Jabbar Muhammad Estate Lawsuit

Andrea Lynn Chasteen
Will County Circuit Clerk

Twelfth Judicial Circuit Court
Electronically Filed
2022LA000681
STATE OF ILLINOIS ) Filed Date: 10/17/2022 12:00 AM
Envelope: 19908449
) SS Clerk: SE
COUNTY OF WILL )
IN THE CIRCUIT COURT OF THE 12TH JUDICIAL CIRCUIT

WILL COUNTY, ILLINOIS
RHONDA WELLS, Independent )

Administrator of the Estate of JABBAR )
MUHAMMAD, deceased, )
)
Plaintiff, )
) 2022LA000681
vs. ) Case No.
)
SILVER OAKS BEHAVIOR, LLC d/b/a )
Silver Oaks Behavior Hospital; )
SOBEREKON MELVIN KOKO, MD; )
MIKE KELLY, in his official capacity as )
Sheriff of Will County, Illinois; and )
COUNTY OF WILL, )
)
Defendants. ) Plaintiff Demands a Jury Trial
COMPLAINT AT LAW
Plaintiff, Rhonda Wells, Independent Administrator of the Estate of Jabbar Muhammad,
deceased, files her original complaint at law:
COMPLAINT AGAINST SILVER OAKS

BEHAVIOR, LLC and SOBEREKON MELVIN KOKO, MD
I. NATURE OF ACTION
1. This is a personal injury action seeking monetary damages on behalf of Plaintiff for
injuries sustained as a result of the acts and/or omissions of the Silver Oaks Behavioral, LLC and
Soberekon Melvin Koko, MD.
02/03/2023 9:00
ROOM: 804
II. PARTIES
A. Plaintiff.
2. Rhonda Wells is the duly-appointed Independent Administrator of the Estate of
Jabbar Muhammad, deceased, having been so appointed by the Circuit Court of the Twelfth
Judicial Circuit (Case No. 2022PR000271) to act in that capacity.
B. Defendants.
3. Silver Oaks Behavioral, LLC is a company that is established in the State of New
York. Silver Oaks Behavioral, LLC operates a 110-bed Acute Mental Illinois (AMI) hospital
named Silver Oaks Behavioral Hospital (1004 Pawlak Parkway, New Lenox, Illinois 60451). The
principal place of business for Silver Oaks Behavioral, LLC is 32 East 57th Street, 17th Floor,
New York, NY 10022. Silver Oaks Behavioral Hospital is a joint venture between Silver Cross
Hospital and Medical Center and US HealthVest.
4. Soberekon Melvin Koko, MD (License No. 036117531) is sued individually and as
an agent/employee of Silver Oaks Behavioral, LLC. Dr. Koko is a board-certified psychiatrist.
III. JURISDICTION
5. The court has jurisdiction over the lawsuit because the lawsuit alleges a justiciable
matter that includes allegations arising under Illinois law. ILL. CONST. 1970, art. VI, § 9.
IV. VENUE
6. Venue is proper in the Circuit Court of the Twelfth Judicial Circuit (Will County,
Illinois) because a substantial part of the events or omissions giving rise to this claim occurred in
this county. 735 ILCS 5/2-101.
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V. VICARIOUS LIABILITY
7. Whenever in this complaint it is alleged that a defendant did any act or thing, it is
meant that the defendant’s agents, officers, servants, borrowed servants, employees or rep-
resentatives did such act or thing and that the time such act or thing was done, it was done with
the full authorization or ratification of defendant or was done in the normal and routine course and
scope of employment of defendant’s officers, agents, servants, borrowed servants, employees or
representatives. The principal is vicariously liable for the acts of the agent because of an employer
employee status, agency by estoppel, ostensible agency or borrowed servant doctrine.
VI. FACTS
8. Prior to October 27, 2021, Jabbar Muhammad stopped seeing his psychiatrist and
stopped taking his medications.
9. On October 27, 2021, at approximately 01:52am, East Joliet Fire Department –
EMS received a 911 call from Jabbar Muhammad’s grandfather (Eldred J. Wells, Sr.) that Jabbar
had attempted suicide by using a knife to cut his left forearm (3cm laceration) at the residence they
shared at 300 Middletree Road, Joliet, Illinois 60433.
10. Present at the scene was a note that stated the following: “I slit my wrist my time.
is off. I have to fix it. Someone when I come back. Please help me be a monk. no smoke. drink.
drugs. only elevation.”
11. Upon the arrival of the ambulance, Jabbar demonstrated inexplicable behavior and
stated, “Your partner is the devil because I can feel him smelling my blood.”
12. On October 27, 2021, at approximately 02:38am, Jabbar Muhammad arrived at the
emergency department of Silver Cross Hospital and Medical Centers (Silver Cross Hospital).
13. Jabbar told a social worker that he cut his arm because “Satan wanted my seed.”
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14. Jabbar reported that “it’s just a small cut, the devil did it”, when asked why, Jabbar
reported “I’m a special person, I’m a special race [Novanoti] and they want our seed all the world.”
15. Jabbar reported he had previously been psychiatrically hospitalized multiple times
since December 2020, but denied previous suicide attempts.
16. Jabbar admitted he wanted to kill people all the time (homicidal ideations), but
denied it was directed toward any specific person.
17. At Silver Cross Hospital, Jabbar Muhammad was diagnosed with psychosis,
homicidal ideations, and intention to self-harm.
18. On October 27, 2021, at approximately 11:30am, Jabbar Muhammad was
transferred by ambulance from Silver Cross Hospital to Silver Oaks Behavioral Hospital to receive
mental health care from, inter alios, Dr. Soberekon Melvin Koko.
19. Per Erin Smith, LSW, the psychiatric reason for admission to Silver Oaks
Behavioral Hospital was danger-to-self with psychosis1.
20. On October 28, 2021, Jabbar Muhammad advised Erin Smith, LSW that he was
“angry with family”, that his current living arrangement with his grandfather (Eldred J. Wells, Sr.)
is “shit”, that Eldred had a bad temper and puts blame on Jabbar that resulted in Jabbar being
hospitalized, and that he had a prior history of domestic battery (3 times).
21. In the evening of November 2nd (23:10), Jabbar Muhammad refused his anti-
psychotic medication (Zyprexa).
1
“‘Psychosis’ is defined as ‘[a] mental disorder causing gross distortion or disorganization of a person’s
mental capacity, affective response, and capacity to recognize reality, communicate, and relate to others to the degree
of interfering with his capacity to cope with the ordinary demands of everyday life.’” People v. Schorle, 206 Ill. App.
3d 748, 754 (1st Dist. 1990) (citing and quoting STEDMAN'S MEDICAL DICTIONARY 1166 (24th ed. 1982)).
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22. On November 3, 2021, at approximately 15:49, Savannah Regis, MSW (intern)
spoke with Jabbar Muhammad about his frustration with his admission and belief that he would
only be admitted for five (5) days.
23. Prior to his discharge, Jabbar Muhammad advised Silver Oaks Behavioral, LLC
and Dr. Koko, when asked about the access to “lethal methods”, that there was the presence of
knives at in the home he shared with his grandfather (Eldred J. Wells, Sr.).
24. On November 5, 2021, in preparation of his discharge, Erin Smith, LSW spoke with
Eldred J. Wells, Sr., who confirmed he had a secured firearm at this home; there was no mention
or discussion about access to other lethal items, namely, knives that were present in the home and
the need to secure those items.
25. In the evening of November 5th (20:40) and the morning of November 6th (06:00),
Jabbar Muhammad refused medication (Zyprexa), which he was prescribed for psychosis.
26. Prior to his discharge, Jabbar Muhammad advised Silver Oaks Behavioral, LLC
and Dr. Koko that yelling and loud noises both trigger and/or cause an escalation when Jabbar is
experiencing a crisis situation.
27. At the time of his discharge, Jabbar Muhammad’s primary psychiatric diagnosis
was major depressive disorder severe with psychosis, and his prognosis was “fair”.
28. At the time of his discharge, Jabbar Muhammad was prescribed Prozac
(antidepressant) and Zyprexa (anti-psychotic).
29. On November 6, 2021, at approximately 11:50am, Jabbar Muhammad was
discharged from Silver Oaks Behavioral Hospital to the home he shared with his grandfather,
Eldred J. Wells, Sr.
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30. Approximately four (4) hours after his discharge from Silver Oaks Behavioral
Hospital, deputies of the Will County Sheriff’s Office were informed by 911 that a man (Jabbar
Muhammad) was armed with a knife and threatening his grandfather (Eldred J. Wells, Sr.).
31. At approximately 4:07pm, a deputy sheriff arrives at the home of Eldred Wells and
Jabbar Muhammad and announces, “Sheriff’s Department”.
32. Within thirty-two (32) seconds of the deputy’s arrival at the residence, Jabbar
Muhammad and Eldred J. Wells, Sr. were shot and killed by deputies of the Sheriff of Will County.
33. On November 6, 2021, 21-year-old Jabbar Muhammad died from multiple gunshot
wounds (GSW).
34. Also, 70-year-old Eldred J. Wells, Sr. died as a result of multiple gunshot wounds.
35. Following the shooting, the Will/Grundy Major Crimes Task Force undertook an
investigation of this police-involved shooting.
36. That at all times relevant herein, Jabbar Muhammad was in the exercise of due care
and caution for his safety and well-being.
COUNT 1
(SILVER OAKS BEHAVIORAL, LLC – SURVIVAL ACT)
37. Plaintiff repeats, realleges, and incorporates paragraphs one (1) through thirty-six
(36) with the same force and effect as though fully set forth herein.
38. This Count is directed against Silver Oaks Behavioral, LLC.
39. That at all times complained of herein, the defendant had a duty to exercise that
degree of knowledge, skill, and care in administering medical care and treatment to Jabbar
Muhammad that reasonably careful health care professional would do under similar circumstances
40. Defendant breached its duty and was negligent in the following respect:
(a) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
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and negligently prematurely discharging Jabbar Muhammad on November
6, 2021;
(b) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
and negligently discharging Jabbar Muhammad on November 6, 2021
before it was safe to discharge him;
(c) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
before he was stable for discharge;
(d) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
and negligently discharging Jabbar Muhammad on November 6, 2021 to a
residential environment that was not safe for him given his clinical
condition.
41. That as a proximate result of one or more of the aforementioned deviations from
the applicable standard of care, Jabbar Muhammad was at an increased susceptibility to agitation
and violence that might be directed at himself and/or others.
the applicable standard of care, Jabbar Muhammad was discharged without sufficient coping
strategies to avoid becoming a safety risk to himself and others.
the applicable standard of care, Jabbar Muhammad became a participant in, first, a domestic
dispute and, then, a police-involved interaction that significantly escalated when the deputies
arrived, which resulted in him being shot multiple times, suffering significant and permanent
injuries, and which resulted in his death.
44. This cause of action has survived the plaintiff’s decedent and accrued to the
plaintiff, Rhonda Wells, Special Representative of the Estate of Jabbar Muhammad, deceased,
pursuant to the Survival Act of the State of Illinois (755 ILCS 5/27-6).
45. Attached hereto as Exhibit “A” and made a part hereof is an affidavit submitted in
compliance with Section 2-622(a)(1) of the Illinois Code of Civil Procedure.
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46. Plaintiff’s damages are in excess of Fifty Thousand Dollars ($50,000.00), the
minimum jurisdictional amount of this Court.
WHEREFORE the plaintiff, Rhonda Wells, Independent Administrator of the Estate of
Jabbar Muhammad, deceased, prays this court for damages according to proof and for such other
and further relief as this Court deems just.
COUNT 2
(SILVER OAKS BEHAVIORAL, LLC – WRONGFUL DEATH ACT)
47. Plaintiff repeats, realleges, and incorporates paragraphs one (1) through forty-three
(43) of Count 1 with the same force and effect as though fully set forth herein.
48. As a direct and proximate result of the death of Jabbar Muhammad, his next-of-kin
have and will continue to suffer great loss of a personal and pecuniary nature, and have been and
will continue to be deprived of the society, companionship, friendship, comfort, guidance, love
and affection of Jabbar Muhammad.
49. That Rhonda Wells, Independent Administrator of the Estate of Jabbar Muhammad,
deceased, and brings this action pursuant to the Wrongful Death Act of the State of Illinois. 740
ILCS 180/2.1.
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COUNT 3
(SOBEREKON MELVIN KOKO, MD – SURVIVAL ACT)
51. Plaintiff repeats, realleges, and incorporates paragraphs one (1) through thirty-six
(36) with the same force and effect as though fully set forth herein.
52. This Count is directed against Soberekon Melvin Koko, MD.
53. That at all times complained of herein, the defendant had a duty to exercise that
degree of knowledge, skill, and care in administering medical care and treatment to Jabbar
Muhammad that reasonably careful health care professional would do under similar circumstances
54. Defendant breached its duty and was negligent in the following respect:
(a) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently prematurely discharging Jabbar Muhammad on November 6,
2021;
(b) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently discharging Jabbar Muhammad on November 6, 2021 before it
was safe to discharge him;
(c) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently discharging Jabbar Muhammad on November 6, 2021 before he
was stable for discharge;
(d) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently discharging Jabbar Muhammad on November 6, 2021 to a
condition.
the applicable standard of care, Jabbar Muhammad was at an increased susceptibility to agitation
and violence that might be directed at himself and/or others.
the applicable standard of care, Jabbar Muhammad was discharged without sufficient coping
strategies to avoid becoming a safety risk to himself and others.
the applicable standard of care, Jabbar Muhammad became a participant in, first, a domestic
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dispute and, then, a police-involved interaction that significantly escalated when the deputies
arrived, which resulted in him being shot multiple times, suffering significant and permanent
injuries, and which resulted in his death.
59. Attached hereto as Exhibit “A” and made a part hereof is an affidavit submitted in
compliance with Section 2-622(a)(1) of the Illinois Code of Civil Procedure.
COUNT 4
(SOBEREKON MELVIN KOKO, MD – WRONGFUL DEATH ACT)
61. Plaintiff repeats, realleges, and incorporates paragraphs one (1) through fifty-seven
(57) of Count 3 with the same force and effect as though fully set forth herein.
ILCS 180/2.1.
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COMPLAINT AGAINST MIKE KELLY, in his official capacity

as Sheriff of Will County, Illinois; and COUNTY OF WILL
I. NATURE OF ACTION
1. This is a personal injury action seeking monetary damages on behalf of Plaintiff for
injuries sustained as a result of the acts and/or omissions of Mike Kelly, in his official capacity as
Sheriff of Will County.
II. PARTIES
A. Plaintiff.
2. Rhonda Wells is the duly-appointed Independent Administrator of the Estate of
Jabbar Muhammad, deceased, having been so appointed by the Circuit Court of the Twelfth
Judicial Circuit (Case No. 2022PR000271) to act in that capacity.
B. Defendants.
3. Mike Kelly, Sheriff of Will County, is an independently elected county officer of
Will County with his principal place of business located at 16911 W. Laraway Road, Suite 101,
Joliet, Illinois 60433. Defendant Sheriff of Will County is sued in his official capacity.
4. Under section 9–102, the Sheriff is required to pay any tort compensatory damages
judgment for which he or an employee acting within the scope of his employment is liable so long
as the conduct was willful and wanton. 745 ILCS 10/9–102.
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5. County of Will is a municipal corporation with its principal place of business
located at the Will County Office Building, 302 N. Chicago Street, Joliet, Illinois 60432. Because
the office of the sheriff is funded by the county, the county is therefore required to pay any
settlement or judgment. Carver v. Sheriff of LaSalle County, 203 Ill. 2d 497, 787 N.E.2d 127, 141
(2003).
III. JURISDICTION
6. The court has jurisdiction over the lawsuit because the lawsuit alleges a justiciable
matter that includes allegations arising under Illinois law. ILL. CONST. 1970, art. VI, § 9.
IV. VENUE
7. Venue is proper in the Circuit Court of the Twelfth Judicial Circuit (Will County,
Illinois) because a substantial part of the events or omissions giving rise to this claim occurred in
this county. 735 ILCS 5/2-101.
VI. FACTS
8. On November 6, 2021, at approximately 11:50am, Jabbar Muhammad was
discharged from Silver Oaks Behavioral Hospital to the home he shared with his grandfather,
Eldred J. Wells, Sr.
9. At approximately four (4) hours after his discharge from Silver Oaks Behavioral
Hospital, deputies of the Will County Sheriff’s Office were informed by 911 that a man (Jabbar
Muhammad) was armed with a knife and threatening his grandfather (Eldred J. Wells, Sr.).
10. At approximately 4:07pm, a deputy sheriff arrives at the home of Eldred J. Wells,
Sr. and Jabbar Muhammad and announces, “Sheriff’s Department”.
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11. Upon his entry into the house, the deputy observes Jabbar Muhammad hold a knife
in his right and identified as the predominant aggressor; Eldred J. Wells, Sr., who was unarmed,
standing a few feet away.
12. After making the initial observation, the deputy did not immediately separate the
parties (Jabbar and Eldred).
13. After making the initial observation, the deputy did not immediately isolate Jabbar
Muhammad in order to protect Eldred J. Wells, Sr. (the source of Jabbar’s agitation) and provide
the best opportunity to de-escalate the domestic dispute event.
14. In the next thirty (30) seconds, the deputies proceed to further agitate and yell at
Jabbar Muhammad, as well as draw their service weapons.
15. When the increasing yelling and agitation became too much, Jabbar Muhammad
lunged at Eldred J. Wells, Sr. and resulted in the deputies discharging their service weapons.
16. Within approximately thirty-two (32) seconds of the deputy’s arrival at the
residence, Jabbar Muhammad and Eldred J. Wells, Sr. were both shot multiple times by deputies
of the Sheriff of Will County.
17. On November 6, 2021, 21-year-old Jabbar Muhammad died from multiple gunshot
wounds (GSW).
18. Also, on November 6, 202170-year-old Eldred J. Wells, Sr. died as a result of
multiple gunshot wounds.
19. Following the shooting, the Will/Grundy Major Crimes Task Force undertook an
investigation of this police-involved shooting.
20. That at all times relevant herein, Jabbar Muhammad was in the exercise of due care
and caution for his safety and well-being.
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COUNT 5
(SHERIFF OF WILL COUNTY – SURVIVAL ACT)
21. Plaintiff repeats, realleges, and incorporates paragraphs one (1) through twenty (20)
with the same force and effect as though fully set forth herein.
22. This Count is directed against the Sheriff of Will County.
23. Prior to November 6, 2021, all deputies of the Will County Sheriff received training
to provide them with a basic understanding of mental health issues and appropriate de-escalation
and communication tactics.
to provide them with training regarding how to safely respond to reports of a domestic dispute.
that one of the primary initial interventions in domestic dispute calls is to separate the parties and,
thereafter, attempt to de-escalate the incident.
26. At the aforesaid place and time, the Sheriff of Will County, by its agents and
employees, was under a duty to avoid willful and wanton misconduct while executing and/or
enforcing the law.
27. Notwithstanding these duties, the Sheriff of Will County committed one or more of
the following acts and/or omissions:
(a) Willfully and wantonly executed or enforced the law on November 6, 2021
in the interaction with Jabbar Muhammad;
(b) Willfully and wantonly failed to separate the parties (Jabbar Muhammad
and Eldred Wells) on November 6, 2021;
(c) Willfully and wantonly failed to make sufficient efforts to de-escalate the
circumstances on November 6, 2021;
(d) Willfully and wantonly agitated and escalated the scene of the domestic
dispute on November 6, 2021.
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28. As a direct and proximate result of the foregoing acts and/or omissions, Jabbar
Muhammad became increasingly agitated and lunged at the closest person near him, Eldred J.
Wells, Sr.
29. As a direct and proximate result of the foregoing acts and/or omissions, the deputies
shot Jabbar Muhammad multiple times and suffered significant and permanent injuries, which
resulted in his death.
COUNT 7
(SHERIFF OF WILL COUNTY – WRONGFUL DEATH ACT)
32. Plaintiff repeats, realleges, and incorporates paragraphs one (1) through twenty-
nine (29) of Count 6 with the same force and effect as though fully set forth herein.
33. This Count is directed against the Sheriff of Will County.
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ILCS 180/2.1.
JURY DEMAND
Plaintiff, Rhonda Wells, Independent Administrator of the Estate of Jabbar Muhammad,
deceased, asserts her right under the Article I, Section 13 of the Illinois Constitution and demands,
in accordance with Section 5/2-1105 of Illinois Code of Civil Procedure, a trial by jury on all
issues.
Respectfully submitted,
SANDBERG LAW OFFICE, P.C.
By: /s/ Craig M. Sandberg__________

CRAIG M. SANDBERG
1104 Somerset Avenue
Deerfield, Illinois 60015
Tel: (833) 726-3237
Fax: (312) 466-1100
E-Mail: craig@sandberglaw.com
ARDC No. 6257836
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2022LA000681
IN THE CIRCUIT COURT OF THE 12TH JUDICIAL Filed
CIRCUIT Date: 10/17/2022 12:00 AM
Envelope: 19908449
WILL COUNTY, ILLINOIS Clerk: SE

)
Plaintiff, )
)
vs. ) Case No.
2022LA000681
)
COUNTY OF WILL, )
)
Defendants. )
AFFIDAVIT REGARDING DAMAGES SOUGHT
NOW COMES the plaintiff, Rhonda Wells, Independent Administrator of the Estate of
Jabbar Muhammad, deceased, by her attorneys, Sandberg Law Office, P.C., through Craig M.
Sandberg, your affiant and being first duly sworn under oath, states as follows:
1. That your affiant is one of the attorneys of record for the party in this matter.
2. That the total money damages sought in this civil action exceeds $50,000.
[x] Under penalties as provided by law pursuant to Section 5/1-109, of the Illinois Code of
Civil Procedure, I certify that the statements set forth in this instrument are true and correct,
except as to matters therein stated to be on information and belief and as such matters the
undersigned certifies as aforesaid that I verily believe the same to be true.
Craig M. Sandberg
P.O. Box 182
Tel: (833) 726-3237
Fax: (312) 466-1100
Email: craig@sandberglaw.com
ARDC No. 6257836
2022LA000681
IN THE CIRCUIT COURT OF THE 12TH JUDICIAL Filed
CIRCUIT Date: 10/17/2022 12:00 AM
Envelope: 19908449
WILL COUNTY, ILLINOIS Clerk: SE

)
Plaintiff, )
)
vs. ) Case No. 2022LA000681
)
COUNTY OF WILL, )
)
Defendants. )
PLAINTIFF’S ATTORNEY AFFIDAVIT PURSUANT TO 735 ILCS 5/2-622(a)(1)
CRAIG M. SANDBERG states as follows:
1. I am one of the attorneys with responsibility for this matter on behalf of the
plaintiff
2. I have consulted and reviewed the facts of the case with a health professional who
I reasonably believe: (i) is knowledgeable in the relevant issues involved in this case; (ii)
practices or has practiced within the last six (6) years or teach or have taught within the last six
(6) years in the same area of health care or medicine that is at issue in this case; and (iii) meets
the expert witness standards set forth in paragraphs (a) through (d) of Section 8-2501 of the
Illinois Code of Civil Procedure.
3. The reviewing health professional is a physician licensed to practice medicine in

all its branches.
4. The reviewing health professional has determined in a written report, after a

review of the medical record and other relevant material involved in this case that there is a
reasonable and meritorious cause for filing this case against the Silver Oaks Behavioral, LLC
and Dr. Soberekon Melvin Koko.
5. I have concluded on the basis of the reviewing health professional’s review and
consultation that there is a reasonable and meritorious cause for filing this case against the Silver
Oaks Behavioral, LLC and Dr. Soberekon Melvin Koko.
6. A copy of the written report, clearly identifying the plaintiff and the reasons for
the reviewing health professional’s determination that a reasonable and meritorious cause exists
for the filing of this case is attached. The original written report includes the reviewing health
care professional’s name, address, current license number, and state of licensure. The copy
attached to the complaint has this information deleted pursuant to the ruling in Lebron v. Gottlieb
Mem’l Hosp., 237 Ill. 2d 217 (2010) and O’Casek v. Children’s Home and Aid Society of Illinois,
374 Ill. App. 3d 507 (4th Dist. 2007).
7. Since the time the reviewing health professional was retained until now, this
health professional has been and has remained a consulting expert as provided for in Illinois
Supreme Court Rule 201(b)(3). I presently do not intend to call this consulting expert as a
witness at trial.
FURTHER AFFIANT SAYETH NAUGHT.
[x] Under penalties as provided by law pursuant to Section 5/1-109, of the Illinois Code of
Civil Procedure, I certify that the statements set forth in this instrument are true and
correct, except as to matters therein stated to be on information and belief and as such
matters the undersigned certifies as aforesaid that I verily believe the same to be true.
Craig M. Sandberg
P.O. Box 182
Tel: (833) 726-3237
Fax: (312) 466-1100
Email: craig@sandberglaw.com
ARDC No. 6257836
CERTIFICATION OF AN ACTION IN MEDICAL MALPRACTICE
PURSUANT TO 735 ILCS 5/2-622
Re: Estate of Jabbar Muhammad v. Silver Oaks Behavioral, LLC, et al.
I am a physician licensed to practice medicine in all of its branches. I am knowledgeable

in the relevant issues involved in this particular action and have practiced medicine within the last
six years. I have reviewed the medical records and other relevant material involved in this case
including, but not limited to, the following: (1) medical records of Jabbar Muhammad from Silver
Cross Hospital; (2) medical records of Jabbar Muhammad from Silver Oaks Behavioral Hospital;
(3) body camera video from Will County Sheriff’s Department; (4) Report of Postmortem
Examination of Jabbar Muhammad; and (5) Report of Postmortem Examination of Eldred J. Wells.
Prior to October 27, 2021, Jabbar Muhammad stopped seeing his psychiatrist and stopped
taking his medications. On October 27, 2021, at approximately 01:52am, East Joliet Fire
Department – EMS received a 911 call from Jabbar Muhammad’s grandfather (Eldred J. Wells)
that Jabbar had attempted suicide by using a knife to cut his left forearm (3cm laceration) at the
residence they shared at 300 Middletree Road, Joliet, Illinois 60433. Present at the scene was a
note that stated the following: “I slit my wrist my time. is off. I have to fix it. Someone when I
come back. Please help me be a monk. no smoke. drink. drugs. only elevation.” Upon the arrival
of the ambulance, Jabbar demonstrated inexplicable behavior and stated, “Your partner is the devil
because I can feel him smelling my blood.”
On October 27, 2021, at approximately 02:38am, Jabbar Muhammad arrived at the

emergency department of Silver Cross Hospital. Jabbar told a social worker that he cut his arm
because “Satan wanted my seed.” Jabbar reported that “it’s just a small cut, the devil did it”, when
asked why, Jabbar reported “I’m a special person, I’m a special race [Novanoti] and they want our
seed all the world.” Jabbar reported he had previously been psychiatrically hospitalized multiple
times since December 2020, but denied previous suicide attempts. Jabbar admitted he wanted to
kill people all the time (homicidal ideations), but denied it was directed toward any specific person.
At Silver Cross Hospital, Jabbar Muhammad was diagnosed with psychosis, homicidal ideations,
and intention to self-harm.
On October 27, 2021, at approximately 11:30am, Jabbar Muhammad was transferred by

ambulance from Silver Cross Hospital to Silver Oaks Behavioral Hospital to receive mental health
care from, inter alios, Dr. Soberekon Melvin Koko. Per Erin Smith, LSW, the psychiatric reason
for admission to Silver Oaks Behavioral Hospital was danger-to-self with psychosis.
On October 28, 2021, Jabbar advised Erin Smith, LSW that he was “angry with family”,
that his current living arrangement with his grandfather (Eldred J. Wells, Sr.) is “shit”, that Eldred
had a bad temper and puts blame on Jabbar that resulted in Jabbar being hospitalized, and that he
had a prior history of domestic battery (3 times). In the evening of November 2nd (23:10), Jabbar
refused his anti-psychotic medication (Zyprexa).
On November 3, 2021, at approximately 15:49, Savannah Regis, MSW (intern) spoke with
Jabbar about his frustration with his admission and belief that he would only be admitted for five
(5) days.
Prior to his discharge, Jabbar advised Silver Oaks Behavioral, LLC and Dr. Koko, when
asked about the access to “lethal methods”, that there was the presence of knives at in the home he
shared with his grandfather (Eldred J. Wells).
On November 5, 2021, in preparation of his discharge, Erin Smith, LSW spoke with Eldred
J. Wells, who confirmed he had a secured firearm at this home; there was no mention or discussion
about access to other lethal items, namely, knives that were present in the home and the need to
secure those items. In the evening of November 5th (20:40) and the morning of November 6th
(06:00), Jabbar Muhammad refused medication (Zyprexa), which he was prescribed for psychosis.
Prior to his discharge, Jabbar advised Silver Oaks Behavioral, LLC and Dr. Koko that yelling and
loud noises both trigger and/or cause an escalation when Jabbar is experiencing a crisis situation.
At the time of his discharge, according to the records, Jabbar’s primary psychiatric diagnosis was
major depressive disorder severe with psychosis, and his prognosis was “fair”. At the time of his
discharge, Jabbar was prescribed Prozac (antidepressant) and Zyprexa (anti-psychotic).
On November 6, 2021, at approximately 11:50am, Jabbar Muhammad was discharged

from Silver Oaks Behavioral Hospital to the home he shared with his grandfather, Eldred J. Wells.
At approximately 4:07pm, a deputy sheriff arrives at the home of Eldred J. Wells and
Jabbar Muhammad and announces, “Sheriff’s Department”. Upon the arrival of the deputies,
Jabbar appeared agitated and became more agitated while he stood in close proximity to the older
male and the deputy shouted directions at Jabbar. Within thirty-two (32) seconds of the deputy’s
arrival at the residence, Jabbar and Eldred Wells were shot by deputies of the Sheriff of Will
County. On November 6, 2021, 21-year-old Jabbar Muhammad died from multiple gunshot
wounds (GSW). Also, 70-year-old Eldred J. Wells died as a result of multiple gunshot wounds.
Following the shooting, the Will/Grundy Major Crimes Task Force undertook an investigation of
this police-involved shooting.
Based upon my review of the aforementioned materials and my training and experience,
and my familiarity with the treatment and management of condition(s) like those involved in this
matter, it is my opinion that a reasonable and meritorious cause exists for the filing of an action
against Silver Oaks Behavioral, LLC as principal to Dr. Soberekon Melvin Koko because it was
negligent in the following ways:
(a) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
and negligently prematurely discharging Jabbar Muhammad on November
6, 2021;
(b) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
before it was safe to discharge him;
(c) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
before he was stable for discharge;
(d) Silver Oaks Behavioral, LLC breached the standard of care by carelessly
and negligently discharging Jabbar Muhammad on November 6, 2021 to a
condition.
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Based upon my review of the aforementioned materials and my training and experience,
and my familiarity with the treatment and management of condition(s) like those involved in this
matter, it is my opinion that a reasonable and meritorious cause exists for the filing of an action
against Dr. Soberekon Melvin Koko because he was negligent in the following way:
(a) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently prematurely discharging Jabbar Muhammad on November 6,
2021;
(b) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently discharging Jabbar Muhammad on November 6, 2021 before it
was safe to discharge him;
(c) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently discharging Jabbar Muhammad on November 6, 2021 before he
was stable for discharge;
(d) Dr. Soberekon Melvin Koko breached the standard of care by carelessly and
negligently discharging Jabbar Muhammad on November 6, 2021 to a
condition.
That as a proximate result of one or more of the aforementioned deviations from the
applicable standard of care, Jabbar Muhammad was at an increased susceptibility to agitation and
violence that might be directed at himself and/or others. That as a proximate result of one or more
of the aforementioned deviations from the applicable standard of care, Jabbar Muhammad was
discharged without sufficient coping strategies to avoid becoming a safety risk to himself and
others. That as a proximate result of one or more of the aforementioned deviations from the
applicable standard of care, Jabbar Muhammad became a participant in, first, a domestic dispute
and, then, a police-involved interaction that significantly escalated when the deputies arrived,
which resulted in him being shot multiple times, suffering significant and permanent injuries, and
which resulted in his death. My opinions are subject to modification upon review of further
materials.
By:_
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Jabbar Muhammad Estate Lawsuit

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Jabbar Muhammad Estate Lawsuit

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Andrea Lynn Chasteen

Will County Circuit Clerk

IN THE CIRCUIT COURT OF THE 12TH JUDICIAL CIRCUIT

RHONDA WELLS, Independent )

Plaintiff, Rhonda Wells, Independent Administrator of the Estate of Jabbar Muhammad,

deceased, files her original complaint at law:

COMPLAINT AGAINST SILVER OAKS

Soberekon Melvin Koko, MD.

2. Rhonda Wells is the duly-appointed Independent Administrator of the Estate of

Judicial Circuit (Case No. 2022PR000271) to act in that capacity.

Hospital and Medical Center and US HealthVest.

4. Soberekon Melvin Koko, MD (License No. 036117531) is sued individually and as

an agent/employee of Silver Oaks Behavioral, LLC. Dr. Koko is a board-certified psychiatrist.

this county. 735 ILCS 5/2-101.

scope of employment of defendant’s officers, agents, servants, borrowed servants, employees or

employee status, agency by estoppel, ostensible agency or borrowed servant doctrine.

stopped taking his medications.

9. On October 27, 2021, at approximately 01:52am, East Joliet Fire Department –

shared at 300 Middletree Road, Joliet, Illinois 60433.

drugs. only elevation.”

since December 2020, but denied previous suicide attempts.

denied it was directed toward any specific person.

homicidal ideations, and intention to self-harm.

18. On October 27, 2021, at approximately 11:30am, Jabbar Muhammad was

Behavioral Hospital was danger-to-self with psychosis1.

hospitalized, and that he had a prior history of domestic battery (3 times).

psychotic medication (Zyprexa).

only be admitted for five (5) days.

the need to secure those items.

experiencing a crisis situation.

(antidepressant) and Zyprexa (anti-psychotic).

29. On November 6, 2021, at approximately 11:50am, Jabbar Muhammad was

Eldred J. Wells, Sr.

Jabbar Muhammad and announces, “Sheriff’s Department”.

investigation of this police-involved shooting.

and caution for his safety and well-being.

38. This Count is directed against Silver Oaks Behavioral, LLC.

and violence that might be directed at himself and/or others.

strategies to avoid becoming a safety risk to himself and others.

injuries, and which resulted in his death.

compliance with Section 2-622(a)(1) of the Illinois Code of Civil Procedure.

minimum jurisdictional amount of this Court.

WHEREFORE the plaintiff, Rhonda Wells, Independent Administrator of the Estate of

and further relief as this Court deems just.

and affection of Jabbar Muhammad.

minimum jurisdictional amount of this Court.

WHEREFORE the plaintiff, Rhonda Wells, Independent Administrator of the Estate of

and further relief as this Court deems just.

52. This Count is directed against Soberekon Melvin Koko, MD.

and violence that might be directed at himself and/or others.

strategies to avoid becoming a safety risk to himself and others.

injuries, and which resulted in his death.

compliance with Section 2-622(a)(1) of the Illinois Code of Civil Procedure.

minimum jurisdictional amount of this Court.

WHEREFORE the plaintiff, Rhonda Wells, Independent Administrator of the Estate of

and further relief as this Court deems just.

and affection of Jabbar Muhammad.

minimum jurisdictional amount of this Court.

WHEREFORE the plaintiff, Rhonda Wells, Independent Administrator of the Estate of

and further relief as this Court deems just.

COMPLAINT AGAINST MIKE KELLY, in his official capacity

Sheriff of Will County.

2. Rhonda Wells is the duly-appointed Independent Administrator of the Estate of

Judicial Circuit (Case No. 2022PR000271) to act in that capacity.