📄 Cross-examination of Lakshmanan Sathyavagiswaran (part 1) — Thursday, June 15, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\15\CROSS-EXAMINATION-OF-LAKSHMANA.DOC
TRIAL
▲ Day 96 of 167

Cross-examination of Lakshmanan Sathyavagiswaran (part 1)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Robert Shapiro
Called by: Prosecution • Date: Thursday, June 15, 1995 • Utterances: 714
Robert Shapiro cross-examines Chief Medical Examiner Dr. Lakshmanan on the limitations of his autopsy review, focusing on his reliance on photographs rather than firsthand examination, the absence of microscopic slides, and the numerous errors in Dr. Golden's original autopsy. Shapiro scores significant points by establishing that the defense's own experts (Dr. Baden and Dr. Wolf) were the ones who first prompted discovery of key evidence like the brain contusion, and that no microscopic slides were taken until the defense paid for them.
1 THE COURT:

All right. Dr. Lakshmanan is again on the witness stand undergoing cross-examination by Mr. Shapiro. Mr. Shapiro.

2 (Discussion held off the record between Defense counsel.)
3 MR. SHAPIRO:

Good morning, your Honor.

4 THE COURT:

Good morning, Mr. Shapiro.

5 MR. SHAPIRO:

Good morning, ladies and gentlemen.

CROSS-EXAMINATION (RESUMED) BY MR. SHAPIRO

6 MR. SHAPIRO:

Good morning once again, Dr. Lakshmanan.

7 DR. LAKSHMANAN:

Good morning.

8 MR. SHAPIRO:

Dr. Lakshmanan, it is clear from your testimony that you were not present when these murders took place?

9 DR. LAKSHMANAN:

That is correct.

10 MR. SHAPIRO:

There were no eyewitnesses to these murders?

11 DR. LAKSHMANAN:

That is my understanding.

12 MR. SHAPIRO:

There has been no weapon that has been associated with these murders that has been recovered?

13 DR. LAKSHMANAN:

That is my understanding.

14 MR. SHAPIRO:

So clearly what you are here to give us, when you tell us that in response to hypotheticals from Mr. Kelberg as to how you are trying to reconstruct what might have happened, when you say it could have been or could be, you are speculating?

15 DR. LAKSHMANAN:

I won't say it is speculation based on the hypothetical. I saw with the medical findings, which I have had an opportunity to review, fits the hypothetical, but sometimes the hypotheticals which are given may not fit the medical findings I have and then I will say it is not consistent. So the hypotheticals which you have presented during the direct examination fitted some of the medical findings and that is why I said it is consistent, so it depends on what the hypothetical is.

16 THE COURT:

When you use the term "Could be," is that a term of medical certainty?

17 DR. LAKSHMANAN:

"Could be" is not medical certainty, but it is based on education and the findings that it is a good possibility that is what could have happened.

18 MR. SHAPIRO:

Could be is a possibility?

19 DR. LAKSHMANAN:

That's correct.

20 MR. SHAPIRO:

And when you say something could be, a fair additional response would also be it could have been something else?

21 DR. LAKSHMANAN:

No, because as I mentioned earlier, there are some wounds on both the bodies which are clearly a single-edged knife and I have opined that. There are other wounds on the bodies which could have been a single-edge or a double-edge knife, so there is a little difference. So when the question is posed can all the wounds be by a single-edge knife, I say could have been because there are some wounds on the bodies which could have been single-edge or a double-edge, but there are wounds which could be caused by a single-edge knife from my review of the report.

22 MR. SHAPIRO:

When you talk about the relative positions of the parties--let's get away for a minute from single versus double-edge. I think we have covered that in a great amount of detail. When you give an answer as to the positions of the assailant or assailants and victim and you answered "Could be," you were not giving us any medical certainty, were you?

23 DR. LAKSHMANAN:

No, but the answer was pertaining to that hypothetical. The injuries on the body match the hypothetical.

24 MR. SHAPIRO:

How many different scenarios do you think one could reasonably come up with as to the positions of the bodies at the time of death between Nicole Simpson and her assailant or assailants?

25 DR. LAKSHMANAN:

You mean the--could you repeat the question? I didn't catch the earlier part, I'm sorry.

26 MR. SHAPIRO:

How many different reasonable hypotheticals could you come up with regarding the relative positions of Nicole Brown Simpson and her assailant or assailants?

27 DR. LAKSHMANAN:

For the final wound there is only one possible position. I already opined that. But for the other wounds there could be several other scenarios, but I would rather you give me a scenario and I can opine whether that scenario will fit the injuries I have reviewed.

28 MR. SHAPIRO:

It is your testimony that you are medically certain the position of Nicole Brown Simpson and the position of the assailant at the time of death or assailants?

29 DR. LAKSHMANAN:

Not on all the wounds.

30 MR. SHAPIRO:

On the fatal wound are you medically certain as to the position of Nicole Brown Simpson at the time she received the fatal wounds?

31 MR. KELBERG:

Objection, your Honor. That misstates the testimony as to the number of fatal wounds.

32 THE COURT:

Sustained. You are referring to one specific wound.

33 MR. SHAPIRO:

Yes.

34 MR. SHAPIRO:

As to the last fatal wound are you medically certain as to the position Nicole Brown Simpson was in at the time she received that?

35 DR. LAKSHMANAN:

Yes.

36 MR. SHAPIRO:

There are no other reasonable interpretations that other experts could give?

37 DR. LAKSHMANAN:

I have given you my opinion.

38 MR. SHAPIRO:

Are there other reasonable interpretations other experts that you would hold in high regard could give?

39 DR. LAKSHMANAN:

I would like to listen to them before I offer any opinion whether I agree or disagree, but I have clearly enunciated, I think during the direct examination, what are the reasons why I felt that that particular wound took place in that particular position, and based on the crime scene photographs and the medical findings. So I do not know what other opinions are being offered, and when I hear them I can then make a decision.

40 MR. SHAPIRO:

Are you certain as to whether the assailant--as to whether there was one or more assailants regarding Nicole Brown Simpson?

41 DR. LAKSHMANAN:

I'm not certain.

42 MR. SHAPIRO:

Are you certain as to whether the assailant or assailants were right or left-handed?

43 DR. LAKSHMANAN:

I've already opined on that, I think.

44 MR. SHAPIRO:

I'm asking you are you certain?

45 DR. LAKSHMANAN:

I'm not certain.

46 MR. SHAPIRO:

And again, that is because you weren't there and there are no eyewitnesses to this; isn't that correct?

47 DR. LAKSHMANAN:

That is correct, but what I gave was what are the possibilities and based on the wounds. For example, the last wound on Nicole Brown Simpson had to be right-hand person because the wound travels, in my opinion, from left to right and it has to be done from the back based on the blood flow pattern.

48 MR. SHAPIRO:

Isn't that equally consistent with--how many different ways can a right-handed person hold a knife?

49 DR. LAKSHMANAN:

They could hold it in different ways.

50 MR. SHAPIRO:

How many different ways, in your opinion as an expert, can a right-handed person hold a knife?

51 DR. LAKSHMANAN:

I already showed one way they could hold it. They could be--but for that wound it had to be held in that way.

52 MR. SHAPIRO:

Well, that is not my question, doctor. How many ways, as an expert, can you tell us that a right-handed person can hold the knife?

53 DR. LAKSHMANAN:

Only--only one way he can hold the knife; hold it on the handle part. I mean, how else can you hold it?

54 MR. SHAPIRO:

Your testimony as an expert witness is a right-handed person can only hold the knife in one position?

55 DR. LAKSHMANAN:

Well, I mean, for the wound which was caused.

56 MR. SHAPIRO:

I'm asking you how many--this is a broad question.

57 DR. LAKSHMANAN:

Okay.

58 MR. SHAPIRO:

The question is--and I think it is pretty simple.

59 MR. KELBERG:

Objection, your Honor, to counsel's statement.

60 THE COURT:

Sustained. Rephrase the question.

61 MR. SHAPIRO:

How many ways can a right-handed person hold a knife?

62 DR. LAKSHMANAN:

There is only one way I can see a person could hold the knife if you are going to hold it in the handle part.

63 MR. SHAPIRO:

Only one way?

64 MR. KELBERG:

Excuse me. For the record, the doctor, with his right hand he reached out and appeared to twist his wrist as if holding an object.

65 THE COURT:

Yes.

66 DR. LAKSHMANAN:

If you give me a knife I can show you one of the ways you can do it because this way we can demonstrate it better, because instead of going over a hypothetical in an abstract sense, if you give me a knife, let's go over it and I will tell you how many other ways you can hold it and we can look at it and make a decision on it.

67 MR. SHAPIRO:

Your Honor, I would object to the witness asking questions.

68 THE COURT:

That was an answer. Ask your next question.

69 MR. SHAPIRO:

Can you tell us how many ways a right-handed person can hold a knife as an expert?

70 DR. LAKSHMANAN:

I think the best way is to demonstrate it.

71 MR. SHAPIRO:

So the answer--would you give us an answer or you cannot tell us?

72 DR. LAKSHMANAN:

I can tell you if you have the knife, if you can give it to me, a weapon, and I can show you one of the ways I think it can be held, but to make it useful as an object, you can hold it in certain ways, but in certain other positions it won't be useful as to the function of that weapon.

73 MR. SHAPIRO:

So I understand you, and I don't want to belabor this point, you can't articulate how many ways a right-handed person can hold a knife?

74 DR. LAKSHMANAN:

I think for somebody to understand it will be difficult. Unless you give a demonstration in certain types of situations, that is the best way to do it.

75 MR. SHAPIRO:

Well, let's assume we have reasonably intelligent people listening. Can you verbalize how many ways a right-handed person can hold a knife? If you can't, just say you can't.

76 DR. LAKSHMANAN:

I said I could, but I said it will be better demonstrated.

77 MR. SHAPIRO:

Okay. You can. What is the answer? How many ways can a right-handed person hold a knife?

78 DR. LAKSHMANAN:

You can hold it with the blunt edge facing you, the sharp edge facing you, depending on where you hold the handle. There are only two parts of the knife, the blade and the handle. You are going to hold it in the handle portion, and if it is a single-edge knife, the one sharp edge is going to face you when you hold it in one manner. If you will rotate the knife, the blunt edge is going to face you and hopefully you won't hold it in the blade portion so then it won't serve the function. And if it is a double edge knife, it doesn't matter how you hold it, because both edges are available for causing the function you want it to perform.

79 MR. SHAPIRO:

So your answer is for a single-edge knife you can hold it in two positions?

80 DR. LAKSHMANAN:

Yes.

81 MR. SHAPIRO:

And for a double-edged knife you can hold it in one position?

82 DR. LAKSHMANAN:

Yes.

83 MR. SHAPIRO:

For a right-handed person?

84 DR. LAKSHMANAN:

Yes.

85 MR. SHAPIRO:

Would your answer be the same for left-handed person?

86 DR. LAKSHMANAN:

Yes.

87 MR. SHAPIRO:

Can people hold knives in different angles?

88 DR. LAKSHMANAN:

They could.

89 MR. SHAPIRO:

Would there be an infinite number of angles that somebody could hold a knife?

90 DR. LAKSHMANAN:

Yes.

91 MR. SHAPIRO:

For example, a right-handed person could hold the knife backhanded and make a thrust with the blunt edge out; is that correct?

92 DR. LAKSHMANAN:

Yes.

93 MR. SHAPIRO:

And a right-handed person could hold a knife with the blunt edge out and make a thrusting motion from the right side; is that correct?

94 DR. LAKSHMANAN:

Using the--you are using an example of a single-edged knife, I presume?

95 MR. SHAPIRO:

Yes. Is that correct?

96 DR. LAKSHMANAN:

Where is the blade portion in your hand right now? You made a fist and I want to--

97 MR. SHAPIRO:

I don't want to--let's--

98 THE COURT:

Mrs. Robertson.

99 MR. SHAPIRO:

Mrs. Robertson, do we have a knife here?

100 THE COURT:

Excuse me.

101 (Discussion held off the record between the court and the clerk.)
102 THE COURT:

I will give you something from my evidence collection.

103 MR. SHAPIRO:

Thank you, Judge. I knew you would always have some demonstrative evidence.

104 (Brief pause.)
105 (Discussion held off the record between Defense counsel.)
106 THE COURT:

Mr. Kelberg, did you mark those knives that we had?

107 MR. KELBERG:

I believe that we did, your Honor, and we only needed them that first day, so they were kept downstairs, as I understand it.

108 THE COURT:

All right.

109 MR. KELBERG:

If I could have a moment, I think I can give you an exhibit number.

110 (Brief pause.)
111 MR. KELBERG:

Correct, and 333 and 334.

112 THE COURT:

All right.

113 (Brief pause.)
114 THE COURT:

Mr. Shapiro.

115 MR. SHAPIRO:

Thank you very much, your Honor.

116 (Brief pause.)
117 MR. SHAPIRO:

All right. Doctor, this is a single-edged knife?

118 DR. LAKSHMANAN:

I would have to look at it up close. Yes, it looks like a single-edged knife.

119 MR. SHAPIRO:

So one way a person could hold the knife would be with the forearm back and the blunt edge to the outside, (indicating); is that correct?

120 DR. LAKSHMANAN:

If the thrust is being made in the fashion you are demonstrating and a wound is inflicted, it is a possibility, yes.

121 MR. SHAPIRO:

Then the knife could be turned just the opposite way and a thrust could be made, (indicating)?

122 DR. LAKSHMANAN:

That is also a possibility.

123 MR. SHAPIRO:

That would cause a blunt edge to the inside and a straight edge to the outside?

124 DR. LAKSHMANAN:

Depending on which part of the body it is striking.

125 THE COURT:

Mr. Shapiro, would you just turn because the jurors in the back end were looking to see how you were holding the knife.

126 MR. SHAPIRO:

This was the first time and this was the second time, (indicating).

127 MR. SHAPIRO:

Now, on the wound that you saw on Mr. Goldman's neck, you saw one wound with a blunt end in one direction and one with a blunt end in an opposite direction?

128 DR. LAKSHMANAN:

In Goldman's wound both were incise thrust/stab wounds which I described, so it could have been either way.

129 MR. SHAPIRO:

And the same would be true if somebody held the knife coming from the outside of the right hand, they would thrust it with the blunt edge out, (indicating), or they could thrust it with the blunt edge in?

130 DR. LAKSHMANAN:

That's correct.

131 MR. SHAPIRO:

Could also somebody take a knife and thrust it underhand, (indicating)?

132 DR. LAKSHMANAN:

They could do that also.

133 MR. SHAPIRO:

And there would also be four possibilities of doing it that way, wouldn't there?

134 DR. LAKSHMANAN:

Yes.

135 MR. SHAPIRO:

Turning the knife the other way and also coming backhand straightened, (indicating)?

136 MR. KELBERG:

Excuse me, Mr. Shapiro, you are getting a little too close, if you don't mind.

137 MR. SHAPIRO:

And also somebody could come from the bottom, (indicating); is that correct?

138 DR. LAKSHMANAN:

That is also a possibility.

139 MR. SHAPIRO:

And that could be four additional ways?

140 DR. LAKSHMANAN:

That is correct.

141 MR. SHAPIRO:

And then a right-handed person could also, from behind, come backhand the same way we have described, (indicating); isn't that correct?

142 DR. LAKSHMANAN:

That is also a possibility.

143 MR. SHAPIRO:

And from behind could come forehand, (indicating)?

144 DR. LAKSHMANAN:

That is what I demonstrated in my demonstration, yes.

145 MR. SHAPIRO:

And the same thing for a left-handed person, a left-handed person could come behind, (indicating)?

146 DR. LAKSHMANAN:

Yes.

147 MR. SHAPIRO:

On either side?

148 DR. LAKSHMANAN:

Yes.

149 MR. SHAPIRO:

So you couldn't tell whether it is right or left-handed because there are so many different ways a knife can be held; isn't that correct, sir?

150 DR. LAKSHMANAN:

I thought I opined that, that--

151 MR. SHAPIRO:

And you really can't tell positions of the body because there are so many different--there are an infinite number of ways a knife can be wielded; isn't that correct?

152 DR. LAKSHMANAN:

We have discussed that, yes.

153 MR. SHAPIRO:

You told us yesterday that there was a technician by the name of Mr. Taylor who was present at the autopsy of Mr. Goldman and Miss Brown Simpson?

154 DR. LAKSHMANAN:

Yes.

155 MR. SHAPIRO:

And that Dr. Golden was present?

156 DR. LAKSHMANAN:

Yes.

157 MR. SHAPIRO:

Was anyone else present at the autopsy?

158 DR. LAKSHMANAN:

Yes. He was also I think assisted by Miss Maria Diaz.

159 MR. SHAPIRO:

Maria Diaz?

160 DR. LAKSHMANAN:

Yes.

161 MR. SHAPIRO:

What was her role?

162 DR. LAKSHMANAN:

I mean technicians assist in the autopsy as I told you, help in removal of the organs and assist the doctor in any way they need to assist the doctor, so--and I already told you yesterday I was not there when the autopsy was being performed in its entirety, so I don't know what exact assistance was provided to Dr. Golden by these two technicians. But I do know that Mr. Taylor took the photographs because some of the photographs that were on display on the posterboard was the photographs taken during autopsy, especially the photographs of the scalp wound on the victim.

163 MR. SHAPIRO:

Is Mr. Taylor a competent technician?

164 DR. LAKSHMANAN:

Yes, he is.

165 MR. SHAPIRO:

Is he somebody whose opinion you rely on?

166 DR. LAKSHMANAN:

On Mr. Taylor?

167 MR. SHAPIRO:

Yes.

168 DR. LAKSHMANAN:

I worked with him for many years. He has been there in the department many years, so I know his competence. I don't have to get an opinion from others on that.

169 MR. SHAPIRO:

In your opinion is he honest?

170 DR. LAKSHMANAN:

In my opinion he has always been honest to me and he has done his job when I asked him to do something.

171 MR. SHAPIRO:

Anyone else present, that you are aware of, during the autopsy of both of the decedents or either of the decedents, I should say?

172 DR. LAKSHMANAN:

The autopsy supervisor and the other autopsy technicians will also be present. As I told you, there are six other--there are total six stations in that room, so there could be other doctors and other technicians there in that room at that time, so I can't really tell you who all were there. I already said that yesterday.

173 MR. SHAPIRO:

Are there any notes or logs to reflect who was there?

174 DR. LAKSHMANAN:

I could try and obtain some information for you on that, because who were working that day, but I can't really specifically tell you who was in the autopsy room at that time because, as you know, we do certain number of cases a day and doctors--different doctors could be doing different cases at that time and during the span these cases were done, and technicians could be taking breaks, other technicians could be coming in, so really all I can give you is who was working that day and what cases were done, but I really can't tell you with certainly who was there in the room when these cases were being done, other than what I've already told.

175 MR. SHAPIRO:

Are you saying that you do not keep log records of who is present during an autopsy?

176 DR. LAKSHMANAN:

We do. We usually keep log of the--the--the--the witnesses who attend the autopsy, and there is a log of which technician helped with a particular case, but I thought your question was who all were present in that room, so that is what I was trying to answer. I already told you who helped Dr. Golden on these cases.

177 MR. SHAPIRO:

Let me be more specific. Regarding Nicole Brown Simpson, do you have log records of every person who was present during the time her body was autopsied?

178 DR. LAKSHMANAN:

I have to check the autopsy technician sheet, which they do maintain, who helped whom, because that was one of the procedures which should be in place.

179 MR. SHAPIRO:

My question wasn't who was present. My question was do you have records as to who was present?

180 DR. LAKSHMANAN:

I said I have to go and check into that. I don't know whether they have the records or not on that particular issue.

181 MR. SHAPIRO:

Are you supposed to have records of who was present at an autopsy?

182 DR. LAKSHMANAN:

It is kept that we have the record of the technicians present because the same technician may help in other cases, so we do have records on that.

183 MR. SHAPIRO:

Are you supposed to keep records of everyone who was present at an autopsy?

184 (no audible response.)
185 MR. SHAPIRO:

Yes or no?

186 DR. LAKSHMANAN:

We only record the witnesses present during the autopsy; not the technicians.

187 MR. SHAPIRO:

So you will also have records of the doctor who was present and the witnesses, but other parties you will not have records?

188 DR. LAKSHMANAN:

I didn't say that. I said there are technicians who help in the autopsy. We keep records of the technicians' roster there. And I already told you who the technicians helped in these cases, but I am not sure whether we have information that these are the only technicians who worked only on these cases or did they do other cases. That is what I'm saying.

189 MR. SHAPIRO:

By policy would you kindly tell the ladies and gentlemen of the jury what records should be kept of who viewed the autopsy of Nicole Brown Simpson?

190 DR. LAKSHMANAN:

The persons who view the autopsies would be the doctor, the technicians who assist the case and the witnesses would be the police officers who attend the autopsy, and of course other doctors and technicians who are in the autopsy room will be seeing portions of the autopsy.

191 MR. SHAPIRO:

Those are the records you should have?

192 DR. LAKSHMANAN:

Yes.

193 MR. SHAPIRO:

Do you know if you have such records?

194 DR. LAKSHMANAN:

I said that I have to go and check in my department to see whether we got the log sheet for that and I will be happy to provide that and I'm sure we do.

195 MR. SHAPIRO:

So the question is you expect that you do, but you don't know?

196 DR. LAKSHMANAN:

At this time I don't have it, so I have to say I don't know, but I'm sure it will be there to get you that information.

197 MR. SHAPIRO:

Do you have any information as to whether or not any police officers were present during the autopsy?

198 DR. LAKSHMANAN:

Yes. I already showed that on the form 15. Dr. Golden has clearly recorded Detective Vannatter and Lange to be present during the autopsy on the form 15. It says "Witnesses to the autopsy." We saw that yesterday.

199 MR. SHAPIRO:

Was Detective Fuhrman present during the autopsy?

200 DR. LAKSHMANAN:

As I told you, that is not recorded, so I would have to presume that he was not there.

201 MR. SHAPIRO:

Do you know that for a fact?

202 DR. LAKSHMANAN:

I told you I reviewed the record and I gave you the information from the record. I was not present during the whole autopsy.

203 MR. SHAPIRO:

Is it important to maintain the security of the area where an autopsy is taking place?

204 DR. LAKSHMANAN:

Yes, and the security is provided for the department to have only people who are responsible to be there.

205 MR. SHAPIRO:

Well, isn't it true that construction workers were in the proximity of Mr. Goldman's body?

206 MR. KELBERG:

Your Honor, I will object as vague on the term "Proximity."

207 THE COURT:

Sustained. Rephrase the question.

208 MR. SHAPIRO:

Do you know what "Close to" is?

209 DR. LAKSHMANAN:

Close to means, I believe, to observe a process.

210 MR. SHAPIRO:

Do you know whether or not construction workers were close to Mr. Goldman while he was in the Coroner's office?

211 DR. LAKSHMANAN:

I am not aware of that.

212 MR. SHAPIRO:

You hadn't heard that from anyone?

213 DR. LAKSHMANAN:

No.

214 MR. SHAPIRO:

That wasn't brought up in any of your meetings?

215 DR. LAKSHMANAN:

No.

216 MR. SHAPIRO:

Would you be surprised if that happened?

217 DR. LAKSHMANAN:

Well, it will be new information which I have learned from you.

218 MR. SHAPIRO:

Would you be surprised if that happened?

219 DR. LAKSHMANAN:

Well, I won't be surprised because there are people who visit the department and who--also there may be repairs going on, but I am not aware of it, that a construction worker was there watching the autopsy.

220 MR. SHAPIRO:

Would there be anything wrong with that?

221 DR. LAKSHMANAN:

Well, I don't know whether it is wrong or right, but if he observed it, he observed it because he was doing some construction work, so I can't say it is right or wrong, but I would prefer that was not watched because it is a medical process and only the doctors and the technicians and the detectives who are supposed to be present should be present.

222 MR. SHAPIRO:

Was Mr. Goldman's body, from the time it was brought in, ever left unattended, to your knowledge?

223 DR. LAKSHMANAN:

As I told you, when they are left in the crypt area they are left unattended because the doors are closed and they are unattended at that point, so I do not know what you mean by "Unattended."

224 MR. SHAPIRO:

Left out in view of people other than medical professionals necessary to do the work of the Coroner's office?

225 DR. LAKSHMANAN:

As I told you, I have given you the whole process on last Tuesday, how the bodies went through our office and where they are stored, so it is my understanding that only the people who work in the department and who should have been watching the process, because that is my understanding.

226 MR. SHAPIRO:

What about in the--is there any hallway areas where bodies are left prior to autopsy or after autopsy?

227 DR. LAKSHMANAN:

If at all they are left it is for a short time because you have to move a body to place another body in the autopsy room, so for a short period they will be in the hallways because you have to go through the hallway from the cold crypt area to go to the autopsy room. And I didn't have any photographs of the hallway, but there is a transit period, and also--so to answer your question, there is--the bodies will be in the hallway at some time between the crypt and the autopsy area.

228 MR. SHAPIRO:

Was Mr. Goldman's body ever left in the hallway unattended?

229 DR. LAKSHMANAN:

Not to my knowledge.

230 MR. SHAPIRO:

Would that be a violation of your policy if it was?

231 DR. LAKSHMANAN:

I wouldn't say it is a violation because they would usually try and place the bodies, as soon as the autopsy is done, back in the cold crypt area, but as I told you, I am not aware that was done, so we like to remove the remains from the autopsy area and put them in the cold crypt area as soon as possible, because it is good to preserve the bodies in the cold area as much as possible, depending on the situation that day.

232 MR. SHAPIRO:

Would it be proper for construction workers to be close to Mr. Goldman's body while it was in the hallway?

233 DR. LAKSHMANAN:

I said I am not aware of that, so--

234 MR. SHAPIRO:

I am asking you if it happened, would that be appropriate?

235 DR. LAKSHMANAN:

Well, if he is--if the person was there in the hallway doing some kind of construction work or he had to do some repairs, that is something which we can't avoid, as long as he doesn't touch the body, because the bodies are kept on gurneys.

236 MR. SHAPIRO:

How would you know if he touched the body or not if nobody was watching?

237 DR. LAKSHMANAN:

Well, as I told you, it is beyond my expertise to tell you what exactly happened, but I am telling you that it should not happen and it is my understanding nothing of such nature happened.

238 MR. SHAPIRO:

Now, you have told us that all of your information regarding your testimony comes from photographs; is that correct?

239 MR. KELBERG:

Objection, that does misstate the testimony.

240 THE COURT:

Sustained.

241 MR. SHAPIRO:

Regarding the coloration of the wounds, do you have any firsthand knowledge of the color of the wounds other than from photographs on the two decedents?

242 DR. LAKSHMANAN:

I had--as I told you, I did examine the bodies briefly on the 13th and I saw some of the major wounds, but more--almost most of the other wounds which were in the covered areas of the body was from photographs, yes.

243 MR. SHAPIRO:

On the 13th did you dictate any memoranda as to what you observed?

244 DR. LAKSHMANAN:

No.

245 MR. SHAPIRO:

Did you write any notes as to what you observed?

246 DR. LAKSHMANAN:

No.

247 MR. SHAPIRO:

Did you file any notes as to what you observed?

248 DR. LAKSHMANAN:

No.

249 MR. SHAPIRO:

Did you make any measurements as to what you observed?

250 DR. LAKSHMANAN:

No.

251 MR. SHAPIRO:

You have nothing other than your memory to rely upon to refresh your recollection as to what you observed on the 13th?

252 DR. LAKSHMANAN:

That is correct.

253 MR. SHAPIRO:

And you have told us that as a supervisor you literally review thousands of bodies?

254 DR. LAKSHMANAN:

Over the year, yes.

255 MR. SHAPIRO:

And this has been over a year?

256 DR. LAKSHMANAN:

Over a year means over a stretch of a year we do hundreds and thousands of cases so that is what I meant by an answer, but it is a year since I reviewed this body; that is correct.

257 MR. SHAPIRO:

So you have seen thousands of cases since then?

258 DR. LAKSHMANAN:

That's correct.

259 MR. SHAPIRO:

And with no notes to refresh your memory it would be very hard to describe with a medical degree of certainty, the wounds, the coloration that you observed on the 13th; isn't that correct?

260 DR. LAKSHMANAN:

That is correct.

261 MR. SHAPIRO:

So you are relying entirely on photographs when you form those conclusions?

262 DR. LAKSHMANAN:

That is correct.

263 MR. SHAPIRO:

And on photographs you can't measure depth, can you?

264 DR. LAKSHMANAN:

No, you cannot.

265 MR. SHAPIRO:

Now, is there a term in forensic pathology that takes a wound and puts it together called "Reassessment"? Have you ever heard that term?

266 DR. LAKSHMANAN:

I have not heard the word "Reassessment." I have heard the word "Approximation" when you put the wound together, edges together.

267 MR. SHAPIRO:

Reapproximation?

268 DR. LAKSHMANAN:

That would be a better term I used than what you used.

269 MR. SHAPIRO:

We will go with your term. And when you reapproximate a wound, that is to try to put it back to the position it was in at the time the injury took place; is that correct?

270 DR. LAKSHMANAN:

Yes.

271 MR. SHAPIRO:

And what efforts did you make, in coming to your conclusions, to reapproximate any of the wounds on Nicole Brown Simpson?

272 DR. LAKSHMANAN:

I clearly stated that I had limitations in the photographic process when I gave my testimony on the direct exam. Do you want me to repeat it?

273 MR. SHAPIRO:

Let me just repeat the question.

274 DR. LAKSHMANAN:

Okay.

275 MR. SHAPIRO:

Maybe you didn't understand it. What efforts did you take to reapproximate the wounds on Nicole Brown Simpson before you gave this jury your opinion?

276 DR. LAKSHMANAN:

I already said I reviewed from photographs and I did not reapproximate the wounds. The measurements of Dr. Golden are those taken when the wounds were approximated.

277 MR. SHAPIRO:

Well, when he says they were approximated--

278 DR. LAKSHMANAN:

Yes, he did, and he dictated that he approximated the wound.

279 MR. SHAPIRO:

Did you see him do it?

280 DR. LAKSHMANAN:

I didn't see him do it.

281 MR. SHAPIRO:

You have already told us he has made lots of mistakes?

282 DR. LAKSHMANAN:

I also said that they were not significant mistakes. I told you that they don't have significance to the matter which concerns the case. There were no mistakes on the wounds which caused the major fatal injuries on both the victims.

283 MR. SHAPIRO:

Are you medically certain that there are no other errors that Dr. Golden made in this autopsy?

284 DR. LAKSHMANAN:

I have truthfully discussed all the errors which I believe are there, but as I also opined that the significant injuries which I could evaluate, I could give an opinion on, and I believe that the errors which were addressed had no significance to my final opinion.

285 MR. SHAPIRO:

My question was--

286 DR. LAKSHMANAN:

I am--

287 MR. SHAPIRO:

I'm sorry. Finish.

288 DR. LAKSHMANAN:

I'm finished.

289 MR. SHAPIRO:

Are you medically certain that Dr. Golden made no other errors?

290 DR. LAKSHMANAN:

To my knowledge on the review of the case.

291 MR. SHAPIRO:

All right. I didn't understand that answer. Can you answer yes or no? Are you medically certain that Dr. Golden made no other errors?

292 MR. KELBERG:

Excuse me, your Honor. I will object. It is asked and answered and argumentative.

293 THE COURT:

Overruled.

294 DR. LAKSHMANAN:

Could you repeat the question.

295 MR. SHAPIRO:

Are you medically certain Dr. Golden made no other errors?

296 DR. LAKSHMANAN:

To the extent I reviewed the case, yes. I mean, to the extent I reviewed the case, no, I don't think he made any other errors to the extent I reviewed.

297 MR. SHAPIRO:

You don't know whether he overlooked something that may be important?

298 DR. LAKSHMANAN:

Well, from my review of the photographs there was nothing else which was overlooked on the case from what I already opined.

299 MR. SHAPIRO:

So you are saying that a photograph is a substitute for an in-person autopsy by a medical examiner?

300 DR. LAKSHMANAN:

I didn't say that. I never said that.

301 MR. SHAPIRO:

Is that your opinion?

302 DR. LAKSHMANAN:

No, it is not my opinion. I never said that.

303 MR. SHAPIRO:

That is what you are going on, isn't it?

304 DR. LAKSHMANAN:

Well, under the circumstances, yes.

305 MR. SHAPIRO:

Now, you were shown a picture in a standard text of a wound that was reapproximated; is that correct?

306 DR. LAKSHMANAN:

Yes.

307 MR. SHAPIRO:

And did I understand your testimony that the purpose of that was only to demonstrate for photography, but that wasn't a method that was actually used?

308 DR. LAKSHMANAN:

No. My understanding is that I thought I said that on approximation you will find that the length of the wound will be greater than the wound--wound measurement when it is gaping, and true reflection would be when you approximate the wound and take the measurement, and that is what I restating.

309 MR. SHAPIRO:

Isn't it true that you cannot, as a medical examiner, correctly measure a wound from a photograph unless it has been reapproximated, sir?

310 DR. LAKSHMANAN:

Yes.

311 MR. SHAPIRO:

And that wasn't done in this case, was it?

312 DR. LAKSHMANAN:

Not in my review; that's correct.

KEY QUOTE
313 MR. SHAPIRO:

What about--you put a lot of emphasis in your testimony on the color of the wounds; is that correct?

314 DR. LAKSHMANAN:

Yes.

315 MR. SHAPIRO:

Are there different degrees of color in photographs?

316 DR. LAKSHMANAN:

Yes.

317 MR. SHAPIRO:

And do they vary based on lighting?

318 DR. LAKSHMANAN:

Yes.

319 MR. SHAPIRO:

Do they vary based on the type of equipment that is used?

320 DR. LAKSHMANAN:

Yes.

321 MR. SHAPIRO:

And is there something that forensic pathologists use to measure color called a color slide or a color standard? Is there something like that?

322 DR. LAKSHMANAN:

I am not a photographer and I do not know about this color standards, but the photographs which are developed clearly demonstrate the wounds and I have already given my opinion on it.

323 MR. SHAPIRO:

So you are not aware of anything called a color chart that is taken simultaneously with a photograph to compare colors?

324 DR. LAKSHMANAN:

As I told you, I am not a photographic expert and that is not my area of expertise.

325 MR. SHAPIRO:

But you are testifying from photographs?

326 DR. LAKSHMANAN:

That is correct.

327 MR. SHAPIRO:

And would you agree that colors in photographs may vary due to the printing process of those photographs?

328 DR. LAKSHMANAN:

I have already said that I am not a photographic expert and do not want to go into that.

329 MR. SHAPIRO:

Are you familiar with a process known as microscopic slides?

330 DR. LAKSHMANAN:

Yes.

331 MR. SHAPIRO:

Are microscopic slides something that is commonly used in forensic pathology?

332 DR. LAKSHMANAN:

Yes.

333 MR. SHAPIRO:

And would you agree that you can better age abrasions and contusions from microscopic slides than you can from photographs?

334 DR. LAKSHMANAN:

Yes.

335 MR. SHAPIRO:

What microscopic slides were taken of the skin areas of Nicole Brown Simpson?

336 DR. LAKSHMANAN:

None were taken.

337 MR. SHAPIRO:

What microscopic slides were taken of the skin area of Ronald Goldman?

338 DR. LAKSHMANAN:

None were taken.

339 MR. SHAPIRO:

When was the first time you decided--well, let me ask you this: Did you decide on your own to independently review the findings of Dr. Golden?

340 DR. LAKSHMANAN:

That was when the addendum was prepared I--I looked at the case and I brought his attention about the missed contusion and he brought to my attention some of the injuries which were not described in the original report, and that is the time I discussed that with him, yes.

341 MR. SHAPIRO:

My question was did you decide on your own to reevaluate the work of Dr. Golden?

342 DR. LAKSHMANAN:

No, I did not.

343 MR. SHAPIRO:

Did someone ask you to reevaluate the work of Dr. Golden?

344 DR. LAKSHMANAN:

I did that reevaluation when the District Attorney wanted me to testify, yes.

345 MR. SHAPIRO:

And who asked you to do the reevaluation of Dr. Golden?

346 DR. LAKSHMANAN:

When--actually initially I was considered as a possible witness during the latter part of last year, but this year, when Mr. Kelberg and Mr. Lynch came to see me, I was told that I would be testifying and that is the time I really started an intensive review process of the case.

347 MR. SHAPIRO:

Could you give us a date?

348 DR. LAKSHMANAN:

Yes.

349 MR. SHAPIRO:

Do you have your logs with you today?

350 DR. LAKSHMANAN:

Yes. I think I gave you a copy yesterday.

351 MR. SHAPIRO:

Yes, you do. Do we have that copy? Do you have that?

352 (Discussion held off the record between Defense counsel.)
353 MR. SHAPIRO:

Did you provide it? I don't know whether we left it here or not, but go ahead.

354 MR. SHAPIRO:

Would that refresh your memory, sir?

355 DR. LAKSHMANAN:

Yes. I have to look at the log sheet. Sometime the beginning of February 8;th I had my first conversation with Mr. Kelberg.

356 MR. SHAPIRO:

So let's see if we can answer the question specifically. When was the first time your notes reflect that you were requested to reevaluate the work done by Dr. Golden?

357 DR. LAKSHMANAN:

This entry is February 8th of this year.

358 MR. SHAPIRO:

That was by Mr. Coleberg--Kelberg, I'm sorry?

359 DR. LAKSHMANAN:

Yes.

360 MR. SHAPIRO:

When--was that the first time that you began to focus on reevaluating the work of Dr. Golden?

361 DR. LAKSHMANAN:

No. I already said that we addressed some of the errors in the addendum report in July.

362 MR. SHAPIRO:

All right. Let me--may I just stop you there?

363 MR. KELBERG:

Excuse me, your Honor. I would ask that the witness have an opportunity to fully complete his answer.

364 THE COURT:

Overruled at this point because we are getting two different answers.

365 MR. SHAPIRO:

Thank you.

366 THE COURT:

Proceed.

367 MR. SHAPIRO:

And in July who initiated the reevaluation work?

368 DR. LAKSHMANAN:

Actually it was June 30th when I evaluated the report for the addendum preparation.

369 MR. SHAPIRO:

Who initiated the work on June 30th?

370 DR. LAKSHMANAN:

That was me and Dr. Golden.

371 MR. SHAPIRO:

You did this on your own?

372 DR. LAKSHMANAN:

Yes.

373 MR. SHAPIRO:

And why did you decide to reevaluate the work on June 30th?

374 DR. LAKSHMANAN:

As I told you, there were some errors found. One was the contusion which was there in the storage tissues which was not addressed. And the other issue was Dr. Golden had some injuries which were not addressed which were in the photographs, and he had finished his recent review of the case, and I instructed him that you need to address these issues and that is how the addendum report was prepared.

375 MR. SHAPIRO:

So prior to that you yourself, as the Chief Medical Examiner, did not undertake any reexamination of Dr. Golden's work; is that correct?

376 DR. LAKSHMANAN:

On these cases, yes.

377 MR. SHAPIRO:

And it was only when Dr. Baden and Dr. Wolf, who is not here today, through myself, made an appointment to come review your findings that attention was first focused on errors; isn't that true, sir?

378 DR. LAKSHMANAN:

At least the brain contusion part because the errors which Dr. Golden had in his mind would have been also addressed, because that was not addressed in the meeting with Dr. Baden and Dr. Wolf. The only reason which I felt I should definitely review was the contusion part of that. The rest of the addendum report was Dr. Golden's own initiative which resulted in the addendum report being repaired.

379 MR. SHAPIRO:

Regarding the brain contusion, is it correct, sir, that on June 22nd, at the direction of myself to bring in Dr. Baden and Dr. Wolf to reevaluate the autopsy, for the first time the brain tissue was brought out for reexamination based on their request?

380 DR. LAKSHMANAN:

That is correct.

381 MR. SHAPIRO:

And at that time Dr. Baden was dictating notes to Dr. Wolf, was he not?

382 DR. LAKSHMANAN:

Yes.

383 MR. SHAPIRO:

And you were also taking notes of what Dr. Baden was dictating, were you not?

384 DR. LAKSHMANAN:

I was taking notes of what Dr. Baden was going and also what I was observing.

385 MR. SHAPIRO:

And you took notes when Dr. Baden observed the injury to the brain, did you not?

386 DR. LAKSHMANAN:

Well, I also observed the injury at the same time, because I was working with him at the same time.

387 MR. SHAPIRO:

Did you take notes of Dr. Baden's findings regarding the brain? Yes or no?

388 DR. LAKSHMANAN:

I took notes of what I observed, but Dr. Baden also observed the same thing and he took his notes. I was taking notes of the meeting to record it for posterity.

389 MR. SHAPIRO:

Did you turn those notes over to the Defense as required by discovery?

390 DR. LAKSHMANAN:

I turned over the typed report which was present which is a final report, yes, and I also turned over the notes to you I think a few days ago.

391 MR. SHAPIRO:

And did those notes indicate they were your findings or Dr. Baden's findings?

392 DR. LAKSHMANAN:

They were my findings and his findings, yes.

393 MR. SHAPIRO:

Actually it was really obvious what the injury was, wasn't it?

394 DR. LAKSHMANAN:

Yes.

395 MR. SHAPIRO:

But it was at Dr. Baden's request that that sample jar be brought out?

396 MR. KELBERG:

Asked and answered, your Honor.

397 THE COURT:

Overruled.

398 DR. LAKSHMANAN:

Yes.

399 MR. SHAPIRO:

Did Dr. Baden and Dr. Wolf ask to be able to take photographs of their findings?

400 DR. LAKSHMANAN:

I don't recall that because we did take photographs of the evidence during the histopathological process. I don't recall them requesting it.

401 MR. SHAPIRO:

Do you recall denying them the right to take photographs saying that they couldn't?

402 DR. LAKSHMANAN:

That I said that as a general rule in our department we don't allow outside people to take photographs. We take the photographs and provide them copies, but I don't recall that they wanted to take photographs during the tissue examination process, but we did take photographs during the other evidence examination process.

403 MR. SHAPIRO:

You know Dr. Baden for a long time, don't you?

404 DR. LAKSHMANAN:

Yes, I do. He takes a lot of photographs. I know that.

405 MR. SHAPIRO:

And you trained under him, didn't you?

406 DR. LAKSHMANAN:

Yes. I trained under him for two years on a part-time basis.

407 MR. SHAPIRO:

Is there any reason why you would not allow him to take photographs in your laboratory?

408 DR. LAKSHMANAN:

We have procedures in our department, and we can't break rules just because I know somebody and I am friendly with them. I have to follow the rules of the department because I establish these rules so that we have control on the photographs being taken in the department.

409 MR. SHAPIRO:

Did Dr. Baden try to talk to you, as a medical examiner, about the findings while you were there?

410 DR. LAKSHMANAN:

No.

411 MR. SHAPIRO:

Didn't you tell him that you were instructed by the District Attorney that you couldn't talk to him?

412 DR. LAKSHMANAN:

I think I told you that also, because I didn't tell you about the District Attorney not asking me to talk to you. I told you that I won't be able to talk to you on the case because the case was in grand jury at the time and Dr. Golden was not present because he was testifying at the grand jury. So that is my understanding of our conversation, if I remember it right.

413 MR. SHAPIRO:

So you were--you did instruct Dr. Golden--I'm sorry--Dr. Baden, that you could not speak with him?

414 DR. LAKSHMANAN:

About the case, yes.

415 MR. SHAPIRO:

Even about medical findings that would commonly be shared by forensic pathologists?

416 DR. LAKSHMANAN:

At that time, yes, because the case was in grand jury.

417 MR. SHAPIRO:

Isn't it true that the only slide that your office made at your own direction was after Dr. Baden asked for the brain tissue to be examined?

418 DR. LAKSHMANAN:

That is correct.

419 MR. SHAPIRO:

And isn't it true that the only other microscopic slides that have been done in this case were done recently at the request and expense of Dr. Baden, Dr. Wolf and myself?

420 DR. LAKSHMANAN:

That is also correct.

421 MR. SHAPIRO:

By the way, how much did you charge us for those slides?

422 DR. LAKSHMANAN:

If I remember right, the department charged you, not me, the County of Los Angeles charged you $1393.60, if I remember right, but I can pull out the invoice and I can verify that number, but that is my recollection of the number, $1395.60, but I can check it.

423 MR. SHAPIRO:

And we were charged for your time?

424 DR. LAKSHMANAN:

No. Basically what has happened is that the county has some fixed rates when tissues and slides--slides are made from tissue processing, and you were charged for 16 slides at the rate of eighty plus dollars per slide and that is what the county charges, yes, and that includes my time also or any doctor's time.

425 MR. SHAPIRO:

How much an hour were you billed for my time?

426 DR. LAKSHMANAN:

You were not billed for my time. You were only billed for the slide cost.

427 MR. SHAPIRO:

Are you sure of that?

428 DR. LAKSHMANAN:

Positive.

429 MR. SHAPIRO:

So if I have a bill for your time, we will get a refund?

KEY QUOTE
430 DR. LAKSHMANAN:

Yes, because the--the amount of money you were charged as the doctor's time is built into it. The county has some procedures.

431 MR. SHAPIRO:

And the $80.00 a slide?

432 DR. LAKSHMANAN:

Eighty plus I said.

433 MR. SHAPIRO:

Eighty plus. All right. Let's say eighty for the sake of this discussion. Would you say that the going rate in forensic laboratories around the country for such a slide is $5.00?

434 MR. KELBERG:

Objection, your Honor, calls for hearsay, lack of foundation.

435 THE COURT:

Overruled.

436 DR. LAKSHMANAN:

I think you are confusing the picture here. Maybe I should explain this a little bit in detail. The cost when you are paying for slide includes the initial phone calls you made. The county takes a lot of things into consideration. My clerical person answering the phone call, our conversations, our being present. And remember, during the process we took extra photographs which we didn't charge you for. We gave you the photographs free. Whatever I think is necessary which needs to be done on the case is given to both parties without any cost. It is something when I don't feel it is necessary and is requested by another party, then the county charges for that request, no. 1. No. 2, if it is just a duplicate of a slide which is being made, it is done at a much lower cost. And with reference to the only slide we made was the brain contusion slide, that we gave the duplicate free, we didn't charge Dr. Baden for it. We didn't charge Dr. Baden or yourself for the initial set of photographs. We didn't charge you for anything. Whatever we gave the Prosecution, we gave you, but what a we did charge was for the extra effort the department made for the additional sections which in my opinion were not adding anything further to the cause and manner of death in this case was charged to you, and I think the charge is what the county sets up based on the clerical--if--the clerical call to the histopathology technician, going and retrieving the jars, his time, because he has to stop what he is doing, bring these jars from storage and then we are to give it to the processor and the processor process slides that come back. All these charges are built in, and then since we generated slides on a case, even though it is requested by another person, we still have to look at the slides, because it is our case, we have to generate a report. I mean, all these costs are built in and then--and that is how those charges come. So it looks--this is similar to what the hospital charges you when get Tylenol from the hospital. They have the built-in cost of running the whole show. It is just not the slide cost. It is not like buying retail. It is the whole process. That is what the auditor does. I just tried to explain my understanding of the process of why the cost should be so much.

437 THE COURT:

Next question.

438 MR. SHAPIRO:

Do you remember the question I asked?

439 DR. LAKSHMANAN:

Yes, I do.

440 MR. SHAPIRO:

What was the question?

441 MR. KELBERG:

Objection, object as argumentative.

442 THE COURT:

Sustained.

443 MR. SHAPIRO:

Didn't I just ask you isn't it the standard cost around the country that the cost is $5.00. Can you answer that yes or no?

444 DR. LAKSHMANAN:

Well, it won't really explain the question the way you phrased it, because it looks--

445 THE COURT:

All right. Thank you. Let's move on.

446 MR. SHAPIRO:

Isn't it true, doctor, the best way to determine the aspiration of blood into the lungs is to examine microscopic slides?

447 DR. LAKSHMANAN:

You can tell from grossly also, but microscopically you will see the aspirated blood, but in gross position you can see aspirated blood very clearly but you will have to see blood in the trachea and the larynx first. It is the initial pathway from where the blood reaches the lungs.

448 MR. SHAPIRO:

Is it your medical opinion that a better way to determine the issue of bleeding into the lungs, or aspiration of blood into the lungs, is by microscopic slide or relying on somebody else's visual observation?

449 MR. KELBERG:

Your Honor, I object as vague. Are we asking aspiration of blood or bleeding.

450 THE COURT:

Sustained.

451 MR. SHAPIRO:

Aspiration of blood.

452 THE COURT:

Do you understand the question?

453 DR. LAKSHMANAN:

Because you sustained it, so I don't know what the exact--

454 THE COURT:

No, he just restated it. Why don't you restate the complete question.

455 MR. SHAPIRO:

Regarding aspiration of blood, would you, as an expert medical examiner, say it would be a better way to make the determination by a microscopic slide or relying on a medical examiner who has made numerous mistakes in an autopsy?

456 DR. LAKSHMANAN:

It depends on the issue you are trying to study. If you think by gross examination the bleeding was acute, which was from a fracture of the skull or whatever the reason for the aspiration was, you don't need to do a microscopic study, but if you feel the aspiration occurred and you need to date the aspiration, then a microscopic study will be useful, but as far as looking at an aspirated blood, it is pretty obvious, if you have done many forensic autopsies, to see aspirated blood in the lungs.

457 MR. SHAPIRO:

Wouldn't it have helped you in this case, in reaching your conclusions regarding the injuries to the neck that caused bleeding in the area of the windpipe, to have microscopic slides?

458 DR. LAKSHMANAN:

Not necessary, because you have the cause of death clearly established and injury is an acute injury.

459 MR. SHAPIRO:

It wouldn't be a better way, in your opinion?

460 DR. LAKSHMANAN:

No.

461 MR. SHAPIRO:

Would you say that a reasonable conclusion in a case involving stabbing is that the more stab wounds you find, the more likely there is that a struggle was put up?

462 DR. LAKSHMANAN:

I wouldn't make that conclusion by the number of stab wounds, because there are other factors involved.

463 MR. SHAPIRO:

You have indicated that not all the blunt wounds on the decedents are in the same direction; is that correct?

464 DR. LAKSHMANAN:

I don't know what you mean by blunt wounds. What direction? Which wound are you referring to? If you could specify your question, maybe I will be able to give an answer better.

465 MR. SHAPIRO:

Are all the wounds that you observed on both of these decedents that have blunt ends to them in the same direction?

466 DR. LAKSHMANAN:

No, they are in different--slightly different directions, depending on which wound you are referring to. The wounds on Goldman, they were in different directions. The--Nicole's wounds, two of them were in the same direction. One of them was in a different direction on the left side of the neck.

467 MR. SHAPIRO:

And that clearly indicates that there was movement between the decedent and the perpetrators, doesn't it?

468 DR. LAKSHMANAN:

Yes. I think I opined that the stabbing process is a dynamic process; it is not a static process. I already explained that.

469 MR. SHAPIRO:

And because it is a dynamic process involving movement, you, nor any other medical examiner, has any ability to accurately reconstruct what took place; isn't that correct?

470 DR. LAKSHMANAN:

Accurately reconstruct it, no.

471 MR. SHAPIRO:

Now, you talked about the reaction of an individual, who in this case was Mr. Goldman, and how he, in your opinion, would react to being attacked, did you not?

472 DR. LAKSHMANAN:

Could you read that part of my testimony and then I can refresh my memory what I exactly said? Because I have been testifying for eight days, so I don't know which part of the testimony you are referring to.

473 MR. SHAPIRO:

Your testimony was so long you have already forgotten it?

474 MR. KELBERG:

Objection, your Honor, as argumentative.

475 THE COURT:

Sustained.

476 MR. SHAPIRO:

Was your testimony so long that you already forgot it?

477 DR. LAKSHMANAN:

Well, there were different scenarios posed, different questions asked, so if you can refresh my memory, I will be happy to look at the statements I made and explain it again, if you wish me to.

478 MR. SHAPIRO:

One of the areas you talked about were injuries to the fist?

479 MR. KELBERG:

I think, your Honor--

480 MR. SHAPIRO:

Do you recall that?

481 MR. KELBERG:

Excuse me. That misstates the testimony of the anatomy.

482 THE COURT:

Sustained. Rephrase the question; hands.

483 MR. SHAPIRO:

Did you testify about injuries to the hands?

484 DR. LAKSHMANAN:

Yes, I did.

485 MR. SHAPIRO:

Did you testify that you had read some literature in that regard?

486 DR. LAKSHMANAN:

Yes, I did.

487 MR. SHAPIRO:

Where was that article published that you read?

488 DR. LAKSHMANAN:

I just read a chapter in a sports injury textbook. It was by Foo and Stone is the textbook, by Foo and Stone on sports injuries. It was a chapter on boxing injuries by timothy ward.

489 MR. SHAPIRO:

And when did you read that?

490 DR. LAKSHMANAN:

The last few months, and--

491 MR. SHAPIRO:

Did anybody call that article to your attention?

492 DR. LAKSHMANAN:

No.

493 MR. SHAPIRO:

You just did research yourself?

494 DR. LAKSHMANAN:

Yes.

495 MR. SHAPIRO:

And that article dealt with injuries to the hand that take place in a fistfight?

496 DR. LAKSHMANAN:

Well, boxing injuries.

497 MR. SHAPIRO:

Boxing with or without gloves?

498 DR. LAKSHMANAN:

That's correct.

499 MR. SHAPIRO:

It dealt with both injuries that occur with gloves and without gloves?

500 DR. LAKSHMANAN:

Yes.

501 MR. SHAPIRO:

And there is something in there that you have relied upon as to what you would expect if one individual struck another individual with a closed fist?

502 DR. LAKSHMANAN:

There was information there as to the injuries they have observed in their research material, but when I opined, my opinion was based on my experience and information I gathered from there, so my experience on seeing blunt force injuries also is this when I gave my opinion.

503 MR. SHAPIRO:

What information did you rely on in that article in coming to your opinion?

504 DR. LAKSHMANAN:

Well, I was just saying what type of fractures one would get in the boxing and those other kind of information I was looking at.

505 MR. SHAPIRO:

What information did you rely on in giving your purpose from reading that?

506 DR. LAKSHMANAN:

The information that was just part of the chapter plus my experience.

507 MR. SHAPIRO:

And what information was that that you relied on as to whether or not the victim or victims in this case struck the assailant or assailants?

508 DR. LAKSHMANAN:

I looked at where the injury patterns would happen with reference to if it is a closed fist, if it is a properly laid blow or a glancing--improperly laid blow on the person, what type of injuries you would get, what type of fractures you would get, just improved my understanding of the injury patterns observed by sports injury orthopedic physicians.

509 MR. SHAPIRO:

Would you relate to the jury that section that you relied upon for that opinion?

510 MR. KELBERG:

Objection as asked and answered.

511 THE COURT:

Overruled.

512 DR. LAKSHMANAN:

Basically the area which I looked at was to see what type of fractures you can get. You can get fractures of the first metacarpal bone in a boxer who wears the gloves but the thumb was not in the glove, and you can get a fracture of the base of the metacarpal bone. You can get fractures of the fifth and fourth metacarpal bone, which is the outer little finger bones, if the blow is not improperly placed. You could get injuries to the ligaments on the back of the metacarpal phalangeal joints depending how the blow was applied, et cetera.

513 MR. SHAPIRO:

So what you are saying is if one person hits another person they could hurt their hand?

514 DR. LAKSHMANAN:

Yes.

515 MR. SHAPIRO:

And you needed to do research to find that out?

516 MR. KELBERG:

Objection, your Honor, as argumentative.

517 THE COURT:

Sustained.

518 MR. SHAPIRO:

How much research did you do to find that out?

519 DR. LAKSHMANAN:

Well, the chapter which just improves my knowledge based on it, but as I already told you, my opinion was based on also our own experience on different blunt force trauma you see in the hand of different individuals.

520 MR. SHAPIRO:

How many bare hand fights have you actually witnessed?

521 DR. LAKSHMANAN:

I have not witnessed bare hand fights, but I have seen people who have died from altercations who have had fights and who have injuries to the face and hand. I have seen many cases.

522 MR. SHAPIRO:

Is there a proper way to throw a punch?

523 DR. LAKSHMANAN:

Well, it is--there is an ideal punch when the whole force delivers its effect on the target and there are blows which may not deliver the entire force on the target.

524 MR. SHAPIRO:

What is the position of the fist in a proper punch?

525 DR. LAKSHMANAN:

Do you want me to demonstrate, your Honor? This would be one way of holding your hand to deliver a punch, (indicating).

526 MR. KELBERG:

For the record, your Honor, with his right hand Dr. Lakshmanan has closed his hand into a fist. His arm is at perhaps a 45-degree upward angle.

527 THE COURT:

Yes.

528 MR. SHAPIRO:

Could you hit somebody with your hand in that position and cause injury to them?

529 DR. LAKSHMANAN:

Well, I have not hit anybody closing my fist, but you could cause definite blunt force injury by hitting somebody hard with this kind of closed fist.

530 MR. SHAPIRO:

Could you cause injury to somebody by hitting them with a closed fist and not cause injury to yourself?

531 DR. LAKSHMANAN:

It is a possibility that you may not get injured, but you could also get bruising of your hand. That is why you do--you can get bruising of the hand, too.

532 MR. SHAPIRO:

So you could get hurt; you could not get hurt?

533 DR. LAKSHMANAN:

That's correct, and I also I think stated that if there were gloves present, there is less chance striking somebody would get hurt and the person who gets hit would get hurt more.

534 MR. SHAPIRO:

Is there something known as a glancing blow?

535 DR. LAKSHMANAN:

Yes, and that would be the one which the blow did not have its full effect on the target, either due to movement of the target being the victim and the--or the reach was not as it was planned to be delivered.

536 MR. SHAPIRO:

So it is possible if someone hits someone improperly that they could only hit with one knuckle or one portion of the hand and not cause injury to other parts of the hand?

537 DR. LAKSHMANAN:

Generally that could happen, theoretically, but if you hit the knuckles you will expect other bruising of the other knuckles in that situation.

538 MR. SHAPIRO:

What if you only hit one knuckle on the chin?

539 DR. LAKSHMANAN:

Well, that is always a possibility, I suppose, but generally, if you look at it in context, you will get injuries to other knuckles, too.

540 MR. SHAPIRO:

Even if only one knuckle came in contact with someone's chin?

541 DR. LAKSHMANAN:

I said it is a possibility.

542 MR. SHAPIRO:

You would expect injuries on other knuckles?

543 DR. LAKSHMANAN:

I said in your theoretical possibility--I mean, your possibility that if only a glancing blow with only one knuckle hitting, then this is a possibility, I suppose, but if you look at it logically, it doesn't make sense that you would only hit one knuckle on somebody, especially in the case of Mr. Goldman, when you have a clear-cut bruise on the middle finger knuckle, it is--it is--it seems unlikely that--that you would not see bruising of the other knuckles, especially when the knuckle which was injured is in the middle of the closed fist.

544 MR. SHAPIRO:

Doesn't the middle knuckle protrude in most people's hands from other knuckles?

545 DR. LAKSHMANAN:

The other knuckles protrude, too. In my hand you can see that both the knuckles protrude.

546 MR. SHAPIRO:

Did Mr. Goldman's index knuckle protrude?

547 DR. LAKSHMANAN:

I didn't close his fist to see that, but just in my experience this is the average appearance of a closed fist, and I think if you take the closed fist of most people, this is the appearance it will have.

548 MR. SHAPIRO:

Have you done any studies on that?

549 DR. LAKSHMANAN:

I have not done studies on that, but I'm just giving you from my experience.

550 MR. SHAPIRO:

What experience is that?

551 DR. LAKSHMANAN:

Experience means my knowledge on this.

552 MR. SHAPIRO:

Where did you obtain this knowledge?

553 DR. LAKSHMANAN:

Practical knowledge. If you close anybody's fist you can see the appearance.

554 MR. SHAPIRO:

So general knowledge that all of us have?

555 DR. LAKSHMANAN:

That's correct.

556 MR. SHAPIRO:

If someone was attacked from behind, would you expect that the victim would try to kick the assailant?

557 DR. LAKSHMANAN:

That would depend what kind of attack was from the behind, so could you expand on it a little better?

558 MR. SHAPIRO:

Well, you did that demonstration. Maybe you can--with Mr. Kelberg you grabbed him with one hand around his chest and you held a ruler to his throat. Remember when you did that?

559 DR. LAKSHMANAN:

Yes.

560 MR. SHAPIRO:

Now, if Mr. Kelberg was fighting for his life, would you expect that he might try to kick you to get away?

561 DR. LAKSHMANAN:

That is a possibility, and I did mention it in my opinion, that the victim could have wrestled himself away from the assailant. And a normal human being is not going to just allow somebody to cut your throat. You are going to try and escape from that life-threatening situation.

562 MR. SHAPIRO:

So the reasonable thing to expect is that there would be a struggle?

563 DR. LAKSHMANAN:

Yes.

564 MR. SHAPIRO:

And that the victim would try to kick?

565 DR. LAKSHMANAN:

That is a possibility.

566 MR. SHAPIRO:

Would try to hit?

567 DR. LAKSHMANAN:

If the victim is being held, yes.

568 MR. SHAPIRO:

Try to hit with closed fist?

569 DR. LAKSHMANAN:

It is a possibility.

570 MR. SHAPIRO:

With an open hand?

571 DR. LAKSHMANAN:

It is a possibility.

572 MR. SHAPIRO:

With elbows?

573 DR. LAKSHMANAN:

It is a possibility.

574 MR. SHAPIRO:

With anything else in the natural instinct to survive the attack; isn't that true?

575 DR. LAKSHMANAN:

That is correct.

576 MR. SHAPIRO:

Have you--now, part of this you say is you go through all these scientific things that you have studies and then one of the criteria is witnesses, to ask people what really happened or to ask about reactions of people. Is that part of your job?

577 DR. LAKSHMANAN:

Well, I don't talk to witnesses, because we just do our autopsies and review the injuries.

578 MR. SHAPIRO:

In forming your opinion, wouldn't you like to know if the victim was physically fit?

579 DR. LAKSHMANAN:

Well, from the appearance of the body, he appeared to be an athletic young man who was not obese. He was a very athletic, handsome young man.

580 MR. SHAPIRO:

Wouldn't you like to know if that is the person who is likely to perhaps just kowtow to an attacker and melt away and not do anything or whether he is the type of person who would in fact try to defend himself and put up a struggle?

581 DR. LAKSHMANAN:

That is a difficult question to answer, because you are going into areas because sometimes you can have a very big person who can be intimidated by fear, and so I don't know what exactly happened, but theoretically physically athletic person could definitely offer resistance. But if there is fear element involved, they could be just intimidated and just freeze and that is also known to occur, so I really don't know what happened, but I do not what injuries happened, and I have given you my opinion on the injuries as to what could have happened.

582 MR. SHAPIRO:

Would it have helped to talk to somebody and ask what the make-up of the victim was and what the victim would likely do?

583 DR. LAKSHMANAN:

I didn't do that.

584 MR. KELBERG:

That is a compound question.

585 THE COURT:

Overruled.

586 MR. SHAPIRO:

What about Nicole Brown Simpson? Was she physically fit?

587 DR. LAKSHMANAN:

She looked like a young physically fit woman, yes.

588 MR. SHAPIRO:

Is there a difference between the way women react to an attack and men?

589 DR. LAKSHMANAN:

Well, I can't say that because nowadays--not nowadays, any human being can react in the same way in a situation of stress. Either they can fight the attacker or they can be in fear and freeze. So I don't think a difference of sex matters. It is a situation in which the person is put into place.

590 MR. SHAPIRO:

Would it be unreasonable to expect that a woman would fight off an attacker?

591 DR. LAKSHMANAN:

Well, I would expect any human being to fight off the attacker if they are not frozen by fear. You are fighting for your life.

592 MR. SHAPIRO:

And in such a fight for your life you would expect the attacker or attackers to have some injuries or evidence of being in some type of struggle, wouldn't you?

593 DR. LAKSHMANAN:

If the victim was able to deliver some blows, but if the attacker quickly incapacitated them, you may not see injuries on the attacker, so it depends on the situation. It is--I am just giving you my understanding of what could happen, but I have already discussed what injuries each one had. And I already discussed what my opinion on both the victims are. It is in evidence and we could go over the transcript if you want.

594 MR. SHAPIRO:

You told us the minimum amount of time the struggle between Ron Goldman and his attacker or attackers was and you said it could be less than a minute?

595 DR. LAKSHMANAN:

Yes, I did say that.

596 MR. SHAPIRO:

What is the maximum amount of time the struggle could have taken place between Ron Goldman and his attacker or attackers?

597 DR. LAKSHMANAN:

I would say within a few minutes. Because of the nature of the injuries and the acute bleeding, I wouldn't expect the attack to be more than a few minutes because you can't really tell how long, but I would favor it within a few minutes the attack took place, but it could have been done very well within a minute.

598 MR. SHAPIRO:

What if the fatal wound were the last wounds struck?

599 DR. LAKSHMANAN:

There were quite a few fatal wounds. He had two wounds to the chest, one wound to the neck which caused bleeding from the jugular vein. He had an aortic wound. The thigh wound was hot fatal, but it was still causing significant bleeding. The only other wounds you are left with is three, four cuts in the--two cuts on the top of the head--I mean of the back of the head and you have blunt force injuries to the hand, so I think the injuries which were inflicted to him were significant injuries, and I think they could have been done very well within a minute, and I would not expect the struggle to have been more than a few minutes based on the injuries he received. So unless there is any other possibility you want to offer, we could discuss it.

600 MR. SHAPIRO:

All right. Well, let's assume Mr. Goldman was a physical--in very good physical shape, that he is 25 years old, that he is six feet tall, that he works out regularly and that he is not taken by surprise, but he sees attackers and he puts up a really valiant struggle. Is that something that could take place?

601 DR. LAKSHMANAN:

Could you explain what you mean by "Valiant struggle." What exactly happened?

602 MR. SHAPIRO:

He fought his attackers real hard?

603 DR. LAKSHMANAN:

In what way?

604 MR. SHAPIRO:

With his legs, with his hands, with his fists, with his body.

605 DR. LAKSHMANAN:

As I already told you, I don't think he fought the attacker in the manner you are portraying because he was trying to avoid the wounds, as I see it. I think Mr. Goldman was mainly ducking, turning, twisting and backing when these injuries took place, as I already mentioned that he was in a closed environment, and in my own feeling he was rapidly incapacitated. He didn't have a chance. The injuries are in the front of the hands, there is no cuts on the back, so my feeling is he was turning, twisting at some point because of the nature of the clothing injuries we have. He was ducking because he has got injuries to the front of the hands as if he was facing the assailant and most likely backing into the bushes with his flailing hands when the attack took place, and that is my opinion from what I can see of the injuries we have discussed it.

606 MR. SHAPIRO:

Your opinion is that a person or persons with a knife came at Mr. Goldman, and rather than trying to cover his head and face or trying to bend over to protect himself, (indicating), or trying to get into some type of defensive stance, he just put his arms out and started hitting a tree and a fence? Is that your testimony, sir?

607 DR. LAKSHMANAN:

Well, the point is he doesn't have any injuries on the back of the hand. In your demonstration you just said, if he did this, (indicating), the man has got wielding cuts in the left side of the neck from--I mean he has got cuts on the left side of the neck in the face from the wielding knife, so from your demonstration he should have a lot of cuts on the back of the hand which he doesn't have--which he doesn't have pathologically. You saw the photographs. I saw the photographs. There are no back--and there is no injuries to the back of the hand.

608 MR. SHAPIRO:

Is it your testimony that he did not try to defend himself but rather threw his arms out and hit a tree and hit the fence? Is that your testimony?

609 DR. LAKSHMANAN:

No. My testimony is that the injuries I see do not support that hypothetical situation. It supports, rather, a situation which I already opined. He backed, he ducked, he turned, he twisted and he didn't have a chance.

610 MR. SHAPIRO:

And you base that solely on viewing photographs?

611 DR. LAKSHMANAN:

Photographs show the injuries and the description of the report is available for my review, and it is an independent review.

612 MR. SHAPIRO:

And are there other experts whose opinion you trust who could give different scenarios?

613 MR. KELBERG:

Objection, your Honor. That calls for speculation.

614 THE COURT:

Sustained.

615 MR. SHAPIRO:

Based on your expertise are there others who would disagree with that opinion?

616 MR. KELBERG:

Objection, your Honor, as calling for hearsay, speculation and irrelevant.

617 THE COURT:

Sustained.

618 MR. SHAPIRO:

You talked about the tip of the knife and that there was no evidence that any tip of a knife was broken off; is that correct?

619 DR. LAKSHMANAN:

Yes.

620 MR. SHAPIRO:

Was a correct examination done to look for a tip of a knife?

621 DR. LAKSHMANAN:

We didn't do x-rays before the autopsy, so--but we did do x-rays after the autopsy, and on the only bony structure which was injured, so that way we did an examination for any foreign body.

622 MR. SHAPIRO:

The x-ray that you did was of what size of the spine?

623 DR. LAKSHMANAN:

The x-ray was of just of the spine specimen removed.

624 MR. SHAPIRO:

What size of the spine specimen as compared to the entire spine?

625 DR. LAKSHMANAN:

It was only three pieces of the vertebra.

626 MR. SHAPIRO:

How large were those three pieces of the vertebra?

627 DR. LAKSHMANAN:

One portion was a portion of the vertebra; the other two were intact.

628 MR. SHAPIRO:

What size were they?

629 DR. LAKSHMANAN:

They were typical size which is a normal size with a couple of inches length of the spine which was removed which was x-rayed; not the entire spine, no.

630 MR. SHAPIRO:

Would you show the jury, just holding your hand, what size of a portion of the vertebra we are talking about?

631 DR. LAKSHMANAN:

We had a length of the spine of this length, approximately, (indicating). Each body is about so much, so you are talking about this length of spine which was examined.

632 THE COURT:

Approximately three or four inches.

633 MR. SHAPIRO:

Is it a medical possibility that if the tip of a knife broke off in that area that it could dislodge itself without a medical examiner finding it?

634 DR. LAKSHMANAN:

Generally, no, because usually when a knife tip breaks, the knife tip is stuck to the bone. In my experience I have had two cases where we have seen this. The tip which is broken is imbedded in the bone, they won't fall off, because what breaks it is the tip gets stuck and then the knife is twisted, the tip breaks and it is imbedded in the bone, at least in my experience in the two cases I have been involved, the knife tip gets struck and you have to virtually take it out of the bone with the help of x-rays. So to answer your question, I don't think it is likely.

635 MR. SHAPIRO:

So based on those two times that you have seen a knife tip in a bone, you would opine that it is not reasonable that a knife tip could become dislodged and go to another part of the body?

636 DR. LAKSHMANAN:

Generally not. That is my feeling on it from my experience, because as I told you, the tip is the one which gets broken--the tip is usually very small. It is not a big chunk which gets broken. And the tip gets stuck this bone, in my experience, but--and I'm going with my experience.

637 MR. SHAPIRO:

Is it possible that the tip of the knife or knives could have been broken in any other portion of the body, other than that small fragment of spine that you saved?

638 DR. LAKSHMANAN:

Generally not. Usually the knives break when they hit bony structures, because when you have a soft tissue structure and you have a sharp instrument, there is no resistance. You usually break an instrument when there is resistance, and the resistance is compounded by the tip getting stuck somewhere. So in my experience and my reading of the subject, it would be most likely if the knife struck a hard bony structure and not a soft tissue structure.

639 MR. SHAPIRO:

Now, to ask the question the way they were asked on direct examination, could someone be cut with a knife, have the tip broken off and have it not lodged in the only small area of the spine that you covered?

640 DR. LAKSHMANAN:

As I told you from my experience, I don't think that is very likely, but unless you have some information which you can provide me which shows that that is happened in other cases.

641 MR. SHAPIRO:

My question isn't isn't it likely. My question is could it happen?

642 DR. LAKSHMANAN:

Theoretically it is possible, but from what I just opined, medically it doesn't seem possible.

643 MR. SHAPIRO:

And wouldn't the best way to determine that be by taking an x-ray?

644 DR. LAKSHMANAN:

Yes.

645 MR. SHAPIRO:

And x-rays were not taken in this case?

646 DR. LAKSHMANAN:

I have already said that.

647 MR. SHAPIRO:

And they were not taken because the x-ray machine was broken?

648 DR. LAKSHMANAN:

I don't have an exact answer for that. I don't think the doctor felt it was necessary to do it at that time, but when I got involved in the case later, I ordered x-rays to be done on the spine, which we have, and most importantly, most importantly, during the examination Dr. Golden saved the only bony injury he observed, which was the spine. He saved it for storage.

649 MR. SHAPIRO:

How much later did you take the x-ray--order the x-ray to be taken?

650 DR. LAKSHMANAN:

I have to refer to the report, but I think it is sometime in September of last year when I ordered it to be done and I asked our radiologist to look at it.

651 MR. SHAPIRO:

What happened during the three or four months which caused you to form the opinion that x-rays taken on the 13th were proper to take?

652 DR. LAKSHMANAN:

I just felt to complete the process to make sure we didn't miss anything. I just wanted to make sure, because the wound patterns didn't suggest the knife was broken, but I felt to complete the process we needed to make sure that we didn't miss anything which may be of importance in the case. And I just completed an investigation. Just like I ordered the c-screen, I ordered this also to complete the procession to make sure we didn't miss anything.

653 MR. SHAPIRO:

Because you felt those were the proper things to do?

654 DR. LAKSHMANAN:

Well, you can put it that way, yes.

655 MR. SHAPIRO:

And if they were proper to do in September, they were certainly proper to do in June, weren't they?

656 DR. LAKSHMANAN:

Yes, but I also said that we saved what was essential. Dr. Golden saved the only major bony injury he observed on both the cases in storage. We had the specimen.

657 MR. SHAPIRO:

But you are relying on somebody's observations who you've already told us makes lots of mistakes?

658 MR. KELBERG:

Excuse me, your Honor. That mistakes the testimony.

659 MR. SHAPIRO:

Makes mistakes?

660 THE COURT:

It is an argumentative question. Rephrase the question.

661 MR. SHAPIRO:

You are relying on the opinion of someone else who you have already told us has made several mistakes in this autopsy; isn't that correct?

662 DR. LAKSHMANAN:

Yes, but I also said they were not significant as to the outcome of the case. There were some mistakes but they were all of the non-lethal injuries.

663 MR. SHAPIRO:

As you testify today here as an expert, would you say that a certified medical examiner should know the difference between an entrance and an exit wound caused by a bullet?

664 DR. LAKSHMANAN:

Yes, but there are difficulties even for the most expended pathologist sometimes to differentiate an entrance and an exit when you have what's called a short exit, but I agree that a pathologist should be able to tell, but sometimes it is difficult--

665 MR. SHAPIRO:

Okay. And--

666 DR. LAKSHMANAN:

--on certain situations.

667 MR. SHAPIRO:

And you told the jury here yesterday that Dr. Golden made such an error?

668 DR. LAKSHMANAN:

I did say that and it is the truth, he did make an error on that case.

669 MR. SHAPIRO:

And you also--would you also opine that a board certified medical examiner should know the difference between a gunshot wound that is fired at a distance and one that is fired at close range?

670 DR. LAKSHMANAN:

Yes, and I opined on that also yesterday.

671 MR. SHAPIRO:

And Dr. Golden you told us made that mistake?

672 DR. LAKSHMANAN:

Yes, he did.

673 MR. SHAPIRO:

And you--do you think an expert board certified medical examiner should be able to tell whether or not a thyroid is present during an autopsy?

674 DR. LAKSHMANAN:

Yes.

675 MR. SHAPIRO:

And you told us that mistake was made by Dr. Golden?

676 DR. LAKSHMANAN:

Yes, but that mistake is something on somebody who is on thyroid, they are--anyway, that is a mistake, yes.

677 MR. SHAPIRO:

And you still rely upon what Dr. Golden did as being correct in forming the basis for your opinions in this case, don't you?

678 DR. LAKSHMANAN:

Yes, I do, and--and the reason is he has done 5000 plus cases. I know him personally as a pathologist and I know he is a capable doctor and I have seen his work on other cases. These are mistakes which have been acknowledged and I have no hesitation why I can't rely on this report.

679 MR. SHAPIRO:

You know about the case where there were two people who were victims with a gunshot wound that we talked about?

680 DR. LAKSHMANAN:

Yes.

681 MR. SHAPIRO:

Yesterday Mr. Kelberg brought that up, that you said addendums were filed in those cases to correct the mistakes?

682 DR. LAKSHMANAN:

One addendum had been filed. When I reviewed the cases the second addendum was filed on the--the addendum on the sex case was filed and I also had to make a correction on the first case at that time.

683 MR. SHAPIRO:

There was an autopsy that took place in 1990?

684 DR. LAKSHMANAN:

That's correct.

685 MR. SHAPIRO:

And a case that was prosecuted as a capital murder case?

686 MR. KELBERG:

Objection, your Honor, and counsel indicated he would--

687 THE COURT:

Sustained.

688 MR. SHAPIRO:

In this case one correction was made in 1993; is that correct?

689 DR. LAKSHMANAN:

I have to look at the papers, but that sounds about right.

690 MR. SHAPIRO:

Was--

691 THE COURT:

I'm sorry, "In this case" you said?

692 MR. SHAPIRO:

In the case that we are talking about.

693 THE COURT:

All right.

694 MR. SHAPIRO:

In the case we are talking about where the errors were made regarding the gunshot wound.

695 DR. LAKSHMANAN:

That sounds about right, but I would like to refresh my memory.

696 MR. SHAPIRO:

Were both errors corrected at about the same time?

697 DR. LAKSHMANAN:

No, the second error--correction. The error on the other case, the close-range gunshot wound, that was done last year in `94. When I found that the addendum had not been done, I directed Dr. Golden to do the addendum. Another error on the change in direction was done probably in `93, I don't recall the date exactly, and so the addendums are the two mistakes were done at two different times, one at my direction, since it had not been done, and one which was done by Dr. Golden himself earlier in 1994. I also directed a change in the addendum on the other case because there was a typographical error on the number. They typed 9679 instead of 9678 and that addendum was made. So to summarize, we did one addendum in--if it is `93 I don't recall the exact date, but in `94 two addendums were issued, one for each case, one for the number change and one do reflect the range of fire.

698 MR. SHAPIRO:

All right. May I just finish on this line of questioning?

699 MR. SHAPIRO:

To get the sequence of events, two people were killed relatively--in the same crime scene in 1990 and autopsies were done by Dr. Golden?

700 DR. LAKSHMANAN:

Yes, sir.

701 MR. SHAPIRO:

In one case he said that it was a--he missed whether or not it was a point blank injury from a distance injury; is that correct?

702 DR. LAKSHMANAN:

Yes, sir.

703 MR. SHAPIRO:

And in the other he made a mistake as to whether it was an entrance or exit wound?

704 DR. LAKSHMANAN:

That is correct.

705 MR. SHAPIRO:

The mistake in one of them was corrected in June of 1993?

706 DR. LAKSHMANAN:

If that is the date. I said I have to refresh my memory.

707 MR. SHAPIRO:

Let me get those for you.

708 MR. SHAPIRO:

And the mistake in the second case was corrected in September of 1994?

709 DR. LAKSHMANAN:

Yes.

710 MR. SHAPIRO:

Were both mistakes discovered at the same time?

711 DR. LAKSHMANAN:

Well, that is my understanding.

712 MR. SHAPIRO:

Shall we take the recess at this time, your Honor?

713 THE COURT:

All right. Ladies and gentlemen, we are going to take our mid-morning break. Please remember all my admonitions to you. We will be in recess for fifteen minutes.

714 (Recess.)

Temperature

tense

Key Quotes (5)

Dr. Lakshmanan Sathyavagiswaran
I had limitations in the photographic process when I gave my testimony on the direct exam.
The Chief Medical Examiner concedes his entire review was based on photographs with known limitations, undermining the precision of his opinions.
Dr. Lakshmanan Sathyavagiswaran
None were taken.
Dr. Lakshmanan confirms no microscopic slides were taken of either victim's wounds — a key failure Shapiro uses to attack the reliability of wound aging and coloration testimony.
Dr. Lakshmanan Sathyavagiswaran
That is correct.
Confirming that the only brain tissue slide and the only other microscopic slides in the entire case were initiated at the defense's request and paid for by the defense ($1,393.60).
Robert Shapiro
So if I have a bill for your time, we will get a refund?
Shapiro catches the doctor in a minor inconsistency about billing, keeping pressure on credibility even on minor points.
Dr. Lakshmanan Sathyavagiswaran
Not in my review; that's correct.
Concedes that wound reapproximation — necessary to accurately measure wounds — was never performed during his review, undermining measurement-based testimony.

Evidence (6)

People's 333 and 334
Demonstration knives used in court to illustrate grip positions and stabbing angles
Retrieved from storage and used by Shapiro to demonstrate multiple knife-holding configurations
Form 15
Autopsy form recording witnesses present — listed Detectives Vannatter and Lange but not Fuhrman
Referenced to establish who was officially recorded as present during autopsy
Informal
Autopsy photographs of Nicole Brown Simpson and Ronald Goldman
Discussed as the primary basis for Dr. Lakshmanan's opinions, with limitations on color accuracy and wound measurement highlighted
Informal
Dr. Lakshmanan's log sheets / meeting notes
Used to pin down dates — February 8 as first Kelberg meeting, June 30 as addendum work, June 22 as Baden/Wolf visit
Informal
16 microscopic slides from wound tissue, charged at $80+ per slide
Established as having been requested and paid for entirely by the defense team
Informal
Brain tissue sample from Nicole Brown Simpson
First examined on June 22 at Dr. Baden's request; contusion discovered at that time

Notable Exchanges (5)

Robert ShapiroDr. Lakshmanan Sathyavagiswaran
Extended knife demonstration where Judge Ito produced knives from court's evidence collection. Shapiro physically demonstrated multiple grip angles — forehand, backhand, underhand, from behind — to show the infinite possibilities, forcing the doctor to concede he cannot determine handedness or body position with certainty.
strategic
Robert ShapiroDr. Lakshmanan Sathyavagiswaran
Shapiro establishes that Dr. Baden and Dr. Wolf — retained by the defense at defense expense — were responsible for surfacing the brain contusion and initiating all microscopic slide work. The prosecution's own chief medical examiner had not independently reviewed the work until asked to testify.
revealing
Robert ShapiroDr. Lakshmanan Sathyavagiswaran
Shapiro presses on whether construction workers may have been near Goldman's body in the hallway. Lakshmanan denies awareness but cannot rule it out, and concedes bodies were sometimes left in hallways unattended during transit.
unsettling
Robert ShapiroDr. Lakshmanan Sathyavagiswaran
Shapiro gets the doctor to admit that after personally examining the bodies on June 13, he made no notes, no measurements, no dictation — and has reviewed thousands of cases since. The doctor concedes his June 13 observations cannot be stated with medical certainty.
damaging
Robert ShapiroDr. Lakshmanan Sathyavagiswaran
Shapiro reveals that Dr. Lakshmanan told Dr. Baden — his own former mentor — that he could not discuss the medical findings with him because the case was before the grand jury, effectively blocking defense expert consultation.
strategic

Light Moments (3)

Robert Shapiro
Judge Ito personally produced a knife from his 'evidence collection' for the demonstration, prompting Shapiro to quip: 'Thank you, Judge. I knew you would always have some demonstrative evidence.'
Dr. Lakshmanan Sathyavagiswaran
The doctor, asked how many ways a right-handed person can hold a knife, responds: 'Only one way he can hold the knife; hold it on the handle part. I mean, how else can you hold it?' — a moment of unintentional comic literalness.
Brian Kelberg
Kelberg interrupts the knife demonstration with 'Excuse me, Mr. Shapiro, you are getting a little too close, if you don't mind' as Shapiro approaches during stabbing motion demonstrations.

Credibility Attacks (5)

⚔ Dr. Lakshmanan Sathyavagiswaran
Bias / reliance on inadequate evidence
Shapiro systematically shows that Lakshmanan's opinions rest entirely on photographs, which cannot measure wound depth, accurately represent color, or substitute for reapproximation — and that he lacks the photography expertise to account for these variables.
⚔ Dr. Lakshmanan Sathyavagiswaran
Omission / lack of independent review
Established that Lakshmanan did not independently review Golden's work until asked to testify; the defense's own experts (Baden, Wolf) triggered the discovery of the brain contusion and were responsible for all microscopic slide work.
⚔ Dr. Lakshmanan Sathyavagiswaran
Prior inconsistent statement / evasion
When Shapiro asked if Dr. Golden made no other errors, Lakshmanan gave several evasive, contradictory answers until the judge overruled Kelberg's objection and forced a direct response.
⚔ Dr. Philip Vannatter / Mark Fuhrman (by implication)
Absence of records
Shapiro highlights that Fuhrman's presence at the autopsy is not recorded, raising the question of unauthorized access, while Lakshmanan can only say the records do not list him — not that he was definitively absent.
⚔ Coroner's office procedures
Institutional criticism
Shapiro surfaces the possibility of construction workers near Goldman's body, no reapproximation of wounds, no microscopic slides taken proactively, and incomplete attendance logs — painting a picture of procedural laxity.

Witness Demeanor

Witness volunteered to fetch a knife to demonstrate rather than answer abstractly, suggesting hands-on communication style over verbal precision
Witness occasionally gave incomplete answers and had to be interrupted or redirected by both counsel and the judge
Witness expressed genuine uncertainty on multiple points while maintaining that core fatal wound findings were sound

Objections

12 objections (4 sustained, 4 overruled)
Proceeding 6387 • 714 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 15, 1995 📄 Cross-examination of Lakshmana
JUN 15, 1995 KRT DvH TD