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Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 20 of 24 iii. The average annual expenditures for mental health services for adults 18-64 in the United States is $1,751. Giuffre needs continuing care as a result of the harm she has suffered. Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the beginning of 2015 when the alleged harm occurred. The average remaining life expectancy for a31 year old female is 51.1 years. Based on a remaining life expectancy of 51.1 years, annual healthcare cost growth of 3.3% and a discount rate of 2.7%, the present value of expected treatment costs is $102,200 as of 1/1/2015. b. Supporting Evidence: i. ii, iii, Ms, Giuffre is in the process of collecting records from her physicians Ms. Giuffre’s testimony Ms, Giuffre is in the process of retaining an expert to calculate damages, and will provide further information through expert disclosure, e Past, present and future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of standing in the community, loss of dignity and invasion of privacy in her public and private life not less than $30,000,000.00. a. Computation Analysis i. Under New York law, defamation per se as alleged in this case presumes damages and special damages do not need to be plead and proven. See Celle v. Filipino Reporter Enterprises Inc., 209 F.3d 163, 179 (2"! Cir. 2000) (Second Circuit holding that ‘[i]f a statement is defamatory per se, injury is assumed. In such a case ‘even where the plaintiff can show no actual damages at all, a plaintiff who has otherwise shown defamation may recover at least nominal damages’ and the Second Circuit also confirmed an award of punitive damages). Ms. Giuffre has been severely damaged by the defamation of the defendant, by calling her claims of sexual abuse “obvious lies”. The defamation caused Ms. Giuffre to re-live the sexual abuse she previously endured. Ms. Giuffre has suffered and continues to suffer from the pain, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of standing in the community, loss of dignity and invasion of privacy in her public and private life. The computation of this amount is in the province of the jury but Ms. Giuffre contends, 19 CONFIDENTIAL