EXHIBIT 

Page 1
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ANNABEL K. MELONGO,
)
)
Plaintiff,
)
)
vs.
) Case No.
) 13-cv-04924
ASA ROBERT PODLASEK,
)
et al.,
)
)
Defendants.
)
The deposition of MATHEW MARKOS, M.D.,
called by the Plaintiff for examination, pursuant to
Notice, and pursuant to the Rules of Civil Procedure
for the United States District Courts, taken before
Renee E. Brass, CSR and Notary Public in and for the
County of Cook and State of Illinois, at 180 North
LaSalle Street, Suite 3600, Chicago, Illinois, on
February 20, 2018, at the hour of 10:24 p.m.

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PRESENT (continued)
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
BY: MS. SHIRLEY R. CALLOWAY
scalloway@atg.state.il.us
100 West Randolph Street
Chicago, IL 60601
(312) 814-5581
on behalf of Defendant Kyle French.

Reported by: Renee E. Brass, CSR, RPR
CSR No. 084-004119 - Expiration Date: May 31, 2019.

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PRESENT:
MILLER SHAKMAN & BEEM
BY: MS. JESSICA SCHWARTZ
jschwartz@millershakman.com
MR. WILLIAM J. KATT
wkatt@millershakman.com
180 North LaSalle Street, Suite 3600
Chicago, IL 60601
(312) 263-3700

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on behalf of the Plaintiff;
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COOK COUNTY STATE'S ATTORNEY'S OFFICE
BY: MR. JAMES E. HANLON, JR.
james.hanlon@cookcountyil.gov
50 West Washington Street, Room 500
Chicago, IL 60602
(312) 603-3369
on behalf of all Cook County
Defendants;

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KAPLAN PAPADAKIS & GOURNIS, P.C.
BY: MR. CHRISTOPHER S. WUNDER
cwunder@kpglaw.com
180 North LaSalle Street, Suite 2108
Chicago, IL 60601
(312) 726-0531
on behalf of Defendants William
Martin and the Village of
Schiller Park;
ANGELINI, MILLS, WOODS & ORI LAW
BY: MS. DINA M. NINFO
dnifo@amwolawil.com
155 North Michigan Avenue, Suite 400
Chicago, IL 60601
(312) 621-0000

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on behalf of Defendant Carol
Spizzirri;

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INDEX
EXAMINATIONS
PAGE
MR. SCHWARTZ
5
EXHIBITS
NO.
DESCRIPTION
PAGE
Exhibit No. 1 Summons
48
Exhibit No. 2 Summons
49
Exhibit No. 3 Consolidated Referral
53
Order
Exhibit No. 4 Transcript
57
Exhibit No. 5 Appointment Letter
67
Exhibit No. 6 Chronology of Events
72
Exhibit No. 7 Police Report
87
Exhibit No. 8 Report
89
Exhibit No. 9 Chicago Courthouse
90
document
Exhibit No. 10 Letter
116
Exhibit No. 11 Day of Arrest Document
119
Exhibit No. 12 Report
127
Exhibit No. 13 Report
128

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MATHEW MARKOS, M.D.,
having been first duly sworn, was examined and
testified as follows:
EXAMINATION
BY MR. SCHWARTZ:
Q. Good morning, Dr. Markos.
A. Good morning to you.
Q. My name is Julia Schwartz. I'm going to be
taking your deposition today.
Please state your name.
A. Mathew, spelled with one T, Markos,
M-A-R-K-O-S.
Q. Have you ever been deposed before,
Dr. Markos?
A. Yes.
Q. How many times?
A. I don't remember the exact number.
Q. Would you say more than five times?
A. Yes.
Q. Would you say more than 10 times?
A. Again, I don't remember the exact number.
Q. Would you say more than 50 times?
A. No.
Q. So fewer than 50 depositions. More than,

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Q. For those private cases that you referred
to, were those all in your capacity as an expert
witness?
A. Yes.
Q. In terms of those depositions which were
related to your employment at Cook County Courts,
were those all cases in which you were a party?
A. I was not a party. I was deposed in my
role as the director of the agency.
Q. Have you ever been deposed in a lawsuit in
which you were a party, either the defendant or the
plaintiff?
A. I do not recall.
Q. We may get into some of those details a bit
further, but I know you have been deposed a number of
times before, but I would like to go over some ground
rules before we go further.
A. Sure.
Q. First, we obviously have a court reporter
here today. For her sake, we should try not to talk
over one another.
I will let you finish your answers. Please
also let me finish your questions.
Is that okay with you?

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say, five?
A. Possibly.
Q. What sort of cases have you been deposed
in? Are they all civil lawsuits?
A. Yes.
Q. Were all of those lawsuits related to your
current employment at Cook County?
A. Not all.
Q. What did the others relate to?
A. There are civil cases that I handled
privately outside of Cook County Circuit Court.
Q. Let's go through some of those civil cases
outside of Cook County. What sort of cases were
those?
A. Mostly personal injury cases.
Q. In those were you a defendant or the
plaintiff or were you a witness being deposed?
A. I was an expert witness.
Q. In all of the cases in which you were
deposed outside of your position at Cook County
Court, you were an expert witness; is that right?
A. There were some cases which had to do with
my current employment with Cook County Circuit Court
and some private cases.

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A. Absolutely.
Q. Please give verbal answers. Head nods and
uh-uh and huh-uh don't translate well on to the
transcript.
Are you okay with that?
A. Absolutely.
Q. If I ask a question and you don't
understand it, will you let me know?
A. Yes.
Q. If you answer one of my questions, I will
assume that you understood the question; is that
fair?
A. It depends.
Q. But if you do not understand my question,
you will let me know that?
A. Certainly.
Q. If you need a break at any time, just let
me know.
The only thing I would ask is that you
finish answering whatever question I have just asked;
is that okay?
A. Definitely.
Q. Is there any reason that you can't give
truthful and accurate testimony today?

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A. No.
Q. Are you represented by counsel today?
A. Yes.
Q. That's Mr. Hanlon sitting to your left?
A. Correct.
Q. What have you done to prepare for today's
deposition?
A. I reviewed the case file on this case.
Q. By case file, what do you mean?
A. I mean the file maintained in the
Department of Forensic Clinical Services of this
individual.
Q. Were the contents of that case file to
which you just referred produced in this litigation?
A. I do not know.
Q. Did you meet with your attorney before this
deposition?
A. Yes.
Q. I wanted to go over some general background
questions about your background next. First off,
what county do you live in?
A. I live in DuPage County.
Q. I would like to go over your education
since high school. What's your educational

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1986 -- July 1986 -- I'm sorry.
That is essentially in a nutshell my
training.
Q. I'd like to walk through those points in a
little more detail, Dr. Markos.
You referred to your medical education in
India. Did you do any what would here be equivalent
to an undergraduate degree, or did you go straight
from high school into medical training at
Christian -- what was the name of the -A. Christian Medical College, Brown Memorial
Hospital.
I did a year of premedical prior to joining
Christian Medical College doing my graduate medical
training, and that's what I did.
Q. So what year was your year of premedical
training to get to the timeline?
A. 1971, '72.
Q. When did you start at Christian Medical
College, what year?
A. 1972.
Q. When did you finish your training at
Christian Medical College?
A. I graduated in 1976.

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background since you graduated from high school?
A. Since my graduation from high school, I
completed my medical education at Christian Medical
College and Brown Memorial Hospital in India, where I
also completed one year of rotating internship
encompassing various specialties, medicine, surgery,
so forth and psychiatry, after which I did my
post-graduate training in psychiatry in England, UK,
where I did my formal post-graduate training in
general psychiatry.
And after completing that, I came to
Chicago to pursue formal post-doctoral training in
forensic psychiatry, to which end I completed one
year of post-doctoral fellowship at
Rush-Presbyterian-St. Lukes Medical Center, currently
known as the Rush Medical Center.
After completing my fellowship,
post-doctoral fellowship in forensics, I completed an
additional year of internal medicine at Mt. Sinai
Hospital and Medical Center in Chicago, and after
finishing this training, I joined Cook County Circuit
Court as a staff forensic psychiatrist at the then
known Psychiatric Institute of Cook County, currently
known as Forensic Clinical Services back in June of

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Q. While you were at Christian Medical
College, was this general medical training? Did you
specialize in any particular area of medicine?
A. It is graduate medical training.
Q. So it's fairly general. You learned about
different areas of medicine?
A. In different specialties of medicine. It
was not a specialization.
Q. You mentioned after Christian Medical
College, you did spend some time doing rotating
training. What years were those rotations?
A. 1976 to '77. It was a one-year, 12-month
rotating internship.
Q. That was also in India?
A. Also at Christian Medical College.
Q. Do you recall which rotations you were
involved in during that year, which specialties?
A. Internal medicine, surgery, OB-GYNE,
pediatrics, community medicine, IENT.
Q. IENT, does that stand for ear, nose and
throat?
A. That's correct.
Q. You mentioned that after your rotations,
you went to the United Kingdom for post-graduate

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education, specifically in psychiatry?
A. That's correct.
Q. What was the name of the institution you
studied at?
A. I worked in various hospitals as part of my
post-graduate training, and they include All Saints
Hospital, Oakwood Hospital, Leybourne Grange,
L-E-Y-B-O-R-N-E (sic), Grange Hospital, all hospitals
in the South East Thames area.
Q. Which years were you at each of those
hospitals?
A. I don't remember.
Q. Roughly?
A. It was between the years of 1979 and '84.
Q. At that point were you specialized in
psychiatry in terms of your training?
A. I completed my post-graduate training in
general psychiatry, which encompassed general
psychiatry, a rotation in child, adolescence neuro
psych, geriatric psychiatric, but the specialty
training was general psychiatry.
Q. In 1984 did you receive a degree
culminating in that?
A. The post-graduate training that I did was

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post-graduate work in the United kingdom, you moved
to Chicago to complete additional education,
including a post-doc at Rush.
What years were you at Rush completing the
post-doc?
A. I was at Rush in between 1984 and '85. It
was a one-year post-doctoral fellowship in forensics.
Q. That year you spent at Rush was to
specialize in a particular area of psychiatry, that
area being forensic psychiatry?
A. Correct, to specialize in a subspecialty of
psychiatry, namely forensic psychiatry.
Q. Then after that year at Rush, you said you
spent a year of additional training doing internal
medicine at Mt. Sinai. What years did that span?
A. That was from 1985 to '86.
Q. What sorts of area were you studying during
that year at Mt. Sinai?
A. Just internal medicine as a resident.
Q. What was the reason for doing another
residency in the U.S.?
A. The reason was to become eligible to take
the board examination, the forensic board
examination, which required a year of primary care or

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equivalent to a residency training here, so there's
no diploma or degree except that completed
post-graduate training which qualified me to be board
eligible to take the boards.
Q. Did that qualify you to be board eligible
to take the boards in the United Kingdom or the
United States or both?
A. Both.
Q. Did you take the boards after that in 1984?
A. Yes.
Q. In the United States or in the United
Kingdom?
A. Well, I took part of it in England, but I
took the full board examination in the United States.
Q. What year was that that you took the U.S.
board examination?
A. I took two board examinations. The board
certification in general psychiatry I obtained in
1987.
Q. What was the second?
A. I'm also board certified in forensic
psychiatry by the American Board of Psychiatry and
Neurology, which I completed in 1994.
Q. You mentioned that after completing your

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internal medicine.
Q. After you spent a year at Mt. Sinai, you
then took the second board examination, board
examination for forensic psychiatry in the United
States?
A. No. I took my boards for the general
psychiatry boards, the general certification after
completing my internal medicine.
Q. When did you become board certified for
forensic psychiatry specifically?
A. The American Board of Psychiatry and
Neurology introduced board certification in 1994. I
took the very first exam and took it, so that
certification was available only in 1994.
Q. How would you define forensic psychiatry as
a practice?
A. Forensic psychiatry is a subspecialty in
the field of medicine and psychiatry which represents
the intersection of behavioral sciences and the law.
That's essentially what it really is.
Q. When you were receiving educational
training specific to forensic psychiatry, what were
the areas you focused on? What classes did you take
as some examples?

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A. During my fellowship, I attended law
classes at Kent School of Law, Kent IIT, and during
the fellowship, the training focused on legal matters
pertaining to mental health issues in the broad range
of civil and criminal areas.
Q. What sorts of legal matters are relevant to
a forensic psychiatrist?
A. The legal matters fall into two broad
categories from the forensic clinical standpoint,
criminal forensic psychiatry and civil forensic
psychiatry.
The criminal forensic issues relate
primarily to issues such as competency to stand trial
or fitness to stand trial, competency to be
sentenced, the sanity or the insanity defense,
ability to understand Miranda or waive one's Miranda
rights and other issues related to recommendations on
patients adjudicated unfit to stand trial or
adjudicated not guilty by reason of insanity, and so
that's generally the sort of criminal forensic areas.
And the civil area is mainly pertaining to
personal injury cases, medical malpractice, workmen's
comp, testamentary capacity and so forth, so my
practice currently is devoted to criminal forensics.

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Q. Are there any other educational institutes
or trainings that we haven't covered yet that you
participated in in your career?
A. I'm not clear about your question.
Q. I'll start with the first part. Other than
the institutions you mentioned, including Rush,
Mt. Sinai, Christian Medical College, others, are
there any other institutions, educational
institutions that you have attended for medical
training?
A. While I was in England, I did some locum
jobs or positions before I came to the U.S., not
necessarily as part of the training, but as sort of
an additional experience in various hospitals in
England.
Q. What sort of work were you doing at those
hospitals in England?
A. As a psychiatry resident. It was during my
residency training or the equivalent of residency
training in England where it's better known as the
post-graduate ETY 1 through 4, so during my training
I did some locum assignments at various hospitals in
England within the UK.
Q. Are there any other educational

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Q. You mentioned you took some legal training
in addition to your medical training. Was there any
other legal training that you participated in over
your career in addition to going to Kent?
A. In addition to attending classes and mock
trials at Kent, the teaching staff, forensic division
at that time had attorneys and lawyers, and I
received training from attorneys and psychiatrists
who specialized in that field, so that's training.
Q. When you say the forensics division, are
you referring to the forensics division within the
Cook County Circuit Court?
A. I'm referring to the section on psychiatry
and the law, also known as forensic psychiatry at
Rush-Presbyterian where I received my training.
Once I completed my training, then I
continued to practice forensic psychiatry in the
criminal arena at Cook County Circuit Court.
Q. Since you have been at Cook County Circuit
Court, have you received additional educational
training?
A. I have maintained my continuing medical
education by attending conferences, yes, by training
other staff.

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institutions that you have attended in your career?
A. No.
Q. In terms of additional training or
supplemental training over your career, are there any
additional trainings you have participated in, apart
from continuing education or legal trainings you
mentioned?
A. Well, I need to maintain continuing medical
education in order to maintain my licensure as a
physician, surgeon in the State of Illinois. That's
a requirement.
In addition to that, I'm also required to
maintain a certain number of credits in order to
maintain my board certification in forensics
psychiatry, the maintenance of certification, so
there are various requirements for a physician no
matter what specialty to sort of maintain both the
medical licensure and board certification above the
medical licensure part of it, so I'm required to
maintain that.
Q. Apart from board certification and
continuing education, is there any other training you
have participated in?
A. I have attended conferences convened by the

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American Academy of Psychiatry and the Law, the
American Academy of Forensics Sciences and so forth
which are held in various parts of the country, the
annual conferences or midwest chapter, so there are
various seminars and conferences I have attended over
the years as part of my training, ongoing training.
Q. I would like to go through your employment
history since you finished at Mt. Sinai.
Did you start working with Cook County
directly after completing your time at Mt. Sinai?
A. Yes.
Q. That was in 1987 did you say?
A. July of '86.
Q. What was your first role at Cook County?
A. I'm sorry. I didn't hear you.
Q. What was the title of your first position
that you started in July 1986?
A. I was a full-time staff psychiatrist at the
Psychiatric Institute of Cook County Circuit Court.
Q. Now that institute is called Forensic
Clinical Services at the Circuit Court of Cook
County?
A. Correct.
Q. It's the same otherwise, apart from the

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Q. Which other agencies do you collaborate
with -- does the Department of Forensic Clinical
Services collaborate with?
A. Forensic Clinical Services is an agency of
the court. It comes directly under the Chief Judge
of the Cook County Circuit Court and interfaces with
a number of agencies both within the court system and
outside the court system, and so there are a number
of agencies.
Q. What are some of those agencies?
A. Agencies within the court system would be
like the adult probation department, social service
department and the juvenile court, although I work in
the adult court, the adult division.
And the other agencies we interface with on
a regular basis would be the Department of Human
Services, previously known as the DMH, now known as
DHS, the corrections, the state's attorney's office,
the public defender's office, and those would be some
of the agencies.
Q. Apart from changes to programs related to
consultation and collaboration with other agencies,
are there any other significant changes in terms of
the scope of the work the unit does from when you

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name change, same unit within the Circuit Court of
Cook County?
MR. HANLON: Objection to the extent it
calls for a legal conclusion.
BY MS. SCHWARTZ:
Q. You can answer if you know.
A. The scope and nature of our services has
essentially remained the same.
Q. You said essentially. Are there any
differences between the scope then in 1986 and the
scope of the forensic clinical services today?
A. Over the last 30 years there has been some
changes in the kind of services that we have
provided, not the nature of the evaluations per se in
terms of fitness or sanity, but the consultation or
the collaborative work that we have done with other
agencies.
Q. What do you mean by "changes in terms of
the consultation and collaborative work with other
agencies"?
A. There were programs or services provided by
the departments which have been modified either
through procedural guidelines or in terms of how they
are being serviced.

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started in 1986 to today?
A. No.
Q. You mentioned that you were a full-time
staff psychiatrist starting in July 1986. When did
you -- how long did you have that role?
A. I had that role for approximately eight
years.
Q. Until around 1994?
A. Correct.
Q. In that role what were your primary
responsibilities?
A. My primary responsibilities as a clinical
forensic psychiatrist was to conduct court-ordered
examinations with respect to defendant's fitness to
stand trial, sanity, and so forth, to provide written
records and recommendations and testify as an expert
witness required or mandated by the court.
Q. What was your position after you were a
full-time staff psychiatrist?
A. I'm sorry. I don't understand your
question.
Q. You testified that you were a full-time
staff psychiatrist until 1994. What was your role in
late 1994 or after?

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A. In 1994 I was appointed as the director of
the agency or the program.
Q. Have you been in that position since 1994?
A. Yes.
Q. To present day?
A. Yes.
Q. You were director of forensic clinical
services at the Circuit Court of Cook County in April
of 2010?
A. Yes.
Q. What are your responsibilities as the
director of forensic clinical services?
A. My responsibilities encompass two areas,
both clinical and administrative.
Clinical, as I explained earlier, to
conduct examinations and to testify as an expert
because primarily I'm a forensics psychiatrist.
Additionally, I'm responsible for the
day-to-day operation of the department and work
closely with the office of the chief judge with
respect to establishing procedures and policies which
meet the expectations of the judiciary in terms of
the services that we provide based on the needs of
the court.

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overall supervision of that staff.
Q. When you say each division, what do you
mean? What is the organizational structure?
A. We have three clinical disciplines of
psychiatry, psychology, social service and then the
administrative and support staff and the clerical, so
the three clinical disciplines and the administrative
division, that would be the organizational structure.
Q. You are director of all three of those
divisions?
A. I'm director of the department, yes.
Q. So you have oversight as director of the
department of all three of those divisions?
A. All the divisions, yes.
Q. Was that the general structure of the
department of forensic clinical services in
April 2010 as well?
A. Yes.
Q. In terms of the staff you supervise, how
many evaluators do you supervise who perform
fitness-to-stand trial evaluations,
fitness-to-represent-one's-self evaluations?
A. The number of clinical staff, that's the
psychiatrist and psychologist responsible for

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I'm responsible for hiring staff,
appropriate physicians, psychologists, social
workers, support staff, staff training and
developments.
My administrative responsibilities also
include working on the budget and maintaining the
budget, working with unions, union negotiations and
other administrative chores, so that is, again, in a
nutshell my responsibilities as the director, both
clinical and administrative, in the day-to-day
operation of forensic clinical services for the
court.
Q. You mentioned you're responsible for hiring
staff of various sorts. Do you also supervise those
staff members as director of -A. Yes.
Q. -- forensic clinical services?
A. Yes, I do.
Q. How many people do you supervise?
A. Well, the number of staff in our department
is approximately 30 right now.
I work closely, directly with the managers
of each division of psychiatry and psychology, social
services, support staff, so I'm responsible for the

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conducting court-ordered examinations, is right now
10.
Q. What was the size of the staff responsible
for conducting court-ordered evaluations in April of
2010?
A. I do not remember.
Q. Would it have been approximately the same
amount, 10 or so?
A. That would be correct.
Q. Do you have any other employment or
volunteer work outside of your role at the Circuit
Court of Cook County?
A. No.
Q. You mentioned you testified as an expert in
civil cases. Was that outside your work at the
Circuit Court of Cook County or was it as part of
your general job description as director of forensic
clinical services?
A. I mentioned I gave depositions in civil
cases, and I have testified as an expert on criminal
cases.
Q. So all of the testimony you mentioned in
which you were an expert, those were all in the
context of criminal cases?

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A. Yes.
Q. Have you ever testified as an expert in a
civil case either at trial or in a deposition?
MR. HANLON: Objection. Just to clarify,
like a retained expert or -BY MS. SCHWARTZ:
Q. Either type of expert, retained,
court-appointed.
A. I do not remember.
Q. Have you ever done any teaching?
A. Yes.
Q. What sort of teaching have you done?
A. I continue to teach. I'm basically a
teacher. I teach my staff, my clinical staff.
I make presentations to various agencies
within the court judiciary, state's attorney's
office, public defender's office.
I also lecture at Kent Law School.
Teaching is a big part of my work.
Q. What's the subject of your lectures at Kent
Law School?
A. The topics generally encompass criminal
issues, such as fitness, insanity defense, Miranda,
landmark cases in forensics.

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and the like.
How often do you perform court-appointed
evaluations?
A. It varies.
Q. How many would you guess you perform in a
given week?
A. It depends.
Q. How many would you guess you perform in a
given month?
A. It's variable.
Q. How many court-appointed examinations did
you perform in the year 2010?
A. I do not remember.
Q. Do you think it was more than -- was it
more than five court-appointed examinations?
A. Yes.
Q. Was it more than 10 examinations?
A. In 2010?
Q. In 2010.
A. Yes.
Q. Was it more than 30 examinations in 2010?
A. Yes.
Q. Was it more than 50 examinations in 2010?
A. I do not remember.

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Q. When you say "landmark cases in forensics,"
what do you mean?
A. Landmark cases which pertain to the core
issues that we deal with as it relates to fitness or
insanity defense.
Q. Do you mean legal cases, court cases?
A. Yes, legal.
Q. You discussed your general training in
forensic psychiatry specifically.
Do you have any more particular area of
expertise within the umbrella of forensic psychiatry?
A. No.
Q. Who was your supervisor in April of 2010?
A. My supervisor is the Chief Judge of Cook
County Circuit Court.
Q. Who was the Chief Judge in 2010, do you
recall?
A. It had to be Honorable Timothy C. Evans.
Q. Is Chief Judge Evans your supervisor today?
A. Yes.
Q. You mentioned that in your capacity as
director of forensic clinical services, you still
perform some of the same functions you did as a staff
psychiatrist, conducting court-appointed evaluations

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Q. Could it have been more than 50
examinations?
A. Yes.
Q. In terms of the balance of your time, what
percentage of the time would you guess you spend
doing administrative functions and what percentage do
you spend doing the clinical functions we discussed?
MR. HANLON: Currently or are you sticking
to 2010 right now?
BY MS. SCHWARTZ:
Q. Let's start with currently.
A. Again, it depends.
Q. If you had to guess in a given year, in the
last year.
A. It's variable, so variable.
Q. Do you have a guess as to what that balance
would have been in 2010?
A. No.
Q. How many evaluations for fitness to stand
trial specifically did you complete in 2010?
A. I do not know.
Q. Would you guess that it was more than 20?
A. Could be, yes.
Q. But you can't recall the exact number?

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A. Correct.
Q. How many evaluations for fitness for a
defendant to represent his or herself did you conduct
in 2010?
A. Just pro se?
Q. For a defendant to go pro se, that's
correct.
A. I do not remember.
Q. Was it more than 10?
A. I don't know.
Q. When the court orders an evaluation of a
defendant, how is that evaluation assigned to a
particular psychiatrist or clinical worker?
A. It's done by a scheduler, full-time
scheduler.
Q. Do you supervise the full-time scheduler?
A. Not directly.
Q. Does the full-time scheduler work within
the Department of Forensic Clinical Services?
A. Yes.
Q. How does the full-time scheduler decide who
is assigned to a particular evaluation?
A. There are a number of factors that go into
scheduling or assigning a particular case.

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whether there's one examiner versus two examiners, so
there are multiple factors which go into
consideration before assigning a particular case.
We also maintain continuity of care. In
other words, if I have seen a patient before and it
comes back on another issue or another charge, unless
I'm not available or away at a conference or
vacation, that case will come back to me so that
someone who is already familiar with the case would
be the logical choice to examine that patient.
So the scheduler uses or utilizes multiple
guidelines in the assignment of an individual or
group of cases.
Q. Let's take a step back. What's the
difference between psychiatry and psychology?
A. Okay. A psychiatrist is a physician
licensed to practice medicine who has specialized in
psychiatry or behavioral sciences.
A psychologist is someone either with a
master's or a doctorate level of training in the
field of psychology, either PhD or a PsyD, and
psychologists are specialized to administer
psychological testing, and it's a different level of
training, and so we have both psychologists and

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Q. What are those factors?
A. The factors are either clinical or related
to the courts. Both psychologists and psychiatrists
are qualified to conduct forensic examinations in the
State of Illinois.
If there's some medical issues that may
impact someone's fitness or sanity, there's a
likelihood that the case will be assigned to a
medical physician, doctor, a psychiatrist.
If there's a need for psychology testing,
for example, if someone's IQ is in question or if
there's a personality issue which requires
personality inventory or testing, then obviously a
psychologist would be involved.
The bigger cases or the major cases, like
murder or Class X felonies would as far as possible
be seen by both psychology and psychiatry, and if
there's an issue of psychotropic medication, then
there's an expectation that those cases are seen by a
physician or a psychiatrist.
Also, the time factor in terms of the
turnaround time with respect to the next court date
set by the court, not by us, so we try and meet that
deadline, so if that is also a factor in terms of

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psychiatrists so that -- so we use a
multi-disciplinary approach in providing our services
to the court.
Q. Is it true that generally speaking a
psychiatrist would have more years of training in
total?
A. It depends.
Q. You mentioned that there are 10 clinicians
who perform court-appointed evaluations. How many of
those are psychiatrists versus psychologists?
A. Right now it's five psychiatrists and five
psychologists.
Q. Was that the breakdown in April of 2010?
A. I don't remember.
Q. Would it have been roughly that same
breakdown in April of 2010?
A. I don't know.
Q. Do you have any control over which
court-appointed evaluations you perform yourself?
A. No.
Q. You would not be able to request a
particular evaluation to perform as director of
clinical forensic services?
A. No.

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Q. Do you conduct -- strike that.
Are the types of evaluations you perform
the same types of evaluations that the other
clinicians in your unit perform?
A. Yes.
Q. Are you ever assigned more advanced issues
or more complex cases given your role as director?
A. Only if the court makes such a request.
Q. What kind of cases would the court make
such a request?
MR. HANLON: Objection, foundation.
BY MS. SCHWARTZ:
Q. You can answer if you know.
A. It's up to the court.
Q. In your experience there have been
particular cases where the court has requested that
you as opposed to one of your staff clinicians
perform an evaluation?
A. In a few select cases, yes.
Q. Do you recall what the charges were on
those cases?
A. No.
Q. Do you recall what the medical issues or
psychiatric issues were in those particular cases?

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A. Depending on our opinions. If a defendant
has been found unfit, then we are likely to be an
expert for the defense.
If a defendant has been found legally
insane, then we are likely to, again, be asked by the
defense to testify.
And if the finding was one of sanity, then
we are more likely to be an expert for the witness,
so we testify for both sides depending on our
opinion, and we work for the court, not for the
state, not for the defense.
Q. In instances where you testify for the
state, for instance, would a particular prosecutor
contact you to request your testimony at a trial?
A. It is our practice to prepare for testimony
and there's often a conference, a pre-testimony
conference before we take the stand. That's not
unusual.
And we do that both with the defense and
the state depending on our opinion and who we are
testifying for.
Q. How would you or a clinician in your office
learn that you are being asked to testify?
A. Because a requesting attorney would contact

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A. No.
Q. If the court requested that you perform the
evaluation, would that be reflected in the court's
order directing an examination?
A. Yes. Every examination is conducted
pursuant to a court order. If the court has
specifically asked for my examination, that would be
in the court order.
Q. As director, is it unusual for you to
perform evaluations?
A. No.
Q. Dr. Markos, you testified regarding your
interactions with other agencies. Do you work with
the Cook County State's Attorney's office?
A. I'm not clear about your question.
Q. In your role as director of forensic
clinical services, do you interact with individuals
from the Cook County State's Attorney's office?
A. In my work I interact with both the state's
attorney's office and the public defender's office.
When it comes to testimonies, I and my
staff, we testify for both sides.
Q. When you say you testify for both sides,
what do you mean?

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our office and schedule the testimony and, in many
occasions, a conference before the testimony itself
in preparation for trial.
Q. Are those requests made over the phone, by
letter, by fax?
A. It depends. It could be a phone call. It
could be a subpoena. It could be in writing.
Communication is made, again, with the
scheduler for the department who schedules both
examinations and testimonies, not the clinicians
themselves.
Q. What is the name of the scheduler, the
full-time scheduler?
A. Back in 2010?
Q. Back in 2010.
A. I do not remember.
Q. Who is the full-time scheduler today?
A. We have more than one scheduler, and one of
the schedulers is -- her name is Elana Tapia,
T-A-P-I-A, Sherry Ford, Ms. Terry.
We have more than one scheduler, so there's
a backup in case the primary scheduler is off or not
available, so...
Q. Apart from testifying for either the state

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or the public defender that you mentioned, does your
office have any other interactions with the state's
attorney's office?
A. The state's attorney's office does
represent the department in other legal actions such
as this.
Q. Does your office have any other
interactions with the state's attorney's office?
A. No.
Q. Does your office have interactions with the
Cook County Sheriff's office?
A. The sheriff's office provides security
during our examinations and, as such, is present on
site during the examinations outside the examining
rooms. Other than that, there's no interactions.
Q. Is someone from the Cook County Sheriff's
office present for every single evaluation?
A. Yes.
Q. So there's no -- it's not just evaluations
where there's a particular concern over safety?
A. We do not conduct any examination unless
security is available and a sheriff's deputy, male
and female, are available since we examine both
female and male defendants, and these examinations

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Attorney's office ever ask your unit to conduct
evaluations of defendants?
A. No.
Q. It would only be the court that would order
such an evaluation?
A. Yes.
Q. Do employees of the Cook County State's
Attorney's office ever ask you to ask particular
questions during court-appointed -- court-ordered
evaluations?
A. No.
Q. Do employees of the Cook County State's
Attorney's office ever ask you to help identify
whether an individual is dangerous or a threat?
A. No.
Q. Do employees of the Cook County Sheriff's
office ever ask you to conduct evaluations?
A. No.
Q. Do employees of the Cook County Sheriff's
office ever ask you to ask particular questions of a
criminal defendant during an evaluation?
A. No.
Q. Are the clinicians in your office part of
law enforcement?

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are conducted in specific examining rooms in our
department.
And the sheriff's personnel are present
directly outside the examining room and are
responsible for transporting the defendants back and
forth from Cook County jail, so the sheriff's
deputies, both male and female, are present on site
during examinations.
Q. Is that true even if the person who is
being examined is not in Cook County custody at the
time of the examination?
A. Correct. It applies to all examinations,
including bond cases, EMP cases, cases that come from
the Department of Human Services or any other source.
Q. By EMP, do you mean the electronic
monitoring program?
A. That's correct.
Q. Are the people from the Cook County
Sheriff's office who provide security during the
evaluations, what unit within the Cook County
Sheriff's office do they come from?
A. I do not know.
Q. Does the Cook County State's Attorney's
office or any employees of the Cook County State's

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A. No.
Q. Have you spoken or communicated with anyone
about this lawsuit apart from your attorney?
A. No.
Q. I want to ask you a few questions about the
other parties in this case.
Do you know who Robert Podlasek is?
A. No.
Q. Have you ever met Robert Podlasek?
A. No.
Q. Never spoken to Mr. Podlasek about this
lawsuit?
A. No.
Q. You have never spoken to Mr. Podlasek about
Annabel Melongo?
A. No.
Q. Have you had any written communications
with Mr. Podlasek?
A. No.
Q. Do you know who Julie Gunnigle is?
A. No.
Q. Have you ever spoken to Julie Gunnigle?
A. No.
Q. Have you ever exchanged written

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communications with Julie Gunnigle?
A. No.
Q. Do you know who Kate Garcia or Kate O'Hara
is?
A. No.
Q. Never spoken to Kate Garcia, also known as
Kate O'Hara?
A. No.
MR. HANLON: Let her finish the question.
BY MS. SCHWARTZ:
Q. Do you know who Antonio Rubino is?
A. No.
Q. Never spoken to Antonio Rubino?
A. No.
Q. Do you know who Richard Lesiak is?
A. No.
Q. You have never spoken to Richard Lesiak?
A. No.
Q. Do you know who Sergeant Dillon is?
A. No.
Q. You have never spoken to Sergeant Dillon?
A. No.
Q. Do you know who Randy Roberts is?
A. No.

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communications with Carol Spizzirri?
A. No.
Q. Do you know who Annabel Melongo is?
A. I don't know her.
Q. Do you know who she is though?
A. Based off my records, I examined
Ms. Melongo back in 2010.
Q. Do you remember meeting Ms. Melongo in
2010?
A. No.
Q. Your recollection is based solely on your
records?
A. I do not recall Ms. Melongo. I reviewed my
report prior to this deposition.
Q. Do you recall what Ms. Melongo's criminal
cases were about?
A. I know based on the review of my report
what the case was about.
Q. What do you know about her criminal case or
cases?
A. Based on my review of my report, I do know
that I examined her back in 2010 pursuant to court
order on a charge of computer tampering.
Q. Do you know of any other criminal charges

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Q. You have never spoken to Randy Roberts?
A. No.
Q. Never exchanged written communications with
Randy Roberts?
A. No.
Q. Do you know who William Martin is?
A. No.
Q. Have you ever spoken to William Martin?
A. No.
Q. Have you ever exchanged written
communications with William Martin?
A. No.
Q. Do you know who Kyle French is?
A. No.
Q. You've never spoken to Kyle French?
A. No.
Q. Never exchanged written communications with
Kyle French?
A. No.
Q. Do you know who Carol Spizzirri is?
A. No.
Q. You have never spoken to Carol Spizzirri?
A. No.
Q. You have never exchanged written

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that were brought against Ms. Melongo?
A. No.
Q. Do you know the details of the computer
tampering allegations against Ms. Melongo?
A. No.
Q. How did you first hear about Ms. Melongo?
A. The court issued an order asking our
department to conduct a forensics examination with
respect to her fitness to stand trial and pro se
fitness.
Q. And that was the first you heard about
Annabel Melongo?
A. Yes.
Q. When did you become aware that Ms. Melongo
had filed a lawsuit against you?
A. I don't remember.
MS. SCHWARTZ: I'm going to hand the court
reporter what's going to be marked as Exhibit No. 1.
(Markos Exhibit No. 1 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit No. 1?
A. No, I don't.
Q. Do you see the stamp at the bottom of the

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first page of Exhibit No. 1?
A. Yes.
Q. It's Bates number Markos 0001.
A. Yes.
Q. What is that stamp?
MR. HANLON: You are asking about the Bates
stamp?
MS. SCHWARTZ: I'm sorry. The stamp with a
date in the middle -MR. HANLON: Okay.
BY MS. SCHWARTZ:
Q. It says June 25, 2014.
A. That's a forensics clinical services stamp
indicating that it was received by the department on
that date.
Q. Did you receive this document after it was
received by the department?
A. I do not remember this document.
MS. SCHWARTZ: I'm handing the court
reporter what will be marked as Markos No. 2.
(Markos Exhibit No. 2 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Markos Deposition

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A. I do not remember.
Q. You didn't file an answer in this civil
lawsuit until July of 2017; is that correct?
A. Yes. I don't remember when the response
was prepared.
Q. Why did it take so long for you to file an
answer in this lawsuit?
MR. HANLON: Objection.
BY MS. SCHWARTZ:
Q. Why did it take three years from the time
this civil summons was served on your offices to file
an answer in this case?
MR. HANLON: Objection to the extent it
calls for a legal conclusion. Objection to the
extent it assumes the service was effective.
You can answer.
THE WITNESS: I don't know.
BY MS. SCHWARTZ:
Q. Dr. Markos, you haven't objected to the
service of summons in this case; is that right?
MR. HANLON: Objection to the extent it
calls for a legal conclusion.
BY MS. SCHWARTZ:
Q. You can answer.

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Exhibit 2?
A. No, I don't.
Q. If you turn to the third page of
Exhibit No. 2, do you recognize this proof of service
page?
A. I see the proof of service page, yes.
Q. Does it reflect that this summons was
received by someone in the Department of Forensic
Clinical Services?
A. Yes.
Q. Who was that?
A. This document indicates that this proof of
service was received by Ms. Elena, E-L-E-N-A, Tapia,
T-A-P-I-A, an employee of the Department of Forensic
Clinical Services.
Q. Did you ever receive a copy of this
document?
A. I do not remember.
Q. Did you become aware Ms. Melongo had named
you as a defendant in a civil suit in 2014?
A. I do not remember the date or the year when
I was named in the lawsuit.
Q. Did you discover that you were named in the
lawsuit in 2014, some time in 2014?

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A. I don't believe I have understood your
question.
Q. Have you in this litigation challenged the
validity of the service of the summons in this civil
litigation?
MR. HANLON: Objection to the extent it
calls for a legal conclusion.
THE WITNESS: I have no response.
MS. SCHWARTZ: Let's take a five-minute
break.
(A recess was had.)
BY MS. SCHWARTZ:
Q. I'd like to direct your attention to
April 13, 2010. Do you recall conducting an
evaluation on Annabel Melongo on that date?
A. No.
Q. But you mentioned you reviewed her case
file which reflected that you had conducted an
evaluation of Annabel Melongo on that date?
A. Yes.
Q. Based on that case report, did it refresh
your recollection that an evaluation had happened
with Ms. Melongo on that date?
A. Yes.

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Q. What time did the evaluation begin?
A. I do not remember.
Q. How long did the evaluation last?
A. I do not remember.
Q. How were you first notified of the
assignment to evaluate Ms. Melongo?
A. It was put on my schedule.
Q. Who put the evaluation of Ms. Melongo on
your schedule?
A. The scheduler at that time.
Q. So you did not have any control over being
assigned to Ms. Melongo's evaluation?
A. That's correct.
Q. It was the scheduler who made the decision
that you were to evaluate Ms. Melongo?
A. The scheduler makes the decision to assign
cases to all staff.
Q. I'm handing to the court reporter to be
handed to you what we're going to mark as Markos
Deposition 3.
(Markos Exhibit No. 3 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit No. 3?

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THE WITNESS: I do not know.
BY MS. SCHWARTZ:
Q. Generally when a court orders an
examination of a defendant for fitness to stand
trial, what is the process by which your unit
receives those orders?
A. There are a number of ways in which the
court order is delivered to the Department of
forensic Clinical Services, but on certain occasions
attorneys drop these court orders in the department
itself. They physically bring it to the department.
In other situations it's put into interoffice mail.
If it's a referral that's come from one of
the outlying districts, then it is both faxed to the
department and/or sent via currier or coordinator for
interoffice mail, so there's a number of ways in
which a court order may get to the Department of
Forensic Clinical Services from the court itself.
Q. Can you tell by looking at Exhibit 3 which
way this was delivered to forensic clinical services?
A. No.
Q. Did you speak to anyone about this court
order?
MR. HANLON: Ever?

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A. Yes.
Q. What is Exhibit No. 3?
A. Exhibit No. 3 is a consolidated referral
order from Cook County Circuit Court issued by Judge
Brosnahan ordering forensic clinical services to
conduct an examination with respect to Ms. Annabel
Melongo's fitness to stand trial and also fitness to
represent herself dated March 3, 2010.
Q. Is Exhibit 3 a true and correct copy of the
referral order that you received to conduct an
evaluation of Ms. Melongo?
A. Yes.
Q. Who prepared this order marked as
Exhibit No. 3?
A. I do not know.
Q. Does the stamp in the top right-hand corner
that says forensic clinical services, March 3,
central intake unit, does that reflect that it was
received by your unit?
A. Yes.
Q. How did your unit receive this order marked
as Exhibit 3?
MR. HANLON: Objection, foundation.
You can answer if you know.

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BY MS. SCHWARTZ:
Q. In March or April of 2010, did you speak to
anyone about this court order?
A. I discussed the court order with the
defendant during the examination, Ms. Melongo
herself, to advise her that my examination was
pursuant to a court order, so I did discuss based on
my report with Ms. Melongo.
That's as far as I remember based on my
report.
Q. Apart from Ms. Melongo, did you speak to
anyone else in March or April of 2010 about this
court order?
A. I don't remember.
Q. You don't recall talking to any prosecutor
who was working on the case about the court order?
A. As mentioned earlier, I have not had
discussions with the state's attorney in the case.
Q. Why was Ms. Melongo ordered by the court to
submit to an examination?
MR. HANLON: Objection, form and
foundation.
BY MS. SCHWARTZ:
Q. You can answer.

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A. I just don't know.
Q. You don't know the reason the evaluation
was ordered?
A. No.
Q. I'm handing you what will be marked Markos
Deposition Exhibit No. 4.
(Markos Exhibit No. 4 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Deposition Exhibit No. 4,
which I should note has Bates number that begins with
CCSAO 004641 and ends with Bates number CCSAO 004661.
A. No, I don't.
Q. I'll represent to you this is the
transcript of the hearing in which Ms. Melongo was
ordered to submit to a court-appointed evaluation.
Have you seen this transcript before today?
A. I don't remember.
Q. Do you ever review transcripts of court
proceedings in which a court-appointed evaluation is
ordered before conducting an evaluation?
A. If court transcripts are provided to me
prior to an examination, then as part of an
examination, I'll review the transcripts submitted by

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I'm fully aware what it means.
BY MS. SCHWARTZ:
Q. So if the judge in Ms. Melongo's case said
she was ordering a BCX, what does that mean to you?
A. If a judge were to use that term, which I
have not often heard -- it's usually attorneys and
outside agencies -- I would take that to mean that a
case has been referred to our department for a
forensic evaluation.
Q. Would the same be true if an attorney used
that term, a prosecutor or a defense attorney?
A. Yes.
Q. Generally speaking, what is the purpose of
a consolidated referral order such as the one we see
in Exhibit No. 3?
A. Well, the consolidated order is a document
utilized by a judicial officer to order a
court-ordered examination by our department.
Q. Turning again to Exhibit No. 3, the
consolidated referral order, which is Bates marked
Markos 0025 to 0026, can you tell from looking at the
order what is the purpose of this particular referral
referenced in Exhibit No. 3?
A. The purpose of this order issued by a judge

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the court as it relates to the specific issue of
fitness or sanity.
Q. If it's not listed in your report as
something you reviewed, does that mean you did not
review the court transcript?
A. That's correct.
Q. What does BCX stand for?
A. BCX is a historical acronym for behavioral
clinic examination.
Since the department many decades ago was
known as the Behavioral Clinic of Cook County Circuit
Court and from that name evolved the procedure of
BCX-ing case, which essentially means a case has been
referred for an examination by the behavioral clinic
for a forensic evaluation, so it's a historical term
which is still in use.
Q. And today or in April of 2010 or March of
2010, it was used to refer to a court-appointed -court-ordered examination?
MR. HANLON: Objection, foundation.
You can answer if you can.
THE WITNESS: It's a terminology that is
used by personnel outside the department.
It is not a term that I personally use, but

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was for the Department of Forensic Clinical Services
to examine Ms. Melongo, Annabel Melongo, for the
purpose of determining if she was fit to stand trial
and if she was fit to represent herself.
Q. What does a fitness-to-stand-trial
evaluation involve?
A. A fitness-to-stand-trial examination
essentially involves two parts. The first part is a
review of pertinent records available from court, and
the second part is a clinical examination, the
purpose of which is to determine if the defendant has
a mental illness and, B, if that person is competent
to stand trial, if that person meets the statutory
criteria for fitness to stand to trial in the State
of Illinois.
Q. In the first part you mentioned reviewing
records.
What is the reason for reviewing records in
advance of a fitness-to-stand-trial evaluation?
A. The first step in a forensic evaluation,
after advising the defendant of the nonconfidential
nature of the report, is to determine what the person
is being examined for and on what charge.
Therefore, it is important for a forensic

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examiner or evaluator to know what the formal
complaint is as part of the fitness evaluation.
Q. Is it important to get a general
understanding of the factual allegations underlying
the criminal charges?
A. It is important to know what the charge is.
Q. Why is it important? What's the relevance
of the specific charge?
A. Because it's important to determine if the
defendant is cognizant of the charge pending against
him or her, therefore, a formal complaint needs to be
available to the examiner to corroborate the charge
with the defendant.
Q. Are there any other records that are
pertinent to a fitness-to-stand-trial evaluation that
you would review in advance?
A. It depends.
Q. You mentioned the statutory criteria for
fitness to stand trial. What makes someone fit or
unfit to stand trial?
A. The State of Illinois, fitness criteria are
clearly articulated in the statutes, that's 725 ILCS
5/104-13, which requires that a defendant be
cognizant or aware of the charge, the nature and

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extremely variable.
Q. Are they generally less than an hour, more
than an hour?
A. It depends.
Q. How do you determine if someone is
cognizant of the charges against them?
A. It's based on a direct examination,
clinical examination where the defendant is actually
asked if he or she is aware of the charge pending
against her and what the charge is and what that
means, and so that's done through direct examination.
Q. Is the test whether a defendant can explain
what the charge is, generally can explain the
allegations, is that the question?
A. Yes, and also if the defendant understands
if it's a felony or misdemeanor, what's the
difference, if they can make a distinction between a
misdemeanor and a felony as part of the fitness
evaluation.
Q. In terms of whether the defendant
understands the nature of the court proceedings, what
are you looking for in that part of the analysis?
A. In order to determine that specific issue,
whether the defendant has a comprehension of the

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purpose of the court proceedings and that the
defendant has the ability or capacity to assist
counsel in a rational manner, and the Illinois
statute comports with the Dusky standard.
Q. I'm sorry. What standard?
A. Dusky, D-U-S-K-Y.
Q. How long does a fitness-to-stand-trial
evaluation generally take?
A. Depends.
Q. What's a general range in your estimate for
a fitness-to-stand-trial evaluation?
A. It depends on the extent of the record
review or the records, depending on -- again,
depending on the charge, it may be extensive. In
some cases there may be DVDs available to the
examiner.
And it depends on the mental condition, the
clinical issues related to any individual client,
recipient or patient or defendant, so there are
multiple factors which would determine sort of the
length of the examination, if additional testing is
required to unveil a diagnosis that may not be
clinically apparent through psychological testing, so
the length or duration of a clinical evaluation is

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court proceedings, there are certain questions that
are standardized, which includes, but is not limited
to, questions such as the role of a judge, role of a
public defender or defense attorney in the case, the
role of a prosecutor, the difference between a jury
and a bench trial, the number of people in a jury and
the role of a jury, the meaning of the term plea
bargain, the definition of the term evidence and
examples of evidence, to see if the person
understands who a witness is and what a witness can
do in court.
That's generally the sort of criteria
utilized in determining if the person has a
reasonable understanding of the court proceedings in
order to be competent to stand trial.
Q. How do you determine if someone has a
capacity to assist counsel in defense?
A. That's a very important component of any
fitness examination, and the main underlying factor
would be if there's a mental illness or defect which
would preclude a person from being able to assist
counsel in a rational manner. That's an important
part of the evaluation.
Q. Are there standards or rules that govern

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the way you conduct these evaluations, medical
regulations or industry practices, anything like
that?
A. All forensic issues are legally determined
and defined, whether it be fitness, insanity defense,
and forensic examiners are required to comport with
the legal definitions, whether it be fitness or any
other issue, and that's part of the training.
In terms of the clinical style or the
clinical presentation, different examiners employ
different methods or styles.
There are specialized tests which can be
utilized in certain situations to determine fitness,
but it's basically a clinical interview where the
essential fitness criteria would need to be
determined one way or the other.
It's up to an examiner to decide what
exactly that approach is going to be, so yes, the
forensic organizations, the premiere medical,
psychiatric organizations have established both
professional and ethical guidelines with respect to
fitness, amongst other forensic issues.
Q. Turning to the fitness to represent one's
self, what does an evaluation for fitness to

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Edwards, concluded that there's no separate criteria,
and the American Psychiatric Association and the
American Academy of Psychiatry and the Law has
adopted that legal criteria, so it is essentially the
same criteria.
Q. In other words, there's no difference
between the two criterion?
A. Unless there's a mental illness, and then
it would -- the examiner would need to determine if
the mental illness would preclude that person from
representing himself without the assistance of
counsel or co-counsel.
Q. So are there types of mental illness where
you could be fit to stand, but not fit to represent
yourself?
A. Exactly.
Q. What types of mental illnesses are those?
A. It depends.
Q. I'm going to hand you what will be marked
as Markos Deposition Exhibit No. 5.
(Markos Exhibit No. 5 marked for
identification.)
BY MS. SCHWARTZ:
Q. It is Bates numbered Markos 0027. Do you

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represent yourself entail?
A. A fitness to represent one's self or pro se
essentially entails the same criteria, and the
Forensic Academy has established that the criteria is
no different, especially with respect to the
existence of a mental illness.
And the purpose of a pro se evaluation
would be to see, again, if a person is cognizant of
the charge, understands the nature of the court
proceedings and if there's any mental illness which
would preclude that person from representing himself
or herself in court.
Q. So the type of things you are looking at
overlap a fitness-to-stand-trial evaluation and a
fitness-to-represent-one's-self evaluation?
A. I'm sorry. I didn't understand your
question.
Q. The types of questions you ask overlap with
respect to a fitness-to-stand-trial evaluation and a
fitness-to-proceed-pro-se evaluation?
A. Essentially the same, yes.
Q. Are there any differences?
A. The legal criteria established by a
landmark U.S. Supreme Court case, Indiana versus

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recognize Exhibit No. 5?
A. I know what this document says, yes.
Q. What is Exhibit 5?
A. This document is an appointment letter sent
to Ms. Annabel Melongo dated March 24, 2010,
indicating to Ms. Melongo that the court had ordered
an examination.
This letter also indicates that the
examination was scheduled for April 13, 2010, at
10:30 a.m. and some procedural guidelines in terms of
reporting to the department and any information that
would be helpful in terms of keeping this
appointment.
Q. Is this a document that is generated by
someone within the Department of Forensic Clinical
Services?
A. This department (sic) would be generated by
the clerical section or the intake section of the
department, yes.
Q. Is it a true and accurate copy of the
appointment for court-ordered examination sent to
Ms. Melongo?
A. I have no reason to believe it isn't.
Q. Does your staff automatically generate

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reports such as Exhibit No. 5 when there's a
court-ordered examination?
MR. HANLON: You mean letters, not report?
MS. SCHWARTZ: Letters.
THE WITNESS: Yes. An appointment letter
is mailed out to a defendant, whether they are out on
bond or, if they are in custody, then the appointment
letter is sent to the Cook County Jail to the
sheriff's department to arrange transportation for a
very specific appointment date for the examination.
BY MS. SCHWARTZ:
Q. That role is performed by someone within
the intake unit -A. Yes.
Q. -- in your office?
Someone in the intake unit prepares this
letter in the course of their regular business?
A. This document is prepared in the
clerical/intake division of the department, yes.
Q. That's one of the general job duties of the
clerical staff within the intake unit, to take care
of it?
A. Yes.
Q. On Exhibit No. 5 it says, if you are taking

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or requested examination, the police reports to
confirm the complaint or the charge and any
additional documents I may have had at that time.
Q. Do you recall what those additional
documents were?
A. After reviewing my forensics report
psychiatric report, I had reviewed an article
captioned Chicago Court, if my memory serves me, and
so that was a document that was available to me at
the time of the examination, and I had reviewed that
as part of my examination or prior to the
examination.
Q. Do you know who wrote that article that you
reviewed called Chicago Court?
A. No.
Q. Do you recall who gave you that article
entitled Chicago Court?
A. No.
Q. Did you review any information about
Ms. Melongo's medical history before her examination?
A. Sorry. Could you please repeat.
Q. Did you review any information about
Ms. Melongo's medical history before you examined her
on April 13, 2010?

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any medications, contact forensic clinical services
at (773) 869-6100 before your appointment date.
Do you know if Ms. Melongo contacted
forensic clinical services before her appointment
date regarding any medications she was taking?
A. No.
Q. If she had contacted forensics clinical
services about medications she was taking, would that
be reflected in your final report?
A. Intake would make a note of that. I'm not
sure it would be necessarily reflected in my report.
I would report a medication if the patient
is prescribed certain psychotropic medications, but
in terms of having called in to confirm, I would have
no knowledge of that.
Q. You have no knowledge if Ms. Melongo called
in to report any medications before her examination?
A. Correct.
Q. Did you review any documents before
Ms. Melongo's evaluation on April 13, 2010?
A. Yes.
Q. What did you review?
A. I reviewed, first of all, the court order
to see what the desired examination was in this case,

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A. No.
Q. Did you review any other documents in
advance of Ms. Melongo's examination?
A. I do not remember.
Q. I'm going to hand you what will be marked
as Markos Deposition Exhibit No. 6.
(Markos Exhibit No. 6 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit 6?
A. I know what this document is.
Q. What is Exhibit 6?
A. This is a document prepared by forensic
clinical services which is essentially a chronology
of events from the issuance of a court order with
some biographic information regarding Annabel
Melongo, the charges at that time and the state's
attorney in the case and documents received by the
department, especially police reports, the dates of
my examination, the caseworker on the case from the
intake unit, judge on the case, so it's essentially a
summary of the referral process itself, the name of
the defendant, the charge, the judge, the state's
attorney on the case and the name of the examiner, in

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this case, myself, the date of the examination with
the diagnosis and the chronology of events from the
issuance of the date, so that's what it is.
Q. Who prepared this report, Exhibit 6?
A. I do not know who prepared this, but this
is prepared in the intake division of the Cook County
Jail as part of the case management before it gets to
the examiner, and then they follow through with the
events. It's a tracking system.
Q. It's part of the intake unit's
responsibilities to maintain documents like
Exhibit 6?
A. And the individual responsibility of the
case manager or case manager assigned to the case.
Q. Who is the individual case manager assigned
for this particular document, Exhibit No. 6?
A. Based on the information contained in this
document, it was Ms. Hensch, H-E-N-S-C-H, Dolores
Hensch, who worked in the department at that time.
Q. Does she no longer work in the department?
A. She no longer works in the department.
Q. What are the case manager's
responsibilities?
A. Essentially a case manager is responsible

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examiner, is actually physically procured by the
caseworker internally within the department and is
ready for submittal to the court and a copy is also
maintained in the case file, as in this case.
Q. Is it the duty of the case manager, in this
case Ms. Hensch, to accurately reflect the chronology
on a document like Exhibit No. 6?
A. Yes.
Q. Robert Podalsek's name is listed at the
bottom of the first page, which is Bates number
Markos 0028. What does that mean?
A. It means that Ms. Hensch at that time
obtained this information, the name of the state's
attorney, from the court order and incorporated that
in our information file.
Q. Did Ms. Hensch or anyone else in clinical
forensic services speak to Mr. Podlasek about
Ms. Melongo's evaluation?
MR. HANLON: Objection, foundation.
You can answer if you know.
THE WITNESS: I don't know.
BY MS. SCHWARTZ:
Q. If you turn to the next page, Markos 0029,
at the top it says police reports received. Who

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for preparing the case file and processing the case,
entering information and getting it ready for the
scheduler.
After having made sure that there is a
court order and required documents, the case manager
would be responsible for bringing or sending the case
to scheduling for scheduling purposes, and the case
manager's task doesn't end there.
After the case is scheduled and examined by
a forensic expert and a typed report is completed,
then the case manager, who tracks the case, is
responsible for the case all along in the assembly
line, essentially is responsible for garnishing the
reports and ensuring that information is entered into
the tracking system and documents all relevant data
and completes the file and then gets ready to submit
the written report to the respective court.
These are some of the essential functions
of a caseworker. It is not comprehensive because I
don't know all the details.
Q. When you say "garnishing the report," what
did you mean by that?
A. By garnishing I meant ensuring that the
report, which is being either dictated or typed by an

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sends the police reports to your unit for your review
before an evaluation?
MR. HANLON: Objection, foundation.
You can answer if you know.
THE WITNESS: Usually the referring party.
BY MS. SCHWARTZ:
Q. When you say "the referring party," what do
you mean?
A. The attorney who has requested the court or
has brought the court order, which may not always be
the requesting attorney, and may decide to drop off
the court order, because we work in the same building
and brings the police reports, along with the court
order or sometimes separately.
In this case I notice that it was the same
day that the police reports were received by the
department as the court order.
Q. What does that mean, that it was the same
date?
A. Yes.
Q. Could you tell who dropped off the police
reports in this case?
A. No.
Q. As a general matter, would someone in your

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office generally speak to the assistant state's
attorney assigned to a criminal case prior to an
evaluation?
MR. HANLON: Objection, foundation.
You can answer if you know.
THE WITNESS: It is the practice of our
clinicians in forensic clinical services to not
communicate with the referring attorneys, whether
they be prosecutors or defense attorneys, public
defenders or private defense attorneys prior to an
examination or prior to submittal of an opinion
letter to the court.
A judge who issued the order is the first
one to find out our opinions, and prior to that we do
not discuss with the referring attorney or any
attorney in the case.
Q. What's the reason for that practice?
A. The reason for that practice has to do with
our unique role as independent examiners for the
court.
We are not retained by the defense or the
state. We do not work for the state or the defense.
We work for the judiciary of the circuit court.
We respond to a court order and our

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dangerous behavior to self or others is based on a
clinical examination, a direct examination.
As part of the examination, I would rely on
police reports or any other collateral information.
However, the firm decision of propensity
for dangerous behavior to self or others needs to be
determined directly through a clinical examination.
Q. So the police reports are collateral
documents, provide some information, but those would
not be the sole means of determining whether someone
is dangerous for purposes of evaluation?
A. In certain situations police reports may
provide a suggestion or may be suggestive of violent
or potentially dangerous behavior.
It is possible it's something that's taken
into account or is a consideration, but it's not
always the case.
Q. Do you recall if anything in the police
reports you received related to Ms. Melongo's case or
the charging documents you received showed any
propensity towards violence?
A. No.
Q. You don't recall or they did not show any
propensity towards violence?

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examinations are independent, objective, and a
judicial officer who issued the court order is the
first one to get the report, which is either hand
delivered or via currier or faxed to the judge's
chambers.
Q. Did you or anyone in your office speak to
Ms. Melongo prior to her evaluation on
April 13, 2010?
A. I did not speak with her prior to the
examination.
Q. Did anyone within your office speak to her
prior to the examination?
MR. HANLON: Objection, foundation.
BY MS. SCHWARTZ:
Q. You can answer if you know.
A. I do not remember.
Q. Before Ms. Melongo's evaluation, did you
have any reason to think she was dangerous?
A. Before any examination there's no way of
predicting if someone is dangerous or otherwise.
Q. Can you glean some information from the
police reports you review, for instance, to determine
if someone is dangerous?
A. The clinical determination of potential for

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A. Based on the recent review of my report,
there's nothing to suggest that I had information
which would indicate that she was dangerous to
herself or others.
Q. Turning again to the page of Exhibit 6
marked Markos 0029, what does referral received mean
at the top of the page?
A. It means that the court order was received
on that date.
The referral refers to court documents, the
court order and that it was received on this date.
Q. What do the entries dated April 13, 2010,
refer to?
A. There are two entries dated April 13. The
first one indicates that Ms. Hensch had confirmed
Ms. Melongo's appointment for April 13 at 10:30 a.m.,
and the second notation which indicates that an
appointment had been scheduled with myself on that
date.
I stand corrected, that an examination took
place on the 13th by myself, that I examined the
patient on April 13.
Q. Below that entry it says, no mental
disorder, personality disorder NOS, mentally fit to

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stand trial.
What does that mean?
A. That is my opinion based on my examination
of Ms. Melongo. I did not diagnose her with any
mental disorder.
It was my clinical formulation within a
reasonable degree of medical and psychiatry certainty
that Ms. Melongo did not suffer from any mental
disorder.
I also provisionally considered personality
disorder NOS, which is not otherwise specified, a
provisional diagnosis and answered the bottom line
issue of fitness, which was that she was mentally fit
to stand trial.
Q. When you say provisional diagnosis, what
does that mean?
A. A provisional diagnosis is a clinical
suspicion during an examination which would need to
be corroborated with additional observation in
clinical practice if needed, and it's a clinical
impression or the initial impression of an examiner
based on data, clinical data garnished during the
evaluation.
Q. To make a final diagnosis instead of a

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A. Yes. A dictation involves dictating the
entire summary verbally on a recording device, which
may or may not be digital, and the device captures
the dictation, which is then played back by the
typist or transcriptionist, who would then type the
report, so I don't type my own reports.
I just dictate the summary, and it's
transcribed for me.
Q. The transcriber in this case, Ms. Arroyo,
transcribes word for word what you would have -- what
you said in your dictation?
A. Exactly.
Q. Do you keep those recordings or your
dictations?
A. No.
Q. Why not?
A. Once a dictation has been transcribed, the
transcriptionist would erase the dictation to make
room for more dictations while the summary is
preserved, so there's really no need to save the
original dictation itself because it's already been
transcribed and completed for my review, and once I
sign off on that, that summary is maintained on file
as the actual summary that was dictated.

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provisional diagnosis, would you need to take
additional steps, do additional testing?
A. If needed, if needed in a treatment
setting.
The purpose of my examination was to
conduct a forensic evaluation regarding fitness, and
based on that examination, I considered it a
provisional diagnosis. It was not a firm diagnosis.
It was a consideration on clinical suspicion.
Q. You didn't think that any follow up was
needed on that issue?
A. Not for the purposes of this examination.
Q. Lower down in the page it says, psychiatric
sum. dictated 4-13-2010, Dr. Markos, L.A.
What does this line mean?
A. This line means that I, the examiner,
dictated my forensic summary or report on the same
date of the examination, and my dictation was
transcribed by Lilly Arroyo, A-R-R-O-Y-O, medical
transcriptionist, typist who worked in the department
at that time, but is no longer in the department.
Q. When you say you dictated your report, do
you make a recording generally? Did you make a
recording in this instance?

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Q. In Ms. Melongo's case, the dictation no
longer exists for her?
A. Or any other case that has been dictated in
the past.
Q. I just want to confirm, the dictation for
Ms. Melongo's case in particular, the April 13, 2010
evaluation, that dictation does not exist any longer?
MR. HANLON: Objection, asked and answered.
You can give the exact same answer.
THE WITNESS: Correct.
BY MS. SCHWARTZ:
Q. Do you also keep notes of your evaluations?
A. It depends.
Q. Did you keep notes of Ms. Melongo's
evaluation?
A. I don't remember.
Q. If you did keep notes of Ms. Melongo's
evaluation, would it have been in the case file that
you reviewed?
A. No.
Q. Where would those notes be located?
A. Handwritten notes are maintained by
individual examiners for a certain period of time,
and it's generally my practice not to maintain them

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once it's been dictated and the information from my
handwritten notes has been incorporated in my
summary, so that's my practice.
I cannot speak for all clinicians.
Q. Did you review your files to see if you
have any handwritten notes related to Ms. Melongo's
evaluation?
A. Prior to this deposition I did review my
file and I have not maintained my handwritten notes
from approximately 10 years ago.
Q. Continuing on Markos Exhibit No. 6, page
Markos 0029, the entry psychiatric summary or sum.
transcribed, 4-19-2010, what does that mean?
A. That means that the dictation that was
captured on my Dictaphone was transcribed by
Ms. Arroyo on the 19th of April of 2010.
Q. What does court report typed below that
mean?
A. It means that she prepared the final
summary and opinion report on Ms. Melongo's case
authored by myself.
Q. That happened six days after the
evaluation?
A. Yes.

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BY MS. SCHWARTZ:
Q. What does clerical note dated 4-20-2010
mean?
A. This entry means that Ms. Hensch, who is
the caseworker on the case from start to finish, was
made aware of my report, and Ms. Arroyo conveyed the
completion of the case, the information to Ms.
Hensch, who is the caseworker and, as I mentioned
earlier, would be responsible for managing the case
from start to finish made an entry on the 20th
indicating that the case had been completed by the
examiner assigned to this case, namely myself.
That's the clerical entry made by
Ms. Hensch who is still the case manager on the case.
Q. I'm going to hand you what is marked as
Exhibit 7.
(Markos Exhibit No. 7 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit 7?
A. Again, based on my review of this case
file, this document from Schiller Park Police was
part of our records, yes.
Q. Did you review it prior to evaluation of

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Q. Were you consulted during Ms. Arroyo's
write up of your dictation?
A. It's the practice of the transcriptionist
to prepare a summary and make it available to the
examiner who dictated it for review and corrections
as needed in every case, not just my case, but for
all examiners.
Q. Did you review Ms. Arroyo's transcription
in Ms. Melongo's case?
A. I signed off on it, which means I did
review it, yes.
Q. Did you have any corrections?
A. I don't remember.
Q. Does Ms. Arroyo maintain a separate file
related to Ms. Melongo's evaluation?
MR. HANLON: Objection, form, foundation.
THE WITNESS: I'm not clear about your
question, separate file.
BY MS. SCHWARTZ:
Q. Do you know if Ms. Arroyo maintains
separate records related to evaluations?
MR. HANLON: Same objections.
THE WITNESS: I don't know.

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Ms. Melongo?
A. Yes.
Q. What were the allegations against
Ms. Melongo reflected in this police report?
A. Computer tampering.
Q. Did you also review the charging documents
in this case prior to your evaluation?
A. I don't remember.
Q. I'm handing you what will be marked as
Markos Deposition Exhibit 8.
MR. HANLON: Is that his report?
MS. SCHWARTZ: Yes.
MR. HANLON: Wondering, is this a good time
for lunch?
MS. SCHWARTZ: That's fine with me.
MR. HANLON: Do you have a guesstimate on
total time?
MS. SCHWARTZ: I'm thinking maybe an hour
after.
(Whereupon, the deposition in
the above-entitled cause was
recessed to 1:39 p.m. this
date.)

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AFTERNOON SESSION
EXAMINATION (Resumed)
(Markos Exhibit No. 8 marked for
identification.)
BY MS. SCHWARTZ:
Q. We are back on the record.
Dr. Markos, I'd like to turn your attention
back to what's been marked as Markos Deposition
Exhibit 8, Bates number Markos 0030 to Markos 0033.
Do you recognize Exhibit 8?
A. Yes.
Q. What is Exhibit 8?
A. This is my forensic psychiatric report
authored by myself dated April 13, 2010.
Q. Is that your signature on the last page of
Exhibit 8?
A. Yes, it is.
Q. This is a true and accurate copy of the
report you completed on Ms. Melongo's evaluation?
A. Yes.
Q. And you reviewed the contents of this
report before signing it?
A. Yes.
Q. Does Exhibit No. 8 accurately reflect your

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BY MS. SCHWARTZ:
Q. Dr. Markos, do you recognize Exhibit No. 9?
A. Yes.
Q. What is Exhibit No. 9?
A. This is a document captioned Chicago
Courthouse, which reportedly was posted on a website
www.illinoiscorruption.net/chicagohtml.
Q. Is this the document that you reviewed
prior to your examination of Ms. Melongo?
A. Yes.
Q. On the first page of Exhibit 9, on the
bottom left is a stamp that says director's office,
dated 3-8-2010.
Is that the date your office received this
particular document?
A. Yes.
Q. If you flip through Exhibit No. 9, there's
underlined notations throughout handwritten into the
document. Whose annotations are those, the
handwritten annotations?
A. I do not remember.
Q. If you turn to page 7, which is also Bates
number Markos 0051, there's a handwritten word
"victim" in the middle of the page at the top.

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diagnosis and analysis of Ms. Melongo on
April 13, 2010?
A. Yes.
Q. I would like to go through the report with
you.
On the first page, Bates number 0030,
there's a section titled records reviewed?
A. Yes.
Q. Does this accurately list the records
reviewed before the examination of Ms. Melongo?
A. Yes.
Q. Did you review anything else other than
what's listed in records reviewed for the evaluation
of Ms. Melongo?
A. No.
Q. You mentioned that you reviewed a website
titled www.illinoiscorruption.net?
A. That was a document which came to the case,
yes.
Q. I'm going to hand you what will be marked
as Markos Deposition Exhibit No. 9.
(Markos Exhibit No. 9 marked for
identification.)

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Do you know whose handwriting that is?
A. That is my handwriting.
Q. Does that help you remember whose
annotations are contained here in this document,
Exhibit No. 9?
A. This is a note that I made for my own
personal reference as it relates to Ms. Annabel's
actions in this case.
Q. Are the other annotations throughout this
document, the underlines and written notes in
margins, are those also your annotations?
A. I do not recall that.
Q. Did you review any other part of
Ms. Melongo's website other than this document prior
to her examination?
A. No.
Q. Did you discuss this document, Exhibit
No. 9, with anyone prior to Ms. Melongo's
examination?
A. No.
Q. Who delivered this document to you prior to
Ms. Melongo's examination?
A. I do not recall.
Q. If you turn to page 17 of Exhibit 9, which

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is Markos 0061, at the bottom is underlined a
sentence related to eavesdropping, the Illinois
eavesdropping statute.
Did you know that the state was
investigating potential eavesdropping charges of
Ms. Melongo at the time you did the -A. No.
Q. I would like to turn back to Exhibit 8,
which is your psychiatric summary. On the first page
under the heading clinical interview, it says, the
purpose of the examination and the nonconfidential
nature of the report was explained to her, and she
understood this advisory.
What does that sentence mean?
A. What that means is that prior to getting
into the examination, I advised Ms. Melongo that the
purpose was to determine or give a clinical opinion
on a fitness to stand trial, that the examination was
pursuant to a court order and that the information
that I obtained during my examination would be
contained in the report which would be submitted to
the court and in that respect was not confidential
information.
Q. When you were evaluating Ms. Melongo, did

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question.
BY MS. SCHWARTZ:
Q. I can clarify.
Did you have a duty to treat Ms. Melongo in
the event that you thought she needed medical
treatment?
MR. HANLON: Objection, same objection.
You can answer.
THE WITNESS: As I mentioned earlier, there
was no therapeutic relationship or physician-patient
therapeutic relationship in this case.
The purpose of my examination, which was
ordered by the court, was to conduct a forensic
examination, and there was no treatment
responsibilities on my part.
BY MS. SCHWARTZ:
Q. Did you have any responsibilities to act in
Ms. Melongo's best interests in conducting your
evaluation?
MR. HANLON: Same objection.
You can answer.
THE WITNESS: I was an impartial examiner
for the court.

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you consider her to be your patient?
A. I explained to her that there was no
patient-therapist relationship, which is why it was
not confidential.
Q. When you were evaluating Ms. Melongo, you
weren't -- the purpose of the evaluation was not to
propose any treatment, if necessary, was it?
A. Well, it depends. If the finding was one
of unfitness, then I would be required to make a
treatment recommendation to the court in terms of
inpatient versus outpatient treatment which would be
the least restrictive and most therapeutic, but that
was not the case.
Q. It wasn't the case because you found her to
be fit?
A. It was my clinical opinion with a
reasonable degree of medical and psychiatric
certainty that she was mentally fit to stand trial.
Q. Did you have any obligation to Ms. Melongo
when you evaluated her?
MR. HANLON: Objection to the extent it
calls for a legal conclusion.
You can answer.
THE WITNESS: I'm not clear about your

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BY MS. SCHWARTZ:
Q. But you did not view Ms. Melongo as your
patient?
MR. HANLON: Asked and answered.
THE WITNESS: She was not my patient.
BY MS. SCHWARTZ:
Q. Unlike a doctor who sees a patient
generally, you had no obligation to keep the contents
of your conversation with Ms. Melongo confidential;
is that right?
MR. HANLON: Objection, mischaracterizes
prior testimony and asked and answered.
THE WITNESS: At the very outset I
explained to Ms. Melongo that this examination was
ordered by the court and that it was not
confidential.
BY MS. SCHWARTZ:
Q. Are evaluations like Exhibit 8 generally
filed with the court under seal?
A. The reports are hand delivered in a sealed
envelope. I don't know if that constitutes being
legally sealed.
Q. Do they become part of the public court
file of the individual defendant?

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A. Yes.
Q. Turning back to Exhibit No. 8, the first
page, in the middle of the page, it says under the
heading clinical interview, it says, the defendant
informed this examiner at the very outset that she is
no longer representing herself (pro se) and has
retained a private attorney, i.e., Mr. Nick Albukerk.
What did she say about her decision to hire
a private -- retain a private attorney during the
evaluation?
A. She spontaneously informed me that she was
no longer pro se and that she had retained a private
attorney, a statement that she made and that was
that.
Q. How did that affect your evaluation of
Ms. Melongo?
A. Part of the examination had to do with the
pro se fitness per court order, and if she was no
longer pro se, it was my responsibility to inform the
court, as I did in my opinion letter, that she was
fit to stand trial and that she had reported to me
that she was no longer pro se and that she had
retained a private attorney, so I duly informed the
court of her statement or information that she

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division at that time, so that's information that she
provided to me just contained in my report.
Q. I want to turn your attention to the last
sentence of that paragraph from Exhibit 8. This
document reflects strong paranoid, grandiose and
narcissistic personality traits in the defendant.
What did you base this statement on?
A. This statement was based on my clinical
impression or suspicion that Ms. Melongo had these
characterological traits or tendencies with some
ideas of paranoia, entitlement, and I took that into
consideration when making my provisional diagnosis
later of personality disorder not otherwise
specified, which is NOS, as I mentioned earlier.
Q. Was this conclusion based on your review of
the document entitled Chicago Courthouse or your
evaluation with Ms. Melongo personally or a
combination of the two?
A. A combination of the two.
Q. Let's walk through each of those. What
about Ms. Melongo or the website you reviewed
reflected strong paranoid traits?
A. The information contained in that report in
conjunction with my clinical observations supported

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provided me, and that was the extent of that issue.
Q. Did she say anything else about her
retention of a private attorney?
A. No.
Q. Lower down on the page in the next
paragraph, you write, a document entitled Chicago
Courthouse posted on www.illinoiscorruption.net
website indicates a long and convoluted legal
process, et cetera, et cetera.
What does this refer to, this sentence?
A. This sentence and this paragraph refers to
an account the defendant provided me and based on
collateral information that her case had a long
history in terms of moving from one judge to another,
and so I synopsized that in this paragraph,
information that I garnished from her.
Q. What was the account that the defendant
provided to you during the evaluation?
A. Essentially what's contained in the
paragraph, that she had representation earlier by two
private attorneys named in this report, James Flood
and Darryl Goldberg, and that she had gone before
many judges, several judges with respect to her case,
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my clinical suspicion that Ms. Melongo was
experiencing or experienced paranoid ideas and a
sense of entitlement, and that was a clinical
impression based on the whole picture and not just
one segment.
Q. What in particular about your clinical
observations led you to conclude that she was
exhibiting paranoid traits?
A. In the section I reported her account of
how she had moved from court to court and her
explanation as to why she had to seek other judges
and meet with the chief judge or the presiding judge
of the criminal division in support of her case.
Q. What about that suggests that she exhibited
paranoid traits?
A. Again, it was a clinical impression that
she had concerns about the -- an unusual concern as
compared to other cases with respect to receiving
justice.
Q. What was unusual about it?
A. It's unusual to see a case go through
several judges in my experience.
Q. What is the definition of having a paranoid
personality trait?

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A. Paranoia in general is defined as a
subjective feeling which may be observed by a trained
examiner where an individual feels conspired against
or not being treated fairly or overreading into the
situations where they may feel victimized.
They have been a victim of injustice or
maltreatment, and so it's a broad, general kind of
psychological phenomenon.
Q. Is it paranoid for a defendant to be upset
about criminal charges that he or she did not
actually commit?
MR. HANLON: Objection, form, foundation.
THE WITNESS: I don't know. I do not have
the details or the information to come to a
conclusion with a reasonable degree of certainty on
that issue.
Her general demeanor and her account and
her subjective feelings conveyed to me paranoid
themes, which was my provisional diagnosis, and that
was my impression at that time.
BY MS. SCHWARTZ:
Q. If Ms. Melongo were correct that she was
being charged with crimes that she did not commit,
would that be paranoia?

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Q. What about her demeanor gave you the
impression that she was experiencing feelings of
grandiosity?
A. The demeanor with which she expressed these
very ideas, which was summarized in my report, which
is going from one judge to the next and then SOJ-ing
the case, taking it to another, and she conveyed
feelings of being a very special person and, again,
it's a clinical impression.
Q. SOJ stands for substitution of judge?
A. Yes.
Q. Let's turn to the next one, narcissistic.
What's the definition of narcissistic personality
trait?
A. Narcissism is a pathological trait where
it's very similar to grandiosity where an individual
feels or likes to feel that he or she is the center
of attention, is very important.
It's a feeling of self importance and
wanting to be heard again and again.
And narcissistic people tend to be
self-centered, so these three characteristic traits
are lumped together in psychiatric diagnosis in the
personality disorder section as cluster B, and that

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MR. HANLON: Objection, form, foundation,
incomplete hypothetical, misstates facts.
You can answer.
THE WITNESS: I have no opinion on that.
BY MS. SCHWARTZ:
Q. Turning to the next one, grandiose. What
does it mean to have grandiose traits?
A. Grandiose essentially means being someone
very special and having an exaggerated notion about
themselves, especially in terms of how they are
treated by other people.
Q. What about your clinical observations in
review of Ms. Melongo's website made you determine
that she had grandiose personality traits?
MR. HANLON: Objection, mischaracterizes
prior testimony.
THE WITNESS: That was my clinical
impression, and that was based on, again, her
demeanor and details of information that she provided
to me in terms of seeking a different judge each time
and asking to meet with the chief judge to hear her
case.
I formed a clinical impression that she was
experiencing feelings of grandiosity.

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is because there's an overlap and they are very
similar, grandiosity and narcissistic people, so
narcissistic people are likely to be grandiose and
grandiose people are likely to be narcissistic or
paranoid for that matter, so cluster B, which, again,
is a personality disorder.
It is not a mental illness, such as
depression or bipolar or schizophrenia. It's a
characterological issue where the individual with
these traits are likely to perceive the world very
differently from someone who does not have this
issue.
Q. When you say "characterological," what does
that mean?
A. The word characterological and personality
is essentially synonymous from a clinical standpoint,
so personality is the characterological makeup of an
individual.
Q. In terms of narcissistic traits, were there
any additional aspects of Ms. Melongo's demeanor or
aspects of documents you reviewed that gave you the
impression that she may have narcissistic personality
traits apart from what you testified?
MR. HANLON: Objection, excludes other

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aspects he's testified to.
But you can answer.
THE WITNESS: Again, it's in conjunction
with both, and it was not just the contents of what
she told me, but also the form, manner, demeanor in
which she presented her concerns with respect to how
her case was handled both by defense attorneys and
judges, multiple judges in this case.
BY MS. SCHWARTZ:
Q. What about her form and demeanor suggested
or gave the impression of narcissistic personality
traits?
A. As I explained earlier, that this desire on
her part or expectation that she be assigned to
different judges because she was not satisfied.
Q. Was there any other information apart from
what you testified to on which you based your
impression that she may have paranoid, grandiose and
narcissistic personality traits?
A. No.
Q. Turning to the next page marked Markos
0031, how did you decide what to include in the
section called pertinent background information?
A. Pertinent background information is the

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examination, you concluded that, "There was no
evidence of any anxiety, agitation, depression,
mania, looseness of association, incoherence,
tangentiality, delusions, hallucinations or cognitive
deficits."
How did you reach that conclusion?
A. During a mental state examination or
psychiatric examination per se, an examiner would ask
specific questions in order to rule out the presence
or absence of any specific psychiatric symptoms
before arriving at a formulation and diagnosis.
Questions that are meant to identify the
person's degree of alertness, orientation to time,
place or person, in other words, does the person know
what the date is, the time, the day of the week and
so forth. Questions that are meant to identify
underlying depression or disordered thought process,
like delusions, which are irrational beliefs, any
racing thoughts, any abnormal perceptual disorders,
like hallucinations or illusions and the general
cognitive or intellectual functioning of that person
based on their vocabulary, fount of knowledge and
general information, so, again, these are standard
elements of a psychiatric evaluation.

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section of a clinical report which pertains to an
individual's pertinent background information, where
they were born, the education that they received,
employment history, past criminal history, past
psychiatric history, substance abuse history,
medication history, history of any reported
psychiatric treatment, inpatient versus outpatient
services, so it is the background of the person that
is based on self-reporting in most instances and is
an important part of the examination in terms of
understanding the person's life before moving on to
the psychiatric evaluation, the mental status
examination and the core fitness issue.
So it is trying to understand a person's
background and anything that may be relevant and is a
very standard part of a clinical psychiatric report
or psychological report for that matter.
Q. What is the relevance of the statement that
she was born in Cameroon, Africa and immigrated to
the United States?
A. Again, that's pertinent background
information. That is addressed in each and every
case. It's not unique to this case.
Q. In the next section entitled mental state

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Q. And in this instance, in Ms. Melongo's case
you did not find any evidence of any of those mental
illnesses?
A. Based on my examination of Ms. Melongo in
April 13, 2010, to a reasonable degree of medical and
psychiatric certainty, that she did not present,
manifest or complain of any specific psychiatric
symptoms or signs.
Q. At the beginning of that paragraph on
Markos 0031, Exhibit 8, you wrote, "Ms. Melongo
presented as calm and cooperative," et cetera, et
cetera.
Is that an accurate description of how
Ms. Melongo presented?
A. Yes.
Q. In the next section of Exhibit 8 titled
fitness evaluation, Markos 0031, spanning over to
Markos 0032, what was your conclusion regarding
Ms. Melongo's fitness to stand trial?
A. Ms. Melongo's responses during this part of
the evaluation indicated that she was cognizant of
the charge pending against her. She made a proper
distinction between a misdemeanor and a felony. She
demonstrated satisfactory understanding of court

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proceedings, including the roles of various courtroom
officials, judge, state's attorney, defense attorney
and so forth, understood the meaning of the word
guilty or not guilty, evidence, defined a witness,
and also very importantly showed the capacity to
assist counsel in a rational manner, so those were my
conclusions after this section or segment of the
evaluation.
Q. Are those the standard questions you ask
when you are trying to determine whether a defendant
is fit to stand trial?
A. Generally, yes.
Q. By asking those questions, you reached the
conclusion that Ms. Melongo was fit to stand trial?
A. I reached my conclusion based on my
clinical and psychiatric evaluation and her knowledge
of the fitness, statutory criteria for fitness.
Q. Did you reach a determination of whether
she was fit to represent herself pro se?
A. Ms. Melongo indicated to me that she was no
longer pro se, that she was represented by a private
attorney, Mr. Nick Albukerk, and that she was no
longer pro se.
Q. For that reason did you not list a

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emphysema and so forth.
But the DSM-V, which is the current edition
in use, has done away from the multi-axial system,
but back in 2010 when the DSM-IV-TR was in prevalent
use, Axis I and Axis II referred to two separate
diagnostic categories, so that's essentially what it
is.
Q. And you testified regarding the personality
disorder NOS prior to lunch.
To confirm, NOS, that stands for not
otherwise specified?
A. That's correct.
Q. Is this the provisional diagnosis that you
referred to in your testimony before lunch?
A. Yes.
Q. And does this relate to your conclusion
that we just discussed, that you had impressions that
Ms. Melongo had strong paranoid, grandiose and
narcissistic personality traits?
A. Yes. I formed the opinion that she had
personality traits which led me to make a diagnosis
of not otherwise specified because I did not have
sufficient clinical data to support a full-blown
personality disorder, so it was a consideration. I

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conclusion regarding whether she was fit to proceed
pro se?
A. Given that information, I reported to Judge
Brosnahan that she was no longer pro se.
I did address the issue of fitness and
indicated that she was fit to stand trial and she was
not mentally ill.
Q. Turning now to the section entitled
diagnosis on Markos 0032, what's the difference
between Axis I and Axis II?
A. The Diagnostic and Statistical Manual of
Mental Disorders, also known as DSM, the current
edition is the fifth edition -- at the time I
examined the patient, it was IV-TR was the edition,
and in psychiatric diagnosis, this is a multi-axial
system, and Axis I is reserved for specific mental
disorders, like depression, bipolar disorder,
schizophrenia, dementia, so forth.
Axis II is reserved for -- used to be
reserved for pathological or personality disorders,
which is also defined in DSM manuals using
standardized criteria for making these diagnosis.
And Axis III would be for medical
conditions, like hypertension, heart disease,

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had not ruled it in. I had not ruled it out, and
that's a provisional diagnosis in medical practice.
Q. Did you think the general impression that
Ms. Melongo may have a personality disorder would
affect your ability to -- her fitness to stand trial?
A. Sometimes a personality disorder can
interfere with an individual's level of cooperation
with counsel, and pro se was the consideration in
this case, and in my experience, personality
disorders, if it exists, could impact someone's
capacity to cooperate, and in that respect it could
have a bearing, but that was not the conclusion in
this case.
I opined to the court that she was mentally
fit.
Q. At the bottom of Markos 0032, you again
mention Ms. Melongo informed you that she had
retained a private attorney.
Is it your testimony that she told you that
spontaneously, or did you specifically ask her
whether she had a private attorney?
A. As I mentioned earlier and as represented
on page 1, at the very outset after I advised her of
the non-confidentiality, she spontaneously informed

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me or advised me that she was no longer representing
herself and that she had retained an attorney, so in
that respect, it was in the very beginning that she
spontaneously reported to me. I did not ask her.
Q. I would like to turn your attention back to
what I have in front of you as Markos Deposition
Exhibit 9. If you would turn to the second to the
last page, marked Markos 0072. The final two
sentences at the bottom of page that are underlined,
did you review those last two sentences prior to your
evaluation of Ms. Melongo?
A. I do not recall.
Q. During your evaluation of Ms. Melongo, did
she explain to you what she meant by the statement on
this page, "this surprise will be known on
April 14, 2010"?
A. Based on review of my report, that is not
an issue that was discussed or referenced during my
examination.
Q. If you had discussed that issue during your
examination, would it have been reflected in your
report?
A. It could have.
Q. But not necessarily?

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A. Not that I can recall.
Q. The statement at the bottom of Exhibit 9,
at the bottom of Markos 0072, "Annabel has a big
surprise in store for the court in its attempt to
push her out of the case by pretending she is
psychologically unbalanced," did you think that
statement was potentially a threat to anyone?
A. I don't recall studying these comments.
Q. You don't recall anything about this
statement on Ms. Melongo's website reflected in
Exhibit 9?
A. That's correct.
Q. I'd like to turn briefly back to Exhibit 8,
your report. At the very end, Markos 0033, the first
full sentence says, "Please refer to my full
psychiatric summary for the bases of my opinion."
Is there a separate psychiatric summary
other than this document, Exhibit 8?
A. No. The report that is sent to the court
is the last segment of the summary, the forensic
formulation, because that's what required by the
Court.
A detailed summary remains in our court
file, and the summary is released only pursuant to a

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A. If from the clinical perspective I found it
to be relevant to my examination, I would have
certainly incorporated that.
Q. So your clinical report you include
information that you think could be clinically
relevant?
A. And legally.
Q. Or legally relevant.
If you determined that particular
information is not clinically or legally relevant,
you may or may not include it in that particular
report?
MR. HANLON: Objection, incomplete
hypothetical, form.
You can answer if you can.
THE WITNESS: It depends.
BY MS. SCHWARTZ:
Q. Did anyone tell you that Ms. Melongo had a
history of making threats before you examined her on
April 13, 2010?
A. Not that I can recall.
Q. Did anyone tell you that Ms. Melongo had
any history of violence before you examined her on
April 13, 2010?

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court order or a subpoena and informed consent, so
the letter would indicate that -- a letter to the
court would indicate that there was a detailed
summary if they need it.
Q. I would like to turn to what we are going
to mark as Exhibit 10.
(Markos Exhibit No. 10 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit 10?
A. Yes.
Q. Is this the letter to the court that you
were referring to?
A. Yes.
Q. So this is the portion of your conclusion
that gets filed with the court and becomes part of
the record?
A. Yes.
Q. Is this Exhibit No. 10 a true and correct
copy of the letter you sent to Judge Brosnahan
regarding your evaluation of Ms. Melongo?
A. Yes.
Q. Did you sign the letter at the bottom?
A. Yes, I did.

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Q. You sent this letter to Judge Brosnahan,
but not the full report that we were discussing,
which is Exhibit No. 8?
A. That's the procedure established by the
judiciary, yes.
Q. There's no reason to think that in this
instance the full report that was Exhibit No. 8 went
to Judge Brosnahan?
A. I'm sorry. Can you please repeat your
question?
Q. Do you know if the document marked as
Exhibit 8, your forensic clinical services
psychiatric summary, do you know if that document was
sent to Judge Brosnahan?
A. I don't know. I don't know.
Q. Do you know if it was sent to Ms. Melongo?
A. Reports are submitted to the court and both
parties get a copy.
Q. The full report is submitted to the court
and both parties get a copy?
A. No, just the letter.
Q. Just the letter, Exhibit 10?
A. Just the letter. Either party or side can
request the detailed summary with a court order or a

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interviewed Ms. Melongo?
A. No examination is conducted without
security, and in that regard, there would be
sheriff's deputies assigned to the department seated
outside the examination room, so in that respect,
there would be sheriff's officers assigned to the
forensic clinical services department for that
purpose.
Q. Do you recall who those particular officers
were in Ms. Melongo's case?
A. No.
Q. I'm handing you what will be marked as
Markos Deposition 11, which is Melongo_022914 through
22916.
(Markos Exhibit No. 11 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit 11?
A. No, I don't.
Q. Have you seen or read Exhibit 11 before
today?
A. I don't recall reading this document.
Q. If you don't mind, would you please take a
moment to read the first four paragraphs of

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subpoena.
Q. Do you recall if either party requested a
detailed summary in this case?
A. I do not know.
Q. What happened after you sent this letter
marked as Exhibit No. 10 to Judge Brosnahan?
A. Nothing.
Q. Was the case closed in your office?
A. Yes.
Q. Was there any additional follow up you were
asked to do?
A. No.
Q. Did you ever testify in one of
Ms. Melongo's criminal cases?
A. Not to the best of my knowledge.
Q. At some point during your evaluation of
Ms. Melongo on April 13, 2010, was your evaluation
interrupted by anyone?
A. I do not remember.
Q. Do you recall if Ms. Melongo was taken into
custody during or after your evaluation of her?
A. No.
Q. Do you recall if there were sheriff's
officers outside of the evaluation room when you

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Exhibit No. 11 on the first page.
A. Yes.
Q. Are those first four paragraphs an accurate
description of what happened on April 13, 2010?
A. I have no idea. I don't recall this.
Q. Is anything that you read in those four
paragraphs inaccurate?
MR. HANLON: You want him to go sentence by
sentence?
BY MS. SCHWARTZ:
Q. If anything jumps out that you can identify
as being incorrect.
MR. HANLON: Beyond what he's already
testified to?
You can answer.
THE WITNESS: Beyond what I have already
testified, I don't recall the details provided in
this document in terms of its accuracy or lack of it.
BY MS. SCHWARTZ:
Q. Is it possible that police officers knocked
on the door during your evaluation of Ms. Melongo and
spoke to you for five to ten minutes?
A. I do not recall that.
Q. Have police or sheriff's officers ever

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interrupted an evaluation of a defendant while it was
ongoing?
A. I have been in practice more than 30 years
for the court and conducted many examinations, and
there have been occasions when my examination or
evaluation has been interrupted, sometimes by my
staff to give me a report, message, different judge
is on the line, wants to talk to me, if there's a
fire evacuation drill in process or if a patient who
is not being examined, but is being examined by
someone else has a medical emergency, like a seizure
disorder. There are some scenarios where I could be
interrupted during an examination by sheriff's
deputies, my staff, another doctor perhaps, and so
that is entirely possible, but I do not recall this
interruption as recorded in this document.
Q. Have sheriff's officers or police officers
ever interrupted an evaluation to discuss the
particular defendant whom you were evaluating?
A. Not at the time of the examination.
If a defendant who is scheduled to be
examined is agitated, disruptive or dangerous, and
the sheriff's officers who would normally transport
them from Cook County Jail would give me a head's up

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typically as seriously mentally ill or psychotic,
schizophrenic patient, who is unlikely to be
cooperative, who might become belligerent or agitated
during the evaluation, and that information is
provided to me before, not during or after.
BY MS. SCHWARTZ:
Q. Is the reason to protect your safety during
the evaluation?
A. If it's a security risk, then that would be
the reason, to give me an advanced warning, yes.
Q. Is there any other reason that information
would be conveyed to you before an evaluation?
A. That would be the only instance where a
sheriff's deputy whose primary task is to provide
security for myself and my staff doing examinations
would consult before an examination, not during.
Q. Does information a sheriff's officer gives
you before an evaluation ever influence the types of
questions you ask of a defendant?
MR. HANLON: Objection, form, incomplete
hypothetical.
THE WITNESS: The scope of the examination
does not change.
BY MS. SCHWARTZ:

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in terms of that being -- a defendant being difficult
or likely to be a problem, but that takes place
before I engage in a discussion with the patient.
Q. In that instance, if the sheriffs knew some
information about a potential security issue or
safety issue, you do want to get that information so
you can develop your questions accordingly?
MR. HANLON: Objection, form.
BY MS. SCHWARTZ:
Q. Strike that.
If a sheriff's officer or deputy gives you
information about potential safety or dangerousness
of a defendant, does that influence the way you
conduct the evaluation?
MR. HANLON: Same objection, also
incomplete hypothetical.
You can answer.
THE WITNESS: My previous remark regarding
getting a head's up from a sheriff's deputy relates
to an individual who may be too disturbed to be
examined by myself and who could potentially pose a
risk to myself during the examination.
In those instances, I would get a full
warning, if you will, about that disturbed patient

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Q. Do your questions ever change?
MR. HANLON: Same objections.
THE WITNESS: In clinical practice, there
are several steps with respect to how an exam -- an
individual is examined in terms of forming a rapport
and getting the cooperation, so the manner or the
order in which questions are asked or the clinical
interview process unfolds is very variable, so it
doesn't change the purpose of my examination, which
is to provide an impartial, objective, neutral
opinion to the court with respect to a diagnosis or a
fitness for that matter, so it doesn't change, as I
mentioned, the scope or purpose of my examination.
The approach may vary from a male to female
recipient depending on the mental condition and the
presentation, but the overall purpose is to conduct
an impartial court-appointed examination not working
for the state or the defense.
BY MS. SCHWARTZ:
Q. You testified that you don't recall
Ms. Melongo being arrested during or after her
evaluation on April 13, 2010?
MR. HANLON: Asked and answered.
You can answer it again.

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THE WITNESS: No.
BY MS. SCHWARTZ:
Q. Were you involved in the arrest of
Ms. Melongo on April 13, 2010?
MR. HANLON: I'm sorry?
BY MS. SCHWARTZ:
Q. Were you involved in the arrest of
Ms. Melongo on April 13, 2010?
MR. HANLON: Objection, foundation.
THE WITNESS: I'm not a police officer or
an investigator. I'm a medical doctor, therefore, I
do not arrest or get involved in arresting any
individual.
BY MS. SCHWARTZ:
Q. Turning back to Exhibit No. 11, if you turn
to the final page marked Melongo_022916, can you read
the first two paragraphs of that page.
A. Yes.
Q. Did you ask Ms. Melongo about who owned the
website www.illinoiscorruption.net during your
evaluation?
A. I do not remember asking this question.
Q. Did you ask her about the statement on the
March 3, 2010 posting on her website that "Annabel

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transpired after the examination on that date.
Q. You have no recollection of the arrest of
Ms. Melongo on April 13, 2010?
MR. HANLON: Objection, asked and answered,
at least twice. Same objections as to the first two
times asked.
You can answer it again.
THE WITNESS: Again, as I mentioned before,
I have no memory for that event.
BY MS. SCHWARTZ:
Q. Okay. I'm going to hand you what will be
marked as Markos Deposition Exhibit No. 12. It's
Bates number Melongo_003414.
(Markos Exhibit No. 12 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize Exhibit 12?
A. No, I don't.
Q. You don't recall receiving this report or
seeing this report before today?
A. I do not remember.
Q. I'm going to hand you what will be marked
as Exhibit 13, which is Melongo_003415 through 3417.

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has a big surprise in store for the court in its
attempt to push her out of the case by pretending she
is psychologically unbalanced"?
MR. HANLON: Objection. Asked and
answered.
You can answer.
THE WITNESS: As I mentioned earlier, I
have no recollection of having asked her that
question.
BY MS. SCHWARTZ:
Q. After you finished the evaluation of
Ms. Melongo on April 13, 2010, what did you do?
MR. HANLON: Other than what he testified
to already in terms of sending the letter to the
court?
BY MS. SCHWARTZ:
Q. Apart from sending the letter on -- let me
rephrase.
On April 13, 2010, after you completed the
examination, what happened next? Did you go outside
the office with Ms. Melongo? Did you see her off?
Do you recall what happened immediately following the
examination?
A. I don't have memory for what exactly

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(Markos Exhibit No. 13 marked for
identification.)
BY MS. SCHWARTZ:
Q. Do you recognize this report?
A. No.
Q. You don't recall ever receiving or reading
this report, Exhibit 13?
A. No, I don't.
Q. Did you ever learn that Ms. Melongo was
arrested for threatening a public official on
April 13, 2010?
A. No, I'm not aware.
Q. Did you ever learn that Ms. Melongo was
arrested for eavesdropping at any point?
A. No.
Q. Exhibit No. 13 lists a number of personnel
with the sheriff's office. We discussed earlier
Investigator Rubino, Investigator Lesiak and Sergeant
James Dillon is also mentioned.
Do you recall any interactions with -- I'll
go one by one -- Investigator Rubino?
MR. HANLON: Asked and answered, objection.
THE WITNESS: No.

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BY MS. SCHWARTZ:
Q. Investigator Lesiak?
MR. HANLON: Same objection.
THE WITNESS: No.
BY MS. SCHWARTZ:
Q. Sergeant Dillon?
MR. HANLON: Same objection.
THE WITNESS: No.
BY MS. SCHWARTZ:
Q. Other than this lawsuit in which we are
deposing you today, when did your involvement with
Ms. Melongo or her case end?
A. When I completed my written report and
findings to the court was my last involvement with
the case. I had no further involvement directly or
indirectly.
Q. No involvement with any of the prosecutors
or officers involved in Ms. Melongo's criminal cases?
A. None.
Q. Have you seen any news or media reports
about Ms. Melongo's criminal cases?
A. No.
Q. Did you ever hear what happened to
Ms. Melongo's computer tampering charges after the

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to this case, that's my only memory of Ms. Melongo
and Save a Life Foundation Corporation.
Q. Are you currently a defendant in any other
case, civil cases I should say?
A. No.
Q. Apart from what you testified today, do you
have any other recollection of your interaction with
Ms. Melongo on April 13, 2010?
A. No.
Q. Apart from what you testified to here
today, do have any other recollections of your
interactions with police officers, sheriff's officers
or prosecutors related to Ms. Melongo's on
April 13, 2010?
MR. HANLON: Objection, mischaracterizes
prior testimony, assumes facts not in evidence.
You can answer.
THE WITNESS: No.
BY MS. SCHWARTZ:
Q. You have no further recollection other than
what you have testified to here today?
MR. HANLON: Same objections.
THE WITNESS: Correct.
MR. HANLON: Just to be clear, he hasn't

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April 13, 2010 evaluation?
A. No.
Q. Did you ever hear what happened with any of
the other charges against Ms. Melongo after the
April 13, 2010 evaluation?
A. No.
Q. Have you heard of a former nonprofit
organization called Save a Life Foundation?
A. I have heard of it.
Q. What do you know about the Save a Life
Foundation?
A. Not much.
Q. Do you have any knowledge of the Save a
Life Foundation as it relates to Ms. Melongo's
criminal cases?
A. No.
Q. As it relates to this civil case?
A. After reviewing my report, I realized that
during the course of that examination, Ms. Melongo
had indicated to me, again, based on review of the
report -- I do not recall her telling me that -- but
as mentioned in my report, she reportedly worked for
this organization in some capacity at some point.
I don't have the details, but as it relates

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testified to any recollections, so your question
assumes -MS. SCHWARTZ: I'll rephrase.
MR. HANLON: Okay.
BY MS. SCHWARTZ:
Q. Apart from what you testified today,
Dr. Markos, do you have any recollections of any
interactions with police officers, sheriff's officers
or prosecutors related to Ms. Melongo on
April 13, 2010?
MR. HANLON: Apart from what you already
testified to is the part that's problematic because
he's testified to none, so you are saying other than
what you have already told me, which is nothing.
BY MS. SCHWARTZ:
Q. Apart from your testimony today, which is
that you do not recall speaking to any officers or
prosecutors about Ms. Melongo and her criminal case,
do you have any other recollections of interacting
with prosecutors or officers about Ms. Melongo?
A. I have no other recollections.
MS. SCHWARTZ: If you don't mind, can we
take a five-minute break?
MR. HANLON: Sure.

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(A recess was had.)
MS. SCHWARTZ: I have no further questions.
MR. HANLON: Anybody else have questions?
MS. NINFO: No.
MR. WUNDER: No.
MS. CALLOWAY: No.
MR. HANLON: Very good.
We'll reserve signature.
FURTHER DEPONENT SAITH NOT
(Which were all the proceedings had
or offered at said hearing of the
above-entitled cause at
2:55 p.m.)

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STATE OF ILLINOIS )
) SS:
COUNTY OF COOK
)
I, Renee E. Brass, Certified Shorthand
Reporter of the State of Illinois, CSR No.
084-004119, do hereby certify that said witness was
duly sworn by me to testify the truth; that the said
deposition was taken at the time and place aforesaid;
that the testimony given by said witness was reduced
to writing by means of shorthand and thereafter
transcribed into typewritten form; and that the
foregoing is a true, correct, and complete transcript
of my shorthand notes so taken as aforesaid.
I further certify that there were present
at the taking of the said deposition the persons and
parties as indicated on the appearance page made a
part of this deposition transcript.
I further certify the signature of the
witness to the foregoing deposition was not waived by
agreement of counsel; and that I am not counsel for
nor in any way related to any of the parties to this
suit, nor am I in any way interested in the outcome
thereof.
IN WITNESS WHEREOF, I have hereunto set my
hand this 6th day of February, 2018.

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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

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ANNABEL K. MELONGO,
)
Plaintiff,
)
)
vs.
) Case No.
) 13-cv-04924
ASA ROBERT PODLASEK, et
al.,
)
)
Defendants.
)

)

)

This is to certify that I have read the
transcript of my deposition taken by Renee E. Brass,
C.S.R., on February 20, 2018, and that the foregoing
transcript accurately states the questions asked and
the answers given by me, with the changes made on the
errata sheets, if any, attached hereto.
Number of errata sheets submitted:________
_______________________
MATHEW MARKOS, M.D.

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SUBSCRIBED AND SWORN TO
before me this ______ day
of ___________, 2018.
Notary Public

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Notary Public, Cook County, Illinois
CSR No. 084-004119 - Expiration Date: May 31, 2019

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