Thomas Peprah

Intake Overview: The plaintiff is Thomas Jason Kofi Peprah Jr. (legal name), 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 provided in the intake. Plaintiff resides at 1507 Metropolitan Avenue, Apartment 3B, Bronx, New York 10462, within the Parkchester condominium complex. The incident occurred at that same address on or about December 8, 2024, with the year inferred from context during intake — the attorney should confirm the precise incident date before proceeding. Both plaintiff's residence and the situs of the incident are in Bronx County, which is relevant to venue selection under current New York venue rules. The case is categorized as police brutality / excessive force / unlawful entry. This is not a wrongful death matter. According to the intake, NYPD officers — including Detective Arena (badge number not yet confirmed) — allegedly entered plaintiff's apartment without a warrant, removed him, handcuffed him, and placed him on the floor in the hallway before returning him inside. Officers were reportedly acting on what plaintiff believes was a bad tip, searching for a different individual known as "Kofi," described as an older male approximately 53 years of age. Plaintiff was wearing a Ralph Lauren bathrobe with "Kofi" monogrammed on the back, which an officer reportedly observed. During the incident, one officer accessed plaintiff's Instagram account (@king_kofi___) on plaintiff's phone and showed it to plaintiff. The same officer placed two calls to plaintiff's roommate's cell phone from the officer's own personal cell phone during the incident, and screenshots of those calls are reportedly available. Plaintiff was not charged with any crime arising from the incident. Plaintiff's girlfriend, Marie Cedano, was present in the apartment and witnessed the entire incident; she was placed outside the apartment but was not handcuffed. Plaintiff's roommate was not present, reportedly being at work at the time. The potential defendants identified in the intake are Detective Arena (first name, badge number, and role not yet confirmed) and the New York City Police Department / City of New York, identified as employer. The City of New York is a municipal entity. This designation is of critical procedural importance: claims against the City of New York and its agencies trigger a Notice of Claim requirement under General Municipal Law § 50-e, with a filing deadline of 90 days from the date of the incident. The assigned attorney has already indicated awareness of this deadline and intent to file a Notice of Claim. The applicable statute of limitations for § 1983 federal civil rights claims is three years from the date of the incident; state law claims against the City carry a one year and 90 days limitations period. Both deadlines require prompt action. The intake notes that plaintiff has already filed a written complaint with the NYPD via email and was in contact with a female NYPD investigator who requested photographs of the call log and the bathrobe. The attorney has advised plaintiff to cease all communication with NYPD personnel. Building lobby surveillance cameras and a neighbor's Ring camera may have captured footage of the incident. Plaintiff has referenced requesting surveillance footage in connection with the December 8 date. Injuries and Treatment: No physical injuries are reported in the intake, and plaintiff has not sought any medical treatment arising from this incident. There are no treating providers, no diagnostic imaging, no emergency room visit, no ambulance transport, no surgery, and no future treatment scheduled. No medical records exist to obtain at this time. To the extent plaintiff intends to pursue claims for emotional distress, psychological harm, or civil rights violations in the absence of physical injury, the intake does not identify any mental health provider or treatment for those conditions. This is not a motor vehicle accident; accordingly, New York no-fault considerations are not applicable. Key Facts and Liability Considerations: - Statute of limitations: The applicable limitations period for § 1983 federal civil rights claims is three years from the incident date (approximately December 8, 2027). State law tort claims against the City of New York carry a one year and 90 days limitations period (approximately March 8, 2026). The Notice of Claim under General Municipal Law § 50-e must be filed within 90 days of the incident date (approximately March 8, 2025). The attorney has noted intent to file before year-end 2025; the Notice of Claim deadline is significantly earlier and requires immediate attention upon case acceptance. - The incident date of December 8, 2024 was inferred from context during intake — the year was not explicitly confirmed by plaintiff. The attorney must verify the precise incident date before filing any notice or commencing any proceeding, as this date anchors all applicable deadlines. - City of New York / NYPD is identified as a municipal defendant, triggering the 90-day Notice of Claim requirement and shortened state law limitations periods. - Detective Arena is identified by surname only; first name, badge number, shield number, and role are not yet confirmed in the intake. - Plaintiff filed a written complaint with the NYPD via email and was in contact with a female NYPD investigator who requested photographs of the call log and the bathrobe. The attorney has advised plaintiff to cease all communications with NYPD personnel, which is appropriate to note for conflict management purposes. - Potential witness: Marie Cedano (plaintiff's girlfriend), present during the entire incident and not handcuffed; her contact information is not captured in the intake. - Physical evidence potentially available: screenshots of two calls made by an officer from the officer's personal cell phone to plaintiff's roommate during the incident; photographs of the monogrammed bathrobe; building lobby surveillance footage; neighbor's Ring camera footage. Preservation demands for surveillance footage should be considered immediately. - Plaintiff's roommate was not present during the incident but may have received the two calls placed by the officer; the roommate's identity and contact information are not captured in the intake. - No physical injuries reported and no medical treatment sought. The absence of physical injury and medical records may affect the damages model, which would rely primarily on constitutional violations, emotional distress, and civil rights theories. - No prior injuries, prior treatment, or preexisting conditions are identified in the intake. - No lien or subrogation exposure is identified in the intake. - No parallel criminal proceedings against plaintiff are indicated; plaintiff was not charged with any crime arising from this incident. - No prior firm rejection of this matter, no credibility concerns, no plaintiff criminal history, and no substance abuse history are flagged in the intake. - Extraction confidence is reported at 0.72, which is below the threshold for high confidence; all extracted facts — particularly the incident date and defendant details — should be verified directly with plaintiff before any filing. - Retainer, HIPAA authorization, and limited POA have not yet been signed. Information Gaps: - Incident date: The year 2024 was inferred from context, not explicitly confirmed by plaintiff. The attorney must confirm the precise date before any filing, as all deadlines flow from this date. - Plaintiff demographics: Occupation, employment status, marital status, and dependents are not provided. These affect the damages model and any potential loss of consortium analysis. - Plaintiff contact information: Phone number and email address are not captured in the intake. - Detective Arena: First name, badge number, shield number, and specific role during the incident are unknown. This information is necessary to properly name defendants in the Notice of Claim and any subsequent pleading. - Additional officers: The intake references multiple NYPD officers present at the scene beyond Detective Arena. Their identities, badge numbers, and roles are not identified. - Witness contact information: Marie Cedano (girlfriend/eyewitness) — address and contact information not captured. - Roommate identity and contact information: Not provided. The roommate may be a witness to the officer's calls and potentially to other aspects of the incident. - Surveillance footage: Status of preservation or retrieval of building lobby camera footage and neighbor's Ring camera footage is unknown. A litigation hold or preservation demand may be warranted immediately. - Emotional distress or psychological treatment: No mental health provider is identified. If plaintiff intends to claim psychological or emotional harm, any treating provider should be identified. - Prior injuries, prior treatment, or preexisting conditions: Not addressed in intake, though no physical injury is claimed here. - Health insurance information: Not provided. Relevant if any future treatment arises. - Whether plaintiff has retained or previously consulted any other attorney regarding this incident: Not addressed in the intake. - Plaintiff's written NYPD complaint: The intake references a written complaint submitted by email; the content, date, and any NYPD response are not provided but may be relevant to the claim narrative. - Identity and contact information of the female NYPD investigator who contacted plaintiff: Not captured, though communications with her may be relevant. - Any CCRB (Civilian Complaint Review Board) complaint filed or pending: Not addressed in the intake. - Any prior NYPD encounters or complaints involving plaintiff: Not addressed in the intake. - Plaintiff's full legal name confirmation on retainer and intake forms: The intake notes plaintiff's legal name is Thomas Jason Kofi Peprah Jr., distinct from the name "Thomas Peprah" used elsewhere. All documents should reflect the confirmed legal name. --- PRELIMINARY MEDICAL CHRONOLOGY No medical treatment was sought and no treating providers were identified. No medical chronology entries exist for this matter.