📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 2) — 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 2)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Tuesday, June 13, 1995 • Utterances: 693
Brian Kelberg continues his methodical direct examination of Chief Medical Examiner Dr. Lakshmanan, walking through dozens of blunt force and sharp force injuries to Ron Goldman's hands, forearms, face, and chest using autopsy photographs and diagrams. Dr. Lakshmanan repeatedly finds Dr. Golden's original autopsy documentation deficient — failing to note, diagram, or accurately describe individual injuries — while consistently concluding these omissions have no significance to the overall findings. The examination also establishes that Goldman's hand injuries are consistent with a struggle against the environment (branches, rough surfaces) rather than Goldman striking his attacker.
1 THE COURT:

All right. Thank you, ladies and gentlemen. Be seated. Doctor. And, Mr. Kelberg, you may resume concluding your direct examination.

2 MR. KELBERG:

Thank you, your Honor.

3 THE COURT:

You're welcome.

4 MR. KELBERG:

Doctor, again, with the Court's permission, would you step to the board, and let's pick up with respect to these injuries to the hands.

5 (The witness complies.)
6 MR. KELBERG:

And I think we're now on to, if there is an injury no. 3 of G-29, we're at that stage.

7 DR. LAKSHMANAN:

Yes. The injury no. 3 is an area of abrasion injury to the palm of the hand in the middle finger and near the tip of the middle finger, there are about three abrasions there, one, two and three, and they measure approximately quarter inch by 1/16 inch and 3/8 inch and quarter inch by 1/16 inch, and that's injury no. 3.

8 MR. KELBERG:

Have you marked that then collectively, these abrasions, as injury no. 3?

9 DR. LAKSHMANAN:

Yes.

10 MR. KELBERG:

Do you have an opinion, doctor, as to the manner in which injury no. 3, these series of abrasions, were received?

11 DR. LAKSHMANAN:

That's a nonspecific blunt force injury and it could be from scraping against any rough surface.

12 MR. KELBERG:

Doctor, is this addressed in the protocol?

13 DR. LAKSHMANAN:

No.

14 MR. KELBERG:

Diagrammed anywhere?

15 DR. LAKSHMANAN:

No.

16 MR. KELBERG:

Addressed in the addendum?

17 DR. LAKSHMANAN:

Yes.

18 MR. KELBERG:

Where in the addendum?

19 DR. LAKSHMANAN:

Page 5, no. 14.

20 MR. KELBERG:

Let me pull the board down this way so we can see the injury. And if Mr. Lynch can turn to page 5. Doctor, does that description in item 14 of page 5 accurately describe in your opinion what you have described as injury no. 3?

21 DR. LAKSHMANAN:

No. It has been described collectively here, but actually there are--you can see three separate abrasions, but in the same area. So the report described abrasion collectively rather than individually.

22 MR. KELBERG:

Are you able then to see that these are individual abrasions?

23 DR. LAKSHMANAN:

Well, you can see the--there are some areas where they oppose each other, but they look like three separate areas of injury.

24 MR. KELBERG:

When you say "They oppose each other," what do you mean?

25 DR. LAKSHMANAN:

The margins oppose.

26 MR. KELBERG:

They're opposite each other?

27 DR. LAKSHMANAN:

They touch each other.

28 MR. KELBERG:

Now, doctor, in your opinion, is it a mistake on the part of Dr. Golden to have described these in the addendum "Collectively" rather than to see them and describe them as individual abrasions?

29 DR. LAKSHMANAN:

Yes.

30 MR. KELBERG:

And his mistake--I assume you find it to be a mistake of not including it in the protocol and a mistake of not diagramming it?

31 DR. LAKSHMANAN:

Yes.

32 MR. KELBERG:

Collectively, individually, any significance to them?

33 DR. LAKSHMANAN:

No.

34 MR. KELBERG:

Same reasons?

35 DR. LAKSHMANAN:

Yes.

36 MR. KELBERG:

If Mr. Lynch could, because I think he's going to have a better chance maybe in blue, outline that area on the board, the addendum 10-G and then write out at the side, if you would, please, "G-29, inj. 3." And if you could write in quotation marks "Collectively."

37 (Mr. Lynch complies.)
38 MR. KELBERG:

And may the record reflect that he has done so, your Honor?

39 THE COURT:

Yes.

40 MR. KELBERG:

All right. Doctor, anything further regarding injury no. 3?

41 DR. LAKSHMANAN:

No.

42 MR. KELBERG:

If we could ask Mr. Lynch then to take down the addendum. Let's go to--is there an injury no. 4 in the photograph of the palm of the left hand, G-29?

43 DR. LAKSHMANAN:

No.

44 MR. KELBERG:

So are we done with that photograph?

45 DR. LAKSHMANAN:

Yes, we have.

46 MR. KELBERG:

All right. Let's go to--I think we then talked about G-26 and then we had this smaller photograph that is B-25.

47 DR. LAKSHMANAN:

Yes.

48 MR. KELBERG:

And this is now the back of the left hand?

49 DR. LAKSHMANAN:

Yes.

50 MR. KELBERG:

And the wrist and lower part of the arm?

51 DR. LAKSHMANAN:

Yes.

52 MR. KELBERG:

All right. Do you have again this arbitrary numbering system for injuries seen?

53 DR. LAKSHMANAN:

Yes.

54 MR. KELBERG:

Let's start with injury no. 1.

55 DR. LAKSHMANAN:

Injury no. 1 is the contusion to the back of the hand with a small abrasion which is punctate overlying it.

56 MR. KELBERG:

Doctor, is this again the same kind of contusion with punctate abrasion identified earlier on photograph G-32 in the area of the knuckles of the fingers?

57 DR. LAKSHMANAN:

Yes.

58 MR. KELBERG:

And is your opinion concerning the source for that abrasion contusion the same as you opined regarding the source or sources for the abrasion contusions to the fingers as seen in G-32?

59 DR. LAKSHMANAN:

Could be one of the sources.

60 MR. KELBERG:

In your opinion, doctor, is it inconsistent, however, with the source being a blow from Mr. Goldman's clenched fist to the face of the perpetrator?

KEY QUOTE
61 DR. LAKSHMANAN:

That is correct.

62 MR. KELBERG:

Same reasons as you've previously expressed?

63 DR. LAKSHMANAN:

Yes.

64 MR. KELBERG:

All right. Is that diagrammed by Dr. Golden?

65 DR. LAKSHMANAN:

Yes.

66 MR. KELBERG:

Is it addressed in the protocol?

67 DR. LAKSHMANAN:

Yes.

68 MR. KELBERG:

Is it addressed at all in the addendum?

69 DR. LAKSHMANAN:

No.

70 MR. KELBERG:

Any reason it should have been?

71 DR. LAKSHMANAN:

Not necessary to.

72 MR. KELBERG:

Where in the protocol?

73 DR. LAKSHMANAN:

It's page 12, no. 4.

74 MR. KELBERG:

Keep your voice up, please, doctor.

75 DR. LAKSHMANAN:

Page 12, no. 4.

76 MR. KELBERG:

And point out, if you would, please, where on page 4, no. 4--page 12, no. 4 of board 0G.

77 DR. LAKSHMANAN:

It's here on the last line, the last sentence of page 12, no. 4, there's a fresh bruise on the dorsal surface of the left hand surrounding a punctate abrasion.

78 MR. KELBERG:

I'll outline that in red and we'll write in "G-26." And is it also seen in G-25, doctor, the small photograph or is it covered by the card?

79 DR. LAKSHMANAN:

It's covered by the card on--

80 MR. KELBERG:

The small photo is G-25.

81 DR. LAKSHMANAN:

Okay. It's covered on G-25.

82 MR. KELBERG:

All right.

83 DR. LAKSHMANAN:

Partially covered. Partially covered.

84 MR. KELBERG:

I'll write "G-26 inj. no. 1." Correct, doctor?

85 DR. LAKSHMANAN:

Yes.

86 MR. KELBERG:

Where is it diagrammed, if at all?

87 DR. LAKSHMANAN:

It's diagrammed on I think 23-II or III I think. Can you turn--

88 MR. KELBERG:

This is on 23-II of the board. I think it's 5-G?

89 MR. LYNCH:

5-G.

90 MR. KELBERG:

Mr. Lynch confirms it's 5-G.

91 MR. KELBERG:

All right. Doctor, is there some writing that goes along with this injury diagram?

92 DR. LAKSHMANAN:

Yes. It says "Fresh bruise hemorrhage" and it says here--I'm sorry--one and a quarter inch by one inch. One and a quarter inch by one inch and "Punctate abrasion."

93 MR. KELBERG:

And has Dr. Golden specifically diagrammed the abrasion to be in the center of what he has diagrammed to be the bruise?

94 DR. LAKSHMANAN:

Yes.

95 MR. KELBERG:

Is that an accurate depiction of that injury?

96 DR. LAKSHMANAN:

Yes, it is.

97 MR. KELBERG:

And is it an accurate description of that injury?

98 DR. LAKSHMANAN:

Yes, it is.

99 MR. KELBERG:

All right. Let me circle this area in red and out at the side, "G-26 inj. no. 1." Anything further on that?

100 DR. LAKSHMANAN:

No.

101 MR. KELBERG:

Let's go to no. 2 then if we could, please, doctor.

102 DR. LAKSHMANAN:

No. 2 is the linear abrasion which is situated between the base of the index finger and the wrist which here this is about three-quarters of an inch in length in my measurement and it's also diagrammed and described.

103 MR. KELBERG:

Doctor, is there any significance to you in the appearance of that linear abrasion?

104 DR. LAKSHMANAN:

It's just a nonspecific linear abrasion.

105 MR. KELBERG:

Do you have an opinion as to any source or sources for that?

106 DR. LAKSHMANAN:

The same plant type environment which I described earlier in the crime scene photographs, the branches or one of them can do that kind of abrasion.

107 MR. KELBERG:

Doctor, where is it diagrammed?

108 DR. LAKSHMANAN:

It's again diagrammed in 33-II right here (indicating).

109 MR. KELBERG:

What is the description if any given?

110 DR. LAKSHMANAN:

It's--it's described in actually paragraph 2 here (indicating), and you can see it here on 3/4 inch long skin abrasion terminating 1/8 inch nondescript punctate abrasion, and this is the abrasion which is--

111 MR. KELBERG:

Keep your voice up, please, doctor.

112 DR. LAKSHMANAN:

--this is the abrasion which is diagrammed here and this is the punctate part of the linear abrasion.

113 MR. KELBERG:

What is the significance, if any, to there being a punctate part of a linear abrasion?

114 DR. LAKSHMANAN:

As I told you, this is a nondescript blunt force trauma. And let's assume that the hypothetical situation is, you have a small branch or sharp--not--semi-sharp, not sharp branch which strikes the portion of the skin. And you can get a punctate part of the abrasion caused by that, but when the hand moves, the branch will be drawing against the particular surface of the skin causing the linear appearance adjoining the punctate part.

115 MR. KELBERG:

The hand in this hypothetical is sliding down in essence?

116 DR. LAKSHMANAN:

Yeah. That will be one way it can be caused.

117 MR. KELBERG:

Now, doctor--I'm sorry. Is it just that one sentence of item 4 of page 12 starting with "On the dorsal surface"?

118 DR. LAKSHMANAN:

Yes. That whole sentence and it's diagrammed here (indicating).

119 MR. KELBERG:

And is there a description given by Dr. Golden along with the diagram of the linear abrasion with the punctate?

120 DR. LAKSHMANAN:

Yes. This whole sentence here (indicating).

121 MR. KELBERG:

What does he say that?

122 DR. LAKSHMANAN:

Length 3/4 inch skin abrasion. Then he says, abrasion 1/8 inch punctate, which is the lower part here (indicating).

123 MR. KELBERG:

In your opinion, do these entries both on the protocol and on the diagram accurately describe and diagram that injury?

124 DR. LAKSHMANAN:

Yes, they do.

125 MR. KELBERG:

All right. Let me outline those, please, in red on page 12 of the protocol, and I'll write "G-26, inj. no. 2" is it, doctor?

126 DR. LAKSHMANAN:

Yes. In my description, yes.

127 MR. KELBERG:

All right. And I'll do the same over here and write out at the side "G-26 inj. no. 2." Anything further on that?

128 DR. LAKSHMANAN:

No.

129 MR. KELBERG:

Let's go to no. 3 if there is a no. 3.

130 DR. LAKSHMANAN:

Yes. No. 3 is abrasion which is described as "W" shape in the knuckle area at the base of the middle finger here (indicating).

131 MR. KELBERG:

And that's an abrasion?

132 DR. LAKSHMANAN:

Yes.

133 MR. KELBERG:

Is the appearance of it described as a "W" shape--first of all, is that an accurate description of it?

134 DR. LAKSHMANAN:

Yes. If you look in the magnifying glass, you can see the middle limb of the "W", but if you look at it just from a distance, you can see it looks like a "V".

135 MR. KELBERG:

Well, with the magnifying glass, you see all three limbs in the--

136 DR. LAKSHMANAN:

Yes. You can see the--you can see a faint third limb there.

137 MR. KELBERG:

Doctor, is there any significance to you of the "W" shape in forming any opinion if you have concerning the source or sources for that particular injury?

138 DR. LAKSHMANAN:

It's a--it's a--it looks like a particular pattern, but I can't really tell a source for it. It's a nonspecific type of blunt force abrasion injury. It could be related to the same environment we discussed regarding the branches and the plant material there, but I can't really pinpoint a particular source to it.

139 MR. KELBERG:

Described by Dr. Golden in the protocol?

140 DR. LAKSHMANAN:

Yes.

141 MR. KELBERG:

Diagrammed?

142 DR. LAKSHMANAN:

Yes.

143 MR. KELBERG:

Addressed in the addendum?

144 DR. LAKSHMANAN:

No.

145 MR. KELBERG:

Any need to?

146 DR. LAKSHMANAN:

No.

147 MR. KELBERG:

Where in the protocol?

148 DR. LAKSHMANAN:

It's on page 12, no. 4. If you look at the first sentence, it starts--it's a long sentence on item 4, paragraph 2. There is an irregularly configured abrasion of the proximal knuckle of the left middle finger, apparently 3 linear half an inch abrasions converging at the center having a configuration of the letter "W". They're all superficial skin abrasions.

149 MR. KELBERG:

Just for the record, you've left out a few words as you've read portions of that description; is that correct?

150 DR. LAKSHMANAN:

Yes. I was just summarizing the main highlights of the description.

151 MR. KELBERG:

Is it accurate in your opinion as you look at the abrasion in the photograph?

152 DR. LAKSHMANAN:

Yes. It's described here "Superficial abrasion" and it's diagrammed and described there.

153 MR. KELBERG:

Is that an accurate diagram, a diagrammatic depiction along with description in that 23-II?

154 DR. LAKSHMANAN:

Yes.

155 MR. KELBERG:

Let me outline that area then in both the protocol--I'll do that in blue. I'll write out at the right side "G-26 inj. no. 3" are we at, doctor, injury no. 3?

156 DR. LAKSHMANAN:

Yes.

157 MR. KELBERG:

Okay. And I'll circle the same area you outlined in the upper left quadrant of 23-I and II in blue and write "G-26 inj. no. 3." Anything further about no. 3?

158 DR. LAKSHMANAN:

No.

159 MR. KELBERG:

Let's go to no. 4 if there is one.

160 DR. LAKSHMANAN:

Injury no. 4 is a punctate abrasion adjacent to the "W" abrasion I just described, and that has been diagrammed, but not described in the protocol.

161 MR. KELBERG:

Where is it diagrammed, doctor?

162 DR. LAKSHMANAN:

23-I. It's diagrammed there, next to it.

163 MR. KELBERG:

Is there any description provided?

164 DR. LAKSHMANAN:

No.

165 MR. KELBERG:

I want to be sure--I'd like you to circle if you would, doctor, in red, what you believe to be the diagrammatic depiction of this injury.

166 DR. LAKSHMANAN:

The "W" or the smaller one?

167 MR. KELBERG:

The smaller one.

168 (The witness complies.)
169 MR. KELBERG:

And you've done that in red, and this is described by you as injury no. 4 of G-26?

170 DR. LAKSHMANAN:

Yes.

171 MR. KELBERG:

Now, doctor, is this another depiction of that "W" shaped abrasion that you saw and outlined for us earlier on II?

172 DR. LAKSHMANAN:

Yes. What he has done is, he diagrammed it in that diagram and again diagrammed it in this diagram, and in this diagram is included a measurement of each limb, half an inch.

173 MR. KELBERG:

What--has he written anything besides the length of the measurement?

174 DR. LAKSHMANAN:

He says skin abrasion, length, half an inch and letter "W" here (indicating).

175 MR. KELBERG:

All right. I'm going to circle that in blue on I, form 23, and out at the side, I'll write "G-26 inj. no. 3." Is that correct, doctor?

176 DR. LAKSHMANAN:

Yes.

177 MR. KELBERG:

And the area that--I'm sorry--that you circled-- this is actually injury no. 4. I believe I made a mistake.

178 DR. LAKSHMANAN:

Yes. Injury no. 4.

179 MR. KELBERG:

All right. Your Honor, for the record, I wrote no. 2. May I have the record reflect I'm taking the blue marker and covering over the no. 2, and in red I'll write the no. 4?

180 THE COURT:

Yes.

181 MR. KELBERG:

Anything else regarding that one, doctor?

182 DR. LAKSHMANAN:

No.

183 MR. KELBERG:

Let's go to no. 5.

184 DR. LAKSHMANAN:

No. 5 is a small abrasion the--as you can see, the base of the little finger here, very small one (indicating).

185 MR. KELBERG:

Is that addressed in the protocol?

186 DR. LAKSHMANAN:

No.

187 MR. KELBERG:

Diagrammed?

188 DR. LAKSHMANAN:

No.

189 MR. KELBERG:

In the addendum?

190 DR. LAKSHMANAN:

No.

191 MR. KELBERG:

All mistakes?

192 DR. LAKSHMANAN:

Yes.

193 MR. KELBERG:

Any significance?

194 DR. LAKSHMANAN:

No.

195 MR. KELBERG:

Same reasons?

196 DR. LAKSHMANAN:

Yes.

197 MR. KELBERG:

Any opinions regarding the source or sources for that small abrasion?

198 DR. LAKSHMANAN:

It's the same, similar nonspecific blunt force trauma, same kind of scenario which can cause them as I discussed earlier like the environment.

199 MR. KELBERG:

Is there an injury number--I think we're up to 6.

200 DR. LAKSHMANAN:

Yes. And this is a quarter inch by 3/16 inch abrasion with a mild contusion near the base of the back of the index finger right here (indicating).

201 MR. KELBERG:

All right. Now, you're pointing--that's our G-25. Is that injury seen in both G-25 and G-26?

202 DR. LAKSHMANAN:

Yes.

203 MR. KELBERG:

And for the next series of injuries that we're going to look at, are we starting at the base of the first finger and working our way towards the nail of the first finger?

204 DR. LAKSHMANAN:

I mean index finger, yes.

205 MR. KELBERG:

I'm sorry. And is it accurate to say that G-25, the smaller photograph, shows more fully each of those injuries?

206 DR. LAKSHMANAN:

That is correct.

207 MR. KELBERG:

All right. Tell us a bit about then injury no. 6.

208 DR. LAKSHMANAN:

That's a quarter inch by 3/16 inch abrasion with a mild contusion near the base of the index finger.

209 MR. KELBERG:

Is that something that in your opinion is consistent with being caused by a flailing and coming in contact with a rough surface like a tree?

210 DR. LAKSHMANAN:

That is correct.

211 MR. KELBERG:

Is that diagrammed somewhere?

212 DR. LAKSHMANAN:

Yes, it is. It's diagrammed in 23-I.

213 MR. KELBERG:

We have that up. Would you point out where that is, doctor?

214 DR. LAKSHMANAN:

(indicating).

215 MR. KELBERG:

And is there anything written alongside that?

216 DR. LAKSHMANAN:

Just says "Punctate abrasion" there. "Punctate." Doesn't say "Abrasion." Just says "Punctate."

217 MR. KELBERG:

Says "Punctate"?

218 DR. LAKSHMANAN:

Yes.

219 MR. KELBERG:

Is that a completely accurate description of what you see in the photograph as injury no. 6?

220 DR. LAKSHMANAN:

No. It doesn't describe the contusion as you can see in the photograph.

221 MR. KELBERG:

Let me circle this area in red in the upper left quadrant, and I'll write "G-26, 25 inj. no. 6." Would it be a mistake to characterize it only as a punctate abrasion?

222 DR. LAKSHMANAN:

Yes.

223 MR. KELBERG:

Is that described in the protocol, injury no. 6?

224 DR. LAKSHMANAN:

He has described all the injuries to the index finger collectively as one sentence in page 4--I mean page 12, no. 4.

225 MR. KELBERG:

Would you show us using the photograph what Dr. Golden has described collectively?

226 DR. LAKSHMANAN:

He has described the injuries to the different part of the index finger. You have an abrasion contusion. Let's go to G-25. You have abrasion contusion at the base of the index finger, one of the proximal interphalangeal joint, and then you have two abrasions distal to it on the middle phalanx.

227 MR. KELBERG:

When you say "Distal," moving towards the finger?

228 DR. LAKSHMANAN:

Tip of the finger, yes.

229 MR. KELBERG:

Okay. I'm sorry. The nail I should say.

230 DR. LAKSHMANAN:

Yes.

231 MR. KELBERG:

So you have in your opinion a total of four injuries?

232 DR. LAKSHMANAN:

That is correct.

233 MR. KELBERG:

Is it a mistake in your judgment for Dr. Golden to have described these, as you pointed out on page 12 of the protocol under item 4, described them collectively rather than individually?

234 DR. LAKSHMANAN:

Well, it is a mistake in the sense that he has not described them individually, but he has addressed them.

235 MR. KELBERG:

In the way he addresses them, is that description accurate?

236 DR. LAKSHMANAN:

The abrasion part of it is accurate, but as I told you, the injury no. 7 also has a contusion underlying it.

237 MR. KELBERG:

How about diagramming? Before we mark in any fashion this collective description, has injury number--I think we're up to no. 6.

238 DR. LAKSHMANAN:

No. 7 now.

239 MR. KELBERG:

No. 7, has that been diagrammed?

240 DR. LAKSHMANAN:

Yes, it is. You can see here (indicating).

241 MR. KELBERG:

And you've got no. 7 and what subsequent one, doctor?

242 DR. LAKSHMANAN:

I have 8 and 9 after that, and I've already shown them on the G-25 distal to no. 7.

243 MR. KELBERG:

And does Dr. Golden diagram those injuries in the same schematic?

244 DR. LAKSHMANAN:

He has diagrammed one single marking on the finger corresponding to 8 and 9.

245 MR. KELBERG:

Has he written anything concerning any of that area?

246 DR. LAKSHMANAN:

He has indicated that that is areas of abraded--I mean brown--I mean red abrasion in the back area there.

247 MR. KELBERG:

Doctor, would it be accurate if I were to circle this entire area (indicating) to then describe what you are describing as injuries nos. 7, 8 and 9?

248 DR. LAKSHMANAN:

Yes. Actually all this would also include that because he says "Multiple red brown abrasions" and he says quarter inch by 3/8 inch. That's a maximum dimension he gives it, reddish brown, and all this area would be included.

249 MR. KELBERG:

And, doctor, what, if anything, does this refer to?

250 DR. LAKSHMANAN:

He says that this will be the three knuckles of the index finger. He calls them, each of them a knuckle, the interphalangeal joints.

251 MR. KELBERG:

And I can not make out, can you, the words that appear above the word "Knuckle" that you were just pointing to?

252 DR. LAKSHMANAN:

I am not able to read that. I think it's--

253 MR. KELBERG:

Keep your voice up, please.

254 DR. LAKSHMANAN:

I think it refers to "Irregular" here and configuration, "Conf."

255 MR. KELBERG:

So now, doctor, I want--before I draw, I want to be sure I'm accurate. Would all of this information refer then to what you've described as injuries 7, 8 and 9?

256 DR. LAKSHMANAN:

Yes.

257 MR. KELBERG:

All right. For the record then, your Honor, I will do that with the blue pen.

258 MR. KELBERG:

And in the upper left quadrant diagram 23-I, I'll write "G-26, 25, injs. No. 7, 8 and 9," doctor?

259 DR. LAKSHMANAN:

Yes.

260 MR. KELBERG:

And in the protocol itself, doctor, this first paragraph refers to what you have described as injuries 6, 7, 8 and 9?

261 DR. LAKSHMANAN:

Yes. Paragraph 4.

262 MR. KELBERG:

I'll outline that in red, and out at the side, "G-26, 25, injs. No. 6, 7, 8 and 9" with an arrow touching the box. Anything further regarding these injuries, doctor?

263 DR. LAKSHMANAN:

No. I already addressed that 6 and 7 are also a contusion underlying them.

264 MR. KELBERG:

And again, Dr. Golden's diagram does not include that description?

265 DR. LAKSHMANAN:

That's correct.

266 MR. KELBERG:

Nor does his protocol?

267 DR. LAKSHMANAN:

Yes.

268 MR. KELBERG:

Mistakes on your--in your judgment on his part?

269 DR. LAKSHMANAN:

Yes.

270 MR. KELBERG:

Any significance?

271 DR. LAKSHMANAN:

No significance to the big picture items.

272 MR. KELBERG:

Is it significant, however, as to sources for those blunt force trauma injuries?

273 DR. LAKSHMANAN:

Yes. Because if it's just an abrasion, you'll just have a scrape against a rough surface. But if it's an abrasion contusion, it would be an impact of the hand against that surface which has a different connotation as to the mechanism of injury.

KEY QUOTE
274 MR. KELBERG:

And when you say an "Impact," doctor, would that be in your opinion consistent with a hand that is moving with force in a backward direction by Mr. Goldman coming in contact with the rough surface like the tree and backing away from the assailant?

275 DR. LAKSHMANAN:

Yes.

276 MR. KELBERG:

Anything further about injuries 6, 7, 8 or 9?

277 DR. LAKSHMANAN:

No.

278 MR. KELBERG:

Is there any additional injury in either photograph G-26 or G-25?

279 DR. LAKSHMANAN:

There is--I described one more injury in G-26. There's a small abrasion above the abrasion contusion that we've described here, and this is a 5/16 inch by 5/8 inch contusion--I mean abrasion.

280 MR. KELBERG:

Doctor, is it seen in photograph G-25 as well?

281 DR. LAKSHMANAN:

Yes. You see it better here.

282 MR. KELBERG:

And for the record, on G-26, it appears that the area of the injury that is closest to the hand is in contact or covered if you will by a margin of the photographic identification card?

283 DR. LAKSHMANAN:

Yes.

284 MR. KELBERG:

All right. Doctor, now, this is an abrasion in your opinion?

285 DR. LAKSHMANAN:

Yes.

286 MR. KELBERG:

Do you have an opinion as to the source or sources?

287 DR. LAKSHMANAN:

It's a nonspecific blunt force scraping injury to the back of the forearm.

288 MR. KELBERG:

Is it one that in your opinion is antemortem, before death?

289 DR. LAKSHMANAN:

Yes.

290 MR. KELBERG:

And is it diagrammed in any way by Dr. Golden?

291 DR. LAKSHMANAN:

Yes. It's diagrammed as--in 21-I.

292 MR. KELBERG:

And I think Mr. Lynch has that.

293 MR. KELBERG:

It's board 3-G, your Honor.

294 THE COURT:

Thank you.

295 DR. LAKSHMANAN:

It could possibly be reflected by this abrasion injury here (indicating), but it's difficult to decide whether if you really--

296 MR. KELBERG:

Keep your voice up, please, doctor.

297 DR. LAKSHMANAN:

This diagrammatic marking here could represent that. I'm not sure whether that's what it was representing.

298 MR. KELBERG:

What if any writing is associated with that?

299 DR. LAKSHMANAN:

It just says "Abrasion" here (indicating).

300 MR. KELBERG:

Is there a description given by dimension or any other information?

301 DR. LAKSHMANAN:

I can't read--it says 3/4 inch by half inch, and I think that refers to more the triangular abrasion above it, not to that marking.

302 MR. KELBERG:

And there also appears to be some writing down below where the schematic of the left hand ends. Does that refer at all to that same area?

303 DR. LAKSHMANAN:

No.

304 MR. KELBERG:

So, doctor, if you'll point carefully to the area which possibly refers to this injury.

305 DR. LAKSHMANAN:

Possibly. I'm not sure. This one (indicating).

306 MR. KELBERG:

All right. Let me circle that in red. I'll write out at the side "G-26, 25 inj. no. 10" is it, doctor?

307 DR. LAKSHMANAN:

Yeah. Possible.

308 MR. KELBERG:

And I'll put a big question mark.

309 DR. LAKSHMANAN:

Yeah.

310 MR. KELBERG:

Anything in the way of a description in the protocol?

311 DR. LAKSHMANAN:

It's on page 12, no. 2. All the injuries to the left forearm have been described, including the triangular one which we just discussed, and no specific mention of this particular one, but this paragraph would include all the injuries in the forearm.

312 MR. KELBERG:

Doctor, if you could look to the photograph to the left of G-26--and I can't see the number at the moment.

313 DR. LAKSHMANAN:

G-21.

314 MR. KELBERG:

G-21. Do you see this triangular-shaped injury?

315 DR. LAKSHMANAN:

Yes. Here. You can see it here (indicating).

316 MR. KELBERG:

And that is what kind of injury, doctor?

317 DR. LAKSHMANAN:

That's again a nonspecific blunt force injury which could have been caused by the environment which is present on the Bundy drive.

318 MR. KELBERG:

What kind of blunt force trauma injury is it?

319 DR. LAKSHMANAN:

Again, this could be a branch. You know, as I told you, there are branches which have been cut and there are stalks there; and when you have the forearm rubbing against one of those stalky branches or the stalks of the branch, you could have this kind of abrasion.

320 MR. KELBERG:

It is an abrasion?

321 DR. LAKSHMANAN:

Yes.

322 MR. KELBERG:

All right. And you've already pointed out, apparently it was diagrammed by Dr. Golden?

323 DR. LAKSHMANAN:

Yes.

324 MR. KELBERG:

Is there any description given with the diagram itself?

325 DR. LAKSHMANAN:

Here. Triangular 3/4 inch by half an inch abrasion (indicating).

326 MR. KELBERG:

Doctor, and what number if any do you give to that injury in G-21?

327 DR. LAKSHMANAN:

In G-21, I gave it a no. 2.

328 MR. KELBERG:

All right. Let me circle this area in blue.

329 DR. LAKSHMANAN:

And this measurement also corresponds to the same.

330 MR. KELBERG:

Which measurement, doctor?

331 DR. LAKSHMANAN:

The 3/4 inch by half an inch. He's given the measurement twice on this.

332 MR. KELBERG:

All right. Let me try and include that as well. Does this "Abr" refer to anything, doctor?

333 DR. LAKSHMANAN:

Yes. It's abrasion.

334 MR. KELBERG:

You're referring to that same triangular area?

335 DR. LAKSHMANAN:

Yes.

336 MR. KELBERG:

I'll include that then in the circled area on form 21-I and I'll write at the side "G-21"--and I'm sorry, doctor--injury no. 1? The triangular-shaped injury is which number according to your--

337 DR. LAKSHMANAN:

Injury no. 2 in G-21.

338 MR. KELBERG:

I'm sorry. Injury no. 2. I'll write that in. All right. Let's finish. What other blunt force injuries are included collectively by Dr. Golden in this paragraph item 2 of page 12? If you could go to the photographs and show us.

339 DR. LAKSHMANAN:

He has also addressed this linear abrasion above the triangular abrasion of the left forearm in G-21, and that is also diagrammed here, and he has addressed it in the protocol here as a 3/4 inch in length abrasion (indicating).

340 MR. KELBERG:

What injury number have you arbitrarily assigned that one?

341 DR. LAKSHMANAN:

I assigned that as injury no. 3.

342 MR. KELBERG:

Of G-21?

343 DR. LAKSHMANAN:

Yes.

344 MR. KELBERG:

Let me outline that first on the protocol in blue, and I'll write "G-21 inj. no. 3."

345 DR. LAKSHMANAN:

And I also have--you have to address this 3/4 inch by half an inch triangular abrasion as injury no. 2 of G-21.

346 MR. KELBERG:

All right. I'll do that in red then on the protocol, same page. And that's going to be "G-21 inj. no. 2"; is that correct, doctor?

347 DR. LAKSHMANAN:

Yes.

348 MR. KELBERG:

And then over here where you pointed out--before I circle, doctor, is this the area that refers to that injury no. 3?

349 DR. LAKSHMANAN:

Yes. Yes. This particular abrasion. But my concern is whether the measurement here--it says 3/4 inch by half an inch and again says 3/4 inch by half an inch--whether one of the 3/4 inch applies to this measurement.

350 MR. KELBERG:

Does he describe injury no. 3 then as 3/4 inch by half inch?

351 DR. LAKSHMANAN:

No. He just says 3/4 inch. So I'll just diagram the no. 2 there next to it.

352 MR. KELBERG:

All right. Let me circle this area in red. On the outline of the schematic, I'll write "G-21 inj."--this is no. 3?

353 DR. LAKSHMANAN:

Yes.

354 MR. KELBERG:

Doctor, would you consider these mistakes in the sense that--

355 DR. LAKSHMANAN:

Well, he has described them fairly accurately, the triangular abrasion and the linear abrasion. So they're not mistakes per se.

356 MR. KELBERG:

Is a fairly accurate description a satisfactory description in your judgment, doctor?

357 DR. LAKSHMANAN:

Well, it's a--the triangular abrasion has been described properly and the linear abrasion has been described.

358 MR. KELBERG:

But not completely?

359 DR. LAKSHMANAN:

That's correct. Because you have another abrasion there which has not been addressed, but he says that there are multiple abrasions in the forearm. He has not addressed them individually.

360 MR. KELBERG:

And is his failure to do that considered by you a mistake?

361 DR. LAKSHMANAN:

Yes.

362 MR. KELBERG:

Any significance?

363 DR. LAKSHMANAN:

No.

364 MR. KELBERG:

Same reasons?

365 DR. LAKSHMANAN:

Yes.

366 MR. KELBERG:

What's next in the selective group?

367 DR. LAKSHMANAN:

We have a smaller abrasion just below the blue card here (indicating).

368 MR. KELBERG:

On G-21?

369 DR. LAKSHMANAN:

Yes. And you can also see it on G-26 here (indicating).

370 MR. KELBERG:

At the top of that photograph?

371 DR. LAKSHMANAN:

Yes.

372 MR. KELBERG:

Have you given it an arbitrary number?

373 DR. LAKSHMANAN:

No. 1.

374 MR. KELBERG:

Of which photograph?

375 DR. LAKSHMANAN:

Of G-21.

376 MR. KELBERG:

Of G-21?

377 DR. LAKSHMANAN:

Yes.

378 MR. KELBERG:

All right. Do you see it diagrammed?

379 DR. LAKSHMANAN:

Well, this is the same area which we had a question mark whether it was injury no. 10 of G-26. It could also represent injury no. 1 of G-21 because there's only one marking there for both those injuries.

380 MR. KELBERG:

All right. Let me then add under the description previously given on the diagram board the word "Or G-21 inj. no. 1" with a question mark.

381 DR. LAKSHMANAN:

And you can see both of them in context better in G-26.

382 MR. KELBERG:

Is their relationship as shown in that photograph, G-26, of significance to you in forming any opinion as to how they were incurred?

383 DR. LAKSHMANAN:

No. They're nonspecific blunt force injury. I can't make any inference on that.

384 MR. KELBERG:

Anything further with respect to this collective group that's in this paragraph item 2 of page 12 of the protocol?

385 DR. LAKSHMANAN:

No.

386 MR. KELBERG:

So in order to complete this item, let me circle the no. 2 and indicate collectively which injuries, doctor?

387 DR. LAKSHMANAN:

1, 2 and 3 of G-21.

388 MR. KELBERG:

"G-21 inj. nos. 1, 2 and 3."

389 DR. LAKSHMANAN:

And could be g--injury number 10 of G-20.

390 MR. KELBERG:

And possibly--

391 DR. LAKSHMANAN:

Injury 10.

392 MR. KELBERG:

G-26?

393 DR. LAKSHMANAN:

Yes.

394 MR. KELBERG:

"inj. no. 10."

395 DR. LAKSHMANAN:

Yes.

396 MR. KELBERG:

Is that accurate, doctor?

397 DR. LAKSHMANAN:

Yes.

398 MR. KELBERG:

Anything further?

399 DR. LAKSHMANAN:

No.

400 MR. KELBERG:

Are we done with G-26?

401 DR. LAKSHMANAN:

Yes.

402 MR. KELBERG:

Are we done with G-21?

403 DR. LAKSHMANAN:

Yes.

404 MR. KELBERG:

So we are left with G-20 and G-23?

405 DR. LAKSHMANAN:

Yes.

406 MR. KELBERG:

Let's--we talked yesterday briefly about G-20, doctor, and you talked about this interrupted abrasion. Do you recall that?

407 DR. LAKSHMANAN:

Yes. And also, I described the abrasion in detail, the different parts of it.

408 MR. KELBERG:

All right. Is, first of all, that diagrammed in any fashion by Dr. Golden?

409 DR. LAKSHMANAN:

No.

410 MR. KELBERG:

Is it addressed anywhere in the protocol?

411 DR. LAKSHMANAN:

No.

412 MR. KELBERG:

Is it discussed at all in the addendum?

413 DR. LAKSHMANAN:

No.

414 MR. KELBERG:

All mistakes?

415 DR. LAKSHMANAN:

Yes.

416 MR. KELBERG:

Any significance to you?

417 DR. LAKSHMANAN:

No.

418 MR. KELBERG:

Same reasons?

419 DR. LAKSHMANAN:

Yes.

420 MR. KELBERG:

Is there any other injury you identify in G-20?

421 DR. LAKSHMANAN:

There's also a smaller abrasion just above the--in the region of the elbow area, and I've already discussed this complex interrupted abrasion in the left arm and the smaller abrasion above it and--

422 MR. KELBERG:

The interrupted abrasion you talked yesterday about, the clothing getting folded is one basis that you end up with this situation?

423 DR. LAKSHMANAN:

Yes.

424 MR. KELBERG:

Now, what about this abrasion that you describe as being below the photographic card in G-20?

425 DR. LAKSHMANAN:

Yeah, I gave it a number also. It's again a nonspecific abrasion.

426 MR. KELBERG:

Is that diagrammed?

427 DR. LAKSHMANAN:

No.

428 MR. KELBERG:

Is it addressed in the protocol?

429 DR. LAKSHMANAN:

No.

430 MR. KELBERG:

Addressed in the addendum?

431 DR. LAKSHMANAN:

No.

432 MR. KELBERG:

Same answer to the mistakes question?

433 DR. LAKSHMANAN:

Yes.

434 MR. KELBERG:

Including significance or lack of significance?

435 DR. LAKSHMANAN:

Yes.

436 MR. KELBERG:

Any other injury in G-20?

437 DR. LAKSHMANAN:

No.

438 MR. KELBERG:

Just to conform to the wound chart, which is our exhibit 351, of G-20, which is injury no. 1?

439 DR. LAKSHMANAN:

The lowest one is injury no. 1.

440 MR. KELBERG:

What is injury no. 2?

441 DR. LAKSHMANAN:

Injury no. 2 is this--the three portions to the left arm area. Three--an abrasion, just three portions to it, and then injury no. 3 is the top most one.

442 MR. KELBERG:

And the top most one is where, doctor?

443 DR. LAKSHMANAN:

It's right here. You can see it (indicating).

444 MR. KELBERG:

And what is that injury, no. 3?

445 DR. LAKSHMANAN:

That's also an abrasion which is 3/4 inch by 1/8 inch in size.

446 MR. KELBERG:

Is that discussed at all in the protocol?

447 DR. LAKSHMANAN:

No.

448 MR. KELBERG:

Diagrammed anywhere?

449 DR. LAKSHMANAN:

No.

450 MR. KELBERG:

Addressed in the addendum?

451 DR. LAKSHMANAN:

No.

452 MR. KELBERG:

All mistakes?

453 DR. LAKSHMANAN:

Yes.

454 MR. KELBERG:

Same answers?

455 DR. LAKSHMANAN:

Yes.

456 MR. KELBERG:

Any other injuries in G-20?

457 DR. LAKSHMANAN:

No.

458 MR. KELBERG:

Are we done with that photograph?

459 DR. LAKSHMANAN:

Yes, we have.

460 MR. KELBERG:

Let's go to G-23.

461 DR. LAKSHMANAN:

Yes. G-23 shows the left forearm and shows the inner aspect of the left forearm and also shows the left nipple area. So I have described two injuries. The other injuries seen in this photograph have already been addressed. You have the abrasion behind the left distal forearm, which was juror no. 10 of G-26. We have the smaller abrasion here, which is injury no. 1 I think or--yeah--injury no. 1 of G-21. Yeah. Injury no. 1 of G-21. So barring that, we have an abrasion of the ulnar aspect of the left wrist and you have this abrasion here, the left nipple (indicating).

462 MR. KELBERG:

Doctor, I want to be clear in my own mind. You're saying that that is the nipple of the left breast?

463 DR. LAKSHMANAN:

Of the right breast.

464 MR. KELBERG:

All right. So that's the right breast?

465 DR. LAKSHMANAN:

Yes. But the abrasion is in the left forearm wrist area.

466 MR. KELBERG:

And injury no. 1 for G-23 is that area of the left wrist?

467 DR. LAKSHMANAN:

Yes.

468 MR. KELBERG:

Is that described at all in the protocol?

469 DR. LAKSHMANAN:

Yes, it is.

470 MR. KELBERG:

Where?

471 DR. LAKSHMANAN:

Page 13, no. 5 (indicating).

472 MR. KELBERG:

Is that an accurate description of what you see in photograph G-23?

473 DR. LAKSHMANAN:

No, it is not.

474 MR. KELBERG:

In what way is it inaccurate?

475 DR. LAKSHMANAN:

He described it as two bruises in his protocol description, but it's not a bruise. It's more--and he says it's not abraded. You can clearly see it's an abraded injury with a peeling of the skin.

476 MR. KELBERG:

How can you see that it is clearly abraded and Dr. Golden on the other hand describes it as fresh bruises?

477 DR. LAKSHMANAN:

I can only say what I see here. This is peeling of the skin, which is a flap of skin like any other abrasion like you saw in the little finger here where the skin flap has been peeled off. And you can see the peeling of the skin right here (indicating), and the injury itself is an abrasion injury.

478 MR. KELBERG:

Doctor, would you say that normally it is better to see the actual wound on the body than to review it photographically?

479 DR. LAKSHMANAN:

That is correct.

480 MR. SHAPIRO:

Objection to the form of the question, "Normally."

481 THE COURT:

Sustained. Rephrase the question.

482 MR. KELBERG:

Doctor, in your experience, do you find that a review of injuries on the body yields a more accurate identification than one drawn from photographic identification?

483 DR. LAKSHMANAN:

Looking at the body definitely helps because you have a 3-dimensional look at the injury. And also, you can make incisions to see the depth of the bruising and other--the ability to do other examinations to better define the injury. But in a photograph, you can clearly interpret what the injury appears to be, that is an abrasion or contusion, without difficulty, but you may not be able to tell how deep the bruise is because you can't cut--it's only a 2-dimensional view. It's not a 3-dimensional view and you don't have the additional ability to study the injury in more detail.

484 MR. KELBERG:

And, doctor, I believe you--

485 MR. SHAPIRO:

Objection. Motion to strike. Nonresponsive.

486 THE COURT:

Overruled.

487 MR. KELBERG:

Doctor, I believe you testified several days ago that you routinely review cases performed by other medical examiners in forming independent opinions to testify where those individuals, for example, have left your office or on vacation; is that correct?

488 DR. LAKSHMANAN:

Yes.

489 MR. KELBERG:

And that's the same process also available for Dr. Wolf or Dr. Baden; that is, they weren't there to examine the bodies either; is that correct?

490 MR. SHAPIRO:

Objection. Calls for speculation.

491 THE COURT:

I think we've already asked this question before.

492 MR. KELBERG:

All right.

493 MR. KELBERG:

Doctor, is this diagrammed, this injury no. 1 diagrammed?

494 DR. LAKSHMANAN:

Yes, it is.

495 MR. KELBERG:

Where is it diagrammed?

496 DR. LAKSHMANAN:

23-I right here (indicating).

497 MR. KELBERG:

Where you pointed appears to have a lot of blackened area.

498 DR. LAKSHMANAN:

Yes.

499 MR. KELBERG:

What leads you to believe that there is an entry there that concerns injury no. 1 of G-23?

500 DR. LAKSHMANAN:

It's--it's two discolored areas on the--I mean two markings on the diagram on the same area where the injury is present, and there is some notations here which also have been darkened, but the measurements here have been dictated here in the--in the body of the autopsy report (indicating).

501 MR. KELBERG:

And when you say "The measurements here," you're referring to where?

502 DR. LAKSHMANAN:

You can see this to be 3/8 inch by 3/8 inch and then half an inch by half an inch.

503 MR. KELBERG:

Even though it's darkened?

504 DR. LAKSHMANAN:

Yes.

505 MR. KELBERG:

And you see that same description provided in this page 13, item 5 entry?

506 DR. LAKSHMANAN:

Yes.

507 MR. KELBERG:

From just looking at the diagram, doctor, and your experience in the office and its customs and practices and those of Dr. Golden, can you offer any explanation as to why this area is darkened?

508 DR. LAKSHMANAN:

Well, I--I--one explanation would be that he diagrammed the injury and then he maybe went back and didn't want it mentioned or didn't think it was the right area, then he went back and thought it was the same area. I just have to give my feeling on what happened. I can't tell really what happened.

509 MR. KELBERG:

All right.

510 DR. LAKSHMANAN:

But the point is, it is as it is on the diagram and the description is as it is on the protocol.

511 MR. KELBERG:

Doctor, is it accurate if I circle this entire area? And I don't know. Is this area to refer in your opinion to that injury?

512 DR. LAKSHMANAN:

It would reflect the same area because it says "Skin" and it says "Dermis" there.

513 MR. KELBERG:

And is that in your opinion something that is in consideration in describing that injury of no. 1 of G-23?

514 DR. LAKSHMANAN:

Yes.

515 MR. KELBERG:

Let me circle this information in red, the lower left quadrant, and I'll write "G-23 inj. no. 1," and I'll write or I'll outline on the protocol of this item no. 5 and write "G-23 inj. no. 1" and I'll write-- doctor, in your opinion, this is an--this injury is an abrasion, not a contusion?

516 DR. LAKSHMANAN:

Well, it's an abrasion as far as the skin surface goes, and it looks like an abrasion and not an abrasion contusion.

517 MR. KELBERG:

All right. And I'll write "Per Dr. L., abrasion, not contusion." Is that accurate, doctor?

518 DR. LAKSHMANAN:

Yes.

519 MR. KELBERG:

Anything further about injury no. 1?

520 DR. LAKSHMANAN:

No.

521 MR. KELBERG:

Is there any other injury of G-23 which you identify from that photograph that we have not discussed?

522 DR. LAKSHMANAN:

The--to the right nipple, you have an abrasion contusion here (indicating).

523 MR. KELBERG:

Doctor, is that discussed in the protocol?

524 DR. LAKSHMANAN:

No.

525 MR. KELBERG:

Diagrammed?

526 DR. LAKSHMANAN:

No.

527 MR. KELBERG:

Addressed in the addendum?

528 DR. LAKSHMANAN:

No.

529 MR. KELBERG:

Do you have an opinion as to the circumstance under which that abrasion contusion was received?

530 DR. LAKSHMANAN:

Again, nonspecific blunt force injury to the right nipple area.

531 MR. KELBERG:

And would your answers about that be the same as they have been concerning all other contusion abrasions seen in the hand photographs?

532 DR. LAKSHMANAN:

Yes.

533 MR. KELBERG:

The mistakes--I assume they are mistakes--did not address it, diagram it or address it in the addendum; is that correct?

534 DR. LAKSHMANAN:

Yes.

535 MR. KELBERG:

Of any significance individually or collectively?

536 DR. LAKSHMANAN:

No.

537 MR. KELBERG:

Anything else about G-23?

538 DR. LAKSHMANAN:

No.

539 MR. KELBERG:

Are we done with this photograph board?

540 DR. LAKSHMANAN:

Yes.

541 MR. KELBERG:

Your Honor, I have another board of photographs. May they be marked as exhibit 362?

542 THE COURT:

People's 362.

543 (Peo's 362 for id = board of photographs)
544 (Brief pause.)
545 MR. KELBERG:

And this one is entitled "Sharp force injuries to left flank, left thigh and right chest of Mr. Goldman, blunt force trauma and lividity."

546 MR. KELBERG:

Again, doctor, with the Court's permission, if you'll step down--I'm sorry. Mr. Lynch points something out to me and I do want to cover. We left out in our earlier discussion photograph G-55 and the facial area. And, G-55, doctor, is--

547 DR. LAKSHMANAN:

Yes.

548 MR. KELBERG:

--the photograph in the lower area second from the right border?

549 DR. LAKSHMANAN:

Yes.

550 MR. KELBERG:

How many injuries have you identified to the right side of Mr. Goldman's face that we have not discussed already?

551 DR. LAKSHMANAN:

I have five areas of injury which has not been discussed so far.

552 MR. KELBERG:

Would you just take us through slowly in general terms these areas?

553 DR. LAKSHMANAN:

Yeah. You have two types of injury to the right side of the face. You have blunt force injuries and you have sharp force injuries. The blunt force injuries are represented here as scrapes. I'll go over the numbering after I've given my initial description. You have a linear abrasion here, you have a curved abrasion there. You have an area of confluent abrasions in the right check. The linear abrasion and the curved abrasion are to the right forehead, right temporal area. Then there are also abrasions present around the right eye. So these are all the blunt force injuries (indicating).

554 MR. KELBERG:

Doctor, what did you mean by "Confluent abrasions"?

555 DR. LAKSHMANAN:

"Confluent" means they are--there are linear abrasions which are merging with each other in this area of the cheek (indicating).

556 MR. KELBERG:

All right.

557 DR. LAKSHMANAN:

And then in addition, overlying some of these abrasions in the right cheek area, you have evidence of five sharp force injuries, cuts. You have one, two, three, four and five cuts to the surface of the skin which are sharp force injuries, and four of them seem to overlie the abrasion injury to the cheek, which would indicate that these abrasion injuries occurred before these sharp force injuries to the right cheek area. You also have this--a fifth sharp force injury which is not in the area of the abrasion injury wherein you cannot opine whether it happened before or after. So that roughly describes all the injuries you see in the rights of the face. As I have done with the other injuries, I have numbered them for my convenience, and we will go over them if you want to.

558 MR. KELBERG:

In just a moment. I want to ask just a couple of follow-up questions. The five sharp force injuries that you've described as cuts, four of which you identify as appearing to overlie the area of the abrasions; is that correct?

559 DR. LAKSHMANAN:

Yes.

560 MR. KELBERG:

In your opinion, what would be a source or sources for those cuts?

561 DR. LAKSHMANAN:

A knife.

562 MR. KELBERG:

And from the nature of your observation of those wounds, do you have an opinion as to whether they are all consistent with a single-edged knife with a maximum blade length of approximately 6 inches tapering at the end as you've described?

563 DR. LAKSHMANAN:

They could have been caused by that.

564 MR. KELBERG:

But from the nature of the form of each of those cuts on the surface of the face, can you exclude a double-edged knife as a source for each of them?

565 DR. LAKSHMANAN:

I can not.

566 MR. KELBERG:

And, doctor, hypothetically, is--well, let me ask a couple of preliminary questions. Then I'll ask a hypothetical. From your examination of that area, do you have an opinion as to whether one or more of those five sharp force injuries was received before death?

567 DR. LAKSHMANAN:

They were all received before death.

568 MR. KELBERG:

How are you able to determine that those five sharp force injuries were received before death?

569 DR. LAKSHMANAN:

The description in the report indicates that there is hemorrhage in the tissue.

570 MR. KELBERG:

From your observation of the photographs, are you able to confirm from just that observation that these five sharp force injuries are inflicted before death?

571 DR. LAKSHMANAN:

Their appearance also supports that opinion because they are no different from the other antemortem injuries that are present.

572 MR. KELBERG:

Now, the underlying abrasions to the four of the five sharp force injuries, are they antemortem, that is inflicted before death?

573 DR. LAKSHMANAN:

Yes, they are.

574 MR. KELBERG:

How are you able to make that determination?

575 DR. LAKSHMANAN:

The same reasons. The appearance, the reddish brown color and as I outlined before.

576 MR. KELBERG:

Now, hypothetically, doctor, if Mr. Goldman had been disabled from his--by his assailant's attack, but still had a beating heart and the assailant wanted to check to see whether Mr. Goldman was still alive or not and took this knife, and while Mr. Goldman was in a position where the right side of his face was exposed, poked the knife in the area shown in G-55 to basically detect any reaction from Mr. Goldman, would that set of circumstances be consistent with what you see anatomically in this photograph, G-55?

577 MR. SHAPIRO:

Objection. Improper hypothetical.

578 THE COURT:

Sustained.

579 MR. KELBERG:

Doctor, from the nature of the observations of these five sharp force injuries which you described as all being antemortem and from the underlying abrasions which you've described as being antemortem, is there anything inconsistent from what you see with a hypothetical set of circumstances of the assailant in an effort to ascertain whether Mr. Goldman is alive poking his face five separate times with the end of the knife?

580 MR. SHAPIRO:

Objection. Assumes facts not in evidence.

581 THE COURT:

Sustained.

582 MR. KELBERG:

Your Honor, may I be heard on that, please?

583 THE COURT:

No.

584 MR. KELBERG:

Doctor, medically, is there anything from what you see in the photograph which permits you to understand or offer an opinion as to the sequence from the standpoint of a scenario separate and apart from the cuts overlying the abrasions to describe how those cuts were inflicted?

585 DR. LAKSHMANAN:

Yes. Let's take the one which we have in the right cheek, lower part, which is not in an area of abrasion. It's a superficial puncture type sharp force injury. That could have occurred at the same time since they all have hemorrhage and they all occurred when Mr. Goldman had some blood pressure. It could have occurred at the same time when the threatening cuts took place as a threatening puncture. That particular puncture could have taken place at that time. Now, regarding the other punctures, they're all superficial punctures, and I have no way of knowing exactly why they were done because they really don't have any fatal injury per se from them. They are only superficial punctures, and I would favor that it could be after the fatal injuries were inflicted. It could be--it could have been inflicted to check whether he was still alive or not. That would be one conclusion I would draw also.

586 MR. SHAPIRO:

Motion to strike as calling for speculation without any foundation.

587 THE COURT:

Overruled.

588 MR. KELBERG:

Now, doctor, you started to say arbitrarily how you have numbered these particular injuries. Let's start with your injury no. 1 and go through them, please.

589 DR. LAKSHMANAN:

Injury no. 1 is the linear abrasion which extends from the right forehead down to the right cheek area. Injury no. 2 is the--

590 MR. KELBERG:

Before you move from injury 1 to injury 2, have you measured that injury?

591 DR. LAKSHMANAN:

Yes. I measure it as two and a half inches in length.

592 MR. KELBERG:

Is there any significance in your judgment from its length and appearance on the question of identifying any source or sources for causing it?

593 DR. LAKSHMANAN:

This would again be an abrasion which could be caused by a cut branch or a stalk which could rub against his face in this manner.

594 MR. KELBERG:

Let me--if I can just ask counsel to move slightly aside and get a photograph. And, Mr. Lynch, could you--

595 (Brief pause.)
596 MR. KELBERG:

We're putting up, your Honor, exhibit 359. Have to find a place for Mr. Lynch. I think he just found one.

597 MR. KELBERG:

Doctor, would you point out again on these photographs of the scene at Bundy the kind of environmental source or sources in your opinion which could have caused this injury no. 1, this linear abrasion?

598 DR. LAKSHMANAN:

The face was obviously dragged on a rough surface and other rough surfaces dragged on the facial area. What I'm trying to point out is, if you look at crime scene no. 2 and also crime scene no. 3 and crime scene no. S6, you see areas of where the--there are cuts, stalks of or stumps of a plant, and you have similar cut stumps also available on the branch of the tree here (indicating). And stalks such as that can cause abrasions such as this.

599 MR. KELBERG:

In what manner, doctor?

600 MR. SHAPIRO:

Your Honor, there would be a motion to strike. S photographs were taken in 1995 and there's no foundation that they reflect--

601 THE COURT:

Sustained. The last answer is stricken. The jury is to disregard.

602 MR. KELBERG:

Doctor, I want you to assume that the photographs taken in 1995 fairly and accurately depict the stumps and show these--I want to use the same word you use--the "Shoots" if you will that have grown somewhat, but are basically in the same general condition except for their length as they were on June 12th and 13th of 1994.

603 MR. SHAPIRO:

There would be an objection. No foundation.

604 MR. KELBERG:

There will be a foundation laid by another witness later in this trial, your Honor.

605 THE COURT:

All right. Subject to motion to strike. Proceed.

606 MR. KELBERG:

Now, given that hypothetical set of circumstances, doctor, would you please then explain how these particular kinds of shoots can create an injury like that two plus inch laceration--I'm sorry--abrasion, linear abrasion?

607 DR. LAKSHMANAN:

The same mechanism I mentioned earlier. When you have a cut branch rubbing against your skin surface, it can cause a linear cut abrasion.

608 MR. KELBERG:

Doctor, as long as I'm holding the board, why don't you take us through injury no. 2 if it relates also to this environmental scene.

609 DR. LAKSHMANAN:

Injury no. 2 is the curved abrasion here in the upper part of this linear abrasion here (indicating), in the right forehead area.

610 MR. KELBERG:

In your opinion, is injury no. 2 a distinct injury from injury no. 1?

611 DR. LAKSHMANAN:

Yes. It's separate from injury no. 1 both--though they both meet at a particular area.

612 MR. KELBERG:

And any source or sources from the environmental photographs provided here in 359 which would be a source for that kind of injury, injury no. 2?

613 DR. LAKSHMANAN:

Same type of similar source. A branch or cut stalk of a--correction--a stump of a branch.

614 MR. KELBERG:

Branch of a stump maybe?

615 DR. LAKSHMANAN:

Well, a branch which has had--which is not complete.

616 MR. KELBERG:

The stump, as you use the word "Stump" refers to which of the area?

617 DR. LAKSHMANAN:

No. What I'm saying is, you have--I just gave the stumps on the ground level here on crime scene no. 3. We have similar stumps also on the branch of the tree there.

618 MR. KELBERG:

All right. Now, doctor, how about injury no. 3 if it pertains to a source or sources from the environment as shown in these photos?

619 DR. LAKSHMANAN:

Injury no. 3 is this confluent area of abrasions in the right cheek area.

620 MR. KELBERG:

And in your opinion, are those confluent abrasions consistent with a source or sources from sources seen in the photographs?

621 DR. LAKSHMANAN:

There's a similar source as you can see on the crime scene area. The tree's not well seen here. I see it more in the s photographs.

622 MR. KELBERG:

Well, why don't you point out in the s photographs what it is from the tree that can be a source for that confluent series of abrasions.

623 DR. LAKSHMANAN:

If you look at the other side of the tree and at the base of the tree area here (indicating), you have similar stumps like you see on the ground level here on CS3. And those branches can represent these kinds of abrasions.

624 MR. KELBERG:

Are those confluent abrasions abrasions which are actually individual injuries that just run together or are they from one overall mechanism causing the total appearance?

625 DR. LAKSHMANAN:

I would favor overall mechanism causing a similar appearance because you have several structures there which can cause the abrasion which you see here in the cheek (indicating).

626 MR. KELBERG:

How about injury no. 4?

627 DR. LAKSHMANAN:

Injury no. 4 is the small linear abrasions around the right eye area here (indicating).

628 MR. KELBERG:

Doctor, again, any source or sources environmentally consistent with those?

629 DR. LAKSHMANAN:

The same sources which I just discussed.

630 MR. KELBERG:

And how about then injury no. 5 is it?

631 DR. LAKSHMANAN:

Injury no. 5 is--collectively I described all the five sharp force injuries to the right cheek area and I measured them individually in a counterclockwise direction, but I labeled them as injury no. 5.

632 MR. KELBERG:

Have we omitted any additional injuries to the face?

633 DR. LAKSHMANAN:

No.

634 MR. KELBERG:

And other than going through the protocol diagrams and so forth, have we covered a discussion of the facial injuries of G-55?

635 DR. LAKSHMANAN:

Yes. So basically you have a blunt force and a sharp force injury to the face.

636 MR. KELBERG:

Why don't we use the time we have to try and go through quite quickly the protocol and diagrams if any and the addendum if any concerning those--

637 (Discussion held off the record between the Deputy District Attorneys.)
638 MR. KELBERG:

And we're going to get diagrams to put on the other easel.

639 MR. KELBERG:

Doctor, let's start with injury no. 1, that two plus inch linear abrasion.

640 DR. LAKSHMANAN:

It's in diagram no.--you want to start with the diagram or--

641 MR. KELBERG:

Sure.

642 DR. LAKSHMANAN:

Diagram no. 22-III.

643 MR. KELBERG:

All right. If Mr. Lynch could turn to form 3 of that board. I forget the number of it, but we'll get it.

644 MR. LYNCH:

4G.

645 MR. KELBERG:

4G.

646 DR. LAKSHMANAN:

He diagrams the linear abrasion, injury no. 1, the curved abrasion, the confluent abrasion here (indicating) in the right cheek and the abrasions around the right eye. The only thing is in the diagram for the linear abrasion of the right side of the face and the curved abrasion, he called them cuts, but they are abrasions.

647 MR. KELBERG:

All right. First of all, let's just identify them individually. Which reflects or concerns injury no. 1?

648 DR. LAKSHMANAN:

This particular line going down here (indicating).

649 MR. KELBERG:

And is there a description that goes along with that?

650 DR. LAKSHMANAN:

Basically it says 1-3/4 inch in the protocol. You want to turn to the protocol?

651 MR. KELBERG:

All right. Why don't you tell us which page to turn to.

652 DR. LAKSHMANAN:

Page 6, no. 4. He described them as multiple superficial incised wounds and he described as a 3-inch incised wound in the original protocol the right side of the face extending from the forehead to the cheek, and he also described other superficial wounds half an inch to 1 inch.

653 MR. KELBERG:

Doctor, in your opinion, these are not incised wounds or cuts?

654 DR. LAKSHMANAN:

No.

655 MR. KELBERG:

How are you able to make that determination photographically?

656 DR. LAKSHMANAN:

Just the appearance, you can tell they are abrasions. And also, if you look at under the magnifying glass, you can see the irregularity to the margins, which would be consistent with an abrasion rather than an incised wound.

657 MR. KELBERG:

In your opinion, is it a mistake for Dr. Golden to have opined that these are incised wounds?

658 DR. LAKSHMANAN:

Yes.

659 MR. KELBERG:

Any significance to you in any of the big ticket questions?

660 DR. LAKSHMANAN:

No.

661 MR. KELBERG:

Why not?

662 DR. LAKSHMANAN:

Because of the same reasons I've told before. They don't interfere with my ability to tell you the type of weapon or bleeding effect causing the death, et cetera.

663 MR. KELBERG:

And, doctor, does this paragraph 4 cover more than just injury no. 1 as you've arbitrarily identified them?

664 DR. LAKSHMANAN:

It also reflects the other curve injury next to it, and he calls them "Cuts."

665 MR. KELBERG:

Is the same series of answers going to apply that you just gave to your opinion that these are--this is an abrasion, injury no. 1, rather than an incised wound? Will that apply to the same questions if asked of you on this injury no. 2?

666 DR. LAKSHMANAN:

Yes.

667 MR. KELBERG:

Other than injury 1 and 2, is there any additional injury addressed in this item 4?

668 DR. LAKSHMANAN:

No.

669 MR. KELBERG:

All right. Let me outline this area of the protocol in red, and I'll write, "G-55 inj. nos. 1 and 2, but per Dr. L., abrasions, not cuts." Is that accurate, doctor?

670 DR. LAKSHMANAN:

Yes.

671 MR. KELBERG:

And then if you would, please, again on the diagram form, which is injury 1 and which is injury 2?

672 DR. LAKSHMANAN:

This is 1 and this is 2 (indicating).

673 MR. KELBERG:

All right. And where you indicated 1, I'll do it in blue. Is that correct?

674 DR. LAKSHMANAN:

That says "Length 3 inch, iw," incised wound, "Superficial."

675 MR. KELBERG:

And I'll write, "G-55 inj. no. 1" and I'll write in quotes, "Abrasion." And then if you'd point out injury no. 2, please.

676 DR. LAKSHMANAN:

Injury no. 2 is this curved area here (indicating).

677 MR. KELBERG:

And is there any written description to go along with that?

678 DR. LAKSHMANAN:

It says "Cuts, various, superficial."

679 MR. KELBERG:

Let me circle that area again on the diagram in red this time, and I'll write out at the side "G-55 inj. no. 2" and I'll also write "Abrasion" in quotes. Is it diagrammed anywhere else, doctor?

680 DR. LAKSHMANAN:

Mainly in 23 or mainly in this diagram.

681 MR. KELBERG:

Is there any aspect of the addendum which addresses either injury 1 or injury 2?

682 DR. LAKSHMANAN:

Yes, it does.

683 MR. KELBERG:

Which one or ones?

684 DR. LAKSHMANAN:

Page 2, no. 3.

685 MR. KELBERG:

Why don't we throw it up here in front of the photographs. Page 2, no. 3, doctor?

686 DR. LAKSHMANAN:

Yes. He amended it to indicate that they were all abrasions and he described that the area of abrasion is 4-1/2 inches by 2-1/2 inches and he describes more clearly that one of the abrasions in the right frontal area is curvilinear.

687 MR. KELBERG:

Is that your injury no. 2?

688 DR. LAKSHMANAN:

Yes. And he also describes that the longest abrasion extends from the right temple to the cheek 2-1/2 inches in length, and he also addresses injury no. 4 of the right lower eyelid as a triangular-appearing abrasion.

689 MR. KELBERG:

We'll get to that after lunch, but is it your opinion, doctor, that this paragraph now accurately describes injuries 1 and 2?

690 DR. LAKSHMANAN:

Yes.

691 MR. KELBERG:

And let me outline then that area with the exception of the last sentence which you've indicated, doctor, goes to another injury, G-55, and I'll write over at the side "G-55 inj. nos. 1 and 2." Is that accurate, doctor?

692 DR. LAKSHMANAN:

Yes.

693 MR. KELBERG:

Your Honor, does the Court wish to break?

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
Because if it's just an abrasion, you'll just have a scrape against a rough surface. But if it's an abrasion contusion, it would be an impact of the hand against that surface which has a different connotation as to the mechanism of injury.
Distinguishes abrasion from abrasion-contusion, used to support narrative that Goldman's hand injuries resulted from being forced against rough surfaces during a struggle, not from punching an attacker.
Dr. Lakshmanan Sathyavagiswaran
In your opinion, doctor, is it inconsistent, however, with the source being a blow from Mr. Goldman's clenched fist to the face of the perpetrator? That is correct.
Directly undercuts any defense narrative that Goldman's hand injuries came from him punching OJ Simpson — a potentially exculpatory source of cuts on Simpson's hand.
Dr. Lakshmanan Sathyavagiswaran
A knife.
Blunt, unambiguous answer identifying the source of five sharp force cuts to Goldman's right cheek — the culmination of a long chain of injury documentation.
Dr. Lakshmanan Sathyavagiswaran
Four of them seem to overlie the abrasion injury to the cheek, which would indicate that these abrasion injuries occurred before these sharp force injuries to the right cheek area.
Establishes sequence of events: Goldman was first scraped/thrown against rough surfaces (struggle), then cut with a knife — supporting prosecution's narrative of a prolonged attack.

Evidence (12)

People's G-29
Photograph of palm of Goldman's left hand showing abrasions
discussed
People's G-26
Photograph of back of Goldman's left hand and wrist showing contusions and abrasions
discussed
People's G-25
Smaller photograph of back of Goldman's left hand showing index finger injuries
discussed
People's G-21
Photograph of Goldman's left forearm showing triangular and linear abrasions
discussed
People's G-20
Photograph of Goldman's left arm showing interrupted abrasion complex
discussed
People's G-23
Photograph of Goldman's left forearm (ulnar aspect) and right chest/nipple area
discussed
+ 6 more

Notable Exchanges (3)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg systematically walks through each hand and forearm injury, extracting from Dr. Lakshmanan a repeated finding that Dr. Golden made 'mistakes' by failing to note, diagram, or individually describe injuries — while also repeatedly confirming these mistakes have 'no significance.' The rhythm of 'All mistakes? Yes. Any significance? No. Same reasons? Yes.' becomes a running pattern throughout the examination.
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Extended description of five sharp force cuts to Goldman's right cheek, four of which overlie earlier abrasions, establishing a sequence: blunt force struggle first, then knife cuts. Culminates in the one-word answer 'A knife' for source.
revealing
Robert ShapiroLance A. Ito
Shapiro objects to Kelberg's use of 'normally' in a question about whether physical examination of a body is superior to photographic review. Judge sustains the objection, Kelberg rephrases. Shapiro then moves to strike Dr. Lakshmanan's detailed answer as nonresponsive; Ito overrules.
procedural

Credibility Attacks (1)

⚔ Dr. Irwin Golden
Systematic documentation critique by superior officer
Dr. Lakshmanan (Golden's boss as Chief Medical Examiner) identifies over a dozen specific failures in Golden's original autopsy: injuries not noted in the protocol, not diagrammed, described 'collectively' rather than individually, injuries misidentified as contusions when they are abrasions, and measurements attributed to wrong injuries. The pattern is methodical and relentless, though Dr. Lakshmanan consistently softens the critique by saying none of it has 'significance to the big picture items.'

Witness Demeanor

(The witness complies.) — stepping to board repeatedly throughout examination
(The witness complies.) — circling injury on diagram
Repeatedly told 'Keep your voice up, please, doctor' by Kelberg — witness speaking quietly during detailed technical descriptions

Objections

3 objections (1 sustained, 1 overruled)
Proceeding 6356 • 693 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 13, 1995 📄 Direct examination of Dr. Laks
JUN 13, 1995 KRT DvH TD