SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
FAMILY COURT
Domestic Relations Branch

Motion for Order of Dismissal of Divorce

Respondent Frederick Shaddock moves the court for an order dismissing this action because the requirements of Grounds for Divorce, Legal Separation, and Annulment, according to § 16-904 of the District of Columbia Code have not been met.

Contrary to requirements a(1) and a(2), both parties have not lived separate and apart for a period of six months.  Plaintiff and Respondent have continuously lived together in the same apartment since August 2008 until the present day.

Contrary to requirement a(c), Plaintiff and Respondent have resided under the same roof, sharing bed and board, and have resumed marital relations since August 2008.

They have not pursued separate lives.  On the contrary, they together celebrated the holidays of Frederick's birthday (October 7, 2008), Thanksgiving 2008, Christmas 2008, New Year's 2009, Wedding Anniversary (January 17, 2009), and President Obama's Inaugural Ball (Mayflower Hotel, January 20, 2009). 

Plaintiff uses the divorce process as a "control mechanism" - to get her husband do things that she would like.  This abuses a process which is publicly funded by the citizens of the District of Columbia for the sincere dissolution of marriage.

Sincerely,

Frederick Shaddock
Plaintiff, Pro Se
510 N Street, SW  N32
Washington, DC  20024
202-829-4444

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 2nd day of February 2009, a copy of the foregoing document was sent via first-class postage prepaid to Robert Case Liotta, Esq. 1666 Connecticut Avenue, NW, Washington, DC 20009.

______________________________
Frederick Shaddock, Pro Se

POINTS OF AUTHORITY

§ 16-904. Grounds for divorce, legal separation, and annulment.

(a) A divorce from the bonds of marriage may be granted if:
(1) both parties to the marriage have mutually and voluntarily lived separate and apart without cohabitation for a period of six months next preceding the commencement of the action;
(2) both parties to the marriage have lived separate and apart without cohabitation for a period of one year next preceding the commencement of the action.
...
(c) For purposes of subsections (1) and (2) of paragraphs (a) and (b) of this section, parties who have pursued separate lives, sharing neither bed nor board, shall be deemed to have lived separate and apart from one another even though:
(1) they reside under the same roof; or
(2) the separation is pursuant to an order of a court.

______________________________
Frederick Shaddock, Pro Se
510 N Street, SW, Apt. N-32
Washington, DC  20024   202-289-4444