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Valentine vs Pippen #SERVICE by #PUBLICATION

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

 

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.

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.

The 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.

The 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 his 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.

III.              Introduction to Scottie Pippen:

The 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 1990, 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 a 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

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

The relationship ended following an assault that transpired on February 18, 1993.

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.

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

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

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

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.

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.

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

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

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.

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.

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”.

While enroute to Plaintiffs home to visit Scottie Pippen was stopped by police possessing a firearm in his vehicle, riding along with Carl Pippen his brother at the time, the charge was dropped citing the firearm belonged to his brother.

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.

Upon returning to Chicago, Plaintiff children were “illegally seized” by DCFS in an attempt to cover up and/or conceal Devonte Pippen’s true identity, Plaintiffs sexual assault, and events associated. This was done to “avoid paying child support”, and “extending Devonte any due benefits he may have been entitled to because of said parentage”.

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

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.

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.

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

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.

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.

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

February 8, 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.

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

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

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

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.

Plaintiff was taken into police custody and placed into Banner Mental Hospital for 9 days citing grandiose delusional behavior. In this instance a police officer joked "Yea you are Pippen's baby mother, and I am the Pope”. Her 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 a NBA player.

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.

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

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

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. 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).

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.

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

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.

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

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.

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.

On 07/18/2019 Plaintiff filed a small claim lawsuit against Scottie M Pippen case 2019SMSC02104. 

This case was filed in Los Angeles County Superior Courts, Santa Monica Courthouse located in Los Angeles, California. At the same time claims were also filed against Lisa Mc Coy and 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” for Scottie Pippen.

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.

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

August 8, 2019, Defendants including Larsa Pippen 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.

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. 

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.

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.

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.

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

February 20, 2021, subpoenas were served to 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.

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.

Plaintiff summoned Scottie Pippen, Michael Jordan, Charles Oakley, Earvin Magic Johnson, Shaquille O’Neal, Gary Payton, Floyd Mayweather, Lisa McCoy and Dr. Theressia Washington to appear.

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

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.

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.

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.

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.

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.

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

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).

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

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.

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.

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

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

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

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

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

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.  

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

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

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

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.

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.

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.

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.

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.

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

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.

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

March 6, 2024 Plaintiff relocated from Illinois to Arkansas with intention of

ARGUMENT

Plaintiff has presents 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. The 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.

The plaintiff's allegations do not end there. She 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. The 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. The plaintiff's allegations, if 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.

1. Harassment and Distress

• Allegations: Scottie Pippen has allegedly used his resources to stalk, harass, and intimidate the plaintiff and their family, resulting in significant mental, emotional, and financial distress.

2. Involvement of Others

• Scope of Harassment: This harassment extends beyond the plaintiff to include her children, family members, mutual friends, and other individuals, including Earvin "Magic" Johnson.

3. Invasion of Privacy

• Misappropriation: Unauthorized use of the plaintiff's personal story in a film.
• False Light: The film may portray the plaintiff in a misleading or damaging way.
• Defamation: The film contains false statements that harm the plaintiff's reputation.
• Intentional Infliction of Emotional Distress (IIED): Due to the alleged harassment and intimidation caused by Scottie Pippen and others.

4. Stalking and Harassment

• Legal Action: Legal action related to stalking, harassment, and related criminal behavior that has continued from 1987 to the present.
• Legal Reference: According to Illinois law (720 ILCS 5/12-7.3) (from Ch. 38, par. 12-7.3), stalking is defined as knowingly engaging in a course of conduct directed at a specific person that causes fear for safety or emotional distress.
• Specifics of the Law:
• A person commits stalking if, on at least two separate occasions, they follow another person or place the person under surveillance and transmit a threat of harm, sexual assault, confinement, or restraint.
• A person also commits stalking if they have previously been convicted of stalking and, on one occasion, follow or place the same person under surveillance while transmitting a threat of harm.
• Stalking also includes making threats that are part of a course of conduct, being aware of the threatening nature of the speech.

5. Interstate Stalking and Extortionate Threats

• Counts and Violations:
• Plaintiff seeks damages for five counts of interstate stalking, in violation of 18 U.S.C. § 2261A(2)(A), and five counts of interstate extortionate threat, in violation of 18 U.S.C. § 875(d).
• Count 1: Interstate Stalking to Arizona.
• Count 2: Interstate Stalking to Nevada.
• Count 3: Interstate Stalking to California.
• Count 4: Interstate Stalking to Arkansas.
• Count 5: Interstate Stalking to Mississippi.

Summary

The defendants, including Scottie Pippen and others, are alleged to have engaged in continuous and pervasive stalking, harassment, and intimidation, causing significant distress to the plaintiff. The plaintiff seeks legal redress and damages for these actions under both state and federal laws.

Impact on Plaintiff

Throughout this period, 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.

Relief Sought

The 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
• Child support arrears for the period from 1993-2012
• Any other relief deemed necessary by the court to ensure the plaintiff's protection and to hold the defendant(s) accountable for their actions.

I forgot there's a new judge