Many district courts outside the Third Circuit that have considered the issue have denied motions for compassionate release because the defendant did not raise the same issues in their requests for release addressed to the BOP. See e.g., United States v. Hernandez, Crim. A. No. 13cr4467-JAH, 2020 WL 3051105 (S.D. Cal. June 5, 2020); United States v. Baye, Crim. A. No. 3:12-CR-00115-RCJ, 2020 WL 2857500, at *5 (D. Nev. June 2, 2020); United States v. Shakur, Crim. A. No. 82 CR 312 (CSH), 2020 WL 2749686 (S.D.N.Y. May 27, 2020); United States v. Samak, Crim. A. No. 91-189, 2020 WL 2473780, at *2 (E.D. La. May 13, 2020); United States v. Heath, 2:17-CR-0133-TOR, 2020 WL 2114364 (E.D. Wash. May 4, 2020); United States v. Grimes, Crim. A. No. 18-CR-6101 CJS, 2020 WL 2098106 (W.D.N.Y. May 1, 2020); United States v. Dougherty, 2:18-cr-229-2, 2020 WL 1909964, at *2 (S.D. Ohio Apr. 20, 2020); United States v. Mollica, Crim. A. No. 2:14-CR-329-KOB, 2020 WL 1914956, at *6 (N.D. Ala. Apr. 20, 2020); United States v. Jenkins, Crim. A. No. 4:15-CR-3079, 2020 WL 1872568, at *1 (D. Neb. Apr. 14, 2020); United States v. Mogavero, Crim. A. No. 2:15-cr-00074-JAD-NJK, 2020 WL 1853754, at *2 (D. Nev. Apr. 13, 2020). For example, in McNair, the defendant requested compassionate release from the warden of his prison due to his remorse for his criminal behavior and rehabilitative efforts while incarcerated.