July 16, 2014
Parking Ticket Appeal
Addendum to Section C
The original judge made mistakes of law and fact when reaching his
ﬁnding of guilty, and his decision should be reviewed and reversed.
In August 2013, I moved to Pennsylvania from Oklahoma to work for
The National Park Service at the Delaware Water Gap National
Recreation Area as the chief of maintenance and facility management.
I have never visited the Great State of New York, or New York City in
my entire life, nor has my Toyota Corolla listed on the parking
However, I received a parking ticket in the mail alleging that I violated
a NYC parking rule by parking my Toyota (I'm the registered owner,
and the only person that has access to the car) in a safety zone
located on the North Side of Randall Avenue, Bronx, 75 feet West of
Zerega. Despite the fact that there isn't a safety zone anywhere to be
found on Randall Avenue between Havemyer Avenue and the T
intersection of Zerega Avenue.
However, there is a safety zone on Zerega Avenue.
I contested the parking ticket, informed the court that I've never been
to NYC, nor has my Toyota ever travelled to NYC. And, neither I nor
the Toyota was parked at that location.
J OE SMITH
The judge found me guilty of parking in a non-existent safety zone,
despite the fact that neither my car nor I have even been in New York
According to the E-book published by the Adjudication Unit of the
Parking Violation Bureau, there is a promise made to the public to
review every parking ticket for missing or misdescribed required
elements (such as place of occurrence). This promise was broken and
the parking ticket was sustained.
In addition, Pennsylvania requires motorists to afﬁx the month and
year registration expires on Pennsylvania license plates. The month/
year was displayed on my Toyota plate (registered in Pennsylvania) on
the date this parking ticket was issued. However, the TEA did not
enter this information on the parking ticket. Instead, the TEA again
blundered and checked "N/S." This is also a required element that
must be entered on a NYC parking ticket when displayed on an out-
This is a Google Map Street View image of the T
intersection of Zerega Avenue and Randall Avenue, Bronx, NY
This is a Google Map Street View image of Zerega Avenue at the T
intersection with Randall Avenue, showing the safety zone on Zerega
Avenue, not Randall Avenue!
I fully understand that when a driver parks his car in NYC, they are
submitting to the jurisdiction of NYC and NY to enforce its rules of the
road. But, I never drove my car in NYC or NY, ever. Neither me nor my
Toyota have ever parked in NYC. There is no jurisdictional basis or
authority to issue this parking ticket.
This is a Google Map Street View image of Randall Avenue looking
down the block to the T intersection with Zerega Avenue. There is no
safety zone on the entire block.
The only reason the parking ticket found its way to my home in
Pennsylvania was because the TEA entered the wrong license plate
number (another mistake) on the defective parking ticket, that had a
missing and misdescribed required element (month/year of
registration expiration, and place of occurrence).
Due to these circumstances, please right this wrong and dismiss this