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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

__________________________________ 

William Gildea 

SHORT-FORM COMPLAINT – VERSION 3 

The Plaintiff named below, by counsel, files this Short Form Complaint against Defendants 

named below. Plaintiff incorporates 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 files this Short Form Complaint – Version 

3 as permitted by Court’s Orders regarding motions to dismiss and specifically DE 3751 at 1, as 

outlined on page 1 of the SAMPIC. 

Plaintiff selects and indicates 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 shall add and include them herein. 

Plaintiff, by counsel, alleges as follows: 

I. PARTIES, JURISDICTION, AND VENUE

A. PLAINTIFF 

1. Plaintiff William Gildea (“Plaintiff”) brings this action (check the applicable 

designation): 

 On behalf of himself. 

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2. Injured Party is currently a resident and citizen of Stuart, Florida and claims 

damages as set forth below. 

B. DEFENDANT(S) 

3. Plaintiff names the following Defendants from the Amended Master Personal 

Injury Complaint in this action: 

a. Brand-Name Manufacturers: 

AUROBINDO PHARMA USA, INC. 

AUROBINDO PHARMA LTD 

CHATTEM, INC. 

DSM PHARMACEUTICALS INC. 

DR. REDDY’S LABORATORIES, INC. 

DR. REDDY’S LABORATORIES, LTD. 

DR. REDDY’S LABORATORIES LLC 

DR. REDDY’S LABORATORIES, SA 

GERI-CARE PHARMACEUTICALS CORP. 

GLAXOSMITHKLINE LLC 

GLAXOSMITHKLINE (AMERICA) INC. 

GLAXOSMITHKLINE PLC 

GRANULES USA, INC. 

L. PERRIGO CO. 

PFIZER INC 

BOEHRINGER INGELHEIM PHARMACEUTICALS, INC 

BOEHRINGER INGELHEIM INTERNATIONAL GMBH 

BOEHRINGER INGELHEIM PROMECO, S.A. DE C.V. 

BOEHRINGER INGELHEIM CORPORATION 

BOEHRINGER INGELHEIM USA CORPORATION 

PATHEON MANUFACTURING SERVICES LLC 

SANOFI-AVENTIS U.S. LLC 

SANOFI US SERVICES INC. 

STRIDES PHARMA, INC. 

SUN PHARMACEUTICAL 

SUN PHARMACEUTICAL INDUSTRIES, INC. 

TEVA PHARMACEUTICALS U.S.A., INC. 

WOCKHARDT 

b. Generic Manufacturers: 

c. Distributors and Repackager: 

d. Retailers: 

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e. Others Not Named in the AMPIC: 

C. JURISDICTION AND VENUE 

4. 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 SOUTHERN DISTRICT 

OF FLORIDA

5. Jurisdiction is proper upon diversity of citizenship.

II. PRODUCT USE 

6. The Injured Party used Zantac and/or generic ranitidine: [Check all that apply] 

[ ] By prescription 

[X] Over the counter 

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

(month, year) 06/2004 to 02/2020. 

III. PHYSICAL INJURY 

8. As a result of the Injured Party’s use of the medications specified above, he 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 CANCER 

[X] ESOPHAGEAL CANCER 11/27/2013 

[] GASTRIC CANCER 

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[] KIDNEY CANCER 

[] LIVER CANCER 

[] LUNG CANCER 

[] PANCREATIC CANCER 

[] PROSTATE CANCER 

OTHER CANCER: 

DEATH (CAUSED BY CANCER) 

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

Plaintiff. 

IV. CAUSES OF ACTION ASSERTED 

10. 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. 

11. By checking the appropriate causes of action below, Plaintiff asserts 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 

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 

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 

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

V. JURY DEMAND 

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12. Plaintiff hereby demands a trial by jury as to all claims in this action. 

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff has been damaged as a result of Defendants’ actions or inactions 

and demands 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. 

DATED: September 6, 2022. Respectfully Submitted, 

GORDON & PARTNERS, P.A. 

/s/ Trevor M. Gordon 

Trevor M. Gordon, Esq. 

Florida Bar No. 0115121 

4114 Northlake Boulevard

Palm Beach Gardens, FL 33410 

TGordon@fortheinjured.com

Telephone: (561) 799-5070 

Facsimile: (561) 634-2793 

Counsel for Plaintiff 

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