discussed Cited as authority (rule) People v. Burnett (Shamar) (2×) Since there was no written motion to dismiss the accusatory instruments based on statutory speedy trial grounds before the court, and the People were not put on notice that the court was contemplating dismissal of the accusatory instruments on that ground, the District Court improperly sua sponte dismissed the accusatory instruments ( see People v Littles , 188 AD2d 255, 256 [1992]; Ramos , 94 AD2d at 708; People v McKiver , 24 Misc 3d 78, 79 [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2009]; People v Salanardi , 23 Misc 3d 139[A], 2009 NY Slip Op 50966[U] [App Term, 2d Dept, 2d, 11th & 13th…

discussed Cited "see, e.g." People v. Sullivan Whether the dismissal was upon the court’s own motion or the defendants’ oral motion, there must be strict compliance with the procedural requirements of CPL 210.45, namely, "reasonable and specific notice to the People and a hearing 'in order for there to be full development of the issues and an adequate opportunity for the People to contest the specific grounds asserted for dismissal’ ” (People v Jack, 117 AD2d 753, 753-754 , quoting from People v Vega, 80 AD2d 867 ; see also, People v Ramos, 94 AD2d 708 ).