SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION

Frederick J. Shaddock
Petitioner
v. Case No. 2025 CAB 004804
Oksana S. Shaddock
Respondent

OPPOSITION TO PENDING MOTIONS

Subsequent to the filing of his Complaint, Plaintiff, filed four motions and a
pleading captioned "Notice of Supplemental Authority and Evidence of
Defendant’s Bad Faith". These Motions are filed in this same case number and are
captioned as follows:
• Emergency Ex parte Motion for Notice of Lis Pendens and TRO.
• Emergency motion for Use of marital Automobile
• Emergency Motion for restoration of Access, declaratory Judgment, Add
Plaintiff to Title
• Motion for Protective order and Declaratory Judgment on Constituional
Grounds

On October 9, 2025 the Court held a hearing on the Motions denominated as
"Emergency" and denied all three. Defendant then abandoned his Motion for a
Protective Order. The Court then notified the parties that it would decide
Defendant’s pending Motion to Dismiss the Complaint before the Scheduling
Hearing now scheduled for Friday, October 3l, 2025. Since the hearing on October
9, 2025 Defendant has filed two additional motions® l) Emergency Motion for
Reconsideration on Financial Grounds and Clarification and (2) a Motion for
Leave to Amend Complaint to Add Equitable Refonnation of Title.

Defendant opposes these Motions as follows:

l. Most of the relief requested is relief that might be provided in a divorce case
that is filed in a proper jurisdiction but no divorce case has been filed in the
District of Columbia nor is there jurisdiction . A divorce case is pending in Iowa.

(In Re The marriage of Fredrick J. Shaddock and Oksana Shemet Shaddock , in
the Iowa District Court for Jefferson County, Case No. 08511 CDCV4020l5) and
that Court may be the appropriate jurisdiction for the adjudication of the Complaint
and these Motions.

2. Defendant has not and will not address the merits or the lack thereof of
these Motions because if the Complaint is dismissed the Motions will become
moot.

3. In the event that the Court deems motions filed during the pendency of a
Motion to Dismiss the underlying Complaint to require an Opposition, Defendant
denies all of the factual allegations set forth in these Motions and opposes the
granting of any of the requested relief.

4. Further, Defendant submits that the Complaint and the filing of numerous
j  motions both in this Court and the Iowa Court are part of a sustained
campaign of harassment directed at Defendant. He admitted to such a campaign
when he wrote to Defendant and Counsel to the effect that he was represented by
"CHATbt, Esquire " which cost him nothing while Defendant had to utilize a
lawyer to respond. To that campaign he has now added a physical component. The
parties were separated under the same roof in their Iowa home. The divorce case
was proceeding. Plaintiff then announced that he was going to visit in the District
of Columbia and he would reside in the Cooperative Apartment titled in
Defendant’s sole name. That apartment is a Cooperative; not a Condominium. It
was bought and paid for solely by Defendant and the shares are all owned by
Defendant. Plaintiff has no rights to occupy the apartment. It has primarily been
occupied by Defendant during times of separation in the marriage (there have been
a few) and it has been rented to tenants with the consent of the Coop Board over
significant periods of time. Defendant had been intending to reside in the
apartment in October and then to rent it out as she is currently without
employment. Instead, Plaintiff suddenly departed Iowa and somehow gained
entrance to the apartment from a staff member at the building; over Defendant’s
objections . He does not, however, have the fob that will allow him building access
and elevator access. He has utilized his access to remove many of Defendant’s
personal papers and tangible personal property. He seems to believe that having
access to the apartment somehow buttresses his claim that the apartment is marital
property despite the fact that occupancy has no relevance to the definition of
marital property set forth in DC Code l6-9l0 and a similar Iowa statute.

WHEREFORE, Defendant requests that the pending Motion to Dismiss be
granted, thereby making any remaining motions moot, or if the Motion to Dismiss
is not granted, to grant Defendant leave to supplement her Opposition and to
schedule a hearing on the motions.

Respectfully Submitted,

Robert Case Liotta
3726 Harrison Street, NW
Washington, DC 200l5
202 53l 8088
Email: rcl@ldelavv.com

POINTS AND AUTHORITIES
Superior Court Rule of Civil Procedure l2(b)(l) through (6). Jurisdiction is
dictated by DC Code Sections ll-l l0l et seq. D. C. Code Section l6-9l0
governs the determination of marital versus non—marital property in a Family
Court case.

CERTIFICATE OF SERVICE
I HEREBY CERT IF Y, that on this 27 day of October 2025 a copy of the foregoing
Opposition to Motions was sent via email and eFile to Frederick J. Shaddock, 806
North 4th Street, Fairfield, Iowa 52556.
Robert Case Liotta