RECElVEll
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
Au212
Ii 37 PM ‘96
POSTALRATFCD~HISSIOW
OFFlCEOiTHE
SECRETARY
Special
Services
Fees
Docket
and Classifications)
No.
MC96-3
ClFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS W. ASHLEY LYONS
(OCA/USPS-Tl-34-35)
(August
12, 1996)
Pursuant
the
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
Commission,
25 and 26 of
the
interrogatories
Instructions
States
Postal
Office
the
of
Rules
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
Advocate
production
OCA Interrogatories
June
19,
1996,
GAIL WILLETTE
Director
Office
of the
are
/4DAVID RUDE=
Attorney
submitted,
Consumer
of
l-4
by reference.
Respectfully
of
Advocate
hereby
to
Docket
No.
MC96-3
2
OCA/USPS-Tl-34.
F'lease
refer
to
your
answer
to
interrogatory
charge
[the
OCA/USPS-Tl-19.
a.
YOU state
postal
"[tlhe
that
card
rate1
identified
that
the
manufacturing
postal
Please
that
the
Please
d.
"Customers
who buy
already
disagree
with
Please
Please
the
explain
means
explain
advantage
the
as you
as used
the
as you
contained
in
the
the
Please
card,
i.e.,
costs
assigned
rate
answer
to
OCA/USPS-TS-10.
use
in
your
it
paid
the
by the
'postal
DMM E110.3.1
at
a post
Please
phrase
use
it
in
establishing
of
the
attributable
explain
"clarify
your
fee
the
testimony
for
a sounder
costs
of
costs.
office
Do you
on it."
how a separate
when all
not
postage."
in
statement.
what
products"
to
name,
has postage
of
of
is
attributable
covered
postcards
this
card
20 cent
by postal
response:
card',
implies
a postcard."
"card"
postcard
choice"
f.
define
relate
product
is
the
amount
Patelunas'
current
product
C.
e.
and are
"postcard"
the
the
in
that
to
which
-
witness
define
"Moreover
from
costs,
S&e,
of
relates
costs
cards
cards.
b.
which
separately
confirm
to
portion
the
postal
cost
product
- E110.3.3.
kncsw that
agree
your
the
or
answer.
customer's
and response.
cards
"also
basis
for
are
has
these
currently
Docket
23.
No.
MC96-3
Please
refer
believe
that
cards
for
if
say,
any
h.
to
section
Postal
20 cents
asked,
that
affirmative
Please
Will
for
3
that
customer's
22 cents
choice
Service
and your
customers
and now have
the
answer
rate
to
had
thereto.
Do you
who have
bought
22 cents
would
pay
increased?
Please
postal
nat.
explain
answer.
assume
the
(d)
or
was to
not
buy
the
stamped
card
fee
choice
be either
to
to
a card
buy
a postal
card
whereas
for
proposal
buy
is
adopted.
a stamped
the
20 cents?
card
previous
Please
explain.
OCA/USPS-Tl-35.
Please
will
explain
decline.
Please
refer
why expenses
to
for
your
certified
testimony
mail
at
page
and return
8.
receipt
Docket
No.
MC96-3
CERTIFICATE
I hereby
document
upon
accordance
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
in
served
this
special
DAVID RUDERMAN
Attorney
Washington,
August
12,
DC
1996
20268-0001
the
foregoing
proceseding
rules
of
i-n
practice.