Here is the complaint in Seminole Tribe v. Wells Fargo Bank NA (17th Jud. Cir., Fla.):

Complaint

An excerpt:

The Seminole Tribe of Florida seeks to recover millions of dollars of fees fraudulently charged Minor Tribe Members when Wells Fargo was supposed to be acting as a fiduciary trustee to protect the financial interests of those same minors. Instead Wells Fargo engaged in a decade-long fraudulent scheme using deficient and confusing account statements to conceal the collection of unauthorized fees to the minor beneficiaries. The Tribe also seeks to recover for its Minor Tribe Members at least one hundred million dollars in lost value to the trust as a result of the Trustee’s gross mismanagement of the trust assets by negligently employing imprudent investment strategies. It is evident that Wells Fargo focused its attention on concealing the collection of unauthorized fees instead of adopting a viable investment protocol. It appears as if, the Trustee established the trust, placed it in cruise-control, failed to properly advise the Tribe or its minor beneficiaries on investment strategies, and invested in a deficient portfolio in order to defraud the minor beneficiaries out of millions of dollars in fraudulent fees. The bank’s collection of fraudulent fees and the gross mismanagement of the trust is a breach of fiduciary duty to the beneficiaries and the proximate cause of the plaintiffs damages.