Deposition of Dr. G. Brent Dalrymple
Deposition of Dr. G. Brent Dalrymple (U.S. Geological Survey, Menlo Park, CA) - transcript paragraph formatted version. (Plaintiffs Witness)
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ANSWERS AND DEPOSITION OF G. BRENT DALRYMPLE, Ph.D.,
a witness produced on behalf of the Defendant, taken in the above style and numbered cause on the 3rd of December, 1981, before Laura D. Bushman, a Notary Public in and for Pulaski County, Arkansas, at the office Mr. Robert Cearley, 1014 West 3rd Street, Little Rock, Arkansas at 10:35 a.m., pursuant to the agreement thereinafter set forth.
G. BRENT DALRYMPLE, Ph.D.
the witness hereinbefore named, being first duly cautioned and sworn to tell the truth, the whole truth, and nothing but the truth testified as follows:
DIRECT EXAMINATION
BY MR. WILLIAMS:
Q. Would you please state your full name, please?
A. Gary Brent Dalrymple.
MR. WOLFE: David, perhaps before we begin we ought to speak about the documents.
MR. WILLIAMS: All right, sir.
MR. WOLFE: Dr. Dalrymple has — has made a document production in response to defendants request for documents. The only two points of interest about the production are that Mr. Williams and I have agreed that all the materials which were not reprints of published articles will be given circulation limited to the purposes of this lawsuit, and I've also informed Mr. Williams that plaintiffs
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have withheld certain products under the Work Product Doctrine. They are specifically certain letters and notes, and reprints of a few articles which were sent and exchanged
between Dr. Dalrymple and attorneys for plaintiffs in preparing the case, and a proposed question and answer list relating to Dr. Dalrymple's possible testimony.
MR. WILLIAMS: Is that it?
MR. WOLFE: That's it.
MR. WILLIAMS: For the record, I want to object to the claim of Work Product Privilege. I think that this is not the client of the plaintiff — of these — of these attorneys. Mr. — Dr. Dalrymple is an expert witness who is supposed to be testifying objectively. Therefore to claim a Work Product Privilege on parti — particularly documents that he has written, I think it's inappropriate and not supported by the law. Further, I think it is particularly inappropriate in light of what I think will be shown in this deposition that Dr. Dalrymple is not supposed to be testifying for either side but presenting objective facts in this case. Therefore to claim the Work Product Privilege when he is not to be a witness for either side is — is — is particularly inappropriate.
MR. WOLFE: Well, we certainly agree that — that there is no attorney/client relationship here and the Work Product Doctrine is asserted because the questions
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that were addressed to Dr. Dalrymple and the areas that he was asked to consider we regard as evidencing the workings of the minds of the attorneys on the plaintiffs' side here, and that's the basis for our asserted privilege.
BY MR. WILLIAMS:
Q. Dr. Dalrymple, have you ever had a deposition taken before?
A. No.
Q. Have you ever testified in court before?
A. No.
Q. Has Mr. Wolfe or some other attorney for the plaintiffs explained to you what a deposition is?
A. Yes.
Q. All right. Well, then if I do ask any questions that are unclear, I want you to please tell me so and I will try to make them clear. There will probably be several when I get into some of the — some of the dating methods.
A. Okay.
Q. Also, let me tell you that our purpose here is to simply try to discover what your testimony might be, and as this colloquia we just had over the — over the Work Pro — Product that doesn't concern you personally I don't think, and we are simply trying to make our record in — in doing our job for our clients.
A. I understand.
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Q. I've been supplied with a copy of a document which appears to be your curriculum vitae. I would like to have this marked as exhibit — defendants' exhibit one to the deposition.
[Thereupon State's Exhibit #1 was marked for the record.]
Q. Can you identify that as being your curriculum vitae?
A. Yes.
Q. It includes a list of publications. Is that correct?
A. That's right.
Q. Is that list of publications everything that you have ever had published not limited — I'm not limiting myself now but — now to simply scientific articles?
A. Yes. The only thing I've ever had published has been scientific articles.
Q. Where are your daughters attending school?
A. At Gunn High School in Palo Alto.
Q. Is that a public or private school?
A. That's a public school.
Q. Do you know if they have taken any science courses as of yet?
A. Yes, they have
Q. What courses have they taken?
A. Well, I don't think I can remember a complete list they have taken mathematics, general science courses.
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My two older daughters have taken a course in biology. My oldest daughter is taking a physics. Two oldest ones have had courses in chemistry.
Q. Uh-huh. Do you know whether the creation-science model or theory of origin was ever mentioned in a classroom?
A. As far as I know, it was not.
Q. Has the evolution-science model or theory of origins ever been mentioned in their classroom?
A. In the — they were taught some evolution in the biology course and perhaps another general science course. I really don't know.
Q. Are you aware that back in 1969, I think it was, that the California Board of Education issued a statement on creation-science as being — it — I'm paraphrasing now so I'm — I — `a scientific alternative to evolution'?
A. I am generally aware that at one time they did make such a statement, yes. Then it was later revised.
Q. That was later revised? But — but to your knowledge as a citizen of the state of California do — do you know whether in Palo Alto public schools for example whether creation-science was presented pursuant to that resolution?
A. I have no knowledge one way or the other.
Q. Is your wife employed? I — she's a teacher according to your vitae I —
A. She's a teacher
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Q. Where does she — she teach?
A. She teaches at a private school.
Q. What school is that?
A. It's called Pinewood. Pinewood Private School in Los Altos.
Q. Is that — what does she teach there?
A. She teaches mathematics presently to six grade, I believe.
Q. What is her degree?
A. She has a bachelor's degree.
Q. In what area?
A. Education.
Q. Elementary education or —
A. Yes.
Q. Is that a private school or affiliated with any group or church?
A. No. It's — it's purely a private school. It's nonprofit.
Q. Nonprofit.
A. It's not affiliated with any church.
Q. Do you know whether in that school the creation-science model of origins is discussed?
A. I have not heard that it is.
Q. Is that school to your knowledge — well, how long has that school been in existence?
A. I don't know but for many years.
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Q. Do you know who formed it or the reasons why it was formed?
A. I — I know who — I know who formed it. I do not know the reasons why it was formed.
Q. Who formed it?
A. I'm trying to think of their names and now I've forgotten them. Perhaps it will come to me later, I'm sorry.
Q. Okay. Has it at any time been affiliated with any — any group, any religious sect or any other group?
A. To my knowledge, the school has not.
Q. Why does your wife teach in a public a private school as opposed to a public school?
A. Because at present, positions in public schools are extremely hard to get in California and at one time she did teach in a public school and then she quit to have a family, and when she went back jobs were not easily available particularly in Palo Alto.
Q. Are you a member of any organized religious faith?
A. No.
Q. Have you ever been a member?
A. When I was a teenager I attended church regularly, yes.
Q. What church did you attend at that time?
A. A variety. Methodists, Baptists, Friends, a few services in a Catholic church.
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Q. Were you ever a member of any of those churches?
A. No.
Q. When did you begin attending churches, your — as I best you recall now?
A. I really can't remember. When I was quite small.
Q. When did you cease to attend church services?
A. When I was in my mid-teens.
Q. What is your personal opinion as to the existence of a god?
A. Well, I — hmm. The reason I am pausing is because I don't normally give that question much thought. I have seen no evidence that requires me personally to believe in a god.
Q. Do you have any statement of your religious faith that you would subscribe to or the lack thereof?
A. I have never tried to put myself in a category if that is what you're — what you're asking.
Q. Well, I am sure you are familiar with the terms which are sometimes used such as deist, agnostic, atheist. Would any term or any such similar term be accurate in describing your own religious faith?
A. I have not studied the definition of those carefully enough that I think I want to commit to one or the other. If you would care to define for me maybe I could —
Q. Well, if a deist means simply that someone who believes
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there is some sort of sub — god but not in the sense of a personality, as a person, as a personality or maybe — maybe agnostic is someone who doubts the existence of a god and an atheistic is one who believes that there is no god. Between those three terms could one more accurately describe your own views?
A. Well, I guess perhaps half way between an agnostic and an atheistic.
Q. Okay.
A. I try to remain open minded on questions like that.
Q. You said you have seen no evidence which would require you to believe that there is a god. Do you — for you to believe that would there have to be some evidence?
A. Yes.
Q. What sort of evidence do you think it would take to convince you?
A. I am a scientist and I tend to deal in scientific evidence but that's a difficult question to answer because, I know people at certain stages of their life sometimes are willing to accept evidence and other times they're not. So I guess the answer to your question is I don't know.
Q. You're not aware of what — of what evidence it would take?
A. No. Because I think that would be a highly personal happening, if and when it ever did happen and I'm not sure
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how that would happen or what it would take.
Q. Okay. Did you at one time when you were attending church in your childhood and your teens, did you at that time have a belief in a god?
A. I think that I was brought up to have a belief in a god. My family had a tradition of such beliefs. Is — does that answer your question?
Q. Well, you were brought up to — no, I don't think that really it does. Because I asked you did you have?
A. I'm not sure how — how fastly I ever held that belief. One of the reasons I went to different church with what — what I was hearing. So I think that I was more inquisitive then held any belief very hardly.
Q. Do you think that a religious person can be a competent scientist?
A. Oh, yes.
Q. Do you think that a person — do you think there is any correlation between the presence and degree of a person's religious faith and their competence as a scientist?
A. I don't think there has to be but it depends on how the individual wants those two disciplines to interact, I think.
Q. Do you have a — heard of a code of personal conduct?
A. Yes.
Q. Could you describe it for me?
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A. Well, I think it pretty much probably parallels to the Ten Commandments. I come from basically a Christian background and I think that the morals and code of ethics that are taught there are — are fairly valuable to — including not lying, cheating, stealing, hurting other people and so forth.
Q. Have you ever been a member of any other sort of group such as the ethic — Ethical Society or Society of Religious Humanists or any group like that?
A. No.
Q. Where are you presently employed?
A. I am employed by the Department of Interior, Geological Survey in Menlo Park, California.
Q. And what position do you hold there?
A. I am the assistant chief geologist for the western region.
Q. Okay. Would you just very briefly describe what the purpose of the U.S. Geological Survey is?
A. Well, it has a multiplicity of purposes. It conducts geological research, it makes topographic maps of the United States and its territories, it manages and collects royalties on mineral and oil resources on federal lands and it's concerned with water quantity and quality throughout the United States.
Q. How long have you been involved — been employed in
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one capacity or another for the U.S. Geological Survey?
A. It's been since about June of 1963. So that would be about what — about eighteen years. Eighteen and a half.
Q. And prior to that time you were with the National Foun — Foundation?
A. No. I was a student at the University of California at Berkeley.
Q. From when to when?
A. Well, that would have been from about September of 1959 until June of 1963.
Q. And you received your Ph.D. in 1963, correct?
A. That's correct.
Q. Did you write a dissertation?
A. Yes. I did.
Q. What was the topic of your dissertation?
A. The topic was described in the title. It's the Cenozoic chronology of the Sierra Nevada.
Q. What is Cenozoic?
A. Well, the Cenozoic is a period of geologic time that goes from the present back to about sixty-five or seventy million years.
Q. How is that spelled?
A. C-E-N-O-Z-O-I-C. Usually with a capital C.
Q. When did you first study radiometric dating?
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A. When I was first a graduate student at Berkeley.
Q. What is Occidental College?
A. That's a liberal arts college in southern California.
Q. Is it affiliated with any private groups?
A. Not — it's a private school if that is what you are asking?
Q. Right. Is it affiliated with any sort of private groups such as religious or specific groups?
A. It has not been affiliated with a religious group for many decades. I do not recall but there originally was, I believe.
Q. As assistant chief geologist, are your duties more administrative than they are research?
A. Yes. I've only held that position for a few months, however.
Q. Since May?
A. The end of May or the first of June, yes.
Q. What area is covered by the western region?
A. It consists of the six western states plus Alaska plus Hawaii and the Pacific trust territories. Would you like me to name the states?
Q. No. That's all right. And prior to that time you were branch representative for the Menlo Park, Branch of Isotope Geology?
A. That's correct
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Q. Were your duties there more in the area of research or administration?
A. Primarily research.
Q. Of your publications, approximately how many have been written in the course of your employment?
A. With the Geological Survey?
Q. Yes.
A. All but about two, I believe.
Q. I also notice that on your list of publications there is either a P or an A or in some cases there is an O. What do those represent?
A. The P's are publications published in the traditional scientific literature. The A's are abstracts for scientific meetings. We normally don't count those as publications. They are brief paragraphs describing a talk. And the O's, if I remember correctly, are internal administrative type reports but the ones listed in there are — are scientific internal administrative reports.
Q. So you have studied radiometric dating for approximately I twenty-one years, is that correct?
A. That's approximately correct.
Q. When did the concept of radiometric dating originate?
A. It started with a paper by Boltwood in the early 1900's shortly after it became known that there was such a thing as radioactivity.
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Q. And could you just briefly sketch for me the history of radiometric dating in terms of it's acceptance within the scientific community as you view it?
A. Well, I think it was accepted as a viable possibility from — from the earliest proposal that such a scheme might work.
Q. Uh-huh.
A. But in the early days not all of the physical principles had been developed. For example, when the first lead ages had been — were calculated by Boltwood it was not known that there were things like isotopes and there was not equipment developed then to measure them. I think it's been accepted as an accurate, reliable technique generally for probably close to thirty years now. It's —
Q. For the rate continually —
A. — continually improves.
Q. All right. But there was a period there of — in the early 1900's until approximately in somewhere of the 1940's 50's when it was — it was not fully accepted, is that correct?
A. That's correct. It was highly experimental. There seemed to be lots of problems and gradually those have been overcome.
Q. Is there one point to which you can direct me or one article or event in which — kind of established radiometric
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dating in your mind as being scientific and eliminated the problems which had been viewed earlier?
A. I don't think so. Because there are a variety of different radiometric techniques and each one has it's own history and most of them have evolved through a series of experiments from things that were highly speculative to an end point which is considered highly reliable. And I don't think there was any single point probably in any of those that would — would have been considered definitive.
Q. Prior to the rise of radiometric dating as a dating technique, what techniques were utilized in the scientific community?
A. To do what?
Q. To date — to date rocks and to date — date the earth?
A. Oh, there were a variety of things that were attempted including rates of sedimentation, cooling of the earth. Geologists used to attempt to estimate the age of the earth based on the general rate at which they saw general processes working and none of those worked very well.
Q. Have all of those now been discarded?
A. Yes.
Q. You are a member, actually a fellow I think of The Geophysical Society of America? Could you briefly describe what The Geophysical Society of America is?
A. You mean the American Geophysical Union?
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Q. No. The Geophysical Society of America. Oh, excuse me. I'm sorry. I think I was reading on two lines. It's Geological Society of America.
A. Geological Society of America. Okay. That's I suppose the principal geological organization of geoscientists in the United States perhaps in North America.
Q. What's the active membership to your knowledge?
A. I really don't know.
Q. And when were you selected a fellow? Were you elected first of all?
A. Well, a fellowship in The Geological Society is not elected.
Q. Okay.
A. It's after five years you can apply and I think pay a small fee and you're made a fellow. That's not true of some of the other societies like the AGU. That's a different situation.
Q. The American Geophysical Union. Do you care to describe what that is?
A. That's basically a geophysical society. That consists of an affiliation of oh about a dozen or so sections, each section with different interests. There is a section on volcanology, geochemistry and petrology. There's a section on hydrology. There are sections on upper atmosphere physics. There is a section on planetology.
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Q. What sections are you a member of?
A. Volcanology, geochemistry and petrology. That's one section.
Q. Okay. And you were selected as a fellow by what method?
A. Fellowship in the American Geophysical Union is — is elective. It's restricted to, oh, I think about three per cent of the membership.
Q. When were you elected?
A. Oh, I don't remember. I think it was about 1975.
Q. And what is the American Quaternary —
A. Quaternary.
Q. —Quaternary Association?
A. That is a group of scientists who are interested in problems of the Quaternary period of geologic history which is just the last few million years.
Q. Have any of these societies taken a formal or informal position on creation-science?
A. Not that I know of.
Q. Did you take any courses in biology in the undergraduate or graduate school?
A. No.
Q. Do you have any expertise in the area of biology?
A. No, I do not. I had one course in paleontology as undergraduate. I don't know if you want to include that in biology or not but I'll mention it.
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Q. Okay.
A. In case you'd like to.
Q. Do you recall, you know, in your undergraduate or graduate school days studying theories of origin of the universe, of life, of man and of the earth?
A. I guess that depends on what you mean by origin. If you mean by that the way things were shaped as we now see them, then the answer is yes. If you mean by that ultimate origins, then the answer is no.
Q. Could you explain how you see the difference between those two?
A. Well, the first one is basically how the things that we observe today got to be that way by natural processes. How they I hate to use the word `evolve' but will you let me use it in a different sense? How they change —
Q. You mean it in a nontechnical sense —
A. — in a nonevolutionary sense. Yes, that's right. Okay. The other one, the question of ultimate origins of the universe and of matter is primarily a philosophical or religious subject in that — that I did not study in any of those courses.
Q. Have you ever taken any courses in religion?
A. Yes. At Occidental College everyone was required to take a one semester course, I believe, in religion and the the course consisted of the Bible as literature.
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Q. The Bible as literature?
A. Yes.
Q. Taking then your first definition of theories of origin, how things got to be the way they are today, what courses or what disciplines did you study which would address that subject?
A. Do you mean in a broad sense like geology or specific courses within geology?
Q. First just take the broad sense.
A. Well, I've had courses in geology, some courses in physics and chemistry. Most of them that would fall in that category would be geology.
Q. How many courses in physics or chemistry did you take?
A. Oh, I really don't know. Totalling perhaps half a dozen. I don't remember.
Q. Did you ever study the creation-science model of origins in school?
A. No.
Q. Now, are the three professional societies which you have listed on your curriculum vitae the only groups of which you are a member? Science and non-science?
A. Do I take it then that you mean formalized groups?
Q. I mean formal groups, you know, where you have joined, you are a member.
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A. I belong to a yacht club.
Q. I assume that they have not taken a position on creation-science?
A. As far as I know, they have not.
Q. What is the Society of Irre — Irre — Irreproducible Research?
A. Oh, that's a sort of lighthearted organization to which one really doesn't belong you simply subscribe to their journal which is series of articles that spoof science.
Q. Uh-huh.
A. It's sort of science's Punch if you — if that's a good analogy.
Q. Have you ever written any articles?
A. No. I have been tempted but I've not yet.
Q. What's the American Nuclear Society?
A. That's — that's a group to which I don't belong but which has — which — is that a committee task that you're — Yes. That's — that's a group that is concerned with factors involving nuclear reactors and nuclear standards, and I was invited to be on a working group to write standards for siting earthquake — for siting of nuclear reactors with specific regard to earthquake hazards. I'm not a member of that society.
Q. You said earlier that there were various methods of radiometric dating, is that correct?
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A. That's correct.
Q. Could you list for me what you consider to be the main areas — the main types of radiometric dating?
A. I think potassium-argon including its variation of argon-40/argon-39.
Q. So those would be kind of sub-areas of potassium-argon?
A. Yes. Those are based on the same decays
Q. That's argon-40, you said?
A. Yes. Argon-40/argon-39. And those two go together usually with a slash between them or something like that.
Q. Okay.
A. The difference is basically in how the measurements are made. Rubidium/strontium would be another one. I'll write that one down. Uranium/lead concordia-discordia method.
Q. Uh-huh.
A. Carbon-14 and there are a few new ones that are now being used because analytical techniques have developed to the stage where it is now possible to make measurements it wasn't possible to do before. And those include neodymium-samarium.
Q. Is that neo?
A. Neodymium, yes. N-E-O-D-Y-M-I-U-M. Samarium. S- A-M-A-R-I-U-M. And lutetium, L-U-T-E-C-I-U-M, I believe. I'm not even sure how that one is spelled.
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MR. WOLFE: T. L-U-T-E-T-I-U-M.
BY THE WITNESS:
A. T-I-U-M. That's right. Hafnium. H-A-F-N-I-U-M.
Q. Is this the third one?
A. No.
Q. Oh, part of lutetium?
A. Yeah.
Q. Hafnium? Okay.
A. Now, those are not — the last two are not in terribly common use because the measurements are difficult but they are becoming the principal methods for certain kinds of studies. I think that those are the major ones which is —
Q. Are you — do you consider yourself, placing humility aside, to be an expert in all these areas?
A. I suppose it depends on what you mean by expert. Most of the measurements that I've been involved in myself are concerned with potassium/argon, some with rubidium/strontium and I've studied the others.
Q. Have you ever used the other?
A. I've never used the others.
Q. Why have you used essentially potassium/argon and rubidium/strontium?
A. Those are the two that have probably the broadest applicability for most geologic problems in which I've been interested. In particular, the potassium/argon method.
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Q. A document has been filed in this case earlier which is entitled, Radiometric Dating, Geologic Time, and The Age of The Earth. A Reply to Your "Scientific" Creationism by G. Brent Dalrymple, and it's dated 8-4-81. Did you write this document?
A. The title page looks familiar, yes.
Q. Would you like to —
MR. WOLFE: There's another copy here.
MR. WILLIAMS: Okay. If he — you might want to get that for him.
BY THE WITNESS:
A. Yes.
Q. When did you write this document?
A. I started writing that about March of 1981. And the draft you have was typed on the date that you see on the bottom.
Q. And what was the occasion that you began to write this document?
A. I wrote this after the Segraves trial in California.
Q. Why did you write it after the trial?
A. As you probably know the complaint in that trial was changed so that most of the scientific witnesses did not appear. And some of us discussing our experiences over dinner one evening —
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MR. WOLFE: Excuse me a second —
[Off The Record Discussion.]
BY MR. WILLIAMS:
Q. You — you want to read back what he said?
[Thereupon the Court Reporter read back the preceding answer]
A. — decided to take advantage of the time we had put into preparing for that trial by writing up what we had learned and possibly putting it in a book
Q. And who over dinner discussed this?
A. There was Bill Mayer, Richard Dickerson of Cal Tech, Tom Jukes of Berkeley. I believe Junji Kumimoto was there from UC Riverside and myself. That's all I can remember
Q. Is this going to be published?
A. Yes
Q. Where is it going to be published?
A. We're not sure who the publisher is going to be. We have a tentative agreement with the publisher at the moment
Q. And what publisher is that?
A. It's William Kaufmann Company of Los Altos
Q. And to what audience have you written this? Do you have a plan on to whom it will be marketed and distributed?
A. It's directed primarily at people who have to deal with scientific creationism in their literature It is intended to be a partial reply to some of the criticisms
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that those people have to some of the conclusions of science.
Q. When did you actually first start writing this?
A. I think I said it was in March.
Q. Has your involvement in this case here in Arkansas, has it affected what you have written here?
A. No. That was completed before I was approached about this.
Q. Have you read Act 590?
A. Yes. I did several months ago.
Q. I am going to refer you to your manuscript. Page 1 the introduction where you state, "scientific creationism as represented by Morris, Kofahl and Segraves and others is a model for the creation and history of the universe based on a literal interpretation of parts of the book of Genesis". Have you made a decision in your own mind if that is what Act 590 requires? The teaching of the literal interpretation of Genesis?
A. Act 590 I think specifies the teaching of scientific creationism and from the body of literature on scientific creationism that I have read that, is the conclusion that that I come to, yes.
Q. Much of the literature on scientific creationism that you have read does include references to religious works, does it not?
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A. Yes.
Q. Are you aware that Act 590 specifically prohibits any religious instruction and also prohibits any references to religious writings?
A. Yes. I am aware of that but I think that would be difficult to do.
Q. So many of the — without asking for a legal judgement are you aware that many of the books and articles on the sci — creation-science of which you have read and on which you may rely may very well violate the Act?
A. Would you repeat that for me?
Q. That many of the articles which you have read may very well violate the Act?
MR. WOLFE: Is that a question and if so I didn't catch it.
BY MR. WILLIAMS
Q. Are you aware of that fact whether they will violate the Act? And I'm not asking for a legal judgment I'm just — just —
MR. WOLFE: No. No. I'm — I'm — object to the form of the question and ask whose view that is that that is a fact and I would like to have that specified within the question.
MR. WILLIAMS: I'm not asking him not if it is a fact but I'm asking him if he is aware
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as to whether many of these publications on scientific creationism which he has read, if he is aware as to whether or not they would violate the Act.
BY THE WITNESS:
A. Well, I — without interpreting the law I don't know how I could answer that.
[Thereupon State's Exhibit #2 was marked for the record.]
Q. Let me show you what has been marked as State's Exhibit #2 and ask you to look at it and tell me if you can identify that — those documents, please?
A. Is this the top sheet or the whole package?
Q. The whole package is State's exhibit. Can you identify that?
A. Yes. That's a reply that I received from Bill Mayer.
Q. Do you have the letter that you sent to him?
A. I could not find it.
Q. Did you — could you tell me as best you recall what your letter to him said?
A. Well, I asked him if he could send me any copies of resolutions opposing the teaching of creationism as science from professional scientific organizations. And in reply he sent me that letter and the copies that are attached to it.
Q. Why did you write him for — for those resolutions?
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A. I was interested in the possibility of drafting a similar resolution for the American Geophysical Union and I wanted to find out what other societies had said.
Q. Why did you become interested in drafting a resolution for the American Geophysical Union?
A. Because I thought it was fairly important that religious subjects not be introduced in the science classroom and I thought it was appropriate for the AGU to at least consider this matter as part of their involvement in science education.
Q. When did you first decide that you were going to try to draft a resolution?
A. Well, I don't remember. Spring or summer. What is the date on Bill Mayer's letter? It would not have been too much before that?
Q. March 30 of 1981.
A. Okay. It would have been in March then.
Q. Do you have any authority within the AGU for resolutions on education?
A. I'm the secretary of the section of volcanology, geochemistry and petrology and as such am an officer of one of the sections. And any member is allowed to submit any matter for consideration by the council. Yes.
Q. But are you charged with the responsibility of either drafting resolutions or being responsible for matters in education within that organization?
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A. No more so than any other officer or member of the AGU.
Q. Are any other officers charged with that responsibility, either responsibility?
A. Well, the officers of the AGU are charged with the responsibility to oversee all the functions of the society and one of those includes attitudes toward public education. There is also a committee on — on education — science education.
I don't remember the exact title of that committee. I'm not a member of that committee.
Q. Who is chairman of that committee?
A. His name is Chris Russell.
Q. What specifically motivated you to write Bill Mayer and drafting such a resolution?
A. My motivation was that I think it would be very unhealthy for science and the public at large to teach nonscience topics as science in the public schools.
Q. Was there any one event which prompted you to take this course of action?
A. I — not specifically but I think if there was one event it was probably the Segraves trial.
Q. What involvement did you play in the Segraves — role did you take in the Segraves trial?
A. Well, in the end I played virtually no role but I was asked by the Deputy Attorney General of California to appear as witness. And did go to Sacramento and was prepared to
33
appear on essentially the same basis that I am appearing here, but the complaint was changed and I did not in fact appear.
Q. In anticipation of your testimony in that case, did you review books or works on creation-science or scientific creationism?
A. Yes I did. On request from the Deputy Attorney General.
Q. And how did you select which books you reviewed or articles?
A. I started with the ones that he sent to me and some of those books or articles referred to other articles which I then obtained and read in whole or in part.
Q. Was that your first exposure to creation-science?
A. It was not my first exposure, but it was my first involvement.
Q. Do you recall when you were first exposed to creation-science or scientific creation?
A. Yes. It was back in approximately 1975 give or take a year when Duane Gish and Henry Morris of the Creation Research Institute came to Menlo Park to give a talk at the Geological Survey to a group of geologists. There were several hundred present at the evening lecture. And the next morning they requested a tour of the radiometric dating labs which a colleague of mine and I gave them. And I sat down across the table with Morris and Gish and we
34
discussed scientific creationism and the second law of thermodynamics for about thirty minutes. They had a tour of the laboratory and that was the complete extent. After — after they left they had left copies of some of their works including a book by Henry Morris called, Scientific Creationism: Public School-Edition, and I believe a paper by Slusher, "Critique of Radiometric Dating" and a paper by Thomas Barnes on The Decay of the Magnetic Field. And I read through those just out of interest after hearing their talk, and then I put the matter aside and didn't even think about it until contacted by the State of California.
Q. What was the subject of the talk that evening?
A. Well I don't remember what the titles were. Each of them gave, a — gave a talk. It was basically what they considered to be the scientific evidence for creationism.
Q. And do you recall now what your response or opinion was of their talks?
A. Well, I thought scientifically they were extremely poor talks.
Q. Is that all that you can recall about your reactions to it?
A. I was somewhat appalled that they were attempting to pass what appeared to be religious beliefs as science.
Q. Do you know if you plan to rely on any statements that were made during that talk or that meeting that you
35
had with them in your testimony in this case?
A. Not as far as I know, no.
Q. Do you recall if they talked about Genesis during that talk?
A. I don't really remember specifically what the topics were. That's been a long time ago.
Q. In 1975 you had that brief involvement and exposure to creation-science or scientific creationism at least as practiced or espoused by these two individuals?
A. Yes
Q. And then you say your next involvement was not until the Segraves case in California?
A. A few months before the Segraves case when I was contacted by the Deputy Attorney General and he asked me to read and evaluate some of their literature.
Q. When were you contacted by the California Attorney General's office?
A. I don't remember I think it was about December in the year before but I'm not clear. It was — it was a few months before the trial.
Q. What year was that now? That would be September —
A. Well, that would have been in late — late 1980, very late 1980 or perhaps it could have been January 1981. I just don't recall.
Q. During that five year period, did you make any effort
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to try to read on any basis, regular or irregular, some of the scientific creation-science literature?
A. No.
[Thereupon State's Exhibit #3 was marked for the record.]
Q. Dr. Dalrymple, I want to show to you what has been marked as State's Exhibit #3 and ask you to look at that document and tell me if you can identify it?
A. Yes, I can.
Q. And what is it?
A. Well, that's the series of correspondence between myself and other officers of the AGU discussing a draft of a resolution opposing the teaching of scientific creationism as science.
Q. When were you first contacted about possibly testifying in this case?
A. I don't remember, but I think I have that in a notebook which is here today. If you would like me to look that up I probably could find that out?
Q. I would like you to.
A. This may take a little time.
Q. While your looking through let me inquire of Mr. Wolfe —
MR. WILLIAMS: Is the notebook that he is looking through something you claim is a privilege,
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a Work product?
MR. WOLFE: Off the record.
[Off the Record Discussion.]
BY THE WITNESS:
A. The contact that I have is September 17th.
Q. 1981?
A. 1981.
Q. The second page of the Exhibit #3 to your deposition is styled a, "Resolution Opposing the Teaching of Creationism as Science in the Public Schools Draft 19 May 1981". Did you personally draft this?
A. Yes, I did.
Q. And did you model this after any other resolution?
A. It's a — it's a composite model after many of the resolutions in that exhibit package plus some statements that would be specifically appropriate to the AGU.
Q. In this resolution or draft of a resolution it says, "science is the rational investigation of the physical world and its phenomena". Is that a definition of science to which you would ascribe?
A. That's a fairly accurate single sentence definition.
Q. What else would you add to the definition of science?
A. Well, if I had to broaden that a bit I think I would say that science is a system of thought or endeavor that attempts to determine the history and natural laws of the
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physical world and its parts, and that it excludes supernatural causes. I think that would be a more complete definition.
Q. Is a definition of science a matter of science? Does it follow within a realm of science?
A. I think so.
Q. Or is it a matter of philosophy?
A. I think the boundary between science and philosophy is a matter of discussion for both disciplines but the definition of science is probably primarily a matter of — left to science. But I say that with the qualification I'm not a philosopher.
Q. On what basis do you define science?
A. I thought I just defined it for you.
Q. I'm — I'm not asking for your definition, I'm asking on what basis you have arrived at that definition? Have you taken it from somewhere else; have you formulated this yourself?
A. Well, throughout my career I've been exposed to various parts of the philosophy of science and I think parts of that definition you also find in Websters Dictionary. In order to practice science one has to know what it is.
Q. What do you mean by the term of rational investigation of the physical world and its phenomena?
A. In the sense that I used it there, I think it's probably, I mean a logical — logical use of physical facts.
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Q. Is there a difference between science or what a scientific theory is to you?
A. Oh, yes.
Q. Could you describe the difference?
A. Well, science is the entire field of scientific endeavor. Scientific theory is one of the tools that scientists work with.
Q. What is a scientific theory to you?
A. A scientific theory is a framework for explaining a large body of physical data. And usually by the time that something becomes generally accepted as the theory there is a rather large preponderance of physical data to support it.
Q. I want to make sure that I got this correctly. A framework for explaining a large amount of physical data, is that what you said?
A. Yes. Connected physical data not random physical data. And I guess what I'm saying is that I don't know of any very tiny theories. Most of them tend to encompass large pieces of science.
Q. You state that science — in your resolution that, "the scientific method prohibits any and all appeals to supernatural or divine agents". What do you mean by the term, `appeal'?
MR. WOLFE: Excuse me. Is that a
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quote?
MR. WILLIAMS: That is a quote. That is a quote.
MR. WOLFE: Could you indicate that on other parts that you are quoting in the future?
MR. WILLIAMS: Sure.
BY THE WITNESS:
A. What do I mean by the word, appeal?
Q. Yeah.
A. Well, I mean one is not permitted to call upon supernatural agents to explain what we see in the physical universe.
Q. You're not allowed to call upon them to —
A. You're not allowed to use those —
Q. — explain them?
A. You're not allowed to use those as an explanation of what we see.
Q. Does that mean that it did not occur?
A. No. That simply means that supernatural causes that science is not equipped to deal with.
Q. What is supernatural?
A. Well, anything that is not natural. Anything that can not be explained by physical laws. And I would include in that appeals to a deity, magic, voodoo, that sort of thing.
Q. When you look at what can be explained by natural law.
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As you look down the road say twenty years from now, do you think that our concepts of what the natural laws are and our knowledge of the natural laws will have changed in those twenty years?
A. Well, if history is any indication of what is going to happen in the future, of course.
Q. We don't — we don't know about all natural laws do we?
A. Of course not. If we did, scientists would be out of business.
Q. So based on our present knowledge of natural law, might there not be things which today would be considered supernatural which as we know more about the laws would be — come into the realm of the natural law?
A. I suppose that's possible.
Q. I guess another way in saying that would be that in trying to explain the natural laws we're unfortunately limited by our own intellects.
MR. WOLFE: Is that a question. If so I object to the form.
MR. WILLIAMS: It is a question.
BY THE WITNESS:
A. Well, we're limited by our intellects, we're limited the extent to which we can observe things and we're limited by our ability to measure things. And I think those situations
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are continually changing.
Q. Is there any distinction in your mind between a supernatural and the divine agent?
A. In the sense that it is used there and the sense that is used in most definitions of science, no. The divine agent would be included under supernatural and by that it only means things that are not concerned with physical law.
Q. On what basis have you made a or reached a conclusion creationism is a religious apologetic?
A. On the basis —
Q. Have you reached that conclusion?
A. Yes, I have. On the basis of reaching — reading the creationist literature.
Q. All right. Could you tell me what you understand religious apologetics to be?
A. It's a framework for expanding — explaining one's religious beliefs.
Q. Do you consider yourself to he an authority on religious apologetics?
A. No. I do not.
Q. Then on what basis have you concluded that creationism is religious apologetics?
A. Well, I looked up apologetics in the Webster's Dictionary and it seemed to fit what I had been reading in the scientific creationist literature.
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Q. Are you relying on any — what you have read anywhere else besides Webster's when you make that statement in this resolution?
A. Well, that plus discussions with colleagues I suppose over things like scientific creationism.
Q. I'd like to show you a copy of Act 590 and refer you specifically to Section 4-a which is the definition of creation science. The 4-a (1). Do you see four by the definition?
A. Yes, I do.
Q. Could you tell me where within Genesis — a literal reading of Genesis that would be found?
A. No. I'm not that familiar with Genesis but there are specific references in some of the creationist literature to — to specific passages in Genesis.
Q. Is that essentially what you are relying on when you make the conclusion that creationism, to paraphrase, is an attempt to reconcile the universe with a literal interpretation of Genesis is — what — the statement you have seen in so called creationist literature, is that what you're relying on when you made this conclusion?
A. Well, yes. I think one has to, you know, if one is interested in knowing what chemistry is you have to study the literature and textbooks of chemistry and in doing so you learn what the subject of chemistry is about. The same is true in geology and I presume that the same is
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true in scientific creationism. I have read within my limited capacity as widely as I could the literature I could get my hands on scientific creationism and I presume that that represents what scientific creationism is.
Q. All right. Have you read any data or read any reports or literature within the referee journals which support creation-science?
A. No. I have not.
Q. Are you aware if there is any?
A. As far as I'm aware, there is none in the trad — traditional scientific literature.
Q. If there were some would that change your opinion?
A. It would depend on how much of it there was and exactly what the evidence was.
Q. Your resolution also states, "it", referring to creationism, "attempts to explain scientific data within the framework of divine biblical revelation as interpreted by certain groups of fundamental Christians". In your reading of Act 590, is there any thing in there that indicates to you that this is biblical revelation interpreted by certain groups of fundamental Christians — funda— fundamental organizations?
A. Well, there again you use the word, creation-science, and I have to take the definition of creation-science from what — from what the creation-scientists provide me.
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You can't define a branch of science in a — in a law. It has to be based on a body of knowledge and that requires literature and textbooks. And I examined what I could in their literature and that tells me what scientific creationism is.
Q. You are aware though, aren't you Dr. Dalrymple, that we're dealing here with creation-science as defined in Act 590 of the Acts of Arkansas?
A. Yes. I understand that. But this requires that you teach something and if it is not based on the traditional scientific literature and it is not based on the literature of scientific creationism then you have me confused. I'm not sure what it is you are going to teach.
Q. As you read Section 4-a which defines creation-science, and I'd like you to read that now and just take a moment.
A. Okay. Including the ones, and twos and threes?
Q. Right. You don't have to read it out loud. Just please tell me when you've completed reading it.
A. Okay.
Q. 4-a (1) states, "sudden creation of the universe, energy and life from nothing". Where to the best of your knowledge of Genesis is that found in Genesis?
A. I could not quote you where that is found. I am not a student of the Bible.
Q. 4-a (2) says, "the insufficiency of mutation
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and natural selection in bringing about developments of all living kinds from a single organism". Is that dealt with anywhere in Genesis to your knowledge?
A. I have — I — I told you I'm not a student, of the Bible and I don't know if or where any of those things are dealt with in the Bible.
Q. Rather than belabor the point, if I read you 4-a (3-6) as well. Would your answer be the same as to where these portions of the definition are found in Genesis that you could not say?
A. I could not give you the chapter or the verse.
Q. Are they found in Genesis?
A. According the creationists, they are.
Q. According to the creationist literature that you have read?
A. According the creationist literature that I have read.
Q. I assume that you are not the only person in the country who utilizes potassium/argon dating or rubidium/ strontium — strontium?
A. That's correct.
Q. And you read other articles on those methods of dating, haven't you?
A. Oh, yes.
Q. Have you agreed with everything that you have read
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in those articles professionally?
A. Not always.
Q. Do you think that each time you have read articles by other people on these methods of dating that they have always fairly characterized what potassium/argon dating is?
A. I think primarily they, yes, they have.
Q. Are you aware — well, my point and I think that you can see and the question that I was going to ask you is simply because someone uses a label for example of potassium/argon dating doesn't mean that they have used it correctly or that you would agree with them, does it?
A. Well, no. That's why we have scientific literatures so that we can read in detail what they have found and draw our conclusions from that. Otherwise the scientific literature would be a collection of opinions and that's not — that's not permitted. We are required to show the evidence and demonstrate how we reach our conclusions.
Q. When you look at scientific evidence is it reasonable as part of the scientific method to infer from scientific evidence? The general principle?
A. I guess I don't know quite what you mean by infer. Do you mean draw up tentative conclusions?
Q. Right. If that is what it means to you? I — I — I don't want to limit —
A. You know, that's what people try to do. They draw up tentative conclusions from their experiments.
[Off The Record Discussion.]
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Q. I'm sorry. Could you read back that last statement?
[Thereupon the court reporter read back the last answer given by the witness.]
Q. This draft resolution states, "The religious doctrine of creationism has no place in any science curriculum." If there is scientific evidence for creation or for the other things included in Act 590, including a relatively recent inception of the earth, do you think that should be taught in a — can appropriately be taught in a public school science classroom?
A. Well, if and when such evidence were gathered and at such time when it became preponderant such that it was believable and was sufficient to overweigh the other evidence that suggests the contrary, then at that time and only at that time it might be an appropriate thing to teach.
Q. So only when it really overcomes evolution to use the term in the broad sense?
A. Well, that's the sense the creationists use it. I have never thought of myself or geology as being evolutionists. But if you're using it in their sense, yes.
Q. Well, let me say that we are dealing with Act 590 and evolution-science, as defined in the Act, does include an inception several billion years ago of the earth.
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A. Several bil —
Q. Yes. Several billion years ago of the earth.
A. Okay.
Q. And that would be your opinion as to the age of the earth; is that not correct?
A. Well, it's not an opinion. It's a conclusion that myself and thousands of other scientists have drawn because the preponderance of evidence is overwhelming in favor of that conclusion.
Q. All right. So to restate, my understanding of your answer is that if there is scientific evidence for creation, it should not be taught in a public school science classroom until such time as it has a preponderance or a majority of the scientific community, or at such time as there is a majority of scientific evidence which supports it.
A. That's a little bit difficult to answer, but let me do it in the best way I can. I think that science classes should teach, as best they can, two things. One is the history of science so we learn the development of ideas. And the second is the present state of scientific knowledge. Now that has to be simplified so much because it's a very complicated subject and you can't teach all of it. Nobody knows all of it.
If any hypothesis, theory, model or set of facts
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becomes supported by enough evidence so that it is generally accepted by the scientific community, then that assumption becomes part of science and it should be taught. But you see, we don't vote on these things. They become accepted by informal consensus.
And so when you say, you know, what if this happens? It's a little difficult to answer that question because we don't know what's going to happen. You see, at present there is overwhelming evidence that the earth is very old. It's virtually 100% of the evidence. Therefore, it is not a feasible hypothesis to propose or to teach as a theory or a hypothesis or anything else that the earth is only 10,000 years old. That's simply not acceptable.
Q. But as I understand your previous answer — and please correct me if I'm wrong — that you don't think that, for example, if there is evidence of a young earth that it should not be taught until such time as it, in effect, overcomes and replaces the evidence which says that the earth is old.
A. That's — that is typically the way that science works, yes.
Q. So for example, if there is a valid scientific theory in the sense that you have defined it and it's a minority scientific theory, you don't think it should be taught in the public school science classroom?
