Doctor, I want to invite your attention to one of the other blow-up diagrams from our 349 collection. In general terms, doctor, would this diagram be useful to diagram any injury to the skull that may have been received?
Yes. But if there's any skull injury and a fracture, they could use the same diagram on the left side. On the right side, it's used to diagram the scalp injury.
And I want to talk only about the left side. And on the left side, do you see any entry made by Dr. Golden to reflect an observation of any injury to the skull?
On the same poster board, but now 20-G--and I think there were two 20-G's. So this is the one that appears to have outlines of the neck and top of the head. Doctor, is this a form that Dr. Golden can use at the time of autopsy to identify any injury to the skull should he find such an injury?
Yes. On the lower part of the 20-G, there's an area where you can diagram skull injury.
Now, if we can flip one more. Now, doctor, form 20-H--and again, I think there are two 20-H's. So this appears to be a diagram showing four different views of the human skull; is that correct?
Is this a diagram that can be used by Dr. Golden to indicate any observed injury to the skull of Nicole Brown Simpson?
Do you find any entry made to reflect that there was any kind of sharp force injury resulting in penetration of the skull?
There's no record of any sharp force injury penetrating the skull, though hemorrhage has been described underlying some injuries.
And we're going to get to those in a little bit when we look at some other photographs. Is that your reflection of your review?
And--I'm not sure if there's one--yes. And this is the second 20-G, which appears to show a cut-away section of the human skull; is that correct, doctor?
And what is--is this a diagram that can also be used by Dr. Golden to reflect injuries observed to the skull of Nicole Brown Simpson?
Does this diagram in fact have an entry in Dr. Golden's handwriting regarding his observations?
That he did not find any internal injuries such as fractures, which may not be visible on the outside, because you could have what is called inner table fractures and they are not seen either. So that's what he has indicated in this.
The skull has got two tables. You have the inner table and the outer table and indicating to what is called the diploe, D-I-P-L-O-E, part of the skull and where the vascular channels of the skull traverse. So this is the inner part of the skull cap and this is the base of the skull on the inside (Indicating). So "No internal injuries" means no internal fractures of the inner table was documented.
Doctor, if there had been a portion of a knife blade which penetrated the skull and had broken off in the skull, would you expect Dr. Golden to have identified that on this form?
Going back to our exhibit 352, doctor, is there anything else that you want to bring to our attention regarding your examination and observations of either the scalp contusion seen in B-20 or the contusion to the brain seen in B-33?
I'd like to move then to the series of photographs that are to the left of the right side of the head, B-20, and look at photographs B-23, B-24 and B-26.
There are two areas of sharp force injury seen of the back, mid back and right side of the head of Miss Simpson. The one which is on the right side of the back of the head is a linear sharp force injury, which is 3/8 of an inch in length in my measurement of the one is to one photograph, and this is located about two and a quarter inches behind the right ear canal, behind the right ear canal two and a quarter inches and three-quarters of an inch above it. So it's somewhere two and a quarter inches behind and three-quarters inches above this ear canal. This is the location of the injury, 3/8 of an inch in length.
Doctor, can you again turn to indicate the left side of your head towards the jury and--
If the label says, "Lower middle and left of back of head," the "Left" is inaccurate?
All right. Doctor, if you'll turn to the right, would you point out the area where this first sharp force injury you identified in B-23 is?
And, your Honor, for the record, the witness has basically pointed in an area above and behind by several inches the top of his right ear.
It's about 3/4 of an inch above the right ear canal and two and a quarter inches behind the right ear canal. So--
Doctor, if you could hold that--that one. And is there any way you can show us simultaneously where the area of the scalp contusion was that we see in B-20?
The sharp force injury which I just described is here, from right here, about three-quarters of an inch above the ear canal and two and a quarter inches behind the ear canal. The contusion I discovered in the scalp was here (Indicating).
And I think we described that contusion earlier. So I don't see any need for the record. Now, doctor, the description that you've given of this first sharp force injury, B-23--and for the record, it appears to be the sharp force injury which is closest to the vertically oriented blue measuring card; is that correct?
Are you able to determine whether this is an incised wound or a stab wound or what?
In your opinion, does it play any significant role in the death of Nicole Brown Simpson?
Are you able to determine from the appearance of that incised wound whether a single-edged knife could have inflicted it?
Because it's just a incised wound, and I already said that any sharp instrument, either the single--one edge of a knife can cause this incised wound.
And based on what you told us earlier in the schematics that we've gone through, can you eliminate the possibility that a double-edged knife could have caused such an incised wound?
Doctor, are you able to determine if this is a wound inflicted before death, that is an antemortem wound?
Does he diagram this particular incised wound anywhere in any of the available diagrams?
Because my measurement of using the one as to one photograph, it's a 3/8 of an inch in length, but the real measurement he has given--the measurement he has given is 3/16 of an inch.
And why in your opinion does that require an entry in the addendum for this particular incised wound?
Well, since we addressed all the errors in measurement with any--since I found an error in the measurement, I thought if it had been measured correctly, it should have been reflected by the number.
Excuse me, Mr. Kelberg. Could we have the doctor keep his voice up, please? I'm having a hard time hearing.
Doctor, in your opinion, was your measurement obtained by reviewing the life-size photographs one which was different from Dr. Golden's for reasons other than the limitations of the process of photographic measurement?
And as such, is it your opinion that Dr. Golden made a mistake in measuring the dimensions of that wound?
And as a result of feeling he made a mistake, you feel that if he looked at the photographs after the original autopsy protocol was prepared, that he should have addressed that error in his addendum?
And, doctor, in your opinion, are any or all of these mistakes of any significance in evaluating any of the issues you've reviewed?
Because, as I already told you, it doesn't affect the big picture of the cause of death, the major wounds I described already, the bleeding pattern or my ability to tell whether it's a single-edged or a double-edge knife.
Whether his measurement is correct or your measurement is correct, the same single-edged knife that you described as being consistent with causing all of the sharp force injuries could have caused this incised wound?
While we're here, let's take care of the second sharp force injury that appears to the left in the photograph B-23 of the one you've just described. Tell us about that one, please.
This is a wound which is located in the mid lower back of the head, and in my measure--in my measurement using the one is to one photograph, I measured this wound to be 5/8 of an inch in length and--
I'm sorry. Would you point to where--no, doctor. I want to--I want to focus if we could on this injury that's on the far left side. Is that the one you're talking about?
Okay. Let's make that clear first then. Is B-24 a close-up if you will of the injury which is seen on the left side of the photograph B-23?
Then let's focus on B-24 if you feel that that's a better depiction of the sharp force injury. The measurement you obtained is?
And if you'll show us slowly with the pointer in what direction that is obtained.
The length was obtained in the one as to one photograph from this forked end to this end here. So it measured 5/8 of an inch, the forked end was up to quarter inch in width and this is the sharp end of the left side of the wound (Indicating).
So as one looks at the photograph, the forked end is to the right side of the photograph of the wound?
Because the--the depth and the--the--the length of the wound surface is more like--it's longer than the depth, but the margin of the wound has some forking. So it could have been a kind of initial penetration component to the knife with either a movement of the head or the knife which created this--and turning of the knife which created this forking as well as the incision component to the wound.
So if I understand correctly, initially there could have been a penetration of the scalp with the knife?
Yes. But either the head was moving or the knife was moving on the scalp and some twisting to cause the fork appearance of the wound with the knife being drawn to create this type of wound.
Doctor, is that the schematic no. 3 that we saw in that chart that was up here yesterday afternoon?
And given the depiction of a forked end and a sharp end, are you able to tell us whether a single-edged knife could have caused that particular sharp force injury?
And is it also fair to say that you can not exclude from the appearance of the wound that a double-edged knife could have done so?
But is there any finding which in fact says that it was a double-edged knife and not a single-edged knife?
Yes. The depth was, as I said, 3/8 inch to half an inch and the length of the wound surface is 5/8 of an inch. So by definition, should be an incised wound, but because of the appearance, we call it a stab/incise because of the explanation I've already given you.
Because it would cause some bleeding, but not significant bleeding to result in death.
Is there any way medically that you can determine how long prior to death at a minimum that that wound must have been inflicted?
It's a sharp force injury which has hemorrhage in the tissues. If you look at the diagram we just saw earlier, you can see the hemorrhage underlying--I'm sorry. Not underlining this one. The other one. This hemorrhage could be as early as--as short as even a minute before death.
Now, doctor, is this sharp force injury seen in both 23 and 24 addressed by Dr. Golden in his original protocol?
Why was there a need if you believe there was a need to address it in the addendum?
Because in the diagram, he diagrammed it as a half an inch long wound, but in the original report, it was transcribed as a one and a half inch--one and a half inch long wound, and also the depth was given as one and a half inches, and this had to be corrected in the addendum.
Before we move to those protocol pages, diagrams and addendums, is there anything else--something I wanted to ask. From either of these two sharp force injuries in B-23, are you able to determine whether the perpetrator held the knife in the right hand or the left hand?
And is there anything about Dr. Golden's mistakes with respect to either of those two sharp force injuries that would have, had they not occurred, facilitated your ability to make that determination?
I'll try again. You have to keep your voice up, please, doctor. Assuming Dr. Golden hadn't made the mistakes you identified with respect to these two sharp force injuries, would you have been better able to determine whether the person held the knife in the right hand or the left hand when these two sharp force injuries were received?
Even if he had accurately depicted them, it would not have made any difference in my ability to opine what I already opined.
Now, is there anything else you want to talk about with respect to the wounds themselves as seen in the photographs before we move to the protocol diagrams and addendum?
Doctor, where in the original protocol does Dr. Golden address either--the protocol, doctor, not the diagrams.
Let me just get my markers. Doctor, where on this page--let's start with the one on B-23 that was more or less in the center of the photograph next to the vertically oriented measuring card.
Now, doctor, where if at all in the diagram or diagrams was that particular wound identified?
Doctor, you've got to keep your voice up. Remember that the reporter is behind you. So it's difficult to hear you.
Your Honor, where Dr. Lakshmanan has indicated with the pointer, I'm circling the area on form 20-F and I'm writing B-23 in red.
Doctor, is this sharp force injury diagrammed anywhere else in any of the other diagrams?
In other words, if you had an opportunity to look at the one as to one photographs and measure.
But it's based ultimately on your belief that there was an error made in the measurement?
Mr. Kelberg, Mr.--doctor, perhaps you can allow each other to finish asking the question before you start to answer, doctor.
And I apologize, your Honor. I'm just going to use the marker with a little more ink in it and write in the 23 on form 20-F in a little clearer fashion.
Doctor, let's go to the second of the sharp force injuries seen in B-23 which is shown, as you said, in close-up on B-24. Where is that addressed in the protocol?
All right. And I'll mark in--actually in blue just to set it off a little better, and I'll write B-24 and comma and B-23. Now, doctor, you mentioned something about how the measurement was reflected in the original protocol?
The transversely oriented wound measures one and a half inches in length and the depth of penetration is 3/8 of an inch to one and a half inches.
This wound here has got the forking on the right side and here's a description, it says transverse cutting half an inch wound and 3/8 inch to half an inch deep. So he has diagrammed the measurement accurately (Indicating).
And the area, doctor, where you've just outlined, I'm circling in blue and I'll write again B-24, B-23. The measurement that is given on the diagram itself, the 1/2 inch and then the depth of 3/8 to 1/2 inch, do those measurements correlate with your measurements?
No. My measurements was actually 5/8 of an inch in length and a quarter inch wide fork, but given the limitation of the process--as you know, it's a gaping wound--I could not approximate it. So given the limitation of the process, his measurement is--falls within my perimeters, given the limitation of the process.
So given that limitation, your measurements are consistent with what is diagrammed?
Yes. There is a--from my measurement and his measurement, there is a 1/8 inch difference in the length. But I would attribute it to the limitation process because of the gaping nature of the wound and the forking that you see there.
But your measurement and Dr. Golden's diagram description of the measurement differ from what is actually in the transcription of the description of the wound?
And let's look at that if we could. Is there any other diagram that has any reference to that second sharp force injury from B-23?
Doctor, on this first page, do you see the reflection in the addendum of a correction for that sharp force injury that's seen in both 23 and 24?
Yes. For--actually the correction is for photograph 24--I mean wound for 23 and 24. It's number 1, page 6, line 4 and line 6 (Indicating).
And where you've just pointed, doctor, I'll outline that in blue and write B-24, B-23. And in essence, does--I'm sorry. You wanted to add something, doctor?
Yeah. I said can be attributed to limitation of the process. This can not be attributed to the limitation of process because there is an 1/8 inch difference. I opined a little differently. It should be--it can not be attributed to the limitation process. So there is a difference.
We'll back up and make sure we have that clear. Let's start with this first of all. The addendum change is to change what the measurements were as transcribed on page 6 of the protocol--
--to the measurements that were written in on the form 20-F that we saw just a moment ago?
Now, you say that your measurement in some fashion, which differs from a measurement of Dr. Golden's as he diagrammed it and as he has corrected the report to reflect, differs in a way that you believe cannot be attributed to the limitation of the process?
Excuse me, doctor. Would you turn just slightly because I don't think all the members of the jury can hear you.
He has diagrammed the injury to be half an inch in length and the gaping state of the photograph in the one as to one photograph I measured it to be 5/8 of an inch, which is 1/8 inch more in the gaping state, which I can not attribute to the limitation of the process of the gaping state.
If you recall, yesterday we had several photographs from a forensic pathology text shown on the overhead and we've had them made into exhibits that showed a gaping wound and then it had been approximated. Do you recall those photographs, doctor?
And when a gaping wound is approximated, what would you expect with respect to the length of the wound when approximated from the length of the wound in the gaping state?
The length of the wound in the approximate state is longer than the length of the wound in the gaping state.
The length of the wound in approximated state is longer than the length of the wound in the gaping state.
And, doctor, did you find from your measurement in the life-size photograph, that in the gaping state, the length of the wound was greater than Dr. Golden has diagrammed and indicated in the addendum from an approximated state?
Well, it's definitely a measurement error, but not as far as the appearance of the wound. It's a nonfatal wound. As far as the big picture goes, it doesn't have any immediate impact on the cause and manner of death.
Doctor, is there any significance as to whether this wound is 5/8 of an inch that you measured in the gaping state or 1/2 inch as measured in the approximated state, according to Dr. Golden, on any of these big ticket questions?
As I already mentioned, it's a nonfatal wound. I already discussed the major wounds where I've indicated the cause of death. I've indicated the blood flow pattern. I've indicated that it's a single-edged knife or double-edged knifed which caused those wounds. I've indicated in this wound, I can't tell if it's a single or a double-edged knife. So I met the requirements to give an opinion on this case. So this small difference in measurement doesn't impair my ability to give an opinion of this case.
Is there anything else you want to say--and don't forget, if you'd speak to the ladies and gentlemen of the jury.
Is there anything else you wish to add regarding these two sharp force injuries that we've talked about from photographs B-23 and B-24?
Yes. Let's do that. All right. Ladies and gentlemen, we'll take a 15-minute recess. Please remember all of my admonitions to you. We'll stand in recess until 2:30.
it doesn't affect the big picture of the cause of death, the major wounds I described already, the bleeding pattern or my ability to tell whether it's a single-edged or a double-edge knife.
Objection. Calls for speculation. He's already admitted to 30 mistakes.
No internal injuries.
I met the requirements to give an opinion on this case. So this small difference in measurement doesn't impair my ability to give an opinion of this case.