Deposition of Harold G. Coffin - Page 4

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about the Mississippi always happened to have been there?

A. No, not necessarily, but that runoff from the
watershed that the Mississippi now has would have had to
have gone at least into the Gulf of Mexico.

Q. Where did the water come from, from the flood?

A. I think we still have it all. Two-thirds or
more of the earth is water.

Q. Well, didn't the flood cover everything but
Mount Ararat?

A. It covered it, too.

Q. What happened to all of that water that
doesn't cover the one-third of the earth?

A. There was uplift of the continents and
depression of the ocean basins. Waters run off to the
oceans and continents have been exposed.

Q. Do you believe that there was a water vapor
canopy that covered the earth?

A. It depends on what kind of canopy one is
talking about.

Q. What kind of canopy would you be talking about?

A. I could envision, possibly, a vapor canopy,
but not a solid water canopy.

Q. Why was there a flood?

A. The only answer to that is a biblical answer,
and that is because of man's wickedness.

Q. And God created the flood because of it?

A. That's what Scripture says.

Q. When did that take place?

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A. When did it take place?

Q. Yes.

A. Once again, I refer back to evidence such as
the building of the Delta, the Mississippi River, which
would seem to indicate that it has been operating ever
since -- for about four or five thousand years and if it
established itself soon after the floor, that gives us
some idea when the flood occurred.

Q. What would lead you to believe that it began
soon after the flood?

A. I don't think there have been major changes
in the earth's topography since then.

Q. What is the scientific evidence for that?

A. Of course, on the basis of that amount of time,
the scientific evidence would support it.

Q. I am sorry. I don't understand.

A. In other words, if you are figuring a few
thousand years, scientific evidence would support that
there hasn't been that much change.

Q. I suspect that would be the first thing we
have agreed on.

Are you aware of what research had been done to
determine whether or not creation week took place five,
ten or fifteen thousand years ago?

A. I naturally have tried to keep up on such
material.

[Discussion off the record]

MR. KLASFELD: Q. What kind of research have you

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done to determine whether it is five, ten or fifteen
thousand units?

A. I have done some calculations on rates of
erosion which we have already discussed. And, of course,
I have mentioned looking into biblical geneologies as a
means of trying to determine how much time is involved.

Q. As a scientist, you are doing work in
paleontology. You are aware of work in other fields, not
to say you are an expert on this, but you are aware that
they are going on. Are you aware of information which
conflicts with your belief that the surface of the earth
and life on it is more than five to ten thousand years
old?

A. Certainly.

Q. What are some examples of that information?

A. Carbon fourteen dating. Now, I mentioned
carbon fourteen dating because you said the surface of
the earth.

Q. Well, you don't disagree that the earth itself
may be billions of years old?

A. That's an impossibility.

Q. You have no opinion on that?

A. Yes.

Q. So that's why I mentioned the surface.

A. And that's why I went to carbon fourteen.
But if you are thinking of the --

Q. I want to talk about only what we disagree
about.

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about.

A. -- of the fossils below the surface of the
earth, then, of course, potassium, argon, fission,
uranium, lead, so on are used, also.

Q. And those are arguments for the fact that
there was life on the earth billions of years ago, is
that true?

A. Billions of years ago, yes. Just a minute.
No, let's back up.

Q. Millions?

A. Millions of years ago.

Q. Our differences are so great, why quibble if
it is millions or billions.

A. Well, we want to be accurate on this record.

Q. You are right. I am sorry, It is late.

How do you factor that in, into your thinking that
there is a related branch of science whose evidence leads
the scientists specializing in that field to believe that
life was begun on earth millions of years ago?

A. There are problems with the radioactive dating
methods. They are not sure-fire.

Q. What are the problems?

A. If catastrophism is a reality, and many
geologists are coming to a limited form of catastrophism,
that would definitely have an effect of these radio-
active dating methods.

Q. Are there any tests that have been conducted
that have brought the radioactive dating methods into

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doubt?

A. Yes.

Q. What are they?

A. One of your witnesses has done so, Dalrimple.

Q. What percentage difference does he find?

A. Well, he has found that the deeper in water
an eruption occurs, the more argon is retained within the
sample and the older the age appears for the same
eruption.

Q. What about non-eruption evidences?

A. Well, most of your radioactive dating methods
are used in plutonic or volcanic materials.

Q. Are you referring to one particular area that
he has talked about?

A. Well, that previous reference to change in
age on depth was researched in Hawaii.

Q. And was the conclusion he reached in that
research that they were getting a large number of
aberrant data?

A. No. Well, depends on what you mean by the
word "aberrant." His conclusion was that rapid cooling
and pressure of the water trapped in argon so that there
was a direct proportion of depth to age.

Q. You don't mean to suggest, do you, that Mr.
Dalrimple has any doubt about the efficacy of radiometric
dating as an effective dating tool, do you?

A. No, I am not suggesting that he feels it is
unreliable.

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Q. Do you respect him as a scientist?

A. Yes, I do.

Q. Understanding that there is someone you respect
as a scientist who believes life on earth came in to being
hundreds of millions of years ago, how do you factor that
in with your own belief about the fossil record?

A. Much of the information, such as he has
presented and many, many others have presented, the
facts, that is, the basic raw material is used by both
evolutionists and creationists, but the interpretation
is different.

Q. Well, what's your interpretation of the facts
that Mr. Dalrimple has produced?

A. My interpretation is that this indicates that
we should be extremely careful about -- let's be
specific, here -- potassium, argon dating because if a
world-wide catastrophy did occur, then it may be that a
great deal of the volcanic material on which potassium-
argon dating is implied, has been affected by this
matter on water and water pressure and rapid cooling.

Q. But Mr. Dalrimple isn't concerned about this,
is he?

A. I have had correspondence with him some time
back but I haven't discussed that aspect of it. By the
way, you asked me awhile ago if I had correspondence with
any of these people and I said no. I will have to take
that back. I did have a letter or two from him. That
was a number of years ago.

157

Q. Right. But there is no doubt in your mind
that he believes that animal --

A. No, I have no intention and I hope I haven't
given that impression or suggested that he has doubts.
I just want to indicate that with someone with a different
paradigm, a different world view of the information can
lead in another direction.

Q. Does Mr. Dalrimple have a paradigm?

A. Certainly.

Q. Is he an evolutionist?

A. No one can go into research without some
paradigm.

Q. But he is just studying the age. Would he
have cared if he found out if the age was five million
years or forty million years?

When he started to study radiometric dating, did he
have an interest in how it came out?

A. Yes.

Q. What was his interest?

A. His interest was to fit in with the paradigm
in which he is in favor.

Q. Which paradigm is that?

A. An evolutionary paradigm.

Q. Have you discussed with Mr. Dalrimple his
interest in evolution?

A. No, I haven't.

Q. How do you know he has one?

A. It is impossible for a person not to have his

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bias. This applies to both creationists and evolutionists.
It influences what he is doing.

Q. Couldn't he say I am just a guy who is studying
radiometric dating. I don't care whether or not it gave
anybody the opportunity to evolve into man. I am just
looking at the rocks.

A. That was the idea of Roger Bacon when the
scientific revolution actually began, but actually it
doesn't work that way. That would be what you would call
trial and error method; just a complete random type of
science. Although it can be done, it is an extremely slow
laborious process.

Q. How did Mr. Dalrimple's bias come into play in
his work?

A. If I had done the research and were writing it
up, I suppose I would have emphasized even more than he did
the fact that it can be interpreted in another way.

Q. What is your own bias?

A. My own bias is that, well, to save time, those
steps in the creation statement.

Q. You are referring to 590?

A. Yes.

[Discussion off the record]

MR. KLASFELD: Q. The six criteria in Act 590 that
you have described as your bias, does your bias stem from
your reading of the Scripture?

A. That's involved, yes.

Q. To what extent is it involved?

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A. I believe that God, that a creator, is
responsible for both nature and Scripture, and that truth
can be arrived at by a study of both.

Q. Just very briefly, would you expect that your
testimony about the fossil record would contain generally
the same arguments that Gish makes in his book?

A. Basically, yes.

MR. KLASFELD: I will start my speech for the record,
now, and allow Dr. Coffin to leave.

[Discussion off the record]

MR. KLASFELD: As agreed, it being 4:00 o'clock,
Dr. Coffin has left. In addition to not sufficiently being
able to inquire as to Dr. Coffin's testimony because that
testimony has not been prepared yet, the fact that the
deposition was forced to end at 4:00 o'clock, despite the
fact that I was prepared to continue, has not allowed me
to complete my deposition of Dr. Coffin even as to matters
that we were in a position to discuss today.

I would request now that the other witnesses that
are made available to us this week, that we be allowed to
conduct our depositions until after 4:00 or until such
time as they are completed rather than be arbitrarily
limited to a 4:00 o'clock time. I think that's what we
are entitled to under the Federal Rules.

MR. CHILDS: The only think I would say is that I
wish we kept the materials here when Dr. Coffin produced
them and then worry about making the copies tonight.
I think that was a mistake.

160

MR. KLASFELD: I have, Mr. Childs, made two
different objections to the conduct of the deposition today.
One of them was to the fact that the material wasn't made
available to us earlier; that Dr. Coffin had made no
effort to prepare his testimony earlier. In addition,
my second problem was that the deposition was limited to
4:00 o'clock when I was prepared to continue until I was
finished with my inquiry and I suppose that that's a
matter that, unless you are willing to agree that the
future depositions will continue until the people taking
the deposition are finished, which I would hope you would
agree to, would be another matter that we would discuss
with the judge tomorrow.

MR. CAMPBELL: Is that your statement?

MR. KLASFELD: Yes.

MR. CAMPBELL: In response to that just for the record,
too, David, when we opened the deposition this morning,
we informed you that Dr. Coffin would be leaving at 4:00
p.m. this afternoon. I think local counsel for the
plaintiffs in this lawsuit was aware, at least sometime
last week, that in order to take approximately thirty
depositions in the next eleven days, there would have to
be some time constraint on both sides to take depositions.

As a matter of fact, defendants have agreed to limit
their depositions of plaintiffs' experts to four hours or
less and take two consecutive depositions.

Dr. Coffin was available, I would say, approximately
five and a half hours to six hours today. The motion or

161

notice for deposition, which the plaintiffs' counsel filed
in this case, asked Dr. Coffin to bring these materials
to the deposition. In other words, there was no request
that the documents be provided to you any earlier than
at the deposition today. So your objection with regard
to seeing the documents before this time I think is
unwarranted in light of your own request to bring the
documents to the deposition.

The judge has indicated on the October 1st pretrial
conference date with regard to the deposition of Mr.
Paul Elwynger in South Carolina that he was not impressed
or inclined to read a nine-hour deposition of any witness.
We believe, just for purposes of the record, too, a
deposition lasting longer than six hours is burdensome
and is oppressive, particularly in light of the expedited
trial schedule and in light of the fact that the number
of witnesses which must be deposed by both parties prior
to the trial date.

[Discussion off the record]

MR. CHILDS: I would like to say one thing on the
record. I am sure when Judge Overton reads the deposition,
he is going to realize that counsel for plaintiff did a
tremendous job and discovered everything that you could
possibly want to know from Dr. Coffin.

[Discussion off the record]

[Recess]

MR. CHILDS: Plaintiffs' collective Exhibit 7 is a
group of documents approximately four and a half inches

162

thick which will be attached and filed with the original
deposition.

[Document more particularly
described in index was marked
for identification as
Plaintiffs' Exhibit No. 7.]

MR. CHILDS: Plaintiffs' Exhibit 8 is a number of
pages from a book beginning page 369 through the last
page number shown which is page 449 appearing in Science
and Health; Department of Education; General Conference
of Seventh-Day Adventists; Health-Science Series; Pacific
Press Publishing Association; Mountain View, California;
Omaha, Nebraska; Calgary, Alberta; copyright 1974 by the
Department of Education, General Conference of Seventh-Day
Adventists, Washington, D.C.; all rights reserved.

[Aforementioned document marked
for identification as Plaintiffs'
Exhibit No. 8.]

MR. CHILDS: Plaintiffs' 9 is Science and Health
Series; Review and Herald Publishing Assocation, 6856
Eastern Aveue, Northwest, Washington, D.C. 20012; copyright
1974 by the Department of Education, General Conference
of Seventh-Day Adventists, Washington, D.C. 20012; all
rights reserved and showing the first page number as
331 and the last page shown is 495.

[Aforementioned document marked
for identification as Plaintiffs'
Exhibit No. 9.]

MR. CHILDS: A book that has not been made an exhibit

163

but which was provided during the deposition by Dr.
Coffin is Creation-Accident or Design? showing Harold G.
Coffin, Ph.D., Research Professor, Geoscience Research
Institute, Professor of Paleontology, Andrews University,
showing Review and Herald Publishing Association,
Washington, D.C., copyright 1969 by the Review and Herald
Publishing Association, Library of Congress Catalog Card
No. 68-18744, containing 512 pages which you will send
this to Little Rock to us?

MR. KLASFELD: Yes.

__________________________________
DR. HAROLD G. COFFIN

164

STATE OF CALIFORNIA )

) ss.

CITY AND COUNTY OF SAN FRANCISCO )

I hereby certify that the witness in the foregoing
deposition named

DR. HAROLD G. COFFIN

was by me duly sworn to testify the truth, the whole
truth and nothing but the truth in the within-entitled
cause; that said deposition was taken at the time and
place therein stated; that the testimony of said witness
was reported by

DEAN MC DONALD and LINDA L. CHAVEZ,

Certified Shorthand Reporters and disinterested persons,
and was thereafter transcribed into typewriting, and that
the pertinent provisions of the applicable code or rules
of civil procedure relating to the original transcript
of deposition for reading, correcting and signing have
been complied with.

And I further certify that I am not of counsel or
attorney for either or any of the parties to said
deposition, nor in any way interested in the outcome of
the cause in said caption.

IN WITNESS WHEREOF, I have hereunto set my hand
and affixed my seal of office the ___ day of November
1981.

_________________________________