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.