Giuffre_Maxwell_Batch2_p00129.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 21 of 24
including but not limited to, awards in other similar matters, that the
amount is not less than $30,000.000.00. Ms. Giuffre is in the process
of retaining an expert, and will provide further information through
expert disclosure.
b. Supporting Evidence
i.
ii,
iii.
iv.
Ms. Giuffre’s testimony
Witness testimony
Awards in similar matters
Ms. Giuffre is in the process of retaining an expert, and will provide
further information through expert disclosure.
3, Estimated lost income of $180,000 annually. Present value of $3,461,000 to
$5,407,000.
a. Computation Analysis
i,
Ms, Giuffre’s estimated compensation capacity is $180,000 annually.
Ms, Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged injury occurred. Her expected
remaining work life based on mortality and probability of continued
work was 20,2 years. Based on these factors, a 2% annual growth rate
and a 2.4% discount rate, the present value of lost compensation is
$3,461,000 as of 1/1/2015.
Alternatively, if Ms. Giuffre is assumed to work until a normal
retirement age of 65, or 33.6 years from her age at the beginning of
2015, and based on an annual growth rate of 2.0% and a discount rate
of 2.7%, the present value of lost compensation is $5,407,000 as of
1/1/2015.
b. Supporting Evidence
i,
Materials regarding compensation and work life expectancy
1) 2010 Life Table for Females, National Vital Statistics Report,
November 6, 2014, U.S. Department of Health & Human
Services, Centers for Disease Control & Prevention, National
Center for Health Statistics.
20
CONFIDENTIAL
Extracted Information
Document Details
| Filename | Giuffre_Maxwell_Batch2_p00129.png |
| File Size | 1350.0 KB |
| OCR Confidence | 94.6% |
| Has Readable Text | Yes |
| Text Length | 1,676 characters |
| Indexed | 2026-02-04 12:37:37.528938 |