june 8, 2015 spring v 4a final new evicdence - motive united states court of appeals pdf

10
1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA _______ JANICE WOLK GRENADIER Pro se Plaintiff v. Civil Action No. 1:14 cv 00827 No. 15-1169 BWW LAW GROUP HOWARD N. BIERMAN EQUITY TRUSTEES, LLC MARK R. GALBRAITH Lost License WELLS FARGO BANK OF AMERICA, f/k/a - as successor-in-interest to LaSALLE BANK, OCWEN LOAN SERVICING LLC Defendants, Jointly and Severally, in their Official and Personal Capacities. MOTION FOR NEW EVIDENCE / THAT SHOWS MOTIVE OF BWW LAW GROUP TO CLAIM OWNERSHIP OF ALLEGED LOAN AND TO IGNORE THE FORECLOSURE DATE OF OCWEN Comes now Plaintiff moves to add additional information that has just been released on the internet in regard to Defendant Howard Bierman / BWW Law Group / Equity Trustees being held accountable and admonition by the Virginia State Bar in 2009 represented by Lawyer Ben DiMuro:. This is important new evidence as it ties in and shows the participation of the lawyers Troutman Saunders aka Mays and Valentine and the BWW Law Group/ Equity Trustees and Howard Biermans participation in the scheme of having me jailed (Tortured). Plaintiff further will show the events and order of events why Howard Bierman would claim ownership of the alleged loan and tell OCWEN they were Foreclosing even though they

Upload: janicewolkgrenadier

Post on 13-Sep-2015

5 views

Category:

Documents


0 download

DESCRIPTION

BWW Law Group - finally released from the Virginia State Bar - Criminal acts by Howard Bierman - Oh Thank God for him - his attorney was Ben DiMuro - DiMuroGinsberg - past President and donating 10% of his estate to the Bar et al - no issue for Corrupt Lawyer Howard Bierman - Thanks to Corrupt[t Lawyer Ben DiMuro - who lies in court, lies in court documents - uses Bribery - what ever it takes to win - a real scumbag of a man

TRANSCRIPT

  • 1

    UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA

    _______

    JANICE WOLK GRENADIER

    Pro se

    Plaintiff

    v. Civil Action No. 1:14 cv 00827

    No. 15-1169

    BWW LAW GROUP

    HOWARD N. BIERMAN

    EQUITY TRUSTEES, LLC

    MARK R. GALBRAITH Lost License WELLS FARGO

    BANK OF AMERICA, f/k/a - as successor-in-interest to LaSALLE BANK,

    OCWEN LOAN SERVICING LLC

    Defendants,

    Jointly and Severally, in their Official and Personal Capacities.

    MOTION FOR NEW EVIDENCE / THAT SHOWS MOTIVE OF BWW LAW GROUP

    TO CLAIM OWNERSHIP OF ALLEGED LOAN AND TO IGNORE THE

    FORECLOSURE DATE OF OCWEN

    Comes now Plaintiff moves to add additional information that has just been released on the internet in regard to

    Defendant Howard Bierman / BWW Law Group / Equity Trustees being held accountable and admonition by

    the Virginia State Bar in 2009 represented by Lawyer Ben DiMuro:.

    This is important new evidence as it ties in and shows the participation of the lawyers Troutman Saunders aka

    Mays and Valentine and the BWW Law Group/ Equity Trustees and Howard Biermans participation in the

    scheme of having me jailed (Tortured). Plaintiff further will show the events and order of events why Howard

    Bierman would claim ownership of the alleged loan and tell OCWEN they were Foreclosing even though they

  • 2

    did not have that authority according to the Rules of the Harp, the Government, OCWEN and attorney Robert

    Michael who works at BWW Law Group/ Equity Trustees with Howard Bierman and is representing them as

    council wanted to be sure that Plaintiff knew they did not own the alleged loan nor did they ever own any loans.

    That October 22, 2015 Plaintiff was Jailed 22 days / 14 days Solitary Confinement by the City of Alexandria,

    Virginia illegal for legal fees that the lawyers had lied in court, lied in court documents, used bribery, ex-parte

    communications as documented in affidavits for legal fees, e-mail from Alps insurance saying they were paying

    the legal fees Plaintiff was released early after sneaking documents out

    While in Jail Plaintiff was tortured by Sheriffs et al with the following:

    1. 14 days Solitaire Confinement till 5pm on election day to prevent disclosure of e-mails between Plaintiff and Senator Mark Warner

    2. Denied phone calls till 10 pm on 1st day and most days by being in Solitaire Confinement and phone control

    3. Woken up every 2 hours at night 4. Not allowed out of cell till 2 or 3 am for by required 1 hour 5. Sat down and told I had less rights than someone who murdered someone 6. No Advocate 7. Denied mail returned to sender saying I was not there 8. Denied copy of any type of order denying my mail or having it opened prior to my receipt of it 9. Stripped searched patted down men watching me shower 10. Warned by Magistrate if I continued my quest for Justice it would only get worse for me and my girls

    What is Solitary Confinement?

    In the early nineteenth century, the U.S. led the world in a new practice of imprisoning people in solitary cells, without access to any human contact or stimulation, as a method of rehabilitation. The results were disastrous, as prisoners suffered severe psychological harm. The practice was all but abandoned. Over a century later, it has made an unfortunate comeback. Instead of torturing prisoners with solitary confinement in dark and dirty underground holes, prisoners are now subjected to solitary confinement in well-lit, sterile boxes. The psychological repercussions are similar

    CCRs Challenges to Solitary Confinement

    In May 2012, the Center for Constitutional Rights (CCR) filed a lawsuit against the state of California for its use of prolonged solitary confinement in the infamous Pelican Bay prison. Ashker, et al. v. Governor, et al., is a federal class action challenging prolonged solitary confinement and deprivation of due process, based on the rights guaranteed under the Eighth and Fourteenth Amendments, at Pelican Bay In Wilkinson v. Austin, the U.S. Supreme Court unanimously ruled in support of CCRs claims that prison officials cannot confine prisoners in long-term solitary confinement in a super maximum prison without first giving them the opportunity to challenge their placement.

    Solitary Confinement is Torture The devastating psychological and physical effects of prolonged solitary confinement are well documented by social scientists: prolonged solitary confinement causes prisoners significant mental harm and places them at grave risk of even more devastating future psychological harm and at times, these harms were found to be permanent or persist even after one was released from solitary. Researchers have demonstrated that prolonged solitary confinement causes a persistent and heightened state of anxiety and nervousness, headaches,

  • 3

    insomnia, lethargy or chronic tiredness, nightmares, heart palpitations, fear of impending nervous breakdowns and higher rates of hypertension and early morbidity. Other documented effects include obsessive ruminations, confused thought processes, an oversensitivity to stimuli, irrational anger, social withdrawal, hallucinations, violent fantasies, emotional flatness, mood swings, chronic depression, feelings of overall deterioration, as well

    as suicidal ideation. Exposure to such life-shattering conditions clearly constitutes cruel and unusual punishment

    in violation of the Eighth Amendment to the U.S. Constitution. Further, the brutal use of solitary has been condemned as torture by the international community. Juan Mendez, the United Nations Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, concluded that even 15 days in solitary confinement constitutes torture or cruel, inhuman or degrading treatment or punishment, and 15 days is the limit after which irreversible harmful psychological effects can occur. Other independent human rights bodies at the UN have also expressed concern about Pelican Bay prison and the overall use of solitary in U.S. prisons. However, many prisoners in the United States have been isolated for far longer than just 15 days. That as documented in this case Plaintiff had received documents and had a court date that conflicted with

    Plaintiff being in jail. That the state refused Plaintiff access to a phone to call or communicate with this court or

    lawyers. Plaintiff was able to be released early by filing a motion stating:

    That your actions have turned back time. Giving me less rights then a slave. Taking someone under Title 42

    US Code 1994 and Title 18 US Code 1581(a): Whoever holds or returns any person to a condition of

    PEONAGE, shall be fined under this title for imprisoned not more than 20 years or both. That on October 22,

    2014 I was placed in jail for failure to pay legal fees in 30 days which is a violation of my Thirteenth

    Amendment "Neither Slavery not involuntary servitude, except as punishment for a crime where of the party

    shall have duly convicted, shall exist within the United States, or any subject to their Jurisdiction".

    Furthermore the right by placing me "under" a state Peonage / Involuntary Servitude violating the Fourth

    Amendment right by malicious prosecution, false imprisonment and unconstitutional arrest. This violation of

    my Eight Amendment Right as to Excessive Bail which in this case constitutes "Restitution Bail" which further

    shows the knowledgeable malicious intent to silence me till the election was over on November 4th. 2014. Bias,

    Retaliation and Retribution to further line the Lawyers pockets by Judge Clark.

    Along with many other Truths about the Criminal actions of many involved in this cover up.

    That Plaintiff was aware and has been looking for the tie in to Legal issues with Lawyer Ilona Grenadier

    Heckman and Defendants. The associations and the connections can now be shown with further investigation

    by discovery will show that Defendants in this have a strong tie and the desire of all to maliciously harm

    Plaintiff for personal financial gain and possible other help in any further conflicts with the Virginia State Bar

    for Howard Bierman et al. That for Troutman Saunders in the accountability to Plaintiff and others for the theft

    of funds from Trust Accounts from the purchase of Mays and Valentine. That a property that settled in April of

    2014 made the thefts a continuing crime from November 1983 and voided all Statue of Limitations as the acts

    and actors acted to scheme and further cover up thefts that Lawyer Ilona Grenadier Heckman used a forged

    Trust Agreement, that Lawyer Jim Arthur and others were or should have been aware of and manipulated

  • 4

    $30,000. along with a great loss of business of Plaintiff. That Troutman Sanders / Mays and Valentine have

    been put on notice of their involvement of such criminal acts.

    That Lawyer Ilona Grenadier Heckman has stolen, lied to, maliciously with intend to harm emotionally and

    physically from Plaintiff since February 14, 1986. That Ben DiMuro started representing Ilona and made it his

    passion to continue the malicious acts and actions as follows:

    Ben DiMuro - DiMuroGinsberg with John Tran, Hillary Collyer and Andrea Mosley in his the office of DiMuroGinsberg are guilty of: Judicial Misconduct, Criminal Misconduct, Discrimination for Religious,

    Social, Economic, Hierarch, Gang Type Behavior Similar to the Klue Klux Klan, Attempt to harm Plaintiff and

    her Girls through Drugs & Rape, Slander of Plaintiff to prevent Due Process, Tampering with Evidence, Mail

    Fraud, Violating the Law and the Rules of the Supreme courts, Violation of the Judicial Cannons, Obstruction

    of Justice, Fraud on the Court, TREASON, Title 18 U.S. Code 241 & 242; Title 42 U.S. Code 1981 & 1983

    and other laws Bribery, ex-parte communications, perjury, Fraud on the Court, conspiracy/collusion to obstruct

    due process, Miscarriage of Justice, Appearance of Justice, conflict of interest, conflict of interest recusal,

    Breach of Fiduciary duties, ignoring his Oath of Office, Conspiracy against rights, and other violations of the

    VSB duties of an officer of the court.

    1. Past President of the Virginia State Bar, which he helps support through the interest of his Escrow Account? Has designated 10% of his and his wife Sandys estate to the Virginia Law Foundation. Purchasing Justice for his clients.

    2. April of 1989 twice met with JWG and her then husband David to discuss a fire that he was representing GIC/Monroe Ave partnership for the overage on the insurance. David & Janice was 49%

    owner of GIC at the time.

    3. April 17, 2009 Wrote threatening letter that JWG was trying to extort money from Ilona - Money that Ilona owed JWG from malicious manipulation, and stealing it from JWG. Through misc letters can and

    shall support the lies of Ilona Grenadier even after given the evidence.

    4. July 2009 to this date is involved with e-mails from the Grenadiers, Loretta Lax Miller aka Muggy Cat to myself in the collusion of their racist bigot attitude to the fact I raised by girls Catholic. Calling

    the Pope a wanker. To harass and intimidate Plaintiff and her girls along with:

  • 5

    5. October of 2009 with the collusion of Randy Sengel - Commonwealth Attorney of the City of Alexandria, using bullying and scare tactics to get JWG charged with the Extortion game he had

    come up with in April of 2009 when hired by Ilona Grenadier and her law firm, to use whatever illegal

    and unprofessional tactics it took to dispose of exposer to her criminal activities. The Extortion issue

    with Randy Sengel bringing in the City of Alexandria Police Charles Pak to try and intimidate JWG.

    In the continuance of the Extortion claim never to be have any basis October 28, 2012 Randy has

    Detective Pak call me about Extortion charges in collusion with Ben DiMuro the pattern of anytime

    Plaintiff finds the law and confronts the illegal behavior Randy Sengel finds a way to go after Plaintiff in

    a Retribution / Retaliation pattern. Extortion Charges which there is no police incident number nor any

    record with the Alexandria Police Records room. January 7, 2012 several e-mails and phone calls to

    Detective Pak who lied on several occasions to Plaintiff and there was no number to give Plaintiff, as he never reported his Scare Tactics to the appropriate people. He went out of his way in collusion with

    Randy Sengel to harm Plaintiff

    6. Feb 2, 2011 Lied in Respondents Joint Motion to Dismiss Petition for Appeal Dated Feb 2, 2011 in the Supreme Court of Virginia on Page 2 Paragraph 2 - Here, Petitioner has failed to ensure that the

    record contains either transcripts or a written statement of facts.

    7. August of 2011 involved in ex-parte communications for the delay of the Motion for Reconsideration to be heard in August of 2011.

    8. October of 2011 publically thanked for the generous donation to Judge Haddocks Portrait Fund Thank you for helping me with my client Ilona Ely Freedman Grenadier Heckman which continued in October of 2011 when Judge Haddock denied JWG in front of a Grand Jury and stated you will never win as we LOVE ILONA he then choose all Judges

    9. He and his law firm has worked in collusion with the actions of the City of Alexandria, Judges, Commonwealth Attorney, Clerk of Court, VSB, JIRC, Courts of Justice, the Democratic party, Virginia

    Legislators, Supreme Court of Virginia has acted intentionally, willfully, wantonly, and maliciously

    in their collusion to protect Ilona Ely Freedman Grenadier Heckman founding partner to the law

    firm Grenadier, Anderson, Stracae, Duffett & Kiesler, the late wife of Judge Albert Grenadier, from

    being held responsible for her and her law firms criminal activity. Ben DiMuros blatant abusive actions in regard to the United States of America Constitution, Virginia Constitution, Civil Rights, religious

    rights of a citizen.

    10. Ben DiMuro and his firm have worked in collusion to Intimidate, Maliciously Manipulate Janice Wolk Grenadier using Scare Tactics, the Alexandria Police, and the Courts of Virginia, motivated by financial

    interests and cronyism. Causing Janice Wolk Grenadier to suffer mentally and financially as well has

    her children innocent victims from his and their actions. The acts of Mr. DiMuro are egregious and

    vicious against Janice a pro se, single mom with her 2 girls because they are Catholic and are x

    communicated from the Old Boy Network

    11. November / December 2012 Involved in the hiring of a Mark Stuart to drug Plaintiff and get inappropriate sexual pictures, rape one of Plaintiffs daughters or to plan drugs on one of girls or in home. That John Tran admitted to collusion in Judge Clarks order to them and others to find

    information on Plaintiff to find incompetent.

  • 6

    12. 04/05/2013 - McLeans John Tran named first Asian-American judge in Virginia history, to join Fairfax bench By Tom Jackman U.S. District Judge Gerald Bruce Lee tried cases against Tran in private

    practice in Alexandria, then supervised his cases as a judge. Its a great day for the Commonwealth of Virginia, said Lee, who was a Fairfax circuit judge for six years before immigrating to the fed bench in 1998. Johns an excellent lawyer whos given much of his time to our community, in the bar association and in pro bono work. Today is a huge step forward for our judiciary and for fairness. Judge Lee actions towards Plaintiff were with Retaliation, Retribution and Bias for his friendship.

    13. That on April 4, 2014 Ben DiMuro Lied in court in Prince William County and Lied in documents submitted to the courts.

    14. That on July 16, 2014 Ex Parte communications with Judge Clark

    15. That on July 23, 2014 Ben DiMuro hopes to again to manipulate the Judicial System to protect his Client Ilona Grenadier Heckman from being accountable for her actions

    16. Ben DiMuro is being paid by Alps Insurance according to an e-mail from Alps Insurance Co.

    17. That Ben DiMuro, John Tran & Hillary Collyer, and Andrea Mosley ccd each other regularly on documents submitted with the Court, letters, e-mails sent to JWG. Making an action of one an action of

    all Four - DiMuroGinsberg Law firm.

    18. That October 22, 2015 DiMuroGinsberg lied / with purpose mislead the court to assure plaintiffs illegal Jailing and Torture

    The Question this court would reasonable have is why would DIVORCE Lawyer Ilona Grenadier

    Heckman go to these measures It is because in a rough accounting she owes Plaintiff over $20 million dollars:

    Money / Claims:

    Note being held by Grenadier Anderson Strace Duffett & Kieser For $30,000. Money borrowed by

    Ilona to prevent her from being questioned and as she knew would happen - Loose her Law License

    Note that was paid off by 54 East Taylor Run Pkwy, Alexandria, Virginia 22304

    Client lost - Due to Jim Arthur / Mays and Valentine now Troutman Sanders to further the cover up

    Rental Income / Loses etc.. Income estimated at $85,000 or more monthly after expenses

    Still owned Real Estate:

    Southway Terrace ( approx 80 condo units) Value $12 Million

    404 East Monroe AVe ( Apartment Building) Value $2 Million

    Property Owners:

    Caroline G or Jonathan M Perkins - 1623 Francis Hammond Pkwy, Alexandria, Virginia 22302

    Mr. Steven M. Kremer - 44 E Taylor Run Pkwy , Alexandria, Virginia 22304

    Mr. William Dale Betz - 1943 Euclid Ave, - Lincoln, Ne 68502 54 E Taylor Run Pkwy - Alexandria, Virginia 22304

    Ms. Mary Gilreath - 33 S Gordon St, Alexandria, Virginia 22304

    Mr. Gregory P Lynskey - 2943 Sycamore St, Alexandria, Virginia 22305

  • 7

    Ms. Anita Workman - 2945 Sycamore St. Alexandria, Virginia 22305

    Robert L or Eunice Thompson - 415 East Del Ray Ave, Alexandria, Virginia 22301

    Ms. Sharon G. Scribner - 224 Guthrie Ave, Alexandria, Virginia 22305

    Mr. Mark R. Anderson - 322 Hume Ave, Alexandria, Virginia 22314

    David B or Dana Funk - 1813 Leslie Ave, Alexandria, Virginia 22301

    Mr. & Mrs Michael B. Porterfield - 16 W Bellefonte Ave, Alexandria, Virginia 22301

    Jose Felix Iglesias or Ana J Villanueva, 707 Four Mile Rd, Alexandria, Virginia 22305

    Juan Flores Henriquez - 715 Four Mile Rd, Alexandria, Virginia 22305

    Olvin Ivan Martinez - 713 Four Mile Rd, Alexandria, Virginia 22305

    Owner 628, Notabene Dr. - 636 Notabene Dr - 638 Notabene Dr, Alexandria Virginia 22305

    James R Montgomery - 710 Four Mile Rd , Alexandria, Va 22305

    Janice Wolk Grenadier (JWG) was divorce without a Property Settlement Agreement in 2000. JWG put

    her own earned funds into the above properties from December 1986 / January 1987. Ilona Grenadier Divorce

    lawyer with knowledgeable intend had David Grenadier while still living in the home in November of

    1997 sign a distribution of property without JWG signature and done by a lawyer not licensed in

    Virginia. ( The document had all Virginia Addresses and all properties were Virginia Properties). These

    actions of Ilona Grenadier Heckman with knowledgeable intend left a cloud on your title. The lawyer in

    collusion was Neil Gurvitch - Wecheler, Selzer & Guritch, Chartered / http://www.selzergurvitch.com/ - Ilona

    being a seasoned divorce lawyer knew exactly what she was doing and he as a lawyer went along with it. She

    was also very much aware of how much money she had stolen from Sonia and from JWG with the Help of

    Fagelson et al law firm, Mays and Valentine Law firm that is not Troutman Saunders.

    On or around May 7, 2015 Richard Perry after being a Victim of Virginia for 25 years was given his life

    back. I will continue to fight to get what is rightfully mine by the law even if it takes 25 years from a JUDGE

    WITHOUT JURISDICTION. Ilona Grenadier Heckman and her lawyers have continued to lie in court, lie in

    court documents, and hire people to physically harm me or my daughters. I will never give up until this is made

    right and she is held accountable.

    Ilona Grenadier Grenadier. Anderson, Starace, Duffett & Kieser - Grenadier. Anderson, Starace, Duffett

    & Kieser is guilty of: 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, joint and several liability,

    malpractice, Bribery, Abuse of her Oath of Office, Conspiracy, Collusion, Gang like activity mirror image to

    the Klue Klux Klan, 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, Social,

    United state Constitutional, Virginia Constitutional and Civil Rights, Breach of Fiduciary Duties, Violating

    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 - Judicial Misconduct; Criminal Misconduct; Mail Fraud; Honest Serves Fraud;

    Extortion; Harassment; Gang activity; Racketeering; Retaliation; Discrimination; et al. not limited to:

    decisions made in bad faith for a corrupt purpose, deliberately and intentionally failing to follow the law;

    Extrinsic fraud; Egregious legal errors; Violation of Procedural Rules; Violation of Due Process; uttering,

  • 8

    etc., other writings et al. All of above charges will and can be proven with letters, documents, witnesses who

    have also been harmed by the actions of Plaintiff.

    That Ilona Grenadier Heckman orchestrated and executed since February 14, 1986 the knowledgeable

    manipulation of Plaintiff and others. That the appearance is the collusion of the Judicial System is deliberate

    and with knowledgeable intend, in its planning to harm Plaintiff.

    That Plaintiff reminds this court from the Amended Complaint the serious of actions that took place

    between the Defendants and Plaintiff (as stated):

    1. On or around January 28, 2013 a letter was sent from Homeward Mortgage - Notice of Servicing

    Transfer (RESPA) and Welcome to OCWEN Loan Servicing, LLC [ Ex 8 ]

    2. Homeward Mortgage servicing was the servicer of Plaintiff Loan till February 18, 2013, On February

    19, 2013 OCWEN became the servicer. Homeward Mortgage supervisor had advised Plaintiff three

    different occasions that all documents were in place for the HAMP Modification. Homeward then

    kept coming back with issues that Plaintiff had been told by Homeward that they were cleared up.

    Homeward supervisor had left Plaintiff a message that the Foreclosure had been stayed.

    3. On February 19, 2013 Plaintiff phoned OCWEN to confirm that there had not been an issue that the

    foreclosure had been stayed as the BWW Law Group still showed it active on BWW Law website.

    OCWEN - informed Plaintiff she would need to re-submit documents for the HAMP Program but,

    to Ignore the Foreclosure date that a foreclosure sale cannot be conducted until after the

    evaluation of the HAMP program is complete and a borrower found ineligible. That as long as

    Plaintiff was being considered for the HAMP the foreclosure could not go forward Plaintiff

    went over this at least 3 times with the agent at OCWEN. OCWEN could not have been more helpful

    and tried very hard to be reassuring about the foreclosure. The phone conversation was close to an

    hour going over everything.

    4. On February 20, 2013 Plaintiff phoned OCWEN again and went through the fact the Foreclosure

    was still on the schedule with BWW-Law Group could they please contact BWW-Law. Ocwen

    again reassured Plaintiff they could not foreclose as the process had begun with Ocwen and it

    was illegal for them to Foreclose on Plaintiff.

    5. On February 20, 2013 Plaintiff sent e-mails to BWW Law Group after unsuccessfully being able to

    reach BWW-Law group on the phone in regard to the Foreclosure date. BWW-Law Group

    informed Plaintiff that the alleged owner of the loan Equity Trustees had made the decision and

    planned to move forward and Foreclose on Plaintiffs property. Remember in December of 2012

  • 9

    BWW-Law Group had no idea who owned Plaintiffs loan or who had the original note. [ Ex.9 e-mail

    page 4 of 11]

    6. . Plaintiff continued thru phone calls and several E-mails with BWW-Law Group. [ Ex 9 & 10 ]

    through the end of business on February 20, 2013

    7. Several phone calls to OCWEN and to supervisors at OCWEN, who were at a loss as to how to help

    Plaintiff. OCWEN claimed to have never seen a situation like this. OCWEN kept informing

    Plaintiff that BWW- Law group could not foreclose prior to on or around April 17, 2013 and

    only then if Plaintiffs documents had not been received, by OCWEN.

    8. Plaintiff with no other choose or recourse was forced to file for an involuntary Bankruptcy on

    February 21, 2013.to protect Plaintiffs interest in the property at 15 West Spring Street.

    9. Plaintiff on February 21, 2013 could not get through to a Voice mail or anyone at BWW- Law group.

    Plaintiff took a copy of the receipt for the bankruptcy to the alleged owner of the Loan according to

    BWW-Law Group Equity Trustees which shows an address of 2020 14th Street N., Suite 250

    Arlington Va 22201. Plaintiff chose to take and deliver the receipt because on the website for BWW-

    Law they only show an address in Richmond, VA and Bethesda, Md.

    10. On February 21, 2013 - Plaintiff was surprised / shocked to learn that BWW- Law group and

    Equity Trustees LLC shared an office. The actions of BWW- Law to refuse to turn over a copy of

    Plaintiffs original note and other information under the circumstances and with the offices in the

    same location showed malicious intent to defraud Plaintiff of her due process in the Foreclosure

    process, in the Government backed HAMP program. The Actions of Equity Trustees LLC,

    BWW-Law Group and defendants were and are willful acts that were malicious, violent,

    oppressive, fraudulent, wanton, or grossly reckless.

    11. On February 22, 2013 Plaintiff e-mailed to Allison Melton associate at BWW Law requesting a

    copy of the Spring Street original note Allison an associate with BWW Law Group denied the

    request [ Ex 14]

    12. On March 1, 2013 Plaintiff returned to the offices of BWW- Law Group and Equity Trustees, LLC

    to hand deliver a qualified written request under the Federal Servicer Act, which is a part of the

    Real Estate Settlement Procedures Act, 12 U.S.C. 2605 (e). Requesting by law the information

    Plaintiff had been denied by defendants. [ Ex 11]

    13. The letter reminds Equity Trustees of their responsibility on page 4 That you must acknowledge

    receipt of this qualified written request within 20 business days, pursuant to 12 U.S.C. Section 2605

    (e) (1)(A) and Reg. X Section 2500.21 (e)(1). Equity Trustees LLC according to the internet is

  • 10

    owned by Lawyers and shares office space with BWW-Law Group so is surrounded by lawyers and

    should know the law.

    14. JWG an Entrepreneur of a product lost her funding the minute BWW-Law advertised her home for

    Foreclosure on February 7, 2013. Plaintiff worked diligently with Homeward and OCWEN to

    prevent the Foreclosure and prevent the filing of Bankruptcy.

    15. BWW-Law group f/k/a Bierman, Geesing, Ward & Wood, LLC - That the internet search for

    articles show the Law firm to act in its own best interest ignoring the interest and the best for the

    public.[ Ex 12] and their clients.

    16. BWW- Law Group search of Jacob Geesing partner is known since October 13, 2010 as The

    Robo Trustee [ Ex 13]

    17. Plaintiffs BWW-Law Group attorney Howard N. Bierman also a known Robo signer [Ex 12]

    includes in [Ex 15 ] 4 different signatures on Plaintiffs forged documents by the BWW Law Group.

    The above was copy pasted from the Amended Complaint to remind this court of the acts and

    actions of Defendants.

    Wherefore Plaintiff asks be heard by this court and for all new and supporting information be

    added to the Record so that in Plaintiffs appeal all information of the disingenuous behavior of

    the Defendants can be used in appeal. That this court is responsible for policing itself and its

    lawyers and the appropriate actions on reporting the criminal acts of lawyers and Judges is the

    responsibility of this court. That the Defendants have refused access to their Insurance

    Companys and have made no attempt of settlement as the appearance is the confidence in the

    Courts to block a Pro Se Litigant and to uphold criminal actions of Lawyers. Plaintiff requests

    that the Chief Judge hears this motion.

    Date: June 9, 2015 Respectfully submitted,

    /S/_____________________________

    Janice Wolk Grenadier

    15 West Spring Street

    Alexandria, Virginia 22301

    Telephone (202) 368-7178

    Email [email protected]

    CERTIFICATE OF SERVICE

    I hereby certify that on this 9th day of June, 2015, I served a true and correct copy of the foregoing by First Class United States Mail, postage prepaid, upon the

    following parties:

    Robert R. Michael (VSB #74148)

    BWW Law Group, LLC

    8100 Three Chopt Rd., Suite 240 Richmond, VA 23229

    Counsel for Defendant Equity Trustees, LLC,

    BWW Law Group et al

    Syed Mohsin Reza, Esq.

    Mary Catherine Zinsner Esq.

    Troutman Sanders, LLP

    1850 Towers Crescent Plaza Suite 500

    Tysons Corner, VA 22182 Counsel for Wells Fargo Bank, N.A. and Ocwen

    Loan Servicing, LLC

    Nathaniel Patrick Lee, Esq.

    McGuireWoods, LLP

    1750 Tysons Blvd Suite 1800

    McLean, VA 22102-4215

    June 9, 2015

    Janice Wolk Grenadier

    ProSe