DRAFT

IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

FREDERICK SHADDOCK,
520 N Street SW, S-316, Washington, DC  20024
Plaintiff,
v.
OKSANA SHEMET SHADDOCK,
520 N Street SW, S-316, Washington, DC  20024
Defendant.

CASE NO. 2025-CAB-004804

MOTION FOR LEAVE TO AMEND COMPLAINT
TO ADD CLAIM FOR TORTIOUS INTERFERENCE
WITH BUSINESS RELATIONS AND
FACILITATOR AS CO-DEFENDANT

Comes now the Plaintiff, pro se, pursuant to Super. Ct. Civ. R. 15(a) and (e), and respectfully moves this Court for leave to amend the Complaint to add a claim for tortious interference with business relations arising from post-filing events. In support, Plaintiff states:

  1. Background: This action seeks to void the 2013 quitclaim deed on marital Unit S-316 at Harbour Square (520 N St SW, DC), affirm Plaintiff's half-ownership, and enjoin access obstructions. The Aug 19 TRO granted temporary relief, but the Oct 9 hearing left gaps in addressing ongoing "mistreatment" (e.g., no ruling on key fob), enabling new harms.

  2. New Facts Justifying Amendment: On or about Oct 12, 2025, Defendant remotely changed the Xfinity WiFi password for S-316 from Iowa (where she enjoys full, Plaintiff-paid internet/house/Mercedes), forcing Plaintiff to order a replacement router from Walmart via FedEx for USDA faculty work. The package arrived (photo confirmation at guard station, Exhibit W: FedEx tracking), but was returned under Defendant's/Judy Tyrrell's ("Facilitator") directive, thus disrupting Plaintiff's business operations on a slow Verizon hotspot (5Mbps vs. needed 50Mbps, causing hours of delay).

  3. Legal Basis for Claim: Under DC law, tortious interference requires:
    (a) valid business relationship (Walmart/FedEx contract);
    (b) Defendant's and Facilitator's knowledge;
    (c) intentional inducement of breach (remote sabotage + return);
    (d) improper means (bad-faith marital interference);
    (e) damages (productivity loss, slow hot spot internet, $10,000 cost)
    This supplements the Complaint without prejudice, as events post-dating the original filing.

  4. No Prejudice/Delay: Amendment promotes justice (R. 15(a)(2)), consolidates related claims, and aligns with the TRO's equity goals. No prior amendment; Defendant has notice via service.

  5. Relief Sought: Grant leave to file attached Amended Complaint; and expedite review pre-Oct 31 hearing; award costs if opposed.

Respectfully submitted,
October 16, 2025

/s/ Frederick Shaddock
 Frederick Shaddock, pro se
Fred@Harbour-Square.com
Phone: 202-365-6100

cc: Oksana Shemet Shaddock, Respondent (via electronic filing)
Robert Case Liotta, Esq. (Counsel for Respondent)
Judy Tyrrell (via electronic filing)