Praecipe Cover Letter

Frederick J. Shaddock
1000 University Manor Drive, Suite A28
Fairfield, Iowa  52556

November 16, 2007

Attn: Deputy, Central Intake Center
DC Superior Court
500 Indiana Avenue, NW
JM 540
Washington, DC  20001

Re: 07 DRB 2108

Dear Ms. Carter:

Thank you for your time on the phone for me to clarify that my address is in Iowa, not DC.  I would also like to inform the Court that my wife's attorney has been deliberately sending notices to an old address, in an unscrupulous attempt to win judgments by default.

Please note that my address above has been my most frequent domicile since January 2005, about 2 and 5/6  years ago.  This is the address on my Iowa driver's license, a photo of which is enclosed.  I have owned the 1000 University Manor condo since 1997.

Please note that my home address has not been 510 N Street, SW in Washington DC for years.  It is a rental property with a lease until August 2008 with the tenant.  My tenant has a PO Box, so no mail gets delivered to that address.  Therefore any legal documents sent to 510 N Street have not been delivered to me, and are void. 

My wife Oksana Shemet Shaddock and her attorney Robert Liotta are fully aware of my living in Iowa.  My wife has visited me several times at my Iowa address.  Mr. Liotta even recommended an Iowa attorney to assist in the divorce case as far back as July 2007.

Nevertheless, according to the DC clerk's office, he sent documents in late September to the old DC address, apparently to prevent my seeing them, and raising any objections in time for hearing dates.  Mr. Liotta has lied to the Court by pretending to think I am in DC.  He knows of, and has met my attorney Robert Stone, yet he sent papers to me "pro se" bypassing the proper procedure of notifying Mr. Stone.  This is irregular behavior on the part of an attorney, who knows the purpose of the Certificate of Service, and should not be condoned by the Court.

Please enter this letter as part of the docket for case 07 DRB 2108 being handled by the Honorable Judge Fern Flanagan Saddler.

Thank you.

 

Frederick Shaddock