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UNITED STATES DISTRICT COURT FOR THE 
SOUTHERN DISTRICT OF NEW YORK 
Jane Doe 1, individually 
) 
and on behalf of all others similarly 
) 
situated, 
) 
) 
Plaintiff, 
) 
) 
) 
v. 
) 
) 
Deutsche Bank 
) 
Aktiengesellschaft, 
) 
Deutsche Bank AG New York 
) 
Branch, Deutsche Bank Trust 
) 
Company Americas, 
) 
) 
Defendants. 
) 
/ 
FIRST AMENDED CLASS 
ACTION COMPLAINT 
JURY TRIAL DEMANDED 
Case No.: 22-cv-10018-JSR 
FIRST AMENDED INDIVIDUAL AND CLASS ACTION COMPLAINT 
Plaintiff Jane Doe 1 files this first amended individual and civil class action 
complaint for damages and other relief under (among other provisions of law) the 
United States federal anti-sex-trafficking statute, 18 U.S.C. §§ 1591-95, et seq.—
the Trafficking Victim Protection Act ("TVPA")—and 18 U.S.C. §§ 1961-68, et 
seq.—the Racketeer Influenced and Corrupt Organizations Act ("RICO"), as well as 
for aiding and abetting, intentional infliction of emotional distress and negligence 
related to the commission of chapter one hundred thirty New York sex offenses, 
timely under the New York Adult Survivors Act. This suit arises from Defendants 
Deutsche Bank Aktiengesellschaft's, Deutsche Bank AG New York Branch's, and 
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Deutsche Bank Trust Company America's (hereinafter referred to collected as 
"Deutsche Bank"), participating in and financially benefitting from their direct and 
intentional involvement in Jeffrey Epstein's sex-trafficking venture by providing the 
financial lifeblood and infrastructure for the venture's continued operation. 
Deutsche Bank knowingly benefited and received things of value for assisting, 
supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey 
Epstein sex-trafficking organization to successfully rape, sexually assault, and 
coercively sex traffic Plaintiff 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 (sexual misconduct), 130.35 (rape in the first 
degree), 130.50 (criminal sexual acts in the first degree), 130.52 (forcible touching), 
130.66 (aggravated sexual abuse in the third degree) and 130.70 (aggravated sexual 
abuse in the first degree). Deutsche Bank aided and abetted those crimes, as well as 
acted in a negligent manner to directly and proximately cause those crimes, enabling 
Epstein to commit such offenses against countless young women. 
Deutsche Bank also knew that Epstein would use means of force, threats of 
force, fraud, abuse of legal process, 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. 
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Knowing that they would earn millions of dollars from facilitating Epstein's sex 
trafficking, and from its relationship with Epstein, Deutsche Bank chose financial 
gain over following the law. Specifically, Deutsche Bank chose to facilitate a sex 
trafficking operation in order to churn profits. 
Jane Doe makes the following allegations on information and belief and 
believes that substantial additional evidentiary support will exist for the allegations 
set forth herein after a reasonable opportunity for discovery: 
I. JURISDICTION, VENUE, AND TIMELINESS 
1. 
This action is brought pursuant to various federal and state statutes, 
including the TVPA, 18 U.S.C. § 1589 through § 1595. This Court has federal-
question subject-matter jurisdiction pursuant to 28 U.S.C. §1331, because Jane Doe 
1—individually and on behalf of the other Class Members—proceeds under the 
TWA. 
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. 
3. 
This Court is "an appropriate district court of the United States" in 
accordance with18 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 Jeffrey Epstein, his co-
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conspirators, and Deutsche Bank all conducted substantial activities in this District. 
Deutsche Bank 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. 
4. 
These acts of sexual abuse and commercial sex committed by Jeffrey 
Epstein and certain select friends of his often took place in 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 from which to 
transport them to other locations outside of New York. 
5. 
A substantial part of the acts, events, and omissions giving rise to this 
cause of action occurred in this District. 
6. 
This action has been timely filed pursuant to 18 U.S.C. § 1595(c)(1), 
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 involves a long-
running conspiracy, which Deutsche Bank joined while it was on-going. Deutsche 
Bank ratified the earlier-committed acts of the conspiracy. This action is also timely 
under RICO and New York's Adult Survivors Act. 
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II. PARTIES 
7. 
Jane Doe 1 is a United States citizen and was at all relevant times a 
resident of and domiciled in the State of New York. 
8. 
Jane Doe 1 is using a pseudonym to protect her identity because of the 
sensitive and highly personal nature of this matter, which involves sexual assault and 
abuse. See Order Granting Motion for Leave to Proceed Anonymously, Dkt. 28. 
9. 
Jane Doe 1 is also at serious risk of retaliatory harm because the co-
conspirators who participated in the Epstein sex-trafficking venture had—and 
continue to possess-tremendous wealth and power and have demonstrated a clear 
ability to cause her serious harm. 
10. 
Jane Doe l's safety, right to privacy, and security outweigh the public 
interest in her identification. 
11. 
Jane Doe l's legitimate concerns outweigh any prejudice to Defendants 
by allowing her to proceed anonymously. 
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 many of these other 
women are known to Defendants and in other proceedings the identities of the other 
Epstein victims have been protected. 
13. 
Defendant Deutsche Bank AG is a global financial institution 
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headquartered in Frankfurt, Germany. 
14. 
Defendant Deutsche Bank AG is licensed by the New York State 
Department of Financial Services to operate a foreign bank branch in the State 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 
("DBTCA"), which is likewise licensed and supervised by the Department. 
15. 
Unless otherwise indicated, the three Defendants—Deutsche Bank AG, 
the New York Branch, and DBTCA—are referred to collectively as "Deutsche 
Bank" in this complaint. 
16. 
Defendants Deutsche Bank AG, the New York Branch, and DBTCA all 
currently conduct substantial business in this District and conducted substantial 
business at the time of events covered in this complaint. 
17. 
As one example of business conducted in this District, Deutsche Bank 
ordinarily trades shares on the New York Stock Exchange, located in this District. 
As another example, Deutsche Bank maintains branch banks within this District. 
18. 
Deutsche Bank's financial activities, including the events alleged 
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, 
interstate telephone communications, and the facilities of national securities 
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markets. 
19. 
Deutsche Bank is responsible, under United States law and otherwise, 
for the acts of its officers, directors, employees, and agents, including for the acts 
described in this complaint. The acts alleged were committed by Deutsche Bank's 
officers, directors, employees, and agents within the scope of their employment and 
with the intention, at least in part, to benefit Deutsche Bank. 
20. 
Numerous Deutsche Bank employees, including Paul Morris, Charles 
Packard and Patrick Harris, were integral in onboarding Epstein and the many 
Epstein-related entities to Deutsche Bank. 
21. 
Paul Morris joined Deutsche Bank as a relationship manager in 
November 2012. During his tenure, he was involved in bringing Jeffrey Epstein 
over to Deutsche Bank from JP Morgan Chase as a client and maintaining Epstein 
as a client. 
22. 
Charles Packard was co-head of Deutsche Bank's Wealth Management 
Americas Group when Epstein became a client. Packard was involved in approving 
Epstein as a Deutsche Bank client and maintaining Epstein as a client. 
23. 
Patrick Harris was the Chief Operating Officer of Wealth Management 
Americas for Deutsche Bank. Harris was involved in approving and maintaining 
Epstein as a Deutsche Bank client. 
III. INTRODUCTION 
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A. Overview of the Jeffrey Epstein Sex-Trafficking Venture and Conspiracy. 
24. 
Before Jeffrey Epstein was ever brought over to Deutsche Bank, he was 
well known as a registered sex offender and sex trafficker who spent his day-to-day 
life sexually abusing young females and constantly recruiting others. He had 
previously established a sex-trafficking venture and conspiracy, which was on-going 
at the time Deutsche Bank became his banker. That conspiracy began in 1998, if not 
earlier. 
25. 
Epstein's sex-trafficking venture operated in many respects as a sex-
themed cult designed to ensnare vulnerable young women and indoctrinate them into 
Epstein's carefully constructed world in which Epstein was their messiah and sex 
abuser. 
26. 
Each victim was led to believe 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 would protect them; but disobey him, and he would punish them and cause 
them serious harm from which they could never recover. 
27. 
Once in Epstein's clutches, each victim was taught and led to believe 
that she must be completely compliant with every wish or demand Epstein had for 
her; otherwise, she would certainly suffer serious reputational, financial, property, 
and psychological harm. By using these and other means of force, threats of force, 
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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. 
28. 
As is evident from this complaint and public reporting on Epstein, he 
was indeed an enormously powerful man, known to have close personal 
relationships with former U.S. Presidents, politicians, billionaires, other world 
leaders, and British Royalty, and to have the backing and support of powerful 
banking institutions which was essential to maintaining Epstein's persona as a 
respectable and powerful person despite the fact that he was a sex-trafficking serial 
abuser. 
29. 
Epstein began his sex-trafficking venture and conspiracy in 1998 and 
perhaps earlier. 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 with a 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 conceal its sex trafficking from law enforcement organizations. And his 
venture operated with a purpose to provide financial and other benefits to those who 
assisted and enabled the venture. 
30. 
The Epstein sex-trafficking venture and conspiracy was well-structured 
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from at least 1998 and grew increasingly more powerful as it victimized more young 
women. 
31. 
Epstein did not, and could not, act alone. He created and maintained 
his sex-trafficking venture and conspiracy with the assistance of other influential 
individuals and entities who knew he was sexually trafficking young women and 
girls yet supported his sex-trafficking operation in order to obtain financial and other 
favors from Epstein. 
32. 
Epstein's sex-trafficking venture and conspiracy was not possible 
without the assistance and knowing complicity of a financial institution—
specifically, a banking institution—which provided his operation not only with the 
means to conduct sex trafficking but also with an appearance of legitimacy, thereby 
ensuring its continued operation without fear of being reported to law enforcement 
or being arrested. Without the financial institution's knowing participation, 
Epstein's sex-trafficking scheme could not have logistically operated and Epstein's 
appearance to the outside world, including his victims, as a powerful and protected 
person could not have been maintained. 
33. 
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. During the times relevant to this action, 
Epstein victimized hundreds of young women and girls. 
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34. 
Epstein's sex-trafficking scheme was supported by virtually unlimited 
wealth, although Deutsche Bank knew that Epstein's self-professed job of "money 
manager to billionaires" was false. 
35. 
Epstein masterfully assessed the specific needs and vulnerability of 
each of his targeted victims. He then closed the trap on his victims with offers of 
money, food, shelter, medical care travel, schooling, and career opportunities for 
them or family members. 
Epstein groomed the young women and girls, 
indoctrinating them to believe that the sexual abuse was normal. 
36. 
Epstein fraudulently represented to the victims that he would take 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 create 
the opportunity for Epstein to sexually abuse them. 
37. 
The Epstein sex-trafficking venture's and conspiracy's purpose 
included enticing, obtaining, harboring, and transporting the young victims for 
Epstein to sexually abuse without drawing unwanted attention from law 
enforcement. The venture had everything a sex-trafficking organization needed—
funding, infrastructure, the appearance of legitimacy, and, most importantly, a 
complicit banking institution to ensure the illegal operation could continue to grow 
undetected by law enforcement. By many accounts, it was the most powerful and 
wealthiest sex-trafficking venture ever created. 
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38. 
The Epstein sex-trafficking venture knowingly used means of force, 
threats of force, fraud, coercion (including threats of serious harm or physical 
restraint), and abuse of law and the legal process, to cause Jane Doe 1 and many 
dozens of others similarly situated to engage in commercial sex acts. 
39. 
The Epstein sex-trafficking venture operated in and affecting interstate 
and foreign commerce. Epstein recruited, solicited, coerced, harbored, 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 Nev, York), Florida, the U.S. Virgin Islands, England, and 
France. 
40. 
The Epstein sex-trafficking venture operated throughout the world from 
(at least) in and around 1998 through in and around August 10, 2019, when Epstein 
died by apparent suicide. 
41. 
After Epstein's death, to and including the date of this complaint, 
members of the sex-trafficking venture continued to further the venture by 
concealing the activities and extent of the venture. 
42. 
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, Florida mansion. During that investigation, it was concluded that 
Epstein and his co-conspirators had committed federal criminal acts constituting 
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violations of 18 U.S.0 §§ 2422(b), 2422(2), 2423(f), 2423(b), 2424(e), 18 U.S.0 § 
371, 18 U.S.0 § 1591(c)(1) and 1591(a)(1) & (2), as well as state crimes in violation 
of Florida Statutes §§ 796.07 and 796.03. Epstein committed these crimes against 
dozens of young women and girls, 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 victims "went to Mr. Epstein's house only once, 
some went there as much as 100 times or more." 
43. 
As a consequence of the Florida investigation, Epstein pled guilty to 
two felony sex offenses, and was permanently labeled as a "Registered Sex 
Offender." He was jailed for these felonies in 2008. 
44. 
The 2006 criminal investigation uncovered a mountain of evidence that 
became public, including documents obtained through trash pulls outside Epstein's 
home, documents discovered in a search warrant, and extensive travel records. This 
evidence revealed details about Epstein's life-style, daily activities, and the unique 
manner of operation for his sex-trafficking venture. 
45. 
Epstein's criminal case in Florida and the many related police reports 
and news reports left no doubt about Epstein's extraordinary penchant for sexually 
abusing and trafficking young women and girls from (at least) about 2005 onwards. 
For instance, it was revealed that until the time of his Florida arrest, Epstein was 
sexually abusing three to four young females per day, in every location he was in at 
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the time. Sexually abusing young girls and women was a full-time job for him, from 
which he never took a vacation or hiatus. 
46. 
Beginning with his Florida arrest and for years after, Epstein was 
embroiled in dozens of highly public lawsuits documenting his sexual abuse of his 
victims. Thousands of news stories circulated worldwide about his sexual crimes. 
47. 
The manner and means of Epstein's sex trafficking operation was 
widely publicized after his 2006 arrest. It was well-known that he would lure young 
women or girls to one of his luxurious mansions, under the guise of being a wealthy 
philanthropist. Epstein would claim to be able to provide them something they 
needed or wanted, such as cash money, advancement of careers, education, or other 
life necessities. Once his victim was under Epstein's control, he would force his 
victim into providing a massage that would turn sexual, and from there he would 
sexually abuse them and cause them to engage in a variety of forced commercial sex 
acts. 
48. 
Once in Epstein's presence, each victim knew there was no realistic 
option to disobey him. 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 if they complied, and through his coercive techniques Epstein made 
clear that he was also able to significantly harm any of his victims of they refused 
his wishes. 
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49. 
While Epstein's first sexual abuse occurred in the early 1990s with the 
complicity of his then-paramour, Ghislaine Maxwell, Epstein's appetite for sexual 
abusing young women and girls grew over the years. His sex-trafficking and abuse 
had crystalized in a well- organized and well-defined conspiracy by as early as 1998. 
50. 
The Florida criminal investigation uncovered that Epstein's sex-
trafficking operation grew its number of victims exponentially in the early 2000s. 
51. 
One major reason why Epstein's sex-trafficking venture accumulated 
new victims at an alarming rate beginning in 2000 was his access to unlimited 
amounts of cash and a bank that would knowingly support and protect his sex-
trafficking operation. 
52. 
Without exorbitantly large amounts of cash, his operation could not run, 
as newly recruited victims were each paid hundreds of dollars in cash immediately 
after Epstein sexually abused them, as hush money. 
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 
that promise of large cash payments. 
54. 
The public police reports, 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 to recruit additional victims. 
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55. 
If Epstein paid every victim, including the young children, with wire 
transfers, 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 egregious sexual crimes many times a day without leaving a trail for each sex 
crime he committed. 
56. 
Because Epstein's vast wealth—said to have been more than a billion 
dollars—was maintained in seemingly legitimate financial institutions, he had 
greater power to wield in order to coerce his victims. 
57. 
In order to access the large amount of cash needed to maintain his active 
sexual abuse of young women, Epstein needed the financial institution where he 
banked to be complicit in his operation. More specifically, Epstein needed a bank 
that would allow him to constantly withdraw cash from his accounts, without regard 
to anti-money laundering prohibitions and currency transaction reporting 
requirements. 
58. 
This scheme of paying victims to bring other victims worked 
effectively because it not only allowed expansion through the recruitment of other 
victims in a pyramid-scheme fashion, but it also allowed each victim a possibility to 
avoid future sexual abuse—she could bring someone else who would be abused in 
her place. 
59. 
This constant expansion of sex-trafficking victims required cash on 
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hand for Epstein to pay many of his victims on the spot at the time of the abuse as 
hush money for the sexual abuse she was suffering as well as each victim's finder's 
fee for bringing another victim. 
60. 
In addition to the inner workings of Epstein's sex-trafficking scheme 
being public when he served his jail time in Florida, other relevant information about 
Epstein 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 amass his vast wealth. 
61. 
Despite the rumors that 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 financial 
institution with whom he was banking. 
62. 
Epstein's aptitude as a sex trafficker and appetite as a sexual abuser did 
not suffer because of his Florida incarceration in 2008. 
63. 
Even while he was in jail in Florida, he continued to sexually abuse 
young girls and women while he was on "work release" to his office that he opened 
under the name "Florida Science Center." 
64. 
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 
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mansions, primarily his townhouse located at 9 East 71s1 Street, New York, where 
he would sexually abuse each one. 
65. 
His sex-trafficking venture and conspiracy continued in the same 
manner and mode as it had in the past, although it involved more phony companies, 
more bank accounts, more withdrawals of large amounts of cash, and more delivery 
of funds to victims and co-conspirators through wires, payroll, direct deposits, and 
other means—means known to his financial institution as evidence of Epstein 
continuing his criminal sex trafficking scheme. 
66. 
As time went by, while Epstein sought to create cover as a well-
connected "money manager to billionaires," the news articles and lawsuits continued 
to mount expressing skepticism of the source(s) of his money and more confirming 
information became publicly available that Epstein was abusing young women. 
67. 
As a registered sex offender known to be sexually abusing 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 was 
essential, without which he could not sexually abuse in the way he did and his 
organization could not operate. 
68. 
From approximately 1998 through around August 2013, JP Morgan 
was the bank complicit in seeing to it that Epstein could sexually abuse countless 
young females and could operate his sex-trafficking venture and conspiracy. 
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69. 
Epstein's relationship with James "Jes" Staley was a key alliance that 
enabled Epstein to run his illegal operation through JP Morgan. 
70. 
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 
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 employee and agent of JP Morgan, 
Staley knew exactly what he was doing, and so did JP Morgan. 
71. 
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 
other legitimate business, began to create the perception of distancing itself from 
Epstein. 
72. 
In 2013, when Epstein was perhaps the most infamous sex offender in 
the world, he was on the precipice of losing his accounts at JP Morgan—the bank 
that had protected him and participated in his operation for nearly 15 years. He 
immediately needed a financial institution that would partner with him to continue 
the operation of his sex-trafficking venture. He found that partner in Deutsche Bank. 
73. 
Deutsche Bank picked up exactly where JP Morgan left off and worked 
quickly and diligently to figure out exactly what they needed to do (and not do) in 
order to conceal Epstein's illegal venture and conspiracy and ensure that it could 
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continue to run without a hitch. 
B. An Overview of Deutsche Bank's Role in the Epstein Sex-Trafficking 
Venture. 
74. 
Various banks and bankers were a critical part of Jeffrey Epstein's 
particular sex-trafficking venture. Due to the extensive publicity about Epstein's 
illegal sexual activities, in 2013 his longtime financial banking institution, JP 
Morgan, had decided it would no longer serve as his banker. 
75. 
By 2013, Epstein needed a new banking institution that would provide 
the necessary appearance of legitimacy for his operation. This institution would 
need to allow him to open many accounts for illegitimate companies, ignore blatant 
red flags, permit him to transfer money without questioning, give him access to 
abundant cash in direct violation of federal law, coach Epstein and his organization 
leaders on how to avoid reporting or scrutiny, and to otherwise intentionally 
participate in and facilitate the commercial aspect of his commercial sex-trafficking 
enterprise. 
76. 
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. Deutsche Bank continued to conceal what it had done through 
about July 2020. Deutsche Bank developed a special—and illegal—banking 
relationship with Epstein. 
77. 
Deutsche Bank knowingly and intentionally participated in the Epstein 
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