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THEREUPON:
ELIZABETH PACKER,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Would you state your name, please.
A. Elizabeth Packer.
Q. Mrs. Packer, I'm Beverly Nash, and I'm
counsel for the United States in this litigation.
And we're here today to try and understand what
computers the water management district has, how
they're utilized, what data is on them, how they're
formatted, and you're here today as a representative
having knowledge concerning one or more of nine areas
that we were inquiring about.
Have you been shown the list of areas?
A. Yes, ma'am.
Q. And what areas are you knowledgeable
about?
A. I believe the copy of the notice that we
received, probably the only thing that I'll be able to
give you any information on is item number two.
Q. What is your present title or position?
A. Legal administrative assistant,
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Administration.
Q. And what division or department is that
in?
A. Office of Counsel.
Q. What is your job description?
A. Basically I provide administrative and
secretarial support for the Deputy District Counsel and
the Inter-agency Coordinator.
Q. And what you are your responsibilities in
that job?
A. Whatever kind of support that they need.
I do typing, set up meetings, keep files, make sure
that they have what they need when they go to their
meetings, documents and thing things that they need to
take with them.
Q. And how long have you been in that role?
A. I'm not sure exactly, but I think it's
about seven years.
Q. Have you had other positions at the water
management district?
A. Yes.
Q. What positions?
A. I was an executive secretary and I was a
legal secretary.
Q. In what divisions?
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A. In the Legal Department.
Q. And how long were you in those positions?
A. Approximately three years each.
Q. Who are your supervisors in Office of
Counsel?
A. The Deputy District Counsel and the
District Counsel.
Q. Who's the Deputy District Counsel?
A. Irene Quincy.
Q. And the District Counsel?
A. Steve Walker.
Q. Do you use computers in your present job?
A. Yes, ma'am.
Q. What computers do you use?
A. I use a Xerox 6085 and an IBM PC.
Q. What records or files do you keep on the
Xerox 6085?
A. Mostly just correspondence, memos,
letters.
Q. Do you make different use of the IBM PC?
A. Basically the only thing I use the IBM PC
for is to transfer documents from one system to the
other.
Q. And what is the nature of the documents
that you would be transferring?
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A. The same kind of things. Same kinds of
things, memos and letters, correspondence.
Q. The memos, letters and correspondence
you're referencing relate only to matters in office of
counsel?
A. Yes, ma'am.
Q. Do you use a particular software package?
A. We use Viewpoint on the Xerox system and
we use Word Perfect on the IBM PC.
Q. Are there documents or manuals that you
use to assist you with the work you do on the Xerox
6085?
A. I'm not sure what you mean by "documents."
Q. If you have a question when you're trying
to do some work on the Xerox 6085, is there something
that you can reference to assist you?
A. We have an instruction manual, yes.
Q. Do you know the name of that manual?
A. No, ma'am, I do not.
Q. Is there anyone you turn to for assistance
if you have a question when using the--
A. Yes, ma'am. We contact the computer
hotline, and that's in the Technical Services
Department.
Q. Is there a different manual that you
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reference when you're using the IBM PC?
A. Yes.
Q. And what manual is that?
A. I don't know the name of it.
Q. And is there an individual or individuals
that you would contact if you have questions?
A. Again, we call the computer hotline.
Q. What procedure do you use for storing
documents on the Xerox 6085?
A. I'm not sure. I know what I have to do to
close the document out and it stays on my desktop, but
I don't--I don't know what technically, what that is.
Q. Do you know what procedure you use for
transferring documents on the IBM PC?
A. Yes, ma'am.
Q. What is that procedure?
A. We convert the document from Viewpoint to
document interchange format, put the document on a
disk, take the disk to the IBM PC, convert it from
document interchange format to Word Perfect on the IBM
PC.
Q. And to go from the PC to the Xerox 6085,
what procedure do you use?
A. There's a program on the PC that's called
Exchange. It's a menu selection that the operator
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makes, and you just answer a couple of questions and it
sends the document. I don't know the technical aspects
of that.
Q. Do you utilize what's called electronic
mail on the Xerox 6085?
A. Yes.
Q. What is the procedure?
A. You copy the document to the out basket
and you get a window that comes up and asks you who you
want to send it to. You type in the name of who you
want to send it to, and that sends the document.
Q. Is there a process for archiving or
retaining documents that you send through electronic
mail?
A. I'm not sure other than just keeping the
copy on your own desktop. I don't really know.
Q. Do you do any backup procedures on the
documents you have which you reference as your desktop?
A. Yes, we can. We have the capability to
store them on a disk.
Q. Do you do so?
A. Not all documents.
Q. What is the distinction between those
documents you store and those you don't?
A. Normally we only store something on a disk
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that we feel we may have a need to reference again in
the future.
Q. Do you keep hard copies of all the
documents?
A. Usually, yes.
Q. To create a new document on the IBM PC,
what would you do; what steps would you go through?
A. You would select Word Perfect from the
menu, and when the software goes into effect, it opens
a blank document for you on the screen.
Q. And if you wanted to retrieve a document
that you had previously created, what steps would you
go through?
A. You would punch the keys that says to
retrieve and give it the name of the document.
Q. Is there a list maintained of the
documents that are stored on your PC?
A. Not to my knowledge.
Q. Is there a list of documents that's
maintained of the documents stored on the Xerox 6085?
A. No, ma'am.
Q. Where do you go, then, if you want to
retrieve a document?
A. From which machine?
Q. From the Xerox 6085.
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A. It's usually on the desktop.
Q. But there's no list that's maintained of
those documents.
A. No, ma'am.
Q. And if you want to retrieve a document
that's on the IBM PC, where do you go?
A. You can do a directory of what you have on
your disk and select the item from that disk. But to
my knowledge, there is no listing of what's on the disk
other than to ask the directory of the disk.
Q. Do you know whether other use is made of
the computers that are in your division in the work you
do?
A. I don't know.
Q. Are you ever requested to transfer
correspondence or memos or files to agencies or offices
outside the water management district?
A. I don't remember ever having to do that.
Q. Do you transfer data or files to other
offices within the water management district?
A. Yes.
Q. How do you do that?
A. If the other person has a Xerox, you send
it electronically. And if they don't, we can put it on
a disk and send it to them.
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Q. And do you ever receive data or documents
from other divisions in the water management district?
A. Yes.
Q. And is there any difference in the
procedure for doing that?
A. No.
MS. NASH: I have no further questions.
MS. STOLLMAN: Do you want to take a break
before the next attorney starts?
THE WITNESS: No.
MS. STOLLMAN: Okay.
CROSS EXAMINATION
BY MR. RICHARDS:
Q. I'm Joe Richards. I represent the
the Cities of Belle Glade and Clewiston.
You mentioned a computer hotline that you
use for questions when you operate the computer.
A. Yes, sir.
Q. Is there an individual at the district who
is responsible for that hotline?
A. I don't know. It's in the technical
services department is all that I know. I don't know
whose responsibility it is.
Q. Are you familiar with the term "SWIM,"
Surface Water Improvement in Management?
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A. Yes, sir.
Q. Have you done any work in drafting the
SWIM plan or any portions thereof for the everglades?
MS. STOLLMAN: Could you explain the
relevance of that?
MR. RICHARDS: I'm just trying to find out
the location of the files and any data
information.
MS. STOLLMAN: You can answer.
A. We have commented on drafts that have been
sent electronically to us and sent those comments back
to whoever requested them. But as far as actually
doing the draft, no.
BY MR. RICHARDS:
Q. You have edited--
A. Yes.
Q. --or altered those drafts?
A. Um-hum.
Q. Do you know who has done that?
A. No, sir, I don't.
Q. You don't know which person within the
office of counsel has done that?
A. Several of the attorneys work on that.
There's not just one person.
Q. Do you know who they are?
15
A. I don't know which ones do what part. No,
I don't know.
MR. RICHARDS: Thank you. I don't have
any other questions.
(Whereupon, the deposition was concluded
at 11:56 a.m.)
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E R R A T A S H E E T
PURSUANT TO RULES OF CIVIL PROCEDURE, this deposition is being submitted to you for
examination, reading and signing. Please do not write on the transcript. Any change in
form or substance you desire to make should be entered upon this sheet as follows:
PAGE NO., LINE NO._________CHANGE_____________REASON___
DATE:__________________
ADDRESS:_____________________
_____________________
COUNTY OF:___________________
_________________________
_________________________
Signature
of Witness
___________________
Notary
Public, State of
Florida
at Large. My
Commission
Expires:
17
I,
ELIZABETH PACKER, do hereby certify
that I have read the foregoing transcript of my
deposition given on August 23, 1990; that together with
the correction page attached hereto noting changes in
form or substance, if any, it is true and correct.
____________________________
ELIZABETH
PACKER
I
do hereby certify that the deposition of
ELIZABETH PACKER was submitted to the deponent for
reading and signing; that after deponent had stated to
the undersigned Notary Public that deponent had read
and examined said deposition, deponent signed the same
in the presence of the undersigned authority on
the day of , 1990.
_____________________________
Notary
Public
My commission expires:
18
CERTIFICATE
THE STATE OF FLORIDA, )
COUNTY OF PALM BEACH. )
I, DONNA McCALLEY, Registered Professional
Reporter, and Notary Public for the State of Florida at
Large, do hereby certify that I reported the deposition
of ELIZABETH PACKER, called by the Plaintiffs in the
above-entitled action; that ELIZABETH PACKER was duly
sworn by me; that the foregoing pages numbered from 1
to 15, inclusive, constitute a true record of the
deposition given by said witness.
I further certify that I am not attorney
or counsel for any of the parties, nor a relative or
employee of any of the parties or any attorney or
counsel connected with the action in which this
deposition is taken, nor financially interested in the
action.
WITNESS MY HAND and official seal in the
City of West Palm Beach, County of Palm Beach, State of
Florida, this 31st day of August, 1990.
__________________________________
Registered Professional Reporter.
and Notary Public, State of Florida
at Large.
My Commission Expires: 10/25/90.
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