IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW Plaintiff, Frederick Shaddock, who respectfully moves this Court for an order granting him at least temporary use of the marital automobile. In support thereof, Plaintiff states:

1. Plaintiff and Defendant were married in Arlington, Virginia on January 17, 2001

2. Defendant had full use of his pre-marital Mercedes Benz 450 SL purchased before the marriage in 1997, (Exhibit A)
   even after Defendant damaged his car in an accident near the Lincoln Memorial on June 1, 2003.  (Exhibit B)
   Defendant purchased the marital Mercedes Benz C230 on or around May 15, 2004.  (Exhibit C) 

3. Plaintiff has work assisting at a Conference at the Meeting Center in Washington, DC, from September 10-12, 2025. (Exhibit D)
   It will put him in contact with speakers including US Senator Ron Johnson, former Congressman Dennis Kucinich (D-Ohio-10), and U.S. Army Lt. Col. Anthony Shaffer.  The conference location is not practically accessible via public transportation from any available lodging.

4. Defendant currently possesses and controls his keys to the marital Mercedes-Benz C230, parked idly the marital DC condo garage and has denied Plaintiff use of this vehicle, who has not incurred any expense, tickets, or harm to their joint vehicle.  When both Plaintiff (husband) and Defendant (wife) are in DC, the wife actually prefers that the husband drives.

5. In contrast, Plaintiff allows Defendant full access and use of the marital Mercedes-Benz 190e automobile in Iowa puchased in 2005, demonstrating a gross imbalance of access to marital assets.  (Exhibit E)

6. Defendant’s refusal to allow use of the vehicle forces Plaintiff to incur the substantial and unnecessary expense of a rental car for the duration of the Conference.

7. Defendant broke signed a contract allowing Plaintiff to use their Mercedes.  (Exhibit F)

8. Plaintiff has a professional need and a marital right to reasonable use of this marital asset, and will be paying for gas and any car related expenses.

WHEREFORE, Plaintiff respectfully requests this Court:
A. Order Defendant to make the marital Mercedes-Benz C230 available for Plaintiff’s use with key and garage fob.
B. Grant Plaintiff use of the vehicle from September 9-13, 2025, for the purpose of attending his conference.
C. Order Defendant to cease all interference with Plaintiff’s use and enjoyment of marital assets.

Dated: September 8, 2025

Respectfully submitted,
/s/Frederick Shaddock
Frederick Shaddock, Pro Se

Exhibit A https://shaddock.net/vehicle/Mercedes/1980-450SL  

Exhibit B https://shaddock.net/vehicle/Mercedes/1980-450SL/20030601  

Exhibit C https://shaddock.net/vehicle/Mercedes/2001-C230

Exhibit D https://aneta.org/events/20250911DC   

Exhibit E https://shaddock.net/vehicle/Mercedes/1989-190E

Exhibit F https://Shaddock.net/Fred/case/Oksana/HarbourSquare/Mercedes/contract

CERTIFICATE OF SERVICE
I certify that on September 8, 2025, this motion was served personally (and video recorded ) to:
Oksana Shemet Shaddock
Certified mail and emailed to Robert Liotta, Esq. (Attorney for Defendant)
3726 Harrison St NW, Washington, DC 20015