📄 Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 3) — Wednesday, June 7, 1995
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C:\DEPT103\CRIMINAL\1995\JUN\7\DIRECT-EXAMINATION-OF-DR-LAKSH.DOC
TRIAL
▲ Day 90 of 167

Direct examination of Dr. Lakshmanan Sathyavagiswaran (part 3)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Wednesday, June 7, 1995 • Utterances: 637
Dr. Lakshmanan continued his direct examination, walking the jury through the four sharp force injuries on Nicole Brown Simpson's neck in forensic detail, including wound dimensions, depth, and what they reveal about the perpetrator's position relative to the victim. He then analyzed a facial abrasion (B-10) and a right-temple contusion (B-20), using the contusion's coloration to establish that Nicole was alive and had blood pressure for at least a minute before the fatal neck wound—setting up a prosecution hypothetical about the killer moving from Nicole to Goldman and back.
1 THE COURT:

All right. Thank you, ladies and gentlemen. Please be seated. Let the record reflect we have been rejoined by all the members of our jury panel. Dr. Lakshmanan is still on the witness stand undergoing direct examination by Mr. Kelberg. And Mr. Kelberg, you may continue with your direct examination.

2 MR. KELBERG:

Thank you, your Honor. And again, with the Court's permission, could Dr. Lakshmanan step down, and we will put the photographic board--and maybe all counsel and Drs. Baden and Wolf will wish to retake their position.

3 THE COURT:

Which board are you putting up, Mr. Kelberg?

4 MR. KELBERG:

I'm sorry?

5 THE COURT:

Which board are you putting up?

6 MR. KELBERG:

352 again, your Honor.

7 THE COURT:

All right.

8 (Brief pause.)
9 MR. KELBERG:

Doctor, I would like to now go into a more detailed description from you of stab wound no. 1 and then go through the series of the four stab wounds.

10 DR. LAKSHMANAN:

Stab wound no. 1 is--

11 MR. KELBERG:

Keep your voice up again, please?

12 DR. LAKSHMANAN:

Stab wound no. 1 is located on the left neck and it measures 7/16 of an inch by 1/8 of an inch in the photographic measurement I did.

13 MR. KELBERG:

7/16 of an inch in what direction, doctor? Can you show us with the pointer?

14 DR. LAKSHMANAN:

In a superior interior direction.

15 MR. KELBERG:

More or less up and down?

16 DR. LAKSHMANAN:

Yes, (Indicating), and 3/16 inch in the transverse or anthroposterior access as I'm pointing here, (Indicating).

17 MR. KELBERG:

Side to side?

18 DR. LAKSHMANAN:

Yes.

19 MR. KELBERG:

All right.

20 DR. LAKSHMANAN:

So this is the wound, when I measured it, in the state I could see it in the photograph, in the one-as-to-one photograph which I had.

21 MR. KELBERG:

The life-size photograph?

22 DR. LAKSHMANAN:

Yes.

23 MR. KELBERG:

The wound in Dr. Golden's measurement is 5/8 inch in length, in his description. The blunt end, as I mentioned earlier, is in the inferior part and the sharp end is in the upper part of the wound, and this wound penetrated the left side of the neck in a left to right direction and was up to two inches in-depth.

24 MR. KELBERG:

Doctor, from the information in Dr. Golden's protocol and your evaluation of the life-size photograph, can you tell us anything about the relative positions of the perpetrator and Nicole Brown Simpson at the time stab wound no. 1 was inflicted?

25 DR. LAKSHMANAN:

Could you expand on your question? You want more information?

26 MR. KELBERG:

Yes. Doctor, for example, when I say "Relative positions," can you say whether the two were, relatively speaking, face-to-face, one was behind the other? Can you give us any additional information from that stab wound no. 1?

27 DR. LAKSHMANAN:

It could be a situation where they were facing each other and the assailant had a weapon in the right hand and that wound could have been inflicted in that manner.

28 MR. KELBERG:

Excuse me. I will step over back here again. Can you use me as Nicole Brown Simpson, just to show, relatively speaking--incidentally, when you use the term, and I used the term "Relative positions," what does that mean to you as a forensic pathologist?

29 DR. LAKSHMANAN:

It just means the positions in which these wounds could have been inflicted by the medical findings one has.

30 MR. KELBERG:

All right. Can you use me as Nicole Brown Simpson and indicate how in your opinion the--Nicole Brown Simpson and the perpetrator could have been face-to-face and have the stab wound no. 1 inflicted with a right-handed held knife?

31 DR. LAKSHMANAN:

In this manner, (Indicating).

32 MR. KELBERG:

And your Honor, for the record, Dr. Lakshmanan with his right hand, clenched fist representing holding a knife, has raised his arm above my left shoulder and has it angled at about a 45-degree angle towards my neck.

33 THE COURT:

All right. Why don't you trade places so that the jurors can actually see the right arm.

34 MR. KELBERG:

All right.

35 MR. KELBERG:

Doctor, let's ask you to do that again.

36 DR. LAKSHMANAN:

The knife in question is a single-edged knife and the blunt edge would be on the lower part and the sharp edge would be the upper part corresponding to the wound.

37 MR. KELBERG:

Is that consistent with what you see in fact in stab wound no. 1?

38 DR. LAKSHMANAN:

Yes.

39 MR. KELBERG:

Now, doctor are there other relative positions that could account for that--

40 DR. LAKSHMANAN:

There could be other positions, too.

41 MR. KELBERG:

Is there any way for you as a forensic pathologist to be able to say with specificity what was the actual relative positions?

42 DR. LAKSHMANAN:

No.

43 MR. KELBERG:

Is there any way, given that you cannot say with specificity the relative positions, that you can say whether the knife was being held by the right hand or the left hand of the perpetrator?

44 DR. LAKSHMANAN:

I cannot say that. I cannot say which hand.

45 MR. KELBERG:

And does the hand depend on what the actual--I will tell you what--does the hand that has the knife then depend--a finding depend on the relative positions at the time the wound was inflicted?

46 DR. LAKSHMANAN:

That is correct.

47 MR. KELBERG:

Now, can you do basically the same identification process for stab wound no. 2, or I'm sorry, sharp force injury no. 2?

48 DR. LAKSHMANAN:

Sharp force injury no. 2, I'm pointing to it right now, (Indicating), 1/8 inch, superficial. It is a superficial puncture/incise wound.

49 MR. KELBERG:

Doctor, in your opinion would that superficial incise wound create any extensive bleeding?

50 DR. LAKSHMANAN:

No.

51 MR. KELBERG:

Incidentally, stab wound no. 1, if it did in fact strike either the left jugular vein or the left carotid artery, would that wound in your opinion be fatal if there was no medical intervention?

52 DR. LAKSHMANAN:

It could be potentially serious wound if the carotid artery and jugular vein was injured.

53 MR. KELBERG:

My question is would it, in your opinion, be a fatal wound if in fact Nicole Brown Simpson did not receive immediate and appropriate medical care?

54 DR. LAKSHMANAN:

If she did not receive proper medical care it could be a potentially serious fatal wound.

55 MR. KELBERG:

I would assume a fatal wound is a serious wound. In your opinion is it a fatal wound?

56 DR. LAKSHMANAN:

Yes.

57 MR. KELBERG:

Now, doctor, in fact if there had been such a striking of the jugular or--and/or carotid, could that wound be fatal even with immediate and proper medical intervention?

58 DR. LAKSHMANAN:

It could be fatal.

59 MR. KELBERG:

Now, stab--I'm sorry--sharp force injury no. 2, in your opinion is that a non-fatal injury?

60 DR. LAKSHMANAN:

Yes.

61 MR. KELBERG:

And other than being a superficial incise wound, does it have any significant bearing on the cause of death of Nicole Brown Simpson?

62 DR. LAKSHMANAN:

No.

63 MR. KELBERG:

Is there anything else about--I'm sorry. Can you tell anything about the relative position of Nicole Brown Simpson and the perpetrator from the appearance of that sharp force injury no. 2?

64 DR. LAKSHMANAN:

The same statements I applied to the stab wound no. 1 would apply to this.

65 MR. KELBERG:

So in the relative positions of face-to-face that you showed, that is a possibility?

66 DR. LAKSHMANAN:

That is a possibility and it could also be the person who had the weapon in the left hand and was in the back, that same kind of wound could have been inflicted in a left or right direction.

67 MR. KELBERG:

If it was face-to-face again it would be a knife held in the right hand?

68 DR. LAKSHMANAN:

Yes.

69 MR. KELBERG:

Now, stab wound no. 3, in the photograph B-18, a description of that, please.

70 DR. LAKSHMANAN:

This stab wound, (Indicating), is transversely oriented. That is side-to-side in this photograph, in contrast to the other wound which is more in a vertical orientation, so this is more in a horizontal orientation. It has got a blunt end in the front and a sharp end in the back and this wound measures 5/16 inch by 3/16 inch in the state of the photography reviewed in the one-as-to-one photograph.

71 MR. KELBERG:

Doctor, from your review of the life-size photograph, is your measurement consistent with any measurement made by Dr. Golden, given limitations of measurements from photographs that you described yesterday?

72 DR. LAKSHMANAN:

There is no significant difference if you take the limitations of the process into consideration.

73 MR. KELBERG:

And those limitations were?

74 DR. LAKSHMANAN:

I discussed them yesterday. The photograph I'm viewing is a two-dimensional photograph. It is a slightly gaping wound. Dr. Golden approximated the wound when he did the measurement and when you approximate, you know, the wound can be longer because he measured it as a half an inch long wound and this--and also indicated that--the other problem when you do photographic measurement is that when you have a curvature like this, the neck is a curved area of the body, your measurement of the photograph doesn't take into consideration the curvature component which you would do in a real life measurement when you are measuring the wound in an approximated. State so given those limitations, his measurements are not significantly different from mine.

75 MR. KELBERG:

Now, doctor, is in your opinion stab wound no. 3 a potentially fatal stab wound if in fact it struck either the carotid or the jugular?

76 DR. LAKSHMANAN:

Yes.

77 MR. KELBERG:

And the same would apply if it struck both, I assume?

78 DR. LAKSHMANAN:

Yes.

79 MR. KELBERG:

If it did not strike either would it be a fatal stab wound?

80 DR. LAKSHMANAN:

No.

81 MR. KELBERG:

Would it still be a stab wound that would produce significant bleeding?

82 DR. LAKSHMANAN:

Yes.

83 MR. KELBERG:

How about stab wound no. 4? Can you give us some more detailed information?

84 DR. LAKSHMANAN:

Stab wound no. 4 is the lower most wound. It also has the same horizontal orientation. It has got a sharp end on the right side of the photograph and a blunt end on the front of the photograph. And this wound in its gaping state measured 9/16 inch by 3/8 of an inch, the 9/16 inch being the horizontal component and 3/8 being the vertical component. And Dr. Golden measured his wound in his original notes as 7/8 inch in the approximated state, and given the limitations of the process, I saw no significant difference attributable to my measurements. And this wound also is a track in the body about one and a half inches.

85 MR. KELBERG:

Now, doctor, I don't think I asked you on stab wound no. 3 about relative positions. Would your answers be the same as to relative positions of Nicole Brown Simpson and the perpetrator in a right-handed or left-handed nature of the knife being held as they were for stab wound 1 and 2?

86 DR. LAKSHMANAN:

Yes.

87 MR. KELBERG:

All right. Now, stab wound no. 4, excuse me, if that had--stab wound had in fact hit in any fashion, either the jugular or the carotid, would that stab wound be a fatal stab wound?

88 DR. LAKSHMANAN:

Yes.

89 MR. KELBERG:

And if it hit both, a fatal stab wound?

90 DR. LAKSHMANAN:

Yes.

91 MR. KELBERG:

And if it neither, a non-fatal stab wound?

92 DR. LAKSHMANAN:

Yes.

93 MR. KELBERG:

Would it still be a stab wound which would produce significant bleeding if it struck neither the carotid or the jugular?

94 DR. LAKSHMANAN:

Yes.

95 MR. KELBERG:

Would your--I'm sorry, did you want to add something?

96 DR. LAKSHMANAN:

No.

97 MR. KELBERG:

Would your answers about relative positions of the perpetrator and Nicole Brown and the right-handed or left-handed nature of holding the knife be the same for stab wound no. 4 as they have been for stab wound 1, 2 and 3?

98 DR. LAKSHMANAN:

Yes.

99 MR. KELBERG:

Doctor, is there any significance to you, as a forensic pathologist, that these four stab wounds appear to have a linear relationship if one goes from the stab wound no. 1 to sharp force injury no. 2, to stab wound no. 3, to stab wound no. 4?

100 DR. LAKSHMANAN:

Yes. It does have a significance because they are all localized to one area of the neck which would signify that there was some limitation of movement created at least to the neck area when these wounds were inflicted by the assailant, because they are localized to one area, more or less in the same area. And there is some movement, because one wound is not as deep as the other, but still it would signify some partial immobilization, at least because given the localized area of all these four stab wounds on that area.

101 MR. KELBERG:

When you say immobilization, immobilization of who or what?

102 DR. LAKSHMANAN:

Miss Brown Simpson by the assailant.

103 MR. KELBERG:

And immobilization is a long word to mean in essence what?

104 DR. LAKSHMANAN:

Prevent movement of the person by holding them or holding them against a wall or just holding them tight so that you have some control over them that they cannot exert the same degree of movement as you would expect in a person who is not so compromised.

105 MR. KELBERG:

If a person were not so compromised, would you expect that person to try to avoid being struck by the knife?

106 DR. LAKSHMANAN:

Yes.

107 MR. SHAPIRO:

Objection, calls for speculation.

108 THE COURT:

Overruled.

109 MR. KELBERG:

And your answer, doctor, is?

110 DR. LAKSHMANAN:

Yes.

111 MR. KELBERG:

Now, doctor, is there anything else, with respect to a description of these four sharp force injuries along the neck as seen in photograph B-18, you wish to bring out?

112 DR. LAKSHMANAN:

No.

113 MR. KELBERG:

If we could move them, we are going to go back to the protocols and the diagrams.

114 (Brief pause.)
115 MR. KELBERG:

And I will ask Mr. Lynch when he is at that position, we are putting 0B up, and we are putting--which is the protocol, and we are putting 3B up which is our form, I believe, 22.

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

Now, doctor, did Dr. Golden address each of these four sharp force injuries that we have been looking at in B-18 in his original autopsy report?

119 DR. LAKSHMANAN:

Yes, he has.

120 MR. KELBERG:

Where?

121 DR. LAKSHMANAN:

On page 5 and 6 of the report.

122 MR. KELBERG:

If Mr. Lynch can turn to page 5 of the protocol blow-up.

123 MR. KELBERG:

Doctor, where does that start?

124 DR. LAKSHMANAN:

1, 2, 3 and 4 is the same numbers which I used when I described photograph B.

125 MR. KELBERG:

18 I believe it is?

126 DR. LAKSHMANAN:

B-18, yes, so it follows the same format.

127 MR. KELBERG:

All right. Your Honor, then on page 5 of the protocol in the upper left-hand corner under "Description and multiple stab wound," I'm writing "B-18." I will leave it at that.

128 THE COURT:

All right.

129 MR. KELBERG:

And you said--it continues on to page 6 is it, doctor?

130 DR. LAKSHMANAN:

Yes, no. 4 stab wound the 7/8 wound which I discussed last continues on to page 6.

131 MR. KELBERG:

If Mr. Lynch could flip that, please.

132 DR. LAKSHMANAN:

Just the first two paragraphs.

133 MR. KELBERG:

Would it be accurate, doctor, that the description on B-18 ends where I've got the red marker here, (Indicating)?

134 DR. LAKSHMANAN:

Yes.

135 MR. KELBERG:

And so your Honor, with that red marker I'm making a u-shaped box, if you will, around those two photographs on page 6 and writing "B-18" within the margin.

136 THE COURT:

Thank you.

137 MR. KELBERG:

Doctor, did Dr. Golden diagram in any fashion on any of the diagrams those four sharp force injuries?

138 DR. LAKSHMANAN:

Yes, he did.

139 MR. KELBERG:

Is it seen in diagram 22?

140 DR. LAKSHMANAN:

Yes.

141 MR. KELBERG:

Would you show us, please, where.

142 DR. LAKSHMANAN:

Yes. I'm going to--

143 MR. KELBERG:

And keep your voice up, please, doctor.

144 DR. LAKSHMANAN:

The four stab wounds are diagrammed on the left side of the neck, in the lower right quadrant of this board, 1, 3, 4 and 2 is here, (Indicating), and you also have the description of all the wounds described.

145 MR. KELBERG:

Well, let's start--first of all, where do you see the description for the four stab wounds?

146 DR. LAKSHMANAN:

One description is here, (Indicating), and then 2 and then you have stab wound no. 3 here, (Indicating), and 4 here, (Indicating).

147 MR. KELBERG:

All right. Doctor--

148 DR. LAKSHMANAN:

So the whole thing is the description for all the four stab wounds.

149 MR. KELBERG:

So basically it is the lower half of form 22 which has been used by Dr. Golden?

150 DR. LAKSHMANAN:

Yes.

151 MR. KELBERG:

To identify and describe those four sharp force injuries?

152 DR. LAKSHMANAN:

Yes, and to repeat, this is no. 1, (Indicating).

153 MR. KELBERG:

All right. Let me just mark that. Which is no. 1, doctor?

154 DR. LAKSHMANAN:

(Indicating).

155 MR. KELBERG:

All right. I'm going to put a box around that on the diagram and write in "SW no. 1."

156 DR. LAKSHMANAN:

And actually this includes also because it says, "Three inches below the EAC" which is external auditory canal. From here it is three inches below here, (Indicating), so that should be included, too.

157 MR. KELBERG:

All right. I will raise the even circled area on the lower right-hand side of the diagram to include that.

158 DR. LAKSHMANAN:

I'm sorry. Can you all see? No. 1 is this 1/8 superficial wound here which I alluded to here which is no. 2, (Indicating).

159 MR. KELBERG:

All right. In that area, doctor, I'm going to circle where you have just been pointing and write "SW--actually "SF" for sharp force no. 2.

160 DR. LAKSHMANAN:

Yes.

161 MR. KELBERG:

All right. How about no. 3?

162 DR. LAKSHMANAN:

No. 3 is here, (Indicating), and the orientation is here and this half an inch and this is the--

163 MR. KELBERG:

All right. Would it be accurate to say, doctor, that the area I'm circling now in the form, taking in the right lower quadrant, is the area of the diagram of sharp force injuries 1, 3 and 4?

164 DR. LAKSHMANAN:

Yes.

165 MR. KELBERG:

So I'm going to mark "SW no. 1, SW no. 3, SW no. 4," and then the area that you circled or with the pointer outlined in the lower left quadrant of form 22 I'm circling and I will write in this is "SW no. 3"; is that correct, doctor?

166 DR. LAKSHMANAN:

Yes.

167 MR. KELBERG:

All right. Now, where is the description with respect to the fourth wound?

168 DR. LAKSHMANAN:

Here, (Indicating).

169 MR. KELBERG:

And I will circle that area and write "SW no. 4." Doctor, can you identify the content of Dr. Golden's description there for us?

170 DR. LAKSHMANAN:

This is--he described as a 7/8 inch wound, 1/32 blunt end in the front, sharp end in the back and one-to-one and a half inches deep, and if you look at the same description here, one to one and a half inches.

171 MR. KELBERG:

"Here" was a reference to page 6 of the autopsy form no. 12. Doctor, anything further with respect to identification on these four sharp force injuries on diagram 22?

172 DR. LAKSHMANAN:

No. And--for this diagram that is it.

173 MR. KELBERG:

Was any other diagram used by Dr. Golden regarding these?

174 DR. LAKSHMANAN:

No, no.

175 MR. KELBERG:

Was there any reference to these four sharp force injuries in Dr. Golden's addendum?

176 DR. LAKSHMANAN:

No.

177 MR. KELBERG:

Was there any need, from your perspective, for any reference in the addendum?

178 DR. LAKSHMANAN:

No.

179 MR. KELBERG:

While we are in this position, let me cover just a couple of brief points, if we could.

180 THE COURT:

All right. You have put up 1B.

181 MR. KELBERG:

Thank you, your Honor. You've got a position to see that.

182 MR. KELBERG:

And this is a blow-up, doctor, is it part of the form 15 document?

183 DR. LAKSHMANAN:

Yes.

184 MR. KELBERG:

Now, in the upper part of that document there is a date and time listed. Do you see that?

185 DR. LAKSHMANAN:

Yes.

186 MR. KELBERG:

And that time is to reflect what?

187 DR. LAKSHMANAN:

Usually that is the time the autopsy is started.

188 MR. KELBERG:

And the class a is checked?

189 DR. LAKSHMANAN:

Yes.

190 MR. KELBERG:

And that is what you indicated is the fullest type of autopsy performed in your office; is that correct?

191 DR. LAKSHMANAN:

Yes.

192 MR. KELBERG:

You also testified yesterday, I believe, regarding a mix-up in identification of a specimen between urine and bile; is that correct?

193 DR. LAKSHMANAN:

Yes.

194 MR. KELBERG:

Does this form show that front page that was completed?

195 DR. LAKSHMANAN:

It is not--it is not on Miss Simpson's 15.

196 MR. KELBERG:

Mr. Goldman's?

197 DR. LAKSHMANAN:

Yeah, but the form doesn't reflect the mistake because the form was correctly marked as bile in there. What was marked wrongly was the bottle. You see, the bottle has spaces--the wrong box was marked off on the bottle, so not on the 15.

198 MR. KELBERG:

Okay.

199 DR. LAKSHMANAN:

So that doesn't apply to this form.

200 MR. KELBERG:

And there is a box marked "Witnesses to autopsy" which has been checked and there appear to be the name of "Vannatter and Lange, LAPD 6/14/94"?

201 DR. LAKSHMANAN:

Yes.

202 MR. KELBERG:

And that is to reflect officers Vannatter and Lange were present to observe the autopsy?

203 DR. LAKSHMANAN:

Yes.

204 MR. KELBERG:

Now, if we could flip this to the next form, 16, now, you mentioned that this type of form is used to write in a lot of information as the autopsy is performed; is that correct?

205 DR. LAKSHMANAN:

Yes.

206 MR. KELBERG:

And it also includes a reference to the time over which the autopsy was conducted, the formal autopsy; is that correct?

207 DR. LAKSHMANAN:

Yes.

208 MR. KELBERG:

And in this case is there an entry by Dr. Golden for that time?

209 DR. LAKSHMANAN:

Yes.

210 MR. KELBERG:

And where is that?

211 DR. LAKSHMANAN:

In the lower part of the form. The autopsy was started at 8:30 and completed at 10:30 from the inscriptions on this form.

212 MR. KELBERG:

Your Honor, I'm just going to outline that box with red on this form 16.

213 THE COURT:

Yes.

214 MR. KELBERG:

Doctor, also, is this from an external exam list of areas an indication by Dr. Golden regarding the height and weight of ms. Brown Simpson?

215 DR. LAKSHMANAN:

Yes.

216 MR. KELBERG:

And in this case is the height listed as 65 inches as I am outlining in red?

217 DR. LAKSHMANAN:

Yes.

218 MR. KELBERG:

And is the weight listed as 129, we will assume, pounds?

219 DR. LAKSHMANAN:

Yes.

220 MR. KELBERG:

Thank you. I think we are done with that.

221 (Brief pause.)
222 MR. KELBERG:

I think we will go back to the photo board, if we could, please.

223 (Brief pause.)
224 MR. KELBERG:

Doctor, is there anything else that you wish to bring to the attention of the ladies and gentlemen of the jury regarding those four stab wounds or sharp force injuries?

225 DR. LAKSHMANAN:

No.

226 MR. KELBERG:

I would like to move just briefly to what is obviously a cropped photograph that is right next to you in the lower series of photographs that I believe is marked B-10. Is that the designation of a better view of it than I, doctor?

227 DR. LAKSHMANAN:

That is correct.

228 MR. KELBERG:

Doctor, again just to be clear, this is cropped pursuant to the order of the Court, correct?

229 DR. LAKSHMANAN:

Yes.

230 MR. KELBERG:

And you viewed the full photograph both in the set of sizes these are in general and also in the life-size photographs; is that correct?

231 DR. LAKSHMANAN:

Yes.

232 MR. KELBERG:

What is shown in B-10?

233 DR. LAKSHMANAN:

It shows a small reddish brown abrasion in the right side of the face a short distance from the eyebrow area.

234 MR. KELBERG:

Now, you talked about an abrasion yesterday being a blunt force trauma type injury; is that correct?

235 DR. LAKSHMANAN:

Yes.

236 MR. KELBERG:

And is the color that you see of that abrasion of any significance to you in evaluating when in relationship to death that injury was received by Nicole Brown Simpson?

237 DR. LAKSHMANAN:

It was antemortem abrasion. That means it happened when she was alive.

238 MR. KELBERG:

How can you tell?

239 DR. LAKSHMANAN:

From the appearance of the coloration.

240 MR. KELBERG:

What is the coloration?

241 DR. LAKSHMANAN:

Reddish brown color we have here, would indicate it is an antemortem abrasion.

242 MR. KELBERG:

Why is that?

243 DR. LAKSHMANAN:

Because it shows evidence of vital reaction photographically.

244 MR. KELBERG:

"Vital reaction" meaning?

245 DR. LAKSHMANAN:

That it happened during when the person was alive.

246 MR. KELBERG:

Is vital reaction something regarding how the body is reacting?

247 DR. LAKSHMANAN:

Yes.

248 MR. KELBERG:

What is the body reacting to? I would like to get a definition of that?

249 DR. LAKSHMANAN:

Basically when you have an injury indicated that you will have inflammatory response and sometimes bleeding. Here there is no bleeding but you have the reddish brown color because of the vascularity of the structures underlining it. And there is no microscopic section available of this area, but looking at it from my experience and the appearance of this wound, it is a wound which happened when she was alive.

250 MR. KELBERG:

Doctor, can you identify any source for the abrasion that you see in that photograph?

251 DR. LAKSHMANAN:

It is a nonspecific type of abrasion. There is no pattern to it. So any rough surface could have caused this type of abrasion which could be--any type of rough surface could have caused this. Depending on what kind of items are given as a hypothetical situations, we can discuss it further.

252 MR. KELBERG:

From your visits to the 875 south Bundy location--and you testified yesterday you did examine the environmental surroundings there for looking for sources for blunt force trauma--can you--did you find any that would be consistent with being a source for this particular abrasion identified in B-10?

253 DR. LAKSHMANAN:

Yes. There is--there is a staircase there and there is a wall, a metal side wall, and this could be from the wall where there is enough surface from the wall.

254 MR. KELBERG:

How is that inflicted then between a rough surface of a wall and the area of the body where this abrasion is seen?

255 DR. LAKSHMANAN:

Well, the head could have come in contact with the wall. That would be one way it could have been caused.

256 MR. KELBERG:

Come in contact in what fashion?

257 DR. LAKSHMANAN:

Being pushed against the wall.

258 MR. KELBERG:

Doctor, could you slide the photograph board--just slide it down for me and take a look for a second.

259 (Brief pause.)
260 MR. KELBERG:

May I have just a moment, your Honor, and I think it will be helpful, doctor, if you slide the board back the other way so microphone is not covered.

261 (Brief pause.)
262 MR. KELBERG:

Thank you, your Honor.

263 MR. KELBERG:

Doctor, in your opinion, is that particular abrasion a non-fatal blunt force trauma injury?

264 DR. LAKSHMANAN:

Yes.

265 MR. KELBERG:

Is it of any significance to the cause of Nicole Brown Simpson's death?

266 DR. LAKSHMANAN:

No.

267 MR. KELBERG:

Is it something which would allow you, as a forensic pathologist, to identify with specificity the manner in which it was inflicted?

268 DR. LAKSHMANAN:

No.

269 MR. KELBERG:

Is there any way that you as a forensic pathologist can tell us, in the sequence of wounds that were received by Nicole Brown Simpson, when that was, other than to say it was received while she was alive?

270 DR. LAKSHMANAN:

No.

271 MR. KELBERG:

Did Dr. Golden describe this particular abrasion in his original autopsy protocol?

272 DR. LAKSHMANAN:

Yes, he did, and he also diagrammed it. He described it in page 8 of his autopsy protocol.

273 MR. KELBERG:

Before we move, page 8--

274 DR. LAKSHMANAN:

Diagram 22.

275 MR. KELBERG:

All right. If we could ask counsel to move briefly.

276 (Brief pause.)
277 MR. KELBERG:

And doctors Baden and Wolf as well. (Brief pause.)

278 THE COURT:

All right. You have put up again B0 and--

279 MR. KELBERG:

3B, your Honor.

280 THE COURT:

--3B.

281 MR. KELBERG:

I'm sorry, doctor, page 8 was it?

282 DR. LAKSHMANAN:

Yes.

283 MR. KELBERG:

We need another few inches to help out.

284 MR. KELBERG:

All right, doctor. Can you find on page 8 where there is a description?

285 DR. LAKSHMANAN:

Fifth paragraph: "External injuries of the scalp, small abrasion, reddish brown measuring 3/8 by quarter inch appearing to be antemortem is found lateral to eyebrow."

286 MR. KELBERG:

Your Honor, may the record reflect with the red marker I am circling that area. I am writing "B-10" on the left margin of that on page 8 of the form 12 protocol.

287 THE COURT:

Yes.

288 MR. KELBERG:

Doctor, would you identify on form 22 where Dr. Golden has described it or diagrammed it.

289 DR. LAKSHMANAN:

Diagrammed it here, (Indicating), and you can see the description here.

290 MR. KELBERG:

All right. First of all, where he diagrammed it, I will circle that area, and this is in the lower left quadrant. I will draw a line out to the clear area and I will write "B-10" there?

291 DR. LAKSHMANAN:

And this description here, antemortem.

292 MR. KELBERG:

Keep your voice up, doctor.

293 DR. LAKSHMANAN:

"Abrasion, reddish brown, 3/8 by quarter inch, antemortem."

294 MR. KELBERG:

And I will circle that area and drawn a line to connect the earlier writing of mine of B-10.

295 MR. KELBERG:

Is there any additional information in the addendum regarding this injury?

296 DR. LAKSHMANAN:

Yes. We did an addendum on this and the measurement has changed in the addendum.

297 (Brief pause.)
298 MR. KELBERG:

And this is 8B. Why don't we put it up over where we had the protocol.

299 (Brief pause.)
300 MR. KELBERG:

Excuse me. Where is there a reference to this, doctor?

301 DR. LAKSHMANAN:

Page 1, roman number ii, item 2.

302 MR. KELBERG:

And I will circle that on the blow-up and write "B-10" out at the margin. Now, what is the difference, doctor, between what is described here in the addendum and what was initially--let me hold up--

303 DR. LAKSHMANAN:

The initial measurement was 3/8 by quarter inch. The measurement was about half an inch by quarter inch.

304 MR. KELBERG:

Doctor, do you have any information, from your review of all of the materials, on which this revision on the description of that abrasion was made?

305 DR. LAKSHMANAN:

He made it in the addendum and I--I think what happened was he had included this injury in the body of the report under the systemic review and he thought he probably didn't address it and then when he saw the photographs he addressed it in the addendum thinking he didn't address it. But I don't have an answer why he called it half-inch by quarter inch. I think he measured it from the photograph he had when he measured it.

306 MR. SHAPIRO:

Motion to strike as speculation.

307 THE COURT:

Sustained. The jury is to disregard the last question and answer.

308 MR. KELBERG:

Doctor--sorry, your Honor. Doctor, according to the diagram, that diagram entry that we circled in the lower left side with the B-10, that handwritten entry was made at the time of the autopsy by Dr. Golden?

309 DR. LAKSHMANAN:

Yes.

310 MR. SHAPIRO:

Objection, calls for speculation, motion to strike.

311 THE COURT:

Overruled.

312 MR. KELBERG:

Your answer, doctor?

313 DR. LAKSHMANAN:

Yes.

314 MR. KELBERG:

One other thing--is there anything further on this abrasion?

315 DR. LAKSHMANAN:

No.

316 MR. KELBERG:

Is there any significance to you, with respect to the difference in description half an inch versus quarter inch, 3/8 inch by quarter inch, on this particular abrasion on any of the issues you reviewed?

317 DR. LAKSHMANAN:

No.

318 MR. KELBERG:

And did you measure that particular abrasion from the one-to-one photograph?

319 DR. LAKSHMANAN:

Yes, I did.

320 MR. KELBERG:

What was your measurement?

321 DR. LAKSHMANAN:

7/16 inch by 3/16 inch.

322 MR. KELBERG:

So you have what would be a third series of dimensions for that particular abrasion; is that correct?

323 DR. LAKSHMANAN:

That's correct.

324 MR. KELBERG:

Is there any significance to you in the difference between your measurement from the one-to-one photograph and the two measurements that are provided in the original protocol and the addendum?

325 DR. LAKSHMANAN:

Not of significance. There is a difference.

326 MR. KELBERG:

Is that difference a difference that can be attributed to something other than the limitations of the process of photographic measurement?

327 DR. LAKSHMANAN:

No, because there is only 1/16 inch difference.

328 MR. KELBERG:

And given that difference of 1/16 of an inch, is that difference consistent with the limitations that you have described of photographic measurement?

329 DR. LAKSHMANAN:

Yes.

330 MR. KELBERG:

My arm is getting tired. I will put that down. If we could take the addendum down.

331 MR. KELBERG:

As long we are in this position, one thing I failed to I think bring out with the protocol, and getting back to the very first major stab/incise wound and what we started with this morning of the aspiration of blood, you mentioned something about it being addressed in some fashion in Dr. Golden's protocol; is that correct?

332 DR. LAKSHMANAN:

Yes. Go to page 9.

333 MR. KELBERG:

Keep your voice up, doctor.

334 DR. LAKSHMANAN:

Page 9.

335 MR. KELBERG:

We are going to put this back up. I will switch with Mr. Lynch.

336 (Brief pause.)
337 MR. KELBERG:

And what is of significance here, doctor?

338 DR. LAKSHMANAN:

If you look at page 9, 1, 2, 3, 4, 5--the paragraph just before the last paragraph of the page--you see: "Injuries to the upper airway including the incise wound of the hypopharynx and epiglottis have been described. Otherwise, the mucosa of the larynx piriform sinuses and trachea and major bronchi are anatomic. No mucosal lesions are evident and no blood is present."

339 MR. KELBERG:

And is that the basis on which you form an opinion that there was no aspiration of blood by Nicole Brown Simpson from that major stab/incise wound?

340 DR. LAKSHMANAN:

Yes, and also--

341 MR. KELBERG:

Keep your voice up, doctor.

342 DR. LAKSHMANAN:

And also the next page.

343 MR. KELBERG:

All right. Before we move to the next page, your Honor, for the record, I'm outlining with the red marker that paragraph and I'm going to write "B-13, 16, B-16, and B-18" and the word "Aspiration of blood" on the left margin.

344 THE COURT:

Yes.

345 MR. KELBERG:

Now, doctor, the next page; is that correct?

346 DR. LAKSHMANAN:

Page 10.

347 MR. KELBERG:

Page 10. All right. Mr. Lynch is--

348 DR. LAKSHMANAN:

Under "Lungs" if you look, it says that the lungs: "Sectioned surface of the lungs show minimal congestion and no injuries or lesions."

349 MR. KELBERG:

And that again is consistent with your opinion of an absence of aspiration?

350 DR. LAKSHMANAN:

Yes, because you have aspiration, you will describe it--when you section the lung you will see the aspirated blood in the distal portion of the airways and you will see it on the dissectioning of the lung.

351 MR. KELBERG:

And you also examined those sections of lung that were preserved?

352 DR. LAKSHMANAN:

The sections which were preserved I examined.

353 MR. KELBERG:

You found no evidence of that aspiration of blood?

354 DR. LAKSHMANAN:

Grossly.

355 MR. KELBERG:

When you say "Grossly" what does that mean?

356 DR. LAKSHMANAN:

On the sections we examined.

357 MR. KELBERG:

Your Honor, I have outlined that area on page 10. I will again write "B-13, B-16, B-18" and aspirate--"Asp of blood."

358 MR. KELBERG:

Doctor, one other thing while we are on this page, we will flip back to page 9, there is an entry regarding the cornu, that horn, in Dr. Golden's original protocol that--

359 DR. LAKSHMANAN:

Yes.

360 MR. KELBERG:

--that is not accurate?

361 DR. LAKSHMANAN:

That is correct.

362 MR. KELBERG:

All right. If we could flip back to page 9 because I think it is caught in mid-sentence in the flip. Doctor, inviting your attention to the last sentence that begins at the bottom of page 9 and continues then on to page 10, does this deal with Dr. Golden's observation regarding that area, including the cornu or horns?

363 DR. LAKSHMANAN:

Yes. He says: "The hyoid bone and thyroid cartilages are intact, inasmuch as the incised wound passes through the thyrohyoid membrane and the ligament and both greater cornuas of the thyroid cartilage are intact."

364 MR. KELBERG:

Were they, in your opinion, intact?

365 DR. LAKSHMANAN:

No, the right cornu was cut and I already addressed it earlier.

366 MR. KELBERG:

And that is a matter that you have addressed as you have identified in Dr. Golden's addendum; is that correct?

367 DR. LAKSHMANAN:

Yes.

368 MR. KELBERG:

So your Honor, where Dr. Lakshmanan has just made mention from page 10, I have circled it and I will write "B-13, B-16, B-18" and I will write the word "Horns."

369 THE COURT:

Yes. Thank you.

370 MR. KELBERG:

So, doctor, the reference here in your opinion would be a mistake by Dr. Golden?

371 DR. LAKSHMANAN:

Yes, because it was incised.

372 MR. KELBERG:

The cornu was incised on the right side?

373 DR. LAKSHMANAN:

Yes.

374 MR. KELBERG:

Is that mistake of any significance to you on these issues that we have discussed?

375 DR. LAKSHMANAN:

I already said it is not of significance because the hold is available and the major description have been described.

376 MR. KELBERG:

Does it in any way, whether it was nicked or not nicked, impact on the manner or sequence of how she died?

377 DR. LAKSHMANAN:

No.

378 MR. KELBERG:

I think we are done with that.

379 (Brief pause.)
380 MR. KELBERG:

All right. Doctor, I think we are going to go back to the photographs if counsel and the doctor would like to change positions again.

381 (Brief pause.)
382 MR. KELBERG:

Doctor, I want to invite your attention now to a photograph that has underneath it the designation "Right side of the head" and the letter and number B-20. Do you see that?

383 DR. LAKSHMANAN:

Yes.

384 MR. KELBERG:

What is depicted or shown in this particular photograph?

385 DR. LAKSHMANAN:

The right side of the head is shown. The scalp hair has been shaved postmortem and you can see a discoloration of the skin which is a bruise. And in my measurement, using the one-as-to-one photograph, it was 7/8 of an inch in diameter.

386 MR. KELBERG:

When you say "A bruise," that is our lay term. What is the more technical term for the bruise?

387 DR. LAKSHMANAN:

Contusion in the right temporal area of the head which is the right side of the head.

388 MR. KELBERG:

Could you turn so that the jury can see the right side of your body and point to the area that is shown with this contusion.

389 DR. LAKSHMANAN:

Right here I'm pointing, right side, (Indicating).

390 MR. KELBERG:

Your Honor, for the record, the witness is using his index finger to point to the--appears to be close to the right temple.

391 THE COURT:

Yes.

392 MR. KELBERG:

Thank you, doctor.

393 MR. KELBERG:

Now, doctor, first of all, is this evidence of blunt force trauma?

394 DR. LAKSHMANAN:

Yes.

395 MR. KELBERG:

From the appearance, the color that you see in this photograph--and incidentally, this was a photograph taken during the course of the autopsy procedures?

396 DR. LAKSHMANAN:

Yes.

397 MR. KELBERG:

And in the manner you described yesterday of shaving when there appears to be an injury that may be hidden by the hair of the decedent?

398 DR. LAKSHMANAN:

Yes.

399 MR. KELBERG:

Is the color that appears in this contusion of significance to you in assessing, no. 1, when in relationship to death this injury was received by Nicole Brown Simpson?

400 DR. LAKSHMANAN:

This occurred when she had blood pressure, she was alive, and there is evidence of hemorrhage. And the color, as I said, is reddish brown in color and this would signify that she had blood pressure when she sustained this injury.

401 MR. KELBERG:

Doctor, how long, if you can offer an opinion, must Nicole Brown Simpson have lived in order for that coloration to have shown and be seen at autopsy?

402 DR. LAKSHMANAN:

You can get this kind of hemorrhage into the soft tissues within minutes after the injury.

403 MR. KELBERG:

And when you say "Within minutes," how many minutes?

404 DR. LAKSHMANAN:

You can see it as early as a minute, because when you crush the tissues, the tissues bleed and you can get the bleeding immediately.

405 MR. KELBERG:

In your opinion could Nicole Brown Simpson have died as little as one minute after this injury was inflicted?

406 DR. LAKSHMANAN:

Well, that is always a possibility, but it could be also a few minutes later.

407 MR. KELBERG:

Could Nicole Brown Simpson have received the sharp force injury that you identified as the last major sharp force injury inflicted, that fatal neck wound, received that within seconds of having received the blunt force trauma injury shown in this photo?

408 DR. LAKSHMANAN:

Yes.

409 MR. KELBERG:

And then lived for the period of time necessary, as you indicated, to allow for the discoloration?

410 DR. LAKSHMANAN:

Not seconds, because you need to have enough blood pressure to cause this bruising. I missed your earlier question. The injury to the neck which caused the fatal wound must have occurred after a few minutes or a minute later, because you need some time for the bleeding to occur in the tissues. And for that reason I would say that she was alive at least for a few minutes, at least a minute, if not more, before the last wound was inflicted, because once the last wound is inflicted, you won't have any blood pressure available to cause this kind of bleeding in the scalp.

411 MR. KELBERG:

Doctor, do you have an opinion as to any source or sources that could cause that blunt force trauma contusion?

412 DR. LAKSHMANAN:

It could be something like a fist, it could be an object with a round smooth surface, like the base of a knife could do that. You could also have the head being struck against a smooth-surfaced area, which is rounded.

KEY QUOTE
413 MR. KELBERG:

And doctor, what, if any, physiological or body reaction would you expect from Nicole Brown Simpson having sustained that injury?

414 DR. LAKSHMANAN:

The injury itself is not fatal, but as you know, the--this is a covering of the head, the skin of the covering of the head, and you have the brain inside, and as you all know that you can have what's called a concussion happening, which is transient loss of consciousness can occur. If somebody sustains a bruising to the head, it can occur.

415 MR. KELBERG:

What is the effect if a concussion occurs?

416 DR. LAKSHMANAN:

You can remain unconscious for some time.

417 MR. KELBERG:

What kind of time period?

418 DR. LAKSHMANAN:

The concussion syndrome can occur for a few seconds to minutes and you may not find any structural abnormality of the brain.

419 MR. KELBERG:

You may not find any structural abnormality of the brain at autopsy?

420 DR. LAKSHMANAN:

Yes.

421 MR. KELBERG:

So in other words, a concussion can be sustained from this blunt force trauma and you, as a forensic pathologist at autopsy, can't see something which confirms that that occurred?

422 DR. LAKSHMANAN:

That's correct. And this is commonly seen in boxers, boxing, when people get hit with a fist, they transiently get dazed or even lowering--

423 MR. KELBERG:

Transiently meaning?

424 DR. LAKSHMANAN:

Seconds. And then sometimes it can be even for minutes and that is what you see in the countdown and then they get up. And people have done studies and they have found that you don't find anything on the CT scans or MRI scans.

425 MR. KELBERG:

Before you run ahead, CT scans are cat scans?

426 DR. LAKSHMANAN:

Yes.

427 MR. KELBERG:

What is that a fancy term for?

428 DR. LAKSHMANAN:

Basically a computerized tomography of the head, computerized axiom tomography of the head.

429 MR. KELBERG:

Can we get it down to a lower level for me? Is it a fancy x-ray?

430 DR. LAKSHMANAN:

It is a fancy x-ray giving three-dimensional views.

431 MR. KELBERG:

All right. And another one you were talking about was an MRI?

432 DR. LAKSHMANAN:

Yeah.

433 MR. KELBERG:

What is an MRI?

434 DR. LAKSHMANAN:

Magnetic resonance imaging.

435 MR. KELBERG:

What is a fancy device for?

436 DR. LAKSHMANAN:

That is another way of looking at the brain structures when somebody is alive.

437 MR. KELBERG:

All right. And what do you want to say about those with respect to--

438 DR. LAKSHMANAN:

What I'm trying to say is that you can have the syndrome of concussion without leaving any finding at all and you can have the syndrome of concussion when somebody is alive the without leaving any brain damage.

439 MR. KELBERG:

Doctor, assume hypothetically that Nicole Brown Simpson was struck on the head, either with a hand, fist or the rounded end of a knife in the manner you described, and became dazed, as you have indicated, and slumped to the ground and the perpetrator then moved from where her body was over to where Mr. Goldman's body is found, to that area, and then came back to Nicole Brown Simpson and raised her head in the manner you described yesterday and inflicted that major incise stab wound as you demonstrated yesterday. Would that circumstance be consistent with the time frame required to create the bruising coloration in the scalp as seen in B-20?

KEY QUOTE
440 MR. SHAPIRO:

Objection, calls for speculation, improper hypothetical, not based on any facts in this case.

441 THE COURT:

Overruled.

442 MR. KELBERG:

You may answer the question, doctor.

443 DR. LAKSHMANAN:

But I also want to ask in your hypothetical discussion regarding the stab wound of the neck and the other wound she had on the head.

444 MR. KELBERG:

All right. What do you want to ask?

445 DR. LAKSHMANAN:

I want to know they were also there when this bruising occurred?

446 MR. KELBERG:

Let's assume they weren't there.

447 DR. LAKSHMANAN:

Then to answer your hypothetical question that is a possibility.

448 MR. KELBERG:

And let's assume they were there.

449 DR. LAKSHMANAN:

Then also it is a possibility but that means the stab wounds to the neck and the other sharp force injuries to the head must have occurred around the time of the bruising but before the final wound in the neck.

450 MR. KELBERG:

And on what basis do you draw that distinction?

451 DR. LAKSHMANAN:

Because my opinion is that the major wound to the neck is the final wound, and the stab wounds to the left side of the neck have hemorrhage in the deep tissues which indicated that she had blood pressure when those wounds were inflicted and they would also cause bleeding. We also have evidence of injuries to the--other sharp force injuries to the left side and back side of the head, in addition to this bruising on the right side of the head, which all have evidence of bleeding in the tissues, which indicates that she had blood pressure when those injuries were inflicted, so--and I already opined that the last wound was the fatal incise wound to the neck. So that is why I am saying that I wanted to know in your hypothetical whether these wounds were there when the bruising to the right side of the head took place.

452 MR. KELBERG:

And if they were, they would result in a lowered blood pressure; is that correct?

453 DR. LAKSHMANAN:

They would cause lowering of the blood pressure, but what I am see saying is that they could have occurred concurrently while the infliction of the stab wounds took place. During the altercation the person could have also been pushed or hit on the right side of the head simultaneously while the stab wounds are taking place.

454 MR. KELBERG:

And still produced the discoloration that you have seen in this photograph B-20?

455 DR. LAKSHMANAN:

Yes.

456 MR. KELBERG:

And still subsequently then produce the major stab/incise wound as the last sharp force injury received?

457 DR. LAKSHMANAN:

Yes. What I'm trying to say is you have sharp force injuries to the left neck, you have sharp force injuries to the side and back of the head, a blunt force injury to the right side of the head. I can't say how they occurred had sequence, but they occurred before the fatal stab wound. And since I already opined that the fatal stab wound occurred when the person was incapacitated and probably unconscious face down, combined, these injuries somehow resulted in her being unconscious.

458 MR. KELBERG:

I'm sorry, resulted in her being?

459 DR. LAKSHMANAN:

Unconscious.

460 MR. KELBERG:

Unconscious?

461 DR. LAKSHMANAN:

With blood pressure.

462 MR. KELBERG:

With blood pressure?

463 DR. LAKSHMANAN:

Yes.

464 MR. KELBERG:

Doctor, in your opinion, given that set of circumstances, could all of those other injuries have been inflicted in a very short period of time?

465 DR. LAKSHMANAN:

Yes.

466 MR. KELBERG:

How short a period of time, in your opinion?

467 DR. LAKSHMANAN:

Within minutes. The altercation can take place so fast because you are talking about three sharp force traumas to the neck and three sharp force traumas to left side of the neck and these sharp force traumas could have occurred within minutes.

468 MR. KELBERG:

When you say "Minutes" do you mean multiple minutes or on you using that term--

469 DR. LAKSHMANAN:

A few minutes, few minutes or even less than that, less than that.

470 MR. KELBERG:

How much less?

471 DR. LAKSHMANAN:

Within a minute also because this kind of altercation can take place pretty rapidly.

472 MR. KELBERG:

Does the period for the altercation to some degree depend upon the relative physical size and strength between the perpetrator and the victim?

473 DR. LAKSHMANAN:

Yes.

474 MR. KELBERG:

Does it also depend on whether or not the victim is taken by surprise or is aware of impending danger?

475 DR. LAKSHMANAN:

Yes.

476 MR. KELBERG:

Does it also depend upon how motivated the perpetrator may be in inflicting injury?

477 DR. LAKSHMANAN:

Yes.

478 MR. KELBERG:

Does it also depend on whether the perpetrator has the element of surprise on his or her side?

479 DR. LAKSHMANAN:

Yes.

480 MR. KELBERG:

And from the standpoint of the forensic pathologist, is there any way medically on that basis alone that you can draw conclusions to a reasonable medical certainty as to how these occurred?

481 DR. LAKSHMANAN:

No.

482 MR. KELBERG:

May I have just a moment, your Honor?

483 (Discussion held off the record between the Deputy District Attorneys.)
484 MR. KELBERG:

Thank you, your Honor.

485 MR. KELBERG:

Doctor, did Dr. Golden address the contusion that is seen in this photograph B-20 in his original protocol?

486 DR. LAKSHMANAN:

Yes, he did.

487 MR. KELBERG:

Did he also diagram it?

488 DR. LAKSHMANAN:

Yes, he did.

489 MR. KELBERG:

Now, doctor, let me move--we will come back to this photograph and we will come back to the diagrams and the chart--protocols in a moment, but I would like to move to the photograph that is immediately to the right on this exhibit 352 of photograph B-20. That has a marking of B-33, brain tissue sample. Do you see that, doctor?

490 DR. LAKSHMANAN:

Yes.

491 MR. KELBERG:

Are you familiar with that particular sample that is shown in that photograph?

492 DR. LAKSHMANAN:

Yes, I am.

493 MR. KELBERG:

What is that?

494 DR. LAKSHMANAN:

That is a sample of the brain of Miss Simpson which was saved by our--by Dr. Golden during his autopsy which Dr.--which I saw when I reviewed the tissue samples with the Defense pathologist, Dr. Baden, and Dr. Wolf was also present at that time.

495 MR. KELBERG:

And that was on June 22nd of 1994?

496 DR. LAKSHMANAN:

Yes.

497 MR. KELBERG:

Now, you indicated that Dr. Golden saved this section of brain tissue; is that correct?

498 DR. LAKSHMANAN:

Yes.

499 MR. KELBERG:

And it was saved in one of those jars that you showed us yesterday from the photographs?

500 DR. LAKSHMANAN:

Yes, the formalin containing jar.

501 MR. KELBERG:

Was there more than this--one sample of brain tissue saved by Dr. Golden from the autopsy of Nicole Brown Simpson?

502 DR. LAKSHMANAN:

There are several samples saved.

503 MR. KELBERG:

Approximately how many samples were saved, and if up need to refresh your memory with something, please do so.

504 DR. LAKSHMANAN:

I have.

505 THE COURT:

While he is refreshing his memory, Miss Clark.

506 (Brief pause.)
507 DR. LAKSHMANAN:

In addition to this specimen which had the contusion, there were 13 sections of brain and brain stem of varying sizes.

508 MR. KELBERG:

That were preserved from the autopsy of Nicole Brown Simpson by Dr. Golden?

509 DR. LAKSHMANAN:

Yes.

510 MR. KELBERG:

So if we include this section, we would have 14?

511 DR. LAKSHMANAN:

Yes.

512 MR. KELBERG:

And doctor, did you examine each of the 14 sections grossly, that is, without the aid of a magnifying device or a microscope?

513 DR. LAKSHMANAN:

Yes, I did.

514 MR. KELBERG:

On June 22nd?

515 DR. LAKSHMANAN:

Yes, I did.

516 MR. KELBERG:

At the same time that doctors Baden and Wolf could do so if they so desired?

517 DR. LAKSHMANAN:

Yes.

518 MR. KELBERG:

When you did this, did you observe anything of significance to you in looking at the brain tissue that is shown in the photograph that is B-33?

519 DR. LAKSHMANAN:

There was evidence of hemorrhage on the surface of the brain which we refer to in medical terms as subarachnoid hemorrhage, S-U-B-A-R-A-C-H-N-O-I-D, hemorrhage, and underlining the hemorrhage on the surface because it is a section of the brain there was evidence of discoloration of the gray portion of the cerebral cortex and this was a contusion of the brain and it measured ten millimeters by four milliliters when we examined it on June 22, 1994.

520 MR. KELBERG:

Doctor, when that examination took place did either Dr. Baden or Dr. Wolf tell you anything regarding what, if any, observation they made of that tissue?

521 DR. LAKSHMANAN:

We were together and I--myself and Dr. Baden felt that this was a brain contusion.

522 MR. KELBERG:

Did you identify that, without hearing from Dr. Baden, as--as to any view he might have?

523 DR. LAKSHMANAN:

Absolutely.

524 MR. KELBERG:

And as to any view Dr. Wolf might have?

525 DR. LAKSHMANAN:

Absolutely.

526 MR. KELBERG:

Were basically the three of you independently looking at this series of tissue samples?

527 DR. LAKSHMANAN:

Yes.

528 MR. KELBERG:

And when you--

529 DR. LAKSHMANAN:

But independently looking at it but collectively there was one sample there.

530 MR. KELBERG:

Independently looking as you are three individuals, but you are all looking at the same thing?

531 DR. LAKSHMANAN:

Yes, yes.

532 MR. KELBERG:

All right. Now, doctor, how long did it take you in looking at that sample to think that there is something of significance, to you as a forensic pathologist, shown in that sample?

533 DR. LAKSHMANAN:

Immediately you could realize that there was a pathology there.

534 MR. KELBERG:

Why can you do that immediately, as a forensic pathologist?

535 DR. LAKSHMANAN:

Because if you look at the photograph here, (Indicating), you see the normal gray/brown cortex and you see the white matter underlying that and that is a normal appearance and it is obvious that this part of the brain is discolored and hemorrhagic, that is there is bleeding into this part of the brain and that is how a contusion looks.

536 MR. KELBERG:

And doctor, when you use the term "Contusion" with this brain tissue, are you using it in the same terms that you have used it with respect to the photograph B-20?

537 DR. LAKSHMANAN:

Yes. It is a bruising of the brain.

538 MR. KELBERG:

And as you have described in general with blunt force trauma that is of a contusion nature?

539 DR. LAKSHMANAN:

Yes.

540 MR. KELBERG:

Doctor, from your examination--and by the way, have you microscopically examined this tissue sample?

541 DR. LAKSHMANAN:

Yes.

542 MR. KELBERG:

What, if any, significant findings did you make from that observation?

543 DR. LAKSHMANAN:

It was an acute--"Acute" means fresh--contusion of the brain with hemorrhage.

544 MR. KELBERG:

What does the--what is the significance, if any, of the finding that it is an acute hemorrhage?

545 DR. LAKSHMANAN:

It could have occurred as--it occurred immediately after the injury, but it can be observable as early as a minute.

546 MR. KELBERG:

A minute after the injury was inflicted?

547 DR. LAKSHMANAN:

Yes.

548 MR. KELBERG:

So if the person lived a minute with blood pressure, that the injury could get to a condition where it can be seen as it is in this photograph?

549 DR. LAKSHMANAN:

Yes.

550 MR. KELBERG:

And then the person could be dead?

551 DR. LAKSHMANAN:

That's correct.

552 MR. KELBERG:

I'm not saying from this injury, but is this injury, in your opinion, a fatal injury?

553 DR. LAKSHMANAN:

No.

554 MR. KELBERG:

Why not?

555 DR. LAKSHMANAN:

Because it is a single contusion to the brain, but it is a marker for injury.

556 MR. KELBERG:

What does that mean?

557 DR. LAKSHMANAN:

That is, you could have this injury as part of the head injury which Miss Simpson sustained when the contusion to the brain was--contusion to the scalp, skin was sustained on the right side of the head, and by itself you can't call it a fatal injury because it is only a small portion of the brain which is endured, but it could be part--this could be associated with a concussion syndrome. No. 1, it could cause seizures sometimes but by itself you cannot say it can cause death like you can say with a stab wound or sharp force injury.

558 MR. KELBERG:

In order to gain context for that injury, what are you going to have to look for?

559 DR. LAKSHMANAN:

We need to know which side it was from and Dr. Golden's report indicates it was from the right side underlying the contusion--underlying the contusion of the skin.

560 MR. KELBERG:

We are going to get into that in a moment in more detail, but first, when a contusion to the brain is observed at autopsy, would it be the custom and practice in your office to retain that sample of brain tissue?

561 DR. LAKSHMANAN:

Yes.

562 MR. KELBERG:

In retaining that sample of brain tissue would the forensic pathologist be expected to cut it in a fashion so that the entire area of the contusion is preserved?

563 DR. LAKSHMANAN:

Yes.

564 MR. KELBERG:

From your observation on June 22nd, your observation of this photograph and your microscopic examination--or let me finish the question, please, doctor--from your examination microscopically can you determine whether all of the contusion in this area of Nicole Brown Simpson's brain was excised at autopsy?

565 DR. LAKSHMANAN:

The photograph we took was on the 30th. The margins of the area we saw of the brain cortex did show hemorrhage in the margins, so I can't say with certainty whether the contusion which was seen was the extent of the contusion or there was any visible contusion which was left in the brain when this portion was resected.

566 MR. KELBERG:

For a little more clarity, at least for me, is this photograph, B-33, a fair and accurate representation of the tissue as you saw it with Dr. Baden and Dr. Wolf on June 22nd?

567 DR. LAKSHMANAN:

This photographer was taken on June 30th, which is not--

568 MR. KELBERG:

I understand that. My question, though, is irrespective of the difference in dates, is the photograph a fair and accurate representation of the tissue as you saw it on the 22nd?

569 DR. LAKSHMANAN:

No, because we took a section for microscopic study so the photograph we have reflects the injury, but I cannot say with certainty that it reflects the state of the contusion as we saw it on the 22nd, because we didn't take photographs on the 22nd.

570 MR. KELBERG:

You did not take photographs on the 22nd?

571 DR. LAKSHMANAN:

That's correct.

572 MR. KELBERG:

But did you, on or after the 22nd and before the 30th, take a sample of that tissue in order to prepare one or more microscopic slides?

573 DR. LAKSHMANAN:

It was done on the 30th.

574 MR. KELBERG:

And that was done before this photograph was taken?

575 DR. LAKSHMANAN:

A section was taken and this contusion was photographed at the same time.

576 MR. KELBERG:

Well, was the photograph taken--I mean we don't see anything in the form of a cutting device in this photograph.

577 DR. LAKSHMANAN:

No. We have additional photographs which show the section we photographed also.

578 MR. KELBERG:

All right. Do you have a photograph which shows the section before any cutting for microscopic examination was performed?

579 DR. LAKSHMANAN:

I have to see my photographs, whether we have additional photographs.

580 MR. KELBERG:

Could we have a moment for the doctor to do that, your Honor?

581 THE COURT:

Go ahead.

582 MR. KELBERG:

Doctor, go ahead.

583 (Brief pause.)
584 THE COURT:

Although at this point we might as well take a break.

585 MR. KELBERG:

Well, I will get a few more minutes in doctor. Why don't you come back here, we can talk some more, and then you will have a chance to look for it over the noon hour.

586 MR. KELBERG:

Doctor, the kind of brain tissue that is represented in photograph B-33 is what kind?

587 DR. LAKSHMANAN:

It is the cerebral cortex.

588 MR. KELBERG:

What is the cerebral cortex?

589 DR. LAKSHMANAN:

It is the outer surface of the brain.

590 MR. KELBERG:

Is it localized in certain areas of the brain?

591 DR. LAKSHMANAN:

It is mainly the surface of the brain and all the lobes of the brain. You have the same appearance grossly of the brain tissue.

592 MR. KELBERG:

Did you examine this tissue sample to try and determine with greater specificity what part of the brain it could have come from?

593 DR. LAKSHMANAN:

Yes. I--I did a microscopic study--I examined the microscopic sections which were submitted and microscopically there was evidence of the internal granular layer. The brain cortex has several layers and there is an internal granular layer present which would go along with it being from the parietal or temporal lobe of the brain.

594 MR. KELBERG:

Would you show us, please, turning--this is from--well, let me start this way. Can you determine, from examination of the tissue sample, what side of the brain, right or left side, parietotemporal area that tissue come from?

595 DR. LAKSHMANAN:

You cannot tell the side.

596 MR. KELBERG:

Can you tell it in any fashion, by either gross examination or microscopic examination?

597 DR. LAKSHMANAN:

Not from a small sample like this you cannot tell, but microscopically you cannot tell the side either.

598 MR. KELBERG:

Would you now--let's assume for just the sake of argument it is the right side. Would you turn to the right side for the jury to view and point out the area or areas from which this tissue sample would be consistent.

599 DR. LAKSHMANAN:

From this parietal area or temporal area. Actually I'm showing the outside of the head. The brain has got a special structure on the inside. Just a rough demonstration of the anatomical location in the brain. Parietal here, (Indicating), and temporal area here, (Indicating).

600 MR. KELBERG:

Your Honor, for the record, Dr. Lakshmanan is turning to face the jury with profile to the right side has circled with his finger the area just immediately in front of and slightly above the right top of the ear, as the temporal area.

601 MR. KELBERG:

Is that correct, doctor?

602 DR. LAKSHMANAN:

Yes.

603 MR. KELBERG:

And parietal area you circled, if you could do that one more time.

604 DR. LAKSHMANAN:

(Indicating).

605 MR. KELBERG:

Is an area that is directly above the first area that I just described and circles a larger area of the--starting to get to the top of the head.

606 THE COURT:

Yes.

607 MR. KELBERG:

And doctor, obviously there is no way that you can show with us your brain because it is, I assume, safely encased within your skull.

608 DR. LAKSHMANAN:

At this time, yes.

609 MR. KELBERG:

At this time. We will try and keep it in that condition. Can I have one moment, your Honor, with one diagram?

610 THE COURT:

Yes.

611 (Brief pause.)
612 MR. KELBERG:

Thank you, your Honor. This is going to be board 5B out of our set 349.

613 (Brief pause.)
614 MR. KELBERG:

And if Mr. Lynch, while counsel and the doctors are moving, could flip to the form 29.

615 (Brief pause.)
616 MR. KELBERG:

Doctor, this form 29, is this the form that was available for Dr. Golden during the course of the autopsy of Nicole Brown Simpson?

617 DR. LAKSHMANAN:

Yes.

618 MR. KELBERG:

And does this in schematic form show the brain?

619 DR. LAKSHMANAN:

Yes.

620 MR. KELBERG:

Can you show us on this form these areas that could be the areas from which the sample of brain tissue seen in photograph B-33 originated?

621 DR. LAKSHMANAN:

Yes. For that I discussed briefly the anatomic description here.

622 MR. KELBERG:

Your Honor, will you give me a few more minutes?

623 THE COURT:

Yes.

624 MR. KELBERG:

Doctor, we will do so then.

625 DR. LAKSHMANAN:

This is the side view of the brain. This is the--what we call as the cerebrum, c-e-r-e-b-r-u-m, and this is the portion of the brain called the cerebellum, c-e-r-e-b-e-l-l-u-m, and you have a smaller structure here which is the brain stem. The anatomical regions; parietal, temporal lobes which we were discussing refers to this part of the cerebrum, (Indicating). The front--there is a--the brain, as you know, has convolutions on the surface and it is basically divided into a frontal lobe, parietal lobe, temporal lobe and occipital lobe, so the parietal lobe is somewhere this area, (Indicating), and the temporal lobe is this area of the brain, (Indicating).

626 MR. KELBERG:

Doctor, before you go further, just briefly, so I can mark in where--I'm going to put f or frontal.

627 DR. LAKSHMANAN:

"P" for parietal.

628 MR. KELBERG:

"P" for parietal; "T" for temporal and "O"--

629 DR. LAKSHMANAN:

Occipital.

630 MR. KELBERG:

"O" for occipital on the lower right hand schematic.

631 DR. LAKSHMANAN:

So this is what I refer to when I say parietotemporal area and this is what I refer to when I said that microscopically there was internal granular layer present on the layers of the cortex, because the layers of the context have six layers. The frontal area of the brain usually doesn't have a granular layer and it is usually a granular layer so that I can--how I see it is from a parietotemporal area. The occipital lobes has also different areas but they are different areas, so just microscopically I can say that this is from the parietotemporal area.

632 MR. KELBERG:

Doctor, is this schematic showing the right side of the brain?

633 DR. LAKSHMANAN:

Yes.

634 MR. KELBERG:

And the diagram directly above it the reverse showing the left side of the brain?

635 DR. LAKSHMANAN:

Yes, and this diagram shows the top part of the brain as you are looking at the brain from above, and this is the lower part of the brain showing the brain when you are looking at it from the bottom, the brain is turned upside down, and to--your have the cerebellum here, brain stem here, and this is the rest of the brain and this part of the brain is the undersurface of the frontal portion of the brain, the "F" part. This is the undersurface of the temporal lobe which is the "T" part here, (Indicating).

636 MR. KELBERG:

Your Honor, during the recess I will mark what has been done and ask that it be reflected on the record at the afternoon start of the trial.

637 THE COURT:

All right. Ladies and gentlemen, we are going to take our recess for the morning session. Please remember all of my admonitions to do. Do not discuss this case among yourselves, don't form any opinions about the case, do not conduct any deliberations amongst yourselves until the matter has been submitted to you, do not allow anybody to communicate with anybody with regard to the case. We will stand in recess until one o'clock.

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
They are all localized to one area of the neck which would signify that there was some limitation of movement created at least to the neck area when these wounds were inflicted by the assailant, because they are localized to one area, more or less in the same area.
Establishes the prosecution theory that Nicole was held in place—immobilized—while being stabbed, consistent with a controlled attack rather than a struggle.
Dr. Lakshmanan Sathyavagiswaran
The injury to the neck which caused the fatal wound must have occurred after a few minutes or a minute later, because you need some time for the bleeding to occur in the tissues. And for that reason I would say that she was alive at least for a few minutes, at least a minute, if not more, before the last wound was inflicted, because once the last wound is inflicted, you won't have any blood pressure available to cause this kind of bleeding in the scalp.
Establishes a wound sequence and timeline that allows for the prosecution's scenario of the killer moving between Nicole and Goldman during the attack.
Dr. Lakshmanan Sathyavagiswaran
It could be something like a fist, it could be an object with a round smooth surface, like the base of a knife could do that.
Links the blunt force trauma contusion on the right temple to a knife handle—consistent with the prosecution's single-weapon theory.
Brian Kelberg
Assume hypothetically that Nicole Brown Simpson was struck on the head, either with a hand, fist or the rounded end of a knife in the manner you described, and became dazed, as you have indicated, and slumped to the ground and the perpetrator then moved from where her body was over to where Mr. Goldman's body is found, to that area, and then came back to Nicole Brown Simpson and raised her head in the manner you described yesterday and inflicted that major incise stab wound.
The prosecution's clearest narrative reconstruction of the murders, embedded in a forensic hypothetical—placing OJ at both scenes in sequence.

Evidence (6)

B-18
Photographic board showing the four sharp force injuries on Nicole Brown Simpson's left neck
Discussed in detail; wounds diagrammed and measured; cross-referenced with Dr. Golden's protocol
B-10
Cropped photograph showing reddish-brown abrasion lateral to Nicole's right eyebrow
Discussed; identified as antemortem, non-fatal blunt force trauma; cross-referenced with protocol page 8 and addendum
B-20
Photograph of right side of head after postmortem shaving showing contusion in right temporal area
Discussed; used to establish wound sequence and minimum survival time before fatal neck wound
People's 0B / 1B
Blow-up of Dr. Golden's autopsy protocol (form 12), pages 5, 6, 8, 9, 10
Displayed and annotated with red marker by Kelberg; cross-referenced wound descriptions
People's 3B
Diagram form 22 from Dr. Golden's protocol showing wound locations on body diagram
Displayed and annotated; wounds 1-4 and B-10 abrasion circled and labeled
People's 8B
Blow-up of Dr. Golden's addendum
Displayed; showed revised measurement of facial abrasion (half inch vs. 3/8 inch)

Notable Exchanges (4)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg walks Dr. Lakshmanan through a detailed hypothetical in which the perpetrator strikes Nicole, she slumps, he moves to Goldman, returns, and delivers the fatal neck wound—Dr. Lakshmanan confirms this is 'a possibility' consistent with the bruising timeline, with or without the other wounds already inflicted.
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg uses himself as a stand-in for Nicole Brown Simpson so Dr. Lakshmanan can physically demonstrate how stab wound no. 1 could have been inflicted face-to-face with a right-handed perpetrator. Judge Ito intervenes to suggest they switch places so jurors can see the right arm.
demonstrative
Robert ShapiroLance A. Ito
Shapiro moves to strike Dr. Lakshmanan's speculation about why Dr. Golden revised the abrasion measurement in the addendum; Ito sustains and instructs the jury to disregard.
procedural
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Extended back-and-forth on whether the right cornu of the thyroid cartilage was intact or incised—Dr. Lakshmanan corrects Dr. Golden's original protocol finding, identifying it as a mistake of no forensic significance.
procedural

Light Moments (1)

Brian Kelberg / Dr. Lakshmanan Sathyavagiswaran
Kelberg asks Dr. Lakshmanan to explain a CT scan 'down to a lower level for me'—Dr. Lakshmanan obliges: 'It is a fancy x-ray giving three-dimensional views.'

Credibility Attacks (1)

⚔ Dr. Irwin Golden
Discrepancy between protocol and addendum
Kelberg and Dr. Lakshmanan walk through multiple instances where Dr. Golden's original protocol differs from his addendum and from Dr. Lakshmanan's own measurements—including the abrasion dimensions (3/8 vs. 1/2 vs. 7/16 inch) and the incorrectly recorded intact cornu—though Lakshmanan consistently characterizes these as non-significant measurement limitations rather than errors of substance.

Witness Demeanor

(Indicating) — repeated throughout as Dr. Lakshmanan points to photographs and diagrams on the board
(Brief pause.) — multiple procedural pauses for board changes and counsel repositioning

Objections

4 objections (1 sustained, 3 overruled)
Proceeding 6302 • 637 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 7, 1995 📄 Direct examination of Dr. Laks
JUN 7, 1995 KRT DvH TD