In the Matter of the Claim of COREY PEGUES Claimant, NOTICE OF CLAIM ~against- ‘THE COUNTY OF NASSAU and THOMAS C. KRUMPTER, as Acting Police Commissioner, Police Department County of Nassau, being sued individually and in his official capecity as an employee of THE COUNTY OF NASSAU Respondents’ To: Respondents’ THE COUNTY OF NASSAU and THOMAS C. KRUMPTER 1 West Street Mineola, NY 11023 82 iT UY 6 030 HW ISSYNPLEASE TAKE NOTICE THAT Claimant COREY PEGUES, do hereby make the following claim for damages, injunctive relief and declaratory relief against Responklents’ THE CITY OF NEW YORK; WILLIAM J. BRATTON; JOSEPH I. REZNICK; THE COUNTY OF NASSAU; THOMAS C. KRUMPTER and THE NEW YORK POST as follows: 1. Claimant is an African-American Male 2 Claimant, prior to his retirement in April 2013, he was employed as a Deputy Inspector with the Police Department City of New York (NYPD), 3. Claimant alleges prior to his retirement, he appeared at the New York City Police Pension Section, Respondent THE CITY OF NEW YORK through its agents in the Employee Management Division, issued him a “Good Guy Letter.” 4. Claimant alleges he passed Respondent THE CITY OF NEW YORK’ pre- retirement background investigation aka “Round Robin” and received the “Good Guy Letter” ‘meaning there were “no open investigations criminal or otherwise” against him 5. Claimant alleges a “Good Guy Letter” is analogous to receiving an “Honorable Discharge” or DD214 as issued by the United States Department of Defense. 6. Claimant alleges based upon Respondent THE CITY OF NEW YORK issuing him a “Good Guy Letter” Respondent THE COUNTY OF NASSAU issued him a FULL UNRESTRICTED Concealed Carry Law Enforcement Pistol License through its Pistol License Section. 7. Claimant alleges upon retirement, he became very “politically active” using his many years of law enforcement training and life experiences publicly lobbying for police reform,8. Claimant alleges most of his public lobbying efforts include press conferences, community discussions, ete. 9. Claimant alleges the New York City Patrolman’s Benevolent Association and others like it are publicly very critical of his lobbying efforts 10, Claimant alleges prior to retirement, he began creating his memoir for publication believing his life experiences might have a positive impact upon others. 11. Claimant alleges on August 13, 2014, consistent with his other public lobbying efforts, he appeared on The Combat Jack Show. The show is titled: The Corey ‘Life’ Pegues — “From the Streets to the Beat.” 12, Claimant alleges on the show, he discussed his childhood living on the Southside of Jamaica, Queens, within a working class family disadvantaged economically along with alcoho! abuse in the household. During the discussion, he talked about becoming less-focused, running the streets getting involved in questionable conduct and criminal activites. The main takeawey, he discusses how despite the aforementioned adversities, he changed and so can the listeners. In other words, your past life does not have to define you. The discussion then focused on “political” controversies involving alleged police-related misconduct, He particularly focused on cases involving African-American Males such as, ‘Abner Louima, Sean Bell, Eric Gamer and Oscar Grant, He publically called Eric Garner's death, a murder. 13. Claimant alleges on September 8, 2014, Defendant THE NEW YORK POST featured him on its front page as a “Thug Cop.” Inside of the publication, Defendant THE NEW YORK POST featured an article titled: “A retired cop’s shocking life of drugs and crime.” Both titles, “intentionally” signals and misleads the reader into “falsely” believing he‘was involved in criminal acts while employed as a police officer, Additionally, Defendant ‘THE NEW YORK POST “intentionally” misrepresented the content of his interview on The Combat Jack Show, as well as the basis for the receipt of his Line of Duty Accidental Disability Retirement Pension. 14, Claimant alleges Defendant THE NEW YORK POST “intentionally” fabricated the basis for the receipt of his Line of Duty Accidental Disability Retirement Pension as well as other “intentional” misrepresentations to generate newspaper and advertising revenue for Defendant THE NEW YORK POST et the expense of his reputation in the community. 15. Claimant alleges later that evening, Respondent THE COUNTY OF NASSAU through Respondent THOMAS C. KRUMPTER as a “political favor” to Respondents? THE. CITY OF NEW YORK and WILLIAM J. BRATTON sent officers to his home and seized his firearms although he violated no conditions of the FULL UNRESTRICTED Concealed Carry Law Enforcement Pistol License issued by Respondent THE COUNTY OF NASSAU through its Pistol License Section. 16. Claimant alleges the officers told him, “The weapons are being seized for violating the “Good Conduct" clause of the pistol license.” 17. Claimant alleges on September 9, 2014, Respondent THOMAS C. KRUMPTER told Defendant THE NEW YORK POST interviewer “This is in my authority to do this, and if [Pegues] doesn’t like it, he can take me to court and sue me.” 18, Claimant alleges Respondent THOMAS C. KRUMPTER told a colleague, he was honoring the NYPD’ request19. Claimant alleges on September 9, 2014, Respondent THE COUNTY OF NASSAU through its Pistol License Section served him with No of Initis! Pistol License Suspension; however, the notice DOES NOT allege the basis for the suspension or provide ‘him with a hearing date to challenge the suspension. 20, Claimant alleges on December 6, 2014, Respondent THE CITY OF NEW YORK through Respondents’ WILLIAM J. BRATTON and JOSEPH J. REZNICK sent him an undated leter in essence “revoking” bis “Good-Guy” Status demanding the retur of his police department identification card referencing the September 8, 2014, Defendant THE NEW YORK POST article. 21. Claimant alleges Defendant THE NEW YORK POST “intentionally” published “false and misleading” articles about him in support ofits “unabashed” support for law enforcement. 22, Claimant alleges Respondents’ THE CITY OF NEW YORK; WILLIAM. BRATTON; JOSEPH J. REZNICK; THE COUNTY OF NASSAU; THOMAS C. KRUMPTER and Defendant THE NEW YORK POST violated his First Amendment Right to Freedom of Speech discussing police reforms, in particular, calling Eric Gamer's death a murder. In retaliation, they collectively violated his civil rights by “intentionally” suspending his pistol license, “revoking” his police identification and damaging his reputation in the community. 23. Claimant alleges Respondents’ THE CITY OF NEW YORK; WILLIAM J, BRATTON; JOSEPH J. REZNICK; THE COUNTY OF NASSAU; THOMAS C. KRUMPTER and Defendant THE NEW YORK POST'S actions caused him to sustain substantial damages.| therefore present this claim for adjustment and payment. You are hereby notified that unless itis adjusted and paid within the time provided for under the General Municipal Law, 1 intend to commence another action against Respondents’ THE COUNTY OF NASSAU and THOMAS C. KRUMPTER, Dated: December 8, 2014 ‘New York, NY : PEGUES vVERIFICATION STATE OF NEW YORK ) ) ss COUNTY OF NASSAU ) Corey Pegues, being duly swom deposes and says: That he is the Claimant in the within Notice of Claim; that he has read the foregoing Notice of Claim and knows the contemts thereof; that the same is true to his own knowledge and belief, and that as to those matters she believes to be true oper PEGUES y On the day of December 2014, before me, the undersigned, personally appeared COREY PEGUES, personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that she executed the same in her individual capacity and that by her signature on the instrument, the individual, or the person upon behalf of which the individual acted, executed the instrument, ONKK Assi n Notary Publi, State of New Yo ON, O1ABE2BGzE Qualified in Nassau County Commission Expires Jan-27, 20