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Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 49 of 348 ‘anything’ she wanted” without the necessity of legal process. Lewis asked to meet with Villafafia and Sloman to discuss the Epstein investigation, but Villafafia declined. Shortly thereafter, Lilly Ann Sanchez, a former AUSA, contacted Sloman and advised him that she also represented Epstein. Sanchez was employed by the USAO from 2000 to September 2005 and had been a Deputy Chief of the USAO’s Major Crimes section at the time Menchel was the Chief. According to Sloman’s contemporaneous email recounting the conversation, when Sanchez indicated to him that his participation in Lewis’s call with Villafafia led the defense team to believe that the matter had been “elevated” within the USAO, Sloman tried to “disabuse” her of that notion. Sanchez said that Epstein “wanted to be as transparent and cooperative as possible” in working with the USAO. Despite the fact that Lewis had already made contact with the USAO on Epstein’s behalf, Sanchez sent a letter to Villafafia on November 15, 2006, in which she asserted that she and Gerald Lefcourt were representing Epstein and asked that the USAO direct all contact or communications about Epstein to them. In response, Villafafia requested that the defense provide documents and information pertinent to the federal investigation, including the documents and information that Epstein had previously provided to the State Attorney’s Office, and “computers, hard drives, CPUs [computer processing units], and any other computer media” removed from Epstein’s home before the PBPD executed its search warrant in October 2005. In January 2007, Sanchez contacted Villafafia to schedule a meeting, but Villafafia responded that she wanted to receive and review the documents before scheduling a meeting with Sanchez. Immediately after receiving Villafafia’s response, Sanchez bypassed Villafafia and phoned Lourie, with whom she had worked when she was an AUSA, to press for a meeting. Lourie agreed to meet with Sanchez and Lefcourt. Lourie explained to Villafafia that Sanchez was concerned that federal charges were “imminent,” wanted to meet with the USAO and “make a pitch,” and promised that once given the opportunity to do so, if the USAO “wanted to interview Epstein, that would be a possibility.” Villafafia told Lourie that Sanchez had not yet provided the documents she had promised, and Villafafia wanted “the documents not the pitch.” Lourie explained to OPR, however, that it was his practice to grant meetings to defense counsel; he considered it “good for us” to learn the defense theories of a case and believed that “information is power.” Lourie further explained that learning what information the defense viewed as important could help the USAO form its strategy and determine which counts relating to which victims should be charged. Lourie also believed that as a general matter, prosecutors should grant defense requests to make a presentation, because “[p]art of [the] process is for them to believe they are heard.” In addition to agreeing to a meeting, Lourie sent Sanchez a narrowed document request, which responded to Sanchez’s complaint that the USAO’s earlier request was overbroad but which retained the demand for the computer-related items removed from Epstein’s home. The meeting was scheduled for February 1, 2007, and Lourie asked Sanchez to provide the documents and materials to the USAO by January 25, 2007. Villafafia did not agree with Lourie’s decision to meet with Sanchez and Lefcourt. Indeed, two days after Lourie agreed to the meeting, Villafafia alerted him that she had spoken again with Sanchez and learned that Epstein was not going to provide the requested documents. As Villafafia told Lourie, “I just get to listen to the pitch and hear about how the girls are liars and drug users.” She told OPR that in her view, “it was way too early to have a meeting,” she already knew what the defense would say, and she could not see how a meeting would benefit the federal investigation. She explained to Lourie the basis for her objections to the meeting, but Lourie “vehemently” 23 DOJ-OGR-00003225