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RICHARD A. TAMOR, ESQ. 

TAMOR & TAMOR

1901 Harrison, 9th Floor

Oakland, CA 94612

Telephone: (510) 847-4170

Facsimile: (510) 847-4174

rtamor@TamorLaw.com

Attorneys for Defendant,

IAN CARL GARCIA

JULIA MEZHINSKY JAYNE (State Bar No. 202753)

E-Mail: jjayne@campbelljayne.com

CAMPBELL & JAYNE LLP

350 Sansome Street, Suite 650

San Francisco, California 94104

Telephone: (415) 623-3600

Facsimile: (415) 623-3605

Attorneys for Defendant 

JUAN PAULO GARCIA

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, 

 

 Plaintiff

JUAN PAULO D. GARCIA AND IAN CARL 

GARCIA, Defendants

CASE NO. CR-08-0888 MHP

STIPULATION AND [PROPOSED] 

ORDER TO CONTINUE HEARING 

DATE

IT IS HEREBY STIPULATED by and between the parties hereto and their respective 

undersigned counsel, and with the consent of Defendants Juan Paulo Garcia and Ian Carl Garcia, 

Case 3:08-cr-00888-MHP Document 40 Filed 01/27/10 Page 1 of 3
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that the hearing presently scheduled for February 1, 2010 at 10:00 a.m. be taken off calendar and 

rescheduled for March 15, 2010 at 10:00 a.m. The purpose of the extension is (1) to allow 

Richard Tamor, defense counsel for Ian Garcia, to attend the court appearance since Mr. Tamor 

is currently scheduled to begin trial in a no-time waiver matter in Alameda County the week of 

January 25, 2010, and so therefore will be unavailable for currently scheduled court appearance ; 

and (2) it is anticipated that significant progress will be made in the next 6 weeks in the Plunder 

case in the Philippines, out of which arises the Defendants’ pending and related extradition 

matter. Resolution of those cases should facilitate resolution of the matter pending before this 

Court. 

The parties stipulate that it is appropriate to exclude time from February 1, 2010 though 

March 15, 2010, for effective preparation of the defense, and because the ends of justice served 

by taking such action outweigh the best interest of the public and the defendant in a speedy trial, 

taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(8)(A) and (B)(iv). The 

defense submits that it is further appropriate to exclude time for availability and continuity of 

counsel, and because the ends of justice served by taking such action outweigh the best interest 

of the public and the defendant in a speedy trial, taking into account the exercise of due 

diligence. 18 U.S.C. § 3161(h)(8)(A) and (B)(iv). The United States does not object to such an 

exclusion.

DATED: January 25, 2010 Campbell & Jayne LLP

By: /s/ Julia Mezhinsky Jayne

JULIA MEZHINSKY JAYNE

Attorneys for Defendant

JUAN PAULO GARCIA 

DATED: January 25, 2010 Tamor & Tamor

By: /s/ Richard Tamor

Case 3:08-cr-00888-MHP Document 40 Filed 01/27/10 Page 2 of 3
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RICHARD TAMOR

Attorneys for Defendant

IAN CARL GARCIA 

DATED: January 25, 2010 UNITED STATES ATTORNEY’S OFFICE

By: /s/ Hartley West

HARTLEY WEST

Attorneys for Plaintiff 

UNITED STATES OF AMERICA

ORDER

IT IS SO ORDERED.

DATED:

HONORABLE MARILYN HALL PATEL

UNITED STATES DISTRICT COURT JUDGE

1/27/2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:08-cr-00888-MHP Document 40 Filed 01/27/10 Page 3 of 3