0058~9
RECEIVEg
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
23
hfJ
4 39 p/j ‘96
‘OsT*i Rir: ?OHHISSIOH
OfFICf
SPECIAL SERVICES REFORM, 1996
Docket
OF THE sECfiETd~y
No. MC96-3
MOTION OF THE UNITED STATES POSTAL SERVICE FOR
RELIEF FROM OBLIGATION TO RESPOND TO lNTERROGATOR,lES
NASHUA/MYSTIC
(NM/USPS-37-65)
PENDING RESOLUTION OF MOTION FOR RECONSIDERATION
OF PRC ORDER 1129 AND, IN THE ALTERNATIVE,
OBJECTIONS
TO NASHUA/MYSTIC
INTERROGATORIES
(August 23, 1996)
On August
13, 1996,
filed interrogatories
On August
37-65
16, 1996,
PRC Order No. 1029,
consideration
Nashua/Mystic.
for the consideration
grounds
issued
Pending
,I--
expanded
moves
interrogatories
Color Lab (Nas;hua/Mys-tic)
States
Postal Service.
filed a Motion
For Reconsideration
the scope of Docket
No. MC96-3
Reply Mail (BRM) classification
§ 3623(b)
August
16, 1996,
Motion
a separate
proposal.
PRC Order No. 1 131, requesting
Today,
proposal
the Commission’s
to initiate
of the Nashua/Mystic
for reconsideration.
filed its response
hereby
to the United
Order or, in the alternative,
under 39 U.S.C.
Commission
directed
The Postal Service’s
the Commission’s
authority
Photo and Mystic
the Postal Service
which
of a Business
Nashua
in a separate
FROM
of interest
to
seeks reversal
of
classification
further
pleading,
to include
exercise
On August
Of
of its
proceeding
;!0,1996,
explanation
the
of the
the Postal Service
has
to that Order.
resolution
of its Motion
that it be relieved
NM/USPS-37-65.
For Reconsideration,
of any obligation
the Postal Service
to respond
to Nashua/Mystic
also
2-
ln all material
Nashua/Mystic’s
respects,
interest
Commission’s
disposition
these interrogatories
in Business
’ it appears
of any obligation
Commission
separate
should
respond
proceeding
the Postal Service
In any event,
objectionable
established
the Postal Service
on the following
be relieved
if the
by initiating
a
the Pos,tal Service
on a timetable
consistent
for such a proceeding.
requests
to interrogatories
would
Alternatively,
of the BRM proposal,
ln
For Reconsideration
For Reconsideration
to these interrogatories
by the
For Reconsideration,.
that the Postal Service
to the Motion
t,o
be affected
in its Motion
to these interrogatories.
schedule
to respond
Motion
request
to assume
to respond
with the procedural
obligation
initial
for consideration
be permitted
Accordingly,
prudent
to respond
should
Reply Mail and would
of the Postal Service’s
the event that the Postal Service’s
is granted,
relate exclusively
that it be relieved
NM/USPS-37-65
of any current
in this proceeding.
finds the aforementioned
additional
interrogatories
grounds:
NM/USPS-45
This interrogatory
for its operation
Mail experiment.”
the Postal
,‘-
Service
requests
of what
that the Postal Service
Nashua/Mystic
As the question
considers
indicate
refer to as the “Prepaid
calls for the statement
that it constitutes
’ That the Commission
reverse its decision
to include consideration
of Nashua/Mystic’s
the legal authority
impermissible
Courtesy
Reply
of a legal conclusion,
discovery.
to expand the scope of Docket
BRM proposal.
No. MC96-3
-3NM/USPS-49(a)
and (c)
Part (a) of this interrogatory
[any formal]
Courtesy
presentation”
management
in any such charts
other factual
information
Part fc) requests
Mail experiment”
opinions
in such charts
The Postal Service
and exhibits
concerning
objects
used in
the “Prepaid
to the disclosure
or recommendations
which
but does not object
of
may be
to the disclosure
of
and exhibits.
of authorization
if it was not approved
that it seeks the statement
of “all charts
The Postal Service
and exhibits,
“the source
Board of Governors.
copies
to the Board of Governors
Reply Mail experiment.”
any pre-decisional
reflected
requests
of the Prepaid Coiurtesy
by a resolution
objects
of a legal conclusion
Reply
(or any other vote)
to this interrogatory
concerning
of the
to the extent
such authorization.
NM/USPS-53
This interrogatory
considers
contrast
“Prepaid
requests
Courtesy
to a subclass
interrogatory
a declaration
Reply Mail”
or rate category
as it calls for the statement
of whether
to be a special
of mail).
the Postal Service
service,
(presumably,
The Postal Service
objects
of a legal conclusion.
Respectfully
UNITED
submitted,
STATES
POSTAL
SERVICE
By its attorneys:
Daniel J. Foucheaux,
Jr.
Chief Counsel, Ratemaking
Michael
./-
475 L’Enfant
Washington,
Plaza West, S.W.
D.C. 20260-l
137
3.7&aL
T. Tidwell
in
to this
.
\
,--.
-4-
CERTIFICATE
I hereby
certify
participants
that
of record
OF SERVICE
I have this day served the foregoing
in this proceeding
of Practice.
in accordance
.&
Michael
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-l
137
(202) 268-2998;
Fax -5402
August 23, 1996
document
with
section
upon all
‘12 of the Rules
2 Lz?QM&
T. Tidwell