RECEIVED
BEFORE THE
POSTAL RATE COMMIS~&&
WASHINGTON. D.C. 2026
POSTAL RATE AND FEE CEANGES, 1997
3 QPM’91
,^.I
Docket
j
:No. R97-1
THE DIRECT MARKETING ASSOCIATION,
INC.'S
FIRST SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION 'OF DOCUMENTS
DIRECTED TO USPS WITNESS DEGEN (DMA/USPS-T12-1)
F'ursuant
Rules
hereby
requests
of
Practice,
other
Sections
the
Direct
submits
the
for
production
(DMA/USPS-T12-1).
respond
to
to
this
qualified
attached
If
of
the
interrogatory,
25 and 26 of
Marketing
first
designated
Commission's
Association,
set
documents
the
of
to
interrogatories
USPS witness
witness
we request
Inc.
is
and
Degen
unable
a response
to
by some
witness.
Respectfully
submitted,
,.#ly&L&!&@&&qu/
bana T. Ackerfi
II,
Esq.
David L. MeyerMichael
D. Bergman
COVINGTON & BURLI:NG
1201 Pennsylvania
Avenue,
Washington,
D.C.
20004
(202) 662-5296
Counsel
for the
Association,
August
27,
1997
Direct
Inc.
N.W
Marketing
- 2 Witness
Degen
(USPS-T-12)
DMA/USPS-TlZ-1.
For each FY 1996 clerks
and mailhandlers
(C/S
3) IOCS tally,
please
provide
the following
information
in a
machine-readable
format:
(1) the date and day of week of
actual
reading,
(2) actual
reading
time,
(3) MODS work center
number,
(4) dollar
amount assigned
by tally,
(5) activity
code,
(6) responses
to questions
18 and 19 in CODES, and (7)
basic
function.
.-
--
-
- 3 -
CERTIFICATE
foregoing
proceeding
Postal
Rule
I hereby
certify
document
upon
in
Rate
3 of
accordance
Commission's
the
Commission's
OF SERVICE
that
all
I have
this
participants
with
Rules
Rule
of
Special
12
date
of
record
(section
Practice
Rules
served
in
the
this
3001.12)
of
and Procedure
of
Practice
in
proceeding.
4%ci!P!F
ergman
August
----.
27,
--
1997
r
the
and
this
COVINGTON
&
BURLING
1201 PENNSYLVANIA
AVENUE. N. w.
P.O. BOX 7566
August
27,
1997
BY HAND
",z 2z
zro "
is2 2
%z
25 0
Docket
Section
Postal
Rate Commission
1333 H Street,
N.W.
Suite
300
Washington,
D.C.
20268
Re:
Dear
R97-1
Sir/Madam:
Pursuant
to
forth
in Special
Rule
in the above-referenced
copies
each of:
format,
documents
P’o
VI ,>
0
2
m
"22
-=vG
-, L?
z<-.:I
a
xc
_
Lp
A--
the alternative
procedure
for filing
set.
of Practice
3, please
accept
for filing
docket
the enclosed
original
and three
1.
The Direct
Marketing
Association,
Inc.'s
("DMA's")
Fourth
Set of Interrogatories
and
Requests
for Production
of Documents
Directed
to USPS Witness
Bradley
(DMA/USPS-T14-32);
and
2.
DMA's First
Set of Interrogatories
for Production
of Documents
Directed
Witness
Degen (DMA/USPS-T12-1).
A disk
containing
is
Aria1
12 font,
these documents
also enclosed.
Please
date-stamp
the enclosed
and return
it with our waiting
Thank
you
very
in
and Requests
to- USPS
WordPerfect
extra
copies
messenger.
much.
Sincerely,
/il&duPfi~~
Michael
Enclosures
9
m
z
D. Bergman
of
5.1
these