[COURT NAME]
[COUNTY], [STATE]
[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )
MOTION TO WITHDRAW AS COUNSEL
NOTICE OF MOTION AND MOTION
PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING COUNSEL] will and hereby does move the Court for an order permitting withdrawal as counsel for [CLIENT NAME].
MEMORANDUM OF POINTS AND AUTHORITIES
I. Introduction
Good cause exists for withdrawal, and [CLIENT NAME] has been provided notice of this motion and the hearing date.
II. Background
- Representation began: [DATE]
- Status of case: [DISCOVERY/TRIAL DATE/DEADLINES]
- Efforts to address issues: [SUMMARY WITHOUT CONFIDENTIAL DETAILS]
III. Legal Standard
Withdrawal is permitted upon a showing of good cause and compliance with applicable rules, including reasonable notice to the client and steps to avoid foreseeable prejudice.
IV. Argument
A. Good cause exists for withdrawal.
[State reasons without disclosing privileged information, such as irreconcilable differences or nonpayment.]
B. Withdrawal will not unduly prejudice the client or other parties.
[Explain upcoming dates and whether a stay or continuance is requested.]
C. Notice has been provided.
[Describe service of this motion on client and opposing counsel.]
V. Requested Relief
[MOVING COUNSEL] respectfully requests that the Court:
1. Grant leave to withdraw as counsel for [CLIENT NAME].
2. Order that [CLIENT NAME] appear pro se or through substitute counsel by [DATE].
3. Stay proceedings for [NUMBER] days, if necessary, to allow substitution.
CONCLUSION
For the foregoing reasons, the Court should grant the motion to withdraw as counsel.
Respectfully submitted,
text
Dated: [DATE]
______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [CLIENT NAME]
CERTIFICATE OF SERVICE
I certify that on [DATE], I served the foregoing Motion to Withdraw as Counsel on [CLIENT NAME] at [CLIENT ADDRESS] and on all counsel of record via [METHOD OF SERVICE].
text
______________________________
[ATTORNEY NAME]
[PROPOSED] ORDER
The Court, having considered the Motion to Withdraw as Counsel, ORDERS as follows:
1. The motion is GRANTED.
2. [CLIENT NAME] shall appear pro se or through substitute counsel by [DATE].
3. [IF APPLICABLE] Proceedings are stayed until [DATE].
IT IS SO ORDERED.
Dated: [DATE]
__________________________________
[JUDGE NAME]
[STATE] Judge