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

Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 6)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Tuesday, June 6, 1995 • Utterances: 527
Prosecutor Brian Kelberg continued his direct examination of Chief Medical Examiner Dr. Lakshmanan, walking the jury through a detailed forensic pathology tutorial on knife wound characteristics. Using multiple charts and demonstration knives, Dr. Lakshmanan explained how skin elasticity, blade taper, compressibility, and wound complexity all limit a forensic pathologist's ability to link specific stab wounds to a specific knife. The session concluded beginning a discussion of blunt force trauma and abrasion types.
1 MR. KELBERG:

Thank you, your Honor.

2 MR. KELBERG:

Doctor, just briefly, to show the difference in thickness in single-edged knives, I want to show you 334 and 333. 333 is the black-handled knife. 334 is the--I'm sorry. 334 is the brown-handled knife. Now, doctor, again, both of these are single-edged knives; is that correct?

3 DR. LAKSHMANAN:

Yes.

4 MR. KELBERG:

If you could take for a moment just as we start this process of comparison--I want to start by putting exhibit 333 up on this board that has been marked as 336. Can you hold it up there to superimpose it over?

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

Now, doctor, if I mark with this marker right here with a straight line--not so straight, but will pass as close to straight at the point of penetration of the skin at the area of where the knife blade has been inserted, would that represent if you will the length of the wound on the body?

7 DR. LAKSHMANAN:

Yes, if it's a straight penetration.

8 MR. KELBERG:

If you take this same knife, if you would, doctor, and try to superimpose it on the earlier silhouetted form.

9 (The witness complies.)
10 MR. KELBERG:

In the point of penetration, I'm drawing another line which is closer to the tip of the knife blade. Is that an accurate reflection of the length of the wound on the body where the depth of penetration is as depicted in the diagram?

11 DR. LAKSHMANAN:

Yes.

12 MR. KELBERG:

Now, if you can give me that for just a second.

13 (The witness complies.)
14 MR. KELBERG:

And Mr. Fairtlough tells me that he can put this on the elmo and we can actually take a picture of it because this is not a permanent marker, your Honor.

15 THE COURT:

Apparently not.

16 (Brief pause.)
17 MR. KELBERG:

It appears that Mr. Fairtlough's got as nervous a hand as I do.

18 THE COURT:

No. That's pretty normal.

19 MR. KELBERG:

Oh. For him or for me?

20 THE COURT:

Normal.

21 MR. KELBERG:

Now, Mr. Fairtlough, you're printing a picture so we can--

22 MR. KELBERG:

All right. I'd like you also, if you could, please, to put these two knives--we used a different set of knives for comparison originally on thickness of blade. If you can do the same thing you did because I think it's a clearer distinction. No. Doctor, I'm sorry, or Mr. Fairtlough. Yeah. That's what I want to do. If you could turn these--I'm not sure if it's--doctor, as we are looking at these now, is the difference in thickness of blade between these two exhibits, 333 and 334, visible?

23 DR. LAKSHMANAN:

Yes. The lower knife seems to be having a thicker blade than the upper knife there on the screen.

24 MR. KELBERG:

And I'm not sure if Mr. Fairtlough can get our pointer out. And that knife is the black-handled knife which is going to be exhibit 333, and then the one below that has the thicker blade; is that correct, doctor?

25 DR. LAKSHMANAN:

Yes. Yes.

26 MR. KELBERG:

Now, doctor, looking at the depiction again in 336--

27 MR. KELBERG:

And thank you, Mr. Fairtlough. And by the way, your Honor, could the picture that was generated of the measurements of the different areas on the same knife, 333, be marked as exhibit 337?

28 THE COURT:

How about 333-A?

29 MR. KELBERG:

That's even better.

30 THE COURT:

All right.

31 (Peo's 333-A for id = generated picture)
32 MR. KELBERG:

I think, Mr. Fairtlough, you don't have to hold them there any longer.

33 MR. KELBERG:

Now, doctor, in pointing to the horizontal area going across where that wound is on the body, do you see that?

34 DR. LAKSHMANAN:

You mean--

35 MR. KELBERG:

Yeah. Not the length anymore, but the horizontal distance from one side to the other. No. Of the wound itself on the body, on the surface of the body.

36 DR. LAKSHMANAN:

Ends, ends of the wounds?

37 MR. KELBERG:

Yeah. And if Mr. Fairtlough can get that back up. There we go. The horizontal--and perhaps Mr. Fairtlough with the arrow can show the distance from side to side of that particular wound. Do you see that, doctor? Not the--that's the length, right? Up and down is the length.

38 DR. LAKSHMANAN:

Yeah.

39 MR. KELBERG:

And side to side is the width, correct?

40 DR. LAKSHMANAN:

That's kind of what he pointed out earlier.

41 MR. KELBERG:

The width--

42 DR. LAKSHMANAN:

The width of the blade is this part. The length is this part (Indicating).

43 MR. KELBERG:

I'm not making myself clear, doctor. I am now focusing on the wound on the body surface, not the blade.

44 DR. LAKSHMANAN:

Okay.

45 MR. KELBERG:

The wound.

46 DR. LAKSHMANAN:

The wound of the body surface here (Indicating).

47 MR. KELBERG:

Up and down, is that the length of the wound?

48 DR. LAKSHMANAN:

That's correct.

49 MR. KELBERG:

Side to side, side to side, is that the width of the wound on the surface? Mr. Fairtlough is working on the knife blade. Forget the arrow and forget the knife blade.

50 DR. LAKSHMANAN:

That is the--that is the width of the wound on the--on the body surface, and that would be the width, which may or may not correspond with the thickness of the blade.

51 MR. KELBERG:

That's what I want to talk about. That thickness that we were looking at between 333 and 334, does that have some significance when you look at the width of the wound as it appears on the surface of the body?

52 DR. LAKSHMANAN:

It's not--this width has some significance, but the width we are concerned with when we evaluate a wound and correlate it with the knife is the ends of the wound. We look at the ends of the wound to see whether the ends of the wound are sharp like in this picture here (Indicating) or they are blunted or squared off. And that would be a reflection of the blunt end of the knife.

53 MR. KELBERG:

In the abstract sense, doctor, does the thickness of the blade as the inset of exhibit 336 indicates, does the thickness of the blade correspond in some fashion to the width of the wound on the body?

54 DR. LAKSHMANAN:

Yes. If you look at this picture here, you could see that the thickness of the blade corresponds to some extent to the width of the wound here (Indicating).

55 MR. KELBERG:

Now, is there a limitation that you as a forensic pathologist have to deal with in using the width of the wound on the body to estimate the thickness of the blade at that point of penetration?

56 DR. LAKSHMANAN:

Yes. One is the elasticity of the skin, which is an important factor. And also, if it's a thin single-edged blade, you may--the--the blunt edge of the blade may not reflect its blunt edge on the wound of the body. It looked like as though it's a double--double-edged knife.

57 MR. KELBERG:

And I'll get to that in a little while.

58 MR. KELBERG:

But with the Court's permission, could the witness step down in front of the jury, and perhaps I can hold the knife so that the jury can see.

59 THE COURT:

Yes.

60 (The witness complies.)
61 MR. KELBERG:

Perhaps if I could just first walk down and let them have a chance to see it, and then I'll ask Dr. Lakshmanan some questions. And, Mr. Lynch, could you hand me the other knife that was exhibit 334?

62 MR. SHAPIRO:

Your Honor, we're going to object to this based on relevancy.

63 THE COURT:

Mr. Kelberg, haven't we already demonstrated the relative thicknesses of the blade on the elmo?

64 MR. KELBERG:

I'm not how clear it is, your Honor. We're now going to talk about the identification of wound patterns based upon the thickness.

65 THE COURT:

It was already--it was already demonstrated on the elmo, the relative thicknesses.

66 MR. KELBERG:

If the Court's satisfied that it's clear, then that's fine.

67 THE COURT:

Yes.

68 MR. KELBERG:

I don't need to do this then.

69 MR. KELBERG:

Doctor, given--let's take a look at exhibit 333. Does the thickness of that blade change as one moves--if you could hold it up too.

70 (The witness complies.)
71 MR. KELBERG:

Does the thickness of that blade change as one moves from the handle of the blade to the tip of the blade?

72 DR. LAKSHMANAN:

Yes. Both the thickness and the width of the blade narrows as it goes towards the tip. So the tip of the blade is not as thick or as wide as it is in the proximal portion of the blade near the handle. So the tip of the blade is much thinner and less wider.

73 MR. KELBERG:

As a result of that, in this kind of knife, assuming this kind of knife is used to inflict two stab wounds like we talked about before, and in one stab wound, it's like we have it in this diagram where the knife goes all the way to the handle, and in the other stab wound, it goes in only to the level depicted in the silhouette, would you expect the width of the wound to differ between those two wounds even though the same knife is involved in both stab wounds?

74 MR. SHAPIRO:

Objection on grounds of relevancy and that it assumes a fact not in evidence in this case. It's already been said this is not the knife.

75 THE COURT:

Overruled.

76 MR. KELBERG:

You may answer the question.

77 DR. LAKSHMANAN:

You would see a difference because in this particular knife, near the tip of the knife, the knife is not as thick as it is in the base of the knife. So the wound which is caused by the knife having penetrated the body fully, you would find that one end of the knife will be slightly blunted whereas if the knife had only penetrated up to the--this mark (Indicating) portion of it, the knife will look as though it is not blunt on one end. It will look as though sharp on both ends.

78 MR. KELBERG:

Is the width of the wound--if the penetration is not as deep, is the width of the wound going to appear narrower?

79 DR. LAKSHMANAN:

Yes.

80 MR. KELBERG:

Than the width of the wound if there is penetration all the way?

81 DR. LAKSHMANAN:

Yes. In this knife, yes.

82 MR. KELBERG:

And assuming that that same knife is used with multiple stab wounds, that same kind of knife with the tapering effect, can you end up on a single individual with many stab wounds, all of which have different widths?

83 DR. LAKSHMANAN:

Yes.

84 MR. KELBERG:

All of which have different lengths of the wounds on the body?

85 DR. LAKSHMANAN:

Yes.

86 MR. KELBERG:

All of which have different depths of penetration?

87 DR. LAKSHMANAN:

Yes. Especially if the knife also has had some rocking motion to it.

88 MR. KELBERG:

And we're going to get to that on this form 336 in just a moment. Doctor, if we can move to the lower part of the same chart, 336, what is intended to be conveyed by this particular box?

89 DR. LAKSHMANAN:

This is to show a factor which must be kept in mind when you evaluate knife wounds. If the knife has penetrated a part of the body which is compressible like the abdomen where you can press and the knife can go all the way in and you can also press the skin surface, there's no bony structure there, then the compressibility factor would make the knife penetrate much deeper into the body cavity. So what you will have in that situation is, after the knife has been withdrawn--this is an example. The abdomen has been--let's assume this is the abdomen and this is a structure in the abdomen (Indicating). The knife has compressed the abdominal wall and the whole knife blade has gone quite a significant depth in the cavity. But when the knife is withdrawn, the abdominal compressibility factor is taken away. The length of the wound track in the body remains the same, but it does not really reflect the length of the blade because the body compression has created an additional length in the wound track in the body.

90 MR. KELBERG:

In that situation, doctor, does the depth of the wound appear longer than the actual length of the blade that has penetrated the body?

91 DR. LAKSHMANAN:

Yes.

92 MR. KELBERG:

Does that create difficulties for you as a forensic pathologist with respect to identifying the specific length of a single knife which may have caused a multitude of stab wounds on a single person?

93 DR. LAKSHMANAN:

Yes. That is why when a forensic pathologist reviews the wounds of the body, you would like to pick a wound like is shown on this upper part of this board where there is a simple penetration and you are confident that the wound track would reflect the true length of the blade as much as possible rather than pick a wound where you have this compressibility factor which is added to the length of the weapon.

94 MR. KELBERG:

Doctor, I don't think you provided more definition with respect to this concept of the elasticity of the skin and how that affects your ability to get some idea of the measurements of a knife blade. Can you elaborate on that, please?

95 DR. LAKSHMANAN:

The skin is in a state of tension in the body because of arrangement of elastic fibers in the area called the dermis. Dermis is just below the skin surface and underlying connective tissue. And the orientation of these elastic fibers are in a particular access, particular access in different parts of the body. The perfect example will be the neck area of the body. The--the--these lines of skin tension are called the lines of Langer, but there are other terms used, also called lanes of Krassl, K-R-A-S-S-L, because Langer worked on cadavers, but Krassl worked on living people where he could analyze elasticity better. A perfect example would be the area of the neck. The lines of skin tension run along the crease of your neck in everybody. This--that is why--and this is important, because if you have a wound which is at right angles to the skin tension line, the wound would gape. But if the incision is made along, parallel to the crease, the wound won't gape. The perfect example is when you go for thyroid surgery, the surgeon always makes an incision like this. He doesn't make an incision like this (Indicating), because--

96 MR. KELBERG:

If you'll stop for a second. For the record, your Honor, that Dr. Lakshmanan is going side to side as the way the incision is made on the neck rather than up and down from the chin down towards the toe area.

97 THE COURT:

Yes.

98 MR. KELBERG:

I'm sorry, doctor. Continue.

99 DR. LAKSHMANAN:

So that would be an example to formulate--and these are--these have been well prodded in the body. So surgeons know how to make an incision. You'll see when you go for an appendix always the scars like this (Indicating) unless it's an emergency surgery. Then they'll open the abdomen in the midline. But--so the surgeons know where the lines of skin tension are. And so what happens is, if somebody has a stab wound which is at right angles to these lines of skin tension, the wound will gape. So you have to approximate the wound before you measure. And the same lines of skin tension and the elasticity also will make a wound look smaller than the width of the blade. For example, if the width of the blade is half an inch, if the wound is at right angles or oblique to the skin lines of tension, the wound may look even smaller than what it is supposed to be with the width of the weapon at the point of penetration.

100 MR. KELBERG:

Your Honor, I'm going to ask Mr. Fairtlough to put page 296 from Spitz and Fisher, medical and legal definition of death, 3rd edition, on the elmo and ask that the photograph or the printout that will be presented be marked as our next exhibit, 337.

101 (Peo's 337 for id = printout)
102 (Brief pause.)
103 MR. KELBERG:

Doctor, what are we looking at in this particular photograph from the textbook?

104 DR. LAKSHMANAN:

These are diagrammatic representation of the human body with the distribution of the Langer's lines. If you focus to 180 of the body like the head and neck, which again is an example, we can see--can we go--

105 MR. KELBERG:

Can we zero in, Mr. Fairtlough, on that area, perhaps on the left--

106 DR. LAKSHMANAN:

Let's go to the neck area. Focus. This is the front of the body (Indicating). Can you move the arrow down to the neck area? Can you move the arrow down to the middle of the neck?

107 MR. KELBERG:

Middle of the neck, please.

108 DR. LAKSHMANAN:

Yeah. If--and run the arrow from one end of the right end of the neck to the left end of the neck. Just follow--just follow the lines there, and that will be a reflection of the lines of Langer in the neck area. If a wound is made parallel to this line of Langer (Indicating), the wound will not gap--I mean gape. But if the wound is made at right angles to the line of Langer, the wound will gape. And--

109 MR. KELBERG:

For right angles, Mr. Fairtlough, could you make--

110 DR. LAKSHMANAN:

Perpendicular to the lines of Langer.

111 MR. KELBERG:

--could you make a line that would be perpendicular to the line you just drew in? No. Actually that's--the line you now have drawn, the second line, if you can hold that one on the--what would be the right side of the neck of the schematic and remove the other diagram--the other line--excuse me--if you can. Okay. We're going to--now, if you could draw at a 90-Degree angle, Mr. Fairtlough, to the base of that--Mr. Fairtlough may not have done well in trigonometry.

112 THE COURT:

I think it's geometry.

113 MR. KELBERG:

It may be both, your Honor. I may not have done so well myself. May I have just a moment to confer with Mr. Fairtlough?

114 THE COURT:

You may.

115 MR. KELBERG:

We'll see if our combined knowledge of the subject is sufficient.

116 (Discussion held off the record between the Deputy District Attorneys.)
117 MR. KELBERG:

We're going to try again. Third time's the charm. Fourth time's the charm. Well, that's not exactly 90 degrees, but we'll settle for it.

118 MR. KELBERG:

Doctor, does this depict in general terms the differences--if you take the line that is running along parallel to or superimposed on top of one of these lines of Langer, what kind of width of the wound on the body would you expect to see?

119 DR. LAKSHMANAN:

The--the wound will not gape and would give you a better reflection of the width of the weapon and also the length of the wound would be better reflected for the class characteristic of the weapon. But if the wound is at right angles, the sharp Langer is going up from head to toe, which was just removed from the screen, then the wound would gape.

120 MR. KELBERG:

And do these phenomena create difficulties to you as a forensic pathologist in being able to give precision to the dimensions of any knife, assuming for the sake of argument that a single knife is responsible for a multitude of stab wounds on a human body?

121 DR. LAKSHMANAN:

This is a factor one has to keep in mind, and that is why when you make the measurements, the wound has to be approximated and measured accurately.

122 MR. KELBERG:

Now, I don't know if Mr. Fairtlough can print that out. That's okay. Let's go to the same page and the bottom portion and ask your Honor that this be marked as exhibit 338 when it's printed out.

123 THE COURT:

338.

124 (Peo's 338 for id = printout)
125 MR. KELBERG:

And if we could back up, Mr. Fairtlough, so we can see both sides of the bottom portion and perhaps raise it. Thank you.

126 MR. KELBERG:

Doctor, what is depicted in what appear to be these two photographs from the same page of the book?

127 DR. LAKSHMANAN:

The photograph on the right is a gaping stab wound and the photograph on the left is the same wound after it has been approximated. You can see that an approximation of the wound has a longer length when compared to the wound which is gaping and if you had measured it in the gaping state.

128 MR. KELBERG:

Is it the standard practice for forensic pathologists such as yourself or Dr. Golden when seeing gaping stab wounds, to do an approximation of the wound as it was when inflicted?

129 DR. LAKSHMANAN:

Yes. And measure it in the approximated state.

130 MR. KELBERG:

Now, doctor, in the photograph that's on the left side of what's on the board right now, has something been done to hold the approximated state of the wound?

131 DR. LAKSHMANAN:

There's been adhesive tape applied.

132 MR. KELBERG:

In your practice at the Coroner's office, is it the custom and practice of your forensic pathologists to use such tape to hold the position of the approximated wound?

133 DR. LAKSHMANAN:

No. We approximate the wounds and take a measurement. I think the adhesive tape has been used here so that you can take a good photograph.

134 MR. KELBERG:

Now, if Mr. Fairtlough could print this out as I think I said, your Honor, as exhibit 338?

135 THE COURT:

338.

136 MR. KELBERG:

And go one page beyond and again focus on exactly where you've got it, maybe just a little lower, and if we could move it just a little to the left to see the full right side. And ask, your Honor, that this printout be marked as exhibit 339.

137 THE COURT:

339.

138 (Peo's 339 for id = printout)
139 MR. KELBERG:

Doctor, what are we seeing on the right side and the--actually the left side let's start with--of these two photographs?

140 DR. LAKSHMANAN:

The one on the left shows the--which is gaping and the wound to the right shows an approximated wound that is also an extension of an incision.

141 MR. KELBERG:

Now, the approximated wound, there appear to be some fingernails at the top and a finger at the bottom of the photograph of the approximated wound. Is that what you would expect to see from the forensic pathologist who is approximating the wound for measurement purposes?

142 DR. LAKSHMANAN:

Yes.

143 MR. KELBERG:

And is this the standard procedure that is done by you and the other forensic pathologists at the Coroner's office when dealing with gaping stab wounds?

144 DR. LAKSHMANAN:

Yes.

145 MR. KELBERG:

Now, there appears to be some measuring device in the bottom of both photographs on the left and right side. Do you see that?

146 DR. LAKSHMANAN:

Yes.

147 MR. KELBERG:

And what is reflected by the approximation of that gaping wound?

148 DR. LAKSHMANAN:

It would give a better reflection of the--of the length of the wound than when it was in the gaping state.

149 MR. KELBERG:

And in the approximated state, does the wound have a greater length on the body surface than it would otherwise appear to have in the gaping state?

150 DR. LAKSHMANAN:

Yes.

151 MR. KELBERG:

And does it have a narrower width on the body surface than the gaping wound appears to have?

152 DR. LAKSHMANAN:

Yes.

153 MR. KELBERG:

And if that can just be printed out, I think we're done with that one.

154 MR. KELBERG:

Doctor, you mentioned something about "Incised wound." I think you mentioned the term before. And I want to invite your attention if Mr. Fairtlough can switch hands and photographs and whatever and bring up from the same exhibit the upper right-hand corner.

155 (Discussion held off the record between the Deputy District Attorney and Defense counsel.)
156 MR. KELBERG:

Doctor, what is depicted in the upper right hand box of this exhibit, 336?

157 DR. LAKSHMANAN:

That is the incised wound. And by definition, an incised wound is that the length of the wound of the body surface is greater than the depth. As you can see from the photograph, I mean the projected image on the screen, the depth of the wound is very shallow. Go to the top of the image. You can see the depth reflected there. And the length of the wound on the skin surface is very long compared to the depth. So this wound, which is shown on the projector image, would fit the definition of an incised wound. And this is in contrast to a stab wound where the depth of the wound on the body--in the body will be longer than the length of the wound on the body surface.

158 MR. KELBERG:

And for that comparison, doctor, I don't know if Mr. Fairtlough needs to change images, but if we go back to the upper left-hand block of this exhibit, 336, is that clearly shown by what we are seeing on that board?

159 DR. LAKSHMANAN:

Yes. And actually the one which I showed where the compressibility shows it much better.

160 MR. KELBERG:

All right. If Mr. Fairtlough--he's got that already.

161 DR. LAKSHMANAN:

See, the--in this particular wound, you can see that the length of the body surface is much shorter compared to the length of the wound--I mean the depth of the wound, and this would fit the definition of a stab wound. So to repeat, incised wound, the length of the wound of the body surface is longer than the depth and the stab wound, the depth of the wound is longer than the length of the wound in the body surface.

162 MR. KELBERG:

Doctor, if you have an incised wound, are you able to use that kind of wound to assess class characteristics of the knife that inflicted that incised wound?

163 DR. LAKSHMANAN:

No.

164 MR. KELBERG:

Why not?

165 DR. LAKSHMANAN:

Because you can have a single-edged blade cause an incised wound and you will not be able to differentiate it from an incised wound from a double-edged knife because only one edge is being used and it can very well cause a cut.

166 MR. KELBERG:

Can you use an incised wound to assess the length of the blade of any particular knife that may have inflicted that incised wound?

167 DR. LAKSHMANAN:

No.

168 MR. KELBERG:

Why not?

169 DR. LAKSHMANAN:

Because you can have a very small--even a pocketknife that can cause a seven-inch long wound of the body surface and you can not use the length of the wound of the body surface to gauge the length of the knife.

170 MR. KELBERG:

Can you use the depth of an incised wound, which is as you say by definition, is going to be shorter than the length of the wound on the body, can you use the depth of the wound to identify class characteristics of the knife with respect to length of the blade for example?

171 DR. LAKSHMANAN:

No.

172 MR. KELBERG:

Width of the blade?

173 DR. LAKSHMANAN:

No.

174 MR. KELBERG:

Thickness of the blade?

175 DR. LAKSHMANAN:

No.

176 MR. KELBERG:

Now, doctor, I'm going to show you exhibit 335. You mentioned differentiating a single-edged blade from a double-edged blade. Let me show you that knife. Are you familiar with in general terms the kind of knife that that is?

177 DR. LAKSHMANAN:

This is a double-edged knife. It looks like a dagger.

178 MR. KELBERG:

Let me ask Mr. Fairtlough if he would, please, to just put this up on the elmo. And also, I'll ask him--let me borrow that. Does Mr. Fairtlough still have the other--doctor, by any chance, do you have the other knife?

179 DR. LAKSHMANAN:

Oh, yes. I'm sorry.

180 MR. KELBERG:

Exhibit 333. Let me ask if Mr. Fairtlough can put these side by side. 333 you've already said is a single-edged blade. Can you indicate, doctor, what is the difference between a double-edged blade and the single-edged blade?

181 DR. LAKSHMANAN:

In double edge, both the edges are sharp, and that is the main difference between the double edge and the single edge.

182 MR. KELBERG:

And Mr. Fairtlough is turning the exhibit, 335, the double-edged blade on its side. Is this one of the sharp edges?

183 DR. LAKSHMANAN:

Yes.

184 MR. KELBERG:

And if he turns it 180 degrees, is this the other sharp edge?

185 DR. LAKSHMANAN:

Yes. Yes.

186 MR. KELBERG:

In comparison with the exhibit 333, as he's turned it here, is this the blunt end?

187 DR. LAKSHMANAN:

Yes.

188 MR. KELBERG:

And 180 degrees, and that is the sharp end?

189 DR. LAKSHMANAN:

Yes.

190 MR. KELBERG:

Or edge I should say?

191 DR. LAKSHMANAN:

Yes.

192 MR. KELBERG:

Thank you, Mr. Fairtlough.

193 MR. KELBERG:

Now, doctor, if we could move to the bottom box of exhibit 336, and I think Mr. Fairtlough will join us in a moment. What does this represent?

194 DR. LAKSHMANAN:

This is what is a complex stab incised wound which is being diagrammatically represented. And what we have is not only the twisting of the weapon during penetration as you can see from the arrows going in a clockwise direction around the blade, and we also have a component of rocking motion to the knife which would create a greater length on the skin surface than the--than what the width of the knife should really reflect. So you not only have turning and twisting of the weapon, but you also have the--an incised component.

195 MR. KELBERG:

Doctor, with the Court's permission, could you step down in front of the jury box, and let me hand you exhibit 333. I've known you a long time. I assume you will not use this in anything but a careful manner. Can you demonstrate without penetration on me what it is that is this turning and rocking motion that you're talking about?

196 DR. LAKSHMANAN:

It could be two ways this can happen. Either the victim moves and the knife is being penetrated or the knife could be turning when the penetration is taking place, and this is the dominant twisting of the weapon when it happens (Demonstrating). The other one is not only is the knife penetrating, but also there is a cutting component to the penetration when it's being inflicted or when the knife is being penetrated, the victim pulls themselves away from the weapon. So that can also cause a complexity and creating the cutting component to the penetrating stab wound.

197 MR. KELBERG:

Doctor, if you use my arm as the area which is going to be penetrated without penetrating as I say and without blocking the view of any jurors--I think you're going to have to back up just a bit--can you demonstrate what you're talking about by just bringing the tip to the edge of my arm?

198 MR. SHAPIRO:

Your Honor, I'm going to object to this.

199 THE COURT:

Overruled. Do you want to come over here and watch?

KEY QUOTE
200 MR. SHAPIRO:

No, thank you. I can see.

201 DR. LAKSHMANAN:

This is called twisting (Demonstrating).

202 MR. KELBERG:

You'll have to keep your voice up, doctor.

203 DR. LAKSHMANAN:

Twisting and also creating a cutting component (Demonstrating).

204 MR. KELBERG:

And if the victim moves, in this case, my arm, at the time that the knife is being penetrated, what effect if any does that have on the appearance of the wound on the body after the knife is withdrawn?

205 DR. LAKSHMANAN:

It will be a complex wound which will have characteristics which are different from a simple penetration which is the wound you look for to compare cause characteristics.

206 MR. KELBERG:

And how will the wound appear with respect to the accuracy of the actual thickness of the blade, the width of the blade and the length of the blade?

207 DR. LAKSHMANAN:

There will be a lot of variability in the wound. You really will not be able to use that wound for this kind of analysis. It will not reflect even reasonable accuracy.

208 MR. KELBERG:

You'll have to--let me get--let me take that back from you, and if you'll retake the stand.

209 (The witness complies.)
210 MR. KELBERG:

Doctor, does that aspect, this complex stab incised wound, create difficulties for you as a forensic pathologist looking at a body with multiple wounds of that type to identify with any precision the actual characteristics of the knife; that is the length of the blade, the width of the blade, the thickness of the blade?

211 DR. LAKSHMANAN:

It will be difficult when you use such a wound to do that kind of analysis. So that is why, as I mentioned earlier, forensic pathologist has to study all the wounds of the body and then pick the wounds which would reflect best a simple penetration which would better give--which would give a better evaluation of a class characteristic of--class characteristic of a suspect weapon.

212 MR. KELBERG:

And even in the circumstance of a simple stab wound as indicated in the upper left-hand box, can you with precision identify the length of the blade, the width of the blade, the thickness of the blade?

213 DR. LAKSHMANAN:

You can--you can analyze the--those factors, but as I mentioned earlier, you now have to keep in mind the elasticity factor in mind when you make such--when you give an opinion as to a particular weapon causing a particular wound.

214 MR. KELBERG:

Doctor, in your practice of many years, in your experience with many cases of sharp force injuries, how common is it for you as a forensic pathologist to be able to identify a specific knife to a specific stab wound in a particular case?

215 DR. LAKSHMANAN:

We have done it a few times when the knife is left on the body penetrated and the knife is still in the body. The other is when the knife tip breaks and you recover the weapon where the other part of the broken knife, you can match the broken tip to the weapon. And we have done it on a--I mean, we have had cases like that. And of course, the other serological markers will also help, if there's blood staining on the knife belonging to a particular victim and the knife is found, and that may also help. But as far as wound characteristics go and correlating the particular weapon, these would be two situations where you could be precise, that you have a bit of the knife that matches the weapon or you have the knife in the body.

216 MR. KELBERG:

And absent those situations, dealing exclusively with wound characteristics of depth of penetration, length of wound on the surface and width of the wound on the surface, in your experience, are you able to identify a specific knife's dimensions that may be responsible for any stab wound?

217 DR. LAKSHMANAN:

We can estimate a class characteristic of a group of weapons, but it would be difficult to estimate a particular weapon to all the wounds.

KEY QUOTE
218 MR. KELBERG:

Doctor, is there anything further about this chart that you need to identify for a better understanding of sharp force injuries and knife class characteristics?

219 DR. LAKSHMANAN:

No.

220 MR. KELBERG:

Your Honor, I have another board.

221 (Brief pause.)
222 MR. KELBERG:

I believe--is this 340, your Honor, exhibit 340? I've lost track now.

223 THE COURT:

340.

224 (Peo's 340 for id = board)
225 MR. KELBERG:

May this board then be marked as exhibit 340 entitled "Wound characteristics and possible sources"? And, Mr. Fairtlough, if you could go to the top portion.

226 MR. KELBERG:

Doctor, in general terms, what is this chart intended to depict?

227 DR. LAKSHMANAN:

This is to depict the wound characteristics on the body surface correlating it with the width and thickness of the blade.

228 MR. KELBERG:

Now, doctor, is the appearance of the wound on the body surface, the ends in their appearance, of significance to you as a forensic pathologist in identifying a class of knife or classes of knives which could have inflicted that particular injury?

229 DR. LAKSHMANAN:

Yes.

230 MR. KELBERG:

In what manner?

231 DR. LAKSHMANAN:

If you look at the image projector on the screen, the appearance of the wound which you see, you have a sharp end--I mean, you have a sharp end in the lower part and a blunt squared off end on the upper part. This is the appearance of the wound on the body surface of a simple penetration of a single-edged knife where the upper part would reflect the blunt end of the weapon.

232 MR. KELBERG:

Now, doctor, the simple stab wound was like that first block that we looked at in the previous exhibit, 336?

233 DR. LAKSHMANAN:

Yes.

234 MR. KELBERG:

In looking at this particular correlation between sharp and blunt ends; is that correct?

235 DR. LAKSHMANAN:

Yes.

236 MR. KELBERG:

And using our exhibit 333, can you point out what it is, which part of the knife leaves which aspect of the wound characteristic?

237 DR. LAKSHMANAN:

The squared--

238 MR. KELBERG:

And hold it up high, please.

239 DR. LAKSHMANAN:

The squared-off end of the wound, the upper part which the arrow is pointing to, is reflected by this blunt end of this knife. The sharp end of the lower part of that wound on the projected image is reflected by the cutting edge of this blade (Indicating).

240 MR. KELBERG:

Now, doctor, if the depth of penetration that creates the blunt and sharp ends, if the depth of penetration changes using this same knife and the knife has a taper as you indicated before, how does that affect what you're going to see with respect to the blunt end and the sharp end?

241 DR. LAKSHMANAN:

You will not have the same squared-off end on the upper part. If you go to the lower picture, you may have a picture like wound no. 2 here (Indicating).

242 MR. KELBERG:

Mr. Fairtlough is going to move us down I think.

243 DR. LAKSHMANAN:

So if the knife only penetrated a portion, the same knife would--could--may create a wound which is sharp on both upper and lower ends.

244 MR. KELBERG:

And there are some red lines that go from the top and bottom of wound no. 2 back to that top knife. That top knife is to represent a single-edged blade?

245 DR. LAKSHMANAN:

That's correct.

246 MR. KELBERG:

And that's the kind like you're holding, 333?

247 DR. LAKSHMANAN:

Yes.

248 MR. KELBERG:

And at this depth of penetration, this is a--a narrower penetration, not as deep; is that--

249 DR. LAKSHMANAN:

It's a shadow penetration.

250 MR. KELBERG:

All right. And you're basically at--closer to the end of the knife blade; is that accurate?

251 DR. LAKSHMANAN:

Yes.

252 MR. KELBERG:

And when you do so, then you're going to see something in the way of the wound pattern that is different than the one we just saw even though it's made by the same knife?

253 DR. LAKSHMANAN:

Yes.

254 MR. KELBERG:

Are you trained to look for those things?

255 DR. LAKSHMANAN:

Yes.

256 MR. KELBERG:

And do you have experience in identifying those things?

257 DR. LAKSHMANAN:

Yes.

258 MR. KELBERG:

Now, according to this, we also have something "Or double-edged knife." Explain that for us, if you would, please.

259 DR. LAKSHMANAN:

We had this dagger type knife shown earlier which is sharp on both ends. When that knife causes a penetrating wound, you would have a wound as is seen in diagram no. 2, which is the--both the upper and lower ends being shot.

260 MR. KELBERG:

Doctor, let me hand you exhibit 335. And if you'll hold it up high, and you can use the pointer with the board we have here rather than just looking at the screen. Show us what you mean.

261 DR. LAKSHMANAN:

This dagger type knife has a sharp end on both sides, and this knife, when there's a simple penetration, will leave a wound just like you see on item 2 here with sharp ends both--at both ends of the wound of the body surface.

262 MR. KELBERG:

And where the red dotted lines go from the top and the bottom to the depiction on the exhibit 340, is that to show the portion of the knife blade that leaves those two sharp ends?

263 DR. LAKSHMANAN:

Yes.

264 MR. KELBERG:

Doctor, you may retake the stand.

265 (The witness complies.)
266 MR. KELBERG:

Is this situation of the double-edged blade one that is created by a similar, that is simple stab wound like we saw before in the very first box of the earlier chart, 336?

267 DR. LAKSHMANAN:

Yes.

268 MR. KELBERG:

How do you as a forensic pathologist or can you as a forensic pathologist differentiate--if you see such a wound characteristic, two sharp ends, how can you differentiate if at all between whether it's a single-edged knife blade or a double-edged knife blade?

269 DR. LAKSHMANAN:

It will be very difficult because you can have a very thin, not so thick single-edged knife with a tapering end which can simulate the same appearance. So when you have a wound like that, you can not say with certainty whether it was a double-edged knife or a single-edged knife, and this is in contrast to wound pattern no. 1 where you have a definite blunt edge where you can say with definite reasonable certainty that it was only caused by a single-edged knife and not a double-edged knife.

270 MR. KELBERG:

Now, I would like you to talk about the last entry, item no. 3, and the pattern that is depicted in this schematic.

271 DR. LAKSHMANAN:

Pattern no. 3 has a sharp--this again the body surface. You're showing a wound appearance on a body surface--has a sharp end in the lower end, but the other end is forked on the upper end. It's forked. Now, this could happen in two fashions. One--and again, if the knife is--if the single-edged knife is very blunt--towards the base of the knife, some knives are very thick and the thickness is up to one-eighth of an inch--those kinds of knives, when they do a simple straight penetration, they--the wound will appear forked on the skin surface because of the width of the--I mean, due to the thickness of the blade.

272 MR. KELBERG:

Doctor, showing you what I think is our exhibit 334, this appeared to have been the thicker of the two Forschner single-edged blade knives; is that correct?

273 DR. LAKSHMANAN:

Yes.

274 MR. KELBERG:

Can you point out using that exhibit what it is you're talking about with respect to the thicker blunt end?

275 DR. LAKSHMANAN:

This knife as we go to the base is quite thick near the base. And actually if the knife is even thicker than this, you can get a forking which you just see in item no. 3 on the poster. Because what happens is, each end of this thick blade will act like a cutting edge and split the skin. But you can also get the same appearance from twisting of the weapon.

276 MR. KELBERG:

Twisting of what kind of weapon, doctor?

277 DR. LAKSHMANAN:

From a double-edged knife. Even though this is a single-edged knife with a pointed end and a forked end, you can have a double-edged knife which can cause a similar wound if there's some twisting of the weapon.

278 MR. KELBERG:

Once again, doctor, how can you differentiate if at all as to whether it's a single-edged knife or a double-edged knife if you see a wound pattern such as is shown in diagram 3?

279 DR. LAKSHMANAN:

You will have difficulty. You have to be--you have to analyze the wound and also see how thick the forking is. If the forking is between one-sixteenth or one-eighth inch, it would--it could very well be from a thick single-edged blade. But you can not exclude a double-edged knife.

280 MR. KELBERG:

Now, doctor, in your experience and training, are these aspects of wound characteristics and class characteristics of knives in trying to correlate one with the other what you would describe as bread and butter forensic pathology?

281 DR. LAKSHMANAN:

Yes.

282 MR. KELBERG:

Anything esoteric about them?

283 DR. LAKSHMANAN:

No.

284 MR. KELBERG:

Is there anything further about this exhibit 340 that we need to talk about?

285 DR. LAKSHMANAN:

No.

286 MR. KELBERG:

Your Honor, I'm not sure that we marked this as exhibit 341. I think it should be.

287 THE COURT:

All right. 341. What's the title of the board?

288 MR. KELBERG:

"Wound characteristics and possible sources." I'm sorry. It was marked as 340.

289 THE COURT:

All right.

290 MR. KELBERG:

I stand corrected.

291 MR. KELBERG:

Doctor, I want to change topics for a moment and discuss something called blunt force trauma. You mentioned it I think on Friday, and let's discuss it if we could, please, in a little more detail. First of all, your generalized definition of what blunt force trauma is.

292 DR. LAKSHMANAN:

Blunt force trauma is injuries caused by blunt force which could be anywhere from, as I mentioned earlier, a hammer or a two-by-two striking a person or a vehicle striking a person, an auto with a pedestrian injury where you have multiple injuries where the force is a blunt type force.

293 MR. KELBERG:

Your Honor, I have another chart that I would ask to be marked then as exhibit 341, and it is entitled "Blunt force trauma."

294 THE COURT:

People's 341.

295 (Peo's 341 for id = chart)
296 MR. KELBERG:

And I think--Mr. Fairtlough, do you have this?

297 MR. KELBERG:

Doctor, we don't have this to put on the overhead. So if you could step to the board, the exhibit 341, and tell us what is shown in this exhibit.

298 THE COURT:

All right. 165, can you see that?

299 JUROR NO. 165:

Yes, sir.

300 THE COURT:

All right. Thank you.

301 MR. KELBERG:

Go ahead, doctor.

302 THE COURT:

Proceed.

303 DR. LAKSHMANAN:

We have a general structure of the skin here. The surface of the skin has some layers of cells which is called the epidermis, and then you have below that the dermis in which you have the hair follicles and the sweat glands, and this is where your elastic fibers and Langer's lines I discussed is in this region, and then you have the subcutaneous tissue, which is the fatty tissue and then you have facial muscle underneath that (Indicating). This is the general structure of the skin, a cross-section of it. Now, you have different types of blunt force which can leave markings on the skin, and you can tell the difference by looking at the appearance of the wound.

304 MR. KELBERG:

Doctor, if you could retake the stand for just a second. I want to talk about some of the topics of blunt force trauma that on the board. First of all, there's the word under no. 1 "Abrasions." Is that a form of blunt force trauma?

305 DR. LAKSHMANAN:

Yes.

306 MR. KELBERG:

What is an abrasion?

307 DR. LAKSHMANAN:

An abrasion is the scraping of the skin. It generally reflects scraping of the epidermis which is the cells on the top of the surface of the skin, this area (Indicating), and that is an abrasion and there could be different types of abrasion injury.

308 MR. KELBERG:

And under 1, we have A, something called "Punctate abrasions." Does that term have significance to you as a forensic pathologist?

309 DR. LAKSHMANAN:

Yes.

310 MR. KELBERG:

What is it?

311 DR. LAKSHMANAN:

That is an abrasion which is very small and punctate on the skin surface.

312 MR. KELBERG:

When you use a definition within a definition, I have to ask--

313 DR. LAKSHMANAN:

Punctate means minute, small area.

314 MR. KELBERG:

And B is something called "Pattern abrasions." What are those?

315 DR. LAKSHMANAN:

Pattern is when--when you have a scraping of the skin which is patterned, following the pattern of the object inflicting that injury. Like if somebody is wearing a weaved dress and they have a blunt force striking them over the dress, the dress could leave a pattern on the skin. That could be pattern abrasion. But you could have an object hitting a surface without any clothing on the surface, but the object may have a pattern to it, which could leave a pattern on the skin surface. So that would be an abrasion injury with a pattern. But usually such injuries, when you have an object striking the body which leaves a pattern, will usually be an abrasion contusion. That is, you'll also have bruising of the tissue underneath that area of injury.

316 MR. KELBERG:

Before we get further definition of that, number one, do you have training as a forensic pathologist in being able to identify abrasions?

317 DR. LAKSHMANAN:

Yes.

318 MR. KELBERG:

What is it you look for?

319 DR. LAKSHMANAN:

You look at the skin surface. And especially if it's a graze abrasion, which an example would be a bullet swiping the surface of the body without penetrating the body, or a scratch abrasion like a fingernail scratching the body surface, then what happens is, in these type of forces, the skin--top layer skin is peeled off the surface. So you can tell direction by looking at which end of the wound has piling of the epithelium. For example, in this tangential graze or scratch type abrasion, the skin is being peeled off. Of course, this reflects the epidermis. You have a piling of the epithelium on one end, and you can see this under just gross examination. You may use a magnifying glass. You may need to use magnifying glass sometimes, but you will able to see this. And this would reflect either the force went in this direction or the body moved in this direction against that rough surface (Indicating).

320 MR. KELBERG:

Just for the record, your Honor, the force would be moving left to right across exhibit 341 where the "Tangential" word appears, and if the body was moving, the direction would be from the right side of the exhibit to the left side as the doctor indicated.

321 THE COURT:

Noted.

322 MR. KELBERG:

Now, doctor, what would you as a forensic pathologist expect to see in the way of coloration from an abrasion that is inflicted while a person is alive?

323 DR. LAKSHMANAN:

The abrasions could be anywhere from red brown to darker colors. And as you can see, that the epidermis is not just a flat surface. It's got some undulations. And underneath the undulations, you have what is called the Rete ridges, R-E-T-E R-I-D-G-E-S, of the dermis where there's vascular channels, which are vessels. So when you have an abrasion, you can also have some bleeding from the underlying ridges, which I just alluded to, and you could have some bleeding from an abrasion or oozing of blood and fluid from the abrasion. So--so by looking at the abrasion, you will be able to tell whether it looks antemortem, when the person was alive, and--or if it happened postmortem, when the abrasion will not be the reddish brown appearance, you'll have a more pale brown appearance. But if you just have an abrasion just involving the epidermis, sometimes it's difficult when you don't have any bleeding component to it.

324 MR. KELBERG:

Exhibit 341 also has a term under "Graze" and "Scratch." Are you familiar with that term, "Brush burn"?

325 DR. LAKSHMANAN:

Yes.

326 MR. KELBERG:

What is that?

327 DR. LAKSHMANAN:

"Brush burn" is caused by friction of rubbing against a rough surface where a large area of the body is involved like somebody dragging a person with the skin coming in contact with the ground surface as they're being dragged. That would be one example. The other example, where somebody who is a pedestrian is hit by a car and then they're thrown off and then they are thrown--dragged along the surface, and that would be an example of--these would be examples of brush burns. So basically, it's caused by the friction of rubbing of the surface, against a rough surface.

328 MR. KELBERG:

And how if at all are you able to distinguish as a forensic pathologist between what is a brush burn abrasion and a graze abrasion?

329 DR. LAKSHMANAN:

Well, graze abrasion is more localized to an area, but a brush burn is usually a terminology used for a larger area of an abrasion in the situations I just described.

330 MR. KELBERG:

Doctor, you mentioned the word "Contusions." I think you've mentioned it several times in the course of your testimony. What is a contusion?

331 DR. LAKSHMANAN:

A contusion is the crushing of the soft tissues where the surface of the skin need not necessarily be broken. That will be just a plain contusion, where the skin surface is not broken, but the tissues are crushed and the vessels in the soft tissues bleed. And in lay terminology, this would be a bruise.

332 MR. KELBERG:

Doctor, when you say that the skin surface may not be affected, would you be able to see anything as a forensic pathologist looking at the skin surface of someone who has sustained such a contusion?

333 DR. LAKSHMANAN:

It will be intact. You'll have a bruising of the soft tissues without the skin surface being affected because if the skin surface has an abrasion like I just mentioned when I described pattern abrasion caused by a force, then you'll have an abrasion component and a contusion component.

334 MR. KELBERG:

Doctor, assuming that a person has a beating heart, an adequate blood pressure at the time the contusion is sustained, would there be any obvious indication by color on the surface of the person's body that such event has occurred?

335 DR. LAKSHMANAN:

Yes. You'll have bleeding in the soft tissues and then you can tell that this happened when the person had blood pressure. Usually a fresh abrasion will be a reddish blue or a bluish purple color.

336 MR. KELBERG:

I'm sorry. You said fresh abrasion.

337 DR. LAKSHMANAN:

I mean fresh contusion. I'm sorry.

338 MR. KELBERG:

And what would you expect to see if you have one of these situations where you have both an abrasion and a contusion? From the same event; is that correct, doctor?

339 DR. LAKSHMANAN:

Yes.

340 MR. KELBERG:

What do you respect to see then?

341 DR. LAKSHMANAN:

You would see an abrasion, and underlying that area of abrasion, you'll see the contusion. And sometimes the abrasion may involve the entire area of contusion or, depending on what kind of force was involved, you may have a smaller area of abrasion surrounded by a large area of contusion.

342 MR. KELBERG:

Doctor, would you describe these aspects of forensic pathology as bread and butter issues?

343 DR. LAKSHMANAN:

Yes.

344 MR. KELBERG:

Anything further that you wish to add about contusions?

345 DR. LAKSHMANAN:

Nothing further.

346 MR. KELBERG:

And the third entry says something about "Lacerations." Is that another form of blunt force trauma?

347 DR. LAKSHMANAN:

Yes.

348 MR. KELBERG:

What is that all about?

349 DR. LAKSHMANAN:

Laceration occurs when the--when a blunt force strikes the skin surface. And underlying the skin surface, there is a bony structure which offers resistance. The perfect example would be your skin surface on your skull or forehead area. So if you have a blunt force striking that area, the skin is sandwiched and you have the resisting bony structure underlying the skin. So the skin would tear under--when such a force is applied. And an example would be like somebody's head being hit with a crowbar or somebody--or by a two-by-two. You'll have a tear in the skin.

350 MR. KELBERG:

And in the lower portion of our exhibit 341, there appears to be some schematic representation with the word "Laceration." What is that intended to show?

351 DR. LAKSHMANAN:

That intends to show several things. One, when you have a blunt force which causes the tear, as I just described, you'll also have the contusion and abrasion of the edges. You'll also--since it's a tear of the skin, it won't be a clean-cut tear. You'll have some bridging of tissue in the depth of the laceration.

352 MR. KELBERG:

And again, is that a bread and butter issue for a forensic pathologist such as yourself?

353 DR. LAKSHMANAN:

Yes.

354 MR. KELBERG:

Doctor, in examining the body of someone like Nicole Brown Simpson or Ronald Goldman, do you attempt to correlate blunt force trauma with the environment in which the decedent's body was found?

355 DR. LAKSHMANAN:

Yes.

356 MR. KELBERG:

Why do you do that?

357 DR. LAKSHMANAN:

Because it tries to explain the injuries you have observed and documented, and you try and see which environmental factor could be responsible for a particular injury.

358 MR. KELBERG:

And you testified earlier that you have twice visited 875 South Bundy; is that correct?

359 DR. LAKSHMANAN:

Yes.

360 MR. KELBERG:

Was one of your purposes in making those visits to look at the environmental surroundings from the standpoint of what could be responsible for any blunt force trauma identified on the bodies of Nicole Brown Simpson and Ronald Goldman?

361 DR. LAKSHMANAN:

That is correct. I also saw the location of the various structures in relationship to each other.

362 MR. KELBERG:

Doctor, in general terms, can blunt force trauma be caused by somebody's fist to another person's head?

363 DR. LAKSHMANAN:

Yes.

364 MR. KELBERG:

So it doesn't require some object. It can be a body part striking another person's body part?

365 DR. LAKSHMANAN:

Yes.

366 MR. KELBERG:

Is there anything else, doctor, in general terms that you want to point out regarding blunt force trauma?

367 DR. LAKSHMANAN:

I think we have covered the highlights.

368 MR. KELBERG:

Your Honor, I have another small board. May this be marked as exhibit 342, entitled, "Terminology describing when injuries were received relative to the time of death"?

369 THE COURT:

All right. Why don't we pull that up. Can we move that up just a little? Can we move it up just a little?

370 MR. KELBERG:

Mr. Fairtlough or Mr. Lynch. I'm mechanically inept. So I'm sure I'll break this thing if I try.

371 THE COURT:

All right. Mr. Fairtlough.

372 (Brief pause.)
373 (Peo's 342 for id = board)
374 THE COURT:

Thank you.

375 MR. KELBERG:

You've already I think used two of these terms, doctor, but would you take us through these three terms, what they mean to you as a forensic pathologist?

376 DR. LAKSHMANAN:

Antemortem means occurring before death. Perimortem means occurring around the time of death and postmortem means occurring after death.

377 MR. KELBERG:

And going back just to sharp force injuries, are you trained as a forensic pathologist to look at whether a stab wound, for example, was inflicted before the person died, at or around the time the person died or after the person was dead?

378 DR. LAKSHMANAN:

Yes.

379 MR. KELBERG:

What do you look for?

380 DR. LAKSHMANAN:

When you have a stab wound, you have injury to the structures of the body, and if the person is alive, they would have blood pressure. So there would be bleeding in the tissues along the track of the wound. And looking just at the wound and the bleeding pattern, you will know that the wound was inflicted when the person had blood pressure and was alive. This is in contrast to a person who is dead. You won't have the same amount of hemorrhage into the tissues. You won't have any hemorrhage in the tissues because they don't have any blood pressure.

381 MR. KELBERG:

And this middle term of "Peri mortem," occurring at or around the time of death, how if at all can you distinguish between an antemortem and a perimortem stab wound?

382 DR. LAKSHMANAN:

The perimortem will have some hemorrhage, but not much hemorrhage. It would mean that the person sustained the wound towards the end of the--just before the person died or when the person was almost in shock when the bleeding for a particular wound should have been more significant than what you see in the wound track.

383 MR. KELBERG:

What does "Shock" mean?

384 DR. LAKSHMANAN:

Shock is when you completely lose your blood pressure. And to put it in simple terms, the--an organ or a part of the body doesn't get any blood supply because the heart is not pumping the blood, there's no blood pressure. So there's no profusion of the tissues in the different parts of the body.

385 MR. KELBERG:

"Profusion" means just the blood supply getting to those areas of the body?

386 DR. LAKSHMANAN:

Yes.

387 MR. KELBERG:

So can a person be alive, but as a result of shock, have very low blood pressure?

388 DR. LAKSHMANAN:

Yes.

389 MR. KELBERG:

And if that is the case, what will you find with respect to this hemorrhaging in a stab wound that is inflicted at the time the person is in shock?

390 DR. LAKSHMANAN:

It will not have the same amount of bleeding which you would expect in a person who had full blood pressure. You'll still see some bleeding. That's how you can still classify it as perimortem because if you don't see bleeding and--it could very well be a postmortem wound also.

391 MR. KELBERG:

Now, how about blunt force trauma? How do you differentiate the three when you have evidence of an abrasion for example?

392 DR. LAKSHMANAN:

An abrasion, as I told you, you have the--the effect of the skin surface being peeled. And let's say there's no bleeding. Still, any reaction to the body which occurs during life will have what's called a vital reaction to it because there's what's called inflammation reaction of the body which is normal. If you scratch yourself on the skin surface, you will see there's a red line coming on to it. You are not causing any injury to the skin. If you all just practice and just scratch your skin on the surface, you'll see a red line. And that is the vital reaction the body does. It's an inflammation reaction, is to--is due to production of certain hormones which causes dilatation of the vessels and causes this hyperemia or engorgement of the vessels, is due to release of some hormones like histamine and serotonin, S-E-R-O-T-O-N-I-N. So that's one factor you will see, which is kind of--you can see is a vital reaction.

393 MR. KELBERG:

What other factors if any would you be looking for to distinguish an antemortem from a perimortem abrasion?

394 DR. LAKSHMANAN:

The appearance. The--just the appearance, the--as I told you, the bruise, you'll have bleeding. In abrasions, you'd be more reddish brown and dark reddish brown. One way to definitely prove your point would be to take a microscopic section and look at the tissue or you can also do analysis of the tissue, which is not readily available to study for this--the presence of these hormones.

395 MR. KELBERG:

And how do you distinguish postmortem?

396 DR. LAKSHMANAN:

Postmortem will be pale and you won't have any bleeding or any reaction to the tissue if you take a microscopic section.

397 MR. KELBERG:

How about on contusions? Is there any difference in what you're looking for to distinguish an antemortem, perimortem or postmortem contusion?

398 DR. LAKSHMANAN:

Postmortem, you won't get--you won't have the bleeding to the tissues as you see with an antemortem contusion.

399 MR. KELBERG:

Your Honor, I have another chart.

400 MR. KELBERG:

I guess we're going to be moving into, doctor, the actual protocols in these two cases, Ronald Goldman and Nicole Brown Simpson.

401 MR. KELBERG:

Your Honor, I would ask that this chart entitled "Anatomical terms" be marked as exhibit I think 343.

402 THE COURT:

343.

403 (Peo's 343 for id = chart)
404 MR. KELBERG:

I should have watched Mr. Fairtlough. I may have been able to do this on my own.

405 (Brief pause.)
406 MR. KELBERG:

Doctor, when you as a forensic pathologist look at wounds on the body, do you attempt to describe the location of any such wound when you are dictating an autopsy protocol?

407 DR. LAKSHMANAN:

Yes.

408 MR. KELBERG:

These terms that are used, these six terms that are used on our exhibit 343, do they have meaning to you as a forensic pathologist for the purposes of identifying where on the body a particular wound is located?

409 DR. LAKSHMANAN:

Yes.

410 MR. KELBERG:

What do they mean to you, doctor?

411 DR. LAKSHMANAN:

Anterior means towards the front of the body. Posterior means towards the back of the body.

412 MR. KELBERG:

If you'll stop. When you say the front of the body, are you talking about the front chest area?

413 DR. LAKSHMANAN:

Yes.

414 MR. KELBERG:

Okay. And the back of the area would be to literally the backside?

415 DR. LAKSHMANAN:

Yes.

416 MR. KELBERG:

Are these relative terms; that is a wound may be anterior to something or posterior to something?

417 DR. LAKSHMANAN:

Yes. But still, the--what anterior means, that means that particular structure in the context you're describing was towards the front of the body.

418 MR. KELBERG:

What about 3 and 4? What do they represent?

419 DR. LAKSHMANAN:

Superior and inferior refers to--superior means towards the head region. Inferior means towards the toe region. And of course, the diagram you have on the poster board is the body, anatomic position.

420 MR. KELBERG:

Let me ask you, is that a recognized term of art, "The anatomic position"?

421 DR. LAKSHMANAN:

Yes. "The anatomic position" is the body being erect, arms by the side with the palms and face facing to the front.

422 MR. KELBERG:

Doctor, if I stand here and hold myself out in this fashion, have I taken the anatomic position (Demonstrating)?

423 DR. LAKSHMANAN:

Yes. Your arms should be a little bit closer to your body and your feet should be a little bit closer. That's better.

424 MR. KELBERG:

And is this a recognized format to use to give relative positions of injuries that are identified on the body--

425 DR. LAKSHMANAN:

Yes.

426 MR. KELBERG:

--of a person on whom an autopsy is being performed?

427 DR. LAKSHMANAN:

Yes. And that is a position we give all our descriptions. We use that--keep that position in mind, especially when we give trajectories.

428 MR. KELBERG:

Doctor, there are two more items listed, 5 and 6, "Lateral" and "Medial." What do they mean?

429 DR. LAKSHMANAN:

"Lateral" means away from the center of the body. "Medial" means towards the center of the body.

430 MR. KELBERG:

I want to ask you about a couple of terms, four actually that are not on this exhibit, 343.

431 MR. KELBERG:

Mr. Fairtlough, is this a permanent marker?

432 MR. FAIRTLOUGH:

Yes.

433 MR. KELBERG:

Doctor, I want to write the term "Radial," r-a-d-I-a-l, on a portion of the diagram, I want to write the term "Ulnar" on another portion of the diagram, I want to write the term "Dorsal," d-o-r-s-a-l, if my spelling is accurate, on a third part of the diagram and I want to write a term "Ventral" on a fourth part of the diagram. Doctor, do these terms have meaning to you as a forensic pathologist?

434 DR. LAKSHMANAN:

Yes.

435 MR. KELBERG:

Let's start with "Radial." What--is this another relative term of position?

436 DR. LAKSHMANAN:

Yes.

437 MR. KELBERG:

What does it mean?

438 DR. LAKSHMANAN:

Radial comes from the--the origin is, if you stand in anatomical position--

439 DR. LAKSHMANAN:

May I stand, your Honor?

440 THE COURT:

Yes.

441 MR. KELBERG:

How about if I stand in the anatomical position, and with the Court's permission, you step to the board or step to me actually and point out what it is (Demonstrating).

442 DR. LAKSHMANAN:

If you see Mr. Kelberg in anatomical position, the arm has a bone called the humorous and the forearm has two bones, one is called the radius and one is called the ulnar. The radius is situated on the outer aspect of the forearm. And in anatomical position, it is the outer-most bone in this position. So radial anyway in this particular position would be lateral to the ulnar.

443 MR. KELBERG:

And in lay terms, doctor, could we think of it in terms of "Radial" as on the thumb side of the hand when the hand is in the anatomic position?

444 DR. LAKSHMANAN:

Yes.

445 MR. KELBERG:

And where is ulnar?

446 DR. LAKSHMANAN:

Ulnar is on the little finger side. It's on the other bone on the inner side of the forearm.

447 MR. KELBERG:

Now, can you use me before I have to move to identify what "Dorsal" and "Ventral" mean?

448 DR. LAKSHMANAN:

"Dorsal" is another term for the back and "Ventral" is another term for the front. And in this situation, ventral would be the palm aspect of the hand, dorsal would be the back of the hand.

449 MR. KELBERG:

And in general, doctor, on exhibit 343, have I written the terms, if one uses the hand, thumb and little finger of the schematic of the human anatomy, written them in their approximate positions that they refer to as you've described. And if you need a--here, here's a marker. Why don't you draw a line to where you believe they represent.

450 (The witness complies.)
451 MR. KELBERG:

Your Honor, may the record reflect that with that marker, Dr. Lakshmanan has drawn four lines each with an arrow at the end where it is in proximity to the appropriate word?

452 THE COURT:

Yes.

453 MR. KELBERG:

May I have a moment with counsel?

454 (Discussion held off the record between the Deputy District Attorney and Defense counsel.)
455 MR. KELBERG:

Thank you, your Honor. Your Honor, I have a series of exhibits to be marked. As exhibit 344, I have what appears to be a 13-Page autopsy protocol for Nicole Brown Simpson.

456 THE COURT:

344 will be protocol regarding Nicole Brown Simpson.

457 MR. KELBERG:

Could that be 344-A, your Honor? I'm sorry, your Honor.

458 THE COURT:

344-A.

459 (Peo's 344-A for id = protocol for NSB)
460 MR. KELBERG:

I have a form 15 for Nicole Brown Simpson as 344-B.

461 THE COURT:

All right. So marked.

462 (Peo's 344-B for id = for 15 for NSB)
463 MR. KELBERG:

A form 16 for Nicole Brown Simpson as C.

464 THE COURT:

344-C.

465 (Peo's 344-C for id = form 16 for NSB)
466 MR. KELBERG:

A diagram form 20 for Nicole Brown Simpson as D.

467 (Peo's 344-D for id = for 20 for NSB)
468 MR. KELBERG:

A diagram form 22 for Nicole Brown Simpson as E.

469 (Peo's 344-E for id = form 22 for NSB)
470 MR. KELBERG:

A form 23 diagram for Nicole Brown Simpson as F.

471 (Peo's 344-F for id = form 23 diagram for NSB)
472 MR. KELBERG:

A 20F form diagram for Nicole Brown Simpson as G.

473 (Peo's 344-G for id = 20F form diagram)
474 MR. KELBERG:

A 20G diagram form for Nicole Brown Simpson as H.

475 (Peo's 344-H for id = 20G diagram form)
476 MR. KELBERG:

A form 24 for Nicole Brown Simpson as I.

477 (Peo's 344-I for id = form 24)
478 MR. KELBERG:

A 20H form diagram for Nicole Brown Simpson as J.

479 (Peo's 344-J for id = 20H form)
480 MR. KELBERG:

A 20G form diagram for Nicole Brown Simpson as K.

481 THE COURT:

I thought we had 20G as 344-H.

482 MR. KELBERG:

There are two different 20G's, your Honor, I believe, and I'm not sure it's two 20G's. It may be two 20H's. Yes, it is two different form 20G's. They are completely different forms. They have the same form number. That will become clear in a moment. Let me just--

483 THE COURT:

All right. I'll take your word for it.

484 MR. KELBERG:

Let me for clarification, k appears to be what Dr. Lakshmanan previously identified as the diagram of the skull and internal area of the head, and the 20G which was our earlier sub part h appears to be a diagram of the neck and top of the head.

485 THE COURT:

Noted.

486 (Peo's 344-K for id = form 20G)
487 MR. KELBERG:

Then as form 29 for Nicole Brown Simpson would be L.

488 (Peo's 344-L for id = form 29 for NSB)
489 MR. KELBERG:

And form 20H, this one appearing to be an outline of the skeleton. I think we had another 20H which is an outline of the human skull, but this is the skeleton of the entire body, this as exhibit M.

490 (Peo's 344-M for id = form 20H)
491 MR. KELBERG:

And a form 20D as in dog, that--for Nicole Brown Simpson--I ask to be marked as exhibit O, subpart O.

492 THE COURT:

How about n?

493 MR. KELBERG:

I'm sorry. N then.

494 (Peo's 344-N for id = from 20D for NSB)
495 MR. KELBERG:

Your Honor, I have what appears to be a two-page document entitled addendum report that is--has both typing and handwriting on it. May this be marked as exhibit 345?

496 THE COURT:

All right. People's 345, two-page addendum.

497 MR. KELBERG:

In fact, 345-A.

498 (Peo's 345-A for id = addendum report)
499 MR. KELBERG:

And I--there may be a reason for that, your Honor, because I seem to have another two-page addendum report that is all typed and ask that that two-page document be exhibit 345-B.

500 THE COURT:

Yes.

501 (Peo's 345-B for id = addendum report)
502 MR. KELBERG:

And then I have, your Honor, a one-page form 14 entitled, "Microscopic description," that applies to Nicole Brown Simpson, and I ask that that be marked as 345-C.

503 THE COURT:

So marked.

504 (Peo's 345-C for id = micro description)
505 MR. KELBERG:

I have, your Honor, what appears to be two pages of toxicology reports for Nicole Brown Simpson, one dated June 21, `94, one dated August 31, `94. I would ask respectively that they be marked as 346-A and B.

506 THE COURT:

So marked.

507 (Peo's 346-A and B for id = tox. Reports)
508 MR. KELBERG:

I have a two-page form 13 odontology report dated September 9, 1994 for Nicole Brown Simpson. I ask that that be marked as 347-A.

509 THE COURT:

Is that Dr. Vale's report?

510 MR. KELBERG:

It is, your Honor.

511 (Peo's 347-A for id = odontology report)
512 MR. KELBERG:

And I have a second form 13 odontology report dated September 14th, 1994 for Nicole Brown Simpson that I would ask to be marked as 347-B that also involves Dr. Vale.

513 (Peo's 347-B for id = odontology report)
514 MR. KELBERG:

I have, your Honor, another form 13 entitled radiology consult dated November 14th of 1994. May that be 347-C?

515 THE COURT:

347-C.

516 (Peo's 347-C for id = radiology consult)
517 MR. KELBERG:

And finally, your Honor, in this series, I have what appears to be a two-page typewritten document entitled, "Forensic laboratory analysis report," from Steven J. Dowell, which has a stamp on the second page at the bottom, "Received October 27, 1994." May that be marked as exhibit 347-D as in dog?

518 THE COURT:

So marked.

519 (Peo's 347-D for id = lab report)
520 THE COURT:

All right. Is that the complete series, Mr. Kelberg?

521 MR. KELBERG:

Your Honor, I have two more documents to mark.

522 THE COURT:

All right.

523 MR. KELBERG:

Which collectively I would ask to be marked as exhibit 348. One is the form 1 report that we previously saw a copy of, exhibit 298 I believe A for Nicole Brown Simpson, and two page 2 forms, form 2, two separate pages, both dated June 13th of 1994 for Nicole Brown Simpson. I ask that all three of these pages be collectively marked as exhibit 348.

524 (Peo's 348 = form 1 and 2)
525 THE COURT:

All right.

526 MR. KELBERG:

And that does complete the series of exhibits to be marked.

527 THE COURT:

All right. We're going to take a 10-minute court reporter recess at this time. All right. Ladies and gentlemen, please remember all of my admonitions to you. This will be a short break to change court reporters, and we'll see you back here in about 10 minutes. All right. Doctor, you may step down.

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
We can estimate a class characteristic of a group of weapons, but it would be difficult to estimate a particular weapon to all the wounds.
Core concession that forensic pathology cannot definitively link the victims' wounds to a specific knife — directly undermining any prosecution claim that a particular knife was the murder weapon.
Dr. Lakshmanan Sathyavagiswaran
It will be difficult because you can have a very thin, not so thick single-edged knife with a tapering end which can simulate the same appearance. So when you have a wound like that, you can not say with certainty whether it was a double-edged knife or a single-edged knife.
Establishes that wound patterns alone cannot definitively distinguish knife types, limiting the evidentiary value of the wound analysis.
Brian Kelberg
I've known you a long time. I assume you will not use this in anything but a careful manner.
Kelberg asking Dr. Lakshmanan to demonstrate knife penetration technique on Kelberg's own arm — a memorable courtroom moment that made the testimony viscerally concrete for the jury.
Lance A. Ito
Do you want to come over here and watch?
Judge's dry response to Shapiro's objection to the knife demonstration on Kelberg's arm — Shapiro declined, defusing his own objection.

Evidence (10)

People's 333
Black-handled single-edged knife (Forschner)
Used for repeated demonstrations of blade taper, thickness, wound pattern comparison
People's 334
Brown-handled single-edged knife (Forschner), thicker blade
Compared against 333 to show blade thickness differences and wound pattern implications
People's 335
Double-edged knife/dagger
Used to demonstrate double-edged wound characteristics versus single-edged
People's 336
Chart depicting wound characteristics, blade types, compressibility, and stab vs. incised wounds
Central reference exhibit for wound classification testimony
People's 333-A
Generated picture of knife measurements at different penetration depths
Introduced as photographic record of knife-to-wound comparison
People's 337
Printout of page 296 from Spitz and Fisher medical textbook showing Langer's lines diagram
Introduced to illustrate skin tension line distribution and wound gaping
+ 4 more

Notable Exchanges (3)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg asked Dr. Lakshmanan to use exhibit 333 to demonstrate knife twisting and rocking motion by bringing the tip to Kelberg's own arm without penetrating, in front of the jury.
dramatic but controlled
Robert ShapiroLance A. Ito
Shapiro objected to the live knife demonstration on Kelberg's arm; Ito overruled and offered Shapiro the chance to come observe up close. Shapiro declined: 'No, thank you. I can see.'
dry/strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Extended back-and-forth about wound width vs. blade width terminology where the doctor and Kelberg spoke past each other for several exchanges before clarifying they were discussing the wound surface, not the blade.
slightly confused, ultimately clarified

Light Moments (3)

Brian Kelberg / Lance A. Ito
Kelberg and Ito bantered about whether Mr. Fairtlough's inability to draw a 90-degree angle was a geometry or trigonometry problem, with Kelberg admitting he may not have done well in either.
Brian Kelberg / Lance A. Ito
After Kelberg noted his own unsteady marker hand, Ito said 'No. That's pretty normal.' Kelberg asked 'For him or for me?' Ito replied simply 'Normal.'
Brian Kelberg
Kelberg prefaced handing Dr. Lakshmanan a real knife to use on his arm with: 'I've known you a long time. I assume you will not use this in anything but a careful manner.'

Witness Demeanor

(The witness complies.) — repeated throughout as doctor held up knives, stepped down, returned to stand
(Demonstrating) — during live knife twist/rock demonstration on Kelberg's arm
(Indicating) — frequently during chart explanations
(Brief pause.) — multiple instances during exhibit handling and ELMO printing

Objections

3 objections (0 sustained, 3 overruled)
Proceeding 6272 • 527 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 6, 1995 📄 Direct examination of Dr. Laks
JUN 6, 1995 KRT DvH TD