Free Reply - District Court of Arizona - Arizona

ll/Ierchant Transaction Systems, Inc.
vs.
Nelcela, Inc., et al.
And related Cross and T lzird-Party Claims
N0. CIV-02-1954-PHX-MHM
Nelcela, Inc., Len Campagna and Alec Do1larhide’s Reply
Statement of Fact in Support of Their Motions for
Partial Summary Judgment
EXHIBIT C
V (Relevant Deposition Testimony 3
of Alec Dollarhide)
Case 2:O2—cv—O1954-I\/IHI\/I Document 362-4 Filed O4/24/2006 Page 1 of 4

1
;¢· UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF ARIZONA
MERCHANT TRANSACTION SYSTEMS, ) No. CIV 02-1954 PHX MEM
INC., > i
) i
Plaintiff, ) A
) 2
vs. ) S
>
NELCELA, INC., an Arizona ) {
Corporation; LEN CAMPAGNA, an ) 3
Arizona resident; ALEC ) {
DOLLARHIDE, an Arizona ) g
resident; EBOCOM, INC., a )
Delaware Corporation; POST ) i
INTEGRATIONS, INC., an )
Illinois Corporation; CHARLES ) i
ANDERSON, a Washington ) j
resident, ) E
fn ```’` Q Defendants. ) 2

Amended Counterclaims, Cross )
Claims and Third—Party Claims.)
) I
VIDEOTAPED DEPOSITION OF ALEC DoI.I.AREIDE
Phoenix, Arizona ,
` August 16, 2005
By: ,Kim Empey, RPR i
Certified Court Reporter i
Certification Number 50570 A
(Copy) l ‘
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109 i
. 1 A. There were two parts to it. One part was in our i
2 Nelcela office, in our communications cabinet, with the 2
3 rest of the routers and switches. The other half to it 1
4 was located in POST's facility.
iise 5 Q. Okay. And what connected those two pieces of
6 hardware? 7
7 A. The internet.
8 Q. So it was an internet VPN connection.
9 A. Yes. 1 {
iiae 10 Q. Okay. The -— in the Nelcela offices, the VPN é
11 appliance, where did it connect to? i
12 A. Into the firewall. 1
I 13 Q. Into the same firewall —- i
14 A. In the firewall segment. i
iiae 15 Q. Okay.
16 A. It connected into the development segment. A
17 Q. It connected directly into the development 3
18 segment? i
19 A. Yes. y
_ll£6 20 Q. Okay. Did the development —- did the development i
21 segment have its own firewall at that time? i
22 A. No, the development segment was part of —- it was S
23 a segment off of the firewall. i
24 Q. Where was the SQL database located?
iies 25 A. SQL database was in the production segment. .
Coash & Coash, Inc. (602)258—1440 y
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110 j
1 Q. Okay. And the purpose of the VPN connection was P
2 to be able to read that SQL database, right? j
3 A. And allow them access to other sources of P
4 information on our system. .
insv 5 Q. Was the purpose of the VPN connection primarily g
6 to allow access to that SQL database? i
7 A. Primarily, yes.
8 Q. Okay. And so the firewall would give VPN access Q
9 to both the production segment and the development j
insv 10 segment. Is that your testimony? j
11 A. Say that one more time, please. j
12 Q. Yes. Let me back up. Who, then, programmed the A
I 13 firewall to allow VPN access? i
14 A. Network Safety. E
inzv 15 Q. So they did not just the —- the VPN device, but i
16 they programmed the firewall, as well. j
l7 A. Yes.
18 Q. And by "firewall," I'm referring to the firewall E
19 that's depicted in 170 that you already have —- i
insv 20 A. If you want to give that a name, it's called a %
21 Watchguard firewall. 6
22 Q. Okay. A Watchguard firewall. So this company I
23 came and configured, then, the Watchguard firewall. i
24 A. In conjunction with the maintenance contract we i
ings 25 had with the Watchguard —- where we bought the Watchguard i
Coash & Coash, Inc. (602)258—144O i
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