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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

__________________________________ 

(Plaintiff Name(s))

SHORT-FORM COMPLAINT – VERSION 3 

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 

Second Amended Master Personal Injury Complaint (“SAMPIC”) in In re: Zantac (Ranitidine)

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

Complaint – Version 3 as permitted by the Court’s Orders regarding motions to dismiss and 

specifically DE 3751 at 1, as outlined on page 1 of the SAMPIC.

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];

Jonathan Payne

Jonathan Payne

X

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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 Second Amended Master

Personal Injury Complaint in this action:

a. Brand-Name Manufacturers:

b. Others Not Named in the SAMPIC:

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.

Boehringer Ingelheim, Chattem, Inc., and Sanofi

DSM Pharmaceuticals Inc., and Walgreen Co.

United States District Court for the Northern District of New York

Syracuse, New York

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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

GASTRIC CANCER

KIDNEY CANCER 

LIVER CANCER

LUNG CANCER

PANCREATIC CANCER

PROSTATE 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 Second Amended Master Personal

Injury Complaint are asserted against Defendants, and the allegations with regard

thereto are adopted in this Short Form Complaint by reference.

X

January 2013 December 2018

X December 18, 2019

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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 SAMPIC

I Strict Products Liability – Failure to Warn through 

Warnings and Precautions 

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA

II Negligence – Failure to Warn through Warnings 

and Precautions 

All States and 

Territories, Except 

LA, NJ, OH, and 

WA

III Strict Products Liability – Failure to Warn through 

Proper Expiration Dates 

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA

IV Negligence – Failure to Warn through Proper 

Expiration Dates 

All States and 

Territories, Except 

LA, NJ, OH, and 

WA

V Strict Products Liability – Design Defect Due to 

Warnings and Precautions

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA

VI Strict Products Liability – Design Defect Due to 

Improper Expiration Dates 

All States and 

Territories, Except 

DE, IA, MA, NC, 

PA, and VA

VII Negligent Failure to Test KS, TX

VIII Negligent Product Containers2 All States and 

Territories

IX Negligent Storage and Transportation All States and 

Territories

X Unjust Enrichment (Against All Defendants) All States and 

Territories

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

Territories

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

a later time. 

2 This Count applies only to pills, not ranitidine-containing products in the form of syrups or 

injections. 

X

X

X

X

X

X

X

X

X

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Check 

all that 

apply

Count Cause of Action States for which 

the cause of action 

was asserted in 

the SAMPIC

XII Survival Actions All States and 

Territories

XIII Wrongful Death All States and 

Territories

V. JURY DEMAND

15. 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 Second 

Amended Master Personal Injury Complaint. 

Dated: November 17, 2022

/s/ Randi Kassan

Randi Kassan, Esq.

MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN, PLLC

100 Garden City Plaza, Suite 500

Garden City, NY 11530

Telephone: (516) 741-5600

Fax: (516) 741-0128

rkassan@milberg.com

Counsel for Plaintiff(s) 

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