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supporting and participating in the Epstein Sex-Trafficking Enterprise. 
513. Deutsche Bank and its employees participated directly and indirectly in 
the conduct of the Epstein Sex-Trafficking Enterprise, through a pattern of 
racketeering activity, including knowingly funding the Enterprise's commercial sex 
trafficking. 
514. Deutsche Bank's RICO violations are both the but-for cause and the 
proximate cause of business and property injuries to Jane Doe 1 and the Class 
Members' injuries. As explained throughout, Deutsche Bank bankrolled the Epstein 
Sex-Trafficking Enterprise and enabled Epstein to have ready and reliable access to 
resources—including cash and a variety of bank accounts and other financial tools—
to recruit, entice, solicit, harbor, provide, obtain, and transport young women and 
girls to sexually abuse them and to cause them to engage in commercial sex acts. 
Deutsche Bank's actions both directly and foreseeably resulted in the trafficking of 
Jane Doe 1 and the Class Members and the resulting injuries to their businesses and 
property. 
515. Pursuant to 18 U.S.C. § 1964(c), Jane Doe 1 and the Class Members 
are entitled to treble damages, plus costs and attorneys' fees from Deutsche Bank. 
COUNT VIII 
CONSPIRACY TO COMMIT VIOLATIONS OF RICO, 18 U.S.C. §§ 
1962(d), 1964(c) 
516. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
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1 — 314, as if fully set forth in this Count. 
517. In this RICO conspiracy count, Jane Doe 1 realleges and incorporates 
by reference paragraphs 470 — 514 of this complaint, which allege a substantive 
RICO violation. 
518. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
519. RICO makes it unlawful "for any person to conspire to violate" the 
provisions of 18 U.S.C. § 1962(a)—(c). 18 U.S.C. § 1962(d). RICO's conspiracy 
provision does not require the commission of an overt act, although Deutsche Bank 
did commit overt acts in furtherance of the RICO conspiracy in this District. 
520. Between about August 2013 and about July 2020, Deutsche Bank 
unlawfully, knowingly, and willfully, combined, conspired, confederated, and 
agreed together with members of the Epstein Sex-Trafficking Enterprise to violate 
18 U.S.C. § 1962(c) as described above, in violation of 18 U.S.C. § 1962(d). 
Deutsche Bank specifically conspired and agreed to the commission of two or more 
predicate acts, which were described in the previous Count. For example, Deutsche 
Bank conspired and agreed that Epstein would commit multiple acts of coercive sex 
trafficking in violation of the TWA, 18 U.S.C. §§ 1591-94. As another example, 
Deutsche Bank conspired and agreed that it would commit multiple violations of 
federal banking laws, including 31 U.S.C. § 5332(a) and 31 C.F.R. § 1010.620. 
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521. In addition to participating in the conduct of the affairs of the Epstein 
Sex-Trafficking Venture, Deutsche Bank conspired with Epstein in his conduct of 
the affairs of the Epstein Sex-Trafficking Venture. Deutsche Bank knew many of 
the details of the Epstein Sex-Trafficking Venture, including in particular the 
funding of the venture. Epstein was, along with others (including Deutsche Bank) 
operating and managing the Epstein-Sex Trafficking Venture. 
522. Deutsche Bank's conspiracy was central to the affairs of the Epstein-
Sex Trafficking Venture. Without its agreement to fund and conceal the activities 
of the Venture, Epstein would not have been able to move forward with the Venture. 
523. Deutsche Bank knew that, as part of the Epstein Sex-Trafficking 
Venture, Epstein was going to commit multiple predicate acts under RICO, 
including coercive commercial sex acts and sex trafficking. Deutsche Bank also 
new that these acts would constitute a pattern and practice of the venture, because 
the coercive commercial sex acts and sex trafficking would be committed against 
Jane Doe 1 and the Class Members in a substantially similar way. 
524. By and through Deutsche Bank's unique and special relationships with 
Epstein and his co-conspirators and its close coordination in the affairs of the Epstein 
Sex-Trafficking Enterprise, Deutsche Bank knew the criminal nature of the 
Enterprise and knew that the Enterprise extended beyond Deutsche Bank's role. 
Moreover, through the same connections and coordination, Deutsche Bank knew 
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that it was joining with Epstein and his associates in a conspiracy to commit sex 
trafficking, in violation of 18 U.S.C. §§ 1581-94. 
525. Deutsche Bank knowingly conspired and agreed to facilitate, conduct, 
and participate in the aforementioned Enterprise engaged in racketeering activity 
within the meaning of RICO, 18 U.S.C. §1961(1)(B), when it engaged in acts 
"indictable under" 18 U.S.C. §§ 1581-1594 (the statutes relating to peonage, 
slavery, and trafficking in persons), including the acts in violation of 18 U.S.C. § 
1591-94 alleged in Counts I-VI and otherwise specified throughout this complaint, 
as well as acts in violation of 18 U.S.C. § 2. 
526. Deutsche Bank knowingly conspired and agreed to facilitate, conduct, 
and participate in the aforementioned Enterprise engaged in racketeering activity 
within the meaning of RICO, 18 U.S.C. §1961(1)(B), when it engaged in acts 
"indictable under" 31 U.S.C. § 5322(a). 
527. Deutsche Bank also committed multiple crimes in furtherance of the 
conspiracy, as alleged in the preceding counts of this Complaint. Deutsche Bank 
intended its crimes to further the Enterprise's affairs. 
528. Deutsche Bank's agreement and conspiracy was necessary to allow the 
commission of this conspiracy. 
529. Jane Doe 1 and the Class Members have been and will continue to be 
directly and proximately injured in their business and property by reason of Deutsche 
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Bank's violations of 18 U.S.C. § 1962(d). Deutsche Bank's conspiracy directly and 
proximately caused these injuries because, without the conspiracy, the injuries 
would not have occurred. 
530. As a direct and proximate result of its violation of 18 U.S.C. § 1962(d), 
Deutsche Bank has directly and proximately caused Jane Doe 1 and the Class 
Members serious and permanent economic injury to their businesses and/or 
property, including, without limitation, pecuniary harm to their careers and 
professional prospects, in an amount to be determined at trial. Deutsche Bank's 
violations continue to cause economic harm and injury to Jane Doe 1 and other 
Members of the Class. 
531. Pursuant to 18 U.S.C. § 1964(c), Jane Doe 1 and the Class Members 
are entitled to treble damages, plus costs and attorneys' fees from Deutsche Bank. 
COUNT IX 
AIDING, ABETTING, AND FACILITATING BATTERY 
532. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 — 314, 
as if fully set forth in this Count. 
533. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
534. Between about August 19, 2013, and August 10, 2019, in this District 
in New York, Epstein intentionally committed batteries and other intentional tortious 
conduct, including crimes in violation of New York Penal Law Chapter 130 such as 
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New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66 (hereinafter 
"Chapter 130 crimes"), against Jane Doe 1 and Class Members. Epstein committed 
the batteries, intentional tortious conduct, and crimes against Jane Doe 1 and Class 
Members when they were 18 or older. As described throughout this complaint, 
Epstein intentionally and non-consensually touched Jane Doe 1 and the Class 
Members in a harmful and offensive manner that resulted in substantial injuries, 
including damages from physical and psychological injury, extreme emotional 
distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and 
invasion of privacy. 
535. The resulting injuries that Jane Doe 1 and the Class Members suffered 
include injuries directly and proximately suffered as a result of sex offenses 
committed by Epstein and criminalized under article 130 of the New York Penal 
Laws. The offenses included sexual intercourse without consent and oral sexual 
conduct without consent, forbidden by New York Penal Law § 130.20. The offenses 
included forcible touching of sexual or other intimate parts without consent, 
forbidden by New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66. 
536. Regardless of when these Chapter 130 crimes were committed by 
Epstein, the crimes are now civilly actionable, regardless of any statute of limitations 
to the contrary, because they are covered by the one-year "look back" window in 
New York Adult Survivors Act. See N.Y. C.P.L.R. § 214-j. 
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537. Between about August 19, 2013, and August 10, 2019, Deutsche Bank 
knowingly and intentionally aided, abetted, and facilitated Epstein's intentional 
tortious conduct (e.g., sexual battery), through his Chapter 130 crimes, of Jane Doe 
1 and the Class Members. Because Deutsche Bank aided, abetted, and facilitated 
Epstein's tortious conduct, battery, and crimes, it is vicariously and otherwise liable 
for damages caused by Epstein's tortious conduct, battery, and crimes. 
538. Between about August 19, 2013, and August 10, 2019, when it provided 
substantial assistance to Epstein, Deutsche Bank was well aware of its important and 
substantial role as a part of Epstein's intentionally tortious and illegal activity in 
committing Chapter 130 Crimes. 
539. Deutsche Bank substantially assisted, and indeed encouraged, Epstein 
to commit sexual battery against Jane Doe 1 and the Class Members by financially 
aiding and enabling Epstein's sex-trafficking venture, as outlined throughout this 
complaint. By aiding Epstein through providing hundreds of thousands of dollars in 
cash, which was a necessary and required part of Epstein's sex-trafficking 
organization, Deutsche Bank was a substantial factor in the battery of Jane Doe 1 
and the other Members of the Class. 
540. At the time of Epstein's batteries, intentionally tortious conduct, and 
crimes against Jane Doe 1 and the Class Members, Deutsche Bank was well aware 
of Epstein's sex-trafficking venture and that its acts in furtherance of the venture 
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were also aiding, abetting and facilitating his batteries, tortious conduct, and crimes. 
541. At the time of Epstein's crimes against Jane Doe I and the Class 
Members, Deutsche Bank knowingly provided substantial assistance in Epstein's 
tortious conduct. That knowing substantial assistance went beyond mere knowledge 
and approval of Epstein's wrongdoing. For example, Deutsche Bank knowingly and 
intentionally provided the cash and the financial support that made it possible for 
Epstein to commit the coercive sex offenses described in the preceding paragraphs 
in this Count. Without that cash and financial support, Epstein could not have 
committed his tortuous conduct and crimes—a fact that Deutsche Bank knew. 
542. Deutsche Bank knowingly committed both overt acts in support of 
Epstein and substantial deliberate omissions in support of Epstein. For example, 
Deutsche Bank deliberately omitted to take important steps (such as filing SAlts) 
that substantially assisted Epstein to commit his crimes against Jane Doe 1 and Class 
Members in violation of New York Penal Law Chapter 130. 
543. In aiding, abetting, and facilitating Epstein's tortious conduct and 
crimes, Deutsche Bank could readily foresee direct and proximate injury to Jane Doe 
1 and the Class Member. Deutsche Bank should have foreseen direct and proximate 
injury from its actions and inactions to Jane Doe and the Class Members. Indeed, 
Deutsche Bank did foresee injury to Epstein's victims, including Jane Doe 1 and 
Class Members. 
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544. As a result of the foregoing, Deutsche Bank is liable civilly for damages 
it directly, proximately, tortiously, and criminally caused to Jane Doe 1 and the Class 
Members. Jane Doe I and the Class Members according are entitled to bring a cause 
of action for damages for physical, psychological, or other injury or condition 
suffered as a direct and proximate result of Deutsche Bank's aiding and abetting 
Epstein's battery described above and for damages for physical, psychological, or 
other injury or condition suffered as a direct and proximate result of Epstein's 
battery. 
545. By virtue of acting intentionally, outrageously, and with a high degree 
of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal 
indifference to civil obligations, Deutsche Bank is liable to Jane Doe 1 and other 
Members of the Class for punitive damages. 
COUNT X 
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 
546. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 — 314, 
as if fully set forth in this Count. 
547. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
548. As a direct and proximate result of aiding, abetting, and facilitating 
Epstein's tortious conduct and sex crimes in violation of Chapter 130, Deutsche 
Bank intentionally inflicted emotional distress against Jane Doe 1 and the Class 
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Members. 
549. Deutsche Bank's actions constitute extreme and outrageous conduct 
that shocks the conscience. 
For example, Deutsche Bank intentionally and 
knowingly participated in Epstein's sex-trafficking venture. Deutsche Bank had a 
legal duty not to participate in, facilitate, or aid and abet Epstein's sex-trafficking 
venture and Epstein's Chapter 130 Crimes. 
550. Deutsche Bank's conduct was especially extreme and outrageous due 
to Jane Doe I and the Class Members' particular vulnerabilities as targets of a sex-
trafficking venture. 
551. Deutsche Bank intended to cause, and did cause, Jane Doe 1 and the 
Class Members severe emotional distress. At the very least, Deutsche Bank 
recklessly disregarded a substantial probability that its actions in aiding, abetting, 
and facilitating Epstein's sex crimes would cause Jane Doe 1 and the Class Members 
severe emotional distress. 
552. Because Deutsche Bank intentionally inflicted extreme emotional 
distress on Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the 
Class Members for damages they suffered as a direct and proximate result. 
553. As a direct and proximate result of Deutsche Bank's conduct, Jane Doe 
1 and the Class Members have in the past and will in the future continue to suffer 
substantial damages from psychological and physical injury, including extreme 
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emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-
esteem, and invasion of privacy. Deutsche Bank's aiding, abetting, and facilitating 
Epstein's sex crimes in violation of Chapter 130 directly and proximately caused 
Epstein's sex crimes. 
554. By virtue of acting intentionally, outrageously, and with a high degree 
of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal 
indifference to civil obligations, Deutsche Bank is liable to Jane Doe 1 and other 
Members of the Class for punitive damages. 
COUNT XI 
NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE TO 
PREVENT PHYSICAL HARM 
555. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
556. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
557. In addition to any duties that might arise as a financial institution (as 
alleged in the next Count, below), Deutsche Bank owed a duty to Jane Doe 1 and the 
Class Members to exercise reasonable care to avoid conduct that created a risk of 
physical harm to them. Deutsche Bank's duties included a duty to exercise 
reasonable care to avoid conduct that would combine with Epstein's (and others') 
crimes, and permit Epstein's crimes, in violation of Chapter 130. 
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558. Deutsche Bank's own conduct in providing financial and other support 
for Epstein's sex trafficking venture set forces in motion that directly and 
proximately injured and caused physical harm to Jane Doe 1 and the Class Members. 
These forces that Deutsche Bank set in motion caused Epstein's intentional tortious 
conduct and Chapter 130 Crimes against Jane Doe 1 and the Class Members, causing 
physical harm and in themselves constituted physical harm to Jane Doe 1 and the 
Class Members. Deutsche Bank owed Jane Doe 1 and the Class Members a duty not 
to set those forces in motion because they unreasonably created a risk of physical 
harm. 
559. Deutsche Bank reasonably could foresee, and did in fact foresee, that 
its negligent failure to prevent physical harm would result in physical harm to Jane 
Doe I and the Class Members. Deutsche Bank owed a duty to prevent that physical 
harm. 
560. Deutsche Bank failed to act objectively reasonably in failing to take 
precautions to prevent Epstein's intentional tortious conduct and sex-trafficking and 
sex crimes in violation of Chapter 130, which were committed against Jane Doe 1 
and the Class Members. If Deutsche Bank had acted reasonably to prevent physical 
harm, it would not have supported and allowed Epstein's sex-trafficking and sex 
crimes to occur. Deutsche Bank owed Jane Doe 1 and the Class members a duty to 
act objectively reasonably. 
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561. At the time of Deutsche Bank's own negligent conduct, Deutsche Bank 
both realized and should have realized the likelihood that it was creating an 
opportunity for Epstein to commit intentional tortious conduct and Chapter 130 
Crimes against Jane Doe 1 and the Class Members. Indeed, Deutsche Bank knew 
that its own conduct was necessary to create Epstein's and others' opportunities to 
engage in that conduct and commit those crimes. Deutsche Bank owed Jane Doe 1 
and the Class Members a duty not to create those opportunities for Epstein and 
others. 
562. In aiding, abetting, and facilitating Epstein's tortious conduct and 
crimes, Deutsche Bank committed intentional torts directed against Jane Doe 1 and 
the Class Members. Deutsche Bank's aiding, abetting, and facilitating Epstein's 
tortious conduct and crimes were its own wrongful acts and omissions. Deutsche 
Bank had a duty not to commit tortious conduct and crimes—specifically aiding, 
abetting, and facilitating New York sex crimes as described above— directed against 
Jane 1 and the Class Members. 
563. Deutsche Bank's breaches of its legal duties were the direct—Le., the 
but-for—cause of physical and psychological injuries to Jane Doe 1 and the Class 
Members. Without Deutsche Bank's breaches of legal duties, those injuries would 
not have occurred. The injuries that occurred were readily foreseeable to Deutsche 
Bank and proximately caused by Deutsche Bank's breaches. 
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564. Jane Doe 1 and the Class Members were easily within the zone of 
foreseeable harm from the Deutsche Bank's negligent acts and omissions. Deutsche 
Bank's negligent acts and omissions foreseeably created substantial risk of Jeffrey 
Epstein and his co-conspirators committing sex crimes against young women with 
whom he was in contact. Tragically, Jane Doe 1 and the Class Members fell within 
that zone. 
565. Because of Deutsche Bank's negligent failure to prevent physical harm 
to Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the Class 
Members for damages suffered as a direct and proximate result. 
566. As a direct and proximate result of Deutsche Bank's negligent failure 
to prevent physical harm, Jane Doe 1 and the Class Members have in the past and 
will in the future continue to suffer substantial damages from psychological and 
physical injury, including extreme emotional distress, humiliation, fear, 
psychological trauma, loss of dignity and self-esteem, and invasion of privacy. 
Deutsche Bank's aiding, abetting, and facilitating Epstein's tortious conduct and sex 
crimes in violation of Chapter 130 directly and proximately caused Epstein's sex 
crimes. 
567. By virtue of acting intentionally, outrageously, and with a high degree 
of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal 
indifference to civil obligations, Defendant is liable to Jane Doe 1 and other 
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Members of the Class for punitive damages. 
COUNT XII 
NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE AS A 
BANKING INSTITUTION PROVIDING NON-ROUTINE BANKING 
568. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
569. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
570. Deutsche Bank owed a duty to Jane Doe 1 and the Class Members not 
to knowingly provide non-routine banking assistance to Epstein that it knew, and 
reason to know, would lead to and support intentional tortious conduct and Chapter 
130 Crimes by Epstein (and others) against Jane Doe 1 and the Class Members. 
571. As described in detail in the fact section of this Complaint, Deutsche 
Bank did not merely provide routine banking assistance to Epstein. Instead, it 
participated in, aided and abetted, and facilitating his sex-trafficking venture and his 
commission of intentional tortious conduct and Chapter 130 crimes. Deutsche Bank 
also knew, and was willfully blind to the fact, that it was going beyond providing 
routine banking by facilitating Epstein's sex-trafficking venture and his commission 
of Chapter 130 crimes. 
572. As an example, in providing hundreds of thousands of dollars in cash 
to Epstein and his co-conspirators in circumstances where it knew that the cash 
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would be used to facilitate coercive sex acts, Deutsche Bank took substantial actions 
outside the scope of routine banking assistance. 
573. As another example, Deutsche Bank deliberately failed to follow 
numerous banking requirements in connection with financial dealings with Epstein, 
including AML rules, KYC rules, and anti-structing rules. In deliberately ignoring 
and failing to follow those rules, Deutsche Bank acted in a non-routine way to 
facilitate and support Epstein's and his co-conspirators' intentional torts, sex-
trafficking and commission of Chapter 130 Crimes. 
574. Deutsche Bank failed to act objectively reasonably by failing to comply 
with relevant banking laws and regulations with regard to its interactions with 
Epstein and his co-conspirators. Deutsche Bank owed a duty to Jane Doe 1 and the 
Class Members to act objectively reasonably in its interactions with Epstein and his 
co-conspirators and to exercise reasonable care to prevent them from engaging in 
foreseeable intentional torts and criminal activity by using Deutsche Bank's 
exceptional and non-routine banking assistance. 
575. Deutsche Bank owed a legal duty to Jane Doe 1 and the Class Members 
to act objectively reasonably and to not deliberately ignore banking obligations, 
including KYC and AML laws and regulations described above, so as to provide 
Epstein and others with an opportunity to engage in coercive sex-trafficking and 
Chapter 130 Crimes. 
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576. Under KYC, AML, and related laws and regulations, Deutsche Bank 
had special duties not ignore crimes being committed by its customers—duties 
above and beyond any duties that the general public may have. The inquiries that 
banks must make include duties to inquire about specific individuals who banks 
know are being harmed. The regulations establish a duty of care that must be 
followed by banks, including Deutsche Bank. These duties exist at least in situations 
where a bank is knowingly going beyond offering routine banking to its customers 
and offering bank accounts, currency, and other assistance specially adapted to 
facilitate crimes. 
577. Deutsche Bank also owed Jane Doe I and the Class Members a duty of 
care because it knew, and had reason to know, that Epstein and his co-conspirators 
were using Deutsche Bank to facilitate a sex-trafficking venture, raising a duty to 
make a reasonable inquiry about suspicious activity. 
578. Deutsche Bank owed Jane Doe 1 and the Class Member a duty not to 
deliberately and purposely fail to file SAlts, which would have alerted federal 
authorities to Epstein's and his co-conspirators' illegal activities, including 
committing Chapter 130 Crimes. 
579. Deutsche Bank also owed Jane Doe 1 and the Class Members a duty to 
prevent physical harm to them when confronted with explicit information that 
Epstein and his co-conspirators were using Deutsche Bank's non-routine assistance 
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to further a sex-trafficking venture harming Jane Doe 1 and the Class Members. 
Once Deutsche Bank had information about Epstein's use of Deutsche Bank for a 
sex-trafficking venture that was physically harming Jane Doe 1 and the Class 
Members, it owed them a duty of care to investigate and prevent Epstein's and his 
co-conspirators' suspicious and criminal activities. 
580. In the exercise of reasonable care, Deutsche Bank and its employees 
knew, and should have known, of the dangerous propensities of Jeffrey Epstein to 
commit violations of article 130 of New York Penal Law against women and girls 
with whom he was in close proximity, including Jane Doe I and the Class Members. 
581. Deutsche Bank also owed Jane Doe 1 a duty of care because Epstein 
and his agents opened a bank account in her name with Deutsche Bank, making her 
a customer of Deutsche Bank. 
582. Deutsche Bank breached its legal duties to Jane Doe 1 and the Class 
Members as described above. Deutsche Bank's breach of its duties led to it failing 
to prevent Epstein from committing Chapter 130 Crimes against Jane Doe 1 and the 
Class Members. Deutsche Bank realized that Epstein were committing Chapter 130 
Crimes against Jane Doe 1 and the Class Members. The criminal activity that harmed 
Jane Doe 1 and the Class Members included foreseeable TVPA and Chapter 130 
Crimes committed by the Epstein. 
583. As a direct and proximate result of the breach of legal duties by 
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Deutsche Bank, Jane Doe 1 and the Class Members repeatedly suffered direct and 
foreseeable injuries from Epstein and his co-conspirators, including federal and state 
sexual offenses (including sexual assaults) and resulting emotional distress, mental 
pain and suffering, and other physical, psychological, and other injuries. 
584. The breaches of legal duties were the direct—Le., the but-for—cause 
of these physical and psychological injuries to Jane Doe 1 and the Class Members. 
Without Deutsche Bank's breaches of legal duties, those injuries would not have 
occurred. The injuries that occurred were readily foreseeable to Deutsche Bank. 
585. The injuries that Plaintiff Jane Doe 1 and the Class Members suffered 
included injuries directly and proximately suffered while they were adults who were 
present in this District. These injuries are permanent in nature and Jane Doe 1 and 
the other Class Members will continue to suffer these losses in the future. 
586. Deutsche Bank could reasonably foresee that their actions and 
omissions in facilitating Epstein's sex trafficking enterprise would lead to intentional 
torts and sex offenses against Jane Doe land the Class Members. Indeed, Deutsche 
Bank was aware, and should have been aware, that Epstein was a "high risk" to 
commit sex offenses against young women and girls. As the New York banking 
regulators concluded, the fact that Epstein was engaging in suspicious transactions 
"should have been obvious to [Deutsche] Bank personnel at various levels." 
587. Jane Doe 1 and the Class Members were easily within the zone of 
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foreseeable harm from Deutsche Bank's negligent acts and omissions. Deutsche 
Bank's acts and omissions foreseeably created substantial risk of Jeffrey Epstein 
committing sex crimes against young women with whom he was in contact. 
Tragically, Jane Doe 1 and the Class Members fell within that zone. 
588. While the foregoing allegations easily make out a clear case of 
negligence, this case does not involve mere negligence. Instead, Defendants' tortious 
conduct in this case evinced a high degree of moral turpitude and demonstrated such 
wanton dishonesty as to imply a criminal indifference to civil obligations. It also 
involved outrageous and intentional acts and omissions, because it was a deliberate 
attempt to further the crimes of a widespread and dangerous criminal sex trafficking 
organization. Defendants' tortious 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. 
589. As a result of Deutsche Bank's negligent actions and omissions 
described in this Count, Jane Doe 1 and the Class Members have sustained both 
general and specifical damages from physical and psychological injury in substantial 
amounts. 
590. By virtue of acting intentionally, outrageously, and with a high degree 
of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal 
indifference to civil obligations, Deutsche Bank is liable to Jane Doe 1 and other 
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