** 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 EDUARDO PADILLA, 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 EDUARDO PADILLA By Ms. Nash 5 By Mr. Richards 15 ** 3 The deposition of EDUARDO PADILLA, 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 3:42 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: EDUARDO PADILLA, having been first duly sworn, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Will you state your name. A. Edwardo Padilla. Q. Can you spell that for the reporter. A. E-d-u-a-r-d-o, last name is P-a-d-i-l-l-a. Q. Mr. Padilla, I'm Beverly Nash. I represent the United States in this litigation. And we're here to find out what the water management district has in the way of computer systems, what data is kept on computers, how that data is formatted, how it's transferred between computers, and you've been designated as responsive to various categories that we're interested in finding out about. Have you been shown that notice of categories? A. Yes. Q. And what category are you here to respond to? A. Well, I don't remember which number, but particularly with PC's. ** 6 Q. What is your present title or position? A. I am a senior electronic tech supervisor. Q. In what division or department? A. Computer Management. Q. And what are your--what is your job description? A. Basically maintenance and service of PC equipment, network system and peripherals related to network and PC's. Q. And how long have you been--been a senior electric--electronics technician supervisor? A. Approximately a year and a half. Q. Have you had prior positions with the water management district? A. As a different position title, yes. Q. What position title was that? A. Was electronic computer tech. Q. And how long were you in that position? A. Two years. Q. And how did your job differ from your present position? A. Minimal. Just this new title is just supervise and a higher grade. Q. Any prior positions with the water management district? ** 7 A. No. Q. What is your training and educational background in the computer area? A. I have an AS in electronic technology engineering. I am also working on a computer science degree. And approximately ten years of computer background. Q. Who is your supervisor in the Computer Management Division? A. Lavinia Ricketts. Q. Are there any employees in the Computer Management Division that work for you? A. Yes. Q. And who are they? A. Donald Turner. Q. And what does Mr. Turner do? A. Repair computers, PC's specifically, and peripherals. Q. You indicated amongst your job responsibilities was maintenance and service of PC's? A. That's correct. Q. Which PC's do you maintain and service? A. Specifically the IBM systems, all IBM PC's. Q. Can you be more specific about what you do ** 8 in maintaining and servicing the PC's? A. Yes. Repair the XT's, AT's, PS 2 line series, which consist of Models 30, 286, Model 50's, 60's, 70's, 80's, also the servers, which are Model 80's, and a network system which consists of peripherals, network peripherals, and any associated cards, network cards, printers, any kind of device that is connected to any of those computers. Q. Which peripherals are you responsible for? A. Is that models? Q. Yes. A. Absence, IBM, HP, Call Comp. That's pretty much it. Also, I forgot to mention certain communication, network communication equipment, Motorola, Ungermann Bass equipment, those type of peripherals also that pertains to the network. Q. When you say you service the network, what does that entail? A. Oh, the functionality of it, the operations of each equipment that can cable that is connected to the network system, to be able to communicate with the servers, to be able to communicate with some of our bridges that we have, that sort of ** 9 thing. Q. Can you describe the network servers that you utilize? A. They are IBM Model 80's, disk drives are a total of 700 megabytes each. They have Ungermann-Bass software, which is set up as a server-type arrangement so they serve to the client. They have peripherals of many types, can range between lazer printers, dot matrix printers, vernouli cartridges, which are a storage device. What else? That's pretty much it. Q. And can you describe the bridges you mentioned that you utilize? A. Some of the ones I'm familiar with are the Atlanta 100's, which is a DEC-type, and their function. Also, the cabling arrangements and organization of some of the TCL equipment that communicate with the print PC's. Also, some of the fiber optics equipment that we use which is related, which is Secor, to communicate between two different sites. Codex equipment, which is a modem company. It's used by--it's the model Codex. They communicate through digital lines to different field stations. That's pretty much it. ** 10 Q. Can you describe the fiber optics communications you mentioned? A. We communicate on our campus through fiber using Secor products. There's the main star coupler, which is in the computer room. They communicate with other Secor fiber optic transceivers, which are located in different trailers among--around the building. And they are point-to-point using fiber cables. Q. And you also indicated commune--communicating to field stations through digital lines? A. That's correct. What you have is basically transland equipment, various models that hook up to Codex model systems, Codex modems, and then from there is digital line out. And then at the field stations you have the same equipment on those lines receiving the information and transmitting the information. Q. Are you aware of the nature of the data that's transmitted from the field stations? A. As far as I know is just basic dos-level files transferred among each other. Q. Do you know what that data relates to? A. Ah, no. Q. You said there were various models of ** 11 transland equipment. Do you know what models there are? A. I know of one model, 320. The others, I'm not sure of. Q. Do you know how many others there are? A. I believe there are two other different models. Some are more sophisticated than others. Q. Do the PC's you maintain, are they all over the district or are they located only within certain divisions? A. Throughout the district. Q. Is that also true with the peripherals that you maintain and service? A. That's correct. Q. Do you do any work with the operating systems that are utilized on these computers? A. Yes. Q. What do you do? A. Basically we prepare format and install dos operating system. Q. That's on all the PC's? A. That's correct. Q. Do you have any responsibilities for any of the software packages utilized on the PC's? A. Just the functionality of them. ** 12 Q. What do you mean by "functionality"? A. Well, if there's a problem pertaining to a specific software package or some kind of conflict, anything that pertains to a persistent problem to the user. Q. What is your role; what do you do if there is a problem? A. I make corrective actions, I resolve the problem, either through electronic background or the software manufacturers. For the hardware equipment itself, determining if it's defective. Q. Do you know what software packages are utilized on the IBM PC's? A. Majority. Q. Which ones are those? A. Word Perfect, Symphony, Harvard Graphics, AUTOCADD, Tech Graphics, Windows and Utilites, just general Utilites. Q. Do you know of any water management district-created software packages that are utilized on the IBM PC's? A. Be more specific. I'm not sure what you're referring to. Q. Word Perfect, for example, was not created by the water management district; is that correct? ** 13 A. That's correct. Q. Nor was Symphony. A. That's correct. Q. Are there any software packages utilized on the IBM PC's that you're aware of that were created within the water management district itself? A. I'm--don't have a direct relationship with those packages. No, I don't know. Q. Do you have responsibilities for any of the mini computers in the water management district? A. No. Q. Do you utilize any of the mini computers? A. Some. Q. Which ones? A. The VAX. Q. What work do you do on the VAX? A. We have our--our own data base system there for equipment and peripherals. Q. What is the nature of the data in that data base system on the VAX? A. Basically information that's hardware-related and software-related for each user; in other words, equipment-type serial numbers, models that pertain to a user. Q. For each user within the Computer ** 14 Management Division or all the divisions in the water management district? A. All divisions. Q. Does that data base system you've been describing have a name? A. We just call it equipment data base. Q. And that's related to the equipment that each user utilizes; is that correct? A. Each--that each person has as their personal use; in other words, whatever's on their desk and they utilize. Q. Do you know whether there's a data base for the data files that users create or use? A. No, I'm not familiar with any. Q. Do you use any of the other mini computers? A. No. Q. Do you use any of the mainframe computers? A. That would be the mainframe that I use, the VAX, the main one, the 8820. Q. So the data base system you're referencing is on the VAX 8820? A. (Witness nods.) MS. NASH: No further questions. ** 15 CROSS EXAMINATION BY MR. RICHARDS: Q. Mr. Padilla, my name is Joe Richards. I represent the Cities of Belle Glade and Clewiston. Are you aware of the accidental loss of any data files? A. Yes. Q. Would you know what those data files contained? A. Not specifically. Q. Do you know who, what individual users, have lost data files? A. No. Q. Do you know what departments they were in? A. Yes. Q. What departments is that? A. In our legal office counsel. Q. Any others? A. Not offhand. Q. Do you know who in the legal department would know what files were lost? A. No. Q. Do you have any knowledge as to the data contained on the different PC's which you maintain and service? ** 16 A. Specific to what? I'm not sure-- Q. What kind of data, water quality data. A. Oh. They could be numerous types. Word Perfect data, Symphony data, Data Flex data, users' data programs. Q. You don't know specifically who, what types of data are contained on those files, on those computers? A. Well, it's pretty broad. I mean there's 500 PC's. Any one specifically or-- Q. Within the Water Quality Division. A. No. Q. Environmental Planning Division? A. No. Just those programs that I mentioned earlier are used throughout the district. MR. RICHARDS: All right. I have no further questions. Thank you. THE WITNESS: You're welcome. (Whereupon, the deposition was concluded at 4:03 p.m.)