Deposition of Dorothy Nelkin
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS - WESTERN DIVISION
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REVEREND BILL McLEAN, et al, :
- against - :
STATE BOARD OF EDUCATION, et al, :
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November 22, 1981
10:30 A. M.
DEPOSITION of DOROTHY NELKIN, taken by the
Defendants, pursuant to stipulation, held at the
Sheraton LaGuardia, 90-10 Grand Central Parkway,
Queens, New York, on November 22, 1981, at 10:30
A.M., before a Notary Public of the State of new
A p p e a r a n c e s :
SKADDEN, ARPS, SLATE, MEAGHER & FLOM, ESQS.
Attorneys for the Plaintiffs
919 Third Avenue
New York, New York 10022
BY: GARY E. CRAWFORD, ESQ.,
STEVE CLARK, ESQ.
Attorney General for the State
of Arkansas, Defendant
Little Rock, Arkansas
BY: DAVID L. WILLIAMS, ESQ.,
Deputy Attorney General
* * *
IT IS HEREBY STIPULATED AND AGREED
by and between the attorneys for the respec-
tive parties hereto that filing and sealing
be and the same are hereby waived.
IT IS FURTHER STIPULATED AND AGREED
that all objections, except as to the form
of the question, shall be reserved to the
time of the trial.
IT IS FURTHER STIPULATED AND AGREED
that the within examination may be signed and
sworn to before any notary public with the
same force and effect as though signed
and sworn to before this Court.
* * *
D O R O T H Y N E L K I N , called
as a witness and having been first duly sworn
by a Notary Public of the State of New York,
was examined and testified as follows:
EXAMINATION BY MR. WILLIAMS:
Q Will you please state your name.
A Dorothy Nelkin.
Q Professor Nelkin, I believe you know we are
here for a deposition this morning in the case of McLean
versus the State Board of Education.
Q I am going to be asking you questions about
your anticipated questions in this case. If I ask any
question you don't understand, please let me know.
Q Have you had your deposition taken before?
Q Have you testified in court before?
Q Are you aware that what you are saying
today will be used in preparation for the trial, and
Mr. Crawford has explained to you the purpose of the
Q Could you please tell me, first of all,
are you married?
Q And what does your husband do?
A He is a professor at Cornell Department of Applied
Q Do you have any children?
A Yes, two daughters.
Q What are their ages?
A 24 and 26.
Q Are they currently in school?
A One of them, yes, is at NYU graduate school.
Q In what?
A Getting her masters in business administration.
Q Where did your two daughters attend under-
graduate school or secondary school?
A Ithaca High School, and my oldest daughter went
to Wesleyan University in Connecticut. My youngest
daughter did not go to college. She is studying drama.
Q Ithaca High School is a public school?
Q To your knowledge, has the subject of ori-
gins been discussed in the classes that they took in
A Well, they took biology classes, so I would pre-
sume there was some discussion.
Q Do you know what text was used in that
A I don't know. It was a long time ago.
Q Do you know if the creation model of origin
was ever mentioned in the class?
A Not that I know of.
Q Do you know whether the evolution of ori-
gins was mentioned?
A I don't know, but I would guess so because I think
that most of the textbooks were presented at that time.
It's not a subject of much discussion -- of any discus-
sion in the house.
Q Are you a member of any organized religious
A Yes. I am Jewish.
Q Are you active --
Q When you say no, could you describe your
inactivity, your own personal belief about the faith?
A I was brought up in a family where there was a
strong cultural identification with being Jewish, but
no particular practice -- no actual religious practice.
Q Do you observe Jewish holidays?
Q What is your personal belief about the
existence of a god?
A I don't know. Again, it's -- religion is not an
important part of my life, so I don't think about it
Q You say you don't know?
A My own particular -- I don't have any strong
belief in God. I guess I don't believe in God.
Q When you say you don't believe in God, would
it be fair to consider yourself an agnostic or atheist?
A I think more of an agnostic. I wouldn't be able
to swear on the bible that there is no God.
Q I think this is a contradiction of terms.
A Exactly. The midpoint is not a part of my life
which I have spent much time on.
Q Do you know what the Jewish faith says
about the origin of the world of man?
A Actually, I have never had an education in the
history of Jewish faith, so I am not sure.
Q Have you ever read any religious books
or religious works on the origin of the world?
A As part of my research, I have been reading a
lot of creationists books. I have been generally in-
terested in trying to understand what they are think-
Q Do you believe that a religious person can
be a competent scientist?
A Well, certainly. I know lots of scientists who
Q I would assume that would apply to social
scientists as well as other types of scientists.
A Of course.
Q Where are you presently employed?
A Cornell University in Ithaca, New York.
Q And your current position there?
A I am a professor in the Department of Sociology
and in an interdisciplinarian program called Science:
Technology and Society with a primary affiliation to
the science STS program.
Q Tell me what the purpose of the science of
A Science: Technology and Society.
Q That is?
A Its purpose is to understand, as a major aspect
of our lives, the interrelationships between science
and society, the impact of science on society, and
Q Is there a purpose for it anywhere in the
A The program exists partly as an educational
unit, people being trained in science and in non-
science of the existence of it, of the so-called two
cultures, and to try to sensitize, for example,
engineering and science students -- for example, some
of their work has social implication, and to try to
increase understanding of the non-science students.
Q Is there a statement of purpose reduced
to writing anywhere?
A Reduced to what?
Q A statement of purpose for the program
reduced to writing?
A Yes. I guess -- yes, we have a report which
states the basis. I could mail it to you.
Q If you would do that, I would appreciate it.
MR. CRAWFORD: We will get that provided
Q Could you describe your own duties in
this program now in some more detail?
A It's teaching and research.
Are you asking what my research --
Q Let's talk about, first of all, your teach-
A I teach basically two courses plus supervise
individual students. One is called the Politics of
Technical Decisions, looking at decisions with respect
to, primarily, technology and the interplay of technical
and political components of that, and looking, in this
case, often on how political and social issues get
translated into technical terms when decisions are
fundamentally political and social, but have a tendency
to become defined as technical.
The other course is called the Social and
Political Studies of Science, and it looks at similar
issues with respect to science in a social component.
Q Do you use a textbook in these courses?
A I use a variety of different readings which have
changed every year.
Q So, there is no one text which is utilized?
A No. There is no one that is constant over
a time. For example, I am using for the spring course
on science a new book by June Goodfield called Science
I am using the book that I wrote, actually,
that you have.
A So, science and religion. But I am looking at
how science becomes used by different social groups.
Q Are you currently on a sabbatical?
A No. I was on sabbatical last academic year until
Q During your sabbatical, you were visiting
associate at the Recourse for the Future in Washington?
A Yes, for five months. And in Paris at the Ecole
Q Could you describe your duties at the
Recourse for the Future?
A I had a research grant. I studied controversies
generally as a methodology to understand a relationship
between science and society, and I had a research
grant there to work on, actually, the antinuclear move-
ment in the United States.
Q And at the Ecole Polytechnique?
A I was there as a guest of the French govern-
ment just to give some seminars and to work with
somebody who is doing work on this assessment. I
lecture in French so I go there very often.
Q According to your curriculum vitae, you
have been a professor since 1977?
A No. I have been a professor since about 18 -- I
have been at Cornell since 1963. I was a certified
research associate until 1972, and then I was asso-
ciate professor in 1973; then I was promoted to full
professor in 1977.
Q How did your duties differ in 1977? It
appears that you were involved with the same program.
A I have been involved with the same program
since 1970. The duties don't differ. What happens is
you get promoted. Duties consist of a mix of teaching
and research and some administration, committees.
Q What courses have you taught besides the
two you mentioned earlier?
A I taught a course for a big undergraduate class
for a long time called the Impact and Control of Tech-
nological Change. Most of the course -- all of the
courses that I have taught have been focused in one
way or another around the same areas.
Sometimes more directed toward under-
graduate; sometimes more directed toward graduate
students. And they differ to the extent to which you
use primary and secondary material, theoretical and
case matter material.
The subject matter is more or less the
same. It is the kind of approach which is a little
more sophisticated for all of the students.
Q Where does the program of Science: Technolo
gy and Society receive its funding from?
A At this point its funding for teaching is in-
house, university funding. Research support primarily
comes from the National Science Foundation. It's had
some funding from Sloane.
Q Sloane is what?
A Sloane Foundation. It's a large private founda-
tion. It's had over the years some funding from Exxon
I have received research support -- it's com
plicated because there is general funds for program
development and there is funds for specific research
projects; then there is a lot of research that goes on
which is not funded, which means that we just operate
off of our faculty salaries.
Q In terms of the outside funding, do you
know approximately what percentage -- just a rough
breakdown -- would be coming from the National Science
A I just don't know that, actually.
Q Would it be the bulk?
A I try to keep my head out of that whole mess. The
initial seed money from the program, I believe, are
five-year grants from NSF, but that money is over.
NSF doesn't give any institutional development funds
Q In 1963 to 1969 you were a research asso-
ciate at the Cornell School of Industrial and Labor
Q Was that a different position and different
A That was a different position. At that time I
was doing a study of migrant farm workers.
Q I notice there is no employment listed on
your curriculum vitae prior to that time other than a
one-year research assistantship?
A This was when I was a student in 1954. I was
child raising and playing a cello.
Q During that time you had no paid employ-
ment during those years?
A Yes, no paid employment.
Q Your degree is from Cornell University?
A Yes, in 1954 a Bachelor's Degree in the Depart-
ment of Philosophy.
Q Do you have any other postgraduate --
A No. I never went to graduate school.
Q Do you know how many other full professors
at Cornell have only a bachelor's degree?
A I don't know how many, but it's not many. It's
an unusual career pattern.
Q I'm curious. Do you feel the lack of a
master's or Ph.D. has hindered your development up
the career ladder to full professor?
A I think if somebody goes that route, they have
to publish a great deal, because generally a Ph.D. is
evidence that one can produce a scholarly work.
And partly because of career patterns of
women and child bearing, by the time you go back to
school you have less patience for classes.
I published a great deal of school litera-
ture in university presses, and that was sufficient to
substitute for the degree.
Q Was it your choice not to get postgrad-
uate education? Was that a conscious choice that you
A No. It was partly circumstantial. We were mov-
ing around the country a fair amount for my husband's
career, and I ended up at Cornell and I happened to
fall into a research job that interested me a great
deal, working for somebody who realized I could do
some writing and independent research, and he gave me
my head and I became substantively involved in a num-
ber of areas, and I moved in the directions I wanted
So it was mostly circumstantial.
Q To your knowledge, did the fact that you
were married to a professor assist you in obtaining
a job at Cornell?
A It's generally an obstacle because there is a
fear of nepotism, a fear of pressure, and so people
bend over backwards to prevent that.
Q The first person you say you worked for
who was open-minded, who was that?
A A man named William Friedland. He was a profes-
sor at the School of Industrial and Labor Relations.
Q How did you meet him?
A I honestly don't remember the details. I think
that I had heard the job was available and just went
up and talked to him -- introduced myself and talked
I think it was in that way, just hearsay
that there was a job available, or maybe it was listed.
I don't know.
Q Where did you graduate from high school?
A Brookline High School in Brookline, Massachusetts
Q What year was that?
A Class of '50. 1950.
Q Where you taking science courses in under-
A In undergraduate school?
Q In secondary school?
A I remember taking a chemistry course and I think
probably a biology course, yes. If you ask me what I
took in the biology course --
Q Do you recall any study of origins at all?
A I really don't.
Q Do you recall any study of evolution at all?
A I just haven't got the faintest idea what I studied
in the 1940's.
Q At your undergraduate school at Cornell --
A I was at Cornell as an undergraduate. I did take
a biology course there. It was an undergraduate survey
course which covered everything.
And, again, I don't remember the details
of what I took. I would presume I must have had some
although I am not sure in the fifties. I really don't
remember what I took in my college course.
Q You say you would not recall now whether
a creation model of origins or an evolution model of
origins was presented?
A I just don't remember. I remember very little in
detail of what I did as a college student.
Q Have you received any training in your field
outside of your formal education, any sort of formalized
A Well, one sits in on seminars and on classes of
colleagues. It's not formalized training, but you
constantly educate yourself and find out what is good
to read. But that's not formal; that's informal.
Q In your work, how have you become familiar
to the extent that you have with science?
A That's a good question because I have no formal
science background. How can I answer that succinctly?
I have never had the feeling that science was something
that a layman could not understand in its broad out-
line and in terms of its methodology.
I obviously cannot do science, but I feel
that I understand how science operates and that's what's
necessary to understand it my work.
Q How does science operate, as you understand
A Well, to put tomes and tomes of volumes into a
succinct -- in a succinct manner, I think the primary,
the most important, characteristic of doing science
is what Robert Merton called organized skepticism.
Where you are, essentially, continually testing hypothe-
ses where you start out with as few apriorius assump-
tions as possible, and I would say that is the pri-
mary characteristic for scientific research.
Q You mentioned the term "sociology of science".
Could you explain to me what the sociology of science is?
A It's a study not so much of science itself, but
of the social institutions and social relationships
that constitute science.
It's a study of the way science operates,
its relationship to the external nonscientific world,
the way science is used by the public.
Q So, is it more of a study of simply the
way it does relate to society than a study of what
A Well, there are really two directions, and
this is necessarily going to be simplistic. There
are two directions in which the sociology of science
has moved. One is called the internalist view; people
who study the internal workings of science, looking
at disciplines, of how it develops historically. It
looks at how ideas get communicated among scientists.
There is what I might call an external-
ist view which focuses on the relationship of science
to society, looking two ways at the bearing of science:
how society influences science and how science is used
and influences social live.
My own specialty is in the latter.
Q When you talk about how science influences
Q -- I take it then that you think that
science does influence society?
A Oh, certainly.
Q Is the converse true, that society influ-
A I think in the broad -- yes, the direction of
science becomes influenced by social needs. Yes.
Q By social needs?
A The directions of science. What gets funded
is not an abstract concept. It's influenced by demands
of society at a given time.
Q In a broader sense, though, do you feel that
society influences science today in the same manner,
though perhaps different in degree, than it did in
the early formative years of science when we had a
geocentric theory of the universe and society was
A I am sorry. I don't know what you mean by in
the same manner.
Q OK. When you define science or classify
science as organized skepticism, is what science is
skeptical about and what perhaps it is not sometimes
skeptical about, is that influenced by society in
the larger sense?
A I think you misinterpret what I meant by the
method of science being organized skepticism. I
think when a scientist does work in his laboratory,
he or she is very careful to continually test ideas,
The one starts with assumptions. One
always has to start with some sort of assumption.
The notion within science is to continually challenge
those assumptions, to try to disprove them, not to
try to prove them.
But in terms of the overall influence of
society on science, I think, for example, our preoc-
cupation with national defense is going to lead to
certain emphasis in certain areas of science in the
next decade that will be somewhat different from an
Q Well, my question concerns the affect of
society on science. Maybe I am not being particularly
articulate and I have a problem trying to talk about
A These issues are difficult.
Q If we look at the history of science, as
I understand it, and I just used probably what would
be the most obvious example of the geocentric theory
of the universe --
Q -- at a time of what science was doing and
the views, prevailing views, sometimes were dictated
by what society wanted more than perhaps just by pure
Do you feel, in your studies now, that
we have gone beyond that where society -- at least in
the research it's doing and -- what I want to call
the purity of the science, that we have a purity of
a science above and beyond the effect of society on it?
A I think it's a very -- the reason I am having
trouble is because the question you are asking is
one of the most profound questions presently being
asked by historians and social scientists, and there
is no easy answer.
You have articulated the question well.
It's just that there are no clear-cut answers. One can
draw upon the history, for example, of genetics and
look at the eugenics movement, which is a part of
science, and how that was influenced by social views,
and how the Nazi period essentially changed those
social views, and that was reflected in the kind of
questions that were asked within science.
In that broad kind of historical framework
there is certainly an interplay between science and
social values, yes.
The more interesting question is almost
the reverse of that, but it is hard to separate it;
namely, the way people in society utilize science in
one way or another and use it as a sort of credibil-
ity for whatever ideas that they have and wish to
Q Who are the leading authorities, in your
mind, on the internal views of the sociology of
A The leading people working in the field?
Q Yes, or who have worked in the field?
A One of the leading social scientists who is now
an old man is Robert Merton, and there is a school of
people that have developed around him a Columbia
University who have been working on the internal
development of science.
Q Any others that come to mind now?
A There is a very interesting young woman in the
University of Pennsylvania, Diana Crane, who is doing
-- who has done some extremely interesting work in
There is a society, a professional society
in the field which has both dimensions represented
called the Society for the Social Studies of Science.
Q Are you a member of that?
A I was president of it and now I am a member.
Q Who are some of the other leading author-
ities in your mind in the relationship of science to
society now, excluding yourself?
A Oh. There is an interesting fellow at Georgia
Tech by the name of Darrel Chubin. There are a lot
of people working -- there is a historian -- by the
way, it's an interdisciplinarian field. It's diffi-
cult to separate the disciplines.
There is a historian at Harvard by the name
of Everett Mendelson. There is a whole number of people
in a program called Science: Technology and Society at
Q Are you familiar with Thomas Kuhn?
A Of course I am. Who isn't?
Q Are you familiar with his book, The Struc-
ture of Science of Revolutions?
Q What is your opinion of that work?
A I think it has a great deal of cogency. It's
been very useful.
Q Where is he now?
A He is now at MIT, jointly in the Department of
History -- I don't know the academic structure. In
this STS program. I think in the Department of History
Q Do you consider him to be in this area
of sociology science?
A Well, he is more historian, yes, bridging it.
Q You said earlier that part of the idea of
science, the notion is to continually challenge the
Q Doesn't Kuhn's work cause paradigm --
doesn't it in a sense run against that theory?
A In a sense. You are talking about different
levels of work, different scales of work. In the over-
all functioning of a field there are given trends
which begin to dominate and, as in every other field,
law included, there is a power structure which tends
It takes a fair amount of work to com-
pletely overthrow a given line, overall line of thought,
but lines of thought do change in science and that was
the substance of his book. That was the essence of
his book, that you can have completely revolutionary
changes in the perspective of science.
On a more microlevel, scientific research
is changing, I think, to get more to the point of what
we are talking about, the disagreement within evolu-
tion theory. The disagreements are wonderful evidence
of how people keep challenging the nature of what
they are doing.
It doesn't mean they necessarily question
the whole entire framework, but they do continually
challenge internal difficulties in the field.
Q But even that fit into his notion of
paradigm, does it not, because they are trying to now
change the model to fit the data, because the data to
some people does not appear to fit the pre-existing
A It depends on what level you are calling para-
digm. If you are calling paradigm to be the whole
basic concept of evolution change, I don't think
that's what Kuhn was implying.
Q What is sometimes called the synthesis
theory of evolution, modern synthesis? Some of the
groups appear to be challenging that.
A The problem I have with your question is that
I am not a scientist. I prefer -- when it comes down
to the details of scientific debates going on in the
field, I cannot talk intelligently about them at the
One learns very quickly in the inter-
disciplinary field when one should open one's mouth and
when one should keep quiet.
Q I am not sure I can talk about it intelli-
A But I think there are other people you can talk
to about that.
MR. CRAWFORD: Off the record.
(Discussion off the record.)
Q Do you have any idea, personally, of what,
if any, assumptions underlie the general evolutionary
A Of what assumption underlie --
Q The general evolutionary theory?
A Yes. Certain assumptions regarding change under-
Q Could you be more specific?
A As I understand it, evolution theory has been
very, very widely accepted among scientists because
it's a very useful explanatory hypothesis that an
awful lot of things become clarified, and that's the
nature of a valid scientific theory.
One of the interesting things that I found
in my own research in this is the discrepancy between
how scientists understand science and how the public
understands science, and the public tends to under-
stand science as an inductive science, as an accumula-
tion of facts.
Science does understand it in terms of
a useful hypothesis, not in terms of truth, but in
terms of evidence to get closer and closer approxima-
tions to reality.
Q I think my questions was, though, what
assumptions underlie general evolutionary theory? You
had assumptions about change, can you be more specific?
A I guess I am having trouble understanding your
Q I just want to know if you have made any
personal study or done any reading on what, if any,
assumptions underlie general evolutionary theory.
MR. CRAWFORD: Could you be more specific
about what you mean by assumptions? You mean
factual assumptions, theoretical assumptions
or natural or supernatural?
MR. WILLIAMS: Well, earlier Professor
Nelkin stated that the primary characteristics
of science is organized skepticism and that
science approaches this work with as few
apriorty considerations as possible.
THE WITNESS: Yes.
MR. WILLIAMS: And I am wondering if we
could call those assumptions.
Q Have you made any study of how many, if any
apriorty considerations or assumptions are involved in
the evolutionary theory?
A I guess my answer, which I thought had answered
that essentially, was that the scientific assumptions
are based on observation and then the attempt to
develop hypotheses out of those observations.
I think we are on different tracks because
I am arguing that there are really no fundamental
apriorty assumptions such as the existence of a god,
but there are hypotheses that are built up from obser-
vations, and then which become tested. Changes of
Q Well, maybe -- you say we are on differ-
ent tracks. I am really curious as to whether you
have made any personal study of what those assumptions
A I have not done any studies in the history of
evolution theory, history of the development of evolu-
tion theory. I am not a historian.
Q For example, do you know whether there
is an assumption in the general evolution theory that
life emerged from nonlife?
A I guess there is an assumption that life did
emerge at some point from nonlife.
Q Is there an assumption, to your knowledge,
of how often life -- how many times life emerged from
A I don't know.
Q Have you relied on your husband any in
the gleaning, or in trying to understand the way science
A Oh, sure. I am sure we talk a lot. I think I
have some understanding the way science operates --
not necessarily talking, but through observing how
We have been married 30 years. I think
one must observe some sense of working style.
Q Some of the work that you have done in
the study of Creation Science, have you ever discussed
that with him?
A Yes, we talk about our work.
Q I think, as a matter of fact, you acknowl-
edge in your book that he perhaps provided some
A Yes. He reads a lot of my material and he
criticizes some of it.
Q Do you know what his personal opinion is
with Creation Science?
Q What would that be?
A More or less the same as mine, yes.
Q We will get to yours in a moment.
A I figured you would. But just to avoid redundancy
and save time.
Q What is the Advisory Group to the Regional
Seminar Program of the American Academy for the Advance-
ment of Science?
A American Association.
Q American Association. Excuse me.
A I have been on a number of committees for that.
Q This was the Advisory Group to the Regional
Seminar Program called Science and the Public.
A There has been a couple of things: One is doing
some relationship between science and the public. My
present commitment there is a committee on the AAA
Scientific Freedom from Responsibility.
Q What is the charge of that committee?
A It deals with human rights issues. It deals
with such questions as science as an intellectual
property at this point, considering questions such as
Freedom of Information Act in its application to
science, the cryptography dispute, problems of patent-
ing of science.
A lot of it deals with whistle-blowing
issues, scientist who blow the whistle who think there
are some problems going on in the agency, and also
international human issues.
Q In 1977 up to the present you have served
on the AAA subcommittee science of textbook?
A Yes. That is sort of a defunct committee. That
is part of that committee which is concerned about the
creation of evolution controversy.
Q Why is the committee now defunct?
A It's not defunct. It's just been fairly inactive.
They haven't been doing anything with the committee.
The AAA is running an all-day panel at its January
Q Do you have a personal code of conduct?
A A personal code of conduct?
A When you say code, it sounds very formal, a
kind of formalized code of conduct. There is no plaque
on my wall.
You mean, do I have ethical principles?
Q Would you make decisions, ethical or other-
wise, by which you would -- your own guide or code for
your own conduct with the --
A Not very clearly articulated, but I guess: That
one is neighborly, one shares, one tries to behave
towards other people as he would like them to behave
toward you; that one takes good care of one's children,
and other kinds of normal, reasonable relationships.
Q Do you belong to any organization, any
ethical societies or any other formal or informal con-
A No. All my affiliations -- I am not a joiner,
generally. All my affiliations tend to be professional
I am a Fellow of the Hastings Center on
Biomedical Research which deals with a lot of ethical
issues in biomedical areas, but these are all profes-
Q Do you belong to any society or groups
besides the professional ones that you have listed
on your curriculum?
Q Is there any one book that you can think
of now or any one writer in terms of your own personal
code of conduct, such as it is defined, that would be
most similar to your own, any philosophy?
A I can't think of any. I feel that codes of
professional conduct are rather personal family-derived
Q What's the Advisory Council of the Society
for History of Technology?
A This is a society -- it's called SHOT. That's
a History of Technology Association, and it's an ad-
visory council to the organization.
And what one does is essentially to peer-
review articles for their journal. You know, all these
organizations have advisory councils. Some of them are
substantive and some of them are just to get names on
Q Have you had any duties on this advisory
A This particular one I have reviewed a couple of
articles on, but it's not been a very active one.
Q What about the Office of Technology
Assessment Advisory Panel on Public Participation?
A Do you know what OTA is?
Q No, I don't.
A That's an arm of the U. S. Congress which looks
at the impact and tries to develop some means of pre-
dicting the impact of new technology. And the public
participation panel was a subgroup of that which looked
at the role of the public in assessing the impact of
OTA reports to the Congress directly.
Q Have you written any reports for this
A This particular advisory group, no.
Q Have you done any writings in this area?
A In public?
Q On this particular advisory group?
A No. I have done no writing for that advisory
group. We met and discussed the issues.
Q Again, what is the Hastings Institute of
Society Ethics and Life Science?
A That is a group in Hastings-on-Hudson which
focuses on biomedical research in medical practices
and looks at the ethical issues that are involved,
some of the problems of professionalism.
There are lots of ethical questions
that come up in the Right to Die cases. At this point
I am involved in an occupational health project. They
run workshops and meetings to discuss questions of
freedom of choice, ethical questions and sociological
questions and historical questions around biological
research and clinical practice.
Q I take it from your comment that those
questions are not questions purely of science?
Q In those types of questions that you are
dealing with, what is the conceptual framework that
you bring to those sorts of questions as to what
role science plays, ethics plays, society in general
A Well, I tent to examine these issues in the
light of the social relationships and power relation-
For example, in a doctor-patient relation-
ship there are lots of ethical questions which arise,
but I think they cannot be properly understood
without an appropriate understanding of the power
relationships that go on between the doctor and the
patient, or the economic relationships that are
involved in doctor-patient and whether there is
third-party insurance in this kind of issue.
So, my own framework is always within
a sociological context. Philosophers or historians
would have another approach.
Q Could you give me a thumbnail sketch of
what is sociology?
A The study of social behavior, social relationship
It views a person not in a psychological framework,
but in excess of social relationships.
Q Is it one of the social sciences, or is
A It's one of the social sciences. Economics,
political science, sociology are all defined as social
Q Is sociology an objective science?
A That's a very difficult question. It makes
efforts to be an honest science. I have problems with
the concept of complete objectivity, no matter what
group you are talking to.
Q That would be true, I suppose, of science
in areas of biology as well, would it not?
Q As a sociologist, when you begin to study
an area, what role, if any, do your own personal
A They play an important role in leading me to
select what problems I want to study primarily.
Q And after you have selected this, what
you want to study --
A What I want to do is understand what is going on
in that particular -- for example, I have no temptation
to really do a sociology of the law. I think it also
influences one's methodology.
I tend to study controversies as a methodol-
ogy. I think it's an interesting way to go about it.
Personal preferences enter into the area that you
move into. Once you move into that area, one tries
to understand what's going on.
One does not enter into a research area
in order to get at any body or to prove one side right
or wrong. One really tries to understand the dynamics
of what is going on.
In that sense, it is an objective science.
Q Do you feel when you begin an examination
of the Creation Science that you entered it with an
objective open mind?
A Yes. The question that interested me is why
creationism -- I mean, here you had a social movement
beginning to develop, one that had been very latent
since the Scopes trial, and I wanted to find out -- it
all of a sudden began to revive at this time and what
creationists wanted, what they were after, and I wanted
to understand something about how biologists reacted
I was not interested in either denigrating
one side or the other. I was interested in, again,
the social context in which these groups begin to
develop and to conflict.
Q At what point did you decide that the
creational science movement was a social movement?
A That gets into a complicated discussion to
define that. I decided it was a social movement be-
cause of the wide dissemination of -- when you had
different groups beginning to find what they were
saying salient for one reason or another.
And I'm not sure it's appropriate to call
it a social movement or a religious movement. But it
began to be an increasingly important social phenomena,
and my judgment of that came because it began to have
influence in local textbook committees.
My question is: What is it that they were
saying that became important?
Q Is there a difference between a social
movement and a social phenomena?
A Yes, sure.
As I mentioned, a source of great dispute
what a social movement is and how you define it; whether
something is a social movement or religious movement
or protest movement. All these words are being ban-
died about and there is no agreement as to what should
be defined as what.
Q If something is a social movement, does
that necessarily mean that it is not a scientific
A I wouldn't equate --
Q Does it necessarily mean that it is not,
A Yes, a social movement is not a scientific move-
Q So, they are mutually exclusive in your
A I am trying to think if I can think of scientific
movements. Yes, I think they are mutually exclusive.
They are categories that you wouldn't tend to put
together, which is why I am having trouble with the
Q You said, as an example, it was a move-
ment when evolution science was first sensitized by
Darwin and its impact on society, if any. It cer-
tainly would appear to be a scientific movement. Was
it also a social movement?
A No, I would not define that as a social move-
ment. Social movements usually develop in organized
protest against something.
Q You served on the editorial boards --
A Of umpteen journals.
Q -- seven journals, according to your
A Yes. I think one of those is now obsolete. The
Q In any of those journals, have you ever
reviewed any article on Creation Science?
A No. There are not many on that. I have been
reviewing other issues.
Q Are you a member of the American Association
for the Advance of Science?
Q Are you a member of any other science organ-
A Yes. The Society for the Social Studies of
Q Any others?
A I guess by being on the board of advisors I
am a member of the Society for the History of Technology.
I don't go to the meetings.
Q Has the AAA taken an informal position on
the subject of Creation Science?
A I don't know whether it has recently. I think
during the early -- there are certainly petitions that
came out during the early seventies.
Q Has it during this year?
A I will tell you better in January because the
National Academy just came out with a deposition ask-
ing for a position to come out, and it hasn't come out
Q When has the National Academy come out
A Didn't they about three weeks ago come out with
a sort of statement?
Q I am asking you?
A I don't know.
Q Do you have a copy of it?
A No, I haven't been keeping accurate in the last
year or two with the details that's been happening.
I sometimes read in the papers what is going on. I
am not keeping up with the details of the contro-
Q So, in the last three years you have not
been really keeping up with the details?
A I have been doing other research.
Q In the last two or three years, where has
your research been concentrated?
A I've generally kept to the areas of looking at
controversies of a science and technology, but I did
a book on European antinuclear movement in comparison
to France and Germany, some work on the American anti-
nuclear movement, and I presently have a study on
occupational health among chemical workers.
Q Other than your consultant role to the
ACLU in this lawsuit, have you had any consultant work
which involved the area of Creation Science?
Q When were you first contacted by the ACLU
about having a role as a consultant in this lawsuit?
A It's not a consultant role as I see it because
I am not paid. It's an expert witness role, and I think
I was contacted about three weeks ago. I don't remember
MR. CRAWFORD: Off the record.
(Discussion off the record.)
A To my best recollection, about four weeks ago.
Q About October 20, somewhere around there?
Sometime in the middle of October?
A Toward the end of October, I believe.
MR. CRAWFORD: I will volunteer for
the record that I believe the first contact,
Mr. Williams, was earlier than that. And
the contact was with the lawyers in Skadden,
A The only contact I have had has been through
Skadden, Arps. But this time of the year, the semes-
ter flies by so fast it's hard to keep track.
Q Have you provided the attorney for the
plaintiffs in this lawsuit any reports?
A I have responded to their questions with letters.
Q Do you have those letters with you?
A No, I don't. I think my attorney does.
MR. CRAWFORD: Mr. Williams, I do have
those. Our position is that that is part of
our work product because that was in response
to specific questions and requests from us for
specific information and, therefore, demon-
strate our thought process in our view of
the case and so forth. We have produced
public writings which express our opinions
which will be presented at the trial.
Q Let me pursue that for just a moment.
Your writings which you have given to
A I have given all of the stuff that I have writ-
ten on creation.
Q The publications. I am talking about other
correspondence that you might have had with them. Have
you prepared an outline of your anticipated testimony?
A What I have done is prepared a -- I was asked
a bunch of specific questions and I responded with a
kind of outline in specific response to the kinds of
questions that they had asked me.
Q Have you been given any instructions as
to your testimony?
A I was told to be prepared for actually
very much the kind of questions that you have asked
me about, my values and this kind of thing, and then
to answer directly and honestly, and to say no and I
don't know about the nature of the instructions, and
to go to the Camelot Inn.
Now it's the Simon Peck Hotel -- whatever,
but I was instructed. The effects of the instruction
were to answer directly and to make sure and not an-
swer if I don't know the answer.
Q Besides that, have you received any in-
structions as to the substance about which they would
like for you to testify?
A No. You mean in terms of how I should answer?
Q Not how you should answer, but the areas
which you would be covering.
A No. I made it very, very clear that I would not
I think they agreed with me. I made it very, very
clear that I would not testify on anything having to
do with science because I could not do that, and that
I would limit myself to the areas I felt where I
honestly could contribute something and avoid issue
areas that I don't know anything about. And they were
thoroughly supportive of that.
MR. WILLIAMS: Mr. Crawford, at this time
I would request that I receive copies of those
writings that Professor Nelkin may have pro-
vided to you to the extent that they are
preliminary reports of her testimony or contain
the substance of her testimony. I think
that as an expert witness we are entitled
to discovery that material.
MR. CRAWFORD: I will take the request
under advisement, Mr. Williams. It's my pres-
ent inclination that that is protected by
the attorney-client privilege. There has
been some time since I reviewed them. I will
consider seriously your request.
MR. WILLIAMS: Can you review those
during this deposition if we took a break?
MR. CRAWFORD: I may be able to do that.
I am not certain I have them with me.
Q Do you presently know what opinions you
will give during your testimony?
A More or less what I talked to you about today.
I have been promised -- since I have not been doing
research in the last two years, I have been told that
I would be given some update material on Creation Science
to try to bone me up a bit.
To the best of my knowledge, not too much
has changed -- to the limited extent that I have kept
up with it, not too much has changed that would change
MR. CRAWFORD: I would state for the
record, Mr. Williams, that she has expressed
an interest in viewing recent creationists
material, and that we have agreed to provide
her material from the various documents pro-
duced from the creationists groups and docu-
ments we may have collected, such as Acts and
Facts from the Institution of Creation Research.
And we have asked her to look at the
material and in her professional judgment re-
view whatever she thinks is important to review.
We just ask her to exercise her independent
judgment as to what she had to look at.
MR. WILLIAMS: Thank you.
Q How many years has it been since you spent
some extended amount of time in the area of Creation
A I concentrated my research in 1976 to 1977. I
have not done any intensive research on the creation-
ists, on the controversy since then. However, when
one does a project like that, one tends to be inter-
ested in it; and even though one is concentrating one's
attention elsewhere, one tries to continually test one's
thought before to see whether it's held up or whether
one is to be embarrassed about one wrote before.
So you tend to keep up to a limited ex-
tent but not in great factual details. It's impossible
Q Since 1977 approximately how much of your
time has been devoted to studying this issue?
A Rather little. I don't know what percentage.
Very ad hoc. Occasionally I get Acts and Facts in the
mail; I pick up creation literature and I look and
see what people are saying.
Q Other than the sort of ad hoc occasional
reference that you would run across?
A I have not done a systematic work, any systematic
work since then. The lawyers have sent me some copies
of creationists writings recently, and I have been
looking at those. I have not been doing research
in the area since '77.
Q What writings have you been sent?
A Some work by Parker, some work by Gish. These
are the texts.
Q Do you know the names of those?
A No, I don't recall the names.
Q Do you recall what your opinions were of
those when you read them, or have you read them?
A I have scanned them. I haven't read them all.
There is a lot. I was struck by the
mix of scientific and religious references.
Q Which ones?
A I have always been struck by the religious
statements of the creationists and their concern with
documenting the inerrancy of the Bible. To somebody
who is doing work in this area, that's the most
interesting aspect, to me, of their work.
Q Any particular one that you recall had
A There were some interesting things in Parker's --
Q Do you know what his first name is? Is
it Gary Parker?
A I think it's Gary Parker -- who continually talks
about how the meaning of creation theory and his per-
sonal religious life; a lot of work by Henry Morris is
filled with religious references, the inerrancy of
The other thing that strikes me as very
interesting in there is the extent to which they are
concerned with using science as a way to deal with
their moral concerns and their religious concerns.
Q The documents that you have here, and
that I have received from Mr. Crawford, does this