Robert Smith is pleading not guilty to a parking violation ticket. He claims that: 1) The officer failed to properly identify him by not including his name on the ticket. 2) The location described on the ticket was too vague. 3) He was briefly waiting in a designated passenger pick-up area at the airport to pick up his friend Joe, as permitted.

1. Defense Certification
Dear Honorable Judge,
I certify as follows:
I plead not guilty to this parking violation because:
-The officer failed to enter my name on the parking ticket (improper service)
-Misdescribed the place of occurrence
-I stopped briefly to pick up a passenger in the loading and unloading area at
United Airlines arriving flights Terminal B
On June 10, 2016, I picked up my friend, Joe at LaGuardia Airport in Queens.
We both live in Monroe Connecticut.
I coordinated my pick up with Joe by cell phone. He called me when he landed
and I entered LaGuardia airport and drove to United Airlines arriving flights in
Terminal B. I pulled to the curb in front of a line of cars that were parked.
Moments later a police officer pulled to the curb in front of my car. The officer
walked to my driver’s side window and asked for my license and registration. I
tried to explain that I was picking up a friend and even pointed to Joe standing
across the roadway.
The officer said it was too late. Joe ran across the roadway, yelled to the officer
that he was here, and got into my car.
The officer returned to his car for about 10 minutes and issued the parking ticket
for no standing in a loading and unloading zone.
However, the officer did not enter my name on the parking ticket even though I
was seated behind the wheel of my car.
The TEA entered a place of occurrence that did not unambiguously describe a
unique location. He entered, Laguardia Airport, Terminal B, lower level in
Queens. However, that described a huge area by Terminal B.
I briefly waited in my car in the area designated for passenger pick up. The
officer wrote on the ticket “loading unloading only.” That’s what I was doing.
1

2. Defense Certification
Attached please find a series of exhibits in support of my defense.
Due to these circumstances, please dismiss the parking ticket.
Thank you.
-I hereby certify that my testimony is the truth to the best of my knowledge. I fully
understand that if my testimony is willfully false, I am subject to punishment.
-I certify that the images contained in my exhibits are true and accurate
reproductions of what they purport to represent
-I certify that Joe's testimony was in response to my request that he write what he
witnessed when this ticket was issued. His statement was hand-written and
certified by Joe Jones
-I certify that I was seated in the driver’s seat on the date/time the officer issued
this parking ticket.
Respectfully yours,
Robert Smith
2