IN
THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
CHYVETTE A. VALENTINE,
Plaintiff,
v.
SCOTTIE M. PIPPEN, LARSA
PIPPEN, CARL T. PIPPEN, MELISSA PIPPEN, JASON B. GILLER, et al.,
Defendants.
Case No. 2024L002166
Judge Maire Aileen Dempsey
Courtroom 2209
PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT WITH PREJUDICE
NOW COMES Plaintiff, CHYVETTE A. VALENTINE, appearing pro se, and respectfully moves this Honorable Court to enter Default Judgment with Prejudice against Defendants Scottie M. Pippen, Larsa Pippen, Carl T. Pippen, Jason B. Giller, and all associated parties, pursuant to 735 ILCS 5/2-1301(d) and Illinois Supreme Court Rule 137. In support of this Motion, Plaintiff states as follows:
I. INTRODUCTION
1. Plaintiff, Chyvette A. Valentine, is an individual who has experienced a sustained, multi-decade campaign of harassment, defamation, physical and psychological harm, employment sabotage, and retaliatory housing discrimination at the hands of Defendants, including Scottie M. Pippen and others affiliated with him, either directly or through agents and co-conspirators.
2. Beginning in or around the early 1987s and continuing through the present, Plaintiff has been subjected to repeated and escalating acts of targeted misconduct intended to destabilize every aspect of her life, from career prospects and safe housing to physical safety and mental health.
3. The pattern of conduct has included but is not limited to: (a) physical assaults and life-threatening sabotage; (b) defamation and interference with professional relationships; (c) retaliatory evictions and sabotage of housing opportunities, (d) death to family, friends, and associates, co-workers; (e) intentional psychological harm through persistent stalking, intimidation, and public humiliation.
4. Defendants’ conduct has not been random or coincidental, but rather, appears to have been executed as part of an organized effort to silence, punish, and destroy the personal and professional reputation of Plaintiff in retaliation for prior reports or grievances Plaintiff made about misconduct involving or implicating the Defendants and their associates.
5. These actions have not only resulted in severe psychological trauma, including Post-Traumatic Stress Disorder (PTSD), anxiety, and depression, but have also had measurable economic consequences: Plaintiff has lost over $2 million in income, suffered repeated housing instability and homelessness, and incurred significant medical expenses due to injuries directly resulting from Defendants’ actions.
6. Despite repeated attempts by Plaintiff to secure work, build businesses, and establish a life free from harassment, Defendants have sabotaged these efforts through stalking, smear campaigns, false reports to employers and clients, and direct interference with business operations, stalking, harassment and smear campaigns to ruin Plaintiff.
7. The conduct described in this Motion is supported by public records, police reports, employment documentation, housing contracts, medical records, and sworn testimony, all of which will be offered at a prove-up hearing or trial on damages, if necessary.
- Since 1987, Plaintiff has been subjected to escalating and deliberate misconduct intended to destabilize every aspect of her life personal, professional, and financial.
- The pattern of misconduct has
included but is not limited to:
(a) physical assaults and sabotage;
(b) defamation and employment interference;
(c) retaliatory evictions; and
(d) psychological trauma through ongoing stalking and intimidation, including and not limited to sudden deaths and/or murders to family related to Plaintiff in this matter. - Defendants coordinated actions were retaliatory, malicious, and intended to punish Plaintiff for prior disclosures of misconduct involving or implicating them.
- As a result, Plaintiff has endured documented diagnoses of PTSD, anxiety, and depression, incurred over $2 million in financial losses, suffered multiple serious physical injuries, and experienced homelessness and reputational ruin.
- The allegations are corroborated by police reports, medical records, housing documents, employment correspondence, and sworn affidavits, and warrant entry of Default Judgment with Prejudice.
II. PROCEDURAL HISTORY
- On May 7, 2024, Plaintiff filed her First Amended Complaint, increasing damages sought to $300 million.
- On May 21, 2024, Plaintiff filed Motions to Amend, submitting subpoenas, exhibits, and factual support.
- On May 29, 2024, the case was reassigned to Judge Maire Aileen Dempsey in Courtroom 2209.
- On June 20, 2024, Plaintiff filed a Motion to Extend, with exhibits supporting default judgment.
- On July 31, 2024, Plaintiff filed a Motion in Opposition to Dismiss, with substantial evidentiary support.
- On August 13, 2024, Plaintiff filed a Motion to Continue, further bolstering her request for default judgment.
- On October 12, 2024, Plaintiff attempted service via continued lawful communications, including emails to Defendant family members and Registered Agent Jason Giller, triggering improper sanctions against her despite longstanding and lawful correspondence since 2019.
- On October 28, 2024, Plaintiff reported renewed stalking and harassment in Las Vegas, Nevada.
III. FACTUAL BACKGROUND
A. Background and Relationship History
- From 1985 to 1993, Plaintiff worked as an independent contractor affiliated with Michael Jordan events.
- Plaintiff met Scottie Pippen in 1987 through Charles Oakley and Kevin Buie during a tour with LL Cool J.
- Plaintiff and Pippen were involved romantically from October 1987 to February 1988, resuming the relationship in 1991 until it ended due to Pippen’s affair with Lisa Raye McCoy, Plaintiff’s roommate and client.
- Following the breakup, McCoy initiated a targeted harassment campaign that included unauthorized use of Plaintiff’s likeness in the 1995 film Players Club, where “Ebonee” mirrored Plaintiff’s traumatic experiences.
B. February 18, 1993, Rape and Resulting Trauma
- On February 18, 1993, Plaintiff attended an afterparty at the Cotton Club in Chicago, where she was drugged by Scottie and Carl Pippen, and later raped at her home.
- She reported the assault to Chicago Police and received medical care at Northwestern Hospital.
- Plaintiff gave birth to Devonte Jeffory Mitchell Pippen in Milwaukee. Devonte was murdered on January 19, 2012, in what Plaintiff asserts was part of the same retaliatory campaign to protect Defendants’ reputation, career and marriage.
- Paternity was initially established by the Office of Child Support in Earle, Arkansas in 2002. However, it is alleged that Carl Pippen fraudulently submitted DNA on behalf of Scottie Pippen.
- Scottie Pippen later confessed in person that Devonte was, in fact, his biological son.
- Despite multiple efforts by the Plaintiff to confirm the child's true paternity and secure child support, these attempts were summarily dismissed. The Plaintiff contends that, to protect Scottie Pippen’s marriage and public image, the Defendants conspired to conceal the child's true parentage and suppress related evidence, thereby obstructing justice and violating the Plaintiff’s rights.
IV. HISTORY OF HARASSMENT, DEFAMATION, AND RETALIATION
25. The harassment campaign against Plaintiff has included sustained and malicious acts of defamation, character assassination, stalking, and retaliatory interference, executed through both overt actions and covert communications with Plaintiff’s employers, landlords, neighbors, clients, and social contacts.
26. Defendants, individually and through intermediaries, disseminated false, damaging, and stigmatizing allegations against Plaintiff, including claims of mental instability, criminal conduct, unprofessional behavior, and sexual impropriety—none of which have any factual basis or lawful justification.
27. These statements were made to pastors, judges, lawyers, employers, landlords, politicians, business associates, social media influencers, entertainment executives, gig platforms, and law enforcement, with the intent to permanently undermine Plaintiff’s credibility, deny her access to housing or employment, and isolate her from all sources of support.
28. Defendants routinely used these fabrications to incite retaliatory employment terminations, evictions, and social rejection. These efforts deprived Plaintiff of livelihood, shelter, and dignity, resulting in economic destitution and psychological trauma.
29. Plaintiff’s personal information, including her photo, contact details, work history, and legal filings was repeatedly weaponized in coordinated smear campaigns involving anonymous reports, impersonation, and digital sabotage such as email spoofing and manipulated social media content.
30. In one such instance, Defendants enlisted the syndicated entertainment show Dish Nation through mutual associate Shawntae Harris a/k/a Da Brat, who has long-standing personal ties to Larsa Pippen and Lisa Raye McCoy.
31. In a segment aired nationally, Dish Nation mocked Plaintiff’s claims and alluded to “receipts” regarding the disputed paternity of Devonte Pippen, despite these matters being the subject of confidential litigation.
32. The segment was a thinly veiled attempt to discredit and humiliate Plaintiff, reflecting the ongoing coordination between Defendants and media personalities to chill Plaintiff’s legal speech and suppress her pursuit of justice.
33. Despite sending formal rebuttals and cease-and-desist notices to individuals and organizations involved, these attacks persisted over decades, growing more complex, persistent, and far-reaching due to digital amplification and artificial intelligence technologies.
34. The Defendants’ conduct violates Illinois defamation per se statutes, including publication of false statements that impute criminal behavior, mental illness, and professional misconduct. (See Bryson v. News Am. Publs., Inc., 174 Ill. 2d 77, 88 (1996); Seith v. Chicago Sun-Times, Inc., 371 Ill. App. 3d 124, 134 (1st Dist. 2007)). These actions also support civil and criminal claims under federal statutes, including 18 U.S.C. § 2261A (Interstate Stalking), 18 U.S.C. § 875 (Threats and Extortion), and 42 U.S.C. § 3617 (Housing Rights Interference).
V. TIMELINE OF KEY INCIDENTS
35. The following timeline sets forth selected, verified incidents reflecting the prolonged, escalating, and targeted campaign of harassment, retaliation, and violence directed at Plaintiff by Defendants and their known agents. These events demonstrate a pattern of intentional misconduct spanning more than two decades, with increasing severity and sophistication.
36. June 11, 2002 – Brake Line Sabotage: Plaintiff narrowly escaped serious bodily harm after discovering that the brake lines of her vehicle had been deliberately cut. A post-incident investigation suggested sabotage. Plaintiff believes this act was committed by individuals with ties to Defendants in retaliation for prior complaints and attempts to pursue legal redress.
37. February 25, 2016 – Carbon Monoxide Poisoning: Plaintiff was found unconscious in her residence and was hospitalized due to carbon monoxide poisoning. The source of the gas was traced to ventilation tampering, believed to have been intentionally altered by third parties with access to Plaintiff’s unit. The plaintiff required emergency care, received 12 stitches, and continued to suffer from neurological damage and scarring. This incident represents a potential attempted homicide.
38. April 19, 2019 – Dog Attack Resulting in Severe Leg Trauma: Plaintiff was attacked by a dog unleashed by an individual with known ties to Defendants. The dog had reportedly been trained to attack, and the incident caused serious leg injuries requiring ongoing medical attention and left Plaintiff physically impaired.
39. June 2020 – Physical Assault and Facial Disfigurement: Plaintiff was assaulted by a man later identified as having associations with one or more named Defendants. The assault caused a nasal fracture and facial trauma, resulting in permanent disfigurement. Plaintiff required emergency care and has endured lifelong physical consequences.
40. 1993 to 2025 – Retaliatory Evictions and Homelessness: Over a thirty-year period, Plaintiff was repeatedly displaced from housing due to coordinated stalking, harassment, and false complaints. As a direct result of these efforts, Plaintiff endured multiple episodes of homelessness, often immediately after asserting legal claims or reporting harassment.
41. 2018–2025 – Deactivation of Income Accounts via False Reports: Throughout this period, Plaintiff’s accounts with major gig economy platforms including Airbnb, DoorDash, Uber Eats, Lyft, Turo, HomeAGlow, and TakeABreak were suddenly deactivated or restricted without cause. Investigations revealed the presence of false complaints submitted by individuals using aliases or traceable to known associates of Defendants. These actions resulted in total or partial loss of income and financial destabilization.
42. 1993–2025 – Continued Surveillance and Media Retaliation: Most recently, Defendants facilitated public ridicule of Plaintiff’s claims through a segment on Dish Nation, facilitated by Shawntae Harris a/k/a Da Brat, in coordination with Larsa Pippen and Lisa Raye McCoy. The segment mocked Plaintiff’s legal claims and questioned the validity of Devonte Pippen’s paternity, thereby reinforcing a longstanding pattern of retaliation and public humiliation.
43. These events represent only a fraction of the harassment and injury sustained by Plaintiff. They are consistent in motive, execution, and target, and provide compelling evidence of a coordinated conspiracy by Defendants to destroy Plaintiff’s livelihood, housing stability, personal safety, and mental well-being through unlawful and malicious means.
VI. DEFENDANTS’ FAILURE TO RESPOND
- Defendants were properly served as
follows:
a. Scottie Pippen – Personally served by the Los Angeles County Sheriff on December 18, 2024;
b. Larsa Pippen – Served via certified mail on October 17, 2024;
c. Carl T. Pippen – Served via certified mail on October 19, 2024;
d. Jason B. Giller – Acknowledged service on October 13, 2024;
e. Melissa Pippen – Acknowledged service on October 13, 2024. - Despite having been duly served, none of the Defendants has appeared, filed an answer, or otherwise defended against the action. Their failure to respond constitutes a willful disregard of the judicial process and supports the entry of default judgment. See Jackson v. Hooker, 397 Ill. App. 3d 614 (1st Dist. 2010).
IV. SPECIFIC INCIDENTS OF DEFENDANTS’ MISCONDUCT
Plaintiff now presents representative examples of the deliberate and repeated pattern of retaliatory conduct perpetrated by Defendants:
A. Employment Interference
26. Dun & Bradstreet (2016): Plaintiff was offered a salaried position paying $75,000 per year. The offer was rescinded without explanation after a background screening flagged defamatory content. Plaintiff later learned this interference stemmed from a third-party smear campaign instigated by individuals tied to Defendants.
27. Sutherland Global (2017): After completing all pre-employment onboarding requirements, Plaintiff was abruptly informed that the position was no longer available. Internal sources indicated that derogatory communications had been received, falsely discrediting Plaintiff.
28. Inglewood Police Department (2019): Plaintiff was blacklisted from civilian support roles. Background inquiries were met with fabricated “red flag” warnings attributed to false criminal or mental health claims circulated by third-party actors affiliated with Defendants.
29. Applebee’s (2024): Plaintiff was terminated based on anonymous allegations conveyed to store management. Despite her clean record and positive evaluations, Plaintiff was not provided with any opportunity to view or challenge the accusations.
30. Shaggy’s (2024): After reporting multiple incidents of stalking, Plaintiff was advised by her employer that the environment was “no longer safe” for her presence due to threats allegedly made by individuals recognized as prior harassers with ties to Defendants.
31. HomeAGlow (2025): Despite earning consistent five-star reviews, Plaintiff’s account was deactivated based on false customer complaints later traced to fraudulent profiles affiliated with Defendant-linked IP addresses or known associates.
32. TakeABreak Vacations (2025): Plaintiff was denied compensation and access to future work after an organized defamation campaign was launched online and through anonymous internal communications directed at the company’s leadership.
26. Tort Intake Professionals (May 15, 2025): Plaintiff was terminated the day she filed Motion for Default Judgement.
27. Gig Platforms (2019–2025): Plaintiff’s accounts on Postmates, DoorDash, Uber Eats, Lyft, and Turo were systematically deactivated. These closures consistently followed incidents of identity-based harassment, false reporting, and retaliation resembling a pattern previously traced to the same network of Defendants and their agents.
B. Physical Harm and Attempted Murder
28. Plaintiff has survived multiple attempts on her life, as well as serious bodily harm, each accompanied by evidence of criminal intent and investigative obstruction by individuals with known affiliations to Defendants.
29. Brake Sabotage (2002): Plaintiff’s vehicle brake lines were tampered with, placing her at risk of a fatal crash. Although sabotage was suspected, the investigation was compromised by third-party interference.
30. Carbon Monoxide Poisoning (2016): Plaintiff was discovered unconscious in her home and hospitalized. Emergency responders determined that ventilation systems had been intentionally altered, resulting in a high-level gas leak. Plaintiff sustained permanent neurological harm and required sutures for facial trauma. Law enforcement reports indicate signs of unlawful entry and tampering.
31. Physical Assaults (1987–2025): Plaintiff was physically assaulted on multiple occasions, including a dog attack on April 19, 2019, and a violent facial assault in June 2020 that caused a nasal fracture and permanent disfigurement. Both incidents were reported to authorities, but investigations were obstructed by individuals linked to the Defendants’ social and professional networks.
C. Housing Discrimination & Wrongful Evictions
32. Between 1993 and 2025, Plaintiff endured over 20 retaliatory evictions, most of which followed her attempts to report misconduct or escape stalking and abuse.
- Plaintiff has been subjected to
a pattern of unlawful evictions, totaling twelve (12) separate incidents,
in violation of the Fair Housing Act, 42 U.S.C. §§ 3601–3619. These
actions were discriminatory and retaliatory in nature.
- The following cases document
ongoing efforts by Plaintiff to seek redress for such violations:
• Valentine v. Waterton, Case No. 20231113048
• Valentine v. TLC Management, Case No. 20211125422
• Valentine v. Lotus Management, Case No. 2021-M1-701669 - Defendants colluded to unlawfully terminate Plaintiff’s housing assistance, directly resulting in Plaintiff’s homelessness, in violation of federal fair housing principles as upheld in Texas Dep’t of Hous. & Cmty. Affairs v. Inclusive Communities Project, Inc., 576 U.S. 519 (2015).
- Plaintiff is also pursuing a $3 million action against the Chicago Housing Authority for its role in the unlawful terminations and discriminatory practices contributing to Plaintiff’s housing instability.
37. Landlords and property managers across Illinois, California, Nevada, Arizona, Tennessee, Mississippi, and Arkansas were contacted by third parties who disseminated false information, including fabricated criminal histories, defamatory psychiatric claims, or misrepresentations of Plaintiff’s litigation history. These communications were designed to terminate existing leases or prevent new tenancies.
38. This conduct constitutes a clear violation of the Fair Housing Act, 42 U.S.C. §§ 3601–3619, which prohibits housing providers from retaliating against tenants or applicants who report discrimination or harassment. Defendants’ persistent interference with Plaintiff’s housing rights was malicious, targeted, and executed across jurisdictions.
39. Plaintiff’s applications for subsidized housing, HUD vouchers, and local rental assistance programs were routinely blocked, delayed, or marked with false “red flag” notations. In several cases, case managers or housing authorities received tampered documentation or defamatory notices that sabotaged Plaintiff’s eligibility.
40. This section evidences an orchestrated pattern of misconduct that violates both state tort law and federal civil rights protections, including:
41. 42 U.S.C. § 3617 (Interference, coercion, or intimidation in relation to housing rights).
42. 18 U.S.C. § 2261A (Interstate stalking).
43. 18 U.S.C. § 875(d) (Extortion and threats using digital means); and
44. 18 U.S.C. §§ 241 and 242 (Conspiracy to deprive constitutional and civil rights under color of law).
45. Defendants’ conduct rises beyond civil liability to reflect potential criminal culpability and justifies both civil damages and federal investigation. The targeted nature of this interference demonstrates a deliberate and ongoing conspiracy to destabilize Plaintiff’s life and retaliate for her prior protected activities.
V. ONGOING NATURE OF HARASSMENT CAMPAIGN
46. The conduct of Defendants constitutes a deliberate, unrelenting, and escalating campaign of harassment, extending across three decades and impacting nearly every aspect of Plaintiff’s life. This misconduct includes economic sabotage, physical endangerment, reputational destruction, psychological manipulation, and digital surveillance.
47. Each time Plaintiff made efforts to stabilize her life through housing, employment, education, or medical care, coordinated retaliation ensued. Known and unknown agents affiliated with Defendants intervened to disrupt, block, or dismantle those efforts using illegal and coercive means.
48. Despite relocating across seven states—Illinois, California, Nevada, Arizona, Tennessee, Mississippi, and Arkansas—Plaintiff was continuously tracked and targeted. Defendants adapted their methods over time, using increasingly sophisticated tactics including unlawful surveillance, impersonation, and cross-jurisdictional digital tracking to perpetuate abuse and interference.
49. Defendants and their proxies engaged in identity theft, impersonation, false reporting, blacklisting, and defamation, isolating Plaintiff from support systems and rendering her vulnerable to further exploitation. These acts were often executed anonymously or through third parties, preventing Plaintiff from obtaining relief or protection.
50. Technological methods were leveraged as tools of harassment, including email spoofing, facial recognition tracking, account infiltration, and social engineering. These mechanisms were used to manipulate landlords, employers, medical providers, and government agencies into denying Plaintiff access to basic services and civil rights.
51. The sophistication, reach, and consistency of these attacks evidence a high degree of planning and coordinated execution. Over 35 years, this campaign has caused Plaintiff severe and irreparable harm, including:
1. Over $2 million in lost income.
2. Repeated housing displacement and homelessness.
3. Chronic physical injuries and trauma.
4. Diagnosed mental health disorders, including PTSD, anxiety, and depression.
5. Complete erosion of personal security, public reputation, and professional standing.
52. These acts are not only civilly actionable but also constitute criminal violations under federal law, including:
a. 18 U.S.C. § 2261A(2)(A) – Interstate stalking using electronic means causing substantial emotional distress and fear for safety.
b. 18 U.S.C. § 875(d) – Extortion and threats communicated via interstate commerce, including online and telephonic communications.
c. 18 U.S.C. §§ 241 and 242 – Conspiracy to deprive rights and acting under color of law to violate constitutional protections.
d. 42 U.S.C. § 3617 – Interference, coercion, or intimidation against a person exercising their rights under the Fair Housing Act.
53. Despite filing multiple legal complaints, police reports, and formal notices to housing authorities, employers, and regulatory agencies, the retaliation has persisted without meaningful intervention, reflecting a flagrant disregard for lawful authority and the dignity of the Court.
54. The sustained and unmitigated nature of this campaign underscores the need for immediate judicial action. Without intervention from this Court in the form of default judgment, permanent injunctive relief, and criminal referrals, Defendants are likely to continue or escalate their misconduct with impunity.
- Attacks extended into the digital sphere: email spoofing, identity theft, facial recognition tracking, and social engineering were used to manipulate third parties against Plaintiff.
- This 30-year campaign has caused irreversible harm to Plaintiff’s financial condition, safety, dignity, and mental health.
VI. FEDERAL VIOLATIONS
57. Defendants’ conduct may constitute violations of multiple federal statutes:
a. 18 U.S.C. § 2261A(2)(A) Interstate
stalking by electronic means causing emotional distress;
b. 18 U.S.C. § 875(d) Threats and
extortion via electronic communication;
c. 18 U.S.C. §§ 241–242
Conspiracy and deprivation of constitutional rights under color of law;
d. 42 U.S.C. § 3617 – Retaliation
and interference with fair housing rights.
- Despite formal complaints and legal actions, the Defendants have continued their conduct with impunity, reflecting open contempt for the law and this Court.
58. The severity, duration, and scope of this misconduct demands not only civil judgment but possible criminal referral for further investigation.
VII. LEGAL STANDARD FOR DEFAULT JUDGMENT
59. A default judgment is proper under Illinois law when a defendant, after being duly served, fails to plead, answer, or otherwise defend within the prescribed time. The controlling statute provides: “A default judgment may be entered for failure to plead, answer, or otherwise appear.” 735 ILCS 5/2-1301(d)
60. Illinois courts have consistently held that where service has been properly affected and a defendant fails to respond, the allegations in the complaint are deemed admitted by operation of law. See People ex rel. Dep’t of Public Aid v. LeVine, 99 Ill. 2d 146 (1983).
In Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986), the Illinois Supreme Court emphasized that default judgment is appropriate where a party willfully refuses to participate in litigation, and that courts must ensure the integrity of judicial timelines and the plaintiff’s right to a fair adjudication.
61. Furthermore, courts are not required to conduct a hearing on damages where they are ascertainable from the pleadings, affidavits, or other sworn documentation. See Jackson v. Bailey, 384 Ill. App. 3d 546 (1st Dist. 2008). In harmony with Illinois procedure, Federal Rule of Civil Procedure 55(a)—frequently cited as persuasive authority—authorizes entry of default “when a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend.”
62. By failing to file a responsive pleading within the statutory timeframe, Defendants are deemed to have admitted all well-pleaded factual allegations in the Complaint and Amended Complaint. The Court is authorized to enter default and proceed directly to a determination of damages and injunctive relief without further notice or hearing.
63. Here, Plaintiff has filed and served her pleadings in accordance with applicable law, and each named Defendant has been lawfully and properly served, as evidenced by filed and notarized Proofs of Service.
64. None of the Defendants have filed an appearance, moved to dismiss, answered, or requested an extension. Their failure to respond demonstrates deliberate disregard for the judicial process, warranting the entry of judgment.
65. Plaintiff respectfully requests that this Court grant default judgment with prejudice against all named Defendants and proceed to determine compensatory and punitive damages, issue permanent injunctive relief, and order any other equitable relief deemed just and appropriate.
VIII. CASE LAW SUPPORTING DEFAULT JUDGMENT
66. Illinois courts routinely uphold default judgments under similar circumstances. The following authorities confirm the Court’s authority and discretion:
- People ex rel. Dep’t of Public Aid
v. LeVine, 99 Ill. 2d 146 (1983):
The Illinois Supreme Court held that when a party fails to respond after valid service, allegations are admitted, and judgment may proceed without hearing. - Smith v. Airoom, Inc., 114 Ill. 2d
209 (1986):
The Court reinforced that default judgment is appropriate where Defendants delay or disregard proceedings, with emphasis on judicial efficiency and protecting Plaintiff’s rights. - Jackson v. Bailey, 384 Ill. App. 3d
546 (1st Dist. 2008):
The Appellate Court affirmed default where affidavits and documents adequately supported damages, eliminating the need for a prove-up hearing. - Thorp v. Mahoney, 348 Ill. App. 3d
423 (1st Dist. 2004):
The Court affirmed a trial court’s discretion to enter default judgment when a party has failed to appear after proper service, recognizing such conduct as contempt for judicial authority. Taken together, these authorities support entry of default judgment against the Defendants, all of whom have failed to appear despite clear, documented notice and service.
IX. ASSOCIATED CASES OF HARASSMENT, DEFAMATION, AND RETALIATION
67. Plaintiff has been forced to initiate multiple related legal actions due to Defendants’ ongoing pattern of harassment, defamation, stalking, and retaliation, each arising from the same core conspiracy and series of events. These cases reflect a long-standing, coordinated effort to destabilize Plaintiff’s personal and professional life, obstruct legal recourse, and suppress public disclosure of misconduct:
68. 20211300843 – Valentine v. Nails Pretty, Salon Nail – Harassment & Defamation
69. 20211300844 – Valentine v. James Trice Sr., James Trice Jr., BBQ Slab, Tonya Trice Stalking & Retaliation
70. 20231300097 – Valentine v. Theressia Washington – Harassment & Defamation
71. 20221301069 – Valentine v. Shalisa Harvey d/b/a CHA et al. – Stalking & Retaliation
72. 2021L012271 – Valentine v. Ervin Johnson – Defamation & Harassment
73. 2020L012117 – Valentine v. LisaRaye McCoy – Defamation & Stalking
74. 2020L012118 – Valentine v. Theressia Washington – Defamation & Harassment
75. 2021L012270 – Valentine v. Curtis “50 Cent” Jackson – Threats, Intimidation, Harassment
76. These actions collectively document a decades-long campaign of coordinated retaliation, spanning across industries, jurisdictions, and individuals—many of whom share personal or professional affiliations with named Defendants in this matter. The repetition, escalation, and interconnectivity of these cases underscore a shared intent to silence, discredit, and harm Plaintiff through unlawful means.
77. Plaintiff previously filed a $10 million claim in 2008 against Scottie Pippen and affiliated parties for harassment, defamation, and emotional distress, that case cannot be located.
78. In Valentine v. DCFS, No. 1:2010cv04751, Plaintiff sought $33 million in damages stemming from the unlawful seizure of her children, allegedly executed in collusion with Congressman Danny K. Davis and associates of Scottie Pippen. This matter further illustrates the scope and reaches of retaliatory acts committed by individuals linked to this case.
79. This persistent course of conduct culminated in the wrongful death conspiracy involving Plaintiff’s son, Devonte Pippen, and continues through present-day digital harassment, defamation, and interference with Plaintiff’s housing, work, and litigation.
80. Defendants’ refusal to answer or appear in this action despite proper service and notice renders them liable for default judgment. Considering the uncontested evidentiary record and consistent factual allegations, summary judgment is also warranted under 735 ILCS 5/2-1005(c).
81. These related matters, public records, and prior filings constitute corroborative evidence of Defendants coordinated pattern of misconduct and confirm a long-standing conspiracy to destroy Plaintiff’s quality of life, professional prospects, and legal standing. Accordingly, they provide further justification for default judgment with prejudice in the present case.
IX. CLAIMS FOR DAMAGES
82. Plaintiff seeks both compensatory and punitive damages because of the sustained, malicious, and coordinated misconduct by Defendants. The injuries suffered by Plaintiff are vast and multifaceted, including emotional trauma, physical harm, reputational destruction, financial ruin, and housing destabilization, each warranting substantial monetary and equitable relief under state and federal law.
A. Emotional and Psychological Harm
83. Plaintiff suffers from Post-Traumatic Stress Disorder (PTSD), anxiety, depression, and insomnia, all of which have been medically documented and directly attributed to decades of stalking, harassment, and defamation by Defendants.
84. The systematic deprivation of psychological safety, personal dignity, and public credibility has forced Plaintiff to live in fear, withdraw socially, and seek therapeutic intervention to cope with sustained trauma.
85. These emotional injuries have been exacerbated by repeated public ridicule, online defamation, media humiliation, and the re-traumatization inflicted by Defendants’ agents and affiliates using broadcast platforms and digital content as weapons of emotional abuse.
B. Lost Income and Career Damage
86. Due to the Defendants’ direct interference, Plaintiff has lost more than $2 million in income over a 20-year period. Plaintiff was systematically blacklisted, defamed, and disqualified from employment through anonymous complaints, false references, and retaliatory acts.
Specific incidents include:
87. Dun & Bradstreet (2016): Offer rescinded after defamatory background interference.
88. Sutherland Global (2017): Employment terminated before starting date.
89. Inglewood & Santa Monica Police Departments (2019): Plaintiff was blacklisted from civilian roles based on falsified information.
90. DoorDash, Uber Eats, Lyft, HomeAGlow, TakeABreak, Turo, and other gig platforms (2019–2025): Accounts deactivated following orchestrated complaints tied to Defendants.
91. Plaintiff’s professional development and ability to earn income were deliberately obstructed, forcing repeated re-entry into unstable employment sectors with increasing vulnerability to harassment.
C. Defamation and Reputational Injury
92. Defendants engaged in defamation per se, as defined under Illinois law.
See Bryson v. News Am. Publs., Inc., 174 Ill. 2d 77, 88 (1996).
93. Plaintiff was falsely labeled a “stalker,” “groupie,” “mistress,” and “side piece” in national and regional broadcasts, including segments on: CBS, NBC, ABC, WGN, V103, WGCI, ESPN, SportsCenter and various other platforms to slander Plaintiff.
94. Wendy Williams Show (Season 10 Finale) – where Plaintiff’s paternity claims
95. Plaintiff further alleges that Defendants, including but not limited to Larsa Pippen, Lisa Raye McCoy, and their affiliates, colluded with the entertainment program Dish Nation to discreetly undermine and mock Plaintiff’s legal claims.
96. Through mutual associate Shawntae Harris a/k/a Da Brat, Defendants orchestrated the broadcast of a defamatory segment wherein the validity of paternity of Devonte Pippen was publicly questioned, and the credibility of Plaintiff’s documented allegations was openly ridiculed.
97. The segment made veiled references to Plaintiff’s claims and referred to having “receipts,” alluding to private matters not publicly disclosed by Plaintiff, thus evidencing insider coordination and retaliatory motive.
98. This public attack, executed via nationally syndicated media, was part of a broader effort to discredit Plaintiff, suppress litigation, and shield Defendants from public accountability.
99. Defendant orchestrated the Plaintiff’s appearance on The Steve Harvey Show in March 2016 following public pressure from Congressman Bobby Rush, who had called upon the Defendant to accept responsibility and cover the final expenses related to the death of Devonte Pippen.
100. This appearance, which took place around March 16, 2012, was allegedly staged by the Defendant to create the false appearance of accountability while deflecting genuine responsibility for the Plaintiff’s and Devonte’s losses.
101. Defendant invited the Plaintiff to appear on Windy City Live, during which he exploited the death of Devonte Pippen for purposes of humor and entertainment, allegedly to appease his wife, Larsa Pippen.
102. Plaintiff later discovered that the appearance had been orchestrated and staged to gain favor with Mrs. Pippen, further compounding the Plaintiff’s emotional distress and demonstrating a pattern of manipulation and exploitation.
103. Defendant Larsa Pippen has abused her public platform as a cast member on “The Real Housewives of Miami” to exploit, harass, intimidate, and mock the Plaintiff. She has knowingly used her role and public persona to falsely portray the Plaintiff, misrepresent facts, and act out defamatory content for public consumption, thereby causing reputational harm and emotional distress.
104.
These broadcasts were not only defamatory
but served as retaliatory tools to suppress Plaintiff’s litigation and publicly
discredit her credibility and factual allegations.
105. Plaintiff alleges that Defendants Larsa Pippen, Lisa Raye McCoy, and other affiliates conspired to orchestrate these attacks through media manipulation, timed immediately following the filing of prior lawsuits, such as Case No. 20SMSC02014 (Santa Monica Superior Court, August 2019).
106. As a result of this campaign, Plaintiff received death threats, experienced digital harassment, and reasonably feared for her physical safety.
107. False statements were also disseminated to landlords, employers, clients, and legal contacts, resulting in housing denials, job loss, and damage to her business ventures and civic reputation.
D. Physical Harm and Medical Expenses
108. Defendants caused or contributed to several incidents of physical harm, including:
109. Brake line sabotage (2002): Near-death incident involving tampered vehicle safety systems.
110. Carbon monoxide poisoning (2016): Manipulated ventilation system caused loss of consciousness, hospitalization, and neurological injury.
111. Dog attack (2019): Severe leg injuries caused by an animal linked to known associates of Defendants.
112. Physical assault (2020): Resulted in nasal fracture, permanent disfigurement, and emergency surgery.
113. Each incident led to significant medical expenses, permanent injury, and prolonged recovery, further compounding Plaintiff’s physical and financial vulnerability.
E. Housing Instability and Discrimination
114. Plaintiff experienced over 20 retaliatory evictions due to coordinated complaints, false “red flag” reports, and fabricated criminal allegations communicated to housing authorities and property managers.
115. These actions violated Plaintiff’s federally protected rights under the Fair Housing Act, 42 U.S.C. §§ 3601–3619, including Section 3617, which prohibits interference, coercion, or intimidation against individuals exercising housing rights.
116. Defendants’ actions resulted in:
1. Loss of access to rental vouchers and public housing programs.
2. Repeated homelessness across multiple states, including Illinois, Nevada, Arizona, California, Tennessee, Mississippi, and Arkansas.
3. Unlawful interference with housing applications, renewals, and landlord communications.
4. The loss of housing not only created physical insecurity but also exacerbated Plaintiff’s mental health conditions, placed her at risk of further violence, and undermined every effort at recovery.
X. CRIMINAL CONDUCT WARRANTING FEDERAL REFERRALS
117. The pattern of conduct also violates federal criminal laws, warranting referral to the U.S. Attorney’s Office, FBI, and HUD.
A. 18 U.S.C. § 2261A – Interstate Stalking
118. Defendants engaged in surveillance, threats, and harassment causing reasonable fear of death or serious harm across multiple jurisdictions.
B. 18 U.S.C. § 875 – Extortion and Threats
119. Plaintiff was threatened by phone, email, and social media to silence her, disrupt her work, and force her to withdraw legal claims.
C. 42 U.S.C. § 3617 – Housing Interference
120. Plaintiff’s reports of discrimination were met with coercion, lease cancellations, and interference with federally protected housing rights.
D. Conspiracy and Retaliation
121. Defendants acted in concert with agents, legal representatives, and third-party proxies in a deliberate effort to destroy Plaintiff’s livelihood and civil rights, warranting criminal conspiracy charges under 18 U.S.C. §§ 241–242.
XI. COMPELLING GROUNDS FOR RELIEF
122. The allegations establish not merely negligence, but malicious, orchestrated, and enduring harm perpetrated against Plaintiff over three decades.
A. Malicious Intent
123. The volume and pattern of events show that Defendants acted intentionally and with specific goals to suppress and destroy Plaintiff’s career, reputation, safety, and legal standing.
B. Coordinated Retaliation
124. Use of third parties—including media outlets, employers, landlords, and digital platforms—demonstrates sophisticated coordination.
C. Irreparable Harm
125. Plaintiff’s injuries span every facet of her life:
· Over $2 million in lost earnings.
· Lifelong physical and emotional injuries.
· Homelessness and housing instability.
· Lasting reputational harm that impedes recovery.
XII. DAMAGES REQUESTED PER DEFENDANT
126. Plaintiff seeks the following damages, commensurate with each Defendant’s conduct:
· Scottie Pippen – $150 million (rape, stalking, defamation, wrongful death conspiracy).
· Larsa Pippen – $125 million (smear campaigns, housing interference, funding retaliation, collusion and conspiracy to commit murder).
· Carl T. Pippen – $750,000 (rape, threats, intimidation, harassment).
· Melissa Pippen – $250,000 (email-based harassment, aiding interference).
· Jason B. Giller – $24 million (concealment, abuse of legal authority, obstruction of justice).
XIII. CONCLUSION AND REQUESTED RELIEF
127. Defendants were properly served and failed to appear or defend. Their silence constitutes deliberate disregard for judicial authority.
- The Court should enter Default Judgment with Prejudice in favor of Plaintiff pursuant to 735 ILCS 5/2-1301(d) and supported by Jackson v. Hooker, 397 Ill. App. 3d 614 (1st Dist. 2010).
- Based on the severity and
documentation of harm, Plaintiff respectfully requests:
XIV. MONETARY DAMAGES REQUESTED
130. Plaintiff respectfully requests that this Court award the following compensatory and punitive damages against each named Defendant, jointly and/or severally, as appropriate under Illinois law:
· Scottie Pippen – $150,000,000
· Larsa Pippen – $125,000,000
· Carl T. Pippen – $750,000
· Melissa Pippen – $250,000
· Jason B. Giller – $24,000,000
TOTAL DAMAGES SOUGHT: $300,000,000
XV. INJUNCTIVE RELIEF REQUESTED
131. Plaintiff respectfully requests that this Court issue a permanent injunction against all named Defendants, prohibiting them from:
· Contacting Plaintiff directly or indirectly.
· Disseminating any further false or defamatory statements regarding Plaintiff.
· Interfering with Plaintiff’s employment, housing, education, business, or travel.
· Retaining, disclosing, or distributing any private communications, materials, data, or intellectual property belonging to Plaintiff.
132. Plaintiff also seeks an order requiring Defendants to:
· Cease all surveillance, harassment, and retaliatory actions.
· Remove or delete all defamatory content from online platforms, websites, and media channels within their control.
· Return and account for all personal and intellectual property unlawfully retained, accessed, or disseminated.
XVI. CRIMINAL REFERRALS AND FEDERAL INTERVENTION
133. Due to the severity, duration, and multistate nature of Defendants' conduct, Plaintiff requests that this Court formally refer the matter for federal criminal investigation to:
· The U.S. Attorney’s Office for the Northern District of Illinois.
· The Federal Bureau of Investigation (FBI).
· The Civil Rights Division of the U.S. Department of Justice.
· The U.S. Department of Housing and Urban Development (HUD).
134. Plaintiff asserts the record supports probable causes for violations of the following federal statutes:
· 18 U.S.C. § 2261A – Interstate stalking.
· 18 U.S.C. § 875 – Extortion and interstate threats.
· 42 U.S.C. § 3617 – Interference with housing rights.
· 18 U.S.C. §§ 241, 242 – Deprivation of rights under color of law.
· 18 U.S.C. § 371 – Conspiracy to commit offense or defraud the United States.
XVII. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully prays that this Honorable Court:
A. Enter Default Judgment with Prejudice against all named Defendants.
B. Award monetary damages totaling $300,000,000 as set forth in Paragraph 136.
C. Grant permanent injunctive relief barring any further harassment, contact, or interference by Defendants or their agents.
D. Refer this matter for criminal investigation under federal law, including but not limited to 18 U.S.C. §§ 2261A, 875, 241, 242, 371, and 42 U.S.C. § 3617.
E. Award Plaintiff the costs of this action, including service fees, documentation, mailing, and related expenses.
. Grant such other and further relief as this Court deems just, proper, and necessary to ensure Plaintiff’s future safety, well-being, and access to justice.
