SUPERIOR COURT
FAMILY COURT - DOMESTIC RELATION BRANCH
500 Indiana Avenue, N.W., Washington, D.C.  20001

MOTION TO CONTEST THE JURISDICTION OF THE COURT
 

1. COMES NOW the Defendant - Respondent, by and through counsel and pursuant to Rule 1 of the District of Columbia Rules of Civil Procedure for the sole purpose of challenging this Court's jurisdiction over the subject matter of this action and over the parts herein, specifically the Plaintiff - Petitioner who is not, and was not a bona fide resident of the District of Columbia at the time of filing this action.

2. The Plaintiff's residence within the District of Columbia was suspect at all times, and moreover she left the premises stated in her complaint as her residence in the District on, or before June 26, 2007 and has never returned, according to the Manager and Security personnel at Harbour Square condo, and owners of condo in the complex.  Plaintiff removed all her belongings to her residence in Virginia and to pubic storage on North 10th Street in Arlington Virginia.

3. Since July 1, 2007, 510 N Street SW, Suite N32 of Harbour Square condo has been occupied by other persons, first by Robert R. Stone, and Kathy Nelson under a contract of lease agreement.  The current lease is attached as defendant's exhibit 1 and made part of this special filing.

4. According to the DC Department of Motor Vehicles, Oksana Shaddock has an invalid address flag on her record, as the 510 N Street SW address cannot be verified for her.

5. In a separate, but related case, Shaddock vs. Shaddock filed by defendant herein as Case Number CDCV 400852 of Jefferson County Iowa, the Plaintiff herein Oksana S. Shaddock accepted personal service of process by a special process server, Tony Snesko, within Arlington County, Virginia on July 31, 2007 at 5:15 pm.  A copy of that return is made a part of this filing as defendant's exhibit 2.

6. Oksana Shemet Shaddock has also transferred her mail to P.O. Box 2816 (South Eads Street branch) in Arlington, Virginia 22202

7. Plaintiff in her Complaint for Separation admits she has vacated the "marital residence" prior to filing, and defendant shows herein she did so voluntarily, and moved in to a Virginia residence with a male professional with whom she is believed to have had a relationship during her present marriage.

WHEREFORE, defendant prays that the complaint be dismissed but without prejudice to right to re-file her complaint, and for his costs, and reasonable attorney fees.

Respectfully,

Robert. R. Stone
Counsel for Defendant
PO Box 10041
Arlington, VA  22202
202-744-2618
DC Bar No. 139-032

CERTIFICATE OF SERVICE

I HEREBY CERTIFY, that on this _____  day of January 2008, a copy of the forgoing was sent via fax and first-class postage prepaid to Robert Liotta, Esq., 166 Connecticut Avenue NW, Suite 250, Washington, DC  20009.

_______________________
Robert R. Stone, Esq.