COMES NOW, Plaintiff Frederick J. Shaddock, pro se, pursuant to D.C. Code § 16-1005, § 16-910, Super. Ct. Dom. Rel. R. 65, and the Court's equitable authority, and moves for an emergency temporary restraining order (TRO) and/or preliminary injunction requiring immediate restoration of Plaintiff's key fob access to Harbour Square Condominium Unit S-316 pending the March 6, 2026 hearing or further order. Plaintiff requests an expedited or ex parte hearing due to ongoing irreparable harm.

 

I. Introduction & Irreparable Harm

 

Defendant has deactivated Plaintiff's key fob since September 10, 2025 (with brief restoration October 2025), denying independent access to the marital condominium (Unit S-316). This confinement prevents Plaintiff from:

• Leaving and re-entering the unit independently.

• Accessing the building gym/pool as ordered by his doctor for health maintenance
  (high blood pressure, sun light, fresh air, daily exercise requirement).

• This constitutes physical/mental harm and interference with marital property use.

Plaintiff satisfies the four-factor test for injunctive relief:
(likelihood of success, irreparable injury, balance of harms, public interest).

 

II. Factual Background

1. Parties married January 17, 2001; condo purchased October 10, 2012 (marital property).

2. Fob deactivated September 10, 2025; brief restoration October 24, 2025; reactivated post-airport drop-off November 29, 2025; deactivated again December 6, 2025 via remote portal.

3. Plaintiff resides in the unit; doctor's order requires gym/exercise access (Exhibit A).

4. Confinement causes physical harm (no independent exit & re-entry, denied exercise).

5. Ongoing mail obstruction to S-316 box exacerbates harm.
    

III. Legal Argument

• Likelihood of success: Condo is marital (§ 16-910); prior TRO shows interference.

• Irreparable injury: Health harm from denied gym access; confinement is abusive.

• Balance of harms: Defendant suffers none from reactivation; Plaintiff suffers daily.

• Inability to open condo garage door with fob to paid-for $155/month spot also deteriorates marital Mercedes Benz which Plaintiff has to park on the street in rain

• Public interest: Preserving access to marital residence pending distribution.

No bond requested (pro se, good faith).

 

IV. Prayer for Relief

1. Immediate TRO restoring key fob access (exterior doors, elevators, gym/pool).

2. Preliminary injunction enjoining further deactivation/interference.

3. Expedited/ex parte hearing (WebEx).

4. Other relief as just.