In People v. Gabbay (175 Misc 2d 421, 422 [App Term, 2d Dept 1997], lv denied 92 NY2d 879 [1998]), the Appellate Term held that a parking violation was an insufficient accusatory instrument which did not allege facts in a nonhearsay form, holding the tickets should have indicated whether the complainant's information "was based on personal knowledge or information and belief." In addition, the Appellate Term also noted that verification was incomplete under CPL 100.30 and should not have read " '[a]ffirmed under the penalty of perjury' " (at 423) and should instead have read that " 'false statements made therein are punishable as a class A misdemeanor pursuant to [Penal Law 210.45]' " (at 422-423). Lastly, the court held that it is the preferred practice to impose the requirements of Vehicle and Traffic Law 238 (2) upon a parking violation. While an examination of Vehicle and Traffic Law 238 (2) appears to limit the requirements to the Parking Violations Bureau, an administrative tribunal, the Appellate Term noted such requirements are equally appropriate to those violations returnable in traditional courts as well. Therefore, although not absolutely mandatory, it is clear the requirements of Vehicle and Traffic Law 238 (2) should be included as the better practice. The requirements of Vehicle and Traffic Law 238 (2) are that all parking violations include (1) plate description, (2) plate type (passenger or commercial), (3) registration expiration date, (4) make or model, and (5) body type.