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 BILL HALL, THE WITNESS, TAKEN ON BEHALF OF THE PLAINTIFFS - - - - - - - - DATE: August 9, 1990 PROFESSIONAL REPORTING SERVICE Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 2 1 I N D E X 2 3 August 9, 1990 DIRECT CROSS 4 5 BILL HALL 6 7 By Ms. Nash 5 8 9 10 August 10, 1990 11 12 By Mr. Richards 114 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 3 1 The deposition of BILL HALL, the witness, in the 2 above-entitled and numbered cause, was taken before me, 3 DONNA McCALLEY, Registered Professional Reporter, and 4 Notary Public for the State of Florida at Large, at 5 Suite 110, 324 Datura Street, in the City of West Palm 6 Beach, County of Palm Beach, in the State of Florida, 7 beginning at the hour of 9:58 a.m., on Thursday, the 8 9th of August, 1990, pursuant to the Notice in said 9 cause for the taking of said deposition, which is 10 annexed to the court file herein, on behalf of the 11 Plaintiffs in the above-entitled action pending in the 12 above-named court. 13 The appearances at said time and place 14 were as follows: 15 UNITED STATES DEPARTMENT OF JUSTICE Room 868, 601 Pennsylvania Avenue, N.W. 16 Washington, D.C. 20044-0663 Attorneys for the Plaintiffs, U.S.A. 17 By BEVERLY SHERMAN NASH, ESQ. 18 PEEPLES, EARL & BLANK, P.A. Suite 3636, Two South Biscayne Boulevard 19 Miami, Florida 33131 Attorneys for the Cities of Belle Glade 20 and Clewiston By JOSEPH RICHARDS, ESQ. 21 SKADDEN, ARPS, SLATE, MEAGHER & FLOM 22 1440 New York Avenue, N.W. Washington, D.C. 20005-2107 23 Attorneys for the South Florida Water Management District 24 By DON JOAQUIN FROST, JR., ESQ. KATHARINE STOLLMAN, ESQ. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 4 1 APPEARANCES CONTINUED: 2 SOUTH FLORIDA WATER MANAGEMENT DISTRICT 3301 Gun Club Road 3 West Palm Beach, Florida 33416-4680 By JACQUELYN L. WATERS, ESQ. 4 CHARRON FOLLINS 5 ALSO PRESENT: John A. Davis, Ph.D. Frank Draughn 6 David Buker Robert Johnson 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 5 1 THEREUPON: 2 BILL HALL, 3 having been first duly sworn, as hereinafter certified, 4 testified as follows: 5 DIRECT EXAMINATION 6 BY MS. NASH: 7 Q. Okay, we are here for what is called a 8 30(b) deposition. This is a deposition where we are 9 inquiring about certain categories of information that 10 the water management district has to understand how the 11 water management district's computer systems operate, 12 how people communicate with each other in the district 13 using computers, what kind of data is stored on the 14 computers, and how that data is formatted. 15 Mr. Hall, you've been submitted as a 16 representative of the water management district having 17 knowledge concerning one or more of nine categories of 18 inquiry that we have submitted to your attorneys on the 19 South Florida Water Management District computer 20 systems and their comments. Have you been shown that 21 list of categories? 22 A. Yes, I have. 23 Q. For which categories are you being 24 submitted as the knowledgeable person; do you know? 25 A. I have some knowledge in almost all of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 6 1 categories. I don't really know which in particular 2 I'm designed to be the only representative for. 3 Q. Then we'll go through all of the 4 categories. 5 What is your present title or position? 6 A. Director of computer management. 7 Q. Is that in a particular division or 8 department? 9 A. It is a division, the division of computer 10 management, of which I am the director. 11 Q. What is your job description? 12 A. To obtain, acquire, set up, operate and 13 maintain all computer systems within the South Florida 14 Water Management District, including training, 15 applications, development, and interoperability of all 16 district computer systems. 17 Q. What was that last term? 18 A. Interoperability. 19 Q. Would you explain what "interoperability" 20 means, please. 21 A. The ability to make different vendors' 22 computer systems operate across a network to exchange 23 data and produce common results. 24 Q. How long have you been in the role of 25 director of computer management? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 7 1 A. Ah, I was appointed to the position June 2 1st, 1984. 3 Q. Have you had other positions at the water 4 management district? 5 A. I have had--have had other positions, yes. 6 Q. What positions have those been? 7 A. Starting approximately June 1973, I was 8 hired as a night computer operator part-time. In 9 approximately July of '75, I was promoted to 10 applications programmer I. 11 In approximately 1976, I was promoted to 12 the systems programmer I. And somewhere between there 13 and 1983, was promoted to a systems programmer II, and 14 finally, systems programmer III. 15 Q. What is a systems programmer I? 16 A. It's a position responsible for the 17 development and installation of operating systems and 18 communications problems on multiple computer systems. 19 Q. How does that differ from a systems 20 programmer II? 21 A. A systems programmer II position has the 22 same, as well as additional, requirements placed on it 23 for being a high level--higher level position requiring 24 more experience and supervision. 25 Q. Is the job function the same? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 8 1 A. Yes. 2 Q. And what about system programmer III? 3 A. Again, additional responsibilities of a 4 systems programmer II, additional years of experience 5 required. 6 (Whereupon, Ms. Waters entered the 7 deposition room.) 8 A. (continuing) And additional supervisory 9 responsibilities added. 10 MS. NASH: Note for the record an addition 11 to the room, please. 12 BY MS. NASH: 13 Q. Mr. Hall, what's your educational 14 background? 15 A. High school degree, bachelor's degree in 16 computer systems with the business and scientific 17 option from Florida Atlantic University. 18 Q. What year was that? 19 A. 1975. 20 Q. Have you had any additional formal 21 education in the computer area? 22 A. Other than continuing education on 23 specialized products, the answer is no. 24 Q. To whom do you report in the water 25 management district? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 9 1 A. To the director of technical services. 2 Q. Who is the director? 3 A. John T. Lynch, Jr. 4 Q. How many employees of the district do you 5 have working for you? 6 A. There are 29 employees within my division 7 directly or indirectly responding to me. 8 Q. Generally what are their job descriptions? 9 MR. FROST: You mean--what do you mean by 10 "generally"? 11 BY MS. NASH: 12 Q. Well, I don't need a description--if there 13 are six computer operators, I don't need each one 14 described separately. Just by category, if there are 15 categories of employees within your division. 16 A. Okay, we have an assistant division 17 director. 18 Q. Who is that? 19 A. Robert Mann, M-a-n-n. Two supervising 20 senior systems analysts, one application supervisor, 21 one senior systems analyst, two systems analysts, one 22 mainframe data base analyst, one technical instructor, 23 one micro computer applications developer. 24 I'm not certain of the counts here, but I 25 believe three applications developers, one senior PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 10 1 computer systems technician, four computer system 2 technicians, one senior electronics engineer. I'm not 3 positive if that title includes the word "engineer." 4 One electronic technician--and excuse me, the previous 5 title didn't include "engineer." It was senior 6 electronic technician, not engineer. 7 One operations supervisor, and four 8 mainframe computer operators, one administrative 9 assistant, and one administrative secretary. 10 That's the best I can recall at this 11 point. 12 Q. What are the computers that are used at 13 the water management district, starting with the 14 mainframe? 15 MR. FROST: You're directing this to the 16 mainframe, this first question? 17 MS. NASH: This first question is directed 18 to the mainframe or frames. 19 MR. FROST: Okay. 20 A. There's a slight gray area on what is the 21 mainframe and what is a smaller system. I'm 22 categorizing two of our systems as mainframes, and 23 those are an IBM 4361 Model 5MO, IBM mainframe, and a 24 Cyber--that's spelled C-y-b-e-r, 830 mainframe. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 11 1 BY MS. NASH: 2 Q. Do you have additional systems that you 3 would not call mainframes other than mini computers or 4 micro computers and PC's? 5 A. No. I don't have any other systems that I 6 would call mainframes that are not one of those. 7 Q. What operating system or systems do you 8 use on the IBM 4361? 9 A. IBM VSE/SP Version 4.1. 10 Q. Any others? 11 A. On the IBM? 12 Q. On the IBM. 13 A. No. 14 Q. And what operating system or systems do 15 you use on the Cyber 830? 16 A. Two operating systems: CDC NOS, spelled 17 N-O-S, and I do not know the current release, and CDC 18 NOS, NOS/VE. Again, I do not know the current release. 19 Q. What are the various software packages 20 that are used on the IBM 4361? 21 A. There are system utilites acquired from 22 IBM to make the system functional, and outside of 23 those, we have MSA software performing our financial 24 business for the district, as well as a number of 25 third-party software packages designed to maintain the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 12 1 financial data files' backups and performance of the 2 system. 3 Q. Can you name those third-party software 4 packages? 5 A. Yes. We have four modules from 6 Goals--that's G-o-a-l-s, Systems, designed to help tune 7 VCN files. I believe the names are VSAM--that's 8 V-S-A-M, AIDS, A-I-D-S. I believe the second one's 9 called HYPER, H-Y-P-E-R. Third one is called FAVOR. 10 And I can't remember the name of the fourth one. All, 11 again, are related to backing up or file tuning. 12 We also have computer associates DUN M/T. 13 I believe the spelling is D-U-N M/T, or close to it. 14 Q. And what is that software package used 15 for? 16 A. That software package is used to compress 17 data files for backup to magnetic tape--or excuse me, I 18 described the previous package. That package-- 19 MR. FROST: Can you clarify which package 20 you're talking about? 21 BY MS. NASH: 22 Q. The DUN M/T. 23 A. The DUN M/T is used to keep track of all 24 the magnetic tapes and IBM 3480 cartridges being used 25 on the IBM system. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 13 1 Q. And which package were you describing when 2 you said one was used to compress data files? 3 A. That was FAVOR that compresses data files 4 when they're being backed up to magnetic tape or 5 cartridges, and, of course, depresss them when they're 6 copied back down. 7 Q. What input and output peripherals are 8 there on the IBM 4361? 9 MR. FROST: I object. That's a compound 10 question. Can we do it--do one or the other? 11 BY MS. NASH: 12 Q. What input peripherals are there on the 13 IBM 4361? 14 A. A series of IBM S and A terminals 15 operating through several communications controllers, 16 as well as a number of 3370 disk drives from IBM, and 17 one controller and disk drive from Storage Tek, 18 S-t-o-r-a-g-e T-e-k, that is IBM 3380 compatible. 19 There are tape drives used for input that 20 are the medium speed inches per second, quantity two, 21 and-- 22 Q. What model tape drives? 23 A. I can't recall the model number, but it's 24 a medium speed nine-track 1600 CPI, 6250 CPI phase 25 encoded group encoded tape drive capable of reading and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 14 1 writing EBCDIC, E-B-C-D-I-C, data. 2 In addition-- 3 MR. FROST: I don't believe we have a 4 question. 5 THE WITNESS: I'm still doing the input 6 devices. 7 MS. NASH: He's going through the input 8 peripherals. 9 MR. FROST: You're asking him now to 10 continue? 11 MS. NASH: Just continue, yes. 12 MR. FROST: Okay. 13 A. In addition, we have an IBM 3490 cartridge 14 tape system composed of two drives with IDRC 15 capability. 16 BY MS. NASH: 17 Q. Explain what IDRC capability is. 18 A. The initials IDRT--I--excuse me, IDRC 19 stand for improved data recording capability. And it 20 is a compression/decompression capability for 21 compressing the 200 megabytes of data that would 22 normally fit on a 3480 cartridge up to approximately 23 one gigabyte, G-i-g-a-b-y-t-e. 24 Q. You indicated a number of IBM S and A 25 terminals. What is that number? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 15 1 A. I believe we have 39 IBM terminals, most 2 of which are IBM 3191 models. 3 Q. Are those 39 IBM terminals located in one 4 location or throughout offices in the water management 5 district? 6 A. The terminals are located in multiple 7 offices within our headquarters building, as well as 8 within two trailers at the headquarters' location. 9 Q. Are there particular divisions or 10 departments that have these IBM terminals? 11 MR. FROST: Can you ask for division or 12 departments? 13 BY MS. NASH: 14 Q. Yes. 15 Either, either special divisions or 16 departments, that have these IBM 3191 terminals. 17 A. Yes. 18 Q. Which divisions and departments are those? 19 MR. FROST: Can you break that in two 20 questions? 21 BY MS. NASH: 22 Q. Which divisions are those? 23 A. There are terminals located in the 24 division of computer management, the division of 25 procurement and contract administration, the division PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 16 1 of financial services, the division of accounting, and 2 the division of personnel. 3 Q. Are there departments within the water 4 management district that have some of these IBM 3191 5 terminals? 6 A. I'm sorry, I didn't hear the question. 7 Q. Are there departments that also have some 8 of these IBM terminals you've been describing? 9 A. Yes, divisions are part of departments, so 10 the division--excuse me, the department of finance and 11 administration has terminals, and the department of 12 technical services has terminals. 13 Q. You testified that these terminals operate 14 through several communications controllers. What model 15 are those and how--well, first, what model are those? 16 A. An IBM 3274 communications controller, and 17 an IBM 3174 communications controller, as well as the 18 communications adapter located on the IBM 4361. 19 Q. You testified to a number of 3370 IBM disk 20 drives. How many 3370 IBM disk drives are there? 21 A. I believe the count is five. It could 22 possibly be six, but I am pretty sure it's five. 23 Q. Are there any other input peripherals that 24 you've not yet described for the IBM 4361? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 17 1 Q. What are those? 2 A. There is a protocol converter incorporated 3 1076 device hanging off the IBM 4361, as well as a DEC 4 NET--that's D-E-C N-E-T, /SNA gateway attached to the 5 IBM 4361. 6 Q. What is the function of the protocol 7 converter 1076 device? 8 A. It allows asynchronous terminals to 9 operate through an SDLC line from the communications 10 adapter on the 4361. 11 Q. What is a SDLC line? 12 A. That is an IBM term for the type of 13 communications line that they handle in their S and A 14 definition. I'm not certain of the exact words that 15 are associated with SDLC. 16 Q. What function does the DEC NET/SNA gateway 17 serve? 18 A. It permits devices that have connected to 19 an IBM--excuse me. It--it permits devices connected to 20 the DEC--that's D-E-C, 6310 to connect to the IBM 4361 21 as a terminal circuit. In addition, it permits the 22 routing of batched jobs called RJE to the IBM 4361, and 23 accepts printouts from the IBM 4361 to the DEC 6310. 24 Q. Are there other input peripherals that 25 you've not yet described? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 18 1 MR. FROST: Can you clarify that as far as 2 what system we're talking about? 3 BY MS. NASH: 4 Q. On the IBM 4361. 5 A. No, there's no other devices for doing 6 input to the IBM system other than unused SDLC lines. 7 Q. What are the output peripherals for the 8 IBM 4361? 9 A. There are a series of hard copy devices. 10 An IBM 3262 printer, quantity two. There's two of 11 those. A Xerox 4050 lazer printer. And all the 12 previous input devices are also capable of being output 13 to that we mentioned previously. Plus, there is one 14 4224 dot matrix printer from IBM, as well. 15 Q. Where are the printer devices located? 16 A. One 3262 is located in the computer room 17 where the 4361 is located. The other 3262 is located 18 in the division of financial services. The Xerox 4050 19 is located in the computer room with the IBM 4361. The 20 IBM 4224 dot matrix printer is located in the division 21 of procurement and contract administration. 22 Q. What communications capabilities does the 23 IBM 4361 have? 24 A. The 4361 has a communications adapter 25 capable of handling synchronous lines up to 9600 bytes PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 19 1 per second. I believe it can be expanded up to eight. 2 At present, I believe we have three. 3 MR. FROST: I object. 4 Are you--do you know that it can be 5 expanded to eight? 6 THE WITNESS: No, I do not. 7 MR. FROST: Oh. 8 A. (continuing) We have a IBM--an IBM, 9 rather, 3720 communications controller that is channel 10 attached capable of driving devices at up to 56,000 11 bytes per second, and our 3174 and 3274 IBM 12 communications controllers are connected to that 13 device. 14 In addition, the DEC NET/SNA gateway is 15 attached directly to the communications adapter and to 16 the IBM 3720 communications controller, terminal lines 17 connected to the 3174, 3274, as well as to the 18 communications adapter on the 4361. 19 Q. What data is stored or processed through 20 the IBM 4361? 21 A. The data stored on the IBM 4361 is 22 financial in nature only, containing information on 23 general lev--general ledger, accounts payable, 24 inventory, budget, and fixed assets. 25 Q. Whose decision was it to use the IBM 4361 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 20 1 just for financial data? 2 A. It was part of the recommendation of the 3 consultant Quad, Q-u-a-d, Corporation to acquire and 4 use the predecessor of the IBM 4361 for financial 5 information only. 6 Q. When was this recommendation made? 7 MR. FROST: Object to this line of 8 questioning. What's the relevance to this 9 lawsuit of who made determinations of what 10 computer system should be used for financial 11 information? 12 MS. NASH: It's brief background 13 information, will not go on. 14 You can answer the question. 15 A. In the fourth calendar quarter of 1983, 16 the IBM 4331 computer system was acquired as a result 17 of the Quad recommendation. 18 BY MS. NASH: 19 Q. When was the IBM 4361 acquired? 20 A. I'm sorry, could you repeat the question? 21 Q. When was the IBM 4361 acquired? 22 A. The IBM 4361 was actually upgraded from a 23 4331 in approximately 1987. 24 Q. Moving now to the Cyber 830 mainframe. 25 What operating--what software is used on PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 21 1 the Cyber 830? 2 A. There is a series of three GL development 3 tools, namely COBOL, Fortran, DMS 170 preprocessor 4 available for use by any of the users. 5 In addition, there are a number of 6 application and statistical packages available for any 7 user. These include SPSS, BMDP, SIR, IMSL, SCA, Plot 8 10 Graphics Libraries, Techtronics Graphics Libraries, 9 and I can't recall any other general application 10 packages available at this time. 11 There is also other development tools from 12 Control Data Corporation, including DMS 170 data base, 13 and utilites for driving the appropriate communications 14 devices attached to the Cyber 180/830 system. 15 Q. What does SBSS (sic) do? 16 A. SPSS is a statistical package that accepts 17 tabular data and allows you to perform statistics and 18 aggression analysis on the sample data. 19 Q. And what does VMDP do? 20 A. I'm sorry, I am not familiar with VMDP. 21 Q. I believe that was the second package 22 mentioned. 23 A. Excuse me, BMDP. 24 Q. I'm sorry, was it B? 25 A. Biomedical-- PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 22 1 Q. BM, okay. 2 A. I believe the term, the name for the 3 package, though everybody knows it as BMDP, I believe 4 that it's an acronym for Biomedical Data Processing, 5 though I'm not positive that's the exact title. 6 BMDP is a statistical package, also 7 capable of accepting tabular text data and performing 8 certain curve-fitting and random analysis testing on a 9 given set of data. 10 Q. What does SIR do? 11 A. SIR is a data storage and statistical 12 analysis package, also. It accepts data from a tabular 13 form into the SIR, which is S-I-R, data base format, 14 and then permits analysis on that data. 15 Q. IMSL package, what does that do? 16 A. IMSL is a series of subroutines for--for 17 performing statistical analysis and must be called from 18 a Fortran program. 19 Q. What does SCA do? 20 A. SCA is also a statistical analysis sub 21 system commonly referenced from Fortran by setting up a 22 set of data and submitting it for analysis. 23 Q. What does the Plot 10 Graphics Library do? 24 A. It's used from Fortran calls to represent 25 data in a graphical form on an output device. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 23 1 Q. And the Techtronics Graphics Library, what 2 does that do? 3 A. It's a series of Fortran COBOL subroutines 4 used to display data in a graphics form on terminals. 5 Q. What are the input peripherals on the 6 Cyber 830? 7 A. The Cyber has a single front end called 8 CDC NET that handles all input communications used for 9 both synchronous and asynchronous data. That's the 10 only input device external to the computer system. 11 Q. What output peripherals are on the Cyber 12 830? 13 A. Internal to the machine, it has a data 14 channel converter, commonly known as DCC, that permits 15 lower 3,000 peripheral devices to be operated. Running 16 off the DCC, we have one CDC 580-12 chain line printer 17 for output. 18 In addition, the CDC NET drives output 19 devices, typically terminals. I'm repeating that, 20 typically terminals. 21 Q. How many terminals are driven off the CDC 22 NET on the Cyber 830? 23 A. The CDC NET is wired to Ungermann-Bass, 24 U-n-g-e-r-m-a-n-n B-a-s-s, network interface units 25 that can be attached from any PC or terminal anywhere PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 24 1 along the network within the district. 2 Forty-eight lines are provided, and 3 normally all forty-eight are hooked up. From time to 4 time, we reduce that--excuse me, 32 lines are normally 5 driven, and we reduce that from time to time. When the 6 net--network interface units are required elsewhere, we 7 borrow them from the system and reduce it by eight 8 lines for each network interface unit. If all are 9 available, it has 32 lines. 10 Q. Where are the terminals or PC's located 11 that connect along this network you've been describing? 12 A. Throughout pretty much all divisions and 13 departments, terminals or PC's are located, as well as 14 anywhere the network goes, which includes our field 15 stations. 16 Q. You mentioned network interface units that 17 might be required elsewhere. Would you describe those 18 network interface units? 19 A. The network interface unit, normally 20 referred to as NIU 180, from Ungermann-Bass Corporation 21 has eight asynchronous ports and can be hung anywhere 22 along the Ethernet network where it is needed, and then 23 up to eight devices can be attached to the NIU 180. 24 Most district employees simply refer to the device as 25 an NIU. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 25 1 Q. What are some of the locations or what are 2 the locations where these--you indicated these--the 3 network interface units might be required elsewhere. 4 Where is--would you define "elsewhere"? 5 MR. FROST: Could you repeat the question? 6 MS. NASH: Yes. He indicated in his 7 previous testimony that these network interface 8 units could be required elsewhere and that would 9 reduce the number of lines by eight, and I'm 10 inquiring as to what, where "elsewhere" is. 11 MR. FROST: Okay. 12 A. Occasionally, due to malfunction or 13 lightening strikes, an NIU will be in need of repair 14 within the district's headquarters, and due to the fact 15 that there's 32 lines on the Cyber, we borrow NIU's 16 while one is being repaired to supplement the terminals 17 that are down as a result of an NIU malfunction. We 18 have them located in our headquarters' building, as 19 well as at a building we refer to at Congress--as 20 Congress Park, and a building we refer to as Congress 21 Avenue. At present, that is the only locations where 22 NIU 180's are located. 23 Excuse me, there may be one in the Fort 24 Myers district office. I know we had located one there 25 on the network. I don't know if it's still there or PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 26 1 if--or if it's returned to the headquarters building. 2 Q. What areas outside of headquarters are 3 included on the network that can access the Cyber 830? 4 A. I'm sorry, could you repeat the question? 5 Q. Yes. 6 What locations outside of headquarters are 7 on the network that can access the Cyber 830? 8 MR. FROST: Are you asking him which ones 9 are on the network or one which one they can 10 access? 11 BY MS. NASH: 12 Q. I'll make it two questions, then. 13 What locations outside of headquarters are 14 on the network? 15 A. Okay. 16 The locations outside the district that 17 are networked, "networked" being defined as Ethernet, 18 are: Congress Avenue, Congress Park, Homestead field 19 station, Miami field station, Fort Lauderdale field 20 station, Clewiston field station, Okeechobee field 21 station, Kissimmee field station, Big Cypress field 22 station, S5A pump station, Fort Myers office, Kissimmee 23 office, and Okeechobee SWIM office. 24 Those are all the locations that are 25 networked with Ethernet outside of the headquarters PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 27 1 complex. 2 Q. What computer capabilities does being on 3 the Ethernet network give the various locations that 4 you mentioned? 5 MR. FROST: Could we break that up? 6 BY MS. NASH: 7 Q. Let me ask first, is--do the various--you 8 mentioned approximately a dozen locations. Do those 9 locations have different computer capabilities from the 10 Ethernet network, or is the--are the capabilities all 11 the same? 12 A. The capabilities at all of those locations 13 are that they are networked, and any device at that 14 location can communicate with any other device at the 15 headquarters or on the network. 16 And you had a second question, but I don't 17 quite recall it. 18 Q. Would be the more specific question then 19 is: What then is the computer capability at each of 20 the locations? I guess we'll go through them one by 21 one. At Congress Avenue? 22 MR. FROST: So your question is--what is 23 your specific question now? 24 BY MS. NASH: 25 Q. What is the computer capabilities at the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 28 1 Congress Avenue location? 2 MR. FROST: Okay. 3 A. At Congress Avenue, there are 4 approximately 50 personal computers and some number of 5 terminals. I don't know exactly how many. As well as 6 some NIU's that--excuse me, those terminals are 7 attached by NIU's, but as well as at least one Xerox 8 word processing unit. 9 BY MS. NASH: 10 Q. Through the PC's at Congress Avenue, can 11 district employees access the Cyber 830 computer? 12 A. Yes, they can access it. 13 Q. What computer facilities or capabilities 14 are there at Congress Park? 15 MR. FROST: Didn't you already ask that 16 question? 17 THE WITNESS: No, she said Congress 18 Avenue. 19 MR. FROST: Okay. 20 A. At Congress Park, there is very much the 21 same computer equipment as Congress Avenue: 22 Approximately 40 personal computers, approximately 23 eight Xerox word processing work stations, and a number 24 of terminals, period. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 29 1 BY MS. NASH: 2 Q. What make and model are the PC's at 3 Congress avenue? 4 A. They can be IBM XT's, IBM XT 286, IBM AT 5 PS 2-30/286, IBM PS2 Model 60, PS2 IBM Model 70, or IBM 6 PS2 Model 80. 7 Q. What make and model of PC's are there at 8 Congress Park? 9 A. The same as Congress Avenue. 10 Q. What computers are there at the Homestead 11 field station? 12 A. Normally IBM XT's only at present, though 13 if a system were to break, sometimes we would 14 substitute with one of the other IBM machines during 15 repair. 16 Q. Do you know how many? 17 A. Quantity two at present. 18 Q. What are the computer devices at the Miami 19 field station? 20 A. The same, quantity two IBM XT's, though 21 substitutes occur from time to time on a temporary 22 basis. 23 Q. What computer facilities are there at the 24 Fort Lauderdale field station? 25 A. Two IBM XT's with occasional substitutes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 30 1 Q. And at the Clewiston field station? 2 MR. FROST: What is the question? 3 BY MS. NASH: 4 Q. What are the computer devices at the 5 Clewiston field station? 6 A. Two IBM XT's. 7 Q. What are the computer devices at the 8 Okeechobee field station? 9 A. I believe they have three IBM personal 10 computers. Two, I know, are IBM XT's. I don't know if 11 the third machine is an XT or a faster machine. 12 Q. What are other computer devices at the 13 Kissimmee field station? 14 A. Two IBM XT's. 15 Q. And what are the computer devices at Big 16 Cypress field station? 17 A. It was one IBM XT, but they may have 18 expanded already to two. 19 Q. What computer devices are at the S5A pump 20 station? 21 A. Two IBM XT's. 22 Q. What computer devices are at the Fort 23 Myers office? 24 A. At present, I believe there's six personal 25 computers. Five, I believe, are IBM XT's, and one is PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 31 1 an IBM AT. There was and I still believe is an NIU 180 2 device that drives several terminals. 3 Q. What are the make and model of those 4 terminals? 5 A. DEC 320 asynchronous terminals. 6 Q. What computer devices are at the Kissimmee 7 office? 8 A. In the Kissimmee office, I believe there's 9 either three or four IBM XT's, as well as an IBM AT 10 personal computer. 11 Q. What computer device are at the Okeechobee 12 SWIM office? 13 A. At the Okeechobee SWIM office, there's a 14 Xerox word processing unit with an output device, and 15 approximately three or four IBM PS2 Model 30's. 16 Several of these numbers I'm having to 17 tell you approximately, because on a daily base--basis, 18 they change. 19 Q. For what reasons do the numbers change? 20 A. Typically--typically someone is moved to 21 the office or from the office or an additional 22 responsibility is transferred from one office to 23 another and a form submitted to say that we've--I 24 should say they have moved the personal computer to a 25 new location. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 32 1 Q. Are there any other locations outside of 2 headquarters where the water management district has 3 computer facilities? 4 A. Yes. 5 Q. Where would those be? 6 A. Some asynchronous cables are extended from 7 the district's NIU at Congress Avenue to some 8 non-district devices located in the DER facility at the 9 same location. 10 In addition, the district owns some 11 statistical multiplexors and CSU/DSU's that extend 12 communications lines from the district's headquarters 13 to USGS in Miami. 14 In addition, there are some personal 15 computers located at department directors' or executive 16 off--office personnels' homes with modems for 17 connecting in to the district's computer network. 18 Also, there is a terminal device located 19 at some of the opera--excuse me, operations and 20 maintenance departments' hydrologists for purposes of 21 calling in to district's telemetry system. 22 Q. Where are the locations of those 23 operations and maintenance departments? 24 A. The operations and maintenance department 25 is located at the district's headquarters complex, and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 33 1 the selected hydrologists that are on call for 2 regulating the gate positions have terminals at their 3 homes. I believe we're talking two terminals here. 4 Q. Back to the-- 5 MR. FROST: You okay? Do you need to take 6 a break for anything? 7 MS. NASH: You want to take a break? I 8 could actually use a pit stop, so-- 9 MR. FROST: Okay. 10 (Short break.) 11 (Whereupon, Ms. Waters left the deposition 12 room.) 13 BY MS. NASH: 14 Q. Mr. Hall, does the Cyber 830 have other 15 communications capabilities that allow access by 16 outside users besides the network that you've been 17 describing? 18 A. Ah, that's a difficult question to answer 19 the way you worded it. I can't answer yes or no. 20 MR. FROST: Can you go ahead and try to 21 clarify what you're asking? 22 BY MS. NASH: 23 Q. What I am--let me rephrase that. 24 A researcher doing work for the water 25 management district, if they were not part of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 34 1 Ethernet network that you've been describing, could 2 they still access data on the Cyber 830? 3 MR. FROST: I would object to that as 4 being speculative, unless you can answer to the 5 extent that it happened or that system is 6 capable of that. 7 MS. NASH: Well-- 8 A. The system is not capable of being 9 accessed other than through the CDC NET. 10 BY MR. NASH: 11 Q. Are there networks other than the Ethernet 12 through which you can access the Cyber 830? 13 A. Yes. 14 Q. What are those other networks? 15 A. Any device that can interface to the CDC 16 NET is capable of accessing the Cyber. 17 Q. What data is stored on the Cyber 830? 18 A. It would take a long time to attempt to 19 describe all the data, and some of the data is really 20 only known by selected users. But to answer in a 21 general fashion: Water level data, rainfall data, 22 water conductivity data, discharge data--referring to 23 quantities--are stored on the Cyber, as well as data 24 that individuals elect to put under their user numbers 25 on the Cyber. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 35 1 There's a lot of data that it would take 2 the individual running that system to be able to 3 properly describe. But there is probably 500, maybe 4 more, accounts, and those have an allocation of disk 5 space for that particular user to store the data that's 6 relative to their work. 7 Also, there's mag tapes used by the Cyber 8 that can contain historical data. And again, the owner 9 of those tapes would know the content data. I or 10 individuals in our division would simply know the owner 11 of the tape and whatever description they decide to 12 call their data. 13 That's about the best description I 14 give--can give for the data on the Cyber other than to 15 say it's where a majority of the historical data is 16 stored. 17 Q. Are there any logs or other form of 18 documentation that would indicate--for example, the 19 lists of magnetic tapes and who the owner of the tapes 20 is or are and what's on those tapes, as well as what's 21 stored directly on the computer? 22 MR. FROST: That--I'm confused at what 23 question you're actually asking. 24 BY MS. NASH: 25 Q. Is there a log or other documentation that PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 36 1 would contain information relating to what is on the 2 computer and the tapes that Mr. Hall has been 3 describing? 4 A. Okay. The question's becoming a little 5 bit too broad to answer. There are logs referring to 6 data stored on tapes. 7 Q. Do those logs have a name or a way of 8 referencing it? What is that name? 9 A. The-- 10 MR. FROST: Go ahead and answer the first 11 question. You can answer it verbally. 12 A. Could you repeat the question? 13 BY MS. NASH: 14 Q. My first question is do--does the log have 15 a name? 16 A. Yes. 17 Q. And what is that name? 18 A. Mag tape user list for the Cyber system. 19 Q. Is there a comparable list for what is 20 stored directly on the Cyber 830? 21 A. Yes. 22 Q. Does that list have a name? 23 A. Yes. 24 Q. What is its--what is that name? 25 A. There is a list that is maintained of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 37 1 backup of all files currently located on the Cyber 2 disks. I'm trying to give a precise name to it here. 3 The PF DUMP listing for any given week of 4 Cyber users sorted in user number order contains a list 5 of the files that were backed up to magnetic tape and 6 are maintained for a minimum of three months. 7 Q. Are any--is any of the data on the Cyber 8 or its disks or tapes password protected or otherwise 9 protected? 10 MR. FROST: Will you break that up? 11 BY MS. NASH: 12 Q. That's a general question first, and then 13 I will break it down. 14 A. Yes. 15 Q. Is the historical data you've been 16 describing that's on the magnetic tapes password 17 protected? 18 A. I can't really say yes or no, so I'm gonna 19 say sometimes. Or I guess I should say in some cases, 20 yes. 21 Q. Do you know the nature of the material 22 that's password protected? 23 MR. FROST: What do you mean by "nature"? 24 Do you understand what--what you're being 25 asked? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 38 1 THE WITNESS: No, the question doesn't 2 relate to the passwords at all. 3 BY MS. NASH: 4 Q. Do you know which files on magnetic tapes 5 are password protected? 6 A. Yes. 7 Q. What files are those? 8 A. All files that are in labeled format may 9 have a password, and you don't know they do or do not 10 until you reference it. 11 Q. You indicated the data on the Cyber disks, 12 that some of that data is also password protected; is 13 that correct? 14 A. I'm gonna try to answer that, not 15 answering your question, but just saying all data on 16 the Cyber disks is password protected. 17 Q. Let' move on for the moment to the mini 18 computers that are located at the--or that are utilized 19 by the water management district. 20 Can you describe what mini computers there 21 are? 22 A. Okay. We have a VAX--that's V-A-X, 8820 23 computer system, a VAX 6310 computer system. We have a 24 Perkin Elmer mini computer. We have a Computer Vision 25 mini computer. We have two micro VAX II--excuse me, PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 39 1 three micro--Micro VAX II mini computers. And that's 2 all the mini computers we presently have at the 3 district. 4 Q. Are there other mini computers used or 5 accessible to water management district employees that 6 are not located at the district? 7 A. I'm sorry, can you repeat? 8 Q. Are there other mini computers that are 9 used by water management district employees-- 10 A. Yes. 11 Q. --that are not in the seven mini computers 12 you've described? 13 A. Yes. 14 Q. Where are those other mini computers 15 located? 16 A. There are computer systems located in 17 Tallahassee that are referenced by individuals at the 18 district for obtaining information. They are not owned 19 or anything by the district. There are mini computers 20 owned by USGS that contain data that the district 21 accesses and copies down to its own systems. 22 There are legal systems from West 23 Publishing and other firms that the district buys time 24 on for doing legal research. 25 There are commercially-available computer PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 40 1 systems that the district subscribes to to get 2 information on products available by other companies. 3 They're computer systems used for 4 biological--excuse me, bibiological--I can't say that 5 word, bibliography research that are accessed from our 6 reference center, commercially available systems. 7 I cannot think of any other--oops, we also 8 references--reference Barnett Bank's computer system 9 for check-clearing data. 10 We also access University of Miami's 11 satellite data for satellite images. We also have 12 individuals that access University of Florida and 13 Florida State's computer system for accessing data. 14 That's all the outside computer systems 15 that I can think of that the district references. Some 16 may or may not be mini computers. 17 Q. The computer system located in Tallahassee 18 that you mentioned as referenced, where is that system 19 located? 20 A. I do not know. 21 Q. By what device or devices is that system 22 in Tallahassee re--referenced? 23 MR. FROST: Referenced? 24 BY MS. NASH: 25 Q. Yes, or accessed. Accessed or referenced. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 41 1 A. A phone number was obtained from our legal 2 department to call up and get information on 3 leg--legislation, and we access it by phone calls from 4 the district. 5 Q. What is the operating system on the VAX 6 8820? 7 A. VMS 5.O at present. 8 Q. I'm sorry, what is that? 9 A. VMS 5.0 at present. 10 Q. And what is the--what are the software 11 packages available on the VAX 8820? 12 MR. FROST: Could you identify what you 13 mean by "software packages," what you're 14 looking for? 15 MS. NASH: I believe Mr. Hall, if he 16 understood the question, can answer it. 17 A. Are you talking about 18 commercially-available software packages? 19 BY MS. NASH: 20 Q. No, what software is utilized-- 21 A. Okay, utilized. 22 Q. --on the VAX 8820? 23 A. Oracle software, system utilites software, 24 communications software, and external device drivers 25 software. There are also language tools for program PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 42 1 development available to users. 2 Q. Please describe the Oracle software. 3 A. We have purchased Oracle software from 4 Oracle Corporation to store tabular data in a data base 5 format under VMS and have the forms utility, 6 report-writer utility, report utility, SQL*PLUS 7 utility, EASY*SQL utility, and data dictionary facility 8 from Oracle Corporation. 9 Q. What is the function of the systems 10 utilites software? 11 A. To--to allow maximum resource utilization 12 of the DEC system's memory by capturing selected pages 13 of memory to and from disks. 14 Q. And the communications software, what is 15 its function? 16 A. The communications software from multiple 17 vendors permits different types of devices on the 18 network to access and copy files to and from the VAX 19 system. 20 Q. Which vendors do you have communication 21 software for on the VAX 8820? 22 A. DEC, D-E-C, an abbreviation for Digital 23 Equipment Corporation, and Interconnections 24 Corporation. That's all. 25 Q. Who's the vendor for the systems utilites PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 43 1 software that you described that's on the 8820? 2 A. I'm not sure whether it's the vendor's 3 name or the vendor's product name, but we refer to it 4 as IO Express. That may be the name of the company. 5 I'm pretty certain it's the name of the product. 6 Q. What is the function of the external 7 device driver software that you described on the VAX 8 8820? 9 A. To drive DEC lazer printers and 10 Hewlett-Packard lazer printers throughout the complex. 11 Let me see if there's any other. 12 And that's all on the VAX 8820. 13 Q. You mentioned there are language tools for 14 program development available on the VAX 8820. Can you 15 describe those language tools? 16 A. Yes. Fortran C, Pro Fortran, and Pro C, 17 and I guess that's all. 18 Q. What are the input peripherals for the VAX 19 8820? 20 A. A console and an Ethernet interface board, 21 and that's all. 22 Q. What are the output peripherals on the VAX 23 8820? 24 A. The console, the Ethernet network board, 25 as well as an LPS 20 lazer printer accessed through the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 44 1 Ethernet board. 2 That's all. 3 Q. What's the memory capacity on the VAX 4 8820? 5 A. 128 megabytes of real memory. 6 Q. What are the network capabilities of the 7 VAX 8820? 8 A. It is networked through a single Ethernet 9 controller board driving two protocols from DEC 10 interconnections. 11 That's all. 12 Q. Do you know the number of terminals that 13 can access data on the VAX 8820 through the Ethernet 14 network? 15 A. There's really not a physical limit except 16 eventually with too many users, the response time would 17 become unbearable. But the Ethernet board does not 18 limit how many terminal sessions can simultaneously be 19 handled. 20 Q. What are the data files that are stored on 21 the VAX 8820? 22 A. Almost exclusively they are Oracle data 23 files containing tabular data that have been created by 24 the different divisions throughout the district. 25 Q. Who makes the decision whether data files PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 45 1 will be stored on the Cyber 830, for example, as 2 opposed to the VAX 8820 or one of the other mini 3 computers that we'll discuss? 4 A. Okay-- 5 MR. FROST: I--what do you mean by "we'll 6 discuss"? I guess this is a compound question. 7 MS. NASH: Well, let him answer the 8 question if he can answer the question. 9 MR. FROST: Do you recall the question? 10 THE WITNESS: Why don't you restate it, 11 just so I make sure I'm answering correctly. 12 BY MS. NASH: 13 Q. Who makes the decision on what data files 14 are stored on the mainframe and the Cyber 830, as the 15 one you have described as having more--other than 16 financial files on it, as opposed to storing data files 17 on the VAX 8820 or one of the other mini computers that 18 you previously mentioned that we'll be discussing? 19 A. The district has recently acquired the VAX 20 8820 and is encourageing the users to store their data 21 in Oracle wherever possible. The Cyber system is much 22 older and is in the process of being phased out, and 23 data files are discouraged from being created there. 24 The user ultimately makes a decision where 25 they put the data and request permission in the form of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 46 1 disk allocation for where they need to put their data. 2 And computer management grants the request if it's 3 considered reasonable. Computer management is a 4 division. 5 Q. Who heads the computer management 6 division? 7 A. Myself. 8 Q. Are you saying then that it would be your 9 decision--or your decision which computer, based on the 10 amount of disk space being requested as to which 11 computer somebody would store files? 12 A. No, I'm not saying that. 13 Computer management personnel grant 14 allocations of disk space, and the user ultimately 15 makes a decision as to how much space they need and 16 then where they put their data. Naturally they can't 17 put more than they have space for, and if we deny their 18 request for space, they won't be able to put it on that 19 particular system. 20 Q. What's the operating system on the VAX 21 6310 computer system? 22 A. At present, VMS 5.0. 23 Q. What are the software packages available 24 on the VAX 6310? 25 A. Again, that's a very generic question. I PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 47 1 guess my attempt to say the packages that can be 2 utilized by a user would be Oracle, system utilites, 3 communications software, language development tools, 4 and then any software somebody may have developed. 5 Q. Is there a standard set of software that's 6 supported for the mini computers or--let me stop there. 7 MR. FROST: What do you mean by-- 8 BY MS. NASH: 9 Q. Is there a standard set of software that 10 is supported by computer management for the mini 11 computers? 12 MR. FROST: Do you understand what she 13 means by "supported by"? 14 THE WITNESS: I think I need to define 15 "support" here. 16 MR. FROST: Go ahead. 17 THE WITNESS: You want me to define 18 "supported by" or you define "supported by"? 19 BY MS. NASH: 20 Q. Let me rephrase the question, actually. 21 What I'm interested in is are users of the 22 mini computers allowed to utilize whatever software 23 package appeals to them, or are they restricted in any 24 fashion to a standard set of software packages? 25 A. There are no restrictions normally placed PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 48 1 on any software packages, but there are permissions 2 required to get to some of the software packages or to 3 access possibly somebody's user number that contains 4 software. 5 Q. Let me see if I understand your answer. 6 A user, under their own user number, can 7 utilize whatever software they choose from whatever 8 source; is that an accurate statement? 9 A. No. A user may access 10 commercially-available software on any mini computer 11 where it is located as long as they have sufficient 12 permissions, meaning resources not so much access to. 13 Q. That gets back to my initial question then 14 is do you support only a standard set of software 15 packages and not-- 16 MR. FROST: Are you-- 17 BY MS. NASH: 18 Q. --the computer management division, and 19 not allow researchers to--or other users to pull in 20 their own software packages from the hinterlands, from 21 wherever? 22 A. Okay. I'm gonna have to qualify the word 23 "support." 24 Computer management installs selected 25 software that it finds of use to the district or its PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 49 1 employees and assists with questions on it. The 2 district is in the process of developing a data and 3 security policy that is consistent with prior year's 4 practices for not allowing the use of pirated software. 5 If a user were to copy a program from an 6 external source to their user number and had sufficient 7 resource privileges to use it, we'd very possibly not 8 be aware of it. 9 I don't know if that is targeting in 10 answering your question. 11 Q. It does. 12 The software packages that can be utilized 13 on the VAX 6310, you mentioned Oracle, systems 14 utilites, a communications software and the language 15 development tools. Are those the same packages that 16 you previously describe as being utilized on the VAX 17 8820? 18 A. All the ones that exist on the VAX 8820 19 also exist on the VAX 6310. 20 Q. Are there additional software packages on 21 the VAX 6310 that are not on the VAX 8820? 22 A. Yes. 23 Q. What are those software packages? 24 A. It'll take a little time, excuse me. 25 Wallengong, W-a-l-l-e-n-g-o-n-g, I PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 50 1 believe, Communications Software, in particular TC PIP 2 and NFS from Wallengong, XNS 4.0 Interconnections Disk 3 services. That was all one word. Interconnection Disk 4 Services called I*, two letters. I asterisks is a 5 better way of saying it. 6 Land Traffic Monitor, LPS 40 Host Service. 7 Q. I'm sorry, was that LPS? 8 A. LPS 40 Host Services. And PC SA. 9 Q. What is the function of the Wallengong TC 10 PIP that you mentioned? 11 A. A communications package permitting 12 computer systems capable of networking through TC PIP 13 to access the VAX 6310. 14 Q And what is the function of the NFS? 15 A. To provide network file services to TCP 16 hosts. 17 Q. What is the function of the--I believe it 18 was XNS 4.0? 19 A. To provide communications to and from the 20 Xerox 8090 server, disk server. Disk and print server, 21 actually. 22 Q. And what is the function of the--you call 23 it Interconnections Disk Services I*? 24 A. To provide personal computer MS NET 25 services to personal computers on the network. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 51 1 Q. And what is the function of the Land 2 Traffic Monitor? 3 A. To monitor and restrict Ethernet packets 4 across land bridge bridges from DEC, D-E-C. 5 Q. And what is the function of the LPS 40 6 Host Services? 7 A. To download the software to the LPS 40 8 lazer printer, period. 9 Q. What is the function of the PC SA? 10 A. To provide multi-user file access to MS 11 Dos Hosts, H-o-s-t-s. 12 Q. Are there any other software utilized on 13 the 6310 that you have not yet described? 14 A. These were just the packages in addition 15 to what exists on the 8820. 16 Q. Correct. 17 A. And no, I can't think of any other 18 packages other than programs that an individual might 19 have developed and have available for their personal 20 use. 21 MS. NASH: Good enough time to break? 22 MR. FROST: Yeah. 23 MR. RICHARDS: Counsel, do you have any 24 idea how much longer you're going to spend with 25 this witness? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 52 1 MS. NASH: Looks like a good part of the 2 afternoon. 3 MR. RICHARDS: Okay. 4 MR. FROST: Resume at 1:30? 5 MS. NASH: Yes. 6 (Whereupon, a lunch recess was taken from 7 12:31 p.m. to 1:40 p.m.) 8 (Whereupon, Ms. Follins entered the 9 deposition room.) 10 BY MS. NASH: 11 Q. Mr. Hall, I want to back up and fill in in 12 a few places. 13 You mentioned on your staff two 14 supervising senior systems analysts; is that correct? 15 A. Yes. 16 Q. Can you name them, please? 17 A. Lavinia Rickets and George Scholl, 18 S-c-h-o-l-l. 19 MR. FROST: Before we go further, I'd just 20 like to have on the record that we would like 21 for the transcript to be certified by the court 22 reporter, and we would also like to have the 23 opportunity to read, correct, and examine the 24 record and to sign it. 25 And I just wanted to make sure that PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 53 1 we have the opportunity. 2 BY MS. NASH: 3 Q. You mentioned a mainframe data base 4 analyst on your staff. Who is that person? 5 A. Thom, T-h-o-m, Scanlan, S-c-a-n-l-a-n. 6 Q. And you also mentioned a micro computer 7 applications developer; is that correct? 8 A. Yes. 9 Q. And who is that person? 10 A. Robert Haine, H-a-i-n-e. 11 Q. With regard to the VAX 8820 mini computer, 12 is there a log or other record of the data files that 13 are contained on that computer in any of its associated 14 disks or tapes? 15 A. Yes. 16 Q. Does that log have a name? 17 A. There--I guess there could be multiple 18 logs here. Can you be more specific as to which one of 19 those three areas, disk tape, et cetera? 20 Q. What is the--all right. 21 Is there a log for the disks on the VAX 22 8820, the data files on the disks? 23 A. Right. 24 Q. On the 8820. 25 A. Again, some are to the Cyber. By backing PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 54 1 the files up to cartridge tape, you obtain a list of 2 the user name, file name for any files as they back up. 3 And that can be created as a hard copy or machine 4 readable text file, naturally reflecting the files at 5 that point in time. 6 Q. Is there a similar list for the data files 7 on the tapes associated with the VAX 8820? 8 A. No, the log on the Cyber referred to as 9 the user tape list on the Cyber also includes any tapes 10 used on the VAX systems. 11 Q. Is there a log for what is stored directly 12 in the memory of the VAX 8820? 13 A. Are you referring to ram memory or disk 14 memory? 15 Q. Well, I believe--ram memory for the 16 moment. 17 A. There is a VMS command that can tell you 18 of any process running at any given time; in other 19 words, that one instant call show process, and that 20 could be copied onto a piece of paper, if desired. 21 Q. Are there any data files stored on the VAX 22 8820 other than on disk or tape? 23 A. Yes. 24 Q. What files are those? 25 A. Files are also stored on cartridges, which PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 55 1 are 3490 compliant. Actually compatibles, I guess, is 2 a more appropriate word. 3 Q. Is there a log of the data files stored on 4 the cartridges on the VAX 8820? 5 A. Yes. Again, any files, data files, stored 6 in the cartridges would be included in the same log 7 we've talked of previously, Cyber tape list/user log. 8 The only other files that may not be 9 included in that list would be simply the system backup 10 tapes. I don't know if they are or not included on the 11 log, but they are mirror images of the disks for 12 disaster recovery purposes. 13 Q. Returning to the VAX 6310. What are the 14 input peripherals on that unit? 15 A. It has two Ethernet controller boards, 16 four RS 232 ports--excuse me, it doesn't have four RS 17 232 ports. I'm thinking of a previous machine. I 18 believe it has just simply one RS 232 port for the 19 console. 20 Q. Are there any other input peripherals for 21 the VAX 6310? 22 A. No, only devices that would be connecting 23 through the Ethernet. There's no other physical 24 connections going in. 25 Q. What are the output peripherals for the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 56 1 VAX 6310? 2 A. Okay, all output peripherals must be 3 reached through the two Ethernet controller boards, 4 which include the devices we've talked about 5 previously, meaning the LPS 40, et cetera, lazer 6 printer, as well as a local Ethernet device that 7 receives and forwards printouts to lazer printers 8 associated with PC servers. 9 Again, those devices are accessed through 10 the Ethernet controller boards but are capable of 11 producing output from the VAX. 12 Q. What is the memory capability of the 6310? 13 A. Ah, I'm not positive. I believe that it's 14 65K--or excuse me, 56 megabyte--or 64 megabyte of real 15 memory. 16 Q. What are the communications capabilities 17 of the 6310? 18 A. Any device on the network that can be 19 input or output device from the VAX Ethernet controller 20 board is capable of being communicated with. There are 21 a number of different devices that exist and also could 22 be interfacted through that Ethernet controller board. 23 Q. What are the data files, if you know, that 24 are stored on the VAX 6310 or--or its related 25 cartridges, disks or tapes? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 57 1 MR. FROST: Can you break that up into 2 two--two questions? 3 MS. NASH: Well, you can--if he can answer 4 it generally. If not, I'll break it down. 5 A. Okay, referring to the disk itself on the 6 VAX, there are Oracle data bases stored there, and 7 there are UNIX flax files stored there, and there are 8 PC data files and programs stored there. 9 Again, users receive a log-on and are 10 given an allotted space, and they may store either VMS 11 files, UNIX text files, or binary files, or PC text, or 12 word processing files on the VAX under their user 13 number, and only the individual user would have a 14 thorough knowledge of what those files were, though as 15 we mentioned previously, the list of files from backup 16 would give you a file name, which would have some 17 meaning. 18 There is also Word Perfect files stored on 19 the VAX. This is something that I had not remembered 20 till just now. There is Word Perfect word processing 21 program running on the VAX 6310, and terminal users 22 store their files under their individual user number, 23 as well as in a general access area for anyone. 24 Again, what's in those files would really 25 be probably only known by the user that created them or PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 58 1 someone they asked to work with those files. 2 Q. Do you know which version of Word Perfect? 3 A. Yes. 4 Q. What version? 5 A. 5.O. Excuse me. 6 Q. Moving on to the--the Perkin Elmer mini 7 computer. What is the operating system for that unit? 8 A. It's Perkin-Elmer owned OS. 9 Q. And what are the software packages that 10 are utilized on the Perkin Elmer mini computer? 11 A. An applications package known as 12 Laboratory Information Management Systems from Perkin 13 Elmer, also abbreviated as LIMS. And that's all. 14 Q. What is LIMS' function; what does it do? 15 A. LIMS is a data collection analysis package 16 for chemical information. I should say laboratory 17 information, chemistry laboratory information. 18 Q. Are the data files on this Perkins Elmer 19 mini computer limited then to chemistry lab 20 information? If you know. 21 A. Yes, the data is limited to the results of 22 chemical analysis performed in the laboratory. 23 Q. What are the input peripherals on the 24 Perkins Elmer? 25 A. All the instrumentation in the chemistry PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 59 1 lab are linked through the network or through direct RS 2 232 communications to the Perkin Elmer. This includes 3 an auto analyzer, spectrometer, balance, carbon 4 analyzer, and some other chemistry instrumentation that 5 I'm really not familiar with. 6 I believe the question was what input 7 devices-- 8 Q. That's correct. 9 A. Okay. 10 There are some terminals directly wired to 11 the Perkin Elmer for input purposes, predominantly in 12 the chemistry--chemistry lab, and a console located in 13 the computer room is also directly attached to RS 232 14 ports on the rear of the Perkin Elmer. 15 Aside from the laboratory instrumentation 16 and the bar code readers associated with those 17 laboratory instruments, that is the only input devices 18 available to the Perkin Elmer. 19 One device that I guess should be called 20 an input device is a synchronous link to the Cyber 21 system for the purposes of doing a remote-job entry 22 used mainly for doing printouts. 23 Q. You mentioned directly-wired terminals in 24 the chemistry lab. Are there directly-wired terminals 25 to the Perkin Elmer elsewhere? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 60 1 A. No, and those may be all networked, as 2 well. They may run through NIU units. There may be 3 none that still have cables going physically into the 4 computer room, except, of course, for the console that 5 is located in the computer room and is directly wired. 6 Q. And what are the output devices on the 7 Perkin Elmer? 8 A. There is a direct wire to a line printer 9 located in the chemistry lab, a line printer obtained 10 from Perkin Elmer. I do not know the model of it. 11 There are terminals, both graphic and 12 textural. I believe they're all on the network at this 13 point, though it's possible we may still have some of 14 the graphics terminals hard wired directly to the 15 Perkin Elmer that are capable of being output to. 16 The only other output device would, again, 17 be the synchronous link to the Cyber system to the CDC 18 NET. 19 Oh, excuse me. There are also two mag 20 tape drives--at least one, I believe it's two, located 21 on the Perkin Elmer system for purposes of doing 22 backup. Those are nine-track tape drives. 23 Q. Other than the synchronous link to the 24 Cyber system that you've mentioned in both input and 25 output on the Perkin Elmer, is there any other PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 61 1 communications capabilities, networking capabilities on 2 that mini computer? 3 A. No, it has RS 232 ports, which link into 4 NIU 180's, and that's the only communications going in 5 and out of the system right now. 6 Q. The next mini computer you mentioned was 7 the Computer Vision mini computer? 8 A. Okay. 9 Q. What is that mini computer used for? 10 A. The Computer Vision system obtains graphic 11 and spatial images of the South Florida area in the 12 form of maps and ground clover--cover, as well as to 13 represent any spatial representation utilized in the 14 documentation of district buildings or structures. 15 Q. What is the operating system for the 16 Computer Vision mini computer? 17 A. CADDS, I think it's C-A-D-D-S, and I 18 believe the current version is 4.0, a Computer Vision 19 operating system. 20 Q. What software package are utilized on the 21 Computer Vision mini computer? 22 A. Purely CADDS 4. They are a graphical CADD 23 system. 24 One other software package is used called 25 CADSI, C-A-D-S-I. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 62 1 Q. What does the function of that software 2 package? 3 A. CADSI is used to convert Computer Vision 4 data bases, referring to graphical information, 5 into--into DIF files, which are compatible with 6 AUTOCAD. 7 Q. Which system utilizes AUTOCAD? 8 A. A number of the personal computers in the 9 district utilize AUTOCAD, as well as DEC station 10 5000's, a micro computer, and Sun 3 micro computers, as 11 well. 12 Q. What are the input devices for the 13 Computer Vision mini computer? 14 A. Computer Vision work stations with a 15 terminal digitizing tablet and keyboard. 16 Q. And how many of these Computer Vision work 17 stations are there in the district? 18 A. Associated with the Computer Vision mini 19 computer, there are four Computer Vision work stations. 20 Q. Where are those four work stations 21 located? 22 A. Again, things change in this area, but I 23 believe they are presently allocated in the division of 24 geographical sciences. 25 Q. Are there any other input devices to PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 63 1 access the Computer Vision mini computer? 2 A. There is a personal computer attached to 3 the Computer Vision through an RS 232 interface capable 4 of doing input. 5 Q. And where is that PC located? 6 A. In the geographical division--geographical 7 sciences division. 8 Q. What are the output devices on the 9 Computer Vision mini computer? 10 A. It has two magnetic tape drives, one seven 11 track and one nine track, plus, of course, the four 12 geographical work stations, in other words, Computer 13 Vision work stations, and the personal computer 14 attached through the RS 232 interface. 15 Q. Is there any other means to retrieve data 16 off this Computer Vision mini computer other than these 17 mag tape drives and the four CV work stations and the 18 PC you've previously mentioned? 19 A. No, that's the only forms, other than 20 possibly removeable disk on the Computer Vision mini 21 computer itself. 22 Q. Does the Computer Vision mini computer 23 have the capability of removeable disks? 24 A. Yes, it does. 25 Q. Is it so used? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 64 1 A. I don't believe so. I don't believe 2 they're ever taken off. 3 Q. You also mentioned a Micro VAX 2 mini 4 computers; is that correct? 5 A. That is correct. 6 Q. What is the operating system for the Micro 7 VAX 2 mini computers? 8 A. We--we distinguish the three different 9 Micro VAX 2 operating systems by the name of the user 10 that tends to use them the most. On the Micro VAX 2 11 for Rudy Vynanek-- 12 Q. Can you spell that last name? 13 A. V-y-n--this is going to be my best guess, 14 V-y-n-a-n-e-k. On the Micro VAX 2 for Rudy Vynanek, we 15 are running VMS 5.0. 16 On the Micro VAX 2 for Dewey Worth, 17 W-o-r-t-h, we are running VMS, I believe it's 18 still--it's now 5.0. It was 4.7, and I believe it is 19 converted over. 20 On the Micro VAX for Bob Mann, M-a-n-n, we 21 are running VMS 5.0. 22 Not to confuse the issue, some of these 23 people don't presently use the system anymore, but we 24 uniquely identify the system by those names. 25 Q. Are the same software packages utilized on PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 65 1 all three of the Micro VAX 2 mini computers? 2 A. No. 3 Q. Okay, then what are the software package 4 capabilities or software packages being utilized on the 5 one you call the Rudy Vynanek Micro VAX 2? 6 A. The software cap--capable of being 7 utilized on Rudy Vynanek's Micro VAX 2 is Oracle, 8 Wallengong, DCP and NFS, and Interconnections I*, 9 virtual circuits only. 10 There is some custom-developed software 11 for communications and data flex software. 12 Q. What is the function of the data flex 13 software? 14 A. It's a data base system used to store 15 quart-level readings, as well as all types of readings 16 collected in the field. 17 Q. Where is the Rudy Vynanek 2 Micro VAX mini 18 located? 19 A. In the section of the computer room walled 20 off for operations and maintenance department in the 21 district's headquarters complex. 22 Q. What other computers are located in this 23 section of the computer room that's walled off for 24 operations and maintenance? 25 A. A Mod Comp mini computer--actually, two of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 66 1 them, that are part of a telemetry system for 2 collecting data. 3 I may not have answered the question that 4 you want-- 5 Q. Are there any other computers-- 6 A. Yes. 7 Q. --of any size located in this area you've 8 indicated as operations and maintenance department? 9 A. There is also a Symbolics, I believe it's 10 a 3640 is the model number, artificial intelligence 11 work station. 12 Aside from personal computers and 13 terminals, that's all the devices in the fenced-off 14 section of the computer room that's designated for 15 operations and maintenance department. 16 Q. What are the input devices on the Rudy 17 Vynanek Micro VAX 2? 18 A. An Ethernet network board and some RS 232 19 ports for local terminals, plus an input RS 232 line 20 that goes to the Mod Comp system. 21 Q. Any other input devices on the Rudy 22 Vynanek Micro VAX 2? 23 A. Only devices that go through that Ethernet 24 controller board, including PC's and terminals. 25 Q. What are the output devices on the Rudy PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 67 1 Vynanek Micro VAX 2? 2 A. They, again, can access the networked 3 lazer printers on the network through their Ethernet 4 controller board, same as previous devices we've talked 5 about. They have terminals directly wired, which are 6 capable of output, and the RS 232 link to the Mod Comp 7 systems is also capable of being used for output. 8 The console, I believe, is a hard copy 9 device, as well, meaning a dot matrix teletype. 10 That's all the output devices that you can 11 get out through. 12 Q. What are the data files that would be 13 contained on the Micro VAX 2 Rudy Vynanek mini 14 computer? 15 A. Users within the operation--operations and 16 maintenance department have set up accounts for 17 selected users within their departments, and there may 18 be some files within those accounts. 19 There are data flex data bases containing 20 data and Oracle data bases containing data, most or all 21 relative to the real-time data being collected by the 22 Mod Comps. 23 Q. Is there a log of the data files on the 24 Rudy Vynanek Micro VAX 2? 25 A. One doesn't exist, but again, if a backup PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 68 1 were done, then all files backed up, the names of files 2 could be logged and printed. 3 MR. FROST: But that's a hypothetical. 4 Has that been done? 5 THE WITNESS: I cannot say for sure. 6 MR. FROST: Okay. 7 THE WITNESS: I don't know the answer to 8 that one. 9 MR. FROST: So it's purely speculation. 10 THE WITNESS: That is speculation. 11 BY MS. NASH: 12 Q. Moving on to the Dewey Worth Micro VAX 2. 13 What are the software packages utilized on that mini 14 computer? 15 A. Communications software, I squared S 16 software, and some language tools, as well. I believe 17 that's all. 18 Q. What is the function of the communications 19 software? 20 A. To communicate with other DEC systems. 21 Q. I'm sorry, what? 22 A. DEC, D-E-C. 23 Q. And what is the function of the I squared 24 S software? 25 A. It is an applications package for PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 69 1 manipulating and processing and outputting information 2 relative to remote sensing. 3 Q. And what are the functions of the language 4 tool packages you mentioned that are on the Dewey Worth 5 Micro VAX 2? 6 A. Correct. 7 There is Fortran. I don't know if he does 8 or does not have C. And certain applications supplied 9 with I squared S are dependent on those language tools 10 to function properly. 11 Q. Where is the Dewey Worth Micro VAX 2 mini 12 computer located? 13 A. In a special room located in the northeast 14 corner of the bui--of the headquarters complex. 15 Q. Are there other computer systems located 16 in this same special room? 17 A. Computer systems? Only personal computers 18 and I squared S work stations. 19 Q. What are the input devices on the Dewey 20 Worth Micro VAX 2? 21 A. It has an Ethernet controller board 22 capable of doing input, a synchronous line 23 capable--capable of dialing out to other computer 24 systems to obtain data, an I squared S scanner, a DEC 25 terminal, and the I squared S work station. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 70 1 Q. Any other input devices? 2 A. The I squared S scanner may actually be 3 two devices. 4 No, I'm sorry, it's just one device 5 capable of scanning a drawing. 6 No, there's no other devices that I can 7 think of. 8 Q. What are the output devices on the Dewey 9 Worth Micro VAX 2? 10 A. It's capable of outputing through a 11 Versatech graphics controller to Versatech color 12 plotters. It has an output device of a Techtronics--I 13 guess a page generator, output through the Ethernet 14 controller board to terminals and PC's, an output I 15 squared S drawings data through the synchronous 16 interface. There is also a console that's a hard-copy 17 console that you could output to, as well. 18 Q. Any other output devices? 19 A. Only devices reached, again, through the 20 Ethernet controller board, which include lazer printers 21 on the network. 22 Q. What are the data files that would be on 23 the Dewey Worth Micro VAX 2 mini computer? 24 A. I squared S data received from satellite 25 photography and then manipulated within the I squared S PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 71 1 system. 2 I'm sorry, can you repeat the question? 3 Q. Yes, what were the data files on the Dewey 4 Worth Micro VAX 2? 5 A. I would say all spatial data originating 6 from land sat photography. 7 MR. FROST: Do you know that? 8 THE WITNESS: I know that there are some. 9 I don't know of what areas, what wavelengths, 10 the particulars of it. 11 BY MS. NASH: 12 Q. Is there a log of the data files on the 13 Dewey Worth Micro VAX 2? 14 A. I'm not aware of one being maintained. 15 Q. The Bob Mann Micro VAX 2, what are the 16 software packages on that? 17 A. Oracle and Interconnections I*, as well as 18 some language tools. I believe that's all. 19 Q. Which language tools are on the Bob Mann 20 Micro VAX 2? 21 A. Actually--excuse me, there is also Free 22 Form and Britten Lee software residing on the Bob Mann 23 Micro VAX. RPH-- 24 Q. What was the last one you-- 25 A. I'll repeat them both. Free form and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 72 1 Britten, B-r-i-t-t-e-n, Lee, L-e-e, host software. 2 Q. What are the language tool softwares on 3 the Bob Mann Micro VAX? 4 A. I believe it's both Fortran and C. 5 Q. What is the Free Form software package; 6 what is its function? 7 A. It is used for referencing the Britten Lee 8 data base from a screen orientation. 9 Q. And what is the Britten Lee host software? 10 A. It is software for accessing the Britten 11 Lee system. 12 Q. And what is the Britten Lee system? 13 A. The Britten Lee system is a--a data base 14 machine for storing relational data, commonly referred 15 to as a back-end data base machine. 16 Q. Where is the Bob Mann Micro VAX 2 mini 17 computer located? 18 A. In the computer room next to the Britten 19 Lee--excuse me, in the computer room next to the Perkin 20 Elmer. 21 Q. What are the input devices for the Bob 22 Mann Micro VAX 2? 23 A. An Ethernet controller board, plus 16 24 asynchronous ports, which I believe are not connected 25 to anything at present. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 73 1 Q. Any other input devices? 2 A. There is a console that is connected to 3 one of those 16 ports actually capable of, of course, 4 doing input. No other devices. 5 Q. What are the output devices on the Bob 6 Mann Micro VAX 2? 7 A. The same devices, the Ethernet controller 8 board and the 16 ports, of which one is used, and 9 devices on the network that can be referenced from that 10 Ethernet controller board. 11 Q. What are the data files on the Bob Mann 12 Micro VAX 2? 13 A. Some Oracle data base files used 14 previously for instruction on how to use Oracle, and I 15 believe that's it. There could be some temporary files 16 going to or from the Britten Lee. 17 Q. Are there any other mini computers 18 utilized by the water management district that you have 19 not yet described? 20 A. Yes. I did forget to earlier the two Mod 21 Comp classic two's that we encountered in the 22 operations and maintenance department section of the 23 computer room. 24 Q. What are they operating system on the Mod 25 Comp classic two? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 74 1 A. MAX, M-A-X, 4 on both systems. 2 Q. And what are the software packages used on 3 the Mod Comp classic two systems? 4 A. An applications system developed by 5 contract from the district to receive data from the 6 field and operate gate structures. 7 Q. Do you know who developed the package? 8 A. Yes. 9 Q. Who is that? 10 A. A contractor called General Dynamics. 11 Q. And when was that package developed for 12 the water management district? 13 A. The contract was let in 1970, 14 approximately, and began testing in 1975, and went full 15 production in 1977. Approximately. 16 Q. Has that applications system package been 17 modified or altered since 1977? 18 A. Yes. 19 Q. When was it modified? 20 A. As needs changed and additional sensors 21 were added to the field, the system was modified on a 22 regular basis to accommodate the changes. 23 In addition, the system was rewritten in 24 1979 to run on the Mod Comp systems. It had previously 25 been on a Control Data Lower 3,000 with PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 75 1 Hewlett-Packard's 2100 front ends. 2 Q. Any other modification or changes? 3 A. Changes have been made internally by staff 4 and by contract to make the system use more 5 off-the-shelf hardware and software in the last eight 6 years. 7 Q. Any other modifications? 8 A. Only some changes to try to keep as much 9 code in Fortran as possible, reducing the assembler to 10 a minimum. 11 Some changes were also made to accommodate 12 new computer systems as they were introduced to the 13 district over the last five years. 14 That's all the changes that I'm aware of. 15 Q. Any other mini computer systems utilized 16 by the water management district that you have not 17 previously mentioned? 18 A. Let me check here. 19 No, at present, there is no other mini 20 computers in the district that we haven't listed 21 specifically here. 22 Q. From your testimony so far today, it 23 appears that certain of the mini computers your 24 computer management division does back up for and 25 certain of the mini computers are not backed up; is PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 76 1 that an accurate statement? 2 A. That is an accurate statement. 3 Q. Can you go over again which of the mini 4 computer systems are--do you back up? 5 MR. FROST: I object. I think that's been 6 asked and answered, but... 7 A. I didn't--I am gonna try to walk through 8 them. 9 Mini computers only: The 8820 is backed 10 up by computer management; the 60--VAX 6310 is backed 11 up by computer management; of the three Micro VAX 2's, 12 the Bob Mann Micro VAX is backed up by computer 13 management, though there's not a regular schedule to it 14 since it wasn't designed for files to change; the Rudy 15 Vynanek Micro VAX is backed up as needed by the 16 operations and maintenance department; and the Dewey 17 Worth Micro VAX is backed up as needed to by the 18 research and evaluation department; the Mod Comp 19 classic 2's are backed up by operations and maintenance 20 department when appropriate--and I've lost track. 21 Are there any other machines? I think I 22 got them all. 23 Q. The Perkin Elmer. 24 A. Sorry. 25 The Perkin Elmer system is presently PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 77 1 backed up by computer management. 2 Q. Is that a change from prior practice? 3 A. Yes. 4 Q. And what was prior practice with regard to 5 the Perkin Elmer? 6 A. When the Perkin-- 7 MR. FROST: I object to that question. 8 Could you specify what you mean by "prior 9 practice"? 10 MS. NASH: Your witness has testified that 11 that is a change from prior practice. I'm 12 asking him to elaborate on his own term. 13 MR. FROST: Specify "prior practice" with 14 regards to what you're asking him about. 15 MS. NASH: To backing up--the change in 16 prior practice of backing up the Perkin Elmer 17 mini computer. 18 MR. FROST: That's fine. 19 A. The Perkin Elmer system was backed up by 20 computer management after its installation in 21 approximately 1974 when the chemistry lab went to a 22 double shift. They began backing up the system 23 themself during the second shift, and then in the last 24 six months, approximately, the need to have it backed 25 up on first shift rose, and computer management PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 78 1 division assumed the backups. 2 (Short break.) 3 BY MS. NASH: 4 Q. Mr. Hall, the other mini computer that you 5 had mentioned was the Computer Vision mini computer. 6 Is that Computer Vision, that mini computer, backed up? 7 A. Could you repeat the last five words? 8 Q. Is the Computer Vision mini computer 9 backed up? 10 A. Ah, yes. Backed up by the geographical 11 division. 12 Q. For the--I believe it's three or four mini 13 computers that you mentioned that the computer 14 management division backs up, what is the procedure for 15 doing that back up? 16 MR. FROST: Do you mean specificly for 17 each individual computer system, or are you 18 looking for more of a general-- 19 MS. NASH: Well, Mr. Hall can answer the 20 question. If it's the same for all systems, 21 then one answer's fine. If it's different for 22 each system, then... 23 MR. FROST: So is the question then is it 24 the same for each system? 25 MS. NASH: I don't know, that's the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 79 1 question you'd like him to answer. 2 A. The backup utility for all systems is the 3 DEC-provided backup utility. 4 BY MS. NASH: 5 Q. Is the backup done on the 8820 on a 6 regular cycle? 7 A. Yes. 8 Q. What is that cycle? 9 A. Operations section of computer management 10 backs up the full system on one day of the week and 11 partial backup of files that have changed on the other 12 four working days of the week. 13 Q. Is the backup done on the 8820, for 14 example, at the end of the day so you're aware of what 15 files have changed during the day? 16 MR. FROST: That's a compound question, I 17 object to it. 18 BY MS. NASH: 19 Q. Is the backup-- 20 MR. FROST: Will you rephrase-- 21 BY MS. NASH: 22 Q. Is back up of the 8820 done at the end of 23 the day? 24 A. The backup, assuming the equipment is 25 functioning, which is the normal, is done on second PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 80 1 shift. 2 Q. What are the hours of second shift? 3 A. Three p.m. to eleven p.m. 4 Q. Is the backup procedure for the 6310 the 5 same as the backup procedure for the 8820? 6 MR. FROST: I'd like to object to this 7 line of questioning. What is the relevance of 8 backup and where's counsel going with this? 9 MS. NASH: Well, we've been advised by 10 you, I believe, that certain computer files were 11 destroyed, and we're trying to find out why and 12 whether there's a backup for the files that 13 you've alleged are destroyed. 14 MR. FROST: Okay. 15 A. The backup for the 6310 is done in an 16 identical manner to the 8820. 17 BY MS. NASH: 18 Q. What about the backup for the Perkin 19 Elmer? 20 A. The Perkin Elmer system has changed from 21 time to time as to whether the user department, R & E, 22 research and evaluation, has backed it up, and whether 23 computer management has backed it up. At present, 24 computer management is backing it up on the second 25 shift. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 81 1 Q. Is computer management backing up the P 2 and E on the second shift on a daily basis? 3 A. Yes. 4 Q. And do you also utilize the DEC-provided 5 backup utility for the Perkin Elmer? 6 A. No. 7 Q. What is the procedure for backing up the 8 Perkin Elmer? 9 A. A Perkin Elmer--excuse me, Perkin Elmer 10 utility provided to do backup to magnetic tape. 11 Q. Mr. Hall, you mentioned in connection with 12 the Rudy Vynanek Micro VAX a Symbolics 3640 Symbolics 13 artificial intelligence work station? 14 A. That is correct. 15 Q. What is that work station used for? 16 A. The development of a expert system for the 17 purpose of advising the operation center's technicians 18 on conditions happening in the field. 19 MR. RICHARDS: Could you please read back 20 that question? 21 (Thereupon, the question was read by the 22 Reporter as recorded above.) 23 MR. RICHARDS: Thank you. 24 BY MS. NASH: 25 Q. What conditions happening in the field are PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 82 1 you referring to? 2 A. A expert system was in the development 3 cycle for the purposes of looking at multiple 4 structures at a single time and advising the operations 5 center operator if there was required action and what 6 the system believes the action should be. 7 Q. Are the structures that you're referring 8 to in your answer gates or dams of that nature or 9 structure? 10 A. Yes. They are gates, as well as other 11 sensors. 12 Q. And the required actions that you mention, 13 are you referring to opening gates or closing gates 14 or-- 15 A. That is correct. 16 Q. In connection with the Bob Mann Micro VAX 17 2 computer, you mentioned a Britten Lee system. What 18 is the Britten Lee system? 19 A. The Britten Lee is a back-end data base 20 machine designed to take requests from a computer host 21 and return relational data base records. 22 Q. Do you know what sort of data base records 23 you're referring to? 24 A. I do not know the actual format of the 25 records. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 83 1 Is that your question? 2 Q. Well, do you know the nature of the--of 3 the data in this--in these data base records you're 4 referring to in relation to the Britten Lee system? 5 A. The data is chemical-type of data 6 originating from several sources. 7 Q. Do you know what those sources are? 8 A. I don't know all the sources. I do know 9 that some of the data is data obtained as a result of a 10 permit requirement to submit data, and some of the data 11 is chemical analysis data from the Britten Lee once it 12 is not required for the current analysis being 13 performed on the Perkin Elmer but desired to be 14 retained for future comparison. 15 Q. What are the micro computers that are used 16 at the water management district? 17 A. They are, from smallest to largest, I 18 guess, IBM XT, IBM XT 286, IBM AT, Toshiba 3100, 19 Compact 1, 2 and 3, Compact 386, IBM PS 2-30/286, IBM 20 PS2 Models 60, 70 and 80, Micro VAX VAC station 3200, 21 Micro VAX VAC station 3500, Sun 3, Sun 4, DEC station 22 3100, DEC station 5000, and Symbolics 3640. I missed 23 one. Toshiba 1200's. 24 Q. How many Toshiba 1200's are utilized? 25 A. Two. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 84 1 Q. And where are those located? 2 A. The electronics division. 3 Q. Both of them? 4 A. Yes. 5 Q. How many Symbolics 3640's? 6 A. One. 7 Q. Where is that located? 8 A. Operations and maintenance department. 9 Q. How many DEC station 5000's? 10 A. As of today, five. 11 Q. What was the basis for your saying "as of 12 today"? 13 A. There-- 14 MR. FROST: Can counsel clarify what you 15 mean by "the basis"? 16 MS. NASH: Obviously Mr. Hall had some 17 reason for not just simply stating "five," and 18 I'm trying to find out what that reason is. 19 A. There are machines on order that have not 20 been delivered yet to the district. There are also 21 machines being traded in that have not been taken away, 22 so I'm trying to give you a picture as it is today, 23 since it is a moving target. 24 BY MS. NASH: 25 Q. Where are the five DEC station 5000's that PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 85 1 presently are in existence at the water management 2 district located? 3 A. One is in the department of research and 4 evaluation. One is in the department of regulation. 5 And three are in the department of planning. 6 Q. How many DEC station 3100's are there? 7 A. One. 8 Q. Where is that located? 9 A. Department of reg--R & E--let me think. 10 Regulation--research and evaluation. 11 Q. How many Sun 4 micro computers are there? 12 A. I guess, again, as of today, there are 13 two. 14 Q. Where are those two Sun 4 micro computers 15 located? 16 A. One is in the department of planning, and 17 the other is in the department of research and 18 evaluation. 19 Q. How many Sun 3 micro computers are there? 20 A. Two. 21 Q. And where are those Sun 3 micro computers 22 located? 23 A. One is in the department of planning, and 24 one is in the department of research and evaluation. 25 Q. How many Micro VAX VAC station 3500's are PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 86 1 there? 2 A. Two. 3 Q. Where are those two Micro VAX VAC station 4 3500's located? 5 A. Department of planning. 6 Q. Both of them? 7 A. Yes. 8 Q. How many Micro VAX VAC station 3200's are 9 there? 10 A. One. 11 Q. And where is that one located? 12 A. Technical services department. 13 Q. How many IBM PS2 60's are there? 14 A. I'm gonna have to give you approximate 15 numbers. I believe we have 19 of the PS2 Model 60's. 16 Q. Do you know where those are located? 17 A. They are spread across the whole district. 18 Q. How many IBM PS Model 70's are there? 19 A. I couldn't give you an accurate count 20 there. I would approximate probably about a hundred 21 units. 22 Q. And where are those units, hundred units, 23 located? 24 A. Across the district as a whole. Some in 25 every department. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 87 1 Q. And how many IBM PS2 Model 80's are there? 2 A. I'm gonna have to approximate again. I 3 believe there is 51. 4 Q. And where are those 51 units located? 5 A. Again, across the whole district. 6 Q. How many IBM PS2-30/286 units are there? 7 A. I'm a little bit less accurate with my 8 count, but I'm gonna say probably around a hundred. 9 Q. Again, where are those IBM PS2-30/286 10 located? 11 A. Spread across the whole district. 12 Q. How many Compact 386 units are there? 13 A. One. 14 Q. And where is that one located? 15 A. Department of planning. 16 Q. How many Compact Model 1's are there? 17 A. Yes. Two. 18 Q. And where are they located? 19 A. Electronics division. 20 Q. How many Compact Model 2's are there? 21 A. Two. 22 Q. And where are those two located? 23 A. They're in the checkout pool, portable 24 from tech services. 25 Q. And how many Compact Model 3's are there? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 88 1 A. I believe there's 16. 2 Q. And where are those 16 compact model 3's 3 located? 4 A. I believe 11 are in the checkout pool from 5 tech services department, and the other five are 6 located in either research and evaluation department or 7 planning department. I'm not sure of the exact split. 8 Q. How many Toshiba 3100 micro computers are 9 there? 10 A. I believe the count is two. 11 Q. And where are those units located? 12 A. They're in the checkout pool from tech 13 services department. 14 Q. How many IBM AT micro computers are there? 15 A. Not really sure of the count. I would say 16 probably somewhere between fifty and a hundred and 17 fifty. 18 Q. And where are those IBM AT units located? 19 A. Spread across the district as a whole. 20 Q. How many IBM XT 286 micro computers are 21 there? 22 A. I would guess, again, somewhere between 25 23 and 75. 24 Q. And where are those units located? 25 A. They are spread across the district, PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 89 1 multiple departments. 2 Q. How many IBM XT micro computers are there? 3 A. I believe the count is 56. 4 Q. And where are the IBM XT micro computers 5 located? 6 A. Again, spread across the district as a 7 whole. Many are at field stations, as well. Some are 8 also at department directors' homes. 9 Q. Is there a standard operating system for 10 the micro computers? 11 A. Yes. 12 Q. What is that operating system? 13 A. On all the IBM systems, it's PC dos 4.1. 14 On the Toshibas, as well as the Compacts, it's MS dos 15 3.3. 16 Q. On the Micro VAX? 17 A. Ah, VMS 5.0. 18 Q. On the Sun? 19 A. Sun OS, I believe 4.0 version. 20 Q. On the DEC station? 21 A. Ah, Ultrix, and I don't know the version 22 number. 23 Q. And on the Symbolics 3640? 24 A. It runs 6 Symbolics LIMS environment. 25 Q. Any other operating system? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 90 1 A. A operating environment. 2 Did I confuse you on that one? 3 Q. Yes. 4 MR. FROST: Could we have the question 5 repeated again? 6 (Thereupon, the question was read by the 7 Reporter as recorded above.) 8 A. They have a fine distinction. They call 9 themselves an operating environment, and we're using 10 the operating environment from--I have forgotten the 11 name of the company. The environment's called ART for 12 applied re--reasoning tools. 13 MR. FROST: I have an objection to this 14 line of questioning going into such excruciating 15 detail for each computer system when counsel has 16 not even identified whether the computer system 17 would contain relevant or responsive information 18 that's relevant to the lawsuit. 19 MS. NASH: Objection's noted. 20 BY MS. NASH: 21 Q. Are there standard software packages 22 utilized on the micro computers? 23 A. Yes. 24 Q. And what are those standard packages? 25 A. For word processing, Word Perfect 5.0 and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 91 1 5.1. For spread sheet, Lodus Symphony, version 2.0. 2 For project management, Micro Soft Project, I believe 3 it's version 2.0. 4 For business graphics generation, Harvard 5 Graphics. For sideways printing, Sideways. For CADD 6 work, it's AUTOCADD, version 10.0. 7 For data base work, it's Oracle, version 8 5.1. For menu system, it's dos SHELL, S-H-E-L-L. For 9 Micro Soft for C Development, it's Micro Soft C and 10 Turbo C. For Fortran development, it's Micro Soft 11 Fortran. 12 That's all the operating software I can 13 think of at present, though there are some others that 14 are specialized within certain sections. 15 Q. Do you know of any specialized software 16 for the environmental sciences division? 17 A. As far as work station goes, they're some 18 of the previously-mentioned commercial packages being 19 used, probably BMDP, SPSS and SAS, though 20 representatives within the department--or excuse me, 21 the division, are much more knowledgeable here on the 22 tools they've been using. 23 As far as spatial representation, the I 24 squared S for remote sensing and land sat photography 25 are very heavily used. AUTOCADD is also used. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 92 1 And I am not aware off the top of my head 2 of any other packages they're using at present. There 3 is very possibly some, though. 4 Q. Are there any specialized software 5 packages for the regulation department? 6 MR. FROST: Object to the form of that. 7 By that do you mean they're presently using or 8 that they have, or can you clarify? 9 MS. NASH: I'm asking if there are any 10 specialized software packages that the 11 regulation department is using, as he described 12 that there were other specialized software 13 packages for other divisions. Just following 14 up. 15 MR. FROST: Go ahead. 16 A. They very heavily use AUTOCADD, as well as 17 are experimenting but are not in production with 18 another software package called Fast Cat. They do use 19 Oricle extensively, as well as DMS 170. 20 They also have some Basic programs that 21 have been written to provide for some of the 22 time-critical legal requirements involved in the permit 23 process. These programs are written in Basic, as I 24 understand. 25 Q. Do you know who wrote these programs PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 93 1 you're referring to? 2 A. To the best of my knowledge, yes. 3 Q. Who wrote those programs? 4 A. Ron Metzger is the only person I'm aware 5 of having written those programs, though he would know 6 the details of somebody else having written them, as 7 well. 8 Q. Is Ron Metzger a water management district 9 employee? 10 A. Yes. 11 Q. Is he in the regulation department? 12 A. No. 13 Q. What department is he in? 14 A. He is presently in the department of 15 technical services. 16 Q. Are there any other specialized software 17 packages utilized by the regulation department? 18 A. One other package that they are working 19 with is a package developed by the University of 20 Florida to do some of the redundant work of permit 21 analysis and is tied into Lodus 1, 2, 3. 22 I'm not aware of any other specialized 23 package that are used by them. Many of these are 24 general packages used by the district, but having 25 worked with them over the years, I'm aware of the fact PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 94 1 that they are using them. 2 Q. Are there any specialized software 3 packages being utilized by the water supply planning 4 division? 5 MR. FROST: Ask for a clarification, just 6 limited to micro computers or--or how is counsel 7 identifying what software packages it is 8 referring to? 9 MS. NASH: We are discussing the micro 10 computers, so the request is limited to the 11 micro computers. 12 A. I do understand that they're using HEC 2. 13 BY MS. NASH: 14 Q. Sorry, I couldn't hear. 15 A. HEC 2, a program developed by the Corps of 16 engineers. 17 There are other programs that I think they 18 have written internally, but I am not knowledgeable in 19 what those programs are. 20 Q. Are there any specialized software 21 packages being utilized by the water quality division 22 on the micro computers? 23 A. No. I know they're using some statistical 24 packages, but I really don't know which one. One of 25 the commercially available ones, I know, have been PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 95 1 asked about in the past. 2 Q. Are there any specialized software 3 packages being utilized by the planning department? 4 MR. FROST: Could counsel please expand 5 upon what you mean by "specialized"? Are we 6 talking about commercial or-- 7 MS. NASH: Either. Again, it's follow-up 8 on Mr. Hall's reference to the fact that there 9 were general standardized software packages and 10 that some of the divisions had specialized 11 software packages, and I'm just following up on 12 his statement. 13 MR. FROST: Okay. 14 THE WITNESS: It's important to mention 15 that we're talking a fairly large agency here, 16 and I'm using my recollection from questions in 17 the past as to products that I believe they're 18 using, so-- 19 MS. NASH: Understood. 20 THE WITNESS: --I'm giving the best I can 21 do off the top of my head. 22 MR. FROST: And only you identify that you 23 know they are using. 24 THE WITNESS: Correct. There could be 25 others that they would be able to tell you more PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 96 1 about. 2 I'm sorry, what division or department are 3 we on now? 4 BY MS. NASH: 5 Q. Planning. 6 A. (continuing) Planning department is using 7 a package called LINDO, L-I-N-D-O, and AUTOCADD, as 8 well as the other general packages, Word Perfect and 9 Symphony. 10 I know they've written some internal 11 models that have been made available for use elsewhere 12 in the district, but I am not really knowledgeable in 13 the name or the capability of those packages. 14 Q. Do you know what LINDO does? 15 A. No. I know it's some form of a numerical 16 analysis. I'm not sure of its capability. 17 Q. Are there any specialized software 18 packages that you're aware of that the water resources 19 division is utilizing? 20 A. No, just AUTOCADD and Word Perfect there. 21 Q. Are there any specialized software 22 packages that you're aware of that the research and 23 evaluation department is using? 24 A. Some Basic programs are used for a surface 25 water model that is also given out as public domain to PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 97 1 the public. 2 I know of several areas that are using SAS 3 and several areas within R & E that are using SPSS. 4 Q. What is SAS? 5 A. SAS is a statistical analysis package that 6 we've spoken of previously. 7 Q. I believe you also described SPSS 8 previously. 9 A. That is correct. 10 Q. Any other specialized packages that you're 11 aware of that research and evaluation department's 12 utilizing? 13 MR. FROST: I think to clarify this is for 14 micro computers. 15 MS. NASH: Correct. 16 A. No, I can't think of any others they're 17 using. I can faintly remember some they've used in the 18 past, but I know we haven't upgraded them in the last 19 couple years, so I don't think they're being used. 20 BY MS. NASH: 21 Q. Any other or any specialized software 22 packages that you're aware of being utilized by the 23 geographic sciences division on their micro computers? 24 A. Just AUTOCADD, CADDSI, and on the higher 25 performance work stations, CADDS IV, ARC/INFO, and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 98 1 ERDAS, E-R-D-A-S. 2 Q. What is ARC/INFO? 3 A. ARC/INFO is a--a spatial data storage 4 system with inherent capability for representing 5 relational data relative to the spatial data. It's 6 commonly known as a GIS system, graphics information 7 system. 8 Q. Do you know which of the micro computers 9 the geographics sciences division utilizes for ARC/INFO 10 or with ARC--with ARC/INFO? 11 A. It's very much a moving target since we've 12 been out on RFP for the last year for GIS type of 13 software. What I'm saying is I know there's one PC 14 copy, and I believe that one of the Sun 4's has an 15 ARC/INFO on it right now, and both of the DEC station 16 3500's, I believe, have ARC/INFO on it right now. 17 That, I think, is all the ARC/INFOs that 18 are already installed. 19 Q. And what is Verdus (sic)? 20 A. ERDAS is remote sensing software that 21 allows you to analyze land sat photography and then 22 overlay the master image of that analysis to an 23 ARC/INFO base map. 24 Q. Do you know which of the micro computers 25 ERDAS is utilized on? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 99 1 A. I believe it's on a Sun 4 in geographical 2 sciences, and I believe it's on one PC in the 3 geographical sciences department. 4 By the way, that one Sun 4 that it's on 5 has temporarily been loaned to the planning department, 6 so as of today, that ERDAS is actually in the planning 7 department. I believe they are others on order at 8 present. 9 Q. Where is ERDAS located, other than in the 10 geographical sciences department, except for this 11 reference you've just made to the Sun 4? 12 A. Installed right now, no. Just, I believe, 13 just those two are installed. 14 Q. And who makes the decision on which micro 15 computers are obtained by the water management 16 district? 17 A. Can you be more specific? Are you 18 referring to brand? Are you referring to who gets one? 19 Q. Both. Brand and--well, let's start with 20 by which brands are obtained? 21 A. Computer management researches what work 22 stations are being acquired, liability, maintenance, 23 and conductivity with a network perspective, and then 24 attempts to acquire quantities of that work station for 25 the district as a whole. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 100 1 Q. Has this been--let me rephrase that. 2 Is the water management district 3 progressing from certain versions or models of micro 4 computers on to others? You've discussed obtaining-- 5 A. Yes. 6 Q. --new equipment. 7 A. Excuse me. 8 Q. Which is that progression? What is being 9 phased out? 10 MR. FROST: Can counsel explain the 11 relevance of that? 12 MS. NASH: We're trying to determine 13 accessibility and need to know, you know, if 14 he's--what are gonna be maintained. 15 MR. FROST: I'll let you answer to the 16 extent you know. 17 THE WITNESS: Okay. 18 MR. FROST: But to the extent you're 19 speculating, I'm gonna ask that you not answer. 20 A. We are in the process of replacing the 56 21 XT's, making reference to IBM XT's, with higher 22 performance 3D6-based machines. We are in the process 23 of replacing the two VAC station 3500's with Sun Park 24 station one pluses. We are in the process of replacing 25 four Sun 386I's of the five the district owns--and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 101 1 excuse me, I believe I've left this out of the list, 2 with DEC station 5000's. There is a machine that I 3 forgot about in the Sun line there called a Sun 386I. 4 Q. How many-- 5 A. We-- 6 Q. --of those units-- 7 A. Five at present, of which we are in the 8 process of replacing four. 9 Q. Where are those located? 10 A. One is in planning department, three are 11 in research and evaluation department, and one is in 12 tech services department. 13 Unfortunately, there's two other work 14 stations I just realized we have. Since I'm doing this 15 from memory here, I'm finding some I left out. 16 We have two Computer Vision S32 work 17 stations that are also being replaced, and the 18 replacement machine has not been determined as of yet. 19 MR. FROST: I believe there is a question 20 right now pending. 21 BY MS. NASH: 22 Q. That is, what--what other micro computers 23 are in the process of being replaced? 24 A. Okay, that is all the micro computers--I 25 just have to make sure here. Yes, I--that's all the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 102 1 micro computers that I'm aware of are being changed 2 over the next six months. 3 Q. Do you know what data files are stored on 4 the micro computers? 5 A. No. The owner of the machine is truly 6 the--probably the best person to know the contents of 7 the files in those machines and will also be 8 responsible for doing whatever has to be done. 9 Q. What do you mean is "responsible for doing 10 whatever has to be done"? 11 A. In other words, their files are on that 12 machine, and if the machine is replaced, it is their 13 function to save those files for copying to the new 14 work station when it comes in. For the most part, 15 these are swapouts where an older machine is being 16 replaced with a newer machine, and the user is integral 17 here to preserve the appropriate files that need to be 18 preserved. 19 Q. Does computer management division do any 20 form of backup on the micro computers? 21 A. When computer management division is 22 swapping personal computers, they will either ask the 23 user to back up the slash data subdirectory, or they 24 will back it up for the user. It is computer 25 management's policy to normally not back up anything PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 103 1 other than the slash data subdirectory. That's 2 referring to personal computers only. 3 Q. Is there a list that would show where each 4 of the micro computers is located? 5 A. Okay, there is a list that shows which 6 division each computer is located in, and there are 7 graphics that attempt to represent physical location. 8 Q. Does that list show in which division the 9 micro computers are located in any other name? 10 A. Yes. 11 Q. What is the name of that list? 12 A. The computer management data base of 13 computer hardware and software. 14 Q. Who has possession of that list? 15 A. Computer management division. 16 Q. You mentioned that the computer management 17 division is responsible for training; is that correct? 18 A. Qualifying that "yes." We are responsible 19 for selective training. 20 Q. What is that selected training in? 21 MR. FROST: Can we clarify what we are 22 talking about, training for mini computers or 23 micro computers or work stations or what? 24 MS. NASH: I'm talking about training on 25 computers right now at whatever level. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 104 1 A. Computer management-- 2 MR. FROST: Well, could you be more 3 specific about the level? 4 MS. NASH: No. If he can answer the 5 question as it's asked, then I think Mr. Hall 6 will answer the question. 7 A. Computer management provides training on 8 supported packages endorsed by computer management, of 9 which many you have asked previously what are the 10 supported packages. 11 BY MS. NASH: 12 Q. Are there manuals or other reference 13 guides for each of the supported packages? 14 A. Yes. I can't say every package, but there 15 are normally manuals for every user for every supported 16 package. 17 Q. Does that manual or manuals have one name, 18 or is it a separate manual for each, separate manual 19 reference guide for each package? 20 A. Typically, a separate manual for each 21 application where it exists. 22 Q. Does the water management district also 23 have personal computers that are--that you've not 24 mentioned among the list of micro computers? 25 A. Could you say the question again? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 105 1 Q. Does the water management district have 2 personal computers other than machines you've mentioned 3 in the list of micro computers? 4 A. I don't think there's any others that 5 exist anywhere within the district that we haven't 6 talked about so far. As you've touched upon different 7 subjects, one or two came to my mind that I wasn't able 8 to recall in running through them. But in going 9 through each department, I am pretty sure now that 10 you've hit on every single system that's there. 11 Q. Does the water management district have an 12 electronic mail system? 13 A. Yes. 14 Q. What is the name of that system? 15 A. There is actually four mail systems that 16 exist in electronic form within the district. 17 Q. Describe the four systems. 18 A. There is a public domain mail package 19 running on the Cyber obtained from Georgia Tech 20 University. It is--there is a Xerox mail system that 21 exists in the Xerox work stations. There is a mail 22 system running on the VAX's called VAX mail. And 23 there's a mail system running on the UNIX work station, 24 and I believe the name is SMNP. 25 Q. Where are the UNIX work stations located PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 106 1 that have this SMNP electronic mail system? 2 A. Within the planning department, research 3 and evaluation department, and tech services 4 department. 5 Q. And how is--how are the messages stored on 6 this SMNP system? 7 A. A clearing house is set up that identifies 8 each user name, and mail can be sent across the TCP 9 protocol from one user name to another, and it is 10 stored on whichever system contains the list of valid 11 names. 12 Q. Is a backup or any archival record of this 13 SMNP electronic mail maintained? 14 A. No. 15 Q. Is there any across-the-district 16 electronic mail system accessible by every person that 17 has a PC or micro computer or access to a mini 18 computer? 19 MR. FROST: Could you--I don't understand 20 the question. Can you repeat? 21 BY MS. NASH: 22 Q. If there is one electronic mail system 23 that crosses-- 24 A. All boundaries? 25 Q. --all boundaries. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 107 1 A. There is not a single system in production 2 that spans all boundaries. Gateways have been set up 3 from SMNP to VAX mail and from Xerox mailing to VAX 4 mail, but only the individuals that happen to know it 5 exists are using those gateways. 6 The second of the two, the Xerox gateway, 7 has just come to production-capable status in the last 8 30 days. Very few users are aware that that linkage 9 exists yet, and training is planned for the future to 10 make a global computer network for mail purposes. 11 Q. Where are the Xerox work stations located 12 that have the Xerox mail system? 13 A. I believe in every department. 14 Q. And how is the--how are the messages 15 stored on the Xerox mail system? 16 A. In a Xerox 8090 server, a mail 17 clearinghouse exists where the mail packets are stored. 18 Q. Is there any backup system for the Xerox 19 mail system? 20 A. Yes. 21 Q. What is that? 22 A. Weekly backup is made of the clearinghouse 23 to permit restoring for disaster recovery purposes, 24 though it does have some bugs in it. 25 Q. Is any archival record kept of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 108 1 electronic mail on the Xerox system? 2 A. Only if the individual were to print a 3 message prior to sending it or the receiver were to 4 print it after receiving it or save the no message for 5 permanent record. 6 Q. You mentioned the public domain mail 7 package on the Cyber. By which divisions is that 8 accessible? 9 A. Accessible across the whole district to 10 anyone who logs on to the Cyber, which, of course, 11 requires having a Cyber log-on. 12 Q. Are there any gateways between this public 13 electric domain mail package and any of the other 14 electronic mail systems? 15 A. No. 16 Q. You mentioned VAX mail. Which divisions 17 would have VAX mail? 18 A. Pretty much any division and department 19 that has a log-on to the VAX has the potential--excuse 20 me, has the potential of using VAX mail. 21 Q. How are messages stored on the VAX mail? 22 A. Internal to deposition VAX mail system, 23 those messages are stored. 24 Q. Is there any backup for the electronic 25 mail on the VAX mail? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 109 1 A. When the volume backups occur once a week, 2 the entire mail system would be backed up with it on 3 the appropriate volume. 4 Q. And is any archival record made of the 5 electronic mail on the VAX system? 6 A. No. 7 Q. Does the water management district have a 8 computerized document processing system for document 9 images? 10 A. I don't believe so. It may have at one 11 time, but I don't believe there's any at this point. 12 I guess let me qualify slightly. 13 MR. FROST: Could you repeat the question 14 again, what we're dealing with. 15 You want your answer read back? 16 A. No. 17 I guess I--I guess the answer is really 18 no. I was thinking that maybe state requirements were 19 something you were asking about. There were certain 20 state requirements for copies being kept, but they're 21 not computerized. 22 BY MS. NASH: 23 Q. Is there networking capability between the 24 micro computers and any of the mini computers or 25 mainframes? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 110 1 A. Yes. 2 Q. How does that operate? 3 A. An Ethernet board is installed in pretty 4 much every micro computer located anywhere within the 5 district's network. And any that aren't on the network 6 would normally have a modem to be able to call into the 7 network for limited access. 8 Q. And this is true whether the micro 9 computers are in headquarters or one of the field 10 sites? 11 A. That is correct. 12 (Short break.) 13 BY MS. NASH: 14 Q. Your testimony was that almost every micro 15 computer in the district is on the network and that 16 would allow them transfer of both data files and text 17 files and anything else between any other micro 18 computer and any mini computer; is that correct? 19 A. No. 20 Q. Okay. 21 Would you clarify, please. 22 A. Okay. 23 It can transfer data files to and from the 24 VAX 6310 as a result of the software doing disk 25 services, also from a PC to a PC server, but you cannot PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 111 1 transfer from a PC to a PC. 2 Q. Are there any PC's that you've mentioned 3 that do have the capability of transferring text files 4 or data files? 5 A. This network, All of the personal 6 computers have the ability to transfer text and binary 7 files to and from the PC servers and the VAX 6310, but 8 not from a single PC to another single PC. 9 Q. See if I can understand this at this 10 point. 11 If a text file, for example, is 12 transferred from one PC to the PC server, can the file 13 then be transferred from the PC server to a different 14 PC? 15 A. Yes. 16 Q. So that although it's not a direct 17 transfer, you can then do transfers from one PC to 18 another by going through the PC server. 19 A. Correct. 20 Q. And would the same also be true of 21 transfer from the PC to the VAX 6310, that files could 22 then be transferred from the PC to the VAX 6310 and 23 then from the 6310 to another PC? 24 A. That is correct. 25 MS. NASH: I have no further questions at PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 112 1 the moment. 2 MR. FROST: "At the moment," are you 3 finished? 4 MS. NASH: I'm finished. 5 MR. FROST: Okay. Because when you're 6 finished, you're finished. 7 MS. NASH: I'm finished. 8 MR. FROST: Okay. 9 MR. RICHARDS: Well, I have a few 10 questions. I don't think I'll be able to finish 11 by five o'clock. I don't know if you want to 12 break now and resume in the morning. 13 MR. FROST: That's fine with me. 14 MS. NASH: That's fine. 15 MR. RICHARDS: Let's do that, then, and 16 I'll start up in the morning. I don't think 17 I'll go past lunch. 18 MR. FROST: Okay. 19 And we'll have other people here. 20 MS. NASH: Don, can you indicate who you 21 will be producing next? 22 MR. FROST: I think next we'll have Dave 23 Sweet. Again, that depends upon how long 24 tomorrow goes. We keep moving people, having 25 to shuffle people, because we aren't sure how PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 113 1 the questions are going. But he's the next 2 person that we're anticipating. 3 MS. NASH: Okay. 4 MR. FROST: What time do you want to start 5 tomorrow? 6 MR. FROST: Start the same time. 7 MS. NASH: Ten o'clock. 8 MR. RICHARDS: You want to start at nine? 9 MR. FROST: I would really discourage it. 10 Just given the length that we're going with each 11 person here, at least the nine o'clock or ten 12 o'clock hour allows that person to get their 13 work done. 14 MR. RICHARDS: How about 9:30? 15 MR. FROST: I'd really like to start at 16 ten. 17 MR. DAVIS: We start earlier, we can quit 18 earlier. 19 MS. NASH: Ten o'clock's fine. 20 MR. FROST: Would 9:30 be better? 21 Let's go with ten. 22 THE WITNESS: Either way's fine. Whatever 23 you want to do. 24 MR. FROST: We can start at 9:30 tomorrow. 25 MR. RICHARDS: Okay, 9:30. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 114 1 (Whereupon, the deposition was adjourned 2 at 4:30 p.m., and resumed on Friday, August 10, 3 1990 at 9:38 a.m., at Suite 303, 324 Datura 4 Street, West Palm Beach, Florida, where the 5 following proceedings were held.) 6 CROSS EXAMINATION 7 BY MR. RICHARDS: 8 Q. Good morning, Mr. Hall. I'm Joe Richards. 9 I represent the Cities of Belle Glade and Clewiston, 10 and I'll be asking you a few questions this morning. 11 And if you don't understand any of my questions or you 12 need clarification, please ask me. 13 Would you do that? 14 A. I sure will. 15 Q. Yesterday you discussed several different 16 computer systems, mainframes and mini computers; is 17 that correct? 18 A. That is correct. 19 Q. And for those different computers, is 20 there one individual who would be responsible for the 21 operation and maintenance of those computers? 22 A. Ah, no. 23 Q. How about the data on those computers; 24 would there be one person that would have knowledge as 25 to what is contained on the different computers? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 115 1 A. I think your question needs to be more 2 specific. 3 Q. Okay, let's talk about the Cyber 830. Is 4 there one person at the district who is most 5 knowledgeable as to what is contained on that computer? 6 A. Ah-- 7 Q. Who would that person be? 8 MR. FROST: Can we ask--let him answer the 9 first question? 10 A. Ah, I don't know if I would say one person 11 most knowledgeable, but yes, there is one person that's 12 a key for approvals, setting up, allocations, et 13 cetera. 14 Again, each individual has selected files 15 of their own, and we would not have knowledge of a 16 certain file containing a certain piece of data that 17 was known only to one individual in that one person's 18 account. 19 BY MR. RICHARDS: 20 Q. Who is that one person you mentioned at 21 the-- 22 A. Stephen McNeil. 23 Q. And for the VAX 8820, is there a similar 24 individual? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 116 1 Q. Who is that? 2 A. Connie Falls. 3 Q. And for the VAX 6310? 4 A. Yes. 5 MR. FROST: We need the question first. 6 What question is on the table? 7 BY MR. RICHARDS: 8 Q. Is there a similar individual for the VAX 9 6310? 10 A. Yes. 11 Q. And that person? 12 A. Connie Falls, F-a-l-l-s. 13 Q. And is there a similar individual for the 14 Perkin Elmer? 15 A. Could you repeat the whole question? 16 Q. Is there a single person that is--would 17 you have knowledge as to the data contained on the 18 Perkin Elmer mini computer? 19 A. Yes. 20 Q. Who is that person? 21 A. Tom Raishe, R-a-i-s-h-e. 22 Q. And is there an individual that would have 23 knowledge as to the data contained on the Computer 24 Vision mini computer? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 117 1 Q. Who is that individual? 2 A. Robert Brown, B-r-o-w-n. 3 Q. And there's three Micro VAX two computers; 4 is that correct? 5 A. That is correct. 6 Q. And one is called the Vynanek, Rudy 7 Vynanek? 8 MR. FROST: Are you asking if that's one? 9 MR. RICHARDS: Yes. 10 THE WITNESS: I am sorry, can you repeat 11 the question? 12 BY MR. RICHARDS: 13 Q. One of those Micro VAX is referred to as 14 the Rudy Vynanek computer? 15 A. Yes. 16 Q. And is there an individual who has 17 knowledge as to the data files contained on that 18 computer? 19 A. Yes. 20 Q. Who is that person? 21 A. Rudy Vynanek. 22 Sorry for that. 23 MR. FROST: That's okay. 24 BY MR. RICHARDS: 25 Q. Okay, and for the Dewey Worth, would that PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 118 1 be Dewey Worth, the person with the most knowledge as 2 to what's contained on that computer? 3 A. I believe so, yes. 4 Q. Would there be-- 5 MR. FROST: Excuse me, object. But do you 6 know? 7 THE WITNESS: The question makes--a single 8 person makes the question hard to answer. 9 MR. FROST: Okay. 10 BY MR. RICHARDS: 11 Q. Is there any other individuals that would 12 have knowledge as to the contents of the Dewey Worth 13 computer? 14 A. Yes. 15 Q. Who are those individuals? 16 A. Ah, Ken Rutchey, I believe R-u-t-c-h-e-y, 17 though I may not have the spelling correct. 18 Q. Is there anyone else? 19 A. No. 20 Q. Okay, and for the Robert Mann Micro VAX, 21 the person with the most knowledge as to the contents 22 of that computer be Robert Mann? 23 A. No. 24 Q. Who would that individual be? 25 A. David Sweet. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 119 1 Q. And there's also some Mod Comp mini 2 computers; is that correct? 3 A. Yes. 4 Q. How many? 5 A. Quantity two Mod Comp mini computers. 6 Q. Is there any way to distinguish between 7 the two; is there different names? 8 MR. FROST: Could you clarify your 9 question? I believe you have two there. 10 BY MR. RICHARDS: 11 Q. Is there any way that the district 12 distinguishes the two computers? 13 MR. FROST: Do you understand the 14 question? 15 A. I do understand the question. 16 Yes, the district has a name for each of 17 the two systems. 18 BY MR. RICHARDS: 19 Q. What are the names? 20 A. I'm not positive of the names. I believe 21 it's left Mod Comp and right Mod Comp. 22 Q. For the left Mod Comp, who would be the 23 individual with the most knowledge as to the data 24 contained on that computer? 25 A. Rudy Vynanek. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 120 1 Q. And for the right Mod Comp? 2 A. Rudy Vynanek. 3 Q. Is there a list of all the users and the 4 space allocations for the different computers, 5 mainframes and mini computers? 6 A. Could you be more specific about the word 7 "list"? 8 Q. Is there some hard copy printout of the 9 users for the different computers? 10 A. Sometimes yes, sometimes no. 11 Q. Could you clarify that for me? 12 MR. FROST: Do you need the question to be 13 clarified? 14 THE WITNESS: I'm gonna try to restate 15 what I think the question is, if that's proper 16 to do this. 17 MR. FROST: You go ahead and try-- 18 THE WITNESS: Why don't you restate the 19 question. 20 BY MR. RICHARDS: 21 Q. If I wanted to know who the users were for 22 this Cyber 830, would there be a list-- 23 A. Yes. 24 Q. --of those names? 25 A. Excuse me. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 121 1 Yes. 2 Q. And is there a name for that list? 3 A. Yes. 4 Q. What's that name? 5 A. Cyber user number report. 6 Q. Does that same list also contain the space 7 allocations? 8 A. No. 9 Q. Is there a list of the space allocations? 10 A. No. 11 Q. Is there a similar list of the users for 12 the mini computers? Let's start with the VAX 8820. 13 MR. FROST: Could you again--that's--I 14 believe we are talking about two lists or you've 15 asked about two lists. Which list are you 16 talking about now? 17 MR. RICHARDS: The list of the users for 18 those computers. 19 A. No. 20 BY MR. RICHARDS: 21 Q. Is there a list of the users for the VAX 22 6310? 23 A. Let me qualify that. I'm not aware of a 24 list-- 25 Q. Okay. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 122 1 A. --by your definition. One may exist. 2 Q. If there is such a list, who would know, 3 who would I ask about that? 4 A. Connie Falls. 5 Q. And for the Perkin Elmer, do you know of 6 such a list? 7 A. I am not aware of an allotment list. 8 Q. If I wanted to know, I would ask Tom 9 Raishe? 10 A. That is correct. 11 Q. And for the Computer Vision, I would ask 12 Robert Brown for such a list? 13 A. That is correct. 14 Q. Is there an individual for the Cyber 830 15 who assigns the accounts or the user numbers used for 16 access to that computer? 17 A. There is not a single individual that 18 assigns accounts for the Cyber system. 19 Q. How are those accounts assigned? 20 A. Cyber user numbers are assigned by a 21 written request form submitted to computer management 22 and then processed by computer operators. 23 Q. And for the VAX 8820, is there an 24 individual who assigns account or user numbers? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 123 1 Q. Would that individual be Connie Falls? 2 A. Yes. 3 Q. And for the VAX 6310, would that be Connie 4 Falls? 5 A. Yes. 6 Q. And the Perkin Elmer, that would be Tom 7 Raishe? 8 A. I believe so. 9 Q. If I wanted to know for sure, I would ask 10 Tom Raishe? 11 A. That is correct. 12 Q. And for the Micro VAX 2 Dewey Worth? 13 MR. FROST: What is the question? 14 BY MR. RICHARDS: 15 Q. Who assigns the account or user numbers; 16 do you know? 17 A. Not for certain. 18 Q. Who would you ask if you wanted to know 19 that? 20 A. Dewey Worth. 21 MR. FROST: Are you okay? 22 THE WITNESS: Excuse me. 23 BY MR. RICHARDS: 24 Q. Talking about the Cyber 830, you mentioned 25 that it had several types of data, including water PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 124 1 level data; is that correct? 2 A. Yes. 3 Q. Does that computer also contain water 4 quality data? 5 A. I don't know. You might have to be more 6 specific when you say "water quality data." 7 Q. Do you know that it contains any water 8 quality data? 9 MR. FROST: Again, object. The witness 10 doesn't understand what you mean by "water 11 quality data." He's asking to be more specific. 12 BY MR. RICHARDS: 13 Q. Just in general terms, any water quality 14 data contained on that computer? 15 A. The Cyber contains information on water at 16 district structures. I don't know if I could classify 17 any of that data as water quality, but there is the 18 potential that some would be water quality, as opposed 19 to quantity. 20 Q. Is this an individual at the district who 21 would have knowledge as to the nature of the water data 22 contained on that Cyber computer? 23 A. Yes, there is an individual, but there may 24 be more than one individual that would know all the 25 answers. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 125 1 Q. Who is that one individual you just 2 referred to? 3 A. Could you repeat the question? 4 MR. RICHARDS: Would you read back the 5 question, please. 6 (Thereupon, the question was read by the 7 Reporter as recorded above.) 8 A. Yes, I believe Rob Startzman would know 9 the content of the data for water quantity and quality 10 on the Cyber. S-t-a-r-t-z-m-a-n. 11 BY MR. RICHARDS: 12 Q. Are you aware of a water quality 13 monitoring program by the district, a districtwide 14 water quality monitoring program? 15 MR. FROST: Object. What do you mean by 16 "a water quality monitoring program"? 17 BY MR. RICHARDS: 18 Q. Do you understand the question? 19 A. The question's very broad. 20 MR. FROST: I'd like to--also, I'd like to 21 get on the record, I believe the purpose of this 22 deposition is not to get into how data is 23 collected and what programs the district may 24 have for collecting data, but seems to be 25 limited to the purpose of obtaining information PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 126 1 about the data as it's collected on the computer 2 system. 3 MR. RICHARDS: I'm just trying to find out 4 the individuals responsible for these particular 5 facets of data. I'm not going into any more 6 than that. I just want to ask him if he's aware 7 of this program. 8 MR. FROST: Could you define "program," 9 then? 10 MR. RICHARDS: The biweekly monitoring of 11 water quality at all the district pump stations. 12 MR. FROST: What's your question? 13 BY MR. RICHARDS: 14 Q. I'm asking him if he's aware of this 15 monitoring program. 16 A. I am not aware of a district policy, what 17 I would call a program; in other words, an objective, 18 as opposed to computer program, to collect water 19 samples every two weeks at the pump stations. Though 20 multiple source of data coming into the district--and 21 in reference to the word "pump station" or "field 22 station," would automatically imply operations and 23 maintenance department, in which case very possibly 24 Rudy Vynanek would be knowledgeable in what you're 25 referring to. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 127 1 BY MR. RICHARDS: 2 Q. I believe a little while ago you mentioned 3 monitoring of water quality and quantity at pump 4 stations; is that correct? 5 A. I did not reference pump stations as to 6 the sole source of water quality and quantity. The 7 district has many sensors in the field, and they 8 collect data regarding the water that could be 9 classified as quantity or quality. 10 Q. That data you just referred to, where is 11 that stored? 12 MR. FROST: Could you be more specific? 13 You are talking about water quality and quantity 14 data? 15 MR. RICHARDS: He just referred to data 16 collected throughout the district at different 17 sensors. 18 A. Right. Data being collected, and not 19 trying to distinguish quality from quantity, is stored 20 in the short-term, referencing under 48 hours, in the 21 Mod Comp telemetry system, and after 48 hours is 22 transferred to the Cyber preprocessor system for 23 permanent archive. 24 BY MR. RICHARDS: 25 Q. Who would be the individual at the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 128 1 district most knowledgeable as to this data that is 2 collected onto the Mod Comp and later transferred to 3 the Cyber 830? 4 A. It's difficult to say that there is a 5 single individual that's most knowledgeable in that 6 data that is stored in a permanent archive. I would 7 reference Rob Startzman as being the individual that 8 would have the most general knowledge of the data, and 9 then individuals he would use for more specific data on 10 how it's stored and the operation of that system on a 11 daily basis. 12 Q. Could you-- 13 A. Have I answered your question? 14 Q. Yes. 15 Could you list those other individuals? 16 A. The other individuals that previously or 17 currently report to Rob that are knowledgeable in the 18 permanent archive of this data would be Marilyn 19 Herring, Paul Ryan, R-y-a-n, and Brian Turcott. I 20 believe it's T-u-r-c-o-t-t, but not positive. 21 Q. What divisions do these individuals work 22 in, starting with Rob Startzman? 23 A. Data management division. 24 Q. And the other three you listed? 25 A. Could you name them? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 129 1 Q. Marilyn Herrington (sic)? 2 A. Data management division. 3 Q. Paul Ryan? 4 A. I'm not positive of the division name. I 5 believe it's operations division. I do know it's in 6 the department of operations and maintenance. 7 Q. And Brian Turcott? 8 A. Computer manage--data management division. 9 Q. You described a permanent archiving of 10 this data in the Cyber 830; is that correct? 11 A. That is correct. 12 Q. Could you describe this permanent 13 archive--archive system? 14 A. The permanent archive system utilized on 15 the Cyber system accepts data from a multitude of 16 sources, performs some quality analysis on the data to 17 ensure as high as a reliability and accuracy as 18 possible, converts it to one-sided break-point data or 19 calculated data, and stores it on magnetic tape 20 relative to its location in a system commonly referred 21 to as the preprocessor and archive system. 22 Q. Is the raw telemetry data and chemical lab 23 data also stored permanently in some sort of archive 24 system? 25 A. I believe you're really asking two PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 130 1 questions. Can you separate them? 2 Q. The raw telemetry data, is that stored 3 permanently in an archive system? 4 MR. FROST: I believe that's still two 5 questions. 6 MR. RICHARDS: I believe that's only one 7 question. 8 A. I'm sorry, can you repeat it? I just--I 9 want to be accurate on the answer here. 10 BY MR. RICHARDS: 11 Q. Is the raw telemetry data stored in a 12 permanent archive system? 13 A. Because of the word "raw telemetry data," 14 I would have to say no. But I think if your definition 15 and my definition of "raw" are different, I might be 16 able to say yes. 17 Q. What's your definition of "raw"? 18 MR. FROST: I believe we'll let counsel 19 define how they're using the term "raw." 20 MR. RICHARDS: He just referred to "raw 21 data" and answered the question. I'd like to 22 know how he defined it, defined "raw," in that 23 answer. 24 MR. FROST: I think it will be more 25 helpful if you could define how you're using PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 131 1 "raw," so then he could say. 2 BY MR. RICHARDS: 3 Q. Do you have a definition of the word 4 "raw"? 5 A. Yes. 6 MR. FROST: Then you can answer that. 7 BY MR. RICHARDS: 8 Q. Would you please give us that definition. 9 A. Raw data, by my definition, is original 10 readings coming from the field without any loss of data 11 or any correction for errors known to be occurring in 12 the field. Raw data means every point is preserved, as 13 opposed to ones that are superfluous being discarded. 14 Q. Is that raw telemetry data stored in a 15 permanent archive system? 16 A. No. 17 Q. Using that same definition of "raw," is 18 the raw chemical lab data stored in a permanent system? 19 A. No. 20 Q. Are you familiar with the term "quality 21 assurance/quantity control"? 22 A. I'm familiar with the industry's term 23 "quality assurance and quality control." To my 24 knowledge, it has different meanings in different 25 industries. I am familiar with the term. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 132 1 Q. How would you define "quality 2 assurance/quality control" within the confines of your 3 position as director of computer management? 4 MR. FROST: I object. Would counsel 5 please explain the relevance of this to this 6 deposition? 7 MR. RICHARDS: I think quality assurance 8 of the data kept by the water management 9 district is very relevant to the issues of this 10 case. 11 MR. FROST: I-- 12 MR. RICHARDS: And I don't think the 13 confines of this deposition are determined by 14 relevancy at this point in fact finding. 15 MR. FROST: This deposition is limited for 16 the purposes of finding out about the computer 17 system, and if counsel would like to address 18 that question to the computer system. 19 MR. RICHARDS: I think I did limit the 20 question. 21 MR. FROST: The question's very broad. 22 You've asked what do we know about quality 23 control or quality assurance-- 24 MR. RICHARDS: --as director of computer 25 management. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 133 1 MR. FROST: You can answer from that 2 perspective. 3 A. From the perspective of computer data, 4 "quality assurance" has a meaning of checking incoming 5 data against known parameters and rate of change 6 parameters to assure that a reading is not accepted 7 that would obviously be an error if reviewed by an 8 individual, and exception reports are used to monitor 9 quality assurance. 10 BY MR. RICHARDS: 11 Q. Are these parameters set out in a written 12 format? 13 A. The answer is different for each system 14 the district has. 15 Q. For the Cyber 830, is there a written 16 quality assurance parameters? 17 A. Yes. 18 Q. Does that document have a name? 19 A. It would be--it's a little bit difficult 20 for the word "document." I would call this the 21 preprocess system programs and documentation as 22 containing the quality assurance related to the 23 preprocessor data. 24 Have I answered your question? 25 Q. I believe so. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 134 1 For the VAX 8820, is there a set policy or 2 guidelines for this quality assurance and control of 3 data? 4 MR. FROST: Object. I believe that's 5 ambiguous. What does counsel mean by "set"? 6 BY MR. RICHARDS: 7 Q. Is there an official policy? 8 A. At the present time, to the best of my 9 knowledge, there is not an official policy. 10 Q. Has there been one in the past? 11 A. No. Relative, please, to the VAX 8820. 12 Q. Is one in development? 13 A. Yes. 14 Q. What is that policy? 15 A. An RFP, defined as request for proposal, 16 was issued previously by the district to provide the 17 equivalent performance of the preprocessor system under 18 Oricle on the VAX, and that contract is not fully 19 completed yet and not in production. That system or 20 that RFP would be my closest definitions to the quality 21 assurance you're referencing here. 22 Q. What policies at the present time are 23 being used for quality assurance and quality control 24 for this VAX 8820? 25 A. I believe the question is still relative PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 135 1 to the preprocessor system, since this is a multitude 2 of data bases. 3 Q. Yes. 4 A. The preprocessor system is not in 5 production yet, and this is not a production version of 6 the documentation limiting the data going to that 7 system. 8 Q. Yesterday you mentioned a data and 9 security policy; is that correct? 10 A. That is correct. 11 Q. And is this policy systemwide within 12 computer management or is it limited to specific 13 computers? 14 A. Neither. 15 Q. Who is implementing this data and security 16 policy? 17 A. Department of technical services. 18 Q. Is this policy in place? 19 A. No. 20 Q. Is there some predecessor to this policy? 21 A. Only a memo, I believe from 1987, 22 prohibiting the use of pirated data and the use of 23 computer systems for profit. 24 Q. Does this data and security policy cover 25 any other parameters other than use of pirated software PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 136 1 or using the computers for profit? 2 A. Yes. 3 Q. What are those other parameters? 4 A. From the best I can recall, it includes 5 the authorizations required to have access to different 6 systems within the water management district, the 7 responsible parties to assure backups on appropriate 8 systems, the approvals required to obtain computer 9 hardware and software within the district, and other 10 general requirements to help assure the safeguard of 11 data within the district as a whole organizationwide. 12 Since this policy is in a draft, it 13 changes even as we speak. That's why it's difficult to 14 ensure that I've told you all the facets of this 15 policy. 16 Q. Does this policy have an official name by 17 which it's identified? 18 A. Yes. 19 Q. What is that name? 20 A. I'm not positive of the name, but I 21 believe it's called the data and security policy for 22 the South Florida Water Management District. Somehow, 23 as I reviewed it in the past, I skipped over the name 24 without memorizing all the information. I believe 25 that's the correct name, though. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 137 1 Q. Are there present policies in place at the 2 district concerning the requirements met to have access 3 to the different computers? 4 A. Yes. 5 Q. For the Cyber 830, does this policy have a 6 name? 7 A. No. Simply a single form must be 8 completed. 9 Q. And who reviews that form and decides 10 whether access is approved? 11 A. The supervisor of the applicant for the 12 access as delineated by the form, followed by a 13 representative from computer management, which changes 14 depending on quantity of resources requested. 15 Q. That supervisor of the individual which 16 you just mentioned, that would be someone within the 17 same division as the individual? 18 A. I believe it's the division director for 19 the individual, unless a division director is 20 requesting, and then a department director must sign 21 for a division director, and I don't know what 22 approvals we really ask for above that. I imagine a 23 division director would have to go to the executive 24 office, but the supervisor of the employee in whatever 25 department is required on the form. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 138 1 Q. Who makes the decision at the water 2 management district as to whether an outside entity 3 would be allowed access to the Cyber system? 4 MR. FROST: I object to the form. I don't 5 believe we've established an outside entity does 6 have access. 7 BY MR. RICHARDS: 8 Q. Can you answer the question? 9 A. Could you repeat it? 10 Q. Who makes the decision--well, let me back 11 up a little. 12 Is it true that there are agencies outside 13 the district that have access to the Cyber system? 14 A. Yes. 15 Q. And who are those agencies, what agencies? 16 A. From my memory only--and there could be 17 others that I can't think of at present, there are 18 individuals in DER that have been granted access, 19 individuals in USGS that have been granted access. 20 There are at least one university that has been granted 21 access. I'm aware of the University of Florida as the 22 one I'm thinking of. And there have been consultants 23 performing services to the district that have been 24 granted access during the term of their contract. 25 Q. And do you know who at the water PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 139 1 management district made the decision to grant these 2 entities access? 3 A. The single form that grants access to the 4 Cyber 830 requires the signature of the director of 5 computer management when the individual requesting 6 access is not a district employee. I am the director 7 of computer management and will typically go talk to 8 the sponsor within the district that completed the form 9 and submitted it, and then talk, as a minimum, to the 10 director of technical services on his blessing of the 11 request. 12 The director of technical service will 13 sometimes escalate this further if it's, in his 14 opinion, if it could be jeopardizing any resources, 15 data, or computer use for profit within the district. 16 Q. If the director of technical services so 17 escalated, as you said it, who would he go to? 18 A. I suspect either the department director 19 for the department sponsoring the request, or one of 20 the two deputy executive directors, or the executive 21 director, the only ones I could think of that he would 22 go to. 23 MR. FROST: I object and move to strike on 24 asking for speculative answer. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 140 1 BY MR. RICHARDS: 2 Q. Do you have knowledge as to who the 3 director of technical services would go to if he wanted 4 to escalate it, as you said it? 5 MR. FROST: Understand the question? 6 Object to the form as ambiguous. 7 You can go ahead. 8 A. I am aware of two instances previously 9 where the director of technical services went to other 10 individuals to assure that this would not be abusing 11 district resources. 12 BY MR. RICHARDS: 13 Q. And do you know who those individuals are? 14 A. One individual was the director of 15 resource planning, a previous department that existed 16 in the district, and the other individual was the 17 executive director of the district. 18 Q. And in these two instances you referred 19 to, who was the outside agency seeking access? 20 A. In the case of visiting the director of 21 resource planning, the outside agency was the 22 University of Florida. 23 Q. And for the instance where the executive 24 director was contacted? 25 A. In the instance where the director of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 141 1 technical services asked the executive director for his 2 opinion granting a request, a consultant performing 3 services for the executive office wanted access. And I 4 can't remember the consultant's full name, but I 5 remember the first name was Patty, I believe. 6 Q. Are you aware of any problems with any 7 outside agencies or parties that have had access to the 8 system and those parties using the system? 9 MR. FROST: Object to as being ambiguous 10 by "problems." What is counsel referring to? 11 Or at least limit it to computer problems. 12 BY MR. RICHARDS: 13 Q. Do you understand the question? 14 A. Yes. 15 Q. Could you please answer. 16 MR. FROST: Only answer to the extent it's 17 limited to computer problems. 18 BY MR. RICHARDS: 19 Q. Would you please answer. 20 A. The question is ambiguous in the fact are 21 you referring to problems from the district or problems 22 for the consultant or outside party? 23 Q. Problems for the district. 24 A. I am not aware of any problems to the 25 district for outside parties having access to the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 142 1 system. 2 Q. Are you aware of any problems with 3 maintaining the integrity of the data when the system 4 is accessed by outside parties? 5 A. I am not aware of any alteration of data 6 by an external party. 7 Q. You mentioned that consultants have had 8 access to the computer. Are you aware of which 9 consultants have had such access during the past two 10 years? 11 A. Yes. 12 Q. Could you please name those consultants? 13 A. The contract at the University of Florida 14 was given access, and I don't know the full purpose in 15 the access, just that it was sponsored by the director 16 of data management. There have been requests from DER 17 and USGS. Again, the sponsor was the director of data 18 management. 19 MR. FROST: I believe the question is 20 limited to consultants. 21 BY MR. RICHARDS: 22 Q. Do you know which consultants have had 23 access? 24 A. I was treating USGS and DER as a 25 consultant and maybe that was incorrect. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 143 1 The consultant advising the executive 2 office on affairs was given access, and it has since 3 been taken away since the contract has expired. 4 A previous employee was contracted to for 5 work and was given access from a university to complete 6 some work for data management office. The employee was 7 from computer management--or excuse me, data 8 management. Unfortunately, I cannot remember his name, 9 just that it was data base design work. 10 Q. Are you aware of any other consultants who 11 have had access? 12 MR. FROST: Can we clarify to what 13 computer again we're talking about having access 14 to? 15 MR. RICHARDS: The Cyber 830. 16 A. That's important, because I have limited 17 these questions to the Cyber 30. 18 From the top of my memory, that's the only 19 external agencies that have had access, to the best of 20 my knowledge, in the last two years. 21 MR. RICHARDS: I'm sorry, I missed. Could 22 you read it back? 23 (Thereupon, the last answer was read by 24 the Reporter as recorded above.) 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 144 1 BY MR. RICHARDS: 2 Q. For the VAX 8820, are you aware of any 3 outside entities that have had access to that system, 4 presently have access to that system? 5 A. I am aware of only one consultant that has 6 access to the VAX 8820 presently. 7 Q. Who is that consultant? 8 A. Oracle Corporation. 9 Q. Do you know for what purpose? 10 A. For the purpose of completing a contract 11 to develop software in Oracle. 12 Q. For the VAX 6310, are you aware of any 13 outside entities that have access to that system? 14 A. No external consultants with the exception 15 of Digital Equipment Corporation, which has controlled 16 access during machine malfunctions. 17 Q. For the Computer Vision mini computer, are 18 you aware of any outside access? 19 A. I am not totally knowledgeable in that 20 area, but I am not aware of any external access. 21 Q. Who would be aware of any external access? 22 A. Robert Brown. 23 Q. And for the Dewey Worth Micro VAX II, are 24 you aware of any outside access? 25 A. I am only aware of one external access, PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 145 1 but I believe that it's only the district accessing 2 data from the University of Miami, but there is a 3 linkage set up to receive land sat photography. I 4 don't know if it can go both directions rather than 5 just one. 6 Q. And for the Rudy Vynanek Micro VAX, are 7 you aware of any outside access? 8 A. Again, I'm not fully knowledgeable of any 9 external access other than district employees. I am 10 not aware of any, but this is not an area that I 11 consider myself totally knowledgeable. 12 Q. As far as in-house access within the 13 district, is there a set policy as to who will be 14 granted excess--access to the Cyber 830, other than the 15 form you mentioned earlier? 16 A. No, the form I mentioned previously is the 17 only technique for gaining access to these systems. 18 Q. And that applies for all the mini 19 computers, also? 20 A. No. 21 Q. What policy determines who has access to 22 the VAX 8820? 23 A. A log-on sheet, similar and very possibly 24 the exact same sheet, used for the Cyber system is also 25 used for the VAX 8820 obtaining an account, and thereby PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 146 1 an allocation of disk space, as well as access as we've 2 referenced it here. 3 Q. And who approves that access? 4 A. The same procedures as the Cyber. The 5 supervisor of the individual, then appropriate 6 individual within computer management. 7 Q. Is there a policy for gaining access to 8 the Micro VAX II computers? 9 A. No, there is not, at least to the best of 10 my knowledge, other than contacting the individuals 11 described previously for requesting permission. 12 Q. And for the Computer Vision mini computer, 13 is there a policy for gaining access? 14 A. I am not aware of one. 15 Q. Is there a policy for setting priorities 16 for access? 17 MR. FROST: I object to the form of the 18 question. No foundation to ask that. 19 BY MR. RICHARDS: 20 Q. Do you understand the question? 21 A. No, there's not enough information 22 regarding what system you're referencing here. 23 Q. Is there a priority system for access for 24 the Cyber 830? 25 A. No. All users are initially granted equal PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 147 1 priority, and only when someone is in need of 2 additional CPU power, they contact computer management 3 personnel and request them to escalate selected jobs at 4 that given time. There is no written policy on when we 5 do and do not approve escalating single jobs. 6 Q. Are you aware of any instances where the 7 workload of the Cyber 830 would result in problems as 8 to access insofar as certain individuals would have to 9 wait their turn, so to speak? 10 MR. FROST: Could you--I object. That's 11 a--I don't understand the question. 12 BY MR. RICHARDS: 13 Q. Do you understand the question? 14 A. Yes. 15 Q. Could you please answer? 16 A. I am aware of problems in completing 17 selected jobs in a timely-enough fashion due to the 18 workload of the system, not having enough resources to 19 perform time critical jobs. 20 Q. How often do those--does that occur? 21 A. In the past two years, there are periods 22 where it was unbearable for multiple days at a time, 23 especially just prior to governing board meetings. 24 Changes in even the operations schedule of the 25 operating systems have even been made because of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 148 1 frequency. This month, the problem does not seem to be 2 very serious. 3 Q. As far as in-house access, are there 4 procedures set up to protect the integrity of the data 5 files on the Cyber? 6 A. Yes. 7 Q. Could you describe those? 8 A. The data files on the Cyber system are 9 backed up daily utilizing a control data routine called 10 PF DUMP to back up all files that have changed so far 11 that week and all files once a week. And those weekly 12 backups go through a rotation cycle offsite for 13 disaster recovery purposes. 14 Q. Are there any precautions or procedures 15 taken to prevent the changing of the data on the Cyber 16 system? 17 A. I think you need to be more specific about 18 what type of data, since there is a lot of data we've 19 not made reference to yet on the Cyber. 20 Q. For the water quality data? 21 MR. FROST: What is the question? 22 MR. RICHARDS: Would you read back the 23 question, please. 24 (Thereupon, the question was read by the 25 Reporter as recorded above.) PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 149 1 A. The data being stored for permanent 2 archive of water quality/quantity data are protected by 3 passwords disallowing access to user numbers that 4 should not access the data when it's on line. 5 After it goes to archive, it is normally 6 copied off to magnetic tape. And the only security 7 that I am aware of that would obstruct alteration of 8 the data would be the physical mounting of the computer 9 tape by an operator upon request through the system. 10 If the operator realizes that you are not permitted 11 access to that tape, since you do not own it, the 12 operator would reject your request to mount it, with or 13 without a right ring. 14 There are also provisions in the 15 preprocessor system to ensure reasonability of the 16 data, and these could act to prevent an unreasonable 17 change. There may be other safeguards in the 18 preprocessor system prior to archive that I am not 19 aware of that the previous parties we've talked about 20 would be aware of. 21 Q. Are you aware of the term "read only 22 file"? 23 A. Yes. 24 Q. How would you define that? 25 A. A file on a computer system that has been PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 150 1 earmarked for read access only, permitting typically 2 the reading but not the execution of data but 3 obstructing altering the data without permission. 4 Q. Is it possible to set up read-only files 5 of this historical water quantity and quality data? 6 MR. FROST: I object to the form of the 7 question, asking a witness to speculate as to 8 what is it possible. 9 MR. RICHARDS: You can answer. 10 MR. FROST: Go ahead and answer. 11 A. The Cyber system contains permissions for 12 files to be granted from one user number to another in 13 a read-only status. But since your question pertains 14 to the preprocessor system, I do not know if the system 15 could function properly with the files being granted in 16 a read-only status. 17 BY MR. RICHARDS: 18 Q. For the historical archive of the water 19 quantity and quality data, is it possible to grant 20 access in a read-only format? 21 MR. FROST: Again, I object to the form of 22 the question, asking a witness to speculate. 23 I'll allow him to answer to the extent he knows 24 the abilities of the system. 25 A. Disk files and tape files that contain PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 151 1 archived data could be permitted for access and 2 read-only mode, though I have no knowledge of whether 3 the preprocessor system or the archive report writer 4 could function properly if those files were granted in 5 the read-only mode. 6 BY MR. RICHARDS: 7 Q. Who would know the answer to that 8 question? 9 MR. FROST: Again, I object because this 10 question is piggybacking on an earlier 11 speculative question. It hasn't even been 12 demonstrated that it's possible. 13 A. I would defer to the same three 14 individuals previously of Robert Startzman, or Paul 15 Ryan, or Marilyn Herring, though I don't know if they 16 would know the answer, either, and possibly a test 17 would be required to truly know that answer. 18 BY MR. RICHARDS: 19 Q. Do you know whether the district has 20 provided read-only access to this water 21 level--historical water level, water quantity/quality 22 data? 23 MR. RICHARDS: I object to the form of the 24 question. There's no foundation. 25 A. The district-- PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 152 1 MR. FROST: Can counsel rephrase the 2 question to establish whether or not there has 3 ever been granted access to read-only files? 4 MR. RICHARDS: I asked him if he knew if 5 such access had been granted. 6 MR. FROST: You can answer that question. 7 A. The access that has been granted to the 8 government entities that we have talked about 9 previously was an attempt to grant access in a 10 read-only mode. Because the system is extremely 11 flexible in its capabilities and permission, there is 12 no guarantee that somebody has not exceeded the 13 privileges we attempted to put in place to not allow 14 access to the data in more than read-only mode. 15 BY MR. RICHARDS: 16 Q. Do you know whether this attempt which you 17 just mentioned was successful? 18 A. We are not aware of DER, USGS, other 19 entities, exceeding the restrictions we've attempted to 20 place on them. 21 Q. You stated that these entities have been 22 granted access. Have there been other agencies or 23 entities in the past that have been granted similar 24 access? 25 A. From my recollection, I can think of one, PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 153 1 only one additional party that was granted access. 2 Q. What is that? 3 MR. FROST: Object. First, are we talking 4 about read-only access? Is that how you 5 answered that question? 6 THE WITNESS: Yes. 7 MR. FROST: Okay. 8 A. (continuing) An attempt to provide 9 read-only access was granted to a firm in Miami that I 10 do not know for certain the name of the company as a 11 result of a lawsuit levied against the district. 12 BY MR. RICHARDS: 13 Q. Do you know whether that attempt to grant 14 that read-only access was successful? 15 MR. FROST: Object to as ambiguous. What 16 does counsel mean by "successful"? 17 BY MR. RICHARDS: 18 Q. Do you understand the question? 19 A. I think I do. 20 Q. Please answer it. 21 A. I think you're asking me if I'm aware of 22 somebody altering our data when given read-only 23 permission. And we have not detected alteration of the 24 data, which doesn't guarantee it didn't occur, but 25 we're not aware of any being changed when later data is PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 154 1 examined for accuracy. 2 MR. FROST: You want to take a break at 3 this point? 4 (Short break.) 5 BY MR. RICHARDS: 6 Q. I'd like to return for a moment to the 7 data and security policy we talked over earlier. 8 What department is responsible for 9 developing this policy? 10 A. The department of technical services. 11 Q. Do you know of the particular individuals 12 who are responsible? 13 A. There is a committee drafting that policy, 14 and it's in the approval process with the MAC, M-A-C, 15 management advisory committee. And after that, I 16 believe it goes to the board for ratification as a 17 district policy. 18 Q. Do you know the individuals on this 19 committee? 20 A. Yes. I believe I do, at least. I believe 21 the individuals are chairman Dion Gluck, G-l-u-c-k. 22 Q. She's chairman of the committee? 23 A. That's correct. 24 Myself, Bill Hall, Jim Edwood, 25 E-l-w-o-o-d, and Tom Thayer, T-h-a-y-e-r. I believe PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 155 1 that's the full committee. 2 Q. That committee is the management advisory 3 committee, or is that a separate committee? 4 A. That committee is not the management 5 advisory committee. That is the committee given the 6 responsibility for preparing and submitting this 7 policy. 8 Q. Is there a name for this committee? 9 A. I don't know if a formal name was given, 10 but the members were appointed to a committee to draft 11 the data and security policy. 12 Q. Yesterday you mentioned access to a 13 University of Miami satellite data system; is that 14 correct? 15 A. That--yes. 16 Q. Do you know what system of satellite 17 imagery is contained on that system? 18 MR. FROST: Object. It's a confusing 19 question. 20 BY MR. RICHARDS: 21 Q. Do you understand the question? 22 A. I'd like to have it repeated. 23 Q. What system of satellite imagery is 24 contained within that University of Miami access? 25 MR. FROST: I still object as being PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 156 1 confusing. 2 A. I do find the question a little confusing, 3 but I don't know the answer, regardless. 4 BY MR. RICHARDS: 5 Q. Do you know which individual or 6 individuals at the district use this access? 7 A. Yes. 8 Q. Who are those individuals? 9 A. I believe it's only Dewey Worth, 10 W-o-r-t-h. 11 Q. Do you know how long the district has had 12 this access? 13 A. I cannot remember the exact date it was 14 established, though I do remember Dewey Worth's 15 original request to have the data phone installed. 16 Q. What-- 17 A. But-- 18 Q. --time was that? 19 MR. FROST: Were you finished? 20 THE WITNESS: Wasn't really finished, but 21 that's okay. 22 MR. RICHARDS: Go ahead and finish. 23 A. I do remember a memo coming in requesting 24 it. I can't remember exactly how long ago it was. I 25 guess the phone bill might reflect. If I had to PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 157 1 approximate, I'd say maybe a year ago, maybe a year and 2 a half ago. 3 BY MR. RICHARDS: 4 Q. Yesterday when you were talking about the 5 Computer Vision mini computer, you mentioned that that 6 system contains graphic and spatial images of South 7 Florida; is that correct? 8 A. Yes, that was something we covered 9 yesterday. 10 Q. Do you know the individual who works with 11 these graphic and spacious--spatial images? 12 A. Yes. 13 Q. Who is that individual? 14 A. Bob Brown. I've referred to him as Robert 15 Brown in the past, just for consistency here. 16 An assistant to Robert Brown, who is no 17 longer in that capacity, Patrick Edmondson may or may 18 not today work with that data, and several technicians 19 under the direction of Robert Brown, who digitize and 20 manipulate the data as changes are discovered in the 21 field. 22 Q. And yesterday you mentioned that the Dewey 23 Worth Micro VAX computer contains remote sensing 24 information; is that correct? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 158 1 Q. And who would be the individual with the 2 most knowledge at the district as to that remote 3 sensing information? 4 A. The individual that would have the most 5 knowledge on that data would be Dewey Worth. 6 Q. Do you know of any other individuals at 7 the district who work with this remote sensing 8 information? 9 A. Yes. 10 Q. Who are those individuals? 11 A. Ken Rutchey. I believe it's 12 R-u-t-c-h-e-y. 13 Q. And yesterday you mentioned a software 14 package called ERDAS within the geographical sciences 15 division; is that correct? 16 A. That is correct. 17 Q. And who would be the individual within the 18 district most knowledgeable about this software package 19 and the data contained therein? 20 MR. FROST: Object. Compound question. 21 BY MR. RICHARDS: 22 Q. Who has the most knowledge as to the 23 software package? 24 A. I don't know which one of the three 25 individuals has the most knowledge. The three PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 159 1 individuals are Robert Brown, Pat Edmundson, and Brent 2 Moll, M-o-l-l. 3 Q. And who has the most knowledge as to the 4 data contained within that software package? 5 A. Again, the same three individuals would 6 have knowledge of parts of the South Florida area in 7 that system; possibly Brent Moll would know the most. 8 Q. Do you know of any other individuals 9 within the district who are using this data? 10 A. I am not aware of other individuals, but I 11 would suspect there possibly are others. 12 Q. Yesterday you talked of the Rudy Vynanek 13 Micro VAX II containing an artificial intelligence work 14 station; is that correct? 15 A. "Containing" is not a word I used. 16 Q. What word would you use? 17 A. Located in the same room with it-- 18 Q. Okay. 19 A. --was how I was attempting to describe it 20 at the time. 21 Q. Is there a name for this artificial 22 intelligence work station? 23 A. Yes. 24 Q. What is that name? 25 A. Symbolics 3640, which is its manufacturer PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 160 1 and model number. It does not have a name other than 2 that that I'm aware of that's used within the district, 3 though I have people making reference to it from time 4 to time as OASIS, O-A-S-I-S. 5 Q. And what individual at the water 6 management district would be most knowledgeable as to 7 this Symbolics 3640? 8 A. I believe the individual with the most 9 knowledge is Gary Goforth, G-o-f-o-r-t-h. 10 Q. Do you know what department he's in--or 11 division, rather? 12 A. I believe the division name is 13 construction management division. It's definitely in 14 the department of construction management. 15 Q. Do you know of any other individuals 16 working with this artificial--artificial intelligence 17 work station? 18 A. Yes. 19 Q. Who are those individuals? 20 A. Paul Ryan, R-y-a-n, Venito Floris, 21 F-l-o-r-i-s. 22 Q. Do you know whether this system is 23 operational? 24 A. The word "operational" has multiple 25 meanings. I believe the system is turned on every day, PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 161 1 and whether operators have been trained to use the 2 results of the Symbolics system, I don't know. And 3 whether they classify it as production or 4 non-production, I think they do not. 5 Q. Is this artificial intelligence system 6 designed to control gate operations? 7 MR. FROST: It's an ambiguous question. 8 Object. 9 A. The word "control" does cause the question 10 to be somewhat ambiguous here. Can you be a little 11 more specific? 12 BY MR. RICHARDS: 13 Q. Do you know what the artificial 14 intelligence work station is intended to do, to be used 15 for? 16 A. Yes. 17 Q. What is that purpose? 18 A. To advise a telemetry-system operator of 19 an impending action that they should probably 20 undertake, including changing the position of gates in 21 the field through the telemetry system. 22 Q. In regard to the telemetry system, who at 23 the district would be most knowledgeable as to that 24 system? 25 A. Rudy Vynanek. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 162 1 Q. Yesterday you mentioned two hydrologists 2 who have access from their homes to the district's 3 computer system; is that correct? 4 MR. FROST: I object as far as ambiguous. 5 What system are you talking about? 6 A. I am able to recall two hydrologists that 7 I made reference to yesterday in regard to the 8 telemetry system. 9 BY MR. RICHARDS: 10 Q. Who are those two hydrologists? 11 A. Ron Mierau. I believe it's M-i-e-r-a-u. 12 And George Wha, I believe it's W-h-a. 13 Q. Is it correct that certain department 14 directors and executive office personnel have in-home 15 terminals? 16 A. No. 17 Q. Is it true that certain department 18 directors or executive office personnel have access by 19 modem to the district's computer system? 20 A. Yes. 21 Q. Which systems are accessed by this modem? 22 A. Any system on the network that permits 23 asynchronous communications. 24 Q. Which systems? 25 MR. FROST: I object. I believe that's PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 163 1 been asked and answered. 2 BY MR. RICHARDS: 3 Q. Can you give me the specific systems that 4 meet this criteria of having asynchronous capabilities 5 accessed by modem? 6 MR. FROST: I object. I believe it's a 7 compound question. 8 A. Yes, I can. 9 BY MR. RICHARDS: 10 Q. Please list those for me. 11 A. Cyber 830, Mod Comp classic two's, both 12 systems, VAX 8820 and VAX 6310, VAX--excuse me, Micro 13 VAX II, all three systems. I believe all the UNIX work 14 stations previously mentioned from Sun and DEC. And 15 from the top of my memory, if I haven't overlooked a 16 system, I believe that's all. I meant to include the 17 IBM 4361 system. 18 Q. Do you know which department directors 19 have this modem access? 20 A. I believe I do. I'm not positive I could 21 name them all. 22 Q. Could you please list the ones you do 23 recall. 24 A. John T. Lynch. 25 Q. And his department? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 164 1 A. Department of technical services. 2 Allen Hall, H-a-l-l. 3 Q. His department? 4 A. Department of operations and maintenance. 5 Pete Rhoads, R-h-o-a-d--I believe S. I'm 6 not positive of any of the others. I believe we're 7 talking these seven or eight machines that are at 8 executive staffs' homes, and this is the best I can 9 recall of those that are department directors, et 10 cetera. 11 Q. Do you know who within the executive 12 office has these, these modems, and access? 13 A. I don't believe any of the executive 14 office personnel have access to the district computer 15 system at their home, except I just remembered--and I 16 don't think we've talked about previously, Tom 17 MacVicar, M-a-c-V-i-c-a-r, does have a terminal with a 18 modem at his home fairly recently. 19 Q. This terminal with the modem has the same 20 access capabilities that you described those other 21 department director modems? 22 A. Yes. 23 Q. Is there anyone else within the executive 24 office that has this outside access? 25 A. I don't believe so. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 165 1 Q. Are you aware of any data that is 2 transferred directly from field collectors to the 3 district's computers? 4 A. Yes. 5 Q. Do you know what type of data is so 6 transferred? 7 A. Water quality/quantity data would be 8 electronically transferred. 9 Q. Any other type of data? 10 A. Yes. 11 Q. And what's that? 12 A. Water levels, quantity of rainfall, water 13 conductivity, gate position. There may be some 14 meteorological type of data in that, wind direction, 15 speed, and temperature, though I am less knowledgeable 16 there. 17 Q. Who would be--who at the district is most 18 knowledgeable as to this electronically-transferred 19 water quantity and quantity data? 20 A. I would say three individuals: Rudy 21 Vynanek, George Wha, and Ron Mierau. 22 Q. And who at the district is most 23 knowledgeable about the electronically transferred 24 water level data? 25 A. The same three individuals, as well as Rob PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 166 1 Startzman, S-t-a-r-t-z-m-a-n. 2 Q. Who at the district is most knowledgeable 3 as to the electronically transferred rainfall data? 4 A. I would say Rudy Vynanek and George Wha. 5 Q. Anyone else? 6 A. No. 7 Q. And who at the district is most 8 knowledgeable as to the electronically-transferred gate 9 position data? 10 A. Rudy Vynanek, George Wha, Rob Startzman, 11 and Ron Mierau. 12 Q. And who at the district is most 13 knowledgeable as to the electronically-transferred 14 water conductivity data? 15 A. Rudy Vynanek, George Wha, and Ron Mierau. 16 Q. Are you aware of any scientific data files 17 that have been accidentally destroyed? 18 MR. FROST: Object to the form as being 19 vague and ambiguous. What is meant by 20 "scientific"? 21 BY MR. RICHARDS: 22 Q. As opposed to financial data. 23 A. Yes. 24 Q. Do you know what types of data were 25 accidentally destroyed? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 167 1 A. Data was lost on the Perkin Elmer system 2 approximately one year ago--excuse me, I named the 3 wrong system, on the Britten Lee back-end data base 4 machine approximately one year ago when the drives were 5 swapped out for larger drives, and the backup tapes 6 were unreadable when we went to restore. 7 Q. Do you know the nature of that data? 8 A. Chemical archival data that was 9 originating from a multitude of sources, but I believe 10 all the data was in a form where it could be recreated. 11 Q. Who at the district would be most 12 knowledgeable as to this chemical archive data that was 13 lost? 14 A. Kevin Rodberg. 15 Q. Are you aware of any other data that was 16 lost? 17 A. Yes. 18 Q. What data is that? 19 A. The district purges files off the Cyber 20 system once they are over 90 days old. The data is 21 first preserved on a PF DUMP tape, and then those same 22 files that are over 90 days are then deleted. 23 Approximately three years ago, a user 24 requested restoration of some of their files from one 25 of the monthly purge tapes which are maintained, and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 168 1 portions of that particular tape turned out to be 2 unreadable when we went to restore. 3 Q. Who was that user? 4 A. I do not remember. 5 Q. Do you know the nature of the data? 6 A. I believe it was raw data in the process 7 of being processed and had to be reentered from its 8 original source. 9 Q. Who at the district would know who that 10 user was? 11 A. Laura McLester, M-c-L-e-s-t-e-r. 12 Q. What is her position? 13 A. She has been in the position in the past 14 and still is currently--but we are in a reorganization 15 now, of operations supervisor. 16 Q. Do you know of any other data that was 17 accidentally destroyed? 18 A. Yes. 19 Q. What was that? 20 A. In January, I believe of 1989, our legal 21 department lost three Xerox desk tops containing all 22 the files on those three work stations after a power 23 fail caused the Xerox 8,000 server that they had been 24 stored on to malfunction. 25 Q. Is there any other data that you're aware PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 169 1 of that's been accidentally destroyed or lost? 2 A. During the failure of that same 8,000 3 server, other data, non legal in nature, was also 4 destroyed, and it was recovered from its closest 5 sources of past data. 6 Q. What was the nature of that data? 7 A. Some of the data was memos regarding SWIM 8 activities, and some of the data was opinions rendered 9 on previous contracts. 10 Q. That was all within the legal department? 11 A. No. 12 Q. What other departments? 13 A. The then-existing department of resource 14 planning, I believe, lost some files, as well. 15 Portions of that, I know, were recovered. 16 I don't know if it was all recovered. 17 Q. Who would be most knowledgeable as to the 18 planning department information that was lost? 19 A. Possibly Connie Falls, the analyst that 20 performed the recovery, and possibly some of the users 21 in the resource planning department that assisted with 22 finding other sources of the documents that were all on 23 the drive that went bad. I believe Tony Federico, 24 Kevin Rodberg, and I believe Julia Brooks, representing 25 the executive office files that were lost, as well. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 170 1 I'm not positive of her last name. 2 Q. Do you know of any other data that was 3 lost during this same power failure? 4 A. No, the Xerox server was the only device 5 that malfunctioned after the power fail, and as I've 6 tried to reflect here, much of the data was recovered 7 from a much older backup, as well as from a VAX backup 8 that had been made. But not all the files. 9 Some had to be rescanned in and retyped in 10 to attempt to get back to where we were. But it was 11 limited to the Xerox server, and Connie Falls, the 12 analyst that did the recovery, would--would be 13 knowledgeable in what drawers were affected and to what 14 extent we were successful in finding the source 15 documents and recovering. 16 Q. Would Connie Falls' knowledge as to the 17 loss and recovery span the effect districtwide? 18 A. Yes. 19 Q. Are you aware of any other instances where 20 data has been accidentally destroyed or lost? 21 A. There have been instances where due to 22 operational procedures data in the process of being 23 updated was damaged--excuse me, damaged. But pretty 24 much in all those cases, rerunning the sequences over 25 again after restoring the files back caused no PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 171 1 permanent loss of data. 2 But there have been operational failures 3 over the past five years, but I'm not aware of any 4 causing a loss of data, just an inconvenience of 5 reprocessing. There have been individuals that have 6 had their hard drive on their work station malfunction 7 and lost the data, partial or fully, on that hard drive 8 due to not having adequate backups. That would include 9 floppies and hard drives. 10 Floppies, when it comes to individuals on 11 PC's and Xerox work stations and hard drives, I'm not 12 aware of any UNIX hard drives that have failed and 13 proper backups not been in place. 14 But there have been some hard drives on 15 Xerox work stations--two I can remember right now, 16 others that might have occured in the last three 17 years--that caused a particular user or two or three 18 users to have to scramble and try to recreate the data 19 that was not properly backed up. 20 Q. Are you aware of any individual users that 21 have been so affected? 22 A. Yes. 23 Q. Who are those individuals? 24 A. On Xerox work stations, the only two that 25 come to my mind right now--and I suspect Connie Falls PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 172 1 would be more knowledgeable if there were any others. 2 The only two that I'm aware of is Pete Rhoads 3 approximately three months ago and Robert Hamrick about 4 six months ago. 5 Q. Anyone else? 6 A. That's all I can think of, and I really 7 don't think there are any more in the Xerox work 8 stations. 9 On the personal computer work stations, I 10 can't think of any immediately that really come to 11 mind. There was one server that caused great concern 12 when a 300 megabyte drive went bad, but if I'm not 13 mistaken, all the data was recovered, if not just a 14 lack of one or two memos being lost on that server. 15 Q. Do you know who the individual was 16 involved in that 300 megabyte problem? 17 A. I know the individual that performed the 18 recovery. I don't know what individuals potentially 19 lost some files on that server. 20 Q. Who performed that recovery? 21 A. Don Turner, T-u-r-n-e-r. And that's a PC 22 server. I would say that was February of '90. And I 23 am approximating. 24 Q. Are you aware of any individual users 25 losing data on either a mainframe or mini computer PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 173 1 system? 2 A. Other than the one--other than the ones we 3 have already talked about--I'm limiting the scope here 4 to scientific, no, I do not recall any other losses of 5 data. 6 Q. Are you aware of any instances where 7 scientific data has been lost during transfer from one 8 hardware system to another? 9 A. No, I am aware of no losses in transfers 10 from one computer system to another computer system. 11 Q. Are you aware--other than purging the 12 files, are you aware of any purposely-destroyed data? 13 A. Limiting the scope to computer data and 14 not referencing the purge of files after a certain age 15 on any of the systems in the district, I can't think of 16 any--I can't think of any other instances other than 17 the ones we've just discussed where data was 18 intentionally in any form destroyed. 19 There have been times when an employee 20 left the district and the supervisor of the individual 21 may not have been able to determine what some of the 22 data files left in that user's name was and then they 23 elected to delete them. That's not something that I 24 have heard any complaints about somebody doing; in 25 other words, concern about the loss of data because of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 174 1 an erased file. 2 So no, there's no others that I can think 3 of. 4 MR. RICHARDS: Thank you very much, Mr. 5 Hall. That's all I have. 6 THE WITNESS: Thank you. 7 (Whereupon, the deposition was concluded 8 at 12:01 p.m.) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 175 1 E R R A T A S H E E T 2 PURSUANT TO RULES OF CIVIL PROCEDURE, this deposition is being submitted to you for examination, 3 reading and signing. Please do not write on the transcript. Any change in form or substance you desire 4 to make should be entered upon this sheet as follows: 5 PAGE NO., LINE NO._________CHANGE_____________REASON___ 6 7 8 9 10 11 12 13 Date:__________________ 14 ADDRESS:_____________________ 15 _____________________ 16 COUNTY OF:___________________ 17 18 _________________________ 19 Signature of Witness 20 _________________________ Notary Public, State of 21 Florida at Large. My Commission Expires: 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 176 1 I, BILL HALL, do hereby certify that I 2 have read the foregoing transcript of my deposition 3 given on August 9 and 10, 1990; that together with the 4 correction page attached hereto noting changes in form 5 or substance, if any, it is true and correct. 6 7 8 ____________________________ 9 BILL HALL 10 11 12 I do hereby certify that the deposition of 13 BILL HALL was submitted to the deponent for reading and 14 signing; that after deponent had stated to the 15 undersigned Notary Public that deponent had read and 16 examined said deposition, deponent signed the same in 17 the presence of the undersigned authority on 18 the day of , 1990. 19 20 21 _____________________________ 22 Notary Public 23 My commission expires: 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 177 1 CERTIFICATE 2 THE STATE OF FLORIDA, ) 3 COUNTY OF PALM BEACH. ) 4 I, DONNA McCALLEY, Registered Professional 5 Reporter, and Notary Public for the State of Florida at 6 Large, do hereby certify that I reported the deposition 7 of BILL HALL, called by the Plaintiffs in the 8 above-entitled action; that BILL HALL was duly sworn by 9 me; that the foregoing pages numbered from 1 to 174, 10 inclusive, constitute a true record of the deposition 11 given by said witness. 12 I further certify that I am not attorney 13 or counsel for any of the parties, nor a relative or 14 employee of any of the parties or any attorney or 15 counsel connected with the action in which this 16 deposition is taken, nor financially interested in the 17 action. 18 WITNESS MY HAND and official seal in the 19 City of West Palm Beach, County of Palm Beach, State of 20 Florida, this 17th day of August, 1990. 21 22 23 __________________________________ Registered Professional Reporter. 24 and Notary Public, State of Florida at Large. 25 My Commission Expires: 10/25/90. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 PROFESSIONAL REPORTING SERVICE, INC. Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 August 20, 1990 Mr. Bill Hall South Florida Water Management District 3301 Gun Club Road West Palm Beach, FL 33406 In Re: United States, etc., et al versus South Florida Water Management District, et al Dear Mr. Hall: Your deposition given in the above-styled cause on August 9 and 10, 1990, has been prepared and is ready for you to read and sign. Mr. Frost has asked me to provide his transcript copy for you to review. After you have noted your corrections, please sign the errata sheet and have it notarized. Please send the original errata sheet to my office at the above address as soon as possible so it can be provided to all counsel. If you have any questions about the procedure you are to follow, please call my office. Sincerely, Donna McCalley PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046