From: Robert Case Liotta <rcl@ldelaw.com>
Sent: Thursday, March 5, 2026 11:33 AM
To: fred shaddock.net <fred@shaddock.net>
Cc: Oksana Shaddock <oksanashaddock@gmail.com>; Joe Pavelich <pavelich@spiespavelich.com>
Subject: FOR SETTLEMENT PURPOSES ONLY Re: Proposal to Resolve Key Fob Access Without Further Litigation – Case No. 2025-CAB-004804
 
Dear Mr Shaddock
      I am confused by your demands. The DC Court has dismissed all of your motions that basically requested that it rule that the DC Apartment is marital or that you had any rights of occupancy. Any new complaints will be dismissed on the ground of res judicata. I will also request sanctions for the filing of a frivolous law suit. 
       As I have said many times, the apartment is titled solely to Oksana and you have no rights of occupancy. In a divorce trial you may or may not be granted some monetary award because you were married when the property was purchased . I am unaware of any cases that would suggest that you would get rights of occupancy of property titled to someone else merely because  you are married to the owner. 
      Given the situation, I am requesting that you vacate the property before March 15 to avoid ejectment. You have no right to be occupying that property and you have zero legal standing to rent out someone else’s property.
         One would think that after your defeats in both the DC  and Iowa courts on your groundless  claims that you would understand that you are wrong with regard to your interpretation of the law.
       Please also note that Oksana  can be awarded attorney’s fees to be paid by you at the conclusion of the divorce and the fees that she has had to pay defending against your groundless litigation could be ordered to be reimbursed to her by you.
       Notwithstanding the above, Mr Pavelich and I remain ready to have good faith settlement discussions with you to finalize a Marital Settlement Agreement. I believe you have the draft of such an Agreement. We could start negotiations by you reviewing the draft and then sending it to either Mr Pavelich or me with your specific proposed edits.
                            Sincerely, 
                            Robert Liotta

 

Robert Case Liotta, Esq.
3726 Harrison Street, NW 
Washington, DC 20015
(202) 531 8088 (Mobile)
(202) 797 7700 (Office)  

           

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On Mar 4, 2026, at 10:42 PM, fred shaddock.net <fred@shaddock.net> wrote:

 

Dear Mr. Liotta,

 
Following the recent dismissal of the prior D.C. action and the ongoing Iowa proceeding, I continue to be denied access to the marital condominium (Harbour Square Unit S-316) due to deactivation of my key fob since September 10, 2025.

 
This denial prevents me from using the gym and pool as ordered by my doctor for health maintenance and causes significant ongoing hardship (confinement, inability to enter/exit independently, health deterioration).
To avoid further motions, filings, or hearings in either jurisdiction, I propose the following simple resolution:
If Oksana agrees to this and confirms in writing (or through counsel), I am prepared to pause additional filings in D.C. and focus on settlement discussions in Iowa or D.C.

 
Please let me know by March 6, 2026 whether Oksana will reactivate the fob and cease interference. If not, I will have no choice but to file a new action in D.C. Superior Court for injunctive relief and declaratory judgment concerning marital property access.

 
I remain open to reasonable settlement terms that recognize the marital nature of both properties and avoid unnecessary expense for all parties.

 
Thank you for your attention.
Respectfully,
Frederick J. Shaddock
520 N St SW, Unit S-316
Washington, DC 20024
(202) 365-6100
fred@shaddock.net (mailto:fred@shaddock.net)