REPLY AND [PROPOSED] ORDER GRANTING COMPASSIONATE RELEASE 

KRASHNA, CR 17–22 JSW 

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STEVEN G. KALAR

Federal Public Defender 

Northern District of California 

JOYCE LEAVITT 

LISA MA 

Assistant Federal Public Defenders 

13th Floor Federal Building - Suite 1350N 

1301 Clay Street 

Oakland, CA 94612 

Telephone: (510) 637-3500 

Facsimile: (510) 637-3507 

Email: Joyce_Leavitt@fd.org 

Counsel for Defendant Krashna 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION 

UNITED STATES OF AMERICA, 

 Plaintiff, 

 v. 

QUINCY KRASHNA, 

 Defendant. 

Case No.: CR 17–22 JSW 

DEFENDANT’S REPLY TO 

GOVERNMENT’S RESPONSE TO 

MOTION FOR COMPASSIONATE 

RELEASE AND [PROPOSED] ORDER 

GRANTING COMPASSIONATE 

RELEASE

Court: Courtroom 5, 2nd Floor

Hearing Date: June 16, 2020 

Hearing Time: 1:00 p.m. 

The government does not oppose Quincy Krashna’s motion to reduce his term of imprisonment 

to time served (Dkt. 40), but requests the Court stay the order granting release until June 18; order 

that Mr. Krashna be quarantined for two weeks prior to his release; impose, as a condition of release, 

home confinement until September 5, 2020; and impose, as a condition of release, that Mr. Krashna 

must abide by all court orders. Dkt. 47. Mr. Krashna, through counsel, does not oppose the 

government’s requests except to the extent that proposed conditions of release unduly restrict his 

right to familial association or are unconstitutionally vague. See United States v. Domingeuz, No. 18-

Case 4:17-cr-00022-JSW Document 48 Filed 06/03/20 Page 1 of 4
REPLY AND [PROPOSED] ORDER GRANTING COMPASSIONATE RELEASE 

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50360, 2020 WL 2844530, at *2 (9th Cir. June 1, 2020) (vacating special conditions of release 

implicating defendant’s right to familial association); United States v. Hall, 912 F.3d 1224, 1226–27 

(9th Cir. 2019) (per curiam). 

Additionally, if Santa Rita Jail is unable to quarantine Mr. Krashna for the full two-week period 

prior to June 18, Mr. Krashna should be permitted to satisfy his two-week self-quarantine at home. 

See United States v. Fischman, No. 16-CR-00246-HSG-1, 2020 WL 2097615, at *3 (N.D. Cal. May 

1, 2020) (permitting defendant to satisfy 14-day self-quarantine requirement at home). 

Dated: June 3, 2020 Respectfully submitted, 

 

 STEVEN G. KALAR

 Federal Public Defender

 Northern District of California 

 

 /S 

 JOYCE LEAVITT 

 Assistant Federal Public Defender 

 

Case 4:17-cr-00022-JSW Document 48 Filed 06/03/20 Page 2 of 4
[PROPOSED] ORDER GRANTING COMPASSIONATE RELEASE 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION 

UNITED STATES OF AMERICA, 

 Plaintiff, 

 v. 

QUINCY KRASHNA, 

 Defendant. 

Case No.: CR 17–22 JSW 

[PROPOSED] ORDER GRANTING 

COMPASSIONATE RELEASE

Court: Courtroom 5, 2nd Floor

For good cause shown, the Court hereby GRANTS the motion for compassionate release. See

Dkt. 40. Quincy Krashna’s sentence of imprisonment is modified to time served, effective on June 

18, 2020. Mr. Krashna’s custodian at Santa Rita Jail shall place Mr. Krashna in quarantine on or 

before June 5, 2020, so that Mr. Krashna may serve a 14-day period of quarantine before his release. 

Mr. Krashna is to be released from custody on June 18, 2020. The government shall serve a copy of 

this Order on Santa Rita Jail immediately. 

Mr. Krashna shall complete the three-year term of supervised release imposed in the original 

sentence subject to the original conditions, see Dkt. No. 37, except Standard Condition No. 8 

(requiring at least part-time employment), and with the following additional special conditions: 

• Mr. Krashna shall be subject to home confinement, without electronic monitoring, at his 

home in Albany, California, until September 5, 2020. Mr. Krashna may only leave his 

residence for necessary medical services or for necessities like toiletries or groceries, 

with the prior approval of the Probation Office, except in the case of medical 

emergencies. 

• Mr. Krashna shall be abide by all court orders. 

Case 4:17-cr-00022-JSW Document 48 Filed 06/03/20 Page 3 of 4
[PROPOSED] ORDER GRANTING COMPASSIONATE RELEASE 

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 IT IS SO ORDERED. 

Dated: ______________ 

 JEFFREY S. WHITE 

 United States District Judge 

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