JWG RICO Against Alexandria Courts-Filed

8/3/2019 JWG RICO Against Alexandria Courts-Filed

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

________________________________________________________

Janice Wolk Grenadier |

Plaintiff, Pro Se |v. |

Ed Semonian, Public servant, individually and in his official |

capacity as Clerk, Circuit Court of Alexandria |

Randy Sengel, Public servant, individually and in his official |

capacity as Commonwealth Attorney, City of Alexandria |

Donald Haddock, Public servant, individually and in his official |

capacity as a Presiding Judge of Alexandria Grand Jury |

J. Howe Brown, Public servant, individually and in his official |

capacity as a Substitute Judge of Alexandria Circuit Court |

Ilona Ely Grenadier, Public servant, individually and in her official |capacity as an Officer of the Court, and illegal Trustee |

Grenadier, Anderson, Starace, Duffett, and Keisler, P.C. |

capacity as a “corporate citizen” shielding violation of Trust |

James M. McCauley, Public servant, individually and in his |

official capacity as “Ethics Counsel”, Virginia State Bar |

Edward L. (Ned) Davis, Public servant, individually and in his |

official capacity as “Bar Counsel”, Virginia State Bar |

Defendants |

________________________________________________________|

COMPLAINT - CONSPIRACY TO INTERFERE WITH 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

1. COMES NOW on Thursday, 20 October 2011, Plaintiff Janice Wolk Grenadier (JWG), having

been denied Rights as a Citizen by coordinated action of employed public servants of the

Courts of the City of Alexandria, namely Defendants Semonian, Sengel, and Haddock, on

11 October 2011, in their denial of access to the Grand Jury to make a Presentment for Bill of

Indictment for Forging, Uttering, and Forging a Public Document against Defendant Ilona Ely

Grenadier, remarried widow of the former City of Alexandria Chief Judge Albert Grenadier,and her law firm Defendant Grenadier, Anderson, Starace, Duffett, and Keisler, P.C. Prior actions

by Defendant Brown and employees of the Alexandria Courts have denied JWG a Trial by Jury.

2. Plaintiff JWG first contacted the Virginia State Bar (VSB) in 2008 about the forged signature on a

Trust Amendment that Defendant Ilona Ely Grenadier used to “loot” the Trust, the same trust that

later Bar member Jim Arthur looted and was convicted for in Federal Court. Both Bar employees

Defendants McCauley and Davis, and the VSB, have aided the cover-up of Bar member crimes.

Grenadier v. Semonian, Sengel, Haddock, Grenadier, Grenadier law firm, VSB employees! page 1 of 12

Case No.

JURY TRIAL DEMANDED



3. On 6 of the January 1978 issue of the ABA Journal (see Exhibit A) is written:

! “Burger said the “sounding” he took from judges and lawyers in federaland state courts revealed that “the most pessimistic view was that only 25 per cent of lawyers appearing in our courts were really qualified to represent their clients properly and to move the case along adequately. Some judges placed it

as high as 75 per cent. Somewhere near the midway mark is probably correct,and it will vary to some extent from place to place.” ! Burger noted some improvement in the attitudes within law schools towardteaching advocacy skills as well as “some emphasis finally , I am glad to say,on ethics and deportment.” ! But, he said, the traditional answer from law school professors has been“ We are not running a trade school.” “That lofty response,” Burger said,“really does not wash… They should be trained in their trade which is trial advocacy.” ! In London, responding to a question, Chief Justice Burger said,! “Our discipline is barely something more than non-existent; discipline of lawyers for misconduct is in an abysmal state in our country.”

In Virginia, in the decades since, there has been no progress to correct this abysmal state of lawyer

discipline by the Defendants Davis or McCauley, or their employer, the Virginia State Bar.

This case is but the “tip of the iceberg” of covered-up crimes by VSB of its members.

4. “Justice Delayed is Justice Denied.” dates back to anno domini 1215, Article 40 of the

Magna Carta. Those wise words grace the entranceway sculpture, and have become the

“motto” of the Alexandria Division of the United States District Court for the Eastern District

of Virginia, known by some as the “Rocket Docket” suggesting an absence of delay in the

pursuit of Justice, where this case of lawyer-trustee embezzlement is being pursued, and

where an associated lawyer-trustee of Defendant Grenadier was convicted in 1993 for similar

acts. Yet with Defendant RICO actions this case is also “Justice Derailed is Justice Denied.”

5. “Neither the politics nor economics of law practice permits lawyers to pursue such cases nor

makes them affordable except to a small elite of citizens.” writes Constitutional Attorney

David C. Grossack. Therefore, for any citizen, much less a citizen standing against violations

of law by a lawyer and a judge, JWG must proceed Pro Se against a judge and Bar members

who have violated her Constitutional Rights. Even if this Plaintiff could afford a lawyer, where

would an honest, fearless of judges and fearless of the Virginia State Bar lawyer be found?




5. The taxpayer paid Alexandria public prosecutor, Defendant Randy Sengel, has “under the color

of law” both refused to prosecute charges of Forging, Uttering, and Forging Public Documents

against powerful, politically connected Defendant Ilona Ely Grenadier, and then, interfered with

the access of a Citizen to the Private Citizens (no lawyers) of the Alexandria Grand Jury.

6. Constitutional Attorney Grossack continues, “Has a judge violated your constitutional

rights? Have you been discriminated against by being treated differently than other people

in similar situations by reason of race, religion, national origin, gender, sexual preference

or political opinion? Have you lost certain rights without a meaningful hearing or even an

opportunity to be heard? Have you been deprived of any other constitutional protection?”

Due to the violations of Plaintiff’s Constitutional Rights in several ways by the various

defendants in a racketeering, influence and corrupt organization (RICO) process of

coordination of actions to my detriment, the answer to each or many of the above is YES!

The plaintiff does not ask the Court to accept the opinion of the plaintiff, the plaintiff respects

the wisdom and justice of the Jury to whom the Plaintiff claims her Right to present her case.

7. Further Grossack writes, “As a general rule, however, judges cannot be held liable for money

damages for acts done in the exercise of his judicial function, within the limits of his

jurisdiction, no matter how erroneous, illegal or malicious his acts may be. (48A Corpus

Juris Secundum §86.) A minority of decisions have held that if an inferior judge acts

maliciously or corruptly he may incur liability. Kalb v. Luce, 291 N.W. 841, 234, WISC 509.”

Although it is almost impossible to recover monetary damages from a judge (unless you can

prove he or she acted ultra-vires beyond his or her legal jurisdiction) it is in fact possible to

obtain relief in equity against a judge through civil rights actions. Equitable relief includes:

* declaratory relief - (rulings by another judge in the form of opinions establishing the

constitutionality or lack of constitutionality of another judge’s actions.)

* injunctive relief - a command or order to do something or refrain from doing so.”

Both actions and neglect of actions by Defendant Haddock are in fact Ultra Vires, beyond his legal

jurisdiction in the administrative function of Presiding Judge over a session of the regular Grand Jury,

which is the “Fourth Branch of Government” for Citizens to Petition for Regress of Grievances.




8. On 13 February 2008 after a hearing presided over by Judge J. Howe Brown, Defendant Ilona

Grenadier said to JWG that Judge Brown will never find against her because he called on her

for help with legal questions. Given that admission by Defendant Ilona Grenadier, Judge

Brown, if honest, and following the Canons of Judicial Integrity, should have self-recused.

Brown never admitted his association with, and assistance from, Defendant Ilona Grenadier.

9. On 8 February 2008, Defendant Ilona Grenadier sent a threatening letter to JWG to drop her suit.

On 27 February 2008, Defendant Ilona Grenadier filed a Counter-Claim and Cross-Complaint

with “disingenuous statements” in lawyer language, or for common folk, “falsehoods”.

10. On 7 May 2008, in Alexandria Court Judges’ Chambers with a third party witness present,

Defendant Haddock stated to Plaintiff JWG:

“You will never get a fair trial because we love Ilona.”

While an honest statement by Defendant Haddock, it is also an admission of intended action

contrary to the law, actions that are ultra-vires, and thus are not protected by judicial immunity.

11. A wise way to a fair trial is to demand a Trial by Jury, because the Private Citizens of a Jury are not part

of the Bar member RICO racket that protects its own members from equal application of our laws.

12. After the admission of Defendant Haddock that “we”, that means by inference, Haddock and

others in the Courts of Alexandria, “love Ilona”, such that Plaintiff JWG would “never get a

fair trial” from judges, Plaintiff JWG filed a Motion for Jury Trial as a “last resort”.

13. On 18 June 2008 Plaintiff JWG again filed a Motion for Trial by Jury, Motion to Compel, Motion

for Default, and Praecipe to be heard 25 June, and again 2 July, that was finally heard 9 July.

Judge Brown denied that Right of a Citizen, Plaintiff JWG to proceed before a Trial by Jury, and

denied every other Motion, echoes of “You will never get a fair trial because we love Ilona.”

14. On 20 January 2011, Plaintiff JWG filed with the Virginia supreme Court an Appeal from the

Circuit Court of the City of Alexandria Case # CH010654 with an Assignment of Error:

“The trial court of the Circuit Court of Alexandra erred by failing to follow

Va. Code 17.1-105 (b) after all the judges recused themselves (or were required




to recuse themselves) from this matter because of personal relationships

between Defendants and the judges. Instead of having the Chief Justice of the

Supreme Court appoint an out of Circuit Judge to hear the case, the Circuit

Court of Alexandria (or its clerk) selected a judge themselves. Appellant’s

motions challenging the appointment the appointment of the out of Circuit judges were denied and judgment ultimately entered against her.”

Defendant Brown was “named” as a substitute judge by either Defendant Semonian or Defendant

Haddock in violation of Va. Code 17.1-105 (b), and despite the inter-personal relationship

with Defendant Ilona Grenadier, failed both to admit that fact or recuse himself, so a judge

with proper jurisdiction could be assigned by the Chief Justice in accordance with Virginia law.

The “other side” lied to the justices of the Virginia supreme Court in their 3 February 2011

Respondent’s Joint Motion to Dismiss Petition for Appeal saying that JWG had failed to file

the Court Statement of Facts, that actually another Alexandria judge had failed to sign, but

had been timely filed by JWG. After a Pro Se appearance by Plaintiff JWG on Tuesday,

24 May 2011 before the justices, the Virginia supreme Court denied her Appeal on 13 June.

JWG filed a Petition for Reconsideration on 27 June, which was denied on or about 21 September.

Further research by JWG revealed the provision of Virginia law for Citizen Presentments to

the Grand Jury, and to request a Special Grand Jury to investigate government criminal acts,

that was illegally denied by Defendants Semonian, Sengel, and Haddock on 11 October 2011.

15. Finally, Constitutional Attorney Grossack writes, “Federal Civil Rights statutes, and possibly

Bivens actions, appear to offer the best path for redressing constitutional grievances with

state and federal judges, respectively, in Federal Court. As a practical matter, such cases

will usually be brought by pro se litigants.” (BOLD emphasis added.)

JURISDICTIONAL BASIS.

16. Plaintiff claims federal jurisdiction pursuant to Article III § 2 which extends the jurisdiction to

cases arising under this Constitution for the United States of America in this federal district.




17. Plaintiff JWG brings this suit pursuant to Title 18 United States Code § 241:

“If two or more persons conspire to injure, oppress, threaten, or intimidate any person in

any State, Territory, Commonwealth, Possession, or District in the free exercise or

enjoyment of any right or privilege secured to him by the Constitution or laws of the

United States, or because of his having so exercised the same; or…”

-- Defendant Ilona Grenadier, on 27 February 2008, and many other times, did threaten and

intimidate Plaintiff JWG, and did injure her by theft of funds from a Trust for her children.

18. Plaintiff also brings this suit pursuant to Title 18 United States Code § 242:

“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, …

… shall be fined under this title or be imprisoned not more than one year, or both;…”

-- Defendants Haddock and Brown did conspire to the favor of Defendant Ilona Grenadier, to

deny and deprive Plaintiff JWG, her RIGHT to Trial by Jury in 2008, exercised by her Motion.

-- Defendants Semonian, Sengel, and Haddock did conspire on 11 October 2011 and the days

leading up to that date, to the favor of Defendant Ilona Grenadier, to deny to Plaintiff JWG,

her RIGHT to present to the regular Grand Jury of Alexandria several Bills of Indictments for

Forging, Uttering, and Forging Public Documents against Defendant Ilona Grenadier.

-- Defendants Semonian, Sengal, and Haddock did conspire on and before 11 October 2011

to the favor of Defendant Ilona Grenadier, to deny and deprive to Plaintiff JWG, her RIGHT

to present to the regular Grand Jury of Alexandria in exercise of her RIGHT to seek their vote

to impanel a Special Grand Jury to investigate “any condition which tends to promote

criminal activity by any governmental authority, agency or official.” as provided in the

Code of Virginia § 19.2-191 (2) and on, plus the October 2010 edition of the Virginia supreme

Court Handbook for Grand Jurors Section 23, titled “Convening”, states:

“Any citizen or group of citizens may ask the Circuit Court of a city or county toconvene a Special Grand Jury.”

and the Handbook for Grand Jurors, Section 26, titled “Functions of a Special Grand Jury” states:

“As has been set out in Section 3, a Special Grand Jury is composed of from seven

to eleven citizens of a city or county, selected by the Circuit Court and summoned




to investigate any condition which tends to promote criminal activity in the

community or by any governmental authority, agency or official.”

“The Special Grand Jury, composed entirely of private citizens, is the one non-

political body with legal authority to make such investigations.”

-- Defendants Semonian, Sengel, and Haddock did conspire on and before 11 October 2011

to the favor of Defendant Ilona Grenadier, to deny and deprive the Citizens of the Grand Jury

to know their Rights and Duty under Virginia Law, evidenced by the fact that after Counsel

for Plaintiff JWG rose and addressed Defendant Haddock and members of the Grand Jury

after they certified as True Bills (of Indictment) the many Presentments made by Police

Detectives and other witnesses scheduled and authorized by Defendant Randy Sengel, to say:

“Your honor, there is “unfinished business” of the Grand Jury with the Presentment of

Charges of Forging, Uttering, and Forging Public Documents by Bar member IlonaGrenadier.”

Defendant Haddock snapped at Plaintiff Counsel stating:

“We discussed that earlier today, and agreed to hear that in December.”

Plaintiff Counsel replied,

“Your honor, the December date was regarding corruption in the courts by Judges, including

you, so there was some merit in bringing in a judge from another jurisdiction to hear those

other Grand Jury Bills of Indictment, but the business left undone for this Grand Jury

regards a lawyer, Ilona Grenadier, who as a Trustee, embezzled funds from a Trust.”Defendant Haddock then turned to address the Citizens of the Grand Jury, and said (paraphrase):

“Is there any other matter in the community of which you have been made aware so you would

like to vote to impanel yourselves as a Special Grand Jury?” (NOTE: Not enough regular Grand

Jurors, only 5 Jurors this day, whereas a Special Grand Jury minimum number is 7, up to 11.)

Defendant Haddock then “glared” down at the Grand Jurors, and the first four, paused, but under

Haddock’s withering stare, said “No”, one after the other, until the Jury Foreman replied meekly,

“I do not understand.” This statement by the Jury Foreman is an admission that either or both

Defendant Semonian as Court Clerk, and Defendant Haddock, as Presiding Judge, had failed intheir DUTY to fully inform the Citizens of the Grand Jury of their RIGHTS and DUTIES under

Virginia law, and suggests neither provided the Virginia supreme Court Handbook for Grand Jurors.

19. Plaintiff also brings this suit pursuant to Title 42 U.S. Code § 1983:

§ 1983. CIVIL ACTION FOR DEPRIVATION OF RIGHTS




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, except that in

any action brought against a judicial officer for an act or omission taken in such

officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory

decree was violated or declaratory relief was unavailable. For the purposes of this

section, any Act of Congress applicable exclusively to the District of Columbia shall

be considered to be a statute of the District of Columbia.

Plaintiff JWG brings this suit for violations of certain protections guaranteed to her by the

First, Fourth, Fifth, Seventh, and Fourteenth Amendments of this Constitution for the United

States of America, by the defendants under color of law in their various capacities in the justice system of the Circuit Court of the City of Alexandria, and as members, agents or

employees of the Virginia State Bar, an agency of the Virginia supreme Court, for each of the

Defendants except Defendant Haddock, who may be exempted from action for injunctive relief:

except that in any action brought against a judicial ofcer for an act or omission

taken in such ofcer’s judicial capacity, injunctive relief shall not be granted

unless a declaratory decree was violated or declaratory relief was unavailable

However, a Presiding Judge over a Grand Jury is an administrative function, not per se, a

judicial function, so there is question if Defendant Haddock is “immune” under 42 USC § 1983.

20. WHEREFORE, plaintiff prays this Court issue emergency injunctive relief:

1. As Pro Se, Plaintiff JWG is at a severe disadvantage in seeking a fair trial given the

Defendants are not “common citizens”, but rather are Bar members, trained in the law,

and Virginia State Bar members, “Bar buddies”, with others in the Courts who control the

Court schedule (docket) like Defendant Semonian, control what gets prosecuted, like

Defendant Sengel, or what Motions get granted, like Defendants Brown and Haddock;

therefore Plaintiff prays this Court will assign a Court Appointed Attorney to provide

“assistance of counsel”, an attorney not a member of the Virginia State Bar, due to

Conflict of Interest thereby, but permitted to practice by provision of Pro Hac Vice, an

“honest, fearless of judges and fearless of the Virginia State Bar” out-of-state lawyer.




21. And WHEREFORE, plaintiff prays this Court issue equitable relief as follows:

1. Issue a Writ of Mandamus to Order a de novo Trial by Jury of the trial of 2008, when a

Jury Trial was Denied by Defendant Brown.

2. Issue a Writ of Mandamus to Order Defendant Semonian to schedule Plaintiff JWG a time

in November 2011 to make Presentment of Bills of Indictment against Defendant Ilona Grenadier.

3. Issue a Writ of Mandamus to Order Defendant Semonian to schedule Plaintiff JWG a time

in November 2011 to make Presentment of Bills of Indictment against Defendants Brown

and Haddock, Defendants Sengel and Semonian, and Defendants McCauley and Davis.

4. Issue injunctive relief commanding a further, detailed forensic investigation into the

collusion, or racketeering of the named Defendants above, building on FBI files and

investigation of convicted Bar member Jim Arthur, Trustee, and Ilona Grenadier, Agent

and Cashier of the Sonia Grenadier Trust. (See Exhibits B and C).

5. Issue declaratory relief as this Court deems appropriate and just.

6. Issue other relief as this Court deems appropriate and just.

7. Award plaintiff her costs of litigation.

I RESPECTFULLY ASK FOR THIS:

Janice Wolk Grenadier

Plaintiff, Pro Se

CERTIFICATE of SERVICE

I hereby certify that a true copy of the foregoing was filed at the United States District Court,

Eastern District of Virginia, Alexandria Division, on 20 October in the Year of Our Lord Jesus

2011, and sent by U.S. First Class Mail to each of the named Defendants.

Janice Wolk Genadier

Plaintiff, Pro Se





Federal Exhibit B - (denied) Grand Jury Exhibit E - “Lawyer Gets 5 Years for Bilking Elderly”

JWG RICO Against Alexandria Courts-Filed

Documents

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