BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes, 2006
Postal Rate Commission
Submitted 7/17/2006 2:55 pm
Filing ID: 50868
Accepted 7/17/2006
Docket No. R2006-1
NEWSPAPER ASSOCIATION OF AMERICA
ESTIMATE OF ORAL CROSS-EXAMINATION
July 17, 2006
Pursuant to Presiding Officer’s Ruling No. R2006-1/12, the Newspaper
Association of America (“NAA”) hereby submits its current estimate of likely oral crossexamination of United States Postal Service witnesses.
Witness
Thress (USPS-T-7)
Kelley (USPS-T-30)
O’Hara (USPS-T-31)
Kiefer (USPS-T-36)
McCrery (USPS-T-42)
Coombs (USPS-T-44)
Amount
None to light
Moderate
Unknown
Moderate to heavy
Light
Light
NAA notes that responses to a number of interrogatories to witness O’Hara are
substantially overdue. Postal Service counsel has advised NAA that this situation will
be addressed soon. However, followup discovery may be necessary as to witness
O’Hara and NAA respectfully asks the Commission to consider scheduling his
appearance, if possible, near the end of the first round of hearings to allow time for such
discovery.
Respectfully submitted,
NEWSPAPER ASSOCIATION OF AMERICA
By:
William B. Baker_____________
William B. Baker
WILEY REIN & FIELDING LLP
1776 K Street, N.W.
Washington, DC 20006-2304
(202) 719-7255
CERTIFICATE OF SERVICE
I hereby certify that I have this date served the instant document on all
participants requesting such service in this proceeding in accordance with section 12 of
the Rules of Practice.
William B. Baker
William B. Baker
July 17, 2006
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