IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW Plaintiff, Frederick Shaddock, appearing pro se, hereby files this Notice to supplement the record in support of his Emergency Ex Parte Motion for Notice of Lis Pendens and Temporary Restraining Order (scheduled for October 9 at 2:00). This Notice provides the Court with critical evidence of Respondent’s pattern of conduct regarding the marital property at issue, which demonstrates bad faith and intent to conceal.

I. BACKGROUND

This case is characterized by a fundamental and telling asymmetry of good faith. Plaintiff’s conduct has consistently reflected the principles of marital partnership and transparency, while Respondent’s has been defined by exclusion, secrecy, and the intentional concealment of marital assets acquired after their marriage of January 17, 2001 subject to DC Code § 16–910(a)(2).

II. EVIDENCE OF DEFENDANT’S PATTERN OF BAD FAITH

A. The Deliberate Exclusion from the Condominium Purchase.
When Respondent purchased the property at 520 N St SW #S-316 in October 2012, she intentionally excluded Plaintiff from the transaction who was at their Iowa house at the time. She did not include her spouse (Plaintiff) with the real estate agent, settlement company, and the Harbour Square Cooperative management. This was not an oversight but a deliberate strategy to unilaterally control the asset. This exclusion was further enforced after closing when Respondent refused to add Plaintiff to the Cooperative’s Guest List (until January 2025) and instructed him to avoid the H. S. Management Office, in an attempt to conceal his marital interest.  However, H. S. Security guards see him drive their marital Mercedes-Benz C230 (purchased 2003) in and out, greet him, and know they are married.

B. The Concealment of Marital Rental Income.
Plaintiff just discovered, after 3 months, that on or about June 5, 2025, Respondent has been secretly renting the subject property to a tenant, Eli Rosenthal, for $2,200 per month (ExhibitA).  After paying the monthly condo fee of $1,200, Respondent retains a net profit of approximately $1,000 per month. This income, a classic marital asset, has been willfully concealed from Plaintiff, representing a diversion and concealment of 3 x $1000 in marital funds. This act is a direct continuation of Respondent’s established pattern of treating this property as her sole asset, in direct contradiction to DC marital property law.

III. CONTRAST WITH PLAINTIFF’S CONDUCT

Plaintiff’s conduct underscores the one-sided nature of Respondent’s bad faith. Back in August 2006, when Plaintiff purchased the marital home at 806 North 4th Street in Fairfield Iowa, he naturally and openly purchased it with Respondent as a co-owner from the outset, a reflection of their partnership and in keeping with principles of marital unity and Iowa Law. Respondent has enjoyed equal rights to use that property and the marital Mercedes-Benz 190e (purchased 2005) for two decades.  Defendant told Plaintiff that she could not afford to help with Iowa house mortgage plus utilities (about $1200/month) because she was "still looking for a renter" for the DC condo, which has no more mortgage but monthly coop fee (also $1200/month).   Defendant caused Ana, an AirBnb guest for an Iowa house room, to postpone her stay thus costing Plaintiff money and making it harder for him to pay Iowa house expenses (Exhibit B). 

IV. CONCLUSION

Respondent’s pattern of conduct—from the purchase in 2012, to the ongoing exclusion, to the recent concealment of significant rental income—demonstrates a 13 year intent to hoard marital assets out of a fear of divorce. Ironically, this very conduct, which demonstrates a fundamental disrespect for Plaintiff’s marital rights and the principles of partnership, is what makes divorce a more likely self-fulfilling prophesy.  So, it is beneficial to marital harmony to legally clarify Plaintiff’s rightful share of the marital estate while averting financial harm.

This pattern directly supports the urgent need for the requested Temporary Restraining Order and Lis Pendens. Without this relief, Respondent will continue to claim unilateral control, causing marital tension, and further dissipating assets, prejudicing Plaintiff’s rights pending the resolution of this matter.

V. PROPOSED CONSOLIDATION

Furthermore, Plaintiff respectfully brings to the Court’s attention that a hearing on the underlying "Complaint to Void the Quit Claim Deed for Defects" is scheduled for October 24, 2025, at 9:30 AM. In the interest of judicial economy and to avoid piecemeal litigation, Plaintiff respectfully requests that the Court consider addressing the merits of the Lis Pendens and TRO at the scheduled October 9th hearing at 2:00 pm, which would provide a complete resolution to both title-related issues two weeks sooner. This would still allow sufficient time for the Defendant to respond to the serious allegations contained in this Notice.

Dated: September 4, 2025

Respectfully submitted,

/Frederick J. Shaddock/

Frederick J. Shaddock, Pro Se

ExhibitA_EliRosenthalMoveInDCJune3Tue6pm_OS.pdf  (Oksana Shaddock's phone)

ExhibitB_Ana20240815CancelIowaDueToOksana_FS.pdf (Frederick Shaddock's phone)

CERTIFICATE OF SERVICE
I certify that on September 4, 2025, this motion was served personally (and video recorded ) to:
Oksana Shemet Shaddock
Certified mail and emailed to Robert Liotta, Esq. (Attorney for Defendant)
3726 Harrison St NW, Washington, DC 20015