Dear Mr. Liotta and Oksana:

1. A document purporting to be a Quit Claim Deed dated December 7, 2013, has been referenced in recent legal discussions and filings between the parties.
2. Upon review, we acknowledge that there is no valid, properly executed, and recorded Quit Claim Deed from Frederick Shaddock to Oksana Shemet Shaddock regarding the above-referenced Property.
3. Specifically:
   • There is no evidence that the alleged deed was signed by Frederick Shaddock in person, willingly, and before a live notary witness;
   • The purported deed was not recorded with the District of Columbia Recorder of Deeds, as would be required for legal validity;
   • There is no credible documentation or financial consideration confirming the alleged transaction (e.g., a receipt, check, bank transfer, or confirmation of $1 exchange);
   • The notary referenced in the document is now deceased and cannot verify the authenticity of the signature.
4. Accordingly, we agree that the alleged Quit Claim Deed shall not be presented, used, or relied upon in any legal proceeding as evidence of a valid transfer of title or waiver of marital interest.
5. We further acknowledge that, in the absence of a valid and recorded deed, the Property remains subject to the presumptions and protections afforded by District of Columbia marital property laws, including D.C. Code § 16–910.

Summary

1. Lack of Voluntary and Knowing Consent

• A valid deed must be signed voluntarily and with full understanding of its legal consequences. If the signer did not understand they were relinquishing ownership, or was misled or coerced, it may be voidable due to fraud, duress, or undue influence.

2. Absence of Independent Legal Counsel

• If no attorney advised Frederick Shaddock at the time of signing a deed that would waive his marital property rights, that can suggest an unconscionable agreement, especially given the $200,000+ value involved and the alleged exchange of only $1.

3. Missing or Faulty Notarization

• For real estate transfers, notarization is critical. If:

  • The notary was not physically present,

  • The notary did not verify identity, or

  • The notary stamp is missing or upside down,
    the notarization may be deemed defective, and the deed invalid.

4. No Legal Description of the Property

• A valid deed must include the full legal description (not just the street address). If the purported deed lacks a metes and bounds description or lot number as defined in the DC land records, it may be legally insufficient.

5. Lack of Recordation

• DC law (and all U.S. jurisdictions) requires a deed to be recorded with the appropriate government agency to provide constructive notice to third parties. An unrecorded deed can be challenged or ignored in disputes over ownership.

6. Inadequate Consideration

• The deed allegedly conveys an interest in high-value property for only $1. While "love and affection" or nominal consideration can be legally sufficient in some contexts, courts may scrutinize this for lack of fairness, especially in a marital context without reciprocal consideration.

7. Contradiction with Tax Filings and Behavior

• Joint tax returns, shared residence, co-management of the condo, and public behavior inconsistent with a property transfer all undermine the idea of a true transfer of ownership in 2013.

8. Forgery Indicators

• If the signature:

  • Differs from known samples,

  • Is in a different ink color,

  • Lacks distinctive handwriting features,
    this raises serious questions of forgery, which alone invalidates the deed.

9. Presumption of Marital Property

• Under DC law, property acquired during marriage is presumed to be marital property unless proven otherwise. A unilateral document not clearly and knowingly executed by both parties is insufficient to rebut this presumption.