ORIGINAL
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Mailing Online Service, 1998
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Docket No. MC98-1
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OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORY
TO MAIL ADVERTISING SERVICE ASSOCIATION/
PITNEY BOWES WITNESS: ROGER C. PRESCOTT (OCAIMASAIPB-Tl-1)
(February 12, 1999)
Pursuant to sections 25 and 26 of the Rules of Practice of the Postal Rate
Commission,
the Office of the Consumer Advocate
interrogatory
and request for production
If data requested
requested,
of documents
are not available in the exact format or level of detail
any data available in (1) a substantially
or (2) susceptible
hereby submits an
similar format or level of detail
to being converted to the requested
format and detail should
be provided
The production
photocopies
attached
of documents
to responses
requested
herein should be made by
to these interrogatories.
If production
copies is infeasible due to the volume of material or otherwise,
be made for inspection
N.W., Washington,
at the Office of the Consumer
D.C. 20268-0001,
The term “documents”
memoranda,
Advocate,
of
production should
1333 H Street,
during the hours of 8:00 a.m. to 4:30 p.m.
includes, but is not limited to: letters, telegrams,
reports, studies, newspaper
clippings, speeches,
testi
Docket No. MCg8-1
pamphlets,
2
charts, tabulations,
and workpapers.
includes other means by which information
printouts,
is recorded or transmitted,
microfilms, cards, discs, tapes and recordings
together with any written material necessary
microfilms,
The term “documents”
also
including
used in data processing
to understand
or use such printouts,
cards, discs, tapes or other recordings.
“All documents”
located, discovered
means each document,
or obtained
limitation all documents
as defined above, that can be
by reasonable
possessed
diligent efforts, including without
by: (a) you or your counsel; or (b) any other
person or entity from whom you can obtain such documents
you have a legal right to bring within your possession
“Communications”
conversations,
by request or which
by demand.
includes, but is not limited to, any and all
meetings, discussions
and any other occasion for verbal
exchange,
whether in person or by telephone,
including
but not limited to letters, memoranda,
as well as all documents,
telegrams,
cables, or electronic
mail.
“Relating to” means discussing,
analyzing,
studying, reporting, commenting
forth, considering,
part. Responses
recommending,
concerning,
by workpapers.
backup material whether prepared
without consideration
reflecting, containing,
on, evidencing,
constituting,
or the derivation
of numbers
The term ‘workpapers”
manually,
setting
or pertaining to, in whole or in
to requests for explanations
should be accompanied
necessary,
describing,
mechanically
or electronically,
to the type of paper used. Such workpapers
be prepared as part of the witness’s
shall include all
and
should, if
responses and should “show
Docket No. MC98-1
3
what the numbers were, what numbers were added to other numbers to achieve
a final result.”
The witness should “prepare sufficient workpapers
possible for a third party to understand
and developed
IO/279596.
how he took data from a primary source
that data to achieve his final results.”
Where the arithmetic manipulations
Docket No. R83-1, Tr.
were performed by an
electronic digital computer with internally stored instructions
language
intermediate
so that it is
printouts were prepared,
and no English
the arithmetic steps should be
replicated by manual or other means.
Please especially
requested
documents
provide an explanation
note that if you are unable to provide any of the
or information,
as to any of the interrogatories,
for each instance in which documents
cannot be or have not been provided.
Respectfully
SHELLEY
Attorney
submitted,
S. DREIFUSS
please
or information
Docket No. MC98-1
OCA/MASA/PB-Tl-1.
4
Please refer to your testimony at page 10, lines 5-13.
a.
Please define “mail preparation
b.
Please define the “competitive
C.
Please confirm that some of the 62 percent of business diverted from
“private competitive
services.”
market for mail preparation
firms to the USPS’ subcontractors”
services.”
could be diverted
from firms that prepare mail in-house as an adjunct to major business
activities, such as insurance
company policy statements.
If you do not
confirm, please explain.
d.
Please provide any studies, reports or other evidence showing the
proportion
of the $121 million of business during the experiment
diverted
from firms that prepare mail in-house.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
all participants
of record in this proceeding
in accordance
upon
with section 12 of the
rules of practice.
Shelley S. Dreifuss
Attorney
Washington, D.C. 20268-0001
February 12, 1999
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