IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ________________________________________________________Janice W olk Grenadier | Plaintiff, Pro Se | v. | Ed Semonian, Public servant, individually and in his official | capacity as Clerk, Circuit Court of Alexandria | Randy Sengel , Publ ic ser vant , 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”, Vir ginia 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 W olk 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 ofIndictment for Forging, Uttering, and Forging a Public Document against Defendant Ilona Ely Grenadier, remarried widow of the former City o f Alexandria Chief Judge Albert Grenadier , and her law firm Defendant Grena dier, 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 fir st contacted the Vir ginia 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
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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
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 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?
Grenadier v. Semonian, Sengel, Haddock, Grenadier, Grenadier law firm, VSB employees! page 2 of 12
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
Grenadier v. Semonian, Sengel, Haddock, Grenadier, Grenadier law firm, VSB employees! page 7 of 12
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.
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