Thank you, ladies and gentlemen. Please be seated. All right. Doctor. Let the record reflect all our jurors have now rejoined us. And, Mr. Kelberg, you may continue with your direct examination.
Thank you, your Honor. Your Honor, before beginning the actual questioning, I have a series of exhibits I ask to be marked with the following designations: I have an 18-page autopsy protocol form 12 that I ask to be marked as exhibit 356-A, and I'm going to staple that for the convenience of the clerk.
And I'm going to ask Mr. Lynch to mark on the last page of these subexhibits what the exhibit identification is so hopefully it will be easier for your clerk. I have, your Honor, what appear to be two form 15's which I ask collectively to be marked as 356-B. And actually I'll do the writing on the back. I think it might be a little faster.
And for the purposes of identification, one appears to have the box for stomach contents unchecked. One appears to have the box checked. A one-page form 16, your Honor, that I would ask to be marked as 356-C.
Two form 20 diagrams, which bear respectively the identifying notation at the bottom right-hand corner, roman numeral I and roman numeral ii, collectively as 356-D as in dog.
Similar series of form 21's, only roman numerals I, ii and iii, and ask that they collectively be marked 356-E.
A similar series of form 22 documents with roman numerals I through iii, three pages collectively, as f, 356-F.
A series of form 23 diagrams also with three of them, roman numerals I, ii and iii, collectively as g, 356-G.
And this h is a form that shows the four different views of the human skull. A 20-G, which is the one showing the skull from the top exterior and the internal view, as 20-J--I'm sorry. 20--356-J.
A five-page autopsy report addendum report, which is for the first four pages a mixture of typing, handwriting, and the last page, what appears to be all handwriting, as 356-N as in Nancy.
A two-page series of toxicological analysis reports, one dated June 21, 1994, one dated August 11, 1994, collectively to be marked, your Honor, as 356-P as in Paul.
A form 42-A appearing to bear the signatures of Dr. Vale and Dr. Anselmo and a corresponding form 13, typewritten, bearing their signatures collectively, your Honor, as 356-Q.
And finally in this series, your Honor, the form 1 and the form 2, the form 1 appearing to be identical to the 3--I'm sorry--293-B as in boy form, but without any redaction, but collectively as 356-R.
Also, your Honor, I have a series of boards that I would ask collectively to be marked as exhibit 357 and designated on the back of each board similar to what we were doing with the brown charts from 0-G through 13-G.
Counsel, will you stipulate that these charts, exhibit 357, are exact replicas of the exhibits 356-A through r, with the exception that they are blow-ups?
Doctor, the various materials that I described as exhibits being marked 356-A through r, have you reviewed all of those documents with respect to an evaluation of the circumstances surrounding the death of Ronald Goldman?
Have you also reviewed one-to-one photographs, life-size photographs that were obtained from the negatives for photographs made on June 14th, 1994 as part of the original autopsy process?
Have you basically reviewed all of the available medical information on the Ronald Goldman autopsy for the purposes of reaching, if you can, independent conclusions on a variety of issues?
Whether one single-edged knife could have caused all sharp force injuries to Mr. Goldman?
The blood patterns, that is the flow of blood expected from any injuries sustained by Mr. Goldman in the course of his death?
And on the issue of how long Mr. Goldman lived from the time of receipt of any first injury until the time of death?
Doctor, just as, again, kind of big ticket approach, what is your opinion, independent opinion to a reasonable medical certainty on the cause of Mr. Goldman's death?
And when you described in acknowledging a lay term I posed, "Bleeding to death," when describing the cause of Nicole Brown Simpson's death, would the same apply to the death of Ronald Goldman?
Doctor, did you form an opinion as to whether a single single-edged knife could have caused all of the sharp force injuries received by Ronald Goldman?
A single-edged knife could have caused all the injuries and sharp force injuries in Mr. Ron Goldman.
From your evaluation of all sharp force injuries, can you exclude the possibility as to some of those sharp force injuries that a double-edged knife may have been involved?
For the same reasons that you have expressed with respect to the Nicole Brown Simpson issues?
Did you see, however, any evidence that there was in fact a second knife which was not this single-edged knife you described as being a possible weapon for all of the sharp force injuries?
You mean if I saw any injury which would reflect unique characteristics for such a weapon?
Doctor, did you also evaluate the circumstances available to estimate a range for time of death for Mr. Goldman's death?
Your Honor, I have a board of photographs that--six photographs, sharp force injuries, blunt force trauma to the face, neck and right shoulder of Mr. Goldman. May this be marked as exhibit 358?
Doctor, before I reach for that exhibit, in your analysis of all the materials, did you find, first of all, that Dr. Golden was the autopsy surgeon? Did you find that he was?
Did you find that Dr. Golden made a lot of mistakes in the course of the autopsy of Ronald Goldman?
For the purpose of assessing its significance if any to each of the issues that we've posed here today?
Do you have an opinion as to whether, singularly or taken collectively, any of the mistakes that you attribute to Dr. Golden for the Ronald Goldman autopsy have any significance on any of the issues we've identified?
Your opinion is--I'm not sure if the no--I may have lost track of the question myself. Is the no, that you have no opinion or is the no, your opinion is that it has no significance?
My opinion is, it has no significance to my opinion on the cause of death, what type of weapon could have caused all the injuries and other issues which were discussed earlier.
And, doctor, we're going to, much like we did through the course of the Nicole Brown Simpson autopsy, ask you to explain your reasons for finding that there is no significance from any or all of these mistakes by Dr. Golden on these issues that you've identified. Now, with that, doctor, let me start with exhibit 358. And again, with the Court's permission, could you step to the easel.
Doctor, all of these photographs from exhibit 358 are photographs that were taken on June 14th, 1994 in the course of the autopsy process for Ronald Goldman?
I want to invite your attention again, much like the photographs on Miss Brown Simpson, there are designations. They're somewhat faint with a letter, this time g instead of b, and a numerical designation afterwards for each of the photographs. Do you see that?
Doctor, first of all, is the title of this board accurate with respect to what is shown in the collective group of photographs?
Let me invite your attention first, if I could, doctor, to photograph G-37. I'll point to it from here.
You have to keep your voice up, don't forget, doctor. And, doctor, I'm not sure if you may be blocking any juror's view if you get in front of the board. You can use the pointer. G-37 is the photo I'm pointing to now.
The photograph shows the neck area and facial area of Mr. Goldman. The neck is exposed by a little bit of the extension of the neck, and you can see evidence of sharp force injuries in the neck. I'll address them one by one. There's also a sharp force injury to the right collar bone area. The sharp force injuries I just alluded to include--
Let me interrupt you before you start in just--no. 1, is something being done by someone with the Coroner's office for the purposes of the photography to make the area more exposed?
The block underneath the neck to show the neck area better so that the injuries could be well documented.
Now, doctor, could we start, please, if--you've indicated I think already you prepared a wound chart--
And does this wound chart serve to identify each and every injury, wound or finding that you have made on all of the photographs you have reviewed?
And in your review of photographs, did they include photographs that are not included in the array of photographs that the jury will see?
And again, we have some photographs, for example, the one in the upper right-hand corner, G-50, that has obviously been cropped. That is pursuant to the order of Judge Ito?
But you have reviewed in the one-to-one photograph, the life-size photograph, the actual full photograph; is that correct?
Which is our exhibit I believe 351, your Honor? Is that--I want to be sure we mark the wound chart for Mr. Goldman. I thought we did at the time. If I can have a moment, I can check.
Does this wound chart also identify where, if at all, as to each injury finding and so forth, Dr. Golden made some entry in the protocol?
Let me start then, doctor--oh, also, last thing--I'm sorry--preliminarily. Did you include then an overview of your findings, not just a description, but your findings in the last column under "Comment"?
And did you also indicate as to each sharp force injury whether it could only be caused by a single-edged knife or that it could be caused by either a single-edged or double-edged knife?
Now, let us start, if we could, with G-37. And let me invite your attention--is the area of the photo that I'm using my finger to trace what you have described as injury no. 1?
It is a superficial incised wound to the front of the neck, measures approximately three inches in length and about--and gapes in width up to 3/16 of an inch in the photograph.
Does Dr. Golden describe this superficial incised wound in his original autopsy protocol?
Before we get into the why's of all of that, are you able to determine, doctor, whether that superficial incised wound was inflicted before death, at or around the time of death or after death?
Because of the bleeding in the tissues which one can see and also the appearance of the wound.
And is it consistent with being inflicted with a single-edged knife such as you described the knife in general terms would have to be for the Nicole Brown Simpson sharp force injuries?
Doctor, before we get into the protocols and so forth on that wound, I want to invite your attention to an area underneath that where I'm tracing now (Indicating). Is this an area you have described as injury no. 2?
It's another incised wound which is below the injury no. 1 I just described. And this photograph only shows a three-inch portion of it because this wound extends not only from the left side of the neck all the way to the right side of the neck, but this photograph only shows a portion of the front of the neck.
Doctor, are you able to offer an opinion as to how long Mr. Goldman lived from the time that that wound was received, no. 1, at a minimum?
It was not a fatal wound, but you're asking me in taking the context with all the fatal wounds or--
Well, let me ask it this way. Is there any way you can determine from merely the appearance of the wound, a minimum length of time that Mr. Goldman must have had a beating heart from the time that that incised wound was inflicted until death?
It could have been just within a minute before his death. He could have had--he could have had the wound and as long as he had blood pressure, it will have this appearance. It's only a superficial wound.
Now, I want to invite your attention, if I could, please doctor, to the photo to the right and slightly below photo G-37, which has the designation G-55. Do you have see that, doctor?
Do you see in G-55 any aspect of injury no. 1, the higher superficial incised wound that we saw in G-37?
Injury no. 1 is seen in the front of the neck here, a portion of it. Actually the end here is seen here in this photograph here (Indicating).
For the record, what you pointed to initially was what is the right side end of injury no. 1 as seen in G-37 and the equivalent aspect of the injury on G-55; is that correct, doctor?
Do you see any aspect of injury no. 2, the lower incised superficial wound in photograph G-55?
Yes. You see it continuing right and continuing all the way, and it seems to end in a larger stab/incised wound of the right side of the back of the neck here (Indicating).
And you're indicating an area that is perhaps half an inch above the top border of a blue photographic identification card in photograph G-55?
Doctor, with respect to that second lower incised wound, inviting your attention to photograph G-40, the photograph that is just to your right, do you see another aspect of that particular wound?
Yes. You see that wound ending in this larger stab/incised wound of the back of the right side of the neck. You can see it ending here (Indicating).
And is that area where it is ending and the stab wound that you've indicated, G-40 somewhat in the center of the photograph, is that the same wound seen in a fuller context as what appears on the left side of the--I shouldn't say the left side. It's the right side of the neck, but it's the left side of the photograph of G-55?
Now, doctor, inviting your attention over to this photograph, which is to the left side of the photograph board, G-51, do you see either the upper or the lower superficial incised wound in that photograph?
Yes. You see a portion of the superficial incised wound no. 1 above the large injury of the left side of the neck.
And that large injury on the left side of the neck seen in G-51, is that also seen in G-37, the photo to the right?
And for the record, you're indicating what appears to be a gaping wound about in the middle of the photograph and on its right margin. Doctor, is there any significance to you in the relative appearance of the two superficial incised wounds?
They look like controlled cuts on the front of the neck, which would indicate to me that the--Mr. Goldman was at some--at some point in the altercation, was immobilized and there were control cuts applied to his neck because they are parallel and they seem to run in a left to right--seem to run from one side of the neck to the other.
KEY QUOTEThey are adjacent to each other and parallel to each other. That is, they have the same axis, horizontal axis in the neck. If you look at it, you can see that both of them are running like a railroad track adjacent to each other.
Because one, the lower wound is a longer wound, if you take all the measurements, is about six inches long. You have a--two wounds which are linear, superficial, parallel to each other, which would indicate that Mr. Goldman was held and immobilized, and these cuts were made and there's no struggle at that point because of the appearance of the wound. That would be my opinion on that two wounds.
Doctor, if I can slide under here, and if you would use me as Mr. Goldman and use yourself as the perpetrator, can you indicate the relative position you believe is demonstrated from these two superficial incised wounds?
One position would be holding him in some manner like this (Demonstrating) and putting your knife in front of the neck and running the knife parallel. It would be like some kind of threatening cuts.
And for the record, your Honor, Dr. Lakshmanan with his left arm had it around my upper chest area, bent at the elbow and with his--
And with his right arm extended in front about the middle portion of my neck, and then moving the right arm, appears to be as if holding an object, pulling it towards the right side of my neck.
The other factor which supports this theory is these two small nicks above and the abrasion below the second injury you see here (Indicating) which we can discuss and--because that would also indicate that the knife was in the front--
--the knife was in the front of the neck and the tip of the knife also caused a smaller cut you see above the superficial cut which I just described as injury no 1 here, and there's also a smaller abrasion below the larger cut in the front of the lower part of the neck (Indicating).
He was held tight so he couldn't move so that these control cuts could be made.
Doctor, do you have an opinion in the relative course of the events when those two superficial incised wounds, injuries 1 and 2, were received by Mr. Goldman relative to the time of his death?
I would favor that they occurred earlier during the altercation because you have other wounds which are more serious wounds and they were--caused death in a rapid manner. Once we discuss all the wounds, you will see that quite a few of his wounds struck certain vital structures which resulted in bleeding and death rapidly after that without medical treatment. So this would have occurred earlier in the struggle.
Doctor, if Mr. Goldman were physically able to move about to try and avoid a sharp force injury such as is seen in injury no. 1 or no. 2, would you expect to see the parallel nature of those two injuries?
There would be other cuts and it won't be so parallel and linear as we see it in this photograph and all the three photographs we have studied so far.
Doctor, the nicks that you were pointing out, I'm afraid I did not get a chance to actually see very clearly.
There's one nick here, but of course this is an abrasion. We're talking about this nick here (Indicating).
For the record, your Honor, where Dr. Lakshmanan is pointing is to an area above injury no. 1 and it is more towards the left side from the midline of the neck under the chin.
And where he said "Not this," I think he said the word "Abrasion," he was referring to some discoloration apparent in the photograph which is below the lower injury no. 2 in about the center of that injury.
And I've labeled these as injury no. 3 and no. 4 for my evaluation of the photographs in my photographic evaluation description.
This cut and 4 being this abrasion below this--other superficial cut. So to recapitulate, you have injury no. 1, which is the superficial cut in the upper part of the front of the neck. You have injury no. 2, which is the lower wound, which is parallel like a railroad track I mentioned earlier. You have no. 3, which is a smaller cut above injury no. 1, which is on the left side of the front of the neck, and you have a smaller abrasion here (Indicating).
Doctor, is there anything about the appearance of the--either the ends or the margins of injury no. 1 that assists you in forming an opinion that it is a control type sharp force injury?
There is no additional cuts there. They--and looks like these are threatening cuts.
Like this is something that you--you threaten somebody when you do this kind of injury. You can see these types of injuries when someone is being immobilized and you're threatening them that you're going to do bodily harm to them when you do this kind of injury.
And is the same answer applicable to your examination of the edges, margins and ends of injury no. 2?
Doctor, was injury no. 3, this cut, addressed by Dr. Golden in the original protocol?
Injury no. 4, what you've described as an abrasion in the area below the incised wound that you've marked no. 2--
I'm sorry. I labeled as injury no. 4 the smaller one, and this is injury no. 5 (Indicating).
But, in fact, for the purpose of our exhibit 351, your wound chart, you have actually labeled the cut as injury no. 4?
Injury no. 3 refers to this larger wound in the left side of the neck, which is described better in G-51.
And we'll get to that momentarily. Doctor, with respect to the cut which is now you say injury no. 4--I'm sorry--did Dr. Golden describe that in the protocol?
Doctor, are you able to offer an opinion as to how Mr. Goldman sustained the abrasion that you have identified as injury no. 5?
That could have been from the--just a scratch from the tip of the knife. That's one possibility. And the other possibility is, when he tried to during the struggle, there could have also been a scratch injury.
From the person who is perpetrating the act, he could have scratched that area, the small abrasion here (Indicating).
If, again, you use me as representative of Mr. Goldman and yourself as representative of the perpetrator, how is such a scratch injury inflicted?
Underneath the second wound, when you're doing it with this part of the thumb and you're holding the knife this way, you can have--that can also happen (Demonstrating).
And for the record, Dr. Lakshmanan took the same position as previously described, but this time with his right hand, he had the back of his thumb pressing against that area of my neck and drawing it across to the right side of the neck, your Honor.
Doctor, in your opinion, both injuries 4 and 5 are ante mortem because of the manner in which you've described you believe that they were received?
Doctor, let me--as long as you had injury no. 3, is injury no. 5 the last injury that you have identified on G-37?
Your Honor, Dr. Lakshmanan is pointing to the lower left corner area of G-37 and to an area that is just immediately below the left edge of the blue paper that is seen behind the neck.
Doctor, is that area of the body an area that would normally have been covered by the shirt that you told us I think yesterday you examined at some point, the shirt worn by Mr. Goldman?
Did you find a corresponding defect, using your term I believe, in the shirt for that particular sharp force injury that you've described as injury no. 6?
No. The shirt was pretty loose over Mr. Goldman. So the shirt could have been retracted at some point during the struggle when this wound was inflicted.
If that had occurred, then would you expect to see necessarily the defect be in the area where if the shirt were worn normally, the shirt would be covering the area of injury no. 6?
I won't expect to see any defect in the clothing if that's what happened, and we don't have a defect in the clothing when we examined it in detail this year and last year. Correction. This year.
Doctor, let me ask you then if there's anything else you want to tell us about initially injury 1, injury 2, injury 4, injury 5 or injury 6?
Nothing other than what we already discussed, and injury no. 6 was discussed in the diagram and protocol of Dr. Golden.
By the way, doctor, all of these sharp force injuries, 1, 2, 4, 5, 6, are they all sharp force injuries that could have been caused by the same single-edged knife that you described as a knife which could have caused all of the sharp force injuries received by Nicole Brown Simpson?
Now, doctor, let's talk, if we can, about what you have described as injury no. 3.
This is a larger incised stab--it's a complex sharp force injury to the left side of the neck. And in the one is to one photograph, I measured this as three inches in the horizontal axis, that is on the side-to-side axis of the photograph, and in the gaping state, it measured nearly 15/16 of an inch. In the vertical axis, that is the up down area of the photograph, it's a complex wound. There seems to be a cut in its lower margin here in its--in the left side of the photograph in the margin--lower margin near the left side of the photograph.
In G-51. And there's also a linear abrasion which is one and a half inches long which extends below the complex injury which I just described. The outer aspect of this injury on the right side of the photograph G-51 shows a forking injury with an abrasion in-between. It's a very complex injury.
And is that the same vein that you described with respect to both the left and right sides of Nicole Brown Simpson and that major stab incised wound that you have testified in your opinion was the last sharp force injury she received?
Was there evidence that the left side carotid artery was impacted by that sharp force injury, that stab/incised complex wound that you have identified as no. 3?
Doctor, do you have an opinion--setting aside all other injuries that may have been received prior to the time that injury was received, do you have an opinion as to how long at a minimum Mr. Goldman would remain alive? Let's start with just that. Would remain alive.
With an internal jugular cut and heavy bleeding and if there's no medical treatment, you could die sometimes immediately if you have an air embolism. But if--but if the normal course of event is bleeding and death, they could live for up to 15 minutes to half an hour depending on without medical treatment and the wound continues to bleed and they don't seek medical treatment.
"Air embolism," because it's a large vein, the vein can sometimes suck air into the--into the venous channel, and that can enter the heart and cause obstruction to the blood flowing from the right side of the heart, and that would result in death.
Doctor, is there a difference in your opinion as to the minimum amount of time Mr. Goldman would live from such a fatal stab wound as from the amount of time such a wound in and of itself would take to incapacitate him from attempting to resist any further injury?
He would be able to--he won't be incapacitated until he goes into shock. And for him to go into shock, he--as I discussed earlier, for anybody to go into shock, you need to lose 2/5 of your blood volume rapidly. And yesterday, I discussed the blood volume of the body is about five liters. So you have to lose two liters of blood rapidly to go into shock. So until the time he goes into shock from that wound, assuming that's the only wound in your hypothetical situation, he will be able to be conscious and resist.
Doctor, is there any diminishment in the effort that can be made by Mr. Goldman to resist even though he's in some sense able to resist prior to the time he becomes unconscious from loss of 2/5 of his blood volume?
As blood pressure drops because of blood loss, naturally he will become weaker. So as time progresses, his ability to resist would decrease.
Doctor, do you have an opinion in the relative sequence or scheme of injuries received, sharp force injuries received by Mr. Goldman, as to where this injury no. 3 came?
This could have come in the earlier or mid portion of the altercations because we have two other injuries which are more--which are also serious injuries. He has a stab wound to the left abdomen which struck the aorta in two places, and you also have stab wounds to the right chest, which hit the lung. And those injuries without medical treatment would have caused him to become in shock within a very short time, within a minute or two. So if you take that in context with this wound, this wound could have occurred during that--concurrently or earlier than those wounds. It could be either way. These are all serious--these are the three serious wounds he has which would cause loss of blood pressure. And among the three wounds, the aortic wound would be most significant in bleeding and more rapid loss of blood pressure than the jugular vein, which would take a longer time to lose blood pressure when you compare it to the big large aortic, which is in the lower part of the abdomen. So--and since I said that the aortic wound could cause loss of blood pressure in a minute, the jugular vein injury if it had occurred within a minute before the aortic injury, it could cause significant bleeding also.
Doctor, as a big ticket type of question, do you have an opinion as to a minimum amount of time it would take for a properly motivated, physically fit human being with the element of surprise to have inflicted all of the sharp force injuries and blunt force trauma received by Mr. Goldman?
Doctor, have you considered from your review of all of the evidence the number of sharp force injuries sustained by Mr. Goldman?
And considered the nature of what the body's reaction would be to those injuries?
Have examined by physically being at the 875 Bundy location any environmental sources like trees?
Trees, brushes--not brushes. Excuse me--bushes, fences, gates, anything of that nature which might be a source or sources for that blunt force trauma?
And have you evaluated a minimum period of time such a human being who is motivated, armed with a single-edged knife such as you described in approximate terms, could have inflicted all of those injuries on Mr. Goldman?
Your Honor--I'm sorry. Doctor, assuming that a single person perpetrated all of these sharp force injuries on Mr. Goldman and assuming that as a result of the lethal assault by that single individual on Mr. Goldman, he sustained all of the blunt force trauma you identified and assuming that that single perpetrator was six foot two, 210 pounds, motivated, in a rage, with a knife with a six-inch blade, can you form an opinion as to the minimum amount of time necessary under that hypothetical for that person to have inflicted these injuries?
Death in the hands of another, homicide.
They look like controlled cuts on the front of the neck, which would indicate to me that the--Mr. Goldman was at some--at some point in the altercation, was immobilized and there were control cuts applied to his neck because they are parallel and they seem to run in a left to right--seem to run from one side of the neck to the other.
You can see these types of injuries when someone is being immobilized and you're threatening them that you're going to do bodily harm to them when you do this kind of injury.
Until the time he goes into shock from that wound, assuming that's the only wound in your hypothetical situation, he will be able to be conscious and resist.