VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_20-vv-00958
Package ID: USCOURTS-cofc-1_20-vv-00958
Petitioner: Crystal Cervantez-Tkac
Filed: 2022-02-15
Decided: 2022-03-18
Vaccine: influenza
Vaccination date: 2018-12-20
Condition: shoulder injury related to vaccine administration (SIRVA)
Outcome: compensated
Award amount USD: 32995

AI-assisted case summary:
Crystal Cervantez-Tkac filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered a shoulder injury related to vaccine administration (SIRVA) caused by an influenza vaccine she received on December 20, 2018. The respondent, the Secretary of Health and Human Services, denied that the petitioner sustained a SIRVA Table injury or that the vaccine caused her alleged shoulder injury. Despite these denials, the parties filed a joint stipulation agreeing that a decision should be entered awarding compensation. The court adopted the stipulation as its decision, awarding Crystal Cervantez-Tkac $32,995.88. This amount includes a lump sum payment of $32,500.00 to the petitioner and $495.88 to reimburse a Medicaid lien for services rendered by the State of Colorado. The award represents compensation for all damages available under the Vaccine Act. The stipulation also addresses future proceedings for attorneys' fees and costs.

Theory of causation field:
Table

Public staged source text:

================================================================================
DOCUMENT 1: USCOURTS-cofc-1_20-vv-00958-0
Date issued/filed: 2021-09-16
Pages: 5
Docket text: PUBLIC ORDER/RULING (Originally filed: 08/16/2021) regarding 28 Findings of Fact & Conclusions of Law,, Scheduling Order, Signed by Chief Special Master Brian H. Corcoran. (sw) Service on parties made.
--------------------------------------------------------------------------------
Case 1:20-vv-00958-UNJ Document 31 Filed 09/16/21 Page 1 of 5
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 20-0958V
UNPUBLISHED
CRYSTAL CERVANTEZ-TKAC, Chief Special Master Corcoran
Petitioner, Filed: August 16, 2021
v.
Special Processing Unit (SPU);
SECRETARY OF HEALTH AND Findings of Fact; Site of Vaccination
HUMAN SERVICES, Influenza (Flu) Vaccine; Shoulder
Injury Related to Vaccine
Respondent. Administration (SIRVA)
Maximillian J. Muller, Muller Brazil, LLP, Dresher, PA, for Petitioner.
Lynn Christina Schlie, U.S. Department of Justice, Washington, DC, for Respondent.
FINDINGS OF FACT1
On August 3, 2020, Crystal Cervantez-Tkac 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 left shoulder injury related to vaccine
administration (“SIRVA”), a defined Table injury, after receiving an influenza (“flu”)
vaccine on December 20, 2018. Petition at 1, ¶¶ 2, 8. 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 1:20-vv-00958-UNJ Document 31 Filed 09/16/21 Page 2 of 5
For the reasons discussed below, I find the flu vaccine was most likely
administered in Petitioner’s left deltoid, as alleged.
I. Relevant Procedural History
Along with the Petition, Ms. Cervantez-Tkac filed the affidavit and most of the
medical records required under the Vaccine Act. Exhibits 1-2, 4-6, ECF No. 1; see Section
11 (c). A few weeks later on August 17, 2020, Petitioner filed the remaining medical
records. Exhibit 3, filed by CD. On February 10, 2020, Respondent filed a status report
indicating additional vaccine documentation, providing information such as the site of
vaccination was needed. ECF No. 13. He also requested updated medical records. Id.
Over the subsequent month, Petitioner filed updated medical records and
additional vaccine documentation providing some of the information requested. Exhibits
7-10, ECF Nos. 14-15. The additional vaccine documentation provided some of the
information sought by Respondent, such as the vaccine’s lot number, but still did not
indicate the arm in which the vaccine was administered. Exhibit 10 at 2.
The initial status conference, previously delayed, was held on May 4, 2021. The
parties indicated at this time that additional vaccine documentation, such as the consent
form, would be helpful. ECF No. 18. Respondent estimated that the HHS review would
be completed within three months. Id.
Over the subsequent three-month period, Petitioner filed three motions for
subpoena authority – all which were granted. ECF Nos. 19-23, 25. On August 9, 2021,
Petitioner filed the documentation obtained in response to the most recent subpoena
served, which still did not indicate the site of vaccination. Exhibit 11.
After informing the parties that I intended to issue a ruling regarding this factual
issue, Respondent noted that he did not wish to file any additional briefing on the matter.
See Informal Remark, dated Aug. 11, 2021. The issue is now ripe for adjudication.
II. Issue
At issue is whether Petitioner received the December 20, 2018 vaccine in her left
deltoid, as alleged.
2

Case 1:20-vv-00958-UNJ Document 31 Filed 09/16/21 Page 3 of 5
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). 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 petitioner’s injury or illness that is contained in a medical record.
Section 13(b)(1). “Medical records, in general, warrant consideration as trustworthy
evidence. The records contain information supplied to or by health professionals to
facilitate diagnosis and treatment of medical conditions. With proper treatment hanging in
the balance, accuracy has an extra premium. These records are also generally
contemporaneous to the medical events.” Cucuras v. Sec’y of Health & Human Servs.,
993 F.2d 1525, 1528 (Fed. Cir. 1993).
Accordingly, where medical records are clear, consistent, and complete, they
should be afforded substantial weight. Lowrie v. Sec’y of Health & Human Servs., No. 03-
1585V, 2005 WL 6117475, at *20 (Fed. Cl. Spec. Mstr. Dec. 12, 2005). However, this rule
does not always apply. In Lowrie, the special master wrote that “written records which
are, themselves, inconsistent, should be accorded less deference than those which are
internally consistent.” Lowrie, 2005 WL 6117475, at *19.
The United States Court of Federal Claims has recognized that “medical records
may be incomplete or inaccurate.” Camery v. Sec’y of Health & Human Servs., 42 Fed.
Cl. 381, 391 (1998). The Court later outlined four possible explanations for
inconsistencies between contemporaneously created medical records and later
testimony: (1) a person’s failure to recount to the medical professional everything that
happened during the relevant time period; (2) the medical professional’s failure to
document everything reported to her or him; (3) a person’s faulty recollection of the events
when presenting testimony; or (4) a person’s purposeful recounting of symptoms that did
not exist. La Londe v. Sec’y of Health & Human Servs., 110 Fed. Cl. 184, 203-04 (2013),
aff’d, 746 F.3d 1335 (Fed. Cir. 2014).
The Court has also said that medical records may be outweighed by testimony that
is given later in time that is “consistent, clear, cogent, and compelling.” Camery, 42 Fed.
Cl. at 391 (citing Blutstein v. Sec’y of Health & Human Servs., No. 90-2808, 1998 WL
408611, at *5 (Fed. Cl. Spec. Mstr. June 30, 1998). The credibility of the individual offering
such testimony must also be determined. Andreu v. Sec’y of Health & Human Servs., 569
F.3d 1367, 1379 (Fed. Cir. 2009); Bradley v. Sec’y of Health & Human Servs., 991 F.2d
1570, 1575 (Fed. Cir. 1993).
3

Case 1:20-vv-00958-UNJ Document 31 Filed 09/16/21 Page 4 of 5
The special master is obligated to fully consider and compare the medical records,
testimony, and all other “relevant and reliable evidence contained in the record.” La
Londe, 110 Fed. Cl. at 204 (citing Section 12(d)(3); Vaccine Rule 8); see also Burns v.
Sec’y of Health & Human Servs., 3 F.3d 415, 417 (Fed. Cir. 1993) (holding that it is within
the special master’s discretion to determine whether to afford greater weight to medical
records or to other evidence, such as oral testimony surrounding the events in question
that was given at a later date, provided that such determination is rational).
IV. Finding of Fact
I make the following finding regarding site of vaccination after a complete review
of the record, including medical records, affidavits, and other additional evidence filed
showing:
• All three vaccines records which were filed indicate Petitioner received the
flu vaccine intramuscularly, but do not indicate the arm in which the vaccine
was administered. Exhibit 1 at 8; Exhibit 10 at 1-2; Exhibit 11 at 3-5.
• In her declaration, Petitioner alleges that she the flu vaccine in her left
shoulder. Exhibit 2 at ¶ 2.
• On February 14, 2019, approximately two months post-vaccination,
Petitioner returned to the clinic where she received the vaccination,
complaining of “arm pain from the site of vaccination.” Exhibit 3 at 47.
• Four months later, she visited CHPG Primary Care Porter to establish care.
Exhibit 5 at 16. She complained of right foot pain, diagnosed as plantar
fasciitis, and acute left shoulder pain which started after immunization. Id.
Petitioner reported that “[s]he had a flu shot in December . . . [which] was
given higher in her left shoulder than normal.” Id. at 18. While reporting that
her pain was improving, she described daily pain and difficulty sleeping. Id.
• On July 17, 2019, Petitioner was evaluated for physical therapy. Exhibit 6
at 115. She reported “that she had a flu shot in December which was very
painful.” Id.
The above medical entries show that, when seeking treatment for her left shoulder
pain, Petitioner consistently attributed her pain to the flu vaccine she reported receiving
in her left arm. She provided these histories to the clinic where she received the vaccine,
to her new primary care provider, and to the physical therapist soon after vaccination,
4

Case 1:20-vv-00958-UNJ Document 31 Filed 09/16/21 Page 5 of 5
when seeking treatment of her left shoulder pain during the seven months following
vaccination. While originating from Petitioner, these statements are set forth in
contemporaneous records, and should therefore be afforded greater weight than any
subsequent assertion or witness statement. The Federal Circuit has stated that “[m]edical
records, in general, warrant consideration as trustworthy evidence . . . [as they] contain
information supplied to or by health professionals to facilitate diagnosis and treatment of
medical conditions.” Cucuras, 993 F.2d at 1528 (emphasis added). Thus, the Circuit has
instructed that greater weight should be accorded to this class of information, even when
the record in question simply memorializes what the petitioner said at the time.
The vaccine record clearly establishes that, on December 20, 2018, Petitioner
received a flu vaccine which was administered intramuscularly. Thereafter, when seeking
medical care for her left shoulder pain, Petitioner consistently attributed the source of her
pain to the flu vaccine she described as improperly administered in her left deltoid. There
is a dearth of evidence that the vaccine was administered in any other location. I thus
determine, based on the record as a whole, that preponderant evidence establishes that
the flu vaccine to which Petitioner attributes her SIRVA was most likely administered in
her left deltoid on December 20, 2018.
V. Scheduling Order
Based on recent data, I expect the HHS review to be completed in this case in
September 2021. Although not clear whether Petitioner’s injury meets all criteria for a
Table SIRVA, given my finding of fact with regard to the site of vaccination, it appropriate
for Petitioner to forward a demand and supporting documentation to Respondent prior to
the HHS review. And I previously instructed Petitioner to begin finalizing her demand,
which appears to involve an amount needed to satisfy a Medicaid lien, in early May 2021.
ECF No. 18. While awaiting the HHS review, Petitioner should continue to work on
finalizing her demand.
Respondent shall file a status report indicating how he intends to proceed
by no later than Thursday, September 16, 2021.
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
5

================================================================================
DOCUMENT 2: USCOURTS-cofc-1_20-vv-00958-1
Date issued/filed: 2022-03-18
Pages: 8
Docket text: PUBLIC DECISION (Originally filed: 02/15/2022) regarding 39 DECISION Stipulation/Proffer Signed by Chief Special Master Brian H. Corcoran. (sw) Service on parties made.
--------------------------------------------------------------------------------
Case 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 1 of 8
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 20-0958V
UNPUBLISHED
CRYSTAL CERVANTEZ-TKAC, Chief Special Master Corcoran
Petitioner, Filed: February 15, 2022
v.
Special Processing Unit (SPU); Joint
SECRETARY OF HEALTH AND Stipulation on Damages; Influenza
HUMAN SERVICES, (Flu) Vaccine; Shoulder Injury
Related to Vaccine Administration
Respondent. (SIRVA)
Maximillian J. Muller, Muller Brazil, LLP, Dresher, PA, for Petitioner.
Emily H. Manoso, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION ON JOINT STIPULATION1
On August 3, 2020, Crystal Cervantez-Tkac 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”), a defined Table Injury, caused-in-fact by the influenza (“flu”)
vaccine she received on December 20, 2018. Petition at 1, ¶¶ 2, 8; Stipulation, filed at
Feb. 15, 2021, ¶¶ 1-2, 4. Petitioner further alleges that she received the vaccination in
the United States, that she suffered the residual effects of her SIRVA more than six-
months post-vaccination, and that neither she nor any other party has filed a civil action
or received compensation for her SIRVA. Petition at ¶¶ 2, 6, 9-10; Stipulation at ¶¶ 3-5.
“Respondent denies that [P]etitioner sustained a SIRVA Table injury; denies that the flu
vaccine caused her alleged shoulder injury or any other injury or condition; and denies
that her current condition is a sequelae of a vaccine-related injury.” Stipulation at ¶ 6.
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 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 2 of 8
Nevertheless, on February 15, 2022, the parties filed the attached joint stipulation,
stating that a decision should be entered awarding compensation. I find the stipulation
reasonable and adopt it as my decision awarding damages, on the terms set forth therein.
Pursuant to the terms stated in the attached Stipulation, I award $32,995.88 as
follows:
1. A lump sum payment of $32,500.00 in the form of a check payable to
Petitioner; and
2. A lump sum payment of $495.88, representing reimbursement of a Medicaid
lien for services rendered to Petitioner by the State of Colorado, in the form
of a check payable jointly to Petitioner and the Colorado Department of
Health Care Policy and Financing, and mailed to:
Colorado Department of Health Care Policy and Financing
333 W. Hampden Avenue, Suite #425
Englewood, CO 80110
Case # 215078.
Stipulation at ¶ 8. Petitioner agrees to endorse the check to the Colorado Department of
Health Care Policy and Financing for satisfaction of the Medicaid lien. This amount
represents compensation for all items of damages that would be available under Section
15(a). Id.
I approve the requested amount for Petitioner’s compensation. In the absence of
a motion for review filed pursuant to RCFC Appendix B, 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 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 3 of 8
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
*************************************
CRYSTAL CERVA NTEZ-TKAC, *
*
Petitioner, * No. 20-958V
* Chief Special Master Corcoran
v. *
*
SECRETARY OF HEALTH AND *
HUMAN SERVICES, *
*
Respondent. *
*************************************
STIPULATION
The parties hereby stipulate to the following matters:
1. Crystal Cervantez-Tkac ("petitioner") filed a petition for vaccine compensation
under the National Vaccine Injury Compensation Program, 42 U.S.C. § 300aa-10 to 34 (the
"Vaccine Program"). The petition seeks compensation for injuries allegedly related to
petitioner's receipt of an influenza ("flu") vaccine, which vaccine is contained in the Vaccine
Injury Table (the "Table"), 42 C.F.R. § 100.3 (a).
2. Petitioner received a flu immunization on December 20, 2018.
3. The vaccine was administered within the United States.
4. Petitioner alleges that she sustained a shoulder injury related to vaccine
administration ("SIRVA") within the time period set forth in the Table. She further alleges that
she has experienced residual effects of her alleged injury for more than six months.
5. Petitioner represents that there has been no prior award or settlement of a civil
action for damages on her behalf as a result of her condition.

Case 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 4 of 8
6. Respondent denies that petitioner sustained a SIRVA Table injury; denies that the
flu vaccine caused her alleged shoulder injury or any other injury or condition; and denies that
her current condition is a sequelae of a vaccine-related injury.
7. Maintaining their above-stated positions, the parties nevertheless now agree that
the issues between them shall be settled and that a decision should be entered awarding the
compensation described in paragraph 8 of this Stipulation.
8. As soon as practicable after an entry of judgment reflecting a decision consistent
with the terms of this Stipulation, and after petitioner has filed an election to receive
compensation pursuant to 42 U.S.C. § 300aa-21(a)(l), the Secretary of Health and Human
Services will issue the following vaccine compensation payments:
A. A lump sum of $32,500.00 in the form of a check payable to petitioner; and
B. A lump sum of $495.88, 1 representing reimbursement of a Medicaid lien for
services rendered to petitioner by the State of Colorado, in the form of a check
payable jointly to petitioner and the Colorado Department of Health Care Policy
and Financing:
Colorado Department of Health Care Policy and Financing
333 W. Hampden Avenue, Suite #425
Englewood, CO 80110
Case# 215078
Petitioner agrees to endorse this check to the Colorado Department of Health Care
Policy and Financing.
These amounts represent compensation for all damages that would be available under 42 U.S.C.
§ 300aa-15(a).
1 This amount represents full satisfaction of any right of subrogation, assignment, claim, lien, or
cause of action the State of Colorado may have against any individual as a result of any
Medicaid payments the Colorado Program has made to or on behalf of Crystal Cervantez-Tkac
as a result of her alleged vaccine-related injury suffered on or about December 20, 2018, under
Title XIX of the Social Security Act, see 42 U.S.C. § 300aa-15(g), (h).
2

Case 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 5 of 8
9. As soon as practicable after the entry of judgment on entitlement in this case, and
after petitioner has filed both a proper and timely election to receive compensation pursuant to
42 U.S.C. § 300aa-2l(a)(l), and an application, the parties will submit to further proceedings
before the special master to award reasonable attorneys' fees and costs incurred in proceeding
upon this petition.
10. Petitioner and her attorney represent that compensation to be provided pursuant to
this Stipulation is not for any items or services for which the Program is not primarily liable
under 42 U.S.C. § 300aa- 15(g), to the extent that payment has been made or can reasonably be
expected to be made under any State compensation programs, insurance policies, Federal or
State health benefits programs (other than Title XIX of the Social Security Act (42 U.S.C.
§ 1396 et seq.)), or by entities that provide health services on a pre-paid basis.
11. Payments made pursuant to paragraph 8 and any amounts awarded pursuant to
paragraph 9 of this Stipulation will be made in accordance with 42 U.S.C. § 300aa-15(i), subject
to the availability of sufficient statutory funds.
12. The parties and their attorneys further agree and stipulate that, except for any
award for attorneys' fees, and litigation costs, and past unreimbursable expenses, the money
provided pursuant to this Stipulation will be used solely for the benefit of petitioner as
contemplated by a strict construction of 42 U.S.C. § 300aa-15(a) and (d), and subject to the
conditions of 42 U .S.C. § 300aa-l 5(g) and (h).
13. In return for the payments described in paragraphs 8 and 9, petitioner, in her
individual capacity and on behalf of her heirs, executors, administrators, successors or assigns,
does forever irrevocably and unconditionally release, acquit and discharge the United States and
the Secretary of Health and Human Services from any and all actions or causes of action
3

Case 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 6 of 8
(including agreements, judgments, claims, damages, loss of services, expenses and all demands
of whatever kind or nature) that have been brought, could have been brought, or could be timely
brought in the Court of Federal Claims, under the National Vaccine Injury Compensation
Program, 42 U.S.C. § 300aa-10 et seq., on account of, or in any way growing out of, any and all
known or unknown, suspected or unsuspected personal injuries to or death of petitioner resulting
from, or alleged to have resulted from a flu vaccination administered on December 20, 2018, as
alleged by petitioner in a petition for vaccine compensation filed on or about August 3, 2020, in
the United States Court of Federal Claims as petition No. 20-0958V.
14. If petitioner should die prior to entry of judgment, this agreement shall be
voidable upon proper notice to the Court on behalf of either or both of the parties.
15. If the special master fails to issue a decision in complete conformity with the
terms of this Stipulation or if the Court of Federal Claims fails to enter judgment in conformity
with a decision that is in complete conformity with the terms of this Stipulation, then the parties'
settlement and this Stipulation shall be voidable at the sole discretion of either party.
16. This Stipulation expresses a full and complete negotiated settlement of liability
and damages claimed under the National Childhood Vaccine Injury Act of 1986, as amended,
except as otherwise noted in paragraph 9 above. There is absolutely no agreement on the part of
the parties hereto to make any payment or to do any act or thing other than is herein expressly
stated and clearly agreed to. The parties further agree and understand that the award described in
this Stipulation may reflect a compromise of the parties' respective positions as to liability and/or
amount of damages, and further, that a change in the nature of the injury or condition or in the
items of compensation sought, is not grounds to modify or revise this agreement.
4

Case 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 7 of 8
17. This Stipulation shall not be construed as an admission by the United States or the
Secretary of Health and Human Services that petitioner sustained a SIRVA Table injury; that the
flu vaccine caused any other injury; or that her current condition is a sequelae of a vaccine
related injury.
18. All rights and obligations of petitioner hereunder shall apply equally to
petitioner's heirs, executors, administrators, successors, and/or assigns.
END OF STIPULATION
5

Case 1:20-vv-00958-UNJ Document 43 Filed 03/18/22 Page 8 of 8
Respectfully submitted,
PETITIONER:
~
ATTORNEY OF RECORD FOR AUTHORIZED REPRESENTATIVE
PETITIONER: OF THE ATTORNEY GENERAL:
, .4-L ~ ~~cvUWZ::-----
~MULLER HEATHER L. PEARLMAN
Muller Brazil, LLP Deputy Director
715 Twinning Road, Suite 208 Torts Branch
Dresher, PA 19025 Civil Division
(215) 885-1655 U.S. Department of Justice
max@mullerbrazil.com> P.O. Box 146
Benjamin Franklin Station
Washington, DC 20044-0146
AUTHORIZED REPRESENTATIVE ATTORNEY OF RECORD FOR
OF THE SECRETA RY OF HEALTH RESPONDENT:
AND HUMAN SERVICES:
Gm·. l.__.~Na~
---··;:;aLl,~
oa/4 ~ , or/Sc-, 7?13, A/JM, #1' L fe~
CDR GEORGE REED GRIMES, MD, MAf EMILY H. MANOSO
Director, Division of Injury Trial Attorney
Compensation Programs Torts Branch
Health Systems Bureau Civil Division
Health Resources and Services U.S. Department of Justice
Administration P.O. Box 146
U.S. Department of Health Benjamin Franklin Station
and Human Services Washington, DC 20044-0146
5600 Fishers Lane, 08N 146B (202) 305-3912
Rockville, MD 20857 emily .h.manoso@usdoj.gov
02-b lwu...
Dated: S
6