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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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** 1
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 ROSALYND HOMER,
THE WITNESS, TAKEN ON
BEHALF OF THE PLAINTIFFS
- - - - - - - -
DATE: August 23, 1990
PROFESSIONAL REPORTING SERVICE
Suite 303, 324 Datura Street
West Palm Beach, Florida 33401
(407) 659-4046
** 2
I N D E X
August 23, 1990 DIRECT CROSS
ROSALYND HOMER
By Ms. Nash 5
By Mr. Richards 18
** 3
The deposition of ROSALYND HOMER, the witness, in the
above-entitled and numbered cause, was taken before me,
DONNA McCALLEY, Registered Professional Reporter, and
Notary Public for the State of Florida at Large, at
Suite 110, 324 Datura Street, in the City of West Palm
Beach, County of Palm Beach, in the State of Florida,
beginning at the hour of 2:14 p.m., on Thursday, the
23rd of August, 1990, pursuant to the Notice in said
cause for the taking of said deposition, which is
annexed to the court file herein, on behalf of the
Plaintiffs in the above-entitled action pending in the
above-named court.
The appearances at said time and place
were as follows:
UNITED STATES DEPARTMENT OF JUSTICE
Room 868, 601 Pennsylvania Avenue, N.W.
Washington, D.C. 20044-0663
Attorneys for the Plaintiffs, U.S.A.
By BEVERLY SHERMAN NASH, ESQ.
PEEPLES, EARL & BLANK, P.A.
Suite 3636, Two South Biscayne Boulevard
Miami, Florida 33131
Attorneys for the Cities of Belle Glade
and Clewiston
By JOSEPH RICHARDS, ESQ.
SKADDEN, ARPS, SLATE, MEAGHER & FLOM
1440 New York Avenue, N.W.
Washington, D.C. 20005-2107
Attorneys for the South Florida Water
Management District
By KATHARINE STOLLMAN, ESQ.
ALLISON BURDETTE, ESQ.
** 4
APPEARANCES CONTINUED:
SOUTH FLORIDA WATER MANAGEMENT DISTRICT
3301 Gun Club Road
West Palm Beach, Florida 33416-4680
By JACQUELYN L. WATERS, ESQ.
ALSO PRESENT: Ray Roberts
Robert Johnson
** 5
THEREUPON:
ROSALYND HOMER,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Would you state your name.
A. Rosalyn Homer.
Q. Miss Homer, I'm Beverly Nash from the--I
represent the United States in this litigation. And
we're here to find out about the water management
district's computers, what information is on the
computers, how the information's maintained, and you've
been selected by the district as a representative
having information on certain categories that we're
inquiring about.
Have you been shown the list of
categories?
A. Yes.
Q. And what category are you here to respond
to?
A. I believe it's number two of the list.
Q. What is your present title?
A. Senior staff analyst.
Q. In what division or department?
** 6
A. The Department of Finance and
Administration.
Q. I'm sorry?
A. The Department of Finance and
Administration.
Q. Is there a particular division within that
department?
A. There are seven divisions within that
department. Seven divisions within that department.
Q. And are you a staff analyst in one of
those divisions or for the whole division? I mean in
one--for the whole department?
A. Ah, for the entire department. However,
my position is housed in one of the divisions, Division
201.
Q. What is your job description?
A. Coordinator of a number of functions,
budget development, training. I perform special
projects at the direction of the department director.
I--I assess, review regularly policy and procedures.
I've even written policies and procedures on occasion.
Assessment of the procedures that are in--in existence
within the department for the determination of their
effectiveness and efficiency.
Q. How long have you been in this role of
** 7
senior staff analyst?
A. A little more than three years.
Q. Have you had other positions at the water
management district?
A. Yes, I have.
Q. What are those positions?
A. I was a budget analyst before being
promoted to the position of senior staff analyst.
Q. And how long were you budget analyst?
A. From April of '87 through November.
Q. Did you have a position at the water
management district prior to being a budget analyst?
A. No, I did not.
Q. How have your duties changed from when you
were a budget analyst to being a senior staff analyst?
A. I'm not sure what you mean by that.
Q. Did your duties change?
A. Yes, they have. They did.
I mean the positions function differently
within--within the district.
Q. What were your functions, your
responsibilities as budget analyst?
A. Primarily districtwide coordination of the
budget development process.
Q. And for whom do you work in the Finance
** 8
and Administration Department?
A. My immediate supervisor is James Yaeger.
Q. Do you have any employees in the
department that work for you?
A. One position reports to me.
Q. And what position is that?
A. Staff analyst.
Q. And who is in that position?
A. Donna Beckner.
Q. You mentioned that you're coordinator of a
number of functions. What are those functions that you
coordinate?
A. Other than the ones that I've previously
defined for you?
Q. Yes.
A. There are no others other than the ones I
detailed for you.
Q. Those were budget development; is that
correct?
A. (Witness nods head.)
Q. Training and special projects?
MS. STOLLMAN: You need to say yes out
loud.
A. Yes.
** 9
BY MS. NASH:
Q. What are special projects that you have
coordinated?
A. They vary, and they are assigned at the
discretion and direction of the department director.
Q. Can you name any specific projects that
you have coordinated?
A. Yes.
Q. What are those projects?
A. The writing of procedures, the development
of scope--scopes of work for requests for proposals,
analysis of data and information.
Q. On what subjects have you written
procedures?
A. Petty cash, primarily.
Q. And what is the nature of request for
proposals that you have written scopes of work?
A. For human resource consultants services
for training. That's training for districtwide staff.
Q. What is the nature of the training, in
what areas?
A. Cost benefit analysis.
Q. Do you use computers to do any of these
functions you've described?
A. Yes.
** 10
Q. And what computers do you use?
A. What computers?
Q. Yes.
A. Personal computer.
Q. Which PC do you use?
A. The brand? Is that...
Q. Yes.
A. It's an IBM, yeah.
Q. Do you use any other personal computers?
A. No, I do not.
Q. Do you use any mini computers at the water
management district?
A. No, I don't.
Q. Do you use any of the mainframe computers
at the water management district?
A. I don't use them directly--
Q. Do you--
A. --no.
Q. Do you use indirectly?
A. I access information from the computers,
but I do not operate them.
Q. From which computers do you access
information?
A. The mainframe.
Q. Which ones, do you know?
** 11
A. The IBM.
Q. What procedures do you use for accessing
information from the IBM mainframe?
A. I access that information through the
personal computer that I have at my work station.
Q. Can you take me through the steps that you
use to access the mainframe? What exactly do you do?
A. The procedure, as I understand it,
entails--all I basically do is choose options on a
menu. That--that is primarily what I do. The
mechanics of that, I do not know.
Q. Do you know what the software program is
that you use?
A. No, I do not.
Q. Why don't you take me through the exact
steps.
When you sit down at your computer
terminal and you want to access the mainframe, what
exactly do you do step by step?
A. I choose menu options.
Q. How do you get those menu options?
A. They are available from the PC that I have
at my work station.
Q. And what do you do to the PC to get those
menu options?
** 12
A. Turn it on.
Q. And the menu options are there when you
turn it on?
A. Yes.
Q. Do you have to program in any instructions
or codes to get to those menu options?
A. No, I do not.
Q. Did I understand correctly, you do not
know what the software package is that you're using; is
that correct, it's whatever's on your PC?
A. No, I--I do not know, no.
Q. Do you store files on your PC?
A. Yes, I do.
Q. And what procedure do you use to store
those files?
A. They are stored primarily using disks that
are made available to us at the district.
Q. And what steps do you take if you want to
store something you've created? What do you do?
A. The storage usually occurs once I'm
completed or done developing whatever project it is
that I'm working with and whatever software. So the
command to store is usually contained within the
software package that I'm working with.
Q. You don't know the names of any of the
** 13
software packages you work with.
A. Yes, I do.
Q. What software packages do you work with?
A. Symphony, Word Perfect, Harvard Graphics--
Q. What were--
A. --Diagraph.
Q. I'm sorry, what was the last?
A. Diagraph.
Q. What work do you do with Symphony?
A. I use it primarily in the
budget-development process or the tracking and
summarization of information from budget development.
I use it in--or I may use it in the development of
information for special projects that I have been
assigned.
Q. And what use do you make of Word Perfect?
A. I use it for the construction of memos
that I issue, for the drafting of information for
projects, such as the RFP's that I mentioned, and for
the development of procedures.
Q. And what use do you make of--you said
Marvard (sic) Graphics?
A. Harvard?
Q. Yes, what use do you make of that?
A. It's used primarily to--to picture, if you
** 14
will, the data and information, whatever data and
information I'm working with.
Q. What do you mean "to picture the data"?
A. Meaning to put it in graphic format,
rather than--than just showing numbers.
Q. And what use do you make of Diagraph?
A. It's a--an enhancement package, contains a
number of pictures. It's basically used to--to enhance
and format data and reports that I'm producing.
Q. Do you transfer any of the reports that
you do to other computers?
A. Yes, I do.
Q. And what procedure do you utilize to do
that transfer?
A. That's done through the--the network
that's in establishment at the district--
MS. STOLLMAN: Do you want some water?
THE WITNESS: No.
A. (continuing) --whereby information is
transmitted and store it to--temporarily in another PC
for access by other work stations, other work stations
or a specific work station.
BY MS. NASH:
Q. What other offices in the water management
district do you transfer files to?
** 15
A. To the budget--the executive office,
office of management and budget, now I believe it's
called. Also, occasionally to other divisions within
the department.
Q. What would those other divisions be?
A. Primarily personnel.
Q. To whom do you make inquiry if you have
questions about using your computer?
A. About the use of it?
Q. Yes.
A. I'm not sure what--what specific
application are you talking about? How to turn it on
or...
Q. If you have a question--
A. (Witness sneezes.)
Q. Bless you.
A. Go ahead.
Q. If you have a question on how to turn on
your computer, to whom would you go?
A. The computer management division of the
office of technical services, the department of
technical services.
Q. If you have questions on how to transmit
data files to others within the water management
district, to whom would you go?
** 16
A. That same source.
Q. Do you store files on the IBM mainframe?
A. No, I do not.
Q. What files do you access from the--that
are on the IBM mainframe?
A. Information regarding the department's
budget.
Q. Do you access any other information from
the IBM mainframe?
A. No, I do not.
Q. Do you ever transfer reports or files to
anyone outside the water management district?
A. Transfer?
Q. Using your computer.
A. No, I do not.
Q. Do you have a list of the files that are
stored on your PC?
A. Do I have a list?
Q. Yes.
A. Yes, I do.
Q. Does that list have a name?
A. It's--yes.
Q. What is the name?
A. It's called a directory.
Q. Is it a directory under your name, or is
** 17
it just called the "directory"?
A. It's--well, there are more than one
directory. One exists under my name, yes.
Q. If someone else wanted to access files
that you had created, how would they do so?
A. By accessing the PC.
Q. And would they have to give them the name
of your directory?
A. Not for access to all of the files that I
have created, no.
Q. Are there files that you have created that
are not on the PC?
A. No.
Q. Do you utilize electronic mail in your
work?
A. I'm not sure what you mean by that.
Q. Do you send messages or correspondence or
other documents to others, either within your division,
within your department or other departments in the
water management district, using the computer?
A. Yes, in the manner that I previously
indicated.
Q. You're not aware of something called
electronic mail where you can send messages?
A. I am aware of it.
** 18
Q. Do you utilize it?
A. No, I do not.
MS. NASH: I have no further questions.
MS. STOLLMAN: How are you doing? Are you
all right? Do you want to take a break?
THE WITNESS: I don't understand.
MS. STOLLMAN: Now we have another
attorney who is gonna ask you questions.
THE WITNESS: Yeah, I'm okay.
CROSS EXAMINATION
BY MR. RICHARDS:
Q. Miss Homer, my name is Joe Richards. I
represent the Cities of Belle Glade and Clewiston.
Do you do any work with scientific data?
A. No, I don't.
Q. Are you familiar with the Everglades SWIM
plan? Do you know what the Everglades SWIM plan is?
A. If I had--no, I don't. You mean--of
course I've heard of it, yes. But in terms of having
to define it to you, no, I would not be able to.
Q. Have you done any budgetary work for the
Everglades SWIM plan?
A. No, I have not.
MR. RICHARDS: I don't have any further
questions.
** 19
MS. STOLLMAN: Okay.
MR. RICHARDS: Thank you.
(Whereupon, the deposition was concluded
at 2:37 p.m.)
