Ambalal Chandubhai Patel petitions for review of the Board of Immigration Appeals’ summary affirmance of an immigration judge’s (“IJ”) order denying his motion to reopen deportation proceedings conducted in absentia. Because the transitional rules apply, see Kalaw v. INS, 133 F.3d 1147, 1150 (9th Cir.1997), we have jurisdiction under former 8 U.S.C. § 1105a(a). We review for abuse of discretion. Garcia v. INS, 222 F.3d 1208, 1209 (9th Cir.2000) (per curiam). We deny the petition for review. The IJ did not abuse his discretion in denying Patel’s motion to reopen because the record shows that his former counsel of record received proper notice of Patel’s deportation hearing held on August 24, 1995. See 8 C.F.R. § 1008.26 (formerly 8 C.F.R. § 3.26); Garcia, 222 F.3d at 1209 (<HOLDING>). The remaining contentions lack merit.
holding that notice to the attorney of record constitutes notice to the petitioner holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice holding that notice to original attorney not formally withdrawn comprised proper notice holding that a defendant is not entitled to relief from default judgment because notice to an attorney of filing of motions and orders is constructive notice to the client even when the client did not have actual notice holding that notice to supervisor is notice to city