IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW Plaintiff, FREDERICK J. SHADDOCK, pro se, and respectfully moves this Court for Reconsideration of any ruling based the fake “Post Nuptial Agreement”, but instead consider Exhibit S.

1. Public Policy Favors Preserving Marriages. The courts have a long-standing policy to err on the side of preserving marriages, and avoid destroying them. Enforcing an alleged, unwitnessed, unexecuted "agreement" that forces a final divorce and the dissolution of a shared City Life / Town Life would run directly counter to this principle.  All this litigation started over an elevator key fob to a marital condo Plaintiff is in possession of for 13 years since 2012.

2. The Practical Necessity of Mutual Support in Aging. Both Plaintiff (age 70) and Defendant (age 56) are facing health challenges that will inevitably increase with age. A final divorce would leave both parties isolated and alone, without the mutual support system that their marital bond provides. They presently have no other probable prospective partners and face the prospect of loneliness and lack of care in their old age. The marital structure is a practical necessity for their future well-being, especially since Defendant has been diagnosed with cancer.

3. De Facto Recognition of Tenancy and Marital Rights. Regardless of any purported agreement, the D.C. Metropolitan Police Department has, in practice, already "ruled" by refusing to evict Plaintiff from 520 N Street SW, S-316. They inspected Plaintiff's valid DC driver's license, bank accounts, IRS tax returns, DC tax returns, Pentagon Federal Credit Union statements, and other mail he received at this address - that is when the Defendant obeys US Code 1705 and does not obstruct his mail.  The Police Officers told the Defendant, through the condo General Manager, that Plaintiff has every right to live in S-316 then left to file report CCN# 25139139.  Police will not assist in an eviction of a spouse without due process and a Court order for division of property after divorce.

4. Plaintiff has always filed taxes with the Defendant from this Harbour Square address since they bought the unit in 2012. The IRS and DC Government recognized S-316 as Plaintiff's lawful marital residence since 2012.  This underscores the reality that this property is a marital asset to which he has a clear right of access.

5. Financial Impossibility of Proposed Division. Defendant Oksana Shaddock has been unemployed since January 2025 when her job was ended as a result the Department Of Government Efficiency (DOGE). Plaintiff Frederick Shaddock is the sole income earner. He is in high demand for employment as a Computer Science graduate of Colgate University in the prestigious Patriot League along with top colleges like William & Mary.
   Defendant is funding this litigation by maxing out her credit cards. Mr. Liotta has kept his "cash cow" in litigation for 16 years, instead of advising in her  best interests to simply cooperate with her husband.  In 2009 Judge Fern Saddler concluded that D.C. Code was not satisfied that "both parties to the marriage have mutually and voluntarily lived separate and apart without cohabitation for a period of six months."  Liotta failed to tell Oksana about the 180 days requirement,  He still billed her $7242.72 for the dismissal. (Exhibit L_LottaLiottaLawyerLootLotteryLie.pdf)
   
   She cannot afford the $1,200 monthly assessment fee (utilities, taxes, amenities) for the Harbour Square condo on her own. As the "bread winner" he is financially responsible for both marital households, the DC condo and Fairfield house.  Without the ability to pay for the DC condo on her own, Defendant would be evicted by Harbour Square, have to sell the unit, and possibly become homeless. Plaintiff has a fundamental and equitable right to full access and use of the DC property he pays for.  He provides the Defendant a free stay at the Fairfield Iowa house. Whenever the couple choose to live in Iowa together, they can offset the $1200/month DC condo fee by renting out their unit S-316, working with General Manager Judy Tyrrell. He needs his working elevator fob back to bring potential renters up the elevator and show the unit, library, gym, swimming pool,and rooftop view of the harbor.

6. Misrepresentation of Negotiations as an Agreement. Defendant’s counsel asserted in today’s hearing that a “Post Nuptial Agreement” exists, dividing the marital properties. This is an egreious mischaracterization. Plaintiff did not sign such a document.  It is a misuse of Plaintiff's digital signature, using an easy technique described in Exhibit Q.  What exists are unaccepted proposals and ongoing negotiations aimed at achieving a Legal Separation, not a divorce. To preserver her 24 year marriage. Defendant needs to understand marital property is 50% not 100% hers.

7. In Limine. There is no formal, executed, witnessed, nor notarized “Post Nuptial Agreement.” Such a significant contract would be a lengthy, formal document, which does not exist. Defendant's counsel's claim on October 9 distracted the Court's time from the Plantiff's core issue: access rights to marital key fob, condo and mail.

8. The Goal is Legal Separation, Not Divorce. Plaintiff’s objective, as stated in all filings, is a Legal Separation. This would preserve the marital union and allow for the shared, rotational use of both marital properties. The enforcement of a purported “agreement” to permanently divide assets would force a divorce outcome and destroy the possibility of the stated goal of enjoyment of both City Life (DC) and Town Life (Fairfield)

9. The Drastic, Unintended Consequences of Enforcement. Treating a negotiation document as a binding contract would force an absolute divorce, mandating Oksana to permanently relinquish her home in Iowa, rent a U-Haul, pack her gardening supplies, clothes, and paintings to live solely in Washington, D.C.  Oksana would never again be able to set foot on the garden she has spent countless hours growing at the Fairfield house. She would never again have tea with her Fairfield friends, or a place for her over 30 paintings.  Likewise, Plaintiff would not have a base from which to do his computer consulting and lobbying work in DC.  This is not the flexible "city and town life" they have built and are negotiating to preserve; it is the destruction of their cherished life.

10. Prejudice and Irreparable Harm. Allowing this mischaracterization to stand would cause immediate and irreparable harm by judicially enforcing a divorce settlement that the parties never finalized and that contradicts Plaintiff’s pleaded objective for a Legal Separation, forcing a final property division that neither party wants.

WHEREFORE, Plaintiff respectfully requests that this Court:
a) Reconsider any finding based on the fake, forged, unwitnessed, unagreed upon “Post Nuptial Agreement”;
b) Clarify the record that the unexecuted fake "agreement" was for ongoing negotiations, not a binding contract;
c) Plaintiff needs access to both marital homes and cars to Separate To in accord with the Exhibit S schedule; and
d) Reaffirm that the objective of this action is to enable Legal Separation (Iowa CDCV402064) to function, which preserves access to marital properties for both spouses, both City Life and Town Life, both apart and together.

Respectfully submitted,

/s/ Frederick J. Shaddock
Frederick J. Shaddock
 

List of Exhibits:

Exhibit L_LottaLiottaLawyerLootLotteryLikeLie.pdf - Liotta's 2009 bill for Petition for Divorce dismissed due to 180 day non-cohabitation requirement at the time, until 2024. He evidently promises Oksana a "lottery-like win" of a large loot from divorce and all she gets are legal bills.

ExhibitM_MailMalfeasance.pdf -U.S. Mail obstruction in violation of Federal Code 1701, a misdemeanor with up to 6 months in jail.

ExhibitQ_QuirkyQuitClaimDeedNotarizedDemo.pdf - a Notarized document verifies the signature, not the content of an agreement.

ExhibitS_SeasonalSemi-yearSeparationSchedule.pdf - Shaddock Seasonal Semi-Year Separation Schedule

CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of October 18, 2025, a copy of the foregoing Plaintiff’s Emergency Motion for Reconsideration and Clarification was served via email upon Robert Case Liotta, Esq. at rcl@ldelaw.com.

Defendant, Oksana Shaddock at OksanaShaddock@Gmail.com

Courtesy notification to General Manager Judy Tyrrell at GM@HarbourSquare.coop

/s/ Frederick J. Shaddock
Frederick J. Shaddock