📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran — Friday, June 2, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\2\DIRECT-EXAMINATION-OF-DR-LAKSH.DOC
TRIAL
▲ Day 87 of 167

Direct examination of Dr. Lakshmanan Sathyavagiswaran

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Friday, June 2, 1995 • Utterances: 657
The People call Dr. Lakshmanan Sathyavagiswaran, the Chief Medical Examiner-Coroner for Los Angeles County, to the stand. This proceeding is almost entirely credential-building — Kelberg walks Lakshmanan through his extensive education, board certifications (six in total), training history, and supervisory role over the Coroner's office. Near the end, Lakshmanan signals what is to come: he confirms that Dr. Irwin Golden, who performed the autopsies on Nicole Brown Simpson and Ron Goldman, made mistakes, and that Lakshmanan has been asked to evaluate their significance.
1 MR. KELBERG:

Thank you. The People call Lakshmanan Sathyavagiswaran to the stand.

Lakshmanan Sathyavagiswaran, called as a witness by the People, was sworn and testified as follows:

2 THE CLERK:

Doctor, will you please raise your right hand. You do solemnly swear that the testimony you may give in the cause now pending before this Court, shall be the truth, the whole truth and nothing but the truth, so help you God?

3 DR. LAKSHMANAN:

Yes.

4 THE CLERK:

Please have a seat in the witness stand and state and spell your first and last names for the record.

5 DR. LAKSHMANAN:

My name is Dr. Lakshmanan Sathyavagiswaran. The first name goes as follows, L-A-K-S-H-M-A-N-A-N, and the last name is S-A-T as in Thomas, H-Y-A-V-A-G-I-S-W-A-R-A-N.

6 THE CLERK:

Thank you.

DIRECT EXAMINATION BY MR. KELBERG

7 MR. KELBERG:

Doctor, are you kind enough to allow those of us from both Prosecution and Defense and the Court and even private lawyers to refer to you by your first name in your professional dealings with us?

8 DR. LAKSHMANAN:

Yes.

9 MR. KELBERG:

And so if we call you Dr. Lakshmanan, you will not be offended, will you?

10 DR. LAKSHMANAN:

No, I will not.

11 MR. KELBERG:

And a lot of us will be a lot happier for allowing us to do that. Dr. Lakshmanan, are you a medical doctor licensed to practice medicine in the State of California?

12 DR. LAKSHMANAN:

Yes, I am.

13 MR. KELBERG:

How long have you been so licensed?

14 DR. LAKSHMANAN:

I've been licensed in the State of California since 1976.

15 MR. KELBERG:

Do you specialize in any particular area of medicine?

16 DR. LAKSHMANAN:

Yes. I am board certified in six specialties in the field of medicine, all American board certifications.

17 MR. KELBERG:

By whom if anyone are you presently employed?

18 DR. LAKSHMANAN:

I'm employed by the County of Los Angeles.

19 MR. KELBERG:

In what position?

20 DR. LAKSHMANAN:

I'm the Chief Medical Examiner-Coroner for the County of Los Angeles.

21 MR. KELBERG:

What does that position mean?

22 DR. LAKSHMANAN:

Basically, I'm the head doctor in the Coroner's office and also carry out the Coroner functions for the County of Los Angeles.

23 MR. KELBERG:

Before we get into a discussion of your specialties and so forth, your Honor, I have what appears to be a 9-page curriculum vitae of Dr. Lakshmanan. May this be marked--I'm afraid I am not aware of our latest markings.

24 THE COURT:

275.

25 MR. KELBERG:

Thank you, your Honor.

26 THE COURT:

All right. People's exhibit 295.

27 (Peo's 295 for id = CV)
28 MR. KELBERG:

And I'm writing 295 on page 1. May I approach the witness, your Honor?

29 THE COURT:

You may. And, Mr. Shapiro, you have a copy of that?

30 MR. SHAPIRO:

Yes, I do. Thank you, your Honor.

31 THE COURT:

All right.

32 MR. KELBERG:

Dr. Lakshmanan, showing you exhibit 295, are you familiar with that document?

33 DR. LAKSHMANAN:

Yes.

34 MR. KELBERG:

What is that document?

35 DR. LAKSHMANAN:

It is a curriculum vitae of my qualifications and experience.

36 MR. KELBERG:

Is that up-to-date as to your education, experience, training that allows you to practice in the field of medicine?

37 DR. LAKSHMANAN:

Yes.

38 MR. KELBERG:

Doctor, beginning with medical school, would you take us through your education, your experience and your training to today's time?

39 DR. LAKSHMANAN:

Yes. I graduated from Madras University, India, from Stanley Medical College in 1971. I did a year of internship in Madras Stanley Medical College, and I came to the United States in 1972. I did a year of straight medical internship at Brooklyn Jewish Hospital, which I completed in 1973, and then proceeded to do a full year training in anatomic and clinical pathology at St. Luke's Hospital of Columbia University, the last six months being as Chief Resident. During this time between 1973 and 1977, I also did some part-time work at the office of the Chief Medical Examiner in New York City for about two years.

40 MR. KELBERG:

Doctor, let me interrupt you if I might for some clarification. First of all, that period you were saying spending some time at the medical examiner's office in New York, did you become acquainted with a Dr. Michael Badin at that time?

41 DR. LAKSHMANAN:

Yes, I did.

42 MR. KELBERG:

Is Dr. Badin here in the courtroom seated behind counsel, I think behind Mr. Kardashian actually?

43 DR. LAKSHMANAN:

Yes. Yes.

44 MR. KELBERG:

And what position did Dr. Badin hold at the time you spent some time at the medical examiner's office in New York?

45 DR. LAKSHMANAN:

He was a Deputy Chief Medical Examiner of New York City.

46 MR. KELBERG:

Who was the Chief Medical Examiner at the time?

47 DR. LAKSHMANAN:

At that time, it was Dr. Vincent d'Mayo.

48 MR. KELBERG:

Now, doctor--

49 DR. LAKSHMANAN:

And followed by Dr. Gross after that.

50 MR. KELBERG:

Dr. Gross?

51 DR. LAKSHMANAN:

Yes, and Dr. Michael Badin.

52 MR. KELBERG:

Did you, as a result of having gone to medical school outside of the United States, have to take some type of examination in order to pursue an internship in the United States?

53 DR. LAKSHMANAN:

Yes. The first step towards that is to pass an examination conducted by the educational council for foreign medical graduates, which I did in 1971, February. Having passed that examination, it makes one eligible to take a graduate study in the United States, and that is how I joined as an intern at Brooklyn Jewish Hospital in 1972. But that does not give you a license to practice. To practice, you need to take the federation licensing examination, which is a three-day examination, which has the same standards as the national board of medical examiners, and I took that exam in 1974. And for that, you need to have completed an internship. That was the New York state law at that time. And I took the FLEX examination in December 1974 and I became licensed in the State of New York as a physician in 1975, March, during my residency training in pathology at St. Luke's Hospital.

54 MR. KELBERG:

Doctor, first of all, what is an internship?

55 DR. LAKSHMANAN:

An internship is the first year of graduate training in any particular field. And I did a straight medical internship, which indicates that I did a full 12 months of internal medicine training at Brooklyn Jewish Hospital. This is in contrast to a rotating internship where you take several fields in medicine and specialize as your first year of training, which I did in India. I did a rotating internship in India, but I did a straight medical internship in the United States.

56 MR. KELBERG:

What is the residency that you were talking about, residency program?

57 DR. LAKSHMANAN:

Residency program is more at one's state of training, and you pick a particular field. After medical school, everybody has to do an internship to get a license. And as I mentioned earlier, that's how I was eligible to take the licensing examination. Later, you decide whether you want to be a surgeon, an internist or obstetrician and then you pick a particular field, and I picked the field of pathology at that time. And as you will see later, that I did complete my internal medicine training too. And the pathology training was at St. Luke's Hospital.

58 MR. KELBERG:

Doctor, what is pathology?

59 DR. LAKSHMANAN:

Pathology is the study of laboratory science to diagnose disease. And to put it in simpler terms, there are several fields in pathology. The field of pathology which most people know about is surgical pathology. He's the physician, when a surgeon removes a tumor, he reads the biopsy and tells you whether it's cancer or not cancer. So that is surgical pathology. I did training both in surgical pathology and clinical pathology. And clinical pathology is the field in pathology which deals with different laboratories, your medical microbiology laboratory, your hematology laboratory--"Hematology" means blood counts, doing the blood typing, et cetera--and there are several areas in clinical pathology, and that is a clinical pathologist.

60 MR. KELBERG:

Is the term "Anatomical pathology" a synonym for what you describe as surgical pathology?

61 DR. LAKSHMANAN:

Yes.

62 MR. KELBERG:

Now, doctor, in that residency that you did, are you doing exclusively a rotation in pathology?

63 DR. LAKSHMANAN:

Yes. In these two specialties in pathology.

64 MR. KELBERG:

And this was a four-year residency?

65 DR. LAKSHMANAN:

Yes.

66 MR. KELBERG:

Take us through what responsibilities you gain from when you first start the residency through the fourth year of the residency.

67 DR. LAKSHMANAN:

Basically you learn how to do autopsies on people who die from natural diseases. You learn how to process surgical specimens. That is, a surgeon sometimes removes a breast or a colon, and you learn how to process those specimens, and microscopic studies are done on those specimens to render a diagnosis. There is also a phase in that training wherein you go to the operating room wherein they give you a piece of tissue and you do a frozen section, which is, basically using certain chemicals, you do a temporally freezing of the tissue and study it microscopically. And this is commonly done as part of your training so that the surgeon can decide whether to remove a whole organ or, for example, in a breast biopsy, you may have a lump, you go to the O.R., they call the pathologist, they take a biopsy piece, and if it is cancer, then they take out the whole breast. Otherwise, they may decide to postpone the surgery depending on what they find. I just give an example. So that is one part of the training.

I told you about autopsies. I told you about surgical specimens. And surgical specimens doesn't necessarily mean entire organ removal. It could mean just biopsies. You know, they do biopsies of the stomach or colon depending on what type of biopsy is done. Another aspect of surgical pathology is also called cytology wherein they don't take any piece of tissue. They remove some fluid, study the cells and then decide whether it's cancer or not cancer. Then coming to the clinical pathology, you learn how to run a blood bank. You learn all the procedures in a bacteriology laboratory. You learn all the procedures about how the counts, different blood counts are done, et cetera.

68 MR. KELBERG:

With respect to autopsies, are you permitted as you begin the residency to independently conduct autopsies on persons who have died from suspected natural causes?

69 DR. LAKSHMANAN:

No. Initially--no. During the residency, you're always supervised. You have an attending pathologist who's on staff in the hospital who will train you in doing autopsies and what organs to dissect and how to study them.

70 MR. KELBERG:

Does this residency or did this residency offer any specific training in an area I would call "Forensic pathology"?

71 DR. LAKSHMANAN:

No.

72 MR. KELBERG:

Differentiate if you could for us what is forensic pathology from anatomical or clinical pathology?

73 DR. LAKSHMANAN:

Yes. Forensic pathology is another subspecialty in pathology. And to do forensic pathology, you must already have done basic pathology. As I told you, pathology is the study of laboratory science to diagnose disease. So you basically deal with natural disease processes. But in forensic pathology, you gain the expertise to study unnatural disease processes; that is deaths from firearms, sharp force injuries, drugs, poisons, et cetera.

74 MR. KELBERG:

Doctor, you use the term sharp force injuries as one of the types of deaths that you investigate as a forensic pathologist. What is or are sharp force injuries?

75 DR. LAKSHMANAN:

Sharp force injuries are injuries caused by any sharp instrument. One weapon which I can bring about is a knife, but it could also be a sharp instrument like a broken glass piece, depending on what is used.

76 MR. KELBERG:

Going back to the anatomical and clinical residency, I believe you mentioned something about in the last six months, you were a Chief resident; is that correct?

77 DR. LAKSHMANAN:

Yes.

78 MR. KELBERG:

What is a Chief resident?

79 DR. LAKSHMANAN:

In Chief residency, you learn some administrative skills of making schedules and also conducting the affairs of the residency program, reporting to the attending pathologist in charge of the residency program. You take residence concerns to the attending pathologist and similar other responsibilities.

80 MR. KELBERG:

Do the responsibilities of the Chief resident include making decisions on cases being evaluated by lower-level residents when the attending physician or attending pathologist is not available?

81 DR. LAKSHMANAN:

Yes. The Chief resident also gives advise to the entry-level residents, but the final decision, the final diagnosis doesn't leave the department till the attending pathologist has seen the material and cosigns with the resident, with the Chief resident.

82 MR. KELBERG:

Doctor, is every resident that attends a program such as the one you attended automatically given responsibility as a Chief resident?

83 DR. LAKSHMANAN:

No. Some residents are picked because the attending pathologist, that is the Chief pathologist in that hospital, thinks you have the skills to become a Chief resident. Normally in a pathology residency program, it's--you have four to five residents in every year, and they pick one, depending whom they feel the--has the skills to do the job.

84 MR. KELBERG:

During the course of the residency, are there any types of national examinations that are given to residents at various levels, first year, second year, third year and so forth?

85 DR. LAKSHMANAN:

Not at the time I did the residency. But right now, they do have in-service examinations in other specialties. When I did my residency, all I took was the board examinations at the conclusion of the residency. I took my board examinations in--by the American Board of Pathology in Anatomic and Clinical Pathology in November of 1977.

86 MR. KELBERG:

Is there any other aspect of your residency training that you believe would be of value to those of us hearing this case regarding its reference to forensic pathology?

87 DR. LAKSHMANAN:

Yes. As I told you, I used to work on weekends at the office of the Chief Medical Examiner wherein I had exposure to deaths which are not from natural causes. I saw injuries from firearms, overdoses, though we were not allowed to do homicide cases. We did autopsies on all the non-homicide cases, but as you know, the Chief--the New York Chief Medical Examiner's Office is as busy as Los Angeles and you see a variety of cases going through that office, and I had the privilege of working with different senior pathologists who were on staff at that time.

88 MR. KELBERG:

And one of those would be Dr. Badin?

89 DR. LAKSHMANAN:

One of them was Dr. Badin. The others were Dr. Roe, I worked with Dr. Devlin, I worked with Dr. Gross, I worked with Dr. D'Mayo and different--basically when you work on the weekend, you moonlight and you do two cases when you work on the weekend and you work under the supervision of the Deputy Chief Medical Examiner who takes responsibility for your actions.

90 MR. KELBERG:

What length of time did you do this additional--

91 DR. LAKSHMANAN:

I used to work on weekends beginning 1975, somewhere mid 1975 to mid 1977.

92 MR. KELBERG:

During that period of time, were you exposed to criminal homicides from sharp force injuries such as you've identified?

93 DR. LAKSHMANAN:

I've seen cases, but I did not do them personally. As I told you, we were not allowed to do homicide cases when we did autopsies under the supervision.

94 MR. KELBERG:

In seeing such cases, were you given training as to what it is you as a pathologist would be looking for in such cases?

95 DR. LAKSHMANAN:

I wouldn't say full-fledged training because more education on a one-to-one basis because you will be doing your autopsy, and when you conclude it, you go to the next table and talk to the pathologist who is doing the homicide and you learn from him or her.

96 MR. KELBERG:

Doctor, anything further on your residency training?

97 DR. LAKSHMANAN:

Up to this point, that is it. And then I took my boards in--anatomical and clinical in November of `77.

98 MR. KELBERG:

You've mentioned several times something called "Boards". what are boards?

99 DR. LAKSHMANAN:

In the United States, every specialty has a board which conducts an examination and allows people who have gone to accepted residency training to take an examination to see their competence in the field and award a certificate, which is called board certification in that particular specialty. And for the pathology field, that is the American Board of Pathology.

100 MR. KELBERG:

Doctor, is the examination one that consists of both oral and written portions?

101 DR. LAKSHMANAN:

No. In the American Board of Pathology, it's mainly written, slide review, it's multiple choice questions, it's a three-day examination, pretty intense. You go to written part and since anatomic includes evaluation of slides and--which is microscopic slides or microscopic slide session, then you have a gross photographic session where you're given 40 seconds to make a diagnosis and then the clinical pathology section has several areas to it where you deal with problems as presented, giving your best diagnosis.

102 MR. KELBERG:

Did you successfully complete that examination the first time you took it?

103 DR. LAKSHMANAN:

Yes.

104 MR. KELBERG:

And as a result, you became board certified in the area of anatomical pathology?

105 DR. LAKSHMANAN:

And clinical pathology.

106 MR. KELBERG:

Doctor, what did you do following completion of your residency and if it's separate from your studying and passing of the board examinations?

107 DR. LAKSHMANAN:

Yeah. Actually after I finished my residency in St. Luke's Hospital, I moved to Los Angeles in 1977, July. And as I mentioned earlier, I had been licensed in New York in 1975. In 1976, I took the oral examination in California conducted by the Medical Board of California and I took my license in the State of California also. California Board requires an oral examination and--which I did and I became licensed in California because I wanted to move to Los Angeles for my further training in forensic pathology, and I joined the office of the Chief Medical Examiner-Coroner under Tom Noguchi in 1977, July.

108 MR. KELBERG:

What did you do once you joined that office?

109 DR. LAKSHMANAN:

Yeah. At that time, you were taken as a staff physician, but you also did training in forensic pathology; and that's what I did between 1977, July, and 1978, June. And I completed my training in forensics, but because of my experience in New York, the board of pathology allowed me to take the forensic boards in May of `78, and I got my board certification in forensic pathology in `78.

110 MR. KELBERG:

What kind of training did you receive at the Los Angeles medical examiner's office during this period once you began working there?

111 DR. LAKSHMANAN:

I did numerous varieties of homicide cases, unnatural death cases, deaths from drugs, poisons, traffic accident victims. I think I did about 500 plus cases in the first year I was in Los Angeles County and did a variety of homicides.

112 MR. KELBERG:

Were those cases done with supervision, without supervision, a mix? What was it?

113 DR. LAKSHMANAN:

It was done with supervision. At that time, my mentor was Dr. Dean wisely. He was the Chief of forensic medicine. He always was personally responsible for our work. Even though we worked as staff physicians and were Deputy Medical Examiners, we were directly supervised by Dr. Dean wisely, who unfortunately is no more.

114 MR. KELBERG:

Did you have hands-on responsibility however in conducting autopsies in these cases you've described?

115 DR. LAKSHMANAN:

Hands-on individually done and also had to testify in all cases.

116 MR. KELBERG:

Now, doctor, you said something about board certification in forensic pathology. What is that all about?

117 DR. LAKSHMANAN:

That is basically the same board, the American Board of Pathology, recognizes training in an accepted institution, Los Angeles is one of them, and they allow you to take the examination and they give you a certificate of proficiency that you have passed the examination and meet their standards in the field of forensic pathology.

118 MR. KELBERG:

Did you pass that examination the first time you took it?

119 DR. LAKSHMANAN:

Yes.

120 MR. KELBERG:

Approximately how many board certified forensic pathologists are there in the United States if you know?

121 DR. LAKSHMANAN:

I think about 500 to 700. I'm not sure of the exact number. But actively practicing, about 200 to 300.

122 MR. KELBERG:

And over what period of time has there been a board specialty in forensic pathology?

123 DR. LAKSHMANAN:

I think the board certificate start sometime in the early 70's. I forget the exact date, and that's when the certification started.

124 MR. KELBERG:

What did you do after you obtained your board certification in forensic pathology?

125 DR. LAKSHMANAN:

I was retained by the Chief Medical Examiner, Dr. Noguchi, as a staff pathologist, which I stayed on to--in Los Angeles as a staff pathologist and Deputy Medical Examiner. And during my stay in 1979, I also took the Canadian boards in pathology, which made me eligible for the Royal College of Physicians and Surgeons of Canada, and I became certified in pathology by the Royal College of Physicians and Surgeons of Canada in pathology in `79.

126 MR. KELBERG:

By passing an examination?

127 DR. LAKSHMANAN:

That was an examination which included an oral examination also, and you go in two phases. You take a written examination first. They're a more intense process. You had to qualify in the written examination, and then you're invited for the oral examination, which includes a practical portion, and that you go to a different center. I did my written examination in Vancouver in middle part of `79, and then I went for the oral and practical examination in the end of `79.

128 MR. KELBERG:

And what else were you doing at the time that you were working at the medical examiner's office in New York City?

129 DR. LAKSHMANAN:

Conducting autopsies, testifying in Court. I also at this time got my first faculty appointment at USC. I was appointed as a clinical assistant professor. And--

130 MR. KELBERG:

What did that entail?

131 DR. LAKSHMANAN:

Clinical assistant--basically you teach medical students who rotate.

132 MR. KELBERG:

What does the teaching actually involve? What do you do?

133 DR. LAKSHMANAN:

You do lab instructions. You conduct labs for the medical students. You go to the USC and do it.

134 MR. KELBERG:

Doctor, approximately how many autopsies have you conducted since the time that you have worked at the medical examiner's office in Los Angeles?

135 DR. LAKSHMANAN:

I've done over 3,000, but I supervise thousands of others.

136 MR. KELBERG:

How do you account for that "You supervise" thousands of others?

137 DR. LAKSHMANAN:

I've been in a supervisory capacity since 1986 when I became a senior physician. But even before that, the Los Angeles County medical examiner's office had a title called "The operations officer." So you immediately become a supervisory physician when you get to be an operations officer wherein you are the triage physicians for the office. See, we handle 19,000 cases a year. Inquiries, we roughly accept as Coroner's cases about 12,000 plus in which 9,000 are brought to the central facility. You can not autopsy every case. So you are a senior physician as far as the extent of examination, and that is what an operation officer also does. So actually I've been supervisory capacity since `81, `82 and--not `81. 1979, `80. But in `86, I got the official title of senior medical examiner.

138 MR. KELBERG:

Doctor, in the course of the 3,000 or so autopsies you have actually conducted, have they included criminal homicide cases?

139 DR. LAKSHMANAN:

Yes.

140 MR. KELBERG:

First of all, I think we've heard "Murder" used and I'm not sure we've heard what "Homicide" means. Are they one and the same, "Homicide" and "Murder"?

141 DR. LAKSHMANAN:

No, not in the medical examiner's point of view. When I mean "Homicide," I mean death in the hands of another. I don't decide whether there is intent or not. That is decided by the District Attorney's office.

142 MR. KELBERG:

And you present your reports to the District Attorney's office for evaluation?

143 DR. LAKSHMANAN:

I don't. The law enforcement agency handling the particular death investigation does. And of course, I do interact with the District Attorney's office and the public defender's office as to the content of our reports.

144 MR. KELBERG:

In the course of the autopsies that involve criminal homicides, have you looked at cases of sharp force injuries?

145 DR. LAKSHMANAN:

Yes, I have.

146 MR. KELBERG:

Approximately how many?

147 DR. LAKSHMANAN:

I've done hundreds of sharp force injury cases. And I just looked at some statistics. Just in two and a half years, during the early part of my career, I did about 64 stab wound cases in which 24 were multiple. When we mean "Multiple," we mean that the person has sustained more than 10 plus stab wounds. So I've done a significant number of cases.

148 MR. KELBERG:

Of the criminal homicide cases that have been presented to the Coroner's office since you've been working there, what is the most prevalent type of case that you see?

149 DR. LAKSHMANAN:

Most of the cases in homicides are from firearm injuries. I would say 50 to 60 percent of our cases are from firearm injuries. The sharp force injury would be about 15 to 20 percent. I'm just giving you rough percentages.

150 MR. KELBERG:

Doctor, in your training, before you became board certified in forensic pathology, did you receive training in a field involving estimation of time of death based upon medical factors?

151 DR. LAKSHMANAN:

Yes.

152 MR. KELBERG:

What kind of training did you receive in that regard?

153 DR. LAKSHMANAN:

Basically you read the textbooks and also evaluate the cases you have handled yourself. And in our office, we take certain perimeters to estimate the time of death; and those include the commonly used perimeters, which is the rigor mortis, the livor mortis and also the algor mortis, which is a drop in temperature. There are other perimeters available, but these are the common perimeters used in our office, and our investigator collects this data and based on the cases you do perform autopsies on, you review the data which is available and try and come to an estimated range based on knowledge from your reading and experience. And my experience is that I've been taught by Dr. Wisely and other senior pathologists in the department, and we try to come to some estimations. It's only an estimated range as far as time of death. It's an imprecise--you can only give an estimate.

154 MR. KELBERG:

I think we're going to be getting into this in a bit more detail later, but what kind of experience or training have you received on estimation of time of death since the time you've worked at the Los Angeles medical examiner's office?

155 DR. LAKSHMANAN:

As I told you, on all our cases, that will be one of the common questions which is posed as to if we can determine the time of death, especially this is always a question in unwitnessed deaths, and we go through the exercise and we come to some estimated ranges.

156 MR. KELBERG:

Is that an area that is part of the examination process for board certification in forensic pathology?

157 DR. LAKSHMANAN:

Well, you have to have knowledge in that when you take your board examination because there may be questions in that aspect.

158 MR. KELBERG:

Now, doctor, during your tenor at the medical examiner's office after you were made senior physician, have you moved to other status?

159 DR. LAKSHMANAN:

Yes. In 1987, I was promoted to be Chief of forensic medicine, which is the no. 2 position in the department in an acting capacity. In 1988, I became the permanent Chief of forensic medicine. And at that time, it was the office of the Chief Medical Examiner-Coroner. So basically, I was the second in command to the Chief Medical Examiner-Coroner. And in 1990, for a brief time, for three months, when Dr. Kornblum, who came after Dr. Noguchi, the Chief Medical Examiner-Coroner, went for a period of time on vacation, for three months, I was the acting Chief Medical Examiner-Coroner. But--and in 1990, I went back to being Chief of medicine because Dr. Kogan, one of my colleagues, got the acting Chief Medical Examiner-Coroner. So I became no. 2 again. And then `92, February, I was reappointed as the permanent Chief Medical Examiner-Coroner for the County of Los Angeles?

160 MR. KELBERG:

Is that appointment through a political process by the board of supervisors of Los Angeles County?

161 DR. LAKSHMANAN:

That is correct. The board of supervisors appoint the Coroner, and I think you need to have three boards to get appointed.

162 MR. KELBERG:

Doctor, once you were a Chief pathologist, second in command as you said, what were your responsibilities?

163 DR. LAKSHMANAN:

As I mentioned earlier, I'm the head doctor of the Coroner's office. I also carry out the Coroner functions for the County of Los Angeles. And the main mission of the office is to determine the cause, manner of death on all deaths which become Coroner's cases and as a--and the Coroner's office investigates all unnatural deaths, deaths from--that is homicides. We investigate all deaths from suicides, drug overdoses and we also investigate all natural deaths in which there is no physician in attendance 20 days prior to death. So we handle, as I told you, 19,000. There are about 60,000 plus deaths in Los Angeles County. So one--nearly one-third of the deaths in Los Angeles County come to the Coroner's office as Coroner's cases, and I'm responsible through my staff, the doctors, the investigators and everybody in the department to determine the cause and manner of death, conduct an inquiry and determine the cause and manner of death.

164 MR. KELBERG:

Doctor, how many forensic pathologists are employed under you as the Chief Medical Examiner in Los Angeles County?

165 DR. LAKSHMANAN:

At this time, I have 12--I mean, including me, have 12 full-time permanent staff pathologists. I have four temporary full-time staff pathologists that aren't permanent physicians yet. I have one temporary physician, three fellow. So you talk about 19 physicians.

166 MR. KELBERG:

To handle how many cases?

167 DR. LAKSHMANAN:

Last year, I think we handled about 5800 or 5700 autopsies and we did about another 6,000 examinations in which 3,000 took in-house, took place in-house and about another couple of thousand took place outside the office because we don't bring every case to the main facility. We send an investigator to a mortuary, and that determination is made when the case is reported to us, which case is brought to the central facility. So you talk about 12,000 cases. But those 3,000 are under the--the investigator goes to the mortuary and talks to a duty doctor on the department.

168 MR. KELBERG:

Doctor, of the 12 full-time pathologists employed under you, how many of them are board certified in forensic--

169 DR. LAKSHMANAN:

All 12 permanent people are board certified.

170 MR. KELBERG:

I think it will help if you wait until I finish my question, and I'll try and do the same with your answer.

171 DR. LAKSHMANAN:

Yes.

172 MR. KELBERG:

Doctor, do you need more forensic pathologists to in your judgment fully handle your responsibilities of determining cause and manner of death?

173 DR. LAKSHMANAN:

Yes, I--

174 MR. SHAPIRO:

Objection. Irrelevant.

175 THE COURT:

Overruled. You can answer the question.

176 MR. KELBERG:

You may answer.

177 DR. LAKSHMANAN:

Yes.

178 MR. KELBERG:

Why?

179 DR. LAKSHMANAN:

Because we already do more cases than what we can handle and we always have cases which are being held every day, and having more pathologists will, one, help us to carry out our mission in a better manner. And the ratio recommended in the nation is one pathologist for about 200 to 250 autopsies, and my pathologists handle anywhere from 300 to 350 autopsies a year, and that's a big case load. And the other problem is also not only--

180 THE COURT:

Hold on, hold on, doctor. Ask your next question.

181 MR. KELBERG:

Doctor, do you have any control over the number of criminal homicide cases that must be autopsied by your office?

182 DR. LAKSHMANAN:

I don't.

183 MR. KELBERG:

Do you have any control over how many forensic pathologists you may employ?

184 DR. LAKSHMANAN:

I don't have control over how many I may employ, but one of the problems, also recruitment.

185 MR. KELBERG:

As to how many you may employ, does it require funding from the board of supervisors?

186 DR. LAKSHMANAN:

Yes, it does.

187 MR. KELBERG:

And if you don't have the funding, you may not hire?

188 DR. LAKSHMANAN:

That's correct.

189 MR. KELBERG:

Now, what do you mean by "Recruitment"?

190 DR. LAKSHMANAN:

Recruitment is, there is a shortage of forensic pathologists in the country. And we have a big training program. We train pathologists to become forensic pathologists in the--in our office. And one of the issues is, because of the heavy case load, the pathologists who complete the training like to go to a jurisdiction where there's a lesser case load. And so we lose some of the newly-trained staff in that manner, and because of the heavy case load, some other pathologists may not like to work in such a big office. That's one other drawback. And of course, Los Angeles is a big town, and that issue also comes up because of housing and other issues of living conditions here.

191 MR. KELBERG:

Doctor, how would you describe the complexity of cases presented by the criminal homicide cases that must be autopsied by the doctors at your office?

192 DR. LAKSHMANAN:

They are very complex cases. As I told you, our homicide rate is about 2,000 out of the 6,000 autopsies we do, and among the 2,000 every day, we have cases which are of significant complexity. By "Complexity," I mean in the number of injuries the person has sustained. Like gunshot wounds, there are multiple gunshot wounds, there are multiple stab wound cases, people who die from multiple blunt force trauma. So percentage wise, our responsibility for complex cases is higher than other jurisdictions.

193 MR. KELBERG:

Doctor, with respect to complex cases, do they require more time for the forensic pathologist performing the autopsy than would be required for cases not described as complex?

194 DR. LAKSHMANAN:

Yes.

195 MR. KELBERG:

Why is that?

196 DR. LAKSHMANAN:

Because when you have a number of injuries, our purpose in doing the forensic autopsy is to document the findings. Because you only have one shot at doing a thorough job, you need to document all the injuries completely and thoroughly the first time you do the autopsy. And if you have a lot of injuries to document, it takes time. If you have multiple gunshot wounds, you have to find the trajectory of every gunshot wound the person sustained and you need to retrieve the projectile, describe the injuries, et cetera. So--and all cases are not gunshot wounds. So if the case is complex, it's going to take more time. So one pathologist may be only able to do one case in a whole day or may take two days to do a case. And recently, just two weeks ago, I had several cases where people had died from multiple stab wounds and the pathologist took a couple of days to complete the case. So naturally, the complexity definitely reduces the workload of the physician because of the time spent on the case.

197 MR. KELBERG:

Do you consider as a part of complex cases cases involving multiple victims?

198 DR. LAKSHMANAN:

Multiple victims is not considered complexity because they are different individuals. It is--in each individual, what kind of injuries they have is the complexity for that particular case. But in our office, one physician may have to handle two victims of the same crime.

199 MR. KELBERG:

Is it a policy of your office to try and have the same Deputy Medical Examiner handle the autopsy of whatever number of victims arise out of a single incident?

200 DR. LAKSHMANAN:

That was a policy, but right now, we try and divide the autopsies on these victims to different pathologists.

201 MR. KELBERG:

Why was it originally a policy?

202 DR. LAKSHMANAN:

Because this way, one physician has total control of all the injury patterns observed in all the victims so he could see what other common denominators in the injuries to try and arrive at some conclusions.

203 MR. KELBERG:

Why have you changed from that policy?

204 DR. LAKSHMANAN:

Because the cases are becoming more complex and I think it's better that we divide the work among different physicians. One, you can turn around the process in the office in a more timely manner because let's say you have three complex homicides from one scene of crime and one pathologist is assigned. You may have to wait couple of days before all the autopsies are completed. But if you assign two, three physicians to the same cases, you have one physician doing each of the cases and the detectives can come on one day, and we have the results on the same day or within a day or two, and so a couple of days.

205 MR. KELBERG:

Doctor, you mentioned several times your mission to determine "Cause and manner" I believe is the term you used of death; is that correct?

206 DR. LAKSHMANAN:

Yes.

207 MR. KELBERG:

The cause of death I think seems pretty evident, but what's manner of death?

208 DR. LAKSHMANAN:

Manner of death is whether the death was due to a self-inflicted act like in suicide and sometimes drug overdoses, whether it was an accident, and of course homicide is when another person has been responsible for the injuries which resulted in the death. And then we do have the natural deaths, which I've already discussed, and one other category we have is undetermined when we are not able to determine whether it's a suicide or accident or homicide.

209 MR. KELBERG:

In your experience in handling suicide cases, have you had experience where the suicide was committed through the use of a knife?

210 DR. LAKSHMANAN:

Yes.

211 MR. KELBERG:

Is that part of your experience in evaluating cases of sharp force injuries?

212 DR. LAKSHMANAN:

Yes.

213 MR. KELBERG:

You also mentioned a term called "Blunt force trauma." And I think we're going to get into that in a little more detail in a few minutes, but in general, what does that refer to?

214 DR. LAKSHMANAN:

"Blunt force" refers to injuries from blunt objects, and one of the examples could be a hammer or crow bar or two by two, which is a piece of wood, et cetera.

215 MR. KELBERG:

Have you had experience in evaluating cases of blunt force trauma?

216 DR. LAKSHMANAN:

Yes, I have.

217 MR. KELBERG:

Can you estimate approximately through your training and your actual experience how many such cases you've evaluated?

218 DR. LAKSHMANAN:

I would say in the--about a hundred plus.

219 MR. KELBERG:

And have you also supervised cases involving blunt force trauma?

220 DR. LAKSHMANAN:

Yes, I have.

221 MR. KELBERG:

Approximately how many?

222 DR. LAKSHMANAN:

Hundreds because I've been involved in training program for the last 10 plus years.

223 MR. KELBERG:

Now, doctor, when you joined the medical examiner's office, was the office structured such that the investigators worked under the direction of the Chief Medical Examiner?

224 DR. LAKSHMANAN:

Yes.

225 MR. KELBERG:

Has that changed?

226 DR. LAKSHMANAN:

Yes.

227 MR. KELBERG:

When did that change?

228 DR. LAKSHMANAN:

That changed in 1990. The board of supervisors changed the ordinance wherein you had non-physician director to conduct the operations of the department, but the Chief Medical Examiner-Coroner was retained to carry out the Coroner functions or the medical functions.

229 MR. KELBERG:

What responsibility or control do you as the Chief Medical Examiner have over any of your investigators who may be working for the other side of the office?

230 DR. LAKSHMANAN:

I don't have direct control, but I set the standards for their practice in the department, and they usually carry out my requests.

231 MR. KELBERG:

And if they don't?

232 DR. LAKSHMANAN:

They usually do. I have not seen them refuse my request.

233 MR. KELBERG:

We'll leave it at that. Doctor, you indicated earlier that you're board certified in I think six areas of specialties; is that correct?

234 DR. LAKSHMANAN:

Yes.

235 MR. KELBERG:

We've heard so far of the anatomical, clinical, forensic pathology and with the Royal board in Canada. What are your other board certifications?

236 DR. LAKSHMANAN:

I've certified in internal medicine, I've certified in infectious diseases and I've certified in geriatric medicine. The internal medicine, infectious diseases is by the American Board of Internal Medicine, the Geriatric Medicine boards is by the American Board of Internal Medicine and American Board of Family Practice. And those are the other three certifications which I alluded to earlier.

237 MR. KELBERG:

When did you receive each of those board certifications?

238 DR. LAKSHMANAN:

Internal medicine was `83, infectious disease was `84 and the geriatric medicine boards was in `92.

239 MR. KELBERG:

Did each of those board certifications require you to pass some type of examination?

240 DR. LAKSHMANAN:

Yes.

241 MR. KELBERG:

Did each one involve a written examination?

242 DR. LAKSHMANAN:

Yes.

243 MR. KELBERG:

Did any of them involve an oral examination?

244 DR. LAKSHMANAN:

No.

245 MR. KELBERG:

Were you successful in passing each of the examinations the first time you took them?

246 DR. LAKSHMANAN:

I passed the infectious disease examination the first time, but not the internal medicine and infectious disease--I mean internal medicine and geriatrics.

247 MR. KELBERG:

Did you pass them the second time you took them?

248 DR. LAKSHMANAN:

Yes.

249 MR. KELBERG:

Doctor--

250 DR. LAKSHMANAN:

Not the second time. I passed geriatrics the third time and internal medicine the third time.

251 MR. KELBERG:

Doctor, would it be accurate to say your primary area of specialty is forensic pathology?

252 DR. LAKSHMANAN:

Yes.

253 MR. KELBERG:

Why have you pursued board certification in these other areas?

254 DR. LAKSHMANAN:

Because I'm also a clinician and I like doing clinical medicine.

255 MR. KELBERG:

Does clinical medicine help you in any way in being a better forensic pathologist?

256 DR. LAKSHMANAN:

Yes.

257 MR. KELBERG:

In what way?

258 DR. LAKSHMANAN:

It helps you to understand the--the clinical aspects of medicine because half our work is to both--do both--evaluate hospital cases because many deaths which are reported to our office also go to a hospital before they become Coroner's cases because lifesaving efforts are made and it's good to know about medical treatment. And I'm also responsible for evaluating communicable diseases.

259 MR. KELBERG:

Doctor, among the 12 board certified forensic pathologists working for you, is there a doctor by the name of Irwin Golden?

260 DR. LAKSHMANAN:

Yes.

261 MR. KELBERG:

How long have you known Dr. Golden?

262 DR. LAKSHMANAN:

I've known Dr. Golden since 1983 when I returned back to the Coroner's office, but he's been on the staff since 1981.

263 MR. KELBERG:

You've indicated that you left the Coroner's office for some period of time?

264 DR. LAKSHMANAN:

Yes.

265 MR. KELBERG:

When was that?

266 DR. LAKSHMANAN:

I left the Coroner's office in 1980 for two years when I furthered my training in internal medicine and infectious diseases.

267 MR. KELBERG:

And then you returned to the medical examiner's office?

268 DR. LAKSHMANAN:

Yes, I did.

269 MR. KELBERG:

Is Dr. Golden a doctor who has worked continuously at the medical examiner's office since 1983 when you returned?

270 DR. LAKSHMANAN:

Yes.

271 MR. KELBERG:

And from your knowledge of him, you learned that he has worked there in fact since 1981?

272 DR. LAKSHMANAN:

Yes.

273 MR. KELBERG:

In your position as Chief Medical Examiner, are you familiar with approximately how many autopsies he has performed in the course of the time he has been with your office?

274 DR. LAKSHMANAN:

I think over 5,000 plus.

275 MR. KELBERG:

Doctor, do you consider Dr. Golden to be a personal friend of yours?

276 DR. LAKSHMANAN:

Yes. He's also a colleague.

277 MR. KELBERG:

As you sit here today, how do you feel about testifying in this case?

278 MR. SHAPIRO:

Objection. Irrelevant.

279 THE COURT:

Overruled.

280 MR. KELBERG:

You may answer.

281 DR. LAKSHMANAN:

I'm here to present truthfully and accurately the Coroner's findings on the two victims who died, Miss Nicole Brown Simpson and Ron Goldman, so that the jury can understand the Coroner's process and know the truth about all the findings and any errors which were committed by the office, acknowledge them and basically explain the cause and manner of death.

KEY QUOTE
282 MR. SHAPIRO:

Objection. Motion to strike. Nonresponsive.

283 THE COURT:

Overruled. Proceed.

284 MR. KELBERG:

Thank you, your Honor.

285 MR. KELBERG:

Doctor, have you found in your review of all the materials you have reviewed that Dr. Golden made mistakes in the course of conducting autopsies on Nicole Brown Simpson and Ronald Golden--Goldman? Excuse me.

286 DR. LAKSHMANAN:

He has made some mistakes, yes.

KEY QUOTE
287 MR. KELBERG:

And we're going to get into this in much greater detail later. Have you been asked to evaluate as to any such mistake the significance of the mistake on a variety of issues?

288 DR. LAKSHMANAN:

Yes, I have been asked to review the significance.

289 MR. KELBERG:

Have you done that?

290 DR. LAKSHMANAN:

Yes.

291 MR. KELBERG:

Doctor, from your findings of whatever mistakes were made, is it difficult for you to be here today to testify?

292 MR. SHAPIRO:

Objection. Irrelevant.

293 THE COURT:

Overruled.

294 DR. LAKSHMANAN:

No.

295 MR. KELBERG:

Now, doctor, you--going back just to your curriculum vitae, do you have any teaching appointments at the present time?

296 DR. LAKSHMANAN:

Yes, I do.

297 MR. KELBERG:

What are they?

298 DR. LAKSHMANAN:

I'm a Clinical Professor at USC School of Medicine both in medicine and pathology. I'm also an assistant professor--not assistant--associate professor at UCLA school of medicine in pathology.

299 MR. KELBERG:

What do those responsibilities entail?

300 DR. LAKSHMANAN:

The residence from both these institutions rotate in the Department of Coroner, and I'm involved in the training in forensic pathology. They do monthly rotations. I also give lectures when requested by these institutions to their staff. I'm also involved in the medical student rotations at USC school of medicine.

301 MR. KELBERG:

How long have you been with those affiliations?

302 DR. LAKSHMANAN:

With UCLA, I've been associate professor since 1992. With USC, I've been since 1979. But as I told you, I started as assistant professor at USC, moved up to associate professor and now I'm a full professor.

303 MR. KELBERG:

Doctor--

304 DR. LAKSHMANAN:

In the clinical series, clinical series.

305 MR. KELBERG:

Doctor, you've indicated that you have testified before in court as a result of cases that you have handled as a forensic pathologist; is that correct?

306 DR. LAKSHMANAN:

Yes.

307 MR. KELBERG:

Approximately how many times have you testified in court as an expert in forensic pathology?

308 DR. LAKSHMANAN:

Hundreds of times in this county, testified a few--fewer times in San Bernardino, Kern and San Diego counties, testified in Los Angeles Federal Court and also federal courts in Virginia and Las Vegas.

309 MR. KELBERG:

Have you ever testified as a witness called by a Defendant in a criminal case?

310 DR. LAKSHMANAN:

Not that I recall on a criminal matter, but I have been called by the public defender's office to testify as to the findings. But mainly I testified for the Prosecution on criminal matters.

311 MR. KELBERG:

I think the public defender's office would feel slighted if you didn't recognize them as lawyers who represent people charged with crimes.

312 MR. SHAPIRO:

I'm going to object to the form of the question.

313 THE COURT:

Sustained. Rephrase the question.

314 MR. KELBERG:

Doctor, what's your understanding of who the public defender's office represents?

315 DR. LAKSHMANAN:

They represent the defendants. And when they request me to come on a case to explain certain findings, I have done that. But mainly on criminal prosecutions, I have testified for the Prosecution. In civil cases, I've testified for both.

316 MR. KELBERG:

When you say "Both," what do you mean?

317 DR. LAKSHMANAN:

Plaintiff and Defense.

318 MR. KELBERG:

Plaintiffs in what kind of cases, doctor?

319 DR. LAKSHMANAN:

These are malpractice cases which come to court. Sometimes they're a civil litigation on the mechanics of a vehicle which caused a traffic accident. So in these kind of situations, both the Defense and the Prosecution approach me.

320 MR. KELBERG:

Doctor, from your experience, is it common that Deputy Medical Examiners or Chief Medical Examiners are commonly called by the Prosecution in criminal cases?

321 DR. LAKSHMANAN:

Yes.

322 MR. SHAPIRO:

Objection. Irrelevant.

323 THE COURT:

Overruled.

324 MR. KELBERG:

Doctor, can you estimate for us approximately how many hours you have put in in preparing to testify here today, evaluations and so forth?

325 DR. LAKSHMANAN:

I would say at least about hundred plus hours with the--you and Mr. Ken lynch and I spent hundreds of other hours with coordination--coordinating police reports working with Defense attorneys on different issues when they call us. So I would say couple of hundred hours in the last one year.

326 MR. KELBERG:

Doctor, in that couple of hundred hours, have you received any additional compensation from whatever your salary may be for the additional time you've worked on this case?

327 DR. LAKSHMANAN:

No.

328 MR. KELBERG:

Are you still expected to do your work as the responsibilities of the Chief Medical Examiner are defined?

329 DR. LAKSHMANAN:

Yes.

330 MR. KELBERG:

Have you done that?

331 DR. LAKSHMANAN:

Yes.

332 MR. KELBERG:

When do you find the time to work on this case?

333 DR. LAKSHMANAN:

I start early whenever I'm required to meet with the Prosecution team and I work late in the evening sometimes and work at my off hours at home.

334 MR. KELBERG:

Doctor, you've indicated a number of hours that you believe you've worked with Mr. Lynch and myself in preparation for testifying here today. What is the content of that preparation if it's something other than shooting the breeze and having coffee?

335 DR. LAKSHMANAN:

I would say a hundred hours, maybe more.

336 MR. KELBERG:

What have we been doing for a hundred hours?

337 DR. LAKSHMANAN:

There have been several processes involved in the different meetings. One was to evaluate the photographs and understand the injuries depicted in the photographs. That is one aspect of our meeting. The other aspects were preparing the justification of the photographs for introduction into evidence so that the Coroner's findings may be prepared--may be presented in a proper manner. We were also involved in reviewing literature on time of death issues, and I assisted in the process of preparing the charts to--to discuss the time of death issue.

338 MR. KELBERG:

Doctor, can you estimate about how much literature you've reviewed in the course of preparing for your testimony?

339 DR. LAKSHMANAN:

Couple of textbooks and several articles.

340 MR. KELBERG:

And approximately how much time you have devoted to just reading the literature?

341 DR. LAKSHMANAN:

Several hours on each of the books and some of the articles.

342 MR. KELBERG:

I'm sorry. Several hours on each of the books or several hours combined?

343 DR. LAKSHMANAN:

Several hours on each of the books and articles.

344 MR. KELBERG:

Now, doctor, have you been given any instructions or requests by either myself or Mr. Lynch with respect to what is expected from you as you testify here as a witness today?

345 DR. LAKSHMANAN:

Basically to tell the truth and to bring out all the Coroner's findings and present them to this jury and the public as I see it.

346 MR. KELBERG:

Have we suggested in any way how your findings should be or what your findings should be?

347 DR. LAKSHMANAN:

No.

348 MR. KELBERG:

And would you in fact allow us to do that?

349 DR. LAKSHMANAN:

No. First of all, I'm the doctor and you're the lawyer and I'm supposed to present the medical findings. There's no way you can coach me on medical findings.

350 MR. KELBERG:

Have we tried to coach you in any way?

351 DR. LAKSHMANAN:

No.

352 MR. KELBERG:

Doctor, besides your teaching responsibilities, are you a member of certain recognized organizations in the fields of medicine?

353 DR. LAKSHMANAN:

Yes, I am.

354 MR. KELBERG:

What are they?

355 DR. LAKSHMANAN:

I am the--I'm a fellow of the American College of Physicians. I'm a fellow at the College of American Pathologists. I'm a fellow in the Royal College of Physicians and Surgeons of Canada in the division of medicine. I am a member of the Infectious Disease Society of America. I'm a fellow of the American Academy of Forensic Sciences. I'm a member in the National Association of Medical Examiners. I'm a member of the Los Angeles Society of Pathologists.

356 MR. KELBERG:

Doctor, are these organizations, number one, that you've joined just by paying dues?

357 DR. LAKSHMANAN:

You have to pay dues, but to be eligible for membership, you must have achieved certain competence in the field because--for example, the American College of Physicians, to become a fellow, you must ordinarily be board certified in internal medicine or subspecialties and have published some articles. And College of American Pathologists, you have to be board certified in pathology before you become a fellow of the American College of--American Pathologists. For the Royal College of Physicians and Surgeons of Canada, you have to be certified by the Royal College before you get Fellowship. For the American Academy of Forensic Sciences, in addition to being a forensic scientist, you have to have actively taken part in some of the Academy meetings, presented papers, which I have done, and then you get elected to be a fellow after having been a member for several years. For the Infectious Disease Society, you have to be board certified in infectious diseases to be a member of the Infectious Disease Society of America. To be a Los Angeles Society pathologist member, you have to be an active pathologist in the Los Angeles County. As far as the National Association of Medical Examiners, you must be a certified forensic pathologist to be a member of the National Association of Medical Examiners, but they do take board eligible forensic pathologists also.

358 MR. KELBERG:

Does the term "Fellow" that you've used with respect to several of the organizations have any particular meaning?

359 DR. LAKSHMANAN:

Yes. That is a special recognition to years of experience and qualifications in addition to other requirements.

360 MR. KELBERG:

Doctor, you mentioned I think briefly something about literature as far as articles. Are these articles in which you either alone or with others wrote the content of the articles?

361 DR. LAKSHMANAN:

Yes.

362 MR. KELBERG:

Tell us a bit about your literature.

363 DR. LAKSHMANAN:

I've written articles on deaths from disopyramide, flecainide. I've coauthored articles on crossbow injuries. I worked on an article with--a case support on tuberculosis aortitis. Also written articles on identification of doe's by using pacemakers, dentures. Those are some of the publications there in the bibliography there.

364 MR. KELBERG:

Approximately how many publications do you have to your--

365 DR. LAKSHMANAN:

I think about 11.

366 MR. KELBERG:

And are you also involved in something that's called an "Abstract" separate and apart from the actual articles?

367 DR. LAKSHMANAN:

Yes.

368 MR. KELBERG:

What is an "Abstract"?

369 DR. LAKSHMANAN:

Abstract is, you present a paper in a national meeting and you present a particular topic to an audience and that gets published in that meeting handout, and it also includes presentation of posters which would--picking a particular topic and demonstrating it in the form of a poster. And I've done about--

370 MR. KELBERG:

Could you explain that a little bit? What do you mean by demonstrating on a poster?

371 DR. LAKSHMANAN:

If you--if--let's say you're doing sex determination by pubic remains. You take different photographs of--from different victims, the pubic synthases region and demonstrate what are the features that help you identify a person from those features. And that will be one kind of poster presentation. The other poster presentation could be on any other topic the way you want to present it. It could be photographic or literature searches, documenting and supporting the evidence you want to present.

372 MR. KELBERG:

Approximately how many abstracts have you been involved with?

373 DR. LAKSHMANAN:

I think at least nearly two dozen, and I have the exact number here.

374 MR. KELBERG:

Do you have a copy of the curriculum vitae that we've previously marked as exhibit 295?

375 DR. LAKSHMANAN:

Yes. And--

376 MR. KELBERG:

And that will allow you to refresh your memory as to the exact number?

377 DR. LAKSHMANAN:

Yes.

378 MR. KELBERG:

Please do so.

379 DR. LAKSHMANAN:

Publications, 11 as I mentioned and abstracts and poster presentations, 20.

380 MR. KELBERG:

Doctor, is there anything else that you would like to bring to our attention dealing with your education, your experience, your training which allows you to practice in the area of forensic pathology?

381 DR. LAKSHMANAN:

Well, I think I've covered everything I wanted to say.

382 MR. KELBERG:

Now, doctor, I would like to move to a completely different topic. On June 13th, 1994, did you learn that there were two criminal homicide cases presented at your office involving Nicole Brown Simpson and Ronald Goldman?

383 DR. LAKSHMANAN:

Yes.

384 MR. KELBERG:

Have you prepared at your direction photographs which will show us the process that is followed with respect to those two bodies or any other bodies that are suspected criminal homicides from the time they arrive at your office through the time of autopsy?

385 DR. LAKSHMANAN:

Yes.

386 MR. KELBERG:

Before we start with the photographs, would you please define for us, what is an autopsy?

387 DR. LAKSHMANAN:

An autopsy is examination of a human body with the sole purpose of determining the cause and manner of death and also diagnosing the disease processes the person may or may not have had. This is an internal--this includes an external examination of the body. And in the forensic autopsy, you look for identifying characteristics like scars, tattoos. You also document any injuries as you do that process. And the documentation of the injuries and these identifying characteristics take place on diagrams described by the Coroner's office. Photographs are taken. And following this process, the internal examination is done. And the internal examination is an organ-by-organ dissection by the pathologist looking at the various areas of the body. And if the death is from firearm injuries or sharp force injuries, you document the trajectory of the injuries, recover projectiles if they are death from firearms. And during the process also, you save body tissues and fluids for any toxicological analysis you may need to do. You save tissues for any microscopic analysis you need to do. And following the autopsy process, you document all the findings and later, you dictate them, which comes a transcribed autopsy process. Now, the autopsy process also will include collection of any evidence before the autopsy, which will be an external examination stage, at which time the photographs are also taken and sometimes x-rays are taken before the autopsy to document location of projectiles if the death is from firearms. And that gives you a rough summary of the process. Basically you have an external examination, an internal examination, evidence collection before autopsy, tissue, fluid collection during autopsy for various purposes. Conclusion of the process, you determine the findings, assimilate the findings and make a diagnosis as to the cause of death, and then the doctor issues the findings as to the cause of death and a death certificate is issued, which is a final work product of the Coroner's office determining the cause of death.

388 MR. KELBERG:

Doctor, all the documents that you've talked about, the diagrams and so forth, are these documents which are expected to be completed by the Deputy Medical Examiner at or shortly after the time of the actual observation of whatever is being diagrammed?

389 DR. LAKSHMANAN:

Yes.

390 MR. KELBERG:

And is the "Autopsy protocol" the term that is used for this transcribed document which reflects in words the observations made by the medical examiner?

391 DR. LAKSHMANAN:

Yes.

392 MR. KELBERG:

Is that autopsy protocol something which is expected to completed shortly after the autopsy has been performed?

393 DR. LAKSHMANAN:

Yes.

394 MR. KELBERG:

And in your office, is there a time frame with which the medical examiner is expected to comply in order to have the transcription prepared?

395 DR. LAKSHMANAN:

The medical examiner has about 24 hours to dictate the findings and--but generally, most of the doctors dictate the findings the same day soon after the autopsy. The documented injuries are done on the diagrams.

396 MR. KELBERG:

Doctor, in the course of your review of the information in this case, did you learn as to whether or not an investigator from the Coroner's office was dispatched to 875 South Bundy in Los Angeles County on June 13th, 1994?

397 DR. LAKSHMANAN:

Yes.

398 MR. KELBERG:

Who or whom, if it's more than one, was dispatched?

399 DR. LAKSHMANAN:

The investigator who was dispatched to 875 south Bundy was Miss Claudine Ratcliffe. Separately also, one of our forensic attendants responded to the scene, and that was Mr. Jacobo.

400 MR. KELBERG:

What are the qualifications of an investigator such as Claudine Ratcliffe? Maybe we should start with, what is she expected to do when she goes to 875 south Bundy as a Coroner investigator?

401 DR. LAKSHMANAN:

They have several responsibilities. One of the responsibilities is to talk to the--in this particular case, it was a criminal death investigation which was being conducted as two decedents had expired--I mean two decedents were involved. And Miss Ratcliffe had to discuss the circumstances with the law enforcement officials who were there. This is one of the functions, to collect the circumstances and make that available to the medical examiner. The other responsibility is to establish identification of the decedents, collect data which will help in that process.

402 MR. KELBERG:

How is that done? What kind of data?

403 DR. LAKSHMANAN:

Well, one is, if there's family members available, be sure identification, sometimes from California driver's license and sometimes from passports. This is one method of--which is used at the scene, or somebody may know the person. The--shall I continue?

404 MR. KELBERG:

Please.

405 DR. LAKSHMANAN:

The other responsibility for the investigator is to collect perimeters for the medical examiner with reference to time of death, which is the livor mortis, the algor mortis and the rigor mortis, estimate of those perimeters.

406 MR. KELBERG:

I think you mentioned rigor twice and livor once. Did you mean to say a different--

407 DR. LAKSHMANAN:

No. I said livor, algor and rigor.

408 MR. KELBERG:

All right. So three different components?

409 DR. LAKSHMANAN:

Yes.

410 MR. KELBERG:

What are the training procedures or what is the training provided for somebody like Miss Ratcliffe to perform that task?

411 MR. SHAPIRO:

Objection to the form of the question.

412 THE COURT:

Sustained. Rephrase the question.

413 MR. KELBERG:

Does Miss Ratcliffe have any specialized training provided by your office to accomplish that function that you've just identified?

414 MR. SHAPIRO:

Objection. Calls for hearsay.

415 THE COURT:

Overruled. You can answer the question.

416 DR. LAKSHMANAN:

She is trained by the--during the initial part of her career as how to estimate rigor mortis and also the--taking the liver temperature to estimate the temperature decrease after death.

417 MR. KELBERG:

We'll get into that in greater detail. What other responsibilities does Miss Ratcliffe have when she goes out to the scene?

418 DR. LAKSHMANAN:

The next respon--I mentioned three already. The fourth responsibility, to take at-scene photographs so that the medical examiner has an idea what really occurred at the scene because our doctors don't go to the scene on every case and the investigators are the eyes and ears of the medical examiner. And they obtain information for us, as I mentioned earlier. They also take at-scene photographs, which gives us a better feeling of what happened at the scene or the condition of the body in which they saw the decedent. The other aspect of their responsibility is to--

419 MR. KELBERG:

I'm sorry. Before you go further, let me clarify or ask some clarifying questions?

420 DR. LAKSHMANAN:

Some more water?

421 THE COURT:

Miss Robertson. Go ahead.

422 MR. KELBERG:

With respect to the photographs, assuming that there's a police agency involved in the investigation and there is a police agency with a photographer at the scene of the body or bodies that the investigator is going to observe and handle, what kind of photographs do you expect from the investigator, vis-à-vis what you would leave to the police agency to obtain?

423 DR. LAKSHMANAN:

The police agencies take a more detailed--they obtain many photographs of the scene which gives you more detail. But our investigator just takes some Polaroid photographs to give us an idea about the location of the body and its relationship to the surroundings to the extent possible. We only take Polaroid photographs.

424 MR. KELBERG:

Would you like to tape a sip?

425 DR. LAKSHMANAN:

Yes.

426 (Brief pause.)
427 MR. KELBERG:

Now, doctor, what is the responsibility that the investigator like Miss Ratcliffe has, vis-à-vis the responsibility of the police agency investigators dealing with the victim's body?

428 DR. LAKSHMANAN:

The--the examination of the body is the purview of the Coroner's investigator. The law enforcement investigators do not deal with the examination of the body. The examination of the body is under the Coroner's domain.

429 MR. KELBERG:

Doctor, you said that doctors do not go on every case--medical examiners do not go on every case to the scene where the bodies are located. Is that an accurate statement of what you said?

430 DR. LAKSHMANAN:

Yes.

431 MR. KELBERG:

How frequently do you go?

432 DR. LAKSHMANAN:

Only if there's a special need to go. Like the last time I went to a scene was one of my--one of my doctors expired. So I went to the scene. But generally we don't have the staffing to allow that. We do send all our doctors in training to go to the scene.

433 MR. KELBERG:

Doctor, in your opinion, would it be a better practice to have one of your doctors at the scene than to rely, as you say, on the investigator to be the eyes and ears of the medical examiner?

434 DR. LAKSHMANAN:

It would be good practice to have that also happen.

435 MR. KELBERG:

In your opinion, doctor, is the fact that you or a Deputy Medical Examiner from Los Angeles County medical examiner's office did not go to 875 Bundy on June 13th, but rather Miss Ratcliffe was sent, does that affect in any way your ability to determine the issues that you have reviewed in this case?

436 MR. SHAPIRO:

Objection. Calls for speculation.

437 THE COURT:

Sustained.

438 MR. KELBERG:

Doctor, from your review of the information that you have been provided, is there anything which you believe you would have been able to obtain that would have given you significant information not provided in the materials you have?

439 MR. SHAPIRO:

Objection. Calls for speculation.

440 THE COURT:

Overruled.

441 MR. KELBERG:

You may answer the question.

442 DR. LAKSHMANAN:

It would have been nice for one of our doctors to go to the scene, but I don't think we lack any other information we need to provide the opinion we need to provide.

443 MR. KELBERG:

Why is that, doctor?

444 DR. LAKSHMANAN:

Because the different objectives you try to meet when you go to the scene is being met by our Coroner's investigator who is pretty well trained to obtain that information. And in our office, this has been the practice for several years, ever since I joined, and I find that though going to the scene does help, if a trained investigator collects information you need, it provides enough basis for our opinions.

445 MR. KELBERG:

Doctor, as part of your review of the information in this case, have you personally visited 875 Bundy?

446 DR. LAKSHMANAN:

Yes. I visited the sight twice.

447 MR. KELBERG:

And were you able when you visited the sight to look in the areas where from photographs, you learned that the bodies of Mr. Goldman and Miss Brown Simpson were found?

448 DR. LAKSHMANAN:

Yes.

449 MR. KELBERG:

Were you also able to examine the environment surrounding that area, including trees, plants, walls, steps, things of that nature?

450 DR. LAKSHMANAN:

Yes.

451 MR. KELBERG:

Now, were there any other--I think you were going on to another responsibility of Miss Ratcliffe before I interrupted you with some clarifying questions. Were there any other responsibilities?

452 DR. LAKSHMANAN:

Yes, yes, yes. I mentioned identification. I mentioned collecting circumstances. I mentioned collecting perimeters of time of death. I represented at-scene photographs. The other two aspects of the Coroner's investigator is preservation of the property of the decedent, and most importantly, notifying the next of kin because the next of kin may not necessarily be there at the residence and they have--our responsibility in our office also is to notify the next of kin that their loved one has unfortunately died and let them know what the circumstances are. So these are roughly the major responsibilities of the investigator, which I wanted to bring up here.

453 MR. KELBERG:

Doctor, is there also latitude provided to the investigator with respect to calling a criminalist who is employed by the medical examiner's office to the scene?

454 DR. LAKSHMANAN:

Yes.

455 MR. KELBERG:

I think we're going to get into that subject a little later. But would that be an additional possible responsibility of the investigator?

456 DR. LAKSHMANAN:

Yes.

457 MR. KELBERG:

Anything else?

458 DR. LAKSHMANAN:

Basically, I think I've given you the highlights of the Coroner's investigators responsibilities.

459 MR. KELBERG:

Now, you said another person was dispatched as well as Miss Ratcliffe to the 875 Bundy location. Who was that by title or position or something, and we'll get a name in a moment if you know it?

460 DR. LAKSHMANAN:

Mr. Jacobo.

461 MR. KELBERG:

I guess we'll get a name now. What's the position?

462 DR. LAKSHMANAN:

He's a--he was a forensic mortuary attendant at that time.

463 MR. KELBERG:

That is a fancy title for doing what?

464 DR. LAKSHMANAN:

They help in transporting the remains from a scene to the main office. They're also responsible for initial processing of the remains in our office, which includes fingerprinting, measuring the height, weight, et cetera.

465 MR. KELBERG:

Is there a form that the investigator uses that is part of the regular procedure with criminal homicide cases to record the measurements, height and weight, obtained by a person such as Mr. Jacobo when the bodies are returned to the medical examiner's office?

466 DR. LAKSHMANAN:

Yes.

467 MR. KELBERG:

Are there any other responsibilities that Mr. Jacobo would be expected to have in June of 1994?

468 DR. LAKSHMANAN:

Basically the responsibilities I already mentioned.

469 MR. KELBERG:

Is Mr. Jacobo under the direction of Miss Ratcliffe at the scene?

470 DR. LAKSHMANAN:

Yes.

471 MR. KELBERG:

Do they go in the same car or van or do they go separately if there is a usual practice?

472 DR. LAKSHMANAN:

They go in separate vehicles.

473 MR. KELBERG:

And is that the usual practice?

474 DR. LAKSHMANAN:

Yes.

475 MR. KELBERG:

Is that what in fact happened here?

476 DR. LAKSHMANAN:

Yes.

477 MR. KELBERG:

Your Honor, may I have just a moment to talk to Mr. Fairtlough?

478 (Brief pause.)
479 MR. KELBERG:

Thank you, your Honor. Your Honor, I believe at this time, we do have some photographs taken at the direction of Dr. Lakshmanan which are on the laser disk as Mr. Fairtlough confirms for me. I understand we can print out the photograph after it's been shown. And so I would recommend that we use the printout as the exhibit and just do them sequentially starting with 296 on.

480 THE COURT:

All right. People's 296, next photo in order.

481 (Deft's 296 for id = photograph)
482 MR. KELBERG:

Photo 06, please.

483 MR. KELBERG:

Doctor, what are we looking at in this particular photo, which will be exhibit 296?

484 DR. LAKSHMANAN:

You're looking at a Coroner's van, side view.

485 MR. KELBERG:

Without--

486 DR. LAKSHMANAN:

This would be the vehicle that Mr. Jacobo would have taken to the scene to bring back the remains--the decedents back to the office.

487 MR. KELBERG:

Doctor, I don't think we want to have to send you to a chiropractor. I don't know if there's a more readily seen screen.

488 THE COURT:

Yes. Doctor, to your right, doctor, there should be a--to your right.

489 MR. KELBERG:

The other right, doctor.

490 THE COURT:

There you go. Right there.

491 DR. LAKSHMANAN:

Oh.

492 THE COURT:

Mr. Kelberg.

493 MR. KELBERG:

Thank you, your Honor.

494 THE COURT:

You're welcome.

495 MR. KELBERG:

Doctor, is this the actual vehicle or just a representative sample?

496 DR. LAKSHMANAN:

This is actually--not actually. One of the vehicles of the Coroner's office.

497 MR. KELBERG:

As far as shape and design, is this basically the type of vehicle that Mr. Jacobo took?

498 DR. LAKSHMANAN:

Yes.

499 MR. KELBERG:

Where is this van parked in this photograph, 296?

500 DR. LAKSHMANAN:

This is marked in the garage area of the Coroner's office.

501 MR. KELBERG:

I think you might have to swing the microphone.

502 (The witness complies.)
503 MR. KELBERG:

Thank you, doctor.

504 DR. LAKSHMANAN:

It's parked in the garage area of the Coroner's office.

505 MR. KELBERG:

And what is the process that is expected to take place at that location when the bodies are brought back?

506 DR. LAKSHMANAN:

The remains are removed from the van and the--they're taken to a room adjoining the garage there wherein their height and weight is taken.

507 MR. KELBERG:

Is there anything else that this photograph depicts that is of consequence to your practice and procedure?

508 DR. LAKSHMANAN:

Nothing else I see here.

509 MR. KELBERG:

Could I have photo 08, please, Mr. Fairtlough. And could this be 297, your Honor?

510 THE COURT:

297.

511 (Peo's 297 for id = photograph)
512 MR. KELBERG:

What are we looking at in this photo, doctor?

513 DR. LAKSHMANAN:

If I point here, is that pointing there, your Honor?

514 THE COURT:

He needs to point.

515 MR. KELBERG:

I think we've learned from experience that Mr. Fairtlough may be a better pointer. If you could direct Mr. Fairtlough to the portion of the photograph you wish him to highlight, please do so, doctor.

516 THE COURT:

There should be an arrow.

517 DR. LAKSHMANAN:

The arrow is correctly pointing to a gurney, and as the arrow moves to the side, you have the drying racks, the--three of them. This photograph is of the same garage area where you saw the van parked. And what you're seeing is the gurnies and the drying racks which have been washed and are drying in the--actually the clothing--the clothing are hung in these drying racks, and they've been washed and they're allowed to be dried in the garage area.

518 MR. KELBERG:

Is this where they are routinely cleaned, that is these drying racks?

519 DR. LAKSHMANAN:

Yes.

520 MR. KELBERG:

And will they be then taken to another area from this garage for use?

521 DR. LAKSHMANAN:

Yes. They are taken to the photographic area when they're completely dry. And one point I want to make here, if the arrow can go--move downwards a little bit, you can see the--there's a pan there, and that's the drip pan. And there are shelves available in the drying rack. So the location of the pan can be adjusted to the length of the clothing. And the other point I want to make is, the drying pan is also turned here so that any material, any remaining water will be completely dried before the rack is taken back inside, at which point the pan will be turned upside down so that it will be really serve the pan purpose.

522 MR. KELBERG:

Or perhaps right side up?

523 DR. LAKSHMANAN:

Yes.

524 MR. KELBERG:

Is it accurate to say that this is upside down from how the pan appears when it's being used?

525 DR. LAKSHMANAN:

Yes.

526 MR. KELBERG:

Why do you have a pan?

527 DR. LAKSHMANAN:

So that any material which is dripping from the clothing can also be collected if necessary.

528 MR. KELBERG:

And why do you need to adjust the level of the pan?

529 DR. LAKSHMANAN:

Because you have different lengths of clothing. Sometimes you have a jacket which is longer; and depending on the length of the clothing, you can adjust the level of the pan.

530 MR. KELBERG:

In a criminal homicide case at your office, doctor, how many different cases are at the same time placed in one of these drying racks?

531 DR. LAKSHMANAN:

Usually only one--clothing from one particular case is placed in the drying rack.

532 MR. KELBERG:

Why do you do that?

533 DR. LAKSHMANAN:

So that we can separate each person's clothing and--number one, and also for purposes of evidentiary preservation.

534 MR. KELBERG:

You said "Usually." Does that indicate that sometimes that is not the case?

535 DR. LAKSHMANAN:

In rare--I mean not rare. Sometimes when we have an increased number of homicide cases and we only have certain number of racks available, then the pan and--the pan--the same drying rack could be used for two decedents with the--you see, when you turn the pan upside down, there's also a hanger space available.

536 MR. KELBERG:

Underneath the pan?

537 DR. LAKSHMANAN:

Actually in the photograph, you see it above the pan. But when you turn the pan, it will serve as a drying hanger rack.

538 MR. KELBERG:

Where the arrow--Mr. Fairtlough has the arrow now, is that--

539 DR. LAKSHMANAN:

Yes, yes, yes. And so if you have two cases, sometimes we do use the same drying rack for two cases. But that's not a normal procedure.

540 MR. KELBERG:

From your review of the materials in this case, was the clothing of each of the decedents, Nicole Brown Simpson and Mr. Goldberg, placed in a separate drying ran?

541 DR. LAKSHMANAN:

Yes.

542 MR. KELBERG:

Now, doctor, what are these gurnies that are also in this photograph used for?

543 DR. LAKSHMANAN:

They are the gurnies on which the remains are placed for--in the office for purposes of examination, autopsy and storage till they are released.

544 MR. KELBERG:

And is a gurney like this used to remove the body of, for example, Mr. Goldman from the van that we've seen in the earlier photo?

545 DR. LAKSHMANAN:

Yes.

546 MR. KELBERG:

And take it somewhere?

547 DR. LAKSHMANAN:

Yes. As I said, it goes to the next adjoining room.

548 MR. KELBERG:

If we could have, Mr. Fairtlough, 09, please.

549 THE COURT:

All right. This will be People's exhibit 298.

550 MR. KELBERG:

298. Thank you, your Honor.

551 (Peo's 298 for id = photograph)
552 MR. KELBERG:

What are we looking at in this photo, 298?

553 DR. LAKSHMANAN:

You're seeing the weighing scale and height measuring device there which is leaning against the wall. The weighing scale is pretty self-evident.

554 MR. KELBERG:

Do you want to get the arrow moved somewhere, doctor?

555 DR. LAKSHMANAN:

Yes. The--could you move the arrow down, please, and--to the weighing scale? You can see the--a dial there, and then the entire floor area is the weighing scale where the gurney is moved on and the weight is taken. And of course, the weight of the gurney is adjusted so that we get the proper body weight.

556 MR. KELBERG:

And in this photograph, doctor, do you also see this measuring device?

557 DR. LAKSHMANAN:

Yes. On the left side of--on the right side of the weighing scale. Just move the arrow a little more to the right side. That--you can see that. That's the measuring device.

558 MR. KELBERG:

If you'll keep your voice up, please, doctor.

559 DR. LAKSHMANAN:

That is a measuring device.

560 MR. KELBERG:

I think we have a better picture coming up of that. How is the measurement of the body length taken?

561 DR. LAKSHMANAN:

Using that device usually from the--it's placed next to the body, and the height is taken from the feet to the top of the head.

562 MR. FAIRTLOUGH:

If we could have photo 12, please, Mr. Fairtlough.

563 MR. KELBERG:

And I think the arrow is in a pretty appropriate location. There's something in front of the scale, doctor. What is that?

564 DR. LAKSHMANAN:

That is the measuring device I mentioned earlier to take the height.

565 MR. KELBERG:

Now, doctor, is there--is there a specific numbered form on which this information is to be placed as a part of the official record of the Coroner's office for Nicole Brown Simpson and a separate one for Ronald Goldman?

566 DR. LAKSHMANAN:

Yes. They place it on the form 1 of the investigator's report. It's also recorded in the fingerprint cards.

567 MR. KELBERG:

Mr. Fairtlough? Your Honor, we have a document that's going to go up. May this be marked as I believe exhibit--it might be appropriate as 298-A.

568 THE COURT:

298-A?

569 MR. KELBERG:

Yes.

570 THE COURT:

Have you shown that to Mr. Shapiro?

571 MR. KELBERG:

They've seen them all. It's a form 1.

572 THE COURT:

All right.

573 (Peo's 298-A for id = photograph)
574 THE COURT:

Proceed. Thank you

575 MR. KELBERG:

Doctor, in general terms, if you can see, what is this document, 298-A?

576 DR. LAKSHMANAN:

It is the form 1 of the Coroner's investigator's report.

577 MR. KELBERG:

And perhaps, Mr. Fairtlough, if you could zoom in on the top portion of the document. Thank you.

578 MR. KELBERG:

Doctor, the handwritten entries that appear on the first line, Brown, Simpson, Nicole, so forth, is that information that is written in by the investigator?

579 DR. LAKSHMANAN:

Yes.

580 MR. KELBERG:

And in this case, that would be Miss Ratcliffe?

581 DR. LAKSHMANAN:

Yes.

582 MR. KELBERG:

And if we look--and perhaps--I don't know if we have an arrow available with this device. Doctor, is there a place on the form that's visible now to reflect the height and weight obtained from Miss Brown Simpson?

583 DR. LAKSHMANAN:

Yeah. The arrow's just below the weight. And if you move the arrow a little more to the--just left of--left--left of it--the other side. Other side. I'm sorry. Your right is my left. Okay. That is 65 inches. That is the height. So that's the height. And the next number you see, which you just saw, is the weight, 129 pounds.

584 MR. KELBERG:

65 inches is five feet, five inches, doctor?

585 DR. LAKSHMANAN:

Yes.

586 MR. KELBERG:

And she weighed 129 pounds?

587 DR. LAKSHMANAN:

Yes.

588 MR. KELBERG:

And the other information in general terms--

589 MR. KELBERG:

If we could back up just a bit, Mr. Fairtlough, to show the document in fuller form.

590 MR. KELBERG:

The other type of information generally that is to be placed on this document by the investigator is what?

591 DR. LAKSHMANAN:

You get the information of the next of kin. As you--as you move down further, it gives you the place of death, who pronounced the person and then you have the information on the investigating agency. And you also have the relationship of the decedent to the surroundings. Then you have information of the liver temperature, environmental temperature, and on the right side, you're seeing the description of--the opinion of the livor mortis and rigor mortis.

592 MR. KELBERG:

If Mr. Fairtlough could leave the arrow where we are right now.

593 MR. KELBERG:

Doctor, is this one of the pieces of information that you expect the investigator to observe and record to assist you in evaluating a range for time of death?

594 DR. LAKSHMANAN:

Yes.

595 MR. KELBERG:

And if Mr. Fairtlough can move the arrow down another--

596 MR. KELBERG:

Is that another aspect of the information you expect the investigator to get for this purpose?

597 DR. LAKSHMANAN:

Yes.

598 MR. KELBERG:

And if Mr. Fairtlough can turn the arrow around or move it all the way to the left of the document as we are looking at it. The other left. Thank you.

599 MR. KELBERG:

Is this the other aspect dealing with temperature measurement that you expect the investigator to obtain--that arrow is moving too quickly for me--investigator to obtain to evaluate and estimate--to evaluate and estimate range for time of death?

600 DR. LAKSHMANAN:

Yes. The environmental temperature is 70 degrees there and then the liver temperature is 82. And the other term used for environmental temperature is "Ambient temperature."

601 MR. KELBERG:

Doctor, there appears to be next to those temperature readings a column for time and column for date. Is all of this information provided by Miss Ratcliffe?

602 DR. LAKSHMANAN:

Yes.

603 MR. KELBERG:

And what is the time column expected to reflect?

604 DR. LAKSHMANAN:

It is--it reflects the time that environmental temperature was taken.

605 MR. KELBERG:

And down below under--what appears to be 1045; is that correct?

606 DR. LAKSHMANAN:

Yes. And then you have--below that is 1050 when the liver temperature was taken on Miss Brown Simpson.

607 MR. KELBERG:

And both of these were done at the scene on June 13th, 1994?

608 DR. LAKSHMANAN:

Yes.

609 MR. KELBERG:

Now, Mr. Fairtlough, if we could have page 49, please. May we have just a moment with Mr. Fairtlough?

610 (Discussion held off the record between the Deputy District Attorneys.)
611 MR. KELBERG:

Your Honor, these documents appear to contain addresses and phone numbers regarding next of kin and so forth, and Miss Clark has quite appropriately informed me of this, and I'm not certain that's information that should be a matter of public record. We are attempting to--

612 THE COURT:

All right. Do you have anything else you can do to move on because we have about three or four minutes left in our--

613 MR. KELBERG:

This was going to be basically--my understanding was, the Court was going to conclude at 12. I think if Mr. Fairtlough can just--actually, he's got tape and measure ready. So I think we're going to be able to do it. My only concern, your Honor, is in the printed exhibit 298-A, I would ask--

614 THE COURT:

We can go back and reconstruct that. I'm sure there will be no objection.

615 MR. COCHRAN:

No objection.

616 THE COURT:

All right. Proceed.

617 MR. KELBERG:

Thank you.

618 MR. KELBERG:

Now, doctor, looking at the form that's up here now--

619 MR. KELBERG:

Your Honor, may this be marked as 298-B as in boy?

620 THE COURT:

298-B.

621 (Peo's 298-B for id = form)
622 MR. KELBERG:

Is this basically the same form--

623 MR. KELBERG:

We need another quick modification. Your Honor, I think I have a simpler way to do it. We'll get the exhibit taken care of at a later time. Your Honor, may I have just this one-page document marked as 298-B?

624 THE COURT:

298-B.

625 (Peo's 298-B for id = one-page document)
626 MR. KELBERG:

May I approach again?

627 THE COURT:

You may.

628 MR. KELBERG:

Doctor, showing you 298-B, are you familiar with this document?

629 DR. LAKSHMANAN:

Yes.

630 MR. KELBERG:

In essence, is this the same form that we were just looking at, 298-A, except this time, it is to reflect the findings of Miss Ratcliffe concerning Mr. Goldman?

631 DR. LAKSHMANAN:

Yes.

632 MR. KELBERG:

Does the document reflect height and weights for Mr. Goldman?

633 DR. LAKSHMANAN:

Yes, it does.

634 MR. KELBERG:

What are they?

635 DR. LAKSHMANAN:

The height of Mr. Goldman is 69 inches and the weight is 171 pounds.

636 MR. KELBERG:

69 inches is five feet, nine inches?

637 DR. LAKSHMANAN:

That's correct.

638 MR. KELBERG:

And does this document also reflect the perimeters that you were talking about in the other document regarding time of death aspects?

639 DR. LAKSHMANAN:

Yes.

640 MR. KELBERG:

And with respect to the air or ambient and liver temperatures that we saw in the exhibit 298-A as 70 and 82 for liver, are those the readings that Miss Ratcliffe recorded for Mr. Goldberg?

641 DR. LAKSHMANAN:

Yes. But she recorded them at a different time.

642 MR. KELBERG:

What are the times of the air temperature--I believe we saw before was 10:40?

643 DR. LAKSHMANAN:

10:45 for Miss Nicole. Mr. Goldman was done at 10:35, the ambient temperature, and the liver temperature was done at 10:40. Do you want it explained further or--

644 MR. KELBERG:

Just so we have the sequence correct, that according to Miss Ratcliffe's record, Mr. Goldberg's air temperature was taken first?

645 DR. LAKSHMANAN:

Yes.

646 MR. KELBERG:

At 10:35?

647 DR. LAKSHMANAN:

That's what is recorded here.

648 MR. KELBERG:

And then his liver temperature was taken at 10:40?

649 DR. LAKSHMANAN:

Yes.

650 MR. KELBERG:

And according to 298-A, Miss Brown Simpson's air temperature, the surrounding air temperature of 70 was taken at 10:45?

651 DR. LAKSHMANAN:

Yes.

652 MR. KELBERG:

And the liver temperature was taken at 10:50; is that correct?

653 DR. LAKSHMANAN:

Yes.

654 MR. KELBERG:

Your Honor, I think that concludes.

655 THE COURT:

All right. Ladies and gentlemen, we are going to conclude the presentation of the testimony for the morning. Please remember all of my admonitions to you; do not discuss this case amongst yourselves, do not form any opinions about the case, don't allow anybody to communicate with you with regard to the case, do not conduct any deliberations until the matter has been submitted to you. As far as the jury is concerned, we will stand in recess until Monday morning at 9:00 A.M. I'll see counsel back here, Mr. Shapiro, Mr. Kelberg at 1:45 for our discussions. And let me see counsel at the sidebar with the Court reporter, please. Dr. Lakshmanan, see you Monday, 9:00 o'clock.

656 DR. LAKSHMANAN:

Thank you, your Honor.

657 THE COURT:

Thank you, sir.

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
I'm here to present truthfully and accurately the Coroner's findings on the two victims who died, Miss Nicole Brown Simpson and Ron Goldman, so that the jury can understand the Coroner's process and know the truth about all the findings and any errors which were committed by the office, acknowledge them and basically explain the cause and manner of death.
Lakshmanan frames his entire testimony around transparency and error acknowledgment — a strategic prosecution move to preemptively defuse defense attacks on Dr. Golden's autopsy work.
Dr. Lakshmanan Sathyavagiswaran
He has made some mistakes, yes.
The prosecution's own witness openly concedes that Dr. Golden made errors in the autopsies — a significant admission that sets the stage for the rest of the testimony.
Dr. Lakshmanan Sathyavagiswaran
You only have one shot at doing a thorough job, you need to document all the injuries completely and thoroughly the first time you do the autopsy.
Establishes the standard of care for forensic autopsies — a benchmark against which Golden's work will implicitly be measured.
Dr. Lakshmanan Sathyavagiswaran
I passed geriatrics the third time and internal medicine the third time.
A candid admission that humanizes the witness and preempts cross-examination on the same point — Kelberg elicits it himself to blunt the impact.

Evidence (1)

People's 295
Nine-page curriculum vitae of Dr. Lakshmanan Sathyavagiswaran
Marked for identification and shown to witness for authentication

Notable Exchanges (2)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg points out that Dr. Michael Badin — seated in the courtroom behind defense counsel Kardashian — was someone Lakshmanan knew from his time at the New York Chief Medical Examiner's office in the 1970s, where Badin was Deputy Chief. This quietly establishes that the prosecution's expert and defense's expert share professional history.
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg asks Lakshmanan how he feels about testifying against a colleague and personal friend (Golden). Lakshmanan's answer — volunteering that the office made errors and he is here to acknowledge them — draws an objection and a motion to strike from Shapiro, both overruled.
revealing

Light Moments (3)

Brian Kelberg
Lakshmanan spells out his full name for the record — L-A-K-S-H-M-A-N-A-N S-A-T-H-Y-A-V-A-G-I-S-W-A-R-A-N — and Kelberg immediately negotiates permission for everyone to just call him 'Dr. Lakshmanan,' noting 'a lot of us will be a lot happier for allowing us to do that.'
Brian Kelberg
After Lakshmanan repeatedly interrupts Kelberg's questions with answers, Kelberg gently asks him to wait until the question is finished: 'I think it will help if you wait until I finish my question, and I'll try and do the same with your answer.'
Brian Kelberg
Kelberg accidentally calls Ron Goldman 'Ronald Golden' mid-question, catching himself: 'Ronald Golden — Goldman. Excuse me.'

Credibility Attacks (1)

⚔ Dr. Lakshmanan Sathyavagiswaran
Preemptive self-disclosure by prosecution
Kelberg himself elicits that Lakshmanan failed the internal medicine and geriatrics board exams on the first two attempts, passing on the third try — a classic inoculation technique to prevent the defense from using it more damaging on cross.

Objections

5 objections (1 sustained, 4 overruled)
Proceeding 6266 • 657 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 2, 1995 📄 Direct examination of Dr. Laks
JUN 2, 1995 KRT DvH TD