| 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 | ) | ||
| ) | ss. | ||
| 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 and radicals.
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 electromagnetic theory.
3. Dr. Lo did not use appropriate controls in his experiments. Structure Probe used strict controls in the procedures described in its Report #34674.
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 other areas.
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.
Paul Engelking
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