IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW Comes now the Plaintiff, FREDERICK J. SHADDOCK, pro se, and respectfully moves this Court for leave to amend the Complaint to add a count for equitable reformation of title to marital co-op shares for Unit S-316 at Harbour Square Cooperative (520 N Street SW, Washington, DC 20024). In support, Plaintiff states with a heavy heart, seeking not conflict but the fairness our 24-year marriage has earned:

1. Background: This action, born from love's complexities, seeks to void the obviously fraudulent and unrecorded alleged quitclaim deed removing Plaintiff from title, affirm his half-marital interest in S-316 (purchased jointly October 12, 2012), and enjoin access obstructions that have left me feeling confined in the very home we built together. The August 19 TRO granted temporary relief, a small mercy amid the strain, but the October 9 hearing left gaps in title equity, necessitating amendment to preserve our shared assets for the pending Iowa legal separation (Case No. CDCV402064, Jefferson County District Court). Amendment promotes justice (R. 15(a)(2)), as no prior amendments occurred and Defendant has notice via service—allowing us to heal rather than divide.

2. Facts Justifying Amendment: For 24 years, we've supported each other through joys and trials, including Defendant's recent cancer diagnosis, with my contributions to S-316 as marital property (e.g., $1,200/month assessments since 2012, $900/month support 2017-2018, $30/day CashApp) reflecting that bond. Yet title remains solely in Defendant's name—misused for extra-judicial eviction attempts (September 11, 2025, video Exhibit V: Police affirmation of residency, a moment that broke my heart). This omission was an unintentional oversight in our shared life; reformation adds Plaintiff to co-op shares via FlynnCoops.com ($1,000 fee, paid by Plaintiff), securing 50% equity without sale, so we can continue nurturing our connection. Without reformation, the power imbalance—my full Iowa title/access for Defendant since 2006 vs. her denial of DC title and elevator fob—renders separation unviable, forcing divorce and ending our marriage, as Plaintiff lacks a secure 'escape home' for rotations (Exhibit S: Separation Schedule).

The confusion over the March 11, 2025 'Post-Nuptial Agreement' (Exhibit R1: Comparison) arose from Defendant likely sending counsel only the notarized pages 5 (Plaintiff's signature) and 6 (Defendant's signature), leading counsel to assume pages 1-4 from his uncorrected 'before' draft (with typos like 'Divoce' and date errors) were unreviewed and unchanged by Plaintiff. In fact, Plaintiff made 20 changes in his 'Legal Separation Agreement' 'after' version (Exhibit R2: Rick Vs. Frederick Pages 1-4 PDF Comparison), including changing his name from 'Rick' to 'Frederick' and expanding Section 2a for balanced 'Authorized Guest + Occupant' status—creating a fraudulent hybrid that counsel filed without verification, omitting Plaintiff's revisions. Reciprocity, the heart of our marriage, demands this: I immediately added Defendant to title on August 15, 2006, when buying the 5-bedroom house at 806 North 4th Street, Fairfield, IA 52556, granting her 100% access anytime to the house and Mercedes Benz 190E.
 

Meanwhile, Defendant did not add Plaintiff to the DC condo title (as required for marital property) on October 12, 2012, and denies the key to the DC-based Mercedes Benz C230. This power imbalance erodes the trust we've built—how can a wife respect a husband she feels she can exclude from their home with a mere phone call? Marriage thrives on 50/50 ownership of all marital assets, a balance we've lost but can restore together.

3. Legal Basis: Under D.C. Code § 16-910 (equitable distribution), courts reform titles with compassion for marital interests based on contributions and needs (e.g., Bender v. Bender, 292 A.2d 702 (D.C. 1972)—relief for omitted spouses). Amendment adds Count X for "Equitable Reformation of Title": Declare S-316 marital, order Defendant to execute shares addition within 30 days (Plaintiff pays fee), and enjoin further misuse. This relates to existing claims (obviously fraudulent and unrecorded alleged quitclaim deed voiding, access injunction) without prejudice to Defendant, honoring the vulnerability we share.

4. No Prejudice/Delay: Addition consolidates issues for October 31 hearing, requires no new discovery, and aligns with TRO's status quo preservation. Defendant's objections (expected) are outweighed by the equity our long marriage deserves—a chance to rebuild, not break.

WHEREFORE, Plaintiff requests:
a) Grant leave to file attached Amended Complaint (Exhibit A: Redlined version);
b) Declare S-316 marital property and order title reformation (shares addition at FlynnCoops.com, Plaintiff pays $1,000), as denial would force divorce by rendering separation unviable;
c) Expedite review for October 31 hearing or rule on papers, so we can move toward healing.

Respectfully submitted,

/s/ Frederick J. Shaddock
Frederick J. Shaddock, Pro Se
520 N Street SW, Unit S-316
Washington, DC 20024
202-365-6100
Shaddock@Harbour-Square.com
October 20, 2025

Exhibits: (repeated from previous motions for Court's convenience)
Exhibit R1: Rick Vs. Frederick Pages 1-4 PDF (Liotta's "Before" vs. Plaintiff's "After" Version).
Exhibit R2: March 11, 2025 Post-Nuptial Agreement Comparison (Page Switch Analysis).
Exhibit S: Seasonal Semi-year Separation Schedule PDF (Iowa rotation table). https://Shaddock.net/Fred/case/Oksana/separation
Exhibit V: Video of September 11, 2025 Extra-judicial Eviction Attempt http://911HomeJack.com

Certificate of Service

Served via email to Robert C. Liotta, Esq. (rcl@ldelaw.com ), October 20, 2025.
Oksana Shaddock (OksanaShaddock@Gmail.com)