In Gerolemou v. Soliz, 184 Misc 2d 581 (App Term, 2d Dept 2000) the landlord and tenant had an oral month-to-month tenancy. The opinion makes no mention of any type of pre-commencement notice, official or unofficial, to the tenant. Thus, for all that appears, the tenant had absolutely no notice that the landlord was declaring an end to the month-to-month tenancy (and therefore it had not actually ended) and no notice that the landlord was commencing litigation prior to the litigation itself.