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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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THEREUPON:
BILL HALL,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Okay, we are here for what is called a
30(b) deposition. This is a deposition where we are
inquiring about certain categories of information that
the water management district has to understand how the
water management district's computer systems operate,
how people communicate with each other in the district
using computers, what kind of data is stored on the
computers, and how that data is formatted.
Mr. Hall, you've been submitted as a
representative of the water management district having
knowledge concerning one or more of nine categories of
inquiry that we have submitted to your attorneys on the
South Florida Water Management District computer
systems and their comments. Have you been shown that
list of categories?
A. Yes, I have.
Q. For which categories are you being
submitted as the knowledgeable person; do you know?
A. I have some knowledge in almost all of the
6
categories. I don't really know which in particular
I'm designed to be the only representative for.
Q. Then we'll go through all of the
categories.
What is your present title or position?
A. Director of computer management.
Q. Is that in a particular division or
department?
A. It is a division, the division of computer
management, of which I am the director.
Q. What is your job description?
A. To obtain, acquire, set up, operate and
maintain all computer systems within the South Florida
Water Management District, including training,
applications, development, and interoperability of all
district computer systems.
Q. What was that last term?
A. Interoperability.
Q. Would you explain what "interoperability"
means, please.
A. The ability to make different vendors'
computer systems operate across a network to exchange
data and produce common results.
Q. How long have you been in the role of
director of computer management?
7
A. Ah, I was appointed to the position June
1st, 1984.
Q. Have you had other positions at the water
management district?
A. I have had--have had other positions, yes.
Q. What positions have those been?
A. Starting approximately June 1973, I was
hired as a night computer operator part-time. In
approximately July of '75, I was promoted to
applications programmer I.
In approximately 1976, I was promoted to
the systems programmer I. And somewhere between there
and 1983, was promoted to a systems programmer II, and
finally, systems programmer III.
Q. What is a systems programmer I?
A. It's a position responsible for the
development and installation of operating systems and
communications problems on multiple computer systems.
Q. How does that differ from a systems
programmer II?
A. A systems programmer II position has the
same, as well as additional, requirements placed on it
for being a high level--higher level position requiring
more experience and supervision.
Q. Is the job function the same?
8
A. Yes.
Q. And what about system programmer III?
A. Again, additional responsibilities of a
systems programmer II, additional years of experience
required.
(Whereupon, Ms. Waters entered the
deposition room.)
A. (continuing) And additional supervisory
responsibilities added.
MS. NASH: Note for the record an addition
to the room, please.
BY MS. NASH:
Q. Mr. Hall, what's your educational
background?
A. High school degree, bachelor's degree in
computer systems with the business and scientific
option from Florida Atlantic University.
Q. What year was that?
A. 1975.
Q. Have you had any additional formal
education in the computer area?
A. Other than continuing education on
specialized products, the answer is no.
Q. To whom do you report in the water
management district?
9
A. To the director of technical services.
Q. Who is the director?
A. John T. Lynch, Jr.
Q. How many employees of the district do you
have working for you?
A. There are 29 employees within my division
directly or indirectly responding to me.
Q. Generally what are their job descriptions?
MR. FROST: You mean--what do you mean by
"generally"?
BY MS. NASH:
Q. Well, I don't need a description--if there
are six computer operators, I don't need each one
described separately. Just by category, if there are
categories of employees within your division.
A. Okay, we have an assistant division
director.
Q. Who is that?
A. Robert Mann, M-a-n-n. Two supervising
senior systems analysts, one application supervisor,
one senior systems analyst, two systems analysts, one
mainframe data base analyst, one technical instructor,
one micro computer applications developer.
I'm not certain of the counts here, but I
believe three applications developers, one senior
10
computer systems technician, four computer system
technicians, one senior electronics engineer. I'm not
positive if that title includes the word "engineer."
One electronic technician--and excuse me, the previous
title didn't include "engineer." It was senior
electronic technician, not engineer.
One operations supervisor, and four
mainframe computer operators, one administrative
assistant, and one administrative secretary.
That's the best I can recall at this
point.
Q. What are the computers that are used at
the water management district, starting with the
mainframe?
MR. FROST: You're directing this to the
mainframe, this first question?
MS. NASH: This first question is directed
to the mainframe or frames.
MR. FROST: Okay.
A. There's a slight gray area on what is the
mainframe and what is a smaller system. I'm
categorizing two of our systems as mainframes, and
those are an IBM 4361 Model 5MO, IBM mainframe, and a
Cyber--that's spelled C-y-b-e-r, 830 mainframe.
11
BY MS. NASH:
Q. Do you have additional systems that you
would not call mainframes other than mini computers or
micro computers and PC's?
A. No. I don't have any other systems that I
would call mainframes that are not one of those.
Q. What operating system or systems do you
use on the IBM 4361?
A. IBM VSE/SP Version 4.1.
Q. Any others?
A. On the IBM?
Q. On the IBM.
A. No.
Q. And what operating system or systems do
you use on the Cyber 830?
A. Two operating systems: CDC NOS, spelled
N-O-S, and I do not know the current release, and CDC
NOS, NOS/VE. Again, I do not know the current release.
Q. What are the various software packages
that are used on the IBM 4361?
A. There are system utilites acquired from
IBM to make the system functional, and outside of
those, we have MSA software performing our financial
business for the district, as well as a number of
third-party software packages designed to maintain the
12
financial data files' backups and performance of the
system.
Q. Can you name those third-party software
packages?
A. Yes. We have four modules from
Goals--that's G-o-a-l-s, Systems, designed to help tune
VCN files. I believe the names are VSAM--that's
V-S-A-M, AIDS, A-I-D-S. I believe the second one's
called HYPER, H-Y-P-E-R. Third one is called FAVOR.
And I can't remember the name of the fourth one. All,
again, are related to backing up or file tuning.
We also have computer associates DUN M/T.
I believe the spelling is D-U-N M/T, or close to it.
Q. And what is that software package used
for?
A. That software package is used to compress
data files for backup to magnetic tape--or excuse me, I
described the previous package. That package--
MR. FROST: Can you clarify which package
you're talking about?
BY MS. NASH:
Q. The DUN M/T.
A. The DUN M/T is used to keep track of all
the magnetic tapes and IBM 3480 cartridges being used
on the IBM system.
13
Q. And which package were you describing when
you said one was used to compress data files?
A. That was FAVOR that compresses data files
when they're being backed up to magnetic tape or
cartridges, and, of course, depresss them when they're
copied back down.
Q. What input and output peripherals are
there on the IBM 4361?
MR. FROST: I object. That's a compound
question. Can we do it--do one or the other?
BY MS. NASH:
Q. What input peripherals are there on the
IBM 4361?
A. A series of IBM S and A terminals
operating through several communications controllers,
as well as a number of 3370 disk drives from IBM, and
one controller and disk drive from Storage Tek,
S-t-o-r-a-g-e T-e-k, that is IBM 3380 compatible.
There are tape drives used for input that
are the medium speed inches per second, quantity two,
and--
Q. What model tape drives?
A. I can't recall the model number, but it's
a medium speed nine-track 1600 CPI, 6250 CPI phase
encoded group encoded tape drive capable of reading and
14
writing EBCDIC, E-B-C-D-I-C, data.
In addition--
MR. FROST: I don't believe we have a
question.
THE WITNESS: I'm still doing the input
devices.
MS. NASH: He's going through the input
peripherals.
MR. FROST: You're asking him now to
continue?
MS. NASH: Just continue, yes.
MR. FROST: Okay.
A. In addition, we have an IBM 3490 cartridge
tape system composed of two drives with IDRC
capability.
BY MS. NASH:
Q. Explain what IDRC capability is.
A. The initials IDRT--I--excuse me, IDRC
stand for improved data recording capability. And it
is a compression/decompression capability for
compressing the 200 megabytes of data that would
normally fit on a 3480 cartridge up to approximately
one gigabyte, G-i-g-a-b-y-t-e.
Q. You indicated a number of IBM S and A
terminals. What is that number?
15
A. I believe we have 39 IBM terminals, most
of which are IBM 3191 models.
Q. Are those 39 IBM terminals located in one
location or throughout offices in the water management
district?
A. The terminals are located in multiple
offices within our headquarters building, as well as
within two trailers at the headquarters' location.
Q. Are there particular divisions or
departments that have these IBM terminals?
MR. FROST: Can you ask for division or
departments?
BY MS. NASH:
Q. Yes.
Either, either special divisions or
departments, that have these IBM 3191 terminals.
A. Yes.
Q. Which divisions and departments are those?
MR. FROST: Can you break that in two
questions?
BY MS. NASH:
Q. Which divisions are those?
A. There are terminals located in the
division of computer management, the division of
procurement and contract administration, the division
16
of financial services, the division of accounting, and
the division of personnel.
Q. Are there departments within the water
management district that have some of these IBM 3191
terminals?
A. I'm sorry, I didn't hear the question.
Q. Are there departments that also have some
of these IBM terminals you've been describing?
A. Yes, divisions are part of departments, so
the division--excuse me, the department of finance and
administration has terminals, and the department of
technical services has terminals.
Q. You testified that these terminals operate
through several communications controllers. What model
are those and how--well, first, what model are those?
A. An IBM 3274 communications controller, and
an IBM 3174 communications controller, as well as the
communications adapter located on the IBM 4361.
Q. You testified to a number of 3370 IBM disk
drives. How many 3370 IBM disk drives are there?
A. I believe the count is five. It could
possibly be six, but I am pretty sure it's five.
Q. Are there any other input peripherals that
you've not yet described for the IBM 4361?
A. Yes.
17
Q. What are those?
A. There is a protocol converter incorporated
1076 device hanging off the IBM 4361, as well as a DEC
NET--that's D-E-C N-E-T, /SNA gateway attached to the
IBM 4361.
Q. What is the function of the protocol
converter 1076 device?
A. It allows asynchronous terminals to
operate through an SDLC line from the communications
adapter on the 4361.
Q. What is a SDLC line?
A. That is an IBM term for the type of
communications line that they handle in their S and A
definition. I'm not certain of the exact words that
are associated with SDLC.
Q. What function does the DEC NET/SNA gateway
serve?
A. It permits devices that have connected to
an IBM--excuse me. It--it permits devices connected to
the DEC--that's D-E-C, 6310 to connect to the IBM 4361
as a terminal circuit. In addition, it permits the
routing of batched jobs called RJE to the IBM 4361, and
accepts printouts from the IBM 4361 to the DEC 6310.
Q. Are there other input peripherals that
you've not yet described?
18
MR. FROST: Can you clarify that as far as
what system we're talking about?
BY MS. NASH:
Q. On the IBM 4361.
A. No, there's no other devices for doing
input to the IBM system other than unused SDLC lines.
Q. What are the output peripherals for the
IBM 4361?
A. There are a series of hard copy devices.
An IBM 3262 printer, quantity two. There's two of
those. A Xerox 4050 lazer printer. And all the
previous input devices are also capable of being output
to that we mentioned previously. Plus, there is one
4224 dot matrix printer from IBM, as well.
Q. Where are the printer devices located?
A. One 3262 is located in the computer room
where the 4361 is located. The other 3262 is located
in the division of financial services. The Xerox 4050
is located in the computer room with the IBM 4361. The
IBM 4224 dot matrix printer is located in the division
of procurement and contract administration.
Q. What communications capabilities does the
IBM 4361 have?
A. The 4361 has a communications adapter
capable of handling synchronous lines up to 9600 bytes
19
per second. I believe it can be expanded up to eight.
At present, I believe we have three.
MR. FROST: I object.
Are you--do you know that it can be
expanded to eight?
THE WITNESS: No, I do not.
MR. FROST: Oh.
A. (continuing) We have a IBM--an IBM,
rather, 3720 communications controller that is channel
attached capable of driving devices at up to 56,000
bytes per second, and our 3174 and 3274 IBM
communications controllers are connected to that
device.
In addition, the DEC NET/SNA gateway is
attached directly to the communications adapter and to
the IBM 3720 communications controller, terminal lines
connected to the 3174, 3274, as well as to the
communications adapter on the 4361.
Q. What data is stored or processed through
the IBM 4361?
A. The data stored on the IBM 4361 is
financial in nature only, containing information on
general lev--general ledger, accounts payable,
inventory, budget, and fixed assets.
Q. Whose decision was it to use the IBM 4361
20
just for financial data?
A. It was part of the recommendation of the
consultant Quad, Q-u-a-d, Corporation to acquire and
use the predecessor of the IBM 4361 for financial
information only.
Q. When was this recommendation made?
MR. FROST: Object to this line of
questioning. What's the relevance to this
lawsuit of who made determinations of what
computer system should be used for financial
information?
MS. NASH: It's brief background
information, will not go on.
You can answer the question.
A. In the fourth calendar quarter of 1983,
the IBM 4331 computer system was acquired as a result
of the Quad recommendation.
BY MS. NASH:
Q. When was the IBM 4361 acquired?
A. I'm sorry, could you repeat the question?
Q. When was the IBM 4361 acquired?
A. The IBM 4361 was actually upgraded from a
4331 in approximately 1987.
Q. Moving now to the Cyber 830 mainframe.
What operating--what software is used on
21
the Cyber 830?
A. There is a series of three GL development
tools, namely COBOL, Fortran, DMS 170 preprocessor
available for use by any of the users.
In addition, there are a number of
application and statistical packages available for any
user. These include SPSS, BMDP, SIR, IMSL, SCA, Plot
10 Graphics Libraries, Techtronics Graphics Libraries,
and I can't recall any other general application
packages available at this time.
There is also other development tools from
Control Data Corporation, including DMS 170 data base,
and utilites for driving the appropriate communications
devices attached to the Cyber 180/830 system.
Q. What does SBSS (sic) do?
A. SPSS is a statistical package that accepts
tabular data and allows you to perform statistics and
aggression analysis on the sample data.
Q. And what does VMDP do?
A. I'm sorry, I am not familiar with VMDP.
Q. I believe that was the second package
mentioned.
A. Excuse me, BMDP.
Q. I'm sorry, was it B?
A. Biomedical--
22
Q. BM, okay.
A. I believe the term, the name for the
package, though everybody knows it as BMDP, I believe
that it's an acronym for Biomedical Data Processing,
though I'm not positive that's the exact title.
BMDP is a statistical package, also
capable of accepting tabular text data and performing
certain curve-fitting and random analysis testing on a
given set of data.
Q. What does SIR do?
A. SIR is a data storage and statistical
analysis package, also. It accepts data from a tabular
form into the SIR, which is S-I-R, data base format,
and then permits analysis on that data.
Q. IMSL package, what does that do?
A. IMSL is a series of subroutines for--for
performing statistical analysis and must be called from
a Fortran program.
Q. What does SCA do?
A. SCA is also a statistical analysis sub
system commonly referenced from Fortran by setting up a
set of data and submitting it for analysis.
Q. What does the Plot 10 Graphics Library do?
A. It's used from Fortran calls to represent
data in a graphical form on an output device.
23
Q. And the Techtronics Graphics Library, what
does that do?
A. It's a series of Fortran COBOL subroutines
used to display data in a graphics form on terminals.
Q. What are the input peripherals on the
Cyber 830?
A. The Cyber has a single front end called
CDC NET that handles all input communications used for
both synchronous and asynchronous data. That's the
only input device external to the computer system.
Q. What output peripherals are on the Cyber
830?
A. Internal to the machine, it has a data
channel converter, commonly known as DCC, that permits
lower 3,000 peripheral devices to be operated. Running
off the DCC, we have one CDC 580-12 chain line printer
for output.
In addition, the CDC NET drives output
devices, typically terminals. I'm repeating that,
typically terminals.
Q. How many terminals are driven off the CDC
NET on the Cyber 830?
A. The CDC NET is wired to Ungermann-Bass,
U-n-g-e-r-m-a-n-n B-a-s-s, network interface units
that can be attached from any PC or terminal anywhere
24
along the network within the district.
Forty-eight lines are provided, and
normally all forty-eight are hooked up. From time to
time, we reduce that--excuse me, 32 lines are normally
driven, and we reduce that from time to time. When the
net--network interface units are required elsewhere, we
borrow them from the system and reduce it by eight
lines for each network interface unit. If all are
available, it has 32 lines.
Q. Where are the terminals or PC's located
that connect along this network you've been describing?
A. Throughout pretty much all divisions and
departments, terminals or PC's are located, as well as
anywhere the network goes, which includes our field
stations.
Q. You mentioned network interface units that
might be required elsewhere. Would you describe those
network interface units?
A. The network interface unit, normally
referred to as NIU 180, from Ungermann-Bass Corporation
has eight asynchronous ports and can be hung anywhere
along the Ethernet network where it is needed, and then
up to eight devices can be attached to the NIU 180.
Most district employees simply refer to the device as
an NIU.
25
Q. What are some of the locations or what are
the locations where these--you indicated these--the
network interface units might be required elsewhere.
Where is--would you define "elsewhere"?
MR. FROST: Could you repeat the question?
MS. NASH: Yes. He indicated in his
previous testimony that these network interface
units could be required elsewhere and that would
reduce the number of lines by eight, and I'm
inquiring as to what, where "elsewhere" is.
MR. FROST: Okay.
A. Occasionally, due to malfunction or
lightening strikes, an NIU will be in need of repair
within the district's headquarters, and due to the fact
that there's 32 lines on the Cyber, we borrow NIU's
while one is being repaired to supplement the terminals
that are down as a result of an NIU malfunction. We
have them located in our headquarters' building, as
well as at a building we refer to at Congress--as
Congress Park, and a building we refer to as Congress
Avenue. At present, that is the only locations where
NIU 180's are located.
Excuse me, there may be one in the Fort
Myers district office. I know we had located one there
on the network. I don't know if it's still there or
26
if--or if it's returned to the headquarters building.
Q. What areas outside of headquarters are
included on the network that can access the Cyber 830?
A. I'm sorry, could you repeat the question?
Q. Yes.
What locations outside of headquarters are
on the network that can access the Cyber 830?
MR. FROST: Are you asking him which ones
are on the network or one which one they can
access?
BY MS. NASH:
Q. I'll make it two questions, then.
What locations outside of headquarters are
on the network?
A. Okay.
The locations outside the district that
are networked, "networked" being defined as Ethernet,
are: Congress Avenue, Congress Park, Homestead field
station, Miami field station, Fort Lauderdale field
station, Clewiston field station, Okeechobee field
station, Kissimmee field station, Big Cypress field
station, S5A pump station, Fort Myers office, Kissimmee
office, and Okeechobee SWIM office.
Those are all the locations that are
networked with Ethernet outside of the headquarters
27
complex.
Q. What computer capabilities does being on
the Ethernet network give the various locations that
you mentioned?
MR. FROST: Could we break that up?
BY MS. NASH:
Q. Let me ask first, is--do the various--you
mentioned approximately a dozen locations. Do those
locations have different computer capabilities from the
Ethernet network, or is the--are the capabilities all
the same?
A. The capabilities at all of those locations
are that they are networked, and any device at that
location can communicate with any other device at the
headquarters or on the network.
And you had a second question, but I don't
quite recall it.
Q. Would be the more specific question then
is: What then is the computer capability at each of
the locations? I guess we'll go through them one by
one. At Congress Avenue?
MR. FROST: So your question is--what is
your specific question now?
BY MS. NASH:
Q. What is the computer capabilities at the
28
Congress Avenue location?
MR. FROST: Okay.
A. At Congress Avenue, there are
approximately 50 personal computers and some number of
terminals. I don't know exactly how many. As well as
some NIU's that--excuse me, those terminals are
attached by NIU's, but as well as at least one Xerox
word processing unit.
BY MS. NASH:
Q. Through the PC's at Congress Avenue, can
district employees access the Cyber 830 computer?
A. Yes, they can access it.
Q. What computer facilities or capabilities
are there at Congress Park?
MR. FROST: Didn't you already ask that
question?
THE WITNESS: No, she said Congress
Avenue.
19 MR. FROST: Okay.
A. At Congress Park, there is very much the
same computer equipment as Congress Avenue:
Approximately 40 personal computers, approximately
eight Xerox word processing work stations, and a number
of terminals, period.
29
BY MS. NASH:
Q. What make and model are the PC's at
Congress avenue?
A. They can be IBM XT's, IBM XT 286, IBM AT
PS 2-30/286, IBM PS2 Model 60, PS2 IBM Model 70, or IBM
PS2 Model 80.
Q. What make and model of PC's are there at
Congress Park?
A. The same as Congress Avenue.
Q. What computers are there at the Homestead
field station?
A. Normally IBM XT's only at present, though
if a system were to break, sometimes we would
substitute with one of the other IBM machines during
repair.
Q. Do you know how many?
A. Quantity two at present.
Q. What are the computer devices at the Miami
field station?
A. The same, quantity two IBM XT's, though
substitutes occur from time to time on a temporary
basis.
Q. What computer facilities are there at the
Fort Lauderdale field station?
A. Two IBM XT's with occasional substitutes.
30
Q. And at the Clewiston field station?
MR. FROST: What is the question?
BY MS. NASH:
Q. What are the computer devices at the
Clewiston field station?
A. Two IBM XT's.
Q. What are the computer devices at the
Okeechobee field station?
A. I believe they have three IBM personal
computers. Two, I know, are IBM XT's. I don't know if
the third machine is an XT or a faster machine.
Q. What are other computer devices at the
Kissimmee field station?
A. Two IBM XT's.
Q. And what are the computer devices at Big
Cypress field station?
A. It was one IBM XT, but they may have
expanded already to two.
Q. What computer devices are at the S5A pump
station?
A. Two IBM XT's.
Q. What computer devices are at the Fort
Myers office?
A. At present, I believe there's six personal
computers. Five, I believe, are IBM XT's, and one is
31
an IBM AT. There was and I still believe is an NIU 180
device that drives several terminals.
Q. What are the make and model of those
terminals?
A. DEC 320 asynchronous terminals.
Q. What computer devices are at the Kissimmee
office?
A. In the Kissimmee office, I believe there's
either three or four IBM XT's, as well as an IBM AT
personal computer.
Q. What computer device are at the Okeechobee
SWIM office?
A. At the Okeechobee SWIM office, there's a
Xerox word processing unit with an output device, and
approximately three or four IBM PS2 Model 30's.
Several of these numbers I'm having to
tell you approximately, because on a daily base--basis,
they change.
Q. For what reasons do the numbers change?
A. Typically--typically someone is moved to
the office or from the office or an additional
responsibility is transferred from one office to
another and a form submitted to say that we've--I
should say they have moved the personal computer to a
new location.
32
Q. Are there any other locations outside of
headquarters where the water management district has
computer facilities?
A. Yes.
Q. Where would those be?
A. Some asynchronous cables are extended from
the district's NIU at Congress Avenue to some
non-district devices located in the DER facility at the
same location.
In addition, the district owns some
statistical multiplexors and CSU/DSU's that extend
communications lines from the district's headquarters
to USGS in Miami.
In addition, there are some personal
computers located at department directors' or executive
off--office personnels' homes with modems for
connecting in to the district's computer network.
Also, there is a terminal device located
at some of the opera--excuse me, operations and
maintenance departments' hydrologists for purposes of
calling in to district's telemetry system.
Q. Where are the locations of those
operations and maintenance departments?
A. The operations and maintenance department
is located at the district's headquarters complex, and
33
the selected hydrologists that are on call for
regulating the gate positions have terminals at their
homes. I believe we're talking two terminals here.
Q. Back to the--
MR. FROST: You okay? Do you need to take
a break for anything?
MS. NASH: You want to take a break? I
could actually use a pit stop, so--
MR. FROST: Okay.
(Short break.)
(Whereupon, Ms. Waters left the deposition
room.)
BY MS. NASH:
Q. Mr. Hall, does the Cyber 830 have other
communications capabilities that allow access by
outside users besides the network that you've been
describing?
A. Ah, that's a difficult question to answer
the way you worded it. I can't answer yes or no.
MR. FROST: Can you go ahead and try to
clarify what you're asking?
BY MS. NASH:
Q. What I am--let me rephrase that.
A researcher doing work for the water
management district, if they were not part of the
34
Ethernet network that you've been describing, could
they still access data on the Cyber 830?
MR. FROST: I would object to that as
being speculative, unless you can answer to the
extent that it happened or that system is
capable of that.
MS. NASH: Well--
A. The system is not capable of being
accessed other than through the CDC NET.
BY MR. NASH:
Q. Are there networks other than the Ethernet
through which you can access the Cyber 830?
A. Yes.
Q. What are those other networks?
A. Any device that can interface to the CDC
NET is capable of accessing the Cyber.
Q. What data is stored on the Cyber 830?
A. It would take a long time to attempt to
describe all the data, and some of the data is really
only known by selected users. But to answer in a
general fashion: Water level data, rainfall data,
water conductivity data, discharge data--referring to
quantities--are stored on the Cyber, as well as data
that individuals elect to put under their user numbers
on the Cyber.
35
There's a lot of data that it would take
the individual running that system to be able to
properly describe. But there is probably 500, maybe
more, accounts, and those have an allocation of disk
space for that particular user to store the data that's
relative to their work.
Also, there's mag tapes used by the Cyber
that can contain historical data. And again, the owner
of those tapes would know the content data. I or
individuals in our division would simply know the owner
of the tape and whatever description they decide to
call their data.
That's about the best description I
give--can give for the data on the Cyber other than to
say it's where a majority of the historical data is
stored.
Q. Are there any logs or other form of
documentation that would indicate--for example, the
lists of magnetic tapes and who the owner of the tapes
is or are and what's on those tapes, as well as what's
stored directly on the computer?
MR. FROST: That--I'm confused at what
question you're actually asking.
BY MS. NASH:
Q. Is there a log or other documentation that
36
would contain information relating to what is on the
computer and the tapes that Mr. Hall has been
describing?
A. Okay. The question's becoming a little
bit too broad to answer. There are logs referring to
data stored on tapes.
Q. Do those logs have a name or a way of
referencing it? What is that name?
A. The--
MR. FROST: Go ahead and answer the first
question. You can answer it verbally.
A. Could you repeat the question?
BY MS. NASH:
Q. My first question is do--does the log have
a name?
A. Yes.
Q. And what is that name?
A. Mag tape user list for the Cyber system.
Q. Is there a comparable list for what is
stored directly on the Cyber 830?
A. Yes.
Q. Does that list have a name?
A. Yes.
Q. What is its--what is that name?
A. There is a list that is maintained of the
37
backup of all files currently located on the Cyber
disks. I'm trying to give a precise name to it here.
The PF DUMP listing for any given week of
Cyber users sorted in user number order contains a list
of the files that were backed up to magnetic tape and
are maintained for a minimum of three months.
Q. Are any--is any of the data on the Cyber
or its disks or tapes password protected or otherwise
protected?
MR. FROST: Will you break that up?
BY MS. NASH:
Q. That's a general question first, and then
I will break it down.
A. Yes.
Q. Is the historical data you've been
describing that's on the magnetic tapes password
protected?
A. I can't really say yes or no, so I'm gonna
say sometimes. Or I guess I should say in some cases,
yes.
Q. Do you know the nature of the material
that's password protected?
MR. FROST: What do you mean by "nature"?
Do you understand what--what you're being
asked?
38
THE WITNESS: No, the question doesn't
relate to the passwords at all.
BY MS. NASH:
Q. Do you know which files on magnetic tapes
are password protected?
A. Yes.
Q. What files are those?
A. All files that are in labeled format may
have a password, and you don't know they do or do not
until you reference it.
Q. You indicated the data on the Cyber disks,
that some of that data is also password protected; is
that correct?
A. I'm gonna try to answer that, not
answering your question, but just saying all data on
the Cyber disks is password protected.
Q. Let' move on for the moment to the mini
computers that are located at the--or that are utilized
by the water management district.
Can you describe what mini computers there
are?
A. Okay. We have a VAX--that's V-A-X, 8820
computer system, a VAX 6310 computer system. We have a
Perkin Elmer mini computer. We have a Computer Vision
mini computer. We have two micro VAX II--excuse me,
39
three micro--Micro VAX II mini computers. And that's
all the mini computers we presently have at the
district.
Q. Are there other mini computers used or
accessible to water management district employees that
are not located at the district?
A. I'm sorry, can you repeat?
Q. Are there other mini computers that are
used by water management district employees--
A. Yes.
Q. --that are not in the seven mini computers
you've described?
A. Yes.
Q. Where are those other mini computers
located?
A. There are computer systems located in
Tallahassee that are referenced by individuals at the
district for obtaining information. They are not owned
or anything by the district. There are mini computers
owned by USGS that contain data that the district
accesses and copies down to its own systems.
There are legal systems from West
Publishing and other firms that the district buys time
on for doing legal research.
There are commercially-available computer
40
systems that the district subscribes to to get
information on products available by other companies.
They're computer systems used for
biological--excuse me, bibiological--I can't say that
word, bibliography research that are accessed from our
reference center, commercially available systems.
I cannot think of any other--oops, we also
references--reference Barnett Bank's computer system
for check-clearing data.
We also access University of Miami's
satellite data for satellite images. We also have
individuals that access University of Florida and
Florida State's computer system for accessing data.
That's all the outside computer systems
that I can think of that the district references. Some
may or may not be mini computers.
Q. The computer system located in Tallahassee
that you mentioned as referenced, where is that system
located?
A. I do not know.
Q. By what device or devices is that system
in Tallahassee re--referenced?
MR. FROST: Referenced?
BY MS. NASH:
Q. Yes, or accessed. Accessed or referenced.
41
A. A phone number was obtained from our legal
department to call up and get information on
leg--legislation, and we access it by phone calls from
the district.
Q. What is the operating system on the VAX
8820?
A. VMS 5.O at present.
Q. I'm sorry, what is that?
A. VMS 5.0 at present.
Q. And what is the--what are the software
packages available on the VAX 8820?
MR. FROST: Could you identify what you
mean by "software packages," what you're
looking for?
MS. NASH: I believe Mr. Hall, if he
understood the question, can answer it.
A. Are you talking about
commercially-available software packages?
BY MS. NASH:
Q. No, what software is utilized--
A. Okay, utilized.
Q. --on the VAX 8820?
A. Oracle software, system utilites software,
communications software, and external device drivers
software. There are also language tools for program
42
development available to users.
Q. Please describe the Oracle software.
A. We have purchased Oracle software from
Oracle Corporation to store tabular data in a data base
format under VMS and have the forms utility,
report-writer utility, report utility, SQL*PLUS
utility, EASY*SQL utility, and data dictionary facility
from Oracle Corporation.
Q. What is the function of the systems
utilites software?
A. To--to allow maximum resource utilization
of the DEC system's memory by capturing selected pages
of memory to and from disks.
Q. And the communications software, what is
its function?
A. The communications software from multiple
vendors permits different types of devices on the
network to access and copy files to and from the VAX
system.
Q. Which vendors do you have communication
software for on the VAX 8820?
A. DEC, D-E-C, an abbreviation for Digital
Equipment Corporation, and Interconnections
Corporation. That's all.
Q. Who's the vendor for the systems utilites
43
software that you described that's on the 8820?
A. I'm not sure whether it's the vendor's
name or the vendor's product name, but we refer to it
as IO Express. That may be the name of the company.
I'm pretty certain it's the name of the product.
Q. What is the function of the external
device driver software that you described on the VAX
8820?
A. To drive DEC lazer printers and
Hewlett-Packard lazer printers throughout the complex.
Let me see if there's any other.
And that's all on the VAX 8820.
Q. You mentioned there are language tools for
program development available on the VAX 8820. Can you
describe those language tools?
A. Yes. Fortran C, Pro Fortran, and Pro C,
and I guess that's all.
Q. What are the input peripherals for the VAX
8820?
A. A console and an Ethernet interface board,
and that's all.
Q. What are the output peripherals on the VAX
8820?
A. The console, the Ethernet network board,
as well as an LPS 20 lazer printer accessed through the
44
Ethernet board.
That's all.
Q. What's the memory capacity on the VAX
8820?
A. 128 megabytes of real memory.
Q. What are the network capabilities of the
VAX 8820?
A. It is networked through a single Ethernet
controller board driving two protocols from DEC
interconnections.
That's all.
Q. Do you know the number of terminals that
can access data on the VAX 8820 through the Ethernet
network?
A. There's really not a physical limit except
eventually with too many users, the response time would
become unbearable. But the Ethernet board does not
limit how many terminal sessions can simultaneously be
handled.
Q. What are the data files that are stored on
the VAX 8820?
A. Almost exclusively they are Oracle data
files containing tabular data that have been created by
the different divisions throughout the district.
Q. Who makes the decision whether data files
45
will be stored on the Cyber 830, for example, as
opposed to the VAX 8820 or one of the other mini
computers that we'll discuss?
A. Okay--
MR. FROST: I--what do you mean by "we'll
discuss"? I guess this is a compound question.
MS. NASH: Well, let him answer the
question if he can answer the question.
MR. FROST: Do you recall the question?
THE WITNESS: Why don't you restate it,
just so I make sure I'm answering correctly.
BY MS. NASH:
Q. Who makes the decision on what data files
are stored on the mainframe and the Cyber 830, as the
one you have described as having more--other than
financial files on it, as opposed to storing data files
on the VAX 8820 or one of the other mini computers that
you previously mentioned that we'll be discussing?
A. The district has recently acquired the VAX
8820 and is encourageing the users to store their data
in Oracle wherever possible. The Cyber system is much
older and is in the process of being phased out, and
data files are discouraged from being created there.
The user ultimately makes a decision where
they put the data and request permission in the form of
46
disk allocation for where they need to put their data.
And computer management grants the request if it's
considered reasonable. Computer management is a
division.
Q. Who heads the computer management
division?
A. Myself.
Q. Are you saying then that it would be your
decision--or your decision which computer, based on the
amount of disk space being requested as to which
computer somebody would store files?
A. No, I'm not saying that.
Computer management personnel grant
allocations of disk space, and the user ultimately
makes a decision as to how much space they need and
then where they put their data. Naturally they can't
put more than they have space for, and if we deny their
request for space, they won't be able to put it on that
particular system.
Q. What's the operating system on the VAX
6310 computer system?
A. At present, VMS 5.0.
Q. What are the software packages available
on the VAX 6310?
A. Again, that's a very generic question. I
47
guess my attempt to say the packages that can be
utilized by a user would be Oracle, system utilites,
communications software, language development tools,
and then any software somebody may have developed.
Q. Is there a standard set of software that's
supported for the mini computers or--let me stop there.
MR. FROST: What do you mean by--
BY MS. NASH:
Q. Is there a standard set of software that
is supported by computer management for the mini
computers?
MR. FROST: Do you understand what she
means by "supported by"?
THE WITNESS: I think I need to define
"support" here.
MR. FROST: Go ahead.
THE WITNESS: You want me to define
"supported by" or you define "supported by"?
BY MS. NASH:
Q. Let me rephrase the question, actually.
What I'm interested in is are users of the
mini computers allowed to utilize whatever software
package appeals to them, or are they restricted in any
fashion to a standard set of software packages?
A. There are no restrictions normally placed
48
on any software packages, but there are permissions
required to get to some of the software packages or to
access possibly somebody's user number that contains
software.
Q. Let me see if I understand your answer.
A user, under their own user number, can
utilize whatever software they choose from whatever
source; is that an accurate statement?
A. No. A user may access
commercially-available software on any mini computer
where it is located as long as they have sufficient
permissions, meaning resources not so much access to.
Q. That gets back to my initial question then
is do you support only a standard set of software
packages and not--
MR. FROST: Are you--
BY MS. NASH:
Q. --the computer management division, and
not allow researchers to--or other users to pull in
their own software packages from the hinterlands, from
wherever?
A. Okay. I'm gonna have to qualify the word
"support."
Computer management installs selected
software that it finds of use to the district or its
49
employees and assists with questions on it. The
district is in the process of developing a data and
security policy that is consistent with prior year's
practices for not allowing the use of pirated software.
If a user were to copy a program from an
external source to their user number and had sufficient
resource privileges to use it, we'd very possibly not
be aware of it.
I don't know if that is targeting in
answering your question.
Q. It does.
The software packages that can be utilized
on the VAX 6310, you mentioned Oracle, systems
utilites, a communications software and the language
development tools. Are those the same packages that
you previously describe as being utilized on the VAX
8820?
A. All the ones that exist on the VAX 8820
also exist on the VAX 6310.
Q. Are there additional software packages on
the VAX 6310 that are not on the VAX 8820?
A. Yes.
Q. What are those software packages?
A. It'll take a little time, excuse me.
Wallengong, W-a-l-l-e-n-g-o-n-g, I
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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.
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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?
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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
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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
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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
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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
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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?
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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
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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
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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?
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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
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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.
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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
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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?
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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?
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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
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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
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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
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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
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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
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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
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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.
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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
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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.
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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.
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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
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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
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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.
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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?
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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,
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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?
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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
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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.
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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
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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
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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
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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
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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
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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
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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?
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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.
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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
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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
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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
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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.
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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?
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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
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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.
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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
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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?
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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?
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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
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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
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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
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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.
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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?
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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
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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.
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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
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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?
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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
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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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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
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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
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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
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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
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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.
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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
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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,
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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
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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
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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
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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.)
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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
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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
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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--
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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,
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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
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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
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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
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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
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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.
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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
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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
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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,
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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.
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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
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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?
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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.
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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
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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?
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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
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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
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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.
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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
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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
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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
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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
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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.)
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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
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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
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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
