SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION

Case No. 2025 CAB 004804

Frederick J. Shaddock
Plaintiff, v. 
Oksana S. Shaddock
Defendant

OPPOSITION TO EMERGENCY MOTION FOR TEMPORARY OCCUPANCY ORDER AND
INJUNCTION AGAINST EXTRAJUDICIAL EVICTION ATTEMPTS AND FALSE REPORTS

Defendant, Oksana Shaddock, by her attorney, Robert Case Liotta, opposes
Plaintiff” s Motion as follows:

l. This is the sixth Motion (four of which were denominated as "Emergency")
that Plaintiff has filed in this case. The original Complaint (which is subject to a
Motion to Dismiss that has been pending since September 2025) was titled
Complaint for Declaratory Judgment to Void Quitclaim Deed for Defects. The
relief actually requested was to declare the Quit Claim deed null and void and to
confirm that the property, that is Defendant’s sole property titled in her sole name,
is marital. Nothing in the Complaint relates to occupancy of the property or to
eviction. It seems that in Plaintiffs mind, if he filed any case in this Court he can
now file any motion regarding any grievance he may conjure up related to his wife
or the marriage.

2. The Court is again referred to Defendant’s Motion to Dismiss and her Reply
to the Opposition to the Motion to Dismiss wherein she outlines why none of these
matters belong in this Court given the jurisdiction questions and the pendency of a
divorce proceeding in Iowa. The issues raised in this motion and most of the
preceeding ones are issues that belong before the divorce court. No divorce is
pending in the District of Columbia. It is pending in Iowa. She further noted and
notes again, that this motion and any others filed or to be filed will become
moot/dismissed when this Court grants the pending Motion to Dismiss. These
motions are not independent separate causes of action. They are all filed as
motions that presumably relate to the relief requested in the Complaint. They do
not.

3. As previously noted in the Opposition to previous motions, Plaintiff has
aggressively and forcefully occupied Defendant’s District of Columbia cooperative
apartment and established a reign of oppression and harassment over Defendant.
Defendant had intended to move into her apartment for a short term after the
divorce was filed in Iowa and with the goal of renting it. Instead she is faced with
an estranged husband who occupied the apartment before her arrival and refuses to
leave and obstructs her efforts to rent the apartment. Her only hope is to seek a
TRO unless this Court at some point makes it clear to Plaintiff that simply being
married to someone does not include a right to occupy separately owned property

whether such property might be considered marital or not in the context of a
divorce.

4. Plaintiff is requesting that this Court determine that, because Defendant
purchased the cooperative apartment in her sole name in the District of Columbia
after the date of the marriage that he somehow has a right to occupy that apartment
over her objections and in such a way as to thwart any possibility that she can rent
the apartment. Over the many years that the apartment has been hers, she has
rented it for much of that time. Now, separated from her husband and without
employment, she has come to the District of Columbia to try to rent the apartment
before she leaves for Russia to visit her terminally ill father. Renting the apartment
is essential. She arrived to find her estranged husband occupying the apartment and
refusing to leave. Plaintiff owns a house in Iowa where has been living for many
years and to which he can return. There is no viable reason for him to be occupying
the apartment other than his desire to further impoverish his wife during the
pendency of the Iowa divorce. His claim to a right to occupancy seems to be based
upon his claim that the apartment is marital for purposes of divorce and thus he has
the right to occupy the apartment. There is no such occupancy right that flows from
the definition of marital property in the District of Columbia or Iowa. This
apartment has not been the marital home and indeed, Plaintiff has declared the
Iowa house as his residence in the Iowa divorce case. On the other hand, this

apartment has been Defendant’s residence during periods when the parties were
separated and she is now effectively denied quiet possession by Plaintiff’s
takeover. He is now asking this court to sanction his takeover and order that he has
a right to occupy the apartment.