Legal Question in Civil Litigation in California

A litigant who represents itself "Pro Per" is the attorney of record. If the Pro Per defendant filed the response to the summons and complaint, that person remains the "attorney of record" until a Substitution of Attorney form is filed with the court. The defendant can, however, have an attorney advising him or her, but until the attorney files the Substitution of Attorney, the attorney does not formally represent the client before the court.