POSTAL RATE COMMISSION
POSTAL RATE AND FEE CHANGES,
2000
i
113
I3
CJ j: i;j’ ‘fi!3
DOCKET NO. R2000-1
MOTION OF UNITED PARCEL SERVICE TO COMPEL
PRODUCTION OF INFORMATION AND DOCUMENTS
REQUESTED IN INTERROGATORY
UPS/USPS-T34-11
TO WITNESS ROBINSON
(March 13,200O)
Pursuant to Sections 26(d) and 27(d) of the Commission’s
Rules of Practice,
United Parcel Service (“UPS”) hereby moves the Presiding Officer to order the United
States Postal Service (“Postal Service”) to answer interrogatory
filed on February 16, 2000, and to produce the documents
this interrogatory
requested
therein.
on February 28, 2000 (“Objection”).
UPS submits that the requested
of an appropriate
information
is highly relevant to the
cost coverage for Priority Mail, and can be provided
without undue burden and without injury to the Postal Service’s legitimate
THE DISCOVERY
Interrogatory
UPS/USPS-T34-11
directives, or other documents
and how the system operates,”
interests.
REQUEST
requests the Postal Service to identify all
systems for measuring the service performance
guidelines,
A copy of
is attached hereto as Exhibit A. The Postal Service filed an objection
to the interrogatory
determination
UPS/USPS-T34-11,
of Priority Mail, provide “manuals,
which indicate how measurements
are made
and provide “all results for all such systems for each
year (by quarter, if available) from FYI990
through FY1999, and up to the present.”
February 28, 2000, the Postal Service objected to this interrogatory
it is overbroad,
describing
that it “would require a burdensome
the system, and that the information
commercially
on the grounds that
review and collection” of manuals
includes “proprietary,
sensitive, geographically-specific
On
performance
data.”
confidential,
Objection, at 1-2.
ARGUMENT
As we show below, the Postal Service’s objections
Nevertheless,
in an effort to narrow the scope of this discovery dispute, UPS is willing to
limit its request to (1) national
“geographically-specific”
if available).
are without merit.
service performance
results (i.e., excluding
results) and (ii) the period from FYI993
Given the importance
value of service considerations,
to FYI999
of actual service performance
(by quarter,
data in evaluating
the Postal Service should be ordered to produce this
information.
1.
The Interrogatory,
Overbroad.
Especially
as Modified
Herein,
Is not
The Postal Service asserts that UPS’s request for data on the actual service
performance
of Priority Mail is overbroad
“insofar as it requests performance
for years prior to the years at issue in this case.
.” Objection,
information
at 1. As stated above,
UPS is willing to limit its request to quarterly data for the period FYI993
(as opposed to
FY1990, as specified in the original request) through FY1999.
Data prior to the base year in this case is required if the Commission
and the
parties are to be able to compare Priority Mail’s current performance
-- one aspect of
value of service -- to its performance
decision in Docket
leading up to the Commission’s
2
No. R97-1, where the Commission
cut Priority Mail’s cost coverage from 197% -- the
level set in Docket No. R94-1 -- to 166%.
Recommended
Docket No. R97-1, Opinion and
Decision, App. G, at 32 (Revised S/19/98).
The Commission’s
action
was based in part on the view that one witness’ “analysis of delivery performance
suggests that Priority Mail often fails to provide a standard of service superior to, or at
times even equal to, that of First-Class
Priority Mail’s actual performance
FYI996
Mail.” Id. at 363. Clearly, then, a history of
from FYI993
(the base year in Docket No. R97-I),
year, is highly relevant to the determination
(the base year in Docket No. R94-1) to
and from FYI996
of an appropriate
through the most recent
cost coverage for Priority
Mail in this case.
Accordingly,
is not “overbroad,”
2.
UPS’s modified request for data covering FYI993
through FYI999
and the Postal Service should be ordered to respond.
The Requested
Burden.
Information
Can Be Provided
Without
Undue
The Postal Service asserts that to produce copies of the manuals or other
documents
that describe how Priority Mail performance
“burdensome.”
is measured would be
Objection, at 1. The Postal Service does not “state with particularity
the
effort which would be required to answer the request, [or] provide[ ] estimates of cost
and work hours required,” as is required in the case of an undue burden objection.
Rules of Practice, Rule 26(c), 39 C.F.R. 5 3001.27(c).
That is undoubtedly
because the
cost and work hours involved in locating and copying a manual (or possibly manuals) on
how the measurements
are made is minimal.
The Postal Service’s undue burden objection is nothing more than a frivolous red
herring.
It is unlikely that the Postal Service has such a plethora of systems for
3
measuring
Priority Mail performance
be an undue burden.
any new calculations.
already available.
3.
that providing the manuals for each system would
This interrogatory
does not require the Postal Service to perform
It merely asks the Postal Service to collect information
The Postal Service should be ordered to do so.
Priority
Should
Mail Service Performance
Not Be, Confidential.
Information
Is Not, and
Finally, the Postal Service objects that the requested
This objection apparently
information
information
refers only to “geographically-specific”
(although the Postal Service has not responded
is confidential.
performance
to the extent it deems the
interrogatory
to be proper, see Rule 26(c) (“If objection is made to a part of an
interrogatory,
that part shall be specified”),
its entirety).
that is
but rather has objected to the interrogatory
Objection, at 1.
The Postal Service’s confidentiality
claim is mystifying.
apparently publicizes on a regular basis PETE information
See Exhibit B (copies of Postal Service newsletters).’
The Postal Service
on Priority Mail performance.
The newsletters
attached hereto
as Exhibit B were available free to the public in the lobby of the Postal Service’s
Washington,
D.C., headquarters.
performance
information.
(for the Colorado/Wyoming
Priority Mail
See, e.g., Exhibit B, 3 Rocky Mountain Summit No. 8, at 1
Performance
Overnight, and 2-day performance
1.
Each contains “geographically-specific”
Cluster, containing
PETE Combined,
data); 3 Long Island Dispatch No. 3, at 1 (for the
PETE stands for Priority End-to-End Measurement System. See response to
interrogatory DFCIUSPS-49 (inadvertently marked as DFCAJSPS-T34-49)
(March 2, 2000) (“Carlson 49”).
4
in
Long Island Performance
Cluster, containing
PETE “1-2 day” performance
data for Long
Island. NY Metro Area, and National); Triboro Voice No. 22, at 1 (for the Triboro
Performance
Cluster, containing
PETE “Composite”
performance
data for Triboro, NY
Metro Area, and National); 2 Fort Worth News No. 12, at 1 (for the Fort Worth
Performance
Cluster, containing
PETE “2 days” performance
1999. See also response to interrogatory
data), all dated August
Carlson 49, in which the Postal Service
provides a copy of a brochure entitled, “PETE Priority End-to-End
System.”
Measurement
The Postal Service has also provided without objection Priority Mail
performance
information
DFCKJSPS-T34-8
derived from the ODIS system.
See Response to Interrogatory
(February 252000).
The Postal Service also refers to PETE data in its communications
public.
See, e.g., Comprehensive
(‘Service performance,
as measured
a higher percent of intra-Priority
two days when compared
volume.“)
by Priority End to End (PETE), consistently
of Priority Mail performance
actual performance
the Postal Service’s public distribution
posed by Mr. Carlson.
information
that the Postal Service’s confidentiality
any claim of confidentiality.
shows
Network volume is delivered to our customers within
Even if geographically-specific
confidential,
1998, at 48
with the national rate, excluding all Priority Mail Network
These publications
Service demonstrate
Statement on Postal Operations
to the general
claim is spurious.
data were deemed to be
of such data constitutes
Indeed, the Postal Service answered
See responses to interrogatories
5
a waiver of
similar questions
DFC/USPS-T34-8
(February 25, 2000) and to Carlson 49. The Postal Service apparently
standard approach which leads it to take inconsistent
by the Postal
has a double-
positions with respect to different
intervenors -- here, Mr. Carlson on the one hand, and UPS on the other. All
intervenors,
competitors
and mailers alike, stand on the same footing in a rate case.
The bottom line is that no matter who asks for the information,
it either is confidential,
or
it is not.
Finally, it is curious for the Postal Service to take the position that data it already
has on the performance
of a service that it sells to the public is no business of the
public.
As we have shown, the Postal Service does not treat as confidential
“geographically-specific”
Priority Mail actual performance
UPS is willing to forego “geographically-specific”
performance
information.
Nevertheless,
data and to accept solely national
data for the period requested.
WHEREFORE,
Service’s objections
United Parcel Service respectfully
to interrogatory
UPS/USPS-T3C11
requests that the Postal
to Postal Service witness
Robinson be overruled, and that the Postal Service be ordered to produce the
information
and documents
requested
in that interrogatory,
Respectfully
c\/&
as modified herein.
submitted,
<-g ~-JI$ ~-5Y<<A ;/
John E. McKeever
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick &Wolfe
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
LLP
Of Counsel.
7
BEFORE THE
POSTAL RATE COMMISSION
POSTAL RATE AND FEE CHANGES,
2000
:
DOCKET NO. R2000-1
INTERROGATORIES
AND REQUEST FOR PRODUCTION
OF DOCUMENTS FROM UNITED PARCEL SERVICE TO
UNITED STATES POSTAL SERVICE WITNESS ROBINSON
(UPS/USPS-T3C11
and 12)
(February 16, 2000)
Pursuant to the Commission’s
serves the following interrogatories
Rules of Practice, United Parcel Service hereby
and request for production
United States Postal Service witness Robinson:
of documents
UPS/USPS-TM-l
Respectfully
directed to
1 and 12.
submitted,
William J. Pinamont
’
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick & Wolfe LLP
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
Of Counsel.
Exhibit
A
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS ROBINSON
UPS/USPS-T3C11.
(a) Does the Postal Service have a system or systems for
measuring the actual service performance
of Priority Mail, whether that performance
measured in terms of actual days to delivery, extent to which actual performance
service standards,
measure?
time-in-transit,
meets
time from collection to delivery, or any other
If so, identify all such systems, provide descriptions
manuals, guidelines,
is
directives, or other documents
are made and how the system operates),
of them (including any
which indicate how measurements
and provide all results for all such systems for
each year (by quarter, if available) from FY 1990 through FY 1999, and up to the
present.
(b)
Please identify and describe the Postal Service system known as,
or as identified by the acronym of, PETE.
UPS/USPS-T34-12.
attachment
Refer to Attachment
A. which is the Co,mpensation
to Contract Postal Unit Contract No. 363199-99-U-0158,
year contract beginning
relating to a two-
on November 7. 1998, to operate a Contract Postal Unit
(“CPU”) for the Postal Service.
The Compensation
attachment
states that the CPU
operator “will be paid 20% of the postal funds it receives and remits for the sale of
domestic Priority Mail and domestic Express Mail,” and “5% of the postal funds it
receives and remits for the sale of all other postal products and services” that are
subject to the contract.
(a)
Are the full amounts paid by the Postal Service to the CPU
operator under such contracts for the sale of Priority Mail attributed solely to Priority
-l-
.
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS ROBINSON
Mail? If so, indicate how and where this attribution is reflected in the Postal Service’s
presentation
in this proceeding.
(b)
Are the full amounts paid by the Postal Service to the CPU
operator under such contracts for the sale of Express Mail attributed
Mail? If so, indicate how and where this attribution
presentation
solely to Express
is reflected in the Postal Service’s
in this proceeding.
(4
In what cost segment and component
the Postal Service to CPU operators
are the payments
made by
under such contracts recorded in the case of
Priority Mail? Identify all accounts in which such payments on account of Priority Mail
are recorded.
63
In what cost segment and component
the Postal Service to CPU operators
are the payments
made by
under such contracts recorded in the case of
Express Mail? Identify all accounts in which such payments on account of Express Mail
are recorded.
(e)
In what cost segment and component
the Postal Service to the CPU operators
other postal products?
are the payments
made by
under such contracts recorded in the case of
Identify all accounts in which such payments on account of
other postal products are recorded.
0-I
Provide separately
for BY 1998 and FY 1999 the total amount of
payments made by the Postal Service under such contracts for the sale of Priority Mail.
-2-
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS ROBINSON
(9)
Provide separately
Service’s estimates of the total payments
for FY 2000 and for the Test Year the Postal
it will make under such contracts for the sale
of Priority Mail.
W
Provide separately
for BY 1998 and FY 1999 the total amount of
payments made by the Postal Service for such contracts for the sale of Express Mail.
0)
Provide separately
Service’s estimates of the total payments
for FY 2000 and for the Test Year the Postal
it will make under such contracts for the sale
of Express Mail.
0’)
Provide separately
for BY 1998 and FY 1999 the total amount of
payments made by the Postal Service under such contracts for the sale of all other
postal products.
(k)
Provide separately
Service’s estimates of the total payments
for FY 2000 and for the Test Year the Postal
it will make under these contracts for the sale
of all other postal products.
0)
How many such contracts with a “Performance
structure (see the attachment)
attachment
Payment Rate”
that is the same as or similar to that reflected in the
(i.e., where payments
are made to the CPU operator on the basis of a
stated percentage of the funds received for the sale of Priority Mail and/or Express Mail
at a rate higher than for other postal products) are currently in effect?
-3-
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS ROBINSON
(m)
Provide the total amount paid by the Postal Service under all such
contracts since the inception of this program up to the present, separately
Mail and for Express Mail.
-4-
for Priority
ATTACHMENT 4 - COMPENSATION
.
CONTRACT STATION/CONTRACT BRANCH/COMMUNITY
POST OFFICE
The supplier agreesto operatea CONTRACT POSTAL UNIT and will receive performancebasedpaymentsas set out below:
Performancepaymentswill be made in arrears,by the St. Louis Accounting Service Center within 2 I days after the end of eachPOStal
Ac6ounting Period(a twenty-eight day period beginning on a Saturdayand ending on a Friday comprising two designatedtwo-week
postal pay periods) except that payment for Accounting Period 13 shall be madewithin 28 daysafter irs end.
Performance Pavment Rate
PelfomlancePaymentratesare as follows:
Th: Supplier will be paid 20% of the postal funds it receivesand remits for the sale of domesticPriority Mail and domesticExpress
Mail.
The Supplier will be paid 5% of the postal funds it receivesand remits for the saleof all other postal productsand servicesthat are
checkedin SectionII of Attachment 1.
24
Attachment
A
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
mail, postage prepaid, in accordance
document
with Section 12 of the Commission’s
by first class
Rules of
Practice.
Phillip E. Wilson, Jr.
!
Attorney for United Parcel Service
Dated: February 16, 2000
Philadelphia, Pa.
Entries
mountasperformance
climbs
AP 11 Parlomwnce
Cluslter Stats
SERV?ZE QUARTERS 3 A-4
Aad
SPLYGad
Don’t miss your last chance to enter grand prize drawing
Y
N
M
W
0
T
II
N
A
T
R
F
E
R
A
A
G
N
I
I.
C
Y
C
Y
T
C
E
T
R
0
A
K
E
”
D
B
R
A
N
R
I
M
0
a
C
A
R
E
”
c
I
A
T
0
S
E
I
R
E
V
0
A
Y
T
R
S
N
T
V
I,
V
I
1
A
II
a
0
F
S
C
R
N
0
L.
E
R
E
A
C
II
E
D
E
0
P
E
N
T
E
C
Y
C
I,
E
S
R
N
D
E
v
0
Ii
P
M
I
0
V
D
G
G
T
N
E
hI
E
V
E
I
.II
C
A
A
P
G
A
II
M
S
T
N
A
I,
C
Exhibit
G
B
Yes! I know my goals!
:
LoNGIi~k~3hti
for LONG ISLAND PERFORMANCE CLUSTER EMF’LOYEB
Auousr 1999
Vol. 3 No. 3
7~~~~~~speedgoesbeyond
themail
-a District’s
Letter carrier’s tourney
benefits Leukemia Society
All employees are invild 10 participate in the fm annual VCP Golf
Classic at Mcdfdr
Mill FG3 GolfClubonOnl.
ckgmbd by Valley Swam Law
Carrim Glenn Fern u) honor hi hther.UWiICdNYCpoli~manwholos,
hirrigh,lolatkemiaddshispmycar.Ur
wlmMe0t.r prc.xe& will bencflt the
Leukemh sdl
of America
The Oolf Fxckkge la fl2.5. while *
dbmer-xlly package is $35. ckecks.
payable to V(F CkSf Classic, thould
t-z sent by Se& IS IO: Vff Golf Classic.doGlamRFeru.1333Labard
coun, “ninndak NV ,,553. For “WR
h?fomlation, call 483-5081.
“Plasebclp us make lida a IYcceP~
ful and enjoyable cvcn,,” Fuu says.
92.72
9228
93.09
93.0
92.0
92.0
2-3Day
89.75
9931
87.17
Goal
88.9
86.9
%.O
l-2my
99.97
99.95
85.38
Goal
88.9
86.9
85.0
b.SE OF USE (API,)
-id
Lmg Island
e&9
lbd
564
EXFC
Lcng ISlard
NY Ma-0 Area
Nalbml
PETE
Long ISland
NY M&m Area
National
Porral runner John Dcl-
Runnereirr lo beaf
the 9OdeSree heat.
Performance cluster Stats
Quarter 4 through July 30
Ovemlght
Goal
EXFC
Long island
NY Mebn Area
Nalbmal
llte Postal Sewice’s men’s and women’s teams each
of 290
finished immesrivcl” - lbird
Coordinated by Mid-Island ET
Rich Ripke and Syosw’s Posmustcr
Jack Fermm and VOMA Mii Fisher.
~ Doslal
team fielded 110 mmws M in&se of 40 panicipants oyer Ias,
year. With tirclcss support from
Syosrc,‘s Norman Dorf. and MidIsland’s John Wcider and Allison
Scheno. the Postal Service *earn hopes IO grow 10 become the
Barges, of all pardcipadng companies.
This was nat only II 3.5.mile race. *is was a gathering of
all crafts tunnhw tomher in unily. a date to meet cmdowcs
and dxir famili& f& all over l&~lrland:’
said W&&c
Supervisor lamer Casella
This is jus, our d&d year panicipating. Give us a few more
years and all you will see is the Poslal E&e: Ripke added.
P&DCs’
driveraises
nearly
$15K
forACS
Mid-IslendlWencm Nassau’s annual
Combined Federal Campaign (CFC)
drive ,o benefit the American Cancer
Society (ACS) brougb, in close to
SI5,wO for tbz -d
conscc~d”~ year.
The wall for the last three years is
537,COJ to help fnd a myriad of wonbwhile ACS proSrams.
Senior Plan, Manager Timorhy C.
Healy prcmkd the check to Guy Bud,
cxceutivc vie president A& Long Island di”isica. a, a June 22 gadxring of
drive organiurs.
“I want to onnk you all for dw fanmstic job you did will dx cancer drive this
yean I, was another fw year for us and
you’re the ona who made i, happen,”
Heady raid. “In UK last momb. thne of
our employees were diagnosed wirh cancer.,. Al, the people we help WillI this
DEUVERV
CCMRMA~ON
(APII,
AC,“.l 00.1
Long Island
SAFETY
95.1
loo
trm ~lmuph,130)
1dY.l co.,
mv
F~ma,rn,rn~,
‘.95
Yot~vlhlcybmbr4* IO.61 Il.,3
lww+wnaprwcwoYnrr)
Employees
answer
Aonkonkoma
PO‘artgallery’
Western
Nassaugetsnew
....I...............w........ ‘Questionot theMonlh’.**...*.
plantmanager
~......,,I.............,. Inaugurated
2
2
3
money will *ppnxials your efforts.”
“Nobody wants 10bear the words ‘Yw
have cancer: but if you hear those words
early enough... that’s what saves li”es
today,” Bud said. “Early dewdon Icads
to early ucamncn‘”
Hcaly added: “Thiscffon
couldn’,
have been possible wi,hwr Ihe work of
al, the “olunreerr who continue 10 sup
pord the CFC effom in both our p,an,s the leaden in CFC etTorts among all federal agencies hem on Long Island.
7bc dcdicadon and commi,menl *ha,
postal employees have shown in sewing
,he people of Long lrland So far beyond
just processing and delivering ,he mail.
is demans,ra,ed by this recent campaign,” he said.
I,1 Districi g&s up for this year’s
Combined Federal Campaign
This year’s Combined Federal Campaign will be Setting “ndenuay in Sep
,embu.
“We look for ,he conrinucd suppo”
of a11emplayccn so we can help dlow
less fonunate ,hanouncl”cs:‘Hcalysid.
RalphKoosdrawsfive
postmasters
toSyosaet...........
4
I
T~OROVOICE
N.i
forTRIBOROPERFORMANCECLUSTEREMPLOYEES
AUGUST. 1999
ISSUE NUMBER 22
‘Aquarium
fish’unveiledat
IVYAquarium!
On Thursday. July Is,, the
Tribe
Dirtricr unveiled ,be
gorgeous ‘Aquarium
Fish
sramps a, ,he NY Aquarium a,
Coney Irlmd. Brooklyn. The
location was a nawral as the Rsh
and coral reefs &pitied on ,l,e
rlampssrerlw,o”dirplsyr,he
Aquari”m.T?8ere were aIs0 majerlic Beluga Whaler. fierce
sharks. adorable penguins,
manta rays. giant rurtlcr and
many more marine animalr *hat
fomadPw”detiulb&ckdmpdmpGo
his interesting nnd fun eve”,.
A lktlc rain and humidiry did “0, in-
imporU”t
mmmunily au,rueL
Will be in the lxxl Trf6om “o&e.
even,
blessed day m remem-
babysit go, backed in i A~aa
0” the fin, nom apar,men1 in the house
rhe h&e-or on my blcck 10 ask for help. I sppmpched
our mailman. he PcdI of Jamaica’s Wccdbavc” Sra,ion.
He immediately cane m our rescue.
Petit fus, lalked 10 dx liltle girl Lo calm her down.
saying: ‘Ewyibblg
i* al, light. WCM ping 10 get dlc
door opened.” 7%~ only option m ge, in dw apaame”,
was to enter tbmugh the window. and he did. Afwr tie
dirmss. VICwere calm again when dac dmr was opened.
Mr. Peti1 is a hem and we M forever dmhankfu,,o him,
Our neighbmhmd needs more people like Mr. Petit.
Mot-c than I dzdicati mailman. he hm dcmonsvrvd ,o
be a good samaim. Hedeserves a medal forwha, he did
a”d we commend it.
can Women on Tour (AAWOT) Conference.
The conference provides a forum for uplifting. empowering pnd enhancing the quality of life fpr Africa” American
~ womch their families and communities thmugh economic.
i”lellsc,d
,“d spiritual dsvclopmsn,. I” its “in,,, year. the
nation’s forcmos, Black WO”,C”*Eempowerme”, conference
mcorpmler the mkxalion of P rareat vii* the infomntivc
seminars gcncrdly found at nationa! c”“ve”,io”s. and brings
,hcm logerber in a” environme”, which celcbra,cr cultwe
: and womnnhwd. Cues, speakers included ALlallah Sbabau.
social aclivis,; Bsv Smith. radio personality; and Dr. Joccly”
I E’&n.formcr”SSurgm”Ce”crpl.
:
‘Ibe U.S. Postal Service has a proud legacy of cotilmen,,
Auwsr,
1999
forFomwoF3HPERFoRMANcEcLsJ~EMPm~
Struggling
Vol. 2 No.12
to cope with no-fee
Loss of revenue takes bite out of bottom line for rural post offices
Cottlesrecoanizeci
forcommunity
service
MORAh=W;cmMyOdtSMnallcanmurr
ities cross the Oxal Plains. the town of
Mann has a dwindling population in
m,m of peple. But not in terms of nonrcsidcat vacant lots and neglected
iuch of Air free time in hforan mowing
grw,pabldng~rildings.planlingnower..
hauling way d&is. rating
buildings
aLldr.“cnrssloringmr~~dons
for Ibe lawn aueeu.
For their effort, the Moran Masonic
Lodge ,wl;
primed each with the
‘Community BuikJu*wrd.”
&el$The ‘&duty series:
The19208.*...“....,,.,.-..............
4
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document
mail, postage prepaid, in accordance
with Section 12 of the Commission’s
by first class
Rules of
Practice.
iqJ!z~
‘f‘ , *.,“z;>..,
Jihh E. McKeeGer
Attorney for United Parcel Service
Dated: March 13,200O
Philadelphia, Pa.
60209