IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOISCOUNTY DEPARTMENT – LAW DIVISION
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
Plaintiff-Appellant, CHYVETTE A. VALENTINE, hereby 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. This appeal arises from a series of judicial and procedural irregularities that deprived Plaintiff of due process and lawful adjudication, including:
Dismissal without notice or motion from Defendants;
No attorney of record for any Defendant at the time of dismissal;
Improper judicial interference by a judge not assigned to the case;
Pending Motion for Default Judgment and Prove-Up of Damages, set for May 22, 2025;
Retaliatory order striking future court dates on June 16, 2025;
Improper ex parte actions and courtroom threats documented by Plaintiff.
This appeal is filed pursuant to Illinois Supreme Court Rules 301 and 303(a).
FACTUAL BACKGROUND & PROCEDURAL POSTURE
Plaintiff served Scottie Pippen via the Los Angeles County Sheriff on December 18, 2024.
Jason Giller, registered agent for Scottie and Larsa Pippen, acknowledged receipt by email on October 13, 2024, confirming actual notice.
Plaintiff maintained active communication with multiple members of the Pippen family, including Larsa Youkhana Pippen, indicating knowledge and avoidance by Defendants.
Despite these facts, no appearance or answer was filed by any Defendant within 30 days, as required by Illinois Supreme Court Rule 181(a).
Plaintiff filed Proof of Service on April 4, 2025 but was unable to communicate with the clerk or judge due to lack of access to court email systems.
Plaintiff acknowledges that a military affidavit under the Servicemembers Civil Relief Act (50 U.S.C. § 3931) was not yet filed, and intends to file it forthwith.
On May 2, 2025, Judge Kathy M. Flanagan dismissed the matter without assignment, notice, or hearing—despite no appearance by Defendants or formal representation.
On June 16, 2025, Judge Flanagan entered a retaliatory order striking all future court appearances.
Meanwhile, Plaintiff had filed:
An Amended Emergency Motion to Vacate the DWP, based on lack of notice, no Defendant appearance, absence of counsel, and threats made in open court;
An Amended Motion to Increase Damages to $350 Million, reflecting new acts of economic sabotage, stalking, utility disconnection, and employment termination, all occurring on May 15, 2025, the same day Plaintiff was originally scheduled for default prove-up.
LEGAL ARGUMENT
A. Entry of Default Was Procedurally Proper
Under 735 ILCS 5/2-1301(d) and Illinois Supreme Court Rule 181, default is proper where no appearance or answer is filed within 30 days.
In Vision Point of Sale, Inc. v. Haas, 226 Ill. 2d 334 (2007),** the Illinois Supreme Court held that all well-pleaded allegations are deemed admitted upon default.
In Bank of New York Mellon v. Karbowski, 2014 IL App (1st) 130112, the Appellate Court affirmed default and vacated trial court dismissal when procedural rules were followed by the plaintiff.
B. Judge Flanagan Lacked Jurisdiction to Enter Dismissal
Per People ex rel. Reid v. Adkins, 48 Ill. App. 3d 598 (1st Dist. 1977), judges are without authority to issue dispositive rulings outside their assignment.
Plaintiff’s case was assigned to Judge Maire A. Dempsey, not Judge Flanagan.
The May 2, 2025 DWP order was therefore entered ultra vires—without lawful jurisdiction—and is void ab initio.
Entry of judgment or dismissal without notice or a hearing violates constitutional due process under U.S. Const. amend. XIV and Ill. Const. art. I, § 2.
C. Plaintiff Was Entitled to a Hearing on Damages
Under 735 ILCS 5/2-604, plaintiffs are entitled to prove-up hearings following default.
In Collins v. Roseland Comm. Hospital, 2017 IL App (1st) 160559, the court held a trial judge must allow evidence of damages before dismissing a pending motion.
D. Amended Emergency Motion to Vacate Was Timely and Legally Sound
The Amended Emergency Motion to Vacate properly identified procedural errors and threats in court.
The motion was supported by Illinois Supreme Court Rule 2-1301(e) allowing courts to vacate dismissals to promote justice.
Plaintiff was never served with notice of the May 2 hearing and was actively pursuing her motion for default at the time.
E. Amended Motion to Increase Damages Was Based on New, Material Harm
Plaintiff’s Amended Motion to Increase Damages to $350 Million was supported by:
Termination of employment;
Disconnection of utilities;
New threats and intimidation;
Continued harassment consistent with the conduct pled in the Complaint;
The pattern satisfies standards for punitive damages under Illinois law, where malicious conduct is ongoing and intentional.
See Bryson v. News Am. Publs., Inc., 174 Ill. 2d 77 (1996) (defamation per se and reputational harm), and Fellhauer v. City of Geneva, 142 Ill. 2d 495 (1991) (economic interference).
RELIEF REQUESTED
Plaintiff-Appellant respectfully prays that the Illinois Appellate Court, First District:
Reverse the May 2, 2025 Dismissal for Want of Prosecution, and the June 16, 2025 retaliatory order;
Remand to the trial court with instructions to reinstate the Complaint and hear the Motion for Default Judgment with Prove-Up of Damages;
Declare the DWP void ab initio for lack of judicial authority and procedural error;
Grant Plaintiff’s Amended Motion to Increase Damages to $350 Million, or remand for a full hearing;
Refer Judge Flanagan’s actions to the Judicial Inquiry Board pursuant to Illinois Supreme Court Rule 63 (Canon 3);
Grant any other relief deemed just, equitable, and necessary.
