IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ________________________________________________________ Janice Wolk

Grenadier | Plaintiff, Pro Se | Case No. v. | Ed Semonian, Public servant, individually and in his official | JURY TRIAL DEMANDED 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.
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3. On Page 26 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 federal and state courts revealed that the most pessimistic view was that only 25 per cent of lawyers appearing in our courts were really qualied 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 toward teaching advocacy skills as well as some emphasis nally, 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?

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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 Plaintiffs 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 judges 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.
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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

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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. Appellants 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 Respondents 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.

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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 ofcial. 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 to convene 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

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to investigate any condition which tends to promote criminal activity in the community or by any governmental authority, agency or ofcial. The Special Grand Jury, composed entirely of private citizens, is the one nonpolitical 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 Ilona Grenadier. 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 Haddocks 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 in their 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
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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 officers 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 officer for an act or omission taken in such officers 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.

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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

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