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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 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.)
