COMES NOW Plaintiff Frederick J. Shaddock, pro se, for an Emergency Motion for Temporary Restraining Order, and Preliminary Injunction requesting Immediate Reactivation of Key Fob Access to Marital Condominium, Cessation of Mail Interference, and Authorization of Room Division Arrangement.  This is pursuant to D.C. Code §§ 16-910, 42-3505.01, Super. Ct. Civ. R. 65, and the Court's equitable authority, and moves for an emergency temporary restraining order (TRO) and/or preliminary injunction requiring immediate restoration of Plaintiff's key fob access to Harbour Square Condominium Unit S-316 (address above) and all common areas (exterior doors, elevators, gym, pool), cessation of mail interference, and authorization of the current room division arrangement pending further order or final resolution. Plaintiff requests an expedited or ex parte hearing due to ongoing irreparable harm and Defendant's imminent return to D.C. around April 1, 2026.

I. Introduction & Irreparable Harm

Defendant has deactivated Plaintiff's key fob since September 10, 2025 (now over 6 months), denying independent access to the marital condominium and common areas. This constitutes an extra-judicial self-help lockout of marital property without any court order authorizing exclusive possession or denial of access. No final divorce decree or pendente lite order exists in any jurisdiction granting her such authority.

The lockout prevents Plaintiff from following a doctor's order for regular exercise (gym/pool access) to manage high blood pressure, resulting in documented physical deterioration: shaking hands, limping, and frequent headaches. Confinement to the unit without independent entry/exit constitutes ongoing physical and mental harm. Defendant has also interfered with Plaintiff's U.S. mail delivery to the unit (e.g., instructing the guard to return a Walmart package).

Plaintiff is a legal resident of the District of Columbia (DC driver's license, voter registration, bank checks with this address, physical possession since September 2025). Five D.C. police officers have confirmed Plaintiff's right to stay in the unit since September 11, 2025.Plaintiff satisfies the four-factor test for injunctive relief: likelihood of success, irreparable injury, balance of harms, public interest.

II. Factual Background

1. The parties married January 17, 2001. The condominium was purchased October 10, 2012, during the marriage (marital property under § 16-910) (Exhibit M1 Marriage Certificate; Exhibit D: Deed).
2. A 2013 quit claim deed purporting to transfer Plaintiff's interest is unrecorded and defective (Exhibit B:Bogus Quit Claim Deed).
3. Key fob deactivated September 10, 2025; brief restoration October 2025; deactivated again
   December 6, 2025 via Harbour Square Residents online
4. Defendant has repeatedly attempted to wrongfully evict Plaintiff by lying to the Police, or threatening to.  http://911FakeCalls.com and http://911HomeJack.com   Five (5) Police officers have upheld Plaintiff's right to reside at the S-316 condo each time.
5. Plaintiff has a doctor's order requiring gym/pool access for health maintenance (Exhibit AH: Health Affidavit).
6. Deactivation confines Plaintiff to the unit, preventing independent exit/re-entry and exercise, causing shaking hands, limping, nervous twitching, headaches, and other deterioration.
7. Defendant has interfered with Plaintiff's U.S. Mail and package delivery to the unit (Exhibit M).
8. To maintain peace, Plaintiff has divided the living room into two separate rooms using bookshelves and boxes: one for Defendant's working area, one for Plaintiff's bedroom/work area. Defendant retains the bedroom, with shared kitchen/bath (Exhibit PO).
9. No court order authorizes Defendant's actions or grants her exclusive possession. (Exhibit P Lis Pendens)
10. Civil Protection Order was filed with case 2026-CPO 000871 for an April 10, 2026 hearing about Mr. Liotta's threats to evict on March 15 and Defendants threats for March 30, 2026  (Exhibit PO)  In this letter he admitted his unfamiliarity with co-ownership and  marital property law.

III. Legal Argument

Defendant's deactivation of the key fob is an impermissible self-help lockout of marital property. In D.C., unilateral denial of access (e.g., changing locks, disabling key fobs) is prohibited even against a tenant without judicial process (D.C. Code § 42-3505.01; Mullin v. 8921 Georgia Ave. Corp., 199 A.2d 760 (D.C. 1964)). A fortiori, one spouse may not exclude the other from marital property absent a court order awarding exclusive possession (§ 16-910; Turcotte v. Ford, 494 A.2d 119 (D.C. 1985)).

Mail interference violates federal law (18 U.S.C.§ 1702) and Plaintiff's property rights. The room division arrangement maintains peace and should be authorized to preserve the status quo pending final equitable distribution.   No bond is requested (pro se, good faith).

IV. Prayer for Relief

WHEREFORE, Plaintiff requests:

1. Immediate TRO requiring Defendant to reactivate Plaintiff's key fob and restore full access to Unit S-316 and common areas.
2. TRO prohibiting further interference with Plaintiff's U.S. Mail delivery to the unit.
3. Order authorizing the current living-room division arrangement (bookshelves/boxes creating two separate rooms) to maintain peace pending final resolution.
4. Expedited or ex parte hearing (WebEx preferred).
5. Other relief as just.

Respectfully submitted,

/s/ Frederick J. Shaddock
Frederick J. Shaddock, Pro Se
520 N St SW, Unit S-316
Washington, DC 20024
(202) 365-6100
fred@shaddock.net 
 

Certificate of Service

I certify that on March 28, 2026, a true copy was served by email to:
Robert C. Liotta (rcl@ldelaw.com )
Oksana Shaddock (oksanashaddock@gmail.com )
Joe Pavelich (pavelich@spiespavelich.com)

/s/ Frederick J. Shaddock

Attachments/Exhibits (attach as PDFs):

• ExhibitM1_MarriageCertificate20010117ShaddockFrederickOksana.pdf - marriage (1/17/2001)
• ExhibitD_ HarbourSquare/Deed/Shaddock_Oksana_S_Deed.pdf - Defendant's lie of omission about being married (10/12/2012)
• ExhibitB_BogusOksanaQuitclaimdeed20131207R_.pdf Bogus Quit Claim Deed PDF - obviously a forgery - even without the original paper (12/7/2013)
• ExhibitM_MailMalfeasance_.pdf - violation of Federal US Code § 1701-1708 - and proof or residency
• ExhibitP_LisPendensNotarized&Recorded.pdf - Petitioner has a Lis Penden recorded on the DC condo
• ExhibitR3_AffidavitOfPost-NuptialPage1-4SwitchFraud_.pdf - switch of Notorized pages to suit Respondent

New Exhibits

• ExhibitAH_AffidavitOfHealthImpactOfNoFob.htm   Doctor's Note (exercise/gym order ) lockout timeline, symptoms, mail interference, room division
• ExhibitLL_Liotta Letter (March 5, 2026 – threat of "ejectment" from marital home without due process
• ExhbitiPO_Protection Order (March 28, 2026) - unresolved marital property issue since 2001 causes disharmony