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Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 24 of 26 ii. Witness testimony iii. Awards in similar matters iv. Ms. Giuffre is in the process of retaining an expert, and will provide further information through expert disclosure. 3. 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. 23 CONFIDENTIAL as to victims’ identity pursuant to Court’s June 23, 2016 Order