In People v. Denise L., 159 Misc 2d 1080, 608 N.Y.S.2d 40 (Crim Ct, Queens County 1994) the accusatory instrument alleged that a police officer observed the defendant for a period of twenty minutes, that there had been more than twenty arrests at that location in a two-week period, that the defendant stopped three vehicles driven by lone male motorists and carried on conversations with them, that this was not a livery location, and that the defendant's conduct obstructed vehicular traffic. Though these allegations were the type that could be facially sufficient, the court found the complaint defective for failing to include so-called "Dumas" language (see People v. Dumas, 68 N.Y.2d 729, 497 N.E.2d 686, 506 N.Y.S.2d 319) to establish the officer's training and experience in identifying prostitution-related activity, and granted the People leave to replead.