BEFORETHE
POSTAL RATECOMMISSION
WASHINGTON DC 20268~0001
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Docket No. R2000- 1
POSTAL RATEAND FEECHANGES, 2000
)
ALLIANCE OF NONPROFIT MAILERS
AMERICAN BUSINESSPRESS
COALITION OF RELIGIOUS PRESSASSOCIATIONS
DOW JONES &COMPANY, INC.
MAGAZINE PUBLISHERSOF AMERICA, INC.
NATIONAL NEWSPAPERASSOCIATION
THE MCGRAW-HILL COMPANIES, INC.
AND
TIME WARNER INC.
IDENTIFICATION OF EXPECTEDAMOUNT
OF ORAL CROSS-EXAMINATION
and
REQUESTFOR SPECIAL SCHEDULING OF
DESIGNATED WITNESSES
(March 16,200O)
Pursuant to the direction
Nonprofit
Mailers, American
Associations,
America,
Dow
Inc.,
Jones
National
and
of the Presiding Officer, the Alliance
Business Press, Coalition
& Company,
Newspaper
Time
Warner,
Inc.,
Inc.
of Religious Press
Magazine
Association,
Companies,
Inc.
Intervenors”)
report that, at present, they expect
of
the
(collectively,
to,conduct
Publishers of
McGraw-Hill
“Periodicals
oral cross-
examination
of the following
Postal Service witnesses
to the extent
indicated:
Extent of Oral Cross-Examination
USPSWitness
Xie
(USPST-l)
Light
Hunter
(USPST-5)
Moderate
Tolley
(USPST-6)
Light
Tayman
(USPST-9)
Moderate
Kingsley
(USPST-l 0)
Moderate
Meehan
(USPS T-l 1)
Light
Baron
(USPST-l 2)
Moderate
to Heavy
Raymond
(USPST-l 3)
Moderate
to Heavy
Kashani
(USPST-l 4)
Light
Bozzo
,(USPST-l 5)
Light
Degen
(USPST-16)
Moderate
Van-Ty-Smith
(USPST-l 7)
Light
Bradley
(USPST-l 8)
Moderate
Pickett
(USPST-l 9)
Light
Smith
(USPST-21)
Light
Yacobucci
(USPST-25)
Moderate
Mayes
(USPST-32)
Light
Taufique
(USPST-38)
Light
2
REQUESTREGARDING SPECIAL SCHEDULING
With reference to the Presiding Officer’s Ruling No. R2000-l/4 (issued
February 25, 2000), Periodicals lntervenors hereby respectfully
seven of the witnesses th,ey have designated
examination
(Tayman,
Yacobucci)
Kingsley, Baron, Raymond,
be scheduled
11, or between
for moderate
for appearance
or heavy cross-
Degen.
Bradley and
either during the week of April
April 24 and May 5,200O.
Periodicals lntervenors are acting
in concert
the greatest extent possible. Given the complexity
the necessarily compressed
of procedural
request that
and
in this proceeding
of this proceeding
to
and
schedule, we hope that our unified efforts are
logistical
value
to all concerned,
including
the
Commission.
Periodicals lntervenors will be coordinating
schedules.
Specifically,
one
or two
Intervenors’
member
examination
of each USPSwitness designated
organizations
their cross-examination
representatives
will take
of
Periodicals
responsibility
for cross-
above.
During the week of April 17, attorneys for members APB and Dow
Jones, as well as the technical
responsibilities
preparation)
related
expert for MPA - each having important
to cross-examination
-- will be unavailable
(and/or
due to unavoidable
result, Periodicals Intervenors’ ability to conduct
witnesses
during
the
week
cross-examination
of April
3
17 will
conflicts.
cross-examination
be
necessarily
As a
of key
-- and
unavoidably
- constrained.
For that reason, we respectfully
the seven witnesses identified
request that
herein on page three not be scheduled
during that week.
This request has been discussed with the Postal Service counsel.
Respectfully submitted,
L-z**
David M. Levy u
Christopher T. Shenk
Sidley & Austin
1722 Eye Street, NW
Washington, DC 20006-3704
For the Alliance of
Nonprofit Mailers
David Straus
Thompson Coburn
Suite 900
700 14” Street, NW
Washington, DC 20005
For the American
Business Press
0
Michael F. McB!k&
Bruce W. Neely
Joseph H. Fagan
LeBoeuf, Lamb, Greene & McRae LLP
1875 Connecticut Ave., NW
Suite 1200
Washington DC 20009-5728
For Dow Jones & Co.. Inc.
Anne R. Noble
Magazine Publishers of
America, Inc.
1211 Connecticut Ave. NW
Suite 610
Washington DC 20036
Timothy W. Bergin u
Squire, Sanders & Dempsey
1201 Pennsylvania Ave. NW
PO Box 407
Washington DC 20044-0407
For The McGraw-Hill
Companies, Inc.
Tonda F. Rush
PO Box 50301
Arlington VA 22205
For National Newspaper
Ass’n.
4
John M. Burzio
Timothy L. Keegan
Canal Square, Suite 540
1054 31s+Street, NW
Washington DC 20007-4403
For Time Warner, Inc.
“--“pw
Stephen M. Feldman
121’5 17th Street NW
Washington DC 20036
For Coalition of Religious Press Associations
S