CHYVETTE A. VALENTINE,
Plaintiff,
v.
SCOTTIE PIPPEN, LARSA PIPPEN, CARL T. PIPPEN, MELISSA PIPPEN, JASON B. GILLER, ESQ., et al.,
Defendants.
Case No. 2024L002166
Calendar: Judge Maire Aileen Dempsey
Courtroom: 2209
MOTION FOR DEFAULT JUDGMENT WITH PREJUDICE,
PROVE-UP OF DAMAGES,
AND REFERRAL FOR CRIMINAL INVESTIGATION
NOW COMES the Plaintiff, CHYVETTE A. VALENTINE, appearing pro se, pursuant to 735 ILCS 5/2-1301(d), Illinois Supreme Court Rules 181(a) and 219(c), and Rule 55 of the Federal Rules of Civil Procedure (incorporated for persuasive purposes), and respectfully moves this Honorable Court to enter a Default Judgment with Prejudice against Defendants SCOTTIE PIPPEN, LARSA PIPPEN, CARL T. PIPPEN, MELISSA PIPPEN, JASON B. GILLER, for failure to file an appearance, answer, or otherwise defend this action. In support thereof, Plaintiff states as follows:
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; and (d) 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.
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.
8. HISTORY OF HARASSMENT AND DEFAMATION
8. The harassment campaign against Plaintiff has included sustained acts of defamation, character assassination, and psychological torment, executed through both overt actions and covert communication with Plaintiff’s employers, landlords, neighbors, clients, and social contacts.
9. Defendants, individually and through intermediaries, have disseminated false, malicious, and highly damaging claims about Plaintiff, alleging mental instability, criminal conduct, unprofessionalism, and sexual impropriety—none of which have any basis in fact.
10. Such statements were communicated to numerous third parties, including pastors, judges, lawyers, legal aid, business owners, politicians, hiring managers, employers, property managers, neighbors, business associates, gig platforms, investors, other sports figures, entertainers and even law enforcement entities. These defamatory communications were designed to destroy Plaintiff’s credibility, prevent her from obtaining stable housing or employment, and isolate her from sources of support.
11. Defendants repeatedly used false accusations as a tool to instigate retaliatory action against Plaintiff, including employment termination, housing denial or eviction, and denial of public benefits. In several cases, their coordinated efforts resulted in complete disconnection from income sources and displacement from shelter.
12. On multiple occasions, Plaintiff’s personal information—including photos, contact data, and work history—was weaponized in targeted smear campaigns. These attacks often took place via social media platforms, anonymous calls to employers or landlords, and direct confrontations initiated by third parties acting under false pretenses.
13. This deliberate defamation has caused irreparable damage to Plaintiff’s professional reputation, relationships, and mental well-being. Despite submitting formal rebuttals and legal notices to entities involved, the attacks continued, evolving in complexity and reach over the years.
14. The Defendants’ conduct violates state and federal laws prohibiting defamation, stalking, and harassment and further evidences malicious intent to destroy Plaintiff’s quality of life and suppress her legal rights through fear, intimidation, and public disgrace.
15. TIMELINE OF EVENTS (SELECTED HIGHLIGHTS)
15. The following timeline summarizes key incidents that demonstrate the prolonged and escalating nature of the harassment and misconduct directed at Plaintiff by Defendants and their agents.
16. June 11, 2002 – Plaintiff narrowly escaped serious injury or death after discovering that her vehicle’s brake lines had been tampered with. Investigation suggested deliberate sabotage.
17. February 25, 2016 – Plaintiff was found unconscious in her residence due to carbon monoxide poisoning. The incident was later linked to faulty ventilation manipulated by third parties with access, in what Plaintiff believes to be a coordinated attempt on her life. Plaintiff has 12 stiches leaving a permanent scar, and neurological issues.
18. April 19, 2019 – Plaintiff was attacked by a dog in an incident involving a known associate of Defendants. The dog had been trained to attack, and the incident resulted in severe leg injuries requiring medical attention.
19. June 2020 – Plaintiff sustained a broken nose after being assaulted by an individual she later learned had ties to one of the named Defendants. She received emergency treatment and now lives with permanent disfigurement.
20. 2018–2020 – During this period, Plaintiff was rendered homeless multiple times due to retaliatory evictions and stalking behavior that made securing long-term housing impossible.
21. 2024–2025 – Plaintiff’s gig accounts with platforms such as DoorDash, Uber Eats, Lyft, and Turo were deactivated without warning. These disruptions coincided with known incidents of false complaints lodged by third parties with apparent ties to the Defendants.
22. These events represent only a fraction of the sustained efforts by Defendants to destabilize Plaintiff’s life. The documented pattern of conduct spans over two decades and evidences a coordinated strategy of destruction targeting Plaintiff’s livelihood, safety, and well-being.
23. SPECIFIC INCIDENTS OF DEFENDANTS’ MISCONDUCT
23. The following are representative examples of Defendants’ coordinated actions intended to destroy Plaintiff’s economic stability, physical safety, and access to basic life needs. These incidents demonstrate a deliberate and repeated pattern of retaliation and obstruction.
A. Employment Interference
24. Dun & Bradstreet (2016) – Plaintiff was extended an offer for a position paying $75,000 annually. After background interference by a third party referencing defamatory information, the offer was rescinded without explanation.
25. Sutherland Global (2017) – Plaintiff completed all pre-employment steps and was awaiting her start date when she was suddenly informed the position was “no longer available.” Evidence suggests outside interference similar to previous sabotage.
26. Inglewood Police Department (2019) – Plaintiff was blacklisted from consideration for civilian and support roles. Inquiries into her background were reportedly met with “red flag” warnings that were entirely fabricated.
27. Applebee’s (2024) – Plaintiff was terminated after false accusations of misconduct were relayed anonymously to management. She was not allowed to view the complaints or contest the statements made against her.
28. Shaggy’s (2024) – Plaintiff was prevented from working at this location after being recognized by individuals she had previously reported for stalking. Her employer informed her the “environment was no longer safe.”
29. HomeAGlow (2025) – Plaintiff’s account was deactivated without notice after she received five-star reviews from multiple clients. Investigation showed false complaints were filed by fraudulent profiles later traced to known associates of Defendants.
30. TakeABreak Vacations (2025) – Plaintiff was denied compensation and future assignments following a smear campaign targeting her reputation on social media and via anonymous email reports to company leadership.
31. Gig Platforms (2019–2025) – Plaintiff’s accounts on Postmates, DoorDash, Uber Eats, Lyft, and Turo were deactivated. These account closures coincided with orchestrated complaints and identity-based harassment, consistent with tactics used previously.
B. Physical Harm and Attempted Murder
32. Plaintiff has been the target of multiple attempts on her life and sustained serious injuries as a result of Defendants’ interference and criminal conduct.
33. Brake sabotage (2002) – Tampering of Plaintiff’s vehicle brake lines endangered her life and was never fully investigated due to outside interference.
34. Carbon monoxide poisoning (2016) – The dangerous manipulation of ventilation systems in Plaintiff’s home created life-threatening conditions.
35. Physical assaults (2019 to Present) – Attacks resulted in broken bones and long-term disfigurement. Police reports were filed but investigations were obstructed by individuals with ties to Defendants.
C. Housing Discrimination
36. Plaintiff has suffered over 12 retaliatory evictions between 2006 and 2025, each following either formal complaints about misconduct or efforts to escape harassment.
37. Landlords and property managers were routinely contacted and pressured to deny or terminate Plaintiff’s leases. Anonymous letters and calls often referenced false accusations of criminal behavior or “red flag” warnings.
38. The Fair Housing Act, 42 U.S.C. §§ 3601–3619, explicitly prohibits housing discrimination and retaliation against individuals reporting misconduct. Plaintiff’s eviction history reveals a pattern of abuse in violation of this federal statute.
39. Plaintiff’s eligibility for subsidized housing and rental voucher programs was similarly targeted. Applications were delayed, blocked, or tampered with, further destabilizing her living conditions.
40. ONGOING NATURE OF HARASSMENT CAMPAIGN
40. The conduct of Defendants constitutes a deliberate, unrelenting, and escalating pattern of harassment, targeting nearly every facet of Plaintiff’s life. This misconduct spans from economic sabotage and physical danger to psychological abuse and reputational destruction.
41. Each time Plaintiff obtained housing, employment, or medical assistance, coordinated efforts by known and unknown parties associated with Defendants undermined those gains.
42. Plaintiff’s relocation across multiple states—Illinois, California, Nevada, Arizona, Tennessee, Mississippi, and Arkansas—did not deter Defendants’ coordinated attacks. Instead, harassment adapted and followed, aided by unlawful surveillance and digital tracking.
43. Defendants, directly and through their agents, engaged in impersonation, false reporting, smear campaigns, and blacklisting tactics, designed to alienate Plaintiff from basic support systems.
44. Plaintiff was not only victimized through direct contact but through indirect, technologically driven means: identity theft, email spoofing, facial recognition tracking, and social engineering used to manipulate third parties into acting against her interests.
45. The campaign has demonstrated a high degree of organization, intent, and persistence over more than 30 years, culminating in repeated, devastating harm to Plaintiff’s financial status, physical safety, personal dignity, and mental health.
46. These actions violate several federal criminal statutes, including:
a. 18 U.S.C. § 2261A(2)(A) – Interstate stalking using electronic means, including surveillance and causing substantial emotional distress.
b. 18 U.S.C. § 875(d) – Extortion and threats intended to cause injury and loss via digital and verbal communications.
c. 18 U.S.C. § 241 & § 242 – Conspiracy to deprive constitutional rights and acting under color of law to violate civil rights.
d. 42 U.S.C. § 3617 – Interference, coercion, or intimidation in relation to housing rights.
47. Despite multiple complaints, legal filings, and reports to federal and local agencies, Defendants’ conduct has continued, displaying open contempt for the law and this Court’s authority.
48. The sustained nature of this campaign underscores the urgency and necessity of both civil judgment and criminal referral. Without judicial intervention, the campaign is likely to persist or intensify.
49. LEGAL STANDARD FOR DEFAULT JUDGMENT
49. A default judgment is proper under Illinois law when a defendant fails to plead, answer, or otherwise defend after being duly served. The statute provides that:
“A default judgment may be entered for failure to plead, answer, or otherwise appear.”
– 735 ILCS 5/2-1301(d)
50. Illinois courts have consistently held that where service has been properly made and the defendant fails to respond, the allegations in the complaint are taken as true. See People ex rel. Dep’t of Public Aid v. LeVine, 99 Ill. 2d 146 (1983).
51. In Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986), the Illinois Supreme Court emphasized that default is appropriate to prevent delay and maintain judicial efficiency when a party willfully refuses to participate.
52. Illinois courts require no evidentiary hearing when the damages are ascertainable from the pleadings or a sworn affidavit. See Jackson v. Bailey, 384 Ill. App. 3d 546 (1st Dist. 2008).
53. Under Rule 55(a) of the Federal Rules of Civil Procedure (mirrored in Illinois standards), default may be entered against any party who "has failed to plead or otherwise defend."
54. By failing to respond within the time required by law, Defendants are deemed to have admitted all well-pleaded factual allegations. The Court may proceed to enter default and determine appropriate relief without further notice.
55. Here, all Defendants were properly served, as documented in filed proofs of service. None have entered an appearance, moved for an extension, or filed any response.
56. Accordingly, this Court should grant Plaintiff’s motion for default judgment and proceed to award damages and injunctive relief as requested.
#63. CASE LAW SUPPORTING DEFAULT JUDGMENT
#64. Illinois courts have consistently upheld the entry of default judgment when a defendant has been properly served and fails to respond within the statutory period. The following cases support this standard:
#65. People ex rel. Dep’t of Public Aid v. LeVine, 99 Ill. 2d 146 (1983):
The Illinois Supreme Court held that when a defendant does not answer a complaint after proper service, the allegations are admitted by default. This case underscores the principle that a default serves as a procedural mechanism to preserve the integrity of court timelines and plaintiff rights.
#66. Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986):
In this case, the Court reinforced that failure to respond after valid service warrants a default judgment, especially where defendants deliberately delay or neglect proceedings. The Court emphasized judicial efficiency and fairness to plaintiffs.
#67. Jackson v. Bailey, 384 Ill. App. 3d 546 (1st Dist. 2008):
The Appellate Court affirmed a default judgment entered after a party failed to respond. The Court also held that when damages are supported by affidavits and documentation, a prove-up hearing may be unnecessary.
#68. Thorp v. Mahoney, 348 Ill. App. 3d 423 (1st Dist. 2004):
This case affirms that a trial court has discretion to enter a default judgment when defendants fail to appear. The court noted that prolonged non-responsiveness, despite proper service, evidences contempt for judicial authority.
#69. Taken together, these precedents support Plaintiff’s motion and establish that this Court may grant relief in full, without further delay or notice to Defendants who have failed to participate.
#70. ASSOCIATED CASES OF HARASSMENT, DEFAMATION, AND RETALIATION
#71. Plaintiff has been forced to file multiple legal actions due to Defendants' ongoing harassment, defamation, and retaliatory actions.
#72. 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.
#73. Plaintiff filed a $10 million claim in 2008 against Defendants for harassment, defamation, and damages.
#74. On August 8, 2008, while attempting to establish Scottie Pippen’s paternity, Plaintiff’s children were illegally seized in collusion with Congressman Danny K. Davis, as outlined in Valentine v. DCFS, 1:2010cv04751 (seeking $33 million in damages).
#75. Since that time, Defendants have escalated their efforts to destroy Plaintiff’s life, career, housing, and safety, including a wrongful death conspiracy involving Devonte Pippen.
#76. 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).
#77. These cases further demonstrate the pattern of misconduct involving Jason Giller and his co-conspirators, confirming repeated unlawful actions by and on behalf of Defendants.
#78. Related Civil and Criminal Actions Filed by Plaintiff
#79. 20211300843 – Valentine v. Nails Pretty, Salon Nail – Harassment & Defamation
#80. 20211300844 – Valentine v. James Trice Sr., James Trice Jr., BBQ Slab, Tonya Trice – Stalking & Retaliation
#81. 20231300097 – Valentine v. Theressia Washington – Harassment & Defamation
#82. 20221301069 – Valentine v. Shalisa Harvey d/b/a CHA et al. – Stalking & Retaliation
#83. 2021L012271 – Valentine v. Ervin Johnson – Defamation & Harassment
#84. 2020L012117 – Valentine v. LisaRaye McCoy – Defamation & Stalking
#85. 2020L012118 – Valentine v. Theressia Washington – Defamation & Harassment
#86. 2021L012270 – Valentine v. Curtis “50 Cent” Jackson – Threats, Intimidation, Harassment
#87. These cases confirm an ongoing, targeted, and coordinated pattern of misconduct involving the Defendants and their associates.
#88. Accordingly, Plaintiff urges this Court to consider these related matters as corroborative evidence of the Defendants’ continuing unlawful conduct and enter a Default Judgment in Plaintiff’s favor with prejudice.
#89. CLAIMS FOR DAMAGES
89. Plaintiff seeks compensatory and punitive damages stemming from the Defendants’ sustained and malicious course of conduct. The nature and scope of harm inflicted include emotional trauma, financial devastation, reputational damage, and physical injury—all of which warrant significant monetary relief.
A. Emotional and Psychological Harm
90. Plaintiff has endured extreme psychological distress, including but not limited to Post-Traumatic Stress Disorder (PTSD), anxiety, depression, and insomnia, directly resulting from Defendants’ conduct.
91. Defendants’ relentless harassment and stalking campaigns created a climate of fear and instability that deprived Plaintiff of basic peace, dignity, and safety.
92. Plaintiff has been forced to live in hiding, avoid public exposure, and seek therapeutic intervention due to the psychological impact of years of abuse and targeted attacks.
B. Lost Income and Career Damage
93. Defendants interfered with Plaintiff’s employment and career progression over multiple years and industries, depriving Plaintiff of professional growth and stability.
94. Plaintiff estimates a loss exceeding $2 million in career earnings over the past 20 years, including rescinded job offers, terminations under false pretenses, and blacklisting from employment databases.
95. Specific examples include positions with Dun & Bradstreet (2016), Sutherland Global (2017), Inglewood Police Department (2019), Santa Monica Police (2019), and various gig economy platforms including DoorDash, Uber Eats, Lyft, and Turo. Since March 2025 Plaintiff has been deactivated and/or terminated by HomeAGlow and TakeABreak due to stalking activities.
C. Defamation and Reputational Injury
96. Defendants engaged in systematic smear campaigns, both online and offline, designed to tarnish Plaintiff’s credibility, personal brand, and professional reputation.
97. Defendants engaged in a coordinated media smear campaign, violating Illinois defamation per se laws (Bryson v. News Am. Publs., Inc., 174 Ill. 2d 77, 88 (1996)). CBS, NBC, ABC, WGN, V103, and WGCI falsely labeled Plaintiff a “stalker” and “groupie.” The Wendy Williams Show (Season 10 Finale) falsely claimed Plaintiff was Scottie Pippen’s “mistress” and mocked her paternity fraud allegations (Stevens v. Tillman, 855 F.2d 394, 400 (7th Cir. 1988)). A YouTube video titled "Scottie Pippen’s 8 Kids & MESSY Dating History" contains defamatory statements about Plaintiff. Windy City Live and The Steve Harvey Show knowingly broadcast false claims to damage Plaintiff’s reputation.
98. False claims were made to prospective employers, clients, and landlords, resulting in Plaintiff being labeled as unstable, unreliable, or unsafe, despite a clean legal and professional record.
99. Plaintiff continues to suffer reputational fallout that affects employment, housing, and personal relationships.
D. Physical Harm and Medical Expenses
100. Defendants caused or contributed to several incidents of physical harm, including:
a. Brake line tampering in 2002 resulting in near-death;
b. Carbon monoxide poisoning in 2016 requiring hospitalization;
c. Dog attack in 2019 causing facial trauma;
d. Assault in 2020 causing nasal fracture requiring surgery.
101. These incidents resulted in substantial medical bills, long-term health consequences, and ongoing physical pain and suffering.
E. Housing Instability and Discrimination
102. Plaintiff has been forcibly displaced over a dozen times due to orchestrated harassment and discriminatory housing practices in violation of the Fair Housing Act, 42 U.S.C. §§ 3601–3619.
103. Retaliatory evictions occurred after Plaintiff reported stalking or abuse, destroying housing voucher access and causing prolonged homelessness.
104. In several instances, landlords were contacted by unknown third parties tied to Defendants and persuaded to cancel lease agreements or issue unlawful notices.
#105. CRIMINAL CONDUCT WARRANTING FEDERAL REFERRALS
105. In addition to civil violations, the conduct by Defendants includes multiple violations of federal criminal statutes. These actions rise to the level of criminal misconduct and should be referred to appropriate federal authorities for investigation and prosecution.
106. Defendants’ pattern of conduct meets the statutory requirements of interstate stalking, extortion, and interference with federally protected rights, among other crimes.
A. Violation of 18 U.S.C. § 2261A – Interstate Stalking
107. Defendants knowingly engaged in a course of conduct that placed Plaintiff in reasonable fear of death or serious bodily injury.
108. This conduct included physical tracking, online harassment, coordinated third-party surveillance, and repeated interference with housing and employment across state lines.
109. Plaintiff was forced to relocate multiple times due to ongoing threats and intimidation that followed her across jurisdictions, satisfying the “interstate” requirement of the statute.
B. Violation of 18 U.S.C. § 875 – Extortion and Threats
110. Plaintiff received repeated threats to her safety and well-being, both directly and through intermediaries.
111. Defendants used fear and intimidation to force Plaintiff to abandon employment opportunities, withdraw from legal claims, and remain silent about misconduct.
112. These threats were communicated via phone, email, and social media platforms—methods governed under federal jurisdiction.
C. Violation of 42 U.S.C. § 3617 – Interference with Housing Rights
113. Defendants engaged in actions intended to intimidate, threaten, and interfere with Plaintiff’s housing rights because of her exercise of rights under the Fair Housing Act.
114. Plaintiff was evicted or forced to move repeatedly after reporting discrimination, harassment, or dangerous conditions.
115. Landlords, property managers, and housing programs were influenced or coerced by agents associated with Defendants, disrupting Plaintiff’s ability to obtain safe and stable housing.
D. Coordinated Conspiracy and Retaliation
116. Defendants operated through a network of associates, employees, and third-party actors, demonstrating a deliberate and organized plan of retaliation and suppression.
117. The conduct was not isolated or spontaneous, but part of a sustained campaign to destroy Plaintiff’s livelihood, safety, and credibility.
118. Because of the serious and continuing nature of these violations, this Court should refer the matter to the U.S. Attorney’s Office, the Federal Bureau of Investigation, and the Department of Housing and Urban Development (HUD) for criminal investigation.
#119. COMPELLING GROUNDS FOR RELIEF
119. The Plaintiff has demonstrated through detailed allegations and supporting facts that the Defendants have engaged in a longstanding, malicious campaign designed to destroy every area of her life, including her safety, financial stability, and emotional well-being.
120. The scope and scale of the harm suffered by Plaintiff justifies not only compensatory and punitive damages but also judicial intervention to prevent further abuse.
A. Pattern of Malicious Intent
121. Defendants’ actions were not accidental or negligent—they were targeted, repeated, and sustained over decades.
122. Each incident documented in this Motion is part of a broader pattern of behavior that demonstrates clear intent to harm, silence, discredit, and destabilize the Plaintiff.
123. This includes coordinated use of false reports, public defamation, sabotage of career and housing prospects, and direct acts of violence or intimidation.
B. Coordinated Multi-Party Retaliation
124. Defendants acted through agents, associates, and proxies across industries and jurisdictions.
125. The use of third parties to carry out harassment, including employers, landlords, social media platforms, and law enforcement contacts, demonstrates a high level of planning and coordination.
126. This broad network of retaliation warrants the application of conspiracy principles in both civil and criminal contexts.
C. Impact Across All Areas of Plaintiff’s Life
127. The cumulative harm inflicted upon Plaintiff is vast:
a. Over $2 million in lost income and professional opportunities;
b. Physical injuries requiring medical attention;
c. Psychological trauma diagnosed as PTSD, anxiety, and depression;
d. Loss of housing security resulting in homelessness and fear for personal safety;
e. Irreparable reputational damage affecting her employability and social standing.
128. The documented interference with housing rights, employment access, and daily mobility leaves Plaintiff with limited or no alternatives for relief outside of this judicial forum.
D. Criminal Violations Alongside Civil Damages
129. In addition to emotional distress, economic losses, and reputational harm, the violations implicate serious breaches of federal law.
130. The interplay of civil injury and criminal misconduct strengthens the necessity of a comprehensive remedy that includes referrals for criminal prosecution.
131. Without relief, Plaintiff remains vulnerable to continued retaliation and harm, despite multiple relocations, law enforcement reports, and self-advocacy.
#132. DAMAGES REQUESTED PER DEFENDANT
132. Plaintiff seeks the following compensatory and punitive damages from each named Defendant:
a. Scottie Pippen – $150 million, for decades of targeted abuse, defamation, stalking, retaliation, and physical harm;
b. Larsa Pippen – $125 million, for participating in and financing smear campaigns, housing interference, and reputational destruction;
c. Carl T. Pippen – $1 million, for his role in intimidation, threats, and conspiracy;
d. Melissa Pippen – $250,000, for aiding and abetting harassment and unlawful retaliation;
e. Jason B. Giller – $24 million, for colluding with other Defendants, concealing financial assets, abusing his legal authority, and aiding the cover-up of Devonte Pippen’s wrongful death.
#133. CONCLUSION AND REQUESTED RELIEF
133. For the reasons set forth herein, Plaintiff respectfully requests that this Court enter Default Judgment With Prejudice against the named Defendants for failure to answer, respond, or otherwise appear in this matter, despite proper service, lawful notice, and substantial time afforded to defend.
134. Plaintiff has set forth well-pleaded factual allegations and legal causes of action demonstrating entitlement to default judgment under 735 ILCS 5/2-1301(d) and applicable case law, including Jackson v. Hooker, 397 Ill. App. 3d 614 (1st Dist. 2010).
135. In light of the egregious and unremedied harm suffered, the Court is respectfully urged to enter a judgment that includes the following monetary damages, injunctive relief, and federal criminal referrals:
#136. MONETARY DAMAGES REQUESTED
#136. Plaintiff respectfully requests that this Court award the following compensatory and punitive damages against each Defendant, jointly and/or severally as determined appropriate:
-
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
#137. INJUNCTIVE RELIEF REQUESTED
137. Plaintiff respectfully requests that this Court enter a permanent injunction barring all Defendants from:
-
Contacting Plaintiff directly or through third parties;
-
Disseminating any further false or defamatory statements about Plaintiff;
-
Interfering with Plaintiff’s employment, housing, business, travel, or educational pursuits;
-
Possessing or distributing any private materials, data, recordings, or communications involving the Plaintiff.
138. Plaintiff also seeks an order requiring Defendants to immediately:
-
Cease all surveillance, harassment, and retaliatory actions;
-
Remove defamatory content from social media, websites, or publications within their control;
-
Provide a full accounting and return of any private property or intellectual materials unlawfully retained.
#139. CRIMINAL REFERRALS AND FEDERAL INTERVENTION
139. Given the severe and ongoing nature of the conduct described in this Motion, Plaintiff respectfully requests this Court refer the matter 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; and
-
The U.S. Department of Housing and Urban Development (HUD).
140. Plaintiff asserts that the record supports probable cause for investigation of violations under:
-
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 and § 242 (Deprivation of Rights Under Color of Law);
-
18 U.S.C. § 371 (Conspiracy to Commit Offense or Defraud the United States).
#141. 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 $300,250,000 as specified above;
C. Grant permanent injunctive relief enjoining Defendants from further harassment, interference, or contact with Plaintiff;
D. Refer this matter for federal criminal investigation under applicable U.S. Code provisions;
E. Award costs of this action, including fees associated with process serving, document preparation, and mailing;
F. Grant such other and further relief as the Court deems just, proper, and necessary to protect Plaintiff’s rights and ensure future safety and justice.
