AMENDED COMPLAINT FOR SLANDER, DEFAMATION, HARASSMENT, COERCION (NRS 200.550), NEGLIGENT SUPERVISION, RETALIATION, AND HOSTILE WORK ENVIRONMENT
Plaintiff:
CHYVETTE A. VALENTINE
P.O. Box 93832
Las Vegas, NV 89199
Defendants:
Pleshette Roberts-Robinson
8057 Windmill Villa St.
Las Vegas, NV 89139
Hilton Grand Vacations (HGV)
5555 Badura Avenue
Las Vegas, NV 89118
I. JURISDICTION AND VENUE
1. This Court has jurisdiction under NRS Chapter 73 because Plaintiff seeks damages of $10,000 or less.
2. Venue is proper in Clark County, Nevada, under NRS 13.040, because all events giving rise to the claims occurred at Hilton Grand Vacations’ call center, located at 5555 Badura Avenue, Las Vegas, Nevada.
II. PARTIES
3. Plaintiff Chyvette A. Valentine is an adult resident of Las Vegas, Nevada.
4. Defendant Pleshette Roberts-Robinson is an individual residing in Clark County, Nevada, who engaged in harassment, intimidation, defamation, slander, coercion, and related misconduct toward Plaintiff.
5. Defendant Hilton Grand Vacations (“HGV”) is a Nevada employer and Plaintiff’s former employer, responsible for negligent supervision, retaliation, and maintaining a hostile work environment.
III. FACTUAL ALLEGATIONS
6. Plaintiff realleges and incorporates all preceding paragraphs as though fully set forth herein.
A. Employment at Hilton Grand Vacations
7. Plaintiff began employment with HGV at its call center located at 5555 Badura Avenue, Las Vegas, Nevada, on May 27, 2025, and remained employed until her wrongful termination on September 30, 2025, following her reports of threats and harassment by Defendant Roberts-Robinson.
8. Plaintiff was assigned to Defendant Roberts-Robinson as a “training buddy.”
9. Immediately after this assignment, Defendant Roberts-Robinson engaged in a pattern of harassment, intimidation, false statements, threats, and conduct that interfered with Plaintiff’s health, safety, and ability to perform her job.
10. Defendant’s conduct violated numerous Nevada statutes, including:
a. Defamation/Slander – NRS 200.510
- False statements alleging disease, crime, or immoral behavior constitute defamation per se.
- Penalties: Misdemeanor, fines, and civil liability.
- Case Law: Pope v. Motel 6, 121 Nev. 307 (2005); Chowdhry v. NLVH, 109 Nev. 478 (1993); Pegasus v. Reno Newspapers, 118 Nev. 706 (2002).
b. Harassment – NRS 200.571
- Knowingly subjecting another to harassment, threats, or intimidation.
- Penalties: Misdemeanor or gross misdemeanor depending on circumstances.
c. Stalking/Harassing Conduct – NRS 200.575
- Repeated unwanted contact causing fear or distress.
- Penalties: Misdemeanor for first offense; felony for aggravated forms.
d. Hostile Work Environment – NRS 613.330
- Unlawful to allow harassment or discrimination affecting terms or conditions of employment.
- Case Law: Sands Regent v. Valgardson, 105 Nev. 436 (1989); Apeceche v. White Pine County, 96 Nev. 723 (1980); Little v. Windermere, 301 F.3d 958 (9th Cir. 2002).
e. Coercion – NRS 200.550
- Prohibits threats, force, or intimidation used to compel or prevent action.
- Penalties: Misdemeanor or felony depending on the act.
IV. AUGUST 2025 INCIDENT TIMELINE (INCORPORATED IN FULL)
A. August 4, 2025 Medical Emergency and Harassment
11. Plaintiff emailed HR at 6:02 a.m. seeking emergency medical treatment after reporting blood in her mucus.
12. While in the emergency room, Plaintiff emailed Fatima Moncada reporting harassing and threatening text messages from Defendant Roberts-Robinson.
13. Plaintiff emailed Fatima, Chris, Paul, and Cassie regarding a high-profile domestic-violence/stalking matter (Cook County Case No. 2024L002166) due to escalating workplace safety concerns.
14. Plaintiff shared confidential filings solely because Defendant’s harassment raised safety concerns.
B. August 5, 2025 Supervisor-Change Request
15. Following increased harassment, Plaintiff requested a supervisor change, per Defendant’s own suggestion.
16. Plaintiff provided screenshots showing Supervisor Paul Marone threatening termination despite Plaintiff following instructions.
17. In an email titled “two-week notice #Paris,” Plaintiff wrote:
“I will not have sex with my supervisor to keep my job.”
18. This complaint constituted protected activity under Title VII and NRS 613.330, but HGV took no corrective action.
C. August 5–7, 2025 Safety Concerns and Medical Issues
19. Plaintiff reported her residential alarm system had been disabled, increasing fear and anxiety.
20. Plaintiff informed HGV on August 7 that she could not report to work due to severe medical symptoms experienced after using a vape shared by Defendant on July 20.
21. Plaintiff experienced difficulty speaking, swallowing, and breathing and required medical care.
D. August 13, 2025 Workplace Concerns
22. Plaintiff emailed HR detailing:
a. Improper time-off denials
b. Lost hours and income
c. Verbal abuse by Supervisor Paul (“What the F is your problem?”)
d. Termination threats (“I will take your ID; you are fired”)
e. Misleading suggestions by employees aligned with Defendant
f. Medical issues connected to the vape shared by Defendant
E. August 13–15, 2025 HR Responses
23. HR failed to protect Plaintiff, as demonstrated by:
a. No separation from Defendant
b. No discipline issued
c. Claims that Plaintiff’s concerns “mirrored other team members’ concerns” (without support)
d. Delays in the supervisor-change request
F. August 18, 2025 Formal HR Complaint
24. Plaintiff submitted a formal HR complaint.
25. HR representative Denise Edgehill stated she would conduct an investigation.
26. Plaintiff cooperated fully and provided documentation of harassment.
27. Defendant Roberts-Robinson sent over 30 hostile messages during Plaintiff’s August 4 ER visit.
28. Plaintiff also provided evidence that Defendant improperly shared customer-information screenshots, violating HGV privacy policies.
29. HR defended Defendant and refused corrective action.
G. August 18–September 30, 2025 Retaliation
30. Following Plaintiff’s complaint, HGV:
a. Delayed the investigation
b. Acted with bias
c. Accepted Defendant’s false statements
d. Failed to separate Plaintiff from her harasser
e. Terminated Plaintiff on September 30, 2025, 43 days later
V. CAUSES OF ACTION
1. Defamation and Slander (Against Roberts-Robinson)
31. Defendant made false statements including:
a. Alleging Plaintiff was “HIV-positive”;
b. Claiming Plaintiff stalked or harassed her;
c. Claiming Plaintiff drove near her home;
d. Claiming Plaintiff was mentally unstable or dangerous.
32. These statements were published to coworkers, supervisors, HR, and Congressman Danny Davis.
33. Plaintiff suffered reputational damage, humiliation, and loss of employment.
34. NRS 200.510 identifies slander as a punishable offense.
Defamation per se applies to statements alleging disease, crime, or immoral conduct.
Case Law:
-
Pope v. Motel 6, 121 Nev. 307 (2005)
-
Bull v. McCuskey, 96 Nev. 706 (1980)
-
Pegasus v. Reno Newspapers, 118 Nev. 706 (2002)
2. Harassment & Hostile Work Environment (Against All Defendants)
35. NRS 613.330 prohibits workplace harassment and discrimination.
36. NRS 613.340 prohibits retaliation for reporting harassment.
37. NRS 200.571 prohibits harassment causing fear or intimidation.
38. NRS 200.575 prohibits stalking.
39. Defendants’ conduct was severe, pervasive, unwelcome, and interfered with Plaintiff’s employment.
Case Law:
-
Dillard v. Beckwith, 115 Nev. 372 (1999)
-
Sands Regent v. Valgardson, 105 Nev. 436 (1989)
-
Little v. Windermere, 301 F.3d 958 (9th Cir. 2002)
3. Retaliation NRS 613.340 (Against HGV)
40. Plaintiff’s formal HR complaint on August 18 was protected activity.
41. Plaintiff’s termination on September 30 was an adverse employment action.
42. The 43-day proximity and biased investigation establish retaliation.
4. Coercion NRS 200.550 (Against Roberts-Robinson)
43. Defendant used threats, intimidation, and coercion to silence Plaintiff, interfere with medical care, and influence employment decisions.
44. NRS 200.550 prohibits using threats or force to compel or prevent conduct.
Penalties: May constitute a misdemeanor or felony depending on circumstances.
5. Negligent Supervision (Against HGV)
45. Under Barmettler v. Reno Air, 114 Nev. 441 (1998), employers owe a duty to supervise employees.
46. Plaintiff repeatedly notified HGV of misconduct, placing HGV on clear notice.
47. HGV failed to discipline, separate, or protect Plaintiff from foreseeable harm.
6. Intentional Infliction of Emotional Distress (Against Roberts-Robinson)
48. Defendant’s conduct was extreme and outrageous, including:
a. Harassment during Plaintiff’s medical emergency
b. Repeated false accusations
c. Sexual insinuations
d. Threats of reporting Plaintiff
49. Plaintiff suffered severe emotional distress as a result.
VI. DAMAGES
50. Plaintiff seeks $10,000 in damages, including:
a. Emotional distress
b. Reputational harm
c. Lost wages
d. Medical expenses
e. Safety-related costs
f. Filing and documentation expenses
VII. REQUEST FOR RELIEF
Plaintiff respectfully requests:
51. Judgment against Defendant Roberts-Robinson for:
52. Judgment against Defendant HGV for:
-
Hostile work environment
-
Negligent supervision
-
Retaliation
53. Award of $10,000 in compensatory damages.
54. Award of court costs and any other relief deemed just and proper.
Disclaimer to Readers
This blog reflects my personal experiences and perspectives, particularly regarding issues of domestic violence, stalking, and harassment. My goal is to speak truthfully while maintaining my safety, peace of mind, and healing process.
I have learned to see through drama, manipulation, and distraction skills developed from years of surviving abuse and unwanted attention. If you see me walking alone, understand that solitude is my choice, not a sign of isolation. I walk alone to protect my peace.
Some events or people referenced in my writing are part of an ongoing legal matter, including actions connected to Scottie Pippen and incidents I’ve reported in Clark County, Nevada. Any individuals mentioned are included only for the purpose of documenting factual experiences and evidence related to my claims.
This space is not intended for gossip, solicitation, or personal attacks. It is a record of survival, truth, and resilience and a safe space for others who may relate to the complex realities of abuse and recovery.
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