VOTE FORWARD et al v. DEJOY et al

Filing 16

MOTION for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: #1 Memorandum in Support, #2 Exhibit Index, #3 Exhibit USPS OIG Report (Aug. 2020), #4 Exhibit USPS, Postal Operations Manual (Excerpts), #5 Exhibit USPS OIG Report (May 2020), #6 Exhibit USPS, Mandatory Stand-Up Talk: All Employees, #7 Exhibit Leaked USPS Powerpoint, #8 Exhibit DeJoy Testimony - House Oversight Hearing (Aug. 24, 2020), #9 Exhibit DeJoy Testimony - Senate Hearing (Aug. 21, 2020), #10 Exhibit Statement of DeJoy - House Oversight Comm. (Aug. 24, 2020), #11 Declaration Professor Justin Grimmer, #12 Exhibit USPS, Congressional Briefing (Aug. 31, 2020), #13 Exhibit Chart of States Where Voters' Mail-In Ballots Are Impacted By Defendants' Delays, #14 Exhibit USPS Letter to Pa. (July 29, 2020), #15 Declaration Eitran D. Hersh, #16 Exhibit House Oversight Hearing on USPS Operations - Transcript (Aug. 24, 2020), #17 Exhibit Senate HSGAC Hearing on USPS Operations - Transcript (Aug. 21, 2020), #18 Declaration Aaron Carrel, #19 Declaration Martha Thompson, #20 Declaration Kathryn Montgomery, #21 Declaration Sebastian Immonen, #22 Declaration Amy Bolan, #23 Declaration Inderbir Singh Datta, #24 Declaration Scott J. Forman of Vote Forward, #25 Declaration Alex Sanchez of Voces Unidas De Las Montanas, #26 Text of Proposed Order)(Duraiswamy, Shankar)

EXHIBIT 4

Mandelory Stand-Up- Tifts All Employees
July 10, 2020
Plvotliig For. Our Future
• The Postal Service has a tong history of service to the nation, and we take pride in our
ability to deliver mail and packages efficiently, timely, and safely.
• Right now, we are at a critical juncture in our organization and must make immediate,
lasting, and impactful changes in our operations and ii our culture.
• This operational pivot is long overdue and today, we are talking about the first step in a
journey we must take together, for the health and stability of the Postal Service.
• Every single employee will receive this information, no matter what job they perform, so
remember that YOU are an integral part of the success we will have - again, by working
together.
• The initial step in our pivot is targeted on transportation and the soaring costs we incur,
due to late trips and extra trips, which costs the organization somewhere around $200
million in added expenses.
• The shifts are simple, but they will be challenging, as we seek to change our culture and
move away from past practices previously used.
• Specific examples of transportation changes being implemented immediately (today):
V
V

All operations must meet our 24-hour clock commitment
All trips will depart on time (Network, Plant and Delivery); late trips are no longer
authorized or accepted
V Extra trips are no longer authorized or accepted
V There must be proper annotation in the scanner, if a Contractor Failure occurs
V All PVS/HCR drivers must be notified that trips depart on time.
V Function 4 must start on time and end on time and we must make scheduled DUT
V Carriers must begin on time, leave for the street on time, and return on time
V Carriers must make the final dispatch of value; no additional transportation will be
authorized to dispatch mail to the Plant after the intended dispatch
V The right mail must go on the rig1t truck - every time
V ALL EMPLOYEES have an essential role with trips departing on time.

• One aspect of these changes that may be difficult for employees is that. temporarily we may see mail left behind or mail on the workroom foor or docks (in P&DCs), which is
not typical.
• We will address root causes of these delays and adjust the very next day.
• Any mail left behind must be properly reported, and employees should ensure this action
is taken with integrity and accuracy.

•

As we adjust to the ongoingpivot, which will have a number of phases, we know that
operations will begin to run more efficiently and that delayed mail volumes will soon
shrink significantly.

•

More information will be shared as we fully and swiftly implement these strategies.

•

You playa direct role in the success of the Postal Sei vice, and your cooperation and
teamwork are appreciated.

•

This is a critical time for us, when decisive, quick, and meaningful action is needed.

•

This operational pivot will ensure we can secure our future as a world-class service
provider, improving our performance to fulfill our core mission of service to our
customers.

. Thank you for your support and your teamwork.