Department no. 103 Hon. Lance A. Ito, Judge

APPEARANCES: (Appearances as heretofore noted.)

(Janet M. Moxham, CSR no. 4855, official reporter.)

(Christine M. Olson, CSR no. 2378, official reporter.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: All right. Back on the record in the Simpson matter. Mr. Simpson is again present before the Court with his counsel, Mr. Shapiro, Mr. Cochran, Mr. Neufeld, Mr. Douglas. The People are represented by Mr. Kelberg, Mr. Lynch. Also present, Mr. Darden. The jury is not present. Good morning. Mr. Neufeld, Mrs. Robertson told me that you had an issue you wanted to advise the Court of.

MR. NEUFELD: Thank you, your Honor.

THE COURT: Good morning, sir.

MR. NEUFELD: Yesterday I learned of a revised schedule from the District Attorney's office in which they said that after Dr. Lakshmanan there were going to be some witnesses involving gloves and shoes and then they intended to call Bruce Weir and the other DNA witnesses. Umm, you may recall, your Honor, that bruise Weir's name came up when the decision was made by the Prosecution not to rely on Dr. Cotton for certain frequencies, but instead to have that articulated by Dr. Weir. At that time Dr. William Thompson came into Court and expressed on the record our objection to what appeared to be a preliminary report of Dr. Weir's suggesting that he was going to testify about likelihood ratios, and our objection was based in part on the fact that there was no legal precedent for using likelihood ratios in a criminal case anywhere in the State of California, and perhaps anywhere in the United States, as well as other grounds. And at that point Mr. Clarke said we don't intend to use the likelihood ratios in that report, there is a lot of other data there that we intend to rely on to express frequencies. Well, we received another preliminary report from Dr. Weir last week which again relies heavily on this use of likelihood ratios. Dr. Thompson said at that time that if they intend to try and offer likelihood ratios or to offer anything different than what the Court's order required, which was simply an aggregation of frequencies in mixtures, that we would of course demand a 402 hearing on that particular issue, which had nothing to do with the DNA Kelly-Frye hearing, it just has to do with the manner in which evidence can be expressed to the jury. If they intend to call Dr. Weir and if they intend to utilize these likelihood ratios, then we need to sort of schedule this 402 hearing. We would call witnesses in opposition at that hearing just on that one issue of the likelihood ratios. So I'm simply asking for two things: One, perhaps someone from their office can come down either at the break, the lunch break, or the beginning of the afternoon session so just both of us can talk to the Court and get some head's up on, if that is their intent, so that we can schedule that at 1:30.

THE COURT: All right.

MR. NEUFELD: Can that be done at 1:30? Thank you very much.

THE COURT: By the way, we will be in recess for lunch today until 1:30.

MR. KELBERG: Your Honor, may I suggest actually if Mr. Neufeld has limited interest in hearing about forensic pathology, that Mr. Clarke and/or Mr. Harmon may well be upstairs on the 18th floor at this time, or shortly from this time, and it might be beneficial if in some fashion he can wander up to the 18th floor or I assume he has the office number for both Mr. Clarke and Mr. Harmon.

MR. NEUFELD: All right.

MR. KELBERG: See if they can get together before 1:30.

MR. NEUFELD: Fine. We will report back to the Court at 1:30.

THE COURT: Mr. Cochran.

MR. COCHRAN: Good morning, your Honor. Your Honor, with regard to the scheduling, the Prosecution yesterday did delete one witness from their list and we understand they have changed the order. What I'm asking now is whether or not from the Prosecution we can get a list, certain as possible, for the conclusion of the case, because we have lawyers who are all over the United States, and rather than have a delay in the trial--

THE COURT: There will be no delay.

MR. COCHRAN: Okay, and I appreciate that, and so that in order to be ready, your Honor, we need to know who is coming up next and have some kind of certainty with regard to that, so the lawyers can return in enough time to make sure they are ready.

THE COURT: Let me make inquiry of Miss Clark and Mr. Darden since they have the overall responsibility for this. Good morning, counsel.

MS. CLARK: Good morning, your Honor. Yes, I informed counsel yesterday that we are closer to the end than we thought we were, and we are--I inquired of Mr. Harmon and Mr. Clarke yesterday as to when the last probe would be pulled off 117, and I have to solidify that before I can give counsel a totally accurate picture. But I have told counsel so far that after the Coroner--actually, maybe I told Mr. Douglas, I'm sorry.

MR. COCHRAN: Okay.

MS. CLARK: That after the Coroners it would be either shoes or gloves, and they know what chain of witnesses that is, and following that we believe we can proceed with the rest of DNA and Dr. Weir, and EDTA, and then perhaps the Airtouch representative concerning cell phone records, and a couple of other miscellaneous witnesses that I have to solidify, and then hair and trace, so that is roughly the scenario. There are certain things, obviously from what the Court has heard, that we have to solidify and I think that I will be able to do that by the end of the day. I would ask the Court to order, in return for this revised witness order and list, that the Defense be required to turn over the discovery that we have been requesting for months now. We have no expert reports, we have no valid witness statements. We have these little notes scribbled that are basically hieroglyphics. And we are asking the Court to order the Defense to comply in spirit, and not just in form, with 1054 and the Court's discovery orders, because we have received nothing in response to the Court's orders.

THE COURT: We have that scheduled for a hearing.

MS. CLARK: Thank you, your Honor.

THE COURT: So my understanding is gloves, shoes, DNA?

MS. CLARK: Or shoes, gloves, your Honor, yeah.

THE COURT: Cellular phone and then hair--hair and fiber?

(Discussion held off the record between the Deputy District Attorneys.)

MS. CLARK: Yes. Now, the witnesses I told you there were some that we have to solidify, regard domestic violence and we are not sure which, or you know, how many exactly we are going to call, but the Court knows which ones they are potentially, and so does the Defense, and we have to firm up exactly which ones those would be, so that--it won't take very long.

THE COURT: Just scheduling wise, when do you anticipate putting those on? Before or after DNA, before or after the cell phone records?

MS. CLARK: Around the cell phone records. Before or after the cell phone records, that is the feeling, and there are four or five of those witnesses, but they are brief.

THE COURT: Yeah.

MS. CLARK: Okay.

THE COURT: Okay.

MR. COCHRAN: One last thing, your Honor, is I presume that that--what Miss Clark has just indicated will be solidified by the end of the day and we would like to be able to go with that and we will rely upon that and we would like to make sure we have all the discovery also for these upcoming witnesses. We are concerned about whether or not we have all the discovery for Bodziak and certainly with regard to any information on the tickets, on that, and we want to make sure we have all the discovery and make sure there is no delay.

THE COURT: Miss Clark.

MS. CLARK: They have everything we have. We can't give them what we don't have. As soon as we have information, they will have it without any delay at all because everyone is interested in the expeditious end to this trial, so it will be literally within the time frame that we learn that we have a witness we are going to be calling, it will be minutes before we are on the phone to counsel, I can promise you that.

THE COURT: All right. As soon as we finish with the Coroner's testimony I would like to take a five minute recess and launch into the next witness.

MS. CLARK: Sounds good.

THE COURT: All right. All right. Let's have the jurors, Deputy Magnera. I'm sorry, Mr. Kelberg.

MR. KELBERG: Your Honor, for the record, before Court began I provided the Court with three photographs. I have advised Mr. Shapiro as well. And I ask for a motion in limine to be heard at this time regarding the use of these three photographs with Dr. Lakshmanan's testimony. The circumstances arose as a result of Dr. Lakshmanan's testimony yesterday concerning a difference of opinion he holds regarding incise wounds 1 and 2 from photograph G-37 and the time at which those wounds were inflicted. As the Court will recall, it is Dr. Lakshmanan's opinion that those wounds represent control holds that were inflicted early on in the circumstances between the assailant and Mr. Goldman. Dr. Golden's testimony, which was read to Dr. Lakshmanan in front of the jury, suggested in Dr. Golden's opinion those wounds appeared to be inflicted closer to the time of death due to the absence of hemorrhage. In the course of Dr. Lakshmanan's testimony explaining a basis for his opinion that those wounds were in fact early on as control wounds, he referred to review of certain crime scene photographs. Those crime scene photographs have not been marked nor offered at any phase of the proceeding, to my knowledge, certainly not by me. They were not part of our photographic motion that the Court reviewed concerning autopsy photographs, and I believe a total of approximately five crime scene photographs. The three photographs that I provided to the Court, only two of which we were offering, your Honor, one has a glove covering the eye and upper face area of Mr. Goldman. That is one of the two we would offer.

THE COURT: What do you need to offer this for?

MR. KELBERG: It is for the appearance of the two superficial incise wounds. They show hemorrhage in the crime scene photographs which is the basis for Dr. Lakshmanan's opinion that these are antemortem early in the relationship between the assailant and Mr. Goldman as to when they were inflicted. I will be the first to acknowledge to this Court they are nasty photographs to look at, primarily because of the blood that is surrounding the face and neck of Mr. Goldman, but it is extremely important, your Honor, extremely important where especially there is a difference of opinion between the two forensic pathologists, one of whom the Defense has indicated yesterday they intend to call, that this jury have the best available evidence on which to make a determination. Is Dr. Golden correct when he formed the view that they were inflicted at or near the time of death or is Dr. Lakshmanan correct in his view that they were inflicted early on before death as antemortem wounds? And unfortunately, your Honor, there is just no easy way for people to be presented with this evidence, but this is very probative. Of course the aspect of whether they are control wounds inflicted early on goes to the issue of premeditation and deliberation and all of the other circumstances that we posed before. But as I said, I would be the first to acknowledge that they are not pleasant paragraphs to look at, even in the scheme of a series of photographs which the Court has candidly acknowledged are unpleasant to look at. I think to some degree this jury is at least steeled to this type of photograph, and it would be my suggestion--I am not anticipating, if the Court allows me to use the two photographs we have proposed, to have them presented at close range to the jurors. I would rather have Dr. Lakshmanan refer to them, perhaps even while seated at the witness stand, as the basis for part of his opinion that those early--that those two incise wounds were inflicted early on, and then have them available for the jury's consideration. I will not have them put up even on the board. I will not have them even displayed to the jury at this phase, but rather to have them available as evidence at the end for the jury's consideration. But for Dr. Lakshmanan to say, gee, I reviewed some crime scene photos, they were informative to me because they showed hemorrhage and so forth, and that is the basis of my opinion, the jury has no basis on which to Judge his interpretation, because they would not have the photographs if the Court found that the prejudicial impact outweighed--substantially outweighed the probative value. I believe these are substantially probative on this important issue where there may be a conflict between the opinions and where these photographs help to give the jury a legitimate basis on which to determine who is correct in their opinion, Dr. Golden or Dr. Lakshmanan.

THE COURT: Have you shown these to Mr. Shapiro?

MR. KELBERG: Mr. Shapiro, I'm sure, has seen them, not today, so he may not know which ones they are and I will be glad to show them to him now and do whatever the Court wishes.

THE COURT: Mr. Shapiro, are you familiar with these three photographs?

MR. SHAPIRO: Yes, I am, your Honor.

THE COURT: All right.

MR. SHAPIRO: Yes.

MR. KELBERG: So I will submit it on that matter, your Honor, on that basis.

THE COURT: Don't you feel we should at least crop some of these?

MR. KELBERG: Your Honor, I have no problem with cropping to basically just leave the neck area that will show in context the complete neck area that is shown in the photographs. That in and of itself will narrow but not eliminate the unpleasant nature of the photographs. But again, I have to go back to Justice Gardner's observation, these ladies and gentlemen of the jury do not come from an insular world where matters of this nature are completely foreign, and certainly after six days of testimony involving, to some degree, very difficult photographs to look at, I believe they have, at least to some degree, as I use the word "Steeled"--become more comfortable as not an accurate way of describing it--but steeled as to what they are going to look at. And I believe they do understand that these are being presented to them for their informational value, and if the Court would like them cropped, I have no problem cropping them to expose basically the neck area and eliminate everything else, because I anticipate a foundation will be laid by another witness to show that they fairly and accurately show the condition of Mr. Goldman's neck at the time the bodies were examined at the scene on Bundy on June 13, 1994.

THE COURT: I suggest that we mark these first for identification purposes, if nothing else, at this point.

MR. KELBERG: Certainly, your Honor. These go with what I believe is our board 358, so may I suggest they be marked respectively 358-A and B. If I could have the third photograph back--I'm really not offering it. It was just used to give the Court a context to compare two alternative photographs. Do you want me to take the two--

THE COURT: I don't know which one you marked--that you want marked as which?

MR. KELBERG: Do you want me to do it up here for the Court.

THE COURT: Please.

MR. KELBERG: Your Honor, on the back of the first photograph I'm writing "358-A" and on the second photograph I'm writing at the bottom "358-B." And if I may, your Honor, I would take back then the third photograph which I do not intend to offer.

THE COURT: All right. All right.

(Peo's 358-A & 358-B for id = Coroner's photos)

THE COURT: Mr. Shapiro.

MR. SHAPIRO: Thank you, your Honor.

THE COURT: Good morning, counsel.

MR. SHAPIRO: Good morning, your Honor. Your Honor, we would strenuously object to these photographs, as we have strenuously objected to all the photographs. We believe that the Prosecution has presented a scenario to allow these photographs in and then withdrawn from that scenario once the Court admitted the photographs. The Prosecution told you, during the arguments, that these photographs would be necessary because there would be a conflict in the testimony between Dr. Lakshmanan and Dr. Golden and they would be necessary for Dr. Lakshmanan to point out the errors that Dr. Golden made. Now, after all the photographs have been entered, they have withdrawn Dr. Golden as a witness and are relying only on Dr. Lakshmanan who did not in any way participate in these autopsies. There are--what they have done is they have created their own issue that allowed these horrendous photographs to be displayed before the jury, and then said that is no longer an issue because they are not going to be offering testimony from Dr. Golden. What they have done, your Honor, is deliberately presented to this jury the most horrendous and horrifying photographs that one could imagine with only a desire to inflame the passions and prejudices of the jury and anyone who would look at these photographs. And clearly the Court saw that was the case when you had to declare a recess last week when several members of this jury could not look at those photographs any longer and reported illness upon looking at those photographs.

Those photographs now have no value whatsoever. Dr. Lakshmanan's opinion of what took place need not be based on repeated gory photographs. Initially the only reason that they were going to be allowed was he was going to say, well, Dr. Golden looked at this injury and he is going to testify as to what that injury is and my opinion is different than his, and he is wrong and we are going to sacrifice Dr. Golden and his professional reputation because his theory doesn't fit the Prosecution's theory of this. And now you are in a position where you have admitted these photographs, they want more to be admitted with no purpose whatsoever since Dr. Golden won't be a witness. We would strenuously object and we believe that there should be sanctions against the People for presenting a theory to your Honor for entering the photographs and then after they were entered withdrawing from that theory.

THE COURT: Mr. Kelberg.

MR. KELBERG: May I briefly respond, your Honor? I'm always impressed with Mr. Shapiro's hyperbole. I find that the more hyperbole counsel uses the more probative and the more relevant and the more success this evidence is having in establishing for this jury a true understanding of the circumstances. The record will clearly reflect, and I know the Court remembers it quite accurately, that in offering these photographs we have made it clear that it is not a question of whether Dr. Golden testifies or not, it is an issue that Dr. Golden made a lot of mistakes and these photographs will help this jury, as they have I'm sure helped Dr. Wolf and Dr. Baden who have to go through the very same process Dr. Lakshmanan has gone through, and I hope they have spent the same amount of time that Dr. Lakshmanan has, because if they are called to testify, they will be questioned by me quite extensively, that these photographs are the best record to show what in fact happened and with a qualified forensic pathologist like Dr. Lakshmanan to give the jury an understanding of the significance of the findings seen in the photographs and the autopsy materials and also to understand what, if any, significance flows from Dr. Golden's mistakes, because Dr. Golden's mistakes are mistakes whether Dr. Golden testifies or not. And I do find it somewhat disingenuous for the Defense to be claiming that these photographs are irrelevant because of a claimed, quote, conflict in testimony which is not being presented when of course that is not what we told the Court, and then counsel stand up yesterday and says, in essence, Dr. Golden is going to be one of our first witnesses. Well, let's give the jury the truth and let's cut the hyperbole down to a minimum, if we possibly can, and let's talk about what Dr. Lakshmanan said yesterday. Mr. Shapiro didn't mention one whit of what the testimony from Dr. Lakshmanan was yesterday. Mr. Shapiro never objected when the testimony given by Dr. Golden, I believe at the grand jury concerning his interpretation of those two superficial incise wounds, was provided to the jury and for Dr. Lakshmanan to comment on as another mistake in his opinion, Dr. Lakshmanan's, Dr. Golden's opinion on those wounds, that is a mistake.

THE COURT: So what does it tell us--

MR. KELBERG: It tells us--

THE COURT: --to see the hemorrhage in those two incise wounds? What does that tell us?

MR. KELBERG: It tells us, as I have talked with Dr. Lakshmanan, that by seeing that hemorrhage, those superficial incise wounds bearing the same general appearance from the standpoint of hemorrhage as the major stab wounds which is to the left side of the neck which is a fatal wound to the jugular vein, were inflicted antemortem, before death, and would be consistent with Dr. Lakshmanan's opinion that they are in fact control wounds when the perpetrator was threatening or taunting, pardon me, Mr. Goldman, following which it is clearly that Mr. Goldman, realizing the very dangerous and life threatening situation he was in, attempted to save his life and for which there has been much testimony and there will be much more testimony concerning his injuries that ultimately resulted in his death. But Mr. Shapiro never mentions any of that aspect in responding to our comments. He doesn't mention the substantive value of seeing those wounds with their hemorrhage before the bodies are washed at the Forensic Science Center. And the washing, as the Court will recall, is for the specific purpose of getting rid of the bloody appearance, so that the wound can be carefully examined by the forensic pathologist.

THE COURT: How do I know that the blood that is apparent here is blood from the wound itself or blood from the jugular vein, given the proximity?

MR. KELBERG: I believe, and I can only make an offer of proof--and perhaps the Court might want to have Dr. Lakshmanan briefly get on the witness stand and I can do a very quick 402 examination regarding what he observes in those photos regarding those two wounds and the significance, if any, to him, or I can make an offer of proof, whichever the Court prefers.

THE COURT: Let's assume that there is a dispute whether or not--as to the age of those wounds. What is the real probative value one way or another?

MR. KELBERG: If in fact those are antemortem wounds and support Dr. Lakshmanan's opinion that they are control wounds which would be in conformity with, as the Court will recall, the demonstration where Mr. Goldman is being restrained from behind by the perpetrator who is taunting him with the knife in front of his neck and drawing the knife across to create those superficial incise wounds, that is a reflection of premeditation and deliberation, that control and those threatening type wounds, rather than at the end, which I must suggest makes no sense logically. If all hell breaks loose, for lack of a better term, in a struggle between Mr. Goldman and the perpetrator, it makes no sense logically that the perpetrator, who is engaged in inflicting all the defensive wounds and in inflicting fatal stab wounds to the abdomen and the chest and left side of the neck is then going to at some point while Mr. Goldman is disabled from moving, because you need that, carefully draw parallel superficial incise wounds along the neck. I mean, logically I would suggest to the jury, if I were arguing this case, that that would make no sense whatsoever and would be another reason why Dr. Golden's opinion would not make sense, would not stand the scrutiny of scientific investigation. But from the standpoint of medical evidence, besides logic--

THE COURT: Mr. Kelberg, isn't the real issue here what was the cause of death and is it possible for one person to have committed both of these killings? Isn't that the bottom line here?

MR. KELBERG: That is part.

THE COURT: What does that tell me about that?

MR. KELBERG: It is part of the bottom line. One person committing, yes, the fact that these are control superficial incise wounds at the beginning with a taunting and so forth, I think does reflect that it is a single killer who has knocked Nicole Brown Simpson into a dazed or potentially even unconscious state from a concussion, as the Court will recall, to the contusion to the head and now is dealing with Mr. Goldman and dealing with Mr. Goldman with a threatening, taunting control type series, two superficial incise wounds and going to the issue of premeditation and deliberation. But those are not the only issues in this case. It is not just cause and whether one perpetrator did these things, because premeditation and deliberation is built along a process that is not necessarily related to the number of people involved, but actually to the manner of the killing itself. And cause of death, as the Court knows, is a narrow area dealing with the manner which a murder takes place and this is a matter that deals more with the manner than with the cause. I don't think anybody disputes the cause, I mean, having knows these two people bled to death from sharp force injuries, but if that were the only issue, I wouldn't be here and I wouldn't have taken up six days or seven days of this Court's time, the jury's time, Defense counsel's time. We are here because there is a lot more to this than cause of death and this concept of one perpetrator.

THE COURT: Thank you, counsel.

MR. KELBERG: Thank you, your Honor.

MR. SHAPIRO: Your Honor, this appears to be an unprecedented marathon to present evidence that is readily susceptible of reading from a crystal ball, and we have spent seven days, the People want to spend two more days, to criticize what they say is a search for the truth. And that is, there is not one medical examiner or forensic pathologist in the world who would tell you that you are better off looking at photographs to come to an opinion than you are at doing an actual autopsy and looking for evidence. The People love to continue to talk and press and go into minutia and detail that most people who are looking at this case are mystified by, and I think it is time for your Honor to step in and say the jury has enough evidence on the real issues at hand, limit the issues, limit the testimony, and let's, if the real intent is to move this case on and to get at the truth, get at the truth, and that would be by calling the person who did the autopsy, not by somebody who is trying to now look to the past in some mystifying way and reconstruct in their mind what might have happened. It is pure guesswork at its best. Thank you.

MR. KELBERG: Just briefly if I might, your Honor?

THE COURT: No. I think I've heard enough. All right. The Court will sustain the objection to 358-A. I will overrule the objection to 358-B. I will direct that it be cropped to depict only the area between the gloved hands.

MR. KELBERG: All right. Your Honor, if I could get scissors--in fact, actually I think we have scissors. Can I give the Court scissors and the Court crop it in the manner--

(Brief pause.)

MR. KELBERG: And your Honor, may I ask that the two dismembered portions of the photograph be kept, however, as part of the exhibit in the event of the conviction and review on appeal, so that the Court will understand--Court of Appeal, that is--the discretion exercised by this Court in excising those two portions?

THE COURT: I have stapled them together.

MR. KELBERG: Thank you, your Honor. May I approach to obtain that one photograph?

THE COURT: You may.

(Brief pause.)

MR. KELBERG: And your Honor, this one is not marked because the portion that the Court excised had the writing. May I mark this as 358-B?

THE COURT: Yes, you may.

(Brief pause.)

THE COURT: All right. Deputy Magnera, let's have the jury, please.

(Brief pause.)

MS. CLARK: Your Honor, while the jury is coming out, may we approach without the reporter?

THE COURT: Yes. Mr. Cochran.

(A conference was held at the bench, not reported.)

(The following proceedings were held in open court, in the presence of the jury:)

THE COURT: All right. Let the record reflect we have been rejoined by all the members of our jury panel. Good morning, ladies and gentlemen.

THE JURY: Good morning.

THE COURT: All right. Dr. Lakshmanan, would you please resume the witness stand.

Lakshmanan Sathyavagiswaran, the witness on the stand at the time of the evening adjournment, resumed the stand and testified further as follows:

THE COURT: Good morning, doctor.

DR. LAKSHMANAN: Good morning, your Honor.

THE COURT: You are reminded, sir, that you are still under oath. And Mr. Kelberg, you may conclude your direct examination.

MR. KELBERG: I take it not very subtle hint.

THE COURT: Thank you.

(Brief pause.)

MR. KELBERG: But I assume I have at least perhaps all day?

THE COURT: Reasonable time.

MR. KELBERG: Good morning, ladies and gentlemen.

DIRECT EXAMINATION (RESUMED) BY MR. KELBERG

MR. KELBERG: Good morning, doctor. Doctor, I just want to cover a couple of areas that we touched upon yesterday, the first area dealing with a difference of opinion you hold from that of Dr. Golden concerning the time when those two superficial incise wounds, injuries numbers 1 and 2 of photographs G-37, were received by Mr. Goldman. Do you recall that testimony yesterday?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And you testified, as I recall, that you had reviewed certain crime scene photographs which caused you to believe that those superficial incise wounds were received early on and were part of control wounds inflicted by a taunting or threatening perpetrator on Mr. Goldman; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And that Dr. Golden, in his testimony in front of the grand jury, had indicated his opinion that those wounds appeared to be inflicted closer to the time of death due to the absence of hemorrhage; is that correct?

DR. LAKSHMANAN: Yes, but I supported my opinion with the statements he made in his autopsy report, which indicates that there is hemorrhage in the soft tissues underlying these wounds, which would indicate that there was blood pressure present when these wound were inflicted. And that is why I opined that they were antemortem wounds and I also gave an opinion that they are consistent with being control wounds which would have happened during the earlier part of the struggle, which is what I feel happened.

MR. KELBERG: But--and doctor, from what you just said, did you feel that there was an inconsistency between the material that had been included by Dr. Golden in his protocol regarding this hemorrhage that he observed and included in his description and yet his opinion being that these were wounds that were inflicted at or about the time of death rather than before death?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Your Honor, for the record, perhaps in front of the ladies and gentlemen of the jury, may I ask that this photograph that is a small rectangular-shaped photograph be marked as 358-B, as in boy.

THE COURT: So marked.

MR. KELBERG: Doctor, let me show you photograph 358-B. Did you review, among crime scene photographs, this photograph in an uncropped fashion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: In other words, you saw the full photograph and this has been cropped, as I understand, pursuant to the order of Judge Ito?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is there something of significance shown in that photograph on the issue of when those two superficial incise wounds were received in relation to when Mr. Goldman died?

DR. LAKSHMANAN: Yes, the appearance of the wounds itself, the coloration, taken in conjunction with the descriptive report which we have in the autopsy, supports the opinion that these are antemortem wounds because there is--you can see the hemorrhage in the tissues, in the margins and also underlying the--the superficial areas of the cut. You see there are areas of the cut which are deeper than the areas of the cut which are not so deep, and in the not so deep areas you can clearly see the discoloration which you get with hemorrhage underlying the tissue which has been confirmed in the autopsy report of Dr. Golden when he did the autopsy. So this photograph especially you can see very clearly in the upper wound and also in portions of the lower wound on the right side of the photograph, and I have no doubt that these are antemortem wounds based on the description of the autopsy report and the appearance of these photographs, the way they are presented to me.

MR. KELBERG: Another matter, doctor, just to finish up before we go back to the hand area, let me put up board 4G from our collection from 357, I believe, and invite your attention--with the Court's permission could the doctor step down again, please?

THE COURT: Yes.

MR. KELBERG: If I could find the markers.

(Brief pause.)

MR. KELBERG: I want to invite your attention, doctor, there is an area I noticed that has not been circled or addressed in some fashion by us. Do you recognize what is written in this area of this--this is roman numeral II form of no. 22?

DR. LAKSHMANAN: Yes. This refers to the cut of the ear and the length of the wound as six inches and this is the sharp force injury and it says, "If ear involved." This refers to this wound on the left side of the neck which in Dr. Golden's original autopsy report indicated that if this left neck wound exited behind the left ear and also cut the left ear, the total length of that wound would be six inches. That is what this refers to.

MR. KELBERG: Doctor, in essence, is this referring to what you described as injury no. 1 of G-51, this fatal sharp force injury stab wound, injury no. 2 of G-51, the somewhat linear in appearance wound behind the ear running down the neck, and injury no. 4 of G-51, a nick to the area you called the pinna, P-I-N-N-A, of the ear?

DR. LAKSHMANAN: Yes.

MR. KELBERG: So the overall reasoning, according to Dr. Golden, you assumed that was all one injury with the neck going--I'm sorry, the knife going in the injury no. 1 area and coming out the area of injury no. 2 and then nicking the ear in the process, would be six inches?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Your Honor, for the record, on this form let me circle this area of information and I will write "G-51 inj. numbers 1, 2 and 4." Doctor, I would like to get back to a discussion of the hand injuries and see if you can identify in the protocol any of them that are described and to deal with the diagrams and the addendum. And for the record, with Mr. Fairtlough's assistance, we have been able to append a flap, I'm not sure it is--we may have to have it held--we have appended a flap which includes then the photograph that was described as G-34. And let me write "G-34," incidentally, on the board underneath the photograph. And also we have appended, with apparently some kind of photo mount, the photograph that was G-25 which I don't know that I have a marker--I think we could take care of it at a later time so that will be identified--but for the record we will do that.

THE COURT: I think there is also an evidence tag below it there.

MR. KELBERG: There is, but unfortunately it doesn't say that it is G-35.

THE COURT: All right. Proceed.

MR. KELBERG: It refers to that course of testimony. Also with Mr. Lynch's help, if we could set up the two easels.

(Brief pause.)

MR. KELBERG: And your Honor, we are going to be dealing with 0G, 10G and a diagram--Mr. Lynch, I'm going to ask that the addendum just be kept down here, if we could, please, and I will ask you to put up--this is our board 5G that appears to have a series of forms outlining the hand, again all from exhibit 357, your Honor.

THE COURT: All right.

MR. KELBERG: Doctor, again, with the Court's permission, can you step down, and yesterday we did not get into the specifics of where each of these injuries are, if they are described, et cetera, so I would like to do that now. Let's start if we could going photograph by photograph, doctor. I believe you started yesterday with photograph G-35?

DR. LAKSHMANAN: Okay.

MR. KELBERG: Is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let's take those injuries and go through the process of the protocol, the diagram, the addendum.

DR. LAKSHMANAN: Yes. G-35 shows a 5/8 inch cut in the web between the index and middle finger of the right hand on the palmar aspect.

MR. KELBERG: Is that designated arbitrarily by you as injury no. 1?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And that is described by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it diagrammed by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any reason he should have?

DR. LAKSHMANAN: To need to.

MR. KELBERG: All right. Now, injury no. 2 in that photograph?

DR. LAKSHMANAN: That is present in the palmar aspect of the hand, of the right hand, near the base of the thumb, and it measures--a y-shaped wound, and it is addressed in the protocol. It is addressed in the diagram. It was accurately defined in the reports and there was no addendum report prepared.

MR. KELBERG: Keep your voice up, if you would, please, doctor. As I recall, you said those were the only two injuries you observed in photograph G-35?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is it accurate to say that the injury that is seen in photograph G-34 is injury no. 1 that you have discussed in G-35?

DR. LAKSHMANAN: That is correct. There were--the only reason the wound looks a little more gaping and bigger is because the index finger and the middle finger have been pried open so that the wound can be better visualized.

MR. KELBERG: Doctor, where in the protocol are injuries 1 and 2 described?

DR. LAKSHMANAN: Page 11, no. 1 and 2. no. 1 and 2.

MR. KELBERG: Under "Sharp force injuries of hands"?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Which is injury no. 1?

DR. LAKSHMANAN: This is--on page 11, no. 1, is the injury no. 1 and page 11, no. 2, is injury no. 2.

MR. KELBERG: And your Honor, I'm going to outline in blue each of these, write at the side "G-35 inj."--I'm sorry, is it 35?

DR. LAKSHMANAN: Yes.

MR. KELBERG: "Inj. no. 1" and another one I will outline in blue and that is going to be "G-35 inj. no. 2," and I will also, for the G-35 no. 1, write semicolon "G and G-34" and a line underneath that to separate.

MR. KELBERG: Is that accurate, sir?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, are those descriptions in your opinion that are provided by Dr. Golden accurate on those two injuries?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where are they diagrammed, if at all?

DR. LAKSHMANAN: The diagram is 23-III.

MR. KELBERG: So if we ask Mr. Lynch to get us to that--

DR. LAKSHMANAN: The right lower quadrant you can see both the injuries, incise wound, length, 3/4 inch, length half-inch deep, subcu. This wound is a y-shaped wound, depth is 1/4 inch and half-inch dimensions.

MR. KELBERG: Doctor, you have to keep your voice up if you would, please. Injury no. 1--first of all, just circle the area, if you would, that is covered by that?

DR. LAKSHMANAN: (indicating).

MR. KELBERG: For the record, your Honor, I will circle that same area in blue on that area of the lower right quadrant. I will write "G-35 inj., no. 1, and G-34."

MR. KELBERG: And doctor, is that handwritten entry that you just read basically the same as what appears in the dictation?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, the second injury is outlined in what area?

DR. LAKSHMANAN: The same diagram of the right hand, in whole area here is injury no. 2, (indicating).

MR. KELBERG: Doctor, is this little inverted y, what appeared to be an inverted y of some significance to you?

DR. LAKSHMANAN: Well, it shows the appearance of the wound as you see it in the photograph.

MR. KELBERG: Is that a diagram that was made by Dr. Golden in the course of the autopsy?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where you have circled that area, let me do the same with the blue and I will write down at the bottom "G-35 inj. no. 2."

MR. KELBERG: Doctor, there appears to be some writing to the left of the schematic and some lines that run from that writing. What is that?

DR. LAKSHMANAN: Just says there are two Defense wounds.

MR. KELBERG: Do you agree with Dr. Golden's assessment that injuries 1 and 2 are in fact Defense wounds?

DR. LAKSHMANAN: Yes.

MR. KELBERG: As you testified yesterday?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me just circle that and in blue and I will put a line running to each of the two areas that we have previously just circled.

MR. KELBERG: All right, doctor. Are we done with injuries 1 and 2 of G-35?

DR. LAKSHMANAN: Yes, we are.

MR. KELBERG: All right. Let's go back then, if we could, I believe the next photograph you looked at was G-34; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: How many injuries do you identify in there?

DR. LAKSHMANAN: I identified 12.

MR. KELBERG: All right. Let's try and take them individually and cover the protocols, diagrams, addendums as we go so that we don't--at least I don't get lost. Let's start with what you have arbitrarily numbered injury no. 1.

DR. LAKSHMANAN: Injury no. 1 is an abrasion to the ulnar aspect of the right wrist here, (indicating).

MR. KELBERG: Keep your voice up please.

DR. LAKSHMANAN: Right here in the ulnar aspect of the right wrist, (indicating).

MR. KELBERG: Is that antemortem?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that described in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it diagrammed?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any reason to?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's find out where in the protocol and which diagram.

DR. LAKSHMANAN: Page 11 and 12, no. 1.

MR. KELBERG: Under "Other injuries to hands and upper extremities"?

DR. LAKSHMANAN: Yes.

MR. KELBERG: We are on page 11 board 0G. Let me outline this and I'm going to write "G-32 inj. no. 1" and see if we can flip the page.

MR. KELBERG: And it ends before the no. 2?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Let me outline that again and I will write the same information, "G-32 inj. no. 1."

MR. KELBERG: Doctor, is Dr. Golden's description in his protocol accurate, in your opinion, of that particular abrasion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where is it diagrammed, if at all?

DR. LAKSHMANAN: It is diagrammed on 21-I.

MR. KELBERG: And Mr. Lynch is--

MR. KELBERG: All right. Doctor, would you identify where on that particular item--and I will get the board number designation when we pull it down, your Honor.

DR. LAKSHMANAN: Right here. It is a diagram that is 3/4 inch by half an inch ulnar red brown not patterned abrasion, this injury right here, (indicating), the whole injury.

MR. KELBERG: And is there some designation on the form of the body as to its location?

DR. LAKSHMANAN: Yes, ulnar.

MR. KELBERG: I'm sorry, there is an actual diagram on some part of the body to show what it is that Dr. Golden is referring to?

DR. LAKSHMANAN: Here, (indicating).

MR. KELBERG: Where there appears to be almost a circular heavy black outlined area?

DR. LAKSHMANAN: Yes.

MR. KELBERG: For the record, your Honor, then I will circle this area on 21-I and write "G-32 inj. no. 1."

DR. LAKSHMANAN: And actually this also would belong to the same injury because it is in the distal forearm wrist area.

MR. KELBERG: What do those word say?

DR. LAKSHMANAN: "Distal forearm."

MR. KELBERG: So all of that goes with this injury no. 1?

DR. LAKSHMANAN: Yes, yes.

MR. KELBERG: All right. I will circle that and I will connect these two areas with a solid blue line.

MR. KELBERG: Anywhere else that that is diagrammed, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Let me take this board down. That is 3-G, your Honor.

MR. KELBERG: Are we done basically then with injury no. 1 of G-32?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Let's go back and see what injury no. 2 is.

DR. LAKSHMANAN: Injury no. 2 is 5/16 inch by 1/16 inch abrasion over the back of the right wrist and I'm pointing to it right here.

MR. KELBERG: Is that addressed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it diagrammed?

DR. LAKSHMANAN: Yes, it has been diagrammed.

MR. KELBERG: And is it addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Which diagram, doctor?

DR. LAKSHMANAN: The same diagram, 23-III, (indicating).

MR. KELBERG: You are pointing in the upper right quadrant to an area. Is there some writing that you associate with that entry?

DR. LAKSHMANAN: Yes. It says, "Half an inch superficial"--I can't read this word. Could be--

MR. KELBERG: Keep your voice up.

DR. LAKSHMANAN: I can't read this particular letter here, but this is "Superficial" and "Half an inch" and these injuries are--

MR. KELBERG: Where the doctor has just outlined with the pointer, your Honor, I will circle that in blue and write "G-32 inj. no. 2."

MR. KELBERG: Doctor, in your opinion was it a mistake for Dr. Golden not to include a description of that injury in his protocol?

DR. LAKSHMANAN: Well, yes.

MR. KELBERG: Is it of any significance to you?

DR. LAKSHMANAN: No.

MR. KELBERG: For the same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is there any reason he should have addressed it in the addendum, given that he did not describe it in the protocol?

DR. LAKSHMANAN: He could have, but he didn't.

MR. KELBERG: Is that a mistake?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any significance?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything more about injury no. 2?

DR. LAKSHMANAN: Nothing more.

MR. KELBERG: Let's go to injury no. 3.

DR. LAKSHMANAN: Injury no. 3 is a 3/4 inch by one inch contusion to the right hand knuckle at the base of the middle finger here, (indicating), and let's see--

MR. KELBERG: Is that addressed in the original protocol?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Is it diagrammed?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Is there any area of the addendum to which it is addressed?

DR. LAKSHMANAN: No.

MR. KELBERG: Any reason it should have been?

DR. LAKSHMANAN: Not necessary.

MR. KELBERG: Before we go to that, doctor, just one follow-up on this. You testified yesterday that it was of significance to you that the original--in deciding whether or not Mr. Goldman's hand had been closed into a fist and delivering a blow, that the only contusion you saw, without a punctate abrasion centered over the contusion, was to that knuckle; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Can you point out which other knuckles you would have expected to see a contusion if in fact Mr. Goldman had delivered a direct blow to the face, for example, of the perpetrator?

MR. SHAPIRO: Objection, calls for speculation.

THE COURT: Sustained. Rephrase the question.

MR. KELBERG: Doctor, you indicated that you had reviewed, among other material, literature from a sports medicine publication on boxing injuries; is that correct?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: Have you also, as part of your training and experience, studied blunt force trauma injuries received to hands of people who have struck faces of other individuals?

DR. LAKSHMANAN: Yes, I have.

MR. KELBERG: From that have you formed opinions as to the kind of injuries in the form of blunt force trauma contusions one expects to see when a fisted hand delivers a direct blow to the face of another human being?

DR. LAKSHMANAN: Yes.

MR. KELBERG: In your opinion why--withdraw that frame of the question and frame it this way: Point out where you would have expected to see additional areas of contusion, if any, had Mr. Goldman's hand been closed into a fist delivering a direct blow to the face of the perpetrator?

DR. LAKSHMANAN: I would expect to see contusion in the adjoining knuckles and also the adjoining portion of the phalanges, which we don't see here. We only see localized to one knuckle here, (indicating). And the other issue is also that the other injuries in the other fingers show to be abrasion contusions, so the only pure contusion is to one knuckle, which seems a rather unusual. If it was a closed fist which delivered a direct blow to a person, I would expect to see more injuries to the other knuckles, especially the fourth and fifth knuckles and the adjoining--adjoining proximal phalanges. You see, after all, the closed fist is like this, and if somebody is going to give you a direct blow, you would expect to see injury on this knuckle, adjoining knuckles and the adjoining phalanges. And this particular hand only shows a bruise to a knuckle without any abrasion on it, and of course the other injuries show abrasion contusions which do not follow the pattern you see in such a scenario.

MR. KELBERG: You don't expect to see the abrasion on top of the contusion from a blunt force trauma from a fist to the face of another human being?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: And that I think you indicated is part of the basis of your opinion as to why you also believe it was from a flailing into some of the trees and surrounding areas where Mr. Goldman's body was found?

DR. LAKSHMANAN: That is correct, and I also indicated yesterday that the lack--the lack of sharp force injuries to the back of the hands favor that opinion, because the sharp force injuries, as we discussed, are onto the front of the hand, and further, there is no other sharp force injuries which I could see in the forearm either.

MR. KELBERG: Doctor, let's go to the protocol. Where is injury no. 3, that contusion, addressed?

DR. LAKSHMANAN: It is addressed on page 12, no. 3.

MR. KELBERG: We are on page 12?

DR. LAKSHMANAN: No. 3, second sentence: "On the proximal knuckle of the right middle finger is a one inch by 3/4 inch bruise with no overlying abrasion."

MR. KELBERG: Is that the extent of the description?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that then on board 0G and I will write to the side "G-32 inj. no. 3."

MR. KELBERG: Is that an accurate description, doctor?

DR. LAKSHMANAN: Yes. And it is here on 23-III, right here, (indicating), same knuckle, "Fresh bruise, one inch by 3/4 inch" and you can circle it.

MR. KELBERG: You have outlined it with your pointer. Let me ask, before I circle it, there appears to be a circled area with some squiggly lines inside, the circle and a line running horizontally to the outside of this handwritten entry. What is this circled area with the wavy lines to reflect?

DR. LAKSHMANAN: It is diagrammatically depicting the injury that you see in the photograph and which has been dictated as such on the protocol and that is the measurement there, (indicating).

MR. KELBERG: All right. Let me outline that then, this upper right quadrant with the board 2-3 and I will write out at the side "G-32 inj. no. 3."

MR. KELBERG: Anything else regarding this injury, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to injury no. 4.

DR. LAKSHMANAN: Injury no. 4 is 1/32 inch punctate abrasion in the base of the right index, which is a small one right here, (indicating).

MR. KELBERG: So this is on the index finger at the base?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that addressed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it diagrammed anywhere?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: And I think we are going to lose our easel in just a second, if we could have a moment, your Honor.

(Brief pause.)

MR. KELBERG: Doctor, in your judgment, all mistakes by Dr. Golden not to have described, diagrammed or addressed in the addendum?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Individually or collectively of any significance to you on the big ticket issues?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Let's to go injury no. 5.

DR. LAKSHMANAN: Injury no. 5 is a linear diagonally-running abrasion half an inch to the back of the right index next to the small abrasion I just described. It is on the back of the right index here, (indicating).

MR. KELBERG: So we are working our way along the length of the first finger towards the nail area; is that correct?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: All right. Is that linear abrasion addressed in the protocol?

DR. LAKSHMANAN: Yes. Same page, 12, fourth sentence here, (indicating), on the--it says: "There is a linear diagonally half an inch reddish brown abrasion."

MR. KELBERG: Doctor, is that whole sentence to refer to that particular injury no. 5?

DR. LAKSHMANAN: Yes. It also includes the bruising you see there near the--on the proximal phalangeal joint.

MR. KELBERG: Doctor, do you identify that bruising as a separate injury or is that, in your opinion, a part of injury no. 5?

DR. LAKSHMANAN: I described it as a separate injury, but it could have been part of the same force which caused that other injury there.

MR. KELBERG: As long as we are here, is the next injury by your numbering system injury no. 6, what is described here as the fresh bruise?

DR. LAKSHMANAN: Yes.

MR. KELBERG: So if I outline this entire sentence, would it be accurate to say that this concerns G-32, inj. numbers 5 and 6; is that correct?

DR. LAKSHMANAN: It would be the--that's correct. Just one second.

(Brief pause.)

DR. LAKSHMANAN: Yes, fourth sentence. One, two--yeah, fourth sentence, yes.

MR. KELBERG: Keep your voice up, please, doctor.

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, is either injury 5 or 6 diagrammed?

DR. LAKSHMANAN: It is right here, (indicating).

MR. KELBERG: And where--is there an area where it is actually drawn in in some fashion on the schematic?

DR. LAKSHMANAN: You can see it being drawn in right here on the index finger here has a linear thing and then you have the bruise next to it.

MR. KELBERG: And is there any written description provided by Dr. Golden for that particular--this would be injuries 5 and 6?

DR. LAKSHMANAN: Yes. You have a line going from there and this is the description for that.

MR. KELBERG: What is written by Dr. Golden there?

DR. LAKSHMANAN: It says: "Half an inch by half an inch reddish brown abrasion and fresh bruise." And then he has also diagrammed the abrasion here, (indicating), length, half an inch separately, which corresponds to this, so actually the description for this injury would include this handwriting here and this handwriting there, (indicating).

MR. KELBERG: Would it be accurate to say, doctor, that this handwriting on the left of the first finger refers to what you have described as injury no. 5, the abrasion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And what Dr. Golden has written as fresh bruise is referring to what you described as injury no. 6?

DR. LAKSHMANAN: Yes.

MR. KELBERG: For the record, I will circle in red this entire area that Dr. Lakshmanan has just talked about. On the upper right quadrant diagram of 23 roman numeral III, I will write "G-32 inj. numbers 5 and 6."

MR. KELBERG: Anything else in the way of a diagram for either of those two injuries, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything on the addendum either?

DR. LAKSHMANAN: No.

MR. KELBERG: I don't think you have actually shown us injury no. 6. Why don't do you that.

DR. LAKSHMANAN: It is here on the bruise on the index finger, proximal interphalangeal joint.

MR. KELBERG: And again this would be in keeping with a numbering system, if you will, where you are going along the length of the index finger, the first finger, excuse me, towards the nail; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What is injury no. 7 then?

DR. LAKSHMANAN: It is a discolored area on the nail which is a scraping and it measures 3/8 of an inch in area, and I'm pointing to it here, (indicating).

MR. KELBERG: This, doctor, again a photo you reviewed, life-size photo, for your purposes of measuring?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Are you able to tell, doctor, whether that injury occurred during the circumstances of this incident on Bundy on June 12th or whether it occurred at some earlier time?

DR. LAKSHMANAN: It is difficult to say when you have a nail injury, because the nail injuries, unlike skin injuries, do not leave a reaction and there was no hemorrhage which I could see, so I can't tell when that happened, but taking in conjunction with the other injuries, it probably could have happened at the same time, but I can't tell.

MR. KELBERG: Doctor, does Dr. Golden address that nail injury in any fashion?

DR. LAKSHMANAN: No, he does not.

MR. KELBERG: Does it diagram it in any way?

DR. LAKSHMANAN: No, he does not.

MR. KELBERG: Does he address it in the addendum?

DR. LAKSHMANAN: No, he does not.

MR. KELBERG: Do you consider each of those to be a mistake?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Individually or collectively of any significance to you?

DR. LAKSHMANAN: No.

MR. KELBERG: Why not?

DR. LAKSHMANAN: Because as I told you, it has no bearing on the cause of death, my ability to discuss the sharp force injuries, what type of weapon, the bleeding patterns or any of the other issues which I have addressed previously many times on the injuries.

MR. KELBERG: How about injury no. 8 then?

DR. LAKSHMANAN: Injury no. 8 is a 1/8 inch abrasion over a pink contusion just above the base of the right middle finger, right here, (indicating).

MR. KELBERG: Is this one of these abrasion contusions you were referring to as being the cause, in your opinion, from contact with a rough surface like the tree?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, is this addressed in the original protocol?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Is it diagrammed?

DR. LAKSHMANAN: Yes, but the--in the original protocol he has addressed it as an index finger but actually it is the middle finger. He has diagrammed it correctly.

MR. KELBERG: All right. Let's see exactly what has been done here. Why don't we start with the diagram.

DR. LAKSHMANAN: Okay.

MR. KELBERG: Is it on this same form?

DR. LAKSHMANAN: Yes, right here, (indicating). You can see it as right here, the middle finger, you have an abrasion in the middle, which is 1/8 inch here, and you can see bruise half an inch by half an inch width abrasion, so this whole area reflects the injury no. 8 which I just showed you in the photograph there.

MR. KELBERG: Doctor, has Dr. Golden specifically drawn diagrammatically on the outline of the hand, and in particular the middle finger, to show that this is in fact an abrasion sitting in the middle of this contusion?

DR. LAKSHMANAN: Yes, he has. He has very accurately described it. You can see the abrasion in the middle which is dense compared to the rest of the injury here.

MR. KELBERG: Where you have just pointed, the area of the abrasion, I'm going to circle that in red and then I'm going to circle the entire area that you have just described in blue, and make a line going to the top of the diagram and write "G-32".

MR. KELBERG: This is now injury no. 8, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Where is it described in the protocol?

DR. LAKSHMANAN: It is actually on page--third sentence, and injury no. 8 should be the middle finger, but just an error here with the index finger. It says "Index finger" here, (indicating).

MR. KELBERG: All right. First of all, is there an entire sentence to refer to what you've identified as injury no. 8?

DR. LAKSHMANAN: Yes, umm, to the semicolon part.

MR. KELBERG: All right. Let me outline that in red and write to the right "G-3 2 inj. no. 8." And in your opinion, doctor, the identification of the finger as an index finger is an error on the part of the Dr. Golden?

DR. LAKSHMANAN: If he dictated it as such, yes.

MR. KELBERG: As it is drawn, it is drawn on the middle finger?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And as you see it in the photograph, is it the middle finger?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me circle or underline the word "Index" in blue within this area and then I will draw a line in red out to the side and write "Should be middle, see diagram."

MR. KELBERG: Doctor, is this mistake of indicating "Index" rather than "Middle" of any significance to you on the big ticket questions?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: All right. Are we done with injury no. 8?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: What is injury no. 9?

DR. LAKSHMANAN: Injury no. 9 is a small--

MR. KELBERG: If I could just a moment, your Honor.

(Discussion held off the record between the Deputy District Attorneys.)

MR. KELBERG: I'm sorry. Thank you, your Honor.

MR. KELBERG: Injury no. 9, please, doctor?

DR. LAKSHMANAN: Injury no. 9 is a small 1/8 inch abrasion just a little bit away from the injury I just described on the middle finger. It is a little more distal.

MR. KELBERG: Doctor, in looking at the diagram, 23-III, do you see a diagram by Dr. Golden?

DR. LAKSHMANAN: Very accurately diagrammed as 1/8 inch abrasion here.

MR. KELBERG: And he has written in some identification for that?

DR. LAKSHMANAN: Yes, here, (indicating), and he has drawn a line and shown it accurately so that he has--

MR. KELBERG: Doctor, does he describe it in the protocol?

DR. LAKSHMANAN: Yes, he does, and that has been described accurately here. After the semicolon which we just described it says: "Just distal to the middle phalange of the middle finger is a one-inch nondescript abrasion."

MR. KELBERG: Your Honor, first of all, on the diagram that Dr. Lakshmanan was outlining with the pointer, I will circle in red and I have a very short line reading "G-32 inj. no. 9."

MR. KELBERG: Doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And an arrow going to that outlined area.

MR. KELBERG: And then, doctor--and your Honor, for the record, I will outline the rest of that sentence and put a line out to the side, "G-32 inj. no. 9." Anything further on that injury, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to injury no. 10.

DR. LAKSHMANAN: Injury no. 10 is a 1/8 inch abrasion overlaying the contusion near the middle of the ring finger here, (indicating).

MR. KELBERG: Doctor, is this again one of these abrasion contusions which in your opinion is due to contact with a rough surface like the tree?

DR. LAKSHMANAN: That is correct. That is my opinion.

MR. KELBERG: And inconsistent with what kind of abrasion--I'm sorry--what kind of blunt force trauma you would expect if a blow from a closed fist of Mr. Goldman to the head or face of the perpetrator?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: Is this addressed in the original protocol?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Is it diagrammed?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Is it addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any reason it should have been?

DR. LAKSHMANAN: Not necessary to do that.

MR. KELBERG: Let's see where it is.

DR. LAKSHMANAN: It is--it is on page 12, paragraph no. 3, paragraph 2 here, (indicating).

MR. KELBERG: Is that entire paragraph to refer to that injury?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that.

DR. LAKSHMANAN: Actually it also includes injury no. 11.

MR. KELBERG: All right. Let's stop with the part that is injury no. 10. You tell me where it stops.

DR. LAKSHMANAN: "Half an inch by half an inch bruise on the right ring finger surrounding two punctate abrasions approximately 18 inch in maximal diameter."

MR. KELBERG: Is that the part that completes injury no. 10?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that in red and I will write to the side on the left "G-32 inj. no. 10."

MR. KELBERG: While we are here then, what does the rest that have sentence refer to, or paragraph?

DR. LAKSHMANAN: That refers to the fifth finger, but he has included injury no. 11 which we saw in my description--in my description in the same sentence.

MR. KELBERG: And injury no. 11, as you identify it, is what?

DR. LAKSHMANAN: Injury no. 11 is a punctate abrasion which is next to the injury no. 10 in the photograph. You can see it here, (indicating).

MR. KELBERG: Doctor, would it be accurate to say that you see on that finger two punctate abrasions?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And you see a contusion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And that you find that one of the punctate abrasions rests on the contusion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And collectively that is what you describe as injury no. 10?

DR. LAKSHMANAN: I described as injury no. 10 and I described the other abrasion as injury no. 11.

MR. KELBERG: So the second punctate abrasion you've identified as injury no. 11?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And then for the record, your Honor, where Dr. Golden has written "Two punctate abrasions," I'm going to box that in blue and write down below "G-3 2 inj. numbers 10 and 11."

MR. KELBERG: Doctor show us, please, on the diagram, if there is an entry made by Dr. Golden?

DR. LAKSHMANAN: It is on no. 23 on the diagram, if we turn the page.

MR. KELBERG: And I've turned the page to the first diagram.

DR. LAKSHMANAN: It is diagrammed as the ring finger properly. It describes a bruise. It describes the two abrasions which are punctate 1/8 inch, and the whole area you can reflect that they were present, injury 11 and 10 of photograph G-32.

MR. KELBERG: Let me outline that then.

MR. KELBERG: And has Dr. Golden actually diagrammed on this form the appearance of the punctate abrasion?

DR. LAKSHMANAN: Yes, he has. You can see them here, one, and the other one here, (indicating), on the bruise itself.

MR. KELBERG: And in the area I circled I will write "G-32, inj. numbers 10 and 11." Anything further about those two injuries, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's--I think you said there were 12 in this photograph; is that correct?

DR. LAKSHMANAN: Yeah. 12 is the small abrasion to the ring--I mean to the little finger here, (indicating).

MR. KELBERG: Is that addressed in the protocol?

DR. LAKSHMANAN: Yes, it is, and it is the last sentence here on page 12, no. 3, paragraph 3, last sentence.

MR. KELBERG: Let me outline that in blue and I will write "G-32 inj. no. 12." Is this also diagrammed, doctor?

DR. LAKSHMANAN: Yes. You can see it here, 23-III--23-I, you can see it here, 1/16 abrasion.

MR. KELBERG: Doctor, is the source or sources of that abrasion consistent with the environmental surroundings you saw on those photographs?

DR. LAKSHMANAN: Yes, I do.

MR. KELBERG: Does that include the ground?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And the rough surface of the tree?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me circle that area, I will do it in blue, on the chart, and I will write out at the side "G-32 inj. no. 12."

MR. KELBERG: Doctor, in your opinion has Dr. Golden, with respect to each of the injuries that you have seen in the photograph, G-32, and which he describes in the protocol, with the exception of the wrong finger on the one injury, which is injury no. 8, has he accurately described each of the injuries?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And in your opinion has he accurately diagrammed, as to those that he has diagrammed, all of the injuries you see in that photograph?

DR. LAKSHMANAN: Yes, he has.

MR. KELBERG: Is there anything further about that photograph and that series of 12 injuries?

DR. LAKSHMANAN: No.

MR. KELBERG: Your Honor, I'm not sure when the Court wanted to take a break.

THE COURT: 10:30.

MR. KELBERG: Thank you.

MR. KELBERG: All right. Doctor, let's go then--I believe we move next to G-28, if I'm not mistaken. Is that correct?

DR. LAKSHMANAN: Yes. Yesterday that is what we did.

MR. KELBERG: And then G-29, both of these are photographs of the palm surface of the left hand?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let's start with 28, identifying specifically any injuries you see.

DR. LAKSHMANAN: G-28, I went over the sharp force injuries to the base of the thumb and the base of the little finger here, (indicating), not base actually, it is more on the palm of the hand near the same area as the base of the little finger, and we also discussed an abrasion to the tip of the left thumb and we also discussed a linear abrasion to the base of the left--left thumb.

MR. KELBERG: Doctor, is that abrasion or those other abrasions, I think you talked about abrasions that can be inflicted if Mr. Goldman attempted to grab the knife and the knife rotated against--

DR. LAKSHMANAN: Not this abrasion, (indicating). This is a scrape type abrasion which could be--it is nonspecific.

MR. KELBERG: That abrasion, for the record, is the one that appears to be near the end on where the nail is of the thumb on the palmar surface, though, correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Was it consistent with any of the other--any other abrasion you saw?

DR. LAKSHMANAN: No. Even this linear abrasion could have a--it is a nondescript linear abrasion which could be from a rough surface.

MR. KELBERG: Keep your voice up, please.

DR. LAKSHMANAN: Rough surface from the plant material, trying to hold it or trying to brace yourself.

MR. KELBERG: Now, doctor, have you arbitrarily numbered these injuries?

DR. LAKSHMANAN: Yes, I have. The left thumb, the one near the tip, I call injury no. 1.

MR. KELBERG: Let's take care of that one. Is it addressed in the protocol?

DR. LAKSHMANAN: Not in the main protocol, it is not described on the diagram; it is only addressed in the addendum.

MR. KELBERG: I think we have the addendum right here, board 10G, if we could put it over the protocol for just a second.

MR. KELBERG: Where in the addendum, doctor?

DR. LAKSHMANAN: Page 5, no. 16. Number here, "Distal phalange of the left thumb, 3/8 by 1/16 abrasion."

MR. KELBERG: Is this an accurate description, in your opinion, of what you see in photograph G-28, injury no. 1?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline this in the addendum in red and I will put "G-28, inj. no. 1."

MR. KELBERG: Doctor, again, would these be mistakes on the part of Dr. Golden not to have addressed it originally in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And not to have diagrammed it?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Are they of any significance individually or collectively?

DR. LAKSHMANAN: Not in the big picture items which we have discussed.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Are we done with injury no. 1?

DR. LAKSHMANAN: Yes.

MR. KELBERG: How about injury no. 2?

DR. LAKSHMANAN: Injury no. 2 is that linear abrasion in the base of the thumb here, (indicating). You can see it here running.

MR. KELBERG: Is that addressed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: In the diagrams anywhere?

DR. LAKSHMANAN: No.

MR. KELBERG: In the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: All mistakes?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any of them of significance individually or collectively?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything more to say about injury no. 2?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to injury no. 3.

DR. LAKSHMANAN: Injury no. 3 is a cut to the base of the thumb--

MR. KELBERG: Keep your voice up, if you would.

DR. LAKSHMANAN: A cut to the base of the thumb half an inch in length.

MR. KELBERG: Is this a defensive wound, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And in fact would you describe the other two as defensive wounds?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Is that injury no. 3 addressed in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where?

DR. LAKSHMANAN: Page 11, no. 3. Right here, page 11, no. 3: "Palmar surface of the left hand, the web of the thumb, there is a 3/4 of an inch cutting wound involving the skin and subcutaneous tissue, quarter inch deep with hemorrhage in the margins. This is comparable with the Defense wound," the whole paragraph.

MR. KELBERG: Doctor, is this paragraph, in its entirety, in your opinion, accurate in its description and opinion as to the type of injury that injury no. 3 of G-28 is?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that on our board 0G. I will do it in red and I will write out at the side "G-28 inj. no. 3."

MR. KELBERG: Is that injury no. 3 diagrammed, doctor?

DR. LAKSHMANAN: It is diagrammed in 23-I here, (indicating).

MR. KELBERG: All right. Would you identify, please, for us, where it is diagrammed and what, if any, writing is associated with it?

DR. LAKSHMANAN: It is diagrammed at the base of the thumb. It says: "3/4 inch incise wound, web of thumb, skin subcu quarter inch deep hemorrhage."

MR. KELBERG: What does "Subcu" mean, doctor?

DR. LAKSHMANAN: Subcutaneous tissue.

MR. KELBERG: "Subcutaneous" is a fancy word for saying what?

DR. LAKSHMANAN: The skin underlying the skin.

MR. KELBERG: What does that mean?

DR. LAKSHMANAN: The wound is quarter inch in.

MR. KELBERG: Is that consistent with subcutaneous?

DR. LAKSHMANAN: Yes, it could be reaching the subcutaneous tissue at that point.

MR. KELBERG: Let me circle the area on 23-I, again board 5G, and I will write "G-28 inj. no. 3."

MR. KELBERG: Is the diagram and the description along with it accurate, in your opinion, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything further about injury no. 3?

DR. LAKSHMANAN: No.

MR. KELBERG: Any further injuries on photograph G-28?

DR. LAKSHMANAN: It also shows the portion of the sharp force injury to the palm I discussed earlier, but I have described it under G-29 actually.

MR. KELBERG: All right. Anything else for G-28?

DR. LAKSHMANAN: No.

MR. KELBERG: Your Honor, do you wish to start on G-29 or--

THE COURT: Go ahead.

MR. KELBERG: Let's start with injury no. 1 then, however, you have designated it on G-29?

DR. LAKSHMANAN: On G-29 I started with the--this same wound which I discussed in G-28. It is injury no. 1 in my description, and it is 5/8 of an inch in length and it curves in its ulnar aspect here, (indicating), and--

MR. KELBERG: Ulnar aspect again, doctor, is toward the pinkie or little finger side?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Is that addressed in the original protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it diagrammed anywhere?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it addressed in the addendum?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Let's get the addendum. I think we will switch here for just a second. Let's put this up on this side.

MR. KELBERG: Where in the addendum, doctor?

DR. LAKSHMANAN: Page 4, no. 13.

MR. KELBERG: If I could ask Mr. Lynch to join me here.

DR. LAKSHMANAN: No. 13 says: "Palmar surface of the left hand, ulnar aspect, transversely oriented wound, 5/8 inch in length."

MR. KELBERG: Is this an accurate, description, in your opinion, of what you see in that photograph?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that in red and I will write "G-29 inj. no. 1."

MR. KELBERG: Doctor, again a mistake not to address it originally in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Not to diagram it?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Singularly, collectively, any significance to you?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right.

THE COURT: One more.

MR. KELBERG: Okay. Injury no. 2 of photo G-29. Let me take this down, if I could, please. I got the photo.

DR. LAKSHMANAN: Injury no. 2 is located on the little finger and you see it here. It is a 3/8 inch by quarter inch abrasion in my measurement of the one-as-to-one photograph with the skin being peeled off with a flap of peeled skin seen here. I'm pointing to it, (indicating).

MR. KELBERG: Is the fact you see a flap of peeled skin of significance to you in identifying how that injury came to be inflicted?

DR. LAKSHMANAN: As I mentioned earlier yesterday, I felt that it could be related to this cut in the left palm of the hand when the knife was--there was an attempted probable grabbing of the knife and with the knife turning, this skin could have been peeled off. That is one way it could have occurred, because if you look at the flap of the skin, it looks like very thin flap which has come off of the surface.

MR. KELBERG: Is the direction of the flap of some significance to you in evaluating the direction of the force which has created that abrasion?

DR. LAKSHMANAN: Yes. It would mean two things: Either the skin moved in a fashion towards the wrist, the hand moving in this manner, (indicating), on the--

MR. KELBERG: Downward?

DR. LAKSHMANAN: Downward. Or the force which caused it moved upwards to the tip of the finger to peel the skin in such a manner that you have a flap of skin toward the distal aspect of the finger.

MR. KELBERG: For the record, your Honor, Dr. Lakshmanan used his right hand to move upward against the left palm of his--I'm sorry, the palm of his left hand.

THE COURT: Thank you.

DR. LAKSHMANAN: I just gave you one possible mechanism how it could have occurred.

MR. KELBERG: Was this addressed in the protocol, injury no. 2?

DR. LAKSHMANAN: No.

MR. KELBERG: Diagrammed?

DR. LAKSHMANAN: No.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: Yes, it has been.

MR. KELBERG: Let's throw the addendum back up and take care of this one. Where, doctor?

DR. LAKSHMANAN: It was a page on page 5, no. 15.

MR. KELBERG: Page 5, no. 15?

DR. LAKSHMANAN: 15, yes. It says: "The volar surface of the left fifth finger shows a superficial brown abrasion with a 3/8--measuring 3/8 of an inch by 3/8 of an inch with portions of avulsed skin."

MR. KELBERG: "Avulsed" is a fancy way of saying what, doctor?

DR. LAKSHMANAN: Peeled off.

MR. KELBERG: And "Volar" is the palm side of the hand?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is this an accurate description, in your opinion, of the injury no. 2 or is it injury 2 or 3?

DR. LAKSHMANAN: Yes, injury no. 2.

MR. KELBERG: That you see in that photograph G-29?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that in red on the board. This is 10G again, your Honor.

THE COURT: Yes.

MR. KELBERG: And I will write "G-29 inj. no. 2."

MR. KELBERG: Anything further about injury no. 2 of G-29?

DR. LAKSHMANAN: No, no.

THE COURT: All right. Ladies and gentlemen, we are going to take our recess, mid-morning recess. Please remember all of my admonitions to you. Don't discuss the case among yourselves, form any opinions about the case, allow anybody to communicate with you or conduct any deliberations until the matter has been submitted to you. We will take a 15-minute recess. All right.

(Recess.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Back on the record in the Simpson matter. All parties are again present. All right. Deputy Magnera, let's have the jurors, please excuse me, gentlemen.

(The following proceedings were held in open court, in the presence of the jury:)

THE COURT: All right. Thank you, ladies and gentlemen. Be seated. Doctor. And, Mr. Kelberg, you may resume concluding your direct examination.

MR. KELBERG: Thank you, your Honor.

THE COURT: You're welcome.

MR. KELBERG: Doctor, again, with the Court's permission, would you step to the board, and let's pick up with respect to these injuries to the hands.

(The witness complies.)

MR. KELBERG: And I think we're now on to, if there is an injury no. 3 of G-29, we're at that stage.

DR. LAKSHMANAN: Yes. The injury no. 3 is an area of abrasion injury to the palm of the hand in the middle finger and near the tip of the middle finger, there are about three abrasions there, one, two and three, and they measure approximately quarter inch by 1/16 inch and 3/8 inch and quarter inch by 1/16 inch, and that's injury no. 3.

MR. KELBERG: Have you marked that then collectively, these abrasions, as injury no. 3?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Do you have an opinion, doctor, as to the manner in which injury no. 3, these series of abrasions, were received?

DR. LAKSHMANAN: That's a nonspecific blunt force injury and it could be from scraping against any rough surface.

MR. KELBERG: Doctor, is this addressed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Diagrammed anywhere?

DR. LAKSHMANAN: No.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where in the addendum?

DR. LAKSHMANAN: Page 5, no. 14.

MR. KELBERG: Let me pull the board down this way so we can see the injury. And if Mr. Lynch can turn to page 5. Doctor, does that description in item 14 of page 5 accurately describe in your opinion what you have described as injury no. 3?

DR. LAKSHMANAN: No. It has been described collectively here, but actually there are--you can see three separate abrasions, but in the same area. So the report described abrasion collectively rather than individually.

MR. KELBERG: Are you able then to see that these are individual abrasions?

DR. LAKSHMANAN: Well, you can see the--there are some areas where they oppose each other, but they look like three separate areas of injury.

MR. KELBERG: When you say "They oppose each other," what do you mean?

DR. LAKSHMANAN: The margins oppose.

MR. KELBERG: They're opposite each other?

DR. LAKSHMANAN: They touch each other.

MR. KELBERG: Now, doctor, in your opinion, is it a mistake on the part of Dr. Golden to have described these in the addendum "Collectively" rather than to see them and describe them as individual abrasions?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And his mistake--I assume you find it to be a mistake of not including it in the protocol and a mistake of not diagramming it?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Collectively, individually, any significance to them?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: If Mr. Lynch could, because I think he's going to have a better chance maybe in blue, outline that area on the board, the addendum 10-G and then write out at the side, if you would, please, "G-29, inj. 3." And if you could write in quotation marks "Collectively."

(Mr. Lynch complies.)

MR. KELBERG: And may the record reflect that he has done so, your Honor?

THE COURT: Yes.

MR. KELBERG: All right. Doctor, anything further regarding injury no. 3?

DR. LAKSHMANAN: No.

MR. KELBERG: If we could ask Mr. Lynch then to take down the addendum. Let's go to--is there an injury no. 4 in the photograph of the palm of the left hand, G-29?

DR. LAKSHMANAN: No.

MR. KELBERG: So are we done with that photograph?

DR. LAKSHMANAN: Yes, we have.

MR. KELBERG: All right. Let's go to--I think we then talked about G-26 and then we had this smaller photograph that is B-25.

DR. LAKSHMANAN: Yes.

MR. KELBERG: And this is now the back of the left hand?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And the wrist and lower part of the arm?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Do you have again this arbitrary numbering system for injuries seen?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let's start with injury no. 1.

DR. LAKSHMANAN: Injury no. 1 is the contusion to the back of the hand with a small abrasion which is punctate overlying it.

MR. KELBERG: Doctor, is this again the same kind of contusion with punctate abrasion identified earlier on photograph G-32 in the area of the knuckles of the fingers?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is your opinion concerning the source for that abrasion contusion the same as you opined regarding the source or sources for the abrasion contusions to the fingers as seen in G-32?

DR. LAKSHMANAN: Could be one of the sources.

MR. KELBERG: In your opinion, doctor, is it inconsistent, however, with the source being a blow from Mr. Goldman's clenched fist to the face of the perpetrator?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Same reasons as you've previously expressed?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Is that diagrammed by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it addressed in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it addressed at all in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any reason it should have been?

DR. LAKSHMANAN: Not necessary to.

MR. KELBERG: Where in the protocol?

DR. LAKSHMANAN: It's page 12, no. 4.

MR. KELBERG: Keep your voice up, please, doctor.

DR. LAKSHMANAN: Page 12, no. 4.

MR. KELBERG: And point out, if you would, please, where on page 4, no. 4--page 12, no. 4 of board 0G.

DR. LAKSHMANAN: It's here on the last line, the last sentence of page 12, no. 4, there's a fresh bruise on the dorsal surface of the left hand surrounding a punctate abrasion.

MR. KELBERG: I'll outline that in red and we'll write in "G-26." And is it also seen in G-25, doctor, the small photograph or is it covered by the card?

DR. LAKSHMANAN: It's covered by the card on--

MR. KELBERG: The small photo is G-25.

DR. LAKSHMANAN: Okay. It's covered on G-25.

MR. KELBERG: All right.

DR. LAKSHMANAN: Partially covered. Partially covered.

MR. KELBERG: I'll write "G-26 inj. no. 1." Correct, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where is it diagrammed, if at all?

DR. LAKSHMANAN: It's diagrammed on I think 23-II or III I think. Can you turn--

MR. KELBERG: This is on 23-II of the board. I think it's 5-G?

MR. LYNCH: 5-G.

MR. KELBERG: Mr. Lynch confirms it's 5-G.

MR. KELBERG: All right. Doctor, is there some writing that goes along with this injury diagram?

DR. LAKSHMANAN: Yes. It says "Fresh bruise hemorrhage" and it says here--I'm sorry--one and a quarter inch by one inch. One and a quarter inch by one inch and "Punctate abrasion."

MR. KELBERG: And has Dr. Golden specifically diagrammed the abrasion to be in the center of what he has diagrammed to be the bruise?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that an accurate depiction of that injury?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: And is it an accurate description of that injury?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: All right. Let me circle this area in red and out at the side, "G-26 inj. no. 1." Anything further on that?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to no. 2 then if we could, please, doctor.

DR. LAKSHMANAN: No. 2 is the linear abrasion which is situated between the base of the index finger and the wrist which here this is about three-quarters of an inch in length in my measurement and it's also diagrammed and described.

MR. KELBERG: Doctor, is there any significance to you in the appearance of that linear abrasion?

DR. LAKSHMANAN: It's just a nonspecific linear abrasion.

MR. KELBERG: Do you have an opinion as to any source or sources for that?

DR. LAKSHMANAN: The same plant type environment which I described earlier in the crime scene photographs, the branches or one of them can do that kind of abrasion.

MR. KELBERG: Doctor, where is it diagrammed?

DR. LAKSHMANAN: It's again diagrammed in 33-II right here (indicating).

MR. KELBERG: What is the description if any given?

DR. LAKSHMANAN: It's--it's described in actually paragraph 2 here (indicating), and you can see it here on 3/4 inch long skin abrasion terminating 1/8 inch nondescript punctate abrasion, and this is the abrasion which is--

MR. KELBERG: Keep your voice up, please, doctor.

DR. LAKSHMANAN: --this is the abrasion which is diagrammed here and this is the punctate part of the linear abrasion.

MR. KELBERG: What is the significance, if any, to there being a punctate part of a linear abrasion?

DR. LAKSHMANAN: As I told you, this is a nondescript blunt force trauma. And let's assume that the hypothetical situation is, you have a small branch or sharp--not--semi-sharp, not sharp branch which strikes the portion of the skin. And you can get a punctate part of the abrasion caused by that, but when the hand moves, the branch will be drawing against the particular surface of the skin causing the linear appearance adjoining the punctate part.

MR. KELBERG: The hand in this hypothetical is sliding down in essence?

DR. LAKSHMANAN: Yeah. That will be one way it can be caused.

MR. KELBERG: Now, doctor--I'm sorry. Is it just that one sentence of item 4 of page 12 starting with "On the dorsal surface"?

DR. LAKSHMANAN: Yes. That whole sentence and it's diagrammed here (indicating).

MR. KELBERG: And is there a description given by Dr. Golden along with the diagram of the linear abrasion with the punctate?

DR. LAKSHMANAN: Yes. This whole sentence here (indicating).

MR. KELBERG: What does he say that?

DR. LAKSHMANAN: Length 3/4 inch skin abrasion. Then he says, abrasion 1/8 inch punctate, which is the lower part here (indicating).

MR. KELBERG: In your opinion, do these entries both on the protocol and on the diagram accurately describe and diagram that injury?

DR. LAKSHMANAN: Yes, they do.

MR. KELBERG: All right. Let me outline those, please, in red on page 12 of the protocol, and I'll write "G-26, inj. no. 2" is it, doctor?

DR. LAKSHMANAN: Yes. In my description, yes.

MR. KELBERG: All right. And I'll do the same over here and write out at the side "G-26 inj. no. 2." Anything further on that?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to no. 3 if there is a no. 3.

DR. LAKSHMANAN: Yes. No. 3 is abrasion which is described as "W" shape in the knuckle area at the base of the middle finger here (indicating).

MR. KELBERG: And that's an abrasion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is the appearance of it described as a "W" shape--first of all, is that an accurate description of it?

DR. LAKSHMANAN: Yes. If you look in the magnifying glass, you can see the middle limb of the "W", but if you look at it just from a distance, you can see it looks like a "V".

MR. KELBERG: Well, with the magnifying glass, you see all three limbs in the--

DR. LAKSHMANAN: Yes. You can see the--you can see a faint third limb there.

MR. KELBERG: Doctor, is there any significance to you of the "W" shape in forming any opinion if you have concerning the source or sources for that particular injury?

DR. LAKSHMANAN: It's a--it's a--it looks like a particular pattern, but I can't really tell a source for it. It's a nonspecific type of blunt force abrasion injury. It could be related to the same environment we discussed regarding the branches and the plant material there, but I can't really pinpoint a particular source to it.

MR. KELBERG: Described by Dr. Golden in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Diagrammed?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any need to?

DR. LAKSHMANAN: No.

MR. KELBERG: Where in the protocol?

DR. LAKSHMANAN: It's on page 12, no. 4. If you look at the first sentence, it starts--it's a long sentence on item 4, paragraph 2. There is an irregularly configured abrasion of the proximal knuckle of the left middle finger, apparently 3 linear half an inch abrasions converging at the center having a configuration of the letter "W". They're all superficial skin abrasions.

MR. KELBERG: Just for the record, you've left out a few words as you've read portions of that description; is that correct?

DR. LAKSHMANAN: Yes. I was just summarizing the main highlights of the description.

MR. KELBERG: Is it accurate in your opinion as you look at the abrasion in the photograph?

DR. LAKSHMANAN: Yes. It's described here "Superficial abrasion" and it's diagrammed and described there.

MR. KELBERG: Is that an accurate diagram, a diagrammatic depiction along with description in that 23-II?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that area then in both the protocol--I'll do that in blue. I'll write out at the right side "G-26 inj. no. 3" are we at, doctor, injury no. 3?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Okay. And I'll circle the same area you outlined in the upper left quadrant of 23-I and II in blue and write "G-26 inj. no. 3." Anything further about no. 3?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to no. 4 if there is one.

DR. LAKSHMANAN: Injury no. 4 is a punctate abrasion adjacent to the "W" abrasion I just described, and that has been diagrammed, but not described in the protocol.

MR. KELBERG: Where is it diagrammed, doctor?

DR. LAKSHMANAN: 23-I. It's diagrammed there, next to it.

MR. KELBERG: Is there any description provided?

DR. LAKSHMANAN: No.

MR. KELBERG: I want to be sure--I'd like you to circle if you would, doctor, in red, what you believe to be the diagrammatic depiction of this injury.

DR. LAKSHMANAN: The "W" or the smaller one?

MR. KELBERG: The smaller one.

(The witness complies.)

MR. KELBERG: And you've done that in red, and this is described by you as injury no. 4 of G-26?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, is this another depiction of that "W" shaped abrasion that you saw and outlined for us earlier on II?

DR. LAKSHMANAN: Yes. What he has done is, he diagrammed it in that diagram and again diagrammed it in this diagram, and in this diagram is included a measurement of each limb, half an inch.

MR. KELBERG: What--has he written anything besides the length of the measurement?

DR. LAKSHMANAN: He says skin abrasion, length, half an inch and letter "W" here (indicating).

MR. KELBERG: All right. I'm going to circle that in blue on I, form 23, and out at the side, I'll write "G-26 inj. no. 3." Is that correct, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And the area that--I'm sorry--that you circled-- this is actually injury no. 4. I believe I made a mistake.

DR. LAKSHMANAN: Yes. Injury no. 4.

MR. KELBERG: All right. Your Honor, for the record, I wrote no. 2. May I have the record reflect I'm taking the blue marker and covering over the no. 2, and in red I'll write the no. 4?

THE COURT: Yes.

MR. KELBERG: Anything else regarding that one, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's go to no. 5.

DR. LAKSHMANAN: No. 5 is a small abrasion the--as you can see, the base of the little finger here, very small one (indicating).

MR. KELBERG: Is that addressed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Diagrammed?

DR. LAKSHMANAN: No.

MR. KELBERG: In the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: All mistakes?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any significance?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any opinions regarding the source or sources for that small abrasion?

DR. LAKSHMANAN: It's the same, similar nonspecific blunt force trauma, same kind of scenario which can cause them as I discussed earlier like the environment.

MR. KELBERG: Is there an injury number--I think we're up to 6.

DR. LAKSHMANAN: Yes. And this is a quarter inch by 3/16 inch abrasion with a mild contusion near the base of the back of the index finger right here (indicating).

MR. KELBERG: All right. Now, you're pointing--that's our G-25. Is that injury seen in both G-25 and G-26?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And for the next series of injuries that we're going to look at, are we starting at the base of the first finger and working our way towards the nail of the first finger?

DR. LAKSHMANAN: I mean index finger, yes.

MR. KELBERG: I'm sorry. And is it accurate to say that G-25, the smaller photograph, shows more fully each of those injuries?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: All right. Tell us a bit about then injury no. 6.

DR. LAKSHMANAN: That's a quarter inch by 3/16 inch abrasion with a mild contusion near the base of the index finger.

MR. KELBERG: Is that something that in your opinion is consistent with being caused by a flailing and coming in contact with a rough surface like a tree?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Is that diagrammed somewhere?

DR. LAKSHMANAN: Yes, it is. It's diagrammed in 23-I.

MR. KELBERG: We have that up. Would you point out where that is, doctor?

DR. LAKSHMANAN: (indicating).

MR. KELBERG: And is there anything written alongside that?

DR. LAKSHMANAN: Just says "Punctate abrasion" there. "Punctate." Doesn't say "Abrasion." Just says "Punctate."

MR. KELBERG: Says "Punctate"?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that a completely accurate description of what you see in the photograph as injury no. 6?

DR. LAKSHMANAN: No. It doesn't describe the contusion as you can see in the photograph.

MR. KELBERG: Let me circle this area in red in the upper left quadrant, and I'll write "G-26, 25 inj. no. 6." Would it be a mistake to characterize it only as a punctate abrasion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that described in the protocol, injury no. 6?

DR. LAKSHMANAN: He has described all the injuries to the index finger collectively as one sentence in page 4--I mean page 12, no. 4.

MR. KELBERG: Would you show us using the photograph what Dr. Golden has described collectively?

DR. LAKSHMANAN: He has described the injuries to the different part of the index finger. You have an abrasion contusion. Let's go to G-25. You have abrasion contusion at the base of the index finger, one of the proximal interphalangeal joint, and then you have two abrasions distal to it on the middle phalanx.

MR. KELBERG: When you say "Distal," moving towards the finger?

DR. LAKSHMANAN: Tip of the finger, yes.

MR. KELBERG: Okay. I'm sorry. The nail I should say.

DR. LAKSHMANAN: Yes.

MR. KELBERG: So you have in your opinion a total of four injuries?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Is it a mistake in your judgment for Dr. Golden to have described these, as you pointed out on page 12 of the protocol under item 4, described them collectively rather than individually?

DR. LAKSHMANAN: Well, it is a mistake in the sense that he has not described them individually, but he has addressed them.

MR. KELBERG: In the way he addresses them, is that description accurate?

DR. LAKSHMANAN: The abrasion part of it is accurate, but as I told you, the injury no. 7 also has a contusion underlying it.

MR. KELBERG: How about diagramming? Before we mark in any fashion this collective description, has injury number--I think we're up to no. 6.

DR. LAKSHMANAN: No. 7 now.

MR. KELBERG: No. 7, has that been diagrammed?

DR. LAKSHMANAN: Yes, it is. You can see here (indicating).

MR. KELBERG: And you've got no. 7 and what subsequent one, doctor?

DR. LAKSHMANAN: I have 8 and 9 after that, and I've already shown them on the G-25 distal to no. 7.

MR. KELBERG: And does Dr. Golden diagram those injuries in the same schematic?

DR. LAKSHMANAN: He has diagrammed one single marking on the finger corresponding to 8 and 9.

MR. KELBERG: Has he written anything concerning any of that area?

DR. LAKSHMANAN: He has indicated that that is areas of abraded--I mean brown--I mean red abrasion in the back area there.

MR. KELBERG: Doctor, would it be accurate if I were to circle this entire area (indicating) to then describe what you are describing as injuries nos. 7, 8 and 9?

DR. LAKSHMANAN: Yes. Actually all this would also include that because he says "Multiple red brown abrasions" and he says quarter inch by 3/8 inch. That's a maximum dimension he gives it, reddish brown, and all this area would be included.

MR. KELBERG: And, doctor, what, if anything, does this refer to?

DR. LAKSHMANAN: He says that this will be the three knuckles of the index finger. He calls them, each of them a knuckle, the interphalangeal joints.

MR. KELBERG: And I can not make out, can you, the words that appear above the word "Knuckle" that you were just pointing to?

DR. LAKSHMANAN: I am not able to read that. I think it's--

MR. KELBERG: Keep your voice up, please.

DR. LAKSHMANAN: I think it refers to "Irregular" here and configuration, "Conf."

MR. KELBERG: So now, doctor, I want--before I draw, I want to be sure I'm accurate. Would all of this information refer then to what you've described as injuries 7, 8 and 9?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. For the record then, your Honor, I will do that with the blue pen.

MR. KELBERG: And in the upper left quadrant diagram 23-I, I'll write "G-26, 25, injs. No. 7, 8 and 9," doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And in the protocol itself, doctor, this first paragraph refers to what you have described as injuries 6, 7, 8 and 9?

DR. LAKSHMANAN: Yes. Paragraph 4.

MR. KELBERG: I'll outline that in red, and out at the side, "G-26, 25, injs. No. 6, 7, 8 and 9" with an arrow touching the box. Anything further regarding these injuries, doctor?

DR. LAKSHMANAN: No. I already addressed that 6 and 7 are also a contusion underlying them.

MR. KELBERG: And again, Dr. Golden's diagram does not include that description?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: Nor does his protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Mistakes on your--in your judgment on his part?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any significance?

DR. LAKSHMANAN: No significance to the big picture items.

MR. KELBERG: Is it significant, however, as to sources for those blunt force trauma injuries?

DR. LAKSHMANAN: Yes. Because if it's just an abrasion, you'll just have a scrape against a rough surface. But if it's an abrasion contusion, it would be an impact of the hand against that surface which has a different connotation as to the mechanism of injury.

MR. KELBERG: And when you say an "Impact," doctor, would that be in your opinion consistent with a hand that is moving with force in a backward direction by Mr. Goldman coming in contact with the rough surface like the tree and backing away from the assailant?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything further about injuries 6, 7, 8 or 9?

DR. LAKSHMANAN: No.

MR. KELBERG: Is there any additional injury in either photograph G-26 or G-25?

DR. LAKSHMANAN: There is--I described one more injury in G-26. There's a small abrasion above the abrasion contusion that we've described here, and this is a 5/16 inch by 5/8 inch contusion--I mean abrasion.

MR. KELBERG: Doctor, is it seen in photograph G-25 as well?

DR. LAKSHMANAN: Yes. You see it better here.

MR. KELBERG: And for the record, on G-26, it appears that the area of the injury that is closest to the hand is in contact or covered if you will by a margin of the photographic identification card?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Doctor, now, this is an abrasion in your opinion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Do you have an opinion as to the source or sources?

DR. LAKSHMANAN: It's a nonspecific blunt force scraping injury to the back of the forearm.

MR. KELBERG: Is it one that in your opinion is antemortem, before death?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is it diagrammed in any way by Dr. Golden?

DR. LAKSHMANAN: Yes. It's diagrammed as--in 21-I.

MR. KELBERG: And I think Mr. Lynch has that.

MR. KELBERG: It's board 3-G, your Honor.

THE COURT: Thank you.

DR. LAKSHMANAN: It could possibly be reflected by this abrasion injury here (indicating), but it's difficult to decide whether if you really--

MR. KELBERG: Keep your voice up, please, doctor.

DR. LAKSHMANAN: This diagrammatic marking here could represent that. I'm not sure whether that's what it was representing.

MR. KELBERG: What if any writing is associated with that?

DR. LAKSHMANAN: It just says "Abrasion" here (indicating).

MR. KELBERG: Is there a description given by dimension or any other information?

DR. LAKSHMANAN: I can't read--it says 3/4 inch by half inch, and I think that refers to more the triangular abrasion above it, not to that marking.

MR. KELBERG: And there also appears to be some writing down below where the schematic of the left hand ends. Does that refer at all to that same area?

DR. LAKSHMANAN: No.

MR. KELBERG: So, doctor, if you'll point carefully to the area which possibly refers to this injury.

DR. LAKSHMANAN: Possibly. I'm not sure. This one (indicating).

MR. KELBERG: All right. Let me circle that in red. I'll write out at the side "G-26, 25 inj. no. 10" is it, doctor?

DR. LAKSHMANAN: Yeah. Possible.

MR. KELBERG: And I'll put a big question mark.

DR. LAKSHMANAN: Yeah.

MR. KELBERG: Anything in the way of a description in the protocol?

DR. LAKSHMANAN: It's on page 12, no. 2. All the injuries to the left forearm have been described, including the triangular one which we just discussed, and no specific mention of this particular one, but this paragraph would include all the injuries in the forearm.

MR. KELBERG: Doctor, if you could look to the photograph to the left of G-26--and I can't see the number at the moment.

DR. LAKSHMANAN: G-21.

MR. KELBERG: G-21. Do you see this triangular-shaped injury?

DR. LAKSHMANAN: Yes. Here. You can see it here (indicating).

MR. KELBERG: And that is what kind of injury, doctor?

DR. LAKSHMANAN: That's again a nonspecific blunt force injury which could have been caused by the environment which is present on the Bundy drive.

MR. KELBERG: What kind of blunt force trauma injury is it?

DR. LAKSHMANAN: Again, this could be a branch. You know, as I told you, there are branches which have been cut and there are stalks there; and when you have the forearm rubbing against one of those stalky branches or the stalks of the branch, you could have this kind of abrasion.

MR. KELBERG: It is an abrasion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. And you've already pointed out, apparently it was diagrammed by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is there any description given with the diagram itself?

DR. LAKSHMANAN: Here. Triangular 3/4 inch by half an inch abrasion (indicating).

MR. KELBERG: Doctor, and what number if any do you give to that injury in G-21?

DR. LAKSHMANAN: In G-21, I gave it a no. 2.

MR. KELBERG: All right. Let me circle this area in blue.

DR. LAKSHMANAN: And this measurement also corresponds to the same.

MR. KELBERG: Which measurement, doctor?

DR. LAKSHMANAN: The 3/4 inch by half an inch. He's given the measurement twice on this.

MR. KELBERG: All right. Let me try and include that as well. Does this "Abr" refer to anything, doctor?

DR. LAKSHMANAN: Yes. It's abrasion.

MR. KELBERG: You're referring to that same triangular area?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I'll include that then in the circled area on form 21-I and I'll write at the side "G-21"--and I'm sorry, doctor--injury no. 1? The triangular-shaped injury is which number according to your--

DR. LAKSHMANAN: Injury no. 2 in G-21.

MR. KELBERG: I'm sorry. Injury no. 2. I'll write that in. All right. Let's finish. What other blunt force injuries are included collectively by Dr. Golden in this paragraph item 2 of page 12? If you could go to the photographs and show us.

DR. LAKSHMANAN: He has also addressed this linear abrasion above the triangular abrasion of the left forearm in G-21, and that is also diagrammed here, and he has addressed it in the protocol here as a 3/4 inch in length abrasion (indicating).

MR. KELBERG: What injury number have you arbitrarily assigned that one?

DR. LAKSHMANAN: I assigned that as injury no. 3.

MR. KELBERG: Of G-21?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline that first on the protocol in blue, and I'll write "G-21 inj. no. 3."

DR. LAKSHMANAN: And I also have--you have to address this 3/4 inch by half an inch triangular abrasion as injury no. 2 of G-21.

MR. KELBERG: All right. I'll do that in red then on the protocol, same page. And that's going to be "G-21 inj. no. 2"; is that correct, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And then over here where you pointed out--before I circle, doctor, is this the area that refers to that injury no. 3?

DR. LAKSHMANAN: Yes. Yes. This particular abrasion. But my concern is whether the measurement here--it says 3/4 inch by half an inch and again says 3/4 inch by half an inch--whether one of the 3/4 inch applies to this measurement.

MR. KELBERG: Does he describe injury no. 3 then as 3/4 inch by half inch?

DR. LAKSHMANAN: No. He just says 3/4 inch. So I'll just diagram the no. 2 there next to it.

MR. KELBERG: All right. Let me circle this area in red. On the outline of the schematic, I'll write "G-21 inj."--this is no. 3?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, would you consider these mistakes in the sense that--

DR. LAKSHMANAN: Well, he has described them fairly accurately, the triangular abrasion and the linear abrasion. So they're not mistakes per se.

MR. KELBERG: Is a fairly accurate description a satisfactory description in your judgment, doctor?

DR. LAKSHMANAN: Well, it's a--the triangular abrasion has been described properly and the linear abrasion has been described.

MR. KELBERG: But not completely?

DR. LAKSHMANAN: That's correct. Because you have another abrasion there which has not been addressed, but he says that there are multiple abrasions in the forearm. He has not addressed them individually.

MR. KELBERG: And is his failure to do that considered by you a mistake?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any significance?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What's next in the selective group?

DR. LAKSHMANAN: We have a smaller abrasion just below the blue card here (indicating).

MR. KELBERG: On G-21?

DR. LAKSHMANAN: Yes. And you can also see it on G-26 here (indicating).

MR. KELBERG: At the top of that photograph?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Have you given it an arbitrary number?

DR. LAKSHMANAN: No. 1.

MR. KELBERG: Of which photograph?

DR. LAKSHMANAN: Of G-21.

MR. KELBERG: Of G-21?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Do you see it diagrammed?

DR. LAKSHMANAN: Well, this is the same area which we had a question mark whether it was injury no. 10 of G-26. It could also represent injury no. 1 of G-21 because there's only one marking there for both those injuries.

MR. KELBERG: All right. Let me then add under the description previously given on the diagram board the word "Or G-21 inj. no. 1" with a question mark.

DR. LAKSHMANAN: And you can see both of them in context better in G-26.

MR. KELBERG: Is their relationship as shown in that photograph, G-26, of significance to you in forming any opinion as to how they were incurred?

DR. LAKSHMANAN: No. They're nonspecific blunt force injury. I can't make any inference on that.

MR. KELBERG: Anything further with respect to this collective group that's in this paragraph item 2 of page 12 of the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: So in order to complete this item, let me circle the no. 2 and indicate collectively which injuries, doctor?

DR. LAKSHMANAN: 1, 2 and 3 of G-21.

MR. KELBERG: "G-21 inj. nos. 1, 2 and 3."

DR. LAKSHMANAN: And could be g--injury number 10 of G-20.

MR. KELBERG: And possibly--

DR. LAKSHMANAN: Injury 10.

MR. KELBERG: G-26?

DR. LAKSHMANAN: Yes.

MR. KELBERG: "inj. no. 10."

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything further?

DR. LAKSHMANAN: No.

MR. KELBERG: Are we done with G-26?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Are we done with G-21?

DR. LAKSHMANAN: Yes.

MR. KELBERG: So we are left with G-20 and G-23?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let's--we talked yesterday briefly about G-20, doctor, and you talked about this interrupted abrasion. Do you recall that?

DR. LAKSHMANAN: Yes. And also, I described the abrasion in detail, the different parts of it.

MR. KELBERG: All right. Is, first of all, that diagrammed in any fashion by Dr. Golden?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it addressed anywhere in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it discussed at all in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: All mistakes?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any significance to you?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is there any other injury you identify in G-20?

DR. LAKSHMANAN: There's also a smaller abrasion just above the--in the region of the elbow area, and I've already discussed this complex interrupted abrasion in the left arm and the smaller abrasion above it and--

MR. KELBERG: The interrupted abrasion you talked yesterday about, the clothing getting folded is one basis that you end up with this situation?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, what about this abrasion that you describe as being below the photographic card in G-20?

DR. LAKSHMANAN: Yeah, I gave it a number also. It's again a nonspecific abrasion.

MR. KELBERG: Is that diagrammed?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it addressed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Same answer to the mistakes question?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Including significance or lack of significance?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any other injury in G-20?

DR. LAKSHMANAN: No.

MR. KELBERG: Just to conform to the wound chart, which is our exhibit 351, of G-20, which is injury no. 1?

DR. LAKSHMANAN: The lowest one is injury no. 1.

MR. KELBERG: What is injury no. 2?

DR. LAKSHMANAN: Injury no. 2 is this--the three portions to the left arm area. Three--an abrasion, just three portions to it, and then injury no. 3 is the top most one.

MR. KELBERG: And the top most one is where, doctor?

DR. LAKSHMANAN: It's right here. You can see it (indicating).

MR. KELBERG: And what is that injury, no. 3?

DR. LAKSHMANAN: That's also an abrasion which is 3/4 inch by 1/8 inch in size.

MR. KELBERG: Is that discussed at all in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Diagrammed anywhere?

DR. LAKSHMANAN: No.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: All mistakes?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Same answers?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any other injuries in G-20?

DR. LAKSHMANAN: No.

MR. KELBERG: Are we done with that photograph?

DR. LAKSHMANAN: Yes, we have.

MR. KELBERG: Let's go to G-23.

DR. LAKSHMANAN: Yes. G-23 shows the left forearm and shows the inner aspect of the left forearm and also shows the left nipple area. So I have described two injuries. The other injuries seen in this photograph have already been addressed. You have the abrasion behind the left distal forearm, which was juror no. 10 of G-26. We have the smaller abrasion here, which is injury no. 1 I think or--yeah--injury no. 1 of G-21. Yeah. Injury no. 1 of G-21. So barring that, we have an abrasion of the ulnar aspect of the left wrist and you have this abrasion here, the left nipple (indicating).

MR. KELBERG: Doctor, I want to be clear in my own mind. You're saying that that is the nipple of the left breast?

DR. LAKSHMANAN: Of the right breast.

MR. KELBERG: All right. So that's the right breast?

DR. LAKSHMANAN: Yes. But the abrasion is in the left forearm wrist area.

MR. KELBERG: And injury no. 1 for G-23 is that area of the left wrist?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that described at all in the protocol?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Where?

DR. LAKSHMANAN: Page 13, no. 5 (indicating).

MR. KELBERG: Is that an accurate description of what you see in photograph G-23?

DR. LAKSHMANAN: No, it is not.

MR. KELBERG: In what way is it inaccurate?

DR. LAKSHMANAN: He described it as two bruises in his protocol description, but it's not a bruise. It's more--and he says it's not abraded. You can clearly see it's an abraded injury with a peeling of the skin.

MR. KELBERG: How can you see that it is clearly abraded and Dr. Golden on the other hand describes it as fresh bruises?

DR. LAKSHMANAN: I can only say what I see here. This is peeling of the skin, which is a flap of skin like any other abrasion like you saw in the little finger here where the skin flap has been peeled off. And you can see the peeling of the skin right here (indicating), and the injury itself is an abrasion injury.

MR. KELBERG: Doctor, would you say that normally it is better to see the actual wound on the body than to review it photographically?

DR. LAKSHMANAN: That is correct.

MR. SHAPIRO: Objection to the form of the question, "Normally."

THE COURT: Sustained. Rephrase the question.

MR. KELBERG: Doctor, in your experience, do you find that a review of injuries on the body yields a more accurate identification than one drawn from photographic identification?

DR. LAKSHMANAN: Looking at the body definitely helps because you have a 3-dimensional look at the injury. And also, you can make incisions to see the depth of the bruising and other--the ability to do other examinations to better define the injury. But in a photograph, you can clearly interpret what the injury appears to be, that is an abrasion or contusion, without difficulty, but you may not be able to tell how deep the bruise is because you can't cut--it's only a 2-dimensional view. It's not a 3-dimensional view and you don't have the additional ability to study the injury in more detail.

MR. KELBERG: And, doctor, I believe you--

MR. SHAPIRO: Objection. Motion to strike. Nonresponsive.

THE COURT: Overruled.

MR. KELBERG: Doctor, I believe you testified several days ago that you routinely review cases performed by other medical examiners in forming independent opinions to testify where those individuals, for example, have left your office or on vacation; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And that's the same process also available for Dr. Wolf or Dr. Baden; that is, they weren't there to examine the bodies either; is that correct?

MR. SHAPIRO: Objection. Calls for speculation.

THE COURT: I think we've already asked this question before.

MR. KELBERG: All right.

MR. KELBERG: Doctor, is this diagrammed, this injury no. 1 diagrammed?

DR. LAKSHMANAN: Yes, it is.

MR. KELBERG: Where is it diagrammed?

DR. LAKSHMANAN: 23-I right here (indicating).

MR. KELBERG: Where you pointed appears to have a lot of blackened area.

DR. LAKSHMANAN: Yes.

MR. KELBERG: What leads you to believe that there is an entry there that concerns injury no. 1 of G-23?

DR. LAKSHMANAN: It's--it's two discolored areas on the--I mean two markings on the diagram on the same area where the injury is present, and there is some notations here which also have been darkened, but the measurements here have been dictated here in the--in the body of the autopsy report (indicating).

MR. KELBERG: And when you say "The measurements here," you're referring to where?

DR. LAKSHMANAN: You can see this to be 3/8 inch by 3/8 inch and then half an inch by half an inch.

MR. KELBERG: Even though it's darkened?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And you see that same description provided in this page 13, item 5 entry?

DR. LAKSHMANAN: Yes.

MR. KELBERG: From just looking at the diagram, doctor, and your experience in the office and its customs and practices and those of Dr. Golden, can you offer any explanation as to why this area is darkened?

DR. LAKSHMANAN: Well, I--I--one explanation would be that he diagrammed the injury and then he maybe went back and didn't want it mentioned or didn't think it was the right area, then he went back and thought it was the same area. I just have to give my feeling on what happened. I can't tell really what happened.

MR. KELBERG: All right.

DR. LAKSHMANAN: But the point is, it is as it is on the diagram and the description is as it is on the protocol.

MR. KELBERG: Doctor, is it accurate if I circle this entire area? And I don't know. Is this area to refer in your opinion to that injury?

DR. LAKSHMANAN: It would reflect the same area because it says "Skin" and it says "Dermis" there.

MR. KELBERG: And is that in your opinion something that is in consideration in describing that injury of no. 1 of G-23?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me circle this information in red, the lower left quadrant, and I'll write "G-23 inj. no. 1," and I'll write or I'll outline on the protocol of this item no. 5 and write "G-23 inj. no. 1" and I'll write-- doctor, in your opinion, this is an--this injury is an abrasion, not a contusion?

DR. LAKSHMANAN: Well, it's an abrasion as far as the skin surface goes, and it looks like an abrasion and not an abrasion contusion.

MR. KELBERG: All right. And I'll write "Per Dr. L., abrasion, not contusion." Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything further about injury no. 1?

DR. LAKSHMANAN: No.

MR. KELBERG: Is there any other injury of G-23 which you identify from that photograph that we have not discussed?

DR. LAKSHMANAN: The--to the right nipple, you have an abrasion contusion here (indicating).

MR. KELBERG: Doctor, is that discussed in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Diagrammed?

DR. LAKSHMANAN: No.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Do you have an opinion as to the circumstance under which that abrasion contusion was received?

DR. LAKSHMANAN: Again, nonspecific blunt force injury to the right nipple area.

MR. KELBERG: And would your answers about that be the same as they have been concerning all other contusion abrasions seen in the hand photographs?

DR. LAKSHMANAN: Yes.

MR. KELBERG: The mistakes--I assume they are mistakes--did not address it, diagram it or address it in the addendum; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Of any significance individually or collectively?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything else about G-23?

DR. LAKSHMANAN: No.

MR. KELBERG: Are we done with this photograph board?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Your Honor, I have another board of photographs. May they be marked as exhibit 362?

THE COURT: People's 362.

(Peo's 362 for id = board of photographs)

(Brief pause.)

MR. KELBERG: And this one is entitled "Sharp force injuries to left flank, left thigh and right chest of Mr. Goldman, blunt force trauma and lividity."

MR. KELBERG: Again, doctor, with the Court's permission, if you'll step down--I'm sorry. Mr. Lynch points something out to me and I do want to cover. We left out in our earlier discussion photograph G-55 and the facial area. And, G-55, doctor, is--

DR. LAKSHMANAN: Yes.

MR. KELBERG: --the photograph in the lower area second from the right border?

DR. LAKSHMANAN: Yes.

MR. KELBERG: How many injuries have you identified to the right side of Mr. Goldman's face that we have not discussed already?

DR. LAKSHMANAN: I have five areas of injury which has not been discussed so far.

MR. KELBERG: Would you just take us through slowly in general terms these areas?

DR. LAKSHMANAN: Yeah. You have two types of injury to the right side of the face. You have blunt force injuries and you have sharp force injuries. The blunt force injuries are represented here as scrapes. I'll go over the numbering after I've given my initial description. You have a linear abrasion here, you have a curved abrasion there. You have an area of confluent abrasions in the right check. The linear abrasion and the curved abrasion are to the right forehead, right temporal area. Then there are also abrasions present around the right eye. So these are all the blunt force injuries (indicating).

MR. KELBERG: Doctor, what did you mean by "Confluent abrasions"?

DR. LAKSHMANAN: "Confluent" means they are--there are linear abrasions which are merging with each other in this area of the cheek (indicating).

MR. KELBERG: All right.

DR. LAKSHMANAN: And then in addition, overlying some of these abrasions in the right cheek area, you have evidence of five sharp force injuries, cuts. You have one, two, three, four and five cuts to the surface of the skin which are sharp force injuries, and four of them seem to overlie the abrasion injury to the cheek, which would indicate that these abrasion injuries occurred before these sharp force injuries to the right cheek area. You also have this--a fifth sharp force injury which is not in the area of the abrasion injury wherein you cannot opine whether it happened before or after. So that roughly describes all the injuries you see in the rights of the face. As I have done with the other injuries, I have numbered them for my convenience, and we will go over them if you want to.

MR. KELBERG: In just a moment. I want to ask just a couple of follow-up questions. The five sharp force injuries that you've described as cuts, four of which you identify as appearing to overlie the area of the abrasions; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: In your opinion, what would be a source or sources for those cuts?

DR. LAKSHMANAN: A knife.

MR. KELBERG: And from the nature of your observation of those wounds, do you have an opinion as to whether they are all consistent with a single-edged knife with a maximum blade length of approximately 6 inches tapering at the end as you've described?

DR. LAKSHMANAN: They could have been caused by that.

MR. KELBERG: But from the nature of the form of each of those cuts on the surface of the face, can you exclude a double-edged knife as a source for each of them?

DR. LAKSHMANAN: I can not.

MR. KELBERG: And, doctor, hypothetically, is--well, let me ask a couple of preliminary questions. Then I'll ask a hypothetical. From your examination of that area, do you have an opinion as to whether one or more of those five sharp force injuries was received before death?

DR. LAKSHMANAN: They were all received before death.

MR. KELBERG: How are you able to determine that those five sharp force injuries were received before death?

DR. LAKSHMANAN: The description in the report indicates that there is hemorrhage in the tissue.

MR. KELBERG: From your observation of the photographs, are you able to confirm from just that observation that these five sharp force injuries are inflicted before death?

DR. LAKSHMANAN: Their appearance also supports that opinion because they are no different from the other antemortem injuries that are present.

MR. KELBERG: Now, the underlying abrasions to the four of the five sharp force injuries, are they antemortem, that is inflicted before death?

DR. LAKSHMANAN: Yes, they are.

MR. KELBERG: How are you able to make that determination?

DR. LAKSHMANAN: The same reasons. The appearance, the reddish brown color and as I outlined before.

MR. KELBERG: Now, hypothetically, doctor, if Mr. Goldman had been disabled from his--by his assailant's attack, but still had a beating heart and the assailant wanted to check to see whether Mr. Goldman was still alive or not and took this knife, and while Mr. Goldman was in a position where the right side of his face was exposed, poked the knife in the area shown in G-55 to basically detect any reaction from Mr. Goldman, would that set of circumstances be consistent with what you see anatomically in this photograph, G-55?

MR. SHAPIRO: Objection. Improper hypothetical.

THE COURT: Sustained.

MR. KELBERG: Doctor, from the nature of the observations of these five sharp force injuries which you described as all being antemortem and from the underlying abrasions which you've described as being antemortem, is there anything inconsistent from what you see with a hypothetical set of circumstances of the assailant in an effort to ascertain whether Mr. Goldman is alive poking his face five separate times with the end of the knife?

MR. SHAPIRO: Objection. Assumes facts not in evidence.

THE COURT: Sustained.

MR. KELBERG: Your Honor, may I be heard on that, please?

THE COURT: No.

MR. KELBERG: Doctor, medically, is there anything from what you see in the photograph which permits you to understand or offer an opinion as to the sequence from the standpoint of a scenario separate and apart from the cuts overlying the abrasions to describe how those cuts were inflicted?

DR. LAKSHMANAN: Yes. Let's take the one which we have in the right cheek, lower part, which is not in an area of abrasion. It's a superficial puncture type sharp force injury. That could have occurred at the same time since they all have hemorrhage and they all occurred when Mr. Goldman had some blood pressure. It could have occurred at the same time when the threatening cuts took place as a threatening puncture. That particular puncture could have taken place at that time. Now, regarding the other punctures, they're all superficial punctures, and I have no way of knowing exactly why they were done because they really don't have any fatal injury per se from them. They are only superficial punctures, and I would favor that it could be after the fatal injuries were inflicted. It could be--it could have been inflicted to check whether he was still alive or not. That would be one conclusion I would draw also.

MR. SHAPIRO: Motion to strike as calling for speculation without any foundation.

THE COURT: Overruled.

MR. KELBERG: Now, doctor, you started to say arbitrarily how you have numbered these particular injuries. Let's start with your injury no. 1 and go through them, please.

DR. LAKSHMANAN: Injury no. 1 is the linear abrasion which extends from the right forehead down to the right cheek area. Injury no. 2 is the--

MR. KELBERG: Before you move from injury 1 to injury 2, have you measured that injury?

DR. LAKSHMANAN: Yes. I measure it as two and a half inches in length.

MR. KELBERG: Is there any significance in your judgment from its length and appearance on the question of identifying any source or sources for causing it?

DR. LAKSHMANAN: This would again be an abrasion which could be caused by a cut branch or a stalk which could rub against his face in this manner.

MR. KELBERG: Let me--if I can just ask counsel to move slightly aside and get a photograph. And, Mr. Lynch, could you--

(Brief pause.)

MR. KELBERG: We're putting up, your Honor, exhibit 359. Have to find a place for Mr. Lynch. I think he just found one.

MR. KELBERG: Doctor, would you point out again on these photographs of the scene at Bundy the kind of environmental source or sources in your opinion which could have caused this injury no. 1, this linear abrasion?

DR. LAKSHMANAN: The face was obviously dragged on a rough surface and other rough surfaces dragged on the facial area. What I'm trying to point out is, if you look at crime scene no. 2 and also crime scene no. 3 and crime scene no. S6, you see areas of where the--there are cuts, stalks of or stumps of a plant, and you have similar cut stumps also available on the branch of the tree here (indicating). And stalks such as that can cause abrasions such as this.

MR. KELBERG: In what manner, doctor?

MR. SHAPIRO: Your Honor, there would be a motion to strike. S photographs were taken in 1995 and there's no foundation that they reflect--

THE COURT: Sustained. The last answer is stricken. The jury is to disregard.

MR. KELBERG: Doctor, I want you to assume that the photographs taken in 1995 fairly and accurately depict the stumps and show these--I want to use the same word you use--the "Shoots" if you will that have grown somewhat, but are basically in the same general condition except for their length as they were on June 12th and 13th of 1994.

MR. SHAPIRO: There would be an objection. No foundation.

MR. KELBERG: There will be a foundation laid by another witness later in this trial, your Honor.

THE COURT: All right. Subject to motion to strike. Proceed.

MR. KELBERG: Now, given that hypothetical set of circumstances, doctor, would you please then explain how these particular kinds of shoots can create an injury like that two plus inch laceration--I'm sorry--abrasion, linear abrasion?

DR. LAKSHMANAN: The same mechanism I mentioned earlier. When you have a cut branch rubbing against your skin surface, it can cause a linear cut abrasion.

MR. KELBERG: Doctor, as long as I'm holding the board, why don't you take us through injury no. 2 if it relates also to this environmental scene.

DR. LAKSHMANAN: Injury no. 2 is the curved abrasion here in the upper part of this linear abrasion here (indicating), in the right forehead area.

MR. KELBERG: In your opinion, is injury no. 2 a distinct injury from injury no. 1?

DR. LAKSHMANAN: Yes. It's separate from injury no. 1 both--though they both meet at a particular area.

MR. KELBERG: And any source or sources from the environmental photographs provided here in 359 which would be a source for that kind of injury, injury no. 2?

DR. LAKSHMANAN: Same type of similar source. A branch or cut stalk of a--correction--a stump of a branch.

MR. KELBERG: Branch of a stump maybe?

DR. LAKSHMANAN: Well, a branch which has had--which is not complete.

MR. KELBERG: The stump, as you use the word "Stump" refers to which of the area?

DR. LAKSHMANAN: No. What I'm saying is, you have--I just gave the stumps on the ground level here on crime scene no. 3. We have similar stumps also on the branch of the tree there.

MR. KELBERG: All right. Now, doctor, how about injury no. 3 if it pertains to a source or sources from the environment as shown in these photos?

DR. LAKSHMANAN: Injury no. 3 is this confluent area of abrasions in the right cheek area.

MR. KELBERG: And in your opinion, are those confluent abrasions consistent with a source or sources from sources seen in the photographs?

DR. LAKSHMANAN: There's a similar source as you can see on the crime scene area. The tree's not well seen here. I see it more in the s photographs.

MR. KELBERG: Well, why don't you point out in the s photographs what it is from the tree that can be a source for that confluent series of abrasions.

DR. LAKSHMANAN: If you look at the other side of the tree and at the base of the tree area here (indicating), you have similar stumps like you see on the ground level here on CS3. And those branches can represent these kinds of abrasions.

MR. KELBERG: Are those confluent abrasions abrasions which are actually individual injuries that just run together or are they from one overall mechanism causing the total appearance?

DR. LAKSHMANAN: I would favor overall mechanism causing a similar appearance because you have several structures there which can cause the abrasion which you see here in the cheek (indicating).

MR. KELBERG: How about injury no. 4?

DR. LAKSHMANAN: Injury no. 4 is the small linear abrasions around the right eye area here (indicating).

MR. KELBERG: Doctor, again, any source or sources environmentally consistent with those?

DR. LAKSHMANAN: The same sources which I just discussed.

MR. KELBERG: And how about then injury no. 5 is it?

DR. LAKSHMANAN: Injury no. 5 is--collectively I described all the five sharp force injuries to the right cheek area and I measured them individually in a counterclockwise direction, but I labeled them as injury no. 5.

MR. KELBERG: Have we omitted any additional injuries to the face?

DR. LAKSHMANAN: No.

MR. KELBERG: And other than going through the protocol diagrams and so forth, have we covered a discussion of the facial injuries of G-55?

DR. LAKSHMANAN: Yes. So basically you have a blunt force and a sharp force injury to the face.

MR. KELBERG: Why don't we use the time we have to try and go through quite quickly the protocol and diagrams if any and the addendum if any concerning those--

(Discussion held off the record between the Deputy District Attorneys.)

MR. KELBERG: And we're going to get diagrams to put on the other easel.

MR. KELBERG: Doctor, let's start with injury no. 1, that two plus inch linear abrasion.

DR. LAKSHMANAN: It's in diagram no.--you want to start with the diagram or--

MR. KELBERG: Sure.

DR. LAKSHMANAN: Diagram no. 22-III.

MR. KELBERG: All right. If Mr. Lynch could turn to form 3 of that board. I forget the number of it, but we'll get it.

MR. LYNCH: 4G.

MR. KELBERG: 4G.

DR. LAKSHMANAN: He diagrams the linear abrasion, injury no. 1, the curved abrasion, the confluent abrasion here (indicating) in the right cheek and the abrasions around the right eye. The only thing is in the diagram for the linear abrasion of the right side of the face and the curved abrasion, he called them cuts, but they are abrasions.

MR. KELBERG: All right. First of all, let's just identify them individually. Which reflects or concerns injury no. 1?

DR. LAKSHMANAN: This particular line going down here (indicating).

MR. KELBERG: And is there a description that goes along with that?

DR. LAKSHMANAN: Basically it says 1-3/4 inch in the protocol. You want to turn to the protocol?

MR. KELBERG: All right. Why don't you tell us which page to turn to.

DR. LAKSHMANAN: Page 6, no. 4. He described them as multiple superficial incised wounds and he described as a 3-inch incised wound in the original protocol the right side of the face extending from the forehead to the cheek, and he also described other superficial wounds half an inch to 1 inch.

MR. KELBERG: Doctor, in your opinion, these are not incised wounds or cuts?

DR. LAKSHMANAN: No.

MR. KELBERG: How are you able to make that determination photographically?

DR. LAKSHMANAN: Just the appearance, you can tell they are abrasions. And also, if you look at under the magnifying glass, you can see the irregularity to the margins, which would be consistent with an abrasion rather than an incised wound.

MR. KELBERG: In your opinion, is it a mistake for Dr. Golden to have opined that these are incised wounds?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any significance to you in any of the big ticket questions?

DR. LAKSHMANAN: No.

MR. KELBERG: Why not?

DR. LAKSHMANAN: Because of the same reasons I've told before. They don't interfere with my ability to tell you the type of weapon or bleeding effect causing the death, et cetera.

MR. KELBERG: And, doctor, does this paragraph 4 cover more than just injury no. 1 as you've arbitrarily identified them?

DR. LAKSHMANAN: It also reflects the other curve injury next to it, and he calls them "Cuts."

MR. KELBERG: Is the same series of answers going to apply that you just gave to your opinion that these are--this is an abrasion, injury no. 1, rather than an incised wound? Will that apply to the same questions if asked of you on this injury no. 2?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Other than injury 1 and 2, is there any additional injury addressed in this item 4?

DR. LAKSHMANAN: No.

MR. KELBERG: All right. Let me outline this area of the protocol in red, and I'll write, "G-55 inj. nos. 1 and 2, but per Dr. L., abrasions, not cuts." Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And then if you would, please, again on the diagram form, which is injury 1 and which is injury 2?

DR. LAKSHMANAN: This is 1 and this is 2 (indicating).

MR. KELBERG: All right. And where you indicated 1, I'll do it in blue. Is that correct?

DR. LAKSHMANAN: That says "Length 3 inch, iw," incised wound, "Superficial."

MR. KELBERG: And I'll write, "G-55 inj. no. 1" and I'll write in quotes, "Abrasion." And then if you'd point out injury no. 2, please.

DR. LAKSHMANAN: Injury no. 2 is this curved area here (indicating).

MR. KELBERG: And is there any written description to go along with that?

DR. LAKSHMANAN: It says "Cuts, various, superficial."

MR. KELBERG: Let me circle that area again on the diagram in red this time, and I'll write out at the side "G-55 inj. no. 2" and I'll also write "Abrasion" in quotes. Is it diagrammed anywhere else, doctor?

DR. LAKSHMANAN: Mainly in 23 or mainly in this diagram.

MR. KELBERG: Is there any aspect of the addendum which addresses either injury 1 or injury 2?

DR. LAKSHMANAN: Yes, it does.

MR. KELBERG: Which one or ones?

DR. LAKSHMANAN: Page 2, no. 3.

MR. KELBERG: Why don't we throw it up here in front of the photographs. Page 2, no. 3, doctor?

DR. LAKSHMANAN: Yes. He amended it to indicate that they were all abrasions and he described that the area of abrasion is 4-1/2 inches by 2-1/2 inches and he describes more clearly that one of the abrasions in the right frontal area is curvilinear.

MR. KELBERG: Is that your injury no. 2?

DR. LAKSHMANAN: Yes. And he also describes that the longest abrasion extends from the right temple to the cheek 2-1/2 inches in length, and he also addresses injury no. 4 of the right lower eyelid as a triangular-appearing abrasion.

MR. KELBERG: We'll get to that after lunch, but is it your opinion, doctor, that this paragraph now accurately describes injuries 1 and 2?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And let me outline then that area with the exception of the last sentence which you've indicated, doctor, goes to another injury, G-55, and I'll write over at the side "G-55 inj. nos. 1 and 2." Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Your Honor, does the Court wish to break?

THE COURT: Yes. Thank you, counsel. Ladies and gentlemen, we are going to take our noon recess. Please remember all of my admonitions to you; don't discuss the case amongst yourselves, don't form any opinions about the case, don't conduct any deliberations until the matter has been submitted to you or allow anybody to communicate with you with regard to the case. We'll stand in recess until 1:30. All right. Doctor, thank you.

(At 12:05 P.M., an adjournment was taken until the same day, 1:30 P.M.)

LOS ANGELES, CALIFORNIA; TUESDAY, JUNE 13, 1995 1:34 P.M.

Department no. 103 Hon. Lance A. Ito, Judge

APPEARANCES: (Appearances as heretofore noted.)

(Janet M. Moxham, CSR no. 4855, official reporter.)

(Christine M. Olson, CSR no. 2378, official reporter.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Back on the record in the Simpson matter. All parties are again present. All right. Deputy Magnera, let's have the jurors, please.

MR. NEUFELD: Your Honor, you were going to--

THE COURT: I thought you were going to take that up informally with Mr. Clarke.

MR. NEUFELD: The way it was left I wanted to report back to the Court because there were some concerns about it, if I may.

THE COURT: Certainly. Mr. Neufeld.

MR. NEUFELD: Thank you. Your Honor, it has been about four weeks since we made it very clear to the Prosecution in this case that we objected to Dr. Weir using any likelihood ratios, if and when he was called as a witness. At that time four weeks ago, on May 15, and on May 16, umm, Mr. Clarke indicated to the Court that it wasn't his intention to use Dr. Weir for likelihood ratios but rather for the underlying frequency data contained in that report. We needed to know which tact they were going to take, because as we made it clear to the Court at that time, if they took the tact of pursuing likelihood ratios, then we would he have a 402 hearing, we would need to contact witness. We had never heard anything more in the intervening four weeks as to which way they were going to go until we got that report last week which seemed to still indicate their pursuit of likelihood ratios. I spoke to Mr. Clarke this morning at the suggestion of the Court and apparently, as he can report to your Honor, they don't know yet and they haven't been able to speak to Dr. Weir in the last few days or whatever because he has been on vacation. Our concern is, and I think there is some fundamental unfairness here and that the Defendant is certainly prejudiced by this situation in that they've had more than enough time to find out which way they are going to move on this, so we can go out, and if need be, secure witnesses for such a hearing. All I'm asking is that at this point in time, since they have now indicated that they intend call Dr. Weir as early as next week, which doesn't give us a lot of time, that they inform the Court on the record and inform counsel, certainly no later than--tomorrow is Wednesday--certainly no later than Thursday, as to whether or not they intend to pursue the route of likelihood ratios so we can get ready in time for a hearing for next week, otherwise we won't be able to do it with enough time.

THE COURT: Mr. Clarke.

MR. CLARKE: Yes, your Honor. With regard to Dr. Weir, he is on vacation and will be driving home arriving home tomorrow. He is to contact us as soon as he is able to. So it is our intent to speak with him tomorrow, maybe in the evening, and I indicated to Mr. Neufeld earlier today that once we've had that discussion with him I think we will be in a much better position to declare to him what types of evidence we may wish to offer in front of the jury. So I think at this point it is premature, but we are going to operate with all deliberate speed.

THE COURT: All right. Then may I trust that this issue will be laid to rest at the latest by the close of business Friday?

MR. CLARKE: I would hope so, yes. I might indicate to the Court, Dr. Weir in fairly quick fashion produced a report, a preliminarily report, as Mr. Neufeld indicated, fairly quickly. It is not totally complete but he felt it important that both we and the Defense have something to work from in this area. It is our intention to present in terms of population frequencies what the scientific community feels is appropriate and we will convey that direction that the community is telling us as soon as we are able to after we speak with Dr. Weir.

THE COURT: All right.

MR. NEUFELD: Thank you.

THE COURT: All right. Thank you, counsel.

MR. CLARKE: Thank you.

THE COURT: I look forward to hearing more DNA. All right. Let's have the jury, please.

MR. KELBERG: Your Honor, could I have about thirty seconds with Mr. Shapiro?

THE COURT: Sure.

(Discussion held off the record between Deputy District Attorney and Defense counsel.)

MR. KELBERG: Thank you, your Honor.

THE COURT: Deputy Magnera.

(Brief pause.)

(The following proceedings were held in open court, in the presence of the jury:)

THE COURT: All right. Thank you, ladies and gentlemen. Please be seated.

Lakshmanan Sathyavagiswaran, the witness on the stand at the time of the noon recess, resumed the stand and testified further as follows:

THE COURT: All right. Let the record reflect we have been rejoined by all the members of our jury panel. Good afternoon, ladies and gentlemen.

THE JURY: Good afternoon.

THE COURT: Dr. Lakshmanan is again on the witness stand undergoing direct examination by Mr. Kelberg. And Mr. Kelberg, you may conclude your direct examination.

MR. KELBERG: I am going as quickly as I can, your Honor.

THE COURT: All right.

DIRECT EXAMINATION (RESUMED) BY MR. KELBERG

MR. KELBERG: Dr. Lakshmanan, again with the Court's permission could you step down, and let's finish, if we can, please, going through the injuries that are in the photograph G-55. I believe we stopped, if I'm not mistaken, with the protocol and diagrams through injury no. 2; is that correct, the curva linear?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Let's pick up, if we could, doctor, would you identify what is injury no. 3?

DR. LAKSHMANAN: The injury no. 3 is this confluent area of abrasions in the right cheek area which I have described in the morning right here, (indicating).

MR. KELBERG: Has Dr. Golden diagrammed that confluent area?

DR. LAKSHMANAN: Yes, he has.

MR. KELBERG: Where?

DR. LAKSHMANAN: In diagram 22-III.

MR. KELBERG: Would you indicate, please, doctor, where it had been diagrammed, and what, if any, description has been provided? Mr. Lynch could perhaps move back this way?

DR. LAKSHMANAN: This is the area of abrasion injury which he has diagrammed here on the left lower quadrant of 22-III and he has described the description here "One and a half by 3/4 inch abrasion reddish brown" belongs to this area here and also this description here applies to this area of injury.

MR. KELBERG: What is that description that you were just pointing to, doctor?

DR. LAKSHMANAN: Circumscribed area of abrasions. Actually is not patches. Poorly defined.

THE COURT: Mr. Kelberg, I wonder if you and Dr. Lakshmanan could stop talking over each other.

MR. KELBERG: I will try to do better.

DR. LAKSHMANAN: It says "Poorly described circumscribed abrasions."

THE COURT: Mr. Kelberg, would it be better to move the microphone in the doctor's tie? Would that be a better location for it?

MR. KELBERG: I'm getting a shake of the head from side to side from the sound person.

THE COURT: He has been talking a long time.

DR. LAKSHMANAN: The right cheek area. This says, "Poorly circumscribed area of abrasions one and a half inch by 3/4 inch." "Poorly defined," rather.

MR. KELBERG: Doctor, does is writing in any way at all to correspond at all to what you have described as jury no. 3?

DR. LAKSHMANAN: This would be injury no. 4 next to the eye.

MR. KELBERG: So before I start marking with a permanent marker, would it be accurate to include this area?

DR. LAKSHMANAN: Not that area.

MR. KELBERG: I'm sorry, not that area?

DR. LAKSHMANAN: Just this area.

MR. KELBERG: Would that otherwise be accurate?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I have circled that area in the lower left quadrant and I will write "G-55 inj. no. 3."

MR. KELBERG: Does Dr. Golden then describe that confluent area of abrasions, doctor, in his protocol?

DR. LAKSHMANAN: Right here page 6, item 5, the first five lines.

MR. KELBERG: Would you point to where that ends, for that description.

DR. LAKSHMANAN: Right here, (indicating), about.

MR. KELBERG: I will outline that on the protocol in red and to the left I will write "G-55"?

DR. LAKSHMANAN: Yes.

MR. KELBERG: "inj. no. 3"?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, is that an accurate description, in your opinion, of this confluent area?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is this injury no. 3 addressed at all in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: In your judgment was there any reason to do so?

DR. LAKSHMANAN: No.

MR. KELBERG: Is there anything further about injury no. 3 which we have not discussed?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's look at injury no. 4 then if you would identify it first from the photograph?

DR. LAKSHMANAN: Injury no. 4 includes these abrasions around the right eye, including a triangular area of abrasion.

MR. KELBERG: From what you just told us a few moments ago, I gather there was some indication in 22 roman numeral III?

DR. LAKSHMANAN: Yes. You can see some of the abrasions diagrammed there, but also--that is only--that is only diagrammed where you see it, 22-III, right there, (indicating).

MR. KELBERG: Doctor, is there more than one line on the schematic to represent injury no. 4?

DR. LAKSHMANAN: There is one or two lines here.

MR. KELBERG: How many individual abrasions do you include in your description of injury no. 4?

DR. LAKSHMANAN: I just described them as linear and irregular abrasions around the eye.

MR. KELBERG: From looking at the photograph or any other photograph can you approximate the total number of such abrasions around the eye?

DR. LAKSHMANAN: About three of them there. Three of them there, in all the photographs I have seen.

MR. KELBERG: Let me outline this area again in red.

MR. KELBERG: Is that the accurate area, doctor, that I just outlined?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And I will draw a line out to the right side and write "G-55 inj. no. 4."

MR. KELBERG: Anything further about this?

DR. LAKSHMANAN: He correctly labels them as abrasions here, (indicating), abrasions, abr. In the description they were included under the--he just called them areas of the superficial wounds in the description of an item 4 of page 6, so it is not a--it reflects what he has diagrammed there.

MR. KELBERG: So what you were just pointing to, doctor, under item 4, page 6 of the autopsy protocol where we have already written in "G-55 injuries 1 and 2 but per Dr. L abrasions not cuts," that description includes, in your opinion, the description of injury no. 4?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And although Dr. Golden has annotated the diagram to reflect multiple abrasions, he has in fact written a description that describes them as a superficial wound varying from one-half to one inch?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me circle that area in blue just to set it off from what we've already outlined in red. Circle that on the protocol. I will write out at the side "G-55 inj. no. 4, but see diagram"--

DR. LAKSHMANAN: Okay.

MR. KELBERG: --"22 roman numeral III and I will write "Abrasions" in quotation marks?

DR. LAKSHMANAN: He has addressed it in the addendum also.

MR. KELBERG: You said there is something addressed in the addendum, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: We have that here. Tell us where.

DR. LAKSHMANAN: Page 2, no. 3.

MR. KELBERG: No. 3 of page 2, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where?

DR. LAKSHMANAN: The last line here, (indicating), he has described the triangular abrasion which you see in the photograph as triangular. "Right lower eyelid as triangular in appearance," page 2 no. 3 last line.

MR. KELBERG: Would you point again on the photograph where that particular abrasion is there.

DR. LAKSHMANAN: It is right there. There are other photographs which show it well, but in that photograph that is in evidence it shows it right here where I'm pointing and below the right eye, (indicating).

MR. KELBERG: That is on G-55, your Honor, and appears to be the injury which is closest to the lower part of the right eye.

THE COURT: Yes.

MR. KELBERG: I will outline this area also on the addendum in blue and circle it and out at the side write "G-55 inj. no. 4."

MR. KELBERG: Anything further in the addendum regarding that injury, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: All right. Let's take the addendum down and ask you, if you would, please, to move to injury no. 5.

DR. LAKSHMANAN: Injury no. 5 I have collectively labeled as injury no. 5 all the five sharp force injuries to the right cheek and area, and I measured them rating from 5/8 inch, 3/8, quarter inch, 5/8 inch and quarter inch respectively when measured in a counterclockwise direction; one, two, three, four, five.

MR. KELBERG: Doctor, this is the series four of which, in your opinion, overlay the confluent abrasions shown as injury no. 3?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Did Dr. Golden diagram any of those five superficial cuts?

DR. LAKSHMANAN: Yes, in 22-I, right here in the left lower quadrant, and he has labeled it, all five, "Superficial incise wounds of skin of right cheek," one, two, three, four, five.

MR. KELBERG: Is that an accurate, first, diagrammatic representation of their location?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it an accurate description of what you see in the photograph?

DR. LAKSHMANAN: Yes, and it is also described in the report here, (indicating).

MR. KELBERG: Before we get to the report, there appears to be some writing to the right of the schematic. Is that--does that associate itself with these five superficial cuts?

DR. LAKSHMANAN: Yes. It says "Very superficial cuts" here.

MR. KELBERG: What does it say?

DR. LAKSHMANAN: "Superficial cuts." "Superficial IW" is incise wounds.

MR. KELBERG: And that is a more formal way of referring to a cut?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me circle this entire area then and I'm going to ask you, doctor, when I'm done doing that, if you could, after I--to the side I'm going to write "G-55 inj. no. 5."

DR. LAKSHMANAN: Yes.

MR. KELBERG: Would you point out very slowly, and I will circle in red, the five cuts as diagrammed by Dr. Golden.

DR. LAKSHMANAN: One, two--

MR. KELBERG: Let's stop at one. And is there an entry for the size of that adjacent to it?

DR. LAKSHMANAN: It says half an inch there.

MR. KELBERG: So this is no. 1?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I will circle it and I will write number "No. 1 of 5."

DR. LAKSHMANAN: This is 2 here.

MR. KELBERG: I will circle that.

DR. LAKSHMANAN: No, there is only one there. This is 2, 3 and 4.

MR. KELBERG: I'm sorry which is--

DR. LAKSHMANAN: This is no. 2.

MR. KELBERG: Which, doctor?

DR. LAKSHMANAN: This one, the one I'm pointing out right there.

MR. KELBERG: All right. Let me shorten that circle and I will cover what I should have in a second and out at the side I will write "No. 2 of 5."

MR. KELBERG: Where is 3?

DR. LAKSHMANAN: Right next to it there.

MR. KELBERG: I'm sorry, down here, (indicating)?

DR. LAKSHMANAN: Right there.

MR. KELBERG: What is already circled in red?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Let me keep that then and I will write up here "No. 3 of 5"?

DR. LAKSHMANAN: This is no. 4.

MR. KELBERG: I'm sorry, here, doctor?

DR. LAKSHMANAN: This one right here, pointing right there, (indicating).

MR. KELBERG: All right. I will circle that and I will out the side write "No. 4 of 5.".

DR. LAKSHMANAN: And this is no. 5 here, (indicating).

MR. KELBERG: And is there some writing associated with that?

DR. LAKSHMANAN: It says I think it is 5/8 of an inch.

MR. KELBERG: Let me circle this area and I will write "No. 5 of 5."

MR. KELBERG: Doctor, which is the one of these five that, in your opinion, does not overlay the area of the confluent abrasions?

DR. LAKSHMANAN: This one, (indicating).

MR. KELBERG: What we have labeled no. 5 of 5?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, you said Dr. Golden addressed this as well in the protocol?

DR. LAKSHMANAN: Yes. He addresses it as page 6, item 2. This whole paragraph refers to that, (indicating).

MR. KELBERG: Is that an accurate description of what you see in the photograph G-55 concerning this injury or series of injuries?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me outline this in blue. I will write "G-55 inj. no. 5."

MR. KELBERG: Doctor, in Dr. Golden's description, the last sentence, he says: "They are superficial" these five wounds, "Involving the skin and associated with a small amount of cutaneous hemorrhage." Doctor, is that information of assistance to you in assessing whether those five cuts were inflicted before death, at or around the time of death or after death?

DR. LAKSHMANAN: It would--to me it would indicate that they happened before death because you must have blood pressure to have hemorrhage in the soft tissues.

MR. KELBERG: And the cutaneous hemorrhage would be into the soft tissues as you define that term?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything else about no. 5?

DR. LAKSHMANAN: Nothing else.

MR. KELBERG: All right. I believe you said there was a number 6 or am I wrong?

DR. LAKSHMANAN: No. 6 is already we discussed. That is the wound to the right ear which goes to the temporal bone.

MR. KELBERG: Is there any other injury to the face that we have not discussed in 1 through 5?

DR. LAKSHMANAN: No.

MR. KELBERG: Is there any aspect of the addendum that addresses the last series of injuries no. 5 that we have not gone into yet?

DR. LAKSHMANAN: Umm, no.

MR. KELBERG: So as far as you are concerned, doctor, have we completed a discussion of the facial injuries in G-55?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, if you want to take the stand for just a brief moment and sit, I want to ask you some questions about some testimony, and I'm focusing now, doctor, strictly on injury 5, this series of five superficial cuts, four of which you say overlay the confluent abrasion area that is injury no. 3. In part--as part of your review, doctor, did you review Dr. Golden's preliminary hearing testimony concerning this area?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: And inviting--

MR. SHAPIRO: Your Honor, there would be an objection based on the fact that this is all hearsay testimony.

THE COURT: Overruled.

MR. KELBERG: May I continue, your Honor?

THE COURT: At this point, yes.

MR. SHAPIRO: May there be a continuing objection?

THE COURT: The objection is premature at this time. The question was did you review the testimony? Yes, I did. There has been no question.

MR. SHAPIRO: But the harm is going to come if the question is read.

THE COURT: That is a speaking objection as well. Proceed, Mr. Kelberg.

MR. KELBERG: Thank you, your Honor.

MR. KELBERG: Doctor, and inviting Court and counsel's attention to pages 81 and 82 and 85 of that preliminary hearing transcript and 86, I should say, was this part of the information you reviewed, doctor, questioning by Mr. Hodgman: "Now, doctor I realize that there are more lesser wounds that were not indicated on your diagram, but I would like to move ahead now to the lower left hand figure on People's 27 for identification, and sir, you observed, during the course of your autopsy, five wounds to the right side of Mr. Goldman's face; is that correct? "Answer: Yes. "Question: And it appears that we have four of those five wounds marked in red on that lower left-hand figure on People's 27 for identification; is that correct? "Answer: Yes. "Question: Now, would you in brief describe those wounds for us, sir. "Answer: Okay. Referring to my notes, these were superficial cuts, varying in orientation involving the skin of the right cheek and they varied from approximately one-half to one inch in maximal length. "Question: And these five wounds, sir, were not fatal; is that correct, in and of themselves? "Answer: Correction. Yes. I said one-half. It is okay. Referring to my protocol, they were small cuts. They varied from one quarter inch in length to 5/8 of an inch in length, the superficial cuts to the right side of the cheek. "Question: All to the right side of the cheek; is that correct? "Answer: Yes." And before I read the next question and answer, doctor, is this a reference to what you have described as injury no. 3, the area of the confluent abrasions?

MR. SHAPIRO: Objection, hearsay.

THE COURT: Overruled.

MR. KELBERG: You may answer.

DR. LAKSHMANAN: I thought the cuts you described referred to injury no. 5, the five cuts.

MR. KELBERG: May I approach; your Honor?

THE COURT: You may.

MR. KELBERG: Doctor, let me ask you to review, including the part that is going to come after what I've just read to you, and also invite your attention to page 85. I think I may have made a mistake. I may have misinterpreted, but I want to be sure that the doctor--

THE COURT: All right. Mr. Kelberg, proceed.

MR. KELBERG: All right.

MR. KELBERG: Doctor, in fact are those the five cuts which you have identified collectively as injury no. 5?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What I was reading? All right. Then continuing on: "Question: And were all of those antemortem wounds, as far as you could determine? "Answer: Yes, they were." Doctor, are you in agreement with that opinion that those five are antemortem wounds?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, let me refer you to page 85 to questioning starting on line 14. I'm sorry, let me start on line 7. "Question: Those are the five cutting wounds you've testified to? "Answer: Yes. So it had two things visible there, the multiple abrasions on the cheek" --and this refers to this injury no. 3, the confluent abrasions, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: --"And then the circumscribed area which contained the cutting wound, the superficial cutting wounds. "Question: And sir, with reference to diagram People's 28 for identification, you are indicating an area on that figure in the lower left-hand side; is that correct? "Answer: Yes. "Question: Now, with regard to those abrasions," this is injury no. 3, "Would you characterize those abrasions as antemortem, perimortem or postmortem? "Answer: I would not characterize them as postmortem. They appeared to be perimortem based on their color, coloration. "Question: And again, `perimortem' meaning? "Answer: At about the time of death which could be shortly before, at the time of or shortly thereafter." Again, doctor, you reviewed that testimony?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: Doctor, do you agree with that opinion concerning that area of confluent abrasion?

DR. LAKSHMANAN: No. I think it is antemortem because as I pointed out earlier, the five--I mean out of the small stab sharp force injuries we discussed, four of them overlie this area of abrasion, and these sharp force injuries show evidence of hemorrhage in the tissue which would indicate that the person had blood pressure and the heart was beating when those sharp force injuries took place. So if they overlie an area of abrasion, the abrasion must have occurred before the sharp force injury, which would indicate that they also occurred before death when the person had blood pressure and the heart was beating.

MR. KELBERG: And assuming hypothetically that Dr. Golden testified that in his opinion the confluent abrasions, which underlie the cuts, were perimortem, that is around the time of death, would it make any medical sense to you how the cuts that are overlaying those abrasions could have been antemortem?

DR. LAKSHMANAN: I said that they are antemortem.

MR. KELBERG: No. My question is given Dr. Golden's opinion that the underlying abrasions are perimortem--that was his opinion according to this hypothetical transcript, correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: --does it make any medical sense how the injury which in your opinion comes after the cuts overlaying the abrasions, how they could be antemortem with the underlying injury, the abrasions, being perimortem?

DR. LAKSHMANAN: That is what I opined.

MR. SHAPIRO: Objection, your Honor.

THE COURT: Basis?

MR. SHAPIRO: Improper hypothetical, improper questioning.

THE COURT: Sustained.

MR. KELBERG: Doctor, if Dr. Golden testified that injury no. 3, the abrasions, were perimortem and he also opined that the cuts, injury no. 5, were antemortem, in your opinion, would that indicate that the cuts came before the abrasions?

DR. LAKSHMANAN: No, the cuts came after the abrasion.

MR. KELBERG: No, I understand what your opinion is, doctor. My question is if Dr. Golden had the opinion that the abrasions were perimortem, and the cuts were antemortem, would that indicate that at least in Dr. Golden's view the cuts came before the abrasions?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: And, doctor, if the cuts came before the abrasions how, if you can explain medically, could the cut be overlaying the abrasions rather than the abrasions overlaying the cuts?

DR. LAKSHMANAN: It cannot be explained.

MR. KELBERG: Would you consider that opinion, if held by Dr. Golden, that the cuts came before the abrasions, to be a mistake?

DR. LAKSHMANAN: Well, he said it is perimortem and perimortem also includes injuries which could just occur around the time of death, but in this situation I would consider it a mistake.

MR. KELBERG: Any significance to you?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor I think we are done with the picture of the facial injuries, and let's go, if we could, to the board that I had marked just before we started for afternoon session--just before the morning session ended.

THE COURT: 362.

MR. KELBERG: Thank you, your Honor, yes.

MR. KELBERG: Doctor, again, with the Court's permission, would you step to this board of photographs.

DR. LAKSHMANAN: (witness complies.)

MR. KELBERG: And this board is titled "Sharp force injuries to the left flank, left thigh and right chest of Mr. Goldman; blunt force trauma and lividity." First of all, doctor, we have a photograph in the center at the top underneath of which there is a designation 43-E. I ask you to assume that that is a copy of the same photograph which is marked already as People's exhibit 43-E, and it reflects the condition of Mr. Goldman's body at the time the body was discovered by Officer Riske around 12:13 in the morning on June 13, 1994.

MR. SHAPIRO: Objection, no foundation to that statement.

THE COURT: Overruled.

MR. KELBERG: Doctor, first of all, inviting your attention to G-1 and G-2, are you familiar with what is shown in those two photographs?

DR. LAKSHMANAN: Yes. Those are the photographs of Mr. Goldman taken at the Coroner's office on June 14Tg, 1994, in the morning with his clothing present.

MR. KELBERG: And doctor, does this--each of these photographs represent what you saw on June 13th, the day before, when you viewed Mr. Goldman's body and ms. Nicole Brown Simpson's body at the time they arrived at the Coroner's office?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, let me invite your attention, if I could, please, first to a photograph in the lower left-hand corner of the chart or series of photographs marked G-17. Are you familiar with what is shown in that?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What is that?

DR. LAKSHMANAN: That is a close-up photograph of the left thigh area of Mr. Goldman after his clothing has been removed and this is the photograph taken after the body is washed. And what you see here is a stab wound to the left thigh and it is a gaping wound. It has got a blunt end on its posterior aspect or on the right side of the photograph, and the sharp end on the left side of the photograph, and this wound is an antemortem penetrating stab wound and it was about three inches deep.

MR. KELBERG: Doctor, from your description of a posterior blunt end and using the left side of the photograph, the sharp end being on the left side, is that accurate?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Do you have an opinion as to the type or class of knife or knives which could have caused that stab wound?

DR. LAKSHMANAN: It is a single-edged knife.

MR. KELBERG: Is this a wound which could only have been caused by a single-edged knife?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And going back, if you can recall, to our chart with three different examples of wound patterns, which wound pattern, if any, would this particular wound reflect?

DR. LAKSHMANAN: This would reflect an injury pattern 1, but I must emphasize that there is also a cutting component to this stab wound. That is, the blunt end is still retained, but the single-edged knife which caused this wound also caused a cut extension of the--of the--of the wound.

MR. KELBERG: Doctor, in your opinion is this wound a fatal wound?

DR. LAKSHMANAN: It is a non-fatal wound.

MR. KELBERG: What, if any, reaction from the body would you expect, given the location of that stab wound?

DR. LAKSHMANAN: It would cause significant bleeding.

MR. KELBERG: Doctor, I want to invite your attention--and by the way, which leg is this, doctor?

DR. LAKSHMANAN: The left thigh.

MR. KELBERG: Can you point out, in your own body, on your own body, a general area location?

DR. LAKSHMANAN: Roughly in this area here, (indicating).

MR. KELBERG: Could you pull your coat pocket back?

DR. LAKSHMANAN: Right here, (indicating).

MR. KELBERG: Your Honor, for the record, the witness is identifying an area that is just to the front of his left pant pocket and down near the bottom of where the pant pocket ends.

THE COURT: Yes, upper thigh.

MR. KELBERG: Thank you, your Honor.

DR. LAKSHMANAN: When I measured it in my one-as-to-one photographs it measured--G-17--one and 7/8 inch by 7/8 inch in the gaping state.

MR. KELBERG: Doctor, is that hypothetical single-edge knife with an approximate six-inch long blade tapering at the tip consistent with having caused this stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I want to invite your attention back to G-1 and G-2 and in particular your attention to the left pant leg as shown in each of those photographs. Is the appearance of the pant leg in each of those photographs of some significance to you in evaluating the relative positions of Mr. Goldman and the perpetrator at the time that wound was inflicted?

DR. LAKSHMANAN: Yes.

MR. KELBERG: How so?

DR. LAKSHMANAN: Because what we have here in G-1 and G-2 is extensive blood staining of the left part of the jeans which Mr. Goldman is wearing, which would indicate that he was most likely upright for some time after this injury was inflicted, because as you know, blood would come out of a wound such as we have here if the left thigh, would drain down the thigh due to gravity, if somebody is upright, and that would stain the trouser or the jeans.

MR. KELBERG: For example, doctor, if Mr. Goldman had been in the position, as shown in these photos, G-1 and G-2 and had remained in that position with the stab wound received in that position, would you have any scientific explanation as to how the blood could be on the pant leg below the area of the wound going towards the shoe?

DR. LAKSHMANAN: It won't fit that kind of position because the blood seems to be definitely going downwards as if he was upright in the line of gravity.

MR. KELBERG: Doctor, how rapidly a response of external bleeding would you expect from a wound the nature of this particular stab wound as seen in G-17?

DR. LAKSHMANAN: You would have significant bleeding from that stab wound. Even though it did not injure any major big vessel, there are a lot of smaller vessels which supply the muscles in the front of the thigh and it was a wound which went up to three to three and a half inches in depth and you have a pretty gaping wound, so there would be significant bleeding from that wound, but it is not a fatal wound because no major vessel was struck.

MR. KELBERG: Doctor, is there a description provided by Dr. Golden in his protocol regarding this stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Does the description include a description internally of the pathway of this stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What is that description?

DR. LAKSHMANAN: Basically it goes through the muscular tissues to the left thigh and it did not strike any major vessel, and it was three to three and a half inches deep going in a left to right direction without deviation.

MR. KELBERG: Given that description, are you able to offer an opinion as to the relative position--you have indicated Mr. Goldman was upright in your judgment when he received this injury and for some period thereafter--are you able to offer an opinion for the relative positions of the perpetrator and Mr. Goldman at the time that stab wound was inflicted?

DR. LAKSHMANAN: I would not be able to give a specific scenario. The perpetrator could have been in the front or the back. If he was holding the right hand, the knife, it could be that the perpetrator was in the front, but I won't be able to say with definite certainty where the person was or where the victim was when this wound was inflicted.

MR. KELBERG: Doctor, if you could keep your voice up, please.

MR. KELBERG: If we could find a ruler again, would you show us what you mean with a right-handed person, that is, a person holding the knife in the right hand, the relative positions, and then show us a left-handed person in the sense of holding the knife in the left hand. I will take on the role of Mr. Goldman. You tell me where you need me to be in relation to yourself.

DR. LAKSHMANAN: Well, these are just hypothetical demonstrations.

MR. SHAPIRO: Objection, irrelevant.

THE COURT: Overruled.

MR. KELBERG: You may continue, doctor?

DR. LAKSHMANAN: One, you can be facing me in the front. One method could be with the knife being held in this manner with the blunt edge on the outer aspect and the sharp edge on this aspect like this on the thigh, (indicating).

MR. KELBERG: If you will stop this very quickly, the doctor has taken the ruler to represent the knife in his right hand and he referred to the blunt edge as being the edge which is outer, the outer side of the knife, the sharp edge being the inner side, and he has pressed it against that same area of my left thigh with the angulation being full--

MR. KELBERG: That is the angulation, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: He has the bottom of the ruler in contact with my body slightly lower, perhaps at about a thirty-degree angle from the horizontal.

THE COURT: Yes.

MR. KELBERG: Obviously then with the higher end--

MR. KELBERG: The other end being higher?

DR. LAKSHMANAN: Just to add to the--

MR. KELBERG: Can we turn in some fashion, doctor, so the ladies and gentlemen of the jury can see what you are just pointing--set the ruler?

DR. LAKSHMANAN: Like this, yes, (indicating). The other point I want to make is there is also a cutting component to the stab wound, so there was either movement of the knife or the victim's thigh during this time, during this penetration and withdrawal, which caused this stabbing, plus a cutting component to it.

MR. KELBERG: Now, what about a person holding the knife in his left hand?

DR. LAKSHMANAN: Well, if it was the left hand, you could have the same manner, standing behind him and stabbing him in this manner, (indicating).

MR. KELBERG: For the record, Dr. Lakshmanan has taken a position behind me and basically now holding the ruler in his left hand.

MR. KELBERG: Which would be the blunt edge?

DR. LAKSHMANAN: The blunt edge would still be to the back. It has to be a single-edged knife for this wound.

MR. KELBERG: Blunt edge would be the inner edge?

DR. LAKSHMANAN: The blunt edge would be facing me and the sharp end would be facing the front.

MR. KELBERG: And the angulation is still the same?

DR. LAKSHMANAN: Yes. I just gave you two possibilities.

THE COURT: I think you need to angle around the other way to show the jurors at the other end of the box.

MR. KELBERG: Is that the same angulation necessary, doctor, under this scenario?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, you indicated that Dr. Goldman--Golden, excuse me, addressed this in the protocol; is that correct, this stab wound?

DR. LAKSHMANAN: Yes, he addresses it on page 9 and 10, no. 4.

MR. KELBERG: Before we move on, does he also have some indication in a diagram?

DR. LAKSHMANAN: Yes, he does, on form 21, no. II.

MR. KELBERG: Is it addressed in any fashion in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Is there any reason it should have been, in your opinion?

DR. LAKSHMANAN: No.

MR. KELBERG: If I could switch with Mr. Lynch.

(Brief pause.)

MR. KELBERG: And I'm sorry, the page number for the protocol, doctor?

DR. LAKSHMANAN: Page 9 and 10. Starts on page 9, no. 4. Starts here as "No. 4 stab wound of left thigh."

MR. KELBERG: Doctor, in your opinion, is this an accurate description of that thigh injury?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And it continues on to the next page?

DR. LAKSHMANAN: Yes. It is on the top of the next page.

MR. KELBERG: Before we flip it, let me mark--is this the only injury, doctor, of photograph G-17?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me just outline that then on our protocol and I will write "G-17" and now if we can flip the page.

DR. LAKSHMANAN: It ends here on page 10.

MR. KELBERG: With an opinion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: In your opinion is Dr. Golden's opinion accurate on this particular injury?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And I will outline that on page 10 of the protocol and again write "G-17."

MR. KELBERG: Doctor, where on the diagram, if we put up board 21--perhaps Mr. Lynch can refresh my memory as to the number of that board on the back.

MR. LYNCH: 3G.

MR. KELBERG: 3G your Honor?

DR. LAKSHMANAN: This is 21, no. II.

THE COURT: Thank you.

DR. LAKSHMANAN: It is diagrammed in the right--left lateral view of--the left lateral view diagram on the left thigh.

MR. KELBERG: Is there any written description which is attached to that?

DR. LAKSHMANAN: Yes. It says, "Stab wound to left thigh, 33 inches from the heel."

MR. KELBERG: And there appears some writing, is there, doctor, just above the "SW"?

DR. LAKSHMANAN: Yes. It says, "Length" and I can't read the letters. I'm sorry, it says "Left to right."

MR. KELBERG: And that reflects what, doctor?

DR. LAKSHMANAN: The direction.

MR. KELBERG: Of the stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: So if I circled this entire area, doctor, would this accurately identify what is G-17?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And I have done so in blue and written the designation G-17.

MR. KELBERG: Is there anything further about that stab wound, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything further in the protocol on that stab wound?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything further in the photograph of that?

DR. LAKSHMANAN: No.

MR. KELBERG: I want to move then, if we could, doctor, to photograph G-10, the photograph in the lower right corner of exhibit 362. What are we seeing in that photograph, doctor?

DR. LAKSHMANAN: You are seeing evidence of three sharp force injuries to the right--first of all, you are seeing the right side of the trunk, right side of the trunk from the right chest to the right hip area and this is the upper part of the body and the lower part of the photograph shows the upper hip area here, (indicating). The right lower chest shows two sharp force injuries, both are stab wounds; one located in the front of the side of the chest, which is toward the right side of the photograph. The other sharp force jury is to the left side of the photograph on the back side of the side of the chest. This stab wound, (indicating)--both of them are fatal stab wounds. They entered the lung and caused hemorrhage. We have another sharp force injury to the lower right flank area, (indicating), and this one is a superficial wound. It was non-fatal. So this photograph then in addition, we also have some abrasions which are--appear postmortem on the side of the right chest, some between the two sharp force injuries of the right chest, and the sharp force injury of the right flank, and some--and an area of abrasion just below the stab wound in the posterior aspect of the side of the chest. I numbered them for my convenience and they have been addressed in the protocol and diagram and we can discuss it in detail.

MR. KELBERG: Doctor, with respect to these two fatal stab wounds, are those arbitrarily designated 1 and 2?

DR. LAKSHMANAN: Yes. I numbered them 1--the one which is in the front I called no. 1 and the one in the back I called as no. 2.

MR. KELBERG: Let's start with no. 1. Can you point out exactly, using yourself, where that area is on the body?

DR. LAKSHMANAN: Somewhere here on this region of the chest, (indicating).

MR. KELBERG: Perhaps you can turn so the jurors on the right side can also see.

DR. LAKSHMANAN: Right here, (indicating).

MR. KELBERG: Your Honor, for the record, the doctor has pointed to an area below the nipple area of the right breast and toward the back of the body along the midline of the side.

THE COURT: Yes.

DR. LAKSHMANAN: And the second stab wound--you want to just do it one--

MR. KELBERG: Let's see if we can take care of them one at a time.

MR. KELBERG: Doctor, are you able to tell, from examining the photograph, the type of knife or classes of knives, if it is more than one, which could have caused that particular fatal stab wound?

DR. LAKSHMANAN: It was caused by a single-edged knife.

MR. KELBERG: How are you able to say that that was caused by a single-edged knife?

DR. LAKSHMANAN: Because you have a blunt end on the lower part and a sharp end on the upper part of the wound.

MR. KELBERG: Would you point out for us which is the sharp end and which is the blunt end.

DR. LAKSHMANAN: The sharp end is on the top here and the blunt end on the bottom here, (indicating).

MR. KELBERG: For the record, the witness has pointed on the photograph to the top and bottom portions of the wound.

MR. KELBERG: Doctor, in your opinion that stab wound could not have been caused by a double-edged knife?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Let me move briefly to no. 2 and ask you the same series of questions. Are you able to determine from the appearance of that wound the type of class or classes of knives which could have caused that fatal wound?

DR. LAKSHMANAN: That one was also caused by a single-edged knife. You have a blunt end in the back and a sharp end in the front.

MR. KELBERG: Again, doctor, not by a double-edged knife?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: Could the hypothetical approximately six-inch long single-edged knife tapering at the point have caused both of those fatal stab wounds?

DR. LAKSHMANAN: It is possible.

MR. KELBERG: Doctor, are you able to determine, from any description provided by Dr. Golden, the relative positions of Mr. Goldman and the perpetrator at the time either of these two fatal stab wounds was inflicted?

DR. LAKSHMANAN: It would again--there are various possibilities for this--in which--various possibilities how this stab wound could have been sustained.

MR. KELBERG: Let's start with this stab wound no. 1. What is the description--in fact, you said it is described--let's find the actual description, if we could, in the protocol.

DR. LAKSHMANAN: It is on page 8, no. 1. The entire description applies to injury no. 1 on G-5--I'm sorry, G-10.

MR. KELBERG: I will outline this entire area and write "G-10 injury, inj., no. 1."

MR. KELBERG: Doctor, can you summarize in lay terms for us the description provided here by Dr. Golden and let me get out of the way so you can do so.

DR. LAKSHMANAN: Basically the stab wound entered the right chest in the area which I just showed you, went through a rib, the seventh rib, went through the lung, the right lung, and then came to strike the right fourth rib in its back--

THE COURT: Excuse me, I think we need to--

MR. COCHRAN: Your Honor, maybe a brief moment.

(Brief pause.)

THE COURT: All right. Let's take ten minutes.

(Recess.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Mr. Kelberg, Mr. Shapiro.

(A conference was held at the bench, not reported.)

(The following proceedings were held in open court:)

THE COURT: All right. Back on the record. Let's have the jurors, please.

(Brief pause.)

(The following proceedings were held in open court, in the presence of the jury:)

THE COURT: Thank you, ladies and gentlemen. Please be seated. All right. Let the record reflect that we have been rejoined by all the members of our jury panel. Ladies and gentlemen, if--this has been difficult testimony the last several days, and if at any time during these proceedings you feel uncomfortable and you need to take a break, just let me know, because I understand and we will take a break right away. But if you are feeling uncomfortable, don't hesitate to let us know or let the bailiffs know. Okay? All right. Mr. Kelberg, would you conclude your direct examination, please.

MR. KELBERG: I'm moving in that direction, your Honor.

THE COURT: All right. But I realize we still have time of death issues, don't we?

MR. KELBERG: We certainly do, your Honor.

THE COURT: I just remembered that.

MR. KELBERG: I'm sure you wish you hadn't.

THE COURT: Proceed.

MR. KELBERG: Very well.

MR. KELBERG: Doctor, with the Court's permission could you step down. You were describing for us--and if both owe both of us will slow down when we are talking about what is contained on these charts, I think the reporters will find it helpful to getting a fully accurate record. Doctor, you were describing or beginning to describe in lay terms the substance of what Dr. Golden has described in this area of the protocol concerning that fatal stab wound no. 1. Would you pick up where you were, please.

DR. LAKSHMANAN: The stab wound entered the right side of the chest, went through the right seventh rib, went through the lung, the right lower part of the lung, and then the stab wound ended in the back of the right fourth rib. You have twelve ribs on each side, and the fourth rib--on the back of the fourth rib the stab wound ended and the stab wound traveled from back to front, right to left, causing injury to the lung and that caused also bleeding. So this is a fatal stab wound and the total length of the track from the skin to the back of the right fourth rib is about four inches.

MR. KELBERG: That is how Dr. Golden has described this wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: In your knowledge of anatomy is a wound path of approximately four inches consistent with the anatomy between the point of entry and where Dr. Golden describes the wound as ending?

MR. SHAPIRO: Objection, calls for speculation.

THE COURT: Overruled.

MR. KELBERG: You may answer the question, doctor.

DR. LAKSHMANAN: That will be a fair distance of which would fall within the parameters of the anatomy.

MR. KELBERG: If you will keep your voice up, please, doctor. Let me underline, if I could, the last sentence of the third paragraph under item 1 which gives the direction "Right to left and back to front with no other angulation measurable."

MR. KELBERG: Doctor, again giving you the ruler, and I believe you indicated that there are alternatives, depending on whether the knife is being held in the right hand or in the left hand, about the thigh injury. Would the same apply with respect to injury no. 1?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Assuming, hypothetically, that the perpetrator is holding this knife in the right hand, again using me as Mr. Goldman and yourself as the perpetrator, can you demonstrate for us how that wound could have been inflicted?

DR. LAKSHMANAN: Yes. The perpetrator has to be in the back of Mr. Goldman and the stab wound entry is in the front of the right side of the chest. As I told you earlier, the dull end of the knife is in the lower part, the sharp end of the knife is in the upper part, so if I'm holding the knife in this manner, it would be into the chest in this manner, (indicating), causing fracture of the seventh rib going into the chest cavity and ending in the fourth rib. It is likely vertically oriented also, so the blunt end is here and the sharp end is here, somewhat like this, (indicating).

MR. KELBERG: Doctor, if you will fix that position so we can describe it for the record. You are holding with your right hand the ruler to represent the knife. You have positioned yourself behind me. You have the knife angled such that the part in contact with me is closer to the front of my body, than the back end of the ruler which is toward the back of my body.

MR. KELBERG: And the angle appears to be about a thirty-degree angle from the horizontal, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: May the record so reflect, your Honor?

THE COURT: Yes.

MR. KELBERG: Doctor, I want you to, if you could, please, reposition yourself as you did for the demonstration when you described how the two superficial incise wounds had been inflicted or at least in a fashion consistent with that?

DR. LAKSHMANAN: (witness complies.)

MR. KELBERG: And may the record reflect the witness has done that, your Honor?

THE COURT: Yes.

MR. KELBERG: Doctor, in this position could that fatal stab wound no. 1 have been inflicted on Mr. Goldman?

DR. LAKSHMANAN: After the hesitation cuts or--

MR. KELBERG: In this position where the perpetrator is holding Mr. Goldman in the fashion you are holding me?

DR. LAKSHMANAN: Yes, it is possible.

MR. KELBERG: And in what way, doctor?

DR. LAKSHMANAN: Because the location of the perpetrator is in a position where this kind of wound is possible like the demonstration I just--I did.

MR. KELBERG: So in essence does putting your arm--your left arm around my chest to restrain me affect in any way the ability of the right-handed perpetrator from behind to inflict that chest wound?

DR. LAKSHMANAN: Yeah. The only thing is the victim's hand had to be a little bit on the--lifted for the wound to be in that area when the stab wound took place.

MR. KELBERG: And is that something that can be forced by the right arm of the perpetrator?

DR. LAKSHMANAN: Or the victim could be trying to move. As I told you, all these stab wounds and sharp force injuries are dynamic process. It is not a stationary process where a wound takes place, so it is obvious that the arm must have been raised, because the location of the wounds are to the right side of the right chest area, which if the arm is on this side here, (indicating), it will be difficult to do the stab wound, so the arm must have been raised at some point to cause the stab wound in that region. So I really can't tell what exactly took place at that time, but the scenario we enacted is one possible scenario how this stab wound could have been inflicted.

MR. KELBERG: Let's talk about if the knife is held in the left hand to see how that circumstance arises.

DR. LAKSHMANAN: Then again the blunt edge should be in the lower part and the sharp edge of the knife should be in the upper part because that is how the wound configuration of the body surface is surfaces, so it would be something like this, (indicating).

MR. KELBERG: Indicating for the record--

DR. LAKSHMANAN: But the only problem--but it has to be a little more--it is going from the back to front direction, but if I was in front of you, it would be more in a front to back direction, so the direction also should be more in a back to front right to left direction because that is the direction in the body, so the direction in the body doesn't change. So if you are going to enact a scenario, the scenario should match the path in the body.

MR. KELBERG: And so the relative position, if you could retake that position, doctor, the relative position for the left-handed infliction of injury no. 1 has my body turned at a diagonal with my right shoulder closest to you and you then standing at this angle to me so that your left hand is around the back portion of my body to inflict the stab wound; is that accurate?

DR. LAKSHMANAN: Also your arm should be raised because there is no cuts to the arm, you see, so the arm has--cannot be obstructing this entry of this wound in the right chest area, so that also is a factor which must be kept in mind, so when these wounds were inflicted, very likely that the hand of Mr. Goldman was not opposing his body. It was probably up trying to wrestle away from the wound.

MR. KELBERG: And doctor, if, in your opinion, Mr. Goldman had his right arm raised to wrestle away, would that suggest to you that the perpetrator is behind Mr. Goldman, rather than in front of Mr. Goldman?

DR. LAKSHMANAN: That could very well be a scenario.

MR. KELBERG: Now, doctor, as long we are--we have the ruler in your hand, let's see if we could get you back here for injury no 2. Would the same scenarios that you've just demonstrated for the ladies and gentlemen of the jury apply with respect to injury no. 2, the second fatal stab wound seen in photograph G-10?

DR. LAKSHMANAN: Yes. That stab wound, the--it is likely diagonally-oriented, just like the injury no. 1, and here the blunt end is in the back and the sharp end is in the front. You can clearly see it, the blunt end of it.

MR. KELBERG: Let's see if we can get the pointer for you, doctor.

DR. LAKSHMANAN: The dull end of the wound is on the back here, and the sharp end is in the front here, (indicating), and it is diagonally-oriented, so this also is caused by a single-edged knife, and this wound path direction is I think right to left going in a similar fashion as in injury no. 1, but more just in a right to left direction.

MR. KELBERG: Doctor, is that wound also described in Dr. Golden's protocol?

DR. LAKSHMANAN: Yes. It starts on page 8 and continues on to page 9.

MR. KELBERG: And if we can hold up or flip over to page 9, this is a paragraph just above the opinion paragraph for that particular wound. Is that a description by Dr. Golden of the direction of the wound?

DR. LAKSHMANAN: Yes. It goes straight right to left with no other angulation or deviation determined.

MR. KELBERG: And also including a depth of penetration at a minimum?

DR. LAKSHMANAN: Yes. The only issue here is he couldn't give more directions because what you have here is a stab wound which enters a cavity and you don't have an end point to it. It went through the right lung. Unlike the injury no. 1, where the stab wound entered in the back of the right fourth rib, there you have a reference point where the stab wound ended where you can be more definitive about the direction. All you can say here is it went from right to left because it entered a cavity.

MR. KELBERG: Doctor, in your opinion is there anything in the form of a mistake by Dr. Golden for his inability to provide a specific measurement for the depth of the wound?

DR. LAKSHMANAN: It will be difficult to give a full depth of the wound because the stab wound is entering a cavity. That is why he give a minimum total depth of penetration, which is correct thing to do in this situation.

MR. KELBERG: Doctor, from your knowledge of anatomy is that minimum depth of penetration consistent with the description of the injury provided by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me just outline this area first in blue that was talking about the direction. I will outline the entire part of page 9 of the protocol and write "G-10, inj. no. 2," and let me finish off on the previous page with the outline of the beginning description of "G-10, inj. no. 2."

MR. KELBERG: Now, doctor again can you, using the ruler, demonstrate first a right-handed perpetrator and then a left-handed perpetrator to create a direction such as described by Dr. Golden for stab wound no. 2.

DR. LAKSHMANAN: This particular stab wound, the blunt edge is in the back and the sharp edge of the knife is in the front, and it is obliquely oriented, so the stab wound is located somewhere here, (indicating), in the right side the chest right here.

MR. KELBERG: Let me turn just so the jurors can see that area where you are pointing and then I will turn back.

DR. LAKSHMANAN: Somewhere here, (indicating), and all we could say was that it entered the chest cavity. It entered in an area of the chest wall which is called the eighth space which is just below the eighth rib, and it entered in that space, went through the right lung also, perforated the lung, that is, went through and through in the lung causing bleeding. And the direction given is just right to left. It didn't have an end point in the chest cavity.

MR. KELBERG: Doctor, if you could hold that position one more time. Is that the accurate direction, using the ruler to reflect the knife itself, that correlates with this wound description?

DR. LAKSHMANAN: With the description given, this would reflects approximately what happened.

MR. KELBERG: And your Honor, for the record, Dr. Lakshmanan being behind me, is holding the knife--the ruler to represent the knife in his right hand. It has its end touching me. It appears to be slightly above the end opposite--

MR. KELBERG: Is that correct, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And it also has the back end closer to the back of my body than the end touching me.

THE COURT: All right.

DR. LAKSHMANAN: There is one more component to the wound. This wound, if you see, it is much larger, so just like the thigh wound, there has been movement of the body or the knife because there is a cutting component to this particular wound either during penetration or during withdrawal of the knife, which would indicate either the subject moved or the knife moved. It doesn't have just a--it has got a larger appearing gaping wound which would signify that there is a cutting component to the stabbing component.

MR. KELBERG: Doctor, if we asked you again to reenact the position that you did several days ago regarding the superficial incise wound and your left arm around my upper chest and the one you just did for injury no. 1, would the same apply for injury no. 2, that in that position of the perpetrator being behind and restraining Mr. Goldman with his left hand across Mr. Goldman's chest, that injury no. 2 could have been inflicted with the knife held in the right hand?

DR. LAKSHMANAN: That is a possibility.

MR. KELBERG: Now, let's see the alternative of a left hand knife holding situation.

DR. LAKSHMANAN: It will be similar to what we just discussed earlier. The hand has to be elevated a little bit and in this manner, (indicating), which could be one possible scenario how this could have happened with the knife being obliquely oriented to conform--conform to the appearance of the wound on the body's surface.

MR. KELBERG: Your Honor, I cannot see that because of my raised right arm. Would the Court help me out a bit?

THE COURT: Yes. Dr. Lakshmanan has the ruler in his left hand. He is pointing it towards the back of the chest area underneath your right arm, approximately five inches below your right armpit.

MR. KELBERG: Thank you, your Honor.

THE COURT: All right. I think you need to swing around to show the jurors the angle.

MR. KELBERG: This way?

DR. LAKSHMANAN: This manner if the left hand is used.

MR. KELBERG: Thank you, doctor.

MR. KELBERG: Now, doctor, with respect to these two fatal stab wounds, what would be the body's reaction to each them?

DR. LAKSHMANAN: Well, they are fatal wounds. They caused injury to the lung, and you have bleeding, and you also have, compromising the ability to breathe, you have bleeding and you also have compromising of the bleeding--I'm sorry, breathing because blood accumulation in the chest cavity will compromise your breathing.

MR. KELBERG: What kind of bleeding volume wise would you expect from the individual wounds and then the combination of the two stab wounds?

DR. LAKSHMANAN: You will have a significant amount of bleeding because the lung is very vascular structure, and actually the total blood volume of the body can circulate in the lung in a minute's time, but generally these wounds bleed and you can have death--I mean you can lose blood pressure rapidly. If there is an accumulation of blood and air in the chest cavity, so you can expect death in a very short time after the injury.

MR. KELBERG: Assuming no other injuries have been received by Mr. Goldman, do you have an opinion as to the approximate minimum length of time the combination of those two fatal stab wounds would require before Mr. Goldman died?

DR. LAKSHMANAN: Well, it could--because bleeding is a significant component, it could be within a few minutes without medical treatment.

MR. KELBERG: Now, doctor, would the blood from either/or both of those fatal stab wounds go in any particular area, internally, externally or both?

DR. LAKSHMANAN: Because it is a fractured rib in the right, injury no. 1, you could have some external bleeding also, but generally these kind of injuries bleed more internally than externally.

MR. KELBERG: Why is that, doctor?

DR. LAKSHMANAN: Because, first of all, because of the muscle arrangement in the chest wall and also the muscle arrangement between the ribs, the plane which you get may not necessarily be like a defect in a--it won't be a defect which will just open up to the outside because of the varying and amounts of the muscle arrangements in that area, because even though there is a defect in the skin, the defect inside the structures underlying the skin may not have the same plane as the injury itself.

MR. KELBERG: The same plane, P-L-A-N-E?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, did Dr. Golden describe in any fashion a volume of blood found inside this area of the body during the course of the autopsy?

DR. LAKSHMANAN: Yes. He described hundred to 200 cc of blood in the right chest cavity.

MR. KELBERG: Let's see if we could find the entry that you are referring to.

DR. LAKSHMANAN: Umm, it is described 100 to 200 cc in the right chest here under injury no. 1, and he described the same amount--

MR. KELBERG: Before you flip the page, let me just underline that. And for the record, I have underlined in blue in the third pull paragraph of item 1 of page 8 of the protocol.

DR. LAKSHMANAN: I think he described it--this is only one hemothorax belonging to both the wounds, 100 to 200 cc.

MR. KELBERG: And a "Hemothorax" means what, doctor?

DR. LAKSHMANAN: Blood in the chest cavity.

MR. KELBERG: So there is no additional quantification by Dr. Golden of the blood found in this area?

DR. LAKSHMANAN: That's correct. He said the total amount present in the right chest cavity was 100 to 200 cc.

MR. KELBERG: Doctor, how would you characterize a volume of 100 to 200 cc's in that chest cavity?

DR. LAKSHMANAN: A very small amount.

MR. KELBERG: Given the nature of the volume described, assuming that it has been accurately quantified, what significance, if any, does that have to you in evaluating when, in relationship to the whole assault, Mr. Goldman received those two fatal stab wounds?

DR. LAKSHMANAN: Before I answer the question I would like to point out also that he has been lying on--

MR. SHAPIRO: Your Honor, I would object; nonresponsive.

THE COURT: Sustained. Rephrase the question, please.

MR. KELBERG: Thank you, your Honor.

MR. KELBERG: Doctor, let's go back then as you were about to point to exhibit 43-E, the copy of the photograph with that exhibit designation that we have on our board, is there something of significance on this issue of how much blood is found at autopsy in the chest cavity from the position that Mr. Goldman's body is in in that photograph?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What is significant?

DR. LAKSHMANAN: He is found on his right side, lying on the right side when he was found initially, and also if you look at the clothing, the right side of the shirt and other areas are pretty densely stained with blood, so one of the factors one must keep in mind is the dependent drainage of blood from the chest cavity, blood from the stab wound, because one lies on the right side.

MR. KELBERG: Doctor, you examined, I think you've testified, the shirt Mr. Goldman was wearing at the time his body was found?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And you have also examined the body both on the 13th and the 14th; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Did you find, in examining the shirt, that the shirt appeared more blood stained on the right side than on the left?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, does this draining of blood when Mr. Goldman is in the position as seen in the photograph that we've marked 43-E, does that staining--does that external blood flow continue even if Mr. Goldman's heart has stopped pumping?

DR. LAKSHMANAN: Because it is liquid blood in a cavity which can just ooze out through the defect in the chest wall.

MR. KELBERG: Is the blood staining you see in the right side of Mr. Goldman's shirt consistent with that kind of action, that is, drainage out of the wound itself?

DR. LAKSHMANAN: That could be one way that staining occurred.

MR. KELBERG: Doctor, is there any other wound that you have identified in this area of Mr. Goldman's body covered by the right portion of his shirt that has the blood staining that you see in photograph G-1, other than the ones that are shown in the photograph G-10?

DR. LAKSHMANAN: No.

MR. KELBERG: Is there any other source that you can think of, from your examination of the information and the photographs, which could be the source for the blood staining to the right side of the shirt, other than the two fatal stab wounds and the third sharp force injury you've identified but haven't described in much detail yet, in photograph G-10?

DR. LAKSHMANAN: The shirt is also stained in the shoulder area and in the side area, so some of the blood of the shoulder area could be from the neck wounds, but as far as the chest goes, these are the only two wounds there which can account for this kind of staining.

MR. KELBERG: Doctor, given that finding, does that serve as any basis for you to determine whether in fact the volume of blood that originally was in the chest cavity, after these wounds were inflicted, was greater than what was recorded at autopsy by Dr. Golden?

DR. LAKSHMANAN: That would suggest that.

MR. KELBERG: And doctor, if that were the case, that some of this blood flowed out due to the effects of gravity, would that affect your ability to assess when in relationship to the attack those two fatal stab wounds were inflicted?

DR. LAKSHMANAN: It would favor that it occurred during the earlier part of the attack rather than latter part of the attack, but again, I want to emphasize that there are other significant injuries on Mr. Goldman, including the aortic injury and the internal jugular vein injury. And if, as I opined earlier, that they could have all been sustained within a minute's time you may not have much accumulation in the chest cavity, too, if they occurred rapidly after each other.

MR. KELBERG: Even if inflicted early on in the course of all of the wounds being inflicted?

DR. LAKSHMANAN: Because you have the aortic wound which would bleed more than the chest wound at that point.

MR. KELBERG: We have not discussed the aortic wound yet, have we?

DR. LAKSHMANAN: No, we have not.

MR. KELBERG: Doctor, I want to correlate, if a correlation is appropriate, the two fatal stab wounds to the chest and the thigh wound that you described as one which Mr. Goldman must have been in an upright position to have received based upon the blood staining pattern of the left leg. Is there anything medically inconsistent, doctor, with those two fatal stab wounds to the chest having been inflicted by the perpetrator holding the knife in the right hand and restraining Mr. Goldman, with the left hand being behind Mr. Goldman, and thereafter Mr. Goldman, in his effort to break free, breaking free in a position so that he is now face-to-face with the perpetrator and the perpetrator stabbing Mr. Goldman with his right hand still holding the knife in the area of the left thigh as you demonstrated earlier this afternoon?

MR. SHAPIRO: Objection, improper hypothetical.

THE COURT: Overruled.

MR. KELBERG: You may answer the question.

DR. LAKSHMANAN: So let me understand your question. The stab wound to the chest takes place while the perpetrator is in the back and the victim turns and then the stab wound to the thigh is inflicted in rapid succession?

MR. KELBERG: Yes.

DR. LAKSHMANAN: That is--

MR. KELBERG: Anything inconsistent with that--

THE COURT: Medically inconsistent.

MR. KELBERG: Medically inconsistent with that hypothetical set of circumstances?

DR. LAKSHMANAN: Medically there is nothing inconsistent with that, but I would like to add that I also examined the clothing of Mr. Goldman wherein we have defects in the clothing. The larger defect in the clothing corresponds to the smaller wound here.

MR. KELBERG: Which wound, I'm sorry, doctor?

DR. LAKSHMANAN: The one in the right front of the chest. And the smaller defect in the clothing corresponds to the larger wound, which would indicate to me that probably the clothing was not in the same position as the wound when those wounds were inflicted. Again this is only a possibility.

MR. KELBERG: Doctor, from what you observed in the shirt, were the wounds in a position--I'm sorry--the defects in the shirt in a position which would be consistent with the perpetrator holding the shirt upright so as to twist the shirt from its normal position on the body?

THE COURT: Holding the shirt upright?

MR. KELBERG: Pulling it in a direction up toward--doctor, have you ever followed hockey?

DR. LAKSHMANAN: Not much.

MR. KELBERG: Okay. Have you ever tried to pull a sweater off over the top of your head?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Would this location of the defects in the shirt be consistent with somebody trying to pull the shirt over Mr. Goldman's head?

DR. LAKSHMANAN: No. It would be more like the shirt moving around the body rather than in a top/down direction.

MR. KELBERG: And in the movement would that be consistent with Mr. Goldman trying to twist and turn to break free of any restraint that is being imposed on him?

DR. LAKSHMANAN: That would be more likely a possibility than the former possibility you brought up.

MR. KELBERG: And if in fact that was the circumstance of Mr. Goldman trying to twist and turn to break free of the person retraining them, who is behind him, holding knife in the right hand, is there anything medically inconsistent with those two fatal stab wounds being inflicted first followed by--when I say "First" I just mean relative to the thigh injury--being inflicted first and then as Mr. Goldman breaks free and is more in a face-to-face relationship with the perpetrator, to have the perpetrator with the knife still in the right hand moving that knife forward to get the area of the left thigh?

DR. LAKSHMANAN: Nothing medically inconsistent with that possibility.

MR. KELBERG: And even with the effects of those two fatal stab wounds to the right chest area, doctor, medically, could Mr. Goldman still have experienced the kind of bleeding from this left thigh stab wound which would be consistent with the blood flow seen on the bottom or down the length of the left pant leg, his jean?

DR. LAKSHMANAN: Umm, it is possible that that happened, but given the amount of bleeding, I would favor the thigh wound occurred before the stab wounds to the chest.

MR. KELBERG: Why is that, doctor?

DR. LAKSHMANAN: Because the thigh wound didn't hit any major vessel and there is a significant amount of blood staining on the limb portion of the jean, and that could--that means without any major vessel injury there is significant bleeding, that means this occurred earlier in the altercation.

MR. KELBERG: Does the type of injury to the right chest that you expect from those two fatal stab wounds impact directly on the volume of blood that flows to the lower half of the body?

DR. LAKSHMANAN: No.

MR. KELBERG: And if that is in fact the case--

DR. LAKSHMANAN: I'm sorry, it does impact in a way, but not directly, because you have bleeding into the chest cavity, but not directly.

MR. KELBERG: Let me contrast that for a moment and invite your attention to photograph G-8. You talked about the aortic wound, I believe?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that seen in photograph G-8?

DR. LAKSHMANAN: Yes, it is seen on the left flank here, (indicating).

MR. KELBERG: And is that a fatal stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Can you point out on your body, doctor, approximately where that is on the human anatomy?

DR. LAKSHMANAN: It is around here on the left flank. I'm pointing to it right here, (indicating).

MR. KELBERG: Your Honor, about the midline between the front and back of the body and about maybe three inches up from the belt line.

THE COURT: Yes.

MR. KELBERG: Now, doctor, from what you know of this fatal aortic stab wound, medically, would that stab wound affect the volume of blood that could flow to the lower parts of the legs of Mr. Goldman's body?

DR. LAKSHMANAN: Yes, it would, because the flank wound hit the aorta about one and a quarter inches above the bifurcation. You see, the aorta is a large vessel in the abdominal portion and it divides into two branches which supply the lower extremities, which is your thighs and legs, and the--that is why I feel that the thigh wound occurred before the aortic wound, because if the aortic wound occurred earlier, you won't have that much bleeding in the thigh wound because the bleeding would be occurring inside the abdomen from the aortic wound.

MR. KELBERG: Doctor, is that what you would describe as a direct impact between the aortic stab wound and the blood supply available to the lower limbs where the thigh wound is inflicted?

DR. LAKSHMANAN: Yes, that is what I meant by direct impact.

MR. KELBERG: The chest wounds, the two fatal chest stab wounds, do they have that same direct impact on the volume of blood that flows to the lower extremities?

DR. LAKSHMANAN: Not directly as we just discussed.

MR. KELBERG: And how do they indirectly, if at all, affect the blood volume that flows to the lower extremity, the legs?

DR. LAKSHMANAN: What exactly happens is there is only so much blood in the body, as I told you several times in this last few days. The total blood volume in the body is 5.5 liters, and if you have blood loss in one place, the body still tries to maintain blood pressure so that the rest of the key areas of the body get blood supply. So even though there is blood loss--there is blood loss, that wouldn't affect the total blood volume, the mechanism inside the body, which includes the sympathetic nervous system, helps to maintain the blood pressure, but whereas if you have an aortic injury, which would be a direct injury to the vessel, in relation to the thigh wound, it would definitely impair the blood supply to the thigh, because the aortic injury occurred earlier, and that is why it is a direct impact in contrast to this. It is a loss of blood to an area, but not a direct impact to the--umm, as far as the thigh wound goes.

MR. KELBERG: As a result, doctor, is it, in your judgment, more plausible that you can have the thigh wound be incurred after the two fatal stab wounds to the chest and still end up with the blood flow that you see in the pant leg, the left pant leg, than it would be to have the aortic stab wound incurred before that same thigh wound?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Doctor, I don't think we've covered the diagramming, if there was any diagramming, of these two injuries 1 and 2, the fatal stab wounds, have we?

DR. LAKSHMANAN: No.

MR. KELBERG: We have--

DR. LAKSHMANAN: We have not covered the diagramming.

MR. KELBERG: Doctor, we've covered--is there anything else you want to tell us just in general terms about injuries numbers 1 and 2 before we go to the diagram?

DR. LAKSHMANAN: Nothing else. I have addressed the structures they caused injury to. I have addressed the clothing defects. I have addressed the--them being caused by a single-edged knife. I have discussed that they are fatal wounds. I don't think--I have nothing else to add.

MR. KELBERG: One thought I just had pop into my head and I wanted to ask you about, did you examine the jean leg, the left leg and the defects that you described you observed in that left leg, with respect to the location of the left thigh wound injury?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: What were your findings, if any?

DR. LAKSHMANAN: He had a defect in the outer aspect of the jean and he had two additional defects in the pocket underlying the defect in the jean, which would indicate that the stab wound went through the outer garment layer, through the pocket layers and then entered the thigh.

MR. KELBERG: Was there anything inappropriate about the location on the clothing of the defects with respect to the location on the body of the wound, such as you described you found with the defects in the shirt, in relationship to the two fatal chest stab wounds?

DR. LAKSHMANAN: No.

MR. KELBERG: And what, if any, significance did that have to you in talking about the circumstances of Mr. Goldman receiving that fatal--I'm sorry, that thigh stab wound?

DR. LAKSHMANAN: Nothing really much significant, because the--the--the limb portion of a jean is more fixed than a shirt on a trunk of a body.

MR. KELBERG: Anything further, doctor, about then the two fatal chest wounds?

DR. LAKSHMANAN: No.

MR. KELBERG: Your Honor, 3:30? We are going to set up another--

THE COURT: Go ahead.

MR. KELBERG: All right. We won't set it up anywhere but right here.

(Brief pause.)

MR. KELBERG: Doctor, I have put on the board, this is board 3G of our collection 357, the 21 series. Is one of these forms used by Dr. Golden to describe in a diagrammatic fashion the stab wounds 1 and 2 of the photograph G-10?

DR. LAKSHMANAN: Yes, it is in 21-II. It is injury number no. 1 is here and injury no. 2 is there, (indicating).

MR. KELBERG: I'm sorry, doctor, if you will point and hold the pointer, where is injury no. 1?

DR. LAKSHMANAN: This is 1 here, (indicating).

MR. KELBERG: What is the writing that is associated with any diagrammatic representation?

DR. LAKSHMANAN: It says, "Mid-axillary line" and he has just put the location on this diagram.

MR. KELBERG: What is the mid-axillary line?

DR. LAKSHMANAN: That is an imaginary line which passed through the middle of your armpit, if you raise your arm up. I'm sorry, I can't raise my left shoulder very well.

MR. KELBERG: Do you want me to raise mine, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What do you want me to do?

DR. LAKSHMANAN: Just lift and turn this way.

MR. KELBERG: (Mr. Kelberg complies.)

DR. LAKSHMANAN: The armpit area is the axilla, medical term. Mid-axillary line is the imaginary line which runs in the mid-portion of your armpit and down the side of the body, so it is an imaginary line and any injury in that area is described as such.

MR. KELBERG: I think that is pretty self-explanatory for the record, your Honor.

THE COURT: It is.

MR. KELBERG: All right, doctor. Now, I want to circle this area. Is this the appropriate area for fatal stab wound injury no. 1 of G-10?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. I will circle that area in red on the left side of 21, roman numeral II, and I will write "G-10 inj. no. 1."

MR. KELBERG: Where was the second fatal stab wound, doctor?

DR. LAKSHMANAN: Here, (indicating). It is right on the--behind it on the side flank area.

MR. KELBERG: Is there any writing associated with that particular injury?

DR. LAKSHMANAN: No. It just says no. 2 there.

MR. KELBERG: And I will circle that area then in blue and to the side write "G-10 inj. no. 2."

MR. KELBERG: Is there any other diagram, used by Dr. Golden?

DR. LAKSHMANAN: Yes. There is a diagram of the--which also shows the skeletal area of the body with the outline of the body.

MR. KELBERG: Did you have a form number for that, doctor?

DR. LAKSHMANAN: I think it is 2--I forget the number for it.

MR. KELBERG: Let's try board 7G?

DR. LAKSHMANAN: There it is.

MR. KELBERG: And this is the second page of that form 20H with schematic representations of the human order front and back with a skeleton outline, your Honor.

THE COURT: Yes.

DR. LAKSHMANAN: He has described both injuries and I have to help you with this one.

MR. KELBERG: If you would, please.

DR. LAKSHMANAN: Yes. This part he refers to the injury no. 1, stab wound going to the right seventh rib, and in this area here, (indicating).

MR. KELBERG: What does he say there, doctor?

DR. LAKSHMANAN: "Stab wound right seventh rib" and that is no. 1.

MR. KELBERG: Let me--before you go on, let me circle that area and I will write "G-10 inj. no. 1."

DR. LAKSHMANAN: And then it continues, "Right to left back to front, striking chest wall." The length of the stab wound is four inches, and then he continues that it ends in the back of the right fourth rib, and the--he has got two--two defects in the right lung, half an inch and 3/4 inch, and that covers the injury--this includes the pleural--

MR. KELBERG: Keep your voice up.

DR. LAKSHMANAN: It says the pleural areas of the lung have these measurements, have an inch and 3/4 inch, so this would also correspond to that wound.

MR. KELBERG: To injury no. 1?

DR. LAKSHMANAN: Yes, all this, (indicating), because that is where the fourth rib is on the front, but the knife cut the back of the fourth rib inside the chest cavity.

MR. KELBERG: If we can slow down here so I can try and keep up with you, doctor, you pointed now to the left side of the diagram in some area?

DR. LAKSHMANAN: The right side of the diagram--right side of the body, left side of the diagram.

MR. KELBERG: All right. Is this area here, (indicating), also to represent injury no. 1?

DR. LAKSHMANAN: Also this one here, mid-clavicle line.

MR. KELBERG: What does "MCL" mean?

DR. LAKSHMANAN: Mid-clavicle line. That is another imaginary line. You have your collar bone here and an imaginary line which runs in the mid-portion of the line in front of the body is the mid-clavicle line.

MR. KELBERG: Let me circle that area that you described on the left side of there, 28, and I will write again "G-10 inj. no. 1." And does the Court wish to take a break at this point?

THE COURT: Yes, I do.

MR. KELBERG: We will take it up after the recess.

THE COURT: Ladies and gentlemen, I need to take a 15-minute court reporter recess. Please remember all my admonitions to you. This will be a 15-recess. Let me see counsel with the court reporter, please.

(The following proceedings were held at the bench:)

THE COURT: We are over at the side bar out of the presence. Counsel, no. 1290 needs to see her doctor regarding her hip and the only day that we could get her appointment is Thursday, and so Thursday, instead of going to 6:00, we are going to have to quit at 4:45.

MR. COCHRAN: Sorry.

MS. CLARK: Heartbroken.

MR. COCHRAN: Is she the one who fell out there?

THE COURT: Yes, yes, so we are going to break at 4:45 Thursday so she can make her appointment, okay, but she says she doesn't need to go now but she would like to go this week.

MR. COCHRAN: That is fine with us.

THE COURT: See you later.

MR. COCHRAN: Thanks, Judge.

THE COURT: He is going to some other courtroom.

(Recess.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Let me see counsel at sidebar with the court reporter.

(Pages 31793 through 31794, volume 166-A, transcribed and sealed under separate cover.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Back on the record. The Defendant is present with his counsel, Mr. Douglas and Mr. Shapiro, People represented by Mr. Kelberg and Mr. Lynch. All right. Deputy Magnera, let's have the jurors, please.

(The following proceedings were held in open court, in the presence of the jury:)

THE COURT: Thank you, ladies and gentlemen. Please be seated. Let the record reflect we've been rejoined by all the members of our jury panel. Dr. Lakshmanan is again present before the Court. And, Mr. Kelberg, you may continue concluding your direct examination.

MR. KELBERG: Thank you, your Honor.

MR. KELBERG: Doctor, again with the Court's permission, would you step back to the easel, and we'll go back on this 21 form and see if we can identify-- I want to be sure--I think actually we need the other--yes, I'm sorry. We need the other--the 7G board that has the skeletonized schematic. We've identified by marking in red in a designation of G-10, injury no. 1, two areas of this diagram, and then I think, doctor, you had pointed out another area in the lower right-hand corner of this form that refers to injury no. 1, but I want to be sure. So can we again slowly go through what additional entries if any on this form refer to that fatal stab wound, injury no. 1 of G-10?

DR. LAKSHMANAN: We went over the portion of the seventh rib which was injured by the injury no. 1 as it entered the chest cavity. This part of the diagram on the left side on the--shows some markings with reference to the right fourth rib area wherein the stab wound ended (indicating), and the description of that injury to the right fourth rib is reflected in the lower partion of--lower portion of the diagram, posterior right fourth rib, 3/4 inch cut, and then--

MR. KELBERG: Keep your voice up if you would, please, doctor. Is this some form of diagram by Dr. Golden concerning his observation in that area?

DR. LAKSHMANAN: It appears to be, yes.

MR. KELBERG: And what do you interpret that to be a diagrammatic representation of?

DR. LAKSHMANAN: He's trying to show a cut of the right posterior fourth rib.

MR. KELBERG: And in general, doctor, is that a shape that you would find consistent with a single-edged knife such as you identified had to have been the source of that fatal stab wound?

DR. LAKSHMANAN: I cannot make that conclusion from a cut on the posterior surface of the rib.

MR. KELBERG: Why not?

DR. LAKSHMANAN: Because it's just a cut on the posterior surface of the rib. You cannot make any determination from that. And then you have two wounds to the right lower lobe of lung, which indicates that those are entering portion and a exiting portion that is--it was a through and through type of wound to the right lung.

MR. KELBERG: And does all of that still refer to this injury no. 1?

DR. LAKSHMANAN: Yes. All of this up to this point (indicating).

MR. KELBERG: All right. And you've just pointed, before you moved backwards, to another area, and I'm not sure you've interpreted that writing for us, if you can.

DR. LAKSHMANAN: It says plural superficial--I can't read this word here, but basically it refers to these defects in the right lower lobe of lung.

MR. KELBERG: All right. Then for the record, I'll take the blue marker and mark this area of writing that the doctor has just outlined, circle it in the blue and write at the lower left-hand margin "G-10, inj. no. 1."

DR. LAKSHMANAN: Yes. Also, this inscription here, the right lower part of the diagram, also reflects to the same injury.

MR. KELBERG: And what is that description?

DR. LAKSHMANAN: It shows the direction right to left, back to front and the length of the wound track to be 4 inches.

MR. KELBERG: And there's some other writing. Can you make that out, doctor?

DR. LAKSHMANAN: Striking chest wall, and I think this is--says posterior probably reflecting to the right fourth rib posterior aspect.

MR. KELBERG: Again, all of this is still injury no. 1?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I'll circle that area in blue as well and write "G-10 inj. no. 1." What else, doctor?

DR. LAKSHMANAN: This part of the diagram reflects the entry portion of injury no. 2 (indicating), goes to the right eighth space and back to front direction, and I can't read this particular inscription here, but basically this reflects the information pertaining to injury no. 2.

MR. KELBERG: Has Dr. Golden made any kind of diagrammatic entry on the right form of the skeleton--skeletonized human form to represent that second stab wound, that fatal stab wound injury no. 2?

DR. LAKSHMANAN: Yes. Here in the right rib space (indicating).

MR. KELBERG: All right. Let me circle that area in blue and I'll write out at the side "G-10" or actually at the top "inj. no. 2." And the written description that the doctor just referred to a moment or so ago, I'll circle in blue and make a line connecting back up to where the actual wound is drawn in on that same diagram. All right, doctor. Have we covered all of the entries? It seems to me we have some information here.

DR. LAKSHMANAN: Yes.

MR. KELBERG: What if anything does that refer to?

DR. LAKSHMANAN: That refers to the stab wound to the left flank. It reflects stab wound going through skin "Subcu" and iliopsoas muscle and aorta. So that refers to the left flank wound.

MR. KELBERG: I think you're going to have to, if you could, please, spell out the muscle that it went through.

DR. LAKSHMANAN: Iliopsoas, I-L-I-O-P-S-O-S--P-S-O-A-S.

MR. KELBERG: And, doctor, is this the aortic wound that we saw briefly in photograph G-8?

DR. LAKSHMANAN: Yes.

MR. KELBERG: So while we've got this up, let me circle this area in red, and I'll write "G-8." Is there any more than the one--I believe you described that as a fatal stab wound, did you?

DR. LAKSHMANAN: Yes. G-8. You also have diagram--

MR. KELBERG: Is there more than one injury? I just want to find out if there's any need to designate an injury--

DR. LAKSHMANAN: There's only one injury there.

MR. KELBERG: I think what I'll write is "Fatal aortic stab wound." Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Have we covered all of the written information then on this form?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Any other diagram concerning these two fatal stab wounds to the chest?

DR. LAKSHMANAN: No.

MR. KELBERG: Is either of them addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any need to in your opinion?

DR. LAKSHMANAN: No.

MR. KELBERG: Now, you mentioned that there were other injuries or findings in the photograph G-10, and I believe one of them you indicated was a sharp force injury as well; is that correct?

DR. LAKSHMANAN: Yes. I call it injury no. 3 and it's a 3/8 inch sharp force injury which is superficially located to the--mainly running superficially on the skin of the right flank.

MR. KELBERG: Can you point it out first of all? This is on photo G-10?

DR. LAKSHMANAN: (indicating).

MR. KELBERG: For the record, it appears to be in the center of the body that's depicted in the photograph and about an inch or so above the top edge of the blue photographic identification card?

THE COURT: Yes.

MR. KELBERG: Doctor, what kind of injury is that?

DR. LAKSHMANAN: It's a sharp force injury which superficially--it's a superficial injury. It's not deep. It did not penetrate the abdominal cavity.

MR. KELBERG: Given its superficial nature, is this one of those sharp force injuries where you cannot by the form tell whether this is due to a single-edged knife or a double-edged knife?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: But is it consistent again with this same hypothetical approximately 6-inch long single-edged knife blade tapering at the tip?

DR. LAKSHMANAN: Yes.

THE COURT: Excuse me. Dr. Baden, could I ask you to--you're standing in front of the court reporter.

MR. KELBERG: Is that superficial sharp force injury, doctor, described by Dr. Golden in the protocol?

DR. LAKSHMANAN: Yes, he has.

MR. KELBERG: Diagrammed anywhere?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Addressed anywhere in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Any need to?

DR. LAKSHMANAN: No.

MR. KELBERG: Are you able to determine when in relationship to the time of death that injury was inflicted?

DR. LAKSHMANAN: It happened before that.

MR. KELBERG: How are you able to tell?

DR. LAKSHMANAN: Because of the appearance of the description.

MR. KELBERG: Is there anything of significance to the--to you--may I withdraw the question? Are you able to tell anything with respect to the relative positions of Mr. Goldman and the perpetrator from what you see in that particular sharp force injury?

DR. LAKSHMANAN: No, I will not be able to.

MR. KELBERG: Is there anything else that you wish to bring to our attention regarding that sharp force injury?

DR. LAKSHMANAN: No.

MR. KELBERG: Why don't we see where it is in the protocol and see where it is in the diagrams.

DR. LAKSHMANAN: It's on page 9, no. 3. It's located here (indicating), page 9, no. 3, stab wound to right flank. This whole description applies to that.

MR. KELBERG: Doctor, in your opinion, is this an accurate description of what you see in that photograph?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me just outline this in red on our protocol, page 9. This is "G-10 inj. no. 3," which I've written in the left margin.

DR. LAKSHMANAN: Yes.

MR. KELBERG: Where is it diagrammed, doctor?

DR. LAKSHMANAN: It's diagrammed in 21-II.

MR. KELBERG: And we'll put our board right over the protocol. This is 3G. Which form, doctor?

DR. LAKSHMANAN: 21-II (indicating).

MR. KELBERG: And you're pointing to an area. Is there some kind of squiggly line slightly above and to the right of it as you look at the diagram?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I was actually looking--

DR. LAKSHMANAN: No, no. This one is the sharp force injury. This is just the first one, no. 3 next to it (indicating).

MR. KELBERG: So this is what you've just identified as injury no. 3 of G-10, where I'm pointing?

DR. LAKSHMANAN: Yes. Yes.

MR. KELBERG: And this "3" is Dr. Golden's arbitrary designation of wound numbers?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Let me circle that area in red, left side, and I'll write out to the side "G-10 inj. no. 3." Anything further with respect to that injury, doctor?

DR. LAKSHMANAN: Nothing else.

MR. KELBERG: All right. You also testified that there were other findings you made reviewing this photograph G-10. What are those findings?

DR. LAKSHMANAN: There are some postmortem abrasions between injury 1 and 2 and 3 here (indicating) and--

MR. KELBERG: Do you have an opinion as to the cause for those postmortem abrasions?

DR. LAKSHMANAN: No. Non-specific postmortem abrasions.

MR. KELBERG: Doctor, in your opinion, can those postmortem abrasions be due to the manner in which the body was transported from the Bundy location to the Forensic Science Center, the Coroner's office?

DR. LAKSHMANAN: As one--one possible scenario. The other possible scenario is him lying on the right side rubbing--with the clothing rubbing against the area. There are many possibilities for that postmortem abrasion.

MR. KELBERG: If the body is not moving and Mr. Goldman for all intents and purposes is dead or actually is dead and his body is in that position that's shown in 43E, the photograph in our 362 collection, can you still have that kind of postmortem abrasion occurring even if the clothing is not moving against the body?

DR. LAKSHMANAN: No. Because of the clothing pressure itself, you can have sometimes abrasions on the skin surface.

MR. KELBERG: Simply from the pressure?

DR. LAKSHMANAN: From the right side. It's just a postmortem abrasion. It's difficult to specify how it was caused.

MR. KELBERG: All right. Any other injuries-- first, let me ask, does Dr. Golden describe this in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Diagram it anywhere?

DR. LAKSHMANAN: He--he doesn't describe it in the protocol, but he diagrams it.

MR. KELBERG: Where does he diagram it?

DR. LAKSHMANAN: It's right here (indicating), this line here you see here.

MR. KELBERG: Doctor, did you give an injury designation to this area, postmortem abrasion?

DR. LAKSHMANAN: I just called them collectively as injury no. 4.

MR. KELBERG: And is there some writing that you associate with Dr. Golden's diagrammatic representation?

DR. LAKSHMANAN: Yes. It says "Postmortem"--I can't read this, but basically I think refers to that marking there (indicating).

MR. KELBERG: Then I'll circle this area in blue that you've just outlined, and I'll write below it "G-10, inj. no. 4." Anyplace else it's diagrammed?

DR. LAKSHMANAN: No.

MR. KELBERG: And I'm sorry. It is not described in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Is that a mistake?

DR. LAKSHMANAN: Well, it's a postmortem abrasion. Yes, it's a mistake.

MR. KELBERG: Any significance?

DR. LAKSHMANAN: No.

MR. KELBERG: Same reasons?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything further on injury no. 4?

DR. LAKSHMANAN: No.

MR. KELBERG: Any other findings or injuries in this particular photograph?

DR. LAKSHMANAN: There's also area of postmortem abrasions below the right--and below the injury no. 2 in the right chest.

MR. KELBERG: Are you able to differentiate hypothetically the causes for that, such as transportation versus pressure from clothing?

DR. LAKSHMANAN: No.

MR. KELBERG: Basically, would your answers be the same regarding that as they were for the injury no. 4 postmortem abrasions?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Did Dr. Golden describe that area in his protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: How about diagram it anywhere?

DR. LAKSHMANAN: He--he has diagrammed some shading here (indicating) near the no. 2. And the line which reads "Postmortem" reflects both those areas. So I'm not sure whether he diagrammed that collectively with this other postmortem abrasion which we have here.

MR. KELBERG: And is this area by you arbitrarily designated as no. 5?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Why don't we write "No. 4"--after no. 4, we'll write "No. 5" and put a question mark because of your uncertainty. Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything else in this photograph G-10?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything in the addendum regarding these last injuries?

DR. LAKSHMANAN: No.

MR. KELBERG: All right. Let's go back then to G-8 and discuss in greater detail this fatal aortic stab wound.

DR. LAKSHMANAN: G-8 shows the stab wound entering the left flank, and this wound measured in my measurement 5/8 inch by 3/8 inch in the gaping state, but it's part of the body which is--which has a curvature to the area. So the measurement in the protocol is 3/4 of an inch in length.

MR. KELBERG: Is this one of the areas of the body where you obtained a measurement different than Dr. Golden's and where the difference in measurement from his may be attributable to the process of photographic measurement?

DR. LAKSHMANAN: Yes.

MR. SHAPIRO: Objection. Calls for speculation.

THE COURT: Overruled.

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, what else can you tell us about this fatal stab wound?

DR. LAKSHMANAN: This particular stab wound entered the abdominal cavity, went through the iliopsoas area, which is a muscle in the back of the abdominal wall.

MR. KELBERG: Would you turn towards the ladies and gentlemen of the jury and point out where this wound is actually?

DR. LAKSHMANAN: Right here in this area I pointed out earlier in the left flank (indicating).

MR. KELBERG: All right. And the record I think earlier was described.

DR. LAKSHMANAN: Went to the ilipsoas muscle, then struck the aorta one and a quarter inches above where it divides into two branches. And there were two defects in the aorta, two half-inch defects in the aorta and there was bleeding from this injury which resulted in accumulation of blood in what is called the retroperitoneal area, that is in the back side of the abdomen, and also there was some blood accumulation in the abdominal cavity.

MR. KELBERG: Doctor, first of all, why is this in your opinion a fatal stab wound?

DR. LAKSHMANAN: Because of the injury to the aorta, which is a large blood vessels--largest blood vessel in the body, and injury to this structure will result in bleeding and rapid loss of blood pressure and death.

MR. KELBERG: Doctor, in this position that Mr. Goldman's body is found as shown in photograph 43E of our collection 362, is this area of the body not a dependent part?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is that of some significance to you-- let me rephrase the question. Would you expect--where would you expect the blood to go? You said the retroperitoneal cavity and the abdominal cavity; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Retroperitoneal area and the abdominal cavity; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Would you expect blood to come outside of the body from this fatal stab wound?

DR. LAKSHMANAN: Generally not because it will mainly bleed inside.

MR. KELBERG: Would this be the kind of wound like the chest wounds which could drain out of the body if the wound was in a position where gravity could result in the blood flowing down out through the stab wound itself?

DR. LAKSHMANAN: You would not expect this in the abdominal wound. And the only reason I said that in the chest wound also is because of the fractures of the--I mean the stab wound having gone to the rib which would have created a defect. But in this wound, I would not expect it. Usually in such wounds, the bleeding is more internal than external.

MR. KELBERG: And Dr. Golden in his protocol, did he quantify the amount of blood he observed in the course of the autopsy in the areas where you believed bleeding would occur as a result of that fatal stab wound?

DR. LAKSHMANAN: Yes. He said there was hundred cc blood in the abdominal cavity in addition to the bleeding he described in the retroperitoneal area, which was not quantitated.

MR. KELBERG: Was not quantified?

DR. LAKSHMANAN: It's not quantifiable.

MR. KELBERG: Can you give us some idea how big the retroperitoneal area is in a human body?

DR. LAKSHMANAN: It's a fairly--fairly large area, the area in the back of the abdomen. Actually, it extends all the way from the--above the kidney area down below including the pancreas and other structures in the back of the abdomen.

MR. KELBERG: From Dr. Golden's description of the hemorrhage in that area and his quantification of the hemorrhage in the abdominal cavity, do you have an opinion when in relationship to the attack itself that abdominal aorta fatal stab wound was incurred?

DR. LAKSHMANAN: As I opined earlier, I think it occurred during the middle of assault, but it definitely occurred I would favor after the thigh wound which occurred earlier than the abdominal wound.

MR. KELBERG: Doctor, how rapid a response from the body would you expect from that fatal stab wound?

DR. LAKSHMANAN: Could you explain your question further? What do you mean by "Rapid response"?

MR. KELBERG: In a mechanism as a result of that stab wound, what if anything does the body do to try and preserve life?

DR. LAKSHMANAN: Basically, as I told you, there is a part of your nervous system which is involuntary and it's called the sympathetic nervous system that comes to play so that-- because of the loss of blood, the body tries to maintain the blood pressure at any cost, and this involuntary nervous system is brought into play so that the vessels constrict in the other parts of the body so that--and also, the blood coming into the heart from the venous system is also increased so the blood pressure is maintained. So the body tries its best to maintain the blood pressure in this manner until you lose 2/5 the volume. That is the blood volume is five liters. Once you've lost approximately two liters, you will go into shock.

MR. KELBERG: Doctor, assuming that Mr. Goldman had sustained no injury prior to the fatal abdominal aorta stab wound, how rapidly would you have expected him to have died?

DR. LAKSHMANAN: The abdominal aortic wound, you can die within a few minutes, but even less than a minute, depending on the amount of blood lost from those defects. These are big defects in the aortic wall described by Dr. Golden. He said half an inch defects in aortic wall.

MR. KELBERG: And, doctor, assuming that Mr. Goldman had received other stab wounds such as to the chest before that aortic stab wound--and is that your opinion; that he in fact had received those before the aortic stab wound?

DR. LAKSHMANAN: He could have. I said he received the thigh wound before the aortic wound.

MR. KELBERG: Assuming he received the chest wounds, the two fatal chest wounds and the neck wound, the left neck wound, which I believe is injury no. 3 of G-37, injury no. 1 of G-51, before that fatal aortic stab wound, what effect if any would those wounds have had on the length of time you would have expected Mr. Goldman to live once the aortic stab wound had been inflicted?

DR. LAKSHMANAN: It would definitely diminish the amount of time required to go into shock because you already lost so much of the blood volume. As I told you, the blood volume in the body is fixed. If you already lost blood from the neck wound, lost blood from the chest wound and also from the thigh wound--and I already told you if you lose two liters, you go into shock in a normal person. The aortic wound, when it was inflicted, you already lost blood from these other sites. So naturally, the time frame which it would take to go into shock is narrowed, not increased.

MR. KELBERG: And, doctor, do you have an opinion as to a minimum period of time which must have passed from the time the aortic stab wound was inflicted, assuming these other wounds that I've described were inflicted before the aortic stab wound, for Mr. Goldman to have died?

DR. LAKSHMANAN: I--I think I opined this earlier. He would have died--I would expect him to die within five minutes after these injuries were inflicted and even earlier.

MR. KELBERG: How much earlier?

DR. LAKSHMANAN: Two, three minutes, because you're talking about major injuries to the jugular vein, the lung, the aorta, and you'll bleed fast and go into shock rapidly. It doesn't take much time to lose two liters of blood from all these sites to go into shock.

MR. KELBERG: And, doctor, again, from the quantification that Dr. Golden provides in his protocol regarding the abdominal cavity blood that is found, does that give you some indication as to how long after the aortic wound was inflicted Mr. Goldman lived?

DR. LAKSHMANAN: It doesn't help that much because he--the quantity we have is only in the cavity. I do not have an estimate of how much blood is in the retroperitoneum. So you cannot really give an estimate on how much blood loss occurred from that particular wound.

MR. KELBERG: Do you consider it a mistake on the part of Dr. Golden not to have attempted to quantify and report that effort on the retroperitoneal area where hemorrhage was found?

DR. LAKSHMANAN: It's difficult to quantify the retroperitoneal area, but he--it could have been--you could have described the extent of the retroperitoneal hemorrhage.

MR. KELBERG: What effect if any does his failure to do that, if you describe it as a mistake, have on your ability to answer these big ticket questions?

DR. LAKSHMANAN: Even if you had given it measurement, it would be difficult to--to estimate the volume of blood clots in the retroperitoneum unless you take--if you have tissues which you can weigh without the blood clots. It's very difficult to estimate it.

MR. KELBERG: And, doctor, other than--I gather this is of some importance to you in assessing how long Mr. Goldman may have lived from the time that aortic stab wound was inflicted; is that accurate?

DR. LAKSHMANAN: Well, I already told you it won't take much time to go into shock after the aortic wound. So it will help to better define a time, but really, the total time frame you're talking about is not long.

MR. KELBERG: And other than that, would such a quantification have assisted you in identifying whether a single single-edged knife caused all of the sharp force injuries?

DR. LAKSHMANAN: No.

MR. KELBERG: Or have assisted you in identifying the relative positions of the perpetrator and Mr. Goldman at the time that aortic sharp force injury was inflicted?

DR. LAKSHMANAN: No.

MR. KELBERG: Or in identifying from the appearance of the wound the type of knife that inflicted such an injury?

DR. LAKSHMANAN: From the appearance of the wound as I--I couldn't see the edges properly for this wound from the photographs very clearly, but the description of Dr. Golden is that the posterior edge is forked and the front end is sharp. And based on that, it could be a single edge if it's a straight penetration, which would support a thick edge, thick blunt edge because of the forking. The other possibility is, if it's a double edge, you cannot exclude some twisting.

MR. KELBERG: To break this down a bit, doctor, from your review of the photograph, the photograph is insufficient to define with sufficient clarity for you the ends of the stab wound on the surface of the body?

DR. LAKSHMANAN: Yes.

MR. KELBERG: So in this particular instance, you are referring to Dr. Golden's description of the ends of that sharp force injury, that stab wound in his report?

DR. LAKSHMANAN: Yes.

MR. SHAPIRO: Objection. Hearsay.

THE COURT: Overruled.

DR. LAKSHMANAN: Yes.

MR. KELBERG: And based upon what Dr. Golden reports, then this is one of these forms where you cannot differentiate between a single-edged knife and a double-edged knife; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Which of our alternatives if any from that board 1, 2 and 3, the wound pattern--

DR. LAKSHMANAN: That would be no. 3.

MR. KELBERG: And, doctor, you've already indicated that a single-edged knife could be consistent with this and all the other wounds; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: I lost my train of thought for just a moment. If I may have a moment, your Honor.

THE COURT: Certainly.

(Brief pause.)

MR. KELBERG: From Dr. Golden's description of the stab wound itself and the ends of it, are you however able to determine that it is consistent with a single-edged knife?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And from a description given by Dr. Golden, are you able to determine whether the length of the stab wound, that is the depth of the stab wound in the body is still consistent with an approximately 6-inch long tapering blade?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is this diagrammed by Dr. Golden as well as described? You've indicated he described it I believe in the protocol?

DR. LAKSHMANAN: Yes, he did.

MR. KELBERG: Is it diagrammed somewhere?

DR. LAKSHMANAN: Yes, he has.

MR. KELBERG: Let's take the protocol first because you've indicated there's some quantification in the abdominal cavity and so forth. Where in the protocol, doctor?

DR. LAKSHMANAN: It's on page 10, no. 5. Page 10, no. 5, the whole five paragraphs under item 5 that reflects the description of the stab wound.

MR. KELBERG: And let me box that in in red on page 10 of the protocol, 0G, and I'll write "G-8, abdominal aorta." Now, doctor, would you point out for us, please, where there is the quantification made by Dr. Golden?

DR. LAKSHMANAN: We have to start with line 8 under paragraph 2 under item 5, page 10 (indicating). "Two perforating half an inch wounds are seen in the wall of the aorta with surrounding para-aortic hemorrhage. In addition to the retroperitoneal hemorrhage, including hemorrhage into the mesocolon, approximately hundred cc--hundred ml of liquid blood is found free within the peritoneal cavity."

MR. KELBERG: Let me outline this--actually not outline, but let me underline "Approximately 100 ml of liquid blood is found free within the peritoneal cavity." Is "Peritoneal cavity" a fancy way of saying the abdominal cavity?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And, doctor, what if any significance is there to you in the observation by Dr. Golden that there are--and I'll underline this--"Two perforating 1/2 inch wounds seen in the wall of the aorta"?

DR. LAKSHMANAN: It could mean two things. You have the--the aortic--aorta is a tubulous structure. So the knife went through the tubulous structure. It could have gone in and out through the--both walls of the tube. So you could have two defects that way. The other possibility is that the knife could have been withdrawn and reentered in the same area of the aorta. I mean not in the same area. In a different area of the aorta in the same vicinity.

MR. KELBERG: If that had been the situation, doctor, would you have expected Dr. Golden to see separate wound paths at least for some distance to show that the knife had been withdrawn some distance and then replunged to create the second perforation in the aorta?

DR. LAKSHMANAN: It will be difficult to study two different tracks in the retroperitoneal soft tissues. It's not like going through a solid organ. So it would be very difficult to ascertain that in an area where's there so much soft tissues where you cannot really define a track because you have so much hemorrhage in the margins.

MR. KELBERG: Now, according to this same paragraph, Dr. Golden described the path--referring to the path of the stab wound; is that correct, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: --as from left to right and slightly back to front. What if any significance does that have--and I'll underline that for the record. What if any significance does that have to you in ascertaining, if you can, the relative positions of Mr. Goldman and the perpetrator at the time that abdominal aorta fatal stab wound was inflicted?

DR. LAKSHMANAN: It could have been--there are different possibilities again as I said earlier. One possibility is that the perpetrator was in the front of Mr. Goldman on his left, slightly to his left side, and with a knife in the right hand, plunged the knife straight in a left to right direction and in this manner (indicating).

MR. KELBERG: All right. And for the record, Dr. Lakshmanan with his right hand appearing to hold a knife, made a thrusting kind of a sideways motion.

MR. KELBERG: Doctor, do you want to demonstrate, if you would, using me? What are the alternatives, right-handed and left-handed?

DR. LAKSHMANAN: Right-handed could be in this manner (demonstrating).

MR. KELBERG: Let's turn so the jury can see.

DR. LAKSHMANAN: In this manner here (demonstrating).

MR. KELBERG: For the record, Dr. Lakshmanan and I are face-to-face. With his right hand, he's taken the ruler, and the ruler appears to be perpendicular to the side of my body where the stab wound would be located.

MR. KELBERG: Is that correct, doctor?

DR. LAKSHMANAN: Yeah. This is a straight penetration. But as I told you, you could have dynamics in this and it may not necessarily be that the plunge took place in this manner because the body of the victim could be turning this way and it could be just a straight plunge this way too (indicating).

MR. KELBERG: All right. How about a left-handed situation?

DR. LAKSHMANAN: Left-handed situation, it would have to be--the perpetrator would have to be more on the left side like this, in this manner, being the back of the victim, or the perpetrator could also be on the side, on his side facing the--I mean the victim could be on--the victim's side could be facing the perpetrator's knife in this manner, but little more, the victim being turning so that he could have back to front, left to right direction (demonstrating).

MR. KELBERG: In the first demonstration, Dr. Lakshmanan was directly behind me, shifted a little to the left of center of my body, and the second demonstration--if Dr. Lakshmanan could get back into position so I'll accurately describe the second demonstration you were just doing, doctor?

DR. LAKSHMANAN: This way. I'm sorry. You have to be like this (demonstrating).

MR. KELBERG: Dr. Lakshmanan is almost to the left of my left side of the body. He's holding the ruler to represent a knife in a manner in which the contacting portion of the ruler is forward of the back of the ruler which is in Dr. Lakshmanan's hand about a 45-degree angle to the horizontal.

THE COURT: Noted. Thank you.

MR. KELBERG: Doctor, we've done this demonstration with the two of us standing. Is there anything from your review of the material which requires Mr. Goldman to have been standing at the time that fatal stab wound to the aorta was inflicted?

DR. LAKSHMANAN: No. The only thing I want to bring up is that when I examined the shirt of Mr. Goldman, there's no defect directly corresponding to that wound on the left side of the shirt. There were two defects in the back of the mid portion of the shirt. So if the shirt was not covering that area when this stab wound was inflicted, then he need not necessarily be standing up. He could be on the ground wen the stab wound was inflicted. But if there was the possibility that the defects in the back of the shirt, one or both of them correspond to this defect on the side of the abdomen, then it would reflect that there was movement of the shirt on the body surface if that penetration took place through the shirt.

MR. KELBERG: Is there any way you can make that determination, doctor?

DR. LAKSHMANAN: I can't.

MR. KELBERG: And, doctor, could those defects in the back of the shirt that you described--I gather you did not see a corresponding sharp force injury to the back where those wounds would be--where those defects would be in the shirt?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: Would it be accurate to say that the knife could have penetrated the shirt to create the defects in a situation where there was movement by Mr. Goldman such that the knife never came in contact with Mr. Goldman's body?

DR. LAKSHMANAN: That is another possibility.

MR. KELBERG: Doctor, do we see the area of the abdominal aorta stab wound in photograph 43E?

DR. LAKSHMANAN: Yes, we do. It's just--you don't see the wound itself, but it's in this area here (indicating).

MR. KELBERG: And may I ask, Mr. Fairtlough, is there a marker that will mark on the photograph unobtrusively?

(Discussion held off the record between the Deputy District Attorneys.)

MR. KELBERG: Mr. Fairtlough indicates to me that we have a gold marker that he can use.

MR. KELBERG: And, doctor--

DR. LAKSHMANAN: I'm going to put an arrow in this area somewhere here this region (indicating).

THE COURT: I have arrows.

MR. KELBERG: Is it permanently a fixed one, your Honor? I'm just concerned if it might come off.

THE COURT: Well, try it.

MR. KELBERG: All right. May I approach? I'll let Mr. Fairtlough--

MR. KELBERG: Doctor, will you point out where Mr. Fairtlough should put the arrow?

DR. LAKSHMANAN: This area here. That's where the stab wound is in the left flank. Little bit lower. Yeah, that's fine. Little bit lower (indicating). You can't see it because it's slightly on the posterior curvature of the torso.

MR. KELBERG: And, doctor, does the point of the arrow touch the approximate area though?

DR. LAKSHMANAN: Yes. And you can see it in G-5 where it is.

MR. KELBERG: All right. And you've pointed now--

MR. KELBERG: Thank you, Mr. Fairtlough. And I think we owe the Court back its--

THE COURT: No. Keep them.

MR. KELBERG: All right. You're a pessimist, your Honor.

MR. KELBERG: Does that, where you're pointing, doctor, then show the very same fatal abdominal stab wounds that you have identified in G-8?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, in looking at the area in 43E, is that area covered by Mr. Goldman's shirt if you can tell?

DR. LAKSHMANAN: No.

MR. KELBERG: You can't tell or it's not?

DR. LAKSHMANAN: I mean--I'm sorry. You can tell, but it's not covered. That's what I meant.

MR. KELBERG: Doctor, is there anything inconsistent with Mr. Goldman having been in a position on the ground with his shirt not covering that area and the perpetrator reaching down with a right hand and inflicting that fatal stab wound to the abdominal aorta?

DR. LAKSHMANAN: I can't exclude that possibility. It's--it's--there's nothing inconsistent in that statement.

MR. KELBERG: And if that was done, doctor, would it be accurate to say that you would still expect the bleeding to be internal rather than outside of the body?

DR. LAKSHMANAN: Yes. And of course, the wound should have been inflicted when Mr. Goldman had blood pressure to cause all the bleeding which it caused.

MR. KELBERG: And in your opinion, that was in fact the case, that he had a beating heart with sufficient blood pressure?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Before we go, doctor, to the--I think we've taken care of the protocol. Have we taken care of the diagrams that show that abdominal aorta?

DR. LAKSHMANAN: Yes. No. Actually no. There's 20-II.

MR. KELBERG: We'll get that up in just a moment. Before we do, doctor, is there anything further you wish to add concerning the wound itself as it appears in either photograph G-8 or in G-5?

DR. LAKSHMANAN: No.

MR. KELBERG: All right. Let's see if we can then get the protocol. We can put it up right here. Doctor, is it also diagrammed in 21, one of the 21 boards?

DR. LAKSHMANAN: Yes. 21-III.

MR. KELBERG: Why don't we take care of that one while Mr. Lynch is going to put the other one up on the easel. Was going to put the other one up on the easel with the photo. I'll do that.

THE COURT: That's 2G.

MR. KELBERG: 2G. Thank you, your Honor.

MR. KELBERG: All right, doctor. Where is it on 21-III?

DR. LAKSHMANAN: Right here (indicating).

MR. KELBERG: And what if any entry, handwritten entry is made by Dr. Golden?

DR. LAKSHMANAN: It says stab wound abdomen transfers--the length of the track is five and a half inches and went through the abdominal aorta one and a quarter inches proximal, P-R-O-X, to bifurcation.

MR. KELBERG: What does that mean, "Proximal"?

DR. LAKSHMANAN: That means one and a quarter inches above where the aorta divides.

MR. KELBERG: And is there any writing below that that refers to that same area?

DR. LAKSHMANAN: Left to right and slightly back to front.

MR. KELBERG: And, doctor, just--there appears to be some waving line around the circled area to the left of what I thought you pointed out as the diagrammatic representation of the aortic stab wound. Am I correct that this area is the diagrammatic representation of the aortic stab wound (indicating)?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me circle that in red. And what if anything is represented by the area to the left that has that waving black line?

DR. LAKSHMANAN: Well, I think that's just a deletion of something he drew and it doesn't reflect this injury.

MR. KELBERG: All right. Then let me circle the description in the two areas that are covered by that, and I'll make a line out to the side of the lower right-hand area of G-8 and G-5, and I'll write "Abdominal aorta." Is that accurate, doctor?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, you said it's diagrammed also in another form; is that correct?

DR. LAKSHMANAN: Yes. 20-II.

MR. KELBERG: Where on 20-II is that diagram?

DR. LAKSHMANAN: Here (indicating). This particular area here reflects and it says, "Stab wound to the abdomen, left to right, retroperitoneal iliopsoas area."

MR. KELBERG: Keep your voice up, please, doctor.

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is all of this writing here to refer to that abdominal aorta stab wound?

DR. LAKSHMANAN: Yes. And actually, it continues here also (indicating). It reflects the 3/4 inch length of the stab wound of the skin surface, the direction left to right, back to front. And again, it reflects that the injury to the aorta took place proximal, one and a quarter inches proximal to the bifurcation, and you have hundred cc blood in the peritoneal cavity.

MR. KELBERG: Doctor, what if anything is this, where I'm pointing, to represent?

DR. LAKSHMANAN: Well, he describes the stab wound itself, and I think he's trying to point out the--that one end of the wound is sharp and one end of the wound is forked.

MR. KELBERG: And what does this--and I'll have the record hopefully corrected to indicate what I've been pointing to. What is this where I'm pointing to, which is just above what you were just describing? What does that refer to?

DR. LAKSHMANAN: I--I--he's got some kind of diagrammatic notation here, but mainly he says it's a transversely oriented wound, which means it's horizontal, horizontally oriented, which we already saw in the photograph.

MR. KELBERG: Doctor, I believe--

DR. LAKSHMANAN: It runs from a front to back direction, the stab wound.

MR. KELBERG: I believe you indicated Dr. Golden described one end of the stab wound as being forked?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is that accurate?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Would this appear to be a representation of a forked end of a stab wound?

DR. LAKSHMANAN: No. It's just some notation there. I can't really make that diagnosis from that notation.

MR. KELBERG: All right. So all of this area here, all of this area here (indicating) all relates back to that stab wound, the aortic stab wound; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right. Let me circle all of that. Does the no. 5 go along with that information?

DR. LAKSHMANAN: Yes. See, this no. 5 corresponds to the 5 description of the protocol.

MR. KELBERG: All right. So I've circled that area in red and I'll write "G-8, G-5, abdominal aorta." Doctor, as long as we have this form up, 20, there is something written in, several things that appear to be written in on the corresponding left side of the form. What are those representations?

DR. LAKSHMANAN: This would reflect the site of liver temperature puncture (indicating). They puncture the abdomen to get the liver temperature. And "PM" means it was done postmortem. And this is the liver temperature procedure conducted by Miss Ratcliffe, which Dr. Golden is reflecting as he saw as a mark on the body when he examined the body.

MR. KELBERG: Let me circle that area, and I'll just write in "Liver temp probe." Would that be accurate?

DR. LAKSHMANAN: Yes. And this "45H" means that this stab wound to the abdomen was 45 inches above the heel. So this also should be included with this discussion (indicating).

MR. KELBERG: All right, doctor. Is this, where I'm pointing to right how, the location of that abdominal aortic stab wound?

DR. LAKSHMANAN: Yes. Yes.

MR. KELBERG: So I will circle this additional information you just indicated and I will draw red lines to the actual wound itself that's diagrammatically represented, circle that in blue, and out at the side, write "G-8, G-5, abdominal a wound." Doctor, why would doctor--let me withdraw that. Is it a common practice at your office that more than one diagram form would be used to include information for the very same injury such as we have here, 21-III and 20 being used for the abdominal aorta?

DR. LAKSHMANAN: Well, Dr. Golden could have--I mean, to answer that question, sometimes more than one diagram is used to reflect the same injury because we have diagrams which show the anatomical location better.

MR. KELBERG: Is there anything in your opinion which is inappropriate for Dr. Golden to have selected these two forms to include for the information of the abdominal aorta fatal stab wound?

DR. LAKSHMANAN: No. Nothing inappropriate.

MR. KELBERG: Anything further on the diagram?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything in the form of the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Anything further with respect to this injury?

DR. LAKSHMANAN: No.

MR. KELBERG: All right. Let's-- now, doctor I think you indicated that the abdominal aorta stab wound was the only injury which you discussed from photograph G-8; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And just for orientation, is this Mr. Goldman's left hand that is laying alongside the area of the body in G-8?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, we have one photograph left, doctor, and that's G-5; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And you've already indicated where the abdominal aorta wound on the body is located. What other findings have you made from reviewing this photograph? And, by the way, this is a cropped photograph; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And you saw the full photograph?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is this one of the photographs that was not made into a life-size photograph?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is that because in essence, you would need a full five foot, nine inch photograph to accurately represent a life-size depiction of this area of Mr. Goldman's body?

DR. LAKSHMANAN: That is correct. Nearly five feet nine inches because the photograph would view portions of the body, not the whole body.

MR. KELBERG: I'm sorry. Portions of the body?

DR. LAKSHMANAN: But not the whole body.

MR. KELBERG: All right. Now, would you tell us what your findings are that are seen in that photograph?

DR. LAKSHMANAN: I already described the flank wound which is seen, which is seen in G-8. You also have an abrasion in the left shoulder blade area and you have an abrasion in the radial aspect of the left wrist.

MR. KELBERG: Have we seen either of those injuries in any of the other photographs?

DR. LAKSHMANAN: No.

MR. KELBERG: Let's start then with this abrasion you say the left shoulder area.

DR. LAKSHMANAN: Left shoulder blade area.

MR. KELBERG: All right. From your observation in this photograph, is this an antemortem abrasion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Do you have an opinion as to any potential source or sources for that?

DR. LAKSHMANAN: Nonspecific blunt force trauma.

MR. KELBERG: Doctor, from your review of the environmental surroundings that we saw in the earlier photographs, are any of those surroundings a potential source for that abrasion?

DR. LAKSHMANAN: There are several sources which could cause it. Any rough surface could cause it.

MR. KELBERG: And does that include the ground?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Does it include any of the trees?

DR. LAKSHMANAN: It could. But remember that we also have the shirt interspersed between the skin and the inflicting object.

MR. KELBERG: And what effect if any does the shirt interposing between the object and Mr. Goldman's skin have on how that abrasion can be created?

DR. LAKSHMANAN: You cannot--you don't see a pattern. So it would be very difficult to say which object did that particular blunt force.

MR. KELBERG: Is this abrasion discussed by Dr. Golden in the original protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it diagrammed?

DR. LAKSHMANAN: No.

MR. KELBERG: Is it addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: All mistakes?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Collectively and individually, any significance on any of the big ticket questions you've been reviewing and testifying about?

DR. LAKSHMANAN: No.

MR. KELBERG: For the same reasons that you've already described?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, let's talk about this injury--you said something about the radial aspect of the left hand; is that correct?

DR. LAKSHMANAN: Yes. It's right here. You can see an abrasion there (indicating).

MR. KELBERG: And where--perhaps you could point on your right hand where it is--

DR. LAKSHMANAN: You mean my left--my left hand.

MR. KELBERG: I'm sorry. Your left hand. Excuse me.

DR. LAKSHMANAN: Somewhere in this region next to, near my watch area (indicating).

MR. KELBERG: Your Honor, below the base of the thumb at the wrist level the doctor is pointing.

THE COURT: Slightly above the wrist level, yes.

MR. KELBERG: Is this discussed by Dr. Golden in the protocol?

DR. LAKSHMANAN: No.

MR. KELBERG: Diagrammed anywhere?

DR. LAKSHMANAN: No.

MR. KELBERG: Addressed in the addendum?

DR. LAKSHMANAN: No.

MR. KELBERG: Answers the same regarding these mistakes as they just were to the mistakes regarding the shoulder blade abrasion?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: And again, no significance to you on the big ticket questions?

DR. LAKSHMANAN: No.

MR. KELBERG: Are you able to determine from that photograph a source or sources for that abrasion?

DR. LAKSHMANAN: No.

MR. KELBERG: Is any of the environmental surroundings--are any of the environmental surroundings seen in the photographs from Bundy potential sources for those--for that abrasion?

DR. LAKSHMANAN: It could be any rough surface which the hand rubbed against or the surface rubbed against the hand to cause that injury.

MR. KELBERG: Is there anything else in the form of injuries seen in that photograph G-5?

DR. LAKSHMANAN: No.

MR. KELBERG: Now, I want to ask you, doctor, briefly about, in the photograph, you'll notice in the title of the document of the board the word "Lividity" appears at the end. Is there something that you see in photograph G-5 that represents to you lividity?

DR. LAKSHMANAN: Yes. You can see it actually in G-10 also. You see it in the right shoulder area, distinct discoloration, and also in the right flank area, you can see distinct coloration. And if you look at the lower part of G-10, you can see this pink discoloration, which is related to the same right side, and that all would be consistent with lividity.

MR. KELBERG: And, doctor, again, we'll talk about this in much greater detail with the time of death discussion. But in general terms, "Lividity" is?

DR. LAKSHMANAN: Is a postmortem draining of blood to the dependent parts of the body due to gravity and causing discoloration of the skin surface.

MR. KELBERG: Doctor, assuming Mr. Goldman's body was found in the position it is seen in photograph 43E and that the body remained in that position more or less until around 10:30 in the morning of June 13th, 1994, is that position one which is consistent with the location, this area, the pinkish discoloration that you just identified in both photos G-5 and G-10?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Would you point out where it is in the photograph 43E?

DR. LAKSHMANAN: If you look at the thigh here and the arrows going towards the waist area here, and actually you can't see the right side of the body very well because you have the fern plant in front of the body. But basically, the right side of the flank is in contact with the ground. And that's a different part of the body in that position (indicating).

MR. KELBERG: And is a consistent position to having the draining show up at the time of autopsy by the pinkish discoloration you've identified in these two photos?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Anything else about these photos, doctor?

DR. LAKSHMANAN: No.

MR. KELBERG: Have we completed your discussion of all of the photographs of Mr. Goldman's autopsy that we are using in this presentation?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Have we discussed with respect to those photographs all of the entries in the protocol?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All of the entries in the diagrams?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And all of the entries in the addendum?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, there are some other records which were produced in the course of the Goldman autopsy, and I want to begin by putting up our board which is 11G. And we'll take down the protocol. And I'm also going to put up in just a moment--should have started at the other end--the form 15, 16 which is our board 1G. And let me get the corresponding identifying paper documents. Our form 15 is a part of exhibit 356-B. There are two of those form 15's, and the--what appears to be the toxicology report is our exhibit 356-P as in Paul. Doctor, again, are these two documents, the toxicology report, and there are several pages I believe, and the form 15, forms which are produced in the ordinary course of the Coroner's office operation?

DR. LAKSHMANAN: Yes, they are.

MR. KELBERG: And is each of them completed by an employee of the Coroner's office?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is each of such employees under an obligation to complete these records at or about the time of the events which are recorded in each of the documents?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, let me invite your attention--and I'm going to see if we have some pins still left. I don't know if we have them. I don't think we do. Let me hold this back. On the form--

THE COURT: Do you have some? Mrs. Robertson can get you some if you need them.

MR. KELBERG: I think we can proceed without them, but thank you for the offer, your Honor.

THE COURT: All right.

MR. KELBERG: Doctor, this form, is this completed by Dr. Golden in the course of performing the autopsy of Mr. Goldman?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And there appears to be an entry at the top concerning time and listed as 10:30. What does that reflect?

DR. LAKSHMANAN: That is the time he started the autopsy.

MR. KELBERG: And with respect to witnesses, again, like the Nicole Brown Simpson form 15, has Dr. Golden indicated that there were two witnesses, Detectives Vannatter and Lange?

DR. LAKSHMANAN: Yes.

MR. KELBERG: On the right side of the document again in this area preprinted of toxicological specimens collected, did Dr. Golden indicate that such specimens were in fact collected?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What does he indicate?

DR. LAKSHMANAN: He said he collected blood from the right chest and bile, and there's nothing else reflected in the--this particular 15, but he had collected stomach contents.

MR. KELBERG: Doctor, would you like a sip of water?

DR. LAKSHMANAN: Yes. Thank you.

(Brief pause.)

MR. KELBERG: Doctor, I think you testified last week that according to Dr. Golden's records, there was insufficient heart blood to collect as a result of which the alternative of using blood in the chest was collected?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, you say stomach contents were saved. This was something you asked Dr. Golden to do after you learned he had not saved the stomach contents of Nicole Brown Simpson; is that correct?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: And yet on this first page of the form 15, that box for stomach contents does not appear to be checked; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: This is a form I think you testified last week also, it's a multi-page form; is that correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Let me flip the page just briefly to go to what appears to be a second form 15. Is this identical in all respects with respect to--with the exception of the box for stomach contents?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And can you give us some idea of how this document got generated to have a change by having an "X" in the box to mark stomach contents?

DR. LAKSHMANAN: As I told you, there are four copies to this document. The white copy is the file copy and then there's a canary color, yellow copy which goes to the laboratory. The laboratory is where they receive all the specimens. When the canary copy did not reflect the box marked for the stomach contents and they received the stomach contents, the lab marked off the box for that, and you can see the difference in the marking. There's a check done by Dr. Golden, but the "X" is made by the laboratory on the canary copy.

MR. KELBERG: Let me see if I can flip back to the original page to show the difference.

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, this mistake is one of Dr. Golden's for not marking the box?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is it of any significance to you on any of these issues?

DR. LAKSHMANAN: No.

MR. KELBERG: Why not?

DR. LAKSHMANAN: Because it's just an omitting the mark of box. We know he collected the specimen. It has been received in the lab. The lab has documented that it has received the specimen. So it's sort of significance in that manner.

MR. KELBERG: Now, doctor, again, under toxicological analyses ordered, there appears to be a check mark in a particular box. What is that all about?

DR. LAKSHMANAN: That is the box marked for "H" and that reflects that we ordered a--he ordered a homicide screen, a drug screen, which we do on homicide cases.

MR. KELBERG: And in this particular document now off of our board, 11G, do we see the product of the toxicological screen of the blood?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What are we looking at on this--the first page is one that is dated June 21, 1994?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What are we looking at?

DR. LAKSHMANAN: The blood which was submitted was tested for alcohol, methamphetamine, cocaine, narcotics, which includes codeine, narcotics, morphine and phencyclidine.

MR. KELBERG: I believe you have already identified from the toxicological records of Nicole Brown Simpson, Mr. Park and Mr. Mahanay. So they are your toxicologists performing these tests?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And what are the results that are found?

DR. LAKSHMANAN: Alcohol was negative and none of those drugs were detected. "ND" means none detected, not detected.

MR. KELBERG: And there appears to be a second page to this particular toxicological board, this one dated August 11, 1994. What does this represent, doctor?

DR. LAKSHMANAN: This is some additional testing which was requested at a later time to complete the "C" screen, which is a comprehensive screen, and this reflects that.

MR. KELBERG: Is there some reason why Dr. Golden has only requested an "H" screen and ultimately a "C" screen was done?

DR. LAKSHMANAN: I requested--

MR. SHAPIRO: Objection. Calls for speculation.

THE COURT: Sustained. Rephrase the question.

MR. KELBERG: If you know, doctor, is there a reason why a "C" screen was performed?

DR. LAKSHMANAN: Yeah. I ordered the "C" screen to get it completed.

MR. KELBERG: Why did you order that?

DR. LAKSHMANAN: Just to complete the screen to make sure that we don't have any other drugs in the system.

MR. KELBERG: Doctor, would it normally have been the case in a low publicity homicide where the circumstances are all the same with the exception of the identities of the victims and the person arrested for only an "H" screen to have been done?

MR. SHAPIRO: Objection. Irrelevant.

THE COURT: Overruled.

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Is this another instance where you were covering your backside?

DR. LAKSHMANAN: If you want to put it that way, yes.

MR. KELBERG: It's not a question of whether I want to put it that way, doctor. Is that why you ordered it?

DR. LAKSHMANAN: I ordered it to complete the screen so we can get the screen completed.

MR. KELBERG: If you don't do it in other low publicity cases, then why did you do it in this case?

DR. LAKSHMANAN: I just wanted to make sure there was no other drugs which we can test for which was present in the system.

MR. KELBERG: Why don't you do it in the low publicity cases?

DR. LAKSHMANAN: I just did it as I told you already. I don't have a reason for it. I just did it as a judgment call.

MR. KELBERG: And the results?

DR. LAKSHMANAN: Negative.

MR. KELBERG: For any of these additional drugs?

DR. LAKSHMANAN: Both basic--the basic drugs and barbiturates.

MR. KELBERG: Anything further with respect to these two documents on the toxicological analysis?

DR. LAKSHMANAN: No.

MR. KELBERG: I want to--for safety sake, let me move this, the first easel, and I just want to get the exhibit identification number. This is going to be--this is 340--I'm sorry. Wrong one. 356-C. Mr. Lynch helps me out. Thank you.

MR. KELBERG: Our form 16 in this case situation, doctor. First of all, does this form show the actual hours indicated by Dr. Golden in which he performed the autopsy, the gross autopsy and dissection of Mr. Goldman?

DR. LAKSHMANAN: Yes. In the lower part, you can see that he performed the autopsy between 10:30 and 1300, which is 1:00 o'clock in the afternoon.

MR. KELBERG: And I think you testified last week that in your opinion, this autopsy should have taken somewhat longer than two and a half hours as indicated by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: How long would you have expected this autopsy to take?

DR. LAKSHMANAN: I said four to five hours.

MR. KELBERG: Now, doctor, in this particular form, does Dr. Golden indicate the contents of the stomach which he saved at your request?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What does he indicate?

DR. LAKSHMANAN: He says that 200 cc of partially digested material with pieces of spinach--spinach.

MR. KELBERG: Let me ask Mr. Lynch if he could just circle that area with one of the markers at the witness stand, and let me, while he's doing that, put up the protocol. Doctor, is there a description provided in the protocol for the stomach contents of Mr. Goldman?

DR. LAKSHMANAN: Yes. It will be under "Digestive system."

MR. KELBERG: And looking at page 15 of the exhibit board 0G, at the bottom where it starts with "Gastrointestinal system," if we flip the page now, does Dr. Golden describe his findings of the stomach contents?

DR. LAKSHMANAN: Yes. It's on paragraph 1 of page 16-93, "200 ml of partially digested semi-solid food found in the stomach with the presence of fragments of green leafy vegetable material compatible with spinach."

MR. KELBERG: Let me circle that area. Does Dr. Golden on the form 16 make any reference to the fatal stab wounds he identified in the course of the autopsy?

DR. LAKSHMANAN: Yes, he does.

MR. KELBERG: Where?

DR. LAKSHMANAN: He describes the two stab wounds to the right lung and says to the right lower lobe and he also addresses the hundred cc blood present in the chest cavity of liquid blood.

MR. KELBERG: Keep your voice up, please, doctor.

DR. LAKSHMANAN: Liquid blood. And he also addresses the presence of hundred cc blood in the abdominal cavity in addition to the retroperitoneal hemorrhage here (indicating). And that's from the flank wound.

MR. KELBERG: And does he also record the height and weight of Mr. Goldman?

DR. LAKSHMANAN: Yes, he does. The weight is 171 pounds and the height is 69 inches, which is five feet, nine inches.

MR. KELBERG: Doctor, let me show you another board. It's 12G which is in the paper form. It is 356-Q. You testified last week about examination made by Drs. Vale and Enselmo on photographs of the back of Nicole Brown Simpson. Did you also obtain a consultation report from the two of them regarding Mr. Goldman?

DR. LAKSHMANAN: Yes. They reviewed photographs on Mr. Goldman.

MR. KELBERG: And is this form 13 part of the official records of the Coroner's office by these two consultants?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And in summary, what was the result of Dr. Vale and Dr. Enselmo's examination of the photographs?

DR. LAKSHMANAN: We do not find evidence of bite marks in the photographs.

MR. KELBERG: And flipping the page of this board, do we see in essence the handwritten version of the same report you just described, only that report was on a form 13 and the handwritten part is on a form 42?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: Anything else in the way of Dr. Vale and Dr. Enselmo on the Goldman autopsy?

DR. LAKSHMANAN: No.

MR. KELBERG: Doctor, if you would like to retake the stand for just a moment.

(The witness complies.)

(Brief pause.)

MR. KELBERG: I'm just trying to get the designation. I apologize, your Honor, for-- 356-M as in Mary.

MR. KELBERG: Doctor, let me show you the blow-up, which is our board 8G of the exhibit, the paper exhibit 356-M. And I'm sorry. You'll have to get up again, if you would, please. Are you familiar with this document?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What is this?

DR. LAKSHMANAN: This is a summary of the various sharp force injuries on Mr. Goldman, and Dr. Golden did the summary, and basically the document reflects the summary.

MR. KELBERG: Doctor, can you just in general terms indicate what is described by Dr. Golden with this document?

DR. LAKSHMANAN: Yes. He has divided the document in various columns. He has given the numbering which he used for his description of the various sharp force injuries, the site where it's located, orientation, whether the stab wound or the sharp force injury was vertically oriented, diagonally oriented or transversely oriented. Vertically oriented means the long axis of the wound was in a head-toe direction. Diagonally means was diagonal to that axis and transverse is an axis which is perpendicular to the head-toe axis, that is this horizontal axis. So that's what he means by orientation. And then this is--"L" refers to the location. The--for the chest wounds, it's the location below the head. For the abdominal and thigh wounds, it's the location above the heel.

MR. KELBERG: I'm sorry. You can obviously understand how that refers to location. But could you explain it to us, why in number 22 refers to some location?

DR. LAKSHMANAN: Because it's from the top of the head to the location of the wound on the body where it's located. For example, let's take--let's go across one wound so that it will be better understood. Let's take no. 1, first degree stab wound to the right chest. It's vertically oriented. It's 22 inches below the top of the head, and this is the--from the back, it's--it's situated five inches from the back. That is when the body is laying to the back here, five inches to the front (indicating). The length of the wound is 5/8 of an inch. And this is with reference to the edges. The lower end was the blunt end for that front stab wound if you'll recall, and that's the sharpened, and this refers to the depth of the wound. I can't read it clearly here. And then you have the track which goes to the lung, angle is right to left, and hemothorax. Then the second--

MR. KELBERG: Hemothorax was, again, blood in the cavity?

DR. LAKSHMANAN: Yes. Then the no. 2 is the right chest. It was diagonally oriented 21 inches below the head, two inches from the back, one and a half inches long, and the blunt end was in the back and the sharp end was in the front, same right to left. That diagram goes on.

MR. KELBERG: Now, doctor, was each of the fatal stab wounds that you've identified, that is the two fatal stab wounds to the right chest, the fatal stab wound to the abdominal aorta and the fatal stab wound to the left area of the neck, is each of those fatal stab wounds described on this chart?

DR. LAKSHMANAN: The neck is not. You have the two right chest, the nonfatal right flank, the left thigh, which is not fatal, but significant bleeding, left abdomen, which is to the aorta. And here he has given the orientation of the forking in the back and the pointing to the front as far as the characteristics of the edges. I mean characteristics of the ends of the wound.

MR. KELBERG: That's of the abdominal aorta stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And that's the one that you saw in photograph G-8 and also in G-5?

DR. LAKSHMANAN: Yes.

MR. KELBERG: All right.

DR. LAKSHMANAN: And here is a direction here, left to right, slightly back to front, hundred cc of blood in the abdominal cavity, 5 DAPI, which is depth. So it's basically a summary of all the wounds.

MR. KELBERG: Would you have expected Dr. Golden to have included this fatal stab wound to the left side of the neck in this chart review?

DR. LAKSHMANAN: He did not. I guess--

MR. KELBERG: I don't want you to guess, doctor.

DR. LAKSHMANAN: I don't know--I'm not saying--he did not.

MR. SHAPIRO: Objection. Motion to strike. Nonresponsive.

THE COURT: Overruled. Proceed.

MR. KELBERG: Doctor, again, is this a document that is created in the ordinary course of the business of the Coroner's office?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And is it to reflect at a time of or near the observations that are recorded in the document by Dr. Golden?

DR. LAKSHMANAN: Yes. And I'd like to point out also that he has given to the forked end, can vary from 1/16 inch to 1/8 inch in width.

MR. KELBERG: The forked end of what, doctor?

DR. LAKSHMANAN: The stab wound here (indicating).

MR. KELBERG: The abdominal aorta stab wound?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, is a chart like this of any existence to you in forming an opinion such as you indicated you did of general dimensions of a knife that's single edged which would have been consistent with all of the sharp force injuries received by Mr. Goldman?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And in fact, have you reviewed from this chart and all of the other information to form such an opinion?

DR. LAKSHMANAN: Yes.

MR. KELBERG: What is the opinion as to the approximate dimensions?

DR. LAKSHMANAN: As I mentioned earlier, in knife wounds, you can only approximate. You need a suspect weapon to compare to the wounds. But given all the measurements I have done in both the cases and the measurements given by Dr. Golden and appearances and the description, I said all the wounds could have been caused by a single-edged knife, but a thick blunt edge up to 1/8 inch in width with a tapering tip and 6 inches long, 3/4 inch wide.

MR. KELBERG: 3/4 inch wide at its widest point?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And getting narrower as one gets to the tip of the knife blade?

DR. LAKSHMANAN: Yes. This is just an approximate estimation because normally knife wounds, as I said earlier, you like to compare a suspect weapon to a wound.

MR. KELBERG: Doctor, before I get into chain of custody documents that refer to both the Goldman and the Nicole Brown Simpson autopsies, is there anything that you want to bring to our attention with respect to the actual findings or conclusions from the Goldman autopsy that we have not discussed?

MR. SHAPIRO: Objection. Calls for a narrative.

THE COURT: Rephrase the question.

MR. KELBERG: May I have just a moment then, your Honor?

THE COURT: Certainly.

(Brief pause.)

MR. KELBERG: The one thing I did not show you, doctor, would be the blow-ups of the form 1 and 2 that is on our board 13G. We saw the form 1, I believe it's exhibit 298-B, the redacted version to leave out any home address that might be observed. Those documents, are they also created in the ordinary course of the Coroner's office operation?

DR. LAKSHMANAN: Yes, they are.

MR. KELBERG: And are the entries made made by employees at or about the time of the events which are reported in those documents?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, before I go to the chain of custody documents, I want to ask you about something that Mr. Cochran mentioned I believe several times in opening statement and in some examination of witnesses, in particular, Detective Lange.

MR. SHAPIRO: Objection to the form of that statement.

THE COURT: Sustained.

MR. SHAPIRO: Motion to strike, admonish the jury.

THE COURT: Stricken. The jury is to disregard. Proceed.

MR. KELBERG: I'm sorry, your Honor.

THE COURT: Proceed.

MR. KELBERG: Doctor, have you ever heard the term before I may have mentioned it to you "Colombian necktie"?

DR. LAKSHMANAN: I heard the term.

MR. KELBERG: From whom?

DR. LAKSHMANAN: That's used to describe a type of neck injury wherein you have a slash wound to the neck and tongue is interspersed there.

MR. KELBERG: When is the first time you heard such a term?

MR. SHAPIRO: Objection. Irrelevant.

THE COURT: Overruled.

DR. LAKSHMANAN: I've heard it mentioned by different--by different pathologists.

MR. KELBERG: Doctor, have you--

THE COURT: Excuse me, Mr. Kelberg. I hate to break it up. I have a note from the jurors that we need to take a comfort break. All right. So let's take five minutes. All right.

(Recess.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Mr. Kelberg.

(A conference was held at the bench, not reported.)

(The following proceedings were held in open court, out of the presence of the jury:)

THE COURT: Let's have the jurors, please.

(The following proceedings were held in open court, in the presence of the jury:)

THE COURT: Thank you, ladies and gentlemen. Please be seated. All right. Doctor. Mr. Kelberg.

MR. KELBERG: Thank you, your Honor.

MR. KELBERG: Doctor, to continue, when approximately did you first hear the term "Colombian necktie"?

MR. SHAPIRO: Asked and answered.

THE COURT: Overruled.

DR. LAKSHMANAN: From some pathologists--I don't recall--actually sometime ago because I've never seen a case of that.

MR. KELBERG: Can you give any approximation? Are we talking about within the last five years?

DR. LAKSHMANAN: No. Before that when I was in the New York area and also in meetings. But I've never seen a case myself.

MR. KELBERG: When were you in the New York area?

DR. LAKSHMANAN: From 1972 to `77.

MR. KELBERG: Doctor, and you--

MR. SHAPIRO: Objection, 352, questioning along those lines.

THE COURT: Overruled.

MR. KELBERG: Doctor, you have been at the Los Angeles County Coroner's Office in one capacity or another since when? A `78.

MR. KELBERG: Have you ever--

DR. LAKSHMANAN: Since `77. I'm sorry.

MR. KELBERG: Have you ever seen the following kind of case? A victim's neck slashed from ear to ear with the tongue of the victim drawn through the fatal incised stab wound that I've just described as if to reflect a necktie position?

DR. LAKSHMANAN: I've not.

MR. KELBERG: And in your capacity as the Chief Medical Examiner for the County of Los Angeles, you see cases other than ones you are personally handling?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: And you see cases that your other medical examiners are handling on a routine basis?

DR. LAKSHMANAN: That's correct.

MR. KELBERG: And in that time, you've never seen such a case; is that accurate?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Doctor, before I get into chain of custody, let me cover a few other areas concerning Dr. Golden. Since the arrest of Mr. Simpson, did you become aware of other cases where on review, Dr. Golden had made mistakes?

DR. LAKSHMANAN: Yes, I have.

MR. KELBERG: Was one of the cases--actually two cases--involving individuals by the name of Gaye and Phillips?

DR. LAKSHMANAN: Yes.

MR. KELBERG: In general, describe the case, the mistake or mistakes made by Dr. Golden.

DR. LAKSHMANAN: One was a female victim and one was a male victim. Both were in a vehicle when they were victims of a gunshot wound--I mean firearm injury. The lady was in the driver's side. The male was in the passenger side. And the lady, Dr. Golden reflected that the gunshot wound entered in the right arm and exited in the back of the chest, but later, he amended the certificate to reflect that the gunshot wound entered the back of the chest and came out on the right arm. So that is the summary of that case.

MR. KELBERG: Doctor--

DR. LAKSHMANAN: On the--

MR. KELBERG: I'm sorry. Before you go to the next part, would it be accurate to say that Dr. Golden mischaracterized the entrance and exit wounds of those--of that gunshot case?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And the amendment that was done, was that done before you became aware of this case as a possible mistake by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Who did that amendment?

DR. LAKSHMANAN: Dr. Golden did the amendment. I think--I forget the exact date, but much later.

MR. KELBERG: Approximately when did this case arrive in your office?

DR. LAKSHMANAN: I think it was 1990.

MR. KELBERG: 1990?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And approximately when did you first become aware of this case as a case of a possible mistake by Dr. Golden?

DR. LAKSHMANAN: In August last year when there was an episode on prime time.

MR. KELBERG: That's a television program on ABC?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, you were going to say something more I believe regarding the Gaye and Phillips cases; is that correct?

DR. LAKSHMANAN: That's correct. The other gentleman who was a victim of the same incident was also shot in the chest. He had an entrance in the back and exit in the front, and Dr. Golden properly characterized the gunshot wounds as far as the entrance and exit went, but he failed to recognize the range of fire for the entrance wound in the back. There was a--evidence of additional injury in the back near the entrance of the gunshot wound, which would place the range of fire to be at close range rather than a distant range, and that was a mistake which had to be corrected, and it was corrected last year.

MR. KELBERG: If you know, on whose initiative was this corrected?

DR. LAKSHMANAN: The amendment was issued under my direction because an order had been issued at that time.

MR. KELBERG: And did you initiate that amendment after someone brought to your attention this case as a possible case of mistake by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: But this case also arises out of a 1990 incident, the same incident as the one that you previously described?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Now, doctor, in your opinion, were the mistakes that you've described of a mischaracterization of entry and exit wounds and a mischaracterization of the distance between the gun and the body at the time the shot was fired matters that were significant mistakes by Dr. Golden?

DR. LAKSHMANAN: Yes.

MR. KELBERG: How were they significant medically?

DR. LAKSHMANAN: Medically, they were significance because the range of fire is important, and also the direction of fire is important. But as far as the cause of death goes, there was no impact.

MR. KELBERG: Doctor, have you told us in summary the circumstances of those two cases as cases of mistakes by Dr. Golden?

DR. LAKSHMANAN: Yes. I just gave a brief summary. The mistakes were mainly in interpretation of characteristics of the entrance and exit in one and the interpretation of the range of fire in the other case.

MR. KELBERG: Did you also become aware of a case involving Dr. Golden, a decedent's name of Manley Hall, H-A-L-L?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: What is that case all about with respect to any mistakes by Dr. Golden?

DR. LAKSHMANAN: There, the issue was whether he identified the presence of a thyroid gland. The person in question had had a thyroidectomy by history in the past and he had described the presence of a thyroid gland. But in this situation, we did have the neck organ saved. So--which we evaluated. And based on the history and the absence of the thyroid gland in the neck organs, an amendment to the report was issued. This is one of the amendments issued.

MR. KELBERG: On whose initiative?

DR. LAKSHMANAN: My initiative in the sense that at the request of the attorney of the families, it was a person in the family who brought this to our attention.

MR. KELBERG: And you reviewed the case?

DR. LAKSHMANAN: Yes. And I reviewed the neck organs with Dr. Golden.

MR. KELBERG: And you believed that it was appropriate to issue an amendment?

DR. LAKSHMANAN: Yes, based on the information provided because apparently he--this gentleman had a thyroidectomy many years ago, 40 years ago. So I requested for the hospital records before we issued the amendment, which could not be obtained because of the long time interval since the surgery and the death. But the attorney provided a declaration reflecting her attempts to obtain those records, and based on the review of the neck organs, which were available, and the information provided and also review of the medical records which indicated that this particular person was on replacement thyroid therapy, I believe--Dr. Golden and I felt that there was sufficient information to issue the amendment regarding this aspect of the case.

MR. KELBERG: I'm sorry. In essence, did Dr. Golden say that the patient or Mr. Hall, the decedent, had a thyroid gland when in fact the thyroid gland had been surgically removed 40 years earlier? Is that the essence of the mistake?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Was that mistake in your opinion significant to your evaluation of the case as a forensic pathologist?

DR. LAKSHMANAN: No. Because we had the neck organs available and there was no evidence of any injury or anything. So there's no question of any other factor in the case.

MR. KELBERG: Now, doctor, at some time after the deaths of Nicole Brown Simpson and Ronald Goldman, were you approached by a gentleman by the name of Sam Donaldson from ABC news?

DR. LAKSHMANAN: I was accosted by him while I was entering my office one morning when I was coming to work. Yes.

MR. KELBERG: Would you describe, please, the circumstances under which you were, to use your term, "Accosted" by Samuel Donaldson?

DR. LAKSHMANAN: Basically I was coming to work. I parked my car and I--

THE COURT: Excuse me. Hold on, doctor. What's the--the relevance of this is--

MR. KELBERG: There's going to be a statement that Dr. Lakshmanan made to Mr. Donaldson under the circumstances, and the circumstances are relevant to the nature of the statement that was made.

THE COURT: Let me see you with the court reporter, please.

MR. KELBERG: May I come through the well, your Honor?

THE COURT: Yes.

(Proceedings were held at the bench, not reported.)

(The following proceedings were held in open court:)

THE COURT: Thank you, counsel.

MR. KELBERG: Thank you, your Honor.

MR. KELBERG: Doctor, again, if you'd describe the circumstances, please.

DR. LAKSHMANAN: I was coming to work that morning. I parked my car, and as I opened my door of my car, I found several cameras and saw Sam Donaldson coming approaching me suddenly and started asking questions on the current cases which I'm testifying to on--and other issues which he brought up like he brought up the issue of what was the 16 pieces of evidence which was a problem and he wanted to know about Dr. Golden per se and also how we had conducted our--the--the--what he felt about the performance of the office on the autopsies on the current two decedents.

MR. KELBERG: Doctor, were you expecting to see Sam Donaldson that day?

DR. LAKSHMANAN: No. I was just coming to work.

MR. KELBERG: Was the date August 25th of 1994?

DR. LAKSHMANAN: That seems to be about right.

MR. KELBERG: And did you later see an episode or a segment of a program with Sam Donaldson that you've described as prime time live which displayed a portion at least of what you've described for us here?

DR. LAKSHMANAN: Yes. And that's the episode which brought up these two cases of Dr. Golden from the past, which I was not aware of until that particular episode, and I came to be aware of that.

MR. KELBERG: I have--Mr. Fairtlough apparently has this cued up with the laser, and I would ask at this time if this can be marked--I assume this is marked in some fashion from the laser as an exhibit. So I would ask that it be marked as People's exhibit 363.

THE COURT: All right.

(Peo's 363 for id = videotape)

MR. KELBERG: By my Kelberg: And I'm going to ask, doctor, if this is what you saw on television. Please start.

(At 5:45 P.M., People's exhibit 363, a videotape, was played.)

MR. KELBERG: Doctor, you can look down.

DR. LAKSHMANAN: I'm sorry. I didn't see it.

MR. KELBERG: While we have it stopped, doctor, do you recognize the two people seen in this scene from this exhibit 363?

DR. LAKSHMANAN: Yes. He's trying to get some information from Dr. Golden directly.

MR. KELBERG: Just for the record, would you identify who Dr. Golden is and who the other individual is in this stop of the disk?

DR. LAKSHMANAN: Dr. Golden is carrying some papers in his left hand. He's the gentleman on the right side with the glasses and the gray jacket. Mr. Sam Donaldson is holding up some paper in his right hand and is wearing a darker colored suit and he doesn't wear glasses.

MR. KELBERG: All right. If we could continue, Mr. Fairtlough, please.

(The videotape continues playing.)

MR. KELBERG: If we could stop it there. I'm through with the playing.

(At 5:47 P.M., the playing of the videotape concluded playing.)

MR. KELBERG: I have some questions, very brief, to ask Dr. Lakshmanan, if I could.

THE COURT: Very briefly.

MR. KELBERG: Dr. Lakshmanan, when you were talking to Sam Donaldson and you told him that in your opinion, Dr. Golden was a very competent forensic pathologist, did you mean that?

DR. LAKSHMANAN: Yes. That was my belief at that time and still is because "Competent" to me means that a person whom has the requirements to do the job. He's a board certified pathologist, he's still working for our office and does his work in a competent manner.

MR. KELBERG: Doctor, after finding all of the mistakes that you've identified for this jury over the course of the last six or seven days in this set of autopsies, after learning of the Gaye, Phillips matter, after learning of the Manley Hall matter, how can you form in your mind an opinion that Dr. Golden is a very competent forensic pathologist?

DR. LAKSHMANAN: I said he's a competent pathologist.

MR. KELBERG: I think you said very competent, and we can have it replayed if you want.

DR. LAKSHMANAN: I agree there I said very competent because I was not aware of those other mistakes.

MR. KELBERG: Doctor, is there a rating classification in the county system where you must on an annual basis rate your employees?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Is the term "Competent" a term that is used in the rating system?

DR. LAKSHMANAN: Yes.

MR. KELBERG: And where in the rating system does a competent finding place one?

DR. LAKSHMANAN: About that--that means they meet the adequate requirements to do the job and there is--it's just above the "Improvement needed" box.

MR. KELBERG: Just above the--I'm sorry?

DR. LAKSHMANAN: There are only a couple boxes there in the county evaluation. You have improvement needed, you have competent, very good and outstanding.

MR. KELBERG: And in the year of 1994, was Dr. Golden rated as "Competent"?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Not "Very good"?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Not "Outstanding"?

DR. LAKSHMANAN: That is correct.

MR. KELBERG: Is that still your judgment, that he is "Competent" as that term is used?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, were you trying to protect Dr. Golden when you were, to use your term, "Accosted" by Sam Donaldson on August 25th, 1994?

MR. SHAPIRO: Objection. Leading and suggestive.

THE COURT: Sustained. Rephrase the question.

MR. KELBERG: What if anything were you trying to accomplish when you answered Mr. Donaldson's question regarding Dr. Golden?

MR. SHAPIRO: Objection. Irrelevant.

THE COURT: Overruled. You can answer.

MR. KELBERG: You can answer.

DR. LAKSHMANAN: I was just trying to tell Mr. Donaldson that in my opinion, Dr. Golden is a competent pathologist, he has been working with our office since 1981 and he has done over 5,000 cases, he's always been--he's always handled his cases, the most demanding cases in a competent manner. And, as I told you, I was not aware of these errors which were brought to my attention, but in 5,000 cases, these are some--few errors that have been brought to my attention as long as he's been in the office.

MR. KELBERG: Doctor, how could you justify a statement that your office had done a very good job in the Nicole Brown Simpson/goldman autopsy cases knowing, as you did on August 25th, for example, the missed brain contusion? You knew that, didn't you?

DR. LAKSHMANAN: Yes, I knew that.

MR. KELBERG: You knew about the mistakes in the one wound versus two wounds to the neck on the right side of Mr. Goldman, didn't you?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: And you knew the same mistake, two wounds versus one wound on the left side of the neck of Mr. Goldman, didn't you?

DR. LAKSHMANAN: Yes, I did.

MR. KELBERG: And you have an addendum dated July 1 that indicates a series of mistakes, correct?

DR. LAKSHMANAN: Yes.

MR. KELBERG: Doctor, how could you say to Mr. Donaldson when you were accosted by him that you believed your office had done a very good job in these two cases?

DR. LAKSHMANAN: Well, that is my--I mean, first of all, I was taken by surprise when this happened. And no. 2, it was not an intelligent conversation which took place at that time because he suddenly surprised me. But still-- let me put it this way. At that time, I felt that we did a very good job because I felt we met the big picture regarding the cause of death, the manner of death. And really, I couldn't discuss these mistakes with Mr. Donaldson at the time because the case was still in trial and we were not allowed to discuss the case at the time. The reports were not released to anybody. So really, I couldn't intelligently discuss the mistakes which I knew about at that time.

MR. KELBERG: Doctor, do you still feel that way, that your office did a very good job in these two cases given all of the mistakes you've identified and testified about during the course of the last six or so days?

DR. LAKSHMANAN: No. I mean I think we still did an adequate job, but I don't think we did a very good job because when I studied the case in detail, I found additional mistakes which we have discussed in the last few days in this trial. I'm not--I would say that we were doing a satisfactory job in portions of the case and less than satisfactory as far as certain portions of the autopsy because of the mistakes which I've already outlined these few days. But still, as far as the big picture goes, I think we did an adequate performance, that the injuries have been documented, they've been photographed, the cause and manner of death has been discussed--I mean have been determined. And as you can see in the last few days, which we have discussed all the findings on both the cases, the significant fatal injuries have been well documented. There have been some omissions in certain other injuries. So I won't say my opinion has changed since then in my detailed review of the case.

MR. KELBERG: Do you think that your office strives for merely being adequate?

DR. LAKSHMANAN: No. We--as I told you a few days earlier, we want to do the best we can with our resources. As I told you, we are a high-volume office with limited resources. We try very hard not to make mistakes. And in this case, some mistakes have occurred and you all have seen me the last few days. I have nothing to hide here and I went over all the mistakes. But I also pointed out that the significant injuries have been documented and one can easily interpret the cause and manner of death and one can easily interpret the--whether it's from a single-edged or double-edged knife with all the findings we have. But by opinion is no longer that it was a very good job on these two cases, no.

MR. KELBERG: Your Honor, is this a proper time?

THE COURT: Yes. And tomorrow, Mr. Kelberg, how much time do you think you'll need to conclude?

MR. KELBERG: I hope by noon.

THE COURT: All right. All right. Ladies and gentlemen, we're going to take our recess for the evening. Please remember all my admonitions to you; do not discuss this case amongst yourselves, do not form any opinions about the case, do not conduct any deliberations until the matter has been submitted to you, do not allow anybody to communicate with you with regard to the case. We'll stand in recess until 9:00 o'clock tomorrow morning. Thank you very much, doctor. You can step down.

(At 5:55 P.M., an adjournment was taken until, Wednesday, June 14, 1995, 9:00 A.M.)

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE County of Los Angeles

Department no. 103 Hon. Lance A. Ito, Judge

The People of the State of California,)

Plaintiff,)

Vs.) No. BA097211)

Orenthal James Simpson,)

Defendant.)

Reporter's transcript of proceedings Tuesday, June 13, 1995

Volume 166 pages 31579 through 31883, inclusive

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APPEARANCES:

Janet M. Moxham, CSR #4588 Christine M. Olson, CSR #2378 official reporters

FOR THE PEOPLE: Gil Garcetti, District Attorney by: Marcia R. Clark, William W. Hodgman, Christopher A. Darden, Cheri A. Lewis, Rockne P. Harmon, George W. Clarke, Scott M. Gordon Lydia C. Bodin, Hank M. Goldberg, Alan Yochelson and Darrell S. Mavis, Brian R. Kelberg, and Kenneth E. Lynch, Deputies 18-000 Criminal Courts Building 210 West Temple Street Los Angeles, California 90012

FOR THE DEFENDANT: Robert L. Shapiro, Esquire Sara L. Caplan, Esquire 2121 Avenue of the Stars 19th floor Los Angeles, California 90067 Johnnie L. Cochran, Jr., Esquire by: Carl E. Douglas, Esquire Shawn Snider Chapman, Esquire 4929 Wilshire Boulevard Suite 1010 Los Angeles, California 90010 Gerald F. Uelmen, Esquire Robert Kardashian, Esquire Alan Dershowitz, Esquire F. Lee Bailey, Esquire Barry Scheck, Esquire Peter Neufeld, Esquire Robert D. Blasier, Esquire William C. Thompson, Esquire

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I N D E X

Index for volume 166 pages 31579 - 31883

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Day date session page vol.

Tuesday June 13, 1995 A.M. 31579 166 P.M. 31713 166

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LEGEND: Ms. Clark-mc Mr. Hodgman-h Mr. Darden d Mr. Kahn-k Mr. Goldberg-gb Mr. Gordon-g Mr. Shapiro-s Mr. Cochran-c Mr. Douglas-cd Mr. Bailey-b Mr. Uelmen-u Mr. Scheck-bs Mr. Neufeld-n

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CHRONOLOGICAL INDEX OF WITNESSES

PEOPLE'S witnesses direct cross redirect recross vol.

Sathyavagiswaran, Lakshmanan 166 (Resumed) 31606Bk (Resumed) 31719Bk

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ALPHABETICAL INDEX OF WITNESSES

WITNESSES direct cross redirect recross vol.

Sathyavagiswaran, Lakshmanan 166 (Resumed) 31606Bk (Resumed) 31719Bk

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EXHIBITS

PEOPLE'S for in exhibit identification evidence page vol. Page vol.

358-A - Coroner's photo 31592 166 depicting a wound in the neck of Mr. Goldman and the gloved hand of an individual

358-B - Coroner's photo 31592 166 (Cropped into 3 sections) depicting the face, wound to the neck of Mr. Goldman and the gloved hands of an, individual

362 - Chart 31694 166 with 7 photographs entitled "Sharp force injuries to left flank, left thigh and right chest of Mr. Goldman/blunt force trauma and lividity"

363 - Videotape of 31874 166 a conversation between Dr. Golden and Sam Donaldson; Dr. Sathyavagiswaran and Sam Donaldson