VICP Registry Case Source Bundle Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_24-vv-01214 Package ID: USCOURTS-cofc-1_24-vv-01214 Petitioner: Diana Alvarado Filed: 2024-08-08 Decided: 2026-01-15 Vaccine: influenza and tetanus, diphtheria, and acellular pertussis (Tdap) Vaccination date: 2023-08-22 Condition: Guillain-Barre syndrome (GBS) and/or chronic inflammatory demyelinating polyneuropathy (CIDP) Outcome: compensated Award amount USD: 90693.72 AI-assisted case summary: On August 8, 2024, Diana Alvarado filed a petition alleging that influenza and Tdap vaccines administered in her left deltoid on August 22, 2023 caused Guillain-Barre syndrome, or alternatively GBS and/or chronic inflammatory demyelinating polyneuropathy. The stipulation also notes a later October 2, 2023 COVID-19 vaccination with a flu vaccine, and it addresses waiver of any CICP claim as part of the settlement. Respondent denied that Ms. Alvarado sustained a Table GBS injury, denied that her alleged GBS, CIDP, or residual effects were caused in fact by the flu or Tdap vaccines, and denied that the vaccines caused any other injury. The public stipulation does not describe the first neurologic symptom, hospitalization, testing, treatment, rehabilitation, or residual limitations. On January 15, 2026, Chief Special Master Brian H. Corcoran adopted the parties' stipulation and awarded $90,693.72 through counsel's IOLTA account. Theory of causation field: Influenza and Tdap vaccines August 22, 2023 allegedly causing Table GBS or GBS/CIDP; adult, exact age not stated. COMPENSATED by stipulation. Respondent denied Table GBS, causation of GBS/CIDP/residual effects, and other injury. Public text lacks neurologic details; stipulation also references later COVID/flu vaccination and CICP waiver. Award $90,693.72. Chief SM Brian H. Corcoran; petition August 8, 2024; decision January 15, 2026. Public staged source text: ================================================================================ DOCUMENT 1: USCOURTS-cofc-1_24-vv-01214-0 Date issued/filed: 2026-02-17 Pages: 8 Docket text: PUBLIC DECISION (Originally filed: 01/15/2026) regarding 32 DECISION Stipulation/Proffer, Signed by Chief Special Master Brian H. Corcoran. (nh) Service on parties made. -------------------------------------------------------------------------------- Case 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 1 of 8 In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 24-1214V DIANA ALVARADO, Chief Special Master Corcoran Petitioner, v. Filed: January 15, 2026 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. William E. Cochran, Jr., Black McLaren Jones Ryland & Griffee, P.C., Memphis, TN , for Petitioner. Alexis B. Babcock, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON JOINT STIPULATION1 On August 8, 2024, Diana Alvarado 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 Guillain-Barré Syndrome (“GBS”), a defined Table injury, or in the alternative, a caused-in-fact GBS and/or CIDP, after receiving an influenza (“flu”) vaccine on August 22, 2023. Petition at 1, ¶¶ 2, 18; Stipulation, filed Jan. 13, 2026, ¶¶ 1-2, 4. Petitioner further alleged that she received the vaccine within the United States, continues to suffer the residual effects of her GBS/CIDP illness more than six months, and that neither she nor any other party has filed a civil action or received compensation for her GBS/CIDP, alleged as vaccine-caused. Petition at ¶¶ 2, 16-17; Stipulation ¶¶ 3-5. “Respondent denies that [P]etitioner sustained a Table GBS injury; denies that [P]etitioner’s alleged GBS, CIDP or its residual effects were 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 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 2 of 8 caused-in-fact by the flu or Tdap[3] vaccines; and denies that the vaccines caused [P]etitioner any other injury or [Petitioner’s current condition.” Stipulation at ¶ 6. Nevertheless, on January 13, 2026, 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 $90,693.72, to be paid through an ACH deposit to Petitioner’s counsel’s IOLTA account for prompt disbursement to Petitioner. Stipulation at ¶ 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.4 IT IS SO ORDERED. s/Brian H. Corcoran Brian H. Corcoran Chief Special Master 3 The vaccine record in this case shows Petitioner also received a tetanus, diphtheria, acellular pertussis (“Tdap”) vaccine on August 22, 2023. Ex. 2 at 6. 4 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 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 3 of 8 IN THE UNITED STATES COURT OF FEDERAL CLAIMS OFFICE OF SPECIAL MASTERS DIANA ALVARADO, Petitioner, v. No. 24-1214V SECRETARY OF HEALTH AND Chief Special Master Corcoran HUMAN SERVICES, ECF Respondent. STIPULATION The parties hereby stipulate to the following matters: 1. Diana Alvarado ("petitioner") filed a petition for vaccine compensation under the National Vaccine Injury Compensation Program, 42 U.S.C. § 300aa-10 to 34 (the "Vaccine Program"). The petition seeks compensation for injuries allegedly related to petitioner's receipt of an influenza ("flu") and Tetanus diphtheria acellular pertussis ("Tdap") vaccine, which vaccine is contained in the Vaccine Injury Table (the "Table"), 42 C.F .R. § 100.3(a). 2. Petitioner received flu and Tdap vaccines in her left deltoid on August 22, 2023.1 3. The vaccines were administered within the United States. 1 On October 2, 2023, petitioner received a COVID-19 vaccine in her left deltoid, together with a respiratory syncytial virus ("RSV") vaccine. RSV vaccines and vaccines against COVID-19 are not contained in the Vaccine Injury Table. See 42 U.S.C. § 300aa-14 and 42 C.F.R. § 100.3(a). Pursuant to the declaration issued by the Secretary of Health and Human Services under the Public Readiness and Emergency Preparedness Act (42 U.S.C. §§ 247d-6d, 247d-6e), claims for alleged injuries from COVID-19 countermeasures, including vaccines, may be compensable under the Countermeasures Injury Compensation Program ("CICP"). See 85 Fed. Reg. 15198, 15202 (March 17, 2020). Case 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 4 of 8 4. Petitioner alleges that she sustained a Table injury of Guillain-Barre Syndrome ("GBS") following receipt of the flu vaccine. In the alternative, petitioner alleged that she suffered from GBS and/or Chronic Inflammatory Demyelinating Polyneuropathy ("CIDP") that was caused in fact by her vaccinations. Petitioner further alleges that she suffered the residual effects of the alleged injury for more than six months. 5. Petitioner represents that there has been no prior award or settlement of a civil action for damages on petitioner's behalf as a result of the alleged injury. 6. Respondent denies that petitioner sustained a Table GBS injury; denies that petitioner's alleged GBS, CIDP or its residual effects were caused-in-fact by the flu or Tdap vaccines; and denies that the vaccines caused petitioner any other injury or petitioner's current condition. 7. Maintaining their above-stated positions, the parties nevertheless now agree that the issues between them shall be settled and that a decision should be entered awarding the compensation described in paragraph 8 of this Stipulation. 8. As soon as practicable after an entry of judgment reflecting a decision consistent with the terms of this Stipulation, and after petitioner has filed an election to receive compensation pursuant to 42 U.S.C. § 300aa-2 l (a)(l ), the Secretary of Health and Human Services will issue the following vaccine compensation payment: A lump sum payment of $90,693.72 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 42 U.S.C. § 300aa-15(a). 9. As soon as practicable after the entry of judgment on entitlement in this case, and after petitioner has filed both a proper and timely election to receive compensation pursuant to 42 U.S.C. § 300aa-21 (a)(l ), and an application, the parties will submit to further proceedings before 2 Case 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 5 of 8 the special master to award reasonable attorneys' fees and costs incurred in proceeding upon this petition. 10. Petitioner and petitioner's 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-l 5(g), to the extent that payment has been made or can reasonably be expected to be made under any State compensation programs, insurance policies, Federal or State health benefits programs ( other than Title XIX of the Social Security Act ( 42 U.S.C. § 1396 et seq.)), or by entities that provide health services on a pre-paid basis. 11. Payments made pursuant to paragraph 8 and any amounts awarded pursuant to paragraph 9 of this Stipulation will be made in accordance with 42 U.S.C. § 300aa-15(i), subject to the availability of sufficient statutory funds. 12. The parties and their attorneys further agree and stipulate that, except for any award for attorney's fees and litigation costs, and past unreimbursed expenses, the money provided pursuant to this Stipulation will be used solely for the benefit of petitioner as contemplated by a strict construction of 42 U.S.C. § 300aa-15(a) and (d), and subject to the conditions of 42 U.S.C. § 300aa-l 5(g) and (h). 13. In return for the payments described in paragraphs 8 and 9, petitioner, in petitioner's individual capacity, and on behalf of petitioner's heirs, executors, administrators, successors or assigns, (a) 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 hereafter could be timely brought in the Cou1t of Federal Claims, under the Vaccine Injury 3 Case 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 6 of 8 Compensation Program, 42 U. S.C. § 300aa-l O et seq., (i) 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 that may be alleged to have resulted from, the vaccinations administered on August 22, 2023, and (ii) that petitioner has had, now has, or hereafter may have with respect to the injury that gave rise to the petition for vaccine compensation in this case; and (b) waives any and all rights to any compensation that may be available under the Countermeasures Injury Compensation Program (CICP), 42 U.S.C. § 247d-6e (or an action under 42 U.S.C. § 247d-6d(d)), for a claim alleging that a covered countermeasure, including the COVID-19 vaccination administered on October 2, 2023, on its own or in combination with the flu or Tdap vaccinations administered on August 22, 2023, caused or seriously aggravated the injuries that were the subject of the petition for vaccine compensation filed in this case as petition 24-1214 V, including GBS or CIDP, for which petitioner will receive compensation pursuant to this Stipulation. If petitioner has such a claim currently pending with the CICP, petitioner hereby withdraws such claim for compensation in the CI CP. 2 If no claim for compensation has been filed in the CICP as of the date this Stipulation is filed, petitioner waives the right to file a claim as described in this paragraph for compensation in the CICP. 14. If petitioner should die prior to entry of judgment, this agreement shall be voidable upon proper notice to the Court on behalf of either or both of the parties. 15. If the special master fails to issue a decision in complete conformity with the terms of this Stipulation or if the Court of Federal Claims fails to enter judgment in conformity with a 2 After entry of judgment reflecting a decision consistent with the terms of this Stipulation, petitioner agrees that respondent will send this Stipulation to the CICP as evidence of petitioner's withdrawal of their CICP claim and waiver of any potential compensation under the CICP. 4 Case 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 7 of 8 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 flu or Tdap vaccines caused petitioner's alleged injury or any other injury or petitioner's current disabilities. 18. All rights and obligations of petitioner hereunder shall apply equally to petitioner's heirs, executors, administrators, successors, and/or assigns. END OF STIPULATION 5 Case 1:24-vv-01214-UNJ Document 36 Filed 02/17/26 Page 8 of 8 Respectfully submitted. PETITIONER: DIANA ALVA RADO /\. TTORNEY OF RECORD FOR AUTHORIZED REPRESENT/\ TIVE PETITIONER: OF THE ATTORNEY GENERAL: , JA, ~A'ef, ~--u.M ~ J WILLIAM E. COCI IRAN. J . HEATHER L. PEARUv1AN Black. i'vlclaren, Jones. Ryland, Griffee Deputy Director 530 Oak Court Drive Torts Branch Suite 360 Civil Division Memphis. TN 38117 U.S. Department of Justice (90 I) 762-0535 P.O. Box 146 \\·coehran@black1m;la,\·.com Benjamin Franklin Station \Vashington, DC 20044-0146 AUTHORIZED REPRESENTATIVE ATTORNEY OF RECORD FOR OF THE SECRETARY OF HEALTH RESPONDENT: AND IIU!v!AN SERVICES: Jeffrey S. Digitally signed by Jeffrey S. Bc.>ach -5 -S Beach Datc:2026.01.0609:12:29 A~~~ B&z~ -os·oo· for CAPT GEORGE REED GRIMES. MD. MPII Director, Division of Injury Assistant Director Compensation Programs Torts Branch Health Systems Bureau Civil Division Health Resources and Services U.S. Department of Justice Administration P.O. Box 146 U.S. Department of I Icalth Benjamin Franklin Station and Human Services Washington, DC 20044-0146 5600 Fishers Lane. 14\V-18 202-616-7678 Rockville. MD 20857 alexis.babcock@]usdoj.gov Dated: 6 ================================================================================ DOCUMENT 2: USCOURTS-cofc-1_24-vv-01214-cl-extra-11262287 Date issued/filed: 2026-02-17 Pages: 1 Docket text: Supplementary opinion from CourtListener cluster 10795630 -------------------------------------------------------------------------------- In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 24-1214V DIANA ALVARADO, Chief Special Master Corcoran Petitioner, v. Filed: January 15, 2026 SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. William E. Cochran, Jr., Black McLaren Jones Ryland & Griffee, P.C., Memphis, TN , for Petitioner. Alexis B. Babcock, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON JOINT STIPULATION1 On August 8, 2024, Diana Alvarado 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 Guillain-Barré Syndrome (“GBS”), a defined Table injury, or in the alternative, a caused-in-fact GBS and/or CIDP, after receiving an influenza (“flu”) vaccine on August 22, 2023. Petition at 1, ¶¶ 2, 18; Stipulation, filed Jan. 13, 2026, ¶¶ 1-2, 4. Petitioner further alleged that she received the vaccine within the United States, continues to suffer the residual effects of her GBS/CIDP illness more than six months, and that neither she nor any other party has filed a civil action or received compensation for her GBS/CIDP, alleged as vaccine-caused. Petition at ¶¶ 2, 16-17; Stipulation ¶¶ 3-5. “Respondent denies that [P]etitioner sustained a Table GBS injury; denies that [P]etitioner’s alleged GBS, CIDP or its residual effects were 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). caused-in-fact by the flu or Tdap[3] vaccines; and denies that the vaccines caused [P]etitioner any other injury or [Petitioner’s current condition.” Stipulation at ¶ 6. Nevertheless, on January 13, 2026, 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 $90,693.72, to be paid through an ACH deposit to Petitioner’s counsel’s IOLTA account for prompt disbursement to Petitioner. Stipulation at ¶ 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.4 IT IS SO ORDERED. s/Brian H. Corcoran Brian H. Corcoran Chief Special Master 3 The vaccine record in this case shows Petitioner also received a tetanus, diphtheria, acellular pertussis (“Tdap”) vaccine on August 22, 2023. Ex. 2 at 6. 4 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 DIANA ALVARADO, Petitioner, v. No. 24-1214V SECRETARY OF HEALTH AND Chief Special Master Corcoran HUMAN SERVICES, ECF Respondent. STIPULATION The parties hereby stipulate to the following matters: 1. Diana Alvarado ("petitioner") filed a petition for vaccine compensation under the National Vaccine Injury Compensation Program, 42 U.S.C. § 300aa-10 to 34 (the "Vaccine Program"). The petition seeks compensation for injuries allegedly related to petitioner's receipt of an influenza ("flu") and Tetanus diphtheria acellular pertussis ("Tdap") vaccine, which vaccine is contained in the Vaccine Injury Table (the "Tab le"), 42 C.F .R. § 100.3(a). 2. Petitioner received flu and Tdap vaccines in her left deltoid on August 22, 2023. 1 3. The vaccines were administered within the United States. 1 On October 2, 2023, petitioner received a COVID-19 vaccine in her left deltoid, together with a respiratory syncytial virus ("RSV") vaccine. RSV vaccines and vaccines against COVID-19 are not contained in the Vaccine Injury Table. See 42 U.S.C. § 300aa-14 and 42 C.F.R. § 100.3(a). Pursuant to the declaration issued by the Secretary of Health and Human Services under the Public Readiness and Emergency Preparedness Act (42 U.S.C. §§ 247d-6d, 247d-6e), claims for alleged injuries from COVID-19 countermeasures, including vaccines, may be compensable under the Countermeasures Injury Compensation Program ("CICP"). See 85 Fed. Reg. 15198, 15202 (March 17, 2020). 4. Petitioner alleges that she sustained a Table injury of Guillain-Barre Syndrome ("GBS") following receipt of the flu vaccine. In the alternative, petitioner alleged that she suffered from GBS and/or Chronic Inflammatory Demyelinating Polyneuropathy ("CIDP") that was caused in fact by her vaccinations. Petitioner further alleges that she suffered the residual effects of the alleged injury for more than six months. 5. Petitioner represents that there has been no prior award or settlement of a civil action for damages on petitioner's behalf as a result of the alleged injury. 6. Respondent denies that petitioner sustained a Table GBS injury; denies that petitioner's alleged GBS, CIDP or its residual effects were caused-in-fact by the flu or Tdap vaccines; and denies that the vaccines caused petitioner any other injury or petitioner' s current condition. 7. Maintaining their above-stated positions, the parties nevertheless now agree that the issues between them shall be settled and that a decision should be entered awarding the compensation described in paragraph 8 of this Stipulation. 8. As soon as practicable after an entry of judgment reflecting a decision consistent with the terms of this Stipulation, and after petitioner has filed an election to receive compensation pursuant to 42 U.S.C. § 300aa-2 l (a)(l ), the Secretary of Health and Human Services will issue the following vaccine compensation payment: A lump sum payment of $90,693.72 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 42 U.S.C. § 300aa-15(a). 9. As soon as practicable after the entry of judgment on entitlement in this case, and after petitioner has filed both a proper and timely election to receive compensation pursuant to 42 U.S.C. § 300aa-21 (a)(l ), and an application, the parties will submit to further proceedings before 2 the special master to award reasonable attorneys' fees and costs incurred in proceeding upon this petition. 10. Petitioner and petitioner's 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-l 5(g), to the extent that payment has been made or can reasonably be expected to be made under any State compensation programs, insurance policies, Federal or State health benefits programs (other than Title XIX of the Social Security Act (42 U.S.C. § 1396 et seq.)), or by entities that provide health services on a pre-paid basis. 11. Payments made pursuant to paragraph 8 and any amounts awarded pursuant to paragraph 9 of this Stipulation will be made in accordance with 42 U.S.C. § 300aa-15(i), subject to the availability of sufficient statutory funds. 12. The parties and their attorneys further agree and stipulate that, except for any award for attorney's fees and litigation costs, and past unreimbursed expenses, the money provided pursuant to this Stipulation will be used solely for the benefit of petitioner as contemplated by a strict construction of 42 U.S.C. § 300aa-15(a) and (d), and subject to the conditions of 42 U.S.C. § 300aa-l 5(g) and (h). 13. In return for the payments described in paragraphs 8 and 9, petitioner, in petitioner's individual capacity, and on behalf of petitioner's heirs, executors, administrators, successors or assigns, (a) 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 hereafter could be timely brought in the Cou1t of Federal Claims, under the Vaccine Injury 3 Compensation Program, 42 U.S.C. § 300aa-l Oet seq., (i) 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 that may be alleged to have resulted from, the vaccinations administered on August 22, 2023, and (ii) that petitioner has had, now has, or hereafter may have with respect to the injury that gave rise to the petition for vaccine compensation in this case; and (b) waives any and all rights to any compensation that may be available under the Countermeasures Injury Compensation Program (CICP), 42 U.S.C. § 247d-6e (or an action under 42 U.S.C. § 247d-6d(d)), for a claim alleging that a covered countermeasure, including the COVID-19 vaccination administered on October 2, 2023, on its own or in combination with the flu or Tdap vaccinations administered on August 22, 2023, caused or seriously aggravated the injuries that were the subject of the petition for vaccine compensation filed in this case as petition 24-1214 V, including GBS or CIDP, for which petitioner will receive compensation pursuant to this Stipulation. If petitioner has such a claim currently pending with the CICP, petitioner hereby withdraws such claim for compensation in the CI CP. 2 If no claim for compensation has been filed in the CICP as of the date this Stipulation is filed, petitioner waives the right to file a claim as described in this paragraph for compensation in the CICP. 14. If petitioner should die prior to entry of judgment, this agreement shall be voidable upon proper notice to the Court on behalf of either or both of the parties. 15. If the special master fails to issue a decision in complete conformity with the terms of this Stipulation or if the Court of Federal Claims fails to enter judgment in conformity with a 2 After entry of judgment reflecting a decision consistent with the terms of this Stipulation, petitioner agrees that respondent will send this Stipulation to the CICP as evidence of petitioner's withdrawal of their CICP claim and waiver of any potential compensation under the CICP. 4 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 flu or Tdap vaccines caused petitioner's alleged injury or any other injury or petitioner' s current disabilities. 18. All rights and obligations of petitioner hereunder shall apply equally to petitioner' s heirs, executors, administrators, successors, and/or assigns. END OF STIPULATION 5 Respectfully submitted. PETITIONER: DIANA ALVA RADO /\. TTORNEY OF RECORD FOR AUTHORIZED REPRESENT/\ TIVE PETITIONER: OF THE ATTORNEY GENERAL: , JA, ~A'ef, ~--u.M ~ J WILLIAM E. COCI IRAN. J . HEATHER L. PEARUv1AN Black. i'vlclaren, Jones. Ryland, Griffee Deputy Director 530 Oak Court Drive Torts Branch Suite 360 Civil Division Memphis. TN 38117 U.S. Department of Justice (90 I) 762-0535 P.O. Box 146 \\·coehran@black1m;la,\·.com Benjamin Franklin Station \Vashington, DC 20044-0146 AUTHORIZED REPRESENTATIVE ATTORNEY OF RECORD FOR OF THE SECRETARY OF HEALTH RESPONDENT: AND IIU!v!AN SERVICES: Digitally sign ed by Jeffr ey Jeffrey S. S. Bc.>ach -5 A~~~ B&z~ Beach -S Datc:2026.01.0609: 12:29 -os·oo· for CAPT GEORGE REED GRIMES. MD. MPII Director, Division of Injury Assistant Director Compensation Programs Torts Branch Health Systems Bureau Civil Division Health Resources and Services U.S. Department of Justice Administration P.O. Box 146 U.S. Department of I Icalth Benjamin Franklin Station and Human Services Washington, DC 20044-0146 5600 Fishers Lane. 14\V-18 202-616-7678 Rockville. MD 20857 alexis.babcock@]usdoj .gov Dated: 6