on behalf of his heirs, executors, administrators, successors and/or

assigns, does forever irrevocably and unconditionally release, acquit and discharge the United

States and the Secretary of Health and Human Services from any and all actions or causes of

action (including agreements, judgments, claims, damages, loss of services, expenses and all

demands of whatever kind or nature) that have been brought, could have been brought, or could

be timely brought in the Court of Federal Claims, under the National Vaccine Injury

Compensation Program, 42 U.S.C. § 300aa-10 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 vaccination administered on or

about September 24, 2016, as alleged by petitioner inof 1987, Mortimer began working at the Riviera Apartments. Riviera carried no worker's compensation insurance.
Starting in September of 1987 until April 7, 1988, Mortimer performed various maintenance and remodeling jobs at Riviera. On April 7, 1988, Mortimer and another man were measuring the roofs on each of the garages at Riviera in order to determine how much material would be required to re-roof the garages. Mortimer stepped backwards off of a roof and suffered extensive injury.
After a hearing on the question of liability, the Commission concluded that Mortimer was an employee of Riviera and that Mortimer's injury arose out of and during the course of his employment. In so holding, the Commission rejected Riviera's claims that Mortimer was either an employee of First Financial Corporation or an independent