UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

 MDL NO 2924 

20-MD-2924

 JUDGE ROBIN L ROSENBERG

 MAGISTRATE JUDGE BRUCE REINHART

JURY TRIAL DEMANDED

IN RE: ZANTAC (RANITIDINE)

PRODUCTS LIABILITY

LITIGATION

__________________________________/

THIS DOCUMENT RELATES TO: 

__________________________________

(Plaintiff Name(s)) 

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) _________________________________________________________

(“Plaintiff(s)”) brings this action (check the applicable designation):

On behalf of [himself/herself];

1

Terry Derossett

Terry Derossett ✘

Case 9:22-cv-81581-RLR Document 1 Entered on FLSD Docket 10/14/2022 Page 1 of 9
In representative capacity as the __________________, on behalf 

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

___________________.

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 Amended Master 

Personal Injury Complaint in this action:

a. Brand-Name Manufacturers: 

2

Louisa KY

Boehringer Ingleheim Pharmaceuticals, Inc.

Boehringer Ingleheim USA Corporation

Boehringer Ingleheim Corporation

GlaxoSmithKline Inc.

GlaxoSmithKline LLC

Pfizer, Inc.

Sanofi US Services, Inc.

Sanofi-Aventis U.S. LLC

Pantheon Manufacturing Service LLC

Case 9:22-cv-81581-RLR Document 1 Entered on FLSD Docket 10/14/2022 Page 2 of 9
b. Generic Manufacturers:

c. Distributors and Repackager:

d. Retailers:

e. Others Not Named in the AMPIC:

3

AmerisourceBergen Corporation Wal-Mart

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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]:

______________ District of _______

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

BREAST CANCER

COLORECTAL/INTESTINAL CANCER 

ESOPHAGEAL CANCER 

4

Eastern KY ✘

Jan 1995 Dec 2018 ✘ Oct 19 2021

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

Plaintiff(s)

Check all 

that 

apply 

Cancer Type Approximate Date of 

Diagnosis 

KIDNEY CANCER 

LIVER CANCER

LUNG CANCER

PANCREATIC CANCER

PROSTATE CANCER

GASTRIC CANCER 

OTHER CANCER: 

DEATH (CAUSED BY CANCER)

13.

IV. CAUSES OF ACTION ASSERTED

The following Causes of Action asserted in the Amended 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.

By checking the appropriate causes of action below, Plaintiff(s) assert these causes

of action based upon the law and applicable Sub-Counts of the following state(s):1

1

In selecting the relevant states above, Plaintiffs reserve all rights to argue choice of law issues at 

a later time.

14.

Check 

all that 

apply 

Count Cause of Action States for which 

the cause of action 

was asserted in 

the AMPIC 

I Strict Products Liability – Failure to Warn through 

Warnings and Precautions (Against Brand-Name 

Manufacturer Defendants) 

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA 

5

✘

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Check 

all that 

apply 

Count Cause of Action States for which 

the cause of action 

was asserted in 

the AMPIC 

II Negligence – Failure to Warn through Warnings 

and Precautions (Against Brand-Name 

Manufacturer Defendants) 

All States and 

Territories, Except 

LA, NJ, OH, and 

WA 

III Strict Products Liability – Failure to Warn through 

Proper Expiration Dates (Against Brand-Name and 

Generic Manufacturer Defendants) 

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA 

IV Negligence – Failure to Warn through Proper 

Expiration Dates (Against Brand-Name and 

Generic Manufacturer Defendants) 

All States and 

Territories, Except 

LA, NJ, OH, OK, 

and WA 

V Negligence - Failure to Warn Consumers through 

the FDA (Against Brand-Name and Generic 

Manufacturer Defendants) 

CA, DE, DC, HI, 

IN, KY, LA, MD, 

MA, MN, MO, 

NV, NY, OR, and 

PA 

VI Strict Products Liability – Design Defect Due to 

Warnings and Precautions (Against Brand-Name 

Manufacturer Defendants) 

All States and 

Territories, Except

DE, IA, MA, NC, 

PA, and VA

VII Strict Products Liability – Design Defect Due to 

Improper Expiration Dates (Against Brand-Name 

and Generic Manufacturer Defendants) 

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA 

VIII Negligent Failure to Test (Against Brand-Name 

and Generic Manufacturer Defendants) 

KS, TX 

IX Negligent Product Containers: (Against BrandName and Generic Manufacturers of pills) All States and 

Territories 

X Negligent Storage and Transportation Outside the 

Labeled Range (Against All Retailer and 

Distributor Defendants) 

All States and 

Territories 

XI Negligent Storage and Transportation Outside the 

Labeled Range (Against All Brand-Name and 

Generic Manufacturer Defendants) 

All States and 

Territories 

XII Negligent Misrepresentation (Against Brand-Name 

Manufacturers by Generic Consumers in 

California) 

CA only 

Reckless Misrepresentation (Against Brand-Name 

Manufacturers by Generic Consumers in 

Massachusetts) 

XIII MA only 

6

✘

✘

✘

✘

✘

✘

✘

✘

✘

Case 9:22-cv-81581-RLR Document 1 Entered on FLSD Docket 10/14/2022 Page 6 of 9
If Count XV or Count XVI is alleged, additional facts supporting the claim(s):

Check 

all that 

apply 

Count Cause of Action States for which 

the cause of action 

was asserted in 

the AMPIC 

XIV 

XV 

XVI 

Unjust Enrichment (Against All Defendants) 

Loss of Consortium (Against All Defendants) 

Wrongful Death (Against All Defendants) 

All States and 

Territories 

All States and 

Territories 

All States and 

Territories 

Other

7

✘

✘

Kentucky Consumer Protection Act, Ky. Rev. Stat.

§§367.110 et seq.

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V. JURY DEMAND

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

Pursuant to PTO 13, if this is an amended Short Form Complaint, specify all 

changes made to the prior version of the Short Form Complaint, with citations 

to the paragraphs that have been changed:

8

Case 9:22-cv-81581-RLR Document 1 Entered on FLSD Docket 10/14/2022 Page 8 of 9
Attorney 1 Signature:__________________________

Attorney 1 Print:______________________________

Attorney 2 Signature:__________________________

Attorney 2 Print:______________________________

Firm: ______________________________________

Address 1: __________________________________

Address 2: __________________________________

City: ____________________________

State: ___________________________

Zip: _____________

Email: _____________________________________

Phone: ______________________

Attorney 1 Signature:__________________________

Attorney 1 Print:______________________________

Attorney 2 Signature:__________________________

Attorney 2 Print:______________________________

Firm: ______________________________________

Address 1: __________________________________

Address 2: __________________________________

City: ____________________________

State: ___________________________

Zip: _____________

Email: _____________________________________

Phone: ______________________

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. 

9

James E. Douglas, Jr. James E. Douglas, Jr. M. Brandon Smith M. Brandon Smith Childers, Schlueter & Smith, LLC 1932 North Druid Hills Road Atlanta Georgia 30319 jdouglas@cssfirm.com 4044199500

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