IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

COMES NOW  the Plaintiff, FREDERICK J. SHADDOCK, pro se, and files this Amended Complaint pursuant to the Court's October 28, 2025 Order granting leave to amend on or by November 12, 2025. This amendment adds Count IV for Equitable Reformation of Title, building on the original claims to affirm marital interests in Harbour Square Cooperative, 520 N Street SW, S-316, Washington, DC 20024 ("DC Condo") and related assets. The original Complaint, filed on July 24, 2025, is Exhibit 0 herein, preserving all requests.  Plaintiff states:

I. PARTIES

1.  Plaintiff Frederick J. Shaddock is an individual residing at 520 N Street SW, S-316, Washington, DC 20024 ("DC Condo"), a DC resident for most years since 1985, and co-owner of marital property with Defendant.
2.   Defendant Oksana Shemet Shaddock is an individual also residing at DC Condo and married to Plaintiff since January 17, 2001 in Arlington, Virginia.

II. JURISDICTION AND VENUE
3.  This Court has jurisdiction under D.C. Code § 11-921(1) and § 16-910 (equitable distribution of marital property). Venue is proper as the property is located in Washington, DC.

III. FACTUAL ALLEGATIONS
4.  The Parties married January 17, 2001 in Arlington, Virginia, and moved to the Harbour Square Cooperative at 520 N Street SW, N-32 ("1st Condo") purchased solely by the Plaintiff, who paid all expenses as she applied for U.S. Citizenship from Russia, finished her MBA, and interviewed for work. He added his wife (Defendant) to the coop's Authorized Occupant list to enjoy full rights, pool/gym access, keys, and fob.
5.  Plaintiff purchased a five bedroom house at 806 North 4th Street, Fairfield, IA 52556 ("Iowa House") on August 15, 2006 and immediately added his wife (Defendant) to the title and granted her full 100% access to the home, and his fully paid for Mercedes 190e.
6. On October 10, 2012, Defendant purchased the DC Condo yet omitted Plaintiff from the title and denied her husband Authorized Occupant status, Cooperative voting rights, elevator fob, and 2001 Mercedes C230 key, thus creating a power imbalance injurious to marital harmony.
7.  Defendant, through her attorney, has waged a 13 year Campaign Appropriating Husband's Marital Property ("CAHMP") since dismissed 2007-DRB-2108 to separate him from his rightful marital properties.  CAHMP attempts began with the December 7, 2013 unrecorded, forged "Quit Claim Deed", through the March 11, 2025 hoax hybrid "Post-Nuptial Agreement" (Exhibit R2).
8.  CAHMP attempts include obstruction of any mail proving DC residency (Exhibit M - Pentagon Federal checks, DMV license, U.S. Code § 1701), and WiFi cutoff to make it hard for him to do computer consulting work.
9.  CAHMP most egregiously includes 33 fake-emergency 911 calls (Exhibit N: 911FakeCalls.com), September 11 and October 27 eviction attempts (Exhibits N1, N2, N3).  Police affirmed Plaintiff's legal residency on each instance. 
10.  The Seasonal Separation Schedule (Exhibit S) requires equitable access for both parties at both properties, to be negotiated on November 17 in Iowa Case CDCV402064.
11.  On September 28, 2025, Defendant Oksana denied access to paid tenant Jonitka Scott, an African American renter (Exhibit J - Jonitka Affidavit).  Fairfield Iowa Police affirmed her right to stay, per Police Report PD#2506260. White tenants Edith and Amber moved out in solidarity with Jonitka. After Defendant moved from Iowa House to DC Condo on October 24, Plaintiff restored Jonitka's access and equal rights as a tenant at Iowa House. However Defendant, via phone from DC, again accused Jonitka (Exhibit N3 Oct 27). Police again affirmed her right to stay.
12. On October 27, 2025, Defendant instructed third parties Mary Jones and Chris Haggard to enter the Iowa House and remove items without Petitioner's consent, thus disrupting tenant Jonitka. (Exhibit N2, PD#2506908)  Mary then made a call from Iowa, 1000 miles to the DC Police to ask them to remove Plaintiff from the DC Condo. The Police again affirmed Plaintiff's right of residency. This power imbalance at both marital properties dissipates assets and causes Defendant to try to misuse Police to acquire 100% ownership of marital real estate, rather than the usual 50%. 

IV. COUNTS
Count I: Declaration of Marital Property (Original)
13.  DC Condo is marital under § 16-910; declare 50/50 equity, as is the Iowa House.

Count II: Void Fraudulent Quit Caim Deed (Original)
14.  The 2013 "Quit Claim" is void for fraud (unrecorded, Exhibit B).

Count III: Injunction Against Obstructions (Original)
15.  Enjoin eviction, threats, access denial.

Count IV: Equitable Reformation of Title (New)
16.  Reform DC Condo title to add Plaintiff (50/50 shares via title company (FlynnCoops.com) with approximate $1000 cost paid by Plaintiff, recognizing contributions and reciprocity.

PRAYER FOR RELIEF
WHEREFORE, Plaintiff requests:
a) Declare DC Condo is marital with 50/50 equity, same as the undisputedly marital Iowa House;
b) Void "quit claim" and "Post-Nuptial" Campaign Appropriating Husband's Marital Property (CAHMP);
c) Reform title, with approximately $1000 cost paid by Plaintiff to the title company;
d) Enjoin obstructions, including lock-outs, on either property, for Plaintiff, or tenants, regardless of race;
e) Such other relief as just.

Respectfully submitted,

/s/ Frederick J. Shaddock
Frederick J. Shaddock, Pro Se
520 N Street SW, S-316
Washington, DC 20024
202-365-6100
Shaddock@Harbour-Square.com
November 7, 2025

Certificate of Service

Served via email to Robert C. Liotta, Esq. (rcl@ldelaw.com), and
Oksana Shaddock. Defendant, OksanaShaddock@gmail.com
November 7, 2025.
 

Exhibits

Exhibit0_20250724ComplaintToVoidQuitClaimDeedForDefects.pdf - original Complaint filed on July 24, 2025

ExhibitB_BogusOksanaQuitclaimdeed20131207R.pdf - Bogus "Quit Claim Deed" unrecorded, misusing electronic signature and notary

ExhibitJ_JonitkaScottAffidavit.pdf - Affidavit by Jonitka Scott that Defendant discriminated against her tenancy at Iowa House, September 28, 2025 PD#2506260

ExhibitM_MailMalfeasance_.pdf - obstruction of mail proving Plaintiff's DC residency (Pentagon Federal bank checks and DMV license), U.S. Code § 1701

ExhibitN_911NineOneOne_NonEmergencyCalls.pdf - Campaign of 33 threats to call 911 for non-emergency reasons for CAHMP

ExhibitN1_911HomeJack_comPhotos.pdf - false "trespassing charge. DC Police affirmed Plaintiff's right to residency, 9/11/2025

ExhibitN2_911NonEmergency20251027Iowa.pdf - Defendant accused tenant Jonitka Scott of "trespassing" at Iowa House, October 27, 2025

ExhibitN3_911NonEmergency20251027DC.pdf - false "trespassing" charge.  Police affirmed Plaintiff's right to residency, October 27, 2025

ExhibitR2_RickVsFrederickAgreementDifferences.pdf   Page switch fraud, unsigned 1-4 with notarized 5-6 from Plaintiff's Legal Separation version

ExhibitR3_AffidavitOfPost-NuptialPage1-4SwitchFraud_.pdf - Affidavit that "Post-Nuptial Agreement" is fraudulent

ExhibitP_LisPendensNotarized&Recorded.pdf - recorded Lis Pendens on DC Condo

ExhibitS_ShaddockSeasonalSeparationSchedule_.pdf - Legal Separation Agreement sharing both properties 50%