ORtGIRAiL
c3G5 0 9 2
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
SPECIAL SERVICES REFORM, 1996
RECEIVEI\
IEP J
Docket
No. MC96-3
DOUGLAS F. CARLSON
MOTION TO COMPEL UNITED STATES POSTAL SERVICE
WITNESS SUSAN W. NEEDBAW
TO ANSWER INTERROGATORYDFC/USPS-T7-5(a)
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
Susan W. Needham to
answer interrogatory
DFC/USPS-T7-5(a).
BACKGROUND
Interrogatory
DFC/USPS-T7-5
reads
as follows:
In Section
IX, you introduced
newspaper
articles
as
evidence
of the "high
value
of service
from,
and the demand
for,
post-office-box
service."
USPS-T-7 at p. 25, lines
1920.
a. Do you confirm
that post offices
in towns and cities
with
vanity
addresses
experience
a demand for boxes by
nonresidents
that
is atvnicallv
hiuher
than the general
pattern
of demand for boxes by nonresidents
that
the entire
pool of post offices
in the country
experiences?
If not,
please
explain
and provide
available
data.
If your answer to (a) is yes, for typical,
nondo you confirm
that
factors
other
than
vanity
post offices
prestige
of the address
may be most
significant
for
nonresidents
who obtain
box service
at other
than their
local
post office?
b.
Witness
Needham responded
as follows:
I am unable
to confirm
because
the demand for
(a!
boxes by non-residents
in United
States
border
towns may
even higher
than the demand in vanity
address
areas.
1
-
be
8 38 RM ‘96
Additionally,
I am not aware of all non-vanity,
non-border
cities
and towns that,
for whatever
reasons,
may have
atypically
higher
demands for box service
by non-residents.
Not
Ib)
information
applicable.
Moreover,
to confirm.
I do not
have the
DISCUSSION
The question
in subsection
However,
witness
Instead,
she merely
(a) is straightforward.
Needham has failed
cites
two irrelevant
she has no information
as evidence
sufficient
to answer
information
First,
in claiming
boxes with
general
vanity
pattern
addresses
that
non-residents
in United
Interrogatory
DFCfUSPS-T7-5(a).
representative
10,
in the
14-16.
demand for
pattern
of demand in the
Second,
whether
higher
The question
vanity
witness
demand for
than
aware of all
the
and,
witness
boxes
addresses
to
by definition,
offices
testimony
not
boxes
by
in the
at USPS-T-3,
a comparison
with
by
are completely
of demand for
asks for
the
p.
of
the oeneral
country.
boxes with
"non-vanity,
than
Response
towns
of post
Needham claims
general
demand for
higher
towns.
pattern
Landwehr's
boxes with
whether
Border
pool
have
of the demand for
are atypical
entire
See witness
lines
state
border
of the general
nonresidents
country.
they
which
the question.
she is unaware
because
about
boxes nationwide,
States
question.
she does not
is atypically
of demand for
the
factors
that
she cannot
Needham notes
irrelevant
to answer
vanity
pattern
that
she cannot
addresses
is
of demand because
non-border
2
cities
state
atypically
she is not
and towns
that,
for
whatever
reasons,
box service
may have atvoicallv
by non-residents."
DFC/USPS-T7-5(a)
(emphasis
cities
that
and towns
atvpical
pattern
Since
comprise
answer
added).
irrelevant
of demand for
the
Needham's
to answer
demands for
to Interrogatory
Non-vanity,
non-border
higher
demand are
to a discussion
of the
boxes.
two irrelevant
witness
has failed
Response
may have atypically
and therefore
general
higher
sentences
entire
quoted
answer,
the question
above
witness
or explain
Needham
why she cannot
it.
CONCLUSION
Interrogatory
this
DFC/USPS-T7-5(a)
proceeding
nonresident
because
fee
obtain
convenience
reasons.
the
three
only
atypical
lines
all
higher
boxes
than
testimony
Since
offices
demand for
nonresident
to
case for
the
or border
post
offices
addresses
the general
nonresident
that
fee would
for
3
p.
be applied
of whether
are
10,
at
the
is atypically
of demand nationwide
evaluating
impose on the
-
hardly
USPS-T-3,
boxes and the
might
case discusses
offices
by nonresidents
pattern
or
15-17.
in the
the question
is critical
boxholders
lines
in general.
nationwide,
vanity
obtain
presented
that
business,
p. 37,
the nonresident
by nonresidents
why people
Service's
prestige,
USPS-T-7,
of post
14-16.
post
boxes for
vanity
representative
the Postal
relevant
seems to be based on the premise
nonresidents
However,
is highly
the
burdens
Postal
for
reasons
these
Service.
..c-
For example,
if
with
vanity
a demand for
boxes by nonresidents
that
than
the
then
perhaps
vanity
general
the people
hold
at their
arguably
reflect
would
the
comparison
evidence
who hold
their
penalize
added value
Presiding
spirit
I contacted
counsel
Needham refused
contradicts
the
written
and Ruling
regretfully
for
motion
to answer
Dated:
August
31,
fee
accurately
A
be important
practice
desire
Attachment
answer
interrogatory
on August
and/or
28,
witness
to my question.
to expedite
B, p. 6.
the commission
B, p.
my question
See Rules
Attachment
(a
Service
to answer
interrogatories.
Service
A nonresident
Counsel
a revised
refusal
that
they
box service.
the Postal
commission's
request
than
problems
of demand will
answer.
to provide
No. MC96-313,
other
not
No. MC96-313,
a revised
Service's
at non-
issue.
Ruling
to request
The Postal
customers,
of reducing
Officer's
service
of nonresident
this
boxes
reasons
office.
of the two patterns
In the
through
these
higher
boxes nationwide,
boxes for
post
experience
is atypically
nonresident
to avoid
local
in resolving
addresses
of demand for
such as a desire
experience
1996,
offices
pattern
addresses
prestige,
2),
the
order
discovery
of Practice
§ 25
Therefore,
the
Postal
DFC/USPS-T7-5(a).
1996
DOUGLAS F. CARLSON
,-
4
I
CERTIFICATE OF SERVICE
I hereby
foregoing
document
in accordance
sections
certify
I have this
upon the required
with
3(B)(3)
that
section
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