Hilton Grand Vacations
Attn: Legal Department / Team Member Relations
5555 Badura Avenue, Suite 160
Las Vegas, NV 89118
Pleshette Roberts-Robinson
8057 Windmill Villa Street
Las Vegas, NV 89139
From:
Chyvette A. Valentine
P.O. Box 93832
Las Vegas, NV 89199
Bcc: Media from Pippen Case 2024L002166
To Whom It May Concern:
This letter serves as a formal settlement offer regarding the claims arising from my employment at Hilton Grand Vacations (HGV) located at 5555 Badura Avenue, Las Vegas, NV 89118, and the conduct of Pleshette Roberts-Robinson, which resulted in defamation, harassment, coercion, emotional distress, and retaliatory termination.
Based on a comprehensive review of the facts, documented evidence, and the applicable Nevada statutes and case law, I am seriously considering filing an amended action in District Court, which allows for substantially higher damages, including punitive damages and attorney fees.
However, before proceeding with escalated litigation, I am extending this opportunity for voluntary settlement.
I. PRIMARY LEGAL CLAIMS
1. DEFAMATION & SLANDER (Roberts-Robinson)
False statement of fact
Publication to third party
Fault (negligence or disregard for truth)
Damages
Nevada Law Supporting Liability:
• Pope v. Motel 6, 121 Nev. 307 (2005) – False statements harming employment reputation are actionable.
• Bull v. McCuskey, 96 Nev. 706 (1980) – Publication to third parties establishes defamation.
• NRS 200.510 – Criminal slander statute; supports civil liability.
Evidence includes:
• False statements that Plaintiff was “HIV-positive.”
• False allegations that Plaintiff harassed or stalked her.
• False statements communicated to co-workers, supervisors, and external third parties including individuals outside HGV.
This constitutes defamation per se, meaning damages are presumed.
2. RETALIATION – NRS 613.340 (Against HGV)
Retaliation requires:
Protected activity (harassment complaint to HR)
Adverse action (termination)
Causal connection (temporal proximity)
Proven Timeline:
• August 18, 2025 – Formal HR complaint filed.
• September 30, 2025 – Terminated.
• 43 days between complaint and termination.
• Termination was based solely on a complaint from the person I reported.
Nevada Case Law:
• Sands Regent v. Valgardson, 105 Nev. 436 (1989) – Failure to address harassment creates liability.
• Dillard Dept. Stores v. Beckwith, 115 Nev. 372 (1999) – Close timing supports retaliation.
This claim alone could justify tens of thousands in District Court.
3. HOSTILE WORK ENVIRONMENT (HGV & Roberts-Robinson)
Nevada & Federal Support:
• NRS 613.330 – Unlawful employment practices.
• Seng v. State, 131 Nev. Adv. Op. 19 (2015) – Nevada adopts Title VII hostile environment standards.
• Little v. Windermere, 301 F.3d 958 (9th Cir.) – Employer liable when failing to remedy harassment.
Supporting Facts:
• Sexual discussions and inappropriate propositions.
• Aggressive behavior on the call floor.
• Continuous harassment and text messages.
• Failure to separate Plaintiff from aggressor despite repeated HR reports.
4. COERCION – NRS 200.550 (Roberts-Robinson)
Coercion includes threats, intimidation, or actions intended to compel or prevent lawful behavior.
Evidence:
• Threats to file false HR reports.
• Harassing Plaintiff during medical emergency.
• Attempting to intimidate Plaintiff into silence.
5. NEGLIGENT SUPERVISION – HGV
• Barmettler v. Reno Air, 114 Nev. 441 (1998) – Employers liable for failure to supervise known risks.
HGV:
• Failed to address multiple documented complaints.
• Assigned an unstable employee as a “training buddy.”
• Allowed ongoing harassment and violations.
• Terminated Plaintiff rather than address wrongdoing.
6. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Roberts-Robinson)
Nevada requires:
• Extreme and outrageous conduct
• Intent or reckless disregard
• Emotional distress actually suffered
Roberts-Robinson’s behavior especially during medical emergency meets the standard.
II. SETTLEMENT DEMAND
To avoid District Court escalation, media exposure, and potential attorney fees, I extend the following settlement terms:
Settlement Amount:
$10,000 payable jointly by:
Hilton Grand Vacations
Pleshette Roberts-Robinson
Plus:
• Reimbursement of documented medical-related expenses
• Removal of negative employment references
• A neutral reference letter from HGV
• Mutual non-disparagement agreement
• Closure of all claims upon payment
III. DEADLINE FOR RESPONSE
Please respond within 10 business days of receipt of this letter.
If no agreement is reached, I will proceed with:
Filing a District Court Complaint Claims including retaliation, defamation per se, negligent supervision, hostile work environment, and coercion Disclosure of all text messages, evidence, and medical documentation Inclusion of punitive damages and attorney fee requests
This offer is made in good faith and with the intent to resolve this matter efficiently for all parties.
