|
|||||||
Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
|||||||
|
|||||||
|
|||||||
|
|||||||
Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
|||||||
|
|||||||
|
|||||||
** 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 )
REGULATION; AND DALE TWACHTMANN, )
SECRETARY, FLORIDA DEPARTMENT OF )
ENVIRONMENTAL REGULATION, et. al., )
)
Defendants. )
/
DEPOSITION OF LAVINIA RICKETTS
TAKEN ON BEHALF OF THE PLAINTIFF
***
DATE: August 27, 1990
PROFESSIONAL REPORTING SERVICE
Commerce Center
324 Datura Street, Suite 303
West Palm Beach, Florida 33401
(407) 659-4046
** 2
INDEX
August 27, 1990 DIRECT CROSS REDIRECT RECROSS
LAVINIA RICKETTS
By Ms. Beverly Nash 5
By Mr. Joe Richards 21
** 3
The deposition of Lavinia Ricketts, in the
above-entitled and numbered cause, was taken before
me, KAREN BAUER FRY, C.S.R., Court Reporter and
Notary Public for the State of Florida at Large, at
Professional Reporting Service, Commerce Center,
324 Datura Street, in the City of West Palm Beach,
Palm Beach County, in the State of Florida,
beginning at the hour of 3:20 o'clock p.m., on
August 27, 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
Plaintiff in the above-entitled action pending in
the above-named court.
The appearances at said time and place were
as follows:
Beverly Sherman Nash, Esquire
U.S. Department of Justice
Environmental and Natural
Resources Division
P. O. Box 663
Washington, D.C. 20044-0663
Attorney for Plaintiff
Joseph Richards, Esquire
Peeples, Earl & Blank, P.A.
Two South Biscayne Blvd.
One Biscayne Tower, Suite 3636
Miami, Florida 33131
Attorney for Cities of Belle Glade
and Clewiston
** 4
Katharine Stollman, Esquire
Allison Burdette
Skadden, Arps, Slate, Meagher, & Flom
1440 New York Avenue, N.W.
Washington, D.C. 20005
Attorney for South Florida Water
Management District
Jackie Waters, Esquire
So. Florida Water Management District
Box 24680
3301 Gun Club Road
West Palm Beach, FL 33416
ALSO PRESENT: Toni Lafuente
Mike Rose
David Buker
** 5
THEREUPON,
LAVINIA RICKETTS
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Ms. Ricketts, I'm Beverly Nash, counsel
for the United States in this litigation.
We're here to try and find out what
computer systems the Water Management District
has, how people use the computers, how that data is
on the computers, how that data is formatted.
You're here as a representative of the
district to respond to one or more of the various
categories of information that we are interested
in.
Have you been shown that list of
categories?
A. Yes, I have.
Q. And which category or categories are you
here to respond to today?
A. I am familiar with the third item.
Q. What is your present title or position?
** 6
A. It's supervising senior systems analyst.
Q. In what division or department?
A. The division is computer management
division. The department is technical services
department.
Q. And what is your job description?
A. Could you tell me something more specific?
Q. What are your responsibilities?
A. I oversee the systems section of the
computer management division.
Q. And what does that entail?
A. It covers personal computers, networking,
and system support on the DEC systems.
Q. And how long have you been a supervising
senior systems analyst?
A. I believe I have held that title for three
years, approximately three years.
Q. Have you had other positions at the Water
Management District?
A. Yes, I have.
Q. And what are those positions.
A. I was a senior systems analyst, and I was
a system programer.
Q. How long were you senior systems analyst?
A. Approximately a year.
** 7
Q. And what were your responsibilities as a
senior systems analyst?
A. Support on personal computers and
networking.
Q. And how long were you a systems
programer?
A. Approximately a year.
Q. And what were your responsibilities as a
systems programer?
A. Support of personal computers and some
centralized systems.
Q. Were these positions in the computer
management division?
A. I believe the division had a different
title at the time.
Q. But it was basically the same position?
A. Yes.
Q. What's your educational background?
A. I have a Bachelor of Science degree.
Q. In what area?
A. The degree doesn't specify an area.
Q. From what school?
A. Newcomb College of Tulane University.
Q. Who are your supervisor or supervisors in
the computer management division?
** 8
A. Presently?
Q. Yes.
A. Bill Hall, Bob Mann, and John Lynch.
Q. What's Mr. Hall's title?
A. Director of computer management division.
Q. And what is Mr. Mann's title?
A. I believe the title is assistant director
of computer management division.
Q. And Mr. Lynch's title?
A. Director of technical services
department.
Q. Are there employees in the computer
management division that work for you?
A. Yes, there are.
Q. Who are those employees?
A. Do you want me to name them all?
Q. How many are there?
A. Better than five.
Q. Would you name them and tell me what their
position is?
A. Connie Falls is a systems analyst. David
Sweet is a systems analyst. Pat Cordero is a -- I
believe the title is computer systems technician.
Eduardo Pedilla is a senior electronics computer
technician. Don Turner is a computer electronics
** 9
technician. Mitch Krolick is a computer system
technician. Danny Reid, is a computer system
technician. Kevin Smith is a computer system
technician. Paul Crosby is a computer system
technician. I believe that's all of them.
Q. You indicated had that you oversee the
systems section of the computer management
division involving the PCs?
A. I oversee the systems section of the
computer management division.
Q. Does that include all of the personal
computers?
A. Yes, it does.
Q. And what are your functions in overseeing
the personal computers? What do you actually do on
a day-to-day basis?
A. I coordinate with the different sections
in my area to assure that different groups have
information, the one area has information on what
another area is doing, and coordinate information
to the computer coordinators in the different
departments to insure that they know what is
occurring or that they have conveyed to me any
problems in the area.
Q. What do you mean when you say, "so they
** 10
know what is occurring"?
A. If we have received a new software
package, what our schedule is for delivery of the
package. If we have received computers or printers
that need to be distributed, that they know the
status of that distribution.
Q. What software packages are utilized on the
PCs?
A. Word Perfect, Symphony, EM-220, Sideways,
and DOS are the standard packages.
Q. What is Word Perfect utilized for?
A. Word processing.
Q. And what is Symphony utilized for?
A. Spreadsheet analysis.
Q. What is EM-220 utilized for?
A. Terminal emulation.
Q. Can you elaborate on what that means?
A. To use a personal computer as a terminal.
Q. What is Sideways utilized for?
A. Sideways takes output and prints it
sideways.
Q. And what is DOS used for?
A. DOS is the operating system for the
personal computers.
Q. You indicated that you oversee the
** 11
networking. What is the process utilized by the
Water Management District to network between the
computers?
A. Could you be more specific than that?
Q. What is the -- how is the networking done
between the computers at the Water Management
District?
A. An Ungermann Bass Network is used.
Q. And is this network utilized to network
between all the computers at the Water Management
District or is there any restrictions?
A. Virtually all computers have access to the
network.
Q. Do you know whether there are any
computers outside the Water Management District
that have access to Water Management District
computers through this network?
A. There are computers outside the main
building that have access to the network.
Q. Do you know whether there are computers
owned by entities other than the Water Management
District that have access to Water Management
District computers through the network?
A. Yes, there are.
Q. What entities are those?
** 12
A. I believe DER has access, USGS has access,
and I believe the Army Corps of Engineers has
access.
Q. Do you know whether there are any limits
as to which computers DER has access?
A. Yes, there are.
Q. And what are those limits and
restrictions?
A. The limits are set by who needs access and
why they need access. So instead of it being a
limitation of, "you can have access to everything
except," it's more a limitation of, "you can only
have access to."
Q. Do you know to which computers DER has
access?
A. No, I don't.
Q. Do you know to which computers USGS has
access?
A. No, I don't.
Q. Do you know to which computers the Army
Corps of Engineers has access?
A. No.
Q. Do you know who would know?
A. It would probably be multiple people.
Q. These people in the computer management
** 13
division or elsewhere?
A. I would say it would be people -- well, it
would be some people in Computer Management and
elsewhere.
Q. Do you know who any of these people are
that might know?
A. Yes.
Q. And who are they?
A. I believe, Robb Startzman or Kevin
Rodberg.
Q. Anyone else?
A. The system managers for any systems they
have access to would create their passwords or
their user access.
Q. Is Robb Startzman a systems managers?
A. No, he isn't.
Q. Are there systems managers specifically to
whom you were referring to when you said, systems
managers would create the passwords?
A. There is a system manager for each system,
and depending on which systems the users ask for
access to, the appropriate system manager for that
system would create the user name for the system,
and the original password.
Q. Is there a systems managers for the Cyber?
** 14
A. Yes, there is.
Q. Who was that systems manager?
A. Steve MacNeil is the system manager.
Q. Is there a systems manager for the VAX
8810?
A. Yes, there is.
Q. And who is that systems manager?
A. The system manager is Connie Falls.
Q. Is there a systems manager for the VAX, is
it 6320? Is that the other one?
A. There is a VAX Model 6310.
Q. 6310, excuse me. Is there a system
manager for the 6310?
A. The system manager for the 6310 is Connie
Falls.
Q. Is there a systems manager for the DEC
system?
A. Could you be more specific?
Q. Is there a systems manager for any of the
DEC systems?
A. The VAX 8820 and the VAX 6310 are DEC
systems.
Q. There are other DEC systems in the Water
Management District, aren't there?
A. There are other DEC work stations. Those
** 15
--
Q. Are there -- go ahead.
A. I don't know the specific system managers
on each of those systems.
Q. Are there system managers for the SUN work
stations?
A. Again, I don't know the specific system
managers for the systems.
Q. Are there systems managers for the Xerox
work stations?
A. Each individual work station doesn't have
a system manager, but Connie Falls acts as the
central system manager.
Q. You indicated earlier that part of your
responsibilities were system support on the DEC?
A. That's correct.
Q. What does that entail?
A. When Connie Falls is unavailable as system
manager, I act as her back-up.
Q. Are back-ups done on the Water Management
District's computer systems?
A. Yes, they are.
Q. Is there a regular schedule on back-ups on
the mainframes?
A. Yes, there is.
** 16
Q. What is that schedule?
A. The schedule varies from system to system.
Q. What is the back-up schedule on the Cyber?
A. I don't specifically know the back-up
schedule for the Cyber.
Q. Do you know the back-up schedule on the
VAX 8810?
A. Not specifically.
Q. Do you know the retention period for the
back-ups that are done on the VAX 8810?
A. No.
Q. Do you know the back-up schedule for the
VAX 6310?
A. No, I do not.
Q. Do you know the retention period for the
back-ups?
A. No, I do not.
Q. Are there regular back-ups on the other
DEC work stations?
A. I'm not familiar with the system
management of those systems.
Q. Are there regular back-ups on the SUN work
stations?
A. I'm not familiar with the management
practices on those systems either.
** 17
Q. Are there regular back-ups on the Xerox
work stations?
A. Back-ups for the individual work stations
are at the discretion of the user.
Q. Are there regular back-ups on the Xerox
server?
A. Yes, there are.
Q. Do you know the schedule of those
back-ups?
A. No, I do not.
Q. Do you know the retention period for the
back-ups on the Xerox server?
A. No, I do not.
Q. Are there regular back-ups done on any of
the PCs?
A. There are regular back-ups on the PC
servers.
Q. Do you know the schedule of the back-ups
on the PC servers?
A. The PC servers in the B50 Building are
backed up weekly.
Q. Do you know the retention period for the
back-ups of the PC servers?
A. No, I do not.
Q. Do you know the format in which data is
** 18
stored on the PCs?
A. The format varies, depending on the
software package used.
Q. What would the format be for the Word
Perfect software package?
A. Typically, the format is a standard Word
Perfect document file.
Q. Do you know what the format would be for
the data in using the Symphony software package?
A. Typically, the data is stored in a
standard Symphony file with an extension WR. I
believe it's WR-1.
Q. Do you know the format of the data in the
M220 software?
A. Typically, data is not stored in the M220.
Q. The M220 is just used as a processor?
A. It's used as an emulation package.
Q. What is the format of the data in
Sideways?
A. I'm not sure.
Q. Are there indexes of the data files on the
PCs?
A. What do you mean by "indexes"?
Q. Is there a list in any form on the
computer or otherwise of the data files that are on
** 19
the various PCs?
A. I don't know of a list of data files on
PCs.
Q. Is there any sort of an inventory
of the data files on the PCs?
A. I don't know of any inventory of data
files on the PCs.
Q. Are there other sorts of inventories of
what's on the PCs?
A. We maintain a data base of the standard
software packages installed on each system.
Q. Does that data base have a name?
A. No, I guess it doesn't have a name.
Q. How would one go about finding out what
data files are stored on the computers?
A. To find out what data files are on every
computer?
Q. Yes.
MS. STOLLMAN: Are you referring to
the PCs now?
MS. NASH: No, all the computers.
MS. STOLLMAN: If it's different for
each computer, you can answer with respect to each
separate system.
A. On the PCs, the only thing I can think of
** 20
is to go to each system and do a directory of the
files there.
On the VAX you could also do a directory
in each users account.
What other systems did you want me to
answer for?
Q. (By Ms. Nash) Any of the other systems
that are in existence in the Water Management
District.
MS. STOLLMAN: You can answer if
there are other systems that you've worked with.
A. On the Xerox, I'm not sure exactly how
they would get a list of files on the system.
Q. (By Ms. Nash) On the Cyber?
A. On the Cyber, you could go to each of the
user accounts and get a list of files in the
account.
Q. Is there a list of user accounts for each
system?
A. There is a list of accounts for the VAX
8820, for the VAX 6310, and for the Cyber.
Q. Does the list of accounts for the VAX 8820
have a name?
A. I'm not sure of the name of the program
that maintains that list.
** 21
Q. Who would know the name of the program?
A. Connie Falls.
Q. Is there a list of the accounts on the VAX
6310?
A. That's the system I was answering about.
Q. I thought you were answering about the
8820?
A. It would be the same for both.
Q. You said there is a list of accounts for
the Cyber, does that list have a name?
A. I don't know the name if it exists.
MS. NASH: I have no further
questions.
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. My name is Joe Richards. I represent the
cities of Belle Glade and Clewiston.
You were just talking about an index to
accounts for the VAX system. Are you aware of
whether this index would indicate the subject
matter of the files?
A. I believe it would not.
Q. And when you were talking about the
** 22
outside access by DER, and USGS, the Corps of
Engineers, are you aware of any problems in
maintaining data base integrity by allowing that
outside access?
A. I know that that access causes an
additional system load for us in supporting
questions that they have accessing the system.
Q. Are you aware of the data ever being
changed by outside parties when accessing the
information?
A. I would not be aware of that information.
Q. Are you aware of whether this access is
granted in a read only format?
A. I don't have that information.
Q. Who would have that information?
A. I would first ask Connie Falls.
Q. Are you aware of whether it's possible to
grant outside access at night or on weekends?
A. Access that would be limited only to those
times?
Q. Is it possible to have access at those
times?
A. It's possible to have access to some
systems at that time.
Q. Do you know which systems?
** 23
A. It would depend on the back-up schedule on
the systems.
Q. If access was granted at night or on the
weekend, would you expect problems with the system
load?
A. That would depend on the number of users
having access.
Q. Do you know whether there is a limit on
the number of users?
MS. STOLLMAN: Are you asking for any
specific system or each system?
Q. (By Mr. Richards) Each system that you're
aware of.
A. Could you repeat the question?
MR. RICHARDS: Could you read it back
please?
(WHEREUPON, the requested testimony
was read back by the court reporter.)
A. Nothing is infinite, so there would be
some limits as to the number of users that could
have access to each system.
Q. (By Mr. Richards) Are you aware of that
number for, say, the Cyber system?
** 24
A. No, I'm not.
Q. Who would know that?
A. Steve MacNeil.
Q. And for the VAX system, would that be
Connie Falls?
A. Yes, it would.
Q. Are you aware of the accidental loss of
any data files?
A. Are you asking me if there have ever been
data files accidentally lost?
Q. Any that you're aware of?
A. I am sure I have known of some.
Q. Do you know of any particular data that
you can recall?
A. No.
Q. From any system, from the Cyber system?
A. I don't interface that directly with the
Cyber.
Q. What about the VAX?
A. Right offhand, I don't recall any data
that we have lost on the VAX and not been able to
recover.
Q. Are you aware of any data lost from the
Chemical Analysis Archive System?
MS. STOLLMAN: You can answer if you
** 25
work with that system or are familiar with that.
Answer if you know. I don't want you to speculate
about that.
A. Could you specify what you mean by
"chemical" -- I've forgotten what you called it.
Q. (By Mr. Richards) Chemical Analysis
Archive System.
A. Are you referring to the Perkin Elmer.
Q. Perkin Elmer, okay. Let's start with
that.
A. I don't know of any data lost on the
Perkin Elmer.
Q. Any lost from the Britton Lee?
A. I have heard of data lost on the Britton
Lee. I don't know what the recovery of it was.
Q. Do you know who would know that?
A. I don't know specifically who would know
the answer.
Q. Yet you're aware of a loss from the
Britton Lee, but you don't know whether it was
recovered or not; is that correct?
A. That's correct.
Q. Are you familiar with the DB Hydro data
base?
A. I have heard of the DB Hydro data base.
** 26
Q. Are you aware of any data lost from that
data base?
A. I don't specifically recall any instances
of data lost on the DB Hydro data base.
Q. You mentioned that you didn't have --
well, that your BS degree wasn't in any specific
area. What was your area of concentration?
A. My primary studies were biology.
Q. Did you have a minor concentration?
A. I studied a lot of computer science
classes at the time.
Q. Do you perform any analysis of data?
A. No.
Q. Have you in the past?
A. No.
MR. RICHARDS: All right. That's all
I have. Thank you.
(The deposition was concluded at 4:05
o'clock p.m.)
