DECISION AND ORDER
*1 The defendant stands charged with Aggravated Unlicensed Operation of a Motor Vehicle in the Third Degree in violation of VTL §511.1. In a pretrial omnibus motion, defendant seeks an order: 1) dismissing the information as facially insufficient pursuant to CPL 100.40; 2) dismissing the information pursuant to a speedy trial violation under CPL §30.30; 3) dismissing the information in the interests of justice pursuant to CPL §170.40; and 4) reserving to defendant the right to make additional motions as necessary. The People oppose this motion. The simplified information alleges that on April 18, 2017, at approximately 6:15 p.m., the defendant was driving a motor vehicle in the City of Mount Vernon in violation of VTL §511.1. On May 18, 2017, the defendant was arraigned on the accusatory instrument and released on his own recognizance. The defendant was arrested on May 23, 2017 on a very serious unrelated matter and has been incarcerated in that case since that date. On October 11, 2017, at the defendant’s request, this Court set bail in the instant matter so that the defendant would receive credit for the time that he’s incarcerated.Defendant first moves to dismiss the charge on facial insufficiency on the ground that he has not been served with a supporting deposition more than six months after his arraignment. As defined in CPL §100.10(2), a simplified traffic information is a streamlined instrument designed for the expeditious processing of traffic infractions; it is a short, written accusation, signed by a police officer and filed with a criminal court. Evidentiary facts are not required. To be facially sufficient, the instrument must also comply with the requirement of CPL 100.25.(1) that it be substantially in the form prescribed by the commissioner of motor vehicles.”VTL §511(1)(a) provides that “[a] person is guilty of the offense of aggravated unlicensed operation of a motor vehicle in the third degree when such person operates a motor vehicle upon a public highway while knowing or having reason to know that such person’s license or privilege of operating such motor vehicle in this state is suspended, revoked or otherwise withdrawn by the commissioner.”A traffic action can be commenced by a simplified information; and that instrument is jurisdictionally sufficient to enable prosecution of the action, provided that it is issued in the form required by the statute and by an officer authorized to do so under the statute (CPL §§1.20(5) and 100.10(2). However, since a simplified information does not provide any evidentiary facts with respect to the charge, it does not establish reasonable cause for the charge against the defendant (see, People v. Abajian, 142 Misc2d 250, 256 [justice Court, Village of South Nyack, 1989]). Accordingly, the Legislature has given the defendant an absolute right to obtain a deposition from the arresting officer, setting forth sufficient facts to establish a reasonable cause for the charge, although not necessarily a prima facie case sufficient to go to trial (People v. Hohmeyer, 70 NY2d 41, 43 [1987]).If demanded in accordance with the statute, the defendant must be provided with the supporting deposition within 30 days of the demand, or else the charges against him must be dismissed (People v. Nuccio, 78 NY2d 102 [1991]). The defendant must make a timely request for the deposition, either (1) at the arraignment or (2) within 30 days of entry of [a] his plea of not guilty or [b] written notice that he is entitled to receive a supporting deposition (CPL §100.25(2). If the defendant does not make a timely request, his right to receive the supporting deposition is deemed waived (People v. Clark, 142 Misc.2d 544 [Justice Ct., Town of Arcadia, 1988]).Given the spare standards applicable to simplified traffic informations, and since there is no indication that the
