Motion for Default Judgement Editing All Day!!!This will change all day... (adding details)

IN THE HE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION

CHYVETTE A. VALENTINE,

Plaintiff,

v.

CHICAGO BULLS, SCOTTIE M. PIPPEN, LARSA PIPPEN, CARL PIPPEN, JASON GILLER, et al.,

Defendants.

Case No.: 2024L002166

Courtroom: 2209

Judge: Hon. Maire Aileen Dempsey

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PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT AND PROVE-UP HEARING

NOW COMES Plaintiff, CHYVETTE A. VALENTINE, pro se, and pursuant to 735 ILCS 5/2-1301(d), Illinois Supreme Court Rule 219(c), the Federal Rules of Civil Procedure 55, and the Violence Against Women Act (VAWA), respectfully moves this Honorable Court to enter a Default Judgment against Defendants Scottie M. Pippen, Larsa Pippen, Carl Pippen, Jason Giller, and all named Defendants for their failure to appear, plead, or otherwise defend against this action.

Plaintiff further requests a Prove-Up Hearing to establish damages and a ruling with prejudice, as Defendants have:

1. Failed to respond despite proper service.

2. Refused multiple settlement offers, demonstrating bad faith.

3. Engaged in willful and malicious conduct, necessitating a strong judicial ruling.

Accordingly, Plaintiff seeks:

• Entry of Default Judgment against all Defendants;

• $300,000,000 in damages, including compensatory, punitive, and statutory damages;

• Permanent injunctive relief preventing further harassment, defamation, and financial interference;

• Referral for criminal prosecution under Illinois and federal law, including VAWA violations;

• A ruling with prejudice, barring Defendants from attempting to relitigate claims.

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I. INTRODUCTION

1. Plaintiff initiated this action on February 26, 2024, alleging that Defendants engaged in a targeted and sustained campaign of harassment, stalking, defamation, and conspiracy, violating state and federal law.

2. Defendants were properly served but have failed to answer or appear, as detailed below:

   • Scottie Pippen was served by the Los Angeles County Sheriff’s Department on December 18, 2024.

   • Jason Giller, as a registered agent, responded via email on October 13, 2024, acknowledging receipt of the Complaint.

   • Plaintiff has maintained ongoing email contact with multiple Pippen and Larsa Youkhana family members, demonstrating Defendants' actual knowledge of this lawsuit.

3. Defendants have ignored numerous settlement offers, demonstrating bad faith and causing unnecessary litigation costs.

4. Illinois law, federal law, and established case precedent support the entry of default judgment.

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II. LEGAL STANDARD FOR DEFAULT JUDGMENT

A. Illinois and Federal Rules on Default Judgment

5. Under 735 ILCS 5/2-1301(d), default judgment is proper when:

   • A defendant has been properly served; and

   • A defendant fails to respond within the statutory time period.

6. Illinois Supreme Court Rule 219(c) allows courts to enter default judgment when a party willfully refuses to comply with procedural requirements.

7. Federal Rule of Civil Procedure 55(a) allows a court to enter default judgment when a defendant "fails to plead or otherwise defend."

8. Case Precedents Supporting Default Judgment:

   • People ex rel. Department of Public Aid v. LeVine, 99 Ill. 2d 146 (1983) – The Illinois Supreme Court held that failure to respond to a complaint results in admission of all allegations.

   • Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986) – Default judgment is appropriate where a defendant deliberately disregards legal proceedings.

   • Celotex Corp. v. Catrett, 477 U.S. 317 (1986) – The U.S. Supreme Court held that failure to dispute material allegations allows for judgment as a matter of law.

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III. FAILURE TO ENGAGE IN GOOD-FAITH SETTLEMENT DISCUSSIONS

9. Plaintiff made multiple attempts to settle this dispute amicably, including formal written settlement offers.

10. Defendants either ignored these offers or refused to engage in meaningful negotiations, demonstrating bad faith and warranting heightened damages.

11. Under Illinois law, refusal to engage in settlement can justify increased punitive damages (see Ciraulo v. Ciraulo, 398 Ill. App. 3d 1 (2010)).

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IV. PROVE-UP HEARING TO ESTABLISH DAMAGES

12. Given Defendants' default, Plaintiff requests a prove-up hearing to establish damages.

13. Illinois law permits a prove-up hearing in default judgment cases to determine compensatory, punitive, and statutory damages (735 ILCS 5/2-1301(d)).

14. Plaintiff seeks:

• Compensatory damages for reputational harm, emotional distress, and financial loss.

• Punitive damages due to Defendants' malicious and intentional misconduct.

• Statutory damages under VAWA and defamation laws.

15. Defendants' failure to appear should not prevent a full assessment of damages.

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V. RELIEF REQUESTED

16. Based on Defendants' undisputed liability, Plaintiff respectfully requests:

A. Monetary Damages

• $300,000,000 in compensatory and punitive damages, including:

  • Emotional distress and reputational harm.

  • Financial losses from job interference.

B. Permanent Injunction

• A court order prohibiting Defendants from:

  • Contacting, harassing, or defaming Plaintiff.

C. Criminal Referral & Sanctions

• Referral for criminal prosecution under:

  • 720 ILCS 5/12-7.4 (Stalking, Class 4 felony)

  • 18 U.S.C. § 2261A (Federal Stalking Law)

D. Ruling with Prejudice

• A final ruling with prejudice, barring Defendants from relitigating these claims.

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VI. CONCLUSION

WHEREFORE, Plaintiff respectfully requests that this Honorable Court:

1. Enter Default Judgment in Plaintiff’s favor;

2. Schedule a Prove-Up Hearing to determine final damages;

3. Award Plaintiff $300,000,000 in damages;

4. Issue a Permanent Injunction against Defendants;

5. Refer Defendants for Criminal Investigation;

6. Issue a ruling with prejudice against Defendants.

Respectfully submitted,

/s/ Chyvette A. Valentine

Pro Se Plaintiff

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CERTIFICATE OF SERVICE

I, Chyvette A. Valentine, hereby certify that on March 31, 2025, a true and correct copy of the foregoing Motion for Default Judgment was mailed via certified mail and emailed to:

Jason Giller, Attorney for Defendants

1111 Brickell Bay Dr #1550

Miami, FL 33131

Email: Jason@Gillerpa.com

/s/ Chyvette A. Valentine

Chyvette A. Valentine

Pro Se Plaintiff