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of force, threats of force, fraud, coercion, and a combination of such means to cause 
Jane Doe 1, as well as other Class Members, some of whom were under the age of 
eighteen, to engage in commercial sex acts. 
360. Deutsche Bank and its employees had actual knowledge that they were 
perpetrating and facilitating Epstein's sexual abuse and sex trafficking conspiracy to 
recruit, solicit, entice, coerce, harbor, transport, obtain, and provide Jane Doe 1 as 
well as other Members of the Class, into commercial sex acts, through the means of 
force, threats of force, fraud, abuse of process, and coercion. 
361. Despite such knowledge, Deutsche Bank intentionally paid for, 
facilitated, perpetrated, and participated in Epstein's violations of 18 U.S.C. § 
159I(a)(1), which Deutsche Bank knew, and were in reckless disregard of the fact 
that, Epstein would coerce, defraud, and force Jane Doe 1, as well as other Members 
of the Class, to engage in commercial sex acts. 
362. Deutsche Bank's actions were in and affecting interstate and foreign 
commerce, including its banking activities which were in and affecting interstate and 
foreign commerce. 
363. By taking the concrete steps alleged in this complaint, Deutsche Bank 
knowingly participated in sex trafficking and furthered the Epstein sex-trafficking 
venture. The concrete steps constituted taking part in the sex-trafficking venture and 
were necessary for its success. The concrete steps constituted active engagement by 
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Deutsche Bank in Epstein's sex-trafficking venture. Deutsche Bank knew that its 
active engagement would lead to and cause coercive commercial sex-trafficking. 
364. As part of perpetrating TVPA violations, between on or about August 
19, 2013, and through about July 2020, Deutsche Bank concealed its delivery of 
hundreds of thousands of dollars in cash to Epstein and his associates. 
365. As part of perpetrating TVPA violations, Deutsche Bank also willfully 
failed to file required SARs with the federal government. 
366. Deutsche Bank's affirmative conduct was committed knowing, and in 
reckless disregard of the facts, that Epstein would use cash and the financial support 
provided by Deutsche Bank as a means of defrauding, forcing, and coercing sex acts 
from Jane Doe 1 as well as other Members of the Class. Deutsche Bank's conduct 
was outrageous and intentional. 
367. Deutsche Bank's knowing and intentional conduct has caused Jane Doe 
I and the other Members of the Class serious harm including, without limitation, 
physical, psychological, emotional, financial, and reputational harm. 
368. Deutsche Bank's knowing and intentional conduct has caused Jane Doe 
1 and the other Members of the Class harm that is sufficiently serious, under all the 
surrounding circumstances, to compel a reasonable person of the same background 
and in the same circumstances to perform or to continue performing commercial 
sexual activity, in order to avoid incurring that harm. 
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369. This case does not involve mere fraud. Instead, Deutsche Bank's 
criminal conduct in perpetrating TVPA violations was outrageous and intentional, 
because it was in deliberate furtherance of a widespread and dangerous criminal sex 
trafficking organization. Deutsche Bank's criminal conduct also evinced a high 
degree of moral turpitude and demonstrated such wanton dishonesty as to imply a 
criminal indifference to civil obligations. Deutsche Bank's criminal conduct was 
directed specifically at Jane Doe 1 and other members of the Class, who were the 
victims of Epstein's sexual abuse and sex trafficking organization. 
370. Deutsche Bank's outrageous and intentional conduct in this case is part 
of a pattern and practice of Deutsche Bank profiting by undertaking illegal "high 
risk, high reward" clients. 
371. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 
1591(a)(1), 1595, Deutsche Bank is liable to Jane Doe 1 and the other Members of 
the Class for the damages they sustained and reasonable attorneys' fees. 
372. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 
1591(a)(1), 1595, Deutsche Bank is liable to Jane Doe 1 and other members of the 
Class for punitive damages. 
COUNT III 
AIDING, ABETTING, AND INDUCING A SEX-TRAFFICKING VENTURE 
IN VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, 
18 U.S.C. §§ 2,1591(a)(1) & (2), 1595 
373. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
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I — 314, as if fully set forth in this Count. 
374. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
375. Deutsche Bank aided, abetted, and induced Epstein's sex-trafficking 
venture that was in and affecting interstate and foreign commerce, together and with 
others, in violation of 18 U.S.C. §§ 2, 1591(a)(1) & (a)(2). 
376. The crimes that Deutsche Bank aided and abetted are (1) Epstein's 
perpetrating of coercive sex trafficking, in violation of 18 U.S.C. § 1591(a)(I), and 
(2) Epstein's co-conspirators' knowingly benefitting from coercive sex trafficking, 
in violation of 18 U.S.C. § 1591(a)(2). These crimes were in and affecting interstate 
and foreign commerce. 
377. Epstein's co-conspirators benefitted financially and received things of 
value from their participation in the Epstein sex-trafficking venture, including 
payments and other compensation from Epstein. The co-conspirators who benefitted 
financially include Attorney-1, Accountant 1, Ghislaine Maxwell, Lesley Groff, 
Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 
378. Under 18 U.S.C. § 2, Deutsche Bank is punishable as a principal under 
18 U.S.C. §§ 1591(a)(1) & (a)(2) and thereby committed and perpetrated violations 
of Chapter 77, Title 18, U.S. Code, when it aided, abetted, counseled, commanded, 
induced, and procured Epstein's and his co-conspirators sex-trafficking venture and 
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sex trafficking of Jane Doe 1, as well as other Class Members. 
379. Under 18 U.S.C. § 2, Deutsche Bank committed and perpetrated crimes 
in violation of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, inducing and 
procuring Epstein's and his co-conspirator's sex-trafficking venture and the sex 
trafficking of Jane Doe 1, as well as of other Class Members. As a consequence, 
Jane Doe 1, as well as other members of the Class, are victims of Deutsche Bank's 
criminally aiding, abetting, and inducing Epstein's and his co-conspirators' 
violations of 18 U.S.C. §§ 1591(a)(1) & (a)(2). 
380. Deutsche Bank itself directly committed and perpetrated violations of 
Chapter 77, Title 18, U.S. Code, including 18 U.S.C. §§ 1591(a)(1) & (a)(2), by 
aiding, abetting, and inducing the sex-trafficking venture and the sex trafficking of 
Jane Doe 1, as well as other Class Members. Deutsche Bank itself directly violated 
Chapter 77 by committing and perpetrating these violations. 
381. Among other things, Deutsche Bank aided, abetted, and induced 
Epstein's and his co-conspirators' sex-trafficking venture and sex trafficking of Jane 
Doe 1, as well as other Class Members, knowing that Epstein and his-conspirators 
would use means of force, threats of force, fraud, coercion, and a combination of 
such means to cause Jane Doe 1, as well as other Class Members, some of whom 
were under the age of eighteen, to engage in commercial sex acts. 
382. By aiding, abetting, and inducing Epstein's and his co-conspirators' 
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sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class 
Members, Deutsche Bank knowingly benefited, both financially and by receiving 
things of value, from participating in Epstein's sex-trafficking venture. 
383. Deutsche Bank and its employees had actual knowledge that they were 
aiding, abetting, and inducing Epstein's and his co-conspirators' sexual abuse and 
sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain, 
and provide Jane Doe 1 as well as other Members of the Class, into commercial sex 
acts, through the means of force, threats of force, fraud, abuse of process, and 
coercion. Deutsche Bank knew, and should have known, that Epstein had engaged 
in acts in violation of the TVPA. 
384. Despite such knowledge, Deutsche Bank intentionally paid for and 
aided, abetted, and induced Epstein's violations of 18 U.S.C. §§ 1591(a)(1) & (a)(2), 
which constituted perpetrating violations of those laws under 18 U.S.C. § 2. 
Deutsche Bank knew, and acted in reckless disregard of the fact that, Epstein would 
coerce, defraud, and force Jane Doe 1, as well as other Members of the Class, to 
engage in commercial sex acts. 
385. Deutsche Bank's affirmative conduct of aiding, abetting, and inducing 
Epstein's violations was committed knowingly, and in reckless disregard of the 
facts, that Epstein would use cash and financial supported provided by Deutsche 
Bank as a means of defrauding, forcing, and coercing sex acts from Jane Doe I as 
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well as other Members of the Class. Deutsche Bank's conduct was outrageous and 
intentional. 
386. Deutsche Bank's knowing and intentional conduct of aiding, abetting, 
and inducing Epstein's violations has caused Jane Doe 1 and the other members of 
the Class serious harm including, without limitation, physical, psychological, 
emotional, financial, and reputational harm. 
387. Deutsche Bank's knowing and intentional conduct of aiding, abetting, 
and inducing Epstein's violations has caused Jane Doe 1 and the other members of 
the Class harm that is sufficiently serious, under all the surrounding circumstances, 
to compel a reasonable person of the same background and in the same 
circumstances to perform or to continue performing commercial sexual activity, in 
order to avoid incurring that harm. 
388. This case does not involve mere fraud. Instead, Defendants' criminal 
conduct in aiding, abetting, and inducing Epstein's violations of the TVPA was 
outrageous and intentional, because it was in deliberate furtherance of a widespread 
and dangerous criminal sex trafficking organization. Deutsche Bank's criminal 
conduct also evinced a high degree of moral turpitude and demonstrated such wanton 
dishonesty as to imply a criminal indifference to civil obligations. Deutsche Bank's 
criminal conduct was directed specifically at Jane Doe 1 and other members of the 
Class, who were the victims of Epstein's sexual abuse and sex trafficking 
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organization. 
389. Deutsche Bank's outrageous and intentional conduct in this case is part 
of a pattern and practice of Deutsche Bank profiting by undertaking illegal "high 
risk, high reward" clients. 
390. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 
1591(a)(1), 1595, Deutsche Bank is liable to Jane Doe 1 and the other members of 
the Class for the damages they sustained and reasonable attorneys' fees. 
391. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 
1591(a)(1), 1595, Deutsche Bank is liable to Jane Doe 1 and other members of the 
Class for punitive damages. 
COUNT IV 
CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING 
VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c), 1591, 1595 
392. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
393. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
394. Deutsche Bank intentionally conspired with others, by agreement and 
understanding, to violate 18 U.S.C. § 1591(a)(1) & (a)(2) & 1591(d), and to further 
Epstein's and his co-conspirators' sex-trafficking venture to coerce commercial sex 
acts from Jane Doe 1 and other Class Members, all in violation of 18 U.S.C. § 
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1594(c). Deutsche Bank employees directly conspired with Epstein himself to 
further the sex trafficking venture. 
395. Deutsche Bank's conspiracy to violate 18 U.S.C. 1591(a)(1) & (a)(2) 
was forbidden by 18 U.S.C. § 1594(c), and Deutsche Bank thereby violated Chapter 
77, Title 18. Deutsche Bank's conspiracy directly, proximately, and foreseeably 
harmed Jane Doe 1, as well as other members of the Class, by directly leading to 
their forcibly being caused to engage in commercial sex acts and in other ways. 
Deutsche Bank's conspiracy victimized Jane Doe I and the other members of the 
Class. 
396. Deutsche Bank's conspiracy to violate 18 U.S.C. 1591(d) was 
forbidden by 18 U.S.C. § 1594(c), and Deutsche Bank thereby violated Chapter 77, 
Title 18. Deutsche Bank's conspiracy directly, proximately, and foreseeably harmed 
Jane Doe 1, as well as other members of the Class, by directly leading to their 
forcibly being caused to engage in commercial sex acts and in other ways. Deutsche 
Bank's conspiracy victimized Jane Doe I and the other Members of the Class. 
397. Deutsche Bank conspired with Epstein and his co-conspirators to 
further the Epstein sex-trafficking venture and with the purpose of facilitating 
Epstein's illegal sex trafficking. Deutsche Bank had actual knowledge of Epstein's 
sex-trafficking venture. Deutsche Bank acted with the specific intent to violate 18 
U.S.C. §§ 1591(a)(1) & (a)(2), that is, with consciousness of the nature of Epstein's 
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sex-trafficking venture and with the specific intent to further venture. Deutsche 
Bank and Epstein had a meeting of the minds as to the essential nature of the plan. 
398. The Epstein sex-trafficking conspirators had a shared and common 
purpose-securing young women and girls for Epstein to sexually abuse and to 
commercially sex traffic. Deutsche Bank and other members of the Enterprise 
associated together for this common purpose. As quid pro quo, in exchange for 
working toward this common purpose, Epstein rewarded Deutsche Bank. 
399. The Epstein sex-trafficking conspiracy was an ongoing organization 
with the same hierarchy and regularity of function. Epstein was at the top of the 
hierarchy and effectively served as the CEO of the organization. Deutsche Bank 
served as the bank for the conspiracy after around August 19, 2013. Before that time, 
JP Morgan had served as the bank for the conspiracy. The sex-trafficking conspiracy 
was itself in and affecting interstate and foreign commerce and involved overt acts 
that were in and affecting interstate and foreign commerce. 
400. In and around August 19, 2013, Deutsche Bank purposefully joined 
Epstein's previously operation, and on-going, sex-trafficking conspiracy. It quickly 
ratified the previous (from 2005 onward) actions, conduct, intentional torts, and 
crimes of the conspiracy, by joining the conspiracy, adopting its goals, and taking 
actions and committing overt acts in furtherance of it. 
401. Deutsche Bank's conspiracy with Epstein was part of its participation 
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in his sex-trafficking venture. Without Deutsche Bank agreeing to facilitate the 
venture (by, for example, conspiring to keep the existence of cash disbursals secret), 
Epstein would not have been a position to move forward with his sex-trafficking 
venture. 
402. Deutsche Bank also conspired with Epstein to obstruct, attempt to 
obstruct, to interfere with, and to prevent the enforcement of the TVPA, violating 18 
U.S.C. § 1591(d). The conspiracy included an agreement to keep Epstein's sex-
trafficking venture secret or, at least, concealed to the greatest extent possible. 
Among the means for keeping the venture secret were paying for the commercial 
sex acts in cash, structuring cash withdrawals in a way to avoid detection, and 
Deutsche Bank's failing to timely file SARs of Epstein's suspicious activities. 
403. Further actions regarding Deutsche Bank's conspiracy to obstruct 
TVPA enforcement are outlined in Count VI (obstruction) below in paragraphs 445-
59, which are hereby incorporated by reference as if set forth in full in this Count. 
404. Within this District, Deutsche Bank intentionally committed overt acts 
in furtherance of the conspiracy, agreement, and understanding to violate 18 U.S.C. 
§ 1591(a) by knowingly playing an active role in assisting, supporting, and 
facilitating the recruiting, enticing, coercing, harboring, transporting, and inducing 
and forcibly causing Jane Doe 1 and other Class Members to engage in commercial 
sex acts, through providing financial support for the Epstein sex-trafficking venture. 
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405. Among the many overt acts intentionally committed by Deutsche Bank 
in furtherance of the long-running Epstein sex-trafficking venture were creating and 
maintaining a special and unusual financial relationship between Deutsche Bank and 
Epstein within this District designed to facilitate Epstein's sex-trafficking. 
406. Acting within this District and in furtherance of the Epstein sex-
trafficking venture, on or about August 19, 2013, Deutsche Bank opened brokerage 
accounts for Southern Trust Company Inc., an Epstein-related company. Deutsche 
Bank knew, and should have known, that opening this account would facilitate 
Epstein's sex trafficking. 
407. In furtherance of the Epstein sex-trafficking venture, between on or 
about August 19, 2013, and through about 2018, Deutsche Bank opened about 40 
accounts for Epstein, his related entities, and associates. The accounts were in and 
affecting interstate and foreign commerce. The accounts were opened within this 
District. 
408. In furtherance of the Epstein sex-trafficking venture, between on or 
about August 19, 2013, and through about July 2020, Deutsche Bank concealed its 
delivery of hundreds of thousands of dollars in cash to Epstein and his associates. 
Among its affirmative acts of concealment, Deutsche Bank willfully failed to timely 
file required SARs with the federal government. 
409. Deutsche Bank's continued to participate in the conspiracy through 
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about July 2020, when it entered into a consent decree with New York banking 
regulators and admitted some of its actions. 
410. Deutsche Bank deliberately and purposely omitted to timely file 
appropriate SARs about Epstein's cash transactions, wrongful omissions that were 
actions in furtherance of its conspiracy. 
411. Deutsche Bank also deliberately concealed its knowledge about how JP 
Morgan had previously acted in furtherance in the Epstein's conspiracy. 
412. Deutsche Bank's actions in furtherance of Epstein's conspiracy were 
intertwined with Epstein's sex-trafficking venture, as the funding for the sex-
trafficking venture (and particularly cash for the venture) were essential tools for 
Epstein to commit coercive commercial sex acts. 
413. It was part of the conspiracy that Deutsche Bank would financially 
benefit from providing financial support for the Epstein sex-trafficking venture. 
Deutsche Bank did financially benefit from its participation in the venture, including 
receiving valuable deposits from Epstein and Epstein-related entities into Deutsche 
Bank. 
414. Deutsche Bank's participation in furthering Epstein's sex-trafficking 
venture was intentional and willful and, therefore, Deutsche Bank intentionally and 
willfully caused Epstein's commission of the forcible commercial sex acts with Jane 
Doe 1 and other Class Members through its affirmative and overt acts supporting 
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Epstein. 
415. Deutsche Bank knew, acted in reckless disregard of the fact, and should 
have known, that its conspiracy would directly and proximately lead to unlawful 
coercive commercial sex acts by Epstein with young women and girls, including 
Jane Doe 1 and other Class Members. 
416. The conspiracy that Deutsche Bank joined had specific knowledge that 
Jane Doe I, as well as other Members of the Class, were being coercively sex 
trafficked by Epstein. The conspiracy's knowledge extended to the names of 
Epstein's victims, because Epstein and his co-conspirators knew the names of the 
victims, including Jane Doe I's name. 
417. Deutsche Bank conspired to violate 18 U.S.C. § 1591(a) with Epstein 
and through its affirmative acts and substantial support to Epstein committed, 
perpetrated, and directly and proximately caused Jane Doe 1 and other Class 
Members to engage in commercial sex acts through means of force, threats of force, 
fraud, coercion, and a combination of such means. 
418. In addition to acting with knowledge that they were conspiring to 
support the Epstein sex-trafficking venture, Deutsche Bank benefited financially 
from conspiring to participate in the Epstein sex-trafficking venture, which Deutsche 
Bank knew and should have known that had engaged in coercive sex trafficking in 
violation of 18 U.S.C. § 1591(a)(1) & (a)(2). 
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419. Deutsche Bank's conspiracy has caused Jane Doe 1 and other Class 
Members serious harm, including, without limitation, physical, psychological, 
financial, and reputational harm. That harm was directly and proximately caused by 
the conspiracy and the harm resulting from conspiracy was foreseeable. 
420. Deutsche Bank's conspiracy has caused Jane Doe I harm that is 
sufficiently serious, under all the surrounding circumstances, to compel a reasonable 
person of the same background and in the same circumstances to perform or to 
continue performing commercial sexual activity in order to avoid incurring that 
harm. 
421. This case does not involve mere fraud. Instead, Deutsche Bank's 
criminal conduct in conspiring to violate the TVPA was outrageous and intentional, 
because it was in deliberate furtherance of a widespread and dangerous criminal sex 
trafficking organization. Deutsche Bank's conspiracy also evinced a high degree of 
moral turpitude and demonstrated such wanton dishonesty as to imply a criminal 
indifference to civil obligations. 
Deutsche Bank's conspiracy was directed 
specifically at Jane Doe 1 and other Class Members, who were the victims of 
Epstein's sex trafficking organization. 
422. By virtue of these violations of 18 U.S.C. §§ 1594(c), 1595, Deutsche 
Bank is liable to Jane Doe 1 and the other Class Members for the damages they 
sustained and reasonable attorneys' fees. 
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423. By virtue of its intentional and outrageous conspiracy to violate 18 
U.S.C. §§ 1594(c), 1595, Deutsche Bank is liable to Jane Doe 1 and other Class 
Member for punitive damages. 
COUNT V 
AT TE M PT TO COMMIT VIOLATIONS OF THE TRAFFICKING VICTIM 
PROTECTION ACT, 18 U.S.C. §§ 1594(a), 1591, 1595 
424. Plain t i ffJane Doe 1 realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
425. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
426. Deutsche Bank intentionally attempted to violate 18 U.S.C. § 
1591(a)(1) & (a)(2), and to further Epstein's sex-trafficking venture to coerce 
commercial sex acts from Jane Doe 1 and other Class Members, all in violation of 
18 U.S.C. § 1594(a). 
427. Deutsche Bank employees deliberately took substantial steps to attempt 
to violate 18 U.S.C. § 1591(a)(1) & (a)(2) within this District, from around 2013 
through around July 2020. 
428. Deutsche Bank deliberately took substantial steps toward attempting to 
violate 18 U.S.C. § 1591(a), by providing substantial financial support for the 
Epstein sex-trafficking venture. The financial support included hundreds of 
thousands of dollars in cash. This support was in and affecting interstate and foreign 
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commerce. 
429. Among the many substantial steps taken by Deutsche Bank to 
deliberately attempt to violate 18 U.S.C. § 1591(a) were creating a special and 
unusual financial relationship between Deutsche Bank and Epstein within this 
District that was designed to, and did, facilitate Epstein's sex-trafficking venture and 
the sex trafficking of Jane Doe 1, as well as other Members of the Class. 
430. Acting within this District and in attempting to further the Epstein sex-
trafficking venture, on or about August 19, 2013, Deutsche Bank opened brokerage 
accounts for Southern Trust Company Inc., an Epstein-related company. These 
accounts were in and affecting interstate and foreign commerce. 
431. In attempting to further the Epstein sex-trafficking venture, between on 
or about August 19, 2013, and through about 2018, Deutsche Bank opened about 40 
accounts for Epstein, his related entities, and associates. The accounts were in and 
affecting interstate and foreign commerce. Deutsche Bank opened the accounts 
within this District for the purpose of facilitating Epstein's sex-trafficking venture. 
432. In opening 40 accounts for Epstein, his related entities, and associates, 
Deutsche Bank took a substantial step toward benefitting from participating in 
Epstein's sex-trafficking venture. Deutsche Bank also took other substantial, 
concrete steps toward benefits from the venture. 
433. It was part of the attempt to violate 18 U.S.C. 1591(a) that Deutsche 
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Bank would financially benefit from providing financial support for the Epstein sex-
trafficking venture. Deutsche Bank did financially benefit from its participation in 
the venture, including receiving valuable deposits from Epstein and Epstein-related 
entities into Deutsche Bank. 
434. Deutsche Bank's attempt to violate the TVPA by furthering Epstein's 
sex-trafficking venture was intentional and willful and, therefore, Deutsche Bank 
intentionally and willfully caused Epstein's commission of sexual abuse and 
commercial sex acts with Jane Doe I and other Class Members through its 
affirmative and overt acts supporting Epstein. 
435. Deutsche Bank knew and acted in reckless disregard of the fact, that its 
acts and conduct attempting to support and facilitate Epstein would lead to sexual 
abuse and unlawful coercive commercial sex acts by Epstein with young women and 
girls, including Jane Doe 1 and other Class Members. 
436. In addition to acting intentionally and with knowledge that they were 
supporting the Epstein sex-trafficking venture, Deutsche Bank benefited financially 
from attempting to participate in the Epstein sex-trafficking venture which Deutsche 
Bank should have known that had engaged in coercive sex trafficking in violation of 
18 U.S.C. § 1591(a)(1). 
437. This case does not involve mere fraud. Instead, Defendants' criminal 
conduct in attempting to violate the TVPA was outrageous and intentional, because 
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it was a deliberate attempt to further the crimes of a widespread and dangerous 
criminal sex trafficking organization. Deutsche Bank's criminal attempts also 
evinced a high degree of moral turpitude and demonstrated such wanton dishonesty 
as to imply a criminal indifference to civil obligations. Deutsche Bank's criminal 
attempt was directed specifically at Jane Doe 1 and other members of the Class, who 
were the victims of Epstein's sex trafficking organization. 
438. Deutsche Bank's conduct has caused Jane Doe 1 and other Class 
Members serious harm, including, without limitation, physical, psychological, 
financial, and reputational harm. This harm was a direct, proximate, and foreseeable 
result of Deutsche Bank's attempt in violation of 18 U.S.C. § 1594(a). 
439. By virtue of these violations of 18 U.S.C. §§ 1594(a), 1595(a), 
Deutsche Bank is liable to Jane Doe 1 and the other Members of the Class for the 
damages they sustained and reasonable attorneys' fees. 
440. By virtue of its intentional and outrageous attempt to violate 18 U.S.C. 
§§ 1594(a), 1595, Deutsche Bank is liable to Jane Doe 1 and other members of the 
Class for punitive damages. 
COUNT VI 
OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING 
VICTIM PROTECTION ACT, 18 U.S.C. § 1591(d) 
441. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
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442. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
443. Deutsche Bank and its employees knowingly and intentionally 
obstructed, attempted to obstruct, interfered with, and prevented the enforcement of 
18 U.S.C. §§ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § 1591(d). This 
activity is hereinafter referred to collectively simply as "obstruction." 
The 
obstruction occurred from around 2013 to around July 2020. 
444. Deutsche Bank's obstruction of the enforcement of 18 U.S.C. §§ 
1591(a)(1) and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and Deutsche Bank 
thereby violated Chapter 77, Title 18. Deutsche Bank's obstruction described in the 
preceding paragraph directly, proximately, and foreseeably harmed Jane Doe I, as 
well as other members of the Class, by directly resulting in them coercively being 
caused to engage in commercial sex acts and in other ways. These actions were in 
and affecting interstate and foreign commerce, including the substantial sums of 
currency which affected interstate and foreign commerce. 
445. As alleged in the fact section of this Complaint, the United States 
Department of Justice (including the U.S. Attorney's Office for the Southern District 
of New York and the U.S. Attorney's Office for the Southern District of Florida) 
was investigating Epstein's federal criminal liability for violating (among other 
laws) the TVPA up to and following the return of an indictment against Epstein on 
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