Metes and Bounds Description of Place of Occurrence can be Beaten

Last Updated on April 13, 2022 by Lawrence Berezin

Metes and bounds description of the place of occurrence can be a true friend of the NYC driving public

If ignored, a metes and bounds description can be like the pit of misery.

I absolutely love the Bud Light commercials where the king gets presents from his adoring countrymen. The first two people in line give the king his beloved Bud Light. But, the third guy offers a special bottle of wine and is immediately escorted to the pit of misery. Dilly Dilly.

Are you a true friend of the Evil Empire? Of course not!

Then why do you grimace when you see a metes and bounds description entered on a parking ticket and ignore it? Personally, I smile because it can be a great way to beat a parking ticket.

Let’s start from the beginning

There are three ways to describe a place of occurrence (your parking space):

• Front
• Opposite
• Metes and Bounds

The first two ways are easy to understand. But, a metes and bounds description can make eyes roll because you may not understand how to translate it. Here’s a parking ticket with a metes and bounds description [click to enlarge]:

E/S Jackson Ave_20 ft S/of 44th DR in Queens means:

East Side of Jackson Avenue, 20 feet South of 44th Drive (Queens).  Pretty easy, right? But:

• How do you figure out whether the description is correct?
• If it is misdescribed, how do you prove it?

Larry’s resources of choice

The DOT Parking Regulations Map (Text Version)

Google Maps Street View

Easy-step-by-step guide to a metes and bounds description defense

[Click on image to enlarge]

First step:

Translate the metes and bounds description

E/S Jackson Ave_20 ft S/of 44th DR in Queens = East Side of Jackson Avenue, 20 feet South of 44th Drive in Queens.

Second Step

Locate Jackson Avenue and 44th Drive, Queens, on Google Maps Street View

What is the next street that intersects with Jackson Avenue and 44th Drive? Purvis Street

What is the next street that intersects with Jackson Avenue and 44th Drive in the opposite direction from Purvis Street? Court Square

Third Step

Go to the DOT parking regulations map and plug-in the variables were called for with your parking ticket.

• Queens
• Jackson Avenue
• 44th Drive
• Purvis Street and click

And then,

• Queens
• Jackson Avenue
• 44th Drive
• Court Square and click

Fourth Step

You’ll learn whether the sides of the streets run North-South or East-West. In this case, you win because the East Side (E/S) of Jackson Street does not exist.

Hopefully, in your case, the answer will prove the Warrior screwed up and misdescribed the sides of the street.

Update Alert: “Old” Parking Regulations Map Gone

The “old” parking regulations map is currently living in a retirement village at an unknown location.

You’ll find the “new” map here.

When you land, enter the intersection in the “search parking signs” bar, for example, 5th Avenue and 53 Street, NYC, and click away.

You’ll be magically transported to:

Click on one of the green buttons showing the signs on support.

A drop-down menu will appear that advises those signs live on the EAST SIDE of 5th Avenue. Likewise, click on the green button on the opposite side of 5th Avenue, and it shows the signs are on the WEST SIDE of 5th Avenue.

Now, you can prove that 5th Avenue runs NORTH AND SOUTH, while the sides of the street on 5th Avenue are EAST and WEST.

How to prepare your defense certification and exhibits

Here’s a template to follow for your defense certification;

Dear Honorable Judge,

I hereby certify as follows:

I plead not guilty to this parking violation because:

-The Place of Occurrence was misdescribed

The TEA entered, “E/S Jackson Avenue_20’ S of 44th Drive, Queens.” The East Side of Jackson Avenue does not exist

I have submitted a series of exhibits in support of my defense.

Due to this circumstances, please dismiss this 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 of the parking ticket, DOT Parking Regulations Map (text version), and Google Maps Street View are true and accurate reproductions of the originals as they existed on the date/time this parking ticket was issued.

Respectfully submitted,

I suggest you make screen grabs of the four exhibits above, but to the specifications and details of your parking ticket case.

How do you fare fighting fire hydrant parking tickets? Need a refresher? Click here. to learn five mistakes to avoid at all costs.

Commentary

Dilly Dilly.

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