Deposition of Donald E. Chittick
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION
REVEREND BILL McLEAN, et al.,)
)
Plaintiffs,)
)
vs. ) NO. LR-C-81-322
)
STATE BOARD OF EDUCATION, et )
al., )
)
Defendants.)
_____________________________)
DEPOSITION OF
DR. DONALD ERNEST CHITTICK
Wednesday, November 18, 1981
Reported by: LINDA L. CHAVEZ, CSR
Cert. #2108; and
THOMAS A. LIBATIQUE, CSR
Cert. #1550
2
I N D E X
PAGE
DEPOSITION OF DR. DONALD ERNEST CHITTICK:
Examination by Mr. Lahiff 5; 53
AFTERNOON SESSION 53
- - -
E X H I B I T S
PLAINTIFFS':
No. 1 Copy, two-page document,
Pyrenco, Inc. 20
No. 2 Copy, single-page document,
"Application Form for the
Creation Research Society" 54
No. 3 Copy, twenty-page document,
"Repossess the Lane,"
August 12-15, 1979 70
No. 4 Photocopy of document entitled
"Deep-Ocean Basalts: Inert
Gas Content and Uncertainties
in Age Dating" 96
No. 5 Photocopy of document entitled
"Argon-40: Excess in Submarine
Pillow Basalts from Kilauea
Volcano, Hawaii" 107
- - -
3
BE IT REMEMBERED that, pursuant to Notice, and on
Wednesday, the 18th day of November, 1981, commencing at
the hour of 9:00 o'clock a.m. thereof, at the law offices
of Brobeck, Phleger & Harrison, One Market Plaza, San Fran-
cisco, before me, LINDA L. CHAVEZ, a Certified Shorthand
Reporter and Notary Public in and for the State of Cali-
fornia, personally appeared
DR. DONALD ERNEST CHITTICK,
called as a witness by the plaintiffs, who, being by me
first duly sworn, was thereupon examined and testified as
hereinafter set forth.
- - -
SKADDEN, ARPS, SLATE, MEAGHER & FLOM, 919 Third Avenue,
New York, New York 10022, represented by THOMAS M. LAHIFF,
JR., and STEPHEN G. WOLFE, Attorneys at Law, appeared as
counsel on behalf of the plaintiffs.
STEVE CLARK, Attorney General, State of Arkansas,
Justice Building, Little Rock, Arkansas 72201, represented
by CALLIS L. CHILDS, Deputy Attorney General, appeared as
counsel on behalf of the defendants.
- - -
MR. CHILDS: On the record, we agreed last night that
the original deposition will be sent to Dr. Chittick and he
will make any changes he wants to on the face of the
original deposition and forward the original deposition to
our office in Little Rock, Arkansas, and you all are au-
thorized to charge that to our federal expense account and
to send a forwarding label for his use.
4
MR. LAHIFF: I would appreciate that if that could
be signed within five days --
MR. CHILDS: This will be done immediately and when
we get it in Little Rock, we will make note if any
changes have been made and take it over to Bob Cearley's
office.
MR. LAHIFF: Now, as I understand it, we are not
providing copies to you and we have offered in the past
to waive signature and sealing and all objections, except
as to form, are being reserved?
MR. CHILDS: That's true.
I didn't understand what you said about the copies.
MR. LAHIFF: As I understand it, we are not providing
you with copies.
MR. CHILDS: That was the original understanding
that the party that was initiating the deposition would
provide copies, but that apparently has gone by the boards.
MR. LAHIFF: It has.
MR. CHILDS: We are responsible for paying for our
copies and you are responsible for paying for yours.
MR. LAHIFF: That's fine.
- - -
5
DR. DONALD ERNEST CHITTICK,
being duly sworn, testified as follows:
EXAMINATION BY MR. LAHIFF:
MR. LAHIFF: Q. Dr. Chittick, have you brought any
documents with you here today?
A. Yes
Q. Could I see them, please?
Could I see the documents?
Are these all the documents that you brought with
you today?
That, and these [indicating].
Q. I would like the record to indicate that Dr.
Chittick has provided us with a spiral-bound notebook --
A. Ringed.
Q. -- ringed notebook containing pages of slides.
Could you describe what these slides are of?
A. I teach a course on creation and find that it
helps to illustrate it visually and these are some of the
slides that I use for that course.
These are the ones I thought you would be interested
in.
Q. Is there any particular theme to the slides or
do they go across a wide spectrum?
A. Wide spectrum.
MR. LAHIFF: I would like to take a short recess.
[Recess taken]
MR. LAHIFF: Q. Dr. Chittick, I would like to fill
out your curriculum vitae a little bit.
6
Could you please describe your educational background
starting with high school, please.
A. High school, Salem, Oregon; undergraduate,
Willamette University, Salem, Oregon, B.S. in chemistry;
Ph.D., Oregon State University, physical chemistry.
Q. When did you get your B.S.?
A. 1954.
Q. And when did you get your Ph.D. in physical
chemistry?
A. 1960
Q. Have you had any continuing education since
you received your Ph.D. in physical chemistry?
A. I attended a summer institute at the University
of Southern California on colloid science.
Q. Could you please describe what colloid science
is?
A. It is the science of surfaces, coatings,
paints, lubricants, et cetera.
Q. Have you obtained any other degrees?
A. No other degrees.
Q. What areas did you study when you received
your B.S. in chemistry?
A. Emphasis was in chemistry and that included
the requirements for the B.S. degree in the catalog
at that time and I don't recall all of those.
Q. Was there any particular emphasis on organic
chemistry?
A. No, we took general chemistry, organic
7
chemistry, analytical chemistry and physical chemistry
and special topics.
Q. Could you describe your course of studies to
obtain the Ph.D. in physical chemistry?
A. The course of studies included a major, a minor
and a second minor.
The major was in physical chemistry and a first
minor in physics and a second minor in mathematics.
Q. Could you please describe what physical chemis-
try is?
A. Physical chemistry is sometimes referred to
as theoretical chemistry.
It is the theory behind why the other chemistry
branches work.
Q. What do you mean by the theory behind that
explains how the other branches of chemistry work?
A. In organic chemistry, they will have an organic
physical reaction.
Physical chemistry would be an attempt to under-
stand why the reaction took place, the mechanism of the
reaction, the rate of the reaction, the kinetics, and
steps involved.
That would be it.
Q. In addition to the course in colloids, have
you had any other continuing education?
A. Well, as a teacher of science at the university
level for over twenty years, one tries to stay abreast
of the literature by attending professional meetings
8
and reading the literature and in that sense my educa-
tion has continued.
Q. Have you received any academic honors during
the course of your education?
A. Yes.
Pardon me, the last?
Q. During the course of your education.
A. Yes, in high school I got the Bausch & Lomb
Science Award.
In Oregon State I was elected to Phi Lambda Upsilon
Honorary and associate member of Sigma Xi.
Q. What is Sigma Xi?
A. Sigma Xi is the National Science Research
Honorary Association.
Q. And what has been your employment experience
since you graduated with a Ph.D. in physical chemistry
in 1960?
A. In 1958, before I had my Ph.D., while I was
writing my thesis, I received employment at the University
of Puget Sound in Tacoma in the chemistry department
and remained there until 1968 where I transferred to
George Fox College in Newberg, Oregon and remained there
until my present employment in 1979.
Q. And what is your present employment?
A. It is as a research and development person
with Pyrenco.
[Discussion off the record]
MR. LAHIFF: Q. Could you please describe for me
9
exactly what Pyrenco is?
A. Pyrenco is the business of converting biomass
waste materials into usable fuel.
Q And what position do you hold with Pyrenco?
A. Research and development.
Q. Who else is associated with Pyrenco?
A. A number of other employees.
Q. Would you be considered the president of Pyren-
co?
A. No.
No, the president of Pyrenco is Fred Beirle.
Q. And who else are officers in Pyrenco?
A. Bob Poole, Al Garwood, Jim Harvey.
There may be one or two others.
I don't remember.
Q. Who else is associated with the firm in a re-
search and development capacity?
A. I am the director of research and development
and have two assistants.
Q. And who are you assistants?
A. Steve Allemann and Jack Smith.
Q. What courses did you teach at George Fox?
A. My primary responsibility was chemistry
courses and also taught a course in creation.
Q. Exactly what chemistry courses did you teach?
A. General chemistry, quantitative analysis,
advanced and literal chemistry --
[Mr. Klasfeld enters the deposition room]
10
MR. KLASFELD: Excuse me.
[Discussion off the record]
[Mr. Klasfeld leaves the deposition room]
MR. LAHIFF: Q. I am sorry, before we were inter-
rupted, you were describing the courses at George Fox.
A. I listed general chemistry, advanced analytical
chemistry in organics and physical chemistry and selected
topics.
Q. What exactly is selected topics?
A. Selected topics is a course that is designed
for one term to meet a special instance need of a particu-
lar group of students going through at the time.
For example, it might be on the environment or on
forensic chemistry.
Q. Could you please describe your course in crea-
tion science?
A. Creation science, as taught at the college,
was a course that was taught on an every-other-year basis,
usually -- well, always in -- well, in the evening for
upper level students who had to have at least one year
in science, one of the natural sciences.
- - -
11
Q. And, what topics did you cover?
A. As listed on the syllabus that I brought for
the document.
Q. I think we will wait until we get those docu-
ments back, then we will go over the syllabus.
Do you have any other activities in addition to your
activities as director of research and development for
Pyrenco; do you act as a consultant for any other organiza-
tion?
A. No.
You mean consultant on a paid basis?
Q. On a paid basis?
A. No.
Q. Do you act as a consultant on an unpaid basis
to any organization?
A. When people telephone me and ask me questions,
I try to answer them.
Q. Do you have any kind of a permanent relation-
ship with any particular organization, whether on a
paid or unpaid basis?
A. Not on an active basis.
Q. What do you mean by not on an active basis,
do you have that relationship on an inactive basis?
A. Some people have listed my name on this
literature without my permission as a consultant.
Q. Which people have listed your name as a con-
sultant?
A. Norman Fox.
12
Q. And, who is Norman Fox?
A. He is a person who is developing a motion
picture on the creation-evolution discussion.
Q. And, what is the name of his organization?
A. I would have to go look.
I'm not sure.
I think Maranatha Productions, but I'm not certain
of that, Eugene, Oregon.
Q. And, he has listed your name without your per-
mission?
A. That's correct.
Q. What other organizations have listed your
name as a consultant?
A. Creation Science Research Center.
Q. Could you please identify that organization?
A. They are in San Diego.
Q. And, was that listing of your name as a con-
sultant without your authorization?
A. I wrote to them and asked to have my name
removed from their literature.
Q. Did you bring a copy of that letter with you?
A. No.
Q. Did you send any letters to Norman Fox asking
that your name be removed from his literature?
A. No.
Q. Do you have any relationship at all with
Creation Science Research Institute or Center, are
you a member?
13
A. No.
Q. Have you ever done any consulting work for them?
A. Not that I recall.
Q. Did you engage in any research during your
period of employment at George Fox?
A. Yes, I was working with conversion of biomass
to fuel.
Q. Did you receive any grants for that work?
A. No grants.
Q. And, how was the research funded?
A. It was funded by my own funding.
Q. Was the research associated with the university
in any way?
A. No.
MR. LAHIFF: Excuse me, could I take a brief recess.
[Recess taken]
[Record read]
THE WITNESS: By association I mean they didn't fund
it.
MR. LAHIFF: Q. I am sorry, who didn't fund it?
A. The university.
I did it on their premises.
Q. Have you received any grants to do research?
A. I received a National Science Foundation
summer grant while I was at the University of Puget
Sound to do research with high school students in photo-
chemistry.
Q. Exactly what did that involve?
14
A. It involved teaching them what basic research
is all about, and actually doing a research project in-
volved with photochemistry.
Q. What precisely was the grant for?
A. For exposing high school students to an actual,
real live research situation.
Q. Have you received any other grants?
A. No, not that I recall.
Q. What was your thesis on?
A. Kinetics of bleaching and colored KCL.
Q. What is colored KCL?
A. KCL is a potassium chloride, and we grew single
crystals, and caused a stoichiometric excess of potassium
to be present so the electron would go into the traps
in the crystal, and cause it to be colored, and then I
measured the rate of bleaching from that.
Q. Is there any practical application for that?
A. The practical application was that at that
time, and still today, solid-state electronic theory is
useful, so the normal materials are nontransparent,
whereas potassium chloride is transparent so one can look
inside and see what is going on to serve as a model for
the nontransparents.
Q. Was your thesis ever published?
A. A copy of it is in the library, if that
constitutes publication.
Q. But, it wasn't published in any scientific
journal?
15
A. That's correct.
Q. Have you ever made an application for a grant
that wasn't funded?
A. No.
Q. What do you believe to be your field of ex-
pertise?
A. My training is in physical chemistry.
Q. Have you ever published any articles dealing
with physical chemistry?
A. Yes, in connection with other authors, I
published an article in the Journal of Electrochemistry,
and I don't recall the reference right now, on oscillating
electrodes using titanium and zirconium.
Q. Is that your only publication, or do you have
others; these are publications dealing with your field
of expertise?
A. Other than patents, no.
Q. And, what are your patents?
A. In alternate fuels.
Q. Could you describe?
A. The conversion of biomass to usable fuel by
pyrolysis on which I have a patent with some claims
granted on the first device, and we have a second device
with patenting well along on it.
Q. And, what is pyrolysis?
A. Pyrolysis is a chemical reaction carried out
with the aid of heat.
Q. Could you elaborate on that a little bit for
16
me, please?
A. I am not sure of the semantic background of
the material, but some chemical reaction can be carried
out with electricity, so we call it electrolysis.
Some chemical reactions can be carried out with
the aid of heat, so we call it pyrolysis, because py
comes from heat, it means heat.
Q. Exactly what do you do as director of research
and development for Pyrenco?
A. My primary responsibility is to suggest solu-
tions to engineering problems, and to investigate further
areas of development that the company might wish to work
with related to alternate fuels.
Q. Are these research programs technical applica-
tions?
A. They are, let's see, how would we define those --
Q. Well, what do you understand by research?
A. I understand research has two thrusts:
One is applied to solve practical problems, try to
do something, say corrosion comes in, for example, so how
do you do it so you will get your process to go and avoid
the corrosion problems.
That would be a practical.
The other is fundamental research where you try to
look for new ways of doing something, you want to go from
Point A to Point B, how do you get from Point A to Point
B more efficiently, more economically with a higher yield.
Those are fundamental research, and I am involved
17
in both.
Q. Do you have any other areas of expertise in ad-
dition to physical chemistry, do you claim any expertise
in geology, paleontology, any other discipline?
A. I have studied as a physical chemist, I have
studied areas that physical chemistry relates to.
Q. And what areas does physical chemistry relate
to?
A. Chemicals reactions that would occur in, for
example, formation of fossils.
Q. Do you have any background or training in
geology?
A. I have no formal course work in geology.
Q. Do you have any background or training in
paleontology?
A. I have no formal course work in paleontology.
Q. Have you published any articles dealing with
your work at Pyrenco?
A. I have mentioned articles like the newspaper
article that you have as a document, that that research
was an offshoot of the creation model.
Q. Have you published any articles dealing with
your research at Pyrenco in publications objected to
pure review?
A. Other than patents, no.
Q. Could you explain to me why you left the
University of Puget Sound?
A. The George Fox College was wanting to institute
18
a chemistry major, and invited me down as a visiting
professor to set up a program for their evaluation, and
having done that, and having also been from Oregon, I
decided to stay.
Q. Does George Fox have any religious affiliation?
A. George Fox was Quaker, founded by the Quakers.
Q. Does it continue to have a religious affilia-
tion?
A. Yes.
Q. And does it continue to be affiliated with the
Quakers?
A. Yes.
Q. Have you ever been denied tenure?
A. No.
Q. What kinds of publications, or have you published
newspaper articles dealing with physical chemistry since
you graduated in 1960?
A. No.
Q. Did the colleges where you taught, the Univer-
sity of Puget Sound, and George Fox grant graduate degrees?
A. The University of Puget Sound granted a Master's
degree.
Q. Master's degree in what?
A. Several area, one of which was chemistry.
Q. And other areas?
A. Yes.
I don't recall what they were right now.
Q. Does George Fox grant graduate degrees?
19
A. No, George Fox is an undergraduate institution.
Q. Did you teach graduate level courses at the
University of Puget Sound?
A. Yes, I did.
Q. What grade level courses did you teach?
A. I don't recall all of them.
One of them was solid-state physics.
Q. And, what background or training to you have to
teach solid-state physics?
A. My thesis area.
Q. Do you have any formal training in physics in
addition to -- I think you said a minor when you received
your B.S.?
A. When I received my Ph.D.
Q. Your Ph.D.?
A. No.
Q. Have you published any articles dealing with
physics?
A. No.
Q. While you were employed either by the University
of Puget Sound or George Fox, did you supervise the
research of graduate students?
A. While I was at the University of Puget Sound I
did supervise graduate students.
Q. What kind of research?
A. Photochemistry.
Q. Did you supervise the research of graduate
students -- oh, there were no graduate students at George
20
Fox.
What kind of professional affiliations do you have?
A. I have those listed on my vitae.
MR. LAHIFF: Perhaps we should mark your vitae
as Exhibit 1.
[Plaintiffs' Exhibit 1, two-page
document, Pyrenco, Inc., marked
for iden.]
MR. LAHIFF: Q. I would like to ask you if you
recognize Plaintiffs' Exhibit 1 for identification, and
is that a copy of your vitae?
A. Yes.
Q. Do you belong to any other organizations other
than what are listed on your vitae?
A. Let me see it again.
Your question was, again?
Q. Do you belong to any other professional organiza-
tions other than the ones listed on your vitae?
A. No.
Q. Have you ever held an office in the American
Chemical Society?
A. A minor office.
I was the program chairman for the Northwest regional
meeting division of analytical chemistry some years back
while I was at the University of Puget Sound.
Q. And, during what period of time was this?
A. This was between '68 and -- no, between '58
and '68.
21
Q. What were you responsibilities?
A. My responsibilities were to arrange all the
details of the professional meetings, edit and accept
papers from my colleagues around the Northwest whenever
they came in, and conduct, chair the meetings.
Q. Were you part of a peer review process for
articles that were eventually published in the journal?
A. I'm not sure I understand your question.
Q. Is there a journal associated with the American
Chemical Society?
A. There are numerous journals associated with
the American Chemical Society, each of their branches.
There are many publications in this particular
situation, then I was involved with reviewing the articles
that were associated with that, that meeting.
Q. Were you ever an officer of the American Associ-
ation For The Advancement of Science?
A. No.
Q. Were you ever an officer with the New York
Academy of Sciences?
A. No.
Q. Did you ever hold an office with the Creation
Research Society?
A. No.
Q. Have you ever attended any meetings of the
Creation Research Society?
A. The Creation Research Society?
Let's see.
22
No, I have not.
Q. What do you do as a member of the Creation
Research Society?
A. I receive their publication.
Q. Do you have any activities, do you publish
in the creation --
A. I have not to date.
Q. Do you pay dues to the Creation Research Society?
A. Yes.
Q. Have you ever performed any tasks for the
Creation Research Society?
A. No.
Q. Have you ever received any academic awards?
A. Those listed.
Q. In addition to those listed on your vitae?
A. No.
Q. Have you ever presented any papers to any
meetings of any of these organizations?
A. Yes, I presented a number of papers.
Q. Of which you are a member?
A. To several professional organization, includ-
ing the American Chemical Society.
Q. Could you please indentify those papers for
me?
A. I don't recall now the dates on these.
One was to the Oregon Academy of Sciences on
oscillating electrodes, and likewise to the American
Chemical Society, and another paper to the American
23
Chemical Society on program instruction.
Q. Does the Creation Research Society have a
publication associated with it?
A. Yes, Creation Research Society Quarterly.
Q. Have you ever published in that?
A. No.
Q. Have you ever had any adjunct teaching posi-
tions?
A. How would you --
Q. Have you ever been an adjunct member of a
faculty or university or college in addition to the ones
listed on your vitae?
A. Yes, I taught creation at two places.
One was a summer school course which you have the
syllabus for in the deposition at Western Evangelical,
Western Baptist Evangelical Seminary, and I have taught
a number times in the evening school at Multmoma School
of the Bible.
Q. What kinds of courses have you taught?
A. They asked me to teach the Bible and earth
history.
Q. Have you ever taught any seminars?
A. Yes.
Q. Could you please describe them for me?
A. I presented a number of seminars for universi-
ties in various locations on the topic of origins.
Q. In which universities have you presented
seminars?
24
A. I don't recall all the universities that I
have presented seminars.
They include Oregon College of Education, Oregon
State University, Evergreen State College, and there
were six universities in New Zealand, there was one
university in Peru, Lima, Peru, and some others, I don't
recall.
It has been over a period of years.
Q. And you have taught seminars on origins at
all these universities?
A. Yes.
Q. Are you a member of the Creation Research
Society?
A. I am.
Q. Are you a member of the Institute for Creation
Research?
A. No.
Q. Are you a member of the Creation Science Re-
search Center?
A. No.
Q. Are you a member of the Bible Science Associa-
tion?
A. I am.
Q. Are you a member of Citizens for Fairness in
Education?
A. No.
Q. Are you a member of Citizens for Balanced Educa-
tin as to Origin?
25
A. No.
Q. Have you ever held any office in the Bible
Science Association?
A. No.
Q. Turning back to the seminars that you have
taught, which departments sponsored these seminars at
these respective universities?
A. Normally it was the chemistry departments,
but in some cases it was the science department in general
as for example at OCE, Oregon College of Education.
Q. Has the religion or theology department ever
sponsored any of these seminars which you have taught?
A. Last spring the Clackamas Department of Region
and Philosophy invited me to present seminars, and you
have that in the deposition
Q. Any other religion or theology departments?
A. Yes, I think there was another one at a school
in the Midwest, and I don't recall the details now.
Q. What is your religious affiliation?
A. I am a member of the Newberg Friends Church.
Q. And, what religious denomination is that?
A. Quaker.
Q. Do you hold any office in the church?
A. I am presently on the board of elders.
Q. And, do you attend church regularly?
A. Yes.
Q. Do you belong to any church groups?
A. What would be called a church group?
26
Q. Well, do you belong to any groups or organiza-
tions sponsored by the Newberg Friends Church, or any
other church?
A. No.
Q. Do you consider yourself a fundamentalist?
A. What would be a fundamentalist?
Q. Do you consider yourself a biblical literalist?
A. Well, fundamentalist as it is used is a radical,
emotional, more than logical thinking individual.
I would not classify myself that way.
Q. Do you consider yourself a biblical literalist?
A. What would be a biblical literalist?
Q. Do you believe the Bible is a literal account
of the creation of the universe, and that it represents
historical truth rather than religious myth?
A. My personal opinion is that that would be
correct.
Q. What would be correct?
A. That the Genesis account is an accurate histori-
cal record.
Q. Do you have a personal religious counselor or
adviser?
A. No.
Q. Have you ever read the Bible?
A. Yes.
Q. How often do you read the Bible?
A. I read portions of it.
I don't know how often I go clear through.
27
I read portions of it daily.
Q. Do you as a physical chemist ever consult the
Bible?
A. For physical chemistry, no.
Q. Do you consider the Bible to be a source of
personal revelation?
A. Let me back up on this.
Do I consult as a physical chemist.
I feel that any source that bears on my discipline
is worth looking at academically.
There may be situations that would bear on my
discipline there, and I wouldn't want to rule them out.
Q. Have you ever consulted the Bible for your
discipline?
A. In the sense that it mentions, for example,
alloys, I have been curious about the early alloys.
- - -
28
Q. What do you mean about the early alloys?
A. For example, the Bronze Age.
Q. What do you mean by "For example, the Bronze
Age"?
A. Bronze is an alloy that is mentioned in Genesis.
Q. How have you used the Bible as a research tool
with respect to bronze alloys?
A. That gives an early date for the alloying of
metals to make bronze, so I was curious about the chemical
and physical qualities of early bronze.
Q. Is there any description of the chemical and
physical properties in the Bible?
A. Not that I am aware.
Q. Does the Bible predict future events?
A. My personal opinion is that it does.
Q. What events has it predicted?
A. What events has it predicted?
Q. Already.
A. Already predicted?
Q. Already predicted.
A. It has already predicted the downfall, I
suppose, of civilizations that have departed from some of
the precepts that are mentioned there.
Q. Could you be a little more specific, which
civilization has it preducted the downfall of?
A. Well, as I am aware, and, again, this is not an
area -- history is not an area of my specialty, but I have
been interested in the writings of those who have written
29
on the subject relating to the four empires mentioned in
Daniel, Book of Daniel, for example.
Q. And what are the four empires?
A. Let's see. Babylonian, the Medeal Persian, the
Grecian and the Roman.
Q. And the Bible specifically refers to the down-
fall of those four empires?
A. As I understand it.
Q. Has the Bible ever been an inspiration for any
research project that you have undertaken?
A. Indirectly, perhaps. The Creation model inter-
ested me and scientists who had written on the Creation
model talked about things that would get me started
thinking about formation of fossil fuels and lead to the
research that I am presently engaged with.
Q. But has the Bible itself ever provided you with
a specific project to investigate, for example?
A. We did some -- one of the students that was at
George Fox College needed a senior thesis and Genesis
mentioned a geological event known as the flood and it
occurred to me that if that water had been receding, then
there ought to be water recessional lines.
There are terraces located very broadly, notably up
in the Northwest. I suggested to the student that he do
a research project asking geologists and investigating
and doing research on those terrace line formations.
Q. Did a paper ever come out of that research?
A. Research paper made and went into the library at
30
George Fox College, is the requirement for that study.
Q. Was it ever published in any journal?
A. Not that I am aware.
Q. Does the Bible suggest methods of investigation?
A. How do you mean that?
Q. Well, what do you think I mean by methods of
investigation? Methods of scientific research.
A. Methods of scientific research come to creative
people, it seems to me, ideas come in and you want to go
from point A to point B and these ideas come and you
begin to think about a problem, and it is very possible
that some of those suggestions came from study of
Genesis.
Q. But has the Bible itself ever suggested a
methodology for your research?
A. Methodology to such and so on in a certain way?
Q. Yes.
A. Not that I am aware.
Q. Have you had any contact with the Attorney
General prior to today about your testimony?
A. The Arkansas office of the Attorney General
telephoned me some time back, a week or so or two weeks,
I am not sure how long ago, and inquired about my willing-
ness to be involved.
Q. Did they discuss any specific topics about what
you would be testifying?
A. I don't recall that they did.
Q. Do you remember the individual at the Attorney
31
General's Office that you had the contact with?
A. You told me his name last night. I should
remember.
MR. CHILDS: Mr. Campbell, I believe.
THE WITNESS: Rick Campbell, thank you. Rick
Campbell.
MR. LAHIFF: Q. Did you have any other discussions
with Mr. Campbell or with anyone else from the Attorney
General's Office regarding your testimony?
A. Prior to today?
Q. Prior to today.
A. Last evening we discussed what a deposition is,
what our time frame was when my plane would leave.
Q. But did you have any discussion of the substance
of your testimony?
A. What I would say?
Q. Those areas that you would testify about.
A. He suggested to me that I testify in my area.
Q. And what is your area?
A. Physical chemistry.
Q. Have you had any discussions with anyone from
the Attorney General's Office about your testimony during
the trial of McLean vs. Arkansas?
A. No, not that I recall.
Q. Have you had any contact with any Creation
Science groups regarding your testimony here today?
A. No.
Q. Have you had any contact with any Creation
32
Science groups regarding your testimony during the trial
of McLean vs. Arkansas?
A. No.
Q. Had anyone from any Creation Science group
sought to recruit you to testify?
A. Wendell Bird inquired whether I would be willing
and you have his letter to me.
Q. And when did Mr. Bird write to you?
A. I don't know. The date is on the letter.
Q. Did you respond to Mr. Bird?
A. Yes.
Q. What was you response?
A. Affirmative.
Q. And when was that?
A. I don't recall that.
Q. Did Mr. Bird discuss with you your testimony?
A. No.
Q. Did Mr. Bird suggest any areas in which you
could testify?
A. No.
Q. Did you suggest any areas to Mr. Bird?
A. I may have. I don't recall. It seems like I
did suggest that I was a physical chemist.
Q. Have you had any contact with an individual by
the name of John Whitehead?
A. I may have seen him somewhere. It may have been
at one of the meetings that I was. I do not recall that.
I do not know the gentleman.
23
Q. Have you ever testified prior to today in any
court proceeding?
A. No.
Q. In any legislative proceeding?
A. Yes, the Washington House of Representatives
invited me to testify last spring.
Q. And what did they invite you to testify about?
A. The Creation model, scientific Creation model.
Q. Do you happen to know if there is a transcript
available of your testimony?
A. I don't, no.
Q. What was the substance of your testimony?
A. The substance of my testimony -- How detailed
do you need?
Q. Well, as detailed as you can give me.
A. I was there -- I was testifying for about 30
minutes, as I recall, and used some of the visual
materials that I have at the present, showing that there
are two models currently being talked about in the
scientific community and gave a little bit of scientific
background, why I had become interested in the topic of
origins, and some of my discussions with my colleagues
relating to that and then some of the evidences that
seemed appropriate.
Q. What was this legislative proceeding being held
in connection with?
A. As I recall, there was a legislator, a woman, I
believe -- I'm not sure -- from the Spokane area district
34
-- who had introduced a bill requiring balanced or asking
for balanced treatment, and I didn't have the bill. So I
am not sure of the content of it.
Q. You didn't have the bill before you testified?
A. That's correct. That morning, when I arrived,
I quickly went over the bill before the testimony, but
just five minutes.
Q. You were testifying in favor of the bill?
A. I was testifying in favor of the Creation model.
Q. Are you familiar with the Arkansas statute
that is the focus of this lawsuit?
A. This morning I was presented with a copy at
breakfast which I quickly went over. So I have glanced
over it. I would not say that I am familiar with it.
Q. Who presented you with a copy?
A. David Campbell, I think.
MR. CHILDS: Williams.
THE WITNESS: David Williams. I am sorry.
MR. LAHIFF: Q. Had you seen a copy of this statute
prior to today?
A. No.
Q. Were you aware of its existence prior to today?
A. Yes, the Arkansas Attorney General's Office,
on the telephone, said there was such a document.
Q. Prior to being informed by the Arkansas
Attorney General, were you aware of the existence of this
statute?
A. No -- yes, I heard a news comment about it. I
35
don't know when.
Q. Have you ever participated in any debates deal-
ing with Creation Science?
A. Yes.
Q. Could you tell me when those debates were?
A. It was not a formal debate. It was more of a
forum. One was this last spring at the Clackamas
Community College and you have a copy of that correspond-
ence.
Q. Any other debates?
A. Again, a forum type with the pro and con sides
represented, the National Science Teachers Association in
Portland, Oregon, and you have that letter and document.
Q. I am sorry, the National Science --
A. Teachers Association.
Q. Any other forum?
A. Yes, I was invited to Holland in '78 -- '77 or
'78 -- late '70s for a debate.
Q. And who sponsored that?
A. Evangelische Omroep.
Q. Were you paid for any of your appearances at
any of these forums?
A. My expenses were covered and it seems like I
may have received a small honorarium in addition.
Q. From which organization?
A. From Clackamas Community College and from the
Holland group.
Q. Do you recall what that honorarium was?
36
A. It is stated in the paper. I don't recall the
figure.
Q. Do you know if there are any transcripts availa-
ble from any of these forms?
A. The proceedings of the Holland debate were
published in booklet form in Dutch.
Q. Do you happen to have a copy of it?
A. At the house.
Q. Do you know if it is available in English
translation?
A. I don't know that.
Q. Who sponsored the forum at Clackamas Community
College?
A. The Philosophy-Religion Department.
Q. And what was the substance of your discussion
or your participation during the forum?
A. The forum lasted for three evenings with a
Creation model proponent and an Evolution model proponent
each evening. The final evening was a panel, sort of an
informal debate interacting between the members of the
panel and/or any question from the audience directed to
any panel member.
Q. Who were the members of the panel?
A. I believe -- I don't recall. That's in the
deposition -- the announcement. Mark Feldman is a man
from Portland State University who is in paleontology, I
believe, and a geologist and I don't recall his name
now. And there was a fellow from -- a geologist, also,
37
from Whitworth College in Spokane. There were four of
us.
Q. On which side did you argue?
A. The creation side. The others were for the
Evolution model.
Q. Who was in support of the creation side?
A. Just me.
Q. What was the structure of the forum at the
National Science Teachers Association?
A. The structure was that each of us, Dr. Stearns
-- and I forget his first name, now -- from Reed College,
whose specialty was evolution -- presented the Evolution
model and then I presented the Creation model and then
we both were present for questions from the audience.
It seems like it was Steven Stearns, but don't quote
me on that.
Q. Did anyone else participate in that forum?
A. As main people other than the audience?
Q. Other than the audience?
A. No.
Q. And what was the structure of the forum in
Holland? I won't attempt to pronounce it.
A. In Holland there were six people involved in
addition to the moderator. There was a pro and con
astronomer, a pro and con paleontologist or fossil record
discussion and a pro and con geology area.
Q. And who were the participants?
A. I do not recall the Dutch participants. The
38
Americans were Dr. Harold Slusher, Dr. Duane Gish and
myself. And they had asked me specifically to speak on
the age of the earth and to write a paper. We each had
to do that, make our presentation and send it to them a
month ahead of time, so that they could be prepared to
rebut or ask questions on it and that was then translated
into Dutch.
Q. Did you bring a copy of your paper with you
here today?
A. Yes, I did.
Q. How did you first come to hear about this case?
A. In the news media.
Q. Are you being paid for your testimony?
A. No.
- - -
39
Q. Have you discussed the specifics of your
testimony to be given at the trial with the Attorney
General?
A. No.
Q. Have you discussed the specifics of your testi-
money to be given at trial with anyone?
A. Specifics, other that it is going to be on the
topic "Origins" and -- you mean details?
Q. Details of what you are going to be testifying
to.
A. No.
Q. Has anyone suggested a discipline or an area
as to what you should testify?
A. I suggested when asked what my area was,
physical chemistry.
Q. Do you what your testimony will be?
A. It will be similar to those seminars that I
have given elsewhere.
Q. Well, what will your testimony be?
A. I haven't worked it all out.
Q. Well, have you thought about what your testimony
would be?
A. Oh, ,yes, of course.
Q. What have you thought you might testify about
or what are you considering testifying about?
A. I thought about -- I don't know how much time
we will have, how much is proper.
But suppose I had an idea --
40
MR. CHILDS: You mean at the trial?
THE WITNESS: Yes.
MR. CHILDS: I am sorry.
Go ahead.
I am sorry.
THE WITNESS: If I had an idea of the amount of time
which would be like I present -- obviously it is a very
broad subject.
You could spend a lot of time on it but I suspected
that time is going to be critical and important. It is to
me. I presume to others.
So if I were to condense it down to, say, a forty-
five-minute period or less, a condensed version, I would
like to present a little bit of my own background and
how I got interested in the topic; what I have learned by
talking with my colleagues who are in both camps and some
of the evidence that I looked at that convinced me the
creation model had a lot going for it.
Q. Well, what will you be testifying about with
respect to physical chemistry which is your field of
expertise?
A. Physical chemistry is kind of king of sciences,
in my judgment, my personal opinion.
It relates to the chemistry behind fossil formation,
for example.
Q. In addition to fossil formation, what does it
relate to?
A. Isotope ratios, chemical processes involved with
41
earth history.
Q. Such as?
A. Fossil fuel formation.
Q. Anything else?
A. Not that immediately comes to mind.
Q. Do you consider yourself to be a creation
scientist?
A. Yes.
Q. Why?
A. I haven't always been a creation scientist
and --
Q. At what point did you become a creation sci-
entist?
A. After I finished my Ph.D. training.
Q. What happened at that point to lead you to be-
come a creation scientist?
A. I began to become a ware of the discussion
creation science/evolution science as models for origins
and I found it fascinated me and very fascinating to study
and to discuss and being in the educational field, being
people would ask me questions, I found that they were in-
terested as well.
And as a result of being asked questions, many of
which I found interesting, also, I began to study what
scientific evidence was available, not only in my own
discipline but from writings of others and from that
study became a creation scientist.
Q. Could you define creation science for me as you
42
practice it?
A. Creation science, as I practice it, is looking
at the scientific data from the point of view that
origin was by creation.
Q. Any specific scientific data?
A. I mentioned fossil fuel formation.
Q. Well, is there any specific scientific data
that led you to become a creation scientist?
A. Among the data that I considered were the order-
liness of the universe.
It appeared to be one of law and order.
The geophysical, geochemical processes seemed to go
against the idea that they were requiring or had occurred
over long period of time and just geochemical processes.
Q. Any other scientific data?
A. As I practiced it or that I was reading in con-
nection with other--
Q. That led to your belief or to your acceptance
of creation science.
A. While I am not a paleontologist, the fossil
record did not seem to support slow, gradual change over
vast periods of time by the writings of other people who
were interested in the topic.
Q. Is there any other scientific data that you
could point to?
A. The fossil record, geophysical processes,
geophysical-geochemical processes, orderliness in the
universe and the writings of biochemists who looked at
43
life processes.
Q. Was the Bible a piece of scientific evidence
that led to your adoption or acceptance of creation
science?
A. I don't recall any particular point there that
convinced me.
It was primarily the fields that I have mentioned
for you.
Q. Did you consult the Bible at all during this
process of researching?
A. I would consult it to see if statements people
would make that were contained therein were true.
If it mentioned there was bronze mentioned early, I
would check to see if that was true.
Q. In other words, you used the Bible as a source
of scientific information?
A. Where Genesis talked about those points that
science could investigate, where it talked about places
and times, locations, yes.
Q. Did any particular event precipitate or act
as a significant cause in your becoming a creation sci-
entist?
A. Many discussions.
Q. But was there a particular event?
A. Not that I recall.
Q. Did any particular person precipitate or act
as a significant cause in your becoming a creation
scientist?
44
A. A single individual?
Q. A single individual or several individuals.
Are there any individuals to whom you would point as
saying they were a significant cause in my becoming a
creation scientist?
A. Well, there were many people who were patient
with me as I was asking questions.
My colleagues in my departments.
Q. But did any of these people lead to your ques-
tioning?
A. Not that I recall.
Q. Do you consider your becoming a creation sci-
entist a religious experience?
A. No.
Q. Turning back to the data that formed the basis
for your acceptance of creation science, what do you mean
by the orderliness of the universe?
A. Orderliness, particularly from a physical-chemi-
cal chemistry point of view, because physical chemistry
attempts to describe in terms of mathematical equations,
insofar as possible, the events that occur. These are
predictable and do not seem to be random or haphazard.
Q. And how did that lead you to accept creation
science?
A. It led me to ask the question, which origin
model would tend to predict an orderly world study.
Q. And how doesn't the evolution model predict an
45
orderly world?
A. As I heard my colleagues discuss the evolution
model, at no time did they, as I heard them discuss, at
least, and in writings of other literature -- and they
were my friends so we had a lot of discussions -- did they
ever mention intelligence being involved with origins.
They talked about stochastic processes which left
a philosophical hole as far as where the orderliness came
from.
Q. Is there any factual basis for this orderliness,
this intelligence?
A. In the sense that the starting point of a model,
as we call creation model and evolution model begin a
priori, that's your starting point predisposition.
Q. What are your a prioris or assumptions?
A. In the creation model?
Q. In the creation model.
A. In the creation model the a priori is that there
was a creative force involved in origins.
Q. Are there any other assumptions?
A. That would be what we call the capital as-
sumption and there are subassumptions and subassumptions
and subcatagories of assumptions and assumptions and
assumptions, depending how narrow you get off in the
field, ad infinitum.
Q. Could you describe the major assumptions in
the creation model and we will start with those first.
A. The major assumptions, and this may not be
46
an exhaustive list because I am trying to do this by re-
call, would be that there was a creative force involving
origins. That's the top one.
In the creation model is not -- it seemed to me not
trapped into a particular time frame as the evolution
model seemed to require.
Q. What do you mean by trapped in a specific time
frame?
A. As I read the literature, some of which you have
in deposition and as I talked with colleagues, they all
seemed to tell me that they required that the evolution
model required vast amounts of time and that the model
wouldn't be viable if they were not there. That seemed
to put blinders on me as a scientist.
I did not like that restriction.
I like to say if it is there, fine.
If it isn't, that's fine too.
So one of the assumptions in the creation model was,
we were freer to look at the time question.
Q. Doesn't the Bible act as a restriction on your
research or your investigation?
A. Not in my personal opinion.
Q. But you do consult the Bible?
A. For professional -- I consult the Genesis record
-- I consider the Genesis record and any other area that
touches my discipline to be fair game for my investigation.
Q. But you do consider that to be a literal account
of the origin of the universe?
47
A. If by literal we mean that the points that can
be checked in time and place as in, say, bronze chemical
composition of tin and copper, I find that checked for
accuracy and I find it to be accurate.
Q. What other assumptions are there in the creation
model?
A. I think those are the main ones.
Q. Are there any other minor assumptions, then?
A. Well, when a scientist makes a model he, you
know -- you have the other model then you have your little
subareas that you are going to investigate.
For example, my areas of alternate fuels, I assume
a process and then go check the process out.
And that assumption would be consistent with the over-
all creation model.
Q. What process do you assume?
A. In the alternate fuels area, I made the assump-
tion, suppose the conversion of biomass to fossil fuels
were a much more rapid process than the evolution model
had considered. What kind of chemistry -- what assump-
tions would I need to make about the chemistry involved,
mid those assumptions and then began to check it out from
that point of view.
So, what I am saying is the overmodel, then, you
make assumptions for the area that you are going to apply.
Q. Is there any scientific evidence of a creative
force?
A. We have all the data that can be looked at,
48
all the known data can be looked at from a creative --
from the creation model assumptions.
Q. But is there scientific data that demonstrates
the existence of a creative force?
A. In my judgment.
Q. And what is that scientific data?
A. Orderliness.
Q. Is there any experimental basis for your belief
that there is a creative force?
A. The experimental basis would mean that you can
go into the laboratory and repeat. The creation was a
past event. It was history. We cannot put history into
a test tube, at least as far as I know.
Q. What in your understanding are the assumptions
of the evolution model?
A. In my understanding, the assumptions of the
evolution model is that no intelligence was involved, no
creative force, but that the present state of the universe
must be accounted for using only natural processes.
Q. Are there any other assumptions?
A. That's the primary assumption and subassumptions
that apply to each of the areas of investigation.
Q. Do you believe there is any scientific evidence
to support any of these assumptions?
A. The evidence -- the data are what we have.
Then the assumptions are used to interpret the data.
So it would be the same case for the evolution model
that I just stated for the creation model.
49
Q. Could you define science for me, please.
A. Science probably has as many definitions as
there are scientists, but the definition that I prefer is
a search for truth in the realm of nature.
Q. What do you believe to be the attributes of
science?
A. I believe science is -- has involved with it a
philosophical base. That's why they grant Ph.D.'s.
You begin with a set of assumptions, look at the
data and draw corresponding conclusions which we call
making models.
In the microscopic area, we make some assumptions
and look at the data and come up with what we call an
atomic model.
Q. What would distinguish religious faith from
science?
A. Well, it seems to me that religious faith in-
volves theology as a study and some religious exercise.
Q. Well, what would distinguish science from faith?
A. In the sense that religious faith begins with
assumptions also and then looks at religious data, draws
conclusions.
They have a formal analogy.
Q. Well, you have testified that assumptions are
the basis of science as well.
What would distinguish science from religion?
A. Well, religion, of course, would have some --
perhaps some formalized liturgy or worship or sociologic
50
associations with it.
It might and does speculate or discuss or talk about
the nature of the creative force.
Q. Do you believe science to involve falsifia-
bility?
A. Yes.
Q. Do you believe observability to be an attribute
of science?
A. Yes.
Q. Do you believe testability to be an attribute
of science?
A. Yes.
Q. Do you believe predictability to be an attribute
of science?
A. Yes.
Q. How does creation science measure up to the
attributes of falsifiability, for example?
A. Well, it seems to be very attractive at that
point.
For example, mentioning one of the things that con-
vinced me, if there was intelligent design, if we start
with the assumption of intelligent design, then the uni-
verse might well be expected to be consistent and pre-
dictable first off.
So I would not be inconsistent p. chem. equation
to describe some process.
It will predict, if possible, creation as an event
as opposed to a process; that the fossil record ought
