COOK COUNTY CASE # 21-L1-11793
County Department, Law Division
Cook County
Chyvette A Valentine; Plaintiff
Vs. Case # 2021-L1-11793
Claimed Damages: $30 million
Curtis “50 cents” Jackson.
Anthony Wilson.
G-Unit Movies and Film Productions LLC.
G-Unit Records LLC.; et.al., Defendants
Jury Demanded
Complaint
Chyvette A Valentine, 6700 S Oglesby, Chicago, Illinois 60649, (773) 633-5567, Pro Se; (known as the “Plaintiff”), hereby file her Complaint against Defendant Curtis “50 cents” Jackson, dba G-Unit Films and Television LLC., G-Unit Records LLC, and Anthony Wilson, manager, who conducts business and is registered at 21731 Ventura Blvd, #300, Woodlawn Hills, CA 91354 (the “Defendants”) and allege as follows:
NATURE OF THE ACTION
Plaintiff brings this action under the Illinois Hate Crime Act, 720 ILCS 5/12-7.1; the Illinois Human Rights Act, 775 ILCS 5/3-105.1; and bring Illinois claims for assault and intentional infliction of emotional distress, seeking actual and punitive damages and injunctive relief caused by Defendant’s unprovoked, willful, and ethnically motivated actions against her.
Plaintiff lives at 6900 South Oglesby, Chicago, Illinois 60649 in Chicago’s historic Southshore Community.
Defendant Curtis “50 cents” Jackson, dba G-Unit Films and Television LLC., G-Unit Records LLC. Anthony Wilson manager for artist Curtis Jackson conducts business and is registered at 21731 Ventura Blvd, #300, Woodlawn Hills, CA 91354. Defendant(s) conducts business and films in Cook County, in addition to multiple states and countries, he has international access and following(s).
Defendant(s) has persistently engaged in intimidating, threatening, coercive, harassing, and interfering conduct that has continued up to the time of the filing of this Complaint, with the intent to force Plaintiff, into silence about “incidents” leading to and relating to, or involvement with Scottie Pippen.
The defendant is a known “gay lover” of NBA player Scottie Pippen, he has also expressed interest and has pursued Plaintiff for his own personal reason(s). Defendant has pursued, inquired, or asked about Plaintiff since the “Scream” Concert in Memphis, TN in 2002.
It is “rumored” that Defendant Curtis “50 cents” Jackson allegedly bought the Manson of retired boxer Mike Tyson’s home, to impress Plaintiff in 2003 in Farmington, CT.
Plaintiff contends that the defendant is merely a “fan” there is no connection other than professional affiliation(s), and that any/all contact is “unwanted” and demanded to “cease and desist” all communications with all parties named and unnamed.
Defendant’s conduct, actions, and behavior have caused Plaintiff her family, and immediate friends immense mental, emotional, and physical distress.
Defendant’s actions have included recruitment or “conspiring” of people to “stalk”, “harass”, “intimidate” the “name” and “reputation” of Plaintiff using: (a) persistent harassing, threatening, and degrading abuse against the Plaintiff with sexist slurs, epithets, and profanity, physical assaults, and battery, and repeatedly referring to the Plaintiff as a “homeless prostitute” seeking fame. Plaintiff has been subject of; (b) threatening attack(s) by fans, friends, and/or associates of Defendant (c) targeting chasing, chasing, and pursuing Plaintiff throughout the Los Angeles communities while working (2018-2020); (d) targeting Plaintiff son Diandre Valentine for drug and gun trafficking, he is currently incarcerated at Greene County Jail in St. Louis Missouri (461840), (g) illegally entering Plaintiff home to ejaculate on the toilet in Clark County, Nevada (October 2017), (h) acting on behalf of or in concert with his “gay lover(s)”.Case(s) on record and/or pending are as follows:
· Scottie Pippen (21-L-005963); Santa Monica (19SMSC02104)
· Ervin “Magic” Johnson (21-L-11782)
· Lisa R McCoy(21-L-06280); Santa Monica (19SMSC02103)
· Dr. Theressia L. Washington w/ Monique Boyd (21-L-005278); Santa Monica (19SMSC2102)
As a result of Defendant’s persistent and abusive conduct, Plaintiff have been denied basic civil rights, to live peaceably without the threat(s) intimidation, threats, coercion, harassment, and interference.
As a direct and proximate result of Defendant’s acts, Plaintiff has suffered severe emotional distress, anguish, and humiliation, and continues to suffer to the present day until and after filing, fearing for her safety and well-being.
Plaintiff feared for her safety and her life while being forced to live in a car, for 21 months from June 2018 until August 2020, while seeking safe refuge from “abuse” of Defendant and “co-conspirers”.
Plaintiff Chyvette A. Valentine feared for the safety of her children who were targeted because of activities.
Plaintiff has been so diminished by Defendant’s acts that she relocated back to Cook County, IL where the threat(s) intimidation, threats, coercion, harassment, and interference continue until the time of filing, thereafter. Where the intimidating behavior, threats, and coercion continues with locals who are affiliated and/or associated with Scottie Pippen*, Ervin “Magic” Johnson*, Lisa R McCoy*, Dr. Theressia L. Washington*, and Monique Boyd. *Named Defendants in a separate non-associated claim(s).
Plaintiff asks for compensatory damages for her financial loss and for the pain, suffering, and emotional distress that Defendant has inflicted and continues to inflict.
Because of the willful, wanton, and malicious nature of Defendant’s actions, Plaintiff also seeks punitive damages to punish Defendant and to deter others from participating in such hateful, demeaning, and threatening acts.
PARTIES
1. Plaintiff Chyvette A. Valentine is a 53-year-old woman of multiple backgrounds. Plaintiff currently resides at 6700 S Oglesby, Chicago, IL 60649; and is also the former girlfriend, lover, and mother of the child (Devonte Pippen) son of NBA Chicago Bull Scottie Pippen. Plaintiff is the mother of (4) children (one son deceased Devonte Pippen), and the grandmother of (24) grandchildren.
Plaintiff is an “entrepreneur”, “self-employed chef”, “civil rights advocate”, “community activist”. In 2015 Plaintiff unsuccessfully run for Alderman of Chicago’s 7th Ward.
Plaintiff works as an Independent Contractor for security; or corporately as a Career/Credit/Financial Advisor, in addition to running several of her own businesses.
Plaintiff has worked as a “Private hire bodyguard/security from 1985 to present. Most notably plaintiff began her career in Chicago with Andy Frain Security Services and in 1985 she worked on contract with Unique Protection Services for the American Music Awards, Grammys, and most famously, the historical recording session “We Are The World”, with Michael Jackson in 1985.
Plaintiff worked private hire security for various nightclubs, concerts, and events from 1986-2000, including and not limited to employer Calvin Hollins, former owner/operator of Chicago Night Spot “Hero’s” aka The Clique aka Em2, located at 2347 S Michigan in Chicago. Ems caught fire in (around 2005, very much associated with this matter).
The club caught fire when Plaintiff returned to Chicago with Devonte Pippen.
2. Plaintiff Diandre Valentine is a 34-year-old male, a father of (19 or so) who is currently serving time for drug trafficking, influenced by Lisa R McCoy and Curtis “50 cents” Jackson. Currently incarcerated at Green County Jail in St. Louis Missouri. He is inmate #461840 to which Defendant bases his TV show “For Life”, a show loosely based on the current “incarceration of said Plaintiff.
Plaintiff assumed he was “hired” for a “movie scene” in the role of a “looter”, “robber”, “thug” or some sort of criminal committing a crime. These were “not” acting role(s), but real crimes being committed, using the platform of filming a movie.
Plaintiff was involved in “real crimes”, with “real prison sentencing”.
In one instance Plaintiff was given a “Police Uniform” and told to act like an “LAPD Officer” while robbing a home. In another instance Plaintiff was held with a gun to his head and instructed to “act like a hostage”. When in fact the firearm was real, and my son was an actual dancer. All roles are hired under contract with or filmed by and produced under G-Unit Films and Movies, and are marketed under Starz, and/or Lionsgate Films.
3. Plaintiff Dejanara Valentine is a 26-year-old single mother of (3), who has been a repeat target of “human trafficking”, “physical”, “mental” and “emotional” abuse, “physical battery”, and “assault(s)” directed by Curtis “50 cents” Jackson, who “misguided”, “mislead”, “coerced” and “manipulated” Plaintiff into thinking she was “filming a movie”. Plaintiff was held captive and/or “hostage” in various locations/cities, under the brand of G-Unit Films, while sexually exploiting her for and on behalf of Scottie Pippen, Ervin Johnson, Lisa R McCoy, Dr. Theressia Washington, and/or Monique Boyd.
Plaintiff “reserves the right”, to question the paternity of Dejanara Valentine’s children.
Plaintiff assumed she was “hired” for a “movie scene” in the role of a “vixen”, “sex slave”, “hostage” or some sort of “human trafficking victim”. These were “not” acting role(s), using the platform of filming a movie, to cover up and or disguise said crime(s). All roles are hired under contract with or filmed by and produced under G-Unit Films and Movies, and are marketed under Starz, and/or Lionsgate Films.
In one instance Plaintiff was told she was attending an Award show and that she was the “bride” of Defendant, she was later sexually assaulted and threatened with silence, or threats of death to self, her children, or other family members (s).
4. Defendant Curtis “50 cents Jackson” is a 46-year-old rapper, movie and tv director, producer and promoter, whose business is located at 21731 Ventura Blvd, #300, Woodlawn Hills, CA 91364. This is the primary address for business listed for G-Unit Films & Movies LLC, to which the defendant is the sole owner of all entities G Unit Movies and Film Productions, G Unit Records LLC. G-Unit Foundation LLC.
5. Anthony Wilson (Co-Defendant) works as the manager for Defendant Curtis “50 cents” Jackson. Anthony Wilson has no listed address and/or phone.
JURISDICTION AND VENUE
6. This Court has jurisdiction over this action pursuant to 735 ILCS 5/2-209(a)(2) because it arises from tortious acts committed in this State. This Court also has jurisdiction over this action pursuant to 735 ILCS 5/2-209(b)(2) because Defendant resided in this State when this cause of action arose and when this cause of action was commenced.
7. Venue is proper in this judicial district pursuant to 735 ILCS 5/2-101 because the incidents that gave rise to this action took place in Cook County, Illinois.
FACTUAL ALLEGATIONS COMMON TO ALL COUNTS OF THE COMPLAINT
8. Plaintiff made contact or met Defendant in Memphis, at the FedEx Forum Arena 2003 for the Scream Concert. Through multiple third-party affiliates(s) and/or associates, who mutually know both parties. Defendant made “inquiries” to Lisa R McCoy who identified Plaintiff and disclosed her identity. Defendant has maintained third-party contact since August 2003.
9. Plaintiff son Devonte Pippen was “murdered” on January 19, 2012.
10. Defendant made direct contact, to invite Plaintiff to his birthday party, held in Chicago at the Shrine on July 30, 2015. Where after said event, the next episode of “Power” highlighted the FBI agent leaving her shoe in the car, the same events that transpired at Birthday Party, where Plaintiff left her shoes in the drivers’ vehicle after the event.
Subsequently, various characters are loosely based on the identity of Plaintiff in her real-life role(s) and/or characters. His admiralty obsession is noted, yet unwanted. Power is a show filmed by and produced under G-Unit Films and Movies.
All roles are hired under contract with or filmed by and produced under G-Unit Films and Movies, and are marketed under Starz, and/or Lionsgate Films.
11. Plaintiff who operates/operated a Bed & Breakfast from home using the Gig-App Airbnb, started receiving “bookings” from June to October 2015 from the various cast from the show “Empire” and “Power”.
12. Plaintiff relocated from Illinois to Tucson, Arizona after her home located at 8005 S Marquette Ave, Chicago, IL 60649, was “shot up” on September 27, 2015.
13. Plaintiff resided at 7700 E Speedway, #710 Tucson, AZ 85710 and was gainfully employed at Dun & Bradstreet from May 2016 to May 2017. She also inquired and/or applied for Tucson Police Department in the Records Division.
14. After “making contact” via email relating to and/or regarding opening, and resume status, the Mayor of Tucson “Jonathan Rothschild” was “carjacked at gunpoint”. Similar or same activity as in Chicago. Mayor Rahm Emmanuel’s son was beaten after Plaintiff’s son’s murder (alleged to be affiliated with Pippen).
15. In January of 2017 Plaintiff was oddly diagnosed with “fibroids” and was advised to a full hysterectomy, requiring a full removal of her uterus and womb (so alleged).
In March of 2017 Plaintiff made plans to relocate from Pima County to Clark County Nevada, to be closer to family and friends. She traveled to place personal belongings in storage until after the said procedure.
16. From May 2016 to the Present in “various” situations, circumstances, and/or occasions (too many to list); the defendant has “worked”, “acted”, or “performed” as the “muscle” or “intimidator” for Scottie Pippen*, Ervin “Magic” Johnson*, Lisa R McCoy*, Dr. Theressia L. Washington*, and Monique Boyd. *Named Defendants in a separate non-associated claim(s).
After learning of their “gay relationship” in 2017, it was “clearly established” that the defendant was working mainly in part of or for Pippen.
17. The week of July 6-15, Plaintiff attended several events and private parties, to which she paid $100-$150 per admission.
· July 7, 2017, Drai’s with Chris Brown
· July 8, 2017, Hard Rock Café w Kevin Hart (Plaintiff was targeted & harassed by security).
· July 12, 2017, Drai’s with Snoop Dogg
18. On or about the week of September 15, 2017, Plaintiff was contacted by singer Chris Brown, who requested I set up an after-show “meet and greet”. He gave Plaintiff the direct private number to Anthony Wilson, the mutual manager of both Curtis “50 cents” Jackson and Chris Brown, with intention of a “private meeting”.
Upon making contact Anthony Wilson began making threats, requesting money, and being verbally abusive sending links, videos, and photos privately sent to Chris Brown.
Plaintiff rejected the request and maintained communications but refused to pay to meet anyone. Chris Brown requested that Plaintiff teach him about marketing and proper artist management and requested I attend the New Years’ Eve Show at Drai’s.
Plaintiff purchased her own ticket and promoted the event for $150 to avoid commitment and confusion.
October 1, 2017, Vegas was the target of a deadly shooting, 58 lives were lost.
19. On October 23, 2017, upon returning from home with a meeting with Nevada State Bank, Plaintiff observed: “body fluid” or “semen” on her toilet. Police were called and a report was filed.
For the immediate 3-4 weeks thereafter, there was “shooting”, “fighting”, “sounds of rape and child molestation” with no police responses, when called.
20. From August 2017 to the Present, Plaintiff has been the “target” of Defendant any/all known associates and affiliates who conduct business or engage in casual contact with said Defendant. On December 31, 2017, while attending Chris Brown’s concert at Drai’s, Plaintiff was attacked from behind by an unknown person who grabbed and started punching her, when she retaliated and began to defend herself, she was removed and banned from Drai’s, per the instructions of Anthony Wilson.
21. June 7, 2018, Plaintiff relocated from Clark County Nevada to Los Angeles County, CA to seek safety and shelter, where she was forced to live in a vehicle until September 2019. Where she immediately relocated to Encino, CA in the vicinity of Defendants’s corporate office location (unbeknown to Plaintiff at the time).
22. From August 2018 to August 2020 Plaintiff was subject to every kind if harassment imaginable from car chases, collisions, assault(s), battery(s), and “life-threatening confrontation” that could have resulted in the harm, “injury”, “safety” and/or “security” as she was aggressively pursued from county to county throughout Los Angeles.
23. From August 2018 to August 2020 Defendant uses situations, and or incidents from real occurrences to justify his filming projects while subjecting Plaintiff, her children, and known associates to dangerous and potentially deadly situations, which he portrayed as casting for a show and/or movie for his film production(s).
24. In February 2019 A group of men approached Plaintiff while trying to keep warn at a local homeless fire, three men attempted to set Plaintiff’s clothing afire. This homeless encampment was less than 5 miles from the address listed for Defendant in Woodlawn Hills.
In March 2019 Plaintiff was chased and crashed into a wall in Santa Monica on 3rd/Pico in the parking lot of the bowling alley. Airbags on rented vehicles imploded causing the driver to pass out of the vehicle after slamming into a wall.
April 1, 2019, Plaintiff purchased a 25’ RV the brake line was cut prior to driving off. This was the day after rapper Nipsey Hussle was shot. The RV has purchased blocks from the shooting, in the community where Nipsey Hussle owned The Marathon Shop.
This prompted an appearance by The Nation of Islam and its leader Louis Farrakhan and the Supreme Captain Mustapha Farrakhan to speak to interceded on Plaintiff’s behalf, as threats of violence circulated throughout Los Angeles and its community.
April 10, 2019, Plaintiff’s granddaughter was seized by DCFS, forcing the plaintiff to return to Chicago to assist her daughter Dejanara to recover her daughter, after being detained by Chicago Police.
25. In May 2019 Plaintiff was seized out of her vehicle for a week. Forcing her into homelessness in Venice, CA where Defendant, his associates, and unknown offenders chased Plaintiff on foot until she could secure a safe place to dwell while awaiting money to lease another vehicle.
From May to August 2019 Defendant rented a room at Hotel Ervin in Venice, the same location for Bernie Sanders’s speech in Venice, steps from where Plaintiff’s body was recovered; blocks from where her car was seized.
In one instance, Plaintiff was offered a drink on or about May 28, 2019, to which she accepted (regretfully). Plaintiff woke up in an alley covered with garbage and boxes waiting for the garbage people to discard her remains.
26. In June 2019 While Plaintiff conducted research for claim(s) against Scottie Pippen, Plaintiff son Diandre Valentine was arrested for trafficking charges, directly associated and in relation to the relationship Curtis “50 cents,” Jackson has with Lisa R McCoy who is also in an open relationship with his father Morgan Proctor, and a lesbian twist with Morgan’s wife Robin Kent.
The objective was to remove Diandre from any potential claims or inheritances from his father.
27. From December 2019 to January 2020 Plaintiff’s daughter was subject to cruel and abusive behavior as she was “cast” for roles, which in turn were “human trafficking” platforms to seek revenge or cause mental and emotional distress. In some instances where Plaintiff would pick up an order for delivery, her daughter was being sexually assaulted in the restroom, with no police assistance and/or help. Using the guise that Defendant was “filing a movie” or abusing his celebrity status to have open access.
28. While working for various Gig-Apps, Plaintiff would receive mock or fake orders to fans who would file bogus and/or false complaints, attack while attempting to complete a delivery, or there was a person being attacked and/or assaulted while I was waiting for the customer to accept the order.
29. On August 25, 2020, Plaintiff returned to Chicago where she is known among all federal, state, and local authorities, and to seek legal action. Since returning the stalking and harassment have continued. Defendant has been sighted in the Southshore Community where Plaintiff resides, the defendant has used his influence to attempt to stalk, harass and intimidate; defendant continues to access the Plaintiff and her children, with intention of causing harm, as it is rumored, he is “alleged” to have was involved with the shooting of Plaintiff’s son Devonte Pippen. Whereas there is no direct evidence that gives a resounding involvement, his behavior and activities since the death have caused question(s).
On April 25, 2021, Plaintiff daughter Dejanara Valentine was “caught” entering 6900 S South Shore where incidents of “human”, “drug” trafficking, and “other questionable activities, were called into question. Stopped before entering the building, this confirmed Plaintiff’s concern that she heard her daughter in previous incidents that week, that included a “woman being raped and beaten”. Please refer to Valentine vs Lotus Realty 21-L1-11783.
Plaintiff Chyvette A. Valentine has made several public appearances to “reestablish” herself within the community, which have had deadly or fatal results including and not limited to:
· May 10, 2021, visit to Sam Chatman at the 50-yard line located at 353 E 75th, 2 weeks later there was a shooting.
· May 31, 2021, Attack by Slab Rib Owner, Trina Trice (case 21-Mi-300843)
· June 27, 2021, BET Awards, Shooting on 71st/Cyril in Southshore
· July 7, 2021, visit Danny Davis while Joe Biden visited, 2 days later, major shooting on Kilpatrick.
· July 2021 Valentine vs Pretty Nails, Plaintiff’s eyes were “glued shut”
July 24, 2021, threats from Cedric P Harris, hired handler of Plaintiff’s daughter Dejanara Valentine. Curtis “50 cents Jackson” compensates family and friends, to “handle”, “Travel”, with Plaintiff’s daughter for “sexual encounters”. Dejanara has been “sighted and confirmed” in
· Tucson, AZ
· Las Vegas, NV
· Los Angeles CA
· Atlanta, GA
· Milwaukee, WI and
· Miami, FL
Under the “guise” that she was being cast for “movie and/or tv roles” when she was, in essence, being “handled” for organized “human trafficking”.
Plaintiffs’ daughter was forced and/or coerces into stories for TV shows and attended events, to provide testimony to discredit Plaintiff for the purpose of presenting an image of a “cheater” or “Side chick” some of these shows include and are not limited to:
· The Steve Harvey Show
· Wendy Williams
· Several Sporting Events
· Kobe Bryant’s Funeral
· Superbowl 2019
· DNC Debate at LMU in Los Angeles
COUNT I
(Violation of The Illinois Hate Crime Act 720 ILCS 5/12-7.1)
30. For their paragraph 30, Plaintiffs repeat, reallege, and reincorporate herein Paragraphs 1 through 29 as if the same were fully set forth herein.
31. Defendant intentionally committed unlawful acts, assault, battery, aggravated assault, intimidation, stalking, cyberstalking, misdemeanor theft, criminal trespass to residence, misdemeanor criminal damage to property, criminal trespass to vehicle, criminal trespass to real property, mob action, disorderly conduct, the transmission of obscene messages, harassment by telephone, or harassment by reason of Plaintiffs’ gender, religious beliefs, physical and mental disabilities, and ancestry, all in violation of the Illinois Hate Crime Act, 720 ILCS 5/12-7.1.
32. Defendant committed the actions described in this Complaint willfully, wantonly, and with malicious disregard of Plaintiffs’ rights.
33. As a direct and proximate result of Defendant’s acts in violation of the Illinois Hate Crime Act, Plaintiffs have suffered severe emotional distress, anguish, and humiliation, and continue to suffer emotional distress, anguish, and humiliation.
WHEREFORE, Plaintiffs ask that this Court enter judgment in their favor and against Defendant Curtis “50 cents” Jackson and “Anthony Wilson” on Count I and award relief as follows:
A. Actual damages sufficient to compensate Plaintiffs for the expenses and costs incurred and directly caused by Defendant’s actions.
B. Actual damages are sufficient to compensate Plaintiffs for their injuries, including the pain, suffering, and emotional distress caused by Defendant’s actions.
C. Punitive damages in light of the willful, wanton, and reckless actions of Defendant, in an amount sufficient to punish Defendant for his actions and hold him fully accountable, and to deter others from following his example.
D. Costs and disbursements, including reasonable attorneys’ fees, in accordance with 720 ILCS 5/12-7.1(c);
E. Prejudgment interest on all damages.
F. A permanent injunction prohibiting Defendant from engaging in any further or prospective contact with Plaintiffs; and
G. Such other and further relief as the Court may deem just.
COUNT II
(Violation of Illinois Human Rights Act)
34. For their Paragraph 34, Plaintiffs repeat, reallege and incorporate by reference paragraphs 1 through 33 of this Complaint as if fully set forth herein.
35. The Defendant, by his actions described herein, intended to and did coerce, intimidate, threaten or interfere with Plaintiffs in the exercise and enjoyment of, or on account of their having exercised or enjoyed, their right to own the property free from unlawful discrimination based on race, color, and national origin, in violation of Illinois Human Rights Act, section 3-105.1, 775 ILCS 5/3-105.1.
36. As a direct and proximate result of Defendant’s acts in violation of the Illinois Human Rights Act, Plaintiffs have suffered severe emotional distress, anguish, and humiliation, and continue to suffer emotional distress, anguish, and humiliation. They feel like prisoners in their own homes. Plaintiffs fear for their own safety and for the safety of their children. Plaintiffs are afraid to dwell outside of their homes.
WHEREFORE, Plaintiffs ask that this Court enter judgment in their favor and against Defendant Curtis “50 cents Jackson”, Anthony Wilson dba G-Unit Films and Movies, also G-Unit Recordings on Count II and award relief as follows:
A. Actual damages sufficient to compensate Plaintiffs for the expenses and costs incurred and directly caused by Defendant’s actions.
B. Actual damages are sufficient to compensate Plaintiffs for their injuries, including the pain, suffering, and emotional distress caused by Defendant’s actions.
C. Punitive damages in light of the willful, wanton, and reckless actions of Defendant, in an amount sufficient to punish Defendant for his actions and hold him fully accountable, and to deter others from following his example.
D. Costs and disbursements, including reasonable attorneys’ fees, in accordance with 775 ILCS 5/10-102(c);
E. Prejudgment interest on all damages.
F. A permanent injunction prohibiting Defendant from engaging in any further or prospective contact with Plaintiffs; and
G. Such other and further relief as the Court may deem just.
COUNT III
(Assaults and Battery to Plaintiffs)
37. For their Paragraph 37, Plaintiffs repeat, reallege and incorporate by reference paragraphs 1 through 34 of this Complaint as if fully set forth herein.
38. Defendant’s intentional and unlawful acts as alleged in this Complaint constitute an 18-year pattern of harassment. Defendant’s acts gave and continue to give Plaintiffs a well-founded fear of imminent peril and a reasonable with the murder of Devonte Pippen.
39. On or about September 2017 Anthony Wilson sent a direct text and threatened to “Pay $4000 to anyone who provides proof of your death” and many other threats.
40. During this act, Defendant had the apparent present ability to cause imminent harm or injury to Plaintiffs and to inflict a battery upon Plaintiffs.
41. Defendant committed the actions alleged in this Complaint willfully, wantonly, and with malicious disregard of Plaintiff’s rights.
42. As a direct and proximate result of Defendant’s acts of assault, Plaintiffs suffered injuries, severe emotional distress, and anguish, and continue to suffer severe emotional distress and anguish.
WHEREFORE, Plaintiffs ask that this Court enter judgment in their favor and against Defendant Curtis “50 cents Jackson”, Anthony Wilson dba G-Unit Films and Movies, also G-Unit Recordings on Count III and award relief as follows:
A. Actual damages sufficient to compensate Plaintiffs for the expenses and costs incurred and directly caused by Defendant’s actions.
B. Actual damages are sufficient to compensate Plaintiffs for the injuries described above, including the pain, suffering, and emotional distress caused by Defendant’s actions.
C. Punitive damages in light of the willful and wanton actions of Defendant, in an amount sufficient to punish Defendant for his actions and hold him fully accountable, and to deter others from following his example.
D. Prejudgment interest on all damages.
E. A permanent injunction prohibiting Defendant from engaging in any further and prospective contact with Plaintiffs; and
F. Such other and further relief as the Court may deem just.
COUNT IV
(Intentional Infliction of Severe Emotional Distress)
43. For their Paragraph 43, Plaintiffs repeat, reallege, and incorporate herein Paragraphs 1 through 42 of the Complaint as if the same were fully set forth herein.
44. Defendants’ acts, as alleged in this Complaint, constituted extreme and outrageous conduct.
45. Defendants’ acts, as alleged in this Complaint, were such that Defendants knew severe emotional distress was substantially certain to result.
46. Defendants, by their acts alleged in this Complaint, caused severe emotional distress to the Plaintiffs. The emotional distress suffered by the Plaintiffs was such that no reasonable person could be expected to endure.
47. As a direct and proximate result of Defendants’ acts, Plaintiffs have suffered severe emotional distress and have been harmed, including suffering significant mental anguish, significant amounts of weight loss, and being unable to sleep.
WHEREFORE, Plaintiffs ask that this Court enter judgment in their favor and against Defendants as to Count IV and award relief as follows:
A. Actual damages sufficient to compensate Plaintiffs for the expenses and costs incurred and directly caused by Defendant’s actions.
B. Actual damages are sufficient to compensate Plaintiffs for their injuries, including the pain, suffering, and emotional distress caused by Defendant’s actions.
C. Prejudgment interest on all damages.
D. A permanent injunction prohibiting Defendant from engaging in any further contact with Plaintiffs; and
E. Such other and further relief as the Court may deem just.
JURY DEMAND
Plaintiffs demand a jury trial of all issues properly triable by a jury in this action.
Date: Wednesday, December 9, 2021
Respectfully submitted,
Chyvette A Valentine
Pro Se; 99500