VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_19-vv-01031
Package ID: USCOURTS-cofc-1_19-vv-01031
Petitioner: Bilinda Anderson
Filed: 2019-07-17
Decided: 2023-01-30
Vaccine: influenza
Vaccination date: 2017-09-12
Condition: shoulder injury related to vaccine administration (SIRVA)
Outcome: compensated
Award amount USD: 71383

AI-assisted case summary:
Bilinda Anderson filed a petition for compensation under the National Vaccine Injury Compensation Program alleging that she suffered a shoulder injury related to vaccine administration (SIRVA) as a result of an influenza vaccine administered on September 12, 2017. The case was assigned to the Special Processing Unit. On September 13, 2022, the Chief Special Master issued Findings of Fact determining that Ms. Anderson provided preponderant evidence that the onset of her left shoulder pain occurred within 48 hours of vaccination. Respondent filed an Amended Rule 4(c) Report agreeing that Ms. Anderson had otherwise satisfied the criteria set forth in the Vaccine Injury Table and the Qualifications and Aids to Interpretation for SIRVA. Respondent conceded that Ms. Anderson satisfied all legal prerequisites for compensation. On December 23, 2022, a ruling on entitlement was issued, finding Ms. Anderson entitled to compensation. On December 28, 2022, Respondent filed a proffer on award of compensation, indicating Ms. Anderson should be awarded a lump sum payment of $65,000.00 for pain and suffering and $6,383.00 to satisfy a State of Maryland Medicaid lien. Ms. Anderson agreed with the proffered award. The Chief Special Master awarded Ms. Anderson a total of $71,383.00 in compensation.

Theory of causation field:
Table

Public staged source text:

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DOCUMENT 1: USCOURTS-cofc-1_19-vv-01031-0
Date issued/filed: 2022-10-17
Pages: 6
Docket text: PUBLIC ORDER/RULING (Originally filed: 09/13/2022) regarding 36 Findings of Fact & Conclusions of Law. Signed by Chief Special Master Brian H. Corcoran. (kle) Service on parties made.
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Case 1:19-vv-01031-UNJ Document 38 Filed 10/17/22 Page 1 of 6
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
19-1031
UNPUBLISHED
BILINDA ANDERSON, Chief Special Master Corcoran
Petitioner, Filed: September 13, 2022
v.
Special Processing Unit (SPU);
SECRETARY OF HEALTH AND Findings of Fact; Onset; Influenza
HUMAN SERVICES, (Flu); Shoulder Injury Related to
Vaccine Administration (SIRVA)
Respondent.
Maximillian J. Muller, Muller Brazil, LLP, Dresher, PA, for Petitioner.
Alexa Roggenkamp, U.S. Department of Justice, Washington, DC, for Respondent.
FINDINGS OF FACT1
On July 17, 2019, Bilinda Anderson 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 she suffered a shoulder injury related to vaccine
administration (“SIRVA”) as a result of an influenza (“flu”) vaccine administered on
September 12, 2017. Petition at 1. The case was assigned to the Special Processing Unit
of the Office of Special Masters.
1 Because this unpublished fact ruling contains a reasoned explanation for the action in this case, I am
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). This means the fact 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, 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 (2012).

Case 1:19-vv-01031-UNJ Document 38 Filed 10/17/22 Page 2 of 6
For the reasons discussed below, I find the onset of Petitioner’s shoulder pain
occurred within 48 hours of vaccination, consistent with the Table requirements for a
SIRVA claim.
I. Relevant Procedural History
As noted above, the case was initiated in July 2019. Despite attempts to informally
resolve this case, the parties reached an impasse in May 2021. ECF No. 31. On June 29,
2021, Respondent filed his Rule 4(c) Report recommending that entitlement to
compensation be denied under the terms of the Vaccine Act. ECF No. 32. Among other
things, Respondent argued that “[P]etitioner’s contemporaneous medical records do not
support a finding that her left shoulder pain began within 48 hours of vaccination.” Id. at
7.
In a Scheduling Order filed on August 12, 2021, I expressed the tentative view that
based on review of the existing record, a hearing would not be necessary, and that I could
instead issue a fact finding as to the onset of Petitioner’s injury based on the record. ECF
No. 33. Petitioner thereafter filed a brief on September 15, 2021, contending that she had
met her burden of proof for a Table SIRVA. ECF No. 34 (“Motion”). On October 15, 2021,
Respondent opposed entitlement, maintaining the position that this case should be
dismissed. ECF No. 35 (“Response”). This matter is now ripe for resolution.
II. Issue
At issue is whether the onset of Petitioner’s left shoulder pain occurred within 48-
hours after vaccination, as set forth in the Vaccine Injury Table for a SIRVA injury after
receipt of the flu vaccine. 42 C.F.R. § 100.3(a) XIV.B. (2017) (influenza vaccination). The
Table’s “Qualifications and Aids to Interpretation” (“QAI”) for a SIRVA-based claim also
require that a petitioner’s pain have occurred within this same 48-hour time frame. 42
C.F.R. § 100.3(c)(10).
III. Authority
Pursuant to Vaccine Act Section 13(a)(1)(A), a petitioner must prove, by a
preponderance of the evidence, the matters required in the petition by Vaccine Act
Section 11(c)(1). I have discussed the factors to be considered in determining whether a
petitioner has met their burden in several recent decisions. I fully adopt and hereby
incorporate my prior discussion in section III of the following decisions: Marrow v. Sec’y
of Health & Hum. Servs., No. 17-1964V, 2020 WL 3639775 (Fed. Cl. Spec. Mstr. June 2,
2020); Robinson v. Sec’y of Health & Hum. Servs., No. 17-1050V, 2020 WL 3729432
2

Case 1:19-vv-01031-UNJ Document 38 Filed 10/17/22 Page 3 of 6
(Fed. Cl. Spec. Mstr. June 5, 2020); Decoursey v. Sec’y of Health & Hum. Servs., No.18-
870V, 2020 WL 4673228 (Fed. Cl. Spec. Mstr. July 9, 2020).
In sum, a special master must consider, but is not bound by, any diagnosis,
conclusion, judgment, test result, report, or summary concerning the nature, causation,
and aggravation of the petitioner’s injury or illness that is contained in a medical record.
Section 13(b)(1). Moreover, a special master may find that the first symptom or
manifestation of onset of an injury occurred “within the time period described in the
Vaccine Injury Table even though the occurrence of such symptom or manifestation was
not recorded or was incorrectly recorded as having occurred outside such period.” Section
13(b)(2). “Such a finding may be made only upon demonstration by a preponderance of
the evidence that the onset [of the injury] . . . did in fact occur within the time period
described in the Vaccine Injury Table.” Id.
IV. Finding of Fact
I make the following finding regarding onset after a complete review of the record
to include Petitioner’s affidavit, all medical records, Respondent’s Rule 4 report, and
briefing by the parties. Specifically, I base the findings on the following evidence:
• Petitioner received the flu vaccine on September 12, 2017. Ex. 1 at 117-118; Ex.
3. It was administered in her left deltoid by Dr. Lauren Kay Rabin Blair, Petitioner’s
obstetrician-gynecologist. Ex. 1 at 118.
• Petitioner presented to Dr. Blair approximately two weeks later - on September
27, 2017 - for an endometrial biopsy. Ex. 1 at 133-135. There is no indication that
Petitioner complained of left shoulder pain during this appointment.
• In her affidavit, signed on July 1, 2019, Petitioner avers that she experienced
immediate pain after receiving the vaccine at issue. Ex. 2 at 1. Petitioner further
avers that she “asked about the soreness in my shoulder” during her September
27th appointment with Dr. Blair, but was told to consult with her primary care
provider if her symptoms continued for longer than 30 days. Id.
• On November 17, 2017 (now 66 days post-vaccination), Petitioner sent an email
to her primary care provider (“PCP”), Dr. Oluwakemi Abosede Ajide, concerning
left shoulder pain. Ex. 1 at 147. Petitioner explained that she received a flu shot
on September 12, 2017, and that although she had been “waiting for the soreness
to go away . . . it’s only gotten worse.” Id.
• Petitioner presented to Dr. Ajide on December 14, 2017, concerning left shoulder
pain and limited range of motion. Ex. 1 at 155-157. Petitioner reported that she
3

Case 1:19-vv-01031-UNJ Document 38 Filed 10/17/22 Page 4 of 6
continued to have soreness at the injection site of her September 12, 2017 flu
shot. Id. at 156.
• Petitioner attended her first physical therapy appointment on December 14, 2017.
Ex. 1 at 164-169. The note documenting this appointment indicates that Petitioner
started having lateral pain “after a flu shot that began weeks ago.” Id. at 166.
• On January 9, 2018, Petitioner presented to orthopedist Dr. Gurminder Singh
Ahuja, MD. Ex. 1 at 192. Dr. Ahuja noted that Petitioner “[m]entions to me that
after she received her [f]lu shot in September, [she] started having lateral shoulder
pain.” Id. at 193.
• In a January 30, 2018 email to Dr. Ajide, Petitioner reported that “[b]efore I got this
vaccination of the flu shot I have [sic] free range of motion [and] no pain in my
shoulder . . . then after the flu shot[,] I begin [sic] having problems moving my
shoulder almost immediately [.]” Ex. 1 at 205.
• Petitioner presented to Dr. Melissa Sinkiewicz on February 1, 2018, concerning
her left shoulder pain. Ex. 1 at 223-227. The note documenting this visit indicates
that Petitioner’s symptoms “began in Sept 2017 after getting her flu vaccination
and she feels like it has become worse over time.” Id. at 224.
Overall, although the evidence offered in support of Petitioner’s onset allegation is
not extensive, I find that the totality of the record supports the conclusion that Petitioner’s
shoulder pain most likely began within 48 hours of receiving the September 12, 2017 flu
vaccine. While Petitioner’s medical records do not reflect a precise date of onset and
include vague temporal references (e.g., “after the flu shot. . .” (emphasis added)), on at
least two occasions during the fall of 2017 she reported that her pain had begun in
September 2017. See, e.g., Ex. 1 at 193, 224. Moreover, in one instance, Petitioner
described “having problems moving my shoulder almost immediately” after the flu shot.
Ex. 1 at 205. This history is further supported by Petitioner’s own declaration which
describes the onset of her condition in greater detail.
Admittedly, there is evidence of an intervening gynecological appointment with Dr.
Blair (occurring only fifteen days post-vaccination) at which time Petitioner made no
mention of her shoulder injury or its purported onset. Ex. 1 at 133-135. Although Petitioner
attests that she did mention her shoulder pain at this visit, the record itself is silent on the
issue. Respondent acknowledges that it is not always reasonable to assume that a
claimant would report - and that a physician would document - all of a patient’s concerns.
Response at 6. But Respondent nevertheless contends that “it is reasonable that when
[Petitioner] returned for treatment from her OB-Gyn fifteen days [after receiving the flu
shot], [P]etitioner would mention, and that her provider would note, any ailments
4

Case 1:19-vv-01031-UNJ Document 38 Filed 10/17/22 Page 5 of 6
stemming from a vaccine that was administered by that provider a few days earlier.”
Response at 6-7 (citing Ex. 1 at 133-35).
This assertion has some persuasive force. But a single intervening medical
encounter is not enough to disprove onset, especially given the consistent assertions
about close-in-time onset at all subsequent medical encounters. And although it is
reasonable to expect a person suffering from a recent shoulder injury to raise the matter
at a general physical exam, a medical visit with a specialized purpose is different (and
indeed – in this case, Petitioner has persuasively explained that her Ob-Gyn expressly
directed her to raise the issue with her PCP at a later date).
In addition, the time gap from alleged onset to efforts at treatment - a 66-day delay
– is not of sufficient magnitude to call into question Petitioner’s onset allegations.
Petitioner’s medical records and affidavits reflect a pattern similar to other SIRVA claims,
in which injured parties reasonably delay treatment, often based on the assumption that
their pain is likely transitory. See, e.g., Tenneson v. Sec’y of Health & Human Servs., No.
16-1664V, 2018 WL 3083140, at *5 (Fed. Cl. Spec. Mstr. Mar. 30, 2018), mot. for rev.
denied, 142 Fed. Cl. 329 (2019) (finding a 48-hour onset of shoulder pain despite a nearly
six-month delay in seeking treatment); Williams v. Sec’y of Health & Human Servs., No.
17-830V, 2019 WL 1040410, at *9 (Fed. Cl. Spec. Mstr. Jan. 31, 2019) (noting a delay in
seeking treatment for five-and-a-half months because petitioner underestimated the
severity of her shoulder injury); Knauss v. Sec’y of Health & Human Servs., 16-1372V,
2018 WL 3432906 (Fed. Cl. Spec. Mstr. May 23, 2018) (noting a three-month delay in
seeking treatment). And Petitioner clearly began complaining “on the record” of shoulder
pain within two and a half months of vaccination, consistently thereafter relating onset to
the vaccination. The overall weight of the evidence is sufficiently supportive of her onset
allegations to find in her favor.
Accordingly, I find there is preponderant evidence to establish that the onset
Petitioner’s left shoulder pain occurred within 48 hours of the September 12, 2017 flu
vaccination.
V. Scheduling Order
Given my finding of fact regarding onset – and specifically that it is consistent with
the Table requirements of a SIRVA claim – Respondent shall evaluate and provide his
current position regarding the merits of Petitioner’s case.
Respondent shall file, by no later than Wednesday, October 12, 2022, a status
report indicating whether he intends to defend this matter in any regard other than onset.
5

Case 1:19-vv-01031-UNJ Document 38 Filed 10/17/22 Page 6 of 6
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
6

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DOCUMENT 2: USCOURTS-cofc-1_19-vv-01031-1
Date issued/filed: 2023-01-23
Pages: 2
Docket text: PUBLIC ORDER/RULING (Originally filed: 12/23/2022) regarding 43 Ruling on Entitlement. Signed by Chief Special Master Brian H. Corcoran. (kle) Service on parties made.
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Case 1:19-vv-01031-UNJ Document 49 Filed 01/23/23 Page 1 of 2
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 19-1031V
UNPUBLISHED
BILINDA ANDERSON, Chief Special Master Corcoran
Petitioner, Filed: December 23, 2022
v.
Special Processing Unit (SPU);
SECRETARY OF HEALTH AND Ruling on Entitlement; Concession;
HUMAN SERVICES, Table Injury; Influenza (Flu) Vaccine;
Shoulder Injury Related to Vaccine
Respondent. Administration (SIRVA)
Maximillian J. Muller, Muller Brazil, LLP, Dresher, PA, for Petitioner.
Alexa Roggenkamp, U.S. Department of Justice, Washington, DC, for Respondent.
RULING ON ENTITLEMENT1
On July 17, 2019, Bilinda Anderson 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 she suffered a shoulder injury related to vaccine
administration (“SIRVA”) as a result of an influenza (“flu”) vaccine administered on
September 12, 2017. Petition at 1. The case was assigned to the Special Processing
Unit of the Office of Special Masters.
On September 13, 2022, I issued Findings of Fact in which I determined that the
Petitioner provided preponderant evidence to establish that the onset of her left shoulder
pain occurred within 48 hours of vaccination. ECF No. 36 at 5. In reaction, on November
10, 2022, Respondent filed an Amended Rule 4(c) Report stating that (while preserving
1 Because this unpublished Ruling contains a reasoned explanation for the action in this case, I am 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). 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, 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 (2012).

Case 1:19-vv-01031-UNJ Document 49 Filed 01/23/23 Page 2 of 2
his right to appeal the September 13, 2022 Fact Finding) he agrees that “petitioner has
otherwise satisfied the criteria set forth in the Vaccine Injury Table and the Qualifications
and Aids to Interpretation (“QAI”) for Shoulder Injury Related to Vaccine Administration
(“SIRVA”).” Respondent’s Rule 4(c) Report at 2 (citing 42 C.F.R. §§ 100.3(a)(XIV) and
(c)(10)).
Specifically, Respondent stated as follows:
In light of the Chief Special Master’s fact ruling, and medical record evidence
submitted in this case, [the Secretary] has concluded that petitioner suffered
SIRVA as defined by the Vaccine Injury Table . . . Therefore, based on the record
as it now stands and subject to his right to appeal the Findings of Fact, respondent
does not dispute that petitioner has satisfied all legal prerequisites for
compensation under the Act.”
Id. at 7.
In view of Respondent’s position and the evidence of record, I find that
Petitioner is entitled to compensation.
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
2

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DOCUMENT 3: USCOURTS-cofc-1_19-vv-01031-2
Date issued/filed: 2023-01-30
Pages: 5
Docket text: PUBLIC DECISION (Originally filed: 12/29/2022) regarding 45 DECISION Stipulation/Proffer. Signed by Chief Special Master Brian H. Corcoran. (kle) Service on parties made.
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Case 1:19-vv-01031-UNJ Document 50 Filed 01/30/23 Page 1 of 5
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 19-1031V
UNPUBLISHED
BILINDA ANDERSON, Chief Special Master Corcoran
Petitioner, Filed: December 29, 2022
v.
Special Processing Unit (SPU);
SECRETARY OF HEALTH AND Damages Decision Based on Proffer;
HUMAN SERVICES, Influenza (Flu) Vaccine; Shoulder
Injury Related to Vaccine
Respondent. Administration (SIRVA)
Maximillian J. Muller, Muller Brazil, LLP, Dresher, PA, for Petitioner.
Alexa Roggenkamp, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION AWARDING DAMAGES1
On July 17, 2019, Bilinda Anderson 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 she suffered a shoulder injury related to vaccine
administration (“SIRVA”) as a result of an influenza (“flu”) vaccine administered on
September 12, 2017. Petition at 1. The case was assigned to the Special Processing Unit
of the Office of Special Masters.
On December 23, 2022, a ruling on entitlement was issued, finding Petitioner
entitled to compensation for SIRVA. On December 28, 2022, Respondent filed a proffer
on award of compensation (“Proffer”) indicating Petitioner should be awarded (a) a lump
sum payment of $65,000.00, representing compensation for actual pain and suffering;
and (b) a lump sum payment of $6,383.00, representing compensation for satisfaction of
1 Because this unpublished Decision contains a reasoned explanation for the action in this case, I am
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). 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 (2012).

Case 1:19-vv-01031-UNJ Document 50 Filed 01/30/23 Page 2 of 5
the State of Maryland Medicaid lien. Proffer at 1-2. In the Proffer, Respondent
represented that Petitioner agrees with the proffered award. Id. Based on the record as a
whole, I find that Petitioner is entitled to an award as stated in the Proffer.
Pursuant to the terms stated in the attached Proffer, I award Petitioner:
A. A lump sum payment of $65,000.00 in the form of a check payable to
Petitioner; and
B. A lump sum payment of $6,383.00, representing compensation for
satisfaction of the State of Maryland Medicaid lien, payable jointly to
Petitioner and
The Rawlings Company
ATTN: Bethany Gardner
Reference No. 115353396
P.O. Box 2000
La Grange, KY 40031-2000
Petitioner agrees to endorse this payment to the Rawlings Company for
satisfaction of the Medicaid lien.
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-01031-UNJ Document 50 Filed 01/30/23 Page 3 of 5
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
BILINDA ANDERSON,
Petitioner, No. 19-1031V
Chief Special Master Corcoran
v. ECF
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
RESPONDENT’S PROFFER ON AWARD OF COMPENSATION
On July 17, 2019, Bilinda Anderson (“petitioner”) filed a petition for compensation
(“Petition”) under the National Childhood Vaccine Injury Act of 1986, 42 U.S.C. §§ 300aa-1 to
-34 (“Vaccine Act” or “Act”), alleging that she suffered a shoulder injury related to vaccine
administration (“SIRVA”) in her left shoulder as a result of an influenza (“flu”) vaccine
administered on September 12, 2017. Petition at 1. On December 23, 2022, the Chief Special
Master issued a Ruling on Entitlement finding petitioner entitled to compensation. ECF No. 43.
I. Items of Compensation
A. Pain and Suffering
Respondent proffers that Bilinda Anderson should be awarded $65,000.00 in actual pain
and suffering. See 42 U.S.C. § 300aa-15(a)(4). Petitioner agrees.
B. Medicaid Lien
Respondent proffers that petitioner should be awarded funds to satisfy a State of
Maryland Medicaid lien in the amount of $6,383.00, which represents full satisfaction of any
right of subrogation, assignment, claim, lien, or cause of action the State of Maryland may have

Case 1:19-vv-01031-UNJ Document 50 Filed 01/30/23 Page 4 of 5
against any individual as a result of any Medicaid payments the State of Maryland has made to
or on behalf of petitioner from the date of her eligibility for benefits through the date of
judgment in this case as a result of his alleged vaccine-related injury suffered on or about
September 12, 2017, under Title XIX of the Social Security Act.
The above amounts represent 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
Petitioner is a competent adult. Evidence of guardianship is not required in this case.
Respondent recommends that the compensation provided to petitioner be made through two
lump sum payments as described below:
1) A lump sum payment of $65,000.00 in the form of a check payable to petitioner.1
2) A lump sum payment of $6,383.00, representing compensation for satisfaction of
the State of Maryland Medicaid lien, payable jointly to petitioner and to:
The Rawlings Company
ATTN: Bethany Gardner
Reference No. 115353396
P.O. Box 2000
La Grange, KY 40031-2000
Petitioner agrees to endorse this payment to The Rawlings Company for satisfaction of
the Medicaid lien.
Respectfully submitted,
BRIAN M. BOYNTON
Principal Deputy Assistant Attorney General
C. SALVATORE D’ALESSIO
Director
Torts Branch, Civil Division
1 Should petitioner 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 lost earnings
and future pain and suffering.
2

Case 1:19-vv-01031-UNJ Document 50 Filed 01/30/23 Page 5 of 5
HEATHER L. PEARLMAN
Deputy Director
Torts Branch, Civil Division
DARRYL R. WISHARD
Assistant Director
Torts Branch, Civil Division
/s/ Alexa Roggenkamp
ALEXA ROGGENKAMP
Trial Attorney
Torts Branch, Civil Division
U.S. Department of Justice
P.O. Box 146
Benjamin Franklin Station
Washington, D.C. 20044-0146
(202) 616-4179
alexa.roggenkamp@usdoj.gov
DATED: December 28, 2022
3