Yes, the trick is to first remove the edge of the side material that curls into the channel of the back panel edge. It helps to pry up on this edge from the bottom with a thin screwdriver and work upwards. A seat that hasn't been apart for a while will be very sticky at this seam, almost as though it's glued together.

The plastic rack and pinion mechanism that operates the headrest is usually the problem. The fix should be obvious once the back panel is off.

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95 E320 Cabriolet, 169K