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3 Day Notices in Commercial Leases Must Comply With the Terms of the Lease

Proper service of a valid notice to pay rent or quit is a prerequisite to an unlawful detainer action.  (Bevill v. Zoura (1994) 27 Cal.App.4th 694, 697).  “Because of the summary nature of an unlawful detainer action, a notice is valid only if the lessor strictly complies with the statutorily mandated notice requirements.”  (Id. (emphasis added)).  In fact, proper service of a notice to pay rent or quit is a necessary element of the UD Claim.  (See CACI No. 4302 [“To establish this claim, [plaintiff] must prove all of the following: …. That [plaintiff] properly gave [defendant] three days’ written notice to pay the rent or vacate the property”;  See also CACI No. 4304 (Sufficiency and Service of Notice of Termination for Failure to Pay Rent)). The unlawful detainer statutes have strict requirements governing

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