FILED DATE: 8/28/2026 10:56 PM 2024L005346
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1IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 2COUNTY DEPARTMENT, LAW DIVISION 3________________________________ 5Independent Administrator of the 6Estate of ABNERD JOSEPH, 7Deceased, Job No. CS8049870 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 21STEVEN LEVY; CONSTANTINE "DEAN" 22ANDREWS; JOHN CARONA; and FILED DATE: 8/28/2026 10:56 PM 2024L005346
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2________________________________ 7Independent Administrator of the 8Estate of ABNERD JOSEPH, 11________________________________ 12DEPOSITION OF RINKU SHAH, D.O. 13DATE: Thursday, April 30, 2026 15LOCATION: Remote Proceeding 17REPORTED BY: Brittany Olis Page 3
2ON BEHALF OF PLAINTIFF DELBERT J. CHARLES: 3PAUL M. MCMAHON, ESQUIRE (by videoconference) 4Romanucci & Blandin, LLC 5321 North Clark Street, Suite 900 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 15MICHAEL J. WEISS, ESQUIRE (by videoconference) 17123 North Wacker Drive, Suite 1800 Page 4
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 11ON BEHALF OF DEFENDANT GARRETT MARK SMITH: 12ERIN I. WENGER, ESQUIRE (by videoconference) 13Sweeney Scharkey & Blanchard LLC 14230 West Monroe Street, Suite 1500 16ewenger@ssbpartners.com Page 5
2ON BEHALF OF DEFENDANT ANDREW CLEMENT: 3JOHN A. LOSURDO, ESQUIRE (by videoconference) 53815 East Main Street, Suite A-1 7jlosurdo@amundsendavislaw.com 10ON BEHALF OF DEFENDANTS ROBERT JOHN BISHOPP, JR. AND 12ALLIE M. BURNET, ESQUIRE (by videoconference) 13Best Vanderlaan & Harrington 14200 North LaSalle Street, Suite 600 FILED DATE: 8/28/2026 10:56 PM 2024L005346
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2ON BEHALF OF RINKU SHAH, D.O.: 3ROENAN PATT, ESQUIRE (by videoconference) 5180 North LaSalle Street, Suite 3200 Page 7
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 Page 8
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, 11I'm a notary authorized to take 12acknowledgments and administer oaths in Illinois. 13Parties agree that I will swear in the witness 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 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 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 9MR. WEISS: Michael Weiss -- 10MS. WENGER: Erin Wenger -- sorry. 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 22MS. BURNET: Allie Burnet for the 24MR. YEADON: Ken Yeadon for Legacy and FILED DATE: 8/28/2026 10:56 PM 2024L005346
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2Q Are you familiar with a drug -- it's a 3street drug called tusi? 6MR. MCMAHON: No. Probably 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. 14Q Tusi, T-U-S-I or T-U-S-S-I. 15A Yeah. I just found out what purple sizzurp 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
2Q And why is that different than what your 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 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 Page 64
1MS. WENGER: Okay. I think that's all 2I have. Thank you, Doctor. 4MR. MCMAHON: I don't have anything 6MS. BURNET: I just have two quick 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? 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? 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? 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 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 24MR. MCMAHON: Object to the form of the FILED DATE: 8/28/2026 10:56 PM 2024L005346
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1question. It’s too general. 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 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? 14MS. BURNET: Okay. That's all I have. 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. 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 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. 16Q And whether you know or not? 17MS. BURNET: Objection joined. 18THE WITNESS: Not to my knowledge. I 20MR. MCMAHON: All right. Fair enough. 21I don't have anything else. 22MS. BURNET: I have one more. Page 68
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. 13Q Did you understand that was my question? 15MS. BURNET: Okay. Thank you. That's 17MR. MCMAHON: Anything else? Anybody 19MR. WEISS: I don't have anything. 22Thanks for your time, Doctor. 23MR. MCMAHON: Counsel, waive? Reserve? Page 69
2Thanks, Dr. Shah. Nice to meet you. 3MS. BURNET: All right. Thank you, 5MR. WEISS: Thanks, Dr. Shah. 6MS. WENGER: Thank you. Appreciate 8THE REPORTER: And then before we go 9off the record, can I just ask if there are any 11MR. WEISS: I'll order, Brittany. 12MR. MCMAHON: I'll take a copy. 14MS. WENGER: I'll take an electronic 16MS. BURNET: Yeah. I'll take a copy as 18MR. LOSURDO: I will also take a PDF 20MR. MCMAHON: All right. Thanks, 22MS. BURNET: Thanks, all. 23MR. WEISS: Thanks, guys. FILED DATE: 8/28/2026 10:56 PM 2024L005346
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1THE REPORTER: Going off the record, 4(Whereupon, at 11:40 a.m., the 5proceeding was concluded.) 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. 20Notary Public in and for the 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.