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Q. Is there also something called the — is there an assumption that the rate of decay has been constant throughout the geologic column?
A. No. The geologic column is essentially the system of rock units that represent geologic history on the earth. So it's remained constant through the geologic column, you're really saying it's remained constant with time. I think, if I understand you correctly, those are essentially equivalent statements.
Q. Would the Big Bang be a uniformitarian event?
A. Well, again that's a question in astrophysics. But if I understand what the Big Bang was, it was probably initially a catastrophic event.
Q. So it would not be an event of uniform laws that are in effect today?
A. No, that's not what I said.. Uniformitarian.— you can have catastrophism and uniformitarianism at exactly the same time. They do not preclude each other at all. So that it's possible that the Big Bang was caused by the same physical laws that operate today in the universe. In fact, I think the theoretical physicists who work on the Big Bang use that presumption.
Q. To your knowledge, has anyone been able to synthesize, in a laboratory, granite?
A. I don't know that anyone's ever crystallized granite
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in a laboratory.
Q. Would it be significant if they could?
A. It would be significant in the sense that it would allow experimental petrologists to perform new experiments on how rocks crystallize that they cannot now perform because of that limitation. But the reason they cannot synthesize granite in the laboratory is because of the kinetic problem. It's one of getting crystals to nucleate and start to grow. It's really an experimental problem. It may be that someday they'll find a way to do that. But the difficulty is in experimental technique.
Q. Well, if you could get a synthesis of granite in the labs, what would that tell you about the rate of decay, if anything?
A. Nothing.
Q. Nothing? Did you understand radioactive halos to be — since you read that one article, what significance do they have if you studied them? What can we determine from studying of radioactive halos of some of these granites or rocks or whatever?
A. Well, I'm not — you know, relevant to what? I suppose they learn how far an alpha particle will travel through mica and things like that. In terms of learning things about the age and history of the universe, I'm not sure there is much to be learned from those if I
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understand Gentry's conclusion correctly. That is insofar as it applies to decay rates.
Q. Uh-huh.
A. His statement was that the uncertainties in the measurements are simply too large. You can't tell whether they've changed or not.
Q. On page three of Exhibit #6, at the bottom of the page you point out that a small number of wrong ages are nearly all due to unrecognized geological factors, to unintentional misapplication of the techniques or to technical difficulties. Could you give me an example of the first where a wrong age has occurred due to unrecognized geological factors?
MR. WOLFE: I would like the record to show that the actual quote includes quotational marks around the word "wrong".
A. You want an example of something that's due to unrecognized geological factors?
Q. Right.
A. Okay. Often times when we want to date a rock by potassium/argon, for example, we look at the rock and see if we can see any evidence that the rock has been reheated. And we do that by certain petrographic criteria and geologic criteria. However, the state of that knowledge is imperfect and sometimes we will select a sample that
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we think has been a simple system that has not been reheated. And in fact, after performing a number of consistency tests, we may find out that all of the evidence indicates that that one rock may have, in fact, been reheated or in some way disturbed. That it has not been an unaltered system. So that would be a — that's an abstract example.
Q. How often does some unrecognized geological factor arise which renders a conclusion about the age of something wrong?
A. — Well, it's not — it's not very often because usually radiometric dating, the way it's done now, is done on large numbers of samples in a controlled experiment with internal checks and geological checks on the results so that we can look for consistency and spot errors. This is done in several ways. The simplest way is to do the measurements two or three times to make sure that there is no error there. We can compare whether rocks are amenable to it. We can compare ages from different decay schemes. We can do ages on rocks that are stacked in sequence so that they know what their proper order should be and so forth.
So I think it's extremely rare that a single age measurement will give us misleading information because usually they are not done singly. They are done in large
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groups with an experimental design in mind so that the results can be internally checked.
Q. Could you give me the example of where an unintentional misapplication of the techniques have resulted in an erroneous age for a rock or some other part of the earth?
A. Oh, that's a case where scientists will simply make a mistake.
Q. Have you ever made any of those?
A. Oh, sure. It's — this is why we try to build as many checks and balances into our experiments as possible. But if we go out to do a study on a volcano, for example, and collect 106 samples, I suppose there's a small percentage that sometime during the sample processing we may get some samples mixed up. And we may apply, for example, a potassium/argon method to a sample that we never intended to apply it to simply because there was a mix-up in sample numbers or something like that. This happens rarely, but it's still a problem. With any complicated technique people are going to make mistakes.
Q. And the third thing there mentioned is — are the technical difficulties.
A. Well, in isotopic age measurements we need to add a tracer of an amount of an isotopic substance of known composition and amount in order to make the measurements. That's simply a consequence of the techniques. If there
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is some technical difficulty with the way that isotopic tracer is metered out, for example, then we would not get the right answer. For example, if we thought we had twice as much of that tracer as we actually did in the experiment, then we would get a result that was incorrect. But there again, this is the reason for building redundancy, considerable redundancy in the experiments is to try to pick those things out.
Q. Why is radioactive decay a statistical process? Would you explain that?
A. Well, it's because if you take a single atom, you can't tell when it's going to decay. You can't tell when that particular atom is going to decay. What you can do is specify a probability that that particular atom will decay per unit time, per second and so forth. Therefore, if you have a large — well, that's where the statistical part comes in. But the statistical uncertainties disappear when you have large numbers of atoms. And even in very small amounts of a substance, like tiny, tiny fractions of a grain, you have billions of atoms. And so the statistical uncertainties in the radioactive decay process disappears as far as practical measurements are concerned.
Q. Your statement on page 10 is that radioactive decay must be constant and predictable. You say that's one of the requirements of each of the radiometric systems —
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methods, excuse me.
A. If the methods are to work that must be true.
Q. In other words, this is one of the — may also be termed one of the assumptions?
A. No, I think I've already explained the reasons for being sure that radioactive decay is constant within any limits that will affect our dating techniques. And by predictable, I simply mean that we must be able to predict that where ever those elements occur, those elements will always decay at the same rate. That's really simply a corollary of uniformitarianism in the sense that physical laws are constant. We can't say that Rubidium-87 decays at one rate in this rock and at another rate in the other rock. That must be predictable. Once we've measured in one rock or 100 rocks, then it needs to be the same everywhere. And again, there are theoretical and experimental reasons for thinking that has to be true.
Q. So to your knowledge, that is true? That where ever an element is found, it's going to decay at the same rate?
A. Within the set of physical circumstances that rocks on the earth and meteorites and the moon experience, that's true; yes.
Q. Was there something — I just recall reading something about some dates which were once determined, as I understand
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it, around some volcanos which later were determined to be inaccurate. Does that ring a bell with you at all?
A. Are you thinking of Hawaii? Submarine basalts?
Q. Perhaps so. Do you recall something that occurred like that? What happened that would cause the error that you're aware of?
A. The thing that I'm thinking of was not an error.
Q. Oh, okay. Well, you explain what you're thinking about. Maybe that's the same thing and my memory is poor.
A. Well, what I'm thinking about is an example that is used in some of the creationist literature. That is the submarine basalts off of the east rift zone of Kilauea Volcano.
Q. Uh-huh.
A. And these lava flows occur underwater. They're known with a fair probability that they're very young, they're still erupting. And the estimates are that these lava flows that occur right along the top of the rift zone are at most within a few hundred — formed within the last few hundred years or so.
A number of years ago Dr. Jim Moore and myself did an experiment. There was another group that independently did the same experiment to determine whether or not these types of rocks could be dated by the potassium/argon method. And the reason we did that was these types of
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basalts, types of lava flows form large — form most of the ocean crust. And we wanted to know if it was going to be possible to date these type of rocks in order to date the ocean crust in different places in the ocean basin. So in order to determine whether we could use submarine basalts to make these measurements, we first had to do a controlled experiment to see if the potassium/ argon dating technique would work on those types of rocks. So we went to Kilauea where we had samples that were of reasonably known age. That is zero age as far as the potassium/argon method is concerned, and had been dredged from various depths along the east rift zone. We found that these particular type of rocks trapped excess argon so that the potassium/argon system did not behave in such a way that it could be used for dating. And as a result of those experiments, those types of rocks are not dated.
Most of these radioactive dating techniques can be applied only to certain kinds of rocks and certain kinds of geological situations. And what those rocks and situations are depends on the particular technique
Q. Is that an objective decision where you can look at the type of rock that you have and if you wanted to could reduce it to a list and say this type of rock has to use this type of method?
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A. Yes.
Q. How have you arrived at that determination that it's objective?
A. Those are usually done by a series of controlled experiments similar to the one I just described to you. If you want to date submarine basalts, first you test the method under known circumstances and see if the technique works on those kinds of rocks. In this case it didn't. And through the years this has been a gradual learning experience. We do not have adequate tests on all kinds of rocks yet. There are still large numbers of rocks that we don't know whether the techniques will work or not. But there are also large numbers that we're very confident that they work on.
Q. The second thing on page 10, the second requirement for radiometric dating methods to work is that the rate of decay must be known.
A. Uh-huh.
Q. What, do you mean by that statement?
A. That means simply that we have to be able to measure that rate of decay independently in the laboratory so that we know what the rate of decay is. And for all the major dating techniques and apparent isotopes, those decay rates are known to within a percent or better by direct laboratory experiments.
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Q. Are there any factors which would influence the rate of decay?
A. Not that we know of. Let me qualify that. There are certain types of decay which can be affected by a very, very tiny percentage like a tenth of a percent or less in the laboratory. Theory predicts that these things should be affected very, very slightly.
So when I say the rate of decay is invariant, I mean within any limits that would affect radiometric dating.
Q. Have you written articles yourself, besides this one, which talks about the age of the earth as being approximately 4.5 to 4.6 billion years old?
A. No.
Q. Is that an area of your specialty? The age of the earth?
A. Well, the age of the earth was — the presently accepted age of the earth was made — that measurement was made some 25 years ago by Clair Patterson.
Q. Has anyone since that time done any work to either further that study or to confirm it?
A. There was a recent review of Patterson's model for the age of the earth in Carnegie Institution Yearbook in I think 1980 by Tera. I think it's referenced in there. He did a fairly careful reevaluation based on all the latest data and he came up with 4.54 billion years.
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Patterson's age I think was 4.55 or 4.56. So in 25 years it's not changed at all.
Q. All of the articles which you have written deal with some form of radiometric dating do they not?
A. Not all of them. I wrote one on the weather once.
Q. Okay. Besides that?
A. Certainly most of them, yes.
Q. And all of them do have these three factors which you-have mentioned as three requirements as part of the radiometric dating method?
A. Well, those requirements are fundamental to any radiometric dating.
Q. What would be the effect if the rate of decay or radioactivity was, in fact, not constant?
A. Do you mean what would be the effect on the results that we have obtained?
Q. Right.
A. I think we would get chaotic and uninterpretable results. We would find that there would be no consistency in radiometric dating. We would find that the geologic time scale, instead of all the radiometric ages agreeing with the paleontologists' determination we would get random results. We would find that the age of the earth as measured by different ways would not agree. It would be chaotic. And in that sense, it's really self-checking.
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Q. What would be the effect on the presently accepted age of the earth of 4.5 to 4.6 billion years if the rate of decay is not constant?
A. It depends on how much you want it to change?
Q. Well, I don't necessarily want it to change any. I'm asking what effect it would have.
A. Well, the effect is the function of the decay constant. I mean if you want to change the decay constant by one percent, then, that will have a proportionate effect.
But if you want to get the age of the earth down to 10,000 years, then you have to change the decay constant by many, many orders of magnitude. Factors of thousands and thousands.
Q. What if the rate of the decay simply has not been constant?
A. Do you mean if it varies?
Q. If it had varied at some point, it just simply had not been constant throughout the history of this planet.
A. Well, there again, if it has been varying by plus or minus one percent around the mean for the last 4® billion years, then the basic effect would be nil. If it's varied by thousands of percent at random times, then the effect would be unpredictable.
Q. If there had been or if there were a worldwide flood
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several thousand years ago or more, would that have any effect on the dating methods?
A. No.
Q. How do you date fossils?
A. Well, fossils are datable because certain types of igneous rocks occur either below or above or intermixed with or they may crosscut sedimentary rocks that contain the fossils. There are virtually no dating techniques that work well on sediments with a couple of minor exceptions. But for radiometric dating purposes, sediments are kind of garbage piles. They're pieces of other rocks that have been thrown into the sea or lakes or rivers. So we have to get a rock that we can date in juxtaposition with a sedimentary bed that contains fossils. And we have to know what that relationship is.
In fact, these were the kinds of experiments that were done to check the geological time scale when radiometric dating techniques became available.
Q. I'm sorry. What was that last statement again?
A. I said these are the types of experiments that were done to check the geological time scale when radiometric dating techniques became available. It was one of the first problems that was attacked was the age of the geologic time scale and all of its parts.
Q. Can you date fossils by taking the fossil out and
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subjecting it to these tests or any other tests that you're aware of?
A. There are some kinds of techniques for dating very young fossils that work sometimes. These include amino acid racemization, which is not a radiometric dating technique, and some of uranium thorium disequilibrium techniques. But they only work on things over the last few hundred thousand years and they often work poorly. Scientists use them because there's nothing else to use. But there are very few circumstances in which a fossil can be dated directly because of the types of rocks in which they occur in and the types of the fossils.
Q. Since fossils are normally found in sediment, if there had been a world wide flood would that have affected where they would be found and then where these igneous would be and then the resulting age which you could determine? Would it affect the accuracy of that at all?
A. Well, I'm not quite sure I understand the question. But if the creationists were right and that all the sedimentary rocks were deposited by a great flood within a period of about a year, then the geologic column would be chaotic. And in fact, we should get the same age for all sedimentary rocks.
I thought you said you really can't date sedimentary rocks?
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A. We can date them when we find an igneous rock whose relationship to the sedimentary rock is known. There are lots of circumstances in which that happens. That's how the geologic time scales, the various geologic time scales have been dated. Those circumstances are still true. So what I'm saying is if the creationists were right, then all of the dates on the geologic time scale should be the same. And in fact, with our radiometric dating techniques, a very long half life should get zero because we can't — with things like potassium/argon or Rubidium/strontium you can't measure ages of a few thousand years. So we should effectively get zero for everything dated in the geologic column. We almost never get zero except on historic things.
Q. Well, you said — when you say we should get zero, is that based on the assumption that if there was a flood it occurred approximately 7,000 years ago?
A. Yes, that's based on the assumption that — I think I said if the creationists were right and such a flood occurred and, although I didn't say it as part of that, but that it had occurred very recently
Q. What if there was a flood long — a longer time period — longer ago than 7,000, would that still be true?
A. Well, if the flood was — took place 100 million years ago, then we should get an age of 100 million years
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for all of the rocks that are related to the geologic time scale. If it was 50 million years ago, then all of those rocks should give us 50 million years ago. And in fact they don't.
Q. Without telling me what was contained in your letters, could you describe the letters that you have written to the attorneys in this case?
A. Well, they were basically just letters of transmittal of requests for papers and information. I don't know how to describe them in general any more than that.
Q. What about notes that you have written? Anything else?
A. Well, what do you mean notes?
Q. Well, one of the categories of documents which your lawyer — not your lawyer, but Mr. Wolfe has mentioned was letters and notes from you to Bruce Ennis and to himself.
MR. WOLFE: Perhaps I can clarify this. The distinction between letter and note mean this. One of these documents was typed on stationery and I call that a letter. A couple of them were written by hand on memo size sheets of paper and I call those notes as opposed to letters.
A. It would be things like, "Here is the information requested by the Attorney General's office in Arkansas covering correspondence relating to evolution." Those
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are the sorts of things they were, I believe.
Q. Have you written and said to the attorneys for the Plaintiffs any sort of explanation of radiometric dating and the age of the earth, your area of expertise, other than this document, Exhibit #6?
A. This is the only one that involved radiometric dating. I can't think of any.
Q. The witness list which the Plaintiffs filed in this case states that you are going to testify concerning evidence relevant to the age of the earth, relevance of geology to evolution and creation-science, catastrophism and your reasons for opposing the teaching of creation- science. Do you know at this point what opinions you're going to be giving concerning the relevance of geology to evolution and creation science?
A. It will depend on the questions, and I don't know what those will be.
Q. Well, you have seen a set of proposed questions and answers based on that, do you know what opinions or answers you will be giving?
A. I was handed that list last night and I've not looked at it. So yes, I've seen it I've not read it. I stuck it in my suitcase.
MR. WOLFE: I would be happy to add that the list — I'm sorry. The description of the
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testimony, I don't know the date of it but it's a couple of months old now. And I would say that the present expectation is that Dr. Dalrymple's testimony will be more narrowly confined than is that description, specifically to geochronology and the age of the earth. At least I can represent that as my present state of knowledge and expectations.
MR. WILLIAMS: So to the extent of your present knowledge, Dr. Dalrymple will not be discussing generally the relevance of geology to evolution and creation-science, catastrophism or his reasons for opposing the teaching of creation-science?
MR. WOLFE: Well, there may well be some testimony about the — his reasons for opposing the teaching of creation-science. And we've discussed that here today. And to the extent that geochronology is the relevance of geology to catastrophism or to creation-science. That is, I don't expect that Dr. Dalrymple will give testimony about the fossil records, for instance, except as he has today. That is that he knows something about dating fossils. I think that the things we talked about today are an accurate picture of the things that we would expect that Dr. Dalrymple will talk about at the trial.
Q. Dr. Dalrymple, let me be sure that I understand.
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Could you define for me what the term "geochronology" means?
A. Oh, age measurements on rocks of the earth. And that's usually extended to include the moon and meteorites, objects within the solar system, objects that are accessible to us.
Q. What's your opinion of the publication by Slusher on the critique of radiometric dating?
A. Well, I don't think it's a very good critique of radiometric dating. It's not balanced and it's unscientific.
Q. Are you aware of scientists — let's for convenience sake take creation-scientists out of this question and place them over here and not consider them. Are you aware of scientists who you would consider to be a scientist who do not agree with your view of the accuracy of radiometric dating methods?
A. I don't know of any. I might disagree with some of my colleagues over whether the errors are 2% or 3%. I'm not talking about that kind of disagreement. I'm talking about the kind of disagreement that the creationists propose.
Q. I'm not talking about necessarily the agreement of whether the earth is 10,000 or 4.6 billion years. I'm talking about who question the validity and the accuracy of the radiometric dating method.
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A. I don't know of any scientists who do that now. All the earth scientists that I know or know of through their writings accept the general accuracy of radiometric dating. I don't mean that they don't look critical at each individual result. Everybody does. But as a general tool, its accuracy and its utility is accepted.
Q. What is your opinion of the article written by Akridge which you read on the Faraday-disc dynamo angeomagnetism?
A. Well, I think that paper involves a "straw man". That paper sets up a "straw man" which has no meaning.
Q. How so?
A. Well, first place, Akridge claims that the Faraday- disc dynamo has been advanced to explain the earth's magnetic field and that's not true. I don't know of any scientists dealing with the magnetic field that's ever said the Faraday-disc dynamo is a reasonable model for the earth's magnetic field.
Second, he claims that the Faraday-disc dynamo will not reverse polarity and that's not true either. There are mathematical models which demonstrate conclusively that the Faraday-disc model can, under certain conditions, reverse polarity. The reason I say it's a "straw man" is because nobody really seriously considers that dynamo model as a
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realistic model for the earth's magnetic field. The reason scientists work on Faraday-disc dynamos and similar disc dynamos is because dynamo theory is extraordinarily complex and you have to start with the simplest kinds of dynamos and understand the mathematics of those before you can go on to the more complicated ones.
Q. What is this Critique of the Principle Uniformity by M. King Hubbert?
A. That's a summary of the history and current thinking about the usage of the word "uniformity" and the principle of uniformity. It's a very scholarly review.
Q. What are the conclusions as you recall of the article if there are any?
A. Well, it's — I guess the conclusions are that the historical usage of uniformity has varied and some of the definitions are not now acceptable. Probably were not terribly reasonable when they were advanced and that uniformity now means only two things. One, that natural laws are variant with time and two that supernatural agents are not an acceptable explanation for any part of the physical world.
Q. Is this where you derived your definition of uniformitarianism?
A. Yes.
Q. In this article Hubbert says — speaks of the
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limitations imposed by the law of Thermodynamics. Are you aware of what he is talking of there as it relates to uniformity?
A. I'd have to see the context.
Q. I'm looking at close to the end of the article and just ran across that.
A. I'm not sure what he means by that. It may be that if I were to reread the entire article, that would — but just taking that one paragraph, I'm not sure what he means.
Q. He later says, "A major part of this emancipation" referring to an emancipation from the assumptions of special creation, by divine providence. Again, "a major part of this emancipation has been accomplished by the employment of the principle of uniformity. But this rests upon insecure grounds due, in large part, to its having been formulated in ignorance of the later developed laws of thermodynamics."
A. May I look at that?
Q. Certainly.
A. Which paragraph is that?
Q. Right there.
A. I think in that sentence he's talking about the principle uniformity in its historical connotation. Uniformity is really not a term we use very much anymore because it lost virtually all of its original meaning.
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That is that the rates are constant rates of geological processes were constant. Things like the second law of thermodynamics tells you that ultimately systems run down. I would guess that's what he's talking about there. See, what he's basically saying is that if you have to define uniformity today, you must define it simply in terms of constancy of physical laws and its corollary of not allowing supernatural explanation. And that is really a principle that doesn't need a name.
Also, I think there's been such confusion because of the historical context of uniformity that it would be better to do without the name entirely.
Q. Do you generally agree with this paper?
A. I think it's a very scholarly review, yes.
Q. Are you familiar with the laws of thermodynamics?
A. Yes.
Q. You are aware then, no doubt, that's one of the things some creation scientists have relied on in trying to say that creation-science is as reliable or more reliable than evolution, that the second law of thermodynamics dictates that there will be increasing entropy?
A. Yes, I'm aware of that argument.
Q. What is your response to that argument?
A. That argument is incorrect. It's a misinterpretation of the second law of thermodynamics.
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Q. Could you tell me why you feel that way?
A. Yes. The second law of thermodynamics says that heat will not, of itself, flow from a colder body to a hotter body. There's a mathematical expression of that, but that's the most concise best definition of that. A corollary of that is that in any isolated system, the entropy or degree of randomness of a system must increase. That is it must become more disordered. But the fact is that the earth, and biological systems are not isolated systems. That is you can reverse entropy as long as you're willing to put energy into the system. And if that were not true, we would not have automobiles and ice cubes. And the creationists claim that evolution violates the second law of thermodynamics is simply wrong because biological systems are open, they receive energy, they are not isolated.
Q. Well, the example you mentioned that we wouldn't have automobiles. That goes a step further, I think, of what some of the creation-scientists have said that there you have a mechanism to convert the energy into something else. In this case, taking gasoline and converting it into power. Is there a mechanism for converting the energy in the earth as a whole into order? To increasing order?
A. When you're talking about the earth as a whole you're
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talking about an extremely large system. And I think you need to define it a little more narrowly than that. There certainly must be a mechanism for creating energy into order in the human body, for example. That's why we eat. We start as a single cell and we grow because we're given energy in the form of food. So there are mechanisms to do that. There are also mechanisms to order rocks, for example. You can take a sedimentary rock which is a garbage pile of particles from all kinds of rocks, essentially a highly disordered rock, and by applying heat and pressure — in other words, energy — you can convert that into a highly organized rock like a lava flow or like a granite.
So as long as you're willing to put some energy into your subsystem, the entropy is allowed to increase.
Q. Well, is there or is there not a need for a mechanism to convert the energy into order?
A. Well, there has to be some procedure for doing that, yes. You have to get the energy into the system. Let's take a short break.
[Short break.]
BY MR. WILLIAMS:
Q. You have with you an article by Melvin Cook on the Creation Research — excuse me. Radiological Dating and Some Pertinent Applications of Historical Interest,
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Do Radiological Clocks Need Repair. Do you intend to rely upon this in your testimony?
A. I have no present plans to do that. There again, I don't know what the questions specifically are going to be.
Q. Well, do you have an opinion as to this article? Have you read it?
A. I read that article many months ago. I think I would put it in the same class as Slusher's article about which you asked me earlier.
Q. That being?
A. It's a rather unscholarly critique of certain aspects of radiometric dating. There are numerous errors and serious scientific mistakes in it.
Q. Mark this as Exhibit #11.
[Thereupon State's Exhibit #11 was marked for the record.]
I show you Exhibit #11 to your deposition which is an article entitled "A Response to Creationism Evolves" from the November 6, 1981 "Science" magazine.
A. Uh-huh.
Q. How did you come to have a copy of that?
A. One of my colleagues copied it out for me. He saw it in Science magazine and made a copy of it for me. That was in that package simply because I had thrown it in there
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of things to read.
Q. Have you read this?
A. I read through it, yes.
Q. Are you going to have any involvement in writing a handy-dandy creationism refuter?
A. I have no plans to do that and I've not been approached.
Q. The response which is discussed in here, have you been any part of this, either directly or indirectly, yourself?
A. I think there were two groups. That National Academy and the National Association of Biology Teachers. I have no affiliation with either group and I was not involved in the issues reported there. I read that strictly for interest.
Q. And you have an article in here from the "Annual Review of Nuclear Science" on Perturbation of Nuclear Decay Rates by Emory?
A. Yes.
Q. Why do you have a copy of this article?
A. That's another review article on the state of scientific knowledge as of 1972 concerning whether or not decay rates change. What the experimental evidence is and what the theoretical evidence is.
Q. What is the conclusion that this article reaches
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if you recall?
A. It concludes that alpha and beta rates, theoretically, should not be changed in experiments. They have never been changed in the laboratory. It concluded that the electron capture, theoretically, should be changeable by a minute percentage, and in fact, small changes up to a tenth of a percent have been found, but no larger. It concludes basically that the theory and experimental evidence are in good agreement.
Q. I have another file here that you've given me which is entitled "the Woodmorappe Paper" that contains several articles.
A. Yes.
Q. What — first of all, why are all of these in something entitled the Woodmorappe paper?
A. Well, I was given a copy of a paper from a Creation Research Society Quarterly by Mr. Wolfe and Mr. Ennis asked to look at that and give a scientific opinion.
It has a list of some 300 and some odd wrong ages I forget how they're titled, but that's the essence of it. I went through and picked out five of the examples with which I was already familiar and had the literature at hand because some of these examples involved either myself or my immediate colleagues. I evaluated his criticism of
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each of those five examples. The information you have here are the reprints of the papers to which Woodmorappe refers for his examples.
Q. And you have, in a paper, critiqued this article by Woodmorappe which you have given to the attorneys; is that correct?
A. It's the other way around. They gave a copy to me.
MR. WOLFE: I can make this clearer perhaps. A copy of Woodmorappe's article that was a Xerox from the Creation Research Society Quarterly and on which Bruce Ennis had made notes was given to Dr. Dalrymple and he was asked to comment on the article. The reprint which was given to him and which was in the folder I have withheld as covered by work product doctrine, specifically for the fact that Bruce Ennis's comments are on the thing. The response that Dr. Dalrymple gave to us was partially oral and partially in the letter that I referred to of Bruce Ennis The folder and the other things I did not withhold because I do not regard them as covered by doctrine
MR. WILLIAMS: With respect to those documents, I'd like to request if you could, if there are portions of those letters which you feel are not covered by the work product privilege, that you excise those portions which are and turn those over to us.
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MR. WOLFE: Well, that's fair enough. I'll try to do that. I will look at the letter — there's only one letter — and I'll look at the letter and I try to — there are certainly parts of it that I don't regard as covered by work product. And I will try to mask the parts that I do so regard and send a copy of it down to you.
MR. WILLIAMS: Let's go off the record.
[Off the record discussion]
MR. WOLFE: I'm giving Mr. Williams now a three page letter dated November 23, 1981 from Dr. Dalrymple to Bruce Ennis from the second page of which I have masked two paragraphs and portions of two others which I regard as covered by the work product doctrine. I'll also add that on the second page I left the first sentence of where I began the masking to show that's it's the discussion of the paper of Woodmorappe.
BY MR. WILLIAMS:
Q. What is you opinion of the paper by Woodmorappe?
A. Well, I can only base my opinion on those five instances that I looked into in some detail. I didn't have time to go through his entire list. He either misunderstands or misrepresents the cases that he claims are anomalies.
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Q. Okay. Could you describe that in more detail why you think he either misunderstands or misinterprets?
A. Well, I went back to the original documents that he cites and, in fact, some of the things he said simply aren't true. In other cases he's not bothered to explain the reason for doing the experiment and the fact that some of them were controlled experiments to test certain types of materials under controlled conditions, He just cited the ages as anomalies.
Q. Do you know if Woodmorappe is considered one of the leading authorities as you understand it on creation- science?
A. I had never heard of him before this article. The footnote says that he studied geology and biology. It doesn't say whether he has a degree in either subject.
Q. So there were five out of the three hundred that you looked at?
A. Yes.
Q. So there were 295 that you didn't look at and have no opinion on.
A. I have no opinion on them one way or the other. I have a reasonable sampling I think.
Q. Would you mark this as #12?
[Thereupon State's Exhibit #12 was marked for the record.]
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Q. In your letter you do mention that you have enclosed a very rough draft of a paper on Barnes' magnetic field hypothesis.
A. Yes.
Q. Is this reference to this article?
A. Yes.
Q. What is the purpose of this article?
A. It's an evaluation of Barnes' claim that the magnetic field indicates that the earth is less than 10,000 years old.
Q. What is your conclusion in the article?
A. My conclusion is that Barnes doesn't know what he's talking about. He has ignored most of what is known about the magnetic field and in fact, the magnetic field cannot be used to date the earth.
Q. You say the magnetic field cannot be used to date the earth? Can't the magnetic field be used at all in dating in your professional opinion?
A. The reversal time scale has been used in some instances to tell ages under particular circumstances. But it can't be used to tell the age of the earth or to place limits on the age of the earth.
Q. How has it — can you describe how it's been appropriately used in your opinion?
A. Well, for example, we know that the last major
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reversal of the earth's magnetic field took place 730,000 years ago. And if you're studying very young rocks, you find that they are normally polarized and that confines their age to those times in the geologic past when the magnetic field has been normal. And if they have reversed polarization that tells you that those rocks are almost certainly older than 730,000 and it confines their age to those periods in the earth's past when the earth's magnetic field has been reversed.
There is a second way and that is these reversals are recorded on the sea floors. It spreads outward from mid-ocean ridges. And the ages of these magnetic stripes have been determined so that you can tell the age of a certain part of the ocean's crust if you have adequate magnetic data to match that up to the time scales. It's a similar type of matching as is done in tree rings.
Q. Do you plan to rely upon this article in your testimony?
A. If I get asked questions about Barnes' age for the earth or about the techniques he uses, possibly. But I think I have in my head everything that's in the article.
Q. Do you plan to have it published somewhere? Has it been accepted for publication?
A. No, it's a ver — yes, I do intend to have it published, but it is a very rough draft and won't be ready for review for at least another month, even for
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internal review.
Q. Would it be scientific in your opinion if a scientist, using the scientific method of inquiry, determined that it would be impossible for spontaneous generation to have occurred of the first life I'm talking about?
MR. WOLFE: I will object to the form of the question unless spontaneous generation is more fully defined.
Q. Do you know what the term "spontaneous generation" means?
A. No. You'll have to tell me more exactly what you mean.
Q. Are you aware of some of the theories concerning the origin of the first life on this planet?
A. I think you probably mean hypotheses. I'm not aware of them in detail, no.
Q. Are you aware of them in general terms, general outlines?
A. I know that people have been doing experiments to see if they could put together organic molecules from inorganic substances using electrical discharges and so forth. That's basically the extent of my knowledge.
Q. Is that part of Stanley Miller's works?
A. I don't know. You're out of my field again.
Q. Okay. Do you think it's scientific to study the origin of first life or can be scientific?
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A. If you mean creating life from inorganic substances by normal physical and natural processes, yes that's a legitimate scientific area of inquiry. In fact, as I said before, there are experiments being done on that.
Q. Uh-huh. If someone, in looking at that question of life coming from inorganic substances, concluded that it could not have happened by purely natural laws, do you think that could be scientific?
A. I don't think such a conclusion is possible. I think they might conclude that a certain mechanism was not possible, but then that would leave the way open for people to pose additional natural mechanisms. I don't know that you can categorically rule out all natural causes for something. I think that would be quite impossible.
Q. I'd like to have this marked as the next exhibit.
[Thereupon State's Exhibit #13 was marked for the record.]
Q. I show you Exhibit #13 to your deposition which is a letter from you to Robert Tyler, Deputy Attorney General, State of California. Do you recall that letter?
A. Yes.
Q. Do you recall making a comment in there that there appears to be a strong thread of conspiracy throughout the evolutionist material — creationist material?
A. Yes.
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Q. What do you mean by that?
A. I mean that the creationist literature makes rather frequent statements that evolutionists have somehow conspired to make radiometric ages and the age of the earth agree with biologists' need for long periods of time. And in fact, that's just not so.
Q. If you look at the response, particularly of late, to creation-science with like the article that we have marked as Exhibit #11 and some of the things that you're doing, the fact that you've got resolutions from Bill Mayer and all these other organizations. Looking at that objectively from someone who's not within the scientific community, would you not agree that there would appear to be some evidence that there is a concertive effort among the various disciplines of science to thwart creation- science?
A. No, that's not quite right. The conspiracy that the creationists talk about or allude to is the conspiracy of scientists to fabricate data and to misinterpret data to fit a preconceived notion. That's what they claim and that's the part that's wrong. I think what you're seeing in articles like this report in "Science" is the fact that science is getting alarmed that there is a group who are trying to get their religious views taught as a science subject. And they are very alarmed about the future of
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science in this country, and of science education if that should happen.
Q. The idea then — well, first of all, that does seem to be some sort of concerted effort.
A. It's an effort to answer the claims of the creation scientists that science is wrong. And that, incidentally, is a legitimate function of science. These articles that I've written are a legitimate function of science. When somebody comes out with an idea or ideas that are wrong, it's the obligation of other scientists to explain why they're wrong. This is commonly done in the scientific literature. So I think what you're seeing is part of the natural scientific process.
Q. Are you familiar with the "Structure of Scientific Revolutions" by Kuhn?
A. I've heard of it, but I've not read that work.
Q. So in other words, as I understand what you're saying, you see in the creationist literature a thread that evolutionists have, somehow, massaged the data or misinterpreted it so it would fit their own preconceived notions. Is that correct?
MR. WOLFE; I will object to the form of the question as ambiguous unless it's made clear that the thread you're referring to is an assertion made by creationists on occasion within the literature rather
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than one made by Dr. Dalrymple.
MR. WILLIAMS: Yes. I think that's what I'm asking and I thought that was clear.
A. Yes.
Q. Okay. And in turn as I understand your testimony from some of the other articles we have reviewed today, you see in the creationist literature a misinterpretation of data or an effort to massage the data to fit their own preconceived ideas. Is that correct?
A. Yes. It's — most of their works are gross misinterpretations of the scientific data.
[Continuation of testimony on next page.]
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Q. So, we in a sense have two groups pointing their fingers at each other saying, "You're misinterpreting the data", is that right?
A. Well, yes. Except that I — I can give you my personal example because they they like to claim that person working in geochronology somehow fabricate the data to suit the biologist's need for a long time. Personally, I don't care how old the earth is. I have no desire to have it four and a half billion years old or ten thousand years old. The biologists are just simply going to have to make do with what ever we find out I have nothing at stake whether the earth is very old or very young. It just simply doesn't matter to me.
Q. Well —
A. It probably doesn't matter that much to the biologists.
Q. You say that you have nothing at stake. If — if you have written I think you said over a hundred technical articles and all of them to some degree have been on dating methods or the dates of some particular rocks or something.
A. Uh-huh
Q. I mean if there should be shown to be a — a fundamental error in radiometric dating, your hundred articles may be fundamentally all wrong, isn't that correct
A. That's possible, yes.
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Q. So to some degree you do have an interest, a professional interest in your own reputation, in your own stature within the scientific community in seeing that what you have written remains accurate in the eyes of the scientific community?
A. No. That's not right. Science is one of the few fields in which it is all right to be wrong. You can't be wrong as a surgeon. That's got serious consequences. And it's not good to be wrong as a judge. That's got serious consequences. Scientists are often wrong and it's perfectly acceptable as long as you admit your mistakes. In fact, if I could prove if I thought there were the remotest chance that I could prove that the earth was ten thousand years old then I would start that experiment today because it would make me instantly famous. I probably would win the Nobel Prize. So I've got a lot more to gain — I would have a lot more to gain if I thought there was the outside chance of proving that the earth were less than ten thousand years old.
Q. Okay. So if you thought you could prove that you would have a lot more to gain?
A. I am compelled to find my own mistakes and I have published papers where I have admitted my mistakes I have said, "I have found this error. Here is what the new measurements indicate". But that doesn't happen often.
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Q. If you could do a — do a reverse field (sic) and say, "No. I was wrong. It's ten thousand years.", would that make you famous?
A. No. Only if I could prove it with a preponderance of evidence.
Q. I understand. But if someone could turn around and prove it was ten thousand years and you're still out here saying 4.5 billion years. What would that do to your stature as one of the leading authorities on dating?
A. It would depend on how I handle that evidence — evidence. If I evaluated that evidence and if it was really overwhelmingly in favor of the hypothesis that the earth was less than ten thousand years old, and I — and I ignored those facts then it would damage my reputation. If I objectively evaluated it and — and came to reasonable conclusions based on those facts then it would do no damage at all. You — amongst other things, I would be in very good company.
Q. My — my point I think is just the larger point of one of human nature. That — that you have to date, you know, staked your — your professional reputation and in fact your life's work to date has been on articles which talk about the age of the earth as being this many, you know, billions of years old. And if — and if you were proven wrong and you — you didn't agree with that then, then, I mean, your own stature would be — would be necessarily
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be affected, correct?
A. Well, yes. But you see the chances of that happening are so infinitesimally small that — that it's not something that you worry about. I mean — I mean if the earth blew up from internal causes tomorrow we'd all be dead. But the chances of that happening are infinitesimally small and I'm just not going to worry about it. And so as far as damage to my scientific reputation is concerned, there is simply none to be had I don't think. It's — it's a hypothetical situation which I don't think will ever come true.
Q. But because you have devoted your life's work to this area and to the validity of radiometric dating and if it should be shown with it you have something of a vested interest is really the point?
A. I really don't, no. If someone showed — showed with good evidence that there was serious problem with radiometric dating I could- I would conduct experiments to show if they were right or they were wrong. And thus I would immediately become involved with the proof that they, themselves, had put out. And if right then that would be fine. I would have helped prove it. I — I really have no vested interest in this at all. I have nothing to lose.
Q. Are you aware that Gentry has in some of his writings, later than the ones that you have read, challenged someone
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to prove him wrong?
A. I am not aware of that, no.
[Thereupon State's Exhibit #14 was marked for the record.]
Q. I am going to show you Exhibit #14 which is a letter I think by you to Deputy Attorney General Tyler?
A. Yes.
Q. Is that written in the Segraves case again?
A. Yes.
Q. In response to information that he sent you
A. Yes.
Q. Do you know how he selected what books he sent you?
A. No.
Q. Do you know whether they're representative of creation-science?
A. From — from my readings they are, yes.
Q. Now, the two notebooks that you have in front of you creation — ones labeled, "Notes on Scientific Creationism, 1981," and the second is labeled, "Notes on Scientific Creationism, II, 1981," a copy of which has been supplied to me. Could you just generally describe to me the basis — the basis on which you have developed these notebooks?
A. Well — well, these were simply notes that I took while I was reading the information that Mr. Tyler sent me in particular Notebook # I so that I could refresh my
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memory about the literature that he had sent. And Notebook # II contains some, oh, things like listings of decay constants and a few quotes out of creationist literature that make reference to the Bible and God and other things like that.
Q. Well what I'm not fully understanding, I suppose, is if you have something in here is this necessarily that you — are these always your thoughts or are these things that you may have summarized from things that you have read?
A. Well, they're some of both. Some of it is — Notebook # I is primarily just summaries of their literature, just a summary of what those books and works are about. Number II are thoughts that I have had about — about some of their statements and a few other things that I didn't like to keep in my head that I would rather refer to like decay constants and whatnot.
Q. Let me just refer you to a page I just turned to and identify and I don't even know you can look at mine if you like there where there are, I believe, a quote or a chart taken from one of Morris' books talking there about the second law of thermodynamics?
A. Yes.
Q. At the bottom you state that one, two and four that being an open system. Number two there I can read it?
A. Available energy.
Q. And number four?
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A. Conversion mechanisms.
Q. Are always present.
A. That's basically true in a general sense for systems.
Q. All right. In three you say, "In a case of evolution which is genetic, this is unnecessary that — that evolution proceeds by mutation".
A. This mutation random changes and DNA, etc., this is another general conclusion that I get from talking to some of my biologist colleagues. That's a little note to myself. That's not the sort of thing I would use in testimony because that's out of my field.
Q. Who — what biologist would you be reliant when you make that -
A. That came primarily out of conversations with Tom Jukes and Richard Dickerson.
Q. If I showed you a writing by a leading evolutionist which talked about evolution as a religion, that evolution was simply a religion. Would that be a valid ground to keep that out of the public schools? Evolution I'm talking about.
A. No. I don't think one article by any person would it would have to be balanced against everything else.
Q. Okay. What do you mean bal — balanced against everything else?
A. Well, I mean that you might get any one person to
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say almost anything. If you have one person who has a crazy idea you need to balance that against perhaps thousands of others who have different ideas.
Q. Uh-huh.
A. We don't let the future of our society be influenced always by one person's opinion. If you're talking about keeping something out of the public schools then I don't think one person's opinion should he overriding.
Q. How many should it take?
A. Well, I don't know. I would say it would kind of depend on the subject and the — and the circumstances.
Q. Do you think that the notion of a creator is an inherently religious concept?
A. Yes. I think it is.
Q. Are you aware that, in origin — in The Origin of The Species, that Darwin says, to paraphrase in the conclusion, "that there is a grandeur in this form of life with the first few forms having life breathed into them by the Creator"?
A. Yes. I think he made statements similar to that.
Q. Do you think that's an appropriate subject for study in a public school science classroom, that book?
A. As a document that's important to the history of science, yes.
Q. You don't think it's important to study the scientific
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document itself?
A. Not opinions about a creator, no.
Q. Well, I'm talking about the book itself?
A. I think that The Origins of The Species is a — is a important document for the history of science and I can't say it any better than that.
Q. You're saying that you no longer think it's a scientific document?
A. No. I'm saying it's outdated. My understanding is it's simply outdated. It's over — it's a hundred years old.
Q. Well, do you think because it talks about a creator we shouldn't be studying that in the public schools?
A. I don't think we should be studying the creator in the public schools, in science classes.
Q. Well, Darwin had a concept of the creator in The Origin of The Species.
A. And that book was not written for classroom teaching.
Q. So, should — would you be, in your personal opinion, allow that to be in the public schools classroom?
MR. WOLFE: I — I will object to the form of the question unless it's specified in what — I don't know — are you asking about Dr. Dalrymple's personal opinion as a scientist or -
MR. WILLIAMS: A scientist.
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MR. WOLFE: — citizen or educational?
MR. WILLIAMS: As a scientist.
MR. WOLFE: All right. So, it's not either a personal opinion or a scientific opinion?
MR. WILLIAMS: His opinion as a scientist.
BY THE WITNESS:
A. Well, my own feeling as a geologist is that — and Darwin is writing on biology — is that — that document is primarily for historic interest. And studied in that way I see nothing inappropriate about it at all. It's an extremely important book.
MR. WOLFE: I don't like to interrupt but I think that only another 2, 3 minutes is all that we can allow.
MR. WILLIAMS: Okay. I'm sorry.
BY MR. WILLIAMS:
Q. The notebooks were they used in drafting this document?
A. Well, partly yes. They were used as one of many sources.
Q. If some — if you were teaching a class in science and some student asked you, "how did the first life come about?" What would you tell them?
A. I would have to tell him that I didn't know.
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Q. Do you think that science can provide an answer to that question?
A. It's possible. Ask me fifty years from now and I'll have a better answer.
Q. If creation-science could be studied in a classroom without incorporating religious teachings and writings, would you still oppose it's use in the classroom?
A. I don't think that's possible.
Q. But if it could? I — I — asking you -
A. You're — you're asking me an absolutely impossible — what I think is an impossible hypothetical question and I can't simply respond to a hypothetical question that is not within the realm of possibility.
Q. I'm asking you to — to assume that it could be taught without references to religious writings and religious doctrines? Would you oppose it?
A. I would oppose it on the grounds it would still be rotten science even if you could expunge all of the — all of the religious reference from the question but I don't think you could. It would be terrible, terrible science. And I don't think we should be teaching bad science to children. It's a difficult enough subject without confusing them further.
Q. Just briefly what is this article that you received a letter from Russell Arks (sic) do you recall this?
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A. Yes.
Q. Why did he send these to you, do you know?
A. I asked for them.
Q. What is your opinion of them?
A. I think he doesn't know what he is talking about. He's — he's not a geologist and he clearly does not understand the subject about which he is writing.
Q. What is this document here, "Problems with Mixing Models"?
A. Those are simply my notes on things that are wrong with his model for isochrons which are mixing models. Just a capsule summary of some of the relevant points.
Q. I have no other questions. Thank you Dr. Dalrymple.
MR. WOLFE: I would like to put one question to Dr. Dalrymple. Doctor, Exhibit #14 is dated February 1980, is that a correct date?
DR. DALRYMPLE: Yes. Oh, no. No. That should have been 1981. It's a typographical error.
[Thereupon the taking of the above deposition was concluded at 4:14 p.m.]