I have seen so many cars just dragged slowly with the wheels locked. Of course it would depend on how far you have to move it and the surface it is on. Often I see the tow drivers throw shovelfuls of gravel or sand in front of the tires to help it slide easier, but they never take the time to properly unlock the wheels.
3 kw solar pv - XW6048 - eight L16's
4 ton GSHP
2003 VW TDI 180k miles - 52 mpg lifetime
evse level 2 - Clipper Creek HSC-40
2013 S model with QC package Mar of 2013
@70k miles - 56.56Ahr - 86 SOH - 82.55 Hx - 245 GID