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. 2026-CAB-001539
EMERGENCY MOTION FOR
|
COMES NOW Plaintiff Frederick J. Shaddock, pro se, respectfully moves the Court for a hearing on the Complaint for Declaratory Judgment and Injunctive Relief filed in this case, and for temporary relief pending that hearing.
I. Statement of Claim
Plaintiff claims that Harbour Square Condominium Unit S-316 is marital property purchased during the marriage, that he is entitled to equal access and use of that property, and that Defendant’s unilateral deactivation of his key fob since September 10, 2025 constitutes an impermissible self-help lockout. Plaintiff further claims that this ongoing lockout has caused him serious and continuing physical harm, including stroke-like symptoms, and that he is entitled to immediate temporary injunctive relief restoring his access pending a full hearing on the merits.
The prior related case (2025-CAB-004804) was dismissed without a hearing on the merits.
This new case (2026-CAB-001539) presents the same core issues: whether Harbour Square Unit S-316 is marital property and whether Plaintiff is entitled to equal access (including a working key fob).
Defendant has deactivated Plaintiff’s key fob since September 10, 2025, denying him independent access to the marital condominium and common areas for over six months. This ongoing lockout is an untreated "open wound" that continues to cause suffering as long as there is ambiguity about the status of the marital condo.
A simple declaration of the obvious from an authority, from this honorable Court - that the property was bought on October 12, 2012 well after the ongoing marriage of January 17, 2001, will finally end 14 years of ongoing marital arguments. .
The lockout prevents Plaintiff from following his doctor’s order for regular exercise and has caused ongoing physical harm, including shaking hands, stroke-like symptoms (inability to speak or remember recent events), and joint atrophy from lack of exercise.
Defendant continues to interfere with Plaintiff’s U.S. mail delivery to the unit in violation of 8 U.S. Code §1701.
Plaintiff is a legal resident of the District of Columbia and has been in physical possession of the unit, with belongings, for years since the marital condo was purchased on October 12, 2012.
Plaintiff requests that the Court schedule a hearing at the earliest convenient date and, pending that hearing, enter a temporary order requiring Defendant to reactivate Plaintiff’s key fob, cease all mail interference, and cease any other interference with his access to the marital property.
II. 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).
Iii. Prayer for Relief
WHEREFORE, Plaintiff requests:
Clear declaration of the Harbour Square condo as marital property
Immediate TRO requiring Defendant to reactivate Plaintiff's key fob and restore full access to Unit S-316 and common areas.
TRO prohibiting further interference with Plaintiff's U.S. Mail delivery to the unit.
Order authorizing the current living-room division arrangement (bookshelves/boxes creating two separate rooms) to maintain peace pending final resolution.
Expedited or ex parte hearing (WebEx preferred).
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 30, 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):