Petition DENIED.

DISTRIBUTED for Conference of October 7, 2016.

Waiver of right of respondent United States to respond filed.

Petition for a writ of mandamus and motion for leave to proceed in forma pauperis filed. (Response due September 29, 2016)

Party name:, Petitioner, represented by David E. Payne

United States, Respondent, represented by Ian Heath Gershengorn