|
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.)
23
E R R A T A S H E E T
(blank)
24
I, CONNIE FALLS 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.
_____________________________
CONNIE FALLS
I do hereby certify that the depostion of
CONNIE FALLS 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: _______
|
