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 2 1 I N D E X 2 3 August 10, 1990 DIRECT CROSS 4 5 DAVID SWEET 6 7 By Ms. Nash 5 8 By Mr. Richards 28 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 3 1 The deposition of 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 4 1 APPEARANCES CONTINUED: 2 SOUTH FLORIDA WATER MANAGEMENT DISTRICT 3301 Gun Club Road 3 West Palm Beach, Florida 33416-4680 By JULIE JENNISON 4 ALSO PRESENT: John A. Davis, Ph.D. 5 Frank Draughn David Buker 6 Robert Johnson 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 5 1 THEREUPON: 2 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? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 6 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 7 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 8 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," PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 9 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 10 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 11 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 12 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 13 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.) PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 14 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... PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 15 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 16 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 17 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 18 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? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 19 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 20 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 21 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 22 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? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 23 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? PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 24 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 25 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 26 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. PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 27 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 PROFESSIONAL REPORTING SERVICE, INC., (407) 659-4046 28 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