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)

Download PDF
EXHIBIT 5 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … JOIN US OUR NETWORK GET INVOLVED DONATE  FIND HELP CASE STUDIES NEWS CONTACT US Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control Alliance Report July 14, 2020  SHARE FACEBOOK Alliance Supports Emphasis on Efficiency while Attaining Service TWITTER LINKDIN We have long expressed our concerns with lack of cost control and declining productivity at USPS, in filings at the PRC, Alliance Reports, and elsewhere.  Recently, we received the following email from a postal employee who was reacting to one of our articles.  We are leaving out her or his name to protect him or her from any repercussions. I’ve been a City Letter Carrier for 28 years. In a recent article, you mentioned how labor costs are up, while hours were down. I might have a partial explanation. I was asked the other day if I could help a CCA who was unfamiliar with a route. He would have gone into about 20 minutes of double time if I didn’t help. USPS frowns upon double time. My salary is about twice his. I would have had to find the person, sort and organize the mail, go to the part of the route to be delivered, deliver it, and drive back to the office. It would have taken me about an hour to do this. So, instead of paying that CCA about 20 minutes of double time, (about the same as my base https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 1/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … salary), I would have been paid an hour of overtime. My supervisor understood this also, but shook his head and said, the priority is cutting double time, not costs.   We’re pretty sure that this is but one example of many ways in which USPS hurts itself with irrational, wasteful practices at the front lines.  Yet, in recent years, USPS management seems to have put cost control on the back burner as it has sought financial assistance from Congress and the PRC.   Postmaster General Louis DeJoy has kept a low profile with customers and the media in his first month on the job.  Reportedly, he is working hard to scope out the organization and develop his priorities.  An aggressive focus on cost reduction may have leaked out in the form of an obscure PowerPoint presentation from within USPS operations in Ohio. Alliance supports efficiency and service together If it is true, the Alliance wholeheartedly supports an emphasis on cost control and efficiency while attaining service standards.  We do not believe the brief mention of leaving mail behind reflects a directive from PMG DeJoy.  As a seasoned business leader, he knows that to succeed, a service provider must deliver both service and efficiency simultaneously.    The many acronyms aside, these slides represent major changes in how the USPS operates.  And many will say that service will go into the tank as a result.  A firmly-held element of USPS culture is that you either emphasize budget or service, but you never succeed at both.  Everyone in the private sector knows, however, that you really have to be both efficient and provide or exceed the level of service your customers expect in order to survive.   The Postal Service has not confirmed or denied that these slides accurately portray national policy.  USPS spokesperson Dave Partenheimer provided EcommerceBytes with the following statement on Monday:   “The Postal Service is developing a business plan to ensure that we will be financially stable and able to continue to provide reliable, affordable, safe and secure delivery of mail, packages and other communications to all Americans as a vital part of the nation’s critical https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 2/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … infrastructure. While the overall plan is not yet finalized, it will certainly include new and creative ways for us to fulfill our mission, and we will focus immediately on efficiency and items that we can control, including adherence to the effective operating plans that we have developed.”   POT = penalty overtime CSDRS = customer service delivery reporting system SDO = scheduled day off DUO = delivery unit optimization DUT = delivery up time DM = district manager AVP = area vice president 204 = temporary supervisor on loan from the craft OIC = officer in charge EAS = executive and administrative schedule https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 3/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 4/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 5/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 6/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/ 7/8 9/8/2020 Leaked USPS PowerPoint indicates PMG DeJoy focus on getting operating costs under control - Alliance of Nonprofit Mailers : Alliance of … OUR NETWORK JOIN US GET INVOLVED FIND HELP CASE STUDIES NEWS CONTACT US 1211 Connecticut Avenue, NW, Suite 610, Washington DC 20036-2705 • 202.462.5132 © Copyright 2015 Alliance of Nonprofit Mailers • Disclaimer https://www.nonprofitmailers.org/leaked-usps-powerpoint-indicates-pmg-dejoy-focus-on-getting-operating-costs-under-control/   8/8

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?