VICP Registry Case Source Bundle Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_24-vv-01790 Package ID: USCOURTS-cofc-1_24-vv-01790 Petitioner: Tyronda Roberson Filed: 2024-10-31 Decided: 2026-01-16 Vaccine: influenza Vaccination date: 2023-10-02 Condition: shoulder injury related to vaccine administration (SIRVA) Outcome: compensated Award amount USD: 40115.22 AI-assisted case summary: On October 31, 2024, Tyronda Roberson filed a petition alleging that an influenza vaccine administered on October 2, 2023 caused a shoulder injury related to vaccine administration. Respondent denied that Ms. Roberson sustained a SIRVA as defined in the Vaccine Injury Table, denied that the vaccine caused her alleged shoulder injury or any other injury, and denied that her current condition was a vaccine-related sequela. The public stipulation does not describe onset, treatment, imaging, therapy, injections, or functional limitations. On January 16, 2026, Chief Special Master Brian H. Corcoran adopted the parties' stipulation and awarded $40,000.00 through counsel's IOLTA account plus $115.22 for a Wisconsin ForwardHealth Medicaid lien, for a total of $40,115.22. Theory of causation field: Influenza vaccine October 2, 2023 allegedly causing SIRVA; adult, exact age not stated. COMPENSATED by stipulation. Respondent denied Table SIRVA, causation, and sequelae; public text lacks clinical detail. Award $40,000 petitioner + $115.22 Wisconsin ForwardHealth lien = $40,115.22. Chief SM Brian H. Corcoran; petition October 31, 2024; decision January 16, 2026. Public staged source text: ================================================================================ DOCUMENT 1: USCOURTS-cofc-1_24-vv-01790-0 Date issued/filed: 2026-02-17 Pages: 8 Docket text: PUBLIC DECISION (Originally filed: 01/16/2026) regarding 25 DECISION Stipulation/Proffer. Signed by Chief Special Master Brian H. Corcoran. (cr) Service on parties made. -------------------------------------------------------------------------------- Case 1:24-vv-01790-UNJ Document 31 Filed 02/17/26 Page 1 of 8 In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 24-1790V TYRONDA ROBERSON, Chief Special Master Corcoran Petitioner, Filed: January 16, 2026 v. SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Jonathan Joseph Svitak, Shannon Law Group, P.C., Woodridge, IL, for Petitioner. Alyssa M. Petroff, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON JOINT STIPULATION1 On October 31, 2024, Tyronda Roberson 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 Table injury - shoulder injury related to vaccine administration (“SIRVA”) as a result of the administration of her October 2, 2023 influenza (“flu”) vaccination. Petition at 1; Stipulation, filed January 15, 2026, at ¶¶ 1-2, 4. Petitioner further alleges that she received the vaccine in the United States, that she suffered the residual effects of her injury for more than six months, and that there has been no prior award or settlement of a civil action on her behalf as a result of her injury. Stipulation at ¶¶ 3-5; see Petition at ¶¶ 2, 15, 18-19. “Respondent denies that [P]etitioner sustained a SIRVA, as defined in the Table; denies that the vaccine caused [P]etitioner’s alleged shoulder injury, or any other injury; and denies that her current condition is a sequela of a vaccine-related injury.” Stipulation at ¶ 6. 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-01790-UNJ Document 31 Filed 02/17/26 Page 2 of 8 Nevertheless, on January 15, 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,3 I award the following compensation: 1. A lump sum of $40,000.00, to be paid through an ACH deposit to Petitioner’s counsel’s IOLTA account for prompt disbursement to Petitioner; and 2. A lump sum payment of $115.22, representing compensation for satisfaction of the Wisconsin Forward Health Medicaid lien, to be paid through an ACH deposit to Petitioner's counsel's IOLTA account for prompt disbursement to: Optum P.O. Box 182642 Columbus, OH 43218-2643 Tax ID: 41-1858498 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 “R Sign” “Envelope Data” form at page seven of the parties’ Stipulation has been omitted from the attached copy. 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-01790-UNJ Document 31 Filed 02/17/26 Page 3 of 8 IN THE UNITED STATES COURT OF FEDERAL CLAIMS OFFICE OF SPECIAL MASTERS TYRONDA ROBERSON, Petitioner, No. 24-1790V V. Chief Special Master Corcoran ECF SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. STIPULATION The parties hereby stipulate to the following matters: l. Tyronda Roberson, 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 the influenza vaccine, which vaccine is contained in the Vaccine Injury Table (the "Table"), 42 C.F.R. § 100.3(a). 2. Petitioner received the influenza vaccination in her right arm on October 2, 2023. 3. The vaccine was administered within the United States. 4. Petitioner alleges that she suffered a Shoulder Injury Related to Vaccine Administration ("SIRVA") as a result of receiving the influenza vaccine within the Table time frame, and that she experienced residual effects of this 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 her behalf as a result of her condition. :NV36397497-5391-8AFF-2639-DBDD )1/08/202618:45 PM UTC Case 1:24-vv-01790-UNJ Document 31 Filed 02/17/26 Page 4 of 8 6. Respondent denies that petitioner sustained a SIRVA, as defined in the Table; 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-21 (a)(l ), the Secretary of Health and Human Services will issue the following compensation payments: a. A lump sum payment of $40,000.00 to be paid through an ACH deposit to petitioner's counsel's IOLTA account for prompt disbursement to petitioner, Tyronda Roberson; and b. A lump sum payment of $115.22, 1 represeotingcompensationfor satisfaction of the Wisconsin Forward Health Medicaid lien, to be paid through an ACH deposit to petitioner's counsel's IOLTA account for prompt disbursement to: Optum P.O. Box 182642 Columbus, OH 43218-2643 Tax JD: 41-1858498 1 This amount represents fu)l satisfaction ofa ny right of subrogation, assignment, claim, lien, or cause of action the State of Wisconsin may have against any individual as a result of any Medicaid payments the State of Wisconsin or UnitedHealthcare Community Plan has made to or on behalf of Tyronda Roberson as a result of her alleged vaccine-related injury suffered on or about October 2, 2023, under Title XIX of the Social Security Act, see 42 U.S.C. § 300aa-l S(g), (b). 2 :NV363974 97-5391-BAFF-2639-D8OD )1/08/202618:45 PM UTC Case 1:24-vv-01790-UNJ Document 31 Filed 02/17/26 Page 5 of 8 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-2 l (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. 10. 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 under42 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 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 of this Stipulation, and any amounts awarded pursuant to paragraph 9 of this Stipulation, will be made in accordance with 42 U.S.C. § 3()0aa-l 5(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 of4 2 U.S.C. § 300aa-15(a) and (d), and subject to the conditions of 42 U.S.C. §§ 300aa-15(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, causes of action (including 3 :NV363974 97-5391-BAFF-2639-DBDD )1/08/202618:45 PM UTC Case 1:24-vv-01790-UNJ Document 31 Filed 02/17/26 Page 6 of 8 agreements,judgments, claims, damages, loss ofs ervices, 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 influenza vaccine administered on or about October 2, 2023, as alleged by petitioner in a petition for vaccine compensation filed on October 31, 2024, in the United States Court of Federal Claims as petition No. 24-1790V. 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 decision that is in complete confonnity 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. 4 :NV363974 97-5391-BAFF-2639-O8DO )1/08/2026 18:45 PM UTC Case 1:24-vv-01790-UNJ Document 31 Filed 02/17/26 Page 7 of 8 17. This Stipulation shall not be construed as an admission by the United States or the Secretary of Health and Human Services that the influenza vaccine caused petitioner to suffer a shoulder injury or her current disabilities, or any other injury or condition, or that petitioner sustained 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 5 :NV363974 97-5391-BAFF-2639-DBDD )1/08/202618:45 PM UTC Case 1:24-vv-01790-UNJ Document 31 Filed 02/17/26 Page 8 of 8 Respectfully submitted, PETITIONER: TYRONDA ROBERSON ATTORNEY OF RECORD FOR AUTHORIZED REPRESENTATIVE PETITIONER: OF THE ATTORNEY GENERAL: ~~~~ HEATHER L. PEARLMAN Shannon • aw Group, . . Deputy Director 6825 Hobson Valley Drive, Suite l O1 Torts Branch Woodridge, IL 60517 Civil Division (312) 578-9501 U.S. Department of Justice E-mail: jsvitak@shannonlawgroup.com P.O. Box 146 Benjamin Franklin Station Washington, DC 20044-0146 AUTHORIZED REPRESENTATIVE ATTORNEY OF RECORD FOR OF THE SECRETARY OF HEAL TH RESPONDENT: AND HUMAN SERVICES: Jeffrey S. Digitally signed by Jeffrey S. Beach -S Beach-5 Date: 2026.01.06 -os·oo· for 09:41 :49 CAPT. GEORGE REED GRIMES, MD, :MPH Director, Division of Injury Trial Attorney 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 Health Benjamin Franklin Station and Human Services Washington. DC 20044-0146 5600 Fishers Lane, 14W-18 Te1: (202) 307-3852 Rockville, MD 20857 E-mail: Alyssa.Petroff2@usdoj.gov 6 =NV36397 497 -5391-BAFF-2639-DBDD )1/06/202618:45 PM UTC ================================================================================ DOCUMENT 2: USCOURTS-cofc-1_24-vv-01790-cl-extra-11262267 Date issued/filed: 2026-02-17 Pages: 1 Docket text: Supplementary opinion from CourtListener cluster 10795610 -------------------------------------------------------------------------------- In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 24-1790V TYRONDA ROBERSON, Chief Special Master Corcoran Petitioner, Filed: January 16, 2026 v. SECRETARY OF HEALTH AND HUMAN SERVICES, Respondent. Jonathan Joseph Svitak, Shannon Law Group, P.C., Woodridge, IL, for Petitioner. Alyssa M. Petroff, U.S. Department of Justice, Washington, DC, for Respondent. DECISION ON JOINT STIPULATION 1 On October 31, 2024, Tyronda Roberson 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 Table injury - shoulder injury related to vaccine administration (“SIRVA”) as a result of the administration of her October 2, 2023 influenza (“flu”) vaccination. Petition at 1; Stipulation, filed January 15, 2026, at ¶¶ 1-2, 4. Petitioner further alleges that she received the vaccine in the United States, that she suffered the residual effects of her injury for more than six months, and that there has been no prior award or settlement of a civil action on her behalf as a result of her injury. Stipulation at ¶¶ 3-5; see Petition at ¶¶ 2, 15, 18-19. “Respondent denies that [P]etitioner sustained a SIRVA, as defined in the Table; denies that the vaccine caused [P]etitioner’s alleged shoulder injury, or any other injury; and denies that her current condition is a sequela of a vaccine-related injury.” Stipulation at ¶ 6. 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). Nevertheless, on January 15, 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, 3 I award the following compensation: 1. A lump sum of $40,000.00, to be paid through an ACH deposit to Petitioner’s counsel’s IOLTA account for prompt disbursement to Petitioner; and 2. A lump sum payment of $115.22, representing compensation for satisfaction of the Wisconsin Forward Health Medicaid lien, to be paid through an ACH deposit to Petitioner's counsel's IOLTA account for prompt disbursement to: Optum P.O. Box 182642 Columbus, OH 43218-2643 Tax ID: XX-XXXXXXX 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 “R Sign” “Envelope Data” form at page seven of the parties’ Stipulation has been omitted from the attached copy. 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 TYRONDA ROBERSON, Petitioner, V. No. 24-1790V Chief Special Master Corcoran SECRETARY OF HEALTH AND ECF HUMAN SERVICES, Respondent. STIPULATION The parties hereby stipulate to the following matters: l . Tyronda Roberson, 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 the influenza vaccine, which vaccine is contained in the Vaccine Injury Table (the "Table"), 42 C.F.R. § 100.3(a). 2. Petitioner received the influenza vaccination in her right arm on October 2, 2023. 3. The vaccine was administered within the United States. 4. Petitioner alleges that she suffered a Shoulder Injury Related to Vaccine Administration ("SIRVA") as a result of receiving the influenza vaccine within the Table time frame, and that she experienced residual effects of this 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 her behalf as a result of her condition. :NV36397497-5391-8AFF-2639-DBDD )1/08/202618:45 PM UTC 6. Respondent denies that petitioner sustained a SIRVA, as defined in the Table; 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 ofjudgment 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-21 (a)(l ), the Secretary of Health and Human Services will issue the following compensation payments: a. A lump sum payment of $40,000.00 to be paid through an ACH deposit to petitioner's counsel's IOLTA account for prompt disbursement to petitioner, Tyronda Roberson; and b. A lump sum payment of $115.22, 1 represeotingcompensationfor satisfaction of the Wisconsin Forward Health Medicaid lien, to be paid through an ACH deposit to petitioner's counsel's IOLTA account for prompt disbursement to: Optum P.O. Box 182642 Columbus, OH 43218-2643 Tax JD: XX-XXXXXXX 1 This amount represents fu)l satisfaction ofany right of subrogation, assignment, claim, lien, or cause of action the State of Wisconsin may have against any individual as a result of any Medicaid payments the State of Wisconsin or UnitedHealthcare Community Plan has made to or on behalf of Tyronda Roberson as a result of her alleged vaccine-related injury suffered on or about October 2, 2023, under Title XIX of the Social Security Act, see 42 U.S.C. § 300aa-l S(g), (b). 2 :NV36397497-5391-BAFF-2639-D8OD )1/08/202618:45 PM UTC 9. As soon as practicable after the entry ofjudgment 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-2 l (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. 10. 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 under42 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 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 of this Stipulation, and any amounts awarded pursuant to paragraph 9 of this Stipulation, will be made in accordance with 42 U.S.C. § 3()0aa-l 5(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 of42 U.S.C. § 300aa-15(a) and (d), and subject to the conditions of 42 U.S.C. §§ 300aa-15(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, causes of action (including 3 :NV36397497-5391-BAFF-2639-DBDD )1/08/202618:45 PM UTC agreements,judgments, claims, damages, loss ofservices, 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 influenza vaccine administered on or about October 2, 2023, as alleged by petitioner in a petition for vaccine compensation filed on October 31, 2024, in the United States Court of Federal Claims as petition No. 24-1790V. 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 decision that is in complete confonnity 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. 4 :NV36397497-5391-BAFF-2639-O8DO )1/08/2026 18:45 PM UTC 17. This Stipulation shall not be construed as an admission by the United States or the Secretary of Health and Human Services that the influenza vaccine caused petitioner to suffer a shoulder injury or her current disabilities, or any other injury or condition, or that petitioner sustained 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 5 :NV36397497-5391-BAFF-2639-DBDD )1/08/202618:45 PM UTC Respectfully submitted, PETITIONER: TYRONDA ROBERSON ATTORNEY OF RECORD FOR AUTHORIZED REPRESENTATIVE PETITIONER: OF THE ATTORNEY GENERAL: ~~~~ HEATHER L. PEARLMAN Shannon • aw Group, . . Deputy Director 6825 Hobson Valley Drive, Suite l O1 Torts Branch Woodridge, IL 60517 Civil Division (312) 578-9501 U.S. Department of Justice E-mail: jsvitak@shannonlawgroup.com P.O. Box 146 Benjamin Franklin Station Washington, DC 20044-0146 AUTHORIZED REPRESENTATIVE ATTORNEY OF RECORD FOR OF THE SECRETARY OF HEALTH RESPONDENT: AND HUMAN SERVICES: Digitally signed by Jeffrey S. Jeffrey S. Beach -S Date: 2026.01.06 Beach-5 09:41 :49 -os·oo· for CAPT. GEORGE REED GRIMES, MD, :MPH Director, Division of Injury Trial Attorney 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 Health Benjamin Franklin Station and Human Services Washington. DC 20044-0146 5600 Fishers Lane, 14W-18 Te1: (202) 307-3852 Rockville, MD 20857 E-mail: Alyssa.Petroff2@usdoj.gov 6 =NV36397497-5391-BAFF-2639-DBDD )1/06/202618:45 PM UTC