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REW'EO
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
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SPECIAL SERVICES REFORM, 1996
Docket
No. IMC96-3
MOTION OF THE UNITED STATES POSTAL SERVICE FOR
EXTENSION OF TIME TO RESPOND TO INTERROGATORIES
FROM
NASHUA/MYSTIC
(NM/USPS-l-7)
(August 22, 1996)
On August
directed
8, 1996,
interrogatories
On August
Obligation
Photo and Mystic
NM/UPS-l
19, 1996,
To Respond
Commission’s
Nashua
through
disposition
27 to the United
the Postal Service
To Interrogatories
Color Lab (Nashua/Mystic)
filed a Motion
NM/USPS-S
of its August
States
16, 1996,
For Relief From Its
through
Motion
IPostal Service.
27, pending
the
For Reconsideration
of
PRC Order No. 1129.
In accordance
with
Service
will file tomorrow
request
for clarification
than initially
Service
extent
exceed
will address
/‘-
interrogatories
consider
Responses
addressing
in tomorrow’s
NM/USPS-l
among
inquiries
Motion
proposal
the C:ommission’s
PRC
other things,
is significa,ntly
To Enlarge.
supplemental
through
th,e Postal
For Reconsidleration.
to address,
in their July 15, 1996,
this point
20, 1996),
for the Motion
the Postal Service
the scope of the classification
Commission
pleading
the scope of Nashua/Mystic’s
outlined
to which
a supplemental
of the grounds
Order No. 1 131 invites
issue of whether
PRC Order No. 1 131 (August
the
broader
The Postal
pleading,
including
the
7 appear to significantly
that Nashua/Mystic:
would
have the
in this proceeding.
to NM/USPS-l
through
7 are due today.
Notwithstanding
tlhe
--
/-‘
importance
Docket
these
the Postal Service
NO. MC96-3
particular
responses
witnesses
who would
interrogatories,
MC96-3
preparing
responsibilities
been able to prepare
Putting
the August
pleading
can prepare
responses
6, 1996.
relevant
other non-Docket
to interrogatories
Accordingly,
7 in time for filing
toclay,
may grant in response
For Reconsideration
through
through
to
and the
the Postal Service
NM/USPS-l
No.
has not
through
the Postal Service
NM/USPS-l
to
the Postal Service
of any relief the Commission
to be filed tomorrow,
responsefs
to the scope of the case filed by the
Accordingly,
Motion
requests,
their time to preparing
and obligations.’
to NM/USPS-l
to discovery
in preparing
as well as juggling
Postal Service
to interrogatories
be involved
for hearings,
aside the impact
supplemental
September
requests
responses
19, 1996,
responses
of late, have devoted
to other discovery
Postal Service,
respond
places on timely
antic:ipates
7 for filing
respectfully
requests
that it
by Friday,
leave to
7 by that date
Respectfully
UNITED
submitted,
STATES
POSTAL
SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemakinsg
d4
Michael
?
2-&4--@3
T. Tidwell
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
(202) 268-2998;
Fax -5402
August 22, 1996
,r’.
’ Some of the interrogatories
require analysis of information filed in Olocket No. R94-1
and other data on special services not at issue in this proceeding.
-3CERTIFICATE OF SERVICE
I hereby
certify
participants
that
of record
I have this day served the foregoing
in this proceeding
in accordance
document
with
of Practice.
Michael
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
(202) 268-2998;
Fax -5402
August 22, 1996
T. Tidwell
upon all
section1 12 of the Rules