CIRCUIT COURT OF OREGON
STATE OF OREGON ex rel )
HARDY MYERS, Attorney General )
for the State of Oregon, )
Plaintiff, ) No.
v. ) AFFIDAVIT OF
) PAUL ENGELKING
TRADENET MARKETING, INC., a )
Florida corportation; TOP )
MARKETING BUSINESS CONSULTING )
INCORPORATED, a Florida )
corporation; AMERICAN )
TECHNOLOGIES GROUP, INC., a )
Nevada corportation; and )
L.W. COOPER and ERWIN RICHARD )
ANNAU, individuals, )
STATE OF OREGON )
County of Lane )
PAUL ENGELKING, being duly sworn, deposes and says:
1. I am employed by the University of Oregon as a Professor of
Chemistry. I received my bachelor's degree in chemistry from California
Institute of Technology in 1971, and my Ph.D. from Yale University in
1976. The subjects I teach include Physical Chemistry and Instrumental
Analysis. My research specialties are in the area of spectroscopy of ions
2. I have reviewed Structure Probe Report #34674, Exhibit "1" to the
Affidavit of Andrew W. Blackwood, Ph.D., and the materials authored or
co-authored by Dr. Lo, mentioned in that report. I have also consulted
standard reference materials in my field. The existence of "IE Crystals"
around ions, as described by Dr. Lo, is not supported by theory. One of
Dr. Lo's calculations violates one of the three fundamental laws of
thermodynamics and one of the four fundamental equations of
3. Dr. Lo did not use appropriate controls in his experiments.
Structure Probe used strict controls in the procedures described in its
4. Names of members of the board of directors of American Technologies
Group, Inc. ("ATG"), and their institutional affiliations, appear in
Exhibit "1" to this affidavit. None of the people listed appears to work
in the field of physical chemistry, specifically in the relevant areas of
water or ionic solvation. Instead their affiliations are in the fields of
mathematics, nuclear physics, sewage treatment, and others which do not
necessarily address the questions raised by the publications of Dr.
Shui-Yin Lo. There is thus no reason to believe the training of these
individuals in their fields of specialization would necessarily allow them
to see the contradictions within the literature submitted to prove the
existence of "IE Crystals."
5. I have reviewed the materials attached as Exhibit "2" to this
affidavit, which the Oregon Department of Justice asked me to evaluate for
evidence that "IE" exists. The materials report findings that "IE" has
effects on combustion efficiency, steam cracking of hydrocarbons, and in
6. The experiments described in these documents either do not use
appropriate controls and/or fail to describe the controls clearly. For
example, Dr. Senkan's description of formation of coke deposits in an
engine compares the effects of gasoline, on the one hand, against a
mixture of gasoline, alcohol, and "IE Crystals," on the other. Even
without the "IE Crystals," the two fuel mixtures are considerably
different. In other articles in these materials, so little attention is
given to the description of the controls that it cannot be said that
adequate controls were used, so as to discriminate between the presence or
absence of "IE" and thus isolate the effect, if any, of "IE" alone. These
materials thus do not demonstrate that "IE" exists.
DATED this 28th day of October, 1997.
SUBSCRIBED and SWORN to before me this 28th day of October, 12 1997.
Notary Public for Oregon
Department of Justice
1162 Court Street NE
Salem, Oregon 97310
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