PLOTKIN, Judge.
The issue herein, is what type of notice of trial must an unrepresented litigant receive, in order to meet the requirement of procedural due process. We hold that, when the address of the litigant is known, the unrepresented litigant must receive written notice of trial, either from the court or from his former attorney, at the time the court authorizes his withdrawal as attorney of record.
Defendant, Harold Doley, appeals a judgment rendered...
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