IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION

FREDERICK SHADDOCK,
520 N Street SW, S-316, Washington, DC  20024
Plaintiff,
v.
OKSANA SHEMET SHADDOCK,
520 N Street SW, S-316, Washington, DC  20024
Respondent.

CASE NO. 2025-CAB-004804

COMPLAINT FOR DECLARATORY
JUDGMENT TO VOID QUIT CLAIM
DEED FOR DEFECTS

COMES NOW the Plaintiff, Frederick Shaddock, appearing pro se, respectfully moving this Honorable Court for a Declaratory Judgment to void the alleged "Quit Claim Deed" dated December 7, 2013, concerning the property at 520 N Street SW, Suite S-316, Washington, DC 20024, void, null, and of no legal effect, for defects in execution, coercion, and non-registration:

  1. Background:
    Plaintiff and Respondent were lawfully married on January 17, 2001, and during the marriage, acquired real property presumed to be marital property under D.C. Code § 16–910(2).

  2. Alleged "Quit Claim Deed":
    Respondent has produced a purported "Quit Claim Deed" allegedly executed by Plaintiff in December 2013, purporting to transfer Plaintiff’s marital interest in the Harbour Square condominium for a nominal consideration of one dollar ($1).

  3. Irregularities and Defects: the alleged document is flawed for multiple independent reasons, including:

  1. Pattern of Conduct:
    Respondent has previously submitted unilateral, non-consensual documents to courts, such as a purported mutual divorce dismissal in Iowa (Case CDCV402015), without Plaintiff’s agreement or verified signature, evidencing a pattern of document fabrication or misrepresentation.


     

  2. Photos and Conduct History:
    Plaintiff has photographic records of major real estate transactions, including the purchase of the Harbour Square N32 unit and an Iowa home, but no photos exist of the purported execution of this Quit Claim Deed—highly inconsistent with Plaintiff’s longstanding documented practice.

  3. Emergent Issue:
    This matter was not adjudicated in prior case 2025-CAB-000953 but emerged from Respondent’s subsequent claims and must be resolved to clarify the marital property status of the Harbour Square condominium.

  4. Legal Standard:
    Under DC law and general contract principles, a deed executed under duress, without proper notarization, without registration, or without valid consideration is void and of no legal effect.

  5. Jurisdiction:
    Under DC Code § 16-910 this Court has jurisdiction over matters regarding this property and residents of Washington, DC.

WHEREFORE, Plaintiff respectfully requests this Honorable Court:

Respectfully submitted,
June 6, 2025

Frederick Shaddock, pro se
Email: fred@shaddock.net
Phone: 202-365-6100

cc:
Oksana Shemet Shaddock, Respondent (via electronic filing)
Robert Case Liotta, Esq. (Counsel for Respondent)