Deposition of Harold G. Coffin




- - -

vs. ) NO. LR-C-81-322
al., )



Monday, November 16, 1981

Reported by: DEAN McDONALD, CSR
Cert. #1869; and
Cert. #2108




Examination by Mr. Klasfeld 4; 80


- - -



No. 1 Curriculum Vitae of witness 12

No. 2 Document 60

No. 3 Copy of application form for

Creation Research Society 63

No. 4 Article entitled "The Spiroribis

Problem" 97

No. 5 Document 120

No. 6 Document 143

No. 7 Document 162

No. 8 Document 162

No. 9 Document 162

- - -


BE IT REMEMBERED that, pursuant to Notice, and on
Monday, the 16th of November, 1981, commencing at the
hour of 10:00 o'clock a.m. thereof, at the law offices of
Brobeck, Phleger & Harrison, One Market Plaza, San
Francisco, California, before me, DEAN McDONALD, a Cer-
tified Shorthand Reporter and Notary Public in and for
the State of California, personally appeared


called as a witness by the plaintiffs, who, being by me
first duly sworn, was examined and testified as herein-
after set forth.

- - -

Avenue, New York, New York 10022, represented by DAVID
KLASFELD, Attorney at Law, appeared as counsel on behalf
of the plaintiffs.

STEVE CLARK, Attorney General, State of Arkansas,
Justice Building, Little Rock, Arkansas 72201, repre-
sented by RICK CAMPELL and CALLIS L. CHILDS, Assistant
Attorneys General, appeared as counsel on behalf of the

- - -



being duly sworn, testified as follows:


MR. KLASFELD: Q. Dr. Coffin, when was the first
time you heard about this case?

A. I think I may have noticed something in the
news three, four months ago.

I am not sure.

Q. When was the first time that someone from the
Arkansas Attorney General's Office got in touch with you
about the possibility of your testifying in this case?

A. Actually, I heard it indirectly through my
colleague, Ariel Roth, and did not have direct contact
with the Arkansas Attorney General's Office until perhaps
jsut a week ago or maybe a little bit over a week ago.

Q. Who did you speak with?

A. Tim Humphries, H-u-m-p-h-r-i-e-s.

Q. Do you know who Mr. Humphries is?

A. Legal counsel for the Attorney General of

MR. KLASFELD: Mr. Campbell, is he a member of
your staff?


I guess you would call him -- he is an intern in
our office.

MR. KALSFELD: Q. What did Mr. Humphries said to

A. He just asked me if I would be willing to



Q. And this was a week ago, you say?

A. I'm not really sure but it was not over two
weeks ago.

Q. So within a week to two weeks?

A. Let's say within two weeks.

Q. Is that all he said to you?

A. He asked me my educational background and he
asked me what my expertise would be in or is in.

Q. What did you tell him your expertise was in?

A. I told him my expertise was in the area of

Q. You said earlier that your colleague, Dr. Roth,
had mentioned the possibility of your testifying at the
trial to you earlier.

A. Yes.

Q. When was that?

A. I really cannot remember exactly when it was
but say within the last three weeks, perhaps a month.

Q. What did you discuss with Dr. Roth?

A. I don't recall discussing anything except just --

Q. Well, do you recall how he raised the matter,
what he said to you?

A. No, I really don't recall what he said.

Q. As close as you can recall, what was the sub-
stance of your conversation?

A. I think he just merely said it would be a
possibility that we would be witnesses in the Arkansas


lawsuit and he wondered if I was interested or agreeable.

Q. What did you tell him?

A. I told him -- he is the director of the insti-
tute, so he sort of had the final say, you might say.

I said, "Well, I am agreeable, if that is what you
want me to do."

Q. What institute is that?

A. The Geoscience Institute.

Q. Is that connected with a school of any kind?

A. It is loosely affiliated with Loma Linda Uni-

Q. Is that a church-affiliated school?

A. Yes.

It's a Seventh-Day Adventist university.

Q. Now, Dr. Coffin, I have here a document filed
with the court and served on plaintiffs which is called
Defendant's Second List of Witnesses. The attached
certificate of service is signed by David Williams and
it says it was served on us the 10th of October.

MR. CAMPBELL: For the record, I think that is the

MR. KLASFELD: That may well be.

It looks like the 20th, though.

Q. That document, on its fourth page, lists you
as a witness for the defense in this action.

October 26th would be about three weeks ago.

Is your testimony then that you did not speak with
anyone in the Arkansas Attorney General's Office prior


to the filing of this document?

A. No.

Q. That is not your testimony?

A. I am sorry.

Yes, my testimony is I did not speak to anybody prior
to that.

Q. Where the Defendant's Second List of Witnesses
says, "Dr. Coffin will testify that the fossil record supports
the Creation Science model," while that may in fact be
the case, you didn't discuss with anyone from the Arkansas
Attorney General's Office that it was the case?

A. No.

As far as I know, we discussed just what I told you,
my academic background and the area of my expertise.

Q. But prior to October 26th,you hadn't spoke with
anyone about that?

A. No.

Q. Since having spoken with Mr. Humphries between
a week and two weeks ago, what further contact have you had
with the Arkansas Attorney General's Office?

A. Well, the only contact I had is a letter I re-
ceived containing the Act, Act 590.

Q. You received a letter?

A. Yes, plus an accompanying letter from Tim
Humphries, and the contact I have had with these gentlemen
since I have been here [indicating counsel].

Q. Let me understand this:

You received a letter containing the Act from Mr.



A. Yes.

Q. When was the next contact you had with someone
from the Arkansas Attorney General's Office?

A. Yesterday.

Q. Yesterday?

A. Yes.

Q. When you spoke with whom?

A. With Mr. Campbell and Mr. Williams.

Q. What time yesterday was that?

A. Let's see.

About somewhere between 4:30 and 5:00 o'clock.

Q. How long was that meeting?

A. Somewhere around an hour, an hour and a half,
in there.

Q. Would you characterize that meeting as a
substantive discussion of your possible testimony at the

A. What do you mean by "substantive"?

Q. Well, did they discuss the testimony you might
offer about fossils at the trial?

A. They gave me an idea, gave us an idea, what the
deposition would be and more or less what to expect.

Q. When you say "us," did you meet with them with
Dr. Roth?

A. Yes.

Q. So you discussed what the deposition would be


Did you discuss the testimony you were likely
to give at the trial?

A. Not really.

MR. KLASFELD: Excuse me.

[Discussion off the record]

MR. KLASFELD: Back on the record.

I have here another document, which is called
Plaintiffs' First Set of Interrogatories.

Let me just show you the document and ask you if at
any time this document has been discussed with you.

A. I have not seen this.

Q. The substance of it was discussed with you to-

A. I would have to look at it again.

I just noticed that it was new to me.

Q. Sure.

A. Well, I would say that, in the course of the
discussion, some of these points were at least touched
on, such as the first one, the qualifications and so on.

Q. But you didn't discuss the substance of the
facts and opinions as to which you were expected to

A. Not really.

Q. Or your grounds for each opinion?

A. Not in that kind of detail.

MR. KLASFELD: I would like to put my position on
the record about this.

It is, of course, plaintiffs' opinion that we are


entitled to a response to Plaintiffs' First Set of In-
terrogatories prior to Dr. Coffin's deposition, and his
testimony makes clear that there has been no attempt of
any kind to respond to the First Set of Interrogatories
in any kind of meaningful way.

He has said that, apparently, the information con-
tained in Defendant's Second List of Witnesses, which
lists him as a witness, that information was supplied to
us without his knowledge or his review of that.

This failure to allow us the discovery we are en-
titled to prior to the deposition leads me to object to
the notion of terminating the deposition today, and pend-
ing, of course, our discussion with the judge tomorrow, I
would expect to continue Dr. Coffin's deposition either
tomorrow or as soon thereafter as is possible after we
get a proper response to the interrogatories.

MR. CAMPBELL: Your objection is noted.

We did timely file an objection to the interroga-
tories, along with a motion for extension of time to com-
plete the interrogatories.

I think that Dr. Coffin has testified here that the
information which you requested has not even at this
time been given to us by Dr. Coffin, and we had made at-
tempts, as is set out in our objection and the motion for
extension of time, to secure that information, and we
believe that, under the Federal Rules, you can utilize
this time today to secure from him his expert testimony
and the bases upon which he will testify at trial.


Likewise, when we set up the depositions for Dr.
Coffin and all of the other defendant's witnesses with
local counsel in Little Rock, we emphasized to them that,
in order to be able to take or to participate in thirty-
five depositions between now and trial date, it would be
necessary to limit the depositions to all day, from 9:00
in the morning until 4:00 in the afternoon, so we would
have an opportunity to meet with our witnesses for the
first time the night before the depositions.

MR. KLASFELD: Do you have a copy with you of your
response to our set of interrogatories?

MR. CAMPBELL: I don't.

Mr. Williams has that.

MR. KLASFELD: Could we get it up here?

MR. CHILDS: We can do that at our break.

MR. CAMPBELL: Yes, we can do that at the break.

MR. CHILDS: We will be glad to make it available
to you.

MR. KLASFELD: I understand.

THE WITNESS: Could I make a statement?

MR. KLASFELD: Certainly.

THE WITNESS: I was away from October 29 to November

There may have been some difficulty communicating
with me at that time.

MR. KLASFELD: Just for the record, Mr. Campbell,
was there any attempt by your office during that period
to get in touch with Dr. Coffin?


MR. CAMPBELL: I don't know.

Mr. Humphries is the one who contacted the witnesses
for our office.

MR. KLASFELD: Was he instructed, do you know, hav-
ing made the initial contact with Dr. Coffin and the
other witnesses, to get in touch with them again?

MR. CAMPBELL: This is Dr. Coffin's deposition.

I am just not sure at this time.

MR. KLASFELD: We have been supplied, Dr. Coffin,
with a copy of what I believe is your curriculum vitae.

Let me have that marked as Plaintiffs' Exhibit 1
for identification.

[Curriculum Vitae of witness marked
for iden. as Plaintiffs' Exhibit
No. 1]

MR. KLASFELD: Q. Dr. Coffin, would you please look
at Exhibit 1.

A. Yes.

Q. Is this one-page document your curriculum vitae?

A. Yes.

As far as I can see, it's correct.

Q. I am not asking, Dr. Coffin, whether it's

I am asking whether or not you have a curriculum
vitae that you would give to someone if they asked you
for it.

I am asking you:

Is this the document?


A. Yes.

Q. It is.


It seems, at least to my eye, to sort of end abrupt-

Are there other pages to this?

A. No.

That is it.

Q. Is that a document that you supplied to the
Arkansas Attorney General's Office?

A. Yes.

Q. When was that, please?

A. I really cannot remember.

In fact, I'm a little bit surprised, considering the
paucity of communication with them, that they had it,
and I am not sure whether I sent it or my colleague or
my secretary sent it.

Q. Your vitae says that in 1947 you got a biology
degree from Walla Walla College, Washington; is that

A. Correct.

Q. What else did you study while you were there?

A. Well, all that would be involved in a Bachelor
of Arts degree in Biology.

Q. And this indicates that in 1952 you got a
Master's degree in biology from the same university;
is that right?

A. That is right.


Q. Did you spend all of your time during those
five years obtaining that degree?

A. No.

Mostly during the summers.

Q. What did you do the rest of the time?

A. I was teaching.

Q. At Canadian Union College?

A. That is right.

Q. Where is that?

A. That is about in the center of the Province of
Alberta, Canada.

Q. That is quite a commute.

A. Pardon?

Q. I say, that is quite a commute.

Oh. You did it during the summer.

I see.

A. Yes.

Q. And then in 1955 you got a Ph.D. in zoology
from the University of Southern California?

A. That is right.

Q. Was that a specialty in paleontology?

A. No.

It was a specialty in Invertebrate Zoology.

Q. Could you please define for me the field of
Invertebrate Zoology.

A. Those animals that do not have backbones.

Q. What is it that you --

Strike that.


Are these living animals that you studied?

A. Well, Invertebrate Zoology would be all aspects:
anatomy, physiology, behavior, et cetera, for animals
that don't have backbones.

Q. I wanted my question to direct itself to see
whether or not you dealt with extinct, fossilized animals
or recently dead or living animals.

A. It's usually considered to be living animals, but
I did take work with extinct animals.

Q. Did you study paleontology during your doctorate

A. Yes.

Q. How many courses did you take?

A. It has been a little while.

Two, possibly more. I can think of two.

Q. Do you recall who the professors were?

A. Mattux was the first one, M-a-t-t-u-x, I
think, and Easton was the second one, E-a-s-t-o-n.

Q. Did you receive any honors during your Ph.D.
program at the University of Southern California?

A. I was a Research Fellow.

Q. Just what does that mean?

A, It means that I had a scholarship or a fellow-
ship and I assigned with certain research activities of
the institution.

Q. What field were you a Research Fellow in?

A. I was a Research Fellow under Dr. John Garth,
G-a-r-t-h, whose expertise is with carcinology, c-a-r-



Carcinology is the study of crustacea, like shrimps
and crabs.

Q. The study of crustaceans, was that of crusta-
ceans as they are today?

A. Mostly.

Q. Was any part of your Research Fellow work done
in fossils?

A. Not directly.

Q. From the University of Southern California,
you then became Chairman of the Division of Science at
Canadian Union College?

A. That is right.

Q. Is that a church-affiliated school?

A. Yes, it is.

Q. What church?

A. The Seventh-Day Adventist Church.

Q. Did you teach while you were there as well?

A. Where?

Q. At Canadian Union College.

A. Yes, I taught.

Q. What courses did you teach?

A. I taught general science in the secondary
level and I taught general zoology and botany and genetics
in the college level.

Q. What are you referring to when you say "the
secondary level"?

A. High school level.


Q. I see.

Was the high school part of the college?

A. Yes.

It's a small institution and the high school and
the college are together.

Q. I missed a question that occurs to me now.

Is Walla Walla College also a church-affiliated

A. Yes.

Q. What church is that?

A. The same church.

Q. The Seventh-Day Adventist Church?

A. Yes.

Q. Did you teach Creation Science at Canadian
Union College?

A. I taught a course entitled "Philosophy of
Science," which might be comparable.

Q. But in that course of Philosophy of Science,
you taught the discipline or the study of Creation

A. Yes.

Q. In your teaching of general science, general
zoology, botany and genetics, did you also teach Crea-
tion Sciences theories as part of those courses?

A. Yes.

And evolution as well.

Q. I see.

You then left Canadian Union College and became an


associate professor of biology at Walla Walla College;
is that correct?

A. Yes.

Q. What courses did you teach at Walla Walla

A. I taught Invertebrae Zoology, I taught genetics
and evolution, I taught part of the time basic general
biology for freshmen.

Q. Again, did you teach Creation Science in these

A. Yes.

Q. Did you in addition teach a course in the
Philosophy of Science as well there?

A. In comparable material.

I don't think it was named that.

The course name was different.

Q. In 1958, you became a professor and the head
of the Department of Biology at Walla Walla College;
is that correct?

A. Yes.

Q. Did you continue teaching during that time?

A. Yes.

I taught less but I continued teaching.

Q. Did you teach any additional courses?

A. Any that I haven't mentioned thus far, you

Q. Yes.

A. I think I taught a class in microbiology for a


short time.

Q. Do you recall what text you used in the
general biology course you taught at Walla Walla College?

A. Oh, Storer, I believe, is the author.

Q. Could you spell that, please?

A. S-t-o-r-e-r.

Q. Is that book still being used today?

A. I have been out of it for a while.

I really can't say.

Q. Did that book have a section on Creation Science
in it?

A. No.

Q. In the Creation Science parts of the course you
taught, what materials did you use?

A. I prepared my own materials.

Q. I see.

Do you still have copies of those materials?

A. Not in that form.

Q. What form do you have them in?

A. My work since then has been totally devoted to
the subject of creation evolution and it has been expanded
much, much more than that.

Q. In 1964, you left Walla Walla College and went
to the Geoscience Research Institute; is that correct?

A. That is right.

Q. Who offered that position?

A. Dr. Richard Ritland offered me that position,
or he is the one that made the contact with me.


Q. Do you know how he came to come into contact
with you?

A. We knew each other previously.

Q. What was his position at that time?

A. He was at least --

MR. KLASFELD: Excuse me just one moment, please.

[Discussion off the record]

MR. KLASFELD: Back on the record.

Q. The interruption leads me to ask another ques-
tion which I was going to get to later.

Have you brought any documents with you today?

A. Yes, I have some.

Q. Could I see them, please?

A. Yes.

MR. KLASFELD: Off the record.

[Discussion off the record]

MR. KLASFELD: Back on the record.

Let's put on the record that the witness has given
me three textbooks and, what shall we call this, a stack
four inches thick of other documents; is that right,

MR. CAMPBELL: Yes, that is fine.

MR. KLASFELD: Q. Dr. Coffin, how did you come to
bring these documents with you today?

A. We received a list, a sheet with a list of things
we were supposed to bring.

Q. You received that list from whom?

A. Well, I received it from Dr. Roth.


Q. Do you know who Dr. Roth received it from?

A. I would have to ask him, but I suppose from
Tim Humphries or somebody from the Arkansas Attorney
General's Office.

MR. KLASFELD: Off the record.

[Discussion off the record]

MR. KLASFELD: Back on the record.

If I may, let me make a brief statement for the

I have indicated the amount of documents that Dr.
Coffin has made available to me today, and it's obvious
it would be impossible for me to attempt to digest them
and question Dr. Coffin about them, and their delivery
to me this morning frustrates any type of serious inquiry
I can make into Dr. Coffin's work and thoughts and testi-
mony and it's clear we are going to have to continue Dr.
Coffin's deposition from this afternoon and continue it
to a time reasonable to both sides.

MR. CAMPBELL: For the record, the documents were
produced pursuant to the notice of deposition and a
subpoena duces tecum which requested that Dr. Coffin bring
these documents to his deposition.

We were not requested to present them to you earlier
than this date.

MR. KLASFELD: Let me just take a minute to see what
is here.

Off the record.

[Discussion off the record]


MR. KLASFELD: Back on the record.

Q. Dr. Coffin, do you have a copy of the letter
requesting that you bring these documents?

A. No, I don't.

Q. What did you understand the substance of that
letter to be that led you to choose these documents?

A. It was extremely broad and it was difficult to
know what to bring.

Q. I see.

But generally, what did you understand the request
to mean?

A. The materials that would be of particular value
in this particular lawsuit and on the topic of evolution

Q. I see.

I have, Dr. Coffin, read some articles you have
written for the magazine "Origins."

I don't see any of those articles here.

Q. Is there any reason why they are not here?

A. Dr. Roth has the complete set of Origins.

He brought them, so I didn't bring any.

MR. KLASFELD: Off the record.

[Discussion off the record]

MR. KLASFELD: Back on the record.

Q. Going through these documents, Dr. Coffin, I
notice that the curriculum vitae that appears among the
documents you have just given me is different to some
degree from the document we have been discussing this



Let me show you a copy of one of these that you gave
me and I will ask you how that difference came about.

A. Do you mean between the two of them?

Q. Yes.

A. We have a new word processor and I just was
practicing on that the other day.

Q. I see.

And the indication "pp" after the books listed at
the bottom indicates how many pages the book contains;
is that right?

A. Yes, that is right.

Q. Have you taken any courses in continuing educa-
tion since your graduation from the University of Southern

A. Yes.

Q. Where have you taken those courses?

A. At the University of Alberta in Edmonton,
Canada, and Notre Dame University in Indiana.

Q. And when was that?

A. The first, 1956 and '57; the second, 1965 and
and '66.

Q. Were each of those for a full year?

A. No.

They were in the summer.

Well, no. I beg your pardon.

It was two summers in Alberta and one year in Indi-


Q. I see.

Was that the entire year?

A. It was nearly a full load.

But it was during the school year.

Q. I see.

So that while you were associate professor of
biology at Walla Walla during those summers, you took
courses at the University of Alberta.

And during the time you --

Did you get a leave of absence from --

A. Let me back up, please.

It was when I was Chairman of the Division of Science
of Canadian Union College that I did the work at the
University of Alberta.

Q. I see.

So that would then have been 1955 and '56 rather
than 1956 and '57.

A. What did I tell you?

Q. You said 1956 and '57.

A. Okay.

Let's move it back one year.

Q. And then at Notre Dame, you were there while
you were senior research assistant at the Geoscience Re-
search Institute?

A. Yes.

MR. KLASFELD: Off the record.

[Discussion off the record]

MR. KLASFELD: Back on the record.


Q. What course did you take at the University of

A. A psychology course and a methods course, I
think in mathematics.

Q. Methods in mathematics?

A. Yes.

Q. What did they teach you about methods in mathe-

A. Teaching methods in mathematics.

Q. I see.

It was an education course, was it?

A. Yes.

Q. How did you come to take these two courses?

A. Because the Canadian system required those of
us who were not Canadians to meet certain requirements,
despite the fact that we might already have a Ph.D., so I
had to go and take some courses there.

Q. What did you study at Notre Dame?

A. At Notre Dame, I was working in geology and

Q. What courses did you take there?

A. I took mineralogy and sedimentary petrology.

Q. Fine.

Go ahead.

A. And stratigraphy, s-t-r-a-t-i-g-r-a-p-h-y.

I took a paleontology course but I can't remember
what the name of it was.

Q. I see.


Were these undergraduate courses that you took?

A. Well, I didn't pay much attention to that be-
cause I already had a degree.

I think they can be applied either way.

Q. Do you recall whether they were part of the under-
graduate curriculum?

A. Some of them would be.

Q. Do you recall which ones?

A. Probably stratigraphy and mineralogy would be

Q. And the other courses, were they in the gradu-
ate curricula?

A. I would have to check the bulletin again.

I just can't tell you.

Q. Do you recall who the paleontology professor

A. I can't remember his name.

Q. Is there some reason these continuing educa-
tion programs aren't listed on your resume?

A. No.

This is the curriculum vitae I have sent out through
the years. It's not complete. I just haven't felt it
was necessary to put down every item, including publica-

They are not all there.

Q. Did you get grades in these courses at Notre

A. Yes, I did.


Q. What were they?

A. I think they were A's.

Q. Have you taken any other continuing education
courses since your work at Notre Dame?

A. I was a member of a National Science Founda-
tion field conference.

I guess that is what it would be called.

It was on the structure and origin of volcanic --
that isn't quite the right name -- on volcanic phenomena,
let's say.

Q. When was that?

A. Well, actually, it was not after this, not after
Notre Dame.

It was before Notre Dame, the summer before.

It was the summer of '64.

Q. What work did you do in connection with this

A. We spent four weeks, I believe, touring the
greater Yellowstone area.

Q. How were you chosen for this project?

A. I saw it advertised in some science journal and
I submitted my name and was accepted.

Q. Was there a competition of some kind that you
are aware of?

A. Only insofar as the number might be filled up
and I would be too late, like a class.

Q. I see.

The only competition was in the form of a race?


A. In the form of getting there before there
wasn't any more room.

Q. Was there any other continuing education ex-

A. No.

Q. During the time you have been teaching, have
you applied for grants of any kind from the government or
from foundations?

A. Yes.

Q. Have you received any?

A. Yes.

Q. What grants have you received?

A. I received, when I was at Walla Walla College,
two or three grants dealing with research in -- I said
we weren't going to use this word again, in carcinology.

Q. I said we weren't going to use it again.

Who did you receive those grants from?

A. From the National Science Foundation.

Q. And since then have you received any other

A. Did you say from the government?

Q. From the government or --

A. No.

Q. -- or any other kind of institution.

A. No.

Q. Or any kind of foundation, private foundation?

A. No.

Q. Have you been turned down for any grants from


the government or any foundation?

A. I think -- it has been a while.

I think I was at least once.

Q. Do you remember when that was?

A. I can't give you the dates on that.

Q. Was it the National Science Foundation?

A. Yes.

Q. Was that after these grants they awarded you
or was it before?

A. It was during that time.

Q. I see.

And since that time you haven't make application
for any grants?

A. No.

Q. I see.

What was your doctoral thesis in?

A. My doctoral thesis was the -- this is the title:
"The Biology of Paurus Samuellis."

Q. What is pagurus samuellis?

A. Pagurus samuellis is a species of hermit crab
that lives on the California Coast.

Hermit crabs are those crabs that live in empty

Q. Have you ever received any academic discipline
at the institutions at which you have been a student or
a teacher?

A. No.

Q. How much are you paid for being a senior re-


search assistant the Geoscience Research Institute?

A. You would just about have to ask my wife that

I turn my check over to her.

I am just frankly not able to actually give you an
exact figure.

Q. What is your best guess?

A. It must be -- it's somewhere around twelve to
fifteen hundred dollars a month.

- - -


MR. KLASFELD: Q. Your curriculum goes on to say
you a member of the association for the Advancement of

Could you tell me something about the makeup of
that association?

A. Well, it is a large -- it is the major
science association of North America, involving sciences
all the way from astronomy to botany and so on.

Q. How does one become a member of that associa-

A. I don't think -- I've sort of forgotten, but I
don't think it's a recommendation requirement in this case.
I think it is merely a paying dues.

Q. Can a nonscientist become a member, if you

A. I'm not sure.

Q. Do you receive a journal?

A. Yes, indeed, Science.

Q. Science Magazine.

Have you written any articles for that journal?

A. No.

Q. Have you submitted any?

A. Yes. They were not accepted or, I have once.

Q. You have once submitted?

A. Yes.

Q. You are also a member of the Geological
Society of America?

A. Yes.


Q. How does one become a member of that organiza-

A. One has to be recommended for membership in
that case by a member.

Q. I see.

And who recommended you?

A. Dr. Raymond Gottschalk (phonetic). He is or
was the chairman of the geology department of Notre Dame

Q. Do they have a journal?

A. Yes, two journals.

Q. Do you receive those journals?

A. Yes.

Q. Have you ever submitted anything for publica-

A. Yes.

Q. To either of those journals?

A. Yes.

Q. Were they published?

A. Yes.

Q. Were those articles in the package of documents
you gave me this morning?

A. There were two articles in the package of
documents, one from the GSA Bulletin and one from the
Journal of Paleontology, which is not their journal.

Q. Are those articles reviewed prior to their print-
ing and accepted or rejected or do they just publish
whatever is submitted?


A. It is a tear review process.

Q. When was those articles written?

A. I think the GSA Bulletin article was in 1971
and the Journal of Paleontology article was 1973, I

Q. What was the topic of the GSA Bulletin

A. The floatation of equisetum.

Q. What are equisetum?

A. Horsetails, scouring rushes, joint grass.

Q. And what was the article in the Journal of
Paleontology about?

A. I may not have the exact title, but it is
close to the orientation of Yellowstone petrified trees.

Q. What did you mean in the article by orienta-

A. The way these trees are lined up in the rocks.

Q. Did either of these articles come to any
conclusion about the merits of evolution or Creation

A. No.

Q. And both of those articles were within the
package that you gave me today?

A. Yes.

Q. Are these the only two articles you have
written for either of those journals?

A. Yes.

Q. The resume says you are also a member of Sigma


Xi. What society is that?

A. It is the Honorary Scientific Society.

Q. How does one become a member?

A. By recommendation.

Q. And who recommended you?

A. Dr. -- I can't recall his first name -- Chen,
of the University of Southern California.

Q. Was that during your PhD program there?

A. Right at the conclusion of it.

Q. And do they have a magazine?

A. Yes.

Q. Do you receive that regularly?

A. Yes.

Q. Have you ever published an article in it?

A. No.

Q. Have you ever submitted an article for publica-

A. No.

Q. The article which you wrote which was rejected
for Science Magazine, is there a copy of that in the
documents that you gave me this morning?

A. No.

Q. What was the subject of that article?

A. It was the same subject that was published in
the Journal of Paleontology.

Q. Was it the same article?

A. No, there was some modification.

Q. You submitted it to Science Magazine before you


submitted it to the Journal of Paleontology?

A. I believe so.

Q. Do you recall sort of the general area of what
the modification was?

A. Each journal has its own format.

Q. And style?

A. Yes.

Q. The changes were stylistic?

A. They were that and there may have been some
textual changes as well.

Q. This was the only article that you ever sub-
mitted to Science Magazine?

A. Yes.

Q. And you are also a member of the Creation
Research Society?

A. I used to be but my membership has lapsed.

Q. When did it lapse?

A. Well, it is hard to say. We get the Journal
at the Institute and it just sort of dawned on me
recently that nobody had asked me for any money for
some time and I am sure my membership has lapsed.

Q. Have you not continued to renew your member-
ship for any particular reason?

A. I am not too -- it is not too important a
journal to me.

Q. What do you mean by it is not too important?

A. I don't agree with some of the research in it
or some of the articles.


Q. Do you remember in particular any of the
articles with which you disagree?

A. Oh, there was one article on Mt. Arat.

Q. What did that article say?

A. Oh, it is hard for me to remember the details.

Q. In general?

A. In general it was talking about the geology of
Mt. Ararat and trying to draw some implications which I
didn't really agree with.

Q. What were the implications?

A. Its past geological history.

Q. Are there other articles that you can recall
that were in the magazine that you disagree with?

A. There are some articles -- there have been
some articles on glaciation that I haven't agreed with,
evidences for glaciation.

Q. And you disagreed that those were evidences
for glaciation?

A. They claimed they were not evidences for
glaciation and I disagree with that.

Q. You believe they were?

A. Yes.

Q. Are you paid for doing anything else other
than being senior research scientist at the Geoscience

A. No, that's my full-time work.

Q. During the time that you were at the Canadian


Union College and Walla Walla College, did you, while
teaching there, conduct any scientific research?

A. Not at Canadian Union College but at Walla
Walla College I did, yes.

Q. What was the nature of the research work that
you did?

A. It was on some of the life cycles of crabs in
the Puget Sound.

[Discussion off the record]

MR. KLASFELD: Q. Now, since you have become
senior scientist at the Geoscience Research Institute,
what kind of research have you conducted?

A. My research has been mainly with paleontology.

Q. From 1964 until the present?

A. Yes.

Q. Why the switch from crabs?

A. Well, invertebrate paleontology is really a
very good way to enter the area -- I mean, invertebrate
zoology is a good way to enter paleontology, because 95
percent of your fossils are invertebrate.

Q. Aside from the one course that you took at
Notre Dame in paleontology, have you taken any other
courses in paleontology?

A. I really need my transcript to refer back to.

Q. But, in any event, it was during that one year
at Notre Dame?

A. Yes, that's right.

Q. Could you describe the nature of your research


on the crabs, exactly what it was that you did?

A. Okay.

My doctoral dissertation, the title of which I men-
tioned already, had to do with working out certain phases
of the life cycle which were unknown. Hermit crabs had
never been successfully reared in the laboratory up to
that time and there was a step in the transfer of the eggs
to the posterior portion of the abdomen where they are
carried for a period of time that was perplexing and
unknown, which I was able to work out.

Q. How were you able to do that?

A. The animal lives in a seashell and it extrudes
its eggs and the eggs get to the back of the abdomen and
are glued to the appendages on the back of the abdomen
inside the shell, so it never could be seen.

So I had the glassblower in the chemistry department
blow me some glass seashells and they were willing to use
those for their homes, providing there weren't any
natural seashells, and thus I was able to see the actual
ovulation process and see how it happened.

Q. So the nature of your research on crabs was
to observe what was going on underneath the shells?

A. Inside.

Q. I don't mean to denigrate it, I just mean to
describe it.

[Discussion off the record]

MR. KLASFELD: Q. When you went to work at the
Geoscience Research Institute, was the understanding that


you would go to work in paleontology?

A. Yes.

Q. I guess I don't understand why the switch.

A. It is not, as I say, it is really not that
great a shift from invertebrate zoology and paleontology
and my paleontology has been in the area of invertebrate
paleontology. So vertebrate paleontology is not my

Q. I see.

But the study of paleontology and the study of
fossils is really entirely different than the studies of
crabs in a --

Q. As far as that specific research is concerned,
yes. My work in the Geoscience Research Institute includes
paleontology, but it is not limited to that. It is
science in religion, you might say.

Q. What else, other than paleontology, do you do?

A. Speciation.

And, as I say, science and religion, relating of
science and religion.

Q. What do you mean by speciation?

A. Change within organisms.

Q. What kind of research are you doing on that,
if any?

A. I'm really not doing any research on that
right now.

Q. What research have you done?

A. Well, work with the crabs would be in the area


of speciation. At least it would be involved in it.

Q. Did you continue some of that crab research
when you went to the Geoscience Research Institute?

A. No, not the actual laboratory.

Q. What is the nature of your work in science and

A. This, of course, is an institution that's
funded by the Seventh-Day Adventist Church.

Q. The institute is funded by the Seventh Day
Adventist Church?

A. Yes, my work is to, in part, to show the
relationship between science and religion.

Q. Do you conduct any experiments to do that?

A. Sure, that's where our research comes in.

Q. What kind of research are you doing?

A. I have been working in the Yellowstone region.
For instance, the paper on the Yellowstone petrified
forest and paper on flotation, these are aspects of
research dealing with that.

Q. I thought I understood you to say that those
articles made no reference to creation, science or

A. They didn't, but they --

Q. Why do you then make reference to them in this
discussion if you work in the areas of science and

A. Because they -- they have implications for


Q. What is the nature of your research in

A. The petrified forest of Yellowstone.

Q. In other than going there and looking at the
petrified forest, what else do you do?

A. We measure the tree rings; we extract the
fossil pollen out of the sediments; we determine the kind
of wood involved and orientation of the trees, et cetera.

Q. When you say "we," who is doing this work with

A. I have often had graduate students with me.

Q. I see.

How much of your time do you spend at Yellowstone
during the year?

A. That's limited by the weather.

Q. I see.

But how much?

A. Oh, one or two months a year.

Q. And what do you do the other 10 months?

A. Some of the materials that I brought, writing,
research, that is, literature research.

Q. I guess I am trying to understand what the
research that you do is and I understand that you go to
Yellowstone and gather data.

When you get back to the Institute, what is it that
you do there?

A. Well, we analyze it. We try to determine
what the information is telling us.


Q. How do you do that?

A. Well, the article on orientation of the trees
would give an idea of how we go about that.

Q. Inasmuch as I don't have the article in front
of me, could you describe that?

A. This article shows the relationship of the
trees to each other and comparison is made with living

Q. What are the relationships to the trees to
each other in Yellowstone?

A. There is a parallel orientation for many of the
levels --

Q. What do you mean?

A. -- which we don't usually fine in a living

Q. There is a parallel what?

A. Parallel orientation.

Q. I guess I missed the word.

You mean that's how the petrified trees are lying,
parallel to one another?

A. Yes, yes.

Q. You say that's different than the way trees
are found in the living forest?

A. Yes.

Q. In the living forest, then, they are not

A. Not unless there are some extenuating circum-
stances, such as being along the open edge of the forest


where the wind can reach it.

Q. What is your explanation for the parallel
orientation of petrified trees?

A. It looks like some different forces have been
in operation than are in operation today.

Q. I see. That have made them lie parallel to
one another?

A. Yes.

Q. What are those forces?

A. Movement of volcanic muds and breccias.

Q. And those volcanic muds and breccias move the
-- were the trees petrified when they moved them?

A. No.

Q. But these volcanic muds and breccias moved
the trees to where they are now and are the cause for
them being parallel?

A. Yes, it appears that way.

Q. When did that take place?

A. The usual geological reckoning for that
activity is in the Eocene.

Q. And now long ago was that?

A. Let's see. That is considered to be -- I would
have to check for sure, but somewhere in the realm of
40, 50 million years.

- - -


Q. Is that how long ago you believe it took

A. No, I have no different views on it.

Q. What are you views?

A. I think it is much more recent.

Q. How recent?

A. I think it is a phenomena of catastrophism
which is only a few thousand years ago.

Q. But you do believe that it was caused by
volcanic muds and breccias?

A. Yes.

Q. And what caused the volcanic muds and breccias?

A. Eruptions from some volcanic center.

Q. Do you know where that was?

A. Mount Washburn is considered to be one of the

Q. Excuse me for a moment, you seem to be dif-

You used the words "considered" before in terms of
describing the Eocene period. You said something like,
"It is considered to be X million years ago but that
wasn't your opinion."

In talking about Mount Washburn, are you speaking
of your opinion or what somebody else considers to be

A. I am using literature that has been published
on this and it is not too clear-cut.

It is hard to find the source areas.


Q. Why couldn't this have happened forty or
fifty million years ago?

A. It could have, but my own personal opinion
is that it didn't.

Q. Because why?

A. Because my view of earth's history is not that,
that life on earth has been that long or that old.

Q. Is there any data that you developed in your
work in Yellowstone that would preclude the earth being
that old?

A. No.

Q. It is that you don't believe the earth is
that old so it had to have happened more recently?

A. My belief, in regard to the age of the earth,
is based on other evidences, not Yellowstone.

Q. I see.


[Recess taken]

MR. KLASFELD: Q. Your resume also mentions that
you have papers in various church and religious journals.

A. Yes.

Q. What journals are those?

A. The church paper is the Advent Review.

That is the official church paper.

I also have articles in Science of the Times.

Q. Science of the Times?

A. Yes.

Liberty, Ministry, These Times.


[Discussion off the record]

MR. KLASFELD: Mr. Campbell and I had a discussion
off the record in which Mr. Campbell has stipulated that
Dr. Coffin's testimony at the trial will be limited only
to his work in the area of fossils and that on that
basis, I'll limit my questioning of Dr. Coffin's recent
work to the area of fossils.

MR. CAMPBELL: If I may add?


MR. CAMPBELL: His testimony will center arount
the fossil record.

I don't know the distinction, if there is one, be-
tween fossils and fossil record, but at least be that

MR. KLASFELD: That's fine.

I just want to preclude him testifying about --

MR. CAMPBELL: Astronomy.


MR. CHILDS: Dr. Coffin, do you feel comfortable
about that?

Do you feel there is any area of expertise that
you would be qualified to testify about at the trial
other than the fossil record?

TNE WITNESS: No, I feel comfortable with that.

[Discussion off the record]

MR. KLASFELD: Q. The articles that you have
written for these religious and church journals, have
they been science articles or religious articles?


A. They are both.

Q. You said that your work was in the area of
science and religion.

Have you written exclusively religious articles?

A. Without any reference to science?

Q. Well, we will start with that question, yes,
without any reference to science.

A. I don't think so.

Q. Have the articles in these journals been dif-
ferent in substance than the articles in Origins Magazine,
for instance?

A. Well, Origins is a scientific journal.

Q. Yes, I understand.

I am saying these church and religious articles
that you have written, have they been different in sub-
stance than the articles that you have written for

A. Not really in substance but in level.

Q. When you say "level," you say the science is

A. Reader level.

Q. I see.

If I could just ask you a few questions about the
crabs, and that will be the end of it.

Do you have a copy of the --

A. Dissertation?

Q. Yes, the dissertation.

A. Not with me.


Q. Is it possible for us to get a copy of it?

A. Yes.

MR. CHILDS: We will make that available.

THE WITNESS: It is not here.

MR. CHILDS: You will send it to our office in Little
Rock and we will make it available because we are sort of
in a turmoil this week.


MR. CAMPBELL: For the record, may I send it to Mr.
Kieley or send it to you in New York?

MR. KLASFELD: I think to me in New York.

Q. Could you briefly describe the nature of your
research with crabs?

A. I told you about part of it with --

Q. I understand you observed what was going on
under the shells.

What else did you do?

A. Because it had never been possible to grow them
in the laboratory, I worked on that aspect of it and was
able to bring the crabs all the way from eggs through
larval states to adults in the laboratory.

Q. Did you experiment with conditions that were
conducive to breeding?

A. Yes.

Q. How did you alter the conditions?

A. The main problem was food for the larvae. I
was able to find the right kind of food.

Q. How did you do that?


Did you lose a lot of crabs?

A. Yes.

Q. And how did you finally come to finding out the
right way to feed the crabs?

A. Mostly just trial and error and somebody referred
to me or mentioned to me the use of brine shrimp such as
are used to feed tropical fish and they turned out to be
very satisfactory.

Q. Were those the natural source of food for the

A. Yes and no.

The natural food is plankton which is floating micro-
scopic organisms.

These brine shrimp are not normally -- don't make up
a very large fraction of the ocean plankton, but they are
floating microorganisms.

Q. Did you use the normal food, the plankton?

A. We tried that.

Q. That didn't work?

A. No.

Q. Do you know why?

A. Plankton is extreme sensitive to changes in
the normal environment.

They do not survive in the laboratory.

Q. So, having won this battle of trial and error
on how to keep the larvae alive, then what did you do?

A. I wrote the dissertation and submitted it.

Q. The research that you did after the completion


of your dissertation, what did that consist of?

A. That was applying this technique to other species
of crustaceans that did not have their life cycles undis-

Those papers are in the material.

Q. I see.

Did you design experiments for your work with the

A. Yes.

The glass shells would certainly be an experimental

Q. And the different feeding techniques?

A. And the different feeding techniques.

Q. Had other people done work in this area and
unable to find the answer or were you just doing work in
an area where people had never done work before?

A. The question concerning the ovulation of the
hermit crabs had been discussed back and forth for ninety
years and not knowing what the answer was.

Q. How would you compare the nature of the research
that you did with the hermit crabs with the research that
you do with the petrified rock?

A. Well, it is really very different except that
research techniques, literature research, applies pretty
broadly in all scientific research.

A doctorate in education is not helpful insomuch as
in the specific area of your dissertation as the methods

Transcript continued on next page

Deposition of Harold G. Coffin - Page 2


of scientific research that you developed and learned.

Q. How would you describe the methods of your
petrified wood research?

A. I am just not too sure.

Repeat that again.

What are you asking?

Q. How would you describe the methods of your
research with the petrified wood?

A. Okay.

That's basically the method of science which is
observation and experimentation.

Q. What kind of experiments did you do?

A. The flotation experiment was related to the
petrified wood.

Q. How did the flotation experiment work?

A. How did it work?

Q. What was the methodology for the experiment?

A. It was obtaining horsetails, putting them into
different controlled situations and observing their flo-
tation in water.

Q. And the horsetails were substituting for the --

A. The horsetails were chosen because they are
modern forms of fossil representatives in the same group.

Q. What kind of fossils did you discover in Yellow-
stone, then, that the horsetail represented for you in
the experiment?

A. Horsetails.

Q. So it was these horsetail fossils that were


aligned in a parallel manner that you were trying to ex-

A. No, the paper on the orientation concerned the

Q. As a result of your experimental on the flota-
tion of horsetails, did you derive any conclusions in
the area of evolution versus Creation Science?

A. Relative to -- on the basis of that experiment,

Q. What were those?

A. That not all vertical fossil horsetails are
necessarily in position of growth.

MR. KLASFELD: I am sorry, could you read that, please.

[Record read]

MR. KLASFIELD: Q. And what relevance does that have
to the Creation Science versus evolution controversy?

A. It has to do with the aspect of catastrophy in

Q. How?

A. Flotation would be a phenomenon of catastrophy
or could be a phenomenon of catastrophy.

Q. Could you describe for me how the experiments

A. I can, but let me also say that the article
describing the flotation is in the material with illustra-

Modern living horsetails were placed into tanks of
salt or ocean and freshwater and observed over a period of


days as to their sinking characteristics and their floating

Q. What did you discover?

A. I discovered that a fair proportion of them will
float vertically and sink vertically.

[Discussion off the record]

MR. KLASFELD: Q. I am sorry, did you say they all
floated vertically or some did?

A. No, about two-thirds.

Q. Were you able to determine why some did and some

A. No.

Q. Did you attempt to?

A. Yes.

- - -


A, Yes.

Q. What experiments did you do to find that out?

A. The horsetails are hollow and so some of the
experiments, the partitions between the joints, were
removed in order for the air to pass out more easily to
determine whether that might be a factor in their
floating characteristics.

Q. But the result of that experiment was --

A. Inconclusive.

Q. -- inconclusive.

Did you conduct any other experiments?

A. I tried agitation of the water as a factor for
increasing the rate of absorption of water by these
plants. Again, more or less inconclusive.

Q. And what was the importance of this flotation
experiment in terms of creation science and evolution?

A. Well, as I mentioned, it is related to
catastrophism in that a view of catastrophism would
postulate flotation phenomena of this type.

Q. And, therefore?

A. It would be a factor in support of catastro-

Q. Did you gather any evidence about how long
ago this flotation might have taken place?

A. I was not dealing with that at all.

Q. I see.

Let me just make sure in my own limited way I
understand what you are saying.


You did some experiments on horsetails but found
that they floated and that, because they floated verti-
cally, they might have been fossilized vertically, which
supports the case for catastrophism, but that you did not
do any experiments to determine when that might have taken

A. That's right.

Q. Is there some reason you didn't conduct those

A. I don't know what experiments one would do.

Q. How large were the tanks in which you floated
the horsetails?

A. One was about 4-by-8.

Q. You are speaking feet?

A. Yes, by 3 in depth. The other was 4-by-4-by-

Q. How large is a horsetail?

A. Full grown, full size [indicating].

Q. The witness held his hand about three feet off
the floor.

A. Yes, that's about right.

Q. How many horsetails did you have in a tank at
any one time?

A. 120.

Q. Each experiment?

A. Salt and fresh.

Q. So there were 120 in one tank and 120 in the


A. No.

Q. Sorry.

A. I have to look in my paper, but I believe it is
120 together for both.

Q. What experiments did you do to satisfy yourself
that the conditions in the tank would be similar to the
conditions that existed at the time the catastrophy took

A. Agitation would be one feature. It is a possi-
bility, that's why I did it in both salt and fresh water,
because we are not sure. That's about it.

Q. What about the fact that the real life occur-
rence took place in much larger areas than the tanks?

A. I don't think that would be a factor involved.

Q. Same things in the tanks as in a lake or a

A. Pretty close.

Q. How did you agitate the water?

A. It was open to the elements. So a certain
amount of the time it was just wind blowing agitating the
surface and occasionally it would be stirred by hand.

Q. The tanks were outdoors?

A. Yes.

Q. How occasionally were they stirred by hand?

A. Two or three times a day.

Q. For how long?

A. Until the water was circulating well.

Q. How long would that take?


A. Three to five minutes.

Q. Was this back and forth on one side or round
and around the tank?

A. It was -- the tanks are too large to go all the
way around. Well, one could, but mostly on one side,
causing the circulation of the water.

Q. How did the agitation affect the horsetails?

A. It did not make any substantial difference to

Q. Was the density of the horsetails in the tank
about the same as you would imagine the density was in the
real life occurrence?

A. The horsetails, the fossil horsetails, are
most like the horsetails -- the modern horsetails are in
the fall, when they start to dry up, and so it was that
condition that I used.

MR. KLASFELD: Could you read back my question,

[Record read]

MR. KLASFELD: Q. What I mean, the number of horse-
tails in the limited area of the tanks, was that the
density with which they occurred in relationship to one
another in real life?

A. Yes, very similar.

Q. Had you done some studies of that in order to
choose 60 for each tank?

A. The larger the number, the better as far as
scientific experimentation is concerned.


Q. Not if they all filled up the tank?

A. That would be true. There would be some
limitation of space, but there wasn't any problem in this

Q. What I am trying to get at, was the limitation
of space in the tank different than the horsetails occur
in the natural environment?

A. No, because you find them in the same density
in the way you mean it, in the fossil record.

Q. You mentioned before something about pollen.
What was that in reference to?

A. About what?

Q. Pollen.

A. Pollen in the sediments in the Yellowstone
petrified forest.

Q. In the organizations of which you are a member,
have you ever held any office?

A. No, I have not.

Q. Have you ever had any special duties in connec-
tion with those organizations?

A. I've given lectures in relationship to --

Q. Which organization?

A. Sigma Xi.

Q. When was the lecture?

A. When I was at Walla Walla College in about 19 --
I would say somewhere between 1960 and '64.

Q. Where was that lecture given?

A. In Walla Walla.


Q. That's not where Sigma Xi has its offices?

A. Sigma Xi has chapters in educational facilities
all over the country.

Q. So you addressed the Sigma Xi chapter in Walla

A. That's right.

Q. Your lecture was presumably on crabs?

A. No, it was on periodicity in invertebrate

Q. What is periodicity?

A. Cycles of activity.

Q. Are you a member of any society that is not
listed on your curriculum vita?

A. No. National Geographic Society.

Q. Have you ever made application to a society and
been denied?

A. No.

Q. Have you ever sought a license which you weren't
given in the area of science?

A. No.

Q. Do you do any teaching now?

A. Guest lecturing.

Q. Where have you guest lectured?

A. In various classes at Loma Linda University.

Q. Which classes?

A. General geology, historical geology, graduate
biology seminars, I guess it would be called. That's all
that comes to mind at the moment.


Q. And that's been true since 1964, has it?

A. Not at Loma Linda University.

Q. Have you been guest lecturing elsewhere?

A. Yes, at Andrews University where I lived for
most of that time from '64 until now.

Q. Is Andrews University a church affiliated --

A. Yes, it is.

Q. Seventh-Day Adventist Church?

A. Yes.

Q. Are you the member of any other creation
science organizations?

A. No.

Q. The Institute for Creation Research?

A. That's not a membership organization.

Q. The Bible Science Association?

A. No.

Q. Citizens for Fairness in Education?

A. No.

Q. Citizens for Balanced Education As to Origin?

A. No.

Q. Let me mark as Plaintiff's Exhibit No. 2, a
letter from the Creation Science Legal Defense Fund, and
some attached articles to that letter.

[Document more particularly identi-
fied in the index marked for
identification Plaintiffs' Exhibit
No. 2]

MR. KLASFELD: Let me, Dr. Coffin, show you a copy


of this letter and ask you if you have seen it before.

A. I can't remember exactly, but this is a form
letter and I wouldn't be a bit surprised it was sent to

Q. Your name appears on the left-hand side.

A. Yes.

Q. Do you know how it came to be there?

A. Yes, they asked me if I would be a witness for
the trial that was -- where was it? --here in San
Francisco, wasn't it? Or no, Sacramento.

Q. This letter, though, doesn't make any reference
to the case in San Francisco. It refers to this action
in which we are involved here today, is that correct?

A. I didn't read it all.

You did.

Let me look at it for a moment.

Q. I think if you look at it, you will find that
that's correct.

A. Well, if this paper is referring only to this
situation involving Arkansas, then I can truthfully say,
if it was sent to me, I did not read it. I am not aware
of it.

Q. Your name appears in the left-hand column.
Did anybody discuss it with you before it was sent?

A. I suspect that that is a holdover from my
willingness to be a witness for them in the Sacramento

Q. Who is the "them" that you are referring to?



Q. By which you mean?

A. Creation Science Research Center, San Diego.

Q. But you weren't part of this fund-raising

A. No, I never submitted any money to them.

Q. Are you a member of any other kind of organiza-
tion that's not listed on the --

I presume you are a member of the Seventh-Day
Adventist Church?

A. Yes.

- - -


Q. Any other organizations, political organizations?

A. I am wracking my brain trying to think of organi-
zations that I belong to, but I can't think of any others.

Q. Were you approached to be an intervenor in this
action by any group?

A. Please explain what you mean by an intervenor.

Q. There was a motion made to intervene in this
case by a group -- and Mr. Campbell will correct me if I
am wrong on the law -- who felt that their interests were
not being adequately represented at the trial by either of
the parties and they sought to intervene in the trial so
that their position could be adequately represented.

A. I did receive some communication, and I'm not
certain whether it was in connection with Arkansas, whether
or not they could use my name, sort of like on the side of
the list there [indicating] as an expert in the area of
creationism and I agreed to it.

Q. But you never discussed the possibility of your
becoming a party?

A. No, I am not a party to it.

I know nothing about the organization.

Q. You, at one time, were a member of the Creation
Research Society, is that correct?

A. Yes.

MR. KLASFELD: I would like to have marked as Plain-
tiffs' 3 for iden. an application form for the Creation
Research Society.

[Copy of application form for


Creation Research Society marked
for iden. as Plaintiffs' Exhibit
No. 3]

[Discussion off the record]

MR. KLASFELD: Q. Let me ask you, Dr. Coffin, the
application form describes four types of membership.

Would you tell me what kind of membership you were?

A. I would be a voting member.

Q. You were a voting member.

The membership forms requires on it that if you were
a voting member, you must have subscribed to the four
principles of the Creation Research Society.

Do you subscribe to those principles?

A. I subscribe to -- the first one, I do not accept

Q. Let me read into the record the first one, which

"The Bible is the written Word
of God, and because we believe it
to be inspired thruout, all of
its assertions are historically
and scientifically true in all
of the original autographs. To
the student of nature, this
means that the account of origins
in Genesis is a factual presenta-
tion of simple historical truths."

If you could state for the record, Dr. Coffin, in


what respect you disagree with that statement?

A. This is a statement out of a belief of the
inerrancy of Scripture, which I do not subscribe to.

Q. Do you believe the Bible makes mistakes?

A. Yes, occasionally, small mistakes.

Q. Which ones?

A. The number of demoniacs.

Q. What is a demoniac?

A. Demoniac was the crazy men that Jesus met on
the opposite side of the Sea of Galilee.

One person says, two, another persons says one.

Q. What do you think?

A. I don't know.

Q. What other mistakes are in the Bible?

That's not so much a mistake as a contradiction
within the Bible?

A. Within the testimony of those authors, biblical

Well, for instance, there are two main sources from
which Scripture comes, the Massoretic and the Septuigent.

In one, numerical figures are different than the
other and they are both the Bible.

Q. Which numerical figure?

A. Oh, many of them.

Q. What is the source of the Massoretic?

A. It is a Hebrew source.

Q. And the Septuigent?

A. A Greek source.


Q. Do you have any view about which is correct?

A. I am not a theologian.

The usual view is that the Massoretic is more correct.

MR. CAMPBELL: Just for the record, here, David,
since we did limit his expertise to the fossil record, I
home you will not consider him an authority in religion?

MR. CHILDS: He is speaking personally.

MR. KLASFELD: I understand that.

I am simply trying to explore his disagreement to the
extent there is any with the four --

MR. CAMPBELL: Tenets of membership to the Creation
Research Society.


Thank you.

Q. Do you have an opinion about how those mistakes
occur in, otherwise, an inerrant book.

A. Yes, I do, but I don't think it is of value be-
cause I am really not a theologian.

Q. How do you think those mistakes came to be?

A. To answer that, I have to go more deeply into
the philosophy of inspiration of the Bible authors.

My view is that the inspiration that God provided
the Bible authors is message inspiration, not verbal in-
spiration. They used their own style.

Q. They, the authors?

A. The authors used their own style.

They were influenced by the society of which they
were a part. They were not machines through which God dictated.


Q. The nature of the errors in the Bible which
you believe exist strike me as being minor.

Would you characterize them as minor?

A. Very much so.

Q. So that with the exception of some minor
discrepancies, are you in agreement with Tenet No. 1?

A. All its assertions are historically and sci-
entifically true with the exception of minor problems.

Q. No. 1, are you in agreement with No. 2?

Let me just read it for the record.

"All basic types of living things,
including man, were made by direct
creative acts of God during Crea-
tion Week as described in Genesis.
Whatever biological changes have
occurred since Creation have ac-
complished only changes within the
original created kinds."

A. I subscribe to that.

Q. How do you define "kinds"?

A. Kind is a broad term.

It would be defined differently with different taxo-
nomic groups of animals.

Q. You mean there is a different definition for
each different group of animals?

A. Because it is a broad term and has no specific
meaning to a taxonomist, one who classifies living things,
it cannot be pinpointed to a definite meaning.


Q. Well, how would I know if a change took place
that wasn't within the original created kinds?

A. Well, that's what evolutionists have been look-
ing for for a hundred twenty years.

Q. But what I mean to ask is, how do I know where
the barriers are?

I mean, how do you define kinds such that if an
evolutionist was trying to find that information, he
would know or she would know when it crossed that barrier?

A. If we look at the fossil record and compare it
with living organisms and we see the same basic categories
of plants and animals from the past to the present, we
could get some feel as to what those basic created kinds

Q. How many kinds are there?

A. I haven't counted them.

Q. About how many?

A. I don't know.

Q. Ten thousand?

A. More than that.

Q. More than ten thousand?

A. Yes.

Well, I don't know.

I really have to say I don't know.

Q. A hundred?

A. Certainly more than that.

Q. Can you give me the ends of the spectrum?

MR. CAMPBELL: He answered the question.


He really doesn't know.

MR. KLASFELD: I understand he doesn't know.

Q. But it is more than a hundred and less than,
how many?

A. Let's say less than ten thousand.

Q. Are dogs and cats in the same kind?

A. No.

Q. Are lions and tigers in the same kind?

A. Yes.

Q. If you were to take as a project, the creation
of such a list, how would you go about it?

MR. CHILDS: Why don't we say "preparation" instead
of "creation"?

MR. KLASFELD: Q. If you were going to prepare such
a list, how would you go about it?

A. You would go about it actually more or less
the same way that a classifier of organisms today tries
to determine species.

Q. Is a kind the same as a species?

A. Not identical.

Q. How is it different?

A. In most cases it is a broader category.

Q. What are the criteria for a kind that make it
broader than a species?

A. Most likely the ability to cross is --

Q. The ability to crossbreed?

A. Yes.

Q. What do you mean "most likely"?


A. That is the most usable, most concrete method
of trying to determine.

Q. Well, let me ask you this:

If I was going to do research with some animals that
crossbred and I could alter one so that it couldn't cross-
breed, would I have created a new kind?

A. No.

Q. Why not?

A. Because its ability to cross was evident to be-
gin with.

Q. But I have taken an animal that originally could
crossbreed and I have now made a new animal, some genera-
tions later, that can't crossbreed.

Is that a new kind?

A. Not a new kind, but a new species, perhaps, or
a new variation.

Q. I thought that you said that the inability to
crossbreed was the distinction between kinds?

A. That inability may be psychological, it may be
geographical, and it may be behavioral, but if you brought
the sperm and the ovum into the laboratory, they probably
would cross as they did originally.

Q. What if I brought the sperm and the ovum
into the laboratory and they didn't?

A. What if they did?

Q. My question is, what if they didn't?

A. That remains to be seen.

Q. Let me ask you this:


What information could you conceive of that would
lead you to believe that the tenet of No. 2 wasn't true?

A. It would be the evidences that evolutions have
been looking for for connections between major kinds,
missing links.

Q. Now, you are talking about major kinds, isn't
that distinguished from kinds?

A. Major kinds or basic kinds, I am using that

Q. Let me go back to the sperm and the ovum.

If I was to conduct an experiment that would satis-
fy you that the sperm and the ovum wouldn't create an
offspring, would that satisfy you that those were two
different kinds that created the sperm and ovum?

A. I am willing to go wherever the truth leads.

However, on the basis of all the rest of organisms
in the plant and animal world, I would be inclined to
think there were factors there that I was unaware of,
factors preventing the cross.

Q. I understand you wouldn't like the information,
but let's say that I could satisfy you that I conducted
the experiment in a way whose methodology was unassailable.

Would you then say that I created a new kind?

A. You have set up a hypothetical situation and it
is very difficult to answer because I would need to
really look at that carefully.

It does not agree with my concept of what can happen.

Q. Yes, but, as you said, you will follow the


truth wherever it leads.

A. Yes.

- - -


Q. I am not saying that it is going to happen or
did happen; I am saying if you were provided with this
information, would you then think that a new kind had been

A. I would have to take another look at the
classification of these particular organisms and evaluate
the situation.

Q. It strikes me that you are posing for the
evolutionist an impossible test.

You won't say what kinds are, but you want them to
find separate ones that might interbreed or the creation
from one kind of something that won't interbreed.

I want you to propose the test that would satisfy


A. The Bible is written for the common man. The
kind is not meant to be scientific.

We are doing violence to Scripture by trying to
give a scientific meaning to the word, "kind."


Q. But creation scientists use the word, "kind,"
don't they?

A. Yes.

Q. Are they using it in a scientific sense or
biblical sense?

A. They are using it in a general sense.

Q. A nonscientific sense?

A. Well, it can be used in science as long as it
is understood to be a general term.

Q. What would your scientific definition of "kind"

A. It could be all the way from a species to an

Q. But that's pretty far all the way?

A. Man is an example of species kind. Perhaps
there are examples among the insects --

Q. Is there another animal which is part of the
same kind as man?

A. No.

Q. Is there any other kind of which there is only
one example?

A. I suspect there are, but I can't tell you what
they are.

Q. How do you go about determining that the lion
and the tiger are of the same kind but the lion and the
dog are not of the same kind?

A. The breeding test is not the only basis, but it
is one of the main bases.


Q. What are the other bases?

A. Anatomy, physiology, overall experience,

Q. What about the seriology?

A. The types of tissues and blood and so on.

Q. Could two people disagree on whether or not
two animals were of the same kind or not?

A. Surely.

Q. To that extent it is arbitrary?

A. That's why it is a general term.

Q. Let me look at tenet number three, which reads:

"The great Flood described in Genesis,
commonly referred to as the Noachian
Deluge, was an historical event,
worldwide in its extent and effect."

Do you agree with that?

A. Yes, I do.

Q. When did that flood take place?

A. My personal belief is that it took place just a
few thousand years ago.

Q. How many?

A. Shall we say from five to seven thousand years

Q. Could it have been 10,000 years ago?

A. Perhaps.

Q. Could it have been 15,000 years ago?

A. Not in my thinking.


Q. What makes you think it was five to 7,000 years
ago rather than 10,000 years ago?

A. My belief as far as the time of the flood is
concerned is based largely on Scripture.

Q. What scientific evidence do you have for the
time of the flood?

A. Not much.

Q. "Not much" suggests there is some. What is

A. Oh, rates of erosion, rates of sedimentation.

Q. And that suggests to you that it is five to
7,000 years rather than 10,000 years ago?

A. Yes.

Q. What is there about the rate of erosion that
suggests that to you?

A. If they proceeded at the rate they are going
today, we wouldn't have any land above sea level in a few
million years.

Q. And the rate of sedimentation?

A. If they proceeded at the rate they are now, we
wouldn't have a Gulf of Mexico in 10 million years.

Q. Do you believe the rates of erosion and sedi-
mentation have always been constant?

A. No.

Q. How have they changed?

A. By catastrophism.

Q. Since the catastrophy they have been constant?

A. No.


Q. How have they changed?

A. By climatic fluctuations, by vegetation changes,
by -- even by man, man's influence.

Q. Why, then, do you think if they have been
changing over a substantial period of time, that the rate
of erosion and sedimentation could help you tell how long
ago something happened?

A. It doesn't really tell me that it happened five
to 7,000 years ago, but it does tell me that it doesn't
appear to have happened hundreds of hundreds of thousands
of millions of years ago.

Q. Why do you believe five to 7,000 rather than

A. Because I have confidence in the information
given in the Scripture.

Q. Let me read number 4, tenet number 4, into
the record.

"Finally, we are an organization of
Christian men of science, who
accept Jesus Christ as our Lord and
Savior. The account of the special
creation of Adam and Eve as one man
as one woman, and the subsequent
Fall into sin, is the basis for our
belief in the necessity of a savior
for all mankind. Therefore, salva-
tion can come only through accepting
Jesus Christ as our Savior."


Do you believe tenet number 4?

A. Yes, I do.

Q. So, with the exception that you mentioned in
number 1 of some minor discrepancies between accounts in
the Bible, you agree with tenets 1 through 4?

A. Yes.

Q. When did you embrace the Seventh-Day Adventist

A. I was born a member of the Seventh-Day
Adventist Church.

Q. Do you hold any office in the church?

A. Not at the present time.

Q. Have you been?

A. Yes, I have.

Q. What office did you hold?

A. An office that's referred to as an Elder in the

Q. Do you attend church regularly?

A. Yes, I do.

Q. How frequently?

A. Every week.

Q. Do you consider yourself a fundamentalist

A. I suppose, despite the rather negative connota-
tions of that, I think it would fall in that category.

Q. How would you define that?

A. One who accepts the tenets that you just read.

Q. Do you have a personal religious counselor or



A. No.

Q. Do you engage in activities to spread the faith?

A. Yes.

Q. Do you have an evangelical mission as part of
your membership of the church?

A. Can you explain a little more what you mean?

Q. Well, what do you do to spread the faith?

A. I speak to people when I have the opportunity,
I write for church papers which are used for evangelistic
purposes; I speak in churches; I speak in evangelistic
services, so forth.

Q. Have you been baptized?

A. Yes.

Q. How many times?

A. Once.

Q. Is that when you were a child?

A. Yes.

[Discussion off the record]

MR. KLASFELD: Q. Do you believe that it is okay
to exaggerate in order to spread the faith?

A. Absolutely not.

Q. And you wouldn't distort anything to spread the

A. Not knowingly.

MR. KLASFELD: Why don't we take a break and pick up

[Luncheon recess]



1:15 O'CLOCK P.M.

- - -


MR. KLASFELD: Q. Dr. Coffin, when you read the
Bible, is there any particular version that you read?

A. No.

Q. How often do you read the Bible?

A. I read it almost every morning.

Q. Do you set aside some time for that?

A. Yes, I do.

Q. How long?

A. My aim, and I usually reach it, is a half-hour
in the morning.

MR. CAMPBELL: Just for the record, I will object
to these questions as being irrelevant to the particular
issues in this lawsuit.

MR. KLASFELD: My understanding is that the judge
has been heard on that. I don't want to characterize
what he said because I wasn't there, but I am told that
that discussion was had with the judge and the judge
authorized us to ask these questions.

MR. CAMPBELL: You can talk about his religious
views, is my understanding of what the judge said, but
he diver did take up Bible reading and things like that.

That is all I am saying, that this may be
irrelevant, but he can answer the question.

MR. KLASFELD: How do you decide which section you


are going to read each morning?

A. Oh, I simply choose some part of the Bible
which, for various reasons, might be of interest to me
at the time.

Q. As a paleontologist, do you consult the Bible
for the purposes of your scientific inquiry?

A. Not directly.

Q. Indirectly?

A. Well, my research on flotation, for instance,
probably would never have arisen if I didn't have
confidence in the flood story in Genesis.

Q. So in conducting that research, did you
consult the flood story in the Bible?

A. No.

Q. For what purpose in relation to your
scientific work do you consult the Bible?

A. To one who has confidence in its authenticity,
he would consult it for the same reason he would consult
any other authority which he feels to be reliable.

Q. Is the Bible a source of personal revelation
to you?

A. Personal revelation, can you explain that?

Q. Well, I am not sure that I can.

Does it provide for you a personal code of

A. Yes.

Q. What is that code of conduct?

A. "Thou shalt love the Lord thy God with all


thy heart, and thy fellow likewise," paraphrasing.

Q. Do you believe that the Bible is, except for
minor, minor discrepancies, literally true?

A. Yes, except where it is obviously symbolic.

Q. In what respects is it obviously symbolic?

A. Well, where there are words or messages that
are clearly symbolic.

Q. Which ones are they?

A. Well, the beasts in Revelation, the parables
of Jesus and so forth.

Q. What about the Genesis part of the Bible?

A. I accept Genesis as being accurate history.

Q. And literally true?

A. Yes.

Q. Does the Bible predict future events?

A. I believe it does.

Q. What future events does it predict?

A. The end of earth history, the second coming
of Christ.

Q. The rapture?

A. To some people.

Q. Not to you?

A. No.

Q. Does the Bible predict for you when the end
of earth history is going to take place?

A. No.

Q. Or when the second coming of Christ is going
to be?


A. No.

Q. Is the Bible an inspiration for your research
in any way?

A. No, I don't think so.

Q. Is it, in its literal truth, a source of
scientific learning for you?

A. No.

Q. Is it a source of scientific truth which sets
forth parameters for your research, your work?

A. To some extent, yes.

Q. To what extent would that be?

A. It provides basic concepts and basic
understandings that will influence a person's research.

Q. What basic concepts and understandings would
those be?

A. Of course, we are talking about creation and

Q. By which you mean the creation of the world
and the universe in six days and the Noachian flood?

A. Yes.

Q. Does the Bible suggest methods of scientific
investigation to you?

A. No.

Q. What information would you think of that
would lead you to conclude as a scientific matter that
the earth was millions of years old?

A. What information can I think of that would
lead me to think that the earth was millions of years



Q. Yes.

A. Radioactive dating.

Q. I'm sorry.

That would lead you to believe that the earth was
millions of years old?

A. That could lead me to believe that.

Q. Well, you believe -- I will start at the

I understand you to believe that -- I will start
from scratch.

When do you believe the events of Genesis, as
described in the Bible, took place, how long ago?

A. A few thousand years ago.

Q. That would be, presumably, before the flood?

A. Yes.

Q. How long before the flood?

- - -


A. Let's say up to ten thousand years before, before

MR. KLASFELD: Excuse me.

[Discussion off the record]

MR. KLASFELD: Back on the record.

Q. In connection with this case, Dr. Coffin,
have you had any contacts with people other than the
Arkansas Attorney General's Office and Dr. Roth?

A. It was discussed in the Geoscience staff

Q. Who was there at that time?

A. The individuals were two secretaries and two
other members of the Geoscience staff.

Q. What was discussed?

A. Just simply should we or shouldn't we.

Q. And you reached the decision that you should?

A. We decided we would go ahead with it.

Q. What were the considerations against doing it?

A. Whether we could be useful or whether we wanted
to be identified with some others that might be involved
in it.

Q. Who were those others?

A. I'm thinking particularly of ICR.

Q. The Institute for Creation Research?

A. Yes.

Q. Who were the major members of that group?

A. No individuals were referred to specifically.

Q. But who are they?


A. I don't know all of their membership.

Some of them, of course, are Duane Gish, Henry
Morris, Gary Parker and -- what is his first name? -- well,
Bliss; and there are some others.

I don't really remember who all is there now.

Q. And you discussed the negative effect of your
becoming associated with them?

A. Well, as I indicated, there are certain aspects
of creationism which we don't quite agree with them on,
so we weren't sure we wanted to be lumped in with that

Q. You ultimately decided you would?

A. Yes.

Q. Did you have any discussions with the people
at ICR about your testimony?

A. No.

Q. Did they attempt to get into contact with you?

A. No.

Q. Have you had any contact, first of all, ever,
with Wendell Bird or John Whitehead?

A. No.

Q. Have you ever testified in any kind of court
proceeding before?

A. I'm not sure of your legal terminology.

I was involved personally in a lawsuit involving
an accident in which my wife's back was broken, an
automobile accident.

Q. I see.


But not regarding your scientific expertise?

A. No.

Q. Have you engaged in any debates on creation
science versus evolution?

A. No.

Q. No public debates?

A. No.

Q. What about any debates involving evolution in
any way?

A. Define what you mean by "debate."

Q. I guess I would mean a public kind of debate,
where you are speaking for one side and somebody else
is speaking for another side.

A. I have been involved in public discussions on
creation evolution but not what you would call a debate.

Q. Where did those discussions take place?

A. One of them occurred in San Francisco.

Q. Who set up the discussion?

A. It was -- I don't remember the call numbers
but --

MR. KLASFELD: Excuse me.

[Discussion off the record]

MR. KLASFELD: Back on the record.

I am sorry.

I apologize for the interruption.

THE WITNESS: It was a local educational TV station,
and they had a discussion on -- it was when the teaching
of creation in public schools in California was strongly


being considered.

MR. KLASFELD: Q. Who else participated in those

A. I don't remember the names but one was an
official in the high school system of San Francisco and
another was a science teacher from the University of

Q. Do you know if there are any transcripts of
that television program?

A. A videotape was made of it.

Whether that is still available, I don't know.

Q. Do you have a copy of it?

A. I don't have a copy.

Q. About when did this take place, do you know
the dates?

A. Well, I would say 1965 or '66, somewhere in

Q. What station was that on?

A. I don't remember the call letters.

It's a local educational TV station.

Q. Thank you.

Since then, have you engaged in any other public
debate or discussion about the issue?

A. No.

MR. CHILDS: Excuse me, David.

[Discussion off the record]

MR. KLASFELD: Back on the record.

THE REPORTER: The best known local public tele-


vision station in this area is KQED.

THE WITNESS: I think that was the one.

MR. KLASFELD: Q. All right.

Were you paid for your appearance on KQED?

A. No.

Q. Are you being paid for your testimony at this

A. No.

Well, just for expenses.

Q. Have you ever been arrested for any criminal

A. No.

That doesn't include minor automobile accidents,
I presume.

Arrested, no.

I just received a citation.

Q. For speeding?

A. No.

For failing to yield the right of way.

Q. Did you do it?

A. Well, I hit the side of the car so I didn't
really have much of an excuse.

Q. But other than that, no arrests or convictions?

A. No.

Q. Have you discussed with anyone the specifics
of what you expect to testify to at trial?

A. With Dr. Olson, I have talked about it with


Q. How many times have you talked about it?

A. Almost none before we came up here, but we
are, of course, just a couple rooms apart, and at break-
fast time or other meal times we have talked about it.

Q. How many other members are there at the Geo-
science Research Institute?

A. There are four, plus two secretaries.

Q. Who are the other two scientists?

A. The other two, their names are Richard Tkachuck,
T-k-a-c-h-u-c-k, and Robert Brown.

Q. What is Dr. Tkachuck's area of expertise?

A. His area is in speciation and variation,
evolution, if you please.

Q. And Brown?

A. He is a nuclear physicist.

Q. Is there any particular reason why they are not
testifying at the trial, that you know of?

A. That is something I have no information on.

Q. What have you discussed with Dr. Roth about
your testimony at trial?

A. Almost nothing about the testimony.

Q. What did you talk about?

A. About what to expect; in other words, what it
is going to be like.

Q. Just to be a witness?

A. Yes.

Q. While we are on this subject, what would you
describe as Dr. Roth's area of expertise?


A. His area of expertise would be catastrophism
and philosophy of science.

Q. Does he have any other areas of expertise?

A. I think that I had better not say, really,
any more.

Q. Is he an expert on coral reefs?

- - -


A. Yes.

Q. Is your testimony going to be based on any of
the documents you have brought this morning?

A. Yes.

Q. Which of those?

A. I can't answer that. I haven't prepared it

MR. KLASFELD: Mr. Campbell, I guess that answer is
indicative of the problem we are faced with in terms of
our efforts to seek discovery about Dr. Coffin and his
testimony. It's difficult to explore his areas of
testimony if he hasn't thought about it himself, and in
the area of fossils and paleontology is a very broad area.

MR. CAMPBELL: I think what it reflects is that he
has told you that his testimony will come from the
documents which he has provided you, and certainly, you
could ask him about those documents.

I think, too, and more basically, that what it
reflects is that we have simply not had the time to prepare
our witnesses as we would like to have prepared them for
trial; we might not find that same problem with your
witnesses, but this is actually a reflection of the number
of attorneys that you have available to prepare your
witnesses, while on our side, there has been only the two
of us, or three of us now, working on the case.

MR. KLASFELD: But that really doesn't go to the
merits of what it is we are entitled to be able to do
in a discovery deposition.


We are supposed to be given the opportunity to
examine and to discuss with a potential witness what his
testimony is going to be, what he expects to rely on in
that regard, in an effort to probe that testimony.

And it's clear to me it's not that Dr. Coffin is
unwilling to discuss anything, and I certainly don't want
to suggest that, but simply the fact that, you know, the
interrogatories weren't answered and I gather from
discussions with our people that you feel that the
information that was given to us in the witness list and
the --

MR. CAMPBELL: And the information which the witnesses
can provide you at these depositions.

MR. KLASFELD: -- and the information which the
witnesses can provide us at these depositions, should be

My objection is that the area of paleontology and
fossils is a very wide area.

For instance, I read an article by Dr. Coffin on
spirorbis, and I am prepared to discuss the article on
spirorbis with him, but I think I am entitled to know
whether he expects to testify as to spirorbis at the time
of trial.

MR. CAMPBELL: You didn't ask that.

I think in a discovery deposition you should ask him
about all of these areas you know of or about. I think
you mentioned this morning you have already read some of
his articles in Origins Magazine.


MR. KLASFELD: That's right.

MR. CAMPBELL: So you might ask him whether or not
he would rely upon those.

MR. KLASFELD: I want to and I will.

Part of what we are entitled to do, in my mind, at
these discovery depositions, is to limit the area about
which the witness is going to testify; and while I have
read three or four or more of Dr. Coffin's articles, and
if I had all of this information, I would have read the
others as well, it seems to me that it's going to be
impossible to serve the other legitimate purpose of a
deposition, which is to limit what it is that somebody is
going to say and rely upon.

MR. CAMPBELL; I understand what you are saying.
I guess my only response would be that the witness should
not be penalized because of his lawyers, in this instance
the Arkansas Attorney General's office, for being unable
to adequately prepare his testimony in advance of this

We have undoubtedly an expedited trial date in this
case, and as Dr. Coffin has testified, we just recently got
in contact with him. I think we have done remarkably well
in getting all of these depositions lined up and getting
them all done before the trial date.

MR. KLASFELD: I think it's true that the witness
shouldn't be penalized, but neither should the other side.

MR. CAMPBELL: But you have him here today. That
is the thing.


MR. KLASFELD: That is true. But what I am able to
accomplish at this deposition is greatly limited from what
it would be in the ordinary case.

MR. CAMPBELL: I guess I just don't understand the
purpose of a discovery deposition the way you are viewing
it, because as I would interpret it, as I view a
discovery deposition, it's a time where you sit around and
you start with a very broad area and continually try to
break it down, you continually try to narrow it down.

Obviously, Dr. Coffin can only testify at trial about
what he knows about, whatever that is, so it seems to me
that the purpose of the discovery deposition would be for
you to determine what it is he knows, because he is not
going to testify to anything else but that.

MR. KLASFELD: I understand that.

Q. Do you anticipate testifying about spirorbis
at the trial?

A. Well, once again, that is a difficult question
because I just really haven't put together this information
and I am not sure that I would have put it together even if
I had known three months ago.

Q. Would you anticipate testifying about the
Burgess shale formation?

A. That is a possibility.

Q. Or the ginkgo petrified forest?

A. I doubt it. I don't know.

Q. But what about the work you have done in the
Yellowstone area?


A. Perhaps.

Q. And the work on the horsetails?

A. Possibly.

MR. KLASFELD: Mr. Campbell, I think I'm entitled
to more than that or better than that or something different
than that.

MR. CAMPBELL: I guess the only thing I'm saying is
that, where he has given you indication he may be
testifying about that, you should inquire into what it is
about that that leads him to have these opinions which he
may have on this.

MR. KLASFELD: I will do that. But I want to
continue to state that, in my own view, that is not

MR CHILDS: I think the problem is that the
procedure in Rule 26 on experts has not been followed,
which says that first the written statements would be
filed with the court and then, after a motion to the court
and for good cause shown, the court would then order the
deposition to be taken. And the situation you are in is a
result of not following the right procedure. You got the
procedure screwed up.

I think counsel for both sides contributed to that.
We are going to be at the same disadvantage with your
witnesses that you are with ours.

MR. KLASFELD: Let me mark for the record, as
Plaintiffs' Exhibit No. 4, an article from Volume II of
the magazine "Origins," entitled, "The Spirorbis Problem,"


written by Dr. Coffin.

[Article entitled "The Spiroribis
Problem" marked for identification
Plaintiffs' Exhibit No. 4.]

MR. KLASFELD: Q. Look at Plaintiffs' Exhibit 4,
Dr. Coffin, and tell me if that is an article that you
wrote for Origins Magazine.

A. Yes, it is.

Q. This article makes reference to some work you
did in coal areas of Nova Scotia; is that correct?

A. Yes.

Q. Where in Nova Scotia were these coal mines?


















A. Joggins, Nova Scotia, J-o-g-g-i-n-s, and North
Sydney, Nova Scotia.

Q. How did you happen to go there?

A. Because that is known in the geological litera-
ture as an interesting area for coal exposures.

Q. Had you been working on spirorbis prior to

A. Not in the field.

Q. In the lab?

A. In literature research.

Q. Why did you focus on spirorbis?

A. Because it is a significant fossil element of

Q. Of coal?

A. Yes.

Q. Directing your attention to the third paragraph,
the second sentence says,

"In the coal measures of Nova Scotia,
I have observed spirorbis fastened
to the outside edges of mussels."

A. I don't follow where you are reading.

Q. Paragraph 3.

A. 3?

Q. The second sentence.

A. Oh, yes, I'm sorry. Go ahead.

Q. Could you define for me coal measures?

A. That is a term that means the sediments in
which coal seams are located, including the coal seams,


the whole system.

Q. But it's not limited to just the coal?

A. Not limited to the coal, that is right.

Q. Do you know the genus of the mussel that you
described here?

A. Modialus, is it? It's probably in here. I
believe it's modialus.

Q. Could it have been mytilus?

A. Well, that is the modern genus.

Q. Could it have been promytilus?

A. I don't think so.

Q. Do you think it's modialus?

A. Yes.

Q. Could you spell that, please?

A. M-o-d-i-a-l-u-s.

Q. Is modialus extinct?

A. Probably.

Q. Could you tell me the difference between
modialus and promytilus?

A. The reason I hesitate on the extinction question
is that there isn't a great deal of difference and it's
sometimes hard to say whether it is or isn't.

Q. How would you distinguish modialus from

A. Well, I'm not familiar with the genus pro-
mytilus, but I am familiar with the genus mytilus.

Q. But you are certain the mussel to which the
spirorbis was attached was modialus and not mytilus?


A. I am going by the indications in the previous
genealogical literature.

Q. There is genealogical literatures which identi-
fies the mussel?

A. Oh, a great deal.

Q. What is the source of that literature, and I'm
speaking of literature that identifies particularly the

A. Dawson.

Q. D-a-w-s-o-n?

A. Yes. I think it's -- I'm trying to think of the
initials or the first name.

But he was a very well-known Canadian geologist. I
think his first name was William.

Q. But you yourself couldn't distinguish a pro-
mytilus from a modialus?

A. I could if I studied the characteristics ahead
of time. I couldn't right now.

Q. They are both invertebrate fossils, though.

A. Yes.

Q. Your third paragraph goes on to say, and I will
skip slightly:

"The worm is distributed throughout
the geological record, and on the
basis of the standard geological
time scale, spirorbis had been in
existence for nearly 500 million

Transcript continued on next page

Deposition of Harold G. Coffin - Page 3


Does the article say that?

A. Yes.

Q. Do you believe it has been in existence for
less than 500 million years?

A. My personal belief is that. As far as scienti-
fic evidence is concerned, there wouldn't be any direct
evidence on it.

Q. And there is no direct evidence that it's less
than 500 million years?

A. That is right.

Q. Now, if I can, I'm going to try to characterize
what I understand to be the point of your article, and
please correct me if I am wrong.

The point of the article is that spirorbis was a
salt water animal; that coal was believed to be formed in
a fresh water situation; and the fact that the spirorbis
is found mixed in among the coal creates the enigma of
how, if the coal was formed in fresh water, a sea water
animal could be among the coal.

Is that correct?

A. That is correct.

Q. How do you understand coal to be formed?

A. Coal is the accumulation of vegetable matter
and its burial.

Q. How long does that take?

A. It depends upon conditions.

Q. What conditions?

A. The depth of burial, the temperatures involved,


bacterial decay.

Q. What is the standard notion among experts on
the formation of coal about how long that takes place, how
long it takes for that to take place?

A. In the geological literature there is very
little information on actually how long the coalification
or petrification process takes.

Q. There is disagreement, I understand that, but
is there sort of a low range as to how little time that
might be?

A. Really, in my reading, I have very seldom run
across any information along this line.

Q. Does anybody feel it could take place in 5,000

A. Yes.

Q. Who?

A. Some museum curators.

Q. Who is that?

A. In the coal museum in Bochum, Germany, they
have a post taken out of an old coal mine that is coali-

Q. Where is that?

A. In Bochum, Germany.

Q. B-o-k-u-m?

A. B-o-c-h-u-m.

Q. And you say they have a post that had been in
a coal mine?

A. Yes.


Q. And that had turned into coal?

A. Yes.

Q. And the curator of that museum is who?

A. I don't know who he is.

Q. But he is the person who thinks it could take
less than 5,000 years?

A. I'm just assuming that, since they have got it
on display in the museum.

Q. I see.

But you have never spoken to him about it?

A. No.

Q. Have you been to the museum?

A. Yes.

- - -


A. Yes.

Q. Can you explain how the standard people who
study in this area, and I'm using the term, "standard,"
the way I think you are trying to use it in your article,
tell me what you understand the explanation to be for how
the spirorbis appears in the coal?

A. Their explanation is that, during the carboni-
ferous period, the spirorbis was a fresh water animal.

Q. Have you ever heard the argument that changes
in the sea water or changes in the sea level in low-lying
areas allowed sea water to wash over what had previously
been fresh water areas and thereby bring in the spirorbis?

A. Yes, I have heard that.

Q. Do you know of any scientific evidence to lead
you to believe that is not true?

A. Yes.

Q. What is that?

A. A marsh is a very specific environment, and to
have peat bogs, which is more specific yet, developing
one above another repeatedly, is extremely unlikely.

Q. Why is it unlikely?

A. Because the conditions for the development of a
peat bog are so rigid.

Q. Have you done any experiments which lead you
to conclude that it's unlikely?

A. I have done a lot of reading on the subject.

Q. Could you state for me the authorities that
agree with you that it's unlikely?


A. Those who work with limnology, which is the
study of fresh water.

Q. Specifically whom?

A. This is getting a little bit out of my area of
expertise. I'm not a limnologist, I can't really tell you
offhand who the experts are in the field.

In the study on the Nova Scotia materials, this, of
course, was handled by Dawson, whom I already mentioned.

Q. Does Dawson say in his work that it's impossible
to have stratified peat bogs turning into coal?

A. No, he doesn't say that.

Q. Well, that is what we are talking about now.

Who are the authorities that lead you to your con-
clusion in a field outside of your area of expertise, that
this couldn't happen?

A. Well, in research one often has to call upon
other areas of expertise, so it's difficult for me to
remember names of experts in the area of limnology, which
is not paleontology.

Q. But it is true that there are experts in those

A. Yes.

Q. Experts who agree with you that it's impossible.

A. No. Just a minute now.

Experts who agree that the requirements for the
production of a peat bog are very rigid.


Q. Okay.

But it's another step to go from there, isn't it,
to say that it's virtually impossible that a fresh water
peat bog could exist and salt water could, due to a change
in sea level, come into that area, and that the sea level
could recede so that it could become a fresh water bog

A. That is a possibility, but I don't think that
is what happened in this case.

Q. Why?

A. For the reason that I have just stated, the
unlikelihood of the same environments developing repeatedly
one above the other in the same place.

Q. To say that something is unlikely strikes me as
sort of an unscientific basis for believe it to be so or
hot so.

I mean, is there any other support that you have for
your notion that it's unlikely?

A. That is merely a common expression for

Q. On what do you base the probability?

A. That is difficult to answer briefly, because
there is so much involved.

I have never seen a situation where an advancing sea
leaves intact the environment over which it is advancing.

Q. Let me ask you this. Is the Illinois Basin,
is there a series of 40 to 50 coal seams, one on top of
the other?


A. Yes, there are.

Q. How did that happen?

A. I think the most reasonable explanation is a
drift model.

Q. What is a drift model?

A. It's that these plants have been transported
into the position where they now lie.

Q. By what?

A. By water.

Q. How do you get this layering of 40 to 50 layers
of coal, how did that happen?

A. By a change in currents that would bring in a
deposit of drifting plant material and then sediments
coming in over them from another direction by tidal

Q. Did this happen during the flood?

A. I would consider it to be a product of the
catastrophy that occurred during the flood.

Q. How does it happen then, in areas in Indiana
and adjacent areas in Illinois, there are some areas of
40 levels of coal and other areas where there are 30
levels of coal, and in other areas 10, and in others two?

A. Just like there are different heights of tides,
even different cycles of tides in different areas today.

Q. Perhaps you can explain for me specifically
how you believe these 40 to 50 layers were formed.

Did the coal come from the peat bogs?

A. Some did.


Q. But not all?

A. No.

Q. Where did the others come from?

A. Vegetation of various sorts.

Q. So somehow the vegetation was swept in, covered
with something else, and some more vegetation was swept in
and covered with something else, and more vegetation was
swept in and then it was covered with something else.

How long did that take place? How long did it take
for that to happen?

A. I don't know.

Q. Well, was it 3,000 years or was it two weeks?

A. I really don't know, but it would be closer to
the two weeks than the 3,000 years.

Q. And did the coal form in the two weeks?

A. No.

Q. The coal was formed since then?

A. Yes.

Q. Are you familiar with the Everglades as a model
of coal formation?

A. Yes, I am.

Q. Through what information are you aware of it?

A. Well, I have been there and, obviously, any-
body who has studied the coal literature would be aware of

Q. Is there fresh water floating on top of the
salt water in the Everglades?

A. Yes. Well, on top of the salt water?


Q. Yes.

A. Well, sometimes.

Q. It forms a lens on the top, is that what it's

A. Yes.

Q. And if the fresh water rivers that flow into
the Everglades would shut off for some reason, would for
some reason become blocked or would dry up, would that
turn into a marine environment?

A. No, it would turn it into a fresh water environ-

Q. Do the rivers coming in bring in salt water?

A. Rivers don't bring salt water.

Q. Well, then that is what I said.

If the rivers were for some reason shut off from
coming into this marsh area, would that then turn into a
completely salt water environment?

A. No.

Q. Why not?

A. Because the rivers are bringing in fresh water.

Q. Well, I said if, for some reason, the rivers
were diverted or dried up or were shut off, would that
then create a salt water environment?

A. You mean, if they are shut off from reaching
that area?

Q. Yes.

A. Possibly, yes. It depends on the elevation of
the land.


Q. Well, the Everglades are approximately sea
level, all of them are, and a very minor fluctuation in
the sea level would cover certain areas with sea water
that previously had been fresh water, and vice versa as

A. Yes.

Q. Why could that not be an explanation for the
appearance of spirorbis in the coal of Nova Scotia?

A. It could. It's another model.

Q. I see.

What is the scientific support for your model?

A. I have mentioned the repeated nature of the
coal seams as speaking against their being this growth;
the presence of marine organisms; the absence of erosion,
and the -- well, this would be similar, the extensive
flat-line nature of the coal beds.

Q. In your use of the term, "coal measure," which
you said was a thickness, including the coal seam and
areas above and below, were the spirorbis in the measure
or were they mixed in among the coal?

A. Both.

Q. Is there any explanation for it getting into
the coal -- strike that.

Is there any literature which describes its appear-
ance in the coal as opposed to in the coal measure?

A. Yes.

Q. Where is that?

A. I can get the reference for you, but I am not


sure I can give it to you off of the top of my head.

MR. KLASFELD: Will you do that?


Could we go off the record for a moment?


[Discussion off the record]

MR. KLASFELD: Back on the record.

Q. Do the standard scientists -- excuse me.

Do you object to me using that term?

A. No.

Q. I use it because I seem to have picked it up
from your use of it in your article.

Do the standard scientists have an explanation for
how the spirorbis comes to occur directly in the coal
seam, other than the washing in and out of sea water and
the possible change from being a fresh water animal?

A. Well, that is the main -- most of the literature
would suggest it was a change from a marine animal to a
fresh water animal.

Q. Which literature would that be?

A. The literature on spirorbis and on the appear-
ance of spirorbis in the coal measures.

Q. By whom?

- - -


A. Oh, by Francis, by Stewart, by Arnold, by

Q. And they all posit a change from freshwater
to saltwater for the fish or the spirorbis?

A. Some of them do, I am sure.

Q. Are there any authorities who support your
position for the appearance of these spirorbis in the
coal seem?

A. Yes.

Q. Whom?

A. Fayol, F-a-y-o-l, and Francis, Austin.

Q. A-u-s-t-i-n?

A. A-u-s-t-i-n, yes.

Q. All right.

In what sense were they in agreement with you?

A. That coal is allochthonous, drifted.

Q. Are they in agreement with you that the ap-
pearance of the spirorbis in the coal seam is support
for the flood theory.

A. Catastrophy?

Q. Yes.

A. Yes.

Q. Well, do you believe that it was one large,
worldwide catastrophy that had occurred within the last
ten thousand years?

A. I can't really answer that because they didn't
go into a discussion on that point.

Q. Well, what did they mean when they said



A. That this is in a catastrophic origin for

Q. What did they mean when they said

A. Just that: Brought in by the storm or by
transportation rather than growth in position.

Q. But that could have been --

I mean, would they agree or disagree that it could
have been something that happened hundreds of thousands
of millions of years ago?

A. I think most of them would feel that it prob-
ably happened millions of years ago.

Q. Is there anyone who agrees with you that it
happened five to seven thousand years ago, anyone who
studied this problem?

A. Yes.

Q. Whom?

A. Austin, and perhaps Francis.

Q. Where is Mr. Austin.

A. He is on the staff at ICR.

Q. And Mr. Francis?

A. He is a British paleontologist or coal geologist.

Q. Where is he?

A. I don't know his location.

Q. Is he affiliated with a Creation Science

A. No.


Q. What is the scientific evidence for the fact
that this happened five to seven thousand years ago?

A. Well, we come back to what I mentioned earlier,
and that is rates of erosion and deposition and so forth.

Q. Rates of erosion in the area around Nova Scotia?

A. No.

In general, on the earth in general.

Q. Did you study the area in Nova Scotia at all?

A. Certainly.

Q. How did the rates of erosion in Nova Scotia
affect your thinking?

A. It's very rapid there.

Q. And it's your belief that rapid rate has been
uniform over a time?

A. No.

Q. Why do you then conclude that, because it's
rapid now, something had to take place five to seven
thousand years ago?

A. I have to distinguish between the fact that,
although I feel or I believe that this happened a relative-
ly short time ago, there are many scientific evidences
of a longer period of time; but there are also strong
evidences that it is not hundreds of thousands or millions
of years.

Q. What are those evidences?

A. I already mentioned that, if we take the
average rates of erosion, which you can select out of the,
quote, standard, end quote, literature," there wouldn't


be any continents present at the present time if those
rates of erosion had continued over hundreds of thousands
or millions of years.

Q. But there are two parts to that:

One part is that you have to assume that they have
continued at that same rate for all of that period of
time; is that right?

A. If you assume that --

Q. Well, that is what you do in order to conclude it
has to be less than seven thousand years?

A. Yes.

You assume that, in a few million years, the rate of
erosion would have worn it down to sea level.

Q. What is the basis for that?

A. The average erosion given in the literature.

Q. Over the last how many years?

A. Over the last twenty years.

Q. So what you have done is taken the last twenty
years and extrapolated that over millions of years and
come to the conclusion that, if it had gone on at that
rate, the continent would have been worn away?

A. No.

You are misunderstanding me now.

Q. Okay.

A. I thought you meant what geological literature
over what period of time I obtained this information from.

It would be recent.

Q. Literature?


A. In other words, recent literature.

In other words, their extrapolations are variable,
depending on what areas they are looking at and over how
long a period of time they worked it out.

Q. I understand what you are saying.

Or I understand what I understand.

I understand you have taken the information as to
the rates of erosion for the last twenty years and you
have said, if that average rate --

You are shaking your head, "No."

What have you done with it?

A. Forget the twenty years.

Q. Okay.

A. If you take the average rates of erosion that
one finds listed in the geological literature, a figure
which is considered to have been consistent throughout
geologic time, it would have brought about the erosion of
continents to sea level by now if the earth were millions
of years old.

Q. How did the standard scientists deal with that
information; I mean, are they stupid?

A. That is a good question.

They don't handle it.

Q. You mean they just ignore it?

A. You very seldom see any discussion of it.

I don't think they are aware of it.

Q. Is that possible?

A. They may feel there has been subsequent uplift.


Q. Do you believe that the earth was made, with
all of the mountains that are now in place, in place
from the beginning?

A. No.

Q. When did the other mountains come into being?

A. During the Genesis flood.

Q. And since then there has been no change?

A. No.

Or, yes, there has been change.

Q. That change has only been erosion, though?

A. No.

Q. I am sorry.

Has there been subsequent uplift after the Genesis

A. To some extent.

Q. Where?

A. The Himalayan mountains are rising several feet
every year, I guess, still.

Q. What causes that?

A. And then there are volcanic eruptions that
cause --

Q. What causes the Himalayan uplift?

A. The current beliefs are the colliding of con-
tinents, like India, for instance, against Asia.

Q. Is that a standard belief as distinguished
from your own belief?

A. Well, I would go along, at least with qualifi-
cation, with the idea of continental drift.


Q. So even in your own belief about this, that
erosion isn't the only effect; I mean, there is also
uplift as well?

A. Yes.

Q. Does your calculation about the evening out of
all of the continents take into account the uplifts
that have taken place as well?

A. Yes.

Q. And do you still come out with less than five
thousand years?

A. No.

Just a minute.

Q. I'm sorry.

A. I come out with the fact that the earth would
be --

MR. CHILDS: That it would be under water.

THE WITNESS: -- that the earth would be down to
sea level in a few millions of years.

MR. KLASFELD: Q. In a few millions of years?

A. Yes.

Q. How about a hundred thousand years?

A. No, not that quick.

- - -


Q. So it could be 100,000 years old?

A. Yes, on the basis of that information.

Q. I see. What is the information that leads you
to believe that it's five to 7,000 years old?

A. The sedimentation we see in some areas.

Q. What sedimentation, what areas?

A. Like river deltas.

Q. Like the Mississippi Delta?

A. Yes.

Q. What is there about the Mississippi Delta?

A. At the present rate of deposition, it's only
four to 6,000 years old.

Q. Why do you believe that the Mississippi Delta
started forming the day the earth was formed?

A. I don't. I have extrapolated backwards. I
haven't gone from that forwards.

Q. Well, what you have said is that the
Mississippi Delta has been forming for four to 6,000
years; is that correct?

A. Right.

Q. Why does that provide us with any information?

For instance, I have only been going for thirty-five
years. Why does that provide us with any information about
the age of the earth?

A. Well, the word "earth" is pretty broad. We
are talking about the surface of the earth here.

Q. Why does that provide us with any information
about the surface of the earth?


A. Where was the Mississippi River during all of
the rest of geologic time?

Q. Well, one of the things about these depositions
is the lawyer asks the questions and the witness gives
the answers.

A. Well, that is what I am thinking, you are.

Q. But there are examples on the earth's surface,
are there not, now, of rivers forming, rivers drying up,
are there not?

A. Yes.

Q. So that rivers that presently exist were not
always in place the way they are now; is that correct?

A. Yes.

Q. Why couldn't the Mississippi simply have come
into being 4,000 years ago?

A. As long as there was a continent here, there
has to be drain-off of water.

Q. But why did it have to take place where the
Mississippi is?

A. Well, if it's some other river, then there
should be evidences of those deposits.

MR. KLASFELD: Let me mark, as Plaintiffs' Exhibit
5 for identification, an article from Volume I of
Origins Magazine called "Famous Fossils From a Mountain-
top," also written by Dr. Coffin, which is, I think, a
transcript of a talk that Dr. Coffin gave.

[Document more particularly
described in index marked for


identification as Plaintiffs'
Exhibit No. 5.]

MR. KLASFELD: Q. Did you write this article, Dr.

A. Yes, I did.

Q. If I can summarize the point that I understand
you to be making in this article, it's that this
Burgess shale formation contains certain extremely well-
preserved fossils that are just as intricate as the worms
and crabs that are existing today; is that the point of
the article?

A. Yes.

Q. And the argument that you are making is that
evolution has to be wrong if those fossils are supposed
to be so terribly old, yet there are organisms on earth
which are exactly the same as those fossils now?

A. Not quite.

Q. Where did I slip up?

A. Or similar.

Q. Similar. I see.

A. Yes.

Q. Well, your article says --

Let's see the point where I have made my error and
perhaps you can explain it.

On page 47, paragraph 3, the third sentence, you
say: "In fact they are just as intricate as the worms,
crabs, et cetera, in the ocean today."

A. That is correct.


Q. So they are not just similar?

A. But they are not identical.

Q. They are not identical?

A. No.

Q. But they are just as intricate?

A. Yes.

Q. Did you compare the different kinds of limbs
in the fossils with the similar animals that are alive

A. Limbs?

Q. Yes.

A. The ambulatory limbs?

Q. The limbs for food manipulation and motion.

A. Yes.

Q. How would you compare the fossils with the
animals which are alive today?

A. They are extremely complex and they are
typically crustaceans.

Q. Are the animals that are alive today, do they
have different kinds of limbs with more differentiated

A. Then those in the fossil record?

Q. Yes.

A. I would say no.

Q. You would say that, for all purposes, they are
the same?

A. Yes, in the same basic categories. They are
not the same species.


Q. I am sorry. I missed the point about their
not being the same species.

A. We cannot identify them as being the same
species living today, but they are crustaceans. In other
words, they can be categorized in a larger taxonomic

Q. So they are sufficiently different that they
are not in the same species?

A. That is right.

Q. But at the same time, they are sufficiently
similar to lead you to believe that a substantial problem
has been created for the evolutionists by their

A. Yes.

Q. Why is that a problem if they are not even
in the same species?

A. Because we are not dealing with speciation,
we are dealing with macroevolution. The problem is
macroevolution or major change.

Q. Why is that a problem for evolutionists?

A. Because they can't find the ancestor leading
up to these complex animals.

Q. Are there pre-Cambrian fossils?

A. Some.

Q. What are they?

A. It depends on what authority you read.

Q. The authorities that you rely on.

A. Pardon me?


Q. The authorities that you rely on.

A. As to micro-organisms like fungi and algae and
protozoa, there have been frequent reports in the
literature of brachiopods and --

Q. Do you believe this literature?

A. I have not gone into the sites to check it out
but I have no particular reason to doubt it.

Q. There had been, correct me if I am wrong,
until recently, a significant Creation Science argument
that there was a lack of fossils in the pre-Cambrian
rock and that that was a significant problem for
evolutionists; is that correct? A. Yes.

Q. But recently, through newly devised techniques,
these pre-Cambrian fossils have been discovered?

A. A few.















Q. So that earlier creation science argument is
no longer valid as a scientifically factual matter?

A. No.

Q. Well, the argument was, wasn't it, that there
are in fact none in the pre-Cambrian run; is that right?

A. There may have been some who said none.

Q. But you aren't one of them?

A. No.

Q. Who were they?

A. I don't remember.

Q. Have you always believed Creation Science
as a theory?

A. Yes.

Q. Let me ask you about the worms and the fossils:

Has the variety of worms now living increased from
the number of varieties that are found in the fossils?

A. Yes.

That has to be qualified.

Q. Okay.

A. Worms do no fossilize well.

Therefore, their preservation in the record is less

Q. But in any event, there is a much greater
variety among living worms than among fossilized worms?

A. It would appear that way.

Q. How do you explain that, other than the failure
of the fossil record to preserve that.

A. I would explain it on the basis of speciation


or minor change.

Q. What about the brachiopods in the Burgess
shale, are they as diverse as the brachiopods living to-

A. The way you worded that is difficult.

There aren't very many modern brachiopods.

Neither were there very many in the Burgess shale.

Q. Are there mollusks in the Burgess shale?

A. Yes.

Q. There are?

A. Yes.

Q. What kind?

A. Gastropods.

Q. Which one specifically?

A. I have not identified it to the genus, but
it is a snail, a marine snail.

MR. CHILDS: Off the record.

[Discussion off the record]

MR. KLASFELD: Back on the record.

But you don't know which gastropods?

A. No.

Q. How old do the standard scientists think the
Burgess shale formation is?

A. It's what they call the middle Cambrian,
which I would say is somewhere around five hundred

Q. What is the scientific evidence for your
belief that it's five thousand years old?


A. My belief in the usefulness of the earth is
not so much based on scientific evidence as on Scriptural-
historical information.

From the scientific standpoint, there really isn't
strong evidence, I would say, in regard to the age, either
young or old.

Q. What is the Scriptural evidence for the young

A. Well, I accept to a general -- well, let me
reword that.

The genealogical records and Scripture indicate to
me at least a general indication of time.

Q. What do you mean by "the genealogical record"?

A. The various individuals listed in the years
for their lives and so on.

Q. Let me ask you this, sort of dispensing
faith for a moment.

If you didn't have the Bible to rely on, what would
the scientific evidence lead you to believe about the
age of the earth?

A. The scientific evidence would lead me to think
that the earth was somewhere between, shall we say --
the figure I gave you, for instance, for the -- well,
no. That wouldn't work either.

I was going to mention the Mississippi Delta, but
that would be a flood phenomenon, which would be after

However, we are dealing with the structure in the


surface of the earth, which is a phenomenon, in my think-
ing, of catastrophism, so the evidences for catastrophy
would be involved and it would range somewhere, I would
say, between a few thousand years and a few hundreds of
thousands of years.

Q. It could be hundreds of thousands of years?

A. Yes, if you are taking the scientific evidence

Q. How do you factor in the Scriptural evidence?

A. Because I have confidence in the Scriptures.

Q. What is the scientific basis for that confi-

A. The same as the scientific basis for confidence
in any research that anybody else has done, and that is
we have to check it out and determine for ourselves that
it is reliable.

Q. Are you at least generally familiar with radio-
metric dating?

A. Yes.

Q. Are you at least generally familiar with radio-
metric data?

A. Yes.

Q. What is the standard belief among experts in
radiometric data as to the age of the earth?

A. It has been increasing.

What was the last figure?

Q. Could we agree at four and a half billion years?

A. Four and half million --


Q. Billion.

A. Four and a half billion, yes.

Q. How do you explain that?

A. I would say that they have come to those
figures honestly, and that is the way they view it.

Q. The people who have come to those figures,
are they necessarily evolutionists; I mean, do they
care what the rocks show?

A. Some of them aren't.

Q. Some of them are not?

A. That is right.

Q. How do you, as someone who believes that the
earth is ten thousand years old, deal with the informa-
tion from radiometric data?

A. You are really getting out of my area of

Q. I understand that, but I am saying this:

As a scientist, you are aware that there is an area
of scientific study that has generated the information
that the earth is four and a half billion years old,
give or take a few hundred million years.

How do you, as a scientist, evaluate that informa-
tion and consider it in terms of your own beliefs?

A. There needs to be a distinction between the
substance of the earth and the living things on it.

Q. I see.

What is that distinction.

A. I have no objection to radiometrically dating


ages as far as the inorganic matter is concerned.

Q. I see.

The earth may have been here for billions of years?

A. Yes.

Q. But the living forms on the earth came into
being only ten thousand years ago?

A. That is right.

Q. Where does it say in the Bible that the earth
could be billions of years old?

A. It doesn't.

Q. Then how could that be; in your belief, how
could that be true?

A. Because if you examine the Scriptural account
of creation carefully, you will find it is really just
talking about the surface of the earth.

Q. I see.

Can you quote the section you are referring to?

A. "And the earth was without form and void and
darkness was upon the face of the deep."

Q. Is this a belief and an understanding you have
come to recently or is it one you have always had?

A. It's one that I have had for quite a number
of years.

Q. Forty, ten?

A. Oh, for twenty years.

Q. What about the stars and the sun?

A. I don't think those were involved in creation


Q. They were there?

A. Yes.

This is my personal opinion.

Q. I see.

A. I'm speaking for myself.

Q. That is your interpretation from your reading
the Bible?

A. Yes.

Q. Did God put them there?

A. God created them, put them there.

Q. Why did He wait so long to put life on earth?

A. I don't know.

Q. Do you have any theory?

A. Of why God waited so long?

Q. Yes.

A. What is time to God?

Q. Who do you respect as leaders in the field of
Creation Science research other than the people at the
Geoscience Research Institute?

A. I respect Gish and Morris and John Moore
and others.

I may not agree with them totally, but that is
nothing unusual among scientists.

Q. No, it's not.

Are there standard scientists whose work you

A. Yes.

Q. Whom?

A. Oh, a large number.

It would be impossible to begin to recite them.

I respect the work of some of the individuals that
are going to be witnesses for you.

Q. Professor Gould, for instance?

A. Gould, Ayala and Simpson and some of the

Q. They come to enormously different conclusions
than you do, though?

A. Sure.

Q. Professor Gould recently won an award for
being a genius; are you familiar with that, the Mac-
Arthur Fellowship?

A. I heard about it recently.

Q. Have you corresponded with him at all about
your research?

A. No.

Q. What about with Professor Simpson?

A. No.

I haven't corresponded with any of them.

Q. You haven't wanted to share your work with
them at all as people in your field that you respect?

A. Well, our research has not really been in
the same areas and there is no occasion for me to be
writing to them.

Q. Professor Gould is an invertebrate paleon-
toligist, isn't he?

A. I'm not aware that he is.


Q. What do you understand he is?

A. I understand him to be an expert in the
history of science.

Q. Have you read any of this works?

A. Yes, I have.

Q. What have you read?

A. I have read some of the work he has authored
on his theory on punctuated equilibria and I have read
at least portions of his book --

Q. The panda's thumb?

A. No.

I have read at least one dealing with neotony and
and recapitulation.

Q. And you don't know that he is an invertebrate

A. I never thought of him that way.

Q. Do you know the book "Evolution, Fossils
Say No"?

A. Yes.

Q. That is by Dr. Gish.

Do you agree with that book?

MR. CAMPBELL: I would object.

That one is somewhat ambiguous.

I mean, do you mean particular parts of the book?

MR. KLASFELD: Well, do you generally agree with
the book?

A. Yes, generally.

Q. Are there areas with which you disagree?


A. It depends on the edition.

Some editions have information that I am not so
sure about and others do not have.

Q. Are you distinguishing between the public
school edition and the non-public school edition?

A. No.

Just different printings, different editions.

Q. What is it that is in one of the editions
that is not in the other and that you disagree with?

A. I think the main thing is the use of the
so-called human footprints in the Biloxi River in

Q. You disagree with that?

A. I don't think it's sufficiently strong
evidence to use.

Q. Do you use Dr. Gish's book as a research tool,
as a teaching tool?

A. I have used it as a teaching tool.

Q. Is it a book that is generally accepted by
Creation Scientists?

A. I really can't say.

I am not that well versed with what other creation
groups are doing.

Q. Why is it that you think you are not going
to testify about your work in the ginkgo petrified

A. Well, that is a point of interest but I
haven't thought of it as being a particularly important


aspect of what I have written on or what I have studied

Q. Did you discuss your work in the ginkgo petri-
fied forest at all with Professor Daniel Alexander?

A. No, I haven't.

Q. What other areas do you anticipate testifying
about, to the extent you have given it some thought?

A. A sudden appearance of complex organisms in
the Cambrian, which we have already covered; the absence
of good connecting links between major groups.

Those would be the important points.

Q. What else?

A. Well, I think that is the essence of peleon-
tological testimony.

Q. What is the archeoptrix?

A. It is a bird that is considered to be a con-
necting link between reptiles and birds.

Q. I gather you don't consider it to be a con-
necting link?

A. No.

It's a bird.

Q. Why?

A. Because it has feathers exactly like a modern
bird and it could fly.

Q. What about its sternum bone, is its sternum
bone like a lot of birds?

A. It lacks the typical bird's sternum but that
does not preclude its ability to fly, as has been pointed


out in the scientific literature.

Most birds don't have their -- many birds don't
have their flight muscles attached to the sternum.

Q. What would you want to see in a link between
birds and reptiles that doesn't appear in archeoptrix?

A. Some intermediate form of feather, for in-

Q. Well, there are no feathers preserved in
fossil record, are there?

A. Yes, there are.

- - -


MR. KLASFELD: Q. Is evolution a science, Dr.

A. Usually so considered.

Q. Do you so consider it?

A. Yes.

Q. What are the attributes of a science?

A. The scientific method of science is the body
of knowledge arising from the use of scientific methods
which is experimentation and observation.

Q. And does evolution, people who study evolution,
do they do that?

A. Yes.

Q. Are you aware of Creation Science's
criticism that evolution isn't a science because you
can't observe what was supposed to have happened millions
of years ago?

A. Yes, I am aware of that criticism.

Q. Do you disagree with that criticism?

A. I would say that's a qualification that has
to be made in regard to Evolution Science.

Q. So it is not a particular good science?

A. It is science, but it does have to operate in
some ways that are not truly scientific.

Q. Is Creation Science a better science than

A. It is in the same category.

Q. And what would that category be?

A. If evolution is science, creation is science


and if evolution isn't science, creation isn't science.

Q. But in your mind, is evolution science?

A. Yes.

Q. Are you familiar with the term falsifibility
in terms of science?

A. Yes.

Q. Is evolution falsifiable?

A. Basically, essentially, no.

Q. Is Creation Science falsifiable?

A. No.

Q. Does science, in your mind, have to do with
the examination of the natural world?

A. Yes.

Q. Did the events that take place during creation
week, were they part of the forces that are at play in the
natural world?

A. To some extent.

Q. To what extent are they not?

A. As far as we know, there are no activities
going on in the world today that would be similar to those
involved in the actual creation process.

Q. So the study of Creation Science in that sense
is not a study of the natural forces in play in the world

A. Creation is not something that we can observe
today, not the kind of creation that went on then.

Q. But not only is it not something that we can't
observe today, but they are not the natural forces that


are in effect today, either, is that correct?

A. I think I can answer yes on that, but the laws
of nature in operation in the world today were established
at creation.

Q. But did not take place during creation, there
were other laws in effect then?

A. They were in operation then, too, but there
were other laws beyond them that are not in operation now.

Q. What laws were those?

A. If we knew, we would be winning the Nobel Prize.

Q. Does Creation Science make any sense without
the Bible as sort of a belief form?

A. I have felt that it does, that a person who
knew nothing about evolution or creation, if he took the
fossil record at face value, he would come up to the
opinion that there was a sudden creative act.

Q. Based on the sudden appearance of complex
organisms in the Cambrian, and the absence of good
connecting links between major groups?

A. That's right.

Q. Those two?

A. That's right. Now, I might add, in the study
of paleontology and these two points, it may well be
that we would spill over into speciation to some extent,

Q. Is there any aspect of speciation that makes
you believe that it has to stop at a certain point?

A. Yes.


Q. What mechanism is that?

A. Genetic mechanism.

Q. Which one?

A. The inability of the chromosomes to synapse,
match up.

Q. Synapse doesn't mean match up, does it?

A. That's the way it is used in genetics.

Q. I thought a synapse meant the gap?

A. No.

Q. Is that wrong?

A. Not in genetics.

Q. And this inability of chromosomes to synapse
creates the parameters within which --

A. The limits.

Q. -- the limits for which DNA can change?

A. Between which crossing between diverse types
can occur.

Q. Could you tell me what it is that you anticipate
testifying about the sudden appearance of complex
organisms in the Cambrian as support for your belief in
Creation Science?

A. Well, if the theory of evolution is correct,
there should be a series of steps leading up to these
complex organisms and since those are not found, the
evidence supports sudden creation.

Q. What about these organisms that we discussed
before that are in the pre-Cambrian?

A. It may have enlarged to the picture some of


what is in the pre-Cambrian, but, to my knowledge, none
of them classify as ancestors to the Cambrians.

Q. And what would you anticipate saying about the
absence of good connecting links between the major groups?

A. That even in punctuated equilibria, which is
Gould's and Eldrige's ideas, you would still have series
of connecting links between one basic category and

Q. And that those links are missing?

A. Yes.

Q. What about intermediate structural forms, do
you view those as, one, existing; and, two, if they are
existing, are they evidence for evolution?

A. Are you thinking of like vestigia organs?

Q. Like that.

A. Well, that argument is almost never used any-
more in evolution. Vestigia organs have pretty well turned
out to be useful.

Q. How is the appendix useful to me?

A. Well, I am not a physician, but I think you can
find that quite a number of them would suggest that
it does have a function.

Q. Are you familiar with Professor Gould's work
on the Panda's thumb?

A. I have not read it, but I have heard mention of




Q. You understand what the panda's thumb is and
what it does?

A. No, you would have to explain it.

Q. Are we, as organisms, as efficient as we might

A. No.

Q. Why did God make us inefficient?

A. He didn't. There has been change, degenerate
evolution, if you please, since creation.

Q. I am a less inefficient form than the form
that existed four or 5,000 years ago?

A. What was the first word you said?

Q. I.

A. I, not this "eye"?

Q. That's right.

A. Yes.

Q. How come people today can run faster than
they could a hundred years ago?

A. Because of various factors. They have learned
how to train for those particular muscles and nutrition is
better. We know more about nutrition.

Q. Aren't they more efficient?

A. To some extent.

Q. How do you explain that in terms of your
notion of degenerative evolution?

A. That example would have to be balanced by the
increased number of individuals in insane asylums and
people who are mentally retarded.


Q. Do you believe in the existence of unidentified
flying objects?

MR. CAMPBELL: Object to that for relevance purposes,
but you may answer it.

THE WITNESS: Not very -- not very well. Not very

MR. KLASFELD: Q. Do you believe that testability
is a hallmark of science?

A. Yes, it should be.

Q. In what sense is creation science testable?
Is creation week testable?

MR. CHILDS: Scientifically?

MR. KLASFELD: Q. As a science.

A. It is not testable scientifically.

Let me qualify that slightly. There is no good
explanation for the week, outside of creation. But to my
knowledge, that's the only, shall we say, scientific
evidence in support of creation week.

Q. What is the only scientific evidence?

A. The present worldwide, still today, of a seven-
day week cycle.

Q. Oh, I see, the fact that --

A. There is no astronomical explanation.

Q. Monday through Sunday?

A. Yes.

[Discussion off the record]

MR. KLASFELD: Let me mark this as the next exhibit.

[Document, more particularly


described in index marked
Plaintiffs' Exhibit 6 for identi-

MR. KLASFELD: Q. Section 4(a) of the Act defines
creation science. It says,

"Creation science includes scienti-
fic evidences and related infer-
ences that indicate: one,
sudden creation of the Universe,
energy and life from nothing."

What is the scientific evidence for that?

A. I think we just discussed the fossil evi-

Q. This is the sudden creation of the Universe,
energy and life from nothing.

Oh, you are saying the fossil evidence is the evi-
dence from sudden creation of life?

A. Right.

Q. What about sudden creation of the Universe?

A. I really can't go into that, because I am just
not at all versed in astronomy.

Q. And energy?

A. Even less, really.

Q. And number 6,
"A relatively recent inception of
the Earth and living kinds."

What is the scientific evidence for that?

A. The evidence is on the surface of the Earth,


that its present configuration has not been around that

Q. What are those specifically, those evidences?

A. That if it had been around a long time, there
would have been erosion down to sea level and filling in
of the Gulf of Mexico and that type of thing.

Q. But you said that could have been as much as
several hundreds of thousands of years, is that correct?

A. Yes, I said that. Several thousand to --

What did I say?

Q. I thought you said several hundred thousand.

A. Several thousand to several hundred thousand, I
said, on the basis of scientific evidence.

Q. Yes.

What is the basis for your belief that it was
certainly less than 10,000?

A. Well, of course, that statement there says
relatively young. It doesn't identify it.

Q. That's right.

A. So I am not sure what they are thinking of.

Q. But you do in fact believe that it is 10,000
years or less?

A. My opinion, not so much based on science as
based on my confidence in Scripture, is that it is just a
few thousand years old, life upon this Earth.

Q. What is the scientific evidence for separate
ancestry for man and apes?

A. The absence of a good series of connecting


links between man and ape.

Q. Are you going to testify at all about any other
aspects of the geological column, the formation of the
geological column during the flood period?

A. Well, of course, we have already mentioned that
I haven't prepared the testimony yet. But I could discuss
how the geologic column could be explained on the basis of
an ecological sequence rather than an evolutionary

Q. Why are there no complex forms in the Cambrian?

A. What you are trying to say, why are there no
vertebrates in the Cambrian?

Q. Yes.

A. Well, fish have been reported in the Cambrian,
but on the basis of our concept of ecology, we wouldn't
expect to find at least land vertebrates, because these
are largely sea bottom creatures that are found in the

Q. Why are they there?

A. Because they would be the first ones buried in
a universal catastrophe.

Q. It wasn't just a flood, though, right?

A. I am thinking.

Q. The fish wouldn't drown, is my point.

A. Oh, yes, they would. You stir up the water
and get it muddy and the fish would not survive. But that
would happen later. I mean there would be a little
passage of time before the fish would start to drop out.


Q. How about the trilobites?

A. They are benthonic animals, benthonic animals.
They live on the bottom.

Q. Weren't there any dead fish lying on the

A. Apparently there are, if the reports of fish
are true, although very few have been found in the

Q. Aren't there always a lot of dead fish on the

A. No, that's an amazing thing. Vertebrate
remains do not accumulate down in present ocean bottoms.
It is so rare to find even the scales of fish on the
bottom of muds, of lakes or rivers that it even gets
reported in the scientific literature.

Q. Is the geologic column, is it consistent
around the world?

A. Pretty nearly so. Australia, South America,
are a little odd.

Q. But in general, it is an amazing consistency?

A. Yes.

Q. How do you account for no sort of mixing?

A. There is mixing, but not through the whole

Q. Not one trilobite got missed?

A. You mean surviving today?

Q. Well, even getting up above the Cambrian level.

Q. There are trilobites all the way up to the



Q. Oh, is that right?

A. Yes.

Q. Where is that found?

A. Where is it found?

Q. Yes.

A. You mean the mississippian?

Q. Where are the trilobites found in the
mississippian level?

A. This is nothing rare. This is the usual
stratigraphic range.

Q. How did they get up there?

- - -


A. Some were swimmers and some were bottom-crawlers
and some were mud-burrowers, and as far as ecologic idea
is concerned, they would be buried in that sequence.

Q. So that the ones that were mud-crawlers were
on the bottom and the ones that were swimmers were found
further up?

A. Farther up, yes.

Q. Why did the swimmers get drowned?

A. For the same reason that any fish, which have
gills, would be unable to extract oxygen from turbid

Q. Why aren't there trout with the swimming

A. Why aren't there what?

Q. Dolphins with the swimming trilobites?

A. Of course, when you get up farther, farther
up the geologic column, you do get into vertebrates.
There are vertebrates.

Q. Are there vertebrates where the trilobites are?

A. In the same formations in the same geologic

Q. Are there any cows where trilobites are?

A. No.

Q. Why not?

A. Because cows don't walk around on the bottom
of the sea.

Q. But you said some of the trilobites swim.

A. Well, the cows don't swim, either.


Q. So that the first division is things that are
in the water, right?

A. The lower Paleozoic is sea bottom and sea-
swimming animals.

Q. Why aren't there any cows with the dinosaurs?

A. I would take that to be evidence that they
occupied a different kind of environment than with such
animals as the ungulates would occupy.

Q. The dinosaurs did?

A. Yes.

Q. Are there dinosaur fossils where we have cows,

A. In the fossil record?

Q. No, no. Are there dinosaurs in the fossil
record where there are cows living today?

A. Oh, sure. You mean, in other words, cows are
grazing in Colorado where there are dinosaur fossils

Q. Yes.

A. Sure.

Q. So why aren't there remains there today,
fossil remains?

A. Well, I am sure you wouldn't want to say the
environment in Colorado now is the same as when the
dinosaurs were buried.

Q. No, I wouldn't.

A. I wouldn't, either.

Q. But at the same time you are willing to talk

Transcript continued on next page

Deposition of Harold G. Coffin - Page 4


about the Mississippi always happened to have been there?

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

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

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

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

A. It covered it, too.

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

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

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

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

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

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

Q. Why was there a flood?

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

Q. And God created the flood because of it?

A. That's what Scripture says.

Q. When did that take place?


A. When did it take place?

Q. Yes.

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

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

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

Q. What is the scientific evidence for that?

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

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

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

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

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

A. I naturally have tried to keep up on such

[Discussion off the record]

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


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

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

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

A. Certainly.

Q. What are some examples of that information?

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

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

A. That's an impossibility.

Q. You have no opinion on that?

A. Yes.

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

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

Q. I want to talk about only what we disagree



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

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

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

Q. Millions?

A. Millions of years ago.

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

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

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

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

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

Q. What are the problems?

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

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



A. Yes.

Q. What are they?

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

Q. What percentage difference does he find?

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

Q. What about non-eruption evidences?

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

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

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

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

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

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

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


Q. Do you respect him as a scientist?

A. Yes, I do.

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

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

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

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

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

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


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

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

Q. Does Mr. Dalrimple have a paradigm?

A. Certainly.

Q. Is he an evolutionist?

A. No one can go into research without some

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

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

A. Yes.

Q. What was his interest?

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

Q. Which paradigm is that?

A. An evolutionary paradigm.

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

A. No, I haven't.

Q. How do you know he has one?

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


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

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

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

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

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

Q. What is your own bias?

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

Q. You are referring to 590?

A. Yes.

[Discussion off the record]

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

A. That's involved, yes.

Q. To what extent is it involved?


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

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

A. Basically, yes.

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

[Discussion off the record]

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

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

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


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

MR. CAMPBELL: Is that your statement?


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

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

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


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

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

[Discussion off the record]

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

[Discussion off the record]


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


thick which will be attached and filed with the original

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

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

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

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

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

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


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





) ss.


I hereby certify that the witness in the foregoing
deposition named


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


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

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

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