Deposition of Nalin Chandra Wickramasinghe

NO. LR-C-81-322

et al. *
Defendants * DIVISION
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MR. DAVID KLASFELD, Esq., Skadden,
Arps, Slate, Meagher & Flom,
919 Third Avenue, New York,
New York 10022
For the Plaintiffs

MR. STEVE CLARK, Attorney General,
MR. RICK CAMPBELL, Assistant Attorney
MR. DAVID WILLIAMS, Assistant Attorney
General, State of Arkansas, Justice
Building, Little Rock, Arkansas
For the Defendants


Dr. Lawrence Coleman U.A.L.R.
Dr. Eric Holtzman, Columbia University
DR. JOEL CRACRAFT, U of Illinois
* * * * * * * * * * * * * * * * * * * * * * * * * * * * *
witness produced on behalf of the Plaintiffs, taken in
the above styled and numbered cause on the 15th of December,
1981 before Laura D. Bushman, Notary Public in and for
Pulaski County, Arkansas at the office of Mr. Cearly,
1014 West Third, Little Rock, Arkansas at 7:40 p.m.



the witness hereinbefore named, being first duly cautioned
and sworn to tell the truth, the whole truth, and nothing
but the truth, testified as follows:



Q. Dr. Wickramasinghe, is that the correct pronunciation?

A. Uh, Wickramasinghe, right. Hard G. It just has
a certain phonetic --

Q. Hard G. Okay. Could you tell me as best you can,
what the testimony that you expect to give tomorrow will

A. I think I would like to lead the Court through a
series of arguments, beginning with the evidence that I
had to be fairly decisive that there is organic matter in
the dust clouds of space; then to proceed to argue about
the composition of the organic material. I am referring
now to the organic material in the gas place; then to show
that the most sensible, and the most -- in my opinion the
inevitable explanation for the dust -- for the data that
one gets related to dust. The organic material have to be
of a -- in a particular form of particular sizes, pretty
uniform throughout the galaxy and also pretty uniform
throughout the other galaxies outside of our own galaxy
wherever it's been possible to measure the effects of the


dust. And I would like to discuss certain observations
of infrared sources of radiation in our galaxy, which
show certain pattern of absorption. And it's been
something like two or three years -- more than that --
four years now that we've been trying to separate -- her
and I have been trying to examine the behavior of the
spectra to try to understand them in terms of particular --
certain moderates of the dust. And I would argue that the
microbial model -- microorganism model of the dust is not
only consistent with the data, it seems to be quite
reasonably definite identification for the dust in space.

I've brought a couple of slides
that I have or displays to point to correspondence between
a microbial microorganism model of the dust and a set of
astronomic observations relating to the dimming of
starlight, and also to the infrared -- the infrared
properties of one source at the center of our galaxies,
which shows an extremely close correspondence with the
behavior of desiccated bacteria that has been studied in
the lab, under conditions that we think are similar to
what would operate in the interstellar medium.

Q. Uh-huh.

A. So these are two -- the observation and data that I
want to confine my attention to mainly, and the astronomic
observations; and then to discuss various areas in which


such microorganisms could be propagated to enhance numbers
in interstellar material in the galaxy.

And I suppose the next think
I would like to say is that if one looks at the conventional
wisdom of the origin of life on the earth -- I'm not referring
to the creation theory. The conventional beliefs that
scientists have heard about -- that there are major
difficulties in understanding how simpliest elementary
life forms could get together from conditions that might
have been relevant to the idea. And I also wanted -- I
think among other things I want to point out that the
polymerization of amino acids in the oceans is --

Q. P-o-l-y-m-e-r-i-z-a-t-i-o-n.

A. The stringing together of amino acids, which has
almost been taken for granted in the arguments for
chemical evolution. This process presents very serious
problems for -- to understand how it could happen on the

Q. Let me just interrupt you for a second. When the
court reporter doesn't understand a word, she doesn't
want you to explain it. She just wants to get the word
down accurately.

A. Okay, fine. Then I guess I suppose -- I -- I --
I probably should bring something else with me in there
because I think I've got a series of logical arguments


that I want to follow through. And I guess at some stage
I would like to bring up the business of spontaneous
generation of life and the -- the old concept of spontaneous
generation. This -- if -- if I'm to demolish by Pasteur --
by the experiments of Pasteur was -- this -- this doctrine
or theory recovered despite Pasteur's declaration that
it received a mortal (sic.) blow in his famous address
to the French Academy -- in some form it's recovered and
dominated science from oparin --

REPORTER: From what?

Q. O-p-a-r-i-n.

A. Then I think I would like to go through the geologic
record and point out that the Pasteur doctrine of life,
being generated from life appears to be maintained right
through the fossil record. We don't really know how the
different connections have come into being. But there is
a logical hierarchic logical connection between person's
life (sic.) and fossils on the earth. And you can take
it all the way back to a certain point in the earth's
history. This point that we can take it back up to life
generated -- life to life. This, in my opinion, stops
at about 3.83 billion years before the present time.

This was the time when the
earth's -- in my view and the view of Sir Fred Hoyle when
the earth's oceans were laid --


Q. Excuse me. In the view of you and who, Sir Fred

A. Yes.

Q. I just wanted to be sure the name was understood.

A. I mentioned it but it is not consensus view. The
earth's oceans and atmosphere seems to be laid at about
that time. The earliest sedimentary processes started
also at 3.83 billion years. And I think at that precise
time there's also evidence for microbic fossils on the
earth. The oldest fossils came to be. There's been
some argument about the identity of these fossils, but
3.83 is a reasonable time to -- to -- for dating the
earliest appearance of life as one can see in the rocks.

And I think the next point I
want to make is the -- if you take the resection (sic.)
of spontaneous generation to its logical conclusion, then
the time before 3.83 on the earth has to be linked to a
source of information about life. One could either say
that life appeared in a random shuffling operation and
appeared in the primordial mix. Or if it didn't happen
that way, when it had to be injected from outside.

And I think I would briefly
discuss my views and views that I share with Sir Fred
Hoyle about how the injection of biologic material might
have taken place at 3.83 billion years before the present


time. And also show how this process might still continue
to the present day.

Then I suppose at that point I
also want to bring up an issue that isn't too well known
to science at the moment. However, there is a colleague
who came to Cardiff quite a few weeks ago --

Q. Cardiff, C-a-r-d-i-f-f.

A. -- and spoke about some of his recent work on the
Merchison meteorite. The evidence that he showed me and
an audience who came and heard it was that there appears
to be a very very strong case for microbic fossils in the
Merchison meteorite. Both chemical evidence and morphological
evidence and I want to discuss that very briefly.

So if it is the case that one
has life on the earth and one has life on -- appears on
a meteorite, then the question of independent origins is
to be asked. Is it likely that there were two origins,
one on the earth and one on the meteorites. And if there
are such two origins, could they have converged to
produce the same type of structures?

So I suppose I think I would
like to take off from that to argue that -- are the
matters of the probabilities of the appearance of first
life in the universe. And go on from there to say that
where ever it happened that there seems to be -- first of


all, there seems to be a difficulty in understanding the
acquisition of information that is relevant to life.
There's an information content in life that is very specific
relating to enzymes and so on. And could this -- one
could pose the question could this information have been
derived in a chemical evolutionary sense or has it got
any deeper significance? The massive quantity of

I think that sort of summarizes
what I would like to....

Q. It was an awesome job. Okay. Why don't we start
with the astronomical observation. What is it you would
expect to say about the organic matter found in dust

A. That it has to be of a rather complicated polymery
character. That the --

Q. Complicated?

A. Polymer character. Simple organic vertical molecules
and so on, that these together would not account for the

Q. What is the data that it wouldn't account for?

A. Absorption properties of infrared wave lengths.

Q. Why wouldn't it account for that?

A. Because it doesn't. We've attempted to compare --

Q. What is there about the absorption qualities?


A. Un, it's a -- this is just one example of it. There's
a -- it's a very detailed profile of transmittance and
plus the wave lengths are very involved --

Q. Well, perhaps if you could explain what the dots

A. Dots represent the astronomical data for the flux,
radiation comes from a source that is called JCR located
at the center of our galaxy. And the reason for choosing
this amongst several of our other sources is that this
particular source is a sort ten kiloparsecs away. And
it samples a long parcel length of interstellar material.
He is very flat -- I don't know. Maybe I shouldn't really
go into technical issues but you can see it has a flat
background here.

Q. I simply want to understand what you're going to
testify about tomorrow. If you're going to testify in
this kind of detail, I'd like to know about that tonight.
If you're not going to --

A. No, I think not. I think I'll make a general
statement in that it is my belief from long experience
in trying to fit these curves in astronomical context that
it is very difficult to get an agreement between the date
and a model unless one postulates something very complex
and very specific in a very specific manner.

Q. Have you examined this matter with other wave lengths


other than infrared? Have you examined it with ultraviolet?

A. Yeah, yeah.

Q. What is the result with ultraviolet?

A. The results -- the overall ultraviolet behavior of
the dots is represented by the dots here.

Q. I guess if you could explain what the longitude and
latitude measure.

A. On the X axes is the inverse of the wave length and
on the Y axes is sort of the dimming of starlight. I don't
know -- I think this is pointless to bring very technical
arguments into a courtroom.. But it's my opinion, having
attempted to match this data, this models for nearly
two decades or so, this is -- the (inaudible. Sounds like
"masterphone") gets really almost with the first shot
of trying to match the microbial model -- microorganism
model has to mean something. In my view it means --

Q. I guess I just don't begin to understand what it is
you're observing. What the dots measure.

A. The dots measure the --

Q. Let me start over this way. What kind of machinery
are you using?

A. The machinery involved in making the observation?

Q. Yeah.

A. Okay. Telescopes. Telescopes mounted on satellites
and on the surface of the earth


Q. And you're looking at one star or a lot of stars?

A. This is, in fact, the average for lots of stars, yeah.
For maybe five hundred or thousands of stars.

Q. And what does each dot represent?

A. Each dot represents a particular wavelength point
and averaged over the last number of stars. But in fact,
as it turns out, if I were to clock the variation from
one star to another, the variation is not particularly
great except maybe in the ultraviolet wavelengths. in
this particular wavelength, for instance, see the points
sort of hug that curve rather closely where ever you look
at it in the galaxy.

Q. And each of those dots represents a sighting of
different groups of stars or the same group of stars?

A. Each dot is the -- represents the -- on some kind of
anomalized -- some kind of scale here the fogging of or
dimming of starlight a logarithmic scale.

Q. And is that the same thing in the infrared --

A. Infrared represents the -- it represents absorption
below. It's not the same thing. It's the same philosophy.
There's an absorption here. This in fact is not absorption.
But most of this is scattering, it is electromagnetism by
small particles.

Q. Suffice it to say that these two short charts show,
to your satisfaction, that there is some kind of living


matter out there.

A. Matter that started of living in the first place.
I think the exercise here is to take -- is to take an
ensemble of bacteria that you can get in the lab and the
sizes are measured, the optica (sic.) properties are
measured and so on. And in a hypothetical experiment you
fling them into space and ask the question, "What is the
obscuration that it would produce and what is the
absorption it would produce?" And they match the
astronomical data.

Q. Is the -- are the ultraviolet -- is the ultraviolet
chart characteristic of nucleic acids?

A. No, it's not that -- there are very minor effects
here and here on -- this hump here is the strongest effect,
absorption effect in the ultraviolet and it is attributed
in this model to be graded -- it's graphite -- soot like
material releases this absorption here.

The unfortunate situation is the
nucleic acids would have absorption at about 2,600 angstrom
so it is a very small effect here. And at the present
time it's hard to pick it out in relation to the --
to the general background of absorption. It is due to
the carbonized, the graphitized biology on this model.

Q. Have you reached any conclusions about the properties
of the organic material?


A. Yeah. It's just what I told you. I think the
properties are consistent in my mind. Though I'll not speak
of material that started off as biology in the first place.

Q. Is there any evidence for nucleic acids in these
two charts?

A. The evidence for nucleic acids -- the evidence in
this -- the type of evidence that's shown in this figure
here is an absorption profile. It's due to all of the --
all of the organics that are involved in biology.

Q. I see a lot of dots on a white thing and I just don't
understand what it is they represent.

A. Well the dots -- the dots, as I told you, represent
the flux, the wavelengths dependents of a certain
absorption of the stars in the galaxy. And the attempt
is made to compare the detailed profile of this absorption
with a laboratory system. The laboratory system that I've
chosen for this comparison is desicated bacteria that's
kept in the laboratory and under conditions it's tried
out. And the agreement without any further assumptions
comes out to be exactly right.

Q. Exactly right with what?

A. Pardon me? The comparison. It's obvious to anyone
that the curve runs through the data points and that's the
only point I'm making. The curve is a theory --

Q. Did you put the curve on the graph before you put


the data points there?

A. No. There are two different effects. The points
are the astronomical data. That's one -- on one -- one
one element of astronomical data, the points. The curve
is the predicted behavior of graph -- of desicated bacteria.
And the overlay is the correspondents to which I attribute
some significance.

Q. So basically you think there's some organic matter
out in space. That's the conclusion -- I don't want to
denigrate what the ultimate conclusion is, but that's what
the conclusion is.

A. That's the first order of conclusion, yes. That
there is organic material simply because -- I mean --
well, first of all zero (inaudible) on the spectrum is a
CH stretching which any organic chemist would recognize
as being tied with sea organic matter. But a further
conclusion which is more contentious and which people are
very resistant to accept it as a detail profile which
involves a certain amount of modeling, and a type of
modeling which is not -- is somewhat atypical of the
modeling you do in the laboratory when you want to
recognize laboratory spectrum and say what material there
is in that -- that gives rise to that spectrum. You use
certain criteria.

In astronomy one -- when it's


almost every fragment of information that is possible.
And I think that the kind of exercise that we've been
involved in this business, we use not only the wavelengths
of the absorptions, which are sort of separated points in
there, the dips and variations defined by the structures
of that curve. Not the set of those wavelengths only,
but the relative magnitudes of the absorption from point to

It is essentially that the detailed
distribution of oscillators that are involved there. And
I think it's something that is very -- I -- I -- I've
managed to convince lots of chemists on this, but it
takes a good half hour to tell -- to -- to point that
there is a different -- there's a different exercise
involved when one is trying to match a spectrum which
has this kind of structure and so on. And attempting to
use all the information which is available relative
strengths of it from point to point on that curve.

Q. And it's your understanding that there's evidence
of properties with nucleic acid --

A. It's a whole slew of stuff. You take the bacteria
from the lab, it is not nucleic acids, all the polypeptides
(sic.), everything that goes in (inaudible) shows up in
absorption. So it is hard to separate the nucleic acids
from anything else by this kind of criterian and one has


to look for other things. And one of the things that we
have been attempting to look for, sicknesses (sic.) in
nucleic acid, what you told me and what you asked me a
little while ago. The absorption in the ultraviolet --
but unfortunately turns out that those are ultraviolet
absorptions are weak. The nucleic acids -- they have low
values of what chemists call a massive absorption coefficient
and it is hard to pick it out from the background absorption
of the other stuff that is in the dust.

Q. You said something about the explanation for dust
and particulate form in particulate sizes. Did I write that
down right?

A. Right. This curve is the calculation -- behavior of
a certain ensemble of particles with certain defined
properties that defined properties that refer to refractive
index. And the refractive index here is choosen to be
appropriate to dried out bacterian that I hypothetically
fling out and I sort of -- in a conjecture experiment fling
out in space and ask how much evacuation that occures.

Q. What do you mean by that?

A. Creation of a vacuum. Just as it mean. And then
they are off to calculating the electromagnetic absorption
and scattering properties of that system. The curve is
the calculation. And the -- without any further assumptions --
I mean let's take the lab spectrum, the flinging into space.


I find that I get an agreement that these are rather close
and that's the -- that leads -- these are the two pairs that
I just want to refer to rather briefly and express my
opinion, which isn't necessarily the opinion of every other
astronomer alive.

Q. Is it the opinion of any other astronomers aside from
you and Sir Fred Hoyle?

A. I haven't done a consensus.

Q. I'm not asking for a consensus. Is there anybody
who agrees with you and Hoyle about this?

A. Well, I think very few people have addressed their
minds to it and to the detail operation that are involved
in comparison. But I think the answer is yes, I can
think of a few that appear to be partially convinced.
But there are lots of barriers to complete and --

Q. Are you aware of anybody who buys the whole theory
aside from you and Hoyle?

A. Buys the whole theory? Do you want me to name a

Q. I'm asking you first if you are aware of anyone. If
you tell me you are, then I would ask you who it is.

MR. WILLIAMS: If you know.

A. Not to my knowledge. I have not attempted to have
extensive dialogues on this matter at this time. I knew
that it is something that requires a lot of conviction in


the sense that it takes a lot to convince someone on the
basis of this kind of data. But I think it needs a
background of understanding of what the data means. A
background of information of understanding what the
calculations mean. As it turns out, without any false
modesty, I think I can make a claim that this kind of
operation of comparing this type of calculation with
data is something that I've been involved in and I think
very few astronomers around the world have the -- the
length of experience that I've had and attempted to compare
various models of the dust rains with the relevant astronomical
observation. I have worked on my own and other people
intermittently. And it is -- it hasn't been -- I think
the situation is that it has not been examined critically
by any astronomer that I know of.

Q. Does your testimony that no astronomer agrees with
you totally about this theory --

A. No, I did not say that. I said I have not conducted
a census.

Q. That you are not aware of any astronomer --

A. I'm not aware of -- these have been published and
I am not aware of any astronomer who has published a retort
that could demolish the comparison.

Q. I'm asking you a different question. I'm asking you
has anybody told you, any astronomer told you that they agree


with you or the totality of your theory?

A. I haven't asked that question of any astronomer.

Q. Have you discussed it with any astronomer?

A. Yes, I have. In fact, in the United States they are the
people who have been working rather closely on the interstellar
medium from other directions. Not on the grains, not on
the dust, several of them tell me that they are now willing
to buy this aspect of the story. But there are other
aspects that require further --

Q. Have you discussed it with any biologist?

A. Have I discussed it with any biologists? The
astronomical implications or the comparison --

Q. The data?

A. The data is -- no, not the precise comparisons that
were involved here because the comparisons are not -- do not
relate to any particular expertise of biologist. These
spectra obtained just from the laboratory experiment the
astronomical data obtained from using telescopes and so
on. And comparison is -- did not demand expertise in biology.

Q. Have you discussed with anybody except astronomers?

A. Yes, lots of people.

Ql What other disciplines I mean have you sought out the
advice of people in other disciplines?

A. I haven't sought out the advice --

Q. I've given seminars, I've given lectures to


departments of microbiology up and down Britain. To that
extent, I have disseminated some of these ideas in public
and amongst biological colleagues.

Q. Have you gotten feedback from them about your result?

A. Yes, I've got some feedback in the sense that they
say the comparisons are quite interesting and impressive
and so on. But they would like to think that there are
simpler explanations for the correspondences, but until I
find somebody who produces correspondence such as of a
comparable kind, I'm not willing to regard the possibility
that there may be a simpler alternative because I myself
have looked at simpler alternatives. I looked for instances
in this particular case -- I've looked for comparison with
the prebiology models of Sagan, and so on, and his colleagues.
A lot of experiments done on the behavior of absorption
properties of prebiologic particles, and I've looked at
dozens of these, and it just failed completely to explain
the fact in the infrared.

Q. I just noticed on this chart that you are making
reference to dry E. Coli. Is it that property particularly
that you guess that it is?

A. No. The reason I think that it is a fairly long
story that -- what really happened in this case was that
we were looking -- by we I mean myself and Sir Fred Hoyle,
two colleagues. We were looking at the behavior of


microorganisms sealed in -- not the biological behavior,
but the absorption properties sealed in KBr disks --

Q. What kind of disks?

A. Potassium bromide disks. -- and heated to various
temperatures in an inherit atmosphere to decide how high
a temperature these things could stand before the chemical
signatures essentially got molified over this wavelength.
And we found that -- the reason for doing this experiment
was that there were various claims about the fossils,
microfossils in sediments and the Isua sediments was the
oldest sediments on the earth.

Q. What kind of sediments?

A. Sedimentary rocks.

Q. I would like for you to repeat the word so that the
court reporter gets it.

A. Isua, I-s-u-a. that means -- there has been a
controversy --

DR. HOLTZMAN: Capitol "I"?

A. Yeah. It refers to a certain geological formation.
And there have been various arguments about the biogenesity
(sic.) or otherwise of certain fossils or certain structures
that were discovered in these rocks. One of the arguments
against biogenesity was the high metamorphic compress (sic.).
These rocks have been turned through fairly high temperatures
after the initial sedimentation. The question was raised,
could the -- if (Testimony continued on next page.)


they were organic sediments, if they were biological sediments
trapped in these rocks, could they have survived and preserved
their chemical integrity through the heating processes.
And we know that the rocks went through about 400 degrees of
centigrade or near enough. So we tried to mimic that
condition by -- obviously you cannot recreate the geological
experiments. So we thought it would be interesting to
see how microorganisms sealed in a KBr disk, not just one
but a whole bunch --

Q. Oh, I see. You're saying capitol K, capitol B,
little r.

A. This disk was -- and I am not going to go into
details about it.

Q. No. What I'm asking is this line somehow representative
of E. Coli in particular?

A. No, there were several other organisms that were
also -- it is not diagnostic of the particular bacteria
over that wavelength. I know that infrared spectrous could
be used to -- to -- to dec -- to decide between different
types of bacteria. But either fortunately -- or I think
that is sort of a thumbprint reason for biology in general.
It seems that we looked at the yeast cell and it had
pretty much the same spectrum.

Q. Yeast cell?

A. Yeah. I think this is the reason that it was -- the


most invariance from the different system and overall the
E. Coli at room temperature, E. Coli at 350 degrees saved
in a caviar (sic.) disk and in that atmosphere and yeast
at 20 degrees centigrade. And the overlay there was --

Q. What's the temperature of the grains of dust?

A. The temperature of the grains of dust in space
averages about 10 degrees above absolute zero. But it is
more than likely that in -- that the dust goes through
high temperatures from time to time. They get some dust
clouds involved in the formation of near stars and part
of the gas and dust that does not really go into the stars
become exposed to transiental high temperatures.

Q. But you are taking something that is normally at
10 degrees Kelvin and comparing it with the curve of
something that is either 20 degrees centigrade, and if I'm
not wrong, is 270 degrees Kelvin and something at 600
degrees Kelvin?

A. That's right. In this experiment. But there are
sound technical reasons for doing that and I think there
are also reasons for expecting that the low temperatures
of behavior of the absorption over that wavelength was
likely to be not different.

Q. I don't understand why you think you can measure
something at 10 degrees Kelvin and it be --

A. It wasn't --


Q. What would it look like at 10 degrees Kelvin?
Can you draw that on here?

A. Yeah. Exactly the same.

Q. Where, right in the same spot?

A. Right in the same spot. I think there is no

Q. Why if there is a difference between 20 --

A. Because at 350 chemical bonds are broken. The trace
quantities of water are thrown out and so on. But go
below room temperature in general, there is a sharpening
of absorption as a general rule. But the situation here
is that these absorption structures are not single
transitions, but a whole bunch of them. So the thermal
affects as you cool them, cool the dust or the bacteria
below 20 degrees is not, for this particular comparison,

Q. Okay. Is the size or the shape of the dust particles
in any way relevant?

A. Not for this comparison.

Q. I wrote it down hurridly. I thought you said
something about the explanation for the dust particulate
form and particulate size?

A. Particulate form is in the form of small particles
and the particular size I referred not to the -- the
infrared behavior at wavelengths that are -- how technical


do you want me to get? You are not trapping me in any way
because it is in my --

Q. No. Believe me, no one knows better than me that I
am not trapping you.

A. At wavelengths long compared to the size of the
particles. If you take small particles, look at a
wavelength that is large compared to the size of the
particle, then the size does not enter explicitly into
the absorption. It is what's known as Rayleigh absorption.
So in the long waves, size does not enter. And in the short
waves the size does enter.

(Testimony continued on next page.)


MR. WILLIAMS: Before we begin back,
I wanted to put on the record in this deposition, for the
record in this case, that Mr. Henry Voss will be available
for deposition at 6:30 tomorrow morning at the Attorney
General's office. And we've had some -- I had some
earlier discussions with Mr. Novik and I'm communicating
that to the Plaintiffs now, on the record.

MR. KLASFELD: I'm not sure exactly
what Mr. Novik's reply was, but 6:30 in the morning
strikes me as a little bit unreasonable.

MR. WILLIAMS: Well, it's 12:30
London time, you know.

MR. KLASFELD: Mr. Voss isn't
coming from London. Dr. Voss? Dr. Voss.

MR. WILLIAMS: Off the record.

(Off the record discussion.)


Q. You said something about the infrared sources of
radiation in our galaxy showing certain patterns of
absorption. What is it that you would expect to testify
about that?

A. That the presence of absorption detected in the
galaxy, not simply consistent with biology, which it is
in fact, without a shadow of a doubt that it is consistent
with biology. But in my opinion it's also -- there is a


reasonable chance that it is a diagnostic of biology.

Q. And the microbial model is due to this pattern that
you find that you can only satisfactory explain by what
you call a microbial model. And by microbial model you
mean that it's dried out bacteria?

A. Yeah, terrestrious (sic.) type bacteria is just
shoved into space and experiments done on that.

Q. You've done that?

A. I've done them, not myself, but along with a student
and a professional of biochemistry.

Q. How did you get it out there?

A. I didn't get it out there. No, no. This is in a

Q. Oh, I see.

A. They're attempting to mimic conditions that would
obtain when I shove it out there.

Q. Do you have what you consider to be unequivocal
evidence for nucleic acids in space?

A. In a spectra line it is something like that.

Q. In any form that satisfies you that it's unequivocal

A. No, I said it's not. It's masked in the general --

Q. Excuse me, masked?

A. Masked in the general absorption behavior of the
dusts. So, I think it's hard to be sure until one gets


a much higher definition of the data. It's not -- it's
impossible to detect it. And it was detected unequivocally
in the present.

Q. Okay. Do you have a theory about how those microbial
organisms got there?

A. Yes, I do.

Q. What is that theory?

A. It's a theory that's discussed in a couple of the
books that I've written over the past couple -- year or
two, or so. I think I'll draw your attention to page --
besides in the galaxy the bacteria are most likely to
replicate and to be amplified in numbers is in the
environments of planets and surfaces of planets, and in
interiors of comets their liquid water could be present
for -- over lengths of long periods of time. And we know
that as a consequence of star formation there is --
planets, comets form along with the stars. So, there is
a sort of feedback loop that develops.

Suppose one starts with a very small
component of biological material in the galaxy -- call it
biotic material. It's incorporated --

Q. Biotic -- I call it biotic material. It's incorporated --

A. Uh-huh. -- into the intercellular material, into
the gas and dust in space. And these gas and dust is going
to form new stars, planets, and comets. And the tiniest


amout of material that you start with in this loop is
amplified when it goes into a comet or into surface of
the watery planet. And the circumstance that the
particles are of the sizes that they are, the bacteria to
speak of is a third of a micro in radius, permits them
to be exposed by force of radiation from stars, radiation
as a factor -- starlight as a factor of pushing these --
rocketing these particles out from the parent stars
where they are -- around which they are amplified. And
it goes back into the intercellular medium -- into the
gas. And this incidentally is just a orilnebular --

Q. O-r-i-l-n --

A. Orinebular. And that's the reason of very accurate
star information. So, particles are amplified as -- as --

Q. By what process are they amplified?

A. By -- simply by logical replication and --

Q. They grow?

A. Hum?

Q. They're alive?

A. Yeah, a small fraction. There could be a massive
massacre due to radiation conditions in space, and so on.
And I don't want to go into detail or anything although
it is very authoritive that there is -- there are various
mechanisms that would permit survival of biology to
significant extents. But it doesn't require even survival


of one part in a million to make this loop go and to
amplify the numbers of biological particles.

Q. But they're alive and they replicate and grow?

A. Some fraction, some fraction is in a viable condition
to get to the next site of amplification to convert the
ambiant matter -- inorganic matter into more biology and
the -- the feedback builds up to account essentially
for all of the -- or a large fraction of the dust in

Q. Where does the biotic material come from in the
first place?

A. From the -- you mean the very first -- very first
cell? Is that the question?

Q. Well, you're assuming the presence of some biotic
material that then gets into some kind of circle. I'm
asking where the biotic material comes from in the first

A. Yeah, that's -- that's -- I think there is several
possibilities. One is that it -- it gets in -- gets
together in random shuffling of the cosmic -- on the
cosmic scale, right. The advantage one has from going
out from a little pool on the earth to -- to the whole --
to our universe is that we've got many more sites for
the shuffling -- you could use one -- a couple of pools
on the surface that are invariably sheltered -- the


conditions are the least favorable for any polymerizations
to occur.

Q. The least favorable where?

A. On the surface of the earth, and the earth's oceans.

Q. I see.

A. So, if one takes account of all the possible occasions
in the galaxy and the universe where they could -- water
could -- present, you could improve their chances of
starting life somewhere. But once it is started, then
it gets into this -- it gets ineligibly trapped into a
feedback loop-back simply because the particles of biology --
the microorganisms and particles of biology have the
right sizes to -- to get expelled from nearby stars, from
parent stars. They have the right sizes to get pushed
away from the parent stars.

Q. Why did you say that the earth's surface was the
least favorable?

A. It's -- there are several reasons. Do you want me
to enumerate them or what?

Q. Yes.

A. It's -- It's in the earth's oceans that something
might have happened, right. The aqueous conditions that
may -- are required to be the -- would have to obtain the
assertions. So, the -- and the oceans -- I think the --
the difficulties of getting molecules together, amino


acids together, polymerizing in a watery matrix -- in a
watery medium with very little ultraviolet light
penetrating an atmosphere, it presents problems I think.
Perhaps I should tell you this. I think that when the --
when the earth's oceans were made, then inevitably that --
an atmosphere develops. It's my -- in my opinion an
atmosphere develops. And that makes -- an atmosphere
shields the ultraviolets from the sun and there's hardly
any ultraviolet phortons (sic.) that would be raining --
falling on the surface of the ocean. It's minute fraction
of ultraviolet flux that gets onto the surface of the

And it's only ultraviolet light that can
polymerize the -- produce energy -- provide energy for
linking amino acids and polymydes (sic.). For example,
if you don't have -- if you don't -- if you start with
no life on the earth, to get from no life to life requires
stringing together of these -- of amino acids. And I
would argue that that doesn't happen in a radiation
protected environment.

Q. You said that random shuffling on a cosmic scale was
one of the possibilities. What are some of the other

A. The -- I think the information content applies. It's
so, incredibly, vast that one has to entertain the


possibility of a creation, but a creation not in the
sense that we've been hearing from the trial. But a
creation within the -- the framework of the universe, within
the laws of physics and chemistry of the universe.

Q. What do you --

A. A Creator that somehow develops them in the context
of the universe -- within the -- within the universe
consistent with the laws of physics just as -- just as --
I think that is a logical place for a Creator, within
the planet of the earth.

Q. Are you saying Creator --

A. Creator of the first life

Q. Yes, he's saying Creator. But consistent -- acting
consistent with the laws of physics and chemistry?

A. I believe it could be done. I believe there is
such a possibility, not that I understand it -- the details
of such a mechanism. But there is no apriori reason for
rejecting that as a possibility.

Q. Is there any positive scientific evidence for such
a possibility?

A. In a negative --

Q. No. I asked if there was any positive evidence.

A. No. That's -- I don't see how one could get a
positive -- positive evidence. I think it is by eliminating
the other possibilities as one argues that there is still


a logical place left for -- for this option.

Q. How many other possibilities would you say there

A. For this sort of life?

Q. Yes.

A. For the origin of life. I think there are certain
possibilities that -- I would like in my own -- what I
would like to think possible is a mechanistic approach
to the origins of life. But the information content of
life is so incredibly vast that I think one is an open
time scale for the universe.

I'm prepared to believe that present
cosmilogical ideas on the time scale of the universe may
be in error, in which case a mechanistic origin might
develop once and then -- that's one possibility.

Q. You've mentioned two possibilities.

A. Yes.

Q. One, the random shuffling through perhaps some
extended time scale.

A. Yes.

Q. Two, a Creator.

A. Yes.

Q. Is there a third possibility?

A. Not as I can say for the moment, no.

Q. You said that the earth was 3.83 -- you say the life


on the earth was 3.83 billion years old.

A. Yeah, the present evidence seems to me to suggest
that it's -- it's -- I mean you could subtract .4 billion,
I think. It's somewhat of a contentious matter, the --
the fact that 3.83. But at 3.5 there's a concensus view
that there is life at 3.5. At 3.3, if you go nearing the
present day, the agreement -- the sort or examiner belief
is that the evidence is even stronger. But in -- the
way I look at it, I think there's no reason for doubting
that there was life at 3.83.

Q. And how old is the earth itself?

A. About 4.55 billion years.

Q. Are you aware of any evidence that the earth
might be significantly younger than that?

A. No.

Q. What would you think of a -- someone who called
themself a scientist who felt that the earth was 10
thousand years old?

A. I think that he is misled and is not looking at the
facts in a systematic, reasonable way.

Q. Could any rational scientist think that the earth
was even a million years old?

A. No.

Q. You said that the conventional wisdom of the origin
of life, that there are major difficulties in forming


simple life forms. What are those major difficulties?

A. Major difficulties. You mean conceptually or --

Q. In whatever sense that you mean it.

A. The difficulties are really vast and inmeasurably
because it hasn't happened in the lab, for one thing. And
major difficulties I think are in getting together the
information that is required for life. And I'm not
referring to any sort of -- any arbitrary set of information
or instructions for life, but a specific as we recognize
as life. That has to arise from a situation that it's
initially random and the rate of acquisition of units of
information that leads to the particular system that we
recognize as life poses a serious problem, I think. If
one is dealing with limited time scales on the -- on the --

Q. And you're referring to several billion years as
a limited time scale?

A. Cosmilogical time scale.

Q. You do a calculation in the book Evolution From Space --

A. Uh-huh.

Q. -- in which you come up with the number 10 to the
40 thousandth. That's sort of a conservative estimate --

A. Yeah.

Q. -- of the possibility of arriving at life randomly
on the earth.

A. Yes, I think I would stand by that characterization.


Q. Could you go through the -- could you go through
the calculations for me?

A. Yes, I suppose I could. Right now, or --

Q. Yes, please.

A. Okay. I would say that a necessary condition for
reaching the living system from a non-living system is to
get the very specific information in arrangement as one
finds in the enzymes, right. The -- and one knows how
many sites are crucial in an enzyme for -- for particular
biochemical -- for particular straight -- for particular
biological function of the enzyme, themselves, to do
something. And you know how many -- you know how many sites
typically are required to be filled by particular amino
acids. And the conservative estimate I would say is one
of our fifteen sites -- fifteen or twenty sites. You
pull it down maybe, I don't think it helps very much.

So, it's really a calculation, a very
straight forward combintarior (sic.) calculation of
finding out how many possibilities there are of reaching
the crucial enzyming system that goes across the whole of
life. And it's just -- we're talking up numbers. I think
it comes up to 10 to the 40 thousandth.

Q. Well, you take 10 to the 20th, right? That's what
you're just talking about, the points, right? 10 to the
20th? How do you get from there to 10 to the 40 thousandth?


A. No, if that's --

Q. Twenty --

A. You mean twenty sites.

Q. Yes.

A. So, that's 15 sites, let's say for argument sake.
Fifteen sites for enzymes, a critical -- required to be
filled by particular amino acids. Then the chance of the
number of shufflings that they need to get one amino acid,
right -- one enzyme, right, is 20 raised to the power
assuming there are twenty relevant amino acids for enzymes,
is 20 raised to the power of 15. That's raised to the
power of 2000 if there are 2000 enzymes. And you do a
bit of combintariorizing (sic.) and divided by facterials
(sic.) and so on. And obviously aren't going into that
deep, there's a book here. But if you do a bit of
elementary divisions of the 15 sites -- need not be 15
specifically, you can slide them up and down and you can
also mix up the enzymes. It doesn't matter whether you
find one enzyme first or the other one, or that enzyme
last in your shuffling. So, there are various divisions
that has to be done. And many times it's about maybe
10 to the 40 thousandth --

Q. Is that a big number?

A. You can say that again.

MR. CLARK: It's more than Mr. Williams,


Mr. Campbell, and I can add together

Q. What exactly is the information you're talking
about when you use the word information?

A. The arrangement of the sites, the filling of the
sites. Information needed to fill those sites with one
of twenty amino acids.

Q. Is the -- is the information a natural substance
or is it some kind of concept that we impose on what we
find there?

A. It's a concept that arises from the arrangement.

Q. Are there reasonable relationships between these
enzymes to the extent that you are aware of?

A. Not -- not -- it's not sufficient to -- to pull that
number down to -- I mean you could tell me -- someone
might tell me -- maybe someone could tell me that all
enzymes are living independent on a smaller set or something
like that. But unless a small set is reduced to ten --
I think the 10 to the 40 thousandth is such a vast number
that they could really -- I could have thought to --

Q. You can give me 10 thousand?

A. I could give you -- yes.

Q. The -- and I suppose it's this number that you're --
that you're using when you say that the chances of it
happening are so small it's not to even consider?

A. Yes. I would say yes. Uh-huh.


Q. And you made reference to the difficulties in the
polymerization of amino acids, is that the same thing
that we're talking about?

A. No, it's a different definition.

Q. That's something more?

A. That's -- that's -- I would have thought it was a
higher order difficulty in a sense, higher order relating
to location on our planet because the situation there
is that even the shuffling which one assumes -- I'm not --
in that operation of -- in the calculation there are no --
there are no kinetics involved. It's just the simple
statistic elementary probablistic calculation. I'm not --
I'm not dealing with any kinetic processes. So, the
kinetics -- if one considers kinetics of association then
there are process -- I mean, facts that could be regarded
as helping out of the dilemma. But there are also effects
that are devastating against the association of amino
acids and similar monimals (sic.) of life.

Q. What would that raise it to -- what level of
difficulty would that raise it to?

A. Beg your pardon.

Q. Would that make it 10 to the 50 thousandth, 10 to
the 100 thousandth?

A. I haven't set numbers on it yet I think the processes
don't to with some of the processes that I invoke.

Q. Why don't we take a break?



Q. Would you tell me what graduate degrees you have
in biology?

A. In biology?

Q. In biology.

A. No, I have taken no degrees in biology.

Q. In geology?

A. No, none.

Q. In paleontology?

A. No.

Q. Are there any sources that you've used in your --
in your work that you recognize as authoritative sources
on biology or genetics?

A. Yeah. I have used several texts.

Q. Which texts would those be?

A. Lehninger's Biochemistry.

Q. Who else?

A. Uh, in what, biology, biochemistry or what?

Q. Yeah. Any of those texts.

A. I don't carry a list in my head unfortunately, of
those texts. Quite a few of them I've used.

Q. Watson Molecular Biology of the Gene?

A. Watson -- yes, I've read his, yeah.

Q. Do you recognize that as an authority -- an
authoritative text?

A. Yes, I do. And I think the others are a miscellaneous


collection of texts.

Q. All right. What about the Benjamin Lewin Gene

A. Yeah. I've seen that. Yeah. Some of it.

Q. Do you recognize it as an authoritative book on
gene expression?

A. Not all of it. I've noticed -- I've looked at it,

Q. I'm not asking you if you know the whole book --

A. No. I would recognize him as an authority, yes.

Q. -- have you read the book -- and -- uh --

A. Not that -- I wouldn't say that I agree with
everything that's written there, but I would like to --

Q. -- and there are a witness offered in this trial,
Dean Kenyn. Are you familiar with his book, Biochemical

A. No, I haven't read it. No. No.

Q. Is it possible that life always existed, that
there was no beginning and no end?

A. Uh, it is possible logically. I think there is
no reason to doubt it -- for dissipating a logical
possibility, but the present data one has about the
universe seems to suggest that over time scales of twelve --
ten billion years, material gets turned around and heated
to temperatures that would eventually destroy the chemical



selection together with mutations, gene doubling, and so
on, provides a woefully adequate explanation for the
generation of verities, and that there is a need for a
continuing addition of information.

Q. But you are disputing only the mechanism and not the
fact of evolution.

A. The mechanism, yes, most certainly.

Q. Do you think that evolution is a fact?

A. Evolution as depicted in the fossil record and in
the general disposition of biochemistry of cross life, yes,
certainly, yes.

Q. Do you have a copy of your book, or did David
take it back?

A. I've got a copy, yes.

Q. Would you take out the copy of Evolution from Space?
Would you look at the bottom of page 64?

A. Yep.

Q. And the paragraph that begins at the bottom of that
page, which says, "Is it the same story within the bodies
of animals. We always talk as if we ourselves digested
our food. This is loose talk, for it is bacteria that
breaks --" or "it is bacteria that break the food down
for us into more elementary substances which our bodies are
able to use. Bacteria do much of the digesting. We only
create the conditions that make it convenient for them to


live inside us." What is the basis for your view that
bacteria do much of the digesting?

A. From what I've read in various places, it seems
to me that the -- the enzymes that are required for unzipping
a lot of the -- the -- uh -- let me just recall what was
the basis of that. It's a bacterial enzyme that are --

Q. Bacteria enzymes?

A. Enzymes in bacteria that seem to be required for
doing certain things. It's a --

Q. What is -- what is the source? Is it in one of
these texts?

A. No. I cannot -- I really cannot recall the origin
of that paragraph. This book has been put together by
two people, and I've looked over it -- I've looked over
the synthesis the scientists put together, and some of
it comes to me --

Q. Did Hoyle put together this chapter?

A. That particular paragraph, yes. Certainly I don't --
I don't really have the chapter and verse to -- to substantiate

Q. Does Hoyle have any expertise in biology?

A. Uh, in a self-taught way, yes, I think so. I think
there's no -- to my mind there's no good argument for
requiring expertise in the sense that you've been discussing,
like degrees in universities and so on.


Q. But he has no degree in biology; is that right?

A. No. He has no degree in biology.

Q. Do you believe that to be true?

A. That bacteria do much of the digesting?

Q. Yes. And much here, in the context here, seems to
me to be most.

A. Uh, I'm not really -- I don't think I have got
enough information at the moment to make that -- to
accept that categorically. It's my opinion -- it's my
impression by what I remember reading is that this bacteria
will play some role in digestion, but -- let me -- if that's
it, maybe I should do this -- this refers to humans --
this refers -- perhaps because we is used in that context,
it has to refer to humans, but bacteria in the guts of
sheep, for instance, involved in the breakdown of cellulose,
maybe that's the sort of thing that --

Q. Well, isn't it always cellulose that bacteria is
important in digesting?

A. It's a -- that's a particular -- right. Okay.

Q. But this doesn't make reference to cellulose, does

A. It doesn't make an explicit --

Q. Well, it says we always talk as if we ourselves
digested our food.


A. Yeah. It probably is an extrapolation from the
sheep -- faults (sic.) in the sheep story, but I don't
know what the -- the precise --

Q. Would you look at page 72, please?

A. Uh-huh.

Q. Would you look at the -- the top paragraph, not the
full paragraph, but the top paragraph.

A. Uh-huh.

Q. Where you say, "There is evidently a major chasm
between the modes of gene expression in the two kinds of
cell. A similar conclusion might have been reached
long ago from the fact that photosynthesis and prokaryotes,
that's P-R-O-K-A-R-Y-O-T-E-S, does not use water as in
eukaryotes, E-U-K-A-R-Y-O-T-E-S, a remarkable difference
mentioned already in chapter four." Did you write this

A. Let me recall the context of that. The first couple
of sentences I -- I recall --

Q. Was that before what I read?

A. What's that?

Q. I'm sorry.

A. The first couple of sentences of the paragraph,
"Genes of the..." (inaudible, witness reading.)

COURT REPORTER: Could you please
slow down. I can't understand what you're saying.


A. On the broken segments of the DNA, I think there
is enough evidence that this is true?

Q. What about the section that I read?

A. That the difference is in the way that the DNA
sequences are comprised -- uh -- would represent to my
mind the major chasm between the modes of gene expression,
between prokaryotes and eukaryotes. I would -- I would
go along with that.

Q. What is blue-green algae? Is it a prokaryote or

A. Blue-green algae -- uh -- are prokaryotes.

Q. Does it use water in a vial of oxygen?

A. Uh, no. I guess not.

Q. Are you saying it does not?

A. Does it use water? No, I think that it does not.

Q. You think that it does not?

A. I think that there's probably evidence -- I don't
know. I haven't got the facts in my head at the moment.

Q. Did you ever?

A. What's that?

Q. Did you ever have the facts in your head about this

A. About what subject?

Q. Whether or not blue-green algae is a prokaryote, and
whether or not blue-green algae uses water in a vial that


evolves oxygen.

A. Uh, uses water and evolves and --

Q. Well, what you're saying here is that, prokaryotes
do not use water --

A. Uh-huh.

Q. -- a remarkable difference. And you said that
blue-green algae is a prokaryote.

A. Uh-huh.

Q. And I'm asking you if it uses water.

A. Yes, I think it does. Yeah. I'm sure it does.

Q. You're sure that it does?

A. Yes.

Q. So you're saying that a remarkable difference
between prokaryotes and eukaryotes is that prokaryotes
don't use water?

A. I better look at the reference in chapter four.

MR. CAMPBELL: David, just for the
record, if Dr. Wickramasinghe's answers don't seem as clear,
it is almost 4:00 in the morning London time, and that --

MR. KLASFELD: I would have taken
it any time today.

MR. CAMPBELL: Our position is that --

MR. KLASFELD: This deposition is
at your convenience at the time that you set.

MR. CAMPBELL: I'm just explaining


the reason why it is that way.

MR. KLASFELD: Well, I understand
that, but you can't have it both ways. You can't say --

MR. CAMPBELL: I'm not trying to
have it either way. I was making a comment on the record.



Q. Could you turn to page 105, Dr. Wickramasinghe?

A. Yep.

Q. Would you look at the first full paragraph. It says,
"In the similar way, there must be a program that directs
the activity of a living cell. The question is, what
decides this program, and where inside the cell are the
instructions for it located. To take the easier second
part of the question first, while biologists are generally
agreed that such instructions must exist, the situation
concerning their location is indefinite. The usual
disposition is to suppose that the location is on the
chromosomes." Now, these next two parts is what I want
to focus on.

A. Uh-huh.

Q. "If so, a possible location would be in the so
called nucleolus, N-U-C-L-E-O-L-U-S, a chromosomal region
that appears decisively during the process of cell division,
and which would seem to preserve its identity in that

Transcript continued on next page

Deposition of Nalin Chandra Wickramasinghe - Page 2


process. Cell division is a violent, electro-mechanical
affair, and the location of the cell program must be such
as to preserve its integrity through..." mitotis?

DR. HOLTZMAN: Mitosis. It's a
misspelling. It's nothing.

MR. KLASFELD: What is the right

DR. HOLTZMAN: Mitosis.

"(normal cell division) and meiosis (a more complex double
division leading to the production of sex cells.)" Did
you write this section, or did Hoyle write this section?

A. Uh, this particular section, I think -- I'm pretty
sure it's not -- doesn't link -- doesn't click in my head
as being something that came from my pen. It probably --
I could defend any of those reasons, I suppose.

Q. Okay. Could you tell me what a nucleolus is?

A. It is a tiny -- a small -- uh -- a separate mini-
chromosome that's -- that's within the cell, the inner
nucleus of the cell.

Q. And what does it do?

A. It is -- what does it do? Do in the instant -- I
don't know.

Q. What is it's function?

A. Its function is -- uh -- it could be to contain the


program that directs the activity of a living cell. I --
I don't have any opinions about it apart from the
speculation that it could contain the main program of
the cell that controls its activities.

Q. And you say here, it appears decisively during
the process of cell division?

A. Uh-huh.

Q. What do you mean by decisively?

A. Shows up in the electro-micrographs and so on. It's --

Q. And you're saying that it appears during the
process of cell division?

A. Uh-huh. Uh-huh.

Q. Next you say, "Cell division is a violent electro-
mechanical affair." What does that mean, violent electro-
mechanical affair?

A. Uh, it's a -- I think it's an opinion on how cell
division -- on the mechanism of cell division, that it is
-- uh -- the separation of charges that dates to --

Q. Separation of --

A. Charges, on the nucle -- on the cell that leads
to -- uh -- leads to a breakup of the cell due to -- due
to forces -- due to electromagnetic forces that operates
on a charge separation.

Q. By cell division, you mean that the cells are
actually dividing in two?


A. Yeah.

Q. What is the source of this electro-mechanical force?

A. The sources are -- just the separation of the

Q. What's the source of the theory?

A. Oh, source of the theory. A conjecture, I guess,
and looking at the various writings and everything.

Q. What writings?

A. Pardon?

Q. What writings?

A. On the -- on the subject of cell division.

Q. Anyone in particular?

A. No.

Q. Okay.

[Testimony continued on next page.]


Q. I gather from reading your book that what you believe
is the earth passed through or nearby some kind of cometary
source of life forms that rain down on the earth and seeded
the earth with life; is that right?

A. Uh-huh.

Q. Were these seedings, was it material composed of
DNA or was DNA a part of the materials that seeded the

A. Yeah. The idea is that it's living cells; that all
the -- the full complement of biochemical in the living
cells that seeded the earth, not just one time in the past,
but it continues to do so right through to the present

Q. Do the -- these life forms that come down, do they
incorporate themselves with presently existing life forms?

A. Uh-huh. Wherever they could do it, it does that.
If it does not it just perishes.

Q. Through what kind of mechanism does it incorporate
itself with living life forms?

A. Through the incorporation in the cellular DNA while
the processes of one recognizes as being infective; that
the process that is recognizable as viral diseases and so
on. This is one way in which the incoming viruses could
be -- incoming DNA could be incorporated into the cells.

Q. Do you think that the -- I don't know if you were


present in the courtroom today when there was a discussion
of the possibility of an explanation for the earth's
geology by the force of one major catastrophe.

A. I wasn't there then. Was it in the afternoon or --

Q. I don't remember at what point it might have arisen.

A. No.

Q. Are you aware of any scientific evidence for the
fact that the earth's geology could be explained by one
single catastrophic event?

A. No.

Q. Would you think any rational scientist could think
that was true?

A. Not on the evidence that I've been able to look at,

Q. Do you think that humans and apes have a common

A. Yes, I do, with the reservation that I don't believe
that monkeys -- apes could lead to humans without some
additional information that is specific to the design of

Q. I'm not asking if apes led to humans. I'm asking
if at some point in the past they had a common ancestor?

A. Yeah, I believe so.

Q. You believe that's true?

A. Uh-huh.


Q. Do you think it is possible that insects have greater
intelligence than people?

A. No, not on -- it depends on how one defines intelligence.
But if one measures the intelligence of -- operation of
capabilities of (Inaudible) assesses human or monkey
intelligence, I would say no.

Q. Do you think it is possible that a large society of
insects could have more intelligence as a group than humans?

A. You mean a social unit of insects or something?

Q. Yes.

A. Not in a way that one would recognize as intelligence
in the usual -- in the usual definition of intelligence.
But it could be that in a conflict or confrontation that
might develop, the course of evolution between insects and
higher evolved forms of life, that the collective behavior
of insects and the genomes of insects have a better chance
of beating a higher intelligence, I think, even though the
-- even though the human intelligence is by usual standards
higher than the insect intelligence. I think it is -- I
believe it is highly significant that humans have succeeded
in demolishing even one insect species through chemical
(Inaudible) warfare. All the methods of -- all the surfaces
that have been used by human scientists have failed to do
very much.

Q. Is it possible to falsify the basic theory that you


testified to about tonight and will testify about tomorrow?

A. Yes. I think there is an experiment that would be
done to detect life outside. If it turns out to be negative
consistently, then I think the theory is falsifiable (sic.).

Q. What kind of experiment would you suggest?

A. I would say looking directly for life on the surface
of -- in the interiors of comets and cometary particles,
scooping up the material that the earth is picking up, the
cellulite (sic.), and looking for active biology, and the
experiment could be done. There is no reason why it is
not a doable experiment. So that the experiment is
conducted with a negative result, then it would be a direct
falsification. That's the idea.

Q. Do you think that there are any ethical implications
of evolution?

A. Not in a very -- not in -- in a particular type --
particular model of evolution or in evolution in general,
or what? I don't --

Q. Either.

A. I think there are -- there are ethical issues to do
with particular models of evolution.

Q. Which ones?

A. Well, I suppose -- let me just stick to the Darwinian
model. I think there are probably ethical issues that have
been discussed by sociologists and so on, from several


places at several times.

Q. Which ones for instance? Not which sociologists,
but which implications?

A. Which implications. I think that the -- the
Darwinian -- the Darwinian evolution theories imply that --
that the stronger social groups necessarily overrun and
dominate the weaker social groups. And wherever this has
happened in the world, like the -- and there is sort of
a moral justification in that simplicity. In sociological
situations there is an overt attempt to dominate the weaker
groups by the larger groups. The implication being -- the
justification being that it happens in biology, and therefore,
it is a reasonable thing to happen in society.

Q. Do you think that the rise of Nazism was in any
way related to evolution?

A. Yes, I do. I think there is -- not to -- it is --
that is my belief. I don't have any substantial proof
of it, but I think that it is more than likely to be
connected to it.

Q. The rise of Nazism is more than likely to be connected
to evolution?

A. With Darwinian evolution.

Q. You make reference in Evolutions In Space to a
possible predecessor of life on this earth, being silicone
chips somewhere else in space.


A. I don't think -- I would like to withdraw that.
Again, that is my colleague, and I think it's conjecturable.
It is the analogy that he makes -- that one could make
with the computer. I don't know how far one could take
with the analogy, but .... The semiconducting properties
of siliceous material is such that it could contain
information and could --

Q. This last chapter, "Convergence to God," Hoyle wrote

A. That's -- entirely, yes. In fact, I don't even --
it is one of the issues that we have had a lot of discussion
and debate about, and I don't necessarily subscribe to
everything that is written there in that chapter.

Q. There is no disclaimer though?

A. There is no disclaimer, no. I don't have any strong
brief for it either. But I think -- I think from the
general claim, the general statements there that are involved
in that chapter, I tend to agree with.

Q. Do you agree that there might be any number of steps
between God and life on this earth?

A. Logically, yes. I think it is possible to envision
a hierarchical structure of intelligence that's above us.
It seems to me to be the study of arrogance, beyond words,
to say that we are the highest level of organizational
intelligence that's possible in the form of a living system.


And I believe that there could be a multitude of steps --
many steps above the human intelligence leading ascentotically
(sic.) to one of those equations and symbolic statements
that have been made.

Q. I wasn't going to call it an equation, but is that
what you would call it, this business with an arrow and then
five question marks, and an arrow and four question marks,
and an arrow and three question marks, and an arrow and
two question marks? The way I sort of understood this was
God --

A. There are big unknowns and we were just putting
together the possible logical connections that might exist
between the sequences of unknown intelligences.

Q. If I gave you a factorial could you reasonably,
quickly compute a power of ten for me?

A. With a calculator I could, yes.

Q. Do you have a calculator?

A. I didn't bring one with me, no.

Q. Are you familiar with Sterling's formula?

A. Yes.

Q. Without a calculator could you do a reasonable

A. To a factorial -- to a large number.

Q. If I gave you a factorial could you give me a
reasonable approximation to the power of ten?


A. Yes, a reasonable approximation I could.

Q. What -- how would you imagine this creator working
somehow subject to the laws of chemistry and physics, and
why put that limitation on the creator?

A. Why should it --

Q. Actually, I'm asking two question, which I'm not
allowed to do. One of them is --

MR. CLARK: I was just fixing to
ask you to ask them one at a time.

Q. My first question is why put that limit on a creator?

A. On the -- you mean the limits of staying within the

Q. Being within the laws of chemistry and physics.

A. Well, if it is possible to be outside, then I think
it is not part of the inquiry that scientists are supposed
to be engaged in, and it becomes metaphysical.

Q. Excuse me. But then why posit the need for a creator
if you are going to have him working by the laws of chemistry
and physics?

A. I don't posit the need for a creator. I think --
I think one could logically -- maybe there are circumstances
in which one could logically infer that a certain arrangement
of molecules in the universe as being put together more
probably by deliberate action than by random shuffling.
And so to say that there was a creator that could have put


it together -- I could give you an example -- I mean, if you
are a spaceman who came -- descended into this room, looked
at the faces around this table, talking a strange language,
he might have looked at some of this equipment here and
someone asked the question, "Are these -- are all of these
bits and pieces a natural result of random shuffling or
was it put together by a creator?" And to surmise that
this tape recorder had a human creator is not in any way
outrageous. I can't see any reason why it should be
considered to be improper to make the conclusions if one
looks into the problem and assesses the odds of that tape
recorder being put together, plus all the problems of the
-- all the various (Inaudible -- sounds like consitron)
atoms coming that way be a certain number.

Q. Are you aware of any limits between -- of genetic
change such that there is only change within limited kinds?

A. An empirical law or an empirical --

Q. Any kinds of genetic limitation that would limit
through the course of time a change from bacteria to man.
Are you aware of any scientific genetic law that would limit
that change?

A. I don't know what you mean by scientific.

Q. The statute, which is the subject of this lawsuit,
posits something called creation-science, one of the tenets
of which is changes, that plants or animals could only change


within fixed limits of originally created kinds of plants
and animals. Are you aware --

A. Of the -- of a nature law that limits it?

Q. Yes.

A. I don't know whether there is an empirical -- I
think I -- I think that there are limitations to the
extent to which a bacterium could change. Do you want me to
give you my personal opinion?

Q. Well, let me ask you a different question. Your
theory does not suggest that -- have you read any creation-
science literature at all?

A. I don't know what --

Q. Are you familiar with the expression creation-science?

A. Not in the general accepted -- not in what I think
seems to be the conventionally generally accepted view of

Q. What is your understanding of this lawsuit?

A. What is my understanding of the lawsuit? Do you want
me to tell you what I make of it?

Q. What do you understand is the issue? Why are you
here? Why am I here? Not in the grand sense, but in the
small sense.

A. The issue seems to be that the State of Arkansas
has passed this act within its Legislature to give an equal


coverage of creation. I know it is creation-science, but
I would like to extract it and put it in a wider -- slightly
wider context. All right? But I would interpret -- I
don't -- I am not concerned about the details, letter of
the law there, but I think the --

Q. Unfortunately, that's where we are at this period
of time.

A. -- the spirit of the -- I think I would like to
stick to the spirit of the law that I feel in some ways
sympathetic towards. The attitudes to creation have been
sort of almost a blanket -- almost a complete condemnation
of it by scientists, any creation. And I think it is
perhaps not a reasonable thing to condemn it without having
a proper inquiry as to whether it could be accommodated
within the empirical frame of the science. And some
creation -- some concepts of creation may be well within
the purview of empirical science. And so if one is dealing
with sort of the origins of life or some -- an issue like
that, it is my belief that the -- that there is no evidence
at all for chemical evolution. I think there are great
claims that chemical evolution could do something, but I
could give you a dozen reasons why I think that chemical
evolution wouldn't lead to anything. So in the absence of
such -- in the absence of any nonmechanism for life emerging
from random shuffling through chemical evolution, I think


it is reasonable to explore an alternative possible.

Q. Are you using this as a form for your theory?

A. No, I'm not.

Q. How did you come to testify?

A. Because Mr. Clark invited me to do so, and to ask if
I could point out the aspects of my joint work with Fred
that might in some way relate to the need for creation,
even in a limited sense, and the inadequacies of Darwinian

Q. Was Mr. Clark the first person that you heard from
in this lawsuit?

A. The first person that approached me about coming
here was -- it wasn't you. It was one of your colleagues.

MR. CLARK: Mr. Williams probably.

WITNESS: Mr. Williams or Mr. Tim --

MR. CLARK: Tim Humphries. Tim
Humphries probably.

Q. But he was the first -- you didn't hear about it
from anybody in the creation-science movement?

A. No.

Q. What -- where did you get your notion of -- sort of
the classic -- what the classic model is for chemical
evolution and what specifically do you disagree with?

A. Well, I think the sources are numerous. I don't
know whether I could recall them in detail. I am sure


most of the symposiums, you know, on cosmochemistry by
some people. I could not (Inaudible - Witness mumbling)

COURT REPORTER: Please don't

WITNESS: I think it is getting
rather late and I think maybe we should reconvene if there
is a need to have another.

MR. CLARK: Do you have many more
questions, David?

MR. KLASFELD: Not too many more,
I don't think.

MR. CLARK: Ten or fifteen minutes,
you think?

MR. KLASFELD: What time is it now?

MR. CLARK: A quarter 'til 10:00.

WITNESS: The mumbling referred
to a name. You asked me resources and I thought of one
person that I read about, was Noda, N-O-D-A, was one
author that put together -- he wasn't an author, but he is
an editor of a symposium.


Q. Are you familiar with the experiments of Stanley

A. Oh, yes, I am very familiar with him.

Q. What is, in your mind, the failure of those experiments?


A. Those experiments don't tell you anything except
that an inorganic -- a mixture of inorganic acids could be
put together using -- injecting nonthermodynamic sources of
energy, ultraviolet light and sparks of electric discharge.
If you put these through a mixture of inorganic acids,
suitably a chosen mixture, then you could get substances
that are similar to the biochemical monomers, sugars, and
amino acids, and nucleotides and so on. That's the extent
to which those experiments go.

Q. What do you mean when you say similar to -- you said
that it was similar to these various chemicals. Why similar?

A. Because you get some amino acids that are nonbiological
and you get amino acids that are biological. You get sugars
that are biological and that are nonbiological. So it
includes the set. What you get in trace quantities includes
the set that -- includes the set of molecules that are
considered to be the bows (sic.) for the monomers.

Q. Isn't this straying pretty far from your area of

A. What is?

Q. Your judgements about the biochemistry.

A. I don't really understand that question.

Q. Well, you are an astronomer and a mathematician.

A. Yes. Does that clear --

MR. CLARK: You asked him and he responded
to your question.


Q. Do you believe that insects moved through the
universe on comets and meteorites or other bodies?

A. It's a possibility that we could discuss, but I
don't think that one could make a decisive statement on
that one way or another.

Q. But you thought it was a sufficiently worthwhile
possibility --

A. To discuss.

Q. -- that you put it in the book?

A. Yeah. Uh-huh.

Q. Would you look at section 4a here, where it says,
Definitions in Creation-science, do you see that? See
that, 4a, 1 through 6. Would you read that for me and
tell me if you agree with any of those points?

A. There's one I think I don't -- sudden creation of
the universe and its life from nothing. The life I would
cross out for the time being, but I suppose sudden creation
of the universe, energy, is the standard Big Bang cosmology.
I can't complain about that. I don't agree with it either
as a theory. I wouldn't buy one particularly. I think --
I think it's a big -- I was just being facetious. It
could include aspects of Big Bang cosmology.

Q. Well I prefer for you not to be facetious. Do you
agree with 4a, 1?

A. As a -- as a possible -- no, I don't agree with


4a, 1, no.

Q. What about 4a, 2?

A. Yes. I do agree with that. I think it's my
believe that is true.

Q. Which is 4a, 2.

A. Sudden creation -- no it's not. It's insufficiency
of the --

Q. Okay. What about 3?

A. Not only -- now I think that -- no. Not in the
way it's stated there.

Q. Okay. What about 4?

A. No.

Q. What about 5?

A. No.

Q. What about 6?

A. No.

Q. Okay. Does the creator you make reference to have
any form?

A. I can't draw anything on the board, no. I can't
depict it in the way that -- I don't know. It's a concept
that may have validity, logical place in the logical
argument, but I don't -- uh -- until one -- in the present
state of our knowledge I think the answer is no.

Q. In the book Diseases From Space, you make reference
to the human nose; do you recall that?


A. Yes. Yeah.

Q. What is the significance for you of the shape of
the human nose?

A. To me personally?

Q. Well, in terms of the book. You say the evaluation
of the human nose, on page 99, would also permit one to
conclude that transmission from individual to individual
has never been a dominant factor in the spread of disease,
for transition would have happened in the forest just as
much as on open ground. What is there about the nose --

A. (inaudible, witness mumbling) The shape of the
nose was first brought into that argument because we felt
that a direct inhalation of material that is in the form
of an aerosol dripping on the -- descending onto the
surface of the planet would be taken up more effectively
more readily by a nose without a protective -- without an
apparent canopy, like -- sort of like a human nose. And
the need for -- for -- for the canopy like structure, might
have been an evolutionary property that permitted the
primitive man or the primitive ape to get out of the
relatively secluded, protective environment of the rain
forest, a lot of leaves and foliage that would have been
an asset in the sense of not getting -- not taking --
inhaling too much of the -- the aerosol, in the sense that --

Q. You mean we're better off with our nostrils facing


down than facing up?

A. I would -- I would say so, yes.

Q. Do you believe that the transmission from
individual to individual is not the dominant factor in
the spread of disease?

A. Uh, it depends on which disease that one is talking
about. I think in the case of influenza -- is what I've
looked at in great detail -- I think the -- that the
statistics point decisively to a negative answer, yes. I
believe that it is not the dominant factor for --

Q. What is the dominant factor?

A. The dominant factor is -- is an aerosol or some
material that is turned around in the rain and the weather.

Q. Have you ever recorded the arrival of any of these
seedings on the earth?

A. I don't understand the question. Ever recorded it
what -- in what way?

Q. Any kind of -- do you have any scientific evidence
that the -- these seedings have ever taken place?

A. The nature of evidence that was discussed in
Diseases From Space is --

Q. No. I'm talking about evolution from space, sir.
Do you have any evidence that these seedings have in fact
taken place?

A. Seedings of diseases or bugs or life or --


Q. The seedings of any kind of form -- life forms
that would have given rise to life on the planet?

A. I haven't -- I haven't discovered evidence for
myself, but I think there is evidence in the fossil record
that the origins of life, the very abrupt beginnings of
life, the first cretaceous explosion of living -- the
several explosions of -- the so called -- I forgot what
they call it these days. The punctuated equilibrium
that describes, not a mechanism in my mind, but to my
way of thinking. But it's just the phenomenon. It's the
phenomenon that's describing these words, punctuated
equilibrium. There are -- there are several discreet --

Q. Do I understand your theory of sort of the regular
seedings to be things that gave a boost to evolution to
speed it up at certain points?

A. Uh-huh. Uh-huh. Yes.

Q. And in what manner did the life form that seeded
the planet interact with the life forms that were here

A. Well, the fragments of DNA which carried the
information from new species came in the form of viruses
That were taken up by the set of living creatures and living
organisms that were on the earth, evolved at any given
time. And whenever the particular virus carrying the
information was incorporated in the genome, then it was


let to the possibility of leading to -- of progressing
forward and producing them.

Q. I promise this will be the last question. Are you
aware of the enzymes amylasetrypsin and chymotrypsin?
Are you aware of their functions?

A. No, not of the --

Q. Not?

A. Not the functions of the individual enzymes, no.
But these are details. I don't -- I don't know. Is there
any --

Q. But do they function in the digestive system, as
far as you are aware of?

A. No. I don't have the facts in my head. I've been
very concerned --

Q. Fair enough.

A. -- with the systematics of the operation, not the

Q. Thank you.

(Thereupon the above styled
deposition was concluded at 10:10 p.m.)



I, __________________________, the witness, hereby
certify that I have thoroughly read the transcript of my
deposition taken on ______ day of ______________, 1981, and
have made any necessary changes or corrections to make the
transcript a true and accurate accounting of my testimony given
on that day.


(Date signed)

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

COUNTY OF ____________)

I, __________________________, a Notary Public in and
for __________________ County, Arkansas do hereby certify that
the above deposition was read, corrected and signed in my

________ day of ___________________, 1981.

My commission expires ___________________________________
on __________________ Notary Public






REPORTING SERVICE, a Notary Public in and for Pulaski
County, Arkansas do hereby certify that the facts stated
by me in the caption on the foregoing deposition are true;
and that the foregoing deposition was transcribed by
me or under my supervision from my machine shorthand
notes taken at the time and place set out hereto, the
witness being first duly cautioned and sworn to tell the
truth, the whole truth, and nothing but the truth.

16th day of December, 1981.

Laura D. Bushman, Notary Public
in and for Pulaski County, AR

My commission expires 1-10-84