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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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** 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 88-1886-CIV-HOEVELER
UNITED STATES OF AMERICA, et al, )
)
Plaintiffs, )
)
vs. )
)
SOUTH FLORIDA WATER MANAGEMENT )
DISTRICT; JOHN R. WODRASKA, )
EXECUTIVE DIRECTOR, SOUTH FLORIDA )
WATER MANAGEMENT DISTRICT; FLORIDA )
DEPARTMENT OF ENVIRONMENTAL REGU- )
LATION; AND DALE TWACHTMANN, )
SECRETARY, FLORIDA DEPARTMENT OF )
ENVIRONMENTAL REGULATION, et al, )
)
Defendants. )
___________________________________)
- - - - - - - -
DEPOSITION OF BRIAN TURCOTTE,
THE WITNESS, TAKEN ON
BEHALF OF THE PLAINTIFFS
- - - - - - - -
DATE: August 24, 1990
PROFESSIONAL REPORTING SERVICE
Suite 303, 324 Datura Street
West Palm Beach, Florida 33401
(407) 659-4046
** 2
I N D E X
August 24, 1990 DIRECT CROSS
BRIAN TURCOTTE
By Ms. Nash 5
By Mr. Richards 74
** 3
The deposition of BRIAN TURCOTTE, the witness, in the
above-entitled and numbered cause, was taken before me,
DONNA McCALLEY, Registered Professional Reporter, and
Notary Public for the State of Florida at Large, at
Suite 110, 324 Datura Street, in the City of West Palm
Beach, County of Palm Beach, in the State of Florida,
beginning at the hour of 11:34 a.m., on Friday, the
24th of August, 1990, pursuant to the Notice in said
cause for the taking of said deposition, which is
annexed to the court file herein, on behalf of the
Plaintiffs in the above-entitled action pending in the
above-named court.
The appearances at said time and place
were as follows:
UNITED STATES DEPARTMENT OF JUSTICE
Room 868, 601 Pennsylvania Avenue, N.W.
Washington, D.C. 20044-0663
Attorneys for the Plaintiffs, U.S.A.
By BEVERLY SHERMAN NASH, ESQ.
PEEPLES, EARL & BLANK, P.A.
Suite 3636, Two South Biscayne Boulevard
Miami, Florida 33131
Attorneys for the Cities of Belle Glade
and Clewiston
By JOSEPH RICHARDS, ESQ.
SKADDEN, ARPS, SLATE, MEAGHER & FLOM
1440 New York Avenue, N.W.
Washington, D.C. 20005-2107
Attorneys for the South Florida Water
Management District
By KATHARINE STOLLMAN, ESQ.
ALLISON BURDETTE, ESQ.
** 4
APPEARANCES CONTINUED:
ALSO PRESENT: Toni Lafuente
Ray Roberts
Robert Johnson
David Buker
Frank Draughn
** 5
THEREUPON:
BRIAN TURCOTTE,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Will you state your name.
A. Brian Turcotte.
Q. Mr. Turcotte, I'm Beverly Nash, counsel
for the United States in this litigation, and we're
here to understand what computer systems the water
management district has, how they're set up, how
they're used, how data is formatted, how it's
transmitted, and you are here as a representative of
the water management district having knowledge on one
or more areas that we're interested in inquiring in.
Have you been shown the list of
categories?
A. Yes.
Q. What areas are you here as a
representative?
A. Items two and three.
Q. What is your present title or position?
A. Data base manager hydrology.
Q. In what division or department?
** 6
A. Data Management Division, Department of
Research and Evaluation.
Q. What is your job description?
A. My duties and responsibilities include
supervision of a group of engineers and programmers,
also implementation of our hydrologic data base and its
maintenance.
Q. And how long have been been in that role?
A. Nineteen months.
Q. Have you had other positions at the water
management district?
A. Yes.
Q. And what are they?
A. Water resource engineer.
Q. What division were you a water resource
engineer?
A. Data Management Division.
Q. And how long were you a water resource
engineer?
A. From April '86 to January 1989.
Q. And what were your job responsibilities as
a water resource engineer?
A. My duties and responsibilities included
technical review of literature, computer programming,
data base maintenance, and limited field work.
** 7
Q. Did you have any prior positions to that
at the water management district?
A. No.
Q. What is your educational background?
A. I have a Bachelors of Science degree in
civil engineering and a Master of Science degree in
civil engineering.
Q. Who is your supervisor in the data
management division?
THE WITNESS: Could you repeat the
question, please?
(Thereupon, the question at line 8 through
9 was read by the Reporter as recorded above.)
A. Rob Startzman.
BY MS. NASH:
Q. What is his title?
A. Division director.
Q. Are there employees who work for you in
the data management division?
A. Yes.
Q. How many?
A. Four.
Q. What are their titles and names?
A. Okay. Two engineers: Jose Otero and John
Fazio, and two programmers: Gene Schlacks,
** 8
S-c-h-l-a-c-k-s, and Marilyn Herring, H-e-r-r-i-n-g.
Q. What computers are utilized in the Data
Management Division?
A. Our Cyber computer and our VAX 8820 and
6310. Also personal computers and Xerox work station.
Q. Which personal computers?
A. They're a variety of IBM personal
computers.
Q. What work do you do on the Cyber?
A. My work on the Cyber right now is
primarily focused on the migration of data from the
Cyber to the VAX in support of our new data base.
Q. Is there a new data base created on the
VAX?
A. Yes.
Q. Does that data base have a name?
A. Yes.
Q. And what is its name?
A. DB Hrdro.
Q. Can you describe what DB Hrdro does?
A. It's the repository for our hydrologic
data.
Q. What is the source of the hydrologic data
in DB Hrdro?
A. The data comes from our own efforts. We
** 9
also receive data from Everglades National Park, Corps
of Engineers, Lake Worth Drainage District, and some
other cooperating agencies.
Q. What is the format in which you receive
data from these outside sources?
A. We receive data from Everglades National
Park on floppy disk. We receive data from the USGS via
dedicated connection, network connection. Most of our
data from the Corps of Engineers comes in paper copy.
Q. You mentioned receiving data from the Lake
Worth Drainage District.
A. That's also on paper copy.
Q. Are reports or analyses done of the data
in DB Hrdro?
A. Yes.
Q. What are those reports or analyses?
A. I don't feel qualified to give you a list.
It would not be complete in any--in any way.
Q. Can you tell me which reports or analyses
you know that are done?
A. I think our recent drought report to the
governing board.
MS. STOLLMAN: Don't speculate. If
you. If you don't know...
A. (continuing) Other than that, I--I really
** 10
couldn't--couldn't pin things down.
BY MS. NASH:
Q. Who would be most knowledgeable about what
reports or analyses are done on DB Hrdro?
A. I don't know who'd be the most qualified
to answer that question.
Q. Well, who knows? Who are the people that
know of the reports or analyses done?
A. George Marban, Tony Federico, Scott Burns.
That's all.
Q. Are you aware of a list of reports that
are done utilizing DB Hrdro?
A. No.
Q. On which VAX is DB Hrdro?
A. The 8820.
Q. Do you make other use of the VAX 8820?
A. Yes.
Q. What is that usage?
A. Our preprocessing system is also being
migrated to the VAX 8820.
Q. From the Cyber?
A. Yes.
Q. What is that preprocessing system?
A. The preprocessing system is our means of
processing data that the district collects in a variety
** 11
of formats, such as chart recorders, punch tape
recorders, and the like, checking the data and
ultimately placing it on our archive.
Q. Where would these chart recorders be
located that you mentioned?
A. Throughout the district.
Q. Do you mean within the building or
throughout the--
A. No. Throughout the boundaries of the
16-county region.
Q. And where would the punch tape recorders
be located?
A. Several locations that I can't identify at
this time.
Q. Do you know who can identify the location
of the punch tape recorders?
A. Yes. Anybody in Data Management Division.
Q. Is there a list of where the punch tape
recorders are located?
A. No.
Q. Is there any record of where they are?
A. Yes.
Q. What record is that?
A. That information is contained in our
preprocessing system.
** 12
Q. Does this preprocessing system have a
name?
A. That is its name.
Q. Just the prepro--the preprocessing system?
A. Right.
Q. Do you make other use of the VAX 8820?
A. No.
Q. What use do you make of the VAX 6310?
A. We use the 6310 as a intermediate storage
location for raw data collected by our solid-state
recorders.
Q. What is the nature of the raw data being
collected by these solidstate recorders?
A. Typically instantaneous values recorded
every 15 minutes. The data is usually water level
data.
Q. Any other sorts of data collected by the
solid-state recorders?
A. Yes.
Q. What is that data?
A. Rainfall, pump RPM's, gate openings, solar
radiation, wind speed, wind direction, conductivity,
oxidation reduction potential, air temperature, water
temperature.
I think that covers it.
** 13
Q. Where are these solid-state recorders
located?
A. Many different locations throughout the
district.
Q. Is there some record of where these
solid-state recorders are located?
A. Yes.
Q. What is that record?
A. On a preprocessing system.
Q. Do you make any other use of the VAX 6310?
A. No.
Q. What use do you make of the Xerox work
station?
A. Document preparation.
Q. What is the nature of the documents you
prepare on the Xerox work station?
A. Memorandums, technical papers, training
documents, and any other word processing-type
functions.
Q. What's the software you utilize on the
Xerox work station?
A. Viewpoint.
Q. Any other?
A. No.
Q. What software do you utilize on the VAX
** 14
6310?
A. The VMS operating system.
Q. Any other software?
A. No.
Q. What software do you utilize on the VAX
8820?
A. The VMS operating system and the Oracle
data base management system.
Q. What is the nature of the technical papers
you prepare on the Xerox work station?
A. The papers relate to data base design and
how our functions interface with the data base.
Q. Is there any permanent repository of these
technical papers?
A. No.
Q. Are there copies of these technical papers
located anywhere, either on computer or hard copy?
A. Yes.
Q. Where would they be located?
A. Data management division.
Q. In what format?
A. Some are on disk and some are on paper.
Q. Is there any list or record of what
technical papers are available on paper?
A. You mean is the list on paper or is the--
** 15
Q. Is there a list anywhere on paper or on
computer?
A. No.
Q. Do you know what technical papers exist on
paper?
A. Are you referring to all technical papers
in general or just the ones of which we've been
speaking?
Q. The ones you've been mentioning.
A. Carol Goff, our secretary, might be a
common person.
Q. With reference to the technical papers
that are on disk, is there any record or index of what
those technical papers are?
A. No.
Q. Who would know what technical papers exist
on disk?
A. Again, Carol, our secretary.
Q. What use does the--do you make of the IBM
PC's in the division?
A. Use the IBM PC's for preparation of
charts, graphs, digitization of strip charts,
preparation of correspondence.
That's all I can think of right now.
Q. What software do you use on the IBM PC's?
** 16
A. Harvard Graphics, Word Perfect, Cross
Talk.
That really covers it.
Q. What is the nature of the charts you
prepare on the IBM PC?
A. I left out Symphony on the types of
software we use on the PC. I guess that's all.
The nature of the charts we prepare on the
PC?
Q. Yes.
A. Are maps of locations of recording
stations, rating curves for structures, internal
productivity reports.
That's all.
Q. What is the source of the data from which
you prepare maps of locations of the recordings
stations?
A. DB Hrdro or the preprocessing system.
Q. And what is the source of data on the
rating curves--you said for structures?
A. Right. The rating--rating curves are
developed from field measurements and theoretical
equations.
Q. What are the nature of these field
measurements?
** 17
A. Field measurements are referred to as
stream gauging and follow commonly-accepted procedures.
Q. Who does the--these field measures or
stream gauging?
A. Typically, one engineer and one
technician.
Q. From your division?
A. Yes. Sometimes the Water Resources
Division contributes an engineer.
Q. By what means do they get the data into
the computer once they've collected it?
A. Manual entry.
Q. Are there set forms they use to collect
the data?
A. Yes.
Q. Do these forms have a name?
A. I don't know.
Q. Is there any quality checking or
verification of the data that these engineers and
technicians collect?
A. Yes.
MS. STOLLMAN: Are you referring to when
it's input on the computer?
MS. NASH: Yes.
A. Yes.
** 18
BY MS. NASH:
Q. And what is that procedure?
A. Comparison against previous measurements,
comparison of the result against expected results.
Q. Who does the quality checking?
A. An engineer.
Q. The same engineer that collected the data?
A. Most often.
Q. What is the nature of the graphs you
create on the IBM PC?
A. Say, rating curves, productivity reports,
and locations of sites.
Q. Do you utilize different files to prepare
these graphs, those you mentioned in the chart
preparation you were discussing?
A. I think I need to retrace what was said.
It seems like to me we're retracing the same, the same
question.
Q. That's what I'm asking you. You mentioned
that you used the IBM PC to do charts and graphs, and
so I asked you what charts you made, and you went
through those. And now I'm asking what graphs you
made, and I'm trying to find out whether you're using
the same data to make the--what sounds like the same
name for graphs as the charts you described.
** 19
A. Okay, I guess I wasn't making the same
distinction between charts and graphs that you were.
MS. STOLLMAN: Would you repeat the
question you want him to answer.
THE WITNESS: Please.
(Thereupon, the question at line 13
through 18 was read by the Reporter as recorded
above.)
A. Yes.
BY MS. NASH:
Q. What files do you utilize to create the
graphs that you did not use in creating the charts?
A. Can I just try to clear up the whole thing
here?
MS. STOLLMAN: Well--
A. I--okay. Rating curves are usually--are
developed from running a program that generates the
points and then they're entered manually. Whether
that's a chart or a graph can be up to your own
interpretation. It's a visual display.
Productivity or those internal-type
reports are generated from data from our preprocessing
system as to how many data points were placed on our
archive and compared to, say, the previous month. That
data is transmitted in a file and can then be plotted
** 20
via Symphony. Station locations are usually plotted
using AUTOCADD, assigning the coordinates of the given
station to that location, and the file is a PC-based
file which was created from data transmitted from the
Cyber.
MS. STOLLMAN: Okay, why don't we go back
and try and trace through what it is you want to
know.
THE WITNESS: I think we're spending a lot
of time going over something I think might be
very moot, so if you have a question...I am just
trying to--trying--
MS. STOLLMAN: I don't want you to go on
unless she has a question.
THE WITNESS: I'm just trying to help you
get to what you want to get at.
BY MS. NASH:
Q. What use is made of the location maps that
you prepare?
A. They're frequently photocopied and
distributed to people requesting data. They first need
to know where we collect data before they can ask for a
specific location. It's a helpful process in
identifying where things are.
Q. When you say "people requesting data," do
** 21
you mean water management district employees or people
outside the district?
A. Both.
Q. These location maps are available to the
general public or specific governmental entities?
A. Somebody makes a request, we photocopy
them and send them out.
Q. What use is made of the rating curves?
A. We use the curve--curves to compare
measurements against theory.
Q. Do others in the water management district
utilize the rating curves?
A. I don't know.
Q. So you do not provide the rating curves to
others in the district?
A. Our policy is to provide whatever
information we can when people ask for them. If they
were to ask for them, we would probably provide that.
Q. But as a general practice, you do the
rating curves for your division?
A. Yeah. I'm not aware of other people using
them.
Q. You also mentioned utilizing the IBM PC's
for digitization of strip charts.
A. Right.
** 22
Q. What is that?
A. That's a process by which a line traced on
paper with a pen via a mechanical device can be
transformed into machine-readable format, i.e., a file,
computer file.
Q. What is the information that is being
traced, what are these strip charts?
A. Water levels, gate openings and rainfall.
Q. Where are these water level data
collected?
A. At many locations throughout the district.
Q. By what means?
A. With a pencil.
Can you clarify, please?
Q. What's the method of collecting the water
level data that are on these strip charts?
A. We'll visit them there via helicopter or
truck and manually removed from the recorders.
Q. Do I understand then that these strip
charts are located in recorders?
A. Yes.
Q. Is there a list of the locations where
these recorders are?
A. No.
Q. Is there some other record--
** 23
A. Yes.
Q. What is that?
A. Preprocessing system.
Q. You testified that part your job
description is to implement the hydrologic data base?
A. Yes.
Q. What does that entail?
A. Managing contractual programming, managing
subordinates, designing and developing a data model,
computer programming. I'll leave it at that.
Q. What is the contractual program that you
manage?
A. The conversion of our preprocessing system
from the Cyber to the VAX.
Q. Which you've already discussed this
morning.
A. Correct.
Q. Is there anything else involved in
managing the contractual program?
A. No.
Q. What is the data model that you're
designing and developing?
A. A data model is a method of describing the
data in which we have an interest and how it relates to
other data.
** 24
Q. What is the type of data in which you have
an interest that you're developing this data model for?
A. Station locations, water control
structures, and the other hydrologic data which we
previously discussed.
Q. And what relationships to other data are
you interested in in this data model?
A. Could you repeat the question, please?
(Thereupon, the question at line 6 through
7 was read by the Reporter as recorded above.)
MS. STOLLMAN: What do you mean by
"interested in"?
BY MS. NASH:
Q. Well, his description of the data model
was it is a method of describing data in which they
have an interest and in how it relates to other data,
so I am trying to find out what that interest is and
what the other data and what the relationship is.
MS. STOLLMAN: You can answer if you
understand the question.
THE WITNESS: Yeah.
MS. STOLLMAN: Do you need some
clarification?
A. No, I don't. Or at least I don't think I
do.
** 25
The relationships between the data are
relationships such as a station must be in a county,
and a county can contain many stations, or a spillway
structure can contain many gates, but a gate can only
be at one spillway. Those are the types of
relationships among the data that we're looking at.
BY MS. NASH:
Q. Does this data model you're developing
have a name?
A. No.
Q. Is this data model being developed in
Oracle?
A. No.
Q. Where?
A. The data model is a conceptual view of--of
data, and presently it is located on our Xerox software
Viewpoint.
Q. Is what you're attempting to establish
a--what he's called a relational data base?
A. Yes.
Q. Are there backups done on the hydrologic
data that you utilize?
A. Yes.
Q. Who does the backups?
A. Computer Management Division.
** 26
Q. Do you do any backup in your division?
A. Yes.
Q. On what information do you do backups in
your division?
MS. STOLLMAN: Could you specify the
system you're interested in?
MS. NASH: That's what I expect him to
tell me.
A. We make an additional backup of the data
in our preprocessing system. We also back up to floppy
disk data from our solid-state recording devices. And
other people back up files on their own prerogative.
BY MS. NASH:
Q. In what form is the backup data in the
preprocessing system done?
A. Nine-track magnetic tape.
Q. What is the retention period?
A. I don't know.
Q. Who would know what the retention period
is on the backup tapes?
A. Computer Management Division.
Q. What is the retention period on the floppy
backups to the solid-state recording devices?
A. Permanent.
Q. Is there a name assigned to these floppies
** 27
that back up the solid-state recording devices?
A. Do you mean a collective name?
Q. Yes.
A. No.
Q. How are the individual floppies named?
A. They're usually lo--excuse me, labeled
with the location name and the range of dates for which
the data is collected.
Q. What is the type of data that's stored in
DB Hrdro?
A. The same data types as mentioned
previously; however, the data is summarized into mean
daily values which are more commonly used by engineers,
scientists and planners.
Q. Who does the summarization into mean daily
values?
A. It's an automated process.
Q. Is there any water quality data in DB
Hrdro?
A. Yes.
Q. Can you describe the water quality data in
DB Hrdro?
A. We--we receive conductivity data from the
USGS and we have some of our own conductivity data and
some water quality data from the areas north of the
** 28
lake that--that's part of dairy monitoring.
Q. Is that--
A. There may be more.
Q. Is there any water quality data for the
agricultural areas south of the lake?
A. I don't remember.
Q. Who would know?
A. I don't know who would know.
Q. Is there any water quality data for the
water conservation areas?
A. Not that I'm aware of.
Q. Who might know?
A. Again, I think the size of the data base
is such that--well, again, I don't know. And the size
of data base is such that to know all the types of data
at all the locations would probably be near impossible.
But the--a lot of the information that you're asking
for could be obtained by querying the data base.
I was hoping that might condense some of
the questioning.
MS. STOLLMAN: Maybe this would be a good
time to break for lunch.
MS. NASH: It's fine with me.
(Whereupon, a luncheon recess was taken
from 12:33 until 1:38 pm.)
** 29
BY MS. NASH:
Q. Mr. Turcotte, we were talking about the
types of data stored in DB Hrdro. Is there discharge
data stored in DB Hrdro?
A. Yes.
Q. What is the sources of that discharge
data?
A. Multiple agencies.
Q. What are those agencies?
A. The water management district, USGS, and
Lake Worth Drainage District.
Q. How does the water management district
collect the discharge data that's stored in DB Hrdro?
A. Could you clarify that, please?
Q. What procedure do they use to collect the
data, the discharge data?
A. Discharge data is not collected per se.
It's computed or derived.
Q. From what is the discharge data computed
or derived?
A. Water levels and structure operations. By
that I mean gate openings or pump RPM's.
Q. Are you saying there is gate-opening data
in DB Hydro?
A. No.
** 30
Q. Is there gate-opening data stored
elsewhere?
A. Yes.
Q. Where is gate-opening data stored?
A. On the preprocessing system.
Q. Where's the pump RPM data stored?
A. In the preprocessing system.
Q. Are there other computed--computer data
bases that you're aware of where hydrologic data is
stored?
A. No.
Q. Are there other computers at the water
management district that you're away of where
hydrologic data is stored?
A. No.
Q. Could you go through the steps on how you
access the data in DB Hrdro?
A. Yes.
Q. Please.
A. First I sign on to the Cyber computer, and
then I begin a command procedure which executes the
ACCESS program. Data is retrieved in the PRO--from the
PRO by using the program, and the user enters commands
based on the type of data they wish to obtain.
Q. Does the command procedure that you
** 31
utilize after you sign on to the Cyber have a name?
A. Yes.
Q. And what is its name?
MS. STOLLMAN: I would object to that on
the same bases I objected to obtaining the
telephone number for getting access to the
modem.
MS. NASH: It's a computer-command
instruction.
MS. STOLLMAN: Well, then why do you want
it if it's such a simple piece of information?
MS. NASH: I want to know the name
specifically required for on accessing how we
access information that's on the computer, and
this is how it's accessed. It's not a telephone
number. It's the name of the procedure that he
utilizes to access the information.
MS. STOLLMAN: You may answer the
question.
A. The name of the procedure is called
ACCESS.
BY MS. NASH:
Q. You next indicated that you execute an
ACCESS program. Does that Access program have a name?
A. Yes.
** 32
Q. And what is its name?
A. DB ACCESS, spelled D-B A-C-C-E-S.
Q. Is there documentation or other
instruction information on how to access DB Hrdro?
A. Yes.
Q. Does that documentation or instruction
manual have a name?
A. Yes.
Q. And what is its name?
A. The name on the cover sheet I couldn't
give to you verbatim, but essentially, it's the user's
guide for DB Hrdro.
Q. Are there any internal water management
district guidelines or instructions for accessing DB
Hrdro?
A. I don't understand your question.
Q. Any guidelines or instructions written
internally within the water management district that
are utilized to access DB Hrdro or that assist in
accessing DB Hrdro other than this user's guide you've
mentioned?
A. No.
Q. Are you aware of any hydrological data
stored in Oracle data bases?
A. Yes.
** 33
Q. What is the hydrological data stored in
Oracle data bases?
A. It is test data for the conversion of DB
Hrdro and our preprocessing system.
Q. Have you performed any analyses of
hydrologic data relating to the everglades SWIM plan?
A. Will you repeat the question, please?
(Thereupon, the question at line 6 through
7 was read by the Reporter as recorded above.)
A. No.
BY MS. NASH:
Q. Do you know whether anyone else in your
division have performed analyses of hydrologic data
relating to the SWIM plan?
A. I don't know.
Q. Have you performed any analyses of
hydrologic data relating to what's called the nutrient
removal project?
A. No.
Q. Are you aware of anyone else in the
division who performed analyses of hydrologic data
relating to the nutrient removal project?
A. No.
Q. Have you done any reports relating to the
everglades SWIM plan?
** 34
A. No.
Q. Have you done any reports relating to the
nutrient removal project?
A. No.
Q. Have you done any work related to the
Everglades National Park experimental removal program?
MS. STOLLMAN: Is this work on the
computer you're referring to?
MS. NASH: Yes.
A. Are you referring to the rainfall-based
management plan for Shark River sluice?
BY MS. NASH:
Q. If that's part of the Everglades National
Park program, I am.
MS. STOLLMAN: Do you understand the
question?
THE WITNESS: I'm not sure if we're using
the same terminology, different terminology to
mean the same thing.
MS. STOLLMAN: Can you clarify what you're
looking for?
MS. NASH: Can you read back what his
question was?
(Thereupon, the answer at line 10 through
line 11 was read by the Reporter as recorded
** 35
above.)
BY MS. NASH:
Q. Assuming that I am referring to the
rainfall-based management plan for Shark River sluice,
have you done any work related to that management plan?
A. Yes.
Q. And what work have you done on the
rainfall-based management plan for Shark River sluice?
A. I review the output each week of the
computer program that calculates that discharge.
Q. Do you report to anyone else or provide
the output to anyone else in the water management
division--district, I'm sorry?
A. Yes.
Q. To whom in the water management district
do you provide that information?
A. I think there is a--I know there is a list
of approximately 15 to 20 people who receive the
output.
Q. Do you recall any of the names on that
list?
A. Tom MacVicar, and I believe the other
people on the list are referred to by title on routing
slips, so...
Q. Do you recall any of the titles?
** 36
A. Division directors of the divisions in our
department, Research and Evaluation, and other division
directors within the district. That's as far as I can
recall right now.
Q. The computer program you mentioned that
calculates the discharge, the rainfall-based management
plan, does that program have a name?
A. Yes.
Q. What is its name?
A. I don't recall.
Q. On which system does that computer program
run?
A. It runs on our VAX 8820.
Q. Is there a directory that would contain
the name of that computer program?
A. Can you rephrase or clarify your question?
Q. Is there another way of obtaining the name
of the computer program that you've been discussing?
A. Yes.
Q. And how would one go about obtaining that
name?
A. I would examine the source code and
identify the program name that way.
Q. Where's the source code located that you
would examine?
** 37
A. On the VAX 8820.
Q. Mr. Turcotte, as part of this litigation
were you asked to compile a list of computer files that
you have?
A. No.
MS. NASH: No more questions.
CROSS EXAMINATION
BY MR. RICHARDS:
Q. Mr. Turcotte, my name's Joe Richards. I
represent the Cities of Belle Glade and Clewiston.
You discussed structure rating curves a
little while ago. Do you know what a structure rating
curve is?
A. Yes.
Q. Could you define for us what you mean by
the term "discharge rating curve"?
MS. STOLLMAN: Excuse me, could you
clarify that or simplify the question? You
asked two questions at once.
Maybe you could read back the question.
(Thereupon, the testimony from line 9
through line 16 was read by the Reporter as
recorded above.)
MS. STOLLMAN: Are you asking about the
structure rating curve or discharge rating
** 38
curve?
MR. RICHARDS: Structure rating curve.
THE WITNESS: Can I have the question one
more time, please.
BY MR. RICHARDS:
Q. Could you define what you mean by the term
"rating curve"?
A. Yes.
Q. Please do so.
A. Rating curve is the relationship between
water levels and structure operations that yields a
discharge value.
Q. Do you know what program is used to
develop these rating curves?
A. There is no program to develop the rating
curves.
Q. Is there a program used to develop the
discharge values?
A. Yes.
Q. What's that program?
A. The name of that program is E034. E034.
MR. ROBERTS: E Oh or E zero?
BY MR. RICHARDS:
Q. Is that E zero--
A. E zero 34.
** 39
Q. And could you describe the constituents
that are used to develop the discharge values?
A. Water levels, gate openings, or pump
RPM's.
Q. Are you familiar with the process used to
generate the data points that are plotted on the rating
curves?
A. Yes.
Q. Could you describe that process, please.
MS. STOLLMAN: This is a process used on
the computer system?
MR. RICHARDS: Yes.
MS. STOLLMAN: Which computer system are
you referring to?
MR. RICHARDS: He said he could answer the
question.
Please answer the question.
MS. STOLLMAN: Do you need some
clarification?
A. I don't have any problem with it.
Theoretical values are computed using
E034. The resultant points are plotted and compared
against any field measurements or stream-gauging values
that may be observed.
** 40
BY MR. RICHARDS:
Q. Do you know who at the district does this
work?
A. Yes.
Q. Who is that person?
A. Myself.
Q. Anyone else?
A. Yes. Rob Startzman.
Q. Anyone else?
A. That's all I can think of right now.
Q. Who does the work to generate the
discharge values?
A. The discharge values are computed by the
program.
Q. Do you know who runs that program?
A. Program is executed automatically.
Q. Is there an individual at the district
responsible for making sure this process is completed?
A. Are you asking me if there's just one
individual who's responsible to make sure the process
is completed?
Q. One or several.
A. Each technician who works on data is
responsible to ensure that the entire process is
completed for their--for the data in which they have
** 41
processed.
Q. Do you know who the technicians are that
process discharge values?
A. The technicians do not process discharge
values. The discharge values are computed
automatically.
Q. Could you list the technicians you just
referred to?
A. There are approximately 14 technicians.
Q. Within what division?
A. Within the Data Management Division.
Q. Do you know how often discharge values are
processed?
A. Yes.
Q. How often?
A. Every time new data is made part of the
permanent record, the discharge values for that data
are then computed.
Q. Is this done on a regular basis?
A. Yes. Discharge is computed for someplace
in the district every day, probably.
Q. Do you know how often discharge is
computed for the water conservation areas?
A. Discharge is computed on a
station-by-station basis. I do not know exactly the
** 42
frequency of which discharge is computed for those
individual stations.
Q. Do you know who would know that?
A. No, I don't.
Q. Where is this information stored,
discharge values?
A. DB Hrdro.
Q. Is there a period of record for this
discharge value information?
A. Yes.
Q. What is the period of record?
A. The period of record varies from station
to station.
Q. Do you know what the period of record is
for the discharge value information for the water
conservation areas?
A. No.
Q. Who would know that?
A. I don't know.
Q. What about for the everglades agricultural
area, do you know the period of record?
A. No.
Q. Do you know who would?
A. No.
Q. Who would you ask if you wanted to find
** 43
out what the period of record is?
MS. STOLLMAN: I believe that's been asked
and answered. He doesn't know who would know,
so how would he know who to ask?
BY MR. RICHARDS:
Q. If you wanted to find out period of
record, who would you ask the answer?
MS. STOLLMAN: You can answer if you know.
A. Data Management Division.
BY MR. RICHARDS:
Q. Do you know how--after the program
generates data points how the rating curve is created
on the computer?
A. I think I already answered that
previously.
Q. What software package is used to do that?
A. Symphony.
Q. And where are the rating curves stored?
A. Could you be more explicit or concise?
Q. Do you generate rating curve graphs?
A. Yes.
Q. Where are those graphs stored?
A. I retain copies.
Q. Where are those copies?
A. In my office.
** 44
Q. And how long are these graphs maintained
in your office?
A. I don't understand the question.
Q. Do you retain these graphs for a certain
period of time?
A. We have no date at which we dispose of
them.
Q. Are they updated on a regular basis?
A. No.
Q. Are they ever updated?
A. Yes.
Q. How often are they updated?
A. I think that's too general.
Q. Is there some set schedule for when you
update a data rating curve for a particular structure?
A. No.
Q. When do you decide to update a rating
curve for a structure?
A. Could you read the question back?
(Thereupon, the question at line 17
through 18 was read by the Reporter as recorded
above.)
A. When a representative number samples from
stream gauging measurements have been obtained, they
can be compared against the existing curve. If there
** 45
are large differences between the existing curve and
the measured values, then modification may be made to
the rating curve.
BY MR. RICHARDS:
Q. What individual at the district decides
when to update these rating curves?
A. I don't think it's an individual decision.
Q. Are there several people that would make
this decision?
A. Yes.
Q. Who are these people?
A. Partial list would include myself, Ron
Miearu, M-i-e-a-r-u, and Rob Startzman.
Q. Do you know whether rating curves have
been developed for structure S-5A?
A. Yes.
Q. Do you know when the last time a rating
curve was developed for that structure?
A. No.
Q. Who would know that?
A. I don't know.
Q. Do you possess a rating curve graph in
your office for structure S-5A?
A. Yes.
Q. And structure S-6?
** 46
A. Yes.
Q. S-7?
A. Yes.
Q. S-8?
A. Yes.
Q. S-2?
A. Yes.
Q. S-3?
A. I don't know.
Q. S-4?
A. No.
Q. No, you don't know, or no, you don't have
it?
A. No, I don't have a graph for S-4.
Q. Do you know when these graphs were
developed for these structures you just named?
A. Yes.
Q. When was that?
A. Over the last several months.
Q. And these graphs are in your office?
A. Yes.
Q. Are they contained anywhere else?
A. Are the graphs contained anywhere else?
Q. The rating curves.
A. Okay.
** 47
Q. Or the graphs.
A. Rob Startzman has copies of some.
Q. Are they contained in a digital format?
A. Yes.
Q. Symphony?
A. Yes.
Q. Is there a period of record for these
rating curves?
A. I'm not certain what you mean.
Q. You have rating curves that were developed
in the last several months. Are there any that date
back through any period of time?
A. I'm still not sure what you're asking.
Q. Well, you stated that rating curves are
developed on some sort of basis and they are updated so
you have these rating curves that were just developed.
Are there any rating curves that were developed in the
past that are still maintained at the district?
A. The--yes.
Q. Do you know how far back they date?
A. No.
Q. Is there someone at the district who would
know that?
A. I don't know.
Q. Do you know how far back the graphs that
** 48
you possess date back?
A. Yes.
Q. How far back?
A. The structures for which I've created
graphs have rate--rating curves which are applicable to
the beginning of their period of record.
Q. Dating back to the--the exact date of
which I am uncertain.
Q. The period of record for those structures,
is that what you said?
A. Correct.
Q. So that dates back to when the structure
was built?
A. Correct.
Q. And besides the structures we went over,
do you have rating curves for other structures?
A. No.
Q. Do you have rating curves for the S-10's?
A. No.
Q. S-11's?
A. No.
Q. S-12's?
A. No.
Q. Does anyone at the district have rating
curves for those structures?
** 49
A. Do you mean graphs?
Q. Yes.
A. No.
Or excuse me, I don't know.
Q. Do you know who would know?
A. No.
Q. In what format is the data contained that
is used for generating the rating curves?
A. I'm not sure I know what you mean by
"format."
Q. Is it contained in a digital format?
A. Yes.
Q. Symphony?
A. Yes.
Q. Any other?
A. No.
Q. Where is this data stored?
A. On my computer and also backed up onto
diskette.
Q. You talked about location maps for
sampling stations; is that correct?
A. Yes.
Q. Do you know whether these maps contain
Loerhan coordinates?
A. Could you repeat that question?
** 50
Q. Do you know whether these maps contained
the Loerhan coordinates for the different sampling
sites?
A. The stations are plotted based on state
plane coordinates.
Q. Excuse me?
A. The stations are plotted based on state
plane coordinates.
Q. In reference to the discharge data DB
Hrdro, is there a period of record for that
information?
A. Yes.
Q. Do you know what it is?
A. Each station has its own period of record
information.
Q. Do you know what the period of record is
for any particular stations?
A. No, I do not.
Q. Do you know who would?
A. No.
Q. Is there--is that information contained on
the computer?
A. Yes.
Q. And which computer is that?
A. Cyber.
** 51
Q. Is the Cyber computer and DB Hrdro data
base accessible from outside the district?
A. Yes.
Q. By what means?
A. Someone with a modem can dial up the
district and connect to our network.
Q. Do you know of anyone that presently has
outside access to this DB Hrdro?
A. Yes.
Q. Who is that?
A. Dave Sakema of Everglades National Park,
several people with the Corps of Engineers, several
people with the USGS, and essentially any cooperating
agency who would wish to have access will probably be
granted access.
Q. Is this read-only access?
A. Correct.
Q. Does someone at the district have a
write-access to this data bass?
A. Yes.
Q. Could you tell us who those people are?
A. Yes. Technicians in data management,
myself, and my subordinates.
Q. Do these people have authority to change
the data other than inputing new data?
** 52
A. No.
Q. Does anyone have such authority?
A. Yes.
Q. Who?
A. Myself.
Q. Anyone else?
A. I think we might be getting into a area of
confusion here.
MS. STOLLMAN: You can answer if you know
anyone else who has write access; otherwise,
don't speculate.
A. Well, I'm trying to--you--
MS. STOLLMAN: Do you know if someone else
has write access?
THE WITNESS: I'm trying to understand if
you're talking about actual data values of, say,
a water level. If that's the type of data--is
that the type of data to which you're referring?
BY MR. RICHARDS:
Q. Yes.
A. Myself would be the only person.
Q. And under what circumstances would you
have the authority?
A. I'm not--I am unaware of such
circumstances because the opportunity or the--the set
** 53
of circumstances haven't occurred.
Q. So you have not gone into the data base
and changed data?
A. Correct.
Q. Has anyone?
A. I don't know.
Q. Are there any guidelines set up within the
district to grant outside access to the DB Hrdro?
A. Yes.
Q. Can you explain those guidelines to us?
A. Any cooperating agency or other entity who
desires to use the data and in which the district would
find a exchange of information mutually beneficial will
be granted access.
Q. Does there have to be an exchange of data
to grant access?
MS. STOLLMAN: You can answer if you know.
THE WITNESS: Can we repeat the previous
question and my response, please.
(Thereupon, the question and answer
starting at line 10 through 14 was read by the
Reporter as recorded above.)
THE WITNESS: And now your question was?
** 54
(Thereupon, the question at line 15
through 16 was read by the Reporter as recorded
above.)
A. No.
BY MR. RICHARDS:
Q. Who makes the determination to grant
outside access?
A. Myself and Rob Startzman.
Q. Are you confident that the read-only
access granted to these outside parties you named
protects the integrity of the data?
MS. STOLLMAN: You can answer that if you
know.
A. Yes.
BY MR. RICHARDS:
Q. Is there a limit on the number of users
that can access DB Hrdro at any one time?
A. I don't know.
Q. Who would know?
A. I don't know.
MS. STOLLMAN: Would this be a good time
to take a break?
MR. RICHARDS: Sure, if you want.
MS. STOLLMAN: How much more do you have?
MR. RICHARDS: I'm not sure.
** 55
MS. STOLLMAN: Why don't we take a break.
(Short break.)
BY MR. RICHARDS:
Q. I believe right before the break, you said
you didn't know how many users could use the DB Hrdro
at one time. Is there someone at the district who
would know?
A. I don't know.
Q. Would that information be obtainable from
the user manual?
A. No.
Q. Do you know the source that it would be
obtainable from?
A. No.
Q. In regard to the outside access, you
mentioned ENP and the Corps of Engineers, USGS. Are
there any restrictions on this access by these parties?
A. No, they are allowed to access all the
information on the data base.
Q. Are they allowed to access it at any time?
A. Yes.
Q. Is there any restriction on the length of
time they can be on the system?
A. I don't know.
Q. Do you know who would know?
** 56
A. No.
Q. And is outside access to DB Hrdro
available at night?
A. Yes.
Q. On the weekends?
A. Yes.
Q. Are you aware of any problems that would
develop if additional outside accessers were allowed on
the system?
A. Yes.
Q. What would those problems be?
A. I interpret your use of the word
"additional access" by meaning access to absolutely
anyone who chooses to access the data. Is my
understanding correct?
Q. Well, if additional parties were granted
access, would be there a problem?
A. Are you referring to a problem in terms of
performance?
Q. Any problems.
A. Meaning--there are potential problems.
Q. What are those problems?
A. In that as the number of users increases,
the response time to get to the data decreases.
Q. Do you know how many users it would take
** 57
to decrease the response time?
A. No.
Q. Do you know how likely would it be that
response time would be decreased if additional parties
were granted access?
A. I don't know.
Q. Is there someone at the district who would
know?
A. I don't know.
Q. Are there any other problems?
A. I don't know.
Q. With outside access granted to ENP, the
Corps of Engineers and USGS, have you ever experienced
problems such as a decrease in response time?
A. I'm not aware of any decrease in response
time.
Q. Are you aware of any instance when users
within the district experienced a decrease in response
time due to the amount of use of the system?
A. No, I'm not aware of that.
No, I'd like to amend my answer. Yes, I
am. I conducted a training class, and I had
approximately eight people simultaneously accessing the
data base, and there was a decrease in response time.
Q. How were they accessing?
** 58
A. Through the ACCESS program which everybody
uses.
Q. Are there any other instances?
A. I don't recall any other instances.
Q. Have you provided data sets to outside
entities?
A. Yes.
Q. Is there a procedure for complying with
requests from the outside for data sets?
A. Yeah, the proceed--yes. The procedure, as
I understand it, is that requests are categorized by
priority. We have certain legal mandates that must be
satisfied before we can process requests from--that are
not part of legal requirements.
Q. Are these legal mandates?
A. We--for instance, we provide a monthly
report to the Corps of Engineers, water levels and
flows.
Q. Are there any others?
A. Not that I can think of.
Q. Who handles these requests?
A. Most of our requests are handled by Ernie
Gallego, our hydrologic records coordinator.
Q. Do you handle any requests?
A. Yes.
** 59
Q. And do you make the determination as to
whether the information will be provided?
A. To my knowledge, all information requests
we receive are satisfied or fulfilled.
Q. Is there someone in the district who is to
receive of all these requests? Do they have to go
through a certain individual or office?
A. Can you repeat the question, please?
Q. Is there one individual or office within
the district that must approve data requests?
A. No.
Q. For the data requests that you've handled,
did you have to seek approval from someone else in the
district before the information was provided?
A. Yes.
Q. Who?
A. Our Office of Counsel.
Q. Has that always been the procedure since
you've been at the district?
A. No.
Q. When was that procedure instituted?
A. To my knowledge, certain voluminous data
requests regarding SWIM plan data have been funneled
through our Office of Counsel.
Q. Are all data requests funneled through
** 60
Office of Counsel?
A. No.
Q. Do you know which ones are?
A. I thought I answered that already.
Q. Only the large requests for SWIM plan data
must be--are funneled through Office of Counsel?
A. That has been my understanding.
Q. Is there a written policy on this process?
A. I don't know.
Q. Are you aware of any other requests
besides these large SWIM requests that have been
funneled through Office of Counsel?
A. No.
Q. Is there a fee schedule for providing data
sets to outside entities?
A. Yes, the district had an administrative
fee policy.
Q. Is that a written policy?
A. Yes.
Q. Do you know the name of that document?
A. Administrative fee policy.
Q. Do you know when that administrative fee
policy was instituted?
A. No.
Q. Are you aware of a time where there was
** 61
not an administrative fee policy?
A. Yes.
Q. When was that?
A. Can you rephrase the question, please?
Q. You stated that you were aware of a time
when there was no administrative fee policy. Do you
know the approximate time that switch from when there
wasn't a policy and when there was?
A. Sometime between 1986 and the present.
Q. Do you know how the fees are determined
when you provide the data from DB Hrdro?
A. Yes.
Q. Could you explain that process?
A. The fees are based on some formula from
the Florida State University computing center and are
based on CPU usage.
Q. Are you aware of any differences between
the district's formula and the formula at Florida
State?
A. There are some subtle differences that I
could not expand upon at the present.
Q. Is this formula contained in the
administrative fee policy?
A. No.
Q. Is this formula contained on some other
** 62
document?
A. Yes.
Q. What document is that?
A. The NOS, N-O-S, operating system reference
manual.
Q. And is this fee formula applied to all
data requests?
A. No.
Q. Do you know which data requests it is
applied to?
A. I think those requests which require more
than, say, two-person days to fulfill.
Q. Do you know whether a fee formula is
applied in a different manner--or different manner
depending on who requests the data?
A. No, I don't know--or will you repeat that
question, please?
Q. Would a public interest group be charged a
different rate than private group?
A. No.
Q. Would a university be charged a different
rate than private industry?
A. No.
Q. Would a city government be charged a
different rate than private industry?
** 63
A. No.
Q. Would a state agency be charged a
different rate than a city government?
A. No. And the answers to all these
questions are presuming that these are not cooperating
agencies that you were referring to.
Q. Would a cooperate--cooperating agency have
to pay for data requests?
A. No.
Q. Who are these cooperating agencies?
A. USGS, Corps of Engineers, Everglades
National Park. There may be others.
Q. Are you familiar with the term "discharge
code"?
A. Could you expand upon that?
Q. Yesterday we talked with Kevin Rodberg
about the discharge codes for the data contained on the
chemical archives system. Are you familiar with those
codes?
A. I am not familiar with the data on the
chemical analysis and archives system.
Q. Are there discharge codes for the DB Hrdro
data base?
A. What is your definition of a discharge
code?
** 64
Q. Do you know what a discharge code is?
A. If you could explain to me what it is,
what it is to you, then I could tell you.
Q. The code for whether the water is flowing,
not flowing or back-flowing.
A. Those--those codes then would not be on DB
Hrdro.
Q. For the transfer of DB Hrdro from the
Cyber to the VAX 8820, do you know when this transfer
will be complete?
A. No.
Q. Is it presently being transferred?
A. Yes.
Q. Who would know?
A. I don't know.
Q. Do you know what percentage has been
completed to date?
A. You want to know what percentage of the
data on DB Hrdro has been transferred to the VAX; is
that correct?
Q. Yes.
A. Less than 5 percent.
Q. Do you know what software will be used on
the VAX computer to access DB Hrdro?
A. Yes.
** 65
Q. What is that?
A. Oracle data base management system.
Q. You stated that the VAX 6310 is used
to--for the intermediate storage of raw data from the
solid-state recorders. Do you know how long that data
is retained on the VAX 6310?
A. Presently it's just a test, but it will be
permanent storage to tape.
Q. Where is it now permanently stored?
A. On diskette. That's where--that is where
it's permanently backed up. It is still stored on the
tape.
Q. Do you know how long that backs
up--backups are retained?
A. Permanently.
Q. Where are those backup diskettes stored?
A. Data Management Division.
Q. Do you have raw data for pump operations,
including pump RPM's and pumping times?
MS. STOLLMAN: Are you talking about on
one of the computer systems?
MR. RICHARDS: Yes.
A. Yes.
BY MR. RICHARDS:
Q. Is that the VAX 6310 that we just talked
** 66
about?
A. That raw data is part of our preprocessing
system.
Q. Is that data permanently stored?
A. Yes.
Q. Is that the diskettes we just talked
about?
A. No.
Q. Where is that permanently stored?
A. At present, on the Cyber.
Q. It's gonna be stored somewhere else in the
future?
A. Yes.
Q. Where?
A. The VAX 8820.
Q. Do you know the period of record for this
data?
A. No.
Q. Do you know who would?
A. No.
Q. Who would you ask if you were gonna find
out?
A. Myself or Ernie Gallego.
Q. Where would you go to find that
information?
** 67
A. The data base.
Q. Do you have this data for pumps S-5A, S-6,
S-7 and S-8?
A. Yes.
Q. What data base would you go to to find out
the period of record information for this data?
A. Which type of data are you referring?
Q. You talked about the period of record for
this raw data.
A. Would be our preprocessing system.
Q. Do you have any additional data on pump
operations?
A. I don't know.
Q. Is there any data on pump operations that
is not in digital format?
A. I don't know.
Q. Is there hard copy of this pump operation
raw data?
A. Yes.
Q. Where is that hard copy located?
A. Data Management.
Q. Is there a period of record for that?
A. Yes.
Q. Do you know what that is?
A. No.
** 68
Q. Do you know who would?
A. No.
Q. Where would you go to find it out?
A. To the individual files of those hard
copies.
Q. Are there guidelines set up to protect the
integrity of DB Hrdro?
A. Yes.
Q. Could you explain those guidelines?
A. Only those familiar with our procedures
and those who have been trained in them would know the
commands necessary to access the data base or to update
that data base.
Q. Do you know what those guidelines are?
A. Yes.
Q. Could you explain them to us?
A. Yes.
Q. Please do.
MS. STOLLMAN: Would you like the question
repeated?
A. No.
The process is rather detailed but
involves updating our archive, which is the
preprocessing system raw data repository which we've
talked about previously.
** 69
After that is updated, the steps to update
DB Hrdro are automated, so the person or technician--or
more appropriately, updating the preprocessing system
archive would follow command procedures, which are
documented in our division.
Q. Where are they documented?
A. In technicians' guide to processing data
in hydro data management.
Q. Is there written procedures to follow in
manually inputing data to DB Hrdro?
A. There is no manual input per se to DB
Hrdro.
Q. Is there a manual input into the
preprocessing?
A. Yes.
Q. Is there written guidelines for that
process?
A. Yes.
Q. What is that?
A. The technician's guide to processing data
in hydro data management.
Q. Are you aware of any accidental loss of
data from DB Hrdro?
A. No.
Q. Are you aware of any accidental
** 70
destruction of data from DB Hrdro?
A. No.
Q. Is there anyone at the district who would
know if there was a--such loss or destruction besides
yourself?
A. I don't know.
Q. Has there ever been any accidental loss or
destruction of data from the preprocessing system?
A. I believe there may have been a disk
failure that we lost maybe two day's worth of work and
we had to go back and reprocess data.
Q. So you were able to re--
A. We were able to recover the lost
information.
Q. Are you aware of any accidental loss or
destruction of data from any other computer system?
A. Yes.
Q. What computer?
A. I think the--one of the file servers on
the Xerox had a failure some time ago. I can't
remember exactly when.
Q. Do you know what data was contained?
A. Word processing-type documents.
MR. RICHARDS: That's all I have, Mr.
Turcotte. Thank you.
** 71
(Whereupon, the deposition was concluded
at 3:26 p.m.)
