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Ismael Arreola, et al. v. Southern Industrial Contractors, LLC, et al.

U.S.D.C. (E.D. Tex.) No. 9:23-cv-50-MJT

Motion for Extension of Time for Service of Process

IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

LUFKIN DIVISION

ISMAEL ARREOLA and ISRAEL ARREOLA PLAINTIFFS

Each Individually and on Behalf of All

Others Similarly Situated

vs. No. 9:23-cv-50-MJT

SOUTHERN INDUSTRIAL CONTRACTORS,

LLC, and SAMUEL ESTIS DEFENDANTS

MOTION FOR EXTENSION OF TIME FOR SERVICE OF PROCESS

Plaintiffs Ismael Arreola and Israel Arreola (“Plaintiffs”), each individually and on 

behalf of all others similarly situated, by and through their undersigned counsel, for their

Motion for Extension of Time for Service of Process (“Motion”), state and allege as follows:

1. Plaintiffs make this request in good faith; this Motion is made for good cause 

and not for the purpose of delay. 

2. On March 14, 2023, Plaintiffs filed their Original Complaint against 

Defendants Southern Industrial Contractors LLC and Samuel Estis.

3. Plaintiffs’ original deadline to serve Defendants is June 12, 2023.

4. Plaintiffs engaged a process server on or around March 17, 2023, but efforts 

to serve Defendants have continued to be unsuccessful. 

5. The process server has tried multiple different addresses, but service has 

been unsuccessful.

6. ABC Legal Services opened an investigation to investigate possible service 

addresses. On May 31, 2023, a new service address was discovered, and a server was 

Case 9:23-cv-00050-MJT Document 3 Filed 06/09/23 Page 1 of 3 PageID #: 20
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Ismael Arreola, et al. v. Southern Industrial Contractors, LLC, et al.

U.S.D.C. (E.D. Tex.) No. 9:23-cv-50-MJT

Motion for Extension of Time for Service of Process

dispatched to that address. 

7. Plaintiffs believe that with additional time and continued diligent efforts,

Defendants will be successfully served.

8. For the good cause shown, Plaintiffs seek a 90-day extension to serve 

process on Defendants.

9. Defendants will not be harmed or prejudiced if this Court grants the relief 

requested herein. 

WHEREFORE, premises considered, Plaintiffs respectfully request that this Court 

enter an Order allowing them an additional 90 days, up to and including September 11, 

2023, in which to serve the Summons and Original Complaint on Defendants, and for any 

other relief that the Court deems just and proper. 

Case 9:23-cv-00050-MJT Document 3 Filed 06/09/23 Page 2 of 3 PageID #: 21
Page 3 of 3

Ismael Arreola, et al. v. Southern Industrial Contractors, LLC, et al.

U.S.D.C. (E.D. Tex.) No. 9:23-cv-50-MJT

Motion for Extension of Time for Service of Process

Respectfully submitted,

ISMAEL ARREOLA and ISRAEL 

ARREOLA, Each Individually and on 

Behalf of All Others Similarly 

Situated, PLAINTIFFS

SANFORD LAW FIRM, PLLC

Kirkpatrick Plaza

10800 Financial Centre Pkwy, Suite 510

Little Rock, Arkansas 72211

Telephone: (501) 221-0088

Facsimile: (888) 787-2040

/s/ Colby Qualls________

Colby Qualls

Ark. Bar No. 2019246

colby@sanfordlawfirm.com

/s/ Josh Sanford________

Josh Sanford

Tex. Bar No. 24077858

josh@sanfordlawfirm.com

Case 9:23-cv-00050-MJT Document 3 Filed 06/09/23 Page 3 of 3 PageID #: 22