VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_19-vv-00507
Package ID: USCOURTS-cofc-1_19-vv-00507
Petitioner: J.J.S.
Filed: 2019-04-05
Decided: 2023-10-05
Vaccine: DTaP; hepatitis B; MMR; IPV; varicella
Vaccination date: 2016-04-06
Condition: left arm cellulitis and/or abscess allegedly following DTaP, hepatitis B, MMR, IPV, and/or varicella vaccines
Outcome: compensated
Award amount USD: 49831.65

AI-assisted case summary:
On April 5, 2019, Julio Samble filed a petition under the National Vaccine Injury Compensation Program on behalf of his minor child, J.J.S. The petition alleged that J.J.S. received diphtheria-tetanus-acellular pertussis (DTaP), hepatitis B (Hep B), measles-mumps-rubella (MMR), inactivated poliovirus (IPV), and/or varicella vaccinations on April 6, 2016, and subsequently developed a left arm abscess. The case was assigned to the Special Processing Unit. On July 22, 2019, respondent conceded entitlement to compensation, stating that a preponderance of the medical evidence established that J.J.S.'s cellulitis and/or abscess was caused-in-fact by one or more of the April 6, 2016 vaccines, that no other cause was identified, and that the injury met the Vaccine Act's severity requirement due to inpatient hospitalization and surgical intervention. Chief Special Master Nora Beth Dorsey accepted this concession and ruled J.J.S. entitled to compensation. The public entitlement ruling does not specify J.J.S.'s date of birth or exact age, identify which vaccine was most likely responsible, detail the onset date, or provide specifics about the hospitalization and surgery beyond the general findings. Damages were addressed in two separate proffers. Initially, in September 2019, the parties proposed an award of $35,000.00 for pain and suffering, plus $14,831.65 for past unreimbursed medical expenses, totaling $49,831.65. However, this initial judgment had to be vacated due to issues related to guardianship required for the settlement. A final controlling damages decision was entered on October 5, 2023, by Chief Special Master Brian H. Corcoran. Under the revised terms, petitioner received a lump sum of $14,831.65 for past unreimbursable expenses. Additionally, up to $35,000.00 was allocated to purchase an annuity for J.J.S.'s pain and suffering. This annuity was structured with specific lump sum payments scheduled for April 1, 2033 ($17,799.71), April 1, 2036 ($20,570.55), and April 1, 2039 ($23,765.48). The payment due on April 1, 2039, is adjustable to ensure the total cost of the annuity purchase does not exceed $35,000.00. The total visible value of the final award was $49,831.65. Petitioner was represented by Russell Anthony Murray of Lovett Law Firm. Respondent's counsel included Mollie Danielle Gorney and Alexis B. Babcock.

Theory of causation field:
Minor J.J.S. received DTaP, hepatitis B, MMR, IPV, and/or varicella vaccinations on April 6, 2016. Petitioner alleged a left arm abscess resulted from these vaccinations. Respondent conceded entitlement on July 22, 2019, agreeing that a preponderance of the medical evidence showed one or more of the vaccines caused J.J.S.'s cellulitis/abscess, no other cause was identified, and the injury met the Vaccine Act's severity requirement due to inpatient hospitalization and surgical intervention. The public decisions do not specify J.J.S.'s exact age or date of birth, the onset date of the injury, details of the hospitalization or surgical intervention, or which specific vaccine(s) caused the injury. Initially, in September 2019, Chief Special Master Nora Beth Dorsey awarded $35,000.00 for pain and suffering and $14,831.65 for past unreimbursed medical expenses, totaling $49,831.65. This award was later vacated due to guardianship issues. On October 5, 2023, Chief Special Master Brian H. Corcoran issued a final decision based on a revised proffer. The final award consists of a $14,831.65 lump sum for past unreimbursable expenses and up to $35,000.00 to purchase an annuity for pain and suffering. The annuity includes scheduled payments of $17,799.71 on April 1, 2033, $20,570.55 on April 1, 2036, and $23,765.48 on April 1, 2039, with the final payment adjusted to ensure the annuity's purchase price is exactly $35,000.00. The total visible value of the award is $49,831.65. Petitioner's attorney was Russell Anthony Murray; respondent's attorneys included Mollie Danielle Gorney and Alexis B. Babcock.

Public staged source text:

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DOCUMENT 1: USCOURTS-cofc-1_19-vv-00507-0
Date issued/filed: 2019-10-11
Pages: 2
Docket text: PUBLIC ORDER/RULING (Originally filed: 07/22/2019) regarding 12 Ruling on Entitlement Signed by Special Master Nora Beth Dorsey. (ypb) Service on parties made.
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Case 1:19-vv-00507-UNJ Document 19 Filed 10/11/19 Page 1 of 2
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 19-0507V
Filed: July 22, 2019
UNPUBLISHED
JULIO SAMBLE, on behalf of
J.J.S., a Minor,
Special Processing Unit (SPU);
Petitioner, Ruling on Entitlement; Concession;
v. Causation-In-Fact; Diphtheria
Tetanus acellular Pertussis (Dtap)
SECRETARY OF HEALTH AND Vaccine; Hepatitis B (Hep B)
HUMAN SERVICES, Vaccine; Measles Mumps Rubella
(MMR) Vaccine; Inactivated Polio
Respondent. (IPV) Vaccine; Varicella Vaccine;
Shoulder Injury Related to Vaccine
Administration (SIRVA)
Russell Anthony Murray, Lovett Law Firm, El Paso, TX, for petitioner.
Mollie Danielle Gorney, U.S. Department of Justice, Washington, DC, for respondent.
RULING ON ENTITLEMENT1
Dorsey, Chief Special Master:
On April 5, 2019, petitioner filed a petition for compensation under the National
Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq.,2 (the “Vaccine
Act”). Petitioner alleges that as a result of diphtheria-tetanus-acellular pertussis
(“DTap”), Hepatitis B (“Hep B”), measles-mumps-rubella (“MMR”), inactivated polio
(“IPV”), and/or varicella vaccinations administered on April 6, 2016, J.J.S. suffered from
1 The undersigned intends to post this ruling on the United States Court of Federal Claims' website. This
means the ruling will be available to anyone with access to the internet. In accordance with Vaccine
Rule 18(b), petitioner has 14 days to identify and move to redact medical or other information, the
disclosure of which would constitute an unwarranted invasion of privacy. If, upon review, the undersigned
agrees that the identified material fits within this definition, the undersigned will redact such material from
public access. Because this unpublished ruling contains a reasoned explanation for the action in this
case, undersigned is required to post it on the United States Court of Federal Claims' website in
accordance with the E-Government Act of 2002. 44 U.S.C. § 3501 note (2012) (Federal Management
and Promotion of Electronic Government Services).
2 National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3755. Hereinafter, for
ease of citation, all “§” references to the Vaccine Act will be to the pertinent subparagraph of 42 U.S.C. §
300aa (2012).

Case 1:19-vv-00507-UNJ Document 19 Filed 10/11/19 Page 2 of 2
a left arm abscess. Petition at 1. The case was assigned to the Special Processing
Unit of the Office of Special Masters.
On July 22, 2019, respondent filed his Rule 4(c) report in which he concedes that
petitioner is entitled to compensation in this case. Respondent’s Rule 4(c) Report at 1.
Specifically, respondent indicates that “a preponderance of the medical evidence
establishes that J.J.S.’s cellulitis and/or abscess was caused-in-fact by one or more of
the vaccines he received on April 6, 2016.” Id. at 3. Respondent further agrees that no
other causes for J.J.S.’s injury was identified, and the medical records demonstrate that
J.J.S. underwent an inpatient hospitalization and surgical intervention to meet the
severity requirement under the Vaccine Act. Id.
In view of respondent’s position and the evidence of record, the
undersigned finds that petitioner is entitled to compensation.
IT IS SO ORDERED.
s/Nora Beth Dorsey
Nora Beth Dorsey
Chief Special Master

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DOCUMENT 2: USCOURTS-cofc-1_19-vv-00507-1
Date issued/filed: 2019-10-22
Pages: 5
Docket text: PUBLIC DECISION (Originally filed: 09/13/2019) regarding 18 DECISION Stipulation/Proffer Signed by Special Master Nora Beth Dorsey. (ypb) Service on parties made.
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Case 1:19-vv-00507-UNJ Document 21 Filed 10/22/19 Page 1 of 5
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 19-0507V
Filed: September 13, 2019
UNPUBLISHED
JULIO SAMBLE, on behalf of
J.J.S., a Minor
Petitioner,
Special Processing Unit (SPU);
v.
Damages Decision Based on Proffer;
Diphtheria Tetanus acellular
SECRETARY OF HEALTH AND
Pertussis (DTap) Vaccine; Hepatitis
HUMAN SERVICES,
B (Hep B) Vaccine; Measles Mumps
Rubella (MMR) Vaccine; Inactivated
Respondent.
Polio (“IPV”) Vaccine; Varicella
Vaccine; Shoulder Injury Related to
Vaccine Administration (SIRVA)
Russell Anthony Murray, Lovett Law Firm, El Paso, TX, for petitioner.
Mollie Danielle Gorney, U.S. Department of Justice, Washington, DC, for respondent.
DECISION AWARDING DAMAGES1
Dorsey, Chief Special Master:
On April 5, 2019, petitioner filed a petition for compensation under the National
Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq.,2 (the “Vaccine
Act”). Petitioner alleges that as a result of diphtheria-tetanus-acellular pertussis
(“DTap”), Hepatitis B (“Hep B”), measles-mumps-rubella (“MMR”), inactivated polio
(“IPV”), and/or varicella vaccinations administered on April 6, 2016, J.J.S. suffered from
a left arm abscess. Petition at 1. The case was assigned to the Special Processing
Unit of the Office of Special Masters.
1 The undersigned intends to post this decision on the United States Court of Federal Claims' website.
This means the decision will be available to anyone with access to the internet. In accordance with
Vaccine Rule 18(b), petitioner has 14 days to identify and move to redact medical or other information,
the disclosure of which would constitute an unwarranted invasion of privacy. If, upon review, the
undersigned agrees that the identified material fits within this definition, the undersigned will redact such
material from public access. Because this unpublished decision contains a reasoned explanation for the
action in this case, undersigned is required to post it on the United States Court of Federal Claims'
website in accordance with the E-Government Act of 2002. 44 U.S.C. § 3501 note (2012) (Federal
Management and Promotion of Electronic Government Services).
2 National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3755. Hereinafter, for
ease of citation, all “§” references to the Vaccine Act will be to the pertinent subparagraph of 42 U.S.C. §
300aa (2012).

Case 1:19-vv-00507-UNJ Document 21 Filed 10/22/19 Page 2 of 5
On July 22, 2019, a ruling on entitlement was issued, finding petitioner entitled to
compensation for J.J.S.’s left arm abscess. On September 11, 2019, respondent filed a
proffer on award of compensation (“Proffer”) indicating petitioner should be awarded
$49,831.65 (comprised of $35,000.00 for pain and suffering and $14,831.65 for past,
unreimbursed medical expenses). Proffer at 1. In the Proffer, respondent represented
that petitioner agrees with the proffered award. Id. Based on the record as a whole, the
undersigned finds that petitioner is entitled to an award as stated in the Proffer.
Pursuant to the terms stated in the attached Proffer, the undersigned awards
petitioner a lump sum payment of $35,000 (representing compensation for J.J.S.’s
pain and suffering) in the form of a check payable to petitioner, Julio Samble, as
guardian/conservator of the estate of J.J.S. for the benefit of J.J.S3 and a lump
sum payment of $14,831.65 (representing compensation for past, unreimbursed
medical expenses) made payable to petitioner, Julio Samble. This amount
represents compensation for all damages that would be available under § 15(a).
The clerk of the court is directed to enter judgment in accordance with this
decision.4
IT IS SO ORDERED.
s/Nora Beth Dorsey
Nora Beth Dorsey
Chief Special Master
3 No payment shall be made until petitioner provides the Secretary of Health and Human Services (the
“Secretary”) with documentation establishing his appointment as guardian/conservator of J.J.S.’s estate.
If petitioner is not authorized by a court of competent jurisdiction to serve as guardian/conservator of the
estate of J.J.S. at the time a payment pursuant to the terms stated in the Proffer, any such payment shall
be paid to the party or parties appointed by a court of competent jurisdiction to serve as
guardian(s)/conservator(s) of the estate of J.J.S. upon submission of written documentation of such
appointment to the Secretary.
4 Pursuant to Vaccine Rule 11(a), entry of judgment can be expedited by the parties’ joint filing of notice
renouncing the right to seek review.
2

Case 1:19-vv-00507-UNJ Document 21 Filed 10/22/19 Page 3 of 5
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
)
JULIO SAMBLE, on behalf of )
J.J.S., a Minor, )
)
Petitioner, ) No. 19-0507V
) Chief Special Master Dorsey
v. ) ECF
)
SECRETARY OF HEALTH AND HUMAN )
SERVICES, )
)
Respondent. )
RESPONDENT’S PROFFER ON AWARD OF COMPENSATION
I. Items of Compensation
On July 22, 2019, respondent conceded that entitlement to compensation was appropriate
under the terms of the Vaccine Act. Thereafter, on the same date, Chief Special Master Dorsey
issued a Ruling on Entitlement, finding that petitioner was entitled to vaccine compensation for
J.J.S.’s left arm abscess. Based upon the evidence of record, respondent proffers that petitioner
should be awarded $49,831.65. The award is comprised of the following: $35,000.00 for pain
and suffering and $14,831.65 for past, unreimbursed medical expenses. This amount represents
all elements of compensation to which petitioner would be entitled under 42 U.S.C. § 300aa-
15(a). Petitioner agrees.
II. Form of the Award
The parties recommend that compensation provided to petitioner should be made through
a lump sum payment as described below, and request that the Chief Special Master’s decision
and the Court’s judgment award the following:
A. A lump sum payment of $35,000.00 representing compensation for J.J.S.’s pain

Case 1:19-vv-00507-UNJ Document 21 Filed 10/22/19 Page 4 of 5
and suffering in the form of a check payable to petitioner as
guardian/conservator of the estate of J.J.S. for the benefit of J.J.S. No payment
shall be made until petitioner provides the Secretary with documentation
establishing his appointment as guardian/conservator of J.J.S.’s estate. If
petitioner is not authorized by a court of competent jurisdiction to serve as
guardian/conservator of the estate of J.J.S at the time a payment pursuant to this
Proffer is to be made, any such payment shall be paid to the party or parties
appointed by a court of competent jurisdiction to serve as
guardian(s)/conservator(s) of the esate of J.J.S. upon submission of written
documentation of such appointment to the Secretary.
B. A lump sum payment of $14,831.65, representing compensation
for past, unreimbursed medical expenses, made payable to petitioner.
Respectfully submitted,
JOSEPH H. HUNT
Assistant Attorney General
C. SALVATORE D’ALESSIO
Acting Director
Torts Branch, Civil Division
CATHARINE E. REEVES
Deputy Director
Torts Branch, Civil Division
HEATHER L. PEARLMAN
Assistant Director
Torts Branch, Civil Division

Case 1:19-vv-00507-UNJ Document 21 Filed 10/22/19 Page 5 of 5
/s/ Mollie D. Gorney
MOLLIE D. GORNEY
Trial Attorney
Torts Branch, Civil Division
U.S. Department of Justice
P.O. Box 146
Benjamin Franklin Station
Washington D.C. 20044-0146
(202) 616- 4029
mollie.d.gorney@usdoj.gov
Dated: September 11, 2019

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DOCUMENT 3: USCOURTS-cofc-1_19-vv-00507-2
Date issued/filed: 2023-11-06
Pages: 6
Docket text: PUBLIC DECISION (Originally filed: 10/05/2023) regarding 26 DECISION Stipulation/Proffer ( Signed by Chief Special Master Brian H. Corcoran. )(mpj) Service on parties made.
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Case 1:19-vv-00507-UNJ Document 30 Filed 11/06/23 Page 1 of 6
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 19-0507V
JULIO SAMBLE, on behalf of Chief Special Master Corcoran
J.J.S., a Minor ,
Filed: October 5, 2023
Petitioner,
v.
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Russell Anthony Murray, Lovett Law Firm, El Paso, TX, for Petitioner.
Alexis B. Babcock, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION AWARDING DAMAGES1
On April 5, 2019, Julio Samble, on behalf of his minor child, J.J.S., filed a petition
for compensation under the National Vaccine Injury Compensation Program, 42 U.S.C.
§300aa-10, et seq.2 (the “Vaccine Act”). Petitioner alleges that J.J.S. suffered from a left
arm abscess as a result of a diphtheria-tetanus-acellular pertussis, Hepatitis B, measles-
mumps-rubella, inactivated polio, and/or varicella vaccinations administered on April 6,
2016. Petition at 1. The case was assigned to the Special Processing Unit of the Office
of Special Masters.
1 Because this Decision contains a reasoned explanation for the action taken in this case, it must be made
publicly accessible and will be posted on the United States Court of Federal Claims' website, and/or
at https://www.govinfo.gov/app/collection/uscourts/national/cofc, in accordance with the E-Government
Act of 2002. 44 U.S.C. § 3501 note (2018) (Federal Management and Promotion of Electronic Government
Services). This means the Decision will be available to anyone with access to the internet. In
accordance with Vaccine Rule 18(b), Petitioner has 14 days to identify and move to redact medical or other
information, the disclosure of which would constitute an unwarranted invasion of privacy. If, upon review, I
agree that the identified material fits within this definition, I will redact such material from public access.
2 National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3755. Hereinafter, for ease
of citation, all section references to the Vaccine Act will be to the pertinent subparagraph of 42 U.S.C. §
300aa (2018).

Case 1:19-vv-00507-UNJ Document 30 Filed 11/06/23 Page 2 of 6
On July 22, 2019, a ruling on entitlement was issued in Petitioner’s favor. ECF No.
12. Respondent next filed a proffer (“Original Proffer”) for a damages award of
$49,831.65. ECF No. 17. However, although judgment subsequently issued, the parties
recently asked for the judgment to be vacated due to circumstances relating to the
guardianship required by their settlement terms, and I acted accordingly.
On October 4, 2023, Respondent filed a new proffer on award of compensation
(“Proffer”). Under the revised terms, Petitioner will receive a lump sum payment of
$14,831.65 for past unreimbursable expenses, plus an amount not to exceed $35,000 to
purchase an annuity contract (pursuant to the terms set forth in the Proffer) that will be
used to pay pain and suffering amounts. Proffer at 2-3. In the Proffer, Respondent
represented that Petitioner agrees with the proffered award. Id. at 3.
Based on the record as a whole, I find that Petitioner is entitled to an award as
stated in the Proffer. Accordingly, and pursuant to the terms stated in the attached Proffer,
Petitioner is awarded:
A. A lump sum payment of $14,831.65 in the form of a check payable to
Petitioner for past umreimbursable expenses.
B. An amount not to exceed $35,000.00 to purchase an annuity contract, subject
to the conditions described in the Proffer, that will provide payments for
J.J.S.’s pain and suffering, paid to the life insurance company from which
the annuity will be purchase.
These amounts represent compensation for all damages that would be available
under Section 15(a).
The Clerk of Court is directed to enter judgment in accordance with this Decision.3
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
3 Pursuant to Vaccine Rule 11(a), entry of judgment can be expedited by the parties’ joint filing of notice
renouncing the right to seek review.
2

Case 1:19-vv-00507-UNJ Document 30 Filed 11/06/23 Page 3 of 6
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
JULIO SAMBLE, on behalf of
J.J.S., a Minor,
No. 19-507V
Petitioner,
Chief Special Master Corcoran
ECF
v.
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
RESPONDENT’S PROFFER OF DAMAGES
I. Procedural History
On April 5, 2019, Julio Samble, on behalf of his minor child, J.J.S. (“petitioner”) filed a
petition under the National Childhood Vaccine Injury Act of 1986, 42 U.S.C. §§ 300aa-1 to -34,
as amended (“Vaccine Act” or “Act”), alleging that J.J.S. suffered left arm abscess resulting from
diphtheria-tetanus-acellular pertussis (“DTap”), Hepatitis B (“Hep B”), measles-mumps-rubella
(“MMR”), inactivated polio (“IPV”), and/or varicella vaccinations administered on April 6, 2016.
Petition at 1. On July 22, 2019, respondent conceded that entitlement to compensation was
appropriate under the terms of the Vaccine Act. Thereafter, on the same date, Special Master
Dorsey issued a Ruling on Entitlement, finding that petitioner was entitled to vaccine
compensation for J.J.S.’s left arm abscess.

Case 1:19-vv-00507-UNJ Document 30 Filed 11/06/23 Page 4 of 6
II. Items of Compensation and Form of the Award
Based upon the evidence of record, respondent proffers, and the parties recommend, that
compensation be made through a lump sum and future annuity payments as described below, and
request that the Chief Special Master's decision and the Court's judgment award the following:1
A. Past Unreimbursable Expenses
Evidence supplied by petitioner documents his expenditure of past unreimbursable
expenses related to J.J.S.'s vaccine-related injury. Respondent proffers that petitioner should be
awarded past unreimbursable expenses in the amount of $14,831.65, in the form of a check
payable to petitioner. Petitioner agrees.
B. Pain and Suffering
For pain and suffering, an amount not to exceed $35,000.00 to purchase an annuity
contract,2 paid to the life insurance company3 from which the annuity will be purchased,4 subject
to the conditions described below, that will provide payments to J.J.S. as set forth below:
1 Should J.J.S. die prior to entry of judgment, the parties reserve the right to move the Court
for appropriate relief. In particular, respondent would oppose any award for future medical
expenses, future lost earnings, and future pain and suffering.
2 In respondent’s discretion, respondent may purchase one or more annuity contracts from
one or more life insurance companies.
3 The Life Insurance Company must have a minimum of $250,000,000 capital and surplus,
exclusive of any mandatory security valuation reserve. The Life Insurance Company must have
one of the following ratings from two of the following rating organizations:
a. A.M. Best Company: A++, A+, A+g, A+p, A+r, or A+s;
b. Moody's Investor Service Claims Paying Rating: Aa3, Aa2, Aa1, or Aaa;
c. Standard and Poor's Corporation Insurer Claims-Paying Ability Rating: AA-, AA,
AA+, or AAA;
d. Fitch Credit Rating Company, Insurance Company Claims Paying Ability Rating:
AA-, AA, AA+, or AAA.
4 Petitioner authorizes the disclosure of certain documents filed by the petitioner in this case
consistent with the Privacy Act and the routine uses described in the National Vaccine Injury
Compensation Program System of Records, No. 09-15-0056.
2

Case 1:19-vv-00507-UNJ Document 30 Filed 11/06/23 Page 5 of 6
1. A certain Lump Sum of $17,799.71 payable on April 1, 2033.
2. A certain Lump Sum of $20,570.55 payable on April 1, 2036.
3. A certain Lump Sum of $23,765.48 payable on April 1, 2039.
The purchase price of the annuity described in this section II.B shall neither be greater nor less
than $35,000.00. In the event that the cost of the certain lump sum annuity payments set forth
above varies from $35,000.00, the certain lump sum payment due on April 1, 2039, listed above,
shall be adjusted to ensure that the total cost of the annuity is neither less than nor greater than
$35,000.00. Should J.J.S. predecease any of the certain lump sum annuity payments set forth
above, said payments shall be made to his estate. Written notice to the Secretary of Health and
Human Services and to the Life Insurance Company shall be provided within twenty (20) days of
J.J.S.’s death.
These amounts represent all elements of compensation to which J.J.S. would be entitled
under 42 U.S.C. § 300aa-15(a). Petitioner agrees.5
III. Summary of Recommended Payments Following Judgment
A. Past Unreimbursable Expenses: $14,831.65
B. An amount of $35,000.00 to purchase the annuity contract
described above in section II. B.
Respectfully submitted,
BRIAN M. BOYNTON
Principal Deputy Assistant Attorney General
C. SALVATORE D’ALESSIO
Director
Torts Branch, Civil Division
5 At the time payment is received, J.J.S. will be an adult, and thus guardianship is not
required.
3

Case 1:19-vv-00507-UNJ Document 30 Filed 11/06/23 Page 6 of 6
HEATHER L. PEARLMAN
Deputy Director
Torts Branch, Civil Division
LARA A. ENGLUND
Assistant Director
Torts Branch, Civil Division
s/Alexis. B. Babcock
ALEXIS B. BABCOCK
Assistant Director
Torts Branch, Civil Division
U.S. Department of Justice
P.O. Box 146
Benjamin Franklin Station
Washington, D.C. 20044-0146
Tel: (202) 616-7678
alexis.babcock@usdoj.gov
DATED: October 4, 2023
4