📄 Cross-examination of Dr. Michael Baden (part 1) — Friday, August 11, 1995
Address:
C:\DEPT103\CRIMINAL\1995\AUG\11\CROSS-EXAMINATION-OF-DR-MICHAE.DOC
TRIAL
▲ Day 134 of 167

Cross-examination of Dr. Michael Baden (part 1)

Witness: Dr. Michael Baden
Examiner: Brian Kelberg
Called by: Defense • Date: Friday, August 11, 1995 • Utterances: 332
Prosecutor Brian Kelberg cross-examines defense forensic pathologist Dr. Michael Baden, focusing on two fronts: challenging Baden's claim that the stomach empties 90-95% of its contents within two hours (which underpins a later time-of-death argument), and attacking Baden's credibility as a paid defense expert with financial and publicity motivations. Kelberg methodically uses Baden's own prior testimony from an unrelated murder case (Bent) and an HBO special to expose inconsistencies and potential bias, while Baden pushes back with experience-based authority and occasional wit.
1 (The following proceedings were held in open court, in the presence of the jury:)
2 THE COURT:

All right. Thank you, ladies and gentlemen. Please be seated. All right. The record should reflect that we've been rejoined by all the members of our Friday morning casual jury. Dr. Michael Baden is on the witness stand. Dr. Baden, would you resume the witness stand, please.

Michael Baden, the witness on the stand at the time of the evening adjournment, resumed the stand and testified further as follows:

3 THE COURT:

All right. Good morning, Dr. Baden.

4 DR. BADEN:

Good morning, Judge.

5 THE COURT:

Doctor, you are reminded, sir, you are still under oath. And, Mr. Kelberg, you may continue with your cross-examination.

6 MR. KELBERG:

Thank you, your Honor. Good morning, ladies and gentlemen.

THE JURY: Good morning.

CROSS EXAMINATION (RESUMED) BY MR. KELBERG

7 MR. KELBERG:

Good morning again, doctor.

8 DR. BADEN:

Good morning, Mr. Kelberg.

9 MR. KELBERG:

Doctor, when we were last in court questioning you, we were talking about your opinion on how the stomach empties. Do you recall that area of inquiry?

10 DR. BADEN:

Yes.

11 MR. KELBERG:

And just to bring it up to speed again, your basic view is that a person's stomach empties approximately 90 to 95 percent of the stomach volume within two hours of the meal having been eaten; is that correct?

12 DR. BADEN:

Of a normal eating person within a reasonable meal.

13 MR. KELBERG:

And you would find, would you not, from your review of the evidence that Nicole Brown Simpson was a normal healthy person at the time of her death?

14 DR. BADEN:

That's correct.

15 MR. KELBERG:

And same for Mr. Goldman?

16 DR. BADEN:

Yes.

17 MR. KELBERG:

And now, doctor, I offered you an opportunity before we started with the jury to review a transcript of your testimony in the bent case; is that correct?

18 DR. BADEN:

Yes.

19 MR. KELBERG:

Did you have an opportunity to review that?

20 DR. BADEN:

I looked at some of the portions, yes.

21 MR. KELBERG:

And I highlighted a couple of areas that I asked you to take a look at, in particular, dealing with the volume of stomach contents of Joan Bent at the time of the autopsy. Did you look at those areas?

22 DR. BADEN:

Yes. I have--I think so. I mean, I looked at a couple of areas. I just want to see what you highlighted.

23 MR. KELBERG:

May I approach again?

24 THE COURT:

You may.

25 MR. KELBERG:

Let me show you what's page 1180 of the transcript at the bottom. Was that one of the areas you looked at, doctor?

26 DR. BADEN:

I haven't, but I will. A thousand cc, yes, a thousand grams.

27 MR. KELBERG:

And I have another highlighted area, I think it's 1206. Would you take a look at that? 1205. Sorry. At the bottom?

28 DR. BADEN:

Yes. Yes.

29 MR. KELBERG:

Now, doctor, is it accurate to say that in the bent case where you formed the opinion that Mrs. Bent had been killed within an hour of having eaten her dinner rather than what her husband said, that she left about two hours after eating dinner not to be seen again, that you found the stomach volume of the contents of the meal to be about a thousand cc's? Is that correct?

30 DR. BADEN:

That's what was reported in the autopsy, yes.

31 MR. KELBERG:

And you did get that material for your review later on when you were brought into the case, correct?

32 DR. BADEN:

I got some of that material, yes, and I examined some of the stomach contents personally.

33 MR. KELBERG:

And you then later on were asked by the attorney for Mr. Bent, the Defendant, how you would describe a thousand cc meal, and you said it would be on the heavy side, correct?

34 DR. BADEN:

Yes.

35 MR. KELBERG:

Now, Nicole Brown Simpson's stomach volume, according to Dr. Golden's report, is 500 cc's, correct?

36 DR. BADEN:

Yes.

37 MR. KELBERG:

About half the volume that was reported in the bent case; is that correct?

38 DR. BADEN:

Yes.

39 MR. SHAPIRO:

Your Honor, I'm going to object. We went over all of this yesterday, the exact same questions.

40 THE COURT:

I think this is foundational for what we're about to--

41 MR. KELBERG:

It is, your Honor.

42 THE COURT:

All right.

43 MR. KELBERG:

Now, doctor, if in fact Nicole Brown Simpson had rigatoni at the Mezzaluna restaurant and had a salad at the Mezzaluna restaurant, left the restaurant about 8:30 to 9 o'clock, say a quarter to 9:00, stopped eating perhaps by 8:30 and did not have rigatoni after getting home, did not have additional salad after getting home and was killed between 10:15 and 10:30 on that same evening or roughly two hours after she left, if your opinion as to how the stomach empties were correct, a finding of 500 cc's in her stomach would have required her to have eaten a meal of approximately 5,000 cc's; isn't that correct?

44 MR. SHAPIRO:

Objection. Improper hypothetical.

45 THE COURT:

Overruled.

46 DR. BADEN:

You're getting there. That's right. She would have had to eaten a huge amount of food, no. 1. No. 2, you left out one important factor in the bent case, is the state of digestion.

47 MR. KELBERG:

I'm going to move to strike as nonresponsive, your Honor.

48 THE COURT:

Overruled. He can explain his answer.

49 DR. BADEN:

The state of digestion is important.

50 MR. KELBERG:

Doctor, my question to you is, would it have required her to have eaten a meal of about 5,000 cc's for your opinion of how the stomach empties to leave 500 cc's in her stomach two hours after she last ate at the time of her death?

51 DR. BADEN:

No.

52 MR. KELBERG:

90 percent of 5,000 cc's is how much, doctor?

53 DR. BADEN:

90 percent would be 4--4500.

54 MR. KELBERG:

And 4500 from 5,000 would leave how much?

55 DR. BADEN:

Yeah. But that's a huge meal. A huge meal doesn't empty in two hours. You're mixing apples and oranges.

56 MR. KELBERG:

Doctor, in the bent case, did you ever testify that a heavy meal does not empty within a two-hour period according to your 90 to 95 percent rule?

57 MR. SHAPIRO:

Your Honor, I'm going to object to Mr. Kelberg badgering Dr. Baden.

58 THE COURT:

Overruled.

59 DR. BADEN:

In the bent case, you're distorting what I said. I relied on the unlack of any digestion of the potato fragments, and that was an important part of my opinion that the food was in the stomach less than an hour. The potato showed no digestion. Page 1187, bottom.

60 MR. KELBERG:

Doctor, my question to you is, you were asked at the bent trial your opinion as to how the stomach normally empties, correct?

61 DR. BADEN:

Yes. I think so.

62 MR. KELBERG:

And referring to page 1180--let me give you the transcript.

63 DR. BADEN:

Thank you.

64 MR. KELBERG:

And you can follow along with me. Under questioning by the Prosecutor, were you asked the following question starting on line 8, page 1180? "Now, doctor, would you tell us or explain to this jury about the digestive process? Once someone consumes food, what happens to that food? "Answer: Yes. In the normal condition, when food is swallowed, taken into the body, within about two hours, the food has undergone preliminary digestion in the stomach and has been moved onto the small intestine so that normally very little food remains in our stomachs after two hours or so. This can be affected by factors such as illness and fright and alcoholism, but is rather an universal manner in which people digest food and how long it stays in the stomach." Did you give that answer in response to that question, sir?

65 DR. BADEN:

Yes.

66 MR. KELBERG:

And, sir, did you qualify that in any way when you listed the factors that may affect the two-hour period by adding the volume of the meal? Did you qualify that answer in any way at that time, sir?

67 DR. BADEN:

Well, can I read--the question was, "Would you tell us what is the basis of your opinion?" I did qualify it, yes.

68 MR. KELBERG:

Sir, my question--

69 DR. BADEN:

My answer to you is, yes.

70 MR. KELBERG:

Did you qualify it in the answer I just read? Did you list that as one of the factors that affects the normal process?

71 DR. BADEN:

The amount of food?

72 MR. KELBERG:

Yes.

73 DR. BADEN:

Yeah. I said in the normal condition. 5,000--five quarts of food is not a normal condition.

74 MR. KELBERG:

You would not expect any human being short of an athlete, a pro athlete perhaps to eat what is 5,000 cc's; isn't that correct?

75 DR. BADEN:

You don't have adult children.

KEY QUOTE
76 MR. KELBERG:

How much is 5,000 cc's?

77 DR. BADEN:

Five quarts.

78 MR. KELBERG:

All right. Doctor--

79 DR. BADEN:

A quart of water--my son drinks a quart of water in two minutes.

80 MR. KELBERG:

Doctor, you described the bent meal of a thousand cc's as a heavy meal; isn't that right?

81 DR. BADEN:

Yes. The thousand cc that's left, yes, a quart.

82 MR. KELBERG:

You did not believe that Nicole Brown Simpson had a 5,000 cc meal at the Mezzaluna restaurant, do you?

83 DR. BADEN:

No. No. I don't think so. No.

84 THE COURT:

Hold on, guys.

85 MR. KELBERG:

I apologize, your Honor.

86 THE COURT:

Both of you, slow down. The jury is only six feet away. They can hear you, Mr. Kelberg.

87 MR. KELBERG:

Thank you, your Honor.

88 THE COURT:

All right?

89 MR. KELBERG:

Maybe I'll move from the microphone.

90 THE COURT:

Why don't we move on. I think we've discussed this point.

91 MR. KELBERG:

I have just a few follow-up questions.

92 MR. KELBERG:

Doctor, in fact, if Nicole Brown Simpson ate at Mezzaluna the rigatoni and the salad, went for some ice cream with her children, came home at around 9:40 or 9:42, made a call to the Mezzaluna restaurant after a call from her mother regarding her missing glasses, the mother's missing glasses, that she was killed between 10:15 and 10:30 without having eaten rigatoni, without having eaten salad, the finding of 500 cc's in her stomach of the food that was described by Dr. Golden would demonstrate that your view of how the stomach normally empties is inaccurate; isn't that correct, sir?

93 MR. SHAPIRO:

Objection to the hypothetical.

94 THE COURT:

Overruled.

95 DR. BADEN:

No.

96 MR. KELBERG:

Dr. Knight does not agree with your view of how the stomach normally empties, does he?

97 DR. BADEN:

Not true. He just summarizes of what a lot of other people say. And I don't know--I haven't spoken to him about it. I've spoken to Dr. Spitz about it, but not to Dr. Knight.

98 MR. KELBERG:

Dr. Spitz you consider a foremost pathologist in the United States?

99 DR. BADEN:

Yes. He's one of the foremost pathologists in the United States. Yes, I would consider that.

100 MR. KELBERG:

And in his book, doesn't he say that if you can recognize identifiable food in the stomach at autopsy, in general, that means the person died within two hours of having eaten the meal, correct? Isn't that what he says?

101 DR. BADEN:

Something like that.

102 MR. KELBERG:

And, doctor--

103 DR. BADEN:

He quotes something like that.

104 MR. KELBERG:

He quotes or that's his statement?

105 DR. BADEN:

I'd have to review it. But there's something to that effect in the book, yes.

106 MR. KELBERG:

May I approach, your Honor?

107 THE COURT:

You may. What page are you referring to?

108 MR. KELBERG:

31. And I've got it boxed in blue, doctor. Are there quotation marks there, doctor?

109 DR. BADEN:

I'll read. "It has been found by others that stomach contents which are readily identified by naked-eye inspection were usually ingested within a two-hour period." I'd agree with that.

110 MR. KELBERG:

Well, doctor, if in fact at autopsy, you find identifiable food in the stomach and that indicates death within two hours, that would be inconsistent with your view that the stomach empties 90 to 95 percent of it's contents within that same two-hour period, wouldn't it, sir?

111 DR. BADEN:

By the end of two hours, most of the food is out in the normal situation, when people are not emotionally upset, et cetera. We don't know about Miss Simpson's state during that two-hour period. I can not tell you--if you're asking me, I can not tell you from the stomach contents the difference between being killed at 10:30 or 10:40 or 10:50. I have not said that and I would not claim that. There's no way of looking at that stomach contents and determining whether Miss Nicole Brown Simpson was murdered 10:15, 10:20, 10:25, 10:30, 10:40, 10:50. I'm not claiming that and I don't want to have to defend it.

112 MR. KELBERG:

My question though, sir, was, Dr. Spitz' statement about if you can identify food in the stomach, it generally indicates death within two hours--

113 DR. BADEN:

Depending on how much food there is. As I said, we can find pieces of food 20 hours later in the stomach.

114 MR. KELBERG:

Your Honor, could I finish the question, please?

115 THE COURT:

Well, the problem is, I've heard the question now, this is the third time.

116 MR. KELBERG:

All right.

117 MR. KELBERG:

Doctor, can you cite any recognized forensic pathology text which supports your contention that the stomach empties generally 90 to 95 percent of its stomach contents within two hours?

118 DR. BADEN:

Sure. Even the Spitz thing you say is--can I read that?

119 MR. KELBERG:

Sure.

120 DR. BADEN:

Within two hours--if it's still--

121 MR. KELBERG:

No. The question is, can you cite any recognized forensic pathology text which says that the stomach empties 90 to 95 percent of its contents within two hours, the view that you expressed in the bent case?

122 DR. BADEN:

Umm, I would be glad to get you references if you'd like, Mr. Kelberg. I don't have it here with me. I have it--you cited my book that you have in front of--that you gave me to look at last night which says that without criticism.

123 MR. KELBERG:

Your book confessions of a medical examiner?

124 DR. BADEN:

Yeah. Yeah. Yeah.

125 MR. KELBERG:

That's not a recognized forensic pathology text, is it, doctor?

126 DR. BADEN:

It's a description of forensic pathology. It's not meant to be a textbook, but there's been no objection to that in--

127 MR. KELBERG:

Well, that was just a repetition of your own view, wasn't it?

128 DR. BADEN:

That's my view, yes.

129 MR. KELBERG:

I'm asking you any recognized forensic pathology text that supports your view that the stomach empties 90 to 95--

130 DR. BADEN:

I will be glad to get that to you. I don't have it with me.

131 THE COURT:

Wait, wait, wait, doctor. Let him finish speaking and asking the question before you start to answer.

132 MR. KELBERG:

Last question. I'm moving on. What forensic pathology text that is a recognized forensic pathology text supports your view that the stomach normally empties 90 to 95 percent of the stomach contents from a meal within two hours of the meal having been eaten?

133 DR. BADEN:

I will get you articles if you wish. That is a commonly recognized view. And it's my experience. This is my experience of 40 years of looking at stomach contents, is that a normal healthy person, it empties within two hours, 95 percent, most of the stomach contents, and that's my opinion.

134 MR. KELBERG:

I'm sorry--

135 DR. BADEN:

And it's been very valid over the years.

136 MR. KELBERG:

Doctor, for that to be valid, you would need to know in each case--

137 THE COURT:

Counsel, we've already asked that question yesterday.

138 MR. KELBERG:

All right. I'll move on.

139 MR. KELBERG:

Doctor, you said something about examining the socks. Do you recall that?

140 DR. BADEN:

Looking at the socks. I didn't examine--I didn't touch the socks. I looked at the socks.

141 MR. KELBERG:

And Dr. Wolf was with you at the time?

142 DR. BADEN:

Dr. Wolf, Miss Kestler, Mr. Vannatter, Detective Vannatter, Lieutenant Rogers were there, yes.

143 MR. KELBERG:

And Dr. Wolf was taking the notes for you or were you taking the notes or were each taking notes?

144 DR. BADEN:

Dr. Wolf was taking notes.

145 MR. KELBERG:

Your Honor, I have a document that's been provided through discovery that has the page from the imprinted sequential numbering, 1022. May that be marked as People's 582 I think we're at?

146 THE COURT:

582.

147 (Peo's 582 for id = document)
148 MR. KELBERG:

May I approach?

149 DR. BADEN:

May I just read from this?

150 THE COURT:

No. We've moved on.

151 DR. BADEN:

We've moved on. Let me just take--because there is something here.

152 MR. KELBERG:

Want a page number?

153 MR. KELBERG:

I'll be glad to let him read it if you want, your Honor.

154 THE COURT:

Let's move on. We've spent enough time with that.

155 MR. KELBERG:

Okay. Doctor, is that one of the notes of the visit that you indicated you and Dr. Wolf used at the LAPD crime lab on June 24th at I believe it's--well, I can't read the time. Let me show you a page and ask--maybe that will refresh your memory as to the time.

156 DR. BADEN:

We began--we arrived about 11:00 A.M.

157 MR. KELBERG:

And does this page refer to the observations of those socks?

158 DR. BADEN:

Yes.

159 MR. KELBERG:

Your Honor, may I ask to put this on the elmo?

160 MR. KELBERG:

And, sir, when you and Dr. Wolf were examining the socks, you were looking for--

161 DR. BADEN:

We didn't examine the socks. We just looked at the socks. We weren't allowed to touch them, pick them up, hold lights to it or to photograph it.

162 MR. KELBERG:

But--

163 DR. BADEN:

Just to inventory it in a sense.

164 MR. KELBERG:

A visual observation is an examination. It may not be a complete examination, but it is an examination, isn't it?

165 DR. BADEN:

Yes. Yes.

166 MR. KELBERG:

And now if we could look at item 13, if Mr. Fairtlough can bring that one into focus. Now, doctor, you see--and maybe Mr. Fairtlough can outline that so we'll have it preserved. Just box in--yeah. Box in item 13. The area that Mr. Fairtlough has just outlined, doctor, is the notation made regarding the socks; is it not?

167 DR. BADEN:

Yes. I believe so.

168 MR. KELBERG:

And what does that say?

169 DR. BADEN:

"No. 13, two dark socks, no analysis yet."

170 MR. KELBERG:

Do you see anything written regarding "No blood observed"?

171 DR. BADEN:

I--we didn't write that down, no. There was no blood observed or else I would have included it.

172 MR. KELBERG:

Well, sir, wouldn't it be important for you to document that in looking at the socks, as far as you were able to see, that you couldn't see blood on them?

173 DR. BADEN:

No.

174 MR. KELBERG:

Doctor--

175 DR. BADEN:

I--I don't document the negatives. I document the positives.

KEY QUOTE
176 MR. KELBERG:

Isn't the negatives sometimes as important as the positive?

177 DR. BADEN:

Can be.

178 MR. KELBERG:

Now, doctor, what does "No analysis yet" refer to?

179 DR. BADEN:

Miss Kestler had told me that no analysis had yet been done on the socks.

180 MR. KELBERG:

And did that--

181 DR. BADEN:

By the Los Angeles Police Department, and we didn't do any further analysis on it.

182 MR. KELBERG:

And did that analysis, as she spoke, was that something you understood to be an analysis looking for things like blood?

183 MR. SHAPIRO:

Objection. Calls for speculation.

184 THE COURT:

Sustained.

185 MR. KELBERG:

What was your understanding of "No analysis yet" as reflected in the notes Dr. Wolf wrote for the two of you?

186 MR. SHAPIRO:

Objection. It's irrelevant, what his understanding was.

187 THE COURT:

Overruled.

188 DR. BADEN:

That no detailed examination had been done.

189 MR. KELBERG:

And--

190 DR. BADEN:

By the LAPD.

191 MR. KELBERG:

For what?

192 DR. BADEN:

For anything. Whatever. When we examine for things, we look for the unexpected.

193 MR. KELBERG:

So you did not do any kind of microscopic examination--

194 DR. BADEN:

I--I'm sorry.

195 MR. KELBERG:

You did not do any kind of microscopic examination of the socks; is that correct?

196 DR. BADEN:

I was not allowed to touch the socks. That's correct.

197 MR. KELBERG:

And they weren't turned inside out for you by anyone at the time you and Dr. Wolf were looking at them with the naked eye?

198 DR. BADEN:

That's correct.

199 MR. KELBERG:

What was the lighting like at the time of your observations?

200 DR. BADEN:

Not very bright. It was a little better than the--better lighting than here presently, but not very bright.

201 MR. KELBERG:

Not what you would describe as the kind of ideal lighting for conducting a close visual examination of something like a dark pair of socks?

202 DR. BADEN:

Yes. That's fair.

203 MR. KELBERG:

There was no high intensity lighting, was there?

204 DR. BADEN:

That's correct.

205 MR. KELBERG:

And high intensity lighting is the kind of lighting that you would like to have when conducting a close visual inspection of an item like black socks, right?

206 DR. BADEN:

That's correct, yes.

207 MR. KELBERG:

Let's see. I think we're done with that. If we could print that out. I don't know if the red lines print out.

208 THE COURT:

Yes. That will be 582-A.

209 MR. KELBERG:

Thank you, your Honor.

210 (Peo's 582-A for id = printout)
211 MR. KELBERG:

Now, doctor, I wanted to go into this issue of interpretation. Forensic pathologists do interpretation, crime scene reconstruction. That's interpretation; is it not, sir?

212 DR. BADEN:

The criminalist does crime scene interpreta--interpretation. The forensic pathologist examines the body in the context of the crime scene. There's a certain amount of interpretation, but not to the extent that a criminalist would do.

213 MR. KELBERG:

Well, for example, when you offered opinions about the extent of a struggle between Ronald Goldman and any perpetrator or perpetrators, that was interpretation of the findings that the forensic pathologist makes. Isn't that what you do?

214 DR. BADEN:

That's correct. To that extent, yes.

215 MR. KELBERG:

And interpretation by you or any other forensic pathologist to some degree employs simple common sense, doesn't it, sir?

216 DR. BADEN:

Well, includes common sense, but includes mixed with some expertise or else it's no more valuable than common sense.

217 MR. KELBERG:

And logic plays a role in the interpretations that you draw?

218 DR. BADEN:

Yes.

219 MR. KELBERG:

Would you agree that interpretation such as you offered yesterday is more of a subjective process than necessarily an objective process?

220 MR. SHAPIRO:

Objection, your Honor. Calls for speculation.

221 THE COURT:

Overruled.

222 DR. BADEN:

You'd have to give me a--the specific issue you're alluding to. It varies.

223 MR. KELBERG:

Well, doctor, for example, in the science field, the term "Reliability" is familiar to you; is it not, sir?

224 DR. BADEN:

Yes.

225 MR. KELBERG:

And doesn't that mean reproducibility?

226 DR. BADEN:

Yes.

227 MR. KELBERG:

That means--

228 DR. BADEN:

It can mean that.

229 MR. KELBERG:

--if two people are doing some form of testing, if the test is a reliable test, the two people should reach the same conclusion from the same test that is performed by the two of them?

230 DR. BADEN:

It depends whether you're using a very scientific interpretation or a more general interpretation. And when doing experiments, when doing an experiment in a laboratory, reproducibility is--can be equated to reliability. But in common discussion, reliability can have a little different meaning.

231 MR. KELBERG:

Well, I'm talking to you as a scientist, doctor. Do you consider yourself to be a scientist?

232 DR. BADEN:

No. I'm a physician.

233 MR. KELBERG:

Well, isn't a physician a form of a scientist?

234 DR. BADEN:

Art and science to medicine.

235 MR. KELBERG:

Isn't interpretation more an art than a science?

236 DR. BADEN:

Among--in medicine, that's probably true.

237 MR. KELBERG:

And as an art, isn't that suggesting then that the process is subjective rather than objective in the sense that two people can look at the very same set of circumstances and draw different conclusions, not the same conclusions?

238 DR. BADEN:

That's true. That two people--two physicians can look at the same set of circumstances and draw different conclusions, and I guess that suggests a subjectivity to it, yes.

239 MR. KELBERG:

And with subjectivity comes the possibility of bias; isn't that correct, sir?

240 DR. BADEN:

Oh, sure. Yes.

241 MR. KELBERG:

Now, doctor, when you are retained by a Defense attorney in a criminal case, you understand that there are privileges that attach to whatever you do and find such that you may not disclose those findings unless the lawyer authorizes you to do so or through the litigation is required to have that disclosed. Isn't that your understanding, sir?

242 MR. SHAPIRO:

Objection, your Honor. That calls for a legal conclusion that is beyond his expertise.

243 THE COURT:

Overruled.

244 MR. KELBERG:

You may answer the question.

245 DR. BADEN:

Yeah. I'm not--as we--as you showed yesterday, I'm not a lawyer, and that's a complicated question. I know that there are some things that are considered work product or privileges that I'm constrained from talking about, but that goes with Prosecutors also, all lawyers, when I work with Defense attorneys or with Prosecuting attorneys.

246 MR. KELBERG:

Doctor--

247 DR. BADEN:

What that extends to, I would have to ask the attorney as to what I can talk about, what I can't talk about. But usually it doesn't come up.

248 MR. KELBERG:

Doctor, you understand there is a fifth amendment privilege that prevents you from disclosing what your findings are if you're not going to be called as a witness by the Defense when you're retained by the Defense?

249 MR. SHAPIRO:

Objection.

250 THE COURT:

Sustained.

251 MR. SHAPIRO:

May we approach, your Honor?

252 THE COURT:

No. Sustained.

253 MR. KELBERG:

Doctor, you understand that unless you find favorable findings to a criminal Defendant who retains your services, the likelihood is, you will not be called to the witness stand; isn't that correct, sir?

254 MR. SHAPIRO:

Objection. Calls for speculation.

255 THE COURT:

Overruled.

256 DR. BADEN:

In general, I am aware that if my findings are contrary to the theory of the Prosecutor or the Defendant, they're not likely to call me as a witness, yes. But it works for both sides, not just for one side.

257 MR. KELBERG:

Excuse me, doctor. If your findings are contrary to the view of the Prosecution and you have been retained by the Defendant, it would be logical that you would be called by the Defense attorney just as you've been called here to try and refute the Prosecution theory. Isn't that your understanding?

258 MR. SHAPIRO:

Objection. Argumentative.

259 THE COURT:

Sustained.

260 MR. KELBERG:

Doctor, isn't it your understanding--and please listen to the question carefully--your understanding--

261 MR. SHAPIRO:

Objection, your Honor. I think that's improper.

262 THE COURT:

Overruled.

263 MR. KELBERG:

--your understanding that unless--when you're retained by a criminal Defendant's lawyer, unless your findings are favorable or helpful to that Defendant, you will not be called by that Defendant's lawyer to testify at any trial. Isn't that your understanding?

264 DR. BADEN:

That generally is the way it works with all lawyers. With all lawyers.

265 MR. KELBERG:

But, doctor, when you're retained by the Prosecution, isn't it also your understanding that the Prosecution is obligated constitutionally to turn over to the Defendant, the criminal Defendant, your findings even if your findings are not helpful to the Prosecution?

266 MR. SHAPIRO:

Objection, your Honor. That's a question of law and a question of ethics.

267 THE COURT:

Let's not pursue this area.

268 MR. KELBERG:

All right, your Honor.

269 MR. KELBERG:

Doctor, would you agree that if you want to testify in court in a high publicity case, it helps for you to have findings that are favorable to the side that have retained your services?

270 MR. SHAPIRO:

Objection, your Honor. It's argumentative.

271 THE COURT:

Overruled.

272 DR. BADEN:

Could you repeat that, please, Mr. Kelberg?

273 MR. KELBERG:

Your Honor, may I have a moment to try and read it back? I would like the--

274 THE COURT:

Doctor, would you agree that if you wanted to testify in court in a high publicity case, it helps for you to have findings that are favorable to the side that has retained your services?

275 DR. BADEN:

No. 1, I do not wish to testify in court. But if I should have the desire to testify in court, I guess what you say is correct. But I would much prefer not to be here, Mr. Kelberg.

KEY QUOTE
276 MR. KELBERG:

Doctor, are you familiar with a special on HBO, Home Box Office called Autopsy Confessions of a Medical Examiner?

277 DR. BADEN:

Yes, I am.

278 MR. KELBERG:

And how are you familiar with that program?

279 DR. BADEN:

It was a program emanating from the book I wrote that you have in which I narrated. It had to do with a number of my--the cases I was involved with, and HBO made a special about it to demonstrate autopsies and findings.

280 MR. KELBERG:

And, doctor, was there a premier for this special, a special kind of gala presentation?

281 DR. BADEN:

Well, there was some kind of in-house HBO cocktail party when it was--the first night that it was shown. It's been shown many times, but the first night, they had some kind of a cocktail party.

282 MR. KELBERG:

Doctor, would it be fair to say that this special puts you in a very favorable light?

283 DR. BADEN:

I think the HBO program was about cases that I was involved with and was favorable to me, yes, I guess.

284 MR. SHAPIRO:

We have no objection to this document.

285 DR. BADEN:

I cooperated with it.

286 MR. KELBERG:

Well, doctor in fact, the special--

287 MR. KELBERG:

Your Honor, may the--I have a videotape. May that be marked as 583?

288 THE COURT:

For identification purposes at this point.

289 MR. KELBERG:

Yes.

290 (Peo's 583 for id = videotape)
291 MR. SHAPIRO:

Your Honor, can we also mark the document that Mr. Kelberg--

292 MR. KELBERG:

I'm going to use it, Mr. Shapiro. Trust me.

293 THE COURT:

Proceed.

294 MR. KELBERG:

And I'll ask that one-page document be marked as exhibit 584.

295 MR. SHAPIRO:

If he's going to use the videotape, your Honor, there is a procedure that your Honor--

296 THE COURT:

We're not there yet.

297 (Peo's 584 for id = document)
298 MR. KELBERG:

May I approach, your Honor?

299 THE COURT:

You may.

300 MR. KELBERG:

Let me show you, doctor, 584. Are you familiar with that document?

301 DR. BADEN:

No, I'm not.

302 MR. KELBERG:

Doctor, would you read to us how the document starts?

303 MR. SHAPIRO:

Your Honor, there is no foundation.

304 THE COURT:

Foundation? Sustained.

305 MR. KELBERG:

You never saw this document until I just showed it to you, doctor?

306 DR. BADEN:

I've never seen that document. I'm familiar with what it says, but I've never seen that document, no. It was not sent to me.

307 MR. KELBERG:

Were you asked to be basically a co-host of this premier, of your HBO special?

308 DR. BADEN:

No. I was there. I was there. They had a--they made a--you know, a fuzz about it. They had a cocktail party and I was there, yes.

309 MR. KELBERG:

Doctor, I believe you said yesterday that perhaps of your total annual income, you said 39- or 40,000 comes from your relationship with the Albany state police, correct? New York state police. Excuse me.

310 DR. BADEN:

Yes. My position with the New York state police, yes.

311 MR. KELBERG:

Part-time position. And about four times that amount is brought in annually from your privately retained cases; is that correct?

312 DR. BADEN:

Yes.

313 MR. KELBERG:

Doctor, was it your expectation that by having this HBO special, it would generate further business for you, sir?

314 DR. BADEN:

No, Mr. Kelberg. It was my expectation that that special would help educate people and the public about what medical examiners do, what forensic pathology is all about and why we need reform in this country, to have a uniform system of forensic pathology investigation that doesn't exist. And that was the main thrust of my involvement with HBO. And we're doing another one because it was very successful. But it was not done because I wanted more business.

315 MR. KELBERG:

Doctor, wasn't the first case that was used the bent case?

316 DR. BADEN:

The bent case I believe was involved, yes. That was one of the cases they referred to with the importance of stomach contents and importance that medical examiners and police, when they go to a scene, they find out what the last meal was, what's in the refrigerator, what's in the stove, what's in the garbage so it can be then compared with the autopsy findings and that the stomach contents should be looked at. In most autopsies in this country, the stomach contents are ignored.

317 MR. KELBERG:

Doctor, my question is, wasn't that the first case that was on the special?

318 DR. BADEN:

I said I don't know. It was in the special. I don't know if it was the first case.

319 MR. KELBERG:

How many times have you watched that special, if at all?

320 DR. BADEN:

Twice. Once. Once at the premier and once afterwards I think.

321 MR. KELBERG:

Now, doctor, case file numbers were given to each of your cases that was described in the special; isn't that correct?

322 DR. BADEN:

Yes.

323 MR. KELBERG:

What was the case file number for the bent case?

324 DR. BADEN:

I don't know.

325 MR. KELBERG:

If it was approximately 500 and something, would that sound right?

326 DR. BADEN:

Whatever it says, it says. That was--the case file numbers was artistic license taken by HBO.

327 MR. KELBERG:

Well, that's what I wanted to ask you. If it said, for example, that it was Baden case file 506, was that in fact a case file no. 506 of Michael Baden?

328 DR. BADEN:

No, it was not.

329 MR. KELBERG:

And you said you've done over 20,000 autopsies, right?

330 DR. BADEN:

Yes.

331 MR. KELBERG:

So with respect to any of the cases that were used, any that was used in the special with a case file number, that was all made up, right?

332 DR. BADEN:

No. I don't save and retain every case--every death I investigate. There were a number of deaths over the years that I've retained because I think they're instructive and formative mostly for the textbook that I'm involved with. But of the 20,000 cases, there may be a few hundred that I think will be informative and the cases and the photographs and the information usable in a textbook.

Temperature

tense

Key Quotes (5)

Dr. Michael Baden
I can not tell you from the stomach contents the difference between being killed at 10:30 or 10:40 or 10:50. I have not said that and I would not claim that. There's no way of looking at that stomach contents and determining whether Miss Nicole Brown Simpson was murdered 10:15, 10:20, 10:25, 10:30, 10:40, 10:50. I'm not claiming that and I don't want to have to defend it.
Baden retreats from precision, effectively conceding that stomach contents cannot pinpoint time of death to the narrow windows the defense implied — a significant concession under Kelberg's relentless hypotheticals.
Dr. Michael Baden
You don't have adult children.
Baden's quip when Kelberg suggests no human being could eat 5,000cc — a rare moment of levity that also reveals Baden's combative confidence under pressure.
Dr. Michael Baden
That is a commonly recognized view. And it's my experience. This is my experience of 40 years of looking at stomach contents, is that a normal healthy person, it empties within two hours, 95 percent, most of the stomach contents, and that's my opinion. And it's been very valid over the years.
When pressed to cite a recognized forensic pathology text supporting his 90-95% rule, Baden falls back entirely on personal experience — exactly the weakness Kelberg was exposing.
Dr. Michael Baden
No. 1, I do not wish to testify in court. But if I should have the desire to testify in court, I guess what you say is correct. But I would much prefer not to be here, Mr. Kelberg.
Baden's admission, under Kelberg's bias attack, that findings favorable to the retaining side help an expert get called — while simultaneously expressing exasperation at the examination itself.
Dr. Michael Baden
I don't document the negatives. I document the positives.
Baden's explanation for why his June 24 sock observation notes contain no entry for 'no blood observed' — a principle Kelberg immediately challenges as selectively convenient.

Evidence (7)

People's 582
Notes from Baden and Dr. Wolf's June 24 visit to LAPD crime lab, page 1022 of sequentially numbered document — shows sock observation entry reading 'No. 13, two dark socks, no analysis yet' with no notation of blood absence
introduced and displayed on ELMO to challenge Baden's claim that socks showed no blood
People's 582-A
Printout of the ELMO display of the sock notation from People's 582
preserved as exhibit
People's 583
Videotape of HBO special 'Autopsy: Confessions of a Medical Examiner' featuring Baden
marked for identification, not yet played
People's 584
One-page document related to the HBO special premier — Baden says he has never seen it
marked for identification; foundation objection sustained, not admitted
Informal
Bent case trial transcript, pages 1180, 1187, 1205-1206 — Baden's prior testimony about stomach emptying and the 1,000cc meal in that case
read into record to impeach Baden's stomach-emptying opinion
Informal
Dr. Werner Spitz's forensic pathology textbook, page 31 — passage stating identifiable stomach contents 'usually ingested within a two-hour period'
used to challenge internal consistency of Baden's 90-95% emptying rule
+ 1 more

Notable Exchanges (5)

Brian KelbergDr. Michael Baden
Extended battle over the stomach-emptying math: Kelberg walks Baden through arithmetic showing that for 500cc to remain after two hours using Baden's 90-95% rule, Nicole would have needed a 5,000cc meal. Baden resists, insisting huge meals don't empty at the same rate and that 'you're mixing apples and oranges,' but eventually concedes he cannot pinpoint time of death precisely from stomach contents.
heated
Brian KelbergDr. Michael Baden
Kelberg attacks Baden for being unable to cite any recognized forensic pathology text supporting his 90-95% stomach-emptying rule, forcing Baden to offer only personal experience and a promise to 'get you articles.' Kelberg then dismisses Baden's own book as merely a repetition of his own view.
strategic
Brian KelbergDr. Michael Baden
Kelberg explores Baden's financial motivations via the HBO 'Autopsy' special, questioning whether it was designed to generate business. Baden deflects with an educational mission rationale and notes a follow-up special is in production.
strategic
Brian KelbergDr. Michael Baden
Kelberg pursues the structural bias argument — that defense-retained experts are only called when findings favor the defense, unlike prosecution experts who must disclose unfavorable findings constitutionally. Ito shuts down the constitutional disclosure line after a sustained objection from Shapiro.
revealing
Brian KelbergDr. Michael Baden
Kelberg uses Baden's June 24 sock observation notes to challenge the significance of Baden's claim of no visible blood on the socks — the notes say only 'no analysis yet' with no 'no blood observed' entry. Baden explains he only documents positives, not negatives.
strategic

Light Moments (5)

Dr. Michael Baden
When Kelberg suggests no normal human would eat 5,000cc of food, Baden shoots back: 'You don't have adult children.'
Dr. Michael Baden
Baden elaborates: 'A quart of water — my son drinks a quart of water in two minutes.'
Lance A. Ito
Judge Ito interrupts a rapid-fire exchange: 'Hold on, guys' — then admonishes Kelberg that the jury is only six feet away and can hear him without the microphone.
Dr. Michael Baden
Baden, asked if he wants to testify in high-profile cases, says: 'No. 1, I do not wish to testify in court... I would much prefer not to be here, Mr. Kelberg.'
Brian Kelberg
Shapiro, apparently having been waiting to introduce a document himself, interjects during the HBO exhibit marking: 'Can we also mark the document that Mr. Kelberg—' Kelberg cuts him off: 'I'm going to use it, Mr. Shapiro. Trust me.'

Credibility Attacks (5)

⚔ Dr. Michael Baden
prior inconsistent statement / prior testimony
Kelberg uses Baden's own testimony from the Bent murder trial to show he previously described stomach emptying without qualifying for meal volume — and that the 1,000cc Bent meal he called 'heavy' is far smaller than what his math would require for Nicole's 500cc finding.
⚔ Dr. Michael Baden
lack of authoritative support
Kelberg presses Baden to name any recognized forensic pathology text supporting his 90-95% two-hour emptying rule. Baden cannot produce one, citing only his own book (dismissed as self-referential) and a promise to provide articles later.
⚔ Dr. Michael Baden
financial bias / self-promotion
Kelberg questions Baden about the HBO 'Autopsy' special, suggesting it was designed to generate private consulting business. Baden earns roughly four times his state salary from private retained cases.
⚔ Dr. Michael Baden
structural bias of defense-retained expert
Kelberg elicits Baden's admission that defense-retained experts are generally only called to testify when their findings favor the defendant — contrasting this with the prosecution's constitutional obligation to disclose even unfavorable expert findings.
⚔ Dr. Michael Baden
incomplete/selective documentation
Kelberg shows Baden's June 24 sock observation notes contain no entry for 'no blood observed,' undermining Baden's earlier testimony that the socks showed no visible blood. Baden's explanation — 'I don't document the negatives' — is challenged as a convenient omission.

Witness Demeanor

Baden is combative and resistant throughout, frequently interrupting questions to qualify or reframe answers before the question is finished
Baden repeatedly tries to volunteer information beyond the question's scope — Ito warns him multiple times to wait for the question to finish
Baden displays visible frustration with the stomach-emptying line of questioning, at one point saying 'you're distorting what I said'
Baden maintains composure and occasional dry wit despite sustained pressure

Objections

14 objections (4 sustained, 9 overruled)
Proceeding 7280 • 332 utterances • Defense witness
Criminal Trial
Department 103
⚖️ Start
📂 AUG 11, 1995 📄 Cross-examination of Dr. Micha
AUG 11, 1995 KRT DvH TD