The Eleventh Circuit has determined that a petitioner who was served a defective Notice to Appear (missing the time and place of his first hearing) can still be ordered removed in absentia if he moved after receipt of the NTA and before issuance of a notice of hearing, but did not update the immigration court about his new address.
The full text of Dragomirescu v. Attorney General can be found here:
https://media.ca11.uscourts.gov/opinions/pub/files/202013705.pdf