In Au-Yang v. Barton (1999) 21 Cal.4th 958, trial was set for October 12, 1995, but the trial date was subsequently advanced to August 10, 1995. Defendant was not notified of the new date and the trial proceeded in his absence. The California Supreme Court discussed the notice of trial requirement and held that Code of Civil Procedure section 594, subdivision (a), precludes trial of a factual issue when a party is absent unless it is shown that the absent party had 15 days' notice of trial. The court commented: "Whatever considerations of fairness and policy may support permitting a trial to go forward in the absence of the opposing party when a properly noticed trial date is continued, they do not apply when a trial date is instead advanced without giving the absent party the statutory 15-day notice. When a trial, previously set for one date, is continued to a later date, the absent party's opportunities to plan and prepare for trial and to be present at trial are unlikely to be harmed, for it will have completed its preparations by the previously scheduled date. This is true even if the party is unaware of the continuance, for in that case it will have completed its preparations by the original trial date and simply by appearing at that time it will learn of the new time for trial." (Id. at p. 965.)