does a "3 day notice to pay or quit" have to be served in NY?

[David Kirchhoff]

does a "3 day notice to pay or quit" have to be served in NY?

 In the past I've just sent them in the mail or hand delivered the "3 day notice" before starting the eviction process. However, a new judge is telling me I have to have this document served like the petition and notice or petition and verification. I've never had to do this in the past. does anyone know the exact answer and where can I find it in the legal code?