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Mine does this from time to time. I can only assume but I'm thinking that the E brake gets seized slightly and needs some encouragement to release. My driveway is sloped a bit so it gets some help from gravity when I'm trying to back out. I have the MT and sometimes when I release the E brake in N the car doesn't move. I can usually rock back and forth in my seat and it will brake free and start rolling back. I wouldn't worry too much about it.
Mostly happens if I wash the car in the driveway and then let it sit for a while, drying the brake dust residue onto the brake pad and rotor.
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