|
5
THEREUPON,
DION GLUCK
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Mr. Gluck, I'm Beverly Nash, I'm counsel
for you the United States in this litigation.
We're here to find out what information
the Water Management District has on its
computers, what computers it utilizes, how the data
is formatted and generally about the workings of
the Water Management District's computers.
You've been selected as a representative of
the Water Management District having knowledge of
one or more of the categories that we've inquired
about. Do you know to which categories you're
responsive?
A. I believe it was 1, 2 and 6.
Q. What is your present title or position?
A. I'm a staff director in the department of
technical services.
Q. And what are your job responsibilities as
6
staff director?
A. I assist in the management of the
department and act as the department head in his
absence.
Q. Who is the department head?
A. John Lynch.
Q. And how long have you been enrolled as
staff director?
A. I have been a staff director for about a
year?
Q. Have you had positions prior to that?
A. Yes, I have.
Q. What position?
A. I was a senior staff analyst and assistant
to the director.
Q. Were these positions also in tech
services?
A. Yes.
Q. And what were your job responsibilities as
senior staff analyst?
A. They were similar. My progression has
added duties and responsibilities in a management
form over time.
Q. How long were you senior staff analyst?
A. Approximately a year and a half to two
7
years.
Q. And how long were you assistant to the
director?
A. Approximately a year to a year and a
half. I'm not sure of that. I started March
31st, 1986.
Q. And what's your educational background?
A. I have a BS in business administration.
Q. Are there employees in tech services that
work for you?
A. They all do.
Q. How many employees is that?
A. I believe it's approximately 58.
Q. What computers are utilized in tech
services?
A. Could you clarify that question a bit?
Utilized by the personnel themselves?
Q. Yes.
A. I believe all of them are.
Q. All of the computers in the Water
Management District are utilized there?
A. Well, personnel under me would have
knowledge of them all.
Q. I'm trying to find out what specific
computers are utilized by personnel in tech
8
services?
A. Well, being we provide the services for
the computers to all departments, we are familiar
with all the systems that exist at the district.
Q. Are there some computers that are
specifically utilized by the personnel in tech
services?
A. No more specifically than others.
Q. What work is done by the personnel in tech
services on the IBM mainframe?
A. Specifically it would be financial
systems.
Q. And who in tech services does the
financial?
A. George Scholl would be responsible for the
systems. There are a number of applications
analyst that are under George that would be working
with that system.
Q. And what work is done by personnel in tech
services on the Cyber?
A. I believe it would be on a systems
operation type thing. It wouldn't be actual
applications.
Q. Explain what you mean by "systems
operation"?
9
A. Maintenance of the system in order to
provide the service of the computer, the
availability of the computer to run the modelling,
et cetera.
Q. But there is no modelling actually run by
tech services' personnel?
A. No, not to my knowledge.
Q. And who in tech services maintains the
Cyber?
A. At this time, I believe, it's Steve
MacNeil.
Q. What work is done by the personnel in tech
services on the VAX 8820?
A. I believe it's support of the Oracle data
bases is its primary function.
Q. And who in tech services?
A. Again, a number of individuals.
Q. Is there one person primarily in charge?
A. I believe they share duties and back each
other up.
Q. How many people are we talking about?
A. Primarily two.
Q. What are their names?
A. David Sweet and Connie Falls.
Q. And what work is done in tech services on
10
the VAX 6310?
A. Again, I believe it's the same type of
work as the other one and the same people involved.
Q. And what work is done on the Perkin Elmer?
A. To my knowledge, that would be a
laboratory information system.
Q. And what work is done by personnel in tech
services on that machine?
A. Again, I don't believe the work is done by
us. We just provide the support.
Q. And what work is done by personnel in tech
services on the Computer Vision in the computer?
A. Primarily mapping.
Q. And who in tech services does the mapping
on the Computer Vision?
A. A number of GIS CADD techs.
Q. These are personnel within tech services?
A. That's correct.
Q. What are their names?
A. Jimmy Kramp, Theresa McRorie, Nancy Lin,
Cecilia Conrad, and Judy Canada.
Q. What is the nature of the mapping work
they do on the Computer Vision?
A. I'm not familiar enough to answer that
question.
11
Q. Who would know?
A. Any number of the people I just mentioned.
Q. What work is done by tech services'
personnel on the Micro VAX 2 mini computers?
A. I'm not exactly sure.
Q. Who would know?
A. Bill Hall.
Q. What work is done by personnel in tech
services on the Modcomp?
A. I don't believe any.
Q. Which microcomputers are utilized by
personnel in tech services?
A. IBM PCs, compacts, and Toshiba portables.
Q. What's the nature of the work done on the
IBM PC?
A. Varied.
Q. Give me some examples?
A. Symphony, Harvard Presentation Graphics.
Q. For what purpose is Symphony used?
A. Spreadsheet applications.
Q. For what purpose does tech services do
spreadsheet applications?
A. Again, that's very varied.
Q. Give me some examples?
A. Budgeting.
12
Q. What work is done by personnel in tech
services on the compacts?
A. Basically they're used in lieu of PCs when
they're not available and for loan out, and we are
in charge of the loan out procedure.
Q. And what work is done by personnel in tech
services on the Toshiba?
A. Again, the same type deal as the compacts.
Q. Does tech services' personnel do any work
on the SUN work station?
A. We administrate and support those work
stations.
Q. Does tech services' personnel do any work
on the DEC work stations?
A. We administrate and support those
stations, also.
Q. Explain what you mean by supporting the
work stations?
A. I would say it would be systems
administrative type tasks, file availability, or
storage availability, that kind of thing.
Q. Does tech services provide technical
support for the I square S hardware in
environmental sciences?
A. To my knowledge, no.
13
Q. Who would know?
A. Bill Hall would know specifically.
Q. Is there a listing of which you're aware
of the computer files created or utilized by
environmental sciences?
A. Not to my knowledge.
Q. Who would know?
A. Dewey Worth.
Q. Is there a listing of computer files
created or utilized by the regulation department?
A. I have no idea.
Q. Who would no?
A. Someone in the regulation department.
Q. Is there a listing of the computer files
created or utilized by the water supply planning
division?
A. Not to my knowledge.
Q. Who would know?
A. Someone in that division.
Q. Is there a listing of computer files
created or utilized by the water quality division?
A. Not to my knowledge.
Q. Who would know?
A. Someone in that division.
Q. Is there a listing of the computer files
14
created or utilized by the planning department?
A. Not to my knowledge.
Q. Who would know?
A. Someone in planning.
Q. Is there a listing of the computer files
created or utilized by the personnel in water
resources division?
A. Not to my knowledge.
Q. Who would know?
A. Someone in that division.
Q. Is there a listing of the computer files
created or utilized by the personnel in the
research and evaluation department?
A. Not to my knowledge.
Q. Who would know?
A. Someone in that department.
Q. Is there a listing of the computer files
created or utilized by personnel in the geographic
sciences division?
A. I don't believe to my knowledge there is a
list that exists.
Q. Who would know?
A. Bob Brown in that case.
Q. Are you aware of the procedures for
backing up files created by the other divisions?
15
A. Not by the other divisions, no.
Q. What back-up procedures are you aware of?
A. I'm aware they exist in technical
services for the systems we support.
Q. For which systems do you support that you
do back-up procedures on?
A. I believe there's back-up procedures for
the IBM, the DEC systems, the Cyber system, and the
PC servers.
Q. Who is familiar with the back-up
procedures for the Cyber?
A. Bill Hall.
Q. Who is familiar with the back-up
procedures for the DEC?
A. Bill Hall.
Q. Who is familiar with the back-up
procedures for the PC servers?
A. Bill Hall.
Q. Are you familiar with the procedures by
which files are transferred between divisions or
departments in the Water Management District?
MS. STOLLMAN: This would be
transferred on the computers systems?
MS. NASH: Yes.
A. I'm only aware of the transfer of files
16
over the PC servers or the Xerox servers.
Q. (By Ms. Nash) And how does that transfer occur?
A. In my knowledge, it would be through menu
systems or icons, which make the actual workings
transparent to the user.
Q. Does tech services have any involvement in
those transfers?
A. I believe tech services' involvement would
be probably setting up the menus and the icons in
order to make it user friendly.
Q. And who in tech services would do that?
A. It would probably be the PC technicians or
other individuals working for Bill Hall.
MS. NASH: I have nothing further.
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. Mr. Gluck, my name is Joe Richards. I
represent the cities of Belle Glade and Clewiston.
For the systems backed up by tech
services, are you knowledgeable as to the periods
of time that these back-ups are maintained?
A. Not for sure.
Q. Are you aware of any written policies or
17
guidelines for quality control and quality
assurances of computer data bases?
A. To my knowledge, such a policy doesn't
exist.
Q. Are you aware of any data files that have
been accidentally lost by the district?
A. Not to my knowledge.
MR. RICHARDS: I have nothing
further. Thank you.
(Short break.)
MS. STOLLMAN: I just want to put on
the record that the witnesses identified in
response to the United States' 30(b)(6) notice have
been produced and have been questioned by both the
United States and the attorney for the cities of
Belle Glade and Clewiston, and that the 30(b)(6)
deposition is now concluded.
MS. NASH: We will disagree that the
30(b)(6) deposition is concluded, because we will
be making a motion to compel, because of the large
number of areas to which nobody was knowledgeable;
and we'll also be moving for sanctions and costs,
because of the large number of totally
18
nonresponsive people that were submitted, so that
the 30(b)(6) deposition is not concluded.
MS. STOLLMAN: Well, it's the
district's position that it produced witnesses who
were responsive to each and every one of the areas,
as was indicated on Laura Ahern's letter of August
6th, to Beverly Nash.
In fact, many of the witnesses testified
on more areas than those for which they were
identified in that letter. The district produced a
large number of witness in order to respond to the
broad nature of the 30(b)(6) notice. It is the
district's position that at this time each of the
witnesses has testified, and the deposition has
concluded.
MR. RICHARDS: It's the position of
the cities of Belle Glade and Clewiston that over
the course of this deposition, numerous people were
identified to have more knowledge than the people
proffered, and it is obvious that several of the
individuals produced were not responsive to the
United States' subpoena.
(The deposition was concluded at 3:50
o'clock p.m.)
19
(Missing)
20
I, DION GLUCK 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.
_____________________________
DION GLUCK
I do hereby certify that the
depostion of DION GLUCK 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: _______
|
