Attorneys should always note their appearance in writing in a case. A Virginia Bar ID number should be included. Once an appearance is entered in a case, counsel may not withdraw without leave of court, after notice to the client. Substitution of counsel may be made by letter to the court stating the substitution is made pursuant to agreement by the parties represented and original counsel (see §16.1-69.32:1 of the Code of Virginia). This also applies when filing a garnishment or other collection action, on which an attorney was not the original attorney.