UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN RE: ZANTAC (RANITIDINE) MDL NO 2924 

PRODUCTS LIABILITY 20-MD-2924 

LITIGATION 

 JUDGE ROBIN L ROSENBERG 

 MAGISTRATE JUDGE BRUCE REINHART 

__________________________________/ 

THIS DOCUMENT RELATES TO: JURY TRIAL DEMANDED

__________________________________

Jerry Pugh as the proposed personal 

representative of the Estate of Pamela McMahan 

SHORT-FORM COMPLAINT – VERSION 2 

The Plaintiff(s) named below, by counsel, file(s) this Short Form Complaint against 

Defendants named below. Plaintiff(s) incorporate(s) by reference the allegations contained in the 

Amended Master Personal Injury Complaint (“AMPIC”) in In re: Zantac (Ranitidine) Products 

Lability Litigation, MDL No. 2924 (S.D. Fla). Plaintiff(s) file(s) this Short-Form Complaint –

Version 2 as permitted by Pretrial Order No. 31 and as modified by the Court’s Orders regarding 

motions to dismiss [DE 2532, 2512, 2513, 2515, and 2016]. 

Plaintiff(s) select(s) and indicate(s) by completing where requested, the Parties and Causes 

of Actions specific to this case. Where certain claims require additional pleading or case specific 

facts and individual information, Plaintiff(s) shall add and include them herein. 

Plaintiff(s), by counsel, allege as follows: 

I. PARTIES, JURISDICTION, AND VENUE

A. PLAINTIFF(S) 

1. Plaintiff(s) Jerry Pugh. (“Plaintiff(s)”) brings this action (check the applicable 

designation): 

 On behalf of [himself/herself]; 

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 In representative capacity as Proposed personal representative of 

the Estate _ on behalf of the injured party, (Injured Party’s Name) 

Pamela McMahan.

2. Injured Party is currently a resident and citizen of (City, State) _______________ 

and claims damages as set forth below. 

—OR—

Decedent died on (Month, Day, Year) October 6, 2008. At the time of Decedent’s 

death, Decedent was a resident and citizen of (City, State) Campobello, South 

Carolina. 

If any party claims loss of consortium, 

3. (“Consortium Plaintiff”) alleges damages for loss of consortium. 

4. At the time of the filing of this Short Form Complaint, Consortium Plaintiff is a 

citizen and resident of (City, State) ___________________. 

5. At the time the alleged injury occurred, Consortium Plaintiff resided in (City, State) 

. 

 

B. DEFENDANT(S) 

6. Plaintiff(s) name(s) the following Defendants from the Amended Master Personal 

Injury Complaint in this action: 

a. Brand-Name Manufacturers: 

GlaxoSmithKline, LLC; 

Pfizer, Inc. 

Boehringer Ingelheim Pharmaceuticals, Inc. 

b. Generic Manufacturers: 

c. Distributors and Repackager: 

d. Retailers: 

e. Others Not Named in the AMPIC: 

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C. JURISDICTION AND VENUE 

7. Identify the Federal District Court in which Plaintiff(s) would have filed this action 

in the absence of Pretrial Order No. 11 (direct filing) [or, if applicable, the District 

Court to which their original action was removed]: 

South Carolina District Court. 

8. Jurisdiction is proper upon diversity of citizenship.

II. PRODUCT USE 

9. The Injured Party used Zantac and/or generic ranitidine: [Check all that apply] 

 By prescription 

 Over the counter 

10. The Injured Party used Zantac and/or generic ranitidine from approximately 

(month, year) January, 2004 to __October, 2009_.

III. PHYSICAL INJURY 

11. As a result of the Injured Party’s use of the medications specified above, [he/she] 

was diagnosed with the following specific type of cancer (check all that apply): 

Check all 

that 

apply 

Cancer Type Approximate Date of 

Diagnosis

BLADDER CANCER 

BREAST CANCER 

COLORECTAL/INTESTINAL CANCER 

ESOPHAGEAL CANCER 

GASTRIC CANCER 

KIDNEY CANCER 

LIVER CANCER August 1, 2008 

LUNG CANCER 

PANCREATIC CANCER 

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VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff(s) has/have been damaged as a result of Defendants’ actions or 

inactions and demand(s) judgment against Defendants on each of the above-referenced causes of 

action, jointly and severally to the full extent available in law or equity, as requested in the 

Amended Master Personal Injury Complaint. 

September 9, 2022 

/s/ Christopher LoPalo 

Christopher LoPalo 

NAPOLI SHKOLNIK, PLLC 

400 Broadhollow Rd, Suite 305 

Melville, NY 11747 

Tel: (212) 397-0000 

Fax: (646) 843-7603

CLoPalo@napolilaw.com

Attorney for Plaintiff

 

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