UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 88-1886-CIV-HOEVELER UNITED STATES OF AMERICA, et al, ) ) Plaintiffs, ) ) vs. ) ) SOUTH FLORIDA WATER MANAGEMENT ) DISTRICT; JOHN R. WODRASKA, ) EXECUTIVE DIRECTOR, SOUTH FLORIDA ) WATER MANAGEMENT DISTRICT; FLORIDA ) DEPARTMENT OF ENVIRONMENTAL REGU- ) LATION; AND DALE TWACHTMANN, ) SECRETARY, FLORIDA DEPARTMENT OF ) ENVIRONMENTAL REGULATION, et al, ) ) Defendants. ) ___________________________________ ) - - - - - - - - DEPOSITION OF CONNIE FALLS, THE WITNESS, TAKEN ON BEHALF OF THE PLAINTIFFS - - - - - - - - DATE: August 23, 1990 PROFESSIONAL REPORTING SERVICE Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 ** 2 I N D E X August 23, 1990 DIRECT CROSS CONNIE FALLS By Ms. Nash 5 By Mr. Richards 20 ** 3 The deposition of CONNIE FALLS, 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 1:05 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. ** 4 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 ** 5 THEREUPON: CONNIE FALLS, having been first duly sworn, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Would you state your name, please. A. Connie Falls. Q. Miss Falls, my name is Beverly Nash, and I'm attorney for the United States in this litigation. And we're here so that we can understand what computer systems the water management district has, how they're utilized, what data's on the system, how data is transferred amongst the systems, and you're here today as a representative of the district alleged as having the most knowledge on certain areas. Have you been shown the list of areas that we're interested in getting information on? A. Yes. Q. And what areas are you representing the water management district on today? A. Probably one through three. Q. What is your present title or position? A. Senior systems analyst. Q. And what division or department? ** 6 A. Computer Management. Q. What is your job description? A. I--it has several things in it, but I couldn't really say what they are right here. Q. What do you do? A. I take care of two VAX's and a VAX cluster. I do the systems work, install and upgrade software, system software, and I maintain Xerox work stations. Q. Anything else? A. I help users who have problems accessing systems or--or doing things with the software that's on the systems. Q. And how long have you been in that role? A. A little over three-and-a-half years. Q. Have you ever had another position at the water management district? A. I was just promoted from systems analyst. Q. And how long were you a systems analyst? A. Until a couple months ago. Q. Were your job responsibilities different when you were a systems analyst? A. Not really except that now I'm supervising a couple of people. Before I wasn't supervising anyone. ** 7 Q. Who are you supervising? A. David Sweet and Laura McLester. Q. Anyone else? A. No. Q. And who is your supervisor? A. Lavinia Ricketts. Q. What is your educational background? A. I have an AS degree in computer science from Palm Beach Junior College. Q. Do you have any other formal training in systems analysis? A. No. Q. Any informal training? A. You mean like job experience? That's where I got most of my other training was on the job. Q. You said one of your job responsibilities is to take care of two VAXs. What does that entail? A. Well, I make sure that the systems are running, that all the software on them is running, that people are able to access the systems. I upgrade the software when new releases come out. Q. Which of the VAXs are you responsible for? A. 8820 and 6310. Q. Are there other VAX machines in the district? ** 8 A. There are some Micro VAX's and some VAX stations or DEC stations. Q. Do you have responsibility for the Micro VAX's? A. No. Q. How about for the DEC stations? A. No. Q. Which of the software packages are you responsible for maintaining? A. All of them except for Oracle. Q. And who maintains Oracle? A. David Sweet. Q. And is there a list of all the software packages that you maintain? A. Yes. Q. Does that list have a name? A. No. Just a list I have. Q. Can you tell me what software packages are on that list? A. I*, Fortran, VAX C Programming Language, SPM, Data Flex, Word Perfect, LPS Supporting Host and Client, Diskkeeper, I-O Express, S and A Gateway software, Message Router, the Mail Gateway. That's all I can think of. Q. What function does I* serve? ** 9 A. It's a connections software for the network for the Ungermann-Bass network. Q. You mentioned SPM? A. Software Performance Monitor. It's a DEC-monitoring tool to help tune a system. Q. And what function does Data Flex perform? A. It's a data base software. Q. What is it used for? A. The card catalog for the reference center is on that. Q. And what sort of information is in that card catalog on the-- A. What you would normally have in a library card catalog, titles of articles or books or other things--I don't know what all they have there--and the author's name and a brief description of what it's about. Q. You mentioned LPS. What is that system? A. Lazer Printing Systems. Software that allows you to print things on a lazer printer. Q. You mentioned Support Host and Client? A. Supporting Host is the part that is downloaded to the lazer printer whenever it needs to be rebooted. Q. Is another part of that Supporting Client? ** 10 A. Yes. Q. And what is that? A. That allows you to have print cues on the VAX that are route printouts to the laser printer. Q. And Disk Keeper, what is that? A. It's a disk defragmenting software that keeps the files on the disks packed tightly together so that you have big blocks of free space instead of a bunch of little pieces of free space. Q. Iowa (sic) Express, what is that? A. I-O Express is a data-caching software that utilizes virtual memory so that not as many disk accesses need to be made. It speeds up the running of the machine. Q. S and A Gateway software, what is that? A. It's software that allows the VAX to communicate with the IBM through an S and A gateway. Q. And the Message Router, what is that? A. It's a--it's a facility that routes messages to a foreign-mail gateway. Q. What do you mean by "foreign-mail gateway"? A. Well, not--not on the VAX cluster. Something away from the VAX cluster. Q. And what is the mail gateway? ** 11 A. That's part of the message router. Q. Are any of these software packages you mentioned created internally by the water management district? A. No. These were all purchased. Q. Do you do any other work in maintaining the software? A. No. Q. What do you do in maintaining the Xerox work stations? A. When there are hardware problems, I'm one of the people who calls in for a service man to come out and repair them, or if there are problems with the software, there are certain procedures that can be done in-house to repair the software and get it running again. I am one of the people who does that. Q. So you have certain in-house programs used to repair software problems? A. There are procedures, diagnostic procedures, from Xerox, but you don't need a hardware technician to run them. Q. These are procedures that were provided to the district by Xerox? A. Yes. Q. Are you ever asked to maintain or work ** 12 with software packages that are not among these standard ones you mentioned? Do individual researchers ever ask you-- A. No. Q. --for assistance with other software packages? A. No. Q. What are the operating systems on the VAX's you maintain? A. VMS. Q. What's the nature of requests you get from users to render assistance? A. It's usually something like they've run out of disk quota, they need more space to store their files, or they've gotten disconnected and they don't know what to do. Or sometimes it's an actual problem in using a package, such as Word Perfect, where they don't know what keys to press or--or what to do to get something to work. Q. If a user calls with a space problem, who has authority the assign them more space? A. I do, or David Sweet or Lavinia Ricketts. Q. And if you are unable to solve a problem that a user comes to you with, to whom do you turn? A. Lavinia Ricketts. ** 13 Q. In the work that you do, do you transfer files from one computer to another? A. Occasionally I help users accomplish that. Q. And what procedures do you use? A. We transfer files either on diskettes or electronically through the VAX. Q. Are you ever requested to transfer files to users outside the water management district? A. No. Q. Are there manuals or other documentation that you turn to to assist you in your job? A. Yes. Q. What are those manuals, documentation? A. VMS manuals for the VAX, and the Viewpoint Reference Library for the Xerox work stations. Q. Are you responsible for creating any text data documents in your job? A. Yes, I generate memos and documentation of procedures that I use in maintaining the VAX's and the Xeroxs. Q. Is there a directory or a library in which those documents are stored? A. No. Q. Are there hard copies of those memos or files you create? ** 14 A. Yes. Q. Is there a name under which you keep them filed? A. No. Q. Are you responsible for making decisions on which computer or which system water management district users utilize? A. No. Q. Are you responsible for doing any backup on the VAX's? A. Not directly. I set up the original procedures that the operators carry out. Q. And what are those procedures? A. They do an incremental backup of all the disks Monday through Thursday and a full backup every Friday. Q. How long are those backups maintained? A. I believe they have a five-week cycle. Q. Is there any permanent or historical records kept of the data on the VAX's? A. Not that I'm aware of. Q. Do you have any responsibility for backup on the Xerox work stations? A. Again, it's partially a procedure that I help set up that the operators carry out. ** 15 Q. Does the procedure for doing backup on the Xerox work stations differ from that on the VAX's? A. Yes. Q. What is that procedure? A. It's one disk is--it's done once a week, a full backup. Q. Do you know what data files are stored on the VAX's? A. It's all according to what each user stores in their individual account. I don't know what that would be. Q. Is there any record that you're aware of that would indicate what data files are stored? A. No. Q. Are data files stored on the Xerox work stations? A. Yes, on their local disks. Q. Do you know what data files those would be? A. Whatever data files they're working on, I presume. Q. And is there any list or record of what data files would be stored on the Xerox? A. No. Q. Are there means to access the VAX's from ** 16 outside the water management district? A. Yes. Q. And what procedure is used to do that? A. You would need a password to call in and get a modem, and then you would need a valid log-on to log on to the VAX. Q. And who is responsible for issuing the password? A. David Sweet. Q. And what's entailed in having a valid log-on to log in? A. To be a registered user on the VAX, you would have to have approval from your division director that you need access to the VAX, and then we add them as a user. Q. Are there water management district employees that you're aware of that access the VAX from home or from outside the district? A. The only one I know of for sure is me. I sometimes call in and do systems work at night. Q. Is there a particular telephone number that you call to do that? A. Yes. Q. What is that number? A. I think it's-- ** 17 MS. STOLLMAN: I would object to that question. For what purpose are you obtaining the telephone number here today? MS. NASH: For the very purpose that we're here taking this deposition, how we can access, question number three, computer systems which it can access directly and the procedure for accessing such computer systems. MS. STOLLMAN: And the procedure for accessing it is a telephone number. MS. NASH: I'm asking her what that telephone number is. MS. STOLLMAN: We're not here to tell you how to access that system. MS. NASH: It's directly relevant to number three. MS. STOLLMAN: My understanding is the purpose of the deposition is the procedure of obtaining access-- MS. NASH: Right. MS. STOLLMAN: --and at a later time, the government will make a motion to either obtain access to the systems or obtain the information that is desired based on what is discovered today but not for obtaining access today. ** 18 MS. NASH: We are not obtaining access today. We're only trying to find out the means by which to obtain the access and the telephone number. MS. STOLLMAN: And you know that's the telephone number. MS. NASH: We're entitled to know what that telephone number is to answer the question. MS. STOLLMAN: I don't think you're entitled to know that telephone number today. MS. NASH: Are you directing the witness not to answer? MS. STOLLMAN: Yes. MS. NASH: Fine. We'll take this up with the judge. BY MS. NASH: Q. Are there procedures for accessing the Xerox work stations from outside the water management district? A. No. Q. Do you know whether any entities other than water management district employees have access to the VAX? A. I believe the Army Corps of Engineers were doing a project with the district and were transferring ** 19 some files onto the VAX strictly as a file server. Q. Would you explain what you mean by trans--having the VAX used as a file server? A. They were doing some kind of Symphony spread sheet application, and they were simply transferring the files onto a VAX disk so that the person at the district who needed those could get them off of there and use them on the PC. Q. Is there networking that's done between the VAX's and any other computers that the water management district has? A. Yes. Q. And how is that networking accomplished? A. To the IBM through the S and A Gateway, to other VAX's that are not in the cluster through DEC NET, and to the Xerox central server through XNS for VMS. Q. Do you know whether there's any networking between the VAX's and any computers outside the water management district? A. Not that I know of. MS. NASH: I have no further questions. MS. STOLLMAN: Do you want to take a break before we continue? THE WITNESS: No, I'm okay. ** 20 MS. STOLLMAN: Okay. CROSS EXAMINATION BY MR. RICHARDS: Q. My name's Joe Richards. I represent the Cities of Belle Glade and Clewiston. Are you aware of any data that has been accidentally lost or destroyed? A. No. Q. Have you performed any recoveries after power failures or crashes of computers? A. Could you clarify what you mean by "recovery"? Q. Attempts to restore data after a crash. A. I'm not aware of any data being lost as a result of crashes, not on my systems. Q. Mr. William Hall testified that you performed some recoveries on--after a power failure. Is that true? A. Not of data. Bringing machines back up. Q. But not restoring data files. A. I've never lost any data files as a result of a power failure that I can recall. Q. Are you aware of any water quality or hydrology data stored on the VAX computers that you maintain? ** 21 A. I don't know what they store on there. Q. Do you know how many users are on the VAX 8820? A. Do you mean-- Q. Number of individuals who utilize the system. A. Oh, who are generally on the system? Q. Yeah. A. Usually around 30. Q. Do you know what divisions those individuals? A. Regulation, land management, data management. I believe those are the main ones. Q. And the same question for the 6310. A. The 6310, I would say, all divisions. We have many users using terminals and utilizing the Word Perfect on the 6310. Q. And I would have to ask those individual users what data they have on those computers. A. Yes. I don't know what the data is they have. Q. Are you aware of any quality assurance or quality control procedures for the use of these two VAX computers? ** 22 A. No. MR. RICHARDS: I have no further questions. Thank you. THE WITNESS: You're welcome. (Whereupon, the deposition was concluded at 1:38 p.m.)