A wide spectrum of critics level this charge: from educators, scientists, and the Smithsonian Institution to individuals who oppose the teaching of creationism alongside science on ideological grounds. The following are the most common areas in which the Institute is accused of intentionally misleading:  Intellectual dishonesty, in the form of misleading impressions created by the use of rhetoric, intentional ambiguity, and misrepresented evidence; and a lack of rigor are the most common criticisms of the Center. Critics have also stated that its goal is to lead an unwary public to reach certain conclusions, and that many have been deceived as a result. Its critics, such as Eugenie Scott, Robert Pennock, and Barbara Forrest, claim that the CSC knowingly misquotes scientists and other experts, deceptively omits contextual text through ellipsis, and makes unsupported amplifications of relationships and credentials. Barbara Forrest, author of "" and Glenn Branch say that the CSC uses academic credentials and affiliations opportunistically. In 2001 the Discovery Institute purchased advertisements in three national publications ("The New York Review of Books", "New Republic" and "Weekly Standard") to proclaim the adherence of approximately 100 scientists to the following statement: "We are skeptical of claims for the ability of random mutation and natural selection to account for the complexity of life. Careful examination of the evidence for Darwinian theory should be encouraged." Such statements usually refer to the institutional affiliations of signatories for purposes of identification. But this statement strategically listed either the institution that granted a signatory's PhD or the institutions with which the individual is presently affiliated. Thus the institutions listed for Raymond G. Bohlin, Fazale Rana, and Jonathan Wells, for example, were the University of Texas, Ohio University, and the University of California, Berkeley, where they earned their degrees, rather than their current affiliations: Probe Ministries for Bohlin, the Reasons to Believe ministry for Rana, and the CSC for Wells. During controversies over evolution education in Georgia, New Mexico, Ohio, and Texas, similar lists of local scientists were circulated. Alongside the allegation that the Center intentionally misrepresents facts, Eugenie Scott and other critics say there is a noticeable conflict between what the CSC tells the public through the media and what they say before conservative Christian audiences. They contend that this is a studied and deliberate attempt at the obfuscation advocated by Wedge strategy author Phillip E. Johnson. Critics can also be found outside of the scientific community. Barry W. Lynn, executive director of Americans United for Separation of Church and State has voiced First Amendment concerns over Discovery Institute's activities.