on my '95 all you have to do is pull up the black plastic strip on top of the bumper and un-bolt the fender liners. Then pull straight back. I don't recall there being any screws inside the liftgate on mine.
...or you can keep snagging it on rocks like my buddy with the '96 does every time he goes wheelin', LOL
52 Willys CJ3a: stock-ish (his)
95 ZJ Laredo 4.0: removable doors, longarm, 8.8 rear, leaks, squeaks, dents, dings, etc (ours)
03 TJ Rubicon: longarm, body lift, 33" Duratracs (MINE!)