Thomas Peprah

Intake Overview: The plaintiff is Thomas Jason Kofi Peprah Jr., date of birth December 7, 1990, making him approximately 34 years of age at the time of the incident. His occupation, employment status, marital status, and dependents are not reflected in the intake. The plaintiff resides at 1507 Metropolitan Avenue, Apt 3B, Bronx, NY 10462, which is also the situs of the incident (identified in the intake as part of the Parkchester condos complex). Because the plaintiff's residence and the incident location are one and the same, both are available as independent bases for venue in the Bronx. The incident is dated December 8, 2024, though the intake notes that the year was not explicitly confirmed in the transcript and flags this as requiring verification. The case category is police_brutality, encompassing claims of excessive force, wrongful entry, and civil rights violations. This is not a wrongful death matter. According to the intake, NYPD officers — including a detective identified only by the surname "Arena," badge number to be provided — wrongfully entered the plaintiff's apartment without apparent lawful basis. Officers handcuffed the plaintiff, removed him from the apartment, placed him on the floor in the hallway, and subsequently returned him inside. The incident appears to have been precipitated by a case of mistaken identity: officers were reportedly searching for an individual named "Kofi," described as an older male of approximately 53 years of age. The plaintiff shares "Kofi" as a middle name and had that name embroidered on a robe, which may have contributed to the confusion. No charges were filed against the plaintiff. Officers allegedly accessed the plaintiff's Instagram account (@king_kofi___) during the incident. The plaintiff subsequently filed a complaint with the NYPD and emailed an investigator (identified only as a female contact); her identity and contact information are not further specified in the intake. The identified defendants are: (1) Detective Arena (last name only; badge number, first name, and address unknown), in his individual capacity as an NYPD officer; (2) the New York City Police Department; and (3) the City of New York. The NYPD and the City of New York are governmental/municipal entities. This has critical procedural implications: a Notice of Claim must be served on the City of New York within 90 days of the date of the incident pursuant to General Municipal Law § 50-e. The intake expressly notes that the assigned attorney flagged the 90-day notice of claim deadline as approaching. If the incident date is confirmed as December 8, 2024, the notice of claim deadline falls on or about March 8, 2025. Immediate action upon case acceptance is required. No police report is referenced in the intake as having been filed at the scene in connection with the incident itself; a separate NYPD complaint was filed by the plaintiff after the fact. Injuries and Treatment: The intake does not identify any physical injuries claimed by the plaintiff, and no treating providers are listed. The intake expressly states that no medical records or physical injuries were reported, characterizing this as a civil rights matter. No emergency services response, ambulance transport, ER visit, hospitalization, diagnostic imaging, or surgical treatment is referenced. As this matter does not arise from a motor vehicle accident, no-fault considerations are not applicable. The absence of documented physical injury does not foreclose the civil rights claims (wrongful entry, unlawful seizure, excessive force), which may support recovery for constitutional violations, emotional distress, and related non-physical harms; however, the damages model will depend significantly on what injuries — physical or psychological — the plaintiff can substantiate, and the intake is silent on both. Key Facts and Liability Considerations: - Statute of limitations: Civil rights claims under 42 U.S.C. § 1983 carry a three-year statute of limitations in New York, running from the date of the incident. If the incident date is confirmed as December 8, 2024, the federal SOL runs to approximately December 8, 2027. State law claims against the City of New York are subject to a one-year-and-90-day limitations period following timely service of a Notice of Claim. The Notice of Claim deadline is the immediate pressure point — see below. - Notice of Claim deadline is critical and imminent: If the incident date is December 8, 2024, the 90-day Notice of Claim deadline under General Municipal Law § 50-e falls on or about March 8, 2025. The assigned attorney has already flagged this. Failure to serve a timely Notice of Claim will bar state law claims against the City of New York and the NYPD. Immediate action is required upon case acceptance. - Incident date requires verification: The transcript states "December 8" but does not explicitly confirm the year. The extraction notes context suggests 2024. The confirmed date drives all notice and limitations deadlines and must be nailed down before any filing. - Mistaken identity as liability theory: The intake suggests officers targeted the plaintiff due to a shared name ("Kofi") and a robe bearing that name, rather than any individualized suspicion directed at the plaintiff personally. This narrative, if corroborated, may support claims of unlawful entry and unlawful seizure. - No charges filed: The intake confirms no criminal charges were filed against the plaintiff arising from this incident, which is favorable to the liability narrative. - Potential corroborating evidence identified in intake: The plaintiff's girlfriend, Marie Cedano, was present and witnessed the incident. The plaintiff's roommate received two phone calls from an officer's personal cell phone during the incident, and the plaintiff reports having screenshots of those calls. These may serve as significant corroborating evidence and should be preserved immediately. - Alleged access to plaintiff's Instagram account: Officers allegedly accessed the plaintiff's Instagram account (@king_kofi___) during the incident. If substantiated, this may implicate additional Fourth Amendment privacy claims. - NYPD internal complaint filed: The plaintiff filed a complaint with the NYPD and emailed a female investigator. The status of that complaint and any response or investigation number are unknown. - Defendant "Arena" identity is incomplete: Only a last name is provided for the individual officer defendant. Badge number was noted as "to be provided." Full identification of all officers present is necessary before suit can be commenced against individual defendants. - No physical injuries documented: The absence of documented physical injury will affect the damages model. Emotional distress, constitutional harm, and dignitary injury may still be viable, but the intake contains no information regarding any psychological treatment, therapy, or related claims. - Extraction confidence flagged at 0.72: The system flagged moderate confidence in the extraction, suggesting the attorney should review the underlying transcript carefully before relying on any specific factual detail. - Retainer, HIPAA authorization, and limited POA: None signed as of the date of this summary. Information Gaps: - Incident date year not confirmed: The transcript states "December 8" without explicitly naming the year. Confirmation of the full date — December 8, 2024 — is essential before any Notice of Claim or filing deadline can be acted upon with certainty. - Plaintiff occupation, employment status, and income: Unknown; relevant to any lost wages or economic damages component. - Plaintiff marital status and dependents: Unknown; relevant to the damages model and any potential loss of consortium claim. - Full identity of Detective Arena: First name, badge number, shield number, and command/precinct are unknown. Badge number was noted as "to be provided" but is not in the intake. All individual officer defendants must be fully identified before suit is commenced. - Identity and badge numbers of all other NYPD officers present: The intake references "officers" in the plural but identifies only Detective Arena by name. All officers involved must be identified. - Identity of the female NYPD investigator who received the plaintiff's complaint: Name and contact information unknown; NYPD complaint number or CCRB complaint number, if any, also unknown. - Plaintiff's roommate identity: Name not provided; this individual may be a material witness and should be identified. - Whether plaintiff has retained any other attorney or whether this matter was previously presented to or rejected by another firm: Unknown. - Physical or psychological injuries, if any: The intake states no physical injuries were reported, but it is unclear whether plaintiff is claiming emotional distress, PTSD, anxiety, or other psychological harm. If so, treating mental health providers should be identified. - Whether plaintiff sought any medical or psychological treatment following the incident: Unknown. - Plaintiff's phone number and email: Not captured in the intake. - Basis for officers' entry — warrant, exigent circumstances, or consent: Unknown; critical to the unlawful entry liability analysis. - Whether any video footage exists (building surveillance, body-worn camera, or other): Unknown; highly material and subject to rapid spoliation. A litigation hold or preservation demand directed to the City of New York / NYPD should be considered immediately upon case acceptance. - Whether plaintiff has copies of any body-worn camera footage, police records, or documents related to the incident: Unknown. - Referring attorney or referral source: Not identified in the intake. --- PRELIMINARY MEDICAL CHRONOLOGY No medical encounters, treating providers, diagnostic imaging, or surgical procedures were identified in the intake. This section will be populated once medical or psychological treatment information is obtained from the plaintiff.