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In defense of assistant state’s attorneys Mike Jacobs and Dave Meyerson, who I knew when I worked for the Cook County state’s attorney, and from my own experience representing this sheriff’s office in civil litigation, whether you have all the necessary facts in a case depends entirely on your client’s willingness to be honest and truthful with you. As I found in my own travails representing the sheriff, that was frequently not the case. Thus, attorneys Jacobs’s and Meyerson’s lack of knowledge about the inner workings of Cook County Jail were due to no fault of their own but rather due to decisions made within the sheriff’s office–most probably by the sheriff’s two personal staff attorneys who were involved with the case–regarding what information would be disclosed to them.
Similarly, if attorneys Jacobs and Meyerson seemed reticent or unwilling to schedule that visit to the jail, it is not because they were not willing to schedule the visit but because their client, the sheriff, was refusing to cooperate. It was my experience that the sheriff’s personal attorneys did not appear to believe that the federal rules of civil procedure applied to the sheriff.