BEFORE THE
RECEIVELI
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
5 26 PM‘97
hc 11
Posvt
RATE COllr4lSSIOH
OFFICE DiTHE SCCHETARY
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
:
RESPONSE OF UNITED STATES POSTAL SERVIC’E
WITNESS CURRIE TO INTERROGATORIES
OF
THE OFFICE OF THE CONSUMER ADVOCATE
(OCAIUSPS-T42-l-2)
The United States Postal Service hereby provides responses
to the following
USPS-7’42-1-2,
interrogatories
of the Office of the Consumer
of witness
Advocate:
Currie
OCA/
filed on July 29, 1997.
Each interrogatory
is stated verbatim
and is followed
Respectfully
by the response.
submitted,
UNITED STATES
POSTAL
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Kenneth N. Hollies
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-3083; Fax -5402
August 11, 1997
SERVICE
RESPONSE OF U.S. POSTAL SERVICE WITNESS CURRIE TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAIUSPS-T42-1.
Please list all differences between your testimony In Docket
No. MC97-2 (USPS-T-l 1) and your testimony in Docket No. R97-1 (USPS-T-42).
Give full citations to page and line. Explain the reasons for the changes.
RESF’ONSE:
The only substantive change between my MC97-2 testimony and my R971 testimony is the insertion in my R97-1 testimony of material suppliied as an
interrogatory
response in MC97-2.
This material appears at p. 13, line 5 through
page 14, line 4
In addition, there are a few editorial changes that are intended to improve
the clarity of the testimony,
RESPONSE OF U.S. POSTAL SERVICE WITNESS CURRIE TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAllJSPS-T42-2.
Please refer to your interrogatory
Tll-l-,18
in Docket No. MC97-2.
responses to OCAAJSPS-
a. Please confirm that your responses to the above-referenced interrogatories
are true, accurate, and complete for purposes of your testimony in Docket
No. R97-I. If you do not confirm, please explain and provide corrections.
b. Ple!ase confirm that you hereby adopt your responses to the abovereferenced interrogatories as yorur testimony in Docket No. R97-‘I. If you do
not confirm, please explain.
RESPONSE:
a-b. Confirmed
DECLARATION
I, John V. Currie, declare under penalty of perjury that the foregoing answers are true
and correct to the best of my knowledge, information, and belief.
Dated:
s ii
47
CERTIFICATE
OF SERVICE
I lhereby certify that I have this day served the foregoing
participalnts of record in this proceeding
in accordance
IL+xl T &II,
Kenneth N. Hollies
-
upon all
with section 12 of the Rules
of Practilce.
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
August 11, 1997
document