📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 1) — Monday, June 12, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\12\DIRECT-EXAMINATION-OF-DR-LAKSH.DOC
TRIAL
▲ Day 93 of 167

Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 1)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Monday, June 12, 1995 • Utterances: 816
Dr. Lakshmanan continued his direct examination under Kelberg, systematically cataloging injuries 5 through 12 found on Ron Goldman's neck, ear, and jaw areas in photographs G-51 and G-53. He methodically compared his own findings against Dr. Golden's original autopsy protocol and addendum, repeatedly noting Golden's errors in diagramming and classifying wounds while consistently emphasizing that none of these mistakes affected the 'big ticket' questions of cause of death, manner of death, or knife characterization. A notable moment occurred when Lakshmanan added that a rough glove — not just a fingernail — could have caused a particular abrasion on Goldman.
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. Let the record reflect we have been rejoined by all the members of our jury panel. Good afternoon, ladies and gentlemen.

THE JURY: Good afternoon.

3 THE COURT:

All right. Dr. Lakshmanan, would you resume the witness stand, please.

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

4 THE COURT:

However briefly. Let the record reflect that Dr. Lakshmanan is again on the witness stand. Good afternoon, doctor.

5 DR. LAKSHMANAN:

Good afternoon, your Honor.

6 THE COURT:

Thank you for returning with us this afternoon. And doctor, sir, you are reminded you are still under oath. And Mr. Kelberg, you may continue with your direct examination.

7 MR. KELBERG:

Good afternoon, ladies and gentlemen.

THE JURY: Good afternoon.

8 MR. KELBERG:

And to you, doctor.

DIRECT EXAMINATION (RESUMED) BY MR. KELBERG

9 MR. KELBERG:

Doctor, I want to do a little more follow-up regarding the two juries that you talked about at the end of Friday's testimony which are reflected--are demonstrated in photographs G-51 and one of which is better shown in a close-up in G-53 and these are the injuries which Dr. Golden originally described, in essence, as one wound going in where we have injury no. 1 by your designation of G-51, and exiting what you have as injury no. 2 and also nicking the ear which you have described, I believe, as injury no. 3 of that photograph; is that correct?

10 DR. LAKSHMANAN:

Yes.

11 MR. KELBERG:

And again the Court was correct, I don't think you get to sit very long. If you could step to the board and perhaps bring the pointer that is behind you--

12 THE COURT:

And Mr. Kelberg, we are referring to 358?

13 MR. KELBERG:

Exhibit 358, yes, your Honor.

14 THE COURT:

All right.

15 MR. KELBERG:

Doctor, your opinion, as I believe you testified last week, was that these are separate sharp force injuries, injuries no. 1 and no. 2; is that correct?

16 DR. LAKSHMANAN:

Yes.

17 MR. KELBERG:

And as I recall your testimony also, injury no. 2 is described by you as entering in the area shown in the photograph where Dr. Golden describes it, in essence, as exiting; is that correct?

18 DR. LAKSHMANAN:

Yes.

19 MR. KELBERG:

What leads you to form the opinion that that is where the knife entered rather than the knife exiting?

20 DR. LAKSHMANAN:

That is because of the appearance of both the wounds. If you had a knife which entered here on the left side of the neck, (indicating), and came out here at this point behind the ear, (indicating), when this ripping of the skin is caused you would expect more cutting of the skin on this part, that is the outer part of this wound, which really doesn't show any cut in the depth wound. It only shows mostly like a bridge going. The cut is mostly on the surface. As I already mentioned, this is a complex wound caused by different penetrations on a preexisting cut or it could have been a separate penetration without a preexisting cut, but in my opinion this is a separate wound, (indicating), this is a separate wound, (indicating). This wound to the left ear could be related to this wound as I explained I think two days ago, and the--also the directions are different for--which supports my opinion.

21 MR. KELBERG:

For the record, your Honor, when the witness was initially talking about the appearance of the surface cutting, he was referring to injury no. 1 of G-51, and when he was referring to the direction, he was referring initially to injury no. 2 and then back to injury no. 1. May the record so reflect?

22 THE COURT:

Yes. Thank you.

23 MR. KELBERG:

Doctor, in your review of the evidence in this case, did you also review testimony given by Dr. Golden before the Los Angeles County Grand Jury on June 20th of 1994?

24 DR. LAKSHMANAN:

Yes, I did.

25 MR. KELBERG:

And inviting counsel, if they are so inclined, to page 114 of the grand jury transcript, and in particular beginning line 1 of that page and continuing on to page 115, and on to page 116, doctor, did you review this testimony from Dr. Golden?

26 DR. LAKSHMANAN:

Yes, I did.

27 MR. KELBERG:

"Question: I'm focusing now on the injury which appears to be a rather large hole in the left side of the neck." And you interpreted that, doctor, to refer to what is described as injury no. 1; is that correct, of G-51?

28 DR. LAKSHMANAN:

Yes.

29 MR. KELBERG:

And the answer is "Yes." "Question: Approximately how large was that particular wound? "Answer: That wound was three inches in length. It was a gaping, as you can see, wound, and after putting it together it was three inches in length, tapering as you--if you taper it here, tapering where I indicated towards the back of the neck where it involves just the skin.

"Question: Would you describe that wound as a cutting wound or stabbing wound or both? "Answer: Well, it appears to be a combination of stabbing and cutting wounds. "Question: Now, it appears to be a deep wound and I can see why you call that a stabbing wound. Can you tell us why it is that you also described that as a cutting wound? "Answer: Well, first of all, it is very wide, so it is compatible with a narrower blade that is also cutting the skin. Also, it appears to taper into that area which indicates that this may have been a slicing component also. It is a stab wound. It goes into the neck and connects with another wound behind the left ear which is at a distance of approximately four inches from that first wound." Doctor, you interpret that last reference to be to what is described as injury no. 2?

30 DR. LAKSHMANAN:

That's correct.

31 MR. KELBERG:

Incidentally, these questions you read were from a Deputy District Attorney from the name of Mr. Conn, C-O-N-N?

32 DR. LAKSHMANAN:

Yes.

33 MR. KELBERG:

Continuing the answer: "So it appears that it is at least four inches deep. "Question: So what you are saying is that this wound going into the neck is connected to this wound coming out on the left side on the back side of the left ear? "Answer: Yes. Of course I can't unequivocally say which one came first. It also appears that the one on the lower neck came first, but it is also possible that it came from downward and came out, depending on how the neck was held, but they do connect. "Question: And there also appears to be in this photograph an injury to the ear where the ear is cut." And did you interpret that, doctor, to refer to this injury, I believe you described it as injury no. 3 of photograph G-51?

34 DR. LAKSHMANAN:

I think it is injury no. 4.

35 MR. KELBERG:

Or no. 4?

36 DR. LAKSHMANAN:

No. 4 I did.

37 MR. KELBERG:

Injury no. 4?

38 DR. LAKSHMANAN:

Yes.

39 MR. KELBERG:

And continuing on in the question: "Can you determine at all whether that injury to the ear was part of the--of one continuous movement from the neck into the back of the ear and then up to the ear? "Answer: Yes. I made an assumption by placing a rod or probe along the entire length there. They all connected up. So it is possible that one stabbing motion caused all three of those, which would make it about a six-inch long wound. In other words, from here, if I include this earlobe cut --correction, not earlobe but the ear cut--if the ear cut and this and this are all connected, there is approximately a six-inch long stabbing wound and that is the completion actually of the testimony regarding the relationship if any between these." Doctor, in your opinion is Dr. Golden's testimony in that area an erroneous opinion?

40 DR. LAKSHMANAN:

Yes.

41 MR. KELBERG:

For the same reasons that you described with respect to how the addendum came to reflect a change to two separate wounds?

42 DR. LAKSHMANAN:

Yes.

43 MR. KELBERG:

Is this a mistake, doctor, that you consider significant to you in evaluating the big ticket questions?

KEY QUOTE
44 DR. LAKSHMANAN:

No.

45 MR. KELBERG:

For the same reasons as you explained last Friday on them same area?

46 DR. LAKSHMANAN:

Yes.

47 MR. KELBERG:

Now, doctor, I don't believe we finished evaluating any injuries of G-51 beyond injuries 1, 2, 3 and 4; is that correct?

48 DR. LAKSHMANAN:

Yes.

49 MR. KELBERG:

Can you take us through what, if any, additional injuries you see in that photograph and then we will go through a description of each and any additional information and then we will go to the protocols and so forth on those.

50 DR. LAKSHMANAN:

Yes. There is also a cut to the left earlobe. There is a cut to the left ear here, (indicating). This is a cut abrasion to the--part of the ear behind the ear canal. There is a triangular abrasion to the left side of the jaw. There is another linear interrupted cut to the left angle of the jaw here, (indicating). And there are some smaller abrasions to the left side of the chin which would complete all the injuries in this photograph.

51 MR. KELBERG:

Have you again arbitrarily numbered these additional injuries that you have just described as numbers 5 through whatever the last number would be for--

52 DR. LAKSHMANAN:

Yes, through 12 I think. Just a moment.

53 (Brief pause.)
54 DR. LAKSHMANAN:

I numbered them up to 12.

55 MR. KELBERG:

All right, doctor. Let's go individually, if we can. Injury no. 5 in photograph G-51 is which injury?

56 DR. LAKSHMANAN:

That is the one to the earlobe, (indicating).

57 MR. KELBERG:

And what kind of injury is that, doctor?

58 DR. LAKSHMANAN:

That is a cut to the earlobe.

59 MR. KELBERG:

And in your evaluation were you able to determine the instrument or nature of how that cut was inflicted?

60 DR. LAKSHMANAN:

It is a sharp force injury.

61 MR. KELBERG:

And doctor, from what you saw, were you able to say whether or not it was only from a single-edged knife or could it have been from either a single-edge or a double-edge?

62 DR. LAKSHMANAN:

It could have been from either.

63 MR. KELBERG:

What told you that that was the case?

64 DR. LAKSHMANAN:

Because it is just a cut, and as I mentioned earlier when we discussed in general about sharp force injuries, you cannot tell the difference when you just have a cut.

65 MR. KELBERG:

From your observation of it and any review of Dr. Golden's protocol information, how deep was that cut?

66 DR. LAKSHMANAN:

It is a cut to the earlobe, so it is just a cut. It is not--depth has not been described.

67 MR. KELBERG:

And doctor, in that area, how deep is the earlobe?

68 DR. LAKSHMANAN:

It is less than a quarter inch.

69 MR. KELBERG:

Doctor, are you able to determine whether that injury was received before death, at or around the time of death or after death?

70 DR. LAKSHMANAN:

Before death.

71 MR. KELBERG:

What led you to that conclusion?

72 DR. LAKSHMANAN:

The appearance.

73 MR. KELBERG:

What about the appearance?

74 DR. LAKSHMANAN:

The bleeding that you can see in some of the scene photographs also.

75 MR. KELBERG:

Doctor, can you keep your voice up.

76 DR. LAKSHMANAN:

The crime scene photographs also you can see the wound.

77 MR. KELBERG:

You have looked at all of the crime scene photographs?

78 DR. LAKSHMANAN:

Yes.

79 MR. KELBERG:

Concerning the bodies as found?

80 DR. LAKSHMANAN:

Yes.

81 MR. KELBERG:

And in those you saw what was of significance to you on this issue of whether or not that was received before death?

82 DR. LAKSHMANAN:

Because you have evidence of blood over the area and also the reddish appearance which is antemortem.

83 MR. KELBERG:

Doctor, is there anything about the position of that cut that gives you any information regarding the relative position of Mr. Goldman and the perpetrator?

84 DR. LAKSHMANAN:

No.

85 MR. KELBERG:

Is there anything else, as far as a description of that particular cut goes?

86 DR. LAKSHMANAN:

Nothing else.

87 MR. KELBERG:

Doctor, did Dr. Golden address that injury no. 5 in the autopsy protocol?

88 DR. LAKSHMANAN:

Yes, he did.

89 MR. KELBERG:

Did he diagram it in any of the available forms?

90 DR. LAKSHMANAN:

He did.

91 MR. KELBERG:

Was it addressed in any of the addendum?

92 DR. LAKSHMANAN:

No.

93 MR. KELBERG:

In your opinion was there any reason to?

94 DR. LAKSHMANAN:

No.

95 MR. KELBERG:

Did he accurately describe and diagram it?

96 DR. LAKSHMANAN:

Yes.

97 MR. KELBERG:

Anything else before we move to injury no. 6?

98 DR. LAKSHMANAN:

Nothing else.

99 MR. KELBERG:

Injury no. 6 then is which one, doctor?

100 DR. LAKSHMANAN:

Injury no. 6 is the cut to the left ear here, (indicating).

101 MR. KELBERG:

If I could just duck under you for one second, doctor.

102 MR. KELBERG:

Would you point again.

103 DR. LAKSHMANAN:

(indicating).

104 MR. KELBERG:

Now, doctor, this is a different cut than the cut you previously referred to as injury no. 4; is that correct?

105 DR. LAKSHMANAN:

Injury no. 4 is to the edge of the ear. This cut is to the side of the ear behind the ear canal there.

106 MR. KELBERG:

Your Honor, may the record reflect that this new injury no. 6 is slightly to the left and below what was previously described as injury no. 4.

107 THE COURT:

Yes.

108 MR. KELBERG:

Now, doctor, again, are you able to determine when in relationship to the time of death that injury was received?

109 DR. LAKSHMANAN:

That also occurred before death.

110 MR. KELBERG:

For the same reasons you just described--pardon me--for injury no. 6?

111 DR. LAKSHMANAN:

Yes.

112 MR. KELBERG:

I'm sorry, injury no. 5?

113 DR. LAKSHMANAN:

Yes, the appearance and the nature.

114 MR. KELBERG:

Doctor, is that a sharp force injury?

115 DR. LAKSHMANAN:

Yes.

116 MR. KELBERG:

Are you able to differentiate between a single-edge or a double-edge knife for that particular sharp force injury?

117 DR. LAKSHMANAN:

No, I'm not able to.

118 MR. KELBERG:

Why not?

119 DR. LAKSHMANAN:

Because it is only a cut and the same reasons I gave earlier, when you just have an incise wound you cannot differentiate between a single-edge or a double-edge.

120 MR. KELBERG:

In your opinion are both injuries 5 and 6, however, injuries which could have been inflicted with that same single-edged knife that you said approximately would have to have a six-inch long blade?

121 DR. LAKSHMANAN:

Yes.

122 MR. KELBERG:

Doctor, are you able to offer information, from your review of that injury and any other material concerning the relative positions of Mr. Goldman and the perpetrator at the time that sharp force injury was received?

123 DR. LAKSHMANAN:

No, I'm not able to.

124 MR. KELBERG:

Is this injury no. 6 addressed by Dr. Golden in the autopsy protocol?

125 DR. LAKSHMANAN:

He has addressed it in the autopsy protocol but not--

126 MR. KELBERG:

Keep your voice up.

127 DR. LAKSHMANAN:

He has addressed it.

128 MR. KELBERG:

I think I heard you say he has not diagrammed it in any of the available diagram forms?

129 DR. LAKSHMANAN:

Yes.

130 MR. KELBERG:

Is his failure to diagram injury no. 6 a mistake, in your judgment?

131 DR. LAKSHMANAN:

Yes.

132 MR. KELBERG:

Does that mistake have any significance to you in evaluating things like cause of death?

133 DR. LAKSHMANAN:

No.

134 MR. KELBERG:

Or whether one knife could have caused all of the sharp force injuries that Mr. Goldman and Ms. Brown Simpson received?

135 DR. LAKSHMANAN:

No.

136 MR. KELBERG:

Or the manner of death?

137 DR. LAKSHMANAN:

No.

138 MR. KELBERG:

Or any of the other big ticket questions?

139 DR. LAKSHMANAN:

No.

140 MR. KELBERG:

Why not, doctor?

141 DR. LAKSHMANAN:

Because as I mentioned earlier, it is only a cut and it could have been caused by a single-edge or a double-edge and really does not have any significant impact on all the items we just discussed and is not a fatal wound.

142 MR. KELBERG:

I assume the same would apply to injury no. 5? That is not a fatal wound either?

143 DR. LAKSHMANAN:

That's correct.

144 MR. KELBERG:

Doctor, is this addressed at all by Dr. Golden in his addendum?

145 DR. LAKSHMANAN:

It was in the original protocol so it is not addressed in the addendum.

146 MR. KELBERG:

In your opinion was there any reason that he needed to?

147 DR. LAKSHMANAN:

Not necessary.

148 MR. KELBERG:

Anything else about injury no. 6, doctor?

149 DR. LAKSHMANAN:

Nothing else.

150 MR. KELBERG:

How about injury no. 7?

151 DR. LAKSHMANAN:

Injury no. 7 is a linear abrasion, measurement 3/8 of an inch in length, and it is behind the left ear canal.

152 MR. KELBERG:

All right. Let me slide over one more time just briefly. Would you point that out again for us.

153 DR. LAKSHMANAN:

(indicating).

154 MR. KELBERG:

Your Honor, where the witness has pointed, this injury no. 7, the abrasion, is to the left and below what has been described as injury no. 6, the cut to the ear.

155 THE COURT:

Yes.

156 MR. KELBERG:

Doctor, how can you tell that is an abrasion?

157 DR. LAKSHMANAN:

Because of the appearance and its characteristics.

158 MR. KELBERG:

What is it about the appearance and characteristics that led you to that conclusion?

159 DR. LAKSHMANAN:

Because it looks like a linear scrape, reddish brown in color.

160 MR. KELBERG:

Now, do you have an opinion as to what source or sources could have inflicted that linear abrasion?

161 DR. LAKSHMANAN:

One source could have been the dull edge of the knife could have caused the same wound--the same stroke which caused this cut could have just scraped the superficial part of the skin here, (indicating).

162 MR. KELBERG:

I'm sorry, the same--

163 DR. LAKSHMANAN:

Cut which caused the injury no. 6 could have also caused this cut abrasion.

164 MR. KELBERG:

The same instrument you mean?

165 DR. LAKSHMANAN:

Yes, the same instrument.

166 MR. KELBERG:

And you indicated I believe using the term "Dull"?

167 DR. LAKSHMANAN:

Yes.

168 MR. KELBERG:

Dull edge of a blade?

169 DR. LAKSHMANAN:

Yes.

170 MR. KELBERG:

If it is a dull edge of a blade, what kind of knife must that be?

171 DR. LAKSHMANAN:

Single-edge.

172 MR. KELBERG:

And how in your opinion could that same knife have created that abrasion as it created the cut that is injury no. 6?

173 DR. LAKSHMANAN:

Because you could have had the cut and then the knife movement could have also caused the cut abrasion.

174 MR. KELBERG:

How does the knife movement create that?

175 DR. LAKSHMANAN:

Because if it is turned or twisted you could have this abrasion caused.

176 MR. KELBERG:

Now, doctor, again that is an antemortem, that is, before death abrasion?

177 DR. LAKSHMANAN:

Yes.

178 MR. KELBERG:

How are you able to tell that?

179 DR. LAKSHMANAN:

The appearance, the reddish brown color.

180 MR. KELBERG:

Does this have any significant impact on cause of death?

181 DR. LAKSHMANAN:

No.

182 MR. KELBERG:

Or any of the other issues?

183 DR. LAKSHMANAN:

No.

184 MR. KELBERG:

Did Dr. Golden address this in his original protocol?

185 DR. LAKSHMANAN:

Yes, he did.

186 MR. KELBERG:

Did he diagram this?

187 DR. LAKSHMANAN:

No.

188 MR. KELBERG:

Is that a mistake?

189 DR. LAKSHMANAN:

Yes.

190 MR. KELBERG:

Is it significant to you on these big ticket issues?

191 DR. LAKSHMANAN:

No.

192 MR. KELBERG:

For the same reasons that you just expressed for the failure to diagram injury no. 6?

193 DR. LAKSHMANAN:

Yes.

194 MR. KELBERG:

Anything else about that particular one, doctor?

195 DR. LAKSHMANAN:

Nothing else.

196 MR. KELBERG:

I'm sorry, did Dr. Golden address it at all in his addendum?

197 DR. LAKSHMANAN:

No.

198 MR. KELBERG:

How about no. 8 then, doctor?

199 DR. LAKSHMANAN:

No. 8 is the triangular abrasion in the left side of the jaw.

200 MR. KELBERG:

Doctor, I'm sorry, would you point to it one more time, please.

201 DR. LAKSHMANAN:

(indicating).

202 MR. KELBERG:

Your Honor, may the record reflect that the doctor has pointed to something which appears to be almost in the immediate center of the photograph and does appear to be triangularly shaped with the point of the triangle facing the top of the photograph.

203 THE COURT:

Yes.

204 MR. KELBERG:

Doctor, what kind of injury is that, in your opinion?

205 DR. LAKSHMANAN:

It is a triangular-shaped abrasion which is a blunt force type injury.

KEY QUOTE
206 MR. KELBERG:

How were you able to make that determination?

207 DR. LAKSHMANAN:

Because of the appearance of the injury itself.

208 MR. KELBERG:

What is it about the appearance?

209 DR. LAKSHMANAN:

It is triangular in shape and it is not a cut. It looks more like an abrasion.

210 MR. KELBERG:

Is this an injury that you inspect with your magnifying glass to make these kind of determinations as to is it is an abrasion versus a cut or laceration?

211 DR. LAKSHMANAN:

That is correct, because with a magnifying glass you are able to see. If it is due to a sharp force injury you will see the splitting of the skin.

212 MR. KELBERG:

And did you in fact do that with this particular injury?

213 DR. LAKSHMANAN:

Yes, I did.

214 MR. KELBERG:

Did you see that splitting of the skin associated with the sharp force injury?

215 DR. LAKSHMANAN:

No.

216 MR. KELBERG:

Are you able to determine when in relationship to death that injury was received?

217 DR. LAKSHMANAN:

It is an antemortem, before death.

218 MR. KELBERG:

How are you able to tell?

219 DR. LAKSHMANAN:

The same reasons I gave earlier, the appearance and the nature of the wound.

220 MR. KELBERG:

Does this play any significant impact on cause of death?

221 DR. LAKSHMANAN:

No.

222 MR. KELBERG:

Or any of the other big ticket issues?

223 DR. LAKSHMANAN:

No.

224 MR. KELBERG:

For the same reasons as you have expressed?

225 DR. LAKSHMANAN:

Yes.

226 MR. KELBERG:

Does Dr. Golden address this in the original protocol?

227 DR. LAKSHMANAN:

No.

228 MR. KELBERG:

Does he diagram it anywhere in the available diagrams?

229 DR. LAKSHMANAN:

No.

230 MR. KELBERG:

Does he address it in the addendum?

231 DR. LAKSHMANAN:

Yes, he does.

232 MR. KELBERG:

Doctor, would you consider it a mistake on the part of Dr. Golden not to have described it initially and not to have diagrammed it initially?

233 DR. LAKSHMANAN:

Yes.

234 MR. KELBERG:

Are those mistakes significant to you on these big ticket questions?

235 DR. LAKSHMANAN:

No.

236 MR. KELBERG:

For the same reasons?

237 DR. LAKSHMANAN:

Yes.

238 MR. KELBERG:

Doctor, is there anything else about that--oh, I know I wanted to ask you, do you have any opinion, from your review of the material, as to what source or sources could have caused that particular triangular-shaped abrasion?

239 DR. LAKSHMANAN:

It is a blunt--nonspecific blunt force trauma. As I told you earlier, if you look at the scene, there are some branches which are cut--cut plant branches, some of them could have caused this kind of injury.

240 MR. KELBERG:

I think we are going to look at that again when we look in more detail at G-55; is that correct, doctor?

241 DR. LAKSHMANAN:

Yes.

242 MR. KELBERG:

Anything else then about that injury no. 8, I believe?

243 DR. LAKSHMANAN:

No.

244 MR. KELBERG:

What is injury no. 9 then, doctor?

245 DR. LAKSHMANAN:

Injury no. 9 is an interrupted three-inch cut abrasion.

246 MR. KELBERG:

I'm sorry?

247 DR. LAKSHMANAN:

Injury no. 9 is an interrupted three-inch long cut abrasion.

248 MR. KELBERG:

What do you mean by "Interrupted"?

249 DR. LAKSHMANAN:

Interrupted means there is areas of skin which are intact in the line of--in the line of path of injury.

250 MR. KELBERG:

Your Honor, where the witness has been pointing may the record reflect--

251 DR. LAKSHMANAN:

Intact skin in between, (indicating), the length of the injury.

252 MR. KELBERG:

May the record reflect that the injury described as injury no. 9 by the doctor--this is injury no. 9, correct, doctor?

253 DR. LAKSHMANAN:

Yes.

254 MR. KELBERG:

--appears to run at a 45-degree angle and appears to begin approximately halfway between the bottom of the ear and the left jawline and runs diagonally in a downward direction toward the back of the neck.

255 THE COURT:

Yes.

256 MR. KELBERG:

When the doctor was talking about interrupted, in looking at the photograph there appears to be a reddishness part to the line and then it becomes pale for a short distance and then reddish again, pale again, reddish again, pale and slightly reddish as it tails off in the photograph in the lower right-hand side.

257 THE COURT:

Yes, that appears to accurately depict that wound.

258 MR. KELBERG:

Now, doctor, in talking about abrasions, I'm not sure you discussed what a cut abrasion is. You talked about other kinds.

259 DR. LAKSHMANAN:

Umm, a cut abrasion is where a dull edge of a knife can cause a wound on the skin's surface. Not necessarily--it mainly scrapes the surface of the skin, but the margins will be sharp because it is caused by a sharp instrument's dull edge and that is a little different from another linear abrasion where you do not necessarily have the clean-cut appearance to the margins. And if you see it in a magnifying glass you can tell the difference.

260 MR. KELBERG:

Doctor, in talking about a dull edge, are you talking about a specific type of knife that creates that kind of interrupted abrasion, a cut abrasion?

261 DR. LAKSHMANAN:

A single-edge knife could do that or the dull tip doing this kind of injury.

262 MR. KELBERG:

Would you expect a double-edge knife to be able to give that kind of impression?

263 DR. LAKSHMANAN:

It could, but the--the knife has to be drawn perpendicular to the cutting edges. The tip has to be drawn across the skin's surface, but I would favor the former to the latter.

264 MR. KELBERG:

Why is that?

265 DR. LAKSHMANAN:

For the same reason I mentioned earlier, because this would--this would have a more linear appearance than the other one, but it is difficult to differentiate.

266 MR. KELBERG:

Now, doctor, is this also an injury that is received before death?

267 DR. LAKSHMANAN:

Yes.

268 MR. KELBERG:

How are you able to tell that?

269 DR. LAKSHMANAN:

Because of the appearance and the color.

270 MR. KELBERG:

Doctor, does this play any significant role in cause of death?

271 DR. LAKSHMANAN:

No.

272 MR. KELBERG:

Or any of the other big ticket issues?

273 DR. LAKSHMANAN:

No.

274 MR. KELBERG:

Did Dr. Golden address this in his protocol?

275 DR. LAKSHMANAN:

Yes, he did.

276 MR. KELBERG:

Did he diagram it in any available form?

277 DR. LAKSHMANAN:

Yes, he did.

278 MR. KELBERG:

Is it addressed at all in that addendum?

279 DR. LAKSHMANAN:

No.

280 MR. KELBERG:

In your judgment any reason that he needed to?

281 DR. LAKSHMANAN:

Not necessary.

282 MR. KELBERG:

Are you able to tell in any way, from what you see and have reviewed, the relative positions of Mr. Goldman and the perpetrator to result in this particular injury no. 9?

283 DR. LAKSHMANAN:

I have considered that, but you cannot tell.

284 MR. KELBERG:

Why can you not tell?

285 DR. LAKSHMANAN:

Because it is an injury which is in an area which could have been either the perpetrator could have been in the front or the back.

286 MR. KELBERG:

The perpetrator could have been either to the front of Mr. Goldman or the back?

287 DR. LAKSHMANAN:

Back on the side.

288 MR. KELBERG:

Of Mr. Goldman?

289 DR. LAKSHMANAN:

Yes.

290 MR. KELBERG:

When this injury was received or inflicted?

291 DR. LAKSHMANAN:

Yes.

292 MR. KELBERG:

Anything else about that injury, doctor?

293 DR. LAKSHMANAN:

Nothing else.

294 MR. KELBERG:

How about injury no. 10?

295 DR. LAKSHMANAN:

Injury no. 10 is a faint abrasion which you can see running from the--below the left ear downwards here, (indicating).

296 MR. KELBERG:

And doctor, is that seen also--if we could move up to G-53, is that seen in that photograph as well?

297 DR. LAKSHMANAN:

Yes, running parallel to injury no. 2 I think, yes, (indicating).

298 MR. KELBERG:

Your Honor, for the record, may the record reflect that the injury no. 10 is a linear abrasion pointed out by the doctor in both photographs G-51 and G-53, appears to be, as you look at the photograph, to the left of injury no. 2 in G-51, running in the same direction as G-51's injury no. 2 and terminating short of where injury no. 2 in G-51 terminates?

299 THE COURT:

Yes.

300 MR. KELBERG:

Doctor, how are you able to tell that is an abrasion?

301 DR. LAKSHMANAN:

The appearance, and as I told you, I examined all these injuries with the magnifying glass also in the photographs.

302 MR. KELBERG:

Did you measure from the life-size one-to-one photographs to determine the approximate length of that abrasion?

303 DR. LAKSHMANAN:

Yes. It was one and a half inches.

304 MR. KELBERG:

Doctor, does this abrasion play any significant role in cause of death?

305 DR. LAKSHMANAN:

No.

306 MR. KELBERG:

Or in any of the big ticket questions?

307 DR. LAKSHMANAN:

No.

308 MR. KELBERG:

Do you have an opinion as to what cause or causes could have inflicted that?

309 DR. LAKSHMANAN:

It is a nonspecific blunt force linear injury, and as I told you, there are some branches and plant stalk which could have resulted in that kind of injury.

310 MR. KELBERG:

Doctor, did Dr. Golden address this in his protocol?

311 DR. LAKSHMANAN:

He did not address this, per se, in his protocol. He described a cut there.

312 MR. KELBERG:

Doctor, did he diagram this abrasion in his original diagram forms?

313 DR. LAKSHMANAN:

Not as an abrasion.

314 MR. KELBERG:

Did he address this abrasion in his addendum?

315 DR. LAKSHMANAN:

No.

316 MR. KELBERG:

I think this might be an opportunity, if Mr. Lynch could help me out to put up a diagram.

317 (Brief pause.)
318 MR. KELBERG:

Doctor, did you find, in your review of the protocol and a diagram, that Dr. Golden had some injury associated with this same general area as injury no. 10 but which, in your opinion, is not the same injury that you have just described and which you see in those photographs?

319 DR. LAKSHMANAN:

That is correct.

320 MR. KELBERG:

Let me take this down for just a second.

321 (Brief pause.)
322 MR. KELBERG:

Can you refer me, doctor, to which diagram?

323 DR. LAKSHMANAN:

I think it is on the addendum description page 4 and if we go to the--

324 MR. KELBERG:

Keep your voice up, doctor.

325 DR. LAKSHMANAN:

If we go to the 22 diagrams.

326 MR. KELBERG:

All right. Put that up first. Which one of the 22's, doctor?

327 DR. LAKSHMANAN:

The next. 22-II, I think, if I remember right. No, 22-III. Yeah. That is the one right there, 22-II.

328 MR. KELBERG:

Keep your voice up, doctor.

329 DR. LAKSHMANAN:

22-II.

330 MR. KELBERG:

Let me get out of the way. First of all, what is it that you see on diagram 22 roman numeral ii that you believe is associated with the same general area as that injury no. 10?

331 DR. LAKSHMANAN:

This one and 1/8 inch cut that says, "Incise wound superficial," one and 1/8 inch long behind the left ear.

332 MR. KELBERG:

Doctor, where you have indicated with your marker I'm going to circle and I will write "G-51" and I'm also going to write "G-53" and I will put in quotation marks, "Cut." Doctor, if Dr. Golden described this as a cut, in your opinion, he has inaccurately assessed what the injury that you see as an abrasion actually is; is that correct?

333 DR. LAKSHMANAN:

Yes, and also this is a diagrammatic representation. All I could see in that area was this linear abrasion I just described. I didn't see any cut.

334 MR. KELBERG:

In your opinion, is it a mistake to opine that that is a cut rather than an abrasion?

335 DR. LAKSHMANAN:

Yes.

336 MR. KELBERG:

Is it significant, however, as a mistake, on your ability to determine any of these big ticket questions?

337 DR. LAKSHMANAN:

No.

338 MR. KELBERG:

Why not?

339 DR. LAKSHMANAN:

For the same reasons I alluded to earlier, because it is only a superficial injury. It didn't have anything to do with the cause of death or my ability to characterize the wound or my ability to determine that it is a single-edge or a double-edge or my ability to interpret fatality from an injury, the bleeding patterns, because it is a superficial injury. So really it didn't have an impact as far as the big ticket items we have been discussing on every other injury so far.

340 MR. KELBERG:

The measurement that is provided there of one and 1/8 inch is different than your measurement of one and one-half inch?

341 DR. LAKSHMANAN:

That's correct, but also my orientation is a little different because the abrasion I diagrammed as--not diagrammed--I perceived from the photograph is parallel to the injury here. This looks as it is running from the attachment of the earlobe backwards into the skin--the back of the neck.

342 MR. KELBERG:

Doctor, let me put up again the photograph--let me actually hold it down a bit so that we can see the orientation as seen in the photograph. And I would ask you, if you can, please, to diagram on form 22, let me give your the blue marker--can you diagram in there the orientation you believe accurately reflects the orientation of the abrasion itself?

343 DR. LAKSHMANAN:

Just an approximation, (indicating).

344 MR. KELBERG:

Your Honor, for the record, Dr. Lakshmanan has made three dash lines within that area of red that I just circled in the upper right quadrant diagram for form 22. And what I'm going to do is draw with a blue line out to the side and write "G-51, G-53, injury, inj., no. 10."

345 THE COURT:

Yes.

346 MR. KELBERG:

Doctor, I think you mentioned Dr. Golden had some information in the original protocol referring to this cut; is that correct?

347 DR. LAKSHMANAN:

Yes and--

348 MR. KELBERG:

Where within the original protocol?

349 DR. LAKSHMANAN:

It is on page 4, here, (indicating), lower paragraph: "Also in the left postauricular region, transversely oriented, extending from the auricular attachment laterally to the scalp is a one and 1/8 inch linear superficial incised wound." Last four lines of paragraph 3.

350 MR. KELBERG:

And where Dr. Lakshmanan has just pointed that out and read it, I will outline that in blue on page 4 of the protocol which is our board 0G. And I apologize, 4G was the board for the form 22.

351 THE COURT:

All right. Thank you.

352 MR. KELBERG:

I will write out at the side "G-51, G-53" and I will write the word "Cut," C-U-T, in quotation marks.

353 MR. KELBERG:

Now, doctor was there any description or additional information provided by Dr. Golden in the addendum referring to the cut versus the abrasion injury no. 10?

354 DR. LAKSHMANAN:

No.

355 MR. KELBERG:

Let me put up the photo one more time because I want to focus this time on G-53 and invite your attention, if I could, to where I'm pointing now, is this same abrasion, injury no. 10; is that correct?

356 DR. LAKSHMANAN:

Yes.

357 MR. KELBERG:

And there appears to be some discoloration right at the upper end of that injury that is not seen in the angle of the photograph G-51. Do you see that, doctor?

358 DR. LAKSHMANAN:

Yes.

359 MR. KELBERG:

Does that observation have any significance to you?

360 DR. LAKSHMANAN:

It is just a blood clot there behind the ear which has not been washed off and that is what this discoloration is, a blood clot remaining there in spite of all the washing and cleaning before the photographing.

361 MR. KELBERG:

Does that blood clot have any significance to you in being able to form an opinion as to whether what you described as an abrasion, injury no. 10, was in fact a cut as Dr. Golden described it?

362 DR. LAKSHMANAN:

There is no cut there, and this blood clot is probably related to the cut on the earlobe.

KEY QUOTE
363 MR. KELBERG:

Cut in the earlobe which you have previously described?

364 DR. LAKSHMANAN:

Yes, and Dr. Golden has described, also.

365 MR. KELBERG:

Doctor, do you consider it then a mistake for Dr. Golden again to have addressed in his protocol this particular item as a cut?

366 DR. LAKSHMANAN:

Yes, because I don't see it in the photographs.

367 MR. KELBERG:

Is the area that Dr. Golden describes as being the area where the cut is observed visible in both photographs G-53 and G-51?

368 DR. LAKSHMANAN:

Yes, and--

369 MR. KELBERG:

Is there anything else about this cut versus the abrasion?

370 DR. LAKSHMANAN:

No.

371 MR. KELBERG:

Doctor, what is injury no. 11 then?

372 DR. LAKSHMANAN:

Injury no. 11 is superficial irregular abrasions--actually 11 and 12 below injury no. 8 on the inferior chin here, those abrasions here, (indicating), and here, (indicating). This is 11 and 12 respectively. You have some faint abrasion itself which are nonspecific.

373 MR. KELBERG:

I'm sorry, doctor, which is 11 and which is 12?

374 DR. LAKSHMANAN:

The left chin below injury no. 8.

375 MR. KELBERG:

Is 11 the one that is in the lower left-hand corner of the photograph?

376 DR. LAKSHMANAN:

Yes.

377 MR. KELBERG:

And your Honor, for the record, in the lower left-hand corner where the chin is.

378 DR. LAKSHMANAN:

Yes.

379 MR. KELBERG:

Where the doctor was pointing.

380 THE COURT:

Yes.

381 MR. KELBERG:

And 12 is an area which is a bit below and a little to the right of the triangular-shaped abrasion; is that correct?

382 DR. LAKSHMANAN:

Yes.

383 MR. KELBERG:

Now, tell us about these two particular findings?

384 DR. LAKSHMANAN:

These are nonspecific superficial abrasions and could be related to the same type of plant material contact I discussed earlier regarding the linear abrasions.

385 MR. KELBERG:

Doctor, are you able to determine again whether these are inflicted or received before death?

386 DR. LAKSHMANAN:

They appear to be antemortem.

387 MR. KELBERG:

Again why?

388 DR. LAKSHMANAN:

Same reasons, the appearance, the discoloration.

389 MR. KELBERG:

Do they play any role in cause of death?

390 DR. LAKSHMANAN:

No.

391 MR. KELBERG:

Or any of the other big ticket issues?

392 DR. LAKSHMANAN:

No.

393 MR. KELBERG:

Did Dr. Golden address these in the protocol?

394 DR. LAKSHMANAN:

No.

395 MR. KELBERG:

Did he diagram them anywhere?

396 DR. LAKSHMANAN:

No.

397 MR. KELBERG:

Did he address them in the addendum?

398 DR. LAKSHMANAN:

No.

399 MR. KELBERG:

All mistakes in your judgment?

400 DR. LAKSHMANAN:

Yes.

401 MR. KELBERG:

Significant singularly or collectively?

402 DR. LAKSHMANAN:

No.

403 MR. KELBERG:

Why not?

404 DR. LAKSHMANAN:

Because of the same reasons I gave earlier, these are very superficial injuries. They have no significance to the cause of death. They do not interfere with my ability to discuss the nature of the sharp force injuries or the bleeding patterns or any of the other issues I have discussed before previously.

405 MR. KELBERG:

Doctor, are there any other injuries that are in photograph G-53 that we have not discussed?

406 DR. LAKSHMANAN:

No. I think we have discussed all the injuries in G-51 and G-53.

407 MR. KELBERG:

Before--and I included, I'm sorry, by omission, but I intend to include it, G-37 before we put up the protocols and so forth to show which are the diagrammed injuries and described injuries, I wanted to come back just briefly to one of the injuries you described in G-37 as I believe a cut below injury no. 2, the superficial incise.

408 DR. LAKSHMANAN:

I said it is an abrasion, yeah.

409 MR. KELBERG:

Abrasion, I'm sorry. In talking with you this afternoon you brought some additional information to my attention. I think you said last week that it could be caused by a fingernail?

410 DR. LAKSHMANAN:

Yes.

411 MR. KELBERG:

Is there additional source or sources that you believe it would be important to know?

412 DR. LAKSHMANAN:

If it is a rough glove, the glove also could do the same type of abrasion.

KEY QUOTE
413 MR. KELBERG:

A rough glove?

414 DR. LAKSHMANAN:

Yes. It is an abrasion injury. I just gave one example the other day and I gave another example today.

415 MR. KELBERG:

How is that done by a rough glove?

416 DR. LAKSHMANAN:

The same kind of movement which I discussed that day, gloved finger can also cause the same type of abrasion when these threatening cuts were made.

417 MR. KELBERG:

Anything else you wanted to add about that particular one, doctor?

418 DR. LAKSHMANAN:

Nothing.

419 MR. KELBERG:

Doctor, then let's go to the protocols and the addendums and the diagrams for the other injuries of G-51 that we have not discussed. Why don't we start--we had gone through injury 4, I believe you said, so should we start with injury no. 5? I think you said that that was addressed?

420 DR. LAKSHMANAN:

Yes, injury no. 5 is on the protocol and it is on page 4 here, (indicating). It is the linear triangular size wound of the inferior portion of the left earlobe.

421 MR. KELBERG:

Just will you point that out real quickly for us?

422 DR. LAKSHMANAN:

(indicating). It is there and here, this G-53, it is on the left earlobe here, (indicating), and G-51 you can see it in the left earlobe here and this is the description here on the protocol, (indicating).

423 MR. KELBERG:

Let me outline that in red on page 4 of board 0G and that is going to be "G-51 inj. No. 5."

424 MR. KELBERG:

Where is it diagrammed, if at all, doctor?

425 DR. LAKSHMANAN:

It is diagrammed in 22-II.

426 MR. KELBERG:

If I could ask Mr. Lynch just to temporarily take care of that board.

427 MR. KELBERG:

You say 22-II which we have up, our 4G board?

428 DR. LAKSHMANAN:

Yes.

429 MR. KELBERG:

What has he done?

430 DR. LAKSHMANAN:

He has diagrammed accurately the left earlobe of an inch wound and you can see it here.

431 MR. KELBERG:

Does this writing that appears above what appears to be a horizontal line have anything to do with that particular injury no. 5?

432 DR. LAKSHMANAN:

It is magnified demonstration of the same injury to show that it is a cut to the earlobe.

433 MR. KELBERG:

Where the doctor has indicated on the form in the lower right-hand quadrant, I will circle it in red and I will write "G-51 inj. No. 5."

434 MR. KELBERG:

Is that accurate, doctor?

435 DR. LAKSHMANAN:

Yes.

436 MR. KELBERG:

Does that take care of all of the entries regarding injury no. 5?

437 DR. LAKSHMANAN:

Yes.

438 MR. KELBERG:

Nothing in the addendum, correct?

439 DR. LAKSHMANAN:

That's correct.

440 MR. KELBERG:

Injury no. 6?

441 DR. LAKSHMANAN:

Injury no. 6 is page 7, no. 6.

442 MR. KELBERG:

Let me ask you is it diagrammed somewhere?

443 DR. LAKSHMANAN:

Injury no. 6, no.

444 MR. KELBERG:

Okay. Let's take this one down.

445 (Brief pause.)
446 MR. KELBERG:

And put our protocol back up.

447 MR. KELBERG:

And I'm sorry, doctor, the page number of the protocol?

448 DR. LAKSHMANAN:

Page 7, no. 6. The whole paragraph refers to injury no. 6 and 7.

449 MR. KELBERG:

All right. Let's separate, if we could, first of all, point out for us, if you would, which is injury no. 6?

450 DR. LAKSHMANAN:

Injury no. 6 is the cut to the left ear behind the ear canal. You can see it also in G-53 and in G-51. The linear abrasion is behind the ear canal in G-53 and you can also see it in G-51.

451 MR. KELBERG:

That would be injury no. 7; is that correct?

452 DR. LAKSHMANAN:

Yes.

453 MR. KELBERG:

Let's break this down then. Which part is injury no. 6 as described?

454 DR. LAKSHMANAN:

The first two lines.

455 MR. KELBERG:

Ending with the word "Pinna."

456 DR. LAKSHMANAN:

Yes.

457 MR. KELBERG:

Let me outline that in red on page 7 of this board and I will write "G-51 inj. No. 6."

458 MR. KELBERG:

And then the next sentence refers to--in this same subgroup refers to injury no. 7?

459 DR. LAKSHMANAN:

Yes.

460 MR. KELBERG:

I will outline that in blue and write on the right-hand side "G-51 inj. No. 7."

461 MR. KELBERG:

Any other place in the protocol for either of those two?

462 DR. LAKSHMANAN:

No.

463 MR. KELBERG:

You said there was no diagram done of no. 6; is that correct?

464 DR. LAKSHMANAN:

That's correct.

465 MR. KELBERG:

Any diagramming done of no. 7?

466 DR. LAKSHMANAN:

No.

467 MR. KELBERG:

Any aspect of the addendum addressing either one?

468 DR. LAKSHMANAN:

No.

469 MR. KELBERG:

How about no. 8, injury no. 8?

470 DR. LAKSHMANAN:

Injury no. 8 is in the addendum description.

471 MR. KELBERG:

Injury no. 8 again is which one, doctor?

472 DR. LAKSHMANAN:

Injury no. 8 is the triangular abrasion to the angle of the jaw which is this one here, (indicating), which I described earlier, and it is also seen in G-51 and 53.

473 MR. KELBERG:

All right, doctor. Where in the protocol?

474 DR. LAKSHMANAN:

It is not in the protocol, it is not in the diagram, but it is on the addendum, page 4, no. 9.

475 MR. KELBERG:

No. 9?

476 DR. LAKSHMANAN:

No, no, not no. 9. No. 8, (indicating)--here, no. 10.

477 MR. KELBERG:

"On the left side of the jaw at the angle of the mandible there is a triangular shaped brown abrasion measuring maximally 1/4 inch."

478 DR. LAKSHMANAN:

Yes.

479 MR. KELBERG:

I will outline that from our board no. 10G, your Honor.

480 THE COURT:

Yes. Thank you.

481 MR. KELBERG:

And I will write at the side "G-51 inj. No. 7", doctor?

482 DR. LAKSHMANAN:

No. 8.

483 MR. KELBERG:

No. 8, I'm sorry. Any entry in the addendum?

484 DR. LAKSHMANAN:

No.

485 MR. KELBERG:

How about injury no. 9?

486 DR. LAKSHMANAN:

It is diagrammed in--is--

487 MR. KELBERG:

It addressed in the protocol?

488 DR. LAKSHMANAN:

Yes.

489 MR. KELBERG:

Where?

490 DR. LAKSHMANAN:

I'm sorry, not in the protocol. Is it is in the diagram and the addendum.

491 MR. KELBERG:

Let's stay in the addendum since we have it up. Where in the addendum?

492 DR. LAKSHMANAN:

It is on the page 4, no. 10, (indicating).

493 MR. KELBERG:

No, I think no. 10 we just outlined.

494 DR. LAKSHMANAN:

No. 9.

495 MR. KELBERG:

Okay. First of all, let's refresh our recollection. Which is injury no. 9?

496 DR. LAKSHMANAN:

The linear cut abrasion which I have described earlier just above the triangular abrasion in G-51 and in 53.

497 MR. KELBERG:

And your Honor, on that same page then I will outline it in blue and on the left side I will write "G-51 inj. No. 9."

498 MR. KELBERG:

Correct, doctor?

499 DR. LAKSHMANAN:

Yes.

500 MR. KELBERG:

All right. Now, where is it diagrammed?

501 DR. LAKSHMANAN:

It is in 22, no. I. You can see it here, (indicating), right here, (indicating), between the lower left neck, sharp force injury, and the left postauricular sharp force injury is a linear cut abrasion.

502 MR. KELBERG:

And doctor, is there any writing that has been added by Dr. Golden?

503 DR. LAKSHMANAN:

It says here, "Three and a half inch interrupted incise wound superficial," arrow pointing to that, so that would be injury no. 9.

504 MR. KELBERG:

What the doctor has just pointed, your Honor, I will circle that area in the lower right-hand quadrant diagram of 22-I.

505 MR. KELBERG:

And I will write "G-51 inj. No. 10," doctor?

506 DR. LAKSHMANAN:

Yes. No, no. 9.

507 MR. KELBERG:

No. 9, I'm sorry. I will write no. 9. While we are here, doctor, I don't think we actually outlined injury no. 2, that is that one that we talked about that is part of the continuation of injury no. 3 of G-37, injury no. 1 of G-51 or whether, as you opined, it was a separate wound. Is that this area here, (indicating)?

508 DR. LAKSHMANAN:

You can see it here. It says, "Two inch incise wound superficial" right here, (indicating), and this is the part of injury no. 2 which we discussed earlier under the photograph description.

509 MR. KELBERG:

Doctor, there appears to be some writing above what you just read. Does that refer to this particular injury as well?

510 DR. LAKSHMANAN:

Yes. It says "Border is wavy" and that is what is being described.

511 MR. KELBERG:

Does any of the writing above that refer to that injury?

512 DR. LAKSHMANAN:

It says--actually this part of the six inches is the location of the--of this incise wound, actually, of injury no. 3, and the direction is--also refers to the injury no. 1 actually, so--

513 MR. KELBERG:

I'm sorry, doctor. If you will keep your voice up. Let's break this down. Six inches refers to what?

514 DR. LAKSHMANAN:

It refers to that is below the ear area here, (indicating), and refers to this particular injury no. 1 of g--

515 MR. KELBERG:

51, I believe?

516 DR. LAKSHMANAN:

Yes.

517 MR. KELBERG:

Okay. So we will circle that as well and just include it with a line down to that same area that is already labeled.

518 MR. KELBERG:

It is also injury no. 3 of G-37, correct, doctor?

519 DR. LAKSHMANAN:

Yes, yes.

520 MR. KELBERG:

And I will write "G-51 injury no. 5, inj. No. 1."

521 MR. KELBERG:

Okay. What about the rest of this? This refers to what?

522 DR. LAKSHMANAN:

The front to back would refer to the same injury.

523 MR. KELBERG:

All right. Let me circle that and just have that connect up with the six-inch circle entry.

524 MR. KELBERG:

Next?

525 DR. LAKSHMANAN:

And this "Border wavy," all this belongs to the injury behind the ear, all of this, (indicating).

526 MR. KELBERG:

What about this writing above the "Border wavy"?

527 DR. LAKSHMANAN:

"Border wavy" belongs to that injury also. That is the front margin.

528 MR. KELBERG:

I understand that, doctor. I'm talking about the writing that appears above "Border wavy"?

529 DR. LAKSHMANAN:

That is difficult for me to read.

530 MR. KELBERG:

I will circle that injury all in blue in the same form, lower right-hand quadrant and I will write "G-51 inj. No. 2."

531 THE COURT:

Thank you.

532 MR. KELBERG:

All right.

533 MR. KELBERG:

Doctor, anything more on the diagramming of injury no. 9?

534 DR. LAKSHMANAN:

No.

535 MR. KELBERG:

And then you said it is found in the addendum?

536 DR. LAKSHMANAN:

Yes. We already discussed that.

537 MR. KELBERG:

Have we taken care of that?

538 DR. LAKSHMANAN:

Yes.

539 MR. KELBERG:

So we are done with injury no. 9?

540 DR. LAKSHMANAN:

Yes.

541 MR. KELBERG:

All right. How about injury no. 10?

542 DR. LAKSHMANAN:

Injury no. 10 is not described.

543 MR. KELBERG:

How about in the addendum?

544 DR. LAKSHMANAN:

No.

545 MR. KELBERG:

So there is nothing referring to injury no. 10?

546 DR. LAKSHMANAN:

No.

547 MR. KELBERG:

And no. 11 and 12, what did you say?

548 DR. LAKSHMANAN:

Not diagrammed, not described.

549 MR. KELBERG:

Not in the addendum?

550 DR. LAKSHMANAN:

No.

551 MR. KELBERG:

Are we done then with that photograph?

552 DR. LAKSHMANAN:

Yes.

553 MR. KELBERG:

Okay.

554 (Brief pause.)
555 MR. KELBERG:

Doctor, is there anything else regarding G-53 that we have not discussed with respect to its appearance in G-51?

556 DR. LAKSHMANAN:

No, except that for the wound behind the ear there is a 7/8 component which is described in the addendum and it is seen in the photograph, which would be the penetrating part of the stab wound as I discussed.

557 MR. KELBERG:

When you say a "7/8 inch component"--

558 DR. LAKSHMANAN:

Yes. That is the penetrating area of the stab wound behind the left ear.

559 MR. KELBERG:

And that is found in the addendum?

560 DR. LAKSHMANAN:

Yes.

561 MR. KELBERG:

In an area--let me just see if we didn't cover that. What page, doctor?

562 DR. LAKSHMANAN:

That will be in page 2, no. 4, here. It is covered in the addendum but not in the original protocol.

563 MR. KELBERG:

And the component, is that of significance to you in deciding that that is an entry area for a second sharp force injury rather than an exit associated with injury no. 1?

564 DR. LAKSHMANAN:

That is correct and also I have already given you the other reasons already.

565 MR. KELBERG:

Anything else about that?

566 DR. LAKSHMANAN:

No.

567 MR. KELBERG:

All right. Let's get that down.

568 (Brief pause.)
569 MR. KELBERG:

One last thing comes to my mind, doctor, regarding injuries numbers 1 and 2 as seen in photograph G-37. And again, as part of your review of the grand jury testimony by Dr. Golden, did you find Dr. Golden made reference to those two particular superficial incise wounds?

570 DR. LAKSHMANAN:

Yes.

571 MR. KELBERG:

If I may have just a moment, your Honor.

572 THE COURT:

Certainly.

573 (Brief pause.)
574 MR. KELBERG:

And inviting counsel to page 120 of the grand jury testimony and beginning questioning by Mr. Conn of the District Attorney's office on line 8 through line 20 with the answer, doctor, did you review this testimony: "Question: Now, the wounds that we looked at so far, which are People's 6, 7 and 8, the injury to the neck here, can you tell us anything about the time that those wounds may have been inflicted? "Answer: Well, the two deep wounds on each side of the neck occurred before death. There is extensive bruising along or in the tissues. The two wounds across the larynx, those superficial ones, don't have as much bleeding." Let me stop at this point, doctor. Did you interpret that testimony to refer to injuries numbers 1 and 2, that is, the two wounds across the larynx?

575 DR. LAKSHMANAN:

Yes.

576 MR. KELBERG:

Continuing, as I said: "The two wounds across the larynx, those superficial ones, don't have as much bleeding. I think that it is possible that they occurred on or about the time of death. In other words, when blood pressure had dropped considerably. In other words, maybe later on in the--or during the assault or the sequence." Doctor, in your opinion is Dr. Golden's opinion one which is medically sound concerning those two superficial incise wounds?

577 DR. LAKSHMANAN:

No. My--

578 MR. KELBERG:

Why not?

579 DR. LAKSHMANAN:

My opinion is that they occurred when he had blood pressure, one, was there is dermal hemorrhage described by Dr. Golden in the report itself. No. 2, when I reviewed the crime scene photographs, we have definite evidence of bleeding from those wounds.

580 MR. KELBERG:

Was the presence of dermal bleeding of significance to you in deciding when in relationship to the time of death those two control superficial incise wounds were received?

581 DR. LAKSHMANAN:

That would indicate that Mr. Goldman had blood pressure when those wounds were inflicted and that would--because to have bleeding in the dermis you need to have blood pressure.

582 MR. KELBERG:

Doctor--

583 THE COURT:

Excuse me, Mr. Kelberg. Are you referring to G-37, the incise wound.

584 MR. KELBERG:

Yes, G-37, injuries no. 1 and 2. Thank you, your Honor.

585 THE COURT:

All right.

586 MR. KELBERG:

Doctor, in forming your opinion that those two superficial incise wounds represented control type of injuries--I think you talked about threatening, as the perpetrator is threatening or taunting I believe may have been the words you used?

587 DR. LAKSHMANAN:

That is correct.

588 MR. KELBERG:

--in your opinion did that indicate that those were, if not the first two, very close to the first two injuries received by Mr. Goldman?

589 DR. LAKSHMANAN:

That is correct.

590 MR. KELBERG:

Why?

591 DR. LAKSHMANAN:

Because they are control cuts. As I told you, they run parallel. They railroad track like. And I also pointed out to you the cut above the wound which would favor that they occurred earlier when the victim was in close proximity and held immobilized by the suspect.

592 MR. KELBERG:

Is there anything else you wish to add to your assessment of Dr. Golden's conclusion regarding those two superficial incise wounds?

593 DR. LAKSHMANAN:

Nothing else, because the dermal hemorrhage has been described in the report. The crime scene photographs indicate they are antemortem when they happened during life.

594 MR. KELBERG:

Since you mentioned again the dermal hemorrhage, can you refer me by page?

595 DR. LAKSHMANAN:

They are on page--page 5, no. 3 and 4. No. 4, it says, "There is a small amount of dermal hemorrhage" and no. 3 it says, "Small amount of cutaneous hemorrhage is evident."

596 MR. KELBERG:

Where the witness has indicated, your Honor, on or about our 0G page 5 of the protocol--

597 THE COURT:

Yes.

598 MR. KELBERG:

--I will underline sub-parts 3 and 4.

599 MR. KELBERG:

Anything further on that issue, doctor?

600 DR. LAKSHMANAN:

No.

601 MR. KELBERG:

Does Dr. Golden's opinion, which you describe as not medically supported, constitute a mistake, in your judgment?

602 DR. LAKSHMANAN:

Well, it is an opinion.

603 MR. KELBERG:

It is a mistaken opinion?

604 DR. LAKSHMANAN:

In my opinion, yes.

605 MR. KELBERG:

Does it have any significance to you in forming any of your own opinions on these issues?

606 DR. LAKSHMANAN:

Yes. The presence of hemorrhage indicates it is antemortem and would go along with my opinion that they probably occurred earlier in the struggle and they were threatening wounds.

607 MR. KELBERG:

Is the fact that in your opinion his opinion is a mistake, does the mistake aspect have any significance to you?

608 DR. LAKSHMANAN:

No.

609 MR. KELBERG:

You are able to form your own opinions regarding these matters in spite of that?

610 DR. LAKSHMANAN:

Yes. And as I told you, the crime scene photographs do show bleeding in the wounds.

611 (Brief pause.)
612 MR. KELBERG:

May I have just a moment, your Honor?

613 THE COURT:

Certainly.

614 (Brief pause.)
615 MR. KELBERG:

Thank you, your Honor.

616 MR. KELBERG:

Doctor, can we move back now, I think we are--we still have some injuries, G-55, G-40 and G-50 to describe; is that correct?

617 DR. LAKSHMANAN:

Yes.

618 MR. KELBERG:

Could we start with photograph G-55 and I'm going to save for a later time a discussion of the head area, but at this point I want to focus, if we could, please, on what appears to be some kind of discoloration area that is to the right of that major sharp force injury you described last week that is also seen in G-40.

619 DR. LAKSHMANAN:

It is a 5/8 inch stab wound and that is located in the right side of the neck, (indicating), and that is the main description of that injury.

620 MR. KELBERG:

Doctor, is this the same sharp force injury that we see in the lower right-hand corner of the cropped photo G-50 up here in the corner?

621 DR. LAKSHMANAN:

Yes. Here, this is a more closer up photograph of the same injury. You can see the ends of the wound better defined. You can tell whether it is a sharp end or a blunt end. You can see that the front of the wound is sharp and the back of the wound is slightly forked, and this measured I think 1/16 inch in width.

622 MR. KELBERG:

What measured that?

623 DR. LAKSHMANAN:

The forked end.

624 MR. KELBERG:

The overall wound measured how much?

625 DR. LAKSHMANAN:

5/8 of an inch.

626 MR. KELBERG:

Now, doctor, is this also seen in the lower right hand neck area in photograph G-40?

627 DR. LAKSHMANAN:

Yes.

628 MR. KELBERG:

Did you give this a number, with respect to one or more of these photographs?

629 DR. LAKSHMANAN:

Yes. I described it as injury no. 2 under G-40.

630 MR. KELBERG:

Now, injury no. 1 of G-40 is--

631 DR. LAKSHMANAN:

This larger penetrating type wound in the back of the right side of the neck which continues or is in conjunction--seen in conjunction with injury no. 2, which is that long superficial cut in the lower neck which we called this injury no. 2 in G-37.

632 MR. KELBERG:

Let's focus then on injury no. 2 for a second, as seen perhaps most clearly, as you said, in G-50. Are you able to determine the type of instrument that could have made that injury, that sharp force injury?

633 DR. LAKSHMANAN:

It is a stab wound from a knife.

634 MR. KELBERG:

Are you able to determine whether it is a single-edged or it could be either a single- edge or double-edge?

635 DR. LAKSHMANAN:

It could be a single-edge or a double-edge knife. It could be a single-edge knife with a blunt edge which caused the forking of the wound.

636 MR. KELBERG:

Going back to that chart we did I think the second day you were testifying regarding the correlation between types of knives and the kind of wounds and their appearances on the surface, do you recall which of the types--

637 DR. LAKSHMANAN:

It is no. 3, no. 3, the lower portion which had the forking on the top. This wound is similar to that.

638 MR. KELBERG:

Is it, however, doctor, your opinion that that approximately six-inch long blade that you talked about that is a single-edged knife could be the source for this sharp force injury, this stab wound injury no. 2?

639 DR. LAKSHMANAN:

It could be, because you see--the wound has been only described as two inches in-depth and it communicates with injury no. 1, and so it would be more toward the tapering part of the knife.

640 MR. KELBERG:

When you say two inches, that is a description given by Dr. Golden?

641 DR. LAKSHMANAN:

Yes.

642 MR. KELBERG:

To represent what?

643 DR. LAKSHMANAN:

The depth of the wound.

644 MR. KELBERG:

Can you say again, this word "Communicates," what do you mean by that?

645 DR. LAKSHMANAN:

They share a common path with this wound, (indicating), which is injury no. 1 in G-40, I think.

646 MR. KELBERG:

If we could go perhaps to G-55, does this perhaps show most clearly the relationship on the body between the injuries--injury no. 2, this stab wound you have just been talking about, and what is that other sharp force injury, and I'm not sure which designation you gave it, I believe you said injury no. 1 of G-40?

647 DR. LAKSHMANAN:

Yes. This gives a better orientation. This wound is in front of injury no. 1 of G-40 and it is behind the right terminal portion of injury no. 1 of G-37 which is one of the superficial cuts to the front of the neck which we discussed earlier.

648 MR. KELBERG:

Did Dr. Golden address in his original protocol both injury no. 2 of G-40 and injury no. 1?

649 DR. LAKSHMANAN:

Yes, he did.

650 MR. KELBERG:

How did he, in essence, describe them, before we look at the actual paperwork?

651 DR. LAKSHMANAN:

He described them as communicating and he described them as being possibly entrance and exit of one wound, but in the addendum he describes them that they could be separate wounds.

652 MR. KELBERG:

In the original protocol, let's put that up then and see what he said and follow up with the specific questioning.

653 (Brief pause.)
654 MR. KELBERG:

Where, doctor, on the protocol?

655 DR. LAKSHMANAN:

It is page 4, no. 2, and page 5.

656 MR. KELBERG:

Let's see if we can--without impaling Mr. Lynch, if I hold this and I watch myself with Mr. Darden and Miss Clark, what page I'm sorry, doctor?

657 DR. LAKSHMANAN:

Page 4, no. 2. Start here, (indicating).

658 MR. KELBERG:

You are saying item no. 2?

659 DR. LAKSHMANAN:

Yes.

660 MR. KELBERG:

Down at the bottom of the page?

661 DR. LAKSHMANAN:

Then it goes on to page no. 5.

662 MR. KELBERG:

All right.

663 MR. KELBERG:

Before we turn the page, Mr. Lynch, if you could give me a marker to the right of my notebook and let me outline this. As the description starts, doctor, is Dr. Golden referring to injury no. 1?

664 DR. LAKSHMANAN:

He is actually starting with injury no. 2. If you go on, I will show you the next page.

665 MR. KELBERG:

All right. Well, let me outline it then and so this is going to be "G-40 inj. Numbers 1 and no. 2."

666 DR. LAKSHMANAN:

Yes.

667 MR. KELBERG:

And I will put also "G-55 and G-50" and that would be "Injury no. 2, inj. No. 2."

668 MR. KELBERG:

Is that correct, doctor?

669 DR. LAKSHMANAN:

Yes.

670 MR. KELBERG:

All right. Now let's flip.

671 DR. LAKSHMANAN:

He actually starts describing as a complex wound and then he says: "The initial wound present is present on the right side of the neck over the sternocleidomastoid muscle, three inches below the right auditory canal measures 5/8 of inch in length."

672 MR. KELBERG:

Let me stop you. That is a reference then specifically then to injury no. 2?

673 DR. LAKSHMANAN:

Yes.

674 MR. KELBERG:

All right. And let me underline "After approximation of the edges measures 5/8 inch in length" and I will write out on the left border "G-40 inj. No. 2."

675 MR. KELBERG:

Go on if you would, please, doctor.

676 DR. LAKSHMANAN:

Then he says that: "The wound path is through the skin and subcutaneous tissue without penetration of injury of a major artery or vein."

677 MR. KELBERG:

Let me stop you there. Does that have significance to you in evaluating whether either injury no. 1, as you describe it, or injury no. 2, as you describe it, are fatal wounds?

678 DR. LAKSHMANAN:

They are not fatal wounds.

679 MR. KELBERG:

Either one of them?

680 DR. LAKSHMANAN:

That's correct.

681 MR. KELBERG:

Go on, if you would, please.

682 DR. LAKSHMANAN:

"The direction of the--the direction is front to back and upward, for a total wound path of two inches and the wound exits on the right side of the back of the neck, posterior to the right sternocleidomastoid muscle where a two-inch gaping long incise wound is evident on the skin."

683 MR. KELBERG:

Let me stop you at that point. I'm going to underline the part about the direction that you have just read.

684 MR. KELBERG:

And would it be accurate where it says, "And the wound exits on the right side of the back of the neck," that Dr. Golden is referring to what you've described as injury no. 1?

685 DR. LAKSHMANAN:

Yes.

686 MR. KELBERG:

So let me write to the left of this "G-40 inj. No. 1."

687 MR. KELBERG:

All right. Continue, if you would, please, doctor.

688 DR. LAKSHMANAN:

And he says that: "Superiorly there is an one-inch incise wound extension and inferiorly there is a two-inch long superficial skin extension inferior toward the back of the neck." It is reference to this cut here, you see here, (indicating).

689 MR. KELBERG:

Doctor, you may be blocking the view of some of the juniors on that end. Would you point out again, please.

690 DR. LAKSHMANAN:

He is referring to this cut he sees here, (indicating).

691 MR. KELBERG:

That is that this two-inch wound superficial skin extension?

692 DR. LAKSHMANAN:

Yes.

693 MR. KELBERG:

So this is all a matter that you would associate with the injury no. 1 of G-40?

694 DR. LAKSHMANAN:

Yes.

695 MR. KELBERG:

Let me--I'm sorry.

696 MR. KELBERG:

Do you want to add something?

697 DR. LAKSHMANAN:

This one inch is one going to the back and this two inches is the one going here toward the base of the neck, toward the base of the neck here, this one, (indicating), which is actually part of six-inch wound injury no. 2 of G-37.

698 MR. KELBERG:

Is one of G-37, doctor?

699 DR. LAKSHMANAN:

It says--

700 MR. KELBERG:

If I can show you the photograph.

701 DR. LAKSHMANAN:

This is the--this one, (indicating).

702 MR. KELBERG:

The lower incise wound?

703 DR. LAKSHMANAN:

Of G-37.

704 MR. KELBERG:

And the extension of it as seen in G-40 is--

705 DR. LAKSHMANAN:

Here he says a two-inch extension here, (indicating), going inferiorly toward the base of the neck, and this is the one-inch extension to the back of the head.

706 MR. KELBERG:

Would it be accurate to say then that where he is describing inferiorly there is a two-inch long extension that actually he refers to injury no. 2 of G-37?

707 DR. LAKSHMANAN:

If you recall, he didn't have a measurement for it in the original protocol.

708 MR. KELBERG:

Let me box that in blue and I will write "G-37 inj. No. 2."

709 MR. KELBERG:

Anything further with respect to his description?

710 DR. LAKSHMANAN:

This one, the one-inch extension belongs to injury number--

711 MR. KELBERG:

1?

712 DR. LAKSHMANAN:

Yes.

713 MR. KELBERG:

All right. Let me mark that in and I will outline that so that this is "G-40 inj. No. 1."

714 DR. LAKSHMANAN:

Yes.

715 MR. KELBERG:

Okay, doctor. That is basically the description?

716 DR. LAKSHMANAN:

Yes.

717 MR. KELBERG:

Doctor, in essence, and let me hold this out, hopefully without hitting anybody, in essence has Dr. Golden done the same thing with regard to injuries numbers 1 and 2 of G-40 that he did with respect to injuries 1 and 2 of G-51, that is, he has described them as all part of one wound?

718 DR. LAKSHMANAN:

Yes, he did.

719 MR. KELBERG:

In your opinion is he wrong?

720 DR. LAKSHMANAN:

Yes.

721 MR. KELBERG:

Why?

722 DR. LAKSHMANAN:

Because he has described this smaller 5/8 inch wound exiting in the back here, (indicating). I think they are separate wounds because you need to explain this cut abrasion which is going above the wound.

723 MR. KELBERG:

When you say the cut abrasion above the wound, you have been pointing--

724 DR. LAKSHMANAN:

Which would only--which is part of injury no. 1 of G-40. You can see it here better, but I only concurred the knife was penetrating there, rather coming out, because there had to be a separate entrance and that could be a separate entrance sharing injury no. 2, could be a separate entrance.

725 MR. KELBERG:

In your opinion is it a separate entrance?

726 DR. LAKSHMANAN:

Yes.

727 MR. KELBERG:

Doctor, is this a mistake on Dr. Golden's part to have formed the opinion that he expressed in the autopsy on page 5?

728 DR. LAKSHMANAN:

Yes, and I think he changed his opinion in the addendum.

729 MR. KELBERG:

Is this a mistake which you consider significant to you in forming any of your opinions on cause of death, manner of death, single-edge knife, single perpetrator, bleeding and so forth?

730 DR. LAKSHMANAN:

No, because he has described the wound which you can make those determinations possibly the one with the 5/8 inch wound and they did not cause death because they did not injure any major vessels, so they don't play a role in the big ticket items which we have discussed several times before.

731 MR. KELBERG:

Doctor, in your knowledge of anatomy are you able to say that Dr. Golden has accurately described the absence of a fatal injury to a vein or an artery in that area?

732 DR. LAKSHMANAN:

Yes, because--yes.

733 MR. KELBERG:

Why?

734 DR. LAKSHMANAN:

Because he has described accurately what happened on the left side. If you look at the internal diagrams, he described the internal jugular vein injury and said that the carotid artery was not injured and he has also diagrammed them.

735 MR. KELBERG:

Now, doctor, is--in Dr. Golden's description of the direction, if--because I'm going to have to put this down momentarily before we have an accident here--I want you to keep that in mind, because I'm going to ask you with the ruler--thank you--can you basically use the ruler and again myself to represent Mr. Goldman to give the orientation on the right side that Dr. Golden describes for injuries numbers 1 and 2 of G-40?

736 DR. LAKSHMANAN:

Yes.

737 MR. KELBERG:

And I would like whatever side of mine that you need to be toward the jury box so they will be able to see.

738 DR. LAKSHMANAN:

Umm, you want me to demonstrate both injury no. 1 and 2?

739 MR. KELBERG:

I would like you, if you can, to demonstrate the wound path, the direction as described by Dr. Golden, with respect to these two injuries?

740 DR. LAKSHMANAN:

Yeah. He describes that this wound entered in a front to back direction.

741 MR. KELBERG:

Okay.

742 DR. LAKSHMANAN:

That is injury no. 2 which is the 5/8 inch wound we discussed and it came out here in the back, as this wound here, (indicating), as injury no. 1, and the path in the body was two inches without injury to the artery or vein.

743 MR. KELBERG:

Doctor, if you could just get back into position briefly so we can describe this for the record.

744 (witness complies.)
745 MR. KELBERG:

Your Honor, with Dr. Lakshmanan behind me and slightly to my right and holding the ruler in his right hand, he has placed what appears to be about three or four inches of the ruler extending from his right hand against my neck on the right side with the ruler at a downward angle away from my neck and the angle appearing to me to be approximately 45 degrees from the horizontal.

746 THE COURT:

Yes.

747 MR. KELBERG:

And then, doctor, the exit as described by Dr. Golden--

748 DR. LAKSHMANAN:

Was here in the back here, (indicating).

749 MR. KELBERG:

And you have pointed, for the record, to the back of the right side of my neck?

750 THE COURT:

Yes.

751 MR. KELBERG:

Thank you.

752 THE COURT:

Mr. Kelberg, three o'clock.

753 MR. KELBERG:

Whenever the Court wishes.

754 THE COURT:

Three o'clock.

755 MR. KELBERG:

Now, you said, doctor, that--first of all, let's ask if Dr. Golden diagrammed either/or both of what you describe as injury no. 1 and 2?

756 DR. LAKSHMANAN:

Yes, he did.

757 MR. KELBERG:

Where?

758 DR. LAKSHMANAN:

In diagram 22-II.

759 MR. KELBERG:

All right. Let me put up 4G again and let's see if we can flip to--

760 DR. LAKSHMANAN:

You see, this is the diagram 22-II, left lower quadrant. This is 2, and you can see the--this is the 5/8 inch wound here, (indicating), and this is the wound we just discussed--

761 MR. KELBERG:

As injury no. 1?

762 DR. LAKSHMANAN:

Yes, and this is the two-inch extension which is actually going down here, (indicating), which if you look at the photograph, it really is part of injury no. 2 of G-37.

763 MR. KELBERG:

Before you run further, if Mr. Lynch could hand me the marker? Let's see if we can mark these things as we go. Doctor, what you started with was where I am right now, correct?

764 DR. LAKSHMANAN:

Yes.

765 MR. KELBERG:

And let me circle this and I will run it out to a clear area and this is "G"--

766 DR. LAKSHMANAN:

--40.

767 MR. KELBERG:

"40 inj. No. 2," correct?

768 DR. LAKSHMANAN:

That's correct. That's correct.

769 MR. KELBERG:

All right. Then you pointed to an area right there?

770 DR. LAKSHMANAN:

Here, (indicating).

771 MR. KELBERG:

Let me circle that area in red and to a clear area. That is "G-40 inj. No. 1."

772 MR. KELBERG:

Is that correct?

773 DR. LAKSHMANAN:

Yes.

774 MR. KELBERG:

And then you pointed to a third area?

775 DR. LAKSHMANAN:

This is two-inch cut which goes to the base of the neck, (indicating).

776 MR. KELBERG:

And this is actually, as you described it, injury no. 2 of G-37?

777 DR. LAKSHMANAN:

If you look at the photograph, that is how it looks.

778 MR. KELBERG:

So I'm going to write in blue out at the side "G-37 inj. No. 2."

779 DR. LAKSHMANAN:

And this is that one-inch cut which he describes as going to the back of the neck which you can see in G-40 very well here, (indicating).

780 MR. KELBERG:

And that you associate with injury no. 1; is that correct?

781 DR. LAKSHMANAN:

That's correct.

782 MR. KELBERG:

There appears to be a lot of writing surrounding this area. Can you give us an interpretation of that writing?

783 DR. LAKSHMANAN:

Yes. This is "Sharp force, stab wound, diagonal, three inches below the right ear canal." That is the arrow going downwards. And then this is the a 5/8 inch wound. He has described the forked wound very clearly.

784 MR. KELBERG:

Let me stop you here. Is this a diagram of what would be injury no. 2?

785 DR. LAKSHMANAN:

Yes.

786 MR. KELBERG:

All right. Let me circle that.

787 MR. KELBERG:

And the 5/8 you have already described as the length of the wound?

788 DR. LAKSHMANAN:

Yes.

789 MR. KELBERG:

And the 1/16 dealing with the forking end?

790 DR. LAKSHMANAN:

That's correct.

791 MR. KELBERG:

All right. Let me circle that.

792 MR. KELBERG:

And this is again "G-40 inj. No. 2"?

793 DR. LAKSHMANAN:

Yes. Actually all this belongs to the same wound.

794 MR. KELBERG:

All of--

795 DR. LAKSHMANAN:

All the handwriting there. This is the external auditory canal "EAC."

796 MR. KELBERG:

I will circle it so it is all connected and make another line--

797 DR. LAKSHMANAN:

Okay.

798 MR. KELBERG:

--that way.

799 DR. LAKSHMANAN:

And this is the--this is two-inch long stab wound here, (indicating), and this is one-inch extension. This is the "L" and "1."

800 MR. KELBERG:

"L-1" means what?

801 DR. LAKSHMANAN:

Length, one inch, and "L-2" means it is abbreviated length, two inches.

802 MR. KELBERG:

And the--the additional writing at the bottom was?

803 DR. LAKSHMANAN:

This is the L-2, two-inch extension which I interpret as injury no. 2 of G-37.

804 MR. KELBERG:

So that aspect goes to this over here, (indicating)?

805 DR. LAKSHMANAN:

Yes, and these two go to injury no. 1 of G-40.

806 MR. KELBERG:

Let me circle that in red and have it join the line up here where we have a designation of "G-40, injury no. 1."

807 MR. KELBERG:

Doctor, has Dr. Golden accurately described what is seen in the photographs, separate and apart from an interpretation of the correlation, if any, between the injuries?

808 DR. LAKSHMANAN:

Yes, but as I told you, the cut abrasion on the surface of injury no. 1 has not been described, which is important for me to opine that it is a separate penetration rather than an exit. That is where this cut penetration you see--I mean, this cut abrasion. You cannot get it in an exit. It has to be a separate penetration there.

809 MR. KELBERG:

How is that inflicted as a separate penetration? Again, if you could use the ruler and use me as Mr. Goldman, demonstrate for us.

810 DR. LAKSHMANAN:

When you--as I told you, as a hypothetical, when the threatening cut took place and we--in my hypothetical explanation, and the knife was drawn here, (indicating), and I said a penetration could have taken place at that point and then the sudden movement of the victim while trying to wrestle away, the knife would come out. And then because of the movement of the knife and the body you could get the cut abrasion which favors that being an entrance and not an exit, because you cannot get a surface marking on the skin from an exit.

811 MR. KELBERG:

And so when we were doing a demonstration last week where you instructed me to pull away from you, it is in that pulling away and the twisting process that, in your opinion, one gets that appearance?

812 DR. LAKSHMANAN:

That would be one way would you get it.

813 MR. KELBERG:

Okay. What are other potential ways you can get that?

814 DR. LAKSHMANAN:

Well, before the perpetration itself there could have been movement and you could get a cut abrasion and then the penetration could have taken place, holding the person tighter, so there are different mechanisms. But what I wanted to drive home the point, to see a surface wound like that would favor this is a surface entrance and not an exit.

815 MR. KELBERG:

Your Honor, I believe the Court wishes to take a break.

816 THE COURT:

Ladies and gentlemen, we are going to take a 15-minute recess at this time. And remember all of my admonitions to you. Do not discuss the case among yourselves, form any opinions about the case, conduct any deliberations until the matter has been submitted to you or allow anybody to communicate with you with regard to the case. We will stand in recess for fifteen minutes. All right.

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
If it is a rough glove, the glove also could do the same type of abrasion.
Unprompted addition connecting a Goldman abrasion to a glove — potentially relevant to the defense glove narrative, introduced during discussion of injury to Goldman's neck.
Dr. Lakshmanan Sathyavagiswaran
There is no cut there, and this blood clot is probably related to the cut on the earlobe.
Direct contradiction of Dr. Golden's characterization of a wound as a cut versus an abrasion, reinforcing Kelberg's theme that Golden made consistent documentation errors.
Brian Kelberg
Is this a mistake, doctor, that you consider significant to you in evaluating the big ticket questions?
Recurring refrain used throughout the examination to neutralize defense attacks on Golden's errors by pre-emptively establishing that the mistakes are inconsequential to conclusions.
Dr. Lakshmanan Sathyavagiswaran
It is a triangular-shaped abrasion which is a blunt force type injury... there are some branches which are cut plant branches, some of them could have caused this kind of injury.
Provides alternative explanation for blunt-force abrasions consistent with the crime scene vegetation, contextualizing Goldman's injuries beyond the knife.

Evidence (8)

G-51
Photograph of Ron Goldman's neck and face showing multiple wounds
discussed extensively; injuries numbered 1-12 identified and analyzed
G-53
Close-up photograph of Goldman's neck/ear area
discussed; used to confirm abrasion orientation and identify injury no. 10
G-37
Photograph of Goldman referenced for prior injury discussion
referenced briefly; abrasion below injury no. 2 revisited
People's 358
Exhibit board referenced by Judge Ito at opening
identified as reference board for wound diagram
Informal
Dr. Golden's autopsy protocol pages 4 and 7
read aloud and annotated on courtroom board; errors in injury classification noted
Informal
Dr. Golden's addendum, page 4
referenced for injuries 8 and 9; compared against Lakshmanan's photographic analysis
+ 2 more

Notable Exchanges (3)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg read Golden's grand jury testimony describing a single six-inch connected stab wound through Goldman's neck and ear, then asked Lakshmanan if that was erroneous. Lakshmanan confirmed it was, for the same reasons he had already explained regarding the addendum correction to two separate wounds.
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
After Lakshmanan mentioned a fingernail as a possible cause of a particular abrasion, he volunteered that a rough glove could also produce the same result. Kelberg followed up to establish the mechanism.
revealing
Brian KelbergLance A. Ito
Throughout the session, Kelberg regularly asked the judge to let the record reflect the locations of wounds and annotations being made on courtroom boards, with Ito consistently confirming. This created a meticulous evidentiary record of the wound mapping.
procedural

Credibility Attacks (1)

⚔ Dr. Irwin Golden
Prior inconsistent findings / professional error pattern
Kelberg and Lakshmanan systematically documented a series of errors in Golden's original autopsy protocol and grand jury testimony: misclassifying an abrasion as a cut (injury no. 10), failing to diagram injuries nos. 6, 7, 11, and 12, and erroneously describing three separate wounds as a single six-inch connected stab wound in grand jury testimony. Each error was acknowledged by Lakshmanan as a mistake, but each time he stated it had no significance on the 'big ticket' questions — a deliberate prosecution strategy to inoculate against defense attacks on Golden's credibility.

Witness Demeanor

(Brief pause.) — witness paused to recount injury numbering before confirming injuries went through no. 12)
(Brief pause.) — pause while counsel retrieved diagrams for display)
Witness repeatedly had to be reminded by Kelberg to keep his voice up

Objections

None recorded
Proceeding 6342 • 816 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 12, 1995 📄 Direct examination of Dr. Laks
JUN 12, 1995 KRT DvH TD