CHYVETTE A. VALENTINE,
Plaintiff,
v.
SCOTTIE PIPPEN, LARSA PIPPEN, CARL PIPPEN, JASON GILLER, et al.,
Defendants.
Case No.: 2024L002166
Courtroom: 2209
Judge: Hon. Maire Aileen Dempsey
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT WITH PREJUDICE, INTENT TO PROVE-UP DAMAGES, AND REFERRAL FOR CRIMINAL CHARGES
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 submits that Defendants have been properly served but have failed to respond within the legally required timeframe. As such, Plaintiff seeks:
Entry of Default Judgment against all Defendants;
Award of $300 million in damages, including compensatory, punitive, and economic damages for defamation, false arrest, blacklisting, housing discrimination, retaliation, and attempted murder;
Permanent injunctive relief preventing further harassment, defamation, and financial interference;
Referral for criminal prosecution under Illinois and federal law, including violations under the Violence Against Women Act (VAWA) and interstate stalking and extortion laws;
Any other relief this Court deems just and proper.
I. INTRODUCTION
Plaintiff first met Defendant Scottie Pippen in August 1987 at Hero’s Nightclub, located at 2347 S Michigan, Chicago Illinois where she was employed by Calvin Hollins. Between 1986 and 1993, Plaintiff held various roles, including server, security, event planner, and promoter.
Plaintiff was introduced to Scottie Pippen by Charles Oakley, whom she had met while touring with LL Cool J as a security escort for dancers.
At Oakley’s request, Plaintiff socialized with Scottie Pippen, who was new to the city. They casually dated from August 1987 to February 14, 1988. However, upon learning that Pippen was married to Karen McCullum, Plaintiff ended the relationship to avoid engaging in adultery.
In 1991, following Pippen’s divorce, he sought to rekindle their relationship, even assisting in Plaintiff’s relocation. The relationship ended when Pippen was caught openly cheating with Plaintiff’s then-roommate, Lisa Raye McCoy.
On Saturday February 13, 1993, Plaintiff hosted and promoted an event featuring the singing group "Silk" at Buddy Guy’s. After the event, while at the Cotton Club with clients, Defendants Scottie Pippen and Carl Terry Pippen sent Plaintiff a drink.
Shortly after consumption, Plaintiff became violently ill and ended her evening, returning home to 10 East Ontario, #2206, in Chicago. Approximately an hour later, Scottie Pippen arrived at her residence. Plaintiff, now incoherent, was sexually assaulted by both Defendants. She was subsequently transported to Northwestern Hospital, where she was examined for sexual assault, and a police report was filed.
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 Pippen, her family members, demonstrating Defendants' actual knowledge of this lawsuit.
Plaintiff also notes that settlement talks were refused on the following dates, further demonstrating Defendants’ lack of cooperation:
January 24, 2024
July 10, 2024
October 13, 2024
Defendants' failure to respond within the required timeframe constitutes a legal admission of the allegations contained in the Complaint under 735 ILCS 5/2-1301(d) and Illinois Supreme Court Rule 181(a).
Illinois law, federal law, and established case precedent support the entry of default judgment.
II. LEGAL STANDARD FOR DEFAULT JUDGMENT
A. Illinois and Federal Rules on Default Judgment
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.
Illinois Supreme Court Rule 219(c) allows courts to enter default judgment when a party willfully refuses to comply with procedural requirements.
Federal Rule of Civil Procedure 55(a) allows a court to enter default judgment when a defendant "fails to plead or otherwise defend."
B. 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.
III. CLAIMS FOR DAMAGES AND RELIEF
A. Forced to Live in a Car for Two Years to Escape Harassment
Due to the sustained campaign of harassment and stalking by Defendants, Plaintiff was forced to live in her car for two years, from 2018 to 2020, in order to escape the constant threats, attacks, and intimidation orchestrated by Defendants. This has caused severe emotional and psychological distress, as well as significant financial and physical harm.
The Fair Housing Act (42 U.S.C. §§ 3601-3619) protects individuals from discrimination and harassment related to housing, and Defendants’ conduct has caused Plaintiff to experience extreme hardships, including the deprivation of basic shelter.
B. Employment Interference & Financial Harm
Plaintiff has lost high-paying jobs due to the defamatory statements and harassment inflicted by Defendants, as follows:
Dun & Bradstreet (2016) – Lost an opportunity to earn $75,000+ per year.
Sutherland Global (2017) – Lost an opportunity to earn $55,000 per year.
Inglewood Police 911 Dispatch (2019) – Lost an opportunity to earn $55,000-$75,000 per year.
Santa Monica Background Officer (2019) – Lost an opportunity to earn $65,000-$85,000 per year.
Applebee's Server (2024) - Lost opportunity after filing employer address on Davis complaint. Defendants sent family to the location in Gulfport, Mississippi on June 16, 2024. Plaintiff was terminated 3 days later.
Shaggy's Server (2024) - Lost opportunity due to stalking by Defendants
HomeAGlow Deactivated (2025) - Lost opportunity, due to complaints to state
Additionally, Defendants used their influence to have Plaintiff’s accounts on gig economy platforms, such as Postmates, DoorDash, Uber Eats, Lyft, and Turo, deactivated, depriving her of income. This interference in Plaintiff's employment prospects constitutes financial harm under 42 U.S.C. § 1983.
C. Physical Attacks & Attempted Murder
June 11, 2002 – Plaintiff’s brakes were deliberately cut, causing her to crash into an 18-wheeler truck while attempting to establish paternity.
February 25, 2016 – Plaintiff nearly died from carbon monoxide poisoning, sustaining head injuries requiring 12 stitches.
April 19, 2019 – Plaintiff was attacked by a dog, resulting in a severe 6-inch by 6-inch bite.
June 2020 – Plaintiff’s nose was broken three times by Maurice Farzam, the owner of Holiday Motel, as part of an orchestrated attack.
Each of these acts constitutes attempted murder, and Plaintiff seeks damages for the physical harm and emotional distress caused by these attacks under 18 U.S.C. § 1111 (Federal Murder Statute).
D. Interstate Stalking and Extortion
In addition to violations under VAWA, Plaintiff asserts the following criminal acts in violation of federal law:
Six counts of interstate stalking, in violation of 18 U.S.C. § 2261A(2)(A), as Plaintiff was stalked and harassed across multiple states:
Count 1: Interstate Stalking to Arizona (March 2016)
Count 2: Interstate Stalking to Nevada (July 2017)
Count 3: Interstate Stalking to California (June 2018)
Count 4: Interstate Stalking to Arkansas (March 2024)
Count 5: Interstate Stalking to Mississippi (April 2024)
Count 6: Interstate Stalking to Tennessee (May 2024)
Count 7: Interstate Stalking to Nevada (July 2024)
Seven counts of interstate extortionate threats, in violation of 18 U.S.C. § 875(d), relating to threats made across state lines with the intent to extort money, property, or services from Plaintiff.
These actions, which span multiple states, further substantiate the scope and severity of Defendants' conduct.
IV. ASSOCIATED CASES OF HARASSMENT, DEFAMATION, AND RETALIATION
Plaintiff has been forced to file multiple legal actions due to Defendants' ongoing harassment, defamation, and retaliatory actions.
This case arises from 30 years of harassment, stalking, defamation, wrongful eviction, wrongful termination, and conspiracy by Defendants, resulting in severe emotional, financial, and reputational harm to Plaintiff.
Plaintiff filed a $10 million claim in 2008 against Defendants for harassment, defamation, and damages. On August 8, 2008, working in collusion with Congressman Danny K. Davis, Plaintiff’s children were illegally seized while she attempted to establish Scottie Pippen’s paternity, see Valentine v. DCFS, 1:2010cv04751 (seeking $33 million in damages).
Since that time, Defendants have escalated their efforts to destroy Plaintiff’s life, career, housing, and safety, including an alleged wrongful death conspiracy involving Devonte Pippen.
Because Defendants have failed to appear, respond, or defend against these well-pleaded claims, summary judgment is warranted under 735 ILCS 5/2-1005(c).
These cases further demonstrate the pattern of misconduct involving Jason Giller and his co-conspirators:
20211300843 – Valentine v. Nails Pretty, Salon Nail – Harassment & Defamation
20211300844 – Valentine v. James Trice Sr., James Trice Jr., BBQ Slab, Tonya Trice – Stalking & Retaliation
20231300097 – Valentine v. Theressia Washington – Harassment & Defamation
20221301069 – Valentine v. Shalisa Harvey d/b/a CHA et al. – Stalking & Retaliation
2021L012271 – Valentine v. Ervin Johnson – Defamation & Harassment
2020L012117 – Valentine v. LisaRaye McCoy – Defamation & Stalking
2020L012118 – Valentine v. Theressia Washington – Defamation & Harassment
2021LO12270 – Valentine v. Curtis "50 Cent" Jackson - Threats, Intimidation, Harassment
These cases confirm the ongoing pattern of misconduct involving Defendants and their co-conspirators, further demonstrating the need for this Court to enter a Default Judgment in favor of Plaintiff.
V. HOUSING DISCRIMINATION & WRONGFUL EVICTIONS
Plaintiff has been subjected to unlawful evictions in violation of the Fair Housing Act (42 U.S.C. §§ 3601-3619), which prohibits discrimination based on race, color, religion, sex, familial status, or national origin.
Over the course of 30 years, Plaintiff has been unlawfully evicted 12 times, and Defendants have colluded to terminate Plaintiff's housing assistance. This conduct, carried out by the Defendants and their co-conspirators, has forced Plaintiff into homelessness.
Plaintiff has filed the following cases related to housing discrimination and wrongful eviction:
Valentine v. Waterton (20231113048)
Valentine v. TLC Management (20211125422)
Valentine v. Lotus Management (2021-M1-701669)
Defendants colluded with Congressman Danny K. Davis to unlawfully terminate Plaintiff’s housing assistance, forcing her into homelessness.
VI. CONCLUSION
WHEREFORE, Plaintiff respectfully requests that this Honorable Court:
In light of the overwhelming evidence presented before this Court, Plaintiff, Chyvette A. Valentine, respectfully urges this Honorable Court to grant the requested Default Judgment against all Defendants, as their failure to respond to the Complaint not only constitutes a legal default but also reflects their continued disregard for the laws and rights of Plaintiff. The repeated pattern of harassment, defamation, retaliation, financial interference, and physical harm by Defendants has caused significant distress, loss, and damage to Plaintiff, compelling this Court to act in favor of justice.
Under 735 ILCS 5/2-1301(d), Illinois Supreme Court Rule 219(c), and Federal Rule of Civil Procedure 55(a), this Court is authorized to grant Default Judgment when a defendant has been properly served but fails to respond to the complaint within the statutory timeframe. Defendants in this case have been duly served and have not provided any substantive defense or response to the allegations. As established in People ex rel. Department of Public Aid v. LeVine, 99 Ill. 2d 146 (1983), a failure to respond results in an admission of all the allegations contained in the complaint.
Furthermore, Illinois case law and federal precedence are clear in supporting the entry of a Default Judgment when a defendant's willful failure to respond reflects a deliberate disregard for legal proceedings. In Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986), the Illinois Supreme Court emphasized that default judgment is appropriate when a defendant consciously ignores or disregards the legal process. Likewise, in Celotex Corp. v. Catrett, 477 U.S. 317 (1986), the U.S. Supreme Court held that failure to dispute material allegations permits a judgment as a matter of law.
The evidence presented to this Court confirms that Defendants, including Scottie M. Pippen, Larsa Pippen, Carl Pippen, and Jason Giller, have engaged in a coordinated campaign of harassment, stalking, defamation, and retaliation against Plaintiff. They have caused Plaintiff to be unlawfully evicted multiple times, interfered with her employment opportunities, and inflicted severe physical and emotional harm through attacks and orchestrated events.
Plaintiff’s claims for defamation, false arrest, housing discrimination, and retaliation are not just personal grievances but represent violations of both state and federal law. As highlighted under the Violence Against Women Act (VAWA), Plaintiff has been subjected to systematic stalking and harassment, which are criminal offenses under 18 U.S.C. § 2261A.
Additionally, Defendants’ unlawful actions have interfered with Plaintiff’s ability to earn a living, resulting in economic harm, including loss of employment opportunities with organizations such as Dun & Bradstreet, Sutherland Global, and Inglewood Police 911 Dispatch.
Plaintiff has lost multiple business opportunities while pursuing various entrepreneurial endeavors, including but not limited to seeking investment from Floyd Mayweather, Shaquille O’Neal, and Gary Payton. While residing in Las Vegas, Defendants defamed Plaintiff by slandering her name, reputation, and business acumen—falsely labeling her as a “mentally ill groupie.”
Defendants further targeted her through casino establishments, restricted her career prospects, and obstructed investment opportunities for her businesses, including Sunday's Soul Food and Catering, Sunday's Bed and Breakfast LLC, and Hail Mary Jane Marijuana Farm.
Motivated by revenge, retaliation, and malicious intent, Defendants subjected Plaintiff to a ten-month-long bed bug infestation at Presidential Towers, a luxury housing complex, ultimately leading to her eviction and homelessness.
Additionally, Defendants have engaged in relentless social media attacks, spreading false and defamatory statements fueled by envy and jealousy. Larsa Pippen has been a primary instigator, acting to protect her own interests and those of her children.
Further, the repeated physical attacks and threats made against Plaintiff, as detailed in the complaint, amount to attempted murder and interstate stalking under 18 U.S.C. § 875(d) and 18 U.S.C. § 2261A. These are not isolated incidents but part of a deliberate campaign to harm, isolate, and intimidate Plaintiff, and the Defendants' refusal to answer or participate in settlement talks reflects their continued pursuit of these unlawful objectives.
Plaintiff’s legal action is grounded in protecting her rights against unlawful harassment and ensuring that justice is served. Illinois law recognizes the gravity of harassment and retaliation in the workplace and housing, and courts have consistently awarded significant damages when such actions are proven, as seen in cases like Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986) and People ex rel. Department of Public Aid v. LeVine, 99 Ill. 2d 146 (1983).
For these reasons, Plaintiff respectfully requests that this Court enter Default Judgment in favor of Plaintiff and grant the relief sought, including:
$300 million in compensatory, punitive, and economic damages;
Injunctive relief preventing Defendants from further harassment and retaliation;
Referral for criminal prosecution under federal law for stalking, defamation, and extortionate threats;
Any other relief this Court deems just and proper.
