PLEASE SHOW ME A NOTICE OF MOTION PLEASE!!! The timeline goes from April 7, 2025 "Continuance" to May 2, 2025 "Dismissal"

IN THE APPELLATE COURT OF ILLINOIS
FIRST JUDICIAL DISTRICT

 

CHYVETTE A. VALENTINE,

Plaintiff-Appellant,

v.

SCOTTIE PIPPEN, LARSA PIPPEN, CARL T. PIPPEN, MELISSA PIPPEN, JASON GILLER, et al.,

Defendants-Appellees.

Case No.: 2024L002166

Calendar: Judge Maire Aileen Dempsey

Courtroom: 2209

 

NOTICE OF APPEAL

1. Plaintiff-Appellant, CHYVETTE A. VALENTINE, respectfully appeals to the Illinois Appellate Court, First Judicial District, from the Dismissal for Want of Prosecution (DWP) entered on May 2, 2025, by Judge Kathy M. Flanagan, who was not the assigned judge of record.
2. The case remains assigned to Judge Maire A. Dempsey in Courtroom 2209, where Plaintiff has consistently complied with all scheduling orders.
3. This appeal is brought pursuant to Illinois Supreme Court Rules 301 and 303(a) and is based on the following constitutional, procedural, and ethical violations:

3.1. Improper dismissal without notice, motion, or hearing;

3.2. Unauthorized participation by unregistered counsel without filed appearances, violating Illinois Supreme Court Rule 13(c);

3.3. Jurisdictional overreach by a judge not assigned to the case;

3.4. Retaliatory order striking all future court dates entered on June 16, 2025;

3.5. Active Motion for Default Judgment and Prove-Up of Damages was scheduled for hearing on May 22, 2025;

3.6. Courtroom threats and intimidation documented by Plaintiff;

3.7. Denial of Zoom access to Plaintiff on June 2, 2025, further indicating bias and exclusion.

FACTUAL BACKGROUND & PROCEDURAL POSTURE

4. Service of Process:

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

4.2. Defendant Jason Giller acknowledged receipt via email on October 13, 2024, confirming actual notice.

5. Defendants' Default:

5.1. No appearance, answer, or motion was filed by any Defendant.

5.2. Under Illinois Supreme Court Rule 181(a), default judgment was procedurally proper.

6. Jurisdictional Breach by Judge Flanagan:

6.1. On May 2, 2025, Judge Flanagan entered a DWP without notice, assignment, or hearing.

6.2. This was not a scheduled hearing before the assigned judge, Judge Maire Dempsey.

6.3. On June 2, 2025, Plaintiff was denied Zoom access to court—further evidence of prejudice and bias.

7. Pending Motions Ignored:

7.1. An Amended Motion to Vacate the DWP was filed, asserting due process violations.

7.2. An Amended Motion to Increase Damages to $350 Million was filed, supported by the following new acts of harm on May 15, 2025:

    7.2.1. Termination of employment;

    7.2.2. Disconnection of utilities;

    7.2.3. Continued harassment and intimidation.

LEGAL ARGUMENT

8. Default Judgment Was Legally Appropriate

8.1. Under 735 ILCS 5/2-1301(d) and Supreme Court Rule 181, default is appropriate when no appearance is entered.

8.2. See Vision Point of Sale, Inc. v. Haas, 226 Ill. 2d 334 (2007);

8.3. See also Bank of N.Y. Mellon v. Karbowski, 2014 IL App (1st) 130112.

9. Judge Flanagan Acted Without Jurisdiction

9.1. As held in People ex rel. Reid v. Adkins, 48 Ill. App. 3d 598 (1st Dist. 1977), non-assigned judges lack authority to issue dispositive rulings.

9.2. The May 2, 2025 DWP is void ab initio.

9.3. This action violated U.S. Const. amend. XIV and Ill. Const. art. I, § 2.

10. Due Process Requires Hearing on Damages

10.1. Plaintiff had a prove-up hearing scheduled for May 22, 2025 pursuant to 735 ILCS 5/2-604.

10.2. See Collins v. Roseland Comm. Hosp., 2017 IL App (1st) 160559.

11. Motion to Vacate Was Timely and Proper

11.1. Filed under 735 ILCS 5/2-1301(e), the motion satisfies all legal criteria for vacatur:

                         11.1.1. Lack of notice;

                        11.1.2. Unlawful judicial conduct;

                         11.1.3. No attorney of record for Defendants.

12. New Material Harm Warrants Increased Damages         

12.1. See Bryson v. News Am. Publs., 174 Ill. 2d 77 (1996);

12.2. See Fellhauer v. City of Geneva, 142 Ill. 2d 495 (1991).

12.3. The conduct justifies punitive damages due to its malicious and retaliatory nature.

 

JUDICIAL MISCONDUCT COMPLAINT

13. This complaint is filed under Illinois Supreme Court Rule 63 (Canon 3) and alleges the following:

13.1. Judge Flanagan was not assigned to the matter yet issued a dispositive ruling.

13.2. No Defendants appeared, and Plaintiff received no notice.

13.3. Court procedures were circumvented to issue an unauthorized DWP.

13.4. Plaintiff was prevented from appearing via Zoom on June 2, 2025.

13.5. Alleged judicial bias and external interference constitute misconduct.

14. Plaintiff further alleges a pattern of collusion and political interference, including actions by Defendant Scottie Pippen:

14.1. Exploiting political relationships to impair Plaintiff’s housing, employment, legal access, and public credibility.

14.2. Targeting pastors, judges, employers, influencers, and law enforcement to socially and financially isolate Plaintiff.

 

RELIEF REQUESTED

15. Plaintiff respectfully requests the following relief:

15.1. Reversal of the May 2, 2025 DWP and June 16, 2025 retaliatory order;

15.2. Reinstatement of the Complaint and hearing on all pending motions;

15.3. Declaration that the DWP is void ab initio;

15.4. Referral of Judge Flanagan’s conduct to the Judicial Inquiry Board;

15.5. Hearing or grant of Plaintiff’s $350 Million Amended Motion for Damages;

15.6. Independent investigation by the Judicial Inquiry Board into unauthorized judicial conduct;

15.7. Public acknowledgment of violations and procedural safeguards;

15.8. Any additional relief deemed just and proper by this Court.

Respectfully submitted,
/s/ Chyvette A. Valentine
Chyvette A. Valentine, Pro Se