-1-

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

__________________________________

(Plaintiff Name(s))

SHORT-FORM COMPLAINT 

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 

Master Personal Injury Complaint (“MPIC”) in In re: Zantac (Ranitidine) Products Lability 

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

by Pretrial Order No. 31. 

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) ____________________ (“Plaintiff(s)”) brings this action (check the

applicable designation):

On behalf of [himself/herself];

In representative capacity as the __________________, on behalf 

of the injured party, (Injured Party’s Name)

___________________.

Ricky Smith

Ricky Smith

✔

Case 9:22-cv-81311-RLR Document 1 Entered on FLSD Docket 08/24/2022 Page 1 of 5
-2-

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) _______________. At the time of 

Decedent’s death, Decedent was a resident and citizen of (City, State)

_________________________.

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 Master Personal Injury

Complaint in this action:

a. Brand Manufacturers:

b. Generic Manufacturers:

c. Distributors:

d. Retailers:

e. Repackagers:

f. Others Not Named in the MPIC:

Oakland, Arkansas

Sanofi-Aventis U.S., LLC; Sanofi US Services, Inc.; Sanofi S.A.; Boehringer Ingelheim Pharmaceuticals, Inc.; Boehringer Ingelheim Corporation;

Boehringer Ingelheim USA Corporation; Boehringer Ingelheim International GmbH; Boehringer Ingelheim Promeco, S.A. de C.V.; GlaxoSmithKline,

LLC; GlaxoSmithKline (America), Inc.; GlaxoSmithKline, PLC; Pfizer, Inc.; Patheon Manufacturing Services, LLC; Thermo Fisher Scientific, Inc.

Dr. Reddy's Laboratories Limited

Sandoz, Inc.

Denton Pharma, Inc., d/b/a Northwind Pharmaceuticals

Golden State Medical Supply, Inc.

Case 9:22-cv-81311-RLR Document 1 Entered on FLSD Docket 08/24/2022 Page 2 of 5
-3-

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]:

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) _______________ to _______________.

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

BRAIN CANCER

BREAST CANCER

COLORECTAL CANCER

ESOPHAGEAL/THROAT/NASAL CANCER

INTESTINAL CANCER

KIDNEY CANCER 

LIVER CANCER

LUNG CANCER

OVARIAN CANCER

PANCREATIC CANCER

PROSTATE CANCER

STOMACH CANCER

1997 2001

✔ September 15, 2015

✔

United States District Court for the Western District of Arkansas, Harrison Division

Case 9:22-cv-81311-RLR Document 1 Entered on FLSD Docket 08/24/2022 Page 3 of 5
-4-

TESTICULAR CANCER

THYROID CANCER

UTERINE CANCER

OTHER CANCER: 

DEATH (CAUSED BY CANCER)

12. Defendants, by their actions or inactions, proximately caused the injuries to

Plaintiff(s).

IV. CAUSES OF ACTION ASSERTED

13. The following Causes of Action asserted in the Master Personal Injury Complaint

are asserted against the specified defendants in each class of Defendants

enumerated therein, and the allegations with regard thereto are adopted in this Short

Form Complaint by reference.

Check if

Applicable

COUNT Cause of Action

I STRICT PRODUCTS LIABILITY – FAILURE TO WARN 

II STRICT PRODUCTS LIABILITY – DESIGN DEFECT

III STRICT PRODUCTS LIABILITY – MANUFACTURING 

DEFECT

IV NEGLIGENCE – FAILURE TO WARN

V NEGLIGENT PRODUCT DESIGN 

VI NEGLIGENT MANUFACTURING 

VII GENERAL NEGLIGENCE 

VIII NEGLIGENT MISREPRESENTATION 

IX BREACH OF EXPRESS WARRANTIES

X BREACH OF IMPLIED WARRANTIES

XI VIOLATION OF CONSUMER PROTECTION AND 

DECEPTIVE TRADE PRACTICES LAWS and specify the state’s 

statute below:

_______________________ Ark. Code Ann. § 4-88-107; Deceptive and Unconscionable Trade Practices

✔

✔

✔

✔

✔

✔

✔

✔

✔

✔

✔

Case 9:22-cv-81311-RLR Document 1 Entered on FLSD Docket 08/24/2022 Page 4 of 5
-5-

Check if

Applicable

COUNT Cause of Action

XII UNJUST ENRICHMENT

XIII LOSS OF CONSORTIUM

XIV SURVIVAL ACTION

XV WRONGFUL DEATH

XVI OTHER: 

XVII OTHER: 

If Count XVI or Count XVII is alleged, additional facts supporting the claim(s): 

V. JURY DEMAND

14. Plaintiff(s) hereby demand(s) a trial by jury as to all claims in this action.

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 

Master Personal Injury Complaint.

5HVSHFWIXOO\6XEPLWWHG

V$GDP7)XQNBBBBBBB

$GDP7)XQN

32776/$:),50

%XIIDOR6SHHGZD\6XLWH

+RXVWRQ7;

7HO

)D[

(PDLODIXQN#SRWWVODZFRP

7H[DV6WDWH%DU1R

Counsel for Plaintiff(s) 

✔

Case 9:22-cv-81311-RLR Document 1 Entered on FLSD Docket 08/24/2022 Page 5 of 5