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or about July 8, 2019. On or about that date, the U.S. Attorney's Office for the 
Southern District of New York indicted Epstein (and unnamed "associates") for 
violating the TVPA. Later, on about June 29, 2020, the same Office indicted 
Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims 
to travel to be abused by Epstein. The federal criminal investigation of Maxwell 
included investigation of possible violations of the TVPA. 
446. By providing and concealing financing for Epstein's sex trafficking 
organization from about August 2013 through about July 2020, Deutsche Bank 
obstructed, interfered with, and prevented the federal government's enforcement of 
the TVPA against Epstein. To the extent that the federal government was able to 
ultimately charge Epstein with TVPA violations, the filing of those charges was 
delayed by Deutsche Bank's actions. Because of that delay, Jane Doe 1 as well as 
other members of the Class, were coercively caused to engage in commercial sex 
acts. 
447. As one example of how Deutsche Bank obstructed, attempted to 
obstruct, interfered with, and prevented the federal government's enforcement of the 
TVPA, Deutsche Bank provided large amounts of cash (about $200,000 per year) to 
Epstein and his associates so that the coercive commercial sex acts would escape the 
detection of federal law enforcement and prosecuting agencies. Deutsche Bank 
provided large amounts of cash to further the Epstein sex-trafficking venture and 
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with the purpose of helping Epstein evade criminal liability for violating the TVPA. 
448. As another example of how Deutsche Bank obstructed, attempted to 
obstruct, interfered with, and prevented the federal government's enforcement of the 
TVPA, Deutsche Bank did not follow conditions imposed by the ARRC in around 
January 2015. These conditions included a requirement that Deutsche Bank would 
review transactions in the Epstein's Deutsche Bank accounts for a determination of 
whether they "involve[d] any unusual and/or suspicious activity or are in a size that 
is unusually significant or novel in structure." If Deutsche Bank had observed these 
conditions, then it would have prevented many of the subsequent transactions 
committed by the Epstein sex-trafficking venture. Deutsche Bank knowingly did 
not observe these conditions because it knew that doing so would have prevented 
Epstein's secret cash transactions that were necessary to his sex-trafficking operation 
escaping knowledge of federal investigative and prosecuting agencies. Without 
Deutsche Bank's cash, Jane Doe 1, as well as other members of the Class, would not 
have been coercively forced to engage in commercial sex act. 
449. As another example of how Deutsche Bank obstructed, attempted to 
obstruct, interfered with, and prevented the federal government's enforcement of the 
TVPA, Deutsche Bank failed to timely file with the federal government the required 
SARs that financial institutions must file with FinCEN whenever there is a suspected 
case of money laundering or fraud. Timely filing of these reports is required by the 
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Bank Secrecy Act and related laws and regulations. These reports are tools that the 
federal government uses to detect and prosecute, among other illegal activities, sex 
trafficking in violation of the TVPA. By failing to timely file the required SARs 
regarding Epstein's cash transactions, Deutsche Bank obstructed, attempted to 
obstruct, interfered with, and prevented the federal government's enforcement of the 
TVPA by concealing from the federal government's attention Epstein's cash 
transaction in aid of sex trafficking. 
450. Deutsche Bank can disclose its failure to file appropriate SARs without 
disclosing the existence of an SAR. Deutsche Bank is not protected from liability 
for failure to file a required SAR. 
451. Deutsche Bank's failure to timely file SARs about Epstein's sex-
trafficking venture, in spite of numerous red flags, was wrongful and purposeful. 
452. If Deutsche Bank had filed timely required SARs about Epstein's sex-
trafficking venture with the federal government, the appropriate federal agencies 
would have been well positioned to investigate Epstein's sex-trafficking venture's 
TVPA violations. 
Deutsche Bank's failure to timely file the required SARs 
obstructed the federal government's ability to investigate those TVPA violations, 
including violations harming Jane Doe 1 and other Class Members. If Deutsche 
Bank had timely filed the required SARs, it would have prevented the continuation 
of Epstein's sex trafficking venture, which required the ability to secretly use cash 
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to pay off victims. 
453. By providing large amounts of cash (about $200,000 per year) to 
Epstein and his associates, Deutsche Bank intended and knew that Epstein's coercive 
commercial sex acts would escape the detection of federal law enforcement and 
prosecuting agencies for some period of time. Deutsche Bank provided large 
amounts of cash to further the Epstein sex-trafficking venture and with the purpose 
of helping Epstein evade criminal liability for violating the TVPA. 
454. Deutsche Bank's obstruction, attempted obstruction, interference with, 
and prevention of the enforcement of the TWA were all done intentionally and 
knowingly. For example, Deutsche Bank knew that Epstein was "high risk"—
specifically, high risk to violate the TWA through continuing criminal sex 
trafficking activities. 
455. Deutsche Bank was well aware that Epstein had pleaded guilty and 
served prison time for engaging in sex with a minor—a crime closely connected with 
sex trafficking in violation of the TVPA. Deutsche Bank was also well aware that 
there were public allegations that his illegal conduct was facilitated by several named 
co-conspirators. But Deutsche Bank concealed from the federal government its 
numerous cash payments to those co-conspirators. Deutsche Bank continued its 
affirmative conduct of providing cash to Epstein so that he could make those cash 
payments to his co-conspirators with knowledge that such cash transaction did not 
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produce a clear paper trail. Deutsche Bank's intentional conduct obstructed, 
attempted to obstruct, in many ways interfered with, and prevented the enforcement 
of the TVPA by federal investigators and prosecuting agencies. 
456. Deutsche Bank's relationship with Epstein in providing to him 
$200,000 in cash per year went far beyond a normal (and lawful) banking 
relationship. Deutsche Bank knew, and intended, that its relationship with Epstein 
would go far beyond a normal banking relationship. Deutsche Bank knew that its 
decision to beyond a normal banking relationship with Epstein obstructed the ability 
of federal law enforcement and prosecuting agencies to enforce the TVPA. 
457. Deutsche Bank's obstruction continued through around July 2020, as it 
was not until that time that Deutsche Bank entered into its consent agreement with 
New York banking regulators. 
458. Deutsche Bank's obstruction of the federal government's TVPA and 
other law enforcement efforts was intentional and willful and, therefore, Deutsche 
Bank intentionally and willfully caused Epstein's commission of the forcible 
commercial sex acts with Jane Doe 1 and other Class Members through its 
obstruction supporting the concealment of Epstein's sex-trafficking venture. 
459. Deutsche Bank knew, acted in reckless disregard of the fact, and should 
have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would directly 
and proximately lead to unlawful coercive commercial sex acts by Epstein with 
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young women and girls, including Jane Doe 1 and other Class Members. 
460. Deutsche Bank's obstruction has caused Jane Doe I and other Class 
Members serious harm, including, without limitation, physical, psychological, 
financial, and reputational harm. That harm was directly and proximately caused by 
the obstruction and the harm resulting from obstruction was foreseeable. 
461. Deutsche Bank's obstruction has caused Jane Doe 1 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. 
462. This case does not involve mere fraud. Instead, Deutsche Bank's 
criminal conduct in obstructing enforcement of the TVPA was outrageous and 
intentional, because it was in deliberate furtherance of a widespread and dangerous 
criminal sex trafficking organization. Deutsche Bank's obstruction 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 obstruction was 
directed specifically at Jane Doe 1 and other members of the Class, who were the 
victims of Epstein's sex trafficking organization. 
463. By virtue of these violations of 18 U.S.C. § 159I(d), Deutsche Bank is 
liable to Jane Doe 1 and the other Members of the Class for the damages they 
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sustained and reasonable attorneys' fees by operation of 18 U.S.C. § 1595. Deutsche 
Bank perpetrated an obstruction of the TVPA, and therefore perpetrated a violation 
of Chapter 77, Title 18. 
464. By virtue of its intentional and outrageous obstruction to prevent 
enforcement of the TWA, in violation 18 U.S.C. § 1591(d), Deutsche Bank is liable 
to Jane Doe 1 and other members of the Class for punitive damages by operation of 
18 U.S.C. § 1595. 
COUNT VII 
VIOLATIONS OF RICO, 18 U.S.C. §§ 1962(c), 1964(c) 
465. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs 
1 — 314, as if fully set forth in this Count. 
466. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
467. From around August 2013 through around July 2020, Deutsche Bank 
violated RICO, 18 U.S.C. § 1962(c), within this District and elsewhere, for which 
Jane Doe 1 and the other Class Members are entitled to recover damages under 18 
U.S.C. § 1964(c). Deutsche Bank and others acting in concert with them as part of 
the aforementioned enterprise engaged in a pattern of racketeering activity within 
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. 
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Specifically, Deutsche Bank and others in the Enterprise committed multiple acts in 
violation of 18 U.S.C. § 1962(c) over the course of several years from about 2013 to 
about December 2018, during which time Jane Doe 1 was sexually assaulted and 
sexually trafficked. 
468. Deutsche Bank's pattern of racketeering activity extended over a 
substantial period of time—i.e., during the multiple years that Deutsche Bank 
financially furthered and supported the Epstein Sex Trafficking Enterprise. 
469. Deutsche Bank violated RICO, 18 U.S.C. § 1962(c), which makes it 
"unlawful for any person employed by or associated with any enterprise engaged in, 
or the activities of which affect, interstate or foreign commerce, to conduct or 
participate, directly or indirectly, in the conduct of such enterprise's affairs through 
a pattern of racketeering activity . . . ." Deutsche Bank was associated with the 
Epstein Sex-Trafficking Enterprise and conducted and participated (directly and 
indirectly) in the conduct of the enterprise's affairs by financially supporting the 
Epstein sex trafficking enterprise and also engaging in a pattern of racketeering 
activity as alleged above. Deutsche Bank's actions, including its predicate acts, 
directly and proximately injured Jane Doe 1 and the Class Members in their business 
and property. 
1. The RICO Enterprise 
470. Deutsche Bank, along with Epstein and his employees, agents, and co-
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conspirators, was engaged in a RICO "enterprise," which "includes any individual, 
partnership, corporation, association, or other legal entity, and any union or group 
of individuals associated in fact although not a legal entity." 18 U.S.C. § 1961(3). 
Deutsche Bank and others employed by or associated with it or others acting in 
concert with Deutsche Bank, promoted, facilitated, financed, and otherwise 
effectuated the Epstein sex-trafficking venture and Epstein's coercive commercial 
sex acts, as alleged in this complaint, and constituted an "enterprise" under the RICO 
definition. This enterprise is described herein as the "Epstein Sex-Trafficking 
Enterprise," or simply the "Enterprise." References in this complaint to the Epstein 
Sex-Trafficking Venture and Epstein Sex-Trafficking Conspiracy are also 
references to the Enterprise. 
471. The Epstein Sex-Trafficking Enterprise had a shared and common 
purpose—securing young women and girls for Epstein to sexually abuse and to 
commercially sex traffic. Deutsche Bank and other members of the Enterprise 
associated together for this common purpose. 
472. The Epstein Sex-Trafficking Enterprise was an ongoing organization 
with the same hierarchy and regularity of function. Epstein was at the top of the 
hierarchy and effectively served as the CEO of the organization. 
473. The Epstein Sex-Trafficking Enterprise consisted of more than Epstein 
and Epstein's own employees and agents. It also included other persons, including 
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Deutsche Bank's employees and agents. The Enterprise operated together as an 
association-in-fact. The persons who operated together as an association-in-fact 
included, but were not limited to, Defendant Deutsche Bank, Jeffrey Epstein, 
Attorney-1, Accountant-1, Ghislaine Maxwell, Sarah Kellen, Leslie Grog Adriana 
Ross, Nadia Marcinkova, Charles Packard, Patrick Harris, 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 provide the funding for the enterprise and that Deutsche Bank would be 
rewarded as a result. 
474. The Epstein Sex-Trafficking Enterprise had a relationship among the 
associates, including a relationship among Epstein's employees and agents and 
Deutsche Bank's employees and agents. The associates coordinated their actions to 
facilitate the actions of the sex-trafficking enterprise, including ensuring that the 
Enterprise had sufficient financing to pursue its purpose. 
475. The Epstein Sex-Trafficking Enterprise lasted for many years, but from 
(at least) around 2013 through around July 2020, permitting the associates in the 
Enterprise to successfully pursue the Enterprise's purpose. As a result of the 
longevity of the 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 the common purpose. 
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476. The participation and agreement of Deutsche Bank was necessary to 
allow the commission of this scheme. 
2. Nexus Between the "Deutsche Bank" and the "Enterprise" 
477. Deutsche Bank, acting through its employees and officers, participated, 
directly and indirectly, in the conduct of the affairs of the Epstein Sex-Trafficking 
Enterprise. Deutsche Bank's agents, acting within the apparent scope of their 
authority, participated, directly and indirectly, in the conduct of the affairs of the 
Epstein Sex-Trafficking Enterprise. 
478. Deutsche Bank, acting through its employees and officers, participated 
in the operation and management of the enterprise itself. For example, Deutsche 
Bank officers met personally with Epstein at his New York mansion, during which 
they collectively shaped the conduct of the affairs of the Epstein Sex Trafficking 
Enterprise. 
479. Deutsche Bank, acting through its employees and officers, exercised a 
significant degree of direction over the affairs of the Enterprise and played a part in 
directing the affairs of the Enterprise. 
480. Deutsche Bank, acting through its employees and officers, aided and 
abetted Epstein, who participated in the operation and management of the Enterprise. 
3. Acts of Racketeering 
481. Deutsche Bank and others acting in concert with them as part of the 
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Epstein Sex-Trafficking Enterprise engaged in racketeering activity within the 
meaning of RICO, 18 U.S.C. § 1961(1)(B), when they engaged in acts "indictable 
under" 18 U.S.C. §§ 1581-1594 (the statutes relating to peonage, slavery, and 
trafficking in persons), to wit, the acts in violation of 18 U.S.C. §§ 1591 to 1594 
alleged in Counts I-VI and otherwise specified throughout this complaint. 
482. Deutsche Bank and others acting in concert with them as part of the 
Epstein Sex-Trafficking Enterprise engaged in racketeering activity within the 
meaning of RICO, 18 U.S.C. § 1961(1)(B), when they engaged in acts "indictable 
under" 31 U.S.C. § 5322 (the Bank Secrecy Act) and failing to adhere to the 
minimum due diligence requirements contained in 31 C.F.R. § 1010.620, by (among 
other things) (1) failing to ascertain the source of Epstein's funds and the purpose 
and expected use of his accounts; and (2) ensuring that the activity in Epstein's 
accounts was consistent with the information Deutsche Bank obtained about 
Epstein's source of the funds and stated purpose and expected use of the accounts. 
Deutsche Bank's knowing, intentional, and willful failure to comply with federal 
laws and banking regulations constituted a felony under 31 U.S.C. § 5322(a). 
483. The acts of racketeering described in the paragraphs above occurred 
within about August 2013 and about July 2020. 
484. As an example of acts of racketeering, on multiple occasions Deutsche 
Bank participated in TVPA violations by provided substantial sums of cash to 
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Epstein, which he then used to conclude coercive acts of commercial sex abuse and 
sex trafficking, in violation of the TVPA (as elaborated in detail in Count II and 
elsewhere above). 
485. As another example of acts of racketeering, on multiple occasions 
Deutsche Bank knowingly received benefits from participated in sex trafficking by 
provided substantial sums of cash to Epstein, which he then used to conclude 
coercive acts of commercial sex abuse and sex trafficking, in violation of the TVPA 
(as elaborated in detail in Count I and elsewhere above). 
486. Among the acts constituting a pattern of racketeering activity, on or 
about August 19, 2013, Deutsche Bank opened brokerage accounts for Southern 
Trust Company Inc., a self-described "database company and services" founded in 
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. 
§§ 1581-94, and 18 U.S.C. § 2, for the reasons described above. 
487. Among the acts constituting a pattern of racketeering activity, over 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. §§ 
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1581-94, and 18 U.S.C. § 2, for the reasons described above. 
488. Among the acts constituting a pattern of racketeering activity, over 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 
Trust. These transfers furthered the sex-trafficking enterprise, including funds 
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 
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. §§ 1581-94, and 18 U.S.C. 
§ 2, for the reasons described above. 
489. 
Deutsche Bank knowingly facilitated Epstein using Deutsche Bank 
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. §§ 1581-94, and 18 U.S.C. § 2, for 
the reasons described above. 
4. Pattern of Racketeering Activity 
490. During around August 2013 through the end of 2018, Deutsche Bank 
engaged in a pattern of racketeering activity. 
491. Deutsche Bank's pattern of racketeering activity included repeatedly 
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providing approximately $200,000 in cash to the Epstein Sex-Trafficking Enterprise 
on a yearly basis. 
492. Deutsche Bank's pattern of racketeering activity included repeatedly 
failing to file required SARs for suspicious cash and other transactions of the Epstein 
Sex-Trafficking Enterprise. 
493. Many of the suspicious cash withdrawals made by the Epstein Sex-
Trafficking Enterprise were made in the same way by the same person at the same 
branch bank. The cash withdrawals those involved similar methods. 
494. The cash withdrawals all bore a relationship to each other, because they 
were providing the necessary funding for the coercive commercial sex trafficking 
and sex abuse of the Epstein Sex Trafficking Venture. Indeed, some of the cash 
withdrawals necessarily related directly and precisely to each other, because they 
were "structured" together to avoid triggering certain current transaction reporting 
requirements. 
495. The funding involved similar goals and effects of providing sufficient 
cash to allow the Epstein Sex-Trafficking Venture to pay victims for commercial 
sex acts in cash, thereby avoiding a paper trail. 
5. Effect on Interstate Commerce 
496. The Epstein Sex Trafficking Enterprise engaged in, and had activities 
which affect, interstate and foreign commerce. 
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497. Among the activities of the Enterprise which had an effect on interstate 
commerce were cellular and other telephone calls to Epstein's victims to schedule 
time for sexual abused. 
498. Among the activities of the Enterprise which had an effect on interstate 
commerce were cash withdrawals from Deutsche Bank, which does business in and 
effecting interstate commerce. 
499. Among the activities of the Enterprise which had an effect on interstate 
commerce were movements of Epstein, his confederates, and his victims on aircraft 
moving in interstate commerce. 
6. Injury to Business and Property by Reason of the RICO Violation 
500. By reason of its violations of 18 U.S.C. § 1962(c), Deutsche Bank has 
directly and proximately caused Jane Doe 1 and the Class Members serious and 
permanent economic injury to their businesses and property, including, without 
limitation, pecuniary harm to their careers and professional prospects, in an amount 
to be determined at trial. Deutsche Bank's violations continue to cause economic 
harm and injury to Jane Doe 1 and other Members of the Class. 
501. Deutsche Bank's acts of racketeering and activities as part of the 
Epstein's Sex-Trafficking Enterprise, described above, have directly and 
proximately caused Jane Doe 1 and the Class Members serious and permanent 
economic injury to their businesses and property, including, without limitation, 
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pecuniary harm to their careers and professional prospects, in an amount to be 
determined at trial. 
502. As an example of the injury to business and property suffered by Jane 
Doe 1 and other Class Members, because of being coercively sex trafficked and 
sexually abused by Epstein, Jane Doe 1 and other Class Members were preventing 
from pursuing other employment opportunities. As a direct and proximate result of 
the acts of the RICO Enterprise generally and Deutsche Bank in particular, Jane Doe 
1 and the Class Members lost legitimate employment opportunities. The lost 
opportunities produced concrete financial loss. 
503. As another example of the injury to business and property suffered by 
Jane Doe 1 and other class members, because of being coercively sex trafficked and 
sexually abused by Epstein and the Enterprise, Jane Doe 1 and other Class Members 
directly and proximately lost an ability to pursue gainful employment while being 
coercively sexually trafficked and sexually abused by Epstein. Indeed, it is these 
lost opportunities—which themselves constituted injury to business and property—
were the Enterprise's direct target, because the lost opportunities rendered Jane Doe 
1 and the other Class Members more economically and financially reliant on the 
Sex-Trafficking Enterprise and therefore more vulnerable to the trafficking and 
abuse. It was part of Epstein's coercive sex trafficking that he would discourage and 
prevent Jane Doe 1 and the Class Members from obtaining employment and income 
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outside of that provided by the Sex-Trafficking Enterprise. 
504. Direct and proximately because of the pattern of racketeering activity 
by the Epstein Sex-Trafficking Enterprise, Jane Doe 1 and other Class Members 
were rendered, in whole or substantial part, economically dependent on the 
Enterprise and therefore more vulnerable to the Enterprise's sex trafficking. Indeed, 
it was part of the Enterprise's pattern of racketeering activity—and a goal of that 
activity— to render its victims economically vulnerable to any effort to escape from 
Epstein's sex trafficking. 
505. As another example of the injury suffered by Jane Doe 1 and other class 
members, because of being coercively sex trafficked and sexually abused by Epstein, 
Jane Doe 1 and other Class Members were falsely promised certain employment and 
professional opportunities by Epstein, which prevented them from pursuing other 
employment opportunities. Again, these false promises were part of the Enterprise's 
operation, because they forced and caused Epstein's victims to participate in 
commercial sex acts. Forcing sex-trafficking victims into a position of economic 
dependency on their traffickers is a well-known means of coercion—one that 
Deutsche Bank should have recognized and, in fact, did recognize. 
506. As another example of the injury suffered by Jane Doe 1 and other class 
members, Jane Doe 1 and other Class Members incurred alleged debts to the Epstein 
Sex-Trafficking Enterprise, which constituted injury to business and property. Jane 
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Doe 1 and the other Class Members would then be forced to pay off those debts by 
submitting to Epstein's sexual demands. 
More generally, the Epstein Sex-
Trafficking Enterprise forced Jane Doe I and the Class Members to participate in 
commercial sex acts by creating economic dependency on the Enterprise. 
507. The losses to their business and property that Jane Doe 1 and the Class 
Members suffered were by reason of the Epstein-Sex Trafficking Enterprise and its 
RICO violations. These losses were directly and proximately caused by the 
Enterprise's misconduct, including the predicate acts committed by the Enterprise. 
Because the losses stemmed from being forced to engage in commercial sex acts, 
the Enterprise's violations of 18 U.S.C. § 1591 were the direct (i.e., the "but-for") 
cause of the losses. Because those commercial sex acts were readily foreseeable 
(and, indeed, were foreseen) by the participants in the Enterprise—including 
Deutsche Bank—the losses were proximately caused by the Enterprise's violations 
of 18 U.S.C. §§ 1591-94 and 1962(c). 
508. The losses to the business and property that Jane Doe I and the Class 
Members suffered were directly caused by Deutsche Bank's violations of 18 U.S.C. 
§§ 1591-94 and 1962(c). There was a direct relationship between Deutsche Bank's 
violations of 18 U.S.C. §§ 1591-94 and I 962(c). Put directly, the Epstein Sex-
Trafficking Enterprise was committing coercive sex-trafficking; and Jane Doe 1 and 
the Class Members were the direct and intended victims of that coercive-sex 
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trafficking. There was no attenuation between the Enterprise and the injuries to 
business and property it caused to Jane Doe 1 and the Class Members. There were 
no intervening causes of the injuries to business and property suffered by Jane Doe 
I and the Class Members. 
509. Jane Doe 1 and the Class Members are in the best position to enforce 
the legal requirements in question, including the legal requirements stemming from 
18 U.S.C. § 1591-94 and 18 U.S.C. § 1962(c). They are young women who have 
suffered losses to business and property from the coercive sex-trafficking by the 
Epstein Sex-Trafficking Enterprise and are seeking to hold accountable those 
responsible for the losses to business and property from that victimization. There 
are no more directly injuries parties who could bring this suit. 
510. Jane Doe I and the other Class Members will be able to provide 
reasonable quantification of the losses to their business and property at trial. 
Determining those losses will not be difficult and no complicated rules will be 
required to avoid the risk of multiple recoveries. 
511. Jane Doe 1 and other Class Members will be able to acquire additional 
evidence supporting their RICO losses through discovery. 
512. Deutsche Bank received income in interstate commerce, derived 
directly and indirectly from participating in a pattern of racketeering activity, 
specifically by obtaining interest and other things of value from financially 
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