VIRGINIA: IN THE SUPREME COURT Janice Wolk Grenadier Plaintiff, Pro Se v.

Va. supreme Court # 110156 Alex. Circuit Court # CH010654 Alex. Circuit Court # M011001482 USDC EDV Case # 1:11CV1136

JURY TRIAL DEMANDED 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 (as in Federal Civil Rights Complaint 1:11CV1136) PETITION FOR WRIT OF ERROR CORAM VOBIS ALEXANDRIA COURT ILLEGAL ACTIONS TO DENY CITIZEN RIGHT TO TRIAL BY JURY and GRAND JURY 1. COMES NOW on Wednesday, 21 December 2011, Plaintiff Janice Wolk Grenadier (JWG), in accordance with Code of Virginia 8.01-677, 17.1-105 (b), and the Constitution of Virginia ARTICLE I Bill of Rights Section 11: Due process of law; obligation of contracts; taking of private property; prohibited discrimination; jury trial in civil cases.
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2. In addition, the following are named Defendants, for their roles in the intentional or inadvertent DENIAL of the Citizen RIGHT to Trial by Jury and DENIAL of Due process of law; obligation of contracts; taking of private property; prohibited discrimination; jury trial in civil cases.: - Nolan B. Dawkins, Public servant, individually and in his official capacity as a Judge of the Alexandria Circuit Court - John E. Kloch, Public servant, individually and in his official capacity as a Judge of the Alexandria Circuit Court - Lisa Kemler, Public servant, individually and in her official capacity as a Judge of the Alexandria Circuit Court - John J. McGrath, Public Servant, individually and in his official capacity as a Substitute Judge of Alexandria Circuit Court - Thomas Fortkort, Public Servant, individually and in his official capacity as a Substitute Judge of Alexandria Circuit Court 3. Further, the following are named Defendants Actions to DENY of Due process of law; -- obligation of contracts; taking of private property, by the theft or embezzlement of funds from the Grenadier Trust to the tune of $90,000 or more, fraud on the Bellefonte Avenue property, and involvement with a forgery on a Trust document. - David Mark Grenadier, individually, and partner with Ilona Grenadier in Grenadier Investment Co. Ltd. - Grenadier Investment Co. Ltd. in its capacity as a corporate citizen 4. Constitution of Virginia ARTICLE I Bill of Rights Section 11 prohibited discrimination, INCLUDING discrimination favoring State Bar members.
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5. Defendant Ilona Ely Grenadier, as a Virginia State Bar member and (remarried) widow of a Virginia Judge has been a beneficiary of discrimination in her favor by Defendant Judge Donald Haddock, who stated to JWG We love Ilona. Youll never get a fair trial. One question before this court is: Who is We? The other Bar buddy judges named as defendants, or as the folk saying goes, the mouse in his pocket? There is a witness to the statement of Judge Haddocks bias for Ilona. 6. After Defendant J. Howe Brown, substitute judge, DENIED Plaintiff JWG her RIGHT to a Trial by Jury, the cocky Defendant Ilona Ely Grenadier, crowed at the Plaintiff that Judge Brown called her all the time for legal advice and they were great friends. Under Court Discovery, subpoena of phone records can validate the truth or falsity of part of Ilonas assertion. 7. Virginia Canons of Judicial Conduct 2 B appears to be violated by both judges, Haddock and Brown, a decision that a Special Grand Jury of Private Citizens should be impaneled to decide, not a JIRC panel of fellow judges:
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.

It is judicial error by both judges to have such bias in favor of Ilona.

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8. Defendants Haddock, Brown, McGrath, Kloch, Dawkins, Kemler, and Fortkort should be evaluated by a Special Grand Jury of Private Citizens, not a JIRC panel of fellow judges as with the rare to take disciplinary action, for negligence in their duty to Canon of Judicial Conduct 3D:
Disciplinary Responsibilities. 1. A judge who receives reliable information indicating a substantial likelihood that another judge has committed a violation of these 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.

9. In relation to Defendant Ilona Ely Grenadier, a former wife of a Judge and a highly favored member of the Virginia State Bar, Defendant Judges Haddock, Brown, McGrath, Kloch, Dawkins, Kemler, and Fortkort should be evaluated by a Special Grand Jury of Private Citizens, not a JIRC panel of fellow judges as with the rare to take disciplinary action, for negligence in their duty to Canon of Judicial Conduct 3D:
2. 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 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.

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10. In relation to Defendant Ilona Ely Grenadier, a former wife of a Judge and a highly favored member of the Virginia State Bar, Defendants McCauley and Davis have failed to self-govern the legal profession, especially reprehensible because their JOB at the Virginia State Bar is to a lesser or greater degree, discipline of errant Bar members. Both have failed in their duty to the Citizens of Virginia, and specifically one Citizen, Plaintiff JWG, to her serious disadvantage, to the considerable advantage of much favored Bar member, Ilona Ely Grenadier.
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.

11. The current close relationship of the Virginia State Bar and the Courts of Virginia, from the Virginia supreme Court on down to the lowliest Juvenile and Domestic Relations District Court, could be defined by a non-Bar Citizen objective observer as an incestuous relationship, that has created a privileged class, a violation of Equal Justice for All. 12. Statistics are available of the VERY low percentage of Disciplinary actions against Bar members, far lower than a Citizen prosecuted by a Bar member, even one like Commonwealth Attorney Paul Thomson who was reported for skimming money from drug dealers and committing adultery.
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13. The statistics for discipline of Virginia State Bar members defined as judges is even lower than for regular, run of the mill, lawyers. 14. There is a Constitutional principle of Equal Justice Under the Law, that there should not be erected separate tribunals for privileged classes of Citizens. Both the JIRC for judges, and the Bar Disciplinary Committees are in direct violation of that lofty Constitutional principle of Equal Justice. 15. Cited in item #1 above, is 8.01-677 regarding Writ of Error, Coram Vobis. The Code of Virginia states:

8.01-677. Errors corrected on motion instead of writ of error coram vobis. For any clerical error or error in fact for which a judgment may be reversed or corrected on writ of error coram vobis, the same may be reversed or corrected on motion, after reasonable notice, by the court. (Code 1950, 8-485; 1977, c. 617.)
The operative words are may be, not shall be. In 2007, the Virginia supreme Court ruled in favor of a Petition for Writ of Error Coram Vobis, not on a motion; showing that however titled, Petition or Motion, the Court is open minded to either. Given the 2007 Neighbors precedent, the Petition for Writ of Error Coram Vobis has gained a new lease on life, from its archaic origins. 16. The error is clear. A Citizen may NOT be denied a RIGHT to Jury Trial.

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17. Due to judicial bias in favor of the deceased judges wife, Defendant Ilona Grenadier, Defendant Brown denied the RIGHT of Plaintiff JWG to a Trial by Jury. A JURY, not a judge is the only proper body to evaluate the facts and the law to determine if Judge Brown violated his Trust. 18. Due to judicial bias in favor of the deceased judges wife, Defendant Ilona Grenadier, Defendants Haddock, Kloch, Dawkins, Kemler, Fortkort denied the RIGHT of Plaintiff JWG to full and fair Due Process of the law. A JURY, not a judge is the only proper body to evaluate the facts and the law to determine if these judges violated their Trust. 19. So accepting that MOST Americans, both laymen, lawyers and jurists, and jurors still believe in this new century and this new millennium, this Year of Our Lord 2011, that the RIGHT to a Trial by Jury is a most precious, and most inviolable RIGHT, then it would not include frivolous -permits a district court to dismiss a claim filed in forma pauperis if the cause of action is frivolous or fails to state a claim upon which relief can be granted. 20. Eliminating now the issue of lack of good faith in the In Forma Pauperis application and affidavit, and eliminating any question of frivolous where a Citizens Complaint about being DENIED the RIGHT to TRIAL by JURY, and later while specifically allowed by Virginia law, one or more of the Defendants

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DENIED Plaintiff Grenadier access to the City of Alexandria GRAND JURY on 11 October a.d. 2011, then that leaves just the question of: ...or fails to state a claim upon which relief can be granted. 21. Federal courts in many cases have ordered the state courts to retry a case with a Jury Trial. THAT IS THE ERROR of the Court, the DENIAL of the CITIZEN RIGHT to a TRIAL BY JURY. A Jury of ones peers to decide the facts of the case, as applied to the Virginia law, would very likely have far less bias in favor of a Virginia State Bar member, and former wife of a Virginia judge than would a Virginia Judge, such as the Defendant judges herein named. 22. That is the simple claim of Plaintiff Grenadier, to grant the relief of Order of a new trial with a Jury. 23. The SECOND Error of the Virginia Courts in this case is in regard to the Code of Virginia 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. Defendant Ed Semonian VIOLATED this Code of Virginia LAW. It says shall at once certify to the Chief Justice Semonian DID NOT DO SO.
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24. A detailed discussion of the manipulations or violations of the Plaintiff JWGs RIGHTS to Due Process of Law by each of several Defendants named above was provided in the Original Complaint, so will not be repeated here due to its length. To apply the KISS principle, Keep It Short and Simple - the Defendant public servants of the Alexandria Courts, along with various compliant substitute judges, ignored the law of Virginia to appoint a judge of their own choosing, to protect Ilona, rather than obey the Virginia law that states that the Chief Justice ...SHALL DESIGNATE a judge of some other court of record (EMPHASIS ADDED). 25. The facts are clear, to an objective world... A. One or more of the Defendants were involved in the DENIAL of the RIGHT to TRIAL BY JURY in 2008. B. One or more of the Defendants were involved in the DENIAL of the RIGHT under Virginia Law for a Citizen or a group of Citizens to ask the Circuit Court to convene a Special Grand Jury on 11 October a.d. 2011. C. On 21 November 2011, Chief Justice signed an ORDER assigning Judge Potter of Prince William County to preside over the Grand Jury on 13 February 2012, ADMISSION there is a RIGHT of a Citizen to present to a Grand Jury to expose wrongdoing by government agencies or officials; thereby effectively OVERRULING the ORDER of 13 June 2011.
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26. The laws are clear, to an objective world A. ARTICLE I Bill of Rights A DECLARATION OF RIGHTS made by the good people of Virginia in the exercise of their sovereign powers, which rights do pertain to them and their posterity, as the basis and foundation of government. Section 11. Due process of law; obligation of contracts; taking of private property; prohibited discrimination; jury trial in civil cases. That no person shall be deprived of his life, liberty, or property without due process of law; that the General Assembly shall not pass any law impairing the obligation of contracts, nor any law whereby private property shall be taken or damaged for public uses, without just compensation, the term "public uses" to be defined by the General Assembly; and that the right to be free from any governmental discrimination upon the basis of religious conviction, race, color, sex, or national origin shall not be abridged, except that the mere separation of the sexes shall not be considered discrimination. That in controversies respecting property, and in suits between man and man, trial by jury is preferable to any other, and ought to be held sacred. The General Assembly may limit the number of jurors for civil cases in courts of record to not less than five. B. 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.

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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. 27. Without question a condition which tends to promote criminal activity in the community or by any governmental authority, agency or official. is when a government authority like Defendant J. Howe Brown, abusing his trust as a judge in the Commonwealth of Virginia, denies a Citizen the Section 11 of the Virginia Bill of Rights RIGHT to a Trial by Jury in a Civil Trial involving property, the funds embezzled from a Trust by the wife of a Chief Judge of Alexandria, a powerful, politically connected Bar member, Defendant Ilona Ely Grenadier. Therefore the commission of the wrongdoing by Defendant Brown, validates the use of the Special Grand Jury request by Plaintiff Grenadier, that was DENIED in a coordinated action by the elected servants, Clerk of the Circuit Court, Semonian, and Commonwealth Attorney, Sengel, with the presiding judge of the Grand Jury, Haddock, so the Plaintiff claim of denial of RIGHTS to
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protection under the Code of Virginia is far from frivolous, as the law states: The Special Grand Jury, composed entirely of private citizens, is the one non-political body with legal authority to make such investigations. Important to note is the specification of Grand Jury, composed entirely of private citizens because the Founding Fathers knew that Private Citizens as opposed to Officers of the Court lawyers or judges, are less likely to rule based on fear or favor than members of the Bar today. 28. The issues for a Jury of Private Citizens to hear and decide is if there is merit to the claims of Plaintiff JWG, or if as one judge stated, they are frivolous: various public servants and members of the Virginia State Bar to deny her access to the Grand Jury to make a Presentment for Bill of Indictment for Forging, Uttering, and Forging a Public Document against one of the named defendants and her law firm. (Plaintiffs Complaint #1). Plaintiff alleges further that, when she contacted the Virginia State Bar about the alleged forgery, Bar employees, also named as defendants in the Complaint, aided the cover-up of Bar member crimes. (Pl.s Compl. #2) These allegations are deemed frivolous. 29. Embezzlement of $90,000 from a Trust Account by a member of the Virginia State Bar, Ilona Ely Grenadier, widow of the former Chief Judge of Alexandria, is not a frivolous complaint by the Plaintiff. A prior Bar

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member Trustee of the same trust, Jim Arthur, was convicted in Federal Court for much the same action as later done by Bar member Ilona Grenadier, and Arthur wrote a letter to Ilona Grenadier that some of her actions were not proper even when he was still Trustee. Arthur was disbarred. Refusal by the Virginia State Bar to investigate or impose any disciplinary action against Bar member Ilona Ely Grenadier is not a frivolous complaint by the Plaintiff. 30. WHEREFORE, plaintiff prays this Court issue injunctive relief: 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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31. And WHEREFORE, plaintiff prays this Court issue equitable relief to stated claims 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 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). NOTE: That Jim Arthur was convicted in FEDERAL court, not Virginia Courts, for which there may be a reason of protecting fellow Bar members as is seen in this case where Virginia Courts have protected fellow Bar member Ilona Grenadier from her Bilking the Elderly by embezzling around $90,000 from the Sonia Grenadier Trust, as Arthur did too. 3.Issue declaratory relief as this Court deems appropriate and just. 4.Issue other relief as this Court deems appropriate and just. 5.Award plaintiff her costs of litigation. Under United States Code, Pro se litigants may be entitled to Attorney fees and costs under the Civil

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Rights Attorney's Fee Award Act of 1976, 90 Stat. 2641, as amended 42 USC 1988. 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 Virginia supreme Court, online, on 21 December 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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The CHIEF JUSTICE KINSER ORDER to the left afrming Plaintiff JWG her right to make a Presentment to a Grand Jury DATED 21 November 2011 after being DENIED on 11 October 2011 effectively OVERRULES... ...the Virginia supreme Court ORDER below DATED 13 June 2011. The underlying issue of graft and corruption by the wife of a Virginia Judge, a member of the Virginia State Bar, an agency of the Virginia supreme Court, is the same; the FACTS are the same, the LAWS violated by one or several of the Defendants are the same.

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