BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2001
)
)
RECEIVEO
Nov21 II 03 AM‘01
“Q:idi ;:,:i:. jp,Y:/,:,s,U.8
OFTIC!
‘:i~:~I~,;.
ji ,.:i,t!‘,W!
Docket No. R2001-1
FIRST INTERROGATORIES
AND REQUESTS FOR PRODUCTION
DOCUMENTS OF AMERICAN BUSINESS MEDIA AND
THE MCGRAW-HILL
COMPANIES DIRECTED TO USPS
(ABM/USPS-1-8)
OF
Pursuantto the Commission’s Rules of Practice. American BusinessMedia and The
McGraw-Hill Companies, Inc. hereby submit the attachedinterrogatories and requestsfor
production of documents to the Postal Service (ABM-MWUSPS-l-8).
Theydeal with matters
related to the testimony of severalwitnesses. We requestthat a designatedrepresentative
respondto the interrogatories.
ft;~&+*h~
Timothy W. Bergin
Squire, Sanders& Dempsey LLP
1201 PennsylvaniaAvenue, NW
Washington, DC 20004
;
Counsel for The McGraw-Hill
Companies, Inc.
CERTIFICATE
1909 K Street,NW, Suite 600
Washington, DC 20006
Counsel for American BusinessMedia
OF SERVICE
I hereby certify that I have this date servedthis do
of the Commission’s Rules of Practice.
Dated: November 2 1.200 1
ce with Section 12
FIRST INTERROGATORIES
AND REQUESTS FOR PRODUCTION
DOCUMENTS OF AMERICAN BUSINESS MEDIA AND THE
MCGRAW-HILL
COMPANIES DIRECTED TO USPS
(ABM-MHKJSPS-13)
OF
ABM-MHKJSPS-1. Pleaseprovide all studiesconducted by or on behalf of the Postal Service
since 1995 that analyzed or consideredin any way separateeditorial drop ship pound rates for
Periodicals. If the USPS has not studied these issuessince 1995, pleaseso state.
ABM-MHKISPS-2. Pleaseprovide all studiesconducted by or on behalf of the Postal Service
since 1995 that analyzed or consideredin any way a per-piece pallet discount for Periodicals. If
the USPS has not studied these issuessince 1995, pleaseso state.
ABM-MHKISPS-3. Pleaseprovide all studiesconducted by or on behalf of the Postal Service
since 1995 that analyzed the particular characteristicsof periodicals publications and/or
Periodicals mailers who drop ship. Possible characteristicsstudied might include publication
circulation or density, time sensitivity or other factors. If the USPS has not studied these issues
since 1995, pleaseso state.
ABM-MHKJSPS-4. Pleaseprovide all studies conducted by or on behalf of the Postal Service
since 1995 that analyzed the particular characteristicsof Periodicals publications and/or
Periodicals mailers who do not drop ship. Possible characteristicsstudied might include
publication circulation or density, time sensitivity or other factors. If the USPS has not studied
theseissuessince 1995, pleaseso state.
ABM-MHRJSPS-5. Pleaseprovide all studies conductedby or on behalf of the Postal Service
since 1995 that analyzed or consideredin any way co-palletizing in which different Periodicals
are combined in a single pallet. If the USPS has not studied theseissuessince 1995, pleaseso
state.
ABM-MHRJSPS-6. Pleaseprovide all studies or estimatesavailable to the USPS of the number
of Periodicals and the number of pieces for eachsuch Periodical that are not now drop shipped
but will begin to be drop shipped in responseto the USPS’s proposededitorial drop ship pound
rate in Periodicals. If the USPS has not studied this issue,pleaseso state.
ABM-MH/USPS-7. Pleaseprovide all studiesor estimatesavailable to the USPS of the number
of Periodicals and the number of pieces for eachsuch Periodical that are not now mailed on
pallets but will begin to be mailed on pallets in responseto the USPS’s proposedper piece pallet
discount in Periodicals. If the USPS has not studied this issue, pleaseso state.
ABM-MWLJSPS-8. Pleaseprovide all studiesor estimatesavailable to the USPS of the number
of Periodicals and the number of pieces for eachsuch Periodical that are neither drop-shipped nor
enteredon pallets at present but that will begin to be both drop shipped and enteredon pallets in
responseto the combined effects of the USPS’s proposededitorial drop ship and per piece pallet
discount in Periodicals. If the USPS has not studied these issuesin combination, please so state.