1. Whether this Court should issue a writ
of mandamus directing the U.S. Court of
Appeals for the Second Circuit to rule forthwith on Petitioners' emergency motion in No. 26-523, which has been
fully briefed and pending without action
for over 22 days, while six medically fragile disabled students' 1:1 nursing services — without which they cannot travel to or attend their court-mandated
pendency placement at iBRAIN — have
been completely suspended by DOE's
eight-month refusal to fund those
services.

2. Whether the Second Circuit's 22-day
inaction on a fully briefed emergency motion—in the face of concrete, compounding, and irreversible harm to
six children whose federally-mandated
pendency placement has been functionally terminated by financial
starvation—constitutes the type of
extraordinary cause warranting the writ
of mandamus under Cheney v. U.S. Dist.
Ct. for D.C., 542 U.S. 367 (2004), where
the district court has also denied all
relief and disclaimed jurisdiction,
leaving Petitioners with no forum
capable of compelling compliance with
the Individuals with Disability Act's
("IDEA") automatic stay-put obligation.

Whether the Second Circuit's 22-day inaction on a fully briefed emergency motion constitutes extraordinary cause warranting a writ of mandamus where disabled students' federally-mandated pendency placement has been functionally terminated by DOE's refusal to fund required 1:1 nursing services and no forum remains capable of compelling IDEA compliance