IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION
| FREDERICK SHADDOCK, 520 N Street SW, S-316, Washington, DC 20024 (Square 0503, Lot 0116). Plaintiff, v. OKSANA SHEMET SHADDOCK, 520 N Street SW, S-316, Washington, DC 20024 Defendant. |
CASE NO. 2025-CAB-004804
MOTION TO WITHDRAW |
COMES NOW Plaintiff, Frederick J. Shaddock, pro se, and respectfully moves this Court for an Order to formally withdraw his consent for Defendant’s use of a marital asset and to grant reciprocal relief. In support, Plaintiff states:
1. Conditional Consent Offered to De-escalate. Plaintiff previously allowed Defendant the use of the marital Mercedes Benz 190e in Iowa (Exhibit R), a vehicle titled solely in Plaintiff's name, as a unilateral good-faith gesture intended to de-escalate conflict. This offer was made with the reasonable expectation that it would facilitate reciprocal good faith, including Plaintiff's use of the marital Mercedes C230 in Washington, D.C. (Exhibit S), for which Defendant retains the only key.
2. Good Faith Met with Bad Faith, Worsening the Conflict. Plaintiff's de-escalatory gesture was met with an escalation of bad faith, including Defendant's reliance on a fraudulent document in these proceedings. This response fundamentally undermined the purpose of Plaintiff's offer and intensified the dispute. Instead of promoting fair marital relations, the Court’s ruling on October 9, 2025, which denied Plaintiff’s access to the D.C. vehicle, has now formalized an inequitable outcome. Defendant has enjoyed full use of the Iowa Mercedes, while the Plaintiff cannot even go down the elevator with an access fob to the DC Mercedes, much less drive it. The foundational condition for Plaintiff’s consent has therefore failed, and the circumstances have materially changed, cementing a severe imbalance.
3. Request for Equitable Balance. It is fundamentally inequitable for one party to have exclusive use of a marital vehicle while the other is denied equivalent access. To restore a balanced status quo and prevent unjust enrichment pending a final resolution of this case, reciprocal action is required.
WHEREFORE, Plaintiff respectfully requests that this Court issue an Order:
a) Formally recognizing the withdrawal of Plaintiff’s consent for Defendant’s
use of the 190e titled in his name;
b) Granting Plaintiff exclusive use of the Iowa Mercedes 190e; or,
in the alternative,
c) Enjoining both parties from using either the Iowa 190e or the Washington,
D.C. C230 until a final equitable distribution is determined.
Respectfully submitted,
/s/ Frederick J. Shaddock
Frederick J. Shaddock
CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of October 2025, a copy of the foregoing Plaintiff’s MOTION TO WITHDRAW CONSENT FOR ASSET USE AND FOR RECIPROCAL RELIEF was served via email upon Robert Case Liotta, Esq. at rcl@ldelaw.com.
/s/ Frederick J. Shaddock
Frederick J. Shaddock