, scheme, or device a material fact, or makes any false, fictitious or fraudulent statements or representations, or makes or uses any false writing or document knowing the same to contain any false, fictitious or fraudulent statement or entry, shall be guilty of a Class 6 felony.

6. That Ilona acting as Plaintiff’s attorney was acting in her (Ilona “The Grenadier Parties”) best interest to protect herself and her greed, her deceptive practices with the IRS in tax evasion.

7. The tax returns will further show the deceit with the property known as 314 A East Cutis Ave.

8. The tax returns will further show that Ilona being involved in a Forged Addendum to a Trust agreement and the use of the forged agreement to donate property belonging to the Sonia Grenadier Trust from King David.

9. The information from Yoav Katz is needed for Plaintiff in her claim against GIC/Defendant as Ilona split the partnership using a lawyer not licensed in Virginia to do business and without the consent of Plaintiff who at the time was Defendant’s wife and had her funds used to purchase properties owned by GIC, ignoring Plaintiff’s rights to them, as an attorney she knew Plaintiff had rights to such properties. This is also evidence. The split of Partnership did not hold up with Virginia Attorneys & the Bank Rup Court.

Wherefore if Ilona Ely Grenadier Heckman “The Grenadier Parties” wish to intervene that then they will come under the same admissions and discovery rules and laws as Defendant. That Ilona “The Grenadier Parties” will be held accountable for all expenses for their intervention. That they will be responsible for all Plaintiffs’ legal fees for legal representation against them and the attorneys they will be using to intervene. That the intervention puts Plaintiff on an uneven playing field, so the only way they should be allowed to Intervene is with covering the cost of Plaintiff getting a lawyer to represent Plaintiff and all expenses.

The Plaintiff seeks an award of sanctions.

September 16, 2013

Janice Wolk Grenadier

15 West Spring Street

Alexandria, Virginia 22301

jwgrenadier@gmail.com

202-368-7178

Certificate of Service

I hereby Certify that a true copy of the following was e-mailed and Hand Delivered to Defendants Counsel Lana Manitta of LMManitta@rrbmdk.com, Rich RosenthalBrincefield Manitta Dzubin & Kroeger, LLP - 201 North Union Street, Suite 230, Alexandria, VA 22314 - Phone: 703.299.3440. and to Ben DiMuro DiMuroGinsberg 1101 King Street, Suite 610 Alexandria, Va 22314, 703-684-4333.

September 16, 2013

Janice Wolk Grenadier

VIRGINIA

IN THE CIRCUIT COURT OF the cITY OF aLEXANDRIA

IN THE MATTER OF:

jANICE wOLK gRENAIDER

Case # CH991234

PLANTIFf

vs.

DAVID MARK GRENADIER

DEFENDANTS.

1. Motion for the Circuit Court Judges Kemler, Dawkins and Clark to recuse themselves following the directions of the law under Virginia Supreme Court Rule 17.1 -105 (b)

2. Motion for Property Settlement Agreement in the Divorce between Plaintiff and Defendant as Defendant has acted in a Fraudulent Manor since October of 1985 – New evidence a in recent weeks supports this

3. Motion Demand Trial by Jury and Change of Venue

1. COMES NOW PLAINTIFF requests under the law that the presiding Judges, Kemler, Dawkins and Clark file the appropriate paper work under 17. 1- 105(b) to recuse themselves from hearing any Motions or Trial on this case. The attached letter dated July 14, 2013 states the Plaintiff is in the process of filing suit against above judges and clerk of court for their actions. The suit will be filed in Federal Court under 42 United States Code standards 1983. This suit asks for Relief of all orders made in violation of the Law that Due Process of Law is allowed and further issue relief as the court deems appropriate.

While a Judge performing Judicial functions may enjoy Immunity, denial of constitutional and civil rights are absolutely not a judicial function and conflicts with any definition of a Judicial function.

17.1-105 B. 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.

2. COMES NOW PLAINTIFF requests that a trial date be set with a demand for Jury for plaintiff to present that there was no property settlement on the grounds of fraud by Defendant. With respect to the conduct that constitutes fraud, Delaware's high court held that these showings were required: Plaintiff will show (1) false representation, of facts, made by the defendant; (2) that defendant's knowledge, was that the representation was false and was made with reckless indifference to the truth; and (3) was done with purpose and an intent to induce the plaintiff to act or refrain from acting. Schmeusser v. Schmeusser , 559 A.2d 1294 (Del. 1989). E.g., Billington v. Billington , 220 Conn. 212, 595 A.2d 1377 (1991) Plaintiff will show that (1) false representation was made as a statement of fact; (2) that statements was untrue and was known to be so by Defendant; (3) that statements were made with the intent of inducing reliance); Despain v. Despain , 855 P.2d 254 (Utah Ct. App. 1993) Plaintiff will prove (1) that a representation was made, (2) concerning a presently existing material fact, (3) which was false, (4) which the Defendant (a) knew to be false and (b) made recklessly, knowing that he had sufficient knowledge upon which to base such representation, (5) for the purpose of inducing the Plaintiff to act upon it).

3. COMES NOW PLAINTIFF Demands a Trial by Jury and Change of Venue.

That under Federal Law and Virginia Law Plaintiff has the right to a Trial by Jury:

§ 8.01-336. Jury trial of right; waiver of jury trial; court-ordered jury trial; trial by jury of plea in equity; equitable claim.

A. The right of trial by jury as declared in Article I, Section 11 of the Constitution of Virginia and by statutes thereof shall be preserved inviolate to the parties.

B. Waiver of jury trial. - In any action at law in which the recovery sought is greater than $100, exclusive of interest, unless one of the parties demands that the case or any issue thereof be tried by a jury, or in a criminal action in which trial by jury is dispensed with as provided by law, the whole matter of law and fact may be heard and judgment given by the court.

C. Court-ordered jury trial. - Notwithstanding any provision in this Code to the contrary, in any action asserting a claim at law in which there has been no demand for trial by jury by any party, a circuit court may on its own motion direct one or more issues, including an issue of damages, to be tried by a jury.

D. Trial by jury of plea in equity. - In any action in which a plea has been filed to an equitable claim, and the allegations of such plea are denied by the plaintiff, either party may have the issue tried by jury.

E. Suit on equitable claim. - In any suit on an equitable claim, the court may, of its own motion or upon motion of any party, supported by such party's affidavit that the case will be rendered doubtful by conflicting evidence of another party, direct an issue to be tried before an advisory jury.

Plaintiff demands a change of Venue due to the actions of the Clerk of Court, Commonwealth, Attorney and Judges in the Circuit Court of Alexandria due to their ability to influence and tamper with a Jury. as Plaintiff has witnessed them tampering with the Grand Jury and Plaintiff’s files in the Clerk’s office in the Circuit Court.

July 15, 2013

Janice Wolk Grenadier

15 West Spring Street

Alexandria, Virginia 22301

jwolkgrenadier@aol.com

202-368-7178

Certificate of Service

Emailed to David Mark Grenadier at renovo1@msn.com and mailed to his last known attorney whom did not respond to phone calls or e-mails to Lana Manitta of LMManitta@rrbmdk.com, Rich RosenthalBrincefield Manitta Dzubin & Kroeger, LLP - 201 North Union Street, Suite 140, Alexandria, VA 22314 - Phone: 703.299.3440.

July 15, 2013

Janice Wolk Grenadie

David Grenadier

Wednesday, August 13, 2014

Saturday, September 21, 2013

Janice Wolk Grenadier's Response to the "Grenadier Parties" Intervene and how Guilty they are!!!

Ilona Grenadier's Motion to Intervene in the Divorce LOL

The Slippery Slope of Collusion willful acts that were and still are malicious, violent, oppressive, fraudulent, wanton, and grossly reckless against Janice Wolk Grenadier and her girls started in or around October of 1996 - The lies had started -