Deposition of Nalin Chandra Wickramasinghe

NO. LR-C-81-322

REVEREND WILLIAM McLEAN, *
et al. *
*
Plaintiffs * UNITED STATES DISTRICT
*
VS. * COURT, EASTERN DISTRICT
*
BOARD OF EDUCATION OF THE * OF ARKANSAS, WESTERN
STATE OF ARKANSAS, et al. *
Defendants * DIVISION
*
* * * * * * * * * * * * * * * * * * * * * * * * * * * * *

ORAL DEPOSITION OF DR. WICKRAMASINGHE

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

APPEARANCES:

MR. DAVID KLASFELD, Esq., Skadden,
Arps, Slate, Meagher & Flom,
919 Third Avenue, New York,
New York 10022
For the Plaintiffs

MR. STEVE CLARK, Attorney General,
MR. RICK CAMPBELL, Assistant Attorney
General,
MR. DAVID WILLIAMS, Assistant Attorney
General, State of Arkansas, Justice
Building, Little Rock, Arkansas
72202
For the Defendants

ALSO APPEARING:

DR. PHILLIS GARNET, U of A, LR
Dr. Lawrence Coleman U.A.L.R.
Dr. Eric Holtzman, Columbia University
DR. JOEL CRACRAFT, U of Illinois
MR. ALAN ROSS, SASMF
* * * * * * * * * * * * * * * * * * * * * * * * * * * * *
ANSWERS AND DEPOSITION OF DR. WICKRAMSAINGHE, a
witness produced on behalf of the Plaintiffs, taken in
the above styled and numbered cause on the 15th of December,
1981 before Laura D. Bushman, Notary Public in and for
Pulaski County, Arkansas at the office of Mr. Cearly,
1014 West Third, Little Rock, Arkansas at 7:40 p.m.

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DR. NANIN CHANDRA WICKRAMASINGHE

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:

DIRECT EXAMINIATION

BY MR. KLASFELD:

Q. Dr. Wickramasinghe, is that the correct pronunciation?

A. Uh, Wickramasinghe, right. Hard G. It just has
a certain phonetic --

Q. Hard G. Okay. Could you tell me as best you can,
what the testimony that you expect to give tomorrow will
be?

A. I think I would like to lead the Court through a
series of arguments, beginning with the evidence that I
had to be fairly decisive that there is organic matter in
the dust clouds of space; then to proceed to argue about
the composition of the organic material. I am referring
now to the organic material in the gas place; then to show
that the most sensible, and the most -- in my opinion the
inevitable explanation for the dust -- for the data that
one gets related to dust. The organic material have to be
of a -- in a particular form of particular sizes, pretty
uniform throughout the galaxy and also pretty uniform
throughout the other galaxies outside of our own galaxy
wherever it's been possible to measure the effects of the

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dust. And I would like to discuss certain observations
of infrared sources of radiation in our galaxy, which
show certain pattern of absorption. And it's been
something like two or three years -- more than that --
four years now that we've been trying to separate -- her
and I have been trying to examine the behavior of the
spectra to try to understand them in terms of particular --
certain moderates of the dust. And I would argue that the
microbial model -- microorganism model of the dust is not
only consistent with the data, it seems to be quite
reasonably definite identification for the dust in space.

I've brought a couple of slides
that I have or displays to point to correspondence between
a microbial microorganism model of the dust and a set of
astronomic observations relating to the dimming of
starlight, and also to the infrared -- the infrared
properties of one source at the center of our galaxies,
which shows an extremely close correspondence with the
behavior of desiccated bacteria that has been studied in
the lab, under conditions that we think are similar to
what would operate in the interstellar medium.

Q. Uh-huh.

A. So these are two -- the observation and data that I
want to confine my attention to mainly, and the astronomic
observations; and then to discuss various areas in which

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such microorganisms could be propagated to enhance numbers
in interstellar material in the galaxy.

And I suppose the next think
I would like to say is that if one looks at the conventional
wisdom of the origin of life on the earth -- I'm not referring
to the creation theory. The conventional beliefs that
scientists have heard about -- that there are major
difficulties in understanding how simpliest elementary
life forms could get together from conditions that might
have been relevant to the idea. And I also wanted -- I
think among other things I want to point out that the
polymerization of amino acids in the oceans is --

Q. P-o-l-y-m-e-r-i-z-a-t-i-o-n.

A. The stringing together of amino acids, which has
almost been taken for granted in the arguments for
chemical evolution. This process presents very serious
problems for -- to understand how it could happen on the
earth.

Q. Let me just interrupt you for a second. When the
court reporter doesn't understand a word, she doesn't
want you to explain it. She just wants to get the word
down accurately.

A. Okay, fine. Then I guess I suppose -- I -- I --
I probably should bring something else with me in there
because I think I've got a series of logical arguments

5

that I want to follow through. And I guess at some stage
I would like to bring up the business of spontaneous
generation of life and the -- the old concept of spontaneous
generation. This -- if -- if I'm to demolish by Pasteur --
by the experiments of Pasteur was -- this -- this doctrine
or theory recovered despite Pasteur's declaration that
it received a mortal (sic.) blow in his famous address
to the French Academy -- in some form it's recovered and
dominated science from oparin --

REPORTER: From what?

Q. O-p-a-r-i-n.

A. Then I think I would like to go through the geologic
record and point out that the Pasteur doctrine of life,
being generated from life appears to be maintained right
through the fossil record. We don't really know how the
different connections have come into being. But there is
a logical hierarchic logical connection between person's
life (sic.) and fossils on the earth. And you can take
it all the way back to a certain point in the earth's
history. This point that we can take it back up to life
generated -- life to life. This, in my opinion, stops
at about 3.83 billion years before the present time.

This was the time when the
earth's -- in my view and the view of Sir Fred Hoyle when
the earth's oceans were laid --

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Q. Excuse me. In the view of you and who, Sir Fred
Hoyle?

A. Yes.

Q. I just wanted to be sure the name was understood.

A. I mentioned it but it is not consensus view. The
earth's oceans and atmosphere seems to be laid at about
that time. The earliest sedimentary processes started
also at 3.83 billion years. And I think at that precise
time there's also evidence for microbic fossils on the
earth. The oldest fossils came to be. There's been
some argument about the identity of these fossils, but
3.83 is a reasonable time to -- to -- for dating the
earliest appearance of life as one can see in the rocks.

And I think the next point I
want to make is the -- if you take the resection (sic.)
of spontaneous generation to its logical conclusion, then
the time before 3.83 on the earth has to be linked to a
source of information about life. One could either say
that life appeared in a random shuffling operation and
appeared in the primordial mix. Or if it didn't happen
that way, when it had to be injected from outside.

And I think I would briefly
discuss my views and views that I share with Sir Fred
Hoyle about how the injection of biologic material might
have taken place at 3.83 billion years before the present

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time. And also show how this process might still continue
to the present day.

Then I suppose at that point I
also want to bring up an issue that isn't too well known
to science at the moment. However, there is a colleague
who came to Cardiff quite a few weeks ago --

Q. Cardiff, C-a-r-d-i-f-f.

A. -- and spoke about some of his recent work on the
Merchison meteorite. The evidence that he showed me and
an audience who came and heard it was that there appears
to be a very very strong case for microbic fossils in the
Merchison meteorite. Both chemical evidence and morphological
evidence and I want to discuss that very briefly.

So if it is the case that one
has life on the earth and one has life on -- appears on
a meteorite, then the question of independent origins is
to be asked. Is it likely that there were two origins,
one on the earth and one on the meteorites. And if there
are such two origins, could they have converged to
produce the same type of structures?

So I suppose I think I would
like to take off from that to argue that -- are the
matters of the probabilities of the appearance of first
life in the universe. And go on from there to say that
where ever it happened that there seems to be -- first of

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all, there seems to be a difficulty in understanding the
acquisition of information that is relevant to life.
There's an information content in life that is very specific
relating to enzymes and so on. And could this -- one
could pose the question could this information have been
derived in a chemical evolutionary sense or has it got
any deeper significance? The massive quantity of
information.

I think that sort of summarizes
what I would like to....

Q. It was an awesome job. Okay. Why don't we start
with the astronomical observation. What is it you would
expect to say about the organic matter found in dust
clouds?

A. That it has to be of a rather complicated polymery
character. That the --

Q. Complicated?

A. Polymer character. Simple organic vertical molecules
and so on, that these together would not account for the
data.

Q. What is the data that it wouldn't account for?

A. Absorption properties of infrared wave lengths.

Q. Why wouldn't it account for that?

A. Because it doesn't. We've attempted to compare --

Q. What is there about the absorption qualities?

9

A. Un, it's a -- this is just one example of it. There's
a -- it's a very detailed profile of transmittance and
plus the wave lengths are very involved --

Q. Well, perhaps if you could explain what the dots
represent.

A. Dots represent the astronomical data for the flux,
radiation comes from a source that is called JCR located
at the center of our galaxy. And the reason for choosing
this amongst several of our other sources is that this
particular source is a sort ten kiloparsecs away. And
it samples a long parcel length of interstellar material.
He is very flat -- I don't know. Maybe I shouldn't really
go into technical issues but you can see it has a flat
background here.

Q. I simply want to understand what you're going to
testify about tomorrow. If you're going to testify in
this kind of detail, I'd like to know about that tonight.
If you're not going to --

A. No, I think not. I think I'll make a general
statement in that it is my belief from long experience
in trying to fit these curves in astronomical context that
it is very difficult to get an agreement between the date
and a model unless one postulates something very complex
and very specific in a very specific manner.

Q. Have you examined this matter with other wave lengths

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other than infrared? Have you examined it with ultraviolet?

A. Yeah, yeah.

Q. What is the result with ultraviolet?

A. The results -- the overall ultraviolet behavior of
the dots is represented by the dots here.

Q. I guess if you could explain what the longitude and
latitude measure.

A. On the X axes is the inverse of the wave length and
on the Y axes is sort of the dimming of starlight. I don't
know -- I think this is pointless to bring very technical
arguments into a courtroom.. But it's my opinion, having
attempted to match this data, this models for nearly
two decades or so, this is -- the (inaudible. Sounds like
"masterphone") gets really almost with the first shot
of trying to match the microbial model -- microorganism
model has to mean something. In my view it means --

Q. I guess I just don't begin to understand what it is
you're observing. What the dots measure.

A. The dots measure the --

Q. Let me start over this way. What kind of machinery
are you using?

A. The machinery involved in making the observation?

Q. Yeah.

A. Okay. Telescopes. Telescopes mounted on satellites
and on the surface of the earth

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Q. And you're looking at one star or a lot of stars?

A. This is, in fact, the average for lots of stars, yeah.
For maybe five hundred or thousands of stars.

Q. And what does each dot represent?

A. Each dot represents a particular wavelength point
and averaged over the last number of stars. But in fact,
as it turns out, if I were to clock the variation from
one star to another, the variation is not particularly
great except maybe in the ultraviolet wavelengths. in
this particular wavelength, for instance, see the points
sort of hug that curve rather closely where ever you look
at it in the galaxy.

Q. And each of those dots represents a sighting of
different groups of stars or the same group of stars?

A. Each dot is the -- represents the -- on some kind of
anomalized -- some kind of scale here the fogging of or
dimming of starlight a logarithmic scale.

Q. And is that the same thing in the infrared --

A. Infrared represents the -- it represents absorption
below. It's not the same thing. It's the same philosophy.
There's an absorption here. This in fact is not absorption.
But most of this is scattering, it is electromagnetism by
small particles.

Q. Suffice it to say that these two short charts show,
to your satisfaction, that there is some kind of living

12

matter out there.

A. Matter that started of living in the first place.
I think the exercise here is to take -- is to take an
ensemble of bacteria that you can get in the lab and the
sizes are measured, the optica (sic.) properties are
measured and so on. And in a hypothetical experiment you
fling them into space and ask the question, "What is the
obscuration that it would produce and what is the
absorption it would produce?" And they match the
astronomical data.

Q. Is the -- are the ultraviolet -- is the ultraviolet
chart characteristic of nucleic acids?

A. No, it's not that -- there are very minor effects
here and here on -- this hump here is the strongest effect,
absorption effect in the ultraviolet and it is attributed
in this model to be graded -- it's graphite -- soot like
material releases this absorption here.

The unfortunate situation is the
nucleic acids would have absorption at about 2,600 angstrom
so it is a very small effect here. And at the present
time it's hard to pick it out in relation to the --
to the general background of absorption. It is due to
the carbonized, the graphitized biology on this model.

Q. Have you reached any conclusions about the properties
of the organic material?

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A. Yeah. It's just what I told you. I think the
properties are consistent in my mind. Though I'll not speak
of material that started off as biology in the first place.

Q. Is there any evidence for nucleic acids in these
two charts?

A. The evidence for nucleic acids -- the evidence in
this -- the type of evidence that's shown in this figure
here is an absorption profile. It's due to all of the --
all of the organics that are involved in biology.

Q. I see a lot of dots on a white thing and I just don't
understand what it is they represent.

A. Well the dots -- the dots, as I told you, represent
the flux, the wavelengths dependents of a certain
absorption of the stars in the galaxy. And the attempt
is made to compare the detailed profile of this absorption
with a laboratory system. The laboratory system that I've
chosen for this comparison is desicated bacteria that's
kept in the laboratory and under conditions it's tried
out. And the agreement without any further assumptions
comes out to be exactly right.

Q. Exactly right with what?

A. Pardon me? The comparison. It's obvious to anyone
that the curve runs through the data points and that's the
only point I'm making. The curve is a theory --

Q. Did you put the curve on the graph before you put

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the data points there?

A. No. There are two different effects. The points
are the astronomical data. That's one -- on one -- one
one element of astronomical data, the points. The curve
is the predicted behavior of graph -- of desicated bacteria.
And the overlay is the correspondents to which I attribute
some significance.

Q. So basically you think there's some organic matter
out in space. That's the conclusion -- I don't want to
denigrate what the ultimate conclusion is, but that's what
the conclusion is.

A. That's the first order of conclusion, yes. That
there is organic material simply because -- I mean --
well, first of all zero (inaudible) on the spectrum is a
CH stretching which any organic chemist would recognize
as being tied with sea organic matter. But a further
conclusion which is more contentious and which people are
very resistant to accept it as a detail profile which
involves a certain amount of modeling, and a type of
modeling which is not -- is somewhat atypical of the
modeling you do in the laboratory when you want to
recognize laboratory spectrum and say what material there
is in that -- that gives rise to that spectrum. You use
certain criteria.

In astronomy one -- when it's

15

almost every fragment of information that is possible.
And I think that the kind of exercise that we've been
involved in this business, we use not only the wavelengths
of the absorptions, which are sort of separated points in
there, the dips and variations defined by the structures
of that curve. Not the set of those wavelengths only,
but the relative magnitudes of the absorption from point to
point.

It is essentially that the detailed
distribution of oscillators that are involved there. And
I think it's something that is very -- I -- I -- I've
managed to convince lots of chemists on this, but it
takes a good half hour to tell -- to -- to point that
there is a different -- there's a different exercise
involved when one is trying to match a spectrum which
has this kind of structure and so on. And attempting to
use all the information which is available relative
strengths of it from point to point on that curve.

Q. And it's your understanding that there's evidence
of properties with nucleic acid --

A. It's a whole slew of stuff. You take the bacteria
from the lab, it is not nucleic acids, all the polypeptides
(sic.), everything that goes in (inaudible) shows up in
absorption. So it is hard to separate the nucleic acids
from anything else by this kind of criterian and one has

16

to look for other things. And one of the things that we
have been attempting to look for, sicknesses (sic.) in
nucleic acid, what you told me and what you asked me a
little while ago. The absorption in the ultraviolet --
but unfortunately turns out that those are ultraviolet
absorptions are weak. The nucleic acids -- they have low
values of what chemists call a massive absorption coefficient
and it is hard to pick it out from the background absorption
of the other stuff that is in the dust.

Q. You said something about the explanation for dust
and particulate form in particulate sizes. Did I write that
down right?

A. Right. This curve is the calculation -- behavior of
a certain ensemble of particles with certain defined
properties that defined properties that refer to refractive
index. And the refractive index here is choosen to be
appropriate to dried out bacterian that I hypothetically
fling out and I sort of -- in a conjecture experiment fling
out in space and ask how much evacuation that occures.

Q. What do you mean by that?

A. Creation of a vacuum. Just as it mean. And then
they are off to calculating the electromagnetic absorption
and scattering properties of that system. The curve is
the calculation. And the -- without any further assumptions --
I mean let's take the lab spectrum, the flinging into space.

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I find that I get an agreement that these are rather close
and that's the -- that leads -- these are the two pairs that
I just want to refer to rather briefly and express my
opinion, which isn't necessarily the opinion of every other
astronomer alive.

Q. Is it the opinion of any other astronomers aside from
you and Sir Fred Hoyle?

A. I haven't done a consensus.

Q. I'm not asking for a consensus. Is there anybody
who agrees with you and Hoyle about this?

A. Well, I think very few people have addressed their
minds to it and to the detail operation that are involved
in comparison. But I think the answer is yes, I can
think of a few that appear to be partially convinced.
But there are lots of barriers to complete and --

Q. Are you aware of anybody who buys the whole theory
aside from you and Hoyle?

A. Buys the whole theory? Do you want me to name a
person?

Q. I'm asking you first if you are aware of anyone. If
you tell me you are, then I would ask you who it is.

MR. WILLIAMS: If you know.

A. Not to my knowledge. I have not attempted to have
extensive dialogues on this matter at this time. I knew
that it is something that requires a lot of conviction in

18

the sense that it takes a lot to convince someone on the
basis of this kind of data. But I think it needs a
background of understanding of what the data means. A
background of information of understanding what the
calculations mean. As it turns out, without any false
modesty, I think I can make a claim that this kind of
operation of comparing this type of calculation with
data is something that I've been involved in and I think
very few astronomers around the world have the -- the
length of experience that I've had and attempted to compare
various models of the dust rains with the relevant astronomical
observation. I have worked on my own and other people
intermittently. And it is -- it hasn't been -- I think
the situation is that it has not been examined critically
by any astronomer that I know of.

Q. Does your testimony that no astronomer agrees with
you totally about this theory --

A. No, I did not say that. I said I have not conducted
a census.

Q. That you are not aware of any astronomer --

A. I'm not aware of -- these have been published and
I am not aware of any astronomer who has published a retort
that could demolish the comparison.

Q. I'm asking you a different question. I'm asking you
has anybody told you, any astronomer told you that they agree

19

with you or the totality of your theory?

A. I haven't asked that question of any astronomer.

Q. Have you discussed it with any astronomer?

A. Yes, I have. In fact, in the United States they are the
people who have been working rather closely on the interstellar
medium from other directions. Not on the grains, not on
the dust, several of them tell me that they are now willing
to buy this aspect of the story. But there are other
aspects that require further --

Q. Have you discussed it with any biologist?

A. Have I discussed it with any biologists? The
astronomical implications or the comparison --

Q. The data?

A. The data is -- no, not the precise comparisons that
were involved here because the comparisons are not -- do not
relate to any particular expertise of biologist. These
spectra obtained just from the laboratory experiment the
astronomical data obtained from using telescopes and so
on. And comparison is -- did not demand expertise in biology.

Q. Have you discussed with anybody except astronomers?

A. Yes, lots of people.

Ql What other disciplines I mean have you sought out the
advice of people in other disciplines?

A. I haven't sought out the advice --

Q. I've given seminars, I've given lectures to

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departments of microbiology up and down Britain. To that
extent, I have disseminated some of these ideas in public
and amongst biological colleagues.

Q. Have you gotten feedback from them about your result?

A. Yes, I've got some feedback in the sense that they
say the comparisons are quite interesting and impressive
and so on. But they would like to think that there are
simpler explanations for the correspondences, but until I
find somebody who produces correspondence such as of a
comparable kind, I'm not willing to regard the possibility
that there may be a simpler alternative because I myself
have looked at simpler alternatives. I looked for instances
in this particular case -- I've looked for comparison with
the prebiology models of Sagan, and so on, and his colleagues.
A lot of experiments done on the behavior of absorption
properties of prebiologic particles, and I've looked at
dozens of these, and it just failed completely to explain
the fact in the infrared.

Q. I just noticed on this chart that you are making
reference to dry E. Coli. Is it that property particularly
that you guess that it is?

A. No. The reason I think that it is a fairly long
story that -- what really happened in this case was that
we were looking -- by we I mean myself and Sir Fred Hoyle,
two colleagues. We were looking at the behavior of

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microorganisms sealed in -- not the biological behavior,
but the absorption properties sealed in KBr disks --

Q. What kind of disks?

A. Potassium bromide disks. -- and heated to various
temperatures in an inherit atmosphere to decide how high
a temperature these things could stand before the chemical
signatures essentially got molified over this wavelength.
And we found that -- the reason for doing this experiment
was that there were various claims about the fossils,
microfossils in sediments and the Isua sediments was the
oldest sediments on the earth.

Q. What kind of sediments?

A. Sedimentary rocks.

Q. I would like for you to repeat the word so that the
court reporter gets it.

A. Isua, I-s-u-a. that means -- there has been a
controversy --

DR. HOLTZMAN: Capitol "I"?

A. Yeah. It refers to a certain geological formation.
And there have been various arguments about the biogenesity
(sic.) or otherwise of certain fossils or certain structures
that were discovered in these rocks. One of the arguments
against biogenesity was the high metamorphic compress (sic.).
These rocks have been turned through fairly high temperatures
after the initial sedimentation. The question was raised,
could the -- if (Testimony continued on next page.)

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they were organic sediments, if they were biological sediments
trapped in these rocks, could they have survived and preserved
their chemical integrity through the heating processes.
And we know that the rocks went through about 400 degrees of
centigrade or near enough. So we tried to mimic that
condition by -- obviously you cannot recreate the geological
experiments. So we thought it would be interesting to
see how microorganisms sealed in a KBr disk, not just one
but a whole bunch --

Q. Oh, I see. You're saying capitol K, capitol B,
little r.

A. This disk was -- and I am not going to go into
details about it.

Q. No. What I'm asking is this line somehow representative
of E. Coli in particular?

A. No, there were several other organisms that were
also -- it is not diagnostic of the particular bacteria
over that wavelength. I know that infrared spectrous could
be used to -- to -- to dec -- to decide between different
types of bacteria. But either fortunately -- or I think
that is sort of a thumbprint reason for biology in general.
It seems that we looked at the yeast cell and it had
pretty much the same spectrum.

Q. Yeast cell?

A. Yeah. I think this is the reason that it was -- the

23

most invariance from the different system and overall the
E. Coli at room temperature, E. Coli at 350 degrees saved
in a caviar (sic.) disk and in that atmosphere and yeast
at 20 degrees centigrade. And the overlay there was --

Q. What's the temperature of the grains of dust?

A. The temperature of the grains of dust in space
averages about 10 degrees above absolute zero. But it is
more than likely that in -- that the dust goes through
high temperatures from time to time. They get some dust
clouds involved in the formation of near stars and part
of the gas and dust that does not really go into the stars
become exposed to transiental high temperatures.

Q. But you are taking something that is normally at
10 degrees Kelvin and comparing it with the curve of
something that is either 20 degrees centigrade, and if I'm
not wrong, is 270 degrees Kelvin and something at 600
degrees Kelvin?

A. That's right. In this experiment. But there are
sound technical reasons for doing that and I think there
are also reasons for expecting that the low temperatures
of behavior of the absorption over that wavelength was
likely to be not different.

Q. I don't understand why you think you can measure
something at 10 degrees Kelvin and it be --

A. It wasn't --

24

Q. What would it look like at 10 degrees Kelvin?
Can you draw that on here?

A. Yeah. Exactly the same.

Q. Where, right in the same spot?

A. Right in the same spot. I think there is no
difference.

Q. Why if there is a difference between 20 --

A. Because at 350 chemical bonds are broken. The trace
quantities of water are thrown out and so on. But go
below room temperature in general, there is a sharpening
of absorption as a general rule. But the situation here
is that these absorption structures are not single
transitions, but a whole bunch of them. So the thermal
affects as you cool them, cool the dust or the bacteria
below 20 degrees is not, for this particular comparison,
relevant.

Q. Okay. Is the size or the shape of the dust particles
in any way relevant?

A. Not for this comparison.

Q. I wrote it down hurridly. I thought you said
something about the explanation for the dust particulate
form and particulate size?

A. Particulate form is in the form of small particles
and the particular size I referred not to the -- the
infrared behavior at wavelengths that are -- how technical

25

do you want me to get? You are not trapping me in any way
because it is in my --

Q. No. Believe me, no one knows better than me that I
am not trapping you.

A. At wavelengths long compared to the size of the
particles. If you take small particles, look at a
wavelength that is large compared to the size of the
particle, then the size does not enter explicitly into
the absorption. It is what's known as Rayleigh absorption.
So in the long waves, size does not enter. And in the short
waves the size does enter.

(Testimony continued on next page.)

26

MR. WILLIAMS: Before we begin back,
I wanted to put on the record in this deposition, for the
record in this case, that Mr. Henry Voss will be available
for deposition at 6:30 tomorrow morning at the Attorney
General's office. And we've had some -- I had some
earlier discussions with Mr. Novik and I'm communicating
that to the Plaintiffs now, on the record.

MR. KLASFELD: I'm not sure exactly
what Mr. Novik's reply was, but 6:30 in the morning
strikes me as a little bit unreasonable.

MR. WILLIAMS: Well, it's 12:30
London time, you know.

MR. KLASFELD: Mr. Voss isn't
coming from London. Dr. Voss? Dr. Voss.

MR. WILLIAMS: Off the record.

(Off the record discussion.)

BY MR. KLASFELD:

Q. You said something about the infrared sources of
radiation in our galaxy showing certain patterns of
absorption. What is it that you would expect to testify
about that?

A. That the presence of absorption detected in the
galaxy, not simply consistent with biology, which it is
in fact, without a shadow of a doubt that it is consistent
with biology. But in my opinion it's also -- there is a

27

reasonable chance that it is a diagnostic of biology.

Q. And the microbial model is due to this pattern that
you find that you can only satisfactory explain by what
you call a microbial model. And by microbial model you
mean that it's dried out bacteria?

A. Yeah, terrestrious (sic.) type bacteria is just
shoved into space and experiments done on that.

Q. You've done that?

A. I've done them, not myself, but along with a student
and a professional of biochemistry.

Q. How did you get it out there?

A. I didn't get it out there. No, no. This is in a
lab.

Q. Oh, I see.

A. They're attempting to mimic conditions that would
obtain when I shove it out there.

Q. Do you have what you consider to be unequivocal
evidence for nucleic acids in space?

A. In a spectra line it is something like that.

Q. In any form that satisfies you that it's unequivocal
evidence?

A. No, I said it's not. It's masked in the general --

Q. Excuse me, masked?

A. Masked in the general absorption behavior of the
dusts. So, I think it's hard to be sure until one gets

28

a much higher definition of the data. It's not -- it's
impossible to detect it. And it was detected unequivocally
in the present.

Q. Okay. Do you have a theory about how those microbial
organisms got there?

A. Yes, I do.

Q. What is that theory?

A. It's a theory that's discussed in a couple of the
books that I've written over the past couple -- year or
two, or so. I think I'll draw your attention to page --
besides in the galaxy the bacteria are most likely to
replicate and to be amplified in numbers is in the
environments of planets and surfaces of planets, and in
interiors of comets their liquid water could be present
for -- over lengths of long periods of time. And we know
that as a consequence of star formation there is --
planets, comets form along with the stars. So, there is
a sort of feedback loop that develops.

Suppose one starts with a very small
component of biological material in the galaxy -- call it
biotic material. It's incorporated --

Q. Biotic -- I call it biotic material. It's incorporated --

A. Uh-huh. -- into the intercellular material, into
the gas and dust in space. And these gas and dust is going
to form new stars, planets, and comets. And the tiniest

29

amout of material that you start with in this loop is
amplified when it goes into a comet or into surface of
the watery planet. And the circumstance that the
particles are of the sizes that they are, the bacteria to
speak of is a third of a micro in radius, permits them
to be exposed by force of radiation from stars, radiation
as a factor -- starlight as a factor of pushing these --
rocketing these particles out from the parent stars
where they are -- around which they are amplified. And
it goes back into the intercellular medium -- into the
gas. And this incidentally is just a orilnebular --

Q. O-r-i-l-n --

A. Orinebular. And that's the reason of very accurate
star information. So, particles are amplified as -- as --

Q. By what process are they amplified?

A. By -- simply by logical replication and --

Q. They grow?

A. Hum?

Q. They're alive?

A. Yeah, a small fraction. There could be a massive
massacre due to radiation conditions in space, and so on.
And I don't want to go into detail or anything although
it is very authoritive that there is -- there are various
mechanisms that would permit survival of biology to
significant extents. But it doesn't require even survival

30

of one part in a million to make this loop go and to
amplify the numbers of biological particles.

Q. But they're alive and they replicate and grow?

A. Some fraction, some fraction is in a viable condition
to get to the next site of amplification to convert the
ambiant matter -- inorganic matter into more biology and
the -- the feedback builds up to account essentially
for all of the -- or a large fraction of the dust in
space.

Q. Where does the biotic material come from in the
first place?

A. From the -- you mean the very first -- very first
cell? Is that the question?

Q. Well, you're assuming the presence of some biotic
material that then gets into some kind of circle. I'm
asking where the biotic material comes from in the first
place.

A. Yeah, that's -- that's -- I think there is several
possibilities. One is that it -- it gets in -- gets
together in random shuffling of the cosmic -- on the
cosmic scale, right. The advantage one has from going
out from a little pool on the earth to -- to the whole --
to our universe is that we've got many more sites for
the shuffling -- you could use one -- a couple of pools
on the surface that are invariably sheltered -- the

31

conditions are the least favorable for any polymerizations
to occur.

Q. The least favorable where?

A. On the surface of the earth, and the earth's oceans.

Q. I see.

A. So, if one takes account of all the possible occasions
in the galaxy and the universe where they could -- water
could -- present, you could improve their chances of
starting life somewhere. But once it is started, then
it gets into this -- it gets ineligibly trapped into a
feedback loop-back simply because the particles of biology --
the microorganisms and particles of biology have the
right sizes to -- to get expelled from nearby stars, from
parent stars. They have the right sizes to get pushed
away from the parent stars.

Q. Why did you say that the earth's surface was the
least favorable?

A. It's -- there are several reasons. Do you want me
to enumerate them or what?

Q. Yes.

A. It's -- It's in the earth's oceans that something
might have happened, right. The aqueous conditions that
may -- are required to be the -- would have to obtain the
assertions. So, the -- and the oceans -- I think the --
the difficulties of getting molecules together, amino

32

acids together, polymerizing in a watery matrix -- in a
watery medium with very little ultraviolet light
penetrating an atmosphere, it presents problems I think.
Perhaps I should tell you this. I think that when the --
when the earth's oceans were made, then inevitably that --
an atmosphere develops. It's my -- in my opinion an
atmosphere develops. And that makes -- an atmosphere
shields the ultraviolets from the sun and there's hardly
any ultraviolet phortons (sic.) that would be raining --
falling on the surface of the ocean. It's minute fraction
of ultraviolet flux that gets onto the surface of the
oceans.

And it's only ultraviolet light that can
polymerize the -- produce energy -- provide energy for
linking amino acids and polymydes (sic.). For example,
if you don't have -- if you don't -- if you start with
no life on the earth, to get from no life to life requires
stringing together of these -- of amino acids. And I
would argue that that doesn't happen in a radiation
protected environment.

Q. You said that random shuffling on a cosmic scale was
one of the possibilities. What are some of the other
possibilities?

A. The -- I think the information content applies. It's
so, incredibly, vast that one has to entertain the

33

possibility of a creation, but a creation not in the
sense that we've been hearing from the trial. But a
creation within the -- the framework of the universe, within
the laws of physics and chemistry of the universe.

Q. What do you --

A. A Creator that somehow develops them in the context
of the universe -- within the -- within the universe
consistent with the laws of physics just as -- just as --
I think that is a logical place for a Creator, within
the planet of the earth.

Q. Are you saying Creator --

A. Creator of the first life

Q. Yes, he's saying Creator. But consistent -- acting
consistent with the laws of physics and chemistry?

A. I believe it could be done. I believe there is
such a possibility, not that I understand it -- the details
of such a mechanism. But there is no apriori reason for
rejecting that as a possibility.

Q. Is there any positive scientific evidence for such
a possibility?

A. In a negative --

Q. No. I asked if there was any positive evidence.

A. No. That's -- I don't see how one could get a
positive -- positive evidence. I think it is by eliminating
the other possibilities as one argues that there is still

34

a logical place left for -- for this option.

Q. How many other possibilities would you say there
are?

A. For this sort of life?

Q. Yes.

A. For the origin of life. I think there are certain
possibilities that -- I would like in my own -- what I
would like to think possible is a mechanistic approach
to the origins of life. But the information content of
life is so incredibly vast that I think one is an open
time scale for the universe.

I'm prepared to believe that present
cosmilogical ideas on the time scale of the universe may
be in error, in which case a mechanistic origin might
develop once and then -- that's one possibility.

Q. You've mentioned two possibilities.

A. Yes.

Q. One, the random shuffling through perhaps some
extended time scale.

A. Yes.

Q. Two, a Creator.

A. Yes.

Q. Is there a third possibility?

A. Not as I can say for the moment, no.

Q. You said that the earth was 3.83 -- you say the life

35

on the earth was 3.83 billion years old.

A. Yeah, the present evidence seems to me to suggest
that it's -- it's -- I mean you could subtract .4 billion,
I think. It's somewhat of a contentious matter, the --
the fact that 3.83. But at 3.5 there's a concensus view
that there is life at 3.5. At 3.3, if you go nearing the
present day, the agreement -- the sort or examiner belief
is that the evidence is even stronger. But in -- the
way I look at it, I think there's no reason for doubting
that there was life at 3.83.

Q. And how old is the earth itself?

A. About 4.55 billion years.

Q. Are you aware of any evidence that the earth
might be significantly younger than that?

A. No.

Q. What would you think of a -- someone who called
themself a scientist who felt that the earth was 10
thousand years old?

A. I think that he is misled and is not looking at the
facts in a systematic, reasonable way.

Q. Could any rational scientist think that the earth
was even a million years old?

A. No.

Q. You said that the conventional wisdom of the origin
of life, that there are major difficulties in forming

36

simple life forms. What are those major difficulties?

A. Major difficulties. You mean conceptually or --

Q. In whatever sense that you mean it.

A. The difficulties are really vast and inmeasurably
because it hasn't happened in the lab, for one thing. And
major difficulties I think are in getting together the
information that is required for life. And I'm not
referring to any sort of -- any arbitrary set of information
or instructions for life, but a specific as we recognize
as life. That has to arise from a situation that it's
initially random and the rate of acquisition of units of
information that leads to the particular system that we
recognize as life poses a serious problem, I think. If
one is dealing with limited time scales on the -- on the --

Q. And you're referring to several billion years as
a limited time scale?

A. Cosmilogical time scale.

Q. You do a calculation in the book Evolution From Space --

A. Uh-huh.

Q. -- in which you come up with the number 10 to the
40 thousandth. That's sort of a conservative estimate --

A. Yeah.

Q. -- of the possibility of arriving at life randomly
on the earth.

A. Yes, I think I would stand by that characterization.

37

Q. Could you go through the -- could you go through
the calculations for me?

A. Yes, I suppose I could. Right now, or --

Q. Yes, please.

A. Okay. I would say that a necessary condition for
reaching the living system from a non-living system is to
get the very specific information in arrangement as one
finds in the enzymes, right. The -- and one knows how
many sites are crucial in an enzyme for -- for particular
biochemical -- for particular straight -- for particular
biological function of the enzyme, themselves, to do
something. And you know how many -- you know how many sites
typically are required to be filled by particular amino
acids. And the conservative estimate I would say is one
of our fifteen sites -- fifteen or twenty sites. You
pull it down maybe, I don't think it helps very much.

So, it's really a calculation, a very
straight forward combintarior (sic.) calculation of
finding out how many possibilities there are of reaching
the crucial enzyming system that goes across the whole of
life. And it's just -- we're talking up numbers. I think
it comes up to 10 to the 40 thousandth.

Q. Well, you take 10 to the 20th, right? That's what
you're just talking about, the points, right? 10 to the
20th? How do you get from there to 10 to the 40 thousandth?

38

A. No, if that's --

Q. Twenty --

A. You mean twenty sites.

Q. Yes.

A. So, that's 15 sites, let's say for argument sake.
Fifteen sites for enzymes, a critical -- required to be
filled by particular amino acids. Then the chance of the
number of shufflings that they need to get one amino acid,
right -- one enzyme, right, is 20 raised to the power
assuming there are twenty relevant amino acids for enzymes,
is 20 raised to the power of 15. That's raised to the
power of 2000 if there are 2000 enzymes. And you do a
bit of combintariorizing (sic.) and divided by facterials
(sic.) and so on. And obviously aren't going into that
deep, there's a book here. But if you do a bit of
elementary divisions of the 15 sites -- need not be 15
specifically, you can slide them up and down and you can
also mix up the enzymes. It doesn't matter whether you
find one enzyme first or the other one, or that enzyme
last in your shuffling. So, there are various divisions
that has to be done. And many times it's about maybe
10 to the 40 thousandth --

Q. Is that a big number?

A. You can say that again.

MR. CLARK: It's more than Mr. Williams,

39

Mr. Campbell, and I can add together

Q. What exactly is the information you're talking
about when you use the word information?

A. The arrangement of the sites, the filling of the
sites. Information needed to fill those sites with one
of twenty amino acids.

Q. Is the -- is the information a natural substance
or is it some kind of concept that we impose on what we
find there?

A. It's a concept that arises from the arrangement.

Q. Are there reasonable relationships between these
enzymes to the extent that you are aware of?

A. Not -- not -- it's not sufficient to -- to pull that
number down to -- I mean you could tell me -- someone
might tell me -- maybe someone could tell me that all
enzymes are living independent on a smaller set or something
like that. But unless a small set is reduced to ten --
I think the 10 to the 40 thousandth is such a vast number
that they could really -- I could have thought to --

Q. You can give me 10 thousand?

A. I could give you -- yes.

Q. The -- and I suppose it's this number that you're --
that you're using when you say that the chances of it
happening are so small it's not to even consider?

A. Yes. I would say yes. Uh-huh.

40

Q. And you made reference to the difficulties in the
polymerization of amino acids, is that the same thing
that we're talking about?

A. No, it's a different definition.

Q. That's something more?

A. That's -- that's -- I would have thought it was a
higher order difficulty in a sense, higher order relating
to location on our planet because the situation there
is that even the shuffling which one assumes -- I'm not --
in that operation of -- in the calculation there are no --
there are no kinetics involved. It's just the simple
statistic elementary probablistic calculation. I'm not --
I'm not dealing with any kinetic processes. So, the
kinetics -- if one considers kinetics of association then
there are process -- I mean, facts that could be regarded
as helping out of the dilemma. But there are also effects
that are devastating against the association of amino
acids and similar monimals (sic.) of life.

Q. What would that raise it to -- what level of
difficulty would that raise it to?

A. Beg your pardon.

Q. Would that make it 10 to the 50 thousandth, 10 to
the 100 thousandth?

A. I haven't set numbers on it yet I think the processes
don't to with some of the processes that I invoke.

Q. Why don't we take a break?

(Recess.)

41

Q. Would you tell me what graduate degrees you have
in biology?

A. In biology?

Q. In biology.

A. No, I have taken no degrees in biology.

Q. In geology?

A. No, none.

Q. In paleontology?

A. No.

Q. Are there any sources that you've used in your --
in your work that you recognize as authoritative sources
on biology or genetics?

A. Yeah. I have used several texts.

Q. Which texts would those be?

A. Lehninger's Biochemistry.

Q. Who else?

A. Uh, in what, biology, biochemistry or what?

Q. Yeah. Any of those texts.

A. I don't carry a list in my head unfortunately, of
those texts. Quite a few of them I've used.

Q. Watson Molecular Biology of the Gene?

A. Watson -- yes, I've read his, yeah.

Q. Do you recognize that as an authority -- an
authoritative text?

A. Yes, I do. And I think the others are a miscellaneous

42

collection of texts.

Q. All right. What about the Benjamin Lewin Gene
Expression?

A. Yeah. I've seen that. Yeah. Some of it.

Q. Do you recognize it as an authoritative book on
gene expression?

A. Not all of it. I've noticed -- I've looked at it,
yeah.

Q. I'm not asking you if you know the whole book --

A. No. I would recognize him as an authority, yes.

Q. -- have you read the book -- and -- uh --

A. Not that -- I wouldn't say that I agree with
everything that's written there, but I would like to --

Q. -- and there are a witness offered in this trial,
Dean Kenyn. Are you familiar with his book, Biochemical
Predestinations?

A. No, I haven't read it. No. No.

Q. Is it possible that life always existed, that
there was no beginning and no end?

A. Uh, it is possible logically. I think there is
no reason to doubt it -- for dissipating a logical
possibility, but the present data one has about the
universe seems to suggest that over time scales of twelve --
ten billion years, material gets turned around and heated
to temperatures that would eventually destroy the chemical

43

[PAGE MISSING]
44

selection together with mutations, gene doubling, and so
on, provides a woefully adequate explanation for the
generation of verities, and that there is a need for a
continuing addition of information.

Q. But you are disputing only the mechanism and not the
fact of evolution.

A. The mechanism, yes, most certainly.

Q. Do you think that evolution is a fact?

A. Evolution as depicted in the fossil record and in
the general disposition of biochemistry of cross life, yes,
certainly, yes.

Q. Do you have a copy of your book, or did David
take it back?

A. I've got a copy, yes.

Q. Would you take out the copy of Evolution from Space?
Would you look at the bottom of page 64?

A. Yep.

Q. And the paragraph that begins at the bottom of that
page, which says, "Is it the same story within the bodies
of animals. We always talk as if we ourselves digested
our food. This is loose talk, for it is bacteria that
breaks --" or "it is bacteria that break the food down
for us into more elementary substances which our bodies are
able to use. Bacteria do much of the digesting. We only
create the conditions that make it convenient for them to

45

live inside us." What is the basis for your view that
bacteria do much of the digesting?

A. From what I've read in various places, it seems
to me that the -- the enzymes that are required for unzipping
a lot of the -- the -- uh -- let me just recall what was
the basis of that. It's a bacterial enzyme that are --

Q. Bacteria enzymes?

A. Enzymes in bacteria that seem to be required for
doing certain things. It's a --

Q. What is -- what is the source? Is it in one of
these texts?

A. No. I cannot -- I really cannot recall the origin
of that paragraph. This book has been put together by
two people, and I've looked over it -- I've looked over
the synthesis the scientists put together, and some of
it comes to me --

Q. Did Hoyle put together this chapter?

A. That particular paragraph, yes. Certainly I don't --
I don't really have the chapter and verse to -- to substantiate
that.

Q. Does Hoyle have any expertise in biology?

A. Uh, in a self-taught way, yes, I think so. I think
there's no -- to my mind there's no good argument for
requiring expertise in the sense that you've been discussing,
like degrees in universities and so on.

46

Q. But he has no degree in biology; is that right?

A. No. He has no degree in biology.

Q. Do you believe that to be true?

A. That bacteria do much of the digesting?

Q. Yes. And much here, in the context here, seems to
me to be most.

A. Uh, I'm not really -- I don't think I have got
enough information at the moment to make that -- to
accept that categorically. It's my opinion -- it's my
impression by what I remember reading is that this bacteria
will play some role in digestion, but -- let me -- if that's
it, maybe I should do this -- this refers to humans --
this refers -- perhaps because we is used in that context,
it has to refer to humans, but bacteria in the guts of
sheep, for instance, involved in the breakdown of cellulose,
maybe that's the sort of thing that --

Q. Well, isn't it always cellulose that bacteria is
important in digesting?

A. It's a -- that's a particular -- right. Okay.
Yeah.

Q. But this doesn't make reference to cellulose, does
it?

A. It doesn't make an explicit --

Q. Well, it says we always talk as if we ourselves
digested our food.

47

A. Yeah. It probably is an extrapolation from the
sheep -- faults (sic.) in the sheep story, but I don't
know what the -- the precise --

Q. Would you look at page 72, please?

A. Uh-huh.

Q. Would you look at the -- the top paragraph, not the
full paragraph, but the top paragraph.

A. Uh-huh.

Q. Where you say, "There is evidently a major chasm
between the modes of gene expression in the two kinds of
cell. A similar conclusion might have been reached
long ago from the fact that photosynthesis and prokaryotes,
that's P-R-O-K-A-R-Y-O-T-E-S, does not use water as in
eukaryotes, E-U-K-A-R-Y-O-T-E-S, a remarkable difference
mentioned already in chapter four." Did you write this
section?

A. Let me recall the context of that. The first couple
of sentences I -- I recall --

Q. Was that before what I read?

A. What's that?

Q. I'm sorry.

A. The first couple of sentences of the paragraph,
"Genes of the..." (inaudible, witness reading.)

COURT REPORTER: Could you please
slow down. I can't understand what you're saying.

48

A. On the broken segments of the DNA, I think there
is enough evidence that this is true?

Q. What about the section that I read?

A. That the difference is in the way that the DNA
sequences are comprised -- uh -- would represent to my
mind the major chasm between the modes of gene expression,
between prokaryotes and eukaryotes. I would -- I would
go along with that.

Q. What is blue-green algae? Is it a prokaryote or
eukaryote?

A. Blue-green algae -- uh -- are prokaryotes.

Q. Does it use water in a vial of oxygen?

A. Uh, no. I guess not.

Q. Are you saying it does not?

A. Does it use water? No, I think that it does not.

Q. You think that it does not?

A. I think that there's probably evidence -- I don't
know. I haven't got the facts in my head at the moment.

Q. Did you ever?

A. What's that?

Q. Did you ever have the facts in your head about this
subject?

A. About what subject?

Q. Whether or not blue-green algae is a prokaryote, and
whether or not blue-green algae uses water in a vial that

49

evolves oxygen.

A. Uh, uses water and evolves and --

Q. Well, what you're saying here is that, prokaryotes
do not use water --

A. Uh-huh.

Q. -- a remarkable difference. And you said that
blue-green algae is a prokaryote.

A. Uh-huh.

Q. And I'm asking you if it uses water.

A. Yes, I think it does. Yeah. I'm sure it does.

Q. You're sure that it does?

A. Yes.

Q. So you're saying that a remarkable difference
between prokaryotes and eukaryotes is that prokaryotes
don't use water?

A. I better look at the reference in chapter four.

MR. CAMPBELL: David, just for the
record, if Dr. Wickramasinghe's answers don't seem as clear,
it is almost 4:00 in the morning London time, and that --

MR. KLASFELD: I would have taken
it any time today.

MR. CAMPBELL: Our position is that --

MR. KLASFELD: This deposition is
at your convenience at the time that you set.

MR. CAMPBELL: I'm just explaining

50

the reason why it is that way.

MR. KLASFELD: Well, I understand
that, but you can't have it both ways. You can't say --

MR. CAMPBELL: I'm not trying to
have it either way. I was making a comment on the record.

MR. KLASFELD: Okay.

BY MR. KLASFELD:

Q. Could you turn to page 105, Dr. Wickramasinghe?

A. Yep.

Q. Would you look at the first full paragraph. It says,
"In the similar way, there must be a program that directs
the activity of a living cell. The question is, what
decides this program, and where inside the cell are the
instructions for it located. To take the easier second
part of the question first, while biologists are generally
agreed that such instructions must exist, the situation
concerning their location is indefinite. The usual
disposition is to suppose that the location is on the
chromosomes." Now, these next two parts is what I want
to focus on.

A. Uh-huh.

Q. "If so, a possible location would be in the so
called nucleolus, N-U-C-L-E-O-L-U-S, a chromosomal region
that appears decisively during the process of cell division,
and which would seem to preserve its identity in that

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