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Friday, June 14, 2024

FILED BEFORE TONIGHT'S GAME : Valentine vs Waterton response filed 2024L002089



PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

            The Plaintiff respectfully submits this opposition to the Defendant's motion to dismiss, as outlined, on the grounds that the case at hand fundamentally challenges the Defendant's failure to act on complaints concerning retaliation activity(ies) which are prohibited in Cook County, Il. The Plaintiff respectfully submits this opposition to the Defendant's motion to dismiss, asserting that the Defendant's actions are in direct violation of the public policy of the City of Chicago. This policy explicitly prohibits landlords from engaging in retaliatory actions against tenants, except in cases where there has been a violation of a rental agreement or a breach of a law or ordinance. The Defendant, as the landlord, is alleged to have knowingly terminated the tenancy, increased the rent, decreased services, and threatened to bring a lawsuit against the Plaintiff for possession. These actions were purportedly taken in response to the Plaintiff's good faith efforts to assert their rights as a tenant. Furthermore, the Defendant is accused of refusing to renew the lease or tenancy, which is another form of retaliation that is strictly forbidden by the aforementioned policy. The Plaintiff maintains that she has not violated any terms of the rental agreement or any laws or ordinances, and as such, the Defendant's retaliatory actions are not only unwarranted but also unlawful.

Therefore, the Plaintiff implores the court to consider the gravity of the Defendant's actions and the potential implications for the Plaintiff's rights as a tenant, and to deny the Defendant's motion to dismiss.

Plaintiff, in this case, is seeking to recover costs incurred as a result of her untimely displacement, a situation that has not only left her homeless but also at risk of losing all her personal property. This includes the remains of her deceased son, material evidence pertinent to this case and others, and other significant property related to this matter, subject to auction on June 24, 2024, as a direct result of actions taken by Defendants in this matter. The gravity of the situation is further compounded by the fact that this displacement is a direct result of obstruction of justice and tampering with a witness. The plaintiff was forced into homelessness, a circumstance that was made perfectly clear to the executive of Waterton Residential. Despite having full knowledge of the events as they transpired, the executive refused to intervene or take accountability for the actions of the staff and management.

This refusal to act, despite the clear and present danger to the plaintiff's wellbeing and property, is a gross dereliction of duty. The plaintiff now seeks to recover the costs associated with this displacement and the potential loss of her property, as well as seeking justice for the obstruction and witness tampering that has occurred. The tone of this case is one of grave concern and urgency, as the plaintiff's livelihood and justice hang in the balance.

In a clear violation of the legal procedures, the Defendants executed an eviction without any prior notification to the Plaintiff, a move that starkly contravenes the stipulations outlined by the law. The Plaintiff was not served with any eviction proceedings, a fundamental requirement in such matters, which further underscores the irregularity of the Defendants' actions. This abrupt eviction occurred amidst an outstanding legal issue that is currently pending, specifically concerning damage due to the loss of property. See Valentine vs Waterton Residential 20231113048.

This loss was a direct result of a severe bed bug infestation that plagued the Plaintiff's residence for a distressing period of 9 months. Interestingly, this matter was heard in court merely 4 days prior to the execution of the eviction. Despite this, there was no advance indication of the impending eviction, nor was there any notice of actions pending, further exacerbating the Plaintiff's predicament.

Plaintiff was not properly served any notification of said action, a glaring omission that starkly contrasts with the due process of law. This entire sequence of events raises serious questions about the Defendants' adherence to the law and their respect for the rights of the Plaintiff.

On February 26, 2024, the plaintiff was forcefully and violently evicted from her residence by the Cook County Sheriff, a day before her scheduled court hearing in the case of Valentine vs Congressman Danny K Davis 2023L013006, set for February 27, 2024. This abrupt and aggressive action has raised serious concerns and allegations of retaliatory tactics, purportedly linked to the ongoing case of Valentine vs Congressman Davis 2024CV00676, currently pending in Federal court.

Plaintiff alleges that this eviction was not only an act of intimidation but also a calculated attempt to distract and overwhelm her, thereby hindering her ability to effectively pursue her claims against Congressman Davis. The timing and nature of the eviction have raised questions about the potential misuse of power and the undermining of the plaintiff's rights. This incident underscores the importance of ensuring that legal proceedings are conducted in a fair and unbiased manner, free from any form of coercion or intimidation. It is crucial that the plaintiff's allegations are thoroughly investigated to uphold the integrity of the judicial process and to safeguard the rights of individuals involved in legal disputes.

Plaintiff has finally put forth allegations that the eviction in question was not merely a routine enforcement of property rights, but rather, was executed with a willful and/or “premeditated intentional intent”.

Plaintiff asserts that this eviction was strategically timed and carried out to influence the outcome of the 7th Congressional District election, in which Congressman Danny K Davis was a candidate.

Plaintiff further alleges that this eviction was not only intended to sway the congressional race, but also to manipulate the results of the States Attorney election. These allegations, if proven, could reveal a deeply troubling misuse of power and a blatant disregard for the democratic process.

Plaintiff's claims underscore the importance of maintaining the integrity of our electoral system and ensuring that all actions taken in relation to it are free from ulterior motives or manipulative intent.

ARGUMENT

Plaintiff’s complaint states a claim upon which relief may be granted. Plaintiffs ask the courts to allow said case to proceed based on the following: 1. Defendants colluded with abuser former Chicago Bulls player Scottie Pippen to conceal and/or cover up rape, illegal seizure, stalking and/or harassment for political and monetary gain, willfully causing Plaintiff and her family immense and irreparable mental, emotional, financial, psychological duress. 2. Defendants willfully used Plaintiff information, data and confidentially protected (collected) information and/or access, to abuse, misuse and exploit Plaintiff high profiler stalking circumstances for professional advancement, personal gains and posturing; including and not limited to securing leases for the Democratic National Convention, Tickets and favor at Chicago Bulls events abusing his authority and/or knowledge of plaintiff high profile domestic violence history and/or claims. 3.Defendants exploited Plaintiff residency for professional gains; 4. Defendants retaliated with “a forced eviction”, “threats of harm and/or violence”, “delayed assistance”, obstruction of justice “threats of false imprisonment”, “witness tampering”, “slander” and “defamation of personal and professional character” using allies in political power to execute and/or enforce harassing behavior that has led to mental and emotional duress, fiscal duress for Plaintiff. 5. Plaintiff seeks to amend claim to $500,000.

I.                    Defendants colluded with abuser former Chicago Bulls player Scottie Pippen to conceal and/or cover up rape, illegal seizure, stalking and/or harassment for political and monetary gain, willfully causing Plaintiff immense and irreparable mental, emotional, financial, psychological duress.

 In the case of Valentine v Scottie Pippen 2024L002166, the Plaintiff alleges that the Named Defendants, who held significant positions and powers, egregiously abused their authority.

Plaintiff contends that these individuals, through their actions, evoked and enforced illegal eviction. The Plaintiff further alleges that these Named Defendants threatened detainment as a means to suppress any potential exposure of their illicit activities. Moreover, the Plaintiff asserts that these individuals, in a calculated and malicious act of collusion and conspiracy, terminated residency to further oppress and silence the Plaintiff. This eviction, the Plaintiff argues, was a strategic move designed to cover up and conceal the crimes. The Plaintiff maintains that these actions were not only a gross misuse of power but also a flagrant violation of their rights. In the context of the Valentine v Scottie Pippen 2024L002166 case, the Plaintiff accuses the Named Defendants of colluding to "cover up" these activities.

Plaintiff alleges that these individuals, while acting as an advocate on their behalf, were in fact working against them, further exacerbating the trauma and distress they were experiencing. The Plaintiff's allegations paint a picture of a deeply entrenched system of corruption and abuse of power, where those in positions of authority use their influence to perpetrate and conceal crimes, rather than uphold justice and protect the rights of individuals. The allegations made in this case underscore the urgent need for transparency, accountability, and justice in our political and legal systems. It is a stark reminder that those in positions of power must be held to the highest standards of conduct and integrity, and any deviation from these standards must be met with swift and appropriate legal action. 


 

 

II.                 Defendants willfully used Plaintiff information, data and confidentially protected (collected) information and/or access, to abuse, misuse and exploit Plaintiff high profiler stalking circumstances for professional advancement, personal gains and posturing; including and not limited to securing leases for the Democratic National Convention, Tickets and favor at Chicago Bulls events abusing his authority and/or knowledge of plaintiff high profile domestic violence history and/or claims.

Defendants, in a calculated and deliberate manner, willfully utilized the Plaintiff's personal information, data, and confidentially protected details, which were collected under the guise of professional necessity. This egregious misuse of sensitive information was not only a violation of trust but also a blatant exploitation of the Plaintiff's high-profile stalking circumstances.

Defendants, driven by a desire for professional advancement and personal gains, manipulated the situation to their advantage, demonstrating a complete disregard for the Plaintiff's privacy and well-being. This included, but was not limited to, securing leases for the 2024 Democratic National Convention, acquiring tickets and favor at Chicago Bulls events, and leveraging their authority and knowledge of the Plaintiff's high-profile domestic violence history and claims.

Defendants' actions were not only unethical but also potentially illegal, as they abused their authority and exploited the Plaintiff's circumstances for their own benefit. This blatant misuse of power and information is a stark reminder of the need for stringent data protection measures and the importance of maintaining the sanctity of personal information.

Defendants' actions have not only caused significant harm to the Plaintiff but have also undermined the trust placed in them by the public. The untimely planning of the plaintiff's eviction, which coincided with the announcement of Scottie Pippen's No Bulls Tour on February 24, 2024, has raised significant concerns. The tour was purportedly designed to exploit the plaintiff's abusive relationship and history of stalking with Scottie Pippen, a narrative that has been met with widespread criticism.

This exploitation was further exacerbated by Governor JB Pritzker's State of Address, where the plaintiff's precarious housing situation was repeatedly referenced, thus exploiting their "homeless circumstances". It should be noted JB Pritzker and his family formerly owned Presidential Towers now owned by Waterton Residential, dba Presidential Towers. The timing of these events, coupled with the public nature of the discourse, has led to a heightened scrutiny of the plaintiff's personal life, which has been used as a tool for public spectacle. The tone of these events, particularly the State of Address, has been deemed unprofessional and insensitive, as it capitalizes on the plaintiff's misfortunes for political gain. The plaintiff's eviction, the No Bulls Tour, and the State of Address have collectively created a narrative that exploits the plaintiff's personal struggles, thereby undermining their dignity and privacy. This situation underscores the need for a more respectful and empathetic approach to public discourse, particularly when it involves individuals who are in vulnerable situations.

 III.              Defendants exploited Plaintiff residency for professional gains.

 

In the period spanning from July 2022 to June 2023, the Defendants, Waterton Residential, exploited the Plaintiff's residency for their professional gains. This exploitation was manifested in the form of leases that were signed as a direct consequence of the Plaintiff's residency. The Defendants leveraged the Plaintiff's association with high-profile figures and celebrities, such as Scottie Pippen and Taylor Swift, to attract potential tenants and secure lucrative lease agreements. The allure of residing in proximity to such renowned figures was a compelling selling point that the Defendants capitalized on to their advantage. Furthermore, the Defendants also profited from tickets to events and monetary gifts that were exchanged for the participation of these celebrities. This exploitation of the Plaintiff's residency and associations not only resulted in financial gain for the Defendants but also elevated their professional standing in the residential leasing market. The Defendants' actions, however, raise serious ethical and legal questions about the exploitation of personal relationships and residency for professional gains. The Plaintiff's case serves as a stark reminder of the need for clear boundaries and respect for personal privacy in professional dealings.

 

IIII. Defendants retaliated with “a forced eviction”, “threats of harm and/or violence”, “physical assault” by staff members, “delayed services”, “obstruction of justice”, “witness tampering”, “slander” and “defamation of personal and professional character” using allies in political power to execute and/or enforce harassing behavior that has led to mental and emotional duress, for Plaintiff.

The Plaintiff alleges that the Defendants have engaged in a series of retaliatory actions, including forced evictions, threats of harm and/or violence, delayed services, and obstruction of justice.

These actions, according to the Plaintiff, were not only designed to intimidate and harass, but also to inflict mental and emotional duress.

Defendants are also accused of making threats of false imprisonment, engaging in witness tampering, and spreading slanderous and defamatory statements about the Plaintiff's personal and professional character.

Plaintiff contends that these actions have not only caused significant emotional distress but have also resulted in fiscal duress.

Plaintiff further alleges that the Defendants have used their allies in political power to execute and enforce this harassing behavior.

Plaintiff argues that this misuse of political connections to further personal vendettas is not only unethical but also a clear violation of their rights.

Plaintiff seeks redress for these alleged actions, asserting that they have suffered considerable harm as a result of the Defendants' retaliatory behavior.

Plaintiff's allegations highlight the potential misuse of power and the damaging effects of retaliatory actions on individuals' lives and livelihoods.


 

IV. Defendant seeks to amend claim to $500,000.

Plaintiff, in this case, is seeking to amend their claim to $500,000 for damages associated with an alleged illegal retaliatory eviction, a serious violation of tenant rights. This claim is grounded in the provisions of the Chicago Residential Landlord & Tenant Ordinance, specifically Section 5-12-150, which explicitly prohibits retaliatory conduct by landlords. This ordinance is designed to protect tenants from vindictive actions by landlords, such as eviction, in response to a tenant's exercise of their legal rights. The plaintiff alleges that the landlord's actions were not only in direct contravention of this ordinance but also resulted in significant financial and emotional distress. The damages sought have been calculated to reflect the gravity of the landlord's alleged misconduct and the substantial harm suffered by the plaintiff. The amendment to the claim is a necessary step in ensuring that the plaintiff is adequately compensated for their losses. It is also a clear signal to landlords that retaliatory evictions will not be tolerated and that they carry significant legal and financial consequences. The plaintiff's action underscores the importance of the Chicago Residential Landlord & Tenant Ordinance in safeguarding tenant rights and promoting fair and equitable landlord-tenant relationships. It serves as a reminder that landlords must adhere to the law and respect the rights of their tenants or face severe penalties.

I certify that all statements made in this Motion are true and correct. I understand that making false statements is perjury under 735 ILCS 5/1-109.