Jane Doe 1 v. Deutsche Bank Aktiengesellschaft et al.

Jane Doe 1 v. Deutsche Bank Aktiengesellschaft et al. was a putative class action filed in the Southern District of New York on November 24, 2022 by an Epstein survivor proceeding under pseudonym, on behalf of a class of women alleged to have been trafficked by Jeffrey Epstein during the period in which Deutsche Bank served as his successor banking institution after JPMorgan exited the relationship in 2013. The First Amended Class Action Complaint (EFTA00161958), filed January 13, 2023 against Deutsche Bank Aktiengesellschaft, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company Americas, brought claims under the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591–1595, the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. §§ 1961–1968, and the New York Adult Survivors Act, N.Y. C.P.L.R. § 214-j, together with state-law claims for aiding and abetting and intentional infliction of emotional distress (EFTA00161958 at 1–2). The action was assigned to Judge Jed S. Rakoff.

The complaint pleaded that Deutsche Bank "knowingly benefited and received things of value" by providing the "financial lifeblood and infrastructure" for Epstein's trafficking organization, that the bank knew Epstein was committing specific New York Penal Law Article 130 sex offenses against young women, and that the bank "engaged in repeated acts of racketeering activity to support the Epstein organization" (EFTA00161958 at 2). The Doe class period tracked the period in which Deutsche Bank held Epstein's accounts — the bank had publicly disclosed in a 2020 New York Department of Financial Services consent order that it had failed to apply adequate anti-money-laundering controls to suspicious payments from Epstein-controlled accounts to women, attorneys, and others between 2013 and 2018.

In early 2023 the Court consolidated 22-cv-10018 for discovery with two parallel actions before the same judge: Jane Doe 1 v. JPMorgan Chase Bank, N.A., 22-cv-10019 (S.D.N.Y.), filed days earlier against Epstein's prior bank, and the parens patriae enforcement action Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., 22-cv-10904 (S.D.N.Y.), filed by the V.I. Attorney General one month after Doe (EFTA02807219). On March 20, 2023, Judge Rakoff issued a single consolidated bottom-line order ruling on both bank defendants' Rule 12(b)(6) motions across all three cases (EFTA02806578); a 54-page Opinion and Order issued May 1, 2023 explained the reasoning (EFTA02807221). Against Deutsche Bank, the Court dismissed Counts II, III, IV, V, VII, VIII, IX, and X of the First Amended Complaint and sustained Counts I, VI, XI, and XII — leaving in the case the TVPA § 1591(a)(2) beneficiary claim, the TVPA § 1591(d) obstruction claim, and two negligence claims (negligence to prevent physical harm and negligent provision of non-routine banking services) (EFTA02806578 at 2).

The parties announced a class settlement of approximately $75 million in May 2023, before the consolidated summary-judgment record in 22-cv-10904 was developed. Because the substantive fact-discovery and Daubert phase that followed was litigated principally under the JPMorgan-and-USVI caption with Jes Staley as third-party defendant, Deutsche Bank dropped out of the cross-caption from spring 2023 onward; subsequent dual-caption filings name the JPMorgan and USVI plaintiffs only. The Doe v. Deutsche Bank case is closed at the trial-court level.

The corpus contains 37 EFTA-stamped pages and 27 emails linked to docket 22-cv-10018, drawn from three distinct phases of the litigation: the operative pleadings filed in January 2023, the consolidated motion-to-dismiss record from spring 2023, and a small group of objector-class-member filings made under the Doe/Deutsche Bank cross-caption during the parallel JPMorgan settlement fairness process in October 2023. Document types in the sample include the First Amended Class Action Complaint (EFTA00161958, 163 pp.), Judge Rakoff's two-step ruling on the Rule 12(b)(6) motions (the March 20, 2023 bottom-line order at EFTA02806578 and the May 1, 2023 Opinion and Order at EFTA02807221), an order requiring "DB Jane Doe" to disclose her identity to JPMorgan and to third-party defendant Jes Staley on a confidential basis (EFTA02807131), pro hac vice orders documenting consolidation with 22-cv-10019 and 22-cv-10904 (EFTA02807219, EFTA02807275), and FBI New York and San Juan internal email threads in which agents circulate the Doe v. Deutsche Bank, Doe v. JPMorgan, and USVI v. JPMorgan amended complaints (EFTA00156578, EFTA00161833).

The Doe v. Deutsche Bank-specific filings in the sample show the substantive shape of the case at the pleading stage. The First Amended Complaint frames Deutsche Bank as having taken on Epstein as a client "after Epstein's well-publicized 2008 conviction" and pleads predicate-act RICO theories alongside the TVPA beneficiary and obstruction counts, with reference to specific New York Penal Law sex offenses defined by Article 130 (EFTA00161958 at 1–2). Judge Rakoff's May 1, 2023 Opinion (EFTA02807221) is the principal merits decision in the case at the trial-court level: it sustained the federal TVPA § 1591(a)(2) beneficiary count, the § 1591(d) obstruction count, and two negligence counts against Deutsche Bank, while dismissing the bank's RICO counts and several adjacent state-law theories. Because the Doe and JPMorgan class actions were consolidated, several Doe-stage filings appear on the docket in cross-caption form — including the proposed JPMorgan Notice of Class Action Settlement and Questionnaire and Release attached to the Boies–Edwards joint declaration (EFTA01652881, EFTA00146745, EFTA00146735), under which class members seeking to recover from the JPMorgan settlement were also asked to release "any person who is connected to or otherwise associated with Jeffrey Epstein or any Jeffrey Epstein sex trafficking venture" between January 1, 1998 and August 10, 2019 (EFTA00146745 at 1).

A small but distinct subset of filings comes from a separately represented class member who objected to the JPMorgan settlement structure and filed her objections under the consolidated Doe/Deutsche Bank caption: the Objections to Proposed Settlement (EFTA00037109) and the Declaration of Objector/Class Member (EFTA00144588). These cross-caption objector filings were filed in 22-cv-10019 (the JPMorgan docket) but reference the Doe v. Deutsche Bank action by case number on the caption and were assigned EFTA numbers tied to the 10018 case. The corpus does not contain the executed Doe v. Deutsche Bank settlement agreement, the Court's final approval order in 22-cv-10018, the Doe class notice and claims-administration record specific to the Deutsche Bank settlement, the bank's internal AML and KYC files on the Epstein relationship, or the deposition transcripts and exhibits that were developed in the joint-discovery phase principally under the 22-cv-10904 caption.