VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_21-vv-00692
Package ID: USCOURTS-cofc-1_21-vv-00692
Petitioner: Linda Lykins
Filed: 2021-01-12
Decided: 2026-02-18
Vaccine: influenza
Vaccination date: 2019-09-11
Condition: shoulder injury related to vaccine administration (SIRVA)
Outcome: compensated
Award amount USD: 100819.72

AI-assisted case summary:
On January 12, 2021, Linda Lykins filed a petition seeking compensation under the Vaccine Program, alleging shoulder injury related to vaccine administration (SIRVA) after receiving influenza on September 11, 2019.

Respondent disputed whether the symptoms were limited to the vaccinated shoulder.

She had no prior left-shoulder pain despite a history of carpal tunnel syndrome and ulnar neuropathy. She initially thought the post-shot pain seemed normal, but it worsened by the next day; on October 1, 2019 she reported left shoulder pain down the arm that started two days after the flu shot, with numbness and pins-and-needles symptoms.

The damages were resolved by proffer after entitlement.

On February 18, 2026, Chief Special Master Brian H. Corcoran adopted the parties' stipulation or proffer, found the disposition reasonable on the record before the Court, and awarded $100,000.00 pain and suffering plus $819.72 unreimbursed expenses.

Petitioner was represented by Renee J. Gentry, The Law Office of Renee J. Gentry, Washington, DC.

Theory of causation field:
influenza vaccine on September 11, 2019 (exact age not stated) allegedly causing shoulder injury related to vaccine administration (SIRVA); onset 0 days/within 48 hours. COMPENSATED. Respondent disputed whether the symptoms were limited to the vaccinated shoulder. She had no prior left-shoulder pain despite a history of carpal tunnel syndrome and ulnar neuropathy. She initially thought the post-shot pain seemed normal, but it worsened by the next day; on October 1, 2019 she reported left shoulder pain down the arm that started two days after the flu shot, with numbness and pins-and-needles symptoms. Award/status: $100,000.00 pain and suffering plus $819.72 unreimbursed expenses. Chief Special Master Brian H. Corcoran; petition filed January 12, 2021; decision February 18, 2026. Attorney: Renee J. Gentry, The Law Office of Renee J. Gentry, Washington, DC. No expert causation analysis in public stipulation/proffer.

Public staged source text:

================================================================================
DOCUMENT 1: USCOURTS-cofc-1_21-vv-00692-0
Date issued/filed: 2025-11-18
Pages: 7
Docket text: PUBLIC ORDER/RULING (Originally filed: 10/14/2025 ) regarding 60 Ruling on Entitlement, Order on Motion for Ruling on the Record Signed by Chief Special Master Brian H. Corcoran. (nh) Service on parties made.
--------------------------------------------------------------------------------
Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 1 of 7
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 21-0692V
LINDA LYKINS,
Chief Special Master Corcoran
Petitioner,
v.
SECRETARY OF HEALTH AND Filed: October 14, 2025
HUMAN SERVICES,
Respondent.
Renee Ja Gentry, The Law Office of Renee J. Gentry, Washington, D.C., for Petitioner.
Camille Michelle Collett, U.S. Department of Justice, Washington, DC, for Respondent.
FINDINGS OF FACT AND RULING ON ENTITLEMENT1
On January 12, 2021, Linda Lykins 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 alleged that she suffered a shoulder injury following an influenza
vaccine she received on September 11, 2019. Petition at 1. The case was assigned to
the Special Processing Unit of the Office of Special Masters.
For the reasons set forth below, I find that Petitioner has provided preponderant
evidence that her symptoms were limited to her vaccinated shoulder, and that she has
1 Because this Ruling 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 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 (2018).

Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 2 of 7
satisfied all of the requirements of a Table SIRVA claim. Therefore, Petitioner is entitled
to compensation under the Vaccine Act.
I. Relevant Procedural History
In October, 2022, more than 18 months after the Petition was filed, the parties
began settlement discussions. See ECF No. 25. Those discussions continued until
February 2024, when they reached an impasse. See ECF No. 50. Respondent thereafter
filed his Rule 4(c) Report opposing entitlement on April 24, 2024, in which he argued that
Petitioner failed to establish that her symptoms were limited to her left shoulder. Rule 4(c)
Report at 8.
Petitioner then filed a Motion for Ruling on the Record (“Mot.”) on June 20, 2024.
ECF No. 57. Respondent filed a response (“Resp.”) on July 30, 2024 and Petitioner filed
a reply (“Repl.”) on September 24, 2024. ECF No. 34. The matter is now ripe for
adjudication.
II. Relevant Facts
Petitioner received a flu vaccine in her left shoulder on September 11, 2019. Ex. 1
at 4. Although Petitioner had a history of carpal tunnel syndrome and ulnar neuropathy,
the parties agree that she had no prior history of left shoulder pain. See Mot. at 2; Resp.
at 1. Petitioner initially experienced pain that “seemed normal,” but worsened to the point
that she contacted the administrator the following day. Ex. 7 at ¶3.
On October 1, 2019 (20 days after vaccination), Petitioner saw her primary care
provider (“PCP”) for left shoulder pain “down her arm” that “started 2 days after a flu shot.”
Ex. 2 at 6. She noted that she also had numbness and “a pins and needles sensation all
over her entire hand.” Id. On exam, she displayed tenderness in her cervical muscles,
decreased sensation in the entire left arm from shoulder to fingers, pain over her entire
shoulder, and decreased shoulder range of motion. Id. at 8. The doctor suspected cervical
radiculopathy, but noted that his “exam was limited because she [was] unable to really
move her left arm at all without pain.” Id. at 9. X-rays of Petitioner’s cervical spine revealed
muscle spasms and moderate degeneration at C5-6. Id. at 5. Petitioner was referred for
an EMG and prescribed gabapentin for pain. Id. at 9. On October 30, 2019, Petitioner had
an MRI of her cervical spine which showed cervical spondylosis and facet arthropathy,
with “disc degeneration and neural foraminal narrowing” the “most pronounced at C5-6.”
Ex. 3 at 63.
Petitioner first saw an orthopedist on November 4, 2019. Ex. 6 at 17. She reported
a normal shoulder until she had a flu shot “a few weeks ago.” Id. She had “significant pain
2

Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 3 of 7
with abduction and overhead activities, but denied any numbness, tingling, or pain
radiating from her neck. Id. Her exam revealed tenderness in the deltoid and “definite
impingement” with forward elevation and abduction. Id. at 18. The doctor found no
neurovascular deficits in the left upper extremity. Id. He opined that “more than likely the
injection which occurred penetrated [sic] the area of the deltoid and was deeper along the
area of the rotator cuff and external rotators.” Id. at 19. He administered a cortisone
injection. Id.
Petitioner began physical therapy on November 20, 2019. Ex. 4 at 2. She reported
that she “received a flu shot on 9/11/19 in the L arm – extreme pain ever since and even
lack of grip in L non-dominant hand.” Id. Petitioner noted that she had a history of
numbness in her 4th and 5th fingers due to ulnar nerve damage dating back to 1992 with
impact on her grip strength. Id. Petitioner had four sessions through November 29, 2019
when she discontinued treatment. Id. at 20.
Petitioner returned to the orthopedist on December 4, 2019 with continued left
shoulder pain. Ex. 6 at 14. She reported no relief from the injection or physical therapy.
Id. On exam, her range of motion was further restricted. Id. at 15. Surgery was scheduled.
Id. at 16. Petitioner saw her PCP on December 23, 2019 for pre-operative medical
clearance. Ex. 9 at 26. She reported that she was “fairly certain that she did experience
a post vaccination adhesive capsulitis . . . and it has only gotten worse.” Id. An x-ray of
Petitioner’s left shoulder showed “minor degenerative changes of the AC joint.” Id. at 161.
Petitioner had arthroscopic surgery on January 16, 2020. Ex. 3 at 42. Her post-
operative diagnosis was “early adhesive capsulitis with impingement, rotator cuff
tendonitis, and bursitis.” Id. At her first post-operative follow up, Petitioner reported
improving pain and range of motion. Ex. 6 at 12. She returned to physical therapy on
February 6, 2020, and completed eight sessions through March 4, 2020. Ex. 4 at 21-51.
At her last visit, Petitioner reported 65-70% improvement. Id. at 52. Petitioner’s discharge
note indicates that she stopped physical therapy due to a “plateau in progress.” Id. at 54.
She states that she continued to do “PT at home.” Mot. at 6.
Almost three years later, Petitioner returned to her PCP for treatment for her left
shoulder. Ex. 49. She reported that her pain started September 11, 2019, and that she
was “still having the pain if she raises [her] arm above [her] head” and reduced strength.
Id. The records notes that “this pain has gone on a full 3 years.” Id. On exam, Petitioner’s
left shoulder was “very tender anteriorly” and her range of motion was restricted. Id. at
52. Her doctor believed she had a rotator cuff tear, ordered an MRI, and referred her to
an orthopedist. Id. The MRI showed acromioclavicular joint degeneration and mild
supraspinatus tendinopathy without evidence of tearing.” Ex. 12 at 68-69.
3

Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 4 of 7
Petitioner returned to the orthopedist on March 14, 2023, to discuss her MRI
results. Ex. 19 at 1. She reported left shoulder pain, stiffness, and decreased strength. Id.
She noted that she had to stop physical therapy due to the Covid-19 Pandemic, but had
continued her home exercise program without relief. Id. She noted that her “symptoms
have worsened at this time.” Id. She was diagnosed with rotator cuff tendinitis, prescribed
a Medrol dosepak, and referred back to physical therapy. Id. at 3. She returned on April
25, 2023. Id. at 4. She reported improvements in range of motion with therapy,3 but
continued weakness. Id. A second surgery was recommended. Id. at 6.
Petitioner had a second arthroscopic surgery on June 2, 2023, which included a
labral tear repair. Ex. 19 at 7. During her post-operative follow-up appointments, Petitioner
was encouraged to continue physical therapy.4 See Ex. 19 at 16-17; Ex. 23 at 11-15. On
September 26, 2023, just under four months after surgery, Petitioner reported
improvement in her range of motion and only occasional soreness in her shoulder. Ex. 23
at 8.
Petitioner’s orthopedist provided handwritten answers to a list of typewritten
questions. See Ex. 25. He has opined that Petitioner’s injury is permanent and
recommends a functional capacity evaluation. Id. at 2.
III. Applicable Law
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 & Hum. 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 & Hum. Servs., No. 03-
1585V, 2005 WL 6117475, at *20 (Fed. Cl. Spec. Mstr. Dec. 12, 2005). However, this rule
3 Petitioner has not filed any physical therapy records for this period.
4 Petitioner has not filed any physical therapy records for the period after her second surgery.
4

Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 5 of 7
does not always apply. “Written records which are, themselves, inconsistent, should be
accorded less deference than those which are internally consistent.” Murphy v. Sec’y of
Health & Hum. Servs., No. 90-882V, 1991 WL 74931, *4 (Fed. Cl. Spec. Mstr. April 25,
1991), quoted with approval in decision denying review, 23 Cl. Ct. 726, 733 (1991), aff'd
per curiam, 968 F.2d 1226 (Fed.Cir.1992)). And the Federal Circuit recently “reject[ed] as
incorrect the presumption that medical records are accurate and complete as to all the
patient’s physical conditions.” Kirby v. Sec’y of Health & Hum. Servs., 997 F.3d 1378,
1383 (Fed. Cir. 2021).
The United States Court of Federal Claims has 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 & Hum. 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 v. Sec’y
of Health & Hum. Servs., 42 Fed. Cl. 381, 391 (1998) (citing Blutstein v. Sec’y of Health
& Hum. Servs., No. 90-2808, 1998 WL 408611, at *5 (Fed. Cl. Spec. Mstr. June 30, 1998).
The credibility of the individual offering such fact testimony must also be determined.
Andreu v. Sec’y of Health & Hum. Servs., 569 F.3d 1367, 1379 (Fed. Cir. 2009); Bradley
v. Sec’y of Health & Hum. Servs., 991 F.2d 1570, 1575 (Fed. Cir. 1993).
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.
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 & Hum. 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
5

Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 6 of 7
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. Findings of Fact - Injury Localized to Vaccinated Arm
Respondent argues that Petitioner cannot sustain a Table SIRVA claim because
her “symptoms were not limited to [her] left shoulder.” Resp. at 9. In support, he points to
Petitioner’s first medical visit, during which she “reported pain radiating down her neck in
addition to pins and needles sensations all over her hands.” Id. at 9-10.
While the record of Petitioner’s initial visit with her PCP on October 1, 2019,
mentions symptoms radiating from her shoulder down to her hand, the bulk of the
remaining filed evidence focuses on Petitioner’s left shoulder. Ex. 2 at 6-9. And although
Petitioner’s PCP initially evaluated her cervical spine, he found no condition that
explained her shoulder symptoms and did not recommend any further evaluation or
treatment. See e.g., Ex. 2 at 5; Ex. 3 at 63. Further, Petitioner did not continue to complain
of radiating symptoms. By her first visit with her orthopedist on November 4, 2019 - less
than two months after her vaccination - she specifically denied any radiating symptoms.
Ex. 6 at 17. From then on, Petitioner received treatment focused solely on her shoulder
symptoms, including imaging, physical therapy, cortisone injection, and surgery. In fact,
Respondent does not cite any records other than the first treatment record. See. Resp.
at 9-10.
While I acknowledge the one report of radiating pain, it is outweighed by the
majority of evidence in Petitioner’s medical and treatment records establishing that her
pain and decreased range of motion was limited to her left shoulder. Despite
Respondent’s argument, Petitioner’s medical records need not be devoid of all reference
to pain or other symptoms outside the affected shoulder. See Kahler v. Sec’y of Health &
Human Servs., No. 19-1938V, 2024 WL 1928451, at *8 (Fed. Cl. Spec. Mstr. Mar. 27,
2024). In fact, “claims involving musculoskeletal pain primarily occurring in the shoulder
are valid under the Table even if there are additional allegations of pain extending to
adjacent parts of the body.” Id. (citing K.P. v. Sec'y of Health & Hum. Servs., No. 19-65V,
2022 WL 3226776, at *8 (Fed. Cl. Spec. Mstr. May 25, 2022).
Therefore, I find that Petitioner has provided preponderant evidence that her pain
and limited range of motion were limited to her left shoulder.
6

Case 1:21-vv-00692-UNJ Document 62 Filed 11/18/25 Page 7 of 7
V. Ruling on Entitlement
A. Requirements for Table SIRVA
I have found that Petitioner has preponderantly established that her symptoms
were limited to her vaccinated shoulder. 42 C.F.R. § 100.3(c)(10)(iii). Respondent has not
contested Petitioner’s proof on the remaining elements of a Table SIRVA. See 42 C.F.R.
§ 100.3(c)(10)(i), (iv). Therefore, I find that Petitioner has provided preponderant evidence
to establish that she suffered a Table SIRVA injury.
B. Additional Requirements for Entitlement
Because Petitioner has satisfied the requirements of a Table SIRVA, she need not
prove causation. Section 11(c)(1)(C). However, she must satisfy the other requirements
of Section 11(c) regarding the vaccination received, the duration and severity of injury,
and the lack of other award or settlement. Section 11(c)(A), (B), and (D).
The vaccine record shows that Petitioner received a flu vaccine in her left deltoid
on September 11, 2019. Ex. 1 at 4; Section 11(c)(1)(A) (requiring receipt of a covered
vaccine). Additionally, Petitioner has stated that she has not filed any civil action or
received any compensation for this vaccine-related injury, and there is no evidence to the
contrary. Ex. 6 at ¶9; Section 11(c)(1)(E) (lack of prior civil award). Finally, the records
indicate that Petitioner has suffered the residual effects of her vaccine-related injury for
more than six months and Respondent has not argued otherwise. See e.g., Ex. 4 at 52;
Ex. 12 at 49; Section 11(c)(1)(D)(i) (statutory six-month requirement). Therefore,
Petitioner has satisfied all requirements for entitlement under the Vaccine Act.
Conclusion
Based on the entire record in this case, I find that Petitioner has provided
preponderant evidence satisfying all requirements for a Table SIRVA. Petitioner is
entitled to compensation in this case. A separate damages order will be issued.
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
7

================================================================================
DOCUMENT 2: USCOURTS-cofc-1_21-vv-00692-1
Date issued/filed: 2026-03-31
Pages: 5
Docket text: PUBLIC DECISION (Originally filed: 02/18/2026) regarding 67 DECISION Stipulation/Proffer Signed by Chief Special Master Brian H. Corcoran. (nh) Service on parties made.
--------------------------------------------------------------------------------
Case 1:21-vv-00692-UNJ Document 73 Filed 03/31/26 Page 1 of 5
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 21-0692V
LINDA LYKINS, Chief Special Master Corcoran
Petitioner, Filed: February 18, 2026
v.
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Renee J. Gentry, The Law Office of Renee J. Gentry, Washington, DC, for Petitioner.
Camille Michelle Collett, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION AWARDING DAMAGES1
On January 12, 2021, Linda Lykins 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 following an
influenza vaccination on September 11, 2019. Petition at ¶2, 4, 15. The case was
assigned to the Special Processing Unit of the Office of Special Masters.
On October 14, 2025, a ruling on entitlement was issued, finding Petitioner entitled
to compensation for her shoulder injury. On February 17, 2026, Respondent filed a proffer
on award of compensation (“Proffer”) indicating Petitioner should be awarded
$100,819.72, comprised of $100,000.00 for pain and suffering and $819.72 for past
unreimbursed expenses. Proffer at 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.
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 1:21-vv-00692-UNJ Document 73 Filed 03/31/26 Page 2 of 5
Pursuant to the terms stated in the attached Proffer, I award Petitioner a lump
sum payment of $100,819.72, comprised of $100,000.00 for pain and suffering and
$819.72 for past unreimbursed expenses, to be paid through an ACH deposit to
Petitioner’s counsel’s IOLTA account for prompt disbursement to Petitioner. This
amount represents 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 1:21-vv-00692-UNJ Document 73 Filed 03/31/26 Page 3 of 5
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
LINDA LYKINS,
Petitioner, No. 21-692V
Chief Special Master Corcoran
v. ECF
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
PROFFER ON AWARD OF COMPENSATION
On January 12, 2021, Linda Lykins (“petitioner”) filed a petition for compensation 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 left shoulder and arm pain that was caused-in-fact by an
influenza (“flu”) vaccine she received on September 11, 2019. ECF No. 1 at 4. On June 20,
2024, petitioner filed a Motion for a Ruling on the Record (“Motion”), arguing that she had
established entitlement to compensation for both a causation-in-fact claim and a claim of
Shoulder Injury Related to Vaccine Administration (“SIRVA”), as defined by the Vaccine Injury
Table. ECF No. 57. Respondent filed his Response to Petitioner’s Motion on July 30, 2024,
recommending that entitlement to compensation be denied. ECF No. 58. On October 14, 2025,
the Court issued a Ruling on Entitlement, finding that petitioner is entitled to compensation.1
ECF No. 60.
1 Respondent has no objection to the amount of the proffered award of damages set forth herein.
Assuming the Chief Special Master issues a damages decision in conformity with this proffer,
respondent waives his right to seek review of such damages decision. However, respondent
reserves his right, pursuant to 42 U.S.C. § 300aa-12(e), to seek review of the Chief Special
Master’s October 14, 2025, entitlement decision.

Case 1:21-vv-00692-UNJ Document 73 Filed 03/31/26 Page 4 of 5
I. Compensation
A. Pain and Suffering
Respondent proffers that petitioner should be awarded $100,000.00 in pain and suffering.
See 42 U.S.C. § 300aa-15(a)(4). Petitioner agrees.
B. Past Unreimbursable Expenses
Evidence supplied by petitioner documents that she incurred past unreimbursable
expenses related to her vaccine-related injury. Respondent proffers that petitioner should be
awarded past unreimbursable expenses in the amount of $819.72. See 42 U.S.C. § 300aa-
15(a)(1)(B). Petitioner agrees.
These amounts represent all elements of compensation to which petitioner is entitled
under 42 U.S.C. § 300aa-15(a).2 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 lump sum payment of $100,819.72 to be paid through an ACH deposit to petitioner’s
counsel’s IOLTA account for prompt disbursement to petitioner, Linda Lykins.
Petitioner is a competent adult. Evidence of guardianship is not required in this case.
Respectfully submitted,
BRETT A. SHUMATE
Assistant Attorney General
2 Should petitioner die prior to the 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

Case 1:21-vv-00692-UNJ Document 73 Filed 03/31/26 Page 5 of 5
JONATHAN D. GUYNN
Acting Director
Torts Branch, Civil Division
HEATHER L. PEARLMAN
Deputy Director
Torts Branch, Civil Division
VORIS E. JOHNSON, JR.
Assistant Director
Torts Branch, Civil Division
s/Camille M. Collett
By s/ Madelyn E. Weeks
CAMILLE M. COLLETT
Trial Attorney
Torts Branch, Civil Division
U.S. Department of Justice
P.O. Box 146
Benjamin Franklin Station
Washington, D.C. 20044-0146
Tel.: (202) 616-4098
Email: Camille.M.Collett@usdoj.gov
Dated: February 17, 2026
3