VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_23-vv-00283
Package ID: USCOURTS-cofc-1_23-vv-00283
Petitioner: Ryland Beutz
Filed: 2023-02-27
Decided: 2025-09-17
Vaccine: meningococcal B
Vaccination date: 2021-09-30
Condition: shoulder injury related to vaccine administration (SIRVA)
Outcome: compensated
Award amount USD: 65000

AI-assisted case summary:
On February 27, 2023, Ryland Beutz filed a petition alleging that a meningococcal B vaccination administered on September 30, 2021 caused a shoulder injury related to vaccine administration. The vaccination occurred during a 16-year-old well-child visit.

Respondent disputed the Table SIRVA onset requirement. Ms. Beutz had a physical therapy appointment four days after vaccination for preexisting unrelated knee pain without mentioning shoulder pain, and when she called her primary-care office 11 days after vaccination she reported generalized symptoms rather than specifically naming shoulder pain. Respondent also pointed to a report that she attended volleyball practice after the shots and to later shoulder findings, including a SLAP tear, biceps tendinosis, and a glenoid cartilage/labral abnormality, as possible alternative explanations.

Chief Special Master Brian H. Corcoran found onset within 48 hours. Ms. Beutz stated that the injection site burned badly and became sharp pain the same day, that she cried that night from the pain, and that she could not lift her arm without shooting pain. Her mother stated that immediately after the appointment Ms. Beutz complained of severe pain and inability to move the arm. On October 14, 2021, two weeks after vaccination, Ms. Beutz returned to her primary-care provider reporting left arm pain after immunizations. Later physical therapy, acupuncture, neurology, and pain-clinic records repeatedly linked the shoulder pain, swelling, redness, and tenderness to the vaccination, though the record also contained treatment gaps.

The special master found the onset evidence sufficient and urged informal resolution, noting that treatment gaps could matter to damages. The case then resolved by stipulation. On September 17, 2025, Chief Special Master Corcoran awarded Ms. Beutz a lump sum of $65,000.00 through counsel's IOLTA account, representing all Vaccine Act damages.

Theory of causation field:
Meningococcal B vaccine, September 30, 2021, age 16, alleged SIRVA. COMPENSATED. Respondent disputed onset within 48 hours and noted PT visit 4 days post-vaccination, PCP call 11 days post-vaccination, volleyball practice, and alternative shoulder findings. Chief Special Master Corcoran found onset within 48 hours based on petitioner/mother affidavits, October 14 PCP visit, later PT/acupuncture/neurology records tying pain/swelling to the shot, while noting treatment gaps and alternative abnormalities for damages. Award by stipulation September 17, 2025: $65,000 lump sum. Attorney Glen H. Sturtevant; respondent Madylan Yarc.

Public staged source text:

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DOCUMENT 1: USCOURTS-cofc-1_23-vv-00283-0
Date issued/filed: 2025-03-17
Pages: 8
Docket text: PUBLIC ORDER/RULING (Originally filed: 01/31/2025) regarding 22 Findings of Fact & Conclusions of Law, Signed by Chief Special Master Brian H. Corcoran. (nh) Service on parties made.
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Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 1 of 8
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 23-283V
RYLAND BEUTZ, Chief Special Master Corcoran
Petitioner,
v. Filed: January 31, 2025
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Glen Howard Sturtevant, Jr., Rawls Law Group (Richmond), Richmond, VA, for Petitioner.
Madylan Louise Yarc, U.S. Department of Justice, Washington, DC, for Respondent.
FACT RULING ON ONSET1
On February 27, 2023, Ryland Beutz (“Petitioner”) filed a petition for compensation
under the National Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq.2
(the “Vaccine Act”), alleging that she suffered a Table shoulder injury related to vaccine
administration (“SIRVA”) as a result of a Meningococcal B vaccine administered to her on
September 30, 2021.3 Pet. at 1, ECF No. 1. The case was assigned to the Special
Processing Unit of the Office of Special Masters.
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).
3 Petitioner alternatively alleges that her SIRVA was caused-in-fact by the subject vaccination, or if her
injury is found to be immunologic, neurologic, or genetic in nature, that the vaccination significantly
aggravated her underlying disorder. See Pet.

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 2 of 8
For the reasons discussed below, I find it more likely than not that the onset of
Petitioner’s shoulder pain occurred within 48 hours of vaccination, as alleged.
I. Relevant Procedural History
Shortly after initiating her claim, Petitioner filed affidavits and medical records,
followed by a statement of completion. ECF Nos. 6-8, 14-15, 19. Respondent thereafter
determined this matter was not appropriate for compensation. ECF No. 20. Respondent
filed his Rule 4(c) Report in defense of this case on May 24, 2024. Respondent’s Report,
ECF No. 21.
Among other things, Respondent contends that the medical records do not support
the conclusion that the onset of her pain occurred within 48 hours of vaccination.
Respondent’s Report at 14. Petitioner had a physical therapy (“PT”) visit four days post
vaccination without mentioning shoulder pain. Id. at 14-15. Then, when she called her
primary care provider (“PCP”)’s office roughly 11 days post vaccination, she reported only
generalized symptoms, and did not seek shoulder-related care for a few days more. Id.
at 15. And any allegations of Petitioner’s pain beginning soon after vaccination made
during her first treatment visit are inconsistent with her statement that she participated in
volleyball practice right after her receipt of the subject vaccination. Id. (citing Ex. 3 at 12).
The onset dispute is now ripe for consideration.
II. 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). “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
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.
2

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 3 of 8
The United States Court of Federal Claims has recognized that “medical records
may be incomplete or inaccurate.” Camery v. Sec’y of Health & Hum. 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 & 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, 42
Fed. Cl. at 391 (citing Blutstein v. Sec’y of Health & Hum. Servs., No. 90-2808, 1998 WL
408611, at *5 (Fed. Cl. Spec. Mstr. June 30, 1998)).
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 § 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 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).
III. Relevant Factual Evidence
I make this finding after a complete review of the record to include all medical
records, affidavits, and additional evidence filed, and in particular the following:4
• Petitioner received the subject vaccination on September 30, 2021, during
a visit with her PCP for a 16-year-old well-child visit. Ex. 3 at 23.
4 While I have reviewed all the evidence filed to-date in this case, only evidence related to onset will be
discussed herein, though other facts may be provided as necessary.
3

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 4 of 8
• Petitioner maintains that “[a]fter [her] shot, the spot where the needle was
injected burned badly and it turned into a very sharp pain. The pain did not
get better throughout the day.” Ex. 2 at 1. That night, “[t]he pain was so
intense . . . that [she] cried to her mom about how much it hurt[,]” and she
could not lift her arm without shooting pain. Id. She explained that her pain
persisted “after two weeks,” so she sought care. Id.
• Petitioner’s mother authored an affidavit on her behalf attesting that
“[i]mmediately following [the vaccination] appointment, [Petitioner]
complained [to her] of severe pain and [that] she could not move her arm.”
Ex. 1 at 1. Petitioner’s mother noted that they “did typical anti-inflammatory
treatments for a couple days with no improvement.” Id.
• Four days post vaccination, on October 4, 2021, Petitioner had a visit with
her physical therapist for pre-existing and unrelated left knee pain. Ex. 4 at
9. Petitioner did not report left shoulder complaints during this visit.
• One week later, on October 11, 2021, Petitioner called her PCP’s office
reporting that it had been “[o]ver 3 days since [her] shot and [she had]
general symptoms (such as muscle aches, headache, fussiness, chills)
[that] are getting worse.” Ex. 3 at 15. Left shoulder symptoms were not
mentioned along with these other complaints. See id.
• On October 14, 2021 (now 14 days post vaccination), Petitioner returned to
her PCP complaining of “left arm pain after her immunizations done a
couple of weeks ago.” Ex. 3 at 12. Petitioner’s mother (also present during
this visit) stated that Petitioner “had volleyball practice right after getting her
immunizations done that day.” Id. She was assessed with acute pain of the
left shoulder and prescribed prednisone. Id.
• On March 25, 2022 (after a four-month gap in shoulder-related care),
Petitioner had an initial PT evaluation. Ex. 4 at 5. She reported that her
“[s]ymptoms started last fall after she received a shot/vaccination at her
physical.” Id. Specifically, she described “[i]nsidious onset after receiving
[her] shot.” Id. She endorsed pain throughout the left deltoid, upper
trapezius, and collarbone, that was worse with activity, sharp and achy, and
rated at a 2-10/10. Id. The assessment was “consistent with left shoulder
pain; specifically throughout [the] deltoid [and] potential nerve irritability
following [a left] shoulder injection/vaccination in the fall.” Id. at 7.
4

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 5 of 8
• Petitioner had an orthopedic consultation on April 12, 2022. Ex. 13 at 33.
She complained of “left-sided shoulder/neck pain since October” but that
there was “no known injury or mechanism of action.” Id.
• Petitioner began acupuncture treatment on April 28, 2022, and reported that
she “received a vaccine [on] 9/30/2021 in [her] left shoulder. Immediately
following the shot [she] had so much pain [she] couldn’t move [her] arm.”
Ex. 5 at 2. She rated the pain at a 3-8/10. Id.
• During a neurology consultation on May 27, 2022, Petitioner reported “left-
sided shoulder and neck pain since October 2021.” Ex. 6 at 5. She did not
describe a known “injury or mechanism of action EXCEPT she was given a
vaccine in her [left] deltoid which became swollen, reddened, and
exquisitely tender.” Id. (emphasis in original). She also complained of
headaches on the left side of her head. Id. Petitioner’s mother added that
“the only event they can correlate to [Petitioner’s] shoulder pain and
headaches is when she received a vaccine, she was unable to move her
left arm for a few days following injection, her left arm ‘swelled up’ and [she]
experienced sudden onset of zinging pains up her neck.” Id.
• Following another six-month gap in treatment, on November 29, 2022,
Petitioner visited a pain intervention specialist for chronic left shoulder pain.
Ex. 7 at 17. She “correlate[d] her initial episode of pain with a vaccine
approximately one year ago which resulted in swelling in the area.” Id.
Petitioner stated she was “unaware of the exact start date of her first
symptoms.” Id.
• Petitioner sought care with a new physical therapist on November 30, 2022.
Ex. 7 at 11. She reported “left shoulder pain that started after a
meningococcal vaccine before school started in 2021.” Id. More so, “that
her left shoulder swelled and was very painful for 2 weeks before going in
for prednisone.” Id.
• No other medical record or affidavit evidence regarding the onset of
Petitioner’s post vaccination shoulder injury has been filed.
IV. Finding of Fact Regarding Onset
A petitioner alleging a SIRVA claim must show that she experienced the first
symptom or onset within 48 hours of vaccination (42 C.F.R. § 100.3(a)(XIV)(B) and
3(c)(10)(ii) (QAI criteria)). As stated above, Respondent contends that Petitioner’s
5

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 6 of 8
medical records do not support that the onset of her pain occurred within 48 hours of
vaccination. Respondent’s Report at 14-15.
Respondent’s objections are ultimately unpersuasive, however, when considered
against the totality of the evidence. The aforementioned medical records, coupled with
Petitioner’s filed affidavits, establish that Petitioner consistently reported to treaters an
onset close-in-time to vaccination, that she sought treatment within two weeks of the
September 30, 2021 vaccination, and that she indeed was experiencing symptoms in the
relevant timeframe. See, e.g., Exs. 1-2, Ex. 3 at 12; Ex. 4 at 5; Ex. 5 at 2.
The fact that Petitioner sought treatment within two weeks of her vaccination (on
October 14, 2021) actually supports a finding of Table onset. In other cases, significantly
greater delays did not undermine an otherwise-preponderantly-established onset
showing consistent with the Table. See, e.g., Tenneson v. Sec’y of Health & Hum. 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 & Hum. 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 a petitioner underestimated the
severity of her shoulder injury).
Likewise, the fact that Petitioner sought care with her physical therapist four days
post vaccination (on October 4, 2021) without mentioning left shoulder pain does not
detract from her arguments on onset, as it was a regularly-scheduled visit for unrelated
and pre-existing knee pain – a separate injury from her SIRVA. Similarly, her call to her
PCP on October 11, 2021, with generalized complaints including “muscle aches,” not left
shoulder pain specifically, does not preclude a finding of Table onset – especially in light
of the fact that Petitioner still sought care for left shoulder pain within three days of this
call when her home remedies proved unsuccessful. See, e.g., Ex. 2 at 1.
In addition, the filed medical record establishes that Petitioner affirmatively and
repeatedly linked her shoulder pain to the subject vaccine – beginning with the October
14th treatment encounter, at which time she noted that her shoulder pain began “after
getting [her] immunizations [sic] done a couple of weeks ago.” Ex. 3 at 12. This reporting
provides further support for Table onset. Other subsequent medical and/or acupuncture
records describe onset with more particularity, noting that her left shoulder pain had an
“[i]nsidious onset after receiving [her] shot” and, most persuasively, that she “received a
vaccine [on] 9/30/2021 . . . . Immediately following the shot [she] had so much pain [she]
couldn’t move [her] arm.” Ex. 4 at 5; Ex. 5 at 2. More so, such entries corroborate the
6

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 7 of 8
contention made in Petitioner’s affidavit that her pain began within 48 hours of
vaccination. Ex. 2 at 1.
Although some of Petitioner’s records suggest an onset beginning at some
unspecified time in October 2021, I do not find this evidence preponderates against a
favorable onset finding. See Ex. 13 at 33 (an April 12, 2022 report of “left-sided
shoulder/neck pain since October”); Ex. 6 at 5 (a May 27, 2022 report of “left-sided
shoulder and neck pain since October 2021” and that “she was given a vaccine in her
[left] deltoid which became swollen, reddened, and exquisitely tender.”). In fact, Petitioner
still related her pain as beginning after her receipt of the vaccine in question. Ex. 6 at 5.
These records are thus consistent with her other general reports of pain beginning after
her subject vaccination. See, e.g., Ex. 7 at 11, 17.
Conclusion and Scheduling Order
Petitioner has provided preponderant evidence that the onset of her shoulder pain
occurred within 48 hours of vaccination.
I will note, however, that Respondent’s remaining objection to a Table SIRVA5 (not
discussed in this Ruling) could ultimately require more evaluation. I thus strongly
encourage the parties to promptly attempt an informal resolution of this claim before
expending any further litigative resources on the case. If at any time informal resolution
appears unlikely, given that the claim has been pending in SPU for over one year (having
been assigned in August 2023), the parties should propose a method for moving forward,
i.e., with a proposed briefing schedule or otherwise stating how they wish to proceed.
I will also encourage that Petitioner’s settlement demand should contemplate the
multiple gaps in Petitioner’s treatment course – as such evidence is often deemed to show
the mildness of the injury as the petitioner could handle the pain with conservative
measures, only.
Accordingly, by no later than Monday, March 17, 2025, the parties shall file a
joint status report confirming the date on which Petitioner conveyed, or intends to convey,
a reasonable settlement demand and supporting documentation for Respondent’s
consideration.
5 In disputing Petitioner’s Table SIRVA claim, Respondent also argued that there are other conditions or
abnormalities present (SLAP tear, biceps tendinosis, and/or grade 3 chondral lesion of the central glenoid
with fraying of the labrum) that could explain her post-vaccination symptoms independent of the subject
vaccination. Respondent’s Report at 15-16 (citing Ex. 13 at 6, 23).
7

Case 1:23-vv-00283-UNJ Document 25 Filed 03/17/25 Page 8 of 8
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
8

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DOCUMENT 2: USCOURTS-cofc-1_23-vv-00283-1
Date issued/filed: 2025-10-31
Pages: 7
Docket text: PUBLIC DECISION (Originally filed: 09/17/2025) regarding 32 DECISION Stipulation/Proffer, Signed by Chief Special Master Brian H. Corcoran. (nh) Service on parties made.
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Case 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 1 of 7
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 23-283V
RYLAND BEUTZ, Chief Special Master Corcoran
Petitioner,
v. Filed: September 17, 2025
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Glen Howard Sturtevant, Jr., Rawls Law Group (Richmond), Richmond, VA, for
Petitioner.
Madylan Yarc, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION ON JOINT STIPULATION1
On February 27, 2023, Ryland Beutz filed a petition for compensation under the
National Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq.2 (the
“Vaccine Act”). On September 30, 2021, Petitioner received a Meningococcal B vaccine,
a vaccine contained in the Vaccine Injury Table (the “Table”), 42 C.F.R. § 100.3(a).
Petitioner alleges that she sustained a shoulder injury related to vaccine administration
(“SIRVA”) as defined in the Table; she further alleges that the vaccine caused her alleged
shoulder injury, and that she suffered the residual effects of her alleged injury for more
than six months.
Respondent denies that Petitioner sustained a SIRVA Table injury; denies that the
vaccine caused Petitioner’s alleged shoulder injury, or any other injury; and denies that
her current condition is a sequela of a vaccine-related injury.
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 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 2 of 7
Nevertheless, on September 17, 2025, 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 the following
compensation:
A lump sum of $65,000.00 to be paid through an ACH deposit to Petitioner’s
counsel’s IOLTA account for prompt disbursement to Petitioner. Stipulation
¶ 8. 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 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 3 of 7
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
RYLAND BEUTZ,
Petitioner, No. 23-283V
Chief Special Master Corcoran
v. ECF
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
STIPULATION
The parties hereby stipulate to the following matters:
1. Ryland Beutz ("petitioner") filed a petition for vaccine compensation under the
National Vaccine Injury Compensation Program, 42 U.S.C. § 30-0aa-l0 to -34 (the: "Vaccine:
Program"). The petition seeks compensation for injuries allegedly related to petitioner's receipt
of a Meningococcal B vaccine, which vaccine is contained in the Vaccine Injury Table (the
"Table"), 42 C.F.R. § I00.3(a).
2. Petitioner received a Meningococcal B vaccine on September 30, 2021.
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 experienced
the residual effects of this condition 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 alleged injury.

Case 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 4 of 7
6. Respondent denies that petitioner sustained a SIRVA Table injury; denies that the
vaccine caused petitioner's alleged shoulder injury, or any other injury; and denies that her
current condition is a sequela 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 ofj udgment reflecting a decision consistent with
the tenns of this Stipulation, and after petitioner has filed an election to receive compensation
pursuant to 42 U.S.C. § 300aa-2l(a)(I), the Secretary of Health and Human Services will issue
the following vaccine compensation payment:
A lump sum of $65,000.00 to be paid through an ACH deposit to petitioner's counsel's
IOLT A account for prompt disbursement to petitioner. This amount represents
compensation for all damages that would be available under 42 U.S.C. § 300aa-15(a).
9. As soon as practicable after the entry ofj udgment 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-21 (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.
I 0. 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
2

Case 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 5 of 7
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. Payment 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 S(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
(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-IO 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, the Meningococcal B vaccination administered on
September 30, 2021, as alleged in a petition for vaccine compensation filed on or about February
27, 2023, in the United States Court of Federal Claims as petition No. 23-283V.
3

Case 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 6 of 7
14. If petitioner should die prior to entry ofj udgment, 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 fai Is to issue a decision in complete confonnity with the tenns
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.
17. This Stipulation shall not be construed as an admission by the United States or the
Secretary of Health and Human Services that the Meningococcal B vaccine caused petitioner's
alleged injury or any other injury or her current disabilities, or that petitioner suffered an injury
contained in the Vaccine Injury Table.
18. All rights and obligations of petitioner hereunder shall apply equally to petitioner's
heirs, executors, administrators, successors, and/or assigns.
END OF STIPULATION
4

Case 1:23-vv-00283-UNJ Document 36 Filed 10/31/25 Page 7 of 7
Respectfully submitted,
PETITIO~r ~
R~ DBEUTZ
ATTORNEY OF RECORD FOR AUTHORIZED REPRESENTATIVE
PETITIONER: OF THE ATTORNEY GENERAL:
G~~
~~p~
HEATHER L. PEARLMAN
Rawls Law Group Deputy Director
211 Rocketts Way Torts Branch, Civil Division
Suite I 00 U.S. Department of Justice
Richmond, VA 23231 P.O. Box 146
(804) 344-0038 Benjamin Franklin Station
gsturtevant@rawlslawgroup.com Washington, DC 20044-0146
AUTHORIZED REPRESENTATIVE ATTORNEY OF RECORD FOR
OF THE SECRETA RY OF HEALT H RESPONDENT:
AND HUMAN SERVICES:
Jeffrey S.
Digitally signed by
Jeffrey S. Beach -S
-S 11ffe:ft:#4fH ,
Beach Date:2025.08.1-4
09:ss:s3 -04' 00' for
CAPT GEORGE REED GRIMES, MD, MPH
Director, Division of Injury
Compensation Programs Torts Branch, Civil Division
Health Systems Bureau U.S. Department of Justice
Health Resources and Services P.O. Box 146
Administration Benjamin Franklin Station
U. S. Department of Health Washington, DC 20044-0146
and Human Services (202) 742-6376
5600 Fishers Lane, 08W-25A madylan.l.yarc@usdoj ,gov
Rockville, MD 20857
1
Dated: ~ r / /7 / i.oz5
I
5