UNITED STATES DISTRICT COURT

DISTRICT OF COLUMBIA
ILONA ELY GRENADIER HECKMAN
DAVID M. GRENADIER

Case No. 1:15 mc 01540 UNA

PLAINTIFFS
V.

CASE NO City of Alexandria VA: CL 15 - 003661

JANICE WOLK GRENADIER

WELLS FARGO BANK
GJJV PARTNERSHIP
JAMES WARBASSE
PADRIC KELLY OBRIEN
ARMY NAVY COUNTRY CLUB
DEFENDANTS

COUNTER CLAIM / CROSS COMPLAINT

JANICE WOLK GRENADIER
DEFENDANT
V.
ILONA ELY FREEDMAN GRENADIER HECKMAN ( Ilona)
GREANDIER ANDERSON STARACE DUFFETT & KIESER (Grenadier Law et al)
DAVID MARK GRENADIER (David)
MICHEAL WIESER ESQ (M. WIESER)
DIMUROGINSBERG
BEN DIMURO (BEN)
ANDERA MOSLEY
STATE OF VIRGINIA
BWW LAW GROUP (BWW LAW)
TROUTMAN SANDERS AKA MAYS AND VALENTINE
WELLS FARGO BANK
Plaintiffs AS PUBLIC SERVANTS, INDIVIDUALLY AND IN THEIR OFFICIAL
CAPACITY AS AN OFFICER OF THE COURT WHERE APPLICABLE

MOTION FOR THE FOLLOWING JUDGES TO RECUSE THEMSELVES

UNDER 28 U.S.C. 144 and 28 U.S.C. 455 (a) and (b)(2)
JUDGE JAMES E. BOASBERG, JUDGE BERYL A. HOWELL, JUDGE REGGIE B. WALTON,
JUDGE EMMET G. SULLIVAN, JUDGE AMY BERMAN JACKSON,
JUDGE ELLEN S. HUVELLE, JUDGE RICHARD J. LEON,
JUDGE COLLEEN KOLLAR-KOTELLY

COMES NOW Defendant Janice Wolk Grenadier Poor Person PRO SE here by state, affirm and submits
that the above Judges under the Judicial Canons has shown a bias to the Defendant Janice in support of criminal
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acts of Plaintiff Divorce Lawyer Ilona Grenadier Heckman and should immediately recuse themselves as well
as any Judge who will not rule by the United States Constitution and the Rules of the Supreme Court of the
United States of America., or would show a conflict that would prevent Fairness in the court.
. That the Law requires Self reporting of actions in conflict of the Judge and the Plaintiff Lawyer Ilona
as well as other Plaintiffs as noticed in the Counter Claim - Oaths of Office, Forgery, Perjury
Obstruction of Justice, Libel, slander Deformation of Defendant Janice in Orders, Fraud on the Court
Fraud, Honest Service Fraud 18 U.S.C. 1346 against Defendant Janice et al. The obvious question
becomes: Why arent Plaintiffs - Lawyers / Banks not being held accountable and forced by a Judge to follow
the law. That this in itself shows the continuing disingenuous, with knowledgeable intend and willful acts of
behavior of this court to deny Due Process to Poor Persons, Pro Se Litigants. Further the Scheme of Plaintiffs
and Judge include Professional Code of Ethics Violations, support of hate crimes, mental pain and suffering,
discrimination for religion, intimidation, support of illegal jailing and torture of Defendant to intimidate and
silence, et al that all acts and actions have been knowledgeable willful acts that were and are ongoing malicious,
violent, oppressive, fraudulent, wanton, or grossly reckless.

Introduction for Judicial Recusal

This is a motion pursuant to 28 U.S.C. 144 and 28 U.S.C. 455 (a) and (b)(2), and it is based on the
accusation of a personal, professional bias and appearance of willing to rule by Retribution, Retaliation,
Favoritism and Cronyism with possible financial conflict of JUDGE JAMES E. BOASBERG, JUDGE BERYL A.
HOWELL, JUDGE REGGIE B. WALTON, JUDGE EMMET G. SULLIVAN, JUDGE AMY BERMAN JACKSON,
JUDGE ELLEN S. HUVELLE, JUDGE RICHARD J. LEON, JUDGE COLLEEN KOLLAR-KOTELLY made by Poor

Person Pro Se litigant. That the above Judges have the responsibility to recuse themselves and immediately to
turn that information over to the Prosecuting Attorney and request a Special Grand Jury be convened to
investigate all allegations by Defendant as set out in this, the Motion to Vacate, Orders of November 3, 2015,
and Motion to Re-Open filed on December 2, 2015 along with any other and all information that has been filed
by Defendant. That Defendant first filed in the United States District Court of the District of Columbia due to
that fact she had already been denied her Constitutional rights of Due Process in this court and in the State of
Virginia which should have been and still today should be notice to this Court that Defendant would stand
strong in fighting for her Basic Liberties of Due Process and a Judge with Jurisdiction. A Judge that is not
chosen as a pay back to further through Deformation with libel and slander to Defendant. That Defendant can
show by the Orders in other cases by these Judges and will show further the conflict that the above Judges have
ruled against Defendant with Retribution, Retaliation, Bias, Favoritism, Cronyism and possible FINANCIAL
conflict in this case. The law is very clear and the Plaintiffs and the above Judges were very clear in their
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actions of Obstruction of Justice, Perjury, Forgery, the appearance of owning the Judge, Fraud, Fraud on the
Court, Honest Service Fraud 18 U.S.C. 1346, Professional Code of Ethics Violations, mental pain and
suffering, support of hate crimes, discrimination for religion, intimidation, support of illegal jailing and torture
of Janice to intimidate and silence, et al that all acts and actions have been knowledgeable willful acts that
were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.
The combination of these factors shows virulent bias and hostility toward Poor Person Pro Se Janice by
appearance stemming from Favoritism, Cronyism and possible FINANCIAL conflict clearly satisfy the
standards of both statutes since any reasonable person, apprised of these circumstances, would reasonably
question the Court's impartiality. See Liteky v. United States, 510 U.S. 540, 114 S.Ct. 1147, 127 L.Ed. 2d 474
(1994). Moreover, the explicit provisions of 28 U.S.C. 455 (b)(2), have been satisfied. Marshall v Jerrico Inc
446 US 238, 242, 100 S. Ct 1610, 64 L. Ed 2d 182 (1980) The neutrality requirement helps to guarantee
that life, liberty, or property will not be taken on the basis of an erroneous or distorted conception of facts
or the law This is applicable to this court by application of Article VI of the United States Constitution
and Stone v Powell 428 US 265, 483n. 35, 96 S. Ct. 3037, 49 L.Ed.2d 1067 (1976). State courts, like federal
courts, have a constitutional obligation to safeguard personal liberties and to uphold federal law
That the Judicial Cannons were written as guidelines for Judges due to the self reporting, lack of oversight of
the Judiciary. The above Judges have deliberately violated the Defendant Janice personal liberties and has
wantonly refused to provide due process and equal protection to a Pro Se litigant before the court and has
consistently behaved in a manner inconsistent with that which is needed for full, fair, impartial Orders. The
United States Constitution guarantees an unbiased Judge who will always provide litigants with full protection
of ALL RIGHTS.

Statement of Material Facts

That Defendant as stated in the Motion to Re-Open originally filed in the District of Columbia due to the
knowledge she would never get a fair trial in Virginia and that Judge Clark who would hear this has acted
criminally towards Janice even illegally jailing her. That the above Judges have ruled from Chambers and not
the Bench is only one of many conflicts that Defendant can point to, as well as compromising / tampering with
Defendants files in other cases in this court. Using the words frivolous incoherent et al in Orders not only
shows disrespect and attempt to intimidate, deformation, slander and libel a ProSe Litigant further show the
inability to use real law in dismissing this case. In the past ignoring facts in the Complaints and picking and
choosing ones that Judges can find questionable law to dismiss on or only give partial subjective law shows
further favoritism to the lawyers/banks/plaintiffs.
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That the Plaintiffs have ignored and acted in bad faith for several years that this is a behavior of the plaintiffs
that is being ignored by the Judiciary, the Government and Elected Officials.
That the following Cases in this court have been treated outside the law to protect the criminal acts of Divorce
Lawyer Ilona Grenadier Heckman her gang / Banks that have paid $251 Billion in fines, that the above Judges
in these cases acted by the Judicial Cannons Criminally.

Case No. 1:14-cv-00162-UNA

Case No. 1:13-cv-01152-UNA
Case No. 1:14-cv-01463 -UNA

Argument Recusal of the above Judges

Their are responsibility and consequences of a Judge who has grounds to recuse himself is expected to do so.
If a judge does not know that grounds exist to recuse themselves the error is harmless. If a judge does not recuse
themselves when they should have known to do so, they may be subject to sanctions, which vary by
jurisdiction. Depending on the jurisdiction, if an appellate court finds a judgment to have been made when the
judge in question should have been recused, it may set aside the judgment and return the case for retrial. In this
case the Scheme of Fraud on the Court to work with the Plaintiffs ruling in their favor even with Civil Rights
Violations shows a strong bias to harm and intimidate Pro Se Defendant Janice.
Any judge who does not comply with his oath to the Constitution of the United States, wars against that
Constitution and engages in violation of the Supreme Law of the Land. If a judge does not fully comply with
the Constitution, then his orders are void, In re Sawyer, 124 U.S. 200 (1888), he is without jurisdiction, and
he/she has engaged in an act or acts of treason. U.S. v. Will, 449 U.S. 200, 216, 101 S. Ct. 471, 66 Ed.2d 392,
406 (1980); Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5 L.Ed 257 (1821)
Where an extrajudicial false accusation of a deeply personal and profession nature has been made by the Court
against Pro se Defendant prior to his ever ascending the bench, but manifests itself in his current hostile and
antagonistic frame of mind in a matter over which he is currently presiding, Section 455 (a) of Title 28
mandates that the Court "shall disqualify himself" since his impartiality might reasonably be questioned.
Added to the clear language of Section 445, which requires disqualification where the court's impartiality might
reasonably be questioned, is the forceful holding of the U.S. Supreme Court in Liteky v. U.S., 510 U.S. 540,
557 (1994), clearly requiring disqualification under the circumstances presented here:

"Section 455(a) provides that a judge "shall disqualify himself in any proceeding in which his impartiality might
reasonably be questioned." For present purposes, it should suffice to say that Section 455 (a) is triggered by an
attitude or state of mind so resistant to fair and dispassionate inquiry as to cause a party, the public, or a
reviewing court to have reasonable grounds to question the neutral and objective character of a judge's rulings
or finding" .
The Second Circuit and the Southern District have repeatedly invoked these objective standards in defining the
basis for recusal. Gil Enterprises, Inc. v. Delvy, 79 F.2d 241 (2d Cir. 1996); U.S. v. Occhipinti, 851 F. Supp. 523
(SDNY, 1993). As acknowledged in Grodin v. Random House, Inc., 61 F. 3d. 1045 at 1053, citing appropriate
language in Liteky: "deep seated antagonism makes fair judgment impossible."
The basis for recusal here is premised on an extraordinary false accusation leveled against counsel while the
judge was still in private practice. It was, and is, a personal attack that is extrajudicial. See U.S. v. Serrano, 607
F.2d 1145 (5th Cir. 1979) and U.S. v. Zagaire, 419 F. Supp. 494 (N. Dist. Cal. 1976), where specific note is
taken that extrajudicial attacks of a personal nature are the strongest basis for granting relief.
Nor does it matter that the Court fails to recall the specifics of the event in question: "The goal of section 455(a)
is to avoid even the appearance of partiality. If it would appear to a reasonable person that a judge has
knowledge of facts that would give him an interest in the litigation then an appearance of partiality is
created even though no actual partiality exists because the judge does not recall the facts, because the judge
actually has no interest in the case or because the judge is pure in heart and incorruptible. The judge's
forgetfulness, however, is not the sort of objectively ascertainable fact that can avoid the appearance of
partiality." Lilyeberg v. Health Services Acquisition Corp., 486 U.S. 847, 871 (1988).
The plain language of 28 U.S.C. 455(b)(2) is clear:
(a) Any justice, judge, or magistrate of the United States shall disqualify himself in any proceeding in which
his impartiality might reasonably be questioned.
(b) He shall also disqualify himself in the following circumstances:
(2) Where in private practice he served as lawyer in the matter in controversy, or a lawyer with whom he
previously practiced law served during such association as a lawyer concerning the matter, or the judge or such
lawyer has been a material witness concerning it.
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In discussing the import of 455(b), Chief Justice Rehnquist noted, in his dissent, in Lilyeberg v. Health
Services Acquisition Corp., 486 U.S. 847, 871 (1988) that: "Subsection (b) of 455 sets forth more
particularized situations in which a judge must disqualify himself. Congress intended the provisions of 455
(b) to remove any doubt about recusal in cases where a judge's interest is too closely connected with the
litigation to allow his participation."
Where two separate factors involving a past association with a party and personal animus toward counsel
combine to establish the personal bias and prejudice of the judge, as set forth in a timely and sufficient affidavit,
the allegations must be accepted as true and the Court is required to recuse itself pursuant to 28 U.S.C. 144."
The recusal motion has been filed "at the earliest possible moment after obtaining the facts demonstrating a
basis for recusal." See U.S. v. Occhipinti, 851 F. Supp. 523, 567 (So. Dist., NY 1993). It sets forth the origins of
the Court's bias: an extrajudicial episode and prior association. U.S. v. Zagaire, 419 F. Supp. 494 (No. Dist. Cal.
1976), and documents with particularity the manifestation of bias as reflected in the current proceeding.
As such, and for purposes of Section 144 of Title 28, the allegations of a certified affidavit must be accepted by
the Court as true, and the Court must act in accordance with the mandate of 144 and recuse itself. U.S. v.
Sykes, 7 F. 3d 1331 (7th Cir. 1993).
That the evidence in this case filed shows the Fraud, Perjury, Forgery, Obstruction of Justice, intend
to mentally harm with much suffering by Defendant Janice, Discrimination for Social Hierarchy and
Religious beliefs, the collusion to silence Plaintiff while illegally jailed, Fraud on the Court, Professional

Code of Ethics Violations, support of hate crimes, intimidation, support of illegal jailing and torture of
Defendant Janice to intimidate and silence, et al that all acts and actions have been knowledgeable willful acts
that were and are ongoing malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

Conclusion
THEREFORE, Plaintiff respectfully demands the above Judges to recuse themselves in light of the evidence
detailing prior unethical and illegal conduct which gives Janice good reason to believe that above Judges cannot
hear the above case in a fair and impartial manner. That finding a Judge in the immediate area is difficult and
that the court should look outside of the immediate area for a Judge.

That Judges are and should be held to a High Ethical Standard. That most importantly the
system is set up that it is a self reporting system or those others in the system when they see another
Judge or Lawyer committing an act or actions in violation of their Oath of Office, Fraud on the court,

Honest Service Fraud 18 U.S.C. 1346 or any other action in conflict with the law that they must
report it to the correct authorities or they themselves can be held liable for the criminal acts or actions.
That further Plaintiffs actions as Lawyers be reported to the appropriate officials and be investigated along with
the above Judges by a Special Grand Jury..
That this case be re-opened with the above Judges and any and all other Judges that feel they have a conflict
recuse themselves from this case.
I, Janice Wolk Grenadier, am the Defendant in this action. I personally set forth the allegations of fact in
this Answer and Counter Claim Cross Complaint, and I hereby declare under penalty of perjury that each of said
allegations is true and correct.
Date: December 1, 2015

Respectfully submitted,
/S/_____________________________
Janice Wolk Grenadier
15 West Spring Street
Alexandria, Virginia 22301
Telephone (202) 368-7178
Email jwgrenadier@gmail.com