a particularized need. 4. Seriousness of the Litigation and Issues Holmes maintains that the gravity of her allegations — namely, that IPRA “concealed] its widespread efforts to cover-up unlawful shootings by police officers,” Pl.’s Reply Br. at 3 — warrants disclosing the draft summary reports. In other words, Holmes asserts that the privilege is overcome because IPRA’s deliberative process, which includes the back-and-forth exchange of draft summary reports between supervisors and investigators, is “part of the code of silence.” Id. Where a plaintiff directly challenges a government agency’s deliberative process, courts routinely find that there is a particularized need for disclosure. See, e.g., Smentek v. Sheriff of Cook Cnty., 2013 WL 2588709, at *4 (N.D. Ill. June 11, 2013) (<HOLDING>); Ferrell, 177 F.R.D. at 430-31 (finding a
holding that both saline county and grant county had jurisdiction to try the appellant for murder where the actual killing occurred in one county but the acts requisite to the consummation of the murder and the subsequent disposal of the body occurred in the other county holding that mandatory visual strip search policy in county jail was unconstitutional holding that public employees working for the office of cook county assessor and receiving their compensation from cook county had no vested right in the expectation of the continuance of this compensation holding that plaintiffs had a particularized need for cook county jail prebudget documents after observing that the plaintiffs theory is that the county allegedly approved the dental services budget despite knowing that it might create unconstitutional conditions at the jail accordingly  the countys deliberative process is directly at issue in this case holding that employees of county jail that housed federal prisoners pursuant to contract with the federal government were not federal employees even though county jail had to comply with federal rules and regulations