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The Critic's Resource on AntiEvolution

Deposition of Dr. Stephen Jay Gould





REV. BILL McLEAN, et al.,






Deposition of STEPHEN JAY GOULD, held at the offices of Skadden, Arps, Slate, Meagher & Flom, Esqs., 919 Third Avenue, New York, New York, on the 27th day of November, 1981, at 9:30 o'clock a.m., pursuant to Notice, before Helaine J. Dribben, a Notary Public of the State of New York.






Assistant Directors for Affiliate Program American Civil Liberties Union

132 West 43rd Street New York, New York 10036

STEVE CLARK, ESQ. Attorney General State of Arkansas Justice Building Little Rock, Arkansas



919 Third Avenue New York, New York 10022





IT IS HEREBY STIPULATED AND AGREED by and between the attorneys for the respective parties herein, that filing and sealing be and the same are hereby waived.

IT IS FURTHER STIPULATED AND AGREED that all objections, except as to the form of the question, shall be reserved to the time of the trial.

IT IS FURTHER STIPULATED AND AGREED that the within deposition may be signed and sworn to before any officer authorized to administer an oath, with the same force and effect as if signed and sworn to before the Court.

- oOo -



as a witness, having been first duly sworn by the Notary Public, was examined and testified as follows:


Q. Could you state your name, please?

A. Stephen Jay Gould.

MR. ENNIS: Bruce J. Ennis, appearing for Dr. Gould. Steve Barnes also appearing for Dr. Gould.

Q. Have you brought any documents with you today?

MR. ENNIS: Yes we have. In addition to the 3 books we have produced, ONTOGENY and PHYLOGENY, THE PANDA'S THUMB and THE ORIGIN, A VIEW OF LIFE, we are also producing several documents.

You previously received a curriculum vitae for Dr. Gould, but I would like to give you an updated current version of that CV, together with a complete scientific bibliography of the many articles written by Dr. Gould. We are also producing various file


folders which break down by categories relevant to your request for production of documents, additional correspondence, and documents that were in Dr. Gould's possession.

And we are in addition producing articles written by Dr. Gould which bear specifically on the subject of creationism or creation-science and subjects directly relevant to this lawsuit.

Finally, I would like to state for the record that we would like to at least mention to you that there is one article written in the Creation Research Society Quarterly, which Dr. Gould may have occasion to refer to in the course of his testimony, but for which I do not have a copy. It's called THE CEPHALOPODS IN THE CREATION and THE UNIVERSAL CREATION, and it's written by John Woodmorappe.

In the Creation Research Society Quarterly, volume 15, September 1978. I will give you this copy now, but I do not have an extra. If you would like to make one, I would appreciate if you will return the original.

MR. WILLIAMS: Yes, I would like to


have a copy made of this.

MR. ENNIS: I would also like to state for the record that we made a diligent effort at Harvard Wednesday to try and find our Creation Society literature on which Dr. Gould might rely in his testimony. We have not been able to determine for certain which things he will be relying on, but he has read many books by creationists, and if you would like we can state them for the record because he may -

A. Yes. The main ones would be Gish's EVOLUTION THE FOSSILS SAY NO. THE GENESIS FLOOD by Whitcomb and Morris: FOSSILS KEYED TO THE PRESENT, by Bliss, Parker and Gish. SCIENTIFIC CREATIONISM, by Henry Morris.

I am not saying I won't read some others before the trial, but these are the ones I have read so far. In fact, the only major creations works I own.

MR. ENNIS: I would like to say for the record that I now understand that you have a copy of another book written by Dr. Gould entitled EVER SINCE DARWIN. And that will complete our document production in response to your request.


I would like to state for the record that Dr. Gould has written literally hundreds of articles in his professional career and all of them to some extent or another have something to do with evolution. We have not produced all of those articles because he does not have copies of most of them, and had reprints of virtually none of them. But we have made an effort to reproduce all articles that deal with creation-science or anything related to this case.

We have also produced a list of publications, and if on looking at that list there appear to be any additional publications in that list which you think might be relevant, we will be happy to try and get copies of those as well. We made an effort to screen through and I think we complied in good faith with your request.

MR. WILLIAMS: Thank you.

MR. ENNIS: We are going to have the standard stipulation reserving all objections except as to form until the trial. We will not waive the signing of the deposition, however. Anything else you would like to add, David?

MR. WILLIAMS: No. Its my


understanding though, concerning the details, that the original will be forwarded directly to Dr. Gould; is that right? For his signature.

MR. ENNIS: We will have to figure out. what's the quicker way to do that since he's going to be out of the country.

MR. WILLIAMS: Off the record.

(Discussion off the record.)

MR. WILLIAMS: In our off the record discussion, I think we have agreed that the original of the deposition transcript will be sent to Dr. Gould either tomorrow or Sunday by Federal Express or some other overnight delivery service. He will then read it and make any necessary corrections before he leaves the country on Wednesday of next week. Will return it by Express Mail or some other overnight means of delivery to Skadden, Arps, who will conform their copy to any changes made. They will in turn send the original signed and corrected to the Attorney General's Office, Justice Building, Little Rock, Arkansas, to my attention.

Q. Dr. Gould, where are you currently employed?


A. Harvard University.

Q. And your position at Harvard?

A. Professor of geology.

Q. Are you tenured?

A. Yes.

Q. When did you receive your tenure?

A. 1971, July 1 - sorry, July 1, 1973.

Q. Your attorneys - the attorneys for the plaintiff, have they explained to you the purposes of a deposition?

A. Yes.

Q. Have you testified before in any case?

A. Never.

Q. Ever had a deposition taken before?

A. No.

Q. Are you married?

A. Yes.

Q. What Is your wife's name?

A. Debra Lee, maiden name, Lee.

Q. Is she employed?

A. She's a self-employed artist and illustrator.

Q. Do you have any children?

A. Two boys.


Q. Ages, please?

A. One 8 and one is going to be 12 next Thursday.

Q. Where are they in school?

A. My youngest son is in the local public school called the Agassiz School, my older boy is seriously learning disabled is in a special school called League School in Newton

Q. Your 8-year old will be in the second grade?

A. Third grade

Q. Would he have any courses yet in which they discuss the subject of origins?

A. I wish he did, but the state of public education in Massachusetts is such that there is no science at all in public schools now, which is a scandal or other reasons.

Q. Why is there no science in the public schools of Massachusetts?

A. There is in some schools. There was a science specialist, but he was released for lack of funds. I don't say the teacher doesn't occasionally discuss some scientific subjects.

Q. To your knowledge, has the subject of


evolution ever been discussed in your son's class?

A. I am it wasn't.

Q. Are you a member of any organized religious faith?

A. Not a formal member.

Q. Informal member?

A. I identify myself as Jewish faith. Not a paying member of any temple or synagogue.

Q. Do you observe any Jewish holidays?

A. In my own way. I fast on Yom Kippur, and that's difficult for a fatso like me.

Q. Have you ever been a member of a synagogue?

A. No.

Q. Have you ever studied what the Jewish faith says about the origins of man and life in the world?

A. Yes.

Q. Where did you study that?

A. Informally, personally.

Q. What is your understanding of their position on the origin of the world?

A. As with virtually all matters among Jews there are as many opinions as there are



Q. Are there some individuals, if not viable groups, within the Jewish faith who subscribe to literal interpretation of Genesis?

A. There are, but it's definitely a minority position.

Q. What is your personal belief as to the existence of a God?

A. Difficult question because it depends so much on a matter of definition. If you ask me whether I think there's a male figure with a beard sitting in the clouds, I certainly don't. But if one were to define God as the source of order in the universe, I might be tempted to say yes.

Q. You might be tempted to. Is that your -

A. I reserve judgment, because that's an issue far too difficult for the human mind to answer.

Q. So to the extent that you would consider the possibility of a God, you would define it as a source of order in the universe?

A. No. I didn't quite say that.

Q. I just want to understand what your


position is.

A. I said if one were to define God that way, I might be willing to give my assent.

Q. What is your present opinion as to the existence of a God?

A. It's again a definitional question. If one chooses to -

Q. Define God.

MR. ENNIS: If you can. If the witness has a definition.

A. No, I really don't. It means too many different things to too many people.

Q. That's why I am trying to ask you what it means to you, because I understand that it can be given different meanings.

A. No, I really can't. Mysteries have no definitions.

Q. Would you characterize yourself as an agnostic, an atheist, deist, sir, or any of the other labels which have arisen to put people in nice pigeon holes?

A. The problem with academics is we tend to perhaps traversely and certainly ardently to value our personal approaches so much that we


really decline to impose any label upon ourselves, and therefore I have always resisted such characterizations. As the literal meaning of the word, and agnostic is one of them, is unsure. In the literal meaning of course I am, in the vernacular agnostic, and have done many things. Let us say I regard the issues too difficult for either my mind or anyone else's to solve.

Q. To the extent that any of those are a label concerning your position on the existence or lack of existence on a God, would agnostic be the closest that you are aware of?

A. When something is close it's not necessarily good enough. I will certainly admit that agnostic is certainly a closer word than creationist. But any word is so far from my personal beliefs that I decline to be labeled by the terms.

Q. You say that mysteries have no definition. What do you mean by that, that the existence of God is a mystery?

A. However we define it, we know so little that the subject is beyond our comprehension.

Q. Beyond our intellectual comprehension?


A. That's the only way I know to comprehend. To comprehend literally, that doesn't mean that we don't have other sources of feeling, et cetera.

Q. Do you think that a religious person can be a competent scientist?

A. Of course. The empirical record proves it. There are thousands upon thousands of religious people who are competent scientists.

Q. Do you think that a religious person who might be characterized as a fundamentalist can be a competent scientist?

A. Depends on what they do. If the science that they do has no bearing upon their belief in the literal interpretation of scripture, then the answer might be yes. If, for example, they worked on the mechanism of the heart, and were only interested in how it functions as a machine, never ask questions about how it got there, how it arose, I imagine that one could.

Q. Do you think that a person who might be characterized as a fundamentalist on religious issues could be an adequate scientist in studying evolution and the subject of origins generally?


A. Insofar as at least in my understanding the basis of creationism is a belief that God or some supernatural force placed creatures on earth by an act of miraculous creation, and insofar as a miraculous creation is a suspension of natural laws and insofar as science deals with natural laws only, the answer would be no. Except with one qualification. If for example a creation scientist can find himself in my profession, for example, merely to describing fossils, I suspect since that's a purely empirical endeavor, it could be done.

Q. My question, though, I am not sure if I was perhaps as clear as I might be, is if someone is a "religious fundamentalist" and is a scientist studying origins, if they look at all the scientific data and attempt to analyze it, in the most competent scientific manner that they know, would they be any less a competent scientist because of their religious beliefs?

A. Could you define fundamentalist for me?

Q. I admit the term does not admit of an easy definition for me. It is a term bandied about in this lawsuit, more by the plaintiffs than


the defendants, I might say. Let's take one step back and just replace the term fundamentalist with one who has an article of faith, believes in the literal account of Genesis, his article of faith I said.

A. Science of course by definition doesn't deal in articles of faith. So insofar as articles of faith involve empirical claims, as a literal belief in Genesis does, such a person could not be by the usual definitions a scientist.

Q. How does Genesis necessarily involve an article of faith as empirical data, is that what you said?

A. That was your definition.

Q. I am saying as an article of faith — let me rephrase the question. If a scientist believes in Genesis literally as an article of faith and then studies it, studies not it, but the subject of origins generally as a scientist, can he not believe in one as an article of faith, Genesis as an article of faith and then study the scientific evidence without being biased or tainted in your own mind?

A. You mean of course the literal


interpretation of Genesis. I believe that Genesis is an inspired account in a different way, and very great literature as well. Sorry, I missed the thread of your question.

Q. What I heard you say earlier indicated to me that you understand that a scientist who believed as an article of faith in the literal account of Genesis could not be a competent scientist to study the subject of origins and theories of origins.

A. If they insisted a priori and an unreviseable belief that the literal story of Genesis had to be true, then since the empirical evidence is so overwhelmingly against certain aspects of the Genesis story, particularly the creation of all life in 6 days and 24 hours, that could not be because that belief has been falsified.

Q. That is the key, isn't it, as to whether they will try to establish or come to their work with a priori conviction?

A. That could not be altered.

Q. If they had this religious belief but they were able to put that aside and look at the


data as a scientist there is no reason why they —

A. That's a contradiction in terms, they couldn't. If they really are biblical literalists committed to it, then the scientific data puts to the contrary.

Q. Are you aware that even among biblical literalists that they don't necessarily believe that week of Genesis was a week of 24-hour days?

A. The bill as I understand it, demands that they are not 24-hour day, then the creation of the earth is so recent then it is equally falsified by the evidence that we have.

Q. We will get into the bill in a moment. I have been handed this morning either revised or updated curriculum vitae. Does this vitae include all of your employment since you received your Bachelor's Degree?

A. Yes, it does. It's been a dull life. I have just been at Harvard since I got my Ph.D.

Q. What courses do you teach in geology at Harvard?

A. I teach several courses. I teach either year a large course in the core curriculum, which is the general education program for the


college which is called science B-16, which is an overview of the history of the earth and life. In addition, I teach, though not every year and in varying intervals, a number of more technical courses in paleontology, evolutionary theory, and the history of evolutionary and geological thought.

Q. You received your Bachelor's Degree in geology at Antioch in 1963?

A. Correct.

Q. Did you have any subspecialty in your study of geology?

A. Antioch is a strange school. It doesn't really recognize formal majors. I took a fair number of courses in biology as well, with a major in geology.

Q. Did you bypass the Master's Degree? I don't see that listed.

A. Yes. It's customary. At least many schools that are Ph.D. oriented to either have an honorary master's that you really get after having taken a certain number of courses or to dispense with it all together. I may even have it, I don't remember.

Q. And your Ph.D. was in what?


A. In geology, with a specialty in paleontology, 1967, Columbia University.

Q. Describe for me briefly how you would define paleontology?

A. Paleontology is the study of fossils. Simple as that, all aspects thereof.

Q. Who was your major advisor at Columbia?

A. My major advisor was Norman Newell, a curator of fossil invertebrates at the Museum of Natural History.

Q. Have you ever taught a course on creation-science?

A. I couldn't. There is no such thing.

Q. Have you ever discussed the subject of creation-science in your classroom?

A. Only in brief allusions in my science B-16 course.

Q. Do you recall what your brief allusions would consist of?

A. They were negative.

Q. I would expect that, but do you recall the content?

A. I in fact will give — come up to Harvard next week. I am going to give 2 lectures


on Monday and Wednesday, which is the first lecture I will give on the subject. They mainly consisted on attempts to show that by the definitions of science, creationism did not qualify.

Q. Are you aware of any schools where the subject of creation-science - I am talking about schools which are post secondary schools, colleges, universities, where creation-science has been taught?

A. I know that it is in the abstract, but have never talked with anyone who teaches such a course. I did in Dayton, Tennessee, meet the president of Bryan College, and I believe, though I am not certain, that they teach creationism there.

Q. Do you know if it's being taught in any other colleges or universities say on the east coast, what would be some of the more major colleges?

A. I'm not aware that it is.

Q. Would you be surprised if it is?

A. Yes — depending on how it's taught, I would not be surprised if it were considered in sociology courses an issue of the day. I simply


don't know.

Q. Where did you graduate from high school?

A. Jamaica High School. It's a public high school in New York, in Queens. Not on the island of.

Q. What science courses did you take there?

A. The standard very poor offerings that existed before the Sputnik went up. I had in junior high school, a year of general science, and then a year of biology, a year of physics, and a year of chemistry, plus mathematics of course. No calculus.

Q. Did you study theories of origins in high school?

A. Ever so briefly.

Q. What do you recall about your study?

A. Virtually nothing. Evolution was treated in a week or so at the end of the course. That being, by the way, a legacy of the Scopes trial and the textbooks which still exist not many years later.

Q. How did you arrive at the conclusion that that was a legacy of the Scopes trial?

A. Because the book we used was Moon,


Mann, and Otto. And we know since that book was around since 1920 that, although the early editions included much evolution, the post-Scopes trial ones did not.

Q. Are you aware that there were other texts which were available which perhaps had a more thorough discussion of evolution?

A. No idea. I was a little child.

Q. Was the creation model or any symbols there of origins treated in your high school courses?

A. No. But there was very little evolution either.

Q. In undergraduate school at Antioch, what courses on theories of origins would you have taken?

A. Theories of origins is a bad term, because we don't really deal with origins in the study of evolution. If you ask me in evolution, the answer is a fair number. I guess I only had one formal course entitled "Evolution," but I had since age ten or 11 made a personal study of the subject.

Q. What books had you read from age ten


and 11 that you can recall and that would have been influential?

A. The first book and most influential one was George Simpson's, THE MEANING of EVOLUTION.

Q. When did you read that book?

A. Let us say I attempted to read it at age 11. I doubt in rereading it later that I understood much of it then.

Q. Any other particular influential books in this area?

A. I like Roy Chapman Andrews' ALL ABOUT DINOSAURS, but I doubt very much that it said much about processes of change.

Q. In undergraduate school, did you receive any instruction in creation-science, model of origins or anything similar thereto?

A. Only from personal study. I always had an interest In the subject.

Q. And in your postgraduate studies, did you have any study of the creation-science model of origins, or anything similar to it?

A. Not formally, again.

Q. What was the subject of your Ph.D. dissertation that you wrote?



Q. Was that published?

A. Yes, it was. It's item 20 on that list if I remember correctly, a very long and complex title.

Q. When was the first time you heard the term creation-science?

A. I just don't know.

Q. Approximately?

A. The problem is I don't know whether — I certainly am aware of literal beliefs in Genesis. I have read a lot about the Scopes trial as a teenager. I just don't know whether the term was used then. I don't think so, but I don't know.

Q. In response to our request for documents you brought with you this morning some various documents I want to ask you some questions about.

First of all, labeled in a folder entitled American Society of Naturalists, Committee on Creationism, there is a memo and two or three letters. Do you recall what the occasion was that you received this?


A. Yes. I became president of the American Society of Naturalists by the death of the man who should have served. I was not so elected. I was vice president. And one of the items of business was the establishment of a committee within the society to study the creationist challenge, and I as president participated in the setting up of such a committee asking Bruce Wallace to be its chairman. That committee functioned sporadically, made the report that you have, and more or less merged with a still ongoing committee for which you have a folder of documents and of which I am a member of the Society for the Study of Evolution. I might say that the Society for the Study of Evolution of the American Society of Naturalists are the two major professional societies of evolutionists.

Q. So you appointed Bruce Wallace to chair the committee; is that correct?

A. Bruce Wallace is too eminent a man. One doesn't appoint him, one begs him to do it.

Q. You were responsible?

A. I asked him, yes.


Q. When did the American Society of Naturalists decide to set up a committee on creationism?

A. My memory for dates is terrible.

Q. Approximately?

A. It was 1978 or '79 or 1980. It was at the annual meeting.

Q. Is there any resolution or any other written documentation concerning the reasons why this committee was set up?

A. If so, I don't have them. As I remember, Walter Bock, was a professor of biology at Columbia, wrote to the president of the society asking or recommending that such a committee be established. I had that letter at one time. I don't now, because I passed on my entire files. As I said, I was only president pro tem.

Q. What do you recall as the reasons motivating this committee being established?

A. We evolutionists believe that what you call creation-science is a contradiction in terms and is not science. We were alarmed at its spread in various secondary schools across the nation and set up a committee to look into ways whereby


evolutionary biologists might raise questions and oppose this spread.

Q. Was a charge given to this committee?

A. Only to report back the following year as to what they thought effective tactics might be. Let me not say that. What they thought the appropriate stands of professional evolutionary biologists might be.

Q. It was clear at the outset, was it not, that the overall purpose would be to symbol creationism?

A. Oh, yes, indeed. I presume that's not an issue. Sorry if I was pussyfooting.

Q. What is the Voice of Reason?

A. The Voice of Reason about which I confess I know not a great deal, is an organization brought to my acquaintance by Morris Goodman, who is an evolutionary biologist at Wayne State University in Detroit, which has at least one of its charges combating creationism. Dr. Goodman asked if I would sign the statement of purpose and become a member of I don't know if it's the board of advisers or just a list of signatories. I read the list and signed them.


Q. These subscribe to this document entitled the Voice of Reason with several subtopics, the American Tradition and another subtopic of the Secular Stage.

MR. ENNIS: Is your question did he by signing subscribe to the entire document or just the statement on creation-science?

MR. WILLIAMS: My question is, there is a two page document there which his name I think the fourth page is listed as on the national board of advisers.

A. As always in signing documents, I do not guarantee that I accede to every nuance of every word, but the resolution section which is the guts of the document I signed because I do indeed support it.

Q. What have been the functions or activities of the Voice of Reason to date?

A. I don't know.

Q. When did you agree to sign on as a member of the National Advisory Board?

A. I think it was last spring, spring of 1981 that is. But I would not commit myself to that. Plus or minus 8 months, which is the


academician's statistical fluctuation.

Q. Looking at the National Advisory Board I notice it includes people like Isaac Asimov, Francisco Ayala, Guy Bush, and there are people on the list. Would it be fair to say that all these people would be evolutionists?

A. I am sure they are all evolutionists. Yes, it would.

Q. These other documents that you have provided from the Voice of Reason which include some really outstanding works of art, have you read those before?

A. I have glanced through them.

Q. I notice on one page it says "It is our heritage to continually construct a wall of separation between church and state."

A. The only thing wrong with that is the split infinitive.

Q. But do you agree that's part of our heritage, to have a wall of separation between church and state?

A. I thought that's what the first amendment says, not in quite that graphic language. The best for the protection of religion, as well


as everything else.

Q. Has this been published, to your knowledge, any of this information in any other form?

A. I don't know.

Q. It would appear to be perhaps the draft of some sort of pamphlet or something?

A. It did come in a bound pamphlet form. No, that art does not hold a shadow to Michelangelo. I think Michelangelo today would have been an evolutionist.

Q. Does this group have any meetings that —

A. I don't know.

Q. You have not attended any personally. By the way, did anybody ever ask you if you do this last Tuesday?

A. No. I am sorry. I don't like being here either. I want to be with my family.

Q. But you were never contacted to check and see if you could have done this Tuesday?

A. I couldn't have, I had to teach. I don't really remember if we did, since I had a class in the morning, I couldn't have in any case.


As I understand it, I am here at your request, not at my personal desire.

Q. I understand that. What involvement have you had with the so-called Committees of Correspondence?

A. No personal involvement. I merely submitted those documents since they were sent to me. I tried to give you whatever literature I had from any formally constituted anti-creationist group.

Q. Are you aware of the purpose of Committees of Correspondence?

A. In a loose sort of way, yes. I have spoken very briefly to Stanley Weinberg in the State of Iowa, whom I understand is their leader, and I know the head of Massachusetts branch, Laurie Godfrey, but have had no formal ties with them.

Q. You haven't done any work or any writings yourself?

A. No.

Q. Do you know why you were sent this material?

A. I imagine they have a mailing list that


Includes evolutionists of notoriety. I guess I classify - I qualify as such.

Q. I think you said earlier that you are a member of the Society for the Study of Evolution's education committee. What is your understanding of the purpose of the education committee?

A. To study the creationist challenge and devise means of meeting it.

Q. Again, the purpose is to oppose it, correct?

A. Oh, yes, indeed.

MR. ENNIS: Can I ask you to clarify your question by what you mean oppose it, do you mean oppose the teaching of it in public schools or oppose it more generally?

A. You can't oppose what parents do in their house or what churches do in their buildings. That's no concern of ours.

Q. I notice in some of the correspondence on the committee, education committee of the Society for the Study of Evolution the term the anti-evolutionist is often used. Do you use that term in reference to the creation scientist?

A. I usually call them creationists. They


are not creation scientists, because in my view they are not scientists, and they are people opposed to evolution. So I myself use the term creationist.

Q. Do you use the term anti-evolutionist?

A. I haven't, I don't think. But it would not be an inappropriate term.

Q. What duties or activities have you undertaken on the education committee?

A. I attended a meeting at the annual meeting of the Society for the Study of Evolution held in Iowa this June or July, and beyond that I have been a fairly passive member, merely receiving documents, although I did send out one mailing in which I merely sent copies of the two of the articles that you have to all members of the committee in response to a request that we circulate among ourselves those writings that we have.

Q. What articles did you send?

A. The piece from DISCOVER MAGAZINE, and the natural history column entitled a visit to Dayton, both of which you have.

Q. There is a file with some


correspondence in it titled the "National Academy of Sciences."

A. The National Academy of Sciences has a committee. How active or how it's constituted I don't know. It was preparing a draft statement on creationism. I was contacted by Dr. Maxine Singer, and asked to check its wording and make any comments. I suggested a very few alterations, mainly stylistic.

Other than that, they did hold a meeting in Washington, I was invited to attend it but was unable to because I had classes that day. That is the extent of my involvement with them.

Q. Have you had any other — you may have said something on this, perhaps I didn't hear — but other than this reviewing this draft of a statement on creationism, have you had any other involvement with the National Academy of Science's opposition to creation?

A. Not other than being invited to this meeting and being unable to attend.

Q. In the final folder that I have in front of me presently is a National Association of Biology Teachers, which contains apparently some



A. Yes. I have had no official contact with them. That like the Committee of Correspondence information that came to me and knowing that the NABT is active in the anti- creationist front, I thought I would supply those documents. I should, however, mention that I did at the annual meeting of the National Association of Biology Teachers held in Boston and now again it's plus or minus a year, it was either this year's or last year's meeting, give an address on creationism.

Q. Is there a transcript of that address?

A. I think there is.

Q. Is it included in these materials?

A. I don't own it, but it could be, if such exists it would be a cassette tape and could be obtained by contacting Wayne Moyer, who is head of the national association.

MR. ENNIS: Let me say for the record that in Boston on Wednesday we did ask Dr. Gould if there were any transcripts of any of the addresses or speeches he had given on the subjects covered by your request to produce documents which


were in his possession, and the answer is that there are not or to the extent there are, they are included in those document requests. There may have been other brief appearances on radio shows or other speaking engagements, but he does not have any transcripts of those in his possession.

Q. To the best of your recollection, would your talk or speech on creation-science given to the National Association of Biology Teachers contain any information different than what is included in your writings?

A. It was longer, so evidently there would be more words, but I think the content of it covered, particularly the article that you are holding now.

Q. You're referencing the DISCOVER article?

A. Yes.

Q. Have any of the other organizations that you are a member of or have been involved with besides the ones we have gone through taken an official position on creation-science?

A. Not that I know of.

Q. How about the AAAS, are you aware of it?


A. I don't think they have, but I don't know for certain. The AAAS, of course, is such a large organization. One is a member to receive the magazine SCIENCE and I am not aware of their official position.

Q. Are you a fellow of —

A. That's an honorary title.

Q. What does it mean?

A. It means that with your document, and 75 cents you can take a ride on the New York subway.

Q. Are you voted on?

A. Yes. You get a little psuedo parchment document in the mail that says you're a fellow and you put it on your CV.

Q. Is that a mark of distinction within the scientific community?

A. It is said to be. I do not regard it as a particularly distinguishing mark thereof.

Q. Do you recall making a remark previously in a speech or a presentation or perhaps at a so-called debate, I don't know if it was a debate or not, on creation-science, that creation-science was not an issue anywhere in the world except in the United States?


A. I have said things like that but not quite in those terms.

Q. What is your position on that?

A. That so far as I know, that in no other western nation - I don't know what's happening in China or Sri Lanka — That in no other Western nation though. I know there are individual creationists and even in England a few societies, but that this is not a major political issue.

Q. Are you aware of as to creation-science or some form of creation model is taught in Canada?

A. I guess I always consider chauvinistic, one tends to consider Canada as an extension of the United States. After all, Montreal almost got into the World Series this year. Yes, I think there's a creationist movement in Canada, and I guess I was lumping Canada with the United States.

Q. Are you aware whether creation-science is taught in the public schools in Canada?

A. I don't know.

Q. And you say this is really not an issue, as I understand it, anywhere but in the United States and Canada?

A. As far as I know it is not a major


political issue that commands media attention.

Q. Now you have said not a political issue. Is it an issue in the scientific community?

A. No.

Q. Are you aware that the, if I have the term right, the Museum of Natural History in London had an exhibit in which creation-science or something similar thereto was presented as an alternative to Darwin's theory of evolution?

A. I am afraid that's a misinterpretation of what was done at the British Museum of Natural History. There was a fairly cautionary put up in one of the exhibit halls that spoke about alternatives, but it was not an equal time exhibit.

Q. But which said that creation-science, if we can use that term, in the general sense at this point, was an alternative theory to evolution?

A. I have the copy of the wording. I don't believe that that's an accurate representation of it. I don't have it with me.

Q. Could you produce that?

A. I could produce it insofar as it is an editorial in NATURE MAGAZINE that talks about this. I believe I have a copy of it and can produce it.


MR. WILLIAMS: If you can produce that, I would appreciate it.

THE WITNESS: However, it was an editorial in NATURE MAGAZINE, which is a fairly common magazine.

Q. If I can have just have a cite.

MR. WILLIAMS: I would like this marked as Defendants' Exhibit 1 to the Gould deposition an article from the May 1981 DISCOVER MAGAZINE entitled "Evolution as Fact and Theory."

(Whereupon, document above referred to was marked as Defendants' Exhibit 1 for identification, as of this date.)

Q. In Exhibit 1, on page 34, the second paragraph you state that "The arousal of dormant issues should reflect fresh data that give renewed life to abandoned notions." And then you go on to state that "The creationists have not a single new fact or argument."

Upon what do you base your belief that the creationists do not have any new facts or arguments?

A. Reading their literature and being aware of what was used in the 1920's in the Scopes


trial, and the literature of that time, particularly by George McCready Price, who was the leader of the creationists in the 20's and 30's.

Q. Could you describe for me the literature that you are talking about, particularly with reference to George McCready Price? I am talking about George McCready Price. What arguments did he forward?

A. I haven't read this material for a while, but they were mainly including what Bryan and others presented at the Scopes trial, primarily arguments about the presumed young age of the earth and gaps in fossil record, et cetera.

Q. Did he talk about the second law of thermodynamics?

A. Who remembers, but —

Q. Do you recall that?

A. I don't remember. It's a pseudo argument. When I say not a single new fact or argument, a literal meaning of argument to me is something that has, I suppose argument is anything that anyone says, there are new words that weren't used before. By "argument," I mean something that has integral substance.


Q. If your statement that the creationists have not a single new fact or argument, if that were not true would your opinion change any on the subject of creation-science?

MR. ENNIS: I didn't understand that question.

THE WITNESS: I didn't either.

Q. One of the first statements that you make in this article is that the creationist have not offered any new facts or new arguments, as I take it —

A. I mean arguments of substance.

Q. I understand that. But if there are in fact new facts since 1925 in the Scopes trial or new arguments, and arguments of substance as you term those, would your opinions be different?

MR. ENNIS: About what?

Q. Your opinions on creation-science as a science.

MR. ENNIS: I don't mean to be obstructive here, but I still don't understand it. It seems to me what you're asking is if in fact there were scientific evidence for creation would you then have a different view.


MR. WILLIAMS: I think the witness' article begins on the premise that there are or there is no new evidence.

A. The main premise of the article is that —

MR. ENNIS: I am sorry. If you can answer the question, I have no objection to your answering the question.

A. I still don't really understand it but the main premise of the article of course is that there is nothing going forth. The main point is not a historical one as to when arguments arose. Like any scientist, when an argument that we haven't heard arises we have to assess it. I am unaware, and I have read a fair amount of creationist literature, of anything that I find in the slightest persuasive.

Q. You use the term creationist literature. What do you include within that term?

A. Here I am using the sentence of those who support the literal interpretation of Genesis as an infallible guide to interpreting the history of life in the earth.

Q. I don't understand your definition or


characterization of creationist literature. You seem to be describing it with reference to the beliefs of the writers, rather than to the implications of the writings.

A. I think that is what the creationist movement represents, and I think the bill specifies that when it talks about the age of the earth and the flood. So it's that body of literature by Gish, Henry Morris and others I regard as the main body of creationist literature.

Q. Have you read Act 590?

A. Yes.

Q. I would like to ask you if you could to look at it again for a moment. And looking at section 4-A, which is the definition of creation-science, before asking you questions about that, from your other testimony I think it's fair to say that you view creation-science as nothing more than a literal interpretation of Genesis under the guise of science?

A. Let me say that creation-science is to me a contradiction of terms. Because creation, in my understanding, refers to the suspension of natural law by some power to place creatures upon


this earth.

Q. First of all, let me ask you then, where in the act is creation-science or creation defined or described in such a way that it necessarily includes the suspension of natural laws?

A. Point one, sudden creation of the universe, energy and life from nothing.

Q. Now that is one part of what creation-science may include. It says, does it not, that creation-science is the scientific evidences for creation and inferences there from. Is that correct?

A. Not exactly in those words. Creation-science includes the scientific evidence and related inferences that indicate, yes.

Q. Is there anything in that sentence which necessarily requires the suspension of natural laws?

A. In vernacular definition, the production of things from nothing is to me miraculous.

Q. In that first sentence.

A. I think so because to me the term


creation-science, defining creation as I do, implicitly refers to miraculous suspension. That's the way I define the miracle of creation.

Q. A miraculous suspension of natural laws?

A. Yes.

Q. That is how you define creation-science?

A. That's the core claim of creation-science as I understand it is the suspension of natural law to place on this earth by the fiat act of a supernatural Creator the kinds of life.

Q. Do you feel like you are familiar with the account of creation given in Genesis?

A. I have read Genesis. I don't know all the exogenical traditions, of course.

Q. Looking at 4-A1, could you tell me if that language is in Genesis?

A. I read Genesis different from creationists. To me it's an allegorical tale of great literary power.

Q. My question is, I think according to your earlier statement that creation-science is derived from a literal reading of Genesis, is that right?


A. As I understand it.

Q. I want you to just look at 4-A1, which says, "the sudden creation of the universe, energy and life from nothing." Is that in Genesis?

A. I don't think it is. Other people do. Remember, any part of the Bible can be read in many different ways.

Q. 2 says, "the insufficiency of mutation and natural selection in bringing about investment of all living kinds from a single organism," is that in Genesis?

A. I'm not aware of that Genesis speaks of mutation. I don't see how it could.

Q. 3 is, "changes only within fixed limits of originally created kinds of plants and animals" does Genesis say that only the kinds have only fixed or — does Genesis say that the living kinds changed only within fixed limits?

A. My answer is really the same to all of these.

MR. ENNIS: Are you asking the witness what his interpretation of Genesis is, or are you asking the witness of his understanding of what the interpretation of Genesis advanced by creation


scientists is?

MR. WILLIAMS: From his earlier testimony I think he said that he had studied the Genesis account of creation. Genesis account of —

MR. ENNIS: I believe his testimony was that he had read the Genesis account of creation, but I don't believe he said he had studied or studied it or read it recently.

THE WITNESS: I said that I am aware that there are many exogenical traditions of it. I certainly know what the words say, but there are so many different interpretations. There is no book that has been more interpretive in a variety of ways than the Bible. There are 100 different interpretations, as you know. I don't quite see what you are getting at.

Q. Your statement I think earlier was that creation-science, besides the point that you think it's a contradiction in terms, that it is also merely a literal account of Genesis, is that correct?

A. It depends upon the claim that Genesis read literally represents the facts of nature. Specifically in points 5 and 6. And if you

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