BEFORE THE
POSTAL RATE COMMISSION
RE:CEIVE[,
WASHINGTON, DC 2926S-6661 kov , 3 25p~ ,96
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pDSidi RAT;
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oFF'cF OF i'tl1: SECiiEThRi
Docket
SPECIAL SERVICES REFORW, 1996
No. MC96-3
DOUGLAS F. CARLSON
WOTION TO REQUIRE UNITED STATES POSTAL SERVICE
TO WARE AVAILABLE A WITNESB FOR ORAL CROSS-EXAMINATIO:N
CONCERNING STATUS REPORT ON IMPLEMENTATION
OF PROPOSEDNEW POST-OFFICE-BOX FEE SCHEDULE
October
On October
23,
Report
of United
Special
Services
reveals
some of the Postal
for
proposed
the
status
willing
Postal
the
status
they
believe
questions
written
alter
that
previous
1
,r-.
l(c)
the
plans
plans
In filing
that
the
substance
it : ..--1d1
-.
,,+#g:ir:~
?i;;:':,?.~:
of some of the proposals.
in obtaining
See, w,
responses
and DFC/USPS-T7-5
answers
rather
because
I experienced
responsive
answers
interrogatories
In addition,
obtain
cross-examination,
interrogatories,
given
late
date
to these
than
some
to several
concerning
the
I
post-office-box
in the
to the following
interrogatories:
(where witness
Needham's
reason
for
p,rocedural
DFC/USPS-,T3being
unable
1
--
.-
raise
I can most effectively
written
report
implementation
indicated
of
available
by way of oral
difficulty
status
fees.
Service
Status
on Implementation
'This
Service's
filefd
report.
The implementation
since
Service
Service
new post-office-box
to make a witness
about
fees.i
Postal
Reform Proposals.
the
report,
1996
the Postal
1996,
States
29,
-
,
I--
calendar
at which
concerning
the Postal
implementation,
interrogatories--and
cause
into
on the
for
plans.
The Commission
witness
be prepared
oral
of earlier
witnesses,
details
that
possible
not
given
From Oral
the
direct
that
questions
,*-
to
specific
implementation
on October
Commission
1996,
on Monday,
announce
participants
implementation
the
October
29,
Postal
with
Service
to the
the
testimony
questions
financial
I described
25,
a
about
the
plans.
the personal
Cross-Examination
schedule
pertaining
plans
just
that
be scheduled
so that
on the
and
in my Motion
on My Direct
I further
a hearing
date
can make travel
to Be
Testimo'ny,
request
November 25,
Respectfully
Dated:
follow-up
case-in-chief
the Commission
implementation
constraints
I served
that
should
of the
In addition,
the hearing
Service's
to answer
of the
Excused
need for
cross-examination--could
cross-examination
interaction
which
Postal
I request
hearing
logistical
oral
details
December.
Therefore,
technical
has produced
the potential
eventual
discovery
continue
Service
1996,
that
and
as soon as
plans.
submitted,
w--
1996
DOUGLAS F. CARLSON
to answer the question
relies
on facts that are irrelvant
to the
question).
See also Response
to DFC/USPS-T7-7,
where the response
merely
begs the follow-up questions--namely,
"Why did neither
$1 or
fee?"
seem sufficient?",
and "Why is $3 a reasonable
2
---
$2
CERTIFICATE OF SERVICE
,-.
I hereby
foregoing
in
certify
document
accordance
with
that
upon
section
the
I
have
this
required
12 of
the
day
served
participants
Rules
of
the
of
record
Practice.
-49%
DOUGLAS F.
October
29,
Emeryville,
,/-
1996
California
CARLSON