IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

Plaintiff, FREDERICK J. SHADDOCK, pro se, files this Sur-Reply as follows:

1. Prejudicial, Last-Minute Filing. Defendant’s “Corrected Reply” was emailed to the Court and served upon Plaintiff via an incorrect Iowa address instead of his often asserted and DMV registered Washington DC address, on the eve of the hearing. This tactic deliberately deprived Plaintiff, a self-represented litigant, of a fair opportunity to respond, constituting ambush and severe prejudice.

2. This Court Has Subject-Matter Jurisdiction. Defendant’s claim that this action cannot be for quiet title is incorrect. An action to void a fraudulent deed that clouds title is a quintessential action “relating to real property” over which this Court has broad jurisdiction under D.C. Code § 11-921. The Complaint’s request to void the deed is a proper cause of action.

3. Lis Pendens is Moot and Proper. Defendant admits in his own filing (Para. 5) that a notice of lis pendens is filed directly with the Recorder of Deeds. Plaintiff has done exactly that this morning, filing the Notice of Lis Pendens (Exhibit P from this morning’s submission). This argument is now moot.

4. The Motion Ignores the Core Issues. Defendant’s filing attempts to narrow the scope to procedural technicalities, wholly ignoring the emergency relief sought for Plaintiff’s denial of access to his home, mailbox, and personal effects, which are the subject of today’s hearing.

WHEREFORE, Plaintiff respectfully requests that the Court deny Defendant’s Motion to Dismiss.

Respectfully submitted,

/s/ Frederick J. Shaddock
Frederick J. Shaddock
October 9, 2025

CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of October 2025, a copy of the foregoing Plaintiff’s Sur-Reply was served via email upon Robert Case Liotta, Esq. at rcl@ldelaw.com.

/s/ Frederick J. Shaddock
Frederick J. Shaddock