IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
CHYVETTE A. VALENTINE,
Plaintiff,
v.
CHICAGO BULLS, SCOTTIE M. PIPPEN, CARL PIPPEN, LARSA PIPPEN, et al.,
Defendants.
Case No.: 2024L002166
Courtroom: 2209
Judge: Hon. Maire Aileen Dempsey
MOTION FOR DEFAULT JUDGMENT
NOW COMES Plaintiff, Chyvette A. Valentine, pro se, and hereby moves this Court to enter a Default Judgment against Defendants Chicago Bulls, Scottie M. Pippen, Carl Pippen, Larsa Pippen, and associated parties, for failure to appear, respond, or otherwise defend in this action, pursuant to 735 ILCS 5/2-1301. In support of this Motion, Plaintiff states as follows:
I. SERVICE DETAILS AND FAILURE TO RESPOND
Case Background and Damages Sought: Plaintiff filed this action alleging damages of $300 million based on claims of stalking, harassment, intentional infliction of emotional distress, defamation, and additional causes of action detailed in the complaint.
Service of Process on Defendants: Defendants were duly served with the Summons and Complaint as follows:
Scottie M. Pippen: Served on October 11, 2024, via certified mail to 24612 Wingfield Rd, Hidden Hills, CA 91302, parcel #9589071052702108909206.
Attorney Jason Giller: Received service on behalf of Scottie M. Pippen on October 16, 2024, via certified mail to 1111 Brickell Ave, Ste 1550, Miami, FL 33131, parcel #9589071052702108909213.
Dorothy R. Pippen: Received service on behalf of Scottie and Carl Pippen on October 19, 2024, via certified mail to 105 N Pine St, Hamburg, AR 71646, parcel #9589071052702108909176.
Kimberly Pippen: Accepted service in person on October 17, 2024, on behalf of the defendants, parcel #9589071052702108909183.
Larsa Pippen: Although evading service, accepted on October 17, 2024, via certified mail to 851 NE 1st Ave, Miami, FL 33132, parcel #9589071052702108909183.
Lack of Response: Defendants failed to file an appearance, respond, or defend against the allegations within the required timeframe.
Informal responses from Jason Giller and Dorothy R. Pippen did not constitute formal appearances or answers as required by law.
II. LEGAL GROUNDS FOR DEFAULT JUDGMENT
Illinois Statutory Authority for Default Judgment: Under 735 ILCS 5/2-1301(d), default judgment is appropriate when a party fails to plead or otherwise defend a claim after proper service. Plaintiff asserts that each Defendant’s failure to appear or answer meets the criteria for default judgment.
Claims Presented by Plaintiff: Plaintiff’s complaint sets forth substantial allegations, including but not limited to:
Stalking: Defined by 720 ILCS 5/12-7.4, with alleged incidents involving unwelcome contact, tracking, and personal intimidation.
Harassment: Outlined in 720 ILCS 5/26.5-3, with claims of repeated actions intended to alarm, distress, and harm Plaintiff.
Intentional Infliction of Emotional Distress: Pursuant to 740 ILCS 21/10, based on a sustained campaign of emotional and psychological harm.
Defamation and Slander: Under 740 ILCS 145, asserting that Defendants have made false and damaging statements against Plaintiff’s character.
Federal Claims of Interstate Stalking and Extortionate Threats: Based on incidents spanning various states, as per 18 U.S.C. § 2261A(2)(A) and § 875(d), alleging serious federal violations.
Documented Pattern of Abuse: Plaintiff claims that Defendant Scottie M. Pippen leveraged his status to conduct actions constituting harassment and defamation, impacting Plaintiff’s well-being and reputation over an extended period.
III. REQUEST FOR RELIEF AND DAMAGES
Damages Requested: Plaintiff seeks a monetary judgment of $300 million in compensatory and punitive damages due to the mental, emotional, and financial harm incurred.
Injunctive Relief: Plaintiff requests that the Court issue a permanent injunction barring all Defendants from any future contact with Plaintiff, whether direct or indirect.
Additional Relief: Plaintiff requests the Court to grant such other relief as may be deemed just and appropriate given the Defendants’ default and the severity of the allegations presented.
WHEREFORE, Plaintiff respectfully prays that this Honorable Court:
Enter a Default Judgment in favor of Plaintiff against all named Defendants in the amount of $300 million;
Issue a permanent injunction prohibiting Defendants from contacting or harassing Plaintiff in any manner;
Grant such other and further relief as deemed just and proper.
Respectfully Submitted,
