UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF VIRGINIA

____________________________________
JANICE WOLK GRENADIER

Pro se
Plaintiff
v.

Civil Action No. 1:14 cv 00827

BWW LAW GROUP, f/k/a

BIERMAN, GEESING, WARD & Wood, LLC.
HOWARD N. BIERMAN
EQUITY TRUSTEES, LLC
MARK R. GALBRAITH
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 to be allowed into the Record
For Appeal and For Reconsideration
That OCWEN employee under Oath Acknowledged Forgeries by
Bank of America which with Plaintiffs Exhibits showing Forgeries
by Bank of America that include Wells Fargo
Claims in Original and Amended Complaint included Forgery
8 US Code 1324c Penalties for document fraud is being
ignored by Judge Brinkema due to Bias by all appearance from
personal financial loss in or around 2008, from lack of knowledge
of the Judicial Canons and since Janice informed Lee Farkas
that she had a conflict.
That Judge Brinkema has Libel and Slandered Janice Wolk
Grenadier in her Orders to Lee Farkas
Comes Now Plaintiff brings to this court new evidence learned by OCWEN employee under oath
on March 17, 2016 at the law office of Wade, Friedman &Sutter PC stated very clearly after
looking at the evidence included in this suit that Bank of America was involved in forgeries. He
was unaware of Wells Fargo but, the appearance of the documents included in the Original and
Amended Complaint Exhibits filed in the District of Columbia and not refilled in the Virginia
Eastern Division because the Clerk informed Janice that they did not need to be re-filed as they

were stamped into the record separate than the first Complaint, show the forgeries of Securitized
documents create a Fraud under:
8 US Code 1324c: Penalties for document fraud
(a) ACTIVITIES PROHIBITED It is unlawful for any person or entity knowingly
(1) to forge, counterfeit, alter, or falsely make any document for the purpose of satisfying a requirement
of
this chapter or to obtain a benefit under this chapter,
(2) to use, attempt to use, possess, obtain, accept, or receive or to provide any forged, counterfeit,
altered,
or falsely made document in order to satisfy any requirement of this chapter or to obtain a benefit under
this
chapter,
(3) to use or attempt to use or to provide or attempt to provide any document lawfully issued to or with
respect to a person other than the possessor (including a deceased individual) for the purpose of
satisfying a
requirement of this chapter or obtaining a benefit under this chapter,
(4) to accept or receive or to provide any document lawfully issued to or with respect to a person other
than
the possessor (including a deceased individual) for the purpose of complying with section 1324a(b) of this
title (/uscode/text/8/lii:usc:t:8:s:1324a:b) or obtaining a benefit under this chapter, or
(5) to prepare, file, or assist another in preparing or filing, any application for benefits under this chapter,
or
any document required under this chapter, or any document submitted in connection with such
application
or document, with knowledge or in reckless disregard of the fact that such application or document was
falsely made or, in whole or in part, does not relate to the person on whose behalf it was or is being
submitted, or
That several lawyers including OCWENs lawyer was in the room Troutman Sanders aka Mays & Valentine
at the time OCWENs representative admitted under Oath of the knowledge of forgeries. That under the
Professional code of ethics the lawyers are required by law to report such criminal activity.

Plaintiff incorporates / references all documents filed in this case that shows the Pattern and
Practice of the collusion of the Lawyers and the Judge to deny due process. That Judge
Brinkema due to her acts and actions should recuse herself from this case.
A chill of First Amendment-protected conduct constitutes a Constitutional
injury-in-fact sufficient to establish irreparable harm. By taking unconstitutional actions and
ignoring the law and allowing lawyers to not respond to the complaint wrongfully chilled
2

Plaintiffs in her exercise of First Amendment rights to access court, petition the government, and
a fair jury trial further denying Plaintiffs Seventh Amendment and violated Plaintiffs Fifth
Amendment right to an impartial tribunal. As such, Plaintiffs Constitutional rights which were
clearly violated at all times since filing of this Complaint in the USDC of the District of
Columbia. Additionally, Judge Brinkemas orders were entered in retaliation for by all
appearance due to personal financial loss and her belief that DOJ Eric Holder had a right to steal
from the American People the right to Justice in the Courts as his behavior of conflict in dealing
with the Banks and Covington & Burling LLP is well documented. Janice Wolk Grenadier has
thereby been damaged by the actions of the Defendants and Judge Brinkemas Bias.
WHEREFORE, under the authority of Bivens v. Six Unknown Names Agents of Federal
Bureau of Narcotics, 403 U.S. 388 (1971) the original Default against the Defendants all
Defendants with the new evidence should be immediately reconsidered.
Relief Requested : That this court up hold the Law and a Judge with Jurisdiction be appointed.
That the Default be established as it would be if I had a lawyer. That a Trial By Jury is
demanded, and a special Grand Jury be put into place to look into the actions of the Judge and
Lawyers for the above allegations. Ignoring their professional code of ethics. Any and all relief
request in The Bill of Complaint, Motion for Default and anything else this court deems
reasonable.
I, Janice Wolk Grenadier, am the Plaintiff I hereby declare under penalty of perjury that
each of said allegations is true and correct.
Date: April 1, 2016

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

I hereby certify that on this April1 , 2016, 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
Tel: (804) 521-6121

Email: Robert.Michael@bww-law.com
Counsel for Defendant Equity Trustees, LLC, BWW Law
Group and Howard Bierman
Syed Mohsin Reza, Esq.

Mary Catherind Zinsner

Troutman Sanders, LLP
1850 Towers Crescent Plaza Suite 500
Tysons Corner, VA 22182
Email: mohsin.reza@troutmansanders.com
Email: mary.zinsner@troutmansanders.com
Counsel for Wells Fargo Bank, N.A. and Ocwen Loan
Servicing, LLC

McGuireWoods, LLP
1750 Tysons Blvd Suite 1800
McLean, VA 22102-4215
Email: plee@mcguirewoods.com
Counsel for Bank of America, N.A
April 1, 2016
_______________________________
Janice Wolk Grenadier

Nathaniel Patrick Lee, Esq.