Professional Documents
Culture Documents
Deutsch Bank Epstein Lawsuit
Deutsch Bank Epstein Lawsuit
Plaintiff Jane Doe 1 files this individual and civil class action complaint for
damages and other relief under (among other provisions of law) the United States
intentional and negligent acts and omissions under the New York Adult Survivors
Act. The suit arises from Defendants Deutsche Bank Aktiengesellschaft’s, Deutsche
Bank AG New York Branch’s, and Deutsche Bank Trust Company Americas’
providing the requisite financial support for the continued operation of Epstein’s
Deutsche Bank knowingly benefited and received things of value for assisting,
supporting, facilitating, and otherwise providing the most critical service for the
and coercively sex traffic Plaintiff Jane Doe 1 and the numerous other members of
the Class proposed below (the “Class”). Deutsche Bank knew that Epstein was
regularly committing violations of New York Penal Law Art. 130, including and
especially New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66, and
Deutsche Bank also knew that Epstein would use means of force, threats of
force, fraud, abuse of legal process, exploitation of power disparity, and a variety of
other forms of coercion to cause young women and girls to engage in commercial
sex acts. Deutsche Bank also engaged in repeated acts of racketeering activity to
support the Epstein organization. Knowing that they would earn millions of dollars
from facilitating Epstein’s sex trafficking, and from its relationship with Epstein,
Deutsche Bank chose profit over following the law. Specifically, Deutsche Bank
2
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 3 of 104
believes that substantial additional evidentiary support will exist for the allegations
including the federal TVPA, 18 U.S.C. § 1589 through § 1595. This Court has
2. This Court also has supplemental jurisdiction of the state law claims
recounted below pursuant to 28 U.S.C. § 1367(a), because all claims alleged herein
are part of a uniform pattern and practice and form part of the same case or
controversy.
accordance with 18 U.S.C. § 1595, in which to bring this action. Venue is proper in
this District under 28 U.S.C. § 1391(b)(2), because Epstein, his co-conspirators, and
Deutsche Bank all conducted substantial activities in this District and knowingly
aided and abetted, facilitated, and directly participated in Epstein’s illegal venture
through actions that originated in this District. In addition, Epstein sexually abused
and trafficked Jane Doe 1, and members of the Class is this District.
3
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 4 of 104
4. Often these acts of sexual abuse and commercial sex acts, committed
by Jeffrey Epstein and certain select friends of his, took place in Jeffrey Epstein’s
New York mansion, located within this District at 9 East 71st Street, New York
City. Epstein also used his New York mansion to harbor his victims and as a base
5. A substantial part of the acts, events, and omissions giving rise to this
which provides that a plaintiff shall have ten years after the cause of action arose to
file suit against any person who knowingly benefits, financially or by receiving
anything of value from participation in a venture which that person knew or should
have known violated the laws against sex trafficking. This action is also timely
II. PARTIES
7. Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of
because of the sensitive and highly personal nature of this matter, which involves
sexual assault.
9. Jane Doe 1 is also at serious risk of retaliatory harm because the co-
4
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 5 of 104
10. Jane Doe 1’s safety, right to privacy, and security outweigh the public
12. As discussed below, many other women, who are victims and
survivors of sexual abuse and trafficking are similarly situated to Jane Doe 1 and
also need to proceed anonymously for the same reasons. The identities of most of
New York, the Deutsche Bank AG New York Branch (the “New York Branch”),
and also operates a trust company, Deutsche Bank Trust Company Americas
5
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 6 of 104
AG, the New York Branch, and DBTCA—are referred to collectively as “Deutsche
16. Defendants Deutsche Bank AG, the New York Branch, and DBTCA
all currently conduct substantial business in this District and conducted substantial
ordinarily trades shares on the New York Stock Exchange, located in this District.
As another example, Deutsche Bank maintains branch banks within this District.
herein, were in and affecting interstate and foreign commerce. In connection with
the acts alleged in this complaint, Defendants, directly or indirectly, used the means
and instrumentalities of interstate commerce, including, but not limited to, the mails,
markets.
19. Deutsche Bank is responsible, under United States law and otherwise,
for the acts of its officers, directors, employees, and agents, including the acts
November 2012. During his tenure, he was involved in bringing Jeffrey Epstein over
6
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 7 of 104
client.
Management Americas Group when Epstein became a client. Packard was involved
III. INTRODUCTION
them into Epstein’s carefully constructed world in which Epstein was their messiah
24. Each victim understood that Epstein was the most powerful man in
the world, with the most powerful connections. Epstein and his co-conspirators
preached the Gospel of Epstein. Epstein’s victims were taught to do what he said
and he could protect them; but disobey him, and he would punish them and would
cause them serious harm from which they could never recover.
25. Once in Epstein’s clutches, each victim was taught and understood
that she must be completely compliant with every wish or demand Epstein had for
7
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 8 of 104
her; otherwise, she would certainly suffer serious reputational, financial, and
psychological harm. By using these and other means of force, threats of force, fraud,
threats of abuse of the legal process and coercion, Epstein and his co-conspirators
sexually trafficked and sexually abused Plaintiff Jane Doe 1 and the other members
of the Class.
leaders, British Royalty, and had the backing and support of powerful banking
institutions.
27. The Epstein sex-trafficking venture originated in the 1990s. From its
inception until Jeffrey Epstein’s arrest by the FBI for sex trafficking in 2019 (and
his subsequent death on August 10, 2019, by apparent suicide), the venture operated
primarily for the purpose of luring young women and girls into a position where
Jeffrey Epstein and his co-conspirators could coerce them to engage in commercial
sex acts and commit sexual offenses against them. His venture also operated to
beginning and grew increasingly more complex and powerful as it victimized more
young women.
8
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 9 of 104
29. Epstein did not, and could not, act alone. He created and maintained
his sex-trafficking venture with the assistance of other influential individuals and
entities who knew he was sexually trafficking young women and girls and provided
operation and sexual abuse and sex-trafficking of young women and girls. Without
31. Epstein’s victims were young women and girls, who suffered severe
abuse as Epstein’s sex-trafficking victims and who believed they had to remain loyal
to the venture at all costs in order to survive. At all times relevant to this action,
wealth, derived from carefully selected wealthy individuals who acted as the
financial engine behind the sex-trafficking operation. During all times relevant to
this Complaint, one wealthy individual provided almost all the financial fuel for
9
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 10 of 104
each of his targeted victims. He then closed the trap on his victims with offers of
money, food, shelter, medical care for them or family members, travel, schooling,
and career opportunities. Epstein groomed the young women and girls,
care of them in various ways, which ultimately allowed Epstein to cause them to
engage in commercial sex acts with himself and, on occasion, others, as well as to
obtaining, harboring, and transporting the young victims without drawing unwanted
restraint), and abuse of law and the legal process, to cause Jane Doe 1 and many
10
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 11 of 104
transported, and enticed some of his victims, including Jane Doe 1 and others
similarly situated, to engage in commercial sex acts in, among other places, New
York (including the Southern District of New York), Florida, the U.S. Virgin
from in and around the 1990’s through in and around August 10, 2019, when Epstein
40. In 2006, Jeffrey Epstein was arrested in Florida after state and federal
law enforcement discovered that he had sexually abused more than 30 children in
his Palm Beach, FL mansion. During that investigation, it was concluded that
Epstein and his co-conspirators had committed federal criminal acts constituting
violations of 18 U.S.C §§ 2422 (b), 2422 (2), 2423 (f), 2423 (b), 2424 (e), 18 U.S.C
§ 371, 18 U.S.C § 1591 (c) (1) and 1591 (a) (1) and (2), as well as state crimes in
violation of Florida Statute §§ 796.07 and 796.03, against dozens of young women,
some as young as 14 years old. With respect to the specific discoveries, the United
States Attorney’s Office for the Southern District of Florida found that some of the
11
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 12 of 104
victims “went to Mr. Epstein’s house only once, some went there as much as 100
times or more.”
two felonies, was permanently labeled a “Registered Sex Offender,” and was jailed
in 2008.
information that became public, including documents obtained through trash pulls
travel records, revealing details about Epstein’s life-style, daily activities, and
43. Epstein’s criminal case in Florida and the many related news reports
left no doubt about Jeffrey Epstein and his extraordinary penchant for sexually
abusing and trafficking young females. For instance, it was revealed that until the
time of his Florida arrest, Jeffrey Epstein was sexually abusing three to four young
females per day, in every location he was in at the time; sexually abusing young girls
and women was a full-time job for him, from which he never took a vacation or
hiatus.
44. Beginning with his Florida arrest and for years moving forward,
Epstein was embroiled in dozens of public lawsuits pertaining to his sexual abuse of
females and hundreds if not thousands of news stories circulated worldwide about
12
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 13 of 104
operation was widely publicized after his 2006 arrest. He would lure young girls or
women to one of his luxurious mansions, under the guise of being a wealthy
cash money, advancement of careers, education, or other life necessities, and once
inside he would force his would-be victim into providing a massage that would turn
sexual, and from there he would sexually abuse them and cause each of his
46. Once in his presence, each victim knew it was no option to disobey
Epstein. It was well known and understood that he was one of the most powerful and
connected people in the United States, able to help any of these young victims and
47. Through the 2006 criminal investigation and the ensuing hundreds of
news articles and dozens of lawsuits, the details of Epstein’s sexual abuse and sex
48. While the first sexual abuse was discovered to have likely occurred
in the early 1990s with the use of his then paramour, Ghislaine Maxwell, his appetite
for sexual abusing young women and girls grew over the years.
49. By the late 1990s each victim was being requested to bring other
13
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 14 of 104
victims and being paid handsomely in cash for recruiting other victims.
trafficking operation grew its number of victims exponentially in the late 1990s and
early 2000s.
new victims at an alarming rate beginning in 2000 was his access to unlimited
amounts of cash.
52. Without exorbitantly large amounts of cash, his operation could not
run, as newly recruited victims were each paid hundreds of dollars in cash
53. Each victim was also informed that she would be paid hundreds of
dollars in cash for each additional victim she recruited, and Epstein made good on
54. The public documents and articles stemming from the 2006 arrest
made abundantly clear that Epstein was doling out thousands of dollars in cash every
day as hush money to victims he was sexually abusing and to victims he was using
55. If Epstein paid every victim with wire transfers and left a money trail,
his illegal sex trafficking operation would have been easily uncovered; however,
with access to unlimited amounts of cash, Epstein was able to commit the most
14
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 15 of 104
egregious sexual crimes many times a day without leaving a paper trail.
hand for Epstein to pay each victim as hush money for the abuse she was suffering
57. Because Epstein’s vast wealth, said to have been more than a billion
dollars, was maintained in seemingly legitimate financial institutions, not in the form
of cash in a warehouse.
58. In order to access the large amount of cash needed to maintain his
active sexual abuse of young women, it was essential that the financial institution
where he banked be complicit in his operation, and more specifically that the bank
at a financial institution that would allow him to constantly withdraw cash from his
effectively because it not only allowed expansion through the recruitment of other
avoid future sexual abuse – she could bring someone else who would get abused in
her place.
hand for Epstein to pay each victim as hush money for the sexual abuse she was
suffering as well as each victim’s finder’s fee for bringing another victim.
15
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 16 of 104
being public when he served his jail time in Florida, other relevant information
became public about Jeffrey Epstein and was widely published: he had no college
degree, had never obtained any specialized license, none of the companies with
whom he was associated had any legitimate business structure or purpose, and he
had no documented expertise that would provide the requisite skill or knowledge to
62. Despite the false rumors Jeffrey Epstein had created to conceal his
true “business,” he was exposed as literally nothing other than an expert sex
trafficker and abuser of young females—a fact easily discernible by any responsible
65. Once out of jail and off work release, Epstein continued to collect
young women and lure them through force, fraud, or coercion into one of his
mansions, primarily his townhouse located at 9 East 71 Street, NYC, where he would
66. His sex trafficking operation continued as it had in the past, although
16
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 17 of 104
it became more elaborate, creating more phony companies, opening more bank
through wires, payroll, direct deposits, and other means known to his financial
67. As time went by, the news articles and lawsuits continued to mount
and more information became publicly available that Epstein was continuing to
sexually abuse young women, and was using professionals on his payroll to help him
conceal his illegal activity, and give him ostensible cover as a well-connected money
manager.
multiple young women each day through a pyramid-type recruiting scheme that
required the transfer of millions of dollars to continue the operation, a complicit bank
69. From approximately 2000 through 2013, JP Morgan was the bank
complicit in seeing to it that Epstein could abuse countless young females and could
70. Epstein’s relationship with James “Jes” Staley was key to Epstein
71. Staley and JP Morgan built the financial infrastructure that allowed
for Epstein’s sex trafficking operation to become what it was. They had a business
17
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 18 of 104
relationship with Epstein when he was arrested, when he was required to register as
a sex offender, and even continued to enable and support his sex trafficking
operation after he was released from jail. As an agent of JP Morgan, Staley knew
72. Staley left JP Morgan in 2013, and JP Morgan, knowing that Epstein
was a sex trafficker running a publicly known sex trafficking operation, with no
73. In 2013, when the world knew Epstein was now perhaps the most
famous sex offender, publicly known for abusing females on a daily basis, and as he
was on the precipice of being dropped by JP Morgan, the bank that had protected
him and his operation for nearly 15 years, he needed a financial institution that would
allow him to run his illegal operation indifferent to the victims that he was continuing
74. Deutsche Bank picked up exactly where JP Morgan left off and
became the bank that Epstein needed to fund his sexual abuse and sex-trafficking
operation.
75. Various banks and bankers were a critical part of Epstein’s particular
sex-trafficking venture. Due to the extensive publicity about Epstein’s illegal sexual
activities, in 2013 his longtime financial banking institution was severing ties with
18
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 19 of 104
him.
that would provide the necessary legitimate appearance for his operation, allow him
to open many accounts for illegitimate companies, ignore blatant red flags, allow
him to transfer money without questioning, allow him access to abundant cash in
direct violation of federal law, and to otherwise facilitate the commercial aspect of
77. From on or about August 19, 2013, through about 2018, Deutsche
Bank was the key bank participating, and playing an essential role in, the Epstein
sex-trafficking venture.
venture by (among other things) providing the financial underpinnings for Epstein
coerce, and entice young women and girls to be sexually abused and to cause them
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-
19
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 20 of 104
Epstein’s illegal conduct. Deutsche Bank’s conduct violated the TVPA, which
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
and before on-boarding Epstein, Deutsche Bank estimated that it would earn
banker brought Epstein over from JP Morgan to Deutsche Bank, and all knowledge
20
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 21 of 104
responsibility to make all available inquiries to any other entity who had been
associated with Epstein to learn if in fact Epstein had retired from his illegal sex-
Laundering (“AML”) risks posed by the client, including 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
when a client relationship poses too high of a risk and therefore must be terminated.
88. Without Deutsche Bank’s assistance, Epstein could not have abused
or trafficked the dozens of young women he did between 2013 and 2018.
89. On July 6, 2020, Deutsche Bank agreed to pay a fine of $150 million
dollars 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
21
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 22 of 104
Jeffrey Epstein.
trafficking activities that affect interstate or foreign commerce or take place within
92. The TVPA also contains an explicit “civil remedy” provision which
U.S.C. §§ 1591-95) to bring a civil action against the perpetrator and any person or
93. Unlike the criminal penalties provisions in the TVPA, the civil
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
94. In this complaint, Jane Doe 1 and other members of the class allege
that Deutsche Bank acted outrageously and intentionally. But, in addition, in the
paragraphs that follow, wherever Jane Doe 1 and the other members of the class
allege that the 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,
engage in commercial sex acts, Jane Doe 1 and other members of the class also allege
that, at a bare minimum, the Defendants should have known that the Epstein sex-
trafficking venture had used such means to engage in illegal sex trafficking in
23
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 24 of 104
forbids racketeering activities that affect interstate or foreign commerce or take place
and uses intentionally broad language. The Act provides that, “[t]he provisions of
this title shall be liberally construed to effectuate its remedial purposes.” Pub.L. No.
(a) 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.
98. RICO also contains an explicit “civil remedy” provision which allows
24
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 25 of 104
1964(c).
99. In the paragraphs that follow, Plaintiff allege that the Defendants
violated 18 U.S.C. § 1962 and injured them in various ways, including injury to their
100. 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 Palm Beach mansion, and an island in the U.S. Virgin
Island.
101. Beginning in the early 1990’s and continuing through the summer 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
and in other countries to sexually abuse and exploit, Epstein worked and conspired
25
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 26 of 104
with others, including employees and associates who facilitated his conduct by,
among other things, recruiting victims, coercing victims, and scheduling their sexual
abuse by Epstein at his New York mansion, his Palm Beach mansion, and his island
similar ways. Epstein and his co-conspirators lured new victims into his home for
alleged philanthropic Epstein and provide “massages” to him. Once at the home and
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.
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
26
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 27 of 104
as for recruiting, created a sex trafficking spider web and maintained a steady supply
105. Epstein was skilled at ascertaining his victim’s greatest fears and
aspirations and targeted those fears and aspirations to coerce and trap his victims
commercial sex acts, specifically sex acts for which his victims received things of
107. Among other things, Epstein provided things of value to his victims
in order to cause them to engage sex acts with him and on occasion his friends, co-
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.
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.
27
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 28 of 104
Epstein and his co-conspirators would “gift” his victims money and provide them
his co-conspirators would then force them to pay off the “debt” by complying with
111. Throughout most of the 1990s through about July 2019, the Epstein’s
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
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
boundaries between New York, Florida, New Mexico, New Jersey, Massachusetts,
and the U.S. Virgin Islands and elsewhere, and in foreign commerce to places,
28
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 29 of 104
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
116. 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,
117. On July 8, 2019, Jeffrey Epstein was arrested pursuant to the New
York Indictment.
118. On August 10, 2019, prison guards found Epstein unresponsive in his
Metropolitan Correctional Center jail cell, where was awaiting trial on the federal
sex trafficking charges. He was later pronounced dead from apparent suicide.
charges filed in this Court. The charges alleged that she had assisted, facilitated, and
groom, and ultimately abuse his victims. See United States v. Maxwell, Case No.
29
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 30 of 104
1:20-cr-00330 (S.D.N.Y.).
120. On December 29, 2021, Maxwell was found guilty in this Court on
B. Consistent with His 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.
121. In about 2003, Jane Doe 1 moved to New York City where she was
122. From 2003 until the time that Jane Doe 1 escaped, Jeffrey Epstein
committed numerous intentional acts against Jane Doe 1 which constitute sexual
offenses as defined in New York Penal Law § 130, including but not limited to the
following:
young, vulnerable women like Jane Doe 1. Epstein and his co-conspirators
124. The well-oiled Epstein sex abuse and trafficking venture included
frequent statements to Jane Doe 1, and other victims, by Jeffrey Epstein and his co-
conspirators that: (1) Jeffery Epstein possessed extraordinary wealth, power and
influence; (2) Jeffrey Epstein’s business and political friends, including world
leaders, included some of the most powerful people in the world; (3) Jeffrey 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
1’s and other victims’ life needs such as shelter or housing if she or they failed to
allow sexual abuse or to perform those acts or did not follow his instructions no
125. 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 single day she was in his presence, as was customary practice for
Jeffrey Epstein. His sex-trafficking venture targeted vulnerable young women and
Jane Doe 1 was soon forced to remain in contact with Epstein, was unable to
31
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 32 of 104
extricate herself, and had no real choice but to comply with his every command or
126. Jane Doe 1 was sexually abused and trafficked by Epstein for
numerous years and was not able to escape from Epstein until 2018. Having been
conditioned that the sexual abuse was “normal” and knowing that everyone
people, were aware of the sex abuse, Jane Doe 1 was coerced into a cult-like life
127. Over the ensuing years, from about 2003 through about 2018, Epstein
sexually abused Jane Doe 1 and trafficked her to friends for commercial sex acts in
this District.
128. 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
129. 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
130. Epstein transported Jane Doe 1 from New York to other states to
32
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 33 of 104
sexually abuse her and to cause her to engage in commercial sex acts.
131. Over the ensuing years, 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
132. 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.
133. 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
135. From on or about August 19, 2013, through about 2018, Deutsche
underpinnings for the venture. Deutsche Bank’s conduct, as described below, was
33
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 34 of 104
136. Deutsche Bank enabled Epstein to have ready and reliable access to
transport young women and girls (including the Plaintiff bringing this action) to
abuse and sex-trafficking venture, including in particular his coercive sex trafficking
disregard of the fact, that the person has been caused to engage in a commercial sex
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
34
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 35 of 104
Epstein penetrated Jane Doe 1—forcing all Jane Does to engage in sexual activity.
Deutsche Bank also provided funds through wire transfers and by mail.
venture by (among other things) providing the financial underpinnings for the
venture.
141. Deutsche Bank 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.
and in other ways from its participation in Epstein’s sex-trafficking venture with
knowledge, or with reckless disregard to the fact, that Epstein used means of force,
threats of force, fraud, and coercion (and combinations thereof) to force young
women and girls to be sexually abused and to engage in commercial sex acts.
144. As recounted more fully in the paragraphs that follow, Deutsche Bank
did financially benefit by earning millions of dollars from its participation in the
35
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 36 of 104
directly from its participation in the sex-trafficking venture and because of its
participation in that venture. In other words, there was a causal relationship between
Deutsche Bank’s conduct furthering Epstein’s sex-trafficking venture and its receipt
of the financial benefits with actual (and constructive) knowledge of that causal
relationship.
illegal sex-trafficking venture. Deutsche Bank knew that if it did not finance
accounts. Faced with the choice between profiting from Epstein’s sex-trafficking
various “Know Your Customer” laws, Deutsche Bank regularly authorized cash
withdrawals and deposits for the Epstein sex-trafficking venture, as well as wire
transfers, which allowed Epstein, his co-conspirators, and those they directed to
victims.
allowed Epstein and his various corporations to stay “under the radar” and continue
36
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 37 of 104
sexual abuse and commercial sex acts in interstate and foreign commerce, Deutsche
Bank earned interest, commissions, service fees, and other financial benefits directly
from its connection with Epstein, Epstein-related entities, and others acting in
concert with Epstein. Epstein provided those financial benefits to Deutsche Bank
knew that was the reason that Epstein was providing them with those financial
benefits.
accounts. For example, Epstein and his co-conspirators forced Jane Doe 1 to open
simultaneously created greater connection between Jane Doe 1 and the Epstein
from Epstein’s sexual abuse and sex-trafficking venture by profiting from the funds
that Epstein, his co-conspirators, and his wealthy associates deposited with Deutsche
Bank.
37
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 38 of 104
Trust Company, Inc., (2) Southern Financial LLC, (3) The Butterfly Trust, (4)
Among the various things of value it received were (1) connections with Jeffrey
Epstein, his co-conspirators, and his wealthy friends and associates; (2) additional
deposits from Epstein, his co-conspirators, and his wealthy friends and associates;
(3) the ability to charge above-normal fees to Epstein because he was a “high risk,
high reward” customer; and (4) the opportunity to earn financial benefits from the
funds that had been deposited with it. Deutsche Bank knowingly received these
153. Among the women and girls whose sex trafficking and sex abuse
154. On July 20, 2020, the New York State Department of Financial
Service (hereinafter “New York Banking Regulators”) and Deutsche Bank agreed to
Bank’s relationship with Epstein and Epstein-related entities. Deutsche Bank agreed
to pay a penalty of $150 million to resolve the investigation regarding Epstein and
38
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 39 of 104
155. The New York Banking Regulators found, accurately, that Deutsche
156. The New York Banking Regulators found, accurately, that Deutsche
157. The Federal Bank Secrecy Act (“BSA”) requires financial institutions
New York state law requires financial institutions to devise and implement systems
reasonably designed to identify and report suspicious activity and block transactions
prohibited by law.
their unique risk factors, incorporating parameters such as institution size, presence
in high-risk jurisdictions, and the specific lines of business involved, and the
institutions have an affirmative duty to ensure that their systems run effectively.
necessary for financial institutions to monitor their customers for the purpose of
preventing their customers from facilitating criminal activity using the institutions’
39
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 40 of 104
facilities.
(“KYC”) and customer due diligence are critically important, and financial
relationships with clients, including as necessary to assess the risks associated with
the client. To properly consider these risks, financial institutions must consider
relevant factors such as the nature of the client’s business, the purpose of the client’s
161. Financial institutions must also conduct KYC reviews for each client
including 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
activity is identified.
when a client relationship poses too high of a risk and therefore must be terminated.
40
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 41 of 104
Deutsche Bank failed in various respects to meet its Know Your Customer and other
obligations fully with respect to its relationship with Jeffrey Epstein and entities
related to Epstein.
164. In around 2013, Deutsche Bank was aware that Epstein was a wealthy
165. In around 2013, Deutsche Bank was aware that Epstein also had a
young women. Allegations against him began appearing in the press as early as
March 2005, with the accusation that he paid a 14-year-old girl for a “massage.”
166. That year, the Palm Beach (Florida) Police Department began an
investigation into allegations against Epstein related to his sexual abuse in Palm
Beach. The investigation quickly uncovered dozens of other Epstein sex abuse
victims. The investigation also identified the Epstein sex-trafficking venture, which
included a number of individuals who were responsible for recruiting young women
167. In 2006, the State Attorney handling the case, after meeting privately
with an attorney representing Epstein, referred the case to a state grand jury instead
41
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 42 of 104
of charging Epstein and his co-conspirators for crimes for which local police
believed there was abundant evidence. As a result, the Palm Beach Police Chief
publicly denounced the State Attorney and referred the case to the Federal Bureau
providing him and his co-conspirators (including Lesley Groff, Sarah Kellen,
Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for
sentence and Epstein was also required to register as a sex offender upon his release.
Epstein ultimately served only 13 months of his 18-month sentence in the Palm
Beach County jail and was allowed work release privileges that enabled him to leave
with the U.S. Department of Justice was made public when it was unsealed in
connection with a challenge brought to the NPA by two of his victims. The
agreement, among other things, outlined possible charges that could have resulted
from the investigation, including charges that Epstein conspired to use a facility or
42
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 43 of 104
in illicit sexual conduct with minors, conspiring with others to do the same, and
trafficking minors. That agreement also notes that the United States had compiled
“a list of individuals whom it [had] identified as victims,” and that Epstein would
continued between 2008 and 2013 (and beyond) and attracted significant media
attention.
171. Indeed, between 2005 and 2013, press reports outlined the allegations
underlying the NPA and to varying degrees detailed the involvement of Epstein’s
Marcinkova.
172. Some articles reported that Lesley Groff and Sarah Kellen had
invoked their Fifth Amendment right against self-incrimination, and others reported
that Nadia Marcinkova had allegedly recruited underage girls to give Epstein
“massages.”
173. The names of these women and other alleged co-conspirators were
174. Additionally, press reports during this time noted allegations that
Epstein was involved with Eastern European women in particular and that a
43
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 44 of 104
modeling agency he helped fund brought “young girls . . . often from Eastern
175. Deutsche Bank was aware of the foregoing information and more
about Epstein’s sex abuse and sex trafficking activities by around 2013, when it
176. In early 2013, Epstein, who had been banking with one of Deutsche
Bank’s competitors, J.P. Morgan, began the process of moving his assets to Deutsche
Bank.
177. The relationship between Deutsche Bank and Epstein came about
through a Deutsche Bank relationship manager, Paul Morris, who had left J.P.
Morgan bank (“JP Morgan”) to join the Bank’s private wealth department. At JP
Morgan, Morris had been a member of the team servicing Epstein’s accounts.
178. Paul Morris joined Deutsche Bank in November 2012. Soon after
joining Deutsche Bank, Morris suggested to senior management that Epstein was a
potential client who could generate millions of dollars of revenue as well as leads
for other lucrative clients to Deutsche Bank. Morris and Epstein began discussions
in the spring of 2013 about a potential relationship between Deutsche Bank and
Epstein.
44
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 45 of 104
send to Deutsche Bank’s then co-head of the Wealth Management Americas Group,
Charles Packard, and Patrick Harris, the Chief Operating Officer of Wealth
Management Americas.
concerning Epstein’s previous plea deal and prison sentence for sex-trafficking
related crimes. In particular, the memorandum stated that “Epstein was charged with
soliciting an underage prostitution [sic] in 2007,” that “[h]e served 13 months out of
his 18-month sentence,” and that “[h]e was accused of paying young woman [sic]
for massages in his Florida home.” It also highlighted that Epstein was involved in
181. In the email to Charles Packard and Patrick Harris attaching the
memorandum, Paul Morris noted how lucrative becoming Epstein’s banker could
be, stating “[e]stimated flows of $100-300 [million] overtime [sic] (possibly more)
w/ revenue of $2-4 million annually over time.” In the same email, Morris proposed
that all Epstein-related accounts be for “entities” affiliated with Epstein, “not
personal accounts.”
“Approval Email”) to Morris, which read “spoke with [the Head of AML
45
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 46 of 104
Compliance for Deutsche Bank Americas and the then-General Counsel for
Deutsche Bank Americas, who at that time served as chair of the Bank’s Americas
relationship] requires rep risk and we can move ahead so long as nothing further is
identified through KYC and AML client adoptions.” The ARRC did not meet in
by the relevant regional reputational risk committee. Deutsche Bank’s policies and
identify a client that they believe could pose a reputational risk to the Bank, it must
escalate that client for review by the attendant reputational risk committee. In the
case of the onboarding of the Epstein relationship, this was the ARRC.
184. At the time, Deutsche Bank was aggressively expanding its U.S.
wealth management business under its new co-chief executive, Anshu Jain, and was
multiples had driven strong investment from Deutsche Bank into asset and wealth
management, as they consumed less capital than the investment banking business.
Deutsche Bank officials have repeatedly called the Bank’s private banking wealth
46
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 47 of 104
Court, no formal KYC investigation was ever ultimately undertaken for Epstein.
186. The relationship between Deutsche Bank and Epstein officially began
on August 19, 2013, when the Bank opened brokerage accounts for Southern Trust
U.S. Virgin Islands in 2011, and Southern Financial LLC, a wholly owned subsidiary
of Southern Trust Company Inc. According to the KYC record, the purposes of the
brokerage accounts were to “hold marketable securities and cash” and “to invest
long term [sic] with the bank,” respectively. Over the course of the relationship,
Epstein, his related entities, and associates would eventually open and fund more
than 40 accounts at Deutsche Bank, with more than $110 million in just one of the
187. From the time of Epstein’s onboarding, the relationship was classified
47
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 48 of 104
Although the Bank did not initially classify Epstein as a politically exposed person
(“PEP”), the Bank did designate him an “Honorary PEP” because of his connections
his sex-trafficking venture began using Deutsche Bank accounts to make wire
transfers of money to facilitate Epstein’s sex abuse and his sex-trafficking venture.
Over the course of the relationship, Epstein and his representatives used Deutsche
Bank accounts to send dozens of wires, directly and indirectly, including at least 18
wires in the amount of $10,000 or more to then known co-conspirators in the sex-
trafficking venture, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova.
189. Deutsche Bank was aware that the recipients of some of these wire
described further below. Deutsche Bank was aware that its wire transfers were in
190. On January 24, 2014, Deutsche Bank opened checking and money
market accounts for an Epstein-related trust named “The Butterfly Trust.” The
48
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 49 of 104
Groff, Sarah Kellen, and Nadia Marcinkova, and a number of women with Eastern
European surnames. When Deutsche Bank personnel asked Epstein and Epstein’s
representatives about his relationship with the beneficiaries, Epstein represented that
they were employees or friends. Deutsche Bank’s KYC records state that the purpose
of the money market account was “to pay all expenses/disbursements related to the
191. The Butterfly Trust accounts were, like the overall Epstein
relationship itself, approved for onboarding based on the earlier Approval Email
from Charles Packard, despite obvious reputational and possible financial crime
risks. Specifically, the beneficiaries of the Butterfly Trust included, among others,
Lesley Groff, Sarah Kellen, and Nadia Marcinkova. The existence of co-conspirators
knowledge that payments through the Trust would be used to further or coverup
criminal activity and to endanger more young women and girls as victims of
Bank was aware that one of the Trust’s beneficiaries was an alleged co-conspirator
officer performed background checks on the beneficiaries of the trust and flagged
49
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 50 of 104
for Paul Morris that one of the beneficiaries, Sarah Kellen had been alleged to be
one of Epstein’s co-conspirators. In reply, Paul Morris confirmed that Kellen “was
accused as a co-conspirator in a case but was never brought to trial nor ever
convicted. The account for which she will be associated is a trust account which
names her as a beneficiary.” The alert was cleared citing the Approval Email from
Paul Morris.
193. While Epstein held accounts at Deutsche Bank, he used the Butterfly
Trust account and various other accounts to send over 120 wires totaling $2.65
million to beneficiaries of the Butterfly Trust. These transfers furthered his sex abuse
and the sex-trafficking venture, including funds paying directly for coercive and
commercial sex acts, funds paid to professionals for carrying out illegal acts for the
operation of the sex-trafficking venture, and paying funds to others for committing
194. Epstein used Deutsche Bank accounts to pay for coerced commercial
trafficking, its continuation of its financial relationship with Epstein after January
24, 2014 (and earlier) was, at a minimum, in reckless disregard of the fact that
Epstein was using means of force, threats of force, fraud, coercion (and a
50
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 51 of 104
victims (who essentially lived with Epstein as commercial sex slaves) began having
was to force certain of his American victims to enter into same-sex marriages with
his foreign victims in order to prevent deportation and to exercise even greater
197. It was during this late part of 2013, that Epstein needed a banking
institution that would be complicit and provide all the necessary services for his sex
198. One way in which Epstein obtained victims to sexually abuse was by
using sham marriages to bring the victims into this country illegally. Because
Epstein was paying fees to a particular immigration attorney to coach the women
who did not want to participate on what to say from his Deutsche Bank account, had
his personal attorney also advising the women and signing related checks, and even
opened bank accounts in the names of the victims, Epstein needed to know with
absolute certainty that the bank would not report this highly suspicious activity.
Even though his relationship with Deutsche Bank was brand new, he knew the bank
would play along in even this multi-layered criminal aspect of his sexually abusive
51
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 52 of 104
international operation.
199. The abuse victims were given no choice about whether to marry one
another.
200. Epstein demanded that they comply, and the professionals closest to
Epstein choreographed the entire arrangement, from hiring and paying the crooked
201. The sham marriage scheme, which was designed solely to perpetrate
continued sexual abuse and trafficking through immigration and marriage fraud, was
just another example of Epstein’s brazen criminality that he could never have pulled
202. Epstein used Deutsche Bank for all matters relating to his criminal
sex trafficking enterprise because he knew that Deutsche Bank would disregard the
fact that Epstein was using the account as part of his sex-trafficking venture.
203. Deutsche Bank financially benefitted from the accounts that Epstein
used for his sex-trafficking operation, including the accounts for his many related
entities, the personal accounts for his longtime attorney, and the accounts for some
of his victims.
204. In addition to actual knowledge that it was facilitating the Epstein sex-
venture that it should have known had engaged in coercive sex trafficking in
206. In 2014 and into 2015, the Bank’s Anti-Financial Crime department
of his victims because Deutsche Bank was profiting handsomely from facilitating
with the Bank’s opening of a Global Markets account for Epstein. In January 2015,
during the onboarding process for that account, a Deutsche Bank AML Compliance
Epstein, including (a) a June 2014 federal appeals court ruling that some of Epstein’s
sex offenses against Epstein, and (b) additional allegations in the press regarding
53
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 54 of 104
208. AML Officer-1 escalated these issues to a more senior AML officer
(“AML Officer-2”). In response, AML Officer-2 initially noted that the same
negative allegations against Epstein had been approved by Charles Packard, the
former Head of AML and the former General Counsel for the Americas and attached
a copy of the Approval Email. AML Officer-1 responded that they should still run
the issue by the then-Head of AFC Americas because: (1) the Approval Email was
“not a direct approval by [the Head of AML Compliance for Deutsche Bank
Americas and the [then] General Counsel for Deutsche Bank Americas]; it’s a
statement by a front office MD about his conversation with them and their alleged
opinion not to escalate to Rep Risk;” (2) the Head of AML Compliance was no
longer at the Bank; and (3) there were new developments in Epstein’s case that could
regarding Epstein’s association with prominent political figures, AML Officer-2 put
the question of whether to escalate before Patrick Harris, who agreed to escalate to
the ARRC. In the email to Patrick Harris, AML Officer-2 noted that the
developments and for further background also noted, among other things, that “[b]y
2011, 40 underage girls had come forward with testimony of Epstein sexually
assaulting them” and that “Epstein [had] managed to settle at least 17 lawsuits out
54
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 55 of 104
of court.”
210. Later that month, on January 22, 2015, in preparation for the ARRC
meeting, Charles Packard and Paul Morris met in person with Epstein at his New
York home. The meeting was held in a bar adjacent to Epstein’s indoor swimming
pool, located in the basement of his Manhattan mansion. During the meeting,
Packard asked Epstein about his involvement in sex trafficking. During the meeting,
withdrawals and payments to Russian accounts that appeared suspicious in that they
may have been indicators of sex trafficking and coercive commercial sex acts.
211. Suspiciously, or tellingly, Packard and Morris did not make any
contemporaneous record of their meeting with Epstein. Other than this perfunctory
meeting with Epstein to get their stories straight, Deutsche Bank did not take any
other steps at the time to investigate the veracity of the allegations about Epstein
being involved in sex abuse and sex trafficking. The reason Deutsche Bank did not
take further steps to investigate the veracity of the allegations is because it knew that
212. On January 30, 2015, members of the ARRC, including Stuart Clarke,
Chief Operating Officer for the Americas and General Manager of Deutsche Bank’s
New York branch, and Jan Ford, a Managing Director and Deutsche Bank Americas
55
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 56 of 104
Head of Compliance and a member of the North America Executive Committee and
relationship. Despite the fact that Deutsche Bank’s policies and procedures mandate
that detailed minutes of such meetings be kept, Deutsche Bank did not make any
record of this important meeting. Deutsche Bank decided not to make a record of
this meeting because a record would have demonstrated that it knew, and was acting
in reckless disregard of the fact, that Epstein was using his Deutsche Bank accounts
to cause his victims, thorough means of force, fraud and coercion, to be sexually
213. In a recent case before this Court, it was alleged that a confidential
witness (identified only as “CW1”) reported that the way this meeting was conducted
flouted all of Deutsche Bank’s rules about how such meetings should be handled.
Specifically, the meeting at Epstein’s bar has been described as a “due diligence
meeting” by Deutsche Bank. However, Deutsche Bank’s own rules lay out how such
diligence meetings are to be conducted when dealing with his risk clients. CW1
record of the meeting, allegations are meant to be put to the client in writing and the
client is generally expected to have his lawyer or advisor, and often also his
accountant, with him.” Both sides are meant to sign off on the minutes of such
56
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 57 of 104
Bank. According to CW1, however, neither Packard nor Morris were ever
214. Later that day, a member of the ARRC emailed Charles Packard to
say, without explanation, that the committee was “comfortable with things
continuing” with Epstein, and that another member of the committee had “noted a
number of sizable deals recently.” The reason that Deutsche Bank was
“sizeable deals” it was obtaining. The sizeable deals with Epstein were very
215. The following week, another member of the ARRC, Jan Ford, the
to other executives, stating that ARRC had agreed to “continue business as usual
with Jeff Epstein” based upon Packard’s “due diligence [bar] visit with him.”
Deutsche Bank knew, and was acting in reckless disregard of the fact, that Epstein’s
usual business was the sexual abuse and coercive sex trafficking of young women
and girls.
57
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 58 of 104
216. That same email outlined three conditions that the ARRC placed on
the relationship (1) Epstein would be allowed to continue to “conduct trades and
the business had determined these transactions do not involve any unusual and/or
(2) The Bank’s Corporate Banking and Securities unit would be allowed to “also
‘open’ accounts to facilitate activity as a booking matter where the activity has
and (3) The business would “need to monitor for any further developments in
connection with the reputational risk of the client relationship and to review
described in [the first condition].” Deutsche Bank was aware that conditions such as
these were necessary (although not sufficient) to prevent Epstein from using
Deutsche Bank accounts in furtherance of sex abuse and coercive sex trafficking.
designed to create the illusion—i.e., a paper trail—that would make it appear that
Deutsche Bank was closely monitoring Epstein when, in fact, it was allowing him
to use his multiple Deutsche Bank accounts for sex abuse and sex trafficking
purposes.
58
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 59 of 104
personnel who did not have day-to-day operational authority over the Epstein
account. Deutsche Bank never communicated the conditions to those who could
same manner as they had before the ARRC meeting. The conditions thus became a
219. This failure was then substantially compounded when AML Officer-
a Russian model and Russian publicity agent, stating, “[s]ince this type of activity is
59
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 60 of 104
220. Instead of monitoring the accounts for all potential crimes and
involving adults, AML Officer- 2 only instructed the relevant transaction monitoring
team to verify, using internet searches, that any woman involved with transactions
related to the Epstein relationship was at least 18 years old and to only flag
transactions if they could not discern a rational reason for the transaction, a standard
which had little if any effect on the Bank’s furthering Epstein’s sex abuse and his
221. On July 21, 2015, Epstein requested that Deutsche Bank increase his
trading limits. Several days later, a member of Epstein’s coverage team (“Coverage
Team Member-1”), who was aware of the ARRC’s conditions on the relationship,
escalated this request to AML Officer-2, who in turn escalated the issue to the
Chairman of the ARRC. On July 29, 2015, after conferring with other members of
the ARRC but without formally meeting, the Chairman replied to AML Officer-2
stating they had no objections. The Chairman added, “I also checked in with
[Packard] last night to make sure he supports this and has heard nothing negative on
222. Again, without any due diligence and in complete disregard for the
60
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 61 of 104
crimes Epstein was perpetrating and the reputational risks he posed, Deutsche Bank
knowingly and intentionally allowed him to continue to employ the Bank’s services
1, 2021), Dkt. 37 at ¶ 92 (case later transferred to this Court, Case No. 1:22-cv-
02854-JSR).
“Accountant-1”) requested that the Bank open a brokerage account for Gratitude
America, Epstein’s private charity. Coverage Team Member-1 escalated the request
to AML Officer-2, who directed the inquiry to the Secretary for the ARRC. The
Secretary of the ARRC conferred with a member of the ARRC and ordered that an
external due diligence report be prepared on Epstein. In response to the request for
Gratitude America and withdrew the request to open the account. As a result,
224. Deutsche Bank was aware that the reason that Epstein was
withdrawing his request to open the new account was to avoid a due diligence report.
Deutsche Bank was aware that a due diligence report on Epstein would have
documented that Epstein was using Deutsche Bank accounts to facilitate his sex
61
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 62 of 104
Epstein. Although Relationship Manager-2 had Epstein’s KYC file and had been
made aware of the prior escalation of the relationship to the ARRC, he was not made
aware by anyone at the Bank of the three conditions the ARRC placed on the
European surnames at a Russian bank, and asking for an explanation of the purpose
of the wire transactions and Epstein’s relationship with the counterparties. After
FRIEND FOR TUITION FOR SCHOOL.” When the compliance officer followed
up, asking “[w]hy is this client using this account to . . . pay school tuition?,”
manage each of his properties. This is one of them. However, when making one-off
transfers to people, he and his finance staff have the flexibility to use any account
227. The compliance officer did not ask any further follow-up questions,
and the transaction was cleared. This transaction was one of many in which Epstein
62
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 63 of 104
used his Deutsche Bank accounts to further his sex abuse and sex-trafficking
venture.
228. In addition, payments from the Butterfly Trust accounts and other
Epstein accounts were used for lawsuit settlement payments to alleged victims, and
rent, legal, and immigration expenses made to or on behalf of young women whom
Epstein was sexually abusing and trafficking, including additional women with
Park Avenue (New York City) Branch from 2013 to 2017 from personal accounts
times per month, all in the amount of $7,500 per withdrawal, the Bank’s limit for
third-party withdrawals (i.e., withdrawals made by an authorized user who was not
a primary account holder). When Deutsche Bank personnel asked Attorney-1 why
Epstein needed cash, Attorney-1 replied Epstein used it for travel, tipping and
expenses.
230. Under federal regulations, banks and other financial institutions must
63
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 64 of 104
file Currency Transaction Reports (“CTRs”) with the U.S. Treasury Department
when there are cash transactions with an individual in excess of $10,000 in one day.
referred to as “structuring.”
231. In May 2014, Attorney-1 inquired into how often he could withdraw
cash on behalf of Epstein without triggering an alert. Around the same time,
Attorney-1 “asked how often they could come in to withdraw cash without creating
some sort of alert,” and asking “Is it once a week? Twice a week? Once every other
week?”
Specifically, in July 2017, Attorney-1 had, among other things, asked a teller
upon being advised that it would, broke up the withdrawal transaction over two days.
In July of that year, members of the Bank’s Wealth Management AML transaction
from his own and Epstein’s accounts. In 2018, just prior to the Bank’s closing of the
Park Avenue Branch, which was located nearby Epstein’s house, Attorney-1
64
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 65 of 104
Attorney-1 withdrew these sums from the Bank, Attorney-1 reported that Epstein
needed the funds for tipping and household expenses—and explanation that was not
Epstein’s behalf more than $800,000 in cash from Epstein’s personal accounts.
Throughout the Epstein relationship, Deutsche Bank never sought or received any
explanation for Epstein’s cash activity beyond the general travel, tipping, and
Deutsche Bank. Attorney 1 withdrew substantial amounts of cash from his accounts
and transferred money from Epstein controlled accounts to his accounts as payment
or his participation in activities to further his sex abuse and his sex-trafficking
235. In light of all of these red flags, in addition to its actual knowledge
that they were facilitating the Epstein sex-trafficking venture, Deutsche Bank should
have known that it was facilitating sex abuse and a sex-trafficking venture that was
236. In a recent case before this Court, it was alleged that a confidential
witness (identified only as “CW1”) reported that Epstein was retained as a client
65
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 66 of 104
only after discussion at Deutsche Bank’s Board level. Karimi v. Deutsche Bank
2022).
237. In the same recent case before this Court, it was alleged that a
confidential witness (identified only as “CW8”) reported that “Deutsche Bank had a
KYC [Know Your Customer] ‘special deal’ for Epstein and other high-net-worth
individuals. CW8 explained that such individuals were not required to submit to the
Bank Aktiengesellschaft, Case No. 22-cv-2854-JSR (S.D.N.Y. June 13, 2022), Dkt.
86 at 7.
238. In the same recent case before this Court, a confidential witness
(“CW8”) explained that “after Epstein was onboarded, decisions about whether to
Bank’s Reputational Risk Committee. ‘He would go up, get approved, go up, get
approved,’ CW8 said. CW8 noted that the people who sat on Deutsche Bank’s
were interested solely in making money for the Bank.” Karimi v. Deutsche Bank
7.
66
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 67 of 104
that from the time of Epstein’s onboarding, the relationship was classified by
Deutsche Bank as “high-risk” and therefore should have been subject to enhanced
due diligence. Instead, in an ironic twist, the Bank designated as an “Honorary PEP”
such thing as an honorary PEP. You are either a PEP or you aren’t. I suspect they
use this term to fudge things. Epstein was certainly very high risk …. But Deutsche
Bank did not treat him as a high-risk client. I think the phrase ‘honorary PEP has
100, Karimi et al. v. Deutsche Bank Aktiengesellschaft et al., Case No. 2:20-cv-
08978-ES-JRA (D.N.J. Mar. 1, 2021), Dkt. 37 at ¶ 100 (case later transferred to this
journalistic report entitled: Perversion of Justice, which rehashed old news stories
about Jeffrey Epstein and his publicly known history of sexual abuse. While the
series did not contain any new information, it resurfaced previously publicized
information about Jeffrey Epstein’s sexual abuse of ‘women, now in a post #metoo
world.
67
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 68 of 104
241. With the world once again talking about Jeffrey Epstein’s long known
history for committing sex crimes, Deutsche Bank got nervous it would be exposed
relationship with Epstein, the Bank informed Epstein by letter that they would no
243. Despite the Bank’s decision to offboard all Epstein accounts due to
financial institutions, on Deutsche Bank letterhead, indicating in one such letter that
he was “unaware of any problems relating to the operation or use of [the] accounts.”
Epstein’s sexual abuse and the sex-trafficking venture from the public until around
July 2020.
that institution is required to conduct due diligence commensurate with that risk and
what the risk is. Deutsche Bank knowingly, intentionally, deliberately, and
246. After reviewing Deutsche Bank’s relationship with Epstein, the New
68
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 69 of 104
York Banking Regulators concluded that “although the Bank properly classified
Epstein as high-risk, the Bank failed to scrutinize the activity in the accounts for the
247. The Bank was well aware not only that Epstein had pled guilty and
served prison time for engaging in sex with a minor but also that there were public
allegations that his conduct was facilitated by several named co- conspirators.
248. Despite this knowledge, the Bank did little or nothing to inquire into
numerous young women, or to inquire how Epstein was using, on average, more
249. Epstein used the $200,000 per year in cash to facilitate his sex abuse
and his sex-trafficking venture. As the New York Banking Regulators concluded,
the fact that the cash withdrawals “were suspicious should have been obvious to
Bank personnel at various levels.” In fact, Bank personnel at various level did
recognize that the transactions were being used by Epstein to facilitate his sex abuse
Epstein led it to deliberately avoid taking steps that would have documented its
history, the initial onboarding of the first Epstein account was not reviewed by the
69
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 70 of 104
Bank’s regional reputational risk committee but was instead approved in what
appears to have been an off-hand conversation reflected only in the Approval Email.
That Approval Email was then relied upon, substantially without additional scrutiny,
251. When the relationship was finally elevated to the full ARRC in early
2015, no minutes were taken of that meeting, contrary to Deutsche Bank policy.
purported due diligence meeting between two front-office personnel and Epstein
not transmitted to the majority of the relationship team; and (b) were misinterpreted
by a compliance officer in a way that resulted in very little change in how the
monitoring of the accounts occurred going forward. As the New York Banking
transactions were ever questioned, and when they were, they were usually cleared
the Bank’s services to cover up old crimes and to facilitate new ones—a major
70
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 71 of 104
compliance failure and reputational stain on the bank. See Second Amended
Epstein sex abuse and sex-trafficking venture was not a “one off.” To the contrary,
its deliberate participation fits within a pattern and practice of Deutsche Bank
profiting by undertaking illegal “high risk, high reward” clients. See generally
Opinion and Order, Karimi v. Deutsche Bank Aktiengesellschaft et al., Case No. 22-
Deutsche Bank executives “routinely overruled compliance staff so that the Bank’s
risk, ultra-rich clients, such as Russian oligarchs, the convicted sex trafficker Jeffrey
255. As discussed above, the “special deal” that Epstein received from
Deutsche Bank in not being required to provide the normally required Know Your
Customer document was extended to other high net worth individuals. Deutsche
71
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 72 of 104
Bank gave this “special deal” because of the amount of business these individuals
Dkt. 37 at ¶ 101 (case later transferred to this Court, Case No. 1:22-cv-02854-JSR).
256. As part of a similar pattern and practice to has it did for Jeffrey
Epstein, Deutsche Bank routinely onboarded without due diligence and serviced
financial and other crimes they helped to perpetrate. Second Amended Complaint,
ES-JRA (D.N.J. Mar. 1, 2021), Dkt. 37 at ¶ 103 (case later transferred to this Court,
257. In a similar pattern to what it did for Jeffrey Epstein, Deutsche Bank
258. In a similar pattern to what it did for Jeffrey Epstein, Deutsche Bank
259. In a similar pattern to what it did for Jeffrey Epstein, Deutsche Bank
onboarded and serviced a billionaire who was a relative of one of the founders of Al
260. In a similar pattern to what it did for Jeffrey Epstein, Deutsche Bank
72
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 73 of 104
onboarded and serviced Germán and José Efromovich despite their links to a
261. Deutsche Bank’s pattern and practice has been exposed in multiple
ways. For example, in 2015, Deutsche Bank agreed to pay a combined $2.5 billion
in fines—a $2.175 billion fine by American regulators and a €227 million penalty
2012. The company also pleaded guilty to wire fraud, acknowledging that at least 29
262. For another example, in November 2015, Deutsche Bank was ordered
to pay $258 million in penalties imposed by the New York State Department of
Financial Services and the U.S. Federal Reserve Bank after the bank was caught
doing business with Burma, Libya, Sudan, Iran and Syria, which were under U.S.
$7.2 billion settlement with the U.S. Department of Justice over its sale and pooling
of toxic mortgage securities in the years leading up to the 2008 financial crisis. As
part of the agreement, Deutsche Bank was required to pay a civil monetary penalty
of $3.1 billion and provide $4.1 billion in consumer relief, such as loan forgiveness.
264. For another example, in January 2017, the bank was fined $425
million by the New York State Department of Financial Services and £163 million
73
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 74 of 104
in the Epstein sex-trafficking venture and its other illegal behavior is that Deutsche
Bank intentionally planned to profit from being the banker for individuals and
organizations that other banks knew they could not lawfully handle. For Deutsche
Bank, this “high risk, high reward” approach ensured—and continues to ensure—
that it will earn greater profits than would come from complying with the law.
266. The statute of limitations under the TVPA is ten years after the cause
of action arose, or ten years after the victim reaches eighteen years of age, if the
victim was a minor at the time of the alleged offense. 18 U.S.C. § 1595(c)(1), (2).
The TVPA causes of actions for Jane Doe 1, and the other Class Members, all arose
267. The New York Adult Survivor’s Act has opened up a one-year revival
268. RICO does not establish a precise statute of limitations. In this case,
the RICO enterprise continued and caused injury through December 2018, as
74
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 75 of 104
Epstein sex trafficking venture through around July 20, 2020, when Deutsche Bank
and the New York banking regulators publicly announced a civil settlement for
Deutsche Bank’s violation of its obligations in connection with Jeffrey Epstein’s sex
trafficking. As a result, any applicable statute of limitations was equitable tolled until
270. Plaintiff did not have the means and resources to uncover Deutsche
Bank’s role in facilitating their sexual abuse and sex trafficking until New York
271. Plaintiff brings this action pursuant to Federal Rule of Civil Procedure
All women who were sexually trafficked by Jeffrey Epstein during the
time when Deutsche Bank maintained bank accounts for Epstein and/or
Epstein related-entities, which was in or about August 19, 2013,
through in or about December 31, 2018, both dates inclusive (the “Class
Period”).
272. Plaintiff reserves the right to seek leave to modify this definition,
including the addition of one or more subclasses, after having the opportunity to
conduct discovery
impracticable, in satisfaction of Fed. R. Civ. P. 23(a)(1). The exact size of the Class
and the identities of the individual Class members are ascertainable through records
75
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 76 of 104
maintained by the Epstein estate executors and the Defendants, including but not
274. Typicality: Plaintiff’s claims are typical of the claims of the other
Class members she seeks to represent. The claims of Plaintiff and the other Class
members are based on the same legal theories and arise from the same unlawful
275. Commonality: There are many questions of law and fact common to
the claims of Plaintiff and the other Class members, and those questions predominate
over any questions that may affect only individual Class members, within the
meaning of Fed. R. Civ. P. 23(a)(2) and (b)(3). Class treatment of common issues
276. Common questions of fact and law affecting Class members include,
277. Absent a class action, most of the Class members would find the cost
The class treatment of common questions of law and fact is also superior to multiple
courts and the litigants and promotes consistency and efficiency of adjudication.
278. Adequacy: Jane Doe 1 will fairly and adequately represent and protect
the interests of the other Class members she seeks to represent. Jane Doe 1 has
class actions. Plaintiff and her counsel are committed to vigorously prosecuting this
action on behalf of the other Class members and have the financial resources to do
77
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 78 of 104
so. Neither Plaintiff nor her counsel have any interests adverse to those of the other
Class members.
279. This action has been brought and may properly be maintained as a
class action against Defendant pursuant to Rule 23 of the Federal Rules of Civil
tend to establish inconsistent standards of conduct for Defendants and result in the
impairment of Class Member’s rights and the disposition of their interests through
efficiently, and without the unnecessary duplication of effort and expense that
and be aggrieved and Defendants will continue to violate New York and federal law
without remedy;
78
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 79 of 104
administration of class claims, economies of time, effort and expense will be fostered,
f. Plaintiff and her counsel are unaware of any class action brought
business with Jeffrey Epstein in this District and Class Members were consequently
COUNT I
PARTICIPATING IN A SEX-TRAFFICKING VENTURE IN VIOLATION
OF THE TRAFFICKING VICTIMS PROTECTION ACT,
18 U.S.C. §§ 1591(a)(2), 1595
282. Plaintiff Jane Doe 1 brings this Count individually and on behalf of the
interstate and foreign commerce, together and with others, in violation of 18 U.S.C.
79
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 80 of 104
§ 1591(a)(2).
and received value for, its participation in the sex-trafficking venture, in which
Epstein, with Defendant’s knowledge, or its reckless disregard of the fact, that
Epstein 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.
285. Among the financial benefits that the Deutsche Bank received for
funds that Epstein and Epstein-controlled entities made to Deutsche Bank. Deutsche
Bank profited from the use of these deposits. Epstein and Epstein-controlled entities
deposited these funds in exchange for Deutsche Bank’s facilitation and participation
286. Among the financial benefits that the Defendants received for
opportunities from Epstein and his co-conspirators. Deutsche Bank profited from
these referred business opportunities. Epstein referred business entities and business
287. Deutsche Bank financially profited from the deposits made by Epstein
80
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 81 of 104
288. Deutsche Bank knew, and was in reckless disregard of the fact, that it
was Epstein’s pattern and practice to use the channels and instrumentalities of
interstate and foreign commerce, to entice, recruit, solicit, harbor, provide, obtain,
and transport young women and underage girls for purposes of causing commercial
289. Deutsche Bank and its employees had actual knowledge that they
were 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,
Defendants 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
participated in the sex trafficking conspiracy and led Jane Doe 1, as well as other
81
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 82 of 104
members of the Class, to believe that they would be rewarded if they cooperated and
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 1 as well as other members of the Class. Defendants’ conduct was
facilitating the Epstein sex-trafficking venture, the Defendants also should have
known that it was participating in and facilitating a venture that had engaged in
means of obtaining economic success and promotion within the Deutsche Bank
hierarchy.
296. Defendants’ knowing and intentional conduct has caused Jane Doe 1
and the other members of the Class serious harm including, without limitation,
82
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 83 of 104
297. Defendants’ knowing and intentional conduct has caused Jane Doe 1
and the other members of the Class harm that is sufficiently serious, under all the
298. This case does not involve mere fraud. Instead, Defendants’ tortious
conduct in violating the TVPA was outrageous and intentional, because it was in
specifically at Jane Doe 1 and other members of the class, who were the victims of
a pattern and practice of Deutsche Bank profiting by undertaking illegal “high risk,
1591(a)(2), 1595, Defendants are liable to Jane Doe 1 and the other members of the
Class for the damages they sustained and reasonable attorneys’ fees.
83
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 84 of 104
§§ 1591(a)(2), 1595, Defendants are liable to Jane Doe 1 and other members of the
COUNT II
CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING
VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c),1595
303. Plaintiff Jane Doe 1 brings this Count individually and on behalf of
trafficking venture to coerce commercial sex acts from Jane Doe 1 and other Class
further the Epstein sex-trafficking venture and with the purpose of facilitating
recruiting, enticing, coercing, harboring, transporting, and inducing Jane Doe 1 and
84
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 85 of 104
other Class members to engage in commercial sex acts, through providing financial
financial relationship between Deutsche Bank and Epstein within this District.
308. Acting within this District and in furtherance of the Epstein sex-
trafficking venture, on or about August 19, 2013, Deutsche Bank opened brokerage
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.
310. 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.
venture was intentional and willful and, therefore, Deutsche Bank intentionally and
85
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 86 of 104
willfully caused Epstein’s commission of the commercial sex acts with Jane Doe 1
and other Class members through its affirmative and overt acts supporting Epstein.
312. Deutsche Bank knew, or acted in reckless disregard of the fact, that
its acts and conduct supporting and facilitating Epstein would lead to unlawful
coercive commercial sex acts by Epstein with young women and girls, including
313. Deutsche Bank conspired with Epstein through their affirmative acts
and provided substantial support to Epstein committing commercial sex acts upon
314. In addition to acting with knowledge that they were supporting the
participating in the Epstein sex-trafficking venture which Deutsche Bank also should
have known that had engaged in coercive sex trafficking in violation of 18 U.S.C. §
1591(a)(1).
315. Defendants’ conduct has caused Jane Doe 1 and other Class members
reputational harm.
316. Defendants’ conduct has caused Jane Doe 1 harm that is sufficiently
86
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 87 of 104
317. This case does not involve mere fraud. Instead, Defendants’ tortious
conduct in conspiring to violate the TVPA was outrageous and intentional, because
specifically at Jane Doe 1 and other members of the class, who were the victims of
Defendants are liable to Jane Doe 1 and the other members of the Class for the
U.S.C. §§ 1594(c), 1595, Defendants are liable to Jane Doe 1 and other members of
COUNT III
ATTEMPT TO COMMIT VIOLATIONS OF THE TRAFFICKING VICTIM
PROTECTION ACT, 18 U.S.C. §§ 1594(a), 1595
321. Plaintiff Jane Doe 1 brings this Count individually and on behalf of
87
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 88 of 104
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).
to violate 18 U.S.C. § 1591(a) providing financial support for the Epstein sex-
trafficking venture.
326. Acting within this District and in attempting to further the Epstein
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.
88
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 89 of 104
328. It was part of the attempt to violate 18 U.S.C. 1591(a) 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
commercial sex acts with Jane Doe 1 and other Class members through its
330. Defendants knew and acted in reckless disregard of the fact, that its
acts and conduct supporting and facilitating Epstein would lead to sexual abuse and
unlawful coercive commercial sex acts by Epstein with young women and girls,
331. In addition to acting intentionally and with knowledge that they were
have known that had engaged in coercive sex trafficking in violation of 18 U.S.C. §
1591(a)(1).
332. This case does not involve mere fraud. Instead, Defendants’ tortious
89
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 90 of 104
conduct in attempting to violate the TVPA was outrageous and intentional, because
high degree of moral turpitude and demonstrated such wanton dishonesty as to imply
directed specifically at Jane Doe 1 and other members of the class, who were the
333. Defendants conduct has caused Jane Doe 1 and other Class members
reputational harm.
Defendants are liable to Jane Doe 1 and the other members of the Class for the
U.S.C. §§ 1594(a), 1595, Defendants are liable to Jane Doe 1 and other members of
COUNT IV
CIVIL RICO, 18 U.S.C. §§ 1962, 1964(c)
337. Plaintiff Jane Doe 1 brings this Count individually and on behalf of
90
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 91 of 104
partnership, corporation, association, or other legal entity, and any union or group
340. The Epstein sex trafficking enterprise engaged in, and had activities
341. The Epstein sex trafficking enterprise consisted of more than Epstein
and Epstein’s own employees and agents. It also included other persons, including
association in fact.
but were not limited to, Defendant Deutsche Bank, Jeffrey Epstein, Attorney-1,
Sarah Kellen, Leslie Groff, Adriana Ross, Nadia Marcinkova, defendants Charles
91
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 92 of 104
Packard, defendant Patrick Harris, defendant Paul Morris, and Jan Ford. These
individuals knew of, and agreed to, the general criminal objective of the Epstein sex
trafficking enterprise. These individuals also agreed that Deutsche Bank would
343. The Epstein sex trafficking enterprise had a shared and common
purpose—securing young women and girls for Epstein to sexually abuse and to
344. The Epstein sex trafficking enterprise had a relationship among the
Deutsche Bank’s employees and agents. The associates coordinated their actions to
facilitate the actions of the sex trafficking enterprise, including ensuring that the
345. The Epstein sex trafficking enterprise lasted from (at least) around
2013 through around December 2018, permitting the associates in the enterprise to
enterprise, many young women and girls were sexually abused and sexually
trafficked by Epstein. In this way, those involved in the enterprise helped it achieve
346. Deutsche Bank and others acting in concert with them as part of the
92
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 93 of 104
persons), to wit, the acts in violation of 18 U.S.C. § 1591 alleged in Count I and
347. Deutsche Bank received income derived directly and indirectly from
and other things of value from financially supporting and participating in the Epstein
348. Deutsche Bank and its employees participated directly and indirectly
trafficking.
349. Deutsche Bank and others acting in concert with them as part of the
meaning of RICO, 18 U.S.C. §1961(5), when they committed two or more separate
acts constituting a pattern of racketeering activity, the last of which occurred within
ten years after the commission of a prior act of racketeering activity. Specifically,
Deutsche Bank and others in the enterprise committed multiple acts in violation of
18 U.S.C. § 1962(a)-(d) over the course of several years from about 2013 to about
December 2018, during which time Plaintiff were sexually assaulted and sexually
93
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 94 of 104
trafficked.
about August 19, 2013, Deutsche Bank opened brokerage accounts for Southern
the U.S. Virgin Islands in 2011, and Southern Financial LLC, a wholly owned
subsidiary of Southern Trust Company Inc. Opening these accounts for the Epstein
sex trafficking enterprise constituted acts which were indictable under 18 U.S.C. §
the course of its relationship with the Epstein sex trafficking enterprise from about
2013 to December 2018, Deutsche Bank would open and allow Epstein to fund more
than 40 accounts at Deutsche Bank. Opening these accounts for the Epstein sex
trafficking enterprise constituted acts which were indictable under 18 U.S.C. § 1581-
the course of its relationship with the Epstein sex trafficking enterprise, Deutsche
Bank sent over 120 wires totaling $2.65 million to beneficiaries of the Butterfly
paying directly for commercial sex acts, funds paid to professionals for carrying out
illegal acts for the operation of the sex-trafficking venture, and paying funds to
94
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 95 of 104
others for committing crimes necessary to continue the operation of the sex
trafficking venture. Sending the wires for the Epstein sex trafficking enterprise
constituted acts which were indictable under 18 U.S.C. § 1581-92, for the reasons
described above.
accounts to pay for coerced commercial sex acts by Jane Doe 1. Helping Epstein
provide the funding for commercial sex acts constituted acts of racketeering activity
because they were indictable under 18 U.S.C. § 1581-92, for the reasons described
above.
substantial period of time—i.e., during the multiple years that Deutsche Bank
“unlawful for any person employed by or associated with any enterprise engaged in,
a pattern of racketeering activity ….” Deutsche Bank were associated with the
enterprise and they conducted or participated (directly and indirectly) in the conduct
95
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 96 of 104
356. Jane Doe 1 and other members of the class were directly and
357. Among the injuries that Plaintiff directly and proximately suffered
economic consequences and damage from the sexual abuse and sex trafficking by
Epstein.
358. The injuries that Plaintiff directly and proximately suffered from
included, in addition, economic injuries and injuries to the Plaintiff’ business and
property.
serious and permanent economic harm, including, without limitation, financial harm,
including harm to their careers and business and professional prospects. Defendants’
violations continue to cause economic harm and injury to Jane Doe 1 and other
360. Under 18 U.S.C. § 1964(c), Jane Doe 1 and the other members of the
class are entitled to recover from Defendants the “threefold the damages” they have
sustained, and the cost of the suit, including reasonable attorneys’ fees.
96
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 97 of 104
COUNT V
INTENTIONAL AND NEGLIGENT ACTS AND OMISSIONS UNDER
THE NEW YORK ADULT SURVIVORS ACT,
NEW YORK CPLR § 214-j.
362. Plaintiff Jane Doe 1 brings this Count individually and on behalf of
363. Pursuant to New York Civil Practice Law and Rules § 214-j, this
Count for intentional and negligent acts and omissions has been timely filed, as every
civil claim or cause of action brought against any party alleging intentional and
as defined in article one hundred thirty of the penal law committed against such
person who was eighteen years of age or older was revived effective November 24,
2022.
Bank within this District and elsewhere directly and proximately resulted in the
commission of sexual offenses by Epstein and his co-conspirators under the laws of
the State of New York (e.g., New York Penal Law Art. 130, including New York
Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66), which injured Plaintiff
365. As a financial institution operating within this District and within the
State of New York, Deutsche Bank owed legal duties to Plaintiff Jane Doe 1 and the
(including Jeffrey Epstein) for the purpose of preventing them from facilitating and
engaging in foreseeable criminal activity using the Bank’s facilities that could harm
366. All employees of Deutsche Bank also owed these same legal duties
367. The legal duties of Deutsche Bank described in the two preceding
paragraphs also extended to the other Class members whom Plaintiff Jane Doe 1
seeks to represent.
368. The legal duties of Deutsche Bank include, but are not limited to, the
Know Your Customer (“KYC”) laws and related regulations described above.
369. Under KYC laws, banks have special duties to inquire about possible
crimes being committed by their 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 are being harmed. The regulations establish
370. Deutsche Bank breached their legal duties to Plaintiff Jane Doe 1 and
the Class Members by failing to discharge their legal duties to prevent Jeffrey
98
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 99 of 104
Epstein and others from using the Bank’s facilities to facilitate and commit criminal
activity harming the Plaintiff. The criminal activity that harmed the Plaintiff and
Class Members included foreseeable federal crimes committed by the Epstein sex
Deutsche Bank, Plaintiff Jane Doe and the Class Members repeatedly suffered
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.
372. The breaches of legal duties were the direct—i.e., the but-for—cause
of these injuries. Without Defendants’ breaches of legal duties, those injuries would
not have occurred. The injuries that occurred were readily foreseeable to Deutsche
Bank.
373. 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.
374. The injuries that Plaintiff Jane Doe 1 and the Class Members suffered
committed by Epstein and other co-conspirators and criminalized under article 130
99
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 100 of 104
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,
Plaintiff Jane Doe 1 and the Class Members to repeatedly suffer injuries from
Epstein and his co-conspirators, including sexual assaults and resulting emotional
distress, mental pain and suffering, and other physical and psychological trauma.
These injuries were easily foreseeable, because Deutsche Bank knew, and acted in
reckless disregard of the fact, that their actions and omissions supporting and
facilitating Epstein would lead to (among other crimes) sex offenses by Epstein and
his co-conspirators forbidden by article 130 of New York Penal Law against his
376. In the exercise of reasonable care, Deutsche Bank and its employees
knew or should have known of the dangerous propensities of Jeffrey Epstein and the
proximately harm that would be caused by his likely sexual crimes and various
377. Deutsche Bank could reasonably foresee that their actions and
100
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 101 of 104
offenses against Plaintiff and the Class Members. Among other things, the
Defendants were specifically aware that Epstein had previously been prosecuted for
similar sex crimes and previously paid numerous civil settlements associated with
similar sex crimes. Indeed, the Defendants were 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
378. Plaintiff Jane Doe 1 and the Class Members were easily within the
zone of foreseeable harm from the Defendants’ reckless and negligent acts and
omissions. The Defendants’ 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, Plaintiff Jane Doe 1 and the Class
379. The sex offenses Jeffrey Epstein committed against Plaintiff Jane Doe
1 and the Class Members were easily within the zone of foreseeable risks that the
Defendants created with their reckless and negligent actions and omissions. Those
actions and omissions foreseeably risked further sex crimes by Jeffrey Epstein and
101
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 102 of 104
380. 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
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
and other members of the class, who were the victims of Epstein’s sexual abuse and
described in this Count, Plaintiff Jane Doe 1 and the Class Members have sustained
indifference to civil obligations, Defendants are liable to Jane Doe 1 and other
Jane Doe 1 respectfully requests that the Court enter judgment in her favor,
a. That the Court certify the Class, name Jane Doe 1 as Class
102
Case 1:22-cv-10018 Document 1 Filed 11/24/22 Page 103 of 104
b. That the Court award Plaintiff and the other members of the Class
c. That the Court award punitive and exemplary damages and treble damages
d. That the Court award to Plaintiff the costs and disbursements of the
e. That the Court award pre- and post-judgment interest at the maximum
f. That the Court grant all such other and further relief as it deems just and
proper.
JURY DEMAND
Respectfully Submitted,
EDWARDS POTTINGER, LLC
EDWARDS POTTINGER
Brittany N. Henderson
1501 Broadway
Floor 12
New York, New York
(954)-524-2820
Fax: (954)-524-2822
Email: [email protected]
Paul G. Cassell
Pro Hac Vice
S.J. Quinney College of Law at the
University of Utah
383 S. University St.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail: [email protected]
David Boies
Boies Schiller Flexner LLP
55 Hudson Yards
New York, New York
Telephone: (212) 446-2300
Facsimile: (212) 446-2350
E-mail: [email protected]
Sigrid McCawley
Boies Schiller Flexner LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL 33316
Telephone: (954) 356-0011
Facsimile: (954) 356-0022
E-mail: [email protected]
Pro Hac Vice Pending
104