In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 24-965V
JESSICA MORA, Chief Special Master Corcoran
Petitioner, Filed: October 7, 2025 v.
SECRETARY OF HEALTH AND HUMAN SERVICES,
Respondent.
Elizabeth Hess, Shannon Law Group, Woodridge, IL, for Petitioner.
Adam Nemeth Muffett, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION ON JOINT STIPULATION1
On June 25, 2024, Jessica Mora 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 shoulder injury related to vaccine administration (“SIRVA”) as a result of his October 28, 2022 influenza (“flu”) vaccination. Petition at ¶¶ 2, 4, 38; Stipulation at ¶¶ 2, 4. Petitioner further alleges that she received her vaccination 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. Petition at ¶¶ 2, 38, 41; Stipulation at ¶¶ 3-5. “Respondent denies that [P]etitioner sustained a SIRVA Table Injury, denies that [P]etitioner’s alleged shoulder injury was caused-in-fact by the flu vaccine, and denies that the flu vaccine caused [P]etitioner any other injury or her current condition.” 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 October 7, 2025, the parties filed the attached joint stipulation, stating that a decision should be entered awarding compensation.3 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 $100,000.00, 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 final page of the parties’ stipulation, an e-signature verification, has been removed from the attached copy of the stipulation. 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
) JESSICA MORA, ) ) Petitioner, ) ) No . 24-965V (ECF) V. ) Chief Special Master Corcoran ) SECRETARY OF HEALTH ) AND HUMAN SERVICES, ) ) Respondent. )
STIPULATION
The parties hereby stipulate to the following matters:
1. Jessica Mora, petitioner, filed a petition for vaccine compensation under the National
Vaccine Injury Compensation Program, 42 U.S.C . § 300aa-10 to -34 ("Vaccine Program"). The
petition seeks compensation for injuries allegedly related to petitioner's receipt of the influenza
("flu") vaccine, which vaccine is contained in the Vaccine Injury Table ("Table"), 42 C.F.R.
§ 100.3(a).
2. Petitioner received the flu vaccination in her left shoulder on October 28, 2022.
3. The vaccine was administered within the United States.
4. Petitioner alleges that she suffered a Shoulder Injury Related to Vaccine
Administration ("SIRVA") within the time period set forth in the Table, 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.
ENV137834 74-6809-CECF-8464-CEAC 09/30/2025 13:50 PM UTC 6. Respondent denies that petitioner sustained a SIRVA Table Injury, denies that
petitioner's alleged shoulder inju1y was caused-in-fact by the flu vaccine, and denies that the flu
vaccine caused petitioner any other injury or her cunent condition.
7. Maintaining their above-stated positions, the patties neve1theless 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-21(a)(l), the Secretary of Health and Human Services will issue
the following vaccine compensation payment:
A lump sum payment of $100,000.00 to be paid through an ACH deposit to petitioner's counsel's IOLTA account for prompt disbursement to petitioner, Jessica Mora. This amount represents compensation for all damages that would be available under 42 U.S.C. § 300aa-l 5(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 pa1ties will submit to fmther proceedings before
the special master to award reasonable attorneys' fees and costs incmTed 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
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
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.
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In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 24-965V
JESSICA MORA, Chief Special Master Corcoran
Petitioner, Filed: October 7, 2025 v.
SECRETARY OF HEALTH AND HUMAN SERVICES,
Respondent.
Elizabeth Hess, Shannon Law Group, Woodridge, IL, for Petitioner.
Adam Nemeth Muffett, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION ON JOINT STIPULATION1
On June 25, 2024, Jessica Mora 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 shoulder injury related to vaccine administration (“SIRVA”) as a result of his October 28, 2022 influenza (“flu”) vaccination. Petition at ¶¶ 2, 4, 38; Stipulation at ¶¶ 2, 4. Petitioner further alleges that she received her vaccination 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. Petition at ¶¶ 2, 38, 41; Stipulation at ¶¶ 3-5. “Respondent denies that [P]etitioner sustained a SIRVA Table Injury, denies that [P]etitioner’s alleged shoulder injury was caused-in-fact by the flu vaccine, and denies that the flu vaccine caused [P]etitioner any other injury or her current condition.” 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 October 7, 2025, the parties filed the attached joint stipulation, stating that a decision should be entered awarding compensation.3 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 $100,000.00, 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 final page of the parties’ stipulation, an e-signature verification, has been removed from the attached copy of the stipulation. 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
) JESSICA MORA, ) ) Petitioner, ) ) No . 24-965V (ECF) V. ) Chief Special Master Corcoran ) SECRETARY OF HEALTH ) AND HUMAN SERVICES, ) ) Respondent. )
STIPULATION
The parties hereby stipulate to the following matters:
1. Jessica Mora, petitioner, filed a petition for vaccine compensation under the National
Vaccine Injury Compensation Program, 42 U.S.C . § 300aa-10 to -34 ("Vaccine Program"). The
petition seeks compensation for injuries allegedly related to petitioner's receipt of the influenza
("flu") vaccine, which vaccine is contained in the Vaccine Injury Table ("Table"), 42 C.F.R.
§ 100.3(a).
2. Petitioner received the flu vaccination in her left shoulder on October 28, 2022.
3. The vaccine was administered within the United States.
4. Petitioner alleges that she suffered a Shoulder Injury Related to Vaccine
Administration ("SIRVA") within the time period set forth in the Table, 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.
ENV137834 74-6809-CECF-8464-CEAC 09/30/2025 13:50 PM UTC 6. Respondent denies that petitioner sustained a SIRVA Table Injury, denies that
petitioner's alleged shoulder inju1y was caused-in-fact by the flu vaccine, and denies that the flu
vaccine caused petitioner any other injury or her cunent condition.
7. Maintaining their above-stated positions, the patties neve1theless 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-21(a)(l), the Secretary of Health and Human Services will issue
the following vaccine compensation payment:
A lump sum payment of $100,000.00 to be paid through an ACH deposit to petitioner's counsel's IOLTA account for prompt disbursement to petitioner, Jessica Mora. This amount represents compensation for all damages that would be available under 42 U.S.C. § 300aa-l 5(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 pa1ties will submit to fmther proceedings before
the special master to award reasonable attorneys' fees and costs incmTed 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
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
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.
2 ENV13783474-6809-CECF-8464-CEAC 09/30/2025 13:50 PM UTC 11. Payment 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. § 300aa-
15(i), subject to the availability of sufficient statutory funds.
12. The patties and their attorneys fmther 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-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 in-evocably 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
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 Comt of Federal Claims, under the National Vaccine Injury Compensation Program, 42
U.S.C. § 300aa-l 0, 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 flu vaccine administered on or about October 28, 2022, as
alleged by petitioner in a petition for vaccine compensation filed on June 25, 2024, in the United
States Comt of Federal Claims as petition No. 24-965V.
14. If petitioner should die prior to entry of judgment, this agreement shall be voidable
upon proper notice to the Comt on behalf of either or both of the parties.
3 ENV137834 74-6809-CECF-8464-CEAC 09/30/2025 13:50 PM UTC 15. If the Chief Special Master fails to issue a decision in complete confonnity with the
terms of this Stipulation, or if the Comt 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 patty.
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 patt of the
patties 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 vaccine caused petitioner's alleged shoulder
injury or any other injury.
18. All rights and obligations of petitioner hereunder shall apply equally to petitioner's
heirs, executors, administrators, successors, and/or assigns.
END OF STIPULATION
I I I I I I I I I I
ENV137834 74-6809-CECF-8464-CEAC 09/30/2025 13:50 PM UTC Respectfully submitted,
PETITIONER:
JESSICA MORA
ATTORNEY OF RECORD FOR AUTHORIZED REPRESENTATIVE PETITIONER: OF THE ATTORNEY GENERAL:
+Le_d.,~ L P-0.A. ~ ~ Cb-L'd-0 g. €:dh020--- ELIZABETH HESS HEATHER L. PEARLMAN Shannon Law Group, P.C. Deputy Director 530 Oak Comt Dr., Suite 360 Torts Branch Woodridge, IL 60517 Civil Division (312) 578-9501 U.S. Depaitment of Justice ehess@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
Beach -5 Date: 2025 .09.25 for 13:34:08 -04'00' CAPT GEORGE REED GRIMES, MD, MPH Director, Division of Injury A #:f:;;:!/: /~ 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 (202) 616-2895 Rockville, MD 20857 adam.muffett@usdoj.gov
/ _1--+-/_z_5_ Dated: _ t _o___ _
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