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The Critic's Resource on AntiEvolution

Deposition of Harold G. Coffin - Page 3


Does the article say that?

A. Yes.

Q. Do you believe it has been in existence for
less than 500 million years?

A. My personal belief is that. As far as scienti-
fic evidence is concerned, there wouldn't be any direct
evidence on it.

Q. And there is no direct evidence that it's less
than 500 million years?

A. That is right.

Q. Now, if I can, I'm going to try to characterize
what I understand to be the point of your article, and
please correct me if I am wrong.

The point of the article is that spirorbis was a
salt water animal; that coal was believed to be formed in
a fresh water situation; and the fact that the spirorbis
is found mixed in among the coal creates the enigma of
how, if the coal was formed in fresh water, a sea water
animal could be among the coal.

Is that correct?

A. That is correct.

Q. How do you understand coal to be formed?

A. Coal is the accumulation of vegetable matter
and its burial.

Q. How long does that take?

A. It depends upon conditions.

Q. What conditions?

A. The depth of burial, the temperatures involved,


bacterial decay.

Q. What is the standard notion among experts on
the formation of coal about how long that takes place, how
long it takes for that to take place?

A. In the geological literature there is very
little information on actually how long the coalification
or petrification process takes.

Q. There is disagreement, I understand that, but
is there sort of a low range as to how little time that
might be?

A. Really, in my reading, I have very seldom run
across any information along this line.

Q. Does anybody feel it could take place in 5,000

A. Yes.

Q. Who?

A. Some museum curators.

Q. Who is that?

A. In the coal museum in Bochum, Germany, they
have a post taken out of an old coal mine that is coali-

Q. Where is that?

A. In Bochum, Germany.

Q. B-o-k-u-m?

A. B-o-c-h-u-m.

Q. And you say they have a post that had been in
a coal mine?

A. Yes.


Q. And that had turned into coal?

A. Yes.

Q. And the curator of that museum is who?

A. I don't know who he is.

Q. But he is the person who thinks it could take
less than 5,000 years?

A. I'm just assuming that, since they have got it
on display in the museum.

Q. I see.

But you have never spoken to him about it?

A. No.

Q. Have you been to the museum?

A. Yes.

- - -


A. Yes.

Q. Can you explain how the standard people who
study in this area, and I'm using the term, "standard,"
the way I think you are trying to use it in your article,
tell me what you understand the explanation to be for how
the spirorbis appears in the coal?

A. Their explanation is that, during the carboni-
ferous period, the spirorbis was a fresh water animal.

Q. Have you ever heard the argument that changes
in the sea water or changes in the sea level in low-lying
areas allowed sea water to wash over what had previously
been fresh water areas and thereby bring in the spirorbis?

A. Yes, I have heard that.

Q. Do you know of any scientific evidence to lead
you to believe that is not true?

A. Yes.

Q. What is that?

A. A marsh is a very specific environment, and to
have peat bogs, which is more specific yet, developing
one above another repeatedly, is extremely unlikely.

Q. Why is it unlikely?

A. Because the conditions for the development of a
peat bog are so rigid.

Q. Have you done any experiments which lead you
to conclude that it's unlikely?

A. I have done a lot of reading on the subject.

Q. Could you state for me the authorities that
agree with you that it's unlikely?


A. Those who work with limnology, which is the
study of fresh water.

Q. Specifically whom?

A. This is getting a little bit out of my area of
expertise. I'm not a limnologist, I can't really tell you
offhand who the experts are in the field.

In the study on the Nova Scotia materials, this, of
course, was handled by Dawson, whom I already mentioned.

Q. Does Dawson say in his work that it's impossible
to have stratified peat bogs turning into coal?

A. No, he doesn't say that.

Q. Well, that is what we are talking about now.

Who are the authorities that lead you to your con-
clusion in a field outside of your area of expertise, that
this couldn't happen?

A. Well, in research one often has to call upon
other areas of expertise, so it's difficult for me to
remember names of experts in the area of limnology, which
is not paleontology.

Q. But it is true that there are experts in those

A. Yes.

Q. Experts who agree with you that it's impossible.

A. No. Just a minute now.

Experts who agree that the requirements for the
production of a peat bog are very rigid.


Q. Okay.

But it's another step to go from there, isn't it,
to say that it's virtually impossible that a fresh water
peat bog could exist and salt water could, due to a change
in sea level, come into that area, and that the sea level
could recede so that it could become a fresh water bog

A. That is a possibility, but I don't think that
is what happened in this case.

Q. Why?

A. For the reason that I have just stated, the
unlikelihood of the same environments developing repeatedly
one above the other in the same place.

Q. To say that something is unlikely strikes me as
sort of an unscientific basis for believe it to be so or
hot so.

I mean, is there any other support that you have for
your notion that it's unlikely?

A. That is merely a common expression for

Q. On what do you base the probability?

A. That is difficult to answer briefly, because
there is so much involved.

I have never seen a situation where an advancing sea
leaves intact the environment over which it is advancing.

Q. Let me ask you this. Is the Illinois Basin,
is there a series of 40 to 50 coal seams, one on top of
the other?


A. Yes, there are.

Q. How did that happen?

A. I think the most reasonable explanation is a
drift model.

Q. What is a drift model?

A. It's that these plants have been transported
into the position where they now lie.

Q. By what?

A. By water.

Q. How do you get this layering of 40 to 50 layers
of coal, how did that happen?

A. By a change in currents that would bring in a
deposit of drifting plant material and then sediments
coming in over them from another direction by tidal

Q. Did this happen during the flood?

A. I would consider it to be a product of the
catastrophy that occurred during the flood.

Q. How does it happen then, in areas in Indiana
and adjacent areas in Illinois, there are some areas of
40 levels of coal and other areas where there are 30
levels of coal, and in other areas 10, and in others two?

A. Just like there are different heights of tides,
even different cycles of tides in different areas today.

Q. Perhaps you can explain for me specifically
how you believe these 40 to 50 layers were formed.

Did the coal come from the peat bogs?

A. Some did.


Q. But not all?

A. No.

Q. Where did the others come from?

A. Vegetation of various sorts.

Q. So somehow the vegetation was swept in, covered
with something else, and some more vegetation was swept in
and covered with something else, and more vegetation was
swept in and then it was covered with something else.

How long did that take place? How long did it take
for that to happen?

A. I don't know.

Q. Well, was it 3,000 years or was it two weeks?

A. I really don't know, but it would be closer to
the two weeks than the 3,000 years.

Q. And did the coal form in the two weeks?

A. No.

Q. The coal was formed since then?

A. Yes.

Q. Are you familiar with the Everglades as a model
of coal formation?

A. Yes, I am.

Q. Through what information are you aware of it?

A. Well, I have been there and, obviously, any-
body who has studied the coal literature would be aware of

Q. Is there fresh water floating on top of the
salt water in the Everglades?

A. Yes. Well, on top of the salt water?


Q. Yes.

A. Well, sometimes.

Q. It forms a lens on the top, is that what it's

A. Yes.

Q. And if the fresh water rivers that flow into
the Everglades would shut off for some reason, would for
some reason become blocked or would dry up, would that
turn into a marine environment?

A. No, it would turn it into a fresh water environ-

Q. Do the rivers coming in bring in salt water?

A. Rivers don't bring salt water.

Q. Well, then that is what I said.

If the rivers were for some reason shut off from
coming into this marsh area, would that then turn into a
completely salt water environment?

A. No.

Q. Why not?

A. Because the rivers are bringing in fresh water.

Q. Well, I said if, for some reason, the rivers
were diverted or dried up or were shut off, would that
then create a salt water environment?

A. You mean, if they are shut off from reaching
that area?

Q. Yes.

A. Possibly, yes. It depends on the elevation of
the land.


Q. Well, the Everglades are approximately sea
level, all of them are, and a very minor fluctuation in
the sea level would cover certain areas with sea water
that previously had been fresh water, and vice versa as

A. Yes.

Q. Why could that not be an explanation for the
appearance of spirorbis in the coal of Nova Scotia?

A. It could. It's another model.

Q. I see.

What is the scientific support for your model?

A. I have mentioned the repeated nature of the
coal seams as speaking against their being this growth;
the presence of marine organisms; the absence of erosion,
and the -- well, this would be similar, the extensive
flat-line nature of the coal beds.

Q. In your use of the term, "coal measure," which
you said was a thickness, including the coal seam and
areas above and below, were the spirorbis in the measure
or were they mixed in among the coal?

A. Both.

Q. Is there any explanation for it getting into
the coal -- strike that.

Is there any literature which describes its appear-
ance in the coal as opposed to in the coal measure?

A. Yes.

Q. Where is that?

A. I can get the reference for you, but I am not


sure I can give it to you off of the top of my head.

MR. KLASFELD: Will you do that?


Could we go off the record for a moment?


[Discussion off the record]

MR. KLASFELD: Back on the record.

Q. Do the standard scientists -- excuse me.

Do you object to me using that term?

A. No.

Q. I use it because I seem to have picked it up
from your use of it in your article.

Do the standard scientists have an explanation for
how the spirorbis comes to occur directly in the coal
seam, other than the washing in and out of sea water and
the possible change from being a fresh water animal?

A. Well, that is the main -- most of the literature
would suggest it was a change from a marine animal to a
fresh water animal.

Q. Which literature would that be?

A. The literature on spirorbis and on the appear-
ance of spirorbis in the coal measures.

Q. By whom?

- - -


A. Oh, by Francis, by Stewart, by Arnold, by

Q. And they all posit a change from freshwater
to saltwater for the fish or the spirorbis?

A. Some of them do, I am sure.

Q. Are there any authorities who support your
position for the appearance of these spirorbis in the
coal seem?

A. Yes.

Q. Whom?

A. Fayol, F-a-y-o-l, and Francis, Austin.

Q. A-u-s-t-i-n?

A. A-u-s-t-i-n, yes.

Q. All right.

In what sense were they in agreement with you?

A. That coal is allochthonous, drifted.

Q. Are they in agreement with you that the ap-
pearance of the spirorbis in the coal seam is support
for the flood theory.

A. Catastrophy?

Q. Yes.

A. Yes.

Q. Well, do you believe that it was one large,
worldwide catastrophy that had occurred within the last
ten thousand years?

A. I can't really answer that because they didn't
go into a discussion on that point.

Q. Well, what did they mean when they said



A. That this is in a catastrophic origin for

Q. What did they mean when they said

A. Just that: Brought in by the storm or by
transportation rather than growth in position.

Q. But that could have been --

I mean, would they agree or disagree that it could
have been something that happened hundreds of thousands
of millions of years ago?

A. I think most of them would feel that it prob-
ably happened millions of years ago.

Q. Is there anyone who agrees with you that it
happened five to seven thousand years ago, anyone who
studied this problem?

A. Yes.

Q. Whom?

A. Austin, and perhaps Francis.

Q. Where is Mr. Austin.

A. He is on the staff at ICR.

Q. And Mr. Francis?

A. He is a British paleontologist or coal geologist.

Q. Where is he?

A. I don't know his location.

Q. Is he affiliated with a Creation Science

A. No.


Q. What is the scientific evidence for the fact
that this happened five to seven thousand years ago?

A. Well, we come back to what I mentioned earlier,
and that is rates of erosion and deposition and so forth.

Q. Rates of erosion in the area around Nova Scotia?

A. No.

In general, on the earth in general.

Q. Did you study the area in Nova Scotia at all?

A. Certainly.

Q. How did the rates of erosion in Nova Scotia
affect your thinking?

A. It's very rapid there.

Q. And it's your belief that rapid rate has been
uniform over a time?

A. No.

Q. Why do you then conclude that, because it's
rapid now, something had to take place five to seven
thousand years ago?

A. I have to distinguish between the fact that,
although I feel or I believe that this happened a relative-
ly short time ago, there are many scientific evidences
of a longer period of time; but there are also strong
evidences that it is not hundreds of thousands or millions
of years.

Q. What are those evidences?

A. I already mentioned that, if we take the
average rates of erosion, which you can select out of the,
quote, standard, end quote, literature," there wouldn't


be any continents present at the present time if those
rates of erosion had continued over hundreds of thousands
or millions of years.

Q. But there are two parts to that:

One part is that you have to assume that they have
continued at that same rate for all of that period of
time; is that right?

A. If you assume that --

Q. Well, that is what you do in order to conclude it
has to be less than seven thousand years?

A. Yes.

You assume that, in a few million years, the rate of
erosion would have worn it down to sea level.

Q. What is the basis for that?

A. The average erosion given in the literature.

Q. Over the last how many years?

A. Over the last twenty years.

Q. So what you have done is taken the last twenty
years and extrapolated that over millions of years and
come to the conclusion that, if it had gone on at that
rate, the continent would have been worn away?

A. No.

You are misunderstanding me now.

Q. Okay.

A. I thought you meant what geological literature
over what period of time I obtained this information from.

It would be recent.

Q. Literature?


A. In other words, recent literature.

In other words, their extrapolations are variable,
depending on what areas they are looking at and over how
long a period of time they worked it out.

Q. I understand what you are saying.

Or I understand what I understand.

I understand you have taken the information as to
the rates of erosion for the last twenty years and you
have said, if that average rate --

You are shaking your head, "No."

What have you done with it?

A. Forget the twenty years.

Q. Okay.

A. If you take the average rates of erosion that
one finds listed in the geological literature, a figure
which is considered to have been consistent throughout
geologic time, it would have brought about the erosion of
continents to sea level by now if the earth were millions
of years old.

Q. How did the standard scientists deal with that
information; I mean, are they stupid?

A. That is a good question.

They don't handle it.

Q. You mean they just ignore it?

A. You very seldom see any discussion of it.

I don't think they are aware of it.

Q. Is that possible?

A. They may feel there has been subsequent uplift.


Q. Do you believe that the earth was made, with
all of the mountains that are now in place, in place
from the beginning?

A. No.

Q. When did the other mountains come into being?

A. During the Genesis flood.

Q. And since then there has been no change?

A. No.

Or, yes, there has been change.

Q. That change has only been erosion, though?

A. No.

Q. I am sorry.

Has there been subsequent uplift after the Genesis

A. To some extent.

Q. Where?

A. The Himalayan mountains are rising several feet
every year, I guess, still.

Q. What causes that?

A. And then there are volcanic eruptions that
cause --

Q. What causes the Himalayan uplift?

A. The current beliefs are the colliding of con-
tinents, like India, for instance, against Asia.

Q. Is that a standard belief as distinguished
from your own belief?

A. Well, I would go along, at least with qualifi-
cation, with the idea of continental drift.


Q. So even in your own belief about this, that
erosion isn't the only effect; I mean, there is also
uplift as well?

A. Yes.

Q. Does your calculation about the evening out of
all of the continents take into account the uplifts
that have taken place as well?

A. Yes.

Q. And do you still come out with less than five
thousand years?

A. No.

Just a minute.

Q. I'm sorry.

A. I come out with the fact that the earth would
be --

MR. CHILDS: That it would be under water.

THE WITNESS: -- that the earth would be down to
sea level in a few millions of years.

MR. KLASFELD: Q. In a few millions of years?

A. Yes.

Q. How about a hundred thousand years?

A. No, not that quick.

- - -


Q. So it could be 100,000 years old?

A. Yes, on the basis of that information.

Q. I see. What is the information that leads you
to believe that it's five to 7,000 years old?

A. The sedimentation we see in some areas.

Q. What sedimentation, what areas?

A. Like river deltas.

Q. Like the Mississippi Delta?

A. Yes.

Q. What is there about the Mississippi Delta?

A. At the present rate of deposition, it's only
four to 6,000 years old.

Q. Why do you believe that the Mississippi Delta
started forming the day the earth was formed?

A. I don't. I have extrapolated backwards. I
haven't gone from that forwards.

Q. Well, what you have said is that the
Mississippi Delta has been forming for four to 6,000
years; is that correct?

A. Right.

Q. Why does that provide us with any information?

For instance, I have only been going for thirty-five
years. Why does that provide us with any information about
the age of the earth?

A. Well, the word "earth" is pretty broad. We
are talking about the surface of the earth here.

Q. Why does that provide us with any information
about the surface of the earth?


A. Where was the Mississippi River during all of
the rest of geologic time?

Q. Well, one of the things about these depositions
is the lawyer asks the questions and the witness gives
the answers.

A. Well, that is what I am thinking, you are.

Q. But there are examples on the earth's surface,
are there not, now, of rivers forming, rivers drying up,
are there not?

A. Yes.

Q. So that rivers that presently exist were not
always in place the way they are now; is that correct?

A. Yes.

Q. Why couldn't the Mississippi simply have come
into being 4,000 years ago?

A. As long as there was a continent here, there
has to be drain-off of water.

Q. But why did it have to take place where the
Mississippi is?

A. Well, if it's some other river, then there
should be evidences of those deposits.

MR. KLASFELD: Let me mark, as Plaintiffs' Exhibit
5 for identification, an article from Volume I of
Origins Magazine called "Famous Fossils From a Mountain-
top," also written by Dr. Coffin, which is, I think, a
transcript of a talk that Dr. Coffin gave.

[Document more particularly
described in index marked for


identification as Plaintiffs'
Exhibit No. 5.]

MR. KLASFELD: Q. Did you write this article, Dr.

A. Yes, I did.

Q. If I can summarize the point that I understand
you to be making in this article, it's that this
Burgess shale formation contains certain extremely well-
preserved fossils that are just as intricate as the worms
and crabs that are existing today; is that the point of
the article?

A. Yes.

Q. And the argument that you are making is that
evolution has to be wrong if those fossils are supposed
to be so terribly old, yet there are organisms on earth
which are exactly the same as those fossils now?

A. Not quite.

Q. Where did I slip up?

A. Or similar.

Q. Similar. I see.

A. Yes.

Q. Well, your article says --

Let's see the point where I have made my error and
perhaps you can explain it.

On page 47, paragraph 3, the third sentence, you
say: "In fact they are just as intricate as the worms,
crabs, et cetera, in the ocean today."

A. That is correct.


Q. So they are not just similar?

A. But they are not identical.

Q. They are not identical?

A. No.

Q. But they are just as intricate?

A. Yes.

Q. Did you compare the different kinds of limbs
in the fossils with the similar animals that are alive

A. Limbs?

Q. Yes.

A. The ambulatory limbs?

Q. The limbs for food manipulation and motion.

A. Yes.

Q. How would you compare the fossils with the
animals which are alive today?

A. They are extremely complex and they are
typically crustaceans.

Q. Are the animals that are alive today, do they
have different kinds of limbs with more differentiated

A. Then those in the fossil record?

Q. Yes.

A. I would say no.

Q. You would say that, for all purposes, they are
the same?

A. Yes, in the same basic categories. They are
not the same species.


Q. I am sorry. I missed the point about their
not being the same species.

A. We cannot identify them as being the same
species living today, but they are crustaceans. In other
words, they can be categorized in a larger taxonomic

Q. So they are sufficiently different that they
are not in the same species?

A. That is right.

Q. But at the same time, they are sufficiently
similar to lead you to believe that a substantial problem
has been created for the evolutionists by their

A. Yes.

Q. Why is that a problem if they are not even
in the same species?

A. Because we are not dealing with speciation,
we are dealing with macroevolution. The problem is
macroevolution or major change.

Q. Why is that a problem for evolutionists?

A. Because they can't find the ancestor leading
up to these complex animals.

Q. Are there pre-Cambrian fossils?

A. Some.

Q. What are they?

A. It depends on what authority you read.

Q. The authorities that you rely on.

A. Pardon me?


Q. The authorities that you rely on.

A. As to micro-organisms like fungi and algae and
protozoa, there have been frequent reports in the
literature of brachiopods and --

Q. Do you believe this literature?

A. I have not gone into the sites to check it out
but I have no particular reason to doubt it.

Q. There had been, correct me if I am wrong,
until recently, a significant Creation Science argument
that there was a lack of fossils in the pre-Cambrian
rock and that that was a significant problem for
evolutionists; is that correct? A. Yes.

Q. But recently, through newly devised techniques,
these pre-Cambrian fossils have been discovered?

A. A few.















Q. So that earlier creation science argument is
no longer valid as a scientifically factual matter?

A. No.

Q. Well, the argument was, wasn't it, that there
are in fact none in the pre-Cambrian run; is that right?

A. There may have been some who said none.

Q. But you aren't one of them?

A. No.

Q. Who were they?

A. I don't remember.

Q. Have you always believed Creation Science
as a theory?

A. Yes.

Q. Let me ask you about the worms and the fossils:

Has the variety of worms now living increased from
the number of varieties that are found in the fossils?

A. Yes.

That has to be qualified.

Q. Okay.

A. Worms do no fossilize well.

Therefore, their preservation in the record is less

Q. But in any event, there is a much greater
variety among living worms than among fossilized worms?

A. It would appear that way.

Q. How do you explain that, other than the failure
of the fossil record to preserve that.

A. I would explain it on the basis of speciation


or minor change.

Q. What about the brachiopods in the Burgess
shale, are they as diverse as the brachiopods living to-

A. The way you worded that is difficult.

There aren't very many modern brachiopods.

Neither were there very many in the Burgess shale.

Q. Are there mollusks in the Burgess shale?

A. Yes.

Q. There are?

A. Yes.

Q. What kind?

A. Gastropods.

Q. Which one specifically?

A. I have not identified it to the genus, but
it is a snail, a marine snail.

MR. CHILDS: Off the record.

[Discussion off the record]

MR. KLASFELD: Back on the record.

But you don't know which gastropods?

A. No.

Q. How old do the standard scientists think the
Burgess shale formation is?

A. It's what they call the middle Cambrian,
which I would say is somewhere around five hundred

Q. What is the scientific evidence for your
belief that it's five thousand years old?


A. My belief in the usefulness of the earth is
not so much based on scientific evidence as on Scriptural-
historical information.

From the scientific standpoint, there really isn't
strong evidence, I would say, in regard to the age, either
young or old.

Q. What is the Scriptural evidence for the young

A. Well, I accept to a general -- well, let me
reword that.

The genealogical records and Scripture indicate to
me at least a general indication of time.

Q. What do you mean by "the genealogical record"?

A. The various individuals listed in the years
for their lives and so on.

Q. Let me ask you this, sort of dispensing
faith for a moment.

If you didn't have the Bible to rely on, what would
the scientific evidence lead you to believe about the
age of the earth?

A. The scientific evidence would lead me to think
that the earth was somewhere between, shall we say --
the figure I gave you, for instance, for the -- well,
no. That wouldn't work either.

I was going to mention the Mississippi Delta, but
that would be a flood phenomenon, which would be after

However, we are dealing with the structure in the


surface of the earth, which is a phenomenon, in my think-
ing, of catastrophism, so the evidences for catastrophy
would be involved and it would range somewhere, I would
say, between a few thousand years and a few hundreds of
thousands of years.

Q. It could be hundreds of thousands of years?

A. Yes, if you are taking the scientific evidence

Q. How do you factor in the Scriptural evidence?

A. Because I have confidence in the Scriptures.

Q. What is the scientific basis for that confi-

A. The same as the scientific basis for confidence
in any research that anybody else has done, and that is
we have to check it out and determine for ourselves that
it is reliable.

Q. Are you at least generally familiar with radio-
metric dating?

A. Yes.

Q. Are you at least generally familiar with radio-
metric data?

A. Yes.

Q. What is the standard belief among experts in
radiometric data as to the age of the earth?

A. It has been increasing.

What was the last figure?

Q. Could we agree at four and a half billion years?

A. Four and half million --


Q. Billion.

A. Four and a half billion, yes.

Q. How do you explain that?

A. I would say that they have come to those
figures honestly, and that is the way they view it.

Q. The people who have come to those figures,
are they necessarily evolutionists; I mean, do they
care what the rocks show?

A. Some of them aren't.

Q. Some of them are not?

A. That is right.

Q. How do you, as someone who believes that the
earth is ten thousand years old, deal with the informa-
tion from radiometric data?

A. You are really getting out of my area of

Q. I understand that, but I am saying this:

As a scientist, you are aware that there is an area
of scientific study that has generated the information
that the earth is four and a half billion years old,
give or take a few hundred million years.

How do you, as a scientist, evaluate that informa-
tion and consider it in terms of your own beliefs?

A. There needs to be a distinction between the
substance of the earth and the living things on it.

Q. I see.

What is that distinction.

A. I have no objection to radiometrically dating


ages as far as the inorganic matter is concerned.

Q. I see.

The earth may have been here for billions of years?

A. Yes.

Q. But the living forms on the earth came into
being only ten thousand years ago?

A. That is right.

Q. Where does it say in the Bible that the earth
could be billions of years old?

A. It doesn't.

Q. Then how could that be; in your belief, how
could that be true?

A. Because if you examine the Scriptural account
of creation carefully, you will find it is really just
talking about the surface of the earth.

Q. I see.

Can you quote the section you are referring to?

A. "And the earth was without form and void and
darkness was upon the face of the deep."

Q. Is this a belief and an understanding you have
come to recently or is it one you have always had?

A. It's one that I have had for quite a number
of years.

Q. Forty, ten?

A. Oh, for twenty years.

Q. What about the stars and the sun?

A. I don't think those were involved in creation


Q. They were there?

A. Yes.

This is my personal opinion.

Q. I see.

A. I'm speaking for myself.

Q. That is your interpretation from your reading
the Bible?

A. Yes.

Q. Did God put them there?

A. God created them, put them there.

Q. Why did He wait so long to put life on earth?

A. I don't know.

Q. Do you have any theory?

A. Of why God waited so long?

Q. Yes.

A. What is time to God?

Q. Who do you respect as leaders in the field of
Creation Science research other than the people at the
Geoscience Research Institute?

A. I respect Gish and Morris and John Moore
and others.

I may not agree with them totally, but that is
nothing unusual among scientists.

Q. No, it's not.

Are there standard scientists whose work you

A. Yes.

Q. Whom?

A. Oh, a large number.

It would be impossible to begin to recite them.

I respect the work of some of the individuals that
are going to be witnesses for you.

Q. Professor Gould, for instance?

A. Gould, Ayala and Simpson and some of the

Q. They come to enormously different conclusions
than you do, though?

A. Sure.

Q. Professor Gould recently won an award for
being a genius; are you familiar with that, the Mac-
Arthur Fellowship?

A. I heard about it recently.

Q. Have you corresponded with him at all about
your research?

A. No.

Q. What about with Professor Simpson?

A. No.

I haven't corresponded with any of them.

Q. You haven't wanted to share your work with
them at all as people in your field that you respect?

A. Well, our research has not really been in
the same areas and there is no occasion for me to be
writing to them.

Q. Professor Gould is an invertebrate paleon-
toligist, isn't he?

A. I'm not aware that he is.


Q. What do you understand he is?

A. I understand him to be an expert in the
history of science.

Q. Have you read any of this works?

A. Yes, I have.

Q. What have you read?

A. I have read some of the work he has authored
on his theory on punctuated equilibria and I have read
at least portions of his book --

Q. The panda's thumb?

A. No.

I have read at least one dealing with neotony and
and recapitulation.

Q. And you don't know that he is an invertebrate

A. I never thought of him that way.

Q. Do you know the book "Evolution, Fossils
Say No"?

A. Yes.

Q. That is by Dr. Gish.

Do you agree with that book?

MR. CAMPBELL: I would object.

That one is somewhat ambiguous.

I mean, do you mean particular parts of the book?

MR. KLASFELD: Well, do you generally agree with
the book?

A. Yes, generally.

Q. Are there areas with which you disagree?


A. It depends on the edition.

Some editions have information that I am not so
sure about and others do not have.

Q. Are you distinguishing between the public
school edition and the non-public school edition?

A. No.

Just different printings, different editions.

Q. What is it that is in one of the editions
that is not in the other and that you disagree with?

A. I think the main thing is the use of the
so-called human footprints in the Biloxi River in

Q. You disagree with that?

A. I don't think it's sufficiently strong
evidence to use.

Q. Do you use Dr. Gish's book as a research tool,
as a teaching tool?

A. I have used it as a teaching tool.

Q. Is it a book that is generally accepted by
Creation Scientists?

A. I really can't say.

I am not that well versed with what other creation
groups are doing.

Q. Why is it that you think you are not going
to testify about your work in the ginkgo petrified

A. Well, that is a point of interest but I
haven't thought of it as being a particularly important


aspect of what I have written on or what I have studied

Q. Did you discuss your work in the ginkgo petri-
fied forest at all with Professor Daniel Alexander?

A. No, I haven't.

Q. What other areas do you anticipate testifying
about, to the extent you have given it some thought?

A. A sudden appearance of complex organisms in
the Cambrian, which we have already covered; the absence
of good connecting links between major groups.

Those would be the important points.

Q. What else?

A. Well, I think that is the essence of peleon-
tological testimony.

Q. What is the archeoptrix?

A. It is a bird that is considered to be a con-
necting link between reptiles and birds.

Q. I gather you don't consider it to be a con-
necting link?

A. No.

It's a bird.

Q. Why?

A. Because it has feathers exactly like a modern
bird and it could fly.

Q. What about its sternum bone, is its sternum
bone like a lot of birds?

A. It lacks the typical bird's sternum but that
does not preclude its ability to fly, as has been pointed


out in the scientific literature.

Most birds don't have their -- many birds don't
have their flight muscles attached to the sternum.

Q. What would you want to see in a link between
birds and reptiles that doesn't appear in archeoptrix?

A. Some intermediate form of feather, for in-

Q. Well, there are no feathers preserved in
fossil record, are there?

A. Yes, there are.

- - -


MR. KLASFELD: Q. Is evolution a science, Dr.

A. Usually so considered.

Q. Do you so consider it?

A. Yes.

Q. What are the attributes of a science?

A. The scientific method of science is the body
of knowledge arising from the use of scientific methods
which is experimentation and observation.

Q. And does evolution, people who study evolution,
do they do that?

A. Yes.

Q. Are you aware of Creation Science's
criticism that evolution isn't a science because you
can't observe what was supposed to have happened millions
of years ago?

A. Yes, I am aware of that criticism.

Q. Do you disagree with that criticism?

A. I would say that's a qualification that has
to be made in regard to Evolution Science.

Q. So it is not a particular good science?

A. It is science, but it does have to operate in
some ways that are not truly scientific.

Q. Is Creation Science a better science than

A. It is in the same category.

Q. And what would that category be?

A. If evolution is science, creation is science


and if evolution isn't science, creation isn't science.

Q. But in your mind, is evolution science?

A. Yes.

Q. Are you familiar with the term falsifibility
in terms of science?

A. Yes.

Q. Is evolution falsifiable?

A. Basically, essentially, no.

Q. Is Creation Science falsifiable?

A. No.

Q. Does science, in your mind, have to do with
the examination of the natural world?

A. Yes.

Q. Did the events that take place during creation
week, were they part of the forces that are at play in the
natural world?

A. To some extent.

Q. To what extent are they not?

A. As far as we know, there are no activities
going on in the world today that would be similar to those
involved in the actual creation process.

Q. So the study of Creation Science in that sense
is not a study of the natural forces in play in the world

A. Creation is not something that we can observe
today, not the kind of creation that went on then.

Q. But not only is it not something that we can't
observe today, but they are not the natural forces that


are in effect today, either, is that correct?

A. I think I can answer yes on that, but the laws
of nature in operation in the world today were established
at creation.

Q. But did not take place during creation, there
were other laws in effect then?

A. They were in operation then, too, but there
were other laws beyond them that are not in operation now.

Q. What laws were those?

A. If we knew, we would be winning the Nobel Prize.

Q. Does Creation Science make any sense without
the Bible as sort of a belief form?

A. I have felt that it does, that a person who
knew nothing about evolution or creation, if he took the
fossil record at face value, he would come up to the
opinion that there was a sudden creative act.

Q. Based on the sudden appearance of complex
organisms in the Cambrian, and the absence of good
connecting links between major groups?

A. That's right.

Q. Those two?

A. That's right. Now, I might add, in the study
of paleontology and these two points, it may well be
that we would spill over into speciation to some extent,

Q. Is there any aspect of speciation that makes
you believe that it has to stop at a certain point?

A. Yes.


Q. What mechanism is that?

A. Genetic mechanism.

Q. Which one?

A. The inability of the chromosomes to synapse,
match up.

Q. Synapse doesn't mean match up, does it?

A. That's the way it is used in genetics.

Q. I thought a synapse meant the gap?

A. No.

Q. Is that wrong?

A. Not in genetics.

Q. And this inability of chromosomes to synapse
creates the parameters within which --

A. The limits.

Q. -- the limits for which DNA can change?

A. Between which crossing between diverse types
can occur.

Q. Could you tell me what it is that you anticipate
testifying about the sudden appearance of complex
organisms in the Cambrian as support for your belief in
Creation Science?

A. Well, if the theory of evolution is correct,
there should be a series of steps leading up to these
complex organisms and since those are not found, the
evidence supports sudden creation.

Q. What about these organisms that we discussed
before that are in the pre-Cambrian?

A. It may have enlarged to the picture some of


what is in the pre-Cambrian, but, to my knowledge, none
of them classify as ancestors to the Cambrians.

Q. And what would you anticipate saying about the
absence of good connecting links between the major groups?

A. That even in punctuated equilibria, which is
Gould's and Eldrige's ideas, you would still have series
of connecting links between one basic category and

Q. And that those links are missing?

A. Yes.

Q. What about intermediate structural forms, do
you view those as, one, existing; and, two, if they are
existing, are they evidence for evolution?

A. Are you thinking of like vestigia organs?

Q. Like that.

A. Well, that argument is almost never used any-
more in evolution. Vestigia organs have pretty well turned
out to be useful.

Q. How is the appendix useful to me?

A. Well, I am not a physician, but I think you can
find that quite a number of them would suggest that
it does have a function.

Q. Are you familiar with Professor Gould's work
on the Panda's thumb?

A. I have not read it, but I have heard mention of




Q. You understand what the panda's thumb is and
what it does?

A. No, you would have to explain it.

Q. Are we, as organisms, as efficient as we might

A. No.

Q. Why did God make us inefficient?

A. He didn't. There has been change, degenerate
evolution, if you please, since creation.

Q. I am a less inefficient form than the form
that existed four or 5,000 years ago?

A. What was the first word you said?

Q. I.

A. I, not this "eye"?

Q. That's right.

A. Yes.

Q. How come people today can run faster than
they could a hundred years ago?

A. Because of various factors. They have learned
how to train for those particular muscles and nutrition is
better. We know more about nutrition.

Q. Aren't they more efficient?

A. To some extent.

Q. How do you explain that in terms of your
notion of degenerative evolution?

A. That example would have to be balanced by the
increased number of individuals in insane asylums and
people who are mentally retarded.


Q. Do you believe in the existence of unidentified
flying objects?

MR. CAMPBELL: Object to that for relevance purposes,
but you may answer it.

THE WITNESS: Not very -- not very well. Not very

MR. KLASFELD: Q. Do you believe that testability
is a hallmark of science?

A. Yes, it should be.

Q. In what sense is creation science testable?
Is creation week testable?

MR. CHILDS: Scientifically?

MR. KLASFELD: Q. As a science.

A. It is not testable scientifically.

Let me qualify that slightly. There is no good
explanation for the week, outside of creation. But to my
knowledge, that's the only, shall we say, scientific
evidence in support of creation week.

Q. What is the only scientific evidence?

A. The present worldwide, still today, of a seven-
day week cycle.

Q. Oh, I see, the fact that --

A. There is no astronomical explanation.

Q. Monday through Sunday?

A. Yes.

[Discussion off the record]

MR. KLASFELD: Let me mark this as the next exhibit.

[Document, more particularly


described in index marked
Plaintiffs' Exhibit 6 for identi-

MR. KLASFELD: Q. Section 4(a) of the Act defines
creation science. It says,

"Creation science includes scienti-
fic evidences and related infer-
ences that indicate: one,
sudden creation of the Universe,
energy and life from nothing."

What is the scientific evidence for that?

A. I think we just discussed the fossil evi-

Q. This is the sudden creation of the Universe,
energy and life from nothing.

Oh, you are saying the fossil evidence is the evi-
dence from sudden creation of life?

A. Right.

Q. What about sudden creation of the Universe?

A. I really can't go into that, because I am just
not at all versed in astronomy.

Q. And energy?

A. Even less, really.

Q. And number 6,
"A relatively recent inception of
the Earth and living kinds."

What is the scientific evidence for that?

A. The evidence is on the surface of the Earth,


that its present configuration has not been around that

Q. What are those specifically, those evidences?

A. That if it had been around a long time, there
would have been erosion down to sea level and filling in
of the Gulf of Mexico and that type of thing.

Q. But you said that could have been as much as
several hundreds of thousands of years, is that correct?

A. Yes, I said that. Several thousand to --

What did I say?

Q. I thought you said several hundred thousand.

A. Several thousand to several hundred thousand, I
said, on the basis of scientific evidence.

Q. Yes.

What is the basis for your belief that it was
certainly less than 10,000?

A. Well, of course, that statement there says
relatively young. It doesn't identify it.

Q. That's right.

A. So I am not sure what they are thinking of.

Q. But you do in fact believe that it is 10,000
years or less?

A. My opinion, not so much based on science as
based on my confidence in Scripture, is that it is just a
few thousand years old, life upon this Earth.

Q. What is the scientific evidence for separate
ancestry for man and apes?

A. The absence of a good series of connecting


links between man and ape.

Q. Are you going to testify at all about any other
aspects of the geological column, the formation of the
geological column during the flood period?

A. Well, of course, we have already mentioned that
I haven't prepared the testimony yet. But I could discuss
how the geologic column could be explained on the basis of
an ecological sequence rather than an evolutionary

Q. Why are there no complex forms in the Cambrian?

A. What you are trying to say, why are there no
vertebrates in the Cambrian?

Q. Yes.

A. Well, fish have been reported in the Cambrian,
but on the basis of our concept of ecology, we wouldn't
expect to find at least land vertebrates, because these
are largely sea bottom creatures that are found in the

Q. Why are they there?

A. Because they would be the first ones buried in
a universal catastrophe.

Q. It wasn't just a flood, though, right?

A. I am thinking.

Q. The fish wouldn't drown, is my point.

A. Oh, yes, they would. You stir up the water
and get it muddy and the fish would not survive. But that
would happen later. I mean there would be a little
passage of time before the fish would start to drop out.


Q. How about the trilobites?

A. They are benthonic animals, benthonic animals.
They live on the bottom.

Q. Weren't there any dead fish lying on the

A. Apparently there are, if the reports of fish
are true, although very few have been found in the

Q. Aren't there always a lot of dead fish on the

A. No, that's an amazing thing. Vertebrate
remains do not accumulate down in present ocean bottoms.
It is so rare to find even the scales of fish on the
bottom of muds, of lakes or rivers that it even gets
reported in the scientific literature.

Q. Is the geologic column, is it consistent
around the world?

A. Pretty nearly so. Australia, South America,
are a little odd.

Q. But in general, it is an amazing consistency?

A. Yes.

Q. How do you account for no sort of mixing?

A. There is mixing, but not through the whole

Q. Not one trilobite got missed?

A. You mean surviving today?

Q. Well, even getting up above the Cambrian level.

Q. There are trilobites all the way up to the



Q. Oh, is that right?

A. Yes.

Q. Where is that found?

A. Where is it found?

Q. Yes.

A. You mean the mississippian?

Q. Where are the trilobites found in the
mississippian level?

A. This is nothing rare. This is the usual
stratigraphic range.

Q. How did they get up there?

- - -


A. Some were swimmers and some were bottom-crawlers
and some were mud-burrowers, and as far as ecologic idea
is concerned, they would be buried in that sequence.

Q. So that the ones that were mud-crawlers were
on the bottom and the ones that were swimmers were found
further up?

A. Farther up, yes.

Q. Why did the swimmers get drowned?

A. For the same reason that any fish, which have
gills, would be unable to extract oxygen from turbid

Q. Why aren't there trout with the swimming

A. Why aren't there what?

Q. Dolphins with the swimming trilobites?

A. Of course, when you get up farther, farther
up the geologic column, you do get into vertebrates.
There are vertebrates.

Q. Are there vertebrates where the trilobites are?

A. In the same formations in the same geologic

Q. Are there any cows where trilobites are?

A. No.

Q. Why not?

A. Because cows don't walk around on the bottom
of the sea.

Q. But you said some of the trilobites swim.

A. Well, the cows don't swim, either.


Q. So that the first division is things that are
in the water, right?

A. The lower Paleozoic is sea bottom and sea-
swimming animals.

Q. Why aren't there any cows with the dinosaurs?

A. I would take that to be evidence that they
occupied a different kind of environment than with such
animals as the ungulates would occupy.

Q. The dinosaurs did?

A. Yes.

Q. Are there dinosaur fossils where we have cows,

A. In the fossil record?

Q. No, no. Are there dinosaurs in the fossil
record where there are cows living today?

A. Oh, sure. You mean, in other words, cows are
grazing in Colorado where there are dinosaur fossils

Q. Yes.

A. Sure.

Q. So why aren't there remains there today,
fossil remains?

A. Well, I am sure you wouldn't want to say the
environment in Colorado now is the same as when the
dinosaurs were buried.

Q. No, I wouldn't.

A. I wouldn't, either.

Q. But at the same time you are willing to talk

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