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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 43 Filed 03/09/10 Page 1 of 3
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that the hearing presently scheduled for March 15, 2010 at 10:00 a.m. be taken off calendar and 

rescheduled for April 19, 2010 at 10:00 a.m. The purpose of the extension is (1) to allow 

coordination of the matter before this case and the extradition matter, since the Plunder case in 

the Philippines has been continued to March 16, 2010 and resolution of the case in the 

Philippines and the pending extradition case should facilitate resolution of the matter pending 

before this Court; and (2) counsel for the Government, Hartley West, is expected to be in trial 

until the second week in April, and counsel for Juan Paulo Garcia, Julia Jayne, currently has a 

trial scheduled for April 12, 2010; thus, the next available court date for all parties would be 

April 19, 2010. 

The Defense submits and the Government does not object that it is appropriate to exclude 

time from March 15, 2010 though April 19, 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: March 9, 2010 Campbell & Jayne LLP 

By: /s/ Julia Mezhinsky Jayne 

 JULIA MEZHINSKY JAYNE 

Attorneys for Defendant 

JUAN PAULO GARCIA 

DATED: March 9, 2010 Tamor & Tamor 

By: /s/ Richard Tamor 

Case 3:08-cr-00888-MHP Document 43 Filed 03/09/10 Page 2 of 3
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 RICHARD TAMOR 

Attorneys for Defendant 

IAN CARL GARCIA 

DATED: March 9, 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 

 

3/9/2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:08-cr-00888-MHP Document 43 Filed 03/09/10 Page 3 of 3