EFTA00161958.txt

"Epstein sexually abused and trafficked Jane Doe 1"

"Paul Morris joined Deutsche Bank as a relationship manager in November 2012"

"Charles Packard was co-head of Deutsche Bank's Wealth Management Americas Group"

"Numerous Deutsche Bank employees, including Paul Morris, Charles Packard and Patrick Harris"

"On July 6, 2020, Deutsche Bank agreed to pay a fine of $150 million to the New York State Department of Financial Services"

"Charles Packard was co-head of Deutsche Bank's Wealth Management Americas Group"

"Patrick Harris was the Chief Operating Officer of Wealth Management Americas for Deutsche Bank"

"Epstein and his co-conspirators sexually trafficked and sexually abused Plaintiff Jane Doe 1"

"Epstein recruited, solicited, coerced, harbored, transported, and enticed some of his victims, including Jane Doe 1"

"sexually abused more than 30 children in his Palm Beach, Florida mansion"

"Jeffrey Epstein was an extraordinarily wealthy man with multiple residences in the United States, including a New York City mansion"

"Jeffrey Epstein was an extraordinarily wealthy man with multiple residences in the United States, including... a New Mexico Ranch"

"Jeffrey Epstein was an extraordinarily wealthy man with multiple residences in the United States, including... a Palm Beach mansion"

"Jeffrey Epstein was an extraordinarily wealthy man with multiple residences in the United States, including... an island in the U.S. Virgin Islands"

"Epstein was sexually abusing three to four young females per day, in every location he was in"

"he would lure young women or girls to one of his luxurious mansions, under the guise of being a wealthy philanthropist"

"In 2013... He found that partner in Deutsche Bank"

"newly recruited victims were each paid hundreds of dollars in cash immediately after Epstein sexually abused them, as hush money"

"Epstein was continuously at the hub of The Organization"

"the United States Attorney's Office for the Southern District of New York filed a sealed, two-count Indictment against Epstein"

"Epstein's criminal activities in his New York Mansion located at 9 East 71st Street"

"Epstein's co-conspirator in the origin of the sex-trafficking venture, Ghislaine Maxwell"

"The charges alleged that she had assisted, facilitated, and contributed to Epstein's abuse of sex trafficking victims, helping Epstein to recruit, gro"

"Maxwell was found guilty in this Court on five federal sex-trafficking counts"

"In about 2003, Jane Doe 1 moved to New York City where she was introduced to and sexually abused by Jeffrey Epstein."

"Epstein recruited Jane Doe 1 to, among other things, cause her to engage in commercial sex acts"

"he housed her at his victim stash houses that he owned at 310 East 66 Street, NY, NY"

"Epstein controlled where Doe 1 lived, and he housed her at his victim stash houses that he owned at 310 East 66 Street, NY, NY"

"Epstein continued to demand sexual compliance from Doe 1... Epstein penetrated Jane Doe 1"

"From on or about August 19, 2013, through about July 2020, Deutsche Bank knowingly and intentionally participated in the Epstein sex-trafficking ventu"

"On July 20, 2020, the New York State Department of Financial Service (hereinafter "New York Banking Regulators") and Deutsche Bank agreed to a"

"While Deutsche Bank was providing Epstein more than $200,000 in cash per year"

"On December 21, 2018... Deutsche Bank informed Epstein by letter that they would no longer be servicing his accounts"

"Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23... about Jeffrey Epstein"

"Epstein was using Deutsche Bank accounts to facilitate his sex abuse"

"On July 20, 2020, the New York State Department of Financial Service... and Deutsche Bank agreed to a Consent Order... Deutsche Bank agreed to pay a p"

"a Deutsche Bank relationship manager, Paul Morris"

"his co-conspirators (including Lesley Groff"

"his co-conspirators (including... Sarah Kellen"

"his co-conspirators (including... Adriana Ross"

"his co-conspirators (including... Nadia Marcinkova)"

"the investigation regarding Epstein"

"Epstein would use means of force, threats of force, fraud, coercion, and a combination of such means to cause Jane Doe 1... to engage in commercial se"

"provide $200,000 per year in cash to someone like Epstein"

"The cash was also a necessary and required part of Epstein's recruitment of Jane Doe 1"

"PlaintiffJane Doe 1 realleges and incorporates by reference paragraphs 1 — 314"

"Jane Doe 1 and her counsel are unaware of any class action brought against any Defendant for the violations alleged in this action"

"Stuart Clarke, Chief Operating Officer for the Americas and General Manager of Deutsche Bank's New York branch"

"Jan Ford, a Managing Director and Deutsche Bank Americas Head of Compliance"

"On January 30, 2015, members of the ARRC, including Stuart Clarke... and Jan Ford... met to discuss the Epstein relationship"