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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION

Chyvette A. Valentine,   Plaintiff,   v.   Chicago Bulls, Scottie Pippen, Carl Pippen, Larsa Pippen et. al., Defendant(s).

No. 2024L002166   Courtroom   Judge Maire Aileen Dempsey   Damages: $300 Million   Three Hundred Million dollars

 

FIRST AMENDED COMPLAINT

In this complex and multifaceted case, the plaintiff brings forth a claim that spans over three decades, alleging a series of legal violations that have caused significant harm and distress. The plaintiff alleges that the defendant has engaged in a pattern of behavior that includes stalking, as defined by 720 ILCS 5/12-7.4, and harassment, as outlined in 720 ILCS 5/26.5-3. The plaintiff further contends that the defendant has demonstrated a clear intent to cause harm, a violation of 720 ILCS 5/7-8. The plaintiff also alleges that the defendant has willfully and intentionally inflicted mental and emotional distress, a violation of 740 ILCS 21/10. The plaintiff claims to have been the recipient of death threats, a serious violation of 720 ILCS 5/8-1. In addition to these allegations, the plaintiff accuses the defendant of defamation of character and slander, as defined by 740 ILCS 145. Beyond these violations, the plaintiff seeks compensation for child support arrears and palimony, both associated with a relationship that has lasted since 1987.

 

This case represents a serious and long-standing pattern of alleged abuse and violation of the plaintiff's rights. The plaintiff's claims, if substantiated, represent a significant breach of trust and violation of personal rights, warranting serious consideration and potential legal consequences. The court is tasked with the responsibility of carefully examining the evidence presented, considering the long duration of the alleged violations, and determining the appropriate legal and financial remedies for the plaintiff.

Plaintiff's allegations paint a picture of a prolonged and relentless campaign of abuse and intimidation, which has caused significant harm and distress.

Plaintiff seeks redress for these alleged violations, asserting that the defendant's actions have caused significant harm and distress. The tone of the plaintiff's claim is one of grave seriousness, reflecting the severity of the alleged violations and the profound impact they have had on the plaintiff's life.

Plaintiff's claim arises from an extensive history spanning over 30 years, involving domestic violence, stalking, harassment, and threats of harm perpetrated by the defendant(s) and/or their family members and associates.

From 1987 to the present, the plaintiff has been subjected to continuous and escalating patterns of abusive behavior that have caused significant emotional, physical, and psychological harm. The harassment and stalking have been persistent, invasive, and have severely impacted the plaintiff's quality of life, safety, and well-being. These actions have resulted in substantial distress, trauma, and significant life disruptions, including the loss of employment and housing.

Most tragically, the plaintiff's son, Devonte Pippen, was murdered on January 19, 2012. This devastating loss is a direct consequence of the defendant(s)' actions and has caused irreparable damage to the plaintiff's life.

Plaintiff seeks appropriate legal remedies to address the ongoing abuse, prevent further harm, and seek justice for the loss of her son. This includes but is not limited to compensatory and punitive damages, restraining orders, and any other relief deemed necessary by the court to ensure the plaintiff's protection and to hold the defendant(s) accountable for their actions.

JURISDICTION

This Court has Jurisdiction, as the events that transpired occurred in Cook County, Illinois. Pursuant to 735 ILCS 5/21-101, this is the proper venue to proceed with said claim.

BACKGROUND

Plaintiff began her professional career in 1985 with Andy Frain Security Services, where she had the distinguished opportunity to work at the world-famous "Jackson Victory Tour," providing front-row security for all three nights of the event.

Progressing in her career, the plaintiff joined Unique Protection Services in Los Angeles, California, under the leadership of Reginal Brass. During her tenure, she provided security at high-profile events such as the Grammys, American Music Awards, and Soul Train. Notably, she also worked at the historical recording of "We Are the World" at Kenny Rogers' studio in 1985.

From 1985 until the closing of E2 nightclub in 2003, the plaintiff worked in various capacities, including security, promotions, and events (sales), at Hero's (1985), later known as The Clique (1993), and eventually E2 nightclub. This venue was renowned for hosting athletes and celebrities’ post-games and after concert events. Throughout this period, she was employed by Calvin Hollins as a security escort.

 

Plaintiff has a notable background as an independent private hire security escort, working with renowned comedians such as Martin Lawrence, Fast Eddie Griffith, DL Hughley, and Bernie Mac at The Clique in Chicago. Her experience extends to working with prominent boxers, including Mike Tyson on New Year's Eve 1992, alongside Tony Pitts, and Floyd Mayweather in 2019 at his nightclub Girl Collection in Las Vegas, NV. http://cat7thward.wixsite.com/sundayscatering/security

Plaintiff's extensive career also includes providing security services for a wide range of athletes, artists, and entertainers. Some of the notable names she has worked with include Michael Jackson, Whitney Houston, Prince, Janet Jackson, New Edition, LL Cool J, Run DMC, Yo-Yo, Eric B & Rakim, Fresh Prince & Jazzy Jeff, Queen Latifah, Public Enemy, Whodini, Teddy Riley & Guy, Keith Sweat, Silk, TLC, Bow Wow, Naughty By Nature. Additionally, the plaintiff has worked as a "tour assistant" with industry figures such as Bobby Sanders, Lonnie Ferguson, and Phil Robinson from Def Jam.

I.                    Volunteer Work with the NBA:

In 1995, the plaintiff volunteered with the NBA in Phoenix, AZ, where she worked in guest services for the NBA and its players. During this time, she had the opportunity to engage with the players and their families, providing exceptional guest services. Notably, the NBA has footage of the plaintiff’s son, Diandre Valentine, playing basketball during a special playtime for his birthday. The footage also includes Diandre meeting Shaquille O'Neal during a press conference and attending Brandy's birthday party in 1995.

Plaintiff often worked as a security escort in the VIP section with the players and/or their wives or dates, including, but not limited to, Juanita Vanoy Jordan and Donna Grant. Her responsibilities often involved providing concierge services to celebrities and their guests, working alongside Dawn Hendrick (Milhouse) and Sonya DeBerry. She frequently networked and promoted parties and events where she worked exclusively with NBA players.

II.                 Notable Client: Michael Jordan

One of the plaintiff’s most notable clients in Chicago was Michael Jordan, who lived at 2559 Essex Rd, Northbrook, IL 60062.

She personally promoted and escorted Jordan at numerous after-hour events, including Michael Jordan’s birthday celebration at Palmer House in 1985 and the Spike Lee Fundraiser for the movie "Malcolm X" at the Walnut Room at Marshall Field’s in 1991.

The plaintiff worked as an independent contractor for various events hosted by and/or for Michael Jordan from 1985 until his retirement.

Plaintiff and Michael Jordan have been “affiliated” since his recruitment to the Bulls and would often attend events by request of Michael Jordan, which is how she was introduced to Scottie Pippen in 1987.

III.              Introduction to Scottie Pippen:

Plaintiff was introduced to Scottie Pippen by Charles Oakley, whom she met in Cleveland, Ohio, in 1985 while on tour with LL Cool J, serving as a security escort with Kevin Buie.

A.     Plaintiff's Relationship and Subsequent Events with Scottie Pippen:

Plaintiff dated Scottie Pippen from October 1987 until February 1988. The relationship ended when Pippen, during sexual intercourse, confessed to being married. Upon learning this, the plaintiff demanded the relationship cease due to his marital status.

In 1991, after Pippen divorced his then-wife Karen, he sought to reestablish his relationship with the plaintiff. They resumed their relationship until an event hosted by the plaintiff for Pippen at the Dating Game lounge, located at 8924 S Stony Island Ave, Chicago, IL 60617.

Plaintiff ended the relationship once again after discovering Pippen had cheated on her with Lisa Raye McCoy, an associate of Pippen at the time.

Pippen has since maintained an open relationship with McCoy, who has conspired and colluded with Pippen to cause distress, intimidate, and abuse the plaintiff. McCoy has used her celebrity status to stalk, harass, and torment the plaintiff, engaging in unwanted and harassing behavior that has significantly impacted the plaintiff's personal life.

Defendants along with Lisa McCoy later filmed "Players Club" 1993, a movie where Plaintiff is depicted as roommate "Ebonee" to Lisa McCoy, who cheats with her boyfriend, then is sexually assaulted working in a strip club. This is an unauthorized use of personal story Defendant Scottie Pippen is played by O'Shea Jackson aka Ice Cube, and the story is loosely based on a story line version of events based on Lisa McCoy's version of events. Scottie Pippen has used every resource he can to stalk, harass, intimidate causing mental, emotional and financial distress to Plaintiff's children, family, mutual friends, other players namely Earvin Magic Johnson.

B.      Rape Incident on February 18, 1993:

On February 18, 1993, while promoting an event with the singing group Silk, the plaintiff attended an event at the Cotton Club, located at 1710 S Michigan Ave, Chicago, IL. During this event, Scottie Pippen and Carl Pippen sent the plaintiff a drink, which caused her to fall ill. The plaintiff suspected the drink was contaminated and subsequently stopped all activities.

Later that evening, both Scottie and Carl Pippen went to the plaintiff's home located at 10 East Ontario St #2206, Chicago, IL 60611, where they raped her. The rape was reported to the Chicago Police, and the plaintiff received treatment at Northwestern Hospital.

Due to the embarrassment and trauma of being raped by such high-profile figures, the plaintiff relocated to Milwaukee, Wisconsin, where she gave birth to her son, Devonte Pippen, on November 5, 1993.

C.      Unauthorized Use of Personal Story: Players Club 1993 with Lisa McCoy

Plaintiff asserts that the movie "Players Club" depicts a storyline based on their personal experiences without their consent. The character "Ebonee," portrayed as a roommate to Lisa McCoy, represents the plaintiff and her experiences, including cheating and sexual assault. Lisa McCoy and others involved in the making of the film, including Scottie Pippen.

Portrayal and Identification: O'Shea Jackson (Ice Cube) plays a character based on Scottie Pippen in the movie, further linking real individuals to the film's narrative.

FACTS

1.       Plaintiff was in a romantic relationship with Chicago Bulls player Scottie Pippen, which lasted intermittently from October 1987 until February 1993.

2.       Plaintiffs maintain a regular relationship with Defendant, was respected by the team, staff and arena, openly recognized in Chicago as Scottie Pippen’s girlfriend.

3.       Defendant Scottie Pippen equally was granted immediate recognition as he was Chyvette Valentine’s boyfriend, which made him popular.

4.       From 1985 until 1987 Michael Jordan, and Charles Oakley would weekly visit Ernie’s Barber Shop located at 4110 W Madison, Chicago, Il 60644 before games to “get his weekly grooming”, then “pass Plaintiff’s home”, “blow horn” and ask “if she (Plaintiff) was (is) attending the game that night?

5.       This was an “extended invitation”, which meant “follow me to the game”.

6.       Plaintiff would get into her vehicle and follow Michael Jordan to the Chicago Bulls Stadium, where she walked in with him and sat wherever she liked, traditionally behind the bench where he could hear her “trash talking” during the games.

7.       Plaintiff never purchased tickets to any Chicago Bulls games from 1985 until 1993, “she walked into the arena, free of charge for every event attended with Michael Jordan” at gate 3.5.

8.       From 1985 to 1987 Plaintiff was a frequent guest of Michael Jordan, who would often invite her to the Deerfield Multiplex when it was newly constructed, to visit during practices.

9.       When Scottie Pippen was recruited in 1987, he joined the two in weekly grooming and would also drive to Plaintiff home then located at 4627 W Monroe, Chicago, IL 60644 to ask if she was attending the nights events.

10.   Plaintiff would spend the night often and leave for work at O’Hare airport from his home.

11.   January 1988 season, Pippen invited Plaintiff to visit him during the Bulls vs Detroit series, claiming he needed me present for moral support, along with best friend Sharon Tharpe.

12.   The plaintiff traveled to Detroit and stayed at the Renaissance Hotel; she paid her own expenses for travel with a promise of being reimbursed. When Plaintiff arrived at Scottie’s suite, he began acting strange, like he was trying to impress Plaintiff. His behavior was unusual and abnormal.

13.   When parties began to engage in intimate exchanges Plaintiff noticed a shadow in the bathroom. Charles Oakley was hiding in Scottie’s bathroom hoping to partake in group sex.

14.   Plaintiff entered restroom demanding an explanation from Charles Oakley, who was ultimately the reason parties met. He refused to explain then left the room.

15.   Plaintiff refused to partake in any group/orgy sex activities and attempted to leave. Scottie punched Plaintiff in the face and exclaimed, “If I cannot have you, nobody will”, “I will kill you and everyone who loves you”.

16.   After sex Plaintiff returned to her room where she confided events with Sharon Tharpe and refused to meet and/or see Pippen alone, or in private after that event.

17.   February 14, 1988, Defendant Scottie Pippen invited Plaintiff to his home to apologize, Plaintiff agreed to meet under the condition, upon arriving at his home Plaintiff noticed (8-10) cases of baby formula stacked behind the door. Scottie claimed they were for his sister’s baby who was born in December. Plaintiff later learned he fathered a son Antron Pippen who was born on December 29, 1987, three months before said encounter.

18.   During sexual intercourse, Scottie Pippen confessed he was married to “Karen McCullom”, which sparked a heated argument regarding broken/empty promises, adultery and infidelity issues.

19.   Plaintiff excused herself from any further dealings and left his home.

20.   February 1990 to November 1991 Plaintiff was employed at Illinois Medical Training Center located at 162 N State Street, Chicago, IL 60611.

21.   Plaintiff then began working for Randolph Beepers, with Tony Blair where the Jordan Codes were created, also located at 162 N State Street, Chicago, IL 60611.

a.       “Jordan Codes” are “morse codes” and/or numbers that communicate messages to call games for players with specific meaning, i.e. Jordan (23), Pippen (33), rape (11), or Marijuana (21) a code often used by Players looking to score locally, using discretion.

b.       Example if Jordan sent Plaintiff a beer, he would send 312-123-4567-23-21 which would mean this is Jordan, bring me marijuana.

c.       Plaintiff would be obliged to request in accordance to said request.

d.       These codes are actively used in the present day to predict the outcome of games and/or series.

22.   Plaintiff was invited to Michael Jordan fundraiser for Spike Lee in 1991 (exact date unknown) at Marshall Field’s Walnut Room.

23.   Spike Lee was filming the movie Malcolm X at the time.

24.   Plaintiff was assigned security escort and roommate Malika Shabazz, daughter of the late Malcolm X.

25.    Plaintiff invited Lisa McCoy, a model she managed, her mother Katie McCoy, and aunt Linda.

26.   Plainitf invited Supreme Captain Mustapha Farrakhan, of the Nation of Islam.

27.   This debut was the event that led to the first Bulls NBA Championship in 1991.

28.   From 1990-1992 season, Plaintiff hosted various events in Chicago, at various venues including and not limited to The Club Ultimate in Harvey, IL, The Clique located at 2347 S Michigan, The Cotton Club located at 1910 S Michigan, and Chick Ricks located at 2201 S Michigan, Chicago.

29.   This also included “601 Parties”, hosted by former Alderman Howard Brookins of Chicago City Council.

30.   Attendees would include the entire Bulls team namely Brad Sellers, Cliff Livingston, Stacy King, Jeff Sanders and other team members who knew of Plaintiff relationship with Jordan, in addition to dating Scottie Pippen. See photos.

31.   In August of 1991 during an event hosted by Plaintiff at The New Dating Game, Scottie Pippen was the guest of honor.

32.   Plaintiff often hosted parties, events and such at local clubs, and asked him to appear.

33.   Upon arriving Scottie Pippen was seated in the VIP area where drinks and food were served, when then roommate Lisa McCoy arrived and showed interest in the player.

34.   In an attempt to embarrass and/or upstage Plaintiff, Scottie Pippen began rubbing and touching on Lisa McCoy who came as guest of Plaintiff and knew of our relationship.

35.   Allegations of abuse, threats, racism, and other form of mistreatment were reported.

36.   Plaintiff confided in friends, family and others her lack of interest in continuing any form of relationship with Scottie Pippen, who harbored deep embedded destain relating to his career with the Chicago Bulls.

37.   Defendant Scottie Pippen did not fit the culture of the Plaintiff, as he vocalized “racist rants” when he lost games; suppressed his gay lifestyle and feelings towards other players including and not limited to his teammates, harbored ill feelings towards “women in general.”

38.   Events from this evening caused Plaintiff to move out of Lisa McCoy’s home located at 2552 E. 75^th, Chicago, IL where she was her roommate for a “few months”.

39.   This ended her manager/client relationship with Lisa McCoy, whom she managed temporarily.

40.   Plaintiff did not make contact, answer calls, respond to any request to meet, greet or eat with Defendant(s), “his list of red flags for infidelity were too extreme”, within Plaintiff personal inner circle.

41.   From 1992 to 1993 Plaintiff was involved in a relationship with singer Sean LeVert from the singing group LeVert.

42.   June 26, 1991, during the NBA Draft 1991, Plaintiff hosted a private NBA watch party at her home located at 7500 South Shore Drive, Chicago, IL 60649.

43.   In attendance were Dawn Hendricks and Sonya DeBerry.

44.   Dawn Henricks and Sonya DeBerry often asked for input about players given Plaintiff extensive history with Michael Jordan.

45.    Prior to the draft Plaintiff picked Gary Payton to be in the top #10 pick to be drafted.

46.   David Stern announced the pick Gary Payton was Seattle Supersonic #2 Draft pick coming from Oregon State.

47.   Dawn Hendricks then called the NBA hotel where the players were staying and “connected” and/or “introduced” Plaintiff to Gary Payton, who exchanged home contact, phone numbers.

48.   Plaintiff and Gary Payton dated from July 1991 to early 1992 season then parted ways amicably.

49.   Plaintiff was “extremely impressed” with his stats and performance as an overall player and made “suggestions” during her excursion to Seattle.

50.   October 11, 1991, for her birthday in conjunction with Plaintiff’s birthday (October 6); and for Gary Payton’s NBA signing, she flew to Seattle, Oregon to meet his coach, team, family, children and attend his signing party.

51.   Gary Payton signed for $12 million dollars.

52.   During said trip, Gary Payton suggested the possibilities of “being married”.

53.   Plaintiff traveled again to visit Gary Payton, during the Bulls vs Seattle pregame series in Miami.

54.   Coach Phil Jackson, who knows Plaintiff personally chastised Plaintiff when caught in Miami, at the team hotel during Bulls vs Supersonics 1991 Preseason, for “cheating with Gary Payton” after catching her in the hotel elevator, going to Gary Payton’s room.

55.   1991 Eastern Conference Finals series with Detroit, Plaintiff was invited to attend a game by then associate Dawn Hendricks and Sonya DeBerry, she claimed to have tickets and needed someone to drive, Plaintiff agreed.

56.   Upon arriving Dawn Hendricks visited Scottie Pippens room where “sexual favors” were performed in exchange for tickets.

57.   After arriving to the arena, Dawn claimed Scottie only gave her (4) tickets, yet (6) people were present, leaving Sonya DeBerry and Plaintiff stranded without seats.

58.   Plaintiff watched the Bulls team bus arrive, then walked to the players entrance where she called for Michael Jordan, who then walked Plaintiff into arena.

59.   The plaintiff was seated directly behind the bench where the team played.

60.   It was not uncommon for the Plaintiff to sit behind the team, when attending games per Jordan’s request she typically could sit wherever she wished in any arena, as a guest of Michael Jordan.

61.   June 24, 1992, Plaintiff was again invited to attend a private NBA party held at Sonya DeBerry home, Dawn Hendricks, Michelle McDaniel, and Kim Sparks was also present.

62.   Plaintiff showed a special interest in two players Doug Smith and Shaquille O’Neal but did not purse any special intent to meet either.

63.   Shaquille O’Neal was top pick in the 1992 Draft.

64.   July (XX) 1992 while entertaining for the NBA camp in Chicago, Plaintiff received a call from Dawn Hendericks to the Four Season’s Hotel located at 120 E Delaware, Chicago IL., for a “secret surprise”.

65.   When Plaintiff arrived Shaquille O’Neal, his uncle Jerome and others were gathered in his suite.

66.   Plaintiff was escorted off to the side for a “private encounter” with Shaquille O’Neal.

67.   When Plaintiff awoke, she silently left the room, and maintained “limited contact” thereafter.

68.   August 1992 Plaintiff left Chicago and went on tour with Robert Sanders of “On tour with Bobby Sanders”. Reference Triple Threat, Keith Sweat, Kris Kross, LL Cool J.

69.   Plaintiff worked as security escort and/or assistant depending on the contract and/or budget.

70.   Contracted by Teddy Riley and Guy, she relocated short term to Los Angeles, California, then traveled on the road randomly until her return.

71.   “Bobby Sanders” was hired by “Teddy Riley” was secretly recording “Remember the Time” and “Keep It In the Closet” with “Michael Jackson”.

72.   Plaintiff was present for both studio sessions, per Teddy Riley and traveled with the band often.

73.   Month unknown 1992, Plaintiff took occupancy at 10 East Ontario #2206, Chicago, IL 60611.

74.   Upon returning to Chicago Michael Jordan filmed the video “JAM” with Kriss Kross, at unknown location, (Reminder: I lost a whole day salary because I could not find that location).

75.   Plaintiff worked private hire promotions for local events, clients, made celebrity appearances at local events and networked while modeling and performing throughout Chicago.

76.   Plaintiff appeared on the “Jerry Springer Show” featuring “Women who wanted to be married”. (Date unknown) See Lisa Ely for booking information.

77.   Plaintiff auditioned for the LUV A BULLS, but failed when the team recognized she dated Scottie Pippen. Mike Ditka’s Luv A Bulls Auditions 1992.

78.   Plaintiff modeled for Helen Wooten, HK promotions, various conventions throughout Chicago.

79.   Primary role (source of income) was promoter for The Clique owned and operated by Calvin Hollis, where her duties ranged. Plaintiffs’ roles ranging from server, to dancer, to security.

80.   Most notably Plaintiff was part time choreographer for “The Clique Dancers” a performing arts dance group that performed specifically for the Clique at events, shows and parties.

81.   May 27, 1992, Plaintiff worked security for Boyz II Men and was interviewed by Art Norman after the slaying of Boyz II Men manager “Khalil Roundtree”. https://www.chicagotribune.com/1992/05/27/boyz-tour-death-points-to-security/

82.   The plaintiff was the airport pick-up driver for Brooke Payne.

83.   October 1992 Plaintiff was security escort for Wesley Snipes, publicly/privately with honored guest Lynn Winfield at Operation PUSH, including Dinner at Glady’s, and private party at Hyatt.

84.   Plaintiff “invited” guest Lisa McCoy, for cigars and brandy.

85.   Plaintiff was personal security escort for Mike Tyson, and Tony Pitts, New Years Eve 1992 at the Clique 2347 S Michigan, Chicago, IL 60629 featuring Boyz II Men and Fast Eddie Griffin.

86.   February 18, 1993, Plaintiff hosted a private party for singing group “Silk” who were scheduled to appear the “Tom Joyner Jam” event being hosted at the Congress Hotel.

87.   Plaintiff hosted a separate event at a Blues club across the street, which featured the singing group.

88.   After making their appearance, all attended an after party at the Cotton Club.

89.   Plaintiff hosted events, worked security, and invited special guests to appear regularly, when Scottie and Carl Pippen arrived requesting to speak alone with Plaintiff, she refused.

90.   Later that evening Defendants sent a drink to Plaintiff, citing wanting to rekindle relationship, that he has divorced wife and wanted to reunite.

91.   Plaintiff accepted the drink, listened to appeal, then excused herself from the conversation.

92.   Immediately after consuming swallows of said drink Plaintiff fell ill and began feeling sick which immediately prompted her to return the guests to their hotel, and then home.

93.   Plaintiff had received a “spiked drink”, a substance had been put in the drink.

94.   Scottie Pippen became jealous of Plaintiff in the company of the members of the group and sought to impede any progress or interfere with any “new relationship(s)”.

95.   February 18, 1993, Scottie Pippen and his brother, Carl Pippen, raped and assaulted her after they attended an event at the Cotton Club located at 1910 S Michigan, Chicago.

96.   Plaintiff asserts that this assault resulted in the birth of her son, Devonte Pippen.

97.   Devonte Jeffory Mitchell Pippen was born November 5, 1993, in Milwaukee, Wisconsin.

98.   Plaintiff raised him out of state due to the violent events that transpired resulting in his birth, for her safety, and the safety of her children.

99.   Defendant(s)s was never ordered to pay child support in the “appropriate amounts”, Although the state of Arkansans established paternity (citing Carl Pippen was the father) Illinois refused to enforce child support payments, and Defendants were never called into account for support, there was never a clear understanding of which was the father, which was another trigger of emotional duress for the Plaintiff, she never knew which one was the father.

100.                       Plaintiff left Illinois to heal mentally and emotionally from said events.

101.                       Devonte was named “Jeffory” after Michael “Jeffery” Jordan #23 of the Chicago Bulls.

102.                       Plaintiff who was referred to as Michael Jordan’s “lucky charm” or “source for motivation to play”, was encouraged to return by mutual friends who citied Jordan had lost his motivation to play and had left the Bulls to play baseball for the Chicago White Sox, stating he would not return in Plaintiffs absence.

103.                       September 1993 Plaintiff returned to Chicago for a weekend with Lisa McCoy and guest Alonzo Mourning, whom she transported during his visit to Chicago.

104.                       Alonzo Mourning took Plaintiff shopping at Nike, buying Devonte shoes while discussing details of her pregnancy, and plans with unborn child. Paternity of child being Scottie Pippen.

105.                       The Chicago Bulls maintain that they were "unaware" and "not responsible" for certain issues, yet it was the contributions of the Plaintiff, both on and off the court, which played a significant role in the team's success and their six NBA Championships.

106.                       The Plaintiff provided essential moral and mental support to the team. Furthermore, the Plaintiff hosted events, attended events, and promoted the team, directly contributing to its achievements.

107.                       The persistent disagreements between Scottie Pippen and Michael Jordan were a result of a troubling off-court relationship, which eventually led the Plaintiff to leave the city.

108.                       In 1994, upon returning to Chicago Scottie Pippen made request to “visit” and/or “meet” said child suing various third-party individuals namely Dawn Hendricks to advocate for said “reunion”.

109.                       While enroute to Plaintiffs home to visit Scottie Pippen was stopped by police possessing a firearm in his vehicle.

110.                        Riding along with Scottie Pippen was his brother Carl Pippen.

111.                        The charge was eventually dropped citing the firearm belonged to his brother.

112.                       January 10, 1995, Plaintiff was notified by Dawn Hendricks, and Sonya DeBerry that Michael Jordan wanted her to volunteer for the NBA All Star events in Phoenix, Arizona.

113.                       January 20, 1995, Plaintiff relocated to 4731 W Monroe, Chicago, IL. 60644 with son’s Diandre Valentine and Devonte Pippen.

114.                       February 10-12, 1995, Plaintiff worked as a registered NBA volunteer for the NBA All Star Weekend, hosted in Phoenix Arizona, where she attended with her oldest son Diandre Valentine.

115.                       While Plaintiff worked, her son Diandre Valentine had VIP all access to events including a pickup game with Boyz II Men, access to an exclusive interview with Shaquille O’Neal, and VIP access to singer “Brady’s” birthday party.

 

116.                       December 1998 in fear for her life and the safety of her children, Plaintiff relocated to Atlanta, Georgia where she was the Executive Sous Chef to Chef Donald Wilson, at New Birth Missionary Baptist Church.

117.                       Plaintiff sought to establish child support but was unsuccessful due to lack of information to locate father, in addition the reality of being raped by both men, left Plaintiff seeking clarification of who the actual father was.

118.                       Plaintiff remained in Lithonia, Georgia until 2000 when she was forced to leave due to threats of harm from Pippen.

119.                       Plaintiff relocated to Earle, Arkansas where she resided until October 2005.

120.                       September 10, 2001, Plaintiff initiated child support action against the Pippen brothers. See State of Arkansas vs Pippen case E-2001-379.

121.                       Carl Pippen responded and allegedly submitted samples for DNA testing.

122.                       Scottie Pippen later reported the DNA sample collected was his, and not his brother Carl who accepted credit for DNA to evade “rape charges”, and “child support” that should have been paid.

123.                       On April 10, 2002, Lisa McCoy made a guest appearance at Earle High School for Plaintiffs oldest son Diandre Valentine, she took photos attending a meet and greet, then attempted to reunite after betraying Plaintiff.

124.                       Lisa McCoy later “shared Plaintiffs residence and location” with Defendant(s) Scottie, and Carl Pippen, who were seeking Plaintiffs exact location.

125.                       She called singer Bobby Brown, who was filming a movie (then married to Whitney Houston) and otherers who were “looking for Plaintiff “who had disappeared; for the purpose of raising her children in a country setting, away from city life/influences.

126.                       On June 11, 2002, three days after Mike Tyson fought in Memphis, Tennessee Plaintiffs brakes to her car were “tampered with”. Causing her to crash head on at 85 mph into an 18-wheeler truck.

127.                       Plaintiff barely escaped with her life and has long term damage to her spine because of said collision.

128.                       Plaintiff has a herniated disc, sciatica nerve damage and lower lumbar damages because of said collision.

129.                       Plaintiff’s brake line has been “tampered with”, causing her vehicle to lose control.

130.                       In October 2002, Scottie Pippen invited Devonte Pippen to the Peacock Hotel in Memphis, after the opening of the FedEx arena.

131.                       Scottie Pippen invited Devonte into his private room to meet the family, take pictures and acknowledge “he was in fact the real father”.

132.                       He took photos with all of Plaintiffs children, along with Rev Otis Davis local pastor, and school bus driver, who was later promoted to State Representative.

133.                       A month after said meeting, Plaintiff landlord “removed all windows and doors from her home, forcing her to relocate from Earle, Arkansas to Chicago.

134.                       October 2, 2005, Plaintiff returned to Chicago to establish “true paternity” for her son Devonte Pippen, who was evidence of gang rape by Scottie Maurice Pippen, and his brother Carl Pippen.

135.                       October 25, 2005, Michael Jordan taped an exclusive interview with Oprah Winfred, announcing Plaintiff had returned to Chicago. His good luck charm had returned to Chicago. https://www.oprah.com/oprahshow/one-on-one-with-michael/all

136.                       From October 2005 to 2015, Plaintiff has moved over six (6) times, seeking safe refuse with her children away from stalking and harassment. 1. 425 Beachview Drive, Roundlake Beach, IL, 2. 6221 S St. Lawrence, Chicago, IL, 3. 7656 S Colfax, Chicago, IL 4. 875 Glenlake Dr, Carol Stream, Il. 5. 7718 S Phillips, Chicago, IL. 6. 8005 S Marquette, Chicago, IL.

137.                       At each location Plaintiff and her children reported stalking, and harassment.

138.                       Defendant(s) follow Plaintiff and her children to each address.

139.                       Devonte Pippen was targeted, harassed, bullied at every school.

140.                       From 2005 to present, Plaintiff withstood some of the harshest verbal, physical and mental abuse from NBA fans sent by Scottie Pippen to stalk, harass, intimidate Plaintiff into silence about her child.

141.                       August 9, 2008, Plaintiff attended the Bud Billiken Back to School parade with her children, it was their first parade, where they met many of the people Plaintiff worked with including and not limited to Bobby Rush, Danny Davis, Al Sharpton and Jesse Jackson.

142.                       August 16,2008 Plaintiff allowed her children to appear with Congressman Danny K Davis for the Taste of Austin Back to School parade, where they were featured on his float, and experienced their first parade as participants.

143.                       Plaintiff reported stalking activities to Congressman Danny K Davis during this event and confided in him about the events related to Pippen and wanting to correct records, collect support and establish paternity for her son.

144.                       With instructions from Congressman Danny K Davis, Plaintiff children were “illegally seized” by DCFS to cover up and/or conceal Devonte Pippen’s identity; Plaintiffs sexual assault, and events associated. See Valentine vs Davis 2024cv00676.

145.                       This was in part and/or with assistance from Neshell Robinson, daughter of Alex Robinson Jr. the abusive father figure who abuse Plaintiff as a child, forcing her into state protection after the death of her grandmother.

146.                       Her statements were false and untrue silicate and paid for “attending the wedding of actress Lisa McCoy” to Michael Misak in 2006.

147.                       Neshell Robins was paid to falsify records, make false statements and cause havoc for Lisa McCoy, working for Scottie Pippen

148.                       This was done to “avoid paying child support”, and “extending Devonte any due support, benefits he may have been entitled to because of said parentage”.

149.                       Plaintiff children were held in states custody for (4) four years, with no founded abuse and/or neglect, and were eventually returned to Plaintiff.

150.                       In 2010 Plaintiff attempted to file a federal case 1:2010cv04751. Unfamiliar with the federal filing process, Plaintiff was instructed to refile.

151.                       In 2011 Plaintiff attempted to file a federal case 1:2011cv08532 highlighting the illegal seizure of her children, and the improper placement of children with Ardell Sims, Cedric and Victoria Harris and their family.

152.                       Six months after being returned to Plaintiff, Devonte Pippen was “allegedly” shot by Chicago, DCFS custody. It was later discovered that Devonte has suffered extreme abuse and/or neglect while in DCFS custody and years of abuse by foster parents and guardians whom the state assigned them care. Ardell Sims, Cedric and Victoria Harris were granted temporary guardianship, although they were not related to Devonte.

153.                       It is Plaintiff position that Cedric Harris who later confessed was responsible for the murder of Devonte Pippen, another “gay lover fan” who exploited his access for personal profit and/or gains. Cedric Preston Harris was state assigned with an extensive criminal record, DCFS allowed said placement although Plaintiff strongly contested said placement and/or illegal seizure.

154.                       Plaintiff was unaware of, and not informed of the abuse Devonte suffered while in DCFS custody, as the state concealed Scottie Pippen was the father, crediting the brother Carl for fathering his son. See Valentine v Pippen 2008 claim, which somehow was never assigned a case number, but the claim was filed in Cook County court.

155.                       Tragically, Devonte Pippen was murdered on January 19, 2012.

156.                       After the death of Plaintiffs son, Defendant began initiating contact, sending communications hoping to reunite and/or rekindle relationship. Failing to understand that Plaintiff did not wish to engage in any manner, these attempts became more frequent.

157.                       January 29, 2014 (or so) Plaintiff was invited to ABC studio located at 190 N State, Chicago Il., to be a guest advocating against gun violence by Val Warner.

158.                       It is a fact that Scottie Pippen and Val Warner were “entangled” at one time, and that she and her husband agreeably swing with Scottie Pippen, a lifestyle Plaintiff refuses to engage in.

159.                       The Chicago Bulls encouraged said behavior on and off court.

160.                       Profiting from Players' Sacrifices: Reinsdorf has financially benefited from the hard work and personal sacrifices of the players and their families.

161.                       Lack of Responsibility for Off-Court Behavior: The organization, under Reindorf’s leadership, has allegedly ignored or failed to address the off-court conduct and antics of its players.

162.                       Creating Unrealistic Fantasies: The team permitted the creation of a bedroom to support a fantasy, which contributed to chaos and delusional behavior, particularly involving Scottie Pippen and his entourage. Capitalizing on Chaos: Reinsdorf has allegedly focused solely on profit, neglecting accountability and contributing to long-term issues within the team.

163.                       March 25, 2015, The Chicago Bulls constructed a fantasy bedroom suite, to which Plaintiff was a “suggested guest”, sponsored by Airbnb the vendor or employer of Plaintiffs bed and breakfast platform. https://www.nba.com/bulls/news/nba-legend-scottie-pippen-host-once-lifetime-experience-united-center-home-chicago-bulls. The Chicago Bulls granting full permission planned to “exploit” Plaintiff who was “the invited and/or intended guest” to have sex in the Bulls fantasy suite.

164.                       After refusing to engage in any activities including Defendant(s), the Plaintiff was banned from the platform causing a loss of revenue.

165.                       Defendant(s) abused his celebrity access to gain knowledge and/or information of Plaintiffs whereabout when she traveled, abusing access to track, harass, stalk and eventually forcing her away from being a guest on the platform, forcing homelessness and/or displacement.

166.                       Working in collaboration with Congressman Danny K Davis, Defendant evaded child support, and facing sexual assault charges, making financial donations, offering tickets to events and/or games, Scottie Pippen abused his “celebrity status” to influence politicians, law enforcement, judges and others to conceal his identity and said connection to Plaintiff as it related to her son. See Valentine vs Congressman Danny K Davis 2023L013006 and/or 2024cv00676.

167.                       After the murder of her son Plaintiff sought to relocate from Chicago.

168.                       February 12, 2016, Plaintiff was invited to be a guest on the Steve Harvey Show, featuring families who lost loved ones to gun violence.

169.                       Plaintiff was a featured guest “Steve Harvey talks Chicago Gun Violence” video https://www.youtube.com/watch?v=RAMpnT-rbHY&t=7s

170.                       Plaintiff son Devone Pippen was featured during the closing segment which agitated Scottie Pippen and caused him to retaliate even more to silence Plaintiff provoking her to relocate out of state. #ChicagoGunViolence: Steve’s Final Thoughts || STEVE HARVEY video https://www.youtube.com/watch?v=Lh0Qoa85XEA

171.                       February 27, 2016, Plaintiff suffered a severe head injury resulting in twelve stiches to her forehead, while renting a house managed by “Manage Chicago” located at 8005 S Marquette, Chicago IL 60619, Plaintiff was subject to a “mysterious gas leak” that rendered her unconscious.  Video https://www.youtube.com/watch?v=UvhC8nx1jOg&feature=youtu.be

172.                       When found by paramedics she has a CO2 level of 8 and was informed that 10 resulted in death.

173.                       Manage Chicago failed to install Carbon Monoxide Detectors when Plaintiff took occupancy.

174.                       Chicago Housing Authority did not inspect the unit properly, failed to report unit did not have carbon monoxide detectors.

175.                       Port Out paperwork was issued to Arizona.

176.                       Plaintiff relocated to Tucson Arizona in May 2016, subsequently Defendants Scottie Pippen and associates followed her from city to city.

177.                       Plaintiff relocated with hopes of opening Sunday's Bed and Breakfast, Sunday's Catering and other endeavors.

178.                       Defendants followed her to Arizona, she attempted to file police reports to document said activities, in each circumstance when attempting to report stalking activities, promoting Plaintiff as being unstable, mentally unfit, slandering her name, reputation.

179.                       November 18, 2016, Plaintiff called Congressman Danny K Davis to assist with a legal matter with Plaintiffs handler Lidell Herard. During said call she requested his assistance with a “legal concern”. https://youtu.be/44VQeZx9KIY?si=kYC33IJ5bczIg2he

180.                       Two hours after said call Congressman Danny K Davis grandson “Javon Wilson” was shot over shoes given to him by Scottie Pippen, answering the door. https://www.nytimes.com/2016/11/20/us/danny-davis-grandson-shot-chicago.html

181.                       December 11, 2016, Plaintiff was forcibly taken into police custody and placed into Banner Mental Hospital for 9 days citing grandiose delusional behavior.

182.                       Police officer joked "Yea you are Pippen's baby mother, and I am the Pope”.

183.                       Plaintiff stalking became a point of jokes, rather than an issue of concern for her safety and well-being, as if to say that Plaintiff was not "worthy" of dating an NBA player.

184.                       February 19, 2017, Mayor Jonathan Rothschild was carjacked at gunpoint. https://www.azcentral.com/story/news/local/arizona/2017/02/18/tucson-mayor-jonathan-rothschild-carjacked/98105694/

185.                       March 31, 2017, Stacy Wilson’s son of Congressman Danny K Davis “suddenly dies”. Scottie Pippen allegedly poisoned him with Fentanyl laced cocaine to silence him about the connection to Plaintiff, his sons murder and other events associated with Plaintiff. https://abc7chicago.com/danny-davis-son-death-grandson-stacey-wilson/1828072/

186.                       April 2017 Shaquille O’Neal son Shareef O’Neal signed with Arizona State University.

187.                       Plaintiff left Arizona, then relocated to Las Vegas Nevada in April 2017, where again she attempted to establish herself in business, while networking for multiple clubs, hotels and venues Scottie Pippen followed Plaintiff with intent to force her into homelessness.

188.                       July 7, 2017, Plaintiff attended an event for singer Chris Brown at Drai’s. Scottie Pippen attended secretly. https://draisgroup.com/las-vegas/blog/james-harden-chris-paul-von-miller-others-spotted-drais-nightclub-chris-brown-concert-july-8/

189.                       July 8, 2017, while attending a pool party at Hard Rock Café for Kevin Hart, Scottie Pippen attempted to have Plaintiff removed from the premise, reasons unknown. https://www.youtube.com/watch?v=XdyP52aixsE

190.                       July 8, 2017, while attending Kevin Hart event, a member of the Chris Brown entourage approached her starting the Chris Brown chapter of her career. Scottie Pippen secretly attended said event. https://www.youtube.com/watch?v=PBwxJjV_4_0&feature=youtu.be

191.                       July 12, 2017, Plaintiff attended a pool party for Snoop Dogg, Scottie Pippen also secretly attended this event, and attempted to have Plaintiff removed, but was “very unsuccessful”.

192.                       September 27, 2017, Plaintiff accepted an invitation from the Mayor of Las Vegas, Carol Goodman for coffee. See (11) eleven videos in threat of story. https://www.youtube.com/watch?v=EemNX6yNyOk&list=PL6NUn4IJmwbQiSt9nmwRQyh9DcC-4x2jz&index=12

193.                       Plaintiff was seeking to secure a security contract and/or to network with the mayor in promoting events to Las Vegas.

194.                       Working in concert with Lisa McCoy, Defendants slandered the name, character and working reputation of Plaintiff, hindering her ability to secure employment, housing and damaging her professional image.

195.                       October 1, 2017, Vegas survived a mass shooting with 52 victims claimed.

196.                       October 11, 2017, Plaintiff was called to host a private event at Floyd Mayweather Girl Collection, located at 2580 S Highland Dr, Las Vegas, NV 89109.

197.                       Plaintiff discussed possibilities of managing his club, dancers and promotion of events for his various endeavors under (TMT) the Money Team. In addition, Plaintiff sought a partnership for an investor in a property for Sunday’s Bed and Breakfast.

198.                       Floyd Mayweather verbally agreed to invest in a property located at 2801 Pinto Lane, Las Vegas Nevada. https://sundaysbedandbreakfast.wordpress.com.

199.                       Plaintiff was scheduled to attend a concert with Janet Jackson planned at MGM on October 13, 2017, for her birthday, same hotel where shooter conducted events.

200.                       Plaintiff was attacked by an unknown woman, while attending an event at Drai’s on New Years Eve 2018.

201.                       Unknown woman came from behind her and grabbed her while attending an event with Chris Brown, an artist Plaintiff was soliciting an offer for management and/or promotions.

202.                       Plaintiff was targeted and harassed by Scottie Pippen and then associates “Curtis 50 cent Jackson”, who abused his celebrity status to stalk, harass, and target Plaintiff on behalf of Defendant Scottie Pippen, who is his gay lover.

203.                       Plaintiff was banned from Drai’s although she attempted to explain to Brian Affordi, General Manager of Drai’s Nightclub in Vegas.

204.                       Plaintiff lost another source of income.

205.                       Plaintiff lost her contract with “No Cover Parties”, a party referral service that pays per email collected for FREE ADMISSION to exclusive Vegas events.

206.                       August 22, 2017, after hosting an event for/with Floyd Mayweather and special guest Cassie Ventura, Plaintiff was subject to threats, trespass in her unit, including and not limited to an incident where “someone” entered her unit while not present and ejaculated on her toilet”. (see police report and photos). Curtis 50 cent Jackson. Email “I collected DNA.”

207.                       Plaintiff was forced to relocate on numerous occasions, as Defendants would use (abuse) his celebrity to collude and/or conspire with landlords, neighbors, and/or property managers to force creative evictions, in an effort to push Plaintiff into homelessness and/or human trafficking. See Valentine vs Jackson 2021L012270.

208.                       Plaintiff was again detained by police after Pangea property management filed an anonymous complaint citing mental concerns.

209.                       Plaintiff was detained by my mental professionals for seven days, at Spring Mountain mental facility for “strange behavior”, then released after “no conditions could be found”.

210.                       Plaintiff story was validated by Congressman Danny Davis who functioned as a liaison for Plaintiff during her trials.

211.                       Plaintiff left Las Vegas, then relocated to California in June 2018 where she has family, friends, and a stronger supporting cast to assist her with her issues.

212.                       Plaintiff sent email to Santa Monica city attorney Gary Rhodes asking guidance, reporting stalking by Pippen, sharing background. See email “I live in my car for 2 years”.

213.                       Plaintiff was forced to live in a rental car for 2 years unable to secure housing, and/or stable employment as a direct result of stalking, harassment by Defendants and associates who conspired to cause harm and/or worse.

214.                       March 26, 2019, Plaintiff applied for Backgrund Investigations with the Santa Monica Police Department, this position paid $65,000 to $85,000 per year based on experience.

215.                       March 27, 2019, Plaintiff applied for 911 Dispatch Inglewood Police, then met Mayor James Butts of Inglewood, and his staff relating to said position to discuss qualifications, and background checks.

216.                       May 7, 2019, Plaintiff sent a letter of appeal, outlining abuse, stalking activities and unwanted contact by Scottie Pippen and/or his associates. Email “Demand for Appeal”.

217.                       July 18, 2019, Plaintiff filed a small claim lawsuit against Scottie M Pippen case 2019SMSC02104, in judge Lisa Sepe Weinsfield court, where Plaintiff was portrayed as a “homeless junkie prostitute” by Defendants including Larsa Pippen.

218.                       Scottie Pippen had begun divorce proceedings, and it was rumored he was seeking Plaintiff to reunite.

219.                       Plaintiff has no intention, desire, will and./or demand to be in the presence of Defendants.

220.                       Defendant Scottie Pippen is in denial that there was never any real attraction.

221.                       Defendant Scottie Pippen is in denial of the mental and emotional abuse he forces Plaintiff to endure forcibly interfering with her life, impeding her progress, and hindering her ability to be successful, as we do not have any chemistry. Scottie Pippen is vindictive and vengeful, after these proceedings she wishes to have “no future contact” and/or “communication.

222.                       This case was filed in Los Angeles County Superior Courts, Santa Monica Courthouse located in Los Angeles, California.

223.                       July 18, 2019, Plaintiff filed a claim against Lisa Mc Coy, for conspiracy and damages.

224.                       July 18, 2019, Plaintiff filed a claim against Dr Thressia Washington, a medical professional who abused her access with Pippen to practice and/or abuse her medical degree to falsify records, make statements and or diagnosis Plaintiff as being a “threat”, and/or mentally ill for Scottie Pippen.

225.                       Plaintiff took immediate action(s) to file a legal paper trail of all events, to bring attention to her “residency” in the Los Angeles area(s).

226.                       August 27, 2019, Plaintiff sent an email to Adam Silver, Shaquille O’Neal, Kobe Bryant and others, offering a settlement to avoid taking any future legal action. One season, three teams, regular season only $100 million which is my REPARATIONS CLAIM, this will be taken to court as part of my negotiation. See email “Settlement”.

227.                       September 1, 2019, Kevin Hart crashes on mountain. https://www.tmz.com/2019/09/01/kevin-hart-car-accident-malibu-off-road-passengers-trapped/

228.                       September 19, 2019, Plaintiff sent an email to Kobe Bryant, Shaquille O’Neal and William Briggs (attorney for Earvin Johnson and Taylor Swift) asking “Why” her son was murdered. See email “Why” sent at 5:27 pm and all conversations connected thereafter.

229.                       September 24, 2019, Gary Payton’s mother died, after being served.

230.                       October 25, 2019, Shaquille O’Neal’s sister “suddenly dies”, after being served. https://www.usatoday.com/story/sports/nba/2019/10/25/shaquille-oneal-sister-ayesha-harrison-jex-dies-tnt-tribute/2453294001/

231.                       December 31, 2019, while attempting to attend Church at West LA in Los Angeles, Plaintiff was “attacked by fans” who attempted to “set her clothing on fire”, after filing claim.

232.                       January 2, 2020, Plaintiff sought assistance from West LA Church, where notably attendees included Stevie Wonder, Angela Bassett, Tommy Tiny Lister and Earvin Magic Johnson with his wife Cookie.

233.                       Tommy Tiny Lister “suddenly died” after sending Plaintiff a Cheesecake Factory order December 10, 2020.

234.                       Plaintiff did not attend this Church because of Earvin Johnson, as alleged, nor was that a factor when considering where to attend church.

235.                        Plaintiff often served Bishop Charles Blake, as a former sous chef at New Birth Missionary Baptist Church and sought refuge from churches where she had established relationships with the pastors.

236.                       Plaintiff also visited churches for Bishop Clarence McClendon, Pastor Kenneth Ulmer, Bishop Noel Jones and St, Monica in Santa Monica with Pastor Duffy.

237.                       Defendants slandered her name and reputation, citing she was stalking him, and others which in fact were “false claims”.

238.                       Plaintiff did not know Defendants resided in California.

239.                       Earvin Magic Johnson abused his celebrity status to file a response then a complaint with Santa Monica court, citing Plaintiff was harassing him, when she was in fact seeking answers to the reason for her son’s murder.

240.                       Abusing his authority Earvin Johnsons then “influenced” local authorities that Plaintiff was a threat, and had her arrested, detained unlawfully and targeted by fans who retaliated and/or attacked Plaintiff for these reasons, it was later learned that Scottie Pippen who is also “entangled” in a gay relationship with Earvin “Magic” Johnson used this scenario to target and attack Plaintiff without justification. See Valentine vs Johnson 2021L012271.

241.                       August 8, 2019, Defendants including Larsa Pippen and Lisa McCoy, staged a segment of the Wendy Williams Show, where Plaintiff was portrayed as the “side chick”, this 15-minute segment which was aired on National television, planned and promoted with help from Lisa McCoy, caused Plaintiff to be subject to “death threats”, stalking, harassment and more.

242.                       Defendants Scottie M Pippen and Larsa Pippen were in court dealing with divorce, it is alleged that Larsa wanted Plaintiff “out of the way” to avoid any due child support and/or claims that might manifest from Plaintiff and sought to discredit Plaintiff claims for damages. 

243.                       Larsa Pippen who is “close associates” with Dawn Hendricks and Lisa McCoy, conspired and colluded to “cause harm” to Plaintiff and/or worse as was the case in the murder of Plaintiff son Devonte Pippen in 2012.

244.                       August 27, 2019, Plaintiff sent email “Settlement Offer” to Adam Silver, Scottie Pippen and many others, hoping to come to an amicable resolution.  See email sent 3:46 pm

245.                       September 19, 2019  Plaintiff was riding the bus while seeking housing in Santa Monica when a “member” of the Pippen family entered the bus and sat across from Plaintiff, this was Defendant indirect manner of acknowledging they were following Plaintiff, which cause grave concern for her safety and security, she accepted an assignment as a caregiver living in a Motel to avoid being chased and stalked, hoping to establish a timeline of events.

246.                       February 20, 2020, Plaintiff was detained for six hours undocumented by Santa Monica Police.

247.                       March 10, 2020, Josie Harris, mother to Floyd Mayweather’s children was found in a car dead, from alleged “drug overdose”.

248.                       Defendant Scottie Pippen upon learning her location, moved into the building adjacent to the hotel where he “monitored” all activities in an obsessive and sick manner.

249.                       Abusing his celebrity, he influenced fans to attack, harass and cause confusion then reported Plaintiff as the aggressor.

250.                       February 20, 2021, subpoenas were served to the Adam Silver at the Executive Offices of the NBA, addressed to Adam Silver reporting concerns relating the behavior and conduct of Scottie Pippen, receipt was confirmed by certified mail.

251.                       The NBA, including Adam Silver having full knowledge of all activities failed to correct, interceded and/or address concerns, allowing defendants to continue stalking, harassing, and abusing powers granted by the NBA to continue said behavior, causing Plaintiff immense mental, and emotional distress.

252.                       Plaintiff summoned Scottie Pippen, Michael Jordan, Charles Oakley, Earvin Magic Johnson, Shaquille O’Neal, Gary Payton, via the NBA offices.

253.                       Plaintiff summoned Floyd Mayweather, Lisa McCoy and Dr. Theressia Washington to appear.

254.                       January 20, 2020, Kobe Bryant crashed.

255.                       Defendants recruited the hotel owner Maurice Farzam, and manager to assist, with staling and/or harassment.

256.                        Plaintiff was subject to constant physical, verbal and emotional abuse including and not limited to hotel staff breaking her nose three times, attack(s) by her then patient Geoffery Brown, and/or others. Valentine vs Holiday Motel

257.                       July 10, 2020, after the sudden death of Kobe Bryant Plaintiff returned to Chicago, in fear for her life and the safety of her children. She was the subject of death threats, attacks, and such, in addition her children and grandchildren were targeted with the same.

258.                       Plaintiff was a participant of the Housing Choice Program offered by HUD. At the time she received housing assistance under HUD’s housing choice voucher program which assists individuals with low income with housing payment assistance.

259.                       After speaking with legal advocated Plaintiff was directed to file a VAWA complaint with her local Congressman Danny K Davis which would offer protection dealing with her domestic violence issues.

260.                       May 12, 2021, Plaintiff sent an email to Shalisa Harvey “Suing Pippen for $100 million”, said email contained documents supporting stalking, harassment and/or threatening behavior by Defendant(s) from Chicago interstate from 2016 to 2020.

261.                       This information was confidential and private, not to be shared, used for personal and/or professional gains, then abused for termination of housing benefits when exposed. See Valentine vs Chicago Housing Authority, Shalisa Harvey 20221301069.

262.                       Chicago Housing Authority, working in collusion with Congressman Danny Davis, was granted a sale for CHA land to build Chicago Fire Soccer.

263.                       This deal was brokered with help from Earvin Magic Johnson and Scottie Pippen.

264.                       On May 21, 2021, Plaintiff filed her first VAWA complaint with Congressman Danny K Davis, who then forwarded said paperwork to the Chicago Housing Authority.

265.                       In an attempt to “force Plaintiff into homelessness” and/or “human trafficking”, Defendants have colluded and/or conspired with housing authorities, landlords, property managers and such to harass, violate rights then force eviction actions.

266.                       On November 8, 2021, Plaintiff filed an additional VAWA complaint with the Chicago Housing Authority explaining, Scottie Pippen has (in the past) abused his celebrity to gain access and/or information to Plaintiffs location and/or whereabouts. See Valentine vs Chicago Housing Authority 20221301069

267.                       In addition, he has abused this same authority to have Plaintiff terminated from housing, evicted from housing and/or terminated from the HUD programs, to which she has protection(s).

268.                       After filing VAWA complaint with CHA in April 2021 Plaintiff started receiving threats of eviction and was forced to relocate.

269.                       Since returning in 2020 Plaintiff has lived at four locations, forced to relocate on multiple occasion dues to threats, stalking and harassment issues that arise from landlords and/or neighbors who assist and/or collude with to help Pippen for, monetary gifts, trips and/or free tickets to Bulls events.

270.                       Defendants will extend a “short term residency” at each location, where Defendants can track, monitor and in all cases enter Plaintiff unit, violating her rights to privacy, peaceful enjoyment, causing fear and panic of being attacked or worse.

a.       Valentine vs Rachel Locke 202111111847, 7805 S Chappel, Chicago IL 60649.

b.       Valentine vs Lotus Realty 2021L011783 6900 S Southshore Dr, Chicago, IL 60649.

c.       Valentine vs TLC Management 202111125422, 6700 S Oglesby, Chicago, IL 60649.

d.       Valentine vs Waterton Residential LLC 20231113048, 575 W Madison, Chicago, IL 60661

271.                       Plaintiff has been the subject of multiple threats from male, and female fans who mistake Plaintiff as a fan.

272.                       Defendant(s) capitalize on the attention citing Plaintiff is stalking and harassing him, when in fact they are the perpetrators and/or aggressors in every situation. 

273.                       Plaintiff has lost housing, forced into homelessness, subject to unmentionable living conditions and/or circumstances because of this intolerable behavior.

274.                       Plaintiff has lost numerous career employment opportunities due to stalking activities and harassment initiated by Defendants.

275.                       Plaintiff has suffered irreversible mental, emotional, psychological and fiscal distress as a result of this unprovoked, unwanted and unwelcome contact.

276.                       The Plaintiff has expressed a clear and unequivocal desire to sever all forms of communication and interaction with any member of the Pippen family, their affiliates, and associates. This decision is not taken lightly but is deemed necessary to maintain the Plaintiff's peace of mind and personal well-being. The Plaintiff's request is comprehensive, encompassing all forms of contact, whether direct or indirect, physical or digital. This includes, but is not limited to, phone calls, emails, social media interactions, and in-person meetings. The Plaintiff's wish for complete disassociation from the Pippen family and their affiliates or associates is to be respected and adhered to without exception.

277.                       February 18, 2023, Plaintiff attempted to file a police report JG157295 for stalking communications. Working in collaboration with Mayor Lori Lightfoot, then Mayor of Chicago, said report was cancelled by Chicago Police and the report was voided.

278.                       November 18, 2023, Plaintiff again attempted to file a police report regarding stalking and/or harassing communications from a woman claiming to be “his new chick” (calls from fans), and was denied an opportunity to report activities citing, “Plaintiff would need a lawyer to file a complaint, which was false and misleading.

279.                       Plaintiff has been forced to change her phone number on numerous occasions due to stalking, harassing, unsolicited communications from friends or fans of Pippen, who insist upon abusing access to harass her about being his “side chick”, although it is publicly know that Scottie Pippen is “openly bisexual” and/or “gay”, in fact his “disapproval of females” is documented.

280.                       February 26, 2024, while working in collusion with Waterton Residential LLC., Plaintiff was forced out of her home located at Presidential Towers 575 W Madison and evicted without any prior notice.

281.                       Defendant(s) temporality-maintained residency as a direct result of Plaintiff being a tenant.

282.                       Abusing his celebrity Scottie Pippen worked in concert with onsite management and staff who were hired prior to Plaintiff accepting residency and is affiliated with Howard Gottlied the General Manager of Presidential Towers.

283.                       Since being evicted on February 26, 2024, Plaintiff has been forced to relocate out of state.

284.                       March 6, 2024, Plaintiff relocated from Illinois to Arkansas after receiving an offer for land from a Pippen associate named Andrew Dorsey, who under false pretenses lured Plaintiff to Arkansas with an empty promise of land. Upon arrival he asked Plaintiff to leave his home and filed trespass charges with Conway, Arkansas Sheriff. Plaintiff was being offered in sex trafficking.

285.                       April 1, 2024, Council for the Chicago Bulls is assigned, attorney William Cook is assigned, and Plaintiff begins to submit records and history of stalking to Chicago Bulls legal team.

286.                       Plaintiff was forced into Conway Emergency Homeless shelter where she was abandoned, until the local agency CPAC offered transportation (Greyhound bus ticket) to Mississippi. This was reported via email to William Cook, legal for the Chicago Bulls, who have full knowledge of all stalking activities since being assigned.

287.                       April 14, 2024, Scottie Pippen was seen driving a grey Range Rover past the Conway Emergency Homeless Shelter, this was reported to staff of the shelter, the city government, and attorney William Cook (legal for the Chicago Bulls).  Email sent “Beautiful Homeless Shelter in Conway”. Would it be safe to assume that Scottie is in Conway, driving in a grey Range Rover that past the shelter around 2:30 pm today???

288.                       From April 15, 2024, to April 24, 2024, Plaintiff advises attorney William Cook of human trafficking, obstruction of justice, evidence and witness tampering, and various other issues relating to activities by Scottie Pippen.

289.                       April 16, 2024, Mayor Bart Castleberry of the City of Conway was alerted to trafficking activities. Email sent Press Release: Live from Conway, Arkansas Emergency Shelter. This latest chapter is the funniest of them all. you guys ready... we go to court tomorrow; I must appear remote due to threats... This is exactly why I am suing!!!

a.       Obstruction of Justice, tampering with a witness, threats and intimidation to cease me from filing this action is illegal. Now he has added a new crew to his madness...Threats to a witness in a court case are considered witness tampering, which is a serious crime that occurs when someone tries to influence a witness to make a false statement. Witness tampering can take many forms, including Physical force, threatened physical force, Intimidation, Coercion, and Altering a witness's testimony.  (720 ILCS 5/32-4) (from Ch. 38, par. 32-4 nSec. 32-4. Communicating with jurors and witnesses.(a) A person who, with intent to influence any person whom he believes has been summoned as a juror, regarding any matter which is or may be brought before such juror, communicates, directly or indirectly, with such juror otherwise than as authorized by law commits a Class 4 felony.(b) A person who, with intent to deter any party or witness from testifying freely, fully and truthfully to any matter pending in any court, or before a Grand Jury, Administrative agency or any other State or local governmental unit, forcibly detains such party or witness, or communicates, directly or indirectly, to such party or witness any knowingly false information or a threat of injury or damage to the property or person of any individual or offers or delivers or threatens to withhold money or another thing of value to any individual commits a Class 3 felony.(c) A person who violates the Juror Protection Act commits a Class 4 felony.

290.                       April 18, 2024, Plaintiff contacts the Mayor of the City of Biloxi, announcing her soon arrival into the area. Email sent I am on my way to Biloxi, before I arrive here is the background... I will need a temporary shelter to reside in, until I gain my footing... I have applied for multiple career opportunities and look forward to greeting and hosting all of the tourists who will follow me... when I leave Conway, AR. I will begin promoting Biloxi, MS.

291.                       Plaintiff arrived in Biloxi, Mississippi on April 21, 2024.

292.                       Plaintiff was forced to sleep in a portable toilet on her first night in Biloxi.

293.                       Plaintiff checked into the Inn Town Suite hotel in Gulfport, Mississippi on April 22, 2024.

294.                       Plaintiff applied for three jobs in one day 1. Waffle House, 2. Clark Gas Station, and 3. Appplebee’s in Gulfport, Mississippi all located within one mile of Highway 49.

295.                       April 23, 2024 Plaintiff sent email to William Cook “He once texted Deja, I will shoot you with the same gun I killed your brother with” which reads All DCFS records will reflect how Cedric, his wife and family fabricated lies, to avoid child support... FYI, her DNA was switched too, I did explain what happened at the NBA ASW in Phoenix 1995... Scottie and family are included in this box, emails are hidden for your protection. They attempted to establish parentage, illegally... he cannot claim Deja.

296.                       April 24, 2024, Plaintiff solicited financial support from family member Yma Valentine, who took information provided by Plaintiff, shared it with Congressman Davis, who forwarded information to Scottie Pippen (and/or) associates. With help from Plaintiffs family, Pippen was able to track, stalk and harass Plaintiff with family assistance namely Diane Valentine, Plaintiffs mother, and Benji Valentine, Plaintiff half-brother and a host of Jamison cousins.

297.                       April 26, 2024 “A unknown member” of the Pippen family was seen by Plaintiff walking to work, this was sent to the Congressman. Email sent “Which Pippen is this”? Then suddenly Waffle House has NO HOURS then sends me home.

298.                       April 26, 2024, Plaintiff was released from employment, citing “no schedules available”, and was removed from the schedule at Waffle House.

299.                       April 26, 2024, Plaintiff reports a shooting at hotel where she is temporarily residing at the Inn Town Suites Hotel located at 9145 Highway 49, Gulfport, Mississippi 39503, via email to local leaders. Email sent to William Cook, attorney for the Bulls.

300.           Defendants and/or family members and/or affiliates have visited Plaintiffs place of employment and/or hotel/motels and/or housing facilities. Email sent to William Cook, attorney for the Bulls.

301.           Plaintiff maintained stable employment with Applebee’s from May 2, 2024, until June 16, 2024, after taking a photograph of “a Pippen family member” visiting her employment.

302.           The same day “a Pippen family member visited” Dallas won.

303.           There was an “threat of harm and/or danger” from Pippen.

304.           June 19, 2024, Plaintiff was hired by Shaggy’s on the Beach, in a host capacity, in Biloxi, she interviewed with Captain Matt.

305.           Returning home on the bus from said interview, she was stopped by a white SUV with plates, driver information unknown with Harrison County custom plates that read “PIP PIP”. Suggested custom plates from a Pippen family member.

306.           June 20, 2024, Plaintiff was released from employment from Applebee’s, citing unethical behavior.

307.           June 24, 2024, all of Plaintiffs personal property and storage was sold, after falling behind on payments, due to stalking activities.

308.           The NBA advertised six Applebee’s commercials during 2024 NBA Play Offs.

309.           July 1, 2024, after 3 days of training Plaintiff was released from employment at Shaggy’s for unknown reasons.

310.           Plaintiff has been forced into a homeless shelter, with no source of income, due to stalking and harassing activities.

311.           Defendants circulated rumors (again) that plaintiff was mentally unstable stalking him.

312.           July 7, 2024, Plaintiff attempted to file a police report with Gulfport Police.

313.           Plaintiff was refused her right to file a report for stalking.

314.           When questioning Officer C Parrish, he responded Scottie Pippen would not date a woman like you.

315.           As of this filing on July 9, 2025, Scottie Pippen and/or his “gang of family members” have activity stalked Plaintiff from Illinois now to Mississippi, where she intended to purchase land and retire. The NBA is fully aware of all activities as reported as they occur to attorney William Cook is aware of all activities.

ARGUMENT

 

I.                    Despite the plaintiff and defendant never having a serious relationship, the plaintiff suffered significant emotional distress due to Scottie Pippen's actions.

a.       Pippen, known for his infidelity, betrayed the plaintiff's trust by engaging in affairs with individuals within her close circle, leading to severed relationships.

b.       His abusive behavior, both mentally and physically, further strained their relationship.

c.       Pippen's struggle with his sexual identity added to the complexity of their relationship.

d.       Pippen has “serious competitive issues”, and “does not like and/or respect “women” as a gender.

II.                 Plaintiff, who refrained from (cocaine) drug use and certain sexual (anal) activities, found it challenging to maintain a healthy relationship with Pippen, and severed ties due to extreme abusive behaviors and/or patterns.

III.              Plaintiff and Defendant were never in a meaningful relationship.

a.       a. Scottie Pippen was a cheater, cheating on Plaintiff with family and friends in her inner circle, causing her to sever many relationships due to betrayal of loyalty.

b.       b. Pippen was mentally, physically and emotionally abusive in nature.

c.       c. Pippen struggled with his sexual identity, he did not know if he was gay, straight or bisexual.

d.       d. Plaintiff did not partake in the "drug use" and or "sexual activities" that could sustain a healthy relationship.

IV.              Pippen has serious issues with "women" in general as a gender, issues with his own sexuality, and/or identity.

a.       Defendant Scottie Pippen used and abused access to Plaintiff for publicity, attentions and to seek and/or engage in revenge and/or retaliation against Michael Jordan.

b.       Scottie has always wanted to be "Michael Jordan", he was always whining and complaining about how the Bulls preferred him, that he was the star of the team.

c.        Plaintiff could not entertain such negative company, as he was always making racist, sexist and/or "questionable statements" relating to the Bulls, his teammates and/or his career.

d.       Pippen was known throughout Chicago as "no tipping Pippen", always seeking someone to "pay the bill", or seeking special treatment, this became a problem as his reputation became known city wide.

V.                  Defendant Scottie Pippen embedded his family into the fabric of her family.

a.        a. targeting Plaintiff and her family, he has "matched" members of his family, friends, and/or associates to meet and mate with members of her family. Including and not limited to her siblings, extended family and friends.

VI.              Scottie Pippen willfully and intentionally plants people from his family and/or inner circle for the sole purpose of tracking the activities and movements of Plaintiff.

a.       He has provided financial support, bought houses, cars, and started business for others, in retaliation for Plaintiff rejecting all advances.

b.      Scottie Pippen refers to Plaintiff family as his "slaves", seeking those who will acknowledge his celebrity as a Chicago Bulls that will "serve him".

VII.           Scottie Pippen history of “instability”, and “mental insecurities” in nature were the foundation for his hatred toward Plaintiff, knowing her personal affiliation with personal affiliation with Michael Jordan.

a.       Scottie used Plaintiff to get Michael Jordan's attention, as if he used her to provoke Michael Jordan to anger.

b.      Plaintiff has always "questioned" the theories surrounding the sudden death of Michael Jordan's father, and directly connected Scottie Pippen to said events, although it has not been proven.

c.       Scottie Pippen “obsession” with Michael Jordan, was of serious concern to many on his team, and on other teams he played for.

d.      Plaintiff often wondered about the details of said bond.

VIII.         Devonte Pippen was a product of rape, not a love child and/or a child produced from a long-term relationship.                     

a.       a. Scottie Pippen has worked relentlessly to "make Plaintiff and her children disappear.

b.      Targeting her children, family and those associated, abusing his celebrity granted by the NBA.

                                                              i.       The mental and emotional devastation of raising a child that was a product of a violent rape was too overbearing for Plaintiff to endure.

                                                            ii.       The emotional abuse Plaintiff and her children have endured has long term implications, as her family and inner circle fear harm, and/or danger constantly forcing Plaintiff into isolation.

                                                          iii.      Failing to publicly acknowledge his son evading financial responsibility.

                                                           iv.      Scottie Pippen lied to fans that Lisa McCoy was the mother, not the Plaintiff, basically switching and/or stealing her identity for a prostitute.

IX.              Defendant Scottie Pippen has abused his access to stalk, harass, intimidate, bully in hopes of "forcing Plaintiff into an unwanted relationship".

a.       Hoping to force Plaintiff into homelessness directing her into human trafficking, attempting to control Plaintiff her children and family.

X.                 Adam Silver and the NBA were made fully aware of all details on February 20, 2020.

a.       Adam Silver was personally served with summons to appear.

b.       Michael Jordan was sent a direct email to his 162 Bear St. Jupiter Florida address.

c.       Scottie Pippen has received direct and/or indirect of each legal proceeding.

d.       Despite any filing, Defendants continue to persist stalking, harassing and causing fear, regardless to numerous requests to “cease and/or desist” any/all contact with Defendant(s) in part and/or whole.

e.       Plaintiff wishes to have no contact with anyone NBA affiliates including and not limited to Michael Jordan.

Plaintiff has presented a case, citing that the defendant has engaged in a pattern of behavior that is both alarming and unlawful.

Plaintiff alleges that the defendant has been involved in stalking, as defined by 720 ILCS 5/12-7.4, a statute that clearly outlines the parameters of such behavior. This includes following the plaintiff, appearing at her home or place of work without consent, and making unwanted contact through various means.

Plaintiff further contends that the defendant has not only stalked her but has also engaged in harassment, as outlined in 720 ILCS 5/26.5-3. This includes a series of actions intended to alarm, annoy, or torment the plaintiff, causing her to fear for her safety.

Plaintiff's asserts that the defendant has demonstrated a clear intent to cause her harm, a serious violation of 720 ILCS 5/7-8. This intent, she claims, is evident in the defendant's actions and threats, which have escalated in severity over time.

Plaintiff also alleges that the defendant has willfully and intentionally inflicted mental and emotional distress upon her, a violation of 740 ILCS 21/10. This distress, she claims, has been caused by the defendant's relentless and malicious actions, which have left her in a state of constant fear and anxiety.
Perhaps most disturbingly, the plaintiff claims to have been the recipient of death threats from the defendant, a serious violation of 720 ILCS 5/8-1. These threats, she alleges, have been explicit and unequivocal, leaving her in no doubt as to the defendant's intentions.

Plaintiff's allegations, when proven, paint a picture of a defendant who has engaged in a pattern of behavior that is not only deeply troubling but also clearly in violation of several statutes. The court must now consider the evidence presented and determine whether the defendant's actions constitute the violations alleged by the plaintiff. The tone of these proceedings must remain professional, as we navigate the serious and distressing allegations brought forth by the plaintiff.

 

Plaintiff alleges that Scottie Pippen, a renowned figure in the sports world, has utilized his considerable resources to engage in a campaign of stalking, harassment, and intimidation. This has reportedly resulted in significant mental, emotional, and financial distress for the plaintiff and their family. The scope of this alleged harassment extends beyond the plaintiff, encompassing a wider circle of individuals. This includes the plaintiff's children, family members, mutual friends, and other individuals who are either directly or indirectly connected to the plaintiff. Notable figures such as Earvin "Magic" Johnson, Lisa McCoy, Congressman Danny K Davis, Dr. Theressia Washington, and Dr. Patricia Favia have been implicated in this alleged harassment.

Plaintiff asserts that these individuals have been targeted as part of Pippen's alleged efforts to conceal and cover up the birth, life, and/or existence of a child.

Plaintiff's allegations, when proven, would constitute a serious breach of personal boundaries and a gross misuse of power and influence. It is essential that these allegations are thoroughly investigated to ensure that justice is served and that the rights and well-being of all involved parties are protected. The tone of these allegations is grave, and the implications are far-reaching, underscoring the need for a comprehensive and impartial examination of the facts.

For the reasons outline 1-315, Plaintiff seeks damages and claims that spans over three decades, alleging a series of legal violations that have caused significant harm and distress.

For the reasons outline 1-315, Plaintiff seeks damages and claims that the defendant has engaged in a pattern of behavior that includes stalking, as defined by 720 ILCS 5/12-7.4, and harassment, as outlined in 720 ILCS 5/26.5-3.

For the reasons outline 1-315, Plaintiff seeks damages and claims that the defendant has demonstrated a clear intent to cause harm, a violation of 720 ILCS 5/7-8.

For the reasons outline 1-315, Plaintiff seeks damages and claims the defendant has willfully and intentionally inflicted mental and emotional distress, a violation of 740 ILCS 21/10.

For the reasons outline 1-315, Plaintiff seeks damages and claims to have been the recipient of death threats, a serious violation of 720 ILCS 5/8-1.

For the reasons outline 1-315, Plaintiff seeks damages and claims (7) counts of interstate stalking, in violation of 18 U.S.C. § 2261A(2)(A), and seven (7) counts of interstate extortionate threat, in violation of 18 U.S.C. § 875(d).

1.       Count 1 Interstate Stalking to Atlanta 1998-2003

2.       Count 2 Interstate Stalking to Arizona 2016

3.       Count 3 Interstate Stalking to Nevada 2017

4.       Count 4 Interstate Stalking to California 2018

5.       Count 5 Interstate Stalking in Illinois 2020-2024

6.       Count 6 Interstate Stalking to Arkansas 2024

7.       Count 7 Interstate Stalking to Mississippi 2024

For the reasons outline 1-315, Plaintiff seeks damages and claims the defendant of defamation of character and slander, as defined by 740 ILCS 145.

Beyond these violations, the plaintiff seeks compensation for child support arrears and palimony, both associated with a relationship that has lasted since 1987.

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.