005187
POSTAL RATE CONNISSION
WASHINGTON, DC 20268-0001
RECEIVELI
Ocr 30
SPECIAL SERVICES REFORN, 1996
Dock&
8 54 Ai ‘96
NO. MC96-3
DOUGLAS F. CARLSON
MOTION TO BE EXCUSED
FRON ORAL CROSS-EEANINATION
ON NY DIRECT TESTIMONY
October
I,
Douglas
Commission
on my testimony
On September
Service's
My testimony
and the
reasons
letters
25,
1996,
proposed
explains
nonresident
request
me from appearing
cross-examination
Postal
1996
hereby
F. Carlson,
excuse
25,
in the
In
my reasons
Commission's
Holstein
and Congressman
proposed
nonresident
On October
interrogatories
testimony
nonresident
for
using
my
J. Horwitz
testimony
Commenter File
Mike Doyle,
both
4, 1996,
the Postal
Service
directed
to
On October
of interrogatories
responses
filed
(USPS/DFC-1-9).
me
17.
mailing
has a
Stephen
the
fee.
on October
am
also
box
of whom oppose
responses
I
fee.
from Mr.
14, and the Commission
‘5).
the
summarizes
on October
a set
concerning
a nonresident
responses
served
oral
post-office-box
Valerie
addition,
for
..
in MC96-3.
I filed
why my friend
box.
in person
to Mr. Popkin's
1
to
of
I served
rece.ived
21, David
directed
a set
me
the
B. Popkin
(DBP/DFC-l-
interrogatories
my
’ ii
y-
on October
26.
complete,
My answers
detailed,
cross-examination
that
the
Monday,
lower
November
this
for
personal
mid-week
funds
for
in my office
Immediately
I mailed
again
on
fly
on
to Washington
case.
after
Moreover,
to
I am using
my own,
to my
I cannot
the work load
take
will
more
be int'ense
for
th'e Postal
21 to discuss
whether
the
Po:stal
future
yet
to decide
request
to be excused
from oral
2
--
three
me that
it
the
would
to me
a 'copy of my
When Mr. Rubin
whether
I-.
~
Mr. Rubin
interrogatories,
Commission.
Service
cross-examination
22, I faxed
24, he informed
was not
scheduling
counsel
to submit
them to the
this
Mr. Rubin,
to Mr. Popkin's
able
since
I discovered
On October
on October
from California
at
mid-November.
be satisfied
responses
cross-examination
related
work because
on October
in writing.
to request
at work has been
activities
I telephoned
Service,
meeting
of flying
all
during
conflict,
are
on Monday evening.
is prohibitive,
in this
one day off
would
to California
The cost
participation
than
fares
oral
November 18, and I must make a presentation
meeting.
Washington
air
for
I was planning
I could
an important
scheduled
Since
me for
18 so that
and return
Unfortunately,
to Washington
on the weekend,
schedule
are
to the questions.
to travel
in November.
Commission
Saturday
interrogatories
and responsive
I had been planning
considerably
to all
days before
and I spoke
Postal
support
cross-examination.
Ser-vice
my
The OCA
,-
and Mr.
Popkin
submit
have already
future
contacted
questions
other
participants
since
to date,
expressed
I do not know whether
ask me questions
that
4(A)
written
cross-examination
for
also
the
excuse
suggest
my distance
at work,
that
and the
cross-examination
If
directed
to me, assuming
that
responds
to this
filing
November 15 would
to me.
L.
--
the
nature
expense
by my
on
answers
decides
to
support
an
interrogatories
one other
party
an extension.
be a fair
deadline
of
Commission
responsive
I would
at least
and requests
the
imposed
the Commission
for
directed
that
the
be
on my testimony,
to provide
deadline
motion
to all
cross-
and given
constraints
of the
interrogatories
future
request
I continue
possible.
so far
from Washington,
interrogatories.
that.
whenever
reason,
cross-examination,
believe
to
indicates
and sufficiently
me from oral
extension
plans
be used as a
that
I respectfully
me from oral
to written
wit.h my
of Practice
I have provided
For this
in writing.
condition
should
that
to Washington,
schedule
other
Commissionl
Rules
can satisfactorily
of my testimony,
excuse
Special
strongly
travelling
concern
cross-examination
answers
interrogatories
performed
of the
oral
The responsive
examination
I have not
none of the
the
to
from the bench.
Section
substitute
a willingness
to me in writing.
participants,
has,
testimony.
indicated
I
for
filing
005190
If
,-
the
Commission
cross-examination,
I would
that
the
oral
cross-examination
November
Eastern
decides
Commission
19,, 20,
consider
not
like
to excuse
to ask,
the
in the
feasibility
by telephone
allternative,
of conducting
speakerphone
21, or 22, preferably
oral
hookup
commencing
on
at 9:30
time.
Lastly,,
acceptable,
November
if
neither
I misht
of the preceding
be able
to attend
options,
a hearing
is
on Monday,
2iT "
Respectfully
Dated:
me from
October
25,
1996
submitted,
DOUGLAS F. CARLSON
4
AM
0 0 5 I79 f
CERTIFICATE
I hereby
foregoing
certify
document
in accordance
with
that
OF SERVICE
I have this
upon the required
section
day served
participants
12 of the Rules
the
of record
of Practice.
fQ+Y+=4~LDOUGLAS F. CARLSON
October 25, 1996
Emeryville,
California
5