📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 3) — Tuesday, June 6, 1995
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C:\DEPT103\CRIMINAL\1995\JUN\6\DIRECT-EXAMINATION-OF-DR-LAKSH.DOC
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▲ Day 89 of 167

Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 3)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Tuesday, June 6, 1995 • Utterances: 448
Kelberg continues his methodical direct examination of Dr. Lakshmanan, walking through autopsy instruments, specimen collection containers, and Coroner's office paperwork forms using a series of photographs and paper exhibits. The session establishes standard autopsy protocols while surfacing two documented errors by Dr. Golden: mislabeling Ron Goldman's bile specimen as urine, and failing to mark the fingernail scraping envelope — though Dr. Lakshmanan opines neither error affects his overall conclusions.
1 (The following proceedings were held in open court, in the presence of the jury:)
2 THE COURT:

Thank you, ladies and gentlemen. Please be seated. Good afternoon, ladies and gentlemen.

THE JURY: Good afternoon.

3 THE COURT:

I need for all of you to stay healthy. All right. Let the record reflect that we have been rejoined by all the members of our jury panel. Dr. Lakshmanan is again on the witness stand undergoing direct examination by Mr. Kelberg. And Mr. Kelberg, you may resume with your direct examination.

Lakshmanan Sathyavagiswaran, the witness on the stand at the time of the noon recess, resumed the stand and testified further as follows:

4 MR. KELBERG:

Thank you, your Honor. I have another photograph I'm going to ask Mr. Fairtlough to put on because I want zoom capability. And I ask, your Honor, this be marked as photograph 324, People's exhibit 324.

5 THE COURT:

All right. People's 324.

6 (Peo's 324 for id = photograph)
7 MR. KELBERG:

Now, doctor, we were talking about the autopsy room, and I want you to look at this photograph, People's 324 and tell us what is shown in this particular photograph.

8 DR. LAKSHMANAN:

This is the autopsy instrument tray with the instruments set up in the manner which the doctor has available before he or she starts the autopsy.

9 MR. KELBERG:

Who sets up this tray?

10 DR. LAKSHMANAN:

The autopsy technicians at the Coroner's office.

11 MR. KELBERG:

And this is already in place at the time the medical examiner, like Dr. Golden, is going to begin the autopsy?

12 DR. LAKSHMANAN:

Yes.

13 MR. KELBERG:

Doctor, are these instruments sterilized?

14 DR. LAKSHMANAN:

No. They are washed.

15 MR. KELBERG:

Is there any reason why they are not sterilized?

16 DR. LAKSHMANAN:

Well, we have an autoclave, but it is not used that often, but it is just washed and cleaned.

17 MR. KELBERG:

Is the fact that these people are dead of consequence as to why you do not need or do not at least use the autoclave to sterilize your instruments on a routine basis?

18 DR. LAKSHMANAN:

That is one reason.

19 MR. KELBERG:

Doctor, if we can get Mr. Fairtlough to work our arrow for us and kind of go top to bottom in the tray and ask you if you can just basically tell us what each of the instruments is. Perhaps we could start what looks to be some kind of knife with a white handle and start with that and work our way down.

20 DR. LAKSHMANAN:

That is a large knife which is used to cut the larger organs in the body.

21 MR. KELBERG:

What is it used for?

22 DR. LAKSHMANAN:

It is a larger knife which is used to cut the larger organs in the body like the brain and the liver, the lung, et cetera.

23 MR. KELBERG:

What do you mean by "Cut" those?

24 DR. LAKSHMANAN:

Initially the autopsy process involves examination of the organs inside or in the body to see the relationship and also the--any injuries. And then when the organ is removed from the body, you serial section the organ to look for preexisting disease process in the organ, and this instrument is used for that purpose when you make the serial sectioning of the organs.

25 MR. KELBERG:

What do you mean by "Serial sectioning"?

26 DR. LAKSHMANAN:

Cutting them like you cut a bred loaf so that you can study the cross-section of the organ.

27 MR. KELBERG:

Going from outside to inside?

28 DR. LAKSHMANAN:

Yes.

29 MR. KELBERG:

And is there any custom or practice as to how many, I hate to use the term slices, of the organ the medical examiner takes in making that kind of examination with respect to these organs?

30 DR. LAKSHMANAN:

Well, there is a minimum--I mean, there is no specific number as long as the organ is adequately examined. Some areas may require more sectioning than others, but it is the medical examiner's decision on that.

31 MR. KELBERG:

It is the medical examiner's decision?

32 DR. LAKSHMANAN:

Decision.

33 MR. KELBERG:

If Mr. Fairtlough could move the arrow to the left and stop where he has, what are we looking at now, doctor?

34 DR. LAKSHMANAN:

That is a piece of plastic bulbous syringe which is used to collect urine.

35 MR. KELBERG:

Where is the urine collected from?

36 DR. LAKSHMANAN:

The urinary bladder.

37 MR. KELBERG:

That collection is performed by the Deputy Medical Examiner like Dr. Golden?

38 DR. LAKSHMANAN:

Yes, and sometimes by the autopsy technician who is assisting the doctor.

39 MR. KELBERG:

Now, it appears, if Mr. Fairtlough could move the arrow toward the bulb end of that syringe, is that resting in something, doctor?

40 DR. LAKSHMANAN:

Yes. That is a ladle.

41 MR. KELBERG:

Like a soup ladle?

42 DR. LAKSHMANAN:

Yes.

43 MR. KELBERG:

What is it used for?

44 DR. LAKSHMANAN:

Well, that is used for several purposes; to remove blood accumulating to the chest cavities, used to remove any of the fluid accumulations and to also have a volume estimation of the fluids removed as they are being removed, and it is also washed and sometimes used to estimate the volume of the stomach contents.

45 MR. KELBERG:

The volume of the stomach contents?

46 DR. LAKSHMANAN:

Yes.

47 MR. KELBERG:

What is the size of that ladle?

48 DR. LAKSHMANAN:

The ladles we have in our office is six-ounce ladles, six-ounce capacity.

49 MR. KELBERG:

And in cases like Ronald Goldman and Nicole Brown Simpson would you expect there to be free blood inside of each of these person's bodies as a result of the injuries received?

50 DR. LAKSHMANAN:

Especially in Mr. Goldman, he had evidence of bleeding into the abdominal cavity and chest cavity, so there was evidence of blood accumulation in the cavities of Mr. Goldman.

51 MR. KELBERG:

Would you expect then this ladle to be used to measure the quantity of blood found in that area?

52 DR. LAKSHMANAN:

Approximately, yes.

53 MR. KELBERG:

Now, doctor, you mentioned it can also be used to estimate the volume of the stomach contents; is that correct?

54 DR. LAKSHMANAN:

Yes.

55 MR. KELBERG:

Assuming that this ladle is used to measure the volume of blood, and it is also going to be used to measure the stomach contents, would you expect it to be washed between the two procedures?

56 DR. LAKSHMANAN:

Yes.

57 MR. KELBERG:

Why is that?

58 DR. LAKSHMANAN:

Because you don't want cross-contamination of the blood material with the gastric contents.

59 MR. KELBERG:

What do you do as a medical examiner with any blood that is ladled out of the inside of the body?

60 DR. LAKSHMANAN:

One--sometimes you--you need to collect the blood for toxicology, and when you open the heart, sometimes the blood is collected from the heart in the ladle and placed in the blood bottle. The situations where you are removing blood and blood clots from a cavity, you place it in a tray until you--so you can assess the volume and sometimes in a case of a firearm injury or a gunshot wound which has entered the chest cavity, the bullets can be in the blood clot--in the blood which is accumulated in the chest cavity, so it is important to save all the blood which is removed from the cavity, in addition to measuring the volume, but also to have it available to retrieve any projectiles which may have finally come to rest in the blood clot in the chest cavity.

61 MR. KELBERG:

Doctor, are there, prepared for the use of the medical examiner, vials of various types to collect these kind of specimens?

62 DR. LAKSHMANAN:

Yes.

63 MR. KELBERG:

And I think we have a photo that we are going to get to in a moment, but for our present purposes, with respect to the stomach contents that may be measured with this, what happens to those stomach contents?

64 DR. LAKSHMANAN:

They are placed--first of all, the doctor records the--the character, the gross examination, and also the amount, and it is placed in a container earmarked for collection of such contents and we have a plastic jar which is used for that purpose.

65 MR. KELBERG:

We are going to talk about stomach contents a good deal later on. Is there anything else that this ladle is used for?

66 DR. LAKSHMANAN:

Basically for these two purposes; removing of fluids, collections, give an estimation of the approximate volume.

67 MR. KELBERG:

If we could have Mr. Fairtlough move the arrow down, there appears to be perhaps the end of a knife where it is right now. Do you see that, doctor?

68 DR. LAKSHMANAN:

Yes, it is a smaller knife and that is usually used for--removal of the neck organs and other dissections as the doctor may feel it is necessary during his dissection or her dissection.

69 MR. KELBERG:

Incidentally, doctor, how frequently are these knives, such as the top one that you identified and the one you are looking at now, how frequently are they sharpened?

70 DR. LAKSHMANAN:

They are supposed to be sharpened everyday or as needed. Whenever the doctor gives an opinion that they are dull, then the technician will have it sharpened.

71 MR. KELBERG:

But this would be a knife used to dissect in the neck area of a person like Nicole Brown Simpson?

72 DR. LAKSHMANAN:

It is used more to remove the neck organs after initial inspection.

73 MR. KELBERG:

What are the--I'm sorry. What are the neck organs are you talking about?

74 DR. LAKSHMANAN:

Neck organs, in our office usually we remove the tongue, also inclusive with the larynx and hyoid and pharynx and esophagus together en bloc after having done the dissection of the chest cavity and the head.

75 MR. KELBERG:

Is this knife used for any other purposes?

76 DR. LAKSHMANAN:

As I told you, for dissection of any organ which the doctor feels more comfortable using the smaller knife.

77 MR. KELBERG:

Now, if we could move the arrow to the right a bit where Mr. Fairtlough has it, what are we looking at now?

78 DR. LAKSHMANAN:

That is a kind of a plier like instrument which can be used to strip the pleura.

79 MR. KELBERG:

What is the pleura?

80 DR. LAKSHMANAN:

The pleura is the lining of the inner surface of the chest cavity, also like a lining which also covers the lung and the chest cavity and it forms a kind of potential space between the chest wall and the lung and there is fluid in the pleural cavity and this allows free movement of the lung during breathing.

81 MR. KELBERG:

What other uses, if any, does this particular plier like instrument have?

82 DR. LAKSHMANAN:

Sometimes to open the rib cage after you make an incision and also to--when you remove projectiles from the spine, sometimes when you make cuts it is easier to open up the bone to get the bullet out.

83 MR. KELBERG:

You indicated open up the rib age. How is that done?

84 DR. LAKSHMANAN:

We have a different pair of--it can be done in two process; either by a saw or by a shear. We have a shear which is used to open up the rib cage.

85 MR. KELBERG:

Doctor, is either the saw or the shear shown in this photograph?

86 DR. LAKSHMANAN:

No.

87 MR. KELBERG:

The saw that is used, does it have the appearance of a hacksaw?

88 DR. LAKSHMANAN:

Not exactly a hacksaw. It is more like an electrically power driven saw. We didn't take a picture of it, but it is similar to the saw used in orthopedics to remove a cast.

89 MR. KELBERG:

And the shears that are used, are they similar in nature to pruning shears that one might have around the garden?

90 DR. LAKSHMANAN:

Yes.

91 MR. KELBERG:

Now, doctor, these are not very sophisticated tools it appears; is that correct?

92 DR. LAKSHMANAN:

Well, they are regular--similar to surgical instruments which are used, at least the scalpel and the scissors and forceps part of it.

93 MR. KELBERG:

And in order to get to the internal organs, is the saw or the pruning shears required?

94 DR. LAKSHMANAN:

Yes, because after you reflect the skin and subcutaneous soft tissues to open up the chest cavity, you need to open up the rib cage to do that, to enter the chest cavity.

95 MR. KELBERG:

And was that done in both of the cases here?

96 DR. LAKSHMANAN:

Yes.

97 MR. KELBERG:

Now, doctor if we could move down to the next instrument, what are we looking at?

98 DR. LAKSHMANAN:

You have a forceps and then you have a ruler, which is being pointed to.

99 MR. KELBERG:

The ruler--let's start with the forceps. What is the purpose of that instrument?

100 DR. LAKSHMANAN:

Usually to pick up structures before you dissect them and also during dissection you need the forceps so that you can be up open a vessel or open up a bronchial area in the lung, depending on what structure you are dissecting. Basically these are dissecting instruments.

101 MR. KELBERG:

Those look like big tweezers. Would that be an analogy?

102 DR. LAKSHMANAN:

You could use that analogy, but these are forceps actually.

103 MR. KELBERG:

You prefer that term?

104 DR. LAKSHMANAN:

Yes.

105 MR. KELBERG:

All right. Now, the measuring device that is under there, is that different than what you were mentioning before, this blue card that appears in the photographs?

106 DR. LAKSHMANAN:

That's correct. This is a scientific ruler which gives measurements both in inches and centimeters.

107 MR. KELBERG:

And how is that used, if at all, by the medical examiner?

108 DR. LAKSHMANAN:

They could be used for a variety of purposes, from measuring the injuries of the body surface, to measuring valve circumferences when the heart is dissected.

109 MR. KELBERG:

Valve circumferences?

110 DR. LAKSHMANAN:

Yes.

111 MR. KELBERG:

Incidentally, you mentioned the ladle taking blood from the heart. Is there in cases such as Nicole Brown Simpson and Ronald Goldman, a typical location where blood is collected from?

112 DR. LAKSHMANAN:

Usually you open up the--the--either the inferior vena cavity radial junction and after removing the pericardial fluid you allow the blood to accumulate in the pericardial sac and you retrieve the blood which is placed in the bottle which is earmarked for collection of blood. And then the ladle can be used for the transfer, but we also provide the doctors with a plastic syringe which is to remove the blood and subject in the serology tube which is the EDTA tube.

113 MR. KELBERG:

Doctor, first of all, what is the pericardial sac?

114 DR. LAKSHMANAN:

The pericardial sac is the covering over the cavity. Just like the pleural cavity covers the lung, you have the pericardial sac covering the heart.

115 MR. KELBERG:

Why do you choose that location to collect your blood supply?

116 DR. LAKSHMANAN:

Because you have a sac-like structure there and once you--always the pericardial sac has some fluid. Once you take the fluid out, you have kind of a sac-like structure available for the blood to be collected from.

117 MR. KELBERG:

What is the purpose of the--of collecting blood from that location?

118 DR. LAKSHMANAN:

Well, you get heart blood from the heart when do you this collection in this manner.

119 MR. KELBERG:

And what, if any, purpose will that supply of blood serve?

120 DR. LAKSHMANAN:

We save blood for--usually for toxicological purposes and the blood we collect is placed in sodium fluoride.

121 MR. KELBERG:

What is toxicological purposes?

122 DR. LAKSHMANAN:

Study for drugs and poisons.

123 MR. KELBERG:

Do drugs include blood alcohol levels?

124 DR. LAKSHMANAN:

Yes.

125 MR. KELBERG:

And this is collected by either the ladle or you say a syringe?

126 DR. LAKSHMANAN:

The syringe is used for the serology tube because the syringe is a 10 cc syringe.

127 MR. KELBERG:

And I think we have a picture of that coming up.

128 DR. LAKSHMANAN:

Okay.

129 MR. KELBERG:

Anything further, back on this measuring device, that you haven't covered?

130 DR. LAKSHMANAN:

No, no. It is just a ruler used to measure any structure the doctor wants to measure.

131 MR. KELBERG:

If we could move to the right, Mr. Fairtlough, this next instrument?

132 DR. LAKSHMANAN:

That is a scissor.

133 MR. KELBERG:

What is that used for, doctor?

134 DR. LAKSHMANAN:

Dissection.

135 MR. KELBERG:

In what fashion?

136 DR. LAKSHMANAN:

As I told you, to open up vessels or dissect a particular bronchus, any tubular structure to open up.

137 MR. KELBERG:

And for example--opening up the stomach, the esophagus, anything, wherever you need to open up a hollow tubular structure.

138 MR. KELBERG:

Would substance or structures like the carotid artery be the kind of thing that could be opened up with that type of scissor?

139 DR. LAKSHMANAN:

It could be used for that.

140 MR. KELBERG:

Is that a blunt end or a sharpened type of scissor?

141 DR. LAKSHMANAN:

That looks like a sharp-ended scissor. You would like to use the--you like to use the scissor which has a blunt and a sharp blade to it so that the blunt end could be used for the blunt part of the dissection and then the sharpened to make the final cuts.

142 MR. KELBERG:

Why do you want "A blunt end"?

143 DR. LAKSHMANAN:

This way you do not cause false nicks in the intima vessel, which is the inner lining of the carotid artery.

144 MR. KELBERG:

Anything else that that is used for?

145 DR. LAKSHMANAN:

Basically as I told you.

146 MR. KELBERG:

Doctor, I can't tell, is there an instrument to the right, kind of underlying the handle of the scissors that we were looking at?

147 DR. LAKSHMANAN:

Yes. That is a chisel which is used in the opening of the skull of the decedent.

148 MR. KELBERG:

How is the chisel used to do that?

149 DR. LAKSHMANAN:

The electric saw is used to open the--first of all, the scalp is reflected and the skull is opened with the help of an electric saw and the electric saw usually cuts through the whole thickness of the skull, but after the saw has been used you use the chisel to pry open the skull so that you can examine the dura and the cranial contents in a proper manner.

150 MR. KELBERG:

When you say the "Cranial contents," the brain?

151 DR. LAKSHMANAN:

Yes, and the coverings of the brain.

152 MR. KELBERG:

Doctor, when you say "Pry open," is there like a hammer or something that goes with that chisel?

153 DR. LAKSHMANAN:

No. If the saw has been used properly, the chisel should be able to separate the sawed area so that you can easily open the skull like a cap then examine the cranial contents.

154 THE COURT:

Mr. Kelberg, may I see you and Mr. Shapiro for a moment, please, without the reporter.

155 (A conference was held at the bench, not reported.)
156 (The following proceedings were held in open court:)
157 THE COURT:

Thank you, counsel.

158 MR. KELBERG:

Thank you, your Honor.

159 MR. KELBERG:

Doctor, if we could get the arrow back and move to the last three instruments I think that are there. There are two instruments that appear similar in nature where Mr. Fairtlough has the arrow. What are those?

160 DR. LAKSHMANAN:

Scalpel blades.

161 MR. KELBERG:

And what is their purpose?

162 DR. LAKSHMANAN:

Their purpose is to help in opening up the body and any other dissection and sectioning of tissues necessary for storage.

163 MR. KELBERG:

And the last instrument--I think it is the last instrument in this photograph, is it, doctor?

164 DR. LAKSHMANAN:

Yes.

165 MR. KELBERG:

What is that?

166 DR. LAKSHMANAN:

That is a larger scissor which is constructed in a manner which has a--which can be used to open the intestines.

167 MR. KELBERG:

Why is that done, to open the intestines?

168 DR. LAKSHMANAN:

To study the intestinal contents.

169 MR. KELBERG:

What significance does that have on a routine basis?

170 DR. LAKSHMANAN:

You have to examine the intestine, not only to see the contents but also to see the lining of the intestine to see if there is any disease process, like you can have cancer, you can have diverticulitis, because the colon and intestines have normal disease processes which can only be found if you open the intestine.

171 MR. KELBERG:

Now, Mr. Fairtlough if I can exchange photographs with you, I think we need this one to focus this as well.

172 THE COURT:

This will be People's 325.

173 MR. KELBERG:

325 I believe, your Honor.

174 (Peo's 325 for id = photograph)
175 MR. KELBERG:

Perhaps if you can pull it back a little bit.

176 MR. KELBERG:

Doctor, what are we looking at in this photograph?

177 DR. LAKSHMANAN:

These are the containers set up before an autopsy for a full toxicology and tissue saving during the autopsy. You have two glass bottles on the left side which are used to collect urine and bile, if available. Then you have two other plastic containers. One is used for collecting of stomach contents; another one is used for collecting liver specimen, if necessary. The next jar is a plastic jar which has formalin in it and this is to remove representative sample of tissue and preserve it in formalin so that any microscopic studies, if performed, the tissue would be available, and this is the jar containing tissue which is saved after an autopsy.

178 MR. KELBERG:

Would this be a jar that would be used, for example, to save representative sections of the brains of the decedent?

179 DR. LAKSHMANAN:

Yes.

180 MR. KELBERG:

And each of the items that you've identified so far in the photograph appear to have a band around the item. Do you see that?

181 DR. LAKSHMANAN:

Yes. Those are the labels used in the Coroner's office, and depending on what item is collected, you mark the box. If it is urine, you mark the urine box. If it is bile, you mark the bile box, et cetera.

182 MR. KELBERG:

If Mr. Fairtlough could switch for a moment to photo 53, and I would ask, your Honor, it be marked as 326.

183 (Peo's 326 for id = photograph)
184 THE COURT:

All right. Next photo, 326.

185 MR. KELBERG:

Doctor, are you familiar with what is shown in this photograph?

186 DR. LAKSHMANAN:

Yes. This is the label which is the white structure you saw pasted on order those bottles and plastic containers, and depending on what the specimen is, if the arrow can go down, you mark the box. Suppose you had had the same label on the plastic container which you collect the gastric contents, you would naturally mark the box for the stomach. Now, on the lower part you have histopathology and that part is completed if you have the same label on the jar which has the formalin in it, so--and there we have three boxes there, which are self-explanatory.

187 MR. KELBERG:

Doctor, whose responsibility is it to check the box that corresponds to what is going to be in the container?

188 DR. LAKSHMANAN:

The doctor and the technician. The doctor has to also initial the containers after they remove the specimen.

189 MR. KELBERG:

Now, you say the responsibility is on both individual, the doctor and the technician?

190 DR. LAKSHMANAN:

If it is ultimately the medical doctor's responsibility to mark the box or make sure it is marked.

191 MR. KELBERG:

Now, in this particular case, involving both Nicole Brown Simpson and Ronald Goldman, did you find, after your meeting or in the course of your meeting with Dr. Baden, that there had been a mistake made in labeling?

192 DR. LAKSHMANAN:

Yes.

193 MR. KELBERG:

What was the mistake you identified?

194 DR. LAKSHMANAN:

This was the bile container that was--was marked as urine.

195 MR. KELBERG:

What--

196 DR. LAKSHMANAN:

I would have to refer to my notes to remember which decedent it was, that mistake.

197 MR. KELBERG:

Could you do that, and while you are doing that, if Mr. Fairtlough could go back to the photograph that has the jars, which is our exhibit 325.

198 DR. LAKSHMANAN:

(Witness complies.) the specimen was that of Mr. Ron Goldman where the bile specimen was saved, but the bottle label was marked as urine.

199 MR. KELBERG:

Doctor, as a forensic pathologist can you easily distinguish bile from urine?

200 DR. LAKSHMANAN:

Certainly.

201 MR. KELBERG:

How?

202 DR. LAKSHMANAN:

One is a light amber yellowish color. The bile is thick greenish black in color and anybody can tell the difference between bile and urine.

203 MR. KELBERG:

Anybody who is a forensic pathologist?

204 DR. LAKSHMANAN:

Yes.

205 MR. KELBERG:

All right. Doctor, there is a mistake that was made; is that correct?

206 DR. LAKSHMANAN:

Yes.

207 MR. KELBERG:

And in your opinion is this mistake ultimately the responsibility of Dr. Golden?

208 DR. LAKSHMANAN:

Yes.

209 MR. KELBERG:

In your opinion does this mistake affect in any way your ability to answer the issues that you have reviewed for your testimony here today?

KEY QUOTE
210 DR. LAKSHMANAN:

No.

211 MR. KELBERG:

Were there any other mistakes in labeling that were found in the course of either your meeting on June 22nd with Dr. Baden or any other review?

212 DR. LAKSHMANAN:

We already discussed the mistake of the non-marking of the fingernail kit envelope in which the scrapings were not marked outside as though they had been taken, even though they had been taken, and that is one mistake, I remember, and this one.

213 MR. KELBERG:

Which of these jars or cups was it in type, that is, which had the bile mistakenly labeled as urine?

214 DR. LAKSHMANAN:

This is Mr.--the glass bottles, the jar which is used for collection of urine and bile. That would be--go to the left.

215 MR. KELBERG:

Mr. Fairtlough?

216 DR. LAKSHMANAN:

The left. That jar, that would be the jar which would be marked incorrectly.

217 MR. KELBERG:

Was urine found to have been collected as well in this case?

218 DR. LAKSHMANAN:

Only bile was collected.

219 MR. KELBERG:

Is it customary in cases such as this to collect urine?

220 DR. LAKSHMANAN:

If it is available and if the doctor thinks it is indicated. The collection of toxicology on cases is up to the physician, because we only collect toxicology if we need it for the cause and manner of death.

221 MR. KELBERG:

And in your opinion, from the review of all of the materials you have reviewed which we will identify later, was urine necessary for the answers to those questions?

222 DR. LAKSHMANAN:

No.

223 MR. KELBERG:

Now, doctor, if we could have Mr. Fairtlough move the arrow down to that and maybe move the photograph, actually, so we will center it on the item at the far right. And that is item--and maybe we can get the arrow going the other way. Maybe we can just move it to the--their we go. Doctor, what is this series of materials?

224 DR. LAKSHMANAN:

You have a blood bottle and that is the bottle which contains sodium fluoride and--

225 MR. KELBERG:

Incidentally, why do you have sodium fluoride in the bottle?

226 DR. LAKSHMANAN:

That is a preservative which is used when we collect blood and in it is certain enzymes which prevent conversion of some drugs which may be present. For example, there is the enzyme cholinesterase, C-H-O-L-I-N-E-S-T-E-R-A-S-E, which is present in the blood which can metabolize some of the drugs sometimes and the sodium fluoride also inhibits that and is also used as a preservative.

227 MR. KELBERG:

Why don't you want these enzymes to be able to metabolize the drugs?

228 DR. LAKSHMANAN:

Because you have postmortem conversion of common drug which I can give you an example is cocaine which can be converted to benzoylecgonine.

229 MR. KELBERG:

Benzoylecgonine?

230 DR. LAKSHMANAN:

Yes, and this sodium fluoride will inhibit this enzyme.

231 MR. KELBERG:

And is the preservative aspect of the sodium fluoride, what is that intended to do then?

232 DR. LAKSHMANAN:

Basically inhibits the enzyme and prevents such conversions.

233 MR. KELBERG:

And is this the blood that can be tested for alcohol, for example?

234 DR. LAKSHMANAN:

Yes.

235 MR. KELBERG:

And in fact in the case of both Mr. Goldman and Ms. Brown Simpson were their blood samples tested for blood alcohol levels?

236 DR. LAKSHMANAN:

Yes, and also drugs.

237 MR. KELBERG:

Now, what are the other two devices or materials that are rubberbanded around this big vial?

238 DR. LAKSHMANAN:

This is the serology tube and that contains EDTA which is--

239 MR. KELBERG:

What is EDTA?

240 DR. LAKSHMANAN:

Ethyline Diamine Tetra Acetate Acid. It is a calcium chelating agent. It basically prevents clotting of blood in the tube.

241 MR. KELBERG:

Why do you want to prevent that?

242 DR. LAKSHMANAN:

Because it is used for serological analysis and for serological analysis you need unclotted blood.

243 MR. KELBERG:

Serological analysis, I believe there has been a lot testimony during the last few weeks on serology and so forth, but basically, for the record, is this basically to test their blood types, for example?

244 DR. LAKSHMANAN:

Yes.

245 MR. KELBERG:

This is a tube commercially provided to the Coroner's office which is also prepared with the EDTA in the tube?

246 DR. LAKSHMANAN:

Yes.

247 MR. KELBERG:

What about the label that is around it? Is that already provided in the commercially-provided vial?

248 DR. LAKSHMANAN:

No. That label is supplied from our office, and the next structure next to it is the syringe I was talking to you about, a plastic syringe.

249 MR. KELBERG:

This syringe then is to take blood from the pericardial sac as you identified earlier?

250 DR. LAKSHMANAN:

Yes.

251 MR. KELBERG:

And place it in where?

252 DR. LAKSHMANAN:

Into this test-tube.

253 MR. KELBERG:

And then what happens with the test-tube?

254 DR. LAKSHMANAN:

Then the stopper is placed, the label is properly completed.

255 MR. KELBERG:

By whom?

256 DR. LAKSHMANAN:

By the doctor, and the name is already previously imprinted. The doctor checks the correctness of the number and the name and also initials the tube.

257 MR. KELBERG:

When you say "The number," are we talking about this individualized number that the Coroner's office assigns on each case?

258 DR. LAKSHMANAN:

Yes.

259 MR. KELBERG:

Mr. Fairtlough, if we could move to photo 70, please.

260 (Brief pause.)
261 MR. KELBERG:

And I think--is there any possibility, Mr. Fairtlough, of perhaps turning this to the right ninety degrees?

262 (Discussion held off the record between the Deputy District Attorneys.)
263 MR. KELBERG:

Before we do that, doctor, what is this--I would ask, your Honor, this be marked as 327.

264 (Peo's 327 for id = photograph)
265 DR. LAKSHMANAN:

This is the label that goes on the test-tube which we just discussed and it has got the date, the DME's name and the name of the decedent there, I think.

266 MR. KELBERG:

Let me pull out the photograph just so we can perhaps have it a little clearer. Your Honor, I don't know if the Court wants this marked as a separate sub exhibit or will be satisfied with the first photo printout?

267 THE COURT:

The first photo will be fine.

268 DR. LAKSHMANAN:

Basically the space on the--the empty space is used for the imprinting of the card with the name and number and the date, the DME's name and whether the blood was taken from the heart or cavity. Sometimes if a person has had injuries which have caused a lot of bleeding, you may not have any blood in the heart available, as it happened in Mr. Ron Goldman. Dr. Golden submitted the right pleural blood for toxicology.

269 MR. KELBERG:

When you say--I'm sorry?

270 DR. LAKSHMANAN:

So in that situation the other will be completed as right pleural blood.

271 MR. KELBERG:

In Mr. Goldman's case, from your review of the materials, there was not sufficient blood available in the pericardial sac?

272 DR. LAKSHMANAN:

Not in the pericardial sac, the heart.

KEY QUOTE
273 MR. KELBERG:

In your opinion why was that?

274 DR. LAKSHMANAN:

Because he had a lot of injuries which caused significant bleeding and so the blood from the chest cavity was submitted.

275 MR. KELBERG:

And is that a standard procedure in cases such as this?

276 DR. LAKSHMANAN:

Yes, because as long as the chest cavity is separated from the abdominal cavity, and the--there is no evidence of injury to the gastrointestinal track communicating with the blood collected, we have used it. And in this case this was collected but the key thing is to mark the origin from where you collected the blood and that is why we have the other box that says the word "Other" there.

277 MR. KELBERG:

And then to write in where that other location was?

278 DR. LAKSHMANAN:

Yes.

279 MR. KELBERG:

Thank you, Mr. Fairtlough. And if we could have photo 58, please. And your Honor, I would ask this be marked as exhibit 328.

280 THE COURT:

328.

281 (Peo's 328 for id = photograph)
282 MR. KELBERG:

Doctor, what are we looking at in this photograph?

283 DR. LAKSHMANAN:

This is the--a room which is an extension from the evidence room where the evidence custodian stores the evidence in the Coroner's office. What you are seeing is different shelves containing bags of clothing from different decedents, each separately labeled and packaged. Of course the clothing in all these decedents have been previously dried in the process I already explained and they are stored there until they have been retrieved by a law enforcement agency.

284 MR. KELBERG:

And do all of them appear to have the same kind of packaging or do some have like a clear plastic to the outside and others appear to have a brown wrapping?

285 DR. LAKSHMANAN:

They have a browning wrapping, but some of them also have another meshed sheet around them.

286 MR. KELBERG:

What is the purpose of that?

287 DR. LAKSHMANAN:

The--the reason is to separate out the--the brown paper covered clothing from each other in bag manner because sometimes there is soaking of the paper also sometimes.

288 MR. KELBERG:

Why doesn't each of those packages have that netting around the outside then?

289 DR. LAKSHMANAN:

Only some of them have.

290 MR. KELBERG:

Why don't they all?

291 DR. LAKSHMANAN:

Some of them are older specimens, I think. Some of them are the newer ones.

292 MR. KELBERG:

In other words, you remove the netting at some point in time?

293 DR. LAKSHMANAN:

Yes, and then you open up the brown paper cover and look at the clothing, you have to look at the evidence, like we did with Dr. Baden and Dr. Wolf.

294 MR. KELBERG:

Mr. Fairtlough, could we have photo 81, please, and your Honor, I ask that this be marked as 329.

295 THE COURT:

329.

296 (Peo's 329 for id = photograph)
297 MR. KELBERG:

What are we looking at here, doctor?

298 DR. LAKSHMANAN:

These are the freezers and refrigerators where we store our serological samples and blood swatches.

299 MR. KELBERG:

The serological samples, that is like that EDTA tube?

300 DR. LAKSHMANAN:

Yes.

301 MR. KELBERG:

And where is that stored? Freezer, refrigerated, where?

302 DR. LAKSHMANAN:

The EDTA tube is stored in the refrigerator. The blood swatch is stored in the freezer.

303 MR. KELBERG:

And the blood swatch is prepared from what?

304 DR. LAKSHMANAN:

The EDTA tube of blood.

305 MR. KELBERG:

And in this particular case were blood swatches prepared from blood collected from each of the decedents?

306 DR. LAKSHMANAN:

Yes.

307 MR. KELBERG:

And then they are stored in the freezer; is that correct?

308 DR. LAKSHMANAN:

That's correct.

309 MR. KELBERG:

And is the first--if Mr. Fairtlough moves the arrow to the right, is this first item a freezer, top to bottom?

310 DR. LAKSHMANAN:

Yes.

311 MR. KELBERG:

And then what are these additional things as we go down the line?

312 DR. LAKSHMANAN:

They are refrigerators also present where we store the EDTA specimens, serological tubes.

313 MR. KELBERG:

What happens then if somebody--well, let me withdraw the question if I might, your Honor. Assuming toxicology is going to be done, for example, for alcohol or drugs, what is the process? Does that blood sample go to toxicology first and then come back down or does toxicology get the sample from the refrigerator? How does it work?

314 DR. LAKSHMANAN:

This area is not for storing toxicological specimens. The toxicology is stored in a different area. We have a section on the second floor of our office and also in the service level we have a separate refrigerated area for toxicological specimens which is the bile, the stomach contents and blood bottles. This area is mainly for the swatches and EDTA tubes.

315 MR. KELBERG:

And doctor, assuming that law enforcement wants to obtain those samples that are being either refrigerated or frozen, would this be the area from which they would be obtained?

316 DR. LAKSHMANAN:

Yes. The evidence custodian who releases the evidence would release those serological samples.

317 MR. KELBERG:

Let me go back on toxicology. Wherever the blood sample ends up in this other location or locations you mentioned, what is the procedure? Is toxicology done first? That is, after the blood is collected in the appropriate bottle with the sodium fluoride preservative, does it go immediately for toxicology testing or does it go someplace else?

318 DR. LAKSHMANAN:

The tox--the blood sample goes to the toxicology lab, as I said, in the areas which I already discussed. But whether a toxicology test is ordered--I mean, whether a toxicology test is performed is whether a toxicology test is ordered by the doctor. The doctor has to order the test.

319 MR. KELBERG:

There are forms that are filled out by the doctor, like Dr. Golden, who indicate if in fact he or she wishes a toxicology test?

320 DR. LAKSHMANAN:

Yes.

321 MR. KELBERG:

And if so, what kind of toxicology test?

322 DR. LAKSHMANAN:

Yes.

323 MR. KELBERG:

Mr. Fairtlough, I think we are done with the photographs. And your Honor, I have now some other paper exhibits, and perhaps these can be marked starting at exhibit 330-A and just go down the letters. I have what appears to be a form 12 autopsy report as 330-A; a similar form 12, but without the heading at the top, as b; a form 15, which appears to have multiple pages of different colors, white, pink, yellow, as c; a form 16 autopsy check sheet as d; a form 34, which appears to show skull outlines, as e; a form 20 that appears to show the front and back of the outline of a human being as I guess we are up to f; a form 20-F that has what appears to be some skull and face outlines as g; a form 20-G we are one letter behind on the scheme, but a 20-G, which appears to show the outline of part of the neck and head and skull, as h; a form 29, which appears to show areas of the brain; a form 24, which appears to show areas of the neck internally, as J. I think I left out I for 29. A form 23 showing outlines of the hand, left and right, as j--

324 MR. LYNCH:

That is K.

325 MR. KELBERG:

K. Mr. Lynch has got to write faster or I've got to talk slower. A form 22 showing again the head and neck area as l; a form 21 showing the side views of a human outline, left and right, as m; a form 28, which appears to show the external skull and the internal cavity of the skull as N, as in Nancy; and a form 27, which appears to show the skeletal outline front and back of a human being as O. May they be so marked accordingly?

326 THE COURT:

Yes.

327 MR. KELBERG:

Thank you, your Honor.

328 (Peo's 330-A thru 330-O for id = autopsy forms)
329 MR. KELBERG:

And I believe Mr. Fairtlough has these items available for showing on the screen. Doctor, let me show you all of these exhibits, 330-A through O. In general terms are you familiar with what these documents are?

330 DR. LAKSHMANAN:

Yes.

331 MR. KELBERG:

What are they?

332 DR. LAKSHMANAN:

The form 15 is the medical report and this is the form used by the doctor when he or she completes the autopsy to document the cause of death, and if the case has been deferred for further studies, there will be notations in the chart on this form as to why the case is being deferred for further study. This could include, toxicology, neuropathology, study of the brain in detail, or doing histological studies, that is, to study microscopic sections of the tissues. And this form also has a space for the specimens collected during autopsy.

333 MR. KELBERG:

Let me stop you just quickly enough to ask Mr. Fairtlough, who has already pulled the page, to put it up on the screen. And this is a copy of exhibit 330-C. I think we want to go back to a and B, the form 12's, but let's start with this one. And if Mr. Fairtlough could zoom in a little bit starting at the top portion of the document.

334 MR. KELBERG:

The form number is in the upper left-hand corner; is that correct, doctor?

335 DR. LAKSHMANAN:

Yes. That is 15. This is the medical report form.

336 MR. KELBERG:

And this area, if an arrow can be used to cover this, "Death was caused by," and we can see the words "Or as a consequence" of repeated three times, was is that block to contain?

337 DR. LAKSHMANAN:

As I told you, the doctor that does the cause of death and the format used here is the same format which is used on the death certificate so that this information is used by the clerical personnel in the death certification unit in the Coroner's office to type up the death certificate, so this is where the doctor enters the cause of death. Now, about--if the doctor is not able to determine the cause of death, he would mark--or she would mark the box called "Pending" which is on the left upper corner and then the reason why the cause of death was deferred will be marked off, either toxicology or the doctor needs more medical history or the doctor needs a follow-up investigation from the law enforcement. So depending on what the reason is, that particular box will be completed. The--it is important on the top you have the class of autopsy, A, B and C, which I alluded to earlier. The a and B are the complete autopsies and c is the partial exam, any performed by the doctor, so this will give you an idea if an examination is performed or an autopsy was performed, and if the latter was done, whether it is a complete autopsy or a partial, and then let's move down.

338 MR. KELBERG:

Before we do, doctor, is the most complete autopsy that is done the class a?

339 DR. LAKSHMANAN:

Yes. That is the comprehensive autopsy which includes photography, toxicology and all the homicide cases are treated like "A" cases in which they get all the work-up which the doctor feels necessary.

340 MR. KELBERG:

Doctor, both of the cases, Nicole Brown Simpson and Ronald Goldman, were handled as class a autopsies?

341 DR. LAKSHMANAN:

Yes, yes.

342 MR. KELBERG:

All right. And is this form filled out either during the course of the autopsy or immediately afterwards?

343 DR. LAKSHMANAN:

Portions could be filled during, because you can mark off the "Toxicology" section, what you collected at that time, but the cause of death and the rest of the form will be completed at the end of the autopsy, because as you move down the form, can you--can you move the form, please? You have the "Mode of death" there.

344 MR. KELBERG:

Okay. We are going to come back to that. Where do you want to go?

345 DR. LAKSHMANAN:

Go back a little bit higher, a bit--bit furthermore up the form so you can go to the lower part of the form.

346 MR. KELBERG:

You want to go to the bottom of the page?

347 DR. LAKSHMANAN:

Yes, yes. You can see some areas called organ procurement, witnesses to the autopsy, pertinent comments, evidence recovered, so if any process takes place during the autopsy which needs to be documented, can be documented during the autopsy. That space is available below the statements.

348 MR. KELBERG:

Incidentally, there is a box for "Witnesses to autopsy." In homicide cases is it usual that there will be at least one witness who is not a member of the Coroner's office witnessing the autopsy?

349 DR. LAKSHMANAN:

Yes. We allow the law enforcement investigating officer to attend the autopsy, because this has been the practice in the Coroner's office for many years.

350 MR. KELBERG:

Is it customary during the coarse of the autopsy for the medical examiner to talk with the officer, or if there is more than one officer, officers, to get additional information that may be pertinent to the evaluation being performed by the medical examiner?

351 DR. LAKSHMANAN:

Yes.

352 MR. KELBERG:

Now, doctor, if we could go back to that area "Natural accidents, suicide, homicide and undetermined," I think on Friday you defined the concept of "Manner of death"; is that correct?

353 DR. LAKSHMANAN:

Yes.

354 MR. KELBERG:

That is what these five boxes refer to?

355 DR. LAKSHMANAN:

Yes.

356 MR. KELBERG:

And if we could now, Mr. Fairtlough, go to the right side of the document about midway and below. Your right. And if we could get more of the right side of the document in and perhaps raise the document so we will see the bottom portion. No. Raise it up to show the bottom, please. And stop about there, please.

357 MR. KELBERG:

Now, doctor, let's start with this entry area for "Toxicological specimens collected" and there are a whole bunch of boxes and so forth. No. 1, what is the purpose behind that area of the form?

358 DR. LAKSHMANAN:

That reflects what specimens were collected, and if no specimens were collected, you mark off the boxes giving the information. For example, if somebody had been hospitalized and they were more than 24 hours in the hospital, then we will mark the box over "24 hours in the hospital" and "No blood being collected." And then below that is what kind of screen one would like to request on a particular case. You have a c screen, an h screen, a d screen and an s screen.

359 MR. KELBERG:

What do they reflect, the different types of screens.

360 DR. LAKSHMANAN:

They reflect different types of drugs analyzed. The c screen is a comprehensive complete toxicology, the h screen is what we order in homicide cases. That would include alcohol, the drugs like PCP, cocaine, narcotics, amphetamines. T screen is a traffic screen. Basically you order alcohol, barbiturates and amphetamines and the s screen is similarly a toxicology screen which we do in SIDS death which we do in testing for drugs which I just mentioned and other prescription drugs.

361 MR. KELBERG:

The h screen that you mentioned in all homicide cases, was an h screen done, toxicological h screen done for both blood samples of Nicole Brown Simpson and Ronald Goldman?

362 DR. LAKSHMANAN:

Yes, it was, and actually after the laboratory ordered, I extended it to a c screen just to complete the screen.

363 MR. KELBERG:

Doctor, if we could move up again, under "Toxicological specimens collected" there are a lot of boxes that seem to be similar to that label we saw in one of the earlier photographs that you indicated should be checked off and one of them was erroneously checked off as urine which in fact was bile. Do you see that area?

364 DR. LAKSHMANAN:

Yes.

365 MR. KELBERG:

Who is to fill out this and what is this to reflect?

366 DR. LAKSHMANAN:

This is a form to be filled out by the doctor. This is a medical report. The doctor fills out this form.

367 MR. KELBERG:

Now, doctor, did you find--before we do that, if you could pull out the actual form 15, the hard document that I gave you, and hold it up for us, if you would, please.

368 (Witness complies.)
369 MR. KELBERG:

Is it a single page or is it multiple pages, doctor?

370 DR. LAKSHMANAN:

It is a multiple-page document that is a white copy, gold copy, a pink copy and a darker yellow copy here.

371 MR. KELBERG:

When the medical examiner has this form at time of autopsy, is it in the condition that you are holding it, that is, with all of the copies?

372 DR. LAKSHMANAN:

Yes.

373 MR. KELBERG:

And why do you have all these different copies?

374 DR. LAKSHMANAN:

Because after the medical examiner completes it, when--before it goes to the certification desk, they separate out a form which is the yellow copy. If you look in the bottom--if you go to the bottom, if you go to the bottom below the toxicology, a little more down, a little more down, you can see where each copy goes. The white goes to the file, the canary copy--I'm sorry I used color yellow--it is a canary copy which goes to the lab, pink goes to investigations and the goldenrod is the doctor's copy because we train a lot of doctors and the residents like to keep a copy and also our regular doctors keep a copy for themselves for their record, so that is the reason we have four copies.

375 MR. KELBERG:

Now, doctor, in discussing the bile/urine mistake, where is that material going? To any of the--don't move that please, Mr. Fairtlough. To any of those laboratories, forensic lab, investigation copy and so forth?

376 DR. LAKSHMANAN:

The bile/urine is in the bottle. The mistake was on the bottle; not on the form. But these are copies of this whole document which go to these areas.

377 MR. KELBERG:

Does a copy of this document go with, for example, a jar that might have the stomach contents?

378 DR. LAKSHMANAN:

No. There will be one copy which goes to the toxicology lab and the toxicology division will see whether the specimens which were marked off on the form are actually received in the lab. This is like a cross-check of the specimens received in comparison to the form because the doctor may order certain tests based on the specimens he or she submitted, but the toxicology lab will double-check whether they received the specimens.

379 MR. KELBERG:

In your review of this case did you find that there was a mistake made with respect to the labeling of stomach contents retained from Ronald Goldman?

380 DR. LAKSHMANAN:

Yes.

381 MR. KELBERG:

What was that mistake?

382 DR. LAKSHMANAN:

The white page--

383 MR. KELBERG:

Mr. Fairtlough, before you--if Mr. Fairtlough could get back to that area and back it up just so we can see the bigger picture of that area. Thank you.

384 DR. LAKSHMANAN:

The main white file copy, the stomach contents was not marked off.

385 MR. KELBERG:

On the white copy?

386 DR. LAKSHMANAN:

Yes.

387 MR. KELBERG:

All right. That is the front page in essence, correct?

388 DR. LAKSHMANAN:

Yes.

389 MR. KELBERG:

So if Dr. Golden were to mark stomach contents having been retained from Mr. Goldman, it should be a that white form and all of the underlying copies; is that accurate?

390 DR. LAKSHMANAN:

Yes.

391 MR. KELBERG:

Now, did you find in your review that one or more of the copies did have a marking in the box for stomach contents for Mr. Goldman?

392 DR. LAKSHMANAN:

Yes, I did.

393 MR. KELBERG:

How many copies had that?

394 DR. LAKSHMANAN:

The toxicology copy had it, the yellow copy.

395 MR. KELBERG:

And what does that indicate to you in this area of a cross-check?

396 DR. LAKSHMANAN:

What happened was the lab had received the stomach contents of Mr. Goldman and that was reflected in the--by the way, there is another log sheet which is maintained in the autopsy room which documents the specimens submitted during autopsy, and that log sheet had documented that the stomach contents were submitted on Mr. Goldman. And when that log sheet and specimens were received in the toxicology lab, it was found that the yellow sheet, which they had, the second copy, the canary copy, did not have the stomach contents marked, so they marked that the stomach contents were received.

397 MR. KELBERG:

Now, doctor, do you consider this to be a mistake by Dr. Golden not to have marked on the white copy?

398 DR. LAKSHMANAN:

Yes.

399 MR. KELBERG:

Does that mistake have any significance to you in evaluating any of the issues you've evaluated for your testimony here today?

400 DR. LAKSHMANAN:

No.

401 MR. KELBERG:

Why not?

402 DR. LAKSHMANAN:

It is just an arrow in marking a box. It has nothing to do with the cause of death or manner of death. And the specimen was collected, so it is an error, but I don't think it is significant enough to affect the cause and manner of death.

403 MR. KELBERG:

Or any of the other issues you have reviewed?

404 DR. LAKSHMANAN:

That is correct.

405 MR. KELBERG:

Doctor, if we could move to the form 12, which is page 123, Mr. Fairtlough, and I would ask, doctor, the first page form 12. Do you have that?

406 DR. LAKSHMANAN:

Yes.

407 MR. KELBERG:

Mr. Fairtlough is going to get this up on the elmo.

408 (Brief pause.)
409 MR. KELBERG:

Doctor, is this the protocol document in a blank form, however?

410 DR. LAKSHMANAN:

Yes. This is the form used where the transcribers use to type the reports up.

411 MR. KELBERG:

And so this will actually not have handwritten information generally, it will all be in typed fashion?

412 DR. LAKSHMANAN:

That's correct.

413 MR. KELBERG:

And the second form 12 which is page 124, Mr. Fairtlough--and your Honor, may that be--I'm sorry, we have already marked that, that was 330-A and this is 330-B. And if we could back up just to see the full document.

414 MR. KELBERG:

Is this what each of the subsequent pages looks like before the transcriber puts the words on paper?

415 DR. LAKSHMANAN:

Yes.

416 MR. KELBERG:

Now, if we could move, doctor, form 16, which is our exhibit 330-D, as in dog, and is page 126, Mr. Fairtlough. This autopsy check sheet, what is the purpose of this sheet, doctor?

417 DR. LAKSHMANAN:

The purpose of the sheet is for the doctor to enter the major findings as the autopsy process progresses, documenting the weights of the various organs, any abnormal pathology they may find, and there are different areas in the form giving information on the different organs, so the doctor just completes the information.

418 MR. KELBERG:

I'm going as to ask, Mr. Fairtlough, if he can, to make it a little clearer. Getting up closer to see parts of it. If that is the best we are going to be able to do--

419 MR. KELBERG:

This form is filled out in the course of the autopsy by the medical examiner?

420 DR. LAKSHMANAN:

Yes.

421 MR. KELBERG:

Now, if Mr. Fairtlough could go to the bottom of the document; the real bottom. There we go. And also get it to include the left side.

422 MR. KELBERG:

Doctor, what is to be completed in this area of the form 16?

423 DR. LAKSHMANAN:

The doctor completes the date the autopsy was done, the time he or she started it and completed it, and the doctor signs the report.

424 MR. KELBERG:

Doctor, in the case of Nicole Brown Simpson did Dr. Golden indicate the time during which he performed her autopsy?

425 DR. LAKSHMANAN:

Yes.

426 MR. KELBERG:

What time did he indicate?

427 DR. LAKSHMANAN:

I want to refresh my memory.

428 (Brief pause.)
429 DR. LAKSHMANAN:

He started the autopsy at 8:30 in the morning on June 14th, 1994, and completed it at 10:30. This is the autopsy part of it; not the dictation.

430 MR. KELBERG:

So that was two hours?

431 DR. LAKSHMANAN:

That is the time recorded, yes.

432 MR. KELBERG:

And if you need to refresh your memory can you tell us the time, if any, indicated by Dr. Golden regarding how long he spent on the autopsy of Ronald Goldman?

433 DR. LAKSHMANAN:

I would like to refresh my memory. When it comes to times I want to be accurate.

434 (Brief pause.)
435 DR. LAKSHMANAN:

On Mr. Goldman the autopsy started at 10:30 on June 14th, 1994, and the autopsy is reflected as having been completed at 1300 hours on June 14th, 1994.

436 MR. KELBERG:

That would be one o'clock in the afternoon?

437 DR. LAKSHMANAN:

Yes.

438 MR. KELBERG:

Or approximately two and one-half hours?

439 DR. LAKSHMANAN:

Yes.

440 MR. KELBERG:

Doctor, given what you knew when you examined the bodies briefly on the 13th, given what you now know from your review of all of the materials, do you consider two and a half hours to have been an appropriate time to perform the autopsy of Ronald Goldman?

441 DR. LAKSHMANAN:

The multiplicity of injuries which I saw, if the time reflected is accurate, because sometimes the doctors may spend more time but after the--when they are doing the filling out of the paperwork--I would feel that it should have taken more time than two and a half hours.

442 MR. KELBERG:

Approximately how long, in your opinion, should it have taken to completely and properly perform the autopsy of Ronald Goldman?

443 DR. LAKSHMANAN:

I would say about four to five hours, if you want to diagram every small injury.

444 MR. KELBERG:

And is that what you would expect, to have every small injury diagrammed?

445 DR. LAKSHMANAN:

That is our goal in the Coroner's office, to document every injury accurately and truthfully so that it can be preserved because you only have one shot at doing a good job.

446 MR. KELBERG:

Incidentally, doctor, is there a manual that you have responsibility for having written, called the "Deputy medical examiner procedure manual last revised, 1992, 12th edition"?

447 DR. LAKSHMANAN:

Yes. I have my copy in one of my boxes.

448 MR. KELBERG:

Let me read something to you and ask if this is in fact what you have written in that manual?

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
The bile is thick greenish black in color and anybody can tell the difference between bile and urine.
Underscores the carelessness of Dr. Golden's mislabeling error — this was not a subtle mistake.
Dr. Lakshmanan Sathyavagiswaran
Not in the pericardial sac, the heart. Because he had a lot of injuries which caused significant bleeding and so the blood from the chest cavity was submitted.
Establishes the severity of Goldman's wounds — so much blood loss that the heart itself was drained, requiring an alternate collection site.
Dr. Lakshmanan Sathyavagiswaran
The mistake was on the bottle; not on the form.
Clarifies the scope of the labeling error — limited to the physical container, not the official paperwork.
Brian Kelberg
In your opinion does this mistake affect in any way your ability to answer the issues that you have reviewed for your testimony here today?
Prosecution inoculation strategy — eliciting testimony that errors, while real, are not case-dispositive.

Evidence (7)

People's 324
Photograph of the autopsy instrument tray
introduced and discussed
People's 325
Photograph of specimen collection containers (urine, bile, stomach, liver, formalin jars)
introduced and discussed
People's 326
Photograph of the Coroner's specimen label used on containers
introduced and discussed
People's 327
Photograph of the label used on the EDTA serology tube
introduced and discussed
People's 328
Photograph of evidence storage room with shelved clothing packages
introduced and discussed
People's 329
Photograph of freezers and refrigerators storing serological samples and blood swatches
introduced and discussed
+ 1 more

Notable Exchanges (2)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg elicits that Ron Goldman's bile was mislabeled as urine on its container, that this was Dr. Golden's responsibility, and that any trained forensic pathologist could visually distinguish the two — before immediately rehabilitating by asking whether the error affects Lakshmanan's conclusions (it does not).
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Testimony that Goldman bled so extensively that no blood could be collected from his heart or pericardial sac — it had to be drawn from the right pleural cavity instead, underscoring the severity of his injuries.
revealing

Light Moments (3)

Brian Kelberg
Kelberg asks if the ladle used in autopsies is 'like a soup ladle' and Lakshmanan confirms it is.
Dr. Lakshmanan Sathyavagiswaran
Kelberg suggests autopsy forceps are like 'big tweezers'; Lakshmanan corrects him, saying 'You could use that analogy, but these are forceps actually.' When asked if he prefers that term, he replies simply 'Yes.'
Brian Kelberg
Kelberg jokes about needing to 'talk slower' after his co-counsel Lynch signals he is struggling to keep up with the rapid exhibit lettering recitation (330-A through 330-O).

Credibility Attacks (1)

⚔ Dr. Irwin Golden
eliciting admissions of error through supervising expert
Kelberg — through Lakshmanan — establishes two documented errors by Dr. Golden: (1) mislabeling Goldman's bile specimen container as 'urine,' and (2) failing to mark the fingernail scraping kit envelope to indicate scrapings were taken. Lakshmanan confirms both are Golden's responsibility and constitute mistakes, though he opines neither affects the ultimate forensic conclusions.

Witness Demeanor

(Witness complies.) — referring to notes when asked which decedent had the mislabeled bile specimen
(Witness complies.) — holding up the multi-page Form 15 document for the jury

Objections

None recorded
Proceeding 6277 • 448 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 6, 1995 📄 Direct examination of Dr. Laks
JUN 6, 1995 KRT DvH TD