OG557’G
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON
RECEIVEO
DC 20268-0001
h
3 14
J
PM ‘96
po!jTAi RUE COH+.~~-~~.,
SPECIAL SERVICES FEES AND CLASSIFICATION]
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MOTION TO COMPEL RESPONSES TO INTERROGATORIES
Responses were not received to the following interrogatories:
DBP/USPS-T3-19
DBP/USPS-T7-
parts [e] though [i] and [q] through [w]
4 through 6
I believe that I did not receive full and complete responses to these specrfic interrogatories
the oral cross examination
to them at this time.
during
of these witnesses and I am not willing for forego the written response
I move to compel the United States Postal Service tlo respond to my original
interrogatories.
There were a number of instances in which the United States Postal Service utilized a Library
Reference
in its response to an interrogatory
interrogatories,
of mine.
In the instructiclns that I utilized in my
I requested a copy of any Library Reference that was utili,zed in a response.
Postal Service did not provide the copy nor did they provide it on the follow-up
mailed by me on September 3, 1996.
In their response to Interrogatory
The
interrogatories
DBP/USPS-T8-16[d],
the
Postal Service indicated that the Library Reference was available at the Postal Rate Commission
and the USPS Library.
located
some distance
Both of these locations are in Washington
from Washington
and to require participants
to make a trip to Washington
references does not appear to be an equitable method of conducting
just to view library
discovery.
reference, the Postal Service even included testimony from a previous case.
In this particular
If the Postal Service
is allowed to utilize library references with those located some distance from Washington,
only serve to frustrate complete discovery.
it will
I move that the Postal Service be ordered to provide
me with a copy of the Library Reference utilized
September 30, 1996 Respectfully submitted,
DAVID B. POPKIN, POST OFFICE BOX 528, ENGLEWOOD,
MOTION TO MODIFY THE COMMISSION’S
,,-..
_-.--.
utilizes a Library Reference
RULES OF PRACTICE
Rules of Practice so that if a resppn ’ fi]ed . to an
and all of the lntervenors receiving the 52Pl 0 se are
‘661 V i3(1
,>~.;b,..,,,
-
I wish to file a motion to modify the Commission’s
Interrogatory
NJ 07631-O;
--
located 50 or more miles from Washington,
I-
then the party responding must provide a copy of the
Library Reference with the response.
Changing the rules to require this will create a minimal burden on the responding
party and will
provide for a more appropriate discovery by lntetvenors who are located some distance from the
source of these references.
I believe that it would not be appropriate for an Intervener, such as
make a trip to Washington just to get the full nature of the response to an
myself, to have to
Interrogatory.
September 30, 1996 Respectfully submitted, Li2G?%PA
-
DAVID B. POPKIN, POST OFFICE BOX 528, ENGLEWOOD,
INTERROGATORIES
NJ 07631-13528
OF DAVID B. POPKIN TO THE UNITED STATES POSTAL SERVICE
David B. Popkin hereby requests the United States Postal Service to answer, fully and completely,
the following follow-up interrogatories
Practice and Procedure.
pursuant to Rules 25 and 26 of the Commission’s
The conditions mentioned in my original interrogatories
Rules of
elated August 6,
1996 are incorporated herein by reference [I aPain request that they be followed this time].
event that these are received late, I move for acceptance
In the
particularly since I was in California and
Canada from September 19 through 26, 1996.
September 30, 1996 Respectfully submitted,
ML
DAVID B. POPKIN, POST OFFICE BOX 528, ENGLEWOOD,
DBPIUSPS-T8-35
and [il.
I am still somewhat confused by your response to DBP/USPS-T8-14[e],
You refer to the attachment
DBP/USPS-Tl-3
NJ 07631-19528
to DBP/USPS-T8-3.
[a] Should
[b] If not, explain.
The letter to all District Managers dated August
DBPIUSPS-T8-36
September 11, 1996 revised response to DBP/USPS-Tl-3
to DBPIUSPS-T8-14
[e], [g], [i], and [k] leaves me confused.
seems to state that there is a 100% requirement
1, 1996 provided on the
when taken together with the responses
Your response to parts [e], [g], and [i]
appears to refer to both the DMMTB and to the August 1, 1996 letter.
Your response to part [k]
to complete the return receipt at the time of
The August 1, 1996 letter appears to indicate in the first bull& item [paragraph #4] that
delivery offices should review current delivery arrangements
,-
be to
redirected from Witness Lyons - namely the letter dated August 1, 1996 to District
Managers from Sandra D. Curran?
delivery.
that reference
[g],
over accountable
regarding practices such as handing
mail to be signed for at a “later”, more convenient time.
The fourth bullet item
[the first paragraph on page 21 appears to indicate that long standing, unofficial arrangements
promote exceptions
to stated procedures for “convenience”
2
that
need to b’s reviewed and voided if
necessary.
_,-.
The following paragraph appears to indicate that any of these arrangements
not be tolerated.
should
[a] Does the first bullet item of the August 1, 1996 letter allow a delivery office to
review and then retain delivery arrangements
which allow for handing over accountable
mail to be
signed for at a “later”, more convenient time? [b] If not, why is the letter written so as to imply that
it could be done?
[c] If so, what is the authority for allowing this to be done? [d] Does the fourth
bullet item allow long standing, unofficial arrangements
to be reviewed and then retained?
not, why is the letter written so as to imply that it could be done?
[e] If
[fl Do~ss your response to parts
[e], [g], and [i] indicate that there are exceptions to the various manual references that you have
provided?
[g]
If so, provide a complete
listing of all exceptions
that are either authorized
or
condoned and the authority for each exception.
DBPIUSPS-T8-37
In your response to DBPNSPS-T8-24
parts [i] thrordgh bj], you indicated that
you were unable to identify specific figures in the SO-$25,000 value inscrements for which costs
vary. If you are unable to identify the greater security or care that is being provided for each of the
value increments,
then I request an institutional
response to parts [i] through bj] of my original
interrogatory.
DBPIUSPS-T8-38
attachments.
In your response to DBPIUSPS-T8-24
part [ss], you refer to four pages of
Which specific sections of this manual provide the details of how this need for
special security or care is communicated
DBPIUSPS-TB-39
as the article passes through the system to delivery?
[a] Your response to DBPIUSPS-T8-25
part [e] indicates
Does this mean that there are no other cells that meet the condition?
[b]
“Not applicable”.
If not, what does it
mean? [c] Are there any other cells meeting the condition?.
DBPIUSPS-T8-40
In your response
regarding the difference
to DBPNSPS-T8-25[i],
you mention
six considerations
between Standard Mail - Insured and Priority Mail - Registered.
opinion each of these six considerations
In my
either are similar for both services or favor the less
expensive Priority Mail - Registered [except for perhaps the requirement for sealing the registered
mail].
For each of the six considerations,
and indicate any advantages
itemize how they would differ between the two services
that would be held by the more expensive? Standard Mail - Insured
rate.
r-
DBPIUSPS-T8-41
In your response to DBPNSPS-T8-27,
you indicate that there were 12 claims
that exceeded $500, that the second highest claim was $1588.18, and tliat the average of the 2”d
3
-
through 121hhighest claims was $779.26.
[a] Was there any consideration
given to reducing the
$50,000 limit down to a higher number than the proposed $500 limit so a:; to in&&
some or all of
these claims? [b] If not, why not? [c] If so, why was it not adopted?
DBPIUSPS-T8-42
Regarding your response to DBPIUSPS-TB-30,
the three pages provided as an attachment
to your response provide the definition
“philatelic card product” as utilized in your previous response?
the “A” and afi:er “messages.”
[a:] what specific part[s] of
[b] If I insert quotation marks before
can you then confirm the Section 22;!.11
Schedule - both present and proposed wording?
Which philatelic card products are not cards?
of the term
of the Classification
[c] If not, why not and [provide the definition?
[d]
[e] May philatelic card prloducts which do not have
the postage canceled be utilized for the transmission
of messages?
[fj If not, why not? [g] Does
a philatelic card product, other than one on which the postage has been canceled, meet all of the
requirements to qualify it as a Postal/Stamped
card as specified in the Classification
If not, why not?
of the last clause in your response to parts [i-l]? b]
[i] What is the significance
Which philatelic card products are used for collection purposes only?
Schedule?
[k:] What characteristics
the philatelic card product render it usable for collection purposes only?
[h]
of
[I] If I decide to utilize a
philatelic card product for collection purposes, am I later allowed to utilize if for mailing purposes if
the postage has not been canceled?
Reorganization
[m]
If not, why not?
[n]
Which section of the Postal
Act provides the authority for pricing philatelic card products different than Postal or
Stamped Cards?
stamped cards?
[o]
Is the pricing of philatelic card products different than that for postal or
[p] If not, explain?
[q] Your response to the original part [o] did not provide the
name and title of the Postal Service officer or employee who is responsible
card products at a price which is different than postal/stamped
for pricing philatelic
cards. The pricing is different and
whether or not that is appropriate is not necessary for you to agree to in order to respond to the
question.
What is the appropriate name and title of the responsible officer or employee?
DBPIUSPS-T8-43
Your response
to DBPIUSPS-T8-31
appears
to have failed to take into
account the sentence in the original interrogatory which starts, “Your response must be based on
the existing postal regulations.”
I am not looking for a general comparison between the delivery of
Express Mail or Special Delivery.
because of a lack of understanding
Nor am I looking for what is likely to take place in the system
of the regulations.
Nor am I looking for a comparison
total time from mailing to delivery which would include the overall transportation
of the
of the mail. What I
am looking for are three very specific comparisons based on the postal regulations for the delivery
of the mail. Please respond to the original interrogatory
005574
DBPIUSPS-T8-44
r-
[a] Does the last sentence in your response to interrogatory
DBPLISPS-T8-
33[a] indicate that there will be shipping and handling charges on PFSC included in the rates being
proposed in this proceeding?
[b] If not, what is the significance of the ss!ntence in your response?
[c] If so, provide the details of the other costs.
DBPIUSPS-TB-45
Please respond to the four parts of DBPNSPS-T8-35
if we restrict the USPS
employees or consultants to those that are responsible for the setting of r,ates.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon all participants
in this proceeding in accordance with Section 12 of the rules of practice.
David B. Popkin
September 30, 1996
5
of record