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THEREUPON:
LAURA CORRY,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. State your name.
A. Laura Corry.
Q. Miss Corry, my name is Beverly Nash. I'm
counsel for the United States in this litigation. And
we're here today to try and understand how the water
management district computers operate, how they're set
up, how they're utilized, what data is on them, and
you're here as a representative of the district having
knowledge concerning one or more of nine categories
that we wish to inquire about.
Have you been shown that list of
categories?
A. Yes.
Q. And to which categories are you
responsive?
A. I don't know. It was a general overview
of it.
Q. What is your present title or position?
A. Staff analyst in the Office of
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Communications.
Q. Is that Office of Communications part of a
division or department?
A. It's an office--it's not a division, it's
not a department.
Q. Is it part of a division or department?
A. No.
Q. What is the function of the Office of
Communications?
A. We are the arm of the district which deals
with public relations and communications with the
public.
Q. And what is your job description?
A. I'm the professional administrative
support person for my department.
Q. And what responsibilities do you have in
that role?
A. You need all of them?
Q. Yes.
A. I take care of the budget for the
department. I take care of computer needs. I take
care of policies and procedures inter-departmental.
I would say that's in general.
Q. How long have you been in that role?
A. Almost a year.
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Q. You had other positions at the water
management district?
A. Yes.
Q. And what positions?
A. Administrative secretary.
Q. In what division?
A. Office of Communications.
Q. And how long were you administrative
secretary?
A. Six months.
Q. Any other position at the water management
district?
A. None.
Q. Who is your supervisor in the Office of
Communications?
A. Cathy Anclade.
Q. Do you have any employees that work for
you in the Office of Communications?
A. No.
Q. What use do you make of computers in your
job in your Office of Communications?
A. I use the computer to track our budget
needs and to write documents for basically letters.
And also our mailing lists are kept on the computer
system.
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Q. What computers, computer systems, do you
use?
A. I use an IBM PC, which has the Label Flex
system, which is where our mailing lists are at.
Q. Do you use any other computers?
A. The Xerox 6085.
Q. Any others?
A. No.
Q. What work do you do on the Xerox 6085?
A. There we're able to do tables easier, so
we use it for that. And it has Free Form, so we're
able to design pages on that.
Q. Do you do work other than the mailing
lists on the IBM PC?
A. That's where I do my letters, that's where
I do anything written, I do on my IBM PC. That's where
I track my budget.
Q. What software packages do you use on the
IBM PC?
A. Word Perfect 5.1, Label Flex, and it's
hooked up to the VAX so that I can send information.
Q. Do you also retrieve information from the
VAX?
A. If someone sends me something or when I
have to access the Label Flex system, that's--I believe
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it's through the VAX.
Q. And what software packages do you use on
the Xerox 6085?
A. I'm not sure. Whatever's the basic.
Q. You indicated you use the Xerox 6085 to
create tables for reports or documents you write?
A. We use--whenever we need to keep track of
a long list and we need it in a table form, we usually
do it on the 6085.
Q. What procedure do you use for creating a
document on your PC?
A. I don't understand.
Q. What do you do when you sit down at the PC
and you want to create a document; what steps do you
take?
A. Using Word Perfect 5.1, you turn it on,
you ask for a blank page, start typing.
Q. When you want to store documents that
you've created on the IBM PC, what are the steps?
A. I store them on disks.
Q. Do your disks have names?
A. Most of them.
Q. Do you have a list of the disks that you
have?
A. No.
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Q. Do you transfer documents you've created
to other offices within the water management district?
A. At times.
Q. What procedure do you use to transfer
those documents?
A. I usually put them on a disk and hand them
to the person who's requesting it.
Q. In your work with communicating with the
public, do you create any documents on water quality
issues?
A. No.
Q. What is the sort of documents you would
create that are used to communicate with the public?
A. Usually if someone has written in a letter
with a question or a concern, we respond to the letter.
And also, we write our speeches.
Q. Do you ever write speeches regarding water
quality questions?
A. No.
MS. NASH: I have no further questions.
CROSS EXAMINATION
BY MR. RICHARDS:
Q. Miss Corey, my name's Joe Richards. I
represent the Cities of Belle Glade and Clewiston.
Do you create any documents relating to
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the everglades SWIM plan?
A. No.
Q. Have you written any speeches or drafted
any speeches on your computer relating to the
everglades SWIM plan?
A. No.
Q. Does your office generate public notices
for the district?
A. No.
Q. Where would those public notices be
created?
A. I don't know.
Q. Do you know?
A. (Witness shakes head.)
MR. RICHARDS: I don't have any further
questions. Thank you.
(Whereupon, the deposition was concluded
at 3:27 p.m.)
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E R R A T A S H E E T
(blank)
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I, LAURA CORRY do hereby certify
that I have read the foregoing transcript of my
deposition given on 28th day, August, 1990; that
together with the correction page attached hereto
noting changes in form or substance, if any, it is
true and correct.
_____________________________
LAURA CORRY
I do hereby certify that the depostion of
LAURA CORRY was submitted to the witness for reading
and signing; that after he had stated to the
undersigned Notary Public that he had read and
examined his depositon, he signed the same in
the presence of the undersigned authority
on the _____ day of ____________, 1990.
_____________________________
Notary Public
My Commission expires: _______
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