NO. 123456

THE STATE OF TEXAS	§		IN THE _____ DISTRICT COURT
§
V.	§		OF
§
JOHN DOE	§		____________ COUNTY, TEXAS

MOTION TO WITHDRAW

TO THE HONORABLE JUDGE OF SAID COURT:

     NOW COMES Movant, PATRICK S. METZE, Attorney of Record for the Defendant, JOHN DOE, in the above styled and numbered cause, who would file this Motion to withdraw as counsel in the present cause, and show unto the Court as follows: I.	Movant has ethical considerations which prevent his further representation of the Defendant.  These considerations reduce the ability of present counsel to provide adequate representation to the Defendant within ethical bounds, and renders an ongoing attorney/client relationship impossible. 
						 II.
	Movant will notify the Defendant of his intent to withdraw.  The last known address of the Defendant is set out below in the Certificate of Service below.  A copy of this motion will be sent to that address.  The Defendant is hereby notified in writing of his right to object to the motion.  Movant does not know if the Defendant objects or not to this motion.  

III.
	This case is presently set for a plea negotiation conference for October 1, 2004. 
IV.
The granting of this Motion to Withdraw will not jeopardize the rights of the Defendant.  The requested withdraw is not for the purposes of delay.  Defendant has ample opportunity to employ  counsel, represent himself or request court appointed counsel.  

	WHEREFORE, PREMISES CONSIDERED, Movant prays that this Honorable Court allow the withdrawal of counsel, and that present counsel be released from further obligation or duty to the Defendant as Attorney of Record.

                     			RESPECTFULLY SUBMITTED,

                     			___________________________
                     		
					Movant/Attorney for Defendant

										

CERTIFICATE OF SERVICE

	As Attorney of Record for Defendant, I do hereby Certify that a true and correct copy of the above and foregoing document was this date provided to __________________ County Criminal District Attorney and to the Defendant, John Doe, at his last known address c/o Lubbock County Jail, P. O. Box 10535, Lubbock, Texas 79408, this 29th day of September 2004.

                         					___________________________
							Attorney for Defendant

NO. 123456

THE STATE OF TEXAS	§		IN THE _____ DISTRICT COURT
§
V.	§		OF
§
JOHN DOE	§		____________ COUNTY, TEXAS

ORDER

     BE IT REMEMBERED, that on the ______ day of ______ 2004, came on to be considered the above and foregoing Motion to Withdraw by Defendant’s Attorney.  After consideration of the same, it is the opinion of the Court that the same be:

     (  ) DENIED.

     (  ) GRANTED, IT IS ORDERED, ADJUDGED AND DECREED, that the said Attorney, _________________, shall be allowed to withdraw as counsel, and is hereby relieved of any further duty, obligation or responsibility to Defendant herein: JOHN DOE.

    (  ) SET FOR HEARING ON THE ______ day of _______________, ____, at ______ o'clock ____.

     SIGNED: ___________________, 2004.

                                   _________________________
                                    Judge Presiding