📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 1) — Tuesday, June 13, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\13\DIRECT-EXAMINATION-OF-DR-LAKSH.DOC
TRIAL
▲ Day 94 of 167

Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 1)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Tuesday, June 13, 1995 • Utterances: 580
Dr. Lakshmanan resumes his direct examination by Brian Kelberg, methodically cataloguing each wound on Ron Goldman's hands—identifying injuries in photographs G-32, G-34, G-35, G-28, and G-29—and cross-referencing each against Dr. Golden's autopsy protocol, diagrams, and addendum. For each omission or error by Dr. Golden, Lakshmanan follows a consistent pattern: acknowledging the mistake but denying any significance on the 'big ticket' questions. The testimony also reinforces Lakshmanan's opinion that Goldman's hand injuries are consistent with contact with rough surfaces like the tree in the crime scene, not from delivering a closed-fist blow to the perpetrator.
1 (The following proceedings were held in open court, in the presence of the jury:)
2 THE COURT:

All right. Let the record reflect we have been rejoined by all the members of our jury panel. Good morning, ladies and gentlemen.

THE JURY: Good morning.

3 THE COURT:

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

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:

Good morning, doctor.

5 DR. LAKSHMANAN:

Good morning, your Honor.

6 THE COURT:

You are reminded, sir, that you are still under oath. And Mr. Kelberg, you may conclude your direct examination.

7 MR. KELBERG:

I take it not very subtle hint.

KEY QUOTE
8 THE COURT:

Thank you.

9 (Brief pause.)
10 MR. KELBERG:

But I assume I have at least perhaps all day?

11 THE COURT:

Reasonable time.

12 MR. KELBERG:

Good morning, ladies and gentlemen.

DIRECT EXAMINATION (RESUMED) BY MR. KELBERG

13 MR. KELBERG:

Good morning, doctor. Doctor, I just want to cover a couple of areas that we touched upon yesterday, the first area dealing with a difference of opinion you hold from that of Dr. Golden concerning the time when those two superficial incise wounds, injuries numbers 1 and 2 of photographs G-37, were received by Mr. Goldman. Do you recall that testimony yesterday?

14 DR. LAKSHMANAN:

Yes.

15 MR. KELBERG:

And you testified, as I recall, that you had reviewed certain crime scene photographs which caused you to believe that those superficial incise wounds were received early on and were part of control wounds inflicted by a taunting or threatening perpetrator on Mr. Goldman; is that correct?

16 DR. LAKSHMANAN:

Yes.

17 MR. KELBERG:

And that Dr. Golden, in his testimony in front of the grand jury, had indicated his opinion that those wounds appeared to be inflicted closer to the time of death due to the absence of hemorrhage; is that correct?

18 DR. LAKSHMANAN:

Yes, but I supported my opinion with the statements he made in his autopsy report, which indicates that there is hemorrhage in the soft tissues underlying these wounds, which would indicate that there was blood pressure present when these wound were inflicted. And that is why I opined that they were antemortem wounds and I also gave an opinion that they are consistent with being control wounds which would have happened during the earlier part of the struggle, which is what I feel happened.

19 MR. KELBERG:

But--and doctor, from what you just said, did you feel that there was an inconsistency between the material that had been included by Dr. Golden in his protocol regarding this hemorrhage that he observed and included in his description and yet his opinion being that these were wounds that were inflicted at or about the time of death rather than before death?

20 DR. LAKSHMANAN:

That is correct.

21 MR. KELBERG:

Your Honor, for the record, perhaps in front of the ladies and gentlemen of the jury, may I ask that this photograph that is a small rectangular-shaped photograph be marked as 358-B, as in boy.

22 THE COURT:

So marked.

23 MR. KELBERG:

Doctor, let me show you photograph 358-B. Did you review, among crime scene photographs, this photograph in an uncropped fashion?

24 DR. LAKSHMANAN:

Yes.

25 MR. KELBERG:

In other words, you saw the full photograph and this has been cropped, as I understand, pursuant to the order of Judge Ito?

26 DR. LAKSHMANAN:

Yes.

27 MR. KELBERG:

Is there something of significance shown in that photograph on the issue of when those two superficial incise wounds were received in relation to when Mr. Goldman died?

28 DR. LAKSHMANAN:

Yes, the appearance of the wounds itself, the coloration, taken in conjunction with the descriptive report which we have in the autopsy, supports the opinion that these are antemortem wounds because there is--you can see the hemorrhage in the tissues, in the margins and also underlying the--the superficial areas of the cut. You see there are areas of the cut which are deeper than the areas of the cut which are not so deep, and in the not so deep areas you can clearly see the discoloration which you get with hemorrhage underlying the tissue which has been confirmed in the autopsy report of Dr. Golden when he did the autopsy. So this photograph especially you can see very clearly in the upper wound and also in portions of the lower wound on the right side of the photograph, and I have no doubt that these are antemortem wounds based on the description of the autopsy report and the appearance of these photographs, the way they are presented to me.

29 MR. KELBERG:

Another matter, doctor, just to finish up before we go back to the hand area, let me put up board 4G from our collection from 357, I believe, and invite your attention--with the Court's permission could the doctor step down again, please?

30 THE COURT:

Yes.

31 MR. KELBERG:

If I could find the markers.

32 (Brief pause.)
33 MR. KELBERG:

I want to invite your attention, doctor, there is an area I noticed that has not been circled or addressed in some fashion by us. Do you recognize what is written in this area of this--this is roman numeral II form of no. 22?

34 DR. LAKSHMANAN:

Yes. This refers to the cut of the ear and the length of the wound as six inches and this is the sharp force injury and it says, "If ear involved." This refers to this wound on the left side of the neck which in Dr. Golden's original autopsy report indicated that if this left neck wound exited behind the left ear and also cut the left ear, the total length of that wound would be six inches. That is what this refers to.

35 MR. KELBERG:

Doctor, in essence, is this referring to what you described as injury no. 1 of G-51, this fatal sharp force injury stab wound, injury no. 2 of G-51, the somewhat linear in appearance wound behind the ear running down the neck, and injury no. 4 of G-51, a nick to the area you called the pinna, P-I-N-N-A, of the ear?

36 DR. LAKSHMANAN:

Yes.

37 MR. KELBERG:

So the overall reasoning, according to Dr. Golden, you assumed that was all one injury with the neck going--I'm sorry, the knife going in the injury no. 1 area and coming out the area of injury no. 2 and then nicking the ear in the process, would be six inches?

38 DR. LAKSHMANAN:

Yes.

39 MR. KELBERG:

Your Honor, for the record, on this form let me circle this area of information and I will write "G-51 inj. numbers 1, 2 and 4." Doctor, I would like to get back to a discussion of the hand injuries and see if you can identify in the protocol any of them that are described and to deal with the diagrams and the addendum. And for the record, with Mr. Fairtlough's assistance, we have been able to append a flap, I'm not sure it is--we may have to have it held--we have appended a flap which includes then the photograph that was described as G-34. And let me write "G-34," incidentally, on the board underneath the photograph. And also we have appended, with apparently some kind of photo mount, the photograph that was G-25 which I don't know that I have a marker--I think we could take care of it at a later time so that will be identified--but for the record we will do that.

40 THE COURT:

I think there is also an evidence tag below it there.

41 MR. KELBERG:

There is, but unfortunately it doesn't say that it is G-35.

42 THE COURT:

All right. Proceed.

43 MR. KELBERG:

It refers to that course of testimony. Also with Mr. Lynch's help, if we could set up the two easels.

44 (Brief pause.)
45 MR. KELBERG:

And your Honor, we are going to be dealing with 0G, 10G and a diagram--Mr. Lynch, I'm going to ask that the addendum just be kept down here, if we could, please, and I will ask you to put up--this is our board 5G that appears to have a series of forms outlining the hand, again all from exhibit 357, your Honor.

46 THE COURT:

All right.

47 MR. KELBERG:

Doctor, again, with the Court's permission, can you step down, and yesterday we did not get into the specifics of where each of these injuries are, if they are described, et cetera, so I would like to do that now. Let's start if we could going photograph by photograph, doctor. I believe you started yesterday with photograph G-35?

48 DR. LAKSHMANAN:

Okay.

49 MR. KELBERG:

Is that correct?

50 DR. LAKSHMANAN:

Yes.

51 MR. KELBERG:

Let's take those injuries and go through the process of the protocol, the diagram, the addendum.

52 DR. LAKSHMANAN:

Yes. G-35 shows a 5/8 inch cut in the web between the index and middle finger of the right hand on the palmar aspect.

53 MR. KELBERG:

Is that designated arbitrarily by you as injury no. 1?

54 DR. LAKSHMANAN:

Yes.

55 MR. KELBERG:

And that is described by Dr. Golden?

56 DR. LAKSHMANAN:

Yes.

57 MR. KELBERG:

Is it diagrammed by Dr. Golden?

58 DR. LAKSHMANAN:

Yes.

59 MR. KELBERG:

Is it addressed in the addendum?

60 DR. LAKSHMANAN:

No.

61 MR. KELBERG:

Any reason he should have?

62 DR. LAKSHMANAN:

To need to.

63 MR. KELBERG:

All right. Now, injury no. 2 in that photograph?

64 DR. LAKSHMANAN:

That is present in the palmar aspect of the hand, of the right hand, near the base of the thumb, and it measures--a y-shaped wound, and it is addressed in the protocol. It is addressed in the diagram. It was accurately defined in the reports and there was no addendum report prepared.

65 MR. KELBERG:

Keep your voice up, if you would, please, doctor. As I recall, you said those were the only two injuries you observed in photograph G-35?

66 DR. LAKSHMANAN:

Yes.

67 MR. KELBERG:

And is it accurate to say that the injury that is seen in photograph G-34 is injury no. 1 that you have discussed in G-35?

68 DR. LAKSHMANAN:

That is correct. There were--the only reason the wound looks a little more gaping and bigger is because the index finger and the middle finger have been pried open so that the wound can be better visualized.

69 MR. KELBERG:

Doctor, where in the protocol are injuries 1 and 2 described?

70 DR. LAKSHMANAN:

Page 11, no. 1 and 2. no. 1 and 2.

71 MR. KELBERG:

Under "Sharp force injuries of hands"?

72 DR. LAKSHMANAN:

Yes.

73 MR. KELBERG:

Which is injury no. 1?

74 DR. LAKSHMANAN:

This is--on page 11, no. 1, is the injury no. 1 and page 11, no. 2, is injury no. 2.

75 MR. KELBERG:

And your Honor, I'm going to outline in blue each of these, write at the side "G-35 inj."--I'm sorry, is it 35?

76 DR. LAKSHMANAN:

Yes.

77 MR. KELBERG:

"Inj. no. 1" and another one I will outline in blue and that is going to be "G-35 inj. no. 2," and I will also, for the G-35 no. 1, write semicolon "G and G-34" and a line underneath that to separate.

78 MR. KELBERG:

Is that accurate, sir?

79 DR. LAKSHMANAN:

Yes.

80 MR. KELBERG:

Doctor, are those descriptions in your opinion that are provided by Dr. Golden accurate on those two injuries?

81 DR. LAKSHMANAN:

Yes.

82 MR. KELBERG:

Where are they diagrammed, if at all?

83 DR. LAKSHMANAN:

The diagram is 23-III.

84 MR. KELBERG:

So if we ask Mr. Lynch to get us to that--

85 DR. LAKSHMANAN:

The right lower quadrant you can see both the injuries, incise wound, length, 3/4 inch, length half-inch deep, subcu. This wound is a y-shaped wound, depth is 1/4 inch and half-inch dimensions.

86 MR. KELBERG:

Doctor, you have to keep your voice up if you would, please. Injury no. 1--first of all, just circle the area, if you would, that is covered by that?

87 DR. LAKSHMANAN:

(indicating).

88 MR. KELBERG:

For the record, your Honor, I will circle that same area in blue on that area of the lower right quadrant. I will write "G-35 inj., no. 1, and G-34."

89 MR. KELBERG:

And doctor, is that handwritten entry that you just read basically the same as what appears in the dictation?

90 DR. LAKSHMANAN:

Yes.

91 MR. KELBERG:

Now, the second injury is outlined in what area?

92 DR. LAKSHMANAN:

The same diagram of the right hand, in whole area here is injury no. 2, (indicating).

93 MR. KELBERG:

Doctor, is this little inverted y, what appeared to be an inverted y of some significance to you?

94 DR. LAKSHMANAN:

Well, it shows the appearance of the wound as you see it in the photograph.

95 MR. KELBERG:

Is that a diagram that was made by Dr. Golden in the course of the autopsy?

96 DR. LAKSHMANAN:

Yes.

97 MR. KELBERG:

Where you have circled that area, let me do the same with the blue and I will write down at the bottom "G-35 inj. no. 2."

98 MR. KELBERG:

Doctor, there appears to be some writing to the left of the schematic and some lines that run from that writing. What is that?

99 DR. LAKSHMANAN:

Just says there are two Defense wounds.

100 MR. KELBERG:

Do you agree with Dr. Golden's assessment that injuries 1 and 2 are in fact Defense wounds?

101 DR. LAKSHMANAN:

Yes.

102 MR. KELBERG:

As you testified yesterday?

103 DR. LAKSHMANAN:

Yes.

104 MR. KELBERG:

Let me just circle that and in blue and I will put a line running to each of the two areas that we have previously just circled.

105 MR. KELBERG:

All right, doctor. Are we done with injuries 1 and 2 of G-35?

106 DR. LAKSHMANAN:

Yes, we are.

107 MR. KELBERG:

All right. Let's go back then, if we could, I believe the next photograph you looked at was G-34; is that correct?

108 DR. LAKSHMANAN:

Yes.

109 MR. KELBERG:

How many injuries do you identify in there?

110 DR. LAKSHMANAN:

I identified 12.

111 MR. KELBERG:

All right. Let's try and take them individually and cover the protocols, diagrams, addendums as we go so that we don't--at least I don't get lost. Let's start with what you have arbitrarily numbered injury no. 1.

112 DR. LAKSHMANAN:

Injury no. 1 is an abrasion to the ulnar aspect of the right wrist here, (indicating).

113 MR. KELBERG:

Keep your voice up please.

114 DR. LAKSHMANAN:

Right here in the ulnar aspect of the right wrist, (indicating).

115 MR. KELBERG:

Is that antemortem?

116 DR. LAKSHMANAN:

Yes.

117 MR. KELBERG:

Is that described in the protocol?

118 DR. LAKSHMANAN:

Yes.

119 MR. KELBERG:

Is it diagrammed?

120 DR. LAKSHMANAN:

Yes.

121 MR. KELBERG:

And addressed in the addendum?

122 DR. LAKSHMANAN:

No.

123 MR. KELBERG:

Any reason to?

124 DR. LAKSHMANAN:

No.

125 MR. KELBERG:

Let's find out where in the protocol and which diagram.

126 DR. LAKSHMANAN:

Page 11 and 12, no. 1.

127 MR. KELBERG:

Under "Other injuries to hands and upper extremities"?

128 DR. LAKSHMANAN:

Yes.

129 MR. KELBERG:

We are on page 11 board 0G. Let me outline this and I'm going to write "G-32 inj. no. 1" and see if we can flip the page.

130 MR. KELBERG:

And it ends before the no. 2?

131 DR. LAKSHMANAN:

Yes.

132 MR. KELBERG:

All right. Let me outline that again and I will write the same information, "G-32 inj. no. 1."

133 MR. KELBERG:

Doctor, is Dr. Golden's description in his protocol accurate, in your opinion, of that particular abrasion?

134 DR. LAKSHMANAN:

Yes.

135 MR. KELBERG:

Where is it diagrammed, if at all?

136 DR. LAKSHMANAN:

It is diagrammed on 21-I.

137 MR. KELBERG:

And Mr. Lynch is--

138 MR. KELBERG:

All right. Doctor, would you identify where on that particular item--and I will get the board number designation when we pull it down, your Honor.

139 DR. LAKSHMANAN:

Right here. It is a diagram that is 3/4 inch by half an inch ulnar red brown not patterned abrasion, this injury right here, (indicating), the whole injury.

140 MR. KELBERG:

And is there some designation on the form of the body as to its location?

141 DR. LAKSHMANAN:

Yes, ulnar.

142 MR. KELBERG:

I'm sorry, there is an actual diagram on some part of the body to show what it is that Dr. Golden is referring to?

143 DR. LAKSHMANAN:

Here, (indicating).

144 MR. KELBERG:

Where there appears to be almost a circular heavy black outlined area?

145 DR. LAKSHMANAN:

Yes.

146 MR. KELBERG:

For the record, your Honor, then I will circle this area on 21-I and write "G-32 inj. no. 1."

147 DR. LAKSHMANAN:

And actually this also would belong to the same injury because it is in the distal forearm wrist area.

148 MR. KELBERG:

What do those word say?

149 DR. LAKSHMANAN:

"Distal forearm."

150 MR. KELBERG:

So all of that goes with this injury no. 1?

151 DR. LAKSHMANAN:

Yes, yes.

152 MR. KELBERG:

All right. I will circle that and I will connect these two areas with a solid blue line.

153 MR. KELBERG:

Anywhere else that that is diagrammed, doctor?

154 DR. LAKSHMANAN:

No.

155 MR. KELBERG:

Let me take this board down. That is 3-G, your Honor.

156 MR. KELBERG:

Are we done basically then with injury no. 1 of G-32?

157 DR. LAKSHMANAN:

Yes.

158 MR. KELBERG:

All right. Let's go back and see what injury no. 2 is.

159 DR. LAKSHMANAN:

Injury no. 2 is 5/16 inch by 1/16 inch abrasion over the back of the right wrist and I'm pointing to it right here.

160 MR. KELBERG:

Is that addressed in the protocol?

161 DR. LAKSHMANAN:

No.

162 MR. KELBERG:

Is it diagrammed?

163 DR. LAKSHMANAN:

Yes, it has been diagrammed.

164 MR. KELBERG:

And is it addressed in the addendum?

165 DR. LAKSHMANAN:

No.

166 MR. KELBERG:

Which diagram, doctor?

167 DR. LAKSHMANAN:

The same diagram, 23-III, (indicating).

168 MR. KELBERG:

You are pointing in the upper right quadrant to an area. Is there some writing that you associate with that entry?

169 DR. LAKSHMANAN:

Yes. It says, "Half an inch superficial"--I can't read this word. Could be--

170 MR. KELBERG:

Keep your voice up.

171 DR. LAKSHMANAN:

I can't read this particular letter here, but this is "Superficial" and "Half an inch" and these injuries are--

172 MR. KELBERG:

Where the doctor has just outlined with the pointer, your Honor, I will circle that in blue and write "G-32 inj. no. 2."

173 MR. KELBERG:

Doctor, in your opinion was it a mistake for Dr. Golden not to include a description of that injury in his protocol?

174 DR. LAKSHMANAN:

Well, yes.

175 MR. KELBERG:

Is it of any significance to you?

176 DR. LAKSHMANAN:

No.

177 MR. KELBERG:

For the same reasons?

178 DR. LAKSHMANAN:

Yes.

179 MR. KELBERG:

And is there any reason he should have addressed it in the addendum, given that he did not describe it in the protocol?

180 DR. LAKSHMANAN:

He could have, but he didn't.

181 MR. KELBERG:

Is that a mistake?

182 DR. LAKSHMANAN:

Yes.

183 MR. KELBERG:

Any significance?

184 DR. LAKSHMANAN:

No.

185 MR. KELBERG:

Same reasons?

186 DR. LAKSHMANAN:

Yes.

187 MR. KELBERG:

Anything more about injury no. 2?

188 DR. LAKSHMANAN:

Nothing more.

189 MR. KELBERG:

Let's go to injury no. 3.

190 DR. LAKSHMANAN:

Injury no. 3 is a 3/4 inch by one inch contusion to the right hand knuckle at the base of the middle finger here, (indicating), and let's see--

191 MR. KELBERG:

Is that addressed in the original protocol?

192 DR. LAKSHMANAN:

Yes, it is.

193 MR. KELBERG:

Is it diagrammed?

194 DR. LAKSHMANAN:

Yes, it is.

195 MR. KELBERG:

Is there any area of the addendum to which it is addressed?

196 DR. LAKSHMANAN:

No.

197 MR. KELBERG:

Any reason it should have been?

198 DR. LAKSHMANAN:

Not necessary.

199 MR. KELBERG:

Before we go to that, doctor, just one follow-up on this. You testified yesterday that it was of significance to you that the original--in deciding whether or not Mr. Goldman's hand had been closed into a fist and delivering a blow, that the only contusion you saw, without a punctate abrasion centered over the contusion, was to that knuckle; is that correct?

200 DR. LAKSHMANAN:

Yes.

201 MR. KELBERG:

Can you point out which other knuckles you would have expected to see a contusion if in fact Mr. Goldman had delivered a direct blow to the face, for example, of the perpetrator?

202 MR. SHAPIRO:

Objection, calls for speculation.

203 THE COURT:

Sustained. Rephrase the question.

204 MR. KELBERG:

Doctor, you indicated that you had reviewed, among other material, literature from a sports medicine publication on boxing injuries; is that correct?

205 DR. LAKSHMANAN:

Yes, I did.

206 MR. KELBERG:

Have you also, as part of your training and experience, studied blunt force trauma injuries received to hands of people who have struck faces of other individuals?

207 DR. LAKSHMANAN:

Yes, I have.

208 MR. KELBERG:

From that have you formed opinions as to the kind of injuries in the form of blunt force trauma contusions one expects to see when a fisted hand delivers a direct blow to the face of another human being?

209 DR. LAKSHMANAN:

Yes.

210 MR. KELBERG:

In your opinion why--withdraw that frame of the question and frame it this way: Point out where you would have expected to see additional areas of contusion, if any, had Mr. Goldman's hand been closed into a fist delivering a direct blow to the face of the perpetrator?

211 DR. LAKSHMANAN:

I would expect to see contusion in the adjoining knuckles and also the adjoining portion of the phalanges, which we don't see here. We only see localized to one knuckle here, (indicating). And the other issue is also that the other injuries in the other fingers show to be abrasion contusions, so the only pure contusion is to one knuckle, which seems a rather unusual. If it was a closed fist which delivered a direct blow to a person, I would expect to see more injuries to the other knuckles, especially the fourth and fifth knuckles and the adjoining--adjoining proximal phalanges. You see, after all, the closed fist is like this, and if somebody is going to give you a direct blow, you would expect to see injury on this knuckle, adjoining knuckles and the adjoining phalanges. And this particular hand only shows a bruise to a knuckle without any abrasion on it, and of course the other injuries show abrasion contusions which do not follow the pattern you see in such a scenario.

KEY QUOTE
212 MR. KELBERG:

You don't expect to see the abrasion on top of the contusion from a blunt force trauma from a fist to the face of another human being?

213 DR. LAKSHMANAN:

That's correct.

214 MR. KELBERG:

And that I think you indicated is part of the basis of your opinion as to why you also believe it was from a flailing into some of the trees and surrounding areas where Mr. Goldman's body was found?

215 DR. LAKSHMANAN:

That is correct, and I also indicated yesterday that the lack--the lack of sharp force injuries to the back of the hands favor that opinion, because the sharp force injuries, as we discussed, are onto the front of the hand, and further, there is no other sharp force injuries which I could see in the forearm either.

216 MR. KELBERG:

Doctor, let's go to the protocol. Where is injury no. 3, that contusion, addressed?

217 DR. LAKSHMANAN:

It is addressed on page 12, no. 3.

218 MR. KELBERG:

We are on page 12?

219 DR. LAKSHMANAN:

No. 3, second sentence: "On the proximal knuckle of the right middle finger is a one inch by 3/4 inch bruise with no overlying abrasion."

220 MR. KELBERG:

Is that the extent of the description?

221 DR. LAKSHMANAN:

Yes.

222 MR. KELBERG:

Let me outline that then on board 0G and I will write to the side "G-32 inj. no. 3."

223 MR. KELBERG:

Is that an accurate description, doctor?

224 DR. LAKSHMANAN:

Yes. And it is here on 23-III, right here, (indicating), same knuckle, "Fresh bruise, one inch by 3/4 inch" and you can circle it.

225 MR. KELBERG:

You have outlined it with your pointer. Let me ask, before I circle it, there appears to be a circled area with some squiggly lines inside, the circle and a line running horizontally to the outside of this handwritten entry. What is this circled area with the wavy lines to reflect?

226 DR. LAKSHMANAN:

It is diagrammatically depicting the injury that you see in the photograph and which has been dictated as such on the protocol and that is the measurement there, (indicating).

227 MR. KELBERG:

All right. Let me outline that then, this upper right quadrant with the board 2-3 and I will write out at the side "G-32 inj. no. 3."

228 MR. KELBERG:

Anything else regarding this injury, doctor?

229 DR. LAKSHMANAN:

No.

230 MR. KELBERG:

Let's go to injury no. 4.

231 DR. LAKSHMANAN:

Injury no. 4 is 1/32 inch punctate abrasion in the base of the right index, which is a small one right here, (indicating).

232 MR. KELBERG:

So this is on the index finger at the base?

233 DR. LAKSHMANAN:

Yes.

234 MR. KELBERG:

Is that addressed in the protocol?

235 DR. LAKSHMANAN:

No.

236 MR. KELBERG:

Is it diagrammed anywhere?

237 DR. LAKSHMANAN:

No.

238 MR. KELBERG:

Is it addressed in the addendum?

239 DR. LAKSHMANAN:

No.

240 MR. KELBERG:

And I think we are going to lose our easel in just a second, if we could have a moment, your Honor.

241 (Brief pause.)
242 MR. KELBERG:

Doctor, in your judgment, all mistakes by Dr. Golden not to have described, diagrammed or addressed in the addendum?

243 DR. LAKSHMANAN:

Yes.

244 MR. KELBERG:

Individually or collectively of any significance to you on the big ticket issues?

245 DR. LAKSHMANAN:

No.

246 MR. KELBERG:

Same reasons?

247 DR. LAKSHMANAN:

Yes.

248 MR. KELBERG:

All right. Let's to go injury no. 5.

249 DR. LAKSHMANAN:

Injury no. 5 is a linear diagonally-running abrasion half an inch to the back of the right index next to the small abrasion I just described. It is on the back of the right index here, (indicating).

250 MR. KELBERG:

So we are working our way along the length of the first finger towards the nail area; is that correct?

251 DR. LAKSHMANAN:

That is correct.

252 MR. KELBERG:

All right. Is that linear abrasion addressed in the protocol?

253 DR. LAKSHMANAN:

Yes. Same page, 12, fourth sentence here, (indicating), on the--it says: "There is a linear diagonally half an inch reddish brown abrasion."

254 MR. KELBERG:

Doctor, is that whole sentence to refer to that particular injury no. 5?

255 DR. LAKSHMANAN:

Yes. It also includes the bruising you see there near the--on the proximal phalangeal joint.

256 MR. KELBERG:

Doctor, do you identify that bruising as a separate injury or is that, in your opinion, a part of injury no. 5?

257 DR. LAKSHMANAN:

I described it as a separate injury, but it could have been part of the same force which caused that other injury there.

258 MR. KELBERG:

As long as we are here, is the next injury by your numbering system injury no. 6, what is described here as the fresh bruise?

259 DR. LAKSHMANAN:

Yes.

260 MR. KELBERG:

So if I outline this entire sentence, would it be accurate to say that this concerns G-32, inj. numbers 5 and 6; is that correct?

261 DR. LAKSHMANAN:

It would be the--that's correct. Just one second.

262 (Brief pause.)
263 DR. LAKSHMANAN:

Yes, fourth sentence. One, two--yeah, fourth sentence, yes.

264 MR. KELBERG:

Keep your voice up, please, doctor.

265 DR. LAKSHMANAN:

Yes.

266 MR. KELBERG:

Now, is either injury 5 or 6 diagrammed?

267 DR. LAKSHMANAN:

It is right here, (indicating).

268 MR. KELBERG:

And where--is there an area where it is actually drawn in in some fashion on the schematic?

269 DR. LAKSHMANAN:

You can see it being drawn in right here on the index finger here has a linear thing and then you have the bruise next to it.

270 MR. KELBERG:

And is there any written description provided by Dr. Golden for that particular--this would be injuries 5 and 6?

271 DR. LAKSHMANAN:

Yes. You have a line going from there and this is the description for that.

272 MR. KELBERG:

What is written by Dr. Golden there?

273 DR. LAKSHMANAN:

It says: "Half an inch by half an inch reddish brown abrasion and fresh bruise." And then he has also diagrammed the abrasion here, (indicating), length, half an inch separately, which corresponds to this, so actually the description for this injury would include this handwriting here and this handwriting there, (indicating).

274 MR. KELBERG:

Would it be accurate to say, doctor, that this handwriting on the left of the first finger refers to what you have described as injury no. 5, the abrasion?

275 DR. LAKSHMANAN:

Yes.

276 MR. KELBERG:

And what Dr. Golden has written as fresh bruise is referring to what you described as injury no. 6?

277 DR. LAKSHMANAN:

Yes.

278 MR. KELBERG:

For the record, I will circle in red this entire area that Dr. Lakshmanan has just talked about. On the upper right quadrant diagram of 23 roman numeral III, I will write "G-32 inj. numbers 5 and 6."

279 MR. KELBERG:

Anything else in the way of a diagram for either of those two injuries, doctor?

280 DR. LAKSHMANAN:

No.

281 MR. KELBERG:

Anything on the addendum either?

282 DR. LAKSHMANAN:

No.

283 MR. KELBERG:

I don't think you have actually shown us injury no. 6. Why don't do you that.

284 DR. LAKSHMANAN:

It is here on the bruise on the index finger, proximal interphalangeal joint.

285 MR. KELBERG:

And again this would be in keeping with a numbering system, if you will, where you are going along the length of the index finger, the first finger, excuse me, towards the nail; is that correct?

286 DR. LAKSHMANAN:

Yes.

287 MR. KELBERG:

What is injury no. 7 then?

288 DR. LAKSHMANAN:

It is a discolored area on the nail which is a scraping and it measures 3/8 of an inch in area, and I'm pointing to it here, (indicating).

289 MR. KELBERG:

This, doctor, again a photo you reviewed, life-size photo, for your purposes of measuring?

290 DR. LAKSHMANAN:

Yes.

291 MR. KELBERG:

Are you able to tell, doctor, whether that injury occurred during the circumstances of this incident on Bundy on June 12th or whether it occurred at some earlier time?

292 DR. LAKSHMANAN:

It is difficult to say when you have a nail injury, because the nail injuries, unlike skin injuries, do not leave a reaction and there was no hemorrhage which I could see, so I can't tell when that happened, but taking in conjunction with the other injuries, it probably could have happened at the same time, but I can't tell.

293 MR. KELBERG:

Doctor, does Dr. Golden address that nail injury in any fashion?

294 DR. LAKSHMANAN:

No, he does not.

295 MR. KELBERG:

Does it diagram it in any way?

296 DR. LAKSHMANAN:

No, he does not.

297 MR. KELBERG:

Does he address it in the addendum?

298 DR. LAKSHMANAN:

No, he does not.

299 MR. KELBERG:

Do you consider each of those to be a mistake?

300 DR. LAKSHMANAN:

Yes.

301 MR. KELBERG:

Individually or collectively of any significance to you?

302 DR. LAKSHMANAN:

No.

303 MR. KELBERG:

Why not?

304 DR. LAKSHMANAN:

Because as I told you, it has no bearing on the cause of death, my ability to discuss the sharp force injuries, what type of weapon, the bleeding patterns or any of the other issues which I have addressed previously many times on the injuries.

KEY QUOTE
305 MR. KELBERG:

How about injury no. 8 then?

306 DR. LAKSHMANAN:

Injury no. 8 is a 1/8 inch abrasion over a pink contusion just above the base of the right middle finger, right here, (indicating).

307 MR. KELBERG:

Is this one of these abrasion contusions you were referring to as being the cause, in your opinion, from contact with a rough surface like the tree?

308 DR. LAKSHMANAN:

Yes.

309 MR. KELBERG:

Doctor, is this addressed in the original protocol?

310 DR. LAKSHMANAN:

Yes, it is.

311 MR. KELBERG:

Is it diagrammed?

312 DR. LAKSHMANAN:

Yes, but the--in the original protocol he has addressed it as an index finger but actually it is the middle finger. He has diagrammed it correctly.

313 MR. KELBERG:

All right. Let's see exactly what has been done here. Why don't we start with the diagram.

314 DR. LAKSHMANAN:

Okay.

315 MR. KELBERG:

Is it on this same form?

316 DR. LAKSHMANAN:

Yes, right here, (indicating). You can see it as right here, the middle finger, you have an abrasion in the middle, which is 1/8 inch here, and you can see bruise half an inch by half an inch width abrasion, so this whole area reflects the injury no. 8 which I just showed you in the photograph there.

317 MR. KELBERG:

Doctor, has Dr. Golden specifically drawn diagrammatically on the outline of the hand, and in particular the middle finger, to show that this is in fact an abrasion sitting in the middle of this contusion?

318 DR. LAKSHMANAN:

Yes, he has. He has very accurately described it. You can see the abrasion in the middle which is dense compared to the rest of the injury here.

319 MR. KELBERG:

Where you have just pointed, the area of the abrasion, I'm going to circle that in red and then I'm going to circle the entire area that you have just described in blue, and make a line going to the top of the diagram and write "G-32".

320 MR. KELBERG:

This is now injury no. 8, doctor?

321 DR. LAKSHMANAN:

Yes.

322 MR. KELBERG:

All right. Where is it described in the protocol?

323 DR. LAKSHMANAN:

It is actually on page--third sentence, and injury no. 8 should be the middle finger, but just an error here with the index finger. It says "Index finger" here, (indicating).

324 MR. KELBERG:

All right. First of all, is there an entire sentence to refer to what you've identified as injury no. 8?

325 DR. LAKSHMANAN:

Yes, umm, to the semicolon part.

326 MR. KELBERG:

All right. Let me outline that in red and write to the right "G-3 2 inj. no. 8." And in your opinion, doctor, the identification of the finger as an index finger is an error on the part of the Dr. Golden?

327 DR. LAKSHMANAN:

If he dictated it as such, yes.

328 MR. KELBERG:

As it is drawn, it is drawn on the middle finger?

329 DR. LAKSHMANAN:

Yes.

330 MR. KELBERG:

And as you see it in the photograph, is it the middle finger?

331 DR. LAKSHMANAN:

Yes.

332 MR. KELBERG:

Let me circle or underline the word "Index" in blue within this area and then I will draw a line in red out to the side and write "Should be middle, see diagram."

333 MR. KELBERG:

Doctor, is this mistake of indicating "Index" rather than "Middle" of any significance to you on the big ticket questions?

334 DR. LAKSHMANAN:

No.

335 MR. KELBERG:

Same reasons?

336 DR. LAKSHMANAN:

That's correct.

337 MR. KELBERG:

All right. Are we done with injury no. 8?

338 DR. LAKSHMANAN:

That is correct.

339 MR. KELBERG:

What is injury no. 9?

340 DR. LAKSHMANAN:

Injury no. 9 is a small--

341 MR. KELBERG:

If I could just a moment, your Honor.

342 (Discussion held off the record between the Deputy District Attorneys.)
343 MR. KELBERG:

I'm sorry. Thank you, your Honor.

344 MR. KELBERG:

Injury no. 9, please, doctor?

345 DR. LAKSHMANAN:

Injury no. 9 is a small 1/8 inch abrasion just a little bit away from the injury I just described on the middle finger. It is a little more distal.

346 MR. KELBERG:

Doctor, in looking at the diagram, 23-III, do you see a diagram by Dr. Golden?

347 DR. LAKSHMANAN:

Very accurately diagrammed as 1/8 inch abrasion here.

348 MR. KELBERG:

And he has written in some identification for that?

349 DR. LAKSHMANAN:

Yes, here, (indicating), and he has drawn a line and shown it accurately so that he has--

350 MR. KELBERG:

Doctor, does he describe it in the protocol?

351 DR. LAKSHMANAN:

Yes, he does, and that has been described accurately here. After the semicolon which we just described it says: "Just distal to the middle phalange of the middle finger is a one-inch nondescript abrasion."

352 MR. KELBERG:

Your Honor, first of all, on the diagram that Dr. Lakshmanan was outlining with the pointer, I will circle in red and I have a very short line reading "G-32 inj. no. 9."

353 MR. KELBERG:

Doctor?

354 DR. LAKSHMANAN:

Yes.

355 MR. KELBERG:

And an arrow going to that outlined area.

356 MR. KELBERG:

And then, doctor--and your Honor, for the record, I will outline the rest of that sentence and put a line out to the side, "G-32 inj. no. 9." Anything further on that injury, doctor?

357 DR. LAKSHMANAN:

No.

358 MR. KELBERG:

Let's go to injury no. 10.

359 DR. LAKSHMANAN:

Injury no. 10 is a 1/8 inch abrasion overlaying the contusion near the middle of the ring finger here, (indicating).

360 MR. KELBERG:

Doctor, is this again one of these abrasion contusions which in your opinion is due to contact with a rough surface like the tree?

361 DR. LAKSHMANAN:

That is correct. That is my opinion.

362 MR. KELBERG:

And inconsistent with what kind of abrasion--I'm sorry--what kind of blunt force trauma you would expect if a blow from a closed fist of Mr. Goldman to the head or face of the perpetrator?

363 DR. LAKSHMANAN:

That's correct.

364 MR. KELBERG:

Is this addressed in the original protocol?

365 DR. LAKSHMANAN:

Yes, it is.

366 MR. KELBERG:

Is it diagrammed?

367 DR. LAKSHMANAN:

Yes, it is.

368 MR. KELBERG:

Is it addressed in the addendum?

369 DR. LAKSHMANAN:

No.

370 MR. KELBERG:

Any reason it should have been?

371 DR. LAKSHMANAN:

Not necessary to do that.

372 MR. KELBERG:

Let's see where it is.

373 DR. LAKSHMANAN:

It is--it is on page 12, paragraph no. 3, paragraph 2 here, (indicating).

374 MR. KELBERG:

Is that entire paragraph to refer to that injury?

375 DR. LAKSHMANAN:

Yes.

376 MR. KELBERG:

Let me outline that.

377 DR. LAKSHMANAN:

Actually it also includes injury no. 11.

378 MR. KELBERG:

All right. Let's stop with the part that is injury no. 10. You tell me where it stops.

379 DR. LAKSHMANAN:

"Half an inch by half an inch bruise on the right ring finger surrounding two punctate abrasions approximately 18 inch in maximal diameter."

380 MR. KELBERG:

Is that the part that completes injury no. 10?

381 DR. LAKSHMANAN:

Yes.

382 MR. KELBERG:

Let me outline that in red and I will write to the side on the left "G-32 inj. no. 10."

383 MR. KELBERG:

While we are here then, what does the rest that have sentence refer to, or paragraph?

384 DR. LAKSHMANAN:

That refers to the fifth finger, but he has included injury no. 11 which we saw in my description--in my description in the same sentence.

385 MR. KELBERG:

And injury no. 11, as you identify it, is what?

386 DR. LAKSHMANAN:

Injury no. 11 is a punctate abrasion which is next to the injury no. 10 in the photograph. You can see it here, (indicating).

387 MR. KELBERG:

Doctor, would it be accurate to say that you see on that finger two punctate abrasions?

388 DR. LAKSHMANAN:

Yes.

389 MR. KELBERG:

And you see a contusion?

390 DR. LAKSHMANAN:

Yes.

391 MR. KELBERG:

And that you find that one of the punctate abrasions rests on the contusion?

392 DR. LAKSHMANAN:

Yes.

393 MR. KELBERG:

And collectively that is what you describe as injury no. 10?

394 DR. LAKSHMANAN:

I described as injury no. 10 and I described the other abrasion as injury no. 11.

395 MR. KELBERG:

So the second punctate abrasion you've identified as injury no. 11?

396 DR. LAKSHMANAN:

Yes.

397 MR. KELBERG:

And then for the record, your Honor, where Dr. Golden has written "Two punctate abrasions," I'm going to box that in blue and write down below "G-3 2 inj. numbers 10 and 11."

398 MR. KELBERG:

Doctor show us, please, on the diagram, if there is an entry made by Dr. Golden?

399 DR. LAKSHMANAN:

It is on no. 23 on the diagram, if we turn the page.

400 MR. KELBERG:

And I've turned the page to the first diagram.

401 DR. LAKSHMANAN:

It is diagrammed as the ring finger properly. It describes a bruise. It describes the two abrasions which are punctate 1/8 inch, and the whole area you can reflect that they were present, injury 11 and 10 of photograph G-32.

402 MR. KELBERG:

Let me outline that then.

403 MR. KELBERG:

And has Dr. Golden actually diagrammed on this form the appearance of the punctate abrasion?

404 DR. LAKSHMANAN:

Yes, he has. You can see them here, one, and the other one here, (indicating), on the bruise itself.

405 MR. KELBERG:

And in the area I circled I will write "G-32, inj. numbers 10 and 11." Anything further about those two injuries, doctor?

406 DR. LAKSHMANAN:

No.

407 MR. KELBERG:

Let's--I think you said there were 12 in this photograph; is that correct?

408 DR. LAKSHMANAN:

Yeah. 12 is the small abrasion to the ring--I mean to the little finger here, (indicating).

409 MR. KELBERG:

Is that addressed in the protocol?

410 DR. LAKSHMANAN:

Yes, it is, and it is the last sentence here on page 12, no. 3, paragraph 3, last sentence.

411 MR. KELBERG:

Let me outline that in blue and I will write "G-32 inj. no. 12." Is this also diagrammed, doctor?

412 DR. LAKSHMANAN:

Yes. You can see it here, 23-III--23-I, you can see it here, 1/16 abrasion.

413 MR. KELBERG:

Doctor, is the source or sources of that abrasion consistent with the environmental surroundings you saw on those photographs?

414 DR. LAKSHMANAN:

Yes, I do.

415 MR. KELBERG:

Does that include the ground?

416 DR. LAKSHMANAN:

Yes.

417 MR. KELBERG:

And the rough surface of the tree?

418 DR. LAKSHMANAN:

Yes.

419 MR. KELBERG:

Let me circle that area, I will do it in blue, on the chart, and I will write out at the side "G-32 inj. no. 12."

420 MR. KELBERG:

Doctor, in your opinion has Dr. Golden, with respect to each of the injuries that you have seen in the photograph, G-32, and which he describes in the protocol, with the exception of the wrong finger on the one injury, which is injury no. 8, has he accurately described each of the injuries?

421 DR. LAKSHMANAN:

Yes.

422 MR. KELBERG:

And in your opinion has he accurately diagrammed, as to those that he has diagrammed, all of the injuries you see in that photograph?

423 DR. LAKSHMANAN:

Yes, he has.

424 MR. KELBERG:

Is there anything further about that photograph and that series of 12 injuries?

425 DR. LAKSHMANAN:

No.

426 MR. KELBERG:

Your Honor, I'm not sure when the Court wanted to take a break.

427 THE COURT:

10:30.

428 MR. KELBERG:

Thank you.

429 MR. KELBERG:

All right. Doctor, let's go then--I believe we move next to G-28, if I'm not mistaken. Is that correct?

430 DR. LAKSHMANAN:

Yes. Yesterday that is what we did.

431 MR. KELBERG:

And then G-29, both of these are photographs of the palm surface of the left hand?

432 DR. LAKSHMANAN:

Yes.

433 MR. KELBERG:

Let's start with 28, identifying specifically any injuries you see.

434 DR. LAKSHMANAN:

G-28, I went over the sharp force injuries to the base of the thumb and the base of the little finger here, (indicating), not base actually, it is more on the palm of the hand near the same area as the base of the little finger, and we also discussed an abrasion to the tip of the left thumb and we also discussed a linear abrasion to the base of the left--left thumb.

435 MR. KELBERG:

Doctor, is that abrasion or those other abrasions, I think you talked about abrasions that can be inflicted if Mr. Goldman attempted to grab the knife and the knife rotated against--

436 DR. LAKSHMANAN:

Not this abrasion, (indicating). This is a scrape type abrasion which could be--it is nonspecific.

437 MR. KELBERG:

That abrasion, for the record, is the one that appears to be near the end on where the nail is of the thumb on the palmar surface, though, correct?

438 DR. LAKSHMANAN:

Yes.

439 MR. KELBERG:

Was it consistent with any of the other--any other abrasion you saw?

440 DR. LAKSHMANAN:

No. Even this linear abrasion could have a--it is a nondescript linear abrasion which could be from a rough surface.

441 MR. KELBERG:

Keep your voice up, please.

442 DR. LAKSHMANAN:

Rough surface from the plant material, trying to hold it or trying to brace yourself.

443 MR. KELBERG:

Now, doctor, have you arbitrarily numbered these injuries?

444 DR. LAKSHMANAN:

Yes, I have. The left thumb, the one near the tip, I call injury no. 1.

445 MR. KELBERG:

Let's take care of that one. Is it addressed in the protocol?

446 DR. LAKSHMANAN:

Not in the main protocol, it is not described on the diagram; it is only addressed in the addendum.

447 MR. KELBERG:

I think we have the addendum right here, board 10G, if we could put it over the protocol for just a second.

448 MR. KELBERG:

Where in the addendum, doctor?

449 DR. LAKSHMANAN:

Page 5, no. 16. Number here, "Distal phalange of the left thumb, 3/8 by 1/16 abrasion."

450 MR. KELBERG:

Is this an accurate description, in your opinion, of what you see in photograph G-28, injury no. 1?

451 DR. LAKSHMANAN:

Yes.

452 MR. KELBERG:

Let me outline this in the addendum in red and I will put "G-28, inj. no. 1."

453 MR. KELBERG:

Doctor, again, would these be mistakes on the part of Dr. Golden not to have addressed it originally in the protocol?

454 DR. LAKSHMANAN:

Yes.

455 MR. KELBERG:

And not to have diagrammed it?

456 DR. LAKSHMANAN:

That is correct.

457 MR. KELBERG:

Are they of any significance individually or collectively?

458 DR. LAKSHMANAN:

Not in the big picture items which we have discussed.

459 MR. KELBERG:

Same reasons?

460 DR. LAKSHMANAN:

Yes.

461 MR. KELBERG:

All right. Are we done with injury no. 1?

462 DR. LAKSHMANAN:

Yes.

463 MR. KELBERG:

How about injury no. 2?

464 DR. LAKSHMANAN:

Injury no. 2 is that linear abrasion in the base of the thumb here, (indicating). You can see it here running.

465 MR. KELBERG:

Is that addressed in the protocol?

466 DR. LAKSHMANAN:

No.

467 MR. KELBERG:

In the diagrams anywhere?

468 DR. LAKSHMANAN:

No.

469 MR. KELBERG:

In the addendum?

470 DR. LAKSHMANAN:

No.

471 MR. KELBERG:

All mistakes?

472 DR. LAKSHMANAN:

Yes.

473 MR. KELBERG:

Any of them of significance individually or collectively?

474 DR. LAKSHMANAN:

No.

475 MR. KELBERG:

Same reasons?

476 DR. LAKSHMANAN:

Yes.

477 MR. KELBERG:

Anything more to say about injury no. 2?

478 DR. LAKSHMANAN:

No.

479 MR. KELBERG:

Let's go to injury no. 3.

480 DR. LAKSHMANAN:

Injury no. 3 is a cut to the base of the thumb--

481 MR. KELBERG:

Keep your voice up, if you would.

482 DR. LAKSHMANAN:

A cut to the base of the thumb half an inch in length.

483 MR. KELBERG:

Is this a defensive wound, doctor?

484 DR. LAKSHMANAN:

Yes.

485 MR. KELBERG:

And in fact would you describe the other two as defensive wounds?

486 DR. LAKSHMANAN:

Yes.

487 MR. KELBERG:

All right. Is that injury no. 3 addressed in the protocol?

488 DR. LAKSHMANAN:

Yes.

489 MR. KELBERG:

Where?

490 DR. LAKSHMANAN:

Page 11, no. 3. Right here, page 11, no. 3: "Palmar surface of the left hand, the web of the thumb, there is a 3/4 of an inch cutting wound involving the skin and subcutaneous tissue, quarter inch deep with hemorrhage in the margins. This is comparable with the Defense wound," the whole paragraph.

491 MR. KELBERG:

Doctor, is this paragraph, in its entirety, in your opinion, accurate in its description and opinion as to the type of injury that injury no. 3 of G-28 is?

492 DR. LAKSHMANAN:

Yes.

493 MR. KELBERG:

Let me outline that on our board 0G. I will do it in red and I will write out at the side "G-28 inj. no. 3."

494 MR. KELBERG:

Is that injury no. 3 diagrammed, doctor?

495 DR. LAKSHMANAN:

It is diagrammed in 23-I here, (indicating).

496 MR. KELBERG:

All right. Would you identify, please, for us, where it is diagrammed and what, if any, writing is associated with it?

497 DR. LAKSHMANAN:

It is diagrammed at the base of the thumb. It says: "3/4 inch incise wound, web of thumb, skin subcu quarter inch deep hemorrhage."

498 MR. KELBERG:

What does "Subcu" mean, doctor?

499 DR. LAKSHMANAN:

Subcutaneous tissue.

500 MR. KELBERG:

"Subcutaneous" is a fancy word for saying what?

501 DR. LAKSHMANAN:

The skin underlying the skin.

502 MR. KELBERG:

What does that mean?

503 DR. LAKSHMANAN:

The wound is quarter inch in.

504 MR. KELBERG:

Is that consistent with subcutaneous?

505 DR. LAKSHMANAN:

Yes, it could be reaching the subcutaneous tissue at that point.

506 MR. KELBERG:

Let me circle the area on 23-I, again board 5G, and I will write "G-28 inj. no. 3."

507 MR. KELBERG:

Is the diagram and the description along with it accurate, in your opinion, doctor?

508 DR. LAKSHMANAN:

Yes.

509 MR. KELBERG:

Anything further about injury no. 3?

510 DR. LAKSHMANAN:

No.

511 MR. KELBERG:

Any further injuries on photograph G-28?

512 DR. LAKSHMANAN:

It also shows the portion of the sharp force injury to the palm I discussed earlier, but I have described it under G-29 actually.

513 MR. KELBERG:

All right. Anything else for G-28?

514 DR. LAKSHMANAN:

No.

515 MR. KELBERG:

Your Honor, do you wish to start on G-29 or--

516 THE COURT:

Go ahead.

517 MR. KELBERG:

Let's start with injury no. 1 then, however, you have designated it on G-29?

518 DR. LAKSHMANAN:

On G-29 I started with the--this same wound which I discussed in G-28. It is injury no. 1 in my description, and it is 5/8 of an inch in length and it curves in its ulnar aspect here, (indicating), and--

519 MR. KELBERG:

Ulnar aspect again, doctor, is toward the pinkie or little finger side?

520 DR. LAKSHMANAN:

Yes.

521 MR. KELBERG:

All right. Is that addressed in the original protocol?

522 DR. LAKSHMANAN:

No.

523 MR. KELBERG:

Is it diagrammed anywhere?

524 DR. LAKSHMANAN:

No.

525 MR. KELBERG:

Is it addressed in the addendum?

526 DR. LAKSHMANAN:

Yes, it is.

527 MR. KELBERG:

Let's get the addendum. I think we will switch here for just a second. Let's put this up on this side.

528 MR. KELBERG:

Where in the addendum, doctor?

529 DR. LAKSHMANAN:

Page 4, no. 13.

530 MR. KELBERG:

If I could ask Mr. Lynch to join me here.

531 DR. LAKSHMANAN:

No. 13 says: "Palmar surface of the left hand, ulnar aspect, transversely oriented wound, 5/8 inch in length."

532 MR. KELBERG:

Is this an accurate, description, in your opinion, of what you see in that photograph?

533 DR. LAKSHMANAN:

Yes.

534 MR. KELBERG:

Let me outline that in red and I will write "G-29 inj. no. 1."

535 MR. KELBERG:

Doctor, again a mistake not to address it originally in the protocol?

536 DR. LAKSHMANAN:

Yes.

537 MR. KELBERG:

Not to diagram it?

538 DR. LAKSHMANAN:

Yes.

539 MR. KELBERG:

Singularly, collectively, any significance to you?

540 DR. LAKSHMANAN:

No.

541 MR. KELBERG:

Same reasons?

542 DR. LAKSHMANAN:

Yes.

543 MR. KELBERG:

All right.

544 THE COURT:

One more.

545 MR. KELBERG:

Okay. Injury no. 2 of photo G-29. Let me take this down, if I could, please. I got the photo.

546 DR. LAKSHMANAN:

Injury no. 2 is located on the little finger and you see it here. It is a 3/8 inch by quarter inch abrasion in my measurement of the one-as-to-one photograph with the skin being peeled off with a flap of peeled skin seen here. I'm pointing to it, (indicating).

547 MR. KELBERG:

Is the fact you see a flap of peeled skin of significance to you in identifying how that injury came to be inflicted?

548 DR. LAKSHMANAN:

As I mentioned earlier yesterday, I felt that it could be related to this cut in the left palm of the hand when the knife was--there was an attempted probable grabbing of the knife and with the knife turning, this skin could have been peeled off. That is one way it could have occurred, because if you look at the flap of the skin, it looks like very thin flap which has come off of the surface.

549 MR. KELBERG:

Is the direction of the flap of some significance to you in evaluating the direction of the force which has created that abrasion?

550 DR. LAKSHMANAN:

Yes. It would mean two things: Either the skin moved in a fashion towards the wrist, the hand moving in this manner, (indicating), on the--

551 MR. KELBERG:

Downward?

552 DR. LAKSHMANAN:

Downward. Or the force which caused it moved upwards to the tip of the finger to peel the skin in such a manner that you have a flap of skin toward the distal aspect of the finger.

553 MR. KELBERG:

For the record, your Honor, Dr. Lakshmanan used his right hand to move upward against the left palm of his--I'm sorry, the palm of his left hand.

554 THE COURT:

Thank you.

555 DR. LAKSHMANAN:

I just gave you one possible mechanism how it could have occurred.

556 MR. KELBERG:

Was this addressed in the protocol, injury no. 2?

557 DR. LAKSHMANAN:

No.

558 MR. KELBERG:

Diagrammed?

559 DR. LAKSHMANAN:

No.

560 MR. KELBERG:

Addressed in the addendum?

561 DR. LAKSHMANAN:

Yes, it has been.

562 MR. KELBERG:

Let's throw the addendum back up and take care of this one. Where, doctor?

563 DR. LAKSHMANAN:

It was a page on page 5, no. 15.

564 MR. KELBERG:

Page 5, no. 15?

565 DR. LAKSHMANAN:

15, yes. It says: "The volar surface of the left fifth finger shows a superficial brown abrasion with a 3/8--measuring 3/8 of an inch by 3/8 of an inch with portions of avulsed skin."

566 MR. KELBERG:

"Avulsed" is a fancy way of saying what, doctor?

567 DR. LAKSHMANAN:

Peeled off.

568 MR. KELBERG:

And "Volar" is the palm side of the hand?

569 DR. LAKSHMANAN:

Yes.

570 MR. KELBERG:

Is this an accurate description, in your opinion, of the injury no. 2 or is it injury 2 or 3?

571 DR. LAKSHMANAN:

Yes, injury no. 2.

572 MR. KELBERG:

That you see in that photograph G-29?

573 DR. LAKSHMANAN:

Yes.

574 MR. KELBERG:

Let me outline that in red on the board. This is 10G again, your Honor.

575 THE COURT:

Yes.

576 MR. KELBERG:

And I will write "G-29 inj. no. 2."

577 MR. KELBERG:

Anything further about injury no. 2 of G-29?

578 DR. LAKSHMANAN:

No, no.

579 THE COURT:

All right. Ladies and gentlemen, we are going to take our recess, mid-morning recess. Please remember all of my admonitions to you. Don't discuss the case among yourselves, form any opinions about the case, allow anybody to communicate with you or conduct any deliberations until the matter has been submitted to you. We will take a 15-minute recess. All right.

580 (Recess.)

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
I would expect to see contusion in the adjoining knuckles and also the adjoining portion of the phalanges, which we don't see here. We only see localized to one knuckle here. And the other issue is also that the other injuries in the other fingers show to be abrasion contusions, so the only pure contusion is to one knuckle, which seems a rather unusual. If it was a closed fist which delivered a direct blow to a person, I would expect to see more injuries to the other knuckles, especially the fourth and fifth knuckles.
Core forensic opinion that Goldman did not land a punch on the perpetrator—undermines any theory that the attacker would have identifiable facial injuries.
Dr. Lakshmanan Sathyavagiswaran
I have no doubt that these are antemortem wounds based on the description of the autopsy report and the appearance of these photographs, the way they are presented to me.
Directly contradicts Dr. Golden's grand jury opinion that the superficial incise wounds were inflicted near the time of death, supporting Lakshmanan's 'control wounds' theory of a taunting perpetrator.
Dr. Lakshmanan Sathyavagiswaran
Because as I told you, it has no bearing on the cause of death, my ability to discuss the sharp force injuries, what type of weapon, the bleeding patterns or any of the other issues which I have addressed previously many times on the injuries.
Recurring refrain that neutralizes defense attempts to use Golden's documentation errors as evidence of broader incompetence.
Brian Kelberg
I take it not very subtle hint.
Light moment—responding to Judge Ito's reminder to 'conclude' the direct examination, revealing the lengthy nature of this testimony.

Evidence (9)

People's 358-B
Cropped crime scene photograph showing superficial incise wounds on Goldman, relevant to hemorrhage and antemortem timing
marked and discussed
G-37
Photographs of injuries numbers 1 and 2 on Goldman—superficial incise wounds
discussed
G-51
Photographs of Goldman's fatal neck wounds including stab wound, linear wound behind ear, and nick to pinna
discussed
G-35
Photograph of Goldman's right hand showing defensive cuts in web between index and middle finger and Y-shaped wound near thumb base
discussed in detail, injuries numbered 1 and 2
G-34
Photograph of Goldman's right hand (same injury as G-35 no. 1 but with fingers pried apart for visibility), plus 12 additional hand injuries
discussed in detail
G-32
Photograph of Goldman's right hand showing 12 injuries including abrasions, contusions, and punctate abrasions on multiple fingers
discussed in full—injuries 1 through 12 catalogued
+ 3 more

Notable Exchanges (3)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg walks through the biomechanics of a closed-fist punch to establish Goldman did not strike his attacker—Lakshmanan explains that a direct blow would produce contusions across multiple knuckles and phalanges, not the single isolated contusion seen on Goldman's middle finger knuckle.
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Systematic documentation of Dr. Golden's errors (injuries not described, wrong finger named, injuries not diagrammed) followed immediately by Lakshmanan dismissing each as insignificant—a prosecution strategy to preempt defense attacks on autopsy quality.
strategic
Brian KelbergLance A. Ito
Brief exchange at the start where Ito subtly pressures Kelberg to conclude, and Kelberg jokes about it before asking if he has 'at least perhaps all day.'
light

Light Moments (1)

Brian Kelberg
Kelberg responds to Ito's reminder to conclude direct examination with 'I take it not very subtle hint,' then asks if he has 'at least perhaps all day'—Ito replies simply 'Reasonable time.'

Credibility Attacks (1)

⚔ Dr. Irwin Golden
prior inconsistent statement / documentation errors
Kelberg systematically uses Lakshmanan to catalog Golden's autopsy errors—wrong finger identification for injury no. 8, injuries not described in protocol (nos. 2, 4, 7 of G-32; nos. 1 and 2 of G-28), not diagrammed, not addressed in addendum—while simultaneously having Lakshmanan neutralize each error as insignificant. Also highlights inconsistency between Golden's grand jury opinion (superficial wounds near time of death) and his own autopsy report noting hemorrhage suggesting antemortem wounds.

Witness Demeanor

(indicating) — used repeatedly as Lakshmanan points to specific injuries on photographs and diagrams throughout testimony
Frequently reminded by Kelberg to 'keep your voice up' suggesting soft-spoken delivery

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 6368 • 580 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 13, 1995 📄 Direct examination of Dr. Laks
JUN 13, 1995 KRT DvH TD