UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

1:14 –CV – 00827 – LMB – TCBAppeal on Record No. 15-1169

JANICE WOLK GRENADIER (JWG)

V. BWW LAW GROUP, HOWARD BIERMAN, EQUITY TRUSTEES LLC, WELLS FARGO, BANK OF AMERICA, OCWEN LOAN SERVING LLC

PETITON FOR PANEL REHEARING EN BANC FOR APPEAL # 15-1169

That the decision of JUDGES WILKINSON, NIEMEYER AND CIRCUIT JUDGE HAMILTON

UNPUBLISHED OPINION contains no law used. The question all Americans should be asking is since when

do Lawyers, Judges, the Judiciary and the Government rule on a regular basis for the Banks, the Lawyers who

the Banks and Government are paying MILLIONS and do not have to follow the basic RULES and LAWS

of the Supreme Court, Laws of the State, the Constitution of the United States of America and the Virginia State

Constitution? That the question of Due Process of a Pro Se Litigant being shut out of a Trial by Jury, being shut

out of a hearing in a court room by a Judge ruling from Chambers by all appearance by Bias, Retaliation and

Retribution against a Pro Se Litigant, a Pro Se Litigant being held to a higher standard than the Lawyers, a Pro

Se Litigant not being given the same access to the courts for being Poor. That Pro Se litigant Janice demands

Oral Arguments and that a poll be taken of each Judge as to how he votes and results be made available to Pro

Se Litigant and all others. The other questions presented:

1. That no where can a Pro Se Litigant Janice find where it says that the Department of Justice has stated

that since the Banks paid Billions to the Government and Millions to the States for their illegal actions

we will inform our Federal and State Judges to not hold you or your attorneys to the Rules and the Laws

of the Supreme Court.

2. That no where can a Pro Se Litigant Janice find where if the Judge has a personal bias she can rule on it.

3. That no where can a Pro Se Litigant Janice find where it is legal to Scheme against the Government with

the HAMP program.

4. That no where can a Pro Se Litigant Janice find where it is legal for Lawyer Howard Bierman to forge

documents that are filed against ones home.

5. That no where can a Pro Se Litigant Janice find where it is legal for attorneys at BWW Law group to lie

about the ownership of an alleged loan.

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6. That no where can a Pro Se Litigant Janice find where it is not required for the Lawyer

and the Law firm properly served and the Lawyer whom works with the Law firm to lie,

mislead the opponent and not file an answer to the complaint.

7. That in Pro Se Litigants Claims the following is brought to the attention of the Courts and ignored, due

to lawyers who are paid millions and have personal connections with the Bank and Judges:

Count 1 - Federal False Claims Act, 31 U.S.C. § 3729 (a)(1)(A); 31 U. S. C. § 3729 (a)1(B);31 U.S.C. § (a)(1)(C)

1. This is a claim for treble damages and forfeitures under the False Claims Act, 31 U.S.C. § 3729 et seq.

2. The Defendants created, sold or participated in Mortgage backed securities. The Mortgage backed Securities were composed of mortgages bundled to create the securities in which the mortgages lacked the requisites to create a secured, real estate debt obligation, namely:

The legally binding assignments from the originating bank to the securities trust and, and finally, to the foreclosure agent

Recording of Title in the Cities Clerks office Original Note and Mortgage, signed by both borrower and lender. The prospectus for

each mortgage-backed securities trust, and other public statements, falsely represented that the trust held good title to the mortgages and notes bundled in the securities.

3. By Virtue of the wrongful conduct alleged here including, but not limited to, the false signatures used in manufactured mortgage assignments, each of the mortgage-backed securities sold to the Treasury, or other entity funded by the U.S. government, violated state and federal laws and furthered an effort to transfer impaired securities to the Treasury, or other government funded entity. Defendants and their agents and employees falsely represented that they held good title to 15 W. Spring Street. Defendants received millions of dollars in U.S. government funds to provide services involving fraudulent mortgage assignments. Accordingly, the Defendants and their agents and employees knowingly presented or caused to be presented a false or fraudulent claim for payment or approval from the government entity purchasing the mortgage-backed securities.

4. Defendants and their agents and employees falsely represented that they had good title to 15 W. Spring Street. When in Fact they had in there knowledgeable fraudulent actions created a cloud on the Title making the home unsellable.

5. Defendants acted in concert to create fraudulent legal documentation to conceal that the trust was missing title to the asset, thus impairing the value of the security sold to the treasury, or other government funded entity. Each of the mortgage-backed securities sold to the Treasury, or other government funded entity, was in violation of state and federal law.

COUNT 2 - Breach of Contract – Implied Covenant of Good Faith and Fair Dealing – Breach of

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Contractual Duty of Good Faith and Fair Dealing Honest Services 18 U.S.C. §   1346

6. By virtue of the facts stated above, defendants have violated their contractual duty of good faith and fair dealing. Honest Service under 18 U.S.C. §   1346 the Defendants schemed to foreclose on Plaintiff’s home with forged documents, with knowledgeable intend of Fraud.

7. The above defendants and defendant’s representatives breached their contractual duty of good faith and fair dealing when they refused to provide the requested original Note.

8. That the above defendants Breach of Contract includes not limited to their involvement with breaking the chain of title and creating a situation where Plaintiff could not sell the home . The documents speak for themselves the defendants were aware of these breaches.

9. Plaintiff through implied covenant of good faith and Fair Dealing continued to work with the different Servicing groups even after they continued to lose paper work, and make false claims, and advertise her home for a Foreclosure Sale.

10. The defendant’s “flagrantly violated” their Fiduciary responsibility to Plaintiff to deal in Good Faith while Plaintiff continued to deal in Good Faith.

11.That a Breach of Contract was created when the documents by Wells Fargo, Bank of America were forged, by known robo signers.

Count 3 - Violation of the Fair Debt Collection Practices Act (FDCPA) (15 U.S.C 1692, ET SEQ.)

12.Defendants used unfair/unconscionable means to try and foreclose illegally and unethically

on 15 West Spring Street while Plaintiff was under the production of the HAMP program as

described in paragraph 8.

Count 4 - Wrongful Foreclosure Threat – Failure to Comply with HAMP rules

13.HAMP PROHIBITS A PARTICIPATING server from taking several actions including the following:

Proceeding with a foreclosure sale. Any foreclosure sale must be suspended and no new foreclosure action may be initiated during the trial period, and until the borrower has been considered and found ineligible for other available foreclosure prevention options.

Requiring a borrower to make an initial contribution payment pending the processing of the trial period plan before the plan starts.

Soliciting borrowers to opt out of consideration for HAMP during the temporary review period.

Reporting borrowers as delinquent to credit reporting bureaus without explanation. For borrowers who are current when they enter a trial period, the servicer should report the borrower current but on modified payment if the borrower makes timely payments during the trial period. For borrowers who are delinquent when they enter the trial period, the servicer should report in such a manner that accurately reflects the borrower’s current workout status.

Assessing prepayment penalties for full or partial prepayment as part of the 3

modification.14.The HAMP rules where expressed to Plaintiff several times by AHMSI, Homeward and

OCWEN - that you could not be foreclosed on while you were being considered for the program.

15. It is documented that lawyers are nervous of losing the financial gain of Foreclosures stopping due to their illegal and unethical practices. That if the homeowner gets into the HAMP program and an adjustment is made to the loan – the lawyer losses an extra $50,000 or more. he gets from a foreclosure.

16.BWW Law group had no other motivation to foreclose on Plaintiff except for financial gain, greed and the exposure of their illegal and unethical practices.

17.The attached e-mails in the Exhibits back up these intentions being malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

Count 5 Consumer Protection Act

18.Bank of America and Wells Fargo used representatives to use unfair or deceptive acts or practices in forgery and robo signing of documents.

19. The deceptive acts of BWW Law Group caused JWG the loss of Funding for her company, and the opportunity to meet the guidelines needed for the Hamp Loan.  

Count 6Breach of Fiduciary Duty - Unjust Enrichment/Constructive Trust

20.BWW Law breached its Fiduciary Duty when it put its financial gain above the law and the rights of Plaintiff.

21.BWW Law breached its Fiduciary Duty when it ignored the HAMP rules for financial gain and greed.

22.Bank of America and its representatives breached its Fiduciary Duty with the Robo Signing / forgery of documents breaking the chain of title on 15 West Spring Street.

23.Well Fargo and its representative breached its Fiduciary Duty with the Robo Signing / forgery of documents breaking the chain of title on 15 West Spring Street.

24. BWW Law Group, Howard Bierman, and , Mark Galbraith breached their Fiduciary Duty with the refusal of production of the original Note or any proof of the right to Foreclose on 15 West Spring Street.

Count 7Injunctive / Declaratory Relief

25.That Plaintiff now needs to pray this court grants temporary or permanent injunctive relief as Plaintiff resides in the property and as Defendants are seeking, through illegal and unlawful means and without satisfying the necessary legal standing requirements to institute a foreclosure, take possession, custody, and control of the Property.

Count 8Common Law Fraud12 U.S.C 1972

26.On several occasions Plaintiff sent money to the Servicing agency of Wells Fargo and Bank of America to only have funds returned and agreement squashed.

27. It is very well documented that the Mortgage Servicer’s were instructed to not take any

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payments and to "work with you" only after borrowers fall behind in payments. Once borrowers fall behind on purpose and at the lender's request, foreclosure proceedings begin in earnest. The Foreclosure lawyers and their friends are the beneficiary in the game, as is seen in Paragraph 52 with the amount of money Shapiro and Burson have reported making from being one of Freddie Mac Servicers.

28. The defendants or their representatives on several occasions made false statement of material facts. ie OCWEN – “Ignore the Foreclosure it is illegal for them to as you are in the HAMP program process”

29.The defendants and or their representatives making these statements knew or should have known it to be untrue;

30.Plaintiff to whom the statement was made had a right to rely on the statement; but, fortunately knew how deceitful the defendants had been in the past.

31.Plaintiff relied on the statement for as long as time permitted. 32.Plaintiff believes the statement was made for the purpose of inducing the other party to be

able to Foreclose on Plaintiff’s home and gain financially.33.Plaintiff relied on the Banks and their representatives at Homeward and OCWEN to not

foreclose and to give Plaintiff her legal right the opportunity to get Funding for her company and the opportunity to keep her home.

34.These statement made – created a situation that Plaintiff was not able to get the funding needed for her company, giving her the income to qualify for a loan.

Count 9Negligence – the negligent infliction of emotional distress; the intentional infliction of

emotional distress35. The defendant’s had a legal duty to use reasonable care to protect the Chain of Title to the

property at 15 West Spring Street. By not doing this simple act the defendant’s malicious actions caused great emotional distress to Plaintiff.

36. The actions of the actors to cause this emotional distress were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

37. The defendants failed in their duty and unreasonably caused emotional distress to Plaintiff with intentional infliction of emotional distress. The negligence is sufficient to support this cause of action.

38. The defendants were negligent in all actions against Plaintiff and 15 West Spring Street not following the law and the Rules of the HAMP program.

39.The defendants had a Fiduciary Duty to Plaintiff and 15 West Spring Street.Count 10

Constructive Fraud

40.The defendants were deceptive of material misrepresentations of past and existing facts and remained silent when a duty to speak existed.

41.The defendant’s actions were Arbitrary and Capricious absence of a rational connection between the facts found and the choice’s made, made choices that were not in accordance with the law.

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Count 11 Civil Conspiracy

42.The Collusion of the Defendants to prevent Plaintiff from the chance at the HAMP refinance, of the loan for her company, was done with malicious, violent, oppressive, fraudulent, wanton, or grossly reckless intentions.

43.Defendants Civil Conspiracy to Commit Tortious Interference with Contractual Relations abuse of process, intentional infliction of emotional distress,

44.Civil conspiracy to commit injurious falsehood by advertising 15 West Spring St in the newspaper for a Foreclosure Sale that violated the Law and Rules of HAMP.

45.Defendants were in collusion of civil conspiracy to intentionally inflict emotional distress.

That when a Pro Se Litigant files a document in the USDC of the Eastern Division of Virginia

(Alexandria) they must sign document stating they received no help from an attorney giving way for

the law to be used than that as a Pro Se Litigant you are not expected to know the law as a lawyer

would and you are not allowed to consult with a lawyer. "Pleadings in this case are being filed by

Plaintiff In Propria Persona, wherein pleadings are to be considered without regard to

technicalities. Propria, pleadings are not to be held to the same high standards of perfection as

practicing lawyers. See Haines v. Kerner 92 Sct 594, also See Power 914 F2d 1459 (11th

Cir1990), also See Hulsey v. Ownes 63 F3d 354 (5th Cir 1995). also See In Re: HALL v. BELLMON

935 F.2d 1106 (10th Cir. 1991)." In Puckett v. Cox, it was held that a pro-se pleading requires

less stringent reading than one drafted by a lawyer (456 F2d 233 (1972 Sixth Circuit USCA).

Justice Black in Conley v. Gibson, 355 U.S. 41 at 48 (1957)

That dismissal of complaint under Rule 12-B there is legal sufficiency to show Plaintiff is

entitled to relief under his Complaint. A Complaint should not be dismissed for failure to state

a claim unless it appears beyond a doubt that the Plaintiff can prove no set of facts in support

of his claim which would entitle him to relief. See Conley v. Gibson, 355 U.S. 41, 45-46 (1957)

also Neitzke v. Williams, 109 S. Ct 1827, 1832 (1989). Rule 12(b)(6) does not countenance

dismissals based on a judge's disbelief of a complaint's factual allegations. In applying the

Conley standard, the Court will "accept the truth of the well-pleaded factual allegations of the

Complaint."

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Civil Rights Vol 4, US Supreme Court Digest Page 555 Judges not totally immune as seen in

87 SCT 1213 Pierson v. Ray 94 SCT 1683 Scheur v. Rhodes 96 SCT 984 Imbler v. Pathtman 98 SCT 2018 Monell v. Social SVS 98 SCT 2894 Butz v. Economov

That Judges do not have Absolute Immunity, A complaint is actionable against Judges under Title 42 U.S.C. 1985 (3), whose immunity does not extend to conspiracy under color of law. Section 1985(3) reaches both conspiracies under color of law and conspiracies effectuated through purely private conduct.

When Judges violate their oath of office with a total disregard for their oath of office under Title 28 Section 453, All judges take this oath of office swearing to uphold the U.S. Constitution. Or the use of Arbitrary Exercise of Government Powers

Missouri v. Mackey, 127 US 205, 8 S Ct 1161 Minneapolis v. Herrick, 127 US 210, 8 S Ct 1176 Lepper v. Texas 139 US 462, 11 S Ct 577 Giozza v Tiernan, 148 US 657, 13 S Ct 721 Duncan v Missouri, 152 US 377, 14 S Ct 570

Pro Se litigants are entitled to Fees: Pro se litigants may be entitled to Attorney fees and costs under the Civil Rights Attorney's Fee Award Act of 1976, 90 Stat. 2641, as amended 42 USC 1988

The U.S. ConstitutionalCalls for :

The Fifth Amendment, provides in pertinent part that "nor be deprived of life, liberty, or property, without due process of law..." Due process is denied when a meaningful hearing is denied as in this cause.

The Seventh Amendment, provides in pertinent part that "In suits at common law, where the value in controversy shall exceed twenty dollars, the right to trial by jury shall be preserved..." This language does not include a single reference to "manipulation" of a jury by the Court in a conspiracy with lawyers to design a verdict suitable to the Court through the use of lawyer rules, judicial rules, court rules, or otherwise trumped-up legal technicalities and instructions which effectively "handcuffs" the jury. All of these activities are no more or less than a denial of the right to a jury of peers with the constitutional authority to judge both the facts and law

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in a case.

The Thirteenth Amendment, provides in pertinent part that "Neither slavery nor involuntary servitude, except as a punishment for crime....., shall exist within the United States, or any place subject to their jurisdiction" These judges through their private conduct in conspiracy with the lawyer defendants, caused the Court to effectuate this Plaintiff to "Compulsory Involuntary Servitude", an act punishable under Title 18 1584 as a criminal act.

The Fourteenth Amendment Due Process Clause and Equal Protection clause (Section 1), expressly declares no state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law..."

The Fourteenth Amendment, Section 3, provides in pertinent part that "No person shall hold any office, civil or military, under the United States or under any State.....who, having previously taken an oath,....as an executive or judicial officer of any State to support the Constitution of the United States, shall have engaged in insurrection or rebellion against the same...."

USC 14th Amendment (Deprived of the use of property)

Tracy v. Ginzberg 205 US 170, 27 S Ct. 461 Wagner v Leser, 239 US 207, 36 S Ct 66 Fuentes v. Shevin 407 US 67, 92 S Ct 1983 Leis v Flynt, 439 US 438, 99 S Ct 698, 11 Ohio Ops 3rd 302 Kent.Dept. of Corrections v. Thompson, 490 US 454, 109 S Ct 1904

The following constitutes property protected under constitution?

Slaughter-House Cases, 16 Wall 36 Buchanan v Warley, 245 US 60, 38 S Ct 16 Liggett Co. v Baldridge, 278 US 105, 49 S Ct 57 Board of Regents v Roth, 408 US 564, 92 S Ct 2701

Further On Due Process Violation 5th and 14th Case law

Butler v. Perry, 240 US 328, 36 S Ct 288 Brinkerhoff- Faris Trust v Hill, 281 US 673, 50 S Ct 451 Curry v. McCanless, 307 US 357, 59 S Ct 900

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*Rochin v California, 342 US 165, 72 S Ct 25, Alr2d 1396 *Ivanho Irrig. Dist. v. McCracken, 357 US 275, 78 S CT 1174 *Bartkus v Illinois, 359 US 121, 79 S Ct 676 *Gault 387 US 1, 87 S Ct 1428 *Wolff v McDonnell, 418 US 539, 94 S Ct 2963 **Bordenkircher v. Hayes, 434 US 357, 98 S Ct 663 **Rostker v. Goldberg, 453 US 57, 101 S Ct 2646 **States v. Goodwin 457 US 368, 102 S Ct 2485 **Colorado v. Connelly, 479 US 157, 107 S Ct 515 **DeShaney v. Winnebago, 489 US 189, 109 S Ct 998 **Collins v Harker, 112 S Ct. 1061Jurisdiction of the case (Basic element of due process) Powell v. Alabama, 287 US 45, 53 S Ct 55, 84 ALR 527Sense of fair play shocked is not due process (Congress Barred) Galvan v Press, 347 US 522, 74 S Ct 737 Groban 352 US 330, 77 S Ct 510 Kinsella v United States, 361 US 234, 80 S Ct 297 Bodie v Conneticut, 401 US 371, 91 S Ct 780 Ross v Moffitt, 417 US 600, 94 S Ct 2437 United States v. Salerno, 481 US 739, 107 S Ct 2095

14th Amendment is the due process denial right cases include:

Collins v. Harker 112 S Ct 1061 Hebert v Louisiana, 272 US 312, 47 S Ct 103 Georgia Power v Decatur, 281 US 505, 50 S Ct 369

Discrimination as Violation of Due Process (5th Amendment) Cases:

Bowling v Sharpe, 347 US 497, 74 S Ct 693 Schneider v Rusk, 377 US 163, 84 S Ct 1187 Shipiro v Thompson 394 US 618, 89 S ct 1322 United States v Moreno, 413 US 528, 93 S Ct 2821 Johnson v Robinson 415 US 361, 94 S Ct 1160 Buckley v Valeo, 424 US 1, 96 S Ct 612 Mathews v De Castro, 429 US 181, 97 S Ct 431 Fullilove v Klutznick, 448 US 448, 100 S Ct 2758 Lyng v Castillo, 477 US 635, 106 S Ct 2727

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Fourteenth Amendment and 42 USCS 1983 Statutory requirement under color of law: Lugar v Edmondson Oil, 457 US 922, 102 S Ct 2744

Under the Civil Rights A Continuance of Constitutional Issues Title 42 USC 1983 provides in relevant part that: "every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State....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. ..shall be liable to the party injured...."

A Title 42 1985 action which seeks compensatory and punitive damages in conjunction with equitable relief as in this case is considered a legal claim, entitling Plaintiff to a jury trial. See An-Ti v. Michigan Technological Univ., 493 F. Supp. 1137.

Plaintiff alleges a "class based", invidiously discriminatory animus is behind the conspirators' action as the Court records reflect. That the actions were clearly a product of bias and prejudice of the Court. See Griffen v. Breckridge, 403 U.S. 88, 102 (1971)

The U.S. Supreme Court acknowledged in Bray v. Alexandria Women's Health Clinic 113 S.Ct.753 (1993) that the standard announced in Griffen was not restricted to "race" discrimination. It is therefore reasonable to assume that 1985 (3) may be used for "class-based" claims other than race which is alleged in this case.

The defendant lawyers acting in conspiracy with state actors under color of law have become state actors in this case. The U.S. Supreme Court has ruled that "private parties", lawyers in this case, may be held to the same standard of "state actors" where the final and decisive act was carried out in conspiracy with a state actor or state official. See Dennis v. Sparks, 449 U.S. 24, 101 S.Ct., 183 also See Adickes v. S.H. Kress & Co., 398 U.S. 144, 90 S.Ct. 1598.

That Plaintiff's Complaint is based in part on discrimination and political affiliations by lawyers and lawyer-judges, under 42 USCA 1983 & 1985. See reversal case Acevedo-Diaz v Aponte (1993, CA1 Puerto Rico) 1 F3d 62, summary op at (CA1 Puerto Rico) 21 M.L.W. 3212, 14 R.I.L.W. 389.

Section 1985(3) under Title 42 reaches both conspiracies under color of law and conspiracies effectuated through purely private conduct. In this case Plaintiff has alleged a class-based, invidiously discriminatory animus is behind the conspirators' action as the court records reflect. That actionable cause is the treatment of a non-lawyer pro se litigant as a distinct "class-based subject" of the Court, wherein denial of equal protection of the laws and denial of due process was clearly the product of bias and prejudice of the Court. See Griffen v. Breckenridge, 403 U.S. 88, 102 (1971).

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The U.S. Supreme Court acknowledged in Bray v. Alexandria Women's Health Clinic 113 S.Ct. 753 (1993) that the standard announced in Griffen was not restricted to "race" discrimination. It is therefore reasonable to assume that 1985(3) may be used for "class-based" claims other than race as alleged in this case. It is also important to note in Bray the U.S. Supreme Court'sinterpretation of the requirement under 1985(3) that a private conspiracy be one "for the purpose of depriving... any person or "class" of persons of the equal protection of the laws, or of equal privileges and immunities under the laws, which the Court said mandates "an intent to deprive persons of a right guaranteed against private impairment.

The U.S. Supreme Court in Griffen emphasized 1985(3) legislative history was directed to the prevention of deprivations which shall attack the equality of rights of American citizens; that any violation of the right, the animus and effect of which is to strike down the citizen, to the end that he may not enjoy equality of rights as contrasted with his and other citizens' rights, shall be within the scope of remedies... Id. at 100.

Supreme Court has ruled that "private parties" may be held to the same standard of "state actors" in cases such as the instant cause where the final and decisive act was carried out in conspiracy with a state official. See Dennis v. Sparks, 449 U.S. 24, 101 S. Ct., 183 and Adickes v. S.H. Kress & Co., 398 U.S. 144, 90 S. Ct. 1598.

The Complaint should not be dismissed unless it appears to a certainty that Plaintiffs would be entitled to no relief under any state of facts that could be proved in support of the claims. See Gomez v Toledo (1980, US) 64 L Ed 2d 572, 100 S Ct 1920. That Plaintiff has pled and shown criminal acts by the Attorneys and Banks even if not stated properly the complaint should not be dismissed. The ruling of the court in this case held; "Where a plaintiff pleads pro se in a suit for protection of civil rights, the court should endeavor to construe the Plaintiff's pleading without regard to technicalities." In Walter Process Equipment v. Food Machinery 382 U.S. 172 (1965) it was held that in a "motion to dismiss", the material allegations of the complaint are taken as admitted."

The Defendants acts and actions to conspire come under the Rico and Racketeering Case Law: The defendants constitute an illegal enterprise in acts or threat of acts in violation of Civil Rico Federal Racketeering Act USC 18, 1961-1963 et seq. The following are particular violations:

18 USC 241: Conspiracy against Rights of Citizens 18 USC 3: Accessory after the fact, knowing that an offense has been

committed against the United States, relieves, receives, comforts or assiststhe offender in order to hinder or prevent his apprehension, trial or punishment.

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18 USC 242: Deprivation of Rights color of law of rights protected under the Constitution of the U.S. have been plead and prove given in the Exhibits of the Verified Complaint.

18 USC 1341: Mail fraud 18 USC 1343: Wire fraud 18 USC 1503: Obstruction of justice 18 USC 1510: Obstructing of criminal investigation 18 USC 1513: Retaliating against a witness, victim or informant 18 USC 1951: Interference with interstate commerce 18 USC 1621: Perjury 18 USC 1001: Fraud Continued statute of limitation in ongoing activity (conspiracy) (bankruptcy fraud)

That it is very clear that the Plaintiff Janice has been discriminated against, that the law is clear and that the law is being used in a Smoke and Mirrors fashion to protect the BIG BANKS, THE LAWYERS and the Judges are ruling in bias, favoritism, cronyism with retaliation and retribution with Judge Brinkema by all appearance ruling for personal financial conflict as well.

1. That Janice Wolk Grenadier in her Informal Brief was very clear on the law of Jurisdiction of Judge Brinkema. What law not requiring Due Process by a Judge was used in determining her Jurisdiction? Her acts in her Orders and by denying all in person hearings showed a prejudice especially when she allowed Banks and Lawyers the leeway to not respond to the Complaint. That new information of conflict is in appeal.

2. Lack of Discovery, Admission and Depositions: Denied Janice Wolk Grenadier – What law allows for all evidence in a complaint to be ignored including forgery, perjury of attorneys? What law makes forgery of documents filed in the courts against one’s home legal? What law says perjury by a lawyer is legal? What law states a scheme to defraud by an attorney is legal?

3. Motion for Default Judgment for not responding to Complaint – What law allows for attorneys and law firms to ignore the rules of the courts, to not respond to the complaint, to lie to the opposing side even though the opposing side is ProSe?

4. Conflict of Interest with Troutman Sanders – What law allows conflict of Interest for criminal acts of Troutman Sanders (aka Mays and Valentine) against Janice Wolk Grenadier?

That the law is very clear that Complaints are to be answered in a 21 day time frame. The docket shows the

Defendants to be served. The Janice Wolk Grenadier Poor, indigent due to criminal acts against her by the

above Defendants - the Court / the Marshalls took on the responsibility of making sure all parties were served.

The Docket shows all parties served the Docket shows one lawyer for BWW Law Group, Equity Trustees,

Howard Bierman, that lawyer filed an answer to the complaint for Equity Trustees and stated he would be doing

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the same for the others, by all appearance and documentation this was a false statement. That by all appearance

the deliberate actions was to not be held accountable for such acts as forgery and perjury of Howard Bierman

and BWW Law Group as documented and Exhibits showing such truth. Please clarify the law allowing these

knowledgeable criminal acts of attorneys being legal.

That the Case needs to be moved to the next level and be heard En Banc by all the Judges with a That Pro Se

litigant demands Oral Arguments and that a a poll be taken of each Judge as to how he votes and results be

made available to Pro Se Litigant.

The relief that should be and by LAW should be granted is a Default Judgment in favor of the Plaintiff Janice

Wolk Grenadier and all requested in her Verified Complaint as compensation and anything else this court

deems Just. That a strong message needs to be and should be sent to the Banks, the Lawyers and Judge

Binkema.

I, Janice Wolk Grenadier under my unlimited liability and Oath, proceeding in good faith, being of sound mind, having first-hand knowledge, affirm, state, and declare that the facts contained herein are true, correct, and complete and to the best of my ability, under penalty perjury, so help me, God.

Date: August 25, 2015 Respectfully submitted,

/S/_____________________________Janice Wolk Grenadier15 West Spring StreetAlexandria, Virginia 22301Telephone (202) 368-7178

Email jwgrenadier@gmail.com

CERTIFICATE OF SERVICEI hereby certify that on this 25th day of August, 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, LLC8100 Three Chopt Rd., Suite 240Richmond, VA 23229Tel: (804) 521-6121Email: Robert.Michael@bww-law.comCounsel for Defendant Equity Trustees, LLC, BWW Law Group and Howard Bierman

Syed Mohsin Reza, Esq.Mary Catherind ZinsnerTroutman Sanders, LLP1850 Towers Crescent Plaza Suite 500Tysons Corner, VA 22182Email: mohsin.reza@troutmansanders.com

Email: mary.zinsner@troutmansanders.comCounsel for Wells Fargo Bank, N.A. and Ocwen Loan Servicing, LLC

Nathaniel Patrick Lee, Esq.McGuireWoods, LLP1750 Tysons Blvd Suite 1800McLean, VA 22102-4215Email: plee@mcguirewoods.comCounsel for Bank of America, N.A

August 2, 2015 _____________________ Janice Wolk Grenadier Plaintiff, Pro Se

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