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THEREUPON,
DOUG BERGSTROM
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Would you state your name?
A. Douglas Bergstrom.
Q. Mr. Bergstrom, I'm Beverly Nash, counsel
for the United States in this litigation.
We're here to find out about the computers
the Water Management District has, what's the
nature of the information on the computers, how
they're used, and how the files are stored.
You're here today as a representative of
the district having knowledge on one or more of the
various categories that we're interested in. Have
you been shown that list of categories?
A. Yes, ma'am.
Q. Do you know which ones you're here to
respond to today?
A. I believe 1, 2, and 3, or portions
thereof.
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Q. What is your present title or position?
A. Senior budget analyst.
Q. In what division or department?
A. The executive office.
Q. And what is your job description?
A. It's to prepare and formulate the
district's annual budget.
Q. Do you have other responsibilities?
A. Doing preliminary analyses of specific
items being requested, salary projections, and
those sorts of things.
Q. How long have you been in that roll?
A. Just over two years.
Q. Have you had other positions with the
Water Management District?
A. Same position, different title.
Q. And what was that title?
A. Budget analyst?
Q. And how long were you budget analyst?
A. Almost two years.
Q. Any prior experience with the Water
Management District?
A. No.
Q. What is your educational background?
A. I have a Bachelor of Arts from Penn State
7
University, and a masters in public administration
from George Mason University.
Q. Who is your supervisor in the executive
office?
A. Joseph Moore.
Q. And do you have any employees in the
executive office that work for you?
A. Mostly clerical.
Q. What computers do you use?
A. I use an IBM PS2 Model 70.
Q. Any others?
A. Yes. I run applications on the VAX as
well as the IMB mainframe.
Q. What work do you do on the IBM PS2?
A. I do spreadsheet analysis, salary
projections, as well as using an in-house budget
preparation package for data input.
Q. What software do you use on the IMB PS2?
A. I use Word Perfect, Symphony, EM-220.
Those three are the vast majority.
Q. Which VAX do you use?
A. I think its name is VAX-1. I'm not sure
if that's the 6310 or the other one.
Q. And what are the applications you run on
the VAX?
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A. It's an in-house written package that
combines individual division budget records and
translates them to IBM machine language.
Q. What software do you use on the VAX?
A. I connected the VAX through the EM-220 DEC
terminal emulator.
Q. What work do you do on the IMB mainframe?
A. Budget reporting.
Q. And what software do you use for the
budget reporting?
A. The reports are written in "IE,"
Information Expert.
Q. And what procedure do you use to access
the IBM mainframe?
A. I sign on through EM-220 as well.
Q. Do you transfer any of the work that you
do to others in the Water Management District by
computer?
A. No, they transfer it to me.
Q. Who transfers data to you?
A. All the division or department budget
coordinators transfer their budget input data to me
Q. Do you utilize any documentation or
manuals to assist you in your computer work?
A. Do you mean computer manuals?
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Q. Or in-house manuals?
A. I utilize a budget preparation manual that
we put together that pretty much outlines all the
procedures for doing your initial budget input.
Q. Is that an in-house document?
A. Yes.
Q. Do you utilize any documentation or
manuals to assist you with your work in the IBM
PS2?
A. Reference for software only.
Q. And what would those references be?
A. Word Perfect reference manual, Symphony
reference manual.
Q. What about for your work on the VAX, are
there any documentation or manuals you reference?
A. I do not use them.
Q. And what about for your work on the IBM
mainframe, are there any documentation or manuals
you reference?
A. No.
Q. Are back-ups done for the data files that
you create?
A. Back-ups on the IBM system?
Q. Yes.
A. Only as part of a routine back-up that
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they may run, I think, every week or so.
Q. You yourself do not do any back-ups?
A. No, ma'am.
Q. Who runs the back-ups?
A. The computer operators.
Q. What about for the work you do on the VAX,
do you do any back-ups?
A. No. They do them -- they do those
back-ups as well.
Q. Do you store completed work on the
computer?
A. "Completed work," in what sense?
Q. In any of the projects you work on?
A. Yes. I archive prior budgets submissions
as well as store the analyses I do.
Q. In what medium do you store them on?
A. Hard disk on my PC.
Q. Did you indicate you do not send, by
computer, the results of your work to anyone; is
that correct?
A. That's correct.
Q. Do you know whether there are other users
made of computers in your division?
A. Yes.
Q. What would that work be?
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A. Mostly word processing, memos, and that
sort.
Q. On what computers?
A. The IBM PC's as well as the Xerox 6085
system.
Q. Do you know what work is done on the Xerox
6085?
MS. STOLLMAN: I don't want you to
speculate about work done by other people. To the
extent that you know, you can answer the question.
A. Memos.
Q. (By Ms. Nash) Do you know what software
packages are utilized on the Xerox 6085?
A. It's called Viewpoint.
MS. NASH: I have no further
questions.
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. Mr. Bergstrom, my name is Joe Richards and
I represent the cities of Belle Glade and
Clewiston.
You said that you did an analysis of
specific budget items; is that correct?
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A. Yes.
Q. Have you done any work for the Everglades
SWIM Plan?
A. No, sir.
Q. Lake Okeechobee SWIM Plan?
A. No, sir.
Q. Everglades Nutrient Removal Project?
A. No, sir.
Q. The Holeyland Restoration Project?
A. No, sir.
Q. Rotenberger Restoration Project?
A. No, sir.
Q. Any scientific research in the water
conservation areas?
A. No, sir.
Q. How about any work relating to the
Everglades Agricultural Area?
A. I produced a report, which was
distributed, I believe, during the last legislative
session. It's an analysis of expenditures and
revenues in the EAA.
Q. That was provided to the Florida
legislature?
A. I believe so, yes.
Q. Was that published?
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A. Published as a formal document?
Q. Yeah.
A. It was, based upon a request from one of
our board members who wanted to see that type of
information, and we produced it specifically for
him.
Q. Does that document still exist somewhere?
A. Yes.
Q. And where?
A. I have a copy in my files.
Q. Anywhere else?
A. In a Word Perfect file as well, an
electronic copy.
Q. What was the date of that report?
A. I don't recall the specific date. It was
sometime last fall.
Q. Do you know what time period was covered
in the report?
A. Fiscal year '88, '89, I believe.
Q. Any other work relating to the Everglades
Agricultural Area?
A. No.
Q. How about work relating to Everglades
National Park?
MS. STOLLMAN: Are you asking whether
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he's done any work on the computer relating to
that?
MR. RICHARDS: Yes.
A. No.
MR. RICHARDS: Thank you. I have no
further questions.
(The deposition was concluded at
11:35 o'clock a.m.)
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I, DOUG BERGSTROM, do hereby certify
that I have read the foregoing transcript of my
deposition given on 27th day, August, 1990; that
together with the correction page attached hereto
noting changes in form or substance, if any, it is
true and correct.
________________________
DOUG BERGSTROM
I do hereby certify that the
deposition of DOUG BERGSTROM was submitted to the
witness forreading and signing; that after he had
stated to the undersigned Notary Public that he had
read and examined his deposition, he signed the
same in the presence of the undersigned the authority
on the __________ day of ___________, 1990.
_________________________
Notary Public
My Commission expires: ______
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THE STATE OF FLORIDA, )
COUNTY OF PALM BEACH, )
I, KAREN BAUER FRY, C.S.R., Court Reporter
and Notary Public for the State of Florida at Large,
do hereby certify that I reported the dposition of
Doug Bergstrom, the witness, called by the
Plaintiff in the above-entitled action; that the
witness was duly sworn by me; that the foregoing
pages, numbered from 1 to 16, inclusive, constitute
a tru record of the deposition by said witness.
I further certify that I am not attorney or
counsel of any of the parties, nor a relative or
employee of any atorney or counsel connected with
the action, nor financially interested in the action.
WITNESS MY HAND and offical seal in the
City of West Palm Beach, Countyof palm Beach,
State of Florida, this the 9th day of September,
1990.
__________________________
KAREN BAUER FRY, C.S.R.
Notary Public, State of Florida
at Large. My Commission expires
September 24, 1993
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