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

__________________________________

Charles E. Tackett Sr.

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) Charles E. Tackett Sr. (“Plaintiff(s)”) brings this action (check the 

applicable designation): 

On behalf of [himself/herself];

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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) Olive Hill, Kentucky

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: 

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]: 

Kentucky Eastern 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, 1990 to __December 2014_.

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 December 2, 2008

BREAST CANCER

COLORECTAL/INTESTINAL CANCER

ESOPHAGEAL CANCER

GASTRIC CANCER

KIDNEY CANCER 

LIVER CANCER

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 8, 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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