Free Cross Motion [Dispositive] - District Court of Federal Claims - federal


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Scott Stamp Monthly Linns Stamp News SCOTT CATALOGUES SCOTT ALBUM PAGES MOUNTS BOOKS SCOTT SUPPLEMENTS BINDERS HINGELESS PAGES MINKUS PRODUCTS ACCESSORIES Coin World Coin Values Paper Money Values SCOTT CATALOGUE VOLUME 1 - 2008 (US & COUNTRIES A-B) World Wide Coins Item: C081 Retail Price: $65.99 AA Price: $55.99 More than 16,000 value changes were recorded in Volume 1. Leading the way are the U.S. listings with Stock Status: Available 4,136 new values. Much of the activity is concentrated in the classic issues. Significant activity was also recorded in Antigua, Australia and the Australian States, Bahamas and the Belgian Congo.

SCOTT VOLUME 1 - 2008 CATALOGUE & CD SET
Item: C081CDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

Get the 2008 edition of the Scott Catalogue Vol. 1 in both print and CD versions in this set. Only unopened packages are returnable

SCOTT VOLUME 1 - 2008 CATALOGUE/SPRING VALUE SUPPLEMENT SET
Item: C081VALSET Includes the print versions of the 2008 Scott Catalogue Retail Price: $69.99 Volume 1 and the expanded valuing information for AA Price: $59.99 U.S. stamps in the U.S. Specialized Spring Valuing Stock Status: Available Supplement. Click here for more information on Volume 1 and the Spring Valuing Supplement.

2008 US SPECIALIZED VALUING SUPPLEMENT - SPRING EDITION

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Stamp Collecting Supplies Stamp albums, tongs, mounts, pages, easy order site, Potomac Supplies..
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Item: C081VS Expanded valuing information for U.S. stamps can be Retail Price: $16.99 found in the Spring U.S. Specialized Valuing AA Price: $13.99 Supplement. The expanded grades that are valued in Stock Status: Available the 2008 supplement include the following categories; Superb, Extremely Fine-Superb, Extremely Fine, VeryFine-Extremely Fine, Very Fine, Fine-Very Fine, Fine and Very Good. Definitions and illustrations are provided for the eight stamp grades. Numbered grading has been added to the verbal descriptions.

SCOTT CATALOGUE VOLUME 2 - 2008 (COUNTRIES C-F)

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Item: C082 Retail Price: $65.99 Early issues continue to push values higher in Volume AA Price: $55.99 2 where more than 13,000 value changes were recorded. More than 600 value changes were made in Stock Status: Available Canada. In the Peoples Republic of China increases tend to be concentrated in the early issues and the "Liberation Area" posts. More than 2,700 value changes were made in Ecuador. Many changes, mostly upward, were also made in Cuba and France.

Scott Stamp Cd The Easy Way to Catalog Your Stamps ScottTMLicensed. Free 30 Day Trial.
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SCOTT VOLUME 2 - 2008 CATALOGUE & CD SET
Item: C082CDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

Get the 2008 edition of the Scott Catalogue Vol. 2 in both print and CD versions in this set. Only unopened packages are returnable.

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SCOTT CATALOGUE VOLUME 3 - 2008 (COUNTRIES G-I)
More than 8,500 value changes were recorded in Volume 3, which covers countries of the world G-I. In Great Britain, a number of unused classic stamps rise in value. Increases are scattered throughout the Greece listings, where more than 600 changes were recorded. Almost every value has been increased in Italian Colonies, with the increases being significant. Additions to this year's catalogue are the 410 major and 45 minor catalogue numbers for the Indonesia Revolutionary issues of 1945-49. Item: C083 Retail Price: $65.99 AA Price: $55.99 Stock Status: Available

SCOTT VOLUME 3 - 2008 CATALOGUE & CD SET
Get the 2008 edition of the Scott Catalogue Vol. 3 in both print and CD versions in this set. Only unopened packages are returnable. Item: C083CDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

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SCOTT CATALOGUE VOLUME 4 - 2008 (COUNTRIES J-O)
Item: C084 Retail Price: $65.99 More than 12,000 value changes, many of them AA Price: $55.99 increases were driven by a competitive stamp market. In Jordan alone, more than 2,300 changes were made. Stock Status: Available Other countries with a large number of changes include North Korea, Libya, Lithuania and Madagascar. As part of an on going effort to bring listings for North Korea up-to-date, 675 new major numbers from 1995-2000 were added.

SCOTT VOLUME 4 - 2008 CATALOGUE & CD SET
Item: C084CDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

Get the 2008 edition of the Scott Catalogue Vol. 4 in both print and CD versions in this set. Only unopened packages are returnable.

SCOTT CATALOGUE VOLUME 5 - 2008 (COUNTRIES P-SI)
More than 5,000 value changes in Russia, plus almost Item: C085 2,400 in Peru. All totaled more than 14,000 value Retail Price: $65.99 changes were recorded in the 2008 edition of Volume 5 AA Price: $55.99 of the Scott Standard Postage Stamp Catalogue. As in Stock Status: Available the previous volumes, all of these changes are overwhelmingly increases. In Russia the massive number of changes cover the entire spectrum of time periods. In the classic era, the 10k brown and blue, Scott 2, leaps to $4,250 unused from $1,750 last year. The 1948 30k-1r Young Pioneers set, Scott 1284-1288, jumps to $100 unused and $29 used, from $56.50 and 19.25 respectively. Other countries with significant numbers of value changes include Palau, Philippines, Saar and Senegal.

SCOTT VOLUME 5 - 2008 CATALOGUE & CD SET
Get the 2008 edition of the Scott Catalogue Vol. 5 in both print and CD versions in this set. Only unopened packages are returnable. Item: C085CDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

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SCOTT CATALOGUE VOLUME 6 - 2008 (COUNTRIES SO-Z)
Item: C086 There are more than 25,500 value changes in this Retail Price: $65.99 year's Volume 6, which includes Countries of the world AA Price: $55.99 So-Z. The countries with the most activity are Turkey, Tunisia, Uruguay, Venezuela, Sweden, Tonga, Spain Stock Status: Available and Syria. There are more value changes than have typically been made to this volume in recent years. Value changes in Turkey span all periods. Most value changes in Sweden tend to be in later issues rather than in the classics, and the sizes of the changes are not as large as those seen in Turkey and Tunisa.

SCOTT VOLUME 6 - 2008 CATALOGUE & CD SET
Item: C086CDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

SCOTT CATALOGUE CLASSIC - 2008 (WORLD 1840-1940)
More than 1,000 new numbered and valued items Item: C08C appear for the first time in the 2008 edition of the Retail Price: $129.99 Scott Classic Specialized Catalogue of Stamps and AA Price: $104.99 Covers. Value changes, nearly all increases, appear Stock Status: Available throughout the catalogue, but they are especially numerous in Belgian Congo; Ecuador; French, German and Italian colonies; Italian states and Italy proper; Jordan; Lithuania; Natal; Peru; Russia; Turkey; Uruguay and Venezuela. There are frequent and dramatic gains across the board in the Italian area. All totaled, more than 12,000 additional value changes have been made for items listed only in the Classic.

SCOTT CLASSIC SPECIALIZED - 2008 CATALOGUE & CD SET
Get the 2008 edition of the Scott Classic Specialized Catalogue in both print and CD versions in this set. Only unopened packages are returnable. Item: C08CCDSET Retail Price: $239.99 AA Price: $189.99 Stock Status: Available

SCOTT CATALOGUE US SPECIALIZED - 2008
Item: C08S There are several significant editorial enhancements to Retail Price: $65.99 this year's edition. There are four new major numbers for the 3¢ stamps of 1851-57. The new numbers are AA Price: $55.99 10A, 11A, 25A and 26A. The first three new numbers Stock Status: Available recognize what specialist collectors have long known, that there are two main types of stamp designs for these issues: those with recut outer frame lines but no inner lines and those with recut outer frame lines and

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recut inner lines at the sides. New number 26A raises to major number status the previous minor number 26a. Other improvements include a new and expanded section on military postmarks, and new information on stamp designers for the Bureau of Engraving and Printing produced stamps. The Special Handling stamps have been reordered and revalued to more accurately reflect scarcity and chronology. And a new section of St. Louis Provisional proprietary revenue stamps has been added. Along with all those changes there are more than 12,000 value changes, with more than 3,000 of those changes being in the Postage section. The overriding valuing trend is the tremendous gains for Postage rarities.

SCOTT US SPECIALIZED - 2008 CATALOGUE & CD SET
Get the 2008 edition of the Scott U.S. Specialized Catalogue in both print and CD versions in this set. Only unopened packages are returnable. Item: C08SCDSET Retail Price: $99.99 AA Price: $89.99 Stock Status: Available

SCOTT US SPECIALIZED - 2008 CATALOGUE/FALL VALUE SUPPLEMENT SET
Item: C08SVALSET Retail Price: $69.99 Includes the print versions of the 2008 U.S. Specialized AA Price: $59.99 and the expanded valuing information for U.S. stamps Stock Status: Temporarily Out of Stock Unavailable in the U.S. Specialized Fall Valuing Supplement.

2008 SCOTT US SPECIALIZED VALUING SUPPLEMENT - FALL EDITION
Expanded valuing information for U.S. stamps can be found in the Fall U.S. Specialized Valuing Supplement. The expanded grades that are valued in the 2008 supplement include the following categories; Superb, Extremely Fine-Superb, Extremely Fine, Very-FineExtremely Fine, Very Fine, Fine-Very Fine, Fine and Very Good. Definitions and illustrations are provided for the eight stamp grades. Numbered grading has been added to the verbal descriptions. Item: C08SVS Retail Price: $16.99 AA Price: $13.99 Stock Status: Available

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Catalogues
Shop » catalogues The first Stanley Gibbons catalogue was published in November 1865. During the last hundred and more years it has become more than just a dealer's price list. In the hands of the world's leading stamp dealers and philatelic publishers the catalogue has blossomed into a veritable encyclopaedia of stamps, an authoritative guide to market values and an indispensable work of reference. Our catalogues are virtually the history of philately.

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Collect British Stamps 2008 Edition

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Published November 2007. This unique colour checklist is asimple guide to all British stamps from 1840 up to the date ofpublication.Designed to provide collectors with an easily understoodpricing system. An inexpensive, essential guide forbeginners and advanced collectors alike.Thescope also includes First Day Covers, Presentation Packs, Year Packs and Year Books and, a priced listing is included for Philatelic Numismatic And Philatelicmedallic Covers produced by Royal Mail In association With The Royal Mint. Prices have been reviewed since the last edition with a number of significant increases to both early issues and to recent commemoratives, as a demand for GB stamps shows no signs of slackening. Price: £9.95 Currency Converter Product Code: R0289-08 Categories: COUNTRY - Great Britain , YEAR - 2008 , DETAIL - Checklist , BRAND - Stanley Gibbons , TYPE - Great Britain

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British Railway Modelling Annual 2008 British Railway Modelling Annual: 2008 - Edited by John Emerson. Published: Nov 2007 Format: Paperback Pages: 180 Price: £5.95 Currency Converter Product Code: R2713 Categories: BRAND - Collectors Gazette , YEAR - 2008 , TYPE - Model Railways

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Collect British Postal Stationery

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This New Listing Of British Postal Stationery Covers Allissues From 1840 To The Present Day, Including Post Office,Official & Private Items. It Is Illustrated In Colourthroughout With The Lists Clearly Set Out In A Logicalformat So That Collectors Can Easily Identify Their Items.The 14 Page Introduction Gives A Definition, And A Briefhistory Of The Development Of Postal Stationery, Withdetails Of How The Listing Has Been Constructed. In Mostcases Prices Are Given Against Items For Mint & Usedcondition, Unless There Are Too Few Items On The Market Forrealistic Prices To Be Given.
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Price: £30.00 Currency Converter Product Code: R2731 Categories: YEAR - 2007 , TYPE - British Postal Stationery , BRAND - GBPS

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Coin Yearbook 2008 The Coin Yearbook Is One Of The Best Value Price Guides Tobritish Coins On The Market Today And Is Used Byprofessional Numismatists, Serious Collectors And The "Manon The Street" Alike.Illustrated In Full Colour With Price Guides Going Back Tocoins Of Roman And Celtic Britain As Well As Covering Thecoinage Of Scotland, Ireland And The Channel Islands Therevery Few Books As Detailed Or As Comprehensive Availabletoday - And It'S Under £10.
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Price: £9.95 Currency Converter Product Code: R2743-08 Categories: TYPE - World , YEAR - 2008 , BRAND - Other

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Unitrade Canada Catalogue 2008 The Unitrade Specialised Catalogue of Canadian Stamps including British Colombia and Vancouver Island, New Brunswick, Newfoundland, Nova Scotia and Prince Edward Island. Price: £24.00 Currency Converter Product Code: R2768-08 Categories: COUNTRY - Canada , DETAIL - Specialised , BRAND - Other , YEAR - 2008
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Medal Yearbook 2008 12th Edition The Medal Yearbook 2008 Has Been Completely Updated In Linewith Market Movements. In Colour And Will Include Dozens Of New Medals & Major Foreign Medals Found In British Groups. Price: £19.95 Currency Converter Product Code: R2790-08 Categories: BRAND - Other , YEAR - 2008
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Commonwealth & British Empire Cat 2008 In response to demand from collectors around the World, Stanley Gibbons have extended the period covered by the British Commonwealth catalogue to include the issues up to 1970. Extending the country listings from 1952 to 1970 to take in the issues up to 1970. Extending the country listings from 1952 to 1970 to take in the most popular and

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interesting stamps of the present reign and, as prices for many of the items added had not been reviewed since 2001, there is sure to be a lot of interest in new information which this catalogue contains. Elsewhere, we have increased the proportion of colour illustrations and a number of new items have been added to the catalogue. Price: £69.95 Currency Converter Product Code: R2813-08 Categories: YEAR - 2008 , TYPE - Commonwealth , BRAND - Stanley Gibbons , DETAIL - Comprehensive
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Part 7 Germany 8th Edition In Colour ***PUBLISHED 21 DEC2007 *** 8Th Edition, Germany continues to be one of the most popular stamp collecting areas and this new edition has allowed us to carefully review all the prices and take into consideration current market trends. There have consequently been thousands of price changes running throughout the catalogue. For the first time we have included the stamps issued during the German occupation of the Channel Islands, as well as making numerous revisions throughout. The new issue listing includes stamps issued as recently as Sept 2007 and the Germany design index has been updated to reflect all the later issues.
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Price: £29.95 Currency Converter Product Code: R2836-08 Categories: YEAR - 2008 , DETAIL - Comprehensive , BRAND - Stanley Gibbons , TYPE - Foreign , COUNTRY Germany

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Australia One Country Catalogue 2008 Published 30 November 2007. This Australia volume includes the Colonial Issues Of New South Wales, Queensland, South Australia, Tasmania, Victoria And Western Australia, The Stamps Of The Commonwealth Of Australia To Octoberoccupation Force (Japan), Australian Antarctic Territory,Christmas Island, Cocos (Keeling) Islands,Norfolk Island and the Pre-independence Issues For Nauru (To 1968), New Guinea, Papua And Papua New Gui nea (To1975). Prices for issues up to 1970 have been taken from the new 2008 Commonwealth & Empire stamp catalogue. Later issues have been specially repriced for this volume.
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Price: £19.95 Currency Converter Product Code: R2871-08 Categories: BRAND - Stanley Gibbons , TYPE - Commonwealth , DETAIL - Comprehensive , YEAR - 2008 , COUNTRY - Australia

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St Helena & Dependencies Colour Cat Published December 2007.3rd Edition. This Series Of Col our Catalogues Lists And Prices The Stamps Of Commonwealth Countries From SG1 To Date, To The Level Of Detail Familiar To Users Of The "Part 1" British Commonwealth Listings.Thest Helena & Depencies Catalogue Covers The Stamps Of Ascension And Tristan Da Cunha, Aswell As St Helena Itself, And Includes Booklets And Postage Dues For All Three Territories, Listings Of Great Britain Stamps Used In Ascension And The Popular Tristan Da Cunha 'Cachets'. Listings Of New Issues Are Complete To Late 2007.
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Price: £9.95 Currency Converter Product Code: R2875-08 Categories: DETAIL - Comprehensive , COUNTRY - St Helena , TYPE - Commonwealth , YEAR - 2008 , BRAND Stanley Gibbons

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Hong Kong Country Catalogue 2008

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Published 14 December 2007. Lists and Prices the Stamps Of The Commonwealth Countries From SG1 To Date, To The Level Of Detail Familiar To Users Of The 'Part 1' British Commonwealth Listings. For The Convenience Of Collectors Of Hong Kong, This Catalogue Also Includes The Stamps Of The Special Administrative Region Of The People'S Republic Of China, Issued From 1 July 1997.Also Listed Are Postage Dues, Postcard Stamps, Postal Fiscals, Stamp Booklets, Japanese Occupationstamps And Hong Kong Stampsused In The British Post Offices In China And Japan.Illustraand Illustrated Predominantly In Full Colour.
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Price: £9.95 Currency Converter Product Code: R2877-08 Categories: DETAIL - Comprehensive , COUNTRY - Hong Kong , YEAR - 2008 , BRAND - Stanley Gibbons , TYPE Commonwealth

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Collecting British Fdc`s 2008 Edition Complete From 1840 Penny Black To 2007. Over 6,000 Postmarkillustrations. Hundreds Of First Day Covers Illustrated. Printed On Quality Gloss Art Paper. Fantastic Price Guide For British Fdc Collectors. All Official/Sponsored Covers Are Listed. All Relevant Cds And Slogan Postmarks Listed. Easy To Follow Definitive Section. Full Of Helpful Tips On Collecting Fdcs. All 1999-2007 Official/Sponsored Covers Are Now Priced Individually.
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Price: £14.75 Currency Converter Product Code: R2880-08 Categories: YEAR - 2008 , BRAND - Other , TYPE - Great Britain

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Sotw Vol 1 Countries A-C 2008 Volume 1 Covering Countries A-C. Since It Was First Published In 1934, Stanley Gibbons Simplified Stamps Of The Worldcatalogue Has Become Accepted As A Standard Work Of Reference Around The World. With Its Easy-To-Use, Simplified Listings, Mint And Used Prices For Almost Every One Of Its 474,000 Plus Stamps, Colour Illustrations And Helpful Introductorynotes, This Is The Catalogue For Thethematic Or All-World Collector. The 2008 Edition Continuesthe Long Tradition Of Expansion And Improvement, Which Has Been The Key To The Catalogue'S Ongoing Success. The Coverhas Been Completed Re-Designed For This Edition. Allminiature Sheets Are Now Included Price: £44.95 Currency Converter Product Code: R2881-08 Categories: DETAIL - Simplified , TYPE - World , YEAR - 2008 , BRAND - Stanley Gibbons

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Stamps Of The World Set 2008 (5 Volumes) **Free £50 Stamp Voucher** Complete Set, Volumes 1-5, Covering Countries A-Z. Since It Was First Published In 1934, Stanley Gibbons Simplified Stamps Of The World Catalogue Has Become Accepted As A Standard Work Of Reference Around The World. With Its Easy-To-Use, Simplified Listings, Mint And Used Prices For Almost Every One Of Its 474,000 Plus Stamps, Colour Illustrations And Helpful Introductory Notes, This Isthe Catalogue For The Thematic Or All-World Collector. The 2008 Edition Continues The Long Tradition Of Expansion And Improvement, Which Has Been The Key To The Catalogue'S Ongoing Succesthe Cover Has Been Completed Re-Designed For This Edition.All Miniature Sheets Are Now Included Price: £175.00 Currency Converter Product Code: R2881SET-08

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Categories: DETAIL - Simplified , BRAND - Stanley Gibbons , TYPE - World , YEAR - 2008

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Sotw Vol 2 Countries D-H 2008 Volume 2 Covering Countries D-H. Since It Was First Published In 1934, Stanley Gibbons Simplified Stamps Of The World Catalogue Has Become Accepted As A Standard Work Of Reference Around The World. With Its Easy-To-Use, Simplified Listings, Mint And Used Prices For Almost Every One Of Its 474,000Plus Stamps, Colour Illustrations And Helpful Introductory Notes, This Is The Catalogue For Thethematic Or All-World Collector. The 2008 Edition Continuesthe Long Tradition Of Expansion And Improvement, Which Has Been The Key To The Catalogue'S Ongoing Success. The Coverhas Been Completed Re-Designed For This Edition. Allminiature Sheets Are Now Included Price: £44.95 Currency Converter Product Code: R2882-08 Categories: TYPE - World , BRAND - Stanley Gibbons , YEAR - 2008 , DETAIL - Simplified

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Sotw Vol 3 Countries I-M 2008 Volume 3 Covering Countries I-M. Since It Was First Published In 1934, Stanley Gibbons Simplified Stamps Of The World Catalogue Has Become Accepted As A Standard Work Of Reference Around The World. With Its Easy-To-Use, Simplified Listings, Mint And Used Prices For Almost Every One Of Its 474,000Plus Stamps, Colour Illustrations And Helpful Introductory Notes, This Is The Catalogue For Thethematic Or All-World Collector. The 2008 Edition Continuesthe Long Tradition Of Expansion And Improvement, Which Has Been The Key To The Catalogue'S Ongoing Success. The Coverhas Been Completed Re-Designed For This Edition. Allminiature Sheets Are Now Included Price: £44.95 Currency Converter Product Code: R2883-08 Categories: TYPE - World , YEAR - 2008 , BRAND - Stanley Gibbons , DETAIL - Simplified

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Sotw Vol 4 Countries N-R 2008 Volume 4 Covering Countries N-R. Since It Was First Published In 1934, Stanley Gibbons Simplified Stamps Of The World Catalogue Has Become Accepted As A Standard Work Of Reference Around The World. With Its Easy-To-Use, Simplified Listings, Mint And Used Prices For Almost Every One Of Its 474,000Plus Stamps, Colour Illustrations And Helpful Introductory Notes, This Is The Catalogue For Thethematic Or All-World Collector. The 2008 Edition Continuesthe Long Tradition Of Expansion And Improvement, Which Has Been The Key To The Catalogue'S Ongoing Success. The Coverhas Been Completed Re-Designed For This Edition. Allminiature Sheets Are Now Included Price: £44.95 Currency Converter Product Code: R2884-08 Categories: DETAIL - Simplified , BRAND - Stanley Gibbons , TYPE - World , YEAR - 2008

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Sotw Vol 5 Countries S-Z 2008 Volume 5 Covering Countries S-Z. Since It Was First Published In 1934, Stanley Gibbons Simplified Stamps Of The World Catalogue Has Become Accepted As A Standard Work Of Reference Around The World. With Its Easy-To-Use, Simplified Listings, Mint And Used Prices For Almost Every One Of Its 474,000Plus Stamps, Colour Illustrations And Helpful Introductory Notes, This Is The Catalogue For Thethematic Or All-World Collector. The 2008 Edition

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Continuesthe Long Tradition Of Expansion And Improvement, Which Has Been The Key To The Catalogue'S Ongoing Success. The Coverhas Been Completed Re-Designed For This Edition. Allminiature Sheets Are Now Included Price: £44.95 Currency Converter Product Code: R2885-08 Categories: DETAIL - Simplified , YEAR - 2008 , BRAND - Stanley Gibbons , TYPE - World

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Ipm Picture Postcard Values 2008 Picture Postcard Values 2008 Contains Over 6,000 Entries Andincludes More Than 200 Full Colour Illustrations. Price: £10.95 Currency Converter Product Code: R2981-08 Categories: BRAND - Other , YEAR - 2008

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London Cigarette Card Co Catalogue 2008 The Original Price Guide Now In Its 79Th Year Of Publicationupdated For 2008 And Covering Around 13,000 Different Seriesthe Catalogue Contains 3 Sections:-* Section 1 Covers British Cigarette Cards, Virtually Allknown Cards Listed With Their Price Guide.* Section 2 Covers Foreign Cigarette Cards.* Section 3 Covers Reprinted Series Of Which There Are Nowover 300. Price: £7.00 Currency Converter Product Code: R2985-08 Categories: YEAR - 2008 , BRAND - Other

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1 1 2 3 4 5 V. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Reported by: Sherry L. Brooks Job No. 175664 DEPOSITION OF HORATIA DIANE FAGAN Thursday, July 13, 2006 Washington, DC ) 05-297C UNITED STATES OF AMERICA, Defendant ) PAGES 1-38 ) IN THE UNITED STATES COURT OF FEDERAL CLAIMS -----------------------------------x STERLING, WINCHESTER & LONG, LLC ) Plaintiff ) Case No.:

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2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Pursuant to notice, before Sherry L. Brooks, Court Reporter and Notary Public, in and for the District of Columbia. United States Department of Justice Commercial Litigation Branch, Civil Division 1100 L Street, NW Room 10113 Washington, DC 20530 (202) 307-0282 Deposition of Horatia Diane Fagan held at: July 13, 2006 10:15 a.m.

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3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 ALSO PRESENT: Jeannine H. Turenne, Agency Counsel to Defendant ON BEHALF OF THE DEFENDANT: Sheryl Floyd, Esquire United States Department of Justice Commercial Litigation Branch, Civil Division 1100 L Street, NW Room 10113 Washington, DC 20530 (202) 307-0282 ON BEHALF OF THE PLAINTIFF: Frederick L. Wright, Esquire Vaughn, Wright & Boyer, LLP One Paces West Suite 1740 Atlanta, GA 30339 (770) 805-9889

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21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Yes, I did. Q. At the time that you signed Plaintiff's Exhibit 1 -- well, in fact, let's come at this more directly. Let me hand you what's been marked Plaintiff's Exhibit 6, and you can see there it says -- on its face on the first page that it says glossary of postal terms, May 1997, Publication 32. Are you familiar with that? A. Not offhand. I would have to see it, but not offhand. Publication 32, Corporate Publishing, if I saw a copy of it, I could tell you. Q. Well, I don't have, of course, a nice -the way that it comes I'm sure when it's printed, but I do have, if you want to look at it, something I printed off of the internet, which is the entire glossary of postal terms. That's not an exhibit. I was handing it to you to let you look at it. MR. WRIGHT: If anyone wants to make it an exhibit, we can. MS. FLOYD: Yes. Can we make it an exhibit? MR. WRIGHT: Sure. That's the only copy

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22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 I've got with me, but we can -MS. FLOYD: Sure. We can make a copy at a break. MR. WRIGHT: Sure. That's no problem. THE WITNESS: Yes, I'm familiar with this. BY MR. WRIGHT: Q. Were you familiar with that at the time that you signed Plaintiff's Exhibit 1? A. Yes. Q. All right. If you would turn in there -MR. WRIGHT: We will make that an exhibit, and I think it's going to be 59. Let's just go ahead and do that right now. Can we put a sticker on there right now and just mark that 59? (Exhibit Number 59 was marked for identification and was attached to the deposition.) BY MR. WRIGHT: Q. All right. We've now marked that document that I handed you as Plaintiff's Exhibit 59, which is a Postal Service Publication 32. If you would turn to -- I don't know what page it is, but it's in alphabetical order of course -- the P section. It's

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23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 probably where that red sticker is sticking out actually. And do you see on that page -- that would be Page 84 of the glossary. Do you see there a definition for the term philatelic center? A. Yes. Q. At the time that you signed Plaintiff's Exhibit 1, were you aware that the term philatelic center was defined in Publication 32? A. I'm not sure. Q. Okay. Basically -- have you read that definition? And if not, would -A. I'm not sure. Q. I mean, right now. Would you just take a look at it? A. Okay. Q. All right. Let me ask you this before we go back to that. At the time that you signed the agreement, Plaintiff's Exhibit 1, were you familiar with any kind of a facility operated by the postal service referred to as a philatelic center? A. Repeat that. Q. At the time -- you know, I want to only

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24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 tie this to the time that you signed the agreement -were you aware that the post office operated a facility known as a philatelic center? A. No. Q. Okay. Since that time, have you ever heard of a -A. Have we had -- that the postal service have a philatelic center? Q. Yes, ma'am. A. No. Q. Okay. Now, based on what you've seen there and the definition of philatelic center in Publication 32, Plaintiff's Exhibit 59, just based on that definition now, would you say that a philatelic center is not the same thing as a post office? A. Correct. Q. And it wouldn't be the same thing as a branch post office? A. Repeat that. Q. Have you ever heard the term branch post office? A. Yes.

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Page 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS STERLING, WINCHESTER & LONG, L.L.C., Plaintiff vs. UNITED STATES OF AMERICA Defendant ) ) ) ) )No. 05-297C ) ) ) ) ) )

Deposition of Cindy L. Tackett Washington, D.C. July 27, 2007

Reported by: JOB NO. 182392

Bonnie L. Russo

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1 2 3 4 5 July 27, 2007 6 10:11 a.m. 7 8 9 Deposition of Cindy L. Tackett held at: 10 11 United States Postal Service 12 475 L'Enfant Plaza, S.W. 13 Washington, D.C. 14 15 16 17 18 19 20 21 Pursuant to notice, before Bonnie L. Russo, 22 Notary Public
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CONTENTS EXAMINATION OF CINDY L. TACKETT BY MR. WRIGHT 5

PAGE

EXHIBITS 101 26th Edition Stamp Values 102 27th Edition Stamp Values 103 28th Edition Stamp Values 104 29th Edition Stamp Values 105 30th Edition Stamp Values 106 Handbook Update Notice 107 Philatelic Center 47 Operations Guide (Exhibits included with transcript.)

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APPEARANCES: For the Plaintiff FREDERICK L. WRIGHT, Esq. VAUGHN, WRIGHT & BOYER, LLP One Paces West-Suite 1740 2727 Paces Ferry Road, N.W. Atlanta, Georgia 30339 For the Defendant MAAME A. F. EWUSI-MENSAH, Esq. Department of Justice 1100 L Street, N.W. Room 12000 202-353-0503 and JEANNINE H. TURENNE, Esq. UNITED STATES POSTAL SERVICE Attorney, Law Department 475 L'Enfant Plaza, S.W. Washington, D.C. 20260 202-268-6357 J. G. Long, Sterling, Winchester & Long

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P-R-O-C-E-E-D-I-N-G-S CINDY L. TACKETT, being first duly sworn, to tell the truth, the whole truth and nothing but the truth, testified as follows: EXAMINATION BY COUNSEL FOR PLAINTIFF BY MR. WRIGHT: Q. Would you state your name, please. A. Cindy Lee Tackett. Q. And what's your address, Ms. Tackett? A. My home address? Q. Yes, please. A. 8331 Idulwood, I-d-u-l-w-o-o-d Road, Vienna, Virginia 22182-5139. Q. Are you currently employed? A. Yes, sir. Q. By whom? A. United States Postal Service. Q. And you consent today to testify on behalf of the defendant in this lawsuit? A. (Witness nodding head.)

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member that also -- who manages the pictorial postmark program, which is the postmarks that are used for temporary stations for collectors. Each postal bulletin, every postal bulletin, there is a list of postmarks that are available nationwide for collectors to send their covers in. So it's kind of -- I do have a lot of different things. Q. Okay. And so you're familiar with the Philatelic Centers that are operated by the postal service? A. I'm familiar with the Philatelic Centers, however, I don't have direct management of them. Q. But you are familiar with the fact that they exist? A. Uh-huh. Yes, sir. Q. Okay. And do you have general knowledge of what they -- what kinds of products, let's say, are sold at the Philatelic Centers and that kind of thing? A. Yes, sir.
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exhibit is just a copy of what, the cover? A. The cover. Q. Cover of the guide that you mentioned? A. Uh-huh. Uh-huh. Q. All right. Now, flipping to the third page, what is that? A. That's a list of the Philatelic Centers that's in that publication. Q. That appears in that guide -A. Uh-huh. Q. -- that is identified by the cover of this Page 2? A. Uh-huh. Q. And what is -- and then from that page, the third page of the exhibit to the end, that consists of a list? A. By state. Q. Of Philatelic Centers? A. Yes. Q. That are owned and operated by the postal service?
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(Discussion off the record.) (Deposition Exhibit No. 101 was marked for identification.) BY MR. WRIGHT: Q. Ms. Tackett, let me hand you what has been marked Exhibit 101, which is a document that has been produced to the plaintiff by the postal service in this case. Can you identify what that document is? A. Yes. It's our publication, our annual publication, The Postal Service Guide to U.S. Stamps. It has the Philatelic Centers in certain publications. Q. Okay. Let's just walk through it. The first page is, of course, just a -A. Cover sheet. Q. -- cover sheet generated, I take it, for purposes of identifying the year of the -that the exhibit pertains to, right? A. Uh-huh. Q. And then the second page of the

A. Yes. Q. And to the best of your knowledge, that's a complete listing of all of the Philatelic Centers that existed as of -A. At the time of publication. Q. The time that guide, the 1999 guide was published? A. Uh-huh. Q. Okay. (Deposition Exhibit No. 102 was marked for identification.) BY MR. WRIGHT: Q. All right. Let me hand you what has been marked Exhibit 102. And that -- again, all of these documents that I'm going to show you have been produced to the plaintiff by the postal service so I won't say that every time. A. Okay. Q. Can you identify what Exhibit 102 is? A. A cover sheet and a cover of The Postal Service Guide, 27th Edition, and then a

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you or that you discussed with any attorney, and I'm not asking you to tell me why you looked at the documents. But if you did look at any documents, other than perhaps a memorandum or something from an attorney representing the postal service, if you could just tell me whether you looked at any other documents to prepare to give your testimony today. A. Repeat that again. Q. Not the whole thing. A. I'm like what. Q. Did you -- other than Exhibits 101 through 105, and not counting any memorandum from attorneys representing the postal service or anything like that that may have been generated to you, did you review any documents to prepare for your deposition today? A. Well, I reviewed my bio just to make sure I had my dates down right. Q. Okay. Now, do you have any familiarity, at all, with the agreement between
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City is a mail order center that supports stamp collectors. But what mainly the Philatelic Centers do is they cater to stamp collectors. They have the current stamp issues and older stamp issues available in the facility and they also sell them, I guess you could say, in plate box and different formats that collectors usually like to buy their stamps in. But it's primarily, you know -- at Philatelic Centers, some of the things that collectors look for is the centering of stamps and the perforations and the different formats of a stamp issue. Because sometimes we issue one stamp image, but in many different formats. It could be a paint of stamps; it could be a booklet of stamps; it could be a coil, and so collectors collect different formats of all those. Q. Do the Philatelic Centers offer for sale any products other than stamps themselves? A. They offer Philatelic products, which Philatelic products primarily they have
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the plaintiff, Sterling, Winchester & Long and the postal service that is the subject matter of this case? A. No. Q. And you have no -- not necessarily just firsthand knowledge, but you don't really know anything about that agreement? A. (Witness shaking head.) No. Q. You've got to state your answer. A. Oh. No, I don't. Q. Okay. Can you just explain to me generally -- and to the extent you have already touched on this, I apologize. But I would -if you don't mind, would you just explain generally what is a Philatelic Center as operated by the postal service? A. Okay. A Philatelic Center can be one of several things. It could be a designated building. It could be a designated window. Or it could be our Philatelic -- our Stamford fulfillment service office in Kansas

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stamps in the products. Okay? The only exception to that would be this Postal Service Guide to U.S. Stamps, which is a Philatelic product and it doesn't have stamps. It depicts all the stamps that we have ever issued by the postal service. This publication depicts every single stamp we have ever issued in it. Q. Oh, really? A. It lists it by prices. It has prices in it. We use Scott's pricing for collectors to use as they are valuing their collections and stuff. Q. Uh-huh. So that guide, the guide that you lists every -- depicts every stamp ever issued by the postal service? A. Right. That's why it's the annual publication. Every year we add the next year's in there and we have to change the values. Q. So it gets bigger every year? A. It gets bigger every year.

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Actually, the format doesn't even look like this anymore. It's a spiral big book now. That comes out of my staff. I know. Because my staff produces it. Q. Okay. All right. So a Philatelic Center, now, what -- when you say, "Philatelic products," I'm just trying to determine does that include, though, anything other than stamps or something that actually is incorporating an actual stamp itself? A. Repeat that again. Q. Well, in other words, I know that the Philatelic Centers sell stamps. A. Uh-huh. Q. Is that right? A. Right. Correct. Q. And I think I know that. And they sell some kind of a product that somehow incorporates an actual stamp in the product; is that -A. Correct. Q. -- correct?
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cards, Philatelic products, they're all accountable just like money. And they enter into an accountable system and that -- they're distributed through the stamp distribution offices and then to post offices, and then to Philatelic Centers, and they're all accountable. BY MR. WRIGHT: Q. Okay. What about posters? To the best of your knowledge, during the time frame we're talking about now, 2000 to the present, have Philatelic Centers ever sold posters? A. At one point they did sell a poster, but all posters have a stamp either affixed to it or with the poster. Q. Okay. So only posters that would have a real stamp affixed to the poster? A. To the poster or with it. Q. What do you mean by "with it"? A. Well, sometimes what we would do is put a mount in the actual stamps for the customer to put the stamps onto the poster.
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A. Uh-huh. Q. Okay. Does the -- have the Philatelic Centers ever sold products that do not actually incorporate a stamp as a part of the product itself? In other words, something that maybe is a photograph of a stamp or something like that? MS. EWUSI-MENSAH: I just want to interpose an objection as to the time frame. MR. WRIGHT: Please do. MS. EWUSI-MENSAH: I believe that the topic was just from 2000 to the present. I'm not sure the question is limited to that. MR. WRIGHT: Okay. That's fine. We'll limit all of your answers to that time frame. THE WITNESS: Okay. Not -- no. Not that I am aware of. The reason why I am telling you this is that anything that a Philatelic Center sells has to go through our accountable paper distribution methods and anything -- stamps, stamp stationery, postal

Q. So the stamp would come separately. It would all be part of the sale, but it would be a poster and a stamp? A. Right. Together. Q. Separate? A. Right. Q. Okay. All right. So to the best of your knowledge, then, are there any other products that do not consist of stamps themselves that have been sold in the Philatelic Centers, other than what you have already mentioned? A. Not that I'm aware of. Q. Okay. The Philatelic Centers that are listed there on -- in Exhibits 101 through 105, those -- each one of those is 100 percent controlled by the postal service; is that correct? A. Correct. Q. Now, are you familiar with a Philatelic catalog published by the postal service?

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A. Uh-huh. Yes. That comes out of our office. Q. And is that also 100 percent controlled by the postal service? MS. EWUSI-MENSAH: I would just interpose an objection, that the topic that she's -- was prepared to speak about are specifically Philatelic Centers and not the Philatelic catalog that was in that topic. So she can speak as to her personal knowledge, but that testimony would be all. MR. WRIGHT: Oh, I agree. I just -since she said she's familiar with it I thought -MS. EWUSI-MENSAH: I just want the record to be clear that that is only as to her personal knowledge, not on behalf of the postal service. MR. WRIGHT: That's fine. THE WITNESS: Okay. The question? Am I familiar with the catalog, yes, I am.
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Q. But the catalog is not distributed generally to the -- just to the general public? A. No. It's -- you have to be on the mailing list or you might be able to -- we send some of them to post offices where you might be able to obtain a copy from a post office. But at different times, you know, the level of how many we produce and the quantity and where we distribute them to internally within post offices is varied. Q. Right. In other words, I'm sure anybody can get it, right? A. Uh-huh. You can go online and ask for it, and it's a free publication. Q. But I'm just saying -- but in terms of the mailing list, that's -A. Maintained by us. Q. -- consists generally of only persons who have expressed an interest or a desire to have the catalog; is that fair? A. That's correct. Q. Okay. What kinds of -- well, let me
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BY MR. WRIGHT: Q. And is the catalog, as you understand it, controlled 100 percent by the postal service? A. Yes, it is. Q. Did you say your office is in charge of the catalog? A. Our -- yeah. We -- our office, stamp services produces the catalog and the fulfillment house, which is our -- out of Kansas City, falls under stamp services, which is part of our group. Q. Now, what's the purpose of the catalog? A. The catalog is another channel in order for collectors to purchase their stamps. The catalogs mailed on a quarterly basis to a mailing list, usually the collectors that purchase the stamps through the catalog. They get the catalog on a quarterly basis. And then also we send it to like stamp shows and things like that for people to use as reference.

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ask you this: Are products offered for sale in the Philatelic catalog? A. Are products offered for sale? Q. Yes, ma'am. A. Yes. Q. What kinds of products are offered for sale in the catalog? A. There are Philatelic products. There is -- each of the formats of the stamps, every time we issue a stamp, there's many different formats. There are what we call first day covers. Well, they're Philatelic products. Commemorative -- there are first day issue covers, which are Philatelic products. We sell those in there postmarked. They have the actual first day of issue postmark on them. And then other Philatelic products that our department produces, meaning year books. We have an annual yearbook that includes each of the stamps that are issued in a commemorative yearbook, each of the stamps that are issued for that year. We sell that

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product and we sell other topical products based on -- you know, we have stamped cards. We have stamped stationery. We have -- lets see, what else do we have in there? I'm trying to make a visual -- oh, we sell subscription programs to our collectors. We have American commemorative collectibles program offers collectors opportunities to subscribe to programs. We sell that in there. Q. Okay. And it's published quarterly? A. Yes. Q. Is there any version of the catalog available for viewing online? A. No, not yet. Eventually there will be. We have been working on that. Q. Okay. What about -- let me just jump back really quickly to these lists of Philatelic Centers. I know that only went up through 2003. Could one find similar lists in the guides for the subsequent years, 2004 through 2007?
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be profit centers for the postal service? A. It's my knowledge in the retail operations book that there's supposed to be revenue initiatives that are associated with it. But that management is not under my responsibility, so I wouldn't know the particulars on it. Q. Okay. So you don't really know, then, as to any particular instance of a Philatelic Center closing, whether it might have been a -- due to revenue issues or anything like that? A. No. I wouldn't know that. That would be a postmaster area and district's decision. Q. Okay. As far as you know, if you know, are the Philatelic Centers generally profitable, do you know? A. I can't answer that. Q. Do you have any information on traffic volume in Philatelic Centers, either generally or with reference to any particular
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A. I would have to go back and check, but we did make a decision, and I was part of that decision-making process, to -- because of the size of the book and it kept getting larger and larger, we had to look at ways to kind of reduce, and with Philatelic Centers changing locations and closing down it's hard for us to maintain an accurate address and location of each one of them. So what we have since done is you'll find a little thing where you can call 1-800 and get the current -- you know, you just tell them your state and then they -- they'll give you the current address of a local Philatelic Center now. That's how we do it. Q. Is a listing of the Philatelic Centers, to your knowledge, available on the postal service web site? A. Yes. Q. You mentioned Philatelic Centers closing down, moving, et cetera, et cetera. Are Philatelic Centers intended to

Philatelic Center? A. No. Q. Do you know if such information exists? A. I don't know. Q. I have a couple of other documents here that I believe come within your scope. (Deposition Exhibit No. 106 was marked for identification.) BY MR. WRIGHT: Q. Let me hand you what has been marked Exhibit 106. And that, once again, is a document that was produced for us by the postal service. I think it's just part of a document. Do you recognize that? Can you tell me what that exhibit consists of? A. This is a copy of a PO-209, which is the retail -- the handbook for retail operations dated April 2005. Q. And am I understanding this correctly that the actual handbook itself would be much larger than this?

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A. Yeah, I would think so. Q. And that what we have here is just a part of it, Section 18, or whatever you want to call it, Part 18 of the handbook? A. Well, it looks like you have pages starting with 104. So it's obviously a bigger. Q. Or 103? A. Page 103. Q. 103, right. And that's like Section 18, Philatelic, is that what yours says over there? A. Uh-huh. Yes. Q. Are you familiar with this handbook? A. I am familiar with -- I am familiar with all -- I mean, handbooks. We use them for reference all the time. Q. But this particular one is not something that you have? A. This is a retail that was initiated by retail operations. Q. Which is something other than what you do.
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MR. WRIGHT: That's fine. Yeah. I don't have that on my copy. MS. EWUSI-MENSAH: Okay. BY MR. WRIGHT: Q. Okay. Do you see there Section 18-2 definitions? A. Uh-huh. Q. And it defines the term "Philatelic Center"? A. Yes. Q. Do you see that? A. Yes. Uh-huh. Q. All right. Now, and then it says a Philatelic Center may be referred to as a postal shop, stamp shop, Postique, also a Philatelic windows. What I was wondering is this: The list that we looked at that were in Exhibits 101 through 105, would that include on that list all of the postal shops, stamp shops, Postique, Philatelic windows? Is all -- any of those kinds of things, they're all included on that list?
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So this section here on this Philatelic, is that any -- is that -- starting on the fourth page of the exhibit insofar as that section of this handbook, is that something that you're familiar with on any ongoing basis as a part of your job? A. Repeat that again. Q. As a part of your -- just as a part of your job, are you -- do you have a familiarity with this? A. The Philatelic section. Q. The Philatelic section of this handbook? A. (Witness nodding head.) Q. Is that yes? A. Yes. I'm sorry. Q. All right. Let's just look at this for just a second. The -- well, start there on the page that's in the bottom right there is a -- identified as Page 103. MS. EWUSI-MENSAH: Just to make the record clear, that's Bates No. 2911?

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A. Yes, sir. Q. And is there any way, by looking at those lists, that we can determine which is which? A. No. Q. Are you aware of -A. Off of this list? Q. Right. Exhibits 101 through 105? A. No, there is no way to identify what is a Postique and what is a shop and what is a window. Q. All right. What's the difference between a Postique and a stamp shop? A. Pretty much they're just titles of what they called their facility. A Postique is just -- is a trademark name that we had. Not all offices used it. It's just that some offices use it for their window or their -- at their site location. Q. Now, are we talking about -- when you say, "a window," are we talking about something that is in a -- what is otherwise

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just a branch post office? A. In some cases, yes. Q. And in some cases it's a -A. Separate. Q. -- separate facility? A. (Witness nodding head.) Q. And it consists only of the window? A. Yes. But those are -- a long time ago they were more -- you know, they are not as common anymore because most of the time they're in with regular post office windows. They will be regular traditional over-the-counter windows and there will be a separate area for a Philatelic window that's separate in the lobby. Q. Of a branch post office? A. Yes. Q. All right. Now, are some Philatelic Centers stand alone facilities? A. Currently? Q. Or have any been since 2000, let's put it that way? A. I have to go back and look and see
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is our mail order facility that we do out of Kansas City. I don't know particularly of a specific site that's a stand-alone. We used to have one at L'Enfant Plaza here that used to be a stand-alone that was nothing but a Philatelic Center. Window by itself, a whole area by itself with no other traditional counter lines. Okay? But I don't know what year that closed. Q. When you say, "without traditional counter lines," in other words, it's not a place you could go to mail a package? A. Right. Q. But you don't know whether there have been other similar locations, Philatelic Center locations anywhere in the United States from the year 2000 where the facility, as you've just described, would be only a Philatelic Center? MS. EWUSI-MENSAH: Objection. Asked and answered. BY MR. WRIGHT: Q. You can still answer the question.
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if -- I know of some. I'm just looking to see because they have closed some of them down. Q. I'm sorry, what was that? A. They closed some of them down. Q. Some of the stand-alone? A. Yes. So at some point, there were stand-alones and there may be stand-alones. I wouldn't be able to tell you now nationwide what the stand-alones are. Q. But from the period year 2000 to the present, you do know that there have been stand-alone Philatelic Centers operated by the postal service? A. 2000. I'm specifically thinking of the one that was in this building. I'm not sure when it closed down. I don't know for sure. Q. So you're saying from the year 2000 to the present, you don't know whether the postal service has operated any stand-alone Philatelic Centers? A. The only one that I'm aware of that

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A. Oh. Only the area and district offices would know what sites were stand-alones. I wouldn't know. Q. Okay. And what was that, the area -A. Area and district offices would know what were -- what are currently stand-alones. Q. Okay. That's for each -- there is no -- you're saying for each area or district in the country? A. Right. There is nine areas. I'm sorry. There's nine area offices and under those there are district offices. And they're the ones that approve the use of a Philatelic Center or operations within their areas. Q. Okay. Well, who did the area offices -- what department or what person do the area officers report to? A. Well, the area offices -- the area vice presidents report to senior management within the postal service. They are direct reports to senior management within the postal

11 (Pages 38 to 41)

Esquire Deposition Services

A510

404-872-7890

d3818445-a512-4179-b486-cfd857c5bede

Case 1:05-cv-00297-LSM

Document 34-9

Filed 01/28/2008

Page 35 of 36

A511

Case 1:05-cv-00297-LSM

Document 34-9

Filed 01/28/2008

Page 36 of 36

A512