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The Critic's Resource on AntiEvolution

Deposition of Dr. W. Scott Morrow

                                 No. LR-C-81-322
                   Plaintiffs             *      IN THE UNITED STATES
VS.                                       *      DISTRICT COURT, EASTERN
ET AL.                                   *
                    Defendants        *      WESTERN DIVISION

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


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

                                     MR. DAVID KLASFELD,
                                            Attorney-at-Law, Skadden, Arps,
                                            Slate, Meagher, & Flom, 919
                                            Third Avenue, New York, New
                                            York 10022
                                            ** For the Plaintiffs

                                     MR. CALLIS CHILDS,
                                            Attorney-at-Law, Assistant
                                            Attorney General, Attorney
                                            General's Office, Justice
                                            Building, Little Rock,
                                            Arkansas 72201
                                            ** For the Defendants

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

ALSO PRESENT:                     DR. JOHN W. CRENSHAW, JR., PH.D.
                                            DR. NORMAN GILES, PH.D.
                                            MR. KEVIN MALLERY

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


PH.D., a witness produced on behalf of the Plaintiffs,
taken in the above-styled and numbered cause on the
22nd day of November, 1981, before Certified Court
Reporters and Notaries Public in and for Fulton County,
Georgia, at Atlanta Marriott Hotel, Courtland and
International Boulevard, Atlanta, Georgia, at 2:45
p.m., pursuant to the agreement thereinafter set

MR. DAVID KLASFELD: There are certain
stipulations we want on the record, that is,
signing is not waived; that our expectation
is to get the signed copy back prior to the

All objections are waived except as
objections to form. The deposition is being
taken for all purposes of discovery.

MR. CALLIS CHILDS: I don't think
that's what we stipulated.


MS. LAURIE FERBER: All purposes
allowable under the Federal Rules.

MR. CHILDS: There's no stipulation
that is it to perpetuate testimony.




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


Q Dr. Morrow, would you please state all the
scientific evidence that you're aware of which supports
Creation Science?

A All right. Do I have time to think about
this one, or do I have to --

Q Certainly.

A Well, previously, I've expressed myself
to the effect that Scientific Creation is -- as I see
it, is not a coherent body of concepts, and it, as I
see it, consists of a complication of what could be
called insufficiencies in evolutionary theory.

Now, to try to answer your question directly,
I would say, the strongest argument against evolution
is probably a statistical one based upon what I think
is the low probability, the complex systems -- complex
living systems could develop that degree of complexity
in the time that apparently was available.

Q How much time is that?


A Well, not being a cosmologist, I'd have
to rely upon what other people have told me or what
I have read. And presumably, if we take five billion
years as the age of the earth and if we believe the
evidence for fossil bacteria is about three billion
years, we have two billion years to go from nothing
to the first cell. I don't think that's enough time.

Q You don't think that two billion years
to the development of the first cell was enough time
for the first cell to be developed.

A That's exactly right.

Q How much time would have been enough time?

A I haven't the slightest idea, but I'm
certain that two billion years is not enough.

Q Why?

A Why?

Q Yes.

A Well, for the first cell to be a viable,
living, reproducing cell, you would have to have a
working protein synthetic system, DNA replicating
system, RNA replicating system, and you'd have to
have a generic road in place; and I don't see how this
is going to happen, given -- well, at least to my
knowledge -- the loss of chance.

Q And that's how life came together, by the


loss of chance?

A Well, it depends upon what you're choosing
as your starting concepts.

Q My problem is that if you don't know how
long that it would have had to take, why do you think
two billion years wasn't enough time?

A That's a perfectly good question. I would
myself turn it around and say that if you think it
isn't enough time, then it's your obligation to show
me the mechanisms and the time spans and show it

Q But why is two billion years not enough

A Why is it not enough?

Q Yes. What are the probabilities and the
mathematical functions that suggest that it's not

A I'm not a statistician. I don't make
those calculations.

Q Well, somebody else made them in the way
that you were satisfied with?

A In general what I have read about that;

Q Whom?

A Who?


Q Yes.

- - -


Q What have you read?

A Well, some recent statements by Hoyle.

Q That would be Fred Hoyle?

A Right. I don't have a long documented list
of what I read and what said what to back this up.

Q I may be wrong, but is it Mr. Hoyle's area
of expertise of astronomy?

A Sir, I don't see that that is any particular
deficiency on his ability to sit down and make statis-
tical calculations; that that's one of his specialities.

Q Doesn't it affect his ability to make statis-
tical calculations about subject matters other than

A No.

Q If he was going to use statistical abilities
to pick race horses, would that be okay?

A I don't know if I quite understand what you're
saying. If you are asking me whether or not Hoyle is
capable of making intelligent scientific statements
outside his formal area of expertise, I would say yes,
he is.

Q Who else besides Hoyle?

A Something I read attributed to Echols indi-
cated that he felt that there was insufficient time for
the brain to develop.


Q Who is Echols?

A Sir John Echols is a Nobel Price winner and
neurophysiology or biochemistry.

Q Where did you read this?

A I can dig it out of my briefcase, it was an
article sent to one of my colleagues at Wafford College.
Those are recent things. Like I can put names to
articles, so to speak, or a name to an event.

Q Who else?

A I don't remember. But let's just put it this
way: A simple type of calculation, as I see it, would
be something like this. Let's say you have a polypep-
tide, it's fifty amino acids long. That's a reasonable
length for an enzyme.

If you have 20 different amino acids, I would
presume you would put these amino acids into a specific
order. I guess you would have something like twenty
to the fifty power combinations.

Q Un-huh.

A Now, if we assume, for example, that molecules
-- all of these molecules are viable and they collide,
let's say, one per second, I would tend to doubt that
you would get that enzyme in two billion years.

Q Tend to doubt is -- at least to my mind --
an unscientific choice of words.


A Not at all. Scientists not in exact field.

Q I understand that. But to say that your
most serious argument against the Theory of Evolution

A The Theory of Molecular -- I think you know I
am an evolutionist. I am talking about the difficulty
from going from no polymer species to a living cell in
two billion years.

Q How do you define evolution? You say you are
an evolutionist. How do you define that?

A How do I define it?

Q Yes.

A Let's say there's two different realms that
you would be dealing with. One would be what I call the
chemical evolutionary days which would take us from the
beginning of the planet Earth -- or whatever that might
be -- to the point where you have a cell that's capable
of reproducing itself.

Then beyond the cell to what we have today
would be the Darwinian phase. So what I direct my
attention to is the earlier part.

Q When you say you are directing your attention

A Yes.

Q Is it what you direct your attention to in your


attention to in your professional life?

A I am a biochemist. Insofar as I have to teach
biochemistry in these topics, these are part of what I
teach, yes.

In other words, I don't see a difficulty with
the Darwinian aspect of evolution once you have the
cell. I see some central difficulties getting to this.

Q What has all this got to do with Creation
Science. I mean, the fact that you don't think that the
cell would have lived in two billion years --

A That's not exactly what I said. I said -- not
being accustomed to talking in a legal terminological
way. I don't think there's enough time to produce the
first cell, that's what I said. Now, what that had to
do with Creation Science?

Q Yes.

A Well, presumably your scientific creationists
don't think there's enough time either, and I would
presume that my fellow evolutionists feel there is enough

Q But creation -- let me start at the beginning.
How would you define Creation Science?

A Creation Science is a set of concepts that's
pretty much based upon what I would call a sudden un-
folding of events leading to the formation of life on


the planet as we know it.

Evolutionary Science is based upon a much more
gradual unfolding. So we are really talking about how
much these things happen.



Q Does Creation Science have any kind of
scriptural basis, or is it purely a scientific --

A As I understand, it's quite scientific.
I don't see any necessity to bring the Bible in it
at all. Frankly, I think it's irrelevant.

Q The Bible is irrelevant?

A As far as these particular arguments are
concerned, yes.

Q Well, the Act 590, Section 4A and 4B,
Section 6, contrasts what is characterized as the
Evolution Science Notion of how long all of this
took to the Creation Science function.

The Evoluation Science Notion is, quote,
an inception several billion years ago, the earth and
somewhat later of life. The Creation Science Notion
is, quote, an irrelatively recent inception of the
earth and living kinds.

Now, in earlier depositions in this case,
witnesses for the Defendant, expert witnesses, have
testified that they believe that the relatively
recent inception of the earth, of which the statute
speaks, took place between eight and ten thousand
years ago.

Do you believe that to be true?

MR. CHILDS: David, we will interject


one thing, and that is, that some of the
witnesses went over -- one witness went to
a million, and another witness went to a
hundred thousand, so within that range.


MR. CHILDS: I think that will be a
fair statement.

THE WITNESS: You are asking me if I
think that's true. My own understanding of
the evidence is that, that is far too recent.


MR. CHILDS: Remember, I was talking
about five billion and three billion.

MR. KLASFELD: Right. I understand.

Q (By Mr. Klasfeld) Well, let me just take
you through the definition of creation of science, as
it reads in this statement.


Section 4 says, quote, Creation Science
means the scientific evidence for creation and
influences from that scientific evidence. Creation
Science includes the scientific evidences and related
influences that indicate, one, sudden creation of the
universe, energy, and life from nothing.

What is the scientific evidence that you


are aware of that supports that statement?

A Well, I would have to delete "life" from
it, and I would say that pretty much sounds like the
basic concept; in other words, I don't see any
difference between that statement, if you delete
"life" and what is called the Big Bang Theory.

Q And if you include life?

A Now, if you include life, then we have to
worry about what the word "sudden" means.

Q Okay.

A Now, if the universe is 25 billion years
old, and all this takes place in five billion years,
that might qualify as being sudden.

Q Too, the insufficiency of mutation and
natural selection in bringing about development of
all living kinds from a single organism.

Let me just for a second skip down to

A Well, I would, myself, say that I don't
see anything wrong with Item 2. Remember, I'm an

Q I understand.

A Okay. I think that mutation is fine.

Q Do you think that mutation of natural
selection are sufficient to bring about the development


of all living kinds or a single organism?

A I'm convinced of the evidence of mutation
or natural selection of being sufficient, yes.

Q Are you aware of any scientific evidence
that supports 4A, that is insufficient?

A The insufficiency, only insofar as time
goes, on the people that are in that field, do change
the model.

Q Well --

A But they don't change it enough to make
the model invalid.

Q But are you aware of any scientific

A I'm aware that the evolution scientist
or the scientists that do this work have not settled
among themselves exactly how mutation and natural
selection brought these processes about.

Q Well, that's a different thing. That
sort of speaks toward the mechanism.

A Well, there are insufficiencies in their
model. But I'm not persuaded that those insufficien-
cies are enough to throw those out as the Bible

Q Three, changes only in fixed limits of
original kinds of animals. Are you aware of any


scientific evidence that supports that?

A No.

Q Four, separate ancestries of apes. Are
you aware of any scientific evidence that supports

A There are the two people that are
preeminent of that aspect who are alive today, and
I cannot remember their names.

Q Do they disagree as to whether or not
there was at some point a common ancestor for man and

A As far -- now, they don't disagree about
that, but they certainly disagree about how that
common ancestry was.

Q I understand that, but are you aware of
any scientific evidence that supports a notion of
a separate ancestry for man and apes?

A None that I think is sufficient enough
to persuade me to change my mind on it, so I would
say none.

Q None.

A I mean, there's no point in bringing
up half arguments and conjectures.

Q My point exactly.

Five, explanation of the earth catastrophism


including the occurrence of world-wide flood.

A I know of no evidence for a world-wide
flood, that I find persuasive.

Q Okay.

A As far as catastrophism, what do you mean
by catastrophism?

Q I think the question is what the Statute
means. The Statute means to say essentially that the
processes are going on here and taking place much
more suddenly than the evolutionists would have occur
in their model.

Q Well. to the extent that you are familiar
with the Creation Science model --

A Right.

Q -- are you aware of after the emotion of
a world-wide flood, that --

A I know the creationists interpret the
fossil evidence that say, and I know that as an
evolutionist, I interpret the evidence a different

Q Are you aware of any scientific evidence
that lends credence to the science model of --

A I'm aware, or that there's no scientific
evidence proving either one, and that's more to the


Q But there's no scientific evidence --

A There's no scientific evidence proving
either of those concepts.

Q Do you have any expertise in theology?

A I don't need it.

Q Why don't you need it?

A Because what I said stands on its own
merits, as a principle of science.

Q You are not aware of any scientific
evidence that supports the notion that the fossil
record --

A There is plenty.

Q Excuse me. Let me finish.

A No. You are putting words in my mouth.

Q First, let me finish the question, just
for the record, so the record accurately reflects
what my question is and what your answer is.

A Okay.

Q My question is, is what you said, that
there's no scientific evidence which supports the
notion that it took more than a year to lay down the
fossil record?

A I know of no scientific evidence that I
find persuasive that supports the idea of a world-wide
flood of the kind that scientific creationists believe



Q Okay. My second question: What I
understand 5 to be about, from my taking of
depositions in the case, and my studying of Creation
Science, and if you have a different perception, you
should make that clear, is that the evolution --
excuse me -- the creationists believe that there was
a world-wide flood that took place over approximately
the course of a year, and that the entire geologic
column and the entire fossil record throughout the
world was laid down during the course of that flood,
and the subsequent drainoff of evaporation of the
water from that flood.

Are you aware of any scientific evidence
which supports that theory?

A No. None that I find persuasive. Look,
I've discussed this with creationists back for about
the last 30 years. Okay. And their own thinking
has changed over these 30 years.

Q But it hasn't changed --

A I know that there are creationists that
don't think that all this took place in one year.

Q How long do they think this took place?

A I bet they are talking about 10,000 years.

Q Ten thousand years?


A I would guess.

Q Are you aware of any scientific evidence
that would suggest it could happen in 10,000 years?

A No.

- - -


Q And you've already said that you're not aware
of any scientific evidence that -- relating to No. 6,
a relatively recent conception of the Earth, when
"Relatively Recent" means less then a million years.

A That's correct.

Now, can we go back to that thing about pale-
ontology expertise?

Q Certainly.

A Find. Now, as I understand it, you were
asking me whether I had expertise in paleontology, and
I said I didn't need it.

Q Right.

A Now can we clarify that point?

Q Please.

A All right. One does not need expertise in
paleontology in order to make the statements that I did
that neither of these models can be proven scientifi-

Q Well, what is there about the -- shall we
call it the standard paleontological model that remains
unproven, in your view?

A You mean about origins? We don't know how
we got here. That's the insufficiency.

Q I know. I understand that.
I'm talking here about the fossil record, which


I understood you to be talking about.

A Fine. The fossil record has gaps in it that
all paleontologists will be agreeable to. Now, the
importance of the gaps are unsettled. If you use
evolutionary contacts, the evolutionists feel that
Evolutionary Theory would propose you to find the gaps;
and there's no way to bring those two groups of people
together. But I think that's irrelevant, whether those
two models are scientific or not.

Q But the Creation of Theory goes considerably
further. I mean, it talks as I understand it, about
two things that they view as important -- one, gaps in
the fossil record between species and reptiles and birds
and then what they sort of characterize as the sudden
appearance of life in complex form in Cambria.

A Uh-huh.

Q Now, that's two aspects of it, which I suppose
we could argue about whether or not you could scienti-
fically falsify one or the other. But they go further
and say that the entire geologic column was laid down
during a period of, you say, at an outside, 10,000

Are you satisfied, from a scientific manner,
that it took more than 10,000 years?

A Oh, I am; yes. But if you want someone to


speak that point, obviously you need to talk to someone
like Gish. That wasn't why I brought up that point a
minute ago. What I said was that neither of these
models can be proven scientific.

You can do work on individual processees like
natural fossils and prove what their origins were. You
can't prove what our origins were. We can't do that.
And something scientific which is in direct proportion
to a degree of falsifibility is something called the
principle of falsification; and for something to be
scientific, it must be -- at least theoretically be
capable of being shown to be false. Now, you can't
show either of these things to be false.

Q Well, if I found --

A And you can't do that, because you can't
run the creation off again. There's nobody around to
do it.

Q Yes. But if I found a human fossil among the
Trilobites, would --

A It would not be something that would fit into
the Creation Science at the present time or the --

Q I think it would fit into the Creation Science

A I think both models --

Q But the Creation Science model, as I understand


it, would simply say -- as a matter of fact, one of
their major articles with which you may be familiar is
the argument about whether or not there are fossil --
human fossil footprints on the Poluscy River with the
dinosaurs, and their argument, as I understand it, was,
look, that is humans and dinosaurs at the same place at
the same time. That's what the Creation model suggests,
and they are looking for these kinds of arguments; and
they would argue that if you found human fossils with
Trilobite fossils, that would show that you know men
and Trilobades were at the same time.

A Okay. To that extent, I stand corrected. If
you find a good old human skull, preferably recent,
okay, back that far, that would be a thunderbolt.

Q My point then, is that classic paleontology
would be falsified if they were true.

A Not in terms of origins. Now, if you're
talking about origins as if they began, for example,
in the Cambrian or pre-Cambrian, that's a very insuffi-
cient use of the term. I'm talking about origins of
life; not just origins of man.

Now, if the origin of life occurred five
billion years ago or if it occurred one billion years
ago, there's no way we can test that. We have no obser-
vations at that time about anyone. So we're extrapolating


back into the past in both models.

Q Now let me go back to where I started. You've
talked about one area of criticism you have of the
evolutionary model, which has to do with the amount of
time that it might have taken place until the first
life forms.

All right. What other scientific evidences
are there against evolution and in favor of Creation

A Well, again, the strongest things are the
statistical improbabilities that you would have complex
systems arise in the way that would be required. Okay?
The second thing, I guess, would be the problem with
what are called gaps in the record. One thing I don't
particularly like is the fact that Evolutionary Science,
in what I think is circular reasoning, uses the gaps to
support itself.

Q You're speaking now of gaps in the fossil

A Yes. But I would be much happier if there
were more transitory forms.

Q What are archaopterists?

A What about it?

Q Is it a transitional form?

A It may very well be, but we need more transi-


tional forms than just one.

Q What about intermedial structural forms?

A Well, I mean, those things are there if you
look strongly enough at them.

Q What about -- I mean, it's something like
this. You could look at the comparative anatomy or
physiology among, let's say, all chordates. That's
c-h-o-r-d-a-t-e-s. Now, you can look at those similar-
ities and say, ah, they all had a common origin; however
some are more advanced than others, so they came later.
Or you can look at that sort of thing and say they
pretty much occurred at the same instant in time and
some appeared initially as more complex than another.

Now, there's two different ways you can look
at the same evidence, as far as I'm concerned.

Q Do you have any expertise in physiology?

A Insofar as I'm a biochemist.

Q Well, have you ever -- what courses have you
taken in physiology?

A What have I taken in Physiology?

Q Yes.

A I haven't taken any in physiology. I'm not
a physiologist.

Q And you have no courses in paleontology?

A No. You don't need it to make the statements


that I did. You don't need to take a course or have a
degree in something to be able to talk about it.

Q Well, that's correct. But in order to give
expert --

A Expertise comes through study and work; not
just through formal practice in a classroom.

I'd like to throw in that typically, the people
who contribute most in this life contribute in fields
other than where they got their Ph.D.

Q What studies have you conducted on our own
in the area of paleontology?

A I haven't done any. I'm not a paleontologist.

Q And in physiology?

A I haven't done any. I'm not a physiologist.
I think those are irrelevant questions.

Q Okay. What about the area of fossils them-
selves, what studies have you done?

A That's also irrelevant.

Q Okay. We have the length of time it took to
create life, the gaps in the fossil record. What other
evidence --

A I think those are quite sufficient.

Q Are there others?

A There may be, but they've escaped me right


Q Would you anticipate and testify in the trial
that you'd be testifying in these two areas?

A Possibly, if I thought I was strong enough
in that area; yeah.

Q And other areas?

A If they come to mind, I'll be glad to communi-
cate that information to you.

Q But right now, you can't think of anything

A Right now, I can't; no. But I don't think
that those are important. My support of this piece
of legislation does not rest only on the things that
I've said; they rest on other things.

Q Okay. We will go to the other stuff later.

A Okay.

Q Why did you change your name?

A Frankly, that's none of your business.

Q Why did you change your name?

A I still think it's none of your business.
Now, if you can show me that that's pertinent to this
particular topic, I'll be glad to answer your question.

Q You know, it's something that leaps off your
resume, and I'm entitled to ask about essentially any-
think that I want to.

A And I'm entitled to withdraw an answer if I


see fit.

Q Well, I understand that. I mean, basically,
eventually what happens at the trial is, if somebody
asks you the question --

A I'll suggest you go back to Chapter I and
check the legal record, and they'll have the reason

Q Okay. Your resume indicates -- at least this
copy of your resume that I have -- no publication since
1977. Have you published anything since 1977?

A Huh-uh.

Q Was that a "No"?

A No.

Q Is the "Bulletin of the South Carolina Academy
of Science" a refereed journal?

A I doubt it. I mean, I expect that the papers
we submit for publication there are read and reviewed,
but they're not read and reviewed with the type of
rigor that you'd have with, let's say, the "Journal of
the Book of Biology."

Am I allowed to ask you questions? No.

Q No.

A So be it.

Q That's one of the glories of the deposition
process -- the lawyer asks the question, and the witness


gives the answers.

A I take it you're on the other side. You know,
I don't really know.

Q I'm on the other side.

A Okay.

Q What is Snow's two culture concepts? What
are --

A The general idea, as I understand it, is
that Snow divides academic or intellectuals into two
different categories -- scientific intellectuals and
literary intellectuals -- so that we have, in the
intellectual world, these two realms of intellectability.

Q Have you found out anything about the bio-
chemical methodology for the Gambling Addiction Inter-
vention and --

A I would like to know why that is interest
first with Snow's thing.

Q It simply occurred to me as you were answering
the question.

A Thank you for answering.

MR. CHILDS: It's perfectly legitimate
for the lawyer to -- if a question occurs
to him, to go back to it.

THE WITNESS: That's also a technique
that's used in brainwashing.


MR. CHILDS: I don't think we ought to
say anything about that.

Q (By Mr. Childs.) Are you familiar with brain-

A I've read a little bit about it.

Q What kind of work are you doing with the
Gambling Addiction Intervention and Research Center?

A Right now, I'm not doing anything. I'm waiting
for them to ask me what they want me to embark on. This
center, I think, was set up within the last two or
three months, and the psychologist who is responsible
for putting it together is a good friend of mine, and
he would like somebody with some biochemical expertise
to provide him with some, say, provisional answers and
some criticism of any grant proposals that he might
come up with. So it's just a consulting position where
there's no remuneration.

Q What biochemical methodology might be involved
with gambling addiction?

A Well, it's been proposed, for example, that
you, shall we say, get fatty fluid samples from people
that are compulsive gamblers and then body fluid
samples from people who are not compulsive gamblers,
and look for biochemical differences. And he asked
me my opinion as to whether that is feasible, and I told


him, to the best of my knowledge, it's feasible, but
involves a lot of work, and I don't know if it's worth
the effort yet.



Q How did you come to be offered as an
expert witness in this case; what was the first
knowledge that you had of this case?

A I believe I received a telephone call
from a gentleman named Ed Gran.

Q Could you spell that, please?

A I think his last name is G-r-a-n.

Q Who is Mr. Gran?

A If I remember correctly, he is a physicist
professor at the University of Arkansas.

Q What did Mr. Gran say to you?

A He introduced himself, I think, and
indicated that he had received information that I was
favorably disposed toward this type of legislation and
asked me if I would be willing to assist in Arkansas.

So we discussed it in general terms and
I said sure because I had done that kind of thing in
South Carolina.

Q What happened?

A What happened?

Q Yes. Who was the next person that you
spoke with?

A Frankly, I don't remember. It may have
been Gran again or it may have been Wendel Berg.

Q Was this in relation to your testimony in


this case or your possible intervention in the case
as an intervenor?

A I guess -- I don't know what you mean by
intervenor. I offered my services, I will put it that
way. Since I am an evolutionist -- I am also not a
Christian -- I dare say that would be important for
people on what could be called our side.

Q There was a Motion to intervene in this
case made by Mr. Berg on behalf of a number of groups
and individuals of who, I believe, you were one in
which you sought to become a party to the case. Are
you familiar with what I am speaking about?

A Probably not sufficiently for the legal
aspects of it. Essentially what I had to say was
something like this: I laid out probably to Gran
what I believe in, what I was in favor of, and what
I was willing to do. And I probably said something
to him like: If you can use this thing in some sense,
I will be glad to support it. I don't know if you
find that satisfactory.

Now, I had a long talk with Byrd, I
think, over the telephone for someone in Byrd's
office, and he took down a lot of what I had to say.

MR. CHILDS: Was he an intervenor?



MR. CHILDS: Why don't you tell him
what that means.

THE WITNESS: That would help.

MR. CHILDS: I am not sure he under-

(Thereupon, and off-the-record discussion
was held.)

Q (By Mr. Klasfeld) Who don't we both
look at these copies which we will mark as Plaintiff's
1, the affidavit of Dr. W. Scot Morrow, a science
professor, evolutionist, and agnostic. This is a
supporting motion to intervene.

(Thereupon, Plaintiff's
Exhibit No. 1 was marked
for identification.)

Q (By Mr. Klasfeld) Have you ever seen this
document before, Dr. Morrow?

A Probably. It looks like -- have I seen it?

Q This copy, does not have your signature.

A I probably said something like that.

Q No, no. My question is: Have you seen
this document?

A What I am trying to tell you is I don't
memorize things flat out. And if you give me a moment,
I will tell you whether or not -- I probably did it.

This is probably the kind of thing that I


would have said to someone like Wendel Byrd in the
course of that conversation. But I didn't sit down
and take dictation on it.

Q I am not asking you whether or not you
said what is in the contents of this document, I am
asking you if you have seen this document before.

A I would say yes. I mean, how can I tell
you otherwise? I told you that I talked to Byrd --
I guess this is the document, I don't have any way of
proving it one way or the other. I would have probably
signed it.

Q I am asking you if you recollect seeing
it before?

A This sheet of paper?

Q Not this particular sheet of paper, but
the original from which this document is a copy.

A I don't know how to answer your question
within the legal framework. I suppose so; I mean, I
don't know how I can prove to you whether I have seen
it or not if I didn't sign it.

Q I am not asking you to prove anything
to me. I am only asking you whether or not you recall
seeing this document.

A Can I talk to that gentleman?

Q Sure.


(Thereupon, a short break was held.)

MR. CHILDS: I want the record to
reflect that I have advised Dr. Morrow
that he is not a party to this litigation
and that I do not represent him here.

He is here as a witness voluntarily;
but he will be a witness for the Defendants'
side of the lawsuit in Little Rock.

And he asked my advice on what he
should do. I advised him that I was not
his lawyer, and then I did tell him to
answer the questions; that it would be
better for all if he answered the questions
as clearly as he possibly could. And if
there was any question in his mind about
what was happening, I would be glad to
discuss it with him.

Q (By Mr. Klasfeld) My question, as I
recall it, was: Have you seen the original of this

A I believe so. However, the piece of
paper that I saw before I had signed. And this does
not have my signature on it. That was the difficulty.
I am reluctant to answer that type of question with
a simple affirmative answer because it implies


something other that what I think is implied.

Q That's fair. It says in Paragraph 1 that
you were the Vice-President of Arkansas Citizens for
Balanced Education in Origins. Are you a citizen
of Arkansas?

A Not to my knowledge.

Q Where do you reside?

A South, Carolina, Spartanburg.

Q When was the Arkansas Citizens for
Balanced Education in Origins formed?

A Roughly the same time that Ed Gran called
me on the phone, and that date I don't remember.

Q Approximately when was it?

A The fall.

Q This fall?

A I imagine so.

Q 1981?

A I believe so. I don't really consider
that of substantial importance.

Q Okay. Was the Vice-President an elected
office for the Arkansas Citizens for Balanced
Education in Origins?

A I nave no idea.

Q You are Vice-President?

A Yes.


Q Were you elected?

A I have no idea. Mr. Gran asked me if I
would be Vice-President and I said, "Sure." What's
wrong with that?

Q There's nothing wrong with it. But it
suggests that it wasn't elective.

A Being elective or not doesn't have anything
to do with it.

Q The point of the questioning and the
answers is not for you to define the importance of it
but to answer the question.

A Fine. I said I didn't know.

Q Why did you want to be an intervenor in this

A Now, if you mean by intervenor, a party
to defend the Arkansas law -- is that what you mean?

Q Okay.

A It's something that I believe in very

Q How does it come that a nonresident of
Arkansas is the Vice-President of the Arkansas Citizens
for Balanced Education and Origins?

A You have to ask Gran that. I am not
aware that there is a geographical limitation on
whether I can become an officer in an out-of-the-state



Q Are you aware of other members of this
organization who are not from Arkansas?

A No.

Q You went on to say in Paragraph 4: "I
am an evolutionist and I believe strongly in public
schools teaching both Creation Science and Evolution

"I personally believe that Evolution
Science possesses more experimental strengths, and
in the origin of life area I believe that the initial
life forms evolved by the various mechanisms offered
by Oparin and Fox.

MR. CHILDS: Could you spell that.

MR. KLASFELD: O-p-a-r-i-n.

MR. CHILDS: And Fox?


Q (By Mr. Klasfeld) Earlier you testified
about the lack of time on earth for life to evolve
from nonlife. What are the opinions of Mr. Oparin
and Fox about that?

A As far as I know, Oparin -- since he is
an atheist -- would certainly not accept the idea
of any type of Creation Science.

Q That's not my question.


A As far as I know, Oparin and Fox are
evolutionists. And considering the writings of both
men in the general field of molecular evolution, they
are molecular evolutionists.

Q You previously testified that there wasn't
sufficient time.

A That's my opinion. And Fox disagreed
with me.

Q They disagreed with you?

A I would guess so. I haven't asked them

Q Well, in this document that says: "I
believe that the initial life forms evolved by the
various mechanisms offered by Oparin and Fox."

A If you are asking me how I could make that
statement and also assert there wasn't enough time --

Q That's right.

A All right. What I am trying to say is
that those proposals of Oparin and Fox and other
people in that general field of inquiry, those things,
I think, were the kinds of things that had to go on.
They will represent our best understanding or best
hypothetical guess today on what went on.

But the thing is it might have required
more time to carry out those kinetic activities than


Oparin and Fox thought it was necessary.

You could put it this way: I could say,
for example, that the number of people that are
involved in automobile accidents is a certain number,
let's say, in the State of South Carolina. Then we
could, perhaps, argue about whether or not a sufficient
amount of traffic would be sufficient to greet those
accidents or whether more traffic would be needed to
greet those accidents.

The mechanisms would, perhaps, be the
same; the time frame in which they took place would
be different.

Q How do you believe life came into being
on this planet?

A I think there is a very strong possibility
that this planet was seated for extra terrestrial

Q When would that have occurred?

A My guess would be roughly within that
two billion year time period that I said was insufficient
to produce the first replicating cells.

Q Do you believe in unidentified flying

A What do you mean do I believe in them?

Q Do you believe they exist?


A Yes.

Q Have you ever seen them?

A Probably not.

Q Have you spoken to anyone who has ever
seen them?

A Not to my knowledge.

Q What is the basis for your belief that
they exist?

A Things that I read.

Q By whom?

A Eminently a man called Hynek.

Q Would you spell that?

A I believe it is H-y-n-e-k or H-y-e-k.
And there is a rather pretty good French astronomer,
Jacque Vallee, V-a-l-l-e-e. Those are two people
that have been quite convincing.

- - -


Q Is this belief of yours about the origin of
life here similar to that expressed by Francis Creek, I
think the name of -- the name is directed to Panspermi?

A Panspermiogenesis was advised by Arrhenius
quite a few years ago, I guess around 1925, and Creek
is a more contemporary exponent of the idea, so there
are several different possibilities.

Q But that's your notion of how the life began
on the planet?

A That's, I think -- let's just say I favor
that. My feeling is that that is perhaps the simplest
way to explain how life was able to become so organized
in the time available.

Q And this all happened about how long ago?

A Well, somewhere between the time the Earth
formed and probably the time we note the first fossil
bacteria, although there's no absolute requirement for
that, if this planed had been seeded. It could have
been seeded later. We could have had a whole series of

Q Is there evidence for more than one seeding?

A I'm not aware of it. This is rather hypothe-

Q But you are satisfied that the evidence for
-- for that is better than, stronger than the evidence


for life having evolved on the planet on its own?

A Let's just say that I find it rather more
interesting and probably, you know, it's more -- there
seems to be -- there's more fruitful opportunities to
answer the insufficiency, the statistical insufficiency
by going to extraterrestrial sources.

Q I guess I just don't understand at all why
you mentioned Oparin and Fox in your --

A Because Oparin and Fox have proposed a model
that involves relatively simple chemical species becoming
increasingly more complex, until the polymerian mole-
cules of characterized living things appear, and pre-
sumably by some kind of selective and --

Q You don't believe that happened, do you?

A I think it may very well have happened, but
I don't think they allow those processes to occur.

Q And how long do they --

A There's a kinetic difference something can
take place, but it may not take place fast enough for
a certain type of connection to occur.

Q And how long do they --

A There's a kinetic difference that something
can take place, but it may not take place fast enough
for a certain type of connection to occur.

Q Do Oparin and Fox think it took place?


A Well, the last thing I remember reading on it
was that they certainly felt two or three billion years
was plenty of time.

Q What's the difference between a coaceruate
and a proteinoid?

A Well, there are several differences. One has
to do with stability. A coaceruate is by and large,
as I remember it, is much more unstable. A proteinoid
is plenty stable.

Q What is that holds the coaceruate together?

A That, I guess, is rather hypothetical. I
would expect you would be talking about hydrogen bombing,
ionic bombing, etcetera.

Q And the proteinoids?

A Proteinoid, that I can't be certain of. I
would presume that the proteinoid is something equivalent
to a three-dimensional colloid polypeptide. See, what
you do know is this: Typically, Oparin's coaceruate,
as well as I remember it, had a finite lifetime, in
terms of their chemical stability under normal tempera-
tures. You might find in a laboratory, whereas pro-
teinoids, as far as we know, is quite stable. If the
stuff we've made, be it, however, so simple, did not
decompose as far as we could tell by the normal test
we had available to us. But there's other differences,



Typically, Oparin's coaceruates were put
together using molecules are much more complex, whereas
proteinoid started with much more simple molecules.
Oparin would make a coaceruate molecule system, using
his D.N.A. and his tone. These are basically any ionic
polymers. Your thermal proteinoid would be made by
the coaceruates.

Q Okay. How many students are there at Wofford

A Approximately a thousand.

Q Is it a church affiliated institution?

A I would say so in an phenominal sense, yes.

Q What church is that?

A What church? Methodist.

Q Is it accredited by the State of South Carolina?

A Well, I don't know that the State of South
Carolina is in the business of accrediting colleges.
If it is in the business of accrediting colleges, I
would find it difficult that Wofford College was not.
We are a member of something like the Southern Associa-

Q Are you an officer of the Libertarian Party?

A Definitely not.

Q Does the Libertarian Party have offices?


A Probably, but I consider those people stoic.
I think they are Epicureans.

Q What is the difference of an Epicurean and a

A It has to do with whether your philosophy is
based upon personal pleasure or not.

Q And the Libertarians, I guess, is the greater
or the great?

A In my opinion, the Libertarians that I have
typically met are more interested in personal pleasure
than the more important things.

Q What are those more important things?

A First off, honor; secondly, doing what could
be called the right just thing.

Q How does one determine what is the right just

A You figure it out and use your own values.

Q But it's all something one decides for him-

A I would like to think so. I mean, if you are
a Libertarian by any stretch of the imagination, you
should be fundamentally either an objective or either
an agonist, which means you start with what we would
like to call the self.

Q When you say we, will you --


A Well, teaching as a Libertarian, as far as
I'm concerned, what I know best is myself.

Q Do you have any other kinds of teaching posi-
tions or consultant positions, which you are paid at
the present time.

A Not to my knowledge.

Q Since you graduated from North Carolina State,
have you taken any continuing education courses?

A I graduated from the University of North

Q I'm sorry --

A That's not the same place. Have I taken
continuing education courses, what do you mean?

Q Have you taken any other courses -- have you
been a student in any courses since you graduated?

A No. I had quite enough. I was in college
for 20 years. I haven't stopped studying; however, I
now study for my own purposes.

Q Did you receive any honors at North Carolina?

A I'm unaware of any.

Q Have you received any grants during the time
you've been a professor at Wofford College?

A Let's see, the first three summers I was
there, I had three separate summer research grants.

Q Who funded them?


A Let's see, I guess the Federal Government.
Fundamentally, there was something called the C.S.I.P.
Program, and it's something like the College Science
Improvement Program, I think that's what it was called.
So the college had money to fund appropriate research
activity, if your proposals were accepted, and you were
allowed to do this for three straight years, if they
approved your work, and I had three consecutive grants.

Q Did you apply to the college or to the
Federal Government?

A Well, I applied to the college.

Q The college had the money?

A Yes.

Q And then you applied --

A To the Federal Government, and they got it
from the taxpayer.

Q Do you have any philisophical objection to

A Hell, no. There is something I have called
the "Chicken Noodle Concept." Do you want to hear

Q I do.

A The general idea is if a society has decided
to take money from you, then you have a perfect right
to get it back again.

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