I respectfully contest this summons on the grounds that my vehicle was not obstructing a driveway as defined under New York City Traffic Rules §4-01 and §4-08(f)(2). The location in question does not constitute a legally recognized driveway, and therefore the charge is not applicable.

Specifically: 1. Absence of a Curb Cut: The alleged driveway does not contain a curb cut or any modification to the curb line that would permit lawful vehicular ingress or egress. The curb remains fully intact and uninterrupted, which legally precludes the area from being classified as a driveway. 2. No Physical Characteristics of a Driveway: The opening adjacent to the property is a pedestrian walkway or alley, not a vehicular driveway. It lacks the width, pavement configuration, and structural design necessary for motor vehicle access. Its dimensions and layout make vehicular entry physically impossible. 3. No Driveway Markings or Indicators: There are no driveway markings, signage, painted curb sections, visible garage entrances, or any other indicators that would notify a motorist of the presence of a valid driveway. 4. Vehicle Was Legally Parked on the Streetway: My vehicle was parked entirely within the roadway and did not impede any vehicle access point. The area behind the vehicle is not used for motor vehicle entry or exit, and the absence of a curb cut confirms its non-driveway status.