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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

SULTAN SALLAJ, AS ADMINISTRATOR 

OF THE ESTATE OF RIHAB SALLAJ, 

DECEASED 

__________________________________/ 

SHORT-FORM COMPLAINT – VERSION 2

The Plaintiff(s) named below, by counsel, file(s) this Short Form Complaint – Version 2

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) Sultan Sallaj, as Administrator of the Estate of Rihab Sallaj

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

 On behalf of [himself/herself];

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 In representative capacity as the individually and as the limited 

purpose representative on behalf of the injured party, Rihab Sallaj.

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

claims damages as set forth below.

—OR— 

Decedent died on August 27, 2020. At the time of Decedent’s death, Decedent was 

a resident and citizen of New York and resident of Tonawanda. 

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 ____________________. 

5. At the time the alleged injury occurred, Consortium Plaintiff resided in

________________. 

 

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:

Boehringer Ingelheim Pharmaceuticals, Inc.; Boehringer Ingelheim 

Corporation; Boehringer Ingelheim USA Corporation; DSM 

Pharmaceuticals Inc.; GlaxoSmithKline LLC

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]: 

United States District Court for the Western District of New York

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

January 2010 to March 2015. 

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

LUNG CANCER

PANCREATIC CANCER March 2019

PROSTATE CANCER

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OTHER CANCER: 

DEATH (CAUSED BY CANCER) August 27, 2020

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 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. 

14. 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 

 

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

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, 

3 In selecting the relevant states above, Plaintiff reserves all rights to argue choice of law issues at a later 

time. 

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Check 

all that 

apply

Count Cause of Action States for which 

the cause of action 

was asserted in 

the AMPIC

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

XIII Reckless Misrepresentation (Against Brand-Name

Manufacturers by Generic Consumers in 

Massachusetts)

MA only

XIV Unjust Enrichment (Against All Defendants) All States and 

Territories

XV Loss of Consortium (Against All Defendants) All States and 

Territories

XVI Wrongful Death (Against All Defendants) All States and 

Territories

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

 

V. JURY DEMAND

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

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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. 

Respectfully submitted,

/s/ Michael S. Werner

Michael S. Werner

Slater Slater Schulman, LLP

445 Broad Hollow Road, Suite 419 

Melville, New York 11747 

Telephone: (631) 420-9300 

Facsimile: (212) 922-0907 

mwerner@sssfirm.com

Counsel for Plaintiff(s) 

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