Petition DENIED.

DISTRIBUTED for Conference of September 28, 2015.

Waiver of right of respondent Federal Respondant to respond filed.

Petition for a writ of mandamus and motion for leave to proceed in forma pauperis filed. (Response due September 2, 2015)

Party name:, Petitioner, represented by James C. Platts

Federal Respondant, Respondent, represented by Donald B. Verrilli Jr.