E-FILED
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Jul 17, 2014 11:23 AM
David H. Yamasaki
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Michael Millen
Attorney at Law (#151731)
119 Calle Marguerita Ste. 100
Los Gatos, CA 95032
Telephone: (408) 871-0777
Fax: (408) 866-7480
email: MikeMillen@aol.com
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Attorney for Plaintiff
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Chief Executive Officer/Clerk
Superior Court of CA, County of Santa Clara
Case #1-10-CV-172614 Filing #G-64528
By R. Walker, Deputy
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SUPERIOR COURT OF CALFORNIA
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COUNTY OF SANTA CLARA
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FORREST HUFF,
Plaintiff,
v.
SECURITAS SECURITY SERVICES USA, INC.,
and DOES 1 TO 50,
Defendants.
NO.: 110CV172614
SUPPLEMENTAL DECLARATION
OF MICHAEL MILLEN, ESQ. IN
SUPPORT OF PLAINTIFF’S
OPPOSITION TO DEFENDANT’S
MOTION FOR PROTECTIVE
ORDER
Date: August 1, 2014
Time: 9:00 a.m.
Judge: Kirwan
Dept.: 1
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Michael Millen, Esq.
119 Calle Marguerita #100
Los Gatos, CA 95032
(408) 871-0777
SUPP. DECL. OF MICHAEL MILLEN, ESQ. IN SUPPORT
OF P’S OPPO. TO D’S MOT. FOR PROT. ORDER
110CV172614
E-FILED: Jul 17, 2014 11:23 AM, Superior Court of CA, County of Santa Clara, Case #1-10-CV-172614 Filing #G-64528
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I, Michael Millen, Esq., hereby declare:
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1. I am licensed attorney and represent plaintiff in this proceeding.
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2. On July 15, 2014, I attended and asked questions at the deposition of Beth Hansen, Vice
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President of Information Technology for defendant Securitas Security Services USA, Inc.
3. A court reporter transcribed the deposition and I purchased a copy of the transcript from
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her. True and correct copies of excerpts of the certified transcript she transmitted to me are
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attached hereto as Exhibit A.
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4. In regard to the Worked Hours reports, Ms. Hansen stated the following:
a. An employee can generate a Worked Hours report by entering a query into SUSA’s
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SAFES computer system. This is done by going to the proper screen, entering a date range,
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selecting the employee of interest from a drop-down menu, and then hitting a button to run the
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report. (Depo 59:21-60:21; 64:19-65:4.)
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b. One person could print 57 Worked Hours reports in less than an hour if they used any
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one of several techniques, such as (1) having multiple terminals next to each other, (2) opening
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multiple instances of the Citrix communication protocol (Depo 13:13-19), or (3) getting help from
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someone else who logged in as them. (Depo 84:2-24.)
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c. A person who wanted to rapidly print out 10 Worked Hours reports in succession
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could do so by logging in to the system on multiple PC’s stationed next to each other (65:19-25.)
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In theory, ten laptops could be set up on a long table and the employee could go from machine to
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machine to enter queries but the infrastructure group would need to confirm whether there are any
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system limitations. (Depo. 66:13-67:19.)
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d. Ms. Hansen’s declaration ¶6, in which she says that printing out 42,000 worked hours
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reports would take 21,000 hours (30 min. each), did not take into account that one person could run
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multiple reports at once (Depo. 119:10-121:19)
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e. After a Worked Hours report is run, the results can be delivered in a computer PDF
file instead of being printed. (Depo. 136:9-137:6.)
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Michael Millen, Esq.
119 Calle Marguerita #100
Los Gatos, CA 95032
(408) 871-0777
SUPP. DECL. OF MICHAEL MILLEN, ESQ. IN SUPPORT
OF P’S OPPO. TO D’S MOT. FOR PROT. ORDER
110CV172614
Page 1
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f. The “Run” information in the upper-left corner of each Worked Hours report shows
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either the time the report was “kicked out” by the computer system or the time that it was printed.
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(Depo. 79:16-80:1.)
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g. The “Printed By” notation at the bottom of the Worked Hours report is the name of
the person who printed the report. (Depo. 80:16-81:17.)
5. In regard to Friday / Saturday work history information, Ms. Hansen stated the
following:
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a. Reports currently exist which will show the hours an employee worked each calendar
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day. By paging through the reports one could then determine the Fridays and Saturdays worked.
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(Depo. 121:20-122:15)
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b. The “specific question” Ms. Hansen was answering in her declaration relating to this
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Friday/Saturday issue was “is there a report that has Fridays and Saturdays?”, and not “whether you
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could run another reports [sic] and look through it for Fridays and Saturdays” such as a with a
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schedule. (Depo 122:20-123:9.)
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c. Ms. Hansen recalls that SAFES has a scheduling report which lists the calendar days
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an employee worked (Depo. 123:4-20) but she admitted that she “do[es]n’t have enough
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recollection or knowledge about reports which show particular days that were worked to really
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comment upon what would be feasible or not feasible to print out at this point in time.” (Depo.
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124:1-7)
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d. Ms. Hansen’s estimate of 480 hours to design, produce, and implement a brand new
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Friday/Saturday-only report was a premature estimate because she was not provided with “clear
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specs” and a chance to go over this with her team. (Depo. 124:8-125:4; 128:15-129:7.)
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6. Ms. Hansen readily described the process she would use to generate two comprehensive
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employee lists for each branch (one with employees who worked between May 21, 2009 and July
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15, 2010, and one with those worked from July 16, 2010, to the present). (Depo. 87:4-89:15.)
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Michael Millen, Esq.
119 Calle Marguerita #100
Los Gatos, CA 95032
(408) 871-0777
SUPP. DECL. OF MICHAEL MILLEN, ESQ. IN SUPPORT
OF P’S OPPO. TO D’S MOT. FOR PROT. ORDER
110CV172614
Page 2
E-FILED: Jul 17, 2014 11:23 AM, Superior Court of CA, County of Santa Clara, Case #1-10-CV-172614 Filing #G-64528
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VERIFICATION
I know the contents of the above declaration and declare under penalty of perjury
under the laws of the State of California that the foregoing is true and correct.
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Dated: July 17, 2014
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MICHAEL MILLEN
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Michael Millen, Esq.
119 Calle Marguerita #100
Los Gatos, CA 95032
(408) 871-0777
SUPP. DECL. OF MICHAEL MILLEN, ESQ. IN SUPPORT
OF P’S OPPO. TO D’S MOT. FOR PROT. ORDER
110CV172614
Page 3
E-FILED: Jul 17, 2014 11:23 AM, Superior Court of CA, County of Santa Clara, Case #1-10-CV-172614 Filing #G-64528
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
FORREST HUFF,
)
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Plaintiff,
)
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vs.
)
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SECURITAS SECURITY SERVICES
)
USA, INC., AND DOES 1 TO 50,
)
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Defendants.
)
_______________________________)
Case No. 110CV172614
DEPOSITION OF BETH HANSEN
Sherman Oaks, California
Tuesday, July 15, 2014
10:55 A.M. - 2:45 P.M.
BY:
JANNEA MCCLURE
CSR NO. 13718
Ex. A
IMBER COURT REPORTERS, INC.
E-FILED: Jul 17, 2014 11:23 AM, Superior Court of CA, County of Santa Clara, Case #1-10-CV-172614 Filing #G-64528
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SHERMAN OAKS, CALIFORNIA; TUESDAY, JULY 15, 2014
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10:55 A.M. - 2:45 P.M.
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BETH HANSEN,
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having solemnly stated to tell the truth,
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was examined and testified as follows:
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EXAMINATION
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BY MR. MILLEN:
Q.
Could you please state your name and spell
your last name.
A.
Beth Hansen.
I'll actually spell Beth too.
B-E-T-H, H-A-N-S-E-N.
Q.
Thank you.
Ms. Hansen, my name is Michael
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Millen.
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former employee of Securitas named Forrest Huff.
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here today to ask you some questions about computer
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systems, reports, the SAFES system, and other various
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IT matters related to Securitas Security --
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Securitas -- well, whatever the name is of this "SUSA"
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organization that we call Securitas.
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I am an attorney, and I am representing a
I'm
Have you ever had your deposition taken
before?
A.
Yes.
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A.
So they're in our computer room, and Citrix
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controls the access into -- particularly SAFES -- but
3
into SAFES.
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computer room, but SAFES is accessed by the field
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offices to run their offices.
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So SAFES is actually sitting in the same
And PeopleSoft -- SAFES used to be a
7
different type of system, and it was actually in
8
offices, and it had to -- back in the old days -- dial
9
up.
Now it's just sitting in the same room, and then
10
when it's ready to send information, it uses -- I
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think it's using FTP.
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transmits the data across the room into PeopleSoft.
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Q.
Okay.
It just kind of, like,
So let me see if I understand this.
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user who wants to access data which is inside of the
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SAFES system uses their PC to log in to your data
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center's Citrix system?
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A.
Well, Citrix is really more -- we look at it
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they log into SAFES, but they're using Citrix as the
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communication protocol.
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Q.
A
But I mean -- let me see here.
Citrix -- if
21
I understand, Citrix is kind of like a virtual desktop
22
that it sets up for a user?
23
what Citrix is?
24
25
A.
Is that a fair way to put
I'm not sure if that's the right terminology,
and I'm not super technical on the hardware end of it,
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answering requests for information.
Q.
Is this something that happens with some
3
regularity -- that field offices ask your group to
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come up -- to create a new report that they can access
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on the SAFES system?
6
A.
The field offices don't really ask for a lot
7
of new reports, and we're working on a set of
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projects.
9
not do it unless it was something deemed to be needed
So if one office wanted something, we might
10
by many because there's a cost benefit to every
11
request or every change we make on our systems.
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13
Q.
Understood.
To your knowledge, has anyone in
your organization -- excuse me.
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Has anyone who works for Securitas ever
15
directed a request to your organization inside
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Securitas that some sort of automated report system be
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made that could do multiple reports at once from a
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SAFES report instead of having to run each report and
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then run the next report?
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A.
No.
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Q.
So as an example, let's take the one report
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that I'm familiar with, which is called the "worked
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hours report."
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You know this report?
A.
Yes, I know this report.
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Q.
Okay.
I figured.
My understanding is this
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report is run by a person, logs into the SAFES system
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and some sort of a query screen comes up where the
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employee information is entered and a date range; is
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that true?
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A.
I think so.
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Q.
And do you know is it an employee name or
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employee number?
A.
I believe that there's a drop-down.
I don't
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know that they can actually enter the name or number
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directly.
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to select it.
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Q.
I think there's a drop-down, and you have
That's how I've seen it run.
So when you've seen worked hours run, what
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you've seen is there's a drop-down menu that has every
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single employee?
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one or the other?
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A.
Or do you mean you choose between
Maybe I didn't --
That would depend on your access.
So if you
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only have access to a certain department, it would
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just show the employees in that department.
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have access to the whole system, it would potentially
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show every employee.
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Q.
If you
But if you have access to the whole system
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and you click on a drop-down and there's 15,000 names
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on there, how would you ever select one?
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A.
There's only a few people that have access to
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the PC would actually automatically be able to
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manipulate things on the screen with Citrix never even
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knowing?
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6
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A.
I've never heard of anything like that; so I
wouldn't know.
Q.
Okay.
Fair enough.
Now, after the report is
made -- well, first, let me go over this.
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Would it be fair to say that choosing which
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report to run just takes a matter of seconds because
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it's simply a matter of drop-down menu, time period
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selection, and you're done with all the data entry to
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get the report?
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Is that fair to say?
MS. SHAVIT:
Objection.
Overbroad.
Incomplete hypothetical.
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THE WITNESS:
I'm not sure how many menus
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they have to go through to get to that report.
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they might have to make a few menu selections.
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BY MR. MILLEN:
19
Q.
Okay.
So
But after making a few menu
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selections, when the report itself comes up, the only
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thing that our worker needs to put in in order to
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generate a worked hours report is selection from the
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drop-down plus the time periods?
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A.
I believe that's all he has to put in.
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Q.
Okay.
Then at that point what button is on
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the screen that basically commits that query to cause
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the computer to start generating a file -- a report?
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4
A.
I'm not sure what the button says, but they
basically hit something to run the report.
5
Q.
Okay.
Now, when that happens, does the user
6
have to stay in front of the machine, or can the
7
report run without the user doing anything else?
8
9
A.
The report runs, and then it comes back to
them, and I think they then have a choice of printing
10
it to a printer or to a PDF.
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can run them to the screen; so I'm not sure if that's
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one.
Some of the reports you
They might have a choice.
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Q.
To do that as well?
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A.
Right.
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Q.
Okay.
So tell me -- so after this okay or
16
commit button is hit and the query is sent, what --
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can the employee now type in the next query?
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A.
No.
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Q.
Okay.
They have to wait.
So if an employee had -- so if
20
somebody wanted to run ten reports in rapid
21
succession, how would they do it -- ten worked hour
22
reports in rapid succession?
23
A.
They would run one at a time.
They could log
24
on multiple -- if they that had more than one PC, they
25
could log onto more than one PC.
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Q.
Can one PC allow another Citrix login?
2
A.
I don't know.
3
Q.
So as I understand it, your testimony is
4
you're unsure whether one desktop PC can have multiple
5
instances of the Citrix system running at the same
6
time?
7
A.
Yeah, I'm not sure.
8
Q.
To your knowledge, is there anything in the
9
10
11
12
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Citrix system which prevents someone from logging in
from two different computer systems at the same time?
A.
I'm not sure, but I don't think it prevents
that.
Q.
Okay.
So if I understand it correctly, it
14
would be, in theory, possible to set up ten laptops on
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our long -- this is probably a 20-foot table in this
16
room.
17
logged into a Citrix system, and then one could go to
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the first laptop, enter the query, commit it, then go
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to the next laptop, enter the query, hit commit all
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the way down the line.
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One could set up ten laptops.
Each one is
And in each instance the machine would
22
eventually, after time passed, generate the report,
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and a box would come up saying "Where would you like
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the report delivered?"
25
A.
Correct.
I don't know if there's a limit on
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2
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how many you can set up, but yes.
Q.
Who would know if there's a limit in your
organization?
4
A.
Our Infrastructure group.
5
Q.
I don't think that was a group we talked
6
about, but maybe that's because there's no programmers
7
in it?
8
A.
Right.
9
Q.
Okay.
10
So there's a group called the
Infrastructure group.
11
And would it be safe to say that, if there
12
was some limit, the Infrastructure group knows how to
13
grant an exception if it was specially requested to
14
that?
15
A.
The limit might -- there may be a hard limit
16
depending on number of licenses, or there also -- you
17
could also exceed if you have two many queries going
18
against the database at the same time.
19
down the system.
20
Q.
You said too many queries?
21
A.
Queries.
22
23
24
25
You could slow
Because each one of those executes
a query.
Q.
Are there certain times -- that is what I
wanted to ask.
Is there a certain time when the system is
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Huff 0820."
2
I'll just point for you.
3
that a Bates number; so the first page is 820.
4
look to the right, that's 821.
5
the page, you'll see -- so 820, 821 -- if you flip the
6
page -- can I have you flip it for me -- 822, 823, and
7
on and on it goes until, if you turn to the very last
8
page, it goes to 970.
9
10
And do you see at the bottom -- yeah,
Yeah, there you go.
We call
If you
If you kind of flip
So this is every page your attorneys gave me
that were Bates-stamped 820 to 970.
11
A.
Okay.
12
Q.
Now, do these appear to be the worked hour
13
reports which your SAFES system is capable of
14
producing?
15
A.
Yes.
16
Q.
All right.
Now, let me ask you several
17
questions about this.
18
corner on this very first page, do you see where it
19
says "Run 11 slash 01 slash 2011 space 2:32 p.m."?
First, in the upper left-hand
20
A.
Yes.
21
Q.
What does that mean when a worked hours
22
report says that in the upper left corner next to
23
"run"?
24
A.
25
I believe that's either when the report
kicked out off or when it was printed.
I'm not sure
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which.
2
Q.
Okay.
Now, at the very bottom of this first
3
report on the left side of the first page of
4
Exhibit 6, which is Bates 820, do you see almost near
5
the very bottom it says "Printed by Burden, comma,
6
Matthew A?"
7
A.
Uh-huh, yes.
8
Q.
Okay.
9
10
And if you look on the right-hand
side, does this appear to be the second page of the
same report on the same employee?
11
A.
Yes.
12
Q.
And in fact, if you flip the page over and
There's one of four and two of four.
13
look on the back side, again, do you see pages 3 and 4
14
of the same report?
15
A.
Yes.
16
Q.
Okay.
Now, I note on the bottom of each page
17
in the same area it says "Printed by Burden, comma,
18
Matthew A."
19
20
21
22
23
What does it signify that there was a name
next to the phrase "printed by"?
A.
I would think that that's the person that
printed it.
Q.
Okay.
Is it normal that reports have the
24
name on them of a person who logged in to run the
25
query?
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MS. SHAVIT:
2
THE WITNESS:
Objection.
3
it on all reports so --
4
BY MR. MILLEN:
Overbroad.
I don't know.
I haven't seen
5
Q.
But you've seen it on some reports?
6
A.
No.
7
Q.
Say that again?
8
A.
I haven't really noted it before.
9
Q.
It could have been, you just didn't see it?
10
A.
Yeah.
11
Q.
Okay.
I haven't really noted it before.
But would you say that, under the
12
normal course of things -- and like I said, I will
13
represent that this is an undoctored work hours report
14
from your attorneys -- that more likely than not, the
15
name next to "printed by" is the name of the person
16
who logged in to print it?
17
A.
I would think so.
18
Q.
Okay.
Now, I will represent to you -- and
19
during the break, you and your attorney are free to
20
look -- that everything single page of Exhibit 6 at
21
the very bottom says "Printed by Burden, Matthew A."
22
Every -- the left side of every page, the right side
23
of every page, and the back side of every page.
24
all is printed by the this person named apparently
25
Matthew Burden.
It
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BY MR. MILLEN:
Q.
Okay.
So you see how it starts at 2:32 p.m.
3
on the first page and the last page is 3:22 p.m. on
4
the very back of the last page?
5
A.
Yes.
6
Q.
Okay.
Now, can you tell me how one person,
7
Matthew Burden, was able to print out 57 of these
8
reports that we've just seen here in less than one
9
hour?
10
11
MS. SHAVIT:
speculation.
12
Objection.
Calls for
Assumes facts not in evidence.
THE WITNESS:
Yeah, I'm not sure.
I don't
13
know if he ran them off of multiple terminals or if --
14
BY MR. MILLEN:
15
Q.
So one way he could do reports with this
16
speed would be to have multiple terminals next to each
17
other like we talked about?
18
A.
Yes.
19
Q.
Okay.
20
21
And another way would be to have
multiple instances of Citrix open, if that's possible?
A.
Right.
And although it's highly discouraged,
22
someone could have -- he could have had somebody
23
logging in as him and kicking off some as well.
24
don't know.
25
Q.
I
I wasn't there.
Okay.
I understand.
All right.
Now, if
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Incomplete hypothetical.
2
3
4
THE WITNESS:
I don't know, to be honest.
BY MR. MILLEN:
Q.
Okay.
All right.
Now, I'd like to kind of
5
shift our discussion now to the present period of
6
time.
7
and you've already saw one order from a judge -- but
8
assumes there's a new order that comes out in a few
9
weeks from now, say, on August 1st of 2014.
Let's assume that the judge enters an order --
10
And the order asks you to generate two lists
11
of employees as to each branch.
12
employees who at least worked one day between May 21,
13
2009 and July 15th, 2010; and the other list is an
14
employee who worked at least one day between
15
July 16th, 2010 to the present.
16
two lists -- pre-July 15, post-July 15.
17
18
19
One list should be
So for every branch,
How would you generate such a list for each
branch?
A.
I would talk the -- well, I would go and talk
20
to the SAFES programmers, and I would ask them if they
21
could generate -- and I would ask them for a time
22
estimate.
23
that worked on a certain branch that worked a day, I
24
would ask my PeopleSoft programmers the same thing.
25
And since you're just looking for everybody
Because if you're just asking for a week time
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period, then you don't really care about a particular
2
day; so I would just see if they worked within any of
3
the pay periods.
4
pay detail.
5
Q.
I would go off of the check -- the
Would it be safe to say that that query --
6
what level of complexity is that query that you just
7
talked about?
8
9
A.
I'm not sure about the SAFES because I have
never programmed in SAFES; so I have to rely on what
10
they tell me.
11
much complex as it is time consuming because they have
12
to go through the check detail files, and those are
13
the files that we save off quarterly.
14
On the PeopleSoft side, it's not as
So they basically have to write a program
15
that goes through the file, and then they usually
16
create a staging table, and then they start putting a
17
person's name.
18
in a check date, you know, when the person was paid.
19
If you only want to know that the person was paid, as
20
soon as they get a hit, they would probably stop
21
looking for that person, or they would just create a
22
file of all the check dates.
23
And usually what I have them do is put
But it would be time consuming because they'd
24
have to go through each quarterly file.
25
on the time period you're asking for, there would be a
So depending
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quarterly file for, you know -- so if it's a year,
2
they'd have to search through four files.
3
Q.
And if we want to go back to May of 2009,
4
that would be about 20, 22, something like that?
5
Maybe 22 files you would have to look at?
6
A.
Right.
So they would put the date into a
7
staging table, and then they would either produce a
8
file or a report off of it.
9
Q.
Could that particular list we just talked
10
about be generated as some sort of a text delimited
11
file?
12
A.
Yes.
13
Q.
Because when the programmers are doing it,
14
you have some flexibility versus on the SAFES screen
15
where it's set to be what it is?
16
A.
17
way it is.
18
and it wasn't set up to produce like so.
19
Q.
Right.
The SAFES is just set.
This is the
And it wasn't set -- it's an older system,
Understood.
Understood.
Okay.
Now, let's
20
assume that, from that, we wind up with these lists of
21
employees who worked at least a day, and now you are
22
given a new list.
23
Oh, by the way, that list -- when you say
24
employee name, you can also easily put an employee
25
number?
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take a look at that.
2
to look at.
That is the next thing I wanted
3
MR. MILLEN:
4
(Exhibit 7 marked)
5
6
BY MR. MILLEN:
Q.
7
8
So 7 is the next one.
All right.
So this is Exhibit 7.
Do you recognize this as the declaration you
signed a few weeks ago for this case?
9
A.
Yes.
10
Q.
Okay.
Now, couple questions.
Let's go ahead
11
and start -- let me ask you about paragraph 6.
12
paragraph 6 you said that, to do 42,000 worked hours
13
reports for current and former employees, you
14
estimated a project would take about 21,000 man hours.
15
In
Now, would you say that, since one person
16
could run multiple queries in a half hour using some
17
of the techniques we've discussed, that probably
18
that's -- it could be done faster than that?
19
20
MS. SHAVIT:
Objection.
Calls for
speculation.
21
THE WITNESS:
I don't really know because I
22
wasn't thinking of that at the time I gave this
23
estimate and -- so I'm not really sure.
24
BY MR. MILLEN:
25
Q.
So would it be safe to say, Ms. Hansen, that
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at the time you gave this estimate, you were simply
2
thinking of idea of one person enters a query, they're
3
no longer able to use their machine because the system
4
is going through all the records, and that they will
5
not have access again to their machine until about a
6
half hour when it's gone through all the records and
7
made the report?
8
A.
Correct.
9
Q.
Okay.
But you'd agree, during the time that
10
a report is running, an employee is free to do other
11
tasks if they so choose?
12
13
MS. SHAVIT:
Objection.
Overbroad.
Calls
for speculation.
14
THE WITNESS:
It would depend on if they're
15
good at multitasking.
I mean, some employees may be
16
able to do other things, but a lot of times if I'm
17
doing something important, and I try to do more than
18
one thing at a time, you know, then I forget where I
19
am.
20
BY MR. MILLEN:
21
Q.
Well, let me ask you this --
22
A.
I didn't put that kind of thought into this.
23
I just was asked, if you had to produce this many
24
reports, how long would it take.
25
Q.
But you'd agree that an employee -- that a
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typical employee could do more than simply stare at
2
the screen for a half hour while the computer is out
3
gathering all these records?
4
A.
I'd agree that they could probably do
5
something else during that timeframe unless they were
6
dedicating that time period to -- you know, they came
7
in overtime or something to run the reports.
8
that's probably what they would be doing.
9
Q.
I understand.
Then
What I mean is is that -- how
10
can I put this?
11
walking a dog, if your job is to walk the dog, it
12
doesn't really matter what the dog is doing.
13
pretty much -- about all you can do is walk the dog as
14
you're walking the dog.
15
walk yourself, dog, and I'll be" -- you walk the dog.
16
But when an employee is running one of these
What I'm saying is this.
When you're
You
You can't just, you know, "Go
17
reports, they are not at tethered to the computer --
18
is that fair to say?
19
A.
That's fair to say.
20
Q.
Okay.
All right.
Now, let me ask you about
21
paragraph 7 on page 3.
22
mention in Exhibit 7, page 3, paragraph 7 is "SUSA
23
does not currently have a report that shows all
24
Fridays and Saturdays when each employee worked."
25
Now, the first sentence you
And if I recall -- let me stop on that
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sentence -- but if I recall the rest of your testimony
2
you've given today, there may be reports which
3
generate some aspect of Friday, Saturday information,
4
but you can't remember exactly which reports and what
5
they show?
6
A.
Correct.
I think there's reports that will
7
print, you know, so it would have your name on it and
8
the hours you worked across days.
9
confirmed time report displays that, but it doesn't
I think the
10
just -- you can't -- I don't think you can run it and
11
say "Just show me the weeks that they worked Friday
12
and Saturday."
13
know, page through the reports.
14
asked is if there's a report that shows Fridays and
15
Saturdays --
16
It would take a human to then, you
MS. SHAVIT:
The question I was
Well, hold on, hold on, hold on.
17
Don't talk about any discussions that you've had with
18
an attorney, please.
19
BY MR. MILLEN:
20
Q.
Okay.
21
A.
Well, I was asked to give an estimate.
So --
22
that's how I read it.
23
has Fridays and Saturdays?
So
Like, is there a report that
24
Q.
I understand.
25
A.
That was the specific question I was
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answering.
2
and look through it for Fridays and Saturdays, that
3
would be a different topic.
4
Q.
So whether you could run another reports
So do you think it would be feasible -- let's
5
say -- so we run Employee Smith, and it has all the
6
days -- all the calendar days that Employee Smith
7
worked.
8
That's a report you believe can be made?
9
A.
I think it prints it like a schedule.
10
Q.
For multiple months?
11
A.
I wouldn't know if you could run that for a
12
longer time period or if you have to run it pay period
13
by pay period.
14
reports you can put a beginning and end date in it.
15
Some reports you can only run them for certain pay end
16
date.
17
I'm not sure of that.
A lot of the
Some reports you can -- we've limited them or
18
you can only run them for, like, a quarter or a year
19
so that we don't have what they call runaway queries,
20
where, you know --
21
Q.
I see.
22
A.
Yes.
23
24
25
Goes back to the dawn of time.
So I don't run that report; so I don't
remember what the parameters are for that report.
Q.
Okay.
So let's assume that -- let me put it
this way.
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So would it be safe to say that, as you sit
2
here today, you don't have enough recollection or
3
knowledge about reports which show particular days
4
that were worked to really comment upon what would be
5
feasible or not feasible to print out at this point in
6
time?
7
A.
Correct.
8
Q.
Okay.
9
That's understood.
Now, but let's go
on with what you indicated you were kind of tasked to
10
do, which was to come up with a Friday, Saturday
11
report, which I understand you've indicated kind of
12
what your basis was as you answered this.
13
The second sentence of paragraph 7 on page 3
14
of Exhibit 7 says "To create such a report, SUSA would
15
have would have to design and program a new report
16
which, without specific specifications, is estimated
17
to require six to eight weeks of analysis design,
18
programming, testing to complete, plus the time to run
19
on multiple databases and store the reports on CDs
20
would take an additional two to three weeks."
21
So we've talked a little bit about -- you've
22
done a helpful job of explaining kind of processes you
23
go through as you come up with this new report
24
situation.
25
But would it be safe to say that the six to
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eight week estimate, in terms of how many hours it
2
would take each week, you're not in a possession to
3
really talk about today?
4
A.
Correct.
5
Q.
Okay.
And if the report did what I
6
suggested, which is it simply receives a list of --
7
excuse me.
8
9
If a report did what I suggested in which the
input was a list of employee numbers, such that the
10
report would automatically do one after the other
11
after the other, that probably wouldn't take two to
12
three weeks to run on 1,600 employees?
13
14
15
16
A.
two to three weeks to run.
Q.
19
Okay.
Maybe I didn't quite understand what
the two to three weeks took.
17
18
Well, I wasn't -- I never said it would take
I apologize.
Could you explain to me what was the
additional two to three weeks.
A.
That was to -- I wasn't sure how large, how
20
many reports or people or whatever, right?
21
would take us six to eight weeks to run it, and I
22
figured -- okay.
23
sometimes people think a lot of reports can fit on a
24
CD, and they don't all fit on a CD.
25
CD, I have to have somebody sit there and put a -- so
So it
Depending on how much data it is,
And you know, a
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do it, that would be my preference.
2
If I had to find an outside resource, problem
3
with that is there's not a lot of Delphi resources,
4
you know, single server resources.
5
a combination.
6
the data into, like -- there's all kinds of stuff --
7
into Oracle file and then find Oracle resource to help
8
us.
9
So sometimes I use
I might be able to get them to dump
But I would have to have the clear definition
10
of what was needed in what timeframe so I could make
11
a -- you know, and I was asked to give a time and
12
dollar estimate.
13
$100 to $200 an hour for an outside resource to give
14
an idea of what a cost would be.
15
Q.
So I generally use a standard of
But would it be safe to say that, at this
16
point, as far as the 480 man hours, in light of what
17
we said, would it be safer to say that it might take
18
that long but it's really too early to tell because we
19
haven't done enough research on the project yet?
20
mean, is that fair to say?
21
22
23
A.
I
That's fair to say that I don't know what the
exact hours would be and this is an estimate.
Q.
My question isn't just do you not know what
24
the exact hours are.
25
who can predict anything with precision like that.
I understand that.
I don't know
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My question is, to even come up with 50 hours
2
versus 480 hours, given what you mentioned earlier
3
which is you haven't had the opportunity to spend some
4
time with your team to go over it in detail, wouldn't
5
you say that it's probably premature to even come up
6
with that level estimate right now but you could after
7
you'd had a chance to meet?
8
9
10
11
A.
Correct.
Normally I wouldn't want to give an
estimate until I had clear specs, but I was asked to
give an estimate.
Q.
Okay.
Let's say that the judge entered an
12
order that your team was to meet and confer with a
13
computer expert from my side to work out how to do
14
this thing that we've been talking about -- this
15
Friday, Saturday report.
16
Judge says, you know, "Meet and confer, and everybody
17
try to get along.
18
Just try to get along."
19
Just assume that happens.
Don't throw things at each other.
What kind of expertise would make it easiest
20
for you to be able to talk your techie talk, to not
21
have to spend a lot of time explaining things so that
22
you could meet with a knowledgeable person from my
23
team to talk about "Here's what we can do.
24
too much.
25
doable"?
That's not reasonable.
This is
Yeah, that's
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just so then I can have -- I have a whole team of
2
other programmers that can format a pretty report.
3
But you're not talking about a formatted pretty report
4
so --
5
Q.
Okay.
6
A.
So I would still have the SAFES people go
I understand.
I understand.
7
through and do the algorithm to find the Fridays and
8
Saturdays.
9
Q.
Okay.
I understand.
All right.
Let me
10
double check and see if there's anything else.
11
have a question.
12
report delivery.
13
I did
I was a little curious about this
So we have our employee who is this Citrix.
14
They call up -- let's use the worked hours report.
15
They call up the worked hours report.
16
query.
17
passes.
18
19
20
They enter the
They hit this okay commit button.
Time
And what comes on the screen to tell them
your report's ready?
A.
Apparently a prompt comes back on the screen,
21
and I believe it asks them if they want to save it to
22
a PDF file or print it.
23
actually more of the time, depending on the size of
24
the database, if you're running it at a time when the
25
computer is on a heavy load, the first part will take
Then they answer that, and
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considerable time.
2
If you're running it at a time when the
3
computer's not at a considerable load, then the
4
majority of the time is -- it goes off and spins and
5
either prints the report, sends it to a spool queue
6
and prints it, or it creates the PDF.
7
Q.
Okay.
When you say -- you say yes, please
8
create the PDF, does this get saved in -- on a local
9
device or in a Citrix virtual desktop folder?
10
A.
I believe it gets saved on a network drive
11
that's part of the SAFES system.
12
a file -- Citrix is just the communication software
13
that allows a PC to log onto SAFES.
14
Q.
Okay.
Citrix doesn't have
Then if somebody wants to copy from
15
the network drive to, let's say, a portable two-and-a-
16
half-inch hard drive that they've put into the USB
17
port of their local computer, it's possible to copy
18
from the network drive onto a USB device?
19
A.
Our Infrastructure group would have to do
20
that because we have a lot of encryption and safety
21
controls in place.
22
employee to run our customer file and then save it
23
onto a disk and then leave the company with it.
24
also wouldn't want them to save confidential employee
25
information onto any local devices.
For instance, we wouldn't want an
We
So we have a lot
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REPORTER'S CERTIFICATE
2
3
I, Jannea McClure, CSR No. 13718, a Certified
4
Shorthand Reporter within and for the State of
5
California, do hereby certify:
6
That prior to being examined, the witness
7
named in the foregoing deposition solemnly stated that
8
the testimony given in this deposition would be the
9
truth, the whole truth, and nothing but the truth;
10
That said deposition was taken before me at
11
the time and place set forth and was taken down by me
12
in shorthand and thereafter reduced to computerized
13
transcription under my direction and supervision, and
14
I hereby certify the foregoing deposition is a full,
15
true, and correct transcript of my shorthand notes so
16
taken;
17
I further certify that I am neither counsel
18
for, nor related to, any party to said action, nor in
19
any way interested in the outcome thereof.
20
21
Dated this 16th day of July,
22
2014, at Los Angeles, California.
23
24
25
_________________________________
Jannea McClure, CSR No. 13718
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