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 BILL HALL, THE WITNESS, TAKEN ON BEHALF OF THE PLAINTIFFS - - - - - - - - DATE: August 9, 1990 PROFESSIONAL REPORTING SERVICE Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 2 1 I N D E X 2 3 August 9, 1990 DIRECT CROSS 4 5 BILL HALL 6 7 By Ms. Nash 5 8 9 10 August 10, 1990 11 12 By Mr. Richards 114 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 3 1 The deposition of BILL HALL, the witness, in the 2 above-entitled and numbered cause, was taken before me, 3 DONNA McCALLEY, Registered Professional Reporter, and 4 Notary Public for the State of Florida at Large, at 5 Suite 110, 324 Datura Street, in the City of West Palm 6 Beach, County of Palm Beach, in the State of Florida, 7 beginning at the hour of 9:58 a.m., on Thursday, the 8 9th of August, 1990, pursuant to the Notice in said 9 cause for the taking of said deposition, which is 10 annexed to the court file herein, on behalf of the 11 Plaintiffs in the above-entitled action pending in the 12 above-named court. 13 The appearances at said time and place 14 were as follows: 15 UNITED STATES DEPARTMENT OF JUSTICE Room 868, 601 Pennsylvania Avenue, N.W. 16 Washington, D.C. 20044-0663 Attorneys for the Plaintiffs, U.S.A. 17 By BEVERLY SHERMAN NASH, ESQ. 18 PEEPLES, EARL & BLANK, P.A. Suite 3636, Two South Biscayne Boulevard 19 Miami, Florida 33131 Attorneys for the Cities of Belle Glade 20 and Clewiston By JOSEPH RICHARDS, ESQ. 21 SKADDEN, ARPS, SLATE, MEAGHER & FLOM 22 1440 New York Avenue, N.W. Washington, D.C. 20005-2107 23 Attorneys for the South Florida Water Management District 24 By DON JOAQUIN FROST, JR., ESQ. KATHARINE STOLLMAN, ESQ. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 4 1 APPEARANCES CONTINUED: 2 SOUTH FLORIDA WATER MANAGEMENT DISTRICT 3301 Gun Club Road 3 West Palm Beach, Florida 33416-4680 By JACQUELYN L. WATERS, ESQ. 4 CHARRON FOLLINS 5 ALSO PRESENT: John A. Davis, Ph.D. Frank Draughn 6 David Buker Robert Johnson 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 5 1 THEREUPON: 2 BILL HALL, 3 having been first duly sworn, as hereinafter certified, 4 testified as follows: 5 DIRECT EXAMINATION 6 BY MS. NASH: 7 Q. Okay, we are here for what is called a 8 30(b) deposition. This is a deposition where we are 9 inquiring about certain categories of information that 10 the water management district has to understand how the 11 water management district's computer systems operate, 12 how people communicate with each other in the district 13 using computers, what kind of data is stored on the 14 computers, and how that data is formatted. 15 Mr. Hall, you've been submitted as a 16 representative of the water management district having 17 knowledge concerning one or more of nine categories of 18 inquiry that we have submitted to your attorneys on the 19 South Florida Water Management District computer 20 systems and their comments. Have you been shown that 21 list of categories? 22 A. Yes, I have. 23 Q. For which categories are you being 24 submitted as the knowledgeable person; do you know? 25 A. I have some knowledge in almost all of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 6 1 categories. I don't really know which in particular 2 I'm designed to be the only representative for. 3 Q. Then we'll go through all of the 4 categories. 5 What is your present title or position? 6 A. Director of computer management. 7 Q. Is that in a particular division or 8 department? 9 A. It is a division, the division of computer 10 management, of which I am the director. 11 Q. What is your job description? 12 A. To obtain, acquire, set up, operate and 13 maintain all computer systems within the South Florida 14 Water Management District, including training, 15 applications, development, and interoperability of all 16 district computer systems. 17 Q. What was that last term? 18 A. Interoperability. 19 Q. Would you explain what "interoperability" 20 means, please. 21 A. The ability to make different vendors' 22 computer systems operate across a network to exchange 23 data and produce common results. 24 Q. How long have you been in the role of 25 director of computer management? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 7 1 A. Ah, I was appointed to the position June 2 1st, 1984. 3 Q. Have you had other positions at the water 4 management district? 5 A. I have had--have had other positions, yes. 6 Q. What positions have those been? 7 A. Starting approximately June 1973, I was 8 hired as a night computer operator part-time. In 9 approximately July of '75, I was promoted to 10 applications programmer I. 11 In approximately 1976, I was promoted to 12 the systems programmer I. And somewhere between there 13 and 1983, was promoted to a systems programmer II, and 14 finally, systems programmer III. 15 Q. What is a systems programmer I? 16 A. It's a position responsible for the 17 development and installation of operating systems and 18 communications problems on multiple computer systems. 19 Q. How does that differ from a systems 20 programmer II? 21 A. A systems programmer II position has the 22 same, as well as additional, requirements placed on it 23 for being a high level--higher level position requiring 24 more experience and supervision. 25 Q. Is the job function the same? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 8 1 A. Yes. 2 Q. And what about system programmer III? 3 A. Again, additional responsibilities of a 4 systems programmer II, additional years of experience 5 required. 6 (Whereupon, Ms. Waters entered the 7 deposition room.) 8 A. (continuing) And additional supervisory 9 responsibilities added. 10 MS. NASH: Note for the record an addition 11 to the room, please. 12 BY MS. NASH: 13 Q. Mr. Hall, what's your educational 14 background? 15 A. High school degree, bachelor's degree in 16 computer systems with the business and scientific 17 option from Florida Atlantic University. 18 Q. What year was that? 19 A. 1975. 20 Q. Have you had any additional formal 21 education in the computer area? 22 A. Other than continuing education on 23 specialized products, the answer is no. 24 Q. To whom do you report in the water 25 management district? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 9 1 A. To the director of technical services. 2 Q. Who is the director? 3 A. John T. Lynch, Jr. 4 Q. How many employees of the district do you 5 have working for you? 6 A. There are 29 employees within my division 7 directly or indirectly responding to me. 8 Q. Generally what are their job descriptions? 9 MR. FROST: You mean--what do you mean by 10 "generally"? 11 BY MS. NASH: 12 Q. Well, I don't need a description--if there 13 are six computer operators, I don't need each one 14 described separately. Just by category, if there are 15 categories of employees within your division. 16 A. Okay, we have an assistant division 17 director. 18 Q. Who is that? 19 A. Robert Mann, M-a-n-n. Two supervising 20 senior systems analysts, one application supervisor, 21 one senior systems analyst, two systems analysts, one 22 mainframe data base analyst, one technical instructor, 23 one micro computer applications developer. 24 I'm not certain of the counts here, but I 25 believe three applications developers, one senior PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 10 1 computer systems technician, four computer system 2 technicians, one senior electronics engineer. I'm not 3 positive if that title includes the word "engineer." 4 One electronic technician--and excuse me, the previous 5 title didn't include "engineer." It was senior 6 electronic technician, not engineer. 7 One operations supervisor, and four 8 mainframe computer operators, one administrative 9 assistant, and one administrative secretary. 10 That's the best I can recall at this 11 point. 12 Q. What are the computers that are used at 13 the water management district, starting with the 14 mainframe? 15 MR. FROST: You're directing this to the 16 mainframe, this first question? 17 MS. NASH: This first question is directed 18 to the mainframe or frames. 19 MR. FROST: Okay. 20 A. There's a slight gray area on what is the 21 mainframe and what is a smaller system. I'm 22 categorizing two of our systems as mainframes, and 23 those are an IBM 4361 Model 5MO, IBM mainframe, and a 24 Cyber--that's spelled C-y-b-e-r, 830 mainframe. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 11 1 BY MS. NASH: 2 Q. Do you have additional systems that you 3 would not call mainframes other than mini computers or 4 micro computers and PC's? 5 A. No. I don't have any other systems that I 6 would call mainframes that are not one of those. 7 Q. What operating system or systems do you 8 use on the IBM 4361? 9 A. IBM VSE/SP Version 4.1. 10 Q. Any others? 11 A. On the IBM? 12 Q. On the IBM. 13 A. No. 14 Q. And what operating system or systems do 15 you use on the Cyber 830? 16 A. Two operating systems: CDC NOS, spelled 17 N-O-S, and I do not know the current release, and CDC 18 NOS, NOS/VE. Again, I do not know the current release. 19 Q. What are the various software packages 20 that are used on the IBM 4361? 21 A. There are system utilites acquired from 22 IBM to make the system functional, and outside of 23 those, we have MSA software performing our financial 24 business for the district, as well as a number of 25 third-party software packages designed to maintain the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 12 1 financial data files' backups and performance of the 2 system. 3 Q. Can you name those third-party software 4 packages? 5 A. Yes. We have four modules from 6 Goals--that's G-o-a-l-s, Systems, designed to help tune 7 VCN files. I believe the names are VSAM--that's 8 V-S-A-M, AIDS, A-I-D-S. I believe the second one's 9 called HYPER, H-Y-P-E-R. Third one is called FAVOR. 10 And I can't remember the name of the fourth one. All, 11 again, are related to backing up or file tuning. 12 We also have computer associates DUN M/T. 13 I believe the spelling is D-U-N M/T, or close to it. 14 Q. And what is that software package used 15 for? 16 A. That software package is used to compress 17 data files for backup to magnetic tape--or excuse me, I 18 described the previous package. That package-- 19 MR. FROST: Can you clarify which package 20 you're talking about? 21 BY MS. NASH: 22 Q. The DUN M/T. 23 A. The DUN M/T is used to keep track of all 24 the magnetic tapes and IBM 3480 cartridges being used 25 on the IBM system. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 13 1 Q. And which package were you describing when 2 you said one was used to compress data files? 3 A. That was FAVOR that compresses data files 4 when they're being backed up to magnetic tape or 5 cartridges, and, of course, depresss them when they're 6 copied back down. 7 Q. What input and output peripherals are 8 there on the IBM 4361? 9 MR. FROST: I object. That's a compound 10 question. Can we do it--do one or the other? 11 BY MS. NASH: 12 Q. What input peripherals are there on the 13 IBM 4361? 14 A. A series of IBM S and A terminals 15 operating through several communications controllers, 16 as well as a number of 3370 disk drives from IBM, and 17 one controller and disk drive from Storage Tek, 18 S-t-o-r-a-g-e T-e-k, that is IBM 3380 compatible. 19 There are tape drives used for input that 20 are the medium speed inches per second, quantity two, 21 and-- 22 Q. What model tape drives? 23 A. I can't recall the model number, but it's 24 a medium speed nine-track 1600 CPI, 6250 CPI phase 25 encoded group encoded tape drive capable of reading and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 14 1 writing EBCDIC, E-B-C-D-I-C, data. 2 In addition-- 3 MR. FROST: I don't believe we have a 4 question. 5 THE WITNESS: I'm still doing the input 6 devices. 7 MS. NASH: He's going through the input 8 peripherals. 9 MR. FROST: You're asking him now to 10 continue? 11 MS. NASH: Just continue, yes. 12 MR. FROST: Okay. 13 A. In addition, we have an IBM 3490 cartridge 14 tape system composed of two drives with IDRC 15 capability. 16 BY MS. NASH: 17 Q. Explain what IDRC capability is. 18 A. The initials IDRT--I--excuse me, IDRC 19 stand for improved data recording capability. And it 20 is a compression/decompression capability for 21 compressing the 200 megabytes of data that would 22 normally fit on a 3480 cartridge up to approximately 23 one gigabyte, G-i-g-a-b-y-t-e. 24 Q. You indicated a number of IBM S and A 25 terminals. What is that number? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 15 1 A. I believe we have 39 IBM terminals, most 2 of which are IBM 3191 models. 3 Q. Are those 39 IBM terminals located in one 4 location or throughout offices in the water management 5 district? 6 A. The terminals are located in multiple 7 offices within our headquarters building, as well as 8 within two trailers at the headquarters' location. 9 Q. Are there particular divisions or 10 departments that have these IBM terminals? 11 MR. FROST: Can you ask for division or 12 departments? 13 BY MS. NASH: 14 Q. Yes. 15 Either, either special divisions or 16 departments, that have these IBM 3191 terminals. 17 A. Yes. 18 Q. Which divisions and departments are those? 19 MR. FROST: Can you break that in two 20 questions? 21 BY MS. NASH: 22 Q. Which divisions are those? 23 A. There are terminals located in the 24 division of computer management, the division of 25 procurement and contract administration, the division PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 16 1 of financial services, the division of accounting, and 2 the division of personnel. 3 Q. Are there departments within the water 4 management district that have some of these IBM 3191 5 terminals? 6 A. I'm sorry, I didn't hear the question. 7 Q. Are there departments that also have some 8 of these IBM terminals you've been describing? 9 A. Yes, divisions are part of departments, so 10 the division--excuse me, the department of finance and 11 administration has terminals, and the department of 12 technical services has terminals. 13 Q. You testified that these terminals operate 14 through several communications controllers. What model 15 are those and how--well, first, what model are those? 16 A. An IBM 3274 communications controller, and 17 an IBM 3174 communications controller, as well as the 18 communications adapter located on the IBM 4361. 19 Q. You testified to a number of 3370 IBM disk 20 drives. How many 3370 IBM disk drives are there? 21 A. I believe the count is five. It could 22 possibly be six, but I am pretty sure it's five. 23 Q. Are there any other input peripherals that 24 you've not yet described for the IBM 4361? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 17 1 Q. What are those? 2 A. There is a protocol converter incorporated 3 1076 device hanging off the IBM 4361, as well as a DEC 4 NET--that's D-E-C N-E-T, /SNA gateway attached to the 5 IBM 4361. 6 Q. What is the function of the protocol 7 converter 1076 device? 8 A. It allows asynchronous terminals to 9 operate through an SDLC line from the communications 10 adapter on the 4361. 11 Q. What is a SDLC line? 12 A. That is an IBM term for the type of 13 communications line that they handle in their S and A 14 definition. I'm not certain of the exact words that 15 are associated with SDLC. 16 Q. What function does the DEC NET/SNA gateway 17 serve? 18 A. It permits devices that have connected to 19 an IBM--excuse me. It--it permits devices connected to 20 the DEC--that's D-E-C, 6310 to connect to the IBM 4361 21 as a terminal circuit. In addition, it permits the 22 routing of batched jobs called RJE to the IBM 4361, and 23 accepts printouts from the IBM 4361 to the DEC 6310. 24 Q. Are there other input peripherals that 25 you've not yet described? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 18 1 MR. FROST: Can you clarify that as far as 2 what system we're talking about? 3 BY MS. NASH: 4 Q. On the IBM 4361. 5 A. No, there's no other devices for doing 6 input to the IBM system other than unused SDLC lines. 7 Q. What are the output peripherals for the 8 IBM 4361? 9 A. There are a series of hard copy devices. 10 An IBM 3262 printer, quantity two. There's two of 11 those. A Xerox 4050 lazer printer. And all the 12 previous input devices are also capable of being output 13 to that we mentioned previously. Plus, there is one 14 4224 dot matrix printer from IBM, as well. 15 Q. Where are the printer devices located? 16 A. One 3262 is located in the computer room 17 where the 4361 is located. The other 3262 is located 18 in the division of financial services. The Xerox 4050 19 is located in the computer room with the IBM 4361. The 20 IBM 4224 dot matrix printer is located in the division 21 of procurement and contract administration. 22 Q. What communications capabilities does the 23 IBM 4361 have? 24 A. The 4361 has a communications adapter 25 capable of handling synchronous lines up to 9600 bytes PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 19 1 per second. I believe it can be expanded up to eight. 2 At present, I believe we have three. 3 MR. FROST: I object. 4 Are you--do you know that it can be 5 expanded to eight? 6 THE WITNESS: No, I do not. 7 MR. FROST: Oh. 8 A. (continuing) We have a IBM--an IBM, 9 rather, 3720 communications controller that is channel 10 attached capable of driving devices at up to 56,000 11 bytes per second, and our 3174 and 3274 IBM 12 communications controllers are connected to that 13 device. 14 In addition, the DEC NET/SNA gateway is 15 attached directly to the communications adapter and to 16 the IBM 3720 communications controller, terminal lines 17 connected to the 3174, 3274, as well as to the 18 communications adapter on the 4361. 19 Q. What data is stored or processed through 20 the IBM 4361? 21 A. The data stored on the IBM 4361 is 22 financial in nature only, containing information on 23 general lev--general ledger, accounts payable, 24 inventory, budget, and fixed assets. 25 Q. Whose decision was it to use the IBM 4361 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 20 1 just for financial data? 2 A. It was part of the recommendation of the 3 consultant Quad, Q-u-a-d, Corporation to acquire and 4 use the predecessor of the IBM 4361 for financial 5 information only. 6 Q. When was this recommendation made? 7 MR. FROST: Object to this line of 8 questioning. What's the relevance to this 9 lawsuit of who made determinations of what 10 computer system should be used for financial 11 information? 12 MS. NASH: It's brief background 13 information, will not go on. 14 You can answer the question. 15 A. In the fourth calendar quarter of 1983, 16 the IBM 4331 computer system was acquired as a result 17 of the Quad recommendation. 18 BY MS. NASH: 19 Q. When was the IBM 4361 acquired? 20 A. I'm sorry, could you repeat the question? 21 Q. When was the IBM 4361 acquired? 22 A. The IBM 4361 was actually upgraded from a 23 4331 in approximately 1987. 24 Q. Moving now to the Cyber 830 mainframe. 25 What operating--what software is used on PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 21 1 the Cyber 830? 2 A. There is a series of three GL development 3 tools, namely COBOL, Fortran, DMS 170 preprocessor 4 available for use by any of the users. 5 In addition, there are a number of 6 application and statistical packages available for any 7 user. These include SPSS, BMDP, SIR, IMSL, SCA, Plot 8 10 Graphics Libraries, Techtronics Graphics Libraries, 9 and I can't recall any other general application 10 packages available at this time. 11 There is also other development tools from 12 Control Data Corporation, including DMS 170 data base, 13 and utilites for driving the appropriate communications 14 devices attached to the Cyber 180/830 system. 15 Q. What does SBSS (sic) do? 16 A. SPSS is a statistical package that accepts 17 tabular data and allows you to perform statistics and 18 aggression analysis on the sample data. 19 Q. And what does VMDP do? 20 A. I'm sorry, I am not familiar with VMDP. 21 Q. I believe that was the second package 22 mentioned. 23 A. Excuse me, BMDP. 24 Q. I'm sorry, was it B? 25 A. Biomedical-- PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 22 1 Q. BM, okay. 2 A. I believe the term, the name for the 3 package, though everybody knows it as BMDP, I believe 4 that it's an acronym for Biomedical Data Processing, 5 though I'm not positive that's the exact title. 6 BMDP is a statistical package, also 7 capable of accepting tabular text data and performing 8 certain curve-fitting and random analysis testing on a 9 given set of data. 10 Q. What does SIR do? 11 A. SIR is a data storage and statistical 12 analysis package, also. It accepts data from a tabular 13 form into the SIR, which is S-I-R, data base format, 14 and then permits analysis on that data. 15 Q. IMSL package, what does that do? 16 A. IMSL is a series of subroutines for--for 17 performing statistical analysis and must be called from 18 a Fortran program. 19 Q. What does SCA do? 20 A. SCA is also a statistical analysis sub 21 system commonly referenced from Fortran by setting up a 22 set of data and submitting it for analysis. 23 Q. What does the Plot 10 Graphics Library do? 24 A. It's used from Fortran calls to represent 25 data in a graphical form on an output device. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 23 1 Q. And the Techtronics Graphics Library, what 2 does that do? 3 A. It's a series of Fortran COBOL subroutines 4 used to display data in a graphics form on terminals. 5 Q. What are the input peripherals on the 6 Cyber 830? 7 A. The Cyber has a single front end called 8 CDC NET that handles all input communications used for 9 both synchronous and asynchronous data. That's the 10 only input device external to the computer system. 11 Q. What output peripherals are on the Cyber 12 830? 13 A. Internal to the machine, it has a data 14 channel converter, commonly known as DCC, that permits 15 lower 3,000 peripheral devices to be operated. Running 16 off the DCC, we have one CDC 580-12 chain line printer 17 for output. 18 In addition, the CDC NET drives output 19 devices, typically terminals. I'm repeating that, 20 typically terminals. 21 Q. How many terminals are driven off the CDC 22 NET on the Cyber 830? 23 A. The CDC NET is wired to Ungermann-Bass, 24 U-n-g-e-r-m-a-n-n B-a-s-s, network interface units 25 that can be attached from any PC or terminal anywhere PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 24 1 along the network within the district. 2 Forty-eight lines are provided, and 3 normally all forty-eight are hooked up. From time to 4 time, we reduce that--excuse me, 32 lines are normally 5 driven, and we reduce that from time to time. When the 6 net--network interface units are required elsewhere, we 7 borrow them from the system and reduce it by eight 8 lines for each network interface unit. If all are 9 available, it has 32 lines. 10 Q. Where are the terminals or PC's located 11 that connect along this network you've been describing? 12 A. Throughout pretty much all divisions and 13 departments, terminals or PC's are located, as well as 14 anywhere the network goes, which includes our field 15 stations. 16 Q. You mentioned network interface units that 17 might be required elsewhere. Would you describe those 18 network interface units? 19 A. The network interface unit, normally 20 referred to as NIU 180, from Ungermann-Bass Corporation 21 has eight asynchronous ports and can be hung anywhere 22 along the Ethernet network where it is needed, and then 23 up to eight devices can be attached to the NIU 180. 24 Most district employees simply refer to the device as 25 an NIU. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 25 1 Q. What are some of the locations or what are 2 the locations where these--you indicated these--the 3 network interface units might be required elsewhere. 4 Where is--would you define "elsewhere"? 5 MR. FROST: Could you repeat the question? 6 MS. NASH: Yes. He indicated in his 7 previous testimony that these network interface 8 units could be required elsewhere and that would 9 reduce the number of lines by eight, and I'm 10 inquiring as to what, where "elsewhere" is. 11 MR. FROST: Okay. 12 A. Occasionally, due to malfunction or 13 lightening strikes, an NIU will be in need of repair 14 within the district's headquarters, and due to the fact 15 that there's 32 lines on the Cyber, we borrow NIU's 16 while one is being repaired to supplement the terminals 17 that are down as a result of an NIU malfunction. We 18 have them located in our headquarters' building, as 19 well as at a building we refer to at Congress--as 20 Congress Park, and a building we refer to as Congress 21 Avenue. At present, that is the only locations where 22 NIU 180's are located. 23 Excuse me, there may be one in the Fort 24 Myers district office. I know we had located one there 25 on the network. I don't know if it's still there or PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 26 1 if--or if it's returned to the headquarters building. 2 Q. What areas outside of headquarters are 3 included on the network that can access the Cyber 830? 4 A. I'm sorry, could you repeat the question? 5 Q. Yes. 6 What locations outside of headquarters are 7 on the network that can access the Cyber 830? 8 MR. FROST: Are you asking him which ones 9 are on the network or one which one they can 10 access? 11 BY MS. NASH: 12 Q. I'll make it two questions, then. 13 What locations outside of headquarters are 14 on the network? 15 A. Okay. 16 The locations outside the district that 17 are networked, "networked" being defined as Ethernet, 18 are: Congress Avenue, Congress Park, Homestead field 19 station, Miami field station, Fort Lauderdale field 20 station, Clewiston field station, Okeechobee field 21 station, Kissimmee field station, Big Cypress field 22 station, S5A pump station, Fort Myers office, Kissimmee 23 office, and Okeechobee SWIM office. 24 Those are all the locations that are 25 networked with Ethernet outside of the headquarters PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 27 1 complex. 2 Q. What computer capabilities does being on 3 the Ethernet network give the various locations that 4 you mentioned? 5 MR. FROST: Could we break that up? 6 BY MS. NASH: 7 Q. Let me ask first, is--do the various--you 8 mentioned approximately a dozen locations. Do those 9 locations have different computer capabilities from the 10 Ethernet network, or is the--are the capabilities all 11 the same? 12 A. The capabilities at all of those locations 13 are that they are networked, and any device at that 14 location can communicate with any other device at the 15 headquarters or on the network. 16 And you had a second question, but I don't 17 quite recall it. 18 Q. Would be the more specific question then 19 is: What then is the computer capability at each of 20 the locations? I guess we'll go through them one by 21 one. At Congress Avenue? 22 MR. FROST: So your question is--what is 23 your specific question now? 24 BY MS. NASH: 25 Q. What is the computer capabilities at the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 28 1 Congress Avenue location? 2 MR. FROST: Okay. 3 A. At Congress Avenue, there are 4 approximately 50 personal computers and some number of 5 terminals. I don't know exactly how many. As well as 6 some NIU's that--excuse me, those terminals are 7 attached by NIU's, but as well as at least one Xerox 8 word processing unit. 9 BY MS. NASH: 10 Q. Through the PC's at Congress Avenue, can 11 district employees access the Cyber 830 computer? 12 A. Yes, they can access it. 13 Q. What computer facilities or capabilities 14 are there at Congress Park? 15 MR. FROST: Didn't you already ask that 16 question? 17 THE WITNESS: No, she said Congress 18 Avenue. 19 MR. FROST: Okay. 20 A. At Congress Park, there is very much the 21 same computer equipment as Congress Avenue: 22 Approximately 40 personal computers, approximately 23 eight Xerox word processing work stations, and a number 24 of terminals, period. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 29 1 BY MS. NASH: 2 Q. What make and model are the PC's at 3 Congress avenue? 4 A. They can be IBM XT's, IBM XT 286, IBM AT 5 PS 2-30/286, IBM PS2 Model 60, PS2 IBM Model 70, or IBM 6 PS2 Model 80. 7 Q. What make and model of PC's are there at 8 Congress Park? 9 A. The same as Congress Avenue. 10 Q. What computers are there at the Homestead 11 field station? 12 A. Normally IBM XT's only at present, though 13 if a system were to break, sometimes we would 14 substitute with one of the other IBM machines during 15 repair. 16 Q. Do you know how many? 17 A. Quantity two at present. 18 Q. What are the computer devices at the Miami 19 field station? 20 A. The same, quantity two IBM XT's, though 21 substitutes occur from time to time on a temporary 22 basis. 23 Q. What computer facilities are there at the 24 Fort Lauderdale field station? 25 A. Two IBM XT's with occasional substitutes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 30 1 Q. And at the Clewiston field station? 2 MR. FROST: What is the question? 3 BY MS. NASH: 4 Q. What are the computer devices at the 5 Clewiston field station? 6 A. Two IBM XT's. 7 Q. What are the computer devices at the 8 Okeechobee field station? 9 A. I believe they have three IBM personal 10 computers. Two, I know, are IBM XT's. I don't know if 11 the third machine is an XT or a faster machine. 12 Q. What are other computer devices at the 13 Kissimmee field station? 14 A. Two IBM XT's. 15 Q. And what are the computer devices at Big 16 Cypress field station? 17 A. It was one IBM XT, but they may have 18 expanded already to two. 19 Q. What computer devices are at the S5A pump 20 station? 21 A. Two IBM XT's. 22 Q. What computer devices are at the Fort 23 Myers office? 24 A. At present, I believe there's six personal 25 computers. Five, I believe, are IBM XT's, and one is PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 31 1 an IBM AT. There was and I still believe is an NIU 180 2 device that drives several terminals. 3 Q. What are the make and model of those 4 terminals? 5 A. DEC 320 asynchronous terminals. 6 Q. What computer devices are at the Kissimmee 7 office? 8 A. In the Kissimmee office, I believe there's 9 either three or four IBM XT's, as well as an IBM AT 10 personal computer. 11 Q. What computer device are at the Okeechobee 12 SWIM office? 13 A. At the Okeechobee SWIM office, there's a 14 Xerox word processing unit with an output device, and 15 approximately three or four IBM PS2 Model 30's. 16 Several of these numbers I'm having to 17 tell you approximately, because on a daily base--basis, 18 they change. 19 Q. For what reasons do the numbers change? 20 A. Typically--typically someone is moved to 21 the office or from the office or an additional 22 responsibility is transferred from one office to 23 another and a form submitted to say that we've--I 24 should say they have moved the personal computer to a 25 new location. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 32 1 Q. Are there any other locations outside of 2 headquarters where the water management district has 3 computer facilities? 4 A. Yes. 5 Q. Where would those be? 6 A. Some asynchronous cables are extended from 7 the district's NIU at Congress Avenue to some 8 non-district devices located in the DER facility at the 9 same location. 10 In addition, the district owns some 11 statistical multiplexors and CSU/DSU's that extend 12 communications lines from the district's headquarters 13 to USGS in Miami. 14 In addition, there are some personal 15 computers located at department directors' or executive 16 off--office personnels' homes with modems for 17 connecting in to the district's computer network. 18 Also, there is a terminal device located 19 at some of the opera--excuse me, operations and 20 maintenance departments' hydrologists for purposes of 21 calling in to district's telemetry system. 22 Q. Where are the locations of those 23 operations and maintenance departments? 24 A. The operations and maintenance department 25 is located at the district's headquarters complex, and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 33 1 the selected hydrologists that are on call for 2 regulating the gate positions have terminals at their 3 homes. I believe we're talking two terminals here. 4 Q. Back to the-- 5 MR. FROST: You okay? Do you need to take 6 a break for anything? 7 MS. NASH: You want to take a break? I 8 could actually use a pit stop, so-- 9 MR. FROST: Okay. 10 (Short break.) 11 (Whereupon, Ms. Waters left the deposition 12 room.) 13 BY MS. NASH: 14 Q. Mr. Hall, does the Cyber 830 have other 15 communications capabilities that allow access by 16 outside users besides the network that you've been 17 describing? 18 A. Ah, that's a difficult question to answer 19 the way you worded it. I can't answer yes or no. 20 MR. FROST: Can you go ahead and try to 21 clarify what you're asking? 22 BY MS. NASH: 23 Q. What I am--let me rephrase that. 24 A researcher doing work for the water 25 management district, if they were not part of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 34 1 Ethernet network that you've been describing, could 2 they still access data on the Cyber 830? 3 MR. FROST: I would object to that as 4 being speculative, unless you can answer to the 5 extent that it happened or that system is 6 capable of that. 7 MS. NASH: Well-- 8 A. The system is not capable of being 9 accessed other than through the CDC NET. 10 BY MR. NASH: 11 Q. Are there networks other than the Ethernet 12 through which you can access the Cyber 830? 13 A. Yes. 14 Q. What are those other networks? 15 A. Any device that can interface to the CDC 16 NET is capable of accessing the Cyber. 17 Q. What data is stored on the Cyber 830? 18 A. It would take a long time to attempt to 19 describe all the data, and some of the data is really 20 only known by selected users. But to answer in a 21 general fashion: Water level data, rainfall data, 22 water conductivity data, discharge data--referring to 23 quantities--are stored on the Cyber, as well as data 24 that individuals elect to put under their user numbers 25 on the Cyber. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 35 1 There's a lot of data that it would take 2 the individual running that system to be able to 3 properly describe. But there is probably 500, maybe 4 more, accounts, and those have an allocation of disk 5 space for that particular user to store the data that's 6 relative to their work. 7 Also, there's mag tapes used by the Cyber 8 that can contain historical data. And again, the owner 9 of those tapes would know the content data. I or 10 individuals in our division would simply know the owner 11 of the tape and whatever description they decide to 12 call their data. 13 That's about the best description I 14 give--can give for the data on the Cyber other than to 15 say it's where a majority of the historical data is 16 stored. 17 Q. Are there any logs or other form of 18 documentation that would indicate--for example, the 19 lists of magnetic tapes and who the owner of the tapes 20 is or are and what's on those tapes, as well as what's 21 stored directly on the computer? 22 MR. FROST: That--I'm confused at what 23 question you're actually asking. 24 BY MS. NASH: 25 Q. Is there a log or other documentation that PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 36 1 would contain information relating to what is on the 2 computer and the tapes that Mr. Hall has been 3 describing? 4 A. Okay. The question's becoming a little 5 bit too broad to answer. There are logs referring to 6 data stored on tapes. 7 Q. Do those logs have a name or a way of 8 referencing it? What is that name? 9 A. The-- 10 MR. FROST: Go ahead and answer the first 11 question. You can answer it verbally. 12 A. Could you repeat the question? 13 BY MS. NASH: 14 Q. My first question is do--does the log have 15 a name? 16 A. Yes. 17 Q. And what is that name? 18 A. Mag tape user list for the Cyber system. 19 Q. Is there a comparable list for what is 20 stored directly on the Cyber 830? 21 A. Yes. 22 Q. Does that list have a name? 23 A. Yes. 24 Q. What is its--what is that name? 25 A. There is a list that is maintained of the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 37 1 backup of all files currently located on the Cyber 2 disks. I'm trying to give a precise name to it here. 3 The PF DUMP listing for any given week of 4 Cyber users sorted in user number order contains a list 5 of the files that were backed up to magnetic tape and 6 are maintained for a minimum of three months. 7 Q. Are any--is any of the data on the Cyber 8 or its disks or tapes password protected or otherwise 9 protected? 10 MR. FROST: Will you break that up? 11 BY MS. NASH: 12 Q. That's a general question first, and then 13 I will break it down. 14 A. Yes. 15 Q. Is the historical data you've been 16 describing that's on the magnetic tapes password 17 protected? 18 A. I can't really say yes or no, so I'm gonna 19 say sometimes. Or I guess I should say in some cases, 20 yes. 21 Q. Do you know the nature of the material 22 that's password protected? 23 MR. FROST: What do you mean by "nature"? 24 Do you understand what--what you're being 25 asked? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 38 1 THE WITNESS: No, the question doesn't 2 relate to the passwords at all. 3 BY MS. NASH: 4 Q. Do you know which files on magnetic tapes 5 are password protected? 6 A. Yes. 7 Q. What files are those? 8 A. All files that are in labeled format may 9 have a password, and you don't know they do or do not 10 until you reference it. 11 Q. You indicated the data on the Cyber disks, 12 that some of that data is also password protected; is 13 that correct? 14 A. I'm gonna try to answer that, not 15 answering your question, but just saying all data on 16 the Cyber disks is password protected. 17 Q. Let' move on for the moment to the mini 18 computers that are located at the--or that are utilized 19 by the water management district. 20 Can you describe what mini computers there 21 are? 22 A. Okay. We have a VAX--that's V-A-X, 8820 23 computer system, a VAX 6310 computer system. We have a 24 Perkin Elmer mini computer. We have a Computer Vision 25 mini computer. We have two micro VAX II--excuse me, PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 39 1 three micro--Micro VAX II mini computers. And that's 2 all the mini computers we presently have at the 3 district. 4 Q. Are there other mini computers used or 5 accessible to water management district employees that 6 are not located at the district? 7 A. I'm sorry, can you repeat? 8 Q. Are there other mini computers that are 9 used by water management district employees-- 10 A. Yes. 11 Q. --that are not in the seven mini computers 12 you've described? 13 A. Yes. 14 Q. Where are those other mini computers 15 located? 16 A. There are computer systems located in 17 Tallahassee that are referenced by individuals at the 18 district for obtaining information. They are not owned 19 or anything by the district. There are mini computers 20 owned by USGS that contain data that the district 21 accesses and copies down to its own systems. 22 There are legal systems from West 23 Publishing and other firms that the district buys time 24 on for doing legal research. 25 There are commercially-available computer PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 40 1 systems that the district subscribes to to get 2 information on products available by other companies. 3 They're computer systems used for 4 biological--excuse me, bibiological--I can't say that 5 word, bibliography research that are accessed from our 6 reference center, commercially available systems. 7 I cannot think of any other--oops, we also 8 references--reference Barnett Bank's computer system 9 for check-clearing data. 10 We also access University of Miami's 11 satellite data for satellite images. We also have 12 individuals that access University of Florida and 13 Florida State's computer system for accessing data. 14 That's all the outside computer systems 15 that I can think of that the district references. Some 16 may or may not be mini computers. 17 Q. The computer system located in Tallahassee 18 that you mentioned as referenced, where is that system 19 located? 20 A. I do not know. 21 Q. By what device or devices is that system 22 in Tallahassee re--referenced? 23 MR. FROST: Referenced? 24 BY MS. NASH: 25 Q. Yes, or accessed. Accessed or referenced. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 41 1 A. A phone number was obtained from our legal 2 department to call up and get information on 3 leg--legislation, and we access it by phone calls from 4 the district. 5 Q. What is the operating system on the VAX 6 8820? 7 A. VMS 5.O at present. 8 Q. I'm sorry, what is that? 9 A. VMS 5.0 at present. 10 Q. And what is the--what are the software 11 packages available on the VAX 8820? 12 MR. FROST: Could you identify what you 13 mean by "software packages," what you're 14 looking for? 15 MS. NASH: I believe Mr. Hall, if he 16 understood the question, can answer it. 17 A. Are you talking about 18 commercially-available software packages? 19 BY MS. NASH: 20 Q. No, what software is utilized-- 21 A. Okay, utilized. 22 Q. --on the VAX 8820? 23 A. Oracle software, system utilites software, 24 communications software, and external device drivers 25 software. There are also language tools for program PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 42 1 development available to users. 2 Q. Please describe the Oracle software. 3 A. We have purchased Oracle software from 4 Oracle Corporation to store tabular data in a data base 5 format under VMS and have the forms utility, 6 report-writer utility, report utility, SQL*PLUS 7 utility, EASY*SQL utility, and data dictionary facility 8 from Oracle Corporation. 9 Q. What is the function of the systems 10 utilites software? 11 A. To--to allow maximum resource utilization 12 of the DEC system's memory by capturing selected pages 13 of memory to and from disks. 14 Q. And the communications software, what is 15 its function? 16 A. The communications software from multiple 17 vendors permits different types of devices on the 18 network to access and copy files to and from the VAX 19 system. 20 Q. Which vendors do you have communication 21 software for on the VAX 8820? 22 A. DEC, D-E-C, an abbreviation for Digital 23 Equipment Corporation, and Interconnections 24 Corporation. That's all. 25 Q. Who's the vendor for the systems utilites PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 43 1 software that you described that's on the 8820? 2 A. I'm not sure whether it's the vendor's 3 name or the vendor's product name, but we refer to it 4 as IO Express. That may be the name of the company. 5 I'm pretty certain it's the name of the product. 6 Q. What is the function of the external 7 device driver software that you described on the VAX 8 8820? 9 A. To drive DEC lazer printers and 10 Hewlett-Packard lazer printers throughout the complex. 11 Let me see if there's any other. 12 And that's all on the VAX 8820. 13 Q. You mentioned there are language tools for 14 program development available on the VAX 8820. Can you 15 describe those language tools? 16 A. Yes. Fortran C, Pro Fortran, and Pro C, 17 and I guess that's all. 18 Q. What are the input peripherals for the VAX 19 8820? 20 A. A console and an Ethernet interface board, 21 and that's all. 22 Q. What are the output peripherals on the VAX 23 8820? 24 A. The console, the Ethernet network board, 25 as well as an LPS 20 lazer printer accessed through the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 44 1 Ethernet board. 2 That's all. 3 Q. What's the memory capacity on the VAX 4 8820? 5 A. 128 megabytes of real memory. 6 Q. What are the network capabilities of the 7 VAX 8820? 8 A. It is networked through a single Ethernet 9 controller board driving two protocols from DEC 10 interconnections. 11 That's all. 12 Q. Do you know the number of terminals that 13 can access data on the VAX 8820 through the Ethernet 14 network? 15 A. There's really not a physical limit except 16 eventually with too many users, the response time would 17 become unbearable. But the Ethernet board does not 18 limit how many terminal sessions can simultaneously be 19 handled. 20 Q. What are the data files that are stored on 21 the VAX 8820? 22 A. Almost exclusively they are Oracle data 23 files containing tabular data that have been created by 24 the different divisions throughout the district. 25 Q. Who makes the decision whether data files PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 45 1 will be stored on the Cyber 830, for example, as 2 opposed to the VAX 8820 or one of the other mini 3 computers that we'll discuss? 4 A. Okay-- 5 MR. FROST: I--what do you mean by "we'll 6 discuss"? I guess this is a compound question. 7 MS. NASH: Well, let him answer the 8 question if he can answer the question. 9 MR. FROST: Do you recall the question? 10 THE WITNESS: Why don't you restate it, 11 just so I make sure I'm answering correctly. 12 BY MS. NASH: 13 Q. Who makes the decision on what data files 14 are stored on the mainframe and the Cyber 830, as the 15 one you have described as having more--other than 16 financial files on it, as opposed to storing data files 17 on the VAX 8820 or one of the other mini computers that 18 you previously mentioned that we'll be discussing? 19 A. The district has recently acquired the VAX 20 8820 and is encourageing the users to store their data 21 in Oracle wherever possible. The Cyber system is much 22 older and is in the process of being phased out, and 23 data files are discouraged from being created there. 24 The user ultimately makes a decision where 25 they put the data and request permission in the form of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 46 1 disk allocation for where they need to put their data. 2 And computer management grants the request if it's 3 considered reasonable. Computer management is a 4 division. 5 Q. Who heads the computer management 6 division? 7 A. Myself. 8 Q. Are you saying then that it would be your 9 decision--or your decision which computer, based on the 10 amount of disk space being requested as to which 11 computer somebody would store files? 12 A. No, I'm not saying that. 13 Computer management personnel grant 14 allocations of disk space, and the user ultimately 15 makes a decision as to how much space they need and 16 then where they put their data. Naturally they can't 17 put more than they have space for, and if we deny their 18 request for space, they won't be able to put it on that 19 particular system. 20 Q. What's the operating system on the VAX 21 6310 computer system? 22 A. At present, VMS 5.0. 23 Q. What are the software packages available 24 on the VAX 6310? 25 A. Again, that's a very generic question. I PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 47 1 guess my attempt to say the packages that can be 2 utilized by a user would be Oracle, system utilites, 3 communications software, language development tools, 4 and then any software somebody may have developed. 5 Q. Is there a standard set of software that's 6 supported for the mini computers or--let me stop there. 7 MR. FROST: What do you mean by-- 8 BY MS. NASH: 9 Q. Is there a standard set of software that 10 is supported by computer management for the mini 11 computers? 12 MR. FROST: Do you understand what she 13 means by "supported by"? 14 THE WITNESS: I think I need to define 15 "support" here. 16 MR. FROST: Go ahead. 17 THE WITNESS: You want me to define 18 "supported by" or you define "supported by"? 19 BY MS. NASH: 20 Q. Let me rephrase the question, actually. 21 What I'm interested in is are users of the 22 mini computers allowed to utilize whatever software 23 package appeals to them, or are they restricted in any 24 fashion to a standard set of software packages? 25 A. There are no restrictions normally placed PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 48 1 on any software packages, but there are permissions 2 required to get to some of the software packages or to 3 access possibly somebody's user number that contains 4 software. 5 Q. Let me see if I understand your answer. 6 A user, under their own user number, can 7 utilize whatever software they choose from whatever 8 source; is that an accurate statement? 9 A. No. A user may access 10 commercially-available software on any mini computer 11 where it is located as long as they have sufficient 12 permissions, meaning resources not so much access to. 13 Q. That gets back to my initial question then 14 is do you support only a standard set of software 15 packages and not-- 16 MR. FROST: Are you-- 17 BY MS. NASH: 18 Q. --the computer management division, and 19 not allow researchers to--or other users to pull in 20 their own software packages from the hinterlands, from 21 wherever? 22 A. Okay. I'm gonna have to qualify the word 23 "support." 24 Computer management installs selected 25 software that it finds of use to the district or its PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 49 1 employees and assists with questions on it. The 2 district is in the process of developing a data and 3 security policy that is consistent with prior year's 4 practices for not allowing the use of pirated software. 5 If a user were to copy a program from an 6 external source to their user number and had sufficient 7 resource privileges to use it, we'd very possibly not 8 be aware of it. 9 I don't know if that is targeting in 10 answering your question. 11 Q. It does. 12 The software packages that can be utilized 13 on the VAX 6310, you mentioned Oracle, systems 14 utilites, a communications software and the language 15 development tools. Are those the same packages that 16 you previously describe as being utilized on the VAX 17 8820? 18 A. All the ones that exist on the VAX 8820 19 also exist on the VAX 6310. 20 Q. Are there additional software packages on 21 the VAX 6310 that are not on the VAX 8820? 22 A. Yes. 23 Q. What are those software packages? 24 A. It'll take a little time, excuse me. 25 Wallengong, W-a-l-l-e-n-g-o-n-g, I PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 50 1 believe, Communications Software, in particular TC PIP 2 and NFS from Wallengong, XNS 4.0 Interconnections Disk 3 services. That was all one word. Interconnection Disk 4 Services called I*, two letters. I asterisks is a 5 better way of saying it. 6 Land Traffic Monitor, LPS 40 Host Service. 7 Q. I'm sorry, was that LPS? 8 A. LPS 40 Host Services. And PC SA. 9 Q. What is the function of the Wallengong TC 10 PIP that you mentioned? 11 A. A communications package permitting 12 computer systems capable of networking through TC PIP 13 to access the VAX 6310. 14 Q And what is the function of the NFS? 15 A. To provide network file services to TCP 16 hosts. 17 Q. What is the function of the--I believe it 18 was XNS 4.0? 19 A. To provide communications to and from the 20 Xerox 8090 server, disk server. Disk and print server, 21 actually. 22 Q. And what is the function of the--you call 23 it Interconnections Disk Services I*? 24 A. To provide personal computer MS NET 25 services to personal computers on the network. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 51 1 Q. And what is the function of the Land 2 Traffic Monitor? 3 A. To monitor and restrict Ethernet packets 4 across land bridge bridges from DEC, D-E-C. 5 Q. And what is the function of the LPS 40 6 Host Services? 7 A. To download the software to the LPS 40 8 lazer printer, period. 9 Q. What is the function of the PC SA? 10 A. To provide multi-user file access to MS 11 Dos Hosts, H-o-s-t-s. 12 Q. Are there any other software utilized on 13 the 6310 that you have not yet described? 14 A. These were just the packages in addition 15 to what exists on the 8820. 16 Q. Correct. 17 A. And no, I can't think of any other 18 packages other than programs that an individual might 19 have developed and have available for their personal 20 use. 21 MS. NASH: Good enough time to break? 22 MR. FROST: Yeah. 23 MR. RICHARDS: Counsel, do you have any 24 idea how much longer you're going to spend with 25 this witness? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 52 1 MS. NASH: Looks like a good part of the 2 afternoon. 3 MR. RICHARDS: Okay. 4 MR. FROST: Resume at 1:30? 5 MS. NASH: Yes. 6 (Whereupon, a lunch recess was taken from 7 12:31 p.m. to 1:40 p.m.) 8 (Whereupon, Ms. Follins entered the 9 deposition room.) 10 BY MS. NASH: 11 Q. Mr. Hall, I want to back up and fill in in 12 a few places. 13 You mentioned on your staff two 14 supervising senior systems analysts; is that correct? 15 A. Yes. 16 Q. Can you name them, please? 17 A. Lavinia Rickets and George Scholl, 18 S-c-h-o-l-l. 19 MR. FROST: Before we go further, I'd just 20 like to have on the record that we would like 21 for the transcript to be certified by the court 22 reporter, and we would also like to have the 23 opportunity to read, correct, and examine the 24 record and to sign it. 25 And I just wanted to make sure that PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 53 1 we have the opportunity. 2 BY MS. NASH: 3 Q. You mentioned a mainframe data base 4 analyst on your staff. Who is that person? 5 A. Thom, T-h-o-m, Scanlan, S-c-a-n-l-a-n. 6 Q. And you also mentioned a micro computer 7 applications developer; is that correct? 8 A. Yes. 9 Q. And who is that person? 10 A. Robert Haine, H-a-i-n-e. 11 Q. With regard to the VAX 8820 mini computer, 12 is there a log or other record of the data files that 13 are contained on that computer in any of its associated 14 disks or tapes? 15 A. Yes. 16 Q. Does that log have a name? 17 A. There--I guess there could be multiple 18 logs here. Can you be more specific as to which one of 19 those three areas, disk tape, et cetera? 20 Q. What is the--all right. 21 Is there a log for the disks on the VAX 22 8820, the data files on the disks? 23 A. Right. 24 Q. On the 8820. 25 A. Again, some are to the Cyber. By backing PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 54 1 the files up to cartridge tape, you obtain a list of 2 the user name, file name for any files as they back up. 3 And that can be created as a hard copy or machine 4 readable text file, naturally reflecting the files at 5 that point in time. 6 Q. Is there a similar list for the data files 7 on the tapes associated with the VAX 8820? 8 A. No, the log on the Cyber referred to as 9 the user tape list on the Cyber also includes any tapes 10 used on the VAX systems. 11 Q. Is there a log for what is stored directly 12 in the memory of the VAX 8820? 13 A. Are you referring to ram memory or disk 14 memory? 15 Q. Well, I believe--ram memory for the 16 moment. 17 A. There is a VMS command that can tell you 18 of any process running at any given time; in other 19 words, that one instant call show process, and that 20 could be copied onto a piece of paper, if desired. 21 Q. Are there any data files stored on the VAX 22 8820 other than on disk or tape? 23 A. Yes. 24 Q. What files are those? 25 A. Files are also stored on cartridges, which PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 55 1 are 3490 compliant. Actually compatibles, I guess, is 2 a more appropriate word. 3 Q. Is there a log of the data files stored on 4 the cartridges on the VAX 8820? 5 A. Yes. Again, any files, data files, stored 6 in the cartridges would be included in the same log 7 we've talked of previously, Cyber tape list/user log. 8 The only other files that may not be 9 included in that list would be simply the system backup 10 tapes. I don't know if they are or not included on the 11 log, but they are mirror images of the disks for 12 disaster recovery purposes. 13 Q. Returning to the VAX 6310. What are the 14 input peripherals on that unit? 15 A. It has two Ethernet controller boards, 16 four RS 232 ports--excuse me, it doesn't have four RS 17 232 ports. I'm thinking of a previous machine. I 18 believe it has just simply one RS 232 port for the 19 console. 20 Q. Are there any other input peripherals for 21 the VAX 6310? 22 A. No, only devices that would be connecting 23 through the Ethernet. There's no other physical 24 connections going in. 25 Q. What are the output peripherals for the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 56 1 VAX 6310? 2 A. Okay, all output peripherals must be 3 reached through the two Ethernet controller boards, 4 which include the devices we've talked about 5 previously, meaning the LPS 40, et cetera, lazer 6 printer, as well as a local Ethernet device that 7 receives and forwards printouts to lazer printers 8 associated with PC servers. 9 Again, those devices are accessed through 10 the Ethernet controller boards but are capable of 11 producing output from the VAX. 12 Q. What is the memory capability of the 6310? 13 A. Ah, I'm not positive. I believe that it's 14 65K--or excuse me, 56 megabyte--or 64 megabyte of real 15 memory. 16 Q. What are the communications capabilities 17 of the 6310? 18 A. Any device on the network that can be 19 input or output device from the VAX Ethernet controller 20 board is capable of being communicated with. There are 21 a number of different devices that exist and also could 22 be interfacted through that Ethernet controller board. 23 Q. What are the data files, if you know, that 24 are stored on the VAX 6310 or--or its related 25 cartridges, disks or tapes? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 57 1 MR. FROST: Can you break that up into 2 two--two questions? 3 MS. NASH: Well, you can--if he can answer 4 it generally. If not, I'll break it down. 5 A. Okay, referring to the disk itself on the 6 VAX, there are Oracle data bases stored there, and 7 there are UNIX flax files stored there, and there are 8 PC data files and programs stored there. 9 Again, users receive a log-on and are 10 given an allotted space, and they may store either VMS 11 files, UNIX text files, or binary files, or PC text, or 12 word processing files on the VAX under their user 13 number, and only the individual user would have a 14 thorough knowledge of what those files were, though as 15 we mentioned previously, the list of files from backup 16 would give you a file name, which would have some 17 meaning. 18 There is also Word Perfect files stored on 19 the VAX. This is something that I had not remembered 20 till just now. There is Word Perfect word processing 21 program running on the VAX 6310, and terminal users 22 store their files under their individual user number, 23 as well as in a general access area for anyone. 24 Again, what's in those files would really 25 be probably only known by the user that created them or PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 58 1 someone they asked to work with those files. 2 Q. Do you know which version of Word Perfect? 3 A. Yes. 4 Q. What version? 5 A. 5.O. Excuse me. 6 Q. Moving on to the--the Perkin Elmer mini 7 computer. What is the operating system for that unit? 8 A. It's Perkin-Elmer owned OS. 9 Q. And what are the software packages that 10 are utilized on the Perkin Elmer mini computer? 11 A. An applications package known as 12 Laboratory Information Management Systems from Perkin 13 Elmer, also abbreviated as LIMS. And that's all. 14 Q. What is LIMS' function; what does it do? 15 A. LIMS is a data collection analysis package 16 for chemical information. I should say laboratory 17 information, chemistry laboratory information. 18 Q. Are the data files on this Perkins Elmer 19 mini computer limited then to chemistry lab 20 information? If you know. 21 A. Yes, the data is limited to the results of 22 chemical analysis performed in the laboratory. 23 Q. What are the input peripherals on the 24 Perkins Elmer? 25 A. All the instrumentation in the chemistry PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 59 1 lab are linked through the network or through direct RS 2 232 communications to the Perkin Elmer. This includes 3 an auto analyzer, spectrometer, balance, carbon 4 analyzer, and some other chemistry instrumentation that 5 I'm really not familiar with. 6 I believe the question was what input 7 devices-- 8 Q. That's correct. 9 A. Okay. 10 There are some terminals directly wired to 11 the Perkin Elmer for input purposes, predominantly in 12 the chemistry--chemistry lab, and a console located in 13 the computer room is also directly attached to RS 232 14 ports on the rear of the Perkin Elmer. 15 Aside from the laboratory instrumentation 16 and the bar code readers associated with those 17 laboratory instruments, that is the only input devices 18 available to the Perkin Elmer. 19 One device that I guess should be called 20 an input device is a synchronous link to the Cyber 21 system for the purposes of doing a remote-job entry 22 used mainly for doing printouts. 23 Q. You mentioned directly-wired terminals in 24 the chemistry lab. Are there directly-wired terminals 25 to the Perkin Elmer elsewhere? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 60 1 A. No, and those may be all networked, as 2 well. They may run through NIU units. There may be 3 none that still have cables going physically into the 4 computer room, except, of course, for the console that 5 is located in the computer room and is directly wired. 6 Q. And what are the output devices on the 7 Perkin Elmer? 8 A. There is a direct wire to a line printer 9 located in the chemistry lab, a line printer obtained 10 from Perkin Elmer. I do not know the model of it. 11 There are terminals, both graphic and 12 textural. I believe they're all on the network at this 13 point, though it's possible we may still have some of 14 the graphics terminals hard wired directly to the 15 Perkin Elmer that are capable of being output to. 16 The only other output device would, again, 17 be the synchronous link to the Cyber system to the CDC 18 NET. 19 Oh, excuse me. There are also two mag 20 tape drives--at least one, I believe it's two, located 21 on the Perkin Elmer system for purposes of doing 22 backup. Those are nine-track tape drives. 23 Q. Other than the synchronous link to the 24 Cyber system that you've mentioned in both input and 25 output on the Perkin Elmer, is there any other PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 61 1 communications capabilities, networking capabilities on 2 that mini computer? 3 A. No, it has RS 232 ports, which link into 4 NIU 180's, and that's the only communications going in 5 and out of the system right now. 6 Q. The next mini computer you mentioned was 7 the Computer Vision mini computer? 8 A. Okay. 9 Q. What is that mini computer used for? 10 A. The Computer Vision system obtains graphic 11 and spatial images of the South Florida area in the 12 form of maps and ground clover--cover, as well as to 13 represent any spatial representation utilized in the 14 documentation of district buildings or structures. 15 Q. What is the operating system for the 16 Computer Vision mini computer? 17 A. CADDS, I think it's C-A-D-D-S, and I 18 believe the current version is 4.0, a Computer Vision 19 operating system. 20 Q. What software package are utilized on the 21 Computer Vision mini computer? 22 A. Purely CADDS 4. They are a graphical CADD 23 system. 24 One other software package is used called 25 CADSI, C-A-D-S-I. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 62 1 Q. What does the function of that software 2 package? 3 A. CADSI is used to convert Computer Vision 4 data bases, referring to graphical information, 5 into--into DIF files, which are compatible with 6 AUTOCAD. 7 Q. Which system utilizes AUTOCAD? 8 A. A number of the personal computers in the 9 district utilize AUTOCAD, as well as DEC station 10 5000's, a micro computer, and Sun 3 micro computers, as 11 well. 12 Q. What are the input devices for the 13 Computer Vision mini computer? 14 A. Computer Vision work stations with a 15 terminal digitizing tablet and keyboard. 16 Q. And how many of these Computer Vision work 17 stations are there in the district? 18 A. Associated with the Computer Vision mini 19 computer, there are four Computer Vision work stations. 20 Q. Where are those four work stations 21 located? 22 A. Again, things change in this area, but I 23 believe they are presently allocated in the division of 24 geographical sciences. 25 Q. Are there any other input devices to PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 63 1 access the Computer Vision mini computer? 2 A. There is a personal computer attached to 3 the Computer Vision through an RS 232 interface capable 4 of doing input. 5 Q. And where is that PC located? 6 A. In the geographical division--geographical 7 sciences division. 8 Q. What are the output devices on the 9 Computer Vision mini computer? 10 A. It has two magnetic tape drives, one seven 11 track and one nine track, plus, of course, the four 12 geographical work stations, in other words, Computer 13 Vision work stations, and the personal computer 14 attached through the RS 232 interface. 15 Q. Is there any other means to retrieve data 16 off this Computer Vision mini computer other than these 17 mag tape drives and the four CV work stations and the 18 PC you've previously mentioned? 19 A. No, that's the only forms, other than 20 possibly removeable disk on the Computer Vision mini 21 computer itself. 22 Q. Does the Computer Vision mini computer 23 have the capability of removeable disks? 24 A. Yes, it does. 25 Q. Is it so used? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 64 1 A. I don't believe so. I don't believe 2 they're ever taken off. 3 Q. You also mentioned a Micro VAX 2 mini 4 computers; is that correct? 5 A. That is correct. 6 Q. What is the operating system for the Micro 7 VAX 2 mini computers? 8 A. We--we distinguish the three different 9 Micro VAX 2 operating systems by the name of the user 10 that tends to use them the most. On the Micro VAX 2 11 for Rudy Vynanek-- 12 Q. Can you spell that last name? 13 A. V-y-n--this is going to be my best guess, 14 V-y-n-a-n-e-k. On the Micro VAX 2 for Rudy Vynanek, we 15 are running VMS 5.0. 16 On the Micro VAX 2 for Dewey Worth, 17 W-o-r-t-h, we are running VMS, I believe it's 18 still--it's now 5.0. It was 4.7, and I believe it is 19 converted over. 20 On the Micro VAX for Bob Mann, M-a-n-n, we 21 are running VMS 5.0. 22 Not to confuse the issue, some of these 23 people don't presently use the system anymore, but we 24 uniquely identify the system by those names. 25 Q. Are the same software packages utilized on PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 65 1 all three of the Micro VAX 2 mini computers? 2 A. No. 3 Q. Okay, then what are the software package 4 capabilities or software packages being utilized on the 5 one you call the Rudy Vynanek Micro VAX 2? 6 A. The software cap--capable of being 7 utilized on Rudy Vynanek's Micro VAX 2 is Oracle, 8 Wallengong, DCP and NFS, and Interconnections I*, 9 virtual circuits only. 10 There is some custom-developed software 11 for communications and data flex software. 12 Q. What is the function of the data flex 13 software? 14 A. It's a data base system used to store 15 quart-level readings, as well as all types of readings 16 collected in the field. 17 Q. Where is the Rudy Vynanek 2 Micro VAX mini 18 located? 19 A. In the section of the computer room walled 20 off for operations and maintenance department in the 21 district's headquarters complex. 22 Q. What other computers are located in this 23 section of the computer room that's walled off for 24 operations and maintenance? 25 A. A Mod Comp mini computer--actually, two of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 66 1 them, that are part of a telemetry system for 2 collecting data. 3 I may not have answered the question that 4 you want-- 5 Q. Are there any other computers-- 6 A. Yes. 7 Q. --of any size located in this area you've 8 indicated as operations and maintenance department? 9 A. There is also a Symbolics, I believe it's 10 a 3640 is the model number, artificial intelligence 11 work station. 12 Aside from personal computers and 13 terminals, that's all the devices in the fenced-off 14 section of the computer room that's designated for 15 operations and maintenance department. 16 Q. What are the input devices on the Rudy 17 Vynanek Micro VAX 2? 18 A. An Ethernet network board and some RS 232 19 ports for local terminals, plus an input RS 232 line 20 that goes to the Mod Comp system. 21 Q. Any other input devices on the Rudy 22 Vynanek Micro VAX 2? 23 A. Only devices that go through that Ethernet 24 controller board, including PC's and terminals. 25 Q. What are the output devices on the Rudy PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 67 1 Vynanek Micro VAX 2? 2 A. They, again, can access the networked 3 lazer printers on the network through their Ethernet 4 controller board, same as previous devices we've talked 5 about. They have terminals directly wired, which are 6 capable of output, and the RS 232 link to the Mod Comp 7 systems is also capable of being used for output. 8 The console, I believe, is a hard copy 9 device, as well, meaning a dot matrix teletype. 10 That's all the output devices that you can 11 get out through. 12 Q. What are the data files that would be 13 contained on the Micro VAX 2 Rudy Vynanek mini 14 computer? 15 A. Users within the operation--operations and 16 maintenance department have set up accounts for 17 selected users within their departments, and there may 18 be some files within those accounts. 19 There are data flex data bases containing 20 data and Oracle data bases containing data, most or all 21 relative to the real-time data being collected by the 22 Mod Comps. 23 Q. Is there a log of the data files on the 24 Rudy Vynanek Micro VAX 2? 25 A. One doesn't exist, but again, if a backup PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 68 1 were done, then all files backed up, the names of files 2 could be logged and printed. 3 MR. FROST: But that's a hypothetical. 4 Has that been done? 5 THE WITNESS: I cannot say for sure. 6 MR. FROST: Okay. 7 THE WITNESS: I don't know the answer to 8 that one. 9 MR. FROST: So it's purely speculation. 10 THE WITNESS: That is speculation. 11 BY MS. NASH: 12 Q. Moving on to the Dewey Worth Micro VAX 2. 13 What are the software packages utilized on that mini 14 computer? 15 A. Communications software, I squared S 16 software, and some language tools, as well. I believe 17 that's all. 18 Q. What is the function of the communications 19 software? 20 A. To communicate with other DEC systems. 21 Q. I'm sorry, what? 22 A. DEC, D-E-C. 23 Q. And what is the function of the I squared 24 S software? 25 A. It is an applications package for PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 69 1 manipulating and processing and outputting information 2 relative to remote sensing. 3 Q. And what are the functions of the language 4 tool packages you mentioned that are on the Dewey Worth 5 Micro VAX 2? 6 A. Correct. 7 There is Fortran. I don't know if he does 8 or does not have C. And certain applications supplied 9 with I squared S are dependent on those language tools 10 to function properly. 11 Q. Where is the Dewey Worth Micro VAX 2 mini 12 computer located? 13 A. In a special room located in the northeast 14 corner of the bui--of the headquarters complex. 15 Q. Are there other computer systems located 16 in this same special room? 17 A. Computer systems? Only personal computers 18 and I squared S work stations. 19 Q. What are the input devices on the Dewey 20 Worth Micro VAX 2? 21 A. It has an Ethernet controller board 22 capable of doing input, a synchronous line 23 capable--capable of dialing out to other computer 24 systems to obtain data, an I squared S scanner, a DEC 25 terminal, and the I squared S work station. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 70 1 Q. Any other input devices? 2 A. The I squared S scanner may actually be 3 two devices. 4 No, I'm sorry, it's just one device 5 capable of scanning a drawing. 6 No, there's no other devices that I can 7 think of. 8 Q. What are the output devices on the Dewey 9 Worth Micro VAX 2? 10 A. It's capable of outputing through a 11 Versatech graphics controller to Versatech color 12 plotters. It has an output device of a Techtronics--I 13 guess a page generator, output through the Ethernet 14 controller board to terminals and PC's, an output I 15 squared S drawings data through the synchronous 16 interface. There is also a console that's a hard-copy 17 console that you could output to, as well. 18 Q. Any other output devices? 19 A. Only devices reached, again, through the 20 Ethernet controller board, which include lazer printers 21 on the network. 22 Q. What are the data files that would be on 23 the Dewey Worth Micro VAX 2 mini computer? 24 A. I squared S data received from satellite 25 photography and then manipulated within the I squared S PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 71 1 system. 2 I'm sorry, can you repeat the question? 3 Q. Yes, what were the data files on the Dewey 4 Worth Micro VAX 2? 5 A. I would say all spatial data originating 6 from land sat photography. 7 MR. FROST: Do you know that? 8 THE WITNESS: I know that there are some. 9 I don't know of what areas, what wavelengths, 10 the particulars of it. 11 BY MS. NASH: 12 Q. Is there a log of the data files on the 13 Dewey Worth Micro VAX 2? 14 A. I'm not aware of one being maintained. 15 Q. The Bob Mann Micro VAX 2, what are the 16 software packages on that? 17 A. Oracle and Interconnections I*, as well as 18 some language tools. I believe that's all. 19 Q. Which language tools are on the Bob Mann 20 Micro VAX 2? 21 A. Actually--excuse me, there is also Free 22 Form and Britten Lee software residing on the Bob Mann 23 Micro VAX. RPH-- 24 Q. What was the last one you-- 25 A. I'll repeat them both. Free form and PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 72 1 Britten, B-r-i-t-t-e-n, Lee, L-e-e, host software. 2 Q. What are the language tool softwares on 3 the Bob Mann Micro VAX? 4 A. I believe it's both Fortran and C. 5 Q. What is the Free Form software package; 6 what is its function? 7 A. It is used for referencing the Britten Lee 8 data base from a screen orientation. 9 Q. And what is the Britten Lee host software? 10 A. It is software for accessing the Britten 11 Lee system. 12 Q. And what is the Britten Lee system? 13 A. The Britten Lee system is a--a data base 14 machine for storing relational data, commonly referred 15 to as a back-end data base machine. 16 Q. Where is the Bob Mann Micro VAX 2 mini 17 computer located? 18 A. In the computer room next to the Britten 19 Lee--excuse me, in the computer room next to the Perkin 20 Elmer. 21 Q. What are the input devices for the Bob 22 Mann Micro VAX 2? 23 A. An Ethernet controller board, plus 16 24 asynchronous ports, which I believe are not connected 25 to anything at present. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 73 1 Q. Any other input devices? 2 A. There is a console that is connected to 3 one of those 16 ports actually capable of, of course, 4 doing input. No other devices. 5 Q. What are the output devices on the Bob 6 Mann Micro VAX 2? 7 A. The same devices, the Ethernet controller 8 board and the 16 ports, of which one is used, and 9 devices on the network that can be referenced from that 10 Ethernet controller board. 11 Q. What are the data files on the Bob Mann 12 Micro VAX 2? 13 A. Some Oracle data base files used 14 previously for instruction on how to use Oracle, and I 15 believe that's it. There could be some temporary files 16 going to or from the Britten Lee. 17 Q. Are there any other mini computers 18 utilized by the water management district that you have 19 not yet described? 20 A. Yes. I did forget to earlier the two Mod 21 Comp classic two's that we encountered in the 22