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

__________________________________

Tricia Brown and Carl Brown

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) Tricia Brown (“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) Rock Hill, South 

Carolina, 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. _Carl Brown___________ (“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) ____Rock Hill, South 

Carolina______________.

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

____ Rock Hill, South Carolina ____________. 

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:

1) Glaxo Smith Klein; 

2) Patheon Manufacturing Service, LLC

3) Boehringer Ingelheim Pharmaceuticals, Inc.; 

4) Pfizer, Inc

5) Sanofi U.S. Services Inc.

6) Chattem, Inc.

b. Generic Manufacturers:

c. Distributors and Repackager:

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d. Retailers:

e. Others Not Named in the AMPIC:

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]: 

Alabama Northern 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, 2002 to __October, 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

BREAST CANCER

COLORECTAL/INTESTINAL CANCER

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ESOPHAGEAL CANCER

GASTRIC CANCER

KIDNEY CANCER 

LIVER CANCER

LUNG CANCER

PANCREATIC CANCER 08/01/2018

PROSTATE CANCER

OTHER CANCER: Stomach Cancer 08/01/2018

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

South Carolina

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

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

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

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

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Plaintiff Carl Brown suffered loss of marital services as a result of the 

cancer injuries caused to his Wife, Tricia Brown.

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 

Amended Master Personal Injury Complaint. 

September 6, 2022

/s/ Christopher LoPalo

Christopher LoPalo

NAPOLI SHKOLNIK, PLLC

360 Lexington Avenue, Suite 1101

New York, NY 10017

Tel: (212) 397-0000

Fax: (646) 843-7603

CLoPalo@napolilaw.com

Attorneys for Plaintiff

 Counsel for Plaintiff(s)

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