UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN RE: ZANTAC (RANITIDINE) 

PRODUCTS LIABILITY 

LITIGATION 

MDL NO 2924 

20-MD-2924

JUDGE ROBIN L ROSENBERG 

MAGISTRATE JUDGE BRUCE REINHART 

--------------

THIS DOCUMENT RELATES TO: 

JAY VARGAS, SURVIVING SPOUSE 

AND ANTICIPATED 

REPRESENTATIVE AND HEIR TO THE 

ESTATE OF DOROTHYVARGAS 

(Plaintiff Name( s)) 

JURY TRIAL DEMANDED 

SHORT-FORM COMPLAINT 

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 

Master Personal Injury Complaint ("MPIC") in In re: Zantac (Ranitidine) Products Lability 

Litigation, MDL No. 2924 (S.D. Fla). Plaintiff(s) file(s) this Short-Form Complaint as permitted 

by Pretrial Order No. 31. 

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):

D On behalf of [himself/herself]; 

JAY VARGAS, SURVIVING SPOUSE AND ANTICIPATED REPRESENTATIVE AND HEIR TO 

THE ESTATE OF DOROTHYVARGAS 

Case 9:22-cv-81361-RLR Document 1 Entered on FLSD Docket 09/02/2022 Page 1 of 8
In representative capacity as the ________ , on behalf 

of the injured party, (Injured Party's Name) 

2. Injured Party 1s currently a resident and citizen of (City, State)

___________ and claims damages as set forth below.

-ORDecedent died on (Month, Day, Year) _

Ju

_

I ___ 

2

_

5 __ 

20

_

1

_

9 __ 

. At the time of 

Decedent's death, Decedent was a resident and citizen of (City, State) 

San Diego CA 

If any party claims loss of consortium, 

3. Jay Vargas ("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) San Diego CA

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

San Diego CA

B. DEFENDANT(S)

6. Plaintiff(s) name(s) the following Defendants from the Master Personal Injury

Complaint in this action:

a. Brand Manufacturers:

GlaxoSmithKline LLC

2 

surviving spouse and anticipated representative 

and heir to the estate

Dorothy Vargas

; and John Doe

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b. Generic Manufacturers:

c. Distributors:

d. Retailers:

e. Repackagers:

f. Others Not Named in the MPIC:

3 

John Doe

John Doe

John Doe

John Doe

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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]:

------

Southern District of CA----

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]

00 By prescription 

D Over the counter 

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

(month, year) Nov 2014 to Jul 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 Cancer Type Approximate Date of 

that Diagnosis 

apply 

□ BLADDER CANCER

□ BRAIN CANCER

□ BREAST CANCER

□ COLORECTAL CANCER

4 

Case 9:22-cv-81361-RLR Document 1 Entered on FLSD Docket 09/02/2022 Page 4 of 8
Check all Cancer Type Approximate Date of 

that Diagnosis 

aoolv 

!RI ESOPHAGEAL/THROAT/NASAL CANCER Nov 28 2018 

□ INTESTINAL CANCER

□ KIDNEY CANCER

□ LIVER CANCER

□ LUNG CANCER

□ OVARIAN CANCER

□ PANCREATIC CANCER

□ PROSTATE CANCER

□ STOMACH CANCER

□ TESTICULAR CANCER

□ THYROID CANCER

□ UTERINE CANCER

□ OTHER CANCER:

!RI DEATH (CAUSED BY CANCER) Jul 25 2019 

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

Plaintiff(s)

5 

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IV. CAUSES OF ACTION ASSERTED

13. The following Causes of Action asserted in the 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.

Check if COUNT Cause of Action 

Applicable 

!Kl I STRICT PRODUCTS LIABILITY - FAILURE TO WARN 

!Kl II STRICT PRODUCTS LIABILITY - DESIGN DEFECT 

!Kl III STRICT PRODUCTS LIABILITY - MANUFACTURING 

DEFECT 

!Kl IV NEGLIGENCE - FAILURE TO W ARN 

!Kl V NEGLIGENT PRODUCT DESIGN 

!Kl VI NEGLIGENT MANUFACTURING 

!Kl VII GENERAL NEGLIGENCE 

!Kl VIII NEGLIGENT MISREPRESENTATION 

!Kl IX BREACH OF EXPRESS WARRANTIES 

!Kl X BREACH OF IMPLIED WARRANTIES 

VIOLATION OF CONSUMER PROTECTION AND 

□ XI DECEPTIVE TRADE PRACTICES LAWS and specify the state's 

statute below: 

!Kl XII UNJUST ENRICHMENT 

!Kl XIII LOSS OF CONSORTIUM 

!Kl XIV SURVIVAL ACTION 

!Kl xv WRONGFUL DEATH 

□ XVI OTHER: 

□ XVII OTHER: 

□ XVIII OTHER: 

6 

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If Count XVI, Count XVII or Count XVIII is alleged, additional facts supporting the 

claim(s): 

7 

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V. JURY DEMAND

14. Plaintiff(s) hereby demand(s) a trial by jury as to all claims in this action.

VI. PRAYERFORRELIEF

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 Master 

Personal Injury Complaint. 

Attorney 1 Signature: __________ _ 

Attorney 1 Print: ____________ _

Attorney 2 Signature:. __________ _ 

Attorney 2 Print:. ____________ _ 

Firm: ----------------

Address 1: ---------------

Address 2: ---------------

City:-----------­

State: ------------

Zip: _____ 

Email: ----------------

Phone: ----------

8 

Attorney 1 Signature: __________ _ 

Attorney 1 Print:. ____________ _ 

Attorney 2 Signature:__________ _ 

Attorney 2 Print:. ____________ _ 

Firm: ----------------

Address 1: ---------------

Address 2: ---------------

City:-----------­

State: ------------

Zip: _____ _ 

Email: ----------------

Phone: ----------

/s/ Daniel A. Nigh

Daniel A. Nigh, Esq.

Levin Papantonio

316 S. Baylen St., Ste. 600

Pensacola

FL

32502

dnigh@levinlaw.com

850-435-7013

/s/ Madeline E. Pendley

Madeline E. Pendley

Levin Papantonio

316 S. Baylen St., Ste. 600

Pensacola

FL

32502

mpendley@levinlaw.com

850-435-7003

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