Deposition of Harold G. Coffin
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. HAROLD G. COFFIN
Monday, November 16, 1981
Reported by: DEAN McDONALD, CSR
Cert. #1869; and
LINDA L. CHAVEZ, CSR
Cert. #2108
2
I N D E X
DEPOSITION OF DR. HAROLD G. COFFIN: Page
Examination by Mr. Klasfeld 4; 80
AFTERNOON SESSION 80
- - -
E X H I B I T S
PLAINTIFFS':
No. 1 Curriculum Vitae of witness 12
No. 2 Document 60
No. 3 Copy of application form for
Creation Research Society 63
No. 4 Article entitled "The Spiroribis
Problem" 97
No. 5 Document 120
No. 6 Document 143
No. 7 Document 162
No. 8 Document 162
No. 9 Document 162
- - -
3
BE IT REMEMBERED that, pursuant to Notice, and on
Monday, the 16th of November, 1981, commencing at the
hour of 10:00 o'clock a.m. thereof, at the law offices of
Brobeck, Phleger & Harrison, One Market Plaza, San
Francisco, California, before me, DEAN McDONALD, a Cer-
tified Shorthand Reporter and Notary Public in and for
the State of California, personally appeared
DR. HAROLD G. COFFIN,
called as a witness by the plaintiffs, who, being by me
first duly sworn, was examined and testified as herein-
after set forth.
- - -
SKADDEN, ARPS, SLATE, MEAGHER & FLOM, 919 Third
Avenue, New York, New York 10022, represented by DAVID
KLASFELD, Attorney at Law, appeared as counsel on behalf
of the plaintiffs.
STEVE CLARK, Attorney General, State of Arkansas,
Justice Building, Little Rock, Arkansas 72201, repre-
sented by RICK CAMPELL and CALLIS L. CHILDS, Assistant
Attorneys General, appeared as counsel on behalf of the
defendants.
- - -
4
DR. HAROLD G. COFFIN,
being duly sworn, testified as follows:
EXAMINATION BY MR. KLASFELD:
MR. KLASFELD: Q. Dr. Coffin, when was the first
time you heard about this case?
A. I think I may have noticed something in the
news three, four months ago.
I am not sure.
Q. When was the first time that someone from the
Arkansas Attorney General's Office got in touch with you
about the possibility of your testifying in this case?
A. Actually, I heard it indirectly through my
colleague, Ariel Roth, and did not have direct contact
with the Arkansas Attorney General's Office until perhaps
jsut a week ago or maybe a little bit over a week ago.
Q. Who did you speak with?
A. Tim Humphries, H-u-m-p-h-r-i-e-s.
Q. Do you know who Mr. Humphries is?
A. Legal counsel for the Attorney General of
Arkansas.
MR. KLASFELD: Mr. Campbell, is he a member of
your staff?
MR. CAMPBELL: No.
I guess you would call him -- he is an intern in
our office.
MR. KALSFELD: Q. What did Mr. Humphries said to
you?
A. He just asked me if I would be willing to
5
testify.
Q. And this was a week ago, you say?
A. I'm not really sure but it was not over two
weeks ago.
Q. So within a week to two weeks?
A. Let's say within two weeks.
Q. Is that all he said to you?
A. He asked me my educational background and he
asked me what my expertise would be in or is in.
Q. What did you tell him your expertise was in?
A. I told him my expertise was in the area of
paleontology.
Q. You said earlier that your colleague, Dr. Roth,
had mentioned the possibility of your testifying at the
trial to you earlier.
A. Yes.
Q. When was that?
A. I really cannot remember exactly when it was
but say within the last three weeks, perhaps a month.
Q. What did you discuss with Dr. Roth?
A. I don't recall discussing anything except just --
Q. Well, do you recall how he raised the matter,
what he said to you?
A. No, I really don't recall what he said.
Q. As close as you can recall, what was the sub-
stance of your conversation?
A. I think he just merely said it would be a
possibility that we would be witnesses in the Arkansas
6
lawsuit and he wondered if I was interested or agreeable.
Q. What did you tell him?
A. I told him -- he is the director of the insti-
tute, so he sort of had the final say, you might say.
I said, "Well, I am agreeable, if that is what you
want me to do."
Q. What institute is that?
A. The Geoscience Institute.
Q. Is that connected with a school of any kind?
A. It is loosely affiliated with Loma Linda Uni-
versity.
Q. Is that a church-affiliated school?
A. Yes.
It's a Seventh-Day Adventist university.
Q. Now, Dr. Coffin, I have here a document filed
with the court and served on plaintiffs which is called
Defendant's Second List of Witnesses. The attached
certificate of service is signed by David Williams and
it says it was served on us the 10th of October.
MR. CAMPBELL: For the record, I think that is the
26th.
MR. KLASFELD: That may well be.
It looks like the 20th, though.
Q. That document, on its fourth page, lists you
as a witness for the defense in this action.
October 26th would be about three weeks ago.
Is your testimony then that you did not speak with
anyone in the Arkansas Attorney General's Office prior
7
to the filing of this document?
A. No.
Q. That is not your testimony?
A. I am sorry.
Yes, my testimony is I did not speak to anybody prior
to that.
Q. Where the Defendant's Second List of Witnesses
says, "Dr. Coffin will testify that the fossil record supports
the Creation Science model," while that may in fact be
the case, you didn't discuss with anyone from the Arkansas
Attorney General's Office that it was the case?
A. No.
As far as I know, we discussed just what I told you,
my academic background and the area of my expertise.
Q. But prior to October 26th,you hadn't spoke with
anyone about that?
A. No.
Q. Since having spoken with Mr. Humphries between
a week and two weeks ago, what further contact have you had
with the Arkansas Attorney General's Office?
A. Well, the only contact I had is a letter I re-
ceived containing the Act, Act 590.
Q. You received a letter?
A. Yes, plus an accompanying letter from Tim
Humphries, and the contact I have had with these gentlemen
since I have been here [indicating counsel].
Q. Let me understand this:
You received a letter containing the Act from Mr.
8
Humphries?
A. Yes.
Q. When was the next contact you had with someone
from the Arkansas Attorney General's Office?
A. Yesterday.
Q. Yesterday?
A. Yes.
Q. When you spoke with whom?
A. With Mr. Campbell and Mr. Williams.
Q. What time yesterday was that?
A. Let's see.
About somewhere between 4:30 and 5:00 o'clock.
Q. How long was that meeting?
A. Somewhere around an hour, an hour and a half,
in there.
Q. Would you characterize that meeting as a
substantive discussion of your possible testimony at the
trial?
A. What do you mean by "substantive"?
Q. Well, did they discuss the testimony you might
offer about fossils at the trial?
A. They gave me an idea, gave us an idea, what the
deposition would be and more or less what to expect.
Q. When you say "us," did you meet with them with
Dr. Roth?
A. Yes.
Q. So you discussed what the deposition would be
like.
9
Did you discuss the testimony you were likely
to give at the trial?
A. Not really.
MR. KLASFELD: Excuse me.
[Discussion off the record]
MR. KLASFELD: Back on the record.
I have here another document, which is called
Plaintiffs' First Set of Interrogatories.
Let me just show you the document and ask you if at
any time this document has been discussed with you.
A. I have not seen this.
Q. The substance of it was discussed with you to-
day?
A. I would have to look at it again.
I just noticed that it was new to me.
Q. Sure.
A. Well, I would say that, in the course of the
discussion, some of these points were at least touched
on, such as the first one, the qualifications and so on.
Q. But you didn't discuss the substance of the
facts and opinions as to which you were expected to
testify?
A. Not really.
Q. Or your grounds for each opinion?
A. Not in that kind of detail.
MR. KLASFELD: I would like to put my position on
the record about this.
It is, of course, plaintiffs' opinion that we are
10
entitled to a response to Plaintiffs' First Set of In-
terrogatories prior to Dr. Coffin's deposition, and his
testimony makes clear that there has been no attempt of
any kind to respond to the First Set of Interrogatories
in any kind of meaningful way.
He has said that, apparently, the information con-
tained in Defendant's Second List of Witnesses, which
lists him as a witness, that information was supplied to
us without his knowledge or his review of that.
This failure to allow us the discovery we are en-
titled to prior to the deposition leads me to object to
the notion of terminating the deposition today, and pend-
ing, of course, our discussion with the judge tomorrow, I
would expect to continue Dr. Coffin's deposition either
tomorrow or as soon thereafter as is possible after we
get a proper response to the interrogatories.
MR. CAMPBELL: Your objection is noted.
We did timely file an objection to the interroga-
tories, along with a motion for extension of time to com-
plete the interrogatories.
I think that Dr. Coffin has testified here that the
information which you requested has not even at this
time been given to us by Dr. Coffin, and we had made at-
tempts, as is set out in our objection and the motion for
extension of time, to secure that information, and we
believe that, under the Federal Rules, you can utilize
this time today to secure from him his expert testimony
and the bases upon which he will testify at trial.
11
Likewise, when we set up the depositions for Dr.
Coffin and all of the other defendant's witnesses with
local counsel in Little Rock, we emphasized to them that,
in order to be able to take or to participate in thirty-
five depositions between now and trial date, it would be
necessary to limit the depositions to all day, from 9:00
in the morning until 4:00 in the afternoon, so we would
have an opportunity to meet with our witnesses for the
first time the night before the depositions.
MR. KLASFELD: Do you have a copy with you of your
response to our set of interrogatories?
MR. CAMPBELL: I don't.
Mr. Williams has that.
MR. KLASFELD: Could we get it up here?
MR. CHILDS: We can do that at our break.
MR. CAMPBELL: Yes, we can do that at the break.
MR. CHILDS: We will be glad to make it available
to you.
MR. KLASFELD: I understand.
THE WITNESS: Could I make a statement?
MR. KLASFELD: Certainly.
THE WITNESS: I was away from October 29 to November
6.
There may have been some difficulty communicating
with me at that time.
MR. KLASFELD: Just for the record, Mr. Campbell,
was there any attempt by your office during that period
to get in touch with Dr. Coffin?
12
MR. CAMPBELL: I don't know.
Mr. Humphries is the one who contacted the witnesses
for our office.
MR. KLASFELD: Was he instructed, do you know, hav-
ing made the initial contact with Dr. Coffin and the
other witnesses, to get in touch with them again?
MR. CAMPBELL: This is Dr. Coffin's deposition.
I am just not sure at this time.
MR. KLASFELD: We have been supplied, Dr. Coffin,
with a copy of what I believe is your curriculum vitae.
Let me have that marked as Plaintiffs' Exhibit 1
for identification.
[Curriculum Vitae of witness marked
for iden. as Plaintiffs' Exhibit
No. 1]
MR. KLASFELD: Q. Dr. Coffin, would you please look
at Exhibit 1.
A. Yes.
Q. Is this one-page document your curriculum vitae?
A. Yes.
As far as I can see, it's correct.
Q. I am not asking, Dr. Coffin, whether it's
correct.
I am asking whether or not you have a curriculum
vitae that you would give to someone if they asked you
for it.
I am asking you:
Is this the document?
13
A. Yes.
Q. It is.
Fine.
It seems, at least to my eye, to sort of end abrupt-
ly.
Are there other pages to this?
A. No.
That is it.
Q. Is that a document that you supplied to the
Arkansas Attorney General's Office?
A. Yes.
Q. When was that, please?
A. I really cannot remember.
In fact, I'm a little bit surprised, considering the
paucity of communication with them, that they had it,
and I am not sure whether I sent it or my colleague or
my secretary sent it.
Q. Your vitae says that in 1947 you got a biology
degree from Walla Walla College, Washington; is that
correct?
A. Correct.
Q. What else did you study while you were there?
A. Well, all that would be involved in a Bachelor
of Arts degree in Biology.
Q. And this indicates that in 1952 you got a
Master's degree in biology from the same university;
is that right?
A. That is right.
14
Q. Did you spend all of your time during those
five years obtaining that degree?
A. No.
Mostly during the summers.
Q. What did you do the rest of the time?
A. I was teaching.
Q. At Canadian Union College?
A. That is right.
Q. Where is that?
A. That is about in the center of the Province of
Alberta, Canada.
Q. That is quite a commute.
A. Pardon?
Q. I say, that is quite a commute.
Oh. You did it during the summer.
I see.
A. Yes.
Q. And then in 1955 you got a Ph.D. in zoology
from the University of Southern California?
A. That is right.
Q. Was that a specialty in paleontology?
A. No.
It was a specialty in Invertebrate Zoology.
Q. Could you please define for me the field of
Invertebrate Zoology.
A. Those animals that do not have backbones.
Q. What is it that you --
Strike that.
15
Are these living animals that you studied?
A. Well, Invertebrate Zoology would be all aspects:
anatomy, physiology, behavior, et cetera, for animals
that don't have backbones.
Q. I wanted my question to direct itself to see
whether or not you dealt with extinct, fossilized animals
or recently dead or living animals.
A. It's usually considered to be living animals, but
I did take work with extinct animals.
Q. Did you study paleontology during your doctorate
program?
A. Yes.
Q. How many courses did you take?
A. It has been a little while.
Two, possibly more. I can think of two.
Q. Do you recall who the professors were?
A. Mattux was the first one, M-a-t-t-u-x, I
think, and Easton was the second one, E-a-s-t-o-n.
Q. Did you receive any honors during your Ph.D.
program at the University of Southern California?
A. I was a Research Fellow.
Q. Just what does that mean?
A, It means that I had a scholarship or a fellow-
ship and I assigned with certain research activities of
the institution.
Q. What field were you a Research Fellow in?
A. I was a Research Fellow under Dr. John Garth,
G-a-r-t-h, whose expertise is with carcinology, c-a-r-
16
c-i-n-o-l-o-g-y.
Carcinology is the study of crustacea, like shrimps
and crabs.
Q. The study of crustaceans, was that of crusta-
ceans as they are today?
A. Mostly.
Q. Was any part of your Research Fellow work done
in fossils?
A. Not directly.
Q. From the University of Southern California,
you then became Chairman of the Division of Science at
Canadian Union College?
A. That is right.
Q. Is that a church-affiliated school?
A. Yes, it is.
Q. What church?
A. The Seventh-Day Adventist Church.
Q. Did you teach while you were there as well?
A. Where?
Q. At Canadian Union College.
A. Yes, I taught.
Q. What courses did you teach?
A. I taught general science in the secondary
level and I taught general zoology and botany and genetics
in the college level.
Q. What are you referring to when you say "the
secondary level"?
A. High school level.
17
Q. I see.
Was the high school part of the college?
A. Yes.
It's a small institution and the high school and
the college are together.
Q. I missed a question that occurs to me now.
Is Walla Walla College also a church-affiliated
school?
A. Yes.
Q. What church is that?
A. The same church.
Q. The Seventh-Day Adventist Church?
A. Yes.
Q. Did you teach Creation Science at Canadian
Union College?
A. I taught a course entitled "Philosophy of
Science," which might be comparable.
Q. But in that course of Philosophy of Science,
you taught the discipline or the study of Creation
Science?
A. Yes.
Q. In your teaching of general science, general
zoology, botany and genetics, did you also teach Crea-
tion Sciences theories as part of those courses?
A. Yes.
And evolution as well.
Q. I see.
You then left Canadian Union College and became an
18
associate professor of biology at Walla Walla College;
is that correct?
A. Yes.
Q. What courses did you teach at Walla Walla
College?
A. I taught Invertebrae Zoology, I taught genetics
and evolution, I taught part of the time basic general
biology for freshmen.
Q. Again, did you teach Creation Science in these
courses?
A. Yes.
Q. Did you in addition teach a course in the
Philosophy of Science as well there?
A. In comparable material.
I don't think it was named that.
The course name was different.
Q. In 1958, you became a professor and the head
of the Department of Biology at Walla Walla College;
is that correct?
A. Yes.
Q. Did you continue teaching during that time?
A. Yes.
I taught less but I continued teaching.
Q. Did you teach any additional courses?
A. Any that I haven't mentioned thus far, you
mean?
Q. Yes.
A. I think I taught a class in microbiology for a
19
short time.
Q. Do you recall what text you used in the
general biology course you taught at Walla Walla College?
A. Oh, Storer, I believe, is the author.
Q. Could you spell that, please?
A. S-t-o-r-e-r.
Q. Is that book still being used today?
A. I have been out of it for a while.
I really can't say.
Q. Did that book have a section on Creation Science
in it?
A. No.
Q. In the Creation Science parts of the course you
taught, what materials did you use?
A. I prepared my own materials.
Q. I see.
Do you still have copies of those materials?
A. Not in that form.
Q. What form do you have them in?
A. My work since then has been totally devoted to
the subject of creation evolution and it has been expanded
much, much more than that.
Q. In 1964, you left Walla Walla College and went
to the Geoscience Research Institute; is that correct?
A. That is right.
Q. Who offered that position?
A. Dr. Richard Ritland offered me that position,
or he is the one that made the contact with me.
20
Q. Do you know how he came to come into contact
with you?
A. We knew each other previously.
Q. What was his position at that time?
A. He was at least --
MR. KLASFELD: Excuse me just one moment, please.
[Discussion off the record]
MR. KLASFELD: Back on the record.
Q. The interruption leads me to ask another ques-
tion which I was going to get to later.
Have you brought any documents with you today?
A. Yes, I have some.
Q. Could I see them, please?
A. Yes.
MR. KLASFELD: Off the record.
[Discussion off the record]
MR. KLASFELD: Back on the record.
Let's put on the record that the witness has given
me three textbooks and, what shall we call this, a stack
four inches thick of other documents; is that right,
counsel?
MR. CAMPBELL: Yes, that is fine.
MR. KLASFELD: Q. Dr. Coffin, how did you come to
bring these documents with you today?
A. We received a list, a sheet with a list of things
we were supposed to bring.
Q. You received that list from whom?
A. Well, I received it from Dr. Roth.
21
Q. Do you know who Dr. Roth received it from?
A. I would have to ask him, but I suppose from
Tim Humphries or somebody from the Arkansas Attorney
General's Office.
MR. KLASFELD: Off the record.
[Discussion off the record]
MR. KLASFELD: Back on the record.
If I may, let me make a brief statement for the
record.
I have indicated the amount of documents that Dr.
Coffin has made available to me today, and it's obvious
it would be impossible for me to attempt to digest them
and question Dr. Coffin about them, and their delivery
to me this morning frustrates any type of serious inquiry
I can make into Dr. Coffin's work and thoughts and testi-
mony and it's clear we are going to have to continue Dr.
Coffin's deposition from this afternoon and continue it
to a time reasonable to both sides.
MR. CAMPBELL: For the record, the documents were
produced pursuant to the notice of deposition and a
subpoena duces tecum which requested that Dr. Coffin bring
these documents to his deposition.
We were not requested to present them to you earlier
than this date.
MR. KLASFELD: Let me just take a minute to see what
is here.
Off the record.
[Discussion off the record]
22
MR. KLASFELD: Back on the record.
Q. Dr. Coffin, do you have a copy of the letter
requesting that you bring these documents?
A. No, I don't.
Q. What did you understand the substance of that
letter to be that led you to choose these documents?
A. It was extremely broad and it was difficult to
know what to bring.
Q. I see.
But generally, what did you understand the request
to mean?
A. The materials that would be of particular value
in this particular lawsuit and on the topic of evolution
creation.
Q. I see.
I have, Dr. Coffin, read some articles you have
written for the magazine "Origins."
I don't see any of those articles here.
Q. Is there any reason why they are not here?
A. Dr. Roth has the complete set of Origins.
He brought them, so I didn't bring any.
MR. KLASFELD: Off the record.
[Discussion off the record]
MR. KLASFELD: Back on the record.
Q. Going through these documents, Dr. Coffin, I
notice that the curriculum vitae that appears among the
documents you have just given me is different to some
degree from the document we have been discussing this
23
morning.
Let me show you a copy of one of these that you gave
me and I will ask you how that difference came about.
A. Do you mean between the two of them?
Q. Yes.
A. We have a new word processor and I just was
practicing on that the other day.
Q. I see.
And the indication "pp" after the books listed at
the bottom indicates how many pages the book contains;
is that right?
A. Yes, that is right.
Q. Have you taken any courses in continuing educa-
tion since your graduation from the University of Southern
California?
A. Yes.
Q. Where have you taken those courses?
A. At the University of Alberta in Edmonton,
Canada, and Notre Dame University in Indiana.
Q. And when was that?
A. The first, 1956 and '57; the second, 1965 and
and '66.
Q. Were each of those for a full year?
A. No.
They were in the summer.
Well, no. I beg your pardon.
It was two summers in Alberta and one year in Indi-
ana.
24
Q. I see.
Was that the entire year?
A. It was nearly a full load.
But it was during the school year.
Q. I see.
So that while you were associate professor of
biology at Walla Walla during those summers, you took
courses at the University of Alberta.
And during the time you --
Did you get a leave of absence from --
A. Let me back up, please.
It was when I was Chairman of the Division of Science
of Canadian Union College that I did the work at the
University of Alberta.
Q. I see.
So that would then have been 1955 and '56 rather
than 1956 and '57.
A. What did I tell you?
Q. You said 1956 and '57.
A. Okay.
Let's move it back one year.
Q. And then at Notre Dame, you were there while
you were senior research assistant at the Geoscience Re-
search Institute?
A. Yes.
MR. KLASFELD: Off the record.
[Discussion off the record]
MR. KLASFELD: Back on the record.
25
Q. What course did you take at the University of
Alberta?
A. A psychology course and a methods course, I
think in mathematics.
Q. Methods in mathematics?
A. Yes.
Q. What did they teach you about methods in mathe-
matics?
A. Teaching methods in mathematics.
Q. I see.
It was an education course, was it?
A. Yes.
Q. How did you come to take these two courses?
A. Because the Canadian system required those of
us who were not Canadians to meet certain requirements,
despite the fact that we might already have a Ph.D., so I
had to go and take some courses there.
Q. What did you study at Notre Dame?
A. At Notre Dame, I was working in geology and
paleontology.
Q. What courses did you take there?
A. I took mineralogy and sedimentary petrology.
Q. Fine.
Go ahead.
A. And stratigraphy, s-t-r-a-t-i-g-r-a-p-h-y.
I took a paleontology course but I can't remember
what the name of it was.
Q. I see.
26
Were these undergraduate courses that you took?
A. Well, I didn't pay much attention to that be-
cause I already had a degree.
I think they can be applied either way.
Q. Do you recall whether they were part of the under-
graduate curriculum?
A. Some of them would be.
Q. Do you recall which ones?
A. Probably stratigraphy and mineralogy would be
undergraduate.
Q. And the other courses, were they in the gradu-
ate curricula?
A. I would have to check the bulletin again.
I just can't tell you.
Q. Do you recall who the paleontology professor
was?
A. I can't remember his name.
Q. Is there some reason these continuing educa-
tion programs aren't listed on your resume?
A. No.
This is the curriculum vitae I have sent out through
the years. It's not complete. I just haven't felt it
was necessary to put down every item, including publica-
tions.
They are not all there.
Q. Did you get grades in these courses at Notre
Dame?
A. Yes, I did.
27
Q. What were they?
A. I think they were A's.
Q. Have you taken any other continuing education
courses since your work at Notre Dame?
A. I was a member of a National Science Founda-
tion field conference.
I guess that is what it would be called.
It was on the structure and origin of volcanic --
that isn't quite the right name -- on volcanic phenomena,
let's say.
Q. When was that?
A. Well, actually, it was not after this, not after
Notre Dame.
It was before Notre Dame, the summer before.
It was the summer of '64.
Q. What work did you do in connection with this
conference?
A. We spent four weeks, I believe, touring the
greater Yellowstone area.
Q. How were you chosen for this project?
A. I saw it advertised in some science journal and
I submitted my name and was accepted.
Q. Was there a competition of some kind that you
are aware of?
A. Only insofar as the number might be filled up
and I would be too late, like a class.
Q. I see.
The only competition was in the form of a race?
28
A. In the form of getting there before there
wasn't any more room.
Q. Was there any other continuing education ex-
perience?
A. No.
Q. During the time you have been teaching, have
you applied for grants of any kind from the government or
from foundations?
A. Yes.
Q. Have you received any?
A. Yes.
Q. What grants have you received?
A. I received, when I was at Walla Walla College,
two or three grants dealing with research in -- I said
we weren't going to use this word again, in carcinology.
Q. I said we weren't going to use it again.
Who did you receive those grants from?
A. From the National Science Foundation.
Q. And since then have you received any other
grants?
A. Did you say from the government?
Q. From the government or --
A. No.
Q. -- or any other kind of institution.
A. No.
Q. Or any kind of foundation, private foundation?
A. No.
Q. Have you been turned down for any grants from
29
the government or any foundation?
A. I think -- it has been a while.
I think I was at least once.
Q. Do you remember when that was?
A. I can't give you the dates on that.
Q. Was it the National Science Foundation?
A. Yes.
Q. Was that after these grants they awarded you
or was it before?
A. It was during that time.
Q. I see.
And since that time you haven't make application
for any grants?
A. No.
Q. I see.
What was your doctoral thesis in?
A. My doctoral thesis was the -- this is the title:
"The Biology of Paurus Samuellis."
Q. What is pagurus samuellis?
A. Pagurus samuellis is a species of hermit crab
that lives on the California Coast.
Hermit crabs are those crabs that live in empty
seashells.
Q. Have you ever received any academic discipline
at the institutions at which you have been a student or
a teacher?
A. No.
Q. How much are you paid for being a senior re-
30
search assistant the Geoscience Research Institute?
A. You would just about have to ask my wife that
question.
I turn my check over to her.
I am just frankly not able to actually give you an
exact figure.
Q. What is your best guess?
A. It must be -- it's somewhere around twelve to
fifteen hundred dollars a month.
- - -
31
MR. KLASFELD: Q. Your curriculum goes on to say
you a member of the association for the Advancement of
Science.
Could you tell me something about the makeup of
that association?
A. Well, it is a large -- it is the major
science association of North America, involving sciences
all the way from astronomy to botany and so on.
Q. How does one become a member of that associa-
tion?
A. I don't think -- I've sort of forgotten, but I
don't think it's a recommendation requirement in this case.
I think it is merely a paying dues.
Q. Can a nonscientist become a member, if you
know?
A. I'm not sure.
Q. Do you receive a journal?
A. Yes, indeed, Science.
Q. Science Magazine.
Have you written any articles for that journal?
A. No.
Q. Have you submitted any?
A. Yes. They were not accepted or, I have once.
Q. You have once submitted?
A. Yes.
Q. You are also a member of the Geological
Society of America?
A. Yes.
32
Q. How does one become a member of that organiza-
tion?
A. One has to be recommended for membership in
that case by a member.
Q. I see.
And who recommended you?
A. Dr. Raymond Gottschalk (phonetic). He is or
was the chairman of the geology department of Notre Dame
University.
Q. Do they have a journal?
A. Yes, two journals.
Q. Do you receive those journals?
A. Yes.
Q. Have you ever submitted anything for publica-
tion?
A. Yes.
Q. To either of those journals?
A. Yes.
Q. Were they published?
A. Yes.
Q. Were those articles in the package of documents
you gave me this morning?
A. There were two articles in the package of
documents, one from the GSA Bulletin and one from the
Journal of Paleontology, which is not their journal.
Q. Are those articles reviewed prior to their print-
ing and accepted or rejected or do they just publish
whatever is submitted?
33
A. It is a tear review process.
Q. When was those articles written?
A. I think the GSA Bulletin article was in 1971
and the Journal of Paleontology article was 1973, I
believe.
Q. What was the topic of the GSA Bulletin
article?
A. The floatation of equisetum.
Q. What are equisetum?
A. Horsetails, scouring rushes, joint grass.
Q. And what was the article in the Journal of
Paleontology about?
A. I may not have the exact title, but it is
close to the orientation of Yellowstone petrified trees.
Q. What did you mean in the article by orienta-
tion?
A. The way these trees are lined up in the rocks.
Q. Did either of these articles come to any
conclusion about the merits of evolution or Creation
Science?
A. No.
Q. And both of those articles were within the
package that you gave me today?
A. Yes.
Q. Are these the only two articles you have
written for either of those journals?
A. Yes.
Q. The resume says you are also a member of Sigma
34
Xi. What society is that?
A. It is the Honorary Scientific Society.
Q. How does one become a member?
A. By recommendation.
Q. And who recommended you?
A. Dr. -- I can't recall his first name -- Chen,
of the University of Southern California.
Q. Was that during your PhD program there?
A. Right at the conclusion of it.
Q. And do they have a magazine?
A. Yes.
Q. Do you receive that regularly?
A. Yes.
Q. Have you ever published an article in it?
A. No.
Q. Have you ever submitted an article for publica-
tion?
A. No.
Q. The article which you wrote which was rejected
for Science Magazine, is there a copy of that in the
documents that you gave me this morning?
A. No.
Q. What was the subject of that article?
A. It was the same subject that was published in
the Journal of Paleontology.
Q. Was it the same article?
A. No, there was some modification.
Q. You submitted it to Science Magazine before you
35
submitted it to the Journal of Paleontology?
A. I believe so.
Q. Do you recall sort of the general area of what
the modification was?
A. Each journal has its own format.
Q. And style?
A. Yes.
Q. The changes were stylistic?
A. They were that and there may have been some
textual changes as well.
Q. This was the only article that you ever sub-
mitted to Science Magazine?
A. Yes.
Q. And you are also a member of the Creation
Research Society?
A. I used to be but my membership has lapsed.
Q. When did it lapse?
A. Well, it is hard to say. We get the Journal
at the Institute and it just sort of dawned on me
recently that nobody had asked me for any money for
some time and I am sure my membership has lapsed.
Q. Have you not continued to renew your member-
ship for any particular reason?
A. I am not too -- it is not too important a
journal to me.
Q. What do you mean by it is not too important?
A. I don't agree with some of the research in it
or some of the articles.
36
Q. Do you remember in particular any of the
articles with which you disagree?
A. Oh, there was one article on Mt. Arat.
Q. What did that article say?
A. Oh, it is hard for me to remember the details.
Q. In general?
A. In general it was talking about the geology of
Mt. Ararat and trying to draw some implications which I
didn't really agree with.
Q. What were the implications?
A. Its past geological history.
Q. Are there other articles that you can recall
that were in the magazine that you disagree with?
A. There are some articles -- there have been
some articles on glaciation that I haven't agreed with,
evidences for glaciation.
Q. And you disagreed that those were evidences
for glaciation?
A. They claimed they were not evidences for
glaciation and I disagree with that.
Q. You believe they were?
A. Yes.
Q. Are you paid for doing anything else other
than being senior research scientist at the Geoscience
Institute?
A. No, that's my full-time work.
Q. During the time that you were at the Canadian
37
Union College and Walla Walla College, did you, while
teaching there, conduct any scientific research?
A. Not at Canadian Union College but at Walla
Walla College I did, yes.
Q. What was the nature of the research work that
you did?
A. It was on some of the life cycles of crabs in
the Puget Sound.
[Discussion off the record]
MR. KLASFELD: Q. Now, since you have become
senior scientist at the Geoscience Research Institute,
what kind of research have you conducted?
A. My research has been mainly with paleontology.
Q. From 1964 until the present?
A. Yes.
Q. Why the switch from crabs?
A. Well, invertebrate paleontology is really a
very good way to enter the area -- I mean, invertebrate
zoology is a good way to enter paleontology, because 95
percent of your fossils are invertebrate.
Q. Aside from the one course that you took at
Notre Dame in paleontology, have you taken any other
courses in paleontology?
A. I really need my transcript to refer back to.
Q. But, in any event, it was during that one year
at Notre Dame?
A. Yes, that's right.
Q. Could you describe the nature of your research
38
on the crabs, exactly what it was that you did?
A. Okay.
My doctoral dissertation, the title of which I men-
tioned already, had to do with working out certain phases
of the life cycle which were unknown. Hermit crabs had
never been successfully reared in the laboratory up to
that time and there was a step in the transfer of the eggs
to the posterior portion of the abdomen where they are
carried for a period of time that was perplexing and
unknown, which I was able to work out.
Q. How were you able to do that?
A. The animal lives in a seashell and it extrudes
its eggs and the eggs get to the back of the abdomen and
are glued to the appendages on the back of the abdomen
inside the shell, so it never could be seen.
So I had the glassblower in the chemistry department
blow me some glass seashells and they were willing to use
those for their homes, providing there weren't any
natural seashells, and thus I was able to see the actual
ovulation process and see how it happened.
Q. So the nature of your research on crabs was
to observe what was going on underneath the shells?
A. Inside.
Q. I don't mean to denigrate it, I just mean to
describe it.
[Discussion off the record]
MR. KLASFELD: Q. When you went to work at the
Geoscience Research Institute, was the understanding that
39
you would go to work in paleontology?
A. Yes.
Q. I guess I don't understand why the switch.
A. It is not, as I say, it is really not that
great a shift from invertebrate zoology and paleontology
and my paleontology has been in the area of invertebrate
paleontology. So vertebrate paleontology is not my
specialty.
Q. I see.
But the study of paleontology and the study of
fossils is really entirely different than the studies of
crabs in a --
Q. As far as that specific research is concerned,
yes. My work in the Geoscience Research Institute includes
paleontology, but it is not limited to that. It is
science in religion, you might say.
Q. What else, other than paleontology, do you do?
A. Speciation.
And, as I say, science and religion, relating of
science and religion.
Q. What do you mean by speciation?
A. Change within organisms.
Q. What kind of research are you doing on that,
if any?
A. I'm really not doing any research on that
right now.
Q. What research have you done?
A. Well, work with the crabs would be in the area
40
of speciation. At least it would be involved in it.
Q. Did you continue some of that crab research
when you went to the Geoscience Research Institute?
A. No, not the actual laboratory.
Q. What is the nature of your work in science and
religion?
A. This, of course, is an institution that's
funded by the Seventh-Day Adventist Church.
Q. The institute is funded by the Seventh Day
Adventist Church?
A. Yes, my work is to, in part, to show the
relationship between science and religion.
Q. Do you conduct any experiments to do that?
A. Sure, that's where our research comes in.
Q. What kind of research are you doing?
A. I have been working in the Yellowstone region.
For instance, the paper on the Yellowstone petrified
forest and paper on flotation, these are aspects of
research dealing with that.
Q. I thought I understood you to say that those
articles made no reference to creation, science or
evolution?
A. They didn't, but they --
Q. Why do you then make reference to them in this
discussion if you work in the areas of science and
religion?
A. Because they -- they have implications for
creation.
41
Q. What is the nature of your research in
paleontology?
A. The petrified forest of Yellowstone.
Q. In other than going there and looking at the
petrified forest, what else do you do?
A. We measure the tree rings; we extract the
fossil pollen out of the sediments; we determine the kind
of wood involved and orientation of the trees, et cetera.
Q. When you say "we," who is doing this work with
you?
A. I have often had graduate students with me.
Q. I see.
How much of your time do you spend at Yellowstone
during the year?
A. That's limited by the weather.
Q. I see.
But how much?
A. Oh, one or two months a year.
Q. And what do you do the other 10 months?
A. Some of the materials that I brought, writing,
research, that is, literature research.
Q. I guess I am trying to understand what the
research that you do is and I understand that you go to
Yellowstone and gather data.
When you get back to the Institute, what is it that
you do there?
A. Well, we analyze it. We try to determine
what the information is telling us.
42
Q. How do you do that?
A. Well, the article on orientation of the trees
would give an idea of how we go about that.
Q. Inasmuch as I don't have the article in front
of me, could you describe that?
A. This article shows the relationship of the
trees to each other and comparison is made with living
forests.
Q. What are the relationships to the trees to
each other in Yellowstone?
A. There is a parallel orientation for many of the
levels --
Q. What do you mean?
A. -- which we don't usually fine in a living
forest.
Q. There is a parallel what?
A. Parallel orientation.
Q. I guess I missed the word.
You mean that's how the petrified trees are lying,
parallel to one another?
A. Yes, yes.
Q. You say that's different than the way trees
are found in the living forest?
A. Yes.
Q. In the living forest, then, they are not
parallel?
A. Not unless there are some extenuating circum-
stances, such as being along the open edge of the forest
43
where the wind can reach it.
Q. What is your explanation for the parallel
orientation of petrified trees?
A. It looks like some different forces have been
in operation than are in operation today.
Q. I see. That have made them lie parallel to
one another?
A. Yes.
Q. What are those forces?
A. Movement of volcanic muds and breccias.
Q. And those volcanic muds and breccias move the
-- were the trees petrified when they moved them?
A. No.
Q. But these volcanic muds and breccias moved
the trees to where they are now and are the cause for
them being parallel?
A. Yes, it appears that way.
Q. When did that take place?
A. The usual geological reckoning for that
activity is in the Eocene.
Q. And now long ago was that?
A. Let's see. That is considered to be -- I would
have to check for sure, but somewhere in the realm of
40, 50 million years.
- - -
44
Q. Is that how long ago you believe it took
place?
A. No, I have no different views on it.
Q. What are you views?
A. I think it is much more recent.
Q. How recent?
A. I think it is a phenomena of catastrophism
which is only a few thousand years ago.
Q. But you do believe that it was caused by
volcanic muds and breccias?
A. Yes.
Q. And what caused the volcanic muds and breccias?
A. Eruptions from some volcanic center.
Q. Do you know where that was?
A. Mount Washburn is considered to be one of the
centers.
Q. Excuse me for a moment, you seem to be dif-
ferentiating.
You used the words "considered" before in terms of
describing the Eocene period. You said something like,
"It is considered to be X million years ago but that
wasn't your opinion."
In talking about Mount Washburn, are you speaking
of your opinion or what somebody else considers to be
true?
A. I am using literature that has been published
on this and it is not too clear-cut.
It is hard to find the source areas.
45
Q. Why couldn't this have happened forty or
fifty million years ago?
A. It could have, but my own personal opinion
is that it didn't.
Q. Because why?
A. Because my view of earth's history is not that,
that life on earth has been that long or that old.
Q. Is there any data that you developed in your
work in Yellowstone that would preclude the earth being
that old?
A. No.
Q. It is that you don't believe the earth is
that old so it had to have happened more recently?
A. My belief, in regard to the age of the earth,
is based on other evidences, not Yellowstone.
Q. I see.
Fine.
[Recess taken]
MR. KLASFELD: Q. Your resume also mentions that
you have papers in various church and religious journals.
A. Yes.
Q. What journals are those?
A. The church paper is the Advent Review.
That is the official church paper.
I also have articles in Science of the Times.
Q. Science of the Times?
A. Yes.
Liberty, Ministry, These Times.
46
[Discussion off the record]
MR. KLASFELD: Mr. Campbell and I had a discussion
off the record in which Mr. Campbell has stipulated that
Dr. Coffin's testimony at the trial will be limited only
to his work in the area of fossils and that on that
basis, I'll limit my questioning of Dr. Coffin's recent
work to the area of fossils.
MR. CAMPBELL: If I may add?
MR. KLASFELD: Sure.
MR. CAMPBELL: His testimony will center arount
the fossil record.
I don't know the distinction, if there is one, be-
tween fossils and fossil record, but at least be that
broad.
MR. KLASFELD: That's fine.
I just want to preclude him testifying about --
MR. CAMPBELL: Astronomy.
MR. KLASFELD: Yes.
MR. CHILDS: Dr. Coffin, do you feel comfortable
about that?
Do you feel there is any area of expertise that
you would be qualified to testify about at the trial
other than the fossil record?
TNE WITNESS: No, I feel comfortable with that.
[Discussion off the record]
MR. KLASFELD: Q. The articles that you have
written for these religious and church journals, have
they been science articles or religious articles?
47
A. They are both.
Q. You said that your work was in the area of
science and religion.
Have you written exclusively religious articles?
A. Without any reference to science?
Q. Well, we will start with that question, yes,
without any reference to science.
A. I don't think so.
Q. Have the articles in these journals been dif-
ferent in substance than the articles in Origins Magazine,
for instance?
A. Well, Origins is a scientific journal.
Q. Yes, I understand.
I am saying these church and religious articles
that you have written, have they been different in sub-
stance than the articles that you have written for
Origins?
A. Not really in substance but in level.
Q. When you say "level," you say the science is
simpler?
A. Reader level.
Q. I see.
If I could just ask you a few questions about the
crabs, and that will be the end of it.
Do you have a copy of the --
A. Dissertation?
Q. Yes, the dissertation.
A. Not with me.
48
Q. Is it possible for us to get a copy of it?
A. Yes.
MR. CHILDS: We will make that available.
THE WITNESS: It is not here.
MR. CHILDS: You will send it to our office in Little
Rock and we will make it available because we are sort of
in a turmoil this week.
MR. KLASFELD: Okay.
MR. CAMPBELL: For the record, may I send it to Mr.
Kieley or send it to you in New York?
MR. KLASFELD: I think to me in New York.
Q. Could you briefly describe the nature of your
research with crabs?
A. I told you about part of it with --
Q. I understand you observed what was going on
under the shells.
What else did you do?
A. Because it had never been possible to grow them
in the laboratory, I worked on that aspect of it and was
able to bring the crabs all the way from eggs through
larval states to adults in the laboratory.
Q. Did you experiment with conditions that were
conducive to breeding?
A. Yes.
Q. How did you alter the conditions?
A. The main problem was food for the larvae. I
was able to find the right kind of food.
Q. How did you do that?
49
Did you lose a lot of crabs?
A. Yes.
Q. And how did you finally come to finding out the
right way to feed the crabs?
A. Mostly just trial and error and somebody referred
to me or mentioned to me the use of brine shrimp such as
are used to feed tropical fish and they turned out to be
very satisfactory.
Q. Were those the natural source of food for the
crabs?
A. Yes and no.
The natural food is plankton which is floating micro-
scopic organisms.
These brine shrimp are not normally -- don't make up
a very large fraction of the ocean plankton, but they are
floating microorganisms.
Q. Did you use the normal food, the plankton?
A. We tried that.
Q. That didn't work?
A. No.
Q. Do you know why?
A. Plankton is extreme sensitive to changes in
the normal environment.
They do not survive in the laboratory.
Q. So, having won this battle of trial and error
on how to keep the larvae alive, then what did you do?
A. I wrote the dissertation and submitted it.
Q. The research that you did after the completion
50
of your dissertation, what did that consist of?
A. That was applying this technique to other species
of crustaceans that did not have their life cycles undis-
turbed.
Those papers are in the material.
Q. I see.
Did you design experiments for your work with the
crabs?
A. Yes.
The glass shells would certainly be an experimental
design.
Q. And the different feeding techniques?
A. And the different feeding techniques.
Q. Had other people done work in this area and
unable to find the answer or were you just doing work in
an area where people had never done work before?
A. The question concerning the ovulation of the
hermit crabs had been discussed back and forth for ninety
years and not knowing what the answer was.
Q. How would you compare the nature of the research
that you did with the hermit crabs with the research that
you do with the petrified rock?
A. Well, it is really very different except that
research techniques, literature research, applies pretty
broadly in all scientific research.
A doctorate in education is not helpful insomuch as
in the specific area of your dissertation as the methods
