SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF QUEENS
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PRAKASH CHURAMAN, SUPPLEMENTAL

SUMMONS
Plaintiff,
Index No.:
-against-
The Basis of Venue is:
THE CITY OF NEW YORK, NYPD POLICE Location of Incident
DETECTIVE DANIEL GALLAGHER, Tax ID No.
925326, DETECTIVE BARRY BROWN Tax ID No. Plaintiff designates Queens
911490, NYPD DETECTIVE REBECCA H. SCHMITT, County as the place of trial.
Shield No. 1358 and NYPD POLICE OFFICERS
JOHN/JANE DOES NUMBERS ONE THROUGH TEN,

Defendants.

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To the above named Defendants:

You are hereby summoned to answer the Verified Complaint in this action, and to serve
a copy of your Verified Answer to the Verified Complaint, or, if the Verified Complaint is not
served with this Summons, to serve a notice of appearance on the Plaintiff's attorneys within
twenty days after the service of this Summons, exclusive of the day of service, where service is
made by delivery upon you personally within the state, or, within 30 days after completion of
service where service is made in any other manner. In case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded in the complaint.

DATED: New York, New York

January 10, 2023

Yours, etc.

Cary London, Esq.

Shulman-Hill, PLLC
Attorneys for Plaintiff
1 State Street Plaza
15th Floor
New York, New York 10004
(212) 203-1090

TO: THE CITY OF NEW YORK, Corporation Counsel, 100 Church Street, NY, NY 10007
NYPD POLICE DETECTIVE DANIEL GALLAGHER, Tax ID No. 925326, 113th
Precinct Detective Squad; 167-02 Baisley Boulevard, Jamaica, NY 11434

DETECTIVE BARRY BROWN Tax ID No. 911490, 113th Precinct Detective Squad;
167-02 Baisley Boulevard, Jamaica, NY 11434

NYPD DETECTIVE REBECCA H. SCHMITT, Shield No. 1358, 113th Precinct Detective
Squad; 167-02 Baisley Boulevard, Jamaica, NY 11434

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 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
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PRAKASH CHURAMAN,
INDEX NO.:
Plaintiff,
1ST AMENDED VERIFIED
-against- COMPLAINT

THE CITY OF NEW YORK, NYPD POLICE

DETECTIVE DANIEL GALLAGHER, Tax ID No.
925326, DETECTIVE BARRY BROWN Tax ID No. JURY TRIAL DEMANDED
911490, NYPD DETECTIVE REBECCA H. SCHMITT,
Shield No. 1358 and NYPD POLICE OFFICERS
JOHN/JANE DOES NUMBERS ONE THROUGH TEN,

Defendants.

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Plaintiff PRAKASH CHURAMAN, by his attorneys, Shulman-Hill, PLLC, as and for his
Verified Complaint herein, alleges upon information and belief as follows:

PRELIMINARY STATEMENT

1. This is a civil rights action to recover money damages arising out of

defendants’ violation of Plaintiff’s rights as secured by the Civil Rights Act, 42 U.S.C. Sections
1983 and 1988, and of rights secured by the Fourth, Fifth, and Fourteenth Amendments to the
United States Constitution, and the common law and the laws of the State of New York. On
December 9, 2014, at approximately 6:00 a.m., Plaintiff Prakash Churaman, while lawfully in
the vicinity of 142-04 Foch Boulevard, County of Queens, New York, was subject to an unlawful
arrest, detention, and excessive use of force by defendant Police Officers. In addition, Plaintiff
was subjected to approximately seven (7) years in unlawful custody by defendant officers at the
113th Precinct, Queens County Central Bookings, CrossRoads Juvenile Center, Rikers Island
Correctional Facility, and Great Meadow Correctional Facility. All charges made against the
plaintiff were dismissed and sealed in their entirety on or around June 6, 2022. Plaintiff was
deprived of his constitutional, common law, and statutory rights when the individual defendants
unlawfully stopped, detained, subjected to excessive force, passed along false accusations to
prosecuting attorneys, and engaged in the malicious prosecution of Plaintiff, in violation of the
Fourth, Fifth, and Fourteenth Amendments to the United States Constitution, the common law
and the laws of the State of New York.

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 PARTIES

2. Plaintiff Prakash Churaman is a resident of the state of New York.

3. New York City Police Detective Daniel Gallagher, Tax ID No. 925326, is
and was at all times relevant herein an Officer with the New York City Police Department.

4. New York City Police Detective Daniel Gallagher, Tax ID No. 925326, is
being sued in his individual and official capacity.

5. Currently and at all times relevant herein, New York City Police Detective
Daniel Gallagher, Tax ID No. 925326, was assigned to the 113th Precinct Detective Squad of
the NYPD.

6. New York City Police Officers John/Jane Does #1-10 are and were at all
times relevant herein officers, employees, and agents of the New York City Police Department.

7. New York City Police Officers John/Jane Does #1-10 are being sued in their
individual and official capacities.

8. At all times relevant herein, the individual defendants were acting under
color of state law in the course and scope of their duties and functions as agents, servants,
employees and officers of the New York City Police Department, and otherwise performed and
engaged in conduct incidental to the performance of their lawful functions in the course of their
duties. They were acting for and on behalf of the New York City Police Department at all times
relevant herein, with the power and authority vested in them as officers, agents and employees
of the New York City Police Department and incidental to the lawful pursuit of their duties as
officers, employees and agents of the New York City Police Department.

9. Defendant City of New York is a municipal entity created and authorized

under the laws of the State of New York. It is authorized by law to maintain a police department,
which acts as its agent in the area of law enforcement and for which it is ultimately responsible.
The defendant City of New York assumes the risks incidental to the maintenance of a police
force and the employment of police officers as said risks attach to the public consumers of the
services provided by the New York City Police Department.

10. Plaintiff in furtherance of his causes of action brought pursuant to New

York State law filed a timely Notice of Claim against the City of New York in compliance with
the Municipal Law Section 50 and in accordance with New York State law.

11. In accordance with New York State law and General Municipal Law
Section 50, Plaintiff testified at a hearing held pursuant to General Municipal Law Section 50-H
on October 28, 2022.

12. More than thirty (30) days have elapsed since service of said Notice of
Claim was filed and the City of New York has failed to pay or adjust the claims.

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 13. This action falls within one or more of the exceptions as set forth in CPLR
Section 1602, involving intentional actions, as well as the defendant, and/or defendants, having
acted in reckless disregard for the safety of others, as well as having performed intentional acts.

14. Plaintiff has sustained damages in an amount in excess of the jurisdictional

limits of all the lower Courts of the State of New York.

STATEMENT OF FACTS

15. On December 9, 2014, at approximately 6:00 a.m., Plaintiff was lawfully

present in the vicinity of 142-04 Foch Boulevard, County of Queens, New York, when the
defendant Police Officers unlawfully arrested Plaintiff without probable cause or legal
justification.

16. At the time of the relevant incident, the plaintiff was fifteen (15) years old.

17. Plaintiff was in the basement of his home when defendant officers came
into the home without a warrant.

18. It was at this point that the defendant officers began to arrest the plaintiff,
subjecting him to unlawful pat-down search and tightly restraining him with metal handcuffs.

19. At no time relevant herein did Plaintiff commit a crime or violate the law in
any way, nor did the police officers have an objective reason to accuse Plaintiff of committing a
crime or violating the law in any way.

20. At no point did Defendant Officers recover any drugs, weapons, graffiti
instruments, or other illegal contraband from Plaintiff or from a location that was in Plaintiff's
possession, custody, or control.

21. Plaintiff did not resist arrest.

22. Nevertheless, Plaintiff was unlawfully arrested and handcuffed by the

defendant officers without legal justification or probable cause, placed in the back of an NYPD
vehicle, and transported to the 113th Precinct against his will.

23. Upon his arrival at the Precinct, the Plaintiff was unlawfully fingerprinted,
photographed, subjected to another unlawful search, and placed in a holding cell.

24. At the 113th Precinct, Plaintiff was interrogated for hours by Defendant
Officers, and Plaintiff continued to deny involvement in any murder.

25. Plaintiff was innocent of any crime, and had no knowledge of any
participants in any murder.

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 26. During his time at the 113th Precinct, defendant officers coerced the
plaintiff into making a false confession to a murder that had occurred four (4) days prior; the
plaintiff was psychologically broken by the defendant officers’ interrogation tactics, and told
them whatever they wanted to hear with the belief that the officers would thereafter let him go
home.

27. After a short time at the Precinct, the Plaintiff was transported to Queens
County Central Bookings where he was fingerprinted, searched, and placed in another holding
cell.

28. While Plaintiff was in custody, the defendant police officers provided the
Queens County District Attorney’s Office with the false, misleading, and/or incomplete
information that Plaintiff committed a crime.

29. Specifically, the defendant police officers falsely stated to the Queens
County District Attorney’s Office that Plaintiff was engaged in Burglary and Murder in the 2nd
degree.

30. Plaintiff was brought before a Judge, charged with crimes he did not
commit, and based on the Officers false allegations, the Judge remanded Plaintiff to jail.

31. Since Plaintiff was a juvenile, Plaintiff was remanded to the CrossRoads
Juvenile Detention Center.

32. During his time at CrossRoads, the plaintiff was attacked and physically
injured on several occasions by fellow detainees.

33. On or about July 16, 2016, the plaintiff was transferred to Rikers Island
Correctional Facility, where he attempted suicide twice, because of the dire conditions in jail,
and false allegations levied against him.

34. While at Rikers Island, Plaintiff was routinely subjected to complete strip
searches of his person.

35. On November 18, 2018, the plaintiff was convicted by a trial jury based on
the false and coerced confession by Defendant Officers.

36. On or about January 30, 2019, the Plaintiff was sentenced and transferred
to Great Meadow Correctional Facility in Comstock, New York.

37. While the plaintiff was in custody at Great Meadow, he received a

permanent scar on his face after he was slashed by another inmate.

38. Plaintiff estimates that he spent approximately one (1) full year in solitary
confinement during his time in unlawful custody.

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 39. On June 24, 2020, the plaintiff’s conviction was overturned due to Due
Process Violations committed by the Police and Queens District Attorney’s office.

40. After repeated Court delays by the Queens District Attorney’s office, a
Judge finally set bail on Plaintiff, which he was able to make on or about January 19, 2021.

41. Although Plaintiff was released from Rikers on January 19, 2021, he
remained on house arrest until the charges made against him were dismissed.

42. On or about June 6, 2022, all charges against the plaintiff were dismissed
and sealed in their entirety.

43. Plaintiff’s entire child was unlawfully taken from him, from the age of 14
when he was unlawfully incarcerated, until the age of 20 when he was finally released.

44. As a result of the relevant incident and false charges made against him, the
plaintiff sustained permanent mental and emotional injury from spending his formative years as
a child among men in high security prisons. Further, he has since struggled to find employment
or achieve any sort of normalcy as an adult living outside the penal system.

45. Some of the police officer defendants observed the violation of Plaintiff’s
rights under the Constitution of the United States and New York State Law and did nothing to
prevent their fellow officers from unjustifiably arresting, confining, and using excessive force
against Plaintiff.

46. The unlawful arrest, confinement, and use of excessive force by the
individually named defendants caused Plaintiff to sustain physical, psychological and emotional
trauma.

FIRST CAUSE OF ACTION

Negligence

47. The Plaintiff repeats, reiterates, and re-alleges each and every allegation
contained in the foregoing paragraphs with the same force and effect as if more fully set forth at
length herein.

48. Defendants owed a duty of care to Plaintiff.

49. To the extent defendants claim that the injuries to Plaintiff by the defendant
police officers were unintentionally caused and that the force used by the defendants against
him was unintentional, then the defendants breached that duty of care by, among other things,
tightly handcuffing him and keeping him in unlawful custody for approximately seven (7) years.

50. As a direct and proximate result of such acts, defendants deprived Plaintiff
of his rights under the laws of the State of New York.

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 51. All of the foregoing occurred without any fault or provocation by Plaintiff.

52. Defendants were at all times agents, servants, and employees acting within
the scope of their employment by the City of New York and the New York City Police
Department, which are therefore responsible for their conduct.

53. The City, as the employer of the officer defendants, is responsible for their
wrongdoing under the doctrine of respondeat superior.

54. As a result of the aforementioned conduct of defendants, Plaintiff sustained

injuries, including but not limited to physical, emotional, and psychological injuries.

SECOND CAUSE OF ACTION

Unlawful Stop, Question, and Search

55. The Plaintiff repeats, reiterates, and re-alleges the foregoing paragraphs as
if the same were fully set forth at length herein.

56. The illegal approach, pursuit, stop and grab employed by defendants herein
terminated Plaintiff’s freedom of movement through means intentionally applied.

57. The conduct of defendants in approaching, stopping, and grabbing Plaintiff

was performed under color of law and without any reasonable suspicion of criminality or other
constitutionally required grounds.

58. As a direct and proximate result of such acts, defendants deprived Plaintiff
of his rights under the laws of the State of New York.

59. Defendants were at all times agents, servants, and employees acting within
the scope of their employment by the City of New York and the New York City Police
Department, which are therefore responsible for their conduct.

60. The City, as the employer of the officer defendants, is responsible for their
wrongdoing under the doctrine of respondeat superior.

THIRD CAUSE OF ACTION

Violation of Fourth and Fourteenth Amendment Rights:
Unlawful Seizure and Deprivation of Liberty

61. The Plaintiff repeats, reiterates, and re-alleges the foregoing paragraphs as
if the same were fully set forth at length herein.

62. The individually named police officer defendants, while acting in concert
and within the scope of their authority, caused Plaintiff to be seized, unlawfully searched, falsely
arrested, falsely imprisoned, and maliciously prosecuted without reasonable suspicion and/or

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 probable cause, in violation of Plaintiff’s right to be free of an unreasonable seizure under the
Fourth Amendment of the Constitution of the United States and to be free of a deprivation of
liberty under the Fourteenth Amendment to the Constitution of the United States.

63. As a result of the aforementioned conduct of defendants, Plaintiff sustained

injuries, including but not limited to physical, emotional, and psychological injuries.

FOURTH CAUSE OF ACTION

False Imprisonment

64. The Plaintiff repeats, reiterates, and re-alleges the foregoing paragraphs as
if the same were fully set forth at length herein.

65. The acts and conduct of the defendants constitute false arrest and false
imprisonment under the laws of the State of New York. Defendants intended to confine Plaintiff
and, in fact, confined Plaintiff, and Plaintiff was conscious of the confinement. In addition,
Plaintiff did not consent to the confinement and the confinement was not otherwise privileged.

66. As a direct and proximate result of such acts, defendants deprived Plaintiff
of his rights under the laws of the State of New York and the United States Constitution.

67. Defendants were at all times agents, servants, and employees acting within
the scope of their employment by the City of New York and the New York City Police
Department, which are therefore responsible for their conduct.

68. The City, as the employer of the officer defendants, is responsible for their
wrongdoing under the doctrine of respondeat superior.

69. As a result of the aforementioned conduct of defendants, Plaintiff sustained

injuries, including but not limited to loss of liberty, emotional and psychological injuries.

FIFTH CAUSE OF ACTION

Violation of Plaintiff’s Fourth And Fourteenth Amendment Rights:
Excessive Force

70. The Plaintiff repeats, reiterates, and re-alleges each and every allegation
contained in the foregoing paragraphs with the same force and effect as if more fully set forth at
length herein.

71. The use of excessive force by defendants by, amongst other things, tightly
handcuffing him and keeping him in unlawful custody for approximately seven (7) years,
constituted objectively unreasonable physical seizures of Plaintiff in violation of his rights under
the Fourth and Fourteenth Amendments to the Constitution of the United States and to be free of
a deprivation of liberty under the Fourteenth Amendment to the Constitution of the United States.

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 72. Defendants were at all times agents, servants, and employees acting within
the scope of his employment by the City of New York and the New York City Police Department,
which are therefore responsible for their conduct.

SIXTH CAUSE OF ACTION

Negligent Infliction of Emotional Distress

73. The Plaintiff repeats, reiterates, and re-alleges each and every allegation
contained in the foregoing paragraphs with the same force and effect as if more fully set forth at
length herein.

74. By the actions described herein, defendants, each acting individually and in
concert with each other, engaged in extreme and outrageous conduct, conduct utterly intolerable
in a civilized community, which negligently caused severe emotional distress to Plaintiff.

75. The acts and conduct of the defendants were the direct and proximate cause
of injury and damage to Plaintiff and violated Plaintiff’s statutory and common law rights as
guaranteed Plaintiff by the laws and Constitution of the State of New York.

76. As a direct and proximate result of such acts, defendants deprived Plaintiff
of his rights under the laws of the State of New York.

77. Defendants were at all times agents, servants, and employees acting within
the scope of their employment by the City of New York and the New York City Police Department,
which are therefore responsible for their conduct.

78. The City, as the employer of the officer defendants, is responsible for their
wrongdoing under the doctrine of respondeat superior.

79. As a result of the aforementioned conduct of defendants, Plaintiff sustained

injuries, including but not limited to emotional and psychological injuries.

SEVENTH CAUSE OF ACTION

Negligent Hiring, Retention, Training and Supervision

80. The Plaintiff repeats, reiterates, and re-alleges each and every allegation
contained in the foregoing paragraphs with the same force and effect as if more fully set forth at
length herein.

81. The City of New York and its employees, servants and/or agents acting
within the scope of their employment did negligently hire, retain, train and supervise defendants,
individuals who were unfit for the performance of police duties on the aforementioned dates at
the aforementioned locations.

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 82. As a result of the aforementioned conduct of defendants, Plaintiff sustained
injuries, including but not limited to physical, emotional, and psychological injuries.

EIGHTH CAUSE OF ACTION

Failure to Intervene

83. The Plaintiff repeats, reiterates, and re-alleges each and every allegation
contained in the foregoing paragraphs with the same force and effect as if more fully set forth at
length herein.

84. The defendants that did not physically touch Plaintiff, but were present
when other officers violated Plaintiff’s Constitutional Rights had an affirmative duty to intervene
on behalf of Plaintiff, whose constitutional rights were being violated in their presence by other
officers.

85. Defendants failed to intervene to prevent the unlawful conduct described

herein.

86. As a result of the foregoing, Plaintiff suffered serious injury, his liberty was
restricted for an extended period of time, he was put in fear for his safety, and he was humiliated
and subject to other physical constraints.

87. As a direct and proximate result of such acts, defendants deprived Plaintiff
of his rights under the laws of the State of New York.

88. Defendants were at all times agents, servants, and employees acting within
the scope of their employment by the City of New York and the New York City Police
Department, which are therefore responsible for their conduct.

89. The City, as the employer of the officer defendants, is responsible for their
wrongdoing under the doctrine of respondeat superior.

90. As a result of the aforementioned conduct of defendants, Plaintiff sustained

injuries, including but not limited to emotional and psychological injuries.

NINTH CAUSE OF ACTION

Violation of Fourth And Fourteenth Amendment Rights:
Denial of Right to Fair Trial/Due Process

91. The Plaintiff repeats, reiterates, and re-alleges the foregoing paragraphs as
if the same were fully set forth at length herein.

92. Defendants, individually and collectively, manufactured and/or withheld

false evidence and forwarded this false evidence to prosecutors in the Queens County District
Attorney’s Office.

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 93. Defendants filled out false and misleading police reports and forwarded
them to prosecutors in the Queens County District Attorney’s Office.

94. Defendants signed false and misleading criminal court affidavits and
forwarded them to prosecutors in the Queens County District Attorney’s Office.

95. In withholding/creating false evidence against Plaintiff, and in

providing/withholding information with respect thereto, Defendants violated Plaintiff’s
constitutional right to due process and fair trial under the New York State Constitution and under
the Due Process Clause of the Fifth Amendment to the Constitution of the United States and to
be free to deprivation of liberty under the Fourteenth Amendment to the United States
Constitution.

96. As a result of the foregoing, Plaintiff sustained, inter alia, loss of the right
to due process and a fair trial, loss of liberty, emotional distress, embarrassment and humiliation,
and deprivation of his constitutional rights.

97. Defendants were at all times agents, servants, and employees acting within
the scope of their employment by the City of New York and the New York City Police
Department, which are therefore responsible for their conduct.

98. The City, as the employer of the officer Defendants, is responsible for their
wrongdoing under the doctrine of respondeat superior.

99. As a result of the aforementioned conduct of Defendants, Plaintiff sustained

injuries including, but not limited to: economic, emotional, and psychological injuries.

TENTH CAUSE OF ACTION

Malicious Prosecution

100. The Plaintiff repeats, reiterates, and re-alleges the foregoing paragraphs as
if the same were fully set forth at length herein.

101. The acts and conduct of the Defendants constitute malicious prosecution
under the United States Constitution.

102. Defendants commenced and continued a criminal proceeding against

Plaintiff.

103. There was actual malice and an absence of probable cause for the criminal
proceeding against Plaintiff and for each of the charges for which he was prosecuted.

104. The prosecution and criminal proceedings terminated in Plaintiff’s favor on

the aforementioned dates.

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 ELEVENTH CAUSE OF ACTION
Violation of Article I, § 12 of the New York State Constitution

105. Plaintiff repeats, reiterates, and re-alleges each and every allegation
contained in the above paragraphs with the same force and effect as if fully set forth herein.

106. Such conduct breached the protections guaranteed to plaintiff by the New
York State Constitution, including but not limited to, Article 1, §§ 1, 6, 8, 9, 11, and 12, and
including the following rights:

i. freedom from unreasonable search and seizure of her person and property;
ii. freedom from arrest without probable cause;
iii. freedom from false imprisonment, that being wrongfully detained without
good faith, reasonable suspicion, or legal justification, and of which
wrongful detention plaintiff was aware and did not consent;
iv. freedom from the lodging of false charges against him by police officers
and prosecutors, including on information and belief, by some or all of
the individual defendants; and
v. freedom from deprivation of liberty without due process of law.

107. As a direct and proximate result of defendants’ deprivations of Plaintiff’s

rights, privileges, and immunities guaranteed by the New York State Constitution, Plaintiff
suffered physical, economic and emotional injuries, as well as a deprivation of liberty.

108. As a result of the above tortious conduct, Plaintiff was caused to suffer
physical, economic, and emotional injuries, as well as a deprivation of liberty.

109. As a result of the above unconstitutional conduct, the City of New York is
liable for the conduct of the Individual Defendants and any damages they caused under the
doctrine of respondeat superior.

JURY DEMAND
126. Plaintiff hereby demands trial by jury of all issues properly triable thereby.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff PRAKASH CHURAMAN demands judgment against

the defendants on each cause of action in amounts to be determined upon the trial of this action
which exceeds the jurisdiction of lower courts, inclusive of punitive damages and attorneys’ fees
inclusive of costs and disbursements of this action, interest and such other relief as is appropriate
under the law, and that the Plaintiff recover the cost of the suit herein, including reasonable
attorney’s fees pursuant to 42 U.S.C. § 1988.

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Dated: New York, New York
January 10, 2023

By:
Cary London, Esq.
Shulman-Hill, PLLC
Attorneys for Plaintiff
1 State Street Plaza
15th Floor
New York, New York 10004
(212) 203-1090

TO: THE CITY OF NEW YORK, Corporation Counsel, 100 Church Street, NY, NY 10007

NYPD POLICE DETECTIVE DANIEL GALLAGHER, Tax ID No. 925326, NYPD

113th Precinct Detective Squad; 167-02 Baisley Boulevard, Jamaica, NY 11434

DETECTIVE BARRY BROWN Tax ID No. 911490, 113th Precinct Detective Squad;
167-02 Baisley Boulevard, Jamaica, NY 11434

NYPD DETECTIVE REBECCA H. SCHMITT, Shield No. 1358, 113th Precinct Detective
Squad; 167-02 Baisley Boulevard, Jamaica, NY 11434

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 ATTORNEY'S VERIFICATION

CARY LONDON, an attorney duly admitted to practice before the Courts of the

State of New York, affirms the following to be true under the penalties of perjury:

I am a partner of the law firm of SHULMAN-HILL PLLC, I have read the annexed
VERIFIED COMPLAINT and know the contents thereof, and the same are true to my
knowledge, except those matters therein which are stated to be alleged upon information and
belief, and as to those matters I believe them to be true. My belief, as to those matters therein
not stated upon knowledge, is based upon facts, records, and other pertinent information
contained in my files. The reason this verification is made by me and not Plaintiff is because
Plaintiff does not reside in the county wherein I maintain my office.

DATED: New York, New York

January 10, 2023

______________________________
CARY LONDON, ESQ.

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