VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_21-vv-00711
Package ID: USCOURTS-cofc-1_21-vv-00711
Petitioner: Kathleen Rice
Filed: 2021-01-12
Decided: 2025-08-14
Vaccine: influenza
Vaccination date: 2019-10-30
Condition: shoulder injury related to vaccine administration (SIRVA)
Outcome: compensated
Award amount USD: 69736

AI-assisted case summary:
Kathleen Rice filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging that she suffered a shoulder injury related to vaccine administration (SIRVA) caused by an influenza vaccine administered on October 30, 2019. She had no prior history of shoulder pain. Within two weeks of the vaccination, she began experiencing shoulder pain, which she linked to the flu shot. Medical records documented pain and limited range of motion in her left shoulder, with diagnoses including adhesive capsulitis. Petitioner submitted declarations from herself and her husband corroborating the onset of pain shortly after the vaccination. The respondent filed a Rule 4(c) report but later agreed to a stipulated award. The Chief Special Master issued a ruling on entitlement finding Petitioner entitled to compensation for a Table SIRVA, as the injury manifested within 48 hours of vaccination, was limited to the affected shoulder, and had no other explanatory cause. Subsequently, the parties submitted a proffer for damages. The court awarded Kathleen Rice a total of $69,736.98, comprising $65,000.00 for pain and suffering and $4,736.98 for unreimbursed expenses.

Theory of causation field:
Table

Public staged source text:

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DOCUMENT 1: USCOURTS-cofc-1_21-vv-00711-0
Date issued/filed: 2025-05-13
Pages: 7
Docket text: PUBLIC ORDER/RULING (Originally filed: 04/08/2025) regarding 49 Ruling on Entitlement. Signed by Chief Special Master Brian H. Corcoran. (cr) Service on parties made.
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Case 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 1 of 7
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 21-711V
UNPUBLISHED
KATHLEEN RICE, Chief Special Master Corcoran
Petitioner, Filed: April 8, 2025
v.
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Jessi Carin Huff, Mctlaw, Seattle, WA
Mitchell Jones, U.S. Department of Justice, Washington, DC, for Respondent.
RULING ON ENTITLEMENT1
On January 12, 2021, Kathleen Rice 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”) caused by an influenza (“flu”) vaccine administered on October
30, 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 Petitioner entitled to
compensation.
I. Relevant Procedural History
Following the filing of this case, the parties began informal settlement discussions
on July 5, 2023, but ultimately concluded that settlement was unlikely. Respondent
1 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 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 2 of 7
subsequently filed a Rule 4(c) Report defending this case on May 23, 2023. (“Report”),
ECF No. 42 at 6-8. Petitioner filed a Motion for Ruling on the Record on July 31, 2023.
Motion for Finding of Fact and Conclusions of Law (“Mot.”), ECF No. 44. Respondent filed
a response on October 23, 2023. Respondent’s Response to Petitioner’s Motion for
Findings of Fact and Conclusions of Law (“Resp.”), ECF No. 47. Petitioner filed a reply
on October 30, 2023. Petitioner filed a reply on October 30, 2023. Reply to Respondent’s
Response to Petitioner’s Motion for Ruling on the Record (“Reply”), ECF No. 48.
The matter is ripe for resolution.
II. Petitioner’s Medical Records
On October 30, 2019, Petitioner received a flu vaccine in her left shoulder. Ex. 1
at 1. She had no prior history of shoulder pain or issues.
A little more than two weeks later, Petitioner contacted Teladoc complaining of
shoulder pain on November 17, 2019. Ex. 22 at 4. She stated that her shoulder pain was
present “ever since receiving a flu shot four weeks ago.” Petitioner was advised to follow-
up with urgent care. Id. That same day, Petitioner complained of upper arm pain for
approximately four weeks “since a few days after” the flu vaccine. Ex. 2 at 4. An
examination showed painful but full range of motion. Id. at 5.
On November 21, 2019, Petitioner reported ongoing shoulder and arm pain to her
primary care physician. Ex. 4 at 13. She noted her pain began one-week post vaccination.
Id. X-rays were unremarkable, and she was prescribed gabapentin and hydrocodone.
Petitioner went to the radiology department of Virginia Mason Medical Center that same
day with complaints of shoulder pain “since” the flu vaccine. Ex. 11 at 524. Her
examination was unremarkable.
On November 26, 2019, Petitioner saw Dr. John Osland, an orthopedist. Ex. 4 at
30. She complained of shoulder pain that began “almost immediately” after the flu
vaccine. Id. Petitioner also reported that “[e]ver since then she has lost motion in the
shoulder and it has been pailful….” Id. An examination showed limited range of motion
with pain in all directions. Id. at 32. She was diagnosed with adhesive capsulitis with
possible impingement and nerve entrapment. A steroid injection was administered, and
she was referred to physical therapy. Id.
Petitioner began physical therapy on December 10, 2019. Ex. 4 at 41. At the first
visit, she reported she “got a flu shot about 6 weeks ago”, was sore after, “and the pain
got steadily worse.” Id. Between December 10, 2019 and February 28, 2019, she
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Case 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 3 of 7
attended ten physical therapy sessions. Id. at 63-64. By February 28 she reported her
shoulder was 75% improved. Id. at 64.
On December 26, 2019, Petitioner again contacted Teledoc with complaints of
shoulder pain. Ex. 22 at 6-7. She stated her pain “[s]tarted with flu injection 2.5 months
ago and it was a little sore and didn’t get better.” Id. at 7.
Petitioner next complained of shoulder pain over six months later, on July 16, 2020,
when she reported ongoing arm pain since last receiving a flu vaccine in 2019. Ex. 5 at
233-35. She was diagnosed with adhesive capsulitis and a frozen shoulder that was
“maybe triggered by flu shot.” Id. at 235. Petitioner returned for further testing on July 31,
2020. The record notes that Petitioner’s “history is suggestive of a possible shoulder injury
related to vaccine administration.” Id. at 212. X-ray and ultrasound exams on July 31 were
unremarkable. Id. at 201, 09.
Petitioner returned to physical therapy periodically between August 2020 and
November 2021. On August 20, 2020, Petitioner had an initial evaluation for additional
physical therapy related to her shoulder pain. Ex. 21 at 130. Onset is listed as nine months
ago, and the mechanism of injury is indicated as “[f]lu shot 9 months ago.” Id. In May of
2021, Petitioner had another four physical therapy sessions, this time for both her
shoulder and unrelated right hip pain. Ex. 24 at 12. The shoulder pain “continues to be
due to adhesive capsulitis” which caused limited range of motion, weakness, and pain.
Id. And on November 18, 2021, Petitioner returned for physical therapy related to her hip
and left shoulder pain. Ex. 25 at 8.
III. Affidavit Evidence
Petitioner submitted a declaration in support of her claim. Ex. 30. She states that
the flu vaccine she received on October 30, 2019, was “extremely painful”, and that it
worsened in the days following the vaccine. Id. at 1-2. She also stated that she does not
recall telling anyone that her pain began “a few days after the administration of the flu
shot”, and that “the pain was immediate.” Id. at 2.
Mr. Chris Hall, Petitioner’s husband, submitted a declaration in support of this
claim. Ex. 28. He recalls that “[w]hen [Petitioner] came home from receiving her flu shot,
she began complaining about how painful it was.” Id.
Ms. Wendy Shipp, a colleague of Petitioner, also provided a declaration. Ex. 29.
She stated that Petitioner appeared to be in pain on November 2, 2019. Id. When asked
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Case 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 4 of 7
the problem, Petitioner told her “she had an incredibly painful flu injection a few days prior
and that her shoulder still hurt from the injection.” Id.
IV. Fact Findings and Ruling on Entitlement
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). In addition to requirements concerning the vaccination received, the
duration and severity of petitioner’s injury, and the lack of other award or settlement,3 a
petitioner must establish that she suffered an injury meeting the Table criteria, in which
case causation is presumed, or an injury shown to be caused-in-fact by the vaccination
she received. Section 11(c)(1)(C).
The most recent version of the Table, which can be found at 42 C.F.R. § 100.3,
identifies the vaccines covered under the Program, the corresponding injuries, and the
time period in which the particular injuries must occur after vaccination. Section 14(a).
Pursuant to the Vaccine Injury Table, a SIRVA is compensable if it manifests within 48
hours of the administration of an influenza vaccine. 42 C.F.R. § 100.3(a)(XIV)(B). A
vaccine recipient shall be considered to have suffered SIRVA if such recipient manifests
all of the following:
(i) No history of pain, inflammation or dysfunction of the affected shoulder
prior to intramuscular vaccine administration that would explain the alleged
signs, symptoms, examination findings, and/or diagnostic studies occurring
after vaccine injection;
(ii) Pain occurs within the specified time frame;
(iii) Pain and reduced range of motion are limited to the shoulder in which
the intramuscular vaccine was administered; and
(iv) No other condition or abnormality is present that would explain the
patient’s symptoms (e.g., NCS/EMG or clinical evidence of radiculopathy,
brachial neuritis, mononeuropathies, or any other neuropathy).
42 C.F.R. § 100.3(c)(10).
3 In summary, a petitioner must establish that she received a vaccine covered by the Program, administered
either in the United States and its territories or in another geographical area but qualifying for a limited
exception; suffered the residual effects of her injury for more than six months, died from her injury, or
underwent a surgical intervention during an inpatient hospitalization; and has not filed a civil suit or collected
an award or settlement for her injury. See § 11(c)(1)(A)(B)(D)(E).
4

Case 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 5 of 7
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, the
Federal Circuit has recently “reject[ed] as incorrect the presumption that medical records
are always accurate and complete as to all of the patient’s physical conditions.” Kirby v.
Sec'y of Health & Hum. Servs., 997 F.3d 1378, 1383 (Fed. Cir. 2021). Medical
professionals may not “accurately record everything” that they observe or may “record
only a fraction of all that occurs.” Id.
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 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. Factual Findings Regarding a Table SIRVA
After a review of the entire record, I find that a preponderance of the evidence
demonstrates that Petitioner has satisfied the QAI requirements for a Table SIRVA.
1. Petitioner Had No Prior Left Shoulder Condition or Injury that
would Explain her Symptoms
The first requirement for a Table SIRVA is a lack of problems associated with the
affected shoulder prior to vaccination that would explain the symptoms. 42 C.F.R. §
100.3(c)(10)(i). Respondent does not dispute that Petitioner meets this criterion. I find
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Case 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 6 of 7
that she has demonstrated a lack of history of pain, inflammation, or dysfunction of her
left shoulder that would explain her symptoms.
2. Onset of Petitioner’s Injury Occurred within Forty-Eight Hours of
Vaccination
The medical records preponderantly establish onset of injury close-in-time to
vaccination. Petitioner first reported shoulder pain on November 17, 2019. Ex. 22 at 4.
Her doctor noted Petitioner had pain “ever since receiving a flu shot….” Id. Thereafter,
she linked her shoulder pain to this same vaccination. See, e.g., Ex. 11 at 524
(complaining of shoulder pain “since” the flu vaccine); Ex. 4 at 30 (reporting pain “almost
immediately” after the flu vaccine); Ex. 22 at 6-7 (stating Petitioner’s pain “[s]tarted with
flu injection 2.5 months ago … and didn’t get better.). Petitioner’s declarations corroborate
the onset timeline, stating that her pain started when she received the vaccination. Ex. 28
at 1; Ex. 29 at 1; Ex. 30 at 1.
Respondent argues that Petitioner was inconsistent in describing the onset of her
pain. Resp. at 6-7. He also contends that Petitioner reported onset outside the 48-hour
requirement of a Table Claim on at least two occasions. Ex. 2 at 4 (stating her pain began
a few days after the flu shot and never subsided); Ex. 4 at 13 (record noting Petitioner
“felt fine for a week after her vaccine before the pain came on”). And he maintains that
witness statements should be given little weight because they were prepared over a year
after the events. Id.
While the record does contain inconsistencies, when viewed in its entirety there is
ample evidence to find proper onset near in time to the vaccination. Further, Program
petitioners are not required to marshal records setting forth with chronographic specificity
the precise day and hour that their onset manifested. As noted above, Petitioner generally
linked her shoulder pain to the October 30, 2019 vaccination, and she more often than
not maintained in began in a timeframe consistent with this Table requirement.
Accordingly, there is preponderant evidence that establishes the onset of
Petitioner’s left shoulder pain more likely than not occurred within 48-hours of vaccination.
3. Petitioner’s Pain was Limited to her Left Shoulder
Petitioner’s pain was limited to her left shoulder. Respondent does not contest this
aspect of Petitioner’s claim, and there is nothing in the records to suggest otherwise.
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Case 1:21-vv-00711-UNJ Document 52 Filed 05/13/25 Page 7 of 7
4. There is No Evidence of Another Condition or Abnormality
The last criteria for a Table SIRVA state that there must be no other condition or
abnormality which would explain a petitioner’s current symptoms. 42 C.F.R. §
100.3(c)(10)(iv). Respondent does not contest this aspect of Petitioner’s claim, and there
is nothing in the records to suggest that any such condition or abnormality exists.
B. Other Requirements for Entitlement
In addition to establishing a Table injury, a petitioner must also provide
preponderant evidence of the additional requirements of Section 11(c). Respondent does
not dispute that Petitioner has satisfied these requirements in this case, and the overall
record contains preponderant evidence to fulfill these additional requirements.
The record shows that Petitioner received a flu vaccine intramuscularly on October
30, 2019, in the United States. Ex. 1 at 1; see Section 11(c)(1)(A) (requiring receipt of a
covered vaccine); Section 11(c)(1)(B)(i)(I) (requiring administration within the United
States or its territories). Further, Petitioner suffered the residual effects of her injury for
more than six months. Ex. 5 at 233; see Section 11(c)(1)(D). There is no evidence that
Petitioner has collected a civil award for her injury. Ex. 8; Section 11(c)(1)(E) (lack of prior
civil award).
Based upon all of the above, Petitioner has established that she suffered a Table
SIRVA. Additionally, she has satisfied all other requirements for compensation. I therefore
find that Petitioner is entitled to compensation in this case.
Conclusion
In view of the evidence of record, I find that there is preponderant evidence
that Petitioner satisfies the QAI requirements for a Table SIRVA. Further, based on
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
7

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DOCUMENT 2: USCOURTS-cofc-1_21-vv-00711-1
Date issued/filed: 2025-08-14
Pages: 5
Docket text: PUBLIC DECISION (Originally filed: 07/14/2025) regarding 57 DECISION Stipulation/Proffer. Signed by Chief Special Master Brian H. Corcoran. (cr) Service on parties made.
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Case 1:21-vv-00711-UNJ Document 61 Filed 08/14/25 Page 1 of 5
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 21-711V
KATHLEEN RICE Chief Special Master Corcoran
Petitioner, Filed: July 14, 2025
v.
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Jessi Carin Huff, Maglio Christopher & Toale, PA, Seattle, WA, for Petitioner.
Mitchell Jones, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION AWARDING DAMAGES1
On January 12, 2021, Kathleen Rice 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 vaccine administered on October 30,
2019. Petition at 1. The case was assigned to the Special Processing Unit of the Office
of Special Masters.
On April 8, 2025, a ruling on entitlement was issued, finding Petitioner entitled to
compensation for a SIRVA. On July 7, 2025, Respondent filed a proffer on award of
compensation indicating Petitioner should be awarded $69,736.98 (comprised of
$65,000.00 for pain and suffering and $4,736.98 for unreimbursed expenses).
Respondent’s Proffer on Award of Compensation (“Proffer”) at 1. 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-00711-UNJ Document 61 Filed 08/14/25 Page 2 of 5
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 Proffer, I award Petitioner a lump sum
payment of $69,736.98 (comprised of $65,000.00 for pain and suffering and
$4,736.98 for 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-00711-UNJ Document 61 Filed 08/14/25 Page 3 of 5
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
)
KATHLEEN RICE, )
)
Petitioner, )
) No. 21-711V
v. ) Chief Special Master Corcoran
) ECF
SECRETARY OF HEALTH AND HUMAN )
SERVICES, )
)
Respondent. )
)
RESPONDENT’S PROFFER ON AWARD OF COMPENSATION
On January 12, 2021, Kathleen Rice (“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 a Shoulder Injury Related to Vaccine Administration
(“SIRVA”), as defined in the Vaccine Injury Table, following administration of an influenza
vaccine she received on October 30, 2019. Petition at 1. On May 23, 2023, the Secretary of
Health and Human Services (“respondent”) filed a Rule 4(c) Report indicating that this case is
not appropriate for compensation under the terms of the Act for a Table injury for SIRVA after a
flu vaccination. ECF No. 42. On April 8, 2025, the Chief Special Master issued a Ruling on
Entitlement finding petitioner entitled to compensation. 1 ECF No. 49.
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 April 8, 2025 entitlement ruling.

Case 1:21-vv-00711-UNJ Document 61 Filed 08/14/25 Page 4 of 5
I. Items of Compensation
A. Pain and Suffering
Respondent proffers that petitioner should be awarded $65,000.00 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 $4,736.98. See 42 U.S.C. § 300aa-
15(a)(1)(B). Petitioner agrees.
II. Form of the Award and Recommended Payments Following Judgement
Petitioner is a competent adult. Evidence of guardianship is not required in this case.
Respondent recommends that the compensation provided to petitioner should be made through a
lump sum payment as described below and requests that the Chief Special Master’s decision and
the Court’s judgment award the following:2
a lump sum payment of $69,736.98 (combination of pain and suffering ($65,000)
and past unreimbursed expenses($4,736.98.00)), to be paid through an ACH deposit to
petitioner’s counsel’s IOLTA account for prompt disbursement to petitioner.
These amounts represent all elements of compensation to which petitioner is entitled
under 42 U.S.C. § 300aa-15(a). Petitioner agrees.
Respectfully submitted,
BRETT A. SHUMATE
Assistant Attorney General
2 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 1:21-vv-00711-UNJ Document 61 Filed 08/14/25 Page 5 of 5
C. SALVATORE D’ALESSIO
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/ Mitchell Jones
MITCHEL JONES
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) 305-1748
mitchell.jones@usdoj.gov
DATED: July 7, 2025
3