BEFORE THE
POSTAL RATE COKWISSION
WASHINGTON, DC 20268-0001
RECEIVELI
Docket
SPECIAL SERVICES REFORM, 1996
No. MC96-3
DOUGLAS F. CARLSON
MOTION TO COMPEL UNITED STATES POSTAL SERVICE
WITNESS JOHN F. LANDWEHR
TO ANSWER INTERROGATORYDFC/USPS-T3-l(c)
August
31,
1996
Pursuant
to section
25(d) of the Rules of Practice,
I,
Douglas F. Carlson,
hereby request that the commission
order
United States Postal Service witness John F. Landwehr to
answer interrogatory
DFC/USPS-T3-l(c).
BACKGROUND
Referring
to witness
Landwehr's
testimony
the post offices
in Middleburg,
VA, San Luis,
Blaine,
WA, interrogatory
DFC/USPS-T3-1 reads
concerning
AZ, and
as follows:
14-16,
you stated,
"My experience
On page 10, lines
leads
me to conclude
that
while
these
offices
are atypical
there
are also
many similar
in the pool
of all
post
offices,
offices
nationwide."
(a)
* * *
(b)
*
* *
(c)
Please
confirm
that
these
"similar"
post
offices
atypical
in the pool
of all
post
offices.
are,
nevertheless,
If you do not confirm,
please
explain
how post
offices
that
post
offices
are not also,
are similar
to "atypical"
themselves,
"atypical."
Witness
Landwehr
responded
to subsection
..
follows:
Please
(c)
see
USPS-T-3,
page
ten,
1
lines
14-16.
as
DISCUSSION
By merely
on which
failed
my question
to answer
strongly
offices
these
that
A straightforward
would
whether
are,
nonetheless,
In the
Presiding
2)
provide
counsel
MC96-313,
for
answer
of all
similar
post
some reason,
"similar"
post
to this
"many similar
offices
motion
can be
witness
offices
to
question
nationwide"
practice
the Postal
See Rules
Attachment
Service
B, p.
on August
refused
to
contradicts
discovery
of Practice
28,
The Postal
to my question.
to expedite
('see
Attachment
Counsel
answer.
to evade my question
desire
interrogatories.
for
offices
and no longer
No. MC96-3/3,
a revised
attempt
commission's
the
Ruling
a revised
Service's
so "many"
sentence
pool
answer
of reducing
Officer's
to request
1996,
in the
has
atypical.
spirit
I I contacted
post
these
be atypical.
clarify
"many similar
are commonplace
consider
Service
Landwehr's
Or perhaps,
does not
testimony
Witness
perhaps
they
atypical.
Landwehr
the Postal
atypical
themselves,
However,
exist
considered
was based,
that
are,
offices.
me back to the original
the question.
suggests
nationwide"
post
referring
through
the
written
§ 25 and Ruling
No.
B, p. 6.
CONCLUSION
Interrogatory
straightforward
Landwehr's
,-
DFC/USPS-T3-l(c)
question
testimony.
designed
The question
is a simple,
to clarify
is highly
witness
relevant
to
,,-I,
this
proceeding
because
justification
fee,
for
which
would
it
will
the Postal
affect
box
customers
is based primarily
experiences
of atvpical
request
Service
to provide
a simple,
Dated:
August
1996
31,
at
offices.
the
part
proposed
post
on testimony
post
that
whether
Service's
nationwide,
respectfully
explain
nonresident
offices
about
Therefore,
commission
of the
order
straightforward
the
I
the
Postal
answer.
DOUGLAS F. CARLSON
CERTIFICATE
I hereby
foregoing
document
in accordance
sections
certify
upon the
with
3(B)(3)
that
section
OF SERVICE
I have this
required
day served
participants
12 of the Rules
and 3(C) of the
Special
the
of record
of Practice
Rules
and
of Practice.
DOUGLAS F. CARLSON
August 31,
Emeryville,
1996
California
3