A recent decision of the Ontario Superior Court of Justice confirms that the same considerations apply to civil and family proceedings as to criminal proceedings when a court decides whether a lawyer can withdraw representation. In Froom v. Lafontaine, 2020 ONSC 5650 (CanLII) the court reviewed R. v. Cunningham, 2010 SCC 10 (CanLII) and stated at paragraph 21 that the "principles apply equally."