Petition DENIED.

DISTRIBUTED for Conference of January 9, 2015.

Brief of respondent Washington in opposition filed.

Response Requested . (Due December 4, 2014)

DISTRIBUTED for Conference of November 7, 2014.

Waiver of right of respondent Washington to respond filed.

Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due November 5, 2014)

Samuel M. Piatnitsky, Petitioner, represented by Lila J. Silverstein

Washington, Respondent, represented by Erin H. Becker

Washington, Respondent, represented by James M. Whisman