After remand from prior appeal of orders terminating Respondent's parental rights, her appointed trial counsel renewed his motion to withdraw as her attorney. Court denied that motion and held hearing, granting State's petitions to terminate Respondent's parental rights as to her 2 children. Court had previously terminated her parental rights as to her 4 oldest children. Counsel's motion to withdraw failed to comply with Rule 13(c)(2), as it failed to advise Respondent to file a supplemental appearance within 21 days to avoid risk of being defaulted; and as Respondent did not receive adequate notice of motion and counsel did not serve her with written motion to withdraw before presenting it to trial court. (ZENOFF and HUDSON, concurring.)
Illinois Appellate Court
Civil Court
Termination of Parental Rights