📄 Direct examination of Lakshmanan Sathyavagiswaran (morning, part 1) — Thursday, June 8, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\8\DIRECT-EXAMINATION-OF-LAKSHMAN.DOC
TRIAL
▲ Day 91 of 167

Direct examination of Lakshmanan Sathyavagiswaran (morning, part 1)

Witness: Dr. Lakshmanan Sathyavagiswaran
Examiner: Brian Kelberg
Called by: Prosecution • Date: Thursday, June 8, 1995 • Utterances: 629
Prosecutor Brian Kelberg continues his direct examination of Chief Medical Examiner Dr. Lakshmanan Sathyavagiswaran, methodically walking through autopsy photographs of Nicole Brown Simpson's hands and back. The session covers Dr. Golden's errors in the original autopsy protocol (wrong finger identified for an abrasion, misclassifying antemortem injuries as postmortem excoriations from ant bites), and a detailed discussion of why no sexual assault kit was taken and why one would have been scientifically useless for establishing time of death or identifying a killer.
1 MR. KELBERG:

Thank you, your Honor. And good morning, ladies and gentlemen.

The jury: Good morning.

DIRECT EXAMINATION (RESUMED) BY MR. KELBERG

2 MR. KELBERG:

Doctor, I believe we are going to go back to the photo, back to People's exhibit 355, to finish up some photographs of the hand and other areas of Nicole Brown Simpson, so again with the Court's permission, if we can--

3 THE COURT:

Yes.

4 (Brief pause.)
5 MR. KELBERG:

And for the record, your Honor, we did correct the entry on photograph B-23 of exhibit 352 to reflect that it is the right rather than the left side of the head.

6 THE COURT:

All right. Noted for the record. Thank you.

7 MR. KELBERG:

And, your Honor, we also corrected exhibit 354, I believe it is the crime scene board, to show that the photographs were taken on June 13, 1994, rather than `95, as originally depicted.

8 THE COURT:

Thank you.

9 (Brief pause.)
10 THE COURT:

Mr. Kelberg, can I see that just briefly?

11 (Brief pause.)
12 THE COURT:

All right. Thank you.

13 (Brief pause.)
14 THE COURT:

All right. Doctor, why don't you take the pointer with you.

15 DR. LAKSHMANAN:

Yes, your Honor.

16 THE COURT:

Thank you. Mr. Kelberg.

17 MR. KELBERG:

Thank you, your Honor.

18 MR. KELBERG:

I believe, doctor, we were talking yesterday about B-31 and B-12 with respect to the palm side of the right hand; is that correct?

19 DR. LAKSHMANAN:

Yes.

20 MR. KELBERG:

And doctor, was there anything further that you needed to discuss with respect to any findings with respect to the palm surface of the right hand?

21 DR. LAKSHMANAN:

No.

22 MR. KELBERG:

Doctor, is there any photograph on this board, exhibit 355, showing the back of the right hand?

23 DR. LAKSHMANAN:

Yes. Photograph B-1 shows the back of the right hand.

24 MR. KELBERG:

Doctor, would you normally expect, at the time of the June 14th, 1994, photography process, that a photograph similar in nature to the photograph B-29, showing the back of the left hand, would have been taken of the back of the right hand?

25 DR. LAKSHMANAN:

Yes.

26 MR. KELBERG:

Was any such photograph taken?

27 DR. LAKSHMANAN:

No.

28 MR. KELBERG:

Are you able, from your examination of photograph B-1, to see anything of significance with respect to the back of the right hand?

29 DR. LAKSHMANAN:

There is some blood staining, but one can also see a small abrasion on the right index finger which has been addressed in the report.

30 MR. KELBERG:

Just to set the correct sequence of events, the photograph B-1 was taken on June 14th?

31 DR. LAKSHMANAN:

Yes.

32 MR. KELBERG:

And is this one of the first photographs that would have been taken in the course of the autopsy process?

33 DR. LAKSHMANAN:

Yes.

34 MR. KELBERG:

How can you tell that?

35 DR. LAKSHMANAN:

Because this is the--the decedent is clothed and this is the first paragraph we take in the Coroner's office.

36 MR. KELBERG:

Doctor, does this photograph represent fairly and accurately the condition of Nicole Brown Simpson as you saw her initially on June 13th, the day earlier?

37 DR. LAKSHMANAN:

More or less.

38 MR. KELBERG:

What is the more and what is the less?

39 DR. LAKSHMANAN:

Because I saw her when she was lying on her back on the gurney when she was brought to the office. Right now she has been propped up on her side.

40 MR. KELBERG:

Doctor, even though I think you have a wireless microphone provided by the Court, you may be dropping your voice and it is still I think somewhat difficult to hear you.

41 DR. LAKSHMANAN:

Otherwise it is the same person and the dress is--the clothing is the same which I saw on June 13th.

42 MR. KELBERG:

On June 13th did you examine the back of the right hand to see whether or not there were any injuries, wounds or matters of consequence to you as a forensic pathologist?

43 DR. LAKSHMANAN:

I didn't do a detailed examination of the body. I only saw the major wound which is the neck which has been discussed, and my purpose was to just to get an idea about the two decedents who are brought to our office and also assign the criminalist to examine the remains and assign a medical examiner. I didn't examine in detail.

44 MR. KELBERG:

Doctor, the abrasion that you identify on the back of the right hand, again its located as seen in photograph B-1?

45 DR. LAKSHMANAN:

It is on the right index finger here, (Indicating).

46 MR. KELBERG:

Can you be any more specific where on the right index finger that abrasion--

47 DR. LAKSHMANAN:

It is on the base of the right index.

48 MR. KELBERG:

Doctor, if you will remember to wait until I finish my question, I will try and remember to wait until you finish your answer, and I have a feeling the court reporter will be very happy with both of us.

49 DR. LAKSHMANAN:

Yes.

50 MR. KELBERG:

I'm sorry, where on the index finger?

51 DR. LAKSHMANAN:

The base of the right index finger here, (Indicating).

52 MR. KELBERG:

When you say "Base," could you point on your own, showing it to the ladies and gentlemen of the jury, the area that you see in that photograph.

53 DR. LAKSHMANAN:

Right here, (Indicating).

54 MR. KELBERG:

Keep your voice up, doctor.

55 DR. LAKSHMANAN:

Somewhere here, pointing to my index finger here, (Indicating).

56 MR. KELBERG:

Your Honor, where the finger appears to join the hand.

57 THE COURT:

All right.

58 MR. KELBERG:

Now, doctor, that abrasion, are you able to tell from an examination of the photograph as to whether it was received before, at or around the time of or after death?

59 DR. LAKSHMANAN:

It was an antemortem abrasion.

60 MR. KELBERG:

How are you able to tell?

61 DR. LAKSHMANAN:

By the appearance and color, because I examined it with a magnifying glass.

62 MR. KELBERG:

By the way, you had a magnifying glass I think over the last couple of days that you have pulled out. Is a magnifying glass one of the tools of the trade of a forensic pathologist?

63 DR. LAKSHMANAN:

Yes.

64 MR. KELBERG:

How is it used by a forensic pathologist?

65 DR. LAKSHMANAN:

When you examine wounds, when you examine photographs, it is sometimes--not sometimes--it is a good habit to look at the wounds carefully. This way you see any minor--any minor irregularities on wound margins, and also if the wound is small, it helps you to understand the features better.

66 MR. KELBERG:

Doctor, from what you observed in that abrasion on photograph B-1, do you have any opinion as to the manner in which that abrasion was received by Nicole Brown Simpson?

67 DR. LAKSHMANAN:

It is a nonspecific blunt force trauma.

68 MR. KELBERG:

Which means what?

69 DR. LAKSHMANAN:

Well, it is a blunt force injury. It doesn't have any pattern, it doesn't have any specifics to it. It could occur in the same manner the abrasions to the left hand happened, contact with any rough surface.

70 MR. KELBERG:

Doctor, does that abrasion play any consequence in any of the big picture questions that you have been asked to evaluate and about which you have testified to during the course of your presentation here?

71 DR. LAKSHMANAN:

No.

72 MR. KELBERG:

Doctor, as long as we are on this photograph B-1--in fact, before I move to that other area, did Dr. Golden address that abrasion in any way in his original protocol?

73 DR. LAKSHMANAN:

Yes, he did.

74 MR. KELBERG:

Did he diagram it in any way?

75 DR. LAKSHMANAN:

Yes, he did.

76 MR. KELBERG:

Does it also get addressed in any addendum?

77 DR. LAKSHMANAN:

No.

78 MR. KELBERG:

Doctor, is there any--anything that you observed of significance between the description in the protocol and the diagram and the photograph showing the actual abrasion B-1?

79 DR. LAKSHMANAN:

The diagram accurately reflects the injury, but the description, it was erroneously described as ring finger.

80 MR. KELBERG:

Let me take the photo down and let's go and see the actual protocol and diagram. I don't think we are going to lean this up against here. This is one we have to move back, if we could ask counsel and the doctors to switch places with us.

81 (Brief pause.)
82 MR. KELBERG:

We are going to put up 0B and 4B from our group 349, your Honor.

83 THE COURT:

Noted. Thank you.

84 (Brief pause.)
85 MR. KELBERG:

Doctor, where in the protocol is there any reference to that particular abrasion on the index finger on the back of the right hand?

86 DR. LAKSHMANAN:

Page 7.

87 MR. KELBERG:

Doctor?

88 DR. LAKSHMANAN:

Right here on paragraph no. 4.

89 MR. KELBERG:

And that is a two-line paragraph and it talks about the dorsal surface. From our discussion, I guess on Tuesday, "Dorsal" is another word for the back of the right hand?

90 DR. LAKSHMANAN:

Yes.

91 MR. KELBERG:

And for the record, your Honor, with a red pen or marker I will outline that two-line paragraph and on the right margin I will write "B-1."

92 MR. KELBERG:

Doctor, is that an accurate description of the location of the abrasion that you also identified in the photograph B-1?

93 DR. LAKSHMANAN:

No.

94 MR. KELBERG:

What is wrong?

95 DR. LAKSHMANAN:

It says "Ring finger" but it should be the index finger.

96 MR. KELBERG:

And what I will do for the record then, your Honor, is with the blue marker I will circle the words "Ring finger" on the second line of the paragraph that is already circled in red on page 7 of the form 12.

97 MR. KELBERG:

Doctor, inviting your attention then to the board with the 23 form, do you see any entry there that goes along with the abrasion you identified from the photograph?

98 DR. LAKSHMANAN:

Yes. On the right upper quadrant in the back of the right hand you can see the abrasion to the right index finger.

99 MR. KELBERG:

Can you make out what is the writing from Dr. Golden regarding that?

100 DR. LAKSHMANAN:

It is "Reddish brown abrasion."

101 MR. KELBERG:

And where the doctor has circled in the schematic in the upper right quadrant of this form, I have circled it in red and with a line going to the side I will write "B-1"?

102 DR. LAKSHMANAN:

And that is 1/16 inch punctate abrasion.

103 MR. KELBERG:

I'm sorry, doctor?

104 DR. LAKSHMANAN:

1/16 inch punctate abrasion.

105 MR. KELBERG:

Is that an accurate description from your observation of the blunt force trauma abrasion on the index finger as seen in photograph B-1?

106 DR. LAKSHMANAN:

Yes.

107 MR. KELBERG:

Doctor, would you describe it as a mistake for Dr. Golden's autopsy report to reflect the ring finger as having this 1/16 inch punctate abrasion?

108 DR. LAKSHMANAN:

It is a mistake in his dictation, but in his documentation it is not a mistake because it has documented it properly.

KEY QUOTE
109 MR. KELBERG:

The mistake in the dictation, is that of any significance on any of these big ticket questions?

110 DR. LAKSHMANAN:

No.

111 MR. KELBERG:

Is there anything further about that particular finding?

112 DR. LAKSHMANAN:

No.

113 MR. KELBERG:

Incidentally, doctor, was there seen by you in the photograph any abrasion to the back of the right hand at the base of the ring finger as Dr. Golden's protocol actually says?

114 DR. LAKSHMANAN:

No.

115 MR. KELBERG:

And then I think we are done with these and we will go back to the photographs. I'm sorry, so we don't move counsel, there is something I can take care of while we have these. You will excuse me just one second, doctor.

116 (Brief pause.)
117 MR. KELBERG:

Doctor, I just wanted to briefly return to the entry that reflected B-24 and B-23, the sharp force injury that was to the head area of Nicole Brown Simpson, referring to the one that is seen in both of those photographs, B-24, B-23. Do you recall that?

118 DR. LAKSHMANAN:

Yes.

119 MR. KELBERG:

And you recall testifying that there had been an addendum addition made to reflect that Dr. Golden had described it in the diagram in one fashion?

120 DR. LAKSHMANAN:

Yes.

121 MR. KELBERG:

But the dictation had it in a different form?

122 DR. LAKSHMANAN:

Yes.

123 MR. KELBERG:

And the addendum then corrected it to reflect what the diagram actually showed; is that correct?

124 DR. LAKSHMANAN:

Yes.

125 MR. KELBERG:

Doctor, did you review testimony given by Dr. Golden at a preliminary hearing in this case in which he was asked questions about the dimensions of that particular injury?

126 DR. LAKSHMANAN:

Yes.

127 MR. KELBERG:

And inviting Court and counsel, if you all want to crowd around, I have it here, to page 70 of the preliminary hearing transcript, beginning at line 7 and going through line 18.

128 (Brief pause.)
129 (Discussion held off the record between Deputy District Attorney and Defense counsel.)
130 MR. KELBERG:

Doctor, did you review the following testimony: "Question: Now, Dr. Golden, there were two other wounds you observed with regard to Nicole Brown Simpson's scalp; is that correct? "Answer: Yes. There was a cutting wound or stab wound superficially right in the posterior parietal. In other words, lower down here on the right side of the lower scalp. This was a one and one-half inch in length superficial wound only going in 3/8 inch to one and one-half inches, a non-fatal wound, and there was a small amount of hemorrhage associated again that occurred before death. It was an antemortem injury." Doctor, did you review that testimony?

131 DR. LAKSHMANAN:

Yes, I did.

132 MR. KELBERG:

Is there an error in that testimony, in your opinion?

133 DR. LAKSHMANAN:

Yes.

134 MR. KELBERG:

What is the error?

135 DR. LAKSHMANAN:

He used the same information which was on the protocol when he gave the testimony.

136 MR. KELBERG:

And when you say "The same information," specifically which information, doctor?

137 DR. LAKSHMANAN:

Page 6, item 6.

138 MR. KELBERG:

The dimensions?

139 DR. LAKSHMANAN:

Yes.

140 MR. KELBERG:

And you have testified yesterday those dimensions were not the actual dimensions; is that correct?

141 DR. LAKSHMANAN:

Yes.

142 MR. KELBERG:

And I believe you then testified that the addendum report contains the actual correct dimensions with the change?

143 DR. LAKSHMANAN:

Yes.

144 MR. KELBERG:

Now, does this mistake in Dr. Golden's testimony affect in any way your ability to answer any of the big ticket questions that you've reviewed?

145 DR. LAKSHMANAN:

No.

146 MR. KELBERG:

Now I think we are back to the photos.

147 (Brief pause.)
148 THE COURT:

All right. You are going back to 355?

149 MR. KELBERG:

Correct, your Honor.

150 (Brief pause.)
151 MR. KELBERG:

One last question about the back of the right hand as shown in B-1. Doctor, is there any significance to you in the fact that you observed only one 1/16 inch punctate abrasion at the base of the index finger in the area of the back of the right hand?

152 DR. LAKSHMANAN:

Yes.

153 MR. KELBERG:

What is the significance of that observation?

154 DR. LAKSHMANAN:

The same reason I gave yesterday, that there seems to be a paucity of Defense wounds in the hands of Miss Nicole Brown Simpson which would again support my opinion that she was rapidly incapacitated or incapable of resistance when she was assaulted.

155 MR. KELBERG:

Now, doctor, I want to take your attention back to June 13th, the first day that you saw the body of Nicole Brown Simpson. Were you present for a discussion about whether or not something called a sexual assault kit should be taken in this particular case?

156 DR. LAKSHMANAN:

I didn't play a part in the discussion, but we didn't take a sexual assault kit.

157 MR. KELBERG:

Did you in fact give a concurrence to the determination not to take a sexual assault kit?

158 DR. LAKSHMANAN:

I didn't give a determination, but I didn't feel it was necessary.

159 MR. KELBERG:

And did you express that view?

160 DR. LAKSHMANAN:

I expressed that view later, but I didn't think it was indicated.

161 MR. KELBERG:

Doctor, you are going to have to keep your voice up.

162 DR. LAKSHMANAN:

I didn't think it was indicated.

163 MR. KELBERG:

Doctor, why did you not--first of all, let's define what is a sexual assault kit?

164 DR. LAKSHMANAN:

A sexual assault kit is the process by which you gain evidence from the genital area, oral area, rectal area, to document that there is any evidence of sexual assault which would indicate--you basically look for evidence of seminal material in these areas. Also look for evidence of injuries which could have been from a sexual act which resulted in injuries.

165 MR. KELBERG:

Why did you not feel that it was appropriate or necessary to take a sexual assault kit in the case of Nicole Brown Simpson?

166 DR. LAKSHMANAN:

She was fully clothed, the intimate apparel were in place.

167 MR. KELBERG:

The intimate apparel being what?

168 DR. LAKSHMANAN:

The panties. They were not in disarray. There were no evidence of any injuries to the thighs, which I could see, and basically the appearance did not indicate a necessity to do a sexual assault kit and I did call our criminalist and he also did not feel it was necessary to do, to take a sexual assault kit, because they didn't take any. And later during the autopsy Dr. Golden also did not see any injuries to the genital area and there was no indication for taking a sexual assault kit.

169 MR. SHAPIRO:

Move to strike what Dr. Golden saw or didn't see as hearsay.

170 THE COURT:

Sustained. That answer is stricken. The jury is to disregard that portion of the answer regarding what Dr. Golden said or saw.

171 MR. KELBERG:

Did Dr. Golden include in the autopsy protocol, the form 12, any material regarding an examination of the genital area of Nicole Brown Simpson?

172 DR. LAKSHMANAN:

Yes, he did.

173 MR. KELBERG:

And we will look at it as to the specifics, but if you could summarize what that information was, please tell us.

174 DR. LAKSHMANAN:

Basically there was no injuries observed.

175 MR. KELBERG:

Now, doctor, did you examine the panties for any evidence of tearing, cutting, anything whatsoever that would appear, other than the normal appearance of a pair of women's panties?

176 DR. LAKSHMANAN:

Yes, I did.

177 MR. KELBERG:

What, if anything, did you observe?

178 DR. LAKSHMANAN:

I examined--as I mentioned earlier, I had an opportunity to see the panties first in this appearance when it was on Miss Simpson and later on June 22nd when the evidence was viewed with the Defense pathologist, Dr. Wolf and Dr. Baden, who are here, and at that time ultraviolet light was also used, the panty was carefully examined. There was no evidence of any fluorescence which would indicate a seminal stain. There was a fluorescence from frayed material and that--and also there was no visible tears which could be seen, so basically the panty appeared intact except for some fraying and the fluorescence was not as we could seen from seminal stains.

179 MR. KELBERG:

When you saying "Fraying," doctor, what do you mean?

180 DR. LAKSHMANAN:

Fraying from fibers in the material because of wear and tear. You get some fibers of wear and tear and these fibers flourescence because of the material from which the panties are made from.

181 MR. KELBERG:

Doctor, in your experience as a forensic pathologist can you estimate for us how many cases of rape/murder you have seen?

182 DR. LAKSHMANAN:

A significant number of cases. Either I have seen them during my autopsies, I have done several dozen strangulation cases myself, plus I have supervised cases.

183 MR. KELBERG:

And when you say "Supervised," can you estimate approximately how many homicide cases were handled by your office last year that included evidence of the victim being sexually assaulted?

184 DR. LAKSHMANAN:

I don't have the numbers off the top of my head. I have to get the numbers for you.

185 MR. KELBERG:

Doctor, in your experience have you ever seen a situation where a woman was raped by the murderer, and to rape the woman her panties would have had to be removed so the penis could be inserted in the vagina and ejaculation could occur, and then before the murderer committed the murder the panties were put back on the victim and put back on in the appropriate position with no evidence of tearing or any disarray as you've described was the condition of Nicole Brown Simpson's panties?

186 MR. SHAPIRO:

Objection. That is an improper hypothetical.

187 THE COURT:

Overruled.

188 MR. KELBERG:

You may answer the question.

189 DR. LAKSHMANAN:

I have not seen any cases like that. The cases where the clothing has been put back on, they are--at least the cases I have seen they have been put back on improperly and there is always evidence of--evidence of assault which you can see.

KEY QUOTE
190 MR. KELBERG:

What do you mean by "Evidence of assault that you can see"?

191 DR. LAKSHMANAN:

You will see blood staining and you will--because of the trauma involved and also the zipper--the pant would have been put back in a wrong fashion, the zipper in the back instead of being in the front, the panty could have been put back on upside down. So what I'm saying is I have not seen a case where the assault has taken place, the person has been murdered and where the clothing is in the condition where we see Miss Nicole Brown Simpson's clothing to have been when we see these photographs.

192 MR. KELBERG:

Would your answer be the same if the sexual assault were changed from one of rape involving penetration of the vaginal area to one of sodomy for penetration of the anal area?

193 DR. LAKSHMANAN:

Well, the same--actually in sodomy you would expect to see definite injuries because you will see evidence of anal lacerations which were not described. There was no--you will find evidence of bleeding and that is also not seen.

194 MR. KELBERG:

Doctor, in your opinion is there any basis, from all of the material you have reviewed in this case, now taking you beyond June 13th and to today's date, which would cause you to have changed your opinion that it would have been appropriate to have taken a sexual assault kit in this case?

195 DR. LAKSHMANAN:

No. I still feel it is not indicated and I would not have recommended it.

196 MR. KELBERG:

Doctor, does--may I have just a moment, your Honor?

197 THE COURT:

Certainly.

198 (Brief pause.)
199 MR. KELBERG:

Doctor, is there a manual that is put out by your office to be used by your investigators called a "Physical evidence policy and procedures manual."

200 DR. LAKSHMANAN:

Yes, there is.

201 MR. KELBERG:

And basically is the last manual, full manual that was published, published in August of 1987?

202 DR. LAKSHMANAN:

Yes.

203 MR. KELBERG:

Who is--if there is one or if there are more, who are the authors of this manual?

204 DR. LAKSHMANAN:

The procedures for physical evidence collection started somewhere in the early eighties and I think the manual was compiled by one of our senior criminalists at that time under the direction of the chief of laboratories at that time. And I think the manual came in place sometime in `88 I think, in `88--`87 or `88, the first date--it was--

205 MR. KELBERG:

You have to keep your voice up, doctor.

206 DR. LAKSHMANAN:

It was first issued on February 4th, 1988.

207 MR. KELBERG:

Doctor, I want to invite your attention--I can show Court and counsel--to page 8.1--I shouldn't have given the manual over to you, doctor. I lost my place. Hang on one second if you would, please.

208 (Brief pause.)
209 MR. KELBERG:

8.13.1 on a page starting with the heading "Sexual assault evidence." Is this in fact what your manual indicates is to be a process or procedure followed in your office under "Definition: Evidence collected in the genitals, body orifices and other body surfaces for the purpose of determining if a sexual act may have occurred and who may have participated in that act," then a heading called "Collection, packaging and submission guidelines": "Evaluation for sexual assault evidence shall be made whenever the investigation indicates that a sexual act, whether non-consensual or consensual, may have occurred in association with a death by other than natural causes, whenever identification of the last sexual partner may be of value to the investigation, whenever elimination of sexual activity may be of value to the investigation or when a person involved in the investigation requests that such evaluation be made.

"It shall be the responsibility of the assigned Coroner's investigator and supervising investigator on duty to determine when sexual assault evidence evaluation is required and to notify the criminalistics laboratory staff as soon as possible. The assigned Deputy Medical Examiner may also request sexual assault evidence evaluation if the need has not been previously recognized.

"The body shall not be processed in any manner that might alter or destroy the sexual assault evidence until examined and released by the assigned criminalist. If the decedent has died in a hospital and the hospital or police record indicate that sexual assault evidence was collected antemortem, a criminalist shall be requested to verify the collection and determine if additional evidence collection is indicated.

"Evaluation for and collection of sexual assault evidence shall be made by a Coroner's criminalist. The assigned criminalist shall determine what evidence to collect based upon evaluation of the reported circumstances, the decedent's sex and body condition and personal observations. The prepared evidence kit materials shall be used for sexual assault evidence collection whenever feasible." And then it goes on as to the forms to be filled out and the processing. Is that correct, doctor?

210 DR. LAKSHMANAN:

Yes.

211 MR. KELBERG:

And was that in fact a policy in your office in June of 1994?

212 DR. LAKSHMANAN:

Yes.

213 MR. KELBERG:

Did you, in your opinion, follow that procedure in making a determination that a sexual assault kit was not needed in this particular case?

214 DR. LAKSHMANAN:

Yes.

215 MR. KELBERG:

Doctor, in your opinion does a sexual assault kit assist you, as a forensic pathologist, in establishing a range for time of death that would be between nine o'clock in the evening and 12:13 in the morning, nine o'clock June 12th, 1994, and 12:13 in the morning, June 13th, 1994, when Officer Riske first found the bodies?

216 DR. LAKSHMANAN:

No.

217 MR. KELBERG:

Why not?

218 DR. LAKSHMANAN:

Because just by finding evidence of seminal material or sperms it doesn't necessarily mean that they died between that time.

219 MR. KELBERG:

In fact, is it a matter that is handled in a standard forensic pathology text regarding aging of death based upon the presence of something called motile sperm?

220 DR. LAKSHMANAN:

There are two issues which are done. One is motile sperms.

221 MR. KELBERG:

First of all, what is motile sperm?

222 DR. LAKSHMANAN:

When you get the vaginal aspirate you look under the microscope to see whether there is motility to the sperms because sperm are motile.

223 MR. KELBERG:

What is motile, motility?

224 DR. LAKSHMANAN:

"Motility" means the sperm will be able to move around, even--are able to move around and that is how after an intercourse takes place the sperm are able to reach the fallopian tubes and fertilize the ova, so that is a normal process which the sperms are capable of physiologically.

225 MR. KELBERG:

And even after a person dies, if you take a sample from the vaginal area and you are looking for sperm, you can microscopically see sperm moving around?

226 DR. LAKSHMANAN:

Yes.

227 MR. KELBERG:

What, if any, significance does the presence of moving term have on the issue of when the ejaculation occurred?

228 DR. LAKSHMANAN:

It would--you can see motile sperms, the average is less than--up to four hours, but people have seen motile sperms up to sixty hours, but generally the average is four hours.

229 MR. KELBERG:

So four hours before time of death you can still see motile sperm?

230 DR. LAKSHMANAN:

No, no, no.

231 MR. KELBERG:

I'm sorry. If an ejaculation, four hours before death and a sample taken after death, you may still see motile sperm on average?

232 DR. LAKSHMANAN:

No. The motility of the sperm is for four hours and that could go on up to sixty hours and so it has nothing to do with the death process itself. It is the sperm itself. It is a different--

233 MR. KELBERG:

I understand, but if we put in context of a person dies sometime after there has been ejaculation and you are looking at a slide to look for moving sperm, would it be accurate to say that if you see moving sperm it means that on average that sperm could have been placed inside the vaginal tract as much as four hours before death?

234 DR. LAKSHMANAN:

That could be one conclusion, depending on that the sample being collected immediately after death and you see motile sperms, then that could be one conclusion. But I said there is variability to this and it can go on up to sixty hours they are seeing motile sperms.

235 MR. KELBERG:

So if you were trying to evaluate whether Nicole Brown Simpson died between 10:15 in the evening on June 12th and eleven o'clock in the evening on June 12th, would the presence--just assuming hypothetically there had ever been motile sperm collected and seen--would the presence of motile sperm have permitted you to make that evaluation?

236 DR. LAKSHMANAN:

No, you cannot estimate a time of death from that, especially for such a narrow time frame, and even if it is not a narrow time frame I would not estimate a time of death from presence of sperms because you have so much variability in it.

KEY QUOTE
237 MR. KELBERG:

Doctor, is there another aspect of seminal fluid which may have some value in giving a range for when the ejaculation occurred versus when the sample was obtained?

238 DR. LAKSHMANAN:

Yes. There is another test which you can do chemically, it is for acid phosphatase, it is an enzyme which is present in your prostatic secretions, and then you ejaculate. Prostatic secretions are mixed with your ejaculation, and if you calculate the amount of acid phosphatase and they are measured in what is called Bodansky, B-O-D-A-N-S-K-Y, units, and if you have a level between 10 and 30, it would indicate that the intercourse took place before--shortly before the specimen was collected.

239 MR. KELBERG:

What is a short time when you are using these units?

240 DR. LAKSHMANAN:

That is not defined because you can find up to several hours, but usually you don't find it more than 10 to 24 hours after that. I mean, you don't get a high level. You need to get a level of 10 to 30.

241 MR. KELBERG:

Are there values actually given in a forensic pathology text, such as a Spitz and Fisher edition that we used with a couple of photographs earlier in your testimony?

242 DR. LAKSHMANAN:

Yes.

243 MR. KELBERG:

Doctor, do you recall off the top of your head what those values are?

244 DR. LAKSHMANAN:

10 to 30 and I think--

245 MR. KELBERG:

10 to 30?

246 DR. LAKSHMANAN:

--Bodansky units.

247 MR. KELBERG:

Okay. And translating into a time frame of--

248 DR. LAKSHMANAN:

Up to--it favors that the intercourse took place just before you--you obtained the specimens.

249 MR. KELBERG:

What is "Just before" defined in the text?

250 DR. LAKSHMANAN:

If somebody had coitus just before that.

251 MR. KELBERG:

May I have just a moment, your Honor?

252 (Brief pause.)
253 MR. KELBERG:

By the way, doctor, if there is motile sperm, is there something that is non-moving sperm that can be seen?

254 DR. LAKSHMANAN:

Yes, because what happens is the motility is due to the tail of the sperm and you can lose the tail after certain time and you only see the heads of the sperms, and that you can see for a longer time because they can be there in the vaginal area.

255 MR. KELBERG:

Doctor, what is the time frame during which you can see the presence of non-moving sperm, that is, time of ejaculation to time of sample collection?

256 DR. LAKSHMANAN:

The--the non-moving sperm depend on the state of decomposition of the body. If the body is not decomposed, they have found sperms in frozen bodies even after a week. It depends on whether the decomposition is postmortem deterioration of the body. If that take place also, these tissues can deteriorate.

257 MR. KELBERG:

Doctor, inviting your attention, if I could, to pages 790 and 791--

258 DR. LAKSHMANAN:

Yes.

259 MR. KELBERG:

--of Spitz and Fisher's third edition, have you reviewed that material?

260 DR. LAKSHMANAN:

Yes, I have.

261 MR. KELBERG:

Has that material been relied upon in any way by you in forming opinions regarding the time frame regarding the acid phosphatase determination?

262 DR. LAKSHMANAN:

Yes.

263 MR. KELBERG:

And I don't know if you want to take a look. Does this refresh your memory with respect to any specific--

264 DR. LAKSHMANAN:

It says: "Values ranging from 10 to 30 Bodansky units suggest rape occurred shortly before death rather than intercourse five to ten hours earlier."

265 MR. KELBERG:

And other than that does it define what "Shortly before" is?

266 DR. LAKSHMANAN:

No.

267 MR. KELBERG:

And is there any literature of which you are aware which is a scientific study of the relationship between Bodansky units of acid phosphatase levels and confirmed times between ejaculation and time of death and sample collection?

268 DR. LAKSHMANAN:

Not in--not reviewed other literature.

269 MR. KELBERG:

Or are you aware of any such?

270 DR. LAKSHMANAN:

There must be information in the literature which I have not reviewed.

271 MR. KELBERG:

When you say "There must be," are you aware of any?

272 DR. LAKSHMANAN:

No.

273 MR. KELBERG:

Doctor, taking all this into account, in your opinion would a sexual assault kit from Nicole Brown Simpson have been of any value to you as a forensic pathologist in either identifying the killer or killers of Nicole Brown Simpson?

274 (No audible response.)
275 MR. KELBERG:

Multiple question. Any value to you in identifying the killer or killers?

276 DR. LAKSHMANAN:

No.

277 MR. KELBERG:

And in identifying the specific time of death?

278 DR. LAKSHMANAN:

No.

279 MR. KELBERG:

Why not as to each?

280 DR. LAKSHMANAN:

Because--just because there was evidence of--let's assume there was consensual sexual intercourse because we don't have evidence of assault here, even then it doesn't mean that person is the--is the person who did these murders. Now, coming to time of death, I have already mentioned that there is--this time ranges. When we discussed for the sperm and acid phosphatase, you cannot estimate a time of death from that.

281 MR. KELBERG:

And doctor, have you taken into account in any way nonmedical observations such as evidence that may have been presented in this case regarding telephone records and telephone calls between Nicole Brown Simpson and persons such as her mother?

282 DR. LAKSHMANAN:

Yes.

283 MR. KELBERG:

Mezzaluna restaurant?

284 DR. LAKSHMANAN:

Yes.

285 MR. KELBERG:

You have reviewed that material?

286 DR. LAKSHMANAN:

Not reviewed. I am aware of the material.

287 MR. KELBERG:

And with respect to subsequent contact between Nicole Brown Simpson and the Mezzaluna restaurant?

288 DR. LAKSHMANAN:

I am aware of that also.

289 MR. KELBERG:

Doctor, is there anything of which you are aware which leads you to believe, from a forensic pathologist standpoint, that there was a sexual assault of this woman?

290 DR. LAKSHMANAN:

No.

291 MR. KELBERG:

Now, is there anything further with respect to photograph B-1 that has not been covered?

292 DR. LAKSHMANAN:

There is also blood staining of the left side of the face which would go along with the blood loss from her neck wounds which I discussed earlier.

293 MR. KELBERG:

And that is all fully consistent with what you have seen in the crime scene photographs?

294 DR. LAKSHMANAN:

Yes. I just have a sip of water.

295 MR. KELBERG:

Okay.

296 (Brief pause.)
297 MR. KELBERG:

Anything further on photograph B-1?

298 DR. LAKSHMANAN:

No.

299 MR. KELBERG:

May I have just a moment, your Honor?

300 THE COURT:

Certainly.

301 (Discussion held off the record between the Deputy District Attorneys.)
302 MR. KELBERG:

Doctor, let me invite your attention now back to a photo that you briefly used in conjunction with photograph B-31 and that is photograph B-12. Do you see that?

303 DR. LAKSHMANAN:

Yes.

304 MR. KELBERG:

What are we looking at in that particular photograph?

305 DR. LAKSHMANAN:

We are seeing four small abrasions arranged in the right shoulder region. Of course you are still seeing the cut wound which I described in the right ring finger. In addition, we have a small scar in the right posterior shoulder area. We also have a smaller abrasion, reddish brown in color, adjacent to the scar in the back of the shoulder, and I have the measurements.

306 MR. KELBERG:

Could you get your wound chart which is our exhibit I believe 350?

307 DR. LAKSHMANAN:

Yes. B-12 the measurements are--

308 MR. KELBERG:

Keep your voice up remember, doctor.

309 DR. LAKSHMANAN:

The abrasion which is next to the scar here is 1/8 of an inch and the scar itself is 3/8 of an inch by 3/16 of an inch. This is all my measurement from the one-as-to-one photographs. The four pink brown abrasions on the shoulder range from quarter inch by 1/8 inch, half an inch by 1/8 inch, 1/8 inch and quarter inch by 1/16 inch, so those are the measurements and they are--have been described.

310 MR. KELBERG:

When you say they have been described, have all of the injuries that you have described now in B-12--we have already covered the aspect of the right hand--have all of these injuries been described by Dr. Golden in his original autopsy protocol?

311 DR. LAKSHMANAN:

Yes, but--yes.

312 MR. KELBERG:

What is the "But"?

313 DR. LAKSHMANAN:

He has described them as postmortem excoriations.

314 MR. KELBERG:

We are going to get to the board to show that specifically, but is a term "Postmortem excoriation" of significance to you as a forensic pathologist?

315 DR. LAKSHMANAN:

Yes.

316 MR. KELBERG:

What is that?

317 DR. LAKSHMANAN:

It would indicate that he felt it was a postmortem injury.

318 MR. KELBERG:

What is an excoriation?

319 DR. LAKSHMANAN:

Excoriations are the term which you can use for an abrasion. Basically the skin surface has been peeled off.

320 MR. KELBERG:

In your opinion is it a postmortem excoriation?

321 DR. LAKSHMANAN:

No.

322 MR. KELBERG:

Why not?

323 DR. LAKSHMANAN:

Because the--the appearance of the injury looks perimortem in the shoulder area, which is pinkish brown, and rather antemortem, and the one on the back of the shoulder blade is antemortem also.

324 MR. KELBERG:

Doctor, from the appearance of these abrasions, do you have an opinion as to the manner in which they were inflicted?

325 DR. LAKSHMANAN:

They are nonspecific blunt force injury. They don't have any pattern to them and they are not fatal.

326 MR. KELBERG:

Are they of any significance in your opinion as to any of the big ticket issues that you have reviewed in this case?

327 DR. LAKSHMANAN:

No.

328 MR. KELBERG:

Can you determine how long Nicole Brown Simpson's heart was beating after she received those abrasions?

329 DR. LAKSHMANAN:

Within a few minutes or even less than a minute.

330 MR. KELBERG:

And is there any way to be definite with respect to that timing from what you see in the photograph B-12?

331 DR. LAKSHMANAN:

No.

332 MR. KELBERG:

Before we move to the board, doctor, is there anything else seen in this photograph that you wish to discuss?

333 DR. LAKSHMANAN:

No.

334 MR. KELBERG:

Perhaps we can all switch positions and we will move this board.

335 (Brief pause.)
336 MR. KELBERG:

And your Honor, we are putting up 0B and 2B from our 349 collection.

337 THE COURT:

Thank you.

338 (Brief pause.)
339 MR. KELBERG:

Doctor, first of all, can you tell us where in the protocol there is any entry reflecting any of these abrasions that you have described from photograph B-12?

340 DR. LAKSHMANAN:

Page 3.

341 MR. KELBERG:

Please show us where there is such an entry.

342 DR. LAKSHMANAN:

(Indicating). Paragraph 1 line 4, "Examination of the posterior surface of the trunk."

343 MR. KELBERG:

How far does that run, doctor, to cover what we are looking at?

344 DR. LAKSHMANAN:

Up to line 8.

345 MR. KELBERG:

Your Honor, where Dr. Lakshmanan has outlined with the pointer, I'm going to take a red marker and enclose that area and I will write at the side "B-12."

346 MR. KELBERG:

Doctor, excuse me. Dr. Golden has included the terms, "Compatible with ant to insect bites." As a forensic pathologist does the term "Excoriation" have some correlation with being caused by ant or insect bites?

347 DR. LAKSHMANAN:

Well, that is a term which is used to--by some physicians to describe if they do see ant and insect bites.

348 MR. KELBERG:

Doctor, in your opinion are those abrasions which you have described as antemortem, rather than postmortem as described by Dr. Golden on page 3, due to ant or insect bites?

349 DR. LAKSHMANAN:

No.

350 MR. KELBERG:

Why not?

351 DR. LAKSHMANAN:

Because the appearance have more reddish brown or pinkish brown in color which would indicate that they happened during life and I don't think they are postmortem excoriations.

352 MR. KELBERG:

Doctor, did you also examine, from the crime scene photographs, our board 355, the area of Nicole Brown Simpson's back which in the photograph B-12 contains these abrasions?

353 DR. LAKSHMANAN:

Yes, I did.

354 MR. KELBERG:

What did you examine that area of the back for with respect to this issue of ant or insect bites, if you did that examination?

355 DR. LAKSHMANAN:

I did the examination to see whether there was any ant activity on the body, no. 1. No. 2, also confirmed the appearance of the wound which was the same appearance as I see it in these photographs. You can see it in the right shoulder area very well.

356 MR. KELBERG:

Doctor, in your experience as a forensic pathologist, with respect to ant or insect bites, is it your experience that ants or insects operate individually?

357 DR. LAKSHMANAN:

No.

358 MR. KELBERG:

How do they operate?

359 DR. LAKSHMANAN:

In large groups.

360 MR. KELBERG:

And do you--do you expect to see, if there is a photograph at the crime scene of the body at a time when ants are inflicting this kind of postmortem excoriation, to see evidence of that?

361 DR. LAKSHMANAN:

You would see evidence of ant activity if it was present.

362 MR. KELBERG:

Why don't we finish with the diagram and then we will get to the photograph by moving it out when we move the diagram down. This diagram form 20, does it contain any reference to this same aspect that is covered in page 3 or on page 3, the excoriations?

363 DR. LAKSHMANAN:

Yes. Right in the right posterior shoulder area here, (Indicating).

364 MR. KELBERG:

And there is some entry along the right side of what appear to be several diagonal lines?

365 DR. LAKSHMANAN:

Yes. It shows the--that there are post--

366 MR. KELBERG:

Keep your--

367 DR. LAKSHMANAN:

That there are abrasions present and it says "Appears postmortem."

368 MR. KELBERG:

Where you have outlined that, doctor, with your pointer, I will circle in red and write "B-12" on our board form 20.

369 MR. KELBERG:

Now, doctor in the photograph I belief you identified areas beyond what is shown in this diagram as an area of abrasions, antemortem abrasions; is that correct?

370 DR. LAKSHMANAN:

Yes.

371 MR. KELBERG:

Is that other area or are those other areas shown on figure 20?

372 DR. LAKSHMANAN:

It is a small abrasion right here, (Indicating), in the shoulder blade area, which was not diagrammed.

373 MR. KELBERG:

When you say "Here," let me just circle that--is this the area, doctor, (Indicating)?

374 DR. LAKSHMANAN:

Yes. Yes. That's fine.

375 MR. KELBERG:

It is not fine, if it is not accurate--

376 DR. LAKSHMANAN:

Just a dot of an abrasion; it is not a big one.

377 MR. KELBERG:

I will circle the area in general and I will write "B-12" in blue on form 20.

378 DR. LAKSHMANAN:

Yes.

379 MR. KELBERG:

Is that at least circling the area?

380 DR. LAKSHMANAN:

Yes.

381 MR. KELBERG:

Now, doctor, no. 1, is this a mistake in your judgment for Dr. Golden to have determined that this was a postmortem excoriation or abrasion?

382 DR. LAKSHMANAN:

It is a mistake to call it postmortem when it is antemortem.

383 MR. KELBERG:

Is it a mistake to attribute the source of the abrasion or excoriation to ant or insect bites?

384 DR. LAKSHMANAN:

Yes.

385 MR. KELBERG:

Is it a mistake not to have fully diagrammed, on a form such as 20, the totality of the abrasions seen in photograph B-12?

386 DR. LAKSHMANAN:

Yes.

387 MR. KELBERG:

Individually and collectively, doctor, do any of these mistakes by Dr. Golden have significance on any of the big ticket questions?

388 DR. LAKSHMANAN:

No.

389 MR. KELBERG:

Why not?

390 DR. LAKSHMANAN:

Because these are very small abrasions and sometimes you can fail to document them when you have a case with so many injuries to document, but they have no significance to the cause of death and manner of death or the--to explain further detail as to the weapon or bleeding patterns, et cetera.

391 MR. KELBERG:

Is there anything further for photograph B-12 that we need diagram 20?

392 DR. LAKSHMANAN:

No.

393 MR. KELBERG:

I'm going to take down diagram 20 and I'm briefly going to pull out exhibit 355.

394 THE COURT:

That is 355?

395 MR. KELBERG:

I believe so. I can't see. The exhibit number is on the front.

396 THE COURT:

Lower right-hand--

397 MR. KELBERG:

It is either 54 or 55. It is 354 Mr. Lynch tells me.

398 THE COURT:

354.

399 (Brief pause.)
400 MR. KELBERG:

This is going to be up so briefly we are going to have counsel moving very quickly back.

401 MR. KELBERG:

But doctor, do you see in this photograph, CS-11, the area of the back which is seen also in B-12 and which contains the abrasions that you have identified?

402 DR. LAKSHMANAN:

This photograph doesn't show it very clearly, but this is the area where we are looking at in that photograph. I have seen other photographs where there is better outline.

403 MR. KELBERG:

Let's try CS-12 on the same exhibit.

404 DR. LAKSHMANAN:

This is the area here, (Indicating). I have seen a better picture than this.

405 MR. KELBERG:

All right. A photograph that we are not using; is that correct?

406 DR. LAKSHMANAN:

Yes.

407 MR. KELBERG:

Doctor, in looking at these two photographs, CS-11 and CS-12, and the photograph that you have reviewed, do you see any evidence of ant or insect activity on the back of Nicole Brown Simpson?

408 DR. LAKSHMANAN:

Not on the photographs.

409 MR. KELBERG:

Is that of significance then in evaluating whether in fact the source of those abrasions is due to ant or insect bites, as indicated by Dr. Golden in his protocol?

410 DR. LAKSHMANAN:

Yes. I'm sorry.

411 MR. KELBERG:

Is it of significance to you?

412 DR. LAKSHMANAN:

Could you repeat the question? I'm sorry, I didn't catch it.

413 MR. KELBERG:

All right. Let me slow it down. Is the absence of evidence of ant or insect activity in the area of the back shown in the three photos, the two here and the others that you reviewed, of significance to you in assessing the source of those abrasions seen on the back in photograph B-12?

414 DR. LAKSHMANAN:

Yes.

415 MR. KELBERG:

In what way?

416 DR. LAKSHMANAN:

The absence of it would indicate to me that there is not--not--there is no ant activity at the time these photographs were taken.

417 MR. KELBERG:

And if there had been a source for these abrasions from ant activity, would you expect them to be present in these three photographs?

418 DR. LAKSHMANAN:

I would expect them to be present.

419 MR. KELBERG:

All right. Why don't we take this down. We are going to be right back to that page 3 of the protocol, your Honor.

420 (Brief pause.)
421 THE COURT:

Mr. Lynch, you can leave that one there.

422 MR. LYNCH:

Thank you.

423 MR. KELBERG:

Doctor, because this page has a reference, I want to go back again to the B-1 photograph and the issue of a sexual assault kit and invite your attention to the first--I'm sorry--second full sentence on page 3, the sentence that is immediately above the outlined box for B-12. Is that one of the entries that you reviewed in Dr. Golden's protocol concerning the issue of trauma to the genital area of Nicole Brown Simpson?

424 DR. LAKSHMANAN:

Yes.

425 MR. KELBERG:

Would you read to us, please what would is said in that sentence?

426 DR. LAKSHMANAN:

"The genitals are those of an adult female with no gross evidence of injury."

427 MR. KELBERG:

I will outline that in blue on the posterboard size and write "B-1" on the right hand margin.

428 MR. KELBERG:

Now, doctor is there a specific area of the protocol that discusses an examination of the genital area of Nicole Brown Simpson?

429 DR. LAKSHMANAN:

It should be in the latter part of the protocol under genital--urogenital system.

430 (Brief pause.)
431 DR. LAKSHMANAN:

Page 12, page 12 of the protocol.

432 MR. KELBERG:

And doctor, there is an entry "Genital system," parenthesis, "Female," close parenthesis. What does this refer to?

433 DR. LAKSHMANAN:

This refers to the internal examination of the genitalia of Miss Brown Simpson.

434 MR. KELBERG:

Let me outline that in red, that block of sentences, and I will write out the side "B-1," right side "B-1."

435 MR. KELBERG:

Doctor, can you translate this into lay person's terms, what these observations mean?

436 DR. LAKSHMANAN:

The information is that: "The uterus, tubes, and adnexa are anatomic." That means the internal genitalia which are the uterus, fallopian tubes and the ovaries are normal, normal position and normal appearance. "The cut surface of the uterus shows no lesions and a thin light brown endometrium."

437 MR. KELBERG:

First of all, what is a lesion?

438 DR. LAKSHMANAN:

Le--

439 MR. KELBERG:

Lesion. What is a lesion?

440 DR. LAKSHMANAN:

Lesion is looking for your abnormal pathology because you can have--in the uterus you can have, common thing is fibroid, you can have a fibroid uterus. That is not present. There would be what's called adenomyosis which is presence of endometrial tissue in the muscle of the uterus. That is not present. You can see it grossly, so that is what is meant by "Lesion" when you are looking at the uterus and you are looking for vast abnormal pathology and that is not there. And the endometrium is thin light brown. That means the person--reflects the description of the endometrium which it is in the stage of the endometrium in what is called the stage after--grossly it would mean that it is not in the secretor stage or the proliferative stage.

441 MR. KELBERG:

I--let me shortcut this by asking is everything normal with respect to that aspect of the internal examination?

442 DR. LAKSHMANAN:

Yes, yes.

443 MR. KELBERG:

All right. How about the last sentence?

444 DR. LAKSHMANAN:

"The vagina has its normal mucosal surface and no lesions or injuries are evident," and it is self-explanatory. There was no pathology seen and there was no injury in the vagina present.

445 MR. KELBERG:

Doctor, in your experience in examining cases of rape/murder, does one normally expect to see some kind of injury or lesion in the vaginal area?

446 DR. LAKSHMANAN:

You may see in some cases.

447 MR. KELBERG:

And in some you may not?

448 DR. LAKSHMANAN:

Yes.

449 MR. KELBERG:

Anything further about this particular entry?

450 DR. LAKSHMANAN:

Nothing else to--which I need to discuss.

451 MR. KELBERG:

All right. Let's take this one down.

452 (Brief pause.)
453 THE COURT:

Is this 355?

454 MR. KELBERG:

Yes, your Honor. We are back to that.

455 MR. KELBERG:

Now, doctor is there anything further to discuss on B-12?

456 DR. LAKSHMANAN:

No.

457 MR. KELBERG:

Let's move then, if we could, please, to B-11, the photograph which is immediately to the left. What are we looking at in that photograph, doctor?

458 DR. LAKSHMANAN:

In the back of the right side of the neck you see a u-shaped abrasion which is more well-defined in its lower--in one limb of the u, which is the lower part which is on the lower part of the u, the u being horizontally oriented. And this abrasion, which you see, is also interrupted. That means you have space of intact skin between the points of abrasion.

459 MR. KELBERG:

Does the interruption of an abrasion have any significance to you in evaluating how an abrasion such as this comes to be received?

460 DR. LAKSHMANAN:

That is the--yes. Basically the object or surface which caused this injury was coming in intermittent contact with the skin's surface. That would be one interpretation.

461 MR. KELBERG:

Can you explain what you mean by "Intermittent contact"?

462 DR. LAKSHMANAN:

Umm, if you go back to B-5, I think you can--

463 MR. KELBERG:

You have to keep your voice up, remember, doctor?

464 DR. LAKSHMANAN:

B-5 doesn't show. The clothing has been taken off. If you look at the dress in B-1, there is a neck strap here, (Indicating), which holds up and that strap had a hook--there is a hook to that strap in the back, and one possible source for this abrasion could be from that strap during the--at some point when Miss Simpson was--

465 MR. KELBERG:

I just wanted you to have an opportunity, doctor--I won't put the board up. The crime scene photos, 354, does that show what you are attempting to--

466 DR. LAKSHMANAN:

Yes. It shows it in b--CS-12.

467 MR. KELBERG:

Let me put up exhibit 354 then and ask you to please show us what it is you are trying to use as an example of an interrupted abrasion source?

468 DR. LAKSHMANAN:

This strap you can see it here just below her hairline in the back of the neck, it is a thin strap which is part of this dress.

469 MR. KELBERG:

And how does that come into play if--assuming that is the source?

470 DR. LAKSHMANAN:

If--

471 MR. KELBERG:

--to create this interrupted abrasion that you have seen?

472 DR. LAKSHMANAN:

At some point the strap would have been pulled backward to rub against the skin's surface there and could it have been one possible source for it.

473 MR. KELBERG:

Doctor, are you able to determine whether this abrasion was received before death as an antemortem abrasion?

474 DR. LAKSHMANAN:

Yes, it is an antemortem abrasion.

475 MR. KELBERG:

How are you able to tell that?

476 DR. LAKSHMANAN:

The appearance, the reddish brown color and the features I described.

477 MR. KELBERG:

Does it have any significance, in your opinion, to any of the big ticket questions that you have talked about and reviewed for this case?

478 DR. LAKSHMANAN:

No.

479 MR. KELBERG:

Why not?

480 DR. LAKSHMANAN:

Because it doesn't play a part in the cause of death or manner of death or the other issues I discussed already; bleeding patterns, evaluation of sharp force injury. It is a nonspecific--I mean it is a nonspecific blunt force injury.

481 MR. KELBERG:

Did Dr. Golden address this in his protocol?

482 DR. LAKSHMANAN:

He did, but he didn't describe it as u-shaped, but he has addressed it.

483 MR. KELBERG:

Would you have expected him to describe it as u-shaped based upon what you see in the photograph?

484 DR. LAKSHMANAN:

Yes, but the other limb of the u is very faint, so if it is not looked at closely, you may interpret it as a linear abrasion rather than u-shaped.

485 MR. KELBERG:

A linear abrasion?

486 DR. LAKSHMANAN:

Yes.

487 MR. KELBERG:

Meaning?

488 DR. LAKSHMANAN:

Straight, because you don't see the other limb as clearly as the other--the lower part of the u.

489 MR. KELBERG:

Did Dr. Golden diagram this particular abrasion?

490 DR. LAKSHMANAN:

He has.

491 MR. KELBERG:

And is it addressed in any way in an addenda?

492 DR. LAKSHMANAN:

No.

493 MR. KELBERG:

Is there anything, before we move back then to see the protocol and the addendum--I'm sorry, protocol and diagram--about photograph B-11?

494 DR. LAKSHMANAN:

Nothing else.

495 MR. KELBERG:

Did you ask someone who acts as a consultant to your office to look at this particular abrasion for an interpretation as to possible bite mark?

496 DR. LAKSHMANAN:

Yes, I did.

497 MR. KELBERG:

Who did you ask to look at this?

498 DR. LAKSHMANAN:

Dr. Vale is our forensic odontologist.

499 MR. KELBERG:

Vale, V-A-L-E?

500 DR. LAKSHMANAN:

Yes, Gerald Vale.

501 MR. KELBERG:

And what is a forensic odontologist?

502 DR. LAKSHMANAN:

He is--a forensic odontologist is a dentist who specializes in forensic work and their role would be in identification of decedents by comparing the dental remains. The other function is they help in bite mark evaluations.

503 MR. KELBERG:

What is bite mark?

504 DR. LAKSHMANAN:

Bite mark is the mark left on a body surface by the bite of another person, and what the forensic odontologist would do would examine the mark, take what is called an exemplar of the mark using certain material and also have that available in case they have a potential suspect to compare, they will examine the suspect's teeth and see whether there are features which match with the mark which is seen on the body.

505 MR. KELBERG:

In this particular case was Dr. Vale asked to evaluate this abrasion as a possible bite mark after the autopsy had been completed?

506 DR. LAKSHMANAN:

Not after the autopsy was completed. It was only later when the body had already been released and much later, actually in September sometime in `94.

507 MR. KELBERG:

When I said "After," I meant literally after, at any time after, but it was after; is that correct?

508 DR. LAKSHMANAN:

Yes, yes.

509 MR. KELBERG:

And in essence the body was not available for Dr. Vale to personally examine?

510 DR. LAKSHMANAN:

That is correct.

511 MR. KELBERG:

But was Dr. Vale provided both with the type of photograph we are looking at in B-11 as well as the life-size photographs that you have reviewed of the same area for evaluating this issue?

512 MR. SHAPIRO:

Objection, no foundation.

513 THE COURT:

Overruled.

514 MR. KELBERG:

You may answer the question.

515 DR. LAKSHMANAN:

Yes. He reviewed the original photographs and then he requested one-as-to-one photographs. He requested to examine the clothing. And all this was arranged for Dr. Vale who then gave his opinion on this particular injury.

516 MR. KELBERG:

Did he in fact issue a report to your office?

517 DR. LAKSHMANAN:

Yes, he did.

518 MR. KELBERG:

Is Dr. Vale, in his consulting role as a forensic odontologist, considered an employee of the Coroner's office?

519 DR. LAKSHMANAN:

Yes.

520 MR. SHAPIRO:

Objection, calls for speculation.

521 THE COURT:

Overruled.

522 MR. KELBERG:

You may answer the question, doctor.

523 DR. LAKSHMANAN:

Yes.

524 MR. KELBERG:

Did he in fact submit his report on a form like we have seen in these other forms that there is a specific number used by the Coroner's office in the course of its official responsibilities?

525 DR. LAKSHMANAN:

Yes.

526 MR. KELBERG:

What kind form is that?

527 DR. LAKSHMANAN:

It is a consultant form, form 13, which is used for this purpose.

528 MR. KELBERG:

Now, is there anything else preliminarily to discuss on B-11 before we look at the protocol, the diagram and Dr. Vale's reports?

529 DR. LAKSHMANAN:

Yes. He did not think it was a bite mark.

530 MR. KELBERG:

All right.

531 MR. SHAPIRO:

Motion as to strike as nonresponsive, calling for hearsay.

532 THE COURT:

Overruled.

533 MR. KELBERG:

Your answer was he did not think it was a bite mark?

534 DR. LAKSHMANAN:

From the photographic review.

535 (Brief pause.)
536 THE COURT:

And Mr. Kelberg, 10:30.

537 MR. KELBERG:

Okay. Thank you, your Honor.

538 (Brief pause.)
539 MR. KELBERG:

We are going to be using, your Honor, 0B, I believe that is 2B and 10B from our 349 collection.

540 MR. KELBERG:

Doctor, let's start with the protocol itself. Where is any entry from Dr. Golden concerning this u-shaped abrasion you have identified in photograph B-11?

541 DR. LAKSHMANAN:

Page 3.

542 MR. KELBERG:

Page 3?

543 DR. LAKSHMANAN:

Yes.

544 MR. KELBERG:

Where is the entry?

545 DR. LAKSHMANAN:

He actually has included in the same paragraph because he has used the upper back, right side and medial part of the scapula and he refers to upper back in diagram 20 to this area here, (Indicating), so that is where he has documented it.

546 MR. KELBERG:

All right. First of all, would it be accurate to say that he has in this paragraph on page 3, that we have already outlined in red as B-12, he has incorporated a description of both the B-12 blunt force trauma and what is seen by you in the B-11 photograph?

547 DR. LAKSHMANAN:

Yes.

548 MR. KELBERG:

All right. So what I will write is on--by B-12, I will also write "B-11" in blue by the box.

549 MR. KELBERG:

But there is a separate entry, is there, doctor, on form 20?

550 DR. LAKSHMANAN:

Yes. He has marked it in the back of the right neck area and he has called them antemortem, red brown and he also says "Appears antemortem"--"Ante, abrasion, red brown" and he has marked it here. This is the same injury.

551 MR. KELBERG:

All right. Both where I'm pointing--I don't want to mark it until I'm clear--where I'm pointing, first of all, here, doctor?

552 DR. LAKSHMANAN:

No. This abrasion description could apply to this one, but he has marked it separately as "Am" also, antemortem, so this could reflect for this and this, but in both he has also given notation being ante, a-n-t-e, antemortem.

553 MR. KELBERG:

All right. Is it in your interpretation this entry in the right-hand corner reflects--I'm sorry--refers to these two somewhat diagonal lines?

554 DR. LAKSHMANAN:

Yes.

555 MR. KELBERG:

Let me circle that in blue and I will write B-12--"B-11," excuse me.

556 MR. KELBERG:

Now, doctor, when you were testifying a moment or so ago, you said he didn't describe it as a u-shaped?

557 DR. LAKSHMANAN:

Yes.

558 MR. KELBERG:

And is the basis on that--on which you testified to that, the fact that in the diagram they appear to be in line with each other?

559 DR. LAKSHMANAN:

Yes.

560 MR. KELBERG:

In your opinion is it a mistake for Dr. Golden not to have shown that abrasion to be a u-shaped abrasion as you see it in the photograph?

561 DR. LAKSHMANAN:

I already thought I discussed it. The upper part of the u is very faint, and if you do not perceive it, you may describe it as a linear as he has done.

562 MR. KELBERG:

Would you expect him to perceive it in a meticulous examination?

563 DR. LAKSHMANAN:

Yes.

564 MR. KELBERG:

And if he failed to perceive it and failed to record it, are those mistakes?

565 DR. LAKSHMANAN:

Yes.

566 MR. KELBERG:

Any significance to them?

567 DR. LAKSHMANAN:

No.

568 MR. KELBERG:

For the same reason?

569 DR. LAKSHMANAN:

Yes.

570 MR. KELBERG:

Anything further as to protocol and that diagram for this particular abrasion?

571 DR. LAKSHMANAN:

No.

572 MR. KELBERG:

Let me put up--why don't we take down the--I'm sorry. Dr. Lakshmanan wants to add something; is that correct?

573 DR. LAKSHMANAN:

He didn't describe it--he described it as antemortem in the diagram, but here he has included it as a postmortem.

574 MR. KELBERG:

So again, on page 3, and let me outline in blue, the words "Postmortem injuries," within that box referring to B-11 and B-12, that would be different than how he has actually described it on the form used at time of autopsy, at least for this particular what you say is a u-shaped abrasion?

575 DR. LAKSHMANAN:

Yes, and he has recognized it as being antemortem.

576 MR. KELBERG:

According to his diagrammatic entry; is that correct?

577 DR. LAKSHMANAN:

Yes.

578 MR. KELBERG:

And in your opinion that is accurate, that it is antemortem?

579 DR. LAKSHMANAN:

Yes.

580 MR. KELBERG:

Anything further on that?

581 DR. LAKSHMANAN:

No.

582 MR. KELBERG:

If Mr. Lynch will take down the protocol and we will substitute--

583 THE COURT:

Do you want to just put it on top of the--

584 MR. KELBERG:

I'm not sure. Can we put it back up? I don't know what the weight of this particular easel is.

585 (Brief pause.)
586 MR. KELBERG:

Doctor, in looking at this, are you familiar with this particular type of form?

587 DR. LAKSHMANAN:

Yes.

588 MR. KELBERG:

In general what is this type of form?

589 DR. LAKSHMANAN:

This is a consultant report by the odontologist--it is a consultant report and here we have an odontology consultant report.

590 MR. KELBERG:

And this is one of the reports received by Dr.--from Dr. Vale?

591 DR. LAKSHMANAN:

Yes.

592 MR. KELBERG:

And is this a report that is expected to be completed at or near the time of the events which he is describing in the report?

593 DR. LAKSHMANAN:

Yes.

594 MR. KELBERG:

Is this report kept in the ordinary course of the official business of the Coroner's office?

595 DR. LAKSHMANAN:

Yes.

596 MR. KELBERG:

Now, in essence, what does this say?

597 DR. LAKSHMANAN:

That he has examined the mark on the back of the right side of the neck, he has examined certain other marks in the lower right back, and he has reviewed a lot of photographs and he--this is the point when he examined initially and then he wanted some--wanted someone, as to one photographs and clothing, to examine, and he has given a follow-up report after this one.

598 MR. KELBERG:

Doctor, from your testimony, does this report discuss evaluations of things besides this u-shaped area that we have been talking about in photo B-11?

599 DR. LAKSHMANAN:

Yes.

600 MR. KELBERG:

And matters which we have not yet discussed in one or more photographs?

601 DR. LAKSHMANAN:

That is correct.

602 MR. KELBERG:

All right. What part of this September 9, 1994, report specifically refers to an evaluation of the u-shaped abrasion?

603 DR. LAKSHMANAN:

Photograph a.

604 MR. KELBERG:

And I will outline that in red on page 1 of the September 9th form 13 and write "B-11" out at the side.

605 MR. KELBERG:

And doctor, at the bottom where it says initialed by G.L.V., that is Dr. Vale?

606 DR. LAKSHMANAN:

Yes.

607 MR. KELBERG:

You mentioned something about providing life-size one-to-one--as you described, one-to-one photographs, life-size photographs and an opportunity to look at the dress of Nicole Brown Simpson?

608 DR. LAKSHMANAN:

Yes.

609 MR. KELBERG:

And that is what Dr. Vale has included in this report?

610 DR. LAKSHMANAN:

Yes, and he also requested my criminalist, Mr. Steven Dowell, to look at these injuries--these photographs and the clothing.

611 MR. KELBERG:

There is also a second signature that falls below Dr. Vale's on this form. Who is Dr. Anselmo?

612 DR. LAKSHMANAN:

He is the core director of the School of Dentistry at USC, but he is also another of the forensic odontology consultant who works for our office.

613 MR. KELBERG:

In the same manner that Dr. Vale does?

614 DR. LAKSHMANAN:

Yes.

615 MR. KELBERG:

Now, flipping to a third page, this appears to be another form 13, this time dated September 14, 1994. What is this document, if you are familiar with it, doctor?

616 DR. LAKSHMANAN:

Yes. This is the document which Dr. Vale prepared after reviewing the clothing in the LAPD lab and also the one-as-to-one photographs, and he generated a report.

617 MR. KELBERG:

And what part, if any, of this report is discussing the u-shaped abrasion and possible source or sources for it?

618 DR. LAKSHMANAN:

The second paragraph in the conclusion section of form 13 signed on September 15, `94.

619 MR. KELBERG:

This entire paragraph, doctor?

620 DR. LAKSHMANAN:

Yes.

621 MR. KELBERG:

And I will write "B-11" after I have outlined in red.

622 MR. KELBERG:

Doctor, would you read what Dr. Vale, Dr. Anselmo and Mr. Dowell have included in that paragraph in the report.

623 DR. LAKSHMANAN:

"Regarding on the mark on the back of the neck, right side. It remains our opinion that this is not a bite mark, after having considered the possibilities of a bite in the vertical axis and in the horizontal axis. We do not exclude the possibility that the hook on the neck strap caused some or all of the mark, noting some similarity between the shape of the hook and the upper portion of the mark."

624 MR. KELBERG:

You have examined the clothing of Nicole Brown Simpson that is described in this report, have you, doctor?

625 DR. LAKSHMANAN:

Yes, I have.

626 MR. KELBERG:

And doctor, based upon Dr. Vale, Dr. Anselmo and Mr. Dowell's report and based upon your evaluation of all of the materials you have reviewed, do you have an opinion that is any different from the opinions expressed in that paragraph as to the source or sources for that u-shaped abrasion?

627 DR. LAKSHMANAN:

No.

628 MR. KELBERG:

Your Honor, I think we are done with this and this may be an appropriate time.

629 THE COURT:

All right. Ladies and gentlemen, we are going to take our recess, mid-morning recess at this time. Please remember all of my admonitions to you. Do not discuss this case among yourselves, form any opinions the case, conduct any deliberations or allow anybody to communicate with you with regard to the case. And we will stand in recess for fifteen minutes. All right. Thank you.

Temperature

procedural

Key Quotes (4)

Dr. Lakshmanan Sathyavagiswaran
There seems to be a paucity of Defense wounds in the hands of Miss Nicole Brown Simpson which would again support my opinion that she was rapidly incapacitated or incapable of resistance when she was assaulted.
Core prosecution argument that Nicole had no time to fight back, supporting a theory of a swift, controlled attack.
Dr. Lakshmanan Sathyavagiswaran
I have not seen any cases like that. The cases where the clothing has been put back on, they are—at least the cases I have seen they have been put back on improperly and there is always evidence of—evidence of assault which you can see.
Direct rebuttal of any sexual assault theory; the intact, undisturbed panties rule out rape followed by redressing.
Dr. Lakshmanan Sathyavagiswaran
You cannot estimate a time of death from that, especially for such a narrow time frame, and even if it is not a narrow time frame I would not estimate a time of death from presence of sperms because you have so much variability in it.
Deflects defense arguments that a sexual assault kit could have narrowed the time of death window.
Dr. Lakshmanan Sathyavagiswaran
It is a mistake in his dictation, but in his documentation it is not a mistake because it has documented it properly.
Characteristic pattern of the testimony: acknowledging Golden's errors while minimizing their overall significance.

Evidence (8)

People's 355
Autopsy photograph board of Nicole Brown Simpson
Discussed; specific photos B-1, B-12, B-23, B-24, B-29, B-31 examined
People's 354
Crime scene photograph board; date corrected from 1995 to June 13, 1994
Briefly displayed; photos CS-11 and CS-12 examined for ant/insect activity
People's 352
Autopsy photograph board; B-23 entry corrected to right side of head
Correction noted for the record
People's 349 (0B and 4B; 0B and 2B)
Autopsy protocol form 12 (page 7 re: right hand abrasion; page 3 re: back excoriations) and body diagram form 20/23
Annotated in court with red and blue markers to highlight errors and cross-reference photographs
People's 350
Dr. Lakshmanan's wound chart
Referenced for precise measurements of shoulder abrasions
Informal
LA County Coroner Physical Evidence Policy and Procedures Manual (August 1987, issued February 1988)
Section 8.13.1 on sexual assault evidence read into the record in full; used to establish that proper procedure was followed in not taking a kit
+ 2 more

Notable Exchanges (4)

Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg walks through an elaborate hypothetical asking whether Nicole could have been raped, had her panties neatly replaced, and then been murdered — Lakshmanan says he has never seen such a scenario and the intact, undisturbed clothing makes sexual assault inconsistent with his experience.
strategic
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Extended back-and-forth on motile sperm survival times (average 4 hours, up to 60 hours) and acid phosphatase Bodansky units as potential time-of-death tools, ultimately concluding neither could establish a narrow time-of-death window.
technical/methodical
Robert ShapiroLance A. Ito
Shapiro successfully moves to strike Lakshmanan's reference to what Dr. Golden observed during the autopsy as hearsay; Ito sustains and instructs the jury to disregard.
procedural
Brian KelbergDr. Lakshmanan Sathyavagiswaran
Kelberg repeatedly has to remind the doctor to keep his voice up so the jury can hear him — a recurring issue throughout the session.
light

Light Moments (2)

Brian Kelberg
Kelberg reminds the doctor not to answer before the question is finished: 'If you will remember to wait until I finish my question, I will try and remember to wait until you finish your answer, and I have a feeling the court reporter will be very happy with both of us.'
Brian Kelberg
Kelberg loses his place after handing the coroner's manual to the doctor: 'I shouldn't have given the manual over to you, doctor. I lost my place.'

Credibility Attacks (1)

⚔ Dr. Irwin Golden
Prior inconsistent statement / documentation errors
Kelberg uses Lakshmanan to catalog a series of errors in Golden's original autopsy protocol: wrong finger identified for abrasion (ring vs. index), shoulder abrasions misclassified as postmortem excoriations attributed to ant/insect bites, incomplete diagramming, and incorrect wound dimensions repeated in preliminary hearing testimony — all corrected by the addendum Lakshmanan supervised.

Witness Demeanor

Repeatedly drops his voice requiring Kelberg to prompt him to speak up
Pauses to take a sip of water mid-examination
Occasionally answers before the question is finished

Objections

2 objections (1 sustained, 1 overruled)
Proceeding 6315 • 629 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 8, 1995 📄 Direct examination of Lakshman
JUN 8, 1995 KRT DvH TD