In People v. Roberts-Alexandrov, 102 AD3d 219 [3d Dept 2012]) the issue in was whether the designation of the Easton Town Court as the receiving court in the intrastate order of transfer deprived the Washington County Court of subject matter jurisdiction over the defendant's misdemeanor probation sentence. The defendant's offending conduct occurred in Washington County. Noting that "an appropriate court to receive a misdemeanor probationer is a 'criminal court' (CPL 410.80 [2]), which includes a superior court such as County Court, as well as various other courts (see CPL 1.20 [19]; 10.10)" (id. at 221), the Roberts-Alexandrov court held that "County Court had the power to hear the matter, and the error in the transfer order was similar to a venue or ministerial error that did not deprive County Court of subject matter jurisdiction" (id. at 222).