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 EMERGENCY MOTION FOR TEMPORARY OCCUPANCY ORDER AND INJUNCTION AGAINST EXTRA-JUDICIAL EVICTION ATTEMPTS & FALSE REPORTS (§ 16-911)

COMES NOW the Plaintiff, Frederick Shaddock, pro se, and moves this Court for an emergency temporary order under D.C. Code § 16-911(a) and Superior Court Civil Rule 65, authorizing his continued occupancy of the marital residence at Harbour Square Unit S-316, 500 N Street SW, Washington, D.C. 20024 ("S-316"), and enjoining Defendant from interfering with access pending the January 16, 2026 Scheduling Conference. This relief is urgently needed to prevent irreparable harm: Plaintiff is effectively imprisoned, unable to leave for consulting work for bill payments without risk of permanent lockout.

INTRODUCTION AND EMERGENCY NATURE

1. This case seeks declaratory relief affirming S-316 as marital property (50% equitable interest to Plaintiff) and voiding fraudulent documents (unrecorded Sept 7, 2013 Quit Claim Deed; tampered March 11, 2025 Post-Nuptial Agreement swapping pages 1-4 of our Legal Separation Agreement). The Court's October 29, 2025 Omnibus Order denied related motions without prejudice and granted leave to amend by November 12, 2025, delaying merits to January 16, 2026.  Defendant calls it "harassment" for Plaintiff to defend against 13 years of property rights dissipation attempts.

2. Emergency Facts: Since August 2025, Defendant has obstructed access: Revoking Plaintiff's key fob/elevator privileges; directing Harbour Square management (GM Judy) to bar entry or accept mail (staff letter, Exhibit M); refusing addition to 90-day Guest List or permanent Authorized Occupant List as required by the Bylaws. Plaintiff occupies S-316 but cannot exit without peril.  Defendant retains a Marital Power Imbalance, home access control, and has threatened and attempted to bolt the door from inside, then summon the Cooperative's Security (who enforce her directives) to deny re-entry. Plaintiff cannot accept computer consulting job offers requiring presence in an office building, because he might not be able to go back to his marital condo at his wife's whim, and menopausal mood swings despite her need for his financial support. (Exhibit A2, Affidavit)

3. Defendant's tactics for 100% of DC marital property and dissipation of Plaintiff's escalate:
   (a) Sept 11, 2025 - she called DC police (from Iowa 1,000 miles away) alleging "trespassing," but 2 Officers affirmed Plaintiff's right to stay (Exhibit N1  CCN#25139139 Officer G. Goci & T. Fuller);
   (b) Oct 24, 2025 - she flew 1000 miles from their Iowa home to their DC condo then on October 27, called D.C. police claiming she "felt threatened."  But all 3 Officers refused to remove him, allowing him to stay in his marital condo (report, Exhibit N2 CCN#25163569 lead Officer Nolan Morgan).
   
   (c) Defendant's Entrapment Attempts - she hurls profane insults and takes objects belonging to Plaintiff while recording him with her phone or hidden camera trying to "egg him on" with the plan of showing Police her video, then gaining exclusive access to S-316.  These false emergency calls waste public resources and heighten unilateral lockout or lock change concerns. With the continuance until January 16, Oksana has more 78 days to try this.  Plaintiff must hold his phone camera up to record all interactions with Defendant as proof he did no assault on her.
   Oksana has also changed the master codes to the Iowa House, and refuses to disclose them to the co-owner Plaintiff, basically a lock change. (Exhibit V)

4. Defendant's Deceptive DC Decision Dodging Diversion Delay Decoy to Dropping/Dismissing Divorce in Distant Iowa (Exhibit DD): On March 11, 2025 Defendant signed before a Notary a Legal Separation Agreement, thus dropping the Iowa based divorce.  (Notarized pages 5 & 6 have been misappended to a hoax hybrid "Post-Nuptial Agreement".)  Separation involves no property division or dispute. Since October 3, 2025 Respondent is without representation for a potential divorce when her Iowa attorney Joe Pavelich filed a LIMITED APPEARANCE motion (Exhibit E2 - an exhibit submitted early in this case) basically bowing out due to unpaid legal bills and her behavior. He will only represent her on the matter of her deleting files on Plaintiff's computer related to the case, Destruction of Data on September 18 (Exhibit E), NOT DIVORCE. There is no contention on the title of the Iowa house.  Plaintiff freely shares the title with his wife.  The sole contention between the couple is before this Court in Washington DC. Iowa Courts cannot settle this highly contentious DC matter.  Defendant's DC attorney should have known about this since my October 6 filing, yet still attempts to disrespect and deceive this Court into diverting this definitely DC real estate matter into a case in the process of dropping in an unrelated Court 1000 miles away. An Iowa judge will not and cannot decide on this title dispute for a condo in DC.

5. Defendant's attorney is aware that this is the couple's 10th time to the end of the "Divorce Diving Board" only to back off without taking the plunge. (Exhibit X - Ex-divorce cases, list of 10).  Mr. Liotta first represented her when Judge Fern Saddler dismissed the divorce case 2007 DRB 2108 due to resumed cohabitation, DC Law at the time (Exhibit L).  It should be obvious to him that the couple still cohabitates today, and a divorce has been cancelled yet again.  Yet he asks the Court  to transfer this matter to a former divorce case 1000 miles away.  This keeps his client, over $70000 in credit card debt, with no job since January 2025, in financial straits instead of advising her to stop her 13 year campaign to dispossess her husband of a marital asset, and cooperate with him.  It is not in the Public Interest for the Defendant to hoard marital assets, go into deep debt with legal fees, and cause marital tension and resulting legal action, complaints to the condo management, and false reports to the Police.

6. Plaintiff pays all bills for Iowa house while Defendant pays for DC condo (~$1,200/month each).  Plaintiff has also paid significantly for the DC condo Exhibit X2: EXcel/EXpenses.pdf showing contributions since 2015.   Plaintiff just paid $1525.30 for Iowa house furnace fix and Defendant refuses to pay a penny even though she was there rent free from June 3 - as Defendant is income-less since Jan 2025). Plaintiff pays Iowa house mortgage. Exclusion causes homelessness, lost work, unpaid mortgages—irreparable to marital estate. No prior occupancy order; request ex parte relief within 48 hours, or hearing by Nov 5, 2025. Bond waived (§ 16-911(e)).
    

7. LEGAL BASIS: D.C. Code § 16-911(a) empowers temporary orders for marital home use/occupancy "necessary and proper" during pendency, considering equities (contributions, harm, needs). Pendente lite relief: https://code.dccouncil.gov/us/dc/council/code/sections/16-911
   Courts grant these for status quo preservation in property disputes, even pre-divorce filing (e.g., exclusive/continued use to avoid eviction-like harm; see Tucker v. Tucker, 2019 D.C. Super. LEXIS 12, applying § 16-911 to interim access amid fraud claims).

8. Rule 65 supports preliminary injunctions:
   (a) Likelihood of success (forgery evidence voids Deed; joint title via tax records, Exhibit H);
   (b) Irreparable injury (imminent lockout/prisoner status, police validations of his residency);
   (c) Balance of hardships (favors Plaintiff paying bills; no prejudice to absent Defendant);
   (d) Public interest (fair dissolution, no false police call abuse).

9. Relief is narrow/temporary, mooting denied access motions (Oct 29 Order) and aligning with amendment (Equitable Reformation for title fix).

II. PROPOSED ORDER

Plaintiff proposes the attached Temporary Order directing:
(1) Declare that the condo S-316 is a marital asset;
(2) Continued, and condo management documented, occupancy in S-316 for Plaintiff;
(3) Enjoin Defendant/Management from interference (bolting doors, calling police/security without cause, lock changes, and combinations)
     both at the DC condo and the Iowa house;
(4) Defendant finally (since 2012) complies with Harbour Square Bylaws and adds 13 year occupant Plaintiff to Authorized Occupant List;
(5) return husband's marital Mercedes C230 key;
(6) provides Plaintiff a U.S. Mail key to Box S-316;
(7) Violations = contempt/sanctions.
Effective forthwith; review at Jan 16, 2026 hearing.

WHEREFORE, Plaintiff requests emergency temporary relief as stated, costs as pro se, and such other as just.

Respectfully submitted October 30, 2025,

/s/ Frederick Shaddock
Frederick Shaddock, Pro Se
Harbour Square coop, S-316
Washington, DC 20024
(202) 365-6100
Fred@Shaddock.net

 

 

 

EXHIBITS  (* = new to this filing)
*Exhibit A2 - Affidavit of Frederick Shaddock
*ExhbitDD_20251001LiottaMotionDismissDecoyDiversion.pdf (Liotta's Decoy Diversion)
 ExhibitE_IowaEmergencyMotionTROpreserveData.pdf - filed in Iowa on September 18 -
  Emergency Motion in Fairfield Iowa Court to stop Defendant in the marital Fairfield Iowa house from deleting documents from Plaintiff's computers,
  and submitted with the DC case PLAINTIFF'S CONSOLIDATED OPPOSITION AND EMERGENCY MOTION on October 6
*ExhibitE2_20251003PavelichLimitedIowa_CDCV402064_APAP_349177.PDF - attorney request for LIMITED APPEARANCE
 ExhibitH_ShaddockTaxes2005-2024_WashingtonDCSsnRedacted.pdf
 ExhibitL_LottaLiottaLawyerLootLotteryLikeLie_.pdf  2007 DRB 2108 divorce dismissed due to resumed cohabitation
 ExhibitM_MailMalfeasance_.pdf - Defendant does not permit Plaintiff key
 ExhibitN1_911HomeJack_comPhotos.pdf and 2 DC Police Officers CCN# on 9/11
*ExhibitN2_911NonEmergency20251027.pdf
 ExhibitR2_RickVsFrederickAgreementDifferences.pdf - Legal Separation Agreement
 ExhibitR3_AffidavitOfPost-NuptialPage1-4SwitchFraud_.pdf - Affidavit
 ExhibitS_ShaddockSeasonalSeparationSchedule_.pdf
*ExhibitV_VideoOksanaIowaHouseLockChange.pdf - and transcript
*ExhibitX_10ExDivorceCases.pdf
 

CERTIFICATE OF SERVICE

Copy served on Robert C. Liotta, Esq.  at  rcl@ldelaw.com. and via certified mail of
EMERGENCY MOTION FOR TEMPORARY OCCUPANCY ORDER AND INJUNCTION AGAINST EXTRA-JUDICIAL EVICTION ATTEMPTS & FALSE REPORTS
3726 Harrison Street,
Washington, DC  20015
and OksanaShaddock@Gmail.com

/s/ Frederick Shaddock
October 30, 2025.