Giuffre_Maxwell_Batch2_p00130.png

Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 22 of 24 2) “Calculation of Work life Expectancy Using the Life, Participation, Employment Method,” Vocational Econometrics, Inc. 3) Consumer Price Index for Urban Wage Earners and Clerical Workers, United States Department of Labor, Bureau of Labor Statistics. 4) Federal Reserve Statistical Release H.15, 1/5/2015. ii. Ms. Giuffre’s testimony iii. Ms, Giuffre is in the process of retaining a damages expert and will provide further information through expert disclosures. 4. Punitive Damages - to be based upon all relevant factors, including the egregious nature of Defendant, Ghislaine Maxwell’s conduct and the need for a large award to punish and deter conduct in view of the vast wealth of Defendant Maxwell, in an amount not less than $50,000,000.00. a. This calculation is in the province of the jury. 21 CONFIDENTIAL