In People v. DeFreitas, 48 Misc 3d 569, 9 N.Y.S.3d 822 (Crim Ct, NY County 2015) the complainant's allegations were contained in a DIR, in which the complainant's statement did not include the defendant's name in the space provided and only referred to the perpetrator as "he." The accusatory instrument did not include an alleged point-out of the defendant as the perpetrator. As a result, the court in DeFreitas held that the accusatory instrument did not provide reasonable cause to believe that the defendant was the perpetrator (id. at 580-81). The Court found deficient a D.I.R. the sworn allegations of which referred only to the suspect as "he." 48 Misc 3d at 581. The Court concluded that there was no reasonable way to connect the word "he" to the defendant: the place on the supporting deposition where the suspect's name should have been written was blank, and there was no natural or obvious way of connecting the "he" referred to there to the named suspect on the other page of the D.I.R., which was filled out by a police officer, and hence hearsay. Id. at 572, 580. In addition, the D.I.R. had been completed several months before the defendant was arrested, thus there was no clear connection between the "he" mentioned in the D.I.R. and the defendant named in the misdemeanor complaint. Id. at 579.