POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268~66&” -
POSTAL RATE AND FEE CHANGES, 1997
)
)
Docket No. R97-1
RESPONSE OF MCGRAW-HILL WITNESS
MICHAEL K. HEHIR TO INTERROGATORY OF
THE UNITED STATES POSTAL SERVICE (USPSIMH-Tl-6)
(February 23, 1998)
The McGraw-Hill Companies. Inc. hereby provides the responseof its witness
Michael K. Hehir to interrogatory USPSIMH-Tl-6 filed by the United StatesPostal
Service on February 10, 1998. The interrogatory is set out verbatim and is followed
by the response.
Respectfully submitted,
u
Timothy W. Bergin
Squire, Sanders& Dempsey L.L.P.
1201 PennsylvaniaAvenue, N.W.
P.O. Box 407
Washington, D.C. 20044-0407
(202) 626-6600
Counsel for The McGraw-Hill
Companies, Inc.
RESPONSE OF MCGRAW-HILL WITNESS MICHAEL K. HEHIR
TO INTERROGATORY OF THE UNITED STATES POSTAL SERVICE
USPS/MH-Tl-6.
Pleaserefer to your responseto USPSIMH-TI-2
a.
Does your responsemean that in preparation for this case, you reviewed only
those materials specifically cited in your testimony?
b.
If your responseto subpart (a) above is affirmative:
(1)
Pleaseindicate whether you reviewed only the cited pages of each
reference or whether you reviewed a larger portion of each reference.
(For example, on page 12, n. 18, you reference Docket No. R94-1,
USPS-T-2, but only pp. 130-31.)
(2)
Pleasespecifically identify each portion of each reference you
reviewed, if you reviewed more than the cited pages.
C.
If your responseto subpart (a) above is negative, please list all materials you
reviewed in preparation for your testimony in this case.
(a)
No.
(b)
Not applicable.
(cl
In preparing for my testimony in this case, I reviewed and relied upon
information provided to me by our outside counsel in this case, by our Washington
office, and by our Corporate Distribution and Manufacturing department. That
information, incl,uding testimony in this case by Periodicals witnessesLittle,
Stralberg, Cohen, and Crain, is cited and otherwise reflected in my written direct
testimony. Further, I keep abreastof postal issuesaffecting Periodicals mailers
through review of the trade press and financial reports relating to the Postal Service.
DECLARATION
I, Michael K. Hehir, declare under penalty of law that the foregoing anewere to interrogatories are
true and correct to the best of my knowledge, information, and belief,
February 19, 1998
CERTIFICATE OF SERVICE
I hereby certify that I have this day served this document in accordancewith
section 12 of the rules of practice.
February 23, 1998