In White Angel Realty v. Asian Bros. Corp., 183 Misc 2d 674, 706 NYS2d 583 [Nassau Dist Ct 2000], in determining the sufficiency of a notice of termination, the Court held that it may look beyond the four corners of the termination notice to determine whether the appropriate legal requirements have been met.

The Court noted that the landlord is permitted to demonstrate not merely that the agent was authorized in a writing which accompanied the notice, or that the agent was named in the lease, but that previous dealings between the tenant and the agent can be used to establish the tenant's knowledge of and acquiescence in the agency.