VICP Registry Case Source Bundle Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_23-vv-01078 Package ID: USCOURTS-cofc-1_23-vv-01078 Petitioner: Debra A. Schiller Filed: 2023-07-13 Decided: 2024-09-04 Vaccine: influenza Vaccination date: 2021-10-14 Condition: shoulder injury related to vaccine administration (SIRVA) Outcome: compensated Award amount USD: 159460 AI-assisted case summary: Debra A. Schiller filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered a shoulder injury related to vaccine administration (SIRVA) from an influenza vaccination received on October 14, 2021. The respondent, the Secretary of Health and Human Services, conceded that Petitioner's injury was consistent with SIRVA as defined by the Vaccine Injury Table and that she met all legal prerequisites for compensation. A Ruling on Entitlement was issued on April 5, 2024, finding Petitioner entitled to compensation. Subsequently, on July 29, 2024, the respondent filed a Proffer on Award of Compensation, which Petitioner agreed to. Based on this proffer, Chief Special Master Corcoran awarded Debra A. Schiller a total of $159,460.89. This award included $155,000.00 for pain and suffering, $650.77 for past unreimbursable expenses, and $3,810.12 for past lost wages, to be paid as a lump sum. The decision was finalized on September 4, 2024. Theory of causation field: Table Public staged source text: ================================================================================ DOCUMENT 1: USCOURTS-cofc-1_23-vv-01078-0 Date issued/filed: 2024-05-06 Pages: 2 Docket text: PUBLIC ORDER/RULING (Originally filed: 04/05/2024) regarding 22 Ruling on Entitlement Signed by Chief Special Master Brian H. Corcoran. (ppa) Service on parties made. -------------------------------------------------------------------------------- Case 1:23-vv-01078-UNJ Document 24 Filed 05/06/24 Page 1 of 2 In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 23-1078V DEBRA A. SCHILLER, Chief Special Master Corcoran Petitioner, v. Filed: April 5, 2024 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Ramon Rodriguez, III, Sands Anderson, PC, Richmond, VA, for Petitioner. Sarah Christina Duncan, U.S. Department of Justice, Washington, DC, for Respondent. RULING ON ENTITLEMENT1 On July 13, 2023, Debra A. Schiller 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 the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. The case was assigned to the Special Processing Unit of the Office of Special Masters. On April 5, 2024, Respondent filed his Rule 4(c) report in which he concedes that Petitioner is entitled to compensation in this case. Respondent’s Rule 4(c) Report at 1. Specifically, Respondent agrees that Petitioner’s alleged injury is consistent with SIRVA as defined by the Vaccine Injury Table. Id. at 6 (citing 42 C.F.R. §§ 100.3(a), (c)(10)). 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 1:23-vv-01078-UNJ Document 24 Filed 05/06/24 Page 2 of 2 Respondent further agrees that Petitioner has satisfied all legal prerequisites for compensation under the Vaccine Act. Id. In view of Respondent’s position and the evidence of record, I find that Petitioner is entitled to compensation. IT IS SO ORDERED. s/Brian H. Corcoran Brian H. Corcoran Chief Special Master 2 ================================================================================ DOCUMENT 2: USCOURTS-cofc-1_23-vv-01078-cl-extra-10735393 Date issued/filed: 2024-05-06 Pages: 1 Docket text: Supplementary opinion from CourtListener cluster 10268803 -------------------------------------------------------------------------------- In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 23-1078V DEBRA A. SCHILLER, Chief Special Master Corcoran Petitioner, v. Filed: April 5, 2024 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Ramon Rodriguez, III, Sands Anderson, PC, Richmond, VA, for Petitioner. Sarah Christina Duncan, U.S. Department of Justice, Washington, DC, for Respondent. RULING ON ENTITLEMENT1 On July 13, 2023, Debra A. Schiller 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 the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. The case was assigned to the Special Processing Unit of the Office of Special Masters. On April 5, 2024, Respondent filed his Rule 4(c) report in which he concedes that Petitioner is entitled to compensation in this case. Respondent’s Rule 4(c) Report at 1. Specifically, Respondent agrees that Petitioner’s alleged injury is consistent with SIRVA as defined by the Vaccine Injury Table. Id. at 6 (citing 42 C.F.R. §§ 100.3(a), (c)(10)). 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). Respondent further agrees that Petitioner has satisfied all legal prerequisites for compensation under the Vaccine Act. Id. In view of Respondent’s position and the evidence of record, I find that Petitioner is entitled to compensation. IT IS SO ORDERED. s/Brian H. Corcoran Brian H. Corcoran Chief Special Master 2 ================================================================================ DOCUMENT 3: USCOURTS-cofc-1_23-vv-01078-1 Date issued/filed: 2024-09-04 Pages: 5 Docket text: PUBLIC DECISION (Originally filed: 07/30/2024) regarding 29 DECISION Stipulation/Proffer Signed by Chief Special Master Brian H. Corcoran. (ppa) Service on parties made. -------------------------------------------------------------------------------- Case 1:23-vv-01078-UNJ Document 33 Filed 09/04/24 Page 1 of 5 In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 23-1078V DEBRA A. SCHILLER, Chief Special Master Corcoran Petitioner, v. Filed: July 30, 2024 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Ramon Rodriguez, III, Sands Anderson, PC, Richmond, VA, for Petitioner. Sarah Christina Duncan, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON DAMAGES1 On July 13, 2023, Debra A. Schiller 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 the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. The case was assigned to the Special Processing Unit of the Office of Special Masters. On April 5, 2024, a Ruling on Entitlement was issued, finding Petitioner entitled to compensation for a SIRVA. On July 29, 2024, Respondent filed a Proffer on award of compensation (“Proffer”). Respondent represented that Petitioner agrees with the 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-01078-UNJ Document 33 Filed 09/04/24 Page 2 of 5 proffered award. Id. at 1 – 2. 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 the following compensation: A lump sum of $159,460.89 (representing $155,000.00 for pain and suffering, $650.77 for past unreimbursable expenses, and $3,810.12 for past lost wages) in the form of a check payable to Petitioner. Proffer at 1 – 2. This amount represents compensation for all damages that would be available under Section 15(a). Id. at 2. 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-01078-UNJ Document 33 Filed 09/04/24 Page 3 of 5 IN THE UNITED STATES COURT OF FEDERAL CLAIMS OFFICE OF SPECIAL MASTERS ) DEBRA A. SCHILLER, ) ) Petitioner, ) ) No. 23-1078V v. ) Chief Special Master Corcoran ) ECF SECRETARY OF HEALTH AND HUMAN ) SERVICES, ) ) Respondent. ) ) RESPONDENT’S PROFFER ON AWARD OF COMPENSATION On July 13, 2023, Debra A. Schiller (“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 Table shoulder injury related to vaccine administration (“SIRVA”), as the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. On April 5, 2024, the Secretary of Health and Human Services (“respondent”) filed a Rule 4(c) Report recommending that compensation be awarded for SIRVA, and the Chief Special Master issued a Ruling on Entitlement finding petitioner entitled to compensation the same day. ECF No. 21; ECF No. 22. I. Items of Compensation A. Pain and Suffering Respondent proffers that petitioner should be awarded $155,000.00 in actual pain and suffering. Petitioner agrees. Case 1:23-vv-01078-UNJ Document 33 Filed 09/04/24 Page 4 of 5 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 $650.77. See 42 U.S.C. § 300aa- 15(a)(1)(B). Petitioner agrees. C. Lost Wages Evidence supplied by petitioner documents that she incurred past lost wages related to her vaccine-related injury. Respondent proffers that petitioner should be awarded past lost wages in the amount of $3,810.12. See 42 U.S.C. § 300aa-15(a)(3)(A). Petitioner agrees. These amounts represent all elements of compensation to which petitioner is entitled under 42 U.S.C. § 300aa-15(a). Petitioner agrees. II. Form of the Award Petitioner is a competent adult. Evidence of guardianship is not required in this case. Respondent recommends that the compensation provided to petitioner 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 following1: a lump sum payment of $159,460.89, representing compensation for pain and suffering ($155,000.00), past unreimbursable expenses ($650.77), and past lost wages ($3,810.12), in the form of a check payable to petitioner, Debra A. Schiller. 1 Should petitioner die prior to entry of judgment, the parties reserve the right to move the Court for appropriate relief. In particular, respondent would oppose any award for future lost earnings and future pain and suffering. 2 Case 1:23-vv-01078-UNJ Document 33 Filed 09/04/24 Page 5 of 5 III. Summary of Recommended Payments Following Judgment Lump sum payable to petitioner, Debra A. Schiller: $159,460.89 Respectfully submitted, BRIAN M. BOYNTON Principal Deputy Assistant Attorney General C. SALVATORE D’ALESSIO Director Torts Branch, Civil Division HEATHER L. PEARLMAN Deputy Director Torts Branch, Civil Division LARA A. ENGLUND Assistant Director Torts Branch, Civil Division s/ Sarah C. Duncan SARAH C. DUNCAN 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) 514-9729 Email: sarah.c.duncan@usdoj.gov DATED: July 29, 2024 3 ================================================================================ DOCUMENT 4: USCOURTS-cofc-1_23-vv-01078-cl-extra-10734314 Date issued/filed: 2024-09-04 Pages: 1 Docket text: Supplementary opinion from CourtListener cluster 10267724 -------------------------------------------------------------------------------- In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 23-1078V DEBRA A. SCHILLER, Chief Special Master Corcoran Petitioner, v. Filed: July 30, 2024 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Ramon Rodriguez, III, Sands Anderson, PC, Richmond, VA, for Petitioner. Sarah Christina Duncan, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON DAMAGES1 On July 13, 2023, Debra A. Schiller 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 the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. The case was assigned to the Special Processing Unit of the Office of Special Masters. On April 5, 2024, a Ruling on Entitlement was issued, finding Petitioner entitled to compensation for a SIRVA. On July 29, 2024, Respondent filed a Proffer on award of compensation (“Proffer”). Respondent represented that Petitioner agrees with the 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). proffered award. Id. at 1 – 2. 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 the following compensation: A lump sum of $159,460.89 (representing $155,000.00 for pain and suffering, $650.77 for past unreimbursable expenses, and $3,810.12 for past lost wages) in the form of a check payable to Petitioner. Proffer at 1 – 2. This amount represents compensation for all damages that would be available under Section 15(a). Id. at 2. 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 IN THE UNITED STATES COURT OF FEDERAL CLAIMS OFFICE OF SPECIAL MASTERS ) DEBRA A. SCHILLER, ) ) Petitioner, ) ) No. 23-1078V v. ) Chief Special Master Corcoran ) ECF SECRETARY OF HEALTH AND HUMAN ) SERVICES, ) ) Respondent. ) ) RESPONDENT’S PROFFER ON AWARD OF COMPENSATION On July 13, 2023, Debra A. Schiller (“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 Table shoulder injury related to vaccine administration (“SIRVA”), as the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. On April 5, 2024, the Secretary of Health and Human Services (“respondent”) filed a Rule 4(c) Report recommending that compensation be awarded for SIRVA, and the Chief Special Master issued a Ruling on Entitlement finding petitioner entitled to compensation the same day. ECF No. 21; ECF No. 22. I. Items of Compensation A. Pain and Suffering Respondent proffers that petitioner should be awarded $155,000.00 in actual pain and suffering. 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 $650.77. See 42 U.S.C. § 300aa- 15(a)(1)(B). Petitioner agrees. C. Lost Wages Evidence supplied by petitioner documents that she incurred past lost wages related to her vaccine-related injury. Respondent proffers that petitioner should be awarded past lost wages in the amount of $3,810.12. See 42 U.S.C. § 300aa-15(a)(3)(A). Petitioner agrees. These amounts represent all elements of compensation to which petitioner is entitled under 42 U.S.C. § 300aa-15(a). Petitioner agrees. II. Form of the Award Petitioner is a competent adult. Evidence of guardianship is not required in this case. Respondent recommends that the compensation provided to petitioner 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 following1: a lump sum payment of $159,460.89, representing compensation for pain and suffering ($155,000.00), past unreimbursable expenses ($650.77), and past lost wages ($3,810.12), in the form of a check payable to petitioner, Debra A. Schiller. 1 Should petitioner die prior to entry of judgment, the parties reserve the right to move the Court for appropriate relief. In particular, respondent would oppose any award for future lost earnings and future pain and suffering. 2 III. Summary of Recommended Payments Following Judgment Lump sum payable to petitioner, Debra A. Schiller: $159,460.89 Respectfully submitted, BRIAN M. BOYNTON Principal Deputy Assistant Attorney General C. SALVATORE D’ALESSIO Director Torts Branch, Civil Division HEATHER L. PEARLMAN Deputy Director Torts Branch, Civil Division LARA A. ENGLUND Assistant Director Torts Branch, Civil Division s/ Sarah C. Duncan SARAH C. DUNCAN 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) 514-9729 Email: sarah.c.duncan@usdoj.gov DATED: July 29, 2024 3 ================================================================================ DOCUMENT 5: USCOURTS-cofc-1_23-vv-01078-cl-extra-10844651 Date issued/filed: 2025-04-14 Pages: 1 Docket text: Supplementary opinion from CourtListener cluster 10378063 -------------------------------------------------------------------------------- In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 23-1078V DEBRA A. SCHILLER, Chief Special Master Corcoran Petitioner, v. Filed: March 13, 2025 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Ramon Rodriguez, III, Sands Anderson, Richmond, VA, for Petitioner. Sarah Christina Duncan, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON ATTORNEY’S FEES AND COSTS 1 On July 13, 2023, Debra A. Schiller 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 the result of an influenza (“flu”) vaccination received on October 14, 2021. Petition at 1. On July 30, 2024, I issued a decision awarding compensation to Petitioner based on Respondent’s proffer. ECF No. 29. Petitioner has now filed a motion for attorney’s fees and costs, requesting an award of $57,749.04 (representing $52,831.50 in fees plus $4,917.54 in costs). Motion for 1Because 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). Attorneys’ Fees and Costs (“Motion”) filed November 27, 2024, ECF No. 34. Furthermore, Petitioner filed a signed statement representing that Petitioner incurred no personal out- of-pocket expenses. ECF No. 34-1. Respondent reacted to the motion on December 3, 2024, indicating that he is satisfied the statutory requirements for an award of attorneys’ fees and costs are met in this case but deferring resolution of the amount to be awarded to my discretion. Response to Motion at 2-4, ECF No. 36. Petitioner filed a reply requesting an award of fees and costs as indicated in the Motion. ECF No. 37. I have reviewed the billing records submitted with Petitioner’s request. In my experience, the request appears reasonable, and I find no cause to reduce the requested hours or rates. Furthermore, Petitioner has provided supporting documentation for all claimed costs. ECF No. 34-2. Respondent offered no specific objection to the rates or amounts sought. I find the requested costs reasonable and hereby award them in full. The Vaccine Act permits an award of reasonable attorney’s fees and costs for successful claimants. Section 15(e). Accordingly, I hereby GRANT Petitioner’s Motion for attorney’s fees and costs. Petitioner is awarded attorneys’ fees and costs in the total amount of $57,749.04 (representing $52,831.50 for attorneys’ fees and $4,917.54 for attorneys’ costs) to be paid through an ACH deposit to petitioner’s counsel’s IOLTA account for prompt disbursement. In the absence of a timely-filed motion for review (see Appendix B to the Rules of the Court), the Clerk of Court shall 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), the parties may expedite entry of judgment by filing a joint notice renouncing their right to seek review. 2