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 |
PLAINTIFF’S
OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
1. Plaintiff, Chyvette A.
Valentine, respectfully submits this opposition to Defendant's Motion to
Dismiss.
2. Plaintiff alleges serious
offenses and seeks damages in the amount of $300 million for the following
claims:
3. Stalking (720 ILCS 5/12-7.4):
Plaintiff alleges that the Defendant(s) engaged in stalking activities in
violation of Illinois law. Additionally, Plaintiff claims violations under:
4. Interstate Stalking (18 U.S.C. §
2261A): Plaintiff asserts that the Defendant(s) engaged in interstate stalking,
violating federal laws amended in 1996, 2000, 2006, and 2013.
5. Harassment (720 ILCS 5/26.5-2)
and Intimidation (720 ILCS 5/12-6): Plaintiff asserts that the Defendant(s)
engaged in persistent harassment and intimidation, causing significant
emotional and psychological distress.
6. Solicitation and Solicitation of
Murder (720 ILCS 5/8-1): Plaintiff claims that the Defendant(s) solicited the
commission of crimes, including but not limited to solicitation of murder,
through commands, encouragement, or requests.
7. Defamation of Character and
Slander (740 ILCS 145/ Slander and Libel Act): Plaintiff contends that the
Defendant(s) engaged in defamation and slander, damaging Plaintiff's reputation
and character.
8. Child Support (1993-2012):
Plaintiff demands child support payments for Devonte Pippen from the years 1993
to 2012, which have allegedly been willfully neglected by Defendant Scottie
Pippen.
9. Willful Infliction of Mental,
Emotional, Physical, and Psychological Abuse: Plaintiff asserts that the
Defendant(s) inflicted severe emotional and psychological harm.
JURISDICTION
10. The Court finds that venue is
proper in Cook County, Illinois, under Sections 2-101 and 2-102 of the Illinois
Code of Civil Procedure.
I.
INTRODUCTION
11. A motion to dismiss requires
that the Court assume all allegations in the complaint are true and view them
in the light most favorable to the Plaintiff.
12. Defendants bear the burden of
demonstrating that the Plaintiff has failed to state a claim upon which relief
can be granted.
13. Plaintiff claims that Scottie
Pippen, along with his family, friends, associates, and/or vendors, inflicted
intentional mental, emotional, physical, and psychological abuse on her.
Factual Background
14. Plaintiff, Chyvette A.
Valentine, has been a victim of stalking and harassment for over 30 years.
15. Despite her numerous attempts
to resolve this matter amicably, the NBA and the Chicago Bulls organization
have allowed this conduct to persist without taking corrective measures.
A. See copy of service to NBA
executive offices served August 05, 2020.
B. See copy of service to Adam Silver served February 20, 2020.
C. See copy of service to Michael Jordan served February 21, 2020.
D. See Congressman Danny K. Davis VAWA report.
E. See CHA VAWA report.
F. See Canceled Police Report.
16. Plaintiff specifically alleges
that the Chicago Bulls have a troubling history of covering up misconduct by
their players, including Scottie Pippen and his brother, Carl Pippen.
A. See Valentine vs. Congressman
Danny Davis et. al., 2024cv00676.
B. See Valentine vs. Earvin Magic Johnson et. al.
C. See Valentine vs. Curtis "50 Cent" Jackson et al.
D. See Valentine vs. Lisa McCoy et. al.
E. See Valentine vs. Dr. Theressia Washington et. al.
All cases are directly related to
stalking activities reported, associated with/for and/or about Scottie Pippen.
17. The complaint details that in
1993, while Scottie Pippen was employed by the Chicago Bulls, he and his
brother were involved in a sexual assault incident that the organization failed
to address.
A. See Arkansas Child Support
Records.
18. Additionally, the Plaintiff
asserts a pattern of harassment and stalking by Scottie Pippen, which has been
exacerbated by the NBA’s and Chicago Bulls’ failure to hold him accountable.
A. See email to Mayor Jonathan
Rothschild of Tucson, Arizona.
B. See email to Mayor Carol Goodman of Las Vegas, Nevada.
C. See email to Gary Rhodes of Santa Monica, California.
19. This systemic neglect by the
Defendants has facilitated ongoing abuse, causing significant harm to the
Plaintiff.
II.
LEGAL ARGUMENTS AGAINST DISMISSAL
A. The Complaint States Valid
Claims
20. Defendants argue that the
complaint fails to state a claim. However, the Plaintiff’s allegations,
including the cover-up of misconduct, failure to hold players accountable, and
subsequent harassment, are substantial and meet the legal standards for several
claims, including negligence, intentional infliction of emotional distress, and
breach of duty.
21. The complaint provides specific
instances of alleged abuse and systemic failures that are sufficient to state a
claim upon which relief can be granted.
22. This includes, but is not
limited to, the Chicago Bulls authorizing and granting a bedroom fantasy suite
to be erected with the anticipation of Scottie Pippen luring the Plaintiff to
said suite with intentions of sex trafficking activities.
23. The NBA, namely the Chicago
Bulls, have been aware of the “unpredictable” relations between Plaintiff and
Defendant (Scottie Pippen), yet chose to “turn a blind eye” while their
employee (player) continues his unpredictable behavior they enable.
B. The Plaintiff Has Standing
and Jurisdiction is Proper.
24. Defendants’ assertion that the
Plaintiff lacks standing or that the court lacks jurisdiction is without merit.
25. Plaintiff has standing based on
the direct harm suffered due to the alleged misconduct and the Defendants'
actions.
26. Additionally, the court has
jurisdiction over these claims as they involve violations of state and federal
laws, and the conduct described has crossed state lines, thus engaging federal
statutes such as 18 U.S.C. § 2261A (Interstate Stalking).
27. As stated previously, Plaintiff
has attempted multiple times to hold Defendants accountable for their actions.
28. This is Plaintiff’s first
successful filing.
C. The Complaint Is Adequate and
Defendants’ Conduct Is Relevant
29. Plaintiff’s claims are directly
tied to the Defendants' conduct. The allegations against Scottie Pippen and his
associates are connected to the actions of the Chicago Bulls and the NBA, who
are accused of providing protection and support to Pippen, thereby facilitating
ongoing harm to the Plaintiff.
30. This direct/indirect
involvement and the systemic nature of the alleged cover-up render the claims
valid and appropriate for judicial review.
D. Request for Leave to Amend
31. Should the Court find any
deficiencies in the complaint, the Plaintiff respectfully requests leave to
amend.
32. Plaintiff is prepared to
correct any errors and provide additional details and supporting documentation
to substantiate the claims.
33. Such amendments are crucial to
fully address all relevant allegations and ensure that the claims are properly
articulated.
E. Request for Special Service
34. Considering the history of
stalking and harassment by the Defendants, the Plaintiff requests permission
for special service of process to all Defendants via email, public posting,
certified mail, and/or through third-party service to Jason Giller, Esq.,
representing Scottie Pippen.
35. This measure is necessary to
ensure that all parties are properly notified and to safeguard the Plaintiff’s
right to a fair legal process.
III.
PLAINTIFF’S OBJECTION TO THE INCLUSION OF CERTAIN DOCUMENTS
A. Questioning the Inclusion of
Standing Censure
36. Plaintiff, Chyvette A.
Valentine, respectfully questions the inclusion of standing censure related to
the order put in place by Honorable Rebecca Pallmeyer. This reprimand stemmed
from an email sent by the Plaintiff concerning the sudden death of former Judge
James Zagel, a close friend and lover of the Plaintiff.
37. Plaintiff had suggested that
Scottie Pippen may have had a connection to Judge Zagel's untimely death, which
led to the reprimand.
38. Plaintiff asserts that the
inclusion of this document is not only irrelevant to the present case but also
raises serious concerns regarding the Defendant(s)' potential involvement in
the death of Judge Zagel.
39. Plaintiff further questions the
timing and circumstances surrounding the death of David Reinsdorf on March 3,
2014, which occurred while the Plaintiff was actively attempting to establish a
legal claim.
40. The suspicious nature of these
deaths, coupled with the Plaintiff's ongoing concerns about harassment and
stalking, necessitates further scrutiny and investigation.
B. Implications of the Inclusion
41. Plaintiff contends that the
insertion of these documents, particularly in a motion to dismiss, appears to
be an attempt to discredit the Plaintiff and distract from the substantive
claims presented in this case.
42. The inclusion of irrelevant
documents, particularly those with potentially incriminating implications
against the Defendant(s), should not prejudice the court against the
Plaintiff’s valid claims.
43. Plaintiff emphasizes that these
claims are not baseless but are supported by a long history of alleged
misconduct, harassment, and failure by the Defendant(s) to address or mitigate
the harm caused to the Plaintiff.
IV. CONCLUSION
44. For the reasons stated above,
Plaintiff respectfully requests that the Court deny Defendant’s Motion to
Dismiss.
45. Plaintiff also requests any
additional relief the Court deems just and proper.