IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW the Plaintiff, Frederick J. Shaddock, pro se, opposing Defendant's October 27, 2025 Opposition to Plaintiff's Emergency Motion for Continued Occupancy of Marital Property Order and Injunction Against Extra-Judicial Eviction Attempts and False Reports (§ 16-911) as it relies on a deceptive jurisdictional diversion and flouts established marital property law. Plaintiff states, simply seeking standard equal sharing in the 24-year marriage. 

1. Background: This action a) affirms Plaintiff's half-marital interest in Unit S-316 (Harbour Square Cooperative, 520 N Street SW, Washington, DC ("S-316"), purchased October 12, 2012 over 11 years after their marriage January 17, 2001, b) voiding the obviously fraudulent and unrecorded alleged "quit claim deed", hoax hybrid "post-nuptial", and c) enjoining obstructions. Plaintiff requests the Court declare S-316 marital property under § 16-910, recognizing his financial contributions for over 1/2 of marital assets, and reciprocity (she enjoys full Iowa house access since Plaintiff's purchase (August 2006), as this preserves Legal Separation viability (Iowa Case CDCV402064, Exhibit S: rotational real estate usage schedule) and guides the pending amendment (leave granted October 28, due November 12).

Defendant's opposition dismisses jurisdiction (defer to Iowa) and claims non-marital status of S-316, but this is a "Desperate Deceptive DC Decision Dodging Diversion Delay Decoy - Dropping & Dismissing Divorce in Distant Iowa" (Exhibit DD).  Defendant's Iowa attorney, Joe Pavelich petitioned the Iowa Court on October 3 (Exhibit E2) to limit his representation responsibilities to the November 17 Zoom hearing. This is about protecting Plaintiff's computer files during Defendant's rotational exclusive use of the Iowa property during Legal Separation.  Fair rotational usage of the DC property depends upon this ruling. The November 17 hearing in Iowa is not about divorce.  For a potential 11th divorce proceeding, Defendant would have to hire and bring a new attorney up to date. Yet Liotta appears to cling to a divorce dream  for 18 years of fruitless expensive litigation. He is the only beneficiary "on the shoulder of Oksana", devilishly promising her financial benefits from divorce since 2007.

2. Facts and Marital Status: Since the marriage on January 17, 2001, and a year before, Plaintiff has contributed the majority for the couple's housing costs, from about $1,200 to $2,400//month.  S-316 is not "sole" as claimed. Plaintiff granted Oksana 100% Iowa house title/access (August 15, 2006, 5-bedroom at 806 North 4th Street, Fairfield, IA 52556) and Mercedes 190E.  Marital reciprocity is only fair.

Harbour Square Cooperative management has repeatedly asked Defendant to add any long term occupant to the Authorized Occupant list in accordance with the Bylaws. General Manager Judy Tyrrell wrote on November 1, 2019  (Exhibit M1) "I strongly recommend you consider adding Mr. Shaddock as a short- or long-term guest, otherwise Mr. Shaddock will not be given the same courtesies and services offered to our registered guests and owners." Oksana ignored her.  On 9/11/2025 they both learned that DC Police will not remove a husband upon their command.

Plaintiff is not "obstructing renters" but offers to pay both the DC Coop fee plus the Iowa house from his ample earnings while she is visiting her parents.  He only asks to be declared an Authorized Occupant to make his payments recorded.  Bylaws (and DC Laws) discourage renting to outsiders by making it unprofitable through high fees.  

Recent photos in Exhibit W: Washington, Wharf, Waldorf, Wedded Walks - 8 Within 2 Weeks (October - November 2025) prove no threat exists.  Defendant Oksana flew herself 1,000 miles at her own expense, from Iowa to DC on October 24, 2025 to be with her husband.  They went to a Halloween house party in Virginia, and celebrated his birthday at the Waldorf Astoria restaurant, contradicting Liotta's implication she feels he is "estranged." 

3. Liotta's Litigation Location Legerdemain: DC Courts obviously have jurisdiction over DC property (U.S. Const. art. IV; § 16-910).  Iowa courts defers to situs state for realty. Defendant's Iowan attorney's (Pavelich) request to do the minimum representation confirms no "parallel" dissolution; Defendant's 32 false 911 calls (Exhibit N, including October 27, 2025, Exhibit N2, Police confirmed Plaintiff's DC residency/ID, no crime) and eviction attempts (September 11Exhibit N1) are DC harms, warranting § 16-911 relief. Legal bills exceed $20,000 since 2007 (starting with $7,242 for 2007-DRB-2108 dismissal, Exhibit L), a "cash cow" for Liotta, not in Defendant's interest.  It is unethical to encourage endless fights when marital property truth is clear.

4. No Harassment: Pro se filings are protected (R. Civ. P. 11); Defendant's pattern (false Police calls, lock-out threats) is the harassment (§ 22-3133.01), possibly condoned by Liotta.  Plaintiff support her with 90% of food expense and daily moral/computer/English aid.  Her native languages are Russian and Ukrainian.  She has been unemployed since January 2025.  His support for her amid her cancer diagnosis shows his good faith.  Plaintiff asks for reformation title for equal rights, and will pay the $1,000 fee to at FlynnCoops.com title company.

5. No Delay: Opposition ignores irreparable harm (condo confinement, health risks, high blood pressure, Exhibit Y).

WHEREFORE, Plaintiff requests:
a) Deny Defendant's opposition; grant the emergency motion as prayed;
b) Declare S-316 as marital property under § 16-910, affirming 50/50 equity in time for the Iowa based legal separation and property sharing agreement hearing on November 17;
c) Order title reformation, and proper registry of Plaintiff as an authorized occupant with Coop Management, with door key, mail, and elevator fob rights
d) Expedite review for January 16, 2026 scheduling conference or rule on papers..

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 

EXHIBITS

* = New to this motion

ExhbitDD_20251001LiottaMotionDismissDecoyDiversion.pdf
ExhibitE2_20251003PavelichLimitedIowa_CDCV402064_APAP_349177.PDF
ExhibitL_LottaLiottaLawyerLootLotteryLikeLie_.pdf - $7,242 for Dismissed Divorce Case 2007-DRB-2108
ExhibitM1_ManagementMembershipRecommendMemo.pdf - 11/1/2019 General Manager recommends that Oksana add Frederick as an Authorized Occupant  *
ExhibitN_911NineOneOne_NonEmergencyCalls.pdf   (32 fake Police call situations that Liotta has not censured)
ExhibitN2_911NonEmergency20251027.pdf
ExhibitS_ShaddockSeasonalSeparationSchedule_.pdf - Iowa based Legal Separation Case alternating DC/Iowa property usage schedule
ExhibitW_WashingtonWharfWeddedWalks8Withing2Weeks.pdf - photos of the instant couple out together 16 times, 8 within past 2 weeks despite Defendant being advised not to allow photos to be seen by the Court  *
 

CERTIFICATE OF SERVICE

Served via email to Robert C. Liotta, Esq. (rcl@ldelaw.com ),
Oksana Shaddock, OksanaShaddock@gmail.com

/s/ Frederick J. Shaddock
Frederick J. Shaddock, Pro Se
November 7, 2025