Deposition of Ariel Roth - Page 2


you have been researching?

A. You say has the Bible suggested possible

Q. Yes.

That is, would you say that your reading of the
Bible has ever suggested to you that the answer to some
problem that you were working on might be X or whatever?

A. I don't think one can divorce what he reads
from explanations he tries to arrive at entirely, but
in science, explanations can be of a variety of sources,

What I am trying to do is say the scientific
explanation need not be related to what I get from the
Bible or anthropology but it can influence one's
scientific explanation.

Q. Are you able to explain the way in which the
Bible might influence your scientific explanation in
any particular instance?

A. It could suggest some ideas to be tested.

Q. Do you recall any specific occasion that has
been the case?

A. Well, I'll get back to -- it can suggest a
catastrophism, but other sources can suggest the same

I will add to that comment that many geologists
are suggesting catastrophism, and they have gotten
their ideas from the data, science or their experiments
or from concepts that they have imagined.


In science we are concerned about whether the data
fits the concept, not especially where the concept comes

Archimides got his concept of buoyancy from a

Q. Dr. Roth, have you done any research in

A. Not directly.

Q. Have you done any indirectly?

A. I've analyzed some structures in terms of
whether or not they might be deposited rapidly or slowly.

Q. Have you had any geology training or any
training related to catastrophism other than what you
mentioned earlier, your geology study at U.C. Riverside?

A. Not formal training.

Of course, most geologists have not had training
in this direction because this is a new trend in

Q. Have you had any geology training at all
other than what we discussed earlier about your work at
U.C. Riverside?

A. Not formal training.

Q. Have you had any informal training?

A. Well, whenever one goes out in the field and
field conferences, he learns quite a bit. When one
goes to scientific meetings, he learns quite a bit.

Q. Are there any other bases than the geology
training you had at U.C. Riverside and these references


that you have made to scientific conferences and field
trips for your knowledge or views in catastrophism?

A. Geological literature.

Q. What geological literature in this area have
you read?

A. Well, I get all these journals of which I am
a member of the society. I don't read every journal.
I wish I had time to. But that's part of it.

And, of course, there are reference books.

Q. Could you tell me the primary reference books
and journals in this area that you read?

A. Geological Society of America bulletin,
The Society of Economic Paleontologists and Minerologists
bulletin, The American Association of Petroleum
Geologists bulletin, books of one type and another.

Q. Do you recall any titles?

A. The Nature of the Stratographical Record by

Q. Do you recall by whom that is published,

A. No.

It is in England. It is British.

Q. Any others?

A. Not right offhand.

Q. Sir, would you regard yourself as an expert
in geology or catastrophism?

A. No.

If I can amplify on that, I am an expert in no


area. The more you study, the more you realize how
little you know.

Q. Would you say then that you regard your
command of geology and catastrophism as the equivalent
of your command of marine biology?

A. No, not as good.

Q. And is it correct then that you would not
regard yourself as an expert in marine biology, either?

A. Well --

MR. WILLIAMS: Let me say for the record,
obviously, who is an expert has a legal connotation.


MR. WILLIAMS: And Dr. Roth, despite his own
modesty, we would consider him legally to be an expert.

MR. WOLFE: My inquiry is not based on who may
or may not be legally qualified but, rather, Dr. Roth's
own appraisal of his interest in his work, and that's
what I am making inquiry about.

THE WITNESS: To the extent that you call a person
who has published a number of papers in this area an
expert, I would qualify.

MR. WOLFE: Q. That is, in marine biology?

A. Marine biology.

Q. Would you say that you qualify as an expert
in geology or catastrophism by the same criteria?

A. By the same criteria, I would say no.

MR. WILLIAMS: Can we break now?

[Recess taken.]


Q. Dr. Roth, have you had any contact with the
defendants in this action about the case?

A. No.

MR. WILLIAMS: You are talking now about the
defendants, the named defendants?

MR. WOLFE: The named defendants in the action.

THE WITNESS: You mean the persons whose names are
at --

MR. WOLFE: Q. They are approximately the
Arkansas State Board of Education and its members.

A. No.

Q. Have you had any contact with any Creation
Science groups or institutions about this case?

A. No.

Q. Have you ever seen a copy of the statute that
is at issue in this action?

A. This?

Q. Yes.

A. Yes.

Q. When did you obtain a copy of the statute?

A. Two or three weeks ago.

Q. From whom?

A. The Attorney General's office.

Q. Had you ever seen it prior to that time?

A. No.

Q. Have you ever seen a model Creation Science
bill drafted by any Creation Science group in the past?

A. I have seen some drafted. As models, no.


Q. Have you ever seen bills which were submitted
in other state legislatures than Arkansas?

A. The one that was submitted in Oregon.

Q. When was that, sir?

A. Last spring.

Q. What was the occasion for your seeing that

A. When they asked me to come up there and speak
on behalf of that bill.

Q. Who asked you do that?

A. Congressman Davis.

Q. Was he the Oregon congressman?

A. He was one of the sponsors of the bill.

Q. Sir, do you know a man named -- I will with-
draw that. I take it back. I do not withdraw it. You
mentioned Mr. Bird earlier, but do you know Mr. Wendell

A. I have heard of him. I have never met him.

Q. Have you ever had any correspondence or
telephone conversation with Mr. Bird?

A. No.

Q. Have you ever had a phone or letter
communication with John Whitehead?

A. Yes.

Q. And can you tell me when and on what subjects?
Were there copies of correspondence with Mr. Whitehead
among those that you offered to me earlier today?

A. Yes.


Q. Do you recall the subject on which you
corresponded with Mr. Whitehead?

A. It was about a debate, a written debate in
Liberty Magazine over the issue of whether or not
creation should be taught in the public schools, and I
was debating Bill Mayer. I wanted some constitutional
advice from a constitutional lawyer.

Q. And Mr. Whitehead offered some advice on that

A. Yes.

Q. Have you ever had any contact with Mr.
Whitehead about this case?

A. No.

Q. Have you ever had any contact with Mr.
Whitehead about the Arkansas statute?

A. No.

Q. Have you ever communicated with Mr. Whitehead
about the Oregon statute or any model statute?

A. No. You still have my publications. I can't
look it up.

Q. They are still being copied.

Sir. have you ever given testimony in the past in
a court action or before any legislative or administrative

A. Yes.

Q. On what occasions?

A. State Board of California.

Q. And what was the subject?


A. Whether or not creation should be included
in the public schools.

Q. Have you ever given testimony to any other
school board or board of education?

A. Oregon.

Q. And when was that, sir?

A. Last spring.

Q. Was that before the Oregon Legislature?

A. That was before the Education Committee of the
Oregon Legislature.

Q. Have you ever given testimony before in any
court action?

A. Not related to this subject?

Q. Would you tell me what subjects?

A. Well, I will have to change. I don't think
in court. I don't think I have given testimony in court
on any subject. I made a deposition before but not
testimony in court.

Q. What was the subject of the action in which
you previously gave a deposition?

A. It was about a road near my house which has
a dangerous curve on it, and I was asked to testify
regarding the accidents that occur there near my house.

Q. Sir, have you ever been paid for any of the
appearances that you have just mentioned before the
California Board of Education, the Education Committee
of the Oregon Legislature?

A. Unfortunately, no.


Q. Do you ever recall having given other
prior testimony on any subject before a legislative body
or administrative government body?

A. I can't think of any.

Q. Have you ever made speeches or taken part in
debates about Creation Science or evolution in the past?

A. Yes.

Q. On what occasions, sir?

A. The written debate that you have in Liberty
Magazine was orally presented between Dr. Bill Mayer who
was the proponent for excluding creation from the public
schools and myself suggesting that it ought to be

I have talked at the University of California at
Riverside on the subject of creation to the Geology
Department at a seminar.

Then at the San Diego State University I put on a
series of seminars there once.

I taught a course at DeAnza College on the subject,
West Valley College also. I will correct that last
statement. I have given -- no, that was a course also.
Correction. Back to where we were. DeAnza College and
West Valley College.

Then, of course, on numerous occasions lectures to
classes, Seventh-Day Adventist Church groups.

Q. When you say "lectures to classes" do you
mean college courses or --

A. Yes.


Q. Have you ever been paid for any of the
appearances for the written debate that you mentioned
just now?

A. Yes.

Q. For which ones?

A. What is that?

Q. For which ones?

A. The Liberty. They gave me an honorarium for
that for both the oral and the written.

Q. Do you recall how much that was, sir?

A. Roughly it was around a little less than
500 for the written one and somewhere around 200 for the

Q. Did the documents that you gave me earlier
include the copies of or the transcript of any of these
classes or debates that you have mentioned?

A. Yes, the Liberty debate is among those
documents as one of my publications.

Q. Do you have transcripts of any of these
debates or classes that were not included among those that
you gave to me this morning?

A. Well, let's put it this way: The oral
debate was essentially the written. However, I probably
did not read it per se; I talked. No transcripts.

Q. Sir, have you ever heard the opinion
expresses that Creation Science is really just a ploy or
a device of propagating Christian faith?

A. Yes.


Q. On what occasions have you heard that?

A. I cannot tell you exactly. I don't want to
implicate somebody when I'm not sure they said it, but I
think Bill Mayer says it in the debate. I'm not sure.
I would have to read it to tell you.

Q. Do you recall any other instance?

A. No.

Q. Have you ever heard that Creation Scientists
state that position?

A. Creation Scientists what?

Q. Have you ever heard a Creation Scientist
state a position that Creation Science is a device or
ploy for spreading the Christian faith?

A. No.

Q. Sir, have you ever had any criminal arrests or

A. Traffic tickets.













Q. Other than that?

A. No.

Q. Dr. Roth, when did you first hear about this
court case brought in federal court in the District of

A. About the ACLU case?

Q. Yes, sir, this suit.

A. About three or four weeks ago.

Q. And from whom did you hear it?

A. Tim Humphries.

Q. And have you had contact with anyone at the
Arkansas Attorney General's office aside from
Mr. Humphries and Mr. Williams about this suit?

A. Except the secretaries who deal with travel
arrangements, that's all.

Q. Sir, are you being paid for your appearances
in this action?

A. No.

Q. Are you receiving expenses or any fee for

A. Yes.

Q. Can you tell me what expenses you receive?

A. Actual cost.

Q. By whom are they being reimbursed to you?

A. By the Attorney General's Office, I guess,
or the State of Arkansas. I don't know which one.

The State.

Q. Have you spoken to anyone other than persons


with the Arkansas Attorney General about testifying in
this case?

A. No.

I might correct that.

My wife, secretaries in my office. That's all.

[Luncheon recess.]

- - -


1:20 O'CLOCK P.M.

- - -


MR. WOLFE: Q. Dr. Roth, have you discussed the
testimony that you expect to give at trial with anyone
at the Attorney General's office?

A. I didn't know I was going to give testimony.

Q. Your testimony at trial.

A. Well, I will answer questions.

Q. Yes, sir.

A. That is my understanding, that this is what
it would be.

Q. Have you discussed with the Attorney General
the subject matter of the questions that you will be
asked and the responses that you will give?

A. No.

Q. Have you discussed generally the subject
matter in which the questions might be put to you?

A. Well, certainly it will revolve around this
statement here to the extent he asks me which area I
was a specialist in.

Q. Have you discussed any other subject matters
with the Attorney General?

A. No.

Just for information, Tim Humphries is not the
Attorney General, is he?

MR. WILLIAMS: No, he is not the Attorney General.


He is a law clerk within our office.

MR. WOLFE: Q. Have you discussed the subject
matter about which you might testify with anyone in the
Attorney General's office?

Did you discuss it with Mr. Humphries over the phone?

A. No, not at the office.

Q. Have you discussed with Mr. Williams or
anyone else the deposition that is being taken here

A. We discussed it last night in terms of what
it would be like.

Q. Did you during that time discuss the areas
on which you might give testimony or answer questions at

A. No.

Q. Have you described to anyone from the
Attorney General's office the areas of which you would be
willing to speak at trial?

[Discussion off the record.]

THE WITNESS: Please word your question again.

MR. WOLFE: Will you read back the question,

[Record read.]

THE WITNESS: I have talked to Mr. Williams here
about the catastrophism.

MR. WOLFE: Q. About any other areas?

A. These right here, just those, my specialty.

Q. About coral reefs?


A. Yes.

Q. Dr. Roth, have you discussed with anyone else
outside the Attorney General's office the possible
areas of your testimony at trial?

A. No.

Dr. Coffin. I have discussed with Dr. Coffin the
areas that I might cover.

Q. And when was that, sir?

A. Last week.

Q. What was the occasion of your discussion with
Dr. Coffin?

A. I was in his office and we were discussing
what areas we felt more competent in.

Q. Do you recall the substance of your discussion
with Dr. Coffin about the areas in which you might

A. It was very brief.

I said, "I will discuss the nature of the
scientific method," and he would work on the fossil

That was as far as it went, a very brief

[Discussion off the record.]

MR. WOLFE: Q. Dr. Roth, could you define Creation
Science as you understand it.

A. It's the study of that evidence from science
that suggests maybe some intelligent design in the
nature about us.


Q. Do you consider yourself a Creation

A. It depends on how you want to define
"science," as to what is involved here. If you define
"science" as limited to naturalistic explanations, then
you would get a conflict of terminology here, and the
answer to your question rests on your definition of

Q. Does Creation Science, as you defined it just
a moment ago, confine itself to naturalistic

A. It could if you assumed that design occurred
by naturalistic means.

Q. Do you yourself assume in your work that
Creation Science is confined to naturalistic means?

A. In my work -- you mean research?

Q. Yes, sir.

A. I don't touch on that subject hardly in my

You question was, do I consider in my work that
Creation Science occurred by naturalistic means.

Q. Do you assume that Creation Science is
limited to naturalistic explanations?

A. I don't have an answer to that because I
don't know how creation could have occurred.

Q. And I take it then that you don't make
assumptions about the matter, either?

A. Whether or not it's naturalistic?


Q. Yes.

A. I wonder about it.

Do I make an assumption? I can make assumptions,
but they are revisable.

Q. What assumptions do you make currently about
Creation Science and whether or not it includes only
naturalistic means?

A. Well, if you assume that design was by
naturalistic means, then you could say yes, sure, it's
all naturalistic. If you assume no, that this involved
what we want to call something beyond naturalistic,
then the answer is no.

Q. Do you yourself make any assumptions, either
of those assumptions, about whether or not naturalistic
means are within Creation Science or whether it's
limited to them?

A. I am more comfortable with the possibility I
don't understand what is going on here and that
naturalistic answers may not answer all the reality, but
I cannot say this as a scientist. I cannot say this is
the way it was, because I don't have the evidence for

Q. Is your understanding of Creation Science as
a general discipline that it does or does not confine
itself to naturalistic means?

A. It could go either way.

Q. Do you have any understanding about what is
the current -- let me say it another way.


Do you think there is an identifiable assumption
either that naturalistic means are the only ones to be
considered or that extranaturalistic means will be
considered made by most Creation Scientists today?

A. In terms of some of the scientific data, it
is hard for us to fit what we see into our present
understanding of the naturalistic means; but our
knowledge is so limited that I think one needs to be

- - -


Q. Sir, once again, given what you said about
Creation Science, do you consider yourself a Creation

A. Again, I will come back to your definition
of science. If you say science is purely naturalistic,
then I can't say that, but if you say this science does
allow for other aspects, then I can live with Creation

Q. Do you consider yourself that science only
allows for naturalistic explanations?

A. Historically it has not. There is a tendency
in modern science to move in that direction, but when the
foundations of our science were laid these were very much
in a non-naturalistic mode.

Q. I take it you have said that science at one
time or its origins did allow for non-natural explanations,
but that the current tendency is not to do so?

A. Right.

Q. Do you subscribe to that current tendency to
embrace only naturalistic explanations?

A. Well, again I have to come back to this
unknown. I don't know if it's naturalistic or not.
You are asking me to commit myself on something that I
don't have detailed knowledge of how it could have
happened. I don't have that. It could have been by
naturalistic means. It could not have been by naturalistic
means, but some of the founders, to bet back to the other
point I mentioned, some of the founders of science were


definitely creationists, for example, Newton and Agassiz,

Q. Dr. Roth, do you have a belief about whether
creation proceeded only by or whether the origin of the
earth and life on earth proceeded only by naturalistic

MR. WILLIAMS: Are you asking the witness his
professional opinion as a scientist?


THE WITNESS: On the basis of scientific data that
I have right now, I cannot answer that question.

MR. WOLFE: Q. Do you have a belief, a personal
belief, about the question apart from science?

A. Well, I certainly have certain personal
beliefs, yes, very definitely.

Q. And what are they?

A. On the basis of what I see about me it seems
to me that design of some kind seems to be implied in the
nature I see about me.

Q. Sir, then if we define Creation Science as a
science of origins and one which allows for origination
of the earth and life on earth by naturalistic or non-
naturalistic means, would you define yourself as a creation-

A. No, because science has to be open to other
ideas as well. You have to evaluate other ideas. You
are moving into an area of dogma and away from science in
that particular suggestion you make.


Q. Sir, have you read various books and
publications about Creation Science or Scientific Creation-

A. Yes.

Q. And have you ever attended any lectures or
seminars in the area?

A. Some.

Q. Do you regard Creation Science or Scientific
Creationism based on your experience with it as a science?

A. If you want to define "science" as
testable, predictable, I would say no. This narrows
science down to a very narrow spear of operation. I
would say then you don't have Creation Science, but if
you define it the way it's usually defined as a search
for explanations about nature, then very definitely there
is Creation Science.

MR. WOLFE: Will you read the last answer back,

[Read record]

MR. WOLFE: Q. Sir, would you define marine
biology as a science under one or both of those

A. There is no question it fits very conveniently
under the second one and pretty well under the first.

Q. Would you regard Evolution Science as a
science under either of those two definitions?

A. I would say perhaps the same as I did for
creation. If you are going to limit your definition of


science to the testable and the predictable, then you
would have to say evolution does not fit into science.

If you are speaking of the common definition, a
search for explanations about nature, then I think
evolution can fit under science.

Q. Sir, would you regard Evolution Science as
a religion?

A. You will have to define religion for me.

Q. Let me begin by asking you to define religion.

MR. WILLIAMS: I will have to object. I don't think
he is qualified nor has he been offered as an expert to
define what religion is. We will have other witnesses
on that point, I think, on both sides.

MR. WOLFE: I expect that is right, but we have
been already discussing several areas in which it's not
clear whether Dr. Roth will ever be qualified as a
witness, so I don't know that we could distinguish whether
or not he is able to answer that question on that ground.

MR. WILLIAMS: I don't mind him answering as long as
he is obviously giving a layman's understanding of what he
might consider to be religion.

MR. WOLFE: Well, I don't know that I want to tell
Dr. Roth that he is no more than a layman, but I agree
with you that he has not as yet been qualified as an
expert on religion and may in fact never be. I simply
want to ask him now for the purposes of our discussion
if he could define religion as he understands it.

THE WITNESS: There are different definitions of


religion. Under some of them evolution is a religion;
under others it is not.

MR. WOLFE: Q. Could you explain to me the
definitions of religion that you are thinking of?

A. Some consider religion as involving some type
of deity. Others understand that, of course, you would
say evolution probably does not qualify as a religion.

Sometimes religion is defined as a nondeistic
belief. It's a system of belief and does not involve
deism, and I would say evolution qualifies as a religion
under that definition.

Q. Would you say that Creation Science is religion
under either of those two definitions?

A. Yes, you could put it under both of those.

[Discussion off the record]

MR. WOLFE: Q. Sir, could you turn your attention
to the Arkansas statute. I believe you have a copy of it

Looking at Section 4 of the Act which is headed
Definitions, could you read the Section A, the definition
of Creation Science and Section B, the definition of
Evolution Science?

A. All right.

Q. Sir, would you consider yourself a Creation
Scientist given the definition of Creation Science in
this Act?

A. Yes.

Q. Would you consider yourself an Evolution


Scientist given the definition of Evolution Science?

A. I am closer to the creation than the

Q. Well, are you able to give a yes or no answer
as to whether or not you regard yourself as an Evolution

A. I need to define evolution.

Q. The definition that we are using is the one
in the Act.

MR. WILLIAMS: To the extent that question may assume
a fact not in evidence that the definition of the Act is
an all-inclusive definition.

MR. WOLFE: Well, I don't know whether the definition
purports to be all-inclusive or not, but I'm simply asking
does Dr. Roth consider himself an Evolution Scientist given
this definition in the Act.

MR. WILLIAMS: Okay. I think technically the
definition is the first sentence of Section A and B.
That is the definition.

THE WITNESS: Again, I will state I fit better with
A than with B. I did not write these definitions.









MR. WOLFE: Q. I understand that.

Would you say that it is possible to be both a
Creation Scientist and an Evolution Scientist?

A. It is possible to believe in parts of both of
these, very definitely.

Q. Looking at the definition of Evolution
Science and within that subsection after the listing of
six items that Evolution Science is stated as including,
do you agree with or believe in all or any of those six?

A. Under B?

Q. Yes.

A. The one that I have some -- I am able to
relate to No. 3.

Q. You are saying that you do not agree with item
3 under B?

A. It would depend on how you define some of the
terms there. I can relate to the fact that we do have
variation in nature at present.

Q. Are you able to agree or accept the other
Items 1 and 2 and 4 and 5 and 6?

A. They seem less likely than the counterparts
in Section A above.

Q. As between Item 3 and Section A and Item 3
and Section B which as you suggest I think appear to be
counterparts, do you regard one of them as more likely than
the other?

A. Yes, I would say A is more likely, but the way
3 is worded under B, I'm not satisfied that this is a


good counterpart to 3 under A.

Q. Sir, talking about the items under Creation
Science in the Act and taking them in reverse order, No.
6 says that "Creation Science includes scientific evidences
and related inferences that indicate a relatively recent
inception of the earth and living kinds. The Evolution
Science counterpart is listed as the scientific evidences
and related inferences that indicate an inception several
billion years ago of the earth and somewhat later of life."

A. Yes.

Q. Do you yourself have a view as to the scientific
evidence as to the age of inception of the earth and
living kinds?

A. You are distinguishing here the difference
between the matter of the earth and the living organisms
on it, is that right?

Q. Yes.

A. Yes, sir, it appears to me the Act makes that
decision. In terms of my personal beliefs I guess I would
not fit under either definition there in that my personal
beliefs are that I think maybe the matter of the earth
has been here for a long time but not the living kinds on

Q. Could you restate or are you able to state
what your belief would be about these questions?

A. Well, take No. 6 under B. I would say an
inception of several billion years ago the earth and much
later of life instead of somewhat.


Q. Can you be more specific about the time of the
inception of life?

A. I would say maybe only a few thousand years.

Q. Are you able to explain briefly what
scientific evidences you would point to for the inception
of matter of earth several billion years ago?

MR. WILLIAMS: As I understood the question before
you are talking of personal belief which may or may not
be the same as his professional belief based on scientific

THE WITNESS: Which do you want? You asked my
personal belief in the previous question.

MR. WOLFE: Then please let me be clear that I
understood your testimony.

Your testimony was that your personal belief would
be that the inception of matter of the earth might have
been several billion years ago and that the inception of
life would have been much later, perhaps only a few
thousand years ago.

A. Right.

Q. Would your scientific opinion be any different?

A. I don't think so.

Q. Can you tell me on what you would base your
opinion that the inception of the earth or at least the
matter of the earth is likely to have been several billion
years ago?

A. One of the strongest arguments is radiometric
dating, potassium argon dating, uranium dating, robidium


strontium dating.

Q. And what evidence causes you to place the
inception of life much later than that?

A. Those layers of earth that have evidences of
past life in them should have disappeared long ago if the
earth is as old as ordinary evolutionary interpretation

Q. Sir, I'm not certain that I understood that.

A. In the geologic column we have many layers.
These are being eroded at present and it is on the basis
of the amount of sediment in the rivers. One can
calculate how long it would take to erode these layers of
the geological column.

The figures usually given for eroding our present
continent down to a flat level are about ten to twenty
million years. How come we have this whole geologic
column for 600 million years. I am suggesting a much
shorter time than the age of the matter of earth.

[Discussion off the record]

MR. WOLFE: Q. Dr. Roth, did I understand then that
you regard radiometric dating as important evidence for
a great age for the earth?

A. It seems to me that it suggests this.

Q. Do you regard efforts to date fossil-bearing
geologic strata with radiometric techniques that indicate
ages of a million years for, say, Hominid, H-o-m-i-n-i-d
fossils in East Africa or mammals in the Cretaceous
in North America as tending to indicate that life was in


fact on earth say a million or two million years ago in the
case of East Africa fossils or much longer in the case of
mammals in North America?

MR. WILLIAMS: I think he may have understood that
question. I'm not sure I did. I understood the facts you
gave. I'm not sure I know what the question was though.

MR. WOLFE: I understood Dr. Roth to say that he
regarded radiometric dating as some evidence for an old
inception of the matter of the earth itself but that he
regarded the inception of life as likely to have come
much later, and I wondered if that means that you do not
accept efforts to date fossil life forms with radiometric
dating that give dates of more than a few thousand years

THE WITNESS: One cannot be as sure with the
techniques you are suggesting as with the ones that I
referred to earlier because in the techniques you are
suggesting we are dating not the fossils themselves but
layers in which you find the fossils, and the problem of
inherited age from reworked older material makes that
system less secure than one where you don't have that

Q. Are you aware of any efforts to date fossil
horizons with radiometric techniques that you regard as
more persuasive or more strongly made than others or do
you regard them as simply inherently unreliable because of
this indirect dating method?

A. I'm not a specialist in this area. I do not


have the knowledge to evaluate it that carefully.

Q. But would it be correct to say that if you
were satisfied about the connection between the fossil
occurrence and the radiometric date or the geologic
stratum, then you would be willing to accept the date as
being a date for the fossil?

A. No. We have to base our evidence on a lot of
things. This will not alleviate at all the erosion picture
that I mentioned to you earlier. To build one's view of
truth on one narrow bit of evidence is not sound.




















Q. Dr. Roth, the list of witnesses that was
submitted states that you will discuss "findings from
his research on coral reefs past and present which
indicates support for the Creation Science model."

Could you describe the findings from your research
that are referred to in that description?

A. One of the findings of my research is that
ultraviolet lights inhibits coral reef growth near the

We have analyzed the effect of different wavelengths
of light on coral growth, and we find that ultraviolet
does inhibit while the others tended to enhance it.

Ultraviolet light is absorbed more readily as
light penetrates the ocean than visible light.

This suggests that coral reefs may not grow as
rapidly at the surface where the ultraviolet light is
more abundant than further down on the reef.

This in turn raises questions regarding evaluating
the rate of growth at the surface compared to further
down where there is greater potential, where there is
less ultraviolet light.

A second factor would be temperature, where we have
found that raising the temperature increases the rate
of growth of coral.

Since the paleontological record suggests warmer
temperatures in the past, reefs may have grown faster
in the past. Adding calcium ion in the sea appears to
increase the rate of coral growth.


If there was a greater concentration of calcium
ion present, then one might expect faster coral growth.

These factors may explain why one sees -- back up
-- may explain why in the literature fairly rapid
growth has been reported, much faster than is normally
noted at the surface.

Q. Sir, how does the work that you have just
described bear on the question of origins of life and
Creation Science?

A. It suggests that events in the past may have
occurred more rapidly than is generally assumed.

Q. And what is the importance to Creation
Science of evidence which suggests events in the past
could have taken place more rapidly than they are found
to at the present?

A. Well, one of the problems that evolution
faces, if I can answer it from the other side, is that
by all our best estimates there is not enough time for
evolution to have taken place.

When you look at the data that suggests that the
earth may be younger than generally assumed, this
also fits into that picture and hence supports the
idea that purely naturalist explanations may not be as
correct as other models.

Q. Sir, I am not certain that I understood the
last couple of things that you said.

I take it that you would regard your research on
reefs as supporting the Creation Science explanation as


opposed to an Evolution Science explanation for the
origin of life; is that right?

A. You have to define "support."

Are we working in a disprove mode here or are we
working in a mode of science where we say, "Well, it
looks like this supports this"?

This is where I think we are having difficulty.

Q. In which mode would you regard as your working
relevant to the question of origins?

A. In the disprove mode, the work that I would
think would eliminate the disprove for the Creation Science
has been able to occur rapidly. It favors more rapid
action, is what it does.

Q. So that I take it that you mean one argument
against Creation Science is that it doesn't generally
allow enough time for certain observed things to have

A. There is some data in that direction, yes.

Q. And the fact that your work suggests coral
reefs might have grown faster in the past than is
usually reported at present would tend to support the
notion that presently observed --

A. This is not a strong argument against Creation

Q. Can you summarize for me your understanding
of the argument against Creation Science, that it does
not allow enough time for the presently observed coral
reefs or whatever to have come about.


A. The argument is along the line that some of
our coral reefs are fairly large and it would take a long
time for them to grow.

Q. Have you published any material on
specifically this question of whether or not coral reefs
have had enough time to grow as they presently are seen
to under the Creation Science model?

A. Not specifically on that subject.

I touched on it in the manuscript which was

Q. And when was that, sir?

A. Last year.

Q. To whom, or to what journal was the manuscript

A. I believe it was the Journal of Marine

Q. Were you given any understanding as to why
it was rejected?

A. In general, it was felt the article was too
long, the manuscript was too long.

Q. Were there any other reasons given?

A. The reason given, another reason that was
given was that they felt the data was -- did not support
the conclusions.

I must clarify this point by stating my comments
about the rates of reef growth were incidental to the
research; they were in the discussion of the paper;
let's put it that way.


If you are familiar with scientific papers, they
were not a part of the data.

I can further state, the article has been accepted
for publication, although in much reduced form that
does not include the question of the rate of growth of
coral reefs.

Q. And it was accepted by the Journal of Marine

A. No. I did not resubmit it.

Q. By what journal?

A. Pacific Science has accepted it.

Q. Pass to the last entry on your publications

A. Yes. It is not published yet, but it is in

Q. Sir, is the Journal of Marine Science what is
known as a referreed process in the journals?

A. Well, it is usually sent to two individuals
who are considered competent in the area, and they
anonymously criticise the manuscript and evaluate it.

Q. And then the manuscript is either accepted
or not for publication based upon these comments?

A. These comments.

Q. Sir, is Pacific Science a referreed journal?

A. Yes.

Q. Is the journal that you edit, Origins, a
referreed journal?

A. Yes.


Q. Is Marine Biology a referreed journal?

A. Yes.

Q. And the Journal of Palaeogeography,
Palaeoclimatology, Palaeoecology?

A. Yes.

Q. Sir, as you recognize, I am asking you about
names that I find in your publications list.

Could you tell me about the Journal of the
Association of Adventists Behavioral Scientists; is that
a referreed journal?

A. I do not know.

It is a small publication. The only issue I've seen
is the one in which I happen to have an article that was
reprinted from Origins.

Their policy, their editorial policies I'm not
familiar with.

Q. Sir, could you explain to me what it means that
an article is published as an abstract or in abstract

A. It is only an abstract when it states that.

When you go to a scientific meeting, before your
paper is accepted for presentation, you have to submit
an abstract that is evaluated, and that abstract is
published as part of the proceedings of that meeting.

Q. Are the papers themselves then published, as
a rule?

A. You can publish, and people often do publish
an extensive paper beyond that.


Other times, sometimes the abstract is sufficient
to make the point. You don't bother to produce a more
lengthy presentation.

Q. How long are the abstracts of papers,

A. 300, 500 words. They are brief.

Q. Sir, have you had any other articles which
you submitted for publication which were rejected?

A. I cannot recall of any others except this
last one that I have had trouble with.

Q. Did you include, among the publications that
you gave me this morning, a copy of this article which
is in the press but not yet printed?

A. No.

Q. Did you include a list of the manuscript which
you submitted to Journal of Marine Science but which was

A. No.

Q. I would request, if possible, that you make
available to us copies of each of those, both the
paper in Pacific Science and the earlier manuscript that
you submitted to the Journal of Marine Science.

Sir, were the comments of the reviewers of your
piece submitted to the Journal of Marine Science made
available to you or only described to you?

A. I would have to look back to find out how
they were presented to me.

At times the comments are made, and at other times


the editor writes you a letter telling you what the
reviewers state.

I don't know which way it was.

Q. I would also request, if you have the letter
or copies of those comments, that you produce them, as

Can you recall for me in any more detail the comments
you mentioned before about the submission to the Journal
of Marine Science, a comment by reviewer that the data
was felt not to support the conclusion?

A. As I recall, the statement was not supported.

Q. And I take it that you do not know the
identity of the reviewer who made the comment.

A. No.

MR. WOLFE: I'll ask the reporter to mark as
Roth Deposition No. 2 an excerpt from the journal,
Origins, Volume 6, No. 2, 1979, including pages 57, 58
and 88 through 95.

[Excerpt from Origins, Volume 6,
No. 2, 1979, pages 57, 58 and 88
through 95 was marked Exhibit No.
2 for identification.]

MR. WOLFE: Q. Dr. Roth, before we turn to Exhibit
No. 2, do I understand it to be your opinion that the work
you have done suggests that a relatively short period of
time would have been enough for coral reefs to grow to
the extent that they are known to have reached in the
world today?


A. It favors a shorter time period.

I have not demonstrated that they grew that fast.
I have shown some factors that show that they grow faster
than was thought.

Q. Do you have a view as to the length of time
which is necessary or which is sufficient to account
for the present extent of coral reefs?

A. Well, if you take a figure such as those that
have been obtained by soundings, where I believe we get
40 centimeters per year, it would only take two or
3000 years to grow our deepest reef.

Q. Sir, what are the deepest known reefs?

A. Eniwetok Atoll is the deepest known reef.
It has a depth of 4,610 feet.

Q. And you are not aware of any deeper reefs in
any other areas?

A. No.

Q. Do you know what is regarded as the deepest
known reef in these United States, in Florida or the

A. I can't give you figures.

They are considered very shallow compared to

- - -


Q. Do you regard the figure you mentioned just
a moment ago of 40 centimeters per year as growth rate,
which I believe you said was derived from soundings,
as a reliable estimate or approximation of coral reef

A. There was another estimate that wasn't quite
different from that. Some coral are known to go 26
centimeters, which is not all that far off.

So it is not just a single study that I'm referring

Q. Would the rate of coral reef growth vary from
one geographic location to another?

A. Very definitely.

Q, What factors would cause that variation?

A. Temperature is probably the dominant factor,
and coral reefs grow faster in tropical regions than in
subtropical ones.

Q. Do you know where these soundings were taken
from which the growth rate that you mentioned were

A. They were in the western Pacific.

Q. Do you know if it is mentioned in your
article in origins, the one that was marked as Exhibit
No. 2?

A. In this issue I believe the references are

Q. Sir, on page 90 in the article there is a
reference to soundings of reefs in the last full paragraph


at the bottom of the page.

A. You have two papers there, Sewell and

Q. Are they the instances that you were thinking

A. Right.

Q. Would you expect that growth rate in the
Andaman Islands in the Bay of Bengal are comparable to
those that would be found at Eniwetok Atoll?

A. About. They are both close to the equator and
Eniwetok is 11 degrees north of the equator.

Q. Do you know the latitude of the Andaman
Islands offhand?

A. No, I'm sorry.

Q. Do you know the location of the other instance
mentioned there in the Celebes?

A. It is right near there where it's awful hot.

Q. Do you know if that's close or further from
the equator than Eniwetok?

A. Than 11 degrees? I would have to look at an

Q. Can you tell me, is there any rule of thumb,
or are you aware of any way of assessing the different
growth rates that would exist from a position on the
equator compared to the one 11 degrees north?

A. Actually the position on the equator is not
a very good index of how rapid a reef grows, nor is it a
good index of temperature of the water, it is your ocean


currents that determine this. But it so happens in the
western parts of our oceans, whether it be the Atlantic or
the Pacific, we have our warmest temperatures.

Q. Do you know offhand whether the Celebes and
Eniwetok would be essentially comparable in water

A. Eniwetok might be a little bit cooler at

Q. Do you know if that would make any significant
difference in coral growth rates?

A. It probably would affect it.

Q. I guess that would make the growth rate
somewhat slower than Eniwetok?

A. If we assume that our previous statements
are correct.

Q. Sir, have there been other efforts to estimate
coral reef growth rates other than these that are based on

A. Quite a number.

Q. What other methods are used?

A. Measurement of reef growth rate at the
surface, measuring the result of the coral organisms
themselves, measuring the rate of absorption calcium
carbonate by the reef, and combinations of other
factors. Putting together all that you can gather --

Q. Do you know if these other methods that you
have just mentioned generally give rates greater or
lesser than this one derived from, or that we have seen


derived from soundings?

A. Well, some methods of reef, of actual measure-
ment of coral give what you might call comparable figures,
like the paper by Lewis, I mentioned.

On the other hand, it is generally assumed coral
reef growth is very much slower than in sub-centimeter
to centimeter level per year.

Q. When you say generally assumed, you mean by --

A. Well, on the basis of certain assumptions, on
the basis of the fact that some coral grows slowly and
some grows fast.

The general conclusion is that coral reefs grow
very slowly.

These measurements, however, are at the surface of
the ocean where there is probably some interference from
ultraviolet light.

Q. Are you aware of other people working in your
field who would support your opinion, that is, of these
relatively rapid coral growth rates?

A. Certainly some of them support the idea that
some coral grow very rapidly or they wouldn't have
published the results.

Q. Are you aware of any who support the notion
that corals generally, or that reefs have grown more
rapidly than these slower rates you've mentioned?

A. Just those papers that deal with soundings
and those that deal with the actual growth rates on coral,
not reefs as a whole, no.


Q. Sir, do you know what method was used to
derive these growth rates based on soundings?

A. They used soundings.

Q. Probably now I'm about to reveal how little
I know about the area.

Is this a matter of going out and taking a sounding
and coming back three years later and taking another

A. Right.

Q. I see. The dates that are mentioned in these
two papers in your article, 1935 and 1932, do you know
when those soundings were taken?

A. I could not give you that offhand.

Q. They were sometime prior to the dates of these

A. Obviously.

Q. Do you know approximately when?

A. I suspect scores of years between the two

Q. Do you know if these soundings were taken by
physical means, actually lowering a wire or rope or

A. Yes.

Q. Could they have been done by sonar at that

A. I don't think so.

Q. Have you read these papers?

A. I've read those papers but I would not, I


don't recall exactly which techniques they used there.

Q. Do you know what effort they make, or what
means they use to make certain that they come back to the
same place to make the sounding the second time?

A. I am not that familiar with the technique.

Q. Are these rates derived from soundings
generally regarded as reliable?

A. Highly reliable. They guide shipping, they
have to be reliable, otherwise you would lose boats.

Q. Are they regarded by marine biologists, or
coral researchers, as a reliable way to estimate growth

A. They have not addressed themselves to soundings.
The techniques they use and the techniques I use are

Q. I see. I didn't understand in your last
answer, you said the techniques they used and the
techniques I use. Who did you mean by "they"?

A. You were talking about marine biologists?

Q. Yes.

A. The techniques that marine biologists use,
including myself, are different than soundings.

Q. Why is that, sir?

A. Well, I presume that under the pressure of
publication, and so on, to take a sounding at one time
and then go back forty years later to take another
sounding is not very productive of getting papers out
under the pressure of publishing.


So, I think more rapid techniques are favored.





























Q. Do you know if the authors of the two papers
on soundings that are mentioned here actually performed
both sets of soundings themselves?

A. No.

I would have to go back to the papers and check

Q. Would you regard it as essential to accuracy
in the soundings that they have been taken by the same
investigator on both occasions?

A. I suppose it would help.

I don't think the technique is that vague.

Q. I take it you have never used soundings

A. No.

Q. And you are not aware of any papers published
based on soundings since these two that you have cited?

A. The one mentioned in the Introduction there
just suggested by Ladd, that an error was made or that
coral reefs grew very rapidly because of a ship that
got trapped.

That's the only other reference I can refer to here,
Ladd of the U.S.G.S., but he was just suggesting maybe
these things grew faster than is generally assumed,
and that's why this ship foundered.

Q. You say that he made that suggestion.

Did he offer -- had he done any research or any
study that suggested that?

A. Based strictly on the fact that boat was



Q. Did he suggest any other possible explanation?

A. I don't recall.

He just cautiously suggested maybe these things
grow faster than is generally assumed.

It is just a suggestion on his part.

Q. Sir, who would you regard as the most
knowledgeable researchers in the area of coral reef
growth rates?

A. Keith Chave, Steve Smith. I would not
exclude myself from the group.

Q. Any others?

A. Not that I can think of right now.

Q. Is there any journal that's more important
than others in this area, that is, coral reef growth

A. I don't think so.

As the literature reveals, it is pretty well spread
out over quite a number of marine biology type of

Q. Are there any books in the area that you are
aware of that are particularly useful or important?

A. Not especially.

There have been some technique books put out.

One technique book I can think of that has been
put out, but I know of no books that have really
addressed themselves to this particular issue.

Q. Sir, what was the technique book that you


refer to?

A. I cannot give you the reference right offhand.

It was edited by Johaness, Johaness and another
editor, Stoddart.

Stoddart may be the senior editor on -- I don't know,
one or the other.

Q. Sir, are you familiar with the International
Coral Reefs Symposia that are held from time to time?

Have you ever attended one of those symposia?

A. No, I have not attended one.

Q. Do you know how many have been held?

A. Not offhand.

I think I have missed several. I suspect it is
around every four years.

Q. Would you regard them as important gatherings
of people in your field?

A. Yes.

Q. Are papers presented at these symposia?

A. Yes.

Q. Are they generally by the important
investigators in the area?

A. Right.

Q. Are proceedings or a journal or a text of the
thing published?

A. Proceedings are published.

Q. Are they published each time one is held?

A. As far as I know.

Q. Have you ever read any of these proceedings



A. Sure.

Q. Do you have those volumes yourself?

A. Not personally.

Q. Does the Geoscience Research have them in its

A. I cannot answer that. I do not know the list
of all the holdings of the library.

Q. I think you said a moment ago that you had
read some of these proceedings volumes.

Do you recall where you obtained them?

A. Probably University of California Riverside,
if not at Loma Linda University Library or if not,
University of California at Los Angeles.

I go to a number of libraries and I don't remember
which ones I happened to pick up a certain volume.

Q. Sir, are you aware of any papers that have
been presented at any of the symposia that agree with
your views about more rapid rates of growth for coral
than for reefs?

A. No.

I think the last one that was held in Australia,
my name was mentioned several times, and my research
was mentioned several times in connection with the fact
of light, but not in connection with reef growth.

Q. Sir, returning for a moment to the methods of
measuring reef growth, as you mentioned earlier, you
referred to measurement of reef growth at the surface.

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