SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION
Frederick J. Shaddock
Plaintiff
v. Case No. 2025 CAB 004804
Oksana S. Shaddock
Defendant
CORRECTED
REPLY TO OPPOSITION TO MOTION TO DISMISS COMPLAINT
Defendant, Oksana Shaddock, by her attomey, Robert Case Liotta, Replies to
Plaintiff” s Opposition to the Motion to Dismiss the Complaint as follows:
l.Defendant submits this Reply even though it is unclear whether or not
Plaintiff has actually re-filed his Opposition after it was rejected by efile. Plaintiff
has emailed Counsel and telephoned him to the effect that he has corrected the
filing errors and re-filed. As of this writing Counsel has not received notice from
efile.
2. Plaintiff filed a Complaint which, despite the title which states that it is a
Complaint for Declaratory Judgment and to void quitclaim deed, seeks in the
request for relief only two things; (l) A declaration that the Quitclaim Deed is void
and (2) a confirmation that the property is marital. Defendant in her motion to
Dismiss addressed only these matters raised in the Complaint.
3. Defendant filed a Motion to Dismiss pursuant to SCR-Civil Procedure ,
l2(b) which raises all of the l2(b) defenses and argues especially that there has
been a failure to state a claim upon which relief can be granted.
4. Plaintiff claims in his Opposition that (l) this Court has subject matter
jurisdiction because his Complaint is actually one to "Quiet title" under DC Code
ll-92l(a)(6),(7) and that a claim for Lis Pendens is a tool available in the Civil
Division under DC Code 42-1207. Nowhere in the Complaint is there any mention
of quieting title nor should there be. If Plaintiff had actually looked at the Code
Section he is relying upon he would have seen that the Title of the Section is
actually "Quieting Title Obtained by Adverse Possession" and that adverse
possession has been by the District of Columbia. His claim that this is a Complaint

for a Lis Pendens Notice is equally misplaced as his Complaint does not in any
way request some notice of Lis Pendens. Plaintiff did make such a request at a later
date in one of the four motions he submitted but Defendant’s Motion to Dismiss is
to dismiss the Complaint and did not address the subsequent motions.
5. Although the request for this Court to issue some unspecified Notice of Lis
Pendens is not before the Court with regard to the Motion to Dismiss, it should be
noted that there is no provision in the DC Code for this Court to issue a Notice Lis
Pendens. Notification is accomplished by a party who has a pending case in this
court regarding property in the District of Columbia simply filing a notice of the
pending litigation with the Recorder of Deeds. Again, if Plaintiff had actually
reviewed DC Code Section 42-l207 he would have been aware of this. To date he
has not filed such notice. Indeed he should be cautious in actually doing so as he
will then be responsible for the costs of releasing the Lis Pendens under Subsection
(d)(1)-
6. The remainder of the Opposition set forth in paragraphs numbered l—4 seem
to address Plaintiffs claims for voiding the Quitclaim Deed and proof that he
wishes to present to show that it is void. The recitation of such possible evidence in
no way rebuts the fact that the validity of the Quitclaim deed is not before this
Court in any action that would justify some type of advance evidentiary ruling. As
noted in the Motion to Dismiss, if there was a divorce action pending in the
District of Columbia and if the Quitclaim Deed were to be offered as evidence and
if Plaintiff objected to its’ admission there might be grounds to address the issue of
its’ validity. At this juncture none of those actions are before this or any other
Court and may never be. This fact is at the heart of the Motion to Dismiss.
7. The other request for relief set forth in the Complaint is for this Court "to
confinn" that the Property "remains marital". Defendant addressed that issue
thoroughly in the Motion to Dismiss. Plaintiff in his Opposition does not rebut
Defendant’s grounds for dismissal and presumably has no viable rebuttal.
8. Although not before this Court at this time, it should be noted that there is no
dispute and there never has been regarding recordation of the Quitclaim Deed. lt
has never been recorded. lts’ relevance, if any, would derive from Plaintiff s
waivers of any interest in the property in question contained in the document.

WHEREEORE, Defendant restates her request that this Honorable Court dismiss
the case or treat this Motion as one for summary judgment under SCR 56 and enter
summary judgment in favor of Defendant.
Respectfully Submitted,
Robert Case Liotta
3726 Harrison Street, NW
Washington, DC 20015
202 53l 8088
Email: rcl@ldelaw.com
CERTIFICATE OF SERVICE
I HEREBY CERT IE Y, that on this 8 day of October 2025 a copy of the foregoing Reply
to Opposition to Motion to Dismiss Was S€1’1l via email arid eFile to Frederick J.
Shaddock, 806 North 4th Street, Fairfield, Iowa 52556.
Robert Case Liotta