1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

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 WAIVING PERSONAL 

APPEARANCE OF DEFENDANTS

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 45 Filed 04/15/10 Page 1 of 3
2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

that their personal appearance be waived for the hearing presently scheduled for April 19, 2010 

at 10:00 a.m. 

At the hearing scheduled for April 19, 2010, the defense will request a further 

continuance in order to allow coordination of the matter before this Court and the extradition 

matter currently pending before the Honorable Edward C. Chen in case number CR-09-90136 

MISC. A Settlement Agreement in the case in the Philippines is currently under submission for 

approval by the Sandiganbayan (the Court in the Philippines assigned to hear matters related to 

corruption). Resolution of the case in the Philippines will resolve the pending extradition case 

before Judge Chen and should facilitate resolution of the criminal matter pending before this 

Court. The defense believes that resolution of the case before the Sandiganbayan is imminent. 

At the status conference on April 19, 2010, the defense will be prepared to articulate a basis for 

an exclusion of time for the anticipated further request for continuance.

Because the defendants in this matter are residents of Michigan and Nevada, and their 

travel would be unduly burdensome given the defense’s anticipated request for a further 

continuance, the parties stipulate that it is appropriate to waive the defendants’ personal 

appearance for the status hearing currently scheduled for April 19, 2010.

DATED: April 14, 2010 Campbell & Jayne LLP

By: /s/ Julia Mezhinsky Jayne

JULIA MEZHINSKY JAYNE

Attorneys for Defendant

JUAN PAULO GARCIA 

DATED: April 14, 2010 Tamor & Tamor

By: /s/ Richard Tamor

RICHARD TAMOR

Attorneys for Defendant

IAN CARL GARCIA 

Case 3:08-cr-00888-MHP Document 45 Filed 04/15/10 Page 2 of 3
3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

DATED: April 14, 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

4/15/2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:08-cr-00888-MHP Document 45 Filed 04/15/10 Page 3 of 3