BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-ooo1
4ECElVED
Nov6
12 02 PM'96 ,,~ I:#
POSTAL RATE Cn~,4lLSICN
OFFICE '3: TH' StCRETARY
Special
Services
Docket
Fees and Classifications
No. MC96-3
ANSWEROF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORYUSPS/OCA-T400-29
OF UNITED STATES POSTAI. SERVICE
REDIRECTED TO WITNESS SHERMAN (USPS/OCA-T400-29)
(NOVEMBER6, 1996)
The Office
of the Consumer Advocate
of Roger Sherman to interrogatory
1996),
redirected
stated
verbatim
Witness
filed
from witness
and is followed
hereby
submits
USPS/OCA-T400-29
Collins.
the answer
(October
The interrogatory
25,
is
by the response.
Sherman is out of town and his
declaration
will
later.
Respectfully
submitted,
EMMETTRAND COSTICH
Assistant
Director
Office of the Consumer Advocate
be
ANSWEROF OCA WITNESS ROGERSHERMAN
TO REDIRECTED INTERROGATORYUSPS/OCA-T400-29
USPS/OCA-T400-29.
At page 22, lines 21 - page 23, line 14 of
your testimony,
you discuss witness
Patelunas's
"speculative
reasons"
for the cost difference
between postal
cards and private
cards cited in his response to OCA/USPS-T5-11, Tr. 2/252-53.
YOU
state that postal
cards "are more compatible
with postal
processing
equipment than post cards."
You also state that
"[aIddress
hygiene may be better."
a.
Please confirm
that in his response to interrogatory
OCA/USPS-TS-11, Tr. 2/252-53,
witness
Patelunas
also
states
that it is possible
"that postal
cards are
misidentified
as private
cards during data collection."
If you do not confirm,
please explain
in detail.
Do you have any basis to dispute
witness
Patelunas's
b.
statement
that it is possible
"that
postal
cards are
misidentified
as private
cards during data collection?"
If so, please explain
in detail.
A.
a.-b.
Please
see my response
to USPS/OCA-TlOO-28.
DECLARATION
I,
Roger Sherman, declare
answer to redirected
States
Postal
knowledge,
Service
information
under penalty
interrogatory
is true
USPS/OCA-T400-29
and correct,
and belief.
of perjury
that
the
of the United
to the best. of my
CERTIFICATE OF SERVICE
I hereby
certify
document upon all
accordance
with
that
I have this
participants
section
3.B(3)
of record
date
served
in this
of the special
proceeding
rules
EMMETTRAND COSTICH
Attorney
Washington,
D.C.
November 6, 1996
20268-0001
the foregoing
in'
of practice.