RECEIVEI)
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
1997
)
SEP
16 12IOPh’‘97
m’rki i:.,iE c31~~i~~i~iL,,i
OFFlCic; I!IE sLCf;iii’,2y
Docket No. R97-1
FIRST SET OF INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESS
MICHAEL P. BRADLEY (USPS-T-14)
Major Mailers Association asks the United States Postal Service to answer the
following interrogatories
pursuant to Rules 25 and 26 of the Commission’s
Practice and Procedure. In answering these interrogatories,
the witness is requested to
follow the General Instructions that are set forth in the Attachment
Interrogatories
accordance
to thus witness.
to the First Set of
Requests for data or documents are to be interpreted in
with General lnstructrons G and H. If the designated witness is unable to
respond to any interrogatory
the Postal Service is asked to redirect the questron to
another Postal Service witness who can answer it.
Respectfully submitted,
MAJOR MAILERS ASSOCIATION
(4Amh
R&hard Littell
&20 Nineteenth St. N.W.
Suite 400
Washington, DC 20036
Phone: (202) 4666260
September
Rules of
16. 1997
MMA INTERROGATORIES
TO USPS WITNESS
(Michael P. Bradley: Set One)
MMAIUSPS-T14-1.
On page 3 of your testimony you state that “[IIn the past, the Postal Service has
simply assumed that mail processing labor costs were proportional
to volume. I’
You go on to note that the purpose of your testimony is to prodluce econometric
evidence that permits the evaluation of this assumption.
Then ‘you conclude that
labor costs (for all labor intensive operations) are less than 100% vanable with
volume.
(See Table 1, page 9)
(4
Is this a correct characterization
of your testimony?
If not please
explain
w
Did you or any other USPS witness perform any kind of study or
analysis to determine whrch labor processing operations generate costs
that are not variable with volume?
If so, please provide the results of your
study.
(End of this set of Interrogatories)
CERTIFICATE OF SERVICE
I hereby
certl@
that I have this day served the foregomg document. by First-Class Mail.
upon the participants requestin
September 16, 1997
such seance m rhls proceeding
ATTACRURNT 1
Page 1 of 3
GRNRRAL INSTRUCTIONS
A.
If
Request
the
for
respond,
the
question
or
answer
the
Service
to
of
witness
and his
Documents
to
another
question
or
comply
that
none
position
promptly
with
it
directed
asked
by facsimile
to
advise
message
the
who can
If
can
to
redirect
witness
request.
or
unable
should
witnesses
is
is
Service
the
its
Interrogatory
lawyers
Postal
of
'or Request,
is
or her
request
believes
INTERROGATORIES
whom a particular
Production
Interrogatory
its
witness
POR ANSWERING
the
Postal
respond
to
an
MMA counsel
to
Telecopy
of
Number
202-293-4377.
B.
In
Request
for
interpreting
Production
hypertechnical
what
is
is
not
but
available,
somewhat
could
the
use
in
witness
would
C.
Documents
previously
will
asked
asked
interpret
the
or
know about
the
available
If
the
Interrogatory
information
in
this
or
be
able
to
that
is
or
an
not
the
availability
of
the
requesting
party
In
Interrogatory
that
ascertain
Similarly,
information.
information
party
Supplied
that
or
Interrogatory
information
the
that
often
correctly.
unavailable
to
do not
the
know about
if
requests
for
if
information
the
providing
have
precisely
witness
of
or
may seek
different
lieu
is
generously,
-
the
is
even
precisely
an Interrogatory
please
A witness
sought
or Request
of
Documents,
being
worded
Interrogatory
other,
of
wording
or grudging.
information
Request
the
the
had phrased
such
of
Request
requesting
the
cases,
party
inquiry
more
information.
Request
that
proceeding,
the
for
Production
Postal
Service
please
state
of
has
and
identify
ATTACHHENT 1
Paqe 2 of 3
the
document
in
which
any Library
References
information
relevant
D.
to
the
to
of
As used
term
"documents"
clippings,
tabulations,
The term
"workpapers"
prepared
manually,
permit
contain
workpapers
that
an Interrogatory
are
or
together
of
not
to
Request
of
costs,
for
the
by whatever
such
whether
and should
rates
or
steps
set
statistical
preparing
information
arithmetic
any
documents.
material,
in
means
with
or use
prices,
witness
letters,
newspaper
electronically,
explanatory
the
to:
together
back-up
or
Production,
pamphlets,
understand
all
for
limited
or transmitted,
with
replication
is
and workpapers
mechanically
by or
or Request
testimonies,
includes
calculations
testimony,
to
but
drafts
necessary
created
all
an Interrogatory
stored
material
analyses
response
studies,
recorded,
the
also
Identify
or Request.
provide
includes,
reports,
forth
that
Interrogatory
should
in
memoranda,
written
was provided.
Documents.
E.
created,
the
witness'
Production
the
information
and Workpapers
The witness
relevant
for
that
his
sufficient
depicted
in
to
such
workpapers.
In
F.
title,
author,
should
cite
testimony
location
telephone
G.
the
request
referring
publisher
page
filed
and,
to
a document,
and date
and line,
in
if
number
this
not
of
the
of
the
document's
is
asked
be interpreted
the
complete
References
Unless
please
proceeding,
cite
publication.
possible.
published,
When a witness
should
if
please
the
state
identity,
the
loca-tion
document
is
document's
and
custodian.
to
provide
as asking
data
for
'or a document,
information
that
ATTACHMENT 1
,Page 3 of 3
is
to
available
about
or has
the
determining
of
it
Officer's
Docket
No.
not
provide
that
doing
party
is
the
the
so would
expected
In
the
Service's
cited
to
doing
expected
to
compile
the
Postal
in
the
to
Commission's
June
"The
that
16,
event
the
in
Practice
under
Rule
25(c)
to
perform
research
or to
requested
to
Ruling
Docket
1994 Response
to
comply
No.
No.
Federal
cclurt
Postal
Service's
requested
burden,
the
under
and Procedure.
does
party
(pp.
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decisions
Motion
not
believes
requested
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concerning
and the
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R94-1
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in
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cited
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information,
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to
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Presiding
Response
burden,
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make the
File
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event
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5;
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R94-l/38,
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locate
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May
to
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which
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Practice,
Officer's
Service
information
within
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that
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25,(c)
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party
of
the
is