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             UNITED STATES DISTRICT COURT
             SOUTHERN DISTRICT OF FLORIDA
            CASE NO.  88-1886-CIV-HOEVELER


UNITED STATES OF AMERICA, et al,   	)
                                   	)
             Plaintiffs,           	)
                                   	)
vs.                                	)
                                   	)
SOUTH FLORIDA WATER MANAGEMENT     	)
DISTRICT; JOHN R. WODRASKA,        	)
EXECUTIVE DIRECTOR, SOUTH FLORIDA  	)
WATER MANAGEMENT DISTRICT; FLORIDA 	)
DEPARTMENT OF ENVIRONMENTAL REGU-  	)
LATION; AND DALE TWACHTMANN,       	)
SECRETARY, FLORIDA DEPARTMENT OF   	)
ENVIRONMENTAL REGULATION, et al,   	)
                                   	)
             Defendants.           	)
___________________________________	)


                    - - - - - - - -
              DEPOSITION OF LAURA CORRY,
                 THE WITNESS, TAKEN ON
               BEHALF OF THE PLAINTIFFS
                    - - - - - - - -


DATE:  August 23, 1990
            PROFESSIONAL REPORTING SERVICE
             Suite 303, 324 Datura Street
            West Palm Beach, Florida 33401
                    (407) 659-4046

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                       I N D E X
August 23, 1990        DIRECT  CROSS
LAURA CORRY
By Ms. Nash             5
By Mr. Richards                 10

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The deposition of LAURA CORRY, the witness, in the
above-entitled and numbered cause, was taken before me,
DONNA McCALLEY, Registered Professional Reporter, and
Notary Public for the State of Florida at Large, at
Suite 110, 324 Datura Street, in the City of West Palm
Beach, County of Palm Beach, in the State of Florida,
beginning at the hour of 3:16 p.m., on Thursday, the
23rd of August, 1990, pursuant to the Notice in said
cause for the taking of said deposition, which is
annexed to the court file herein, on behalf of the
Plaintiffs in the above-entitled action pending in the
above-named court.
             The appearances at said time and place
were as follows:
             UNITED STATES DEPARTMENT OF JUSTICE
             Room 868, 601 Pennsylvania Avenue, N.W.
             Washington, D.C.  20044-0663
             Attorneys for the Plaintiffs, U.S.A.
             By BEVERLY SHERMAN NASH, ESQ.
             PEEPLES, EARL & BLANK, P.A.
             Suite 3636, Two South Biscayne Boulevard
             Miami, Florida  33131
             Attorneys for the Cities of Belle Glade
               and Clewiston
             By JOSEPH RICHARDS, ESQ.
             SKADDEN, ARPS, SLATE, MEAGHER & FLOM
             1440 New York Avenue, N.W.
             Washington, D.C.  20005-2107
             Attorneys for the South Florida Water
               Management District
             By KATHARINE STOLLMAN, ESQ.
                ALLISON BURDETTE, ESQ.

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APPEARANCES CONTINUED:
             SOUTH FLORIDA WATER MANAGEMENT DISTRICT
             3301 Gun Club Road
             West Palm Beach, Florida  33416-4680
             By JACQUELYN L. WATERS, ESQ.
             ALSO PRESENT:  Ray Roberts
                            Robert Johnson

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THEREUPON:
                     LAURA CORRY,
having been first duly sworn, as hereinafter certified,
testified as follows:
                  DIRECT EXAMINATION
BY MS. NASH:
       Q.    State your name.
       A.    Laura Corry.
       Q.    Miss Corry, my name is Beverly Nash.  I'm
counsel for the United States in this litigation.  And
we're here today to try and understand how the water
management district computers operate, how they're set
up, how they're utilized, what data is on them, and
you're here as a representative of the district having
knowledge concerning one or more of nine categories
that we wish to inquire about.
             Have you been shown that list of
categories?
       A.    Yes.
       Q.    And to which categories are you
responsive?
       A.    I don't know.  It was a general overview
of it.
       Q.    What is your present title or position?
       A.    Staff analyst in the Office of

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Communications.
       Q.    Is that Office of Communications part of a
division or department?
       A.    It's an office--it's not a division, it's
not a department.
       Q.    Is it part of a division or department?
       A.    No.
       Q.    What is the function of the Office of
Communications?
       A.    We are the arm of the district which deals
with public relations and communications with the
public.
       Q.    And what is your job description?
       A.    I'm the professional administrative
support person for my department.
       Q.    And what responsibilities do you have in
that role?
       A.    You need all of them?
       Q.    Yes.
       A.    I take care of the budget for the
department.  I take care of computer needs.  I take
care of policies and procedures inter-departmental.
             I would say that's in general.
       Q.    How long have you been in that role?
       A.    Almost a year.

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       Q.    You had other positions at the water
management district?
       A.    Yes.
       Q.    And what positions?
       A.    Administrative secretary.
       Q.    In what division?
       A.    Office of Communications.
       Q.    And how long were you administrative
secretary?
       A.    Six months.
       Q.    Any other position at the water management
district?
       A.    None.
       Q.    Who is your supervisor in the Office of
Communications?
       A.    Cathy Anclade.
       Q.    Do you have any employees that work for
you in the Office of Communications?
       A.    No.
       Q.    What use do you make of computers in your
job in your Office of Communications?
       A.    I use the computer to track our budget
needs and to write documents for basically letters.
And also our mailing lists are kept on the computer
system.

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       Q.    What computers, computer systems, do you
use?
       A.    I use an IBM PC, which has the Label Flex
system, which is where our mailing lists are at.
       Q.    Do you use any other computers?
       A.    The Xerox 6085.
       Q.    Any others?
       A.    No.
       Q.    What work do you do on the Xerox 6085?
       A.    There we're able to do tables easier, so
we use it for that.  And it has Free Form, so we're
able to design pages on that.
       Q.    Do you do work other than the mailing
lists on the IBM PC?
       A.    That's where I do my letters, that's where
I do anything written, I do on my IBM PC.  That's where
I track my budget.
       Q.    What software packages do you use on the
IBM PC?
       A.    Word Perfect 5.1, Label Flex, and it's
hooked up to the VAX so that I can send information.
       Q.    Do you also retrieve information from the
VAX?
       A.    If someone sends me something or when I
have to access the Label Flex system, that's--I believe

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it's through the VAX.
       Q.    And what software packages do you use on
the Xerox 6085?
       A.    I'm not sure.  Whatever's the basic.
       Q.    You indicated you use the Xerox 6085 to
create tables for reports or documents you write?
       A.    We use--whenever we need to keep track of
a long list and we need it in a table form, we usually
do it on the 6085.
       Q.    What procedure do you use for creating a
document on your PC?
       A.    I don't understand.
       Q.    What do you do when you sit down at the PC
and you want to create a document; what steps do you
take?
       A.    Using Word Perfect 5.1, you turn it on,
you ask for a blank page, start typing.
       Q.    When you want to store documents that
you've created on the IBM PC, what are the steps?
       A.    I store them on disks.
       Q.    Do your disks have names?
       A.    Most of them.
       Q.    Do you have a list of the disks that you
have?
       A.    No.

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       Q.    Do you transfer documents you've created
to other offices within the water management district?
       A.    At times.
       Q.    What procedure do you use to transfer
those documents?
       A.    I usually put them on a disk and hand them
to the person who's requesting it.
       Q.    In your work with communicating with the
public, do you create any documents on water quality
issues?
       A.    No.
       Q.    What is the sort of documents you would
create that are used to communicate with the public?
       A.    Usually if someone has written in a letter
with a question or a concern, we respond to the letter.
And also, we write our speeches.
       Q.    Do you ever write speeches regarding water
quality questions?
       A.    No.
             MS. NASH:  I have no further questions.
                       CROSS EXAMINATION
BY MR. RICHARDS:
       Q.    Miss Corey, my name's Joe Richards.  I
represent the Cities of Belle Glade and Clewiston.
             Do you create any documents relating to

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the everglades SWIM plan?
       A.    No.
       Q.    Have you written any speeches or drafted
any speeches on your computer relating to the
everglades SWIM plan?
       A.    No.
       Q.    Does your office generate public notices
for the district?
       A.    No.
       Q.    Where would those public notices be
created?
       A.    I don't know.
       Q.    Do you know?
       A.    (Witness shakes head.)
             MR. RICHARDS:  I don't have any further
       questions.  Thank you.
             (Whereupon, the deposition was concluded
       at 3:27 p.m.)