BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268
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Services
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No. MC984
FIRST SET OF INTERROGATORIES
OF PITNEY BOWES INCORPORATED
TO USPS WITNESS PLUNKETT
(PBIUSPS-T6-1)
Pursuant
to Sections 25 and 26 of the Commission’s
Bowes Incorporated
for the production
If data
requested,
(“PB”) hereby propounds
the attached interrogatories
Pitney
and requests
of documents.
requested
are not available
any data available
(2) susceptible
Rules of Practice,
to being
in the exact
in (1) a substantially
converted
format
or level of detail
similar format or level of detail or
to the requested
format
and detail
should
be
provided,
The
production
attached to responses
to the volume
contacted
of documents
to these interrogatories.
of material
or otherwise
should
If production
the undersigned
be made
by photocopies
of copies is infeasible
counsel
to PB should
due
be
to arrange for inspection of the documents.
The term “document”
writing,
requested
means all repositories
audio or video recording
non-identical
or electronically
copies or versions of any document.
of fixed information,
stored information
including
and including
any
all
The term “oral communication”
The term “communication”
means any utterance that is not a document.
means all documents
The terms “identify,” “identification,”
(1)
and oral communications.
or “identity” mean:
With respect to an individual,
his name and present or last known
home and business address (including street name and number, city or town, state, zip
code and telephone
(2)
number).
With respect to a person other than an individual,
type or organization,
the address
of its principal
place of business
name and number, city or town, state, zip code and telephone
and place of its incorporation
knowledge
or organization,
list, memorandum,
identification
original
street
number), the jurisdiction
and the identity of all individuals
the type of document
report), date, title or a description
of its contents,
delivered,
(including
having
of the matter with respect to which the person is named;
(3) With respect to a document,
matter
its full name and
identification
(a,
of the general
of the person
who
prepared
letter, record,
nature or subject
the document,
of the person for whom the document was prepared and/or to whom it was
identification
of the person who has possession,
of the document,
and identification
of each
custody or control over the
person
who
has possession,
custody or control over each copy of the document.
A communication
given subject
embodies,
means
reflects,
or document
“relating, ” “related,”
any communication
identifies,
or document
or which
which
“relates”
constitutes,
refers to, deal with or is in any way germane
to any
contains,
to that
subject,
including
without
limitation,
documents
concerning
the preparation
of other
documents.
Responses
accompanied
whether
by workpapers.
prepared
necessary,
numbers
to requests for explanations
The term “workpapers”
manually, mechanically
be prepared
of the derivation
responses
Such workpapers
should, if
and should “show what the
are, what numbers were added to other numbers to achieve a final result.”
The witness should “prepare sufficient workpapers
to understand
achieve
shall include all backup material
or electronically.
as part of the witness’s
of numbers should be
how he took data from a primary source and developed
his final results.”
manipulations
instructions
so that it is possible for a third party
Docket No. R83-1, Tr. 101279596.
were performed
and
no English
by an electronic
language
Where the arithmetic
digital computer
intermediate
that data to
with internally
printouts
were
stored
prepared,
the
arithmetic steps should be replicated by manual or other means.
If you are unable to provide any of the requested documents
any of the interrogatories,
documents
or information
this request
is directed
please provide an explanation
for each instance
cannot be or have not been provided.
cannot respond,
or information
but another witness
as to
in which
If the witness to whom
can, please redirect the
request to that witness.
PBIUSPS-TBI
a. Is Exhibit A to your response to OGVUSPS-T5-21(a)
terms of Contract No. 102590-98-B-HO25
based on the prices and
(The MOL Printing Contract)?
3
b.
If not, please provide information
in the format of that exhibit reflective of
prices and terms of the MOL Printing Contract,
calculation,
with references
with a complete
explanation
of your
to such contract as appropriate.
Respectfully
submitted,
- +-yzD&JL-
Ian D. Volner
N. Frank Wiggins
Venable, Baetjer, Howard & Civiletti, LLP
1201 New York Avenue, NW
Washington, DC 20005
(202) 962-4800
Aubrey M. Daniel Ill
Carolyn H. Williams
Williams & Connolly
725 12th Street, NW
Washington, DC 20005
Counsel to Pitney Bowes Inc.
4
.
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CFRTIFICATE
OF SERVICF
I hereby certify that I have on this date served this document
record in this proceeding
in accordance
upon all participants
with section 12 of the rules of practice.
DATE: August 21, 1998
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