Deposition of Harold G. Coffin - Page 2


of scientific research that you developed and learned.

Q. How would you describe the methods of your
petrified wood research?

A. I am just not too sure.

Repeat that again.

What are you asking?

Q. How would you describe the methods of your
research with the petrified wood?

A. Okay.

That's basically the method of science which is
observation and experimentation.

Q. What kind of experiments did you do?

A. The flotation experiment was related to the
petrified wood.

Q. How did the flotation experiment work?

A. How did it work?

Q. What was the methodology for the experiment?

A. It was obtaining horsetails, putting them into
different controlled situations and observing their flo-
tation in water.

Q. And the horsetails were substituting for the --

A. The horsetails were chosen because they are
modern forms of fossil representatives in the same group.

Q. What kind of fossils did you discover in Yellow-
stone, then, that the horsetail represented for you in
the experiment?

A. Horsetails.

Q. So it was these horsetail fossils that were


aligned in a parallel manner that you were trying to ex-

A. No, the paper on the orientation concerned the

Q. As a result of your experimental on the flota-
tion of horsetails, did you derive any conclusions in
the area of evolution versus Creation Science?

A. Relative to -- on the basis of that experiment,

Q. What were those?

A. That not all vertical fossil horsetails are
necessarily in position of growth.

MR. KLASFELD: I am sorry, could you read that, please.

[Record read]

MR. KLASFIELD: Q. And what relevance does that have
to the Creation Science versus evolution controversy?

A. It has to do with the aspect of catastrophy in

Q. How?

A. Flotation would be a phenomenon of catastrophy
or could be a phenomenon of catastrophy.

Q. Could you describe for me how the experiments

A. I can, but let me also say that the article
describing the flotation is in the material with illustra-

Modern living horsetails were placed into tanks of
salt or ocean and freshwater and observed over a period of


days as to their sinking characteristics and their floating

Q. What did you discover?

A. I discovered that a fair proportion of them will
float vertically and sink vertically.

[Discussion off the record]

MR. KLASFELD: Q. I am sorry, did you say they all
floated vertically or some did?

A. No, about two-thirds.

Q. Were you able to determine why some did and some

A. No.

Q. Did you attempt to?

A. Yes.

- - -


A, Yes.

Q. What experiments did you do to find that out?

A. The horsetails are hollow and so some of the
experiments, the partitions between the joints, were
removed in order for the air to pass out more easily to
determine whether that might be a factor in their
floating characteristics.

Q. But the result of that experiment was --

A. Inconclusive.

Q. -- inconclusive.

Did you conduct any other experiments?

A. I tried agitation of the water as a factor for
increasing the rate of absorption of water by these
plants. Again, more or less inconclusive.

Q. And what was the importance of this flotation
experiment in terms of creation science and evolution?

A. Well, as I mentioned, it is related to
catastrophism in that a view of catastrophism would
postulate flotation phenomena of this type.

Q. And, therefore?

A. It would be a factor in support of catastro-

Q. Did you gather any evidence about how long
ago this flotation might have taken place?

A. I was not dealing with that at all.

Q. I see.

Let me just make sure in my own limited way I
understand what you are saying.


You did some experiments on horsetails but found
that they floated and that, because they floated verti-
cally, they might have been fossilized vertically, which
supports the case for catastrophism, but that you did not
do any experiments to determine when that might have taken

A. That's right.

Q. Is there some reason you didn't conduct those

A. I don't know what experiments one would do.

Q. How large were the tanks in which you floated
the horsetails?

A. One was about 4-by-8.

Q. You are speaking feet?

A. Yes, by 3 in depth. The other was 4-by-4-by-

Q. How large is a horsetail?

A. Full grown, full size [indicating].

Q. The witness held his hand about three feet off
the floor.

A. Yes, that's about right.

Q. How many horsetails did you have in a tank at
any one time?

A. 120.

Q. Each experiment?

A. Salt and fresh.

Q. So there were 120 in one tank and 120 in the


A. No.

Q. Sorry.

A. I have to look in my paper, but I believe it is
120 together for both.

Q. What experiments did you do to satisfy yourself
that the conditions in the tank would be similar to the
conditions that existed at the time the catastrophy took

A. Agitation would be one feature. It is a possi-
bility, that's why I did it in both salt and fresh water,
because we are not sure. That's about it.

Q. What about the fact that the real life occur-
rence took place in much larger areas than the tanks?

A. I don't think that would be a factor involved.

Q. Same things in the tanks as in a lake or a

A. Pretty close.

Q. How did you agitate the water?

A. It was open to the elements. So a certain
amount of the time it was just wind blowing agitating the
surface and occasionally it would be stirred by hand.

Q. The tanks were outdoors?

A. Yes.

Q. How occasionally were they stirred by hand?

A. Two or three times a day.

Q. For how long?

A. Until the water was circulating well.

Q. How long would that take?


A. Three to five minutes.

Q. Was this back and forth on one side or round
and around the tank?

A. It was -- the tanks are too large to go all the
way around. Well, one could, but mostly on one side,
causing the circulation of the water.

Q. How did the agitation affect the horsetails?

A. It did not make any substantial difference to

Q. Was the density of the horsetails in the tank
about the same as you would imagine the density was in the
real life occurrence?

A. The horsetails, the fossil horsetails, are
most like the horsetails -- the modern horsetails are in
the fall, when they start to dry up, and so it was that
condition that I used.

MR. KLASFELD: Could you read back my question,

[Record read]

MR. KLASFELD: Q. What I mean, the number of horse-
tails in the limited area of the tanks, was that the
density with which they occurred in relationship to one
another in real life?

A. Yes, very similar.

Q. Had you done some studies of that in order to
choose 60 for each tank?

A. The larger the number, the better as far as
scientific experimentation is concerned.


Q. Not if they all filled up the tank?

A. That would be true. There would be some
limitation of space, but there wasn't any problem in this

Q. What I am trying to get at, was the limitation
of space in the tank different than the horsetails occur
in the natural environment?

A. No, because you find them in the same density
in the way you mean it, in the fossil record.

Q. You mentioned before something about pollen.
What was that in reference to?

A. About what?

Q. Pollen.

A. Pollen in the sediments in the Yellowstone
petrified forest.

Q. In the organizations of which you are a member,
have you ever held any office?

A. No, I have not.

Q. Have you ever had any special duties in connec-
tion with those organizations?

A. I've given lectures in relationship to --

Q. Which organization?

A. Sigma Xi.

Q. When was the lecture?

A. When I was at Walla Walla College in about 19 --
I would say somewhere between 1960 and '64.

Q. Where was that lecture given?

A. In Walla Walla.


Q. That's not where Sigma Xi has its offices?

A. Sigma Xi has chapters in educational facilities
all over the country.

Q. So you addressed the Sigma Xi chapter in Walla

A. That's right.

Q. Your lecture was presumably on crabs?

A. No, it was on periodicity in invertebrate

Q. What is periodicity?

A. Cycles of activity.

Q. Are you a member of any society that is not
listed on your curriculum vita?

A. No. National Geographic Society.

Q. Have you ever made application to a society and
been denied?

A. No.

Q. Have you ever sought a license which you weren't
given in the area of science?

A. No.

Q. Do you do any teaching now?

A. Guest lecturing.

Q. Where have you guest lectured?

A. In various classes at Loma Linda University.

Q. Which classes?

A. General geology, historical geology, graduate
biology seminars, I guess it would be called. That's all
that comes to mind at the moment.


Q. And that's been true since 1964, has it?

A. Not at Loma Linda University.

Q. Have you been guest lecturing elsewhere?

A. Yes, at Andrews University where I lived for
most of that time from '64 until now.

Q. Is Andrews University a church affiliated --

A. Yes, it is.

Q. Seventh-Day Adventist Church?

A. Yes.

Q. Are you the member of any other creation
science organizations?

A. No.

Q. The Institute for Creation Research?

A. That's not a membership organization.

Q. The Bible Science Association?

A. No.

Q. Citizens for Fairness in Education?

A. No.

Q. Citizens for Balanced Education As to Origin?

A. No.

Q. Let me mark as Plaintiff's Exhibit No. 2, a
letter from the Creation Science Legal Defense Fund, and
some attached articles to that letter.

[Document more particularly identi-
fied in the index marked for
identification Plaintiffs' Exhibit
No. 2]

MR. KLASFELD: Let me, Dr. Coffin, show you a copy


of this letter and ask you if you have seen it before.

A. I can't remember exactly, but this is a form
letter and I wouldn't be a bit surprised it was sent to

Q. Your name appears on the left-hand side.

A. Yes.

Q. Do you know how it came to be there?

A. Yes, they asked me if I would be a witness for
the trial that was -- where was it? --here in San
Francisco, wasn't it? Or no, Sacramento.

Q. This letter, though, doesn't make any reference
to the case in San Francisco. It refers to this action
in which we are involved here today, is that correct?

A. I didn't read it all.

You did.

Let me look at it for a moment.

Q. I think if you look at it, you will find that
that's correct.

A. Well, if this paper is referring only to this
situation involving Arkansas, then I can truthfully say,
if it was sent to me, I did not read it. I am not aware
of it.

Q. Your name appears in the left-hand column.
Did anybody discuss it with you before it was sent?

A. I suspect that that is a holdover from my
willingness to be a witness for them in the Sacramento

Q. Who is the "them" that you are referring to?



Q. By which you mean?

A. Creation Science Research Center, San Diego.

Q. But you weren't part of this fund-raising

A. No, I never submitted any money to them.

Q. Are you a member of any other kind of organiza-
tion that's not listed on the --

I presume you are a member of the Seventh-Day
Adventist Church?

A. Yes.

- - -


Q. Any other organizations, political organizations?

A. I am wracking my brain trying to think of organi-
zations that I belong to, but I can't think of any others.

Q. Were you approached to be an intervenor in this
action by any group?

A. Please explain what you mean by an intervenor.

Q. There was a motion made to intervene in this
case by a group -- and Mr. Campbell will correct me if I
am wrong on the law -- who felt that their interests were
not being adequately represented at the trial by either of
the parties and they sought to intervene in the trial so
that their position could be adequately represented.

A. I did receive some communication, and I'm not
certain whether it was in connection with Arkansas, whether
or not they could use my name, sort of like on the side of
the list there [indicating] as an expert in the area of
creationism and I agreed to it.

Q. But you never discussed the possibility of your
becoming a party?

A. No, I am not a party to it.

I know nothing about the organization.

Q. You, at one time, were a member of the Creation
Research Society, is that correct?

A. Yes.

MR. KLASFELD: I would like to have marked as Plain-
tiffs' 3 for iden. an application form for the Creation
Research Society.

[Copy of application form for


Creation Research Society marked
for iden. as Plaintiffs' Exhibit
No. 3]

[Discussion off the record]

MR. KLASFELD: Q. Let me ask you, Dr. Coffin, the
application form describes four types of membership.

Would you tell me what kind of membership you were?

A. I would be a voting member.

Q. You were a voting member.

The membership forms requires on it that if you were
a voting member, you must have subscribed to the four
principles of the Creation Research Society.

Do you subscribe to those principles?

A. I subscribe to -- the first one, I do not accept

Q. Let me read into the record the first one, which

"The Bible is the written Word
of God, and because we believe it
to be inspired thruout, all of
its assertions are historically
and scientifically true in all
of the original autographs. To
the student of nature, this
means that the account of origins
in Genesis is a factual presenta-
tion of simple historical truths."

If you could state for the record, Dr. Coffin, in


what respect you disagree with that statement?

A. This is a statement out of a belief of the
inerrancy of Scripture, which I do not subscribe to.

Q. Do you believe the Bible makes mistakes?

A. Yes, occasionally, small mistakes.

Q. Which ones?

A. The number of demoniacs.

Q. What is a demoniac?

A. Demoniac was the crazy men that Jesus met on
the opposite side of the Sea of Galilee.

One person says, two, another persons says one.

Q. What do you think?

A. I don't know.

Q. What other mistakes are in the Bible?

That's not so much a mistake as a contradiction
within the Bible?

A. Within the testimony of those authors, biblical

Well, for instance, there are two main sources from
which Scripture comes, the Massoretic and the Septuigent.

In one, numerical figures are different than the
other and they are both the Bible.

Q. Which numerical figure?

A. Oh, many of them.

Q. What is the source of the Massoretic?

A. It is a Hebrew source.

Q. And the Septuigent?

A. A Greek source.


Q. Do you have any view about which is correct?

A. I am not a theologian.

The usual view is that the Massoretic is more correct.

MR. CAMPBELL: Just for the record, here, David,
since we did limit his expertise to the fossil record, I
home you will not consider him an authority in religion?

MR. CHILDS: He is speaking personally.

MR. KLASFELD: I understand that.

I am simply trying to explore his disagreement to the
extent there is any with the four --

MR. CAMPBELL: Tenets of membership to the Creation
Research Society.


Thank you.

Q. Do you have an opinion about how those mistakes
occur in, otherwise, an inerrant book.

A. Yes, I do, but I don't think it is of value be-
cause I am really not a theologian.

Q. How do you think those mistakes came to be?

A. To answer that, I have to go more deeply into
the philosophy of inspiration of the Bible authors.

My view is that the inspiration that God provided
the Bible authors is message inspiration, not verbal in-
spiration. They used their own style.

Q. They, the authors?

A. The authors used their own style.

They were influenced by the society of which they
were a part. They were not machines through which God dictated.


Q. The nature of the errors in the Bible which
you believe exist strike me as being minor.

Would you characterize them as minor?

A. Very much so.

Q. So that with the exception of some minor
discrepancies, are you in agreement with Tenet No. 1?

A. All its assertions are historically and sci-
entifically true with the exception of minor problems.

Q. No. 1, are you in agreement with No. 2?

Let me just read it for the record.

"All basic types of living things,
including man, were made by direct
creative acts of God during Crea-
tion Week as described in Genesis.
Whatever biological changes have
occurred since Creation have ac-
complished only changes within the
original created kinds."

A. I subscribe to that.

Q. How do you define "kinds"?

A. Kind is a broad term.

It would be defined differently with different taxo-
nomic groups of animals.

Q. You mean there is a different definition for
each different group of animals?

A. Because it is a broad term and has no specific
meaning to a taxonomist, one who classifies living things,
it cannot be pinpointed to a definite meaning.


Q. Well, how would I know if a change took place
that wasn't within the original created kinds?

A. Well, that's what evolutionists have been look-
ing for for a hundred twenty years.

Q. But what I mean to ask is, how do I know where
the barriers are?

I mean, how do you define kinds such that if an
evolutionist was trying to find that information, he
would know or she would know when it crossed that barrier?

A. If we look at the fossil record and compare it
with living organisms and we see the same basic categories
of plants and animals from the past to the present, we
could get some feel as to what those basic created kinds

Q. How many kinds are there?

A. I haven't counted them.

Q. About how many?

A. I don't know.

Q. Ten thousand?

A. More than that.

Q. More than ten thousand?

A. Yes.

Well, I don't know.

I really have to say I don't know.

Q. A hundred?

A. Certainly more than that.

Q. Can you give me the ends of the spectrum?

MR. CAMPBELL: He answered the question.


He really doesn't know.

MR. KLASFELD: I understand he doesn't know.

Q. But it is more than a hundred and less than,
how many?

A. Let's say less than ten thousand.

Q. Are dogs and cats in the same kind?

A. No.

Q. Are lions and tigers in the same kind?

A. Yes.

Q. If you were to take as a project, the creation
of such a list, how would you go about it?

MR. CHILDS: Why don't we say "preparation" instead
of "creation"?

MR. KLASFELD: Q. If you were going to prepare such
a list, how would you go about it?

A. You would go about it actually more or less
the same way that a classifier of organisms today tries
to determine species.

Q. Is a kind the same as a species?

A. Not identical.

Q. How is it different?

A. In most cases it is a broader category.

Q. What are the criteria for a kind that make it
broader than a species?

A. Most likely the ability to cross is --

Q. The ability to crossbreed?

A. Yes.

Q. What do you mean "most likely"?


A. That is the most usable, most concrete method
of trying to determine.

Q. Well, let me ask you this:

If I was going to do research with some animals that
crossbred and I could alter one so that it couldn't cross-
breed, would I have created a new kind?

A. No.

Q. Why not?

A. Because its ability to cross was evident to be-
gin with.

Q. But I have taken an animal that originally could
crossbreed and I have now made a new animal, some genera-
tions later, that can't crossbreed.

Is that a new kind?

A. Not a new kind, but a new species, perhaps, or
a new variation.

Q. I thought that you said that the inability to
crossbreed was the distinction between kinds?

A. That inability may be psychological, it may be
geographical, and it may be behavioral, but if you brought
the sperm and the ovum into the laboratory, they probably
would cross as they did originally.

Q. What if I brought the sperm and the ovum
into the laboratory and they didn't?

A. What if they did?

Q. My question is, what if they didn't?

A. That remains to be seen.

Q. Let me ask you this:


What information could you conceive of that would
lead you to believe that the tenet of No. 2 wasn't true?

A. It would be the evidences that evolutions have
been looking for for connections between major kinds,
missing links.

Q. Now, you are talking about major kinds, isn't
that distinguished from kinds?

A. Major kinds or basic kinds, I am using that

Q. Let me go back to the sperm and the ovum.

If I was to conduct an experiment that would satis-
fy you that the sperm and the ovum wouldn't create an
offspring, would that satisfy you that those were two
different kinds that created the sperm and ovum?

A. I am willing to go wherever the truth leads.

However, on the basis of all the rest of organisms
in the plant and animal world, I would be inclined to
think there were factors there that I was unaware of,
factors preventing the cross.

Q. I understand you wouldn't like the information,
but let's say that I could satisfy you that I conducted
the experiment in a way whose methodology was unassailable.

Would you then say that I created a new kind?

A. You have set up a hypothetical situation and it
is very difficult to answer because I would need to
really look at that carefully.

It does not agree with my concept of what can happen.

Q. Yes, but, as you said, you will follow the


truth wherever it leads.

A. Yes.

- - -


Q. I am not saying that it is going to happen or
did happen; I am saying if you were provided with this
information, would you then think that a new kind had been

A. I would have to take another look at the
classification of these particular organisms and evaluate
the situation.

Q. It strikes me that you are posing for the
evolutionist an impossible test.

You won't say what kinds are, but you want them to
find separate ones that might interbreed or the creation
from one kind of something that won't interbreed.

I want you to propose the test that would satisfy


A. The Bible is written for the common man. The
kind is not meant to be scientific.

We are doing violence to Scripture by trying to
give a scientific meaning to the word, "kind."


Q. But creation scientists use the word, "kind,"
don't they?

A. Yes.

Q. Are they using it in a scientific sense or
biblical sense?

A. They are using it in a general sense.

Q. A nonscientific sense?

A. Well, it can be used in science as long as it
is understood to be a general term.

Q. What would your scientific definition of "kind"

A. It could be all the way from a species to an

Q. But that's pretty far all the way?

A. Man is an example of species kind. Perhaps
there are examples among the insects --

Q. Is there another animal which is part of the
same kind as man?

A. No.

Q. Is there any other kind of which there is only
one example?

A. I suspect there are, but I can't tell you what
they are.

Q. How do you go about determining that the lion
and the tiger are of the same kind but the lion and the
dog are not of the same kind?

A. The breeding test is not the only basis, but it
is one of the main bases.


Q. What are the other bases?

A. Anatomy, physiology, overall experience,

Q. What about the seriology?

A. The types of tissues and blood and so on.

Q. Could two people disagree on whether or not
two animals were of the same kind or not?

A. Surely.

Q. To that extent it is arbitrary?

A. That's why it is a general term.

Q. Let me look at tenet number three, which reads:

"The great Flood described in Genesis,
commonly referred to as the Noachian
Deluge, was an historical event,
worldwide in its extent and effect."

Do you agree with that?

A. Yes, I do.

Q. When did that flood take place?

A. My personal belief is that it took place just a
few thousand years ago.

Q. How many?

A. Shall we say from five to seven thousand years

Q. Could it have been 10,000 years ago?

A. Perhaps.

Q. Could it have been 15,000 years ago?

A. Not in my thinking.


Q. What makes you think it was five to 7,000 years
ago rather than 10,000 years ago?

A. My belief as far as the time of the flood is
concerned is based largely on Scripture.

Q. What scientific evidence do you have for the
time of the flood?

A. Not much.

Q. "Not much" suggests there is some. What is

A. Oh, rates of erosion, rates of sedimentation.

Q. And that suggests to you that it is five to
7,000 years rather than 10,000 years ago?

A. Yes.

Q. What is there about the rate of erosion that
suggests that to you?

A. If they proceeded at the rate they are going
today, we wouldn't have any land above sea level in a few
million years.

Q. And the rate of sedimentation?

A. If they proceeded at the rate they are now, we
wouldn't have a Gulf of Mexico in 10 million years.

Q. Do you believe the rates of erosion and sedi-
mentation have always been constant?

A. No.

Q. How have they changed?

A. By catastrophism.

Q. Since the catastrophy they have been constant?

A. No.


Q. How have they changed?

A. By climatic fluctuations, by vegetation changes,
by -- even by man, man's influence.

Q. Why, then, do you think if they have been
changing over a substantial period of time, that the rate
of erosion and sedimentation could help you tell how long
ago something happened?

A. It doesn't really tell me that it happened five
to 7,000 years ago, but it does tell me that it doesn't
appear to have happened hundreds of hundreds of thousands
of millions of years ago.

Q. Why do you believe five to 7,000 rather than

A. Because I have confidence in the information
given in the Scripture.

Q. Let me read number 4, tenet number 4, into
the record.

"Finally, we are an organization of
Christian men of science, who
accept Jesus Christ as our Lord and
Savior. The account of the special
creation of Adam and Eve as one man
as one woman, and the subsequent
Fall into sin, is the basis for our
belief in the necessity of a savior
for all mankind. Therefore, salva-
tion can come only through accepting
Jesus Christ as our Savior."


Do you believe tenet number 4?

A. Yes, I do.

Q. So, with the exception that you mentioned in
number 1 of some minor discrepancies between accounts in
the Bible, you agree with tenets 1 through 4?

A. Yes.

Q. When did you embrace the Seventh-Day Adventist

A. I was born a member of the Seventh-Day
Adventist Church.

Q. Do you hold any office in the church?

A. Not at the present time.

Q. Have you been?

A. Yes, I have.

Q. What office did you hold?

A. An office that's referred to as an Elder in the

Q. Do you attend church regularly?

A. Yes, I do.

Q. How frequently?

A. Every week.

Q. Do you consider yourself a fundamentalist

A. I suppose, despite the rather negative connota-
tions of that, I think it would fall in that category.

Q. How would you define that?

A. One who accepts the tenets that you just read.

Q. Do you have a personal religious counselor or



A. No.

Q. Do you engage in activities to spread the faith?

A. Yes.

Q. Do you have an evangelical mission as part of
your membership of the church?

A. Can you explain a little more what you mean?

Q. Well, what do you do to spread the faith?

A. I speak to people when I have the opportunity,
I write for church papers which are used for evangelistic
purposes; I speak in churches; I speak in evangelistic
services, so forth.

Q. Have you been baptized?

A. Yes.

Q. How many times?

A. Once.

Q. Is that when you were a child?

A. Yes.

[Discussion off the record]

MR. KLASFELD: Q. Do you believe that it is okay
to exaggerate in order to spread the faith?

A. Absolutely not.

Q. And you wouldn't distort anything to spread the

A. Not knowingly.

MR. KLASFELD: Why don't we take a break and pick up

[Luncheon recess]



1:15 O'CLOCK P.M.

- - -


MR. KLASFELD: Q. Dr. Coffin, when you read the
Bible, is there any particular version that you read?

A. No.

Q. How often do you read the Bible?

A. I read it almost every morning.

Q. Do you set aside some time for that?

A. Yes, I do.

Q. How long?

A. My aim, and I usually reach it, is a half-hour
in the morning.

MR. CAMPBELL: Just for the record, I will object
to these questions as being irrelevant to the particular
issues in this lawsuit.

MR. KLASFELD: My understanding is that the judge
has been heard on that. I don't want to characterize
what he said because I wasn't there, but I am told that
that discussion was had with the judge and the judge
authorized us to ask these questions.

MR. CAMPBELL: You can talk about his religious
views, is my understanding of what the judge said, but
he diver did take up Bible reading and things like that.

That is all I am saying, that this may be
irrelevant, but he can answer the question.

MR. KLASFELD: How do you decide which section you


are going to read each morning?

A. Oh, I simply choose some part of the Bible
which, for various reasons, might be of interest to me
at the time.

Q. As a paleontologist, do you consult the Bible
for the purposes of your scientific inquiry?

A. Not directly.

Q. Indirectly?

A. Well, my research on flotation, for instance,
probably would never have arisen if I didn't have
confidence in the flood story in Genesis.

Q. So in conducting that research, did you
consult the flood story in the Bible?

A. No.

Q. For what purpose in relation to your
scientific work do you consult the Bible?

A. To one who has confidence in its authenticity,
he would consult it for the same reason he would consult
any other authority which he feels to be reliable.

Q. Is the Bible a source of personal revelation
to you?

A. Personal revelation, can you explain that?

Q. Well, I am not sure that I can.

Does it provide for you a personal code of

A. Yes.

Q. What is that code of conduct?

A. "Thou shalt love the Lord thy God with all


thy heart, and thy fellow likewise," paraphrasing.

Q. Do you believe that the Bible is, except for
minor, minor discrepancies, literally true?

A. Yes, except where it is obviously symbolic.

Q. In what respects is it obviously symbolic?

A. Well, where there are words or messages that
are clearly symbolic.

Q. Which ones are they?

A. Well, the beasts in Revelation, the parables
of Jesus and so forth.

Q. What about the Genesis part of the Bible?

A. I accept Genesis as being accurate history.

Q. And literally true?

A. Yes.

Q. Does the Bible predict future events?

A. I believe it does.

Q. What future events does it predict?

A. The end of earth history, the second coming
of Christ.

Q. The rapture?

A. To some people.

Q. Not to you?

A. No.

Q. Does the Bible predict for you when the end
of earth history is going to take place?

A. No.

Q. Or when the second coming of Christ is going
to be?


A. No.

Q. Is the Bible an inspiration for your research
in any way?

A. No, I don't think so.

Q. Is it, in its literal truth, a source of
scientific learning for you?

A. No.

Q. Is it a source of scientific truth which sets
forth parameters for your research, your work?

A. To some extent, yes.

Q. To what extent would that be?

A. It provides basic concepts and basic
understandings that will influence a person's research.

Q. What basic concepts and understandings would
those be?

A. Of course, we are talking about creation and

Q. By which you mean the creation of the world
and the universe in six days and the Noachian flood?

A. Yes.

Q. Does the Bible suggest methods of scientific
investigation to you?

A. No.

Q. What information would you think of that
would lead you to conclude as a scientific matter that
the earth was millions of years old?

A. What information can I think of that would
lead me to think that the earth was millions of years



Q. Yes.

A. Radioactive dating.

Q. I'm sorry.

That would lead you to believe that the earth was
millions of years old?

A. That could lead me to believe that.

Q. Well, you believe -- I will start at the

I understand you to believe that -- I will start
from scratch.

When do you believe the events of Genesis, as
described in the Bible, took place, how long ago?

A. A few thousand years ago.

Q. That would be, presumably, before the flood?

A. Yes.

Q. How long before the flood?

- - -


A. Let's say up to ten thousand years before, before

MR. KLASFELD: Excuse me.

[Discussion off the record]

MR. KLASFELD: Back on the record.

Q. In connection with this case, Dr. Coffin,
have you had any contacts with people other than the
Arkansas Attorney General's Office and Dr. Roth?

A. It was discussed in the Geoscience staff

Q. Who was there at that time?

A. The individuals were two secretaries and two
other members of the Geoscience staff.

Q. What was discussed?

A. Just simply should we or shouldn't we.

Q. And you reached the decision that you should?

A. We decided we would go ahead with it.

Q. What were the considerations against doing it?

A. Whether we could be useful or whether we wanted
to be identified with some others that might be involved
in it.

Q. Who were those others?

A. I'm thinking particularly of ICR.

Q. The Institute for Creation Research?

A. Yes.

Q. Who were the major members of that group?

A. No individuals were referred to specifically.

Q. But who are they?


A. I don't know all of their membership.

Some of them, of course, are Duane Gish, Henry
Morris, Gary Parker and -- what is his first name? -- well,
Bliss; and there are some others.

I don't really remember who all is there now.

Q. And you discussed the negative effect of your
becoming associated with them?

A. Well, as I indicated, there are certain aspects
of creationism which we don't quite agree with them on,
so we weren't sure we wanted to be lumped in with that

Q. You ultimately decided you would?

A. Yes.

Q. Did you have any discussions with the people
at ICR about your testimony?

A. No.

Q. Did they attempt to get into contact with you?

A. No.

Q. Have you had any contact, first of all, ever,
with Wendell Bird or John Whitehead?

A. No.

Q. Have you ever testified in any kind of court
proceeding before?

A. I'm not sure of your legal terminology.

I was involved personally in a lawsuit involving
an accident in which my wife's back was broken, an
automobile accident.

Q. I see.


But not regarding your scientific expertise?

A. No.

Q. Have you engaged in any debates on creation
science versus evolution?

A. No.

Q. No public debates?

A. No.

Q. What about any debates involving evolution in
any way?

A. Define what you mean by "debate."

Q. I guess I would mean a public kind of debate,
where you are speaking for one side and somebody else
is speaking for another side.

A. I have been involved in public discussions on
creation evolution but not what you would call a debate.

Q. Where did those discussions take place?

A. One of them occurred in San Francisco.

Q. Who set up the discussion?

A. It was -- I don't remember the call numbers
but --

MR. KLASFELD: Excuse me.

[Discussion off the record]

MR. KLASFELD: Back on the record.

I am sorry.

I apologize for the interruption.

THE WITNESS: It was a local educational TV station,
and they had a discussion on -- it was when the teaching
of creation in public schools in California was strongly


being considered.

MR. KLASFELD: Q. Who else participated in those

A. I don't remember the names but one was an
official in the high school system of San Francisco and
another was a science teacher from the University of

Q. Do you know if there are any transcripts of
that television program?

A. A videotape was made of it.

Whether that is still available, I don't know.

Q. Do you have a copy of it?

A. I don't have a copy.

Q. About when did this take place, do you know
the dates?

A. Well, I would say 1965 or '66, somewhere in

Q. What station was that on?

A. I don't remember the call letters.

It's a local educational TV station.

Q. Thank you.

Since then, have you engaged in any other public
debate or discussion about the issue?

A. No.

MR. CHILDS: Excuse me, David.

[Discussion off the record]

MR. KLASFELD: Back on the record.

THE REPORTER: The best known local public tele-


vision station in this area is KQED.

THE WITNESS: I think that was the one.

MR. KLASFELD: Q. All right.

Were you paid for your appearance on KQED?

A. No.

Q. Are you being paid for your testimony at this

A. No.

Well, just for expenses.

Q. Have you ever been arrested for any criminal

A. No.

That doesn't include minor automobile accidents,
I presume.

Arrested, no.

I just received a citation.

Q. For speeding?

A. No.

For failing to yield the right of way.

Q. Did you do it?

A. Well, I hit the side of the car so I didn't
really have much of an excuse.

Q. But other than that, no arrests or convictions?

A. No.

Q. Have you discussed with anyone the specifics
of what you expect to testify to at trial?

A. With Dr. Olson, I have talked about it with


Q. How many times have you talked about it?

A. Almost none before we came up here, but we
are, of course, just a couple rooms apart, and at break-
fast time or other meal times we have talked about it.

Q. How many other members are there at the Geo-
science Research Institute?

A. There are four, plus two secretaries.

Q. Who are the other two scientists?

A. The other two, their names are Richard Tkachuck,
T-k-a-c-h-u-c-k, and Robert Brown.

Q. What is Dr. Tkachuck's area of expertise?

A. His area is in speciation and variation,
evolution, if you please.

Q. And Brown?

A. He is a nuclear physicist.

Q. Is there any particular reason why they are not
testifying at the trial, that you know of?

A. That is something I have no information on.

Q. What have you discussed with Dr. Roth about
your testimony at trial?

A. Almost nothing about the testimony.

Q. What did you talk about?

A. About what to expect; in other words, what it
is going to be like.

Q. Just to be a witness?

A. Yes.

Q. While we are on this subject, what would you
describe as Dr. Roth's area of expertise?


A. His area of expertise would be catastrophism
and philosophy of science.

Q. Does he have any other areas of expertise?

A. I think that I had better not say, really,
any more.

Q. Is he an expert on coral reefs?

- - -


A. Yes.

Q. Is your testimony going to be based on any of
the documents you have brought this morning?

A. Yes.

Q. Which of those?

A. I can't answer that. I haven't prepared it

MR. KLASFELD: Mr. Campbell, I guess that answer is
indicative of the problem we are faced with in terms of
our efforts to seek discovery about Dr. Coffin and his
testimony. It's difficult to explore his areas of
testimony if he hasn't thought about it himself, and in
the area of fossils and paleontology is a very broad area.

MR. CAMPBELL: I think what it reflects is that he
has told you that his testimony will come from the
documents which he has provided you, and certainly, you
could ask him about those documents.

I think, too, and more basically, that what it
reflects is that we have simply not had the time to prepare
our witnesses as we would like to have prepared them for
trial; we might not find that same problem with your
witnesses, but this is actually a reflection of the number
of attorneys that you have available to prepare your
witnesses, while on our side, there has been only the two
of us, or three of us now, working on the case.

MR. KLASFELD: But that really doesn't go to the
merits of what it is we are entitled to be able to do
in a discovery deposition.


We are supposed to be given the opportunity to
examine and to discuss with a potential witness what his
testimony is going to be, what he expects to rely on in
that regard, in an effort to probe that testimony.

And it's clear to me it's not that Dr. Coffin is
unwilling to discuss anything, and I certainly don't want
to suggest that, but simply the fact that, you know, the
interrogatories weren't answered and I gather from
discussions with our people that you feel that the
information that was given to us in the witness list and
the --

MR. CAMPBELL: And the information which the witnesses
can provide you at these depositions.

MR. KLASFELD: -- and the information which the
witnesses can provide us at these depositions, should be

My objection is that the area of paleontology and
fossils is a very wide area.

For instance, I read an article by Dr. Coffin on
spirorbis, and I am prepared to discuss the article on
spirorbis with him, but I think I am entitled to know
whether he expects to testify as to spirorbis at the time
of trial.

MR. CAMPBELL: You didn't ask that.

I think in a discovery deposition you should ask him
about all of these areas you know of or about. I think
you mentioned this morning you have already read some of
his articles in Origins Magazine.


MR. KLASFELD: That's right.

MR. CAMPBELL: So you might ask him whether or not
he would rely upon those.

MR. KLASFELD: I want to and I will.

Part of what we are entitled to do, in my mind, at
these discovery depositions, is to limit the area about
which the witness is going to testify; and while I have
read three or four or more of Dr. Coffin's articles, and
if I had all of this information, I would have read the
others as well, it seems to me that it's going to be
impossible to serve the other legitimate purpose of a
deposition, which is to limit what it is that somebody is
going to say and rely upon.

MR. CAMPBELL; I understand what you are saying.
I guess my only response would be that the witness should
not be penalized because of his lawyers, in this instance
the Arkansas Attorney General's office, for being unable
to adequately prepare his testimony in advance of this

We have undoubtedly an expedited trial date in this
case, and as Dr. Coffin has testified, we just recently got
in contact with him. I think we have done remarkably well
in getting all of these depositions lined up and getting
them all done before the trial date.

MR. KLASFELD: I think it's true that the witness
shouldn't be penalized, but neither should the other side.

MR. CAMPBELL: But you have him here today. That
is the thing.


MR. KLASFELD: That is true. But what I am able to
accomplish at this deposition is greatly limited from what
it would be in the ordinary case.

MR. CAMPBELL: I guess I just don't understand the
purpose of a discovery deposition the way you are viewing
it, because as I would interpret it, as I view a
discovery deposition, it's a time where you sit around and
you start with a very broad area and continually try to
break it down, you continually try to narrow it down.

Obviously, Dr. Coffin can only testify at trial about
what he knows about, whatever that is, so it seems to me
that the purpose of the discovery deposition would be for
you to determine what it is he knows, because he is not
going to testify to anything else but that.

MR. KLASFELD: I understand that.

Q. Do you anticipate testifying about spirorbis
at the trial?

A. Well, once again, that is a difficult question
because I just really haven't put together this information
and I am not sure that I would have put it together even if
I had known three months ago.

Q. Would you anticipate testifying about the
Burgess shale formation?

A. That is a possibility.

Q. Or the ginkgo petrified forest?

A. I doubt it. I don't know.

Q. But what about the work you have done in the
Yellowstone area?


A. Perhaps.

Q. And the work on the horsetails?

A. Possibly.

MR. KLASFELD: Mr. Campbell, I think I'm entitled
to more than that or better than that or something different
than that.

MR. CAMPBELL: I guess the only thing I'm saying is
that, where he has given you indication he may be
testifying about that, you should inquire into what it is
about that that leads him to have these opinions which he
may have on this.

MR. KLASFELD: I will do that. But I want to
continue to state that, in my own view, that is not

MR CHILDS: I think the problem is that the
procedure in Rule 26 on experts has not been followed,
which says that first the written statements would be
filed with the court and then, after a motion to the court
and for good cause shown, the court would then order the
deposition to be taken. And the situation you are in is a
result of not following the right procedure. You got the
procedure screwed up.

I think counsel for both sides contributed to that.
We are going to be at the same disadvantage with your
witnesses that you are with ours.

MR. KLASFELD: Let me mark for the record, as
Plaintiffs' Exhibit No. 4, an article from Volume II of
the magazine "Origins," entitled, "The Spirorbis Problem,"


written by Dr. Coffin.

[Article entitled "The Spiroribis
Problem" marked for identification
Plaintiffs' Exhibit No. 4.]

MR. KLASFELD: Q. Look at Plaintiffs' Exhibit 4,
Dr. Coffin, and tell me if that is an article that you
wrote for Origins Magazine.

A. Yes, it is.

Q. This article makes reference to some work you
did in coal areas of Nova Scotia; is that correct?

A. Yes.

Q. Where in Nova Scotia were these coal mines?


















A. Joggins, Nova Scotia, J-o-g-g-i-n-s, and North
Sydney, Nova Scotia.

Q. How did you happen to go there?

A. Because that is known in the geological litera-
ture as an interesting area for coal exposures.

Q. Had you been working on spirorbis prior to

A. Not in the field.

Q. In the lab?

A. In literature research.

Q. Why did you focus on spirorbis?

A. Because it is a significant fossil element of

Q. Of coal?

A. Yes.

Q. Directing your attention to the third paragraph,
the second sentence says,

"In the coal measures of Nova Scotia,
I have observed spirorbis fastened
to the outside edges of mussels."

A. I don't follow where you are reading.

Q. Paragraph 3.

A. 3?

Q. The second sentence.

A. Oh, yes, I'm sorry. Go ahead.

Q. Could you define for me coal measures?

A. That is a term that means the sediments in
which coal seams are located, including the coal seams,


the whole system.

Q. But it's not limited to just the coal?

A. Not limited to the coal, that is right.

Q. Do you know the genus of the mussel that you
described here?

A. Modialus, is it? It's probably in here. I
believe it's modialus.

Q. Could it have been mytilus?

A. Well, that is the modern genus.

Q. Could it have been promytilus?

A. I don't think so.

Q. Do you think it's modialus?

A. Yes.

Q. Could you spell that, please?

A. M-o-d-i-a-l-u-s.

Q. Is modialus extinct?

A. Probably.

Q. Could you tell me the difference between
modialus and promytilus?

A. The reason I hesitate on the extinction question
is that there isn't a great deal of difference and it's
sometimes hard to say whether it is or isn't.

Q. How would you distinguish modialus from

A. Well, I'm not familiar with the genus pro-
mytilus, but I am familiar with the genus mytilus.

Q. But you are certain the mussel to which the
spirorbis was attached was modialus and not mytilus?


A. I am going by the indications in the previous
genealogical literature.

Q. There is genealogical literatures which identi-
fies the mussel?

A. Oh, a great deal.

Q. What is the source of that literature, and I'm
speaking of literature that identifies particularly the

A. Dawson.

Q. D-a-w-s-o-n?

A. Yes. I think it's -- I'm trying to think of the
initials or the first name.

But he was a very well-known Canadian geologist. I
think his first name was William.

Q. But you yourself couldn't distinguish a pro-
mytilus from a modialus?

A. I could if I studied the characteristics ahead
of time. I couldn't right now.

Q. They are both invertebrate fossils, though.

A. Yes.

Q. Your third paragraph goes on to say, and I will
skip slightly:

"The worm is distributed throughout
the geological record, and on the
basis of the standard geological
time scale, spirorbis had been in
existence for nearly 500 million

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