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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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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
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PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
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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
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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
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PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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--
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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.
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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'
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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
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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
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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--
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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
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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
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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.
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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
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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.
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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.
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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
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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.
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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"?
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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.
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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.
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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.
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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
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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.
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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
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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?
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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
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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.
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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
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21
22
23
24
25
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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
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1 24 contained on that computer?
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3 25 A. Rudy Vynanek.
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11 PROFESSIONAL REPORTING SERVICE,
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4 space
14 allocations for the different computers,
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16 5 mainframes and mini computers?
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18 6 A. Could you be more
19 specific about the word
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21 7 "list"?
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23 8 Q MR. FROST: Do
24 you need the question to be
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1 13 clarified?
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3 14 THE WITNESS: I'm gonna
4 try to restate
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6 15 what I think the question is,
7 if that's proper
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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
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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
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1 ask him if he's aware
2
3 7 of this program.
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5 8 MR. FROST: Could you
6 define "program,"
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8 9 3 BY MR. RICHARDS:
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10 14 Q. I'm asking him if he's
11 aware of this
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13 15 monitoring program.
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15 16 A. I am not aware of a
16 district policy, what
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18 17 I would call a prand
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20 21 in reference to the word "pump
21 station" or "field
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23 22 station," would automatically imply
24 operations and
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1 23 maintenance department, in which
2 case very possibly
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4 24 Rudy Vynane
5 1 BY MR. RICHARDS:
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7 2 Q. I believe a little
8 while ago you mentioned
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10 3 monitoring of water quality and
11 quantity at pump
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13 4 stations; is that correct?
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15 5 that could be
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17 9 classified as quantity or quality.
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19 10 Q. That data you just
20 referred to, where is
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22 11 that stored?
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24 12 MR. FROST: Could you
25 be more specific?ifferent
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2 17 sensors.
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4 18 A. Right. Data being
5 collected, and not
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7 19 trying to distinguish quality from
8 quantity, is stored
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10 20 in the short-term, referencing under
11 Q. Who would be the individual at the
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4 1 d single individual that's most
5 knowledgeable in that
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7 6 data that is stored in a permanent
8 archive. I would
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10 7 reference Rob Startzman as being the
11 individual that
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13 8 would have the most general knou--
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15 13 A. Have I answered your
16 question?
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18 14 Q. Yes.
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20 15 Could you list those
21 other individuals?
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23 16 A. The other individuals
24 that previous (Whereupon, the deposition
25 was adjourned
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1 at 4:34 p.m. to be resumed on August 23, 1990.)
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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___
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Date:__________________
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ADDRESS:_____________________
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_____________________
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COUNTY OF:___________________
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_________________________
19 Signature of Witness
20 _________________________
Notary Public, State of
21 Florida at Large. My
Commission Expires:
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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
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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
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2 22 in, starting with Rob Startzman?
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4 23 A. Data management
5 division.
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7 24 129
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14 1 Q. Marilyn Herrington
15 (sic)?
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17 2 A. Data management
18 division.
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20 3 Q. Paul Ryan?
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22 4 A. I'm not positive of the
23 division --data management division.
24
25 9 Q. You described a
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1 permanent archiving of
2
3 10 this data in the Cyber 830; is that
4 correct?
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6 11 A. That is correct.
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8 12 Q. es, performs some
9 quality analysis on the data to
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11 17 ensure as high as a reliability and
12 accuracy as
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14 18 possible, converts it to one-sided
15 break-point data or
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17 19 calculated data, and stores it on
18 maga also stored permanently in some sort of archive
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20 24 system?
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22 25 A. I believe you're really
23 asking two
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tem?
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10 4 MR. FROST: I believe
11 that's still two
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13 5 questions.
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15 6 MR. RICHARDS: I
16 believe that's only one
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18 7 question.
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20 8 ent archive system?
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22 13 A. Because of the word
23 "raw telemetry data,"
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25 14 I would have to say no. But I think
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1 if your definition
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3 15 and my definition of "raw" are
4 different, I might be
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6 20 MR. RICHARDS: He just
7 referred to "raw
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9 21 data" and answered the
10 question. I'd like to
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12 22 know how he defined it,
13 defined "raw," in that
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15 23 answer.
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24 1 "raw," so then he could say.
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1 2 BY MR. RICHARDS:
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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,
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13 Donna McCalley
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