The following excerpt is from People v. Abreu-Tejada, 31 N.Y.S.3d 922 (Table) (N.Y. Crim. Ct. 2016):
Where, as here, a criminal action is commenced by way of a misdemeanor complaint, the People must convert the complaint into an information by filing sufficient supporting depositions ... that remove all hearsay from the complaint and thereby establish a prima facie case against the defendant. People v. Flores, 189 Misc.2d 665, 666 (Crim Ct, Queens County 2001). Requiring that a nonhearsay accusation be filed as a condition precedent is a minimal but significant indication that the prosecution is legitimate. It reduces the possibility that one could be unjustly forced to stand trial by an overzealous or negligent prosecutor based on an indirect, incomplete, or inadequately investigated accusation. People v. Phillipe, 142 Misc.2d 574, 578 (Crim Ct, Kings County 1989).
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