📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 4) — Tuesday, June 6, 1995
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TRIAL
▲ Day 89 of 167

Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 4)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Tuesday, June 6, 1995 • Utterances: 159
Brian Kelberg begins the direct examination of Dr. Lakshmanan, the Chief Medical Examiner, establishing his office's standards and then walking through the autopsy documentation forms used in the case. The central revelation is that Dr. Golden made a documented error — writing 'No injuries' on the brain diagram form when a contusion to Nicole Brown Simpson's cerebral cortex was later found by Dr. Lakshmanan, Dr. Baden, and Dr. Wolf on June 22, 1994. Dr. Lakshmanan systematically testifies that none of Dr. Golden's mistakes affected his ability to determine cause of death or knife characteristics for either victim. The proceeding ends with Shapiro requesting a sidebar before knives can be introduced as evidence.
1 MR. KELBERG:

Thank you, your Honor.

2 MR. KELBERG:

Doctor, did you write this in your 12th edition of the "Deputy medical examiner and procedure manual" on page 40 under the heading "Homicides"? "In homicide cases justice may not be properly served unless meticulous attention to detail is observed. The smallest mark on the body may be of critical importance when all of the facts in the case become known. All marks of trauma are to be charted and described. External measurements shall be in inches since the police and courts are not yet met metricized and recreation of a crime scene is made difficult when converting back and forth from inches to centimeters"?

3 DR. LAKSHMANAN:

Yes, I did.

4 MR. KELBERG:

When you wrote this did you believe what you wrote?

5 DR. LAKSHMANAN:

Yes, I did.

6 MR. KELBERG:

Do you believe in it as you testify here today?

7 DR. LAKSHMANAN:

Yes, I do.

8 MR. KELBERG:

Can your office meet your expectation?

9 MR. SHAPIRO:

Objection, calls for speculation.

10 THE COURT:

Overruled. You can answer the question.

11 DR. LAKSHMANAN:

We try and meet the expectations in every case we do. We try very hard not to make mistakes. When we do make mistakes, we accept them, we review the report and correct them. We work as a team in our office. We have 166 employees who work very hard. We share Honor and blame where the mistakes do occur. We are not proud to make mistakes, we are sad when we make a mistake, but we are ready to accept it.

12 MR. SHAPIRO:

Your Honor, I'm going to move to strike that as nonresponsive to the question that was asked.

13 THE COURT:

Overruled. Proceed. Let's move on.

14 MR. KELBERG:

Doctor, in your--let's finish with these forms just so we see what they are. Mr. Fairtlough, if you can just in sequencing, pages 127, 128 and so forth. Doctor, just to back up so we can see these forms, there are numbers in the upper left-hand corner for each of these forms; is that correct?

15 DR. LAKSHMANAN:

Yes.

16 MR. KELBERG:

And so this would be a form 34; is that correct?

17 DR. LAKSHMANAN:

Yes.

18 MR. KELBERG:

Do the numbers occasionally change?

19 DR. LAKSHMANAN:

Yes. Originally these diagrams had letters attached to a number. They had 20-A, B, C, d and I am in the process of revising the form so we have a number for a form and that is how some forms have the letter next to the number and like 20-J or 20-H and have some numbers and we are in the process of doing that, so at the same time we don't want to throw away a form we already have, we want to finish them and then use the new form when the new forms are printed.

20 MR. KELBERG:

All right. If Mr. Fairtlough can put the next one up, a form 20, again.

21 MR. KELBERG:

Doctor, are all of these forms which are used by the medical examiner in the course of the autopsy?

22 DR. LAKSHMANAN:

Yes, they are, depending on what they need to document.

23 MR. KELBERG:

And Mr. Fairtlough, the next page, please.

24 DR. LAKSHMANAN:

Yes.

25 MR. KELBERG:

And the next page, please.

26 THE COURT:

All right. That was form 20-F.

27 MR. KELBERG:

Right. This is form 20-G. And the next one, please.

28 MR. KELBERG:

Doctor, this is form 29; is that correct?

29 DR. LAKSHMANAN:

Yes.

30 MR. KELBERG:

What are we looking at on this form?

31 DR. LAKSHMANAN:

This is the diagram of the brain. The doctor can use this to document the injuries on the brain if they--when they observe the injuries on the brain during the autopsy.

32 MR. KELBERG:

In the course of reviewing the materials in this case, was there a form 29 completed by Dr. Golden for the autopsy of Nicole Brown Simpson?

33 DR. LAKSHMANAN:

Yes.

34 MR. KELBERG:

Was there any written entry on that form?

35 DR. LAKSHMANAN:

Yes.

36 MR. KELBERG:

What was the written entry, and we will see the document in a few minutes, but what was the written entry?

37 DR. LAKSHMANAN:

Can I refresh my memory?

38 MR. KELBERG:

Yes.

39 DR. LAKSHMANAN:

It says "No injuries," but I want to--just says "No injuries."

40 MR. KELBERG:

And is that in his handwriting?

41 DR. LAKSHMANAN:

Yes.

42 MR. KELBERG:

And incidentally, that scaly looking thing running horizontally at the bottom of the form, what does that depict?

43 DR. LAKSHMANAN:

The bottom portion, that is the spinal cord diagram.

44 MR. KELBERG:

Now, doctor, did you find, in your review of materials on June 22, 1994 with Dr. Baden, that there had been a mistake made by Dr. Golden with respect to that entry of "No injuries"?

45 MR. SHAPIRO:

I'm going to object as leading and assumes a fact not in evidence; misstates the true facts.

46 THE COURT:

Sustained. Rephrase the question.

47 MR. KELBERG:

Sure.

48 MR. KELBERG:

Doctor, on June 22, 1994, did you examine any of the tissue preserved by Dr. Golden from the autopsy of Nicole Brown Simpson?

49 DR. LAKSHMANAN:

Yes, I did. I did it in conjunction with Dr. Baden and Dr. Wolf, Defense pathologists who wanted to examine the tissues which we have in our possession.

50 MR. KELBERG:

I'm not sure if Dr. Wolf has been introduced, but that is the young woman who is seated next--I hope she likes the term young woman--she is smiling so I must not be too offensive--seated next to Dr. Baden.

51 THE COURT:

Noted.

52 MR. KELBERG:

And the three of you examined the tissue; is that correct?

53 DR. LAKSHMANAN:

Yes.

54 MR. KELBERG:

Did the tissue you examined include brain tissue of Nicole Brown Simpson?

55 DR. LAKSHMANAN:

Yes, it did.

56 MR. KELBERG:

When you examined any of the brain tissue, did you see anything that was of significance to you?

57 DR. LAKSHMANAN:

Yes.

58 MR. KELBERG:

What did you see?

59 DR. LAKSHMANAN:

We found a piece of the cerebral cortex which had a contusion injury.

KEY QUOTE
60 MR. KELBERG:

We are going to talk about what a contusion is later on, but given what you saw, did that cause you to form an opinion as to whether or not Dr. Golden's entry of no injury on his form 29 was a mistake?

61 DR. LAKSHMANAN:

Yes, it was.

62 MR. KELBERG:

And have you reevaluated, in the course of reviewing all the material, what significance, if any, that mistake has as to any of the issues about which you are to testify?

63 DR. LAKSHMANAN:

It was a mistake in not documenting the injury, but the injury itself did not cause the death. It was not a fatal injury.

KEY QUOTE
64 MR. SHAPIRO:

Objection, nonresponsive.

65 MR. KELBERG:

I think it probably is nonresponsive, I agree with Mr. Shapiro.

66 THE COURT:

I will let the answer stand.

67 MR. KELBERG:

Okay.

68 THE COURT:

Proceed.

69 MR. KELBERG:

Doctor, my question is did you assess or consider, that is, the significance, if any, of this mistake of Dr. Golden's regarding this injury to the brain when you were evaluating the issues about which you are to testify here today?

70 MR. SHAPIRO:

Your Honor, I'm going to object. That is vague, the issues about which he is to testify?

71 THE COURT:

Sustained. Sustained.

72 MR. KELBERG:

Doctor, have you considered various materials for the purpose of coming to an independent conclusion on cause of death for Nicole Brown Simpson?

73 DR. LAKSHMANAN:

Yes, I have.

74 MR. KELBERG:

On cause of death for Ronald Goldman?

75 DR. LAKSHMANAN:

Yes, I have.

76 MR. KELBERG:

On whether one knife could have caused all injuries that are sharp force injuries received by Nicole Brown Simpson?

77 DR. LAKSHMANAN:

Yes, I have.

78 MR. KELBERG:

On whether one knife could have caused all the sharp force injuries received by Ronald Goldman?

79 DR. LAKSHMANAN:

Yes, I have.

80 MR. KELBERG:

On whether the same knife could have caused all of the sharp force injuries received by both Nicole Brown Simpson and Ronald Goldman?

81 DR. LAKSHMANAN:

Yes, I have.

82 MR. KELBERG:

And in evaluating those issues have you taken into account every mistake that you have identified that you believe is attributed to Dr. Golden?

83 DR. LAKSHMANAN:

Yes, I have.

84 MR. KELBERG:

And have you considered what, if any, significance each of those mistakes has with respect to these issues you have indicated you have considered?

85 DR. LAKSHMANAN:

Yes, I have.

86 MR. KELBERG:

In your opinion did any of the mistakes, including this mistake, have any significance in your ability to determine the cause of death of Nicole Brown Simpson?

87 DR. LAKSHMANAN:

No.

88 MR. KELBERG:

Did it have, any of these mistakes, including this one, have any significance to you in your ability to determine the cause of death of Ronald Goldman?

89 DR. LAKSHMANAN:

No.

90 MR. KELBERG:

Did any of these mistakes, including this one in form 29, have any significance to you in your ability to determine whether one knife could have caused all of the sharp force injuries received by Ronald Goldman?

91 DR. LAKSHMANAN:

No.

92 MR. KELBERG:

Did any of these mistakes, including the one on form 29, have any significance to you in your ability to determine whether one knife caused all of the sharp force injuries to Nicole Brown Simpson?

93 DR. LAKSHMANAN:

No.

94 MR. KELBERG:

Did any of these mistakes, including the one on form 29, have any significance to you in your ability to determine whether the same single knife could have caused all of the sharp force injuries to both Ronald Goldman and to Nicole Brown Simpson?

95 DR. LAKSHMANAN:

No.

96 MR. KELBERG:

And we will get into your reasons as we get into the actual materials and photographs. Now, if we could go to the next form, please, Mr. Fairtlough, and this is a form 24.

97 MR. KELBERG:

What is this form to be used for, doctor?

98 DR. LAKSHMANAN:

This is a form showing diagrammatic representation of the internal neck organs which I alluded to earlier and the doctor uses this form to document any injuries they may see.

99 MR. KELBERG:

And the next form, please, this is a form 23. What is this to be used for?

100 DR. LAKSHMANAN:

This is a form to document injuries on the hands, both the palm and the back of the hands.

101 MR. KELBERG:

Are you familiar with the term called "Defensive wound," doctor?

102 DR. LAKSHMANAN:

Yes.

103 MR. KELBERG:

What does that term mean to you as a forensic pathologist?

104 DR. LAKSHMANAN:

Defensive wounds is a term used for describing injuries on the extremities when they are used by a victim to ward off any inflicting assaultive injuries which is going to be inflicted on them.

105 MR. KELBERG:

The "Extremity" mean what, doctor?

106 DR. LAKSHMANAN:

Both the lower extremity and the upper extremity but most of the extremity means the hands and the feet and the legs and the arms.

107 MR. KELBERG:

And in cases involving stab wounds or the use of a knife to inflict injuries, is defensive wounds on--are defensive wounds kind of thing as a forensic pathologist you are looking for?

108 DR. LAKSHMANAN:

Yes.

109 MR. KELBERG:

And a form like 23, is this where you would expect them to be tagged, at least with respect to the hands?

110 DR. LAKSHMANAN:

Yes.

111 MR. KELBERG:

Mr. Fairtlough, the next one.

112 MR. KELBERG:

And what is this type of diagram, a22, to be used for?

113 DR. LAKSHMANAN:

This diagram is used to document injuries in the head and neck area.

114 MR. KELBERG:

Okay. And would that include stab wounds?

115 DR. LAKSHMANAN:

It would introduce any type of injury one may see on a person.

116 MR. KELBERG:

The next one, Mr. Fairtlough.

117 MR. KELBERG:

Again, doctor, this is a form 21 to be used in the course of the autopsy?

118 DR. LAKSHMANAN:

Yes. This is a side view of the body. We use this diagram because this gives us a better view of the flank area which is demonstrated earlier.

119 MR. KELBERG:

And the next one, Mr. Fairtlough, form 28.

120 MR. KELBERG:

What does this show, doctor?

121 DR. LAKSHMANAN:

This shows the skull cavity after the skull cap has been removed after we see in the top sheet.

122 MR. KELBERG:

And the next one, a form 27?

123 DR. LAKSHMANAN:

This is a diagram which shows the skeletal system with an outline of the body around it to document any fractures or injuries, penetrating injuries through the rib cage or bony cage. It is a good form to diagrammatically represent what you want to demonstrate.

124 MR. KELBERG:

Doctor, in going back briefly to form 28, you have already identified from form 29 the brain form, this issue of no injuries. What you identified on June 22nd as this contusion to the cerebral cortex of Nicole Brown Simpson's brain tissue, would you expect that to be diagrammed on this form?

125 DR. LAKSHMANAN:

Not the brain contusion. The brain contusion is only diagrammed on the brain diagram.

126 MR. KELBERG:

On this form is there any kind of sharp force injury to the skull, like a knife striking the scull? Would you expect that this would be the form where it would be diagrammed?

127 DR. LAKSHMANAN:

Yes.

128 MR. KELBERG:

I think we are done with those forms.

129 (Brief pause.)
130 MR. KELBERG:

And may I just collect those from Dr. Lakshmanan?

131 THE COURT:

You may.

132 (Brief pause.)
133 MR. KELBERG:

Doctor, I want to get into a discussion now of sharp force injuries so we have a little more detailed understanding of that. Let's start off with first just your definition of sharp force injuries.

134 DR. LAKSHMANAN:

A sharp force injury is one which is caused by a sharp instrument. They would be stab wounds or incise wounds. And the sharp instrument could vary anywhere from a knife to a broken glass or an open scissor with each blade of the scissor acting like a knife. I just gave you a few examples.

135 MR. KELBERG:

Your Honor, I have a board which I ask to be marked as exhibit 331, and I'm not certain where is the best place. Mr. Fairtlough is our expert on this.

136 THE COURT:

I don't know. Would that location right there be appropriate?

137 MR. KELBERG:

If it is good for the jury and Defense counsel.

138 THE COURT:

I think we need to turn it so it is parallel and the doctor needs to be able to see it.

139 MR. KELBERG:

I may have to step to the board. And also Mr. Fairtlough has the capability and I ask that he put up this particular exhibit 331, which is our page 140, Mr. Fairtlough.

140 (Peo's 331 for id = posterboard)
141 (Brief pause.)
142 MR. KELBERG:

Doctor, just in general terms, what are we looking at on this diagram?

143 DR. LAKSHMANAN:

What this--you--

144 MR. KELBERG:

You are going to have to keep your voice up, too, doctor. Can we swing this microphone?

145 THE COURT:

I think he is just going to have to shout.

146 DR. LAKSHMANAN:

What we are trying to show here is the correlation between the knife and wound damages. The example here is a single-edged knife. The reason is the description of the injuries on the body correlate with certain class characteristics of a weapon. The length of the blade usually corresponds to the depth of the stab wound in the body. The width of the blade corresponds to the length of the wound of the body surface. The thickness of the blade corresponds to the width of the wound on the body's surface. So I will show you another diagram which explains this further.

147 MR. KELBERG:

All right. Doctor, this title for this particular exhibit is--includes "Single-edged knife" which was defined earlier. Is this in fact a depiction of a single-edged knife?

148 DR. LAKSHMANAN:

Yes, because you can see that this edge is blunt. You can see the blunt edge here of the knife, (Indicating). That is, this edge will not be sharp in contrast to the other edge which will be the sharp cutting edge of this knife.

149 MR. KELBERG:

Doctor, in your training as a forensic pathologist are you taught about class characteristics of knives?

150 DR. LAKSHMANAN:

Yes.

151 MR. KELBERG:

Are you taught about how you look at class characteristics of knives for the purpose of seeking to identify from the wound to the body the kind of knife that may be responsible for the wounds?

152 DR. LAKSHMANAN:

Yes. We look at the wounds, we look for simple penetrating wounds which will help us to give some estimate as to a class characteristic for knife. And "Class characteristic" means the length of the blade, the width and the thickness of the blade.

153 MR. KELBERG:

Doctor, do single-edged knives come in all different dimensions of thickness, width and length?

154 DR. LAKSHMANAN:

Yes, they do.

155 MR. KELBERG:

Your Honor, I have a series of knives.

156 MR. SHAPIRO:

Your Honor, may we approach? I believe there was to be a conference on this.

157 THE COURT:

Yes, that is true.

158 MR. KELBERG:

I'm sorry, I didn't hear.

159 THE COURT:

Yes, with the court reporter, please.

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
We work as a team in our office. We have 166 employees who work very hard. We share Honor and blame where the mistakes do occur. We are not proud to make mistakes, we are sad when we make a mistake, but we are ready to accept it.
Kelberg is preemptively rehabilitating Dr. Golden's errors by framing the office as accountable and self-correcting — deflating the defense's planned attack before it lands.
Brian Kelberg
In homicide cases justice may not be properly served unless meticulous attention to detail is observed. The smallest mark on the body may be of critical importance when all of the facts in the case become known.
Kelberg reads from Dr. Lakshmanan's own procedure manual, establishing the standard of care against which Dr. Golden's errors will be measured — and by which the prosecution argues those errors are still not fatal to the case.
Dr. Lakshmanan Sathyavagiswaran
We found a piece of the cerebral cortex which had a contusion injury.
This is the key mistake being addressed — Dr. Golden wrote 'No injuries' on the brain form, but Lakshmanan found a contusion on preserved tissue, confirming the documentation error.
Dr. Lakshmanan Sathyavagiswaran
It was a mistake in not documenting the injury, but the injury itself did not cause the death. It was not a fatal injury.
Lakshmanan concedes Golden's error while simultaneously neutralizing its impact — the contusion was real but not the cause of death, so the error doesn't change the forensic conclusions.

Evidence (5)

null
Dr. Lakshmanan's 12th edition 'Deputy Medical Examiner and Procedure Manual,' page 40, 'Homicides' section — quoted at length by Kelberg
read into record to establish standard of care
null
Form 29 — brain diagram — Dr. Golden's entry reading 'No injuries' for Nicole Brown Simpson's autopsy
discussed; identified as containing a documented mistake
null
Autopsy documentation forms 20, 20-F, 20-G, 21, 22, 23, 24, 27, 28, 29, 34 — the ME office's standard diagram forms for body regions and injuries
introduced and explained sequentially for jury orientation
People's 331
Posterboard diagram showing correlation between a single-edged knife's dimensions (blade length, width, thickness) and resulting wound characteristics on a body
introduced and explained by Dr. Lakshmanan
null
Series of knives Kelberg attempted to introduce
introduction interrupted by Shapiro's sidebar request; not yet shown to jury

Notable Exchanges (4)

Brian KelbergRobert ShapiroLance A. Ito
Shapiro objects that asking if Lakshmanan's office can meet its own standards 'calls for speculation'; Ito overrules. Shapiro then moves to strike Lakshmanan's extended answer as nonresponsive; Ito overrules again. Kelberg's strategy of letting Lakshmanan speak freely about office accountability appears deliberate.
strategic
Brian KelbergRobert ShapiroLance A. Ito
Shapiro successfully objects that Kelberg's question 'Did you find a mistake made by Dr. Golden' is leading and assumes facts not in evidence — forcing Kelberg to rephrase and build more carefully to the brain contusion finding.
procedural
Brian KelbergLance A. Ito
Lakshmanan volunteers that the brain contusion 'was not a fatal injury' — Shapiro objects as nonresponsive, Kelberg agrees it probably is, but Ito lets the answer stand anyway.
revealing
Robert ShapiroLance A. Ito
As Kelberg announces he has 'a series of knives' to introduce, Shapiro immediately requests a sidebar, indicating a pretrial dispute about this evidence that had not been resolved.
strategic

Light Moments (2)

Brian Kelberg
Kelberg introduces Dr. Wolf by saying 'I hope she likes the term young woman — she is smiling so I must not be too offensive,' drawing a noted reaction from Ito.
Lance A. Ito
Ito, when Dr. Lakshmanan struggles to be heard away from the microphone, deadpans: 'I think he is just going to have to shout.'

Credibility Attacks (1)

⚔ Dr. Irwin Golden
prior documented error / established mistake
Kelberg walks Lakshmanan through Dr. Golden's failure to document a contusion on Nicole Brown Simpson's brain in form 29, eliciting Lakshmanan's confirmation that the 'No injuries' entry was wrong. Paradoxically this is prosecution-led — they are surfacing Golden's errors themselves in order to preemptively argue the errors don't undermine the forensic conclusions.

Witness Demeanor

(Brief pause.) — twice noted, during transitions between form exhibits
Lakshmanan asks to refresh his memory before quoting Dr. Golden's 'No injuries' entry

Objections

6 objections (2 sustained, 3 overruled)
Proceeding 6294 • 159 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 6, 1995 📄 Direct examination of Dr. Laks
JUN 6, 1995 KRT DvH TD