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Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 23 of 26 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. 2. 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 qa" 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, 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. Ms. Giuffre’s testimony 22 CONFIDENTIAL as to victims’ identity pursuant to Court’s June 23, 2016 Order