A. Lack of more sufficient exact analytical
data of natural products.
We don't have the exact analysis of natural products
to compare any closer than superficial comparisons that
they are similar with the available data.
It looks like it is a good model.
Q. Do you know what the traditional scientific
explanation for the formation of coal is?
A. There are a number of explanations and I've
forgotten all the ones that have been suggested other
than I got the general consensus that it was a slow
Q. And how did this slow process operate?
A. Biomass was collected perhaps by leaves or limbs
dropping down and piling up and collecting to form
sufficient carbonaceous material which could then later
on be slowly changed into coal or oil.
Q. Do you know whether or not scientists have
identified the activity of fungi or bacteria as important
in the formation of coal?
A. In my reading on the subject some have suggested
that it was very important.
And in my reading letters to the editor, others
would challenge that.
So it is apparently being discussed with varying
Q. Who are the individuals who are challenging
A. I do not recall that.
That was not the main thrust of my research.
I simply came across it in passing and wasn't
particularly interested in it.
What I was interested in was a process that we wanted
to work at.
Q. Does a challenge constitute a dismissal?
A. No, certainly not.
Q. Could you describe how wood decomposes?
A. How wood decomposes?
Q. Wood decomposes.
A. Normally wood decomposes by bacteria decay and
eventually returns to mineral matter that was in it and
carbon dioxide and water and reenters the cycle.
Q. And that does not operate during the formation
A. That's correct.
Q. When did you last read a published book or
article on the subject of the age of the earth?
A. This fall I read -- it seems to me that I read
One was by -- a little book called "Age of the Cosmos"
by Harold Slusher and there were several articles in the
literature relating to that in, I believe it was Science
And in relation to Age of the Cosmos and the
Red Shift by Arp, was one of the authors, and there were
several others I don't recall.
I believe I have a couple of those in the deposi-
Q. When did you last read a published article
or book on geology?
A. A published article or book on geology.
I tried to read -- I try to stay abreast of some of
the -- I subscribe to a number of professional magazines
including Science Magazine and The Scientist put out by
the New York Academy of Sciences, Sigma Xi publication.
Q. Have there been any article or books published
recently which agree with your position?
A. On a young earth?
A. Yes, there was another one I read this fall
It seems to me there were two issues or two articles
that appeared, as I recall, in, I think, the Bible Science
Newsletter on isochron dating.
Q. Do you know if the Bible Science Newsletter
is in general circulation and usage?
A. It is.
Q. Do you know if that is subject to peer review?
A. I think it isn't.
Q. Have you read any other articles or treatises
recently on geology?
A. I tried to read the journals and that there
have been articles that have been in there and I come
across them but I just at this point don't recall.
Q. Do you believe that faith is a necessary element
in the application of understanding of evolution?
A. Yes, you have to have faith in your primary
Q. Do you believe faith is a necessary element in
the creation model?
A. Yes, you have to have faith in your primary
Q. What is the nature of that faith?
A. It is your a priori, it is where you start to
look at the data to draw conclusions.
Q. Is it a religious faith?
A. It depends on how one might define religious
faith, I suppose.
Q. How do you define religious faith?
A. Generally, I would define religious faith as
the starting point or assumptions for one's theology.
MR. LAHIFF: I am sorry, could you read that answer
for me, please.
MR. LAHIFF: Q. But does your religious faith act
as any assumptions in the field of creation science?
A. Would you say that again, please.
Q. Does your religious faith set forth any of
the assumptions upon which you believe in creation
A. My religious faith is consistent with the
assumptions of creation science.
Q. Are you aware of any tests to which the model
of creation science has been subjected?
A. The data are there.
Involved in creation science are one of the things
we talked about this morning, where the terraced lines are
and they are there.
Q. But is it possible to test your theory?
A. Those terraced lines were formed -- you can test
to see how they were formed and the tests that we per-
formed indicate they were formed by waste.
Q. Do you know what sedimentary facies is?
A. I know what sedimentary is.
I am not familiar with the term facies.
Q. Have you ever read any books or treatises on
Q. What books or treatises have you read?
A. One that interests me and several come to mind.
There are several.
But one that interests me because it was not my
field and I wanted to see the data was Geology Illustrated
by Shelton and I don't remember the first name.
Q. Could you describe for me a little bit about
the book, what the book covers.
A. He discovers a number of -- he's an amateur
photographer and he is an airplane pilot and has an
interest in geology. And it covers photographic pictures
of interesting geological areas along with a discussion.
And in the book, the one that interested me very,
very much was his discussion of geologic time.
Q. What was his discussion of geologic time?
A. Well, the gist of his discussion on geologic
time was that stratigraphy doesn't tell us absolute
He says -- paraphrasing -- that it is not possible
to know how long it takes to lay down a layer or if we
knew that, how much time there was between layers.
And he makes a comment, as a number of others did
when I first began to study this area, that radioisotopes
were the only way that geologists had of measuring
dates and years.
Q. How does stratigraphy relate to geologic time?
A. Well, we have layers in the earth and we see
Those layers presumably were formed at rates which
involves time and since there were rates time is involved.
The evolutionists use stratigraphy as a time index
or has in the past.
Q. Which scientists are you aware that have
used stratigraphy to indicate geologic time?
A. In the broad sense -- now, we are talking
about stratigraphy in the broad sense, not a study of
that as a field or discipline.
Which scientists use the layers as a time index?
A. As a time index?
Q. As a time index.
A. Most of the evolutionary writers that I have
Q. Could you identify specifically any of them
A. G. G. Simpson, Ldyard Stebbins.
I don't recall right now some of the others.
MR. CHILDS: It is quarter till.
THE WITNESS: Is your voice as hoarse as mine.
MR. LAHIFF: It is now 2:45 and Dr. Chittick is
leaving to catch his plane.
I think there are a lot of things that we still
could have covered.
Unfortunately he is not available.
As I understand it, you will provide us with copies
of the slides that you intend to use during your testimony?
MR. CHILDS: Just as soon as we can, right.
MR. LAHIFF: And you will provide those to Bob
MR. CHILDS: Yes, no problem.
MR. LAHIFF: Thank you very much.
[Photocopy of document entitled
"Argon-40: Excess in Submarine
Pillow Basalts from Kilauea
Volcano, Hawaii" marked Plaintiffs'
Exhibit 5 for identification]
DR. DONALD ERNEST CHITTICK
STATE OF CALIFORNIA )
CITY AND COUNTY OF SAN FRANCISCO )
I hereby certify that the witness in the foregoing
DR. DONALD ERNEST CHITTICK
was by me duly sworn to testify the truth, the whole
truth, and nothing but the truth in the within-entitled
cause; that said deposition was taken at the time and
place therein stated; that the testimony of said
witness was reported by
LINDA L. CHAVEZ and THOMAS A. LIBATIQUE,
Certified Shorthand Reporters and disinterested persons,
and was thereafter transcribed into typewriting, and
that the pertinent provisions of the applicable code or
rules of civil procedure relating to the original
transcript of deposition for reading, correcting and
signing have been complied with.
And I further certify that I am not of counsel or
attorney for either or any of the parties to said
deposition, nor in any way interested in the outcome of
the cause in said caption.
IN WITNESS WHEREOF, I have hereunto set my hand
and affixed my seal of office the ____ day of November