1 A We just discussed the bill in general. I assumed
2 everybody had read it. They'd had it in their books for
3 quite a while.
4 Q Do you recall that there were a number of materials
5 that you gave us including some material from a man named
6 Luther Sunderland in Apalachin, New York?
7 A No.
8 Q Well, I will show it to you and perhaps that will
9 refresh your recollection. These are a series of
10 documents you gave us. Here is one, "Introducing the
11 Model Teaching of Origins in Public Schools, An Approach
12 that Works" by Luther D. Sunderland, 5 Griffin Drive,
13 Apalachin, New York.
14 A If I gave it to you I am sure I received it.
15 Q Did you note the organizations from whom he
16 suggested that one could obtain creationist materials?
17 A No.
18 Q Could you take a look at that first letter, the one
19 that I have marked for you there, and tell me the names of
20 the organizations from whom he suggests that a public
21 school district looking to institute such a model might
22 obtain material?
23 A You want me to read these off?
24 Q Yes. Would you, please?
25 A Creation Research Society, Model Science
Association, Institute for Creation Research, Creation
401.
1 A (continuing) Science Research Center, Students for
2 Origin Research, Citizens for Fairness in Education.
3 Q Any others?
4 A I don't see anything else.
5 Q In all of the materials that were submitted to you,
6 Senator Holsted, did you ever discover any organization
7 other than those which you have just read which were
8 indicated as organizations from which you might be able to
9 obtain creationist material?
10 A That was not my problem.
11 Q I understand that. I am merely inquiring as to
12 whether you were ever able to ascertain the names of any
13 organizations other than those which you have just read
14 which might be able to furnish such information?
15 MR. WILLIAMS: Your Honor, the question assumes a
16 fact not in evidence. It calls for speculation on the
17 witness' part. There is no showing that Senator Holsted
18 ever tried—
19 THE COURT: All he has to do is say no, as I
20 understand it.
21 THE WITNESS: No.
22 MR. WILLIAMS: For the record, I want to interpose
23 an objection on the grounds that I think this does,
24 perhaps, go to the question of legislative privilege and
25 the immunity that a legislator has to consider whatever he
wants to in passing on a bill.
402.
1 THE COURT: I think if there is anybody can invoke
2 that, that's Senator Holsted if he wants to. I am not
3 sure that privilege goes that far, but if he wants to
4 invoke that—
5 THE WITNESS: What do I get to invoke it?
6 THE COURT: But in any event, not Mr. Williams.
7 THE WITNESS: It will be up to the Department of
8 Education to determine what materials will be used and to
9 obtain materials I received stuff— You wouldn't believe
10 how much stuff I received. Most of it I didn't even look
11 at. I just stuck it in a box.
12 MR. KAPLAN: (Continuing)
13 Q Let me ask you to just take a look at this. Here is
14 the second page of Mr. Sunderland's book—I am sorry, Mr.
15 Sunderland's communication. At the bottom of that first
16 page he describes how somebody might go about reaching a
17 community and convincing folks that they ought to enact a
18 scientific creation approach.
19 Can you tell me the names of the two books that he
20 suggested one obtain and look at in order to do that
21 convincing? Just read that sentence.
22 A He obtained a number of copies of The
23 Creation-Evolution Controversy by Wysong, and Evolution:
24 The Fossils Say No, Public School Edition by Gish.
25
403.
1 Q By the way, Mr. Sunderland was also selling something
2 for fifty dollars, too.
3 A Oh, is that right? I am sure it is. You would be
4 surprised how many people have got stuff to sell.
5 Q Another one of his points, and I think this will be the
6 last one I will ask you about, are these two over here.
7 Will you just read those?
8 A Points on Reaching the Community. Always document
9 your main points with good references. Never use
10 references from creationist books, religious literature or
11 the Bible. Any aspect of the creation model which
12 requires reference to or interpretation of a religious
13 doctrine should be avoided other than the fact, of course,
14 that a Creator did the creating.
15 Q Then just one more thing I want you to look at.
16 This is also in your materials, and this is a list of,
17 from your materials, dated September, 1980, Creation
18 Evolution Material. It says, "The following books,
19 periodicals, pamphlets and tapes offer invaluable aid to
20 those interested in learning more about evolution versus
21 creation." Can you tell me the names of those sources?
22 MR. WILLIAMS: Your Honor, I object to that. I
23 think the characterization is, this is the witness'
24 writing, that the document is his own. I don't think that
25 is correct. I don't know where that came from.
404.
1 THE WITNESS: I never used these in—
2 THE COURT: Mr. Kaplan, the witness never saw them,
3 never used them. I have a hard time seeing how it is
4 admissible through him.
5 MR. KAPLAN: Fine, your Honor.
6 MR. KAPLAN: (Continuing)
7 Q Let me ask you as a final matter, Senator Holsted,
8 whether in your experience the Senate has ever considered
9 a bill, for example, to allow Christian Scientists to be
10 released from health classes or discussion of various
11 matters that might conflict with their religious views?
12 A No. I think the only thing we did last session that
13 I can remember concerning Christian Scientists is, we
14 released, certain designators in the Christian Science
15 faith from jury duty because they were a minister under
16 their designation. We exempt ministers from jury duty.
17 That was the only thing I can think of that was done like
18 that.
19 MR. KAPLAN: That's all I have. Thank you.
20 THE COURT: We will take about a ten minute recess.
21 (Thereupon, Court was in recess from 4:10 p.m.
22 until 4:20 p.m.)
23
24
25
405.
1
2 BY MR. WILLIAMS:
3 Q Senator Holsted, how long does the Arkansas
4 Legislature meet and how often does it meet?
5 A It meets once every two years, constitutionally
6 sixty days. We generally run sometimes eighty, ninety
7 days.
8 Q In that period of time, meeting sixty to eighty
9 days every two years, are all bills given a long
10 deliberative and investigative process by the Legislature?
11 A In the past session we considered over sixteen
12 hundred pieces of legislation that came through the
13 Senate, to either vote on or for our consideration to vote
14 for, and there's no way possible to have hearings on every
15 piece of legislation that comes through. We'd still be
16 going on on last year's bills.
17 Q Is it unusual to have a bill to be considered in
18 committee only for a matter of minutes?
19 A Not at all. This last special session a lot of
20 bills didn't even go to committee. The only thing the
21 committee process does is try to speed up the flow of
22 legislation, because you have different committees meeting
23 all the time to consider many different bills.
24 The best hearing, of course, that's possible is to get
25
406.
1 A (Continuing) it on the floor and all thirty-five
2 senators hear it.
3 Q At the time that you introduced what is now Act
4 590, as to the extent of your knowledge as a layman in
5 science, did you feel that there was and is scientific
6 evidence to support creation science?
7 A Yes, I did.
8 MR. WILLIAMS: No further questions.
9 THE COURT: May this witness be excused?
10 MR. KAPLAN: Yes, Your Honor.
11 MR. CEARLEY: Plaintiffs call Doctor Brent
12 Dalrymple. Mr. Ennis will handle direct.
13
14 Thereupon,
15
16 called on behalf of the plaintiffs herein, after having
17 been first duly sworn or affirmed, was examined and
18 testified as follows:
19
20 BY MR. ENNIS:
21 Q Doctor Dalrymple, will you please state your full
22 name for the record?
23 A Yes. My name is Gary Brent Dalrymple.
24 Q I'd like to show you Plaintiffs' Exhibit
25 Ninety-eight for identification, your curriculum vitae.
407.
1 Q (Continuing) Does that accurately reflect your
2 education, training, experience and publications?
3 A Yes, it does.
4 MR. ENNIS: Your Honor, I move that Plaintiffs'
5 Exhibit Ninety-eight for identification be received in
6 evidence.
7 THE COURT: It will be received.
8 MR. ENNIS:. (Continuing)
9 Q When and where did you receive your Ph.D.?
10 A The University of California at Berkeley in 1963 in
11 the field of geology.
12 Q What is your current employment?
13 A I am presently employed as the assistant chief
14 geologist for the western region of the United States
15 Geological Survey, and I am one of three assistant chief
16 geologists for the three regions of the United States.
17 The western region includes the eight western states in
18 the Pacific coast territory.
19 Q Were you responsible for scientific testing of the
20 lunar rock samples returned from the moon?
21 A Yes. I was selected by NASA to be one of the
22 principal investigators for the lunar rocks returned by
23 the Apollo Eleven through Thirteen missions.
24 Q What are your areas of expertise?
25 A My areas of expertise include general geology,
408.
1 A (Continuing) geochronology, paleomagnetism, and
2 radiometric data in general.
3 Q What, briefly, is geochronology?
4 A Well, geochronology includes methods that are used
5 to determine the ages of geological events.
6 Q Have you published a substantial number of books
7 and articles in these fields?
8 A Yes. Over a hundred scientific papers and a book
9 that is commonly used as a textbook in radiometric dating
10 classes.
11 MR. ENNIS: Your Honor, I offer Doctor Dalrymple as
12 an expert in the fields of geology, geochronology,
13 paleomagnetism and radiometric dating techniques in
14 general.
15 MR. WILLIAMS: No objection.
16 THE COURT: Okay.
17 MR. ENNIS: (Continuing)
18 Q Doctor Dalrymple, I have just handed you a copy of
19 Act 590. Have you had an opportunity to read Act 590?
20 A Yes, I have.
21 Q Is there anything in the Act's definition of
22 creation science to which the field of geochronology is
23 relevant?
24 A Yes. Section 4(a)(6) specifies, and I quote, A
25 relatively recent inception of the earth and living kinds,
end of quote.
409.
1 Q Is there anything in the Act's definition of
2 evolution to which the field of geochronology is relevant?
3 A Yes. Section 4(b)(6) specifies, quote, An
4 inception several billion years ago of the earth and
5 somewhat later of life, end of quote.
6 Q Are you familiar with the creation science
7 literature concerning the age of the earth?
8 A Yes, I am. I have read perhaps two dozen books and
9 articles either in whole or in part. They consistently
10 assert that the earth is somewhere between six and about
11 twenty thousand years, with most of the literature saying
12 that the earth is less than ten thousand years old.
13 Q Are you aware of any scientific evidence to
14 indicate that the earth is no more than ten thousand years
15 old?
16 A None whatsoever. In over twenty years of research
17 and reading of scientific literature, I have never
18 encountered any such evidence.
19 Q Are you aware of any scientific evidence to
20 indicate the earth is no more than ten million years old?
21 A None whatsoever.
22 THE COURT: Wait a second. What is it that the
23 creation scientists say is the age of the earth?
24 A They make a variety of estimates. They range
25 between about six and about twenty thousand years, from
410.
1 A (Continuing) what I've read. Most of them assert
2 rather persistently that the earth is less than ten
3 thousand years. Beyond that they are not terribly
4 specific.
5 Q Are you aware of any scientific evidence to
6 indicate the earth is no more than ten million years old?
7 A None whatsoever.
8 Q Are you aware of any scientific evidence to
9 indicate a relatively young earth or a relatively recent
10 inception of the earth?
11 A None whatsoever.
12 Q If you were required to teach the scientific
13 evidences for a young earth, what would you teach?
14 A Since there is no evidence for a young earth, I'm
15 afraid the course would be without content. I would have
16 nothing to teach at all.
17 Q Is the assertion by creation scientists that the
18 earth is relatively young subject to scientific testing?
19 Q Yes, it is. It one of the few assertions by the
20 creationists that is subject to testing and falsification.
21 Have such tests been conducted?
22 A Yes. Many times, by many different methods over
23 the last several decades.
24 Q What do those tests show?
25 A Those tests consistently show that the concept of a
young earth is false; that the earth is billions of years
411.
1 A (Continuing) old. In fact, the best figure for the
2 earth is in the nature of four and a half billion years.
3 And I would like to point out that we're not talking
4 about just the factor of two or small differences. The
5 creationists estimates of the age of the earth are off by
6 a factor of about four hundred fifty thousand.
7 Q In your professional opinion, are the creation
8 scientists assertions of a young earth been falsified?
9 A Absolutely. I'd put them in the same category as
10 the flat earth hypothesis and the hypothesis that the sun
11 goes around the earth. I think those are all absurd,
12 completely disproven hypotheses.
13 Q In your professional opinion, in light of all of
14 the scientific evidence, is the continued assertion by
15 creation scientists that the earth is relatively young
16 consistent with the scientific method?
17 A No, it is not consistent with the scientific method
18 to hold onto a hypothesis that has been completely
19 disproven to the extent that it is now absurd.
20 Q How do geochronologists test for the age of the
21 earth?
22 A We use what are called the radiometric dating
23 techniques.
24 Q Would you tell us very briefly, and we'll come back
25 to the details later, how radiometric dating techniques
work?
412.
1 A Yes. Basically we rely on the radioactive decay of
2 long lived radioactive isotopes into isotopes of another
3 element. By convention we call the long lived isotopes
4 that's doing the decaying the parent, and the end product
5 we call the daughter.
6 What we do in principal is we measure the amount of
7 parent isotopes in a rock or mineral and we measure the
8 amount of the daughter isotope in a rock or mineral, and
9 knowing the rate at which the decay is taking place, we
10 can then calculate the age.
11 It is considerably more complicated than that, but
12 that's the essence of those techniques.
13 Q Are these isotopes, isotopes of various atoms?
14 A Yes, they are.
15 Q Could you briefly tell the Court what an atom is,
16 how it's composed?
17 A Well, an atom consists of basically three
18 particles. The nucleus, or inner core of the atom, has
19 both neutrons and protons. The number of protons in the
20 nucleus determines what the chemical element for that atom
21 is. Both neutrons and protons have the same mass.
22 Neutrons have no charge. The number of neutrons in an
23 atom do not determine the elemental characteristics of
24 that atom, only the number of protons.
25 Orbiting the nucleus of the atom is a cloud of electrons
413.
1 A (Continuing) that orbit more or less like the
2 planets around the sun.
3 Q Could you tell us briefly what an isotope is?
4 A Yes. Differing atoms of the same element that have
5 different numbers of neutrons in a nucleus are called
6 isotopes of that particular element. The addition of a
7 neutron, more or less, as I said, does not change the
8 character of the element, it only changes the atomic
9 mass. And in some cases, when several neutrons are added
10 to the nucleus, the atom becomes unstable and becomes
11 radioactive.
12 Q Could you give an example of an isotope?
13 A Yes. Carbon-14, for example. The element, Carbon,
14 normally contains six protons. Ordinary carbon contains
15 six neutrons, as well, giving it an atomic mass of
16 twelve. That is usually indicated by the capital letter
17 C, for carbon, and the superscript in the upper left hand
18 corner denotes it being Carbon-12 for the atomic mass. If
19 we add two neutrons to that atom, it can become Carbon-14,
20 which is designated C-14.
21 Carbon-14, because of those two extra neutrons, is
22 unstable and is radioactive, whereas Carbon-12 is not
23 radioactive.
24 Q Why did geochronologists rely upon radiometric
25 dating techniques rather than other techniques?
A Because radioactivity is the only process that we
414.
1 A (Continuing) know of that's been constant through
2 time for billions of years.
3 Q Is radioactive decay affected by external factors?
4 A No, radioactive decay is not affected by external
5 factors. That's one reason we think it's been constant
6 for a long time.
7 Q Could you give an example of processes that are
8 affected by external factors.
9 A Yes. Examples would be the rates of erosion or the
10 rates of sedimentation. That is the rate that sediments
11 are deposited into the oceans and lakes. Both of those
12 processes are affected by the amount of annual and daily
13 rainfall, they are affected by the height of the
14 continents above sea level, they are affected by the
15 amount of wind, and so forth.
16 We know that all those factors vary with time, both on a
17 daily and annual basis, and, therefore, the rates are not
18 constant. They can't be used to calculate ages of any
19 sort.
20 Q Do creation scientists rely on the rates of erosion
21 or sedimentation in their attempts to date the age of the
22 earth?
23 A Yes. In some of their literature they have used
24 both of those techniques, and that is a good example of
25 how unscientific some of their estimates are, because
415.
1 A (Continuing) again, these processes have not been
2 constant over time.
3 Q Could you tell us why radioactive decay rates are
4 basically impervious to external factors?
5 A It's basically because the nucleus of an atom is
6 extremely well protected from its surroundings. And also
7 because radioactive decay is a spontaneous process that
8 arises only from the nucleus; it's not affected by
9 external factors.
10 The cloud of electrons that surrounds the nucleus of an
11 atom provides very good protection against external
12 forces. And also the strength of the nuclear glue, the
13 strength of the nuclear binding, is among the strongest
14 forces in nature. This is one reason why scientists have
15 to use powerful and extensive accelerators in atomic
16 reactors to penetrate the nucleus of an atom. It's really
17 tough to get in there.
18 Q Have scientists tested and measured those decay
19 rates under various circumstances to see whether they
20 would be affected by external forces?
21 A Yes. There has been a variety of tests over the
22 past number of decades addressing exactly that point. And
23 they found, for example, that decay rates do not change
24 with extremes of temperature, from a hundred ninety-six
25 degrees below zero Centigrade to two thousand degrees
416.
1 A (Continuing) Centigrade. The rates were not
2 affected.
3 At pressures of a vacuum or two thousand atmosphere, for
4 example, thirty thousand pounds per square inch, we found
5 that the combining of radioactive isotopes in different
6 chemical compounds does not affect the decay rates.
7 Q Have any tests ever shown any change in the decay
8 rates of any of the particular isotopes geochronologists
9 use in radiometric dating?
10 A None. They've always been found to be constant.
11 Q Are changes in decay rates of various isotopes at
12 least theoretically possible?
13 A Yes. Theoretically in some instances, and let me
14 explain that. There are three principal types of decay
15 involved in radioactive dating techniques. One is alpha
16 decay. That's the decay that involves the ejection of an
17 alpha particle from the nucleus of the atom. Another is
18 beta decay. That involves the injection of something like
19 an electron - it's called a beta particle - from the
20 nucleus.
21 Theory tell us that neither of those types of decay can
22 be affected by external factors, and in fact, none of the
23 experiments have ever shown any effect on either alpha or
24 beta decay.
25 There is a third type of decay called electron capture,
417.
1 A (Continuing) where an orbital electron falls into
2 the nucleus and converts a proton into a neutron. That
3 type of radioactive decay, because the original electron
4 comes from the electron shell, one can imagine if you
5 depress that shell a little bit, you might increase the
6 probability of the electron falling into the nucleus.
7 Theory tell us that such changes in electron capture
8 decay are possible, but theory also tells us that those
9 changes should be very small. And in fact, the maximum
10 changes ever detected or ever forced have been the
11 Beryllium-7, and that changes only one-tenth of one
12 percent. No larger.
13 There have never been any changes affecting any of the
14 decays being used for radioactive dating.
15 Q Do creation scientists challenge the constancy of
16 those radioactive decay processes?
17 A Yes, they do. There have done that on a number of
18 occasions.
19 Q Have they advanced any scientific evidence to
20 support their challenge?
21 A None whatsoever.
22 Q Did they use the relevant data on the decay rates
23 in a fair and objective manner, in your professional
24 opinion?
25 A No. In fact, they frequently cite irrelevant or
418.
1 A (Continuing) misleading data in their claims of
2 decay rates change.
3 Q Could you give an example?
4 A Yes, I can give two examples. The first is in an
5 Institute for Creation Research technical monograph
6 written by Harold Slusher entitled, I believe, A Critique
7 of Radiometric Dating.
8 In that publication he makes the statement that the
9 decay rates of Iron-57 have been changed by as much as
10 three percent by strong electric fields. The problem with
11 that is that Iron-57 is not radioactive. Iron-57 is a
12 stable isotope. When Iron-57, it does undergo an internal
13 conversion decay, and by that I mean simply a mechanism
14 for getting rid of some excess energy. And that type of
15 decay does also have a decay rate, but it's completely
16 irrelevant to radioactive dating.
17 So when Iron-57 decays, "by internal conversion", it
18 remains Iron-57. One of the dating schemes used in
19 geology involved internal conversions. So the example of
20 Iron-57 cited by Slusher is simply irrelevant.
21 And in fact, he did reference his source of that data,
22 and I've been unable to confirm the fact that Iron-57
23 decay rates by internal conversion have been changed, so
24 I'm not sure that's even true.
25
419
1 Q But even if it were true, it would be irrelevant
2 because Iron-57 would remain Iron-57?
3 A That's exactly right.
4 Q And the isotope techniques you rely upon are
5 changed from one element to another?
6 A That's true.
7 Q Could you give, another example?
8 A Yes. Another example frequently cited is the use
9 of neutrinos. They frequently claim that neutrinos might
10 change decay rates. There are several things wrong with
11 that hypothesis also. The first thing, the source of
12 their statement was a column in Industrial Research by
13 Frederich Houtermanns entitled Speculative Science or
14 something. Scientific Speculation is the title of his
15 column.
16 And without any empirical evidence whatsoever,
17 Houtermanns speculated the neutrinos might somehow effect
18 radioactive clocks. But there is no theory for that and
19 there is no empirical evidence that such is the case.
20 The creationists conveniently leave out the speculative
21 nature of that particular idea.
22 The second thing is that neutrinos are extremely small
23 particles. They have virtually no mass or little mass and
24 no charge. They were first postulated by Pauli back in
25 the 1930's as a way of an atom carrying off excess energy
420.
1 A (Continuing) when it decays by beta decay. They
2 interact so little with matter, in fact, that they're very
3 difficult to detect, and it's several decades later before
4 they were even detected. Neutrinos can pass completely
5 through the earth without interacting with the matter, and
6 there's no reason at all to suspect that they would change
7 the decay rates or alter the decay rates in any way.
8 Finally, the creationists typically argue that neutrinos
9 might reset the atomic clock. I am not quite sure what
10 they mean by that, but if it's used in the usual sense, to
11 reset a clock means starting it back at zero. The effect
12 of that would be that all of our radiometric dating
13 techniques would overestimate the geologic ages and ages
14 of the earth, not underestimate them. So that works
15 against their hypothesis.
16 Q If they reset the clocks, then the test results
17 from that resetting would show the earth to be younger
18 than in fact?
19 A Yes. What, in fact, we would have would be a
20 minimum age instead of a correct age. So it works in
21 exactly the opposite direction.
22 Q In addition to questioning the constancy of the
23 decay rates, do creation scientists make other criticisms
24 of radiometric dating?
25 A Yes. One of their other criticisms is that your
421.
1 A (Continuing) parent or daughter isotopes might be
2 either added or subtracted from the rock between the time
3 of its formation and the time it would be measured. And
4 they commonly say that since we can't know whether or not
5 the daughter or parent isotopes have been added or
6 subtracted, therefore, we have no basis for assuming they
7 are not, or for calculating an age from this data.
8 Q Is that commonly referred to as the closed
9 system-open system problem?
10 A Yes. Basically all radiometric dating techniques
11 require - most of them do, not all - most of them
12 require that the rock system, the piece of rock or the
13 mineral they were measuring, has been a closed system
14 since the time of crystallization up until the time that we
15 measure.
16 And what they're basically saying is that we have no way
17 of knowing whether they have been a closed system or not.
18 Q What steps do geochronologists take to insure that
19 the samples they test have remained closed systems and
20 have not changed since they were initially formed?
21 A We try to be fairly careful with that. We don't
22 run out and pick up just any rock and subject it to these
23 expensive and time consuming tests. There are several
24 different ways we go about this. The first thing is, we
25 can observe the geological circumstances in which the
422.
1 A (Continuing) sample occurs. And that tells us a
2 lot about the history of that sample, what kinds of
3 external factors it might have been subjected to.
4 The second thing is that there are microscopic
5 techniques that we can use to examine the rock in detail
6 and tell, whether or not it's likely to have been a closed
7 system since its formation.
8 You see, all things that can affect the rock system in
9 terms of opening it also leave other evidence behind, like
10 changes in minerals that we can observe. So we have
11 pretty good field and laboratory techniques which will
12 tell in advance whether a system has been a closed system
13 or an open system.
14 Q Do you, yourself, engage in that testing process?
15 A Oh, yes, all the time. As a result, I personally
16 reject perhaps a half to three-quarters of all samples for
17 dating just for that very reason that the samples are not
18 suitable. This rejection is done before we get any
19 results.
20 Q Once you have a sample which you believe has not
21 changed since formation, is there any objective way to
22 test a sample to determine whether you're right or wrong?
23 A Yes. There are a number of objective ways to do
24 that. These ways rely on the results themselves.
25 Q Do the results themselves show whether the sample has
changed its formation?
423.
1 A Yes, they do.
2 Q If the results of a test showed that a sample had changed
3 since formation, is that sample then utterly
4 worthless?
5 A No, not at all. We are not always interested in
6 the age of the rock, For example, sometime we are
7 interested in the age of the heating events. If, for
8 example, a rock body has been subjected to heating, we
9 might be more interested in what event caused that heating
10 than the usual crystallization age of the rock, so that
11 usually these kinds of results give us other kinds of
12 information.
13 They also tell us a good deal about the state of that
14 sample, whether or not it has been an open or closed
15 system. So just because we don't get a reliable
16 crystallization age doesn't mean that we aren't getting
17 other information.
18 For example, we might end up with the age of the heating
19 events which would be an extremely valuable piece of
20 information. Sometimes just knowing the sample has not
21 been a closed system is an extremely valuable piece of
22 information.
23 So we use these dating techniques for lots of things
24 other than determining the age of the rock sample.
25 Q How many methods are there for determining
424.
1 Q (Continuing) subjectively whether a sample has been
2 changed since formation?
3 A Well, there are quite a variety, but I think they
4 can be lumped into about four categories. Those include
5 dating two minerals from the same rock; using two
6 different techniques on the same rock; other tests that
7 are called geological consistency tests, and finally,
8 there is a category of techniques called isochron
9 techniques that also serve that purpose.
10 Q Could you briefly describe the first method?
11 A Yes. In dating of two minerals from the same rock,
12 the reason we do that is because different minerals
13 respond in different ways to external factors.
14 For example, in the potassium argon method, the daughter
15 product is argon, which is a rare gas. It's not terribly
16 happy being inside minerals. It doesn't chemically
17 combine with any of the other elements there.
18 If we take the mineral biotite, that's a mica, for
19 example, and date that with the potassium argon method,
20 then we also date the mineral hornblende with the
21 potassium argon method, if there has been an external
22 influence on this system, we expect those two minerals to
23 respond differently.
24 This is because the biotite would start to release its
25 argon at temperatures of perhaps two-fifty to three
425.
1 A (Continuing) hundred degrees centigrade, whereas
2 the hornblende would reach six or seven hundred degrees
3 centigrade before it starts to release its argon.
4 There, of course, has been a heating event of, let's say
5 hypothetically five hundred degrees, we would expect to
6 see argon loss or younger ages from the biotites, whereas
7 the hornblende might retain all of its argon completely.
8 The main point is that when we get a discrepancy like
9 this, we know that something has happened to the system
10 that made it, violate our assumption of a closed system,
11 and that's valuable information.
12 Q And if you get that result, you then do not use
13 that sample to postulate an age for the initial formation
14 of the samples?
15 A That's right. The results themselves tell us that
16 that would be a very dangerous conclusion to come to. But
17 we can postulate that there has been something happen to
18 that rock.
19 Q Go to the second method you use.
20 A The second method involves using two different
21 dating techniques on the same rock. This has a couple of
22 advantages. It's a little more powerful than the first
23 method.
24 For example, if we use the potassium argon method, which
25 has a half life of one point two five billion years, and
426.
1 A (Continuing) we use the rubidium strontium method,
2 which has a half life of forty-eight point eight billion
3 years, we essentially have two clocks running at different
4 speeds but keeping the same time.
5 If I could use an analogy, we might have two
6 wristwatches. One wristwatch might use a balance wheel
7 that rotates back and forth five times a second. On the
8 other hand we might have a digital watch that uses a
9 little quartz crystal that operates at a speed of, let's
10 say, twenty thousand times a second. We, then, have two
11 watches that are ticking at different rates but keeping
12 the same time. That same advantage accrues to using two
13 different methods on the same rock.
14 The second advantage is the daughter products are
15 different. The daughter product of the potassium argon
16 method is argon. It's a rare gas. It behaves quite
17 differently to heating, whether in alteration, than does
18 strontium-87, which is the daughter product of the
19 rubidium strontium method. Strontium-87 is not a gas,
20 it's a chemical element that likes to be in chemical
21 combination with certain other things in a rock.
22 So again we expect a different response.
23 Q Does testing a sample with the two or more
24 techniques frequently yield the same age for that sample?
25 A Yes. Particularly in the cases where we know from
427.
1 A (Continuing) other evidence that the sample has
2 been undisturbed, we commonly get that result.
3 Q What do creation scientists say about age
4 agreements between different techniques?
5 A Well, they usually just ignore them. They don't
6 pay any attention to them at all.
7 Q Does testing a sample with two or more techniques
8 ever yield different rates for that sample?
9 A Yes. Quite often it does.
10 Q What do creation scientists say about those age
11 disagreements?
12 A Well, they usually use those disagreements and
13 purport that they have evidence that the techniques don't
14 work.
15 Q Is that a scientific assessment of the evidence?
16 A Well, no. There are several things wrong with
17 that. In the first place, when we get disagreements, they
18 are almost invariably caused by some external factor that
19 has caused one of the clocks to read in a way that's too
20 young. It gives us an age that is too young.
21 The second thing is that age that is too young might
22 measure, for example, the age of the event. Those ages
23 that are too young are still millions and millions of
24 years old, which, even though we don't have agreement
25 between the techniques, still contradict the hypothesis
428.
1 A (Continuing) of an earth less than ten thousand
2 years old.
3 Finally, the reason for doing these kinds of tests is to
4 determine in advance upon the results themselves whether
5 or not the technique is reliable. Therefore, they are
6 using our very test method as a criticism of the method
7 itself, and I sort of consider that dirty pool. It's not
8 very honest.
9 Q What's the third method commonly used to test the
10 changes in a sample?
11 A Well, the third method involves geological
12 consistency. Rocks don't occur all by themselves. They
13 usually are surrounded by other rocks, and the
14 relationship of the sample to these other rocks can be
15 determined.
16 Perhaps the simplest example might be a lava flow. If
17 we have a stack of lava flows from a volcano and we are
18 interested in determining the age of that volcano or that
19 stack of lava flows, we wouldn't just date one rock. We
20 would date one from the top of the sequence, perhaps; we
21 would date one from the bottom of the sequence, and we
22 might date eight or ten intermediate in the sequence.
23 We know because of the way lava flows form, one on top
24 of the other, that all of those ages should either be the
25 same or they should become progressively older as you go
429.
1 A (Continuing) down in the pile.
2 If, in fact, we get random or chaotic results, that
3 tells us that something is wrong about our assumption of
4 the closed system, so we can use a variety of geological
5 consistency tests like this to test the results as well.
6 Q What is the fourth method that you rely upon?
7 A Well, the fourth is really a family of methods
8 called isochron techniques.
9 Q How do the isochron techniques differ from the
10 other techniques you've just mentioned?
11 A These are techniques that have especially built in
12 checks and balances, so that we can tell from the results
13 themselves, without making any other assumptions, whether
14 or not the techniques are giving reliable ages.
15 Some isochron techniques really work very well, and work
16 best on open systems. Isochron techniques typically yield
17 two important results. One is, most of the isochron
18 techniques are able to tell us the amount and composition
19 of any initial daughter that is present. That's not
20 something we need to assume, it's something that falls out
21 of the calculations.
22 The second thing is that the isochron techniques tell us
23 very clearly whether a sample has been opened or closed.
24 If the sample is still an isochron, then we know that that
430.
1 A (Continuing) sample is a good closed system. If we
2 don't get an isochron, we know that something is wrong
3 with the sample. And we get these results just from the
4 experimental data themselves, without any other geological
5 consideration.
6 So they are ultimately self-checking, and they are one
7 of the most common, surefire ways to date rocks.
8 Q Have creation scientist's produced any evidence or
9 suggested any plausible theory to support their assertion
10 that the earth is only about ten thousand years old?
11 A No. I know of no plausible theory that they
12 suggest. They have proposed several methods that don't
13 work.
14 Q Have you looked into the creation science claim
15 that the decay of the earth's magnetic field shows a young
16 earth?
17 A Yes. I've looked into that in some detail. That
18 is rather fully described in an Institute for Creation
19 Research technical monograph by Thomas Barnes, which if I
20 recall correctly is titled The Origin and Destiny of the
21 Earth's Magnetic Field.
22 Let me try to explain briefly what Barnes asserts. For
23 the last hundred and fifty years or so, since 1835,
24 scientists have analyzed the earth's magnetic field, and
25 they have noticed that the dipole moment, and we can think
431.
1 A (Continuing) of that just as the strength of the
2 main magnetic field, has decreased, and it has decreased
3 in intensity over the last hundred and fifty years.
4 The decrease amounts to about six or seven percent.
5 Barnes claims that the earth's magnetic fields are
6 decaying remnants of a field that was originally created
7 at the time the earth was created, and that it is
8 irreversible decaying and will eventually vanish, in about
9 nine or ten thousand years.
10 What Barnes does is assume that this decay is
11 exponential. Actually you can't tell whether it's
12 exponential within the earth, but he assumes it's
13 exponential going back to a hypothesis proposed by,
14 actually a model proposed by Sir Forrest Land back in the
15 eighteen hundreds.
16 Land is not talking about the magnetic field, though.
17 He gives the mathematical calculations that Barnes uses.
18 Barnes then calculates a half life with this presumed
19 exponential decay, extrapolates backwards in time and
20 concludes that in 8000 B.C. the strength of the earth's
21 dipole moment would have been the same as the strength of
22 the magnetic star.
23 And since that is obviously absurd, and I would have to
24 agree that that would be absurd, therefore, the earth must
25 be less than ten thousand years old.
432.
1 Q What is wrong with that claim?
2 A Well, there are quite a few things wrong with that
3 claim. To start with, Barnes only considers the dipole
4 field. The earth's magnetic field, to a first
5 approximation, is like a dipole. That is, it produces the
6 same field as would a large bar magnet, roughly parallel
7 to the axis of rotation of the earth, lining across the
8 merging poles, circle around the earth, and return back in
9 at the other pole. But that's not the whole story.
10 That's only the part that Barnes works with.
11 The other component of the magnetic field is the
12 non-dipole field. These are irregularities that are
13 superimposed on the dipole field and amount to a
14 considerable proportion of the total field.
15 Finally, theory tells us that there is probably another
16 very large component of the magnetic field inside the core
17 of the earth that we can't observe because the line of the
18 flux are closed.
19 So Barnes makes several mistakes. First, he equates the
20 dipole field with the total earth's field, which it's
21 not. It's only a part of the earth's field. And second,
22 he equates the dipole field strength with the total
23 magnetic energy. And both of those extrapolations are
24 completely unjustified.
25 Careful studies of the non-dipole and dipole field over
433.
1 A (Continuing) the past fifty years have shown that
2 the decrease in the dipole field is exactly balanced by an
3 increase in the strength of the non-dipole field.
4 In fact, over the last fifty years, as far as we can
5 tell, there has been no decay in total field energy
6 external to the core at all. Similar studies over the
7 last hundred and twenty years show a very slight decrease
8 in the total field energy external to the core. So in
9 fact, we don't know exactly what's happening to the total
10 field energy.
11 And finally, paleomagnetic observations have shown that
12 the strength of the dipole moment doesn't decrease
13 continually in one direction, but it oscillates with
14 periods of a few thousand years. So it goes up for a
15 while and goes down for a while. At the same time the
16 non-dipole field is also changing.
17 And lastly, he completely ignores geomagnetic
18 reversals. Paleomagnetic studies of rocks have shown
19 conclusively that the earth's field has periodically, in
20 the past, reversed polarities, so that the North Pole
21 becomes the South Pole, and vice versa. This happens
22 rather frequently geologically, that is, hundreds of
23 thousands to millions of years at a time.
24 We now have a pretty good time scale for those reversals
25 over the last ninety million years. And Barnes completely
434.
1 A (continuing) ignores that evidence.
2 One thing we do know about geomagnetic reversals from
3 the evidence, of rocks is that during the process of the
4 field reversing, the dipole moment decays.
5 Q What do creation scientists say about the
6 possibility of the polarity reversals?
7 A Well, they claim that they can't happen, and they
8 claim that they have not happened.
9 Q Is there any basis for that claim?
10 A No, none whatsoever. The paleomagnetic evidence is
11 very sound, and, in fact, it's verified by other evidence
12 as well.
13 It's also interesting to note that the earth's field is
14 not the only field that reverses polarity. For example,
15 in 1953, the dipole field of the sun was positive polarity
16 in the North and negative polarity in the South pole.
17 Over the next few years the strength of the sun's dipole
18 field began to decrease, very much in the same way that
19 the strengths of the earth's dipole field is now
20 decreasing, until within a few years it had vanished
21 entirely. It couldn't be measured from the earth.
22 Then gradually it began to reestablish itself, and by
23 1958 the sun's dipole field was completely reversed, so
24 that the North Pole, instead of being positive, was now
25 negative, and vice versa for the South Pole.
435.
1 A (Continuing) So geomagnetic reversals are not a
2 surprising phenomena, and in fact, they are expected.
3 Magnetic reversals have also been seen in the stars.
4 Q But creation scientists just deny that that happens?
5 A Well, they never mention that. It's simply ignored.
6 Q Do creation science arguments for a young earth
7 rely on the cooling of the earth?
8 A Yes. They commonly use that argument. And again,
9 that argument is one that has been championed by Thomas
10 Barnes and some of the patrons of the Institute of
11 Creation Research.
12 That particular theory, or idea, goes back to an idea
13 championed by Lord Kelvin (Thomson) who started in the
14 mid-eighteen hundreds. At that time you must remember
15 that there was no such thing as radioactivity. By that I
16 mean it had not been discovered yet.
17 Kelvin observed that the temperature of the earth
18 increased as it went downward from the surface. That is,
19 he observed the geothermal gradient. He had started with
20 the assumption that the earth started from a white hot
21 incandescent sphere and it cooled to its present state.
22 So he calculated how long that would take.
23 His first estimates were something between twenty and
24 four hundred million years. Later he settled on
25 twenty-four million years, which was not his figure, but
436.
1 A (Continuing) it was a figure that was first
2 calculated by the geologist Clarence King, who quite
3 incidentally was the first director of the Geological Survey.
4 The problem with total analysis in Barnes championing of
5 this thing is that partly he took a physical way to
6 calculate the age of the earth. The problem with that is
7 that in 1903 Rutherford and Soddy demonstrated
8 conclusively that there's an enormous amount of energy
9 available in radioactive decay. In fact, all of the heat
10 now pouring outward from the earth can be accounted for
11 solely by radioactive elements in the earth's crust and
12 mantle.
13 Kelvin never publicly recanted his views, but in the
14 history of his life it has been recorded that he privately
15 admitted that the discovery by Rutherford and Soddy that
16 said this enormous energy is from radioactive decay had
17 completely disproved his hypothesis. Even Kelvin knew it
18 was wrong.
19 It's quite amazing to me that the creationists would
20 hold such an idea for a couple of reasons. The first
21 reason being that we've known for all these centuries that
22 Kelvin's calculations were completely irrelevant. And the
23 second thing is that Kelvin thought the earth was billions
24 of years old.
25 Q Do creation scientists rely on the accumulation of meteor
dust as evidence for a young age of the earth?
437.
1 A Yes. That's another one that they claim. And I've
2 looked into it some, and if you don't mind, I'd like to
3 refer to some notes on that so that I get the figures
4 straight.
5 Q Could you explain that creation science claim?
6 A Yes. Morris, in 1974, and also a book by Wysong in
7 1966, both claim that there's evidence that the influx of
8 meteoric dust to the earth is fourteen million tons per
9 year.
10 And they calculate that if the earth were five billion
11 years old, this should result in a layer of meteoric dust
12 on the earth a hundred and eight-five feet thick. And
13 they say, "How absurd, we don't observe this," of course.
14 There are some problems with that, however. They are
15 relying on calculations done by a man by the name of
16 Peterson in 1960. What Peterson did was collect volumes
17 of air from the top of Mauna Loa volcano in Hawaii, using
18 a pump originally developed for smog, I believe.
19 Then he thought about the dust. Then he analyzed this
20 dust for nickel content. He observed that nickel was a
21 fairly rare element on the earth's crust. That's not
22 exactly true, but that was the assumption that he used.
23 And he assumed that the meteoric dust had a nickel
24 content of two and half percent. So using the mass of
25 dust that he had and the nickel content of the dust and an
438.
1 A (Continuing) assumed two and a half percent nickel
2 content for meteoric material, he was able to calculate
3 the annual volume of meteoric dust that flowed into the
4 earth.
5 He came up with a figure of about fifteen million tons
6 per year, but when he weighed all of the evidence, he
7 finally concluded that perhaps, about five million tons per
8 year was about right.
9 Morris, on the other hand, and Wysong, both choose the
10 higher number, I think because that makes the layer of
11 dust thicker.
12 The problem with that is that nickel is not all that
13 uncommon in the earth's crust, and probably Peterson was
14 measuring a lot of contamination.
15 There have been more recent estimates than Peterson's.
16 In 1968, for example, Barker and Anders made an estimate
17 of the meteoric influx of cosmic dust based on the uranium
18 osmium contents, which are extremely rare, of matter in
19 deep sea sediments. And they came up with an influx
20 figure that was a factor of twenty-three lower than
21 Peterson's figure, and, therefore, twenty-three times
22 lower than the figure used by Morris.
23 Probably the best completely independent estimates,
24 however, are based on satellite data, satellite
25 penetration data. That is, the number and the mass of
particles distract satellites as they orbit the earth.
439.
1 A (Continuing) And NASA collected quite a bit of
2 these data in the 1960's.
3 There was a review of that done in 1972, and you note
4 that that information was available when Morris and Wysong
5 wrote their book, but they didn't cite it.
6 Q What does that NASA data show?
7 A Well, that showed that the influx of meteoric
8 materials was, in fact, not fourteen million tons or even
9 five million tons per year, but more like eleven thousand
10 tons per year. In other words, two orders of magnitude
11 lower.
12 And coming out here on the plane, I redid Morris'
13 calculations using these better figures, and I came up
14 with a rough layer of four point six centimeters in five
15 billion years. And of course, with the rainfall and
16 everything, that simply would have been washed away.
17 There's an interesting aside. NASA was quite concerned
18 about the layer of dust on the moon. NASA estimated that
19 it would produce a layer of dust on the moon in four and a
20 half billion years of about one and half to perhaps
21 fifteen centimeters maximum. And in the least disturbed
22 areas of the moon, the astronauts measured a thickness of
23 about ten centimeters, so the observations agree exactly
24 with the predictions.
25 Q Do these observations on the moon prove that the
440.
1 (Continuing) earth or the moon are, in fact, four
2 point five to five million years old?
3 A No, they don't prove anything whatsoever except
4 that there's dust on the moon. It's another one of those
5 processes that has a non-constant rate. We have more
6 reason to suspect that the rate of influx of meteoric dust
7 has been constant with time. In fact, we have a lot of
8 reasons to suspect that it is not.
9 For example, in the early history of the earth, four and
10 a half billion years ago when the earth was first formed,
11 it was sweeping up out of space enormous amounts of
12 material. During those periods of the earth's history, we
13 would expect the influx rate to be very, very high. Now
14 it's much lower.
15 The evidence indicates it has probably been constant for
16 perhaps the last ten million years. We have no idea what
17 the rate of influx of meteoric dust has been over geologic
18 history. So it's one of these things that you simply can't
19 use.
20 Q Do creation scientists rely upon the shrinking of
21 the sun?
22 A Yes. That's another one I've read, and that stems
23 from a paper, I think in the Institute of Creation
24 Research Impact, Number 82, published in April of 1980.
25 Their claim is based on a paper by Eddie Inpornasian (Aram
Boornazian) which was published in 1979. Using
441.
1 A (Continuing) visual observations of the sun, Aram
2 Boornazian observed that they thought that the sun's
3 diameter was decreasing. And it was decreasing at such a
4 rate that in a hundred thousand years the sun would vanish
5 to a point.
6 And the creationists work this backwards and say that if
7 the earth was as old as geologists claim it was, then the
8 sun would have been very large in the past history, and
9 would have been so large that life would not have been
10 possible on the earth.
11 The problem with this particular calculation is that the
12 original data of Aram Boornazian was completely wrong.
13 There had been another study done by Irwin Shapiro of MIT,
14 who used twenty-three transits of mercury across the face
15 of the sun that occurred between 1736 and sometime within
16 the last few years, a much more accurate way to measure
17 the diameter of the sun than the techniques used by Aram
18 and his colleagues. Shapiro, his paper was published in
19 1980. He said rather conclusively that the sun's diameter
20 is not changing at all. The sun is not shrinking or it's
21 not growing.
22 Q Are you aware of other supposed tests for the
23 earth's age proposed by creation scientists?
24 A Yes. There are a number of them in a book by
25 Morris called, I believe, The Scientific Case for Creation.
As I recall, he proposes about seventy
442.
1 A (Continuing) different methods that he lists. They
2 ranged all the way from influx of soda aluminum into the
3 oceans, for which he gets a figure of a hundred years, I
4 believe, to influx of magma into the crust, for which he
5 gets a figure of five hundred million years.
6 MR. ENNIS: Your Honor, Plaintiffs have previously
7 marked for identification excerpts from that particular
8 book that include approximately six pages to which Doctor
9 Dalrymple might refer in his testimony. I have given
10 copies of those additional six pages to the Attorney
11 General.
12 If there is no objection, I'd like for those six pages
13 to be added and included with Plaintiffs' Exhibit
14 Eighty-Six for identification.
15 THE COURT: Okay.
16 MR. ENNIS: (Continuing)
17 Q I'd like to show you Plaintiffs' Exhibit Eighty-Six
18 for identification.
19 A Okay.
20 Q Does Mr. Morris, in that book, acknowledge any
21 assumptions he used in deciding which of those tests to
22 rely upon and which not to rely upon?
23 A Yes, he does. On page 53 he makes the following
24 statement: "It is equally legitimate for creationists to
25 calculate apparent ages using assumptions which agree with
443.
1 A (Continuing) their belief in special creation,
2 provided they acknowledge that fact. And then he goes on
3 to present seventy such calculations, most of which are
4 made by him and his colleagues, but some of which he
5 refers to the scientific literature.
6 Q What do those seventy tests supposedly show?
7 A Well, Morris approaches this in a rather strange
8 way. He says, "I'm going to make all these calculations
9 for the age of the earth using these assumptions," and
10 then gets a variety of results, ranging from too small to
11 measure, to, I don't know, five hundred million years,
12 something like that.
13 And he says, "Look how inconsistent the results are. As
14 you see, we really can't calculate the age of the earth."
15 However, he thinks that the young ages are probably more
16 reliable than the old ages, basically because there would
17 have been less time for external factors to affect the
18 calculation.
19 The problem with these seventy ages is that most of them
20 rely on rates that are not constant. And these seventy
21 also include things like the magnetic field and meteoric
22 dust, which I have already discussed.
23 Sometimes, however, he uses very misleading and
24 erroneous data.
25 Q Could you give me an example of that?
444.
1 A Yes, I can. There is one which is here, number
2 thirty-three. It's entitled, "Formation of Carbon 14 on
3 Meteorites." The age he lists is a hundred thousand
4 years, and the reference he gives is to a paper published
5 in 1972 by Boeckl. There is a problem with that, and that
6 is that Boeckl's: paper was not about meteorites at all;
7 Boeckl's paper was about tektites. Tektites are objects
8 which are thought to originate on the earth.
9 The second thing was that Boeckl was interested in
10 calculating the cosmic rays exposure ages for these
11 tektites. He wanted to know how long they had spent in
12 space.
13 In order to make the calculations he was trying to make,
14 he had to assume an initial age for the tektites. His
15 calculations were not terribly sensitive at all to what he
16 assumed, so he just assumed ten thousand years for his
17 particular purpose.
18 I don't know where Morris got a hundred thousand years.
19 That figure he must have made up. But the fact is that
20 Boeckl's paper wasn't about the subject Morris claims it
21 was. There was no data in Boeckl's paper that could be
22 used to calculate the age of the earth or anything else.
23 The one age that Boeckl was trying to calculate was the
24 residence time of these objects in space, and that's all.
25 So this is truly misleading and very unscientific.
445.
1 Q Doctor Dalrymple, in conclusion, in your
2 professional opinion, is there any scientific evidence
3 which indicates a relatively recent inception of the earth?
4 A There is none whatsoever.
5 MR. ENNIS: I have no further questions, Your Honor.
6 THE COURT: I think we probably ought to recess for
7 the night. How long do you think your cross examination
8 is going to be?
9 MR. WILLIAMS: Not very long, your Honor.
10 THE COURT: You are talking about five or ten
11 minutes?
12 MR. WILLIAMS: It will be a little longer. Might
13 take twenty minutes, or under.
14 THE COURT: Why don't we wait until tomorrow to do
15 it if you don't mind.
16 I found out today that GSA recalculated the cost of
17 driving an automobile, and it is not twenty-two and a half
18 cents a mile like they were paying us; it is twenty cents
19 a mile. And you can find some comfort in that, but I
20 think I am going to protest by quitting early today.
21 (Thereupon, Court was in recess
22 at 5:15 p.m.)
23
24
25
447.
1 VOLUME III INDEX
2
3 Witness:
4 On Behalf of the Plaintiffs:
5
6 GARY B. DALRYMPLE
7 Cross Examination by Mr. Williams Page 449
8 Redirect Examination by Mr. Ennis Page 471
9 Recross Examination by Mr. Williams Page 486
10
11 HAROLD MOROWITZ
12 Direct Examination by Mr. Novik Page 494
13 Cross Examination by Mr. Childs Page 577
14
15 STEPHEN GOULD
16 Direct Examination by Mr. Novik Page 514
17 Cross Examination by Mr. Williams Page 611
18
19 DENNIS GLASGOW
20 Direct Examination by Mr. Cearley Page 641
21 Cross Examination by Mr. Childs Page 684
22
23
24
25
448.
1 VOLUME III - EXHIBIT INDEX
2
3 EXHIBIT OFFERED RECEIVED
4
5 Plaintiffs' No. 121 474 474
6 Defendants' No. 1 486 486
7 Plaintiffs' No. 93 494 494
8 Plaintiffs' No. 96 515 515
9 Plaintiffs' No. 101 552 552
10 Plaintiffs' No. 123 556 556
11 Defendants' No. 2 616 616
12 Plaintiffs' No. 40 649 649
13 Plaintiffs' No. 41 - 50 660 660
14 Plaintiffs' No. 128 667 667
15 Defendants' No. 3 689 689
16
17
18
19
20
21
22
23
24
25
449.
1 (December 9, 1981)
2 (9:00 a.m.)
3 THE COURT: I see you all made it back, and I
4 believe we are about to begin the cross examination of
5 Doctor Dalrymple.
6
7 BY MR. WILLIAMS:
8 Q Is constancy of the rate of radioactive decay a
9 requirement for radiometric dating?
10 A Yes. It is required that radiometric dating be
11 based on constant decay rates, at least within limits of
12 significant areas, and what I mean by that is that if the
13 decay rates were to change a percent or two, that would
14 probably not significantly alter any of our major
15 conclusions in geology.
16 Q To the best of your knowledge, has the rate of
17 radioactive decay always been constant?
18 A As far as we know from all the evidence we have, it
19 has always been constant. We have no, either empirical or
20 theoretical reason to believe it is not.
21 Q So as far as you know, it would have been constant
22 one billion years ago, the same as it is today.
23 A As far as we know.
24 Q Five billion years ago?
25 A As far as we know.