136-87; see also Ontell v. Capitol Hill E.W. Ltd., 527 A.2d 1292, 1295-96 (D.C.1987) (upholding notice as adequate despite failure technically to comply with § 45-1406). In the Frank Emmet Real Estate case, a tenant informed his landlord that he was temporarily relocating to Colorado, gave him the address there, and indicated the tenant’s intent to return to live in his rented property in Washington. While the tenant was in Colorado, the landlord attempted eviction by posting a summons on the door of the Washington property and mailing a copy of the notice to the Washington address. In this way, the landlord comported with the express statutory requirements for service of summons. The court reasoned, however, that the landlord’s strict adherence to the statute was of a “woode D.C.1981) (<HOLDING>). This court suggested in Gantt that the
holding that substantial compliance with notice is sufficient holding that notice of judgment was insufficient holding that because the requirement of strict compliance with the statute obviates some of the practical difficulties of proving delivery notice to quit served by slipping under door was insufficient despite actual receipt of notice holding that upon receipt of the important notice a conclusive presumption of notice was established holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice