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The deposition of JOSE BODRE, the witness, in the
above-entitled and numbered cause, was taken before me,
DONNA McCALLEY, Registered Professional Reporter, and
Notary Public for the State of Florida at Large, at
Suite 110, 324 Datura Street, in the City of West Palm
Beach, County of Palm Beach, in the State of Florida,
beginning at the hour of 2:39 p.m., on Thursday, the
23rd of August, 1990, pursuant to the Notice in said
cause for the taking of said deposition, which is
annexed to the court file herein, on behalf of the
Plaintiffs in the above-entitled action pending in the
above-named court.
The appearances at said time and place
were as follows:
UNITED STATES DEPARTMENT OF JUSTICE
Room 868, 601 Pennsylvania Avenue, N.W.
Washington, D.C. 20044-0663
Attorneys for the Plaintiffs, U.S.A.
By BEVERLY SHERMAN NASH, ESQ.
PEEPLES, EARL & BLANK, P.A.
Suite 3636, Two South Biscayne Boulevard
Miami, Florida 33131
Attorneys for the Cities of Belle Glade
and Clewiston
By JOSEPH RICHARDS, ESQ.
SKADDEN, ARPS, SLATE, MEAGHER & FLOM
1440 New York Avenue, N.W.
Washington, D.C. 20005-2107
Attorneys for the South Florida Water
Management District
By KATHARINE STOLLMAN, ESQ.
ALLISON BURDETTE, ESQ.
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APPEARANCES CONTINUED:
SOUTH FLORIDA WATER MANAGEMENT DISTRICT
3301 Gun Club Road
West Palm Beach, Florida 33416-4680
By JACQUELYN L. WATERS, ESQ.
ALSO PRESENT: Ray Roberts
Robert Johnson
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THEREUPON:
JOSE BODRE,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Would you state your name, please.
A. Jose Bodre, B-o-d-r-e.
Q. Mr. Bodre, my name is Beverly Nash, and I
represent the United States in this litigation. And
we're here to find out about the computers that the
water management district has and how they are utilized
and the kind of data that's stored on them and how that
data is formated, and you're here as a representative
of the district having knowledge on one of nine
categories.
Have you seen the list of categories?
A. Yes, I have.
Q. And for which category are you here,
category or categories?
MS. STOLLMAN: If you know.
A. Yes, A-CAD is one. AUTOCADD.
BY MS. NASH:
Q. Mr. Bodre, what is your present title or
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position?
A. Design engineer tech.
Q. In what division or department?
A. That's the Engineering Division,
Construction Management Department.
Q. And what are your job responsibilities?
A. Drafting and design of district water
control structures.
Q. And how long have you been in that role?
A. Five years.
Q. Have you had other positions at the water
management district?
A. Yes.
Q. What positions were those?
A. Drafter II.
Q. And what was the job responsibility for
that position?
A. It's very similar. In that case, it's
probably a little less drafting. Just drafting.
Q. And how long were you employed as a
drafter II?
A. Well, it was two years.
Q. Have you had any positions prior to that
with the water management district?
A. No.
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Q. What is your educational training?
A. Presently at college level now, I've had
all types of computer classes, advanced computer class,
advanced AUTOCADD, AUTOLIPS, customizing.
Q. Who are your supervisors in the
engineering department, Engineering Division?
A. Red Rogers.
Q. I'm sorry, what was that?
A. Red Rogers.
Q. Do you have any employees at the water
management district that work for you?
A. Not work for me. No, not work for me, no.
Q. Are there others in the Engineering
Division that also work with AUTOCADD?
A. Everybody does.
Q. What computers do you personally use?
A. PS Model 70's, Xerox 6084 and--well, those
are--that's what we use presently in the division.
Q. Have you used other computers at the water
management district?
A. No.
Q. What work do you do on the PS Model 70?
A. We do word processing, engineering design,
graphics.
Q. And what work do you do on the Xerox 6084?
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A. That is mostly just for word processing.
Q. What software packages do you use on the
PS Model 70?
A. We use Word Perfect, Symphony, Lodus I,
II, III, AUTOCADD, Land CAT.
Q. What was the last one?
A. Land CAT, AAC, DCA, and Harvard Graphics.
Q. And what software packages do you use on
the Xerox?
A. Xerox only uses the Xerox Viewpoint, which
is word processing.
Q. What work do you do with the AUTOCADD?
A. Okay, that's--that's what we do design and
drafting of all the district structures, pumps,
bridges. Mostly it is a drafting package, though you
can run engineering applications, too.
Q. From where does the data come that you use
on AUTOCADD?
A. Okay, you work together with the
engineers. That's how we come up with the data. The
jobs are assigned by the division director, and once we
get the jobs assigned, we start working together. We
get mostly--our surveys come from Land Management, and
then we start working from then on in.
Q. What work do you do using the Land CAT?
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A. The Land CAT is just a--is a survey-type
software. It's a civil software for just survey
information.
Q. And what work do you do using AAC?
A. AAC is an architectural package for
buildings and some of the buildings and layouts, layout
design.
Q. And what work do you do using the DCA?
A. DCA is also a survey package for cross
sections.
Q. Do you know what operating system is used
on the PS Model 70?
A. Excuse me?
Q. What operating system?
A. I don't understand your question,
"operating systems."
Q. You don't know what an operating system
is?
A. I don't understand what you're referring
to.
Q. Do you know what system is utilized to
make the software packages function?
A. Okay.
Yeah, that's--that's the PS 70. It's a
micro computer, the IBM's.
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Q. To whom do you turn if you have questions
or problems utilizing the AUTOCADD software?
A. Nobody, really. I'm the expert on it, so
usually know all the answers.
Q. Is there a documentation or other manuals
to assist in using AUTOCADD?
A. Yes, there is.
Q. These manuals or documentation have names?
A. Yes, Auto Disk inside AUTOCADD. That's
directly from the company.
Q. As far as you know, AUTOCADD is created by
an outside manufacturer?
A. (Witness nods.)
Q. Has it been modified in any manner for use
by the water management district?
A. No.
Q. With Land CAT, is that also a package
created by an outside company?
A. Yes.
Q. Has that been modified at all by the
district?
A. No.
Q. AAC, is that created by an outside
company?
A. Outside company.
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Q. And has that been modified by the
district?
A. No.
Q. And DCA, is that created by an outside
company?
A. Yes.
Q. And has that been modified by the
district?
A. No.
Q. What about Harvard Graphics?
A. No. It's an outside software, hasn't been
modified.
Q. Do you utilize any software packages other
than those that have been acquired by the district in
your work?
A. No.
Q. Do you get involved in transferring files
from PS Model 70 to other computers?
A. Yes, we do.
Q. To what computers do you transfer files?
A. We transfer to, if--if they're needed, to
Land CAT, which is the same type computer to another PS
70's, if they need any of our files.
Q. Who would have need of your files?
A. Project management, and sometimes Land
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Management. And what procedures do you use to transfer
files from your PS 70?
A. We use the server system. We have a
series of servers that we can communicate with other
buildings in the district.
Q. Does that server system have a name?
A. No. "Server" is what they call it. They
have servers one through nine.
Q. Do servers one through nine each have a
different function?
A. Each have a different department or
div--division attached to them.
Q. And what server is attached to--
A. Construction.
Q. --your division?
A. Server nine.
Q. Do you know which divisions are attached
to the other servers?
A. No.
Q. Do you ever retrieve data or files from
other computers?
A. Yes, we do.
Q. From what computers?
A. From the same PS 70's, we retrieve files
from other PS 70's in the same division, Project
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Management or Land Management.
Q. What procedure do you utilize to retrieve
files?
A. Same way. Same server.
Q. Have you done any work on the AUTOCADD
relating to the areas known as water conservation
areas?
A. No.
Q. Have you done any work on the AUTOCADD
related to Everglades National Park?
A. No.
Q. Have you done any work on the AUTOCADD
related to areas known as the everglades agricultural
area?
A. No.
Q. Have you done any work on AUTOCADD
relating to the Loxahatchee National Wildlife Refuge?
A. No.
Q. For which structures have you worked on
the AUTOCADD?
A. Some of the examples that we worked on is
like G-208's.
Let's see--
Q. Do you know where that is located?
A. Not exactly. It's not near any town.
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There's been several. I'm right now
working on B-1, which is our own building, some work
that we have to do to our own area, so that's what
we're busy on doing right now.
And we've done Oketanee, which is out by
Okeechobee, a waste treatment plant we're working on
right now.
Q. Do you know whether any other structures
that you've worked on that you can recall?
A. There's been so many. Let's see...
Can't recall any now that I can recall
where--where they are exactly on the map or--G-207 is
another one just worked on recently.
Q. Do you know where structure G-207 is?
A. It's just near 208. Not exactly.
Did work on Sol Loch, which is
down--Deerfield Loch, excuse me, down in Deerfield.
Q. Do you recall which of the pumps you
worked on using AUTOCADD?
A. All of them. All of them. All the pumps
that we worked on, we use AUTOCADD.
Q. Do you recall which pumps you've done
AUTOCADD work on?
A. S-9. S-9 emergency pumps, we worked on.
Q. Do you recall any others?
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A. No.
Q. Have you heard the term "SWIM"?
A. SWIM, yes.
Q. Have you done any construction design
related to SWIM?
A. No.
Q. Have you done any work on AUTOCADD related
to digital image processing?
A. No.
Q. Have you done any work on AUTOCADD related
to geographical information systems?
A. No.
Q. Are there others in the water management
district beside the Engineering Division that you're
aware of that use AUTOCADD?
A. Several divisions use AUTOCADD. Not to
the extent we use it, but there are others.
Q. And which divisions would those be?
A. Land Management, Project Management, GIS
CAD, planning. That's as far as I can--I know.
MS. NASH: I have no further questions.
MR. RICHARDS: I just have a few
questions, counselor, if you want to call your
next witness.
MS. STOLLMAN: There's someone here.
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MS. BURDETTE: She's sitting outside.
MS. NASH: Who?
MS. STOLLMAN: Laura Corry.
CROSS EXAMINATION
BY MR. RICHARDS:
Q. My name is Joe Richards. I represent the
Cities of Belle Glade and Clewiston.
Have you done any work on the everglades
nutrient removal project?
A. Yes, I have.
Q. What type of work have you done on that
project?
A. On what we call Oketanee. That's work on
the plant right at this moment, on the nutrient
removal, phosphorous removal.
Q. Is that the Nye tract?
A. I don't think so. That's--I'm not sure
that's what--what it's called. I know it's called
Oketanee, is what we're working on right now.
Q. Do you know that it's called the
everglades nutrient removal project?
A. It's part of it. It's part of
the--they're trying to remove phosphorous out of
the--the system there.
MS. STOLLMAN: Are you asking this
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question in the context of the computer? Excuse
me.
MR. RICHARDS: Yes.
MS. STOLLMAN: The computer work that Mr.
Bodre does?
MR. RICHARDS: Yes.
A. So that's--so we're working on right now.
That hasn't got to any point. That's what we have on
the board. We haven't done any work on it. As of this
moment, we're working on B-1.
BY MR. RICHARDS:
Q. Do you know if that is--Oketanee is
located within the everglades agricultural area?
A. It is located just southwest of
Okeechobee.
Q. The City of Okeechobee?
A. City of Okeechobee. We might be thinking
of different things here.
Q. Yeah, I think we are.
Have you done any work on the holy land
restoration project?
A. Yes, I have.
Q. What type of work have you done on that
project?
A. I worked on design of the pump systems
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overland.
Q. And that work is stored on a computer
somewhere?
A. Yes.
Q. Which computer?
A. On my personal computer.
Q. Is it stored anywhere else?
A. No.
Q. Who else worked on the design of these
pumps?
A. Red Rogers, Jack Shim, and almost
everybody had a part to do in overland.
Q. What are the positions of these two people
you named? Are they engineers?
A. Yes, chief of design and senior engineer.
Q. Red Rogers is which?
A. Is the chief of design.
Q. And Jack Shim is what?
A. Senior engineer, is no longer at the
district.
Q. Have you done any other work on the holy
land?
A. No.
Q. Do you know what's the status of the
design of those pumps? Is that complete?
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MS. STOLLMAN: I--
A. Yes.
MS. STOLLMAN: When you're asking about
the design of the pumps, are you asking about
the computer design of the pumps?
MR. RICHARDS: Right.
BY MR. RICHARDS:
Q. Is your work complete on the design of the
pumps?
A. Yes.
Q. You mentioned you did some work on S-9; is
that correct?
A. Yes, um-hum.
Q. What type of work?
A. Design of the pump system on S-9.
Q. When did that work take place?
A. About two years ago.
Q. And the computer information generated
from that work, where is that stored?
A. I have it stored in my computer.
Q. Is it stored anywhere else?
A. No.
Q. Was it transferred to any other individual
within the district?
A. No.
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Q. Anyone outside the district?
A. No.
Q. The information you have on your PC for
the design work you did on the holy land, is that
stored anywhere else?
A. No.
Q. Did you do any work on the Rodenberger
tract?
A. No.
Q. Have you done any work on municipal water
supply or waste treatment?
A. I think this is what we're coming back to
Oketanee.
Q. Okay.
A. That's what we're working on right now,
waste treatment.
Q. Any other cities that you know of that
you've worked on?
A. No.
Q. Do you know who at the district has done
work on AUTOCADD in producing maps?
A. Yes.
Q. Who would that be?
A. Land Management.
Q. Do you know the individuals?
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A. Yes. Howard Emke is the supervisor there.
Q. Do you know how to spell his last name?
A. E-m-k-e.
Q. Anyone else that you know of?
A. No.
Q. Your work on Oketanee--
A. Um-hum.
Q. --what are you designing there?
A. It's a waste removal site. It's a--we're
just improving that. It's--Oketanee, that's just
outside Okeechobee. There's a waste treatment plant
there and we have to make some improvements to it.
Q. What sort of improvements are you making
there?
A. At this point, we haven't got to--to
decide what we're gonna do. It was just on the board.
It's just sitting right now.
Q. Do you store any of your AUTOCADD files on
the server?
A. No. Not on the server.
Q. How much hard disk capacity do you have on
your PS 70?
A. It's a 220 mega drive.
MR. RICHARDS: I have no further
questions. Thank you.
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THE WITNESS: All right.
(Whereupon, the deposition was concluded
at 3:06 p.m.)
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