UNITED STATES OF AMERICA

Before the

POSTAL REGULATORY COMMISSION

WASHINGTON, DC 20268-0001

Rate and Service Changes To Implement )

Baseline Negotiated Service Agreement ) Docket No. MC2007-5

With Life Line Screening )

OFFICE OF THE CONSUMER ADVOCATE

INTERROGATORIES TO LIFE LINE SCREENING

WITNESS ERIC GREENBERG

(OCA/LLS-T1-1-11)

(August 27, 2007)

Pursuant to Rules 25 through 28 of the Rules of Practice of the Postal
Rate Commission, the Office of the Consumer Advocate hereby submits
interrogatories and requests for production of documents.

If data requested are not available in the exact format or level of
detail requested, any data available in (1) a substantially similar
format or level of detail or (2) susceptible to being converted to the
requested format and detail should be provided.

The production of documents requested herein should be made by
photocopies attached to responses of these interrogatories. If
production of copies is infeasible due to the volume of material or
otherwise, provision should be made for inspection of responsive
documents at the Office of the Consumer Advocate, 901 New York Avenue,
N.W., Washington, D.C. 20268‑0001, during the hours of 8:00 a.m. to
4:30 p.m.

If a privilege is claimed with respect to any data or documents
requested herein, the party to whom this discovery request is directed
should provide a Privilege Log (*see, e.g.*, Presiding Officer Ruling
C99‑1/9, p. 4, in *Complaint on PostECS*, Docket No. C99‑1).
Specifically, "the party shall make the claim expressly and shall
describe the nature of the documents, communications, or things not
produced or disclosed in a manner that, without revealing information
itself privileged or protected, will enable other parties to assess the
applicability of the privilege or protection." Fed. R. Civ. P. 26(b)(5).

The term "documents" includes, but is not limited to: letters,
telegrams, memoranda, reports, studies, newspaper clippings, speeches,
testimonies, pamphlets, charts, tabulations, and workpapers. The term
"documents" also includes other means by which information is recorded
or transmitted, including printouts, microfilms, cards, discs, tapes and
recordings used in data processing together with any written material
necessary to understand or use such punch cards, discs, tapes or other
recordings.

"All documents" means each document, as defined above, that can be
located, discovered or obtained by reasonable diligent efforts,
including without limitation all documents possessed by: (a) you or your
counsel; or (b) any other person or entity from whom you can obtain such
documents by request or which you have a legal right to bring within
your possession by demand.

"Communications" includes, but is not limited to, any and all
conversations, meetings, discussions and any other occasion for verbal
exchange, whether in person

or by telephone, as well as all documents, including but not limited to
letters, memoranda, telegrams, cables, or electronic mail.

"Relating to" means discussing, describing, reflecting, containing,
analyzing, studying, reporting, commenting on, evidencing, constituting,
setting forth, considering, recommending, concerning, or pertaining to,
in whole or in part.

Responses to requests for explanations or the derivation of numbers
should be accompanied by workpapers. The term "workpapers" shall include
all backup material whether prepared manually, mechanically or
electronically, and without consideration to the type of paper used.
Such workpapers should, if necessary, be prepared as part of the
witness\'s responses and should "show what the numbers were, what
numbers were added to other numbers to achieve a final result." The
witness should "prepare sufficient workpapers so that it is possible for
a third party to understand how he took data from a primary source and
developed that data to achieve his final results." Docket No. R83-1, Tr.
10/2795‑96. Where the arithmetic manipulations were performed by an
electronic digital computer with internally stored instructions and no
English language intermediate printouts were prepared, the arithmetic
steps should be replicated by manual or other means.

Please especially note that if you are unable to provide any of the
requested documents or information, as to the interrogatory, provide an
explanation for each instance in which documents or information cannot
be or have not been provided.

For purposes of these interrogatories, please interpret the phrase "Life
Line Screening of America Ltd" to mean "Life Line Screening of America"
or "Life Line Screening" where necessary and/or appropriate.

Respectfully submitted,

Kenneth E. Richardson, Acting Director

Office of the Consumer Advocate

Emmett Rand Costich, Attorney

901 New York Avenue, N.W.

Washington, D.C. 20268-0001

\(202\) 789-6833; Fax (202) 789-6891

e-mail: <costicher@prc.gov>

OCA/LLS-T1-1. Please confirm that the full name of your employer is Life
Line Screening of America Ltd, registered in Ohio as a limited liability
company. If you do not confirm, please explain any and all differences
between ''Life Line Screening of America'' and ''Life Line Screening of
America Ltd''.

OCA/LLS-T1-2. Please confirm that Life Line Screening of America Ltd has
never made a filing with the SEC. If you do not confirm, please provide
a copy of the most recent SEC filing.

OCA/LLS-T1-3. At page 3, lines 12-17, of your testimony, you discuss the
effect of adding an ultrasound team to Washington, DC. Is Life Line
Screening of America Ltd currently registered to do business in the
District of Columbia? If not, state the calendar year in which Life Line
Screening of America Ltd expects to commence doing business in the
District of Columbia.

## OCA/LLS-T1-4. Please define and give examples of ''affinity partners'' as that term is used at page 8, line 15, of your testimony.

## Is Memorial Hermann System of Houston, Texas, an affinity partner? (''Memorial Hermann System and Life Line Screening Partner to Promote Healthier Communities in Houston Area'' [**http://www.memorialhermann.org/newsroom/060807.htm**](http://www.memorialhermann.org/newsroom/060807.htm)) If not, please describe the relationship between Life Line Screening of America Ltd and Memorial Hermann System.

## Is Life Line Screening, as used in the quotation above, the same entity as Life Line Screening of America Ltd? If not, please explain any and all differences between ''Life Line Screening'' and ''Life Line Screening of America Ltd''.

## Has the relationship with Memorial Hermann System caused an increase in Life Line Screening of America Ltd's volume of letter-shaped Standard Mail? If so, by how much. If not, why not?

## 

OCA/LLS-T1-5. During calendar year 2007, how many affinity partners has
Life Line Screening of America Ltd acquired?

a.  How has the acquisition of affinity partners during calendar year
    2007 affected Life Line Screening of America Ltd's volume of
    letter-shaped Standard Mail?

b.  Please confirm that the website of Life Line Screening of America
    Ltd makes the following statement: ''These partnerships demonstrate
    the credibility of our organization and provide us the access *to
    market our services in a much broader arena.''*
    <http://www.lifelinescreening.com/Partnerships/Pages/Index.aspx>
    (emphasis added).

c.  Please confirm that Life Line Screening of America Ltd will not seek
    affinity partners or other partnerships during the period of
    calendar years 2008-2010. If you do not confirm, please explain.

OCA/LLS-T1-6. During the effective period of the NSA, how many affinity
partners does Life Line Screening of America Ltd expect to acquire? How
will the acquisition of affinity partners during the effective period of
the NSA affect Life Line Screening of America Ltd's volume of
letter-shaped Standard Mail?

OCA/LLS-T1-7. Please define and give examples of ''major US market,'' as
that term is used at page 6, lines 18-19, of your testimony.

a.  What was the last major US market that Life Line Screening of
    America Ltd entered?

b.  On what date did Life Line Screening of America Ltd commence
    operations in that major US market?

c.  How many major US markets are there?

OCA/LLS-T1-8. Please define and describe ''ultrasound team,'' as that
term is used at page 2, line 7, page 3, line 7, and page 6, line 17, of
your testimony.

a.  As of December 31, 2006, how many ultrasound teams existed?

b.  As of August 31, 2007, how many ultrasound teams existed?

c.  Are all members of ultrasound teams employees of Life Line Screening
    of America Ltd?

d.  As of December 31, 2006, what was the total number of all employees
    of Life Line Screening of America Ltd?

e.  As of August 31, 2007, what was the total number of all employees of
    Life Line Screening of America Ltd?

f.  Have the employees of Line Screening of America Ltd been informed
    that the company will not grow during the period of calendar years
    2008-2010? If not, why not?

OCA/LLS-T1-9. At page 7, lines 6-8, of your testimony, you state,

> Very little growth in screening events is expected to take place in
> 2008 and beyond because we will already have teams in all 48
> continental states. . . . Thus, in the absence of this NSA,
> significant direct mail volume growth is not anticipated, as the
> number of our screening events each year are not expected to increase
> substantially.

a.  Please list the states in which there is only one ultrasound team.

b.  How many ultra sound teams are in Arizona?

c.  Please confirm that four of the top thirty-five fastest growing US
    cities are in Arizona.
    (<http://money.cnn.com/2007/06/27/real_estate/258_fastest_growing_cities/index.htm>)
    If you do not confirm, please explain.

d.  How many ultrasound teams are in Texas?

e.  Please confirm that nine of the top thirty-five fastest growing US
    cities are in Texas.
    (<http://money.cnn.com/2007/06/27/real_estate/258_fastest_growing_cities/index.htm>).
    If you do not confirm, please explain.

f.  Please list the consolidated metropolitan statistical areas (CMSAs
    as defined by the US Census Bureau) in which there is more than one
    ultrasound team.

g.  Please list the CMSAs in which a new ultrasound team will be placed
    during calendar years 2008-2010.

OCA/LLS-T1-10. Please confirm that Polaris Venture Partners holds an
interest in Life Line Screening of America Ltd
([http://www.polarisventures.com/Portfolio/CompanyDetail.asp?CompanyID={4A39D7FD-7FB9-427D-99A6-586B0C7ABC69](http://www.polarisventures.com/Portfolio/CompanyDetail.asp?CompanyID={4A39D7FD-7FB9-427D-99A6-586B0C7ABC69)}).
If you do not confirm, please explain the appearance of Life Line
Screening of America Ltd on the Polaris website.

a.  Please confirm that the Polaris website states, ''We invest in seed,
    early stage, and high growth middle market companies."
    (<http://www.polarisventures.com/WhoWeAre/MissionStrategy.asp>)

b.  At page 3, lines 19-20, of your testimony, you state, "\[W\]e have
    territorial coverage in all the places we need to be in." Please
    confirm that Life Line Screening of America Ltd will not be a
    high-growth company in the period 2008-2010. If you do not confirm,
    please explain.

c.  Please explain why Polaris would retain a stake in a company that
    expects flat growth over the next three years.

OCA/LLS-T1-11. At page 2, line 23, through page 3, line 1, of your
testimony, you state, ''Our customers are typically aging baby boomers
and senior citizens.''

a.  At what age does one become an aging baby boomer?

b.  Is a retiree likely to be an aging baby boomer or senior citizen?

c.  How many people over the age of 60 live in Florida?

d.  How many ultrasound teams are in Florida?

e.  How many people over the age of 60 live in the New York City CMSA?

f.  How many ultrasound teams are in the New York City CMSA?

g.  How many people over the age of 60 live in Texas?

h.  How many ultrasound teams are in Texas?

i.  What state has the highest ratio of people over the age of 60 to
    ultrasound teams?

j.  What state has the lowest ratio of people over the age of 60 to
    ultrasound teams?

k.  Please explain why the difference in these ratios does not signal
    growth opportunities for Life Line Screening of America Ltd.