I, Frederick J. Shaddock, being duly sworn, depose and state as follows:

1. I am the Plaintiff in the above-captioned matter, over 18 years of age, competent to testify, and have personal knowledge of the facts set forth herein.

2. Since September 10, 2025 (over 5 months as of January 14, 2026), Defendant Oksana Shaddock has deactivated my key fob access to Harbour Square Condominium Unit S-316 and common areas, including the building gym and swimming pool. This deactivation was reinstated briefly in October 2025 but reactivated again on or about December 6, 2025, via the Harbour Square Residents portal.

3. I have a doctor's order requiring regular exercise and gym access to manage my High Blood Pressure, reduce muscle deterioration, rapid aging, strokes (inability to speak, memory loss), and to maintain overall health.

4. The deactivation has confined me to the unit without independent ability to exit and re-enter the building, preventing me from accessing the gym/pool as medically required. This constitutes physical and mental harm, as I am unable to follow medical advice for exercise and am limited in daily activities.

5. The lack of fob access forces reliance on delivery food (e.g., DoorDash) rather than shopping for organic, healthy options, further impacting my health.

6. Defendant's continued interference with access to the marital condominium exacerbates this harm and will persist until at least the March 6, 2026 hearing unless enjoined.

7. Defendant's actions has caused Plaintiff to miss 4 medical appointments and 2 dental appointments

8. Immediate restoration of my key fob is necessary to prevent further irreparable injury to my health and preserve my use of the marital property pending final equitable distribution.