BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON DC 20268-0001
POSTAL RATE AND FEE CHANGES, 1997DOCKET NO. R97-1
MOTION TO COMPEL RESPONSES TO DBP/USPS INTERROGATORIES
October 27, 1997Respectfully submitted,
DAVID B. POPKIN, POST OFFICE BOX 528, ENGLEWOOD, NJ 07631-0528
1.The Postal Service was directed by the Commission to respond to my original sixty-eight interrogatories by September 29, 1997. On October 7, 1997, in paragraph 9 of my Motion to Compel Responses to Interrogatories Served on the United States Postal Service as well as to Permit a Single Response to All Answers ["Motion"], I pointed out a number of Interrogatories to which no response had been made, namely, DBP/USPS-6 subparts k, t, and u \\ DBP/USPS-7 subparts l and m \\ DBP/USPS-8 subparts e and j through p \\ DBP/USPS-13 subparts i through l \\ DBP/USPS-19 \\ DBP/USPS-21 subparts a through l, q, s through u, w, x, bb, dd through jj \\ DBP/USPS-29 subpart i6 \\ DBP/USPS-33 subparts d and e, \\ DBP/USPS-37 \\ DBP/USPS-52 subparts a, m through p \\ DBP/USPS-54 subparts a through aa, cc through jj, uu through ddd \\ DBP/USPS-58 \\ DBP/USPS-59 subparts h through l \\ DBP/USPS-62 subparts a through g, l through s \\ DBP/USPS-63 \\ DBP/USPS-67.
2.A number of these interrogatories were filed late by the Postal Service, however, a response still has not been filed, almost a month later, to the following interrogatories: DBP/USPS-6 subparts k, t, and u \\ DBP/USPS-7 subparts l and m \\ DBP/USPS-8 subparts e and j through p \\ DBP/USPS-19 \\ DBP/USPS-29 subpart i6 \\ DBP/USPS-33 subparts d and e, \\ DBP/USPS-52 subparts a, m through p \\ DBP/USPS-58 \\ DBP/USPS-59 subparts h through l \\ DBP/USPS-63 \\ DBP/USPS-67.
3.On October 7, 1997, I filed follow-up interrogatories DBP/USPS-69 through 85. These responses were due to be filed by October 21, 1997. The Postal Service has not responded to Interrogatories 69, 70, and 71. While the Postal Rate Commission website indicates a response to Interrogatory 82 as being filed, it was not in the package that I received with the other October 21, 1997 material and has not been received.
4.There are questions which were raised at the hearings for which written responses are outstanding.
5.Based on the above, I move to compel the Postal Service to expeditiously respond to the outstanding interrogatories. The Postal Service should be required to provide a responsive answer to all of my written interrogatories regardless of the oral responses that may have been given at the hearing [this does not preclude references to Volume 3 of the transcript].
CERTIFICATE OF SERVICE
I hereby certify that I have this date served the foregoing document upon all participants of record in this proceeding in accordance with section 12 of the rules of practice.
David B. PopkinOctober 27, 1997
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