Exhibit V: Deposition of Dr. Rinku Shah

April 30, 2026 · 10:06 a.m. · Case No. 2024-L-005346, consolidated with 2024-L-010547

HTML reproduction of the six filed PDF sheets. The supplied exhibit contains transcript pages 1–9 and 62–72; pages 10–61 are not included. Original page and line numbers, certification signatures, and the blank final panel are retained.

Contents
FILED DATE: 8/28/2026 10:56 PM 2024L005346
Veritext Legal Solutions
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Page 1
1IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
2COUNTY DEPARTMENT, LAW DIVISION
3________________________________
4DELBERT J. CHARLES, as
5Independent Administrator of the
6Estate of ABNERD JOSEPH,
7Deceased, Job No. CS8049870
8 Plaintiff,
9 v. No. 2024L005346
10SUDLER AND COMPANY D/B/A SUDLER Consolidated with
11PROPERTY MANAGEMENT; LEGACY AT No. 2024L010547
12MILLENNIUM PARK CONDOMINIUM
13ASSOCIATION; DEBORAH ROMERO;
14DOMINIC TEDALDI; GARRETT MARK
15SMITH; YOUNAN "JONAH" NENA;
16ANDREW CLEMENT; ROBERT JOHN
17BISHOPP, JR.; and NATALIE
18BISHOPP,
19 Defendants,
20 and
21STEVEN LEVY; CONSTANTINE "DEAN"
22ANDREWS; JOHN CARONA; and
23ASSOCIA, INC.,
24 Respondents in
FILED DATE: 8/28/2026 10:56 PM 2024L005346
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2 (Pages 2 - 5)
Page 2
1Discovery.
2________________________________
3GARRETT M. SMITH,
4Plaintiff,
5v.
6DELBERT J. CHARLES, as
7Independent Administrator of the
8Estate of ABNERD JOSEPH,
9Deceased,
10Defendant.
11________________________________
12DEPOSITION OF RINKU SHAH, D.O.
13DATE: Thursday, April 30, 2026
14TIME: 10:06 a.m.
15LOCATION: Remote Proceeding
16Hinsdale, IL 60521
17REPORTED BY: Brittany Olis
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Page 3
1APPEARANCES
2ON BEHALF OF PLAINTIFF DELBERT J. CHARLES:
3PAUL M. MCMAHON, ESQUIRE (by videoconference)
4Romanucci & Blandin, LLC
5321 North Clark Street, Suite 900
6Chicago, IL 60654
7pmcmahon@rblaw.net
8(312) 253-8810
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10ON BEHALF OF DEFENDANTS SUDLER AND COMPANY D/B/A
11SUDLER PROPERTY MANAGEMENT, DEBORAH ROMERO, AND
12DOMINIC TEDALDI; AND RESPONDENTS IN DISCOVERY STEVEN
13LEVY, CONSTANTINE "DEAN" ANDREWS, JOHN CARONA, AND
14ASSOCIA, INC.:
15MICHAEL J. WEISS, ESQUIRE (by videoconference)
16Cozen O'Connor
17123 North Wacker Drive, Suite 1800
18Chicago, IL 60606
19mjweiss@cozen.com
20(213) 892-7900
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Page 4
1APPEARANCES (Cont'd)
2ON BEHALF OF DEFENDANTS LEGACY AT MILLENNIUM PARK
3CONDOMINIUM ASSOCIATION AND YOUNAN "JONAH" NENA:
4KENNETH E. YEADON, ESQUIRE (by videoconference)
5Hinshaw & Culbertson LLP
6151 North Franklin Street, Suite 2500
7Chicago, IL 60606
8kyeadon@hinshawlaw.com
9(312) 704-3524
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11ON BEHALF OF DEFENDANT GARRETT MARK SMITH:
12ERIN I. WENGER, ESQUIRE (by videoconference)
13Sweeney Scharkey & Blanchard LLC
14230 West Monroe Street, Suite 1500
15Chicago, IL 60606
16ewenger@ssbpartners.com
17(312) 384-0500
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Page 5
1APPEARANCES (Cont'd)
2ON BEHALF OF DEFENDANT ANDREW CLEMENT:
3JOHN A. LOSURDO, ESQUIRE (by videoconference)
4Amundsen Davis LLC
53815 East Main Street, Suite A-1
6St. Charles, IL 60174
7jlosurdo@amundsendavislaw.com
8(630) 587-7922
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10ON BEHALF OF DEFENDANTS ROBERT JOHN BISHOPP, JR. AND
11NATALIE BISHOPP:
12ALLIE M. BURNET, ESQUIRE (by videoconference)
13Best Vanderlaan & Harrington
14200 North LaSalle Street, Suite 600
15Chicago, IL 60601
16aburnet@bestfirm.com
17(312) 819-1100
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FILED DATE: 8/28/2026 10:56 PM 2024L005346
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3 (Pages 6 - 9)
Page 6
1APPEARANCES (Cont'd)
2ON BEHALF OF RINKU SHAH, D.O.:
3ROENAN PATT, ESQUIRE (by videoconference)
4Levin Ginsburg
5180 North LaSalle Street, Suite 3200
6Chicago, IL 60601
7rpatt@levinginsburg.com
8(847) 708-3142
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Page 7
1INDEX
2EXAMINATION: PAGE
3By Mr. Weiss 10
4By Mr. McMahon 49
5By Ms. Wenger 55
6By Ms. Burnet 64
7By Mr. McMahon 66
8By Ms. Burnet 68
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10EXHIBITS
11NO. DESCRIPTION PAGE
12Exhibit A Curriculum Vitae of Rinku Trivedi,
13D.O., AKA Rinku Shah, D.O. 14
14Exhibit B TRIVEDIMD LLC Billing Summary 22
15Exhibit C Medical Records from Clear
16Wellness Group 24
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Page 8
1PROCEEDINGS
2THE REPORTER: Good morning. My name
3is Brittany Olis; I'm the reporter assigned by
4Veritext to take the record of this proceeding. We
5are now on the record at 10:06 a.m.
6This is a deposition of Dr. Rinku Shah,
7taken in the matter of the estate -- or I'm sorry. I
8have the -- the wrong notice -- of Delbert J. Charles,
9et al., vs. Garrett Smith, et al., on Thursday,
10April 30, 2026.
11I'm a notary authorized to take
12acknowledgments and administer oaths in Illinois.
13Parties agree that I will swear in the witness
14remotely.
15Additionally, absent an objection on
16the record before the witness is sworn, all parties
17and the witness understand and agree that any
18certified transcript produced from the recording of
19this proceeding:
20- is intended for all uses permitted
21under applicable procedural and
22evidentiary rules and laws in the
23same manner as a deposition recorded
24by stenographic means; and
Page 9
1- shall constitute written stipulation
2of such.
3At this time will everyone in
4attendance please identify yourself for the record,
5beginning with the doctor.
6DR. SHAH: Hi. I'm Dr. Rinku Shah.
7MR. MCMAHON: Paul McMahon, on behalf
8of the plaintiffs.
9MR. WEISS: Michael Weiss --
10MS. WENGER: Erin Wenger -- sorry.
11MR. WEISS: Sorry.
12MS. WENGER: Go ahead.
13MR. WEISS: Michael Weiss on behalf of
14Sudler, Deborah Romero, and Dominic Tedaldi.
15MS. WENGER: Erin Wenger from Sweeney
16Scharkey, on behalf of Garrett Smith.
17MR. LOSURDO: John Losurdo on behalf of
18Defendant Andrew Clement.
19MR. PATT: Roenan Patt on behalf of
20Dr. Shah.
21MR. LOSURDO: Ken --
22MS. BURNET: Allie Burnet for the
23Bishopps. Sorry.
24MR. YEADON: Ken Yeadon for Legacy and
FILED DATE: 8/28/2026 10:56 PM 2024L005346
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17 (Pages 62 - 65)
Page 62
1A Say that again.
2Q Are you familiar with a drug -- it's a
3street drug called tusi?
4A Unfortunately, no.
5Q Okay.
6MR. MCMAHON: No. Probably
7fortunately.
8THE WITNESS: Say that again. What?
9MR. MCMAHON: Probably, fortunately,
10no, that you don't know of it.
11THE WITNESS: Just so I know, tusi?
12MR. MCMAHON: T-U-S-I. Yeah.
13BY MS. WENGER:
14Q Tusi, T-U-S-I or T-U-S-S-I.
15A Yeah. I just found out what purple sizzurp
16or something is.
17Q And back to -- so similar to the question
18about cocaine, if you had a patient who was using
19marijuana, would you want to know that also before
20prescribing them Adderall?
21A That's usually what -- when, like, they say
22something like this, it's -- we do -- if someone's
23on -- like, we're -- I would actually -- we're okay
24with prescribing stimulants with people who are using
Page 63
1marijuana.
2Q And why is that different than what your
3answer was for cocaine?
4A It's -- it's legal.
5Q Okay.
6A Like, you can -- it's -- it's something that
7is not -- cocaine is not legal currently. Like, you
8can go into the way it's, like, regulated currently.
9There is the -- the interactions.
10Q What about the interactions?
11A Well, not -- there's just -- the one's an
12illicit drug, and one isn't.
13Q Let me take a look at my notes real quick
14here. Doctor, I know you said that you did not review
15the PeachState Psychiatric records. Do you have any
16knowledge of anyone else in your office reviewing
17those?
18A I'm not saying I did not review them. I'm
19not saying if I recalled reviewing them.
20Q Oh, I didn't mean to put words in your
21mouth. So do you have any knowledge of anyone else
22reviewing them in your office?
23A No. I wouldn't know who reviewed them and
24who didn't.
Page 64
1MS. WENGER: Okay. I think that's all
2I have. Thank you, Doctor.
3THE WITNESS: Thank you.
4MR. MCMAHON: I don't have anything
5else.
6MS. BURNET: I just have two quick
7ones.
8EXAMINATION
9BY MS. BURNET:
10Q Doctor, my name's Allie Burnet; I represent
11the Bishopps in this matter. Fair to say on the
12intake form where the drug use box was checked "yes,"
13do you -- you rely upon your patients to truthfully
14report what sort of recreational or illicit drugs
15they're taking; correct?
16A Correct.
17Q And you would find that reporting
18significant in terms of your assessment of what other
19medications may be appropriate for them, based on that
20other drug use; correct?
21A Yes.
22Q Okay. And I think you mentioned there'd be
23a difference between cocaine and marijuana use
24interacting with Adderall, based on the legality of
Page 65
1the two drugs; is that correct?
2A Correct.
3Q Does the fact that cocaine is a stimulant
4also impact your assessment in terms of whether you
5would prescribe Adderall to a patient who reported
6that?
7A Yes.
8Q Okay. And how so?
9A I think the combination of those two could
10lead to a compounding effect.
11Q Okay. And what do you mean by a
12"compounding effect" in layperson's terms?
13A I mean, I'm not an expert on this; but I
14wouldn't want someone taking medications that
15theoretically can do -- a stimulant -- I'm not -- I --
16I wouldn't want -- like, I say -- I tell a patient,
17"Don't take more than the prescribed dose."
18So if a medicine is doing a similar thing
19but to a heightened level, I -- I wouldn't want them
20to take two of those things together.
21Q Okay. And are you aware of there being
22mental health consequences of a person taking too many
23stimulants?
24MR. MCMAHON: Object to the form of the
FILED DATE: 8/28/2026 10:56 PM 2024L005346
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18 (Pages 66 - 69)
Page 66
1question. It’s too general.
2Go ahead.
3THE WITNESS: Yes. That's why there's
4a -- why we monitor patients monthly on the doses that
5we take. We tell them that there's side effects of
6the medications we take, and then we monitor the
7patients.
8BY MS. BURNET:
9Q Okay. And just -- I think I understood this
10based on your prior testimony, but fair to say your
11testimony today has been from your records rather than
12an independent recollection of the patient?
13A That's correct.
14MS. BURNET: Okay. That's all I have.
15Thank you.
16MR. MCMAHON: I have one follow-up to
17that, if people -- unless others want to go.
18MR. YEADON: I don't have any
19questions. Go ahead, Paul.
20MR. MCMAHON: Okay.
21EXAMINATION
22BY MR. MCMAHON:
23Q Doctor, she was just asking you about, you
24know, a potential psychological/psychiatric effects of
Page 67
1of Adderall. You're not aware of any potential of
2Adderall causing psychotic symptoms, are you?
3A If it's not used -- if it's used as
4directed, no. But if it's used not in an improper
5way, like if you're going to take more than the
6prescribed dose or something, then I can see how it
7can cause problems. But, no, not used for the
8corrected -- the -- no.
9Q Well, I'm asking you, I mean, is there
10things in the medical literature, you know, indicating
11that Adderall, even if it's used excessively, could
12cause psychotic symptoms?
13MR. YEADON: Objection. Foundation.
14MS. WENGER: Objection.
15BY MR. MCMAHON:
16Q And whether you know or not?
17MS. BURNET: Objection joined.
18THE WITNESS: Not to my knowledge. I
19have --
20MR. MCMAHON: All right. Fair enough.
21I don't have anything else.
22MS. BURNET: I have one more.
23//
24//
Page 68
1EXAMINATION
2BY MS. BURNET:
3Q Doctor, you understood when I asked you the
4question about use of Adderall with other stimulants,
5such as cocaine, I was not talking about just using
6Adderall on its own; correct?
7MR. MCMAHON: Objection to form.
8THE WITNESS: You were using it -- you
9were asking about a combination effect.
10BY MS. BURNET:
11Q That's correct.
12A Yes.
13Q Did you understand that was my question?
14A Yeah. Yeah.
15MS. BURNET: Okay. Thank you. That's
16all I have.
17MR. MCMAHON: Anything else? Anybody
18else?
19MR. WEISS: I don't have anything.
20MR. MCMAHON: Okay.
21MS. BURNET: No.
22Thanks for your time, Doctor.
23MR. MCMAHON: Counsel, waive? Reserve?
24MR. PATT: Waive.
Page 69
1MR. MCMAHON: All right.
2Thanks, Dr. Shah. Nice to meet you.
3MS. BURNET: All right. Thank you,
4guys.
5MR. WEISS: Thanks, Dr. Shah.
6MS. WENGER: Thank you. Appreciate
7your time.
8THE REPORTER: And then before we go
9off the record, can I just ask if there are any
10transcript orders?
11MR. WEISS: I'll order, Brittany.
12MR. MCMAHON: I'll take a copy.
13MR. YEADON: As will I.
14MS. WENGER: I'll take an electronic
15copy.
16MS. BURNET: Yeah. I'll take a copy as
17well.
18MR. LOSURDO: I will also take a PDF
19copy.
20MR. MCMAHON: All right. Thanks,
21everybody.
22MS. BURNET: Thanks, all.
23MR. WEISS: Thanks, guys.
24MS. WENGER: Thank you.
FILED DATE: 8/28/2026 10:56 PM 2024L005346
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19 (Pages 70 - 73)
Page 70
1THE REPORTER: Going off the record,
211:40 a.m.
3(Signature waived.)
4(Whereupon, at 11:40 a.m., the
5proceeding was concluded.)
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Page 71
1CERTIFICATE OF DEPOSITION OFFICER
2I, BRITTANY OLIS, the officer before whom
3the foregoing proceedings were taken, do hereby
4certify that any witness(es) in the foregoing
5proceedings, prior to testifying, were duly sworn;
6that the proceedings were recorded by me and
7thereafter reduced to typewriting by a qualified
8transcriptionist; that said digital audio recording of
9said proceedings are a true and accurate record to the
10best of my knowledge, skills, and ability; that I am
11neither counsel for, related to, nor employed by any
12of the parties to the action in which this was taken;
13and, further, that I am not a relative or employee of
14any counsel or attorney employed by the parties
15hereto, nor financially or otherwise interested in the
16outcome of this action.
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19BRITTANY OLIS
20Notary Public in and for the
21State of Illinois
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Page 72
1CERTIFICATE OF TRANSCRIBER
2I, MIYA S. FOWLER, do hereby certify that
3this transcript was prepared from the digital audio
4recording of the foregoing proceeding, that said
5transcript is a true and accurate record of the
6proceedings to the best of my knowledge, skills, and
7ability; that I am neither counsel for, related to,
8nor employed by any of the parties to the action in
9which this was taken; and, further, that I am not a
10relative or employee of any counsel or attorney
11employed by the parties hereto, nor financially or
12otherwise interested in the outcome of this action.
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15MIYA S. FOWLER
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