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 KEVIN RODBERG, THE WITNESS, TAKEN ON BEHALF OF THE PLAINTIFFS - - - - - - - - DATE: August 10, 1990 PROFESSIONAL REPORTING SERVICE Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 2 1 I N D E X 2 3 August 10, 1990 DIRECT 4 5 KEVIN RODBERG 6 7 By Ms. Nash 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 3 1 The deposition of KEVIN RODBERG, the witness, in the 2 above-entitled and numbered cause, was taken before me, 3 DONNA McCALLEY, Registered Professional Reporter, and 4 Notary Public for the State of Florida at Large, at 5 Suite 303, 324 Datura Street, in the City of West Palm 6 Beach, County of Palm Beach, in the State of Florida, 7 beginning at the hour of 2:45 p.m., on Friday, the 10th 8 of August, 1990, pursuant to the Notice in said cause 9 for the taking of said deposition, which is annexed to 10 the court file herein, on behalf of the Plaintiffs in 11 the above-entitled action pending in the above-named 12 court. 13 The appearances at said time and place 14 were as follows: 15 UNITED STATES DEPARTMENT OF JUSTICE Room 868, 601 Pennsylvania Avenue, N.W. 16 Washington, D.C. 20044-0663 Attorneys for the Plaintiffs, U.S.A. 17 By BEVERLY SHERMAN NASH, ESQ. 18 PEEPLES, EARL & BLANK, P.A. Suite 3636, Two South Biscayne Boulevard 19 Miami, Florida 33131 Attorneys for the Cities of Belle Glade 20 and Clewiston By JOSEPH RICHARDS, ESQ. 21 SKADDEN, ARPS, SLATE, MEAGHER & FLOM 22 1440 New York Avenue, N.W. Washington, D.C. 20005-2107 23 Attorneys for the South Florida Water Management District 24 By DON JOAQUIN FROST, JR., ESQ. KATHARINE STOLLMAN, ESQ. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 4 1 APPEARANCES CONTINUED: 2 SOUTH FLORIDA WATER MANAGEMENT DISTRICT 3301 Gun Club Road 3 West Palm Beach, Florida 33416-4680 By JULIE JENNISON 4 ALSO PRESENT: John A. Davis, Ph.D. 5 Frank Draughn David Buker 6 Robert Johnson 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 5 1 THEREUPON: 2 KEVIN RODBERG, 3 having been first duly sworn, as hereinafter certified, 4 testified as follows: 5 DIRECT EXAMINATION 6 BY MS. NASH: 7 Q. Would you state your name. 8 A. Kevin Rodberg. 9 Q. Mr. Rodberg, I'm Beverly Nash, counsel for 10 the United States in the litigation against the water 11 management district. And what we're doing here today 12 is trying to get information to understand the water 13 management district's computer system, how it's 14 utilized, how it operates, how data on it is formatted, 15 and what the data is on it. 16 And you are here today as a representative 17 from the water management district having the most 18 knowledge concerning one of nine categories of 19 information that we've requested relating to the water 20 management district's computer system. Have you been 21 shown that list of categories? 22 A. Yes, I have. 23 Q. And are you aware of which of the 24 categories you are here to respond to? 25 A. I'm familiar with several of the items. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 6 1 Q. What is your present title or position at 2 the water management district? 3 A. Information systems analyst. 4 Q. With which division or department? 5 A. Environmental planning and the planning 6 department. 7 Q. And what is your job description? 8 A. Design and maintain data base systems that 9 are divisional, departmental and districtwide, as well 10 as support computer users and basic programming. 11 Q. And how long have you been in this role of 12 information systems analyst in the environmental 13 planning department or planning division? 14 A. Environmental planning department or 15 division just was reorganized seven, eight months ago. 16 Q. What division or department were you in 17 before? 18 A. Water quality in the planning--or resource 19 planning. 20 Q. Is your position with environmental 21 planning the same as it was with the water quality 22 division and resource planning? 23 A. Very similar. 24 Q. How did your job responsibilities differ 25 when you were with resource planning? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 7 1 A. I was more specifically involved with the 2 water quality data base system. 3 Q. And how long were you with resource 4 planning? 5 A. Since December of 1983. 6 Q. You describe your present job description 7 as designing and maintaining data base systems? 8 A. Yes. 9 Q. Okay, what data base systems do you design 10 and maintain? 11 A. Currently? 12 Q. Yes. 13 A. I'm working on the contract information 14 system, the plan management system, the manpower 15 tracking system, and currently maintaining the chemical 16 analysis archive system. 17 Q. What is the chemical analysis archive 18 system? 19 A. Stores water quality data. 20 Q. From where is that water quality data 21 attained? 22 A. It's transferred from the laboratory 23 information management system, as well as some data 24 from external laboratories. 25 Q. And in what computer is this chemical PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 8 1 analysis archive system maintained? 2 A. The Britten Lee. 3 Q. And what format is this water quality data 4 on the Britten Lee? 5 A. I'm not quite sure I understand what you 6 mean. 7 Q. If--we'll get back to that. 8 What is your educational background? 9 MR. FROST: Object to the question. You 10 looking for professional, educational 11 background or--I mean where do you want him to 12 begin? 13 MS. NASH: He can answer the question. 14 MR. FROST: Go ahead. Understand where 15 you're beginning? 16 A. High school graduate. I went to Iowa 17 State University for approximately three semesters. I 18 do not have a college degree. I have various 19 educational experiences around the country from 20 technical education symposiums and conferences, et 21 cetera. 22 BY MS. NASH: 23 Q. Do you have any formal training in 24 information systems analysis? 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 9 1 Q. And where did you get that training? 2 A. From these conferences and seminars. 3 Q. And do you have any formal training in 4 water quality data analysis? 5 A. No. 6 Q. Who are your supervisor--or who is your 7 supervisor in environmental planning? 8 A. I have three supervisors. 9 Q. Who are they? 10 A. Paul Waylin, Tony Federico and Steve 11 Reels, who is on staff in the department of planning. 12 Q. Do you have other supervisors-- 13 A. (Shakes head.) 14 Q. --that are outside of that? 15 A. No. 16 Q. Do you have any employees that work for 17 you? 18 A. No. 19 Q. Which of the computers at the water 20 management district do you presently use? 21 MR. FROST: Object to the question. Are 22 you talking about mainframes, micros? 23 MS. NASH: Whatever ones he uses. 24 A. Let me think just a second. 25 MR. FROST: Take your time. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 10 1 A. (continuing) Associated personal 2 computers, terminals, several of the VAX's, occasional 3 use of DEC work stations, Sun work stations, the 4 Britten Lee, the Cyber, the Perkin Elmer. 5 I think that's it. 6 BY MS. NASH: 7 Q. Were these the same computers you used 8 when you were part of resource planning? 9 A. When I was with resource planning, I did 10 not do any work with the UNIX environment. 11 Q. What work do you do on the--using the 12 Cyber? 13 A. I maintain some trend analysis systems and 14 some statistical--what do you want to call them, 15 program--Fortran programs. 16 Q. What is the nature of the trend analysis 17 data that you maintain on the Cyber? 18 A. I'm not familiar with the exact nature of 19 the program. I didn't write it. I maintain it only. 20 Q. What kind of data is involved in this 21 trend analysis? 22 A. Some water quality data. 23 Q. And could you be more specific about what 24 the water quality data is? 25 A. It's typically data that comes from the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 11 1 CAS system, chemical analysis system, the archives 2 system. We call it CAS frequently. 3 Q. What is the statistical data on the Cyber 4 that you maintain? 5 A. I don't maintain any data on the Cyber. 6 Q. You testified that you--I'm sorry, that 7 you used the Cyber for doing statistical analysis; is 8 that what you-- 9 A. I maintain programs that do statistical 10 analysis. 11 Q. Which programs that do statistical 12 analysis that you maintain on the Cyber? 13 A. There is a library TREND LIB, 14 T-R-E-N-D-L-I-B. 15 Q. What use do you make of the Perkin Elmer? 16 A. I transfer data from the Perkin Elmer to 17 the personal computer to transfer to the CAS system. 18 Q. What is the nature of the data that you 19 transfer from the Perkin Elmer? 20 A. I don't understand what you mean. 21 MR. FROST: Can you please rephrase the 22 question? 23 MS. NASH: Yes. 24 BY MS. NASH: 25 Q. What is the makeup of the data that you PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 12 1 transfer from the Perkin Elmer? 2 A. It's water quality analysis data. 3 Q. And where does that water quality analysis 4 data originate? 5 A. In the laboratories, as far as I know. 6 Q. Do you make other use of the Perkin Elmer 7 computer? 8 A. No. 9 Q. What use do you make of the Sun work 10 stations? 11 A. Currently setting up system administration 12 procedures for other users within our department. 13 Q. Did you use the Sun work station when you 14 were in resource planning? 15 A. I think I mentioned that I didn't. 16 Q. Okay. 17 What use do you make of the DEC work 18 stations? 19 A. The same as the Sun. 20 Q. Did you use those work stations when you 21 were in resource planning-- 22 A. No. 23 Q. --the DEC work stations? 24 A. I--I know what I said before. It was the 25 UNIX work stations. I consider both of them UNIX work PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 13 1 stations. 2 Q. What work do you do on the VAX's? 3 A. The VAX is used as a trying system to the 4 Britten Lee to run reporting programs and some analysis 5 of the data. 6 Q. Do you run these reporting programs? 7 A. I run them sometimes. 8 Q. What are these reporting programs that you 9 run? 10 A. It's part of the CAS system. 11 Q. What other work do you do on the VAX 12 computers? 13 A. Some Oracle programming and data base 14 design. 15 Q. What is the nature of the data base design 16 you do on the VAX's? 17 A. To develop contract information system, 18 plan management system, and manpower tracking system. 19 Q. Did you use the VAX computers when you 20 were in resource planning? 21 A. Yes. 22 Q. And what work did you do on the VAX system 23 then? 24 A. The same, except I was not working with 25 the manpower or the contract information system. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 14 1 Q. How do you make the decision on which of 2 the computers you'll use for the various job 3 responsibilities you have? 4 MR. FROST: Object. That's calling for a 5 narrative answer. You want to ask how he 6 chooses to do work on a particular one, I 7 wouldn't object. 8 MS. NASH: If he can answer it, let him. 9 A. I--it is fairly broad. 10 BY MS. NASH: 11 Q. Well, all right. 12 When you're doing data-base design, how do 13 you decide which computer you're going to use? 14 A. Some of it is decided by policy as to 15 which computer system can be used. If it requires the 16 data base to be compatible with other Oracle data base 17 systems, it needs to be designed and set up on one of 18 the VAX's. We have a production system and we have a 19 development system which are both separate VAX's. One 20 is used for development work, one is used for 21 production systems. 22 Q. Which VAX is used for production systems? 23 A. It's called either WMD6 or VAX 6. 24 Q. And which VAX system is used for 25 developmental? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 15 1 A. The one that's considered developmental is 2 called VAX 1 on WMD1. 3 Q. Which software packages do you use in your 4 work on the VAX system? 5 A. Let me think. 6 The various Oracle products for data base 7 work, Fortran, C, and Free Form. 8 Q. Did you use different software when you 9 were in resource planning? 10 A. Yes. 11 Q. What software did you use then? 12 A. On the VAX's? 13 Q. Did you use the VAX's then? 14 A. Yes. 15 Q. What software did you use on the VAX's? 16 A. I used primarily Free Form. I did do some 17 development work with Oracle, but it was very limited. 18 Q. What software did you use on the Cyber 19 when you were in resource planning? 20 A. IMSL--I'm trying to think of the names of 21 some of these. It's been some time since I've used 22 some of them. 23 SPSS, various software packages that came 24 from the USGS, DMS 170, some programs that were 25 developed in-house for various processing of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 16 1 information. I used them for piper trilinear, paper 2 trilinear diagrams. 3 That's all I can recall right now. 4 Q. Let's back up a moment. 5 The VAX 6 that you referenceed before, 6 where is that machine located? 7 A. In the central computer room. 8 Q. And the VAX 1 or WMD1? 9 A. Same place. 10 Q. You were describing the software that you 11 used when you were in resource planning, including some 12 in-house programs? What were those in-house programs 13 that you used? 14 A. Let's see. There's something called EVO9. 15 Q. And what is its function? 16 A. I can't remember. I just remember the 17 letters. 18 Let's see, there's U002, which is a backup 19 program. 20 There's a couple of models that were used 21 for groundwater work. One was Big Mack and Pinder. 22 Q. Is that--would you speak up, please? 23 A. Big Mack, Pinder, McDonald. I think Big 24 Mack and McDonald were similar. And I don't think they 25 were developed in-house, either. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 17 1 Q. What was the function of Big Mack? 2 A. McDonald model is a--and Big Mack are 3 groundwater modeling programs. I am not familiar with 4 the field of groundwater. 5 Q. I'm not clear now. Did you say these were 6 developed in-house or developed elsewhere? 7 A. They were modified in-house. They were 8 developed outside, I'm quite sure. 9 Q. Do you know who developed them? 10 A. I think a couple of people named McDonald 11 and Pinder. 12 Q. Do you know who in the water management 13 district would be most familiar with these programs? 14 A. Someone in the field of hydrology--or 15 hydrogeology, I mean. 16 Q. Do you know anyone specifically by name? 17 MR. FROST: Well, I object to that being 18 vague. Do you mean you know anybody 19 specifically by name that does anything with 20 these programs or someone in hydrology? 21 BY MS. NASH: 22 Q. Who's familiar with these programs. 23 A. Scott Burns might know. He may know of 24 someone who is, if he doesn't. 25 Q. Did you, when you worked in resource PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 18 1 planning, transfer data files from one computer to 2 another? 3 A. Yes. 4 Q. What system did you use to do that 5 transfer? 6 A. When transferring what data from where 7 to--to-- 8 MR. FROST: Could counsel be more specific 9 on what system she's referring to? 10 BY MS. NASH: 11 Q. Why don't we start with from what system 12 to what system did you transfer data files while in 13 resource planning? 14 A. I transferred data from the Cyber to P--to 15 the PC's. Transferred data from the LIMS system to the 16 PC's. 17 I transferred data from the Cyber to the 18 Perkin Elmer; from the Perkin Elmer to the Cyber; from 19 the PC's to the Cyber; from the LIMS to the PC's to the 20 Cyber; from the LIMS to the PC's to the Britten Lee; 21 from PC's to the PC servers; from the PC's to the PC 22 servers to the Xerox; from the PC's to the Xerox; from 23 the Xerox to the PC's. 24 I don't know if I made all the 25 combinations. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 19 1 Q. What system did you use in transferring 2 data files from the Cyber to the PC's? 3 A. The PC. 4 Q. Excuse me? 5 A. A personal computer. 6 Q. I'm repeating what you said. You said you 7 transferred data files from the Cyber to PC's. 8 A. That's right. 9 Q. I'm asking you-- 10 A. Which system I used. 11 The PC to transfer the data from the Cyber 12 to the PC's. 13 Q. Yes. 14 A. Exactly. 15 Q. Excuse me? 16 MR. FROST: Go ahead. 17 THE WITNESS: I'm sorry? 18 MR. FROST: Go ahead. 19 A. The personal computer is acting as a 20 terminal to the host, the host being the Cyber. 21 When I wanted to transfer data from the 22 Cyber to the PC, I connected to the Cyber, transferred 23 data down to the PC's, capturing it using the software 24 package called Cross Talk. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 20 1 BY MS. NASH: 2 Q. And when you were transferring data from 3 LIMS to the PC, what procedure did you use? 4 A. I would connect from the PC to the LIMS 5 using the software package called Cross Talk, captured 6 the data into aske files on a hard disk. 7 Q. And when you were transferring data from 8 the Cyber to the Perkin Elmer, what procedure did you 9 use? 10 A. There's a software package that was either 11 made available to us by CY--CDC or Perkin Elmer or a 12 third party vendor, I'm not sure. I think it's called 13 Hasp. 14 Q. And when transferring data from the PC's 15 to the Cyber, what procedure did you use? 16 A. I would connect to the Cyber from the PC 17 and transfer data to the Cyber using a software package 18 running on the Cyber called XEdit. 19 Q. When you were transferring data files from 20 LIMS to the PC's to the Cyber, what procedure did you 21 use? 22 A. Combination of the two priors. 23 Q. When you transferred data files from the 24 LIMS to the PC's to the Britten Lee, what procedure did 25 you use? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 21 1 A. I would trans--I would capture data. If I 2 was capturing it from the LIMS, then I would use a 3 software package called IDMF Copy to transfer it to the 4 Britten Lee. 5 Q. When you were transferring data from the 6 PC's to the PC servers, what procedure did you use? 7 A. I would use Ungermann Bass software that's 8 available on most of the PC's at the district that are 9 connected to the Ungermann Bass network and merely copy 10 them. 11 Q. When you were transferring data files from 12 the PC to the PC servers to the Xerox, what procedure 13 did you use? 14 A. I would use two different procedures. 15 Occasionally I would copy them to a floppy disk and 16 manually walk them to the machine and install them, 17 convert them using the software package called Loader 18 on the Viewpoint software. 19 When I would transfer them electronically, 20 I would transfer them to something called the exchange 21 drawer, which would convert them--if I'm not mistaken, 22 the software package runs on a VAX, transfers it 23 electronically to the Xerox exchange drawer. My 24 secretary or myself then would copy the file onto the 25 local Xerox work station and run it through the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 22 1 converter. 2 Q. When you transferred data files from the 3 PC's to the Xerox, what procedure did you use? 4 A. I'm sorry, I thought that's what the last 5 question was. 6 Q. The last, I believe, was PC's to the PC 7 server to the Xerox. 8 A. Oh, the PC server to the Xerox? I didn't 9 know I made that connection. 10 It would be the same. 11 MR. FROST: Did you ever make that 12 connection? 13 THE WITNESS: Yeah, I think I have. 14 BY MS. NASH: 15 Q. When you transferred data files from the 16 Xerox to the PC's, what procedure did you use? 17 A. I would convert Viewpoint documents to 18 aske documents on the Xerox work station and copy them 19 to a dos-prompted floppy and manually walk it to a 20 personal computer and install it. 21 Q. When you were in resource planning, did 22 you also transfer text files between or amongst the 23 various computers? 24 A. Most of these files were considered text. 25 Text is an aske. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 23 1 Q. Did you ever transfer raw data files? 2 A. Okay. Could you describe "text," "raw 3 data," and what was the previous qualification of 4 files? 5 Q. Asked you data files and text files. 6 A. Okay. Can you describe the difference 7 between data files, text files, and what data files? 8 MR. FROST: Raw data. 9 BY MS. NASH: 10 Q. As I--you don't understand what the term-- 11 A. I don't understand your terminology. 12 Q. Do you have a definition for "raw data 13 files"? 14 A. "Raw data files" are information I 15 consider unmodified from the original source. 16 Q. Did you ever transfer data from raw data 17 files? 18 MR. FROST: You mean raw data from raw 19 data files? 20 MS. NASH: Yes. 21 A. Raw data files to where, around any 22 system? 23 BY MS. NASH: 24 Q. Around any system. 25 A. Yes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 24 1 Q. Are the procedures different than the 2 procedures you've described to this point? 3 A. No. 4 Q. Do you understand what the term "text 5 file" means? 6 A. As far as I'm concerned, it is any kind of 7 text. I don't differentiate between data files, raw 8 data files, and text files. I consider all of them 9 aske files. 10 Q. Are the procedures used for transferring 11 all of those amongst the computers the same? 12 A. The same. 13 Q. What documentation or manuals do you refer 14 to to assist you in doing your work? 15 MR. FROST: I object. Are you speaking of 16 computer work or all work? 17 MS. NASH: Computer work. 18 A. It depends on the job that I'm working on. 19 For transferring data files, I don't refer to any 20 documentation. 21 BY MS. NASH: 22 Q. Do you refer to--let me retract that. 23 When you have a question when working on 24 one of the computers, where do you go to get your 25 question answered? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 25 1 MR. FROST: I object as far as "when." 2 You mean a question about transferring or 3 a question about data? How do you-- 4 MS. NASH: Just question in general. He's 5 working on the computer, he's got a question. 6 A. Which computer? I don't know. It really 7 depends on which computer. 8 BY MS. NASH: 9 Q. When you are working on the Cyber. 10 A. On the Cyber, I frequently contact various 11 personnel in technical services for assistance. 12 Q. When you are working on the LIMS, to whom 13 do you go if you have questions? 14 A. Tom Raishe. 15 Q. Sorry? 16 A. Tom Raishe. 17 Q. When you're working on the Britten Lee, to 18 whom do you go if you have questions? 19 A. No one. 20 Q. Is there a manual or other reference to 21 which you can go on the Britten Lee? 22 A. Yes. I have several manuals in my office, 23 as well as technical services--no, a hotline type of 24 number. 25 Q. When you're working on the Xerox, to whom PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 26 1 do you go if you have questions? 2 MR. FROST: Object. "To whom do you go 3 to," someone in the district or someone outside 4 the district? 5 BY MS. NASH: 6 Q. In the district initially. 7 A. Joel VanArnam, Connie Falls, Laura 8 McLester, our secretarial assistant. 9 Q. When you are working on the PC's, who 10 within the district do you go to if you have a 11 question? 12 A. Hardware or software? 13 Q. Hardware. 14 A. I contact the text services computer 15 hotline. 16 Q. If you have questions on the software when 17 you're working on the PC's, to whom do you go? 18 A. Depends on the software package. There 19 are several experts throughout the district that are 20 well versed in various software packages. 21 Q. Can you tell me who those experts are? 22 A. I don't--which software package? I work 23 with an awful lot of different software packages. I 24 don't know-- 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 27 1 BY MS. NASH: 2 Q. To the extent that you can name an expert 3 and which software package they're expert on, do so. 4 A. Okay. 5 Symphony, I think Bob Hain is considered 6 very knowledgeable. 7 Data flex would be Tom Raishe. SAS, Dave 8 Soballe. AUTOCADD--who do we have for AUTOCADD? Some 9 of the different CADD technicians at work. Depends on 10 how detailed the question. 11 Q. Who would those CADD technicians be? 12 A. Some work in the planning department, some 13 work in geographic sciences, some work in the water 14 quality, division of--what's it called now? DRE, 15 department of research evaluation. 16 You want them listed? 17 Q. Yes. 18 A. Let's see, Dera Muzyk, Joan Stockham, Lynn 19 Gullick. I suppose they are the most knowledgeable 20 that I've asked. 21 There are some software packages that I 22 don't always go to people for that I use, which would 23 include--I'm trying to think which ones I have loaded 24 on my system. Harvard Graphics, Stat Graphics, I think 25 those are the primary software packages I use. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 28 1 Q. You mentioned the LIMS before. Can you 2 explain what that is? 3 MR. FROST: Object to the breadth of that 4 question by explaining what that is. You want 5 him to describe the system? Do you want him to 6 explain what his work is? 7 BY MS. NASH: 8 Q. First describe the system. 9 A. The system as I know it is a laboratory 10 information management system. I'm not an expert in 11 laboratory information management systems, but to the 12 best of my knowledge, it is a system which organizes 13 tracks and compiles data from laboratory analysis. 14 Q. Did you make use of the LIMS system when 15 you were in resource planning? 16 A. Yes. 17 Q. And what use did you make of it? 18 A. Transferring data to the PC's to transfer 19 to the chemical analysis archives system. 20 Q. And what type of data was in the LIMS 21 system? 22 A. Water quality analysis data. 23 Q. What did you have to do to access that 24 data? 25 A. From my personal computer, I would run the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 29 1 software package called Cross Talk, connect to the 2 Perkin Elmer, log into my account, and execute a menu 3 option that would generate a report of the particular 4 water quality data that I wished to transfer to the CAS 5 system via the PC. 6 The report would be generated. I would 7 display the information across the screen, capturing it 8 using a utility in Cross Talk to an aske file on the 9 PC, which would then be transferred using an IDMF copy 10 to the Britten Lee. 11 Q. What would you do with the data once it 12 was in the Britten Lee? 13 A. Transfer it into the chemical analysis 14 archives system. 15 Q. For what purpose? 16 A. Archival. 17 Q. Did you ever do any statistical analysis 18 of the data when you were in resource planning? 19 A. Yes. 20 Q. What was the nature of the statistical 21 analysis that you did on that data? 22 A. I'm not a statistics major. I'm not aware 23 of all the function of the statistics that I was 24 running. 25 Q. You would-- PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 30 1 A. I-- 2 Q. How would you know to run statistical 3 analyses if-- 4 A. My supervisors or other professionals 5 within my division would provide me with types of 6 equations and formulas that they would like to have 7 performed using a specific data set. I would then 8 develop a program that would accomplish that task or 9 request that they'd provide the program to me, and I 10 would develop additional programs to facilitate quicker 11 or more extensive testing of the data. 12 Q. And once you would run the statistical 13 analysis you described, would they be stored somewhere? 14 A. Typically they'd be stored on a personal 15 computer or the Cyber. 16 Q. Do you know whether there's a list of the 17 statistical analyses that you'd run on the water 18 quality data? 19 A. Many of the analyses that were run are 20 purged after a certain period of time due to 21 limitations in space that I have in my account from one 22 run to the next. I may have some of the last analysis 23 work that I had done. It's not very consistent as to 24 which run was which, and I would not be aware of 25 exactly which groupings of files were ran together. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 31 1 Q. Did you keep hard copies of the 2 statistical analyses that you ran? 3 A. No. 4 Q. Do you know whether anyone in the water 5 management district kept hard copies of the statistical 6 analyses you ran on the water quality data? 7 A. No. 8 Q. Do you know who, if anyone, would know 9 whether hard copies were maintained? 10 MR. FROST: I tend to object to this line 11 of questioning. I think we're getting into now 12 what documents are available and what data is 13 available, and we're moving away from what's on 14 the computers and the description of the 15 systems, their computers. I think that's beyond 16 the scope of this limited deposition. 17 MS. NASH: Well, I'm not gonna debate that 18 with you. He has indicated that the statistical 19 analysis may have been purged, and I doubt 20 whether there's still versions of that, and this 21 is related to the use that's being made of the 22 computers, so he can answer the question if he 23 knows. 24 MR. FROST: Go ahead. 25 A. I don't keep track of various employees' PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 32 1 personal habits as far as storing their working 2 products. 3 BY MS. NASH: 4 Q. When you were in resource planning, did 5 you do any graphics analysis of the water quality data 6 base? 7 A. I don't understand the term "graphic 8 analysis." 9 Q. Did you do any analysis using graphics? 10 A. I prepared plots of data, yes. 11 Q. What was the nature of the data in which 12 you prepared plots? 13 MR. FROST: Again, this is limited to 14 computers, as opposed to sitting down at a table 15 with a piece of paper. 16 MS. NASH: Yes. 17 A. Some of the data was data or information 18 or results from trend analysis, and some of the data 19 was the results or output from smoothing and trend 20 analysis routines run on the Cyber, transferred to 21 Symphony to display times series plots of various water 22 quality data. Some plots could be described as mapping 23 products. Some plots were the results of contouring 24 packages associated with ground water ambient 25 monitoring. And some simple bar charts and things for PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 33 1 administrative use only. 2 Q. And then in which of the computers would 3 you run these graphs that you've been describing? 4 A. On the past couple years, personal 5 computers only. 6 Q. Are these graphs you've been describing 7 maintained anywhere? 8 A. I wouldn't be aware of it. 9 Q. Did you keep any hard copies of the graphs 10 that you ran on water quality data? 11 A. If I did, they would be in the files that 12 were already reviewed by the document discovery. 13 Q. You indicated in doing these graphics that 14 you utilized data from trend analyses you did? 15 A. Yes. 16 Q. Can you describe the trend analyses that 17 you did? 18 A. I--I'm not a statistician. I only run the 19 programs that were developed by other people. 20 Q. How would you go about knowing that you 21 should do a trend analysis? 22 A. Would be requested by another 23 professor--professional within my division or my 24 supervisor. 25 Q. And what would you do to run a trend PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 34 1 analysis? 2 A. I would transfer the data from the 3 chemical analysis archive system to the PC to the 4 Cyber. I would then manipulate the data to put it into 5 a format that would be compatible with the various 6 formats that the trend analysis routines were required 7 to run. 8 I would execute the programs, generating 9 output files, transfer the output files to the personal 10 computers, transfer them into Symphony, format the data 11 again to facilitate plotting various graphs, and then 12 plot the data. 13 Q. What are the formats that the trend 14 analyses are required to be in? 15 A. Various aske formats that are read by 16 Fortran programs. 17 MR. FROST: Do you want to take a break at 18 this point? 19 MS. NASH: Sure. 20 (Short break.) 21 BY MS. NASH: 22 Q. Mr. Rodberg, you mentioned raw data 23 earlier. Did you ever do any preprocessing with that 24 data before you ran any of your statistical analyses or 25 graphic programs on-- PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 35 1 MR. FROST: For clarification, this is the 2 raw data as Mr. Rodberg defines it. 3 MS. NASH: As Mr. Rodberg defined it. 4 MR. FROST: Okay. 5 A. The only preprocessing of data I would 6 perform before doing any trend analysis would be 7 prescribed by some other professional or statistician. 8 BY MS. NASH: 9 Q. And what would that professional or 10 statistician tell you to do? 11 MR. FROST: Objection for hearsay, but 12 I'll let the witness answer. 13 A. It depends on the type of analysis they're 14 doing. Occasionally they would request that duplicates 15 be handled in some fashion. What do they call the 16 data--provisional data be handled in some fashion. 17 Data may be converted from daily to monthly averages, 18 specific data points may be used in conjunction with 19 two files. Particularly if we were doing flow-weighted 20 averages, you would take in specific a water quality 21 data set, a flow data set, and match data points 22 according to some procedure that they would describe. 23 Q. You used the term "provisional data." Can 24 you describe what that is? 25 A. I don't have a clear definition of PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 36 1 provisional data. It's something that's described in 2 the data base called DB Hydro. 3 Q. And you mentioned working with specific 4 data points. Were you ever given instructions to 5 exclude specific data points from being too high or too 6 low? 7 A. I--I don't know for sure. 8 Q. When you said you--you testified earlier 9 that a professional statistician would give you 10 equations to work with, who were those professionals or 11 statisticians that you mentioned? 12 MR. FROST: Can we just refer to refresh 13 the witness' memory what equations we're talking 14 about? 15 MS. NASH: He didn't des-- 16 A. I think I know what she's talking about. 17 Specifically these people would be John 18 Shaw, George Shih, Kim Odell, Jeff Hare, Jim Grimshaw, 19 Nagendra Khanal, Tony Federico, Mike Cullem, Dave 20 Soballe, Dave Swift, Lorraine Janus, Tracy Slater. I 21 don't recall for sure, Paul Waylin may have. Pete 22 Rhoads, Allen Hall, Fred Davis. 23 That's, I think, about all I can remember 24 right now. 25 Q. When you ran your statistical analyses on PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 37 1 the water quality data, to whom did you give those 2 analyses? 3 A. The same people who requested the analysis 4 to be ran. 5 Q. Are there any-- 6 A. And occasionally some of this information 7 would be sent to external agencies. 8 Q. To which external agencies do you refer? 9 A. In particular, I think Everglades National 10 Park was included, someone associated with the dairy, 11 the USGS on occasion. I can't--I can't recall for 12 certain, someone from the sugarcane league had 13 requested something one time, I think. The Army Corps 14 of Engineers, the DER, BQECB, DERM, Game and Fish. 15 I think that's about it. 16 Q. Would that list be any different for the 17 graphics or plotting analyses that you did? 18 MR. FROST: Before we go further into 19 obtaining the identities of people who are 20 requesting certain types of information to be 21 generated and to run and to where that's going, 22 I would like counsel to identify which one of 23 these requests covers questions concerning to 24 whom or whose request is asking for such 25 analyses and where such analyses is going. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 38 1 MS. NASH: It's covered generally in the 2 request of where the computer information came 3 from and where it goes. 4 MR. FROST: Could counsel be more 5 specific? Are we talking location of computer 6 files or types of information? But I don't see 7 anything asking for the identities of people 8 asking for statistical analyses. 9 MS. NASH: Well, that would certainly be 10 the location of the analyses. It would 11 certainly come right in under number 6. 12 BY MS. NASH: 13 Q. Mr. Rodberg, how was the--the data 14 transferred? Who would you send these analyses to, 15 first of all, those that requested it within the water 16 management district? 17 MR. FROST: Could we once again be a 18 little more specific on now what type of 19 analyses we are talking about? There have been 20 various types of analyses floating around. Are 21 we talking about statistical analyses? 22 BY MS. NASH: 23 Q. I can break it down. Start with the 24 statistical analyses first. 25 A. They would be transferred electronically PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 39 1 over the network to PC servers to VAX, to the Cyber, to 2 the Xeroxs, or on floppy disks, occasionally on 3 magnetic tape. 4 Q. And how would the statistical analyses be 5 given to the non water management district entities 6 that you mentioned? 7 A. It would be in the format that was 8 requested by them. 9 Q. And what might that be? 10 MR. FROST: Only answer this if you know. 11 A. Hard copy occasionally, floppy disks, and 12 sometimes magnetic tape. 13 BY MS. NASH: 14 Q. And how would the trend analyses that you 15 ran be transferred to those within the water management 16 district? 17 A. Most of the time it would be in hard copy 18 printout. Occasionally the data would be provided on 19 the Cyber or on floppy disks or through the PC servers. 20 Q. And how would the trend analyses be 21 transferred to those entities outside the water 22 management district? 23 MR. FROST: Object. I don't believe we've 24 established that he knows that they've been 25 transferred. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 40 1 A. I don't know that they've been 2 transferred, the actual analysis. 3 BY MS. NASH: 4 Q. Do you know whether any of the graphics 5 analyses that you did on the water quality data were 6 transferred to outside entities outside the water 7 management district? 8 A. I don't know specifically, no. 9 Q. And do you know whether any of the trend 10 analyses that you did on the water quality data was 11 transferred to entities outside the water management 12 district? 13 A. The actual trend analysis data. The trend 14 analysis data may have been transferred outside the 15 district. I'm not--I'm not sure if the data actually 16 went out. 17 Q. How was the graphics analyses transferred 18 to those within the water management district? 19 A. Hard copy. 20 Q. Do you know whether any records or lists 21 were made of who would receive various analyses that 22 you did? 23 A. I didn't make any lists. 24 Q. Do you know whether any were made? 25 A. No. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 41 1 Q. You testified earlier to performing 2 smoothing routines. Can you describe what a smoothing 3 routine is? 4 A. Smoothing routine is a program that came 5 from the USGS that I adapted to run on the Cyber. The 6 actual methodology behind how it works and what it 7 actually does I'm not aware of as to whether it's valid 8 or not. 9 Q. For what purpose did you run the smoothing 10 routines? 11 A. To provide graphic output. 12 Q. Did you do any other analyses on water 13 quality data other than what you've described here so 14 far? 15 MR. FROST: I object for ambiguous. Do 16 you mean on the computer? 17 MS. NASH: On the computer. 18 A. Could you review what specific analysis 19 I've described? 20 BY MS. NASH: 21 Q. You've mentioned statistical analyses, 22 trend analyses, and graphics analyses. 23 A. None that I'm aware of. I don't know for 24 sure what other types of analysis there is. 25 Q. Did you do any analyses on surface water PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 42 1 data? 2 A. Yes. What type of surface water? 3 Q. My next question is what is the surface 4 water data that you analyzed? 5 MR. FROST: This, again, is on the 6 computer. 7 MS. NASH: On the computer. 8 A. Water quality data associated with surface 9 water, discharge and flow, stage. I think that covers 10 it. 11 BY MS. NASH: 12 Q. Where is the discharge and flow data 13 located? 14 A. DB Hydro. 15 Q. And what nature of analyses did you do on 16 the discharge and flow data on the computer? 17 A. "Analysis" specifically means that I've 18 analyzed the data. I merely manipulate data or perform 19 analysis for someone else. 20 Q. Well, what forms of analysis did you 21 perform for others on the discharge and flow data? 22 A. May calculate means, mins, max, standard 23 deviations, volumes. 24 Q. I'm sorry, what was that? 25 A. Volumes. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 43 1 Q. And what procedure would you use to 2 perform the means analysis that you mentioned? 3 A. I would typically use Symphony pack or 4 Fortran routine that I would write and calculate a 5 simple mean. 6 Q. And what procedure would you use to do 7 maximum standard analyses that you mentioned? 8 A. Again, either Fortran or using Symphony 9 or--I would like to include SAS, I guess. 10 Q. And what procedure would you use to do 11 deviations analysis on the discharge and flow data? 12 MR. FROST: Again, on the computer. 13 MS. NASH: On the computer. 14 A. Using SAS and Fortran routines. 15 BY MS. NASH: 16 Q. And what procedure would you use to do 17 volumes analysis on the discharge and flow data on the 18 computer? 19 A. Fortran routines and Symphony routines and 20 SAS routines. 21 Q. And in what format would this data be, 22 this discharge and flow data? 23 A. "Format" as in how it was stored? 24 MR. FROST: Can counsel clarify what you 25 mean by "format"? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 44 1 BY MS. NASH: 2 Q. If--do you understand the term "format"? 3 A. I understand about a couple of them-- 4 Q. What is your-- 5 A. --terms for "format." 6 Q. What is your understanding of the term 7 "format"? 8 A. "Format" is how data is laid out. 9 "Format" is how data is stored, or as a verb, how you 10 want it stored. 11 I'm not sure, do you want a hard-column 12 image? I can't say specifically those. If you want 13 aske or binary or relational data is typically stored 14 in a DMS 170 for stage and discharge, which is a data 15 base package. When I would analyze the data, I would 16 convert it to an aske output file. 17 Q. In what form did the analyses take that 18 you performed on the discharge and flow data? 19 A. Aske. 20 Q. And how would you transfer the results of 21 your analyses to whoever was requesting the analysis? 22 A. Occasionally they would want just the 23 number. I could tell them verbally. Occasionally they 24 would like a printout. Sometimes they would want it 25 stored on the Cyber where they would have access to it. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 45 1 Sometimes they would like it transferred to personal 2 computer on a floppy disk, transferred to the Xerox, 3 transferred to the PC servers for their access. 4 Q. Is there any list of the analyses you did 5 on the discharge and flow data while you were in 6 resource planning? 7 A. Not that I'm aware of. 8 Q. You mentioned doing analyses on stage 9 data; is that correct? 10 A. I have used stage data in some analysis, 11 yes. 12 Q. And what is the nature of the analyses 13 you've done on the stage data? 14 MR. FROST: Just to clarify, you didn't 15 actually do the analysis. You manipulate the 16 data that someone else has requested. 17 THE WITNESS: That's correct. 18 MR. FROST: Okay. 19 Could you read back the question, please? 20 (Thereupon, the question was read by the 21 Reporter as recorded above.) 22 A. I'm not sure exactly how the stage data is 23 used. In some cases, they would merely like it merged 24 with other data files in a format that they would 25 describe. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 46 1 BY MS. NASH: 2 Q. Who would request that you do analyses on 3 stage data? 4 A. Again, it would be similar to George Shih, 5 other professionals and my supervisors. 6 Q. And who would you--who requests that you 7 do analyses on the discharge and flow data? 8 A. Other professionals within my division or 9 department, my supervisors. 10 Q. Do you recall any specific individuals 11 that requested that you do analyses on discharge and 12 flow data when you were in resource planning? 13 A. Yes. 14 Q. Who were those individuals? 15 A. George Shih, Dave Soballe, Jim Grimshaw, 16 Tony Federico, Lorraine Janus, Eric Flake. 17 That's all I can think of right now. 18 Q. Did you do any work when you were in 19 resource planning with any data on pesticides? 20 MR. FROST: I object. Ambiguous by "any 21 work." 22 MS. NASH: With the understanding that 23 he's working on the computer. 24 MR. FROST: Okay, I'll let him answer 25 that. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 47 1 A. I stored it. 2 BY MS. NASH: 3 Q. What is the nature of the data on 4 pesticides that you stored in the computer when you 5 were in resource planning? 6 A. The data received from an external lab, 7 which I can't remember the name of, stored on my 8 computer by the request of Richard Fieve. 9 Q. Richard-- 10 A. Fieve. 11 Q. And where did you store this data on 12 pesticides that you're referencing? 13 A. On my hard disk. 14 Q. Were you asked to do any analyses on the 15 computer on data on pesticides? 16 A. No. 17 Q. You did nothing other than store pesticide 18 data. 19 A. I-- 20 MR. FROST: That's been asked and 21 answered. 22 A. I did do one other thing. I backed it up 23 onto floppies, and it's since no longer on my hard 24 disk. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 48 1 BY MS. NASH: 2 Q. Do you know whether the data on pesticides 3 to which you are referring still exists on any of the 4 computers in the water management district? 5 A. I couldn't be for sure. 6 Q. When you were in resource planning, did 7 you do any work on the computer on the nutrient content 8 of soil or water? 9 A. I'm sorry, I couldn't hear. 10 MR. FROST: I object to the scope of that 11 question. It's beyond the scope of this limited 12 deposition on whether or not he did work 13 concerning nutrient content. I would permit 14 questions on whether or not he did work 15 concerning nutrients. 16 BY MS. NASH: 17 Q. I asked the question whether you've done 18 any work on nutrients on the computer while you were in 19 resource planning. 20 A. I've done work with water quality data 21 that represents nutrient data. 22 Q. What is the nature of the work that you 23 did on the water quality data representing nutrients? 24 A. Archival, reporting, trend analysis, some 25 statistical analysis, some graphic. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 49 1 Q. Where, on which computer was the water 2 quality data relating to nutrients located? 3 A. Nutrient data would originally be analyzed 4 and stored on the Perkin Elmer LIMS system and then be 5 transferred to the personal computers, to the chemical 6 analysis archive system for storage in the Britten Lee 7 CAS system. Data can be then transferred to the VAX or 8 the PC's, or from the PC's to the Cyber for analysis. 9 Q. And what--for whom did you do reports on 10 nutrient data? 11 A. Environmental sciences division, water 12 quality division, environmental planning division, 13 hydrogeology division, ground water division, and 14 different titles for different divisions at different 15 times, of course. 16 Q. Is there any record that you're aware of 17 of the reports that you did for the environmental 18 sciences division on nutrients? 19 A. No. 20 Q. Was there any record that you're aware of 21 for the reports that you did on nutrients for the water 22 quality division? 23 A. No. 24 Q. Are there any reports or any records that 25 you're aware of on the reports that you did for the PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 50 1 geology division? 2 A. I'm sorry, could you say-- 3 Q. I believe you mentioned geology. 4 A. Hydrogeology. 5 Q. Hydrogeology. 6 A. I'm not sure if I understood your 7 question. You said am I-- 8 MR. FROST: Can you repeat your question? 9 MS. NASH: Read back the question. 10 (Thereupon, the question was read by the 11 Reporter as recorded above.) 12 A. There are some reports still available 13 that are available for the hydrogeology division. Any 14 records, I would not be aware of. 15 BY MS. NASH: 16 Q. Do you--the reports that you mentioned 17 that are still available have a name or names? 18 A. I have standardized reports that are 19 available to everybody to use. I could list some of 20 the names of the programs. The actual output files I 21 would not know. The users decide on that themselves. 22 Q. What are the names of the programs that 23 you can recall? 24 A. The reports that generate what type of 25 data? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 51 1 Q. You were referencing reports that you did 2 on the nutrient data. 3 A. CAAS NUT.SCR, CAAS-- 4 THE REPORTER: Repeat that. 5 A. (continuing) C-A-A-S, CAAS NUT 1, CAAS 6 NUT 2, CAAS NUT 3 with extensions SCR.RPT. 7 There would also be some reports available 8 in Data Flex for ground water data with nutrients, and 9 I cannot recall the names of those reports. 10 BY MS. NASH: 11 Q. Do you know where someone would go at the 12 present time if they wished to request the reports on 13 Data Flex and ground water data? 14 A. Yes. 15 Q. Where would they go? 16 A. The water quality division in department 17 of research and evaluation. 18 Q. Do you know who in the water quality 19 division would be able to provide those reports? 20 A. Jeff Hare. 21 Q. Sorry, Jeff-- 22 A. Hare. 23 MR. FROST: Let me make it clear for 24 118 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 52 1 2 3 4 5 6 1 be Dewey Worth, the person with the 7 most knowledge as 8 9 2 to what's contained on that 10 computer? 11 12 3 A. I believe so, 8 13 person makes the question hard to answer. 14 15 9 MR. FROST: Okay. 16 17 10 BY MR. RICHARDS: 18 19 11 Q. Is there any other 20 individuals that would 21 22 12 hh-e-y, 23 24 17 though I may not have the spelling 25 correct. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 53 1 2 18 Q. Is there anyone else? 3 4 19 A. No. 5 6 20 Q. Okay, and for the 7 Robert Mann Micro VAX, 8 9 David Sweet. 10 11 12 13 14 15 16 17 PROFESSIONAL REPORTING SERVICE, 18 INC., (407) 659-4046 19 20 119 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 54 1 2 1 Q. And there's also some 3 Mod there any way to distinguish between 4 5 7 the two; is there different names? 6 7 8 MR. FROST: Could you 8 clarify your 9 10 9 question? I believe you have 11 two there. 12 13 10 15 A. I do 14 understand the question. 15 16 16 Yes, the district has a 17 name for each of 18 19 17 the two systems. 20 21 18 BY MR. RICHARDS: 22 23 19 Q. What aral with the most 24 knowledge as to the data 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 55 1 24 contained on that computer? 2 3 25 A. Rudy Vynanek. 4 5 6 7 8 9 10 11 PROFESSIONAL REPORTING SERVICE, 12 INC., (407) 659-4046 13 4 space 14 allocations for the different computers, 15 16 5 mainframes and mini computers? 17 18 6 A. Could you be more 19 specific about the word 20 21 7 "list"? 22 23 8 Q MR. FROST: Do 24 you need the question to be 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 56 1 13 clarified? 2 3 14 THE WITNESS: I'm gonna 4 try to restate 5 6 15 what I think the question is, 7 if that's proper 8 9 Q. You also indicated that you did 10 statistical analyses on the nutrient data on the 11 computer; is that correct? 12 A. Yes. 13 Q. And for whom would you have done 14 statistical analyses on the nutrient data? 15 A. Tom Raishe, Tony Federico, George Shih, 16 Dave Soballe. I would like--I think it would probably 17 be easier to say the water quality division as a whole, 18 and occasional requests from other divisions, 19 specifically environmental sciences and hydrogeology. 20 Q. Where--what programs did you use to run 21 the trend analyses--I'm sorry, the statistical analyses 22 on the nutrient data? 23 A. Some Fortran routines, SAS routines, 24 Symphony, and SQL on the Britten Lee. 25 Q. And where would the output of those PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 57 1 statistical analyses be located? 2 A. The Britten Lee, the Cyber, various 3 personal computers, the VAX and the Cyber. 4 Q. If someone else from the--what was--the 5 resource planning division wanted to access your 6 statistical analyses on the nutrient data, how would 7 they go about doing that? 8 MR. FROST: I object to that question, 9 speculative. If you want to rephrase it so 10 you're just asking how does one obtain the 11 data... 12 MS. NASH: If he can answer the 13 question... 14 MR. FROST: Go ahead. 15 A. The data that would be stored on the 16 Britten Lee, I would have to give specific permission 17 for people to access. Data stored on the Cyber, I 18 could make public, again, by giving them specific 19 permissions making the file public. 20 On the PC's, I would transfer it to a PC 21 server, and they would automatically have access to it. 22 On the VAX, I would typically transfer it to a PC ts of 23 data. I'm not going into any more 24 25 6 than that. I just want to PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 58 1 ask him if he's aware 2 3 7 of this program. 4 5 8 MR. FROST: Could you 6 define "program," 7 8 9 3 BY MR. RICHARDS: 9 10 14 Q. I'm asking him if he's 11 aware of this 12 13 15 monitoring program. 14 15 16 A. I am not aware of a 16 district policy, what 17 18 17 I would call a prand 19 20 21 in reference to the word "pump 21 station" or "field 22 23 22 station," would automatically imply 24 operations and 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 59 1 23 maintenance department, in which 2 case very possibly 3 4 24 Rudy Vynane 5 1 BY MR. RICHARDS: 6 7 2 Q. I believe a little 8 while ago you mentioned 9 10 3 monitoring of water quality and 11 quantity at pump 12 13 4 stations; is that correct? 14 15 5 that could be 16 17 9 classified as quantity or quality. 18 19 10 Q. That data you just 20 referred to, where is 21 22 11 that stored? 23 24 12 MR. FROST: Could you 25 be more specific?ifferent PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 60 1 2 17 sensors. 3 4 18 A. Right. Data being 5 collected, and not 6 7 19 trying to distinguish quality from 8 quantity, is stored 9 10 20 in the short-term, referencing under 11 Q. Who would be the individual at the 12 13 14 15 16 17 18 19 PROFESSIONAL REPORTING SERVICE, 20 INC., (407) 659-4046 21 22 128 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 61 1 2 3 4 1 d single individual that's most 5 knowledgeable in that 6 7 6 data that is stored in a permanent 8 archive. I would 9 10 7 reference Rob Startzman as being the 11 individual that 12 13 8 would have the most general knou-- 14 15 13 A. Have I answered your 16 question? 17 18 14 Q. Yes. 19 20 15 Could you list those 21 other individuals? 22 23 16 A. The other individuals 24 that previous (Whereupon, the deposition 25 was adjourned PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 62 1 at 4:34 p.m. to be resumed on August 23, 1990.) 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 63 1 E R R A T A S H E E T 2 PURSUANT TO RULES OF CIVIL PROCEDURE, this deposition is being submitted to you for examination, 3 reading and signing. Please do not write on the transcript. Any change in form or substance you desire 4 to make should be entered upon this sheet as follows: 5 PAGE NO., LINE NO._________CHANGE_____________REASON___ 6 7 8 9 10 11 12 13 Date:__________________ 14 ADDRESS:_____________________ 15 _____________________ 16 COUNTY OF:___________________ 17 18 _________________________ 19 Signature of Witness 20 _________________________ Notary Public, State of 21 Florida at Large. My Commission Expires: 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 64 1 I, KEVIN RODBERG, do hereby certify that I 2 have read the foregoing transcript of my deposition 3 given on August 10, 1990; that together with the 4 correction page attached hereto noting changes in form 5 or substance, if any, it is true and correct. 6 7 8 ____________________________ 9 KEVIN RODBERG 10 11 12 I do hereby certify that the deposition of 13 KEVIN RODBERG was submitted to the deponent for reading 14 and signing; that after deponent had stated to the 15 undersigned Notary Public that deponent had read and 16 examined said deposition, deponent signed the same in 17 the presence of the undersigned authority on 18 the day of , 1990. 19 20 21 ______t's T-u-r-c-o-t-t, but 22 not positive. 23 24 21 Q. What divisions do these 25 individuals work PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 65 1 2 22 in, starting with Rob Startzman? 3 4 23 A. Data management 5 division. 6 7 24 129 8 9 10 11 12 13 14 1 Q. Marilyn Herrington 15 (sic)? 16 17 2 A. Data management 18 division. 19 20 3 Q. Paul Ryan? 21 22 4 A. I'm not positive of the 23 division --data management division. 24 25 9 Q. You described a PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 66 1 permanent archiving of 2 3 10 this data in the Cyber 830; is that 4 correct? 5 6 11 A. That is correct. 7 8 12 Q. es, performs some 9 quality analysis on the data to 10 11 17 ensure as high as a reliability and 12 accuracy as 13 14 18 possible, converts it to one-sided 15 break-point data or 16 17 19 calculated data, and stores it on 18 maga also stored permanently in some sort of archive 19 20 24 system? 21 22 25 A. I believe you're really 23 asking two 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 67 1 2 3 4 5 6 PROFESSIONAL REPORTING SERVICE, 7 INC., (407) 659-4046 8 tem? 9 10 4 MR. FROST: I believe 11 that's still two 12 13 5 questions. 14 15 6 MR. RICHARDS: I 16 believe that's only one 17 18 7 question. 19 20 8 ent archive system? 21 22 13 A. Because of the word 23 "raw telemetry data," 24 25 14 I would have to say no. But I think PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 68 1 if your definition 2 3 15 and my definition of "raw" are 4 different, I might be 5 6 20 MR. RICHARDS: He just 7 referred to "raw 8 9 21 data" and answered the 10 question. I'd like to 11 12 22 know how he defined it, 13 defined "raw," in that 14 15 23 answer. 16 17 131 18 19 20 21 22 23 24 1 "raw," so then he could say. 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 69 1 2 BY MR. RICHARDS: 2 3 3 Q. Do you have a 4 definition of the word 5 6 4 u have any questions about the 7 procedure you are to follow, please call my office. 8 9 Sincerely, 10 11 12 13 Donna McCalley 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046