IN THE DISTRICT COURT OF
IOWA
IN AND FOR JEFFERSON COUNTY
|
Frederick Shaddock, |
Case No. CDCV402015 MUTUAL MOTION FOR
|
COMES NOW the Petitioner, Frederick Shaddock, and respectfully joins in the
Respondent’s request for an extension of time regarding the hearing currently
scheduled for March 3, 2025. In support of this motion, Petitioner states the
following:
Respondent and Petitioner mutually agree to request additional time; however, the ultimate trial date will be determined by the Court. Both parties recognize that this is an emotionally challenging time to proceed with a divorce trial. An extension would allow for Respondent's emotional, financial, and logistical preparation.
The main Irreconcilable Disagreement remains: Respondent refuses to give Petitioner equal, reciprocal access to their marital DC condo that Petitioner gives her at the marital Fairfield house including keys and registration.
Respondent’s Circumstances:
* Respondent is currently interviewing to secure employment amidst
Government layoffs in Washington, D.C.
* Respondent worries about her elderly parents from Russia and Ukraine, and
wishes to visit them soon.
* Additional time would allow Respondent to earn funds for her legal
representation.
Petitioner’s Circumstances:
* Petitioner requires additional time to secure funds for his prospective
attorney’s $2,500 retainer.
* Petitioner’s prospective attorney (Heather Simplot) has a full court schedule
until June 2025.
* Petitioner’s rental income from the Iowa property has been slow since October 2024.
Proposed Timeline: Both parties respectfully suggest a 90-day extension, subject to the Court’s availability.
To minimize travel expenses, Respondent and Petitioner request that the next status hearing be via Zoom.
WHEREFORE, Petitioner respectfully requests that the Court grant an extension of time for the hearing, continuing it for approximately 90 days or to a date convenient for the Court and Respondent.
RESPECTFULLY SUBMITTED,
/s/
Frederick Shaddock, Petitioner, pro se February
24, 2025
cc: Joseph Pavelich, Esq., Attorney for Respondent (via electronic filing)
Oksana Shemet Shaddock, Respondent (via electronic filing)