A motion to remove counsel from the record is sometimes required when a client fails to pay for services, exhibits some sort of lack of confidence in counsel, or otherwise breaks the solicitor-client relationship down such that it is impossible to continue to represent the client. Clients in this position will often attempt to retain counsel by refusing to liberate counsel from the record. In these situations, the Court must liberate counsel pursuant to rule 15.04.

• Motion record covering page
• Notice of motion to remove counsel
• Draft order to remove counsel