THE REST OF THIS WEEK WORKING ON CASES #EDITING (Due May 22, 2025 at 10 am)

PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT WITH PREJUDICE, PROVE-UP OF DAMAGES, AND REFERRAL FOR CRIMINAL INVESTIGATION

NOW COMES Plaintiff, CHYVETTE A. VALENTINE, pro se, pursuant to 735 ILCS 5/2-1301(d), Illinois Supreme Court Rule 219(c), and Federal Rule of Civil Procedure 55, and respectfully moves this Honorable Court for entry of a Default Judgment with Prejudice against all named Defendants for their failure to appear, plead, or otherwise defend this matter. In support thereof, Plaintiff states as follows:

I. GROUNDS FOR DEFAULT JUDGMENT

1. Plaintiff properly served all Defendants in accordance with applicable law, including service on Scottie M. Pippen by the LA County Sheriff and certified mail receipts for Larsa, Carl, and Jason Giller.

2. No Defendant has entered an appearance, filed an answer, or otherwise defended this action within the time required by law.

3. Under 735 ILCS 5/2-1301(d), and the holding in People ex rel. Dept. of Public Aid v. LeVine, 99 Ill. 2d 146 (1983), failure to respond results in admission of all well-pleaded facts.

4. The Court may enter judgment by default where the record supports a prima facie case, as further established in Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986).

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II. LEGAL STANDARD

5. A default judgment is appropriate where: a. Defendant is properly served; b. Defendant fails to plead or appear; and c. Plaintiff's claims are sufficiently supported by evidence or uncontested allegations.

6. See also Celotex Corp. v. Catrett, 477 U.S. 317 (1986), and Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) – no material dispute of fact precludes entry of judgment as a matter of law.

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III. PLAINTIFF'S ENTITLEMENT TO DAMAGES

A. Common Law and Statutory Violations

7. Plaintiff has brought valid claims for:

   • Defamation and defamation per se;

   • Intentional infliction of emotional distress;

   • Stalking and harassment under 720 ILCS 5/12-7.4;

   • False imprisonment and civil rights violations under 42 U.S.C. § 1983;

   • Housing discrimination under 42 U.S.C. §§ 3601–3619;

   • Tortious interference with employment and business expectancy.

B. Factual Basis

8. Plaintiff alleges:

   • Defendants conspired to defame her in mass media outlets;

   • She was falsely arrested, evicted, blacklisted from employment;

   • Physical attacks occurred from 2002 to 2020;

   • Multiple evictions, blacklisting from gig economy platforms, and ongoing retaliation.

C. Damages Sought

9. Plaintiff seeks the following:

   • Lost Wages & Economic Harm – $10,000,000

   • Defamation Damages – $50,000,000

   • Punitive Damages – $200,000,000

   • Emotional Distress – $40,000,000
     TOTAL DAMAGES SOUGHT: $300,000,000

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IV. REFERRAL FOR CRIMINAL PROSECUTION

10. Based on the conduct described above, Plaintiff requests the Court refer this matter to state and federal law enforcement for:

• Wire Fraud (18 U.S.C. § 1343)

• Obstruction of Justice (18 U.S.C. § 1503)

• Identity Theft (720 ILCS 5/16-30)

• False Imprisonment (720 ILCS 5/10-3)

• Harassment and Stalking (720 ILCS 5/12-7.4)

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V. PRAYER FOR RELIEF

11. WHEREFORE, Plaintiff respectfully requests that this Court:

• Enter Default Judgment with Prejudice against all Defendants;

• Schedule a Prove-Up Hearing;

• Award $300 million in damages;

• Issue injunctive relief barring further harassment;

• Refer for criminal investigation;

• Grant such other and further relief as the Court deems just and proper.