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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

Mark Moore

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) Mark Moore (“Plaintiff(s)”) bringsthis 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 Farmville, North 

Carolina and claims damages as set forth below.

—OR—

Decedent died on N/A . At the time of Decedent’s death, Decedent 

was a resident and citizen of (City, State) N/A .

If any party claims loss of consortium,

3. N/A 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) N/A .

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

State)

N/A .

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;

GLAXOSMITHKLINE (AMERICA)INC.;

GLAXOSMITHKLINE PLC;

BOEHRINGER INGELHEIM PHARMACEUTICALS, INC.; 

BOEHRINGER INGELHEIM CORPORATION; 

BOEHRINGER INGELHEIM USA CORPORATION; 

SANOFI-AVENTIS U.S. LLC;

SANOFI US SERVICES INC.;

CHATTEM, INC.;

PATHEON MANUFACTURING SERVICES LLC

b. Generic Manufacturers:

c. Distributors and Repackager:

d. Retailers:

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e. Others Not Named in the AMPIC: 

DOES 1-100

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 EASTERN 

DISTRICT OF NORTH CAROLINA

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] 

[X] By prescription

[ ] Over the counter

10. The Injured Party used Zantac and/or generic ranitidine from approximately 

(month, year) 01/2014 to 11/2019.

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

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[] BREAST CANCER

[] COLORECTAL CANCER

[] ESOPHAGEAL CANCER

[X] GASTRIC CANCER 11/01/2019

[] 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 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

1 In selecting the relevant states above, Plaintiffs reserve 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

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

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

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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.

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 abovereferenced causes of action, jointly and severally to the full extent available in law or equity, 

as requested in the Amended Master Personal Injury Complaint.

DATED: 29th day of October, 2022 Respectfully Submitted,

/s/ Paige N. Boldt

Paige N. Boldt

Texas State Bar No. 24082626 

Mikal C. Watts

Texas State Bar No. 20981820 

Alicia D. O’Neill

Texas State Bar No. 24040801

WATTS GUERRA, LLC

5726 West Hausman Rd., Suite 119 San 

Antonio, Texas 78249

Phone: (210) 447-0500

Fax: (210) 447-0501

pboldt@wattsguerra.com

mcwatts@wattsguerra.com

aoneil@wattsguerra.com

Counsel for Plaintiff

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