MOTION FOR COMPASSIONATE RELEASE 

EXH., KRASHNA, CR 17–22 JSW 

EXHIBIT A 

EXHIBITS IN SUPPORT OF 

EMERGENCY MOTION FOR 

COMPASSIONATE RELEASE 

 

Case 4:17-cr-00022-JSW Document 40-1 Filed 05/19/20 Page 1 of 4
FEDERAL PUBLIC DEFENDER

NORTHERN DISTRICT OF CALIFORNIA

13TH FLOOR FEDERAL BUILDING - SUITE 1350N

1301 CLAY STREET

OAKLAND, CA 94612

STEVEN G. KALAR Telephone: (510) 637-3500

 Federal Public Defender Fax: (510) 637-3507

JOYCE LEAVITT Email: Joyce_Leavitt@fd.org

 Assistant Federal Public Defender 

May 18, 2020

Ms. Christine Hilliard – via email and US Mail

RRM Sacramento

RESIDENTIAL REENTRY OFFICE

501 I STREET, SUITE 9-400

SACRAMENTO, CA 95814

chilliard@bop.gov

cc, via email:

Dominic Ayotte

Deputy Regional Counsel/WXRO CLC Supervisor

cayotte@bop.gov

RE: Quincy Krashna, Federal Register No. # 24074-111

Dear Ms. Hilliard:

I am writing to ask request that Mr. Krashna be transferred to Home Confinement or 

immediate Compassionate Release. Mr. Krashna has a number of risk factors, which alone and in 

combination place him at risk for severe complications of COVID-19, including a serious heart 

condition (congestive heart failure), hypertension, and a history of smoking. He also has high 

blood pressure. The conditions were verified in Mr. Krashna’s presentence report dated August 

21, 2018 (“PSR”), which was sent to the Bureau of Prisons (BOP) at the time that he selfsurrendered to serve his sentence. The PSR includes confirmation from Mr. Krashna’s treating 

doctor that he had suffered two prior heart attacks in 2004 and 2005 with stint replacements, and 

had a history of transient mini strokes, as well as hypertension, chronic pain and he uses 

marijuana to aid in sleep and pain management. See PSR at ¶¶ 70, 73.

According to information obtained from the BOP, Mr. Krashna is classified as a “Care 

Level 2” inmate, which means he is stable with chronic care issues. However, since he was 

returned to Santa Rita Jail from home detention in early 2020, Mr. Krashna has had ongoing 

medical complications relative to his chronic conditions. Records obtained from Santa Rita Jail 

demonstrate that Mr. Krashna has been seen by medical staff there continuously since January, 

2020, for ongoing chest pains, shortness of breath, and arm pain. In late March 25, 2020, a 

medical doctor assessed Mr. Krashna as potentially experiencing a coronary artery spasm and 

placed him on different medications for high blood pressure and coronary artery disease, as well 

Case 4:17-cr-00022-JSW Document 40-1 Filed 05/19/20 Page 2 of 4
Ms. Christine Hilliard

May 18, 2020

Page 2

as a medication for chest pain. His condition has not resolved and his medical conditions make 

him extremely vulnerable. He also has chronic nerve damage.

Because of his medical condition, I am requesting that you transfer Mr. Krashna to home 

confinement pursuant to § 12003(b)(2) of the CARES Act, and the Attorney General’s April 3, 

2020, Memorandum finding the COVID-19 emergency conditions are materially affecting the 

functioning of the Bureau of Prisons. Mr. Krashna is close to the end of his sentence with a 

projected release date, according to the BOP, of September 5, 2020. He is medically at risk, and 

transferring Mr. Krashna to home detention will decrease the population at Santa Rita Jail 

without endangering the greater community. Alternatively, for the same reasons, immediate 

Compassionate Release is requested. 18 U.S.C. § 3582( c)(1)(A). 

I have spoken with Hari Krashna, Mr. Krashna’s mother. She may be reached at (510) 

932-9385. The release plan is for Mr. Krashna to live at his own apartment which is located at 

700 Calhoun Ave, Albany, CA 94706. This apartment has a long term lease and the rent has been 

paid through November. Alternatively, according to Hari Krashna, her son could live with her. 

Hari Krashna has a residence in Richmond, California, but is currently working in Los Angeles. 

However, she is willing to work out whatever is needed to ensure that her son could be released 

from Santa Rita Jail on home detention. 

Sincerely,

STEVEN G. KALAR

Federal Public Defender

Northern District of California

 /S/

JOYCE LEAVITT

Assistant Federal Public Defender 

Case 4:17-cr-00022-JSW Document 40-1 Filed 05/19/20 Page 3 of 4
MOTION FOR COMPASSIONATE RELEASE 

EXH., KRASHNA, CR 17–22 JSW 

EXHIBIT B – FILED UNDER SEAL

EXHIBITS IN SUPPORT OF 

EMERGENCY MOTION FOR 

COMPASSIONATE RELEASE 

Case 4:17-cr-00022-JSW Document 40-1 Filed 05/19/20 Page 4 of 4