Doctor, I think you mentioned that Dr. Golden addresses in his addendum this relationship between injury nos. 1 and 2 of G-40; is that correct?
And again, let's try another easel for a change in perspective. Could you step down and tell us where in the addendum Dr. Golden addresses those two particular injuries?
(the witness complies.) Page 3, no. 6. Starts as the last paragraph here, "Page 4, item 2, lines 1 and 2, and page 5, paragraph 1, amended as originally stated." It starts here (indicating).
All right. Now, were you pointing, doctor, under subpart 6 of page 3? And Dr. Golden starts, "There is a sharp force wound on the right side of the neck 3 inches directly below the external auditory canal." Is that injury no. 1 or injury no. 2 as we look at it?
And for that--for the record, your Honor, I'm going to outline in red that box of information. On the right-hand side, I'll write "G-40 inj. No. 2."
Now, before we flip the page, has the sentence, "This wound connects," and let me underline the word connects, "With a sharp force wound on the right," and I'll underline that as well. Is this sharp force wound on the right what is described as injury no. 1?
So before we turn the page, I'll write a little arrow, "G-40 inj. No. 1." And now let me continue flipping the page.
And it goes on to say that right side of the neck 2 inches posterior, and it says that the wound is 2 inches in length, this all referring to injury no. 1 of G-40, and says that the posterior portion presents an incised wound 1 inch in length, which is that extension we've discussed, and the anterior end is rounded, and then he describes that it intersects, intersects with the transversely oriented incised wound of the front of the neck, which is injury no. 2 of G-37, injury no. 2 of G-37.
All right. Let me outline that just briefly in red on page 4 of the protocol 0G, and I'll write "G-37 inj. No. 2." Is that correct, doctor?
There's fresh hemorrhage and bruising and no major artery or vein is severed or injured.
Now, doctor, does paragraph no. 8 or item 8 of this same page also refer to injuries 1 and 2?
And is that a procedural thing for us? Mr. Lynch can put the protocol up on the other easel and flip to page 5.
And that's going to be deleted pursuant to that entry that you just outlined in the addendum?
All right. Let me outline these two entries on page 5 of the protocol and at the side write, "Amended by addendum, page 4"?
I'll write "Items 7 and 8." Doctor, in your opinion, does the description provided in the addendum on pages 3 and 4 accurately describe those two injuries, injuries 1 and 2 of G-40?
And let me then write by boxing in blue on page 4 that this is G-40, and this is inj. No. 1; is that correct, doctor?
And then let me outline 7 and 8, and at the side, I'll write "G-40 inj. No. 1 and no. 2." Is that accurate?
And I'll just write a little red line, make a red line to separate it from the entry below that. Doctor, is that opinion expressed in item no. 8 in the addendum accurate in your judgment as to those two injuries, injuries 1 and 2?
Is there anything further with respect to the protocol or the addendum concerning injuries 1 and 2?
Doctor, is a single-edged approximately 6-inch long knife consistent with inflicting both of those injuries?
While we have the charts up, there was one additional chart I did not ask you about.
And the previous--the addendum I think has been marked as 4--10G--excuse me--that we were looking at. Doctor, there's a form 24 page that is the first page of this particular board, and in the upper left-hand quadrant, there appears to be an entry made. What does this refer to?
This refers to the internal injuries which Dr. Golden saw. This is sharp force injury, neck. He says then transection of the left internal jugular vein and the left common carotid artery being intact. LCCA stands for that. And he says the right side is within normal limits and negative also in the front. There's no injury to the larynx.
The injury that he is describing in the upper left quadrant, is that injury no. 1 of G-37?
Let me outline all of that, and I'll "Write G-37 inj. No. 3" and "G-51 inj. No. 1." Now, doctor, what does the rest of this diagram refer to, "Within normal limits," "Negative" and so forth?
That would have one meaning to that, and also it shows that there's no injury to those structures.
Doctor, would it be accurate to say that that wound that you described as the last sharp force injury inflicted on Nicole Brown Simpson seen in I believe B-13, 16 and 18 was a deeper wound than the wound that you described as a fatal wound, no. 3 of G-37, to Mr. Goldman's neck?
It's difficult to make that kind of judgment because in Miss Brown Simpson, the knife went across the neck up to the spine and there's no specific depth given, whereas for the wound on the left side of the neck of Mr. Goldman, at least a 4-inch track because it communicates with the left--behind the left ear. So it's difficult to make that kind of conclusion.
KEY QUOTENo. It just emphasizes the internal injury on the left side and no vascular injury on the right side.
We'll just leave the protocol up and ask you if we could to go back now to photograph G-40 and talk about, if you have not already, additional wounds or injuries you see in that photograph.
We have a sharp force injury to the back of the right side of the head. We have a sharp force injury to the--behind the right ear here (indicating). We have another sharp force injury just near the back of the right earlobe, and then there's an abrasion in the area of the skin between injury no. 1 of G-40 and the ear, which you can see here. And G-50 shows the injuries to the ear very much better, a closer photograph of the two sharp force injuries behind the right ear, and G-55 shows the same sharp force injury to the back of the right side of the head. Doesn't show the cuts behind the ear because it's--the ear being seen on the side, but it does show the abrasion in the skin between the injury no. 1 of G-40 and the ear.
Doctor, let's see if we can talk about these individually. Have you numbered them again with respect to these photographs in some arbitrary fashion?
Yes. I labeled this sharp force injury to the back side of the right side of the head as injury no. 3.
It's caused by a knife. It's 5/8 inch long and it was situated to the right side of the back of the head.
If you'll keep your voice up, please, doctor. In your opinion, is this caused by a knife?
Is it still consistent with your 6-inch approximately long single-edged knife blade?
Are you able to tell the relative positions of Mr. Goldman and the perpetrator at the time that sharp force injury was inflicted?
Well, it could be inflicted if Mr. Goldman is ducking if the perpetrator was in the front. It could be if the perpetrator was in the back and cut Mr. Goldman in the back during the initial other wounds which are the back of the neck.
Doctor, again using the ruler and myself to represent Mr. Goldman, can you demonstrate these alternatives you've just described in a general way?
Want to put down your pointer and your paper, and let's see if Mr. Lynch can put those on the table.
If it was in the back, it could be a cut like--a cut like this (demonstrating).
Now, are you talking about in your scenario with the control hold and the two superficial incised wounds? Is that about that time?
Yes. And this cut could have occurred at the same time this cut occurred in the back of the ear (indicating). They are about the same level.
And how could that cut have been inflicted with the perpetrator behind Mr. Goldman and this injury no. 3 to the head?
They could be separate cuts, but they could have been in the same force when--I mean the same motion which occurred.
With the--there's been--as I told you, all the sharp injuries, sharp force injuries are due to a dynamic process. You have movement of the head and movement of the blade. And if--when the head--when the knife is in contact with the head or the head moves, you can also strike the right ear at the same time because the wound is right here in the back (indicating)--
I'm sorry. Would you turn around and show the ladies and gentlemen of the jury where that--and you're talking about this injury no. 3 in photo G-40 is where you are going to be pointing in a moment?
Your Honor, for the record, the witness has pointed to an area that is slightly above the top of his right ear and to the left of that approximately 2 inches.
Well, I'm just pointing to my back of my head. So the picture is there and it's quite--
And then there's another cut here (indicating). So this could have been--have occurred when the perpetrator is in the back, when the perpetrator was in the back of Mr. Goldman. And the other way it could have happened is if the perpetrator was from the front and wielding a knife, the head was tucked and trying to avoid the knife, cut--the back of the head could have been cut too.
Can you demonstrate--you tell me what to do to represent Mr. Goldman and you be the perpetrator--how that can be inflicted?
From wielding the knife like this and coming against you, and you bend your neck or bend your head downwards, you can cut the head like this right in the back (indicating).
Your Honor, for the record, facing me, Dr. Lakshmanan, with the ruler in his right hand, took several side-to-side motions as he was talking about wielding the knife. I ducked my head in a forward and downward direction. Dr. Lakshmanan with his right hand, holding the ruler, then came I believe with a somewhat overhead motion in the direction of the top of my head, and I felt some grazing of the ruler over the top of my head.
Bottom line is, you can not really tell with definite certainty which kind of movements caused these type of wounds. But these are some possibilities which one could hypo--opine.
KEY QUOTEDoctor, would it be accurate to say that these alternatives that you've suggested are consistent with the physical findings that you can see from the photographs and the autopsy materials?
Your Honor, I believe we've lost some aspect of the microphone that goes here. So--
Is this also shown in another photograph that gives a closer perspective of that?
By the way, is this process of exposing the injury part of the postmortem shaving that you described earlier?
Doctor, is this injury, this sharp force injury no. 3 addressed in Dr. Golden's original protocol?
No. I only describe three injuries under G-40 and actually I describe the injuries in the--behind the ear in G-50, actually in G-50.
All right. The injuries behind the ears are more closely shown in photograph G-50?
Tell us about those. If you can start with some numerical designation and take us through your description.
The larger cut in the back of the right ear is injury no. 1 in G-50, it's about three-quarters of an inch in length, and the smaller wound in the right earlobe is quarter inch in length, and the ear has been--the photograph has been taken of the right ear in a close-up manner so the injuries can be perceived better.
Doctor, using my right ear, can you demonstrate what is being done to expose that area?
Like this so that you can see the cut better behind the right ear and the earlobe (demonstrating). That's what's being done right here.
For the record, your Honor, the doctor with his right hand has pulled the large part of my right ear forward--in a forward direction.
Are you able to determine from its appearance whether it is a single-edged knife or could be also from a doubled-edged knife?
But still consistent with the hypothesized single-edge 6-inch long approximately knife blade?
That's a smaller cut behind the right earlobe, and that's quarter inch in length.
Now, doctor, you mentioned I think some other injuries in both 40 and 55, at least showing them to some degree, and I want to invite your attention, is there an injury in the area of the left--I'm sorry--of the right lower ear area?
And does that have possible significance with respect to either or both injuries 1 and 2 as shown in photo G-50, the ear injury?
It could have significance to the ear, to the injury behind the right earlobe, which is injury no. 2 of G-50. What we have here in the side of the head is a penetrating injury which went to the temporal bone, which is the bone underlying this area of the face (indicating).
This injury is right here in front of the right ear in the earlobe area (indicating) and--
For the--I'm sorry. For the record, your Honor, the doctor was pointing to an area above the bottom of his ear about a third of the way up towards the top of the ear and just adjacent to where the ear joins the face.
About an inch deep up to the temporal bone and stops there. So this injury no. 2 behind the right earlobe which is seen in G-50 could be related to this wound, but I can not exclude them from photograph as not being separate wounds.
What would you be able to do as the autopsy surgeon if anything which would have allowed you to determine whether in fact there is a relationship between this penetration to the temporal bone area and this injury no. 2 to the right ear?
You would see it communicate because what you're seeing is, because the wound goes through the earlobe like this (indicating)--
And since this is a reflected portion of skin, you will see a cut on the inside because of the same penetration. So it could be related, but I can't tell from the photographs.
Does he describe it in a way which allows you to correlate, if there is a correlation to be made, that sharp force injury with this injury no. 2?
No. His description basically gives the course in the body. I'm just giving an opinion based on the photographs, the location and my experience with such injuries.
Would it be accurate to say that Dr. Golden has not provided you with sufficient information to form an opinion as to whether a correlation exists between those two?
Does Dr. Golden address this injury and have you given it a number, and if so, which photograph?
Yes. I can't find the number I gave it. But it's described in the protocol. I can't find the number for it, but it's in the protocol.
So, doctor, what you've just been talking about is this penetrating sharp force injury to the temporal bone is described as injury no. 6 of G-55?
All right. And that sharp force injury, again, can't tell between single edge, double edge?
And with respect to G-55, other than the injuries to the face, are there other injuries that you have not discussed at this point that are apparent in that photograph?
Your Honor, the doctor on photo G-55 has pointed to an area that appears to be midway between the bottom of the right ear and the top of what has been marked as that injury no. 1, sharp force injury as seen in G-40.
It's just a faint abrasion which is seen between the injury no. 1 of G-40 and the right ear. And there's no other sharp force injury in the skin in this area, but there's a sharp force injury which was described in the report.
Before we get to that, how are you able to determine that that is an abrasion rather than a sharp force injury?
By the same examination I did with the other injuries; use a magnifying glass, and you can see whether there's a split in the skin or not. And there's no split. There's only a scrape in the skin.
Do you have an opinion as to what source or sources could be responsible for that?
That's a non-specific blunt force injury and it could be from the plant material which we have discussed before which you see in the crime scene area, and could be one of those cut branches.
Does Dr. Golden have some indication in the form of a diagram or something in the protocol or both for that area describing something that you do not see in these photographs; in particular G-40 and G-55?
He has described a cut there which is 3/4 of an inch long behind the right ear parallel to the sternomastoid muscle which is not seen in the photographs.
While we've got the photos up, which diagram did Dr. Golden use to show that particular--
All right. And, doctor, the location where Dr. Golden has made that what appears to be a vertical line--do you see that?
Is that the same location in general terms anatomically as the location where you see what you describe as an abrasion?
Is it diagrammed though in the positional aspect the same as the abrasion appears in the photograph?
And the measurement--did you try and measure from the life-size photo that faint abrasion?
In your opinion, doctor, can the process of photographic measurement account for the difference between your measurement and that of Dr. Golden?
In your opinion, is it a mistake for Dr. Golden to have concluded, if he is looking at what you describe as this abrasion, to describe it as a cut?
Your Honor, let me, if I could for the record, circle in red that area including the written entry on form 22-I, and I'll write g--
Let me write "G-55 inj. 7," but I'll write "Cut" in quotes rather than "Abrasion."
I'm going to box that on page 6 of the protocol. I'll write "G-55." And this is inj. No. 6?
Yes. No. 7 actually because we discussed no. 7--no. 7 is a faint abrasion in the--in the--so it would correspond in the protocol to injury no. 7.
I'm sorry. Injury no. 7, and I'll write "Cut" in quotation marks rather than "Abrasion." Is that accurate?
Let me just make sure, doctor, that we have--yes. We have it correctly identified in form 22. Any significance to this description in your judgment and evaluating any of the big ticket issues?
All right. If we could put the photos back up then. Now, doctor, other than the faint abrasion, have we covered G-40--I'm sorry. With the faint abrasion, have we covered all the injuries in G-40?
And in fact, injuries no. 1 and 2 that you've identified from G-50 are seen to some extent in photo G-40; is that accurate?
All right. Anything further with respect to photograph G-50 as to any finding or injury?
No, except that the facial injuries, some of them are seen here which we're going to discuss later.
Okay. Let me just finish then with--you described these as injuries 1 and 2 of G-50; is that correct?
Yes. And the addendum page no. Is page 4, no. 11 and 12. Page 4, no. 11 and 12.
And "G-50 inj. No. 2." Doctor, do each of these paragraphs actually describe in your opinion the nature of those two injuries of photograph G-50?
Is there anything further to discuss regarding the addendum and those two injuries?
Doctor, before we get to the facial injuries--I'm--you wanted to point to something.
No. We have not addressed this injury to the right ear, injury no. 6 in the protocol in the diagram.
Let me just outline that in red, "G-55 inj. No. 6." Doctor, in your opinion, does that entry actually describe that particular injury?
And is it your opinion that Dr. Golden's opinion that this is a nonfatal stab wound is accurate?
And what if any--I'm sorry. What if anything has Dr. Golden written concerning that particular injury?
Says stab wound right here, lobe, one and a quarter inches right to left depth, and he has described the one-inch length and the forked ends, both ends, and he--the--he also indicates that the stab wound went from the ear to the temporal bone. So this whole description and this arrow here in the right side of the head would correspond to injury no. 6 of G-55 (indicating).
And up in the upper left-hand corner, I'll write "G-55" and underneath that "inj. No. 6."
Doctor, does that accurately in shorthand form diagram and describe that particular injury?
Doctor, are we done then with respect to all injuries on all of the photographs of our exhibit 358 with the exception of the facial injuries as seen in photographs G-55 and G-50?
Your Honor, I have another small board of photographs. May this be marked as exhibit 360? It appears to have a title "Sharp force injuries and blunt force trauma to head of Mr. Goldman."
And, doctor, on this particular exhibit, we have two photographs, one of which appears to have the designation G-48 and another that has a designation of G-49. Can we start with G-49, the one to the right, and tell us what if anything of significance you see in that photograph.
G-49 is the back of the head of Mr. Goldman and shows a superficial quarter inch cut to the back of the head.
Now, where--first of all, using yourself--or why don't you use me. Would you point out where that area of the head is?
And the doctor is pointing to what feels like slightly to the left of the midline of my head up near the top of my head.
Doctor, where in relation--can you hold that pointer wherever you had it and also point to the injury to the back of the head or the head somewhere that's seen in G-40, injury no. 3 of G-40?
G-40 injury is somewhere here. The G-49 injury is somewhere here, this region (indicating).
And as long as we've got me in this position, do you see a second injury in G-49?
Yes. You see it left of it and slightly to the front of it. In this region here, you have am abrasion contusion, which is a scrape (indicating).
And so those are the three injuries to the head in your review of the autopsy materials in Mr. Goldman that were identified?
Yes. You have a cut to the back side of the right side of the head which you have discussed, a smaller cut now which I've just discussed here, and then you have abrasion contusion to the left side of the head, which is actually seen better in G-48.
Let's talk then first of all about the first injury that's seen in G-49 as you've described it. A sharp force injury that you described as a cut?
And again, the hypothetical, single edge, 6-inch long approximate blade would be consistent with doing that?
Doctor, are you able to tell from that injury the relative positions of Mr. Goldman and the perpetrator at the time that injury was received?
Doctor, is it the same situation as you demonstrated with me regarding alternatives, for example, for the injury that's seen in G-40 to the head?
The other injury--can you give us an orientation, G-48, what we're actually looking at there?
You're looking at the top of the left side of the head. You can see the nose here (indicating).
In the lower left corner, your Honor, of the photograph where the light color meets a border that appears to be a lightish blue color in the photograph.
And the doctor has with the pointer made a horizontal tracing of a small area from the left margin of the skin towards the center of the skin area reflected or shown in that photograph.
You also see the hair in the top of the head falling on the forehead here (indicating).
And that area is where in the photograph--in the lower part of the photograph, the hair seems to end over the skin area; is that correct, doctor?
Yes. And you can see the left earlobe here (indicating). I mean ear, not earlobe, portion of the upper part of the left ear on the right side of the photograph.
And that is where the skin apparently comes photographically in contact with the hair below the injury that's shown in the center of the photograph; is that correct?
Yes. And the injury is above the left ear on the left side of the top of the head. And to show it on my head, it will be somewhere in this region (indicating).
Again, on the left side, your Honor, and perhaps four inches above the top of the ear?
That is a blunt force injury. It's an abrasion contusion. That is you have a scrape and underlying bruising of the skin.
And do you have an opinion as to the potential source or sources for that contusion abrasion?
It's a blunt force injury and could be from a rough surface. There are several areas in the crime scene photograph which could account for that.
We may come back to that then when we look at the other blunt force trauma injuries. Again, doctor, all of these injuries or both of these injuries in 49 and the one in 48 are made apparent due to shaving, postmortem shaving at the Coroner's office?
Doctor, would your answers about nonfatal antemortem be the same for this contusion abrasion as they've been for the sharp force injury no. 1 of G-49?
The last thing about the abrasion contusion, is there anything about it which allows you to give an opinion concerning the relative positions of Mr. Goldman and the perpetrator at the time that injury was received?
Anything further just about the photographs and what they show regarding those injuries?
If we can just identify in the diagram and the protocols where these two injuries to the head are addressed and diagrammed.
And, doctor, how do you designate it? Again, these are the arbitrary designations numerically. Is the sharp force injury injury no. 1 of G-49?
Yes. Actually, we didn't give it a number for--in G-49 because we describe it separately in G-48.
And let me outline that including the opinion, and I'll write at the side "G-49" and "G-48." Doctor, in your opinion, are those descriptions by Dr. Golden of each of those injuries accurate?
And is his opinion that's expressed with respect to that contusion abrasion accurate?
This is the cut, quarter-inch cut in the back of the head which is seen in G-49 and only seen in G-49. It says "Superficial skin cut, quarter-inch deep," and "No SGH" means no subgaleal hemorrhage.
What is the significance if any of the observation that there is no such hemorrhage?
That would signify that this is a superficial cut and not a deep cut in the scalp.
What else if anything does Dr. Golden indicate concerning that particular sharp force injury?
All right. Let me circle that area that you've just outlined in the lower right quadrant of form 20F from board 6G of our collective set 357, and I'll write "G-49" in blue.
And then we have the quarter-inch red brown abrasion with skin bruising showing the injury in G-48.
All right. Let me outline that entire area. Doctor, does this word here that appears to be between the diagram of the abrasion and the circled area for the sharp force injury refer to that abrasion?
Let me outline this area in the same lower quadrant of 20F, and I'll write "G-48, G-49." Now, doctor, as long as we have this board up, there appears to be an additional entry with some handwriting in that same diagram. What does that refer to if anything?
That is the sharp force injury which we saw in G-40 or 55, the one in the back of the head.
He has indicated that it's a sharp force injury, right posterior parietal, back to front.
Yes. And it's a 5/8 inch cut. Depth is quarter-inch to 3/8 inch of the scalp. So this whole thing would reflect to sharp force injury no. 3 in G-40. I mean--G-40.
Doctor, is this area where I'm pointing out a diagram of some form used by Dr. Golden concerning that injury no. 3?
He shows the higher magnification of the wound and he also describes a smaller cut in the upper margin there.
Let me outline that entire area in red, and I'll then write "G-40 inj. No. 3." Doctor, from your review of all the materials, are these three the three and only three injuries to the head of Mr. Goldman?
Oh, okay. Sure. As long as we've got the page, why don't we finish this up. There is some reference in the autopsy protocol to that injury no. 3 of G-40?
It's right here, sharp force injuries of the scalp, the scalp is shaved postmortem, the whole no. 1 up to the "Opinion."
Doctor, that description that is before the two lines for "Opinion," is that an accurate description of injury no. 3 of G-40?
Is the opinion that is offered there one which in your judgment an opinion is accurate?
All right. Let me circle that in red, and up at the left-hand border, I'll write "G-40 inj. No. 3." Is there anything further diagrammatically or in the protocol concerning any of these three head injuries?
All right. Let's take this down then. And before we get to that one photograph with respect to the facial injuries, your Honor, I have another series of photographs that bears the title of "Blunt force trauma, sharp force injury and defensive wounds to the left arm, left and right hands of Mr. Goldman." May this be marked as exhibit 361?
Doctor, again, these are photographs that you have reviewed in the course of your examination of the autopsy materials?
I was going to ask you, you reviewed the life-size photographs for each of these photos?
And did you also see the photos in this dimension, but in an uncropped fashion? Obviously some of these have been cropped, narrowed and so forth to conform to the order of the Court.
Your Honor, with this exhibit, I have two additional photographs which have designations on the back of the photographs. One is--has a "34" written on the back. And for the record, I'm going to write the letter "G" in the red on the back of that, and I would ask that that be marked as 361-A. And I will also write the designation of "Exh. 361-A" in the lower right-hand corner. And then I have a very small photograph that appears to show one hand and wrist area that has "G-25" written on the back, and I'll ask that this be marked as exhibit 361-B, and I'll write that same designation in the lower right-hand corner on the back of that photo.
Doctor, I want to talk first of all about the hands as shown in a series of photographs, G-28, G-35, G-26, G-29 and G-32 as well as our two additional photographs.
And, your Honor, I don't know--does the court clerk have little pins that I might be able to use to stick these two photographs--
Doctor, you talked last week about something called defensive wounds; is that correct?
And in looking at all of these photographs of Mr. Goldman's hands, did you examine them in particular to look for evidence of defensive wounds?
Let's start if we could, please, with the right hand, and the photographs that appear to reflect or represent the right hand are on the right-hand end of this exhibit 361, G-35 and G-32; is that correct?
And also, this individual photograph which hopefully we will be able to put up alongside G-35 which is G-34; is that correct?
Doctor, let's start then with 35 and what is also 34. What are we looking at in those two photographs?
We have evidence of two sharp force injuries. One is a cut in the palm of the hand between the right middle finger and right index finger web. It's right in the base of those two fingers. That's one cut. The other cut is in the palm of the hand near the base of the right thumb, and this is called the--it's like a t-shaped wound here which--
So you have two sharp force injuries, and what you see is--are we calling this G-30?
That is G-34. Let me get behind here and just prop it out a little bit so the ladies and gentlemen of the jury can see it.
G-34 shows the same sharp force injury which you see in the web here in a better manner because the fingers have been opened up so you can see the injury better and you can also see the characteristics of the wound.
Your Honor, Mr. Fairtlough tells me this is translucent on the part that extends. I don't think it causes any concern and the Court's indication conforms with mine. So we'll leave it as is.
Doctor, in your opinion, are these two injuries--and by the way, have you designated them arbitrarily with numbers?
Yeah. I called the one to the web as injury no. 1 and I called the one to the base of the thumb as injury no. 2.
Doctor, in your opinion, is each of those sharp force injuries what you would call a defensive wound?
They would be called as defensive wounds because the victim obviously kept his hand open and tried to grab the knife or tried to defend himself from a knife thrust which was being directed against some part of his body to prevent the knife striking the body. So one option could be that he tried to grab the knife or block the penetration, and the other--the other option is, without grabbing, just kind of blocking maneuver.
Doctor, can you use the ruler, and you tell me what to do as if I'm Mr. Goldman. What is it that you have been talking about which would result in these kinds of defensive wounds?
See, one is a y-shaped wound at the base of the thumb. The other is a cut in the web between the index and middle finger (indicating). If you are Mr. Goldman, if the knife--
If I'm trying to stab you here, you bring your hand and try to hold the knife. You try to, but you won't be able to hold (demonstrating)--if you held the knife, you would have other cuts in the other fingers, and you don't have that. So it would be--though it could be a maneuver towards that, it would be most likely a blocking type of situation.
With the knife tip cutting the skin here (indicating). The other option is, when the knife is being wielded, you could have a cut in the hand without it necessarily having been a puncture type wound.
Now, doctor, from the appearance of injury no. 1, would you describe those besides being defensive wounds, as incised wounds?
In the sense that their depth is less than the length on the surface of the body?
As a result of being incised wounds, can you distinguish as to whether or not this is inflicted with a single-edged knife or a double-edged knife?
But is it still your opinion that both of these are consistent with being inflicted with this hypothetical approximately 6-inch long blade single-edged knife?
And when you say "Tapering tip," meaning getting narrower at the tip of the knife?
Doctor, in your opinion and as you've described, are both of those defensive wounds antemortem, that is inflicted before death?
Can you tell from this information whether they were received at or about the same time, that is as part of the same thrust of the knife or whether they resulted from individual thrusts or wields of the knife?
Because they're separate location, different appearance. And as I pointed out, if the knife was really held, I would expect to see more cuts in the other parts of the palm of the hand, which we don't have. We have two localized cuts to the palm of the hand, one near the base of the thumb and one near the web between the index and middle finger.
I'm sorry. Where in the photo would you expect to see these additional cuts if in fact the hand closed on the knife?
Depending on how the knife is held, you could have it in the palmar surface of these fingers, of this part of the thumb (indicating).
All right. Anything further about those two defensive wounds regarding their nature?
They need not have been addressed because they have been described fairly accurate.
Doctor, are there any additional injuries you see to the palm area of the right hand as seen in either of those two photographs, G-35 or G-34?
Anything further you wish to discuss at this point regarding those two photographs?
Then let's move if we could, doctor, to the bottom photograph, G-32, the right wrist, the hand. And this is showing now the back of the hand and the wrist; is that correct?
Had you numbered these findings again arbitrarily by injury nos. 1 through whatever?
I numbered them starting from the abrasion here and I numbered them through no. 12.
Why don't you take us through just a generalized overview of what each of the injuries you see in that hand depiction, wrist depiction of photograph G-32 shows.
You have an abrasion to the ulnar aspect of the right wrist. You have an abrasion to the back of the right wrist here (indicating). You have a contusion, a bruising of the knuckle of the base of the right middle finger. You have a linear abrasion in the dorsum of the proximal portion of the base of the right index finger.
You also have a small abrasion adjacent to it. You have a contusion in the outer--I mean the ulnar aspect of the index finger near the abrasion I just described. There's also a scraping of the nail evident on the index finger. In the middle finger, you have an abrasion and contusion in the proximal interphalangeal area. See, each finger has three small pieces of bone called the phalanges, and this is located in the joint between the first and second phalanges here and the middle finger.
Can you point that out for the ladies and gentlemen of the jury so they will be able to see, doctor? You want to do it with my hand? And I've got a few ink stains on it, but--
This is the index finger. You see the abrasion right here. You have an abra--you have a contusion in this aspect of the index finger, and on the middle finger, you have an abrasion here, and this overlies a contusion (indicating). And what I meant by phalanges are 1, 2 and 3, the three bones in the finger, and the joints are the interphalangeal joints. So what you have here is a scrape and bruising of the back of the proximal interphalangeal joint.
"Proximal" is just a fancy way of saying it's the part that's closer to the hand itself?
And of course, you do have a scraping of the nail here which is seen in the photograph. Then just under this abrasion bruise, you also have a smaller abrasion in the back of the right middle finger (indicating). The right ring finger shows a similar abrasion contusion over the proximal phalanx, same area as the middle finger, and you have a smaller abrasion here in the proximal interphalangeal joint of the middle finger. So you have several areas of blunt force injury to the back of the hand. And I've already described the other injuries in the wrist area. And I've now put them arbitrarily as 1 through 12 and so that we can correlate the description of these injuries with the diagram and the protocol and--
Doctor, is each of injuries 1 through 12 an injury that in your opinion was received before death?
Are any of them of significance to you in the area of defensive action by Mr. Goldman to avoid his attacker?
What leads you to form an opinion that what is shown in that photograph regarding the back of the hand indicates that Mr. Goldman was trying to back away from an attacker who was coming at him with a wielding knife, as you indicated for the record, with a side-to-side motion in front of your body?
Because of the nature of the appearance of the injuries. The abrasion contusions would indicate that this hand--there are two issues here. One, you don't see any cuts in the back of the hand. The cuts are all on the front of the right side of the hand.
That means the back of the hand was not coming in contact with the sharp force like the front of the hand. And that would also--and also, the back of the hand shows blunt force injuries, which are abrasion contusions, which can be explained by the surroundings which you can--which we saw in the crime scene photographs. There are certain of the surroundings that can account for these types of injuries.
We're going to break this down a bit if we could, doctor. First of all, in saying that you see no cuts to the back of the hand and you see the two defensive wounds to the palm surface of the hand, is that of significance to you in evaluating whether Mr. Goldman ever closed his hand into a fist as if to deliver a punch to his assailant?
It would favor my opinion that the hand was probably kept open rather than clenched because if he had kept the hand clenched, he would have got some cuts in the back of the hand, which I don't see here in the photographs or the description.
Why would you have expected the back of the hand to show cuts if in fact Mr. Goldman had closed his hand into a fist in an effort to deliver a blow to his assailant?
One, he'll be getting closer to the assailant who is having a wielding knife, which is obvious from the sharp force injuries, and would have resulted in cuts to the back of the hand too because he will be more in a proximal or a closer situation to the assailant.
Doctor, would it be accurate, if I take on the role of Mr. Goldman and you're the knife-wielding assailant, in your experience, is the normal human reaction to attempt to avoid the wielding knife?
If someone attempts to deliver a blow by use of a fist to the perpetrator in a manner such as I'm doing now with my right hand closed in a fist, your Honor, and approaching Dr. Lakshmanan, representing the assailant (indicating), would that take me further away from danger or in your opinion bring me closer to the danger?
It would bring me--it would bring the--you closer to danger because I'm wielding a knife like this (indicating), and if you bring your closed fist towards me, you're going to get cuts in your forearms, back of the hand, depending on where the knife is in location to the moving arm of yours.
And for the record, your Honor, I moved forward again as I indicated before, but Dr. Lakshmanan moved closer to me with his right hand extended again waving in a side-to-side manner as if wielding a knife.
And, doctor, that is one of the bases for your opinion that Mr. Goldman did not in fact close his hand into a fist to deliver a punch to the assailant; is that correct?
That is no. 1. And no. 2, also, the appearance of the injuries which you see, if you take them in collectively and also individually, especially the injuries to the back of the knuckles, they all have abrasion contusions, which would favor a blunt force which has a rough surface. And we have certain structures in the environment in Bundy which will explain these injuries which would be more consistent with an open hand trying to avoid a knife and backing of and striking the structures rather than a closed hand attacking the assailant with a wielding knife.
And I'm going to get the photographs out of the environmental surroundings. But, doctor, in your review of this material before testifying, did you review, among other pieces of information, literature from a sports medicine textbook concerning boxing injuries to the hand?
I just looked at what kind of injuries seen in boxing and I did review some information on that.
Was that information of any significance to you along with these other matters you've already described in assessing whether the grouping or pattern of injuries or absence of injuries in certain locations supported your opinion that Mr. Goldman did not close his fist--did not close his hand into a fist in an effort to deliver a blow to the perpetrator?
Because if you have a closed fist and this was--let's assume this bruise which is in the knuckle was from a closed fist--I've already explained there are no cuts on the back of the hand--and this bruise in a closed fist was the result of Mr. Goldman closing his fist and trying to give a punch. The problem is, you don't have other injuries in the adjoining knuckles, because usually in a closed fist type of boxing situation, you'll have other knuckles also affected, which is not present, no. 1. And no. 2, the injuries here, the abrasion contusions do not fit that kind of scenario because this kind of abrasion contusion you get more with a rough surface like the--one of the items which comes right staring at my face is the bark of the tree which you have there, which is in an enclosed environment I discussed on Friday or Thursday I think, the enclosed space in which this attack did take place.
I think we've already had this marked, your Honor, as exhibit 359 I believe. 349. Excuse me.
Now, doctor, we've left the photograph of the back of the hand so that everyone can follow your explanation. Would you show us what it is about the environmental surroundings of Mr. Goldman's body that in your opinion correlates with the nature of the abrasion contusions to the back of the hand?
For that, once you go back to this environment we have, we have the tree here. We have this sapling to support wooden--I think it's a wooden support beam here which supports this plant (indicating). There's not much distance between all these structures. The tree and the side railing you see in the back here, there's only about within a foot, and the tree stump you see here is also pretty close to this tree. There's not much distance between the sapling and this tree nor is there much distance--actually, from this side railing to the walkway, which is a little more on this side of crime scene 1, is only about a couple of feet. So what I'm trying to say is, if Mr. Goldman was--assuming the hypothetical, was situated right between the sapling and the tree and you have somebody wielding a knife and you're backing off, your hand is going to be banging against this rough surface. And if you--I ran my hand myself along the bark of this tree. It's pretty rough. At the same time, it's a hard surface, and I would expect to see these kind of abrasions contusions can occur from that kind of blunt force with an open hand striking that kind of environment in my opinion.
Doctor, in your opinion, is the human body the kind of rough surface that would result in not just a contusion, but an abrasion contusion to the part of the fist or hand in contact with the human body as the blow is delivered?
Not this type of abrasion contusion. And you won't get an abrasion. You'll get more of a contusion when you strike a human body.
Doctor, is the location of the abrasion within each of the contusions of significance to you?
Yes. They seem to be localized in the center of the contusion which would go along with this kind of environment (indicating) rather than what you just also brought up in your hypothetical.
When you say "In the center of the contusion," would that be the area that is in the direct contact with whatever the rough surface is that the hand is coming in contact with?
Yes. Like in the bark of the tree, there are uneven elevations and depressions. So the abrasion would be caused by the rough elevated areas of the bark rather than the depressed areas of the bark.
Now, doctor, I think you indicate--you may have misspoken one word, but did you run your hand, the palm of your hand over the surface of the tree shown in S1?
Did you also run your hand over the surface of the sapling shown in CS1, both of the same exhibit board 349?
Yes, I did. And I also ran my hand over the--each of the--some of these bars here. You do have some irregularities. Even though it's a painted smooth type of metal railing, there are irregularities of the surface either due to dirt when the metal was painted or whatever the reason, there are some irregularities, and that would explain an injury which I have later in the left hand when we discuss it.
If the hand like the right hand that shows the contusion--would you point to the one that's just a contusion without an abrasion?
Yes. The injury number for that is no. 3 of G-32. It's over the right middle finger. I gave it injury no. 3 of G-32.
Doctor, is that a contusion which in your judgment could be caused by Mr. Goldman, in flailing back with his right hand, that hand coming in contact with a smooth area of one of those bars?
One more point you want to make is, then the question that can arise is, why didn't the rest of the finger get contusion? You have space between the bar. There is about a 4- or 5-inch space between the bar. So what I'm trying to drive at is, even though the hand is coming into contact with a particular bar, the rest of the hand need not have come in contact with the next bar. There's a couple of inches between each of those bars. I think it's about 4-1/2 inches between each of those bars if you go and measure approximately.
Doctor, is that therefore the pattern, if you will? Looking at all of these injuries to the back of the hand, in your judgment, is that grouping of injuries then consistent with this flailing, backing away from the attacker rather than an effort by Mr. Goldman to throw a punch in the direction of the assailant coming towards him with a knife?
That is correct. And of course, my--one of the strongest reinforcing--reinforcing points is the cuts being to the palm of the hand, which would indicate that the hand was probably kept open and not closed, because I don't see any cuts in both of the hands like the ones you see in the palm of the hands in both the hands.
Doctor, and is that consistent with your experience of what would be the expected defensive reaction on the part of a human being who is facing an impending assault with a knife-wielding assailant?
Is there anything else for our present purposes that we need to describe with these photographs, the crime scene photographs and the injuries as seen to the right hand, the back of the right hand in photograph G-42?
Let me put this board back then. I think before we go into the protocols and so forth, doctor, why don't we finish with the left hand and cover then all of the injuries if we can or as much as possible before we quit for the end of the day the hands before we then go to the protocols and diagrams and so forth. So can we start then with the left-hand? Photos we have appear to be G-28, G-29, G-26 and G-25, which I'm going to pin between photos G-26 and G-29 on the board. Let's start if we could, doctor, with 28 and 29. What do each of these photographs show?
28 shows the palm of the left hand and you also see a portion of the thumb. The principal injuries you see in G-28 are a cut to the palm of the hand near the base of the little finger, a cut to the base of the thumb. You also see an abrasion to the tip of the thumb and you also see a linear abrasion to the base of the thumb here. And these are the principal injuries you can see in G-28 photograph.
Why don't we do that later. I just want to be sure. You've numbered these four injuries arbitrarily 1 through 4?
1 through 3, and I've described the--this injury near the base of the little finger under G-29 (indicating).
Why don't we then have you discuss, if you would, please, the findings of that photograph.
G-29 shows a portion of the sharp force injury to the base of the thumb, which is a cut, and you see the cut to the base of the--into the palm near the base of the little finger, but you also see abrasions to the front of the little finger here and the middle finger in its distal aspect, that is the part of the middle finger away from the hand. So these are non-specific blunt force type injuries and this is a sharp force injury here (indicating).
Is that a description in general terms, doctor, of all of the findings of photograph G-29?
Now, doctor, taking these two photographs together, would you describe all of these injuries as evidence of defensive wounds?
Are they of significance to you, their location and appearance, in forming an opinion as to how they may have been received?
Yes. The--the--the palmar cuts could be the same way the palmar cuts of the right hand. You have a cut to the palm of the left hand here and the base of the thumb, which could be the same mechanisms I described by the hand being used to avoid a penetrating thrust to a part of the body. Could be from the wielding of the hand being interposed to protect the body against the wielding knife. There are numerous other ways it can happen, but I just gave you some examples. And the abrasion itself, this abrasion is on the little finger is--looks as though the abrasion, the skin has been peeled off or shaved off in a superficial part. And this could be from just scraping of the finger against a rough surface, but it could also be scraping of the finger against the blunt edge of a knife.
Because if a blunt end of the knife is scraped against the skin, you can get this kind of linear scraping of the skin with a peeling of a flap. But it could be from other mechanisms like rubbing against a rough surface with the skin being peeled off in that manner.
Yes. Especially if we take this in conjunction with this cut to the hand, there could be an attempt at the grabbing of the knife at this point like this (indicating).
Doctor, could you use the ruler--it's to your left--and demonstrate either using my hand or yours? And if you'll face the ladies and gentlemen of the jury so they can see.
Like this with the blunt edge here and the sharp edge cutting like this, and you're trying to get it, and you can get the scraping of the skin that way (demonstrating).
The doctor with his right hand has placed about the upper 2 inches of the ruler where it appears to be near the area of the ring and little finger of his left hand with those two fingers curled somewhat, but not curled around the ruler.
The other thing is, the knife is also turning and the skin gets scraped like this, and that's why you're getting the peeling of the skin here, here (indicating).
And for the record, the doctor turned the knife so that the edge in contact with those two fingers was coming or rubbing or scraping, whatever the term may be, across those two fingers as it has been coming free from the area of the hand.
Now, doctor, in your opinion, from observing all of these--these two photographs and reviewing any material, in your opinion, were all of these defensive wounds received before death?
Doctor, given the nature of that, those findings of defensive wounds, do you have an opinion as to whether Mr. Goldman closed his left hand in a fist-like action as if to deliver a blow?
For the same reasons I gave before. If you look at the back of the hand in G-26--should we describe them briefly or--
Yeah. In G-26, is the back of the left hand, you have an abrasion of the left lower forearm. You have a contusion of the base of the left hand here (indicating). But what is important is, you have a punctate, small abrasion middle of the contusion. And this important to remember. There's a linear abrasion here. And the back of the left hand shows an abrasion to the knuckle of the middle finger, an abrasion injury to the base of the index finger, an abrasion contusion to the proximal joint, interphalangeal joint of the index finger here, and there's a smaller abrasion distal to it. And if you look at the back of the left hand, you don't see any cuts. Just like the one in the right hand, you don't see any cuts. The only cuts are to the front of the hand, which again favors an opinion that the hand was probably not clenched or only the front of the hand came in contact with the knife. And the injuries again here (indicating) are non-specific blunt force trauma which can be explained by the environment, which would favor an open hand flailing away against a wielding knife and hitting those objects which I just described in crime scene photographs.
Doctor, I was going to ask you, are those same findings, the rough surface of the tree, the rough surface of some of the bars and so forth, the sapling and the support stake for the sapling, are those the kinds of items which in your opinion are consistent with Mr. Goldman's back of his left hand in a flailing action coming in contact with, resulting in these blunt force trauma injuries?
Now, doctor, is the location--you mentioned this contusion on photograph G-26 near the area where the hand joins the wrist as having a punctate abrasion on it. Is the location of that contusion of some significance in forming an opinion as to whether it was caused by a striking action, that is the fist being clenched to deliver a blow?
The location is more towards the wrist area, but the appearance of the injuries would be more consistent with hitting against a blunt smooth surfaced object with a rough random irregularity like in the metal bar, which I felt the surface, you have certain areas that could be rough, but mostly smooth. And one of the elevations of such a bar could have caused the injury. I'm not saying that's what happened, but that's one of the possibilities rather than the wrist coming in contact through a closed fist causing a punch, because if you throw a punch, you'll get the injuries more to the back of the phalanges and knuckles rather than the wrist unless it was an improperly thrown punch.
The human body doesn't have that kind of rough surface that would translate into a punctate abrasion on top of the contusion?
And, doctor, would it also be your opinion--based upon what you told us a moment ago regarding the unnatural aspect of a victim throwing a punch to bring the victim closer to an attacking--a knife-wielding assailant, would your answers be the same as to why in your opinion Mr. Goldman did not have his left hand clenched in a fist to throw a punch?
That would be my opinion for the various reasons I've already discussed. But one of the important things is, you have cuts in the front of the hand and you don't have any cuts on the back of the hand. And to me, that is significant.
Doctor, are you able to tell from reviewing all of these hand photographs as to the relative positions of Mr. Goldman and the attacker? And by that, I mean, for example, can you tell whether Mr. Goldman was seated and basically flailing backwards in a seated position or standing and flailing backwards? Are you able to make that determination?
It will be difficult for me to opine on that, but I would favor that probably this was when he was mobile and able to move his extremities.
Doctor, let me get another photograph. I think we have enough team to touch upon it.
And, your Honor, I have another board. May this be marked--oh, I'm sorry. I don't need it. I'm sorry. It's on this board. It's photograph G-20.
Doctor, do you see something in photograph G-20 above the blue photographic identification card that is of any significance to you?
Yes. You have a smaller abrasion, and in front of it, there's an interrupted intact skin area, and in front of that, you have a triangular abrasion. By the way, the photograph shows the front of the body. On the left side of the photograph, you can see the nipple there.
Yes. And the triangular abrasion base is facing the front, and you have another area of abrasion in front of the triangular abrasion. There's another area of intact skin between these two. And so you have three non-specific areas of abrasion injury. You also have a faint abrasion above it in this--running in a horizontal axis, on a side-to-side axis of the photograph in the left arm, and you also have a smaller abrasion near the left elbow area.
I would like to focus if we could on this interrupted group of abrasions you talked about. First of all, can you point on your left arm in general where is that area on Mr. Goldman's arm?
For the record, your Honor, Dr. Lakshmanan is pointing to an area, appears to be halfway between the shoulder and the elbow and towards the--about the middle between the front and the back of the body.
If we could have the environmental photos back, please. Let me see if I can hold it over here this time. With the Court's permission, can I sit on counsel table?
Doctor, you have examined, have you not, in your visits to the Bundy location the sapling and the support stake that are seen in photograph CS1?
And, doctor, did you also examine Mr. Goldman's shirt that he was wearing at the time his body was found?
Doctor, and does that shirt and the sapling and the support stake have any significance to you in evaluating what you've described as this interrupted area of abrasion seen in photograph G-20?
There are two issues here. One is, you have an--you have an intermediate object, the clothing, between the area in contact, if that was the area of contact which caused this injury and the skin surface. So you won't have a pattern of the object--
You won't have the pattern of the object which caused the injury on the skin surface because the clothing is interspersed between the object and the skin. The second factor is, there is a space, interrupted skin space there. And if you look at the sapling of the support beam, there is an area between the two because the support beam or stake holds the sapling upright. So one way this injury could have been caused is if the hand put the shirt on its surface, had come in contact with that area causing an abrasion. It's not an abrasion contusion. It's mainly an abrasion injury. So you don't necessarily have force because if it was force, then it's just a scrape on the area.
Doctor, if Mr. Goldman either backed into that area where his left arm in that area shown in the photograph came in contact or if he somehow was pushed into that area such that that part of his left arm came in contact with the space between the sapling and the support stake, would that in your opinion be consistent with the resulting interrupted abrasion pattern we see in photograph G-20?
And, doctor, is there anything about the appearance of that interrupted area of abrasions which allows you to be more specific as to potential manners in which that could have been received?
This would be one possible scenario of how this happened, especially with the interrupted intact skin which would be explained by the space between the stake and the plant. But of course, you should realize that you also have clothing which can also fold when this happens. But there's no specific pattern to the injury which can say with absolute certainty, that's how--that's what caused it, but I would favor that scenario more than other scenarios there.
And, doctor, finally before I believe we're going to end the day, can you exclude that that is due to a blow struck by the perpetrator, either a fist to the perpetrator or a rounded end of the knife?
I couldn't exclude it, but the problem is, you have these areas of intact skin there which, if caused by the folding of the clothing, would leave more of a pattern. But I would favor more an object of this nature because it's only a scrape, because if it's a blow of the knife, you would expect also a lot of bruising there like we saw in the scalp contusion in Nicole because there would also be crushing injury, which you don't have here. It's only a scrape in the skin.
And absent that bruising, does that suggest to you that in fact that was not the cause?
Bottom line is, you can not really tell with definite certainty which kind of movements caused these type of wounds. But these are some possibilities which one could hypo--opine.
It's difficult to make that kind of judgment because in Miss Brown Simpson, the knife went across the neck up to the spine and there's no specific depth given, whereas for the wound on the left side of the neck of Mr. Goldman, at least a 4-inch track because it communicates with the left--behind the left ear.
The left internal jugular vein injury? Yes.
But a mistake nonetheless?