All right. Thank you, ladies and gentlemen. Please be seated. Let the record reflect we've been rejoined by all the members of our jury panel. And, Mr. Kelberg, you may continue with your direct examination of Dr. Lakshmanan.
Thank you, your Honor. I believe we have a stipulation with counsel regarding 11--actually 12 boards that have on the back of each board a designation starting with 0-B as in boy through 11-B as in boy. Will counsel stipulate that these 11 boards and their contents are true and accurate copies blown up of the materials which have previously been marked as exhibits 344-A through 348?
And, your Honor, may they collectively be marked as simply exhibit 349 because they can be identified by the number on the back of each of the boards.
Now, doctor, I think you mentioned something earlier this afternoon about "One-to-one photographs." Did you use that term?
That is an enlargement of the photograph to depict the best reflection of anatomical region, a life size type photograph. And the way we do it in our office, with the assistance of the LAPD lab, as I told you earlier, we have a Coroner's blue card which is placed in any area which is being photographed in the Coroner's office, and the card is always incorporated in the field of photography. So what the process involves is taking a real size card and enlarging the negative to correspond to the size. I'm not a photographic expert, but basically what the end result is, you get a life size image off the region photograph and it's a best reflection of the anatomic region as Dr. Golden would have seen it on June 14th and as I saw it on June 13th.
Doctor, have you reviewed life-size photographs of nearly all of the Coroner's photographs that were taken of Nicole Brown Simpson?
Because you--you have full-length views of the body, you'll need a six foot--pardon me--five feet, five inch length of paper to accommodate such a photograph.
But in the photographic process you identified earlier, part of the process is to give up-close photographs of matters that are deemed of significance in the course of the autopsy and even before the autopsy?
And as to those photographs, have they been blown up to life size to give as accurate as possible a true reflection of the size and appearance of any such wound or injury or finding of significance?
Is there a limitation created from reviewing--even with life-size photographs, is there a limitation to that process in allowing you to with precision measure, for example, the injuries that were in fact on the body of Nicole Brown Simpson at the time of the autopsies?
There are several limitations. One, as I mentioned, photographs are two-dimensional views. It's not a three-dimensional examination. And--number 1. No. 2, you really cannot approximate wounds. If the wounds have been photographed in the gaping state, you have them in the gaping state. You don't have the ability to approximate and measure them. The third issue is, if the wound is on a curvature of the body, on a curvature of the body and a photograph is not taken at right angles to the curvature, there's distortion involved. Fourthly, if the card is not next to the injury you're examining, your--that factor to be kept in mind because the measurement you do may not necessarily reflect the exact measurement. So there are limitations to the process, but it is the best reflection of the injuries of--in the anatomical area possible in this type of examination.
Doctor, short of exhuming a body, are you aware of any better process than the use of life-size photographs to evaluate the wounds as they appeared at the time of an autopsy?
Are there in fact limitations that would make exhumation of the body less of a reliable basis than the use of life-size photographs?
It will be less reliable because if you exhume a body, you're going to have changes of decomposition and distortion of the wounds anyway.
And, doctor, I have an envelope that appears to be quite full with material. Is this basically the size of the type of photograph that you've looked at that would be described as one-to-one photographs?
The size of the envelope and the extension of the photograph would appear to make length 20 inches, make width of photograph 12 inches.
Doctor, are you able to tell us the number of photographs of the body of Nicole Brown Simpson and Ronald Goldman which collectively were taken?
I think there were about 62 photographs of Ronald Goldman and I think about 32. I have the exact numbers in the file but--
I'm--the photographic number I referred to is basically the initial photographs. There have been numerous photographs taken of the evidence, the tissues, the clothing which I'm not taking into the count.
And those are the photographs that would be contained in your one-to-one set you reviewed?
The autopsy photograph, the initial photographs which was taken by the Coroner's office.
Now, doctor, we're going to be looking at some photographs shortly. In looking at the photographs that we will be seeing, have some of those photographs been cropped, that is cut in compliance with an order from Judge Ito?
As you looked at the photographs both in the size that they were originally before cropping--you did do that; is that correct?
Your Honor, I have a series of documents that has the heading "Outline of injuries to Nicole Brown Simpson, 94-05136." May this be marked as exhibit 349?
Oh, I'm sorry. I didn't see where Mr. Lynch had marked the collective boards. Then 350.
And as 351, a similar appearing set of documents, thicker in number I believe, entitled "Outline of injuries to Ronald Goldman 94-05135" as 351.
Doctor, let me show you first exhibit 350, the series of documents on Nicole Brown Simpson. Are you familiar in general terms with this exhibit?
This is an exhibit which I played an important part, and it was prepared principally to present my findings after reviewing the one is to one photographs, and I did it and also look at the autopsy description in the original protocol, also correlate these injury descriptions with diagrams in the original autopsy protocol. In addition, we also correlated the injuries in the addendum description; and following this, we also have a comment section and also an opinion from me whether it's a single edge or a double edge--single edge or--whether it's a single edge or double edge that you can not say. That comment section is also included in this chart. It's important that this chart was done to identify any--because when the original addendum was done, the measurement of the injuries was not done with one is to one photographs, the injuries that were not described earlier. And that is why the one is to one photographs were useful. And basically the chart has these headings, and once the chart is shown to you all, you'll understand the format as I just presented.
Doctor, would it be accurate to say that this document is to reflect your identification of every wound or injury that you found in looking at all of the autopsy photographs of Nicole Brown Simpson?
Is it intended to identify areas within Dr. Golden's original autopsy report where any such wounds were described?
Is it intended to identify any of those diagrams, those form number forms that we looked at earlier where any such injury or wound was marked on the form by Dr. Golden at the time of the autopsy?
Is it intended to identify areas of injury that Dr. Golden did not address, that is, did not include any reference to in his original protocol?
Or did not diagram in one or more of the forms used by Dr. Golden in the course of his autopsy?
Now, doctor, in this case, did Dr. Golden prepare something called an addendum report?
He prepared the addendum because he felt that he had not addressed some of the injuries in the photographs which he had seen, but he had failed to describe in the original report. I also brought to his attention following my examination of the tissues on June 22nd that he had failed to describe a contusion of the brain which was in the hold jar which was not addressed in the original report. And based on these factors, Dr. Golden issued an addendum report under my direction.
Doctor, did you talk with Dr. Golden before any final addendum report was completed?
At that time, did you discuss with him a draft addendum that he may have prepared?
Let me pull out one of these boards for just a moment. It has the number 7-B on the back from our exhibit of 349, your Honor.
And, Mr. Fairtlough, is this set up in the appropriate location, this particular easel?
Doctor, in looking at that blow-up that is right next to you, are you familiar with that document?
Now, let me show you--if you'd take a seat again just momentarily--a document that is two pages and see if you're familiar with that addendum report.
That is an addendum report with my instructions to him on how the addendum should be done because the original report had already been filed and we have a certain format which we follow in our office when we issue addendum report so that the corrections, additions and deletions should be done in a particular format so the person reading the addendum will understand where the additions, deletions and corrections apply.
And I think if I could have that document back, I'm going to ask Mr. Fairtlough if he could put this, which is our exhibit 335-A, put that on the elmo.
I'm not sure if you can focus that a little better perhaps by coming in a little bit.
Doctor, in this document, we are seeing both typewritten information and what appears to be handwritten information; is that correct?
If Mr. Fairtlough can scan down now on the document. And I'm not sure how much further you can go and keep the top part of "Addendum report" still visible. Doctor, there appear to be--for example, under "Addendum opinion," there's a line running horizontally through those words, there's material with a wavy line and so forth. Can you give us some idea of how all this information came to be on this particular page?
Some of the handwriting is mine and some of them may be Golden's. But my handwriting is where if you see, "Page 6, item 5," I have written saying that, "Line 1 amended as originally"--I can't read the handwriting on this computer screen here. If you can give me the original document, I will be able to read it.
So basically I was involved in instructing him how that addendum should be filed because it has to follow the format of our addendums so that people understand what the addendum is in correcting the original report.
When you discussed this report with him, did you also discuss a draft report for Ronald Goldman?
And when you say, "You instructed him," did you instruct him with respect to the actual content or the form or both? Tell us.
It was mainly--it was mainly the format, but I did bring up the point about the cerebral contusion which he had failed to address in the original report which was obviously present in the hold jar. So that information was discussed with him, which is not format, but rather content. And I did also discuss my opinion on the directions of the appearance of the wounds and Ron Goldman on the left and right side of the neck, and he seemed to--he also agreed with me at that point on the directions of the wounds on the neck.
Let me put up now another one of the blow-ups, this is 8-B, and ask, doctor, is this the final product if you will following your discussion with Dr. Golden regarding the draft addendum for Nicole Brown Simpson?
On the second page of the blow-up, you see at the bottom under Dr. Golden's name the letter "T" and a date 6-30-94. Does that have any significance to you in identifying the date you discussed the draft with Dr. Golden?
Now, doctor, I want to flip the page one more time on this same blow-up with the form 14, microscopic description. Are you familiar with the circumstances under which this document came to be produced?
Yes. As I told you, when the omission of the description of the cerebral contusion was discussed, the hold jar was retrieved. This is after Dr. Baden and I examined on June 22nd, we examined the hold jar and Dr. Golden looked at the contusion and he had submitted it for storage; and we submitted a microscopic section, and this is the microscopic examination report of the contusion of the brain which is not addressed in the original autopsy report, but addressed in the addendum.
Doctor, are these addendum reports both with respect to Nicole Brown Simpson and with respect to Ronald Goldman reports that are generated in the ordinary course of business for the Coroner's office?
Yes. We issue addendums. As I mentioned earlier, we try hard not to make mistakes. When mistakes are made, they are reviewed, corrected and an addendum is issued, those original reports stay and you also have that addendum report. There's nothing to hide. We made a mistake and we corrected it.
Doctor, in your two wound summary charts, exhibits 350 and 351, have you attempted to identify where in any addendum for Nicole Brown Simpson on 350 and where on any addendum for Ronald Goldman on the wound chart 351, there was any reference in an addendum to any injury you observed in any of the autopsy photographs? You're staring at me like boy, that question makes no sense whatsoever. Let me try again.
Basically, did you try and put on your wound charts an entry or reference where in each of the addendums, you could find a reference by Dr. Golden to some injury or wound or finding that you saw in a corresponding photograph?
Now, doctor, let me take this down and let me give you back all of the protocols and forms. Doctor, have you examined every report by Dr. Golden generated in the course of the Nicole Brown Simpson case?
Have you examined all of the tissue that has been preserved as a result of the autopsy performed by Dr. Golden?
Have you examined all toxicology reports that have been generated as a result of the autopsy of Nicole Brown Simpson?
Have you examined all consultation reports, which we'll get into in detail later, but for our present purposes, Dr. Vale's odontology report?
Have you examined all evidence available to you from the autopsy records for the purposes of independently, if you can, forming an opinion as to the cause of death of Nicole Brown Simpson?
And independently forming an opinion similarly with respect to the same materials, obviously different content, but same general nature of materials, for Ronald Goldman?
Doctor, what is your opinion to a reasonable medical certainty as to the cause of Nicole Brown Simpson's death?
As a result of multiple sharp force injuries, what happened to her body to cause death?
She had injury to major vascular structures which caused bleeding, and she died as a result of the hemorrhage and the effects of the hemorrhage from these injuries.
With respect to Ronald Goldman, did you form an opinion as to the cause of death which you hold to a reasonable medical certainty?
Did you form an opinion from your review of all of these materials as to whether a single single-edged knife could have caused all of the sharp force injuries received by Nicole Brown Simpson?
My opinion is that a single-edged knife could have caused all the injuries in Miss Nicole Brown Simpson.
Can you approximate the dimensions of any such knife that could have caused all of the sharp force injuries received by Nicole Brown Simpson?
It will be difficult to exactly pinpoint the exact measurements of a weapon. But you could have a--because you won't know the full diameter of the weapon from the base to the tip.
Because you can not gauge the total measurement of the weapon from the base to the tip.
Do you have an opinion as to the approximate minimum dimensions of any single single-edged knife which could have caused all of the sharp force injuries to Nicole Brown Simpson?
All right. Let me save that question until I ask you about Mr. Goldman's case. Did you form an opinion as to whether or not a single single-edged knife could have caused all of the sharp force injuries received by Ronald Goldman?
Did you form an opinion as to whether the same single-edged knife which caused--could have caused all of the sharp force injuries to Nicole Brown Simpson could also have caused all of the sharp force injuries to Ronald Goldman?
The same single-edged knife could have caused the injuries on both the decedents.
KEY QUOTEDoctor, now let me revisit that question I asked you a moment ago. Do you have an opinion as to the approximate minimum dimensions that any such knife would have?
I can only give an approximate estimation because, as I told you, because of the variabilities of different class characteristics of weapons and injury patterns. My estimate, if somebody was looking for a knife, would be a six-inch long blade, single-edged cutting blade with a blunt edge up to one-eighth inch in width and about three-fourth inch wide. This is just a approximate estimation because of all the variabilities I discussed this afternoon. You--in knife wounds, it's best to get a weapon and then see whether the weapon matches all the wounds in the body or could have caused all the wounds in the body. And I've already given you my descriptions on it. So this is my rough estimate of wound damages as I just opined.
Again, just for class characteristics, doctor, exhibit 333, and talking about the minimum length of the blade, in your opinion, approximately at least six inches in length?
And you talked about the thickness of the blade a minimum of an eighth of an inch?
Three-quarters of an inch. And again, this is an approximate estimation. We normally like to have a weapon to compare to the wounds.
Doctor, are you able to say that in fact, only one knife caused all of the sharp force injuries to Nicole Brown Simpson and Ronald Goldman?
Basically that a single-edged knife is capable of causing all the wounds in both the victims, but I can not exclude double-edged knife being used in some of the wounds. But a single-edged knife could have caused all the wounds.
Doctor, from that--let me just briefly go back to one of the exhibits. And Mr. Lynch is going to have to help me with the number. I'm not sure if it's 340. I think it is.
Doctor, what you just said with respect to some of the wound appearances, is it accurate to say that from the appearance of the wound alone in some of these instances on these two cases, you could not distinguish whether it was inflicted by a single-edged knife blade or a double-edged knife blade?
Is it accurate that some of the wounds that you observed could only have been inflicted by a single-edged knife?
Did you see any wound that could not have been inflicted by a single-edged knife when you looked at the two cases together?
Did you see any wound that told you there must in fact have been at least a second knife?
And is it all based upon the kinds of things you talked about with respect to this chart, 340?
Now, doctor, in the course of this review that you made, you've already identified a number of mistakes that in your opinion were made by Dr. Golden; is that correct?
And in the course of your complete review, did you find that Dr. Golden made a lot of mistakes?
Did you find--well, let me ask you in general terms, what kind of mistakes, if you can characterize them, did you find that Dr. Golden made?
The mistakes were, as I told you, he missed a brain contusion on Miss Nicole--he failed to recall the brain contusion on Nicole Brown Simpson on--he also failed to describe the injury to the right thyroid cornu when he described the laryngeal structures of Nicole Brown Simpson. He made some dictating mistakes when he dictated the measurement of the wound from the diagram when he dictated the original description. These were some of the mistakes on Nicole. We are going to go into detail on the charts I've discussed. Ron Goldman, the mistakes were errors where he failed to describe some wounds which were addressed in the addendum after looking at the photographs. He also had some injuries which were diagrammed, two of them which we could not see in the photograph. So basically there were some injuries in both the victims which were not addressed in the original protocol which were addressed in the addendum, and in my detail review in the last few weeks, I found some other injuries which--which needed to be addressed which were not addressed in either the original protocol or the addendum. Taking in total--taking all the facts together, I would say there was several mistakes in both cases, but I won't say a lot of mistakes, but there are mistakes.
Doctor, it took you a long time to give that answer. Doesn't that indicate to you that he made a lot of mistakes?
Doctor, in fact, have you attempted to identify every mistake with respect to the most minor to the most serious?
That is correct. And as I said earlier to this jury and everybody who is watching this trial, I'm here to tell the truth as it is and present the Coroner's findings and discuss the cause and manner of death and the--and interpretation of the injuries.
So, doctor, if we use as an example a failure of Dr. Golden to identify an injury in the protocol, if we call that a mistake, and we say that his failure to diagram it on a form that is available, that's also a mistake, and if in fact he didn't address it in the addendum report that you've identified and we consider that a mistake, out of that one injury, we would have three mistakes; is that correct?
Doctor, using that type of criteria, did you in fact find that Dr. Golden made upwards of 30 or more mistakes?
Have you evaluated to the best of your expertise the significance if any of each mistake as it causes you to evaluate the issue of cause of death?
On the amount of time these two people lived from the times the first injuries were inflicted on each?
On the issue of the time of death, trying to estimate a specific or a range for time of death?
On the source or sources for any blunt force trauma injury that was identified from your photographic review?
Did you find in your opinion that any of these mistakes had any significance to you in being able to form opinions on each of those issues?
Doctor, when we go through bit by bit and photograph by photograph, I'll ask you to spell it out why it is you feel that, taking into account all of these mistakes, not one of them in your opinion was significant?
By the way--by the way, doctor, how about collectively? Setting aside just any one, let's take them all together, significant to you on any of the issues I identified?
Your Honor, at this time, I have some photographs to be marked for identification, a single board to start with. I'm going to ask if I could to have Mr. Lynch help me with some of the oversized boards that we'll be using, and I think Mr. Fairtlough is going to handle the wound chart for Nicole Brown Simpson on the elmo.
And, Mr. Kelberg, would you show briefly to Mr. Shapiro the photo charts that you're going to use first?
Your Honor, I would ask that this board of photographs be marked as I believe it's 352.
Your Honor, I want to be certain that with my clumsiness, I don't inadvertently display them. If I could ask Mr. Lynch when he's done to help me put this board on the easel. Let me get on the other side.
And, doctor, I'm going to ask you, if you would, please, to step down, bring a pointer with you, if you would bring your wound charts on Nicole Brown Simpson. Did I take it back from you, doctor?
And, doctor, I'm going to ask that you keep your voice up, please, as we go through the testimony regarding these particular photographs. Doctor, first of all, do each of these photographs on this exhibit 352 fairly and accurately depict the condition of Nicole Brown Simpson at the time of the autopsy on June 14th, 1994?
Are all of these photographs which were in fact taken in the manner that you described earlier today in your testimony on June 14th, 1994?
Now, doctor, there is a description that has been written in in ink--not description, but a number, a B and some number that is underneath. It's kind of faint, but it will be used as a reference to which photographs we're looking at. Is that your understanding?
Doctor, I want to begin with a photograph that's in the middle of the bottom row, photograph b-13. Is this one of the photographs you reviewed?
Yes. Before I discuss each photograph, I will discuss what is in the photograph, but I'd like to refer to the chart I prepared with reference to the exact measurements.
If you would, please. And, doctor, do your best if you could. There's a microphone I believe that's been placed just about where you're standing. So if you'll keep your voice up, please.
B-13 is a photograph of the facial region of Miss Simpson, and it depicts the fatal large stab/incise wound to the front of the neck. It starts from the left side of the neck and goes upwards to the right side extending to just below the ear, but you can't see it in this frontal view photograph. You can also see a portion of one of the stab wounds of the left side of the neck.
Doctor, did you, using a one-to-one photograph, measure the nature of the wound that we see, this stab/incise wound you've described in photograph b-13?
Yes. The--as I told you earlier, this photograph only shows portions of the major stab/incise wound. In the one is to one photograph, the portion seen measured three and a half inches by one and a quarter inches, and this wound, as you can see, transects the thyroid hyoid area, which is the area between the voice box, which is the larynx. And above the voice box, there is a bone called the hyoid bone. It is a u-shaped bone which is situated above the voice box or the larynx, and that is called the thyroid hyoid area, between the hyoid bone and the voice box. And this wound transected that thyroid hyoid area. It also transected an area of the voice box call the epiglottis, which is like a protruding piece of tissue which closes off the air passage when you swallow fluid.
The same single-edged knife could have caused the injuries on both the decedents.
There's nothing to hide. We made a mistake and we corrected it.
I didn't count them. That would be a fair statement.
My estimate, if somebody was looking for a knife, would be a six-inch long blade, single-edged cutting blade with a blunt edge up to one-eighth inch in width and about three-fourth inch wide.
I'm here to tell the truth as it is and present the Coroner's findings and discuss the cause and manner of death and the interpretation of the injuries.