INTERROGATORIES
UNITED STATES POSTAL SERVICE
AND REQUESTS FOR PRODUCTION OF DOCUMENTS
THE MCGRAW HILL COMPANIES, INC.
(USPSIMH-1-34)
Pursuant to rules 25 and 26 of the Rules of Practice and Procedure
TO
and rule 2 of
the Special Rules of Practice, the United States Postal Service directs the following
interrogatories
Companies,
and requests for production of documents to The McGraw Hill
Inc.: USPSIMH-1-34.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
h.&k
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
January 22, 1998
USPSIMH-1.
For each year fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide a list of publications
and mailed at second-class
USPSIMH-2.
published by your company
regular or periodical regular rates.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please for each publication listed in response to interrogatory
from
number
1 the following information:
(a)
The number of issues mailed.
lb)
The average number of editions (versions) per issue.
(4
An indication of the kind or type of each version.
USPSIMH-3.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the total volumes mailed at seconcl-class
periodical
regular rates for each publication listed in response to interrogatory
from
regular or
number
1.
USPSIMH-4.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular required presort rates for each publication
number 1.
from
regular or periodical
listed in respons?
to interrogatory
USPSIMH-5.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular
3-digit
interrogatory
city/5-digit
presort
rates for each publication
from
regular or periodical
listed in response
to
number 1.
USPSIMHS.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
from
regular or periodical
regular carrier route presort rates for each publication listed in response to interrogatory
number 1.
USPSIMH-7.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular destination
to interrogatory
USPSIMH-8.
delivery office discount rates for each publicatiori
USPWMH-9.
listed in response
For each fiscal year (or calendar year if fiscal year is unavailable)
destination
interrogatory
regular or periodical
number 1.
1986 to present, please provide the volumes mailed at second-class
regular
from
SCF discount
rates for each publication
from
regular or periodical
listed in response
to
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
2
from
regular or periodical
regular high density discount rates for each publication listed in response to interrogatory
number 1.
USPSIMH-10.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
from
regular or periodical
regular saturation discount rates for each publication listed in response to interrogatory
number 1.
USPS/MH-11.
For each fiscal year (or calendar year if fiscal year is Iunavaifab)e) from
1986 to present, please provide the required presort volumes mailecl at second-class
regular or periodical regular prebarcoded
listed in response to interrogatory
USPSIMH-12.
letter size discount rates for each publication
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular prebarcoded
interrogatory
flat size discount rates for each publication
from
regular or periodical
listed in response to
number I.
USPSIMH-13.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the 3-digit city/5-digit volumes mailed at second-class
regular
or periodical
publication
regular prebarcoded
3-digit letter size discount
listed in response to interrogatory
3
number 1.
rates for each
USPSIMH-14.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the 3-digit city/5-digit volumes mailed at second-class
regular or periodical
publication
regular prebarcoded
5digit
listed in response to interrogatory
USPSIMH-15.
letter size discount
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the 3-digit city/5digit
regular or periodical
regular prebarcoded
listed. in response to interrogatory
USPSIMH-16.
rates for each
from
volumes mailed at second-class
flat size discount rates for each publication
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zones I&2 for each publication
listed in response to interrogatory
USPSIMH-17.
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 3 for each publication listed
in response to interrogatory
USPSIMH-18.
number 1
For each fiscal year (or calendar year if fiscal year is, unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
4
at second-class
regular or periodical regular rates for zone 4 for each publication
in response to interrogatory
USPSIMH-19.
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 5 for each publication
in response to interrogatory
USPSIMH-20.
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 6 for each publication
in response to interrogatory
USPSIMH-21.
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 7 for each publication
in response to interrogatory
USPSIMH-22.
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 8 for each publication listed
in response to interrogatory
number 1.
USPSIMH-23.
For each fiscal year (or calendar year if fiscal year is Iunavailable) from
1986 to present,
please provide the average
mailed at second-class
of nonadvertising
content
regular or periodical regular rates for each publication
response to interrogatory
USPSIMH-24.,
percentage
listed in
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed on pallets at sec,ond-class regular
or periodical regular rates for each publication listed in response to interrogatory
number
1 by the following pallet presort levels:
(4
5-digit pallets
lb)
3-digit pallets
w
SCF pallets
W
ADCEDC
W
BMC pallets
(9
Mixed-BMC
USPSIMH-25.
pallets
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
periodical
pallets
for those volumes
mailed on pallets at second-class
from
regular
regular rates for each publication listed in response to interrogatory
or
number
1, please provide the average number of pieces per pallet by the follclwing pallet presort
levels:
(a)
5-digit pallets
(b)
3-digit pallets
(4
SCF pallets
(4
ADClSDC
(6
BMC pallets
(9
Mixed-BMC
USPS/MH-26.
pallets
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
periodical
pallets
for those volumes
mailed on pallets at second.-class
from
regular
regular rates for each publication listed in response to interrogatory
or
number
,I, please provide the average pallet weight by the following pallet presort levels:
(4
5-digit pallets
@I
3-digit pallets
(4
SCF pallets
(4
ADWSDC
W
BMC pallets
(9
Mixed-BMC
USPSIMH-27.
pallets
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed in sacks at second-class
periodical regular rates for each publication listed in response to interrogatory
1 by the following sack presort levels:
(a)
Carrier route(s) sacks
from
regular or
number
@I
Firm sacks
(c)
5digit
(d)
3-digit unique city sacks
(6
3-digit sacks
(9
SCF sacks
(9)
ADClSDC
04
Mixed sacks.
USPSIMH-28.
sacks
sacks
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, for those volumes mailed in sacks at second-class
regular rates for each publication
listed in response to interrogatory
from
regular or periodical
!number 1, please
provide the average number of pieces per sack by the following sack presort levels:
(4
Carrier route(s) sacks
(b)
Firm sacks
(cl
5-digit sacks
(4
3-digit unique city sacks
W
3-digit sacks
(9
SCF sacks
(9)
ADUSDC
(h)
Mixed sacks.
sacks
USPWMH-29.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed in trays at second-class
periodical regular rates for each publication listed in response to interrogatory
from
regular or
number
1 by the following tray presort levels:
(a)
Carrier route(s) trays
(b)
Firm trays
(c)
5digit trays
(d)
3-digit unique city trays
W
3-digit trays
(9
SCF trays
(9)
ADClSDC
O-4
Mixed trays.
USPSIMH-30.
trays
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, for those volumes mailed in trays at second-class
regular rates for each publication
listed in response to interrogatory
regular or periodical
number 1, please
provide the average number of pieces per tray by the following tray presort levels:
(4
Carrier route(s) trays
(b)
Firm trays
(4
5digit
(4
3-digit unique city trays
(6
3-digit trays
trays
from
(9
SCF trays
(!a
ADCEDC
(W
Mixed trays.
USPSIMH-31.
trays
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed in bundles at second-class
regular
or periodical regular rates for each publication listed in response to interrogatory
number
1.
USPSIMH-32.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
for those volumes
mailed
in bundles
at second.-class
from
regular
periodical regular rates for each publication listed in response to interrogatory
or
number
1, please provide the average number of pieces per bundle.
USPWMH-33.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed at second-class
regular or periodical
regular rates that were plant loaded in USPS provided transportation
fclr each publication
listed in response to interrogatory
USPSIMH-34.
number 1.
Please also provide all data furnished
through 33 above in electronic format.
10
in response to interrogatories
1
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
with section Ii! of the Rules of
Practice.
,JGfLS%P-Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
January 22, 1998
upon all