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 DAVID SWEET,
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
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1 I N D E X
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3 August 10, 1990 DIRECT CROSS
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5 DAVID SWEET
6
7 By Ms. Nash 5
8 By Mr. Richards 28
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1 The deposition of DAVID SWEET, 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 1:13 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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1 THEREUPON:
2 DAVID SWEET,
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. David Sweet.
9 Q. Mr. Sweet, I am Beverly Nash. I'm the
10 counsel for the United States in this litigation
11 against the water management district. And we're here
12 because the United States wants to understand how the
13 water management district's computer systems function
14 and how they commun--how people communicate internally
15 using computers, the kind of data that's stored and how
16 that data is formatted. And you are here today as a
17 representative of the water management district having
18 knowledge concerning one of nine categories of inquiry
19 relating to the water management district's computer
20 systems.
21 Have you been shown that list of
22 categories?
23 A. Yes.
24 Q. And can you identify which categories you
25 are here to respond to?
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1 A. Yes.
2 Q. Which subject matters?
3 A. One through six.
4 Q. One through six, okay.
5 What is your present title or position?
6 A. Systems analyst.
7 Q. In what division or department?
8 A. Computer management.
9 Q. And what is your job description?
10 A. I maintain the Oracle data bases on the
11 platforms on which they exist.
12 Q. Can you elaborate on that?
13 MR. FROST: Objection, vague. Elaborate
14 on which one.
15 BY MS. NASH:
16 Q. On his definition of maintaining Oracle
17 data bases on the platforms on which they exist.
18 A. I'm responsible for keeping the versions
19 of the software up to date, that there is sufficient
20 space in the data base for data as it comes in, and
21 also to aid users in securing accounts on our systems.
22 Q. Any other job responsibilities?
23 A. I also maintain the network as backup to
24 someone else.
25 Q. To whom are you backup to in maintaining
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1 the network?
2 A. Lavinia Ricketts.
3 q. Can you spell that last name?
4 A. R-i-c-k-e-t-t-s.
5 Q. Any other responsibilities?
6 A. No.
7 Q. And how long have you been in this role of
8 systems analyst?
9 A. Two and a half years.
10 Q. Have you had prior positions at the water
11 management district?
12 A. No.
13 Q. What is your educational backgrounds?
14 A. I have a Bachelor's of Science in physics.
15 Q. From where?
16 A. Texas A&M University.
17 Q. Do you have any educational training in
18 computers or systems analysis?
19 A. From Oracle Corporation.
20 Q. Any formal training, college or--
21 A. No.
22 Q. Who are your supervisors?
23 A. Constance Falls is my immediate
24 supervisor. Above her is Lavinia Ricketts, then Bill
25 Hall.
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1 Q. Are there others in computer management
2 that have the same job description and responsibilities
3 as you have?
4 A. No.
5 Q. Which of the computers at the water
6 management district do you personally use?
7 A. I use a IBM PS2 Model 80 work station, the
8 VAX 8820, the VAX 6310, a DEC 3200 work station.
9 That's it.
10 Q. What work do you do on the IBM PS2 Model
11 80?
12 A. I use it primarily to communicate with the
13 digital machines.
14 Q. To which digital machines are you
15 referring?
16 A. The DEC 8820, the 6310, and 3200.
17 Q. And what work do you do on the VAX 8820?
18 A. Maintenance of Oracle.
19 Q. What is entailed in maintenance of Oracle?
20 A. Ensuring that the software is up to
21 current release levels, ensuring that there is
22 sufficient space in the table spaces for data as it
23 comes in, granting users access to the system, and
24 monitoring data base performance.
25 Q. By "monitoring data base performance,"
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1 what do you mean?
2 A. I monitor the amount of fragmentation in
3 the table spaces, the process statistics for the data
4 base processes, and amount of space available.
5 Q. What do you do with the statistics you
6 process? Do you do some sort of hard copy report?
7 A. We're working toward that. I review the
8 statistics for problems, and if there are none, I don't
9 act on it.
10 Q. Do you do any other work on the VAX 8820?
11 A. Yes.
12 Q. What else?
13 A. I do occasional support for users in the
14 VMS operating system on that machine.
15 Q. And what does that support entail?
16 A. Granting users more disk space in their
17 VMS accounts as appropriate.
18 Q. Any other support for users in the VMS
19 operating system?
20 A. On the 6310.
21 Q. Any other support on the 8820?
22 A. Occasional general questions.
23 Q. Occasional--I'm sorry?
24 A. Occasional general questions.
25 Q. General, I'm sorry.
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1 What work do you do on the VAX 6310?
2 A. There's an Oracle data base there I
3 maintain. I maintain the Wallengong TC PIP software.
4 I maintain the PC gateway printer symbiont and the
5 Versatech plot server print server symbiont.
6 Q. I'm sorry, would you repeat the last--
7 A. Versatech plot server print symbiont, and
8 some programming.
9 Q. What kind of programming do you do on the
10 VAX 6310?
11 A. C programming.
12 Q. For what purpose?
13 A. For use by our division or to provide
14 services for users on the network.
15 Q. What sort of services for users on the
16 network?
17 A. Print services. That's the PC gateway.
18 Q. What other work do you do on the VAX 6310?
19 A. The general questions, answering, and
20 providing disk space when appropriate for users.
21 Q. You also mentioned that you work on the
22 DEC 3200 work station; is that correct?
23 A. Yes.
24 Q. And what work do you do on the DEC?
25 A. I maintain the print symbiont software on
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1 that machine and the Oracle case designer software.
2 Q. Is that Oracle case designer software
3 different than the Oracle software you described as
4 maintaining on the VAX 8820 and the 6310?
5 A. Yes.
6 Q. In what way is it different?
7 A. It is a graphical graphic space design
8 tool for Oracle relational data bases.
9 Q. Do you assist in transferring data files
10 or text files between systems?
11 A. Yes.
12 Q. What do you do?
13 A. I assist an occasional user in
14 transferring data files from VAX account to VAX
15 account, from VAX account to PC, and PC to VAX. Also,
16 I assist users in transferring data from user to user
17 and Oracle, and from system to system.
18 Q. Are you knowledgeable in the--in what's in
19 the data or you just--that you're assisting in the
20 transfer?
21 A. No.
22 MR. FROST: Object to the question. It's
23 confusing and compound. Can you rephrase it?
24 MS. NASH: It's already been answered.
25
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1 BY MS. NASH:
2 Q. Are you familiar with which of the water
3 management district computer systems can be accessed by
4 outside users?
5 A. Yes.
6 Q. Which ones are those?
7 A. The VAX 8820, VAX 6310, the CDC 180, the
8 IBM mainframe, the Perkin Elmer. That's all I'm aware
9 of.
10 Q. By what means would an outside user access
11 the VAX 8820?
12 MR. FROST: Object to being ambiguous.
13 What do you mean by "outside user"? You mean
14 district users or non-district users?
15 MS. NASH: Non-district user.
16 MR. FROST: You need the question read
17 back to you?
18 THE WITNESS: Please.
19 MR. FROST: Read the question back.
20 (Thereupon, the question was read by the
21 Reporter as recorded above.)
22 A. They would call in to a call-back utility,
23 provide the proper access code and password, specify
24 where they want the call-back to call, and then it
25 would call back.
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1 BY MS. NASH:
2 Q. Are you aware of otherside users that
3 access the VAX 8820?
4 A. Yes.
5 Q. And who are those outside users?
6 A. Oracle Corporation, Constance Falls, and
7 myself.
8 Q. Are you aware of any non water management
9 district entities other than Oracle Corporation that
10 access the VAX 8820?
11 A. No.
12 Q. Are you aware of any non water management
13 district entities that access the VAX 6310?
14 A. No.
15 Q. Are you aware of any non water management
16 district entities that access the CDC 180?
17 A. Yes.
18 Q. And who are they?
19 A. The Everglades, someone there, the United
20 States Corps of Engineers, and the United States
21 Geologic Survey.
22 Q. Is the access to the CDC 180 as you
23 described for the access to the VAX 8820?
24 A. Yes.
25 (Short break.)
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1 BY MS. NASH:
2 Q. What documentation exists to--or what
3 documentation exists to assist users on the computer
4 systems that you're aware of?
5 MR. FROST: Could you clarify "computer
6 systems"?
7 BY MS. NASH:
8 Q. Any one of the computer systems, the
9 mainframes, the minis, or the micros.
10 Start there. Is there documentation that
11 exists to assist users on the various computer systems
12 at the South Florida Water Management District?
13 A. Yes.
14 Q. And what is that documentation?
15 A. Vendors-supplied users manuals and systems
16 manuals, software-specific manuals provided by the
17 software vendors, and some in-house produced
18 documentation.
19 Q. Can you describe the in-house produced
20 documentation?
21 MR. FROST: Again, can counsel clarify
22 what you mean by "describe"? Do you want them
23 to be listed, do you want them to be--
24 MS. NASH: Well, list what there is first
25 and...
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1 MR. FROST: Okay.
2 Can you list them?
3 A. I can't list them all.
4 BY MS. NASH:
5 Q. Do the best of your ability.
6 A. There is documentation detailing how a
7 user can connect over the network using our software
8 packages to the various systems. There's documentation
9 detailing how users can print on the various printers
10 through these packages. There's documentation
11 detailing how one would use the call-back feature to
12 gain access to the network.
13 There is documentation describing how
14 users--or rather, developers, should develop their
15 applications; that is, the structured designed.
16 Q. Any other in-house documentation that you
17 can think of?
18 A. Not that I can think of.
19 Q. Does the documentation on how a user can
20 connect over the network have a name?
21 A. Yes.
22 Q. And what is that name?
23 A. The DEC talk utility.
24 Q. Does the documentation on how users can
25 print through the various software packages have a
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1 name?
2 A. I don't know.
3 Q. Does the documentation on how one uses the
4 call-back feature have a name?
5 A. I must have been confused. That's the DEC
6 talk utility.
7 Q. Does the first system--first documentation
8 you mentioned how the user can connect over the network
9 have a name?
10 A. Not that I'm aware of. Sorry.
11 Q. And does the documentation on how users or
12 developers should develop applications have a name?
13 A. I don't remember it exactly.
14 Q. Who would have knowledge of what the name
15 of that documentation is?
16 A. Trevor Campbell.
17 Q. And who is Mr. Campbell?
18 MR. FROST: He by--do you mean by his
19 position or--
20 MS. NASH: Yes.
21 A. He is the data base administrator.
22 BY MS. NASH:
23 Q. Would Trevor Campbell also know if the
24 other documentation you've described has a name?
25 MR. FROST: Object. Calling for him to
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1 speculate.
2 BY MS. NASH:
3 Q. If he knows.
4 If you know, go ahead.
5 A. I don't know.
6 Q. Is there anyone else that would know
7 whether the other in-house produced documentation has a
8 name?
9 A. Yes.
10 Q. And who would that be?
11 A. Betsy Hacker.
12 Q. What was the last name?
13 A. Hacker.
14 Q. And what is Betsy Hacker's position?
15 A. I can't exact--recall the exact title.
16 Q. What department or division does she work
17 in?
18 A. Computer management.
19 Q. Are you aware of water management district
20 users using non-approved or non-supported software on
21 any of the computer systems?
22 MR. FROST: Object. Ambiguous as to what
23 you mean by "non-supported."
24 MS. NASH: If he can understand the
25 question.
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1 THE WITNESS: Please repeat it.
2 BY MS. NASH:
3 Q. Let me break it down.
4 Are there software packages that are
5 recommended and supported by the computer management
6 division for users on the water management district
7 computer systems?
8 A. Yes.
9 Q. Are you aware of users on the water
10 management district's computer system that use
11 non-recommended or non-supported software?
12 A. No.
13 Q. Is there a list, to your knowledge, of the
14 supported or recommended software?
15 A. Not that I know of.
16 Q. Is there a procedure that users on the
17 water manage--water management district computer system
18 use for transferring text files between computers?
19 A. Yes.
20 Q. What is that procedure?
21 A. It depends on which computer systems that
22 the files are being transferred between.
23 Q. If you were to transfer data between the
24 Cyber and one of the mini computers, what would that
25 procedure be?
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1 MR. FROST: Object. We haven't
2 established with this witness that that's
3 possible.
4 BY MS. NASH:
5 Q. Well, I'll ask him the question.
6 Is it possible to transfer X files from
7 the Cyber to one of the mini computers?
8 A. Yes.
9 Q. And what would the procedure be to do that
10 transfer?
11 A. To use the file transfer protocol and
12 program.
13 Q. Are there mini computers in the water
14 management district's computer system from which you
15 cannot transfer files from Cyber?
16 A. Yes.
17 Q. Which ones are those?
18 A. The IBM mainframe.
19 Q. Are there--strike that.
20 Can you transfer files from the mini
21 computers to Cyber?
22 A. Yes.
23 Q. And what is the procedure that is used to
24 do that transfer?
25 A. The file transfer protocol.
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1 Q. Is the file transfer protocol program the
2 same for a transfer either from the mainframe to the
3 mini computers or vice versa?
4 A. Yes.
5 Q. Can you also transfer programs from the
6 mini computers to micro computers or PC's--I'm sorry,
7 transfer text files?
8 A. Could you repeat that?
9 Q. Yes.
10 Can you transfer text files from the mini
11 computers to the micro computers or PC's?
12 A. From some mini computers to some PC's.
13 Q. From which mini computers can you transfer
14 text files?
15 A. From--
16 MR. FROST: To PC's, is that--
17 MS. NASH: To PC's.
18 MR. FROST: Okay.
19 A. From UNIX or Ultrix-based mini computers,
20 files can be transferred to PC's utilizing Sun's NFS
21 suite of programs.
22 From VMS-based machines, files can be
23 transferred to the PC using Interconnection's I*
24 product, and the PC's running a BASS NET 1X and S
25 software.
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1 Q. Which of the mini computers that have the
2 UNIX, or which of the mini computers have UNIX or
3 Ultrix based?
4 A. All Suns and all DEC stations and VAX
5 stations.
6 Q. And VAX stations?
7 A. (Witness nods.)
8 Q. And which mini computers are VMS-based
9 machines?
10 A. The VAX 6310 and the VAX 8820.
11 Q. Is there a procedure from--for being able
12 to transfer text files from the VAX 6310 to a UNIX
13 based--
14 A. I made a slight error.
15 On the VAX 6310--
16 Q. Yes.
17 A. --it has both, FTP and I*.
18 Q. Then from the VAX 6310, you can transfer
19 to either the UNIX or the VMS-based machines?
20 A. That's correct.
21 Q. Are there guidelines for the users on
22 which of the computers to use?
23 A. Yes, generally.
24 Q. What are those guidelines?
25 A. Production Oracle data base systems are
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1 recommended to reside on the VAX 8820. Development of
2 Oracle systems should be done on the VAX 6310. Word
3 processing should be done on Xerox work stations or
4 PC's.
5 That's what I know.
6 Q. Are there guidelines or procedures for
7 backing up files on the PC's or other micro computers?
8 A. On PC's that is recommended that users
9 back up their files and store data files in particular
10 areas. On the minis--well, in the computer room, the
11 VAX 6310 and 8820, there are established backup
12 procedures for those machines. And the Cyber 180 and
13 IBM mainframe also have procedures of a similar nature.
14 Q. Is your testimony then that for the PC's,
15 it is up to the individual users to perform backup?
16 A. For the individual's work station, yes.
17 Q. Computer management does not oversee that
18 the PC's are backed up?
19 A. There are PC file servers, which are
20 backed up by computer management.
21 Q. And how often are the PC file servers
22 backed up?
23 A. I don't know.
24 Q. Who would know how often the PC file
25 servers are back up?
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1 MR. FROST: Answer that one if you know.
2 A. I don't know.
3 MR. FROST: Can we take a short break?
4 MS. NASH: Sure.
5 (Short break.)
6 BY MS. NASH:
7 Q. Mr. Sweet, are you familiar with which
8 computers handle the water management district's
9 digital image processing system?
10 A. No.
11 Q. Are you familiar with which computers
12 handle the--what's called the geographical information
13 system?
14 A. No.
15 Q. Are you familiar with which computers are
16 utilized for computer-aided drafting and design
17 systems?
18 A. No.
19 Q. Are you familiar with a system called
20 ARC/INFO?
21 A. No.
22 Q. Are you familiar with a system called
23 ERDAS?
24 A. No.
25 Q. Are you familiar with a system called I2S?
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1 A. No.
2 Q. Are you familiar with which of the water
3 management district's computers are used for
4 statistical data gathering or analyses?
5 A. No.
6 Q. Are you familiar with which of the water
7 management district's computers are utilized for
8 graphics?
9 A. No.
10 Q. Are you familiar with which of the water
11 management district's computers are used for modeling?
12 A. No.
13 Q. Are you familiar with which of the water
14 management district's computers are utilized for remote
15 sensing data?
16 A. No.
17 Q. Are you familiar with which of the water
18 management district's computers are utilized for
19 vegetative mapping?
20 A. No.
21 Q. Are you familiar with which of the water
22 management district computers are utilized by the
23 environmental sciences division?
24 A. No.
25 Q. Are you familiar with which computers are
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1 utilized by the regulation department?
2 A. Yes.
3 Q. And which ones are those?
4 A. The VAX 8820.
5 Q. Do you know which of the software packages
6 the regulation department utilizes?
7 A. Oracle.
8 Q. What data bases in Oracle does the
9 regulation department utilize?
10 MR. FROST: Do you understand the
11 question?
12 THE WITNESS: No.
13 MR. FROST: Can counsel please rephrase
14 it?
15 MS. NASH: Strike that.
16 BY MS. NASH:
17 Q. Are you familiar with which of the
18 computers the water supply planning division utilizes?
19 A. No.
20 Q. Are you familiar with which of the
21 computers the water quality division utilizes?
22 A. No.
23 Q. Are you familiar with which of the
24 computers the planning department utilizes?
25 A. No.
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1 Q. Are you familiar with which of the
2 computers the water resources division utilizes?
3 A. No.
4 Q. Are you familiar with which of the
5 computers the research and evaluation department
6 utilizes?
7 A. No.
8 Q. Are you familiar with which of the
9 computers the geographic sciences division utilizes?
10 A. No.
11 Q. Are you aware of who would be familiar
12 with which computers the various divisions utilize?
13 MR. FROST: Object. It's a
14 narrative--question asking for a narrative
15 answer, can be broken up.
16 MS. NASH: The question is, is he
17 familiar with who is aware of. It's a yes or
18 no.
19 MR. FROST: That might be familiar
20 with--he might be familiar with some but not
21 others.
22 BY MS. NASH:
23 Q. You can answer that.
24 MR. FROST: Go ahead.
25 A. No.
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1 BY MS. NASH:
2 Q. Mr. Sweet, are you familiar with which
3 computers contain data bases related to water quantity?
4 A. No.
5 Q. Are you familiar with which computers
6 contain data bases related to water quality?
7 A. No.
8 Q. Do you have a role in the maintenance of
9 any of the Micro VAX II machines--
10 A. No.
11 Q. --owned by the water management district?
12 A. (Shakes head.)
13 Q. Are you familiar with the Britten Lee
14 system?
15 A. I know where it is.
16 Q. Do you have any responsibilities related
17 to the Britten Lee system?
18 A. No.
19 MS. NASH: I have no further questions.
20 MR. FROST: Okay.
21 Jim, before we start up, do you have any
22 idea how many or how long you may--may go?
23 MR. RICHARDS: I believe I'll only spend a
24 few minutes.
25 MR. FROST: Okay. Then can we recess
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1 while I make arrangements for the next person?
2 MS. NASH: Yes. Who will that be?
3 MR. FROST: It would be Kevin Rodberg.
4 MS. NASH: I'm sorry?
5 MR. FROST: Kevin Rodberg.
6 Will you go get him?
7 MS. JENNISON: I'll go get him.
8 MR. FROST: We can go ahead and continue,
9 if you want.
10 MR. RICHARDS: Okay.
11 CROSS EXAMINATION
12 BY MR. RICHARDS:
13 Q. Mr. Sweet, I'm Joe Richards. I represent
14 the Cities of Belle Glade and Clewiston. I'm just
15 gonna ask you a few questions.
16 You stated earlier that you review
17 statistics, is that true, on your work on the VAX 8820?
18 A. Performance statistics.
19 Q. Could you explain "performance
20 statistics," please?
21 A. The Oracle system stores data in tables.
22 However efficiently the data is stored is a--an item
23 which I keep an--I look--gosh.
24 MR. FROST: Take your time.
25 A. (continuing) Keep an eye on.
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
29
1 BY MR. RICHARDS:
2 Q. Okay.
3 I believe you referred to a CDC 180; is
4 that true?
5 A. Yes.
6 Q. Can you explain what that is?
7 A. It's a computer built by Cyber. I have no
8 responsibility as far as that machine is concerned.
9 Q. Is that a mini computer?
10 A. I don't know how to classify it.
11 Q. Do you know who at the district would be
12 most knowledgeable as to the operation of that CDC 180?
13 A. No.
14 Q. Do you operate any guidelines to maintain
15 data base integrity?
16 MR. FROST: Object to the form of the
17 question. We haven't established that there are
18 any guidelines.
19 BY MR. RICHARDS:
20 Q. Are you aware of any guidelines to
21 maintain data base integrity?
22 A. "Integrity" is a broad term.
23 MR. FROST: Could counsel please define
24 what they mean by "integrity"?
25
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
30
1 BY MR. RICHARDS:
2 Q. Just generally, what...
3 A. The data base is backed up frequently by
4 our operators. Relationally, the integrity has to be
5 ensured by the application.
6 Q. Are there precautions taken while a data
7 base is being utilized by a particular user to prevent
8 accidental change to the data?
9 A. Yes. Oracle allows various classes of
10 users. Some users may only look at the data--data.
11 Some may only insert the data, while others can also
12 change it. Any combination also can exist.
13 Q. Are you familiar with any precautions on
14 other systems besides the Oracle?
15 A. I'm not.
16 Q. No?
17 A. No.
18 Q. Are you aware of the accidental
19 destruction of any data files?
20 A. Yes.
21 Q. Could you tell me which data files that
22 you are aware of?
23 A. On the Britten Lee two years ago a disk
24 pack went bad.
25 Q. Are you aware of the nature of that data
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
31
1 that was contained in it?
2 A. No.
3 Q. Are there any other instances which you're
4 aware of the accidental destruction of data files?
5 A. No.
6 Q. Are you aware of the process to purge data
7 files?
8 A. No.
9 MR. RICHARDS: That's all I have. Thank
10 you, Mr. Sweet.
11 MR. FROST: I would like to note on the
12 record that we again would like the right to
13 review the transcript and to correct the
14 transcript and to have our witness sign it, Mr.
15 Sweet sign it.
16 (Whereupon, the deposition was concluded
17 at 2:06 p.m.)
18
19
20
21
22
23
24
25
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
32
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
33
1 I, DAVID SWEET, 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 DAVID SWEET
10
11
12 I do hereby certify that the deposition of
13 DAVID SWEET 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 _____________________________
22 Notary Public
23 My commission expires:
24
25
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
34
1 CERTIFICATE
2 THE STATE OF FLORIDA, )
3 COUNTY OF PALM BEACH. )
4 I, DONNA McCALLEY, Registered Professional
5 Reporter, and Notary Public for the State of Florida at
6 Large, do hereby certify that I reported the deposition
7 of DAVID SWEET, called by the Plaintiffs in the
8 above-entitled action; that DAVID SWEET was duly sworn
9 by me; that the foregoing pages numbered from 1 to 31,
10 inclusive, constitute a true record of the deposition
11 given by said witness.
12 I further certify that I am not attorney
13 or counsel for any of the parties, nor a relative or
14 employee of any of the parties or any attorney or
15 counsel connected with the action in which this
16 deposition is taken, nor financially interested in the
17 action.
18 WITNESS MY HAND and official seal in the
19 City of West Palm Beach, County of Palm Beach, State of
20 Florida, this 17th day of August, 1990.
21
22
23 __________________________________
Registered Professional Reporter.
24 and Notary Public, State of Florida
at Large.
25 My Commission Expires: 10/25/90.
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
PROFESSIONAL REPORTING SERVICE, INC.
Suite 303, 324 Datura Street
West Palm Beach, Florida 33401
(407) 659-4046
August 20, 1990
Mr. David Sweet
South Florida Water Management District
3301 Gun Club Road
West Palm Beach, FL 33406
In Re: United States, etc., et al versus South Florida
Water Management District, et al
Dear Mr. Sweet:
Your deposition given in the above-styled cause on
August 9 and 10, 1990, has been prepared and is ready
for you to read and sign. Mr. Frost has asked me to
provide his transcript copy to your office so that you
may photocopy it for your review.
After you have noted your corrections to the
deposition, please sign the original errata sheet and
have it notarized. Please send the errata sheet to my
office at the above address as soon as possible so it
can be provided to all counsel.
If you have any questions about the procedure you are
to follow, please call my office.
Sincerely,
Donna McCalley
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046
PROFESSIONAL REPORTING SERVICE, INC.
Suite 303, 324 Datura Street
West Palm Beach, Florida 33401
(407) 659-4046
August 20, 1990
Mr. Bill Hall
South Florida Water Management District
3301 Gun Club Road
West Palm Beach, FL 33406
In Re: United States, etc., et al versus South Florida
Water Management District, et al
Dear Mr. Hall:
Your deposition given in the above-styled cause on
August 9 and 10, 1990, has been prepared and is ready
for you to read and sign. Mr. Frost has asked me to
provide his transcript copy to your office so that you
may photocopy it for your review.
After you have noted your corrections to the
deposition, please sign the original errata sheet and
have it notarized. Please send the errata sheet to my
office at the above address as soon as possible so it
can be provided to all counsel.
If you have any questions about the procedure you are
to follow, please call my office.
Sincerely,
Donna McCalley
PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046