Giuffre_Maxwell_Batch5_p00076.png

Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 22 of 26 21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21. 22. January 3, 2015 Daily Mail article: “Harvard Law Professor Named Alongside Prince Andrew in ‘Sex Slave’ Case Accuses Alleged Victim of ‘Making Up Stories,’” attached hereto as Exhibit 22. 23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in “Ghislaine Maxwell: I was not a madam for paedophile,” attached as Exhibit 23. 24. January 4, 2015 Statement by Ghislaine Maxwell to New York Daily News Reporter “Alleged Madam Accused of Supplying Prince Andrew With Underage Teen for Sex Spotted in NYC — As He’s Seen Cutting Swiss Vacation Short to Face Queen,” attached hereto as Exhibit 24. 25. February 1, 2015 Mirror article: “Prince Andrew’s Pal Ghislaine Maxwell May Sue Over Madam Allegations,” attached hereto as Exhibit 25. 26. September 23, 2007 Red Ice Creations Article “Prince Andrew’s Friend, Ghislaine Maxwell, Some Underage Girls, and A Very Disturbing Story,” attached hereto as Exhibit 26. 27. Photographs, attached hereto as Exhibit 27. 28. April 13, 2010 Deposition Transcript of Nadia Marcinkova, attached hereto as Exhibit 28. Computation of damages: Bs Physical, psychological and psychiatric injuries and resulting medical expenses — in an amount of approximately $ 102,200 present value. a. Computation Analysis: i. Giuffre has had to receive treatment for the psychological harm as a result of Maxwell’s conduct towards Giuffre. ii. The average annual expenditures for mental health services for adults 18-64 in the United States is $1,751. iii. 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 a 31 year old female is 51.1 years. iv. 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. 21 CONFIDENTIAL as to victims’ identity pursuant to Court’s June 23, 2016 Order