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terrorist organizations"). 
289. 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 
Bank gave this "special deal" because of the amount of business these individuals 
generated. See Karimi, Dkt. 37 at ¶ 101. 
290. As part of a pattern and practice similar to what it did for Epstein, 
Deutsche Bank routinely onboarded without due diligence individuals reportedly 
engaged in criminal activities, in reckless disregard of the financial and other crimes 
they helped to perpetrate. See id. at11103. 
291. In a similar pattern to what it did for Epstein, Deutsche Bank onboarded 
and provided accounts to Eastern European oligarchs reportedly involved in 
criminality, including Igor Putin and Roman Abramovich. 
292. In a similar pattern to what it did for Epstein, Deutsche Bank onboarded 
and provided accounts to the founders of the Hezbollah terrorist organization. 
293. In a similar pattern to what it did for Epstein, Deutsche Bank onboarded 
and provided accounts to a billionaire who was a relative of one of the founders of 
Al Rajhi Bank in Saudi Arabia, an entity long suspected of financing terrorists. 
294. In a similar pattern to what it did for Epstein, Deutsche Bank onboarded 
and provided accounts to German and Jose Efromovich despite their links to a 
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Mexican drug cartel. 
295. 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 
by British authorities-for its involvement in the Libor scandal uncovered in June 
2012. The company also pleaded guilty to wire fraud, acknowledging that at least 
29 employees had engaged in illegal activity. 
296. 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. 
sanctions at the time. 
297. For another example, in January 2017, Deutsche Bank agreed to a $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. 
298. For another example, in January 2017, the bank was fined $425 million 
by the New York State Department of Financial Services and £163 million by the 
U.K. Financial Conduct Authority regarding accusations of money laundering $10 
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billion out of Russia. 
299. The common thread running through Deutsche Bank's participation 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. 
E. The Statute of Limitations 
300. 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 
within ten years of the filing of this complaint. 
301. The New York Adult Survivors Act has opened up a one-year revival 
window for the statute of limitations. See New York State, Governor Hochul Signs 
Adult 
Survivors 
Act, 
Governor 
Kathy 
Hochul 
(May 
24, 
2022), 
https://www.governor.ny.govinews/governor-hochul-signs-adult-survivors-act 
("For many survivors, it may take years to come to terms with the trauma of sexual 
assault and feel ready to seek just."). 
302. RICO does not establish a precise statute of limitations. In this case, 
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the RICO enterprise, as well as the conspiracy to violate RICO, continued and caused 
injury through around July 2020, as explained in further detail below, within any 
possible statute of limitations. 
303. Deutsche Bank fraudulently concealed its role in facilitating the 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, the conspiracy continued until that time and also any 
applicable statute of limitations was equitably tolled until July 20, 2020. 
304. Deutsche Bank joined a conspiracy to violate the TVPA and a 
conspiracy to violate RICO in and around 2013. Thereafter, it ratified the acts and 
crimes already committed by the Epstein sex-trafficking venture and conspiracy in 
furtherance of the venture and conspiracy. 
305. Jane Doe 1, and other members of the Class, did not have the means 
and resources to uncover Deutsche Bank's role in facilitating their sexual abuse and 
sex trafficking until New York banking regulators announced their findings on July 
20, 2020. 
VII. CLASS ACTION ALLEGATIONS 
306. Jane Doe 1 brings this action pursuant to Federal Rule of Civil 
Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Class: 
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All women who were sexually abused or trafficked by Jeffrey Epstein 
during the time when Deutsche Bank began maintaining bank accounts 
for Epstein and/or Epstein related-entities, which was in or about 
August 19, 2013, through Epstein's death on about August 10, 2019, 
both dates inclusive, as well as all women who were sexually abused or 
trafficked by Jeffrey Epstein during earlier times, between January 1, 
2005 and August 19, 2013, when the sex-trafficking venture and 
conspiracy was operating—i.e., from January 1, 2005 through August 
10, 2019 (the "Class Period"). 
Jane Doe 1 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. 
307. Numerosity: The Class consists of dozens of women, making joinder 
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 
maintained by the Epstein estate executors and the Defendants, including but not 
limited to Deutsche Bank's records for Epstein-related accounts (e.g., account 
ledgers reflecting payments from Epstein to Class Members). 
308. Typicality: Jane Doe 1's claims are typical of the claims of the other 
Class Members she seeks to represent. The claims of Jane Doe land the other Class 
Members are based on the same legal theories and arise from the same unlawful 
pattern and practice of Deutsche Banks' participation in and funding of Epstein's 
sex abuse and Epstein's sex-trafficking venture. 
309. Commonality: There are many questions of law and fact common to 
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the claims of Jane Doe 1 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 under Fed. R. Civ. P. 23(c)(4) will materially advance the litigation. 
310. Common questions of fact and law affecting Class Members include, 
but are not limited to, the following: 
a. Whether the Epstein sex-trafficking venture caused its victims to 
engage in commercial sex acts in violation of Trafficking Victims 
Protection Act, 18 U.S.C. § 1591(a)(1); 
b. Whether the Epstein sex-trafficking venture recruited, enticed, 
solicited, harbored, provided, obtained, and transported victims in ways 
that were in or affecting interstate or foreign commerce; 
c. Whether Epstein and his co-conspirators used means of force, fraud, 
coercion, and abuse of legal process, or a combination of such means, 
to sexually abuse the victims and to cause victims to engage in 
commercial sex acts; 
d. Whether Deutsche Bank knowingly assisted, facilitated, and supported 
the Epstein sex-trafficking venture's pattern and practice of coercively 
forcing victims to engage in commercial sex acts; 
e. Whether Deutsche Bank benefited financially or by receiving things of 
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value from its participation in a venture which has engaged in sex 
trafficking in violation of TVPA, 18 U.S.C. § 1591(a)(1); 
f. Whether Deutsche Bank knew or should have known that the Epstein 
sex-trafficking venture had engaged in violations of the TVPA, 18 
U.S.C. § 1591(a); 
g. Whether Deutsche Bank was part of a conspiracy violate the TVPA and 
RICO, in violation of 18 U.S.C. § 1594(c) & 18 U.S.C. § 1961(d); and 
h. Whether Deutsche Bank committed aided and abetted, or was negligent 
in facilitating, Epstein's sexual abuse which would constitute and 
include sexual offenses as defined in Article 130 of New York penal 
law committed against persons who were eighteen years of age or older. 
311. Absent a class action, most of the Class Members would find the cost 
of litigating their claims to be cost-prohibitive and will have no effective remedy. 
The class treatment of common questions of law and fact is also superior to multiple 
individual actions or piecemeal litigation, in that it conserves the resources of the 
courts and the litigants and promotes consistency and efficiency of adjudication. 
312. 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 
retained counsel with substantial experience in prosecuting complex litigation and 
class actions. Jane Doe 1 and her counsel are committed to vigorously prosecuting 
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this action on behalf of the other Class Members and have the financial resources to 
do so. Neither Jane Doe 1 nor her counsel have any interests adverse to those of the 
other Class Members. 
313. This action has been brought and may properly be maintained as a class 
action against Deutsche Bank pursuant to Rule 23 of the Federal Rules of Civil 
Procedure because there is a well-defined community of interest in the litigation and 
the proposed Class is readily and easily ascertainable from Defendants' records. 
314. Superiority: A class action is superior to all other available methods 
for the fair and efficient adjudication of this controversy because: 
a. Joinder of all Class Members is impracticable; 
b. The prosecution of individual remedies by Members of the Class will 
tend to establish inconsistent standards of conduct for Defendants and 
result in the impairment of Class Members' rights and the disposition 
of their interests through actions to which they were not parties; 
c. Class action treatment will permit a large number of similarly-situated 
persons to prosecute their common claims in a single forum 
simultaneously, efficiently, and without the unnecessary duplication of 
effort and expense that numerous individual actions would engender; 
d. Absent a class action, Class Members will continue to suffer losses and 
be aggrieved and Defendants will continue to violate New York and 
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federal law without remedy; 
e. Class treatment of this action will cause an orderly and expeditious 
administration of class claims, economies of time, effort and expense 
will be fostered, and uniformity of decisions will be ensured; 
f. Jane Doe 1 and her counsel are unaware of any class action brought 
against any Defendant for the violations alleged in this action; 
g. The forum is desirable because Defendants conducted the subject 
business with Jeffrey Epstein in this District and Class Members were 
consequently trafficked in this District; and, 
h. This action presents no difficulty that would impede its management by 
the Court as a class action. 
VIII. CAUSES OF ACTION 
COUNT I 
KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN 
VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, 
18 U.S.C. §§ 1591(aX2), 1595 
315. PlaintiffJane Doe 1 realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
316. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
317. Deutsche Bank knowingly and intentionally participated in, assisted, 
supported, and facilitated a sex-trafficking venture that was in and affecting 
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interstate and foreign commerce, together and with others, in violation of 18 U.S.C. 
§ 1591(a)(2). 
318. Deutsche Bank took many concrete steps to aid Epstein's sex-
trafficking venture, as outlined above. Among the concrete steps that Deutsche Bank 
took to aid Epstein was providing hundreds of thousands of dollars in cash, which 
made the sex-trafficking venture possible. Providing Epstein hundreds of thousands 
of dollars in cash caused Deutsche Bank to receive financial benefits. Deutsche 
Bank's willingness to provide large amounts of cash to Epstein was the quid pro quo 
for it receiving financial benefits from Epstein. 
319. The cash that Deutsche Bank provided was necessary for Epstein to 
coerce Jane Doe I as well as other Class Members to engage in commercial sex acts. 
The cash directly formed part of the commercial nature of the sex acts. The cash 
was also a necessary and required part of Epstein's recruitment of Jane Doe 1 and 
other victims of his sex-trafficking venture. By providing cash that Deutsche Bank 
knew would be used to fund the sex trafficking venture, Deutsche Bank actively 
participated in the recruitment of victims of the venture. 
320. The cash that Deutsche Bank provided went far beyond providing 
routine banking facilities to a client. It was far from routine for Deutsche Bank to 
provide $200,000 per year in cash to someone like Epstein, who did not have an 
apparent need for such extravagant sums. Moreover, the circumstances in which 
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Epstein was requesting such large amounts were far from routine and raised 
numerous "red flags"—taking it well outside routine circumstances. 
321. Deutsche Bank providing $200,000 per year in cash to Epstein, under 
the circumstances of this case, was entirely inconsistent with the ordinary duties of 
a bank or its employees. 
322. The reason that Deutsche Bank ignored the numerous red flags about 
Epstein was to receive financial benefits from Epstein, estimated to be in the range 
of (at least) "$24 million annually." Deutsche Bank knew that it would gain far-
from-routine financial benefits by ignoring the red flags associated with Epstein and 
by participating in his sex-trafficking venture. 
323. Among the concrete steps that Deutsche Bank took to aid and 
participate in the Epstein sex-trafficking venture were opening up more than 40 
accounts at Deutsche Bank for Epstein, his related entities, and associates. By 
opening these accounts, Deutsche Bank receive many benefits from participating in 
Epstein's venture. The opening of these accounts was affirmative conduct that 
caused Deutsche Bank to receive those benefits. 
324. Among the concrete steps that Deutsche Bank took to aid the Epstein 
sex-trafficking venture, between on or about August 19, 2013, and through about 
July 2020, Deutsche Bank concealed its delivery of hundreds of thousands of dollars 
in cash to Epstein and his associates. In order to benefit from the Epstein sex-
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trafficking venture, Deutsche Bank willfully failed to file required Suspicious 
Activity Reports (SARs) with the federal government, because doing so would 
imperil its ability to profit from the sex-trafficking venture. Deutsche Bank's 
concealment of the cash transactions caused it to receive financial benefits through 
continuation of the Epstein sex-trafficking venture. 
325. Among the concrete steps that Deutsche Bank took to aid the Epstein 
sex-trafficking venture were its failure to implement oversight requirements 
imposed by the ARRC. This failure was not just passive facilitation, but a deliberate 
omission by Deutsche Bank. This omission was specific act of concealment, which 
allowed Epstein to continue funding his sex-trafficking venture through suspicious 
transactions that would have otherwise been prevented. 
326. Deutsche Bank knowingly and intentionally benefited financially from, 
and received value for, its participation in the sex-trafficking venture, in which 
Epstein, with Deutsche Bank'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. 
327. Deutsche Bank actually knew that it was participating in a particular 
sex-trafficking venture—i.e., the Epstein sex-trafficking venture outlined above. 
Deutsche Bank's knowledge went far beyond having an abstract awareness of sex 
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trafficking in general. Indeed, Deutsche Bank discussed internally Epstein's sex 
trafficking and the large amounts of cash that Deutsche Bank was giving him. Thus, 
Deutsche Bank did not simply fail to adequately detect signs of Epstein's sex 
trafficking; it did detect multiple signs of Epstein's sex-trafficking venture and 
continued to participate in the venture. Deutsche Bank knew that the venture was 
on-going, which was why Epstein required vast sums of cash. 
328. Deutsche Bank's actions extend well beyond a situation of failing to 
train its staff about recognizing the warning signs of sex trafficking. Deutsche 
Bank's employees did recognize the signs of Epstein's sex trafficking. Indeed, 
Deutsche Bank's employees knew about Epstein's sex-trafficking venture. But 
Deutsche Bank decided to continue facilitating the Epstein sex-trafficking venture 
rather than ending its participation in the venture. 
329. Among the signs that Deutsche Bank was facilitating Epstein's sex 
trafficking venture were those facts that came to the attention of Deutsche Bank's 
Anti-Financial Crime Department at the end of 2014 and into 2015, which caused 
the Department to escalate issues regarding Epstein's sex-trafficking venture to more 
senior levels. 
330. Among the signs that Deutsche Bank was facilitating Epstein's sex 
trafficking venture were those facts that came to the attention of Deutsche Bank were 
those facts that came to its attention that led to an in-person meeting by Deutsche 
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Bank officials with Epstein in the bar in the basement of his New York home. While 
Epstein appears to have denied sex trafficking at that meeting, in light of all the 
circumstances, his denial was not credible—and Deutsche Bank knew that they were 
not credible. 
331. Deutsche Bank's actual knowledge extended to the fact that specific 
individual women and girls were being coercively sex trafficked by Epstein between 
the time of his on-boarding and the termination of its relationship with Epstein. Even 
if Deutsche Bank did not know all the names of Epstein's victims, it knew that 
specific victims (e.g., Jane Doe 1) of a specific trafficker (Epstein) at a specific time 
period (various dates between 2013-19) existed and were being forced to engage in 
commercial sex acts. It also knew that some of the victims had eastern European 
surnames. Deutsche Bank was on notice, and knew, that such victims were being 
coercively trafficked by Epstein's sex-trafficking venture. 
332. Deutsche Bank helped to conceal the names of Epstein's victims from 
the public and from law enforcement and prosecuting agencies by helping to conceal 
the existence of the sex-trafficking venture. Among the ways in which Deutsche 
Bank helped to conceal the venture's existence was by providing the cash necessary 
for the venture to avoid leaving a visible "paper trail." 
333. Deutsche Bank's concealment included failing to follow through on 
enhanced monitoring of Epstein's accounts recommended by the ARRC. Deutsche 
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Bank failed to implement that enhanced monitoring specifically to help conceal 
Epstein's ongoing sex-trafficking. Deutsche Bank knew that if it implemented that 
enhanced monitoring, it would have to stop providing Epstein with the cash needed 
to run his sex-trafficking venture. 
334. Deutsche Bank's concealment included failing to file required SARs 
for Epstein's suspicious cash transactions. 
335. In addition to having actual knowledge that it was participating in 
Epstein's sex trafficking venture, Deutsche Bank had constructive knowledge that it 
was participating in Epstein's sex trafficking venture. Deutsche Bank also had 
constructive knowledge that Jane Doe 1, as well as other Members of the Class, were 
being coercively sex trafficked by Epstein. Its constructive knowledge extended to 
the names of Epstein's victims, because Epstein and his associates knew the names 
of the victims. 
336. Deutsche Bank had constructive knowledge of Epstein's sex-
trafficking venture because of specific acts by Epstein that put it on notice of a 
particular and ongoing sex trafficking venture. Among the specific acts were 
Epstein's use of $200,000 per year in cash in circumstances that prompted Deutsche 
Bank to specifically ask Epstein about sex-trafficking. 
337. Also among the specific acts giving rise to constructive knowledge 
were the facts that an associate of Epstein (his attorney) made a total of 97 
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withdrawals from the Bank's Park Avenue branch, all in the amount of $7,500, 
Deutsche Bank's limit for third-party withdrawals. The circumstances of these 
withdrawals gave the bank notice that "structuring" was occurring to avoid alerting 
federal authorities. 
338. Also among the specific acts giving rise to constructive knowledge 
were the facts that came to the attention of Deutsche Bank's Anti-Financial Crime 
Department at the end of 2014 and into 2015, which caused the Department to 
escalate issues concerning Epstein's sex-trafficking venture to more senior 
management. 
339. Among the financial benefits that the Deutsche Bank received for 
participating in and facilitating Epstein's sex-trafficking venture were the deposit of 
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 
in the sex trafficking venture, including its willingness to provide large amounts of 
cash in suspicious circumstances and to allow "structuring" of withdrawals to avoid 
triggering reporting requirements. 
340. Among the financial benefits that Deutsche Bank received for 
participating in Epstein's sex-trafficking venture was referral of business 
opportunities from Epstein and his co-conspirators. Deutsche Bank profited from 
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these referred business opportunities. Epstein referred business entities and business 
opportunities to Deutsche Bank in exchange for its facilitation and participation in 
the sex trafficking venture. These referrals were a quid pro quo for Deutsche Bank's 
participation in the sex-trafficking venture. 
341. Deutsche Bank financially profited from the deposits made by Epstein 
and Epstein-controlled entities and from the business opportunities referred to 
Deutsche Bank by Epstein in exchange for its facilitation and participation in 
Epstein's sex trafficking venture. 
342. Deutsche Bank knowingly received financial benefits in return for its 
assistance, support, and facilitation of Epstein's sex-trafficking venture. Deutsche 
Bank knew that if it stopped providing assistance, support, and facilitation of 
Epstein's sex-trafficking venture, it would no longer receive those benefits. 
343. 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 
sex acts, in violation of 18 U.S.C. § 1591(a). 
344. 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 
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Members of the Class, into commercial sex acts, through the means of force, threats 
of force, fraud, abuse of process, and coercion. 
345. Deutsche Bank's affirmative conduct was committed knowing, and in 
reckless disregard of the fact, 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. Deutsche Bank's conduct 
was outrageous and intentional. 
346. In addition to actual knowledge that it was participating in and 
facilitating the Epstein sex-trafficking venture, Deutsche Bank also should have 
known that (and was willfully blind to the fact that) it was participating in and 
facilitating a venture that had engaged in coercive sex trafficking, as covered by 18 
U.S.C. § 1595(a). 
347. In exchange for facilitating and covering up Epstein's commercial sex 
trafficking, Deutsche Bank's officers and employees advanced in their careers at 
Deutsche Bank and received financial benefits therefrom by securing the Deutsche 
Bank-Epstein relationship. 
348. Facilitating and covering up Epstein's sexual trafficking and 
misconduct was a means of obtaining economic success and promotion within the 
Deutsche Bank hierarchy. 
349. Deutsche Bank's actions were in and affecting interstate and foreign 
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commerce, including its banking activities which were in and affecting interstate and 
foreign commerce. 
350. Deutsche Bank's knowing and intentional conduct has caused Jane Doe 
1 and the other Members of the Class serious harm including, without limitation, 
physical, psychological, emotional, financial, and reputational harm. 
351. Deutsche Bank's knowing and intentional conduct has caused Jane Doe 
1 and the other Members of the Class harm that is sufficiently serious, under all the 
surrounding circumstances, to compel a reasonable person of the same background 
and in the same circumstances to perform or to continue performing commercial 
sexual activity, in order to avoid incurring that harm. 
352. This case does not involve mere fraud. Instead, Deutsche Bank's 
criminal conduct in violating the TVPA was outrageous and intentional, because it 
was in deliberate furtherance of a widespread and dangerous criminal sex trafficking 
organization. Deutsche Bank's criminal conduct also evinced a high degree of moral 
turpitude and demonstrated such wanton dishonesty as to imply a criminal 
indifference to civil obligations. Deutsche Bank's criminal conduct was directed 
specifically at Jane Doe I and other members of the Class, who were the victims of 
Epstein's sexual abuse and sex trafficking organization. 
353. Deutsche Bank's outrageous and intentional conduct in this case is part 
of a pattern and practice of Deutsche Bank profiting by undertaking illegal "high 
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risk, high reward" clients. 
354. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 
1591(a)(2), 1595, Deutsche Bank is liable to Jane Doe 1 and the other Members of 
the Class for the damages they sustained and reasonable attorneys' fees. 
355. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 
1591(a)(2), 1595, Deutsche Bank is liable to Jane Doe 1 and other members of the 
Class for punitive damages. 
COUNT II 
PARTICIPATING IN A SEX-TRAFFICKING VENTURE IN VIOLATION 
OF THE TRAFFICKING VICTIMS PROTECTION ACT, 
18 U.S.C. §§ 1591(a)(1), 1595 
356. Plain t i ffJane Doe 1 realleges and incorporates by reference paragraphs 
I — 314, as if fully set forth in this Count. 
357. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
358. Deutsche Bank knowingly and intentionally participated in, 
perpetrated, assisted, supported, facilitated a sex-trafficking venture that was in and 
affecting interstate and foreign commerce, together and with others, in violation of 
18 U.S.C. § 1591(a)(1). 
359. Among other things, Deutsche Bank knowingly and intentionally 
recruited, enticed, provided, obtained, advertised, and solicited by various means 
Jane Doe 1, as well as other Class Members, knowing that Epstein would use means 
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