Page 1 of 5 

Paul Garrett, et al. v. Ron's Towing, Inc. 

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1853-E 

Joint Motion to Extend Mediation Deadline

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

PAUL GARRETT, Individually and on PLAINTIFF

Behalf of all Others Similarly Situated

vs. No. 3:22-cv-1853-E 

RON'S TOWING, INC. DEFENDANT

JOINT MOTION TO EXTEND MEDIATION DEADLINE

Plaintiff Paul Garrett (“Plaintiff”), individually and on behalf of all others 

similarly situated, and Defendant Ron’s Towing, Inc. (“Defendant”), by and 

through their undersigned counsel, submit the following Joint Motion to 

Extend Mediation Deadline: 

1. Pursuant to the Court’s Mediation Order (ECF No. 26), the 

Parties were to mediate this case by September 29, 2023. 

2. Due to the availability of the Parties and their counsel, the Parties 

have been unable to schedule and participate in a mediation prior to the 

mediation deadline. 

3. The Parties through their counsel have worked together in trying 

to schedule the mediation, and they have confirmed their availability to 

Case 3:22-cv-01853-E Document 28 Filed 09/29/23 Page 1 of 5 PageID 109
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Paul Garrett, et al. v. Ron's Towing, Inc.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1853-E

Joint Motion to Extend Mediation Deadline

participate in a mediation on November 8, 2023, which was one of the 

available dates previously provided by the Mediator. The Parties have 

requested that the Mediator reserve the date for their mediation but are 

awaiting confirmation that the date is still available. 

4. The Parties respectfully request that the mediation deadline be 

extended to November 30, 2023. 

5. The Parties will participate in mediation in good faith as required 

by the Court and with the previously selected Mediator.

6. This request is made in good faith and not for the purpose of 

delay. This extension should not interfere with the other deadlines in this 

case. 

WHEREFORE, premises considered, the Parties respectfully request 

an order of this Court granting the Joint Motion to Extend the Mediation 

Deadline, and for such other relief as may be just and proper. 

Respectfully submitted,

PAUL GARRETT, Individually 

and on behalf of All Others 

Similarly Situated, PLAINTIFF

FORESTER HAYNIE, PLLC

400 North Saint Paul Street, Suite 700

Dallas, Texas 75201

Telephone: (214) 210-2100

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Paul Garrett, et al. v. Ron's Towing, Inc. 

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1853-E 

Joint Motion to Extend Mediation Deadline

 /s/ Colby Qualls 

Colby Qualls

Ark. Bar No. 2019246 

cqualls@foresterhaynie.com 

Katherine Serrano

Tex. Bar No. 24110764

kserrano@foresterhaynie.com 

Matthew McCarley

Tex. Bar No. 24041426

mccarley@foresterhaynie.com 

SANFORD LAW FIRM, PLLC

10800 Financial Centre Pkwy, 

 Ste. 510

Little Rock, Arkansas 72211

Telephone: 501-221-0088

Facsimile: (888) 787-2040

 

 Josh Sanford

 Tex. Bar No. 24077858

josh@sanfordlawfirm.com 

and RON’S TOWING, INC., 

DEFENDANT

WT SKIP LEAKE PC

350 Westpark Way, Ste. 205

Euless, Texas 76040

P.O. Box 1910

Euless, Texas 76039

Phone: (817) 460-7711

Fax: (817) 469-7020

Donald R. Miller

TBN: 24070273

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Paul Garrett, et al. v. Ron's Towing, Inc. 

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1853-E 

Joint Motion to Extend Mediation Deadline

drmiller@leakelaw.com 

W.T. “Skip” Leake

TBN: 12092350

wtsleake@leakelaw.com 

J. Charlie Conway

TBN: 24092281

cconway@leakelaw.com 

HILBURN & HILBURN, APLC

220 Carroll Street, Building B

Shreveport, Louisiana 71105

(318) 868-8810

(877) 462-6796

/s/ Cary Hilburn_________ 

Cary A. Hilburn

Tex. Bar No. 00790881

cah@hilburnlaw.com 

 

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Paul Garrett, et al. v. Ron's Towing, Inc. 

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1853-E 

Joint Motion to Extend Mediation Deadline

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been 

electronically filed with the Clerk of Court on this date by using the CM/ECF 

system, which will send a notice of electronic filing to all CM/ECF 

participants, including: 

W.T. “Skip” Leake, Esq.

Donald R. Miller, Esq.

J. Charlie Conway, Esq.

WT SKIP LEAKE PC

350 Westpark Way, Ste. 205 (Euless) 76040

P.O. Box 1910

Euless, Texas 76039

wtsleake@leakelaw.com 

drmiller@leakelaw.com 

cconway@leakelaw.com 

Cary A. Hilubrn, Esq.

HILBURN & HILBURN – APLC

220 Carroll Street, Building B

Shreveport, Louisiana 71105

cah@hilburnlaw.com 

/s/ Colby Qualls _

 Colby Qualls

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