IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW Plaintiff, FREDERICK J. SHADDOCK, acting pro se, respectfully files this Supplemental Notice to bring to the Court’s attention a material misrepresentation in Defendant’s Motion to Dismiss.

I. DEFENDANT RELIES ON A QUESTIONABLE, UNILATERALLY FILED DISMISSAL MOTION

In Point 4 of his Motion (page 3), Defendant’s counsel, Robert Liotta, states:

"Plaintiff executed a Post Nuptial Agreement on March 11, 2025 wherein he again waived any rights he may have had to ownership of The Property."

This is false and misleading. The only document filed on March 11, 2025, was a one-sentence, grammatically awkward "Motion to Dismiss" that Defendant fabricated and filed in the Iowa divorce case, attached as Exhibit F.

The document states in just one sentence, in its entirety:

"COME NOW Petitioner and the Respondent and hereby dismiss the above-entitled action without prejudice."

This document was:

1. Not a "Post Nuptial Agreement" and makes no mention of an agreement, property, waivers, or the DC condo.

2. Forged, as it purported to be from the Plaintiff but was "signed" and filed without his knowledge on March 11.

3. Procedurally improper - Defendants cannot unilaterally dismiss a Petitioner's case (CDCV402015, Exhibit I ). 

4. Presumptuous, as a Defendant can only ask the Judge to dismiss a case, not declare the case dismissed herself, nor declare it with or without prejudice.

5. Granted without Plaintiff's consent, forcing him to file an emergency response in attempt to correct the fraud.

6. Causing the Iowa court to reopening the divorce, and defer the Petitioner's Fee for a new case number (CDCV402064, Exhibit J).

II. DEFENDANT SECURED A DIVORCE DISMISSAL THROUGH INTERNET DISRUPTION.

On the morning of the March 31, 2025, hearing on the forged motion, Defendant, who had direct physical access to the Wi-Fi router, changed the password, locking Plaintiff out of the internet. (Exhibit L, Photos and Narrative of Events). Having severed Plaintiff’s access, Defendant then drove to her attorney's office to attend the Zoom hearing. Plaintiff, unable to restore access, realized he was late and frantically drove to the courthouse but arrived just minutes after the case had been dismissed. This forced Plaintiff to re-file the divorce under CDCV402064.

Defendant’s counsel mischaracterized this contested dismissal as a "Post Nuptial Agreement."  This brings into question the faith with which the defect ridden Quit Claim Deed is sought.  It is an attempt to secure 75% of marital assets upon possible divorce, rather than 50%. She wants 100% of the DC condo plus 50% of the Iowa house.

III. DEFENDANT IS ACTIVELY SABOTAGING THE OCTOBER 9 HEARING AND DAILY LIFE.

Defendant’s ongoing campaign of interference is a threat to an orderly October 9 hearing.

A. Active Technological Sabotage of Hearing Connectivity. Defendant has used the online customer portal for Xfinity to deliberately change the password for the primary Wi-Fi network (SSID: Cris22) at the DC marital residence. This is a calculated act intended to force Plaintiff to rely on a slower, less reliable Verizon phone hotspot for his internet connection, thereby degrading his connectivity with the Court's WebEx hearing.

B. Threats to Physically Displace Plaintiff and Disrupt Hearing Access. Defendant has explicitly threatened via phone recording (Exhibit O) to fly to Washington, D.C., to put Plaintiff "on the street" and deprive him of a stable internet connection for the WebEx hearing. Exhibit N has 30 recordings of other threats for years.  She has changed the marital Wi-Fi password for the DC residence, forcing Plaintiff to rely on his Verizon mobile phone Hotspot, which is slower.  This threat was formally communicated to her attorney, who was put on notice of her intent to disrupt the proceedings. (See Exhibit O, Plaintiff's text to Robert Liotta, Oct. 5, 2025).

IV. REQUEST FOR ORDERS TO ENSURE AN ORDERLY HEARING, PREVENT IRREPARABLE HARM, AND PRESERVE MARITAL ASSETS.

Given this pattern, the following orders are necessary to protect the integrity of the October 9, 2024, hearing and Plaintiff's fundamental rights.

A. Primary Protocol for a WebEx Hearing. To ensure a fair, safe, and orderly proceeding, the Court should order that the parties attend the hearing remotely from separate, internet-stable, and non-quarrelsome locations:
Plaintiff Frederick Shaddock from the marital residence at 520 N Street SW, S-316, Washington, D.C., and
Defendant Oksana Shaddock from the marital residence at 806 North 4th Street, Fairfield, Iowa.

B. Contingency Protocol for an In-Person Hearing. Should the Court consider an in-person hearing, a "race" to control the property is imminent. Plaintiff affirms he will not attempt to lock Defendant out. However, to prevent Defendant from executing an extra-judicial lock-out—consistent with her established pattern—Plaintiff would be forced to race to the condo solely to defend his access. To prevent chaos, the Court could order:
i. Establishing that both parties shall have equal right of access to the marital residence at 520 N Street SW, S-316, until the conclusion of the hearing.
ii. Specifically enjoining both parties from altering locks, activating chain locks, or obstructing the other's access.
iii. Authorizing and directing the Harbour Square Cooperative to take any necessary measures to ensure both parties retain their access rights during this period.

C. Necessary Injunctions Against Harassment and Interference. Regardless of location, the Court could order:
i. Enjoining and restraining Defendant from traveling to D.C. prior to the October 9, 2024, hearing.  Exhibit O
ii. Enjoining and restraining Defendant from contacting the Metropolitan Police Department regarding Plaintiff or the subject property, except to report a bona fide emergency involving imminent risk of physical injury.  Exhibit N
 

D. Protection of Plaintiff's Right to Receive Mail and Essential Documents.
Defendant possesses the only key to the marital mailbox and is willfully obstructing Plaintiff's access to essential financial and legal documents. Exhibit M  To ensure Plaintiff can function and receive his property, the Court could order:
i. Directing the Harbour Square Cooperative to immediately provide Plaintiff with his own key to mailbox 316.
ii. Enjoining Defendant from tampering with, obstructing, discarding, or opening any mail addressed to Plaintiff.
iii. Authorizing Plaintiff to have his mail held for pickup at the local post office if Defendant continues to interfere.

E. Restoration of Utilities and Equal Access to Marital Assets.
Defendant has created an untenable situation by withholding essential utilities and assets.
i. Defendant is ordered to provide Plaintiff with all passwords for the internet at the DC marital residence.
ii. Defendant is ordered to provide Plaintiff with a  key to the marital Mercedes C230 in Washington, D.C.
iii. Plaintiff is likewise ordered to provide Defendant with a key to the marital Mercedes 190e in Fairfield.
iv. The Court shall enjoin both parties from selling, relocating, or impairing the operation of any marital vehicle.

F. Request for Sanctions. Plaintiff requests the Court impose sanctions on Defendant for her bad-faith tactics.

CONCLUSION
Defendant has engaged in a persistent pattern of fraud, sabotage, and harassment that threatens to undermine these proceedings and deprive Plaintiff of his rights, property, and ability to litigate. The requested orders are necessary to prevent the complete disruption of the hearing and to protect Plaintiff from immediate, irreparable harm. The document of March 11, 2025 was a questionable Motion to Dismiss the divorce, and unquestionably not a "Post Nuptial Agreement."  

WHEREFORE, Plaintiff respectfully requests that the Court take appropriate action regarding Defendant's reliance on a demonstrably fraudulent document in support of her Motion to Dismiss the Petitioner's assertion that he never signed a Quit Claim Deed for the above captioned marital property.

Respectfully submitted,
October 6, 2025

/s/Frederick J. Shaddock
Frederick Shaddock, pro se
Email: fred@shaddock.net
Phone: 202-365-6100

INDEX OF EXHIBITS
Attachments which are new, or improved from previous motions, are fully underlined.
All letters are a convenient hyperlink to the Plaintiff's web server of the identical PDFs attached..

Exhibit A - Affidavit that Plaintiff never did (or would) sign such a one-sided Quit Claim Deed on 1 of 2 marital properties.
Exhibit B - Bogus Quit Claim Deed PDF - obviously a forgery - even without the original paper
Exhibit C - Call transcript with DC Recorder of Deeds officer saying the QCD "should have had a Bar Code" at the top right. https://Shaddock.net/video/OksanaQCD
Exhibit D - Demand to Defendant's Counsel to see an original paper document of the PDF and its registration with Recorder of Deeds
Exhibit E - Emergency Motion in Fairfield Iowa Court to stop Defendant in the marital Fairfield Iowa house from deleting documents from Plaintiff's computers
Exhibit F - Fake Motion by Defendant to Dismiss the Jefferson County Iowa Divorce case, forging Plaintiff's signature on 3-112025 improved
Exhibit G - Get going again the divorce with Plaintiff's emergency response to the Jefferson County Iowa Court on 3-20-2025 which proceeds to this day.
Exhibit H - IRS Joint tax return for Plaintiff and Respondent at 520 N Street SW, S-316
Exhibit I - Jefferson County Iowa Court (Fairfield) filings for case CDCV402015 - including the mis-dismissed Exhibit F
Exhibit J - Jefferson County Iowa Court (Fairfield) filings for case CDCV402064 - continuation of divorce 
Exhibit K - <future use>
Exhibit L - Late to hearing by 5 minutes due to wife altering Wifi for Petitioner
Exhibit M - Mail malfeasance, monopolization, and manipulation
Exhibit N - Nine-One-One Non-emergency calls by Defendant for no reason
Exhibit O - Oksana Obstruction of October 9 hearing connectivity for Plaintiff, Wifi password change, Webex

CERTIFICATE OF SERVICE

I, Frederick J. Shaddock, hereby certify that on October 6, 2025, I served a true and correct copy of the OPPOSITION TO MOTION TO DISMISS SUPPLEMENTAL NOTICE upon counsel for Defendant, Robert Case Liotta, via electronic mail at his designated business email address: rcl@ldelaw.com and
Oksana Shemet Shaddock, Respondent (via electronic filing: OksanaShaddock@Gmail.com )

Respectfully submitted,

/s/Frederick J. Shaddock
Frederick J. Shaddock, Plaintiff pro se

https://shaddock.net/Fred/case/Oksana/HarbourSquare/quit/20251001LiottaOksanaQuitClaimDeedFredAnswerSupplement.htm
https://shaddock.net/Fred/case/Oksana/HarbourSquare/quit/20251001LiottaOksanaQuitClaimDeedFredAnswerSupplement.pdf