BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
REcEIVEL'
Ocr I6 8 33 Iit! ‘96
SPECIAL SERVICES REFORM, 1996
Docket
NO. MC96-3
DOUGLAS F. CARLSON
MOTION IN SUPPORT OF MOTION OF DAVID B. POPKIN
TO MODIFY RULES OF PRACTICE
CONCERNING LIBRARY REFERENCES
October
With
motion
the modifications
of David
of Practice
to provide
other
references
that
participants
that
the
library
which
by the Postal
that
I am concerned
library
references
because
I live
in this
not
in this
are,
Washington
to review
library
apparently
is not willing
an interrogatory
three
Service's
most of
in response
to
case.
Nonetheless,
references.
to provide
1
I
Admittedly,
the
specific
inaccessible
and cannot
months,
use of library
affect
essentially,
in California
Rules
case.
nearly
have been filed
did
the
a copy of any library
interrogatories.
references
I support
Commission's
answering
in MC96-3 for
answer
interrogatories
files
below,
the
with
party
have been concerned
to
to modify
the party
As a participant
references
discussed
B. Popkin
to require
8, 1996
afford
issues
with
these
to
to fly
The Postal
me
to
Service
r
copies
of library
T8-16(d)
references
that
filing
if
not most,
of a library
instances,
reference
method
of answering
example,
a library
reference
a diskette
than
a library
reference
participants
who reside
metropolitan
area.
LR-SSR-137,
Materials
tories,
of transcripts
could
cost.
The other
in a size
be provided
items
that
to provide
that
or rebuttal
requests--be
required
3(d),
R90-1,
the
a party
evidence
filing
,,-
2
a few pages
These photo-
at a very
may be
be practical.
of Practice
a library
low
also
would
or in response
and
and DBP/USPS-
in LR-SSR-137
Rules
to provide
cited
6, and 7(b)
of only
duplication
Special
for
DC,
Service
and R94-1.
contained
which
soslely
discovery
to DBP/USPS-Tl-6
to a participant
and form for
I propose
by filing
or
to DBP/USPS Interroga-
of photocopies
from R87-1,
copies
however,
the Postal
DBP/USPS-Tl-l(j),
to consist
cases,
the Washington,
Responsive
The answers
DBP/USPS-T8-11.
textual
frustrate
For example,
to answer
appear
outside
document
a written,
interrogatory
may effectively
most
For
a large
In other
to a participant's
Service's
to have been the
containing
to an interrogatory.
responding
Postal
an interrogatory.
may be more practical
response
direct
See DBP/USPS-
the
appears
practical
fied
files.
and 18.
In many,
T8-11
it
be modi-
reference--as
to discovery
any participant
with
a copy
005693
of that
library
participant,
reference
provided
would
proposed
rule
Service
would
of the
all,
reference
upon specific
that
and reasonable.
to Mr. Popkin's
interrogatories,
items
to furnish
contained
that
copies.
To the
burden
of providing
other
participants
library
references,
parties
could
the
information
discovery,
thus
extent
that
through
parties
direct
eliminating
Applying
copies
Service
if
not
to participants
them with
are concerned
with
consider
or reducing
the
Postal
of most,
furnish
testimony
that
library
the
in LR-SSR-137
the Postal
from
a copy of the
be practical
be required
who requested
supplying
request
about
copies
instead
of
providing
or responses
the
need for
the
to
library
references.
Dated:
October
8. 1996
DOUGLAS F. CARLSON
3
.--
005694
CERTIFICATE OF SERVICE
I hereby
foregoing
certify
document
in accordance
section
with
3(B)(3)
that
I have this
upon the required
section
of the
day served
participants,
12 of the Rules
Special
Rules
the
of record
of Practice
and
of Practice.
Mea,DOUGLAS F. CARLSON
October 8, 1996
Emeryville,
California
--
4
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