STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
SUGAR CANE GROWERS COOPERATIVE OF )
FLORIDA, a Florida Agricultural )
Cooperative Marketing Association, ) CASE NOS. 92-3038
ROTH FARMS, INC., and ) 92-3039
WEDGWORTH FARMS, INC., ) 92-3040
)
and )
)
FLORIDA SUGAR CANE LEAGUE, INC.; )
UNITED STATES SUGAR CORPORATION; )
and NEW HOPE SOUTH, INC., )
) ___________________
and )
FLORIDA FRUIT AND VEGETABLE ) DEPOSITION
ASSOCIATION, LEWIS POPE FARMS, )
W.E. SCHLECHTER & SONS, INC., and ) OF
HUNDLEY FARMS, INC., )
) LORI ANN SUTTER
Petitioners, ) ___________________
)
vs. )
)
SOUTH FLORIDA WATER MANAGEMENT )
DISTRICT, an Agency of the State )
of Florida, )
)
Respondent, )
)
and )
)
MICCOSUKEE TRIBE OF INDIANS OF )
FLORIDA, the UNITED STATES OF )
AMERICA, and FLORIDA DEPARTMENT OF )
ENVIRONMENTAL REGULATION, and the )
FLORIDA WILDLIFE FEDERATION, )
)
Intervenors. )
___________________________________)
AT DURHAM, NORTH CAROLINA
NOVEMBER 9, 1992 - 9:00 A.M.
REPORTED BY: CAROLYN R. RICHARDSON
CAROLYN Y. HALL & ASSOCIATES
MS. SUTTER PAGE 2
APPEARANCES:
FOR THE PETITIONERS:
MR. WILLIAM L. HYDE MR. GARY V. PERKO
PEEPLES, EARL & BLANK HOPPING, BOYD, GREEN & SAMS
215 SO. MONROE STREET 123 SOUTH CALHOUN STREET
SUITE 350 POST OFFICE BOX 6526
TALLAHASSEE, FLORIDA 32301 TALLAHASSEE, FLORIDA 32314
TELEPHONE: (904) 681-1900 TELEPHONE: (904) 222-7500
FOR THE
RESPONDENT-INTERVENOR:
MS. SUZAN HILL PONZOLI MR. LEE M. KILLINGER
ASSISTANT U.S. ATTORNEY ASSISTANT GENERAL COUNSEL
SOUTHERN DISTRICT OF FLORIDA STATE OF FLORIDA
155 SOUTH MIAMI AVENUE DEPARTMENT OF ENVIRONMENTAL
SUITE 627 REGULATION
MIAMI, FLORIDA 33130 TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TELEPHONE: (305) 536-4425 TALLAHASSEE, FLORIDA 32399
TELEPHONE: (904) 488-9730
FOR DUKE UNIVERSITY:
MR. RALPH L. McCAUGHAN
KING, WALKER, LAMBE & CRABTREE
SUITE 100, 3708 MAYFAIR STREET
POST OFFICE BOX 51549
DURHAM, NORTH CAROLINA 27717-1549
TELEPHONE: (919) 493-8411
ALSO PRESENT:
MR. RONALD D. JONES, Ph.D.
FLORIDA INTERNATIONAL UNIVERSITY
MR. JIM GRIMSHAW, Ph.D.
SOUTH FLORIDA WATER
MANAGEMENT DISTRICT
MR. SAM ELSWICK, PARALEGAL
MS. SUTTER PAGE 3
T A B L E O F C O N T E N T S
E X A M I N A T I O N I N D E X
DEPONENT - LORI ANN SUTTER - 11/9/92
EXAMINATION BY: PAGES
MS. PONZOLI 4-169
MR. KILLINGER 169-194
-------------------------------------------------------
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
(EXHIBITS NUMBER 1 THROUGH NUMBER 31 WERE
IDENTIFIED BY MS. SUTTER DURING HER DEPOSITION
AND ALL COPIES WERE RETAINED BY MS. PONZOLI.)
-------------------------------------------------------
SIGNATURE PAGE FOR DEPONENT 195
CERTIFICATION OF COURT REPORTER 196
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MS. SUTTER PAGE 4
ON MOTION OF COUNSEL FOR THE
RESPONDENT-INTERVENOR, THE DEPOSITION OF MS. LORI ANN
SUTTER MAY BE TAKEN BEGINNING AT OR AROUND 9:00 A.M.
ON NOVEMBER 9, 1992, AT THE HILTON HOTEL, DURHAM,
NORTH CAROLINA, BEFORE CAROLYN R. RICHARDSON, A
NOTARY PUBLIC.
THE SIGNATURE OF THE WITNESS TO THE TRANSCRIPT
OF HER TESTIMONY IS HEREBY REQUIRED.
- - - - - - - - - - -
WHEREUPON,
LORI A. SUTTER,
HAVING BEEN FIRST DULY SWORN,
WAS EXAMINED AND TESTIFIED
AS FOLLOWS:
EXAMINATION BY MS. PONZOLI:
Q. WOULD YOU STATE YOUR NAME FOR THE RECORD,
PLEASE?
A. MY NAME IS LORI ANN SUTTER.
Q. AND YOUR ADDRESS, MS. SUTTER?
A. MY CURRENT RESIDENCE IS 201 WYNDFIELD COURT,
RALEIGH, NORTH CAROLINA.
Q. AND A -- DO YOU HAVE A BUSINESS ADDRESS, ALSO,
MS. SUTTER?
MS. SUTTER PAGE 5
A. I'M CURRENTLY WORKING FOR THE DUKE UNIVERSITY
WETLAND CENTER.
Q. ARE YOU GOING TO CONTINUE YOUR EMPLOYMENT WITH THE
DUKE UNIVERSITY WETLANDS CENTER, MS. SUTTER?
A. I DON'T ANTICIPATE THAT.
Q. IS IT REALLY LITERALLY ENDING, ALMOST, EVEN AS WE
ARE TAKING THIS DEPOSITION?
A. YES, MA'AM. I'VE ACCEPTED A JOB AND IT HASN'T
BEGUN, AND FORTUNATELY I'VE BEEN ABLE TO MAINTAIN
EMPLOYMENT HERE UNTIL THAT JOB BEGINS.
Q. ALL RIGHT. AND WHOM WILL YOU BE EMPLOYED BY NEXT?
A. BY THE NORTH CAROLINA DIVISION OF COASTAL
MANAGEMENT.
Q. IS THAT A STATE AGENCY?
A. YES, IT IS.
Q. AND WHERE ARE THEY LOCATED?
A. IN RALEIGH.
Q. DO YOU HAPPEN TO KNOW THE ADDRESS?
A. NO, I DON'T. I KNOW IT'S IN THE COOPER BUILDING.
Q. OKAY. IS THERE A PHONE NUMBER WHERE YOU CAN BE
REACHED?
A. DAYTIME IS AREA CODE (919) 684---
Q. RIGHT.
A. ---2619, EXTENSION 23.
MS. SUTTER PAGE 6
Q. IS THAT THE DUKE WETLANDS CENTER?
A. YES, IT IS.
Q. ALL RIGHT. OKAY. MS. SUTTER, HAVE YOU EVER HAD
YOUR DEPOSITION TAKEN BEFORE?
A. NO, I HAVE NOT.
Q. ALL RIGHT. I AM SUZAN HILL PONZOLI. I'M AN
ATTORNEY FOR THE UNITED STATES IN A STATE
ADMINISTRATIVE PROCEEDING THAT IS GOING ON IN
FLORIDA, WHICH THIS DEPOSITION IS TAKEN IN
RELATION TO. I'LL BE ASKING YOU A NUMBER OF
QUESTIONS ABOUT YOUR WORK AT THE DUKE WETLANDS
CENTER. WHEN I ASK A QUESTION AND YOU ANSWER IT,
IT IS PRESUMED THAT YOU UNDERSTOOD MY QUESTION.
SO, IF YOU DON'T UNDERSTAND THE QUESTION, YOU HAVE
TO INDICATE THAT TO US AND I WILL TRY TO FRAME A
BETTER QUESTION FOR YOU. BUT, IF YOU ANSWER, THEN
IT'S ASSUMED THAT YOU UNDERSTOOD AND ARE ANSWERING
IN RESPONSE TO THAT QUESTION. ARE YOU REPRESENTED
BY COUNSEL HERE TODAY, MS. SUTTER?
MR. HYDE: ACTUALLY, SHE'S NOT
REPRESENTED BY COUNSEL. WE'RE HERE
TODAY ON BEHALF OF THE RESPONDENTS,
FLORIDA SUGAR CANE LEAGUE, U.S. SUGAR
CORPORATION AND NEW HOPE SOUTH, INC.
MS. SUTTER PAGE 7
Q. (BY MS. PONZOLI) HAVE YOU BEEN PREPARED FOR THIS
DEPOSITION, MS. SUTTER?
A. HOW DO YOU MEAN PREPARED?
Q. HAS SOMEONE TALKED TO YOU ABOUT WHAT THE
DEPOSITION WOULD BE LIKE?
A. YES.
Q. AND WHO DID THAT?
A. RICK BURGESS.
Q. ALL RIGHT. AND WHEN DID HE DO THAT?
A. FRIDAY MORNING.
Q. HOW LONG DID HE SPEND WITH YOU?
A. APPROXIMATELY AN HOUR AND A QUARTER, NINETY --
EIGHTY-FIVE MINUTES, I GUESS---
Q. CERTAINLY.
A. ---OR SEVENTY-FIVE?
Q. RIGHT. AND WHAT DID MR. BURGESS TELL YOU AT THAT
TIME?
A. HE WENT THROUGH THE PROCEDURE THAT YOU WOULD BE
ASKING ME SIMILAR QUESTIONS THAT YOU HAVE, AND
TOLD ME TO SPEAK HONESTLY, AND ABOUT WHAT I WAS
CERTAIN OF, AND HE JUST STRESSED THE IMPORTANCE OF
TELLING THE TRUTH.
Q. UH-HUH (YES). OKAY.
A. AND ALSO MR. HYDE MET WITH ME EARLY THIS MORNING
MS. SUTTER PAGE 8
AND BRIEFED ME VERY SHORTLY OVER BREAKFAST---
Q. AND WHAT DID HE---
A. ---BRIEFED MAY HAVE BEEN THE WRONG WORD.
Q. DID HE ALSO TELL YOU TO TELL THE TRUTH?
A. YES, HE DID. (LAUGHS.)
Q. (LAUGHS.) HOW DID I KNOW? ALL RIGHT. YOU HAVE
BROUGHT DOCUMENTS WITH YOU HERE TODAY. WHO HELPED
YOU ASSEMBLE THOSE DOCUMENTS?
A. I ASSEMBLED THE DOCUMENTS MYSELF---
Q. UH-HUH (YES).
A. ---I TYPED THE INDEX LIST THAT YOU HAVE THERE WITH
THE ASSISTANCE OF A FRIEND OF MINE WHO IS NOT IN
THE PROJECT IN ANY WAY, HE WAS JUST THERE AND
READING OFF PAGE TITLES TO ME AS I TYPED THEM IN.
Q. OKAY. YOU'RE INDICATING THAT YOU DID PRODUCE AN
INDEX OF THE DOCUMENTS THAT YOU HAVE BROUGHT IN
RESPONSE TO THE UNITED STATES SUBPOENA DUCES
TECUM?
A. YES, MA'AM.
Q. OKAY. CAN YOU IDENTIFY THIS, PLEASE?
A. THIS IS AN INDEX OR AN INVENTORY OF THE CONTENTS
OF THE BOX THAT I BROUGHT IN.
MS. PONZOLI: ALL RIGHT. LET ME
HAVE HER MARK IT FIRST. I SHOULD HAVE
MS. SUTTER PAGE 9
HAD HER MARK IT FIRST, AND THEN WE'LL HAVE
YOU IDENTIFY IT.
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT NO. 1 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) SUTTER ONE, WOULD YOU IDENTIFY
THAT AGAIN, MS. SUTTER?
A. YES. THIS IS AN INDEX OF WHAT IS CONTAINED IN THE
BOX THAT I BROUGHT IN THIS MORNING.
MS. PONZOLI: WOULD YOU MARK THIS
FOR IDENTIFICATION, PLEASE?
(THEREUPON, THE DOCUMENT REFERRED
TO ABOVE WAS MARKED AS DEPOSITION
EXHIBIT NO. 2 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) WOULD YOU IDENTIFY THIS, PLEASE,
MS. SUTTER?
A. THIS APPEARS TO BE A COPY OF A SUBPOENA THAT I
RECEIVED. ACTUALLY, THIS IS THE DOCUMENT I
RECEIVED PRIOR TO MY SUBPOENA, ASKING FOR THE
DOCUMENTS THAT I HAVE PRODUCED.
Q. DO YOU HAVE A COPY OF THAT WITH YOU?
A. NO, I DO NOT.
MS. SUTTER PAGE 10
MS. PONZOLI: I'D LIKE TO GO THROUGH IT
WITH YOU. LET ME SEE IF I HAVE AN ADDITIONAL
COPY, BECAUSE WE NEED TO GO THROUGH THE
DIFFERENT CATEGORIES, AND MAKE SURE THAT YOU
HAVE PRODUCED ALL THOSE DOCUMENTS. LET'S GO
OFF THE RECORD.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
MS. PONZOLI: LET'S GO BACK ON THE
RECORD.
Q. (BY MS. PONZOLI) MS. SUTTER, I'D LIKE TO IDENTIFY
THE DOCUMENTS THAT ARE RESPONSIVE TO THE NOTICE
DUCES TECUM, AND HAVE YOU IDENTIFY AMONG THE
RECORDS YOU PRODUCED HERE WHICH ONES ARE
RESPONSIVE TO WHICH REQUEST, BUT WE'LL TRY TO DO
THIS AS RAPIDLY AS POSSIBLE, AND WE'LL MAKE
COMPOSITE EXHIBITS OF A LOT OF YOUR -- OF YOUR
DOCUMENTS.
A. (NODS AFFIRMATIVELY.)
Q. THE FIRST IS A COPY OF YOUR CV, OR SIMILAR
DOCUMENT. CAN YOU---
A. I HAVE A COPY OF MY RESUME.
MS. SUTTER PAGE 11
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT NO. 3 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) MS. SUTTER, IS SUTTER THREE YOUR
CV?
A. YES.
Q. OKAY. THE SECOND REQUEST IS A LIST OF ALL
TECHNICAL, PROFESSIONAL OR SCIENTIFIC
PUBLICATIONS, ETCETERA, THAT IDENTIFY YOU AS AN
AUTHOR OR CO-AUTHOR RELATED TO EVERGLADES
RESEARCH. DID YOU PRODUCE A LIST?
A. YES, I DID.
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT NO. 4 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) IS SUTTER NUMBER FOUR THAT LIST?
A. YES, IT IS.
Q. AND THEN A COPY OF THE TECHNICAL, PROFESSIONAL OR
SCIENTIFIC PUBLICATIONS, ETCETERA, WHICH YOU ARE
IDENTIFIED AS AN AUTHOR OR CO-AUTHOR, RELATED TO
EVERGLADES RESEARCH.
A. PART OF THAT DOCUMENT ARE THE APPENDICES THAT YOU
MS. SUTTER PAGE 12
ARE HAVING COPIED RIGHT NOW.
Q. ALL RIGHT. WHEN THE PARALEGAL RETURNS, WE'LL HAVE
HIM -- WE'LL HAVE HIM PUT THE APPENDICES BACK WITH
THIS DOCUMENT, AND THIS WILL SIMPLY BE A COMPOSITE
EXHIBIT, SUTTER NUMBER FIVE.
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT NO. 5 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) IS SUTTER NUMBER FIVE YOUR
SINGLE PUBLICATION, MS. SUTTER?
A. YES, IT IS. IT WAS PUBLISHED UNDER -- BOTH AS MY
THESIS THROUGH THE DUKE SCHOOL OF THE ENVIRONMENT,
AS WELL AS IN THE ANNUAL REPORT.
Q. THAT'S THE 1992 ANNUAL REPORT---
A. YES, MA'AM.
Q. ---OF THE DUKE WETLAND CENTER?
A. ALL RIGHT.
Q. ALL RIGHT. ARE THEY IDENTICAL IN THE ANNUAL
REPORT AND IN YOUR MASTER'S THESIS AND THE COPY
THAT WE HAVE BEFORE US?
A. YES, MA'AM. THERE MAY BE A BIT OF A TYPO HERE AND
THERE THAT WAS CHANGED.
Q. OKAY.
††††††††††††⁔䡅剅⁔䡁吠坁匠䍈䅎䝅䐮ഊഊ††††††††††儮†⁏䭁央ഌ
MS. SUTTER PAGE 13
A. BUT NOTHING OF ANY SUBSTANCE WAS CHANGED.
Q. THERE ARE NO -- WE SHOULD FIND NO REALLY SENTENCE
CHANGES OR SUBSTANTIVE CHANGES?
A. NO, YOU SHOULD NOT.
Q. ALL RIGHT. AS PART OF REQUEST NUMBER THREE, WAS A
REQUEST FOR DRAFTS, EDITED COPIES, REVIEWERS'
COMMENTS ON YOUR PUBLICATIONS. DO YOU HAVE THOSE
TYPES OF---
A. I'M SORRY. I APOLOGIZE. I DISCARDED THOSE AT THE
TIME OF MY GRADUATION, AND I PRODUCED A MEMO
SAYING THAT I HAD DISCARDED ALL THOSE.
Q. OKAY.
A. IF I WOULD HAVE KNOWN THAT IT WOULD HAVE BEEN
NEEDED AT A LATER TIME, I WOULD HAVE KEPT THEM.
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT NO. 6 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) SUTTER NUMBER SIX IS YOUR
STATEMENT TO THAT EFFECT. IS THAT ACCURATE?
A. YES, IT IS.
Q. OKAY. LET ME ASK YOU THIS, WHO DID REVIEW YOUR
MASTER'S THESIS AND YOUR ARTICLE PUBLISHED IN THE
'92 ANNUAL REPORT FOR THE DUKE WETLANDS CENTER?
MS. SUTTER PAGE 14
A. IT WAS REVIEWED BY DR. CHRISTOPHER CRAFT.
Q. RIGHT.
A. AND FINALLY BY DR. CURT RICHARDSON.
Q. RIGHT.
A. AND EDITS WERE MADE BY OUR ADMINISTRATIVE
ASSISTANT TO THE WETLANDS CENTER, AND SHE JUST
CHANGED PERIODS AND SPACES.
Q. OKAY. TO THE BEST OF YOUR RECOLLECTION, WHAT WERE
THE SUBSTANCE OF DR. CRAFT'S EDITORIAL OR REVIEW
COMMENTS?
A. MUCH OF IT WAS JUST IN PRESENTATION, IN THE WAY
THAT I EXPLAINED WHAT I FOUND. AND HE HELPED ME
TO INTERPRET MY DATA, AS WELL.
Q. I DON'T KNOW EXACTLY THE TERM, YOU'LL HAVE TO HELP
ME. THERE'S USUALLY A SUPERVISING PROFESSOR. IS
THAT THE APPROPRIATE TERM WHEN YOU DO YOUR
MASTER'S WORK?
A. AT THE SCHOOL OF THE ENVIRONMENT, WE ARE A
PROFESSIONAL SCHOOL, AND NOT A -- QUOTE, UNQUOTE
-- "GRADUATE SCHOOL."
Q. OKAY. DR. RICHARDSON IS MY ADVISOR. HOWEVER,
BECAUSE OF MANY OF HIS OBLIGATIONS, HE'S NOT
AVAILABLE TO GIVE HANDS ON DIRECT DAY-TO-DAY
ASSISTANCE. AND THAT WAS WHERE DR. CRAFT CAME
MS. SUTTER PAGE 15
IN, AND I WORKED VERY CLOSELY WITH HIM ON MY
PROJECT.
Q. DID YOU WORK CLOSELY WITH DR. CRAFT FROM -- FROM
THE EXPERIMENTAL DESIGN THROUGH THE WRITING OF
YOUR MASTER'S THESIS?
A. YES, I DID.
Q. DID DR. RICHARDSON REVIEW YOUR EXPERIMENTAL
DESIGN?
A. YES, HE DID.
Q. OKAY. DO YOU REMEMBER ANY PARTICULAR SUBSTANTIVE
SUGGESTIONS BY DR. CRAFT ON YOUR EXPERIMENTAL
DESIGN?
A. WE HASHED OUT HOW MANY TREATMENTS I WOULD HAVE AND
HOW MANY DEPTHS, WHICH, OF COURSE, WAS LIMITED BY
WHAT WAS PHYSICALLY POSSIBLE, GIVEN OUR GREENHOUSE
AND WHAT MATERIALS WE HAD AVAILABLE TO US.
Q. WERE THOSE LIMITATIONS SPACE YOU'RE TALKING ABOUT
LARGELY?
A. YES, MA'AM. WE HAD A SPACE, AS WELL AS JUST
CONSTRUCTIONARY -- OF HOW -- FOR EXAMPLE, HOW DEEP
THESE WATER TREATMENTS COULD BE.
Q. WHAT WAS THE CONSTRAINT ON DEPTH?
A. JUST THE SIZE OF THE CONTAINER THAT I COULD -- A
WATERTIGHT CONTAINER THAT I COULD FIND.
MS. SUTTER PAGE 16
Q. SO, IT WAS REALLY CONSTRAINED BY WHAT YOU WERE
ABLE TO FIND ON THE OPEN MARKET AVAILABLE, FOR HOW
DEEP YOU WERE ABLE TO MAKE?
A. YES, MA'AM.
Q. AND WHAT DID YOU FIND? I MEAN, WHERE DID YOU
LOCATE YOUR -- IS IT TUBS? WOULD THAT BE A FAIR
TERM?
A. YES.
Q. ALL RIGHT. WHERE DID YOU LOCATE YOUR TUBS?
A. I THINK I PURCHASED THEM BETWEEN ROSE'S, WAL-MART
AND K-MART, THOSE KIND OF STORES.
Q. DO YOU REMEMBER THE SUBSTANCE OF ANY OF DR.
RICHARDSON'S SUGGESTIONS IN REGARD TO YOUR
EXPERIMENTAL DESIGN?
A. NO. LIKE I SAID, WE JUST HASHED OUT AND CAME UP
WITH THE DESIGN THAT WE CAME UP WITH.
Q. OKAY. LET ME ASK YOU THIS, IN REGARD TO THE
CONCENTRATION LIMITS THAT YOU CHOSE, WHOSE
DECISION WAS THAT?
A. ALL THREE OF OURS.
Q. ALL RIGHT. I THINK I'LL RETURN TO THAT MORE WHEN
I TALK ABOUT HOW YOU SET UP YOUR EXPERIMENT. WERE
THERE OTHER MEMBERS OF YOUR MASTER'S COMMITTEE,
OTHER THAN DR. RICHARDSON AND DR. CRAFT?
MS. SUTTER PAGE 17
A. NO, MA'AM.
Q. OKAY. IS THAT COMMON IN THE ENVIRONMENTAL SCHOOL?
A. YES.
Q. DID YOU HAVE TO DEFEND YOUR THESIS?
A. NO, I DID NOT.
Q. AND DO YOU HAVE PLANS TO PUBLISH YOUR MASTER'S
THESIS?
A. YES, I DO.
Q. WHERE?
A. I HAVE NOT DECIDED THAT AT THIS TIME.
Q. HAVE YOU SUBMITTED YOUR PAPER---
A. NO, I HAVE NOT.
Q. ---FOR CONSIDERATION?
A. NO, MA'AM.
Q. ALL RIGHT, WHY NOT?
A. BECAUSE AS A MASTER'S PROJECT, IT'S TOO LONG FOR
PUBLICATION. IT NEEDS TO BE REVISED.
Q. WHAT ARE THE TYPES OF OPPORTUNITIES THAT YOU WOULD
HAVE FOR PUBLICATION? DO YOU UNDERSTAND MY
QUESTION?
A. NO, I DO NOT.
Q. OKAY. WHAT TYPES OF PUBLICATIONS WOULD BE
INTERESTED IN PUBLISHING SUCH A MASTER'S THESIS?
DO YOU UNDERSTAND THAT QUESTION?
MS. SUTTER PAGE 18
A. YES, I DO.
Q. ALL RIGHT.
A. AT BEST, I THINK WOULD BE A JOURNAL SUCH AS
AQUATIC BOTANY.
Q. UH-HUH (YES).
A. MORE REALISTICALLY, I THINK A JOURNAL SUCH AS
WETLANDS WOULD BE APPROPRIATE.
Q. ALL RIGHT. IS WETLANDS AN EASIER PUBLICATION TO
BE PUBLISHED IN THAN AQUATIC BOTANY?
A. I DON'T KNOW IF IT'S EASIER.
Q. RIGHT.
A. THE WORK THAT I DID IS MORE ALONG THE LINES OF
WHAT I THINK WETLANDS PUBLISHES MORE.
Q. OKAY, WHAT IS AQUATIC BOTANY INTERESTED IN?
A. I'M NOT AN EXPERT ON THE SUBJECT---
Q. RIGHT.
A. ---BUT I THINK THEY ARE MORE INTERESTED IN
THEORETICAL RESEARCH, AND DEFINITELY FIELD
RESULTS.
Q. AND WHAT IS WETLANDS INTERESTED IN, TO THE BEST OF
YOUR UNDERSTANDING?
A. TO THE BEST OF MY UNDERSTANDING, I BELIEVE THEY
ARE MORE -- I BELIEVE THEY ARE MORE INTERESTED IN
APPLIED RESEARCH AND PRACTICAL APPLICATIONS.
MS. SUTTER PAGE 19
Q. WHAT ARE THE LIMITS THAT YOU UNDERSTAND, THE PAGE
LIMITS ON PUBLICATION IN WETLANDS?
A. I HAVE NO IDEA.
Q. OKAY. WHY DO YOU BELIEVE THAT YOURS IS TOO LONG
AT PRESENT?
A. BECAUSE WHEN YOU READ ARTICLES, THEY ARE ALL MUCH
SHORTER THAN WHAT I HAVE AT THIS TIME, AND IT'S
JUST GENERAL -- GENERALLY ACCEPTED THAT YOUR
JOURNAL PUBLICATIONS ARE CONCISE VERSIONS OF YOUR
MASTER'S WORK.
Q. OKAY. WHEN DID YOU FINISH THIS MASTER'S THESIS?
A. MY DATE OF GRADUATION IS SEPTEMBER 1, '92.
Q. HAS DR. RICHARDSON GIVEN YOU ANY ADVICE ON
PUBLISHING IT?
A. HE HAS MENTIONED THAT IT WOULD -- THAT IT IS
PUBLISHABLE. BUT AS TO ADVICE AS TO WHERE, IS
THAT WHAT YOU'RE ASKING?
Q. YES, MA'AM.
A. NO, MA'AM, HE HAS NOT.
Q. HAS HE ENCOURAGED YOU TO PUBLISH IT?
A. YES, HE HAS.
Q. DID HE ADVISE YOU TO APPLY OR SUBMIT IT FOR
CONSIDERATION TO WETLANDS?
A. I DON'T THINK DIRECTLY. I THINK I ASKED HIM IF IT
MS. SUTTER PAGE 20
WAS PUBLISHABLE IN WETLANDS AND HE SAID IT WAS --
HE THOUGHT THAT IT WAS.
Q. OKAY. IS THERE NORMALLY AN EFFORT TO GET A PAPER
SUCH AS THIS PUBLISHED BY THE DUKE WETLANDS
CENTER?
A. I DON'T KNOW ABOUT THE DUKE WETLAND CENTER.
Q. HOW LONG WERE YOU WITH THEM?
A. TWO YEARS.
Q. OKAY. IS THERE ENCOURAGEMENT AT THE DUKE WETLANDS
CENTER TO PUBLISH?
A. I'M NOT FAMILIAR WITH ANY ENCOURAGEMENT FROM THE
CENTER ITSELF TO PUBLISH.
Q. WELL, IS THE CENTER -- DOESN'T THE CENTER LARGELY
CONSIST OF DR. RICHARDSON, DR. CRAFT---
A. AND DR. QUALLS.
Q. DR. QUALLS?
A. YES, MA'AM, AND DR. VYMAZAL IS ALSO -- THERE'S
JUST A GENERAL DESIRE IN ACADEMIA TO PUBLISH---
Q. RIGHT.
A. ---AND I DON'T KNOW -- I DON'T BELIEVE THAT MY
ENCOURAGEMENT TO PUBLISH HAS COME FROM THE CENTER
MORE SO THAN JUST MYSELF. AND JUST IN WORKING
WITH THESE PEOPLE, THAT'S KIND OF A GENERAL GOAL
THAT YOU WORK TOWARDS.
MS. SUTTER PAGE 21
Q. BUT THERE'S NO REQUIREMENT THAT YOU MAKE AN EFFORT
TO PUBLISH YOUR MASTER'S---
A. NO, MA'AM.
Q. ---THESIS?
A. THERE IS NOT.
Q. IS THAT UNIQUE TO THE DUKE WETLANDS CENTER?
A. THE SCHOOL OF THE ENVIRONMENT DOES NOT REQUIRE
PUBLICATION OF YOUR MASTER'S.
Q. OKAY. DOES THE SCHOOL OF THE ENVIRONMENT
ENCOURAGE ITS GRADUATE STUDENTS TO PUBLISH THEIR
THESES?
A. YES, IT DOES.
Q. DO YOU HAVE PLANS TO SHORTEN YOUR PRESENT MASTER'S
THESIS AND SUBMIT IT TO WETLANDS OR ANY OTHER
PUBLICATION?
A. I HAVE PLANS TO REVISE IT AND TO SHORTEN THE
LENGTH, YES, BUT NOT TO SHORTEN THE CONTENT.
Q. OKAY. IF YOU ARE GOING TO REVISE IT, WHAT ARE
YOUR PLANS TO REVISE IT?
A. IT'S HARD FOR ME TO SAY AT THIS TIME. I HAVEN'T
REALLY LOOKED AT THE DOCUMENT SINCE I FINISHED.
Q. UH-HUH (YES).
A. IT'S BEEN KIND OF SOMETHING I'VE SET ASIDE TO TAKE
A BREAK FROM.
MS. SUTTER PAGE 22
Q. OKAY. HOW LONG DID YOU WORK ON THIS PAPER?
A. OH, I WORKED ON THE ACTUAL WRITING, I WROTE ON AND
OFF WITHIN THE LAST EIGHTEEN MONTHS, SOMETIMES
MORE INTENSIVELY THAN OTHERS.
Q. OKAY. HAS DR. CRAFT ENCOURAGED YOU TO SUBMIT IT
FOR PUBLICATION?
A. YES, HE HAS.
Q. OKAY. SO THE REVISING, YOU'RE ONLY TALKING ABOUT
SHORTENING IT, OR ARE YOU TALKING ABOUT CHANGING
SOME OF YOUR ANALYSIS?
A. I DON'T CURRENTLY HAVE PLANS TO CHANGE ANY OF MY
ANALYSES---
Q. DO YOU THINK YOU MIGHT?
A. ---BUT I'M NOT SAYING THAT WON'T HAPPEN. I DON'T
KNOW.
Q. WHAT WOULD CAUSE YOU TO HAVE PLANS TO CHANGE YOUR
ANALYSIS?
A. IF WE SEE SOMETHING FROM A DIFFERENT PERSPECTIVE.
Q. WHAT WOULD YOU SEE FROM A DIFFERENT PERSPECTIVE?
A. I DON'T KNOW AT THIS TIME.
Q. WHAT'S GOING ON THAT MIGHT GIVE YOU A DIFFERENT
PERSPECTIVE?
A. WE MAY RUN DIFFERENT STATISTICS, FOR EXAMPLE, ON
THE SOILS THAT I RAN VERY FEW STATISTICS ON.
MS. SUTTER PAGE 23
Q. PRIOR TREATMENT OR POST TREATMENT OR BOTH?
A. BOTH.
Q. WHO HAS SUGGESTED THIS TO YOU?
A. THAT WAS JUST AN EXAMPLE THAT I CAME UP WITH.
Q. HAVE YOU EVER DISCUSSED DOING MORE STATISTICS ON
THE SOILS WITH DR. CRAFT?
A. NO, I HAVE NOT.
Q. HAVE YOU EVER DISCUSSED IT WITH DR. RICHARDSON?
A. NO, I HAVE NOT.
Q. OKAY.
A. THIS IS JUST SPECULATION.
Q. WHY DID YOU THINK THAT THIS MIGHT BE SOMETHING
THAT'S NECESSARY?
A. BECAUSE, AS I MENTIONED, THAT WAS NOT SOMETHING I
RAN A GREAT DEAL OF STATISTICS ON EARLY.
Q. WHAT -- AND I -- I GUESS WHAT I'M DRIVING AT IS
WHERE -- WHERE DID THIS PARTICULAR DEFICIT COME TO
YOUR ATTENTION?
A. I DON'T BELIEVE IT'S A DEFICIT AT THIS POINT---
Q. UH-HUH (YES).
A. ---YOU ASKED FOR AN EXAMPLE WHERE I MIGHT SEE
SOMEWHERE TO CHANGE IT. I THINK THAT WE HAVE
LOOKED AT EVERY PERSPECTIVE FOR THE VEGETATION.
Q. UH-HUH (YES).
MS. SUTTER PAGE 24
A. AND I HAVE NOT LOOKED AT MY SOILS IN AS GREAT A
DETAIL AS I LOOKED AT MY VEGETATION.
Q. OKAY. ARE YOU AWARE OF THE ONGOING RESEARCH OF
THE DUKE WETLANDS CENTER IN THE EVERGLADES?
A. YES, I AM.
Q. ALL RIGHT. ARE YOU FOLLOWING THAT?
A. WHAT DO MEAN BY FOLLOWING?
Q. ARE YOU KEEPING TRACK OF WHAT'S GOING ON IN THAT
PARTICULAR RESEARCH?
A. NOT CLOSELY.
Q. OKAY. WHAT WORK ARE YOU ACTUALLY PRESENTLY
PERFORMING FOR THE DUKE WETLANDS CENTER?
A. I AM, I GUESS, DR. CRAFT'S ASSISTANT.
Q. AND WHAT DO YOU PER -- WHAT DO YOU DO FOR
DR. CRAFT?
A. I ENTER DATA INTO THE COMPUTER.
Q. OKAY.
A. I RUN STATISTICAL ANALYSES ON THAT DATA. I
PRODUCE GRAPHS UNDER HIS SUPERVISION, SLIDES.
Q. ANYTHING ELSE?
A. I DO ANYTHING HE ASKS ME TO---
Q. SURE. SURE.
A. ---WITHIN THE REALM OF THE PROJECT. THOSE ARE THE
THINGS I SPEND MY GREATEST TIME DOING.
MS. SUTTER PAGE 25
Q. OKAY. WHICH PARTICULAR PROJECTS ARE YOU ENTERING
DATA AND RUNNING STATISTICAL ANALYSIS ON,
ETCETERA?
A. DR. CRAFT'S FERTILIZER STUDY.
Q. OKAY. HIS FERTILIZER STUDY?
A. YES.
Q. IS THAT IT?
A. YES.
Q. ALL RIGHT. HAVE YOU DONE ANY WORK ON THE DOSING
STUDY?
A. NO, I HAVE NOT.
Q. ARE YOU FAMILIAR WITH THE WORK THAT'S BEING DONE
ON THE DOSING STUDY?
A. I'M FAMILIAR THAT THERE IS SOME WORK GOING ON
WITH THE DOSING STUDY. I HAVE NEVER WORKED ON
IT.
Q. ALL RIGHT. DO YOU HAVE A TIME FRAME THAT YOU
BELIEVE THAT YOU WOULD SUBMIT THIS PAPER FOR
PUBLICATION TO WETLANDS? HAVE YOU SET ANY GOAL
IN YOUR MIND?
A. I HAVE NOT, BUT I PROBABLY WILL DO IT BY MID '93.
Q. ALL RIGHT. THE NEXT AREA UNDER THE NOTICE DUCES
TECUM WAS ALL DOCUMENTS RELATING TO RESEARCH DONE
IN CONJUNCTION WITH OR UNDER THE DIRECTION OF DR.
MS. SUTTER PAGE 26
RICHARDSON AND/OR THE DUKE WETLANDS CENTER, AND I
ASSUME THAT SORT OF GENERIC REQUEST COVERS
EVERYTHING---
A. YES.
Q. ---ELSE THAT YOU'VE BROUGHT THIS MORNING?
A. YES.
Q. ALL RIGHT.
MS. PONZOLI: DO YOU WANT TO MARK THIS
FOR IDENTIFICATION?
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT NO. 7 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
MS. PONZOLI: LET'S GO OFF THE RECORD.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
MS. PONZOLI: I'D LIKE THE RECORD TO
REFLECT THAT WE ARE RETURNING THE APPENDICES
TO YOUR PUBLICATION AT THIS TIME, AND WE'LL
ADD THEM AT THE APPROPRIATE PLACE.
WITNESS: THEY JUST GO RIGHT -- RIGHT
BEHIND THAT.
MS. SUTTER PAGE 27
MS. PONZOLI: WHICH IS EXHIBIT --
DOCUMENT EXHIBIT NUMBER FIVE. AND THE
APPENDICES WE'LL RETURN TO LATER TO DISCUSS
IN MORE DETAIL.
Q. (BY MS. PONZOLI) OKAY. I WOULD LIKE TO HAND YOU
SUTTER NUMBER SEVEN AND ASK YOU IF YOU CAN
IDENTIFY THAT, MS. SUTTER.
A. THIS IS A COPY OF THE ABSTRACT THAT I SUBMITTED TO
THE SOCIETY OF WETLANDS SCIENTISTS 13TH ANNUAL
MEETING IN NEW ORLEANS.
Q. ALL RIGHT. DESCRIBING YOUR PAPER THAT WE'VE BEEN
DISCUSSING?
A. YES, MA'AM, THE PRESENTATION THAT I WOULD MAKE ON
THAT PAPER.
Q. OKAY. AND TELL ME, THE PURPOSE OF AN ABSTRACT IS
TO DO WHAT?
A. IT IS A SUMMARY OF WHAT, IN THIS CASE, I'M
REPRESENTING, SO THAT PEOPLE DON'T HAVE TO READ
THE WHOLE DOCUMENT.
Q. AND DO YOU THINK THAT YOUR ABSTRACT ACCURATELY
SUMMARIZES YOUR PAPER?
A. VERY, VERY CONCISELY, YES.
Q. I THINK WHAT I'D LIKE TO DO, MS. SUTTER, SINCE
DOCUMENT REQUEST NUMBER FOUR IS SO GENERIC AND
MS. SUTTER PAGE 28
WOULD ENCOMPASS VIRTUALLY EVERYTHING THAT YOU HAVE
BEFORE US IN YOUR DOCUMENTS, I THINK WE'LL READ ON
THE THROUGH THE REST OF THE REQUESTS, AND IF WE'RE
ABLE TO ISOLATE CATEGORIES OF DOCUMENTS A LITTLE
MORE PRECISELY, LET'S -- LET'S ISOLATE THOSE,
IDENTIFY THOSE, AND THEN WE'LL JUST SORT OF HAVE A
GENERIC GROUP AT THE END.
A. (NODS AFFIRMATIVELY).
Q. I THINK NUMBER FIVE, AGAIN, IS PROBABLY FAIRLY
GENERIC. WOULD YOU AGREE WITH ME, ALL DOCUMENTS
RELATING TO RESEARCH DONE IN THE EVERGLADES
PROTECTION AREA, OR EVERGLADES AGRICULTURAL AREA?
A. YES. I DID NOT DO ANY INDEPENDENT RESEARCH IN
THOSE AREAS.
Q. OKAY. AND THEN NUMBER SIX WOULD ONLY SEND US BACK
TO ALL DOCUMENTS RELATING TO YOUR PARTICULAR
PAPER, WOULDN'T IT?
A. (NODS AFFIRMATIVELY) YES.
MS. PONZOLI: ALL RIGHT. NUMBER SEVEN,
HOWEVER, IS ALL DATA, WHETHER USED OR NOT,
COLLECTED AS PART OF THE STUDY OF THE --
OF THE EVERGLADES PROTECTION AREA OR THE
EVERGLADES AGRICULTURAL AREA, AND IT
INCLUDES -- INCLUDED PUBLISHED DATA, MEAN
MS. SUTTER PAGE 29
DATA, AND RAW DATA. I THINK WHAT I'D LIKE TO
ASK YOU TO DO, IS IF YOU WOULD JUST TAKE A
FEW MOMENTS OFF THE RECORD, AND KIND OF
ORGANIZE INTO -- INTO SOME USEFUL MANNER YOUR
DATA THAT YOU'VE PRODUCED BEFORE US TODAY,
AND THEN LET'S IDENTIFY IT AND ENTER IT INTO
THE RECORD. OKAY?
MS. PONZOLI: LET'S GO OFF THE
RECORD, NOW.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
(THEREUPON, THE DOCUMENTS REFERRED
TO BELOW WERE MARKED AS DEPOSITION
EXHIBIT NOS. 8-29 - LORI A. SUTTER
DEPOSITION - FOR IDENTIFICATION.)
MS. PONZOLI: ALL RIGHT. I'D LIKE TO
GO BACK ON THE RECORD.
Q. (BY MS. PONZOLI) MS. SUTTER, WE HAVE CATEGORIES,
WELL, FOUR THROUGH THIRTEEN, AND WE'VE TAGGED
AS COMPOSITE EXHIBITS THE REMAINDER OF THE
DOCUMENTS THAT YOU'VE PRODUCED TODAY, AND IN
TAGGING THEM, IT APPEARS TO ME -- AND I'LL ASK
MS. SUTTER PAGE 30
YOU TO CONFIRM -- WE'VE TAGGED DATA, WE'VE TAGGED
WHAT WOULD BE THE EQUIVALENT OF FIELD NOTES, OR
LABORATORY NOTES, I SUPPOSE, SLIDES, ETCETERA.
IS THAT ACCURATE?
A. YES, IT IS.
Q. ALL RIGHT. THEN WHAT I'M GOING TO ASK YOU TO DO
IS JUST TO GO THROUGH AND, AS WE COME TO EACH
COMPOSITE EXHIBIT, TELL US WHAT THE COMPOSITE
EXHIBIT IS. AND IF THERE ARE DIFFERENT DOCUMENTS
THAT REALLY AREN'T ALL -- LET'S SAY, FOR EXAMPLE,
YOUR PHOSPHORUS DATA FROM A PARTICULAR PART OF THE
EXPERIMENT, BUT THEY FALL INTO A LITTLE DIFFERENT
CATEGORY, I WOULD ASK YOU TO PENCIL NUMBER THE
PAGES AND TELL US, SUTTER DOCUMENT ELEVEN, FOR
EXAMPLE, PAGES ONE THROUGH FIVE ARE SUCH AND SUCH,
AND PAGES SIX THROUGH ELEVEN ARE SUCH AND SUCH, SO
THAT WHEN WE GO BACK AND LOOK AT YOUR DEPOSITION
AND LOOK AT YOUR EXHIBITS, WE WILL KNOW WHAT WE
WERE LOOKING AT. OKAY?
A. OKAY.
Q. THANK YOU. CAN YOU PLEASE IDENTIFY FOR ME SUTTER
EXHIBIT EIGHT?
A. SUTTER EXHIBIT EIGHT IS WHAT I CALL ORGANIZATIONAL
INFORMATION SHOWING MY DESIGN, WHICH POTS WERE
MS. SUTTER PAGE 31
PLACED IN -- WHICH -- WHICH PLANTS WERE PLACED IN
WHICH POTS, WHICH WERE PLACED IN WHICH TUBS, AND
WHAT TREATMENT THOSE TUBS WERE KEPT AT.
Q. DOES THIS INCLUDE YOUR EXPERIMENTAL DESIGN?
A. TO SOME DEGREE. IT'S LAID OUT SIMILAR TO MY
DESIGN, YES.
Q. ARE THERE DOCUMENTS THAT REFLECT YOUR EXPERIMENTAL
DESIGN MORE ACCURATELY AMONG THE DOCUMENTS WE HAVE
HERE?
A. I BELIEVE THAT APPENDIX NINE IN MY PAPER IS MORE
EASILY UNDERSTOOD, FROM MY EXPERIMENTAL DESIGN.
Q. AND IT IS THE ACCURATE DESIGN FOR HOW YOUR
EXPERIMENT WAS ACTUALLY CARRIED OUT?
A. YES.
Q. THESE BEING PERHAPS IN SOME CASES EARLIER
DRAFTS---
A. YES.
Q. ---OF WHAT YOU INTENDED TO DO?
A. YES.
Q. IS THERE ANYTHING ELSE IN SUTTER COMPOSITE EXHIBIT
EIGHT?
A. YES, THERE IS. THERE ARE MY -- THE DIFFERENT
PARAMETERS THAT I MEASURED IN MY SAW -- IN MY
GREENHOUSE EXPERIMENT ARE PENCILED IN ON THESE
MS. SUTTER PAGE 32
PAGES, THAT WERE LATER TYPED IN AND AGAIN
PRESENTED IN THE APPENDICES. THIS WAS JUST FOR MY
UNDERSTANDING PRIOR TO PUTTING IT TOGETHER IN THE
APPENDIX. AND, AGAIN, ANOTHER PAGE OF JUST
ORGANIZATIONAL DATA THAT HELPED ME TO UNDERSTAND
WHAT WAS GOING ON.
Q. OKAY. CAN YOU IDENTIFY SUTTER NUMBER NINE,
COMPOSITE EXHIBIT NUMBER NINE?
A. YES. THESE ARE WHAT I CALL MY MASTER DATA FILES,
AND I -- I HAVE -- AGAIN, I HAVE THEM BROKEN OUT
IN EACH OF THE APPENDICES AS TO WHAT THEY WERE
LOOKING -- AT WHAT EACH APPENDIX WAS REFERRING TO.
BUT I HAVE THEM ALL IN ONE MASTER DATA SET THAT
ARE SHOWN HERE.
Q. ALL RIGHT. I'M NOT A SCIENTIST, SO YOU'LL HAVE TO
EXCUSE ME. ARE THESE RAW DATA THAT WE'RE LOOKING
AT HERE?
A. THESE ARE RAW CORRECTED DATA. WHEN MY SAMPLES
WERE ANALYZED, THE TECHNICIAN OR MYSELF CAME UP
WITH A NUMBER. HOWEVER, THOSE SOMETIMES ARE
CORRECTED FOR YOUR QA/QC'S OR -- OR CORRECTED OUT
FOR ANY -- ANY BLANKS, OR NON-SUBSTANTIAL -- I
DON'T KNOW HOW TO EXPLAIN IT -- BLANKS -- AS IN
JUST RUNNING A SAMPLE WITHOUT -- THAT YOU KNOW HAS
MS. SUTTER PAGE 33
NO PHOSPHOROUS, HOWEVER -- FOR EXAMPLE, PHOSPHORUS
OR NITROGEN, OR WHATEVER I WAS RUNNING AT THE
TIME. IF YOU KNOW IT HAS NOTHING OR SIMILAR TO
NOTHING, YET, IF FOR SOME REASON YOUR MACHINE
PICKED UP A SMALL AMOUNT, THAT WOULD BE SUBTRACTED
OUT FROM ALL OF YOUR SAMPLES. THAT'S THE
DIFFERENCE BETWEEN CORRECTED AND UNCORRECTED, IN
MY UNDERSTANDING.
Q. ALL RIGHT. AND THEN DO WE HAVE YOUR UNCORRECTED
DATA ANYWHERE?
A. I DO NOT HAVE MY UNCORRECTED DATA.
Q. OKAY.
A. THOSE WERE ALL CORRECTED---
Q. ALL RIGHT.
A. ---BEFORE I LOOKED AT THEM.
Q. ALL RIGHT. AND YOUR TECHNICIAN DID THAT, OR YOU
DID IT, OR BOTH?
A. I DON'T RECALL EVER HAVING TO DO THAT.
Q. OKAY. WHO WAS YOUR TECHNICIAN?
A. I WAS MY OWN TECHNICIAN FOR MANY OF THE ANALYSES.
I BELIEVE CELIA BEST RAN MY PHOSPHATES ON THE
TRAACS.
Q. NOW, BECAUSE I'M NOT A SCIENTIST AND I HAVEN'T
LOOKED AT YOUR -- WELL, YOUR APPENDIX WAS NOT
MS. SUTTER PAGE 34
AVAILABLE TO US UNTIL YOU BROUGHT IT TO US THIS
MORNING, IS THAT IN THE SAME FORM AS THIS, OR IS
IT MEAN DATA, OR---
A. IT'S IN THE SAME FORM.
Q. RIGHT.
A. THE FORMAT OF THE PRESENTATION---
Q. RIGHT.
A. ---IS A BIT DIFFERENT.
Q. OKAY. IS THERE ANYTHING ELSE IN THERE?
A. NOT IN EXHIBIT NINE.
Q. ALL RIGHT. WOULD YOU PLEASE IDENTIFY SUTTER
EXHIBIT NUMBER TEN FOR ME?
A. SUTTER TEN HAS IN IT---
Q. OH, I'M SORRY, SUTTER TEN.
A. ---HAS A DIGEST PROCEDURE WHICH WAS NOT USED IN MY
STUDY. IT WAS JUST FOR REFERENCE OF ANOTHER
METHOD. AND THEN ALL OF THE HAND SHEETS THAT I
WROTE OUT WEIGHTS OF MY SAMPLES. AND, AGAIN, THIS
WAS PRIOR TO TYPING THEM INTO THE LAST FOLDER THAT
YOU SAW ANY PHOSPHORUS CONCENTRATIONS, OR I
BELIEVE THAT ALL I HAVE IN HERE IS MASS AND
PHOSPHORUS, DRY WEIGHT OR MASS, WHICH YOU WILL SEE
IT, AND PHOSPHORUS CONCENTRATION.
Q. ALL RIGHT. WOULD YOU PLEASE IDENTIFY SUTTER
MS. SUTTER PAGE 35
COMPOSITE EXHIBIT NUMBER ELEVEN, PLEASE?
A. NUMBER ELEVEN IS ENTITLED "DIGESTION RESULTS."
IN IT, I HAVE THE NATIONAL BUREAU OF STANDARDS
STANDARD LEVELS OF NUTRIENTS AND THE STANDARDS
THAT I USED, AND THEN RESULTS FROM THE MANY RUNS
OF ITEMS IN MY GREENHOUSE STUDY.
Q. ALL RIGHT. SUTTER COMPOSITE EXHIBIT NUMBER
TWELVE?
A. THESE ARE OVERHEADS AND THE GRAPHS THAT I USED TO
PRODUCE THE OVERHEADS FOR MY MASTER'S PROJECT
PRESENTATION THAT I DID TO CLASSMATES. THIS WAS
NOT BASED ON FINAL DATA.
Q. WOULD THERE BE SOME DIFFERENCES WITH YOUR FINAL
DATA FROM---
A. I DON'T BELIEVE SO.
Q. ---WHAT WAS REFLECTED THERE?
A. HOWEVER, THIS WAS PRESENTED IN MARCH OR APRIL; AND
I DON'T BELIEVE ANY OF THIS HAS CHANGED, BUT THERE
MAY BE SOME SMALL DIFFERENCES.
Q. DID YOU USE ANY OF THAT IN NEW ORLEANS AT THE
SOCIETY OF WETLANDS SCIENTISTS?
A. I DID NOT USE THESE ACTUAL DOCUMENTS, NO.
Q. DO WE HAVE ANOTHER SET THAT YOU DID USE?
A. YOU HAVE MY SLIDES.
MS. SUTTER PAGE 36
Q. THE SLIDES, OKAY.
A. YES.
Q. OKAY. AND THESE WERE MADE FROM SEPARATE,
WHATEVER, MASTERS? ARE THE SLIDES DUPLICATES OF
THESE IS WHAT I'M ASKING?
A. TO THE BEST OF MY KNOWLEDGE, YES. FOR EXAMPLE,
THOUGH, IF -- IF I HADN'T RUN A COMPLETE SET AT
THE TIME THAT I PRESENTED MY MASTER'S PROJECT,
WHICH I DON'T BELIEVE IS THE CASE, BUT -- THEY MAY
HAVE CHANGED.
Q. OKAY. CAN YOU IDENTIFY, PLEASE, SUTTER COMPOSITE
EXHIBIT NUMBER THIRTEEN?
A. NUMBER THIRTEEN IS WHAT I HAVE ENTITLED "WATER,"
AND BASICALLY THIS IS A LIST OF THE PHOSPHORUS
CONCENTRATION THAT I MONITORED WEEK BY WEEK, OR IN
EARLY CASES BI-WEEKLY, AND THEN HOW THEY COMPARED
TO THE LEVEL THEY WERE SUPPOSED TO BE AT, AND JUST
A DATA SET INCLUDING ALL THE PHOSPHORUS
CONCENTRATIONS IN WATER.
Q. HOW DO WE KNOW WHAT THEY WERE SUPPOSED TO BE AT?
A. FOR EXAMPLE, IF MY TREATMENT WAS ZERO PARTS PER
MILLION PHOSPHORUS, THERE IS A STRAIGHT LINE
MARKING THROUGH ZERO AND THEN DATA POINTS
SURROUNDING THAT LINE WHERE THEY ACTUALLY FELL.
MS. SUTTER PAGE 37
Q. ALL RIGHT. SUTTER COMPOSITE EXHIBIT NUMBER
FOURTEEN?
A. NUMBER FOURTEEN HAS WHAT I CALL PARTITIONING.
THESE ARE DATA THAT ARE FOUND, AGAIN, IN OTHER
LOCATIONS, JUST PULLED OUT SO THAT I COULD LOOK AT
THEM A DIFFERENT WAY BY TREATMENT AND -- AND BY
TREATMENT AS WELL AS PLANT PART, ABOVEGROUND,
BELOWGROUND, DEAD, LIVE.
Q. OKAY. SUTTER COMPOSITE EXHIBIT NUMBER FIFTEEN,
PLEASE?
A. NUMBER FIFTEEN IS WHAT I HAVE LABELED "TREND
GRAPHS AND DATA." AND THIS IS -- THESE WERE MY
INITIAL ATTEMPTS TO UNDERSTAND MY DATA. EXCUSE
ME. MANY OF THESE ARE WHAT THE TREND -- THE TREND
GRAPHS ARE WHAT MY OVERHEADS WERE MADE FROM.
THESE, YOU WILL FIND IN MOST CASES, ARE DUPLICATE
COPIES.
Q. AND ARE THESE FINALLY REFLECTED IN YOUR TABLES
ATTACHED WITH YOU PUBLICATION?
A. I BELIEVE MY TABLES SHOW DIFFERENT INFORMATION
THAN THOSE GRAPHS DO.
Q. DO THE BAR GRAPHS SHOW SIMILAR INFORMATION, OR
NOT?
A. THE TABLES THAT I HAVE -- YOU'RE GOING TO CATCH ME
MS. SUTTER PAGE 38
NOT HAVING LOOKED AT THIS FOR TWO MONTHS. MAY I
SEE MY TABLES IN MY DOCUMENTS?
(THEREUPON, DOCUMENTS HANDED TO THE WITNESS.)
A. MY TABLES AND MY GRAPHS DO NOT REFLECT THE SAME
INFORMATION WITH THE EXCEPTION OF TABLE THREE
WHICH IS -- WHICH IS REFLECTED IN THE PARTITIONING
FOLDER, THE EXHIBIT FOURTEEN THAT I JUST
EXPLAINED.
Q. HOW ABOUT YOUR TREND GRAPHS AND YOUR BAR GRAPHS,
DO THEY REFLECT SIMILAR INFORMATION?
A. THEY REFLECT MY FIGURES---
Q. ALL RIGHT.
A. ---BUT NOT MY TABLES.
Q. OKAY. HOW ABOUT SUTTER COMPOSITE EXHIBIT NUMBER
SIXTEEN? WAS THAT EVERYTHING FOR FIFTEEN?
A. YES. NUMBER SIXTEEN HAS PROGRAMS AND OUTPUT SAS
RUNS, MHO RECOMMENDATION WRITTEN ON IT. MHO WAS A
FORMER EMPLOYEE OF THE WETLANDS CENTER WHO WAS
WELL-VERSED IN STATISTICS WHO OFFERED ADVICE ON
HOW TO RUN SOMETHING WITH A SIMILAR DESIGN AS
MINE. THIS IS SAS OUTPUT.
Q. S-A-S?
A. YES, MA'AM. THAT WAS---
Q. IS THAT A SOFTWARE PROGRAM?
MS. SUTTER PAGE 39
A. YES, IT IS.
Q. OKAY.
A. STATISTICAL ANALYSIS SYSTEMS, I BELIEVE. THIS WAS
RUN FAIRLY RECENTLY, AND IT HAS NOT BEEN
OVERANALYZED; IT HAS NOT BEEN EXTREMELY ANALYZED.
Q. DO YOU INTEND TO DO MORE ANALYSIS WITH IT?
A. YES. THESE ARE WHAT I WILL USE FOR MY REVISIONS.
Q. OKAY. IS THERE ANYONE WHO WILL BE HELPING YOU
WITH THAT?
A. I EXPECT THAT DR. CRAFT AND DR. RICHARDSON WILL,
AND DR. VYMAZAL, WHOSE NAMES WILL ALL APPEAR ON
THE PAPER, WILL MAKE SOME COMMENTS.
Q. OKAY. DOES DR. RICHARDSON HELP YOU WITH YOUR
STATISTICAL ANALYSIS?
A. NO, HE DOESN'T.
Q. DOES DR. CRAFT HELP YOU WITH YOUR STATISTICAL
ANALYSIS?
A. YES, HE DOES.
Q. OKAY. AND DR. VYMAZAL?
A. NO, MA'AM. HE DOES NOT.
Q. OKAY. IS THERE ANY PARTICULAR PERSON IN THE DUKE
WETLANDS CENTER WHO IS CONSIDERED THE -- I DON'T
KNOW -- THE PERSON WITH THE MOST STATISTICAL
EXPERIENCE?
MS. SUTTER PAGE 40
A. MR. HO, WHO HAS RECENTLY LEFT US, AND WAS NOT --
HE WAS A GRADUATE STUDENT, WAS FAIRLY WELL-VERSED
IN STATISTICS.
Q. MR. WHO?
A. HO.
Q. H-O?
A. YES.
Q. WHO IS CHINESE?
A. YES.
Q. OKAY. AND WHERE HAS HE GONE?
A. I BELIEVE HE'S GONE TO DARTMOUTH ON A POST DOC.
Q. TO DO HIS Ph.D.?
A. NO, MA'AM, HE'S ALREADY---
Q. OH, HE'S ALREADY A DOCTORATE?
A. YES.
Q. OKAY. SO, THIS IS DR. HO, ACTUALLY?
A. ACTUALLY. YES, THAT'S RIGHT.
Q. OKAY.
A. ALTHOUGH I WOULD SAY THAT ALL OF THEM ARE VERY
WELL-VERSED IN STATISTICS.
Q. OKAY.
A. JUST HOW -- HOW MUCH TIME THEY HAVE TO SPEND ON
THAT.
Q. WHAT WAS DR. VYMAZAL'S CONTRIBUTION TO YOUR PAPER
MS. SUTTER PAGE 41
OR YOUR PROJECT?
A. DR. VYMAZAL IDENTIFIED PERIPHYTON AND ALGAE AND
PLANKTON THAT APPEARED DURING THE COURSE OF MY
STUDY, AND HE PERFORMED THE ANALYSES ON THEM.
Q. DO YOU CONSIDER THESE SORT OF SPONTANEOUS GROWTHS
OUT OF THE SOIL, DO YOU CONSIDER THEM AN IMPORTANT
PART OF YOUR -- OF YOUR EXPERIMENT?
A. I DO CONSIDER THEM AN IMPORTANT PART, HOWEVER,
THEY WERE NOT ANTICIPATED.
Q. AND WHY ARE THEY AN IMPORTANT PART?
A. BECAUSE WE WANTED TO KNOW WHERE ALL THE PHOSPHORUS
THAT I ADDED WENT, AND IF THESE PERIPHYTON AND
OTHER ORGANISMS APPEARED, THEN PERHAPS THEY PLAYED
A ROLE.
Q. OKAY. WHAT ROLE DID YOU END UP DECIDING THEY
PLAY?
A. VERY SMALL IN THE BIG PICTURE.
Q. HOW SO?
A. BECAUSE IN THE VERY CONTROLLED ENVIRONMENT THAT I
HAD FOR A LIMITED TIME OF SIX MONTHS, THEY DID NOT
APPEAR TO HOLD A LARGE PART OF THE PHOSPHORUS.
Q. THEY WERE MEASURED FOR HOW MUCH PHOSPHORUS THEY
ACTUALLY CONTAINED, IS THAT RIGHT?
A. YES.
MS. SUTTER PAGE 42
Q. OKAY. AND YOU ACCOUNTED FOR ONLY FIFTY PERCENT OF
THE PHOSPHORUS THAT WAS ADDED TO THE EXPERIMENT.
IS THAT ACCURATE?
A. THAT IS CORRECT.
Q. WHERE DO YOU THINK THE OTHER FIFTY PERCENT WENT?
A. THAT CALLS FOR SPECULATION ON MY PART, BUT I -- MY
GUESS IS THE SOIL.
Q. PARDON?
A. MY GUESS IS THE SOIL
Q. YOU ANALYZED THE SOIL THOUGH AFTERWARDS, THOUGH,
DIDN'T YOU?
A. YES, I DID.
Q. AND YOU ACCOUNTED FOR WHAT HAD GONE INTO THE SOIL,
HADN'T YOU?
A. I ACCOUNTED FOR WHAT WAS IN THE SOIL WHERE I
MEASURED IT.
Q. WHERE DID YOU MEASURE IT?
A. APPROXIMATELY FIVE CENTIMETERS FROM THE SURFACE.
Q. YOU DID NOT MEASURE THE TOTAL SOIL CONTENT OF THE
POTS?
A. IN RETROSPECT, I -- I SHOULD HAVE SAMPLED IT FROM
SEVERAL LOCATIONS, BUT I DID NOT, AND THAT IS WHY
THERE IS ONLY FIFTY PERCENT ACCOUNTED FOR.
Q. SO, IF I UNDERSTAND YOU CORRECTLY, YOU WENT DOWN
MS. SUTTER PAGE 43
FIVE CENTIMETERS FROM THE SURFACE AND TOOK A
MEASUREMENT PER POT?
A. I TOOK A SOIL SAMPLE FROM THERE AND MEASURED THE
PHOSPHORUS AT THAT POINT. OCCASIONALLY, THOSE
WERE REPEATED MEASUREMENTS.
Q. ARE THOSE REFLECTED ANYWHERE AMONG YOUR DOCUMENTS,
WHAT THOSE MEASUREMENTS WERE, FIVE CENTIMETERS
DOWN?
A. THOSE ARE IN MY APPENDICES IN THE RAW DATA, YES.
Q. OKAY. CAN YOU POINT TO THOSE FOR ME, PLEASE?
A. IN EXHIBIT FIVE, IN THE SECTION MARKED APPENDICES,
AND APPENDIX TWO. I'M SORRY, CORRECTION. IT'S IN
APPENDIX THREE. APPENDIX TWO IS BASELINE SOIL.
Q. ALL RIGHT. AND APPENDIX TWO, WERE THESE NUMBERS
BASED ON WET OR DRY WEIGHTS?
A. THE -- I'M SORRY, DID YOU SAY APPENDIX TWO?
Q. YES. YES, MA'AM. I'M GOING TO ASK YOU ABOUT
THREE ALSO, BUT I WAS GOING TO DO THEM SEPARATELY.
A. APPENDIX TWO, THE AMMONIUM NITRATE AND PHOSPHATE
ARE EXTRACTIONS WHICH ARE BASED ON WET -- WET
WEIGHT. THE TOTAL P IS BASED ON DRY WEIGHT.
Q. IS THE SAME TRUE FOR APPENDIX THREE?
A. YES, IT IS.
Q. OKAY. AND I ASSUME THAT THESE SOIL SAMPLES ARE
MS. SUTTER PAGE 44
LONG GONE? I MEAN, THEY'RE NOT AVAILABLE FOR YOU
TO STILL DO THAT TYPE OF ANALYSIS THAT YOU SAY
THAT YOU MIGHT HAVE DONE HAD YOU THOUGHT OF IT?
A. OH, YES, MA'AM. THAT IS CORRECT---
Q. THEY'RE GONE?
A. ---THEY'RE GONE.
Q. THEY'RE GONE. ALL RIGHT. DID ANYONE SUGGEST TO
YOU THAT YOU MIGHT HAVE DONE IT DIFFERENTLY?
A. AT THE TIME THAT I WAS SAMPLING?
Q. WELL, NO. I ASSUME THEY DID NOT DO IT THEN, DID
THEY?
A. NO, THAT'S CORRECT.
Q. HAS ANYONE SUGGESTED TO YOU SINCE THEN, THAT YOU
MIGHT HAVE DONE IT?
A. YES.
Q. WHO WAS THAT?
A. DR. CRAFT. AND I BELIEVE WE HAVE DISCUSSED IT
WITH DR. VYMAZAL, AS WELL, BUT HE WAS PROBABLY
JUST LISTENING.
Q. OKAY. DID YOU EVER DISCUSS IT WITH DR.
RICHARDSON?
A. NOT TO MY RECOLLECTION.
Q. IS DR. RICHARDSON GONE A GREAT DEAL; IS THAT WHAT
I'M TO IMPLY FROM SOME OF THESE?
MS. SUTTER PAGE 45
A. YES.
Q. OKAY.
A. I DON'T KNOW IF GONE IS THE RIGHT WORD. HE HAS A
GREAT AMOUNT OF RESPONSIBILITIES.
Q. OKAY. WHAT DO THOSE INCLUDE?
A. HE JUST -- HE TEACHES---
Q. OKAY.
A. ---HE'S DIRECTOR OF THE WETLANDS CENTER.
Q. OKAY.
A. HE'S INVOLVED IN THIS PROJECT. I SUSPECT HE'S
INVOLVED IN TRYING TO FURTHER THE WETLANDS CENTER
THROUGH TIME.
Q. OKAY. HOW MANY CLASSES -- DO YOU KNOW HOW MANY HE
TEACHES?
A. I DO NOT.
Q. OKAY. DID YOU EVER STUDY UNDER HIM IN A CLASS?
A. YES, I DID.
Q. OKAY. WHAT DID YOU TAKE FROM DR. RICHARDSON?
A. I TOOK A CLASS CALLED "APPLIED ECOLOGY."
Q. UH-HUH (YES).
A. AND I TOOK A CLASS CALLED "WETLANDS ECOLOGY AND
MANAGEMENT," AND I TOOK A WETLANDS SEMINAR UNDER
HIM.
Q. A WHAT?
MS. SUTTER PAGE 46
A. A WETLANDS SEMINAR WHERE THE PARTICIPANTS PRESENT
INFORMATION.
Q. OKAY. DOES THE WETLANDS CENTER HAVE OTHER ONGOING
PROJECTS, OTHER THAN THIS EVERGLADES RESEARCH?
A. YES, THEY DO.
Q. WHAT ARE THEY?
A. THE WETLANDS CENTER HAS RECENTLY ACQUIRED LAND IN
NORTH CAROLINA THAT THEY ARE TRYING TO INVENTORY.
I WOULD BE THE WRONG PERSON TO ASK WHAT ALL THEY
DO. I KNOW THAT THEY ARE INVOLVED IN THAT
PROJECT. THEY MAY HAVE OTHER SMALLER PROJECTS.
BUT, BY FAR, THIS IS THE LARGEST.
Q. DO THEY ACTUALLY OWN THE LAND?
A. I DON'T BELIEVE THEY DO. I DON'T KNOW.
Q. OKAY. SO, WHEN YOU SAY THEY ACQUIRED LAND, THEY
ACQUIRED SOME KIND OF AN INTEREST IN THE LAND, BUT
YOU'RE NOT SURE WHAT IT IS?
A. THAT'S CORRECT.
Q. OKAY. AND WHAT ARE THEY GOING TO INVENTORY IT
FOR?
A. I DON'T KNOW. I BELIEVE THERE'S JUST AN INVENTORY
ONGOING RIGHT NOW.
Q. OF WETLANDS, OR TYPES OF WETLANDS OR HABITATS?
A. RIGHT, ALL OF -- ALL OF THOSE.
MS. SUTTER PAGE 47
Q. OKAY.
A. WATER QUALITY PERHAPS, WHAT SOILS ARE PRESENT.
Q. OKAY. CAN YOU IDENTIFY SUTTER EXHIBIT NUMBER
SEVENTEEN FOR US, PLEASE?
A. NUMBER SEVENTEEN IS A TIMETABLE I CAME UP WITH
EARLY ON IN THE STUDY JUST TELLING ME THAT ON
MONDAY I NEEDED TO DO WHAT, AND THROUGH EACH DAY
OF THE WEEK.
Q. DID YOU PRETTY MUCH FOLLOW THIS?
A. YES, I DID.
Q. OKAY. SUTTER EXHIBIT -- COMPOSITE EXHIBIT NUMBER
EIGHTEEN IS WHAT?
A. THIS IS MY EXPERIMENTAL DESIGN, INCLUDING MY
PROPOSAL FOR STUDY THAT I HAD TO SUBMIT TO THE
SCHOOL FOR MY MASTER'S WORK, ANOTHER COPY OF THE
EXPERIMENTAL DESIGN.
Q. IS THIS ONE PRETTY ACCURATE, MS. SUTTER, AS TO
WHAT YOU ACTUALLY DID?
A. IS THE PROPOSAL ACCURATE?
Q. RIGHT. DID YOU ACTUALLY -- IS THE EXPERIMENTAL
DESIGN ACCURATE, OR DID YOU ALTER IT---
A. THAT HAS---
Q. ---SUBSEQUENT TO THIS?
A. ---THAT HAS STAYED THE SAME.
MS. SUTTER PAGE 48
Q. OKAY.
A. AND THEN IT JUST, FOR MY RECORDS, TELLS ME WHICH
PLANTS AND WHICH PLANT CONTAINERS WERE PLACED IN
WHICH TUBS, SO THAT I WOULD KNOW WHICH NUMBERS TO
PUT INTO WHICH TREATMENTS.
Q. OKAY.
A. AND THEN IT'S JUST MORE TIME LINES AND ORDERING
INFORMATION FOR ANY---
Q. ALL RIGHT.
A. ---ANY MATERIALS I NEEDED.
Q. ALL RIGHT. SUTTER COMPOSITE EXHIBIT NUMBER
NINETEEN?
A. NUMBER NINETEEN IS WHAT I HAVE CALLED
"VEGETATION." IT BASICALLY HAS RAW DATA FOR
MEASUREMENTS THAT I MADE ON VEGETATION PRIOR TO
TREATMENT.
Q. OKAY. SUTTER COMPOSITE EXHIBIT NUMBER TWENTY?
A. IT'S WHAT I HAVE LABELED "SOILS." AND, AGAIN,
IT'S THE NUTRIENT CONCENTRATIONS AND CONTENTS OF
MY SOILS.
Q. IS THAT PRETTY MUCH WHAT THE WHOLE DOCUMENT IS?
A. YES. IT'S ALL SOILS IN THIS SECTION.
Q. ALL RIGHT. YOU'VE PRODUCED SOME DISKS HERE TODAY,
SOME FOUR DISKS IN RESPONSE TO THE NOTICE DUCES
MS. SUTTER PAGE 49
TECUM. IS YOUR DATA, TO THE BEST OF YOUR
RECOLLECTION, REFLECTED IN THIS HARD COPY THAT'S
REFLECTED ON THOSE DISKS?
A. YES, TO THE BEST---
Q. IS THERE ANY -- GO AHEAD. I'M SORRY.
A. ---TO THE BEST OF MY KNOWLEDGE, IT IS.
Q. OKAY. IS THERE ANY OTHER INFORMATION ON THOSE
DISKS?
A. MY DOCUMENT IS ON ONE DISK IN ITS ENTIRETY.
Q. OKAY.
A. THERE ARE DATA SETS IN THERE WHEN I WAS TRYING TO
MANIPULATE THEM TO DUMP INTO A STATISTICAL
ANALYSIS PROGRAM, BUT DIDN'T QUITE WORK. THOSE
ARE PROBABLY STILL ON THERE.
Q. OKAY. THEN I DON'T THINK WE'RE GOING TO REQUIRE
COPIES AT THIS TIME OF THOSE HARD DISKS. SUTTER
COMPOSITE EXHIBIT NUMBER TWENTY-ONE, PLEASE?
A. THIS IS THE SECTION I ENTITLED "WATER." IT HAS A
METHOD FOR HOW TO DETERMINE PHOSPHATE IN WATERS,
AND HOW TO -- HOW TO OBTAIN THE STANDARDS, AND
THEN WEEKLY MEASUREMENTS OF WHAT MY WATER
PHOSPHATE CONCENTRATIONS WERE, AND THEN WHAT I HAD
TO ADD TO GET THEM BACK UP, OR WHAT I HAD TO
DILUTE THEM WITH TO BRING THEM BACK DOWN TO THEIR
MS. SUTTER PAGE 50
RESPECTIVE TREATMENTS. I, ALSO IN THE REAR OF
THIS DOCUMENT, HAVE COPIES OF DR. QUALLS' WATER
QUALITY SAMPLING FROM EARLY ON IN THE PROJECT OF
WHAT WAS FOUND IN THE EVERGLADES, SO IT WAS NOT
USED IN MY STUDY.
Q. OKAY. WHY DID YOU INCLUDE IT IN YOUR GREENHOUSE
EXPERIMENT DOCUMENTS? WAS IT OF INTEREST TO YOU
IN HOW YOU WOULD SET UP YOUR DESIGN?
A. IT WAS OF INTEREST TO ME EARLY ON, YES.
Q. THEN IMPLICITLY YOU DISCARDED IT?
A. I DON'T THINK I UNDERSTAND THE QUESTION.
Q. WELL, YOU SAID IT WAS OF INTEREST EARLY ON, BUT
YOU DID NOT USE THIS IN YOUR DESIGN. IS THAT
ACCURATE?
A. I GUESS THAT'S NOT -- I WANTED TO FIND OUT WHICH
SALTS OR WHICH METHODS PHOSPHATE WOULD BE ADDED IN
MOST APPROPRIATELY. I FOUND THAT INFORMATION AND
THESE DOCUMENTS WERE NOT USED AGAIN. HOWEVER, I
WANTED TO KEEP THEM FOR MY RECORDS.
Q. ALL RIGHT. IT HELPED YOU MAKE YOUR DECISION FOR
THE SODIUM PHOSPHATE?
A. YES.
Q. IS THAT ACCURATE?
A. THAT'S CORRECT.
MS. SUTTER PAGE 51
Q. ALL RIGHT, ON SUTTER COMPOSITE EXHIBIT NUMBER
TWENTY-TWO?
A. THIS IS LABELED p-H AND D-O. THESE WERE
MEASUREMENTS OF pH AND DISSOLVED OXYGEN THAT
I TOOK IN MY GREENHOUSE EVERY WEEK WHEN I
MEASURED.
Q. OKAY.
A. I DID NOT USE THEM IN MY FINAL ANALYSIS.
Q. ALL RIGHT. AND SUTTER COMPOSITE EXHIBIT NUMBER
TWENTY-THREE?
A. THIS IS JUST A SECTION I HAVE LABELED
"CORRESPONDENCE." IT IS LETTERS TO FERTILIZER
COMPANIES IN FLORIDA WHEN I WAS LEARNING ABOUT
WHICH KIND OF FERTILIZER TO USE, WHAT WOULD BE THE
BEST. AND, AGAIN, IT'S MOSTLY JUST THEIR
BROCHURES THAT THEY SENT TO ME.
Q. WHAT DID YOU END UP USING?
A. SEMINOLE FERTILIZER SUPPLIED MY SAWGRASS PLANTS.
Q. RIGHT.
A. I DID NOT -- I DIDN'T USE ANY OF THE -- OF THE
FERTILIZER INFORMATION. I JUST -- IT WAS JUST FOR
MY KNOWLEDGE---
Q. OKAY.
A. ---OF WHAT WAS GOING ON.
MS. SUTTER PAGE 52
Q. OKAY. THEN THERE'S TWO DOCUMENTS AT THE END.
SUTTER EXHIBIT NUMBER TWENTY-FOUR IS WHAT?
A. THIS IS A METHODS PAPER FOR HOW TO DETERMINE TOTAL
PHOSPHORUS IN SOILS. THIS IS THE METHOD THAT I
FOLLOWED IN MY STUDY.
Q. THIS IS THE METHOD YOU FOLLOWED?
A. YES, IT IS.
Q. ALL RIGHT. AND I SEE CRAFT IS WRITTEN --
HANDWRITTEN. DID IT COME FROM DR. CRAFT?
A. DR. CRAFT -- I COPIED DR. CRAFT'S COPY FOR MY
FILES.
Q. OKAY. ALL RIGHT. AND THE FINAL DOCUMENT?