IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION
| FREDERICK SHADDOCK, 520 N Street SW, S-316, Washington, DC 20024 (Square 0503, Lot 0116). Plaintiff, v. OKSANA SHEMET SHADDOCK, 520 N Street SW, S-316, Washington, DC 20024 Defendant |
CASE NO. 2026-CAB-001539
EMERGENCY MOTION FOR
|
I. Introduction & Irreparable Harm
Defendant has deactivated Plaintiff's key fob since September 10, 2025 (now over 6 months), denying independent access to the marital condominium and common areas. This constitutes an extra-judicial self-help lockout of marital property without any court order authorizing exclusive possession or denial of access. No final divorce decree or pendente lite order exists in any jurisdiction granting her such authority.
The lockout prevents Plaintiff from following a doctor's order for regular exercise (gym/pool access) to manage high blood pressure, resulting in documented physical deterioration: shaking hands, limping, and frequent headaches. Confinement to the unit without independent entry/exit constitutes ongoing physical and mental harm. Defendant has also interfered with Plaintiff's U.S. mail delivery to the unit (e.g., instructing the guard to return a Walmart package).
Plaintiff is a legal resident of the District of Columbia (DC driver's license, voter registration, bank checks with this address, physical possession since September 2025). Five D.C. police officers have confirmed Plaintiff's right to stay in the unit since September 11, 2025.Plaintiff satisfies the four-factor test for injunctive relief: likelihood of success, irreparable injury, balance of harms, public interest.
II. Factual Background
III. Legal Argument
Defendant's deactivation of the key fob is an impermissible self-help lockout of marital property. In D.C., unilateral denial of access (e.g., changing locks, disabling key fobs) is prohibited even against a tenant without judicial process (D.C. Code § 42-3505.01; Mullin v. 8921 Georgia Ave. Corp., 199 A.2d 760 (D.C. 1964)). A fortiori, one spouse may not exclude the other from marital property absent a court order awarding exclusive possession (§ 16-910; Turcotte v. Ford, 494 A.2d 119 (D.C. 1985)).
Mail interference violates federal law (18 U.S.C.§ 1702) and Plaintiff's property rights. The room division arrangement maintains peace and should be authorized to preserve the status quo pending final equitable distribution. No bond is requested (pro se, good faith).
IV. Prayer for Relief
WHEREFORE, Plaintiff requests:
Respectfully submitted,
/s/ Frederick J. Shaddock
Frederick J. Shaddock, Pro Se
520 N St SW, Unit S-316
Washington, DC 20024
(202) 365-6100
fred@shaddock.net
Certificate of Service
I certify that on March 28, 2026, a true copy was served by email to:
Robert C. Liotta (rcl@ldelaw.com )
Oksana Shaddock
(oksanashaddock@gmail.com )
Joe Pavelich
(pavelich@spiespavelich.com)
/s/ Frederick J. Shaddock
Attachments/Exhibits (attach as PDFs):
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