gotta take the tray out. I believe I had to use a few extensions to get it out.
I dont have a pic of the drivers side(with battery), but you need to take it all out so you can easily get to the bolts.
One bolt takes the battery out and 3 I believe for the tray.
edit:
Found some more pics. And I was right, its one for the battery and 3 for the tray.

_________________
LOST KJ'S
Where are you going???
Current Jeep: 2004 Jeep Liberty
-Atlantic Blue
-Air Ride Rear Suspension ; OME/Rustys Lift ; Powertrax Locker ; Moog Lower Ball-Joints ; 245/70/16 Yokohama Geolander A/T-S's on MOABS ; Flowmaster 50 SUV
Lost #007082
http://www.cardomain.com/id/jeepjeepster