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sex-trafficking venture by, among other things, providing the financial 
underpinnings for Epstein to have ready and reliable access to resources—including 
cash—to recruit, lure, coerce, and entice young women and girls to be sexually 
abused and to cause them to engage in commercial sex acts and other degradations. 
78. 
Deutsche Bank assisted and participated in Epstein's sex-trafficking 
venture by knowingly enabling him to make payments to victims, including directly 
or indirectly Jane Doe 1, and others similarly situated, and obtain large sums of cash 
from his various accounts in violation of structuring laws in order to finance his well-
known, cash-driven, sex-trafficking venture. 
79. 
Deutsche Bank participated in Epstein's violations of the Trafficking 
Victims Protection Act by knowingly facilitating, assisting, and enabling Epstein's 
illegal conduct. Deutsche Bank's conduct violated the TVPA, which forbids 
benefiting financially by participating in a sex trafficking venture knowing, or in 
reckless disregard of the fact, that means of force, threats of force, fraud, coercion, 
abuse of process, and combination of those means have been used to cause young 
women and girls to engage in commercial sex acts. 
80. 
Deutsche Bank also conspired with Epstein (and others) to violate 18 
U.S.C. § 1591. It knew that it was joining a sex-trafficking venture and conspiracy 
that had been on-going for many years (at least since 2005). It adopted the goals of 
the venture and conspiracy and took specific actions in this District and elsewhere 
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in furtherance of it. 
81. 
When considering whether to participate in the sex-trafficking venture, 
and before on-boarding Epstein, Deutsche Bank estimated that it would earn 
between $2,000,000 to $4,000,000 annually by funding the sex-trafficking venture 
and handling the accounts of Epstein-related entities. 
82. 
Ultimately, Deutsche Bank did financially benefit by earning millions 
of dollars for its participation in the Epstein sex-trafficking venture. 
83. 
Throughout its relationship with Epstein, Deutsche Bank violated 
numerous regulations in order to continue its lucrative venture of facilitating the 
Epstein sex trafficking scheme. These violations were intentional and for the sole 
purpose of aiding and assisting Epstein in his sex trafficking venture and conspiracy. 
84. 
Paul Morris, a former JP Morgan banker, brought Epstein over from JP 
Morgan to Deutsche Bank in around August 2013. All knowledge acquired by JP 
Morgan about Epstein's sex-trafficking venture while Morris was at JP Morgan, 
became known to Deutsche Bank. Morris knew that Epstein was continuing his on-
going sex-trafficking venture and conspiracy. Morris had a special relationship with 
Epstein. 
85. 
In addition to Morris's knowledge and considering the known 
reputation of Epstein as a sex-trafficker, when Deutsche Bank was on-boarding 
Epstein, it had a responsibility to make all available inquiries to any other entity who 
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had been associated with Epstein to learn if Epstein had retired from his illegal sex-
trafficking operation. Reasonable inquiries would have quickly revealed that he had 
not. And, through Morris and other information, Deutsche Bank quickly learned that 
he had not. 
86. 
Financial institutions must conduct Know Your Customer ("KYC") 
reviews for each client relationship at intervals commensurate to the Anti-Money 
Laundering ("AML") risks posed by the client. These reviews included reviewing 
account activity to determine whether such activity fits with what would have been 
expected given the nature of the account. Each client's AML risk should also be re-
assessed if new information or unexpected account activity is identified. 
87. 
Financial institutions must also establish criteria for determining when 
a client relationship poses too high of a risk and therefore must be terminated. A 
financial institution may facilitate illegal activity—and be liable under applicable 
laws—if it maintains such a relationship despite repeated indications of facilitation 
of improper transactions. 
88. 
Without Deutsche Bank's participation and assistance, Epstein could 
not have sexually abused or trafficked the hundreds of young women he did between 
2013 and 2018. 
89. 
Deutsche Bank knew that in order to onboard Epstein and his related 
entities and maintain that relationship, it would have to intentionally circumvent 
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banking rules and regulations and work with Epstein to aid in the operation of the 
sex trafficking venture—and Deutsche Bank did exactly that. 
90. 
On July 6, 2020, Deutsche Bank agreed to pay a fine of $150 million to 
the New York State Department of Financial Services for, among other things, its 
failures to meet banking regulations in connection with its relationship to Epstein. 
Until that date, Deutsche Bank concealed who it had adopted the goals of the Epstein 
sex trafficking venture and conspiracy and worked to further those goals. 
IV. THE TRAFFICKING VICTIMS PROTECTION ACT 
91. 
The Trafficking Victims Protection Act (TVPA) forbids sex trafficking 
activities that affect interstate or foreign commerce or take place within the territorial 
jurisdiction of the United States. Courts must broadly construe the TVPA because 
it serves a remedial purpose and uses intentionally broad language. 
92. 
The TVPA forbids the following sex-trafficking conduct: 
(a) Whoever knowingly—
(1) in or affecting interstate or foreign commerce, or within 
the special maritime and territorial jurisdiction of the 
United States recruits, entices, harbors, transports, 
provides, obtains, advertises, maintains, patronizes, or 
solicits by any means a person; or 
(2) benefits, financially or by receiving anything of value, 
from participation in a venture which has engaged in an 
act described in violation of paragraph (1), 
knowing, or, except where the act constituting the violation of 
paragraph is advertising, in reckless disregard of the fact, that means of 
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force, threats of force, fraud, coercion described in subsection (e)(2), or 
any combination of such means will be used to cause the person to 
engage in acommercial sex act, or that the person has not attained the 
age of 18 years and will be caused to engage in a commercial sex act, 
shall be punished as provided in subsection (b). 
18 U.S.C. § 1591(a). 
93. 
The TVPA also contains a conspiracy provision, which forbids 
conspiring with a person to violate 18 U.S.C. § 1591. 
94. 
The TVPA also contains an explicit "civil remedy" provision which 
allows an individual who is a victim of a violation of Chapter 77 of Title 18 (e.g., 18 
U.S.C. §§ 1591-95) to bring a civil action against the perpetrator and any person or 
entity who knowingly benefits financially or by receiving anything of value from 
participation in an illegal sex-trafficking venture. 18 U.S.C. § 1595(a). 
95. 
Unlike the criminal penalties provisions in the TVPA, the civil 
remedies provision contains a "constructive knowledge" provision. This provision 
allows a civil action to be brought not only against a person or entity who 
participated in a venture known to have engaged in illegal sex trafficking but also 
against a person or entity who participated in a venture that the person or entity 
should have known had engaged in illegal sex trafficking. 18 U.S.C. § 1595(a). This 
expansive provision is known as the "constructive knowledge" provision, which 
provides an alternative to proving actual knowledge as part of civil damages claim. 
96. 
In this complaint, Jane Doe 1 and other members of the Class allege 
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that Deutsche Bank acted outrageously and intentionally. But additionally, in the 
paragraphs that follow, wherever Jane Doe 1 and the other members of the Class 
allege that Defendants acted with actual knowledge, or in reckless disregard of the 
fact, that the Epstein sex-trafficking venture used means of force, threats of force, 
fraud, coercion, abuse of process, or some combination thereof to cause a person to 
engage in commercial sex acts, Jane Doe 1 and other members of the Class also 
allege that, at a bare minimum, Defendants should have known that the Epstein sex-
trafficking venture had used such means to engage in illegal sex trafficking in 
violation of 18 U.S.C. §§ 1591-94—i.e., that they had constructive knowledge of 
Epstein's sex trafficking. 
97. 
In this complaint, Jane Doe 1 and other members of the Class also 
allege that Deutsche Bank was willfully blind to the fact that was facilitating and 
participating in Epstein's sex-trafficking venture. 
V. THE RACKETEER INFLUENCED AND 
CORRUPT ORGANIZATIONS ACT 
98. 
The Racketeer Influenced and Corrupt Organizations Act (RICO) 
forbids racketeering activities that affect interstate or foreign commerce or take place 
within the territorial jurisdiction of the United States. 
99. 
As with the TVPA, courts must broadly construe RICO because it 
serves a remedial purpose and uses intentionally broad language. The Act provides 
that "[t]he provisions of this title shall be liberally construed to effectuate its 
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remedial purposes." Pub.L. No. 91-452, § 904(a), 84 Stat. 922,947 (1970). 
100. RICO forbids the following racketeering activities: 
It shall be unlawful for any person who has received any income 
derived, directly or indirectly, from a pattern of racketeering activity or 
through collection of an unlawful debt in which such person has 
participated as a principal within the meaning of section 2, title 18, 
United States Code, to use or invest, directly or indirectly, any part of 
such income, or the proceeds of such income, in acquisition of any 
interest in, or the establishment or operation of, any enterprise which is 
engaged in, or the activities of which affect, interstate or foreign 
commerce. A purchase of securities on the open market for purposes of 
investment, and without the intention of controlling or participating in 
the control of the issuer, or of assisting another to do so, shall not be 
unlawful under this subsection if the securities of the issuer held by the 
purchaser, the members of his immediate family, and his or their 
accomplices in any pattern or racketeering activity or the collection of 
an unlawful debt after such purchase do not amount in the aggregate to 
one percent of the outstanding securities of any one class, and do not 
confer, either in law or in fact, the power to elect one or more directors 
of the issuer. 
18 U.S.C. § 1962(a). 
101. RICO also contains provision making it illegal for any person to 
conspire with others to violate any of RICO's prohibitions. 18 U.S.C. § 1962(d). 
102. RICO also contains an explicit "civil remedy" provision which allows 
an individual who is injured in his business or property by virtue of a violation of 18 
U.S.C. § 1962 to sue to recover threefold the damages sustained. 18 U.S.C. § 
1964(c). 
103. In the paragraphs that follow, Jane Doe 1 and other members of the 
Class allege that Deutsche Bank violated 18 U.S.C. § 1962 and injured them in 
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various ways, including injury to their businesses and property. 
VI. FACTUAL ALLEGATIONS 
A. The Epstein Sex-Trafficking Venture and Conspiracy. 
104. During all times relevant to this complaint, Jeffrey Epstein was an 
extraordinarily wealthy man with multiple residences in the United States, including 
a New York City mansion, a New Mexico Ranch, an apartment in Paris, France, a 
Palm Beach mansion, and an island in the U.S. Virgin Islands. 
105. Beginning in about 1998 (and perhaps earlier) and continuing through 
the summer of 2019, Epstein knowingly established and ran a sex-trafficking venture 
and conspiracy in violation of 18 U.S.C. §§ 1591-95. As part of the venture and 
conspiracy, Epstein used means of force, threats of force, fraud, coercion, abuse of 
legal process, and a combination of these means to cause young women and girls 
from all over the world to engage in commercial sex acts and to sexually abuse them. 
106. In creating and maintaining this network of victims in multiple states 
and in other countries to sexually abuse and exploit, Epstein worked and conspired 
with others, including employees and associates who facilitated his conduct by, 
among other things, recruiting victims, coercing victims, paying victims, and 
scheduling their sexual abuse by Epstein at each of his residences, most 
predominantly in New York. 
107. In this District and elsewhere, Epstein perpetuated this abuse in similar 
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ways. Epstein and his co-conspirators lured new victims into his home for seemingly 
innocuous activity. Victims were initially recruited to speak with an alleged 
philanthropic Epstein and provide "massages" to him. Once at Epstein's home and 
trapped in his bedroom, the victims were instructed to remove their clothing. Epstein 
would then force the massages to become increasingly sexual in nature, typically 
including one or more sex acts. Epstein would use means of force, threats of force, 
or fraud to coerce the victims to participate in these sex acts and to cause them to 
return and continue to engage in commercial sex acts with him. Epstein and his 
associates then paid his victims hundreds of dollars in cash for each sexual encounter 
and for maintaining silence about the encounter. 
108. Moreover, Epstein actively encouraged and coerced his victims to 
recruit additional girls to be similarly sexually abused. Epstein incentivized his 
victims to become recruiters by paying these victim-recruiters hundreds of dollars 
for each girl that they brought to Epstein. In so doing, Epstein, through this system 
of paying victims to recruit others whom he would also pay for being sexually 
abused as well as for recruiting, created a sex-trafficking spider web and maintained 
a steady supply of new victims to exploit. 
109. Epstein was skilled at ascertaining his victim's greatest fears and 
aspirations and targeted those fears and aspirations to coerce and trap his victims 
into performing commercial sex acts and to be subject to sexual abuse. 
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110. Among other things, Epstein caused and coerced his victims to engage 
in commercial sex acts, specifically sex acts for which his victims received things of 
value, such as cash, promises of educational and career advancement, and promises 
that Epstein would provide various forms of assistance. 
111. Among other things, Epstein provided things of value to his victims in 
order to cause and coerce them to engage sex acts with him and on occasion his 
friends, co-conspirators, or other victims. 
112. As one means of causing and coercing victims to engage in commercial 
sex acts, Epstein and his co-conspirators threatened that harm would come to victims 
if they did not comply with his demands that they perform commercial sex acts. 
113. As another means of causing and coercing victims to engage in 
commercial sex acts, Epstein and his co-conspirators fraudulently promised to 
further victims' educational or career aspirations if they would comply with his 
sexual demands. These promises were a quid pro quo for the sex acts that occurred. 
114. Epstein and his co-conspirators falsely promised Jane Doe 1 and other 
Class Members various employment and professional opportunities, which 
prevented them from pursuing other employment opportunities. These false 
promises were part of the Enterprise's operation, because they forced and caused 
Epstein's victims to participate in commercial sex acts. Forcing sex-trafficking 
victims into a position of economic dependency on their traffickers is a well-known 
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means of coercion, which Epstein used against Jane Doe 1 and the Class Members. 
115. As one means of causing and coercing victims to engage in commercial 
sex acts, Epstein and his co-conspirators would "gift" his victims money and provide 
them with living accommodations, clothing, education, or other necessities. Epstein 
and his co-conspirators would then force them to pay off the "debt" by complying 
with Epstein's sexual demands. 
116. In addition to coercing commercial sex acts from his victims, Epstein 
also committed intentional torts and sexual offenses against them as defined in New 
York Penal Law § 130, as described in greater detail below. 
117. From around 1998 through about July 2019, Epstein's sex-trafficking 
venture recruited, solicited, enticed, harbored, obtained, provided, and transported 
hundreds of victims to cause them to engage in commercial sex acts with Epstein 
and Epstein's friends. Epstein was reliant on banking institutions to help make the 
racketeering activity successful. 
118. Epstein recruited, solicited, enticed, harbored, obtained, provided, and 
transported his victims to cause them to engage in commercial sex acts in ways that 
were in and affecting interstate and foreign commerce, including using means of 
interstate communications (such as cell phones) and means of interstate and foreign 
travel (such as aircraft that he owned and controlled). 
119. Epstein transported his victims in interstate and foreign commerce, 
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including transportation to and from his New York mansion in this District. 
120. The Epstein sex-trafficking venture transported victims across state 
boundaries between New York, Florida, New Mexico, New Jersey, Massachusetts, 
the U.S. Virgin Islands, and elsewhere, and in foreign commerce to places abroad, 
especially Eastern Europe. 
121. At all times relevant to this complaint, the Epstein sex-trafficking 
venture was a group of two or more individuals associated in fact, even if they were 
not a formal legal entity. Indeed, members of the Epstein sex-trafficking venture 
referred to it as "The Organization." Epstein was continuously at the hub of The 
Organization, which operated continuous throughout the times indicated in this 
complaint. 
122. On July 2, 2019, the United States Attorney's Office for the Southern 
District of New York filed a sealed, two-count Indictment against Epstein, including 
one count of sex-trafficking conspiracy and one count of sex trafficking for 
violations of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New 
York Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, 
Case No. 1:19-cr-00490 (S.D.N.Y.). 
123. On July 8, 2019, Epstein was arrested pursuant to the Southern District 
of New York Indictment. 
124. On August 10, 2019, prison guards found Epstein unresponsive in his 
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Metropolitan Correctional Center jail cell, where he was awaiting trial on the federal 
sex trafficking charges. He was later pronounced dead from apparent suicide. 
125. In July 2020, Epstein's co-conspirator in the origin of the sex-
trafficking venture, Ghislaine Maxwell, was arrested on federal sex trafficking 
charges filed in this Court. The charges alleged that she had assisted, facilitated, and 
contributed to Epstein's abuse of sex trafficking victims, helping Epstein to recruit, 
groom, and ultimately abuse his victims. See United States v. Maxwell, Case No. 
1:20-cr-00330 (S.D.N.Y.). 
126. On December 29, 2021, Maxwell was found guilty in this Court on five 
federal sex-trafficking counts in this Court. 
B. Consistent With Jeffrey Epstein's Uniform Pattern and Practice, Jane 
Doe 1 Was Assaulted Within the Definition of New York Penal Law 
Section 130 and Forced to Engage in Commercial Sex Acts With 
Epstein by Means of Force, Fraud, and Coercion. 
127. In about 2003, Jane Doe 1 moved to New York City where she was 
introduced to and sexually abused by Jeffrey Epstein. 
128. From about 2003 until the time that Jane Doe 1 escaped, Epstein 
committed numerous intentional torts and acts against Jane Doe 1 on a regular and 
frequent basis, which constitute sexual offenses as defined in New York Penal Law 
§ 130, including but not limited to the following: 
a. Sexual misconduct as defined in §130.20, as Epstein engaged in sexual 
intercourse with Jane Doe without her consent; 
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b. Rape in the first degree as defined in §130.35, as Epstein engaged in 
sexual intercourse with Jane Doe by forcible compulsion; 
c. Criminal sexual act in the first degree as defined in §130.50, as Epstein 
engaged in oral sexual conduct with Jane Doe by forcible compulsion; 
d. Forcible touching as defined in §130.52, as Epstein, intentionally and 
for no legitimate purpose, forcibly sexual touched Jane Doe for the 
purpose of degrading or abusing her or for the purpose of gratifying his 
own sexual desire; 
e. Sexual abuse in the third degree as defined in §130.66, as Epstein 
inserted a foreign object in the vagina of Jane Doe by forcible 
compulsion; 
f. Aggravated sexual abuse in the first degree as defined in §130.70, as 
Epstein inserted a foreign object in Jane Doe's vagina causing physical 
injury, by forcible compulsion. 
129. Epstein and his co-conspirators had a long history of grooming, 
indoctrinating, controlling, and ultimately committing sexual offenses against 
young, vulnerable women like Jane Doe 1. Epstein and his co-conspirators 
constantly reminded Jane Doe 1 how powerful and important Epstein was. 
130. The well-oiled Epstein sex-abuse and sex-trafficking venture and 
conspiracy included frequent statements to Jane Doe 1, and other victims, by Epstein 
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and his co-conspirators that: (1) Epstein possessed extraordinary wealth, power and 
influence; (2) Epstein's business and political friends, including world leaders, 
included some of the most powerful people in the world; (3) Epstein had the ability 
to advance or destroy nearly anyone financially, reputationally, and otherwise; (4) 
medical and normal life necessities would be denied victims if they, including Jane 
Doe 1, did not allow Epstein to sexually abuse them and failed to perform 
commercial sex acts for Epstein; and (5) Epstein could take away Jane Doe l's and 
other victims' life needs such as shelter or housing if they failed to allow sexual 
abuse or to perform those acts. 
131. As with his other chosen victims, Jane Doe 1 was vulnerable to being 
victimized by Epstein and was sexually abused by Epstein at his sole direction 
almost every day she was in his presence, as was customary practice for 
Epstein. Jane Doe 1 was soon forced to remain in contact with Epstein, was unable 
to extricate herself, and had no real choice but to comply with Epstein's every 
command or risk suffering serious harm. 
132. Jane Doe 1 was sexually abused and trafficked by Epstein for numerous 
years and was not able to escape from Epstein until about 2018. Having been 
conditioned that the sexual abuse was "normal" and knowing that everyone 
surrounding Epstein, including accountants, lawyers, bankers, and other important 
people, were aware of the sex abuse, Jane Doe 1 was coerced into a cult-like life 
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controlled by Epstein and others to be sexually abused and sexually trafficked. 
133. From about 2003 through about 2018, Epstein sexually abused Jane 
Doe 1 in this District. 
134. Epstein used means of force, threats of force, fraud, coercion, abuse of 
process, and a combination of such means to sexually abuse Jane Doe 1 and to cause 
her to engage in commercial sex acts. 
135. Epstein recruited Jane Doe 1 to, among other things, cause her to 
engage in commercial sex acts in ways that were in and affecting interstate and 
foreign commerce, including through use of cell phones and means of interstate 
transportation such as aircraft that he owned or controlled. 
136. Epstein transported Jane Doe 1 from New York to other states to 
sexually abuse her and to cause her to engage in commercial sex acts. 
137. As the years of abuse continued, Jane Doe 1 wanted to escape from the 
Epstein organization, yet Epstein and his supporting team of co-conspirators 
increased the tactics of fraud, force, and coercion to cause her to remain compliant 
in allowing Epstein to sexually abuse and traffic her, making it clear she would suffer 
serious harm if she were to try to leave the organization. 
138. Epstein threatened Jane Doe 1 that she would lose contact with people 
in her social circle who were connected with Epstein if she failed to comply with his 
demands. 
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139. Epstein would alternate between usually false promises and threats to 
secure Jane Doe 1 's compliance with his demands, including demands that she 
engage in commercial sex acts with him and others. In some instances, Epstein 
would pay Jane Doe 1 directly in cash for sex acts and in other instances she was 
provided other things of value such as medical care, housing, transportation, 
schooling, and job opportunity. 
140. From 2003, when Doe was first introduced to Epstein, and through her 
eventual separation from Epstein and his organization 15 years later, Epstein and his 
co-conspirators used extreme measures of force, fraud and coercion to cause Jane 
Doe 1 to engage in commercial sex and to remain obedient to the organization. 
141. Epstein introduced Jane Doe 1 to powerful individuals, made clear he 
could destroy anyone who disobeyed him, including Jane Doe 1. 
142. Even when Epstein was in Florida jail, Doe 1 was required to be in 
Florida for the hours during the day when Epstein was on work release. 
143. Doe I never had a say in anything, including sex, and had to be 
compliant to Epstein's every wish and was trained that she had to express gratitude 
and appear appreciative for Epstein and all he could do for her, knowing that he 
would cause her serious harm if she did not comply. 
144. Epstein controlled where Doe 1 lived, and he housed her at his victim 
stash houses that he owned at 310 East 66 Street, NY, NY. 
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145. When Epstein demanded Doe 1 be on flights to anywhere in the world 
at a moments notice, she had to be there, and co-conspirators for Epstein passed out 
schedules for Doe 1 so she knew where she had to be and when. 
146. When Epstein was in civil or criminal trouble, Epstein provided gifts or 
promises of gifts or promises of employment or schooling to prevent Doe 1 from 
turning on Epstein. 
147. Epstein forced Doe 1 into relationships that would be advantageous to 
Epstein, and Doe I was given no choice but to comply. 
148. Epstein forced Doe 1 to be at his beckon call to participate in whatever 
sexual encounter he commanded at the time, wherever he commanded, with whoever 
he commanded. 
149. Epstein's sexual abuse of exploitation of Plaintiff grew more painful 
as Jane Doe 1 aged, yet Doe 1 was explicitly told she could not leave the Epstein 
organization's grasp without the risk of suffering serious harm. 
150. As late as 2017 and 2018, Epstein continued to demand sexual 
compliance from Doe 1 and Doe 1 continued to ask out of the organization 
peacefully. However, as was Epstein's known coercive style, Epstein and co-
conspirators of his made it clear she would suffer serious harm if she would try to 
separate from the Epstein organization, and that if she did separate it would need to 
be on terms outlines by the organization. 
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151. Certain coercive tactics employed by Epstein and his co-conspirators 
included forced relationships directed by Epstein, legal entanglements with Epstein 
related entities, the threat that Doe 1 would go bankrupt in legal processes if she left, 
threats that the organization would protect her if she remained compliant, yet she 
would suffer if she did not. 
152. Once Doe 1 was lured in, Epstein's coercive tactics increased over time 
to ensure that Jane Doe 1 could never escape. 
153. Epstein and his co-conspirators continued to coerce Jane Doe 1 into 
commercial sex in various ways until her ultimate escape from Epstein and his 
organization in about 2018. 
C. Deutsche Bank's Participation in Epstein's Sex-Trafficking Venture 
1. Overview of Deutsche Bank's participation in the venture. 
154. From on or about August 19, 2013, through about July 2020, Deutsche 
Bank knowingly and intentionally participated in the Epstein sex-trafficking venture, 
conspiracy, and racketeering activity by (among other things) providing the financial 
underpinnings for the venture. Deutsche Bank's conduct, as described below, was 
outrageous and intentional. After Deutsche Bank joined the venture and conspiracy, 
it became aware that Epstein venture and conspiracy had been on-going for many 
years and it adopted the goals and ratified the venture's and conspiracy's earlier 
actions, racketeering conduct, and crimes. 
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155. Deutsche Bank enabled Epstein to have ready and reliable access to 
resources—including cash—to recruit, solicit, entice, harbor, obtain, provide, and 
transport young women and girls (including Jane Doe 1) to cause them to engage in 
commercial sex acts. 
156. Deutsche Bank participated in Epstein's violations of the TWA by 
knowingly assisting, supporting, facilitating, and enabling Epstein's illegal sexual 
abuse and sex-trafficking venture, including in particular his coercive sex trafficking 
in violation of 18 U.S.C. § 1591(a)(I). 
157. Deutsche Bank's conduct knowingly and intentionally violated the 
TWA, which forbids benefitting financially from participating in a venture that, in 
or affecting interstate or foreign commerce, has recruited, solicited, enticed, 
transported, harbored, provided, or obtained a person knowing, or in reckless 
disregard of the fact, that the person has been caused to engage in a commercial sex 
act by means of force, threats of force, fraud, coercion, abuse of process, or a 
combination of such means. 
158. Deutsche Bank's actions knowingly and intentionally furthered the 
Epstein sex-trafficking venture, including specifically Epstein's sex trafficking. For 
example, Deutsche Bank provided cash to Epstein knowing that he would use the 
cash to pay for commercial sex acts—including sexualized massages during which 
Epstein penetrated Jane Doe 1—forcing all Jane Does to engage in sexual activity. 
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