In People v. McGinnis, 42 Misc 3d 183 (Crim Ct, NY County 2013) the defendant was charged with Loitering for the Purpose of Engaging in Prostitution. The court discussed at length the form and content of the accusatory instrument and a preprinted, check-off type supporting deposition. The facts alleged in the complaint mirrored those supplied in the supporting deposition. In granting the defendant's motion to dismiss, the court held that a complaint which only alleged that the defendant, who was previously arrested for prostitution, was observed talking to three individuals late at night in an area frequented by prostitutes was facially insufficient. Most critically, the court did not hold that the use of a preprinted form was prohibited. Rather, the court explained that its lengthy discussion of the preprinted form was done only to stress "the need for an individualized recitation of facts which set forth the elements of an offense based upon the actual observations of the deponent in a given case." Id. at 192-193.